Before the undersigned Notary Public, duly qualified and acting in and for said county and state, appeared Montavious Montrail Gordon, to me well known to be the affiant herein, who stated the following under oath:
"1. My name is Montavious Gordon. My middle name is Montrail. I was born XX-XX, 1977. I have been referred to by the nickname 'Trail'.
2. I was arrested on June 15, 1993, for capital murder and I was detained in the Juvenile Detention Center in Jonesboro, Arkansas, from about June until about December 10, 1993.
3. I was brought in to the Detention Center at the same time as Leonard Haskins and another young man named Tito Coleman. I [handwritten above: pled no contest and] was eventually convicted of first-degree murder [crossed out: by guilty plea]. I was in the Varner Unit for some time after my conviction. I have been released from prison since 2002.
4. When I was at the Juvenile Detention Center, I met Jason Baldwin. He was real quiet at first and stayed in his room. It took some time before Jason would talk to me for more than a few minutes. About a month after I met him, Jason started smiling and playing cards with us from time to time. Over a period of time I got to know Jason fairly well. He and I were in the Varner Unit [handwritten above: and Grimes Unit] together.
5. In all the time I knew Jason, I never saw him get close to anybody in a week or two.
6. Though I do not recall ever harassing Jason, I do recall that from time to time people would harass him about his case. I recall the people on the Detention Center would get on him because he was supposed to have killed some kids. Some kids who were in the Center would call Jason a child killer. They would say things like 'You cut off their penises and put them under your pillow' and 'You sucked their penises'. Those kinds of things were said mainly when Jason was new in the Detention Center.
7. Jason would get upset at these sorts of things. I remember that at times he would cry when people would say those sorts of things to him.
8. I remember that sometimes people would go up to him and ask him if he did it, or would try to talk to him about his case. I remember that at least two times when this happened, Jason just walked away.
9. Jason and I did play cards together. You could play cards in the day room in the Juvenile Detention Center. I taught him how to play spades. He taught me how to play gin rummy.
10. There was never any Monopoly game in the Detention Center area where we were housed. Ms. Joyce, the lady who ran the place, didn't want us playing dice and gambling. I remember that because some people made some dice out of tissue paper and toothpaste.
11. I am not exactly sure, but I think I may remember a white kid named Michael Carson. I never remember him or anyone else having to stick up for Jason. No one ever picked on Jason physically. People might talk and name call. None of the Black guys locked up in the Detention Center threatened Jason physically.
12. There were a couple of guys at the Center who would have gone off on some guy trying to pick a fight with them. One of those people was my close friend Leonard Haskins. Leonard and I are both Black. No one ever tried to come at either of us over some problem with Jason. That never happened.
13. Ms. Joyce, the lady who ran the Center, treated us all like her kids. Any of us could go to her if we had a problem.
14. Leonard Haskins and I were like brothers while we were in the Detention Center, because we were both facing capital murder charges. If anyone like Jason had confessed to a killing, Leonard would have told me with the idea of going to the prosecutor to get a deal on our case.
15. At this point in time, between the Detention Center and the Varner Unit, [handwritten above: and Grimes Unit] I have spent years around Jason Baldwin. I have never, at any time, heard Jason tell anyone that he had anything to do with the killings of those three boys. I have never heard him admit any part of the crime. The only thing he has ever said was that he was not guilty.
16. No lawyer, policeman or investigator ever tried to ask me about the Detention Center, and what went on there until now. If anyone had, I would have answered their questions.
17. 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 9 day of June, 2004.