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The State promptly provided discovery upon the Defendant's request. The
Defendant made a further request for additional discovery in the form of a letter itemizing
31 pieces of evidence. The State promptly provided the itemized request to the Cold Case
Unit of the Jackson Police Department. The Cold Case unit is currently searching for
these items per the Defendant's request. Further, the State has newly discovered evidence
that has led to a subsequent investigation. Attached is a transcript of the newly discovered
evidence, an eyewitness to the crime. The defense will be furnished newly discovered
While the Defendant is constantly requesting discovery from the State, the
pursuant to U.C.C.C. rule 9.04 of the Mississippi Rules of Discovery. The Defendant has
The Court does not need to enter an order compelling the State to provide
evidence until the Defendant provides its reciprocal discovery, and until the Jackson
Police Department and other agencies complete its investigation on the newly discovered
evidence.
••
1st
Respectfully submitted, this the ~ lay. of April, 2008.
7ZLe" t-J)_.
ROBERT SHULER SMITH
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~f _. _
CERTIFICATE OF SERVICE
I, Robert Shuler Smith, hereby certify that I have delivered via hand delivery, a
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APPEARANCES:
10
HONORABLE ROBERT SMITH
11 HONORABLE WINSTON THOMPSON
Office of the District Attorney
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DETECTIVE FELIX HODGE
13 DETECTIVE KENNETH WEST
Jackson Police Department
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1 STEPHAN HICKMAN,
3 as follows, to-wit:
11 Q. Murder?
12 A. Yes, sir.
14 A. Allison Kelly.
20 A. Yes, sir.
22 Attorney?
23 A. Yes, sir.
25 Yes, sir.
3
3 A. Yesr sir.
6 A. Yesr sir.
8 A. Yes, sir.
9 Q. Is that correct?
10 A. Yes, sir.
13 A. Yes, sir.
15 statements?
16 A.
18 statements?
19 A. NOr sir.
21 will?
22 A. Yes, sir.
25 correct?
4
1 A. No, sir.
4 correct?
5 A. Yes, sir.
8 Washington case.
14 Q. Is it Larry Nelson?
15 A. Yes, sir.
16 Q. A/k/a Chicago?
1 money.
2 Q. Who is he?
7 the time Frank Melton told him well, show me you don't
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So Frank Melton jumped in -- got us out of
18 Q. He who?
19 A. Robert Washington.
20 Q. Okay.
22 just went a few blocks and came back with Larry Nelson
2 again.
5 police cruiser.
20 we got out and got inside the pathway going toward the
24 leave. So --
1 Q. Who is they?
6 action because he got out the back seat after the door
8 off.
9 Q. Okay.
15 down.
for his service gun. And, you know, we saw the first
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19 pulling for his pants to get up. And then, you know, he
21 then
22 Q. Who?
1 Burton.
So at that time he shot two more times. Now,
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3 we didn't stay to see if he was hit or where he fell,
18 that Larry had helped Sherrod pull him and put him in
19 the trunk, and then, you know, they fled the scene of
24 to him.
9 Q. What scene?
2 Q. Bailey Avenue?
3 A. Yes, sir.
7 A. Yes, sir.
11 was involved in it, because, you know, not too far back
25 Q. He who?
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25 person that was really giving word was Howard that was
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19 the case. And you know, they would give him an update
2 You don't need to let the witness make it. Who the
4 world.
So after a while I contacted Paul. Paul
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6 couldn't be found so I was talking to his girlfriend,
12 door and didn't kill her. And I was like what you mean.
Now they're looking
13 He said he didn't kill the witness.
18 anything.
So behind that Paul gets caught, gets locked
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Shawn comes down to downtown to see about his
20 up.
He's
1 Shawn needs to leave, you know what I'm saying.
13 they were going to help him, but all the people were
24 A. Yeah, I have.
8 happen.
Now, as far as did someone verbally threaten
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10 me, no, they wouldn't do it because I got too many
A. Pertaining to as far as --
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Well, as relates to Burton, or did you
19 Q.
7 particular person?
9 Camcorder?
She said it's still the same way you left it. It
1 time.
11 Burton?
17 know.
20 A. No, sir.
23 A. No, sir.
25 A. No, sir.
18
8 Wallace--
10 Crockett?
13 people, you know, just around the hood. But now, in the
16 street.
5 this side they might have sold crack. Some people might
7 Blues or however.
11 this side and you got this side. At this point in time
16 us.
25 turned in. He will come back to the block and say here,
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6 off Wood Street. The S-1 boys, then they had the nine
7 o'clock posse, you know what I'm saying, from the north
9 alliance.
13 Not just, you know, well, you need to go sit down. They
20 you know, but several, you know what I'm saying, even
21 not just his involvement but, you know, but just his
24 here. Now you've got this side. sold up, you know what
25 I'm saying. Now we've got to get Aaron out the way and.
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4 over here out here in Georgetown and sell all the dope,
5 and you can handle that. But said, but you've got to
9 If Aaron get out the way they knew that Sherrod and them
11 really Sherrod Moore. And Frank wanted him out the way
15 You know, he can run that. So, they get Aaron out the
16 way, but they get Donnell to do it, you know what I'm
17 saying.
20 Wallace.
3 spot.
5 they know the game now with Frank Melton playing. Frank
15 where he can appoint now who he want, you know what I'm
16 saying.
8 (PAUSE IN PROCEEDINGS)
13 A. Yes, sir.
22 that at first.
24 know, they was like well, you know, Too Sweet was going
4 this forte, you know what I'm saying, this persona like,
6 beside, you know, the street and, you know, vote for
7 such and such and such. And, you know, it's like he
15 you know.
19 I was here.
1 now, he also said that, you know, Shawn was the next
7 you know, ask Frank Melton about what's going on. You
16 to happen.
3 Q. Meaning what?
10 to it, but they both were. And that was the only tie
11 that they had with Sherrod, you know what I'm saying.
12 They could offer him all these nice things, new Rolexes,
13 new herringbone, and you know, buy him new clothes and
7 because, you know, Frank made him mad. Like I'm not
12 you any thing, you know what I'm saying. If you want
16 him.
19 Melton was like, well, show me you don't mess with him
3 Q. Okay.
5 have people dead to the right, and you just let them go
9 A. Yes, sir.
12 A. Yes, sir.
13 Q. Truthfully?
14 A. Yes, sir.
17 notify you.
18 A. Yes, sir.
22 A. Yes, sir.
24 (STATEMENT ENDED)
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2 STATE OF MISSISSIPPI
3 COUNTY OF HINDS
17 March, 2008.
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