Before the undersigned Notary Public, duly qualified and acting in and for said county and state, appeared Danny Williams, to me well known to be the affiant herein, who stated the following under oath:
"1. My name is Danny Williams. I reside in Jonesboro, Arkansas. My date of birth is XX-XX 1964.
2. I attended Southeastern Oklahoma University in Durant, Oklahoma. I then worked for a program for juveniles called Youth Villages for eight years. After that, I then worked for Recovery Way which was a recovery and support program for juveniles, for around three years. As a result of my work for Recovery Way, I transferred from Oklahoma to Arkansas, and began working in Jonesboro a number of years ago.
3. My work with Recovery Way consisted in making assessments of juveniles brought to our attention, and referring youth to Recovery Way facilities.
4. I was working in Jonesboro, Arkansas at or near the time of the trial of Jason Baldwin and Damien Echols. Our program had regular interaction with the Craighead County Juvenile Office.
5. Prior to the Baldwin and Echols trial I also knew Mr. Brent Davis, the local prosecutor. My relationship with Mr. Davis was then, and is still, professional.
6. I am aware that a young man named Michael Carson testified in the Baldwin and Echols trial. I believe that it is a matter of record that my name came up in relation to Michael Carson's testimony.
7. At this point in time, I also believe that it is a matter of record that I had professional contacts with Michael Carson prior to the Echols and Baldwin trial. I worked with Michael in my professional capacity.
8. For reasons that I do not clearly recall at this time, I remember that my name came up near the time of the trial as someone who might have information on Michael Carson, and specifically information that might have a bearing on his credibility.
9. I was contacted both by the prosecution and defense. I spoke personally with Mr. Davis concerning Michael Carson. I told Mr. Davis of my opinions regarding Carson's credibility, and explained to him some specific events that caused me to believe that Michael Carson likely obtained information about the Baldwin and Echols case from me.
10. My recollection was that during the course of a meeting that I had with Michael Carson prior to the trial, I was trying to dissuade him from engaging in counter-productive and illegal activity. In doing so, I had explained to him that if he did not see certain behaviors he might end up in a situation like that of the so-called West Memphis Three. I explained to him that he might end up in detention with the sorts of persons who had mutilated bodies and cut the scrotums off of little boys. I wanted to impress Michael Carson and to motivate him to change his behavior. It was during the course of this session with Michael that I had made reference to facts that I had heard discussed in the community generally, as well as in the community that I worked in.
11. At the time of my contacts with Michael Carson I was in Court regularly in Jonesboro. I had virtually daily contact with prosecutors, defense lawyers, and court personnel. It was as a result of this situation that I would hear information about pending matters, and also it was because of that professional situation that I also knew, and had a good professional relationship with, Mr. Davis.
12. At some point either prior to, or during the Baldwin and Echols trial, I had contact with Baldwin's lawyer Paul Ford. I initiated the contact because I was bothered by a chance encounter that I had had with Michael Carson on Main Street one day. I met him unexpectedly as we were crossing the street in opposite directions. He volunteered that he was now involved in the West Memphis murder case as a witness. I was shocked and concerned because of my immediate reaction, based on my knowledge of him, that Michael Carson might be fabricating his professed knowledge of the case. I recalled immediately the conversation that I had had with him where I discussed some details of the case that I had used in the conversation that I have previously described in this affidavit.
13. Out of concern about the situation, I erred on the side of calling defense lawyer Paul Ford, with whom I did not have any kind of preexisting relationship. My concern was that I did not want to have caused a situation by which a young man that I viewed as troubled, and not credible for a number of reasons, might be professing to have knowledge that he, in fact, may not have acquired in the manner that he was claiming to have acquired it.
14. After my contact with Mr. Ford I was contacted by a law enforcement officer at my house. As a result, I had contact with Brent Davis who asked me why I would have called the defense lawyer. I explained my reasons. Mr. Davis explained his concerns about my contact. I was concerned about Mr. Davis' view of the situation in part because I need to maintain good relations with persons working in the court system in Jonesboro in order to provide effective services. I was concerned that Mr. Davis was upset with me. Our professional relationship was such that he could have contacted me informally about the matter, and asked me to talk to him. He chose to have a law enforcement officer come to my house with some form of paperwork which I took to be either an order or subpoena that I speak with him.
15. My view at the time was that Mr. Davis was in some way concerned about my conduct. It appeared to me during the course of our conversation, only some of which was taped, that while I was trying to explain to him my reasoning for feeling that Michael Carson was not being truthful, he was explaining to me his reasoning for feeling that Carson was in fact telling the truth. It affected me to think that Mr. Davis who I view as a soft-spoken gentleman, who is easy to get along with, would be concerned about my own views about Michael Carson's truthfulness in connection with the West Memphis murder case.
16. My recollection is that Mr. Davis and I had some direct words with one another about my views. I explained some specific matters that Michael Carson and I had talked about which I found out were not true. One was an episode in which Carson had claimed to have tied up his girlfriend. Mr. Davis told me in what I believe was our second meeting that he had also obtained information about this episode either from Michael Carson directly, or from another source. He seemed to agree that some of Carson's stories to people were fabrications. But he seemed upset at me for suggesting that Michael Carson was not telling the truth about how he had received information about the West Memphis murder case.
17. I was concerned that because I had spoken up in regard to this situation with Michael Carson, Mr. Davis felt that I was out of line. As noted, my relationship with Mr. Davis had, up to that point, been cordial and professional. After the trial, it has also been cordial and professional.
18. I recall being interviewed by Mr. Ford for what I believed to be testimony that he intended to present from me during the course of the trial. He and some other men working on the defense asked me a series of questions about the case shortly before I was due to be called as a witness. I was prepared to provide truthful answers to questions about my interactions with Michael Carson, and if asked and permitted to testify, I would have provided evidence about my statements to him pertinent to the West Memphis murders. I was also prepared to offer testimony, if permitted, on specific instances in which Michael Carson either told me things which he later admitted were lies, or he told me things which I established to my satisfaction were not true.
19. I never understood why I was not called to testify. After the conclusion of the Baldwin and Echols trial, I wrote a letter to Jason Baldwin expressing regret about the situation generally. I have since been contacted by several persons, including investigator Tom Quinn, who sought information from me about this matter.
20. It has been explained to me that Mr. Ford has expressed the view that he did not call me as a witness because I was changing my opinions, or my statements, concerning Michael Carson. At no time do I recall having done that. I have also been told that counsel has indicated that I may have conveyed to him my concerns that testifying for the defense might have an effect on my job. I may well have expressed that view, as I was concerned that my professional standing might be affected by my being called as a witness. However, if called, I would have testified truthfully, and would have set forth the evidence which is contained in this affidavit insofar as I was permitted to do so.
21. I have read the foregoing statements and state that they are true and accurate to the best of my knowledge and belief."
Further the affiant sayeth naught.
IN WITNESS WHEREOF, I hereunto set my hand this 8 day of June, 2004.