Before the undersigned Notary Public, duly qualified and acting in and for said county and state, Sue Weaver, to me well known to be the affiant herein, who stated the following under oath:
"1. My name is Sue Weaver. I am 66 years old. I live in Trumann, Arkansas.
2. Beginning in 1989, I worked in the county jail in Jonesboro, Arkansas. I started on a part-time basis, and then went to full time beginning in March, 1989. I worked as a matron for adult females in the jail for some time.
3. After that, I worked in Juvenile Unit. When I first started working there, I was known as a Juvenile Specialist. Thereafter, I held a position known as Juvenile Detention Worker.
4. I received specialized training at the Law Enforcement Training Academy in Camden, Arkansas. We were trained to deal with some of the issues that arise with juvenile populations, including how to deal with juvenile detainees and their problems.
5. I worked at the Juvenile Detention Center under the supervision of Joyce Cureton, and was working there in 1993 and 1994 when Jason Baldwin was incarcerated in the institution. I recall Jason very well because I was aware of his case, and paid attention to him. When he was first incarcerated, all of the staff members were instructed to focus on Jason because of the nature of the charges against him. We had some concern that he might be targeted in some way by the other detainees.
6. At first, we were very protective of him, and tried to make sure that he did not come in contact, as much as possible, with other detainees. Then, after we were able to get to know him, and to see how he interacted with the other detainees, we let him interact with the others more often, but we always kept an eye on him.
7. When Jason was housed in the detention center, there were around a dozen detainees in the unit at any one time.
8. I recall that there were certain routines and procedures that were used at the Juvenile Detention Unit that helped us ensure that proper records were kept, and that we had information to help us manage the Unit, and maintain security.
9. There was a Unit log that was maintained for several purposes. As I recall, we documented how detainees were doing, how they were acting, whether any unusual incidents or matters had come up during the course of a shift. We also documented the handing out of medications, and matters like that.
10. It was also explained that we had to maintain the log for legal reasons. Also, it was clear that we kept the log to keep track of developments so that if trouble ever did emerge we could use the log book to see if we could understand better how the trouble had started in the first place.
11. Another reason that we kept things noted in the log was that the Supervisor of the Unit, Joyce Cureton, wanted things on paper. It was a procedure that she wanted us to follow.
12. From a staff member's viewpoint, having a log available allowed you to follow developments on the Unit. In addition, staff would develop knowledge of how people on the Unit behaved. Who had a big mouth, who was quiet, who among the detainees would be willing to provide you information if you talked to them one on one.
13. My memory is that during the time that Jason Baldwin was on the Unit, I spent most of the time working day shift. The routine that I remember was that the night shift person would serve breakfast at about 6 a.m. The day person would come on after that, at about 7 a.m. When I was the day person I would read over the log, and I would always talk to the night shift to make sure that I understood what had gone on the night before, and to check in on any unusual matters that might have come up. I would also be informed if a new detainee had come on to the Unit, if anyone had any complaints that needed to be followed up on, if anyone was sick, those sorts of things.
14. The next part of the usual routine on most days was that we would hand out medications, make sure that the detainees cleaned up their rooms. They were then allowed out, unless there was a reason not to allow specific detainees out. They usually went into the day room, or into the area that they called the bullpen where we had two tables.
15. A little after 11 a.m., they would be put in A/S - A/S stands for Administrative Segregation - for lunch. Usually the boys liked us to use that phrase more than they wanted to be told that they were being locked up in their cells for lunch. We would serve them lunch, and then they would be let out during the course of the afternoon for various activities.
14. The routine changed a bit on Sundays because we would let them sleep in a bit.
15. When I was on during the day, I would keep track of how the detainees on the Unit dealt with one another. I would be careful to observe when they bunched up together, or got together in a group. If I knew all of the people in the group, I would act differently than if I saw a new person surrounded by a group of others, or if I saw an unusual grouping of people. If I wasn't already on the pod, I would alert the pod worker, who was in a room that had television monitors that allowed us to be under surveillance when we got onto the pod, that I would be going onto the pod. I would then go onto the pod and talk to the boys, and that would usually break things up a bit, so that I could be sure that no trouble would develop.
16. When I was on duty, I was very conscious of where Jason Baldwin was. We were especially cautious with Jason because we were aware of the attention that his case was getting, and we also wanted to make sure that we knew how other people would react to him.
17. In the day room, Jason mostly read and drew. He really liked to draw. On occasion he might play cards. My sense was that he used to stay close to the areas where the pod workers and staff members could see him.
18. We would always pay more attention to a new kid on the Unit than we did to kids that we already knew. It always took some time before we could tell how a new detainee would act and adapt. We needed to find out how the new person would interact with staff, and how cooperative he would be.
19. When Jason was on the Unit, we also paid careful attention to how any new kid interacted with him. If any new person was hanging around Jason while I was on duty, that would have gotten my attention, because it was hard for us to predict if any newcomer might try to prey on Jason, or otherwise focus on him.
20. Generally we watched detainees that we thought might be picked on, or targeted by others, closely. After spending some time on the Unit, you formed judgments about who might be picked on by others, or otherwise taken advantage of. Jason was relatively small, and quiet. That combined with the fact that he was a defendant in a well-known case meant that a new person that we were not used to might cause a problem with him.
21. In the end, looking back, I do not recall Jason having had any problems during the shifts that I was on, but at the time, we would not have known how things would turn out.
22. Because of the amount of attention we paid to Jason during the time he spent with us, had I been contacted earlier in this case, especially either when Jason was still with us, or shortly after he left to go to prison, I would have remembered more of the detail of exactly what happened while I was in the Unit. I do know, based on records that I have been presented with in preparing this affidavit, including copies of Unit logs, that I was working the day shift on September 5, 1993. Prior to my reviewing and signing this affidavit, I was interviewed by a Private Investigator named Tom Quinn, who identified himself to me as working with the lawyers who are currently representing Jason Baldwin. Mr. Quinn showed me copies of the Unit logs.
23. Mr. Quinn has asked me if I remember a person named Michael Carson, as well as whether I remember whether I had ever seen Carson talking to Jason Baldwin when I was on duty at the Unit in September of 1993. At this point, I do not have a recollection of Michael Carson.
24. Mr. Quinn read the names to me from Juvenile Unit document dated September, 1993. I recalled a number of the detainees from this document.
25. For example, I remember Leonard Haskins, who was charged with murder. I also remember Xavier Redus, Freddie Trice and Montavius Gordon. I can generally picture the boys that I associate these names with.
26. Mr. Quinn has told me that Michael Carson is reported to have been in the Detention Unit from about September 1 to September 7, 1993. If that is the case, he would have been the kind of new detainee that I would have paid attention to, particularly if I saw him around Jason Baldwin. My concern would have been that until I had seen him for a couple of weeks or more, it would not have been clear to me whether he, unlike others I had already seen around Jason, might present some kind of a problem that we would need to deal with.
27. If I had seen Jason talking to a new detainee for any length of time I would likely have noted that down just in case something did develop at a later time, unless the interaction seemed brief and unremarkable. Based on my own observations, because Jason Baldwin was shy and usually fairly quiet, it would have been unusual for him to spend time talking to a new person that he had not been associated with before.
28. I have been told by Investigator Tom Quinn, though I do not personally remember, that September 5, 1993 was a Sunday. According to the copy of the log that I have seen, I was on duty on September 5, 1993 during the day. I would have been present beginning at about 7 a.m.
29. During the time I worked at the Detention Unit, the one who stood out of all the detainees was Jason Baldwin, in part because once I was able to observe him closely and to get to know him in the context of the Detention Center, I formed the belief that it was unlikely that Jason had been involved in an act of violence of any kind, to say nothing of a murder. I cannot say the same thing for other detainees from that period of time. It is just that Jason stood out in that respect. Part of the reason that I formed my opinion about Jason was that he gave no indications of violence whatsoever. Other detainees might talk or act in a way that indicated that they might have a propensity for violence. Jason Baldwin never did.
30. One particular incident that happened with Jason impressed me. The boys were returning to their cells, and a cell door closed on Jason's little finger. The finger was cut, and the cut bled. I vividly recall that Jason almost passed out at the sight of blood. Jason turned white as a sheet, and you could tell by looking at him that he was about to faint.
31. I remember being struck by that incident because it underlined for me that Jason Baldwin was not a person who would easily tolerate the sight of blood, let alone be involved in a situation in which he caused injury to another person, or to himself.
32. While I know that other persons involved in law enforcement felt that Jason and his co-defendants were guilty, after being around Jason, as I have indicated, I did not think that he could have participated in killing anyone, and especially killing three young boys in what was reported to be a brutal way.
33. At no time did anyone contact me about Jason during the pendency of this case, either the prosecutors, or the defense lawyers. I do recall that a local youth counselor by the name of Danny Williams would come to the Unit fairly often. I do not recall who he would visit, but I know that he was a regular visitor while I was there.
34. I ceased working at the Juvenile Detention Center shortly after Jason Baldwin was convicted.
35. If called to testify in Court, I would provide truthful and accurate testimony about all the subjects that I have covered here."
Further the affiant sayeth naught.
IN WITNESS WHEREOF, I hereunto set my hand this 23 day of April, 2008.