Territory of Washington
County of Spokane} ss
In the District Court of the 4th Judicial District
holding terms at County
Seat of Spokane County
Territory of Washington
vs. Plaintiff
Ray Raymond Defendant
Territory of Washington}
County of Spokane} ss
J. Kennedy Stout and Thomas C.
Griffitts, being first duly sworn on oath state
we have had the affidavit of T. Donalson
George Wycoff and S.C. Hyde herein filed
and know the contents thereof. That they
and each of them were present together at
the interview between them & said Donalson
at his home in Richland Precinct and at
the interview at the home of defendant
spoken of in the said affidavit of Donalson.
That said first conversation took
place on the 9th day of August 1886.
The affiants were led to find said Donalson
by information received by them that
he had declared he was present at time
of the shooting that in said interview said
Donalson did not know affiant that Wycoff
witnessed the killing, but on the contrary
did tell them that he occupied a position
where it would have been impossible for
him to have seen any part of the scuffle or
shooting or that it would not
be worth her while to see Wycoff as he
knew nothing about it and subsequently
and about the time of the interview
at the "Bay Windows" spoken of in Donalson
affidavit said Donalson himself
told affiants that said Wycoff was
gone from his home and to Walla
Walla County somewhere harvesting
or threshing and as soon as he
knew of his return would inform
affiant and he never did inform affiants
that he had so returned until
after the finding of this indictment.
That in said interview in Richland
Precinct said Donalson did not tell affiants
that he witnessed said shooting
but made quite contrary statements to
thos and while alleying he was present
his statement were so contradictory and
[?] and so contradictory
of known facts in the case that affiants
can obtain no such
statement from him whereupon he declared if
he could see the premises he would explain
and reconcile his testimony and it
was pursuant thereto that the interview was
held in the "Bay Windows" and which considered
as well as the statement again to Donalson what he [?]
of a view of the premises, that the statements of
said Donalson were not in any manner cleared
up by suck view of the presmises but appeared
here inconsistent than ever or such as
That in several days after the finding of this indictment
affiant Thomas C. Griffitts came from
said Donaldson.
That several days after the finding
of this indictment affiants think
as late at the 8th day of this month that
affiants learned that said Donalson
would be a witness
for the prosecution and that he
claimed to be an eye-witness to the
shooting and this was the first any of defendants
counsel or defendant knew that he
would be a witness against defendent in this cause or
That they did not know said Wycoff by sight
nor did they know any one except Donaldson who did know him by sight
and had no means of finding him
until after they were informed by the sheriff that
and neither of affiants ever saw him to know him until he was called up in court this morning
he was on Spokane Falls which was about
the time stated in their previous affidavit
herein, that defendants counsel were well
known to all persons in attendance upon
this court and said Wycoff did not make himself
known either to defendant or any of
her counsel although subpoenas to attend
at her behalf, that the prosecuting attorney has
never notified defendant or her attorneys of his
purpose to use said witnesses Donalson
& Wycoff or either of them or of what he expected
to prove by them and they only learned of at first
incidentally and inquiry disclosed the fact that
they were Donalson was so attending
this court for said purpose. That the presence
of said Donalson in Spokane Falls and about
the court room did not inform affiants of
any thing as his presence in Spokane Falls
was not unusual.
J. Kennedy Stout
Thomas C. Griffitts
Subscribed and sworn to before me that 16th day of December 1886
Frank H Lewis
Notary Public
Wash Ter
1886
Aff Stout[?] Griffitts
Filed Dec. 16, 1886
D.A. Clement
Clerk
