3 copies of these cross-examination notes are in the case file. The handwritten marginal notes, underlined words, corrections and differences on all three have been included in red

8/18

**pardee
prior record?

now you have a deal with the state  Rob was bringing materials
and that deal covers everything you have been charged with how many felony counts have you been charged with 13 x larceny 13 x b&e
those arc all class h felonies
you could get 5-6 months in prison on each of those counts and if you had been convicted of each one of htose without your deal the judge could have given you 6 months on each consectuive
aware how much time ted got 5 yrs.
 

but in exchange for your testimony in this case you are going to get probation
 

if all goes well and mr. panosh is happy satisfied with your testimony, you will not serve a day in prison
 

you arrested in this case have to spend any time in jail before you posted bond
 

in fact da Panosh has agreed to recommend you for the first offenders program
if you completed that the da Panosh would dismiss all the charges against you.
you would wlk out of hte courtroom with nothing on your
record
you would have a spotless record just like these 12 jurors

another clause to the agreement you signed, with prosecutor and that is that your agreement covers only property crimes:
if comes out that you had anything to do with a crime against a person the deal is off
would murder be a crime against a person
so what your agreement says is that if you ever admitted that you had anything to dowith patricia kimble's death, then the whole deal would be off and you would be prosecuted to the fullest extent of the law

you loaned ted $5,000-- didn't have to do that did you
 

you stole lot of building materials with ted k and rob nichols
you told police that rob nichols and ted got the whole thing started--that rob would bring in building materials and sd. he had bought them from a construction superintendant friend of his-- -->Rob started
this was ard. x-mas 96
this was before you were ever involved

ted and rob told you that they bought lumber from a friend of rob's in the construction business
this was 7-8 at night

you told investigators this lumber and building materials rob nichols was bringing in on an almost daily basis

and you told investigators that ted was buying from nichols on a daily basis
 

that he did that several times and ted bought the materials

what did he pay for them
and then he resold them
that started before x-mas
then they got you involved
you told police that the first time you went with them ted and rob told you they had bought some lumber from rob's construction friend and they wanted you tol help load it up

you told police that you thought this was a competely legitimate building materials deal
went to residential building site westridge and bryan.

this was 7 or 8 p.m. early jan
quite dark at this time
loaded up the box truck with two bundles of lumber from a house site
what was the stage of construction
you could tell that the lumber would be needed to complete the house
was that when you realized that you had just participated in stealing the lumber for someone's home
 

after that you graduated to the inner circle of this little conspiracy with ted and rob
were you treated as an equal partner
how did you split the profits
[if no profits: is it your testimony to this jury that you didn't make any money off all this theft

Total value of stolen property
 

did you and ted and rob sit around and talk about what areas you were going to hit next
which neighborhoods
get him to detail these theft outings
 

[what was the total value of what you helped steal]
 

what did you tell police when first interviewed

you got arrested in charlotte and you were brought back to g b and you told them all abt the stealing
 

signed a statement abt that didn't you

this was on april 2, 97
 

admitted to allthis stealing that you and ted and rob nichiols had been doing
 

even went out on april 2 97 and took officers tio a trialer where the loot had been stored and identified it for them
 

you never told them one word about any statements concerning patricia's death did you
 

never said one thing abt. ted admitting to having something to do with his wife's death
 

never said one word abt ronnie kimble
 

then you gave another statement on april 3

talked to detectives for a long time gave a detailed statement
you admitted to stealing more items
 

gave another statement on april 10 about theft of a trailer in oak ridge
go over it
never said one thing abt. any admissions ted supposedly made to you abt. patricia's death
in fact you didn't mention ronnie kimble's name to officers.
 

first time you ever mentioned anything abt. patricia's death was on. 4-7-97 some 5 days after you were arrested
[had to talk to your lawyer first] is that becs. youwere worried that you might be implicated in patricia's death

knew all abt. the investigation
 

did you need time to figure out how to got the governor's award
did you need time to figure out that you could parlay your association with ted into something very advantageous for you
 

ted had been arrested for murder by that time and you knew that
 

you had all that information that you later told investigators was true when you were first arrested

could have told them at that time

nothing to stop you
 

you told police in that signed april 7 statement that: "what I have told you is true and I'm telling you this bcs. I think ted should get what's coming to him for patricia's death."
you didn't mention ronnie kimble's name when you said ted should get what's coming to him for v's death
 

you really didn't know ronnie kimble
police recovered a whole lot of stolen itmes that you and ted and rob nichiols stole didn't they
so they knew the first thing you told them was true that you and ted and rob nichols had conspired. together to form this theft ring
 

tell them anything abt. anything you claim ted sd abt. wife's death
 

never said anything abt. patricia's death.

PDF