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HATFIELD &
HATFIELD June 4, 1998 Mr. W. David
Lloyd Attorney at Law Dear David: I hope you
had a good time in California and that you made it back safely. As you can
see from the enclosed materials, I have given quite a bit of thought
to the new charges against Ronnie Kimble. Included
herewith is an unfiled Motion to Continue the murder, arson and
conspiracy to commit murder cases that I hope you will be willing to
sign and file. I think that we need to make it clear to R. E. Panosh
in no uncertain terms that we are not going to sit back and let him
confuse the issue of the murder case with this absurd sexual case.
The reason I want to file the motion immediately is because I want
Panosh and Sheriff Barnes to see they are not going to be able to
orchestrate adverse publicity about Ronnie a few weeks before the
murder trial. Obviously we
will have to file a Motion in Limine in the murder case that tracks
the things I set out in the Motion to Continue but if we can get a
continuance, we might get a severance along with it. Think about
this very carefully. Do whatever you think is right but file the
motion if you feel comfortable doing so. Also enclosed is a Memorandum I wrote after talking to Percy Wall. I think Percy is of a mind to coordinate his defense with us and I think his client clearly told him there was no sexual intercourse or sexual act. I do not believe I put in the memo Mr. W. David Lloyd Page Two that Janet
believes there is an informant/snitch who may have participated in
the investigation. Since Ronnie and Janet deny any sexual activity,
the only way Panosh can come close to his objective is if he had
someone peering through a window or standing around a corner.
Perhaps we will learn about this at a later date. I have
talked to Roy Forest and Susan Moore at the Sheriff's Department.
Included herewith is a copy of a letter to Susan Moore. I think this
will give us some insight about the practices and procedures and may
tell us that the detention officers were unjustified in their
treatment of Ronnie Kimble. Although Air
France is on strike, we made other arrangements and will be in
France for a week. We will back June 15 and I will talk to you then. Very truly
yours, /signature/ John B. Hatfield, Jr.
JBHjr/ph Enclosures
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