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HATFIELD &
HATFIELD TELEPHONE
(336) 273-0589 KATHRYN K. HATFIELD JOHN B. HATFIELD. JR CYNTHIA A. HATFIELD
May 8, 2000 Route 1, Box
36 Dear Ronnie: I am in receipt of
your letter dated April 19 and postmarked May 3 from Julian I have
not had occasion to write to you since June 22, 1999 when I
responded to your previous request to turn over copies of documents
and other evidentiary items. I have looked over
my records of your murder trial and related matters and they are
very voluminous, filling two large file boxes. Innumerable items of
pretrial discovery and correspondence that was turned over to me at
various times bear my personal notations along with post-it notes
and other memoranda. Also I have
numerous file folders labeled with the names of potential witnesses
containing interviews, discovery materials, addresses and the like. If and when it is
going to be necessary to copy these files. it will be extremely
difficult to do. As I told your father when he called me a few days ago. I do not believe that my duties as a lawyer in North Carolina require me to operate some kind of lending library of innumerable documents. remembered or imagined, that you ask me to find any copy and forward to you or your family, Bear in mind it is not the copying costs but the human time involved in locating these documents in the tiles After a long trial my files are shape) by the sequence of events of the trial itself. Sometimes items are put back in the file in a random way because they were pulled out for a short time for review before particular witness was called to the stand or for motions that may have been heard in court. My personal work product is not separate and Mr. Ronnie Kimble Page Two distinct
from the documents given to me to prepare for trial. Since 1 am
entitled to keep my work product it makes it difficult for me to
turn over items of pretrial discovery and other documents that may
be given to me during the preparation stages of a trial. l am sure
you can understand this because all of the documents in your case
were personally reviewed by you in the jail. As I wrote
to you on June 22, "You participated in the preparation arid
evaluation of every material witness..." who appeared in your trial
with the possible exception of Dr. Wilmington, and the decision not
to call Dr. Wilmington was made by David and myself because we
believed that his testimony would hurt more than help you. In your
letter of April 19 you have turned to the subject of Janet Smith.
Your first request is for copies of the warrant. I cannot find this
and since it is a matter of public record, your parents can obtain
it as easily as I can. You request all original letters from Janet
Smith that you supposedly turned over to David Lloyd and me. Because
I am not sure that the Janet Smith matter is entirely over, I am
going to decline to turn over originals to you at this time.
However, I am enclosing transcripts prepared by the State and copies
made by me and reviewed by you. You asked
for a memorandum circulated by Detective Church at the detention
center. I have never heard of such a memorandum and do not have it
in my file. You asked for specific dates of all hearings prior to
trial. The only hearing I recall involving Janet Smith was a voir
dire in the murder trial to determine the admissibility of your
statement to the effect that you would lie to protect her. Obviously
since it was used in the murder trial you can obtain it yourself in
the trial transcript. Very truly yours,
/signature/ John B. Hatfield, Jr.
JBHjr/ph Enclosures Enclosures include: (see PDF)
Plea Offer, 8/14/98 Media article, May 19, 1998 4 page letter from Janet Smith to Ronnie Kimble
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