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then now

October 2, 2017 Respectfully submitted by:

John C. Williams
Scott W. Braden
Assistant Fed. Public Defenders
1401 West Capitol, Suite 490
Little Rock, AR 72201

Application for Clemency .............................................................................................. 1

Reasons for Granting Clemency .................................................................................... 2

I. JACKS EXTREME MENTAL ILLNESS WARRANTS MERCY ........................................ 3

II. JACKS LIFE HISTORY PRESAGED HIS CURRENT ILLNESS ................................... 10

Conclusion .................................................................................................................... 14

Endnotes ...................................................................................................................... 16


Attachment A: Jacks pro se clemency petition

Attachment B: Iredell Hospital records

Attachment C: Wilkes Regional Medical Center records

Attachment D: Broughton Hospital records

Attachment E: Declaration of Dale Adams

Attachment F: Declaration of Dr. Dale Watson (2009)

Attachment G: Jack Greene affidavit (August 25, 2005)

Attachment H: Jack Greene affidavit (August 21, 2008)

Attachment I: UAMS report

Attachment J: Declaration of Dr. Ruloff Turner

Attachment K: Declaration of Julie Brain

Attachment L: Affidavit of Josh Lee

Attachment M: Jack Greenes notes

Attachment N: Affidavit of David Lewis

Attachment O: Affidavit of Garland Baker

Attachment P: Affidavit of Jack Greene (March 21, 2017)

Attachment Q: Jack Greenes list of injuries

Attachment R: Letter from Jack Greene to Justin Tate

Attachment S: Report of Dr. George Woods (2017)

Attachment T: Declaration of Mary Ellen Blankenship

Attachment U: Declaration of Danny Greene

Attachment V: Declaration of Georgia Howell

Attachment W: Report on interview with Linda Greene

Attachment X: Man Dies of Self-Inflicted Gunshot Wound

Attachment Y: Stonewall Jackson Secrets: Children against Monsters

Attachment Z: Woman Beats Aged Father, Dies Later in Hospital


Jack Gordon Greene is severely mentally ill. Often people who suffer from

mental illness show no visible signs of affliction. Jack is not one of those people. As

Department of Correction personnel have noted in their own observations of Jack,

his face is usually smeared with blood. He stuffs his nose and ears with toilet paper.

He is quite often found standing on his head or otherwise contorting his body in odd

poses. He eats his meals directly out of his sink. He uses his toilet as a desk. He

does all these things because he believes they ease the pain of nonexistent injuries

such as the destruction of his central nervous system. He is fixated on the false

belief that the prison and his attorneys have conspired to torture him to discredit

his pleas to be extradited to his home state of North Carolina. According to Jack, his

execution will be the final act in this conspiracy. If the State of Arkansas proceeds

as planned on November 9, it will be executing a seriously mentally ill man.

After twenty-five years imprisonment, most of them in complete solitary

confinement, Jack is not the same person who killed Sidney Burnett in 1991. A man

who was already predisposed to mental illness has been driven to complete

madness. Jacks execution, if allowed to proceed, will be a miserable spectacle.

Jacks descent into profound mental illness is only the latest in a series of

tragedies in his life. He was born into a large, impoverished family touched by

mental disease. His father committed suicide when Jack was eighteen months old.

His grandfather, who became his paternal figure, beat him. Rather than caring for

and raising Jack, the grandfather sent eleven-year-old Jack to a notorious juvenile

training school, where he was physically and sexually abused. He almost died trying

to escape the hellish conditions. When he finally was released, his family found he

was no longer the gentle person he once was. His traumatic life history primed him

to develop the mental illness that ran in his family.

This case warrants the Parole Boards recommendation of mercy. A death

sentence is excessive in light of Jacks present mental condition. Jacks execution

will not satisfy societys need for punishment, because his understanding of his

sentence is light-years from reality. Jack deserves severe punishment for murdering

Sidney Burnett, but death is not appropriate under the circumstances. Jack is

mentally diseased, and his execution would not be just. It would only bring shame

on the State of Arkansas.


Jack has previously submitted a pro se clemency petition to the Board.1 The

petition and the many writings attached to it show that Jack has completely lost

touch with the real world. He provided four grounds for clemency. In his own words:

A. the State of Ark. violated the Executive Agreement of my extradition

between the State of N. Carolina and Arkansas by not returning me back to
N.C. when my 1st death sentence was overturned 1995 that kept me
sentenced to death 3 different time.

B. the State of Ark. Dept. of Correction, also has violated my civil and human
rights by inflicting me endlessly since July 5th 2004 pre-cussion concussion
brain troma injuries w/ total destruction of neurological nerve system of 13-
yrs of torture.

C. the State of Ark. Dept. of Corrections, then in the collaboration with the self
appointed Ark. Fed. Defenders office spend several million dollars in State +
Fed. taxes to try and make me out to be a psychotic somatic delusion
disordered retard.

D. I Jack Greene request Executive Clemency on the facts of the past 13-yrs of
crippling maim and torture as described in attached 58-legal + med doc and
be returned to the State of N.C. where I can get medical treatment for all the
symptoms I suffer 24/7 as described in enclosed 3-page of torture list.

Needless to say, the Department of Correction has not destroyed Jacks central

nervous system and the undersigned attorneys have not conspired with them to

harm him. From Jacks petition, the Board can begin to comprehend the delusions

that beset him. Jack is so mentally ill as to believe that the prison and his attorneys

have tortured him and prevented him from receiving appropriate medical

treatment, all because he sought extradition to North Carolina. This condition did

not arise in a vacuum. A horrendous background has helped produce the broken

man the Board will interview on October 4. Jacks extreme mental illness provides

ample reason for the Board to recommend that Governor Hutchinson commute

Jacks sentence to life without parole.


Jack killed his brother Tommy in North Carolina and Sidney Burnett in

Arkansas within days of each other in 1991. These acts, while horrible, were not the

product of a healthy mind. Jack had been predisposed to mental illness through

family history and severe trauma he suffered as a youth. His condition has

deteriorated gravely during his time in prison. His sickness has stopped his

attorneys from developing claims that would have prevented his execution. And it

has led him now to the point where his comprehension of the world is overwhelmed

by delusional conspiracy theories. Jacks debilitating mental illness provides a

compelling reason to spare him from execution.

Several other members of Jacks family suffer from mental illness. Jacks father

committed suicide; his mother overdosed on pills. (Whether the overdose was

intentional is unclear). Jacks older brother Bobby died the same way his father

didby shooting himself with a shotgun. When Tommy was 18, his mother filed an

affidavit in court to have him declared mentally incompetent. Jacks brother

Huellett suffered from seizures and fits. Jacks sister Mary Ellen suffers from

chronic anxiety and depression. Jacks brother Danny also suffers from depression.

Jack was unable to escape the familys predisposition to mental illness. He

began showing signs as early as 1982, when he appeared at an emergency room

with a mysterious injury he reported as a snake bite. Jack claimed to have been

bitten on the side of the road, after which he cut a five-inch gash in his leg with a

pocket knife, applied a tourniquet, and sucked the wound for 10 minutes. The

treating doctors, however, concluded hed probably not actually been bitten by a

snake.2 Even more disturbingly, Jack appeared at the hospital three months later

having slit both his wrists, leaving three-inch lacerations that required sutures.3 In

1985, Jack was involuntarily committed to a psychiatric hospital after expressing

fear he would kill his brother Tommy.4 Unfortunately, Jack was never able to

receive mental-health services. Had he been provided such services, its unlikely

that he would be before this Board today.

Jacks mental instability was apparent during his trial proceedings. He was tried

and convicted for Tommys murder in North Carolina first. Notably, this conviction

was vacated on grounds of a mental-health issuenamely, that the trial court had

denied an ex parte hearing on the question of funding for a psychologist.5 After his

conviction in North Carolina, Jack was extradited to Arkansas under an executive

agreement that would come to form the foundation of his delusional thinking. Jack

was tried three times in Arkansas because the Arkansas Supreme Court reversed

his death sentence twice. Before his first resentencing, he fired multiple attorneys

whom his family had privately retained.6 He insisted on appearing at trial in a t-

shirt that read death row because, as he explained to the court, The prosecution

in North Carolina has left me on death row illegally for the past two and a half

years without due process of law of honoring this agreement right here.7 Jack was

also telling mental-health examiners that his life was in immediate danger if he

remained at Tucker Prison and that his attorney was in a conspiracy against

him.8 Consistent with his mental instability, Jack attempted to waive his appeals

from the second and third death sentences multiple times.9

Despite obvious signs of mental illnessand despite a prior experts

recommendation that Jack be tested for neuropsychological damage because of a car

accident he was involved in as a youth (discussed in Part II below)Jacks attorney

at his third and final trial engaged no mental-health expert and presented no

mental-health evidence. When testing was finally performed, it revealed significant

problems with Jacks neuropsychological functioning that an effective attorney

would have used in mitigation.10

Jacks delusions became much more florid in 2004, about a year after he was

moved to total solitary confinement behind a solid steel door at the Varner

Supermax Unit. According to Jack, on July 5, 2004, his postconviction attorney, the

prison warden, and a corrections officer conspired to destroy his left ear by

repeatedly slamming the food slot in his door. He documented this conspiracy in one

of the many affidavits he has composed and sent to various government officials

over the years:

On 5/20/04 I fired attorney Jeff Rosenzweig he then

orchestrated/conspired w/ warden Grant Harris who then w/ aid of two
other ADC staff did cause the permanent debilitating destruction of vital
bodily functioning organs, left inner ear etc. (equilibrium) warden
Harris, learned of hole in right ear drum from prior mid 90s medical
records, on 6/2/04 placed on powerful prescription mood altering drug by
nurse Connie Hubbard as she described was for my cronic pain due to
torn rotary cuff in right shoulder, at this same time I am being druged
illegally CO//guard V. Morris is made Sgt. Works the bks by her self
every shift schedual day purposely slamming my cell door trap door so
hard repeatedly 8/10 times per day until morn of July 5 th 2004 at 9:15
my left inner ear etc. erupted.11

Gradually Jack began to believe himself subject to more and more elaborate injuries

inflicted by more and more people. He started to complain of total destruction of his

nervous system. He accused his current attorneys of conspiring against him. By

2008, he had incorporated high state-government officers into the plot:

U.S. Presidential Candidate prior Ark. gov. Mike Huckabee and prior
att. gen. Ark. gov. Mike Beebe, both with political knowledge of
appointed and retained attorneys, prior of current in their illicit
influence of bias senior Ark. Dept. of Corrections staff to have expedited
by racial black staff of Ark. death-row to inflict constant re-injury to
brain with concussion, destroying all thirty one (31) paired neurological
spinal nerves through burst left inner ear etc. as initially described by
same means in eleven (11) sworn affidavits court filed in both Johnson
Co. Ark. Wilkes Co. N.C. in 2005.06 whereas through inhumane injuries
maim and torture I expose this states appointed political officials.12

Doctors who have examined Jack have found no trace of the physical injuries he

describes.13 Jack nonetheless persists in the belief that his attorneys and the prison

are conspiring to harm him.

Jacks delusions have prevented his attorneys from pursing legal claims that

could remove his death sentence. As one former attorney put it, During the entire

period that I represented Mr. Greene, his profound mental illness made it

impossible for me to represent him effectively.14 Most notably, Jack has a

legitimate claim that he meets the clinical definition of intellectual disability. In

2010, he was sent to a federal medical center, where his IQ was measured at a 76

a score thats consistent with intellectual disability. Dr. Dale Watson reviewed the

available data and found that, while intellectual disability cannot be ruled out, he

would need to conduct further testing. Jacks inability to cooperate prevented this

testing, however, meaning that we will never know whether Jack does, in fact,

warrant a diagnosis of intellectual disability.15 Its possible the State will be

executing an intellectually disabled manwhich the Eighth Amendment forbids.

Jack is apparently aware that this and other claims could cause his death sentence

to be vacated, yet he refuses to cooperate because he believes it would make him

complicit in a cover up of the conspiracy to injure him for wanting to be extradited

to North Carolina. In Jacks words, I would gotton off Death-row 6 or 7 years ago if

I would have allowed this state etc. get away with their planed cover up of crimes

against as described.16

As those who know him personally have attested, Jacks illness has become even

more pronounced in recent years.17 In 2016, a North Carolina court appointed Jack

an attorney to handle filings in the murder case there. The attorney traveled to

Arkansas in an attempt to help Jack with his stated goal of settling his case in

North Carolina.18 But Jack immediately lashed out at him and attributed the ADCs

installation of a video visitation system to the vast conspiracy to prevent his return

to North Carolina:

May 18, 2016, State of N. Carolina v. Jack Greene, First Degree murder,
assignment of counsel Garland Baker . . . visit with att. Baker, Oct. 17,
2016 at ADC, I provided him 10-doc or so legal and med. record doc. in
prof of 13-yrs of inhumane injuries and torture inflicted by ADC and the
attempted costly cover up in collaboration with the self appointed Ark.
Fed. Defenders, failed by and cover such inhumane crimes, I told att.
Baker, he would want to provide the U.S. Dept. of Justice Civil Rights
Dept., a Copy, instead att. Baker files no N.C. pre-trial motions and
starts himself conspiring and collaboration with the Ark. Fed. Defenders
who in turn with the ADC install (an-internet-computer-video-camera-
phone-system) in inmate visitation cell apparently just prior of my ADC
visit with N.C. att. Baker and the first thing he says to me is maybe just
maybe we can settle this N. Carolina case over the internet via Wilkes
Co. Courthouse, N.C. attorney Garland Baker knew of this ADC video
computer being installed befor I knew and sought our brief visit to try
and prevent my brief return to N. Carolina, surely expose torture (Note:
telephone right outside cell I can use 24/7 no one uses ADC computer

Jack has recently sent a steady flow of correspondence to various officials in a

further attempt to expose the cover-up of his injuries. The U.S. Department of

Justice, the North Carolina Extradition Secretary, and Governor Hutchinsons chief

counsel have all heard from Jack. Typically he encloses a document hes entitled

ADC ceaseless inflicted injuries and symptoms 24/7 of pre-cussion concussion brain

troma injuries with total destruction of my spinal neurological 31-paired central

nerve system since July 5th 2004. This document contains a list of the injuries he

believes the conspirators have inflicted on him over the past thirteen years.20 His

hope is that his extradition will allow him to receive medical treatment in North

Carolina. As he informed Governor Hutchinsons chief counsel:

Mr. Tate, when ever I wouldnt stop forcing the legal issues of my return
to N. Carolina, as drafted within the Executive Agreement between
the State of Arkansas and North Carolina, of my Extradition, the Ark.
Dept. of Corrections, then criminally inflicted me, and endlessly since
July 5th 2004 with pre-cussion concussion brain troma injuries with the
total destruction of my entire neurological nerve system that has forced
me to live for the past 13-yrs, all crippled maimed and tortured and
endure and suffer 24/7 so inhumanly, unable to even walk etc., described
within pages 40-41-42 of such pro-long symptoms of such inhumane
maim and torture since July 5th 2004.21

Dr. George Woods, who has seen Jack on multiple occasions, has spelled out in

medical terms something that should be apparent to the Board from observation of

Jack and review of his writings: Jack is severely mentally ill.22 Specifically, he

suffers from a psychotic disordera fact that no court has ever disagreed with when

presented with the evidence. In sum, Jack meets the textbook definition of an

insane person.23

There would be no purpose in executing someone who believes the execution is

part of a conspiratorial cover up concocted by his lawyers and the State. The Board

should recommend that the Governor show mercy to this mentally crippled man.


To fully understand Jacks mental illness, the Board must also understand his

past.24 He was born on March 13, 1955, in Lenoir, North Carolina, the thirteenth

child of his father Turner Greene and the seventh child of Ola Greene, Turners

second wife. Jacks sisters describe him as a sweet, humble boy. The large family

had little money and lived in a three-room house with no electricity, running water,

or indoor plumbing. They lived miles out of town and had no vehicle. Turner was a

severe alcoholic who stayed drunk for weeks, or even months, at a time. When Jack

was eighteen months old, his father committed suicide by shooting himself in the

chest with a shotgun in the room where Jack was napping.25

After Turner killed himself, Olas already tenuous financial situation became

more desperate. The family had to move in with her parents, Coles and Gladys

Taylor. Coles was extremely abusive to the children and Jack was a primary target

of his ire. He beat the children with a belt or a stick until they bled, and he literally

put salt in their wounds. Coles had particular antipathy for Jack. He would beat

Jack once a week or more, and Jack would hide under the bed and cry. Ola had

little power to prevent her fathers abuse because she feared he would evict her

family and leave them homeless.

Ola was able to fix up a chicken house on her parents property. She and her

children moved into the one-room building, which had a dirt floor. The chicken coop

had no electricity, no running water, no indoor plumbing, and no proper door. It did

not protect the family from the elements. One of Jacks siblings recalls waking up

one morning to snow that had drifted into the coop.

Despite her limited means, Ola gardened and canned to feed her family. She

made blankets by sewing together old feed bags. Without money for toys, she would

make do with bunching up a towel and tying a string around it to make a doll for

her daughters. The family relied on government aid and local charity to provide

necessities. The children struggled both academically and socially in school. Two of

Jacks brothers never learned to read or write. The children were ostracized because

of their extreme poverty.

When Jack was eleven, his grandfather called the authorities and asked them to

take Jack to the juvenile boys home in Concord. According to Jacks sister, their

grandfather accused Jack of stealing gasoline. Jack was committed to the Stonewall

Jackson Juvenile Training School for four years. Jacks school records note that at

age 11 he was 4 feet 8 inches tall and weighed 72 pounds. Still very much a child, he

was forced to endure brutal physical and sexual abuse at the hands of older children

and adult staff members. The mistreatment of children at this training school has

been well documented; many survivors of the abuse have spoken out. Survivors

report that children were beaten so severely that they had their teeth knocked out.

One former resident recalls that after the boys showered, it was routine for a

supervisor to line them up naked and beat them on the penis with a rubber strap.26

Jack and another boy, Michael Murray, decided to escape from the training

school. They broke out, stole a car, and tried to get as far away as they could. The

boys, 15 and 14 years old, were chased by police. During the chase their vehicle

flipped and both boys were severely injured. Michael died from his injuries ten

minutes after they arrived at the hospital. Jack suffered a head injury, fractured

ribs, and a punctured lung. The clothes he was wearing during the accident were

soaked in blood. The doctors told Jacks family that his injuries were grave and that

he would probably not survive. Jack did overcome his injuries, but he could not

escape his guilt over his friends death. He was highly emotional and blamed

himself for what had happened. His sister-in-law recalls him crying and wailing and

saying that he would give anything in the world to bring back his friend. When Jack

was released from the hospital, he was forced right back into the abusive

environment from which he nearly died escaping.

A recent report on the school from the Charlotte Observer reveals that escapes

like Jacks were common. Survivors from the school recall that the worst beatings

occurred after runaways were captured. Firsthand reports state that boys were

forced to lie naked across a bench and beaten so hard by grown men that they would

almost pass out. The men who were at this school as children report long-lasting

trauma from the abuse. One recalls being in a bunker in Vietnam under enemy fire:

All these guys were scared to death, and one of the other soldiers asked why I

wasnt afraid of dying. I told him I had been to Stonewall Jackson Training

School.27 Another remembers it as a horrifying experience that left him unable,

even as an adult, to trust anyone.28

According to his family, Jack was never the same after the training school. For

years after being released, intrusive memories would keep Jack up late at night. He

was withdrawn and quiet. He was still haunted by the death of his friend Michael.

His sister-in-law recalled that he would come to her house years after the accident

bawling and needing comfort. Sometimes he would want to talk about the accident

and other times he would just sit in a chair and cry. Before going to the training

school, Jack had been close to his mother and loved to be held and rocked. After the

training school he couldnt stand to be touched. His siblings recall that their sweet

brother Jack had been totally transformed by the training school. He would

constantly pace the floor and nervously peer out the window.

After the training school, Jack was unable to perform as was expected of him in

an ordinary school setting. He dropped out after failing the eighth grade for the

second time. He was introduced to illicit drugs and alcohol at the training school

and he continued to abuse them after his release to cope with his intrusive

memories. He was arrested and imprisoned multiple times for DWI charges. He

struggled to make a living and switched jobs frequently.

Things became worse for Jack when his mother died in a strange incident that

has never been fully explained. One day in 1983, Ola attacked her father with a

hammer, injuring him severely. Sometime around the attackwhether it was

before or after is unclearOla took a large amount of her prescription medication

and overdosed.29 An ambulance came for Ola, but Jacks brother Tommy sent it

away. Ola never recovered from the overdose, and another ambulance called later

was not able to get her to the hospital before she died. Jack was shattered by the

loss of his mother. After her death, several days a week, he would sit at her grave

for hours, crying and talking to her. He could never forgive his brother for turning

away the ambulance that might have saved his mother. Ultimately, he could not

fend off his urges to harm Tommy.

Jacks background doesnt excuse what he did to Sidney Burnett. But it does

help the Board understand how Jack become the damaged person the State intends

to executea person whose mental illness has left him with no ability to

comprehend the world rationally.


It is said that madness is its own punishment. That is certainly true in Jacks

case. Executing him is simply not necessary to achieve the States interest in

retribution for his crimes. Nor will it be effective to achieve that interest. The world

knows Jack is being executed for killing Sidney Burnett. Jack thinks hes being

executed because he asked to be extradited to North Carolina and because he tried

to expose imagined injuries inflicted upon him by his attorneys. Not only will

executing Jack be inhumane; it will be a futile attempt at retribution, one that can

bring satisfaction to no one with even remote knowledge of his mental afflictions. A

recommendation of clemency is warranted.


1Jacks pro se clemency petition is submitted alongside this application as

Attachment A. Reproductions of Jacks written words in this application include
spelling and grammar errors that appear in the original.

2 Attachment B.

3 Attachment C.

4 Attachment D.

5 State v. Greene, 438 S.E.2d 743 (N.C. 1994).

6 Attachment E.

7 2d Tr. R. 1054.

8 2d Tr. R. 237.

9Arkansas Supreme Court opinions addressing (and mostly rejecting) Jacks waiver
attempts can be found at 929 S.W.2d 157 (1996); 933 S.W.2d 392 (1996); 939 S.W.2d
834 (1997); 941 S.W.2d 428 (1997); 949 S.W.2d 894 (1997); 1 S.W.3d 442 (1999); 37
S.W.3d 579 (2001) (supplemental opinion dated March 8, 2001).

10 Attachment F.

11 Attachment G.

12 Attachment H.

13 See, e.g., Attachments I & J.

14 Attachment K.

15 Attachment L.

16 Attachment M.

17 Attachment N.

18 Attachment O.

19 Attachment P.

20 Attachment Q.

21 Attachment R.

22 Attachment S.

23Blacks Law Dictionary 865 (9th ed.) (defining insane as suffering from one or
more delusions or false beliefs that (1) have no foundation in reason or reality, (2)
are not credible to any reasonable person of sound mind, and (3) cannot be overcome
in a sufferers mind by any amount of evidence or argument).

Information about Jacks past comes from interviews conducted with his family

members. Several of these interviews are documented in Attachments TW.

25 Attachment X.

26Children against Monsters, YouTube video with interviews of survivors.

Available at:

Elizabeth Leland, Stonewall Jackson Secrets: Children against Monsters,


Charlotte Observer, Oct. 5, 2013 (attached as Attachment Y).

28 Id.

29 Attachment Z.

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GREENE. Jack Gordon 27 HISt. No.: 12-3734

Phystcian~ HARDAWAY Dafe 6-3-82 Rm. 10/;
CC: SIUilee bite
PI: This 27-year-old white married male states that some time last night about midnight
he was walking up a bank from the Interstate 77 near Union Grove. because his car stopp,d
running. As he walked. something stung him on the anterior aspect of the left leg.
He then states that he felt a snake crawl across the shoe of his right foot. He did not
see a snake. He became extremely frightened and went to the top of the bank and in thG
streetlight there was able to see that the wound was two small holes which he took to be
fang marks. He took his pocket knife and made a five-inch incision through the fang marks
and placed a tourniquet proximal to the wound. He states he tilen sucked t.he wound fOl'
approximately 10 minutes. He bled rather heavily from the cut and bet. e somewhat nauseated.
H found his way to a telephone. called his wife who was in Wilkesboro and after a while
she came with another man and picked him up and brought him to the EQ here at Iredell
Memorial. and he arrived here at 4:07 a.m. He does not remember all that happened in the
ER. but he was nauseated and complained of so~ chest pain. The ER physician ane.thetize~
the incision and sutured it and as he did. patient complained of some chest pain. became
nauseated. pale. sweaty and vomited. His BP dropped to 72/0 and IV fluids were started.
EKG was done which showed ST elevation in the lateral V leads and aT-wave dow!1 in Vl
and V2. Because of his fainting episode. chest pain and nausea he was admitted to the
hasp; trll .
PAST MEDICAL HISTORY: He has alwa;s had good health. He has had no ser', illness. At
age 13 he was in a wreck and fractured ribs on the left and punctured his lung.
HEENT: He rarely has a cold. He keeps a headache much of the time. He
says thi~ is because he does not wear glasses. He has hdd several pair and has lost them.
He says he is far sighted. His hearing is good.
C.R.: No history of heart or pulmonary disease. No history of chest pain or
shortness of brea til.
G.I.: He is not bothered with gas, indigestion, constipation.
G.U.: Negative.
FAMILY HISTORY: Several members of the family have had heart disease and high blood
pressure, His grandmother had cancer. ,here is no fam11y history of diabetes. tuberculosis.
______________ M _


VITAL SIGNS; T. 97.4. P. 88. R. 20. BP 130/80 i.l

GENERAL CONDITION: T~~ patient is a well-developed, well-nouriShed. white male who states
that he was bitten by a snake about 4-5 hours prior to admission to the hospital. but he
did not see the snake.
HEENT: Pupils are round. regular and equal and react to light and accommodation. Ears,
nose and throat are root remarkable. He has some dental decay.
HECK: Supple and there are no masses.
TlIVRAX: Heart is not enlarged. There is a regular sinus rhythm and no munlllr is heard.
lungs are clear to percu~sion and auscultation.
-conti nued-

Attachment B Page 1
27 Hist No. 1I2-3734
Fhysicl;,: HARDAWAY Dale: 6-3-82 Am 106
ABDOMEN: Soft and not distended. No organs or masses are felt. Bowel sounds are
active. There is no inguinal adenopathy.
SKIN. GLANDS & EXTREMITIES: Not remarkable. There is a five-inch laceration of the
left lower leg which has been sutured in the ER. There is essentially no swelling around
the wound which makes one suspicious that he was either not bitten by a poisonous snake or
possibly not by a snake at all. Dorsalis pedis and posterior tibial pulses are good.
Refle1es are active and equal.
IMPRESSION: Possible snake bite of the left leg. Laceration of the left leg through
area of quest~onable snake bite. Syncope secondary to fright and possible blood loss.

JSH/jms D: 6-3-82
T: 6-4-82 )JkJ~~
. ~
HARDAWAY. .--'- M.D~'

Attachment B Page 2
Attachment C Page 1


Admitted: 5/30/85
Discharged: 6/6/85


The patient was involuntarily committed to this hospital because of alleged threats to
kill other people.


The patient is anxious and agitated, but coherent. He expresses no suicidal ideas, "I
felt I was going to hurt my brother". No delusional ideas. He is of above-average
intelligence. Affect is anxious and mildly depressed. Insight and reality testing good,
judgment at times is fair, but poor at other times. Personality trait is impulsive,
dependent. His chief complaint, "My nerves".


Essentially normal.

Supportive laboratory data: Positive drug screen for Marijuana. Urine for C&S is negativ
Routine urinalysis is within normal limits.



Problem #1: History of Alcohol Abuse, Fear of Harming his Brother:

S&O: The patient was admitted to this hospital because he had been drinking, and
had been using marijuana and lost control of his behavior. He was afraid he
was going to hurt his brother over some alleged family conflict, stemming back
to the death of his mother sometime back. The patient went to Caldwell Memorial
Hospital where the doctor felt he was probably dangerous to himself and others,
and committed him here.

While in the hospital the patient settled down, requiring no extensive medicatio
He,gs not suicidal at the time of discharge by court, and it was felt that he
was ready for release. He felt that he could go back to Oklahoma.
A: At time of discharge by court no psychosis and no depression of any great
magnitude, even though he was on Sinequan, 100 mg. at h.s. to help him sleep.
P: Patient plans to return to Oklahoma. No trnc appointment will be made for him.

Attachment D Page 1




This is a 27-year-old white male who came to the hospital, allegedly under the influence
of alcohol, and possibly marijuana. He had made some verbal threats which he now says
he didn't mean. No evidence of psychosis; more likely related to his abuse of drug and




Direct. The patient left in care of himself, to return to 2700 North Council Street,
Bethlay, Okhhoma 73008. No medication was sent with him.

Wade Woodard,P. ., Unit D



Attachment D Page 2

Dictated: 6/4/85
Transcribed: 6/10/85 _~LLLi
Format: Identifying Information, Presenting Problems, Previous psy~iHJft~!WRrf'~:il)ifa1?~M%fl~~A!iHt-gocJJptJ;esPnent,S ocial-environmental
Assessment, Physical Functlonlng, Social Assessment.
D, te --,5,-,/,-,3,-,0,-,/-=8",5,--_


This is the first admissiDn tD BrDughtDn HDspital fDr this 27-year-Dld white, divDrced
male frDm Caldwell CDunty. He is referred fDr invDluntary admission by Dr. Ranier Mc-
Guire, Caldwell MemDrial HDspital, LenDir, NDrth CarDlina. CorrespDndent listed for
this admissiDn is the patient's friend, DDnna Greene, 2600 North Council, Bethlay,
OklahDma, 73008.

The patient has a high school education, plus three years of education in a Vocational
Technical SchoDI. Pri.or to admission he was unemployed. He does not have any type of
charges pending, nor is he a veteran of military service. This is his first admission
to this facility. He has never been declared legally incompetent.


The patient states that he is Driginally from Wilkes County, but has lived in Oklahoma
City for the last IY, years. The patient states that he and his girlfriend were on
their way to Wilkes County to see their family members. Apparently the patient and
his girlfriend left Wilkes County apprDximately IY, years ago and the girlfriend is back,
trying to get custody Df her two children, from her husband. The patient states he is
trying to get visitation rights with his children. The patient states he has been
married twice. He does admit tD drinking prior to admission and states he was afraid
that his drinking was becDming too heavy. The patient states he is an alcoholic and has
been involved in AA prDgram in OklahDma City for the past two years. He states he has
been under a lot of pressure, has been working two jobs in OklahDma City. According to
Mr. Greene, "I thDught I was going to crack up if I did nDt get some help". Due to his
feelings, commitment was sought to this facility.


The patient has never been to the MHC before. This is his first admission to BroughtDn
Hospital. He has attended AA in the past.


Attachment D Page 3




Format: Identifying Information, Presenting Problems, Previous PsychiatrIc HIstory, Family Background, Psycho-social Assessment, SocIal-environmental
Assessment, Physical Functioning, Social Assessment. .
Date _

the ptient and his siblings. The patient seems to have a poor relationship with his
family members. Mr. Grane states that his father committed suicide, and that he was an
alcoholic. He states he was only 18 months old when his father died. The patient does
not have any type of rel~ous pr~ference. Prior to admission the patient had been
residing in Oklahoma City, but upon discharge from this facility he plans to return to
Wilkes County and attempt to get visitation rights set up with his children.


The patient is presently divorced from his second wife. He does have a girlfriend and
no sexual problems are noted.


The patient began school at the age of seven and completed the 9th grade. He states he
eventually obtained his GED, plus completed three years of vocational tech school. He
describes his personality as being friendly, easy-going, and personable. He states when
he begins drinking He personality begins to change. When angry or under stress the
patient states he prefers to be by himself.


Prior to admission the patient was working at a 7-11 Store in Oklahoma City, and was
also doing some part time landscaping work. He is diovrced from his second marriage
and has four children. He has two children by his wife (first), age seven and eleven,
and two children by his second wife, ages five and two. The patient states that he does
plan to reside in Wilkes County until custody suit is settled. He describes himself as
being a fair manager of money. Military service history is not addressed. The patient
is not involved in any type of community activities.


Prior to admission the patient was not on any type of medication. He states he has had
surgery on his foot before from an old gunshot wound. Please refer to Physical Exam
for further information.

Form No. DMH 2~2581


Attachment D Page 4




Format: Identifying Information, Presenting PrOblems, Previous Psychiatric History, Family Background, Psycho-sodal Assessment, SocIal-environmental
Assessment, Physical Functioning, Social Assessment.
Date _


Mr. Greene was admitted to this facility on 5/30/85. He states he had been living for
l~ years in Oklahoma. He states he is an alcoholic and has had various problems with
alcohol, and run-ins with the law-enforcement officers due to alcohol consumption.
He states that alcohol has been aproblem for him since age eleven. At one time he
states he spent three years in a training school. He states he has been in prison
approximately four times for DWIs, and at one time received felony time for two years
for escaping from prison, after being kept there for DWI charge.

The patient appears to be very sincere in stating that he plans to receive help for his
alcohol problem. He did say that he plans to go back to Wilkes County upon discharge
from this facility. It will be recommended to the patient at discharge that wherever
he goes, he become involved with AA once again to seek continued treatment for his
alcohol problem.

The patient does have his GED, and was working two jobs while residing in Oklahoma.
Upon discharge he will be referred to his local MHC, and also will be encouraged to
attend at least two AA meeting s per week.


Form No. DMH 22581


Attachment D Page 5

I, Dale Adams, do declare as follows:

I. Jack Gordon Greene is one of my former clients. I was retained

to represent Jack on his death penalty resentencing. A few months after r

started working on the case, before trial began, Jack told me that I was fired. r
never really understood why I had been fired. I have not been involved in

Jack's case since then.

2. Even though r only represented him for a few months, I saw

Jack quite a bit. r was preparing for trial and spent a lot of time with him at the
jail. Based on my interactions with him, I concluded that Jack was crazy.

don't mean that he was a little off; he was completely nuts.

3. Jack was very paranoid. He had these super conspiracy

theories. He believed somehow that everyone-the prosecutors, the judges,

Didi Sailings, and all his other prior attorneys-were conspiring to kill him.

He would always talk about getting together this one grand lawsuit where he

would name all the people who had ever screwed him over.

Page 1 of 2

Attachment E Page 1
4. Jack did not seem particularly unkempt when I met with him,

nor was his speech difficult to understand. I could easily make out what he

was saying; it was just that what he was saying was insane.

5 r CO'-l/J nof Neef JacK Of) -fmc); enoUjh

+0 --b, IK <1 hiJ 1/ r h'-s r/n ,r/l'n ttl 0I5e. lie
(ovid /lot !dcu5. !Ie was -fufttlly freo u-1t'eJ
With fheft- ul71.zy COJ1ih~c/es-; if wa 5
{AI! he could .falk a.houf: ~

I declare under penalty of perjury under the laws of the United States

and the State of Arkansas that the foregoing is true and correct to the best of

my knowledge.

o2A-- t cJ-----
Dale Adams

-C1J /6rt/J()/O
Date ~ '

Page 2 of 2

Attachment E Page 2
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 1 of 9


I, Dale G. Watson, Ph.D., declare as follows:

1. I am a clinical and forensic psychologist with a specialty in

neuropsychological assessment. I am licensed to practice in the State of California. My

office is in Pinole, California. I am a member in good standing of the American

Psychological Association (APA), and its subspecialty divisions 40 and 41 (Clinical

Neuropsychology and the American Psychology-Law Society), the National Academy of

Neuropsychology, the International Neuropsychological Society and the American

Association on Intellectual and Developmental Disabilities (AAIDD).

2. I received my Bachelor of Arts degree, with a major in psychology, from

California State College, Sonoma in 1975. I received my Masters degree in Clinical

Psychology from John F. Kennedy University in Orinda, California in 1980. In 1988, I

earned a Ph.D. in Clinical Psychology from the California School of Professional

Psychology (CSPP) in Berkeley/Alameda, California. CSPP is accredited by the

American Psychological Association (APA) and is now a school within Alliant

International University with a campus in San Francisco.

3. I have been in private practice in Pinole, California since 1990. In

addition, I serve as the Consulting Neuropsychologist to Neurobehavioral Cognitive

Services (NCS) of Dixon, California, a residential brain injury rehabilitation program. In

that role I am regularly involved in the evaluation of individuals with moderate to severe

brain injuries resulting from trauma, stroke and other neuropathological processes. I also

serve on the adjunct faculty of the Wright Institute, an APA accredited doctoral training

program. At the Wright Institute, I taught a 3-trimester course in psychological

Attachment F Page 1
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 2 of 9

assessment from 1994 until 2000 and resumed these duties beginning in 2007. This

course covers the broad array of psychological assessment instruments utilized within the

field of assessment and includes modules on intellectual assessment, neuropsychological

screening and personality assessment. Until 2003, I was on the panel of forensic

examiners for the Superior Court in Contra Costa County, California. In that role I

regularly examined criminal defendants referred by the court for the evaluation of

competency to stand trial and insanity. I have been qualified as an expert and testified in

the Superior Courts of Contra Costa, Alameda, Fresno, Los Angeles, Marin, Monterey,

Sacramento, San Mateo, Santa Clara, San Francisco and Shasta Counties in California, as

well as Custer County, Montana, King County in Washington, Harris County in Texas

and the York County Poquoson Circuit Court in Virginia. In addition, I have testified

in United States District Courts in California, Oklahoma, and Montana. I have frequently

completed Atkins evaluations in my role as a forensic neuropsychologist.

4. I have made numerous professional presentations regarding: the

neuropsychological impairments found in forensic populations; mental retardation and

adaptive functioning, head injuries; brain functions; substance abuse and traumatic brain

injury; as well as the neurobehavioral differentiation of depression and cognitive


5. From 1989 through 1992, I was a clinical neuropsychologist with

NeuroCare in Concord, California. In that capacity, I conducted neuropsychological

evaluations, served as a psychology team leader, supervised interns, planned treatment,

conducted cognitive rehabilitation and crisis intervention and performed consultation and

project management.

Attachment F Page 2
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 3 of 9

6. From 1986 through 1989, I was on the staff of Specialized Rehabilitation

Services (SRS) of Fremont, California, in the Chronic Pain Management Program.

Between 1986 and 1987, my duties included coordinating the treatment team in the Brain

Injury Rehabilitation Program at SRS. My role at SRS also included conducting

neuropsychological evaluations, performing cognitive rehabilitation and psychotherapy.

In addition, I previously worked as a consultant to a substance abuse treatment program.

7. I was retained by the Arkansas Federal Defender Office to conduct a

neuropsychological evaluation of Jack Gordon Greene, an inmate on Arkansass death

row, for use in federal habeas corpus proceedings. I was asked to thoroughly assess all

aspects of Mr. Greenes neuropsychological functioning, and I was specifically asked to

assess his intellectual functioning for the purposes of determining whether he is a person

with mental retardation.

8. I first met with Mr. Greene at the Arkansas Department of Correction

Varner Unit in Grady, Arkansas, on May 20, 2009. I spent approximately two and one

half hours with Mr. Greene on that date. It was immediately apparent that Mr. Greenes

presentation is extremely bizarre. He was transported to the examination room on an

institutional wheel chair, on which he was curled up almost in a fetal position. He was

audibly gasping and moaning and he stated that he was in severe physical pain. After his

shackles and handcuffs were removed and he got up out of the wheelchair, Mr. Greene

began writhing and contorting his body into a variety of different positions and angles,

explaining that he had to make such movements constantly in order to be able to endure

the pain that he continually experiences. His left index finger was bound up with toilet

paper and tape and he kept that finger pressed against his left ear, in which he also had a

Attachment F Page 3
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 4 of 9

foam earplug. Mr. Greene explained that these actions were necessary to prevent himself

from being reinjured by loud noises in the prison facility that cause his brain to swell.

9. As I introduced myself and began to talk with him, Mr. Greene continued

to gyrate and shift position, at times laying on the floor, leaning up against the walls, and

occasionally sitting for short periods in a chair. When I asked him to describe the pain

that he was experiencing, Mr. Greene said that the sensations were centered in his brain

and spinal cord. He described hearing his brain making a humming sound, and feeling

pain at the base of his skull and in all the nerves in his spinal cord. He stated that the

nerves in his spinal cord were all damaged or destroyed. He vehemently denied that he

had any kind of back pain or skeletal back problem, insisting that the problem was inside

his spinal cord and in his brain. These beliefs are physiological untenable. He related that

yoga exercises helped him to cope with the pain, and proceeded to demonstrate the head

stand and plough poses that he is readily able to perform. If he did not perform these

exercises multiple times a day, he believes, his entire body would freeze up. Despite my

repeated requests that he describe the precise location of his pain, Mr. Greene was unable

to localize it with any further specificity.

10. Mr. Greene stated that his pain was the result of injuries inflicted upon

him by Arkansas Department of Corrections officials, who deliberately and repeatedly

slammed shut the door in his cell door so loudly that they burst his ear drum. He stated

that it was his actions in pushing the issue of what he perceives to have been his illegal

extradition from North Carolina to Arkansas to face capital murder charges that provoked

the ADC to injure him. He also complained of memory difficulties associated with his

injuries. He said that sometimes when he is watching television he forgets what it is he is

Attachment F Page 4
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 5 of 9

watching. He also forgets how to spell even simple words when he tries to write. He

also complained of frequently losing his train of thought when in conversation. Although

he denied suicidal ideation, Mr. Greene stated that he would rather be dead than continue

to live with the pain he experiences.

11. Despite Mr. Greenes bizarre behavior, I attempted to proceed with the

neuropsychological evaluation. Tests were selected based upon the initial targeting of

executive functioning (as these were anticipated to be impaired) and the need to

accommodate Mr. Greenes bizarre behavior. In general, Mr. Greene would select his

response on the computer screen and this examiner would enter his answer. Such a

procedure is far from ideal but the best that could be expected given his presentation.

12. I administered the Victoria Symptom Validity Test (VSVT), a

computerized test designed to detect malingering or poor effort, the results of which

indicated that Mr. Greene was giving good effort and was not attempting to appear more

cognitively impaired than he is. I was also able to administer the Wisconsin Card Sorting

Test (WCST), a measure of executive functioning and problem solving. Mr. Greene

clearly demonstrated a severe conceptual deficit with an on target falling at below the

1st percentile rank of the normative sample. He also failed to complete even a single

categorical sort and was markedly perseverative with a performance at the 2nd percentile

rank. This finding highlights Mr. Greenes profound deficit in mental flexibility and

problem solving. He can be expected to fall into mental ruts wherein he cannot utilize

feedback to alter his thought processes or behavior.

13. A measure of verbal fluency, the Delis-Kaplan Executive Function System

(D-KEFS) Verbal Fluency test, was also administered. This measure, associated with the

Attachment F Page 5
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 6 of 9

functioning of the left prefrontal cortex and the productivity of thought, was severely

impaired for phonemic fluency and moderately impaired on a categorical fluency task.

Likewise, on the D-KEFS Twenty Questions test Mr. Greene demonstrated that he cannot

sustain an effective problem solving strategy despite an initially abstract approach.

14. The Iowa Gambling Test (IGT), a measure sensitive to particular types of

judgment impairments and dysfunction of the orbital frontal cortex was mildly impaired.

15. Throughout the test procedures, Mr. Greene continued to contort his body

and shift position, occasionally responding to test stimuli while lying on his back on the

concrete floor. After approximately two and a half hours of testing, Mr. Greene declared

himself physically unable to continue and so I decided to defer the administration of any

further testing instruments to the next day.

16. On the following day, May 21, 2009, I arrived at the Varner Unit to

continue my evaluation of Mr. Greene. Mr. Greene was once again transported to an

interview room in a wheelchair with his ankles and wrists shackled. When he arrived in

the interview room, the transporting officers informed me that, unlike the day before, Mr.

Greene would have to remain shackled in this way throughout the testing process. Mr.

Greene was immediately distressed, and said that he could not stay shackled for any

length of time because it impeded the movements he made to cope with his pain and

rendered that pain unbearable. I explained to the officers that it would be impossible to

test Mr. Greene while his movements were impaired by restraints, but they reiterated that

they were under orders not to remove the shackles from Mr. Greene. A superior officer

was eventually located and persuaded to authorize the removal of Mr. Greenes

handcuffs, but by that time Mr. Greenes level of distress had escalated significantly and

Attachment F Page 6
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 7 of 9

he loudly insisted that he be immediately returned to his cell where all restraints could be

taken off him. All attempts to persuade him to remain in the interview room and proceed

with testing failed, and I was unable to proceed any further with my evaluation.

17. On July 9, 2009, I returned to the Varner Unit to once again attempt to

complete my examination of Mr. Greene. Mr. Greenes counsel informed me that Mr.

Greene recently had expressed to her a willingness to try to complete the testing.

However, after being escorted to the visitation area, I was informed by correctional

officers that Mr. Greene had refused to leave his cell to meet with me and had told the

transporting officer that he was physically incapable of participating in any testing on that

date. I was therefore unable to perform any additional testing.

18. I have reviewed available medical records on Mr. Greene, and those

records suggest that there is no medical cause for the pain that he is experiencing. On

January 26, 2006, Mr., Greene was seen at the Ear, Nose and Throat Clinic of the UAMS

Medical Center in Little Rock. He complained of severe, constant pain in his left ear

since July 5, 2004. He stated that the pain was caused by purposeful and repeated

slamming of his cell door, and said that he was being tortured to death. Felicia Johnson,

M.D. offered the opinion that the left-sided otalgia was probably due to

temporomandibular joint dysfunction. In addition, there were some symptoms of

Menieres disease including tinnitus or ringing in the ear.

19. During that same hospital visit, doctors examined an MRI scan of Mr.

Greenes brain and cervical spine that was done on December 9, 2005. The MRIs were

completely normal, with the exception of some degenerative changes in several


Attachment F Page 7
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 8 of 9

20. Due to the apparent absence of any medical cause for the extreme pain

that Mr. Greene experiences, it is my opinion that he is suffering from somatic delusions.

A delusion is a firmly established yet false belief that is based upon an incorrect inference

about external reality. A somatic delusion is a delusion that centers around the

appearance or functioning of ones body. Delusions are associated with a number of

psychiatric disorders, especially psychotic disorders, and based upon my clinical

experience I suspect that Mr. Greene suffers from one of these disorders. My suspicion is

supported by Mr. Greenes paranoid and delusional attribution of his injuries to the

actions of a conspiracy. Additionally, in light of the well-known genetic component of

many psychiatric disorders, the extensive history of mental illness on both sides of Mr.

Greenes biological family further suggests that he is suffering from a major mental

disease. In order to accurately assess and diagnose Mr. Greenes disorder, an evaluation

by a psychiatrist is required. Further testing (by a psychologist), which is a lengthy

process, examining his personality and psychiatric functioning is unlikely to be

successful given Mr. Greenes current level of functioning. On the other hand, a

psychiatrist, relying on their skills with diagnostic interviewing, should be able to

establish the diagnosis.

21. Notwithstanding my present inability to conclusively diagnose Mr.

Greenes condition, I can state that his symptoms, and especially his somatic delusions,

are actively preventing Mr. Greene from assisting his counsel and participating in the

investigation and development of his claim of mental retardation. Indeed, Mr. Greenes

preoccupation with his physical pain is so all-consuming that it prevents him from

focusing on any aspect of his legal situation. Mr. Greenes inability to undergo a

Attachment F Page 8
Case 5:04-cv-00373-SWW Document 61-2 Filed 08/21/09 Page 9 of 9

complete battery of neuropsychological tests is the direct result, in my opinion, not of any

volitional unwillingness to cooperate or of a desire to abandon his appeals, but rather of

his mental disease.

I declare under the penalty of perjury under the laws of the United States that the

foregoing is true and correct.


Dale G. Watson, Ph.D.

Attachment F Page 9
Attachment G Page 1
COUNTY OF ~r..ct. . )


, after first being duly

sworn, do hereby swear, depose and state that:

thi ngs

contained herein are true and accurate to the best of my

knowledge, information and belief.


oJ,S-(- day of av.~ , a Notary Public, on
20 {)g_____ .

\. My Commission Expires: 5/31IXJ'7


Attachment H Page 1

UAMS#: 00070-11-89
DOB: 03/13/1955
ACC'l'il: 070118906003
DATE: 01/26/2006


CHIEF COMPLAINT: I,eft ear pain.

HISTOEY Of' PHESEN'l' ILLNE:SS: Mr. Green is a 50-year-old instItutional

pati.ent who presents to t:he E'.NT Clinic today with a chiet complaint at
severe, constant, 1.8ft ear pairl. TIe states that thj.s ear pain started on
July 5, 2004, after he felt a pop in hIs left ear. He also states tllat
lhis pain was caused by a pu_cposeful and repeatod slamming of hi::> cell door
at hi.s j.llstj.tuti.on. He states that no treatment he has tri.ed has rs.l.i.eved
thl.S pain and that the pai.ll i.s "tortlJriI19 hi.m to deatl1.' The patient
denies any heaL'ing loss. He donie.s any tL'LlG vertigo symptoms, although he
does state that he has a constant genc.calized dysoquilibriurn. He denies
any acute episodes of vertigo aasoctated with bearing down or heavy
lifting. lIe does admit to a Bonae of aural pressure and tullno:";;3 1 i1:", weT I
as sensitivity to noise. He also admits to tinnitus in hi:] lett eaL that
includes anything from ringing, Lo a cricket sound, to .cour:inq. The
pati.ont doni.os any i.nfecti.ons or drai.nage.

PAST MEDICAL HISTORY: The paLieIlt 3uslairled a stIotgurl WOUIld to his riqtlt
foot in 1984. he ulso tlus a Lore rotator cuff in tlis rig tIt stloulder. lIe
also complains of left sided neck pain for tl", past two months.

SOCIAL HISTORY: The patient doe~.) have d 30-pack Y+JiJr hi:3tory of .'Hnok:inq,
but qu.i t srnoki nq [ollryears ago. He (jellies aJ.cotlol 113e ()r (jrlleJ llSP.



FEVIEW OF SYSTEMS: A complete review of systems is listed in the

pati.entrs paper chart.

Gerlcral: In geIlersl l tllG paticflt appears weJ.l afId is ill flO acuLe
I-IE~ENT: Head is normocephaltc, at.raumatic. Pupl.ln equal, round, reactive
Lo light. extraocular movements are in tact. Ears were examined undeL'
microscopy. Examirlutiorl DILlIe riqIIt ear ShOW3 eviderlce of a previous
tympanic membrane perforation in the anteri.or/inferior quadrant that: hBS
now healed over with a thin squBmous layer. There is no middle ear
effu,sion. Exam of the left eur is completely normal with no middle ear

? of ?


Attachment I Page 1
U1IMSj[: 00070-11-89
ACCT,: 070118906003

effusion or tympanic membrane abnormality. There is no abnormality of the

external auditory canal or auricle. F:xam of i-.he nose is normal. Exam of
the oLul cavity is nor:mal w-ith a class 1 occlusion. The paLLenL does have
Lenderrless to palpatiofl oiLlIe left temporomandibular joint. Ttlere is flO
obvious crepitus or clicking however.
Mirror exam: Normal hypopharynx and larynx. The vocal cords are immobile
biJ.aterilJ.Jy, arId ttlere are no J.8510T13 seerl.
Neck: EXiJIH oJ: the neck cloe~:; not. r.'c..;JveiJ:! i:lny rnil~),<3e~> oc aclenopdLhyLhaL ar(~

AUDIOLOGY: The patient has an audiogram from December 200~) performed in an

outstde insti.tution. Thi.::> shows a mi.ld symmetric, hi,gh frequency
sensorirloural lloarirlg loss.

RADIOLOGY: The pattent had an MRI of hi.s brai.n and cervi-ca'] done on
December 9, 2000. He brought this to clini.c today and thts wa~l reviewed.
The MJ{1 of the bL'ain i.s completely nonnal with no ovidence of tumor in tho
internal auditor"y canal. The" Ml-G of the C-spine showed deq()neraLlve
changes i.n C4 and CEI and C~') and C6 d.i.scs bulging more pronouncod <1t
the C~), C6 .level. rt a,1so showed iJ C5, C6 posteroJatoraJ npondylytic npur.


1. This is a 50-year-old male with severe left sided otalgia that is
probably due to temporomandibular joint dysfunction. The putient WU3 given
a prescription for ibuprofen 600 mg Lo Lake Un"ee Lo four Limes daily. lIe
was also advised to stay on a 80f1: for about two wc:cks and apply warm
compresses to the tender area. 'T'he patient:: also describes some: symptoms of
Meniere's disease, i)J,thollgtlttlSy are flot cJ.ussj.c. Ttle piltierlt: was gi.ven iJ
prescri.f)'ti.on f()r Maxzide 25/3"J.5 mg ilnd was advi.sed to re~i1~ri(:t tli.s saJ.1:
inLake in his diet to 1500 mg peL" day. 1 counseled Lhe paLienL LhaL his
pain is most likely related to dysfunction in his temporomandibular joint
and that the treatment

The patient was seen and examined by Dr. Johnson, who formulated the plan.

Electronically Signed by
Felicia Johnson, MD 03/31/2006 17:46

Felicia Johnson, MD


2 of 2

PIUNTED BY: llNSMl'l'H DATE 2/18/2009

Attachment I Page 2

I, Dr. Ruloff Tunrer, being of sound mind and legal age do hereby swear and state:

l. I am a medical doctor licensed by the State of Arkansas. I previously was

employed by Correctional Medical Services (CMS) which was contracted by the Arkansas

Department of Corrections to provide medical services and care to their inmates. I have worked

at the Varner Unit as well as the Delta Unit. I am no longer employed by CMS.

2. I remember Jack Greene while I was rvorking at the Varner Unit. He was a

grizzledold man. I remember he was moving all the time, he would never stay still, He did

these yoga like movements constantly. He said he had to move to ease his pain.

3. I ordered some x-rays be taken of him. However, on examination of him I could

not determine that anything was physically wrong with him. He might have had mental

problems, I just don't know. I am not a psychiatrist.

4. I have looked at my notes in Mr. Greene's prison medical chart and they are


I declare under the penalty of perjury that the foregoing is true and corect.

Executed on this 4a auyof August, 2011.

h/*^e aa.

Attachment J Page 1

I, Julie Brain, do declare as follows:

1. I am the Chief of the Capital Habeas Unit of the Delaware Federal Public

Defender Office. I have been a criminal defense attorney for over 14 years and for the past 9

years, I have represented prisoners under sentence of death in postconviction proceedings in

states including California, Arkansas, South Dakota, and Delaware. I was the attorney primarily

responsible for representing Jack Gordon Greene in his federal habeas corpus case between

September 7, 2004 and September 11, 2009. During those years, I was Chief of the Capital

Habeas Unit of the Arkansas Federal Public Defender's Office. I have since resigned that

position and no longer represent Mr. Greene.

2. In my capacity as counsel for Mr. Greene, I informed the Court on October 12,

2004, that Mr. Greene's mental incompetence was preventing him from completing an

Application to Proceed Without Prepayment of Fees or an Affidavit attesting to his indigence. In

Mr. Greene's Petition for Writ of Habeas Corpus, I informed the Court that Mr. Greene's mental

incompetence had severely hampered counsel's efforts to discover and present meritorious

grounds for relief. On June 3rd, July 13th, and August 3, 2009, I again pleaded Mr. Greene's

mental incompetence.

3. I remain firmly convinced that Mr. Greene was severely mentally ill and legally

incompetent thougout the entire period that I represented him. The symptoms observed by Dr.

Dale G. Watson in May, 2009 and noted in his Declaration, filed with this Court, are virtually

identical to those that I observed while attempting to interact with Mr. Greene over the entire five

years that I tried to represent him.

Attachment K Page 1
4. It was apparent to me that Mr. Greene was experiencing psychotic delusions of

pain and persecution. Mr. Greene talked of feeling constant, intense pain in his brain, ear, and

spinal cord and yet his medical records revealed that neither the prison doctors who treated him

nor the outside, private physicians that were consulted were able to find a physical problem that

would cause his symptoms. Over the course of my representation, Mr. Greene engaged in

increasingly bizarre behavior in an effort to ease the pain that he experienced. Towards the end

he traveled throughout the prison in a wheelchair because he believed that he was in too much

pain to be able to walk. He constantly twisted and contorted his body in an effort to find a

position that was not excruciating. Mr. Greene was extremely sensitive to sound, most

particularly in his left ear, and sudden loud noises caused him enormous distress. To guard

against the discomfort he experienced as a result of the noise level in the prison, Mr. Greene

wore an earplug in his left ear at all times, the effect of which he tried to enhance whenever

possible by holding it in his ear with his left index finger, which he kept wrapped in paper.

5. Throughout the entire period that I represented him, Mr. Greene was obsessed

with conspiracies that he believed were being perpetrated against him. Mr. Greene irrationally

believed that he was being singled out by state officials for asking to be extradited to North

Carolina and that prison guards had been intentionally causing his left ear drum to burst.

Specifically, Mr. Greene believed that the guards loudly and repeatedly slammed closed the slot

in his cell door through which he was passed items such as food and mail. Mr. Greene believed

that they did so with the express purpose of causing a noise loud enough to explode his left ear

drum, damage his spinal cord, and injure his brain. Despite repeated examinations, no evidence

of the injuries that Mr. Greene described was found, and in fact they are physiologically

Attachment K Page 2

6. Mr. Greene also believed that the primary conspiracy to punish him for seeking

extradition was being furthered by a secondary conspiracy to cover up the first. According to Mr.

Greene, participants in this cover up included numerous high public officials, the courts, and his

prior attorneys.

7. During the entire period that I represented Mr. Greene, his profound mental illness

made it impossible for me to represent him effectively. In my experience, in capital habeas

corpus cases the client's active participation is extremely important. The client can be a critically

important witness in several respects. The client's memory of the circumstances surrounding the

offense of conviction is important, as in all criminal cases. He may also be a unique source of

information regarding his own social history, a thorough and painstaking exploration of which is

essential to building a case in mitigation in death penalty cases. Whether or not the client ever

testifies, he may provide leads to other witnesses and to documentary evidence. Most times,

some of the information that counsel needs from the client is painful and embarrassing and can

only be elicited slowly, over time, and by someone who has a relationship of trust and intimacy

with him.

8. In addition to providing important leads on his social history, a client in death

penalty postconviction matters is often uniquely in possession of information about what

happened during and prior to his trial, including information about the representation he received

at trial. Aside from the trial lawyer, who is often unavailable to postconviction counsel, only the

client will know such facts as how often his trial lawyer interviewed him and whether his trial

lawyer sought to elicit mitigating evidence from him. The client can often provide evidence or

Attachment K Page 3
leads to evidence about trial-level constitutional violations that are not apparent on the face of the

trial record.

9. Once the client's case has reached the federal habeas corpus stage, he may also be

able to supply counsel with valuable information about state appellate and postconviction

proceedings in his case. In light of the statutory and judicially-developed restrictions on federal

habeas corpus actions, a petitioner usually must show flaws in the state review process in order to

receive meaningful federal habeas review of his constitutional claims. It is often the case that the

client can provide evidence or leads to evidence that exposes defects in the state court


10. In addition to serving as a witness, the client in a death penalty case may also be

called upon to make certain decisions, and he must also be informed and consulted about all

aspects of his case. In particular, the client must give his written consent before counsel may

take certain actions. For example, many institutions require a written release from the client

before they will disclose records. Furthermore, in Arkansas it is necessary to secure the client's

signature before commencing state postconviction actions on his behalf.

11. In 2004, I wrote that Mr. Greene's mental incompetence had forced me to file a

"placeholder" petition only, which almost certainly did not contain all of the meritorious claims

for relief available to Mr. Greene. I was never able to file an amended, adequate petition, nor

was I able to file an adequate Traverse answering the State's procedural defenses, because Mr.

Greene's mental condition never improved. Throughout the period that I represented him, Mr.

Greene was completely preoccupied with his delusional material. I was never able to elicit from

him necessary information about his social history, the offense of which he was convicted, the

Attachment K Page 4
circumstances of his trial, or the circumstances of the state review process. There were important

records that I was never able to collect because I could not convince Mr. Greene to sign the

necessary releases. Despite my best efforts, I was not able to meaningfully discuss Mr. Greene's

case with him because he was obsessively focused on the excruciating pain and persecution that

he believed that he was experiencing.

I declare under penalty of perjury under the laws of the United States and the State of

Delaware that the foregoing is true and correct to the best of my knowledge.

Attachment K Page 5
Attachment L Page 1
Attachment L Page 2
, i ,/
Case 5:04-cv-00.:.3-SWW Document 230 Filed 06/l-: -5 Page tl9 of t9 ' '',

WIIEREFORE, for the foregoing reasons and authorities, ,"rVond"fl\rUff

respectfully requests that the relief prayed for in-Gfeene--Motion to Vacate

Judgment be denied.

Respectful ly submitted,

Attorney General

BY: /s/ Darnisa Evans Johnson

I Arkansas Bar # 90041
Deputy Attorney General
323 Center Street, Suite 200
Little Rock, Arkansas 72201
(s0l) 682-807 s
Darnisa. Johns on@arkansas ag. gov



I, Darnisa Evans Johnson, Deputy Attorney General, do hereby certiff that I

have electronically fled the foregoing pleading with the Clerk of the Court using
the CN4/ECF system, which shall send notification of such filing to Josh Lee,
Assistant Federal Defender, l40l W. Capitol Avenue, Suite 490, Little Rock,
Arkansas 722Q1, this l9th day of June 2015.

/s/ Darnisa Evans J ohnson

,\ :M
Attachment M Page 1
Affidavit of David Lewis

l, David Lewis, do declare as follows:

1. I have been friends with Jack Greene since 2009, writing and communicating by

phone on a regular basis. I also have visited Jack in person. I saw Jack in person in

2009, and then again in August of this year.

2. I knew Jack was suffering even in 2009, but he has gone way downhill since the

last time I saw him. He had toilet paper hanging out of both ears and nose and a

badly cut and bruised face. He was barely able to stand while I spoke with him and

appeared in constant pain. He had some of these symptoms in 2009 but nowhere

near this bad.

3. Jack obviously needs medical attention and has for quite some time. His illness

may well be psychosomatic, but it plays out with severe physical symptoms so he

basically cannot walk and seems to be in physical pain all the time. I am personally

unhappy with the State for not treating him, as he obviously has problems that need


4. I decided to communicate with Jack in order to help "the least among us," and

certainly a man on death row inArkansas is close to that position. From my

perspective as an educated 71-year-old man, Jack is depressed and has a delusion

about being persecuted by the prison system-or at least I hope it is a delusion, as I

would not want to think the system would do that.

I swear under penalty of perjury that the foregoing is true and correct to the best of

my knowledge.

Attachment N Page 1


Attachment N Page 2
Attachment O Page 1
Attachment O Page 2
Attachment O Page 3
{,iri !


r, afrer fistbeing duly sworrr, do hereby swea[ depose

and state that

End of Statement
I further s\/ear that the statementq matters and thngs contairpd herein are fir and accurate to tlp
best of my knowledgE information and belief

,*' i,,,t, .',n,t.t nt,


a Publicl on this of

My Commssion Exp,ires:

My Comnti ssion 03- 1 6-2025

Attachment P Page 1
I - 1
Attachment Q Page 1
Attachment Q Page 2
Attachment Q Page 3
Attachment R Page 1
Attachment R Page 2

WW George W. Woods, Jr., M.D.
A Professional Corporation
Diplomate of the American Board of Psychiatry and Neurology



Scott W. Braden and John C. Williams, counsel for Jack Gordon Greene, referred Mr.
Greene to me for evaluation. Mr. Greene is an inmate in the custody of the Arkansas
Department of Correction under a sentence of death. Counsel for Mr. Greene asked me for
my opinion on the following forensic question:

Whether Mr. Greene is suffering from a mental disease, disorder, or defect that
renders him incompetent to be executed.

Counsel also asked me to opine on whether Mr. Greenes mental status has changed
appreciably since I last evaluated him in 2011.


I am a licensed physician specializing in neuropsychiatry. I am certified by the American

Board of Psychiatry and Neurology. A copy of my Curriculum Vita, containing a complete
statement of my qualifications and publications is attached as Appendix A of this report.


In order to address the referral questions, I reviewed materials provided to me by counsel

for Mr. Greene, including Mr. Greenes recent writings and his recent mental-health records.
Additionally, his attorneys provided me information based on their recent interactions and
phone calls with Mr. Greene. I also attempted to conduct a clinical interview of Mr. Greene
on September 14, 2017. Mr. Greene initially refused to meet. However, he was brought to
the Deputy Wardens office, where I had a chance to observe him. He had dried blood on
the left side of his face and, even in the shackles, he appeared physically deteriorated from
his previous level of health at my last visit. He continued to refuse to answer any questions.

I previously provided a report on Greenes mental status during federal litigation in 2011,
for which I relied on numerous additional materials. For this report I reviewed that prior

Attachment S Page 1
report and also relied on a previous examination of Mr. Greene conducted on April 6, 2011.


Mr. Greene suffers from a psychotic disorder and from ongoing somatic and paranoid

Based on my clinical interviews with Mr. Greene and the extensive collateral information
I have reviewed, it is my professional opinion, which I hold to a reasonable degree of
medical certainty, that Mr. Greene suffers from a psychotic disorder along the
schizophreniform spectrum. Mr. Greenes psychotic disorder is characterized by
encapsulated delusions and, in particular, by primarily somatic delusions and persecutory
delusions. The Diagnostic and Statistical Manual-Vs (DSM-V) diagnosis would be either
Delusional Disorder (page 90) or Other Specified Schizophrenia Spectrum and Other
Psychotic Disorders (page 122). The DSM-Vs definition of a delusion is: A false belief
based on incorrect inference about external reality that is firmly held despite what almost
everyone else believes and despite what constitutes incontrovertible and obvious proof or
evidence to the contrary.1 A somatic delusion is a delusion that focus[es] on
preoccupations regarding health and organ function.2 A persecutory delusion is a belief
that one is going to be harmed, harassed, and so forth by an individual, organization, or
other group.3 The essential feature of a delusion is its tenacity and rigidity, not its bizarre or
non-bizarre quality.

Here, a convergence of evidence demonstrates that Mr. Greene is suffering from a

psychotic disorder. Mr. Greenes social history supports the diagnosis of a psychotic
disorder. I previously provided a declaration detailing Mr. Greenes social history, which is
attached as Appendix B. Briefly, Mr. Greene is a 62-year-old white male who was born in
Lenoir, North Carolina. Mr. Greene was charged with capital murder in Arkansas in 1991,
convicted of capital murder in 1992, and is under a death sentence for that conviction that
was imposed in 1999. Mr. Greenes social history reveals several key risk factors for the
development of psychotic disorder, including an extensive family history of severe mental
illness, a family history of seizure disorder, advanced paternal age, extreme poverty, early
parental loss, prolonged exposure to severe childhood trauma, early marijuana use, low
cognitive functioning, early impaired social functioning, traumatic brain injury, a history of
self-harm, and ongoing solitary confinement.

DSM-V at 819.
DSM-V at 122.

Attachment S Page 2
Diverse witness accounts and records consistently describe Mr. Greene as experiencing
chronic, persistent somatic and persecutory delusions for many yearssince at least 2004.
Mr. Greene believes that his eardrum is burst, that his central nervous system has been
destroyed, that his spinal cord has been damaged or is entirely missing, and that his brain
is swollen. The beliefs are nonpathological, meaning they are inconsistent with anatomic and
neurological pathology. He believes that he experiences constant, intense pain in his brain,
ear, and spinal cord. He also believes that these injuries are the result of a conspiracy to
injure him, perpetrated by the ADC. According to Mr. Greene, employees of the ADC
torture him by purposefully slamming a slot in his cell shut in an excessively loud fashion,
which results in the injuries described. Mr. Greene believes the ADC is maliciously denying
him proper medical treatment for his injuries. Mr. Greene further believes that his attorneys
are involved in a cover up of the ADCs actions. Mr. Greene has described these beliefs to
his attorneys, to multiple medical personnel, to multiple psychologists and psychiatrists
(including me), in numerous handwritten letters and affidavits, and in his federal court
hearings. Multiple witnesses have described Mr. Greene engaging in bodily contortions and
other actions (such as plugging his ear with toilet paper) in an effort to deal with the pain
that he believes he is experiencing. Mr. Greene engages in other abnormal behaviors to
prevent further injury. For example, he has reported to his attorneys that he dumps the
contents of his food tray into the sink and eats out of the sink. This is so he can return the
tray immediately without the guards having to reopen the slot to retrieve it and slam the slot
to his cell.

Mr. Greenes presentation during my clinical interview of him on April 6, 2011, was
consistent with these witness accounts. The evaluation had been set to take place in a private
room, but Mr. Greene was unable or unwilling to leave his cell. As a result, I was escorted to
his cell door and interviewed him cell-side. Mr. Greene appeared to be a middle-aged white
male wearing prison garb. His clothes were not unusual. His movements were distorted and,
at times, while fluid, contorted in extraordinary positions. Much of our interview was
conducted while he was standing on his head on the floor.

Similar to my attempted interview on September 14th, 2017, Mr. Greene initially refused
to speak with me, but he eventually proceeded to discuss with me what he perceived as his
overwhelming medical problems. Mr. Greene told me that his left eardrum had been
destroyed, that his brain was not working, and that his spine had been severed. He
emphasized that he was experiencing great pain and grimaced intensely while describing it.
Mr. Greene described, in great detail, the ongoing harassment he believes he has suffered
secondary to attempting to get the ADC to respond to his medical needs. Mr. Greene told
me that his attorneys have joined the ADC in helping the prison cover up what he believes
to be medical maltreatment. Mr. Greene acknowledged not working with his attorneys and
was unwilling to answer any questions concerning his social history. He informed me that he
had requested that the judge let him withdraw his appeals so that he end the torture that he

Attachment S Page 3
believes he is experiencing.

Mr. Greenes rate of speech was normal, but he was somewhat perseverative, meaning he
gets stuck in his speech pattern, often repeating phrases as if for emphasis. His thought
processes reflected some circumstantial speech with the addition of unnecessary details. His
thought content was occasionally grandiose, and most often psychotic, when discussing his
encapsulated delusional material. He was not able, during my conversation with him, to
move away from his somatic complaints. His mood was anxious, and he was angry, both at
me and his attorneys. His affect was restricted in range.

During my most recent interview of Mr. Greene, on September 14, 2017, Mr. Greene
once again refused to come out of his cell. This time the prison refused to allow me to visit
him at his cell, however, and guards had Mr. Greene physically removed to a room where I
was to meet with him. The left side of Mr. Greenes face was covered with dried blood. The
guards did not permit me a private consultation but instead remained in the room while I
attempted to engage Mr. Greene. All Mr. Greene would say was to tell me to get the fuck
out of here. After further unsuccessful attempts to engage Mr. Greene, I ended the

The somatic complaints described by Mr. Greene are delusions. His beliefs about his
body are false, but he maintains them despite overwhelming evidence that they are false.
Many of the symptoms that Mr. Greene describes are non-pathological, meaning they
cannot be explained by normal anatomic means. Other symptoms he describes, while
physically possible, are not consistent with reality and certainly not consistent with the
degree of physical body control and flexibility that Mr. Greene maintains. Mr. Greene
believes that his spinal cord is not functioning, but the degree of bodily control and
flexibility that he maintains demonstrates that it is functioning. Mr. Greene believes that his
left eardrum is burst, but repeated medical evaluations have shown an intact eardrum. While
some of Mr. Greenes medical records suggest conditions that could be painful, it is clear
that delusional beliefs about the extent, location, and cause of the pain have become
attached to any actual physical problem that he might have.

Instead of suggesting any bodily dysfunction of the sort that Mr. Greene describes,
medical reports regarding Mr. Greene have suggested that Mr. Greene is experiencing
psychological problems. For example, medical professionals at the ADC have described Mr.
Greene as mentally unstable and exhibiting scattered speech and paranoia. One
medical report from the federal hospital in Springfield, Missouri described Mr. Greenes
thought process as illogical, stated that his speech was erratic, and observed that he gave
inconsistent and unreliable answers to questions. A nurse at the federal hospital described
Mr. Greene as irrational and exhibiting an appearance of disarray. Even when I saw him
today, Mr. Greene had dried blood covering the left side of his face.

Attachment S Page 4
Mr. Greenes secondary beliefs that he is being persecuted by the ADC and his attorneys
are also delusions. Mr. Greene maintains his belief in a conspiracy against him despite
overwhelming evidence that he has not, in fact, been injured and is not being denied
appropriate medical treatment by the ADC. He maintains his belief that his attorneys are
conspiring against him despite the federal district courts assurance that his attorneys have
adequately represented him and have acted in what they believe to be his best interest.4

Mr. Greenes presentation bears all the hallmarks of a genuine, severe delusion. The
MacArthur-Maudsley Delusions Assessment Schedule rates delusions to the extent that they
are (1) held with conviction, (2) produce a negative affect, (3) motivate the subject to act, (4)
cause the subject to refrain from actions, (5) preoccupy the subjects thoughts, (6) pervades
the subjects experiences, and (7) change to encompass new people or contexts. Mr.
Greenes presentation has every one of these qualities.

CONVICTION: Mr. Greenes beliefs are held with a rigid conviction. Mr. Greene has
complained of a burst left eardrum and extreme left ear pain since at least 2004, and there is
no evidence that this belief has ever waivered. He has consistently rejected intervention that
did not support his beliefs. He holds onto his belief even though he has never had one
medical provider of any type find evidence that supported his false beliefs.

NEGATIVE AFFECT: Mr. Greenes beliefs produce a negative affect in several ways.
They make him unhappy inasmuch as he has repeatedly expressed that he would rather die
than live in the pain that he feels. Mr. Greenes delusional beliefs also make him anxious and
angry, as multiple people who have interacted with Mr. Greene describe. Mr. Greenes anger
at the ADC, his attorneys and, today, at me, is a manifestation of the negative affect of his
delusion. He is angry at the ADC staff because he believes they are injuring him and failing
to treat his injuries. He is angry at his attorneys because he believes that they are attempting
to cover up the ADCs crimes.

ACTION: Mr. Greenes beliefs motivate action. This particular characteristic is seen in
Mr. Greenes case on a daily basis. In effort to deal with the pain he experiences, Mr. Greene
contorts himself in awkward positions for most of the course of a day, although he can
occasionally be seen lying on the floor or in the bed. Mr. Greene will plug his ear with make-
shift earplugs and insist on being transported by wheelchair. The actions that Mr. Greene
takes in response to his somatic beliefs occur in a wide variety of situations. He has exhibited
these actions in meetings with his attorneys; during medical evaluations; in court; and while

February 24, 2010 Status Hearing Transcript at 1112; Order, Greene v. Hobbs, No. 04-cv-
00373-SWW, Doc. 130.

Attachment S Page 5
sitting alone in his cell. Much of his time is consumed with hypergraphic writings about the
perceived conspiracy and his perceived injuries.

INACTION: Mr. Greenes delusional beliefs also result in inaction. In most instances,
Mr. Greene will not meet with his attorneys5 because he believes that doing so aggravates
his pain and because he believes that they are conspiring against him. Mr. Greene will not
participate in neuropsychological testing arranged by his attorneys for the same reasons.6
On the single occasion on which Mr. Greene has agreed to visit with his attorneys in the past
decade, he did so in the presence of Mr. Greenes pen pal, whom Mr. Greene has not yet
incorporated into his delusion. Likewise, when Mr. Greene accepts mail from his attorneys,
it is to receive documents that he believes are needed to prove his injuries. He refused to see
me as well.

PREOCCUPATION: Mr. Greenes beliefs focus on his somatic complaints. Josh Lee, an
attorney who represented Mr. Greene from 2009 to 2016, explains:

During my private in-person and telephone contact with Mr. Greene, he was
obsessively focused on his belief that there was a conspiracy against him. Mr.
Greene told me that an extradiction [sic] agreement obligated the State of
Arkansas transfer him to North Carolina, where another charge was pending
against him. He told me that he had been pushing that issue for years and
that, as a result, various people acting on behalf of the State of Arkansas were
retaliating against him. He said that, in retaliation, prison guards had assaulted
and battered him and that, due to these crimes, he had suffered various
permanent, excruciating, and debilitating injuries. Mr. Greene believed that
essentially everything in his life was related to this conspiracy. 7

Mr. Greenes presentation during his federal court hearings and during his clinical interviews
with me also demonstrate a single-minded preoccupation with his delusional material. It is
true that Mr. Greene can think about and discuss other things. Mr. Greene is able to discuss
other issues beside his somatic delusion for short periods. While Mr. Greene does not
exclusively think about his somatic concerns, they overwhelmingly predominate.

February 24, 2010 Status Hearing Transcript at 12; Declaration of Tonya Willingham;
Returned Mail of Federal Public Defender; Motion for Leave to Depose, No. 04-cv-00373-SWW,
Doc. 76 89.
Declaration of Dr. Dale Watson 17.
Declaration of Josh Lee 56.

Attachment S Page 6
PERVASIVENESS: Mr. Greenes delusions are pervasive in the sense that he relates and
interprets many of his experiences as related to the delusional belief. The pervasiveness of
Mr. Greenes delusion is shown most clearly by his incorporation of his attorneys into his
encapsulated delusion. Mr. Greene has had a number of different attorneys during the past
decade, and as soon as he realizes that a new attorney will not address his somatic
complaints, Mr. Greene interprets this experience in light of his delusion; he incorporates
the new attorney into his delusion by concluding that the attorney is participating in a cover
up. The incorporation of attorneys and others attempting to evaluate him for his attorneys is
complete. There have no been persons he has been willing to see, within the legal sphere.

FLUIDITY: Mr. Greens delusion is fluid. It incorporates the ADC, the Arkansas
Government, his attorneys, and others, as they attempt to assess him. His delusion that he
has been injured by the clanging of his cell door has been constant since 2004. However, the
particularities of his injuries, and the people involved, have shifted over time. Regarding his
injuries, in 2004, Mr. Greene complained primarily of a burst left ear drum and of extreme
pain in his left ear. By 2006, Mr. Greene was complaining not only of injury to his left ear
but also of injury to his brain and spine. Currently, Mr. Greene complains that his nervous
system has been destroyed and that he has a pre-cussion concussion. Regarding the people
involved, Mr. Greenes somatic delusion evolved to include secondary, persecutory delusions
and grew to encompass prison medical staff and his attorneys. That the particularities of Mr.
Greenes injuries shift over time and that he incorporates more and more people into his
delusion reinforces the degree of fluidity. For example, Greene was appointed an attorney in
North Carolina in 2016 to assist him with pending proceedings there. Mr. Greene told the
attorney that he was being constantly injured in the Arkansas prison. When this attorney
would not help Mr. Greene be returned to North Carolina in the manner Mr. Greene saw fit,
Mr. Greene attempted to file grievances on him with the North Carolina bar. 8

Mr. Greenes mental illness and delusional conduct are exacerbated by both the
conditions of his confinement and his lack of adequate mental-health treatment by prison
authorities. From 1992 to 2003, Mr. Greene was housed at the Tucker Max unit, where
prisoners were held in isolation though with some opportunity to exercise and interact with
fellow prisoners. Since 2003, Mr. Greene has been housed at Varner in completely solitary
confinement, behind a solid door that prevents interaction with other inmates. Prisoners are
allowed out of their cell for one hour a day, where they may access an exercise area that is
akin to a small carport. It is well understood that this sort of arrangement has devastating
consequences for the mental health of all peoplenot to mention profoundly mentally
disordered people like Mr. Greene who have previous indications of mental illness. I find it
notable that Mr. Greenes somatic and persecutory delusions began about a year after he was

See Declaration of Garland Baker 6.

Attachment S Page 7
moved to total isolation at Varner.

The detrimental effect of solitary confinement is compounded by the fact that death-row
inmates at Varner have superficial, if any, access to mental health care. Depositions
conducted in prior litigation in Mr. Greenes case demonstrate that. For example, the prison
staff member who used to be responsible for screening Mr. Greene for mental health
problems, Julia Partain, admitted in a deposition that she did so without even speaking to
Mr. Greene. A second prison staff member who has screened Mr. Greene for mental illness,
Natasha Martin, revealed in her deposition that she lacks even the most rudimentary
knowledge of psychology and mental health symptoms. And Sandra Bonner, a former staffer
who once screened Mr. Greene for mental illness, admitted in a declaration that her
supervisors warned her against providing psychiatric treatment to death row inmates because
[t]he mental health services unit did not want to be involved in any way with an inmates
efforts to stop their execution by claiming mental illness.

Review of Mr. Greenes most recent mental-health records shows that this state of affairs
continues. Mental-health treatment consists of staffers briefly stopping by Mr. Greenes cell
and inquiring about his status. Typically the staffer will make an entry saying Mr. Greene
voiced no mental health concerns and leave it at that. Staff uses this formulation even
when also noting that Mr. Greene is asleep, making it a worthless indicator of Mr. Greenes
mental-health status. Mental-health staff do not otherwise attempt to intervene or otherwise
provide mental-health treatment, though Mr. Greenes need for it is obvious. From my
review of mental-health records, it appears that Mr. Greene has not been provided the type
of psychotropic medication that one would expect a person in his condition to be

In summary, Mr. Greenes delusions are false beliefs that he has maintained despite
overwhelming evidence that they are false. Mr. Greene believes, despite overwhelming
evidence to the contrary, that his left ear, brain, and spinal cord have been injured by the
clanging of his cell door and that his injuries are being maintained and suppressed by the
action of a wide-ranging conspiracy. There is no evidence that Mr. Greene is exaggerating or
feigning these beliefs. Mr. Greenes beliefs meet all the characteristics of a delusion.
Accordingly, Mr. Greene suffers from a psychotic disorder, Delusional Disorder or Other
Specified Schizophrenia Spectrum and Other Psychotic Disorder. I hold these views to a
reasonable degree of medical and professional certainty.


For the reasons explained below, Mr. Greene is incompetent to be executed as a result of
his psychotic disorder.

Attachment S Page 8
A. Legal standard for incompetence to be executed.

The United States Supreme Court has defined the standard for competency to be
executed in Ford v. Wainwright, 477 U.S. 399 (1986), and Panetti v. Quarterman, 551 U.S. 930
(2007). The controlling opinion in Ford holds that prisoners are incompetent to be executed
if they are unaware of the punishment they are about to suffer and why they are about to
suffer it. Ford, 477 U.S. at 422 (Powell, J., concurring). In Panetti, the Court clarified that this
standard does not mean that a prisoner is automatically foreclosed from demonstrating
incompetency once a court has found he can identify the stated reason for his execution.
Panetti, 551 U.S at 959. Rather, a person is incompetent if delusions . . . so impair the
prisoners concept of reality that he cannot reach a rational understanding of the reason for
the execution. Id. at 958. The potential for a prisoners recognition of the severity of the
offense and the objective of community vindication are called in question . . . if the
prisoners mental state is so distorted by a mental illness that his awareness of the crime and
punishment has little or no relation to the understanding of these concepts shared by the
community as a whole. Id. at 95859.

B. Mr. Greene has a mental illness and suffers from persistent delusions.

As discussed in detail in Part IV above, Mr. Greene suffers from somatic and persecutory
delusions and from a mental illness that lies along the same spectrum as Schizophrenia. I
hold this opinion to a reasonable degree of medical and professional certainty.

C. Mr. Greenes mental illness renders him incapable of rationally understanding

the reason for his execution, and thus incompetent to be executed.

Based on my review of records and discussions with his attorneys, Mr. Greene can
articulate that he is to be put to death for the killing of Sidney Burnett. That basic
comprehension, however, does not by itself satisfy the competency inquiry. I am also to
assess whether Mr. Greenes understanding of his punishment is distorted by his mental
illness to the point that it departs from concepts shared by the community as a whole.
Panetti, 551 U.S. at 959.

Mr. Greenes psychotic understanding of his execution is dominated by his somatic and
persecutory delusions. In Mr. Greenes mind, his execution is the culmination of the ADCs
conspiracy against him. Mr. Greene accepts the execution as a means of escaping the torture
he (delusionally) believes he has been exposed to. As Mr. Greene has repeatedly stated, he
would rather be executed than continue to suffer the injuries he believes the prison guards
have inflicted on him.

Mr. Greene has had one goal in his life over the past several years (if not before): to

Attachment S Page 9
expose the conspiracy that he is believes is being carried out against him. His fixation on this
objective has been especially pronounced during the past year, during which he has written
everyone from the Civil Rights Division of the U.S. Department of Justice to local news
reporters to share a catalogue of his injuries and complaints about the conspirators. This
obsession has colored Mr. Greenes comprehension of his execution, such that he cannot
understand it as the final step in carrying out his criminal sentence. Instead, it is the final step
in a cover up. As he recently wrote a news reporter, My worse fear is not of dying of my
inhumane injuries or being put to death from execution, for we must all stand in judgment
of God, my earthly fear is this system getting away with what has/is being done to me over
the past 13 years.

Paradoxically, Mr. Greene apparently sees his execution not only as a way to escape
physical torture, but also as a means to expose the conspiracy against him. For example, he
recently wrote, I would have gotten off Death Row 6 or 7 years ago if I would have allowed
this state etc. to get away with their planned cover-up of crimes as described. Mr. Greenes
desire to go to his death in the service of a delusional goal belies a rational understanding of
his execution.

Mr. Greenes incomprehension of the purpose of his execution is further exhibited in his
approach to clemency proceedings. Mr. Greene wishes to petition for clemency, but on one
ground onlythat he be extradited to North Carolina. He wants to be extradited to North
Carolina so that he may receive that medical treatment he believes is being denied by the
ADC. Otherwise he would prefer to be executed so the prison will stop injuring him. Mr.
Greenes belief in the conspiracy to inflict these injuries, as already discussed, is the product
of a delusion. The community at large would not share Mr. Greenes belief that he is being
executed as part of a cabal. I thus cannot conclude that Mr. Greenes understanding of his
execution is the product of rational thought.

In sum, Mr. Greene does not comprehend that his execution will be imposed as the final
judgment of a court of law for the killing of Sidney Burnett. Instead, because of his
psychotic disorder, Mr. Greene understands his execution to be yet another step in an all-
encompassing scheme to physically harm hima scheme that his death will allow him both
to expose and escape. It is thus my conclusion, to a reasonable degree of medical and
professional certainty, that Mr. Greene is not competent to be executed.

D. Mr. Greenes mental status has deteriorated since his last evaluation in April

Finally, I was asked to provide an evaluation of Mr. Greenes mental status today as
compared to his mental status at the time I last evaluated him in 2011. It is obvious that Mr.
Greenes mental condition has seriously deteriorated over the past six years. Although I did

Attachment S Page 10
Attachment S Page 11
Attachment A

Attachment S Page 12

415 503 3959
Oakland Atlanta Evansville

Curriculum Vitae
401 Grand Avenue, #380
Oakland, California 94610

4062 Peachtree Rd NE Suite D-203

Atlanta, Georgia 30319

437 South Rotherwood Avenue

Evansville, Indiana 47714

1981-1982 American Psychiatric Association/National Institute of Mental Health
Fellowship Pacific Medical Center, San Francisco, California

1981 Residency Psychiatric - Pacific Medical Center, San Francisco, California

1977-1978 Internship Medical/Surgical, Highland Hospital, Oakland, California

1977 M.D. University of Utah, Salt Lake City, Utah

1969 B.A. Westminster College, Salt Lake City, Utah

Leadership Positions
2017 Secretary General, International Academy of Law and Mental Health, during the
amalgamation with the Institute of Ethics, Medicine, and Public Health at the
Sorbonne, Paris, France

2016 Associate Editor, Journal of Policy and Practice in Intellectual


Attachment S Page 13
2016 Deputy Chairperson, International Association for the Specialized Study of
Intellectual and Developmental Disabilities, Special Interest Research

2015 President, International Academy of Law and Mental Health

2013 President Elect, International Academy of Law and Mental Health

2009-2013 Secretary General, International Academy of Law and Mental Health

Licenses & Certifications

2014 Certified International Association for the Scientific Study of Intellectual and
Developmental Disorders Academy (IASSDD) Academy Instructor.

2008 Certified Mediation Specialist, California State University, Sacramento,


2004-2005 Interim License, Zanzibar Revolutionary Government

1992 Certified by the American Board of Psychiatry and Neurology

1979 Licensed Physician in California

2017 Secretary General, International Academy of Law and Mental Health

2015 President, International Academy of Law and Mental Health

2013 Keynote Speaker, Tenth Anniversary of the San Francisco Behavioral Health Court

2013 Vice President/President Elect, International Academy of Law and Mental Health

2009-2012 Secretary General, International Academy of Law and Mental Health

2009 Co-Chair, International Academy of Law and Mental Health Congress, New York
University Law School

2007 Co-Chair, International Academy of Law and Mental Health Congress, University
of Padua, Padua, Italy

2007 Executive Committee, International Academy of Law and Mental Health

Attachment S Page 14
1993 Outstanding Professor Award, Goodrich Program, Department of Public Policy,
University of Nebraska at Omaha

1992 National Medical Enterprises Outstanding Medical Director of Psychiatric,

Rehabilitation and Recovery Hospitals

1992 Chief of Staff Award for Outstanding Service, East Bay Hospital, Richmond,

Faculty and Professional Appointments

2012-present Lecturer, University of California Berkeley School of Law

2012 Newsletter Editor, Challenging Behaviors Special Interest Research Group,

International Association for the Scientific Study of Intellectual Disabilities

2008 Secretary, American Psychiatric Associations Africa Action Committee

2003 Adjunct Professor, California State University, Sacramento, Department of

Educational Leadership and Public Policy, Sacramento, California

2002-present Adjunct Professor, Morehouse School of Medicine, Department of Psychiatry,

Atlanta, Georgia

1999-2004 Affiliate Professor, University of Washington, Bothell Campus, Interdisciplinary

Arts and Sciences

1996-2000 Adjunct Professor, University of California, Davis, Department of Psychiatry,

Forensic Fellowship
1992 Summer Faculty, North Central Educational Research Laboratory, Northeastern

1986-2002 Adjunct Professor, University of Nebraska, Omaha, College of Public Affairs

Advisory Boards
2016 Marsh Clinics, Oakland, California

2013 International Association of Trauma Professionals

2013 Celebrating a Decade of Behavioral Health Court, San Francisco, California,

Honorary Committee

Attachment S Page 15
2012 Executive Committee, Challenging Behaviors Special Interest Research Group,
International Association for the Scientific Study of Intellectual Disabilities

2006-present Executive Committee, International Academy of Law and Mental Health

2004-2007 Advisory Board, Health Law Institute, DePaul University, College of Law

2004-present Advisory Board, Human Dignity and Humiliation Studies, University of Trondheim,

2004-2010 Board of Directors, The Center for African Peace and Conflict Resolution, College
of Health and Human Services, California State University, Sacramento

2003-present International Board of Directors, International Academy of Law and Mental


Professional Affiliations
International Neuropsychological Society

American Academy of Psychiatry and the Law

International Association for the Scientific Study of Intellectual Disabilities

Northern California Psychiatric Society

American Society of Addition Medicine

American Psychiatric Association

Black Psychiatrists of America

American Neuropsychiatric Association

American Psychological Association

American Association for Intellectual and Developmental Disabilities

Attachment S Page 16
Clinical Experience & Consultation
1983-present Individual private practice, Bay Area, California

2016 San Francisco Police Department Crisis Intervention Training(SFPD CIT): The Brain

2015 SFPD CIT: Substance Abuse

2015 SFPD CIT: The Adolescent Brain and Cognition: Slow Down and Watch

2015 SFPD CIT: The Developing Brain

2015 Criminal Justice and Mental Health Reform. San Francisco Collaborative Courts,
Collaborative Courts Training Series

2015 Complex Trauma: Effects and Intervention.

San Francisco Collaborative Courts, Collaborative Courts Training Series

2014 Undoing the Damage: The Mental Health and Criminal Justice Tragedy.
San Francisco Collaborative Courts, Collaborative Courts Training Series

2014 The Constitutional Implications of Ebola: Civil Liberties & Civil Rights in Times of
Health Crises, University of California, Irvine Law School

2014 SFPD CIT: The adolescent and geriatric brains, more alike than different?

2014 Moderator; The Easy Read Project: an investigation into the accessibility value of
health- based easy read literature; Television viewing habits and preferences of
adults and your people with intellectual disability: a survey using a Talking Mats
Questionnaire; Effectiveness of Computer-Based Simulations on Learning of Social
and Communication Skills by Children with IDD and ASD; Social media and
intellectual disabilities: IASSID European Regional Congress, Vienna.

2014 Risk Assessment in Neurodevelopmental Disorders, IASSID European Regional

Congress, Vienna

2013 Task Force on Determination of Intellectual Disability for the Courts, American
Association for Individuals with Intellectual Disabilities

2011 San Francisco Police Department Crisis Intervention Training (CIT): Suicide
Assessment, Mood disorders, thought disorders, and personality disorders

2010 Task Force on Mental Retardation and Forensic Practice, American Association for
Individuals with Intellectual Disabilities.

2006-2009 Projects Among African Americans To Explore Risks for Schizophrenia

(PAARTNERS), Consensus Diagnosis Group, Minority Mental Health Research
Group, Department of Psychiatry, Morehouse School of Medicine, Atlanta, Georgia

Attachment S Page 17
2006 National Consortium on Disaster Response for the Poor and Underserved,
Developmental Task Force for the Minority Mental Health Professions Foundation,
Atlanta, Georgia

2006 Georgia Congressional Representative Cynthia McKinneys Post-Katrina Working

Task Force

1998-2004 Consultant to the Board of Directors, Crestwood Behavioral Health Systems,

Stockton, California

1994-1996 Senior Consulting Addictionologist, New Beginnings Programs, San Ramon and
Pinole, California

1988-1996 Individual Private Practice, Pinole, California

1994-1995 Chemical Dependency Consultant, Physicians Advisory Committee, Alameda

Contra Costa Medical Association

1990-1995 Consultant, Insomnia Division of the Sleep Disorders Center, Doctors Hospital,
Pinole, California

1992-1994 Qualified Medical Examiner, Industrial Medical Council, State of California

1990-1994 Medical Director, Pain Management Program, Doctors Hospital, Pinole, California

1991-1993 Psychiatric/Pharmacologic Consultant, Triumph Over Pain (TOP Program), Kentfield

Rehabilitation Hospital, Kentfield, California

1991-1993 Psychiatric Consultation, NeuroCare Corporation, Concord, California

1989-1994 Clinical Director, New Beginnings Chemical Dependency Program, Doctors Hospital,
Pinole, California

1988-1993 Private Practice, Comprehensive Psychiatric Services, Walnut Creek 1983-1990:

Staff Psychiatrist, Crestwood Manor, Vallejo, California

1982-1983 Medical Director, Westside Geriatric Services of Family Service Agency of San

1982-1983 Staff Psychiatrist, Villa Fairmount Psychiatric Facility, San Leandro, California

1981-1982 Assistant Director of the Inpatient Center, Director of Geriatric Services, Pacific
Medical Center, San Francisco, California

1980-1981 Medical Director, Clinica De La Raza, Blythe, California

1979-1981 Emergency Room Physician, Medical Emergency Services, Fairmount Hospital, San
Leandro, California

Attachment S Page 18
International Clinical Experience & Consultations
2017 Cognitive Factors to Financial Crime Victimization: International Academy of Mental
Health, Prague.

2017 From the Profession: First Concepts, Stigma, and Science. Punjab Judicial
Conference, Lahore High Court and Supreme Court, Lahore, Pakistan.

2017 From the Profession: First Concepts, Social History, The Mental Status
Examination. Punjab Judicial Conference, District Court, Sessions Court,
Prosecutors, Lahore, Pakistan.

2016 Cultural Implications of Utilizing and Developing Neuropsychological and

Intelligence Instruments. United Nations Human Rights Commission, Zomba,

2015 Neurodevelopmental Disorders: Training for Clinicians. Zomba Mental Hospital,

Zomba, Malawi

2006-2008 Adjunct Professor, Makerere University, Department of Psychiatry, Kampala,


2006-present Human Rights Committee, International Academy of Law and Mental Health,
Montreal, Quebec, Canada

2006 Visiting Staff Psychiatrist, Butabika National Hospital, Kampala, Uganda

2004 Clinical Consultant, Kidongo Chekundu Mental Hospital, Zanzibar, Tanzania

2004 Scientific Committee, International Academy of Law and Mental Health

1998-2004 Technical Advisor, Documentation Committee, Operation Recovery, Kenya

Medical Association

1999-2003 Advisor - the Jomo Kenyatta National Hospital, PTSD Project, Nairobi, Kenya

1998-2003 Technical Advisor- Recovery Services, Ministry of Health, United Republic of


Attachment S Page 19
Clinical Lectures
2017 Criminal Law and Mental Illness: The Rising Significance of Neuroscience in the
Courts, APA Pre-Conference Training, Washington, D.C.

2017 Neuropsychiatric Aspects of Physical Disease: San Francisco Economic Round


2017 Culture, Science, and Justice: People of Color and the Mentally Ill as the Canaries
in our Toxic Mental Health and Mass Incarceration System; Dignifying Madness:
Civil Commitment, Disability Rights, and Mass Incarceration: A Symposium at UC
Berkeley School of Law

2016 United States Congressional Briefing: Gun Violence and Trauma, Washington,
DC2016: Culture, Science, and Justice: Hampton University, Hampton, Virginia

2016 Alcohol Related Neurodevelopmental Disorders: An Update on Diagnosis,

Assessment, and Treatment, International Association for the Specialized Study of
Intellectual and Developmental Disorders(IASSIDD), Melbourne, Australia

2016 Children and Adolescents with Developmental Disorders (Moderator);

International Association for the Specialized Study of Intellectual and
Developmental Disorders (IASSIDD), Melbourne, Australia.

2016 Psychiatric Conditions and Developmental Disabilities (Epilepsy, 22q11.2 deletion

syndrome, Potoki-Lupski duplication syndrome) (Moderator): International
Association for the Specialized Study of Intellectual and Developmental Disorders
(IASSIDD) Melbourne, Australia.

2016 Aging and Cognition in Prisoners with Intellectual and Developmental Disabilities
(Workshop): International Association for the Specialized Study of Intellectual and
Developmental Disorders (IASSIDD), Melbourne, Australia

2016 Justice For The Mentally Ill: The ABA Criminal Justice Mental Health Standards.
Disclosing Danger and Other Real-World Issues. The American Bar Association and
UC Hastings Constitutional Law Quarterly and Race and Poverty Law Journal

2015 Moderator, Women & Mass Incarceration: The U.S. Crisis of Women and Girls
Behind Bars. Bad Science. The University of California Law School, Irvine

2015 Neurobehavioral Assessment: Malawi Human Rights Commission

2014 Adolescents and the Elderly; More alike than you would expect. San Francisco
Police Department Crisis Intervention Training.

2014 Bipolar Disorder in Pregnancy: Meena Kumari, MD: George Woods, MD, Faculty

Attachment S Page 20
2013 High Prevalence of Brain Pathology in Violent Prisoners: A Qualitative CT and MRI
Scan Study: Journal Club, Racquel Reid, MD, George Woods, MD, Faculty

2013 Medical disorders that masquerade as psychiatric disorders. International

Academy of Law and Mental Health, Amsterdam, Netherlands

2013 Does Policy Drive Science? University of California, Berkeley, Integrative Biology
Course (MCB15)

2013 Understanding Combat-Related Post-Traumatic Stress Disorder: Andrea

Brownridge, M.D., J.D.; George Woods, M.D., Faculty Discussant

2012 The Neurobiological Effects of Trauma: District of Columbia Criminal Court,

Superior Division Third Annual Criminal Justice Conference, Mental Illness and
Treatment: Past Present and Future

2012 Neurodevelopmental Disorders: International Association for the Scientific Study

of Intellectual Disorders, Halifax, Nova Scotia

2012 Diabetes and Weight Control, Moderator: International Association for the
Scientific Study of Intellectual Disorders, Halifax, Nova Scotia

2012 Health Inequalities in Developmental Disabilities, Moderator: International

Association for the Scientific Study of Intellectual Disorders. Halifax, Nova Scotia

2012 The Neurobiology of Trauma: San Francisco YWCA Intern Training.

2011 Mood and Thought Disorders in Crisis Intervention: San Francisco County Sheriffs
Crisis Intervention Training, San Francisco, California.

2011 Fetal Alcohol Spectrum Disorders and the Criminal Justice System, National Press
Club, Washington, DC.

2011 The Epidemiology of Medicalization of Prisoners in the United States,

International Academy of Law and Mental Health, Berlin, Germany

2011 Intellectual Disability and Fetal Alcohol Spectrum Disorder: International Academy
of Law and Mental Health, Berlin, Germany

2011 Neuronal Plasticity: Cognitive Skills Retraining for students with acquired brain
injuries or learning disabilities. College of Alameda, Alameda, California

2011 The Neurobiology of Trauma In Children: Lessons About Early Childhood; Families
First, Atlanta, Georgia

Attachment S Page 21
2010 From the Plantations/Asylums to the Prisons: The Relationship between
Humiliation, Stigma, Economics and Correctional Care for the Mentally Ill;
Columbia University, Teachers College, New York

2010 Workshop on Transforming Humiliation and Violent Conflict representing the 16th
Annual Human DHS Conference and the Seventh Workshop on Humiliation and
Violent Conflict, Columbia University, Teachers College, New York

2010 Applying the Institute of Medicine Quality Chasm Framework to Improving Health
Care for Mental and Substance Use Conditions; Morehouse School of Medicine,
Department of Psychiatry, Journal Club

2010 Psychiatric Manifestations of Physical Disease. Morehouse School of Medicine,

Department of Family Practice, Atlanta, Georgia.

2009 Sleep Disorders in Psychiatric Practice: Morehouse School of Medicine,

Department of Psychiatry, Atlanta, Georgia

2008 Moderator: The Impact of Mental Health Issues on Aging, Particularly as it Relates
to Alzheimers Dementia and Parkinson Disease, National Medical Association,
Atlanta, Georgia

2008 Aging and Mental Health: What is Wellness and What is Pathology? National
Medical Association, Atlanta, Georgia

2007 The Price of Leadership and the Cost of Success: Urban Leadership Program,
Graduate School of Educational Leadership and Public Policy, California State
University, Sacramento

2007 Cognitive Assessment and Curriculum, Department of Educational Policy, Urban

Leadership Program, Graduate School of Educational Leadership and Public Policy,
California State University, Sacramento

2007 Complex disorders of trauma and torture: The neurological bases examined
through sleep disorders, Padua, Italy

2006 Clinical Aspects of Forensic Evaluation, Makerere University, Department of

Psychiatry, Kampala, Uganda

2006 Memory, Medications, and Aging, Crockett, California Womens Club

2006 Cultural Differences: Ethics or Efficacy, Mental Health, Ethics and Social Policy,
University of Montreal, Quebec, Canada

2006 An Update on Memory Function, Grand Rounds, Morehouse School of Medicine,

Atlanta, Georgia

Attachment S Page 22
2006 Moderator & Respondent (Representing Morehouse School of Medicine)
Consortium for the Poor and Underserved- Cultural Factors, DePaul University
School of Law and Health, Health Law Institute

2005 Constitutional Theory and Medical Rights, Montreal, Quebec, Canada

2005 Medical Diseases with Psychiatric Manifestations: Morrison and Foerster, LLP

2004 Diagnosis and Treatment of Malaria-Induced Altered Mental States: Kidongo

Chekundo Mental Hospital, Zanzibar, Tanzania

2003 Law, Mental Health & Popular Culture: University of San Francisco College of Law

2003 Accommodating Mental Illness in the Workplace: The 28th International

Conference, International Academy of Law and Mental Illness, Sydney, Australia

2002 Cultural and Psycho-biological Factors In the Assessment and Treatment of

Trauma: Dont Believe Everything You Think: Traumatology 1003, The Trauma
Recovery Institute, Morgantown, West Virginia

2002 Trauma, Recovery and Resiliency, University of Washington, Bothell

2001 Understanding the Relationship Between Neuroimaging, Neuropsychology, and

Behavior: National Medical Association 2001 Annual Convention and Scientific
Assembly, Nashville, Tennessee

2001 The Thrill is Gone: Keynote Address, African American History Month, Loras
College, Dubuque, Iowa

2001 Disparate Access- Healthcare: University of Washington, Bothell Campus Nursing


2000 Anger Management: West Contra Costa Stroke and Aphasia Support Group,
Doctors Hospital, San Pablo, California, 2000

2000 Race, Culture and Bioethics: American Society for Bioethics Annual Conference,
Panel Discussion, Salt Lake City, Utah

2000 Globalization and Postmodernism: International Congress on Law and Mental

Health, Siena, Italy

2000 Globalization and Neuropsychiatry: Answers that Transcend Culture? International

Congress on Law and Mental Health, Sienna, Italy

1998 Managed Care in the Kenyan Medical Environment: Kenyan Medical Environment:
Kenyan Medical Association, Aga Khan Hospital, Nairobi, Kenya

Attachment S Page 23
1994 The Relationship Between Holidays and Mood Disorders: Doctors Hospital Pinole,

1994 The Role of the Mental Health Expert as a Liaison Between Chemical Dependency
and Pain Management Programs: American Academy of Pain Management,
Vancouver, Canada

1994 Chemical Dependency: Selected Topics: Critical Care Conference, Doctors

Hospital, Pinole California

1993 Detox: The First Step to Recovery: National Medical Enterprises Management
Services Division Annual Conference, Colorado Springs, Colorado

1993 Substance Use and Substance Induced Organic Mental Disorders: National
Medical Enterprises Management Services Division Annual Conference, Colorado
Springs, Colorado
1993 Dual Diagnosis in the Inpatient Setting- Professional Seminar, Doctors Hospital,
Pinole, California

1993 Depression and Strokes: Brookside Hospital, San Pablo, California

1992 Drug Interactions in the ICU: Clinical Care Rounds, Doctors Hospital, Pinole,

1992 Overview of Sleep Disorders: Grand Rounds, Doctor Hospital, Pinole, California

1991 Benzodiazepines: Uses and Abuses: Grand Rounds, Brookside Hospital, San Pablo,

1990 Sleep Disorders in Schizophrenia: Quarterly Medical Staff Meeting, East Bay

1987 Afro-Centricity in Psychology: Grand Rounds, San Francisco General Hospital, San
Francisco, California

1982 Geriatric Psychiatry-University of Southern California

Attachment S Page 24
Clinical Professional Activities
2016 Associate Editor, Journal of Policy and Practice in Intellectual Disability

2015 International Journal of Developmental Disabilities

2015 Journal of Policy and Practice in Intellectual Disability

2014 Cureus Journal Review

2014 Arts and Social Sciences Journal Review

2013 Journal of Politics and Law Journal Review

2012 Research in Developmental Disabilities Journal Review

2010 American Association for Intellectual and Developmental Disabilities, Task Force
on Intellectual Disability and Forensic Practice

2007-2009 Neurocognitive Committee, PAARTNERS

2004-present Scientific Committee, International Academy of Law and Mental Health

1993-1996 Medical Privileges Committee, Doctors Hospital, Pinole, California

1993-1995 Physicians Advisory Committee, Alameda Contra Costa Medical Association,

Oakland, California

1993-1994 Board of Directors, Solano Park Hospital, Fairfield, California

1992-1993 Board of Directors, East Bay Hospital, Richmond, California

1992 Chief of Staff, East Bay Hospital, Richmond, California

1992 Chairman, Medical Executive Committee, East Bay Hospital, Richmond, California

1992 Allied Health Committee, Doctors Hospital, Pinole, California

1992 Pharmacy & Therapeutics Committee, Doctors Hospital, Pinole, California

1991-1996 Physicians Advisory Committee, Doctors Hospital, Pinole, California

(Chair, 1994-1995)

1991 Professional Activities Committee, Easy Bay Hospital, Richmond, California

1990 Psychiatry Committee, Chairman, East Bay Hospital, Richmond, California

Attachment S Page 25
Clinical Publications
Norton, Johnson, Woods (2016) Burnout and Compassion Fatigue: What Lawyers Need to Know.
The University of Missouri Kansas City Law Review.

Greenspan, S. & Woods, G. (2015). Social Incompetence of FASD Offenders: Risk- Awareness as a Factor in
Criminal Culpability. In E. Jonsson & S. Clarren (Eds.), Brain Damage and the Law. Edmonton, Canada.

Norton, Woods (2015) Interpersonal Violence: The Legacy of Trauma. The American Bar
Associations Ninth Annual Section of Labor and Employment Law Conference.
Greenspan, Harris, and Woods (2015) Intellectual disability is a condition, not a number:
Ethics of IQ cut-offs in psychiatry, human services and law. Ethics, Medicine, and Public Health.

Woods, Freedman ((2015) Symptom presentation and functioning in neurodevelopmental

disorders: Intellectual disability and exposure to trauma, Ethics, Medicine, and Public Health

Greenspan, Woods, and Switzky (2015) Age of Onset and the Developmental Period Criteria,
Intellectual Disability and the Death Penalty.

Greenspan, Woods, Wood (In Press) Risk-Unawareness and Legal Jeopardy: Identifying Non-
Obvious Brain-Based Impairment, Springers International Library of Ethics, Law, and the New

Woods, Freedman (2015) Intellectual Disability, Comorbid Disorders and Differential Diagnosis,
Intellectual Disability and the Death Penalty.

Greenspan, Woods (2014) Intellectual Disability as a Judgment Disorder: The Gradual Move Away
From IQ-Ceilings, Current Opinion in Psychiatry.

Freedman, Woods:(2013) Neighborhood Effects, Mental Illness and Criminal Behavior: A Review.
Journal of Politics and Law; Vol. 6, No. 3.

Woods, Freedman, Greenspan: (2012). Neurobehavioral Assessment in Forensic Practice.

International Journal of Law and Psychiatry.

Norton, Woods, (2012). Secondary trauma among judges, jurors, attorneys, and courtroom
personnel. Encyclopedia of trauma: an interdisciplinary guide. C. Figley, Sage Publications.

Greenspan, Switzky, Woods: (2012) Intelligence Involves Risk-Awareness and Intellectual

Disability Involves Risk-Unawareness: Implications of a Theory of Common Sense, Journal on
Intellectual & Developmental Disability. (Cited in Diagnostic and Statistical Manual, 5th Edition,
online version)

Woods, Greenspan, Agharkar: (2012) Ethnic and Cultural Factors in Identifying Fetal Alcohol
Spectrum Disorders: American Journal of Law and Psychiatry.

Attachment S Page 26
Bradford, Fresh, Woods: Not all patients are alike: (2007) Ethnopsychopharmacology of Bipolar
Disorder in African Americans. Psychiatric Times, February.

Abueg, Woods, Watson: Disaster Trauma; (2000) Cognitive-Behavioral Strategies in Crisis

Intervention: Second Edition, Guilford Press, New York and London; p. 73-290.

Forensic Practice
1981-present Psychiatric Consultant (Civil, Family Law, Criminal and Appellate Judicial
1993-2001 Consultant- the Victims Assistance Program, State Board of Control, State
of California, Sacramento, California

1983-2000 Medical Examiner Panel, San Francisco County, Marin County and Contra
Costa County Superior Courts

Forensic Professional Lectures

2017 Psychological Issues in Employment Law: Practising Law Institute, New York.

2016 Cutting Edge Issues in Employment Law: Practising Law Institute, San Francisco.

2016 Aging and Cognition; Paul Hastings Global

2016 Psychological Issues in Employment Law: Practising Law Institute, 2016, New York.

2015 Legal and Practical Implications of Domestic Violence in the Workplace: Its Not
Just the NFL: American Bar Association Section of Labor and Employment Law 9th
Annual Labor and Employment Law Conference, Philadelphia

2015 Cutting-Edge Employment Law Issues 2015: The California Difference. Mental
Health and the Law, Practising Law Institute, San Francisco

2015 Discussant, Mass Murder: Patterns in Manifestoes: Vienna, Austria

2014 ADA and Mental Disabilities: Inquiries, Exams and Accommodations, Practising
Law Institute, New York, New York

2014 Psychological Issues in Employment Law 2014, Practising Law Institute, New York,
New York

2010 The Trial of Hamlet, Morrison and Foerster, LLP, Law College, San Diego, California

Attachment S Page 27
2009 Treatment of Mentally Ill Offenders in the United States, Canada, and Japan;
Japanese Association of Forensic Psychiatry, Tokyo, Japan

1998-2007 In Association With The National Institute of Trial Advocacy Training, Notre Dame
University, South Bend, Indiana; Georgia State Law School, Atlanta, Georgia; New
York University Law School, New York City, University of North Carolina Law
School, Chapel Hill, North Carolina; University of Houston Law School, Houston,
Texas; University of Tennessee Law School, Knoxville, Tennessee; Atlanta,
Georgia; University of Texas Law School, Austin, Texas; Temple University School
of Law, Philadelphia, Pennsylvania

2006 Aligning Clinical Services with Correctional Treatment, Luzira Prison, Kampala,

2006 Decision Tree for Forensic Evaluations, Butabika Hospital, Kampala, Uganda

2006 Neuropsychiatry and The Courts: The University of Texas Law School, Austin Texas

2002 Demystifying Emotional Damages Claims: Paul, Hastings, Janofsky & Walker, San
Francisco, California

2000 An Introduction-Multi-Axial Assessment and DSM-IV: Second National Seminar on

Mental Illness and the Criminal Law, Miyako Hotel, San Francisco, California

2000 Psychiatric Manifestations of Mental Disorders: Second National Seminar on

Mental Illness and the Criminal Law, Miyako Hotel, San Francisco, California

1999 An Introduction-Multi-Axial Assessment and DSM-IV: First National Seminar on

Mental Illness and the Criminal Law, Radisson Hotel, Washington, D.C.

1999 Physical Manifestations of Medical Disorders: First National Seminar of Mental

Illness and the Criminal Law, Radisson Hotel, Washington, D.C.

1999 The Kenya/Tanzania Embassy Bombings: When Forensic Science, Politics, and
Cultures Collide: International Academy on Law and Mental Health, Toronto,
Quebec, Canada

1999 Research Collaboration Between East Africa and the United States: World
Psychiatric Association/Kenya Psychiatric Association, First Annual East African
Conference, Nairobi, Kenya

1999 Trauma/Resiliency In East Africa Workshop: World Psychiatric Association/Kenya

Psychiatric Association, First Annual East African Conference, Nairobi, Kenya

1998 Mental Health Litigation and the Workplace: Sponsored by the University of
California Davis Health System, Division of Forensic Psychiatry, Department of
Psychiatry, and Continuing Medical Education, Napa, California

Attachment S Page 28
1998 Psychological Disabilities: Charting A Course Under the ADA and Other Statutes:
Yosemite Labor and Employment Conference, Yosemite, California

1998 Current Trends in Psychiatry and the Law: Developing a Forensic Neuro-
Psychiatric Team: CLE, Federal Public Defenders for the District of Oregon,
Portland, Oregon

1997 The Changing Picture of Habeas Litigation: The National Habeas Training
Conference, New Orleans, Louisiana

1997 Accommodating Mental Illness in the Workplace: Employment Law Briefing,

Orange County

1997 Accommodating Mental Illness in the Workplace: Employment Law Briefing, Palo
Alto, California

1997 Accommodating Mental Illness in the Workplace: Employment Law Briefing,

Morrison & Foerster, San Francisco

1997 Psychiatric Evaluations in the Appellate Process: Emory University, Department of

Psychiatry, Forensic Fellowship, Atlanta, Georgia

1997 So You Wait Until Discovery Is Over to Consult with a Psychiatrist? Can You Tell
Me More About That? Morrison and Foerster Labor Law College, Los Angeles,

1997 The Changing Cultural Perspectives in Forensic Psychiatry, San Francisco General
Hospital Grand Rounds, San Francisco, California

1996 Evaluations of an Elementary School Child: Criminal Competency and Criminal

Responsibility, Stanford University School of Medicine, Department of Psychiatry
and Behavioral Sciences, Division of Child, Psychiatry and Child Development,
Grand Rounds, Palo Alto, California

1996 Forensic Psychiatry: Cultural Factors in Criminal Behavior, Malingering, and Expert
Testimony: The Black Psychiatrists of America Transcultural Conference, Dakar,
Senegal, West Africa

1996 Dangerousness; Evaluation of Risk Assessment: Grand Rounds, Department of

Psychiatry, University of California, Davis

1995 Violence in the Workplace: A Psychiatric Perspective of Its Causes and Remedies:
The Combined Claims Conference of Northern California, Sacramento, California
1995 Experts: New Ways To Assess Competency- Neurology and Psychopharmacology:
Santa Clara University Death Penalty College, Santa Clara, California

Attachment S Page 29
1995 Multiple Diagnostic Categories in Children Who Kill: Psychological and Neurological
Testing and Forensic Evaluation: The American College of Forensic Psychiatry 13th
Annual Symposium, San Francisco, California

1995 Mock Trial: Client Competence in a Criminal Case: Testing the Limits of Expertise,
The American College of Forensic Psychiatry 13th Annual Symposium, San
Francisco, California

1995 The Use of Psychologists In Judicial Proceedings: The California Attorneys for
Criminal Justice/California Public Defenders Association Capital Case Seminar,
Monterey, California

1994 Commonly Seen Mental Disorders in Death Row Populations: The California
Appellate Project, Training Session for Legal Fellows and Thurgood Marshall
Investigative Interns, San Francisco, California

1994 Anatomy of a Trial: Mock Trial Participant, The California State Bar Annual
Convention, Anaheim, California

1994 Developing a Forensic Neuropsychiatric Team: The American College of Forensic

Psychiatry 12th Annual Symposium in Forensic Psychiatry, Montreal, Quebec,

1994 Responsibility in Forensic Psychiatry: Department of Criminology Faculty Seminar,

University of Nebraska, Omaha

1994 Attorney/Investigator Workshop: Brain Function: The 1994 California Attorneys for
Criminal Justice/California Public Defenders Association Capital Case Seminar,
Long Beach, California

1994 Appellate and Habeas Attorney/Investigator Workshop: Evaluating Mental Health

Issues in Post-Conviction Litigation: The 1994 California Attorneys for Criminal
Justice/California Public Defenders Association Capital Case Defense Seminar, Long
Beach, California

1993 Psychological Issues in Police Misconduct: Police Misconduct Litigation, National

Lawyers Guild, San Francisco

1993 Neuropsychiatry, Neuropsychology and Criminal Law: Maricopa County Office of

the Public Defender, Seminar on Investigation for Mitigation and Capital Cases,
Phoenix, Arizona

1993 Working with Experts: California Appellate Project, San Francisco, California

1991 Forensic Psychiatry and Ethnicity-Black District Attorneys Association, National


Attachment S Page 30
Professional Forensic Publications
Greenspan, Woods (2016) Chapter 7 Personal and Situational Contributors to Fraud
Victimization: Implications of a Four-Factor Model of Gullible Investing. Financial Crimes:
Psychological, Technological, and Ethical Issues. Dion, Weisstub, Richet. Springer Publishing.

Wood, Hanoch, Woods (2016) Chapter 6 Cognitive Factors to Financial Crime Victimization.
Financial Crimes: Psychological, Technological, and Ethical Issues. Dion, Weisstub, Richet.
Springer Publishing.

Woods, (2016) Cognition and Aging: Impact in the Workplace: Paul Hastings Global.

Woods, (2016) Treat or Assess: Which Hat Should Your Expert Wear? Practising Law Institute.

Bigler, Jantz, Freedman, Woods, (2016) Structural Neuroimaging in Forensic Settings,

University of Missouri-Kansas City Law Review, Volume 82, No. 2. Psychiatry and Criminal Law,
Contra Costa Lawyer, Volume II, No. 8, August 1998.

Mock Trial: Client Competence in a Criminal Case: Testing the Limits of Expertise, The
Psychiatrists Opinion as Scientific, The Experts Foundation as Sufficient, 1995 (Available from
The American College of Forensic Psychiatry and on Audiotape).

Multiple Diagnostic Categories in Children Who Kill: Psychological and Neurological Testing and
Forensic Evaluation, 1995. (Available from the American College of Forensic Psychiatry and on

Developing a Forensic Neuropsychiatric Team,1994. (Available from the American College of

Forensic Psychiatry on Audiotape).

Anatomy of a Trial: 1994 (Available for the California State Bar).

Forensic Professional Affiliations

2013 American Academy of Psychiatry and the Law

1998 International Academy of Law and Mental Health

Attachment S Page 31
Professional Development & Corporate Services

2016 BetterManager, Expert Contributor

2016 Map1080, Big Timber, Montana, Advisory Board

2015 Grade LLC Evansville, Indiana Unified School District: Education/Neuroscience


2015 The Science Advisors, Founding Partner

2015 Defend Your Head Corporation: Medical and Neuroscience Advisor

2014 Forefront Behavioral Telecare, LLC: Assistant Chief Medical Officer

2013 Generations in Transition: YearUp, Atlanta, Georgia

2011 Forefront Behavioral Telecare, LLC: Director of Clinical Research

2009-2010 Forefront Behavioral Telecare, LLC: Chief Medical Officer

2009 AgeServe Communications, LLC: Director of Research/Director of Government


2004 Consultant, Corporate Structure, Tostan, Non Governmental Organization, Theis,


2004 Toward Effective Retention Efforts: The use of narratives in understanding the
experiences of racially diverse college students., Narrative Matters, Fredericton,
New Brunswick, Canada

2003 In Association with the Council on Education in Management, Charlotte, North

Carolina, Accommodating Psychiatric Disabilities: Avoiding the Legal Pitfalls of the
ADA, Human Resources Conference, Palm Springs, California

2001-2003 Consultant, Vulcan Inc., Seattle, Washington

1999 In Association with Matthew Bender Legal Publishing, New York: Psychiatric
Disabilities and California Workplace Requirement, With the Bar Association of
San Francisco, San Francisco

1998 Psychiatric Disabilities under the Americans With Disabilities Act: Without Pretrial
Strategy, Atlanta, Georgia

1998 Psychiatric Disabilities under the Americans With Disabilities Act: Without Pretrial
Strategy, Los Angeles, California

Attachment S Page 32
Johnson Freedman Woods Education, LLC

2017 Criminal Law and Mental Illness: The Rising Role of Neuroscience in the Courts:
The American Psychological Association, Washington, DC.

2012 - present An Evolution in Practice at the Intersection of Mental Health and the Law: Where
Mental Health Meets the Law by Jennifer Johnson, J.D., David Freedman, Ph.D.,
and George Woods, M.D. of Johnson Freedman Woods Education: a
comprehensive curriculum on the evolving field of forensic mental health.
Thomson Reuters West Legal EdCenter

The Critical Moments Consulting Group

2001 Part I- Responding Creatively to Cultural Diversity through Case Stories and Part II-
Strategies and Challenges for Campus-wide Diversity Project: Models of
Integrating Critical Moments, Fourteenth, Annual Conference on Race and
Ethnicity in American Higher Education, Seattle Washington

2001 Teaching Complex Case Stories, Faculty Development, Loras College, Dubuque,

2000 Critical Moments: Creating a Diversity Leadership Learning Community, 13th

Annual National Conference on Race and Ethnicity in American Higher Education
(sponsored by the University of Oklahoma, Southwestern Center for Human
Relations Studies), Santa Fe, New Mexico

2000 Critical Moments: Practicum on Teaching Diversity Through Case Stories, 13th
Annual National Conference on Race and Ethnicity in American Higher Education
(sponsored by the University of Oklahoma, Southwestern Center for Human
Relations Studies), Santa Fe, New Mexico

2000 Improving Undergraduate Education: Teaching and Learning in the Context of

Cultural Differences, The Washington Center for Improving the Quality of
Undergraduate Education, Thirteenth Annual Conference, Seattle, Washington

1999 Critical Moments: Deepening Our Understanding of Cultural Diversity through

Critical Analysis, Effective Interviewing, Case Writing, and Case Teaching, The
Washington Center, Evergreen State College, Olympia, Washington

1999 Teaching Complex Issues with Case Studies: A Workshop for Faculty and Graduate
Teaching Assistants, University of Nebraska at Lincoln, Teaching and Learning
Center and Critical Moments Project

1999 Critical Moments: Writing the Stories of Diverse Students, Washington Center for
Improving the Quality of Undergraduate Education Workshop for College and
University Faculty, Administrators, Staff and Students, Evergreen State College

Attachment S Page 33
1999 Critical Moments: A Case Study Approach for Easing the Cultural Isolation for
Under-represented College Students, Presented at Transforming Campuses
Through Learning Communities, National Learning Communities Conference,
Seattle, Washington

1993 Contextualism and Multi-Cultural Psychology-Graduate Seminar, University of

Nebraska, Omaha, Nebraska

1992 Curriculum and Developmental Stages-North Central Educational Research Lab,

Northwestern University

Critical Moments Publications

Diane Gillespie, Ph.D., Gillies Malnarich, and George Woods, M.D. (2006). Critical Moments:
Using College Students Border Narratives as Sites for Cultural Dialogue, In M.B. Lee (Ed.),
Ethnicity Matters: Rethinking How Black, Hispanic and Indian Students Prepare for and Succeed
in College. (pp. 99-116). New York: Peter Land Publishing Group.

Diane Gillespie, Ph.D. and George Woods, Jr., M.D. (2000). Critical Moments: Responding
Creatively Cultural Diversity Through Case Stories; Third Edition.

(Updated August 8, 2017)

Attachment S Page 34
Attachment B

Attachment S Page 35

I, GEORGE W. WOODS, M.D., declare as follows:

1. Qualifications and Background

1. I am a psychiatrist in private practice based in Oakland, California. I received my

Bachelor's degree in 1969 from Westminster College in Salt Lake City, Utah. I received my

medical degree from the University of Utah Medical Center in 1977. I completed a medical

internship at Alameda County Medical Center, Oakland, California; then completed my residency

at the Pacific Medical Center in San Francisco, California in 1981, where I was Chief Resident my

senior year. I then participated in a National Institute of Mental Health/American Psychiatric

Association (NIMH/APA) Fellowship in 1982. I received my board certification in psychiatry in


2. In addition to my clinical and forensic practice, I teach Clinical Aspects of Forensic

Psychiatry to third and fOUith year residents at Morehouse School of Medicine, Department of

Psychiatry. I am also a member of the faculty of the Department of Educational Leadership and

Public Policy, California State University, Sacramento. I was previously on the faculty of the

University of Washington, Bothell campus, where I taught a course on Mental Illness and the

Law. From 1996 through 2000, I taught in the postgraduate Forensic Psychiatry Fellowship at the

Depaltment of Psychiatry at the University of California, Davis, Medical Center.

3. I am Secretary General of the International Academy of Law and Mcntal Health. I

am a Fellow of the Amcrican Psychiatric Association. I am also a member of the California

Psychiatric Association and the Northern California Psychiatric Association. I am a mcmbcr of the

American Neuropsychiatric Association, and the American Psychological Association. I am a past

membcr of the American Academy of Psychiatry and the Law. I am on the Scicntific and

Attachment S Page 36
Executive Committees of the International Academy of Law and Mental Health. I am a past

member ofthe Advisory Board of The Health Law Institute of the College of Law, DePaul

University. Currently, I am on the Advisory Board of the Center for African Peace and Conflict

Resolution, California State University, Sacramento, and the Global Advisory Board for

Humiliation and Dignity Studies, Trondheim University, Norway, and Columbia University, New


4. I have been retained by the Arkansas Federal Defender Office to conduct a

psychiatric evaluation of capitally-sentenced inmate Jack Gordon Greene and to assess whether he

is mentally competent to participate in federal habeas corpus proceedings. Mr. Greene's attorneys

have requested that I write this preliminary declaration explaining, first, why I suspect that Mr.

Greene may be severely mentally ill and incompetent, and second, why it is impOltant that I have

the opportunity to conduct clinical interviews of Mr. Greene.

5. As is standard practice, in preparation for an evaluation ofMr. Greene, I have

reviewed psychological, medical, educational, social and family history materials. Background

documentation for Mr. Greene's childhood includes life history records from Mr. Greene and

multiple family members as well as interviews with siblings of Mr. Greene. Such materials are

essential to developing reliable opinions about a person's psychiatric condition. At this time, the

materials that have been provided to me in this case arc notably incomplete. It is apparent that

additional mental health and social services records regarding Mr. Greene and his family exist.

Counsel for Mr. Greene was not able to provide me the additional records because a release from

Mr. Greene or a court order is needed to collect them.

Attachment S Page 37
II. Relevant Social History

A. Jack's Childhood.

6. Jack Gordon Greene was born on March 13, 1955 in Lenoir, NOlih Carolina and

was the youngest of thirteen children born to his father, Turner Greene, Sr. Turner had six

children, Jack's half brothers and sisters, with his first wife, Florence Greene. Jack and his six full

brothers and sisters were born to Turner's second wife, Jack's mother, Ola. At the time ofMr.

Greene's bilih his father, Turner, was between 55 and 57 years old.

7. Jack's father, Turner, was an alcoholic whose addition to alcohol was quite severe.

Turner drank constantly and maintained a state of drunkenness for weeks and sometimes months at

a time. He reportedly experienced frequent severe headaches. Turner was also violent, beating his

wife and children and sexually abusing his daughters. According to one of Jack's sisters, Turner

would take her panties off and slide her body up and down the shaft of his penis. The reporting

sister would have been nine years old at the time of their father's death.

8. Jack was born into family that was not only scarred by abuse and alcoholism but

also suffering in extreme poverty. When Jack was an infant, his large family lived in a tiny three-

room house without power, running water, or indoor plumbing. The family drew their bathing and

drinking water out of the spring, washed clothes in the creek and used an outhouse. They did not

have an automobile and lived in rural area of North Carolina, miles away from everything and


9. Jack's father, Turner, committed suicide on September 6, 1956. On that day, Jack,

then eighteen months old, was sleeping in the family's three-room home. Turner was intoxicated

and had been intoxicated for days. He was demanding his shotgun, but his wife, Jack's mother,

Ola, had hidden the gun in a lumber pile in the yard because she was worried that Turner would

Attachment S Page 38
hurt someone. After Ola went down to the creek to wash Jack's diapers, Turner found the gun in

the lumber pile. He then went into the house where Jack was sleeping. Turner's death celiificate

shows that he was killed by a self-inflicted gunshot wound to the chest. When Ola discovered

what had happened to Turner she let out a horrible scream that at least one of Jack's sisters still

vividly remembers to this day and describes as scarring her for life. The sister states that Jack was

there when all of this happened and wonders how being exposed to that trauma would have

affected a small child.

10. The same sister reports that their mother, Ola, seemed to draw closer to Jack after

their father committed suicide and seemed to take solace in snuggling with her baby, Jack. Mr.

Greene's sisters consistently describe him as a sweet, humble little boy.

II. After Turner committed suicide, Jack's large family became even more destitute.

They were forced to move in with Ola's parents, Jack's maternal grandparents, Charlie Coles

Taylor and Gladys Dula Taylor. Jack's grandfather, Coles, is described by multiple sources as

extremely abusive. It was not possible to know what might set him off and he would demand the

siblings remove shirts or pants so that he could lash their bare skins. Coles is said to have beat the

children with belt or a stick to the point of causing free flowing blood, to the point of "blood

everywhere." He is even reported to have thrown salt in the wounds. One of Jack's siblings

described Coles waiting until he was asleep and then snatching him out of bed to whip him with a

handful of switches.

12. More than one sibling was puzzled by the fact that Coles appeared to have

particular antipathy for Jack, the youngest of his grandchildren. Coles would wrongly blame Jack

if anything turned up missing, like a hoc or a rake, even though Jack was just a small boy and

would have little use for such things. He was observed to have "a grudge" against Jack.

Attachment S Page 39
According to Jack's sister, Coles would beat him at least once a week or more, and little Jack

would crawl under the bed to hide and weep. Jack's siblings had no idea why Coles appeared to

target him. Jack's mother did not challenge Coles's abuse of her children; Jack's siblings suggest

that this was because she was fearful that her father would evict them all and she had nowhere to


13. The children describe their mother as working hard to provide for them and state

with pride that they did not go hungry. Their mother raised a large garden and canned. They

regularly received "welfare food" from the county. The grandparents raised hogs and, as one

brother states, "we used everything out of everything, used everything but the squeal from the

hog." Ola made blankets by sewing together old feed bags. There was no money for children's

toys, but Ola would try to make due with such tricks as bunching up a towel and tying a string

around it for a makeshift doll for her girls.

14. Despite her efforts, Ola was far from an ideal caretaker and (as discussed further

below) suffered from serious mental illness. She remained dependent upon her abusive father

throughout her childrearing years and remained unable to protect her children from the abuses of

her father. The family remained poverty stricken and dependent upon government aid for food

and the kindness of neighbors and local ministries for clothing for the children.

15. Ola and the children initially lived with the grandparents in their modest house. In

an effort to escape the abuse meted out by her father, Ola ultimately movcd her children out from

under his roof. A couple hundred fect from the grandfather's house was thc chicken coop, where

the grandfather had kept his chickens. Ola and her children moved into the chicken coop and lived

there for several years. The chicken coop had no electricity, no running water, and no indoor

plumbing. It was one big space with a dirt floor, and according to one sibling, even lacked a

Attachment S Page 40
proper door. Ola would partition off the space for the boys to have a separate sleeping space from

the girls. The chicken coop did not even serve to protect the children from the elements, and one

of Jack's siblings remembers waking up covered in snow that had sifted through the cracks in the

walls. The chicken coop also did not serve to protect the children from their grandfather, who

lived a matter of feet away and continued his abusive practices with all of them.

16. The Greene children did not have such basic necessities as a toothbrush and

toothpaste. One of Jack's sisters recalls that staff at her elementary school gave her a toothbrush

and toothpaste, and she had no idea what to do with it. The children describe hauling water up the

hill from the spring, water that their mother would heat on the fire for baths or for cooking. They

would all share the bath water in a tub that was kept outside in the summers, inside in the winters.

17. Ola's children attended primary school, but it was not something that she

emphasized as important. No one ever helped Jack or his siblings with the homework or even

encouraged them to complete it. All of the children found school difficult both academically and

socially. The sisters describe being taunted by the other children for their poverty. Jack's brother

Danny was pushed through school, despite the fact that he could never learn to read or write. Jack

was reportedly unable to make any friends growing up.

18. Jack's siblings each describe a particular event in his life as being "Jack's

downfall." When he was II years old, Jack was committed to Stonewall Jackson Juvenile

Training School after his grandfather, Coles, accused him (wrongly, according to Jack's siblings)

of stealing Coles's gasoline. Over the course of more than four years, members of the training

school staff raped him. Jack physically fought to prevent the abuse but often was not successful.

The adults ostensibly charged with his care repeatedly forced him to have anal sex. Jack was also

exposed to alcohol, marijuana, and LSD during his years at the state's training school, and began

Attachment S Page 41
using those substances while there at age II. The information that has been provided to me covers

these matters only in the broadest outline, and it is critical that I have the opportunity to discuss

them with Mr. Greene so that he can fill in the details.

19. Jack and a companion, Michael Murray decided to flee from the abusive training

school in early October 1970. The boys took a 1966 Chevrolet and escaped the institution as the

police chased them out of town and over a major federal highway. The vehicle flipped while

being chased by Highway Patrol. Jack was 15 years old, and his companion was 14. Both Jack

and Michael were gravely injured and were rushed to the hospital. Michael died ten minutes after

he arrived. Jack sustained a head injury, fractured ribs, and a punctured lung. Jack's mother went

to visit him and returned, distraught, carrying his clothes, which were soaked with blood. I have

been unable to review the medical records from this incident because Mr. Greene has not signed a

proper release, and the hospital will not otherwise disclose them without a court order.

20. A family member describes Jack's reaction to what happened. Jack was absolutely

distraught and overcome with guilt. He blamed himself for Michael's death. He was described as

highly emotional, crying and wailing and saying that he would give anything in the world to have

those moments back and to bring Michael back. Once Jack was released from the hospital, he was

sent right back into the abusive environment that he had just traumatically escaped from.

21. Jack's relatives say that he was never the same after his experiences in the training

school. The changes appeared to be both acute and chronic in nature. For years after the accident

intrusive memories would keep Jack up late at night and he would visit relatives crying and

needing comfort. Family members describe a young man who became more withdrawn and quiet.

Prior to going to the training school, Mr. Greene had enjoyed a close relationship with his mother

and as a young boy loved to be held and rocked. Aftcr training school, he seemed uncomfortable

Attachment S Page 42
with physical touch - "couldn't stand to be touched." Early on after his release, his sister observed

that he always seemed scared and anxious even when there was nothing to be worried about. This

appeared to worsen over the years and she observed over time that he seemed edgy and suspicious

and could never sit still. He would constantly pace the floor and peer out the windows as if

someone were looking for him or out to get him, even though no one really was. She describes

him as "a nervous wreck for no apparent reason." More than one sibling states that Jack seemed

like a completely different person. Jack reportedly began to get "fixed ideas" that "no one would

be able to budge" even if they "did not make sense."

22. Following his commitment to the training school, Jack did very poorly

academically. With the exception of one term of History, when he scored a C, Jack failed or scored

a D in every academic subject. Jack's overall "failure in subjects" was noted beginning in his

seventh-grade year and continued through the two years that he tried but failed to complete the

eighth grade. A standardized test administered to Jack by his school at the age of 15 was

indicative of serious cognitive deficits. The test notes an I.Q. equivalency of78, though the

instrument used is not an I.Q. test, nor is it an appropriate instrument for a final diagnosis of

Intellectual Disability.

23. Jack's tcachers also rated him poorly on subjective assessments of personal

strengths and weaknesses. They consistently judged him as "low" or "below average" in such

areas as "Cooperation," "Courtesy," "Dependability," "Industriousness," "Initiative," "Leadership,"

"Maturity," and "Self-Control." Jack dropped out of school after he failed the eighth grade for the

second time.

Attachment S Page 43
24. The limited neuropsychological testing of Jack that has been conducted to date

indicates brain damage and significant impairments in the frontal lobes. He has never been

administered a valid I.Q. test, such as a Wechsler Adult Intelligence Scale 01' a Stanford-Binet.

B. Mr. Greene's Adulthood.

25. Mr. Greene tried to work beginning in 1971 but was never able to hold down a

steady job. Social Security record for Mr. Greene indicate that he worked for fourteen different

employers between 1971 and 1987, including several furniture factories and a chicken plant. He

rarely worked anyone job for more than several months at a time, rarely earned more than a

couple thousand dollars in a given year, and typically earned much less than that. For many years

he had no income at all.

26. During this period, Mr. Greene abused alcohol and a number of other substances.

He acknowledged a substance abuse problem and participated in Alcoholics Anonymous in an

unsuccessful effort to control it. Mr. Greene's sister, Mary Ellen, recalls that he had a self-help

book titled "Why Do I Do What I Don't Want to Do?" and that his efforts to combat his addiction

were SIncere.

27. Hospital records show a series of visits that indicate Mr. Greene experiencing

varying levels of psychological distress or disturbance. On June 3, 1982, Mr. Greene, then 27

years old, was admitted to a North Carolina hospital emergency room under strange

circumstances. Mr. Greene had taken his pocket knife and cut a 5-inch gash into the back of his

leg. The wound resulted in significant bleeding, and Mr. Greene was rushed to the ER, where he

lost consciousness due to loss of blood and "fright." At the hospital, Mr. Greene told the doctors

that he had eut himself because he had been bitten by a snake. The doctors found no swelling,

fang marks, or other symptoms that would indicate a snake bite, and did not believe that Mr.

Attachment S Page 44
Greene had, in fact, been bitten. ER staff noted that Mr. Greene was suffering anxiety and had

been having some difficulty sleeping.

28. On September 8, 1982, Mr. Greene was again admitted to the ER for cutting

himself, this time for slitting his wrists. Mr. Greene had made three 3-inch cuts in both of his

wrists. The cuts required stitches.

29. The following year, Mr. Greene's mother committed suicide. Not long thereafter,

Mr. Greene was seen in the ER a third time for self-inflicted wounds. On January 9, 1984, Mr.

Greene shot himself in the foot with a l2-gauge rifle. Although his wound was serious, Mr.

Greene irrationally refused to sign any papers, refused IV fluids, and "refused all therapeutic

attempts" generally. He was transported by ambulance (apparently involuntarily) to North

Carolina Baptist Hospital, where he received some form of inpatient treatment for fifteen days.

Records of Mr. Greene's relatives reveal that N.C.B.H. provided inpatient psychiatric care during

the early I980s; however, that hospital will not disclose its records on Mr. Greene without a

specific release from him or a court order.

30. Approximately six weeks later, on February 27, 1984, Mr. Greene was seen in the

ER after apparently being involved in an automobile accident and suffering a head injury.

Although Mr. Greene, who was intoxicated, had walked himself to the hospital, he emphatically

refused treatment of any sort. He repeatedly refused a cervical collar, refused to sign anything,

refused to stay on the stretcher, refused to allow his forehead to be stitched up, and left the

hospital. Mr. Greene returned to the ER a second timc several hours later and consented to the

stitching and to a skull x-ray, which did not indicate a fracture. After he was released for the

night, Mr. Greene returned to the ER for the third time on the following afternoon complaining of

a headache. Although he had been taking Tylenol with codeine for his injuries, a compound


Attachment S Page 45
analgesic that is used to treat moderate to severe pain, Mr. Greene was getting no relief for his


31. Four days later, on March 3, 1984, Mr. Greene was seen again in the ER. On this

occasion, Mr. Greene complained that the gunshot wound on his foot had become infected. Upon

examination, however, Mr. Greene's foot was found to be healing normally. The doctor declared

that there was "no infection present to inspection" and discharged Mr. Greene without taking

further action.

32. The following year Mr. Greene again presented at a local emergency room in

considered distress. He complained of anxiety, depression, insomnia, weight loss, and disturbing

homicidal thoughts. In light of Mr. Greene's self-reports, a physician at a local hospital declared

that Mr. Greene was mentally ill and a danger to himself and others. He was judicially committed

to a state psychiatric hospital for further evaluation. The clinicians there noted that Mr. Greene

was suffering anxiety and depression and that he was unable to effectively cope with his stress and

anxiety. Mr. Greene expressed a fear that he was "cracking up." The clinicians were impressed

that Mr. Greene was "very sincere" in wanting help for his psychiatric and substance abuse

problems. Mr. Greene was given indefinite diagnoses of mixed substance abuse, mixed

adjustment disorder, and mixed personality disorder, and he was released without substantial


33. Six years later, in 1991, Mr. Greene was arrested on charges of murder. I-Ie was

convicted and sentenced to death by an Arkansas state court on October 15, 1992. Mr. Greene has

spent the intervening years incarcerated on Arkansas's death row. Mr. Greene has spent many of

these years in solitary confinement and without visitation from friends or family.


Attachment S Page 46
C. Family History of Mental Illness and Suicide

34. Mr. Greene has an extensive family history of mental illness, substance abuse,

suicide, and cognitive deficits. Mr. Greene's father committed suicide when Jack Greene was but

eighteen months old and the father was fifty seven years old. Other than what has been previously

discussed, little else is know about Turner Greene, Sr., at this time. Mr. Greene's mother

committed suicide when Mr. Greene was twenty-eight years old and his mother was sixty-three

years old. More is known about Mr. Greene's mother's history than his father's history and shows

a documented history of serious mental illness that goes back to age 23.

35. In 1943, at the age of23, Mr. Greene's mother Ola was the subject of an

"Inquisition of Lunacy" held in Wilkes County Superior Court. A physician made an affidavit

under oath that he had carefully examined Ola and that he believed her to be an "insane person"

and "a fit subject for admission into a hospital for the insane." The Inquisition was tried to a state

judge, who took testimony from two physicians and from Ola's father. The judge found that Ola

was indeed a "lunatic" and that she should be involuntarily committed to the state psychiatric


36. After she was released from the psychiatric hospital, Ola continued to have mental

health problems. She went on to marry Turner Greene and to have seven children. After her

husband's suicide, Ola was left with seven children, ages 18 months to II years old. Her children

state that they believe their mother had mental problems throughout their childhoods. They can

rarely remember ever seeing her smile. When getting up late at night, her daughter remembers

seeing her mother sitting in a chair simply staring at the fIre. For no apparent reason, Ola would at

times grab her head and hair and scream. Ola was quiet and isolative. One of her daughters noted


Attachment S Page 47
that she rarely would initiate any sort of conversation and would often retreat if other people came


37. As her children became adults, they became more aware of their mothers

difficulties. She would often show up at the home of a family member and demand to be rushed to

the hospital. The doctors were unable to find anything physically wrong with her and would

prescribe "nerve pills" or a placebo for her anxiety. At some point, ala began taking psychotropic

drugs on a daily basis.

38. Her children describe ala as continuing to have "bad nerves" and "mental

problems" as she aged. She remained socially withdrawn and would rarely talk or smile; she

would often isolate to her bedroom, particularly when there was company. ala had become

religiously preoccupied. She became fixated on the idea that she would die and go to hell. She

would say that she was going to hell over and over to the extent that she was unable to do anything

else. When asked what she had done to deserve going to hell, ala would say, "Because I took my

medicine wrong, I have sinned." ala was obsessed with taking her medications just so and "went

crazy" ifshe "remotely thought she took something wrong." When asked why taking just the right

pill at just the right time was so important, ala would say that "the Lord will not forgive me"


39. Multiple sources attest that ala firmly believed that her father was being visited by

"demon spirits." She thought that there were "demon spirits all around Coles." She became

preoccupied with the idea that her father was reading "devil worshipper" books and following a

"preacher worshipping something other than the Lord." Her daughters describe ala as

experiencing a high degree of psychological and physical agitation and that she would get fixed

ideas that she would believe as true no matter what. Reportedly, ala was hospitalized a second


Attachment S Page 48
time at some point later in life for her "nerve problems." Counsel for Mr. Greene informs me that

he is unable to obtain these inpatient records without a court order.

40. Due to her destitute circumstances, Ola ended up living with her father after her

children were grown. For unknown reasons, on July 7, 1983, Ola attacked her father, 84, with a

hammer, beating him in the face and almost killing him. At the same time, Ola ingested a large

quantity of prescription pills. A neighbor found Mr. Greene's grandfather, Mr. Taylor, in his

trailer home bloodied, gravely injured, and crying for help. Ola was likewise inside the trailer and

was discovered standing with the hammer still in her hands. Mr. Taylor was taken to the hospital

and treated for cuts and a broken jaw. Ola, however, died from the overdose of pills she had

taken. At the time of her suicide, Ola had a prescription for Ativan, a drug used in the treatment of

anxiety disorder.

41. Mr. Greene's full brothers and sisters also have clinically significant histories. Two

of Mr. Greene's full siblings have had mental health problems significant enough to be judicially

committed to the state psychiatric hospital, like Mr. Greene and his mother. Mr. Greene's brother,

Turner Greene, Jr., was involuntarily committed at the age of 18. Turner's mother, Ola, brought

him before the court, which had Turner examined by three doctors. All three diagnosed Turner as

a mentally disordered person needing commitment to the psychiatric hospital.

42. Mr. Greene's sister, Mary Ellen Blankenship, was judicially committed for mental

illness in 1984; the details of the commitment are unavailable because the Caldwell County

Superior Court requires a court order for the release of Ms. Blankenship's file. Ms. Blankenship's

medical records do reveal a lengthy history of severe Panic Disorder and Major Depressive

Disorder dating back to at least the 1970s. Ms. Blankenship's mental illness has required inpatient

psychiatric hospital care on multiple occasions.


Attachment S Page 49
43. Ms. Blankenship also has a history of agitation and psychosis. Intermittently

between 1971 and the mid 1980s, she was treated with multiple antipsychotics, including

Haloperidol, Perphenazine, and Thioridazine. After her mother died, Ms. Blankenship reports she

would be harassed by a "suicide spirit" and that "[s]omething would say to [her], 'Go and get a

knife.'" She has sometimes attributed her problems to "a trick of the devil." For decades, Ms.

Blankenship has repeatedly visited the emergency room under the belief that she is having a heart

attack, but doctors have not been able to find anything physically wrong with her. Mr. Greene's

counsel informs me that he cannot get disclosure of Ms. Blankenship's inpatient psychiatric

records without a court order.

44. While I have no indication yet that they have been judicially committed, Mr.

Greene's other siblings are also chronically mentally ill. His sister, Georgia Howell, has struggled

with Panic Disorder and Major Depressive Disorder since before her mother's death in 1983. She

has been repeatedly prescribed powerful antianxiety and antidepressive medications. Mr. Greene's

brother, Danny, likewise has a longstanding and consistent history of Major Depressive Disorder

and Anxiety Disorder dating back approximately thirty years and has been prescribed antianxiety

and antidepressive medications. Danny also reportedly gets fixed ideas, and when he does there is

"no changing him," even with "proof" to the contrary. In particular, Danny has long been

obsessed with the idea that his older brother, Tommy, was responsible for his mother's death, and

he impressed Mr. Greene, his younger brother, with this notion.

45. Mr. Greene's brother, Hulette Greene, also has a long history of psychological

problems, with his dating back to at least 1961. Hulette was treated for Seizure Disorder with

Grand Mal, Major Depressive Disorder, and Anxiety Disorder with panic attack for many years

before his death in 2007. Even when he was a child, Hulette would engage in bizarre behavior,


Attachment S Page 50
described by his siblings as "hollering and screaming and beating on the walls" in the middle of

the night that terrified his family. Siblings also describe that Hulette as a child experienced

periods of anergy and isolation to the point that he would refuse to get out of bed for days on end.

46. Hulette is described by those who knew him well as a chronically depressed "basket

case" who "couldn't or wouldn't face reality." Hulette was known to isolate as an adult, refusing to

come out of his house or to open his door to visiting family members. By 1991, Hulette's

difficulties were so well established that he was diagnosed with "chronic stress reaction." There

are indications in his medical records that Hulette may have had psychosis. On one visit that

Hulette made to the emergency room, Hulette reported symptoms consistent with a panic attack

but simultaneously reported experiencing hallucinations.

47. A number of Mr. Greene's half siblings also have clinically significant histories.

Only limited medical history information is available for most ofMr. Greene's half siblings, and

counsel for Mr. Greene informs me that their records cannot be secured without a court order.

What limited history I do have regarding Mr. Greene's half brothers, Bobby Greene and David

Greene, is revealing. Like Mr. Greene's mother and father, his brother, Bobby, committed suicide.

In 1986, Bobby shot himself in the neck with a 20-gauge shotgun, and he died from his wounds.

Bobby is described by siblings as a "heavy drinker" and had said that he would "go the same way

my daddy went." He also experienced frequent severe headaches. Bobby had apparently been

suicidal for many ycars before he killed himsclf. Grccne family lorc holds that numerous Greenes

going back furthcr than Turner Sr. also committed suicide.

48. Mr. Greene's half-brother David has a history of Anxiety Disorder dating back to at

least 1998 and probably earlier, and he has been treated with a number of antianxiety medications

over the ycars.


Attachment S Page 51
49. Mr. Greene's children also have serious mental illness. As with Mr. Greene's half

siblings, I have limited (albeit psychologically significant) information about Mr. Greene's

children. Most notable is Mr. Greene's son, Timothy Greene, who has struggled with mental

illness since at least 1993. Timothy has received mental health treatment for panic attacks,

insomnia, anxiety, and depression, and he has been diagnosed with Bipolar Disorder. Mr.

Greene's only other son, Brandon Eller, has a long history of substance abuse problems as well as

a documented history of suicidal ideation and at least one suicide attempt. On that occasion, Mr.

Eller ingested 30 unidentified pills, for which he was hospitalized for three days. Mr. Eller's sister,

Mr. Greene's daughter, Jessica Darling, has a history of substance abuse problems, for which she

has received counseling.

D. Family History of Cognitive Impairments

50. Mr. Greene's family has a significant history of cognitive impairment. Mr. Greene's

father, Turner, was unable to read or write. His brother Hulette was likewise illiterate, as is his

brother Danny. His sister, Mary Ellen, only learned to read in her teens and still does so only with


51. The academic histories of at least four of Mr. Greene's full siblings reveal evidence

of intellectual disability. Mr. Greene's brother, Turner, Jr., scored a 79 I.Q. equivalency on a

standardized test, which indicates a significant cognitive impairment. Turner Jr. failed the 3rd,

4th, and 8th grades and then dropped out of school after he failed the 9th grade. Teachers noted

that he was irritable most of the time, often very restless, and usually did not get along well with


52. Mr. Greene's brother, Hulette, scored a 65 I.Q. equivalence, indicating that he was

likely suffering from an intellectual disability. Hulette had poor grades, failed the Ist and 6th


Attachment S Page 52
grades, and left school after the 8th grade. At age 16, his teacher noted her perception that Hulette

needed psychological testing and "help from a social worker." She noted that he "tried to behave

but was often restless."

53. Mr. Greene's sister, Mary Ellen, scored an l.Q. equivalence of81 on a test of

mental ability, placing her in the lower level of intellectual functioning. She had to repeat the 1st

grade and left school following after the 8th grade. A teacher wrote that, at the age of fifteen,

Mary Ellen was only reading at a primary (or third-grade) level and that she was unable to follow

oral instructions unless they were repeated to her. In one of her adult medical records, Mary Ellen

is noted as "slow" and as someone who needs special assistance with reading.

54. Mr. Greene's brother, Danny, took multiple standardized tests, resulting in the

following l.Q. scores: 78,76,67, and 64, with the lower scores coming later in Danny's school

career. These scores indicate that Danny was likely suffering from an intellectual disability.

Danny's grades were always very low, and he failed 1st, 5th, 6th, and 7th grades before being

placed in "Special Projects," where he received no formal grades.

55. The materials that 1 have been provided contain no academic, medical, or

psychiatric records for Mr. Greene's sister, Joyce Osborne, and counsel for Mr. Greene informs me

that he is unable to obtain them without a court order. Ms. Oshorne is described by her siblings

has having "nerve" troubles. She is said to have had "fits" like her brother Hulette during her

childhood in which she would "fall out and hit the ground, passed out." Ms. Osborne does not

work, never learned to drive, receives disability payments, and lives with one of her daughters.


Attachment S Page 53
III. Contemporary Observations and Evidence

56. Contemporary observations of Mr. Greene and the evidence provided by his own

writings suggest that he may be psychotic. Numerous and diverse witness accounts consistently

describe Mr. Greene as experiencing persistent paranoid and somatic delusions.

57. First, Dr. Dale Watson, a highly qualified clinical and forensic psychologist with a

specialty in neuropsychological assessment, observed Mr. Greene's symptoms during his aborted

neuropsychological evaluation ofMr. Greene. Dr. Watson, who visited with Mr. Greene in May

2009, describes witnessing Mr. Greene engaging in bizarre behaviors and experiencing delusions

of extreme pain that lacked any medical cause. Dr. Watson heard Mr. Greene give "paranoid and

delusional attribution of his 'injuries' to the actions ofa conspiracy." Dr. Watson writes that such

"[d]elusions are associated with a number of psychiatric disorders, especially psychotic disorders,

and based upon my clinical experience I suspect that Mr. Greene suffers from one of those

disorders. "

58. Second, four ofMr. Greene's prior attorneys, who met with him over more than a

decade, describe him generally as "mentally ill," "mentally incompeten[t]," "insane," "crazy,"

"nuts," "irrational[]," having "significant psychiatric or psychological issues," and "hav[ing] lost

his mind." In particular, like Dr. Watson, they describe persecutory and somatic delusions. Dale

Adams, who represented Mr. Greene during 1995 and 1996, describes Mr. Greene as "very

paranoid" and "totally preoccupied with these crazy conspiracies" that everyone was plotting

together "to kill him." JefIRozensweig, who represented Mr. Greene during 2002 and 2003, says

that "Mr. Greene was convinced that" "everyone in the past," including "all of his previous

attorneys," "had been purposefully undermining him." Mr. Rozensweig says that Mr. Greene

ultimately came to believe that "I was out to get him, too."


Attachment S Page 54
59. Didi Sailings, who previously represented Mr. Greene and observed him in 2004,

says that Mr. Greene "was convinced that the guards were trying to contaminate him," and that he

was "absorbed with the pain" that "he thought the prison was inflicting upon him." According to

Ms. Sailings, Mr. Greene "thought that everyone, including me, was involved in this conspiracy

against him" and that he "did not want anything done on his case because he was convinced we

were going to use it against him somehow." Julie Brain, who represented Mr. Greene between

2005 and 2009, describes Mr. Greene as "feeling constant, intense pain in his brain, ear, and spinal

cord" for which doctors could find no physical cause. Ms. Brain further says that Mr. Greene

attributed these injuries to state officials' efforts to punish him "for asking to be extradited to North

Carolina" and that Mr. Greene believed that "numerous high public officials, the courts, and his

prior attorneys" were involved in a "cover up" of these actions. Mr. Greene's present attorneys

inform me that Mr. Greene is not accepting mail from them.

60. Third, the Depattment of Correction's medical staff has made consistent

observations which provide significant insights into Mr. Greene's mental health. One doctor

describes Mr. Greene as complaining of pain so severe that he "would rather be dead" than live

with it, yet the doctor was unable to find any medical causc for such pain. The samc doctor

described Mr. Greene as being "mentally unstable," complaining of "damage[ to] his brain," and

engaging in "yoga-ish contortions" of his body. Another doctOl: described Mr. Greene as engaging

in such bizarre behavior that she was unable to complete her physical examination of him. Nurses

describe Mr. Greene as demonstrating "paranoia," exhibiting "scattered speech," and claiming a

"conspiracy" between prison guards and his attorneys to "burst[] his ear drum."

61. Finally, I have reviewed some ofMr. Greene's personal writings, which are

consistent with the foregoing, reflect fixed delusions, and also seem to indicate a level of


Attachment S Page 55
disorganized thinking. (Spelling and grammar are from the originals.) For example, Mr. Greene


Sence befor July 5th 2004, my cell door trap-door has/is being used as a weapon 24/7 to
inflict more ceaseless debilitating agonizing pain w/injury by the forceful jamming of steel
bor and slomming of trap-door opened/closed bock so hord purposefully repeated for
which originally caused my left inner ear etc. to erupt/burst on the morning of July 5th
2004, the permanent destruction of these vital bodily functioning organs was
orchestrated/conspired criminally by the following and in this chronological order, fired
ex-attorney Jeff Rosenzweig, Worden Grant Harris, Unit Medical dept Nurse Connie
Hubbard, and prison guard Sgt. V. Morris.

62. In another representative example, Mr. Grecne explains:

I stort this I-Iunger Strike until my Demise Due to the prolong and repeated injuries
inflicted on me by the same means sence July 5, 2004 by staff of the ark. Dept. of
Corrections with the deliberate permanent destruction of such vital bodily functioning
organs thats caused injuries so severe and traumaticly inflicted to my brain, head, left inner
ear etc. with such neurological spinal system nervous and other trauma brain damage that I
suffer as well with a deadly and severe Concussion for all of which is so painfully torturing
and inhumane I con no longer humanly function properly and live with.

63. Mr. Greene also writes in a private letter:

oh deor Ms. Nixon, please try and except my humble apology for just now replyin that is
due to the severity of these such prolonged injuries I have, I truely connot rembel', or con
honestly sit. etc. for long enough to try and write ....

64. In a journal entry, Mr. Greene writes:

Due to prolong burst inner ear etc. without the proper specialized medical treatment and
without the ability to no longer breath through my nose I started hyper-ventilating
uncontrollably with my bodily collapse in floor unable to get up from 7:30AM until
11 :30AM (four(4)hr's) all wile all four of my extremitys, both legs and arms were totally
numb and ice cold to the touch w/out of control contraction of muscles and violent shaking
as I go in and out of shock w/possible cardiac-arrest and or stroke at least ten (I 0) or more
different high ranking ADC guords plus three(3) different ADC nurses do nothing but
literally watch me almost die.


Attachment S Page 56
65. Mr. Greene writes of his belief that "the state of at'kansas ... now inflict me with

such at1 inhumane injury as described within these affidavits all because I have always pushed the

issue sence 1994 when my N.C. case being overturned got my arkansas case set aside as weI!."

66. Mr. Greene also writes of the "endless destruction of my legal mail etc. by the ark.

dept. of Corrections" and of the "Dept. of Corrections destroying my legal mail etc.... in their

attempt to prevent me from seeking justice." Mr. Greene further writes that he is being stymied by

"corrupt ADC collaborating attorneys," by "some corrupt lawyer" and by "corrupt ADC with its'

corrupt shot calling lawyers." He writes that he "connot keep being forced to live in such a

manner due to this corrupt ADC and their attorneys with whom I have been firing." He writes that

his court-appointed attorneys secretly took on his case for the purpose of "help[ing] cover up" the

crimes being perpetrated against him.

67. In one filing Mr. Greene explains the "corruption" of one prior attorney as follows:

If after I fired attorney Jeffery Morx Rosenzweig had not have influenced improperly their
government agency in which this case being the ark. Dept. of Corrections as described in
formal complaint with attached nine (9) sworn afIidavits where I am being housed on
death-row I would surely not be inflicted with such debilitating permonent injury so
"Prolonged" for which I am literally being tortured by force to death due to the Corruptness
of the ark. Dept. of Corrections brought on by fired attorney Jeffery Morx Rosenzweig. In
which corrupt attorneys such as him self are the very reason this ark. Dept. of Corrections
con bring its' self above the law to inflict such in-humane injury up on another human
being and then as I be forced to live with such a torturing injury of the destruction of a vital
bodily functioning organ all because of such an improper influencing of a government
agency by fired attorney Jeffery Morx Rosenzweig.

68. Mr. Greene also writes that he has filed a number of judicial ethics complaints

against state and federal judges. I-Ie writes that everything will "be made very public soon."

In an affidavit labeled "Stort of til-Death Hunger Strike," Mr. Greene then writes:

U.S. Presidential Candidate prior ark. gov. Mike Huckabee and prior att. gen. ark gov Mike
Beebe. both with political knowledge of appointed and retained attorney's. prior of Current
in their illicit influence of bias senior ark. Dept of Corrections staff to have expedited by
racial black staff of ark. death-row to inflict constant re-injury to brain with concussion


Attachment S Page 57
destroying all thirty one (31) paired neu-rological spinal nerves through burst left inner ear
etc. as initially described by some means in eleven (II) sworn affidavits. court filed in both
Johnson Co. ark. Wilkes Co. N.C. in 2005.06 whereas through inhumane injuries maim
and torture I expose this state's apointee political officials.

69. In a letter to ajudge submitting affidavits describing his "injuries" and the

conspiracy he believed was being perpetrated against him, Mr. Greene wrote: "Judge Patterson if

you took the time to read these legal documents then you cleorly undertond why I droped my

appeals in 1999 .... " Mr. Greene has sent bizarre writings to lawyers, judges, politicians, other

public figures, and family members for many years now.

IV. Risk Factors for Psychotic Disorders

70. In light of this substantial evidence, I should note that Mr. Greene's history reveals

a number of important risk factors that predict psychotic disorder, including the following:

71. Extensive Family History of Severe Mental Illness. Mr. Greene's extraordinary

family history of severe mental illness is an important predictor of psychosis. Mental illness,

particularly Schizophrenia, has a significant genetic component. Mr. Greene's mother and siblings

appear to have experienced psychotic symptoms themselves, which is especially significant.

72. Family History of Seizure Disorder. Mr. Greene's brother, Hulette, suffcred from

Seizure Disorder. A family history of Seizure Disorder is associated with increased with of

psychotic disorders such as Schizophrenia. Foong, 1. (2006). Epilepsy or a family history of

epilepsy incrcases the risk of Schizophrenia or Schizophrenia-like psychosis, Evidence Based

Menial Health 9(1): 23-23. Researchers believe that common structural brain abnormalities likely

underlie both epilepsy and psychosis. Saehdev, P. (1998). Schizophrenia-like psychosis and

epilepsy: the status of the association, American Journal ofP.\ychiatry 155:325-36.

73. Advanced Paternal Age. Mr. Greene's father was 55 to 57 at the time of his birth.

The literature reveals that such advanced paternal age is strongly associated with psychotic


Attachment S Page 58
disorder. The risk of a father having offspring with Schizophrenia begins increasing substantially

at age 35 to 40 years. The posited cause of this increased risk is mutation in the male sperm cell,

which increases exponentially with advancing paternal age.

74. Extreme Poverty. Mr. Greene grew up in extreme poverty, which places him at

greater risk for many forms of mental illness and for psychotic disorders such as Schizophrenia in

particular. Harrison, G., Gunnell, D., Glazerbrook, C., Page, K., Kwiecinski, R. (2001).

Association between Schizophrenia and social inequality at birth: case-control study, British

Journal ofPsychiatry 179:346-50.

75. Early Parental Loss. Increased risk of psychosis is associated with early parental

loss, pmticularly in persons who, like Mr. Greene, lost a parent before the age of 9. Agid, 0.,

Shapira, B., Zislin, J., Ritsner, M., Hanin, B., Murad, H., Troudmt, T., Bloch, M., Heresco-Levy,

D., Lerer, B. (1999). Environment and vulncrability to major psychiatric illness: a case control

study of early parental loss in major depression, bipolar disorder and Schizophrenia. Molecular

Psychiatry 4(2): 163-71.

76. Prolonged Exposure to Severe Childhood Trauma. Childhood trauma of the sort

that Mr. Greene experienced is a risk factor for a plethora of psychiatric disorders, including

psychotic disorders generally and Schizophrenia in particular. Read, 1., van Os, 1., Morrison, A.P.,

Ross, C.A. (2005). Childhood trauma, psychosis and Schizophrenia: a literature review with

theoretical and clinical implications. Acta Psychiafrica Scandanavia 112: 330-350. Childhood

trauma has a dose-response relationship with psychosis, meaning the individuals who, like Mr.

Greene, experienced severe trauma over a number of years have a greater risk of psychosis and

morc severe psychosis, on average, than those with a more limited trauma history.


Attachment S Page 59
77. Early Marijuana Use. Recent studies have shown a multiplier effect between

childhood sexual abuse of the SOlt that Mr. Greene endured and use of marijuana (in particular)

before the age of 16. Among children who are sexually abused, those who, like Mr. Greene, use

marijuana before the age of 16 are nearly twelve times as likely to receive a diagnosis of psychosis

later in life. Houston, J.E., Murphy, J., Adamson, G., Stringer, M., Shevlin, M. (2007). Childhood

sexual abuse, early cannabis use, and psychosis: testing an interaction model based on the National

Comorbidity Survey, Schizophrenia Bulletin 34(3): 580-85.

78. Low Cognitive Functioning. Premorbid cognitive impairment of the sort suggested

by Mr. Greene's academic record, work history, and family history is strongly associated with

psychosis. Indeed, contrary to certain popular conceptions of the disorder, cognitive impairment

(not secondary to the disorder) is present in the majority of patients with Schizophrenia.

79. Early Impaired Social Functioning. Early impaired social functioning of the sort

indicated by the subjective assessments of Mr. Greene's teachers and siblings is associated with

psychotic illness later in life. Schizophrenic patients often had difficulty in developing and

maintaining friendships with peers during the prodromal phase.

80. Traumatic Brain Injury. Psychosis may also develop secondary to head injuries of

the sort that Mr. Greene sustained, and it is especially likely to develop in people, like Mr. Greene,

who have had more than one head iqjury. The literature shows that the consequences of head

injury are long term and that psychosis may take years and even decades to develop.

81. History of Self-Harm. Self-harming behaviors of the sort that Mr. Greene exhibited

during the mid 1980s are also significant. Self~harm is common during the early, pretreatment

phases of psychotic illness. Harvey, S.B., Dean, K., Morgan, C., Walsh, E., Demjaha, A., Dazzan,


Attachment S Page 60
P., Morgan, K. (2008). Self-harm in first episode psychosis, British Journal ofPsychiatry 1982:


82. Solitary Confinement. The sensory deprivation and social isolation inherent in

supermax confinement of the sort Mr. Greene has experienced increases the risk of psychosis.

This is particularly true in persons who, like Mr. Greene, are predisposed to mental illness and

have impaired cognitive functioning.

83. The information that I have strongly suggests the presence of a psychotic disorder.

However, I cannot establish a diagnosis for Mr. Greene or assess the forensic significance of his

symptoms without conducting a clinical evaluation. The extensive history that I have for Mr.

Greene is necessary, but it is not sufficient. A skilled and careful exploration of the information

that only Mr. Greene himself can provide is required. Likewise, an expert examination of Mr.

Greene's appearance, attitude, consciousness, psychomotor function, speech, thinking, affect,

mood, thought content, cognition, insight, and judgment is essential. The signs of specific

psychiatric disorders often will not be apparent to a layperson. Those signs may even be missed

by medical or psychological professionals who lack specialized expertise in clinical

neuropsychiatry. I would need to visit with Mr. Greene personally before I can offer any definite

opinion in this case.

I declare, under penalty of perjury under the laws of California and the United States that
the foregoing is true and correct to the best of my knowledge.

George W. Woods, M.D.

Date: February 15,2010


Attachment S Page 61

I, Mary Ellen Blankenship, do declare as follows:

1. I am Jack Greene's older sister, and I was eight years old when

Jack was born. My maiden name was Mary Greene. There were seven of us children in

my family growing up: Tom was the oldest, then Huellett, me, Joyce, Danny, Georgia and

then Jack. My father was married before he married my mother and he had six children

from that marriage.

2. I was married to Scott Blankenship, and Scott died in 2004. I am currently

married to Karl Wolfe. We married in 2005 or 2006. I kept my name as Blankenship so

that I would have the same name as my children. I have five of them, four daughters and

one son. My daughters are Angela, Amanda, Tammie, and Jennifer. My son's name is


3. My momma was my daddy's second wife. They married after his first

wife passed away. Five of their children, including me, were born at home. Only the two

youngest, Jack and Georgie, were born in the hospital. Daddy was a very heavy drinker.

He was drunk, not just for weeks, but for months at a time. I'm sure that he was drunk

around the time that Jack was conceived. When my oldest brother Tommy was born, my

mother lost a lot of blood and had to go to the hospital for a transfusion. My grandma

took care of Tommy and she wouldn't ever give him up. Grandma just got attached to

Page I of 18

Attachment T Page 1
him so she kept him. It wasn't too long before my momma had her second baby so it just

stayed that way, that Tommy lived with my grandparents. I was bom at home and was a

preemie. I heard that my momma lost a lot of blood with me, too, and that she had to go

to the hospital. Mrs. Hodge kept me while she was in the hospital. I had the yellow

jaundice and was so tiny she kept me in a shoe box!

4. The earliest house I can remember living in was in Yadkin' s s~~f, ~1;h
Carolina. Our house there was about four miles from my grandparents and I remember us

all walking there to see them. We didn't have a car but momma had a path through the

woods. Still, it would take us hours to walk there. I loved my grandmother and I liked to

be able to see her. Our house in Yadkin Shop two stories: one room in the second story

where us children slept and one room on the first floor, where my parents slept. There

was a kitchen in the back. There was power but no running water. We had to walk clear

across road to get to the spring to get water and carry it back to the house. I remember

when my little brother Danny fell out of the crib at the bam and hurt himself. I don't

remember anyone getting any help for him. I have some good memories and some bad

memories in that house. One bad memory was when my daddy got mad at my half

brother, Bobby, who was grown by then. I think maybe Bobby had disrespected my

momma. Daddy beat him with his belt. It was either a whupping or a beating, I'm not

sure. I think maybe my best memory of that house might be leaving it.

Page 2 of 18

Attachment T Page 2
5. When we moved to a different house in Ferguson, we were farther away )
(excepr- fov OUII 801;\y ifC()An.joVi
ii'om my grandparents and I don't remember seeing them from the time we moved there

until the day my father died. We were not close to anything. You had to walk for two

miles to get to our house off of the main road and we did not have a car. Jack was a baby

in that house.

6. We lived in a real small house with one bedroom, a living room, and a

kitchen. We children shared the bedroom: the boys slept in one bed and the girls slept in

the other. My parents had a bed in the living room that they shared with Jack. The house

did not have running water, no indoor plumbing and no lights. My daddy worked at the

sawmill and, when he was not working, he was drunk. It seemed like he stayed drunk

forever, all the time.

7. My momma worked real hard taking care of us children and putting in a

big garden to help feed us all. Momma was a constant worker. In the summers, my

grandma would give us milk and butter she had chumed. We didn't have power, or an

icebox, so momma had a spring box where she would put the milk and butter in the

spring to keep them cool. Momma would walk down the hill to the spring and get water

to cany back up to the house to heat for bathing us. Then she would bathe us in a

washtub. She had a wash pot that she would carry down to the spring to wash our clothes

and the diapers on an old washboard and then bring the clothes back up to the house to

Page 3 of 18

Attachment T Page 3
hang. Momma would use that same pot to make red devil lye soap. She would put meat

skins and lye and other things in that pot, stir it and oil it until it got thick and then she

would pour it out on something long, cut it up and make soap. We couldn't wash our

bodies with it, but she would use it to wash the floors and wash our clothes.

8. We had to walk down this long path to get to the dirt road where the

school bus would pick us up. It seemed like it was four or five miles and we would walk

it in the dark on winter mornings. There wasn't anything near to us and we didn't have a

car. I don't what they did if one of us got sick or if they needed something.

9. I will never forget the day my daddy died. I was nine years old and

remember it well. As usual, my daddy was drunk and had been for days. Daddy wanted

his shotgun; he said that he wanted to go shoot a chicken. Momma did not want him to

have it because he was so drunk that she knew he couldn't shoot straight; she was afraid

and thought he might hurt someone. Momma had hidden the shotgun in a hack pile out

in the yard. I remember that momma and daddy had been arguing about the b'Un for days.

On this day, momma was in the kitchen, and Daddy came in, and they started arguing

again about the gun.

10. Then, momma went down to the creek to wash the diapers. I was sitting

outside on the front porch. Jack was just eighteen months old; he was in the bed sleeping.

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My daddy came outside. Somehow he knew where the gun had been hidden. Daddy got

the gun out of the hack pile, and then he walked back past me and into the house. I was

scared to death; it looked like that something had switched in my daddy, and because they

had been arguing I was worried he was going to hurt my momma. Daddy went into the

bedroom and shut the door. Daddy was in the bedroom for a long time. Then I remember

hearing a loud noise-a terrible commotion. Momma came back up from the creek. She

went into the bedroom, and saw my daddy unconscious. She didn't see any blood but

couldn't get him to wake up. Momma ran half a mile to Mr. Wolfe's house (my current

husband's father's house) to get someone to see what was wrong with my daddy. Mr.

Wolfe came back to our house and went into the bedroom where daddy was lying. He

said, "Turner is dead." The scream my momma let out will live me the rest of my life; it

has scarred me for life. I will never forget that scream and I don't know what it done to

Jack. He was right there. A car came that was probably the undertaker and then my

grandma and my granddaddy came. We left that house and we never went back.

1 I. My momma had all these kids and no place to go. We had to move in with

my momma's parents, my grandparents. My grandparents had a two-bedroom house.

The girls were in one bedroom and the boys were in the other. I don't remember where

my grandparents slept, but there were seven children and three adults living in that house.

That house had power and it had water but it did not have indoor plumbing. We had an

outhouse. We were very very poor. Momma lived off of welfare but we had a big garden

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Attachment T Page 5
and raised hogs.

12. I had to change schools when we moved and went to Mt. Pleasant

Elementary School, the same school where Jack later went. It was a two or three room

school and had two or three grades per room. I just remember us kids got talked down to

a lot, put down, by the other kids. We got put down for being poor. There was a teacher

who wanted to take me, to raise me. There were other people that wanted to take one of

us kids. Momma wouldn't let any of us go; she used to say, "I wouldn't give a plug

nickel for anyone of you, but I wouldn't take a nickel for you either."

13. There were times back then that momma might run out offood or

something in the middle ofthe month. She would send me to school with a note asking

my teacher to excuse me to run to the store to pick up something for her. It was so far to

the store and we didn't have a car but the school bus would take me to school and I could

go to the store during school hours. I remember one time my sister Georgie didn't come

home when she was supposed to. One of my uncles said that he thought that Georgie was

at Uncle Dick's. My momma sent me up to Uncle Dick's, which was all the way past the

schoolhouse. It was a long walk to get there and I was scared. Georgie was there and I

brought her home. What happened when she got home wasn't pretty! If one of us got

sick, Dr. Miles lived on top of the hill. He built a little room onto his house and that was

where he would see people.

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14. Living with my grandparents was difficult. Tom had always been living

there, and so he was given special treatment. He was used to being king of the hill and

that's why there was so much jealousy, envy and strife. He had been there since birth and

he didn't want to deal with all these siblings. He would keep things stirred up. My

granddaddy, Coles Taylor, treated the rest of us kids like trash, like white trash. My

granddaddy was mean and abusive. He beat all of us kids, especially the four boys, even

when we hadn't done anything wrong.

15. Granddaddy would just get real angry over nothing, like it was nothing to

trigger him off and ifhe would whip one of us, he would whip all of us. He used a belt

and also used a switch. I remember when he whipped Huellett. He thought Huellett had

stolen same hams. He had Huellett pull his pants down and whipped him so hard there

was blood running down his legs. There was blood evelywhere. Huellett was probably

thirteen or fourteen. I remember Huellett screaming. Then granddaddy throwed salt in

his wounds and rubbed it in. It was horrible and we all had to watch that, even Jack. I

just thought he didn't deserve that. I cannot remember what momma did when that

happened. After granddaddy discovered that Tom had been the one to steal the hams, he

had Tom arrested but went and got him out ofjail the same day. Tommy had been living

there before us and he was the king of the bunch. I look at this picture of all of us at a

family reunion before my daddy died. There we all are: I had bare feet, Georgie had bare

feet; Danny had no shilt and bare feet and there's Tom with shoes on. We used to have

Page 7 of 18

Attachment T Page 7
one pair of shoes to wear to school. We would come home and have to put them up.

16. My granddaddy beat and mistreated Jack along with all the rest of us. I no

longer remember any specific beatings that Jack got, but I do know that he got a lot of


17. My brother Huelett would have fits. Apiletic fits and momma would have

to go and hide the butcher knives. He would cut some of the awfullest shines in his sleep.

Momma didn't have no money to get him help. He would walk in his sleep and he would

holler and it would scare momma and she would hide the butcher knives because she was

afraid he would do something. Huellett would wake us all up hollering and screaming

and beating on the walls. He was walking and his eyes were open but he was asleep.

18. My granddaddy was so horrible to us kids that my momma wanted to get

us out of his house in any way she could. She got a welfare check, and got a little

settlement and she managed to scrape together $200 or $300. She fixed up an old

chicken house that was near my grandparents' house. My momma moved into that

chicken house with us kids. My brother Tommy stayed behind with my grandparents. It

was only about 500 feet from granddaddy's house, but at least we weren't under the same

roof. The chicken house had a bedroom and a curtain that set it off from another room, a

living room and a kitchen area. We had lights but still did not have any running water

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Attachment T Page 8
and had to use the outhouse at my grandparents. I remember momma would order us one

set of clothes out of a catalogue. We would wear that one set of clothes to school and

hang it up as soon as we come home. One year a lady gave my momma a bunch of clothes

that her children had outgrown. My momma took and reworked those clothes so that we

could wear them. That was the most precious thing in life: we had a change of clothes! I

remember some woman gave my momma some old bedspreads. She thought so much of

them that she put them in the old quilt shed; she didn't even want to use them. My

momma would take old feed bags and make quilts out of them. My momma continued to

work really hard to take care of us all and we never went hungry. My mother would work

from dawn to dark trying to do everything she could to take care of us, to plant, can, cook,

wash, and give us baths. She just worked so hard, there wasn't time for other things,

things like one to one attention.

19. I remember when we were little, not long after daddy died, we went to the

Mission at Christmas time. They would give us candy, fmit and nuts and one gift. One

year, they gave me a doll. It was the most beautiful thing I had ever seen. My

grandmother would keep it in the closet. She would take it out and let me hold it and

then put it back. I didn't want to keep it out. I was ali'aid someone would tear it up. Sure

enough, at some point my brother Tommy did tear my doll up when I was about sixteen

years old. At some point I got to thinking. My Uncle Paul and his wife Betty lived right

above us in a nice house. They didn't have any children. They both had good jobs and had

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Attachment T Page 9
all kind of money coming in. They made not one effort to see that we could have

something just one time a year, at Christmas. Not once did they give anything to us kids.
::13 Wt1.D ri/ee fu, i5W ~e{vc:s cf +VoW] k<. '" ~fed. Jl?t{t!
(\01"1\130 b do wrth us
20. When he was growing up, Jack had a special relationship with my mother.

After my daddy died, my momma took solace in the fact that she could still snuggle up

with her baby boy. That was all she had left, and she and Jack always maintained a

strong bond. I don't remember Jack having any friends his own age growing up.

21. My momma and both of her parents could read. My daddy never could

read a lick and neither Danny nor Huellett could read either. School was not something

that was emphasized in our house. I can't remember anyone ever helping me or any of us

with our homework and I don't remember being encouraged to do my schoolwork. When

I was thirteen or fourteen, I still couldn't read good. I remember my grandma taught me

to read by teaching me to read the words on the oatmeal box. I think that Jack learned to

read when he went to training school. As soon as we were old enough, every single one

of us quit school.

22. Jack was a good boy, but for some reason my granddaddy didn't like him.

He never gave that kid a chance; one day when Jack was eleven, granddaddy called the

authorities to come pick up Jack and take him away to the juvenile home in Concord. My

momma did not have any transpOitation to go and see Jack. But, by that time I was

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Attachment T Page 10
married, and my then-husband Scott and I took my momma down to visit Jack. It was

years later that Jack told me what was happening in the training school. He told me that

an adult there had "molested him from behind." I understood this to mean that the man

was putting his penis up Jack's rectum. Jack told me that the rapes happened over and

over and over for years.

23. Jack got to know a colored boy who was also being raped in the

institution. They decided that they couldn't take it anymore and would escape. They

broke out, stole a car, and were trying to get as far away from that place as possible. For

a while, the colored boy was driving, but he got scared, and Jack agreed to drive.

Somehow the law got to chasing them, and Jack had a wreck. The colored boy was

thrown through the windshield and into a big tree. It killed him, and Jack almost died

himself. After Jack got out of the hospital, they sent him right back to the juvenile home.

I am not sure how long Jack was in the training school, maybe four or five years. He was

never the same after he got out ofthere.

24. When Jack got out of the juvenile home, he initially went to stay with my

mother. My momma had stayed in the chicken house for three or four years and then she

moved back into the house she had been raised in, the white house. My grandparents

moved into a trailer that they bought and put on land that was nearby. After Jack quit

school, he asked me ifhe could live with Scott and our children, and I agreed. Jack lived

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Attachment T Page 11
with us for about a year. Jack was real good while he lived with us. He would help

watch the children and sometimes go out with me and Scott.

25. Jack had changed since he was in the training school. He was never the

same. Everything about him seemed different. He was so withdrawed, so quiet. There

seemed to be an emptiness to Jack, needing attention or affection. He had always been a

quiet boy but now he was real quiet and did not want to talk, you had to work to get him

to talk. I think that school messed him up. I had never seen anything in the way of

temper in Jack and I still didn't. He did not drink that I knew of while he was living with

us. What I saw was that Jack looked like he was scared or anxious about something, even

when there was nothing to be scared of. It was later, after his first marriage broke up, that

I saw this get even worse. He didn't live with us then but I would see him. He would

pace and look scared. I first noticed this when he got out of training school, it got worse

when his marriage ended and it was there from then on, always there, sometimes worse

than others. He was velY edgy, he couldn't sit still. He was different from my other

brothers. There was something wrong with him but I could never put my finger on what

the problem was; I could just see that something wasn't right. Jack fell onto drinking and

dmgs and that was his security. But he was constantly suspicious-like, thinking, "They're

out to get me."

26. One time in later years, Jack asked ifhe could have a girl come to live

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with him at out house. They weren't married, and I could not agree to let them live

together under my roof because it wouldn't set a good example for my children. So, Jack

and his girlfriend left and moved to Arkansas. I guess they lived there for a few years.

About a year before all of this happened, Jack came to stay with me for the last time. I

remember that he was completely stressed out. He was constantly pacing the floors and

peering out the windows. I don't think anyone was actually looking for Jack; he was just

a nervous wreck for no apparent reason. He got this book, "Why Do I Do What I Don't

Want to Do?" He wanted to get help.

27. It was after I got married that I began to realize that my momma had

mental problems. I would go over there to visit and even if it had been several weeks or

months since I had seen her, momma would never start a conversation. She just would

not say anything but would speak if! spoke to her. She was bad to withdraw, big time. I

can see how Jack got that from momma. My momma was also a worrier and she was a

constant worrier. I think she worried herself to death. Anything could worry her.

28. My brother Danny bought my momma a trdiler house and put it on some

land that he owned. After my momma moved out of the house on my granddaddy's land,

that old white house burned down. Then Danny claimed that he could no longer afford

the payments for the trailer. He took her trailer and she couldn't live there anymore. I

think it broke her heart. She was again left with no place to go and was forced to move

Page I3 of 18

Attachment T Page 13
back in with my granddaddy. She lost many of her possessions in that fire.

29. At some point, my momma became convinced that she was going to die

and go to hell. She became so convinced about this that she would say it over and over

and over again. When I asked her why, she said, "Because I took my medicine wrong, I

have sinned." You could not talk sense into her. I thought I was going to lose her. She

stopped being able to function. She got so bad with this that my sister carried her down to

Statesville and they put her in the hospital where she stayed on the intensive care unit for

several days. They had to give her some nerve medicine and she took some kind of

medicine from then on. .

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30. Momma and Jack are exactly alike. If they believe that something is true,

they get a fixed idea and no one would be able to budge it, even if it did not make sense.

Jack and momma were alike in many ways but that one way they were alike sticks out to

me. .1 Jd COres wOldd U'stet1 to a preo<L4c:v on crtAd/ol !lOt I,'k:e.

(i)~ m()mJYnCt T0I me ~ 0/11 ~ m lovd jJ- (rec-r((
0;M~~ ~~:~ tt~~lfClr:~~r~ d"~(+ W:-stlrO '1g viemo~-C:p,"'-f3 Ihd-Y w&tf>eveA
3I. Now my momma lived with her father, my granddaddy, but he had gotten ~~
real ornery and got on her about everything. Momma told me that she felt demon spirits, 1..: COuld fIlc:l,-
bad spirits, all around Coles Taylor. I worried enough about her that I took her home to 'fI.u1' _
live with me and my family. I wanted to take care of her, wanted to baby her. I felt like
she needed that. She had health problems and she worried about Jack all the time. Jack

Page 14 of 18

Attachment T Page 14
was in jailor in prison at the time. Momma wrote some things to Jack that really hurt my

feelings and she ended up going back to my granddaddy's house, where she lived until

she died.

32. Momma would get really upset about things at home with her father. My

granddaddy mistreated my momma just as before, and would yell and chastise her for the

smallest of things. He would berate her forever for opening the refrigerator and costing

him money. When my momma told Danny how she was being treated, Danny told her

that she needed to do something about it. Danny knew that my granddaddy kept a

hammer underneath his bed. Danny told my momma, "The next time that granddaddy

gets after you, go get that hammer and beat his brains out." Danny repeatedly suggested

this and egged her on. My psychiatrist told me that, if you put something in someone's

mind like that over and over, it can make it come hue.

33. Danny had put it into momma's head that she should go after my

granddaddy with a hammer ifhe got onto her again and finally, that is just what she did.

One day when they had an argument, my momma did go get that hammer and beat my

granddaddy with it. She hit him so hard that she thought my granddaddy was dead.

Thinking that she had killed her own father, my momma went and gathered up all the

pills that she had in the house and took them at once. My momma died. She had

committed suicide. My granddaddy was in the hospital a long time, but he survived.

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Attachment T Page 15
34. The day that momma died, I had a strong feeling earlier that day that I

should go and see her. I went swimming with my family instead. When I learned that she

was dead, a suicide spirit hit me so strong I had to fight it. I had have had to fight that

spirit several times. It was so horrible. It would scare me. I would have to just fight that

spirit to keep from going to get that knife and killing myself. Something would say to

me, "Go and get a knife." My momma and my daddy killed themselves. My brother

Bobby killed himself. I knew that I needed help and I got it. They told me I had a really

scvere depression and now medicine has helped me a lot over the years.

35. After my momma's death, Danny put it into Jack's head that Tom was

responsible. He would tell Jack over and over that Tom's car was seen at my

granddaddy's house on the day she died and that Tom somehow caused my mother's

death. Of course Tom's car was near my granddaddy's house--he lived just next door so

that didn't mean anything-but it was easy to make Jack believe that Tom was at fault. I

tried to tell Jack that this just wasn't true, but it was no good, Danny just pondered that

into Jack's head. Danny just kept weaving his lies and provoking Jack, who was

becoming more and more upset. Just like momma, he got an idea and he would not

budge. Danny knew how Jack felt about my mother, and hc knew that Jack was a

troubled boy. Tbl'\flY V\od --twxh'aett a.lX>cd'- \OW\(I\Y aY!d d- IMM .tJet/
'!-neve was VlCJ CWw! In' ht'fY), ric" WC'ulcX not k:>l.Wige Pvt7W\ that- r'u{ee:t.
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36. All my family has problems. Mental problems run in the family, ..

Page 16 of 18

Attachment T Page 16
especially on the Greene side. My momma and daddy both committed suicide. My half

brother, Bobby Greene, also committed suicide. Bobby was the youngest of my half

siblings, and he was the,only one who lived with us after my daddy's first wife died. I /l#
13ctJby. Mct hie, \'YI( tid set tiM If (,iliS F\?t 00 I n:J to Ci'CM1~e. 'fYl 'UD
heard that Bobby always said, "I will go the same way my daddy went." 1have also heard

that lots of my relatives going back even earlier than my daddy also committed suicide.
ilwc: is tt 5LUCLc(e. .3piVlf. 'fMat IS s;rvo",::) Cf you. L'Ci/t1llo/- -;Jet- C1t.<JQ'j A
{?rom. (;t, /VOUJ my SOM f'Itl.s if toad. flC' IS jf>f- I, let: fh.;j (YJOI11 Wl?t. 1fJe/J
37. My brother, Huellett, had serious mental problems. Huellett was a basket

case-very peculiar, very different. He would close himself into the house and would not

go out for weeks. He couldn't work. He couldn't or wouldn't face reality. He was just

odd. He died of a heart attack around 2008. Hulled was never right in the head. He had

depression. I think that his mental problems may have contributed to his heart attack.

38. Both my daughter and I have really bad nerve problems. I have taken

medicine for my nerve problems, seen a number of psychiatrists for them, and even been

hospitalized for nerves. 1have panic attacks. I remember my first panic attack happened

when I was driving down highway 421 nearby Lowe's Food store. I was with my

daughter Angie. Angie noticed that something was wrong with me, and she looked over,

and said, "Are you okay?" I said, "No." I couldn't put my finger on it, but for some

reason I thought that I was going to die. Angie said later that I had turned as white as a

sheet. Angie called 911, and they took me to the emergency where I was given pills for

my nerves. My daughter Angie takes pills for her nerves everyday. If she forgets her pills

Page 17 of 18

Attachment T Page 17
even for one day, it is easy for me to tell that there's something not right with her.

39. Jack was never right in the head after what happened to him throughout

his childhood. Jack was arrested for the kidnaping of my daughter, Angie. Whatever

Jack has done, Angie and I have both forgiven him. I don't believe that Jack is a bad

person or that everything that happened is his fault. Jack has always had mental

problems, and I think they have gotten worse in prison. Jack has written me a lot of

letters that say he is in pain and that he is being mistreated in prison. Jack says that the

guards are slamming his door with the intention of hurting his ears. Jack also became

obsessed with getting me to be his Power of Attorney, but I wouldn't do it.

40. None ofthe lawyers who represented Jack at his trials ever came to talk to

me about any of this. If they had, I would have told them what I know.

I declare, under penalty of perjmy under the laws of the United States and of

North Carolina, that what I have said in this declaration is true and correct to the best of

my knowledge.

a lien Blankenship
,;; - jt) -;!O!tJ

Page 18 of 18

Attachment T Page 18

I, Danny Greene, do declare as follows:

I. I am Jack Greene's older brother, and I was five years old when

Jack was born. There were seven children in my family growing up: Tom was the oldest,

followed by Huellett, MalY Ellen and Joyce. I came next, followed by Georgia and then

Jack, who was the baby. My father was married before he married my mother and he had

several children from that marriage.

2. I married Jennifer Forester in 1970. Jennifer and I had one son, Kevin.

Jennifer died in 1999. I married Retha Hart in 2000. That marriage ended with divorce in


3. When I was a little boy I fell out ofa loft in the bal11. We were living in

Yadkin's Shop at the time. I fell so hard that it shifted the inside of my whole skull. I am

sure I had real bad damage and we didn't have the money to have it treated. I have real

bad problems with my memory and do not remember much about my childhood at all. I

have wondered if this is the reason. Years later I went to a chiropractor and he asked me

what in the world happened to your head?

4. I do not remember my daddy. I was five years old when he died. I always

heard that my momma had caught him trying to kill himself earlier and took the gun away

Page I of I I

Attachment U Page 1
from him. I heard she wrapped the gun around the lumber hack and bent it but daddy

went back and used that gun anyways to kill himself. I heard he had a drinking problem

and that it gave him awful headaches. Someone said that you could track him through the

woods with the little bags from his Goodie's Powders. The Taylors (my momma's

family) hated my daddy like they hated a rattlesnake. My daddy dranked but he was a

hard worker. I never understood why they hated him so much.

5. My earliest memories are ofliving in the chicken house, near my

grandparents' home. This was a house where my grandparents kept chickens. Now my

mom lived in this chicken house with all us kids. I remember a bobcat came up on our

porch and screamed one night. I was so scared, I climbed on my momma's lap. . J_, A.

We. W l\evO,$eY)e (AWlP.s liM+eAef ofe1ecfy,c 110 VLlI1V1~, UtXfCV.

W~ lrM Wl\ t9w+oU4.< ~ kept- W\,ll~ ~ f.,utte'". (f)t:l1e $fh'~ .
6. I remember more after we moved up to the white house. I hated going to

school. I think that fall had something to do with it, but I got a real bad learning disability

and I cannot read nor write to this day. I can barely sign my name. You couldn't get

tutored back then, there was nothing. They would just push you all the way through

school without even knowing how to read or write. I remember my grandma throwed

rocks at me to try and make me go to school. I am sure the kids would pick on me back

then. Sometimes I would get so aggravated: we had these big old windows in the school

and I would just jump out the window and go find a farm to work at for the day. I don't

remember ever getting no help at all. I asked my momma one time, "Why didn't you get

Page 2 of 11

Attachment U Page 2
somebody to help me?" She didn't have much an answer for that.

7. My momma was a real hard worker. They would can in these half gallon

jugs and she raised a garden for us. The only meat we had was hog meat. The best treat

we ever had was liver mush and sausage. Everything got used out of everything but the

squeal on the pig. We had welfare food, too and we never went hungry. I don't remember

us having many clothes. I remember looking through catalogues and just wishing. For

Christmas, we would get a little old brown bag that would have an orange, a piece of

tangerine, an apple. I thought that was the biggest treat that's ever been. That was a big

treat and momma made sure we always had Christmas. For Christmas and Thanksgiving

we would always kill a hawk for meat.

8. Momma would get a big sack of flour and that sack would have one candy

cane in it. We would each get a piece of that candy cane. That was a treat, We didn't have

no TV. My Uncle Paul had a TV and, if! had done some stuff around his house to help

him, I got to watch Gunsmoke. We didn't get to do that too often and we had to do

something for him to be able to do that. We would go the spring to get water and then tote

it back up to the house. I still have the big old pot that momma would heat water in for

baths and that she used to make soap. The washtub would be out back and we would each

take turns with the water. I didn't care how many people done used it before me, Ijust

had to have a little bath. If kids had to do that today, they would bow up and die! We had

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an old wringer washer that I thought was a real treat- watching the clothes go through the

wringer. It had an old masher on it that would wring the water out and then you would

catch the clothes and put them in a rinse tub. One day I put my finger into the wringer!

Momma had told me to keep my fingers away but I didn't listen. I didn't do that but one


9. I remember that momma would take the Mt. Zion feedsacks and she would

make quilts out of them. There wasn't any heat in the back and it got so cold at night that

we would pile on four or five quilts at night to stay warm. I remember waking up one

morning in the chicken house and snow had sifted across the quilts through the cracks in

the walls. For fun we kids would roll a tire, swing off a tree, go the creek. There were

never many toys. There was never money for a bicycle. There was an old farm near our

house. They would go home at night and they had a bicycle that they would leave behind.

I saw that bicycle and we didn't have one. So I would sneak over at night after they had

left the farm and I would sneak that bike out and ride it. I thought it was the biggest treat!

I did that for three or four years and I would always put it right back where they left it. No

telling how many miles I put on that bike!

10. My grandparents had raised my brother Tom and he was always petted.

Tom was the meanest of the whole bunch. He would beat me and hit me. He had been

there the longest and he was the oldest. Huellett used to beat on me too. When I got old

Page 4 of II

Attachment U Page 4
enough, 1got momma's butcher knife and took it after Tom. 1 got going so's 1wanted

them to think was going to whack them wide open, but 1don't think 1would have really

cut them. They stopped beating on me after that.

II. My brother Huellett always had problems. He had apiletic fits and would

holler and squall and bang against the walls. Poor old Huellett; he was the laziest one of

the bunch. He suffered from depression. Wheeler Ferguson lived down the holler from us

and had always been real good to us. One time Huellett went down and told Wheeler that

he needed a job. Wheeler told Huellett that he could probably use him and said he would

come by and get Huellett Monday morning. Monday come around and Wheeler knocked

on the door. Momma sent him on back to wake Huellett up. He shook Huellett and told

him, "Come on Huellett, time to go to work." Huellett told Wheeler, "I don't work on

Mondays" and rolled over and went back to sleep. Huellet would just stay in bed for days.

One time, he stayed in bed for two whole days and two nights. He only got up to go to the

back porch and go to the bathroom and go back to bed. He wouldn't do nothing and

Coles, my grandpa, hated him like you hate a grizzly. Huellett couldn't read or write a

lick neither. Coles whupped him one time and threwed salt in those wounds.

12. My grandpa was a mean old man. He used to whip all of us and he

whipped me quite a bit. He would take switches and whip my legs so hard that it would

bring blood. He had spells where, according to who he wanted to look down on that

Page 5 of II

Attachment U Page 5
day, that was who he used to go after. I used to holler and squall just to aggravate him and

then I would hide. That was how I would get back at him. Then he would come a~d et ~
anti. ~~IP lYle. iAJ/~lIJrtr.l1es/ p W9e1nev-
me out of the bed at night when I was asleep~ There was a time when I was young that I

left home and went to live with the neighbors. My grandpa was the main reason why I

left. I went and stayed with the Huffinans. They fed and clothed me and even took me to

the movies. I was able to do more things there and I thought that was something else.

13. For some reason, my grandpa always seemed to pick on Jack. Grandpa

was always upset about something, and with Jack, it was blaming Jack for things that got

moved or were out of place. He just acted like he had a grudge against poor Jack. I didn't

see how he could accuse Jack, but grandpa just acted like he was all down on him. One

day he went to the law and had Jack put in training school and taken from his mother.

14. My momma told me that Jack was beaten and that he was molested at

training school. I think if Jack was here today, he would tell you that was his downfall.

While he was at the training school, he and this colored boy broke out and stole this car

and wrecked it. The colored boy got killed and Jack was hurt real bad. I did not see Jack

in the hospital and I never knew for sure what had happened. When Jack came out of the

training school, we were living in the white house. Jack never seemed the same, never

acted the same. Seemed like with everything that had happened to him, he was always

~ 5ce~d.. f\eflVtJ/AS
drinking. One time he half shot his foot off while drinking. .
loOk IX{- wW!:iiocU like.- he ,was wi ~ev fM:';V1d. He tJoubt
?~ce.. Acied like 5tP4page60f II tva::> I?Y) Vu:::J fVlthtc(.
t-\e.- WiAS d.tfrevem-.

Attachment U Page 6
15. My momma ended up living with my grandpa. My momma told me that

while she was living with my grandpa, he would only let her open the refrigerator once, in

the morning, when she was allowed to take some ice out. He didn't want her wasting the

electricity. She told me that when my Uncle Paul and his wife Betty (momma's brother)

would come over to visit, they would not even speak to her. Those Taylors are quair as

quair could be, the quarest people ever been around. It was like they were for themselves

and no one else. It was like they resented momma for having seven children. Momma

took care of her daddy. I took her to the beach and I took her to the mountains but she

'1Qf-llYMdpq{/\ J,
would always say that she had to get back and take care of him. j'(\omh'a folJ
S~ ~.ta.
l\ wor$I1J'p,pe.v" books t!Jr dev:t h0les ~ 1+ ~other-ed ht!Y- 4
SO/I'IRth~ UJ~ 6IJe% her 'iYlar ,w(:lsrl'-l:. ri&'*; ak?tUjSte rr ike
111L '(
~e wevc:': olemonS fheve Javownd her tf.l:ther ,f ~ WtIS reodlN\1:..n,~ Iootl~
16.Momma always had a nerve problem. I took momma to Baptist Hospital in
--f;1i.jroid 'P.r-ob ~1Yl
Winston-Salem where they were going to do some treatment for her,'Where she had to

swallow something. I think it burned her and it really bothered her from then on. She was

just a nervous type lady. She would just go off the deep end and go all to pieces.

17. I always thought my brother Tom had something to do with my momma's

death. Momma had gotten onto Tom's daughter Lanie about using bad language. I think

that made Tom mad and he came over and had words with momma. I think momma got

so upset at Tom that she went and took a bunch of those pills. When my grandfather came

home I think that momma thought it was Tom coming back again, and that she was so

upset and so out of it from those pills that she took a hammer and beat my grandfather,

Page 7 of II

Attachment U Page 7
thinking it was Tom. I think she was out of her head with her medicine and takes a

hammer to her daddy and didn't even know she done it. A guy came by there after Coles

had been beaten and saw momma shaking those pills into her mouth and swallowing. She

was trying to take them all. I know Tom done something and set her off. Tom was afraid

to see me at the hospital after momma died and why would that be? Why would you be . (7)
afraid of something if you hadn't done anything? ~ ()'te ':J()W~_~I/~ ~ ~d 7i!f]
-Tv go to Vub ,ho~. W~ WO uRd ~ be {)(fYtA-~d It VIC: .. ~ ~
G\ Ol'le SOuYle-ti-( ~
18 I saw Tom on the street at the Apple Festival for the first time after

momma died. I flew into him and whipped him good. In my own mind, I believe that he

had something to do with my momma's death. I beat him up right there in the street. His

camera got tore up and he didn't even press no charges. If you don't have no guilt and

when your brother comes up and is frailing you, then why don't you press charges? Tom

Greene done something to my momma. He jumped on her about Lanie. .::r:. w;\~ b~i~ \t:)
It tv <fue ~ r c<ie. 1Y-e CI1t' C\. ~[11 ~ Ire ever-cUd -f-Ov hW F ~
~ WtW fV~p ptl.~ her ~eY"4f io;tr. Gt.tif+L, "1- WM qui/f.
19. I went to my grandpa before he died and I asked him why he treated his

daughter (my mom) and Jack the way that he did. I asked him why he had to do Jack that

way. I told him that he was the reason for Jack's downfall, for sending him to that

training school where he was beaten and molested and for taking him away from his

momma when he was so young. He said to me, "I ought to have had YOU put in that

training school. You're the one who put those firecrackers in my pick up truck." I told

him, "I ought to have whipped your butt but you're an old man and I wouldn't touch

Page 8 of 11

Attachment U Page 8
you." He was mad and told me to leave. I hated my grandpa so much for what he did to

my momma and what he did to Jack. I didn't go to his funeral. I did go to his grave

though and I peed on his grave.

20. I have had problems with my nerves for a long time. For about thirty years,

I have taken Prozac. My problem is that I don't feel like going and doing if I don't take

my medicine. I try coming off the medicine but I always go back on it. I get to feeling

sluggish and don't want to go. I have a need for things to be clean. Wherever I travel, I

cany my own sheets, towels and pillow cases. I do this ifI am staying in a hotel or with

friends. And I take flip flops with me and I won't stand in their shower. My son Kevin

has a problem with alcohol and with drugs. I think he has a problem with depression and I

try to get him to go and see a doctor, but he won't go.

21. My brother Huellett continued to have problems with his nerves. There

were times that I would go to his house and I would hear him walking around inside and

he would not even come to the door.

22. My sister Joyce has had a real hard life. She and her husband used to move

around a lot. When they would move, they put everything they could into the car and just

leave the rest behind. Since her husband died, she lives with her daughter. I always try to

give Joyce some money over Christmas. Joyce is Jack's sister, too, so I left a message for

Page 9 of 11

Attachment U Page 9
her saying why don't we all try to go to Arkansas to see Jack. Joyce's daughter called me

back and said if I ever set foot out there again, she will have me arrested, never call or

come back there again. That bunch is half crazy and they all treat her awful. She draws

disability now. I encouraged her to get a place of her own, but that's a blown wind. She'll

stay there til the day she dies.

23. I used to go and visit my half brother Bobby at times. I heard that he had

been out squirrel hunting and tried to kill himself. The other hunter he was with talked

him out of it but he killed himself later anyways. Bobby could never get over daddy

dying. I think it had something to do with him shooting himself. I heard that the day he

died he even went and told his kids that he loved them; he still had kids at home. He went

in the back bedroom and shot himself with them still at home.

24. Bobby could be a heavy drinker and I always heard that he had really bad

headaches when he drank. My daddy had really bad headaches when he would drink. I get

the awfullest headaches ifI drink a carton. IfI hadn't gotten such headaches, I could have

been a bad alcoholic myself. Neither my brother Huellett nor my brother Tom were ever

big drinkers.

25. Jack is my brother, and I love him and care about him. He has had a hard

life and I know that what happened when he got sent to the training school was the

Page IOof II

Attachment U Page 10
beginning of the downfall for Jack.

I, Danny Greene, declare under penalty of perjury under the laws of Nolth
Carolina and the laws of the United States, that the foregoing is hue and correct to the
~ y ~/)..4&YL~

I, Deborah Grey, declare under penalty of perjury under the laws of North
Carolina and the United States that Danny Greene told me the foregoing and that I read
the foregoing to him verbatim.

J)ebOVbk] 6y~,---- _
Deborah Grey )

_ _().=bl--,{ to { to

Page 11 of 11

Attachment U Page 11

I, Georgia Howell, do declare as follows:

I. I am Jack Greene's sister. Jack is thirteen months younger than me. My

maiden name was Georgia Greene. I was maJTied to Denver Caudill, and known as

Georgia Caudill, for twenty years. Denver and I divorced in 2003, and I have since

married my current husband, Thomas Howell. We live in a trailer home on eighteen

acres of land. Thomas works at a local funeral home. I am presently working at a hotel.

2. My father, Turner Greene, Sr., had fourteen children. He had seven

children with my momma, Ola Pearl, and seven from a previous maniage. In addition to

me, Turner and Ola had Jack, Danny, Joyce, Mary Ellen, Huellet, and Tom Greene

(whose real name is Turner, Jr.). Tom was the oldest and Jack is the youngest. I do not

remember the names of any of my half-siblings offhand. They were much older than me,

and many of them have passed away. I do recall, though, that a few of them lived with us

at times when I was growing up.

3. My dad married my mother when she was only sixteen years old. I think

that they ran off to get married. I heard that my grandfather did not approve: my dad was

so much older than my momma and he had all these children.

4. I do not remember my dad because he committed suicide when I was only

Page I of 13

Attachment V Page 1
two years old. From what I hear, though, Dad was momma's whole world. Momma told

me that Dad drank a lot. She told me that, on the day he died, he had been drinking

heavily and started asking about his shotgun. Momma didn't want him to have it, and she

hid the shotgun under a plank pile in the yard. We didn't have a washing machine then,

and so momma had to go down to the creek to wash out our dirty diapers. It was while

she was doing the wash that she heard the gun go off. She ran back up to the house and

found my dad dead. When I got older I started to ask momma lots of questions about Dad

and about their relationship, but momma never wanted to talk about it. The memories

were just so hard for her. She did not even want us to hang his picture up.

5. After my daddy died, we had no choice but to move in with my mother's

father, my grandfather, Coles Taylor. My grandfather ordered my momma around, and he

beat the kids all the time. He would beat us all for no reason all. He did it just because

he knew he could; my mother had nowhere else to go. I remember Danny testifying at

Jack's trial that Grandfather used to beat him until he bled and then pour salt in the

wounds. I don't think I saw that specifically, but it wouldn't surprise me at all that it

happened. Those were the sorts of things that Grandfather did. I remember telling

momma that she should find someone to remany so that we could all leave. She told me

that she didn't want to risk that some man she was living with would mistreat her kids. I

remember thinking, "Well, geez, that's already happening here with Grandpa." Grandpa

was a mean, mean old man.

Page 2 of 13

Attachment V Page 2
6. My earliest memories are of living in the chicken house. It was just a few feet

from where my grandparents lived and it was where they had kept their chickens. They let

momma and us kids live in it. The chicken house had maybe two windows. It had a dirt floor.

There was no running water; we had to get water from the spring. There was no electricity;

we had lantems. There was no indoor plumbing; we shared an outhouse with my grandparents.

We was so poor, I remember my momma going out and getting broom sage to use as a broom.

It was one big room and momma put a sheet up to divide us boys from the girls. There was an

old wood stove and when it was time to take a bath, momma would have to go to the spring to

get the water, heat it up on the wood stove and use an old washtub to wash us in. Because we

were the littlest, Jack and I usually got the water first. The chicken house didn't even have a

proper door; you had to prop the door up with a stick. I had never been nowhere else, knew

nothing but our life so I didn't really know how bad it was until I got older.

7. My earliest memories are about first or second grade while we lived in that

chicken house. I remember momma had a big garden and she would work from the time I left

to go to school until I come home. She was always tired, so tired. Today I have the utmost

respect for that lady; I could not do what she done, taking care of all of us. Still, momma

couldn't grow enough to feed us all and we had to survive on welfare food, where you go pick

it up once a month. Momma also got a welfare check and foodstamps that she would have to

make last for a month.

Page 3 of 13

Attachment V Page 3
8. We moved from that chicken house into the white house when I was in around

third grade. My grandparents felt son'y for us so they got a trailer and moved into it and gave

us the white house. It was a two story farmhouse with chipped paint. To us, it was like a

mansion on a hill. It had a stove. It had a refrigerator, although we didn't have anything to

put in it. It had electricity and water, although no indoor plumbing. Momma would put the

sheet up to partition the boys from the girls. We had a coal stove in the front that would heat

things but we had to keep the back of the house closed offto keep the front warm. It got so

cold back there. Sometimes momma would heat up a brick and wrap it us for us to have at

night so we would not be so cold. We were still real poor, but we had more than when we

were in the chicken house.

9. There was no such thing as celebrating birthdays. At Christmas time, I

remember momma would get seven little bitty brown bags and she would put stick candy or

oranges or maybe chocolate drops in them. That was Christmas. She would take the broke

candy and put it in her own bag. r_ ...h. , . _ . ..J ./- ~IA .(;fs
frIu bro-{hev. f.\ue( e+f-e fAA/ld I'ltM e;,.i6teY St:yCQ <-UW\]V ~

lhttl toOuPO( fttrr OLtt tvrd hit 'the S'!17UA-dl passed, 04 .:a: wt7ufd Scwe .
t.ID M IY\oIY\Il\A l"J1t/ holol t{ Nom tv ~l.'" h~"ods -fl { f?6''j {'~ W.-- J::cfOYl't;, _
. re~~v
10. I never even went into town until I was a grown woman. We never went J(' t/lockv:

anywhere. Momma never had a car. So the only place we would go would be to school. Once oH. W.
a month momma would go and pick up the welfare food or she would get Mary Ellen to take

her to Charlie Keyes' church where she would get some clothes for us. But we kids never

went. -+ cR.o nor rewteWlbev -ax.~ 4' ftd- dca

.., .J (?V',q ha~~er
- \./
Wv..0 c{/ WM R ~t'1' Wt'vt1,;}/J ;ti, rjj,
Page 4 of 13

Attachment V Page 4
II. School was really hard for both Jack and for me. We was always made fun of

because we was so poor. We had a card that got us free lunch and they made fun of us for

that. School was hard for us and there was never anyone there who could help it with us at

night. Not a one of us kids finished school. It was like even the teachers didn't care about us,

they just wanted to get us out of there. Every day me and Jack would be deathly sick until

after bus had left. We hated it because we was teased so much. I can remember one coat and

one sweater in my life, growing up. I had to wear my sisters' clothes to school, I never had

any new clothes of my own growing up. I remember we had to walk a ways through the mud

to get to the school bus and by the time we would get to school we would be all covered with

mud to our knees Momma would wash all of our clothes out with a wringer washer. She

would heat the water up and she would be doing laundry when I left for school and still doing

it when I came back. We didn't have a clothes line so she would spread our clothes on the
f\ r'I._ <M" ~ 0 1-,,,,,,,.. c'" 'Ioven ll:".f'-t V)l>f11e 'fheve .()Ito t::I
bushes and the grass to dry. rrr-rev II u::: V'\:;. 'II I.
li#\e 'VJre mont'L{ ,'* t'\o l'l1ore i;);tre{ me c(OUJns. SCJf'Mft-wztl::J Yl't~t::I
WI7LJc( (JJ,..c(e ~ ~'.lf(e c(res.$ ({CWl Seavs c/ ~oebt.<*.(. O,.,e> f~1 nuo
utt~ Plttic{ o(r-e.sse.s ~ fo~ ttwCl'e...h:?//v-?t r t<)M LJo Vlo..f~j.. J;j, tL
12. I never remember seeing a toothbrush or toothpaste. At school one year, they

gave out a toothbrush and toothpaste and I didn't even know what to do with it. 1 don't know

what we did at home for that, but a toothbrush was too much of a luxury. I remember

sometimes other children would bring their toys to school for show and tell and Jack and me

never had anything to bring. One day this girl let me take a raggedy old doll of hers home

with me. My momma spanked me for that. Later she told me that if something were to

happen to that doll, she would have no money to replace it. I took it back to the girl.

Page 5 of 13

Attachment V Page 5
13. We got hand me down clothes from Charlie Keyes' mission church. Mary

Ellen and her husband would take momma there to get free clothes and us little ones would

wear the hand me downs from the older ones. Charlie Keyes also gave us whatever toys we

might have, a little ball or a jack in the box.

14. We had relatives who had more than us. My mother's brother Paul lived up the

hill in a nice brick house. She had a another brother, Dean, who lived in Lenoir. You saw

things that they had, and you wanted to have nice things too. One time we were visiting Dean

and his wife had a doll. I wanted to pick it up and take it home so bad I could die. My

momma took a towel and bunched it up in the middle and tied a string around, especially on

wash day. That was the only doll I ever had.

15. I was close to Jack growing up because we were close in age. He was a sweet,

nice boy. For reasons that I never understood, my grandfather really had it in for Jack.

Grandpa was always blaming everything that happened on Jack. Ifhis hoe or his rake got

misplaced or missing, it was always Jack's fault. Jack was just a little boy. What would he

have wanted with those things? Things were always Jack's fault and grandpa would just wear

him out-beat him. He would go after Jack at least once a week, maybe more. Sometimes

after he would whip him, Jack would crawl under the bed and just cry. My heart would break

and I didn't know why this was happening to him. I am assuming that why my momma did

not say anything was because we lived in grandpa's home and he could have thrown us out.

Page 6 of 13

Attachment V Page 6
We had to put up with his abuse and I am sure it broke my momma's heart.

16. One day, some of my grandfather's gas got missing. Jack was just a little boy.

Grandpa automatically jumped on momma and said that Jack did it, and Jack not even old

enough to drive. Grandpa asked Jack one day ifhe wanted to go into town with him. Jack

was so excited, he said yes. We never got to go anywhere! Then my grandfather took Jack

downtown to the sheriff's office and told them that Jack was delinquent and mean. And they

sent Jack offto Stonewall Jackson Training school. Can you believe that a grandparent would

do that to a child? My mother had no say over the whole thing.

17. Sometime while Jack was in the training school, he and another little boy ran

away. The other boy got thrown out of the car and he was killed. Jack got hurt real bad. I

remember going to the hospital with momma but I don't think they would let me in the

hospital. Then momma came out from the hospital with his clothes and they was all covered

in blood. She was real bad upset.

18. Danny told me years later that Jack told him that he had been sexually molested

like crazy while he was at training school. Before he went in there, Jack was the sweetest,

humblest child but when he came out he was so distant, did not want anything to do with

momma or with us. Jack just wanted to be off by himself. I know that was the start ofhis

downfall; he wasn't my sweet little brother anymore. He was the baby and he was momma's

Page 7 of 13

Attachment V Page 7
little pride and joy.

19. Jack was never the same after he got sent to that training school. That

sweet little boy just was not there anymore. It was like a stranger. I can remember when

he was little, momma would rock him and he loved to be held. Now he couldn't seem to

stand for anyone to touch him. He stmted doing dmgs and alcohol at a very early age,

would do whatever he could get whenever he could. It was like he was out in the world

and he just didn't care. You could give Jack one beer and his whole thought process, his

whole demeanor would change. You didn't have to give him a glass of Jack Daniel's for

that to happen. He would become cocky and arrogant, would be insistent about doing

things his way and we would not even know who we were talking to, he would be that

different. Momma found it very confusing.

20. r saw Jack once take something and melt it in a spoon and then shoot in
into his arm. He said that it made him see snakes crawl out of you, see blood dripping out

of the walls, see monsters come at you. r asked him what he would do that for and he
said because he liked it. I think he was in his late teens or early twenties. Still, even after

that Jack never really had any problems ifhe wasn't drinking and dmgging. When he

was sober, Jack would never hurt a fly. None ofthis would have happened if Jack hadn't

been using.

Page 8 of I3

Attachment V Page 8
21. I look back now and I can see where my momma had mental problems,

even back when I was little. I would wake up in the night sometimes, and just find her

sitting there, staring at the stove. 1very seldom remember my momma smiling so 1

thought that people just don't smile. She had a nervous problem. More than once, 1 saw

her just grab her head and her hair and just scream for no reason that 1 could see. I was

around nine or ten the first time 1 saw it and 1was scared to death. 1didn't know what

was going on. She would scream things like, "I don't know what 1 am going to do." She

was also very backward and shy. People would come to the house and she wouldn't talk.

As she got older, she would go to the bedroom. She was my best friend, though, and a

real humble lady. 1remember one time a little bird flew against the glass and knocked

itself out. My momma went out and held that bird until it came to and flew away. She

wanted to do so much for lJ..s but she just did not have it to give. fY\1Wlma lUcufc/ gef
~ ClMc( UXUk ~ fIO&vS o.lof (;lee Sh<'" eouldM'i fj6?f ~~t-A.h(P.
SIV e'OuJ{1/rd:.. 5/t sn(l, WM VeST(~St:'\{of ,tf. d.
22. 1 got married at age sixteen to get away from the house but that marriage

didn't last but a little bit. As 1got older, I stayed close to momma but was never that

close to my other brothers and sisters. Jack and 1 stayed close but he was often gone. At

some point while 1 was married, Jack called and wanted to come and stay with us. 1

found out the law was looking for him and my husband told me that we couldn't let him

stay with us. Sometimes it would be years and 1would not hear from Jack.

23. It was sometime after 1was grown that the white house burned down.

Page 9 of I3

Attachment V Page 9
Danny bought momma a trailer and put it in a trailer park. Then he told her that she

couldn't live there anymore. She went and stayed with Mary Ellen for awhile. The Mary
thY dtUI..L ~ O~'1h6li1!1 C\. I'l'\OW\I'Y1~I:s clotl-t.4 t<A::l<:l a..U Olle" tu. r{4f'"d ~ VI1Pl1t 1I1C1C?!f ~
:/tllen told her that she had to leave.!\ Momma ended up going to live with my ,tj. t:/., V
grandfather. People would corne to see him and my momma would just go back into the

bedroom and not corne out until they were gone. I am the same way. I don't like to be

around people either. My grandpa only got meaner as he got older. They never had a

television set and he had a radio. Only he could listen to it, though and he would only

listen to the obituaries. If someone else turned it on he would get really upset. Momma

was only allowed to wash twice a week. She couldn't do anything. He would say mean

W~ we. weve lrtf-Ie l Iv. Wt;v1d ~~

things. He was like a dictator to her.
ClU ~ Uo 30 io bed ~rt Jt 90t O{ClYk' to Si:W~ e!C'cofy'G,1 Y .
Jt- WaD .ot:\d . ..:et WtJl() filet m.~ ttlWa::J!i. ~ fa Ctve .:ptne~~,f.,/
6~ Wtull\ '-I: wan+~. 101. 'H .
24. Momma was pretty sickly as she got older and she had a lot of medicine

that she took. It seemed like she was under stress all the time. She was so cautious with

her medicines. If she remotely thought she took something wrong, she went crazy. She

won'ied that she had not taken her medicine properly. She would make sure she had

cleaned her glasses so she could see what she was taking. She would cry and say,

"Georgie, do you reckon it's going to hUtt me?" I would count her pills out for her and

tell her that I thought she would be okay. But she stayed nervous about taking it just

right, the right pill for the right thing at the right time. She took nerve pills but I don't

Attachment V Page 10
25. One time, I took my momma down to Statesville because she wasn't feeling

well. They admitted her to the hospital. She could be so calm one minute and then the

very next she would be up on her elbows saying I am going to die, I need a preacher to

talk to. She had rubbed all the meat off her elbows. .5~e !V~d Ctlll11 ~ fl)1f"}Ufu;>,
iht-n SIt- up Ch.o< ~ '.t/Vl SIC/e To({)Y)'l rKLY)()ti) wW~ C1?rOVlJ
.<7ITh ~/, 5>lV WM (eacAVI\?f Ocd fur http. Sly {1XJ.fe.t.d set:V1.{t7l J-.( J..-./
+(9 deetfh. 4 ecurs, I cJ-ev; :c ~ trwt- {ool(: on rYUf ft>.e.. f . .Td qJ.
26. I w6uld talk to my momma on the phone almost every night and go by to see

her. About a week before she died, I went by there and she was acting funny. Usually she

would sit and talk and ask how my day was going. That day, she was not my momma.

She was very very quiet and she had a strange look in her eyes. I thought maybe she was

having a bad day. The next day she called and told me to remember that no matter what

happened, she always had and always would love me. I knew that didn't sound right.

The next day or so Jennifer (Danny's wife) calls and tells me my momma is dead from a

bunch of pills. I never saw her autopsy; I don't know what happened.

27. Everyone but me still lives in North Carolina around the area where we

grew up. Danny inherited a lot of money from his rich wife, Jennifer. Huellett died of a

heart attack just a few years ago. Of course, my oldest brother, Tom, is also deceased. I

remember Tom as being a lot like my grandfather. They were both very temperamental.

My sister Joyce's husband died and she lives with her daughter. Joyce has always been

very nervous. She has never learned to drive. I don't know if she goes to a doctor for her

nerves or not.

Page 11 of 13

Attachment V Page 11
28. I have had problems with my nerves for along time, going back to after

momma died. It first happened when I was at work. It felt like the roof was coming down

on me, everything was getting dark and my heart was pounding ,so fast. I went to the (\
.I ~'"tM ~M'\I petVlI'- sau-(%'.{ It>>k I7V1 ~ ttlCQ ())
emergency room and they told me I had a panic attack."I have been on medicine for a r: ..5GU<? t'n
f'YI0VI.A14 's
long time, although I am not on any medicine right now. I still have the bottle from what .tJ, eti .
I took though and it is nefazodone hydrochloride. Recently I went to the doctor and he

told me that he thought my problem was more depression. He put me on Cymbalta but

that medicine made me feel really weird and I wouldn't take it.

29. All of Jack's siblings love him a lot, and none are mad at him in the least.

Some might have been before, but they are not now. Even Maty Ellen, whose daughter

Jack was accused of kidnaping, has made up with Jack. I think that she has been in

contact with him recently.

30. Jack has written me these disturbed letters, as recently as a month ago,

saying that he is being horribly abused in the prison and that people are plotting against

him. He says that two guards held him while another slammed the prison door on his

head and hurt his ears. He told me that they have hit him in the groin area and that they

have hUlt him real bad. Jack told me that his lawyers are not doing him good, that they

are not trying to helping him. Some of the things Jack writes are strange; they don't

make sense. It worries me a lot that he says that he is being abused in there and that it is

Page 12 of 13

Attachment V Page 12
going on day after day. It just eats at me and there is nothing that I can do.

I declare under penalty of perjury, according to the laws of the United States and

Virginia, that the foregoing is hue and correct to the best of my knowledge.

Georgia H ell

d -/3 /12

Page I3 of 13

Attachment V Page 13
Attachment W Page 1
"1t vlas" Ute second su."c'h
~~~~:ath~',;~~d d;?'s~~,.,,;ne;:10~~~:: i~
the object heing 1.0" put out ,;''-''i;'''',:::<;::.
llluen.. tire wiU.l little \,;"\L ! SL;<"<;:;'
RaiD darnpened t.he !;-~-C)i'
of the :its,sr:mbled ero\vd of OH~' MY;
luokers but llunl)' vlEtting nre~ 'fur,ncr ll)l"oi
H1t'<u watched w!.th interest and t't fil.rlner of .' hti.tI h~'ll
uU1!)bex' !J(.1.rticipated, ll,llnity, wai$ k - i public 'lI'!n lH;ii0.i ftl\'
li'iremen 'i':ere here from GrKll~: flk.t.ed allot-gun
. and lr""'lll"nn hl" M i
ite Falls, ValdeB6, Salisbury, homt":. TlnlfH{ls.y \Vilk(,%ubD(n\uaH'd {)(
Huthel'f<wdtoXl, Hiddenite, ElkIn,' Dr. Jamcl:ll: \\/11 nion~n'iL
\VUkosboro, lVlorganton, Blowing' JIBS eotoner, t'uledthe death ,L Al'l ~)I(I_i'iit1i:.n{ or UH\
,JI,ock, Long View, Lenoir, StRteg,: "uicide, Deput.y Sheriff linke !lrt'll\e wlli """"",,<1 P".
~~!e, \-Vest Jefferson, Lansin~; \Viieg flided In the invetlli~'1tllo)l who jg heiHJll:llf,' th~l '
:and 8.1Hl.rtrt. i or the death. . ~i\lCC(~l$!,)fUl way In 1 ~
'Wiikes!)Ol;O and Elkin had fire I Greene, tile oWcers ,,"ir!, "11- oiik,,"" ,d"ded ]i'riday
trucks on .the SC6TI0 and 1\1organ-1 pnrently hcl{1 a shotgull in ,front roJj()W~i: paul ClJtU'ch,
ton' fi1'e!)),!11 brought along R 1 pf hirn and dtscha.rge<l the load ident.; J. n. \Vhick~)'.
piece of water sp:eay equipment' int.o his heart. No reason was (jell\'; T. 1<';. story,
for B. demonstra.tion. gjYen for the act. li'rtmcl~l GarvIll,Jfnll(~:
In chaige was J. :Fi, Bailey of . Dorn in Wilke.s ,,'M3.rch 7, 1.898, son, 'ClnLeJ)uncan" lUt?
A::>heville, a ~'epresentative of. lIe was a son of the late .1s~ltt('. .r. R. Hix, ])1'. F'. C, "Hh
tho Alnerican LeFrv.nce Com~ Greene and Mrs, I\htry Ellen Cecil Lee" porter,
lHmy \'rhich builds fi:l."0 engines Carltoa G1'o('no of Deep Ga.p. h~lcct.f.'d de18gat:~s 1.0 t.
and truC1m. .North Wilkeshoro S1.u'vivini1,: are his wife,. l\tlru, Kiwani~j CO!wttt.!01i t
F.iremen wero undel' dil'cetion of Ola. Pearl 'Greene oitho home; October 7,R and 9 ill (
Fire . Ch~ef Thul'mond Keuerly~ six sons, Bobby a11d David S. C .., 'were Hobert i\L
Among the visitors were H. :B::. Greene of I Pre-...dcl'lch:shUl'g, Va" n. n.. Chl1rc)], Hoberl
IDl1iott of nuthcrfordton, pres!" Burctt, Hillett;. ,DannY,.an'd.,Jael{. ,lnd Glenn Daney.
dent of the Istate Firemen's As Greene of the i1om'e; "a'even-. ;Ed Cn:u,jill was prop;
"~ocirit.ion; (1. L, Burkett, direc~.~ ,daught.e.r.~,":"\r~:;'~f>Yi~R;1nia.-Spears "man and hr: pl'esentf:
0\' of the North C~l'o1ina Fire at: Lor'~ftiH;':<::Q1ild;::.:::~::1\1i;s~ vi61l" c: Hawn'o"f 'Charlot!
College and Drill School; and A. Gl~eene of FergusOll', Mrs, Velma Ol)ern 001\5 ml\uager' 'of
Y. Cottrell of Lenoh~. a former Felts and Mrs.Vandella. Greene SE:l'vice.
faculty member of t~le North. or Lenoir.l\1ary':,El~len,.T0JT,c~and ;Mr., J1a w.n outlined
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Attachment X Page 1
9/29/2017 Stonewall Jackson secrets: Children against monsters

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Stonewall Jackson secrets: Children against monsters

Charlotte Observer (North Carolina)

October 5, 2013 Saturday

Copyright 2013 The Charlotte Observer All Rights Reserved

Length: 2228 words

Byline: Elizabeth Leland

Dateline: CONCORD


The once-grand brick dormitories of the old Stonewall Jackson Training School have fallen into disrepair, overgrown, crumbling relics
abandoned so many years ago that vultures are roosting inside an open dormer window.

The place looks haunted.

And no wonder, say men who claim they were physically and sexually brutalized by caretakers while locked up at the juvenile detention facility
during the 1940s to 1960s.

Back then, boys as young as 7 were taken from their families and sent to Stonewall Jackson for petty wrongdoings such as skipping school or
riding a bicycle on the sidewalk and for more serious crimes such as stealing cars and breaking into stores.

Others were guilty of nothing more than being hungry or orphaned.

They are grown men now, their hair graying, their faces lined, some with successful careers to reflect on, others still struggling with the law or
with alcohol or both, all with the same chilling memories of the training school.

Three years ago, a chance discovery on the Internet brought them together.

Jerry Moore, who paints houses in Black Mountain, had just bought his first computer, and he Googled Stonewall Jackson Training School.
Up popped a UNC Chapel Hill website with a grainy black-and-white photograph of boys cultivating a corn field at the school in 1937. Linked to
that was another website with a glowing description of Stonewall Jackson .

Moore, 60, was so upset by what he read, he broke years of silence and posted a comment: I remember severe cruelty. He accused his adult
caretaker of hitting him in the face, kicking him in the ribs and slapping his penis with a rubber strap.

Other men found Moores lament and added their own, launching a painful conversation that continues today.

Through the UNC website, then on Facebook, and eventually by phone, the men have formed a fraternity of sorts of former inmates who
understand one anothersdemons. The distrust. The anger. The alcoholism. For some, its meant a few tentative steps toward healing and self-
discovery that might not have happened otherwise.

People who have never seen blood dripping off the toes of children will never understand what we feel, said John Pate, 83, who grew up poor
near Goldsboro in Eastern North Carolina. He said he committed no crime but was locked up at Stonewall Jackson from 1940-1945 on the
advice of a neighbor who assumed he would be better off living there than in poverty and squalor with his father.

Though nearly 70 years have passed, Pate said he still suffers from the trauma.

Children vs. monsters

Waitsel Beard, pastor of Community Baptist Church in Lenoir, wept when he described how a cottage parent broke up a fight between two boys
in 1965. 1/4

Attachment Y Page 1
9/29/2017 Stonewall Jackson secrets: Children against monsters
He grabbed each one of them by the collar, and he rammed their heads together two or three times, Beard said, choking back tears. It
sounded like cantaloupes popping.

Beard, 62, said many boys deserved to be punished, but instead they were tortured. When you slap a 13-year-old in the face, bust his eyes, ...
rub his nose in urine, stuff like that, its sadistic.

The men arent seeking reparations, and legal experts said its unlikely they would prevail on any claim it took a special act of the Legislature
this year to approve compensation for victims of state-enforced eugenics.

But the men who agreed to be interviewed believe the public should be aware of the savage beatings young boys endured or witnessed at the
hands of the state similar, they said, to the atrocities at the Arthur G. Dozier School for Boys in the Florida Panhandle city of Marianna, where
this year graves were excavated to see if anyone was murdered.

We were children, coming up against monsters, Moore said about Stonewall Jackson . Until now, he said he told only a few people, partly
out of embarrassment, partly because he didnt think anyone would believe him.

It excites me a little bit, he said, that the truth is finally coming out.

Thousands of boys were sent to Stonewall Jackson over the years as many as 500 lived on campus at any one time, and theres no way to
determine how widespread abuse might have been. Karin Zipf, associate professor of history at East Carolina University, has written two books
about North Carolina reform schools and said brutality wasnt limited to Stonewall Jackson .

Sometimes it got nasty in the state reformatories, Zipf said. Boys, girls, parents and teachers have told stories of brutal beatings, solitary
confinement and psychological abuse. Because the juvenile court system in North Carolina did not encourage accountability or due process,
officials could inflict brutal punishments almost willy-nilly.

According to state documents, vasectomies were performed on six boys at Stonewall Jackson in 1948.

Mission to save children

The incongruity between what the men said happened and what was supposed to happen is startling.

Stonewall Jackson , named for the Confederate general, was the first detention center in North Carolina, pushed for by reformers who thought
children should not be housed with adult prisoners. These so-called child savers demanded a separate juvenile justice system.

Newspaper editor James Cook of Concord became an advocate after witnessing a 13-year-old orphan sentenced to 31/2 years of hard labor on
an adult chain gang for stealing $1.30. Cook was instrumental in the location of the school off N.C. 49 in Concord.

When Stonewall Jackson opened in 1909, it promised a chance to the boys of the state who need its care and direction.

Funny how such good intentions can get bent all to hell, wrote John Dollard of Asheville, who was sent to the school in 1964. Imagine if your
10-year-old son was slapped to the ground by a grown adult and kicked senseless, or had to fight off sexual predators. ... What if they had to
live in constant fear they are going to do the wrong thing or never see their mother or father again. ...

By the way, the only crime I committed was not having a home and (having) an alcoholic father who couldnt get over World War II. Nobody is
ever going to understand the kind of dent Jackson Training School put in my soul.

In 1969, Dollard said he was hunkered down with other soldiers in a bunker in Vietnam, the enemy firing at them. All these guys were scared
to death, and one of the other soldiers asked why I wasnt afraid of dying, Dollard said. I told him I had been to Stonewall Jackson Training

Very sadistic

The renamed Stonewall Jackson Youth Development Center continues to operate from newer buildings on the back side of the original
campus. The center, which is run by the N.C. Department of Public Safety, is set away from the highway and enclosed behind barbed-wire
fences because many youth housed there committed violent or serious crimes.

At its grandest, Stonewall Jackson encompassed nearly 1,000 acres of rolling farmland, including two lakes, one now a part of Frank Liske
Park. The setting was bucolic and it still is.

Up front on the former, shuttered campus, along a rocky ridge facing Old Charlotte Road, a row of dilapidated red-brick Colonial-Revival-style
dormitories look so eerie, they have attracted a cult-like following. People have sneaked in and posted photographs online, fueling a growing
interest in the school.

The buildings were designed by Charlotte architect Louis Asbury to be family-like settings, where cottage parents were supposed to assume
the roles of mother and father to 25 or more boys. Some couples were caring and empathetic, the men said, but others were vile.

There were no fences, and the Observer regularly published stories about runaways. The worst beatings, the men said, occurred after boys ran
away. When they were captured, they said, they were forced to lie naked across a bench.

Three grown men took their time to beat you so bad you almost passed out, Dollard said. ... It was beyond pain.

One man who did not want to be identified said he still has the scars to prove it.

Half of each day, boys attended class; the other half, they worked in the fields and orchards or learned trades such as repairing shoes, cutting
hair or fixing machines.

Though Wiley Lankford of Jacksonville, N.C., acknowledged being beaten many times during one year at Stonewall Jackson in the 1960s, he
said he never ate better, thanks to an abundance of meat and vegetables from the self-sustaining farm. Having grown up poor in Winston-
Salem, one of nine children, Lankford said he is still grateful for the food.

But thats all.

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9/29/2017 Stonewall Jackson secrets: Children against monsters
It was a horrifying experience, said Lankford, 61, a truck driver. To this day, I dont trust people.

It will never go away

Over the years, there were unsettling reports about the school.

Critics in the 1940s claimed it was little more than a working farm that depended on child labor.

In 1972, a study by a committee of the N.C. Bar concluded that the states eight training schools had become a dumping ground for
unfortunate children and recommended an overhaul of the criminal justice system. The committee was impressed by most cottage parents, but
said some were not equipped for the job by temperament or training, and some were emotionally unstable. The committee also cited incidents
of older children forcing themselves on younger children at night.

At the time, North Carolina ranked first among states in the number of children sent to training schools per capita. Half of the children, the
report said, should never have been locked up.

Two years later, James Tompkins of Huntersville, then director of the Child Advocacy Commission, wrote an explosive paper based on his visits
to Stonewall Jackson and four other schools.

Children are beaten, choked, slapped, verbally assaulted, sexually assaulted and required to experience long periods of solitary confinement,
Tompkins wrote. State officials said reforms had been made and denounced the report as outdated. Tompkins resigned under fire and took a
job teaching special education at Appalachian State University. He is now retired.

What the men are saying doesnt surprise him or the fact that they still suffer.

Those who are treated most abusively will live with it for the rest of their lives, Tompkins said. It will never go away.

Some caretakers displayed sensitivity and kindness, he said. But he was stunned at the open and unchecked aggression against children.

Its impossible to say whether boys who grew up to be criminals, alcoholics and drug addicts turned out that way because of cruelty they
endured at Stonewall Jackson or whether they would have ended up that way regardless.

And it shouldnt matter, Tompkins said. No child should be beaten, especially while under the care of the state.

Tompkins is 78 and doesnt remember specifics about each school, but he hasnt forgotten one.

Stonewall was a nightmare, he said. It was out of the twilight zone.

Im sorry

The mens descriptions have prompted tense online exchanges with children of former caretakers.

Who cares? Get over it, one woman wrote after a post by John Pate.

Right, that was 72 years ago. Move on with life, added another woman.

As long as my parents were cottage parents ... there were no bad things that happened to my knowledge, wrote Kaye Cheek Cook of
Southport. Certainly no boy was mistreated.

Cooks father and mother were cottage parents in the 1950s and 60s, and she defended Stonewall Jackson and the people who worked
there. She said her parents were Christian and believed working at the school was a calling. Im not saying my daddy never spanked a kid,
Cook said in an interview. My daddy spanked me, too.

A former clinical worker, who took a job at Stonewall Jackson after the reforms in the mid-1970s, accused the boys themselves of provoking
a lot of the trouble. The woman, who asked not to be identified, cautioned that their accounts should be taken in the context of the times, when
corporal punishment was allowed.

But she added, If anyone was brutalized, somebody needs to say Were sorry.

And because no one has, she said it: Im sorry.

Struggling to forgive

Beard preaches forgiveness in sermons on Sunday mornings, but he said he harbors feelings of revenge toward former cottage parents, most of
whom are dead. One administrator, whom the men described as especially cruel, is in a nursing home.

I would really like to take a stick and give them a whipping, Beard said, just beat the devil out of them.

Pate said he, too, has struggled to forgive. He retired from a career in sheet metal design and fabrication and splits his time between homes in
California and Idaho.

I have been told I should be grateful, Pate said. I should be grateful nobody wanted a half-starved, illiterate, snotty-nosed little kid, not
even my family. But an innocent child and I was an innocent child doesnt deserve to be mistreated. The children at Stonewall Jackson
were supposed to be fed, clothed and taught reading, writing, arithmetic not have the living hell beat out of them.

Pate assumed that conditions improved after he left, that there were few others alive who would understand. And so for 70 years, he kept the
nightmare of Stonewall Jackson mostly to himself. He did not tell his first wife. He didnt tell his five sons.

Who would believe him?

Talking with the other men has brought not only tears, he said, but also a long-overdue healing of the scars of a broken childhood.

Leland : 704-358-5074

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9/29/2017 Stonewall Jackson secrets: Children against monsters


Language: ENGLISH

Publication-Type: Newspaper


Company: FACEBOOK INC (53%)

Ticker: FB (NASDAQ) (53%)


Geographic: NORTH CAROLINA, USA (75%)

Load-Date: October 8, 2013

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Attachment Y Page 4 4/4
Woman Beats Aged Father,
Dies Later In Hospital
A Wilkes/;l$ro man was seriously injured Furll!ral services for' Mrs. Greene were
Thursday afternoon when his daughter held Sunday at "p.m. at Mountain View
attacked and beat him with a hammer, Baptist Church in Watauga County by the
according to the Wilkes County Sheriff's Rev. Gary Watson and the Rev. Roscoe
Department. Greene. Burial was in the church
C. C. Taylor, 84. of Route 1, Wilkesboro, cemetery.
is in satisfactory condition at Baptist Mrs. Greene was born in Wilkes County.
Hospital in Winston-Salem with multiple June 23, 1920, to Cowles and Gladys Dula
fractures and lacerations. Taylor.
According to a sheriff's department She is survived by three daughters, Mrs.
report Taylor was beaten by his daughter. Georgie Caudill of West Jefferson, Mrs.
ala Pearl Greene, with a hammer. Mrs. Mary Ellen Blankenship of Millers Creek,
Greene died a short while after the in- and Mrs. Joyce Osborne of St. Paul, Va.;
cident at Wilkes General Hosrital. Four sons, Danny Greene of 601 Magnolia
Road, North Wilke;;boro, Tom Greene of
Detective David Call said that Taylor
Route 1, Wilkesboro, Hulette Greene of
made a statement that his daughter had
beaten him with the hammer and that Route 6, North Wilkesboro, and Jack
Greene of Wilkesboro; her father, Cowles
there were witnesses who saw her with the
Tay lor of Route 1, Wilkesboro; two
hammer at the home.
e, brothers, Paul Taylor of Route 1,
Ie County Coroner John S. Blackburn sala Wilkesboro, and Dean Taylor of Lenoir;
:i1 Mrs. Greene probably died of an ac- four step-daughters, Mrs; Lloyd Woodruff,
cidental overdose of prescription drugs. Mrs. Edd PhE'lps, and Mr.s. Jake Spears,
a Rodney Shumate. one of the sheriff's all of Lenoir, and Mrs. Ronald Gmene of
Ig deputies investigating the incident, said Millers Creek; two step-sons, Bobby
s. they are not sure whether or not the d l'UgS Greene of Fe,'guson, and David Gl'eene, of
of had anything to do with Mrs. Greene's Morganton; 19 grandchildren' and 25 step-
et attack on her father, grandchildren.

~~ Savings And Loan To Merge


North Carolina Federal Savings ard By the end of the month, he said, North
Loan's merger with North Wilkesboro Wilkesboro Federal shou.ld begin
Federal Savings and Loan has been ap- operating as North Carolina Federal.
t proved by federal regulators and will be
completed this month.
R. G. Finley, a director on the North
Wilkesboro Federal Board. will become a
This will make the North Wilkesboro member of the major N,C. Federal board
institution a member of the state's largest of directors. All other members of the
savings and loan, with nearly $900 million North Wilkesboro Federal board will
in assets, North Wilkesboro Federal, prior remain as members of the local advisory
a to the merger, listed its assets at $86 board.
ck million. 1'hi" is the first .:ase in which a mutual S
Wayne Church, executive vice president and L owned I 'y its depositors and
Ill- vf North Wilkesboro Federal Sand L, said borrowers has merged with a stockholdE r-
lic the response from depositors at this point owned Sand L, The members -- includinp,
h~~ h",..n "/excellent." The merger wlll
,1Qn,..~il()r" "nrl borrowers of North

Attachment Z Page 1

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