CAUSE NO.

24,467

7/91£1

TATE OF TEXAS

IN THE

DISTRICT COURT

ERSUS

NAVARRO COUNTY, T E X A S

( ARMERON TODD WILLINGHAM

13TH JUDICIAL DISTRICT

STf-JP1ENT OF ilCTS VOLUME ~ OF . VOLUMES

AUGUST 18, 1992

MR. JOHN JACKSON HR. ALAN BRISTOL

ASSISTANT CRIMINAL DISTRICT ATTORNEYS NAVARRO COUNTY COURTHOUSE

300 W. Third Ave.

Corsicana, Texas 75110

903-654-3045

ATTORNEYS FOR THE STATE

MR. DAVID MARTIN ATTORNEY AT LAW

200 N. 13th Street Coraicana, Texas 75110 903-874-1000

MR. ROBERT C. DUNN ATTORNEY AT LAW

115 W. Collin Corsicana, Texas 75110 903-872-3024

ATTORNEYS FOR THE DEFENDANT

BE IT REMEMBERED that on the 18th day of August, 1992, the

~bove styled and numbered cause came on for hearing before said

presiding, and the

fILED IN

COURT O~ CIW¥llNAl APPEALS

NOV 23 1992

~ollowing proceedings were had; to wit:

Thomas Lowe, lilerK

9

109 113 114 115 116

CHRONOLOGICAL WITNESS INDEX

PAGE

ROCEEDINGS BEGIN

1

URY INSTRUCTIONS

3

PENING STATEMENT (By Mr. Jackson)

8

~PENING STATEMENT (By Mr. Martin)

10

rrITNESSES:

OHNNY EVERETT WEBB

Direct Examination (By Mr. Jackson) .... Cross-Examination (By Mr. Martin)

ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson)

13 22 43 47 49

ARY DIANE BARBE:

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

50 68 83

-85

/j

~RANDY BARBK

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

86 93 98 100

~UFFY BARBE.

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson)

101 103 104

OHN HENRY BAILEY

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

105 106

~ERRY LONG

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson)

9

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CHRONOLOGICAL WITNESS INDEX (Continued)

PAGE

ONALD G. FRANKS

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

117 132

3TEVEN KEITH VANDAVOR

Direct Examination (By Mr. Jackson)

134

~THEL BAPTI ST

Direct Examination (By Mr. Jackson) 139

Cross-Examination (By Mr. Martin) 144

ReDirect Examination (By Mr. Jackson) 144

ReCross-Examination (By Mr. Martin) .... 145

Further Direct Examination (By Mr. Jackson) 146

Further Cross-Examination (By Mr. Martin) 147

ASON GRANT

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct .Examination (By Mr. Jackson)

148 152 153 155 155

DOUGLAS FOGG

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson) Further Cross-Examination (By Mr. Martin)

156 168 179 180 184 185

AMES PALOS

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

186 192

~NDREW T. ARMSTRONG

Direct Examination (By Mr. Jackson) Voir Dire Examination (By Mr. Martin)

201 206

~ANUEL VASQUEZ

Direct Examination (By Mr. Bristol) Voir Dire Examination (By Mr. Martin)

224 264

~OURT REPORTERS CERTIFICATE

270

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ALPHABETICAL WITNESS INDEX

PAGE

ITNESSES:

~NDREW T. ARMSTRONG

Direct Examination (By Mr. Jackson) Voir Dire Examination (By Mr. Martin)

OHN HENRY BAILEY

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

~THEL BAPTIST

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson) Further Cross-Examination (By Mr. Martin)

6RANDY BARBER

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

86 93 ·98 100

201 206

105 106

139 144 144 145 146 147

101 103 104

50 68 83 85

156 168 179 180 184 185

UFFY BARBER

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson)

~ARY DIANE BARBER

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

)OUGLAS FOGG

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson)

ReCross-Examination (By Mr. Martin) ..

Further Direct Examination (By Mr. Jackson) Further Cross-Examination (By Mr. Martin)

.REPROD,!CED FfloM THE Hc>(iJjJ!NejOF iiiETEXAS snl:tEiJicRJV~S .

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ALPHABETICAL. WITNESS INDEX (Continued)

PAGE

ONALD G. FRANKS

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

117 132

ASON GRANT

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson)

148 152 153 155 155

ERRY LONG

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin) ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin)

Further Direct Examination (By Mr. Jackson)

109 113 114 115 116

AMES PALOS

Direct Examination (By Mr. Jackson) Cross-Examination (By Mr. Martin)

186 192

,TEVEN KEITH VANDAVOR

Direct Examination (By Mr. Jackson)

134

1ANUEL VASQUEZ

Direct Examination (By Mr. Bristol) Voir Dire Examination (By Mr. Martin)

224 264

~OHNNY EVERETT WEBB

Direct Examination (By Mr. Jackson) .... Cross-Examination (By Mr. Martin)

ReDirect Examination (By Mr. Jackson) ReCross-Examination (By Mr. Martin) .... Further Direct Examination (By Mr. Jackson)

13 22 43 47 49

~OURT REPORTER'S CERTIFICATE .

169

.0 STATE'S EXHIBIT INDEX
r '''l O. DESCRIPTION IDENTIFIED OFFERED ADMITTED
) Photograph 83 83 83
Photograph 126 127 127
Photograph 126 127 127
Photograph 162,245 162 162
Photograph 162,246 162 162
Photograph 164 165 165
Photograph 166 167 167
Photograph 189,253 189 189
Document 190 190 190
0 Document 190 190 190
1 Document 190 190 190
2 Wood Sample 219 221 221
3 Can 219,252 221 221
4 Jar 218 221 221
5 Report 222 223 223
6 Report 222 223 223
7 (Not Used) * * *
8 Diagram 230 231 231
9 Photograph * 231 231
0 Photograph * 231 231
1 Photograph * 231 231
2 Photograph * 231 231
3 Photograph 240 231 231
('j 4 Photograph 240 231 231
5 Photograph 240 231 231
6 Photograph 239 231 231
7 Photograph 239 231 231
8 Photograph 240 231 231
9 Photograph 241 231 231
0 Photograph 241 231 231
1 Photograph 241 231 231
2 Photograph 242 231 231
3 Photograph 242 231 231
4 Photograph 243 231 231
5 Photograph * 231 231
6 Photograph 243 231 231
7 Photograph 244 231 231
8 Photograph 245 231 231
9 Photograph 246 231 231
0 Photograph 248 231 231
2 Photograph 249 231 231
3 Photograph 249 231 231
4 Photograph 249 231 231
5 Photograph 251 231 231
6 Photograph 252 231 231 0 STATE'S EXHIBIT INDEX (Cont'd)
r_j ADMITTED
O. DESCRIPTION RKED IDENTIFIED OFFERED EXCLUDED SHOWN
7 Photograph 253 231 231
8 Photograph 253 231 231
9 Photograph * 231 231
0 Photograph * 231 231
DEFENDANT'S EXHIBIT INDEX
ADMITTED
O. DESCRIPTION MARKED IDENTIFIED OFFERED EXCLUDED SHOWN
Photograph 181 182 182
Ph~tograph 182 182 182
Photograph 183 183 183
Photograph 183 183 183 , :~.~-'~f#'itiE:1i:XA,SS'tA~~RlV~S'

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PRO C E E DIN G S

THE COURT: Prior to the time the jury

panel comes in, have you furnished them with a copy of

your motion?

MR. MARTIN: I did, Your Honor.

MR. JACKSON: State's seen a copy of

it, Your Honor, and agree to take up matters with

reference to photographs and extraneous offenses outside

the presence of the jury and obtain a ruling prior to

eliciting any testimony.

THE COURT: That will be fine.

MR. MARTIN: Is the Defendant's motion

granted, Your Honor?

THE COURT: Yes, sir.

THE COURT: Bring the panel in, Bill.

MR. DUNN: We would ask the Court to

swear the witnesses in.

THE COURT: Before you bring them in

all the witness that expect to testify in this case, stand

and raise your right hand if you are going to testify.

(Witnesses sworn)

THE COURT: The rule has been

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Okay. Bill, bring the panel in.

1 invoked -- did you want the rule?

MR. DUNN: Yes, Your Honor.

3

MR. MARTIN: Yes.

4

THE COURT: The rule has been invoked

5 which means that all witnesses that expect to testify in

6 this case must go outside the courtroom and remain outside

7 the courtroom and remain close by subject to call, and

8 from this point forward not discuss what your testimony

9 has been or will be other than under the direction of this

10 Court.

11 Now, there is some people that have come in later.

12 Those of you that were not sworn a few minutes ago,

13 will you raise your right hand?

14

15

(Witnesses sworn)

16

17

THE COURT: Each of you were in the

18 courtroom at the time I was telling you what the rule was.

19 Most of you know what the rule is; and you will need to

20 remain outside the courtroom, remain close by subject to

21 call and from this point forward not discuss what your

22 testimony has been or will be with anyone other than under

23

the direction of this Court. You will need to go outside

24

the courtroom.

25

2

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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THE COURT: Now, members of the jury

panel, if you are comfortable, stand and raise your right

3 hands, please?

4

5

6

7

(Jurors duly sworn)

THE COURT; You may be seated.

8 Members of the jury panel, I'm going to go over

9 some additional instructions with you.

10 Basically, this case will proceed in the following

11 order:

12 The state may make an opening statement outlining

13

14

15

its case. The opening statement is not evidence but is

merely to aid you in generally understanding the nature of

the case and the significance of evidence when it is

16 introduced.

17 After the state makes an opening statement, the

18 defendant may -- defense attorney may make an opening

19 statement or he may wait until later or he may not make

20 one.

21 After the opening statement, if any, the state may

22 introduce evidence; and at the conclusion of the State's

23

24

25

evidence, the defendant has a right to make an opening

statement if he hasn't already made one and to introduce

evidence. However, he need not do so.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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······· . ."..~.i-~···TitEHotijiNGS.oF_lixA~$;tl~lrcR1v~ .

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Rebuttal evidence may be introduced.

At the conclusion of all the evidence, the

3 attorneys may make their closing arguments to you.

-4 Faithful performance by you of your duty is vital

5 to the administration of justice.

6 The law applicable to this case will be contained

7 in the instructions I give you during the course of this

8

trial. And it is your duty to follow all such

9 instructions.

10 It is your duty to determine the facts and

11 determine them from the evidence and the reasonable

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inferences arising from such evidence. And in so doing,

you must not indulge in guesswork or speculation.

The evidence which you are to consider consists of

the testimony of witnesses and the exhibits admitted in

evidence.

The term "witness" means anyone who testifies in

person or by deposition, including the defendant. The

admission of evidence in court is governed by rules of

law. From time to time it may be the duty of the

attorneys to make objections and my duty to rule on those

objections on whether you can consider certain evidence.

You must not concern yourselves with the objections or the

Court reasons for these rulings.

You must not consider testimony or exhibits to

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

.~~_·_jJf£.·,.~'rE,x;~s'tt~·~JtJm~~2 .

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1 which an attorney was sustained or which has been ordered

2

stricken.

3 Opening statements and closing arguments of the

4 attorneys are intended to help you in understanding the

5 evidence and applying the law, but they are not evidence.

6 You must not be influenced in any degree by any

7 personal feeling of sympathy for or prejudice against the

8 State or the defendant in this case, for each is entitled

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to the same fair, impartial consideration. No statement

or ruling or remark which I may make during the

presentation of testimony is intended to indicate my

opinion as to what the facts are.

You are to determine the facts. In this

determination you alone must decide upon the believability

of the evidence and its weight and value.

In consideration of the weight and value of the

testimony of any witness, you may take into consideration

the appearance, attitude and behavior of the witness, the

interest of the witness in the outcome of the case, the

relation of the witness to the State or the defendant, the

inclination of a witness to speak truthfully or not, the

probability or improbabilty of the witnesses' statement,

and all other facts and circumstances in evidence.

Thus, you may give the testimony of any witness

just such weight and value as you may believe the

5

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

testimony of such witness is entitled to receive.

Until this case is submitted to you for your

1 2

3 deliberations -- you previously had this one gone over

4 with you a couple of times -- but until this case is

5 submitted to you for your deliberation, you must not

6 discuss the case with anyone or remain within hearing of

7 anyone discussing it; neither should you read any

8 newspaper article, listen to any radio broadcast or view

9 any TV program which discusses the case.

10 After this case has been submitted to you, you must

11 discuss the case only in the jury room when all members of

12 the jury are present.

13 You are to keep an open mind, and you must not

14 15 16 17 18 19 20 21 22 23

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decide any issue in this case until the case is submitted to you for your deliberation under the instructions of the Court.

Is the State ready to proceed in this cause?

MR. JACKSON: In this case in which the defendant stands accused of the offence of capital murder, the State is ready.

THE COURT: Is the defendant ready? MR. MARTIN: The defense is ready, You

Honor.

THE COURT: Mr. Jackson, you want to read the indictment?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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(Defendant arraigned in open court)

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.THE COURT: Now how does the defendant

4 plead?

5

MR. MARTIN: Not guilty.

6

THE COURT: All right.

7

Call your first witness.

8

Do you want to make an opening statement?

9

MR. JACKSON: I have a very brief

10 opening statement, Your Honor.

11

THE COURT: You may proceed.

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SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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By Mr. Jackson

OPENING STATEMENT

2

3

4 Members of of the jury, Cameron Todd Willingham

5 stands accused of the crime of capital murder here in

6 Navarro County, Texas. That crime is alleged to have

7 occurred here in Corsicana two days before Christmas of

8 last year.

9 State believes that the evidence in this case will

10 show that Cameron Todd Willingham and his wife, Stacy

11 Willingham, lived on 11th Avenue here in Corsicana and

12 that they had three children, one of those children named

13 Amber, two years old, and two one-year-old twins,

14

Carman Willingham and Cameron Willingham.

15 The State believes that the evidence in this case

16 will show that on· the 23rd of December, two days before

17 Christmas, in the mid morning hours, Cameron Todd

18 Willingham poured a combustible liquid on the floor of the

19 babies' room there in the house on 11th Avenue in

20

Corsicana. And also that he poured this combustible

21

liquid in the hallway of that same house leading to the

22

entrance door of the house. The State believes that it

23

will further prove that he set fire to that combustible

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liquid in that house, starting the fire that killed those

25

three children, Amber Kuykendall, Carman and Cameron

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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1 Willingham.

2

We believe the evidence will show that he stood by

3 and he did nothing as the heat and the flames and the

4 smoke killed those three children.

5 Members of the jury, we think that the evidence

6 will show that he was urged to enter the house to rescue

7 those children; and he did nothing.

8 State belfeves that the evidence will show that the

9 patterns of those combustible liquids that burned those

10 children burned in puddles on the floor of that house in

11 the babies' room and also in the hallway of that house.

12 And the State believes that the evidence will show

13 that Cameron Todd Willingham, the defendant in this case,

14

15

unmistakably committed the conduct of which he is accused.

State will present evidence in this case from that

16 witness stand through witnesses' testimony and through

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18

19

20

21

22

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documents and through exhibits. Some of those pieces of

evidence will be big, and some of them will be little.

All we can ask you to do is listen to that evidence

and pay attention to the big pieces and pay attention to

the little pieces.

Thank you very much.

THE COURT: Mr. Martin, you want to

24 make one at this time?

25

MR. MARTIN: We do, Your Honor.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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OPENING STATEMENT

By Mr. Martin

4 May it please the Court, ladies and gentlemen of

5 the jury, the charge is capital murder; and the penalty is

6

life in prison or death. You can imagine, I'm sure, the

7 pressure and anxiety that is brought to bear upon the

8 participants in this proceeding.

9

But no pressure and no anxiety, I'm sure, is as

10 great as yours as the State prepares to commence the

11 presentation of their case.

12 I want to remind you before the State begins their

13 evidence of just a thing or two and tell you what I think

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the evidence is going to show.

Every time I hear described to me the State's

theory of what happened -- and it is a theory; no one

knows for certain; it is a theory that they propose to

you -- it makes me shutter. It truly does.

Because the State's theory in the case is the most

unexpected, unprobable, unreasonable scenario that we can

imagine.

The accusation is that this 24-year-old father of

three poured a flammable liquid throughout ~is house and

set it on fire to murder his three infant children. That

is the State's theory that they offer to you.

J.U

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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11

But the law requires, and wisely so for all of our sakes, that they must be able to prove to you in your mind

3 that that is the most reasonable theory that exists about

4 the circumstances that were found because this is a

5 circumstantial evidence case --

6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

MR. JACKSON: I am going to have to object to that characterization, Your Honor. That has yet to be seen, and the State believes that it is not a circumstantial case.

MR. MARTIN: Let me change my statement

then, if I may.

THE COURT: All right, sir.

MR. MARTIN: We believe that the

evidence is going to be that it is a circumstantial evidence case. We believe that the State is relying upon circumstances that they say they have found that points toward their theory. But they must, in your mind, ladies and gentlemen, prove it beyond a reasonable doubt.

Because although the question you will be asked to answer at the end of the State's case is whether Todd Willingham is guilty or not, the ultimate issue that must be resolved in your mind is: Has the State, in the presentation of their ev'Lderrce , excluded from your mind every other reasonable explanation for the circumstances that were found?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

';"'''(f''))J'Jjgl~w:~~.1tIIi7iiASSfiiT-E°AliCHjV •.

....

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(Witness sworn)

1

I ask you to do this: As the State presents their

2

case.

3

MR. JACKSON: Excuse me, Your Honor. I

4 am going to have to object one more time. This is an

5 argument. This is not on opening statement.

6

MR. MARTIN: This is not an argument.

7 I am reminding the jurors of the obligation of the law and

8 that alone, Your Honor.

9

THE COURT: We need to proceed, Mr.

10 Martin.

11

MR. MARTIN: As the evidence is

12 presented, please bear this in mind. The ultimate

13 question for you to decide is: Has the State taken out of

14

your mind and erased it as a possibility any other

15 reasonable explanation for the circumstances that they

16 present?

17 Thank you.

18

THE COURT: Call your first witness,

19 Mr. Jackson.

20

MR. JACKSON: State calls Johnny Webb.

21

THE COURT: Were you sworn?

22

THE WITNESS: (Shaking head negatively)

23

THE COURT: Raise your right hand.

25

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

1 2 3 4

THE COURT: Take your seat there in the

witness chair.

MR. JACKSON: May I proceed? THE COURT: Yes, sir. You may.

5 JOHNNY EVERETT WEBB,

6 After having been called as a witness by the State and

7 after having been first duly sworn to tell the truth, the

8 whole truth, and nothing but the truth, the witness

9 testified on his oath as follows:

10 DIRECT EXAMINATION

11 BY MR. JACKSON:

12 13 14

Q A Q

Would you state your name, please? Johnny Everett Webb.

Johnny, I think it's apparent the place that

15 you come from. Tell me where you live at this time.

16 17

I live in Navarro County Jail, B-21 cell. How long have you been in the Navarro County

A Q

18 Jail, Johnny?

19 20

Six, seven months.

All right. My understanding is that you're

A Q

21 confined in the Navarro County Jail based on a robbery

22 conviction; is that correct?

23 A Yes, sir.

24 Q How long have you been in jail on this robbery

25

charge, Johnny?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Drugs.

Six or Seven months.

A Q

All right. It's my understanding that you were

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3 convicted of the crime of robbery back in March of this

4 year; is that correct?

5 6 7 8

A Q A Q

I believe so.

All right. How old are you, Johnny? Twenty-two.

You have had a rather extensive criminal

9 histroy, have you not?

Yes, sir, I have.

A Q

You've been charged and convicted one time or

12 another for stealing a car; is that right1

13 14 15 16 17 18 19 20

A Yes.
Q Of delivery of marijuana?
A Yes, sir.
Q Theft?
A Yes, sir.
Q Forgery?
A Yes, sir. Q

And of burglary, in addition to the robbery; is

21 that right?

22 23

A Q

Yes, sir.

Johnny, what is your problem as far as not

24 being able to stay out of trouble?

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A

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q

I take it you are off drugs now.

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A

Yes, I am, Except for the medication.

Q

Okay. You have any trouble with mental

4 impairment or anything like that, Johnny?

A

Not always.

Q

Okay. You have a good grasp of what is

7 happening around you?

8 Yes, I do.

A
Q
A
Q
you come in
Willingham?
A
Q Okay. What kind of education do you have?

About 10th grade.

All right. Johnny, while you were in jail, did

contact with a person named Cameron Todd

Yes, I did.

15 Is that the same Todd Willingham that is

16 present here in this courtroom today?

A

Yes, it is.

Q

Is he here seated at the counsel table with his

19 defense attorneys?

A

Do what?

Q

Is that the same Cameron Willingham seated here

22 with his defense lawyers?

A

Yes, it is.

Q

What do you do at the jail, Johnny?

A

Housekeeper.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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-- J.b
Q Are you a trusty?
A Yes, sir, I am.
Q What does that mean?
A It just means I get to go out, clean up, you 2

3

4

5 know, in the morning and at night, just keep the floors

6 mopped, swept.

7

Q

How did you happen to come in contact with

8 Cameron Willingham?

9

A

Doing my normal thing, you know, just sweeping

10 and mopping every day.

11

Q

Did you know what he was in jail for?

12

A

When I first met him?

13

Q

Yes, sir.

14

A No, sir, I didn't. It took me a couple days

15

before I found out what he was in jail for.

16

Q How did you find out?
A I was told.
Q By somebody else at the jail?
A Yeah.
Q Did you have a chance to engage him in 17

18

19

20

21 conversation?

22

A

Yes, sir, I did.

23

Q

Did he know what you were in jail for?

24

A

I'm not sure. I don't know if I told him or

25 not. I imagine he does, though.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

[)

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2

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4

Q

Did you ever talk to him about why he was in

6

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jail?

A

Yeah, I did.

17

Q

All right. Did anybody ever ask you to go find

5 out what Cameron Willingham knew about this crime?

A

No, sir, they did not.

Q

Were you working for any law enforcement agency

8 when you talked to him?

A

No, I was not.

Q

Did anybody ever threaten you or coerce you?

A

No, sir, they never did.

Q

What did Mr. Willingham tell you about the

incident of the fire at his house?
MR. MARTIN: Object to the hearsay, Your
Honor.
THE COURT: I overrule the objection.
MR. JACKSON: You may answer that
question.
THE WITNESS: He said he had done it. 20 BY MR. JACKSON:

Q

Pardon?

A

He said he had done it.

Q

Can you tell us what he told you about those

24 events?

A

Yes, sd r .

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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13

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the children?

MR. MARTIN: We object, Your Honor, to

2

the hearsay.

3

THE COURT: I overrule the objection.

4

MR. JACKSON: You may answer that.

5

THE WITNESS: He was telling me about

6 something about he had came home or something, and he

7 was -- I don't remember exactly where he was at or what he

8 was doing -- but when he came in the house that one of the

9 babies were injured or dead or something like that and he

10 freaked out and --

11

Q

Did he tell you who had injured the child?

A

His wife.

Q

All right. Please continue.

A

And he didn't know what to do. She was crying

15 and going on, and he said he thought of a way to get them

16 all out of it by setting the house on fire.

17

18

Q

Did he tell you what he did at that point?

A

Yes, he did. He said that he took some kind of

19 lighter fluid, squirting around the walls and the floor

20 and set a fire.

21

Q

Did he tell you anything else about how he

22 attempted to shift the blame from him to someone else?

23

24

25

A

I'm not sure.

l~

Q

Did he tell you anything about what he did with

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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the same room?

MR. MARTIN: We object. Leading.

2

THE COURT: I overrule the objection.

3

THE WITNESS: Yes. He said that he had

4 burned one of the kids. I don't know which one, and I

5 assumed at the time that it was

6

MR. MARTIN: We object to the witness

7 speculating.

8

THE COURT: I sustain the objection.

9 BY MR. JACKSON:

10

Q

You can't tell us about your assumptions. Just

11 tell us what he told you.

12

A

That he took some paper, wadded it up, and lit

13 a fire and burned one of the kids on their arm, on their

14

forehead to make it look like they were playing with fire.

15

Q

What else did he say, Johnny?

16

A

That he ran out of the house to go call 911,

17 and someone asked him to go get the kids. He said they

18 were still in the house, and someone told him to go get

19 them. He refused.

20 Q Did he tell you why he wouldn't go back in the

21 house?

22

A

Because he knew they would find out one of the

23 babies was injured.

24

Q

Did he say whether he left all the children in

25

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

n

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MR. MARTIN: Object. Leading.

THE COURT: Overrule the objection. THE WITNESS: No, he didn't.

BY MR. JACKSON:

Q Why did you decide to tell anyone about this

conversation?

A

Because it got to bugging my conscience.

That's why

I mean, three kids -- I mean, you know,

9 someone tells you something like that, it's not something

10 to be taken lightly.

11 12 13 14 15

Q A Q A Q

Did it worry you? A lot, yeah.

Who did you tell about it? Robert Chapman.

Based on your conversation with Mr. Chapman,

16 did you elect to talk with me?

17

A

Well, in a way. Not exactly you; but, you

18 know, I told him, I said, "What should I do 'cause I don't

19 really want to go get into it, but it's bugging me." And

20 he said, "Well, yeah, it's true."

21 22 23 24 25

MR. MARTIN: Object. Hearsay.

THE COURT: Overrule the objection. THE WITNESS: But, you know, he said,

"Now it's on my conscience, too" because I had told him. He said, "I don't think I can -- I don't think I can

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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1 handle that on my conscience."

2

So it went on about three weeks. He said, "Look, do

3 you want me to tell someone?" I said yeah. That's when

4 he said, "Okay. I will tell them what you told me."

16

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Q

Do you remember the first time I talked to you,

21

Johnny?

A

Yes, I do.

Q

You remember the first thing I told you?

MR. MARTIN: Your Honor, we object to

hearsay.

MR. JACKSON: I will rephrase the

question, Your Honor.

THE COURT: All right, sir.

BY MR. JACKSON:

Q

Do you remember our conversation when I first

met with you over across the street?

A

Somewhat, yes, I do.

Q

Johnny, have I ever promised you anything in

return for your testimony in this case?

A

No, sir, you haven't.

Q

As a matter of fact, I told you there is

nothing I can do for you.

MR. MARTIN: Object. Leading.

THE COURT: Overrule the objection.

THE WITNESS: You said there was nothing

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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that no one can do for me.

BY MR. JACKSON:

Q

Do you understand you placed yourself at risk

5

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4 by coming forward with this testimony?

MR. MARTIN: Your Honor, we object to

6 that as leading, assuming some facts not in evidence.

THE COURT: Go ahead.

MR. MARTIN: There is no evidence

9 whatsoever that he has been placed at risk at all in any

10 way.

THE COURT: I sustain the objection.

MR. JACKSON: Pass the witness.

MR. MARTIN: Judge, I need to get the

black board, if I may.

THE COURT: Sure.

16 CROSS-EXAMINATION

17 BY MR MARTIN:

18

19

20 21

22

23

24

25

Q

Mr. Webb, how long have you been in jail?

A

Six, seven months.

Q . And you were in jail -- this time, was it

robbery or burglary?

A

Both. Burglary, robbery and forgery.

Q

Who did you rob? A woman?

A

Yes.

Q

Robbed her of her purse?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

1 2 3 4

A Q A

No, I did not. What did you take? Nothing.

You were charged with robbery, yet, you did not

Q

5 take anything?

6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

A Q A Q A

Q

True.

Tried to take something? What they say I did.

But it's not true?

I don't know if it's true or not.

You don't know whether you are guilty of

robbery or not?

A True.

Q

They did a fabrication on the part of the

police?

A I doubt that very seriously.

Q Then you think it is true?

A I could have done it, but I do not remember

doing it.

Q Because you were under the influence of drugs?

A True.

Q A Q

What kind of dOPe was it? Crack cocaine? Marijuana and drink.

You been smoking marijuana and drinking since

you were nine?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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THE COURT: Mr. Webb, you need to answer

24

A

About that, yes.

2

Q

And have smoked marijuana and drank liquor

3 since the age of nine until -- how old are you now?

4 Yes, drink, until I was 16 or 17.

5

All right. Smoked marijuana since you were

6

13 problem as being?

14

A

Post dramatic stress disorder.

15

Q

And what is it that caused the stress and the

16 trauma?

17

A

I decline to answer that question in open

18 courtroom.

19

Q

Well, I ask you to answer me immediat~ly. What

20 caused it?

21

A

I still decline.

22

MR DUNN: May we have an instruction,

23 Your Honor. I think that's very probative in the

24 credibility of this witness.

25

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1 that question.

2

THE WITNESS: I was assaulted in the

3 penitentiary.

4 BY MR. MARTIN:

5 And that was when?

8

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Q
A
Q
time?
A
Q
A
Q
A
Q 7 And how long were you in the penitentiary that

Thirty days shock probation.

And you were sexually assaulted?

Yes.

Raped by an inmate?

Yes.

I don't mean to be indelicate, but you can see

this is quite important, can you not?

A

Q

Yes.

And since that time -- and we sympathize with

18 you; we do -- but since that time, you have suffered

19 off-and-on mental difficulties?

20

21

A

Q

Yes, I have.

22 that you take now?

And would you tell us what the medication is

23

24

25

A

Q

A

It's Elavil, but I get the generic form.

It's prescribed to you by a doctor?

Yes, it is.

25

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q

You've seen a psychiatrist?

5

6

8

9

10

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A

Yes, I have.

Q

He has diagnosed you as having these mental

4 problems?

A

Yes, he has.

Q

And you went to jail this time, did you tell

7 me, in February?

13

15

16 17

18

19

20 21

22

23

24

25

A

No, I did not tell you February.

Q

What did you say?

A

I believe I came to jail January the 9th of

this year.

Q

Oh, and have been in there continuously since

that time?

A I have never been out since January the 9th.

I've been there continuously.

Q But the last day that you had outside of the

jail, you were under the influence of marijuana and

liquor? Is that the day you were arrested?

A I was under the influence of not only marijuana

and alcohol but, yet, crack cocaine, too, the day I was

arrested.

Q

And how long had you used crack cocaine?

A

Probably four or five months.

Q

And do you steal to get money. to buy crack?

A

Most people do.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Q

Is it possible for you to describe for us the

strength of the addiction to crack cocaine? Would you say it is utterly overwhelming to be --

A

No, I wouldn't.

You can control your actions when you were

Q

under its influence?

A Q A Q

Sometimes.

And sometimes you cannot? Right.

The strength of the addiction is so strong that

you will go out and rob people, correct?
A Some people do.
Q You do, do you not?
A No, I did not.
Q So, are you telling us that you did not rob
someone or that you did or that you just don't know? A

I'm telling you I did not rob someone for the

money to get crack cocaine.

Why did you rob them?

I don't know as if I did.

But you pled guilty to robbing someone.

Well, it seems pretty weird that someone would say I tried to rob them when I didn't, don't

Q
A
Q
A
come up and
you think?
Q I don't know.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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But, in other words, are you telling us that

you stood her -- was it in this courtroom?

5 now?

6

7

8 robbery?

9

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11 not?

12

13

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A

Yes, it was.

Q

You were placed under oath just like you were

22

23

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25

A

Yes, I was.

Q

Swore to the Court that you committed this

A

Yes, I did.

Q

But you can't remember whether you did so or

A

True.

Q

I suppose that you and Todd Willingham have

been friends for a great many years?

A

Q

A

Q

A

Q

No.

You haven't been?

No, we haven't.

You met him only when?

Jail.

In jail this year. And do you remember when

21 this year in jail?

A

Q

A

Q

Between January 9th and January 30th.

You met him first in January?

January or first of February.

And you were in the same cell with him, and you

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

29

were friends with him and talked to him every day?

A Q

I was not in the same cell with him.

You were not in the same cell, but you talked

to him for hours at a time, no doubt?

A Q A

Q

Probably 30 minutes to an hour, yeah. When? Once a day?

Once or twice.

And in some hidden spot there of the jail where

no one else could hear you?

A

No. Anyone could have keyed a mike in on the

telephone on the speaker system and heard exactly what I was saying.

Q A

Q A Q A Q A Q

This occurred under a speaker in the jail? Yes, it did.

The deputies could have heard? The deputies could have heard.

Anybody else in the cell could have heard? Not unless --

-- they were listening?

Yes.

You see what I've drawn here on the board? You

don't know what this is yet, do you?

A Q

No, I don't.

Well, what this is meant to be is a drawing of

the place where you say this conversation took place there

:'

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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okay.

1 in the jail. This is meant to represent Cell Block 38,

3

Is that any more familiar to you now? Do you

4 recognize this as the small area outside the cell blocks?

5

6

A

Yes, I do.

Q

And right out here a few feet away is the

7 control room where a deputy stays; isn't that right?

8

9

A

Yes, it is.

Q

And this is where you would go into this little

10 area here to pick up trays and sweep up?

11

12

13

14

15

16

17

18

19

20

21

22

23

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25 there?

A

Just sweep up. I never picked up trays.

Q

You just go in there to sweep?

A

Sweep and mop.

Q

Okay. The deputies stay in this control room?

A

Yes, he does.

Q

And this is all glass right here, isn't it?

A

Yes, it is.

Q

And this is all glass, isn't it?

A

Except for the metal.

Q

Metal door?

A

Yeah.

Q

But there are ho bars, right?

A

No bars.

Q

There is no solid steel doors in this area, is

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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No, there's not.

8

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Q

Anybody standing anywhere out here or in these

3 cells could see you standing here, couldn't they?

4 Sure could.

A
Q
A
Q
is h~?
c; •
A
Q
A
Q 5 And could see Todd standing there, right?

7 He's not in solitary confinement or anything,

No, sir, he's not.

There are three cells right here, aren't there?

Yes, there is.

And this is the day room area with the table

and television set, right?

A

Yes, it is.

Q

And during the day the prisoners in that cell

16 block can come out there, wonder around, eat, watch TV,

17 right?

A

Right.

Q

And same' is true for this cell block and this

cell block, true?

A True.
Q Everybody over here can see everybody over here
if they are standing around the door, can't they?
A Yes, they can.
Q The deputies can see everybody all the time, SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

-.

1 2 3 4 5 6

can't they?

A Q

Sure can.

Because it's glass all the way through here and

here, right?

A Yes,

it is.

Q

Wouldn't you agree that it was made so that the

7 deputy could see everybody sitting from the control room?

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

A Q

That's the purpose, yes.

And inside this room, this door shuts and

locks, doesn't it?

A Q

Yes, it does.

Inside this room there is an intercom, isn't

there?

A Q

Yes, there is.

The deputy in the courtroom (sic) can listen to

every conversation in there, can't he?

A Q

Yes, he can.

And what you are telling us is that Todd

Willingham stood at this door and talked to you through the food tray slot, correct?

A

Correct.

Q I want to show you a videotape of this area and

ask you to tell us whether it is exactly the spot where you are saying you were, okay?

(Videotape playing)

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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BY MR. MARTIN:

6 conversation was taking place, right?

13 don't they?

18 prisoners in there with him, correct?

21 say you were talking to him, weren't there?

Q

Is that it? Is that the door?

A

It may be -- yeah, that's it.

Q

This is where you say you stood while this

A Yes.
Q Prisoners in here, right?
A Yeah.
Q Prisoners in here?
A Uh-huh. Q

All these food trays stay out all the time,

A

Yes, they do.

Q

Just like that?

A

Just like that.

Q

There's where Todd is locked up. There's other

A

I would assume so.

Q

Well, there were other people in there when you

A

I believe there was.

Q

And so you are telling us that standing there

at this food tray slot with these other people around, a

person whom you did not know before you met them in jail

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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confessed to you that he had murdered his three children?

5

6

7

8

9

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12

A

True.

Q

Told you all about those details that you

4 described?

confess to you?

A

YeS, he did.

13

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20

21

22

23

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25

Q

And you were dumbfounded?

A

I don't understand the word "dumbfounded".

Q

You were shocked?

A

YeS, I was.

Q

You were surprised

A

Yeah.

Q

-- that anybody would do such 'a bizarre thing?

A

Yes.

Q

First time it's eVer happened to you? Someone

A

YeS.

Q

Never happened before?

A

Not with something like this, no.

Q

You took some notes?

A

No, I didn't take no notes.

Q

Can you write?

A

Yes, I can write.

Q

And read?

A

Yes.

Q

You took no notes?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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. 35

A (Shaking head negatively)

Q This conversation occurred over the course

of -- what did you tell us -- two or three weeks?

A About a month.

Q Over a month's time?

A Yes.

Q Bits and pieces picked up over 30 days or so?

A No.

Q How did it happen?

A Well, I had been talking to him and he had been

having

Q Talking to him about what? Just

A Everyday events, things. He was having a hard

time sleeping and asked me if I would give him some of my

medication. I said yes, I would.

Q And you did?

A Yes, I did.

Q Had it in your pocket?

A Yes, I did.

Q Is it sleeping pills?

A Yes, it is.

Q Is that the only kind of medication you had?

A No, it's not.

Q You had some other medication on you?

A Yes.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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/~)
--_.,_.- .. Q

And the people of the jail just let you wonder

through the jail with medicine in your pocket?

A No, they don't.
Q But you had it with you?
A Yes.
Q Weren't supposed to?
A Wasn't supposed to.
Q How did you get it?
A Through the nurse.
Q Was she supposed to give it to you?
A Yes, she was.
Q What were you supposed to do with it?
A Take it.
Q Take it and put it up?
A No. Take it by mouth.
Q But you didn't?
A Yes.
Q You just stuck it in your pocket?
A Not all of it. I would give him, like, one pill every now and then to help him sleep because he said

he was having a real hard time sleeping. He was telling

me about the case the whole time, but he was always

telling me that he didn't do it. Then one day, mainly, he

just broke down and said, "I done it."

Q Cried, no doubt?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A

Yeah.

Q

And eVerybody could See him there crying,

3 confessing to you?

18

4

5

6

7

8

9

10

11

12

13

14

15

16

17

A

No. There was no one at the other doors.

Q

EVerybody was --

A

-- watching TV.

Q

Okay. And the television, as I recall, in this

cell block is about right here?

A

Yes, it is.

Q

And the television in the other day rooms is

always up near the front, isn't it?

A No. It's about middle-ways of the wall back.
Q Back down here somewhere?
A No. On this other one.
Q We will watch the tape again in a minute see if
We can see. No one else was in Todd's cell except him?

A

I don't remember. There might have been

19 someone laying in there. I don't remember.

25

20

21

22

23

24

Q

So, in other words, he talks to you about it

for 30 days, says he didn't do it. Then all at once, much

to your surprise, he confesses?

A

True.

Q

You go back to your cell; you write down what

he said?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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No.

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Q

You just remembered it?

.:HS

A

Yes.

Q

This occurred when?

A

About in April, I would imagine.

Q

And then you told us that you told the

7 deputy

A

Robert Chapman.

Q

-- a month later?

A

No. About a week later. A week later, but,

11 you know, I told him I didn't want him to tell what I

12 knew. He said that he wouldn't, and I kept talking to

him. He ~aid, "Well, man --" he says, "

what are you

going to do about that?" I said, "I don't know what to

do. I really don't want to get involved in it." He said,

16 "Yeah, but the man told you something that people really

17 do need to know. I mean, if the dude done it, then you

18 need to tell someone." You know, it got to bugging me.

Q

But you slept on it for a week?

A

Hum?

Q

You didn't tell anybody for a week?

A

No. Robert, that's it.

Q

Okay. But for the first week after this

24 supposed confession, you didn't say anything to anyone?

A

No.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

.~8fj~-~i#_:"ixAS·STJi$E·AJ.WRWes'

...

1

2

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Q

Didn't tell anyone at all?

A

No.

Q

Then a week later your conscience began to

4 bother you?

6 me.

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My conscience pothered me from the day he told

39

Q

You told the deputy sheriff that sombody had

confessed three murders to you, and he asked you what you

were going to do about it?

A

Well, you know, I considered him my friend. I

said, "Look, can I tell you something without you telling

anybody?"

Q

And for three weeks this secret was kept

between you and he?

A Yes, until he made the decision that it was the

right decision. He just wanted me to do the right thing.

That's what I tried to do.

Q

You know Joe Jackson?

A

Yes, I do.

Q

He was in the cell with James McKnight? Do you

know the FBI agent, Mike McKlusky? You know him, don't

you? You know any FBI agents at all?

A

No, I don't.

Q

Mr. Webb, aren't you the same Mr. Webb that

made a complaint to the FBI in May of this year that you

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

'·1fll'III.' ••• ~.s~~;ii:_lilxAssni1-Ec;;weFltv@.S .

,

2

Q

4U

1 were being physically abused in the jail?

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6 investigate?

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20

A

A

A

No, I'm not.

Q

You called the FBI --

A

No, I did not.

Q

in Dallas? They came down here to

A

No, I did not.

Q

You were interviewed by the FBI in May?

A

No, I was not.

Q

Not at all? That's not true, not any of it?

A

No, sir, it's not.

Q

You never made a complaint to the FBI?

A

No, sir, I haven't.

Q

Joe Jackson?

A

He's a black guy that was in Cell 44.

Q

It's around here?

A

Yes, sir.

Q

Where? Over here?

No, next one.

Q

Here?

Right there.

Q

And how long was Joe in there?

I don't know, four, five months, maybe longer.

24 I can't remember.

How did you know him, just like you did Todd?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Just came around. You know, they ask us for

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bleach to clean their showers. We give them the stuff.

3 That's about it.

Q

How did you learn his name?

A

Well, I've known him before from jail. I've

6 been there. I know who he is.

7 Q This wasn'~ the first time you met him?

8 A No, it wasn't.

9 Q Now, presently, you are under a sentence of 15

10 years to do in the penitentiary?

A

True.

Q

Is that aggravated or non-aggravated?

A

Aggravated.

Q

How much time do you understand that you will

stay at minimum in the penitentiary?

A

Three years, nine months.

Q

And when were you sentenced to that?

A

Sometime either in late January or early

February.

Q

Do you know why you are still here?

A

Basically, no, I don't. I think to testify on

this, but I'm not,sure.

Q

You should have gone to the penitentiary before

now, but you you've been held over to testify here?

A

Not necessarily. There's another person in

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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/j
---_."- jail that's got 35 years aggravated. He's been there 18 months. They are not really rushing to get anybody with aggravated time out because they got so much time to do.

Q Would you tell us what the symptoms of your

mental problems have been? Depression?

A Yes.

Q Lo~s of sleep?

A Yeah, I've lost a lot of sleep.

Q Mental confusion?

A I wouldn't say mental confusion.

Q You mean, you don't know that you robbed

somebody, but you are not mentally confused?

A I think I was so blitzed on drugs, you know, I

blacked out.

Q And how long have you been on medication?

A Two years.

Q Continuously for two years?

A Not continuously.

Q Just off and on?

A Off and on.

Q Have you been on medication for your mental

problems the entire time you've been in jail?

A Yes, I have.

Q Been taking medicine every day for the entire

time you've been in jail?

42

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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1

Q

A

Yes, I have.

2

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Q

Q

It was prescribed to you by the jail nurse?

43

A

By the jail doctor.

12

13

14

prison?

Q

Who is that?

A

Barnaby.

Q

Can you tell us how many times you've been

7 interviewed by the prosecutors in this case?

15

A

A

As in who?

Q

Mr. Jackson, Mr. Bristol, mister

A

I've been interviewed about four times.

Did you ever make any notes about any of it?

A

No.

Q

Can you tell us when' you are expecting to go to

I expect to go whenever they make a list and

16 put my name on it.

17

MR. MARTIN: Pass the witness.

18 REDIRECT EXAMINATION

19 BY MR. JACKSON:

20

Q

Johnny, I believe you told Mr. Martin that this

21 defendant was having a hard time sleeping; is that right?

22

A

Yes, it's true.

He told you why he was having a hard time

24 sleeping, didn't he?

23

25

MR. MARTIN: Object. Leading.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Q A Q

THE COURT: Overruled.

THE WITNESS: Yes, he did.

He told you he killed his children, didn't he? Yes, he did.

He told you he needed your sleeping medication

44

to sleep; is that right?

A Q

True.

You understand there's going to be lots of

problems for you associated with giving this testimony, don't you?

A Q

I'm well aware of that fact.

What happens to people who give this type of

testimony in your situation?

MR. MARTIN: Your Honor, we object to that as calling on the witness to speculate to things. Irrelevant. No personal knowledge.

MR. JACKSON: Let me rephrase that.

BY HR. JACKSON:

Q

Do you have personal knowledge of people who

have given information about fellow inmates?

A Q

Not really.

You have information of what's happened to you

after you've given information about fellow inmates, don't you?

A

Yes, sir.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q What has happened to you?

MR. MARTIN: We object to that as being

irrelevant.

THE COURT: I overrule the objection.

THE WITNESS: My life has been threatened

as well as my family's life. And if I make it to the

penitentiary, then I'm going to be in deep trouble.

Q Who has threatened you, Mr. Webb?

A Two people, sir. Robert Lyles and Todd

Willingham.

Q What did Mr. Willingham say he would do?

A He just pointed his finger at me. He did like

this.

MR. JACKSON: Let the record show, Your

Honor, that the witness has drawn a his finger across his

neck.

THE COURT: The record will so reflect.

BY MR. JACKSON:

Q Mr. Webb, you gave a written statement to a

deputy sheriff in this case, I believe; is that correct?

A True.

Q In that written statement, I believe you said

Todd Willingham told you --

MR. MARTIN: Your Honor, we object to

this as an improper attempt to bolster the witness'

45

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

c)

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MR. JACKSON: The credibility of this

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILL'E, TX 75116

1 statements.

3 witness has been substantially attacked during

4 cross-examination. I think I'm entitled to do that.

5

THE COURT: Rephrase your question, Mr.

6 Jackson.

7 BY MR. JACKSON:

8

Q

Did Todd Willingham tell you he poured lighter

9 fluid on the children's floor of the children's room in an

10 X pattern?

11 12

A Q

Yes, he did.

Did he tell you he removed one of the children

13 to a different location in the house?

14 15

A Q

No, I don't think he said that.

Okay. You made a statement at an earlier time,

16 I believe

17

MR. MARTIN: We object to this again as

18 an improper attempt to bolster the witness. It's also

19 leading.

20

21 BY MR. JACKSON:

THE COURT: Overrule the objection

22

Q

I believe you said at one point he said he

23 moved one of the kids from one room to another; is that

24 right?

25

MR. MARTIN: May the record reflect that

i")

:~~~_.~"T_rEX4SST.41?E:j/llBHiVil$"

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2

exactly; but I think that's probably right.

47

1 the prosecutor is showing the witness a piece of paper.

THE COURT: Yes, sir.

3

MR. MARTIN: May we know for the record

4 what the prosecutor is showing the witness?

5

MR. JACKSON: I will be happy to offer it

6 at any point you choose, Mr. Martin.

7

MR. MARTIN: I'm not offering it.

8 BY MR. JACKSON:

9

Q

In that statement you said, "He then moved one

10 of the kids from one room to another, then started the

11 fire in the hallway." Would that be a fair statement?

12

A

Yes, I believe it would.

13

Q

Are you scared of Todd Willingham?

14

A Scared of what could happen through the people

15

he knows, yes.

16

MR. JACKSON: Pass the witness.

17 RECROSS-EXAMINATION

18 BY MR. MARTIN:

19

Q

Now, Mr. Webb, you told us twice that Todd

20 didn't say anything to you about taking one of the

21 children to another room; and then when the prosecutor

22 showed you the script, you changed your mind. Now, which

23 one is it?

24

A

I think he said -- you know, I can't remember

25

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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MR. MARTIN: Pass the witness.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

Q

After being reminded by Mr. Jackson of what you

2

said in the script he showed you, right?

3

A

Not just that. It's just, you know, that's

4 probably right.

5

Q

Now, when Todd supposedly told you this, you

6 didn't think too much about it, did you?

7

A

At first, no. It stunned me. I didn't really

8 know what to think.

9

Q

Well, you said in the past that you didn't

10 think too much about what he told you, did you?

11

A

I don't believe I've made that statement.

12

Q

Well, let me show you what Mr. Jackson showed

13 you that he provided me. Didn't you say, "In the past at

14

first I did not think too much about what Todd told me?

15

A

Probably, yeah.

16

Q

You said that, didn't you?

17

A

Yes, I did.

18

Q

Now, are you swearing to this jury that you

19 never made a complaint to the FBI about being abused in

20 jail?

21

A

I have never been abused in jail.

22

Q

Are you swearing that you did not complain to

23 the FBI this year that you had been abused in jail?

24

A

I have never complained to the FBI.

25

4 make you doubt ~our testimony here this morning?

7 Willingham said he killed his children?

8 9 10 11 12 13 14 15

1 2 3

5 6

FURTHER DIRECT EXAMINATION

BY MR. JACKSON:

Q

Johnny, has Mr. Martin said anything that would

No, sir.

A Q

Does it remain your testimony that Cameron

A

Yes, it does.

MR. JACKSON: Pass the witness. MR. MARTIN: No further questions. THE COURT: You may step down,

Members of the jury panel, at this time we are going to take about a ten-minute recess.

It's very important to continue to remember the instructions previously given everybody with reference to

16 conversation among yourselves or with anyone else.

17 If you happen to -- if you run into some of the

18 people in the audience outside the courtroom, if you are

19 outside the courtroom, if anyone attempts to talk to you

20 about this case, you need to let me know about it at once,

21 okay.

22 You can go in the jury room.

23 24 25

(Recess)

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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1

Q

Is that near the house that used to be the

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

THE COURT: Jury panel is back in the

2

courtroom.

3

Mr. Jackson, call your next witness.

4

MR. JACKSON: State calls Diane Barbe.

5

THE COURT: Come forward, please, ma'am.

6

You were previously sworn?

7

THE WITNESS: Yes.

8

THE COURT: Take your seat, please.

9

MR. JACKSON: May I proceed, Your Honor?

10 MARY DIANE BARBE,

11 After having been called as a witness by the State and

12 after having been first duly sworn to tell the truth, the

13 whole truth, and nothing but the truth, the witness

14

testified on her oath as follows:

15

DIRECT EXAMINATION

16 BY MR. JACKSON:

17

Q

Would you state your name, please, ma'am?

18

A

Mary Diane Barbe.

19

Q

And where do you live, Mrs. Barbe?

20

A

1205 West 11th.

21

Q

That's here in Corsicana, Texas?

22

A

Yes, sir.

23

Q

Is that correct?

24

A

Yes, sir.

25

()

2

Q

Let me direct your attention to the mid-morning

51

1 residence of the Willinghams?

A

Yes.

3

Q

Can you tell us where the Willingham house is

4 or was with reference to your house?

5

A

Two doors down.

6

Q

All right.

7

A

East, I believe. I have a bad sense of

8 direction. Two doors down.

9 Q And did Cameron Todd Willingham live in that

10 house for a period of time?

11

A

Yes.

12

Q

Did his wife, Stacy, live in that house?

13

A

Yes, she did.

14

Q And did the children Amber, Carman and Cameron

15

also live in that house?

16

A

Yes, they did.

17

Q

Let me ask you first: How long have you lived

18 where you do, Mrs. Barbe?

19

A

I have lived at 1205 for 15 years.

20

Q

So, you lived there back on December the 23rd

21 of last year; is that correct?

22

A

Yes, sir.

23

Q

Do you have a recollection of that date, ma'am?

24

A

Very well.

25

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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hours of that date. And let me ask you what you were

doing around 10:00 o'clock in the morning?

A

Well, I was babysitting. I was in the living

7

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room, the den.

Q

Does that time, 10:00 o'clock, stick in your

6 mind for any particular reason?

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A

Yes, because my two youngest daughters, and

they had two sleep-overs, was in the back room -- had been

in the back room playing. They come in and wanted to go

out on the back padio because they was bored.

When they come into the den, it was 10:00 o'clock.

Bob Barker was coming on, "The Price is Right," and I

looked up at the clock. I told them, I said, "You can

stay out there just a little while," because it was cool.

Q Can you tell us what, if anything, unusual

happened at that point or shortly after that time?

A

Well, Buffy, my youngest one

Q

How old is she?

A

Eleven.

Q

Okay.

A

They were outside playing. They had been out

there, I guess, maybe ten minutes whenever she come

running through the back door and screamed that Sheila's

house was on fire.

Q

And what did you do at that point?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A

I jumped up from the chair, and she was right

behind me because it's a long room, the den area and

7 correct?

6

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to us.

3 dining room is together and she was right behind me; and

23

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4 We hit the screen door about the same time, and I just run

5 out the front door.

Q

She said Sheila's house was on fire; is that

A

Yes.

Q

Who is that?

A

Mrs. Daniels, sir, that lives right next door

that correct?

Q

In fact, her house was not on fire, though; is

Q

A

A

That's right.

At what point did you find that out?

When We got out to the front of the house, when

we opened the front door.

A

Q

out?

A

Q

Q

Did you go out the front door in a hurry?

Yes, in a run.

Would you say you banged the door on the way

Yes, it was a screen door. Yes, it banged.

Can you tell us what you first saw when you

went out that door, when you ran out that door?

A

As soon as we got out the front door, I just

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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immediately looked and Cameron was on the front porch

screaming, had started screaming whenever we come outside.

Q

It that the same Cameron Todd Willingham

04

present here in the courtroom today?

A

Yes, sir.

MR. JACKSON: I would ask the record

reflect the witness has identified the defendant.

THE COURT: Record will so reflect.

BY MR. JACKSON:

Q

Let me ask you something, Mrs. Barbe: Had you

heard any calls or screams from Mr. Willingham before you

ran out the front door?

A

No, sir.

Q

Can you describe then what you saw when you ran

out the front door?

A

He was on the front porch and he had both arms

crossed like this and he was crouched down screaming,

hollering.

Q

Okay. When did he start screaming?

A

When we come outside.

Q

Okay. So he had not been screaming before that

point?

A

I had not heard any screams, and my daughter --

two daughter's and their two friends were in the backyard,

and they heard no screaming. Until she run -- we went out

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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in the front yard, we didn't hearing any hollering.

Q

When you say he was crouched down, where was he

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crouched down?

A

In front of his front door, facing his front

5 door on his front porch?

6 Was the house engulfed in flames at that point?

Q
A
Q
for me?
A
Q
A 8 Could you describe the condition of the house

There was smoke coming out.

What did the smoke look like?

It wasn't real dark at that point. It was

coming out the -- of course, whenever I looked over there,

I was facing, you know, the side and the porch. It was

coming out the front windows and the front door and the

side windows of the front room. And it was coming down

low. It wasn't a high smoke. It was low.

Q

Coming from a low point in the house?

A

Uh-huh.

Q

At that point did you determine whether Mr.

Willingham was injured or not?

A

Not at that time. I didn't -- all he did was

holler that, you know, the house was on fire and that the

babies was in the houser and my kids, the three girls

were, you know, was out there. Then I told them, I said,

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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"You stay here." I turned back around to go into the

house when I realized that the phone wasn't working, and I

3 just told mother, I said, "The babies are in the house.

4 The house is on fire." I turned back around, just ran

5 outside, started running.

6

Q

Let me back up a little bit. Before we go

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7 further, based on your observation, did Mr. Willingham

8 appear to be overcome by smoke, or was he coughing at that

9 point?

A

Well, I wasn't up close to him. I didn't see

him coughing. He was hollering.

Q

Okay. Tell us what you did next.

A

I ran back out the front door, told the kids to

stay in the yard, stay there until I got back. I ran down

the street until I found somebody to call 911.

Q Who did you finally find to call?

A It was on the next block about three.doors

down. I think they was finally -- they said they called.

So I don't know what call that was that come into it

but

Q

But how long would you estimate it took you to

go down to the neighbor's house to call 911?

A

Well four, five, six minutes.

Q

Is that the time it would have taken you to go,

or to go and come back?

SHERRY D. DEAREN, 210 WESTWOOD COURT f DUNCANVILLE., TX 75116

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n A Go and come back, yes. I was -- I've lost some

weight. I've lost about 80 pounds. So, you know, it's

harder to run and get somewhere when you are real heavy,

you know, but I was going as fast I could and I was real

upset, too, you ~now, and everybody around our house, our

neighborhood, they were -- they all work or gone. You

know, it was down the street before I could find anybody

to call.

Q Tell us what you did when you got back to the

house that was on fire?

A As soon as I ran back up to our house, Cameron

ran and met me about where my fence was and --

Q What did he do or say at that point?

A I asked him where the babies was. I tried to

get him to come into my house because I didn't know -- I

know when you are in shock and stuff, it can be critical.

I didn't know how badly he was hurt or anything; and he

was hysterical, hollering and all. I tried to ask him

where the kids was and to get him to come in my house

because I didn't know, you know, how bad it was, how badly

hurt he was.

Q What was the condition of the house next door

at that time?

A Still a lot of smoke coming out, just the

front.

57

SHERRY D. DEAREN, 210 viESTWOOD COURT, DUNCANVILLE, TX 75116

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house?

A I was hysterical. I was -- I got three

daughters myself.

Q Did you or anybody else ask Cameron to go back

in the house or get the babies?

A My daughter, that's all they were hollering.

That's all they were hollering, screaming, "Go back in and

get them."

Q Did he make any response?

A No.

Q Did he go in the house with you?

A Did he go in my house? No, sir, I could not

get him to.

Q What did he do?

A Well, I asked him, I said, "Where are the

babies?" He said that Amber had woke him up, and the

house was full of smoke. She jumped off the bed. He

couldn't find her, and he run out.

Q Did he say where he ran out?

A Run out back is what he told me, ran out back.

Q He told you he ran out the back?

A Out back.

, Q Okay. Tell us what happened next, Mrs, Barbe?

A Well, the house was still smoking bad and my

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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(') oldest daughter was out screaming for him to go back in,

and he had gone back over to the house several times. We

couldn't get him to do anything, couldn't get him to go in

the house or anything. The fire truck still wasn't there.

Q Was the back of his house involved in any

flames or smoke?

A No, sir.

Q Just the front?

A That's all I could see coming out the front

room and the front door.

Q All right. I want you to continue in

chronological order just as you remember then you couldn't

get him to go back in the house?

A So Mr. Long down the street, the other end of

the street, had heard all the hollering and stuff. I seen

him come out in the middle of the street, and he run down

there and talked to Cameron, and it was about that time, I

think, that the house erupted in fire. It blew up, blew

out. I was -- I had been talking to him whenever I seen

that, you know. I couldn't tell where the kids was when

me and my oldest daughter -- I was in Mrs. Daniels' yard.

She was in the street, and we started running back up

toward the house when it blew up.

Q Why were you running back toward the house?

A Well, I was going to try to see if I could get

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SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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I didn't know the kids room had been moved. I still

thought that their room was across, and that was the

living room where all the flames was. I didn't know they

had moved their ·rooms.

Then, let's see, when it blew up, of course, I

knew there wasn't anything we could do. It was just, you

know, it was totally engulfed in that front room and --

Q You understood that you could not get in the

house at that point when the fire actually broke out?

A No. The heat was so intense. ~ just -- I was

in the middle of Mrs. Daniels' yard, it just met me.

Q Just to clear it up, where is Mrs. Daniels'

house?

A In the middle of our houses.

Q Mrs. Daniels' house is between your house and

Willingham house, right?

A Right.

Q All right. Mrs. Barbe, tell us what you

remember after the fire ignited in flames?

A Well, Cameron hollered about his car; and he

run and pushed it back.

Q Did he start the car up?

A No. He pushed it back. I guess you have to

put it out of gear to push it back. He pushed it back

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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maybe five or eight feet, not far. It was up by the tree right by the house. He pushed it back down in the driveway.

Q He was concerned about his car?

A Well, he pushed it back.

Q Did he ever go back in the house at any time

you were present before the fire broke out?

A No.

Q Can you tell us how Cameron Willingham was

dressed during these events?

A He had on a pair of britches. That's all.

Q Did he have on any shoes?

A No, sir.

Q No shirt?

A No.

Q No socks?

A No socks.

Q Did he have any injuries to his feet?

A No.

Q Did you have an opportunity to look at him to

see later to see if he had any significant injuries?

A I had my arms around him one time trying

whenever I was trying to get him into the house and to find out where the kids was, and his hands had black all on his arms and some on his back and his eye lashes and.

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SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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the top of his hair was singed was all that I seen. I

couldn't tell. You know, I couldn't tell.

Did he have any actual burns that you could

Q
tell?
A
Q
car?
A I didn't see any, but his arms was black.

What did Todd Willingham do afte~ he moved his

He went across and sat in front of Mrs.

Arnett's house right across the street from their house.

That was about the time that the ambulances and fire

trucks and police cars was all pulling up out there.

Q Do you have any idea how long it was from the

time Buffy first told you about the smoke and you ran out

in the yard until the time the fire actually broke out?

A Well, I would say it wasn't any more than ten

minutes, if they were out there that long; and I think the

fire trucks got there at 10:26.

Q What did you do at that time, Mrs. Barbe?

A When fire trucks got there?

A Yes, ma'am.

Q Well, I was hysterical and we finally got two

paramedics to get Cameron, and they couldn't get him to

the ambulance. He went and sat on the back of the big

fire truck that was right in front of their house and --

Q That was after he moved the car?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A Q A

This was when the first trucks got there. Okay.

And they was taking care of him, and they was

trying to put out the fire.

Q

Were you there when the defendant, Mr.

oj

6 Willingham, was taken to the hospital?

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A

Yes, sir.

Q

When was the next time you saw him or came in

contact with him after that?

A

The next morning I seen him.

Was there anything that drew your attention to

Q

him the next morning?

Well, it was

I don't really know what time

A

it was that morning, but I was in the kitchen and I was baking and, you know what boom boxes are? I don't know if that's the correct term for them, but any how, they go down the street all the time with these, kids, with these boom boxes.

Talking about a big radio?

Q A A

Yes, sir.

And I was in there, I just thought one of the

cars or something was -- well, it just kept getting louder and louder and I walked out of my kitchen, down into the den and you could feel the vibration of it coming off my walls, and I walked to the front door and looked out and

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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-.-.~- ... " ... - .. --- there were some people oVer at the house in front of the

house.

Q The burned house?

A Yes.

Q This was the next morning; is that correct?

A Yes, sir.

Q Who was there?

A Cameron was there. I don't know who all was

there. There was a small pick-up and another car out

front. The little pick-up was parked partly in Sheila's

driveway and partly in their driveway across it, and

that's where the music was coming from, was from the

little pick-up.

Q I may have asked you that, but the defendant,

Todd Willingham, was there?
A Yes, he was.
Q What was he doing?
A They were out in the front yard talking.
Q Mrs. Barbe, did you have an opportuntiy to see
how they acted, what their attitude was like? A They.were just all around talking in the front

yard and wheneVer they seen me and the girls come outside

they

MR. MARTIN: We object to this as

nonresponsive.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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--.~.-.- MR. JACKSON: Let me back up and ask a

question.

BY MR. JACKSON:

Q What happened when they saw you come out?

A When we went outside, they turned off the jam

box or boom box.

Q Did the party get quieter after that?

MR. MARTIN: We object to that as a

misstatement of the testimony and assumption of facts not

in evidence.

THE COURT: I sustain the objection.

Restate your question, Mr. Jackson.

BY MR. JACKSON:

Q Did the gathering get quieter after that, after

they saw you?

A Yes, the music stopped.

Q Do you have any idea how long that went on out

there that morning?

A How long they stayed?

Q Yes, ma'am.

A I didn't stay outside long, but the kids stayed

outside. Cameron and some other people was with him.

They was getting stuff out of the house.

Q Did you have an opportunity to see Cameron

later on that day?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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- ... -.-~ A That night.

Q Can you tell us how that came about?

A Well, Channel 5 come over to the house, I

think, it was right at 6:00 o'clock that night. I seen them drive up, and it wasn't long afterwards that Stacy and Todd drove up, and they talked to Channel 5.

Q Did Mr. and Mrs. Willingham come to your house

at any time during that period of time?

A After they got through with talking to them,

they walked over.

Q Did you have an opportunity to talk with Mr.

Will~ngham or Mrs. Willingham at that time, that point?

A Yes, sir. They come in, and that's the first

time I had seen Stacy since it had happened.

Q What was Todd talking about to you at that

time?

A Stacy sat down in the chair. I was trying to

talk to her. She was crying, and I was trying to talk to StacYi and Cameron was talking to us about the neighbor who had took up some money and what they had went and bought for Amber, what they had bought for Amber, and he told her that when I ran down the street was when he went back into the house.

Q You overheard Todd Willingham tell his wife

that he went back into the house?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A Q

Yes, sir.

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3 back in that house?

To your knowledge did Todd Willingham ever go

A

Not while I was out there.

Do you have any reason to believe he ever went

Q

6 back in the house?

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MR. MARTIN: We object to that as calling

on the witness to speculate, Your Honor.

THE COURT: Restate your question, Mr.

Jackson.

BY MR. JACKSON:

Q You've had an opportunity to speak with your

daughters, I assume, about what happened when they were there?

A Q

Yes, sir.

Did it surprise you that Todd Willingham told

anyone he went back in the house?

A

Yes, it did. My husband asked me why I didn't

say something. I told him I couldn't.

Q A

Why couldn't you?

Because Stacy had just lost them three babies.

How could you tell somebody. She was devastated.

Q

that?

A

What was your reaction to hearing Todd say

I couldn't believe he said it.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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_,"_,_ ..• __ ._-. MR. JACKSON: Pass the witness.

CROSS-EXAMINATION

BY MR. HARTIN:

Q Mrs. Barbe, is it fair to say that during these

events you described that you were hysterical?

A Yes, I was hysterical.

Q As was everybody else there?

A Yeah.

Q And it gets -- is that the first time you've

ever been that close to a house on fire; is that correct?

A That close, yes.

Q And the first time you've ever been present

when a house burned belonging to someone you knew?

A Yes.

Q Do you know what Mr. Willingham's wife calls

him?

A I guess his name.

Q Do you know, though? That's my question.

A No, sir. I've always called him Ca~eron. I

don't know.

Q But you don't know what Stacy referred to him

as far as what she used for him?

A No.

Q You have not been in their home? ~'ve been in

that home but not since they

I've been in that

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q Would not consider yourself a close family

friend of theirs?

A No, sir.

Q Let's try to get some perspective on what you

are telling us here. If this is the Willingham home, Mrs.

Daniels lives here and your home is here?

A Yes.

Q Your van is parked out here?

A Yes.

Q And there is a fence here; is that correct?

A And one in between my house and Mrs. Daniels

house.

Q And the fence here, does it go behind your

house?

A Yes, sir.

Q As well as behind the Willingham house?

A I believe it does. I know it does Sheila's. I

don't know if it does theirs or not.

Q You told us that at some point during these

events that Todd's car was parked -- was it parked here,

about the corner of the house?

A The corner of the house. There's a tree that's

about where they -- it was parked right by the tree. It's

a small --

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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-,.--,-- Q Front porch is out here, isn't it?

A Uh-huh.

Q And there's a tree here?

A Well, it's up by the porc~.

Q Okay.

A Right next, right up next to the porch.

Q The car was parked about here?

A Uh-huh.

Q It was very close to the burning house?

A Uh-huh.

Q Originally? Is that right?

A It was up by the porch, yes.

Q Just like a foot or two from the porch,

probably?

~1Tell, it was --

A
Q
A
tree is.
Q
A
Q Very close at any rate?

-- by the tree. I don't know how close the

It's just right there.

Then Todd pushed the car back this way?

Yes.

And when this happened, the house was burning,

it was smoking; you could see it smoke; you knew it was on

fire?

A You could see the smoke, yes.

Q Now, let me draw the front of the Willingham's

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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-- .. --_----_ home here.

(Attorney drawing on board)

BY MR. MARTIN:

Q Is that pretty much the way it is?

A Uh-huh.

Q This is the front door here?

A Yeah.

Q And there is a window here, is there not?

A Is that facing the outside?

Q Yes. The street is out here.

A Yes.

Q In other words, this is the front porch here .

It's raised a foot or two out of the ground? You have to

go up the steps to get on it?

A Yes.

Q And there are two windows and the front door on

the front of the house on this side?

A And two on the side.

Q Okay. There's two on this side facing your

house?

A Uh-huh, yes, sir.

Q And when you first came out of your house over

here, you ran around here?

Il

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Yes.

Q

That's where you stopped; is that correct?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A

Uh-huh.

Q

At that point you saw Todd on the front porch

of his house?

A Uh-huh.

Q And he was about here?

A Somewhere in that, right in the area of the

front door.

Q He was crouched down?

A Yes.

Q Had his arms folded across his chest?

A Yes.

Q You thought he had been injured? He looked

like he had been injured?

A (Nodding head affirmatively)

Q Was that your first thought?

A Yes. The house was on fire. I mean, the house

was smoking. He was hollering. He was screaming the

babies was in there.

Q You saw smoke coming out from around the front

window?

A Come out the front door, down the windows, on

the side windows.

Q Smoke was coming out the side of the house,

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And so you saw smoke coming out the front door?

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lover here, right?

A

Uh-huh.

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Q

Smoke was coming out the front door?

4

A

Uh-huh.

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Q

But you don't know whether the front door was

6 opened or closed?

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No, because I didn't run over there.

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Q

You never got over here in front of the house?

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A

My kids did. I did not.

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Q

But my question to you is that you don't know

11 whether the front door was open or closed at this time?

A

No. The girls said it was open.

MR. MARTIN: I object to that. That's

not responsive and hearsay.

THE COURT: I sustain the objection.

MR. MARTIN: Request the jury to be

17 instructed to disregard.

THE COURT: The jury panel is so

19 instructed.

20 BY MR. MARTIN:

Q

Mrs. Barbe, I am interested in only what you

22 know, okay?

A

Uh-huh.

Q

If you will, just answer those questions.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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--.-----, ..... --- A Uh-huh.

Q But don't know whether it was open or shut?

A Right.

Q Now, is it fair to say that this area here was

smoking?

A Yes it was smoking.

Q Would you describe it as being filled with

smoke?

A When I first come out, it was s~oking; but it

wasn't a black smoke.

Q Like a gray smoke?

A It was grayish, but it had not gotten black

like it did right before it busted into flames.

Q But you did not, at any time when you w~re out

there ,before it burst into flames, see any actual fire on

the front of the house, did you?

A I didn't see any at first. I just seen the

smoke.

Q And that was just coming out of the windows and

the doors as I've indicated?
A Yes.
Q But no fire?
A Huh-uh.
Q And you didn't see any flames until, as you,
described, the house burst into flames? SHERRY D. DEAR EN , 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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-.-'~----."-'-' A That's right.

Q And that was about two minutes before the fire

department arrived?

A Yes, sir, approximately.

Q And then at that time you described something

similar to an explosion?

A Well, when we was running back up toward the

house, it just busted out.

Q Did the windows break out?

A The windows, the electricity started crackling

and popping, and the top of the -- well, I was facing the

side of the house, and it ju~t blew out. The flames just

blew out.

Q Did you first see flames coming out of windows?

A Well, I was -- yeah, I seen them coming out of

windows and the top. You know, I mean, it's just busted

out.

Q Yes, ma'am.

A All the windows and the front room was

engulfed. I guess what I'm trying to say, it was just

engulfed.

Q So, the flames you saw when you did see them

came out of these windows and these windows over here on

the side?

A Yes, sir. I was facing the side windows; and,

75

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE! TX 75116

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you know, that's what I remember seeing. It's just coming

up at me.

Q Yes, ma'am. And where were you when this

happened?

A I was in the middle of Mrs. Daniels' yard and

Brandy was in the middle of the street. We was running up

back toward the house.

Q Okay. Is it fair to say that at any time

during all of this, did you ever come into the middle of

the yard or in front of the house?

A I did not.

Q Did you stay beside the house; is that correct?

A Yes.

Q So, what we have is the benefit of your vantage

point from about here; is that right?

A I was in Sheila's yard, about the middle of

Sheila's yard.

Q So, the events that you described were viewed

from over here; is that correct?

A About there.

Q Now when your daughter, Buffy, ran in the back

door and ran through the house here, you went out the

front door initially went to about here, you say?

A That's where.

Q Then Todd, was he screaming, "My babies are

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A Yes, that's what he was hollering: "My babies

are burning."

Q He appeared to be hysterical?

A Yes.

Q Do he tell you to dial 911?

A Yes. He hold me to go call 911.

Q That's why you went to do it?

A Yes.

Q It was Todd that asked you to do so, scream it,

rather?

A Uh-huh.

Q And you were in such a state of confusion that

first you ran back into your, own house?

A Yes, I forgot the telephone, you know, wasn't

working.

Q How long had it not been working?

A That morning it was working. You couldn't

hear. There was water in the lines. It had rained so

much.

Q You had forgotten that in your state of

excitement?

A Yeah. I just, you know

Q -- ran into the house. Did you actually go to

your phone and pick it up?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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------ A Whenever I got in front door, mother said, "The

phone is not working."

Q Your mother's there with you?

A She had broken her f60t.

Q You had been taking care of her?

A Yes.

Q How many children did you have in the house at

that time?

A We had four sleep-overs and keep five. There

was nine to ten kids there at the house.

Q And did all ten of those children, had they

been there all night?

A
Q
A
Q
A
Q
home?
A
Q No. Four sleep-overs.

And when did the other six arrive?

That morning.

About what time?

About 7:00, 8:00.

Are those children that you care for in your

Uh-huh, some of them.

So, at the time that all this happened, you had

ten children in the home with you?

A Uh-huh.

Q Your mother with a broken foot?

A Uh-huh, that's right.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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- •. _._._,._-_ ... _ Q Now, after you went to this location and Todd

was on the porch, he asked you to call 911 --

A Uh-huh.

Q -- did he not? Then you ran to your hOUSe,

forgot your phone was out of order, then you came back and

ran this way down the street?

A That's right.

Q You went down there about a block or so?

A No. Let's See, in the middle of the next block

is where they finally called.

Q And were you just running down the street

screaming for someone to call 911?

A Yes. EVerybody works around there. They are

gone.

Q Yes, ma'am.

A And several people, several of them dOesn't

haVe phones so

Q So, finally

A Kim came out of'their house. She hollered and

asked me what was happening. I told her, I said, "The

hOUSe up here is burning. The babieS are in there."

Q Then after you had done that, you ran back to

about here, the middle of Sheila's yard?

A Yes, the fence between my yard. The fenCe.

Q Ran oVer here. Is that about where you

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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--- .. -.~- remained for the duration?

A You got the wrong fence. My fence, mine and

Sheila's fence. That's where Cameron run down and met me

whenever I come back up the street.

Q
A
Q
A
Q
here?
A
Q Over to your fence?

Yeah.

Here?

Uh-huh.

And Cameron ran from the porch and met you

Uh-huh.

And is that where you tried to talk him into

going back into your house?

A
Q
A
Q
A
Q
that area? Yes, it is.

And he wouldn't do so?

No.

He was hysterical from all --

Yes, he was.

He went back into his front yard, somewhere in

A Several times.

80

[

-

Q Running back and forth?

A Yes.

Q Obviously excited?

A Yes.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q About as excited or more so than you were?

A Well, yeah, I would say we was both excited.

Q Now, you didn't go into the burning house,

obviously?

A No, sir. It looked to you as if you could not

get in. It was burning.

A Whenever the flames burst out? Is that what

you are talking about or at any time?

A Yeah, it was smoking bad.

Q All right. Smoking bad the first time you saw

it?

A No. When 'I first come out, it wasn't then. I

mean, it was smoking; but it was geting worse as the time went on. But, I mean, we are talking about, like, ten minutes here, in ten minutes' time.

Q Okay. You think the whole affair from the time

you went outside until when was about ten minutes?

, A Well, I would say Buffy come in maybe by ten

after 10:00. She wasn't out there maybe ten minutes whenever, you know, she came back through there; and they got there at 10:26. That's what? 13, 14 minutes?

Q And it was your daughter who was in your back

door that first noticed the smoke?

A Yes.

Q Do you remember what she said when she came

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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running through the house?

A

Yes, sir.

Q

"Sheila's house is on fire"?

A

Uh-huh.

Q

And who was caring for these ten children in

6 your home while this was happening?

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A

My daughter, Brandy, which is 17, and my mother

and me. Four of them was sleep-overs. They were big

kids.

Q

Now, you talked about the next morning you

heard a loud radio in the yard?

A

Yes, sir.

Q

And was that coming from somebody's car?

A

Little truck.

Q

Little pick-up?

A

Uh-huh.

Q

It was not Todd's pick-up, though, as far as

you know?

A

No. His car was over in the yard.

Q

Okay. It was somebody else's pick-up playing

the music; is that correct?

A Uh-huh, right.

MR. MARTIN: Pass the witness.

REDIRECT EXAMINATION

BY MR. JACKSON:

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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n Q Mrs. Barbe, you've talked about electricity

popping. At what point did you first hear the electricity

popping?

A When it engulfed the house, when the fire broke

out.

Q When the flames engulfed the house?

A Yes. It started, you know, cracking and

sparking, all that.

Q Had you heard any electrical noises before

that?

A No.

Q I will show you what's been marked State's

Exhibit No.1. Just to get an accurate photograph of what

the house looked like, would you take a look at that and

identify it for me, if you can?

A That's Cameron and Stacy's house.

Q Is that an accurate representat~on of the house

that you testified about that was smoking and caught fire?

A Yes, sir.

MR. JACKSON: I offer this as State's

Exhibit 1.

MR. MARTIN: No objection.

THE COURT: It's admitted.

BY MR. JACKSON:

Q When you had an opportunity to see Cameron the

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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::l next day, could you tell that he had no serious injuries?

A I didn't see any.

Q Did he act like he had any serious injuries?

A No.

Q Have any bandages or anything like that at any

point on his body?

A No. He had on a sweater, britches and shoes

and socks.

Q Do you have any idea how long that house had

been on fire when Buffy first smelled smoke and came into

the house?

A She went outside at 10:00 o'clock, and she

smelled the smoke when she went outside, first went

outside.

Q At 10:00 o'clock?

A Yes, sir. But she thought -- what she told me,

I know, which is hearsay. I won't --

Q Do you know it was 10:00 o'clock when she went

outside.

A It was 10:00 o'clock.

Q It was about ten minutes after 10:00 o'clock,

then, when you first came out through the door, at least?

A Yeah. I don't know if they had really been out

there that long before she looked up. You know how kids

are when they get to playing. They don't think about

SHERRY D. DEAREN, 210 vlESTlJOOD COURT, DUNCANVILLE, TX 75116

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.~.--. anything, and she didn't bother even to look until she --

Q You had not heard a cry for help during that

time period?

A No, sir, I did not.

Q You did not hear a cry for help until you

hurriedly went out the front door?

A Until we went out the screen door, yes, sir.

Q Was Stacy Willingham, the wife, at home at this

time to your knowledge?

A No, sir, she wasn't.

MR. JACKSON: Pass the witness.

RECROSS-EXAMINATION

BY MR. MARTIN:

Q Now, Mrs. Barbe, before you went outside, you

were in your home watching television with ten children?

A Uh-huh, six.

Q six children?

A There was four outside.

Q And you believe that Buffy, your youngest

daughter, had been outside smelling smoke for about ten

minutes before she came in and alarmed you?

A Uh-huh.

MR. MARTIN: Pass the witness.

MR. JACKSON: I have no further

questions.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILL_E, TX 75116

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()
----.--~-. THE COURT: You may step down.

Call your next witness, Mr. Jackson.

MR. JACKSON: State calls Brandy Barbe.

THE COURT: Come forward, please.

You were sworn earlier?

THE WITNESS: Yes.

THE COURT: Take your seat in the witness

chair.

MR. JACKSON: May I proceed, Your Honor?

THE COURT: Yes, sir, you may.

BRANDY BARBE,

After having been called as a witness by the State and

after having been first duly sworn to tell the truth, the

whole truth, and nothing but the truth, the witness

testified on her oath as follows:

DIRECT EXAMINATION

BY MR. JACKSON:

Q Would you state your name for the record,

please?

A Brandy Barbe.

Q And where do you live?

A At 1205 West 11th.

Q About how long have you lived there?

A About 12 or 13 years.

Q I believe you are the daughter of Diane Barbe;

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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~'-"'--'-"- is that correct?

A Uh-huh.

Q You were living on 11th Avenue, I believe, back

in December of last year; is that correct?

A Uh-huh.

Q Let me direct your attention to the 23rd of

December of last year, two days before Christmas. Do you

remember that day?

A Yes, sir.

Q Let me direct your attehtion to the mid-morning

hours of that day. Can you tell me, in your own words,

what you remember about the events that took place shortly

after 10:00 o'clock that morning?

A After 10:00? Well, I heard my mom come back in

the house screaming that there was a fire and that the

babies were burning up. I had just gotten out of the

shower. I threw something on, and I ran out there in the

street.

Q Can you tell me what you saw when you got out

in the street?

A Todd was standing in the yard when I got out

there.

Q Can you tell us or describe for us what part of

the yard he was standing in?

A He was standing by a tree. It was right by the

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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driveway.

Q

And what was he doing when you first saw him?

88

A

He was screaming that there was a fire, that

his babies were burning and for someone to help him, to

call 911.

Q

What did you do at that point?

A

I was s~reaming for him to go back in the house

and get the babies or tell somebody where the babies were,

and my little sister was with me. I told her to go to the

house next to his and call 911.

Q Did he ever make an attempt to go back in the
house when you asked him to go back in?
A Not that I seen.
Q Did he ever go back or attempt to go back in
the house while you were there? A

Not that I seen.

Q

Can you describe what happened after you asked

him to go back in the house?

A

Well, he was screaming about the car a little

while later and told someone to help him move it out of

the driveway. The next thing I seen, he went across the

street and sat down on the curb.

Q

Were you there present while your mother was

going down the street to try to get help?

A

Uh-huh. That's when I run down towards his

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q

Can you tell us how you happened to go to the

1 house.

Q

All right. And about how long did you stay

3 there outside the premises of his house?

4

A

I was there until the fire trucks got there.

5

Q

All right. And you, at no time, saw him try to

6 go back in the house?

7

A

No.

8

Q

Was he coughing during this time period?

9

A

No.

10

Q

Did you see him move his car?

11

A

Yes.

12

Q

Did he seem concerned about his car?

13

A

Yes.

14 Q After the fire department got there, did he

15 try what did Todd Willingham do?

16 A Well, he was still screaming about the babies,

17 and by that time I had left.

18

Q

Were you acquainted with Cameron Todd

19 Willingham and his wife, Stacy?

20

A

Well, I knew that they lived next door. I

21 never really talked to them.

22

Q

Did you later have an opportunity to go to the

23 hospital?

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A

Yes.

89

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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hospital?

A Well, one of my friends, Stephanie, she babysat

on Tuesday nights with Amy O'Shay, and she was hysterical.

She couldn't believe the fire had happened and everything.

She asked me to take her out there. I took her out there.

Q What did you do when you got to the hospital?

A We found out where his room was and went up to

his room.

Q Did you have an opportunity to see him when you

got to the room?

A Yes.

Q Can you describe him when you walked into the

room?

A Well, when we first walked in, he was on the

phone talking about caskets and --

Q For the babies?

A Uh-huh, I believe so.

Q You overheard him making funeral arrangements?

A Well, that's what it sounded like.

Q This was how long after the fire?

A It was probably about 2:30 or 3:00 that day_

Q Fire was at 10:10, and this was about 2:30?

A Uh-huh.

Q What did he look like. Did he have any

injuries?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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A

We went to Jack in the Box and got some food

A

Well, his eye lashes and ey~ brows was singed,

2

but other than that, I didn't see anything wrong with him.

3

Q

Did he make any request of you or Stephanie at

4 this time?

5

A

Well, we went downstairs, and then Stephanie

6 said, "Well, let me call back up there to see if they want

7 anything to eat." When she called up there, they wanted

8 us to go

9

MR. MARTIN: We object to hearsay or

10 speculation if she wasn't the party to the phone call, and

11 she obviously wasn't.

12

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15

MR. JACKSON: I will rephrase my

question.

THE COURT: All right, sir.

MR. JACKSON: Based on a request from Mr.

16 Willingham's room, what did you do at that point?

17

MR. MARTIN: Your Honor, we object to

18 that as getting hearsay through the back door. It's

19 assuming facts not in evidence.

20

MR. JACKSON: I'm not asking for any

21 hearsay.

22

THE COURT: Overrule the objection.

23 BY MR. JACKSON:

24

25

Q

What did you do at that point?

91

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

1 and then we came back to the hospital and I dropped

3 not go back in.

8 even think about eating after his babies had just burned

2

4

5

6

7

Stephanie off and she took the food up to the room. I did

Q

Were you upset at this point?

A

Yes, I was upset.

Q

Why were you upset?

A

Well, I couldn't believe that somebody would

9 up.

10 Did Todd make any comments about the babies?

13

14

15

16

Q
A
Q
A
Q
him? 11 Like that day?

12 While you were there at the hospital?

I didn't really talk to him.

Did he seem overcome with emotion when you saw

MR. MARTIN: We object to that as

17 leading.

18

MR. JACKSON: It's an observation, Your

19 Honor.

20

21

22

THE COURT: I overrule the objection.

MR. JACKSON: You can answer.

THE WITNESS: What was the question?

23 BY MR. JACKSON:

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Q

Was he upset in the room when you saw him?

A

He wasn't crying or anything.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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MR. JACKSON: Pass the witness.

CROSS-EXAMINATION

BY MR. MARTIN:
Q Miss Barbe,
in a fire, have you?
A No.
Q Never lost
accident or death? you have never lost a family member

a close family member, have you, to

A

I lost my grandmother, my great grandmother.

Q

But you weren't in --

A

I was small. I hardly remember it.

Q

So, my point is that this is the first time

you've ever been around someone who has lost children in a

fire or an accident; isn't that correct?

A

Yes.

Q

And so you wouldn't know typically how people

would respond to that, would you?

A

No.

Q

You were not a party to the conversation that

Amy O'Shay had with Todd in the hospital when she talked

to Todd, were you?

A

No.

Q

Don't know what was said during that

conversation?

A

No.

SHERRY D. DEAREN, 210 'WESTWOOD COURT, DUNCANVILLE, TX 75116

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driveway.

Q

And what was he doing when you first saw him?

88

A

He was screaming that there was a fire, that

his babies were burning and for someone to help him, to

call 911.

Q

What did you do at that point?

A

I was s~reaming for him to go back in the house

and get the babies or tell somebody where the babies were,

and my little sister was with me. I told her to go to the

house next to his and call 911.

Q Did he ever make an attempt to go back in the
house when you asked him to go back in?
A Not that I seen.
Q Did he ever go back or attempt to go back in
the house while you were there? A

Not that I seen.

Q

Can you describe what happened after you asked

him to go back in the house?

A

Well, he was screaming about the car a little

while later and told someone to help him move it out of

the driveway. The next thing I seen, he went across the

street and sat down on the curb.

Q

Were you there present while your mother was

going down the street to try to get help?

A

Uh-huh. That's when I run down towards his

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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Q

Can you tell us how you happened to go to the

1 house.

Q

All right. And about how long did you stay

3 there outside the premises of his house?

4

A

I was there until the fire trucks got there.

5

Q

All right. And you, at no time, saw him try to

6 go back in the house?

7

A

No.

8

Q

Was he coughing during this time period?

9

A

No.

10

Q

Did you see him move his car?

11

A

Yes.

12

Q

Did he seem concerned about his car?

13

A

Yes.

14 Q After the fire department got there, did he

15 try what did Todd Willingham do?

16 A Well, he was still screaming about the babies,

17 and by that time I had left.

18

Q

Were you acquainted with Cameron Todd

19 Willingham and his wife, Stacy?

20

A

Well, I knew that they lived next door. I

21 never really talked to them.

22

Q

Did you later have an opportunity to go to the

23 hospital?

24

25

A

Yes.

89

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

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','c_ , >:::r'-~~""~::::-:·.~;-:.:~·;:_;-;l~,:i~" 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lWIPRiiJ!QilfI'CSIJ)FR;QM THE HOtQIN·ii-sOF THE TEXASST.4TEARCiiiv#s

hospital?

A Well, one of my friends, Stephanie, she babysat

on Tuesday nights with Amy O'Shay, and she was hysterical.

She couldn't believe the fire had happened and everything.

She asked me to take her out there. I took her out there.

Q What did you do when you got to the hospital?

A We found out where his room was and went up to

his room.

Q Did you have an opportunity to see him when you

got to the room?

A Yes.

Q Can you describe him when you walked into the

room?

A Well, when we first walked in, he was on the

phone talking about caskets and --

Q For the babies?

A Uh-huh, I believe so.

Q You overheard him making funeral arrangements?

A Well, that's what it sounded like.

Q This was how long after the fire?

A It was probably about 2:30 or 3:00 that day_

Q Fire was at 10:10, and this was about 2:30?

A Uh-huh.

Q What did he look like. Did he have any

injuries?

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

l:)

n

1

A

We went to Jack in the Box and got some food

A

Well, his eye lashes and ey~ brows was singed,

2

but other than that, I didn't see anything wrong with him.

3

Q

Did he make any request of you or Stephanie at

4 this time?

5

A

Well, we went downstairs, and then Stephanie

6 said, "Well, let me call back up there to see if they want

7 anything to eat." When she called up there, they wanted

8 us to go

9

MR. MARTIN: We object to hearsay or

10 speculation if she wasn't the party to the phone call, and

11 she obviously wasn't.

12

13

14

15

MR. JACKSON: I will rephrase my

question.

THE COURT: All right, sir.

MR. JACKSON: Based on a request from Mr.

16 Willingham's room, what did you do at that point?

17

MR. MARTIN: Your Honor, we object to

18 that as getting hearsay through the back door. It's

19 assuming facts not in evidence.

20

MR. JACKSON: I'm not asking for any

21 hearsay.

22

THE COURT: Overrule the objection.

23 BY MR. JACKSON:

24

25

Q

What did you do at that point?

91

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

1 and then we came back to the hospital and I dropped

3 not go back in.

8 even think about eating after his babies had just burned

2

4

5

6

7

Stephanie off and she took the food up to the room. I did

Q

Were you upset at this point?

A

Yes, I was upset.

Q

Why were you upset?

A

Well, I couldn't believe that somebody would

9 up.

10 Did Todd make any comments about the babies?

13

14

15

16

Q
A
Q
A
Q
him? 11 Like that day?

12 While you were there at the hospital?

I didn't really talk to him.

Did he seem overcome with emotion when you saw

MR. MARTIN: We object to that as

17 leading.

18

MR. JACKSON: It's an observation, Your

19 Honor.

20

21

22

THE COURT: I overrule the objection.

MR. JACKSON: You can answer.

THE WITNESS: What was the question?

23 BY MR. JACKSON:

24

25

Q

Was he upset in the room when you saw him?

A

He wasn't crying or anything.

SHERRY D. DEAREN, 210 WESTWOOD COURT, DUNCANVILLE, TX 75116

C_J

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

"'0';" ~'~'·"-:"'~""':"";:.1 ;';'£:' -. " ," .:,- '"-.-_- ;'_ " . ,,' ': " _ ~?"~if,! .ElF c _. .. : T'-ifH~'~r~:~,' -}iF'Y,:;;;~-~J ,- '-l'J':!{-;; t1'., 4" '~~/~4i?"':·'··'t;;i,~t:-~~~';)i>~ :'i;)"<;: r;Jt:~.

~OD;rJCED FROM THE HOLDINGS OF THE TEXAS SJ:4 FE ltRCHJVES

1

2

3

4

5

6

7

8

9

93

MR. JACKSON: Pass the witness.

CROSS-EXAMINATION

BY MR. MARTIN:
Q Miss Barbe,
in a fire, have you?
A No.
Q Never lost
accident or death? you have never lost a family member

a close family member, have you, to

A

I lost my grandmother, my great grandmother.

Q

But you weren't in --

A

I was small. I hardly remember it.

Q

So, my point is that this is the first time

you've ever been around someone who has lost children in a

fire or an accident; isn't that correct?

A

Yes.

Q

And so you wouldn't know typically how people

would respond to that, would you?

A

No.

Q

You were not a party to the conversation that

Amy O'Shay had with Todd in the hospital when she talked

to Todd, were you?

A

No.

Q

Don't know what was said during that

conversation?

A

No.

SHERRY D. DEAREN, 210 'WESTWOOD COURT, DUNCANVILLE, TX 75116

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