IN THE CIRCUIT COURT OF SHELBY COUNTY,
TENNESSEE FOR THE THIRTIETH JUDICIAL
_______________________________________________
CORETTA SCOTT KING, et al,
Plaintiffs,
Vs. Case No. 97242
LOYD JOWERS, et al,
Defendants.
_
A. Leon Cohen. I reside at 1859 Poplar Pines Drive, Number 201, Memphis, 38119.
[...]
Q. Where did you live before that?
A. New York City.
Q. What did you do in New York City?
A. I was a member of the New York City Police Department. For twenty-three years.
[...]
Q. How often would you say you saw Mr. Bailey in an average week or month?
A. Two or three times a week.
Q. And you became quite friendly with him?
A. Yes, I did.
[...]
Q. Right. What did Mr. Bailey do for a living in 1968?
A. He was the owner and the manager of the Lorraine Motel.
Q. The Lorraine Motel, is that the same motel which Martin Luther King came to stay
in Memphis on April 3rd, 1968?
A. That's correct.
Q. Were you familiar with the fact that
Dr. King was coming to Memphis at that time?
A. No. I was not.
Q. When did you learn that Dr. King was in Memphis?
A. I was on my way back from Nashville when I heard the news on the radio about his
assassination. That's the first I knew of him being in Memphis.
Q. That would have been on the 4th of April that you heard this news?
A. Yes, sir.
Q. When did you next see Mr. Walter Bailey?
A. The very next morning.
Q. On the 5th of April you went to see him?
A. No. I went to take -- to look over the scene at the Lorraine Motel, and I took
some photographs while there. After I had taken photographs, I ran into Mr. Bailey.
Q. What time of the morning would that have been?
A. Between eight and nine a.m., as I best recall.
Q. So it was quite early in the morning?
A. Yes, sir.
Q. Actually where did you go to look
over this scene? Where were you? What was your path?
A. Well, I first went to the rooming house where the alleged shots had been fired
and took some photographs from the lavatory of the rooming house aiming towards the
Lorraine Motel. Then I went down and took photographs of the Lorraine Motel and
vicinity. At that time I ran into Mr. Bailey.
Q. And where did you meet Mr. Bailey?
A. Right outside his office.
Q. At the Lorraine Motel?
A. At the Lorraine Motel.
Q. Did you have a conversation with him?
A. Yes, sir, I did.
Q. And what -- how did you perceive him at that time? Was he upset? How did you view him?
A. Well, he seemed visibly upset about the occurrence.
Q. Did you ask him any questions about the incident?
A. I mentioned the terrible occurrence. He said in response, if they had listened to
me, this wouldn't have happened. And he went on to explain that the previous night, he got
a call from a member of Dr. King's group in Atlanta who wanted him to change the location
of the room where Dr. King would be staying. And he was adamantly against that because he
had provided security by the inner court for Dr. King, Dr. King's room.
Q. Where did he want Dr. King to stay in his motel?
A. There was an inner court behind the office which had very good security. In
other words, it was not exposed to public view. Per se.
[...]
Q. And, instead, where did Mr. Bailey say he was being instructed to move Dr. King?
A. The room -- I don't recall the room number, but the room which Dr. King had
occupied that night, that's the room that they wanted him to occupy.
Q. A balcony room?
A. Yes, sir.
Q. For the record, that was Room 306, that balcony room. So Bailey said he was
instructed to move Martin King from room -- well, you didn't know the number, but from a
courtyard room to a balcony room?
A. Yes, sir.
Q. Did he say he opposed that?
A. He adamantly opposed it.
Q. Did he say who in Dr. King's organization wanted him placed in that
exposed balcony room?
A. He just mentioned that a member of Dr. King's group had told him, advised him,
he wanted the room changed. He said he knew the person, but I did not question him as to
who it was or his name or pedigree or whatever.
Q. Did he indicate, when he spoke to you, if you can reflect very carefully, Mr.
Cohen, did he use the pronoun "he" or "she"?
A. He used the pronoun "he."
Q. So some male member of Dr. King's Atlanta office instructed the room change?
A. Yes, sir.
Q. Once again, when did he receive that instruction?
A. He said the previous night that Dr. King was supposed to stay there.
Q. Prior to the arrival?
A. Yes, sir.
Q. Just moving on, when you were down in that area early that morning, did you then or
had you previously had an opportunity or occasion to look at the area behind the
rooming house?
A. No. No, that was the first and last occasion.
Q. Did you look at the area that morning?
A. After the assassination, yes, sir, I did.
Q. How did it appear to you?
A. Which area are you referring to?
Q. I'm referring to the area behind the rooming house above the wall on Mulberry
Street. I could show you -- we have -- can you see this?
A. No, I can't.
[...]
Q. (BY MR. PEPPER) I'm asking you about this area here that is above the wall. There
is a wall here on Mulberry Street. I'm asking you about this area which is behind
the rooming house.
A. Uh-huh.
Q. The rooming house has two wings. There is an alleyway. This is vacant area
fenced in. I'm asking you about this. I just wondered if you had a chance to look at this.
A. Yes, I did, that very same morning I had taken the photographs.
Q. And how did it appear to you? What did you see?
A. Well, it was kind of dense with underbrush.
Q. Dense with underbrush?
A. As a matter of fact, I went to the room which James Earl Ray had occupied and
looked out the window which overlooks the alley and looked out the window intending to
take some photographs, but I never did because they wouldn't have shown anything
outside of the underbrush.
Q. So it was thick underbrush is what you are saying?
A. Yes, sir.
Q. Okay.
MR. PEPPER: Thank you, Mr. Cohen. No further questions.
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transcribed statement of Kaye Pittman Black:
Question: Without telling us exactly what was said, but did you have a
telephone conversation with Mayor Ingram on morning of April the 5th?
Answer: Yes, I did. He called somewhere between I would say seven and ten.
The reason I say seven is most of us had been up all night. A lot of us came in at seven,
some had gone home. So it would have been between seven and ten.
Question: And as a result of that conversation, did you go over to the South
Main Street area?
Answer: Yes.
Question: Where did you go and what did you observe at the South Main Street
area?
Answer: The trees which lined the embankment behind the rooming house and which
would have overlooked the Lorraine Motel had been cut and the area had been cleared and
cleaned.
Question: Would you show us the area where the trees that you are talking
about were located?
Answer: They would have been -- this faces the Lorraine back, the back of the
rooming house, correct?
Question: That's the rooming house. That's the back area of the rooming
house there.
Answer: This is where the embankment would have been where the trees
would have been. It overlooks the Lorraine.
In other words, someone here up in the rooming house would have had to look down to
the Lorraine because the embankment was taller than me, which means, you know, which
I'm not very tall, but it would have been six or eight feet tall. I think it was a
concrete embankment holding up the back of the building.
