1061 Page – Leo Frank Georgia Supreme Court Appeals Records, 1913, 1914

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that I locked it Saturday. I did say in that affidavit it is kept locked all the time. The reason I said at the coroner's inquest that the elevator box was always locked and that I left it locked on Saturday was because I forgot to tell about that sawing. I did that sawing just after I left there Saturday. Friday evening I never heard Mr. Frank say anything to Newt Lee. When I left the factory at 11:45 on Saturday Mr. Frank said to me "You can go ahead if you want to; we will all go at noon." At about 9:30 Mr. Frank and Mr. Darley went over to Montag Bros. I have seen Gaunt talk to Mary Phagan frequently. The stairs leading from the first floor into the basement are in good condition. They haven't been used this year. They have been nailed up all the year. The area on first floor around trap-door down there was cleaned up about two weeks after the insurance people came over and went through the building.

CROSS EXAMINATION.

Mr. Denham and Mr. White were working there Saturday, up on the fourth floor. They were up there when I left the building. Anybody could have walked from the fourth floor to the second floor all day long; there was no obstruction. A man at the stairway on the third floor can see the second floor in front of the clock. The front doors were unlocked all the morning and they were still unlocked when I left. When Mr. Denham and Mr. White asked me to saw some timber for them that morning I went and got the key and unlocked the motor that runs the elevator. I left it unlocked after that. Anybody could have started the elevator running then by throwing in the switch. I am familiar with the floor back there in the metal department. It is a very dirty, greasy, stained up floor-there isn't a worse one in town. Whenever you walk along there you will fall down if you are not very particular. The floor has never been washed the three years that I have been there. You see the analines and white stuff scattered all over the floor every day and the sweepers just sweep it along together. You see spots on the floor quite frequently. We work about 100 girls in the factory. Four or five of them work in the metal room. There is a lady's dressing room right where they chipped up the spots, and right across from there is the toilet, not over six feet from it. I have seen blood spots frequently ever since I have been working there around the ladies toilets and the ladies dressing rooms; the foreladies would always tell me about it and I have often noticed it when we were working or sweeping or anything of the kind, and I would know what it meant. I would go back and have it cleaned. These spots that Barrett claims to have found I don't recall having noticed before; they would not have attracted my attention. They were right on the way to the ladies dressing room. Yes, this man Barrett discovered mighty near everything that was discovered in the building- hair, blood, and pay envelope. That's what he says. No, I have never seen Mr. Frank speak to Mary Phagan. I was at the factory at 6:30 Saturday morning. I was the first man that got there. Denham and White came in about 7 o'clock and went up on the fourth floor. They were doing some work