petition for executive clemency roger keith coleman exhibits arnold & porter

160 Pages·2006·7.03 MB·English

This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

PETITION FOR EXECUTIVE CLEMENCY
ROGER KEITH COLEMAN
EXHIBITS
w.
Philip Horton
Kathleen A. Behan
Eric Hermanson
ARNOLD & PORTER
1200 New Hampshire Ave., N.W.
Washington, D.C. 20036
Attorneys for Petitioner
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

LIST OF EXHIBITS
1. statements of Teresa Horn
statement of Jamie Sword Ross
Statement of Linda Mullins
.r:-._ Affidavit of Goldie Owens
2.
Affidavits of Keester Shortridge
3.
4. Affidavit of Nell Shortridge
5. Photograph of Timecard
6. Virginia State Police Report
Grundy Police Department Report
7. Charts
8. statement of Kathleen A. Behan
Dr. Gist's Report-certificate of Analysis 8/21/81
Report of Investigation by Medical Examiner
9. Affidavit of James Mccloskey
10. statement of Sherry Porter
11. Affidavit of Morris Clark
12. Statement of Tina McNutt
13. Affidavits of William F. McCormick, M.D.
14. Press Clippings
15. Report of Robert E. Craig
16. Certificate of Analysis 5/7/81
17. Statement,of Brenda K. Keene
18. statement of Kennith Clevinger
19. Statement of Harold Smith ~
20. statement of James Mccloskey
21. Statement of Betty Hurley
22. Statement of Betty Smith
23. Statement of Kenneth Darrell Stiltner
24. Statement of Loretta Bartlett
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

25. Arrest Reports
26. Statement of Brenda Burks Wright
27. Statement of Drema Stiltner
28. Unsigned Letter
29. Roger Lee Matney's Arrest Warrants
30. statements of Roger Lee Matney
31. statement of Lee Matney
32. statement of Harry Keen
33. Roger Lee Matney's Arrest Warrants and Judgments
34. Order of Roger Lee Matney
35. Statement of Kermit Owens
36. Complaint of Randy Blackburn
37. Affidavit of Frank Hinkle
38. Statement of Myrel Justus
39. Statement of Dr. Walter Rowe
40. Statements of Dr. Bruce Kovacs
41. National Academy of Sciences Report
42. Affidavit of Mayor Miller Richardson
Affidavits of Texas and Opal Rash
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

STATDQT OP TIRP:SA HORI
I, Teresa Horn, say:
1. My mailinq address is at Route l, Box 46, Oakwood,
Virqinia. My residence is in Patterson, Buchanan County, Virqinia.
2. My date of birth is Auqust 16, 1968:
..
3. I am makinq this statement in relation to the case of
Roqer Keith Coleaan, who was convicted of the rape and murder of
a woman in Slate Creek, in Lonq Bottoa, in Grundy, Virqinia. I
~
makinq this state. .n t because another man, Donny Raaey,
told~•
that he co1lllllitted the crime.
4. I have never met Roqer Keith Coleman.
5. I first met Donny Raaey throuqh my boyfriend at the time,
Larry Kenneth C.ievinqer, who qoes by th• nail• "Kenny. " I saw Donny
from time to ti•• at Clancy's, the bar where I worked.
6. on th• niqht that Donny Raaey first told .. that he
comaitted the cri. . , I was workinq at Clancy's. Donny Raaey was
in the bar that niqht, alonq with Mark Helton and Jeff Chaffles.
7. To th• best of ay recollection, this was in March or April
1987.
a. I knew Mark Belton fro• hiqh school. I aa not sure of the
spelling of Jeff Chaffles' naae.
-
9. That niqht, .I was workinq at Clancy'•· Jeff had too auch
to drink, so he asked .. to drive hi• ho... Mark Helton and Donny
RUiey drove ay car to Jeff'• house, and I drove Jeff in hi• car.
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

10. We drove to Jeff Chaffles' mother's house, which was in
Deel. Jeff's mother was not home at the time.
11. When we arrived there, Jeff went inside and went to sleep
riqht away.
12. I was ready to leave riqht away, but Donny and Mark
persuaded me to stay. When I went into the house, Donny told me
I was qoinq to be raped. I thouqht he was kiddinq at f' irst,
~at
but then he started takinq my clothes off aqainst my will.
13. once my clothes were taken off, Donny picked me up and
carried me into a bedroom. He closed and locked the door behind
him.
.
14. Donny threw •• on a bed in th• bedrooa. As he threw me,
I hit my face on the niqhtstand. This left a bruise on my face by
my eye.
15. Donny pinned ae on the bed by kneelinq on my leqs, and he
tried to force my leqs apart with his knees. He tried to force me
to kiss him. I was yellinq to make hi• stop, so he put his hand
over my mouth very hard, which left bruises alonq the side of my
mouth. With his other hand, he qroped over my body.
16. Be told • that if I didn't sh°u"t up• · and quiet down, he
~.
was qoinq to do • like he did that qirl CrMk. I didn't
~Slate
really know vbat he was talkinq about when he said that.
17. Donny is very atronq, atronq enouqh so that he could have
succeeded in rapinq •· Be kept tellinq .. that I would like i.t.
He also kept pullinq my hair over ay face.
18. I quesa because I was yellinq, Mark broke into the
2
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

bedrOOJI and pulled Donny ott ae. He hit Donny, hard.
19. After I put my clothes back on, I drove to the house
where Kenny was livinq. I was very upset. I didn't qo to the
police, though, because I thought it wouldn't do any qood. 11rJ b(;c~e
He. #oirea:knCd me... T· t+·
20. Kenny told me there why Donny's nickname was "The Hand."
(Another nickname Donny has is "Trouble.") Kenny said that Donny
qot the nickname when he sexually attacked a woman, when he shoved
his hand into her vaqina.
21. I met Mark some days later. He said that he had moved
out of the house he was sharinq with Donny, because Donny had told
hi• that he aurdered that qirl in Lonq Bottoa. Mark said that he
couldn't live with Donny after he heard that. Mark explained ·to
me that Donny was reterrinq to that when he told me that he would
do me like he had done that qirl in Slate Creek.; until Mark
explained it to ae, I hadn't really understood what Donny meant.
22. I saw Donny a few months later at the Acapulco Club,
which is in West Virqinia. I asked hi• whether he had killed that
girl in Slate creek. He said yes.
23. Later that au.aer, I talked to Donny aqain about the
attack on that c;irl on Slate creek. I asked hi• if he wasn't
afraid that the police would find out what he did. He said no, he
wasn't concerned, because the case had been closed.
24. I oriqinally contacted the lawyers tor Roqer Coleman
because of an advertiae. .n t they placed in th• :11rqinia
Kountaineer. One iaportant reason that I had called them was
because of the obscene phone calla that I had been receiving. I
3
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

ma triqhtened by those calls, because I think they may be cOJU.nq
from Donny Raaey.
Dated: September II, 1990
4
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

STATEMENT OF TERESA HORN
•. ~y name is Teresa Horn. I have given a statement
in relation to the case o! Roger Keith Coleman in the past.
I now make this additional statement to clarity and
supplement my past statement in response to the
Commonwealth's affidavits about me, and to assure the court
that I swear that my testimony in this case is true and
correct under penalty of perjury.
2. I have read th• statements of Bobby Donald Ramey,
Mark Helton, and Wayne Horne. I have also read th•
portions ot Jac~avidson•s statement which relate to me.
Because I believe that th••• staments contain inaccuracies,
I make this statement to correct th••·
3. On the night in 1987 when Oonney Ramey attacked me at
Jett Chattles' hou•• and told me that it I did not shut
up, he would do •• like he did the girl on Slate Creek, I
had no romantic interest in Jeff Chaftle•, Mark Helton,
or Denney Raaey. I did go to Jett'• hou•e to take his car
there since he va• intoxicated, but to clarify ay earlier
stat•••nt, I do not remember hov Jeff got to th• house.
I also did not take ay clothing otf voluntarily or
go in tH• bedrooa voluntarily to have sex vith Donney
Ramey. In•t•ad, Mark Helton from behind vhil•
h•ld~me
Oonney took my cloth•• ott.
4. Oonney Raaey then picked me up and carried me into the
bedroom, clo••d and locked the door, and tried to rape me.
I have de•cribed th• attack at more length in my previous
statement. During that attack h• did say that it I did
not shut up. he would do me like h• did th• girl on Slat• CreeK.
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

5. I went directly after the attack and told Kenny
Clevinger, my ex-boyfriend. He can confirm that it occurred.
I did not tell the police because I decided it would not
do any good since I thought they probably would not prosecute,
and because Denney Ramey had threatened me. I did not
tell or imply to Jack Davidson that I thought I would not
be believed, instead, I said that it would have done no
good, or words to that effect. He may have misinterpreted
my comment.
6. I never had sex with Doney Ramey on a later occasion.
Because Denney Ramey and I had mutual friend• and went to
the same parti••· I had occa•ional contact vith him (lAd
he even attempted to apologize for the incident on more
than one occa•ion. I al•o got a ride home from him once
by which time I wa• no longer concerned about him. Before
the attack, I briefly con•idered moving in vith Mark
and Denney, becauae I conaidered Mark a friend, but decided
not to. (I had originally met Denney through my then
boyfriend Kenny, and had visited Mark and Donney•s vith Kenny.)
I never lived in their ho••·
7. Donner R•••Y adaitted to th• murder on tvo occa•ion•
after the attack in 1987. On the first occasion, I do
recall mentioning Wanda McCoy's name.by asking hi• whether he
had really killed that McCoy girl on Slate Creek, or vords
to that effect. He said yes. That waa at th• Acapulco Club.
The second incident vaa vhen he drove me home from th• s~m•
club one night. That va• the time when he said that he wasn't
This document is housed in the Capital Punishment Clemency Petitions (APAP-214) collection in the M.E. Grenander
Department of Special Collections and Archives, University Libraries, University at Albany, SUNY.

concerned about the case because the case had been closed.
I did not have sex with Doney on that or any other
occasion. I have never had any sexual or other interest
in him.
8. I am not a whore. I do not abuse drugs. I have
used drugs occasionally , although probably not to the
same extent as Denney Ramey. on the
incident where Denney Ramey attacked me, I was completely
sober and had not smoked pot, because I was working two
jobs at the time and had just gotten off work. I do not
even recall there being pot at Jef! Chaffles' house on
that occasion.
9. The incident involving Rufus Viars, my mother's
brother in law, wa• not unfounded. Although he did harass
me and attempt to have sex with me, I eventually dropped the
charges because my faaily had been torn apart by the incident,
and Ru!u• and hi• •on Ricky had been convicted of assault
and battery of ay aother•s hu•band Bobby in relation to
the incident. Glen Mullins and Terry Ward vere present at the
incident and can confira that it occurred.
10. I have read the co. .o nvealth's arguaent in this case
that Mr. Coleaan should not be able to u•• this confession
becau•• it va• available to him in 1987. That is wrong.
It was not available to Mr. Coleman until 1990, when I called
hi• attorneys to tell them about it.
11. I do not think th• Commonweal th• s a ttac:Jc• on my
credibility are fair or correct. Donney Ramey admitted
to the murder of Wanda McCoy to me, and Marie Helton also