Territory of Washington
County of Spokane}
In the District Court of the
4th Judicial district
holding terms at county
seat of Spokane County
Territory of Washington
vs.
Ray Raymond Defendant
Territory of Washington County of Spokane W.T. Ray Raymond being first fuly sworn on my oath state: I am defendant above named and I am not guilty of the crime with which I am charged in this indictment nor of any offense therein contained against the laws of Washington Territory. I believe I cannot have a fair trial of this cause in the county of Spokane on account of and owing to the prejudice and excitement against me in and among the inhabitants of said County, and I ask to be tried by disinterested triers. That among the facts upon which such belief is founded I state the following:
I have a number of bitter personal enemies
in the city of Spokane Falls in said County, whom
am informed and believe, and upon such information
and belief allege have ever since I was
accused of this crime busied themselves
industriously circulating false statements
purporting to be the facts relating to this case
and also in circulating rumors and false
to the effect that I am a dangerous and quarrelsome
attention and given to the wanton and reckless
use of firearms, and so persistently has this
statement been made that many good people of the
county have come to believe it and to repeat it
as true; that many false and, malicious statements
and charges against this defendant have been
circulated among the inhabitants of said
county among which I am informed
and believe, and upon that information
and belief alleges that since I was accused
of the crime it has been circulated
among and is generally believed by
the people of the county, that I had therefore
murdered my husband and had
killed two men & one woman in
matters are of which are wholly false
but have tended greatly to excite and
prejudice the people of the court, against
me that many false and exagerated
and highly colored and prejudicial
account, purporting to be the facts
in this case have been invented
among the people of the county among
other false and untrue statements
purporting to be the facts in this case
circulated since I was accused of
this crime was is the following
I am informed and believe, and upon such information and belief allege that one George Ferster, who appearing as a special prosecuter against me at the hearing of the habeas corpus application to admit me to bail heard before this court about the thing of such having stated That the prosecution had witnesses to prove that at the time of the killing with which I am charged the deceased was in the hallway of the "Bay Window" house and near the door and that two men had hold of him putting him out and had [?] him to his knees and had hold of him and that this affiant came out of her room with a loaded and cocked revolver and said [?] him I'll fix him and thrusting the revolver in his throat fired the shot that killed him applicant here states politely that such statement of the facts in this and is wholly untrue and alleges upon her information and belief that the prosecution never at any time had any person who could swear his was part of it many thing resembling it applicant is further informed and believes that this story was circulated among the people of this county until many good people came to believe it to be the true statement of facts in the case, and am greatly prejudiced against defendant by reason thereof that whether or not said special prosecutor was employed against defendant volunteered to prosecute her affiant does not know but affiant has been informed and believes that citizens of Spokane Falls attempted to employ special council to assist in her prosecution.
Applicant further states that during the time of the
preliminary hearing of this case before justices
Peel and Booge she heard many expressions
of bitter prejudice against her from
among the crowd of people in attendance
and heard the crowd stomp their feet
in approval of the final determination
of such hearing justices in holding
defendant for murder in the first degree
without bail and during said
hearing witnessed many strong
manifestations of prejudice and
excitement against her and
was became alarmed for her own
safety, applicant has heard and the affidavit
of her attorney Thomas C. Griffitts hearin and
knows many of the facts therin stated concerning
the occurances at the preliminary hearing
before said Justices of her own knowledge,
and concerning the publications in
the newspaper therin referred to
and knows such statement to be true
and she refuted said affidavit and
to the affidavit of her other comments
herein filed and to the other affidavit
filed in support of this motion force
were specific statement of the
facts and circumstances upon which she
bases her belief in the prejudice of the people –
I have stated the facts constituting my defenses
herin truly and fully to my council in this
cause and endorsed[?] by them that I have a
good defense and one that can be made available
herein if I can have a fair trial; that this application
is not made for delay but
in good faith and that Justice may be
done.
Ray Raymond
Subscribed and sworn to before me this 2nd day of Dec. 1886
J. Kennedy Stout
Notary Public
Wash. Terr.
Terr. of Washington
vs.
Ray Raymond
Deft.
Affidavit
Ray Raymond
Filed Dec. 4 1886
D.A. Clement
Clerk
