Before the undersigned Notary Public, duly qualified and acting in and for said county and state, appeared Joyce Cureton, to me well known to be the affiant herein, who stated the following under oath:
"1. My name is Joyce Cureton. My date of birth is XX-XX 1944. In 1993 and 1994, I was in charge of the Juvenile Detention Center in Jonesboro, Arkansas.
2. Jason Baldwin was housed in the Detention Center pending his trial, as well as throughout his trial. I recall that the trial took place in 1993 and 1994.
3. When Jason Baldwin was delivered to our facility, the Chief Deputy Sheriff, Dickie Howell told me that Jason should never be let out of his room until trial. I was concerned about the effect that this instruction would have on Jason Baldwin's state of mind, as well as on the problems that ordering him to stay in his room would have on him for other reasons.
4. Therefore, after a time, Jason was allowed out of his room periodically. Jason was never harmed by anyone, nor showed any disrespect to anyone. He was never any trouble. However, we watched Jason closely to make sure that nothing happened to him. I personally was in the Center, and would speak with Jason, and all of the other juveniles, just to keep tabs on things.
5. We did maintain records in the juvenile facility. These records included not only a standardized form covering each juvenile entitled "Client Information" that included background on the juvenile, the juvenile's family, and other background information, but also, records of daily activities inside the unit. One of these records was called a daily sheet. The other one was entitled a juvenile night roster. These records allowed us to document staff observations of juveniles. The records of daily sheet and night roster were maintained by the staff members in the ordinary course of business.
6. I do not recall receiving any reports that anyone had threatened, or victimized, or attempted to victimize Jason Baldwin. When I was on the unit I took specific pains to try to minimize the amount of press coverage about Jason Baldwin's case that may have been shown on the unit. I suspect that there were occasions either when I was not available, or when I was not present, that the day room television was turned to news at the news times.
7. I do remember a juvenile named Michael Carson who was incarcerated in the unit during the same time as was Jason Baldwin. Michael had been in the Detention Center several times prior to Jason Baldwin's incarceration there. At one point either prior to or during the Echols and Baldwin trial, which was well publicized and which I was well aware of, Prosecutor Brent Davis asked me whether we had a file on Michael Carson. I recall being asked to produce some documents about Michael Carson, including his basic file for Mr. Davis.
8. My recollection is that at the time I had this contact with Mr. Davis I had been in touch with a person who worked with a private program for juveniles named Danny Williams. I believe that Mr. Williams had already indicated to me his knowledge of concerns about Michael Carson, and about information that Michael was purporting to have in connection with Jason Baldwin. I remember this because I formed the opinion that Mr. Davis wanted to see Michael Carson's file because Michael either might be, or was going to be, a witness in the Echols and Baldwin case. The file that I brought him would have included the client information form, and other matters customarily kept in a juvenile detainee's file.
9. Based on my contact with Jason Baldwin, I developed a positive view of him. He did not present me with any problems. I believe that he was generally liked by the young persons who were also locked up in the facility. Jason's lawyer Paul Ford called me at one point to ask me to take the stand in Jason's behalf. I told Mr. Ford that I felt that his request would put me in a tough spot.
10. After Mr. Ford called me, I called a friend to talk about Ford's request. Mr. Ford had asked me to be prepared to tell the jury what kind of a person Jason Baldwin was. My friend apparently contacted the Sheriff. The then Sheriff, Larry Emisom, instructed me to get out of Craighead County immediately. He told me that I better not be in court. My now deceased husband and l left town together, and drove to Newport in Jackson County.
11. I regretted leaving town to avoid testifying at Jason's sentencing. I would not have left if the Sheriff had not instructed me to do so. Based on my experience in the Juvenile Detention Center, including my personal observations of Jason Baldwin, and my knowledge of the records concerning his performance there, I believe I could have offered, and would have offered, truthful testimony about his good behavior, positive attitude, and positive character.
12. In addition, if called as a witness, I could have helped to authenticate the records of the juvenile detention center, and could have explained the way in which we dealt with Jason Baldwin, as well as my own observations of his interactions with other people. I never heard Jason discuss his case with any of the other juveniles there. No one, either a juvenile or a staff member, ever reported to me that Jason said anything about his case. He never was reported to have admitted his guilt to anyone. I would also have been prepared to indicate that based on my work at the juvenile detention center, my interactions with all of the juveniles at the facility, and my interactions with staff, I never learned that Michael Carson was alleging, or alleged, that Jason Baldwin had ever discussed his case, or the case facts, with him. That information surfaced after Michael Carson left our custody.
13. I recall specifically being concerned to avoid putting another juvenile in Jason's cell specifically because I did not want to have to deal with claims, whether they were true or false, that a particular juvenile had obtained information from Jason Baldwin, whose case was so well publicized. I was also concerned for Jason's safety because of the allegations in the case.
14. Based on my own observations of, and contact with, Jason Baldwin, and my discussions with other juveniles who were in the facility when he was, it is my opinion that it would have been highly unlikely for Jason to have discussed his case, or made any statements about his participation in the killings of children, with several other juveniles present in the day room. Based on my years of experience in the Juvenile Detention Center, the killing of children is a crime like certain types of crimes involving sexual activity that are viewed by juveniles, and particularly those who have been in the court system, as being particularly disgusting and objectionable. Because of his reserved demeanor, as well as because of the publicity that surrounded his ease, I view it as unlikely that Jason Baldwin would have confessed his participation in the murders of the three young children without any consequences to himself and especially without other juveniles reporting this confession either to me or to my staff.
15. Michael Carson never told me anything about an alleged confession by Jason Baldwin. If he had, I would have viewed it as my duty to report that to the law enforcement officers, and prosecutors, involved in the Echols and Baldwin matter. I believe that Michael Carson would have known to approach me on a matter of any significance to him, since he knew who I was from his prior incarcerations.
16. 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 6 day of June 04, 2004