1756 Sheet – Supreme Court Georgia Appeals of Leo Frank, 1913, 1914

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prompting her and mentioning her in his office, he did not at any time use the word lasciviousness, but when she went on the witness stand, he did use the word, and asked her if Mr.Frank's character for lasciviousness was good or bad, and she answered bad, in the face of the fact that she did not know the meaning of the word "lasciviousness", and never had it explained to her until today; and since the explanation has been made, and she understands the words, she most emphatically denies that Mr.Frank's character or reputation so far as she knew or knew of for lasciviousness. Deponent says that Mr.Frank always made the girls at the factory stop on account of his business, and that he was not generally liked by them on account of his strictness with them in his dealings with them regarding their work.
(Signed) Marie Karst"

O. W. BURKE, Sworn for the Movant. I never told Marie Karst, or any one else, that I had taken Miss Lillie Pettie out to see her sister, Miss Nellie Pettie, or that I told Marie Karst or any other person that Miss Nellie Pettie was admitted to me and her sister-in-law, Mrs. Lillie Pettie, that she had sworn on the hearing before the coroner and on the trial of the case of the State against Leo M. Frank was untrue.

O. O. KNIGHT, Sworn for the Movant. I am a Notary Public for Fulton County, Georgia, and as such took an affidavit from Miss Marie Karst on the 9th day of April, 1914. I, O. W. Burke and Dan S. Lehon, together, went to the home of Miss Marie Karst and met her in her parlor, and while there in the presence of the parties named, the affidavit dated as aforesaid was read to said Miss Marie Karst and she said it was true, and without making any objection to it, swore to it and signed it.

C. W. BURKE, DAN S. LEHON, Sworn for the Movant. Together, with J. O. Knight, a notary public, we went to the home of Miss Marie Karst, on the 9th day of April, 1914, and saw her in the parlor of her home. While there an affidavit, dated April 9th, 1914, in the Frank case, was read to said Marie Karst by the Notary Public, J. O. Knight, and after it was read to her, she stated that it was the truth, whereupon said J. O. Knight swore her and she signed it in our presence.

GROUND 15.

RABBI DAVID MARK, Sworn for the Movant. Between one thirty and two o'clock P.M. on Tuesday, April 14, 1914, accompanied by Dan S. Lehon and Mrs. Leo M. Frank and C. W. Burke, I called on Mary Rich, who conducts a small lunch wagon on the sidewalk located on West Hunter Street between Forsyth Street and Madison Avenue, said wagon being situated near the alley that runs at the rear of the National Pencil Com-