Trial Testimony of
JEREMEY HALLIDAY
(Brown cellmate)
Vol - -  (#20)    pp. 96 - 107   |   Friday, May 24, 1991   |   Jenny Cataldo           
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This is the testimony on Jeremy Halliday on Friday, May 24, 1991. Mr. Halliday was a cell-mate of Michael Brown and testified regarding his conversations with Brown concerning the crimes and the reward during the period immediately prior to the trial (primarily March - April 27, 1991).

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MR. SMITH: Call Mr. Halliday to the stand.

JEREMY HALLIDAY, called as a witness, was sworn and examined, testified as follows:

DIRECT EXAMINATION

BY MR. SMITH:

Q Would you state your name and address?


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A. Jeremy Halliday, 402 East Third Street, Emporium, PA.

Q. How old are you?

A. Eighteen.

Q. Are you currently employed?

A. No.

Q. Mr. Halliday, were you ever incarcerated in the Warren County Jail?

A. Yes.

Q. When?

A. From November 8 until roughly April 27.

THE COURT: What year?

BY MR. SMITH:

Q. What year?

A. 1990.

Q. To - -

A. April 27, 1991.

Q. What were you incarcerated for?

A. Drug charge.

Q. Do you have a prior record other than the drug charge?

A. Yes.

Q. Been in trouble before?

A. Yes.

Q. What were you in the trouble before about?


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A. Harassment, criminal trespass, just - -

Q. Anything else?

A. One theft charge.

Q. You realize you're under oath today?

A. Yes.

Q. Realize if you don't tell the truth, you're subject to penalties of perjury?

A. Yes.

Q. Have you ever met me before?

A. No.

Q. Have you ever met Mr. Cotton before?

A. No.

Q. Do you know Jay Buckley?

A. Yes.

Q. How do you know Jay Buckley?

A. When I was incarcerated, I heard all about him, and the guy that was from my county that with us told me a lot about him. He was celling with him in maximum security.

Q. Were you celling with him?

A. No, I was celling with Mike.

Q. Mike?

A. Mike Brown.

Q. Were you ever celled with Jay Buckley?

A. No.

Q. Are you friends with Jay Buckley?


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A. No, we never talked.

Q. Are you related to Jay Buckley?

A. No.

Q. Are you coming here today under any threats, promises of any kind?

A. No.

Q. Have you talked to Jay Buckley about you being here today?

A. No.

Q. You said you were celled with Michael Brown?

A. Yes.

Q. Did Michael Brown have conversations with you through the period that you were celled with him?

A. Yes, he did.

Q. Did he ever mention things with regard to the Kathy Wilson murder case?

A. Yes.

Q. What types of things did he mention to you?

A. He said he did it mostly more than 95 percent for the reward money, and he also said a few things - - - he would tell me one story, and then would he tell me another story; maybe a week later would he give me a whole different story.

Q. Would it be fair to say what he told you was inconsistent?

A. Yes.


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Q. Did he tell you on occasion how Kathy Wilson got killed?

A. Yes.

Q. How what did he tell you?

A. He told me that she was picked up at a shopping mall, carried in a van out in the wooded area across the state line into Pennsylvania and stabbed and raped.

Q. Did he ever tell you anything about his van?

A. No.

Q. Or tell you there was any blood in his van?

A. Yes.

Q. What did you (sic) tell you with regard to that?

A. He said his van was used during the murder, and when his van was brought back, there was Kathy Wilson's clothes were in the van. There was some blood on the clothes and that's roughly it.

Q. What other types of stories did he tell you?

A. He told me that - - one time he told me first it was a shopping mall and then it was Quality Market I believe, and they all related to the same thing from there, but he always used different stories. He'd say that Jay was the one that did it all, and then he'd say he helped Jay, and then he would say Jay come back and got me and we took the body across the PA line.

Q. When he would tell you Jay did it all, did he tell


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you on those occasions he was alone?

A. Yes.

Q. So he never said Jay did it all alone?

A. Right.

Q. Tell you any other stories about the victim or anything else that you can recollect?

A. No, but I believe this one time he told me the state police stopped at his mother's and father's house. They were building a new garage or something, and they put a concrete foundation for a floor, and they wanted to rip it up and maybe the murder weapon was under there or something, some evidence, and his parents wouldn't let them rip it up.

Q. Did he say he had told him that evidence was under there?

A. No, he didn't.

Q. Did he tell you how the police thought the evidence was under there?

A. He said that they thought that maybe the murder weapon was in the cement, poured in with the cement for a cover up.

Q. He is telling you this in November of '90 - - do you know what specific month he is telling you this, between November and April of '91?

A. When I first went to Warren County Jail, I wasn't in his block, and that was at the beginning of November, and I


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didn't talk to him at all, and then I got back in his block in March, and that's when we started to talk.

Q. March of '91?

A. Right.

Q. So really what you're relaying to us is March '91 to April '91?

A. Yes.

Q. Did he ever tell you he had nothing to do with this crime and was doing it solely for the reward money?

A. Yes.

Q. How many occasions did you tell you that?

A. Almost every time we talked about it, he said he just did it for the reward money, and the only reason he was incarcerated and in jail was for his protection.

Q. What did he say with regard to for his protection?

A. So like maybe Jay's family or friends or something didn't threaten him or take care of him so he couldn't testify or something.

Q. Did he indicate to you that he believed he would still get the reward money?

A. Yes.

Q. And he indicated that to you as late as March and April of 1991?

A. Yes. He says when this is all over he is going to walk out of here clean and with the reward money.


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Q. Did he tell you who told him that?

A. No.

Q. Did he tell you how he was led to believe that or where he got that idea from?

A. No.

Q. And this is - - when did he tell you that, that he is going to walk out of here with the reward money?

A. This was probably April between the 16th and the 27th before I was transferred to McKean County.

Q. Did he indicate to you at that time that Jay Buckley had nothing to do with it and the sole purpose was the reward money?

A. He didn't say Jay didn't have anything to do with it. He just said that when this is all over he is walking out clean and that he will have the reward money.

Q. Did he indicate to you how much reward money?

A. No.

MR. SMITH: No further questions.

CROSS EXAMINATION

BY MR. MASSA:

Q. Mr. Halliday, how old are you?

A. Nineteen.

Q. What is your date of birth?

A. 1-28-72.

Q. You said that you had a drug charge, harassment,


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criminal trespass, theft; is that right?

A. Correct.

Q. What is the nature of the drug charge?

A. It was noncontrolled substance. It's still in the process of getting dismissed from court.

Q. What were you arrested for? What drug were you charged with?

A. It was the cosmetic act under marijuana.

Q. Possession or delivery?

A. Delivery.

Q. Selling drugs?

A. Yes.

Q. What was the harassment charge?

A. Against my ex-girlfriend.

Q. What is what was the nature of that charge?

A. You mean - -

Q. What did you do to bring that charge against you?

A. Me and her broke up in October before I was incarcerated over here, and I just let my heart rule my head, I guess.

Q. What did you do to your girlfriend?

MR. SMITH: Objection. Irrelevant.

THE COURT: Do you want to address the objection?

MR. MASSA: Yes, Your Honor. Counsel has called this individual to the stand. He brought out his criminal


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record. The character or veracity of any witness nondefendant in a trial, his background can be brought before the Court and jury.

MR. SMITH: Well, Your Honor, I agree with that, although I thought I heard Mr. Massa say he could only bring criminal falsity out of any witness before in chambers. But the point of it is, that has been testified to. It's not criminal falsity. He has admitted that. What he specifically did to his girlfriend or didn't do to his girlfriend, I don't see how it's probative in the Kathy Wilson case.

THE COURT: Mr. Massa, if what you say is true, if there is a conviction, not simply a charge. If there is a conviction what he may have done to his girlfriend, the Court would have to entertain that.

MR. MASSA: My understanding was that he was convicted, but I will ask him that.

BY MR. MASSA:

Q. Were you convicted of harassment?

A. Yes.

Q. Tell the jury what you did to your ex-girlfriend.

A. She called me up on exactly October 19 and asked me to come over because her parents weren't home. I went over and I talked to her we got along fine. And the 20th she did the same thing. We were talking about getting back together. And the 21st her dad come home, and he talked to her dad and


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told him I was there, and her dad made her file these charges, and then he followed through with her after she moved to New York.

Q. Were you convicted of criminal trespass?

A. Yes.

Q. What was the nature of that?

A. Same thing.

Q. Were you convicted of theft?

A. Yes.

Q. What was the nature of that conviction?

A. Me and a couple of my friends broke into a camp and took a case of beer and five bottles of whiskey.

Q. Are you convicted of receiving stolen property?

A. No.

Q. Were you convicted of criminal conspiracy?

A. Yes, I was.

Q. What was the nature of that conviction?

A. It relates under the theft charge.

Q. You said that you never met Mr. Smith?

A. No, I never have.

Q. You never met Mr. Smith?

A. No.

Q. Have you ever met Mr. Cotton?

A. No.

Q. Have you ever been met Mr. Herzog?


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A. No.

Q. Have you ever met myself?

A. No.

Q. Who did you talk to relative to these conversations relative to Mr. Brown?

A. I was subpoenaed here on Wednesday.

Q. Pardon?

A. I was served the papers here on Wednesday and - -

Q. Did you know that this trial was taking place?

A. Yes, I did.

Q. Did you know the charges that Mr. Buckley was facing?

A. Yes.

Q. Do you know the charges Mr. Brown himself is facing?

A. Yes.

Q. Did you tell a probation officer, a jail guard or anyone in an official capacity in law enforcement about these statements?

A. No.

MR. MASSA: No further questions.

MR. SMITH: You are not lying today, are you?

THE WITNESS: No.

MR. SMITH: No further questions.

THE COURT: You may step down.


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