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Mr.
Mannix.
I'm, uh, Vucola.
Conrad Vucola. Sheriff here in Manzana County.
How do you do, Sheriff?
Subpoena. to appear and testify in the case of the people versus Harry Barlow.
Moving a little fast for me, friend.
I just came in from out of state to meet a client, Mr.
Dobby Dobson. He was supposed to meet me here at the airport.
He won't be here. Let's go.
I received a special delivery letter last night in Los Angeles.
There was a $1 ,000 cash advance in it, a round -trip ticket to Manzana, and a
note from a man I never met, a desperate man asking me for help.
Well, the letter was from the district attorney. The cash is your expert's fee
for testifying.
You can't subpoena out of state, you know. The DA couldn't risk your
I came here to meet Mr. Dobby Dobson. I don't leave until I see him.
Well, you may have a long wait.
The man at whose trial you're supposed to testify, Harry Barlow, is charged
the murder of Dobby Dobson.
Is this your DA's idea of some kind of a joke?
Well, you're here, aren't you?
Mr. Mannix, so that the court will know that you are an expert witness, would
you please state... If the court please.
Yes, Miss Richards.
Your Honor, defense stipulates acceptance of Mr. Mannix as an expert
Thank you, Counsel.
Let the record so indicate.
You may proceed, Mr. Bartlett.
Thank you, Your Honor.
Mr. Mannix, it is an accepted scientific fact in the field of criminology, is it
not? Professional criminals tend to limit their activities to special kinds
crimes, special methods used in committing these crimes.
In short, they develop a pattern in relation to the crime.
Modus operandi, a method of operation.
Isn't that correct?
Yes, referred to as an M .O.
Now, I have here three police photographs.
People's Exhibits 6 through 8.
illustrating the pattern of a specific burglary.
Now, Mr. Mannix, where there is a burglary, where the glass from a rear
is cut and a rubber suction cup is used to remove the glass,
and where the burglar uses white gloves, cheap white gloves, to
cover his fingerprints, and then he leaves the gloves at the scene of the
and where distinctive drill patterns are used, here.
to insert TNT into the safe, and where foam rubber is used to deaden the
explosion.
Would you say, Mr. Mannix, that from this method of operation, you could
identify the probable burglar as one that you previously had apprehended and
caused to be brought to justice for the crime of burglary?
Objection, Your Honor. The prosecution may not introduce evidence of a prior
criminal act for the express purpose of discrediting the defendant's character.
Your Honor.
The question is not an issue of character, but rather the method of
a burglary. The defendant is on trial for murder, not for burglary.
Murder committed during a burglary. In this case, two inseparable crimes.
The district attorney means two answers to one question.
One question raises the probability that if the defendant committed a prior
burglary, then perhaps he committed this one.
And if he committed this burglary, then chances are that he also committed the
murder. When an expert witness identifies a probable burglar from his
operation, then simultaneously he identifies the murderer.
I assume both counsels are arguing this legal point for the benefit of the
bench. Your Honor, the evidence to be adduced is totally inadmissible. Not
the answer, but the question itself is highly prejudicial.
The defense moves these proceedings be declared a mistrial.
Your motive is good, Miss Richards, but your law is wrong.
Your Honor... Motion denied.
Objection overruled. But, Your Honor...
Now, Mr. Maddox,
from this method of operation, this modus operandi, this M .O., could you
identify the probable burglar?
Yes. And in all your years of investigating, have you ever seen a
operation like this before?
Yes. In more than one person?
No. Now, isn't this true, Mr. Mannix, that seven years ago you represented an
insurance company, and during that time you investigated, pursued, and
apprehended a burglar with this method of operation?
Yes, I did.
And is that man in this courtroom?
Yes. And would you point him out, please?
The gentleman sitting at the table.
Let the record show that the expert witness is identifying the defendant,
Barlow.
Further questions, Your Honor?
The defense may cross -examine.
I have no questions, Your Honor.
May I please approach the bench?
Yes, Miss Richards.
Mr. Bartlett?
Yes, Miss Richards?
With the court's permission, I respectfully request to retire from this
As the court appointed me, it can appoint substitute counsel for the
defendant.
Why, Miss Richards?
This is my first appearance in court as an attorney in a criminal case.
If I keep... Making mistakes about the law, I can only lose a case, but the
defendant could lose his life.
You've placed his life in my hands, and it would seem that they are not
competent hands.
It takes a great deal of courage to make an admission like that, Miss Richards.
The same kind of courage that made your late father, Jack Richards, one of the
finest trial lawyers in this state.
For his sake.
For your own sake.
I want you to think this over.
The defense is granted a 24 -hour continuance.
Court adjourned.
I'm very sorry.
She doesn't want to talk to you, even off the stand.
I called and made a reservation for you on the next plane back to L .A.
You can just make it if I drive you to the airport now.
Thanks, Sheriff.
It is a little chilly here in Manzana.
That lady lawyer's old man, Big Jack Richards, ever known him?
I've seen him in court once or twice.
Mr. Advocate.
Fighter? Who?
Me. He was the kind you took your hat off to even while he was beating the tar
right out of you, which was mostly all of the time.
In fact, he never once lost a criminal case.
That's more than he'll be able to say for his daughter.
Yeah, it's a shame. The girl lives only for the memory of her father while
they're loading the plane.
Have a nice trip and no hard feelings.
My usual expert witness fee is $300 for the day.
You can return the balance to the DA.
I changed my mind. I'd like to cancel off flight 31 after you took it.
Thank you.
Easy, Max.
Just go back the way you came.
You missed one plane to L .A.
There'll be another in about an hour.
Be on it.
I signed resignation from the case.
If you think that's news, Vera, you're free to print it.
As a newspaper woman, I'll print it.
But as a friend, I've got to tell you, I think you're making a mistake, Phyllis.
This is an admission of incompetence.
It's a confession.
I failed.
I failed my father.
What about your client, Harry Barlow?
Did you fail him?
What could I do after your testimony?
You know, if you'd been less concerned with yourself and more concerned with
your client, you might have cross -examined me instead of passing.
You would have asked questions the DA didn't and wouldn't.
You might have got the fact into the record that Harry Barlow, as a burglar
20 years, never once resorted to violence, even when he was caught in the
You know...
I saw your father argue a case once, and he was scared.
He could tell the way he fought to keep his hands from shaking.
The way the sweat stained through the back of his jacket on a cool day. But he
had guts.
Not because he had no fear, but because he fought hard, despite the fear.
But you, you're afraid.
So you're on.
Tomorrow morning early.
I want to see your client, Harry Barlow.
You all right?
I'm Vera Hilsman. I write for the morning news.
Well, do me a favor. Keep this out of the paper.
It's bad for business.
Put you away once, Harry. You keep that Colorado face of yours shut now, and I'm
going to put you away for good.
Now, were you in on that Dobson heist?
I... I think so.
You think so?
You don't know?
Not for sure, no.
Some guy, a drifter I ran into, said he had an easy mark, so I agreed to meet
him out of town and help pull off the heist.
I... I never met him.
Handsome Harry passed up an easy mark.
Yeah, I passed it up.
Stopped in a bar before I left to have a drink, and I... You met a pretty face.
She didn't even belong in there.
Pretty all right, but square.
On the level, just all mixed up.
Some kind of family problem.
Okay, so you parked in the hill and psychoanalyzed your unhappy housewife.
You got back to your place late. What then?
The cops were waiting for me.
Searched me, the car, found five grand in bills hidden in my trunk.
Which means you want me to believe that somebody planted that stolen money in
your car before you left, before the robbery was committed?
So help me, I never laid eyes on that dough before.
I wasn't even near this Dobson's place. Didn't even know who Dobson was.
Now, I swear that you got to believe me.
This woman Barlow says he was with, what about her?
Well, he gave us her description and her name, Bonnie.
He turned the town upside down looking for her.
Mr. Mannix, if it wasn't Barlow, if there was this woman named Bonnie, then
cash in Barlow's car really was planted and Barlow is being framed.
Why would anyone want to frame Harry Barlow?
Because... Because there was another motive for the murder.
Exactly how do you know that?
You don't know it, you just kind of smell it.
By setting up an ex -con with an easy -to -copy M .O. as Patsy, kept anybody
else from looking in another direction for another motive and another murderer.
That still doesn't tell us who or why.
Yeah.
Just who is Dobby Dobson and why would anybody want to kill him?
That's got to be it. There's nothing else that even comes close to adding up.
The Max Taylor Ranch?
How do you add up a piece of cheap real estate to a utility company and come up
with a murder?
One, old man Max Taylor died.
No will, no heirs, and the state took over his property, right?
Dig. Two, the late Dobby Dobson was vice president of the Tri -State Power
Company. Now, the company needed a location for a new multimillion -dollar
nuclear power plant, right?
Still digging.
Three.
Vice President Dobson finds the old Taylor Ranch, recommends it to his
his company buys it.
Well, that's it.
One plus two plus three equals murder?
Sorry, I've just stopped digging.
You forgot to add two and a half.
Now, could Dobson have bought the Taylor Ranch himself at auction, very cheap,
and then sell it back to his company at, say, 10, 20, maybe 100 times more than
he paid for it?
No, of course he couldn't. That's illegal in this state. It's conflict of
interest. Dobson would be crazy to try a thing like that.
Sure, under his own name.
But what if he used a dummy middleman to buy and sell it for him?
Wow. Illicit profits.
And fraud.
Which could add up to murder.
Yes, but you're still guessing about this two and a half link in your chain,
aren't you?
Say, girl reporter, do you have any influence on that paper you work for?
Sometimes.
Now, if Harry, uh... Barlow's attorney couldn't find this so -called woman,
Bonnie, and chances are the murderer couldn't find her either.
She's the one witness that can destroy this frame -up.
She knows that, and she must. She's hiding to protect her life.
I want you to run a personal ad in the classified section, carefully worded,
asking this Bonnie woman to contact me here.
Will do.
Oh, and keep running that every day. Right.
Now, if you'll take me to the county recorder's office, we'll see just how
of a pipe dream that number two and a half is.
Here's what you're looking for.
A Max Taylor ranch sold to the Amos Smith Real Estate Company with a court
passing title after a share of sale.
Smith Real Estate to Tri -State Power, 1 ,500 acres.
Is there an address there for the Amos Smith Real Estate Company?
Sure thing.
Wilshireville, small town north of here.
Thanks.
Shame you had to waste your time coming here for the information. Probably got
it all sitting in your files.
In my files?
Well, your father's, I guess.
He was in here getting the same information about a week or so, I guess,
he was killed in that accident.
As a lawyer, I maintain quite a few confidence.
The Amos Smith real estate company is only one of them.
It acted as a go -between for the purchase and the subsequent resale of
Taylor ranch.
There's no secret about it. We bought 1 ,500 acres at $10 an acre.
The land's practically worthless.
Not good for farming or cattle grazing.
Actually good for nothing.
Oh, not nothing, Mr. Smith. It apparently was an ideal site for a
plant.
Not ideal, sir. It was the only site in the whole state for that kind of plant.
A power company near this, they willingly paid the asking price without
an eyelash.
Not only the fattest commission I ever earned, it was the easiest.
What did the power plant pay for the 1 ,500 acres?
Now, that's a matter between the buyer, the seller, and me.
Mr. Smith, the Tri -State Power Company is a public utility as well as being a
private corporation.
I don't have to tell you as an attorney that with a company like that, the
details of any financial transactions are available on proper inquiry.
$1 ,000 an acre.
Not bad.
Bought for $15 ,000, sold for a million and a half.
You say you acted as go -between, Mr. Smith.
Go -between for whom? I don't have to answer that question, Miss Richards.
As an attorney...
There is, you know, the matter of a lawyer -client privilege.
A lawyer and a client conspiring to break the law and hiding it under the
technicality of a lawyer -client relationship is not my idea of
Just you try to abuse that privilege, Mr. Smith.
You let me subpoena you, and just you try it.
Like father, like daughter.
Big Jack Richards.
Pious, mealy -mouthed Jack Richards.
He tried the same thing right here in this office.
A shakedown.
Negative extortion.
There's nothing illegal about it. Nothing to hide.
Big Jack Bridges didn't collect a cent of blackmail money from me and neither
will you.
Tell you the same thing I told him.
Get out.
Both of you.
The county recorder said something about an accident.
Exactly how did your father die?
An auto accident. He went off the highway and over an embankment.
Where?
On this highway.
Two miles from here.
He was on his way back from Wilshireville.
I'm seeing Amos Smith.
Now, shall we go?
You all right?
I know what you think.
My father tried to blackmail them, and they killed him. And I think we tried to
blackmail them, and they're going to kill us.
Well, I'll tell you something. My father never blackmailed anybody.
My father never blackmailed anybody.
Phyllis. No, he didn't. Phyllis!
Any suggestions?
Yeah.
You find some poor innocent slob of an ex -convict like Harry Barlow and frame
the rap on him.
Now, wait a minute, Mannix.
It's all right.
Miss Richards.
First, Mr. Mannix is assaulted.
Now, the both of you are.
But I can't tell anything from these facts, which leads me to believe that
assaults had anything, anything to do with the murder of Dobby Dobson by your
client. That's for the jury to decide once they get the evidence.
Yes, Mr. Mannix.
All the evidence.
Including this letter.
Mr. Dobson, you promised to call back and set up an appointment.
You didn't.
I tried to get you on the phone three times today.
By now I can recognize a stall when it's tried on me.
You're going to pay.
and pay through the nose.
And the longer you refuse to face that fact, the more it's going to cost you.
Dobson received that letter on the day that the man who sent it died.
He turned it over to me, charging attempted blackmail.
I thought it best just to forget the whole thing, but I'm sorry, I can't sit
it any longer.
Mr. Richards.
If you enter any evidence regarding the Taylor Ranch, I shall be forced to enter
this letter as evidence.
Two dead men will be liable for their reputations smeared.
Your father and Dobby Dobson.
You see, your father sent this letter to Mr. Dobson.
You still have your father's files?
Thanks.
Here's the...
A copy of all the proceedings involved in the sale of the Max Taylor ranch.
There's a copy of the letter that Bartlett read us from my father to Dobby
Dobson. A letter to my father and my father's reply.
From whom?
Some woman in Chicago.
Cousin of Max Taylor.
I thought the state took over the property because there was no will, no
Isn't a cousin an heir?
An heir, yes, but...
Too late under the law to inherit.
You mean by the time the cousin found Max Taylor was dead and got in touch
your father, the state legally owned the property and had a right to sell it?
In non -legal terms, that's what happened.
That's what my father told her.
He could only get her the auction price, $15 ,000.
Would that still be true if he knew and could prove that the sale of the ranch
was a fraud?
Why don't you ask what you really want to know?
Did my father know enough to have the sale set aside? Did he know enough to
blackmail Dobson?
I didn't ask that. You did.
Well, what's the difference who asked it?
The answer's the same.
Yes, he knew enough to blackmail Dobson.
If he were capable of being a blackmailer.
Martini's always make you thoughtful.
Yeah, pretty mixed up thoughts this time.
A little man who wasn't there who couldn't know.
You're late.
Mannix, has anybody answered the ad I ran this afternoon about Barlow's
girlfriend, Bonnie?
No, not a word.
Some housefrau who was out on the town for the first time in her life.
Afraid her husband or family might find out.
More scared of being heard, I guess.
Oh, I think we can just scratch that lead for now.
I'm not so sure.
I just got a phone call.
Anonymous. I think I know where she's hiding.
Wish me luck.
You, uh, tired of living?
But she's a story.
And she's a witness you've got to have.
And she's dynamite that'll blow up in anybody's face that gets close to her.
Sugar and spice and everything nice.
That's not what girl reporters are made of. Now, why find out the hard way?
So what do we do?
Call the sheriff?
All right, give me the keys to your car, the address, and then you go back to
Phyllis Richards' office and keep her company with the doors locked tight.
To everybody but me.
Thank you.
Don't you think you ought to have a doctor look at this? Oh, it's just a
scratch. You know, Harry Barlow's girlfriend wasn't there. Never had been
That so -called newspaper tip was just bait for you and me and Phyllis, maybe
all three of us. But kill us?
Why? Because we're digging too deep.
Did you get the name of that man out there?
Driver's license.
Name was Edward Lewis.
Edward Lewis?
You know him?
He used to work for the DA's office.
He got a little rough with his hands and they fired him about a year ago.
He, uh... He was involved in a couple of Dad's cases.
Violence, murder for a price.
Well, that doesn't help us. Anybody with little adult could have hired him.
I went through those files we brought up from the cellar.
And?
I went through the transcript of the trial with a fine -tooth comb.
I was looking for mistakes and inconsistencies and writing them down.
Question, Counselor. When court reconvenes tomorrow morning, are you
keep on representing Harry Barlow?
I'm not going to just represent him.
I'm going to fight for him.
Even if it means destroying your father's image?
My father was no blackmailer.
And if he was, I'm still my father's daughter.
Big Jack or Dirty Jack.
I still love him.
But I'm a lawyer with a client to defend.
Based on your investigation, Sheriff, would you please describe to the court
chain of events leading up to and including the murder of Dobby Dobson
as the authorities have been able to reconstruct that chain through the
evidence?
Well, after the safe was blown, the burglar reached inside and took out a
cash box.
Now, Dobson, who must have heard the burglar earlier, approached the burglar
pointed a gun at him.
The burglar was surprised and turned to face Dobson, still holding the metal
cash box in his hand.
Dobson stepped closer.
The burglar panicked, swung down with the metal cash box he had in his hand,
striking Dobson on the head and killed him.
Thank you, Sheriff.
No further questions.
Mr. Mannix, as an expert witness qualified to this court, Do you find the
in the sheriff's testimony consistent with the inference that Harry Barlow
struck and killed Dobby Dobson?
No, I don't.
Why not, Mr. Mannix?
If it's all right with your honor, I'd like to demonstrate physically to the
court.
Proceed with your demonstration, Mr. Mannix.
Thank you.
Miss Richards, if you'll take the part of the burglar, I will play the part of
the late Mr. Dobson.
Now, if you'll turn your back and kneel as if you were pulling a cash box out of
a safe.
What are you doing at that safe?
I'll take the cash box.
Hold it.
Now, the coroner's report lists as the cause of Dobson's death, the depressed
fracture of the lateral parietal region, the right lateral parietal region.
Now, would you hit me on this side of the head where Dobson was struck?
I can't. As long as I'm holding the box this way, I can only hit your head on
the left side.
And if you wanted to hit me on the right side, what would you do?
Right.
Now, would the defendant show his left hand to the court, please?
Partial paralysis of the left hand.
Harry Barlow can't pick up or even hold a book of matches. If his life depended
on it, he couldn't pick up anything as big and as heavy as that metal cash box.
Let the record show that the defendant has a congenital deformity of the left
hand. You may sit down.
Mr. Mannix, is it possible that Dobson had his back turned to the burglar when
the blow was struck?
A man with a gun interrupts a burglar, kneeling before an open safe, and then
turns his back on that burglar?
I don't think that's very likely.
Thank you, Mr. Mannix. You may return to the stand.
Mr. Mannix, is there any other theory which you could present at this time
would be consistent with the facts in this case?
Jackson, Your Honor, counsel is asking the witness to speculate.
The prosecution called this man to be an expert witness.
If he has been certified by this court as an expert to create inference for the
prosecution, he is equally qualified to do the same for the defense.
Objection overruled. The witness will answer the question.
Now, Mr. Mannix, is there any other theory which is consistent with the
this case?
Yes. And what is that theory?
That Harry Barlow was deliberately framed for a murder that he did not
Is there anything in the record or any knowledge which you personally have
access to which would corroborate this theory?
Yes, the facts concerning the acquisition of the Max Taylor Ranch by
company.
Mr. Mannix, you were with me last night in the sheriff's office when the
district attorney gave me a letter.
Is this the letter?
Yes.
Your Honor, I'd like to have this letter marked for purposes of identification
only.
Let the exhibit be so marked.
All right, Mr. Mannix.
Will you please read this letter?
Mr. Dobson, you promised to call back and set up an appointment. You didn't.
I tried to get you on the phone three times today.
By now, I can recognize a stall when it's tried on me.
You're going to pay and pay through the nose.
And the longer you refuse to face that fact, the more it's going to cost you.
The letter is signed by Jack Richards.
Thank you.
The district attorney characterized this letter as an attempt by my father to
blackmail Dobby Dobson.
Is that consistent?
With your theory?
Consistent, but unlikely.
Why unlikely, Mr. Mannix?
Jack Richards was not a blackmailer. He was a good lawyer fighting for a client,
fighting to dig out the truth.
I believe he was deliberately killed because he was getting close to that
What truth?
The purchase of the Max Taylor Ranch was a fraud engineered by Dobby Dobson for
an illegal profit of well over a million dollars.
Again, as an expert witness.
What about the death of Dobby Dobson?
I believe Mr. Dobson had an accomplice in the fraudulent sale of that ranch.
The accomplice killed Jack Richards.
But Dobson refused to go along with the murder and threatened exposure.
The accomplice killed Dobson and then framed Harry Barlow for that murder.
I have no further questions.
Mr.
Mannix, this, uh...
Excursion of yours into the never -never land of theory.
Is it not possible that this theory of yours is based on the fact that if the
defendant is innocent, then somebody else must be guilty?
Put in those words. Yes, Mr. Mannix, put in those words.
I suppose so, yes.
And this theatrical demonstration of yours with the left hand and the right
hand, can you state in fact and in law?
That the defendant couldn't have struck and killed the decedent by raising the
cash box with both hands?
It's possible.
And, Mr. Mannix, have you any proof, any tangible shred of evidence that this
theory of yours is anything more than a figment of your imagination?
It's what I believed happened.
No further questions, Your Honor.
Mr. Mannix.
To your knowledge, is there any such proof, proof that Harry Barlow was
proof that your theory is fact and not fiction?
Yes. What is that proof, please?
The testimony of a witness, a woman who was with Harry Barlow miles from the
Dobson house at the time Dobson was killed.
Is that witness and her testimony available to this court?
I hope to have her here in the morning when the court reconvenes.
Board is adjourned until 10 o 'clock tomorrow morning.
I'm proud of you, Counselor.
You know, whoever this Bonnie is, wherever she is, he just made a target
The murderer will kill her if he can to stop her from testifying.
I know.
I hope you've got a rabbit to pull out of that hat.
If you'll hold that.
The woman says it's an emergency. Won't talk to anybody but you.
Put her through.
Sheriff, you call her.
Sheriff, this is Bonnie.
Well, now, the world is just full of Bonnies, ma 'am. Which one are you?
Say, wait a minute. You're not the woman who was with Harry Barlow, are you?
Oh, Harry couldn't have killed that man.
He couldn't.
Well, why didn't you come forward and testify, ma 'am?
Because I'm scared, Sheriff.
I'm scared that real killer's gonna come after me. I'm scared.
Well, scared or not scared, ma 'am, you've got to testify.
A man's life depends on it.
Well, that's what Mr.
Mannix told me when I talked to him on the phone.
I said I'd come in tonight, but I'm frightened.
Ma 'am, there's nothing to be afraid of. You just relax.
Supposing that I come and get you now, you wouldn't be afraid then, would you?
Well, I... Well, where are you?
Well, I...
North of town?
Out by Grace Farms?
Is there some place I could hide till you got here and be safe?
North of town? There's not much out there.
Wait a minute. Do you know where the old Penner house, the one that's half
burned out, is?
Is it safe?
Oh, it's safe, ma 'am. It's very safe. You just go there and wait for me. And
try to stay out of sight.
All right?
Bonnie? Bonnie?
Bonnie?
This is Sheriff Eucola.
Is it safe, Sheriff?
Well, not as safe as if you'd never called me.
I'm sorry, ma 'am. I'm really sorry. I just don't have a choice.
All over, Sheriff.
Well, I figured only a law enforcement officer would think of framing an ex
with a phony M .O. and an expert witness.
That could have been me.
But it was Vucola who mentioned the fact that Phyllis and I had gone to see Amos
Smith, and only Amos Smith knew that.
And Smith telephoned Vucola.
Right.
Vucola and Dobson were partners in using Amos Smith as a front.
Which gives me a pretty good reason to pay a call to Mr. Smith.
I'm just so glad it's all over.
You know, I've got a feeling Big Jack would have liked your style.
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