Greene Clemency Application With Attachments (Reduced File Size)

APPLICATION FOR EXECUTIVE CLEMENCY
JACK GORDON GREENE, SK # 922
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
501.324.6114
john_c_williams@fd.org
scott_braden@fd.org
TABLE OF CONTENTS
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
ATTACHMENTS
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
i
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
ii
APPLICATION FOR CLEMENCY
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
1
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.
REASONS FOR GRANTING CLEMENCY
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.
2
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.
I. JACKS EXTREME MENTAL ILLNESS WARRANTS MERCY
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.
3
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
4
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
5
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
6
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
7
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
visitation)19
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
8
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.
9
II. JACKS LIFE HISTORY PRESAGED HIS CURRENT ILLNESS
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
10
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
11
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
12
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
13
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.
CONCLUSION
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.
14
ENDNOTES
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.
16
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
24
members. Several of these interviews are documented in Attachments TW.
25 Attachment X.
26Children against Monsters, YouTube video with interviews of survivors.

Available at: https://www.youtube.com/watch?v=PWKV0F5VOT8.
Elizabeth Leland, Stonewall Jackson Secrets: Children against Monsters,

27
Charlotte Observer, Oct. 5, 2013 (attached as Attachment Y).
28 Id.
29 Attachment Z.
17
Attachment A Page 1
Attachment A Page 2
Attachment A Page 3
Attachment A Page 4
Attachment A Page 5
Attachment A Page 6
Attachment A Page 7
Attachment A Page 8
Attachment A Page 9
Attachment A Page 10
<.
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',..us illness. At
age 13 he was in a wreck and fractured ribs on the left and punctured his lung.
REVIEW OF SYSTEMS
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 _
i
PHVSICAL EXAMINATIO~
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.
BONES & JOINTS: Normal.
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
NORTH CAROLINA DIVISION OF
MENTAL HEALTH, MENTAL RETARDATION
AND SUBSTANCE ABUSE SERVICES
BROUGHTON HOSPITAL
Admitted: 5/30/85
Discharged: 6/6/85
REASON FOR ADMISSION:
The patient was involuntarily committed to this hospital because of alleged threats to
kill other people.
MENTAL STATUS ON ADMISSION:
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".
PHYSICAL EXAMINATION:
Essentially normal.
Supportive laboratory data: Positive drug screen for Marijuana. Urine for C&S is negativ
Routine urinalysis is within normal limits.
PROVISIONAL DIAGNOSES:
AXIS I:
SUBSTANCE ABUSE, MIXED, 305.92
AXIS I:
ADJUSTMENT DISORDER WITH MIXED DISTURBANCE OF EMOTIONS AND CONDUCT 309.40
AXIS II:
PERSONALITY DISORDER, MIXED 301.89
CLINICAL COURSE IN HOSPITAL:
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.
Form No. DMH 12081 BH DISCHARGE SUMMARY
Attachment D Page 1
GREENE, JACK GORDON
NORTH CAROLINA DIVISION OF //27-66-01
MENTAL HEALTH, MENTAL RETARDATION CALDWELL 14 NR
AND SUBSTANCE ABUSE SERVICES
BROUGHTON HOSPITAL
PAGE TWO
FINAL FORMULATION:
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
alcohol.
FINAL DIAGNOSES:
Unchanged
TYPE OF DISCHARGE:
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
WW/dmp
Form No. DMH 1-20-81 BH DISCHARGE SUMMARY
Attachment D Page 2
o
BROUGHTON HOSPITAL
NORTH CAROLINA
DIVISION OF MENTAL HEALTH
AND MENTAL RETARDATION SERVICES
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,--_
IDENTIFYING INFORMATION:
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.
PRESENTING PROBLEM:
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.
PREVIOUS PSYCHIATRIC HISTORY:
The patient has never been to the MHC before. This is his first admission to BroughtDn
Hospital. He has attended AA in the past.
FAMILY DYNAMICS:
Attachment D Page 3
(
~,
.J
BROUGHTON HOSPITAL
I NORTH CAROLINA
GREENE, JACK GORDON
1127-66-01
CALDWELL
PAGE TWO
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.
PSYCHOSEXUAL FUNCTIONING:
The patient is presently divorced from his second wife. He does have a girlfriend and
no sexual problems are noted.
PSYCHOSOCIAL FUNCTIONING:
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.
SOCIAL ENVIRONMENTAL SITUATION:
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.
PHYSICAL FUNCTIONING:
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

/3 PSYCHOSOCIAL ASSESSMENT
Attachment D Page 4
o
BROUGHTON HOSPITAL
I NORTH CAROLINA
GREENE, JACK GORDON

1127-66-01
CALDWELL COUNTY
PAGE THREE
Format: Identifying Information, Presenting PrOblems, Previous Psychiatric History, Family Background, Psycho-sodal Assessment, SocIal-environmental
Assessment, Physical Functioning, Social Assessment.
Date _
SOCIAL ASSESSMENT AND PLAN:
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.
DL/dmp
Form No. DMH 22581

J+ PSYCHOSOCIAL ASSESSMENT
Attachment D Page 5
DECLARATION OF DALE ADAMS
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
DECLARATION OF DALE G. WATSON, PH.D.
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
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
impairment.
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
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
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
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
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
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
vertebrae.
Attachment F Page 7
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
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.
8/20/2009
X
Dale G. Watson, Ph.D.
Attachment F Page 9
Attachment G Page 1
STATE OF ARKANSAS )
)
COUNTY OF ~r..ct. . )
AFFIDAVIT
, 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.
DATE
this
SUBSCRIBED AND SWORN TO BEFORE ME,
oJ,S-(- day of av.~ , a Notary Public, on
20 {)g_____ .
NOT
~AJ~L
Y PUBLIC
\. My Commission Expires: 5/31IXJ'7
05.22
Attachment H Page 1
UAMS
MEDICAL
CENTER
GREEN, JACK G
UAMS#: 00070-11-89
DOB: 03/13/1955
ACC'l'il: 070118906003
LOCATION: OTO
DATE: 01/26/2006
ATTENDING PHYSICIAN: Felicia lJohnson, M.D.
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.
CUHHENT MEDICATIONS: Tylenol.
ALLF.RGIF.S: None_
FEVIEW OF SYSTEMS: A complete review of systems is listed in the

pati.entrs paper chart.
PHYSICAL EXAM:
Gerlcral: In geIlersl l tllG paticflt appears weJ.l afId is ill flO acuLe
distress.
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 ?
PIUNTED BY: l\NSMITH DATE 2/18/2009
Attachment I Page 1
UAMS
MEDICAL
UAMS OUTPATIENT NOTE
CENTER
GHEEN, JACK G
U1IMSj[: 00070-11-89
ACCT,: 070118906003
LOCATION: 0'1'0
01/26/2006
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(~
palpable.
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'] spi.ne 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 wi.th d.i.scs bulging more pronouncod <1t
the C~), C6 .level. rt a,1so showed iJ C5, C6 posteroJatoraJ npondylytic npur.
ASSE~SSME:N'r AND P.LAN:

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: di.et 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
cc:
2 of 2
PIUNTED BY: llNSMl'l'H DATE 2/18/2009
Attachment I Page 2
DECLARATION OF DR. RULOFF TURNER
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
accurate.
I declare under the penalty of perjury that the foregoing is true and corect.
Executed on this 4a auyof August, 2011.
h/*^e aa.
iu-toff
rurner
Attachment J Page 1
DECLARATION OF JULIE BRAIN
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
impossible.
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
proceedings.
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,
I.ESLIE RUTLEDGE
Attorney General
BY: /s/ Darnisa Evans Johnson

DARNr S , .EVAN S .JOFINi Olf
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
ATTORNEYS FOR RESPONDEI{T
L CA
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

DARNISA EVANS JOHNSON
ti
b
$,
U
,\ :M
{I
Attachment M Page 1
Affidavit of David Lewis
l, David Lewis, do declare as follows:
1. I have been friends with Jack Greene since 2009, writing and communicating by
phone on a regular basis. I also have visited Jack in person. I saw Jack in person in
2009, and then again in August of this year.
2. I knew Jack was suffering even in 2009, but he has gone way downhill since the
last time I saw him. He had toilet paper hanging out of both ears and nose and a
badly cut and bruised face. He was barely able to stand while I spoke with him and
appeared in constant pain. He had some of these symptoms in 2009 but nowhere
near this bad.
3. Jack obviously needs medical attention and has for quite some time. His illness
may well be psychosomatic, but it plays out with severe physical symptoms so he
basically cannot walk and seems to be in physical pain all the time. I am personally
unhappy with the State for not treating him, as he obviously has problems that need
attention.
4. I decided to communicate with Jack in order to help "the least among us," and
certainly a man on death row inArkansas is close to that position. From my
perspective as an educated 71-year-old man, Jack is depressed and has a delusion
about being persecuted by the prison system-or at least I hope it is a delusion, as I
would not want to think the system would do that.
I swear under penalty of perjury that the foregoing is true and correct to the best of
my knowledge.
Attachment N Page 1
Date
7
Date
:t:
2
Attachment N Page 2
Attachment O Page 1
Attachment O Page 2
Attachment O Page 3
{,iri !
('a
800-4
STATE OF'RKANSAS )
(]OT]]VTY OFLNVCOLN
)$
)
.11')VI'i'
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,

DATE AFFiA*
a Publicl on this of
20
My Commssion Exp,ires:
NOTARY OF ARKANSAS
CLEVELAN D
My Comnti ssion 03- 1 6-2025
t
Attachment P Page 1
I - 1
~I
Attachment Q Page 1
Attachment Q Page 2
Attachment Q Page 3
Attachment R Page 1
Attachment R Page 2
FORENSIC REPORT OF GEORGE W. WOODS, JR., M.D.
G
WW George W. Woods, Jr., M.D.
A Professional Corporation
Diplomate of the American Board of Psychiatry and Neurology
415-503-3959
Email: gwoods@georgewoodsmd.com
Oakland/Atlanta/Evansville
I. REFERRAL QUESTIONS
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.
II. QUALIFICATIONS
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.
III. SOURCES OF INFORMATION
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.
IV. CLINICAL FORMULATION
Mr. Greene suffers from a psychotic disorder and from ongoing somatic and paranoid
delusions.
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.
1
DSM-V at 819.
2
DSM-V at 122.
3
Id.
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
interview.
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
4
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.
5
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.
6
Declaration of Dr. Dale Watson 17.
7
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
8
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
prescribed.
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.
V. FORENSIC FORMULATION
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
2011.
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 A
G
WW GEORGE W. WOODS, JR., M.D., F.A.P.A.
A PROFESSIONAL CORPORATION
DIPLOMATE OF THE AMERICAN BOARD OF PSYCHIATRY AND NEUROLOGY
415 503 3959

gwoods@georgewoodsmd.com
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
Education
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

Disabilities
2016 Deputy Chairperson, International Association for the Specialized Study of
Intellectual and Developmental Disabilities, Special Interest Research
Group(SIRG)
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,

California
2004-2005 Interim License, Zanzibar Revolutionary Government
1992 Certified by the American Board of Psychiatry and Neurology
1979 Licensed Physician in California
Honors
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
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,
California
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
University
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
2012 Executive Committee, Challenging Behaviors Special Interest Research Group,
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,
Norway
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

Health
Professional Affiliations
International Neuropsychological Society
American Academy of Psychiatry and the Law
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
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
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
Francisco
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
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,
Malawi
2015 Neurodevelopmental Disorders: Training for Clinicians. Zomba Mental Hospital,

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

Uganda
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

Tanzania
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

Table
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
Discussant
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
Discussant
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
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
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

Program
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
1994 The Relationship Between Holidays and Mood Disorders: Doctors Hospital Pinole,
California
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,
California
1992 Overview of Sleep Disorders: Grand Rounds, Doctor Hospital, Pinole, California
1991 Benzodiazepines: Uses and Abuses: Grand Rounds, Brookside Hospital, San Pablo,
California
1990 Sleep Disorders in Schizophrenia: Quarterly Medical Staff Meeting, East Bay
Hospital
1987 Afro-Centricity in Psychology: Grand Rounds, San Francisco General Hospital, San
Francisco, California
1982 Geriatric Psychiatry-University of Southern California
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
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
Medicine.
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.
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
Proceedings)
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
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,
Uganda
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
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
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,
California
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
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
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,
Canada
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

Convention
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
Audiotape).
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
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

Collaboration
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

Programs
2004 Consultant, Corporate Structure, Tostan, Non Governmental Organization, Theis,

Senegal
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
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,
Iowa
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
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 B
DECLARATION OF GEORGE W. WOODS, M.D.
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
1992.
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
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
York.
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.
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
everyone.
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
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.
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
go.
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
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
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
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.
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.
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
10
analgesic that is used to treat moderate to severe pain, Mr. Greene was getting no relief for his
headache.
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
treatment.
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.
11
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
hospital.
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
12
that she rarely would initiate any sort of conversation and would often retreat if other people came
around.
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"
otherwise.
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
13
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.
14
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,
15
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.
16
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
difficulty.
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
others.
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
17
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.
18
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."
19
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
20
disorganized thinking. (Spelling and grammar are from the originals.) For example, Mr. Greene
writes:
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.
21
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
22
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
23
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.
24
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,
25
P., Morgan, K. (2008). Self-harm in first episode psychosis, British Journal ofPsychiatry 1982:
178-84.
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
26
DECLARATION OF MARY ELLEN BLANKENSHIP
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
Mark.
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 )
P
(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.
Page 4 of 18
Attachment T Page 4
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
Page 5 of 18
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.
Page 6 of 18
Attachment T Page 6
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
them.
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
Page 8 of 18
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
Page 9 of 18
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
Page 10 of 18
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
Page II of 18
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
Page 12 of 18
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
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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a.*a.td I f-ooP- Vhlj flVtUCurv wr~ <>I 'IN lovA IA-~{{ not~5(UC" (fIQ" li1t/5.
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,-
~lt8tClYJd
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
'fI1J;~
she needed that. She had health problems and she worried about Jack all the time. Jack
Page 14 of 18
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.
Page 15 of 18
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
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
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
Date
Page 18 of 18
DECLARATION OF DANNY GREENE
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
2007.
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
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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
time!
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/~cou.pl( 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
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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
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would always say that she had to get back and take care of him. j'(\omh'a folJ
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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,
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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: .. ~ ~
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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
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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.
a
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
~fmYk",Wl""g,.
~ y ~/)..4&YL~
reene
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
Date
Page 11 of 11
Attachment U Page 11
DECLARAnON OF GEORGIA HOWELL
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 ~
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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

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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.
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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.
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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;>,
bL
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
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
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.
~jflau~d/
Georgia H ell
Date
d -/3 /12
Page I3 of 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 \,;"s..tt\L ! SL;<"<;:;'
RaiD darnpened t.he enthtJ:::lll1.sm !;-~-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
h
. 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
.Carol inn. liiil'e College./rrhey with Geol'geGl'een":',.()r>it~e',:home ;::,his' m,eI1(~,?~,~.:t;,r9w~?. '<()"~,:,.,t
,.'\11' .. Hailcy and. Chief Kenerly mother, fonT bro'thcrs, Monroe. 'service" sin\~e':h'e: 'begnn
'~ted
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that lh,' demonstration alld AI'vinGrOell eOLDee p tla p ,alelerkiu 1924; The
v.,1a's: highly fiuceessful, .J CITy ':',~nd::::i?~l'l~T:.,(jrc~Ile>o.r;:Le~ :"afd, 1ms:.'fiecome ""{'O
In four phases, the domonatraN nOir;.:.tllree,~:.:~.i~t~r,~t,::,M~~;:,;).~~?~.c,~a, effects e~;~r~:,IJerson h
Hon shoW6<1 that n. mass of summerlin':(}{"~~~,?i~;'A1r.s".;\:R?Xie ty. ' " , ' , ;
fhuue could he qllidtly o",tlng- Hamby.Of'I'url,;ar;':Mr~,MattIO Mr., B.,.. 'Yn pointe<!
,1I.ho,l with little water damage, l3Iankel\8hip()ifje~p Q~Jl.' tbere,~ret()"er 38,OO?
Tho up.t"ir:; part of the house l"Uuer~t service" weretheld ,es"eIriPIo"ingmOre
\Vl. . set first. When two rooma ;sundayl.1a':'?". at'::M()uil~aln haIr,'rnllliO'nPeoPlO '
,wm enveloped in tlaIOOa, which . Vie;VChllrch.nnoa:r<S}()ll~:\FO~k bulldlngS,,}n 'the' :
".l'~ shootIng oul windOWS. Oll\Vi}h<theR,!'Y" .l&08.Gr~enea;1.1jlJ)leces,ormal1 handle'
Olll,.en,I. ,f ir"m ell used. a 1.10~~lelhe::R~V.:;T~~*:;::J()hils()ll<irnel"grilo*"than55 bllllon,
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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
eleland@charlotteobserver.com
Dateline: CONCORD
Body
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.
https://advance.lexis.com/document/?pdmfid=1000516&crid=1f6f06f7-7807-4154-82cb-4ae04fcdc1cc&pddocfullpath=%2Fshared%2Fdocument%2Fne 1/4
Attachment Y Page 1
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
School.
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.

Attachment Y Page 2
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
Attachment Y Page 3
Classification
Language: ENGLISH
Publication-Type: Newspaper
Subject: CHILDREN (89%); STUDENT HOUSING (78%); ADULTS (77%); FAMILY (76%); JUVENILE JUSTICE (76%); INTERNET SOCIAL
NETWORKING (72%); VEHICLE THEFT (70%); ALCOHOL ABUSE & ADDICTION (68%); SUBSTANCE ABUSE (68%); POVERTY & HOMELESSNESS
(60%)
Company: FACEBOOK INC (53%)
Ticker: FB (NASDAQ) (53%)
Industry: INTERNET SOCIAL NETWORKING (72%)
Geographic: NORTH CAROLINA, USA (75%)
Load-Date: October 8, 2013
Go to

Attachment Y Page 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.
ie
~~ Savings And Loan To Merge

19
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
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APPLICATION FOR EXECUTIVE CLEMENCY

JACK GORDON GREENE, SK # 922

October 2, 2017 Respectfully submitted by:

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

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 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

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

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

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

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

on the State of Arkansas.

REASONS FOR GRANTING CLEMENCY

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

Jacks sentence to life without parole.

I. JACKS EXTREME MENTAL ILLNESS WARRANTS MERCY

by delusional conspiracy theories. Jacks debilitating mental illness provides a

compelling reason to spare him from execution.

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

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

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

that he would be before this Board today.

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

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

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

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

over the years: