State of Arkansas )
) ss.
County of Craighead )

Before the undersigned Notary Public, duly qualified and acting in and for said county and state, appeared Patty Burcham, to me well known to be the affiant herein, who stated the following under oath:

"1. I, Patty Burcham, live in Jonesboro, Arkansas. I was born in 1960.

2. I began work at Jonesboro's Juvenile Detention Unit in December of 1990. I was hired by Joyce Cureton, who was the Supervisor during most of the time I worked there.

3. I received a number of hours of training for the work while I was there, including attending courses at the Arkansas Law Enforcement Training Academy, and with the American Correctional Association. The courses I took included the basic Jailer Training Course, the Juvenile Officer Certification Course as taught in Arkansas, and the Juvenile Care Worker Course as taught by the American Correctional Association, among others.

4. I had not set out to work with juveniles, but after having done some other things, in part because a number of my family and friends had been affiliated with law enforcement, as was my husband during his professional career, I decided to work at the Unit.

5. During the time I worked in the Unit the count of detainees ranged from a low end of no kids at all during one two-week stretch, to 16 on the high side. Usually it was somewhere between 4 and 16 detainees.

6. The Unit had a day room in addition to the housing cells. The day room was a large common area. One part of the common area had two tables in it. Each table had four fixed seats that could not be moved away from the tables. This area was commonly referred to by the boys in the Unit as the Bullpen.

7. When I was on duty, I would go onto the Unit, and would interact with the boys detained there. When we went into the Unit, we were under surveillance from the pod man. He was also a Detention Unit employee who sat watching television monitors that showed the various parts of the Unit. The pod man could help ensure our security by keeping us in view while we interacted with the young people on the pod.

8. Part of our jobs included keeping records about activities on the pod, and matters concerning each of the detainees. There was a daily log in which we would make entries about our observation of the detainees and various activities on the pod. If there was something unusual that we felt we needed to note, we would do so to make sure there was a record of it, and so our co-workers would have a way of knowing what had gone on during a shift that might affect them during their shift.

9. Each individual detainee had his own file, and we would also at times make entries in those files.

10. While I worked in the Unit, I had a fair amount of interaction with detainees. In order to make sure that we maintained security, as well as to keep order on the Unit, we would talk to detainees individually. We would also observe which of the detainees associated with one another. We would watch for any signs of trouble, and would keep an ear open to any talk that indicated either that an individual detainee having problems, or that there might be a matter that we needed to pay attention to.

11. Before Jason Baldwin arrived on the pod, we had heard that he would be sent to us. We knew he was being charged with the murders of the three boys in West Memphis. I remember that I was the one who gave Jason his personal hygiene products when he arrived. He was fairly small in stature, and I recall that he had long hair.

12. During the time Jason was there, he and another young man that I knew stood out. I recall Jason in part because he was good at school, and liked to read. I believe he read every book that we had available. He took his GED while he was in the Unit and he did well.

13. I never recall Jason having any trouble with any of the other detainees. Nobody ever came to me reporting that Jason had done anything wrong or unusual. He was never any part of trouble on the Unit that I know of.

14. I do not remember Jason ever being harassed by other detainees. I recall that we kept him in administrative segregation a little longer than usual when he first arrived. After we had watched him for a while, he was let out with the others, and I do not recall anything unusual happening.

15. The only fight on the Unit that I can recall was between another young man that I had known for some time, Freddie Trice, and his brother Raymond. I know that Freddie was on the Unit at the same time as Jason. Freddie was the other detainee that I remember very well.

16. After spending time around Jason, you could tell that he was a polite and gentle person. There was nothing about him that I can recall that made me think that he was violent, or would have any interest in doing violence to other people.

17. We learned to pay attention to detainees' personalities, the way they get along with other people, the signs that they might be stressed or may otherwise be a problem either for themselves or for the people around them. I never recall having to worry about Jason as a person who might cause trouble.

18. I remember that one of the other kids who was on the Unit for a few days was Michael Carson. I recall him as a Caucasian with sandy brown hair and a kind of chunky build.

19. I do not remember Jason Baldwin being close to Michael Carson. Other than remembering Carson vaguely, I do not remember much about Carson's activities on the Unit.

20. I do remember that Jason got along well with Freddie Trice, as well as with Jason Duncan. Marshall Poole, the teacher who worked with the detainees, was also close to Jason.

21. I do not remember Jason Baldwin ever discussing his case with me, or with people on the Unit. I never heard from anyone that he had discussed his case, or had said anything unusual about it. We would hear a number of things from detainees about what other people were saying, and about rumors that were floating around the Unit. I never heard anyone, staff or detainee, tell me that Jason had said anything indicating that he was involved in the killings of the three boys in West Memphis.

22. I reviewed copies of the Unit log for the night shifts of September 2, 3, and 6, 1993. I recognized my initials along the right-hand column of the logs, which would have meant that I worked those three night shifts.

23. I was in the Unit when Jason Baldwin returned after the jury had found him guilty. I remember that he looked very downhearted when he came back from court, and that he said he didn't do it. He asked me for some time alone, and I remember making arrangements so that he could get it. That was one occasion that stands out for me in which I remember Jason making a comment about his case.

24. Only one outsider to the Unit ever asked me about Jason Baldwin while he was in the Juvenile Unit. The one person who talked to me was a ["police officer" crossed out. "Sheriff dept" written above] who wanted to know what Baldwin had said to the HBO film crew that had been doing some filming on the Unit. Since I was not interested in participating in the film, I had no idea what Jason may or may not have said. That is what I told the ["officer" crossed out. "dept" written above]

25. Other than that, I was never approached by a prosecutor, a defense lawyer, or an investigator until Private Investigator Tom Quinn approached me recently and talked to me about this matter.

26. I am sure that in 1993 I had a better memory of the details of the behavior of Michael Carson, Jason Baldwin, and others on the Unit than I have now. The matters that I have covered in this affidavit are ones that I remember, and that I discussed with Investigator Tom Quinn before this affidavit was prepared for me to review.

27. Had the prosecution or defense questioned me while Jason Baldwin was at the Unit, I would have answered questions truthfully, and would have testified to the best of my knowledge and abilities.

28. If called to testify, I would state that the information set forth in this affidavit is true and correct."

Further the affiant sayeth naught.

IN WITNESS WHEREOF, I hereunto set my hand this 23 day of April, 2008.

Patty Burcham (signature)