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
Territory of Washington County of Spokane} ss
I J. Kennedy Stout being first duly sworn say: I am one of the attorneys of defendant herein. I believe defendant cannot have a fair trial in this cause in Spokane County because of the excitement and prejudice of the people of the court, against her and the reasons of such belief are fully set forth in the affidavit of Thomas C. Griffitts herein, which I have heard read and most of the facts therein stated I know to be true of my own knowledge and expressing the facts stated therein as to what occured at the preliminary examination of defendant and in procuring her bail, I know of my own knowledge and that same are true, I was extensively acquained in Spokane County and during said preliminary examination and since I have conversed with a great many men and women resident in said county and have heard many false and exagerated statements of what purported to be the facts in this case and have often heard it stated that defendant had therefore murdered her husband and had murdered two men and one woman in Montana, and that she was a dangerous, quarrelsome women cruel and wanton in the use of firearms and many other statements prejudicial to deft and have heard many expressions of bitter prejudice against defendant and an almost universal expression of belief in her guilt of the offense with which she is charged in this indictment and have heard many persons say if she was not guilty she ought to be hung anyhow on general principles and from such conversations and all that I know concerning the feelings and opinions of the people of said county I am convinced and verily believe that defendant cannot have a fair trial in said Spokane County in this case and that a change of the place of trial is necessary in order that she may be tried by disinterested triers.
I do not believe that a jury of twelve men could be drawn in this court, leaving out the recognized criminal or outlaw element who would dare acquit defendant if the territory failed to make out any case against her, on account of fear of general abuse afterwards, and reproaches from the public and their own families.
J. Kennedy Stout
Subscribed and sworn to before me this 2d day of December 1886
Thomas C. Griffitts
Notary Public
Terr. of Washington
vs.
Ray Raymond
Affidavit of
J. Kennedy Stout
Filed Dec. 4, 1886
D.A. Clement
Clerk
