Jean Pugh - a local witness

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Between October 1st and 4th, 1990, Debra Milke took the stand in her trial about an alleged role in the killing of her 4-year-old son, Christopher Milke. The local newsmedia covered her testimony in great detail, and it was around that time (October 5, 1990), that defense attorney Kenneth Ray received an anonymous phone call. It turned out that this call was from one JEAN PUGH, who was a resident of the area where Christopher was shot on December 2nd, 1989. Eventually this contact between Mr. Ray and MS. PUGH resulted in three independent testimonies, two of them used at trial (MS. PUGH and MS. GRIFFIN), confirming that five to seven shots where heard on that Saturday (December 2, 1990), some time in the late morning hours.

This information tells us a lot about the actual proceedings of the crime and confirm that the State's theory about an alleged conspiracy of Debra Milke is hardly believable. "debbiemilke.com" is aware of the inconsistencies contained in these accounts (especially comparing it with the timeline), but they also confirm that the rush to judgement in the conviction of Debra was obviously based on a theory that didn't match the true happenings in the murder of Christopher Milke.

MS. PUGH was called to testify at Debra's trial on October 10th, 1990. Later on the same day, the State's ambush witness instrumental in character assassination against Debra, DOROTHY MARKWELL, testified, concealing he reasonable doubts as a result of MS. PUGH'S testimony completely. We publish the initial phone talk between MS. PUGH and defense attorney Kenneth Ray here as well as the trial testimony of MS. PUGH, which took place on October 10th, 1990. This way you can compare how ineffective this important information was handled at trial.



TELEPHONE-INTERVIEW WITH JEAN PUGH
(Transcript)

KEN RAY : Okay, today is the 5th, it's approximately three thirty three (3.33 p.m.), 5th of October. We are calling -- what number, Kirk?
KIRK FOWLER : Ah, she ... (inaudible)
KEN RAY : We're calling 566-8461 and follow up to an anonimous call received earlier today in connection with the Debra Milke case.
(Dialing)
KEN RAY :  (I don't use AT&T. I have different line, different long distance number.)
Jean Pugh: Hello.
Ken Ray: Yes Ma'am, this is attorney Kenneth Ray. I had been, ah, received a call on my answering machine earlier this morning concerning the Debra Milke case that I'm involved in. Someone left this as the phone --
Jean Pugh: I did.
Ken Ray: Did you?
Jean Pugh: Yup, uhm. I wanna make sure that if this is of any use for you that you have the information.
Ken Ray: Could -- I got you on the speaker phone, Ma'am, because I have my investigator here listening, you know to help me out. I'm wondering if you could just speak up, just a little bit.
Jean Pugh: Alright.
Ken Ray: Thank you. What information do you have, Ma'am?
Jean Pugh: Ahm, the day of the shooting, that the little boy was shot, I live out in that area.
Ken Ray: Aha.
Jean Pugh: Ahm, it was -- the shots were very noticeable to me because they were a low, a small caliber --
Ken Ray: Aha.
Jean Pugh: -- and prior to that a neighbor was carrying a gun that is apparently mentally inefficient, retarded.
Ken Ray: Aha.
Jean Pugh: And when I heard the shots I thought "Oh, my God, I hope he can hit the broad side of the barn", because I have a glasshouse in the mountain.
Ken Ray: Aha.
Jean Pugh: And they were so noticeable to me because they were like -- ah, it's hard to explain -- that I really thought, that I thought it wasn't Mike. And I thought "Oh God, some father got his kid a Christmas present, he's teaching him". They were not the professional shots we are used to. We're used to high caliber shots. Ahm yeah, I'm trying to think of the right term, but the firing is in sequence is -- is uniform.
Ken Ray: Aha.
Jean Pugh: The firing was not uniform, ahm, which we though we've got problems and they were not rapid fires. There was one -- then another -- and then another and the first series, I don't know there were three or four shots, because it was of no importance to me. I just thought we gotta get this guy out of here. Then there was -- I stepped outdoors, I was playing cards -- steppped outdoors, walked over the edge of the yard, which is -- as I said off of the mountain -- and I wanted to see who was shooting, walked back in and then sat down and then the shots -- there was two or three more shots after that.
Ken Ray: Aha.
Jean Pugh: Now, ahm --
Ken Ray: Could you see anyone?
Jean Pugh: Well, I evidentially did not see the right person because, ah, short time later I've seen a white car pull away from that area.
Ken Ray: Okay. Did you see how many people?
Jean Pugh: Ah, no, couldn't see, but it was not red. No, I called the detective, I called Peoria police I didn't know what was going on, of course, didn't know until the next day when I've seen the searching lights.
Ken Ray: Aha.
Jean Pugh: I didn't know until Monday or Tuesday. Ahm, I know -- that was on television or in the newspapers, when I found out about it.
Ken Ray: Aha.
Jean Pugh: And I called the police department. They referred me -- you know, that time I didn't know if they had any leads of who did it or not -- the first news report I got, and I called 'em to tell them, you know, I did hear the shots the only shots that was fired and to how many shots approximately was fired.
Ken Ray: Aha.
Jean Pugh: And they informed me that I couldn't have heard the shots because there was definitely only three shots fired, and I said "Well, you're wrong". I said "It's a small caliber, it stood out". And he said, "Yeah, it was a twenty two". That's when I found out it was a twenty two and they told me.
Ken Ray: Aha.
Jean Pugh: And I said no sir, you're wrong. I said I heard those shots I -- I was listening to them, I keep perfect (inaudible) but I know there was three or four shots, then there was a break, enough for me to get up and get outdoors to look and come back in and sit down before the second series of shots. And there was two or three more shots fired and he informed me that no way could those have been the shots, because there was only three shots fired and that I was wrong, and --
Ken Ray: Do you recall who it was that told you that?
Jean Pugh: I was referred to the investigating dete -- homicide det -- the homicide detective who was handling the investigation of the killing.
Ken Ray: Do you recall the name Armando Saldate?
Jean Pugh: It was -- ah, it was not an easy name, so I --
Ken Ray: --- or, ah --
Jean Pugh: -- because I didn't think it was important. But I could not swear what the name was.
Ken Ray: Alright.
Jean Pugh: I was referred to the homicide detective handling the investigation. But I called the Sheriff's department, and I called the Peoria police department, ahm, 'cause I didn't know who to call.
Ken Ray: Aha.
Jean Pugh: And I was just, you know (inaudible) trying to put something together they should have, you know, I should --
Ken Ray: Sure.
KIRK FOWLER : Did she call Phoenix police?
Ken Ray: Did -- when you spoke to the -- the first law enforcement officers you spoke to were the Sheriff's department?
Jean Pugh: Yes, I believe they were.
Ken Ray: Or were they the Peoria police department?
Jean Pugh: I'm not real sure which ones I called, because one was not too interested, the other one immediately gave me the phone number and told me to call that department, that they were the investigating homicide detectives.
Ken Ray: Alright. Now, in connection with the shots, the hearing of the shots -- when did you call the police, or the law enforcement officers?
Jean Pugh: I called them when it came out in the newspapers or on television --
Ken Ray: I see.
Jean Pugh: -- but I found -- it was Monday or Tuesday when I found out that the litte boy -- it must have been Monday -- when I found out the little boy had been killed.
Ken Ray: Alright. And when, when you saw this --
Jean Pugh: I wasn't the only one here.
Ken Ray: I'm sorry?
Jean Pugh: At the time -- I don't know what time it was -- my son was starting a BBQ, he'd come out that day.
Ken Ray: Aha.
Jean Pugh: And there was another friend here. So I mean, there was three of us.
Ken Ray: Aha.
Jean Pugh: I wasn't the only one that heard the shots.
Ken Ray: Okay.
Jean Pugh: And then my neighbors, she said -- well, their dogs raised so much hell ah, and she counted them and she said she heard five.
Ken Ray: Could you tell me how far from, how far were you in distance from seeing this white car?
Jean Pugh: Ahm, it would be straight across about a block and a half. Now you understand I'm on a mountain. The area were the boy was killed was on the southside of another hill, so they come up. Now, they call it the Gaspipe --, ah, El Paso Gasline Road.
Ken Ray: Aha.
Jean Pugh: And the cars go up over that and then down to the gulley or else they come from the south or the north. Now, I've seen the car headin' south.


Outlook from Jean Pugh's home
Outlook from Jean Pugh's home

Comment : The photograph shown above marks the "south" (S) and "north" (N) direction. The big red arrow marks the place where Christopher Milke was found shot to death, hidden by the hill on this picture. The dotted red line (starting left of that hill) is Lake Pleasant Road, which leads back to Union Hills Drive. Cars going south on that road can truly be observed from MS. PUGH'S home.
Ken Ray: Alright.
Jean Pugh: And --
Ken Ray: And that was after the shots?
Jean Pugh: Yeah. When I thought it was save to go out --
Ken Ray: Sure.
Jean Pugh: -- I went out. I'm not a complete idiot. I've had heavy, heavy shell ricochets across my property, I've had it.
Ken Ray: Oh boy.
Jean Pugh: Of course I've had a horse shot, it was twice from the ricochet bullet. So, I am -- I'm not a brave person when I'm hearing shots, I don't know where they're coming from (inaudible) where the most safest spot. It mean that probably sounds gross to you, but -- uhm -- with all the shooting that goes on around here -- but it's coming down slowly now.
Ken Ray: Oh, I noticed when I walked the area out there, there appeared to be a lot of, you know, evidence of gunshooting out there.
Jean Pugh: Oh yes. But just that particular weekend that was all the shooting that there was, was just that one time.
Ken Ray: Do you, do you recall approximately what time of day it would've been?
Jean Pugh: No, I -- I've tried to place my mind to it, my son, like I said, was lightening the BBQ.
Ken Ray: Aha.
Jean Pugh: And -- but when my son's out here, it's like having a new-born baby, that man -- you never can fill him up and it's feeding time constatly, and I BBQed twice that day. And --
Ken Ray: Okay, and this was the first time the BBQ was lid up?
Jean Pugh: I'm not real sure of that. I just know he was lightning a BBQ. I asked him afterwards "Do you remember, which, you know, which time when you heard the shots," and he said "no" and I asked Alan and Alan says "No. I just know it was time to eat again." Ken Ray: It was certainly daylight out, correct?
Jean Pugh: Oh yeah, it was afternoon.
Ken Ray: Yeah.
Jean Pugh: But see, we don't eat -- you know, we don't, ah, I'm retired, I don't eat at -- say -- for years -- you know -- about at a certain time, and lunch at a certain time, and dinner at a certain time.
Ken Ray: Sure.
Jean Pugh: Ahm, no, we just eat when we feel like it. See, there's the difference, so there's no certain hour.
Ken Ray: Right.
Jean Pugh: And -- ah, so I have -- my grand daughter was here, she's pretty efficient but the shock the next day of her, hearing the little boy was shot wiped her out. But her little boy had a post drowning. A drowning post, they call it.
Ken Ray: Aha.
Jean Pugh: Ahm, in the spring of that year, in February prior to this. And it just blanked her out. She don't remember the shots, she said -- yeah, she went out with me, we were playing gin rummy, she don't remember a thing, she blanked out completely.
Ken Ray: Hm.
Jean Pugh: Any upset like that to her -- see, this is the thing, everybody says how cold the woman is --
Ken Ray: Yes.
Jean Pugh: -- now, on the stand. I have been through this for a year and a half with my grand daughter. She went into real deep shock, when the police called her home from work, or called her to the babysitter's house from work and told her her son -- they didn't tell her, they just, they called and said to get over there. She got there. They didn't tell her anything about the boy. She went all through the house, all through the yard, every place hunting for her son. Actually she was in hysterics, they said "Your son drowned, we aerovac him to the hospital, see if he could be revived". Well, that was it. I mean that was all it took.
Ken Ray: Aha.
Jean Pugh: Now, she -- they were left. Now, she had to get help to drive her, somebody to drive her to a hospital. She walked in a child had been revived, he had been revived before they aerovac him, and he was laying there asleep in his crib. He was in a coma. But to her the child was alright, you know I'd asked for her "how's the baby?" "He's fine, he's asleep". Now we went through that for month, but she could quote to me I'd say what did the docter say and she would repeat, everything, medical term and all per word what the doctor would tell her, but it didn't come together. I worked with her for, ahm, I had her with me, my responsibility for a year and a half, and she's not completely, not as perfect yet but she has come out of shock and she is putting her life together and then my daughter took the little boy because he did not die, ahm, he wasn't as lucky as this little boy he ended up eventual.
Ken Ray: Yeah.
Jean Pugh: So I mean I understand how a traumatic shock can effect a person. Now, whether this woman is in shock or not, I don't know. But I'd be willing to damn well bet, after how like my grand daughter was handled, like this woman was handled just as forceably and as cruelly. So I said, "Yeah, I can see why she's not showing any emotions". I used to tell my daughter, or granddaughter -- get mad, throw dishes, hit the wall, I rented the apartment, I've paid the deposit on it, I've picking up the bills, I said "I don't give a damn, just do something besides just" -- no, she says, grandma, I don't feel anything.
Ken Ray: Aha.
Jean Pugh: And she stayed in that state for over one year before she would start coming out of that. And I'd have been glad to bought her dishes, I'd have paid for -- the wall's been repaired, I'd have paid for anything to just get her -- to show some emotions, so I do understand what my grand daugther went through with the police. I don't know whether this woman is guilty, I have no way of knowing. But --  if they're not using the fact that there was more shots -- see, they never questioned anybody in the neighborhood. They never came out and asked anybody, anything. Whether or not we've heard it, or seen anything, or made any inquiry from any of us neighbors. And we're all home --
Ken Ray: (Cough)
Jean Pugh: And --
Ken Ray: Ma'am, when I went out these myself -- I don't know, it's been -- you know, I was out there within three or four days of when the accident, when the incident happened. And my memory was that I didn't remember any houses close by, so I'm, I'm, now -- you know, I haven't been out there since --
Jean Pugh: Alright. You look for the scene for the of where the action was at the foot of the mountain in the ravine. Then look east, shown even on the news reels. If you look to the east, there was a chain linked fence.
Ken Ray: Aha.
Jean Pugh: That's (inaudible) Rosenfirsts (phonetic), they were not home. Now, I live just a block from them, on 93rd Ave. straight up the north of there.
Ken Ray: Aha.
Jean Pugh: Like I said, I'm on a mountain top, it's a white house.
Ken Ray: Yeah.
Jean Pugh: It's uncovered. Now, on the other side of Lake Pleasant Road -- alright, across me there's another man living -- uhm, right across Lake Pleasant Road is the Griffins, Carol and Dale Griffin. And the sound carries to their house for the shots, it's a two-story home.


The white house of Ms. Pugh
Ms. Pugh's 'white' house on top of the hill

Ken Ray: Aha.
Jean Pugh: Now, I haven't talked to the other three parties that own -- that live over there, whether they heard them or not, because I don't -- I don't see the other three parties.
Ken Ray: Aha.
Jean Pugh: But I see Carol and Dale quite often and like I said, the dogs made such a racket, that she counted five shots. So whether it's more before she started counting or not -- I don't know.
Ken Ray: And now this white car that you saw -- do you -- did it look like a small car?
Jean Pugh: It was just an ordinary white car. I would not be able to tell, I don't know makes the cars. You know, car is strictly something to get you from point A to point B, and hope to God it gets you back to point A.
Ken Ray: (chuckle) That's true.
Jean Pugh: Uhm, it was just a white sedan, I couldn't tell if it's two or four doors.
Ken Ray: Sure.
Jean Pugh: But I never seen a red car.
Ken Ray: And -- where was it that you heard about a red car?
Jean Pugh: I don't know. I read in the paper or the officer told me, they were driving a red car.
Ken Ray: Interesting.
Jean Pugh: And I thought "Well shit, at least I've called, I've tried". And that's why I made two phone calls, I think I called the Peoria police first, and they referred me to the homicide detective and the homicide detective was so cruel and, you know -- factually called me a liar --
Ken Ray: Aha.
Jean Pugh: Everything he said was "You're a bold-faced liar", he just used another language.
Ken Ray: Let me give you some names and see if -- let me repeat some names to you and see if it -- any names sound familiar to you? Ah, Armando Saldate? Does that sound familiar?
Jean Pugh: I don't know.
Ken Ray: Detective Ontiveros.
Jean Pugh: Sir, I've heard all those names --
Ken Ray: Have you? Alright.
Jean Pugh: -- so I woud not, I could not honestly swear on it and I don't think I wrote it down. I've, uhm, frankly --- I was upset, I was just gonna say "Well shit, I've done everything I could do". I called my attorney yesterday afternoon --
Ken Ray: Aha.
Jean Pugh: -- and I said, Matt, you know -- you know me. I'm, I'm troubled over a situtation. Ah -- I don't know if they're all guilty, I don't know if any of them is innocent, but you know me and my gut feelings, and he "Yeah, I sure know you and your gut feelings" and he says "I respect them". And I says "This is what happened". And I says "I just don't feel right about ignoring it". He says "Get ahold of her lawyer". And I told him what happened. And he says "Get ahold of her lawyer". And I don't know if it do any good or not I said I had inf --- ooops --- I can't prove what I was about to say.
Ken Ray: Well, I'll tell you what --
Jean Pugh: No, you'd know what to do with the information, cause I said there's something I know but I can't tell, because I don't -- because the way I found out about them half truths because I was so upset and I made a lot of phone calls and I cannot back up how I found out without jeopardizing people, but the one man is going state evidence, he's a state, state witness, for the state --
Ken Ray: Who's this, Ma'am, I'm --
Jean Pugh: There were two men involved in that killing.
Ken Ray: That's right.
Jean Pugh: There was the women's boyfriend --
Ken Ray: Right.
Jean Pugh: And then a friend of the man.
Ken Ray: Right.
Jean Pugh: Alright. The friend of the man as I understand is the one that, that let him to the body.
Ken Ray: Right.
Jean Pugh: He is the one that's giving them all the information and all this hell-or-blue about getting money from her to kill the kid and then the two men went together to kill but he never got out of the car.
Ken Ray: Okay. That's the correct recitation of the governments theory, anyway.
Jean Pugh: Alright, now I was true, true sources that I cannot reveal to you --
Ken Ray: Aha.
Jean Pugh: -- ahm, ah, the gentleman that was not going with the lady, the friend of the man --
Ken Ray: Yes. Hm.
Jean Pugh: -- that's doing all the talking --
Ken Ray: Yes.
Jean Pugh: Ahm, he actually told them there was twelve, shots -- or seven shots fired. That they picked them up, threw them out the window of the car when they were leaving. But they couldn't find the shells, so he was to keep his mouth shut and there was only three shots fired and that was the story he was to tell. But there was only three shots fired. Now he's covering his butt by implicating the other two. And then they got a quick shut and dry conviction.
Ken Ray: Without disclosing those sources, are they in any nature, ah, government officers?
Jean Pugh: One is --
Ken Ray: Alright.
Jean Pugh: -- but, I don't know how many officers know about it.
Ken Ray: I understand.
Jean Pugh: I haven't -- Matt said, you'd know what to do? I said Matt, "What I've got?" You know -- I says, "I can't explain now, I can't use how -- I got the information." I says I was so upset, ahm, when they denied how many shots was fired and I said the whole attitude, I -- I just felt there was something wrong and I says, "For the fact I have reasons why I'm -- I haven't, I'm not -- that I'm here. I want to wait and see how this trial went 'cause I felt I don't know who's guilty and who isn't." If they are guilty I don't wanna see 'em get off, but if they're not guilty I don't wanna see them railroaded.
Ken Ray: Right.
Jean Pugh: And -- why aren't they using the information? I mean why are they changing the story? Why don't they want any information on this killing? Why don't they want the neighbors to come forward? Why didn't they check with us neighbors out here? Ah, why don't they want any information from us? So something -- now, my gut feeling says, when they don't want information, they don't want witnesses to come forward then there's goddamn something wrong.


Click to listen to an excerpt
of the phone talk between JEAN PUGH
and defense attorney Kenneth Ray.

Ken Ray: Ma'am, I'll tell you what. I sure appreciate your phone call, ah --
Jean Pugh: I don't know if it's going to do any good --
Ken Ray: Well, let me tell you it can't hurt and --
Jean Pugh: He's lying. If they're lying about one thing covering up, then how much more are they lying about and covering?
Ken Ray: That's my question, and that's why your information is important.
Jean Pugh: This has been bugging me -- and like I said, ever since I called and talked to him, because I am a very sound person, I'm not senile, ahm --
Ken Ray: That sound quite clear to me.
Jean Pugh: I don't make things up, ahm, and I just -- the, the whole attitude just floured me.
Ken Ray: Ma'am, woud you be willing to meet with me sometime this weekend?
Jean Pugh: Yeah.
Ken Ray: Would -- ah, I have to go to Las Vegas tomorrow, in connection with this case. I won't be back -- so I'm gonna be gone all day tomorrow, but I'd like to meet with you on either Sunday or Monday, if that's convenient to you.
Jean Pugh: Yeah, now -- ahm, well we'll probably go early Sunday morning. There is an antique tractor show over by Goodyear that we are planning on going to . And we'll go out, for I don't like the heat. And so we should be here, ah, in the evening, Sunday evening with no problems, later Sunday afternoon, Sunday evening.
Ken Ray: I would like if it's, if it's possible and again convenient for your schedule I'd like to be able to meet you in the daytime so that we can have benefit of the, you know, of the daylight --
Jean Pugh: I'll show you where everything took place.
Ken Ray: Exactly.
Jean Pugh: Now I have never gone near where the child was killed, I couldn't do that. Or where the child was killed, but I have never gone near the spot ...


(after this point an appointment was discussed; talk ends within three more minutes)

Only five days after this telephone interview has taken place, JEAN PUGH appeared in the court room, testifying on behalf of the defense. It should be noted that an additional, subsequent interview has taken place on October 9, 1990 with Phoenix police detective BOB MILLS. In that interview JEAN PUGH didn't reveal more information about the sources she mentioned to Ken Ray. Therefore Mr. Ray was hesitant to include this point in his examination at trial:



JEAN PUGH, called as a witness herein, having been first duly sworn, was examined and testified as follows:

DIRECT EXAMINATION
BY MR. RAY :
Ken Ray: Ma'am, if you will, pull the microphone farther down so that it will pick up your voice. And be sure to speak loudly so we will all be able to hear you, okay?
Jean Pugh: All right.
Ken Ray: Would you please state your name for the record and spell your last name?
Jean Pugh: Laura Jean Pugh, P-u-g-h.
Ken Ray: And where do you reside, ma'am?
Jean Pugh: 26223 North 93rd Avenue, Peoria.
Ken Ray: Can you give us an indication of the approximate cross streets where you live, ma'am, or cross street?
Jean Pugh: One block south of Jomax and approximately -- well, 93rd Avenue.
Ken Ray: All right. And how long have you lived at that location.
Jean Pugh: Since 1977.
Ken Ray: All right. And were you present at that location on December 2 of 1989?
Jean Pugh: Yes, I was.
Ken Ray: All right. At that location, were you there all day or had you left at any point in time?
Jean Pugh: No, I was there all day.
Ken Ray: Was there anyone else with you?
Jean Pugh: Yes.
Ken Ray: Who was with you?
Jean Pugh: My oldest son and a friend.
Ken Ray: Anyone else?
Jean Pugh: My granddaughter.
Ken Ray: Other members of your family?
Jean Pugh: Yeah.
Ken Ray: All right. Having lived in this area for that long, had you ever had occasion to hear gun fire?
Jean Pugh: Continuously.
Ken Ray: Can you describe the area, whether it's very urban or more rural than urban?
Jean Pugh: It's beginning to be urban. It has been very rural up until the last couple of years.
Ken Ray: Say, in the month of November of 1989, do you have an estimate as to how often you would hear gun fire?
Jean Pugh: Oh, every weekend.
Ken Ray: On this particular day, December 2, 1989, did you have occasion to hear gun fire?
Jean Pugh: Yes, I did.
Ken Ray: Where were you at the time you heard it?
Jean Pugh: Outdoors and in the house. I was in the house first.
MR. RAY : If I may have the witness step down to the easel, Your Honor.
THE COURT : You may.


(The witness went to the easel.)

BY MR. RAY :
Ken Ray: Ms. Pugh, I'm going to show you an item which is -- see, the number is -- Exhibit 106, which has been received into evidence.
Why dontt you stand over here. And if you can accept this as being Happy Valley Road, as indicated, and 99th Avenue, as indicated, could you point to the map and indicate where your house is?
Jean Pugh: Right there.
MR. RAY: With the Court's permission -- no, this is the government's exhibit.
May that position also be marked?
THE COURT: Any objection, Mr. Levy?
MR. LEVY: No, Your Honor.
THE COURT: You may mark it.

BY MR. RAY :
Ken Ray: Ms. Pugh, would you please draw a circle in black around. your house?
Jean Pugh: All right.
Ken Ray: Could you describe the location of the house, whether it's in a valley or on the hill? What is it like?
Jean Pugh: 2200-foot elevation.
Ken Ray: And from your house are you able to see the surrounding area?
Jean Pugh: Yes.
Ken Ray: Is there any point that is obstructed, that obstructs your vision?
Jean Pugh: Yes.
Ken Ray: Where?
Jean Pugh: Well, no, it's over the top of it. No, there is no obstruction.
Ken Ray: Are you able to see 99th Avenue and traffic that flows on that?
Jean Pugh: I see -- this is Lake Pleasant Avenue, 99th here.
Ken Ray: Be sure to speak up so the jury can hear.
Jean Pugh: It's Lake Pleasant Road. 99th Avenue stops down here and this becomes Lake Pleasant. There is a small area right here. I believe that's the mountain, that small hill. That obstructs my view just a very little bit right in there.
Ken Ray: Just draw a line to the point where you indicated your view is obstructed a little bit.
Okay. Thank you.
You have indicated on December 2nd you had occasion to hear gunshots.
Jean Pugh: Yes.
Ken Ray: What time of day did you hear those?
Jean Pugh: Sometime between 10:00 and 11:00. Probably closer to 11:00. I'm not real sure because I wasn't keeping track.
Ken Ray: All right. And what did you do in response to hearing those sounds?
Jean Pugh: I stayed inside until the first series ceased, then I went out to look to see who was shooting.
Ken Ray: Could you tell from where you were at when you heard those sounds from what direction they came?
Jean Pugh: Yes. They were coming from the southwest.
Ken Ray: Why did you take it upon yourself to go look? Was there something unusual about this?
Jean Pugh: Well, yeah. The shots were strange. They weren't the normal shots we have out there.
Ken Ray: What was different?
Jean Pugh: They were so low-caliber. It was the appearance of a mature shooting. It was not someone that shoots to target practice or knows how to handle a gun.
Ken Ray: How many shots did you hear?
Jean Pugh: Three or four.
Ken Ray: From what direction did the shots appear to come?
Jean Pugh: From the southwest.
Ken Ray: And you went outside and looked to the southwest?
Jean Pugh: Yes.
Ken Ray: And what did you see?
Jean Pugh: I didn't see anyone.
Ken Ray: All right. Did you see any objects or anything?
Jean Pugh: No.
Ken Ray: Did you have an occasion to see from where those shots came, the exact point?
Jean Pugh: No. I was satisfied where they were coming from.
Ken Ray: And where was that?
Jean Pugh: From the base of the mountain there that I showed you, the hilltop.
Ken Ray: Where this area is, this location that has the red circle?
Jean Pugh: Yes.
Ken Ray: And as you looked at that location, did you see any vehicies?
Jean Pugh: At that time, no.
Ken Ray: Did you have occasion later to see vehicles?
Jean Pugh: Yes.
Ken Ray: What did you see?
Jean Pugh: I seen a white vehicle leaving on the gasline road.
Ken Ray: In which direction was the vehicle headed?
Jean Pugh: South.
Ken Ray: Did it appear to be moving slowly or average?
Jean Pugh: For that road, average.
Ken Ray: All right. Did you hear any sound of squealing tires or anything of that nature?
Jean Pugh: No.
Ken Ray: Did you ever see any people around or within that car?
Jean Pugh: There appeared to be one person in it.
Ken Ray: Now, it is quite a distance, is it not, from your house to the location that has a circle?
Jean Pugh: About a block and a half.
Ken Ray: Are you able to -- do you wear glasses?
Jean Pugh: Sometimes when I read.
Ken Ray: Do you have vision problems?
Jean Pugh: I'm farsighted.
Ken Ray: Do you feel comfortable saying you saw a white car pull away slowly or leaving this location marked in the red?
Jean Pugh: Yes, I do.
Ken Ray: All right. Did you hear any other shots that day?
Jean Pugh: Well, after I went back in, I heard three more shots, but they were more -- had a rhythm to them. They were a different type of shot, but the same caliber. There was just a matter of possibly two minutes between the first group of shots and the second.
Ken Ray: Did it appear to come from the same direction?
Jean Pugh: Yes, they came from the same spot.
Ken Ray: Did you have an occasion, then, on the following evening December 3rd, to see any kind of activity in the area of this red circle on Exhibit 106?
Jean Pugh: Yes, I did.
Ken Ray: What did you see?
Jean Pugh: Late, when coming home from dinner, they had floodlight set up and they would not -- we wanted to go out to dinner and they wouldn't let us go on Lake Pleasant Road. We had to go back and go 93rd Avenue down to Happy Valley Road in order to get out of the area to go out for dinner.
Ken Ray: And when you got up -- you went back up to the house?
Jean Pugh: Yes.
Ken Ray: And what did you do as the evening progressed?
Jean Pugh: My granddaughter was living just a block from us and we came back from the restaurant and we went down to talk to her and spent several hours with her.
Ken Ray: Did you have an occasion to call any police officers an that day or thereafter?
Jean Pugh: Yes. After I heard about the child being killed, I contacted -- I believe I contacted the Sheriff's Department, and I know I contacted the Peoria Police Department and reported that I had heard. the gunshots. They were the only shots fired that day out there. And they referred me to -- gave me a phone number and referred me to the homicide detective that was handling the investigation.
Ken Ray: Did you make contact with that detective?
Jean Pugh: Yes, I did.
Ken Ray: Do you recall his name?
Jean Pugh: No, I don't.
Ken Ray: All right. And what did you tell that detective?
Jean Pugh: I told him I heard the shots and -- but he wasn't interested.
Ken Ray: How long was your conversation with the detective?
Jean Pugh: Probably not more than a coupie of minutes at the most.
Ken Ray: At the conclusion of the conversation, how did you feel?
Jean Pugh: I was very upset. This child had been murdered and they weren't interested in any information from the neighborhood where it happened.
Ken Ray: Between that phone call -- well, strike that.
When did you and I first meet?
Jean Pugh: First meet or when I called you on the phone?
Ken Ray: Well, when you called me on the phone.
Jean Pugh: Last Friday.
Ken Ray: Had we ever met before that?
Jean Pugh: No.
Ken Ray: And then we -- as a result of that phone call, we then later met at your house, did we not?
Jean Pugh: Yes, the following Monday.
Ken Ray: Between the time that you made the phone call to the detective, homicide detective, and until that day, had you ever been contacted by anyone in connection with this case?
Jean Pugh: No, not at all.
Ken Ray: Any police officers?
Jean Pugh: No.
Ken Ray: Any investigators?
Jean Pugh: No.
Ken Ray: Did you have occasion to hear any gunshots today?
Jean Pugh: Not today, no.
Ken Ray: Have you heard any recently?
Jean Pugh: Last night.
Ken Ray: What time?
Jean Pugh: Probably about quarter after 6:00. There were four shots fired. I went inside at 6:25.
Ken Ray: And could you tell where those shots came from?
Jean Pugh: Oh, about two miles from us down West Jomax Road west of me.
Ken Ray: This being Jomax Road here?
Jean Pugh: Yes.
Ken Ray: Further to the west?
Jean Pugh: Yeah. That is three miles, maybe two-and-a-half.
MR. RAY: All right.
No further questions, Your Honor.
THE COURT: Cross-examination.

CROSS-EXAMINATION

BY MR. LEVY:
Noel Levy: Ms. Pugh, do you remember this particular day because you testified that you saw activity down on 99th Avenue and it was taped off?
Jean Pugh: Yes. That Sunday evening nobody was allowed on Lake Pleasant Road between Jomax and Happy Valley.
Noel Levy: That's how you remembered the shots fired that day?
Jean Pugh: No. The shots were so --
Noel Levy: Excuse me, Ms. Pugh. Did you not testify just a few minutes ago that you remembered these shots because you saw the activity? You were coming home from dinner on 99th Avenue and you saw it taped off and something about your granddaughter coming around. Is that different now?
Jean Pugh: I said I heard the shots Saturday and that they were so unusual that they stuck in my mind and that at the scene they wouldn't let us on Lake Pleasant Road on Sunday.
Noel Levy: Now, Ms. Pugh, you have been interviewed by defense counsel and you were interviewed by Detective Mills, is that correct?
Jean Pugh: I have.
Noel Levy: And you told defense counsel in an interview that he had with you over the phone Friday that just prior to the shooting you saw your neighbor with a gun.
Jean Pugh: No, that's not what I said.
Noel Levy: What did you say?
Jean Pugh: I said I had seen my neighbor prior to then, that he was carrying a gun.
Noel Levy: Okay. Furthermore, you have stated -- and you were personally interviewed by Detective Mills, correct?
Jean Pugh: That is correct.
Noel Levy: Do you see him sitting at the table?
Jean Pugh: Yes. I recognize him.
Noel Levy: And you said that the shots came just below the base of your hill where you are on this aerial. Am I correct?
Jean Pugh: No, you are not far enough over.
Noel Levy: How far over? This far?
Jean Pugh: Go over to where -- where the outline is, the two marks just below that on the drawing.
Noel Levy: Fine, Ms. Pugh. Whatever. Are you saying that it's below these two double marks?
Jean Pugh: Yes.
Noel Levy: That's what you are saying now?
Jean Pugh: That's the spot that I cannot see, where the two spots were marked, where I cannot see Lake Pleasant Road.
Noel Levy: Are you denying, Ms. Pugh, you told Detective Mills, and drew a diagram, that it was right down here in this draw that you heard the shots coming from?
Jean Pugh: I told him that's where the shots were coming from, was the draw, but --
Noel Levy: You are not --
Jean Pugh: Where the draw --
THE COURT : Mr. Levy, you are going to have to wait for the witness because the Court Reporter can't take two of you at ance.
MR. LEVY : I'm sorry.

BY MR. LEVY:
Noel Levy: And you also testified, or told Detective Mills that this white car you are talking about was also down here at Gasline Road?
Jean Pugh: That's right.
Noel Levy: There is a trail down here, isn't there, at the base of the hill that you lived on?
Jean Pugh: That is right.
Noel Levy: And did you see which way it drove out?
Jean Pugh: It drove south.
Noel Levy: And so it went down along this way, is that correct?
Jean Pugh: May I make a remark?
Noel Levy: I'm saying --
Jean Pugh: Where I'm looking at from the map, the trail does not show, the Gasline Road does not show, so it's rather difficult for me from here to tell you where the Gasline Road is as to where they -- the draw is. If I could step down, I could point out where the draw was.
Noel Levy: I will get to that, Ms. Pugh. All right?
Jean Pugh: Okay. All right.
Noel Levy: This trial -- you were watching it an TV, were you not?
Jean Pugh: Very little.
Noel Levy: And you decided, having seen it, that you wanted to be a part of it, isn't that so?
Jean Pugh: No.
Noel Levy: And so you decided to call Mr. Ray, is that right?
Jean Pugh: No.
Noel Levy: In any event, you heard the shots at around 10:30 to 11:00 in the morning?
Jean Pugh: Yes.
Noel Levy: And you were in and out of the house the rest of the day?
Jean Pugh: The rest of the day? Yes, I was in and out of the house.
Noel Levy: And you had company?
Jean Pugh: Yes.
Noel Levy: And sometimes -- I take it that you weren't in a closed room?
Jean Pugh: No.
Noel Levy: Never?
Jean Pugh: The windows were all open. It's a glass house.
Noel Levy: In any event, again, the shots that you claim that you heard, you have a particular recollection that they were between 10:00 and 11:00 a.m.?
Jean Pugh: Yes.
Noel Levy: And you did not see anyone?
Jean Pugh: No. The only thing I saw was the car.
Noel Levy: In any event, now that you have mentioned that you can't see too well, maybe it's easier if you came down, with the Court's permission, Ms. Pugh.
THE COURT : Certainly.

BY MR. LEVY:
Noel Levy: Come ahead.
Now, Ms. Pugh --
Jean Pugh: This map is straight out so far in proportion --
Noel Levy: Excuse me, Ms. Pugh. Could I ask you the question?
MR. RAY: May I move over, Judge?
THE COURT: Certainly.

BY MR. LEVY:
Noel Levy: Now, Ms. Pugh, that you are closer to this aerial view, do you see your house?
Jean Pugh: Yes, I do.
Noel Levy: Do you see Jomax Road?
Jean Pugh: Yes, I do.
Noel Levy: Now, for the Court Reporter and the jury to hear, maybe you could just turn a little bit. Talk up.
Jean Pugh: All right.
Noel Levy: Thank you.
Now, when the defense counsel suggested that the shots were coming from way over here, nearly a mile away, were you actually able to see where he was painting?
MR. RAY : Objection, assumes facts not in evidence. Misstates --
THE WITNESS : Yes.
MR. RAY : -- the witness' testimony.
THE COURT: Sustained.

BY MR. LEVY:
Noel Levy: Are you saying that you heard the shots down here as you told Detective Mills the other day or --
MR. RAY : Objection, calls for an answer based on hearsay.
THE COURT : Sustained.

BY MR. LEVY:
Noel Levy: Didn't I -- I asked you, ma'am, if --
Jean Pugh: I'm pointing to the road here. This is 93rd. This would be -- all right. That would be 94th. This would be 95th here. This is not -- the one here would be Gasline Road, right here.
Noel Levy: Okay.
Jean Pugh: This is the mountain range. He wanted to know why I couldn't see Lake Pleasant. This mountain range goes through here. There is a hill. This is up over the top of this hill. This is the area of Lake Pleasant Road. I'm unable to see it because of this hilltop right here.
Noel Levy: Thank you very much.
Jean Pugh: There was shooting right here. That's where I heard the shots coming from, is that general area.
Noel Levy: Can you make a circle where you said you saw them coming from?
Jean Pugh: Yes. This would be the area down in here.
Noel Levy: You didn't see anybody, so you can't tell precisely?
Jean Pugh: No, I did not see --
Noel Levy: You could just hear sounds?
Jean Pugh: Because of the way the mountain range is.
Noel Levy: Ms. Pugh, you just heard the sound?
Jean Pugh: Yes, I heard the sound.
Noel Levy: You saw a white car?
Jean Pugh: Yes.
Noel Levy: Where?
Jean Pugh: Do you want me to put a mark?
Noel Levy: Use a green -- you just drew a circle in blue an Exhibit 106 where you heard the shots coming from, correct?
Jean Pugh: Right in there.
Noel Levy: And you drew a green circle an Exhibit 106 where Gasline Road is, correct?
Jean Pugh: Yes.
Noel Levy: And then you saw a car heading south, is that correct?
Jean Pugh: Yes.
Noel Levy: So if you draw an arrow south, that's where you saw --
Jean Pugh: Yes.
Noel Levy: Could you see the make of the car?
Jean Pugh: No.
Noel Levy: The style of the vehicle?
Jean Pugh: It was just a car.
Noel Levy: It wasn't a pickup?
Jean Pugh: It appeared to me probably it was a sedan. I can't say four-door or --
Noel Levy: You don't know --
Jean Pugh: I paid no attention to --
THE COURT : Mr. Levy, could the witness retake the witness stand?
MR. LEVY : Yes, Your Honor.
THE COURT : Thank you.

BY MR. LEVY:
Noel Levy: And again, it was between 10:30 and 11:00 a.m. on December 2nd?
Jean Pugh: In that time, yes.
Noel Levy: So if I put 10:30 or 11:00 a.m. right there in blue, that would be --
Jean Pugh: 10:30 to 11:00 -- no, I would say closer to 11:00.
Noel Levy: But didn't you say between --
Jean Pugh: It was in that hour. I wasn't keeping track of time that morning.
Noel Levy: Would it be fair if I put between 10:00 and 11:00?
Jean Pugh: Be fine.
Noel Levy: So, in blue, 10:00 to 11:00. And it was a.m., was it not?
Jean Pugh: Yes, it was.
Noel Levy: And this was Saturday?
Jean Pugh: Yes. It was on December 2.
Noel Levy: 1989?
Jean Pugh: That's correct.
Noel Levy: And did you report that to the police at the time you heard it?
Jean Pugh: The time?
Noel Levy: The time that you heard these shots.
Jean Pugh: When I first called the police?
Noel Levy: Did you call the police --
Jean Pugh: I --
Noel Levy: -- between 10:00 and 11:00 on December 2, 1989?
Jean Pugh: No, I did not call them between 10:00 and 11:00.
Noel Levy: Do you ever call the police when you hear shots?
Jean Pugh: Not until after we were taken into the City of Peoria.
Noel Levy: And how often have you called about shots in Peoria?
Jean Pugh: I have called there once and was -- with no response. It wasn't the time to call in.
Noel Levy: But you have heard shots, I think you said, quite often?
Jean Pugh: Continually.
Noel Levy: Pardon?
Jean Pugh: Continually.
Noel Levy: Ma'am, do you recall ever driving south on 99th Avenue by this wash here?
Jean Pugh: Yes, I have.
Noel Levy: Is that quite a depression?
Jean Pugh: Yes, it is.
Noel Levy: And from your house can you see into that depression?
Jean Pugh: I cannot see in the depression, no.
Noel Levy: There are hills and things between there and your house, are there not?
Jean Pugh: Certainly.
Noel Levy: Ma'am, from where this shooting was, that you state that you heard, to your house, is that about a mile?
Jean Pugh: No, it's not.
Noel Levy: Three-quarters of a mile?
Jean Pugh: No. I would say closer to two blocks straight through.
Noel Levy: Well, ma'am, you live in 92nd Avenue --
Jean Pugh: 93rd Avenue, sir.
Noel Levy: -- 93rd. And then what is the next one over?
Jean Pugh: 94th.
Noel Levy: And the next one over?
Jean Pugh: Is Gasline Road.
Noel Levy: Then if you were -- and these are widely separated streets, are they not? I mean, they are not normal City blocks?
Jean Pugh: They are normal 666-foot blocks.
MR. RAY : Objection, calls for improper opinion and speculation, insufficient foundation.
THE COURT : Overruled.
Ma'am, repeat your answer.
THE WITNESS : I beg your pardon?
THE COURT : Repeat your answer, please.
THE WITNESS: They are normal 666-foot-length lots or blocks.

BY MR. LEVY:
Noel Levy: Well, if that's true, Ms. Pugh, if this isn't too far away, it seems to me the distance between this avenue and this avenue and this avenue and this avenue is quite different. Am I incorrect?
Jean Pugh: There is some difference, yes.
Noel Levy: And then, as you go down, it's quite a few blocks down from here, just going straight down, isn't it?
Jean Pugh: I was not going down, going south and then west, Mr. Levy. I was going diagonal toward the south corner.
Noel Levy: Ms. Pugh, please bear with me. Did I ask you that?
MR. RAY: Objection, argumentative.
THE COURT: Sustained.
Mr. Levy, she is doing the best she can.
MR. LEVY: Yes, Your Honor.

BY MR. LEVY:
Noel Levy: Now, if I put this red thing between where you live and the next street over, would you agree I have got my finger on the right place?
Jean Pugh: Yes.
Noel Levy: Okay. Now, if I was to take it from your property down, would it be four measurements down from here as across to here?
Jean Pugh: I would be better able to tell you the amount of footage that is.
Noel Levy: So you have measured it?
Jean Pugh: I know approximately where the roads are and where the draw is.
Noel Levy: Well, have you measured the distance between here and where you heard the shots, ma'am?
Jean Pugh: No, but I have had survey work done on the road.
Noel Levy: Okay. But it's more than two blocks, though, isn't it?
Jean Pugh: It is -- if you wanted to go north or south and then west, it would be, to that draw. It would be exactly one and one-half blocks if you were going directly south to the draw.
Noel Levy: That's your testimony?
Jean Pugh: Yes, from where my house is.
Noel Levy: And would you dispute, Ms. Pugh, if I suggested to you that the odometer mileage between Jomax and this wash is eight-tenths of a mile?
Jean Pugh: No. I have never checked it out.
Noel Levy: Would you dispute it?
Jean Pugh: No.
Noel Levy: So if you were simply to rotate Jomax toward your house, it would be over a half a mile but less than a mile, would it not be?
Jean Pugh: From Jomax, yes. We are not talking about Jomax.
Noel Levy: I'm talking about from here over to your house.
Jean Pugh: Yes, but that's not what you are asking me the distance from.
Noel Levy: I know that, Ms. Pugh. But my question remains the same. From this red cirle here, this wash, this dip in the road, to your house is less than a mile and more than half a mile, is that correct? That's all I'm asking.
Jean Pugh: Well, I'm fixing my mind from the survey stakes over. If you will give me a minute, I can tell you.
If you want to go diagonal, I would say right about -- to Lake Pleasant Road, as the crow flies, to my house, I would say right about half a mile.
Noel Levy: Thank you. To here?
Jean Pugh: Yes.
Noel Levy: As the crow flies?
Jean Pugh: Yes.
Noel Levy: And to here it's two blocks?
Jean Pugh: Approximately two blocks.
Noel Levy: So it's a considerably short distance from your house to where you heard the shots, correct?
Jean Pugh: Yes.
Noel Levy: And so on the morning of Saturday, December 2, 1989, you hear first three shots, pause, and then two more shots. Am I correct?
Jean Pugh: I said I heard three or four shots and I heard two or three more.
Noel Levy: Am I correct?
Jean Pugh: No. I'm correct.
Noel Levy: You are correct. Quite a few shots, then, at that time of the morning?
Jean Pugh: Yes.
Noel Levy: About two blocks, as the crow flies, from your house?
Jean Pugh: Yes, that's correct.
MR. RAY: Objection, argumentative. Asked and answered repeatedly.
THE COURT: Sustained. But I will allow the answer to stand.

BY MR. LEVY:
Noel Levy: Do you know where Ms. Griffin lives?
Jean Pugh: Yes, I do.
Noel Levy: Showing you Exhibit 106 I will bring it up to you.
MR. LEVY : If I may, Your Honor.
THE COURT : Yes.

BY MR. LEVY:
Noel Levy: Does Ms. Griffin live here?
Jean Pugh: There's two houses there. I believe that is her house. Truthfully, I can't tell from all the -- there is a house there. This is not a very good map, I'm sorry to say.
THE COURT : Ms. Pugh, you are going to have to speak up. THE WITNESS : I said it wasn't a very clear map for picking out houses. I believe that's her house right here.
Noel Levy: Do I have my finger on the right spot?
Jean Pugh: It appears to be, yes.
Noel Levy: Okay. And how far is Ms. Griffin's home from your house?
Jean Pugh: By road, driving it, about a mile-and-a-half.
Noel Levy: All right. And she lives to the west of 99th Avenue and Jomax?
Jean Pugh: I don't know which avenue she lives an.
Noel Levy: I said west of 99th Avenue.
Jean Pugh: West -- no. West of 98th Avenue. I don't know where 99th Avenue goes through. That is Lake Pleasant Road. That is not 99th Avenue.
Noel Levy: I see. Is there a difference?
Jean Pugh: There most certainly is, by several blocks.
Noel Levy: Oh, really.
Jean Pugh: Lake Pleasant Road picks up like I showed you before down on the map. 99th Avenue ceases and then Lake Pleasant Road comes over. 99th Avenue is over farther to the west from Lake Pleasant Road.
Noel Levy: So you are disputing this is even 99th Avenue, is that right?
Jean Pugh: That line is Lake Pleasant Road.
Noel Levy: You are saying it is not?
Jean Pugh: It is not -- that part of it is not 99th Avenue. 99th Avenue is over farther from Lake Pleasant Road west.
Noel Levy: West. I see. And this is Jomax Road?
Jean Pugh: Yes, it is.
Noel Levy: And according to you, this is Lake Pleasant Road?
Jean Pugh: According to the State of Arizona, that is Lake Pleasant Road.
Noel Levy: Ms. Pugh, according to you, this is Lake Pleasant Road?
Jean Pugh: Yes, it is Lake Pleasant Road.


Map of the area
Map of the area
Red Point 1 : Ms. Pugh's home
Red poiunt 2 : murder-scene

Comment : This map proves that MS. PUGH'S testimony was absolutely reasonable. 99th Ave. starts in the south, and when Happy Valley Road cuts it, the road becomes Lake Pleasant Road. 99th Ave. then continues further in the north. Therefore MS. PUGH's statement was consistent with the official map of the State of Arizona. However, Noel Levy's attempts on the credibility of MS. PUGH may have had an effect on the jury members, who reached a verdict against Debra Milke two days later, on October 12, 1990.
Noel Levy: Thank you.
MR. LEVY: That's all I have, Your Honor.
THE COURT: Redirect.

REDIRECT EXAMINATION

BY MR. RAY :
Ken Ray: Mr. Levy asked you questions concerning your decision to call in connection with this case, correct?
Jean Pugh: Yes.
Ken Ray: You did not call Debra Milke's lawyer directly, did you?
Jean Pugh: No, I did not.
Ken Ray: Who did you talk to first?
Jean Pugh: My attorney.
Ken Ray: And then you got in contact with me?
Jean Pugh: Yes.
Ken Ray: The house that you live in has a lot of windows?
Jean Pugh: Yes, sir.
Ken Ray: On practically every side, isn't that right?
Jean Pugh: Yes, sir.
Ken Ray: Are they -- what kind of windows are they?
Jean Pugh: Arcadia doors, basically.
Ken Ray: You mentioned on cross-examination that you hadn't called until the area was taken by the City of Peoria. What did you mean by that?
Jean Pugh: On the shooting?
Ken Ray: Yes.
Jean Pugh: Because we were so isolated and the Sheriff's Department was so scarce, by the time you would call the shooters would be gone.
Ken Ray: I see. Did that area, to your knowledge, recently become annexed to the City of Peoria?
Jean Pugh: It was annexed December 15th, 1989.
Ken Ray: All right. And in connection with other shots that day, this is the only set of shots that you heard?
Jean Pugh: It was the only set of shots, period.
Ken Ray: Did you see on Exhibit 106 this date?
Jean Pugh: No. I did not look for it.
Ken Ray: It indicates 8/5 of '85. Were you living there at that time?
Jean Pugh: Yes.
Ken Ray: Had there been changes since the date of this photograph?
Jean Pugh: Tremendously.
MR. RAY : All right.
No further questions, Your Honor.
THE COURT : Ms. Pugh, thank you very much. You are excused.


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