Direct Examination:

Waples: The people call Andrea Reid your Honor....We’re all nervous, just start to relax.....Between December of 1984, were you living in the Bronx?

Witness: Yes.

Waples: Are you a native New Yorker, were you born in New York?

Witness: Yes.

Waples: Do you work now?

Witness: As a part-time model.

Waples: Do you go to school?

Witness: Yes.

Waples: Now, where do you go to school now?

Witness: John James College

Waples: And what are you studying at John James?

Witness: Law, criminal justice.

Waples: And you expect to receive a degree sometime in the near future?

Witness: uh huh.

Waples: That’s a bachelor degree.

Witness: Yes.

Waples: Now are you married to the witness who previously testified in this case?

Witness: Yes, I am.

Waples: Now, Saturday, December 22, 1984 about two and half years ago, Saturday before Christmas, do you remember that day?

Witness: Yes, I do.

Waples: Did there come a time when you took a subway ride?

Witness: Yes.

Waples: Now, did there come a time when you noticed a group of young people getting on that train?

Witness: Yes.

Waples: Now, what caused you to take notice of these people?

Witness: I don’t ride the subway very often and very afraid at all times and Iam very aware of the people around me.

Waples: How many were in this group as you recall.

Witness: About four.

Waples: And how would you describe them?

Witness: Black teenagers.

Waples: And what exactly were they doing after you saw them on the train.

Witness: They were moving about swinging on the bars, banging on the seats.

Waples: Now, did there come a time Ms. Reid when you saw, or heard, one or more individuals address another passenger?

Witness: Yes.

Waples: Tell us exactly what happen.

Witness: I saw one of the young men that was sitting in the seat.  There was a white male sitting over in front of them. He said to the white male “How ya doing,” you know what’s happening man that way of speaking.

Waples: You were able to hear that?

Witness: Yes.

Waples: And how many of those persons did he address that way, ma’am?

Witness: I saw one.

Waples: Did he get up from his seat to address that person?

Witness: No.

Waples: And what, if anything, did the white man do?

Witness: He shook his head and said, “fine” and put his head, put his head back down.

Waples: What became of that white man?

Witness: He got and he left.

Waples: He got off the train?

Witness: Yes.

Waples: When you noticed that or heard that individual address the white man did you say anything to your husband?

Witness: I said, “Look at those four punks messing with that white man.”

Waples: And what exactly did you see those persons, those young men, doing that caused you to say that?

Witness: I thought there was going to be a little trouble. I didn’t think it was nice of them to approach to why would they start this big mess with him?

Waples: Did you see anyone else approach the white man?

Witness: No.

Waples: Did there come a time, before the train came to Chamber Street, Ms. Reid, when something else happened?

Witness: I heard a gunshot. I turned my head and I saw a white man standing and he was continuing shooting, he was shooting. I heard a lot of shots.

Waples: Do you know who that white man is now?

Witness: Yes.

Waples: Who is that?

Witness: I guess Bernhard Goetz.

Waples: Had you noticed him on the train at any time before you heard that first shot?

Witness: No.

Waples: Is he the same white man that you commented to your husband about when you observed or heard one of the teens addressing a person who was sitting down?

Witness: No. Actually it could’ve been. I don’t think so. I’m not sure. I thought that particular man walked off the train.

Waples: How many shots all together did you hear?

Witness: Approximately five.

Waples:  Can you try to recreate for the jury the spacing between the shots?: like bang…bang..bang.

Witness: Bang….bang..bang..bang..bang.

Waples: Between, before you heard that last shot.  Did you see the four young men approach the defendant?

Witness: No.

Waples: Before you heard that last shot did you hear any those four young men say anything to the defendant?

Witness: No.

Waples: Before you heard the shot did you see those four young men surrounding the defendant?

Witness: No.

Waples: That’s all your Honor.

Cross-examination by Barry Slotnick:

Slotnick: Now, Mrs. Reid, you are presently going to John James College of Criminal Justice?

Witness: Yes.

Slotnick:  You hope to become a police officer?

Witness: Yes.

Slotnick:  You’ve discussed this with Mr. Waples, haven’t you?

Witness: Yes.

Slotnick:  When was the last time you saw Mr. Waples?

Witness: Sunday.

Slotnick And where was that?

Witness: At my home.

Slotnick:  Now, as part of your study.  You’re about to graduate aren’t you?

Witness: Yes.

Slotnick:  You’ve  learned that criminal prosecutions are very serious things, it that right?

Witness: Yes.

Slotnick:  And whenever you talk about a criminal prosecution you’re only to tell the truth, is that right?

Witness: Yes.

Slotnick:  And you are to tell the truth to whatever side comes to you, is that correct?

Witness: Yes.

Mrs. Ried, have you told people about this case and purposely lied to them?

Witness: No.

Slotnick: In other words, whoever to spoke to about this case you told the truth?

Witness: I at times got confused.  I may have gotten confused at times and left out some details or something like that.

Slotnick:  Whoever you spoke to about this case you told the truth. I mean you know your obligation?

Slotnick:  Can we have an answer?

Witness: Yes.

Slotnick:  Now, is it true that some investigators from my office came to see you?

Witness: Yes.

Slotnick:  They came to your home, is that right?

Witness: Yes.

Slotnick:  By the way, have we ever met?

Slotnick:  I didn’t come to your home did I, the way Mr. Waples did?

Witness: No.

Slotnick:  Did you ever tell Mr. Waples that you didn’t want to come to court?

Slotnick:  Did you ever tell anybody that Mr. Waples made a deal with you? That if your husband came to testify that you just could rip up your subpoena that you wouldn’t have to come to court?

Witness: Yes.

Slotnick:  That is true isn’t it.

Witness: It’s not right in that way that you put it. The way that you put it.

Slotnick:  All right, all right, listen, listen to the following if you could: It would be very helpful. Now I’m going to ask you a question and please, try to answer the question.  I have a reason for asking you. The jury is going to decide what’s right and what’s wrong.  Now listen very carefully to the following question. Did Mr. Waples say to you that if your husband came to court to testify, you could rip up your subpoena and you wouldn’t have to come?

Witness: Yes.

Slotnick:  He gave you his word to that effect, didn’t he?

Witness: Yes.

Slotnick:  Of course he didn’t keep his word, did he?

Witness: I chose to come to court because I felt that I should not because he forced me.

Slotnick:  I see.  So when my investigator asked you about the fact of you coming to court, and you said you were very angry and you didn’t want come to court, Waples wasn’t keeping his word, you lied him?

Waples: I object to that your Honor

Slotnick:  Yes or no?

Judge: Sustained.

Slotnick:  Did you tell my investigators that you didn’t want to come to court, Waples was forcing you to come?  Now remember Mrs. Reid, you are under oath.

Witness: I don’t remember.

Slotnick:  By the way Mrs. Reid, do you know that when my investigators spoke to you they wore a tape recorder that recorded everything you said?

Witness: No.

Slotnick:  Now, let me ask you that question again. Did you tell my investigators that you didn’t want to come to court and the only reason that you were coming to court was because Mr. Waples was forcing you to come?

Witness: Maybe, maybe not, I don’t remember saying it like that.

Slotnick:  Well, do you think you might have said it?

Witness: Yes, because I didn’t want to get involved in this whole situation.

Slotnick:  And you think you also might have told my investigators that you may have seen three or four of these guys surrounding Mr. Goetz before he fired?  Do you think you might have said that too?

Witness: I don’t remember.

Slotnick:  And you think you might have told my investigators that when you said to your husband Godfrey, look at those four punks over there messing with that white man, that white man might have been Bernie Goetz?

Witness: I’m not sure.

Slotnick:  Did you also tell my investigators you were sitting on the train and you saw at least two of them go up there.  I ask you one more time did you know that what you said was being taped?

Waples: Objection, your Honor.

Slotnick:  If she knows.

Judge: Sustained.  I think that’s been answered already, Mr. Slotnick.

Slotnick:  Mrs. Reid would you please put this earphone in your ear.  If I may…. Tell us if you recognize your voice?...Do you recognize your voice?

Witness: Yes.

Slotnick:  Now does it refresh your recollection that you saw at least two of them go over the white guy? Will you try to listen to it please? 

Witness: All I hear is two of them.

Slotnick:  Are those your words, is that your voice?

Waples: Objection, your Honor.

Slotnick:  What you just heard, was that in your voice?

Witness: Yes.

Slotnick:  All right, now, when you ask these questions and did you give these answers on Wednesday, May 13^th?

Question: When you saw the four people go over to him or the two people, were they this close to him?

Answer: They were right next to him.

Question: They were right in the face, he’s sitting down?

Answer: They were standing right over him.

Did you ever give those answers to those questions to my investigators in your apartment last Wednesday night?

Witness: No.

Slotnick:  Please listen again, perhaps this will refresh your recollection.  Now I’m asking you. Does that refresh your recollection of what you told my investigators?

Witness: No, I never said "they."  I only saw one of those youths ask Bernhard Goetz a question.  I never said "they."

Slotnick:  Is it your testimony as it stands now that you never said that you saw two four people…four people, four youths standing over him?

Witness: I never saw anyone stand over him.

Slotnick:  Mrs. Reid, on last Wednesday night did you tell my investigators that when you got home you told your husband that your immediate reaction was "They got what they deserved"?

Waples: Objection.

Judge: Overruled.

Witness: I never told the detectives that, no.

Slotnick:  The investigators?

Witness:  No.

Slotnick:  All right. Will you please tell the jury when you hear your voice on the tape? And whether you said, “they got what they deserved.”

Witness: Yes.

Slotnick:  I have no further questions. Thank you very much