From the Direct Examination by Hon. Samuel Leibowitz

Q    Your name is Lester Carter?

A    Yes sir.

Q    How old are you?

A    I am twenty two, the 16th day of May.

*    *    *    *    *    *    *    *    *    *

Q    Lester back in 1931 were you in the jail at Huntsville?

A    Yes sir.

Q    You were a prisoner there and served some time for vagrancy or hoboing or something?

A    Yes sir.

Q    I mean Huntsville in the State of Alabama?

A    Yes sir.

Q    Did you meet a young lady there in jail, also an inmate of the jail serving time, by the name of Victoria Price?

A    Yes sir.

Q    You became acquainted with her in the jail?

A    Yes sir.

Q    While you were serving time there did you meet a man there too?

A    Yes sir.

Q    What was his name?

A    Jack Tiller.

Q    Who made you acquainted with Victoria Price in jail?

A    Jack Tiller.

*    *    *    *    *    *    *    *    *    *

Q    After you were put in jail you met Ruby Bates who was visiting these folks in the jail?

A    Yes sir.

Q    Who introduced you to Ruby Bates?

A    Victoria Price

*    *    *    *    *    *    *    *    *    *

Q    Where was the first time you saw Victoria Price outside the jail?

A    That was one afternoon late as she was coming out of the mill from work, Tiller and I met her there.

Q    Is that the mill at Huntsville?

A    Yes sir.

Q    Where did you go that night, if anyplace?

A    We went to Mrs. Price's home.

Q    Where Victoria lived?

A    Yes sir.

*    *    *    *    *    *    *    *    *    *

Q    Describe her house?

A    It was a small long built house, some people call them shot-gun houses, which has a little porch in the front, small porch with a door, small door; we entered the first room and there was a bed, which I would judge to be a wooden bed, and on the wall were a few pictures, and I noticed a hand Victrola sitting on the table.

*    *    *    *    *    *    *    *    *    *

Q    Go ahead, the first night you say at the house you made an appointment for the next night?

A    Yes sir, to meet the girls Victoria Price and Ruby Bates, Jack and I were to meet them at the mill.

Q    What time?

A    Near seven o'clock.

Q    Did you meet them that night, the second night?

A    Yes sir.

Q    What happened, tell the jury?

A    Well Jack Tiller and Victoria Price said they knew where we could go and see fun, take a walk for instance.

Q    Go ahead, what happened?

A    We walked up the N.C. Railroad yards until we came to the woods, jungles.

*    *    *    *    *    *    *    *    *    *

Q    What occurred in the jungles that night?

A    I had intercourse with Ruby Bates and Jack Tiller had intercourse with Victoria Price.

COURT:    I will exclude he had intercourse with Ruby Bates, but Jack Tiller had intercourse with Victoria Price is permitted to go to the jury.

Q    Did you see Jack Tiller have intercourse with Victoria Price?

A    Yes sir.

Q    Where was that intercourse had?

A    The first time was in the jungles, in the woods.

Q    Where, on what?

A    On the grass.

Q    That was at night about what time?

A    That must have been around eight or nine o'clock.

Q    What happened after that?

A    It went to raining.

Q    Go ahead?

A    We came back down to the N.C. Railroad and got in an empty box car and remained there the rest of the night.

Q    Who got in the empty box car?

A    We had a couple more intercourses with the girls.

COURT:    Don't tell about what you did, what happened to Victoria Price.

Q    What happened to Victoria Price?

A    They had another intercourse there.

Q    You say you all stayed there all night?

A    Yes sir.

Q    What did you do in the box car besides have intercourse, what else did you do in the box car?

A    We talked and started planning this hobo trip; they said they wanted to go to Chattanooga, or some town away from there, that they were getting sick of the place at the mill, it didn't pay enough wages, and we could go some place, and they could "hustle" the town and Jack and I could get a job and work and have that much money between us four.

Q    That was the night in the box car that was talked about?

A    Yes sir.

Q    You are sure Tiller and you and the two girls were there?

A    Yes sir.

COURT:    Did Victoria Price know you as Lester Carter.

A    Yes sir.

*    *    *    *    *    *    *    *    *    *

Q    Tell these twelve men in the jury box what happened from that time on between you and the girls or anybody else--first tell us about what time you got in Chattanooga?

A    It must have been around eight o'clock in the evening, We got off of this train together, us three, Victoria Price, Ruby Bates and myself, and we started walking around and looking for some place to sleep, for we were all broke, no money.  We met a boy who called himself--

COURT:    Victoria Price you say?

A    Yes sir.  We met a boy who said his name was Carolina Slim, you know that is a railroad name, and I found out later his name was Orville Gilley, and he asked me for a match for instance to stop me for a conversation; I give him a match and made him acquainted with Victoria Price; he said he was accustomed to the jungles--

COURT:    That was in the presence of Victoria Price?

A    Yes sir, Victoria Price and Gilley, Ruby Bates and myself.  We hiked up the spur track of the railroad going toward the jungles;  Gilley was going to show us the jungles, he said he knew about them and where we could stay.

*    *    *    *    *    *    *    *    *    *

Q    Did you stay in the jungles all night?

A    Yes sir, until about four o'clock in the morning.

*    *    *    *    *    *    *    *    *    *

Q    You were on your way back to the jungles at that time?

A    Yes sir.

Q    Tell these men what you saw at that time and place with reference to Victoria Price?

A    Those girls had moved from the destination they were supposed to wait for us guys, so I seen them at a distance away down in the flat jungles, that is the main part of the jungles with some negro men sitting on a log by a camp fire.

Q    State how they were sitting with the negroes?

A    Sitting close along with each other, it was a distance away you know from me sitting on the log facing the negroes.

*    *    *    *    *    *    *    *    *    *

Q    What happened in the jail yard between Victoria Price and anybody else?

A    Victoria Price she motioned to me to come to the car which her and Ruby Bates was sitting in; I didn't go, I was as close from the car as you and I are now;  I didn't go to the car, but Odel Gladwel, the boy standing by me he went to see what she wanted, and I heard her say to Odel, one of you boys has got to play like you are my brother, if you don't we will be arrested for hoboing, and Odel said it is O.K. with me, he says I will be your brother.

*    *    *    *    *    *    *    *    *    *

Q    What else was said between Gilley and Victoria Price about what had happened on the train?

A    Victoria Price said to Gilley, if you don't testify according to me-- I am the oldest and will go on the stand first, and if you  don't testify according to what I testify I will see you are took off the witness stand, and Gilley told her to go to Hell he didn't care for that, he was going to tell his own story about this, and she said she would not cook no more for me and Gilley, and said if we wanted anything to eat we would eat the jail feed there.

Q    Was there anything said about, between Gilley and Victoria Price in your presence about the negroes raping them?

A    She said, what the Hell do we care about negroes.

*    *    *    *    *    *    *    *    *    *

From the cross examination by Attorney General Knight
Q    You have been to New York?

A    In the past few weeks.

*    *    *    *    *    *    *    *    *    *

Q    What place in New York did you stop first?

A    I looked up the number of Attorney Brodsky.

Q    Did you go to Mr. Brodsky before you went to see Mr. Roosevelt?

A    That was last summer when I went to see Roosevelt.

Q    You say you went into the Governor's office.

A    I went to the Government building and I went up to where his room was supposed to be and spoke a few words with a guy.

Q    With whom?

A    Some fellow, he said Roosevelt didn't have time to see me about a matter like that.

*    *    *    *    *    *    *    *    *    *

Q    Who got you to New York?

A    I went alone on my own.

Q    How did you go?

A    Hitch hiked.

Q    Had you any word from anybody before you went to New York?

A    Along on the road and hoboes jungles I had talked with ministers.

Q    Out in the jungles?

A    Quite a few ministers on the road hoboing around.

Q    Ministers in the jungles too?

A    One night I talked with a mann at Winn, Arkansas, and he had a bible; he was talking to a group of us boys, and I mentioned something about the Scottsboro case--  I told him something about the Scottsboro case, and he said he would advise me to go back and tell the truth about it, because those people in Alabama would be very interested in my story; that is the reason I went to Roosevelt I wanted to clear my conscience.

Q    You never did make any statement or make any confession like that to the Attorney General of the State of Alabama?

A    No sir.

Q    You never did go to see the Governor of the State of Alabama and tell him anything about it?

A    No sir.

*    *    *    *    *    *    *    *    *    *

Q    Mr. Brodsky did ask you to come to New York and come to his office?

A    Yes sir.

*    *    *    *    *    *    *    *    *    *

Q    How long did you stay with Mr. Brodsky up there?

A    I never stayed with him, he got me a room.

Q    He paid your room rent?

A    Yes sir.

Q    Whose automobile was it you rode back?

A    I don't know.

Q    Any way you had nothing to do with furnishing that car?

A    No sir.

Q    Who drove it?

A    I don't know the fellow that drove the car, one of them was named Pete.

*    *    *    *    *    *    *    *    *    *

Q    Who furnished the expenses for that trip?

A    I bought my meals.

Q    Where did you get the money?

A    Mr. Brodsky would give me three or four dollars along.

Q    Did he pay for your meals?

A    Yes sir.

*    *    *    *    *    *    *    *    *    *

Q    Where did you get that suit of clothes?

A    I bought it in New York.

Q    Who paid for it?

A    I paid for it out of the money I would get.

Q    That Mr. Brodsky let you have?

A    Yes sir.