I, Joe Hutchison, declare as follows:

1. I am Michael Hutchisonís father. I was born in Wynne, Arkansas in 1956 and have lived in this state for most of my life. My parents were both hardworking people. My dad worked for Great Dane Trailers for about 20 years. He worked at the plant in Memphis where they make the flatbed trailers. My mom worked for a drug store for about 15 years. When I was younger, I liked to pass my time by going to the arcades, riding my motorcycle, and going to the movies. I also enjoyed playing for my junior highschool football team as a defensive end and a center. I quit going to highschool when I was in the tenth grade. I did not like attending school at the time and I knew that I could get my GED without having to spend all of that time in school. I studied for the 10th, 11th, and 12th grade portions of the GED in 10 hours and placed in the top 5 of those that took the GED. I went to junior college for a year studying to be a C.P.A. I always liked math and did pretty well in it but after a year in junior college, I decided that I did not want to continue so I quit going.

2. I met my first wife, Pam, through my sister Pat. Pat and Pam were really good friends when we were in highschool. I liked Pam from the beginning but I donít know if she felt the same about me. I had a driverís license and because of that I went over to her house to take her mama into town and when I went over to her house I saw her. I was persistent with her and she finally let me take her to a local fair. Before long we were trying to get married. Pam and I ran off a couple of times but the city clerks did not let us get married because of our age. Pamís parents told us that they would prefer that we go with her mom and get married legally. Pamís mom drove us to New Mexico and we got married in October of 1973. Right before Pam and I married, I enlisted in the Navy and I left for the Navy shortly before we got married. One thing that I have always been is a little hard headed and that got me into a little trouble there. One time, a major gave me an order and I refused to follow it. Because of that, I was asked to leave.

3. Not too long after we got married, Pam got pregnant with our first child, Michael. She had a really hard time during this pregnancy. I remember she threw up a lot and lost a lot of weight. There was a period when we thought that the baby might not even be alive because Pam was so small and the doctor did not detect any movement inside of her. Thankfully though, Pam felt Michael kicking inside of her shortly before she gave birth and she delivered him on December 11, 1974. Sometime, not too long after that, Pamela had a miscarriage. We did not know that she was pregnant until this happened. Her next pregnancy was not much easier for her. She really swelled up during her pregnancy with our daughter Michelle. The labor was really difficult for her because she was not able to use an painkillers because, in her condition, taking painkillers would have been dangerous.

4. When Michael was a baby, I remember that he cried a lot. Pamela did a good job getting him to sleep but I remember that it took a lot of energy to do. Michael used to get awfully upset to where he banged his head against the ground and cried and cried. One time he banged his head really hard against some concrete and when he lifted his head up, his entire forehead was really red. One of the things that Michael always seemed to get was strep throat. It seems like he got it almost every year around the same time of the year. He also got some really bad allergies and he had to get a shot for them.

5. When the kids were growing up, times were hard. I had a hard time finding steady work and because of that there were times when we had to live with our friends, the Sanders. Randy Sanders was my best friend and he had a wife and some kids just like me. Much of the time, either he or I was out of work and we helped to support each otherís families. I moved a lot when the kids were growing up. Sometimes, I think that it might be easier to tell people where I have not lived instead of all of the places that I have lived. During the time that Damien was born and the time that I left their mama in 1986 we lived in a bunch of different places. Some of the places where were lived were Memphis, Tennessee; West Memphis, Arkansas; Louisiana, Texas, Maryland, and Mississippi. Since it was hard to find work, I thought that it was a good idea to go to another state and I remember when we went to Louisiana, we only stayed for about three weeks because I did not like it at all.

6. When Michael was younger he had some close friends and seemed to be doing okay. It was right about the time that I left Pamela that he seemed to be getting less sociable and more shy. When Michael was eight and Michelle was six, I left their mama. At the time, I was working with a company called Allison. I did sandblasting for them. They paid me really well and Pam started looking around for a house. She wanted to buy this house and have me pay a monthly note of over $400.00. I did not think that we could afford this because, even though Allison paid good money, every November they fired most of their employees. During the winter, the demand for sandblasting work slows down and because of that we were always laid off. Allison always rehired me but not until around February and in the mean time I only made a little above $100 in unemployment. Because I made so little during those few months, I knew that I could not afford that bank note. After I told Pam that we could not afford the house, she went and found this trailer that she wanted me to buy. Well, it was the same situation, even though the trailer was cheaper there were going to be the same months when I could not afford the payment. Anyway, Pam told me that if I did not want to buy her a house then I should just go on. In 1986, I left her and moved to Memphis where I lived for a few years.

7. I have found out that Michael had a lot of problems starting around the time I left. I grew up in a strict household and my daddy made it clear what I could and could not do. Because of growing up that way, I am not afraid to tear up a tail. I think that if I had been with Michael all of those later years, then Michael would not have had so many difficulties.

8. After we got divorced, I moved to Memphis for a few years. I worked for trucking companies during that time. One of the trucking companies that I worked for had me start the day in Mississippi and make my way up the interstate. By the end of the day, I had traveled over 400 miles. I did that almost everyday for awhile. After four years in Memphis, I moved to Oregon. I got a job running five BP gasoline stations. I made sure that there were people attending the gas station and then I took care of the paper work. I remember one day I got a call from Pamela telling me that the kids wanted to change their names. Both of them changed their last names and Michael changed his first name to Damien. It does not matter to me what his official name is because I will always think of Michael as being Michael. When he was born, I was the one who came up with his name. His full name used to be Michael Wayne Hutchison. Wayne is the name of one of my cousins and I have always liked the name Michael so that is what we named him.

9. In about 1991, I got a call from my daughter Michelle and she told me that she wanted to get to know me better. Before long, I was moving back to West Memphis so that I could be there for her. When I moved down there, I did not have intentions of getting back together with Pam but, when we saw each other, it was not long before we realized that we wanted to be together again. I told Pam that I thought we should move to Oregon and we packed up the family and took off. Michael was having a really hard time then. He had just broken up with his girlfriend Deanna and cried the entire ride up there. He was just really, really sad. When we got to Oregon, I set Michael up with a job at one of the BP gas stations that I ran. I thought Michael could do a really good job working there and I was hoping that everything was going to work out.

10. While we were in Oregon, Michael got really sad, like the time when we were driving up there. One day he locked himself up in a closet and had taken something in there with him. His grandmom told me that Michael had a knife. I thought that this was really serious and Pam and I made him go to a hospital in Oregon. Michael got really upset with me and I lost my temper and, after I yelled at him, he got even more upset. I feel bad about this whole incident because what started it was when Michaelís grandmom told me that he had a knife. I do not know why I immediately trusted her, instead of checking it out, but what I found out later was that Michael may have just had a spoon with him. Once Michael got out of the hospital he went back to West Memphis on a bus and did not seem to want to have anything to do with me or Pam. He did not have any way to suport himself but he went down there anyway. Pamela, Michelle, her mother, and I all stayed up in Oregon for a few months longer. Pam eventually insisted that we go back to West Memphis so that she could be with Michael because his girlfriend Domini was pregnant. It was not too long after we all arrived back in Arkansas, that Michael started being questioned by the police.

11. On June 3, 1993, Pamela, Randy and Susan Sanders, and I drove up to the trailer that we were staying at and saw all of these police officers in and around the trailer. I had known that they were questioning Michael but I had no idea that he was going to be arrested. When we first went to the trailer a policeman told me that I could not enter it. I did not listen to him and I walked in the trailer and Michelle told me that Michael and his friend Jason had been arrested and taken away. Not too long after that day, I found out that they were keeping Michael at the Monroe County Jail. I went down to visit him as much as I could. He was very upset and depressed every time that I went down there. Michael was not himself when he was in jail and did not seem to know what was going on. Michael was losing a lot of weight while he was in the jail and I was really worried for him. I kept telling him to just hang on and everything was going to turn out okay.

12. I met Val Price and Scott Davidson at their law offices. I went up there two times for about 30 minutes each time. The trial was extremely stressful on me. Pam and I sold most of our possessions so that we could afford to drive up to Jonesboro everyday of the trial. It was very important to me to be able to support Michael. We did not have our own place at that time and we stayed with Pamís friend Anita. I remember that right after the guilty verdict, Mr. Price told me that I was going to be testifying during the penalty phase. I answered his questions as best I could. If anyone would have asked me to tell about Michaelís life and the problems our family had, I would have told them the truth and answered their questions. Right after the trial, Pamela and I broke up again. The stress of the trial was too much for our marriage to handle. I have not seen Michael for a long time and miss him very much. I think about him often and pray that he is doing okay.

I declare under penalty of perjury under the laws of the United States and the State of Arkansas that the foregoing is true and correct and executed this 3 day of September, 2000 in the County of Crittenden.

Eddie Joe Huchison (signature)