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1483 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to the 15th Ground, while submitting that the same does not constitute an extraordinary case, even if true, the State says that this ground, among other grounds, in view of the facts as…
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1484 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to Ground 16: In answer to Ground 16, the State contents itself with setting out a copy of an original affidavit given by Miss Helen Ferguson.Under no view of this case, could this…
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1482 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to Ground 14-1/2. With reference to this ground of the motion, the State submits affidavits of J. W. Gantt Also affidavits of Philip Chambers, As a matter of fact, no one could possibly…
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1478 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to Ground 13. The State, in answer to this ground, submitsthe evidence taken by the defendant before H.D.Smith, Commissionerappointed by this Court, and also attaches hereto affidavits by MaryRich, which not only absolutely…
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1479 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The defendant has not stated frankly at this time why he is soanxious to procure this evidence from Mary Rich.Also the State, in response to this ground, submits an affidavitof F. J. Welborn, a…
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1480 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The absolute worthlessness of the evidence of Mrs. J. B. Simmons, as referred to in Ground 13 of the extraordinary motion, has been duly disposed of in replying to the ground dedicated alone to…
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1481 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: In reply to Ground 14, the State says that, even if it be truethat the said C. Burtis Dalton has changed his evidence as given byhim on the trial of the original case, this…
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1472 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: Also with reference to Ground 9, the State respectfully refers the Court to the affidavit of Mrs. Carrie Smith, and the affidavit of Mrs. Nash, nee Griffin, flled with reference to Ground 8.With reference…
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1473 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: To Ground 10, as a full and complete answer, in view of the law obtaining with reference to such matters, the State submits that the affidavit of Mrs. Mamie Edmunds, nee Miss Mamie Kitchens,…
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1474 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to Ground 11. The State insists that no case does not constitute an extraordinary situation such as is contemplated shall exist before the Court shall set aside a solemn verdict rendered unanimously by…
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1475 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: As to Ground 12: The State submits that, at best, this evidence, if true, is merely cumulative. The plea of alibi constituted, as will be seen by reference to the brief of evidence filed…
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1476 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: on this extraordinary motion, says however, that it is nothing, butright and proper that the Court should be informed as to what Frankhimself said in the evidence on the hearing before the Coroner, as…
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1477 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: changed these statements on the trial, and said, as will be seen by reference to page 3201 of the stenographer's report; "I continued on up Forsyth street to Alabama and down Alabama to Whitehall,…
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1468 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The State submits, with reference to Ground 7, that the same is wholly insufficient; the evidence set out as having been given by Mrs. Ethel Harris Miller and MR. L. LEPOFF being merely cumulative…
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1469 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The State, answering Ground 8, submits that, under the law, the fact that Dewey Hewell has changed, if such be the fact, her evidence as given on the trial of Leo M. Frank, would…
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1470 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: Also, the affidavit given by Mrs. Maggie May, nee Griffin.These affidavits establish the falsity of the claims as containedin Ground 8, and show in a measure the tactics pursued by this defend-ent in his…
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1471 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: Answering Ground 9 of the so-called extraordinary motion of thedefendant, Leo M. Frank, the State submits, as a full and completerefutation to the said ground, even if it were otherwise sufficientin law to warrant…
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1465 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The State submits that Albert McKnight has told the absolute truth, and that no new trial could possibly, under the rules of law as laid down by the Courts, be granted under the showing…
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1466 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: 6. Referring to ground 6 with reference to the newly discovered evidence of Mrs. J. B. Simmons, the State shows, that this constitutes no satisfactory ground for a new trial, because first, this evidence…
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1463 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: 5. Replying to paragraph 5 of the extraordinary motion, the State, for answer, submits the following as being a complete answer and reason why no extraordinary motion under the law should be granted on…
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1464 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: Also the State submits as a complete answer, the affidavit ofAngus Morrison, andAlso affidavit of R. L. Craven.Also the State submits affidavit of H. B. Pickett.Also the State submits the affidavit of W. W.…
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1467 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The evidence as to the general character of this witness, is sufficient answer to the charge that the State did not introduce her, even if there had not been, as there are other reasons…
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1459 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: For one illustration of such a statement on the part of Frank's attorney aforesaid, see p. 2932 of the stenographer's report of the evidence, where he said: I have asked Miss White, a witness…
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1460 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: State, that Magnolia Kennedy, the defendant's witness, saw thehair, they failed to ask any question,with reference to theidentity of this hair, and the State could with much more showof plausibility contend that because counsel…
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1461 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: GROUND 3.In answering Ground 3, the State attaches a copy of an affidavit executed by Mrs. Cora Rich, which in itself amply disproves the contention of the defendant. The statements with reference to diligence…
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1462 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: GROUND 4.With reference to this GROUND, the same objection is urged against the granting of a new trial, as heretofore referred to.We submit that if a verdict rendered after a trial lasting approximately thirty…
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1454 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: --2--For specific answer to the several grounds, the State of Georgia hereby shows:GROUND 1.In response to Ground 1, the State says that the same is not in any view sufficient.The facts with reference to…
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1455 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: the handle and they got around my finger."Quinn was a witness for the defendant on the main trial.Miss Grace Hicks was sworn by the State, and in Vol. 1, p337, of the official stenographer's…
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1456 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: "Q. Did you discover any hair on there anywhere, identify any hair? A. Mr. Barrett called me and showed me that hair at the machine."Q. And you identified it, didn't you? A. Yes sir."Q.…
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1457 Slide – Georgia Supreme Court Leo Frank Appeals Documents, 1913, 1914

Visible Translated Text Is As Follows: The attorneys for the defendant, under the law, propoundedin this case certain questions to Dr. H. F. Harris, sworn by theState on the trial of this case, said Harris not having beenasked either by…