1491 Sheet – Supreme Court Georgia Appeals of Leo Frank, 1913, 1914

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said paper, which was introduced on the trial of the original
case, said Conley said, responding to said rule:

"11. Respondent shows that through no fault of the County
Sheriff, a sufficient inside force of guards has been provided
by the County Authorities, only one man being paid by the
County to guard twenty cell blocks distributed in twenty wings
and over five floors; that it is a physical impossibility for
this one man to keep up or even know what is transpiring on five
different floors, or twenty separate immense wall and steel
blocks, distributed through a large building; that with this
inadequate force, which this Respondent is advised the Sheriff
of this County has complained about, it is an absolute impos-
sibility for the best Sheriff in the world or the best trained
deputies to know exactly what is going on at any and all times
or any reasonable part of the time; that the keys to practically
all of the cell blocks are carried by 'convicted criminals',
known as 'trusties', who turn in and out parties entering or
leaving cell blocks, and while they have general instructions
covering their duties, it is an impossibility for the inside
deputy to know whether each is discharging his duty properly at
all times; that the food is prepared and distributed in the
County prison itself and practically by 'convicted criminals,'
whose disregard for law and principle is written upon the crim-
inal records of this State, that owing to this condition men
have been known to saw through solid steel bars and cages and
escape to freedom; that it would be easy for anyone to reach or
harm respondent or to poison him through his food, that the
'trusty turn keys' who are convicts can easily swear to admis-
sions against the interest of this respondent, even though such
admissions might not be made; that the friends of the Defendant
in this case are allowed to pour constantly into the jail at all
hours of the day and up to a late hour of the night, and are in
close touch with many of these 'trusty turnkeys', and 'trusty
attaches' of the jail; that while a prisoner at the County Prison
before his transfer to the City Prison, a goodly number of
people were admitted to the cell block to talk with Respondent,