1254 Sheet – Supreme Court Georgia Appeals of Leo Frank, 1913, 1914

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posed largely of soap and oil, and that floor, by actual experiment, is covered to a thickness varying from a quarter to a half inch, that is, you can scrape away that much before you get down to the natural color of the wood; moreover, on top-of-that-grease-soaked-floor-the-dirt more or less-and then somebody comes along with a water sprinkler and sprinkles it to sweep it up, and they go over the top of that; it don't sink into the floor, and the result is there is coat after coat of grease and dirt on that floor. Now, with reference to those spots that are claimed to be blood that Mr. Barrett found, I don't claim they are not blood, they may have been, they are right close-to the ladies dressing room, and we have had accidents there, and by the way, in reference to those accidents, the accidents of which we have had records, are not the only accidents that have happened there; for instance, a person cuts a finger; that is an accident, we give first aid to the injured in the office, and we don't have any report on that, the only reports we have are of those accidents that incapacitates the-health, when they demand the money for the time that they have lost due to the accident, and we will have our Employers' Liability Insurance Company to pay the employees, but where people just cut their fingers and they go back to work, we don't make any record of that, and we have people cutting their fingers there very often, and when they cut their fingers, their line of travel is right by that place where Mr. Barrett found those spots, right to the office. Now, we use paint-and varnish around there, a great deal-of it, and while I don't say that this is not blood, it may be, but it could also have been paint, I have seen the girls drop bottles of paint or varnish and have them break there on the floor, I have seen that happen right close to that spot, but the main point about it is this, gentlemen: when I got down and looked at it, you could have scratched away from the top of those dark stains an accumulation of dirt that was not the accumulation of a day or two days or three days or three weeks, but it was at least three months, from off the top of those spots, without touching the spot itself. Moreover, that white stuff was unquestionably, in my opinion, an alkaline compound, and it was dry and it had-to be put on, because I have lived all-evidences-of-having been swept, so it had-to be put on the wood in a liquid state; if that had been fresh red paint, or if that had been fresh red blood, and that haskolime compound, that soap in it, which is a great solvent, should have been put on there in a liquid state, it would not have showed up white, as it showed up then, but it would have showed up either pink or red, and where the spot or blood was, or whatever it was, that stuff was white, and not pink or red.

I returned after making this examination from which I noticed two or three or four chips had been knocked up, the boys told me, by the police that morning; I returned to my office and gathered up what papers I had to take over to Montag Brothers, and I took over the financial report which I had made out the Saturday afternoon previous, and I talked it over with Mr. Sig Montag. I had a good long conversation with Mr. Montag with reference to the occurrences that morning and we decided that since the papers had