Mr. GRIFFIN. Were you a prosecution witness or defense witness?
Mr. BEERS. Defense.
Mr. GRIFFIN. I take it that you were called to testify as to the
climate in Dallas, whether Jack could get a fair trial in Dallas or not?
Mr. BEERS. More or less; yes, sir.
It was concerned with the change of venue hearing in Judge Brown’s
court there.
Mr. GRIFFIN. I might add also that I did not interview you prior to
taking this deposition?
Mr. BEERS. No, sir.