Johnson's petition for Executive Clemency

8/18/2019 Johnson's petition for Executive Clemency

http://slidepdf.com/reader/full/johnsons-petition-for-executive-clemency 1/27

PARDON DOCKET

NO.

BEFORE

THE

LLINOIS

PRISONER

REVIEW

BOARD

ADVISING

THE

HONORABLE PATRICK QUINN GOVERNOR

IN

THE MATTER OF WILLIE JOHNSON

PETITION OF

WILLIEJOHNSON FOR EXECUTIVE

CLEMENCY

Gabriel A.

uentes

Andrew W.

ail

Justin C.

teffen

JENNER BLOCK

LLP

353

N.

lark

St

Chicago,

IL

60654

Telephone:

312) 22-9350

Facsimile: 312)

27-0484

Counsel or

Willie

Johnson



I

INTRODUCTION

II

FACTUAL

BACKGROUND

3

III

REASONS

FOR

GRANTING

CLEMENCY

TO

WILLIE

JOHNSON

1

A.

WILLIE S

JANUARY

011

RECANTION HAD

SUBSTANTIALINDICIA OF

RELIABILITY

11

B

WILLIE S

PROSECUTION,

ND

HISSERVING A PRISON

SENTENCEFOR

PERJURY AFTER

HAVING RECANTED,

WILL

CHILL

FUTURE TRUTHFUL

RECANTATIONS 14

C.

WILLIE PLEADED GUILTY

TO A

FLAWED

INDICTMENT THAT DID NOT STATE

AN

OFFENSE

18

D. WILLIE S

30

-MONTH

PRISON

SENTENCE

S

AN

UNDULY

HARSH AND

DISPROPORTIONATE PENALTY,

FURTHER

CHILLING

RECANTATIONS

2

IV

CONCLUSION

2

V PRAYER FOR RELIEF

23



I.

INTRODUCTION

Willie

Johnson

is the

only person

in

recent

memory charged

with

perjury

by the Cook

County State's

Attorney's Office

for recanting, in

apost-conviction

hearing, earlier

sworn

testimony.

Willie is a 43

-year

-old husband and

father.l

His prosecution and conviction for

perjury resulted

from

a unique

and

highly

aggressive

application

of

he Illinois perjury statute,

which

permits

proof

of

perjury by

the mere

presentation

of

two

conflicting

sworn

statements,

without proof of which was false. 720 ILLS

5/32-2(b).

Willie's prosecution stands to have

a

profound

chilling

effect

on truthful

recantations

by witnesses who

can

and

will

be

told by law

enforcement

that

like

Willie,

they

may

be prosecuted

for

perjury

and

sentenced

to

prison

simply

because they

changed their

story,

and

the law may

not

permit

them to defend themselves by

presenting

evidence

of

he

truth of heir recantation.

Willie

testified at a

February

1994 murder rial

thattwo

men,

lbert

Kirkman

and Cedric

Cal,

had shot

him

and two

of his

friends, who

both

died,

in April 1992 on

the West Side

of

Chicago. In

January

2011,

after

a representative

of

one

of

he convicted

men tracked Willie

down

out

of

tate

and persuaded

him

to

come

forward with

a

recantation, Willie

testified

under

oath

that

a man

named

Keith

Ford

and an

accomplice had

done the 1992 shooting. After a Cook

County

Circuit Court

udge denied the Kirkman and Cal post-conviction petition and said he

did

not believe Willie's recantation, the State

obtained

an

indictment

charging

Willie

with

perjury

each

and

every

day

from

his

February

1994 rial testimony

to his

January

2011 recantation.

Willie's

personal

background

information,data and

history

are

provided

in

greater

detail

in

Exhibit

16, Background of

illie Johnson, in compliance

with

requirements

of

he llinois

Prisoner

Review

Board. Willie

is

asking

for

expedited

consideration

of is

petition

by the

Governor,

utside

the

normal

PR

eview

process.

He

was

onvicted

very

recently,

on

October 7,

014,

and

immediately

entered IDOC

ustody.

While

his attorneys

have

discussed

the

content

of

he

petition

with

him

by

telephone,

they

have

not

yet had

an opportunity to obtain his signed and notarized declaration.

The

declaration

will be submitted

as

soon as it is

obtained.



Willie s

motion

to dismiss was

denied.

Faced with

the

likely

prospect

that he would be

barred

from

offering

any

evidence

of

nnocence

by proving

the

truth of

is

recantation,

and that

the

State would

not be

required to prove

his

recantation

false,

Willie

pleaded guilty to perjury on

October

7,

2014 n Cook

County

in

case number

11

CR 13172

and was sentenced to 30 months

in

the Illinois Department of orrections.

He ntered

custody immediately

on

October 7 2014.

Pursuant to 730

ILCS

5/3-3-13

and the

guidelines

set

forth

by the

Illinois Prisoner

Review

Board Willie

now

respectfully

requests

executive

clemency that

is

a

pardon for

and

expungement of

is

conviction, and

n

the

alternative, the

commutation of

is

prison

sentence so

that

he

may

be

released

immediately.

He

has

not

previously

petitioned

for clemency.

Given the

extraordinary circumstances of his

unique

and unfair application

of

he perjury

statute in a way

even the Cook County

State s Attorney

publicly

disclaimed,

Willie should not spend another day

in prison.

Every day

he spends in

prison does harm

not

only

to

him

but to the

ability

of

ll

potentially

recanting witnesses

to come forward and speak

the

truth

in

cases

in

which

justice

requires that

the

truth be told.

Under ll of

hese

circumstances,

Willie

respectfully

requests

that

the Governor

grant

him

executive clemency

forthwith,

without

the

ordinary time

for review

and

consideration by the

Illinois

Prisoner

Review Board

s

is

within

the

Governor s

authority

under

Madigan

.

Snyder,

208 11.

Zd

457

2004).

II. FACTUAL

BACKGROUND

Until entering

Illinois

Department

of

orrections

custody

on October

7,

2014

Willie was

living as

a

stay-at-home

father with

his wife,

Chiffon, raising

their -year-old

twins,

Jayden and

Jessica, in Dallas, Texas. The events that eventually

led to his plea

of

uilty to

perjury

began

some

22

years earlier, on

the West

Side

of Chicago on April 21

1992 when

he sustained nine

gunshot wounds and his two

friends

were

killed.



n hat day in April

1992,

Willie was with his two friends, Cedric Herron and Sammy

Walker,

during

a fight

at

the West

Side home

of a man

named

Keith

Ford.

(Ex. 4, 11. App.

t.

Kirkman/Cal

June 17, 2013

Opinion

at 3.)

Willie

testified at

the

1994

rial of Kirkman

and

Cal

that

Ford

had directed

Kirkman and

Cal

to

attack

him. (Id.) Later that night, according

to

Willie's

1994

testimony, he

was

talking to Herron

and

Walker

outside

his

home

when two

men

approached and shot at

them,

illing Walker

and

Herron,

and

wounding

Willie

nine times. (Id.)

Willie

testified

at

the

trial that Cal

and

Kirkman

were

the

shooters, and

that

he had told

the

police

they

were

the shooters. (Id.

Also

testifying

at

the

1994

trial was

Willie's

then

-girlfriend,

Latrese

Buford,

who

said

that

earlier

in

the day, she had seen an altercation between Herron and

Ford

over

a

drug sale,and

that Ford

was

driving one of

two Astro

vans which

had

carried

group

of men

who

initiated

a

fight

with one of Herron's

drug dealers.

(Id.) Buford also

testified that after the fight,

Ford

approached Willie

and

told him

that being

around Herron could be

dangerous

because Herron

was

selling drugs on

Ford's

turf. (Id.).

Later

that night, Buford

was

inside a

home

near

the

shooting

when

she

heard

shots.

(Id.).

Later,

at

the

2011

hearing

on

post

-conviction

petitions

by

Kirkman and

Cal,

Buford

testified

further

that as she had told

the

police at

the

time,she

had

seen

an

Astro

van

parked

in an alley at the scene of

he

shooting and that she recognized

the

van.

(Ex.

5,

4/20/11

L.

Buford Post-Conviction

Testimony at

30-31,

68.) The

judge presiding over

the

post-conviction hearing

did not permit

her to testify

to her

understanding

of

whose

van

it

was

(Ford's),

ruling

that

such

testimony

would

be

speculative

or irrelevant. (Id. at

31,

9-71.)

At he

1994

rial of

irkman

and Cal, another witness,John Sylvester, testified

that

in

the

summer of 1992, Sylvester

asked

Willie

whether Kirkman and Cal had actually

done the

shooting

and

he said

no ....

he knew that they didn't do t. (Ex.

, . Sylvester

February

1994



Trial

Testimony at

40,

42.)

Further, at

the Kirkman and Cal

post-conviction

hearing,

Buford

testified

that

a

few months

after

Willie

was

eleased from the hospital in

1992, he

told

her

that he

had a

plan o

deal

with hose

who had shot his

friends to

death

because

I know

where they

play ball.

(Ex. 5, 4/20/11 L.

Buford

Post

-Conviction

Testimony

at 49-50.)

f ourse,

it

is

undisputed

that Kirkman and Cal

were in custody at

that time and

could not have

been

the

persons

Willie told Buford he

planned to deal

with t

a location

where he

knew they play[ed]

ball.

Kirkman

and Cal

were

convicted at

the 1994

trial and

15 years passed. In or

about

2008,

Willie

moved

to

Monroe,

Louisiana,

where he and

Chiffon

were

involved

in

a

2008

car

accident that

left

Willie

disabled.

Meanwhile,

an investigator

for

Kirkman began looking for

Willie.

The

process

of

finding

Willie

took the

investigator, Elliot

Slosar,

about six

months and

began

with

two

trips

Willie's sister in

Green

Bay, Wisconsin.(Ex.

7,

E.

Slosar Affid.

at

2.)

n

the

second

trip,

Willie's sister

was

able

to initiate

a

phone conversation

between

Willie and

Slosar,

but

Willie

was

hostile

to Slosar

in

these conversations

and wanted

nothing to

do

with

Slosar's

questions

about

the

Kirkman

and Cal case.

(Id.

at 2.)

Willie

remained hostile

to

the

idea of

iscussing

the

Kirkman

and Cal

case during further conversations,

at

Slosar's

instance, between

Willie

and his

sister.

(Id.

at

2.)

After

the

investigator himself

nitiated

a phone

call

to an

imprisoned

Chicago

gang member,

Willie

signed

an

affidavit

recanting his 1994 rial

testimony. (Id at

3.) The call

with

the gang

member

later

was

held

against Willie

under

a claim

by the State

that

his

recantation

was

influenced by the gang,

but that claim was

unsupported, and

Slosar's affidavit

flatly

refutes

it.



On January 19, 2011, he testified

at

the post

-conviction

hearing

of

Kirkman

and

Cal,

recanting

his

1994 tri l testimony and

implicating

Keith

Ford.

(Ex

8,

W

Johnson 2011

Testimony.)

Ford was he person whom Latrese

Buford had seen driving an

Astro

van

similar

to

the

one

she

saw at the crime

scene

immediately after

the

shooting,

and Ford was the

person she

had said she

heard

warning Willie

that

being

around Herron

was dangerous because

Ford

was

in

a dispute with

Herron over drug-selling turf.

The

udge, fter

limiting

Buford's

testimony

about

her

identification of the Astro

van

at

the

scene of the shooting

as Ford's,

and after

hearing

Willie's testimony,

denied

the post

-conviction

petitions of

Kirkman

and

Cal.

(Ex. 9, Post

-

Conviction

Ruling.)

The

tri l

judge

based his ruling heavily

on

his conclusion that

Willie's

post

-conviction

testimony was

not plausible.

The

tri l judge

mentioned that multiple

gunshots had

been

fired,

suggesting

to the

court

that Willie's

recollection of

a

single

shooter

was

not plausible.

(Ex.

9,

Post-Conviction Ruling at 4.) The judge disbelieved Willie's

testimony

that his

family

received

telephone

threats

when

he

was t the

hospital

emergency

room in 1992, lthough

the

court added

that

I haven't

heard

any

evidence

other

than

what

Mr.

ohnson

testified

to concerning

that.

Id.

at 4-5).

The

judge further found that Willie's stated reasons

for implicating Kirkman

and

Cal

in

1994 had shifted, and that

Willie recanted

after

having

a telephone

conversation with

a

gang

leader

named

Ray

Longstreet,

who gave him the

green

light to do the

right

thing.

(Id. at 6-7.)

Without

hearing any

other evidence concerning

this Longstreet phone

call,

the

judge

concluded

that

Willie

had testified

out of gang loyalties

and

further found his

recantation

not

credible.

(Id. at 7-9.)

Willie was not

on tri l for perjury

in the

post

-conviction hearing for Kirkman and Cal,

was

not

represented by

counsel, and had no

opportunity

to

present

his

own evidence directed at

D



the

truthfulness of his

2011 recantation. That evidence included

Slosar's full account of

he

circumstances of the Longstreet phone

call, which

was

initiated

not

by

Willie, but

by

Slosar.

Ex.

7,

E.

losar Affid.) Slosar affirms

that Willie initially reacted

with

hostility

to the Slosar's

efforts to talk

with Willie about the Kirkman

and Cal case, that

neither Slosar

nor

Longstreet

attempted

to

tell

Willie what

to

say, and

that

Longstreet

simply

told

Willie he need not

fear

retaliation for coming

forward. (Id.)

Slosar's

narrative

is

being

told here

for

the

first

time

and

was

never

presented

to the

Circuit or Appellate

Courts

in the

Kirkman

and

Cal

post

-conviction

matter.

Slosar's

account

would

have been

presented

to

Willie's

jury, had

it been

permitted

to

hear evidence

of

he

truthfulness

of

Willie's recantation.

The

investigative narrative

is

a

first

hand

account

refuting

the

State's claims,

and

the

Kirkman

and

Cal post-conviction judge's

findings, that

Willie

came forward out

of

ang

loyalties. e id not.

After the

Circuit

Court denied the

Kirkman and Cal

petitions

and

pronounced Willie's

testimony not credible,

the

State's Attorney

of Cook

County

proceeded

to obtain

a

grand

jury

indictment

charging Willie with

perjury

under

an Illinois statute that

allows perjury

to be

proved

by

an

offer

of wo

contradictory,

sworn

statements; unlike the

federal

perjury

statute,

the

Illinois

law

allows

proof

by

two

contradictory sworn statements without regard to

the

age

of

the

statements

or whether both fell within the statute's limitations

period.

Compare 720 ILLS 5/32-

2 b)

stating

that a

perjury indictment

based on

two

contradictory

statements need

not

specify

which statement is false)

with 18 U.S.C.

§

1623 c)

providing that federal perjury

indictment

based

on two contradictory

sworn

statements

need not specify which is false if

each

statement

was

made

during the limitations period).

In an apparent effort

to

avoid

dismissal on

limitations

grounds, the

Cook

County

State's

Attorney's Office

obtained

an

indictment

alleging that Willie

committed

perjury on a

continuing

basis

during each and every day of a 17

-year

-period

from

D



February

8,

1994 far

outside

perjury s three-year

limitations

period)

to

January 19,

2011. Ex.

10, W

ohnson

Motion

to

Dismiss

Indictment.)

After Willie

moved

to dismiss

the indictment on

limitations

grounds,

the

Cook

County

State s

Attorney s

Office told

the

Circuit

Court

that it

need not

be

concerned

about

the

limitations

problem

because

the

prosecution would

prove

only the falsity of

Willie s January

2011

recantation, as this was

he

only

testimony

at issue in the

case. Ex.

1,

11/7/2012

Tr.

at 7.)

The

Assistant

State s Attorney

told the

Court:

Counsel s argument s that

the perjured statement

is

from

1994

when in

fact that s

not

what

we re

alleging.

It s the

statement

that the

defendant made

in

the

post-

conviction

matter

in

January

of

2011,

and we re

within

the

statute

of

imitations

with respect to

that.

That is

the

allegation that is before the

fact finder.

The

prior

testimony

is

simply evidence

that

will be

used

with respect

to the

fact

finder

making that

determination as to

whether

this

defendant

committed

perjury in

2011.

(Id.) Willie s

motion was

denied.

In

April

2014,

23

former judges and

prosecutors

wrote to

the State s

Attorney about

Willie s

prosecution and

expressed

their

concern

that

perjury

prosecutions based

simply

on

recantations

of

ontradictory

earlier

sworn

testimony would discourage

truthful

recantations,

and

that

perjury charges should be

brought in

recantations only

where

the

State could

prove

the

falsity

of the

recantation.

Ex. 1,

W

Wolfson 4/24/14

Letter

to

A. Alvarez.) The

State s

Attorney

of Cook County

responded

in

a

letter

consistent

with her assistant s

representation to

the

Circuit

Court

in

November 2012, that

the

former

judges and prosecutors

need not be

concerned

about whether

the

prosecution

would

discourage

truthful recantations

because the

State s Attorney

would prosecute

recantations

only in cases in

which

it

could

prove

the

falsity of

the

recantation. Ex.2,

/5/14

A.

Alvarez

Letter

to W

olfson.)

The

etter

which

contained a

reference

line

identifying

it

as

having

been sent in

Willie s

criminal

perjury case

then

pending in

the Circuit

Court, stated:

8



[i]t

is appropriate to prosecute

perjury only in

cases

in

which

it can

be proven

beyond

a

reasonable doubt that

a

recantation, as opposed

to

prior

testimony,

is

false. I

say

this

in spite of

the fact

that Illinois law does

not require

such

a

stringent test and appellate courts require much

less

in establishing

guilt

in

perjury

prosecutions ....

n]o

perjury

prosecution

involving

a recantation should

ever

move

forward without

the

evidence and

ability

to

prove

that

the

recantation

is

perjured.

At

the time

of

he State's Attorney's

letter

Willie

had moved

to

dismiss

the

indictment

for having

wrongly

alleged

perjury

as

a continuing offense.

The motion also

sought

a

bill of

particulars

confirming that,

as

the State had represented to the

Court

in November 2012, the

State

would

need to

prove the

falsity

of

illie's

January

2011

recantation.

(Ex.

10,

W

ohnson

Motion To

Dismiss Indictment.) Notwithstanding the State's November 2012 representation

to

the

Circuit

Court whether his defendant committed

perjury

in 2011

was

the allegation

that

is

before the fact

finder ),

and notwithstanding the

State's

Attorney's

statement to the

23

former

judges

and

prosecutors (that

she was in agreement

with them

that

perjury

prosecutions

in

recantation

cases should be brought only where it can be proven beyond

a reasonable

doubt hat

the

recantation,

as

opposed to

prior

testimony,

is

false ),

the

State told

the

Circuit

Court

in

July

2014 hat

it

would

not prove

the falsity of illie's

recantation, that

it need not

do so,and that the

truth or

falsity of

the

recantation was an

issue

that should never reach

Willie's

jury. (Ex.

3,

People's Response to Defendants' Motion to Dismiss Indictment at 1-Z.) The

State

told

the

Court:

The

statute

under which defendant

is

charged does not

require

proof

of which of

the

two statements

is

false.

720

ILLS

5/32-2(b).

The

opinions

of

the parties

regarding

which of

he statements is

the

falsity is irrelevant

to the

question of

Defendant's guilt on the

charge

of

erjury.

The

very

fact that two contradictory

statements

were made

under

oath

at separate proceedings is

sufficient

to prove

the

charge

of erjury. 720

ILCS

5/32-2(b). Just as The People are

not

required to

prove which of he statements are false,a

ury

would

not

be required to determine

or

agree

which

of he statements are false.

D



Ala

Shortly after

the Court

denied Willie's

motion

to dismiss and request

for a

bill of

particulars, Willie

pleaded guilty to

the indictment

on

October

7, 2014.

III.

RE SONS

FOR GR NTING

CLEMENCY

TO WILLIE JOHNSON

Willie Johnson

was

prepared to present substantial

evidence of

he truth of

his

January

2011

recantation in

order

to

establish

his innocence to

the charge

of erjury.

Instead, he

pleaded

guilty

when

confronted with the probability that

the

truth

of

his

2011

recantation would be

considered

irrelevant and

inadmissible. Willie's prosecution

is said to be the only perjury

prosecution

brought

in Cook

County

in

a

recantation

case

in

at

least

the

past

four

years. (Ex.

12,

Frank Main, lvarez: I

on t rosecute

every

witness suspected of ying, Chi, Sun

-Times,

June 3,2014 at

2.)

Ultimately,

Willie's

guilt

or

innocence at his

trial

would have turned

only

on

whether

the

prosecutor

could

present

evidence of

two

conflicting

sworn

statements,

and

not on

whether either

was

rue

or false. The State proceeded under

this

theory even

though it had stated

in

open

court

that

it

would

not,

and

even though

the

State's

Attorney

herself

wrote

to

the

23

former

judges

and prosecutors

in

a

way strongly suggesting

that

she would not exercise her

discretion, in recantation cases, in a way that

availed

itself of

the Illinois perjury

statute's

stringent

provision

allowing

perjury

prosecutions

to be

based on two conflicting statements.

After

the State's

Attorney said she would proceed only with

proof

hat a recantation

was

false,

the

State did

not

follow its own prescription in

Willie's

case and argued

successfully in

the

Circuit Court

that truth or falsity of he

statements was

irrelevant

and

would never

be

decided

by the

jury. The result

was

Willie's

guilty

plea

s tated

forcefully

by

the 23 former

judges

and

prosecutors

in an

amicus curiae

brief

filed in the Circuit Court,

Willie's prosecution

will

discourage truthful

as

well

as

untruthful

recantations.

10



Willie s conviction

and 30

-month

prison

sentence thus

yield

a result that is

abhorrent

to

justice

and that calls

out

for

the exercise

of he Governor s

power of

xecutive clemency. Willie

is

asking that this

power

be

exercised

forthwith,

and

without

the

usual

time

associated

with

consideration

by

the Illinois

Prisoner Review

Board.

Every

day

of

Willie s incarceration

undermines justice

by

sending

a

signal to all

potential recanting witnesses that simply

by

changing their story,

they

will

be

prosecuted

and ailed —with

no

regard

under

Illinois law

for

the

truthfulness

of

heir recantation, and no

guarantee of

an opportunity to

prove

their

innocence by

presenting

evidence

that they recanted

truthfully.

A.

WILLIE S

JANUARY

011

RECANTION

H D

SUBSTANTIAL

INDICIA

OF

ELIABILITY.

The innocence case

which Illinois law precluded

Willie from

presenting would

have

been

based on

his

own testimony that he

told

the

truth in January 2011 at the

Kirkman and Cal post-

conviction

hearing

when he said

he identified

Kirkman and Cal as the shooters,

and did not

identify Ford, out

of

a

fear

of Ford and out

of

a

misguided desire to

exact

revenge

himself

on

Ford. Willie s

testimony

is

backed

by

at leasttwo

prior

and admissible

consistent

statements

(to

Buford

and

Sylvester in or about

1992)

hat

the

men in custody

for

the

shooting were

not

the

shooters. t

also

is backed by

Buford s

sighting of an

Astro

van, resembling

one

Ford

had

been

seen

driving

that day, t

the

scene

of

he

shooting

moments after

the

shooting

happened.

None

of he

responses

the State

has

offered,

in its multiple

opportunities

to

do so

in the

perjury prosecution of Willie,

should

give the

Governor

any

pause

in granting Willie

clemency.

(See Ex. 12, Chi,

Sun

-Times

Article;

Ex. 2, 6/5/14 A.

Alvarez

Letter

to W.

Wolfson;

Ex.

13 ,

People s

Response

to

the

Motion for Leave to

File an

Amicus

Brief in Support of efendant s

11



Motion to Dismiss.)

First, the State has

repeatedly raised

the red

herring

of gang influence

on

Willie's

recantation

by

pointing out that Willie, in his

sworn

recantation, admitted

having

a

phone

conversation with

an

incarcerated gang

leader

named Ray

Longstreet. But Willie

wanted

to have nothing

to do

with the

Kirkman

and

Cal

case

when the Kirkman

investigator found him

living

out of tate in 2008.

(Ex. 7,E. losar Affid. at

2.) The

investigator swears today that

he

initiated

the

Longstreet call,

which

lasted

about

one

minute,

and

in which

no

one told

Willie

whom he should

or should not

identify. (Id at 2,3.)

The investigator

swears today

that the

purpose

of

the

call was

simply to allay Willie's fears

of

retaliation

so

that he would

come

forward

at

ll

with

truthful

testimony

that

Kirkman

and

Cal were

not

the shooters.

(Id. at

3.)

Second, he Circuit

Court's

denial

of he

Kirkman

and

Cal post

-conviction petition

based

on Willie's testimony

being not credible

came

not

after a tri l of any

perjury charge against

Willie,

who

had no counsel

at

the

proceeding

and

no

opportunity himself

to

argue that

his

recantation was in fact

truthful.

The

Circuit

Court

barred

Buford from

testifying

that

the

Astro

van she

had

seen at the

crime scene resembled the one

she

had

seen

Ford

driving

that day.

The

Circuit Court

did not

hear

the

prior sworn

testimony

of

Sylvester.

No vidence

was

presented

from the Kirkman

investigator about

the

full

circumstances

of

the phone call

with

the

incarcerated gang

member, r about how

the investigator,

and

not Willie, had

initiated

that call.

No

vidence was offered

to

explain

how a

heavily medicated Willie might have

been

mistaken

about

having received

threatening phone calls

while

lying in the

emergency

room

19

years

Willie has

attached

these

documents

hereto as

exhibits and has responded

to

them here

to

provide

a

means

by

which the

Governor may

give the

State's

arguments a full and

f ir review in advance of

further briefing. The State has

availed itself

of ultiple

opportunities, as attached hereto,

to state on

the record

and in

public its

belief that

Willie

committed perjury and that his

January 2011

recantation

was alse —but his

Petition

represents

Willie's

first opportunity

to argue

his case for

innocence based

on the

truth of

is

recantation.

12



earlier suffering from nine gunshot

wounds or

about

how the

calls

might

have

been

directed to

his family at another

location, even

elsewhere

in

the

hospital. None of

those

avenues was

explored, and the

Circuit Court

and Appellate

Court

did not

have the

benefit of any of that

evidence or

argument. Accordingly, the

Circuit

Court

and

Appellate

Court

decisions

in

the

Kirkman

and

Cal

matter

have no bearing

whatsoever

on Willie s guilt

or innocence in

his perjury

case.

In

fact,

the

opinions of therjudges based

on

the

incomplete

record

presented

in the post-

conviction hearing most

certainly would

have been

inadmissible

in a perjury

tri l of

illie,

and

Willie sjury would

never have

been

allowed to

hear them.

Third,

t

is

important

to

remember

that Willie,

even

in

his

guilty

plea,

has never

admitted

that he lied when he

recanted

in

January

2011.

Rather, Willie

pleaded

guilty to a

perjury

indictment

that charged him

with

having perjured

himself continuously

over

a

17

-year

-period

based on

two contradictory

sworn

statements

17 years

apart. The indictment

failed to

charge

Willie

with

the specific

act of

committing perjury in his January 2011 recantation, and as

explained further

below

he

State

took

shifting positions

as to

what

t would prove but settled

on

the position

that

it

need

not prove

either

statement

false. For

reasons

stated

below

in Part III(C),

Willie

pleaded

guilty

to a

form

of

perjury that cannot

legally

be considered an offense

under

Illinois law. But for purposes

of considering

the impact of his guilty

plea on

this

clemency

petition,

the

flawed

form of the

indictment means

that

as a

technical

matter, Willie

never

expressly

admitted

perjuring himself

in January 2011. His admission to having

made

two

contradictory statements means no more

than

that —the

statements

were

contradictory,

so one

of

them must

be false.

e maintains that his

1994 ri l testimony —too old itselfto be

prosecuted

for perjury

—was

alse.

His guilty plea

to

perjury

ought

not

to be held

against

him

on the

instant

clemency petition

because the most

critic l of

he

two

statements

has

always

been

his

January

13



2011

recantation

and

the

claim

by the

State, in

its

public statements and

response

to

the

amici,

that in

January 2011, illie was

alsely attempting

to

exonerate two convicted

murderers.

Finally, notwithstanding

the

substantial

evidence

supporting the truthfulness

of

Willie s

recantation

and

the absence

of

rue

admission

by

him that

it

was alse, the

real

issue now before

the

Governor in this

clemency petition goes far beyond

the

guilt

or innocence of

illie Johnson.

The issue

before the

Governor is how truthful recantations

will

be

discouraged by this

prosecution

and the

manner

in which it was brought,

in direct

contravention

of

the line

prosecutor s

promise to the defense and the

Court

in

November 2012

and

of the State s

Attorney s

view

in

June

2014

that recantation perjury

cases

should never

be

brought

in

the

absence

of

proofof

he falsity

of

he

recantation.3

As xplained

below,

Willie s

prosecution

will

have a

palpably

chilling effect on

the

willingness of itnesses to give


in

the

future.

B. WILLIE S

PROSECUTION,

ND

HIS

SERVING

A

PRISON SENTENCE

FOR

PERJURY AFTER HAVING

RECANTED,

ILL

CHILL

FUTURE

TRUTHFULRECANTATIONS.

Willie s prosecution

is

certain

to

chill future

truthful

recantations.

Two groups

of

amici

saw

Willie s indictment as

having

such a chilling effect:

(1)

a

group

of 23

former

prosecutors

and

judges

including

former

U.S. Attorneys

James

R.

Thompson and Dan K.

Webb;

former

3

The

analysis is not changed

were

the

State s

Attorney to

contend

that in

her

letter

to the 23

former

judges and prosecutors,

she

never committed to presenting proof at

trial

of he

recantation s

falsity

In

other words, an

interpretation of

the

State s

Attorney s

June 2014 letter

to

the effect that she

believed

recantation perjury

cases to be

appropriate

only

where she

herself

is

persuaded of the

recantation s falsity

would be a

hollow promise

inconsistent

with the spirit of

er

stated agreement

with the

23

former

judges

and prosecutors. In

Willie s

perjury case,the

State s

Attorney

stood on the

law

that

perjury

could

be

proved

through

two

conflicting statements. A defendant barred

from

putting the State

to its

proofof ts professed

belief in

the falsity

of he

recantation

is

in

the

same

shoes

as a

defendant

prosecuted

based

only on

two

materially

conflicting

sworn

statements. Willie s

prosecution

therefore

was

brought in

precisely the

way

the

State s Attorney

strongly intimated she

would never

proceed.

14



Associate

U.S.

Attorney General John

R.

Schmidt;

former

judges

George N

eighton, Kenneth

L. Gillis,

Dom

J.

Rizzi, Nan Nolan, Warren

D. Wolfson,

and

Julian Frazin;

former Illinois

Attorney

General

Tyrone

C.

ahner; former assistant U.S.

attorneys

Ronald

S.

Safer, Andrea

L.

Zopp (also a

former First Assistant

Cook

County

State s Attorney),

Jeffrey

H. Cramer, Jeremy

D.

argolis, Lori

E.

ightfoot, and

Stuart J. Chanen; and

former

Cook County assistant state s

attorneys

Jeffrey

Singer, Don

J.

Mizerk;

Jorge Montes, and Mary

Brigid

Hayes also a

former

Assistant

Illinois

Attorney

General);

and

(2)

a group

of 12 exonerated Illinois

defendants whose

wrongful

criminal

convictions

were

based

in

whole

or in part

on witness

testimony

later

recanted.

(Ex.

14,

Amicus

Curiae

Brief.)

The

amici

tated:

[T]he

prosecution ofMr.Johnson for perjury will

discourage other witnesses from

recanting false statements

and/or identifications.

The criminal

justice

system

should send a message that the

goal

of ll

judicial proceedings

is

to encourage

truth

-telling,

not

punish it

....The

history of

he

last 30 years

strongly

suggests

that

many

recantations

are truthful, and

such

recantations are among

the

primary

reasons

that so

many

wrongful

convictions

...have recently come o

light. [T]o

discourage

recantation that might be true by

pressing perjury charges too

aggressively —that

urns the

truth-finding mission of he courts upside

down.

(Ex.

14,

Amicus Curiae

Brief

at

10,

quoting Editorial, Law

Shouldn t Discourage

the

Truth,

Chi,

Sun

-Times,May

,2014,

t

61.)

Willie s

prosecution

represents

an especially acute example

of

a

perjury prosecution that

will

discourage

truthful recantations. Willie s

case

demonstrated

ow

asily

a

recanting

witness

may

be

charged and convicted

of

erjury. The

mere existence

of

wo

conflicting

pieces of worn

testimony

is

all

that

is required by the Illinois

perjury

statute.

Accordingly,

every witness who

gives a sworn

recantation of

arlier

sworn

testimony will have created

a

record

upon which a

perjury indictment

may

be

obtained.

Then, at

trial even in

prosecutions

in which

the State

publicly

claims

that

the

recantation was false, and

in which the State

asserts

that

justice

requires

prosecution

of a

false

recantation,

the

State

will

not have to prove the falsity

of he recantation.

This

is

precisely

what happened

in Willie s case. Willie s

prosecution sends a

strong signal

to

15



every potential recanting

witness:

If he

prosecutor

does

not

believe

the

recantation,

or

ifa udge

does

not believe

it

the witness

will be subject

to

a

felony perjury prosecution in which proving

the

truth

of

he

recantation will

not

be

an option.

The mere

existence of the two

conflicting

statements — no

matter that the recanted

testimony

occurred years outside

the limitations

period

for perjury prosecutions — is

enough

to

secure a conviction.

law enforcement

agent

or

official

may

point to

Willie s case as

an

example

of

how

easily

a

perjury

charge

may

be

lodged

and

proved

against a

recanting witness.

Willie s

case

also

demonstrated how

law

enforcement

officials are unafraid to

threaten recanting witnesses with

perjury.

Before

Willie

testified

at

the

Kirkman

and Cal

post-conviction

hearing,

a

prosecutor

and

a State s Attorney s

Office

investigator traveled to

Louisiana to

interview

him,

and

during

the

interview,

the

prosecutor

told

him

he

would

be prosecuted for

perjury

if

he

persisted

in

his

recantation.

Ex.

15, Willie

Johnson Affid.)

Willie

had

everything

to

lose and nothing to gain

by

recanting,

but

he recanted

anyway. Now

hat Willie

was

successfully prosecuted

for perjury,

his case

will

be

used by

law

enforcement

to

show that a

perjury prosecution is

not

just an

idle

threat, but a reality

for recanting witnesses in

Illinois

when law

enforcement

disbelieves the

recantation. The

risk

that

law enforcement

will disbelieve

the

recantation

and

seek a perjury

indictment,

and that

the

recanting

witness will then

be

unable to

point to

the

truthfulness

of he

recantation,

will

be

too great a

risk for many recanting

witnesses.

Counsel for any potential

recanting witness would

likely

advise

the

witness that the

recanting,

under

oath,

ofany

previous

sworn

testimony

brings

substantial

exposure

to a felony

perjury

charge and

a

possible

term of

imprisonment.

Willie s

sentence

was 30 months in

prison.

He its

in an

Illinois

prison in

East

Moline

at

this

very moment

—because he recanted.

~[~



The State's

response to the argument

of

he

amici was

to

state

that Willie's

prosecution

will not

chill truthful recantations because

1)

Willie's

recantation was false,

according to the

State,

and

2)

the

State

will prosecute perjury

only

where it

can prove

the falsity

of the

recantation. Ex. 1,

4/24/14

A.

Alvarez Letter

to

W

olfson.)

First,

Willie's

recantation

had

substantial indicia of eliability

and was

never

proved false.

See Part I(A),

supra.)

Second,

he

reason

why

he truth of illie's

statement

was

never

tested

in his

perjury case was

hat

the Cook

County State's

Attorney's Office

simply declined to do

so.

In what the State described as

the

only recent case

in which the State

has

prosecuted

arecantation-related

perjury,

at

least in

Cook

County,

t

argued

that

the

truth

or

falsity

of

he

recantation

was

irrelevant

and would never be

decided by a jury.

Ex.

3,

People's Response to

Defendant's Motion

to

Dismiss

Indictment.)

The Circuit

Court agreed.

Accordingly, the State's

argument about

why

Willie's

prosecution

will

not have

a

chilling effect

on


is

entitled to

zero

weight. Willie's

prosecution,and

the

circumstances

leading

to

his guilty

plea

after

the

court

accepted the State's

position that the

truth

of his

recantation was irrelevant,

pave a

path

toward chilling

ll

recantations. The State

blazed this

path itselfby

prosecuting

Willie

based

on

the

two

conflicting

statements

and without

committing to

prove the latter statement false,

or to

allow

Willie to

defend

the

indictment

based on the

l tter statement's

truth.

Willie's

prosecution

represents the

ill

effect that

the

Cook County

State's

Attorney

publicly

stated she would avoid

by

not

availing herself

of

he stringent

interpretation of

he

Illinois

perjury

statute

but instead

proceeding where a recantation's

falsity can be proved. See

Ex.

2,

4/24/14

A.

Alvarez

Letter

to

W

Wolfson.) The State's Attorney's

ultimately hollow

promise to

rely

on

proofof he falsity

of

recantation forms perhaps the

most

powerful evidence

in favor of xecutive

clemency. The

prosecutor herself admitted that to

avoid the chilling

effect

17



of

ecantation perjury cases, such cases

would

need to

be

brought

in

a

manner entirely different

from the way

in

which Willie s

perjury

case

was prosecuted.

Executive clemency

represents

an

alternative

—and

now

necessary

—means

o

the end

mapped

out

by

the

State s

Attorney.

C.

WILLIE

PLEADED GUILTYTO

A

FLAWED

INDICTMENT

THAT

DID

NOT STATEAN

OFFENSE

As s

detailed more

fully in

Willie s

motion

to

dismiss

the

indictment

in

this

matter,

the

State improperly charged

him

with an

act

of erjury

that

purportedly continued

every

day over a

14-year period from the

February

1994 Kirkman and Cal

murder

tri l

to his

January

2011

recantation. Ex. 10, W

ohnson

Motion

to

Dismiss

Indictment.) Willie

ultimately pleaded

guilty to

an indictment that did

not charge

him with

a

cognizable offense

under Illinois law.

This

flaw in

the

indictment

highlighted the

need

for

the

State,

as

a

matter

of

olicy,

to do

what t

ultimately

declined

to do: Charge

and

prove

the falsity

of

illie s January

2011

recantation.

Willie s case is notable

not

only as

the

only

recent

matter

in which the State

charged

perjury for a

recantation,

but

also

as the

only case —

to

Willie s knowledge —

in

which the State

has

sought

o prove

its

perjury case

by

two

conflicting

statements

when

one

of hose statements

—

the

February 1994

tri l testimony

implicating Kirkman

and

Cal —

is outside the three-year

limitations

period.

The

State

has never

quarreled with that

testimony

and said

in

open court in

November

2012

hat

it

planned

to

prove only

the falsity

of he

January 2011 recantation

Ex.

11 ,

11/7/2012

Tr. at

7), but

in

reality, the

Illinois

perjury statute did not require the

State to

allege

which was true or false, and

the indictment did

not do

so.

See 720 ILLS

5/32-2(b);

Ex. 10, W

Johnson

Motion

to

Dismiss

Indictment,

Ex. A.)

The

indictment did

something else, and

it was something

very

strange.

In apparent

anticipation

of he

potential

limitations

problem

with the

elements

of

he

offense

including the

1994,

ut

-o f

-time

tri l

testimony, he State

charged that Willie

committed perjury as a continuing

18



from

February 1994

through

the date

of

his

January 2011 recantation. (Id.)

The

indictment's

allegation

that

Willie was

committing perjury every day for 17 years, or that he

could have been under oath

every

day for 17 years,

is

absurd

on

its face,

particularly when

the

State

is invested so

heavily in

the

truth

of he

February

1994 trial testimony.

hy not simply

charge

that

the

perjury occurred

in January 2011?

The

answer may

be

that the

State was

simply

confused

about how precisely to

charge

a

perjury case

based

on

two

conflicting

statements.

Or,

perhaps the State

wanted

to

leave

open

the possibility,

which it ultimately pursued,

of elying on

the

perjury

statute's

provision

that

the State

need

not

prove

the

falsity of

ither

statement, but

need

only prove

that

two

conflicting

statements

were

made.

When

Willie

moved

to

dismiss the

indictment on limitations

grounds because

one

of

he statements was

too

old

to

be

prosecuted,

the

Circuit Court

denied

the

motion in November

2012

by

finding

that the last

act required by

the offense

as

charged

was

he

January 2011 testimony.

Ex.

11, 11/7/2012 Tr. at 7.)

Consequently,

Willie's

case is

an illustration of

he

bizarre result

that

can and did

occur

under the Illinois

perjury statute,

which

lacks the

federal

perjury statute's safeguard

of llowing

proof hrough two

conflicting statements only

if

both were made within the limitations period.

18

U.S.C.§

623(c). To

minimize the chances

of

ismissal on

limitations grounds,

he State

charged perjury

as

a continuing offense

when perjury

was

not and could never be

a

continuing

offense under

the

law.

The

Illinois perjury statute might

work well when both of he

conflicting

statements

fall within

the

limitations

period, but when one

of

hem

does

not,

only

the more recent

of the

two

statements ought

to be

charged

as

perjury.

The

State's

line

prosecutor apparently

understood this truism

in November 2012, but

the

drafters

of

the

indictment did

not charge

Willie

with perjuring

himself only in January 2011. The

indictment's reliance

on both

LL



statements where one

ell long

outside the limitations period made

Willie s

prosecution uniquely

aggressive.

Cases

such as

Willie s,

in

which

the

State

charges

perjury

based

on a

recantation

it

claims

to be false

and

with the

intent to rely

on Section 32-2(b) o

prevail

based

only

on

proof

of

he two

conflicting

sworn statements,

are a

poor fit

for Section

32-2(b) and make a

strong

case

for

the

exercise

of prosecutorial

discretion

and

now

clemency

where

the

prosecutor

failed to

exercise

that discretion. The

State s

Attorney appeared to recognize

how ill-suited

recantation perjury

cases are to

Section

32-2 b)

when

she told the

23 former judges

and

prosecutors that

she

would

only

bring

a

recantation perjury

case

in

which

she could prove

the

recantation

by

definition

the

l tter

of

he

two

statements)

alse.

The

Governor

should

complete the State s

Attorney s

thought

by

granting clemency here.

D. WILLIE S30

-MONTH PRISON

SENTENCE S

AN

UNDULYHARSH

AND

DISPROPORTIONATE

PENALTY,

URTHER

CHILLING

RECANTATIONS.

Probation would have

been

an appropriate

disposition for

this

offense,

given

that Willie

had left

behind his

earlier

gang

and

criminal

lifestyle

and is

now

a

disabled father

oftwo

young

children,

living

alaw-abiding life in the Dallas, Texas area. His previous criminal

conviction for

armed

robbery and

attempted murder, ft-cited

by

the

State, occurred

in

1995 and resulted

in an

18

-year prison sentence

from

which he

was

released

in

2003;

his

drug

convictions two matters

for

which

he

received

one

year and four

years

in 1989, and

two

1990

matters

for which he

received

a

year

each) ccurred

even

earlier. Ex.

16, Background

of

Willie

Johnson.) There is

zero evidence that

Willie,

as

the

person

he

is today,

represents a

hreat to harm anyone.

The

30

-month sentence is

not

only unduly

harsh

in

Willie s

case, but also

disproportionate in

comparison

to

the results of ther

perjury

cases.

In

other

cases, sworn law

enforcement

officials who

perjured themselves despite

their legal obligation to

uphold

the

law



were

sentenced

far

less

harshly.

Sylshina London,

a Chicago

police officer

who was convicted

at rial

on

a charge

that

she

perjuriously

accused a

mourner

in a

funeral procession

of hrowing a

bottle

at

her car,

received

a

sentence of nly

four

-and

-a-half

months.

People v.

London,No. 12

CR 018601

Cook

County);

ee also

Ex.

17,

Mark

Suppelsa, WGN nvestigates: n fficer s

li e

and the

boss

who backed

her

up,

Oct.

6, 2014, wgntv.com.) Pamela Bruce, a Cook County

sheriff

eputy, lso went o

tri l

on a perjury

charge,

which

related

to

her

having lied

about

her

role in

the beating of a

Cook

County

ail

inmate, and she received

probation.

People v. Bruce,

No. 13

CR 4921 Cook

County);

Ex.

18,

Steve Schmadeke,

x

-Cook

ail

guard voids prison

time

for

mentally

ill

inmate s

beating,

Chi.

Tribune,

November

18,

2014,

t l.)

In

other

noted

instances

of perjury

by law

enforcement

officers, no prosecution at all was brought. Ex. 14,

Amicus Curiae

Brief t

9.)

By

ontrast, Willie

Johnson,

a

disabled

father

of

wo young

children

and

not a sworn law

enforcement

officer,

and who did not

go to

tri l

but

pleaded

uilty, received

30

months

in state

prison.

The

severity of

illie s sentence

only

adds to his prosecution s

chilling

effect on

truthful

recantations.

The

unnecessarily

harsh and disproportionate nature of is 30-month sentence adds

yet another ground

for

executive

clemency

—

at minimum, is

sentence should

be

commuted

to

no

prison

time

so he may be released immediately.

I~i~~K~~[~Ily

~]~I

The perjury prosecution of Willie Johnson

creates

an

unacceptable

risk

of

iscouraging

future recantations of false testimony or identifications in criminal

cases.

The

23

former

prosecutors

and

judges who filed

an

amicus brief

in

this case

were correct, and

the

Cook

County

State s

Attorney underscored the

point

of he 23 former judges

and

prosecutors when she said

she would not

bring

a

recantation perjury

case without

being

able to

prove

the

falsity of

the

21



recantation, only to bring the single

recantation perjury

case

her

office

can

remember by

asserting that the

recantation's

truth

or falsity

was

irrelevant and

not a

matter

to

be

considered

by

Willie's

jury. Willie's

perjury

prosecution, and his

unduly harsh and

disproportionate

30-

month

prison sentence,

are

a

paradigm

for

the

concerns

about

chilling

of ruthful recantations.

Future

witnesses prepared to

recant can be told

—correctly —that they

will

be

cannon fodder

for

perjury

prosecutions just

as

Willie was. Willie should

receive executive clemency

immediately,

notwithstanding

the

arguments that the State's

Attorney has made

publicly

and

repeatedly

as to

his guilt,

as

attached hereto.

The

State's

most

trenchant

argument

o the

23

former

judges and

prosecutors,

was

that

Willie's

prosecution would not chill

truthful

recantations

because no

such perjury

case should

ever

be brought

in

the absence

of roof, beyond a

reasonable

doubt,

of

he

recantation's

falsity.

But

in

the

end

he

State

was unwilling

to

apply ts

prescription

to

the

only recantation perjury

case t

was

prosecuting. Willie's

perjury prosecution became a prime example

of

how

recanting

witnesses

so

easily can

and

will

be charged

with

perjury

when the

prosecutor does not

believe

the recantation.

ow

that

recanting witnesses

will

see

from Willie's

prosecution that

they

are

provably guilty

of erjury from the

moment

they

recant,

without

the ability to

demonstrate the

truthfulness of

heir recantations, executive

clemency s appropriate and should be

granted

to

Willie forthwith.

22



V

PRAYER FOR

RELIEF

For

the

foregoing

reasons we

respectfully

request that the

Governor pardon Willie

Johnson and expunge his

October

7,

2014

conviction

for

perjury. In the alternative

we

respectfully

request

that his

30

-month prison sentence be

commuted to no term

of

ncarceration

resulting

in

his

immediate

release.

Dated:

December 3,2014

Gabriel A

uentes

Andrew

W ail

Justin

C.

teffen

JENNER BLOCK

LLP

353 N

lark

St.

Chicago,

L

60654

Telephone:

312) 22-9350

Facsimile: 312)

27-0484

Respectfully

submitted,

WILLIE

JOHNSON

By:

One

of is Attorneys

23



DE L R TION

I

Willie

Johnson eclare under penalty

of

erjury

that

ll

of

he

assertions

made

in

this

petition are

complete

ruthful and accurate.

Willie Johnson

Subscribed

and

sworn to before me

this

day

of

014.

Notary Public



CER

TIFI

CAT

E OF SE

RVIC

E

I Gab

riel

A.

u

en tes

, an

attor

ney

h

ereby

cert

ify t

hat

a ru

e

an

d

corr

ect copy

of

he

Pet

ition

of

ill

ie J

ohns

on

fo

r

E

xecu

tive

C

leme

ncy

was

se r

ve d by

UP

S

vern

ight

mail

this

3rd

Day

of

Dece

mber

upo

n

e

ach of

he f

ollow

ing:

Ho

n.

Jud

ge

D

enni

s Porter

Circu

it

Co

urt

of

Co

ok

C

ounty

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llin

ois

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on

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venue

, R

oom

60

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Hon.

An

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varez

S

tate s

A

ttorn

ey of

C

ook

Co

unty

9

W

ashi

ngton

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uite 3

200

Ch

icag

o IL

60

602

Cam

Ga

briel

A.

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ntes

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ub scr

ibed a

nd

swor

n

to

be

fore me

this .1~~

a~

da

y

of ~,

c.r~,~,I

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014.

-~~

N~o

ary

Pu

blic

~

OFFIC

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SEA

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1f

lE~ST

ER

NOTARY

UBIiC

,

S

TATE

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LLi

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MY

COMMIS

SION

EXPIRES

9-2

9-2015

Gab

riel A.

uente

s

And

rew W ail

Ju

stin C.

te

ffen

JE

NNER

BL

OCK

LLP

3

53 N

.

lark St.

Chic

ago,

IL

6

0654

T

eleph

one:

312)

22

-9350

Fac

simil

e: 3

12)

2

7-04

84

C

ouns

el

or

W

illie

Johns

on

Johnson's petition for Executive Clemency

Documents

Transcript of Johnson's petition for Executive Clemency