Shidoshi Dallas’ Coerced Criminal Conviction

I, Jay Green, have read the exhibits and spoken with some of the people who have first hand
knowledge of the events that lead to Dr. Dallas’ conviction. It is my opinion that Shidoshi Dallas is
innocent. You read the following pages, backed by the numerous legal affidavits and police reports,
and decide for yourself.

You Decide – its time to read the facts for yourself. Don’t be lead around by the nose through a sea
of lies and half-truths.

Growing up in a small town environment it was hard for me to conceive that people did anything
but the right thing. Sure we all see the violence and corruption in the movies, but that’s just it, that’s
in the movies. We, as people, don’t relate that behavior to the average every-day world. I know that
99.9% of the police officers in this country are good, hard working men and women. This section is
no reflection upon them nor meant to take away from their sacrifices, but the following pages do tell
a different tale. I hope that you keep an open mind when you begin reading this section.

Shidoshi Bryce Dallas has been relentlessly attacked on the internet message boards over his felony
convictions by multiple hate groups. They have used a couple of incidents in his life as the means to
try and destroy his entire life.

Many believe it is impossible to force a person to do anything against their will. Often there are
uncontrollable circumstances that play significant roles in the decisions that we face which make
the impossible very likely. These situations usually affect the direction of our lives.

Shidoshi Dallas was presented with one such situation in 1991. Dr. Dallas was arrested for a crime
that his roommate committed, even after the victim told the police who actually committed the
crime, see the exhibits. While incarcerated in jail awaiting his trial he developed an impacted
wisdom tooth and was refused medical attention for six months. His tooth became infected. Dr.
Dallas was told that if the infection was not treated, then the spread of the infection could kill him.
If you have ever had a tooth-ache, then imagine a tooth-ache which has grown a hundred times
worse as it was left untreated over the course of the six months. Combine this pain, with the
jailhouse abuse, and the threat to his life that the infection posed, Dr. Dallas was forced to plead
guilty, in order to receive medical care and get transferred out of the county jail.

The following paragraphs illustrate the tactics used against Dr. Dallas that forced an innocent man
to plead guilty. These pages cannot convey to the reader the magnitude nor the overwhelming
disbelief that the justice system would turn down all evidence presented to them by Dr. Dallas’
friends, family, the “actual” victim, and the “actual” perpetrator on behalf of Dr. Dallas. The
disbelief that all the evidence proving Dr. Dallas’ innocence would be overlooked by the police and
court system mixed with the refusal of medical care and inmate violence are all factors in the
uncontrollable circumstances that forced an innocent man to pleading to charges that he did not
commit. This evidence supports the fact that Dr. Dallas was coerced into pleading guilty.

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 Statements Made by Perpetrators of the Crime and the Victim that Were
Ignored by Police
[The Following are Excerpts from a Court Filed Legal Brief]

The first groups of exhibits are those that eliminate the charges in the indictment, which in some

cases were given to the police during the initial questioning and were available to everyone but Dr.

Dallas before his trial.

A. INDICTMENT COUNT 2: 11/29/1990 Burglary actually done by Mr. Myers acting

alone:

"I watched for two or three days, when Knight left I decided to go in and look

around...I took everything I thought would criple his drug business and hide it

in the woods this took so much time I decided to take his bike and leave." [All

Spelling and Grammar Errors Stated In Context] (Mr. Myers, Jr. See Exhibit

2, Page 2.)

B. INDICTMENT COUNT 3: 5/10/1991 Burglary actually done by Mr. Myers acting alone

as admitted by Mr. Myers.

C. INDICTMENT COUNT 4: 9/25/1991 Burglary actually done by Bennie Myers acting

alone;

"...I saw kinght leave and the thought came to go in and tape, so I did...during

my action against Knight Bryce Dallas, was taking a chemistry final exam,

Bryce Dallas did not help me plan what I did, he isn't guilty." [All Spelling

and Grammar Errors Stated In Context] (Mr. Myers, Jr. See Exhibit 2, Page 3.)

D. INDICTMENT COUNT 5: 9/25/1991 Assault actually done by Mr. Myers acting alone;

"They (officials from another Karate group) have even went as far to lie and

say there was 18 involved in assaulting Knight when it was just me." [All

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 Spelling and Grammar Errors Stated In Context] (Mr. Myers, Jr. See Exhibit

6.)

E. INDICTMENT COUNT 6: 9/25/1991 Car theft actually done by Mr. Myers acting alone;

“When all this happen I decided to leave fast, so I took his car. during my

action against Knight Bryce Dallas, was takeing a chemistry final exam,

Bryce Dallas did not helpme plan what I did, he isn't guilty." [All Spelling and

Grammar Errors Stated In Context] (Mr. Myers, Jr. See Exhibit 2, Page 3.)

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 Exhibits of Fact that Exonerate Dr. Bryce Dallas
[The Following are Excerpts from a Court Filed Legal Brief]

Below is a listing of fifty exhibits that exonerate Dr. Dallas of the crime, beginning with the

perpetrators of the crimes and the “victim’s” own words through affidavit or police report;

A. Exhibit 2 Page 1, Page 2, Page 3, Myers’ Affidavit, ISSUE 10/19/1992: The perpetrator,

Mr. Myers’ Affidavit clearing Dr. Dallas. This is a step by step detailed account of the

occurrence of Mr. Myer’s actions by Mr. Myers that leaves Dr. Dallas exonerated

B. Exhibit 9, Page 1, Police Report, ISSUE 9/25/1991: On page one of Exhibit 9 the victim,

Knight, and witness, Mr. Newman, gave police a report that stated “a man”, “the guy”, and

again “a man” all in singular; i.e. Myers.

C. On page two of Exhibit 9 in the last paragraph Knight names Myers as the lone perpetrator

that shot him, as quoted;

“…C-1 said that Knight said, “A Myers subject shot him.”

D. This police report of the victim Mr. Knight and Knight’s girlfriend named Mr. Myers as the

perpetrator. Although the victim had met Dr. Dallas and knew Dr. Dallas personally, the

victim and victim’s girlfriend did not name Dr. Dallas. It is obvious Dr. Dallas did not

commit a crime against Knight.

E. Exhibit 10, Myer’s Deposition, ISSUE 11/1/1993: Deposition of Mr. Myers taken by a

civil action attorney (Mr. Henley). Page 13 of the deposition is now Page 2 of Exhibit 10.

On line 11 Mr. Myers is asked;

HENLEY: “So ya’ll committed that crime together?”

BRM: “No, sir.”

(Later) BRM: “…I was alone by myself when I committed the crime…”

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F. This statement was part of a deposition taken after Mr. Myers had served his time and the

statement absolutely exonerates Dr. Dallas.

G. Exhibit 3, Ms. Jobe Affidavit, ISSUE 11/20/1992: The affidavit of the late Ms. Jobe (sister

of Dr. Dallas) stating an alibi for Dr. Dallas and that Dr. Dallas’ Attorney never contacted her

to testify. Ms. Jobe’s employment background was that of a laboratory scientist.

H. Exhibit 4, Ms. Dallas Affidavit, ISSUE 11/19/1992: The affidavit of Ms. Dallas, mother to

Dr. Dallas, stating an alibi for Dr. Dallas and that Dr. Dallas’ attorney never contacted her.

Ms. Dallas’ background is that of a registered nurse of approximately 40 years.

I. Exhibit 5, Second Ms. Dallas affidavit, ISSUE 11/19/1992: Second affidavit of Ms. Dallas

stating an alibi for Dr. Dallas. This affidavit is clear and to the point.

J. Exhibit 6, Myers’ Detail Statement, ISSUE 11/19/1992: A statement detailing himself

(Myers) in the crime and clearing Dr. Dallas. This detailed statement clearly defines all

actions and leaves Dr. Dallas exonerated. This statement exonerates Dr. Dallas of count

1,3,4,5, and 6 of the indictment.

K. Exhibit 7, Second Ms. Jobe Affidavit, ISSUE 11/20/1992: A second affidavit giving an

alibi to Dr. Dallas by the late Ms. Jobe.

L. Exhibit 8, Walls’ Affidavit, ISSUE 11/16/1992: An Affidavit by Mr. Walls clearing Dr.

Dallas. This affidavit clearly supports all other affidavits exonerating Dr. Dallas.

M. Exhibit 15 and Exhibit 16, Pawn Receipts: Pawn receipts of Myers showing where he

pawned the stolen items. The pawn receipts were withheld from Dr. Dallas’ knowledge.

(a) Exhibit 15, ISSUE 9/18/1991: Pawn receipt

for diamond nugget ring

(b) Exhibit 16, ISSUE 10/10/1991: Pawn receipt for gold ring

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N. Exhibit 17, Pink Eye Alibi, ISSUE 3/21/1991: Doctor’s information where Dr. Dallas had

an extreme case of “pink eye” on or before 3/31/91 and was absent for weeks during one of

the times in question. Neither the defense nor the prosecution ever investigated or obtained

these medical records, therefore demonstrating an ineffectiveness of counsel and a

miscarriage of justice. Defendant did request that his attorney investigate the matter.

O. Exhibit 18, Broken Ankle Alibi, ISSUE 8/31/1991: Doctor’s information where Dr. Dallas

had a broken ankle on 8/6/91 and was absent for weeks during one of the times in question.

Neither the defense nor the prosecution ever investigated or obtained these medical records,

therefore demonstrating an ineffectiveness of counsel and a miscarriage of justice.

Defendant did request that his attorney investigate the matter.

P. Exhibit 19, Criminal Affidavit on 11/27/91: Shows that Myers was the only one charged

on November 27, 1991 for a crime that happened three months earlier on 8/14/1991. The

fact of a three-month wait to arrest is very suspect because he was spotted leaving the scene

of the crime by multiple people. The fact that this subject never arose leads us to question

what other evidence was withheld from these witnesses? The crime happened on 8-14-91

and Dallas (Defendant) injured his ankle on 8-6-91 as noted in Exhibit 18.

Q. Exhibit 21, Exhibit 22, Exhibits 23- 25, Myer’s “waiver of rights”: The “waiver your

rights” forms showing Myers was arrested and re-arrested for the same crime. There are

missing statements to their waivers that were never turned over to Dr. Dallas’ attorney.

When the defense attorney file was turned over to Dr. Dallas at a much later date, it did

show that this evidence was withheld. A total of five statements were withheld, which is a

“Brady v. Maryland” violation.

Exhibit 21. Signed 10-16-91

Exhibit 22. Signed 11-25-91

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R. Exhibit 28, Myer’s Driver’s License: The driver’s license of Myers showing that Myers

had black hair, weighed 150 pounds, and was 5’9’’ and since Dr. Dallas had blonde hair,

weighed 280 pounds, and was 6’6’’ there is no way the witness was mistaken.

S. Exhibit 32, Seizure Report of Apartment, ISSUE 11/19/1991: Clearly states that only

items truly questionable were found in Myers’ room. There were no items found in Dr.

Dallas’ room.

T. Exhibit 33, Seizure Report of Dr. Dallas’ Car, ISSUE 11/19/1991: Shows Dr. Dallas’ car

to be clean of stolen items.

U. Exhibit 34, Seizure Report of Myer’s Car, ISSUE 11/19/1991: A single page exhibit,

places camouflage clothing used in the crime of 9-25-91 against Knight in Myers’ car.

V. Exhibit 35, Exhibit 36, Exhibit 37, and Exhibit 38, Criminal Warrants and Affidavits:

The day after the shooting all three different police reports say only Myers was involved.

They do not name Dr. Dallas. Furthermore, the reports from all the witnesses and the victim

speak of a lone perpetrator as in “a man” or “the man” but never state “those men,” “them

men,” or “they.”

Exhibit 35. Signed 9-26-91

Exhibit 36. Signed 9-26-91

Exhibit 37. Signed 9-26-91

Exhibit 38. Signed 10-17-91

W. Exhibit 39, Police 9/25/91 Interview of Knight: A policeman’s notes about an interview

with Knight on the day of the crime in which Knight only mentions Myers. Dallas is not

mentioned. The report mentions that Myers had been seen in the area three times before

Myers committed his crime, but again Dr. Dallas was not named as have been present at any

of those times.

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X. Exhibit 40, Police 10/7/91 Interview of Knight and other Witnesses: The police

interview in which Knight and other witnesses indicate Knight had caught only one person,

and named that person as Myers, trying to break into Knight’s house once before. Ms.

Farmer (Knight’s girlfriend) had gotten Myers tag number, and Mr. Gremillion (an

acquaintance of Knight) had seen Myers in a gravel pit near Knight’s house around the time

in question. Note that neither Dr. Dallas nor any other second person is mentioned but that

everyone names Myers. This report was withheld from Dr. Dallas to coerce the plea or at

best to result in ineffective assistance of counsel.

Y. Exhibit 41 and Exhibit 42, Police Line-Up: Where people picked Myers out of line up.

Exhibit 41. Ms. Farmer, Mr. Knight 10/10/1991

Exhibit 42. Line-up list 10/16/199

Z. Exhibit 44, Page 1, Page 2, Page 3, Original Indictment, ISSUE 4/10/1992: The original

indictment. The exhibits attached to this document clear Dr. Dallas of each count in this

indictment.

AA.Exhibit 49, Knight’s Phone Call to Dr. Dallas: The “victim” Mr. Knight called Dallas, but

the transcripts of this call were withheld. The notes in this exhibit are the notes of the sheriff

telling Knight what to say. Counsel has a duty to make reasonable investigation or to make a

reasonable decision that makes particular instigations unnecessary. Therefore these actions

or lack of actions fit both ineffective assistance of counsel due to the lack of investigation

and a duty to disclose violations on the part of the prosecution by not disclosing the tape

recording of the aforesaid conservations.

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 Attorney’s Betrayal of Duties
[The Following are Excerpts from a Court Filed Legal Brief]

The following is an accounting of how Dr. Dallas’ attorney betrayed his duties to provide a proper

defense against the charges. Kelly’s failure to provide proper council and Dr. Dallas’ unfamiliarity

with the legal system played significant roles in forcing Dr. Dallas to pleading guilty to false

charges. Dr. Dallas was under the illusion that his attorney was providing the police with all the

above listed evidence which further lead to the confusion as to why the police were prosecuting him

so fiercely for a crime he did not commit. Take note that attorney Kelly died a few months after the

would be trial of Dr. Bryce Dallas from Cirrhosis of the liver.

1. Exhibit 51, Plea Bargain, ISSUE 4/30/1992: On the day set for trial, Dr. Dallas entered into a

plea “bargain” while at the courthouse after awaiting trial for six months. Kelly came to the

trial under the influence of alcohol to the point that blue blood veins showed in his red nose.

Shortly after trial Mr. Kelly died of alcohol related problems. This plea hearing was the day of

the scheduled trial, but no witnesses had been called by Kelly to testify about the jail violence

and the denial of medical care for an impacted wisdom tooth’s torturous pain, nor was any of the

above exhibits of fact present in Dr. Dallas’ defense. Dr. Dallas also discovered that his lawyer

had shown up drunk. It is obvious that Dr. Dallas was very coerced into the “plea bargain.”

2. Dr. Dallas also stated to law enforcement officers and attorney Kelly that he was on campus at

the University of Southern Mississippi taking a chemistry make-up examination from 10:00

a.m. until 11:55 a.m. on September 25, 1991, and later at his fraternity house. However, Dr.

Dallas was unable to get attorney Harry Kelly to go and interview said witnesses. Attorney

Kelly did not advise Dr. Dallas of the contents of Myers’ statement to the police. Attorney Kelly

does fall short of the standards set forth in Wiley, supra.

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3. The report filed by Officer Clower states that the burglary occurred at approximately 12:15 p.m.

[Exhibit 9, Page 1, Page 2]. Attorney Kelly did not advise Dr. Dallas of the existence of this

report.

4. Dr. Dallas also stated to law enforcement officers and attorney Kelly that he was on campus at

the University of Southern Mississippi taking a chemistry make-up examination from 10:00

a.m. until 11:55 a.m. on September 25, 1991 under Ms. Booth in Dr. Woodruff’s office with Dr.

Dallas present.

5. Dr. Dallas was not aware of the existence of any of the police notes and/or reports or the

contents of Myers’ statement until he wrote attorney Kelly demanding a copy of his file for post-

conviction purposes. It was at that time that Dr. Dallas learned the full extent of counsel’s

errors.

6. Dr. Dallas wrote Kelly, former retained counsel, for a complete copy of his file and received

said copy on 10-22-92. The receipt of the case file was six months after Dr. Dallas’ conviction.

The information contained in the case file only then became known to Dr. Dallas and proof of

when the case file was sent is in Parchman Prison mail records for 24-X.

7. Dr. Dallas has made many attempts to retain the phone bill that would show that someone

placed a collect call to Dr. Dallas’ apartment at Hattiesburg, Mississippi from the Methodist

hospital in Jackson, Mississippi. Dr. Dallas’ car was in Jackson, Mississippi with the

transmission out of order and he had to borrow Ms. May’s car; this is spoken of in Myers’

statement. She was never questioned by Dr. Dallas’ attorney. This proves that Dr. Dallas did

not commit the crime of 11-29-90 and that Dr. Dallas’ attorney did not try to obtain the

information which clearly shows that attorney Kelly’s performance was deficient to the point

that he denied the Dr. Dallas the right of effective counsel guaranteed by the Sixth Amendment.

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8. Ms. Dallas, Dr. Dallas’ mother, has provided an affidavit stating Dr. Dallas was at her home in

Jackson, MS on the afternoon of August 14, 1991, that they returned later that day and stayed

the night, that defense attorney Kelly did not contact her as to when she would testify, nor did

Kelly question her or seek a deposition; but had he done so, she would have been willing to

testify at the trial.

9. Other witnesses would and should have been subpoenaed as well, such as Tau Kappa Epsilon

fraternity fellow members that could testify that Dr. Dallas was present in Hattiesburg, MS., on

9-25-91. On the same day Dr. Dallas took the chemistry exam, Dr. Dallas went by the fraternity

house of Tau Kappa Epsilon and helped perform some needed tasks. About 12 members were

present and all knew Dr. Dallas well. Dr. Dallas asked his attorney Kelly to interview them for

an alibi but Kelly did not. By chance, Dr. Dallas encountered his “big brother” after getting

out of prison and asked if he had been interviewed by Kelly and he had not. His T.K.E. “big

brother” said that he would have testified.

10. Then Sheriff Jackson and other law enforcement officers informed Dr. Dallas that if he were to

contact any witness, that the officers would charge Dr. Dallas with tampering with witnesses

since Dr. Dallas’ witnesses were the same as the officers’ witnesses, leaving Dr. Dallas unable to

seek help. Once an attorney was retained, Dr. Dallas had to depend on the attorney to obtain

witnesses because he was denied bond. This made him totally dependent on the attorney to

research the case, something that the attorney neglected to do.

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 Torture through Physical Pain
[The Following are Excerpts from a Court Filed Legal Brief]

If you have never had any real problems with your teeth, ear infections, or chest pains then I pray

you never do. If you have had a tooth break or a wisdom tooth to become impacted then you will

understand the excruciating pain that Dr. Dallas was facing on a daily basis. Keep that pain in mind

and then compound the impact of it with mass infection to put you in the proper frame of reference

when you read the following paragraphs. How long could you bear the pain before you would do

what it takes to end it?

(a) Dr. Dallas was coerced into pleading guilty by being denied treatment for an impacted wisdom

tooth until he gave a false guilty plea. This denial of treatment caused additional complications,

which included a hole being caused in a second tooth. This hole caused excruciating pain when

food touched it, air passed over it, or water went in it. Another complication from the lack of

treatment was when the roots of the tooth were exposed from the gums, because the first

wisdom tooth was turned on its side and grew straight forward The pain was unbearable. A

severe dental abscess developed from non-treatment, which caused Dr. Dallas intractable pain

and mental anxiety related to the serious nature of his worsening condition In Exhibit 83, the

medical report about Dr. Dallas’ dental problems advises the jail authorities of the depth and

scope of the aforesaid problem. Also see Exhibit 54, which mentions the loose tooth that was

referred to in Exhibit 83 and also states that “Dr. Aiken advised B. Dallas that he had a wisdom

tooth that needed to be pulled.” (Exhibit 54) This was in May 29, 1992. Dr. Dallas was not

given treatment for his wisdom tooth until he entered his plea and was moved to state prison

facilities.

(b) Dr. Dallas was told that if he wanted to escape the pain of the impacted tooth to plea guilty and

go on to the state prison to have his tooth fixed.

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(c) Furthermore, he was denied his pain medication for those injuries as well as his dental problems

to maximize coercive effects.

(d) Exhibit 53, Myers’ Medical Log: Is attached to show that Myers did receive his medication.

Also, notice his initials are in the proper order, showing that initialing first to last name was the

standard procedure.

(e) Exhibit 52, False Medical Log: Is attached to show that Dr. Dallas did not receive his

medication. Note the initials on the log after the first initials in the third column are signed as

DB but, according to standard procedure, they should be signed BD as they were in the first cell

of the third column. This means that Dr. Dallas did not sign for his medication after the first

dose. Dr. Dallas only received one dose of pain reliever throughout his stay in the county jail.

(f) Remember, Dr. Dallas had an impacted wisdom tooth for months and once Dr. Dallas was

coerced into a plea agreement, the wisdom tooth and the second tooth had to be removed. The

wisdom tooth had been pressed into the second tooth and was damaged. The pain was

unbearable and only medically corrected once Dr. Dallas reached state prison. Dr. Dallas

awaited trial for about 6 months with the intractable pain while having his pain medication

withheld as his falsified medical records show. This shows an intentional disregard among the

Officers regarding Dr. Dallas’ condition and anxiety. This condition was another of many factors

that coerced Dr. Dallas into this so called “plea bargain.”

i. EXHIBIT 52: Bryce Dallas’ [Dr. Dallas] Medication Log Sheet

ii. EXHIBIT 53: Myers’ Medication Log Sheet is filled out opposite of Dr. Dallas’

Medication Log Sheet. Myers’ Medication Log Sheet is properly done, further

illustrating the falsification of Dr. Dallas’ Medication Log Sheet which has been initialed

backwards.

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iii. EXHIBIT 71: Mr. Usry’s, Mr. Pullen’s, and Mr. Taylor’s statement, dated 6-18-92,

regarding Dr. Dallas’ daily requests to see a doctor due to a wisdom tooth that prison

officials were advised about more than three weeks previous. Here a jail trustee gives a

statement of medical condition concerning Dr. Dallas’ impacted wisdom tooth. Dr.

Dallas was denied treatment until he was moved to another jail. This was another

example of the torture methods used to coerce the “plea bargain.”

iv. EXHIBIT 83: Dental report refers to Dr. Dallas’ loose teeth from being attacked in jail,

on 5/29/92. This report also notes the possibility of an “abscess…in 2-4wks” which did

eventually occur and was not treated despite this early warning. The pain and violence

this report eludes to is what coerced Dr. Dallas into making his “plea bargain.”

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 Coercion through Violence
[The Following are Excerpts from a Court Filed Legal Brief]

Take a second and imagine what being in jail might be like. Did you picture an orderly well run

facility or the violent unruly jail illustrated by the movies in Hollywood? If you pictured the orderly

jail then try to imagine the toll that constant attacks and violence would take on a person. What

would you do to escape from the violence? No body deserves to live in constant fear of assault.

Below is a listing of reports coupled with photos of the violence filed by Officers’, jailers’,

trustees’, and doctors’ that demonstrate that Dr. Dallas was coerced into falsely pleading guilty in

order to escape the violence he was forced to endure for seven months, while suffering intractable

pain from an impacted wisdom tooth spreading infections into Dr. Dallas’ ears.

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 Denial of Food and Water
[The Following are Excerpts from a Court Filed Legal Brief]

A. EXHIBIT 63: Jail Trustee Byrd’s statement regarding lockdown 6-19-92. Trustee Byrd

showed that Dr. Dallas was denied the full rations allocated by the prison for each prisoner,

when no other prisoners were skipped for meals.

B. EXHIBIT 64: Jail Trustee Byrd’s statement regarding torturous conditions in the cell by the

“drunk tank.” Dr. Dallas was placed in this dry cell with only 3-8 ounce cups of liquid at a time

and 24 total ounces of liquid a day for three weeks 6-19-92. The water that was brought

contained mold. To speed Dr. Dallas’ dehydration, the heat was turned on high with a window

that could not be opened. These conditions occurred in order to force Dr. Dallas to “plea

bargain” and this statement was signed and dated after said coerced plea bargain.

C. EXHIBIT 68: Bowen’s statement regarding the cell next to the “drunk tank,” dated 5-31-92.

Another pre-“plea bargain” event that forced Dr. Dallas to enter a coerced plea. This states that

Dr. Dallas had no running water in this cell for the length of his stay.

D. EXHIBIT 78, Page 1, Page2, Page 3: Inspection of county jails 4-21-92. This inspection

documents multiple health and safety issues within the jail and when coupled with the jail floor

plans gives credence to Dr. Dallas’ claim that his cell had no running sink water.

E. EXHIBIT 79: Copiah County jail floor plan. Floor plan will be used with the above exhibits to

give credence to Dr. Dallas’ claim that he had no running water in his cell.

F. EXHIBIT 84, Page 1, Page 2 10/14/1991: Copiah County Detention Center Jail Inspection

Report. Shows that sink was out of order in Dr. Dallas’ cell and had not been fixed causing

dehydration on an indescribable level. This coerced Dr. Dallas to free himself from the torture

of these inhumane conditions.

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 Violence
[The Following are Excerpts from a Court Filed Legal Brief]

A. EXHIBIT 54, 5/20/1992: Taylor assault “write up” from 5-29-92 about a visit Dr. Dallas has

with the Dentist due to loose teeth from the attack. Written by Channel, the jail administrator.

B. EXHIBIT 55: Jailer Chase’s statement (mostly unintelligible), about Dr. Dallas being hit in the

head by a mop handle and how it was reported to the Sheriff.

C. EXHIBIT 56: Bryce Dallas [Dr. Dallas] statement 5-12-92 about being assaulted with a mop

handle.

D. EXHIBIT 58: Jail Administrator report from 4-5-92, regarding the injuries Bryce Dallas

[Petitioner] received in an assault which was so severe that the injuries needed to be x-rayed.

E. EXHIBIT 60: Jail Trustee Marshall’s Affidavit regarding Mildner 5-14-92. More evidence of

violence that went unchecked by the Officers. Even accuses one Officer Chase of telling

inmates that the next shake-down was because of Dr. Dallas.

F. EXHIBIT 61: Jailer Officer Stark’s statement regarding Minor 3-16-92. Proof the jailer let the

inmates govern themselves.

G. EXHIBIT 62: Jail Trustee Bowen’s statement on 5-31-92 offers an account that is more proof

of the violence suffered by Dr. Dallas.

H. EXHIBIT 67: Myers’ statement, dated 10-91, regarding a glass shard in his ear along with the

continuous intentional neglect by jailers of said wound shows the poor medical conditions and

ongoing violence that contributed to the coerced “plea bargain.”

I. EXHIBIT 69: Jail Trustee Bowen’s statement regarding Myers’ continuous requests to see a

doctor about a shoulder wound 5-31-92. Further proof of violence and poor care.

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J. EXHIBIT 72: Henry’s and Bland’s statement (mostly unintelligible) regarding a falling in a

shower 5-5-91. Here again, something is reported as wrong, but cannot be read intelligibly and

is ignored by the jailers instead of investigated.

K. EXHIBIT 74: Jailer Stark’s statement regarding violence in cell 48 involving Myers, Dr.

Dallas, Taylor, and Ervin 5-29-92. The jailer again writes of violence, in which the

troublemakers are obviously the same gang members. Yet, nothing is done to separate those

involved. Instead, the attacks are allowed to continue. Notice on the bottom the jailer makes a

special note as quoted: “Taylor has been in trouble ever since 4-12-92.” With the note, the jailer

was trying to point out the violence that was coercing Dr. Dallas to falsely plead guilty.

L. EXHIBIT 75: X-Ray report 4-5-92. Here Dr. Dallas has his skull X-rayed after a violent attack.

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 Fire Bombing Cell to Cause Sleep Deprivation
[The Following are Excerpts from a Court Filed Legal Brief]

A. EXHIBIT 66: Keen’s statement regarding the attempted arson of Dr. Dallas’ bed while he was

sleeping on it and violent assault by Mildner 5-31-92. This statement is more proof of the

violence Dr. Dallas suffered and reveals another method of torture: sleep deprivation.

B. EXHIBIT 70: Jail Trustee Newell’s statement confirming Myers’ continuous requests to see a

doctor and seeing burnt toilet paper outside Dr. Dallas’ cell on more than one occasion. He also

states that Dr. Dallas’ cell’s water was not fixed until after Dr. Dallas had been moved and was a

witness to Mildner’s unprovoked attack on Dr. Dallas and Myers. 5-31-92.

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