IN THE UNITED STATES DISTRICT COURT
                 FOR THE DISTRICT OF COLORADO
 
Criminal Action No. 96-CR-68
 
UNITED STATES OF AMERICA,
 
    Plaintiff,
 
vs.
 
TERRY LYNN NICHOLS,
 
    Defendant.
 
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
 
                     REPORTER'S TRANSCRIPT
                 (Trial to Jury:  Volume 147)
ÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄÄ
         Proceedings before the HONORABLE RICHARD P. MATSCH,
Judge, United States District Court for the District of
Colorado, commencing at 1:35 p.m., on the 30th day of December,
1997, in Courtroom C-204, United States Courthouse, Denver,
Colorado.














 Proceeding Recorded by Mechanical Stenography, Transcription
  Produced via Computer by Paul Zuckerman, 1929 Stout Street,
    P.O. Box 3563, Denver, Colorado, 80294, (303) 629-9285
                          APPEARANCES
         PATRICK RYAN, United States Attorney for the Western
District of Oklahoma, and RANDAL SENGEL, Assistant U.S.
Attorney for the Western District of Oklahoma, 210 West Park
Avenue, Suite 400, Oklahoma City, Oklahoma, 73102, appearing
for the plaintiff.
         LARRY MACKEY, BETH WILKINSON, GEOFFREY MEARNS, JAMIE
ORENSTEIN, and AITAN GOELMAN, Special Attorneys to the U.S.
Attorney General, 1961 Stout Street, Suite 1200, Denver,
Colorado, 80294, appearing for the plaintiff.
         MICHAEL TIGAR, RONALD WOODS, ADAM THURSCHWELL, REID
NEUREITER, and JANE TIGAR, Attorneys at Law, 1120 Lincoln
Street, Suite 1308, Denver, Colorado, 80203, appearing for
Defendant Nichols.
                         *  *  *  *  *
                          PROCEEDINGS
    (Reconvened at 1:35 p.m.)
         THE COURT:  Please be seated.
         MR. TIGAR:  May we approach, your Honor?
         THE COURT:  Yes.
    (At the bench:)
    (Bench Conference 147B1 is not herein transcribed by court
order.  It is transcribed as a separate sealed transcript.)




    (In open court:)
    (Jury in at 1:37 p.m.)
         THE COURT:  Next witness, please.
         MR. MACKEY:  We'll call Eric Thompson.
         THE COURT:  Thank you.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Eric Thompson affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Eric Howard Thompson, T-H-O-M-P-S-O-N.
         THE COURTROOM DEPUTY:  Thank you.
         THE COURT:  Mr. Orenstein.
         MR. ORENSTEIN:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MR. ORENSTEIN:
Q.  Good afternoon, Mr. Thompson.
A.  Good afternoon.
Q.  Could you tell the jury where you live, please.
A.  Oklahoma City.
Q.  And it appears by your uniform you're with the Oklahoma
City Police Department.
A.  Yes, I am.
Q.  What is your rank there?



                     Eric Thompson - Direct
A.  I'm a sergeant.
Q.  How long have you been with the police department?
A.  Almost 10 years.
Q.  Sergeant Thompson, were you on duty the morning of
April 19, 1995?
A.  Yes, I was.
Q.  And did you hear an explosion that morning?
A.  Yes, I did.
Q.  Can you tell the jury what you did after you heard the
explosion?
A.  Yes.  I was on the 3d floor of the police station, which is
approximately three blocks away from the Murrah Building site,
and we ran up on the roof to see what had happened.  And we saw
the column of smoke going up from the area of the Murrah
Building, and I immediately ran down to my scout car -- scout
car which was parked directly in front of the police station
and drove to the west side of the Murrah Building.
Q.  What did you see when you got there?
A.  A lot of smoke, debris in the road, and I noticed people
crawling and stumbling down the steps of the plateau area --
plaza area.
Q.  Did you try and help the people that you saw there?
A.  Yes, I did.  The first lady that came to my attention, her
right arm had been broken and was hanging at a -- a right
angle, and she was holding it and limping down the steps.  And



                     Eric Thompson - Direct
I -- I was able to help her into the front seat of my scout
car.  There was another gentleman in an Army uniform, Class A
or Class B uniform, and he had a -- a bleeding head wound.  And
I was able to place him along with two others in the back of my
police car, and I immediately drove them to St. Anthony's
Hospital, which is to the northwest about three blocks.
Q.  Did you return to the scene from St. Anthony's?
A.  Yes, I did.  I unloaded these people at the emergency room
at St. Anthony's and drove back to the street, back to the bomb
site.  And my tire on my police car hit some debris and was
flattened about half a block from the northwest corner of the
Murrah Building.
Q.  Did you just leave the car there?
A.  Pulled the car over to the side of the road, and I ran up
the street to the northwest corner of the Murrah Building.
Q.  Now, were there a number of other people that you tried to
help that day?
A.  Yes, there were.
Q.  I want to ask about one in particular.  When you returned
to the scene of the Murrah Building from St. Anthony's, did you
see somebody in a window on the 3d floor?
A.  Yes, I'd run around to the south side of the Murrah
Building because I knew where the day care had been, and I saw
my lieutenant.  And he asked me where the day care was, and I
ran immediately there.  And upon arriving at the south side of



                     Eric Thompson - Direct
the Murrah Building, the door that I knew that led to the day
care was blocked, and there were people attempting to get
rubble out of that -- that doorway.  And I looked up to my
right, and there was a man in the window.  I guess it would be
the 3d floor.  And a police officer, Sergeant Ed Moore, was in
the window with him, trying to help him in -- out.
Q.  Did you go to help him?
A.  Yes, I climbed up into the window and tried to assist
Sergeant Moore, to the best I could.  The gentleman, his shirt
was tattered.  He had several cuts and scrapes.  He had a very
dazed, foggy look on his expression.  He was mumbling
incoherently.  You couldn't understand what he was trying to
say, but he was grunting.  And Sergeant Moore was leaning him
forward to try to free the debris that was holding his legs.
Q.  Let me interrupt you there.  You say something was holding
his legs.  Could you describe the position he was in?
A.  Sergeant Moore was standing on top of all the rubble at
window level, so his legs were completely out of our sight,
just compacted in a large amount of rubble and debris.
Q.  He was trapped there?
A.  Yes.  He could not be lifted out.
Q.  Did you and Sergeant Moore continue to try and free this
man?
A.  Yes.  We leaned him forward to try to dig the rubble out
from behind him to no avail; and when we leaned him forward, he



                     Eric Thompson - Direct
had a -- obtained a head wound at sometime, and the scalp of
his head flapped forward as we leaned him forward.  And we
couldn't get him free from behind, so we leaned him back.  And
again, the -- the marble or rock was too heavy.  We couldn't
get him free.  And he was bleeding a great amount.  And
Sergeant Moore kept telling him to hang on, that we were --
help was coming and we were going to get him out.  We tried
to -- for a few more minutes to free his legs that were pinned
in the rubble.
Q.  During the time -- I'm sorry.
A.  Well, finally, after a few minutes of trying this, he -- he
stopped grunting.  He kind of sighed, and he stopped moving any
at all.  And Sergeant Moore took his pulse and found no pulse
at that time.
Q.  I'd like you to take a look on your screen, if you would,
at Government Exhibit 1016.  Does that picture depict the
window where you were trying to help this man?
A.  Yes.
         MR. ORENSTEIN:  Government offers Exhibit 1016, your
Honor.
         MR. TIGAR:  We have an objection noted, your Honor.
         THE COURT:  Overruled.  Proceed.
BY MR. ORENSTEIN:
Q.  The jury can see that.  What do you see in that photograph,
Sergeant Thompson?



                     Eric Thompson - Direct
A.  The ledge.  The slanted ledge is where I climbed up to
aid -- to assist them.  The blanket, I suppose -- I'm not sure
when this picture was taken -- is covering the body of the
gentleman.  And Sergeant Moore had been up standing behind him
in the window, and I was there on the ledge trying to help.
Q.  And you say the tarp is covering the body.  Were you
able --
A.  I -- go ahead.
Q.  Were you able to free the man?
A.  No.  We could not get his legs free from the amount of
rubble.
Q.  And he died there on that ledge?
A.  Yes.
Q.  Did you ever learn the name of the man who you were trying
to help that day?
A.  Yes, later on.  It was Johnny Wade.
         MR. ORENSTEIN:  Thank you.
         I have nothing further, your Honor.
         THE COURT:  Any questions?
         MR. TIGAR:  No questions, Officer.  Thank you.
         THE COURT:  You may step down.  You're excused.
         THE WITNESS:  Thank you.
         THE COURT:  Next, please.
         MR. MACKEY:  Greg Sohn.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Greg Sohn affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  My name is Gregory Paul Sohn.  Last name
is spelled S-O-H-N.
         THE COURTROOM DEPUTY:  Thank you.
         THE COURT:  Proceed.
         MR. GOELMAN:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MR. GOELMAN:
Q.  Good afternoon, Mr. Sohn.
A.  Good afternoon, sir.
Q.  You're here to tell us a little bit about your wife, Vicky,
who died in the bombing?
A.  Yes, sir.
Q.  Where do you live?
A.  I live currently in Seattle, sir.
Q.  What do you do there?
A.  I'm a recruiting first sergeant for the U.S. Army.
Q.  How long have you been in the Army?
A.  Been in the Army 17-1/2 years now, sir.
Q.  And do you have a family?
A.  Yes, sir, I do.



                       Greg Sohn - Direct
Q.  How many kids do you have?
A.  Five children.
Q.  Are they all your biological children?
A.  No, sir, they are not.  They are -- three are my biological
children and three were hers.  I mean -- correction -- two were
hers.
Q.  I'm going to show you now Government Exhibit 1457.
         MR. GOELMAN:  Which I offer at this point, your Honor.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received.  1457 may be shown.
BY MR. GOELMAN:
Q.  Can you identify the people depicted in this picture
starting with the back row, please.
A.  Yes, sir.  Of course, there's Vicky standing to the left
rear.  Beside my right shoulder is Jessica.  And right in front
of Vicky to her right front is Gregory, Jr.  To his left is
Steven.  To Steven's left is Vicky, and to Vicky's left is John
Michael.
Q.  And can you please tell us the ages of your children in
this picture.
A.  In the picture, John is 7, Vicky is 8 -- or Vicky is 7, and
Steven is 9, Greg is 12, and Jessica is 11.
Q.  And are the three blonde children in that picture your
biological children?
A.  Yes, sir, they are.



                       Greg Sohn - Direct
Q.  The other two were Vicky's?
A.  Yes.
Q.  Where was this picture taken?
A.  This picture was taken on vacation in Orlando at Universal
Studios.
Q.  How long before Vicky's death?
A.  This was the summer before.
Q.  What did Vicky do at the time of the bombing?
A.  Vicky was an operations sergeant for the Army Recruiting
Battalion on the 4th floor.
Q.  4th floor of the Murrah Building?
A.  Yes.
Q.  I want to talk a little bit about April 19th.  Did you and
Vicky have plans for that day?
A.  Yes, sir, we did.
Q.  What were those plans?
A.  The morning of April 19, 8:30, I last talked to her, and --
about 8:35.  And we were discussing who was going to pick up
the birthday cake.  It was my son's birthday, also.
Q.  How old was he?
A.  He was going to be 12.
Q.  Okay.
A.  And she said she would pick up the cake, not to worry about
it.  She had already picked up the present.  We got him a
tackle box and fishing pole because he likes fishing.  And



                       Greg Sohn - Direct
that -- the plan was to have a -- a family birthday party
there.
Q.  Was that the last time you talked to your wife?
A.  That was the last time, yes, sir.
Q.  And later on that day, after you realized that your wife
was missing in the bombing, did you make plans to make sure
that your son had as normal a birthday party as possible?
A.  Yes, I did.  I -- a friend of the family picked up the
children from school and took them to their house, and I told
them -- told her not to let them watch TV -- rumors were
already flying around what was going on, and the kids were kind
of curious anyway -- and for her to get another birthday cake
and to make this the most normal day possible and not tell them
anything about what's happening.  And as far as I know, they
didn't at that point know anything.
         It was just -- I said, "Could you just tell them that
we've got to work late or something like that."
         And she said, "That's lying."  And she's a woman of --
that goes to church regularly, and she wasn't going to do that;
but because of the situation, she says, "I just won't tell them
everything."  And she'll keep them away from the TV.  And they
went on to, my understanding, have a good birthday party.
Q.  Did there come a time when you decided it was necessary to
talk to your kids about what had happened?
A.  Yes.  The next day, I finally had to sit down and talk with



                       Greg Sohn - Direct
them.  We sat down in the living room floor at my home and we
joined hands, and the chaplain was there and another counselor
and some more friends of the family.  And -- and they knew
something was going on, but I went ahead and broke it to them.
I'm not a very tactful person, I guess, sometimes, and I was
told I should have broke it to them a little bit smarter, but I
told them that mom is missing and she may not be coming back.
But if there's any person that's going to be back because of
what's going on -- I told them about the bombing at that
time -- it was going to be her.  They are going to find her
because she's going to be the one that's going to come through
this thing if nobody else does.  She's just that kind of
person.
Q.  What was it about Vicky that prompted you to say that to
your kids?
A.  She was -- she stood her ground.  She was stubborn.  She's
persistent.  She always had a kind word, but she'd always be
stern if -- if you weren't straight as far as the children
were.  She tries -- or worked very hard at being a
perfectionist, it seemed like.  And she was just rough on one
side and gentle on the other side.
Q.  What was the reaction of the five kids when you told them
that their mom might not be coming back?
A.  Well, of course, it was just nothing but a -- we're all
sitting there crying at that point, and everybody is trying to



                       Greg Sohn - Direct
comfort the children.  I'm trying to comfort them.  And "Why,
why, why, why," is what I'm hearing.  And "Are we going to be
okay?  Are they going to blow us up, too?  And are they coming
to the house?"
         You know, they really didn't know what was going on at
that time.  They just knew that there had been a bombing and
mom probably wasn't going to be coming home.
Q.  And did you reassure your children about their own safety?
A.  Yes, sir, I did.
Q.  What did you tell them?
A.  I told them that there was nothing that was going to get
between me and them.  And as long as they are with me,
everything is going to be safe.  I'm not going to let anything
happen to them.
Q.  I want to talk a little bit about April 25th, six days
later.  Do you remember that day?
A.  Yes, sir, I do.
Q.  Can you tell us about that, please.
A.  April 25th is Steven's birthday, my other boy.  And we had
already had a birthday party there, most normal as possible
considering the circumstances.  The neighbor's kids over and
other friends of the family, and we ate cake and started
opening presents, and Steven was having a problem.  We got him
some roller blades because he wanted some roller blades.  Vicky
and I had already talked about that anyway because he wore out



                       Greg Sohn - Direct
another set that was just plain roller skates and wanted to be
like the other kids and have the new neat roller blades, but
there's a hard plastic around the knee pads and the elbow pads
on there and he couldn't get it open.
         So I was on the hearth in the fireplace, helping him
get that open, and that's when I noticed that the -- I looked
out the front window.  And the informing party, for better
words -- it's my sergeant major, my colonel and the chaplain
and so forth -- they are dressed up in their Class As with the
good -- you know, the business-like look on their face that I
know what they were coming there for.  They are coming there to
inform me, as they did, that they had found Vicky's body.
         And before they came in the door, though, I told the
children to get out of the house, go out and play, because I
didn't want them hearing it the way I had to hear it just in
case I -- I had assumed that probably this is what I was going
to hear, but it didn't really hit me like that until it
actually came into me.
Q.  And did they, in fact, inform you that Vicky's body had
been identified?
A.  Yes.  Yes, sir.  They said they had identified her body
by -- by records.
Q.  You talked a little bit about the kind of person that Vicky
was.  What kind of mom was she to the -- your kids?
A.  That's one thing I really -- I fell in love with her right



                       Greg Sohn - Direct
off the -- the bat was because of how she was.  She's -- she's
so loving.  She at one minute had one child on one knee reading
a book to them, the other one reading a book on the other knee,
and helping somebody look up a word in the -- and she's doing
so many different things with the children.  She was a Brownie
leader.  She went to the -- to -- to PTA meetings.  She went --
she made cupcakes and took them to the school for the children.
And she participated in all kind of activities with the
children.  She just -- she was right there to turn them around
whenever they were making a mistake, too.  So it was what more
could you want?
Q.  What effect has her death had on the five children?
A.  Well, the children -- well, they have nightmares.  They
have been receiving counseling.  They -- one of them is
still -- he's still peeing in his pants.  He's afraid to get up
sometimes at night.  They have dreams.  They still
occasionally -- the younger ones come to my bed and sleep.
And -- but as far as rebounding back from something like this,
it's -- they're -- I can't think of the word, but they are
very -- they come together real good after this.  I mean, they
are really working together now to make things happen the best
way they can despite the loss.
Q.  Did you have a conversation with the children after Vicky's
death about what lay before the six of you?
A.  Yes.  I talked to them about how it's very, very important



                       Greg Sohn - Direct
that we bond together, tighter than we ever had been, and it
would be Vicky's wishes anyway.  And I considered us pretty
tight anyway, but now -- even more important now is kind of
like me bonding my -- my little team together, I guess you
could say, to make sure we're right there for each other.  And
we always had a shoulder.
         And if -- I immediately went and got a cell phone
because they couldn't contact me one day from school, once I
eventually got them back into school.  And because my girl was
just throwing a fit at school because they couldn't get a hold
of me.  So that made communications better, also.  Just little
things like that, the insecurities where I always had to talk
to them about I was going to be there.  I had to keep
reassuring them because I still don't know if they -- you know,
if they believe it really deep in their heart.  They still
doubt things, you know.
Q.  You and Vicky both had children from previous marriages?
A.  That's right.
Q.  What was it like to merge these two families together?
A.  It was a -- I would call it a masterpiece of work.
She's -- she's very good when it came to -- she's talking to me
about things, how difficult it was, and I would talk to her
because the two children she had and the three that I had, put
them together, they are all selfish in their own ways.  And her
having one boy and one girl, the girl didn't have to share girl



                       Greg Sohn - Direct
things and the boy didn't have to share boy things, so that was
something to get over and get working together.  And the
biggest part of it was making the family feel like one family.
And I would put my arms around her children, she'd put her arms
around my children in the beginning; and before you know it, it
was everybody was feeling like they were in the family.  And
one would stand up for the other.  Nobody'd even question
anything else.
Q.  Did your children also bond together in the face of
discrimination?
A.  Yes.  And that was one of the -- I guess one of the
stronger things in the beginning when I lived in a town there
in Oklahoma is they were called names because of their
backgrounds.  And I had gone to the school, and some people got
suspended from the bus, for riding the school bus, and --
because my daughter Jessica didn't know whether to stand up
or -- or -- or drop down a little bit or -- or stand up for her
brother and then the brother stand up because they weren't
biologically together.  But after discrimination and several
things that were being said and -- and we started working
together as a family, one stands up for the other regardless of
what happens.  It's just like brothers and sisters now.  I
mean, there's -- they are inseparable.
Q.  Did you and Vicky have a plan as far as adopting each
other's children?



                       Greg Sohn - Direct
A.  Yes, sir, we did.  Our plan, we started the adoption
process before the bombing.  In March, we started the adoption
process.  And 1 May, it was supposed to be finished.
Q.  May 1, 1995?
A.  Yes, sir.  And -- and we didn't get to that.  But I pursued
on with it anyway.  And that was her wish.  It was my wish.  We
were a family.  We were worried about legalities in case one of
us would pass or -- or something, would the other spouse be
able to keep the children, keep them as a family as we wanted
it to be.
         And then the bombing took place, and that put a stop
into that.  And then I was right in the court just a few days
later, making sure that I still had those children, keeping
them together as a family.  So I was going for guardianship,
and I -- I got that.  And, oh, a year and a couple months later
finally, I ended up finally going through a lot of -- in and
out of court a lot and finally ended up adopting the children.
Finally, we got what we wanted.  And I even tried getting them
to go ahead and let her adopt them even though she had already
passed, but the court couldn't find any kind of basis for
that -- because that was her wish, also.  And it just really
wasn't complete.  But it's -- we're all together now, and
that's what's important.
         MR. GOELMAN:  Thank you, Mr. Sohn.  I don't have
anything else.
         MR. TIGAR:  No questions, your Honor.
         THE COURT:  You may step down.  You're excused.
         Next, please.
         MR. MACKEY:  Next, we'll call Kay Ice Fulton.
         THE COURT:  Thank you.
         THE COURTROOM DEPUTY:  Raise your right hand, please.
    (Kay Fulton affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Kay Ice Fulton, F-U-L-T-O-N.
         THE COURTROOM DEPUTY:  Thank you.
                      DIRECT EXAMINATION
BY MR. MACKEY:
Q.  Ms. Fulton, good afternoon.
A.  Good afternoon, Mr. Mackey.
Q.  Where do you reside?
A.  I live in Beaumont, Texas.
Q.  And how long have you been in Texas?
A.  Two months.
Q.  Before that, did you spend a lot of your life in Oklahoma?
A.  Yes, I was born and raised there.
Q.  And were you a member of a family that included five
children?
A.  Yes, sir.



                      Kay Fulton - Direct
Q.  Where were you in the age range?
A.  I am the youngest.
Q.  And what was the makeup of the rest of your siblings?
A.  There were four girls and one boy in my family.
Q.  And what was that one boy's name?
A.  Paul Douglas Ice.
Q.  Ms. Fulton, I'm going to ask you some questions about your
brother who we all understand that he died in the Oklahoma City
bombing; correct?
A.  Correct.
Q.  Tell the members of the jury, please, a little bit about
your shared youth, you and Paul, growing up in Oklahoma City.
A.  Paul, bless his heart, was sandwiched in between two girls
on each side and he was the consummate big brother, looking
over his little sisters and looking up to his older sisters.
It was an ideal childhood for all of us, and we grew up so
happy and such a -- a -- just a really nice family.
Q.  After he graduated from high school, Mrs. Fulton, did Paul
go on to serve in his country's military?
A.  Yes.  First, he served a short stint in the Army reserves
directly out of high school.  It was less than a year.
Q.  And how long -- excuse me -- after that, did he go into the
Marine Corps?
A.  Correct.  First, he went to Oklahoma City University where
he got a bachelor's of science; and the day he graduated, he



                      Kay Fulton - Direct
was commissioned into the United States Marine Corps.
Q.  And how many years did he serve in the Marine Corps?
A.  Active duty, it was around five or six years.  With reserve
service, all together, it was about 20 years he served in the
Marines.
Q.  When he retired from the Marines, was discharged, what was
his rank?
A.  He achieved the rank of lieutenant colonel.
Q.  And during those 20 years, what sort of assignments did he
carry out on behalf of the Marines?
A.  He was primarily an intelligence officer with the corps.
He served in -- he -- he was first a pilot on a -- on the
Intruder aircraft, and he eventually got into the intelligence
section of the Marine Corps, serving a lot of his time in
Seepac, which is in Hawaii, which is where he served the last
several years of his reserve duty.
Q.  Was Paul married during his life?
A.  Yes, he was.
Q.  And to whom?
A.  He was married to Faith Henson.
Q.  At the time of his death, was he divorced?
A.  Yes, he was.
Q.  And how long had he been divorced?
A.  It was several years.
Q.  Did he have any children by that marriage?



                      Kay Fulton - Direct
A.  Yes, he had two daughters who are now about 18 and 21 years
old.
Q.  And did they live in Oklahoma City during most of the time
that he did?
A.  Yes.  Yes.
Q.  When he left the Marine Corps, did your brother start a
career in law enforcement?
A.  First, he worked at a bank for about a year or two.  And --
but he really, really strived to get government service.  He
loved working for the government.  And his first opportunity
was with the IRS.  He had a -- an accounting and business
background.  And he became a member of the Criminal
Investigation Department of the IRS where he served for about
four or five years.
Q.  And when he left the IRS and the Criminal Investigation
Division of that agency, did he join service with the U.S.
Customs?
A.  Correct.
Q.  How many years had he worked as a Customs special agent
before he died?
A.  He started in May of '87.  So he was with Customs for
almost eight years.
Q.  And during the course of those eight years, did you see --
learn of ways that he contributed to communities as a result of
his work as a Customs agent?



                      Kay Fulton - Direct
A.  Oh, absolutely.  He -- there were a broad -- there was a
broad range of cases that he worked on, anything from -- from
products coming into the country illegally or anything from
drugs to -- oh, goodness.  It was a -- a wide range of -- of
products that he worked on.
Q.  Do you recall a particular case where he was responsible
for seizing more than a million dollars in currency?
A.  Yes.  There was a bust in El Reno, which is a town just on
the west side of Oklahoma City that he was -- played a part in.
And since there were federal agents and the local law
enforcement involved in this, the town received about half
of -- of what was seized in this raid.  May I tell what they
did with this?
Q.  Certainly.
A.  It was over 500,000 that the city -- $500,000 that the City
of El Reno got out of this.  And with that money, they built a
firing range to train their police officers on because they
didn't have one.  And the -- when they opened the range, it was
christened the Paul Ice Memorial Range because my brother was
also the firearms and physical coordinator for the Oklahoma
City U.S. Customs office.
Q.  Ms. Fulton, you told the jury that Paul had a couple young
daughters at the time of his death?
A.  Yes.
Q.  Were they important to him?



                      Kay Fulton - Direct
A.  Oh, Paul's daughters were his world, as was all of his
family.  He -- he was the consummate family person.  Son,
brother, father, nephew, cousin.  He loved his family.
Q.  Ms. Fulton, I want to show you a photograph, Exhibit 1449.
         MR. MACKEY:  And I'd offer that into evidence, your
Honor.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received.  May be displayed.
BY MR. MACKEY:
Q.  And is the man in that photograph your brother?
A.  Yes, it is.
Q.  Do you have an idea about when that photograph of Paul Ice
was taken?
A.  It -- it was during a Christmas in -- it was -- this was
the Christmas of my parents' 40th wedding anniversary, which
was 10 years ago.  They just celebrated their 50th.
Q.  And approximately how old is Paul in this photograph?
A.  He would be in his mid 30's in this picture.
Q.  And what does he have in his hands there?
A.  Airplanes.
Q.  And was that a love of Paul Ice's?
A.  It was.  After being a pilot in the Marine Corps, he had
several planes through the course of the years.  And he
loved -- he loved to fly.  He loved having his own plane.  And
just like everything else Paul did perfectly, he was an



                      Kay Fulton - Direct
excellent pilot and he -- he just loved to fly.  He loved being
up in the air by -- by himself or with friends -- friends or
family.
Q.  Ms. Fulton, was your brother a supporter of the Special
Olympics?
A.  Yes, he was.  In fact, on April 18th, there was a
basketball game in Oklahoma City for Special Olympics that he
attended.  In fact, that's the last photograph we have of him,
was taken at that game; and he had a lot of friends who were
very active in it, and he always supported them and went to any
function he could for them.
Q.  And did you see your brother, Paul Ice, on that day,
April 18th?
A.  Yes, I did.  I saw him just a few hours before the picture
was taken.
Q.  And was that the last time you saw him?
A.  Yes, it was.
Q.  How did you learn of the news of the bombing in Oklahoma
City?
A.  I worked downtown, and I was standing at the window.  I
worked three blocks south of the Murrah Building.  And when the
blast happened, it was so powerful that I fell to my knees, but
I got up.  We didn't know how bad it was because we were on the
south side of the building and we didn't see the devastation.
But I knew it was the federal building, and we were the leasing



                      Kay Fulton - Direct
office of the building I was in.  And as soon as I could get
away from my tenants, I started calling my parents to say,
"Have you -- have you talked to Paul?  Have you heard from
him?"  And so it was several hours before I could get to them
and before we could even talk to anyone with Customs and before
we even knew that he was at work that day.
Q.  How many total days did you and your mother and father and
other family members wait to learn of Paul's fate?
A.  It was eight days before they found his body.
Q.  Ms. Fulton, I -- we've gotten something of the flavor of
Paul Ice, but I'd like to ask you, if you wouldn't mind, to
describe in your own words who he was and what this community
lost as a result of his death.
A.  Oh.  Paul excelled at everything he did.  And he was the
best.  He was the best brother and son and father and Marine
and federal agent and man.  He was deeply spiritual.  He loved
this country.  My brother loved this country.  And he protected
it as a Marine and as an agent; and he was so, so proud to be
able to take care of everyone in this room and everyone in this
country.
         MR. MACKEY:  Thank you, Mrs. Fulton.
         THE COURT:  Any questions?
         MR. TIGAR:  No, I have no questions.  Thank you.
         THE COURT:  You may step down.  You're excused.
         Next, please.



                      Kay Fulton - Direct
         MR. MACKEY:  We'll call Carl Chipman.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Carl Chipman affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Carl Chipman, C-H-I-P-M-A-N.
         THE COURT:  Proceed.
         MR. SENGEL:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MR. SENGEL:
Q.  Would you tell us where you live, please, Mr. Chipman.
A.  I currently live in Stillwater, Oklahoma.
Q.  And where is Stillwater in relation to Oklahoma City?
A.  It's about north by northeast, about an hour away.
Q.  How long have you lived in Stillwater?
A.  I guess now five-and-a-half years.  Since '92.
Q.  You work there in Stillwater?
A.  Yes.  I graduated from OSU in '96 and took a job in an
engineering firm in Stillwater.
Q.  You mentioned OSU.  What is the full name of the
university?
A.  Oklahoma State University.
Q.  And did you lose a family member in the bombing at the



                     Carl Chipman - Direct
Alfred P. Murrah Building?
A.  Yes, sir, I did.
Q.  Who was that?
A.  My father, Robert Neal Chipman.
Q.  At the time of the bombing, how old were you?
A.  I was 2 -- I just -- no.  I was 20.  I turned 21 about two
months later.  20.
Q.  And at that time, in April of 1995, were you still a
student in college at Oklahoma State University?
A.  Yes.  I was a junior.
Q.  Where did your father live in April of 1995?
A.  He lived in Edmond, Oklahoma, about 20 minutes north of
Oklahoma City.
Q.  Who did he live there with?
A.  My mother, Gloria.
Q.  Were there other members of your family besides your father
and mother and yourself?
A.  Yes.  I have an older sister named Kathy who was living in
Tokyo at the time with the U.S. Air Force and a stepsister, my
sister who is the same age as I am who was living in Norman,
Oklahoma, going to school at the University of Oklahoma.
Q.  In April of 1995, how long had your father and mother lived
in the Oklahoma City area?
A.  Seven years.  Since 1988.
Q.  Prior to moving to Oklahoma City, what did your father do?



                     Carl Chipman - Direct
A.  My father was a -- we moved there -- captain in the U.S.
Air Force, and he did mostly air traffic control.  We moved
around a lot.
Q.  Did your father retire from the military there?
A.  Yes, he did.  Actually, he retired in '92, or right when my
sister and I started college.  And actually, he and my mom also
started going back to college at that time, too, so there was
actually four of us in college at that time.  It was pretty
funny.
Q.  At the time of the bombing in April of 1995, where was your
father working?
A.  He was working at the Water Resources Board.  Just -- he
had just started there about three months earlier.  He had just
started there in January of '95 and had been working there for
a little while, and it was across the street just south of the
Murrah Building, I believe.
Q.  And what was your father doing for the Water Resources
Board?
A.  I'm not quite certain.  It -- he tried to explain it to me
once, but I'm an engineer and he was more of a business-type
person; and so he explained it to me a couple times, but I
didn't quite understand.
Q.  Were you in Stillwater, Oklahoma, on April 19, 1995?
A.  Yes, I was, actually.  I -- I had a test that day,
actually, and as I was walking out the door to take the test, I



                     Carl Chipman - Direct
happened to see something on the news, and I didn't even have
time to see what it was.  And then when I got to the test, the
professor actually told me what happened.
Q.  And told you there had been a bombing in Oklahoma City?
A.  Yeah.  He told the whole class, actually.  The test scores
weren't very well on that test.  I think everyone was very
concerned.  He told everyone about it.  My test was at 9:30,
and I was running late.
Q.  Later that day, did you get in contact with your family?
A.  Yeah.  When I got back from my classes that day, I got a --
a really frantic call from my sister saying, you know, "This is
Julie.  We can't get a hold of dad.  We need you to get down
here."  And I grabbed some stuff real quick and had my friend
drive me down.
Q.  And did he drive you down to Oklahoma City?
A.  Yeah, he did.
Q.  What did you do when you got to Oklahoma City?
A.  En route, I think I had a -- we stopped and called -- or I
can't remember if I had a cellular phone.  But en route, I
found out that they had found my father and that he was in the
hospital.  I think it was Presbyterian in the Health Science
Center.  And so we changed course and we met my family there.
Q.  I'm going to show you a photograph we've marked as Exhibit
1386.  Is this your father?
A.  Yes, sir, it is.



                     Carl Chipman - Direct
         MR. SENGEL:  Your Honor, we're going to offer 1386.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received.  May be shown.
BY MR. SENGEL:
Q.  When you got to the hospital, who was there?
A.  My sister Julie was there.  My mother was there.  Her
boyfriend -- I'm sorry.  Julie's boyfriend, Jay, was there.
And then I was.
Q.  Were you able to see your father?
A.  Yeah.
Q.  Did you have -- could he talk to you?  Were you able to
speak with him?
A.  We never talked to my father until the time he died.  We --
he never woke up.
Q.  How long was he in the hospital before he died?
A.  A little under two days.  He came in, you know, that --
that day, you know, from -- they brought him there and they
actually said when they brought him in on the stretcher, he had
put his thumb up, you know, okay.  After he went into surgery,
he never regained consciousness.
Q.  If you would, please, tell us what impact it's had on you
to lose your father.
A.  That's a real tough one.  My father and I were just getting
to the point in time where I was at the age where he could talk

to me as -- as a man.  I was no longer just his son.  I was no



                     Carl Chipman - Direct
longer the son he was responsible for raising and stuff.  My
father and I were just beginning to get to the point where we
could communicate as adults to each other, and it was really
great.  You know, it's real hard, you know.
         My father was a very strong person.  And as always, we
had clashes, also, but at this point in time, he was really
beginning to respect me and we were beginning to really talk
about things and share and help each other out.
         I was, you know, learning a little about his worries
and fears, and he was doing likewise.  And, you know, the
chance that I was going to have was to have a real good friend
in my father, you know.  Not just my father, but also one of my
good friends.  And now that, I don't have.
Q.  What effect has it had on your mother and your sisters?
A.  My sister, Kathy, had had a very -- her and my father had a
fallout; and at the point in time, they were reconciling and
they were trying to work together and rediscovering their
affection and love for each other.  And she, you know,
obviously didn't get to finish that reconciliation.  And
it's -- still to this day, you know, the bitterness and anger
she has over it is just palpable.
         My mother lost the hugest foundation in her life.  You
know, she was a lot of things, but the one big thing she was
was my father's wife, and that whole identity of who she was is
now gone and she's having to fill it up.  I mean, for 15 years,



                     Carl Chipman - Direct
she was my father's wife and our mother.  And she still has the
"our mother" part, but she's no longer my father's wife.  And
she now has to make a new identity for herself, just out of the
blue with no one to help her, no support.  You know, the one
she loves the most is gone.
         And my sister -- my other sister, Julie, she's been
very strong about it.  But my father, although he was her
stepfather, was her daddy.  And no girl likes to lose her
daddy.
         MR. SENGEL:  Thank you, Mr. Chipman.
         I have no further questions.
         MR. TIGAR:  No questions.  Thank you.
         THE COURT:  You may step down.  You're excused.
         Next, please.
         MR. MACKEY:  Alan Prokop.
         THE COURT:  Thank you.
         THE COURTROOM DEPUTY:  Raise your right hand, please.
    (Alan Prokop affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Sergeant Alan A. Prokop, P-R-O-K-O-P.
         THE COURTROOM DEPUTY:  Thank you.
         THE COURT:  Mr. Ryan.
         MR. RYAN:  Thank you, your Honor.



                      Alan Prokop - Direct
                      DIRECT EXAMINATION
BY MR. RYAN:
Q.  Officer Prokop, where do you live?
A.  Oklahoma City.
Q.  What do you do there?
A.  I am the police liaison officer for the municipal court for
the Oklahoma City Police Department.
Q.  How long have you been with the Oklahoma City Police
Department?
A.  28 years, sir.
Q.  Let's turn our attention to April 19.  Where were you at
9:00?
A.  I was in my office located in the basement of the municipal
court building, which is the building directly north of the
police department.
Q.  Tell us what happened.
A.  Officer Ron Bell was in the office with me.  He had just
finished 8:00 court and had come in to complete his paperwork
before he went home to sleep.  He had worked all night.  Right
after 9:00, we heard the explosion.  The building shook.  My
office is located in the basement.  We ran upstairs to check
the building and the people upstairs.
Q.  What did you see?
A.  The people were leaving the building, not in a panic but
evacuating.  We went to the north side of the building.  There



                      Alan Prokop - Direct
were large picture glass windows there, and we could see the
smoke and fire coming from the vicinity of the federal
building.
Q.  And about what time of the morning was this?
A.  Approximately 9, 9:00, 9:02 or 3.
Q.  What did you do?
A.  The doors were clogged up with people leaving the building,
so Officer Bell and I ran to an auxiliary exit located at the
far east side, north corner of the municipal court building,
and exited the building.
Q.  About how far was your office from the Murrah Building?
A.  Approximately six to seven blocks.
Q.  And as you got outside of the building you were in, what
was in the air?
A.  The sky was black and gray.  We had debris falling in the
street around us, large chunks of rock, dirt.  It was smoky.
We could still see pages of papers.  I looked down and saw one
page that had the letterhead from the Social Security
Administration on it.  And Officer Bell remarked to me that it
had to be the federal building.
Q.  What did you do?
A.  My personal vehicle was parked in the parking lot directly
north of us.  Officer Bell's police car was about three blocks
away, so we jumped into my personal vehicle, drove directly to
the federal building.  We parked the car at 4th and Harvey,



                      Alan Prokop - Direct
which would be the southwest corner of the Murrah Building.
Q.  Tell us what you did.  Take us through your efforts to help
the people that morning.
A.  As we stopped and got out of the car, people were running
from the building.  Bloody.  Many people carrying other people.
We checked equipment.  Officer Bell had a hand radio.  I had a
small flashlight, I believe.  He had a larger flashlight.  At
this time, Officer Washington, a new officer, approached us.
He had been in district court.  He ran up.  The three of us
approached the south side of the building.  I had one pair of
gloves, and I asked Officer Bell if he was right-handed or
left; and I split my gloves up, one glove each.
Q.  What did you do next?
A.  We approached the south portion of the Murrah Building,
observed all the glass to be out of the building, people to be
standing in the windows all the way to the 6th or 7th floor,
screaming and crying for help.  We could observe smoke coming
through the building.  There were people staggering and falling
out of the building, walking injured.  There were civilians
helping other people out.
         We approached the very south corner of the building
and looked in.  The entire 2d floor was devastated.  There were
rubbles of concrete.  There was a thick smoke, a layer of real
thick dust.  There were sparks sparking from inside the
building where the electric wires were still on.  I could smell



                      Alan Prokop - Direct
gas and a real strange chemical smell, sir.
Q.  Did you do anything about the utilities?
A.  Yes, sir.  I asked Sergeant Bell to contact dispatch and
tell them we needed all the utilities turned off to the
building as soon as possible.  Requested all heavy equipment,
all ambulance units and all rescue workers that the police
department could send and advised them that we were in the
building.
Q.  How did you enter the building?
A.  It was a kind -- about a 4-foot drop through a window into
rubble and concrete debris, office materials.  And it was still
real thick, heavy dust with the electrical wires sparking when
we dropped down in the building.
Q.  Let me show you what has already been received into
evidence as Exhibit 1012.  Can you see that photograph on your
screen?
A.  Yes, sir.
Q.  Will you take the pen that's on the top of your desk there.
Put it under your desk and show us, if you would, the location
where you were able to enter the building that morning.
A.  It was this area here.  And here, sir.
Q.  Thank you.  Now, let me also show you what's been marked
for identification but not received into evidence as Exhibit
1500.
A.  Yes, sir.



                      Alan Prokop - Direct
Q.  Can you identify that photograph.
A.  Yes, sir.  This is the -- one of the windows where we
entered.  It shows what the debris looked like and the inside
of the building.
         MR. RYAN:  Government would offer Exhibit 1500.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received.  May be displayed.
BY MR. RYAN:
Q.  Tell the jury what they are seeing in this photograph.
A.  This was a window prior to the explosion.  Of course, the
glass is gone.  You can look inside the building and see what
the inside of the building looked like as we approached the --
the Murrah Building itself.  It was necessary to climb up on
this ledge and then drop down.  Inside the building, there was
piles of rubble, insulation, ceiling tiles, an occasional desk
or chair, and numerous body parts, sir.
Q.  All right.  Now, tell us about the first encounter you made
with someone who was injured once you were inside the building.
A.  We could hear screams and moans from inside the building as
we climbed into the building.  Officer Washington shouted to
Officer Bell and I as we looked around that he had found a
victim.  We followed him towards the pit area, they called it
later.  And he had located a piece of concrete setting up on
its edge.  It would have been one of the upper floors that had
fallen into this area.  Next to the ledge and down about 10



                      Alan Prokop - Direct
feet was a female.  She had been crying for help.  Officer
Washington climbed down into the crevice.  I leaned up against
the piece of concrete, and Officer Bell went halfway down.
Officer Washington was able to free her from the rebar and the
debris, lift her up and hand her to Officer Bell.  He then
handed her to me, and I exited the building with her.
Q.  What did you do with this lady once you got her outside the
building?
A.  There was people still running in and out, but there was
not any medical personnel right up to the building at this
point.  So I carried her down the plaza to the street, 4th and
Harvey.  And on the street corner there, the ambulances were
starting to pull up and other officers were arriving.  I laid
her down on the ground, asked her if she was okay.  She said
she was dazed.  I couldn't see any blood.  She -- I asked her
her name.  She told me her name was Teresa, and then she began
to cry.  I told her that I needed to leave her there and that I
had to get back in the building, and she grabbed my shirt and
asked me not to leave.
         And I said, "You'll be okay here."
         And she said, "Yeah, but you won't."
         And she was worried about me going back in the
building.  I finally convinced her that I had to leave, and a
medical worker took care of her and I left and went back into
the building.



                      Alan Prokop - Direct
Q.  What did you do once you reentered the building?
A.  As I entered the building a second time, there had already
been some more rescue workers and a lot more civilians showing
up.  As I entered the building a little bit west of where I had
come out with her, another rescue worker came up and handed me
the body of a man.  His body was ashen.  His head was back.
His eyes were open.  He was covered with a layer of dust.
There was blood running out of his mouth caked up.  There was
no breath, and I could find no pulse, sir.
Q.  What did you do?
A.  I carried him back from the building to the plaza area.
And there were medical people there showing up, and I handed
him off to another person who carried him to the street.
Q.  What did you do after that?
A.  I reentered the building nearer what I understood was an
elevator-type shaft.  There was a large pile of gravel, rubble,
and concrete there.  As I approached that rubble, I could hear
moaning and groaning.  And I observed an arm and hand to be
protruding from the gravel and waving back and forth.
Q.  What did you do?
A.  I took the hand and squeezed it.  It squeezed back.  It
appeared to be a female's hand.  I traced the arm back into the
concrete, and I could observe that there was a large portion of
flooring, concrete, probably 25 feet long, 12 feet tall,
probably 16 inches thick to be laying on top of this lady.



                      Alan Prokop - Direct
There was another piece of concrete behind it.  There was a
rescue worker behind the concrete working towards me.  As I
tried to speak to her, I could hear gurgling sounds and what I
conceived to be water running, sir.
Q.  Was it water running?
A.  No, sir.  I became upset and shouted, "Somebody turn the
water off.  This lady is going to drown."
         The rescue worker behind the concrete held his hand up
and said, "Alan, it's not water.  It's blood," and held his
hand up for me to see.
Q.  What did you do with respect to this lady that you were
holding her hand?
A.  I held her hand for about another three or four minutes and
tried to talk to her.  I prayed a little.  Her hand got cold
and stiff, and she quit moving.
Q.  Did you check her pulse?
A.  Yes, sir.  I checked pulse in her wrist and up into her
elbow.  Her hand continued to get cold, and I could find no
pulse.
Q.  What did you do after this lady's pulse stopped beating?
A.  I wasn't doing real well, and I had to leave that area.  So
I told the other rescue workers that they needed to come over
here; that there was a lady here.  And I stood up and left as
two other workers came over and started working in that area,
and I moved in towards the interior of the building.



                      Alan Prokop - Direct
Q.  Are you still on this plaza level?
A.  Yes, sir.
Q.  Where did you move to?
A.  As I moved into the building, there had been a lady
approach me and tell me that there was a day-care area in the
building.  I had not known that prior to this time.  I asked
her how many children were in the day care.  She said 40 to 50,
and she pointed toward the west side of the building.  As I
moved into that building, a rescue worker came up and handed me
a child and I exited the building.  Because of the interior
damage, it was not like anything you could imagine inside the
building as that picture shows.  The inside, there would be
mounds of brick and rock and debris 3 or 4 feet tall, and you
would crawl up over those to move over in ledges and areas
where you had to walk.  So we were trying to pass victims out
to each other for their safety and so that more rescue workers
could get through there.
Q.  Was the baby that you were handed alive or dead?
A.  It was not moving, and it appeared to be dead.  It had an
extreme wound across its forehead.  It was covered with a heavy
black dust.  It did not cry or move.
Q.  What did you do with this baby?
A.  I exited the building.  It was probably only 12 feet,
15 feet, and another rescue worker ran up to me and I handed
the baby off to him.



                      Alan Prokop - Direct
Q.  What did you do next?
A.  I reentered the building and got a little bit further into
the interior when I was handed another baby.  This child was
alive, was crying and coughing.  And I turned and headed out of
the building with it.  The child was bleeding about the nose
and mouth and out of the ears, and I exited the building with
that child.
Q.  Do you know the name of that child?
A.  No, sir.
Q.  What did you do following that?
A.  As I was exiting the building with this child, I heard
Firemen Atchley who was the photographer, I believe, for the
fire department.  He had been working a little bit further west
and a little bit deeper in the interior than I had been when I
was handed the child.  He said, "Alan, I have two more."
         And I said, "I'll be right back."
         I ran out of the building with this child, through the
plaza area and down towards the steps when an AmCare worker, a
female, ran up to me and I handed the child off to her and ran
back into the building.
Q.  Did you go back in alone?
A.  No, sir.  As I was running back towards the building,
Sergeant -- Detective Sergeant Don Hall ran up to me and asked
me if I had the children.  He was upset.  He had just gotten
there and didn't know how to get into the building.  And I told



                      Alan Prokop - Direct
him there were two more in there, to follow me in, and he
followed me back into the building, sir.
Q.  And what happened once you and Detective Hall reentered the
building?
A.  He followed me back in through the area to where Fireman
Atchley was kneeling down.  He had uncovered these two
children.  They were laying real close to each other.  He was
cleaning their face and the dust off of them.  As I approached
him, he reached down and -- and picked the first child up and
handed it to me.  That child was later identified as Jill
Webber.
Q.  What did you do with this child?
A.  I handed it to Don Hall who was standing behind me.  I saw
him cradle the baby in his arms.  It had a severe arm injury as
well, and he headed out of the building.
Q.  What happened next?
A.  I turned back around to Atchley, and he handed me the
second child they later identified as Brandon Denney.
Q.  What did you do with Brandon Denney?
A.  He said, "Look at his injuries."
         And I looked down, and Brandon had a brick sticking
out of his forehead, sir, the left side.  It was protruding
out, and I could see blood oozing around it.  He was bleeding
out of his mouth.  His eyes were partially opened and appeared
to be looking different directions and told me he had a brain



                      Alan Prokop - Direct
damage.  I stabilized the brick with my hand, cradled him in my
arms, and exited the building.
Q.  What did you do after he exited the building?
A.  He was whimpering, and so I ran as hard and as fast as I
could directly to the -- where the ambulances had been picking
up the children and the other victims at the -- the southwest
corner of the building there at 4th and Harvey.
Q.  Did you give Brandon Denney to one of the workers?
A.  No, sir.  There was an ambulance pulling out as I
approached that area, and I ran up and kicked the ambulance,
the side of the ambulance, and it stopped.  And when it
stopped, the back doors opened up.  I climbed in the back of
the ambulance, and there was a man laying on a gurney, strapped
to a gurney.  He had his arms across his chest.  And as I
climbed in the back of the ambulance, he opened his eyes.  And
he and I made eye contact, and he saw Brandon and smiled at me
and he opened his arms, and I laid Brandon Denney on his chest.
He laid his arms back around him and nodded to me, and I
stepped back out of the ambulance and closed the door and
watched it drive away.
Q.  At some point that morning, were you ordered out of the
building?
A.  Yes, sir.  I reapproached the building once or twice after
that and helped with a few of the other bodies, and then we
were ordered to leave.



                      Alan Prokop - Direct
Q.  Were you, yourself, injured in connection with the things
that you've told us about that you did that morning?
A.  Yes, sir.
Q.  Were you taken to a hospital?
A.  The next day, I was treated at the hospital, yes, sir.
Q.  What was -- how were you treated?
A.  They tried doing some respiratory therapy to us for the
inhalation of the concrete dust and told us we'd just kind of
have to wait and see.  And I had fallen several times.  They
did some therapy to my knees.
Q.  Have you had nightmares since April 19th, 1995?
A.  Yes, sir.
Q.  What is your nightmare about?
A.  It's the -- the fact, sir, that the people in the
building -- as you entered that building, you would see dust
move and bodies would come out of the dust, sir.  They approach
us every night.  I see them every night.  We -- there weren't
enough of us.  We couldn't help.  And I'm sure they died
waiting for us, sir.
         MR. RYAN:  That's all I have, your Honor.
         MR. TIGAR:  No questions, your Honor.
         THE COURT:  All right.  You may step down.  You're
excused.
         THE WITNESS:  Thank you.
         MR. RYAN:  Your Honor, at this time, we'd play the
video involving Brandon Denney.  Exhibit 1427.
         THE COURT:  All right.  You may do so.  You said this
is Brandon Denney?
         MR. RYAN:  Yes, your Honor.
    (Exhibit 1427 played.)
         MR. MACKEY:  Judge, we'll call Sharon Coyne at this
time.
         THE COURT:  All right.  Thank you.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Sharon Coyne affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Sharon Rose Coyne, C-O-Y-N-E.
         THE COURTROOM DEPUTY:  Thank you.
         MS. WILKINSON:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MS. WILKINSON:
Q.  Good afternoon, Mrs. Coyne.
A.  Good afternoon.
Q.  Could you tell the jury where you live.
A.  I live in Moore, Oklahoma.
Q.  How old are you?
A.  27.



                     Sharon Coyne - Direct
Q.  Are you married?
A.  I am, to Scott William Coyne.
Q.  How long have you been married to Scott?
A.  Six years.
Q.  Back in April of 1995, where were you working, Mrs. Coyne?
A.  I worked for the Federal Court Clerk's Office, downtown
Oklahoma City, for the Western District the Oklahoma.
Q.  And how far is the federal courthouse in Oklahoma City from
the Alfred P. Murrah Building?
A.  It's directly south.  It's right across the street.
Q.  Before you started working in the Federal Court building,
did you ever have any military service?
A.  I did.  I joined the Army in '89, and was discharged in
'93.
Q.  What did you do for the United States Army?
A.  I was a Russian linguist.
Q.  And when you and your husband moved to Oklahoma, did you
talk about having a family?
A.  We did.  We had talked a little bit while we were married,
but we were going to wait until we were out of school and
making six digits and -- but when I got out of the military, I
found out that I was pregnant.  I didn't realize before I got
out, so I was about three months pregnant when I got out.
Q.  And before your baby was born, did you express to your
husband whether you wanted a boy or a girl?



                     Sharon Coyne - Direct
A.  No.  I -- not to him.  You know, everybody wants a healthy
baby; and secretly, I think most men want little boys and most
women want little girls.  So I did the right thing and I told
everybody I wanted a healthy baby.  And he had decided that we
wouldn't find out the sex of the child at the ultrasound.  And
I wanted a girl so badly that I decided it would be a boy, so
that I could get ready and I would be, you know, excited about
a little boy.  So I convinced myself, my husband, his family,
my family, that it would be a boy.  And we purchased boy things
and --
Q.  And did you have a baby on February 9, 1994?
A.  I did.
Q.  And what kind of baby did you have?
A.  I had -- well, I have to tell you first that it was not
just go in and have this child.  I mean, I had a perfectly
healthy pregnancy and got in there that day, and there were
some complications.  And they had to do an emergency cesarean
section.  But when I got in there that morning, the woman --
the nurse who had hooked me up to, you know, the heart monitors
and the fetal heart monitor had said, "It looks like it's going
to be a little Valentino.  Really wanted a girl.  Hadn't had a
girl yet this morning, but we can do all boys today."  So it
just kind of confirmed that I was -- what I already had
convinced myself of, and that's that it would be a little boy.
And --



                     Sharon Coyne - Direct
Q.  What happened after the cesarean?
A.  The anesthesiologist told my husband -- he said, "Well you
need to tell your wife --"
         THE COURT:  I don't understand the relevancy of this
part of it.
         MS. WILKINSON:  It gets to some of the impacts, your
Honor.
         THE COURT:  Move ahead.
         MS. WILKINSON:  Yes.
BY MS. WILKINSON:
Q.  Mrs. Coyne, did you have a little girl --
A.  I had a little girl.
Q.  -- on February 9?  What was her name?
A.  Her name is Jaci Rae, Jaci Rae Coyne.
Q.  And when you worked at the federal courthouse, where was
Jaci Rae during the day?
A.  She was in the day-care across the street.  She had been
over there for about three weeks.
Q.  That's the day-care center in the Alfred P. Murrah?
A.  Alfred P. Murrah.
Q.  And was she killed on April 19, 1995?
A.  Yes, she was.
Q.  How old was she when she died?
A.  She was 14 months, 10 days.
Q.  Could she talk at the time?



                     Sharon Coyne - Direct
A.  A little bit.  She said "Mama" and "Dada."
Q.  What kind of little girl was she?
A.  Physically, she was about 20 to 25 pounds.  She had big
blue eyes.  She looked just like her daddy except for without
the beard.  Very little hair.  Jaci was kind of a ham.  She
liked to be in front of the camera.  She liked to be held by a
lot of people.  It didn't matter who.  Anybody.  She was a very
friendly little girl.  She was never shy, not a day in her
life.
Q.  Let me have you look at Government's Exhibit 1534, which we
will introduce into evidence.
         MS. WILKINSON:  We move 1534, your Honor.
         THE COURT:  Have any objection?
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  All right.  Received.  May be shown.
BY MS. WILKINSON:
Q.  Is this Jaci?
A.  Jaci in her raspberry picture.
Q.  And how old was she when this picture was taken?
A.  It was shortly before the bombing.  She was about a year
old.
Q.  On the morning of April 19, 1995, were you in your office
in the federal courthouse?
A.  I was.  I was a file clerk.
Q.  Did you feel the explosion?



                     Sharon Coyne - Direct
A.  I did.  I heard it.  I felt it.  Didn't know what it was.
Knew there was, to my knowledge, not ever an earthquake in
Oklahoma, so I was very confused about what had happened.
Q.  Did you attempt to find Jaci?
A.  I did.  My co-workers and I were all led out of the
building and looked across the street.  You could see the south
side of the building, which has the plaza, right there in front
of us.  And then on either side of the plaza are the stair --
steps that go all the way up to the top of the plaza, which was
the second floor, which is where Jaci was.
         And we walked out and had gone on the west side and
up, and I didn't think there was anything wrong.  I mean, I had
heard this explosion.  I saw all the black smoke.  But when I
got up to the plaza, I just saw people walking outside who were
injured, but they were walking on their own.  They were
coherent.  I -- and I just didn't think there was anything
wrong.
Q.  Did you have any idea about the damage to the front of the
Murrah Building?
A.  No.  Not till way later that night.
Q.  You didn't find Jaci that day, did you?
A.  No.
Q.  And did you -- did your husband eventually convince you to
go home that evening?
A.  He did.  We had gone to the First Christian Church and



                     Sharon Coyne - Direct
waited and filled out paperwork for the ME's office.  And it
was there that I had seen on the television the north side of
the building, and it was there that I had decided that there
was a remote possibility that Jaci could still be in the
building; that they just hadn't been able to find her yet.
Q.  And that evening when you went home, what was your concern
about Jaci?
A.  The First Christian Church was on the north side, and we
lived on the south side; and so we were in my mom's van, and we
were driving.  And the way the highway sits in correlation with
the Murrah Building, you could kind of see down there.  And we
were driving on the highway, and it was all lit up.  And I
thought that Jaci was still in the building.  And because it
had happened at 9:00 and it was almost 9 when we were going
home that night, I knew that she was in a dirty diaper and it
had begun to rain.  And they had kept saying on the news that
maybe there was a little pocket or something.  And I thought
that maybe she was exposed to the rain and that she was hungry
and that she wanted me.  She had mommy-itis really bad, and she
really wanted to be around me all the time.  And I was just
afraid they wouldn't get her out that night.
Q.  Mrs. Coyne, how long did you have to wait to hear about
your daughter?
A.  Seven days.
Q.  Now, if we could, could you tell the jury a little bit



                     Sharon Coyne - Direct
about how you've been impacted by losing your daughter and if
you could start about -- with telling them about the memories
that you have of your daughter today.
A.  I have -- I have lots of good memories of Jaci.  They have
sustained me since I've had to accept that she's not going to

be back.  And I had hoped all of the good memories would get me
through.
         I have one memory of Jaci with my husband and I.  We
live in a very tiny house; and we were in the kitchen and we
were making dinner one night, and we had blocked off the
kitchen area for Jaci to not be able to get in there because it
was a ceramic floor and we didn't want her to fall and hit her
head.  Anyway, it was kind of warm in the house; and she had
taken -- we had taken off her shirt and her pants so she was
basically roaming around with just her diaper on, you know.
And my husband and I were in the kitchen making dinner, and she
started giggling.  And so Scott went out there, and he said --
he said, "Sharon, you have to come here and see this."  And
she's still giggling; and so I poked my head around the corner,
and there she stands.  She has figured out how to get her
diaper off, and she's walking around totally naked with the
diaper sticky stuck to her hand.  And she's just as happy as
she can be.
         So memories like that really have been able to help me
quite a bit, except for that the end of memories always end



                     Sharon Coyne - Direct
with a vision that I can't seem to get out of my head.
Q.  Mrs. Coyne, is that a vision that you had as soon as you
realized that Jaci was stuck in the building?
A.  It was about a week after -- yeah.  It was about a week
after the bombing, and it was out of nowhere.  And it was --
it's not prompted by anything, except for maybe that I'm just a
sick person.  My memories all start good, and then they end
with me -- and it happens very quickly -- hearing the
explosion.  And then my mind imagines the building falling, and
then I see Jaci and her hair is kind of stuck to her head from
the blood.  Her eyes are open.  And she's naked.  And she's got
on just her diaper, and it's -- it's totally filled with blood,
and there's shards of glass all over her skin.  And she's
looking at me.  And it won't go away.
Q.  Mrs. Coyne, is that a picture that you've tried to get out
of your mind?
A.  Yeah.
Q.  Were you allowed to see your daughter, or did you see your
daughter before you buried her?
A.  No.  But I was -- no.  I was very lucky.  I got to hold
Jaci before -- Jaci was wrapped up, and I got to feel of her
and she was all there.  And even though she was in a body bag
and she was totally wrapped, I still got to hold her three
times before.
Q.  You don't know if this vision that you have is how she



                     Sharon Coyne - Direct
actually was?
A.  No.
Q.  Now, have you and your husband talked about having other
children?
A.  We have.  It's taken until this year for us to decide that
we were ready to move on to something like that.  But you know,
I had wanted a girl so badly.  I wanted --
         MR. TIGAR:  Objection to this, your Honor.
         THE COURT:  Overruled.  You may continue.
         THE WITNESS:  I had wanted the relationship with my
daughter to be the same relationship that I have with my mom.
And I wanted for there to be this mom-daughter friendship that
develops.  And even though my husband didn't agree with me, I
had decided that she would be all I had.  I didn't want any
more kids after her.  She made my entire life complete, and she
filled any hole I had left.  And now it's just gone.
BY MS. WILKINSON:
Q.  By losing her, do you have any fear about how you would
feel about having another child?
A.  I'm afraid that -- initially, I was afraid that any child I
had, I would compare to Jaci.  And I was always afraid that I
wouldn't love that child as much or that I would resent that
child for having a life when the one that I loved first didn't.
And now I'm afraid if I have a little boy, because I wanted a
girl so badly, that I wouldn't love it.  And I know that's not



                     Sharon Coyne - Direct
rational.  If you lose your child, it consumes your life.  And
I want it to go away, and it won't.
         MS. WILKINSON:  Thank you very much, Mrs. Coyne.
         THE COURT:  Do you have any questions?
         MR. TIGAR:  No questions.  Thank you.
         THE COURT:  You may step down.  You're excused.
         Members of the jury, we'll take our afternoon recess
at this time.  And again, of course, during the time of the
recess, please continue as you have at all recesses, avoiding
discussion about the matters that you're hearing; and keep open
minds.  Remember that, as I said before, you're hearing one
aspect of the matter, one of the factors that you may consider.
There's more to be heard before you even in your own minds
begin to make a judgment.  So please do not discuss anything in
connection with this matter, and avoid anything outside of the
evidence.  You're excused.
         20 minutes.
    (Jury out at 3:04 p.m.)
         MR. TIGAR:  May I approach, your Honor?
         THE COURT:  Yes.
    (At the bench:)
    (Bench Conference 147B2 is not herein transcribed by court
order.  It is transcribed as a separate sealed transcript.)




    (In open court:)
         THE COURT:  We'll be in recess.  20 minutes.
    (Recess at 3:08 p.m.)
    (Reconvened at 3:28 p.m.)
         THE COURT:  Be seated, please.
    (Jury in at 3:29 p.m.)
         THE COURT:  Next, please.
         MR. MACKEY:  Your Honor, we'll call Mr. William
Titsworth.
         THE COURT:  All right.
         THE COURTROOM DEPUTY:  Raise your right hand, please.
    (William Titsworth affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  William Edward Titsworth,
T-I-T-S-W-O-R-T-H.
         THE COURTROOM DEPUTY:  Thank you.
                      DIRECT EXAMINATION
BY MR. ORENSTEIN:
Q.  Good afternoon, Mr. Titsworth.
A.  Good afternoon.
Q.  Would you tell the jury, please, where you live.
A.  I live in Great Bend, Kansas.
Q.  And is that where you're from originally?



                   William Titsworth - Direct
A.  No, sir, it's not.  I'm from Clayton, Oklahoma.
Q.  What do you do for a living these days?
A.  After the military, I worked for the Union Pacific
Railroad.
Q.  And what do you do for the railroad now?
A.  Foreman for a section maintenance gang.
Q.  When did you start with that?
A.  September of '96.
Q.  Are you married, sir?
A.  Yes, sir, I am.
Q.  What's your wife's name?
A.  Gloria.
Q.  Do you call her Chrissy?
A.  Yes, sir, Chrissy.
Q.  When you married Chrissy, did she have some children?
A.  Yes, sir, she did.  She had two daughters.
Q.  What were their names?
A.  Katie and Kayla.
Q.  Were you and Chrissy and Katie and Kayla all together in
the Murrah Building on April 19, 1995?
A.  Yes, sir, we were.
Q.  Was your wife and was Katie injured that day?
A.  Yes, sir, they were.  Both of them.
Q.  Did you sustain some permanent injuries that day?
A.  Yes, sir, I did.



                   William Titsworth - Direct
Q.  Did Kayla die that day?
A.  Yes, sir.
Q.  Mr. Titsworth, you told us that you joined the railroad in
'96 after some time in the military.  Can you tell the jury
what branch of the service you were in.
A.  I was in the United States Army.
Q.  How long had you been in the Army at the time you ended
your career there?
A.  9 years, 11 months and 16 days.
Q.  Is that a career for you?  Were you planning to make it a
career?
A.  Yes, sir.
Q.  Did you leave your position in the Army because of your
injuries?
A.  Yes, sir, I did.
Q.  When you left the Army, what was your rank?
A.  Sergeant E5.
Q.  And in what parts of the world did you serve your country
in the Army?
A.  I spent two tours in Korea and three different assignments
in the States, Fort Dix, New Jersey; Fort Riley, Kansas and
Fort Sill, Oklahoma.
Q.  Where were you stationed in April of 1995?
A.  Started out the first part of April in Fort Riley, Kansas.
Q.  And did you request a transfer?



                   William Titsworth - Direct
A.  Yes, I did.
Q.  Why did you do that?
A.  Basically to get away from the field time there at Fort
Riley.  We were gone two entire months out of the year and
spent a lot of time in the field.
Q.  What did you not like about the field time?
A.  It was time away from the family.
Q.  And was your request for a transfer granted?
A.  Yes, sir, it was.
Q.  Where were you transferred to?
A.  To the Oklahoma City recruiting battalion in the federal
building.
Q.  That's in Oklahoma City?
A.  Yes, sir.
Q.  Were you satisfied when you found out that's where you'd be
transferred to?
A.  Yes, sir, I was.
Q.  What did you think about that?
A.  I thought that was great.  I mean it was a new start for me
and my family, plus I was going to get to go home.
Q.  When were you supposed to report for duty in Oklahoma City?
A.  My actual reporting date was 1 May.
Q.  And did you ask to report earlier than that?
A.  Yes, sir, I did.
Q.  What was the reason for doing that?



                   William Titsworth - Direct
A.  To go ahead, get to the recruiting battalion, sign in, and
instead of burning up leave days to sign out on permissive TDY,
to move my household goods from Fort Riley to Oklahoma City.
Q.  You threw in some military terms in there.
A.  I'm sorry.
Q.  Was the basic idea that you'd have some time to find a
place to live?
A.  Yes, sir.
Q.  When did you arrive in Oklahoma City?
A.  The evening of the 18th of April.
Q.  What did you do when you arrived?
A.  Picked up a newspaper initially to look for houses in the
area.
Q.  Did you -- did you and your family go on a little car trip
that night?
A.  Yes, sir.  After looking in the newspaper, we drove around
Oklahoma City, we drove by the federal building.
Q.  To see where you were going to work?
A.  Yes, sir.
Q.  Let me ask you to tell us about the next day, April 19,
1995.  Did you go to the recruiting station in the Murrah
Building that day?
A.  Yes, sir.  We went to the recruiting battalion.  We got to
the federal building about 8:30.
Q.  Who was with you when you went there that morning?



                   William Titsworth - Direct
A.  My wife, Chrissy, and Katie and Kayla.
Q.  I'd like to show you --
         MR. ORENSTEIN:  And, your Honor, I'll offer
Government's Exhibit 1437.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received, may be shown.
BY MR. ORENSTEIN:
Q.  Mr. Titsworth, would you walk us through this photograph
and tell the jury who they're looking at.
A.  Yes, sir.  It's a picture of myself, my wife, Chrissy, and
Katie and Kayla.
Q.  Chrissy is on the right-hand side of the picture?
A.  Yes, sir.  That's Chrissy on the right.  The bottom middle
is Kayla, and the upper middle is Katie.
Q.  And how old on April 19 were Katie and Kayla?
A.  Three and five.
Q.  Katie was the older one?
A.  Yes, sir.
Q.  Now, these were Chrissy's children, not yours.  Is that
right?
A.  That is correct, sir.
Q.  Had you become close with them in the time that you knew
Chrissy?
A.  Yes, sir.  I was supposed to adopt them the following
month.



                   William Titsworth - Direct
Q.  Why did you bring your family with you to the Murrah
Building that day?
A.  Well, you move an entire family when you move in the
military.  It's not just one person that goes.  It's a shared
experience.
Q.  When you arrived at the battalion, the recruiting battalion
at the 4th floor that morning, what did you do?
A.  Initially, we met the secretaries that were lined up there
in the hallway; and Sergeant Evans, the PAC supervisor or the
administrative supervisor who was going to be my boss, took me
around and introduced me to other people there in the office.
Q.  Did someone find something for the girls to do while you
were being shown around?
A.  Yes, sir.  Another sergeant in there had given them some
toys to play with while I was being escorted around.
Q.  Do you remember the explosion?
A.  Yes, sir, I do.
Q.  What do you remember happening after the explosion?
A.  I remember everything going black.  It felt like the back
of my head was on fire.  I kept waiting for somebody to turn
the lights back on.  I thought maybe the power went out in the
building or something.
         I felt something warm and wet on my hands.  It scared
me.  I tried to stand up.  I thought I was sitting down, but I
couldn't move.  After that, I just got more scared and started



                   William Titsworth - Direct
pushing.  I got to the point where I could push, and I could
see a slight crack of light.  I could see the top of the
federal building.  I seen nothing but black smoke.
         I finally got out from under what I was under, and I
looked across the room and I seen my wife screaming, "Where is
Kayla, where is Kayla, where is my baby?"
Q.  You saw your wife.
A.  Yes, sir.
Q.  Did you find Katie?
A.  I don't remember exactly what -- where Katie came into
play; but about that time, I somehow got to my feet, and then
Katie was with Chrissy at that time.
Q.  Was your wife telling you anything about her condition?
A.  No, sir, not at that time.
Q.  Did you see what condition she was in?
A.  No -- all I seen at that point is she was scared.  She was
screaming.  It wasn't really making any sense at that point.
Q.  Did you know at that point the extent of your own injuries?
A.  No, sir, I didn't.
Q.  You saw your wife and Katie.  You couldn't find Kayla.
What did you do?
A.  We were told to get out of the building.  Sergeant Evans
told my wife to get me out of the building.
         My wife carried Katie and led me out -- out of that
room to the back side of the building.



                   William Titsworth - Direct
Q.  Once you got out of the building, did you and your wife
continue to look for Kayla?
A.  Yes, sir.  Once we got to the sidewalk, Chrissy hollered
out, "There goes my baby," and pointed towards the ambulance
and told me to go look.
         I ran and banged on the door of the ambulance and
looked inside the ambulance, and I seen a small child; but it
wasn't Kayla.  The only way I could recognize that it wasn't
was by the tennis shoes.
Q.  Why were you not able to tell any other way than by looking
at the shoes?
A.  The baby was burned.
Q.  After chasing down that ambulance, what did you do?
A.  I made my way back to the sidewalk where Chrissy was, and
Chrissy said that her ear was hurting.
         I went over and tried to move her hair, and I see the
blood just coming down on the right side of her head.
Q.  Do you know what had happened to your wife's ear?
A.  Yes, sir.  She lost about a quarter-inch -- inch-and-a-
quarter section of her ear that was completely severed through
here and just hanging off the side.
Q.  Did she go through some operation to try and reattach that?
A.  Yes, sir, she did.  They reattached it at the hospital
there.
Q.  Was your daughter, Katie, injured at all?



                   William Titsworth - Direct
A.  Yes, sir.  She received minor injuries, really.  She had
two pieces of glass.  One was wedged in her cheek and one on
the top of her head.
Q.  You told us that you were injured.  Were you taken to the
hospital?
A.  Yes, sir, I was.
Q.  And did you lose consciousness after you arrived at the
hospital that morning?
A.  After I was at the hospital, I remember a lady saying,
"This is going to hurt a little bit."  And after that, I don't
remember anything.
Q.  That was Wednesday morning, the 19th?
A.  Yes, sir.
Q.  When did you wake up?
A.  I'm not for sure.  It was sometime either Friday night or
early Saturday morning, I woke up in the hospital there.
Q.  Do you know where you were in the hospital?
A.  I was on the 10th floor of University Hospital.
Q.  You were in the intensive care unit?
A.  That was after the intensive care unit.
Q.  Can you tell the jury the extent of your injuries?
A.  Yes, sir.  I got a piece of my skull that's missing, a
little bit bigger than a 50-cent piece.
         I had a major nerve on the left side of my face that
was severed.



                   William Titsworth - Direct
         I have no feeling in three fingers on my right hand.
         And there is a lot of bad headaches.
Q.  What kind of treatment did you receive while you were at
the hospital?
A.  I went through three major surgeries, one for a collapsed
lung, one to remove a large piece of glass that was wedged
through my neck and throat, and then another to remove bone
fragments and glass from my skull.
Q.  Are there still to this day glass fragments above and below
your skull?
A.  Yes, sir.
Q.  After a time, you were released from the hospital.  Is that
right?
A.  Say again, sir?
Q.  After a time, you were released from the hospital.  Is that
right?
A.  Yes, sir.  I was released.
Q.  When you were released, had all of your injuries healed
yet?
A.  Not healed, no, sir.
Q.  I'd like to show you --
         MR. ORENSTEIN:  And, your Honor, I will offer
Government's Exhibit 1436.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received, may be displayed.



                   William Titsworth - Direct
BY MR. ORENSTEIN:
Q.  Mr. Titsworth, would you tell the jury what they're looking
at in this photograph.
A.  That's a picture that was taken Monday evening at the
hospital -- at the hospital -- at the motel across from
University Hospital.
Q.  That was after you had been released?
A.  Yes, sir.
Q.  Did you have any difficulties when returning back to a
normal life just in terms of the physical injuries you had
sustained?
A.  Yes, sir, I did.
Q.  Can you tell the jury about that.
A.  Like I said, for a long time I had some real bad headaches
and sharp pains that shot through my body.  Besides the fact of
just going to work and looking at people, you know, and these
people wanted to talk to me or say something to me but they
were afraid to.
Q.  Did you have any trouble eating?
A.  Yes, sir, I did for about three weeks.
Q.  What was that a result of?
A.  I lost a little bit of weight.  That was about it for that
one.
Q.  Did you have trouble with muscle control?
A.  Yes, sir.  When I got out the hospital, I was having



                   William Titsworth - Direct
problems with my right hand; and I didn't really think about it
at the time, but I reached down trying to pick up a glass and I
couldn't get my hand to close.  It just went straight.  I
couldn't move my hand at all.
Q.  I'm sorry.  Go ahead.
A.  And as far as eating, the nerve that was severed in my neck
and throat -- I'd literally be eating something, and things
just come running out the side of my mouth.
Q.  How long did that go on for?
A.  It went on for about 3 or 4 months.
Q.  You told us that you eventually left the Army because of
your injuries.  What was it about your injuries that caused you
to leave the Army?
A.  The military would no longer let me do PT.
Q.  Let me interrupt you there.  What is PT?
A.  I'm sorry.  Would not let me do physical training.  I
couldn't go outside and do pushups.  I couldn't run.
         As far as military duty itself, I couldn't wear a
Kevlar helmet, which is the helmet required for the battle
dress uniform.
Q.  Why were you unable to wear a Kevlar helmet?
A.  Because of the weight on top of my head and the way the
helmet sit, it laid right across the hole in my head.
Q.  You told us part of your injuries is a piece of your skull
is missing.



                   William Titsworth - Direct
A.  Yes, sir.
Q.  Is that still true?
A.  Yes, sir, it is.
Q.  Did you ultimately take a medical discharge from the Army?
A.  Yes, sir, I did.
Q.  Had you expected that the Army would be your career?
A.  Yes, sir.  I already put almost 10 years in it.  I wasn't
about to quit.
Q.  What did that do to your feelings about yourself?
A.  Lowered them quite considerably.
Q.  As a result of your injuries during the bombing, do you
also have scars to this day?
A.  Yes, sir, I do.
Q.  Your right side -- the right side of your face is to the
jury.  Are most of the scars on the left side of your face and
neck?
A.  Yes, sir.  Back of my head, left side of my head, and left
side of my neck.
Q.  Would you please turn to the jury so they can see how
scarred that is.
         Mr. Titsworth?
A.  I'm sorry.
Q.  Thank you.
         You told us that you and your wife were looking for
Kayla.  Did you ever find her?



                   William Titsworth - Direct
A.  No, sir.  We didn't.  We didn't even find out that she was
deceased until Saturday morning in the hospital.
Q.  Would you tell the jury what kind of person Kayla was.
A.  She was wonderful.  Kayla was my little helper.  Like I
said, it's noted that I was in the process of adopting them.
She wasn't my natural daughter; but when Katie and Kayla came
into my life, Katie knew who her father was.  Kayla was still
at the age that she really didn't have quite an understanding
of what was going on; so to Kayla, I was her father.  You know,
Kayla did everything with me.
         Traditionally on holidays, I cook the turkey.  She's
the one that's in there with me.  If I'm working on the car,
working on the truck, whatever, she was the one that was right
there with me.
Q.  You told us that you were in the process of adopting Kayla
and Katie.  Did you eventually adopt Katie?
A.  Yes, I did.  I adopted Katie on May 19.
Q.  Were you allowed to adopt Kayla?
A.  No, sir, I was not.
Q.  Would you tell the jury the impact that Kayla's death has
had on you and on your marriage to Chrissy and on your family.
A.  It's more than three or four times caused me and Chrissy to
discuss divorce.  There has been a lot of mental abuse between
the two of us, pushing the blame off on each other.
         It's just within the past few months with me and my



                   William Titsworth - Direct
wife being to the point where we can communicate.
Q.  What has Kayla's death, the injuries that you and Katie and
Chrissy all sustained -- what has that done to Katie?
A.  Initially, it set her back almost to a baby stage.  She
quit doing things around the house.  She had no urge to go to
school, no urge to be around people.
         This past year in school, she started to excel a
little bit, and the teachers are coming home -- or teachers
ain't coming home, but the teachers are saying she's doing a
lot better in school.  But it's taking this long for her to do
well in school.
Q.  Has Katie ever expressed any guilt about the bombing?
A.  Yes, sir, she did.  Right after the bombing, we went to my
mom's house in Clayton, Oklahoma, and Katie announced to me and
Chrissy that she killed her sister.  And we asked her why.  And
she said, "I stepped on an electrical cord that set the bomb
off."
         I guess at the point when the bomb exploded, there was
an extension cord that was going across the floor, and she
stepped on it right at the time of impact.  And she thought
that she set the building -- or she set the bomb off that
exploded in the building.
Q.  Have you had trouble convincing her that she was not
responsible for her sister's death?
A.  Yes, sir.  And it took a lot more than just me and Chrissy.



                   William Titsworth - Direct
She's been through three different counselors since that time,
and only within the last eight or nine months has she not
spoken of that.
         MR. ORENSTEIN:  Thank you, Mr. Titsworth.
         That's all I have, your Honor.
         THE COURT:  Questions?
         MR. TIGAR:  No questions.  Thank you.
         THE COURT:  You may step down.  You're excused.
         THE WITNESS:  Thank you.
         MR. MACKEY:  Call Mr. Gary Campbell.
         THE COURTROOM DEPUTY:  Raise your right hand, please.
    (Gary Campbell affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Gary Campbell, C-A-M-P-B-E-L-L.
         THE COURTROOM DEPUTY:  Thank you.
         MR. MACKEY:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MR. MACKEY:
Q.  Good afternoon, Mr. Campbell.
A.  Hello.
Q.  Where do you live?
A.  Currently in Fort Worth, Texas.
Q.  How long have you lived in Fort Worth?



                     Gary Campbell - Direct
A.  Two weeks.
Q.  Before that, where did you live?
A.  Sherman, Texas.
Q.  Lived there many years?
A.  Yes.  Almost 20.
Q.  When did you and your family first settle in Sherman,
Texas?
A.  1978.
Q.  And at that time, what did your family consist of?
A.  I had a wife, two daughters and a son.
Q.  What were the names of your children?
A.  Kimberly, Raymond and Cynthia.
Q.  Were Kimberly and Raymond children from your wife's
previous marriage?
A.  Yes, they were.
Q.  And was Cindy a daughter to you and your wife?
A.  Yes.
Q.  Was Cindy killed in the bombing in Oklahoma City on
April 19?
A.  Yes, she was.
Q.  How old was Cindy at that time?
A.  26 years and 4 days.
Q.  At the time that Cindy was 18 years of age, Mr. Campbell,
did you and your wife divorce?
A.  That's right.



                     Gary Campbell - Direct
Q.  And what decision did Cindy make as to where she would
spend her time?
A.  Cindy decided to stay with me in Texas at that time.
Q.  How long did the two of you reside either in the same home
or in the same city before April of '95?
A.  About six years.
Q.  During those six years, Mr. Campbell, did Cindy Campbell
finish her education?
A.  Yes.
Q.  Where did she go?
A.  She graduated from Sherman High School that same year, in
'87; and then she went to Community College in Sherman.  And
she graduated from there and then went to Baylor University in
Waco, Texas.
Q.  What degree did she obtain from Baylor?
A.  She had a degree in political science.
Q.  During those years, the late teens, early 20's, did you
notice Cindy Campbell to be an interested young woman in the
affairs of other people?
A.  Cindy was a very caring person and put others before
herself and did many things to help.
Q.  What kinds of organizations was she an active part in in
those years?
A.  She was in the Big Sister program in college; and
throughout high school, she worked at the local Girls Club.



                     Gary Campbell - Direct
Q.  Were those interests that she pursued in later years as
well?
A.  Yes.  As she graduated from Baylor, she became a juvenile
probation officer in Sherman.
Q.  How many years did she work as a probation officer there in
Sherman?
A.  Approximately two-and-a-half years.
Q.  And over time, Mr. Campbell, did you learn that Cindy
Campbell had made a difference to youths that she counseled as
a probation officer?
A.  Yes.
Q.  Would you describe what you know.
A.  On two separate occasions, mothers and individuals came up
to me and expressed the fact that Cindy had indeed made a
difference in their -- their son or daughter's life and helped
them turn it around.
Q.  Do you recall an occasion where one youth that she had
counseled came back to the probation officer and reported --
A.  That's right.
Q.  -- his success?  Could you tell us that story?
A.  Her boss related this story to me and others.  We set up a
small scholarship fund for Cindy at the high school, and her
boss at the probation is the one that gives the scholarship or
makes the award.
         And he always relates a story about Cindy, talks about



                     Gary Campbell - Direct
her.  And the story this last May was the fact that a young man
came in the probation office, was not dressed as most kids that
come to the probation office are dressed.  He was very neatly
dressed, had on white shirt and a tie.  And he walked in and he
said, "I want to see Cindy Campbell."
         And the secretary got her boss.  He came out and he
said, "Well, Cindy is no longer here."
         And he said, "Well, I need to tell Cindy that I made
it."  He said, "Thanks to her, I have a wife, a son, I
graduated from high school, and I have a good job.  And I
wanted Cindy to know."
Q.  Did Cindy love her work as a juvenile probation officer?
A.  Very much.  Very much.  She spent -- spent many nights
riding with the local police, making sure that her kids were on
curfew; that they were in fact at home.  She spent many hours
at the high school roaming the halls, making sure that her
kids, as she called them, were, in fact, in class and at
school.
Q.  When she left her job as a probation officer, what new
career did she start?
A.  She became a Secret Service agent.
Q.  And approximately when was that?
A.  Her initial training, I believe, started in September of
1993.
Q.  And how did that come about that she became a Secret



                     Gary Campbell - Direct
Service agent?
A.  One of her kids had written a letter threatening the life
of the President.  And as part of her duty, she reported that
to the Secret Service in Dallas.
         They subsequently came up to interview the young man,
in the course, interviewed Cindy to find out more about him and
his family and at that time asked her if she'd be interested in
coming to Dallas to visit their offices.  And from that, it led
to their requesting her to make application to the Secret
Service.
Q.  Did you and your daughter talk about the decision that she
was to make about leaving work as a probation officer --
A.  Yes.
Q.  -- and moving into the Secret Service?
A.  We did.  And we struggled with it.  She liked what she was
doing so much.  And -- but then on the other hand, she saw it
as a once-in-a-lifetime opportunity to do something that few
people get the honor and privilege to do.
Q.  When Cindy first became a Secret Service agent, did she
have to take a long training course?
A.  Yes.  It was almost a year.
Q.  And was there anything in the course of that training that
changed her life?
A.  Very much so.  She met her future husband, Ron Brown,
during the training.



                     Gary Campbell - Direct
Q.  And was Mr. Brown also a Secret Service agent?
A.  Yes.
Q.  When were Cindy and Ron Brown married?
A.  They were married March 11, 1995.
Q.  Approximately five weeks before the bombing?
A.  That's correct.
Q.  At the time of the bombing, where was Cindy
Campbell-Brown's station with the Secret Service?
A.  Oklahoma City.
Q.  And where was Agent Brown's?
A.  He was stationed in Phoenix, Arizona, at that time.
Q.  Given that the two agents were married, had any request
been made that they be relocated to the same city?
A.  Yes.  In fact, it had already been approved.  They were in
the process of being transferred to Washington, D.C.
Q.  Do you know when their report date was for joining together
in Washington, D.C.?
A.  It was like within 30 days, I believe.  They were -- they
were to leave the week following the bombing for their first
house-hunting trip; and normally once you find a home, it's
fairly quickly after that.
Q.  Mr. Campbell, did your daughter on many occasions express
her care and concern and love for you?
A.  Yes.  Cindy and I had a very special relationship and I
think sometimes very unique.  I know at her wedding, our dance



                     Gary Campbell - Direct
was "You Are the Wind Beneath My Wings," and she played that or
chose that because that's how she felt about me.  But when I
danced with her, I knew Cindy -- this is about you and what you
do for me.  And that's the relationship that we had.
Q.  As her father, were you concerned as she launched a career
with the Secret Service that she would be out of touch; that
you might not know where she was or what she was doing?
A.  Yes.  I always worried about where she was; and that was
kind of an inside joke because when she chose to live with me,
she said, "Dad, what are the rules?"
         And I said, "I have one rule."  I said, "You let me
know where you are."
         So the last Christmas, my present was a map on the
wall with red and blue pins, the red pins for Cindy, the blue
pins for Ron; and a pin was placed in every city that they went
to.  And she said, "Dad, now you'll know where I am all the
time."
Q.  Mr. Campbell, was your daughter a woman with quick wit and
a sense of humor?
A.  Yes, she was.
Q.  And did she sometimes combine that quality with her care
and concern for her mother?
A.  Yes.  In fact, the Christmas present to her mother, the
fact that her mother had moved from Texas and had not had the
opportunity to visit her at Baylor or see the campus -- she and



                     Gary Campbell - Direct
her roommate made a video where her roommate held the camera
and knocked on the door, and Cindy did the, "Hello, Mom, come
on in."  And they took a tour of the campus, went to the
cafeteria, had lunch, did the whole thing.  It was really cute
and meant a lot to her mother.
Q.  At one point in the video, did they show some footage of
the library there at Baylor?
A.  Yes.  And Cindy was always an overachiever, and it was so
unlike her.  And they were standing in front of the library --
or Cindy was, and said, "Mom, they tell me this is the
library."
Q.  Did you travel from Sherman, Texas, to Oklahoma City the
weekend of April 8 and 9 of 1995?
A.  Yes, I did.
Q.  And why did you do that?
A.  It was an early birthday celebration.  Cindy's birthday was
the 15th of April, and she was going to Phoenix to be with Ron
and celebrate her birthday and Easter, so I went up a week
early to take her out to dinner and celebrate her birthday.
Q.  Did you and your daughter visit the offices of the U.S.
Secret Service in downtown Oklahoma City that weekend?
A.  Yes, we did.
Q.  Describe to the jury what happened.
A.  We went to dinner.  We went up to the offices, and Cindy
being a new agent was just so proud of what she was doing.  And



                     Gary Campbell - Direct
we went through the other agents' offices as their doors were
opened.  And she pointed out, "This is Alan Whicher's office,
Mickey Maroney, Don Leonard,'s," etc. and pointed out their
plaques and mementos that they had collected over the years.
And she was just so excited that one day, she said, "Dad I'll
have mementos like this and have been to the places that these
fellows have been."
Q.  At that point in time, Mr. Campbell, had you met or talked
to any of the fellow Secret Service agents that Cindy was
assigned to in Oklahoma City?
A.  Yes.  I had met most of them briefly, just mainly to say
hello and who I was and to visit with a little bit.
Q.  And what was your reaction about the corps of people
assigned to that office there in Oklahoma City, as a father?
A.  I was very pleased.  I felt Cindy had a group of surrogate
fathers, if you will, seasoned veterans that would show her the
ropes, take care of her, and make sure that she got off to a
good start as a Secret Service agent.
Q.  Mr. Campbell, how did you first learn of the bombing in
Oklahoma City?
A.  A friend of mine called me at work and told me that he had
heard a building had been bombed in Oklahoma City.  He was not
sure if it was a federal building or a state building.  And he
was not sure of what building Cindy worked in, but he was
concerned and thought that I should know.



                     Gary Campbell - Direct
Q.  And after learning that in fact it was your daughter's
building, did you travel to Oklahoma City?
A.  Yes.  I went home -- well, I called some friends and went
home and put some belongings together and drove to Oklahoma
City.
Q.  When were you notified as Cindy's father of her death?
A.  It was April 20, around 7 p.m.
Q.  Mr. Campbell, could you tell the jury in your own words who
Cindy Campbell-Brown was as you knew her?
A.  Cindy was a very loving, caring person, one that put others
before her.
         She was a super sister, a super daughter.  She enjoyed
life to the fullest.
         She was one, I felt, that had made a difference based
on what people have told me.  And she's one that I feel that we
will all miss because I feel like she's -- she would have made
a bigger difference had she lived.
Q.  Could you describe the relationship that Cindy had with her
sister or -- excuse me -- sister, Kimberly, and her brother,
Greg?
A.  It was, I would say, probably best of all, a mutual
admiration society.  They were very close in age.  Kimberly
tended to be very smart, very artistic and athletic.
         My son was very athletic, a marine.  And Cindy drew
her strengths, her athleticism and love for athletics and that



                     Gary Campbell - Direct
side from her brother; and yet the academics and I guess
ambition from her older sister, the push to be the best that
she could.
Q.  And do you know that each of those siblings miss Cindy?
A.  Very much so.  And it's -- it's never been this is my
stepsister, this is my stepbrother.  We were all together from
such an early age, and in the family we tried to make no
difference as to stepchildren, etc.
         And I think -- that made a bond between them.  If you
would ask them -- and I know that, you know, that's their
sister, not their stepsister.  It was neat.  They looked out
for each other.  They took care of each other.  They argued,
never fought; but it was special.
Q.  Speaking for you, Gary Campbell, could you tell the jury
the impact of your daughter's death on you.
A.  I've cried about that, trying to think what I would try to
have people understand.  It's very difficult to put into words.
         Having been divorced and living basically alone, you
always have someone that you look to to push you to the next
level or to encourage you, the one you do things for.
         And Cindy was that part of me.  And when I lost her,
I've just -- everything is kind of hollow now.  The things that
come just don't mean the same, because she was always so
excited to share things, so excited to hear about what you were
doing, so excited to say, "Way to go, Dad."  And now that's not



                     Gary Campbell - Direct
there.  And so I don't know; it's very difficult.  It's just an
empty feeling.
Q.  Mr. Campbell, let me ask you to take a look, please, at
Government's Exhibit 1171A.
         MR. MACKEY:  Which we move into admission.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received, may be shown.
BY MR. MACKEY:
Q.  Mr. Campbell, is this the daughter who died on April 19,
1995?
A.  Yes, it is.
         MR. MACKEY:  Nothing else.
         THE COURT:  Any questions?
         MR. TIGAR:  No questions, your Honor.
         THE COURT:  You may step down.  You're excused.
         Next, please.
         MR. MACKEY:  Your Honor, we'll call Barb Trent.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Barbara Trent affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Barbara Jean Trent, T-R-E-N-T.
         THE COURTROOM DEPUTY:  Thank you.
         THE COURT:  Ms. Wilkinson.
         MS. WILKINSON:  Thank you, your Honor.
                      DIRECT EXAMINATION
BY MS. WILKINSON:
Q.  Good afternoon, Ms. Trent.
         Could you tell the jury where you live now.
A.  Harrah, Oklahoma.
Q.  And where is that in relationship to Oklahoma City?
A.  45 minutes east.
Q.  Are you married?
A.  Uh-huh.
Q.  What's your husband's name?
A.  Roy.
Q.  Could you tell the jury how old you are, please.
A.  34.
Q.  And could you share with them a little bit about your
family, how many sisters you have?
A.  I have three older sisters, 40, 44 -- I mean 43 and 44.
Q.  Are you the baby of the family?
A.  Yeah.
Q.  And could you tell the jury your parents' names.
A.  Dr. Charles and Jean Hurlburt.
Q.  Were your parents killed in the bombing of the Murrah
Building on April 19, 1995?
A.  Yes, they were.



                     Barbara Trent - Direct
Q.  How old were your parents when they died?
A.  My father was 73 -- excuse me -- and my mom was 67.
Q.  Was he the oldest, your father, the oldest victim --
A.  Yes.
Q.  -- of the Murrah Building bombing?
         Could you share with the jury a little bit about who
your parents were.  Start with your dad.  Where was he born and
what was his background?
A.  My dad was born in Africa, and his parents were
missionaries.  And he was raised there, five brothers and three
sisters -- they were raised there.
         He came to the States to Wheaton, Illinois, when he
was 24, and he went to school there, got a degree in dentistry.
Q.  Did he graduate from Wheaton College?
A.  Yes.
Q.  And did he go on to dental school at the University of
Illinois?
A.  Yes.
Q.  Did he meet someone at Wheaton College?
A.  Yes.  He met my mother.  She grew up in Decatur, Texas, and
then went to Wheaton, Illinois; and she became a nurse,
so . . .  And they met there, and after a few years got
married.
Q.  And you said you had an older sister who is approximately
44?  Is that right?



                     Barbara Trent - Direct
A.  Uh-huh.
Q.  What's her name?
A.  Betty Palmer.
Q.  And after she was born, did your parents decide to become
missionaries themselves?
A.  Yes.  My mom and dad, after they were married, after they
had my two oldest sisters, went back to Africa to be medical
missionaries, my dad to do dental work and my mom as a nurse.
They were there about five years.  My next sister, next in age
to me, was born there.
         Then they came back to Illinois, and that's where I
was born, in Naperville.
Q.  Now, your older sister you said was Betty.
A.  Correct.
Q.  And then your next sister is 43?
A.  Is Dawn, Dawn Basher.
Q.  And she was born also before your parents went to Africa?
A.  Yes, in Illinois.
Q.  And your third sister's name?
A.  Sherry Elliott, and she was born in Africa.
Q.  Where in Africa did your parents serve?
A.  The Belgian Congo.
Q.  Do you know what kind of medical missionary work they did?
A.  Medical -- basically medical, doing medical missions.
Q.  When your father came back, did he develop a private



                     Barbara Trent - Direct
practice?
A.  He did for a while in Illinois.  And then he became a
professor at one of the universities in Illinois.  Then from
there, we -- when I was age 6, we moved to Birmingham, Alabama,
and that's where he got his master's degree in radiology.
Q.  Did he then become a dental radiologist?
A.  A dental radiologist.
Q.  And was that his specialty from that time on?
A.  Yes.
Q.  Now, when your folks lived in Birmingham, do you recall how
long they lived there?
A.  Three years.
Q.  And did they develop relationships with some of the
community members there in Birmingham?
A.  Yes.  Shades Mountain Bible Church that they went there.
And I'm -- I can't recall with my age all the other events my
mom was involved in.
Q.  Does your sister live in Alabama now?
A.  She does now.
Q.  After your parents were killed, did some of those people in
Birmingham express some of the good deeds that your parents had
done in that community?
A.  Yes.  They all pitched in, and my sisters came down about
two days after the bombing and they helped watch -- helped them
with their kids; and they all pitched in.  And a lot of them



                     Barbara Trent - Direct
knew Mom and Dad well, so they were trying to help us as much
as they could.
Q.  After your folks left Birmingham, where did they move?
A.  To Oklahoma City.
Q.  Is that where they resided until they were killed?
A.  Yes.
Q.  Do you remember what -- approximately what year they moved
to Oklahoma City?
A.  I can't.
Q.  Was it around 1973?
A.  Yeah.  It's -- they were there for 23 years.
Q.  Are you a little nervous?
A.  Yes, I am.  Sorry.
Q.  There is water there, if you --
A.  I'm sorry.
Q.  -- if you want to help yourself.
         Now, when your father moved to Oklahoma City, did he
teach, or did he develop a private practice?
A.  No, he became a dental radiologist at the OU Health Science
Center.
Q.  Did your mother work?
A.  She did.  She worked at Deaconess Hospital as an RN.
Q.  Where is Deaconess Hospital?
A.  In Oklahoma City.
Q.  For how many years did your mother work as a nurse at



                     Barbara Trent - Direct
Deaconess?
A.  23 years.
Q.  Was she working there at or around the time of her death?
A.  Yes.  She was working part-time, and I was also working
there.  I've been there 10 years.
Q.  Tell the jury what you did.
A.  I'm an RN -- after my mother -- became a nurse.  And I
worked there with her.  We worked on separate floors, but we
worked there together.
Q.  Now, tell the jury a little bit about your routine of how
often you saw your mother in those days and months before the
bombing at Deaconess Hospital.
A.  Well, I never -- I didn't live with them in their home, but
I never lived out of state away from them.  And we were very,
very close.  I saw Mom -- she worked part-time at that time.
I'd go up and see her at lunch or eat lunch with her; or after
work, I'd go over after work to their house.  I had my own key,
go over there on the weekends, you know.  We were just really
close.  We did a lot.
Q.  Now, while your mother worked part-time, did your father
come to a point in his career where he retired from teaching?
A.  He did.  He retired in 1989.  And at that time, Mom's --
when she became 65, she had to work less because of Social
Security, but she was still working part-time.
Q.  Did your father do volunteer activities after that time?



                     Barbara Trent - Direct
A.  He and Mom -- he and Mom did a lot together, and Mom got
them involved with training with the Red Cross; and they were
doing that for a full year before they were killed.  They were
actually being trained for emergencies to help out, so they
were going through all the training classes.
Q.  How long was that training?
A.  For a year.  They had done that for a full year.
Q.  Let's turn to April 19, 1995.  Were you at work in
Deaconess Hospital on the morning of the bombing?
A.  Yes.  I work in an outpatient surgery area, but our area is
a central area where when there are any disasters, they will
come through our area.
         And so we are kind of the triage area.  And that
morning, we heard a major thump, and we thought it was -- there
were some -- there was some construction going on, and we
thought something had happened upstairs.  And then we looked on
TV and we saw the Murrah Building.
Q.  Now, at that point, did you have any reason to believe that
your parents were in the Murrah Building?
A.  I thought my mom would be called in to come help, and so
I --
Q.  Did you worry about her that morning?
A.  Not -- my husband was trying to get hold of all of our
family members just to make sure.  I didn't think any
different.  When she didn't come in after a few hours and I



                     Barbara Trent - Direct
didn't hear from her, it was just assumed that she and Dad were
helping with the Red Cross because that's what they were doing;
and so I thought, okay, they're helping with the Red Cross and
they're down there helping people out.  So I just figured she'd
call me later.
Q.  Did you hear from her that evening?
A.  No, and we called them and called them.  I started getting
a little worried, but I thought it couldn't be.
         So I called the church, because I thought they
probably went on there from -- to choir practice.
         And the man that answered the phone couldn't tell me
if they were.  And I thought, okay, they're probably still out
helping; and so my husband called through the night.  And then
I called from 2 a.m. in the morning on.  Then I started
worrying and I called the house.  And I thought, well, they're
out there helping, but Mom will for sure -- it was just strange
that she didn't call me because she'd always call me with
anything.  She'd call just to check on me.
Q.  Did you have to go work that morning on April 20?
A.  I went to work at 6 a.m., and I thought for sure she would
call me.
Q.  Why did you think she would call you at work?
A.  I thought, okay, she's going to let me know because she
didn't want to wake me up through the night, and she's going to
call me and let me know she's coming home -- I'm going to be at



                     Barbara Trent - Direct
work -- and let me know -- I mean, you know, make sure
everything's okay and that she's okay and that she and Daddy
had been helping.  And at 9:00, I was waiting; and a friend
from their church was trying to help find them and couldn't, so
I decided to leave work and go over to their house.  And I let
myself in.
Q.  What did you find?
A.  I thought for sure -- my dad had some heart problems and a
pacemaker -- I thought, okay, I'll check in the cabinet to see
if there is -- his heart pills, because if he's there helping,
then he'll have his heart pills with him.  So I opened the
cabinet, and his heart pills were there; and my heart sank.
And I spotted a folder by the phone, and I rapidly went through
it.  And I opened the middle that said, "If you have any
questions about your Social Security, please come to the Alfred
P. Murrah Federal Building."
         And then I called my sisters and I went frantic.  I
called my sisters; and they said, "Oh, Barb, you know, you
know, everything -- it's fine.  Nothing is wrong."
         And I called my husband, and he left to go up and
look.  So he went downtown.  And he went to the Red Cross,
because I had called the Red Cross and they had said a lot of
people had been volunteering to help but weren't signed in.
Q.  Were you trying to see if your parents had been volunteers
at the Red Cross?



                     Barbara Trent - Direct
A.  Yeah.
Q.  Did there come a time, Mrs. Trent, when you learned that
your parents' car was found in the vicinity of the Murrah
Building?
A.  That day when I went to their house at 4 p.m., the FBI
called and said that their van was found in the -- on that
block in the crime scene.
Q.  Did you later learn that both of your parents had gone down
to Social Security that morning?
A.  Yes.  We figured that where one was, the other -- they
always did everything together.  So we didn't know.  May 4,
after two-and-a-half weeks, the -- until when they stopped the
final search.  They were -- with the last group to be found.
So we didn't know that whole time.  We assumed that that's
where they were because their van was down there; and then they
found them, found their bodies that day.
Q.  So you were told on May 4 about --
A.  Yes.
Q.  -- the identification of your parents?
A.  Yes.
Q.  Could you tell us a little bit about what type of person
your mother was.
A.  Absolutely wonderful.  My parents were so loving, and they
brought us up in a Christian home; and they not only told us
they loved us all the years growing up, they showed it.  And my



                     Barbara Trent - Direct
Mom constantly told me how proud she was.
         And just the little memories I have:  When I'd go see
her on the floor after work, she'd take me and say, "I want you
to meet one of my patients."  And she'd pull me into one of the
rooms with the patients, and she said, "This is my daughter."
And she just got a big smile like she was so proud of me, and
it just made me feel so good, those memories.
Q.  Was she an outgoing person?
A.  She was very outgoing, very hospitable to other people,
always giving.  She would after work go spend time with her
patients.  So many times she was late -- growing up -- she was
late getting home because she'd go sit with her patients and
spend time talking to some of the people.  I've had many
patients later on that have told me that they remember Mom and
how she took care of their husband dying and how much she had
meant to them.
Q.  What kind of person was your father?
A.  He was very -- the gentlest, kindest man you'd ever meet.
An example of how other people thought of him:  A friend of
mine went to a dentist and she asked, "You know Charles
Hurlburt?  You know, he worked at the dental school."
         He goes, "Why, yes, I had worked with him for 10
years."
         And it wasn't a name I recognized.  And upon talking
about Dad, he cried and had to leave the room.  Daddy -- they



                     Barbara Trent - Direct
all loved Dad.  He was just -- he just loved people.  And
they -- at the dental school, they had a scholarship for a
student that showed qualities like Dad that had made good
grades and yet was kind to other people.
Q.  Could you tell the jury what kind of impact it's had on you
personally to lose both of your parents?
A.  Personally, my parents were truly some of the finest people
and the biggest support of my life.  And I have missed them
very, very, very much.
         It's been very hard for me in the realms of working.
I tried to go back to my job; and I worked for six weeks, and
then the stress became incredible with trying to make critical
decisions in the area that I work.  It was hard -- it was very
stressful to make those decisions, so I decided to take a
leave.
Q.  Did you see an impact on the patients you were treating
because of your condition?
A.  No.  I continued to do my job well, but I felt that I was
too stressed to make those kind of decisions.  And I didn't
want to -- I didn't want to -- I did not want to be a negligent
nurse.
         And so I took a leave, and then I went part-time, and
I've been part-time since.  And I'm -- I am hoping to go back
full-time soon.  I'm -- I'm starting to come around finally and
would like to go back full-time, but it's -- up to this time, I



                     Barbara Trent - Direct
have been -- had trouble with physical illness.
Q.  Have you had respiratory problems?
A.  My asthma.  I've been in the hospital with severe
respiratory problems due to -- and my doctors have even said,
"This is all due to your being stressed.  Your immune system is
down."
Q.  In the hospital in Deaconess -- are you there part-time
now?
A.  Yes.
Q.  Do you engage in disaster drills?
A.  Yes.
Q.  And has there been an impact on you due to the loss of your
parents and how you carry out your role in disaster drills?
A.  That is very hard.  We've had quite a few disaster drills
since this has all happened so we could be well-equipped next
time it does; but every time they have one, it does -- it
really -- it upsets me.  It really does.  And it's hard to
think when that happens because I just flash back.  And I have
to just leave what I'm doing and go get myself together and
let -- sometimes let the other nurses handle it, although it is
just a drill.  I don't feel equipped at this point to handle
that.
Q.  Do some of your -- do you have any children, Mrs. Trent?
A.  No, I don't.
Q.  Do some of your sisters have children?



                     Barbara Trent - Direct
A.  They all have three kids apiece.
Q.  I'd like to show you Government's Exhibit 2223 --
         MS. WILKINSON:  Which we would offer into evidence.
         MR. TIGAR:  No objection, your Honor.
         THE COURT:  Received, may be shown.
BY MS. WILKINSON:
Q.  Tell the jury who is in this picture, Mrs. Trent.
A.  That's my mom and my dad and my little nephew, Phillip.

Q.  Whose son is he?
A.  Sherry.
Q.  Could you tell the jury the impact on the rest of your
family, your sisters and your nieces and nephews, the impact
that the loss of your parents has had on them.
A.  It's been hard on all of them and even my nieces and
nephews, their grandchildren -- they -- my parents really,
really got to know their grandkids.  They spent a lot of time
with them.  Whenever they'd baby-sit for my sisters -- although
my sisters are out of state now, at different times in their
life, they did live in Oklahoma.  And my mom and dad spent a
lot of time with the kids and -- and it was just fun, because I
remember when they would take care of them, they just didn't
push them to the side and make them watch TV.  They spent their
days doing things for the kids.  I mean their whole day, they
did things that the kids would enjoy.  They really focused,
they really focused on the kids to make them feel important.



                     Barbara Trent - Direct
Q.  Finally, Mrs. Trent, could you express to the jury the
impact on the community of losing your parents.
A.  There were -- there have been many -- my mom and dad were
involved in many different activities in the church, in
helping, volunteering with the Red Cross, at the hospital, you
know, just different areas that they knew people.  There have
been many people that have come up to me after all this and
said how much they loved Mom and Dad.
         They named the -- the nurses loved Mom so much, they
named one of the day rooms where they put the patients in the
"Hurlburt Hospitality Room," because that was what they thought
of Mom.  They really loved Mom and her hospitality, and -- she
cared.  She had people over to the house a lot.  She cared
about individual people.  She did a lot for people.  Always at
different holidays, she always had people over because she
didn't want people to be left out if they didn't have a place
to go.  She had gifts for them.  She remembered people, she and
Daddy together, so . . .
         MS. WILKINSON:  Thank you very much, Mrs. Trent.
         No further questions, your Honor.
         THE COURT:  Any questions?
         MR. TIGAR:  No, no questions, your Honor.
         THE COURT:  You may step down.  You're excused.
         Next?
         MR. MACKEY:  We'll call Mr. Michael Reyes.
         THE COURT:  Thank you.
         THE COURTROOM DEPUTY:  Would you raise your right
hand, please.
    (Michael Reyes affirmed.)
         THE COURTROOM DEPUTY:  Would you have a seat, please.
         Would you state your full name for the record and
spell your last name.
         THE WITNESS:  Michael Reyes, R-E-Y-E-S.
         THE COURTROOM DEPUTY:  Thank you.
                      DIRECT EXAMINATION
BY MR. MACKEY:
Q.  Good afternoon, Mr. Reyes.
A.  Hi.
Q.  Tell the jury, please, where you live.
A.  I live in Bethany, Oklahoma.
Q.  Is that near Oklahoma City?
A.  It's a suburb.
Q.  How old are you?
A.  33.
Q.  And how long have you lived in Oklahoma City or the area?
A.  20 years.
Q.  What's your educational background?
A.  I have a degree in accounting from Oklahoma State
University.
Q.  And when was that awarded?



                     Michael Reyes - Direct
A.  1989.
Q.  Mr. Reyes, for whom do you presently work?
A.  I work for the Department of Housing and Urban Development.
Q.  And how long have you worked for HUD?
A.  Nine years.
Q.  What's your current assignment or duty?
A.  I'm a housing specialist in the single-family division at

HUD.  We basically work with FHA loans.
Q.  Mr. Reyes, I want to direct your attention now to April 19,
1995, and ask if you were working in the Murrah Building on
that day.
A.  Yes, I was.
Q.  Let me show you Government's Exhibit 952G.  It's already
admitted into evidence.
         You see that before you?
A.  Yes, sir.
Q.  Is that an accurate floor plan of the HUD work area on the
7th floor in the Murrah Building?
A.  Yes, sir.
Q.  Mr. Reyes, if you take your pen -- it's the one with the
cord to -- yes.  Reach down beneath the surface and press on
the monitor.  Mark an X where your work station was on
April 19, 1995.
A.  I didn't mean to -- I mean it to be farther to my left.
Q.  You can press the button and try one more time.



                     Michael Reyes - Direct
         So space was tight and you were sitting on the ledge.
Is -- let me ask this way, Mr. Reyes.  How far from the south
wall was your desk?
A.  About 4 feet.
Q.  At 9:02 on April 19, 1995, were you sitting at your desk?
A.  Yes, sir.
Q.  Tell me what happened.
A.  I was working on my files and the power went off.  I
thought that was very strange because the power had never gone
off before.  And then I started to hear a rumbling sound, and I
thought that perhaps we were experiencing an earthquake, even
though Oklahoma really doesn't get earthquakes.
         So I knew that people in earthquakes usually hide
under things, so I thought I'd jump under my desk.  And when I
went to do that, the floor wasn't there.  And I was in a
head-first dive, in a free fall.  And I knew at that time that
I had maybe 5 seconds to live.
Q.  Were you thinking to yourself, Mr. Reyes, about your
condition and the dangers you were experiencing at that moment?
A.  I was saying to myself that I did not want to die and that
this wasn't real, but -- in my mind, I knew I was about to die.
Q.  Go ahead.
A.  I was going to hit bottom somewhere and that would be it.
Q.  Do you remember striking bottom?
A.  I don't actually remember striking bottom.



                     Michael Reyes - Direct
Q.  What do you remember next?
A.  The next thing I remember is I'm in a position -- in a
crouched position up to my waist in rubble and my arms are kind
of tangled in the -- the steel supports for the temporary walls
on the 3d floor.
Q.  Mr. Reyes, when you landed on the 3d floor after your fall
from the 7th floor, did you see other persons around you?
A.  I saw about six people that worked in that office.  That
was the office of Health and Human Services.
Q.  And did some of those people immediately come to your aid?
A.  As -- the first thing I remember is that a man said, "Is
everyone all right?"
         And I said, "Help me."
         And he was surprised to see me.  He asked where I came
from, and I said the 7th floor.
         He said, "Oh, my God."  And he said, "Stay there.
We'll clear a path to get to you."  And they did that.
         Then they took me -- I was very bloody, and they took
me over to the wall and had me lean against a bookcase while
they worked on getting an escape path out of the building.
Q.  What was your physical condition?  What injuries have you
suffered as a result of that fall?
A.  I had a pretty good gash right here on my left temple, left
part of my chin, my right eye.  I had a pretty good gash on my
wrist.  I didn't know it at the time, but two bones in my



                     Michael Reyes - Direct
pelvis had separated.
         My right leg from mid thigh down was a complete
bruise.  My lower lumbar area was a complete bruise, and I had
pockmarks all over my face and my legs.  I had a gash on each
shoulder blade.  That's about all I can think of.
Q.  In time and with the help of others, were you able to get
out of the Murrah Building that morning?
A.  Yes.
Q.  And how exactly did you do so?
A.  The people from Health and Human Services decided that the
best way to get out would be to climb out on the ledge on the
3d floor and work our way down onto the plaza level, which is
one floor lower.  And so they had someone try it first to see
if it would work.  And they said if that worked, you're going
next.
         And I said, "I don't think I can do that."
         And they said, "Well, you have to."
         So I tried it, and that's how I got onto the plaza,
and then people helped me over to 4th and Harvey to a triage
area.
Q.  Mr. Reyes, let me show you Gove