May 23, 1997

MS. RAMSEY: Your Honor, we would call Daina Bradley.

THE COURT: All right. If you would just face the clerk and raise your right hand to be sworn, please.

THE COURTROOM DEPUTY: Your right hand.

(Daina Bradley affirmed.)

THE COURTROOM DEPUTY: Would you have a seat, please. Would you state your full name for the record and spell your last name.

THE WITNESS: Daina L. Bradley, B-R-A-D-L-E-Y.

THE COURTROOM DEPUTY: Okay.

THE COURT: We're going to have trouble hearing you, so if you would please speak into the microphone.

THE WITNESS: Daina Bradley, B-R-A-D-L-E-Y.

THE COURT: Thank you.

DIRECT EXAMINATION BY MS. RAMSEY:

Q. You need to scoot your chair up a little bit and --

THE COURT: I don't think the chair moves.

MS. RAMSEY: Okay.

BY MS. RAMSEY:

Q. Can you move the microphone a little bit towards you, Ms. Bradley. That might help. Are you ready? Okay.

A. Yes.

Q. Ms. Bradley, how old are you?

A. I'm 2 -- going to be 22.

Q. You're going to have to speak up.

A. 21.

Q. You're 21 now, soon to be 22? You need to answer yes or no.

A. Yes.

Q. Okay. And you do have an attorney representing you in this case, don't you: Ms. Wallace?

A. Yes.

Q. And can you see her --

A. Yes.

Q. -- in the courtroom? Okay. Where do you live, Ms. Bradley?

A. Oklahoma City.

Q. And how long have you lived in Oklahoma City?

A. Born there.

Q. All right. So you've lived there all your life?

A. Yes.

Q. All right. And what's your educational background? Did you go to school in Oklahoma City?

A. Yes.

Q. Okay. And what are some of your special interests? What are your hobbies?

A. I like to read. I like car models, modeling cars.

Q. Okay.

A. Spending lots of time with my son.

Q. Are you comfortable now, a little more comfortable?

A. A little more.

Q. You don't want to be here, do you?

A. No.

Q. You would rather be back in Oklahoma City with your son, as you said; is that correct?

A. Yes.

Q. All right. And you are here because you received a subpoena from the defense; isn't that correct?

A. Yes.

Q. I want you to look on the screen that's below you, and can you tell me what that is.

A. That's the subpoena.

Q. And you were served with that subpoena last week; isn't that correct?

A. Yes.

Q. And that's the only reason you're here, isn't it?

A. Yes.

MS. RAMSEY: Your Honor, we would move for the admission of McVeigh Exhibit G1.

THE COURT: A subpoena?

MS. RAMSEY: Yes.

MR. RYAN: I don't have an objection, your Honor. I don't think it's appropriate.

THE COURT: I don't know what probative value it has, but we'll receive it.

MS. RAMSEY: Thank you, your Honor. Yes. Would you publish that to the jury, please. Thank you.

BY MS. RAMSEY:

Q. Now, Ms. Bradley, you went to the Murrah Building on April the 19th, 1995, didn't you?

A. Yes.

Q. And why did you go?

A. I -- I went for my son to get -- change my son's Social Security card and to get an appointment for SSI.

Q. All right. You need to speak up now. To get an appointment for SSI?

A. Yes.

Q. All right. Now, is that the son that you just talked about a moment ago?

A. No.

Q. Who did you go to the Murrah Building with on April the 19th, 1995?

A. I went with my mother.

Q. And what's her name?

A. Cheryl Hammon.

Q. All right. And you went with who else?

A. And my sister, Felicia Bradley.

Q. And who else accompanied you there?

A. And my daughter Peachlyn Bradley and my son Gabreon Bruce.

Q. And what time did you get to the Murrah Building; do you remember?

A. It was before -- it was like 8 -- we all got there early to try to -- try to beat the people, the rush there.

Q. Did they have a waiting area outside the Social Security office?

A. No. It was in the -- we were in the -- by the time we got there, the Social Security office was open and they -- there was a lot of people there. They were already starting a line.

Q. All right. Do you think you got there around 8:00 when they opened or was it later, if you remember?

A. I don't.

Q. Okay. When you got to the Social Security office -- first of all, where is the Social Security office in the Murrah Building? Where was it on April the 19th?

A. It's on the first floor.

Q. Okay. When you went into the Murrah Building and went into the Social Security office, then what happened next?

A. I went in and signed the papers, and my mom was standing in line for -- for us -- for me. And I was doing the papers. I went to her and let her look over the papers.

Q. Okay. So she was actually holding your place in line?

A. Yes.

Q. While you were trying to get everything ready to present to the person you were going to talk to at Social Security; is that correct?

A. Yes.

Q. All right. You went over and talked to your mom about the papers that you had filled out; is that right?

A. Yes.

Q. And what happened next?

A. At this time, I turned around and looked out the window.

Q. Are there all -- is the front part of the Social Security office windows?

A. Yes.

Q. Okay. And so you looked out the window, and what did you see?

A. I seen the yellow Ryder truck drive up.

Q. And what did you think when you saw the Ryder truck pull up into the -- pull up?

A. That it was very unusual that -- downtown, they do not allow moving trucks as far as those kind of vehicles being parked down in that area.

Q. Okay. And did the -- what did the truck do when you saw it?

A. It -- they stopped.

Q. Did it park?

A. Yes. It parked.

Q. Okay. And did you see anything else at that time or did you continue your conversation with your mother?

A. I went back and I looked up and I started talking to my mother again and I looked back out. I seen two men get out of the truck.

Q. All right. Did you say anything to your mother about the Ryder truck when it pulled in and parked, or did you just think it to yourself?

A. I -- me and my sister and my mother, we both thought that it was unusual.

Q. Okay. So there was something mentioned about it?

A. Yes.

Q. All right. Now, you saw the men get out, and then what happens next that you remember?

A. I seen the driver get out.

Q. I don't want to get into your -- what happened at that point yet. What happened after you saw the Ryder truck park and the men get out? Did you go back to talking with your mother?

A. No. At this time, my mother had told me to go back to my sister to -- for her to help me fill out the part that -- that I did not fill out on the application. At this time that I was going back, that's when I was looking out the window.

Q. Okay. You went over to your sister; is that correct?

A. Yes.

Q. You were talking with her?

A. Yes.

Q. Right? And then what happens next? Does the explosion occur shortly thereafter?

A. Yes.

Q. All right. How long were you in the Murrah Building, do you think, before the explosion occurred, if you remember?

A. I don't. All I know is that when I was talking to my sister, that a flash of light came over the desk, and that's -- that's where I -- I don't know how long that it was there.

Q. And what is it that you remember next?

A. That I was trapped.

Q. All right. How long were you trapped in the building?

A. Before rescue or completely out?

Q. Completely.

A. I was in there for five hours.

Q. All right. And during that time that you were trapped, you had to have your leg amputated, didn't you?

A. Yes.

Q. In order to be released from the building; is that correct?

A. Yes.

Q. And did your mother and your two children survive?

A. No.

Q. And your sister was severely injured, also, wasn't she?

A. Yes.

Q. And you were then taken to the hospital at some point after you were retrieved from the building; is that correct?

A. Right.

Q. How much time did you spend in the hospital? Do you recall how many days?

A. No, I don't, because I lost day and time at that point. I don't -- I don't know -- I don't even, you know -- people coming and going. I couldn't tell you, you know, day or time or where I was most of them.

Q. All right. Now, since this -- since April 19 of 1995, you became pregnant and had another child; isn't that correct?

A. Yes.

Q. And that's the child that you were speaking of that you wanted to be home with; isn't that correct?

A. Yes.

Q. And he was not involved in, nor were you pregnant at the time?

A. No.

Q. Okay. While you were in the hospital, were you contacted by the Federal Bureau of Investigation?

A. Yes.

Q. All right. Haven't you -- I gave you and your attorney the -- what we call the 302's of your statement -- statements with regard to the two times or three times that you've talked with the FBI; isn't that correct?

A. Yes.

Q. Okay. Now, when you first talked with the FBI was on May the 3d and May the 4th, when you were in the hospital; isn't that correct?

A. Yes.

Q. And what did you tell the FBI agents with regard to the Ryder truck, if you recall?

A. I --

Q. Did you tell them the Ryder truck came up and parked?

A. Yes.

Q. All right. Did you tell them that you observed an individual get out of the passenger side of the vehicle?

A. Yes.

Q. Okay. And did you give them a description of the person?

A. Yeah.

Q. All right. And what did you tell them about the person that got out of the vehicle? Do you recall?

A. I recall telling them that -- that it was a olive-complexion man with short hair, curly, clean-cut. He had on a blue Starter jacket, blue jeans, and tennis shoes and a white hat with purple flames.

Q. All right. And did you tell him that -- or tell them that he was wearing a baseball cap?

A. Yes.

Q. And did you also tell them when you talked to them on May the 3d and 4th that you observed him from a side view?

A. Yes.

Q. And did you also tell the FBI what this person did when he got out of the Ryder truck?

A. Yes.

Q. And what did you tell them?

A. I had told him that -- I told them that he had got out of the truck, went to the back of the truck, and proceeded to walk very fast forward in front of the truck. He went back on the sidewalk and left.

Q. All right.

A. In a rapid speed.

Q. And he was walking very quickly?

A. Yes.

Q. And did that also call your attention to him?

A. Yes.

Q. Okay. Did you also talk with the FBI on May the 3d and 4th about the sketch that you had seen when you were in the hospital?

A. Yes.

Q. And what did you tell the FBI about that sketch?

A. That that man was familiar; that I had seen him get out of the truck.

Q. All right. And when had you seen that sketch? Did they show it to you or had you seen it when you were in the hospital?

A. I had seen it when I was in the hospital.

Q. When you saw the sketch when you were in the hospital, were you with someone or were you by yourself?

A. I was by myself.

Q. Now, on your screen, I have what's previously been admitted as Government's Exhibit 320. Is that the sketch that you saw on television?

A. Yes.

Q. All right. And when you saw this sketch, did you say to yourself -- I believe you told the FBI that you were certain that this was the person that you had seen get out of the Ryder truck?

A. Yes.

Q. And I believe also, you told the FBI that when you saw him get out of the truck and walk down the sidewalk very quickly, the next thing that you recall was the explosion; is that correct?

A. Yes.

Q. Now, did the FBI also show you sketches on May the 3d and 4th when you met with them?

A. Yes.

Q. And did you tell them that you had only seen one person --

MR. RYAN: Your Honor, I'm going to object to leading.

MS. RAMSEY: I'll rephrase the question.

THE COURT: All right.

BY MS. RAMSEY:

Q. Did you tell them about anyone else getting out of the vehicle?

A. No, I did not.

Q. Did they -- did the FBI show you a sketch of the other person?

A. Yes.

Q. And you could not identify that; isn't that correct?

A. Right.

Q. Because you said you'd only seen one person; correct?

A. Yes.

Q. Okay. Now, you also met with the FBI on May the 21st; isn't that correct?

A. Yes.

Q. When you met with them on May the 21st, had you been released from the hospital?

A. Yes.

Q. And you met with them where?

A. I met with them at my lawyer's office.

Q. At Ms. Wallace's office?

A. Yes.

Q. And is that in Oklahoma City?

A. Yes.

Q. And when you met with the FBI on May the 21st, did you tell them about the Ryder truck?

A. Yes.

Q. What did you tell them about the Ryder truck?

A. That it parked in front of the Social Security office.

Q. Did you also give them a description of the person you saw get out of the vehicle?

A. Yes, I did.

Q. And what was that description?

A. The olive-complexion man and the short hair, curly hair, with the Starter jacket, blue jeans, and tennis shoes, with the baseball hat with the flame, purple flame.

Q. Did you also tell them that the hat was white on one side with a purple flame on it?

A. I told him the hat was white with flames on it.

Q. Okay. And did you also tell them that he -- the person left the vehicle and walked at a very rapid pace?

A. Yes.

Q. Now, did you also on October -- did you also have a conversation with an investigator from Mr. McVeigh's defense team?

A. Yes.

Q. And was that -- do you recall when that was? Was that in 1995?

A. Yes.

Q. And you've had -- this will be your fourth conversation with regard to what happened that morning with either the Government or someone from the defense; is that correct?

A. Yes.

Q. What did you tell Wilma Sparks when you talked with her on the telephone with regard to that day, if you recall?

A. I don't recall.

Q. Did you tell her what time you got to the Social Security office?

A. Yes.

Q. All right. Do you recall what time that was?

A. I -- I had told her 8.

Q. Okay. And you've seen a copy of this, haven't you?

A. Yes.

Q. The transcript? Okay. And did you also tell her about an individual getting out of the truck?

A. Yes.

Q. And what did you tell Ms. Sparks with regard to a description of that person?

A. I told her that it was the same man.

Q. The olive skin?

A. The olive complexion, yes.

Q. And did you give her any further description of that person?

A. The same as the olive complexion, short hair, white ball cap with purple flames, blue jeans and tennis shoes.

Q. All right. And did you also tell her what height you thought he might have been?

A. I don't recall.

Q. Could you have told her that he was approximately 6 feet tall?

A. Yes.

Q. What did you tell Ms. Sparks with regard to his wearing gloves or glasses?

A. He had none.

Q. Okay. And did he have a beard or a mustache?

A. No.

Q. Clean-shaven.

A. Yes.

Q. Did you also tell Ms. Sparks that the sketch that you had seen of the John Doe 2 was the person that you saw get out of the Ryder truck?

A. I don't understand.

Q. Did you tell her that the sketch that I just had on the monitor was the person that you saw get out of the truck?

A. Yes.

Q. Okay. Did you also talk with her about how this person was acting?

A. Yes, I did. I told her that he was acting very mysterious and that he was walking off very rapidly and very nervous.

Q. Okay. Did you also tell her that that was the only person that you saw get out of the truck?

A. Yes, I did.

Q. Now, these interviews were in 1995; is that correct?

A. Right.

Q. And you had not been interviewed with regard to this case until 1997; isn't that correct?

A. Right.

Q. Now, were you advised by your attorney that I wanted to interview you approximately three to four weeks ago?

A. Yes, she did.

Q. And I -- were you advised by your attorney that I probably -- that you would probably be subpoenaed to come to court today?

A. Yes.

Q. And did we have a meeting in your attorney's office on Friday, May the 16th, which was last Friday?

A. Yes.

Q. And who was present at that meeting, please?

A. You and my attorney and me.

Q. And Wilma Sparks?

A. And Wilma Sparks.

Q. Okay. Now, when we got to the office, we went into your attorney's conference room; isn't that correct?

A. Yes.

Q. And what did you advise me with regard to the Ryder truck?

A. That -- that it had drove up and that I told you that two men got out of the truck.

Q. Did you give me a description or did you state a description of the person that you saw that was the olive-skinned one?

A. Did I -- I don't understand your question again.

Q. Did you describe the olive-skinned person who got out of the Ryder truck?

A. Yes, I did.

Q. And what was the description that you gave on May the 16th, 1997?

A. I told you that he was olive-complexion, clean-cut, baby-faced, and he had on a white ball cap with purple flames, blue jeans and tennis shoes.

Q. And that the tennis shoes were white?

A. Yes.

Q. Did you also describe the jacket that he had on?

A. Yes. It was a blue Starter jacket.

Q. And what did you tell -- what did you say on May 16 that he did when he got out of the Ryder truck?

A. That he went to the back of the truck and walked forward and walked off rapidly.

Q. And walked what?

A. Walked off rapidly.

Q. Okay. And what did you tell me that he had in his hands?

A. He had nothing in his hands.

Q. And did you see him throw anything away at that point?

A. No.

Q. And what did you state with regard to the sketch of John Doe 2 that you saw on TV while you were in the hospital?

A. What did I --

Q. What did you say on May 16th with regard to that?

A. That that was the same guy that I seen get out of the truck.

Q. Now, we also -- in the May 16 interview, you advised that there was another person that got out of the vehicle; isn't that correct?

A. Yes.

Q. And what did you -- how did you describe that other person?

A. That --

Q. What did he do?

A. That he was a white male and that he walked off. I could see enough to see that he was a white male and that he had walked off very fast across the street.

Q. Okay. And which way did he go? Did he go in the same way that the other person went?

A. No.

Q. Okay. Did he -- which way did he head?

A. I --

Q. Are you very good with directions?

A. No, I'm not.

Q. Did he go towards the back of the truck or the front of the truck?

A. He was -- he just got out of the truck and went across the street.

Q. Okay.

A. And the other man went that way.

Q. They went two different directions; is that correct?

A. Yes.

Q. Did the gentleman that you told me about on May 17th (sic) do anything with regard to the truck or just get out and walk away very quickly?

A. He got out and walked away very quickly.

Q. And did you see if he had a hat on?

A. I don't recall or remember.

Q. Okay. Now, how long did our meeting last, if you recall?

A. Maybe an hour. Hour and a half.

Q. Okay. Do you recall me asking you the question did you ever see anyone that day that looked like Timothy McVeigh?

A. Yes, I did.

Q. And what was your response?

A. That I couldn't recall if it was or not.

Q. Is that what you told me on May the 17th -- I'm sorry -- May 16, on Friday, in your attorney's office?

A. No.

Q. What did you tell --

A. I said no.

Q. You said no; is that correct?

A. Yes.

Q. All right. Now, did you meet with anyone else the afternoon of May the 16th?

A. I don't -- I don't --

Q. Did you meet with Ms. Behenna from the prosecution team in Oklahoma City?

A. Yes. Yes.

Q. All right. And that was also in your attorney's office; isn't that correct?

A. Yes.

Q. Now, when did you come to Denver?

A. Monday.

Q. And would that be the 19th?

A. Yes.

Q. Okay. And that was Monday in this week; is that correct?

A. Yes.

Q. All right. And did we meet in your hotel room on May the 19th?

A. Yes.

Q. And who was present at that meeting?

A. You and my attorney and -- I can't recall who else.

Q. The three of us, wasn't it?

A. Yes.

Q. And at that time, did we discuss what your testimony was going to be?

A. Yes.

Q. And at that time, we also discussed some of the description, as you testified before; isn't that correct?

A. Yes.

Q. And were you shown a photograph of Timothy McVeigh at that time?

A. Yes, I was.

Q. Okay. I'm going to show you what's previously been admitted as Government's Exhibit 421 and ask you if that's the photograph that I showed you on May the 19th.

A. Yes.

Q. And did I ask you the question if you were absolutely positive that you did not see Timothy McVeigh in or around the Ryder truck on April the 19th, 1995?

A. Yes.

Q. And what was your response?

A. No.

Q. And did I ask you if you were absolutely positive that you did not see Timothy McVeigh in or around the Murrah Building on April the 19th, 1995, and what was your response?

A. No.

Q. And that was after you looked at this photograph; is that correct?

A. Right.

Q. And did I further ask you if you were absolutely positive that the white male you saw get out of the passenger side of the Ryder truck and walk north was not Timothy McVeigh?

A. Yes.

Q. And your answer was yes, it was not; is that correct?

A. Uh-huh.

Q. Now, also on May the 21st, we met again, didn't we?

A. Yes.

Q. And that was on Wednesday, I believe. Did you meet on Wednesday with anyone from the prosecution: Mr. Ryan?

A. Yes. I did.

Q. And did you also meet with some of the other people -- some of the other victims and victims' families that are here in court today or that are here in Denver?

MR. RYAN: I object to this. That's leaving an impression there were victims with me, and that's not so.

MS. RAMSEY: I'm sorry. I'll rephrase it.

MR. RYAN: It was in the hall of the --

THE COURT: All right. She's going to rephrase it.

MR. RYAN: Thank you, your Honor.

BY MS. RAMSEY:

Q. You met with Pat Ryan in the afternoon; isn't that correct?

A. Yes.

Q. And at a different time, you also ran into some of the people that are staying at the hotel that are here in court; isn't that correct?

A. Yes.

Q. And you just had a normal conversation with them; isn't that correct?

A. Yes.

Q. Okay. And then we also met on the 21st; isn't that correct?

A. Yes.

Q. In my office?

A. Yes.

Q. And who was present at that meeting?

A. Me and my attorney and you.

Q. Okay. And we talked for how long?

A. Not even an hour and a half.

Q. Okay. Just a short time?

A. A short time.

Q. And we were going back over your testimony, weren't we?

A. Yes.

Q. And at that time, what did you tell me about the white male that got out of the passenger side of the vehicle that walked north? Do you recall?

A. No.

Q. Okay.

A. I don't recall.

Q. Did you tell me that it was not Timothy McVeigh?

A. Yes, I did.

Q. But that you had talked to Mr. Ryan and had told him that you were not sure?

A. Yes, I did.

Q. All right. Now, did we meet again yesterday afternoon?

A. Yes.

Q. And in that meeting which -- how long did that meeting take?

A. No more than a couple of minutes or so.

Q. And who was in that meeting?

A. You, me, and my attorney.

Q. And we were again discussing what your testimony was going to be today, weren't we?

A. Yes.

Q. Okay. Now, when we talked yesterday, did you advise me that as -- that you did not get a good look at the person who got out and walked across the street very rapidly?

A. Yes, I did.

Q. Did you also tell me that you -- from what you saw, that the person who got out of the Ryder truck was not Timothy McVeigh?

A. Yes.

Q. But that you didn't get a good look?

A. Right.

Q. Okay. When we met -- or let me rephrase that. From the time that you first met with the FBI, which was on May the 3d and the 4th of 1995, until May the 16th of 1997, you had never advised anyone that there was anyone other than one olive-complexion male that got out of the vehicle; is that correct?

A. Yes.

Q. Since we -- since you knew that you might have to testify and -- when we met on May the 16th was the first time that you have ever advised anyone that there was another person possibly in the vehicle; is that correct?

A. Yes, I did.

MS. RAMSEY: Your Honor, if I might have a moment?

THE COURT: Yes. BY MS. RAMSEY:

Q. Perhaps my questions and your answers are not clear as to no means yes or yes means no. When we -- when you first talked with the FBI, you told them you never identified Timothy McVeigh or the sketch of John Doe 1; isn't that correct?

A. I don't recall; because at that time, I don't even remember half of the things that I said when they did the interview.

Q. You only identified the olive-skinned person as getting out of the truck?

A. Right.

Q. You did not see anyone else get out of the truck?

A. True.

Q. Okay. Then on -- when you had the telephone conversation with Wilma Sparks, you did not say anyone else got out of the truck other than the olive-skinned male; correct?

A. Yes.

Q. And it was not until May the 16th, 1997, that you told anyone that there was a second person who might have gotten out of the truck?

A. Yes.

Q. Or who did get out of the truck?

A. Yes.

Q. Okay. And you have never said that Timothy McVeigh was the person who got out of the truck; isn't that correct?

A. Yes.

MS. RAMSEY: No further questions at this time, your Honor.

THE COURT: Mr. Ryan.

MR. RYAN: Thank you, your Honor.

CROSS-EXAMINATION BY MR. RYAN:

Q. You doing okay? Are you all right?

A. I need to talk to my lawyer.

THE COURT: All right. We'll take a brief recess to accommodate that request. You may step down at this time. Members of the jury, while it's early, we'll go ahead and take the morning recess as requested by the witness so that she may talk with her lawyer. And during this time, of course, please do not talk about anything connected with this case, what's happening here in the courtroom or has happened in the past, and remembering your obligation to maintain open minds. And avoid, of course, any discussion about anything that relates to the case as well as anything in any communication or publication outside the evidence. You're excused now, and we'll assume about 20 minutes, but it depends upon the witness and her lawyer.

(Jury out at 9:47 a.m.)

THE COURT: We'll recess subject to call.

(Recess at 9:47 a.m.)

(Reconvened at 10:10 a.m.)

THE COURT: Please be seated. Are we ready to proceed?

MR. NIGH: Yes, your Honor.

(Jury in at 10:10 a.m.)

THE COURT: All right. Ms. Bradley, are you ready to proceed?

THE WITNESS: Yes.

THE COURT: All right. Mr. Ryan?

MR. RYAN: Thank you, your Honor.

BY MR. RYAN:

Q. Did you have a chance to talk to your lawyer?

A. Yes.

Q. Did you have a chance to talk to your lawyer?

A. Yes, I did.

Q. Okay. Are you ready to proceed?

A. Yes, I am.

Q. I'm sorry to have to be asking you some questions now, but if you'll bear with me.

A. Yes.

Q. Okay. Now, I met with you for the first time two days ago; is that right?

A. Yes.

Q. And do you remember that I called your lawyer and asked if it would be all right with her for me to visit with you for a little bit?

A. Yes, you did.

Q. And when I met with you, it was in your lawyer's room at the hotel?

A. Yes.

Q. And I had a special agent of the FBI with me, Mr. Michalic. I introduced you to him?

A. Yes, you did.

Q. Your lawyer was present for the entire interview?

A. Yes.

Q. Before I ever met with you or before Ms. Behenna met with you, you had told, apparently, Ms. Ramsey that you saw two men on the morning of the 19th. Do you remember that?

A. Yes. Yes, I did.

Q. Excuse me?

A. Yes.

Q. In other words, when you talked to me, it wasn't the first time you said there were two men. You had told Mrs. Ramsey that before; that there were two men that you saw.

A. Yes.

Q. And there were no victims present with me and the FBI agent who met with you and your lawyer, were there?

A. No, they were not.

Q. And has anybody tried to get you to change any of your testimony?

A. No, they have not.

Q. Has any victim tried to get you to do that?

A. No, they have not.

Q. Did anyone from the prosecution or the FBI try to get you to change anything that you remember?

A. No, they did not.

Q. When I met with you on Wednesday, you told me that there were two men and that I asked you to describe the second man who was running across the street, didn't I?

A. Yes, you did.

Q. And you told me he had kind of a baby face and was clean-shaven?

A. Yes.

Q. And then I asked you if -- from what you could see, did it look like Timothy McVeigh?

A. Yes, you did.

Q. Remember that?

A. Yes.

Q. And do you remember what you said?

A. I said that -- that I was not certain, probably and probably not. I didn't give a yes-or-no answer to it.

Q. You told me that there was nothing that you saw about the man that ran across the street that was different than what you could see when you looked at Mr. McVeigh. There weren't any differences that you could see.

A. Yeah.

Q. Now, you told the FBI from the very beginning in this case that you did not have a good memory, didn't you?

A. Yes, I did.

Q. The very first time they came and talked to you, you said, "I've been through a lot of trauma, I've been through a lot of things in my life"?

A. Yes.

Q. "And I just don't have a good memory of these events"?

A. Yes.

Q. And that's true, isn't it?

A. Yes, it is.

Q. Do you remember that when you were in the hospital there that there was a lot of news coverage about this John Doe 2 person?

A. Yes, there was.

Q. And you had a television in your room, didn't you?

A. Yes, I did.

Q. And in fact, the newspaper in Oklahoma City -- they were writing articles about you the week the FBI came and visited you. Do you remember that, the article they wrote about you and your mother, the fact that you had lost your two children?

A. Yes, they did.

Q. And do you recall that in the newspaper, the week that you saw the FBI, there were sketches --

A. Uh-huh.

Q. -- of this John Doe 2 person that you talked about today?

A. Yes.

Q. Do you recall that?

A. Yes, I do.

Q. I'm going to put on the -- you have a computer screen there at your desk. If you'll look down at the top of your desk there. Do you see it?

A. Uh-huh.

Q. I'm going to put before you what is -- what I've marked as Government's Exhibit 1646, which is a newspaper from the Daily Oklahoman dated May 2, 1995. Can you see the date there?

A. Uh-huh.

Q. I'll zoom in a little bit for you.

A. Yes.

Q. Do you see that?

A. Yes, I do.

Q. Now, that's the day before the FBI came to see you, isn't it?

A. Yes, it is.

Q. And in this -- did you read this paper and see this sketch that I've got on the ELMO, on your screen there?

A. No, I didn't. I didn't read it, but I -- I have seen the sketch in the paper.

Q. Excuse me?

A. I had seen -- yes, I had seen the sketch.

Q. You'd seen this exact sketch?

A. Yes, I did.

Q. And why don't you read to yourself, if you would, what it says about the description of this man with the baseball cap. Read what it says there in the newspaper the day before --

A. You mean the picture?

Q. Read to yourself, not out loud. Did you finish?

A. Yes.

Q. Now, had you seen this sketch and read the information that is below the sketch?

A. Yes.

Q. Excuse me?

A. Yes, I read it.

Q. Yes. MR. RYAN: Your Honor, we would move into admission the sketch and the description following the sketch into evidence as part of Exhibit 1646; and I'll redact the rest of the paper at a later time, if that's permissible.

MS. RAMSEY: Your Honor, I don't believe a proper foundation has been laid. I don't know -- is it because she just read it now, or she read it at that time?

THE COURT: I think there should be that clarifying question. It wasn't clear to me, either.

MR. RYAN: Apologize.

BY MR. RYAN:

Q. The question that we're talking about, Mrs. Bradley, is did you see this sketch and this information that's on your screen there before the FBI came to see you for the first time on May 3?

A. No, I didn't.

Q. Oh, okay.

MR. RYAN: I'll withdraw my offer, then.

THE COURT: All right.

BY MR. RYAN:

Q. I misunderstood you. Now, when the FBI came to see you, though, the information that you gave them was very similar to the information that's written here under this sketch?

A. Yes, it is.

Q. You told the FBI that the man was wearing a baseball cap; right?

A. Right.

Q. Just like the paper showed the day before they interviewed you?

A. Yes.

Q. And you told the FBI the man was tanned, didn't you?

A. Yes.

Q. Excuse me?

A. Yes, I did.

Q. And it says right here the very same information, doesn't it, tan?

A. Yes.

Q. It doesn't say olive-skinned, does it?

A. No.

Q. Excuse me?

A. No, it doesn't.

Q. And you didn't tell the FBI olive-skinned the first time you met with them, did you?

A. No, I didn't.

Q. You told them tanned?

A. Right.

Q. And you told the FBI the man was thin, didn't you?

A. That -- excuse me?

Q. That the man was thin. "Slim" I believe was the word you used.

A. Slim, yes.

Q. You never said he was short and stocky, did you?

A. No, I didn't.

Q. You've never said that at any time, have you?

A. No, I haven't.

Q. Now, later when you were interviewed, you changed from tan-skinned to olive-skinned.

A. Yes, I did.

Q. Now, you had a really rough childhood, haven't you?

A. Yes, I have.

Q. You were in a psychiatric home, hospital, when you were 7 years old?

A. Yes, I was.

Q. And you were in a -- a mental health facility from the age of 7 until the age of 16; is that right? Smally's in Norman?

A. Yes, I was.

Q. Were you given a lot of medication during those years?

A. Yes, I was. A lot.

Q. Excuse me?

A. Lots.

Q. How would you describe the effect the medication had on you?

A. It had caused me to lose memory of who I was and people around me.

Q. And you were depressed?

A. I was depressed.

Q. And you were there for a very long time.

A. Yes.

Q. And have you received any therapy since the bombing in which you lost your mother and two children?

A. At a shorter time but not long enough to speak of. A lot -- to explain -- to tell people what is really going on and how exactly I feel: I didn't get that time to do that.

Q. Do you think you need some more counseling and treatment?

A. Yes.

Q. Do you recall which way the truck was facing when you saw it on the morning of the 19th?

A. Yes. It was -- the best I can describe it, your Honor, because I'm not good with directions --

THE COURT: All right.

THE WITNESS: Is that this -- this is the glass, and it was -- the front of it was parking -- parked -- it was in like towards the doors, the front doors of the federal building, the opposite side of where it's supposed to park, which is west instead of when it's supposed to park east because it's a one-way street.

BY MR. RYAN:

Q. Okay. 5th Street in front of the Murrah Building is a one-way street going east. Do you know that?

A. No, not really.

Q. You know where the YMCA is?

A. Yes.

Q. Does the street run from the Murrah Building towards the YMCA, or the other way?

A. I can't exactly remember.

Q. Okay. Do you know where the Regency Tower is?

A. It's -- yeah, it's going that way.

Q. Yes. Was the truck facing the Regency Tower?

A. Yes.

Q. Okay.

A. The Regency.

Q. So the truck was heading west. If west is -- Regency Tower is west of the Murrah Building, the truck was heading west?

A. Right.

Q. And you know that that street is a one-way street going the other way?

A. Right. And that's what made it so unusual, for one thing.

Q. Were there other cars around the truck?

A. Yes, there was.

Q. Were they going the opposite way, or the same way as the truck?

A. They were going the opposite way. They were going the right way.

Q. And only the truck was going the wrong way?

A. Right.

Q. Now, how large was this truck?

A. It was a -- I'd say medium size, half truck, which would probably only fit about a few things in it. It's -- it's not one of the long ones. It's one of short, short ones.

Q. Okay. Now, when you saw the man get out of the truck, the one that when you said for a long time there was just the one man, which direction did he walk in?

A. He walked towards the same facing that the truck was faced, which is towards the Regency Tower.

Q. So the man walked towards the Regency Tower?

A. Yeah. He was -- yeah. He was walking on the sidewalk that way.

Q. Okay. And did you ever tell the defense investigators that you thought he walked east towards the YMCA?

A. No, I didn't.

Q. Okay.

A. I don't recall.

Q. Now, later after you talked to the FBI, you added the purple flames to the hat, didn't you? You didn't tell the FBI that, did you, about the flames?

A. I don't recall what I had said.

Q. Okay. Do you -- you were asked a lot of questions by Ms. Ramsey from the defense about what you recall about different interviews. Do you really recall what you told anyone at any interview? Do you have a clear recollection of what you told anybody during these interviews?

A. Yes and no. I don't recall. I don't recall much sometimes.

Q. All right.

MR. RYAN: May I have just a moment, your Honor?

THE COURT: Yes.

MR. RYAN: May I have just a second?

THE COURT: Yes.

BY MR. RYAN:

Q. If I asked you a bunch of questions about what everybody looked like, what these men looked like or how many there were, would you be able to answer those with a clear memory?

A. About what they looked like and how many?

Q. Yes. Do you know like, for example, how many people there were? Are you sure about that, even?

A. I'm sure that there were two.

Q. You are.

A. Yes.

Q. Excuse me?

A. I -- when I first did my first interviews, I don't recall a lot of things at that time. I can -- you can tell me one thing one week, and I would forget the next week.

Q. Okay.

MR. RYAN: Thank you.

THE COURT: Ms. Ramsey, do you have any more questions?

MS. RAMSEY: Just a few questions.

REDIRECT EXAMINATION BY MS. RAMSEY:

Q. Ready to start?

A. Uh-huh.

Q. I'm just going to ask you a few more questions. I want to show you on your screen what has not been admitted as Defendant's Exhibit G6. Do you recall that drawing?

A. Yes, I do.

Q. And you drew that when you met with the FBI on the second occasion; isn't that correct?

A. Yes, I did.

Q. All right. And you showed -- what is this? Can you tell us what's on that?

A. That is the drawing of the truck, and it is the drawing of the man who was walking on the sidewalk.

MS. RAMSEY: Your Honor, we would move for the admission of G6.

MR. RYAN: May I speak to Ms. Ramsey for a moment, your Honor?

THE COURT: Yes. Yes.

MS. RAMSEY: We would move for the admission.

THE COURT: Mr. Ryan?

MR. RYAN: No objection, your Honor.

THE COURT: All right. G6 is received in evidence.

BY MS. RAMSEY:

Q. And on that drawing, would you please advise -- did you write this, the writing right here?

A. Yes, I did.

Q. Okay. And would you read that to the jury?

A. I walked by myself the whole time, did not watch the whole time.

Q. It said, "Walked by himself but did not watch the whole time," which means you didn't watch it the whole time. Isn't that correct?

A. Yes. And I indicated that to him when he came and questioned me.

Q. You don't recall everything that you wrote -- or everything that you talked to anybody about in any of the interviews, do you, word for word?

A. Not word from word, no, I don't.

Q. You told the FBI when you first talked with them on May 3 and the 4th that the person had on a baseball cap, didn't you?

A. Yes, I did.

Q. Did anyone ever ask you to describe the cap that you recall on that interview?

A. Yes, it was described.

Q. You don't have any control over what's written down in somebody else's report, do you?

A. No, I do not.

Q. And you've always maintained that this was a Ryder truck; isn't that correct?

A. Yes, I did.

Q. And you've never varied from what you've said with regard to the olive-skinned person walking to the back of the truck and then coming to the front of the truck and walking away. Isn't that correct?

A. I don't recall I -- from my recollection, I remember seeing olive complexion.

Q. No, but I mean he wasn't to the back of the truck, came to the front of the truck and then went off in another direction?

A. Yes.

Q. I think I asked you on direct examination, you're not very good at directions, are you?

A. No, I'm not.

Q. A lot of people aren't very good at directions. And the first time that you ever stated that it could or could not have been Timothy McVeigh as the second person was when you met with Mr. Ryan; isn't that correct?

A. Yes, I did.

MS. RAMSEY: No further questions, your Honor.


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