Territory of Washington
County of Spokane} ss
In the District Court, Fourth Judicial District holding terms at Spokane Falls.
The Territory of Washington
vs.
Ray Raymond
I, S.C. Hyde, being duly
sworn on my oath do
depose and say: That I
have read the affidavit
of T.C. Griffitts, N. T. Caton
J. Kennedy Stout, Frederick
Stanford, and Ray Raymond,
filed herein. That
the reason why T. Donaldson
and George Wycoff were not
called as witnesses to testify
in this action before
the committing magistrates
and Grand Jury is because
this affiant has no knowledge
that there were
any such persons, or
that they were present
at the killing of James
Finch, or had any information
that they had
any knowledge concerning
the same; and applicant
verily believes that none
of the grand jurors belonging
to the grand jury
which found the indictment
in this action had
any information thereof.
That affiant was first
informed that said T.
Donaldson and George
Wycoff had knowledge
of the facts and circumstances
concerning the
killing of said James Finch
on after the finding of
the indictment herein.
That I thereupon, immediately
upon receiving such
information caused subpoenas
to issue for
their appearance before
our said court to testify
in this action. That
I have never had any
communication whatever
with said witnesses or either
of them prior to their
appearance at this
time of court as witnesses
in this action.
That none of defendants
counsel have ever inquired
of me concerning
the testimony of said
witnesses or their knowledge
of the facts, relating
to the killing of James
Finch. That if they or
either of them had done
so, affiant would have
given them such information
as he possessed concerning
the same, or would
have made such counsel
of defendant acquainted
with said witnesses
and given them an opportunity
to inquire of
said witnesses conerning
the same. That
affiant is now ready
and willing to make defendants
counsel acquainted
with said witnesses
to the end that they
may become inquire
of said witnesses of their
knowledge of the facts
relating to the killing
of said Finch, to the
end that they may
become informed thereof.
Affiant further deposes and
says: That it is not true
that strong prejudice and
great excitement exists
against defendant in Spokane
county and affiant
further avows that the
defendant can have a
fair just and impartial
trial at this term of court;
and in support of this
statement affiant submits
the affidavits heretofore
filed in this action by
the Territory, upon the
application of defendant
for a change of venue,
and makes said affidavits
a part of this showing.
Affiant further saith that he is acquainted with Charles Wilson mentioned in affidavit of Ray Raymond, that he said Wilson has been present in Spokane Falls up to the last three or four days. That said Wilson and said Ray Raymond are, as affiant is informed and verily believes, acquainted with said Ray Raymond, and that he has often conversed with her, and in all probability has often conversed with her concerning the facts in this. That said Charles Wilson has up to within a short time ago been a hack driver in this city.
S.C. Hyde
Subscribed and sworn to before me this 16th day of Dec. 1886
D.A. Clement
Clerk
Aff-
S.C. Hyde
Filed Dec. 16, 1886
D.A. Clement
Clerk
