0858 Sheet – Supreme Court Georgia Appeals of Leo Frank, 1913, 1914

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Q. How long had Snowball worked at the factory?
A. I don't know, sir.
Q. Now, that time, when you watched in January, was Snowball there that day—I believe you said it was Wednesday?
A. Yes, sir, I said I watched there in January.
Q. Well, was Snowball there?
A. I don't know whether he was or not?
Q. Now, the only time you ever heard Mr. Frank say anything in front of Snowball was that time you have just mentioned? Thanksgiving, is that what you said?
A. Yes, sir.
Q. You heard him say something before Snowball then?
A. One time was in January.
Q. Where was that, in January?
A. He said that in the box room. In the box room, he told me.
Q. Snowball was in there?
A. Yes, sir, he was helping me to stand the boxes.
Q. Snowball was in there?
A. Yes, sir, he was helping me to stand the boxes.
Q. He walked up there and told you before Snowball?
A. I don't know whether he knew Snowball was there or not.
Q. Was he close to Mr. Frank?
A. No, sir, Snowball was sitting up in the rack.
Q. Was he in sight, or not?
A. Yes, sir, he was in front of the little partition, between me and Mr. Frank.
Q. You could see him, could you?
A. No, sir, I couldn't see him from where he was standing, but I knowed he was there.
Q. Mr. Frank wouldn't hide it from Snowball; he would talk before Snowball all right?
A. I don't guess he would if he had seen him.
Q. Tell a single one he has ever talked to you about, except business, before that first time you watched for him. Give us the day and time he ever talked to you, and what he talked about?
A. I couldn't give you the day or time, except about that at all. The time he talked to me was ever with you, prior to the time he talked to me the day before he talked to you the day before you watched for him?
A. I couldn't give you the date. I couldn't tell you the date about it at all—how long was that before the day you watched for him?
A. I don't know, just directly after Mr. Darley had had him.
Q. That was after he had had that talk with you that you are talking about?
A. After he had what talk with me?
Q. The one that he had with you in the elevator?
A. Yes, sir, that was after that time.
Q. The first time you ever saw him have any talk at all with Snowball, except on business, was that day he talked about that girl right before you and Snowball?
A. Yes, sir, that was the first day.
Q. That is the first time?
A. Yes, sir, the first time I saw him talk in front of Snowball.
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