1 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION 2 3 UNITED STATES OF AMERICA, 4 vs. 5 RUSSELL G. BELLAR, 6 Defendant. 7 ___________________________ ) ) ) ) ) ) ) ) ) Cause No.: 3:04cr00068-AS South Bend, Indiana January 6, 2005 9:30 a.m. 8 9 10 11 12 13 TRANSCRIPT EXCERPT OF JURY TRIAL (TESTIMONY OF: JEFF WICKERSHAM and FRED ROWAN) BEFORE THE HONORABLE ALLEN SHARP APPEARANCES: For the Government: MR. DONALD J. SCHMID Assistant United States Attorney M01 Robert A. Grant Courthouse 204 South Main Street South Bend, Indiana 46601 For the Defendant: MR. DENNIS E. ZAHN MR. JAMES H. VOYLES Voyles Zahn Paul Hogan & Merriman 141 East Washington Street Suite 300 Indianapolis, Indiana 46204 14 15 16 17 18 19 20 21 22 23 24 25 MR. C. JOSEPH RUSSELL Krieg DeVault LLP One Indiana Square Suite 2800 Indianapolis, Indiana Joanne M. Hoffman United States Court Reporter 119 Robert A. Grant Courthouse 204 South Main Street South Bend, Indiana 46601 (574)246-8038 Joanne_Hoffman@innd.uscourts.gov 46204 2 1 INDEX 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 JEFF WICKERSHAM DIRECT EXAMINATION BY MR. SCHMID: Page 3 CROSS-EXAMINATION BY MR. VOYLES: Page 24 REDIRECT EXAMINATION BY MR. SCHMID: Page 41 RECROSS-EXAMINATION BY MR. VOYLES: Page 45 FRED ROWAN DIRECT EXAMINATION BY MR. SCHMID: Page 48 CROSS-EXAMINATION BY MR. VOYLES: Page 55 REDIRECT EXAMINATION BY MR. SCHMID: Page 61 * * * WICKERSHAM - DIRECT EXAMINATION 1 2 3 (Transcript of prior proceedings not requested herein.) 3 MR. SCHMID: Thank you, Your Honor. 4 The government calls Jeff Wickersham. 5 (The witness was duly sworn.) 6 THE COURT: Be seated. 7 JEFF WICKERSHAM, 8 having been duly sworn, was examined, and testified as follows: 9 DIRECT EXAMINATION 10 BY MR. SCHMID: 11 Q. Good morning. 12 A. Good morning. 13 Q. Would you please tell us your name for the record. 14 A. Jeff Wickersham. 15 Q. Which city and state do you live in, sir? 16 A. Metairie, Louisiana. 17 Q. What is your current occupation, business, or employment? 18 A. I own an industrial marine supply company. 19 Q. What is the name of that company? 20 A. Shipyard Supply. 21 Q. How long have you owned that? 22 A. Twelve years. 23 Q. Where is that company located? 24 A. Located in Metairie, Louisiana, and Theodore, Alabama. 25 Q. Where did you go to college? WICKERSHAM - DIRECT EXAMINATION 1 A. Louisiana State. 2 Q. Did you play football there? 3 A. Yes, I did. 4 Q. What position? 5 A. I played quarterback. 6 THE COURT: I bet you were unhappy the other day. 7 THE WITNESS: Yes, I was. 8 BY MR. SCHMID: 9 Q. Did you play any football with the NFL? 10 A. I played with the Miami Dolphins for a year and then I 11 played up in Canada for two years after that. 12 Q. Very good. 13 A. Yes, sir. 14 Q. How long have you been hunting? 15 A. Probably since I was 15 or so. 16 Q. Have you ever hunted white-tailed deer? 17 A. Yes. 18 Q. Have you ever hunted at a place called Tara Wildlife or 19 Willow Point? 20 A. Yes, I have. 21 Q. How many years have you hunted there? 22 A. Probably five or six now. 23 Q. Is that a high-fenced facility or not? 24 A. No, it's not. 25 Q. Did you ever hear of a place called Bellar's Place? Are you a hunter? 4 WICKERSHAM - DIRECT EXAMINATION 5 1 A. Yes. 2 Q. Did you ever check out Bellar's Place's website? 3 A. Yes, I did. 4 Q. Was there a point in time when, after checking the website, 5 that you called Bellar's Place to inquire about a hunt? 6 A. Yes. 7 Q. Do you remember when that was approximately? 8 A. I don't remember exactly. 9 made the hunt. Probably in the summer before I 10 Q. Did you go up there in the late fall or early winter of 11 2003 to hunt? 12 A. Yes, November. 13 Q. Did you go up there with anybody that you knew? 14 A. Yes, Tom Fremin. 15 Q. What was Mr. Fremin's relationship with you? 16 A. We're just hunting buddies, friends. 17 Q. Have you known him for a number of years? 18 A. Yes. 19 Q. Did you have to put any kind of deposit down for your hunt 20 at Bellar's Place? 21 A. Yes, we did. 22 Q. Do you remember how much that was, sir? 23 A. I believe that was 1,500 a person. 24 Q. For a total of $3,000 for the two of you? 25 A. That's correct. I've known him for about ten years. WICKERSHAM - DIRECT EXAMINATION 6 1 Q. In November of 2003, did you fly up to Indiana? 2 A. Yes, we did. 3 Q. Did you take a commercial flight or a private plane? 4 A. Commercial. 5 Q. What airport did you fly into, if you remember? 6 A. Indianapolis. 7 Q. Did you stay overnight at a hotel before arriving at 8 Bellar's Place? 9 A. Yes, we did. 10 Q. Do you remember what date that was approximately, if you 11 remember? 12 A. 13 I'm not sure. 14 Q. 15 Place after staying the night in a hotel? 16 A. That's correct. 17 Q. When you got to Bellar's Place, who did you meet with? 18 was there? 19 A. 20 in with, and Mr. Bellar was there and several other people were 21 around. 22 Q. 23 at Bellar's Place? 24 A. Yes. 25 Q. Was Mr. Bellar at the lodge while you were there? Not exactly. I think it was November 5th or something. And I assume that at some point you arrived at Bellar's We went the next morning. Who Tom Jones was there, who we originally met with and signed Did you see the lodge that they had on the property there That's where we stayed. WICKERSHAM - DIRECT EXAMINATION 1 A. Yes, he was. 2 Q. Did you have any discussions with Mr. Bellar when you were 3 at the lodge? 4 A. 5 from there. 6 Q. 7 the facility or property in any way? 8 A. 9 7 afternoon hunt and looked at some of the breeding facilities Not initially. We just checked in with Tom and then went Did they take you on any kind of a tour or examination of It wasn't really a tour. We did walk around before our 10 and some of the deer they had there. 11 Q. 12 or the need to get a license? 13 A. 14 did that before we made the hunt. 15 Q. And who told you that specifically? 16 A. Tom Jones. 17 Q. Did you get a license? 18 A. Yes, sir. Very good. Yes. Did anyone discuss with you getting a license We were told we could get our licenses online and we 19 MR. SCHMID: 20 THE COURT: Your Honor, may I approach the witness? Sure. 21 BY MR. SCHMID: 22 Q. 23 Exhibit 126. 24 A. Yes, I do. 25 Q. Is that the hunting license you obtained for your hunt at Let me show you, sir, what's been marked as Government Do you recognize your signature on that document? WICKERSHAM - DIRECT EXAMINATION 1 Bellar's Place in Indiana? 2 A. 8 Yes, it is. 3 4 MR. SCHMID: Your Honor, I would move the admission of Government Exhibit 126 at this time. 5 MR. VOYLES: 6 THE COURT: 7 MR. VOYLES: 8 THE COURT: 9 MR. SCHMID: 10 No objection, Your Honor. 126, that's the number? Yes, sir. It's admitted. If I could have the jury monitors on. (Jury monitors on.) 11 BY MR. SCHMID: 12 Q. Did you go out hunting that first day? 13 A. Yes. 14 Q. Did you get anything? 15 A. No, I didn't. 16 Q. Later that day, did you have any discussions with anyone 17 about specific deer or white-tailed bucks? 18 A. 19 evening — I was shown a picture of a big deer and was asked if 20 I wanted to hunt that deer. 21 Q. 22 asked if you wanted to hunt that deer? 23 A. 24 the deer in it. 25 Q. Yes. We went out that afternoon. Later on after that hunt — I believe it was that Who was it that showed you a picture of the big deer and It was Russ and Tom, showed me a magazine with a picture of So that would be Mr. Bellar and Mr. Tom Jones together? WICKERSHAM - DIRECT EXAMINATION 1 A. That's correct. 2 Q. Do you see Mr. Bellar in court here today? 3 A. Yes, I do. 4 Q. Could you point him out, please. 5 A. 9 Sitting in the middle (indicating). 6 MR. SCHMID: Let the record reflect that the witness 7 has identified the defendant, Russell Bellar. 8 Q. 9 particular deer? What did they offer you or say to you about hunting that 10 A. They just gave me a price and I agreed to it. 11 Q. Who was the person that quoted you the price on that 12 specific deer? 13 A. Mr. Bellar. 14 Q. What was the price that Mr. Bellar quoted you to hunt this 15 specific deer? 16 A. $20,000. 17 Q. And they had showed you a picture of that deer; is that 18 correct? 19 A. That's correct. 20 Q. And you agreed to it? 21 A. Yes, I did. 22 Q. Now, was the deer out in the pens or was it someplace else 23 or — let me ask a single question. 24 25 What did Mr. Bellar tell you about the location of the deer? WICKERSHAM - DIRECT EXAMINATION 10 1 A. He said that he was on another farm of his. 2 Q. Would the deer have to be moved in order for you to hunt 3 it? 4 A. He said he would have him there the next day. 5 Q. I take it at some point you got some sleep, went to sleep 6 in a room somewhere? 7 A. That's correct, in the lodge. 8 Q. You got up the next morning? 9 A. Yes. 10 Q. Did you see any kind of trailer outside the facility after 11 you got up in the morning? 12 A. Yes. 13 Q. Could you describe that kind of trailer as best you can. 14 A. It looked kind of like a horse trailer that was enclosed. 15 Q. Was it a single horse trailer or was it a multi-horse 16 trailer with enclosed — 17 A. 18 regular single one. 19 Q. Did anyone say anything to you about what was inside of it? 20 A. They said the deer was in there. 21 Q. Who said that to you? 22 A. I believe that was Tom. 23 Q. Did you have an opportunity to look at the deer you were 24 going to hunt while it was still in the trailer? 25 A. I'm not real sure, but I think it was bigger than just a Yes, I did. I'm not exactly positive. WICKERSHAM - DIRECT EXAMINATION 11 1 Q. Did it look like the deer that you had seen in the 2 photograph shown to you the evening before by Mr. Jones and 3 Mr. Bellar? 4 A. Yes. 5 Q. What was the number of points on the horns that they told 6 you that this specific deer that you were going to hunt had; do 7 you remember the number? 8 A. 9 showed me the deer. They didn't give me the specific points when they first They told me it scored probably around 10 215. 11 Q. 12 of the rack? 13 A. Yes. 14 Q. Did you go to a place then in order to hunt this particular 15 deer? 16 A. Yes. 17 Q. Did you hunt from the ground or did you climb up in a tree 18 stand? 19 A. Climbed up in a tree stand. 20 Q. What was the weapon or means by which you hunted the deer? 21 A. Bow and arrow. 22 Q. Bow and arrow. 23 hunt — accompany you? 24 A. Yes, he did. 25 Q. Before you actually started hunting the deer, did you see $20,000 is a lot for a deer. Is that because of the size I went to a pen to hunt it. Did a videographer — a person to video the WICKERSHAM - DIRECT EXAMINATION 12 1 the deer moved from the trailer into the pen where you were 2 located? 3 A. Yes. 4 Q. What did you see as far as the deer being moved toward the 5 pen? 6 A. 7 out of the pen and then ran down a narrow passageway into the 8 bigger pen where I was. 9 Q. Were there fences or gates along that narrow passageway? 10 A. Yes, there were. 11 Q. Was that leading into smaller breeder pens? 12 A. Yes. 13 Q. You were already up in the tree and you could see this? 14 A. That's correct. 15 Q. Did anyone assist with helping to move the deer down the 16 corridor that you observed before you started hunting? 17 A. 18 trailer and started coming down there. 19 Q. 20 were located? 21 A. Yes, I did. 22 Q. Did you kill the deer immediately? 23 A. No. 24 Q. What happened that you saw with respect to the deer and 25 you? I was up in the tree before the deer was moved. They let him out in a narrow way from the front, and he got I don't think they had to. Okay. He got out of the back of the Did you see the deer come into the pen where you WICKERSHAM - DIRECT EXAMINATION 1 A. 2 there. 3 farthest away from where I was and kind of stayed there with 4 the rest of the deer. 5 Q. 6 shot at him? 7 A. Yeah, much further. 8 Q. Okay. 9 13 He came in the pen, and then there were some other deer in far as the deer being moved or whatever? He ran around and basically ran to the back of the pen So he was a little bit further away than you could get a How long passed before something else happened as 10 A. It was probably about ten minutes to see if he was going to 11 stay there or come back closer to where I was. 12 Q. He wasn't moving closer to where you were? 13 A. That's correct. 14 Q. Did you see anybody inside the pen besides you and the 15 videographer that assisted you with the hunt? 16 A. Yes. 17 Q. Who were those people? 18 A. Mr. Bellar, it looked like a Mexican guy, and Tom Jones. 19 Q. Did they do anything in the pen while you were up in the 20 tree stand? 21 A. 22 that area. 23 Q. Was that all three of them that assisted with that? 24 A. Yes. 25 Q. After a period of time, was there a chance for you to get They would walk towards the deer to get him to move out of WICKERSHAM - DIRECT EXAMINATION 14 1 off a shot with your bow and arrow? 2 A. Yes. 3 Q. Did you shoot the deer with your bow and arrow? 4 A. Yes, I did. 5 Q. How long passed from the time that you started to hunt from 6 the tree stand and the deer was in the pen until you were 7 actually able to get off a shot and kill the deer with your bow 8 and arrow? 9 A. I would say approximately 30, 40 minutes. 10 Q. How long were Mr. Bellar and Mr. Jones and the Mexican 11 helper in the pen with you helping to move the deer, 12 approximately? 13 A. 14 so they were there about 30 minutes or so. 15 Q. Did Mr. Bellar see you hunt the specific deer? 16 A. I'm sure he did, yeah. 17 Q. Did you have a chance to have any still photographs taken 18 with the deer after you went down to it? 19 A. Yes, I did. 20 Q. Let me show you some photographs that have been marked in 21 evidence already from Government Exhibit 121 which was 22 introduced yesterday. 23 Is it? 24 A. Yes. 25 Q. Is that the deer you were able to hunt in that pen Probably about ten minutes after I originally got in there, That looks like you (indicating), sir. WICKERSHAM - DIRECT EXAMINATION 1 (indicating)? 2 A. Yes, it is. 3 Q. Is this another similar photo (indicating)? 4 A. Yes. 5 Q. Now, here's some photos. 6 A. Yes, they are. 7 Q. Is that the same deer (indicating)? 8 A. Yes, it is. 9 Q. It looks like you have a shirt on at that point over your 15 Are those photos of you as well? 10 camouflage hunter clothing; is that correct? 11 A. Yes, it is. 12 Q. Did they give you that shirt to put on? 13 A. Yes, they did. 14 Q. Was Mr. Bellar present while these photographs were being 15 taken with you and the deer? 16 A. I can't remember. 17 Q. Okay. 18 A. It said Rack Attract. 19 Q. Did you also have a cap on that said Rack Attract? 20 A. Yes, I did. 21 Q. Let me cut down on some of this glare. 22 I think he was, but I can't be sure. Do you remember what it said on the shirt? There we go. Was the deer scored eventually, Mr. Wickersham? 23 A. Yes, it was. 24 Q. Do you remember what the deer scored? 25 A. 234 and five-eighths. WICKERSHAM - DIRECT EXAMINATION 16 1 Q. Was that the largest deer — white-tailed deer that you had 2 hunted up to that point? 3 A. Yes. 4 Q. Do you remember what happened to the deer after you were 5 able to take him as you described? 6 A. 7 him back to near the lodge. 8 Q. 9 and the meat from the deer, if you remember? They loaded him up on a — like a wagon-type deal and took What happened to the antlers and the cape, or the deerskin, 10 A. They processed — took care of that for me and then shipped 11 it to me in Louisiana. 12 Q. 13 been marked as Government Exhibit Number 129. Okay. 14 Let me show you a plastic container, blue. It's Do you recognize this? 15 A. Yes, I do. 16 Q. What is it, sir? 17 A. It's a container that had my deer in it. 18 Q. So this had both the antlers and the cape in it? 19 A. Yes, it did. 20 Q. Was this shipped to you from Bellar's Place to Metairie, 21 Louisiana? 22 A. Yes, it was. 23 Q. Okay. 24 25 MR. SCHMID: Your Honor, I would introduce into evidence at this point Government Exhibit 129. WICKERSHAM - DIRECT EXAMINATION 1 2 MR. VOYLES: To clarify with the witness, this was just the antlers and the cape? 3 THE WITNESS: 4 MR. VOYLES: 5 That's correct. We have no objection to Government Exhibit 129, Your Honor. 6 THE COURT: 7 MR. SCHMID: 8 17 129 is admitted. Your Honor, I would ask your permission to just walk this in front of the jury. 9 THE COURT: Just don't fall down. 10 MR. SCHMID: Thank you. 11 (Exhibit displayed to the jury.) 12 MR. SCHMID: Thank you, Your Honor. 13 Q. Mr. Fremin, did he hunt as well on this trip? 14 A. Yes, he did. 15 Q. Did he also have an opportunity to kill and take a buck at 16 Bellar's Place? 17 A. Yes, he did. 18 Q. Do you know how much he paid for his deer? 19 A. I believe his was 9,000. 20 Q. Did he hunt his in a pen as well? 21 A. Yes, he did. 22 Q. Was his pen about the same size as the pen that you were 23 in? 24 A. I would say approximately. 25 Q. But it was a different pen though? WICKERSHAM - DIRECT EXAMINATION 1 A. Yes, it was. 2 Q. Did you pay for both your deer and Mr. Fremin's deer? 3 A. Yes, I did. 4 Q. Let me show you some checks that have been marked as a 5 group exhibit, Exhibit 127. 18 6 There are three checks. Do you recognize these checks, sir, and do you 7 recognize your signature on two of the three of them? 8 A. Yes, I do. 9 Q. And is that your signature on the check for 32,500? 10 A. Yes, it is. 11 Q. And the 3,000? 12 A. Correct. 13 Q. Whose signature is on the check for $150.45? 14 A. That's a guy that works with me. 15 Q. Okay. 16 17 MR. SCHMID: Government Exhibit 127. 18 19 Your Honor, I would move into evidence MR. VOYLES: Judge, I have no objection to Government Exhibit 127. 20 THE COURT: 127 is admitted. 21 BY MR. SCHMID: 22 Q. 23 that correct? 24 A. That's correct. 25 Q. So the 32,500 was not only for your deer of 20,000, but Shipyard Supply is your company? You own that company; is WICKERSHAM - DIRECT EXAMINATION 19 1 Mr. Fremin's deer of 9,000 as well? 2 A. That's correct. 3 Q. And this check for — and that was dated 11-8-03, so just 4 after the hunt? 5 A. Yes. 6 Q. And then this check dated a few months before, 7 February 27th, 2003, was that the deposit for your and 8 Mr. Fremin's hunt at Bellar's Place? 9 A. Yes, it was. 10 Q. And this check a little later in November of 2003, do you 11 remember what that was for that's made out to Bellar's? 12 A. 13 something. 14 Q. It's much less. 15 A. Right. 16 Q. When the antlers and cape were sent down to Metairie, 17 Louisiana, in this blue container, what did you do with them at 18 that point? 19 A. I brought them to a taxidermist. 20 Q. And were they mounted for you? 21 A. Yes. 22 Q. What happened to the meat from the deer? 23 A. They took — after I killed it, Tom brought me a brochure 24 and asked if I wanted to get it processed, and I told them, 25 yeah, get it processed there and just ship it to me. That was when we left that day. I guess that was for freight for sending the deer or It's $150? WICKERSHAM - DIRECT EXAMINATION 1 Q. Was the meat shipped to you in Louisiana as well? 2 A. It was shipped to Tom Fremin's. 3 Q. Is he in Louisiana? 4 A. Yes. 5 Q. What business is Mr. Fremin in? 6 A. He owns an auto body shop. 7 Q. Do you do business with him in connection with your 8 company? 9 A. Yes. 10 Q. Did you see any feeders on the property at Bellar's Place 11 while you were there? 12 A. Yes. 13 Q. Did Mr. Bellar tell you what was in those? 14 A. Protein pellets. 15 Q. And at any point did you receive a video of your hunt? 16 A. Yes, I did. 17 Q. Was that shipped to you down in Louisiana as well? 18 A. Yes, it was. 19 Q. What month and year was that, if you remember? 20 A. I don't remember, to tell you the truth. 21 in January of the following year, January or February. 22 Q. 23 everything, did you receive a call from anybody to hear about 24 something that was happening at Bellar's Place? 25 A. 20 Okay. Yes. It was probably After your hunt and after you got the video and I received a call from Bill Molleur (phonetic) of the WICKERSHAM - DIRECT EXAMINATION 21 1 Wildlife & Fisheries. 2 Q. 3 you talk to anybody about what was happening in connection with 4 Bellar's Place? 5 A. Yes. 6 Q. That was on what date, if you remember? 7 A. I can't recall the exact date. 8 the call from Bill. 9 Q. Do you recall the month, approximately? 10 A. I can't remember exactly the month. 11 Q. Did Tom and Russ tell you about the execution of search 12 warrants at Bellar's Place? 13 A. 14 that there was an investigation going on and that they really 15 couldn't talk about it. 16 Q. 17 investigators who might talk to you — make sure to tell them 18 something? 19 A. 20 know that I was just hunting deer. 21 Q. 22 number of deer you were to say was in the pen? 23 A. 24 specific deer. 25 Q. As a result of receiving that call from Bill Molleur, did No. I talked to Tom and Russ. It was right after I got They really didn't tell me too much. They told me Did Mr. Bellar ask you to make sure and tell the Yeah. He just told me to cooperate with them and let them Did he ask you to say anything more specific about the He just wanted to make sure that we weren't hunting a Okay. Were you hunting a specific deer, though, sir? WICKERSHAM - DIRECT EXAMINATION 22 1 A. Yes. I was there to hunt that specific deer (indicating). 2 Q. But Mr. Bellar was telling you to tell the investigators 3 something different than that? 4 A. 5 cooperate with them and let them know that, you know, there was 6 more deer in the pen than just that one. 7 Q. 8 that pen? 9 A. Well, he didn't really tell me that. He just said to Were there other big bucks that you were going to shoot in There was another big buck in there, but I wasn't going to 10 shoot it. 11 Q. 12 were going to shoot? 13 A. That's correct. 14 Q. When Mr. Bellar and Tom Jones and the helper were in the 15 pen, were they trying to shoo that other buck toward you or 16 just the one you had picked out the night before? 17 A. Just the one I had picked out. 18 Q. Were you in kind of a rush to get back on the last day that 19 you were at Bellar's Place? 20 A. Yes, we were. 21 Q. Who was the last person to be hunting between you and Tom 22 Fremin? 23 A. Tom Fremin was. 24 Q. As a result of being in a little rush, did you have to have 25 your bow and arrow shipped back as well? You knew ahead of time from the photograph which one you WICKERSHAM - DIRECT EXAMINATION 23 1 A. Yes, we did. 2 Q. Were you contacted by anyone to obtain any remaining meat 3 that you had from the deer that you hunted at Bellar's Place? 4 A. 5 then shipped to me COD. 6 Q. 7 your freezer or something? 8 A. Yes, I did. 9 Q. Was there a point in time when a law enforcement officer They said that they were going to have it processed and And after it got to you COD from Indiana, did you put it in 10 asked you to provide that meat to him? 11 A. Yes, there was. 12 Q. Did you provide the meat from the deer that you shot at 13 Bellar's Place to that law enforcement officer? 14 A. Yes, I did. 15 MR. SCHMID: 16 Thank you. 17 THE COURT: 18 MR. VOYLES: 19 his pin in. 20 Your Honor, I have nothing further. Cross-examine. May it please the Court? in for him. 21 22 I was going to remind him. He has to put MR. SCHMID: I was going to put it They're laughing at me, Mr. Wickersham; not you. 23 THE COURT: 24 then you can cross-examine him. 25 MR. VOYLES: Let him have his moment in the sun and That's fine, Your Honor. WICKERSHAM - CROSS-EXAMINATION 1 BY MR. SCHMID: 2 Q. 3 work in Metairie and where the deer from Bellar's Place was 4 shipped to you. 5 A. (Witness complies.) 6 Q. 24 Thank you, sir. I would ask you to put a pin in the area where you live and 7 CROSS-EXAMINATION 8 BY MR. VOYLES: 9 Q. Good morning, Mr. Wickersham. 10 A. Good morning. 11 Q. My name is Jim Voyles. 12 Mr. Bellar. 13 I am one of the attorneys for My understanding is that you were acquainted with 14 Tom Jones before you came to Bellar's Place; is that right? 15 A. That's correct. 16 Q. And that relationship went back how many years? 17 A. Probably four or five. 18 Q. And it was a result of him being a hunting guide at another 19 location? 20 A. That's correct. 21 Q. And was it Willow Point? 22 A. That's correct. 23 Q. And you would hunt white-tailed deer there? 24 A. Yes, we did. 25 Q. And had hunted there for a number of years? WICKERSHAM - CROSS-EXAMINATION 25 1 A. That's right. 2 Q. Did you know that Mr. Jones had left and gone to Bellar's 3 Place when you first were using the Internet to look up places 4 to hunt? 5 A. Yes, I did. 6 Q. How did you know that? 7 A. Tom Jones contacted me. 8 Q. So he called you? 9 A. Yes. 10 Q. Would it be fair to say that in the conversation that you 11 learned from Mr. Jones that he was contacting a number of 12 people that had been on his, say, client list, people that had 13 hunted with him before? 14 A. Yes, that's correct. 15 Q. And you were one of those? 16 A. Yes, that's correct. 17 Q. And was Mr. Fremin also one of those? 18 A. Yes, he was. 19 Q. Was it common practice for hunters when they have a 20 successful hunt — or maybe even when they don't have a 21 successful hunt — to tip a guide? 22 A. Yes, it is. 23 Q. What's the normal amount that you would tip a guide? 24 A. On a three-day hunt, I'd normally tip around $300. 25 Q. Was that true of Mr. Jones, that you had treated him in WICKERSHAM - CROSS-EXAMINATION 26 1 that way during the period that you had hunted with him? 2 A. Yes. 3 Q. Now, you indicated — after he called you, did he send you a 4 brochure or did he direct you to an Internet site to look at 5 the place where he was now? 6 A. Yes. 7 Q. And that would have been, you said, the early part of 2003? 8 A. Yeah, I'm most positive. 9 Q. When you saw the site, was it your interest then to hunt in 10 that area? 11 A. Yes, it was. 12 Q. Did you also tell your friend, Mr. Fremin, about it? 13 A. Yes, I did. 14 Q. Did you arrange then with Mr. Jones to what I assume would 15 be to set up a hunting date? 16 A. That's correct. 17 Q. And your schedule permitted you to hunt in this period of 18 time in November? 19 A. That's right. 20 Q. And I noticed from the government exhibit, you sent your 21 deposit well in advance, so it was like in February of 2003? 22 A. That's right. 23 Q. Now, when you went to Bellar's Place, was it the first time 24 you hunted in a high-fenced area? 25 A. No, it wasn't. WICKERSHAM - CROSS-EXAMINATION 27 1 Q. Where else have you hunted in a high-fenced area? 2 A. Triple Seven Ranch in Texas. 3 Q. How big is that place? 4 A. I think that's 16,000 acres. 5 Q. Do you hunt specific deer there? 6 A. Yes. 7 Q. So how many times have you been to this ranch in Texas 8 where you hunted? 9 A. One time. 10 Q. Now, when you came up to Bellar's Place, I think in direct 11 examination you said you flew into Indianapolis and then made 12 your way up to Peru; is that correct? 13 A. 14 then checked into Bellar's the next morning. 15 Q. About when did you get there? 16 A. Around 9:30, 10:00 in the morning. 17 Q. When you got there, did Mr. Jones meet you? 18 A. Yes, he did. 19 Q. You said you kind of walked the place. 20 Mr. Jones? 21 A. Yes, and Tommy and I walked a little bit by ourselves. 22 Q. Okay. 23 A. Yes, that's correct. 24 Q. Describe the place as you saw it. 25 A. A beautiful place. That's correct. We stayed in a hotel room that night and Was that with Mr. Fremin, the other Tom? It had a lot of separate pens where WICKERSHAM - CROSS-EXAMINATION 28 1 they were breeding deer. They'd have, you know, ten or twelve 2 does in there with one buck, set up side by side, and we just 3 took a tour around. 4 Q. 5 how many acres they had there under fence? 6 A. I think they had 800 acres. 7 Q. Now, when you got to the lodge that night, you didn't hunt 8 that first day you got there? 9 A. Yes, we did. 10 Q. Okay. 11 A. That's correct. 12 Q. What area were you hunting? 13 A. I don't know exactly what area, but it was the bigger 14 fenced-in area. 15 Q. Is that the area without a lot of trees? 16 A. No. 17 there's a lot of crops, looks like fields. 18 Q. More crops than there are trees; is that right? 19 A. Yes. 20 Q. But you, in fact, were in a tree stand? 21 A. Yes, we were in the woods. 22 Q. Is that kind of the common practice to hunt; that way the 23 deer come to you? 24 A. Yes. 25 Q. Now, you indicated that evening you went to the lodge; is A very nice lodge. Could you estimate or did Tom Jones indicate to you about We hunted that afternoon. I think you indicated you were unsuccessful? I was hunting out of a tree, but it is an area where WICKERSHAM - CROSS-EXAMINATION 29 1 that right? 2 A. That's right. 3 Q. Were there other people in the lodge that night beside 4 yourself? 5 A. Yes, there were. 6 Q. Other hunters? 7 A. Yes. 8 Q. I think you described it as a rather nice facility? 9 A. Very nice. 10 Q. You mentioned early in direct examination that you had an 11 opportunity to go down into the lower part of the lodge or at 12 least look at the breeding facilities that were there; is that 13 right? 14 A. That's right. 15 Q. Did you visit the lower part of the lodge? 16 A. Yes. 17 Q. What did you see there? 18 A. They had some deer heads in there from previous hunts that 19 hunters had taken. 20 Q. 21 areas where the breeding kind of takes place and the semen 22 collection? 23 A. Yes, sir. 24 Q. Did it appear to be a nice operation? 25 A. Very nice. Did you also see areas where breeding — did Tom show you WICKERSHAM - CROSS-EXAMINATION 30 1 Q. Then at some point that evening you had a conversation with 2 Tom and you mentioned my client, Mr. Bellar? 3 A. Uh-huh. 4 Q. And you also said that you had been shown a brochure? 5 A. It was a magazine. 6 Q. It was a magazine? 7 A. Yes, sir. 8 Q. What kind of magazine? 9 A. I didn't really — 10 Q. Outdoor Life, or something like that? 11 A. No, I don't think it was that. 12 deer magazine. 13 the cover, but it had pictures of different deer in it. 14 Q. 15 just kind of a — because the magazines — they have all kinds of 16 hunting and fishing magazines in the lodge, don't they? 17 A. Yes. 18 Q. It was a national publication of some sort or a deer 19 publication of some sort? 20 A. Some type of deer publication. 21 Q. And while you are kind of looking through that magazine, 22 you find or see a deer that gets your attention? 23 A. They actually brought it to me and showed me this deer. 24 Q. In that magazine? 25 A. That's correct. Okay. I think it was some type of I don't remember the name. I don't remember But it wasn't anything from Bellar's Place; it was It wasn't a Bellar's magazine. WICKERSHAM - CROSS-EXAMINATION 31 1 Q. But it was a magazine — not a Bellar's Place magazine? 2 A. That's correct. 3 Q. And they said, "Would you like to get a deer about looking 4 like that"; is that correct? 5 A. That's correct. 6 Q. As a result of that, you said, "Yes"? 7 A. That's correct. 8 Q. You were interested in getting a big buck; that's why you 9 were there? 10 A. That's correct. 11 Q. Tom had told you that, that he wanted you to have a good 12 hunting experience? 13 A. Sure. 14 Q. So the next day you get up, and at that point you hear or 15 at least see a trailer that's outside the facility? 16 A. Yes, there was. 17 Q. And when you look in it, you see a large buck? 18 A. That's correct. 19 Q. And it has a lot of points? 20 A. Yes. 21 Q. And you then make arrangements to go on out into the field? 22 A. Yes. 23 Q. The hunting area? 24 A. We had made arrangements the prior evening. 25 Q. Okay. Now, you had gone and walked around that place WICKERSHAM - CROSS-EXAMINATION 32 1 before and a lot of the tree stands are in these pens that are 2 four, five, six-acre plots, aren't they? 3 A. 4 that there were a lot of breeding pens there, yes. 5 Q. 6 stands in the breeding pens, were there? 7 A. Not that I noticed. 8 Q. And the tree stands that were in place were in the hunting 9 areas, correct? I didn't notice a lot of tree stands in them, but I noticed Did you also notice that there — so there weren't any tree 10 A. That's right. 11 Q. And those areas — the large area and then there are smaller 12 areas that run three to five acres; is that correct? 13 A. That's correct. 14 Q. You were in one of those three- to five-acre facilities? 15 A. Yes, I was. 16 Q. And I notice in the photograph that's part of the 17 government exhibits that were previously introduced yesterday, 18 your hunting photograph, that it would appear to be that there 19 are a lot of trees in that area (indicating); is that correct? 20 A. Yes, there was. 21 Q. Now, when you went into this acreage to hunt the deer, you 22 indicated there were a number of deer already in there, does; 23 is that right? 24 A. Yes, that's right. 25 Q. And you also indicated there was another buck in there? WICKERSHAM - CROSS-EXAMINATION 1 A. That's correct. 2 Q. But it wasn't a buck as large as the one you were 3 interested in? 4 A. That's correct. 5 Q. How big was it? 6 A. The buck that was in there? 7 Q. Yes. 8 A. He'd probably score 150 or so. 9 Q. Okay. 33 When you talk about scoring, kind of remind us what 10 that means. 11 A. It means inches of antler on the deer. 12 Q. Across? 13 A. You measure several different — 14 Q. You measure the width and height and all that kind of 15 stuff? 16 A. That's correct, yes. 17 Q. So then at some point you see a deer that's bigger than 18 that and it's coming through this area and it's being let out 19 into this acreage where you are? 20 A. Yes, sir. 21 Q. Once it's in that acreage, it kind of starts to mingle with 22 the other deer? 23 A. That's correct. 24 Q. As a matter of fact, goes to the end of the acreage, what, 25 maybe an acre or two away from you? WICKERSHAM - CROSS-EXAMINATION 34 1 A. Something like that, yes. 2 Q. Outside your shooting range? 3 A. That's correct. 4 Q. At some point you see individuals, and you have identified 5 at least a Hispanic man and also Tom Jones, your friend — 6 correct? 7 A. That's correct. 8 Q. — who's kind of in that acreage. 9 Mr. Bellar there; is that correct? You also thought you saw 10 A. Yes. 11 Q. They're just kind of walking in the area? 12 A. They're walking to get the deer moving from just sitting in 13 one place. 14 Q. 15 bucks? 16 A. 17 close to them they would run off and kind of scatter and kind 18 of end up back in the same place together. 19 Q. They kind of always group together at some point? 20 A. Yes. 21 Q. Run away and then get back together? 22 A. Yes, they did. 23 Q. Kind of like people. 24 25 Were all of the deer kind of congregated around the two They would be in the same place, and then when they got Once they were together, is that when you see people walking in the acreage? WICKERSHAM - CROSS-EXAMINATION Yes. 35 1 A. 2 walk and try to get them to move around and not just sit in one 3 place. 4 Q. Now, your video person is above you? 5 A. That's correct. 6 Q. At some point then this one deer that you're interested in 7 comes out of the particular group and comes close enough for 8 you to make your hunt? 9 A. That's correct. 10 Q. And you do shoot the deer and the deer dies? 11 A. Yes, I did. 12 Q. And then these pictures are taken at that point 13 (indicating)? 14 A. 15 following morning I had some more taken. 16 Q. 17 next morning? 18 A. 19 taken. 20 Q. As a matter of fact, aren't they — 21 A. Yes, those they were the next morning. 22 Q. Right. 23 next day. 24 didn't he, and he gave you that shirt? 25 A. Yes. If they were out of my bow range, then they would We had pictures taken immediately after and then the The pictures that you have with the T-shirt, are they the I believe they were. Yes. I'm not exactly sure when those were This isn't the same day (indicating); that's the And Mr. Jones had you go pose for that picture, WICKERSHAM - CROSS-EXAMINATION 36 1 Q. And he gave you that hat? 2 A. Yes. 3 Q. You didn't get that from Mr. Bellar, did you? 4 A. No. 5 Q. Did Mr. Jones tell you he had an interest in that company, 6 that he was a part owner or vice president of that company? 7 A. He indicated he had some type of ownership in Rack Attract. 8 Q. And wanted you to help advertise it for him? 9 A. Yeah, asked me if I wouldn't mind taking a few pictures 10 with the hat and shirt on. 11 Q. 12 promotional matters for himself? 13 A. Yes, he did. 14 Q. Didn't mention Mr. Bellar, did he? 15 A. No, he didn't. 16 Q. Now, on that particular trip, you spent a lot of money 17 because you paid for Mr. Fremin's deer and you paid for your 18 own deer? 19 A. That's correct. 20 Q. Did you give Mr. Jones a pretty good tip? 21 A. Yes, I did. 22 Q. How much? 23 A. 500. 24 Q. Was that cash? 25 A. Yes, it was. Did he tell you he was going to use those pictures for WICKERSHAM - CROSS-EXAMINATION 37 1 Q. That is generally done after the hunt? 2 A. That's correct. 3 Q. Now, you indicated in your questions by Mr. Schmid on 4 your direct that you kind of had to leave in a hurry, that you 5 had an appointment or had business arrangements or something 6 and you had to leave quickly; is that correct? 7 A. Yes, sir. 8 Q. Okay. 9 hunting equipment with you? To the point you weren't even able to take your 10 A. That's correct. We left our bows because they would take 11 too long to check in. 12 Q. 13 you some kind of brochure about processing? 14 A. That's correct. 15 Q. And that he would — and he suggested to just leave your 16 meat; is that correct? 17 A. That's correct. 18 Q. And so the only thing that you got when you testified about 19 Government Exhibit 129 — that's that blue Walmart thing back 20 here that came to you (indicating) — it only had the cape and 21 the antlers in it? 22 A. That's correct. 23 Q. The meat didn't come to you at all, did it? 24 A. No. 25 Q. It was never sent to you in any way? Now, when you did — you said it was Mr. Jones that showed It went to Tom Fremin's office. WICKERSHAM - CROSS-EXAMINATION 1 A. Not sent to me. I went and picked it up at Tom's office. 2 Q. And it went to his auto place; is that right? 3 A. That's correct. 4 Q. When you went and picked it up, when was that? 5 A. I believe I sent one of my guys over there to pick it up 6 the same day that Tom received it. 7 Q. Who would that have been? 8 A. I don't remember exactly. 9 Q. Somebody that works for you? 10 A. One of my drivers, yes. 11 Q. When you got it, did you open it? 12 A. Yes, I did. 13 Q. What was in it? 14 A. Deer sticks. 15 Q. What do they look like? 16 A. Kind of like a little beef jerky. 17 Q. Are they packaged like hot dogs? 18 A. Similar, yes. 19 Q. Did you open them and have some? 20 A. Yes, I did. 21 Q. Once you had it, what did you do with it? 22 A. I put them in the freezer. 23 Q. There at your home? 24 A. At Shipyard Supply. 25 Q. So you kept it at your business? 38 WICKERSHAM - CROSS-EXAMINATION 1 A. That's correct. 2 Q. Did it ever go back to Mr. Fremin's? 3 A. No. 4 Q. What kind of container was it in when you picked it up? 5 A. It was in some coolers. 6 looked like. 7 Q. Were they coolers that Mr. Fremin had put them in? 8 A. No. 9 39 shipped it. I don't remember exactly what they They were coolers that came from the packager, whoever 10 Q. You have no idea who shipped it to you? 11 A. No. 12 Q. Then the coolers stayed in your business coolers; in other 13 words, you got the coolers that the meat is in and then the 14 coolers that you put it in or the freezer that you put it in? 15 A. 16 freezer. 17 Q. Did you continue to eat from those? 18 A. Yes. 19 Q. Now, when Mr. Bellar had a conversation with you — I think 20 both individuals, you said, Mr. Jones and Mr. Bellar, talked to 21 you after this investigation had started. 22 together; that was separate calls? 23 A. Yes, sir. 24 Q. Okay. 25 A. Yes, he did. Yeah. I took them out of those coolers and put them in my They weren't Mr. Bellar told you to cooperate? WICKERSHAM - CROSS-EXAMINATION 1 Q. 2 were other deer in there; not that you wouldn't remember that 3 because you did? 4 A. 40 Mr. Bellar indicated and made sure to remind you that there That's correct. 5 MR. VOYLES: 6 THE COURT: 7 (Brief pause in the proceedings.) 8 Q. Sure. BY MR. VOYLES: 9 Can I have a moment, Your Honor? I think it was a direct examination question that you 10 didn't give the meat to law enforcement, you personally? 11 A. Yes, I did. 12 Q. Someone else didn't get it for you? 13 A. No. 14 Q. From you personally? 15 A. That's correct — no, not from me. 16 my office. 17 Q. 18 personally given by you to any agent, but someone else in your 19 business did it; is that correct? 20 A. 21 and picked it up. 22 Mr. Molleur several times, and I can't remember if I brought 23 him the meat or if he came by my shop to pick it up. 24 Q. 25 for you? He came and picked it up at my shop. That's my question. I apologize. From one of the guys at The meat was never I'm not sure if I didn't go bring it to him or if he came I can't recall exactly. I went and visited Do you have a fellow by the name of Scott Bailey that works WICKERSHAM - REDIRECT EXAMINATION 1 A. Yes, I do. 2 Q. Could it be that Scott Bailey is the one that made the 3 delivery for you and not you? 4 A. 5 office all the time. 6 Scott probably would have given it to him. 7 Q. It would have been Scott and not you — 8 A. That's correct. 9 Q. — if that happened? 10 A. 41 If he came to the office, yes. He wouldn't have made the delivery. Scott stays at the If Mr. Molleur came and picked it up, 11 MR. VOYLES: 12 Thank you, sir. 13 MR. SCHMID: 14 I have no further questions. I have a few, Your Honor. REDIRECT EXAMINATION 15 BY MR. SCHMID: 16 Q. 17 that deer magazine, it wasn't a deer that was going to look 18 like your deer; it was the deer that they were going to have 19 you kill and pay $20,000 for, correct? 20 A. That's correct. 21 Q. Okay. 22 had to wait for the deer to pass by you in order to get off a 23 shot, correct? 24 A. That's correct. 25 Q. And that first day you were not able to get a deer that The photo that Mr. Bellar and Mr. Jones showed you from Now, when you're out in the bigger hunting area, you WICKERSHAM - REDIRECT EXAMINATION 42 1 way, correct? 2 A. That's correct. 3 Q. The day that you hunted, you weren't rushing to leave that 4 day, were you, sir? 5 A. No, I was not. 6 Q. It was the day that Mr. Fremin hunted a little later in the 7 week? 8 A. That last morning hunt, yes. 9 Q. Okay. And the deer that they had you kill in the pen was 10 the deer that they had pointed out to you the night before? 11 A. Yes. 12 Q. That was the deer that Mr. Bellar quoted you the price of 13 $20,000 on? 14 A. That's correct. 15 Q. Let me show you what's been marked as Government 16 Exhibit 30. 17 you killed at Bellar's Place was packaged and provided to you 18 in Louisiana (indicating)? 19 A. Yes, it was. 20 Q. Is that the deer meat sticks that you provided to Bill 21 Molleur, either personally or through someone at your shop? 22 A. Yes. 23 Q. Now, did you receive certain invoices and correspondence 24 from Bellar's Place? 25 A. Is that the way your deer meat from the deer that I think I — yeah, I did receive something. WICKERSHAM - REDIRECT EXAMINATION 1 Q. 2 Exhibit 128 and tell me if that is correspondence that you 3 received from Bellar's Place and an invoice. 4 A. 43 Could you please, sir, take a look at Government Yes. 5 6 MR. SCHMID: introduction of Government Exhibit 128. 7 THE COURT: 8 MR. SCHMID: 9 THE COURT: 10 MR. SCHMID: 11 THE COURT: 12 Your Honor, I would move the Do you need to see it? I think I just showed it to him before. Objection? I didn't show it to you? Better show it to him. He gets his feelings hurt very easily. 13 THE CLERK: It's admitted? 14 THE COURT: Not yet. 15 have I? I haven't ruled on this yet. 16 MR. SCHMID: 17 THE COURT: 18 morning. I haven't ruled on it yet, I'm sorry, Your Honor. I was having my one-liners for the What's the — 19 MR. SCHMID: 20 THE COURT: 21 MR. VOYLES: 22 THE COURT: 23 MR. SCHMID: Number 128, Your Honor. No objection? No objection to 128. Fine. Admitted. Thank you, Your Honor. 24 Q. In this letter that you received, they were informing you 25 that Mr. Jones was no longer employed there, but they wanted to WICKERSHAM - REDIRECT EXAMINATION 44 1 assure you that Bellar's place was going to remain open for 2 hunting and they wanted you to come back in 2004, correct? 3 A. That's correct. 4 Q. Thank you. 5 MR. SCHMID: That's all I have. Oh, I'm sorry. I 6 do have one more thing. 7 Q. 8 that's in evidence already from Government Exhibit 117. 9 short 10 second or so clip, and I just want you to tell me if 10 I have a little bit of video that I would like to show you It's a this is you in the clip just to confirm. 11 (Government Exhibit 117 displayed.) 12 Q. Is this you (indicating), sir? 13 A. Yes, it is. 14 Q. Mr. Wickersham, do you see the little video clip on your 15 monitor in front of you? 16 A. Yes. 17 Q. The Rack Attract that you were referring to, was it those 18 kind of white strips on the ground (indicating)? 19 A. Yes, it was. 20 Q. That would have been placed when you were out hunting in 21 what location? 22 A. That was in the pen where I killed the big deer. 23 Q. Where you killed the big deer? 24 A. Yes. 25 Q. That was the pen that the Hispanic helper was at, Mr. Jones WICKERSHAM - RECROSS-EXAMINATION 1 was at, and Mr. Bellar was at? 2 A. That's correct. 3 Q. So they assisted you with moving the deer toward you? 4 A. Yes. 5 Q. And there was the Rack Attract out, as well, to draw the 6 deer into where you were at in the tree stand? 7 A. Yes. 8 Q. Was this the tree stand that you actually hunted from and 9 45 shot the arrow towards the deer (indicating)? 10 A. Yes. 11 Q. Thank you. 12 MR. SCHMID: 13 THE COURT: 14 MR. VOYLES: 15 Nothing further, Your Honor. He's finished. We're back to you. Thank you. RECROSS-EXAMINATION 16 BY MR. VOYLES: 17 Q. 18 identified on the video, was that the product that Mr. Jones 19 put out there? 20 A. Mr. Wickersham, you indicated — the stuff that you That's correct. 21 MR. VOYLES: 22 THE COURT: May I approach the witness, Your Honor? Sure. 23 BY MR. VOYLES: 24 Q. 25 Mr. Schmid asked you to take a look at that. I want to talk to you a little bit about Exhibit 130. WICKERSHAM - RECROSS-EXAMINATION 1 46 Is there any indication of where that came from, 2 that package that's in front of you? 3 A. No indication on it. 4 Q. And there's no indication to you that that's exactly the 5 deer that you shot, is it? 6 A. 7 shipped to me. 8 Q. That's all you know? 9 A. That's correct. 10 Q. And you don't even know who shipped it to you, where it 11 came from or how it — because it went to Fremin first, correct? 12 A. That's correct. 13 Q. And never came to you? 14 A. That's correct. 15 Q. And you picked it up in this package inside 130 that's 16 unidentified, correct? 17 A. Correct. 18 Q. Thank you. I was told that they were going to have it processed and 19 MR. SCHMID: 20 THE COURT: 21 MR. VOYLES: 22 (Brief pause in the proceedings.) 23 Q. 25 you? Anything else, Mr. Voyles? Maybe one more. Let me check. BY MR. VOYLES: 24 I have nothing further, Your Honor. You're not saying that packet inside 130 was your meat, are WICKERSHAM - RECROSS-EXAMINATION 47 1 A. The meat that I received looked exactly like that. 2 Q. Looked like it, but you can't say it's the deer you shot on 3 November 8th? 4 A. I can't say because I didn't get the deer processed. 5 Q. Thank you, sir. 6 MR. SCHMID: 7 (Transcript of subsequent proceedings not requested 8 Nothing further, Your Honor. herein.) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 * * *