0260 Page – Leo Frank Georgia Supreme Court Appeals Records, 1913, 1914

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EXHIBIT E.

STATE OF GEORGIA,
COUNTY OF FULTON.

State of Georgia,
Fulton Superior Court.

VS.

Leo M. Frank.

Before me personally appear L. Z. Rosser, Morris Brandon, R.
R. Arnold and H. J. Haas, who, being duly sworn, deposes and
says that they are the sole counsel of defendant in the above
case, and they make this affidavit to be used as evidence on the
motion for new trial in said case.

Further deposing they say that, since the trial of said case
and the verdict and sentence therein, it has come to their
knowledge that two of the jurors who sat on said case, to-wit
A. L. Hansford and A. H. Henslee, were prejudiced, partial and
biased against Leo M. Frank, the defendant as evidence by
affidavits attached to motion and hereinafter referred to; that
said prejudice, partiality and bias were present on their part,
when said Hansford and Henslee qualified as jurors in said
case as shown by said affidavits, but that the facts were
unknown to these deponents at the time of the trial of said case,
and at the time said jurors qualified upon voir dire of said
case, and these deponents had no means of knowing said facts
until after said trial.

Further deposing, they say that not until after the trial
of said case did they know or have any means of knowing that
said Hansford and Henslee or either of them, had made any
statement of any kind to, or in the presence of, any of the
following persons, to-wit: H. C. Leventhart, Mrs. J. S. Loven-
hart, Miss Marian Lovenhart, S. A. Vack Parks, R. L. Greener,
Jno. M. Holmes, S. H. Gray, S. V. Johnson, J. J. Nunnally,
W. L. Ricker, J. A. Lehman, C. P. Stough or any other person,
concerning said Leo Frank in connection with the murder
of Mary Phagan, or in connection with said trial, or the possible
outcome of said trial.

Further deposing they say that they have been guilty of no
laches in this matter, but that they have used every means of
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