NEW JERSEY v HAUPTMANN: TESTIMONY OF FRANK A. KELLY, NINTH PROSECUTION WITNESS


STATE vs. HAUPTMANN

January 7, 1935

[389] FRANK A. KELLY, sworn as a witness on behalf of the State:

Direct Examination by Mr. Wilentz: Q. Young man, you are connected with the State Police of New Jersey, are you not? A. Yes, sir.

Q. And you live in the City of Perth Amboy? A. Yes, sir.

Q. You have been connected with the State Police how long? A. It will be eight years the 15th of this coming August.

Q. How many years did you do plain trooper duty? A. Practically a year and a half.

Q. And as a result of some injury that you received, then you went to this work that you are doing now: isn’t it? A. Identification work, yes sir.

Q. Identification. Now, you have made a study of that particular field of endeavor, I take it? A. Yes, sir.

Q. And in that connection you take photographs? A. Yes, sir.

Q. Fingerprints and things of that kind? A. Yes, sir.

[390]Q. All forms of identification? A. Yes, sir.

Q. You have attempted to school yourself and learn as much as you could about it: is that so? And you have been doing that work for the State Police for how many years now? A. About six years.

Q. About six years. And in that capacity did you come to the Lindbergh home on the night of March 1st, 1932? A. On the morning of March 2nd.

Q. About what time? A. Five minutes after twelve.

Q. And when you got there, where did you go and what did you do, sir? A. Upon my arrival I was met at the front entrance of the Lindbergh home by Corporal Wolfe, and Colonel Lindbergh, who directed me to the nursery on the second floor of the home.

Q. When you got to the nursery on the second floor of the Lindbergh home did you see a note there? A. Yes, sir; I did.

Q. And did you take that note and test it for fingerprints? A. Yes, sir; I did.

Q. And this envelope, S‑17, and the note, S‑18, both of which bear your initials on them somewhere, are those the papers that you tested that night? A. They are.

Q. Was the note in the envelope? A. It was.Q. Did you take it out? A. I did.

Q. And did you find any fingerprints there on? A. I did not.

Q. Did you use such appliances as to you or such methods as were known to you that night to the best of your ability, to try to find fingerprints? A. I did.

Mr. Pope: We object to that question; we are entitled to know what methods he used; then we will determine whether they are the best methods or not.

[391] Mr. Wilentz: Who is going to determine that?

The Court: Well, you have the full right of cross-examination in respect to that. I apprehend that the Attorney General thinks that he has qualified this officer as a fingerprint expert.

Do you deny that, Mr. Pope?

Mr. Reilly: I think we will handle it under cross-examination.

The Court: Very well.

Q. Those two things just referred to, you tested so far as those fingerprints are concerned? A. Yes, sir.

Q. What else did you do, sir? A. I made a general observation of the nursery, the conditions therein, noticed the crib and processed the rest of the room for fingerprints, noticed the dirt marks described by Trooper Wolf on the floor and on the leather bag directly under the window. My duties consisted of trying to take fingerprints on various parts of the articles in the nursery, photographs on the interior of the same and processing the ladder that was brought in by Trooper Bornmann for prints.

Q. With reference to your efforts in the room, did you attempt to get any fingerprint evidence in the room aside from the note? A. Yes, sir; I did.

Q. What did you process besides the note and the envelope? A. I processed the window sill, the window, inside and out, the crib, the screen, the light in back of the screen, the French windows, the window on the north side of the nursery, that is the north window on the east side of the nursery, the bureau drawers, a little chair that was at the foot [392] of the crib, everything in the room that it was possible to obtain a fingerprint from.

Q. Did you find any fingerprints upon those articles? A. No, sir; I did not.

Q. Now, what else then did you do later? A. I later was called down into the hall by Bornmann, who had brought that ladder in to me.

Q. When you got down to the hall, did Bornmann give you a ladder? A. He gave me two sections of a ladder. And later he brought in another section of the ladder and a chisel.

Q. And was the dowel pin in there with it? A. It was.

Q. The two that he brought in together, were they somewhat connected, the two sections of the ladder? A. Somewhat connected and somewhat disconnected.

Q. I see. Just a minute. I show you S‑32 and ask you whether that is the ladder, the three sections, that Bornmann gave you that night? A. May I examine that, please?

Q. You certainly may. A. (The witness steps from the witness stand and examines ladder) Yes, sir, it is.

Q. Did you place any marks upon that ladder which lead you to the conclusion that it is the same ladder? A. Yes, I did.

Q. Tell us what marks you put on there. Point them out to us, please. A. On this rung here I marked it No. 1 with my initial, F.K.; on this rung here I marked No. 2 with my initial F.K.

Q. Yes, sir. A. On this rung here I marked No. 3 with my initial F.K.

Q. So that upon each section of S‑32 for identification you marked in your writing a number on one, No. 1, on another one No. 2, and on another one No. 3, and underneath that number you marked your initials? A. That is correct.

[393]Q. And your initials are F.K.? A. That is correct.

Q. And you also marked, did you not, the date March 2, 1932? A. I did.

Q. On each section? A. Yes, sir.

Q. So that at least to the extent of the boards that you marked, they are the boards that were there that night and that you saw and that were given to you by Bornmann? A. Yes, sir.

Q. And are these sections the identical sections that you got from Bornmann? A. Yes, sir.

Q. And what did you do with these sections, S‑32 for identification? A. I had them in my possession except when they were taken out by investigators.

Q. Well, now I want to know about it, about the “except” and the “investigators” and who they were. How long did you have them under your direct charge? A. Under my direct charge until around June, 1932.

Q. Now from March the 1st, 1932, to June, 1932, then you had them under your direct charge and sole custody? A. That is right.

Q. And when it was taken to Washington to be processed or whatever they did with it and tested, did you take it there? A. I did.

Q. And when this operation wasn’t finished at night what did you do with it when you were in Washington? A. Locked up in a safe.

Q. And in the morning did you come and see that it was gotten out of that safe? A. I did.

Q. And is this the same, the genuine same thing that you had that night March the 1st, 1932, and carted with you to Washington and brought back? A. It is.

Mr. Reilly: Now you are leading, Mr. Attorney General.

[394] Mr. Fisher: Let the witness testify.

Mr. Wilentz: If counsel has an objection I take it that Mr. Pope knows where to direct it.

Q. Not having brought it back until June, what did you do with the ladder then? A. I brought it to the training school.

Q. And there you surrendered it to whom? A. Captain Lamb.

Q. And has it been in his custody so far as you know? A. Yes, sir.

Q. And under his charge? A. Yes, sir.

Q. All right, sir.

The Court: Surrendered it to Captain Lamb?

Mr. Wilentz: Yes, sir.

Q. Now, just one other thing before we get away from S‑32 for identification. Will you tell us so far as you know, so far as you remember and recollect, any differences in this ladder as you see it now from the time that you first saw it when Bornmann gave it to you? A. Those numbers were not on there.

Q. Which numbers, these little white— A. These little white numbers, these tags.

Q. The little white clips in each rung? A. That’s right and these aluminum tags.

Q. These aluminum tags with the numbers? A. Nor the board on the side.

Q. The white board as distinguished from the dark and used boards. A. That’s right. Nor this split.

[395]Q. A split there which seems to be the reason for putting this white there to attach one part—

Mr. Pope: We object to that question.

A. That’s right.

The Court: Perhaps it is a little leading.

Mr. Pope: Terribly leading.

A. (Continuing) And the saw cut.

Q. And the saw cut. Now where is the saw cut that you are talking about? A. On this rung.

Q. The saw cut in rung A, where there is tag Number 2 on Section 1.

Q. The cut on one of the rungs where there is a white tag Number 2 on Section 1, is that the cut you are talking about? A. Yes, sir.

Q. Now I notice a couple of holes on top; were they there? A. Yes, sir.

Q. I notice the top rung as we look at it now is separate from the sides of the ladder. Tell me whether that presented that appearance, the nails being out. A. As far as I recall, yes, it does.

Q. Now, sir, I notice these little white—what are they, thumb—some sort of— A. Some sort of a thumb tack.

Q. Thumb tack on Number 2 with your initials on? A. Yes, sir.

Q. It is Number 2 section of the exhibit we are referring to and I ask you whether those thumb tacks were there? A. No, sir; they were not.

Q. Now, what else besides that and these metal clips? A. These ropes.

Q. The metal clips and the ropes were not on. How about the indentations, other indentations? A. [396] Other than the rope and thumb tacks and aluminum tags the ladder was as I have stated.

Q. Well, as you have stated, you mean the same as you found it? A. The same.

Q. How about these holes on top? A. They were in there.

Q. Now, get to the next section, Section 3 as you have it marked with your initials “F. K.” I notice that the same sort of white thumb tacks were on there. Were they there that night, the white thumb tacks? A. No, sir.

Q. Who put them on? A. They were put on at Washington when I brought the ladder there.

Q. And these little clips, were they on? A. No, sir, they were not.

Q. What else besides the metal clips and thumb tacks do you see on this section that were not there that night? A. The rope.

Q. The rope, piece of cord. How about this dowel pin? A. That dowel pin was in the ladder.

Q. One of the dowel pins was in the ladder? A. Yes, sir.

Q. How about the other dowel pin? A. The other dowel pin was outside in the yard.

Q. Outside in the yard so that one dowel pin was in the ladder and the other was outside. Now except for that is there anything about that section that is different than the morning of March 2d, 1932, when it was given to you by the police officer that you referred to a minute ago? A. No, sir; there was not.

Q. Is it the same ladder? A. It is.

Q. It is. All right, sir. Then you came down, I take it, you processed this ladder? A. Yes, sir.

Q. And found no fingerprints on it? A. I did not.

Q. What did you do then? A. I returned to the nursery to continue my investigation there.

[397]Q. All right. What did you do? Tell us about it, please? A. I continued with my fingerprint work there in the nursery and taking photographs in the nursery.

Q. Yes, sir; and having done that, what did you do then? A. I noticed during this investigation that there was a leather case on top of a wooden chest directly under this window, the southeast window. There was a marking of dirt—

Q. Yes., A. On, facing the leather case on the left hand side, apparently a slide—

Mr. Reilly: I object to the apparently.

The Witness: It was my opinion at that time—

Mr. Reilly: I object to your opinion.

The Court: Well, just tell us what you found.

The Witness: This dirt mark on the leather case. Directly under that on the floor there was another dirt mark.

By Mr. Wilentz: Q. Just wait one minute. We will identify the leather case which you are talking about, which I think has already been done. I show you Exhibit S‑11. You notice a leather case there right near the southeast window? A. Yes, sir.

Q. Is that the leather case you are referring to? A. It is.

Q. It is the very nearest to the window sill? A. Yes, sir.

[398]Q. You say you saw some dirt smudge— Is that what you said? A. Yes, sir.

Q. All right. Now, on what part of the leather case was the dirt smudged? A. Facing the leather case it was on the left hand corner.

Q. And as you look from the window was it the far corner? A. Looking from the window with my back to the case?

Q. Well, was it the nearest side of the case to the window or the farthest side? A. The farthest side.

Q. The farthest side? A. Nearest to the crib.

Q. Yes, sir. All right. Then what did you do, sir? What else did you see, rather? A. I noticed on the floor directly under that there was a dirt smudge.

Q. Yes. A. And in the middle of the floor, going in a direction to the crib from the window there was another dirt marking on the floor.

Q. Did you test those? Did you make any test at all with reference to those dirt smudges? A. They were similar to the substance that was in the yard.

Q. Well, did you make any test with reference to them of any kind at all? A. Other than noticing the color of the dirt in the yard and the color on the floor, that was the only test that I made.

Q. Now, then, what did you do, sir? A. I continued my investigation the following morning, as soon as it got light outside.

Q. Yes. A. And made photographs of outside conditions.

Q. As the result of some notice that was directed to you did you take this picture (showing to witness)? A. Yes, sir; I did.

Q. What date? A. The morning of March 2d.

Q. 1932? A. Yes, sir.

Q. And that is a picture of part of that ground [399] and what is supposed to show as it did show on March 2d, 1932? A. Yes, sir.

Q. Referring to S‑3 for identification. Now, referring to S‑6 for identification, did you also take this picture of the board walk? A. I did.

Q. And that is a true picture of conditions as you saw them on March 2d, 1932, early in the morning? A. It is.

Q. With reference to the board walk and on the east side? A. Yes, sir.

Mr. Wilentz: I offer S‑6 in evidence.

Mr. Hauck: I understand there is no objection to that. Have it marked.

Mr. Wilentz: I offer S‑31, while counsel is looking at the other, S‑31 for identification in evidence. I understand there is no objection.

The Reporter: S‑36 in evidence.

The Court: S‑31 is admitted, there being no objection.

Mr. Wilentz: Yes, sir.

(State Exhibit S‑31 for identification is now received in evidence and marked State Exhibit S‑36 in evidence.)

The Court: How about the other?

Mr. Wilentz: It is offered without objection.

The Court: The exhibit will be admitted.

[400] The Reporter: S‑37 now.

Mr. Wilentz: S‑36 and S‑37.

(The photograph referred to was received in evidence and marked S‑37.)

Q. Now, did you—I notice that S‑36 is the picture of a footprint. Did you do anything about encasing it? A. No, sir, I did not.

Q. Did you do anything about preserving it? A. It was preserved when it was pointed out to me.

Q. In what fashion? A. Under the supervision of Lieutenant Lang.

Q. In what fashion? A. Lieutenant Lang was in custody of it to see that nobody destroyed it or tampered with it in any way.

Q. In other words, you mean that somebody was guarding it so far as you know? A. That is it.

Q. I see, but you did nothing of your own account to test it, measure it, preserve it, encase it, or anything else? A. No, sir.

Q. So that, so far as this exhibit is concerned, you know nothing about it except what this picture shows? A. That is it.

Q. With reference to the dowel pin attached to one of the sections—

Mr. Wilentz: May we consider that, for the purpose of identification, as part of the section?

Mr. Reilly: Yes.

Mr. Wilentz: Rather than offer it again?

Mr. Reilly: Yes.

[401] The Court: John, let me see that photograph there about the footprints?

(The exhibit was shown to the Court.)

Q. Now, did you also see Exhibit S‑34 for identification, the chisel—I understood you to say you did see it—did you test it for fingerprints? A. Yes, sir; I did.

Q. Found none on that? A. No, sir; I did not.

Q. Did you test the dowel pins, the one attached to the ladder a part of the exhibit for identification there, and also this identification, Exhibit S‑33 for identification, for fingerprints? A. Yes, sir; I did.

Q. Now, was the ladder which Lieutenant Bornmann gave to you on the premises assembled together in three sections? A. No, sir; it was not.

Q. I mean eventually was it put together? A. Oh, yes.

Q. Was it put together in your presence, the very ladder that was there? A. Yes, sir.

Q. And was it placed against the house? A. It was.

Q. Now, when it was placed against the house, the three sections together, on the east side of that house— A. Yes, sir.

Q. At the point where that ladder touched the house were there any marks at all, the top section? A. Yes, there was.

Q. On the third section? A. On the second section.

Q. Well, first time taking you with the three sections? A. No.

Q. The third section, when placed up at the top of the house—were there any marks there? A. No, sir.

Q. Anywhere within the vicinity of that area? A. No, sir.

[402]Q. Now, then, did you take the ladder with the first two sections, put it together, place it against the wall near that window, and did it show—

Mr. Reilly: I object to that. That is very leading.

 Mr. Wilentz: I will withdraw it if it is leading.

The Court: He is going to reframe his question.

Q. I will reframe it. What did you observe when you did that? A. I observed that at the top section, that is, the top of the second section, where the ladder had rested against the wall of the house, that there were markings, that is the width of the ladder about an inch and a half to two inches above that top section of the second ladder.

Q. I don’t understand about that inch and a half that you are just talking about. A. Placing the ladder—

Q. First when you placed the ladder did you place the ladder in the indentation shown near the board walk in Exhibit S‑37? A. I did.

Q. That is where you rested the ladder? A. Exactly.

Q. All right. Now, were the two sections of the ladder and were the foot of the ladder there in those two holes— By the way, did they fit? A. Exactly.

Q. All right, sir. Then since it did fit you put it against the house at that point? A. I did.

Mr. Reilly: Again you are leading. I am sorry, but my brothers of the Bar are so nervous from your leading I must object.

[403] Mr. Wilentz: I think maybe you are right, but sometimes in our enthusiasm—we forget.

Q. Did you take a picture of the ladder as you placed it at that time? A. I did.

Q. Is this the picture of the ladder as you placed it with the two pieces of wood in those holes shown in Exhibit S‑37? A. It is.

Q. Does that correctly portray the ladder placed against the east side of the house, the bottom part of the ladder in the indentations shown in S‑33? A. It does.

Mr. Wilentz: I offer it in evidence.

Q. And is it incidentally a picture of these two sections? A. It is.

Mr. Reilly: We object to it.

The Court: Object?

Mr. Reilly: We do.

The Court: On what grounds?

Mr. Reilly: On the ground that it does not conform to the testimony heretofore given. It shows a window of a third floor, apparently the nursery, with the shutters off, window open, the general condition not as heretofore testified to.

The Court: Well, it purports to be a photograph of an experiment. Do you put your objection upon that ground?

Mr. Reilly: Yes, sir. Also upon the ground [404] that it portrays and might portray and convey to the jury a wrong impression. It does not conform to the evidence as given heretofore, the physical condition of the outside of that house.

Mr. Wilentz: If your Honor please, it is offered for the purpose of illustration. It is intended to be helpful to the Court and to the jury, and there is nothing about that except the open windows—it is the same ladder, it is the same house—and there is nothing about that picture that the Court cannot instruct the jury about if it so happens that it should escape their memory, the fact that the windows we claim were closed at the time. But I think that it will be helpful and I don’t see why there should be objection if it is going to be helpful.

Mr. Reilly: Whether it is helpful or not we are relying upon the strict rules of evidence. I think there we are perfectly within our rights.

The Court: I suppose the true rule is that either side has a right to make an experiment under substantially the conditions which are of interest to the case and to prove the result of that experiment. That is the rule; but this proposition seems to be rather an extension of the rule and I would think that at the moment I ought to sustain this objection.

Mr. Wilentz: Well, if your Honor pleases, before there is anything like that, let me state very respectfully, that I cannot see how it is anything but a simple experiment and not an extension of the rule; because we have not only the same house, but we have not brought a [405] strange ladder on the theory that someone may have brought one to fit; we have the very same ladder, the very indentations there, the same house, everything identical, except for the physical fact that a window may have been closed or opened, which is a minor matter after all; and with those very things—we are not taking a strange object and bringing it in, if your Honor pleases, not one single strange foreign object, for the experiment, which is a very unusual thing for an experiment, but the very objects there on the ground. Now, if we are permitted to make any experiment at all, if your Honor please, for the purpose of helping the jury and for the purpose of your Honor’s help, we have certainly used only those things that are there, without a foreign object.

Mr. Reilly: Well, of course, it is not our purpose to keep anything from the jury or to prevent the Court, who needs no assistance, from getting assistance, but I say this: If I may look at the photograph, there is no evidence in this case, either direct or, to my mind, circumstantial to this case, that that child was passed out that window and down any ladder or down this ladder, and I contend that this is merely an experiment with a ladder found seventy-five feet away, brought to the house and place in some holes; the shutters are taken off the house, off the window; the window is left open, to convey to this jury an improper idea that by the window being open and the shutters out of the way and the ladder placed the way it is here in this imperfect experiment, it would be possible to go up the ladder only once, go up the ladder, put the ladder against the shutters, open the shutters with the ladder [406] leaning against them, come down, then with your window open go up the ladder again without moving the ladder, go in a window, take the child out and come down the ladder again, and still shut the shutters after you, and leave a note, your visiting card, on the radiator.

Mr. Wilentz: If your Honor please, may I suggest to my delightful adversary’s summation that this ladder when placed in the manner that we are attempting to show it with the two sections, and I don’t want my adversary to get impatient, because we will show it, placed roughly—

Mr. Reilly: I am not getting impatient.

Mr. Wilentz: —placed right up against that building, is placed in such a way that it never approaches the shutters and the shutters have got nothing to do with it. Underneath the window it falls, when you place the ladder in the two holes, indentations, the shutters are no obstruction at all, having nothing to do with this case. Here is this building and that is the more reason I think this experiment is necessary instead of being a matter of argument here is an experiment, an illustration. Let him take that ladder and take that view and situation as an experiment and let him explain it away.

Mr. Reilly: Now it seems to be the contention of the General that he brings in a ladder of three sections of which only two were used.

[407] Mr. Wilentz: That’s right; we will prove that.

Mr. Reilly: That is entirely different from his opening.

Mr. Wilentz: No, it is not.

Mr. Reilly: Oh, yes, it is. “I will bring in a ladder of three sections” up which you say this kidnapper went. Now you are trying to hedge and say he went up two.

Mr. Wilentz: No. Counsel does not need to hedge. We will prove that this ladder as I said in my opening was used. We have it in the court room and the defense is hollering about keeping it out, not the State.

Mr. Reilly: That is very unfair.

Mr. Wilentz: No. You say we are hedging. I want to show you there is no hedging, the very ladder and we will show that that was used in the kidnapping and the murder.

The Court: Well, I am inclined to think at this moment that the State should be confined to proof by the witnesses who can speak concerning what sort of an experiment was made, and he may state the result of that experiment subject to the Court’s ruling, and after all that is done, then if there seems to be any necessity for the picture of this experiment, then we will rule on the picture.

Mr. Wilentz: Thank you, sir, and I withdraw the offer.

[408]Q. And, Kelly, tell us then, please, just exactly what you did in this experiment? A. In this experiment, I placed the ladder with two sections, with the lower part of it resting in these two marks that were found.

Q. The marks are the marks referred to in this exhibit that is in evidence, S‑37? A. Yes, sir.

Q. All right. A. And found that after the bottom section was placed in those marks and the top part of the ladder rested against the house.

Q. Yes. A. Upon examination I found that where this ladder, the top section of the ladder rested against the house, that directly over the top two rungs, or the braces on the side, there were two marks about an inch and a half to two and half inches long that could in my opinion be cause—

Mr. Reilly: I object to your opinion.

Q. Not in your opinion, what did they do with them right with the ladder? A. They were right with the ladder; yes, sir.

Q. On the house? A. On the house.

Q. Are you talking about marks on the wall of the house? A. I am talking about marks on the wall of the house; yes, sir.

Q. Yes, sir. What kind of marks were they? A. Ladder marks.

Mr. Reilly: I move to strike that out as calling for a conclusion, unless the ladder in his experiment made the marks.

The Court: I decline to strike it out.

Mr. Reilly: May I have an exception?

[409] The Court: You may have an exception.

(Exception allowed and the same is signed and sealed accordingly.)

(s. s.) THOMAS W. TRENCHARD, Judge.

Q. And, now, did you also make an experiment with three sections, the three sections that you found there? A. Yes, sir.

Q. And what did you find when the ladder with three sections was placed against the building? A. It went up above the window.

Q. And, when it went up above the building, were there any marks on the wall there? A. No, sir.

Q. None at all? A. No, sir.

Q. All right, sir; now, when you got up to this second—with the ladder, the two sections, did you take a look at the shutter? A. Yes, I did.

Q. What kind of material was on the side of this house, what was it built of on the east side? A. stone.

Q. What color was the stone? A. White.

Q. What sort of white was it? A. I would say whitewash, it was painted with a whitewash or white paint.

Q. Were the marks that you speak of, that you saw when you placed the two sections of the ladder up against the house the marks that you referred to before as ladder marks, were they plain? A. Very.

Q. Tell us with reference to color what color it left with reference to the white? A. A scraping mark in the white paint.

Q. Well, having had these scraping marks, did it leave white there or a different color? A. The gray of the stone showed through just a little bit, but the— [410]

Q. The gray? A. The gray of the stone house.

Q. The gray, and when you say gray, that is as distinguished from the rest of the wall, which is white, is that what you mean? A. That is right.

Q. Now, just about what part—

 Mr. Wilentz: Let me have an exhibit, please, ofhave you got a picture of the outside of the house in evidence?

The Reporter: No.

Mr. Hauck: Not in evidence.

Q. Will you come down, please, Mr. Kelly, to Exhibit S‑2, and will you with this pencil mark just about the point with relation to that southeast window that those ladder marks that you say you saw underneath the window—

Mr. Reilly: Now, just a moment, I object to him marking those exhibits. We asked the right to mark an exhibit before and you objected to it.

Mr. Wilentz: No, I objected to tracing all the way around the map, not the marking.

The Court: It was a tracing, Mr. Reilly. It is common enough practice to allow a witness to point out a spot from a map where certain things are justified and material, and they may make a mark there which is different from a tracing, and we do not feel like denying the State the right to make such a mark, nor the defense to make such a mark.

[411]Q. Will you take this pencil—it is a little sharper-just mark an X where you— (Witness marks State Exhibit S‑2 as indicated.)

Q. All right. Will you just return to the stand a minute? Now the X’s you placed underneath the or in the vicinity of the southeast window on the second floor, are intended by you to indicate the point on the wall where you say these ladder marks were, is that so? A. That is right.

Q. I want to show you a picture of what purports to be the Lindbergh home and particularly the east side of it. (Witness-examines picture.)

Mr. Wilentz: Is there any objection to the picture of the home?

Q. Did you take it, Kelly? A. I did.

Q. Sometime around the time of the crime? A. March 2d.

Mr. Wilentz: Just the picture.

Q. What date, do you know? A. March 2d, 1932.

Q. March 2d, 1932.

Mr. Wilentz: I only intended to use it as the picture of the home, gentlemen.

Mr. Reilly: I know, that is the picture of the man’s home, there is no objection to it.

Mr. Wilentz: All right. We offer it in evidence, Exhibit S‑38.

[412] (Photograph was received in evidence and marked Exhibit S‑38.)

Mr. Wilentz: If there is anything else on there we make no use of it.

Q. Now, can you also—I don’t know whether this material is permitted—but can you with a pencil give us your notion of where those marks were, on this picture. A. I could. (Marks on picture.)

Q. Have you got that—Incidentally, that is my pencil, isn’t it? All right. Will you mark it, please, the best you can? Have you marked it, sir? A. Yes, sir; I have.

Q. The X’s then on Exhibit S‑38 are intended to give your idea of the point at which those ladder marks were shown? A. Yes, sir.

Q. And those marks were on there, as I understand it from you, before you put the ladder up? A. Yes, sir.

Q. And when you put the ladder up is it a correct understanding to understand that they fit with the ladder the top section of the ladder? A. Yes, sir.

Q. Exactly? A. Yes, sir.

Q. Now, with reference to that particular top section of the ladder, did you notice whether there were any marks on the top of that ladder? A. When the ladder was brought in to me by Bornmann to be processed for fingerprints, I noticed on the top inside section of No. 2 that rested against the top that we are referring to now there were two white marks.

Q. That is to say then you have these in three sections, as I understand it. This S something for identification, S‑32, you have these various sections? A. Yes.

[413]Q. As I understand it, one section fits in another, isn’t that it? A. Yes, sir.

Q. And you referred to them as 1, 2 and 3, is that it? A. That is right.

Q. I take it that it fits like that (illustrating)? A. Yes, sir.

Q. Then you take the other one and you fit it in, is that it? A. Yes, sir.

Q. So that one section is wider than the other? A. Yes, sir.

Q. Well, that is a common thing with a section ladder, isn’t it? A. A ladder built that way?

Q. A section ladder has that sort of a peculiarity? A. Yes.

Q. That is, one section is wider than the other? A. Yes, sir.

Q. And a section ladder, the wide part, is down on the ground, isn’t that so? A. Yes, sir.

Q. And then as it goes up, the sections become narrower, isn’t that so? A. Yes, sir.

Q. Now I suppose when you took these ladders, these sections for an experiment, you took the wide part and put it in the hole? A. Yes, sir.

Q. And then being connected—

Mr. Reilly: Will you let him testify, please?

Mr. Wilentz: Yes, sir.

Q. Did you connect it with a dowel pin? A. I did.

Q. And the second sections was connected then by dowel pin? A. Yes, sir.

Mr. Reilly: Again I must ask you to let him testify, please.

[414] Mr. Wilentz: All right, sir.

Q. So that when you talk to us about the white marks, where were the white marks, on what section? A. On the top part of No. 2 section.

Q. On the top part of No. 2 section. What sort of white marks were they? A. That is on the side of the house?

Q. On the top of Section No. 2. A. On the top of Section No. 2 they were white marks that could have been made by paint—

Mr. Reilly: I object to that.

Q. Not what they could have been made by what were they, according to your observation? You saw them there? A. I would say paint.

Mr. Reilly: I move to strike out he would say paint.

Q. Is that what you saw?

Mr. Reilly: Wait a minute.

The Court: Just one minute. If it is important I would have to have the question read and the answer read.

(Questions and answers read by the Reporter as follows:

“Q. What sort of white marks were they? A. That is on the side of the house?

“Q. On the top of Section No. 2. A. On the top of Section No. 2 they were white marks that could have been made by paint.

“Mr. Reilly: I object to that.

[415] “Q. Not what they could have been made by—what were they, according to your observation? You saw them there? A. I would say paint.”)

Mr. Reilly: It is merely a conclusion on his part.

The Court: I think I will decline to strike it out.

Mr. Reilly: Exception.

(Exception allowed and the same is signed and sealed accordingly.)

(s. s.) THOMAS W. TRENCHARD, Judge.

Mr. Wilentz: Now, if your Honor please, it is just about the closing hour and it is still quite stuffy here. Would your Honor mind, then, if we could steal these two minutes and adjourn at this time before we go into another subject?

The Court: The Court will ask everybody to remain where they are until the jury has retired. Now, please, do the people in this court room understand English? The jury may retire and may come in tomorrow morning at ten o’clock. The prisoner is remanded to the custody of the Sheriff. We will take a recess until ten o’clock tomorrow morning. The audience may now retire.

(At 4: 30 P. M. an adjournment was taken until tomorrow morning, Tuesday, January 8, 1935, at ten o’clock.)




STATE OF NEW JERSEY

vs.

BRUNO RICHARD HAUPTMANN

Flemington, N. J., January 7, 1935



Present: Hon. Thomas W. Trenchard.

Appearances: Mr. Wilentz, Mr. Lanigan, Mr. Hauck, Mr. Peacock, Mr. Large, for the State.

 Mr. Reilly, Mr. Fisher, Mr. Pope, Mr. Rosecrans, for the Defendant.

(The jury is polled and all jurors answer present.)

Mr. Wilentz: Mr. Kelly, will you please take the stand.

FRANK A. KELLY resumed the stand.

Direct Examination by Mr. Wilentz (continued):

Q. Officer, you remember this nursery room, do you not? A. I do.

[417]Q. I think there has been testimony that somewhere in the center of that room, or somewhere in the room, at least, there was a table and a chair? A. Yes sir.

Q. Was that table approximately in the center of the room, or where was it? A. It was directly in front of the fireplace and the crib; between the fireplace and the crib.

Q. Between the fireplace and the crib. Well, as I understand it there was a southeast window? A. Yes, sir.

Q. A fireplace and a northeast window; is that right? A. Yes, sir.

Q. So that the fireplace would be between the two windows and approximately in the center of the room? A. Yes, sir.

Q. And then in direct line with that, do you mean that there was a table? A. Yes, sir.

Q. And then beyond that a crib? A. Yes, sir.

Q. As you saw the crib, was it against the wall? A. Yes, sir.

Q. So that to the right and to the left of the fireplace there were windows? A. Yes, sir.

Q. What have you to say as to whether or not the table was in direct line between the southeast window and the crib? A. That is, between the window and the crib?

Q. Yes; what have you to say as to the course from the southeast window to the crib? A. You could have walked a direct line from the window to the crib with no obstruction.

Q. That is to say that the table was not an obstruction in that course. A. No, sir.

Q. I see. Now while this experiment was made with the ladder which has been referred to in this case as Exhibit S‑32 for identification there was another ladder used, was there? A. Yes, sir.

[418]Q. What ladder was that? A. It was an extension ladder that was in the garage of Colonel Lindbergh at the home.

Q. It was the Colonel’s ladder, is that what you mean? A. Yes, sir.

Q. And just one other question. Did you measure the indentations in the ground, the impressions in the ground which you and others have referred to as the holes or impressions made by the ladder? A. No, sir, I didn’t measure it.

Q. Did you take a photograph of the paint—I think you said there was paint or white-wash that was on top of the second rung of the ladder. A. No, sir, I did not.

Q. Why not? A. In the process of testing the ladder for fingerprints that dusted off.

Q. As I understand yesterday, you stated in taking, attempting to take fingerprints in that baby’s nursery, that you found none? A. That is correct.

Q. You have been in court for several days, have you not? A. Yes, sir.

Q. You heard Mrs. Lindbergh’s testimony and Miss Gow’s that they had been in the room? A. Yes, sir.

Q. You mean then that you found no fingerprints of anybody’s? A. I mean this.

Q. Just answer the question. A. No, sir; nobody’s at all.

Q. Nobody’s at all? A. No, sir.

Mr. Wilentz: Mr. Reilly, take the witness.

Cross-Examination by Mr. Reilly:

Q. Mr. Kelly, how much experience have you had in taking fingerprints? A. Six years.

Q. Where did you study? A. While I have been in the department.

[419]Q. Under whom did you study? A. I studied this under Sergeant Jastrom, and I studied myself in various books that I have picked up.

Q. Did you ever study the Bertillon system? A. No, sir, I did not.

Q. And, are you the, what is known as the expert of the Police Department, the State Police? A. No, sir, I am not.

Q. Well, who takes the Bertillon measurements? A. It is not used, it is obsolete.

Mr. Reilly: I move the latter part be stricken out as a conclusion, “It is obsolete.”

The Court: Strike it out.

Q. The Bertillon system is a system of measuring by height, breadth and general dimensions, is that correct? A. That is.

Q. Yes, it has been used for over 100 years in foreign countries and in America, hasn’t it? A. I couldn’t say.

Q. Did you ever study under the late Inspector Farout of New York, the late fingerprint expert? A. I did not.

Q. Did you bring with you the paraphernalia this morning for taking fingerprints? A. No, sir, I did not.

Mr. Reilly: I understood from the table here, the prosecution would have them this morning.

Mr. Wilentz: Well, if counsel wants them I will certainly get them for him sometime today.

Mr. Reilly: All right.

[420]Q. Do you think you would be able to take fingerprints and give the jury an observation? A. I would.

Q. Yes. Now you want us to believe, do you, that although Mrs. Lindbergh had been in the nursery that evening, Miss Gow had been over to the medicine cabinet and the medicine table and given the child, I believe, cough mixture and had rubbed the child’s chest with a jar of Vicks and had been around the medicine table, shown in the State’s exhibit S‑9, you could find no fingerprints? A. Of value.

Q. Of anybody you testified here, of anybody; is that correct? A. That is correct.

Q. Yes. Now you know, do you not, that there are no two fingerprints in the world alike. A. Yes, sir.

Q. That we each have our own individual photograph on our fingerprints. A. Yes, sir.

Q. Does that also apply to the feet? A. Yes, sir.

Q. Now, when you arrived at this house I think you said it was around eleven o’clock. A. No, sir.

Q. How late? A. Five minutes after twelve in the morning of March 2nd.

Q. Five minutes after twelve. I see. And who did you see in the nursery? A. When I went to the nursery it was empty.

Q. Did anybody accompany you to the nursery? A. They did.

Q. Who? A. Colonel Lindbergh and Corporal Wolf.

Q. Was the nursery lighted or was it in darkness? A. As I recall, it was lighted.

Q. What was the first object you attempted to photograph or take fingerprints from? A. The note.

[421]Q. Now, when you received the note it was in the envelope? A. That’s right.

Q. Was it sealed? A. Yes.

Q. And how did you open the envelope? A. With a fingernail file.

Q. Now, what did you do to this envelope to try and find fingerprints from it? A. I at that time used a camel hair brush that is used by fingerprint operators and a black powder which is manufactured by Flaacke, standard fingerprint powder, dusted the surface of the note with the powder and the brush.

Q. First you take the powder and sift it on, don’t you? A. First I dip my brush into the bottle and sift the powder on and then brush over the surface of it.

Q. Very lightly? A. Yes, sir.

Q. Is it not the proper way to take a fingerprint to sift the powder from the bottle over the paper and then blow it off and the powder remains where the fingerprints are? A. No, sir, it is not.

Q. Do you not know that the brushing of your brush destroys the fingerprints? A. I know in blowing it off you blow moisture on it and destroy the fingerprint.

Q. You see me handle this paper? A. Yes, sir.

Q. And counsel at the table are going to handle it now. We are going to leave it right here with the clerk until you bring your apparatus. That is what you did with the note, too, I assume, you brushed it with the brush? A. That is correct.

Q. Dipped in the powder? A. Yes, sir.

Q. Did it leave any marks at all? A. It did not.

Q. Was anybody present when you tried to take the fingerprints? A. Yes, sir.

Q. Who? A. Colonel Lindbergh.

Q. Anybody from the department that knew any- [422] thing about fingerprinting? A. It depends on what you mean, Mr. Reilly, knowing anything about fingerprints.

Q. Any police officer? A. Police officers, yes, sir.

Q. Do they generally know anything about fingerprints? A. They know a fingerprint when they see one.

Q. Do they know how to take one? A. I don’t know. I couldn’t answer that question.

Q. How long were you working on the note before you gave it up as hopeless as far as fingerprints went? A. Possibly about half an hour.

Q. Always in the nursery? A. Yes, sir.

Q. Then what did you do with the note? A. I kept it on my person until the arrival of my troop commander and turned it over to him.

Q. After the note, what was the next place? A. The nursery.

Q. That you went to try and get some fingerprints? A. The nursery.

Q. You were in the nursery? A. That is correct.

Q. With the note? A. Yes, sir.

Q. Now you are through with the note? A. Right.

Q. Where did you go then to try and get fingerprints? A. I believe my next attempt was the window, and the window sill.

Q. Now the windowwhat part of the window did you look for fingerprints? A. All of it.

Q. When you arrived at the window, you found the window closed, is that correct? A. That is correct.

Q. Did you find the latch opened or closed? A. Open.

Q. Did you do anything to the latch? A. Processed it for fingerprints.

Q. You found none on it? A. No sir.

[423]Q. Did you take the bottom of the window and process it for fingerprints, this sash? A. Do you mean inside the bottom window?

Q. Inside and outside. A. Yes, I did.

Q. Did you take this upper part of the window that you would have to shove up with the finger? A. The frame that holds it to it?

Q. Yes. A. I did.

Q. The outside? A. Yes.

Q. You found no fingerprints? A. Yes.

Q. What was the condition of the inside of the window? Did you try to get fingerprints from that? A. I did.

Q. Couldn’t get any? A. No, sir.

Q. Finally you got over to the crib, didn’t you? A. I did.

Q. Now, did you hear Miss Gow testify that she came into the crib and she leaned over the crib, she couldn’t hear the child breathing, and that she started to feel among the coverlets? Did you hear her testify to that yesterday? A. Yes, sir.

Q. And leaning over the crib—did you try to get Miss Gow’s fingerprints or anybody’s fingerprints off the edge of the crib? A. I tried to get any print that was in that room.

Q. Well, you heard Miss Gow testify that at least an hour before, or two hours before, maybe three hours before you arrived, she had been at that crib and leaning over it and handling it: is that correct? A. That is correct.

Q. And you want us to believe that you couldn’t even get her fingerprints from that crib where she was looking for the baby? A. If she leaned over.

Q. She touched the crib and she leaned in the crib and she looked for the baby and she felt the crib, all around the crib. You say there were no fingerprints of hers? A. Exactly.

Q. Nobody’s? A. No, sir.

[424]Q. And a fingerprint in your opinion will last how many days, if any? A. It depends on atmospheric conditions, general conditions in the room or outside conditions.

Q. What atmospheric conditions in the nursery room would cause any fingerprint to disappear within two days? A. I didn’t say it was atmospheric conditions that caused it.

Q. What condition of any kind that you could imagine and know of could cause a fingerprint to disappear in that nursery room within two days? A. General handling conditions.

Q. If anyone went near the crib wouldn’t the fingerprint remain there for at least two days? A. No, I wouldn’t say it would.

Q. Would it remain there one day? A. I wouldn’t say it would.

Q. Would it remain there twelve hours? A. I wouldn’t say it would last five minutes.

Q. What authority did you ever study for fingerprinting? A. I studied the Henry System.

Q. Who was Henry, the Chief of Police in Canada that wrote the book? A. No, sir, I do not know that.

Q. Well, who is Henry? A. He is the man that the Henry System of classification of fingerprints and I studied that.

Q. Where did he come from, what city? A. I believe he came from England.

Q. When was the book written? A. I do not know.

Q. When did you study it last? A. For the past six years. I go over it occasionally.

Q. When did you see it last? A. About two months ago.

Q. And a man named Henry in England wrote a book? A. As far as I recall.

[425]Q. As far as you recall. You have never studied any American system at all, have you? A. That is the American system that has been used by police departments in the United States.

Q. Don’t you know the system used in the United States is a system devised by ex-Inspector Forrot of the Police Department of New York? A. No, I didn’t.

Q. You didn’t know that he was in charge of the New York Police Department on fingerprinting for twenty-five years. A. I don’t know what New York does. I am in Jersey.

Q. You didn’t know he gave lectures to all the fingerprint men in the United States at least once a month? A. I never heard tell of the man.

Q. You never heard tell of the man. Have you any authority in Jersey that you can rely upon as a fingerprint expert? A. What do you mean?

Q. Anybody that ever wrote a book, anybody that ever gave a lecture on fingerprinting in this state that you attended? A. We have men in our department that give lectures on fingerprinting.

Q. Who are they? A. Lieutenant Jostron gives lectures on fingerprinting.

Q. How long has he been giving lectures? A. As long as I have known him.

Q. Did you study under him? A. I did.

Q. You did, correct, did you study under him? A. Pardon?

Q. Did you study under him? A. Yes.

Q. Now, what has been your experience in preserving footprints? A. Will you be more definite on that, please?

Q. Yes. Assuming that a man stepped into a muddy hole and left behind him a footprint as has been photographed here. Outside of photography how would you preserve the footprint? A. How would I preserve it?

[426]Q. Yes. A. If I was the only investigator, I would preserve it by measuring it, making a mold of it.

Q. Well, what would prevent you in an important case like this of not measuring it? A. If it had been done by somebody else.

Q. Who measured it, so far as you know? A. I believe Detective DeGaetano did.

Q. Before you arrived? A. Yes, sir.

Q. Did you check up on his measurements? A. No, sir, I did not.

Q. Did he take a mold of it? A. I couldn’t say.

Q. Did you ask him? A. No, sir.

Q. Did you check up on it? A. No, sir.

Q. Did you take a mold? A. No, sir.

Q. Now, as to the ladder, do you know it has been reported that one man took over 8oo fingerprints from this ladder?

Mr. Wilentz: I object to the question, if your Honor please. I think

Mr. Reilly: All right, I am ahead of myself. I will withdraw it.

 The Court: All right.

Q. Did you get any fingerprints from the ladder? A. No, sir, I did not.

Q. How soon after you were finished with the ladder was it examined by Government men? A. Do you mean a police conference, Mr. Reilly?

Q. No, I will put it this way: I don’t want to do anything to confuse you. The ladder was brought into the Lindbergh home in two sections, correct? A. The first two sections.

[427]Q. Yes, the first two sections were brought in and later on a third section brought in: am I correct about that? A. That is correct.

Q. The first two sections that were brought in were joined together and were not joined together, half and half? A. That is right.

Q. They were loosely joined, I will put it that way; is that correct? A. Correct.

Q. Yes. And where was it put, the first portion of the ladder, when it was brought in? Left in the library or somewhere? A. I received the ladder in the hallway.

Q. Hallway. You had finished, had you, with your experiments up in the nursery? A. Oh, no.

Q. Hadn’t started them yet? A. I had started them.

Q. All right. Then what did you do with the ladder when you finally determined you should look for fingerprints? A. What did I do with it?

Q. Take it to some room and examine it? A. I worked on it right there in the hall.

Q. Right in the hall. That is what I want to know. And you went over all three sections? A. I did.

Q. What condition was the ladder in? Was it dry or wet? A. It was dry.

Q. Wasn’t it covered with frost? A. No, sir.

Q. No moisture on it at all? A. No, sir.

Q. Sure about that? A. Yes, sir.

0. Cold night, wasn’t it? A. Yes, sir.

Q. There wasn’t any moisture on it at all? A. No, sir.

Q. Is that right? A. That is right.

Q. You looked the ladder all over carefully? A. Yes, sir.

Q. It was dry, the entire three sections? A. Yes. sir.

[428]Q. Well now, I want to know a little more about this section ladder from the Colonel’s garage. That was a section ladder too, was it not? A. That was an extension ladder.

Q. That was an extension ladder. What do you mean by that? A. I mean a ladder that is wider at the bottom and it has a pulley effect with a rope on it that you can pull the top section up.

Q. Something like the ladders they used to prune trees with, it has a rope on it? A. It has.

Q. And you can pull it up? A. Yes.

Q. And it clicks as it goes up with a catch? A. Yes. on the side, yes.

0. How high was that ladder when it was pulled to its full length? A. I don’t know. I don’t believe it was pulled to its full length.

Q. Did you not try? A. Not to its full length, no, sir.

Q. Why not? A. There was no necessity for it.

Q. You were there to investigate something, were you not? A. Yes, sir.

Q. You never saw any ladder up against the Colonel’s window, did you? A. No, sir.

Q. You were in possession of two ladders, correct? A. I was in possession of three sections of one ladder, one complete ladder.

Q. And you were in possession of another ladder, the extension ladder? A. That is right.

Q. What I want to know and the jury wants to know is how high the extension ladder would go if you pulled the string? A. I suppose if you pull it all the way

Q. Not suppose—don’t you know? A. No, I do not.

Q. Where is that ladder? A. The last time I saw it, it was in Colonel Lindbergh’s home in Hopewell.

[429]Q. How long ago? A. That was last June, I believe, was the last time I was there.

Q. Yet with all your investigation, you mean to tell us, and that is what you were there for, that you never pulled that string to see how high the extension ladder would go? A. There was no need for it.

Q. I did not ask you if there was any need for it. I ask you if you did it. A. No.

Q. The jury will pass on the need for it. Now, did you see Colonel Lindbergh’s garage that evening and do you agree with him that the garage was always open?

Mr. Wilentz: Of course, the witness would not know that.

Q. Did you go to the garage and see the doors open? A. No.

Q. Who brought you or directed your attention to Colonel Lindbergh’s ladder—I will withdraw that. I don’t want to put Colonel Lindbergh in this at all. The ladder belonging to the Lindbergh home. A. Repeat the question, please.

Q. The ladder belonging to the Lindbergh home? A. Will you repeat the question, please.

Q. Who directed your attention to the ladder belonging to the Lindbergh home? A. I believe, as I recall it, I asked about a ladder, I asked Ollie Whateley, and he told me there was a ladder in the garage.

Q. He was the butler? A. Yes, sir.

Q. He was the man whose word you took that he—you didn’t, it was some other officer. The ladder was brought in to you or did you go up to the garage? A. I went to the garage.

Q. When? A. As soon as I asked about it.

Q. Well, when—I don’t know when that was, that day, or the next day, or when? A. That day.

[430]Q. That day. I suppose you stayed right on the job, did you, right through until about noon the next day: is that right? A. Oh, no. I didn’t leave the premises; I was right there.

Q. Until how long? A. Until June.

Q. Couple of days—You lived right on the premises, did you? A. Yes, I did.

Q. Well, sometime the next day you asked about a ladder and the butler told you there was one in the garage: is that correct? A. That is right.

Q. What did you do about sifting that for fingerprints? A. Sifting what for fingerprints?

Q. The ladder in the garage. A. What do you mean, sifting the ladder, Mr. Reilly?

Q. Well, I mean trying to process it, as you call it. A. I didn’t do anything about it.

Q. You never even looked at that ladder or gave it a processing to see if there was any fingerprint on it: is that right? A. That is right.

Q. You just took it for granted that this makeshift affair they brought in was the ladder somebody might have put up against the house: is that correct? A. I took it for granted for what?

Q. This makeshift ladder was the ladder that was put up against the house, if any ladder was put up against the house: is that correct? A. That is correct.

Q. Now, you knew, did you not, that you were there for the purpose of preserving the evidence for any trial that might ever come up: is that correct? A. Correct.

The Court: Mr. Reilly, just excuse me one moment. I am sorry, but I am very sensitive to drafts and I am feeling a draft from that window. Thank you very much.

Q. Now are you the photographer, too? A. I [431] work at that, yes.

Q. Did you photograph the foot print? A. I did.

Q. Was that photographed at night? A. Daytime.

Q. Daytime? What time? Noon time? A. The following morning around eight o’clock or so.

Q. Did you photograph the outside, this other picture? A. What other picture?

Mr. Hauck: They are all here, Mr. Reilly; all the photographs (indicating).

Mr. Reilly: Thank you.

Q. This one that shows the bush; did you photograph that, Exhibit S‑35 (showing the witness)? A. Yes, sir.

Q. Well, now is this, snow? A. No, it is not.

Q. What is it, mud? A. Mud.

Q. Then the white portion of the photograph indicates mud? A. Indicates the earth there.

Q. Yes. Well, was it soft, mushy? A. In some parts.

Q. Frozen in others? A. Yes, sir.

Q. And this footprint (showing another photograph to the witness) was that more or less frozen in this photograph in the mud the next day? A. No, sir.

Q. It hadn’t been disturbed? A. No, sir.

Q. There had been a State Trooper put there to protect it, hadn’t there? A. That is right.

Mr. Reilly: With the understanding that this witness is to be recalled when he comes back with his paraphernalia, I am through for the present.

STATE vs. HAUPTMANN

January 8, 1935

[479] FRANK A. KELLY, recalled:

Direct Examination by Mr. Wilentz: [480]Q. Mr. Kelly, do you know who sawed this section, referring to the section that is fixed together by a white board, on Section i of the ladder, which is marked S-32 for identification? A. No, sir, I do not.

Q. Were you present when it was done? A. No, sir.

Mr. Wilentz: All right, sir, that is all.

(Witness excused.)

The Court: He says that he does or does not know?

Mr. Wilentz: He does not.

STATE OF NEW JERSEY



vs.

BRUNO RICHARD HAUPTMANN

January 23, 1935

[2125] Present: Hon. Thomas W. Trenchard.

Appearances: Mr. Wilentz, Mr. Lanigan, Mr. Hauck, Mr. Peacock, Mr. Large, for the State.

Mr. Reilly, Mr. Fisher, Mr. Pope, Mr. Rosecrans, for the Defendant.

(The jury was polled and all jurors answered present.)

Mr. Wilentz: My recollection, if your Honor please, is that there is another reserve witness for cross examination with reference to fingerprint work; I think it was reserved by Mr. Reilly and, if Mr. Kelly is here, I suggest that we proceed now with that phase of the case.

Mr. Reilly: That is agreeable.

[2126] FRANK A. KELLY, recalled for cross examination, testified as follows:

Cross Examination by Mr. Reilly: Q. I think when you left the stand you were to go and get some paraphernalia for taking fingerprints; is that right? A. That is correct, yes.

Q. Now, this piece of paper has been handled by counsel for the defense, two or three of them, and has been in the possession of the Clerk ever since you took this witness stand and left the witness stand. Will you take this and show the jury how you attempt to locate fingerprints. A. Yes, sir. Would you mind placing it there, Mr. Reilly?

Q. Sure; I will place it any place. A. (The witness leaves the stand.)

Q. Couldn’t you do it up there, Mr. Kelly, in front of the Judge and jury? A. I believe so.

Q. Yes. A. Just set it there.

Mr. Wilentz: As I understand it, a statement has been made by counsel that this paper has been in the possession of the Clerk.

Mr. Reilly: The Clerk here (Mr. Fell).

Mr. Wilentz: And not in the possession of anybody else?

Mr. Reilly: No.

Mr. Wilentz: No identification mark on it at all.

[2127] Mr. Reilly: No.

Clerk Fell: There is no identification by the Clerk.

Mr. Wilentz: I had hoped and had been under the impression that it was marked for identification but we will make no point of it. You may proceed, Mr. Kelly. May I suggest too, while we are at it, that my understanding of Mr. Kelly’s testimony was that prior to the date of this kidnaping and crime there was one form of test that he made and thereafter some new process came along. I take it that counsel wants the old process.

Mr. Reilly: The old process.

Mr. Wilentz: All right; we want the old process.

(The witness proceeded with his demonstration.)

By Mr. Reilly: Q. Mr. Kelly, on the half that you brushed over have you found some prints? A. On the half I have brushed over I have found some ridge formations from the finger, but I would say that they are prints of no value.

Q. All right. Will you sift the others. A. (The witness demonstrated.)

Q. You don’t have to do any more, Mr. Kelly. [2128] May I have the paper. A. (Paper handed to counsel.)

Q. Mr. Kelly, this is the paper that you brushed over; is that correct? A. Yes, sir.

Mr. Reilly: I ask to have it marked for identification.

(The paper referred to was marked Defendant’s Exhibit D‑37 for Identification.)

Q. Now, Mr. Kelly, as I indicate to you on this paper, this mark here indicates where a finger held this paper? A. Yes, sir.

Q. That is the upper right hand corner. Now, these two marks here at the bottom of the paper indicate where it was held by a finger? A. Where  a finger came in contact with it.

Q. That is right. And that shows certain ridges, does it not? A. Yes, sir; but they are of no value.

Mr. Reilly: Well, I move that that be stricken out, as voluntary, that they are of no value. We will find out if they are of any value in our examination.

 The Court: Yes. It does not seem to be responsive. It will be stricken out, “they are of no value.”

By Mr. Reilly: Q. Now, assuming, Mr. Kelly, that this paper, Defendant’s Exhibit D‑37 for Identification, was handled by at least four of defense counsel without gloves the day that you were last on the witness stand and placed in the possession of the [2129] Clerk of this court until this morning: you say that this is all of the fingerprints or indications that you can obtain from it, is that right? A. Yes, sir.

Q. Now, Mr. Kelly, is it not a fact that the human hand is constantly throwing off a secretion or grease? Is that correct? A. That is right.

Q. And it is that secretion or grease which clings to anything the hand touches? A. That is right.

Q. Such as paper, wood, glass, metal: correct? A. Correct.

Q. And is it not true that each individual—Put it this way: there are no two individuals in the world that have the same fingerprints; is that correct? A. Correct.

Q. We are each individually marked? A. That is right.

Q. Now, am I correct in saying that on the evening that you were called to Colonel Lindbergh’s home this ransom note was shown to you in an envelope? A. That is right.

Q. It had not yet been taken out of the envelope? A. No, sir.

Q. And you dusted it the same as you did here? A. Yes, sir.

Q. And you found no fingerprints on it? A. Yes, sir.

Q. Correct? A. Right.

Q. Now, did you dust the window sill? A. Yes, sir.

Q. Did you dust it completely? A. Yes, sir.

Q. Mr. Kelly, what would remove fingerprints, a handkerchief, cloth, or what kind of a piece of material would remove fingerprints in your opinion? A. Any foreign object that touched it, rubbed it, would remove the fingerprint.

Q. Well now, if that window sill had been gone  [2130] over with a cloth or a wash rag or a Turkish towel, it would remove any fingerprints that were on it, is that right? A. Yes, sir.

Q. So that if the window was opened from the outside and lifted up and fingerprints were on it which were rubbed over with a towel before you arrived in your opinion they would be removed,  is that correct? A. Yes, sir.

Q. Now I understood you to say that you found no fingerprints on the window. A. No fingerprints of value on the window.

Q. Did you find any? A. I found marks.

Q. Well, now, what do you mean “of value?” A. I mean that where there is complete ridge formation enough to make identification of value.

Q. How much ridge formation do you require to make an identification? A. About five points  of identification.

Q. What does that mean? A. Various parts of the fingerprint, the core, the delta, ridge terminations, bifurcations.

Q. Well now, we will start with the thumb, the center of the thumb, you have what, the core? A. The core.

Q. From which all the ridges radiate? A. Yes, sir.

Q. You mean to tell me you cannot compare my  fingerprint if taken from the edge of my thumb with my fingerprint as a standard? A. I didn’t say that, Mr. Reilly. I said five points of identification.

Q. Isn’t it a fact that you can compare my fingerprint taken from the ridge or any portion of my thumb if you had at least two ridges? A. It would be hard to do.

Q. Did you ever try it? A. Yes, sir.

Q. Where did you study fingerprinting? A. [2131] I studied while I was in the Department. I have already answered that question.

Q. Now, did you find more than two ridges in the fingerprints? A. No, sir; I did not.

Q. Did you find any whorls? A. No, sir; I did not.

Q. It has been testified here by both Mrs. Lindbergh and Betty Gow that they both attempted to  close the shutters of the nursery window but, due to a warping of the shutters, they were unable to close them; that after pulling the shutters in as far as they would go on this nursery window, then either one of them or both of them closed that window. Now, did you find on that window that night the fingerprints of either Mrs. Lindbergh or Betty Gow? A. No, I did not.

Q. It has been testified to here that Betty Gow was at the crib, she put the child to bed, she  pinned the child in, she leaned over the crib and went through the usual custom of putting the child to bed. Did you find any fingerprints of Betty Gow on the crib? A. I found hand marks on the crib.

Q. Did you compare them with the Betty Gow fingerprints? A. They couldn’t be compared, they were of no value.

Q. There weren’t enough rings? A. They were of no value. The greasy formation on the side  of the crib was constantly handled.

Q. How many did you take from it? A. I didn’t take any from it.

Q. Didn’t take any. Then you found no fingerprints of value, as you claim? A. On examination of the crib I noticed that there was a grease formation there; in processing it, I smelled it and it smelled like Vick’s. I attributed that to either Betty Gow’s or Mrs. Lindbergh’s hand from rubbing the baby’s chest with Vick’s.

[2132]Q. You would hardly find that in the fingerprint. That might have been a smudge from the hand. A. I don’t understand you, Mr. Reilly.

Q. What you found on the crib was a greasy area? A. Yes.

Q. It might have been a smudge from a greasy hand, palm of the hand? A. It could have been the palm of the hand or it could have been fingers.

Q. What comparison of the ridges did you make? A. When you have no ridges you can’t make a comparison. I have told you that.

Q. Did you have a standard of Mrs. Lindbergh’s fingerprint? A. I have took Mrs. Lindbergh’s fingerprints.

Q. And you had Betty Gow’s? A. That is right; yes, sir.

Q. Where did you make your examination? A. There was no examination to make, because the prints on the crib were of no value.

Q. Did you photograph them? A. No.

Q. In your opinion they were of no value? A. That is right.

Q. Did you call anybody in to look at them? A. It wasn’t necessary.

Q. Did you call anybody in to look at them? A. It wasn’t necessary.

Q. Well now, when did you first go to Dr. Hudson? A. I first met Dr. Hudson at Colonel Lindbergh’s. I don’t know when I first went there.

Q. Did you go to Colonel—to Dr. Hudson’s office and laboratory in New York before he came to Colonel Lindbergh’s? A. No, I did not.

Q. Well, you had been there many times since? A. Oh, yes.

Q. And where—when did you meet Dr. Hudson at Colonel Lindbergh’s? A. Around the 12th or 14th of March, 1932, I think.

[2133]Q. And he came there in relation to the ladder? A. He came there in relation to fingerprints.

Q. Fingerprints. Now, did you see Dr. Hudson fingerprint the ladder? A. I saw him demonstrate on a rail of the ladder.

Q. Well, did you see him demonstrate with a piece of board? A. I don’t recall that, Mr. Reilly, no, sir.

Q. Well now, what in your opinion—withdrawn. A man handling a piece of board, does the secretion of his hand remain on the board? A. Yes.

Q. And it soaks into the board, doesn’t it? A. That is right.

Q. So that although you may take this piece that you have given here on the board and show no fingerprints, there is another process, is there not, which will bring out the fingerprints if they are there? A. If the board has not been constantly handled, yes, sir.

Q. Well, this ladder had been constantly handled, hadn’t it? A. Yes, sir.

Q. And did you dust the ladder for fingerprints? A. On—?

Q. At any time, before Mr. Hudson had it, or Dr. Hudson had it. A. Did I dust it?

Q. Yes. A. Oh, yes, I dusted it.

Q. Did you get any fingerprints from it? A. No, sir, I did not.

Q. No. Did you see Dr. Hudson make a test on the ladder? A. I saw him demonstrate the use of a process on the rail of the ladder.

Q. All right. Tell us about it. A. I just did.

Q. Well, what was the process? A. He used a silver nitrate, sprayed it on the rail of the ladder.

Q. He sprayed the ladder with silver nitrate? A. Not the ladder; a rail of the ladder.

Q. A rail; all right. A rail. Which rail? A. I don’t recall.

[2134]Q. Will you point it out on the ladder? A. I don’t recall; one of the side rails.

Q. One of the side rails. There are only two. A. Oh, no; there are six there.

Q. Well, there are two on each section. A. That is right.

Q. Do you know which section he sprayed?  A. No, sir, I do not.

Q. You can’t tell by looking at it from the color of the wood? A. No, sir.

Q. Didn’t the silver nitrate discolor the wood? A. I believe it did.

Q. Didn’t it discolor it more or less like this piece of wood I show you here? A. Similar to that.

Mr. Reilly: I offer this piece of wood  in evidence.

Mr. Wilentz: No objection.

Mr. Reilly: Or, rather, for identification.

Mr. Wilentz: No objection.

The Court: It may be marked.

 The Reporter: D‑38 for Identification.

(Piece of wood marked D‑38 for Identification.)

Q. Now, is it a fact that you can take a piece of wood that has been handled by a person and you can dust it with your powder and find no finger prints? Is that correct? A. Yes, sir.

Q. And then you can even rub the wood with cloth to clean it, and then apply silver nitrate and [2135] bring out the fingerprints? A. In some cases.

Q. How many times have you tried it? A. Oh, I don’t know. I have experimented with silver nitrate ever since I first learned about it.

Q. Yes. Did you see Dr. Hudson take from this side rail of the ladder and from the ladder itself between 800 and a thousand fingerprints? A. On one rail, Mr. Reilly?

Q. No. On the whole ladder. A. No. Dr. Hudson had nothing to do with the whole ladder.

Q. Well, how many fingerprints did Dr. Hudson take from the rail of the ladder that he tested? A. I do not know. I saw some markings come out on there but I don’t know how many prints came out.

Q. Well, look at this board I have offered for identification. Are those fingerprints? A. Yes, sir.

Q. Have you any silver nitrate here? A. Yes, sir.

Q. Will you take my fingerprint off this board in front of the jury, please? A. If it is on there I will try to.

Q. All right. I will put it on there now for you. I am handing a board—I am handing the board to you. Now, will you please take it out with silver nitrate? A. It has been found, Mr. Reilly, with the silver nitrate method on a piece  of wood—

Q. I ask you to take it out, please, not how it has been found.

The Witness: Will the Court allow me to explain?

The Court: Yes.

A. It has been found that with the silver nitrate  [2136] method on wood, better results are obtained after the prints are on there for a while.

Q. How long do you want my prints to stay on there? A. Why, I could try your print on here with powder and possibly bring it out.

Q. I want it with silver nitrate. Twenty-four hours, forty-eight hours? A. Oh, I should say  overnight would be all right.

Q. All right. How many days after the ladder was found did Dr. Hudson bring out with silver nitrate these fingerprints? A. Dr. Hudson first demonstrated somewhere around the 12th or the 14th of March, I believe.

Q. All right. That would be 12 or 14 days afterward, wouldn’t it? A. Yes, sir.

Q. Now suppose I put the board away. A. By the edges, please.

Q. And don’t touch it again for two or three days and call you during the defense, will you bring it out then with silver nitrate? A. I will try to bring out what is on there.

Mr. Wilentz: Suppose you leave it with the witness. Then there won’t be any question about it.

Mr. Reilly: ’ No, I am going to leave it with the Clerk, if you don’t mind.

Mr. Wilentz: I take it that the clerk will have to apply his fingers to it.

Mr. Reilly: Is it all right to wrap it in paper?

The Witness: I would suggest leaving it as it is and handling it by the edges.

[2137] Mr. Reilly: All right.

By Mr. Reilly: Q. Now, the silver nitrate that was applied to the ladder—were you ever asked to wash those stains off? A. I was detailed to take the stains off, yes, sir.

Q. Did you take them off? A. No, sir, I didn’t.

Q. They were taken off, weren’t they? A. I believe they were.

Q. And they were taken off with a solution of bichloride of mercury? A. I believe so.

Q. Yes.

Mr. Wilentz: I expect to use that, Mr. Reilly, if you don’t mind.

Mr. Reilly: All right.

Mr. Wilentz: I just want you to know that.

Q. How many times would you say after this ladder was first shown to you did you talk to Dr. Hudson about the fingerprints either found or not found on the ladder? A. I don’t believe at any time I ever discussed fingerprints on that  particular ladder with Dr. Hudson. I had discussed the silver nitrate method of obtaining fingerprints and experimenting purposes on wood with Dr. Hudson.

Q. Where? A. At his office in New York.

Q. Where is it? A. Dr. Hudson, I believe, lived on—he had moved—I don’t recall his address.

Q. East 80’s, isn’t he? A. Pardon me?

Q. East 80’s, somewhere in a Doctor’s building, isn’t that where you went to his office? A. I [2138] went to his home when he lived over on—near Seventh Avenue, I think it was, somewhere around there.

Q. That was after he had been down here to Hopewell? A. Yes, sir.

Q. Did you see photographs of Dr. Hudson’s experiments on the ladder taken? A. No, sir; I did not.

Q. Do you know if there are any photographs of Dr. Hudson’s experiments on that ladder in existence? A. No, I do not.

Q. Well, who was there, if you know, when Dr. Hudson was experimenting on the ladder? A. Dr. Hudson demonstrated the use of the silver nitrate on the one rail of the ladder and the rest of the ladder was completed by Sergeant Kubler.

Q. I asked you who was present? A. I am tell ing you Sergeant Kubler.

Q. And you were not present? A. I was there; yes, sir.

Q. Were there any photographs taken in your presence? A. No, sir.

Q. Have you ever seen any photographs that were taken from it? A. No, sir.

Mr. Reilly: I think that is all.

 Re-Direct Examination by Mr. Wilentz: Q. As I understand it, Mr. Kelly, you are going to make a test of this board which is D‑something for identification, D‑38, for counsel; is that correct? A. Yes, sir.

Mr. Wilentz: Is that our understanding?

Mr. Reilly: Yes.

[2139]Q. While you are making that test, will you also make a test of D‑37 for identification, this paper, on the opposite side? A. Yes, sir.

Q. You have made it on only one side? A. Yes, sir.

Q. Is it possible or probable that there may be fingerprints on the other side? A. Yes, sir.

Q. I notice that this board is discolored? A.  Yes, sir.

Q. Am I correct in assuming that it is discolored because of the efforts to take fingerprints? A. Yes, sir.

Q. So did the efforts to take fingerprints on the ladder which is in evidence as S‑211, the processing, cause a discoloration? A. Yes, sir.

Q. Of some parts of the ladder? A. Yes, sir.

Q. Would the efforts to take these fingerprints, the tests that are made, would they discolor it and make it blacker, darker? A. Yes, sir.

Q. Counsel has asked you about some Dr. Hudson who came on the 12th, I think you said, or a little later and took some test fingerprints of this ladder? A. Yes, sir.

Q. Tell me whether or not between the 1st of March and the 12th or the 14th of March, a new process had not been discovered? A. It had.

Q. What was the new process? A. The silver nitrate process.

Q. So that when you first took the test of this ladder, the silver nitrate process, as I understand it, had not yet been discovered? A. It was not known, no, sir.

Q. And between the time of the discovery of the silver nitrate process and the time you took the test on this ladder, that is to say on the 1st or early in the morning of the 2nd of March, had there been many hands touching and handling that ladder? A. Oh, yes, very many.

[2140]Q. As a matter of fact, a great number of police officers from all over the country and others had handled the ladder at that time? A. Yes, sir, that is correct.

Q. And when Dr. Hudson made his test, do you know how many hands did handle that ladder? A. No, sir, I do not.

Q. How many touched it? A. No, sir.

Q. You don’t know whether a great number or just a few? A. A very great number.

Q. A very great number. I suppose that if I took this ladder, each section, and attempted to examine it and handle it all by myself for ten or fifteen minutes, I suppose I might leave a great number of fingerprints, isn’t that so? A. Yes, sir.

Q. That is, one person might leave different  sets? A. That is right.

By Mr. Wilentz: Q. If a man carried this ladder to the Lindbergh home and he carried it with gloves and he didn’t take the gloves off, would he leave his fingerprints on it? A. Absolutely not.

Q. If a man walked into the Lindbergh nursery and took that child and he had gloves on—

Mr. Reilly: I object.

Q. –would he leave fingerprints?

Mr. Reilly: Wait a minute. I object to this. It. is a hypothetical question not based on the evidence. There is no evidence anybody carried a ladder to the Lindbergh home without gloves.

[2141] Mr. Wilentz: We disagree with that, if your Honor please.

Mr. Reilly: Of with gloves; either with or without.

Mr. Wilentz: Mr. Reilly’s questions have been based as hypothetical questions all  morning.

The Court: I think that I will allow the question, Mr. Reilly.

Mr. Reilly: It is argumentative, whether the man had gloves or didn’t have gloves.

The Court: Yes. I will allow it.

By Mr. Wilentz: Q. So that it is only where a person does not use some instrument to hide his fingerprints that the fingerprints may show: is that it? A. Yes, sir.

Q. Now, that is one instance where fingerprints won’t show. Supposing he did use his fingerprints on the window sill, some person, and then with a child in a bundle, a cloth, rubbed along the window sill: would that remove the fingerprints? A. All trace of them.

Q. All trace of them. On the other hand—I withdraw that.

Q. In addition to that, sir, do all impressions by fingers leave fingerprints? A. Not of value, Mr. Wilentz.

Q. Well, when we talk about fingerprints, Mr. Reilly and myself, we mean fingerprints which can be traced or identified if the opportunity later presents itself. A. Not all of them, no, sir.

[2142]Q. In other words, were I to take this paper, and, in the manner that I do now, and then attempt to stretch it like that (Mr. Wilentz takes piece of paper in his hands and jerks on both ends of it) would that have any effect on the prints? A. Very much.

Q. It might affect it? A. Yes, sir.

Q. If it touched it and just rubbed over it or handled it and moved my finger while I was doing it, would that leave a fingerprint or would it interfere with it? A. It would interfere with it.

Q. Now, when you made these tests on these various instruments, ladder, note, parts of the Lindbergh home, did you do the very best that you could with the instruments that you had at your command? A. Yes, sir, I did.

Q. Did you make any effort to conceal anything? A. No, sir.

Q. You have given us the best that was in you at that time? A. Absolutely.

Mr. Wilentz: Thank you, Trooper, that is all.

Re-Cross Examination by Mr. Reilly: Q. Well, now, if Mrs. Lindbergh or Betty Gow,  in closing the window, pressed their hands down on top of the window, just the same as these windows here to close it, and they had no gloves on, that would leave an impression of their hands and fingers, wouldn’t it A. I have no information that they did.

Q. I am asking you if they did. A. I don’t know.

Q. I still appreciate you are a State Trooper, but I am asking you this question: if they pressed  the window down to close it with their hands, and [2143] had no gloves, it would leave an impression of their hands, wouldn’t it? A. It would leave a mark.

Q. And if the baby was kidnaped from that crib and taken down the back stairs, and nobody ever went near the window, the window would not show any fingerprints, would it? A. It might from previous handling.

Q. Yes. But not of the person that took the child out of the crib and went down the back stairs, would it? A. No.

Q. If the man never went near the window. A. No, sir.

Mr. Reilly: That is all.

Re-Direct Examination by Mr. Wilentz: Q. Now, just one more question. If nobody went into the room that night after eight o’clock, and the baby had been put in that room at 7: 30, of course the baby wouldn’t have been missing, would it? A. No, sir.

Mr. Wilentz: That is all.

Re-Cross Examination by Mr. Reilly: Q. Now, just a moment, please. You haven’t any gloves on, have you? A. No, sir.

Q. With the Court’s permission will you open that window up from the bottom and show me how you would do it? You haven’t any gloves on.

Mr. Wilentz: Well, I think, if your Honor please, how he would open that window—

[2144]  Mr. Reilly: I want to see how his hands work, how he touches the railing and how he touches the edge.

Mr. Wilentz: I appreciate—

The Court: Do you think that is important here, Mr. Reilly?

Mr. Reilly: I want to see how he would grip it with his bare hands.

The Court: Well, let him go.

Mr. Wilentz: All right. How many windows, one?

Mr. Reilly: Just one.

Mr. Wilentz: Any particular window?

Mr. Reilly: That window there.

Mr. Wilentz: The first one?

Mr. Reilly: The one he is going to raise up.

Mr. Wilentz: All right.

A. (The witness stepped to a window back of the Court, unlocked it and raised it slightly by grasping the top.)

Q. Now, about the bottom. A. (The witness raised the window still more by taking hold of it from the bottom.)

Q. Now, your hands have touched that window  in how many places? A. Oh, one, two, three.

[2145] The Court: Now, I think he may put that window down. (Laughter.)

Q. Close the window, yes. A. (The witness closed the window.)

Q. Do you think it left any impression of your hands or fingers on it? A. I have left some marks on there, Mr. Reilly.

Q. What? A. I have left some marks on there.

Mr. Reilly: That is all.

Re-Direct Examination by Mr. Wilentz: Q. You didn’t have gloves on when you did that, did you? A. No, sir, I did not.

Q. And you weren’t standing on a ladder, were you? A. No, sir.

Q. That is all. By the way, incidentally, I notice that there is some steam on that window. A. Yes, sir.

Q. There is, isn’t there? A. Yes, sir.

Mr. Wilentz: That is all, Trooper.



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