July 1928 DOJ Document (proposed witness testimony for the last retrial of Hale and Ramsey):
HARRY CORBETT, Fairfax. Okla, made signed statement to effect John Ramsey had told him prior to the killing of Henry Roan that defendant, Hale, had bought him a new Ford carto do a job for him (Hale). Frequently during January 1923 Ramsey called at Corbett home in a new Ford car.
MATT M. WILLIAMS, Pawruska, Okla., made a statement Hale had "propositioned" him to "bump" Henry Roan off, and later told him he had gotten John Ramsey to do the job....Will testify that W.K. Hale told him a short time before Henry Roan was found dead that he had a $25,000 insurance policy on Roan's life.
O.C. WEBB, Fairfax, Okla., made signed statement that he overheard conversation between John Ramsey and W.K. Hale prior to killing of Roan, at which time John Ramsey told W.K. Hale: "We are read to go. Everything is ready to go"; and W.K. Hale said, "Be sure and don't fail." W.K. Hale told Webb the night of his arrest that he would depend upon him to "stand pat."
CHARLES DOTY, Webb City, Okla., gave signed statement referenc[ing] statement by Whitie White of Webb City relative to defense attorney giving him $500 to testify falsely at [first] trial of case.
BOB PARKER, Witness, Fairfax, Oklahoma. Will testify that Henry Roan was well known to him; that about Feb. 6, 1923, George Pratt reported to him the finding of a car in Sel Smith's pasture; that he and Jim Rhodes of Fairfax proceeded to car, in which was found the dead body of Henry Roan, and where an examination of the car and body was made.
W. C. SPURGEON, Witness, Fairfax, Oklahoma. Will testify that he was well acquainted with Henry Roan during his lifetime, and that he examined the body of Henry Roan when it was found on Feb. 6, 1923, he being a member of the coroner's jury. Mr. Spurgeon can testify as to the position of the body and wounds.
DR. J. S. SHOUN, Fairfax, Oklahoma. Will testify that he knew Henry Roan well during his lifetime and that he made an examination of the body and wounds.
T. B. WHITE, Warden, Federal Penitentiary, Leavenworth, Kansas. Formerly special agent in charge, Oklahoma City, can testify as to statements made by W. K. Hale and John Ramsey at Guthrie, Okla., at the time of their arrest. Mr. White will further testify as to a conversation with Hale at the Federal Penitentiary, Leavenworth, Kansas, since Mr. White has been warden, and during Hale's present incarceration at that institution, at which time and place Hale told Mr. White that he had always been very sorry for the lies he told on the witness stand to the affect that Mr. White and other government agents had used an electric cap and other harsh means on him, and further that he (Hale) had told his wife and attorney that he was going to apologize to Mr. White for the lies he had told.
FRANK S. SMITH, Witness, Special Agenty, Dept. of Justice, Phoenix, Ariz. Will testify with reference to interview had by him with W.K. Hale and John Ramsey at Guthrie, Okla., at the time of their arrests.
JOHN McCLAIN, Witness, Agent, Mutual Life Insurance Co., Tulsa, Okla. Will testify that he met W. K. Hale in Pawhuska, Okla., in the year 1921 and inquired of Hale of the names of Indians on the live of whom he might write life insurance, telling Hale that he had been talking to Henry Roan, but did not know that Roan could procure a policy, when Hale asked "What Henry Roan?" Hale then remarked, "I will take that bet, and pay the premium, and make it payable to me." An application was made on the life of Henry Roan's life, but was declined.
DR. W. H. ARON, Witness, Pawhuska, Okla. Will testify that he represented as examiner the Mutual Life Insurance Company of New York, of which Hohn McClain was Agent in 1921 and examined Henry Roan for that company, likewise for the policy in the Capitol Life Insurance Company of Denver for $25,000 payable to W. K. Hale. Dr. ARon will further testify that at the examination of Henry Roan he asked Bill Hale, who was present, if he was going to kill the Indian for his insurance, and who was the beneficiary; that Hale answered "Oh God, I am--hell, yes!"
ERNEST BURKHART, Witness, Oklahoma State Prison, McAlaster, Oklahoma. Nephew of Defendant Hale; will testify that in the fall of of 1922 he and W.K. Hale met John Ramsey at the home of Henry Grammer (deceased), Hale and Ramsey having a conversation by themselves; that on this occasion Hale told Burkhart that he had a life insurance policy on the life of Henry Raon and that John Ramsey was the man he could depend on to "bump" Henry Roan off. Burkhart will also testify as to a conversation with Hale in which he (Hale) stated that he was going to take John Ramsey to Pawnee, Okla. to get Ramsey a car, and would give Ramsey $500 to buy the car....Burkhart will also testify as to a conversation with John Ramsey relative to Ramsey purchasing a car at Ponca City, Okla., a few days later; as well as to a conversation with John Ramsey at Fairfax, Okla., about thirty minutes after Henry Roan was killed, during which conversation at Fairfax Ramsey asked Burkhart where Bill Hale was--that he (Ramsey) wanted to see Hale that night; that Ramsey requested Burkhart to see Hale and tell him the job was done, that he had "bumped" that Indian off in a canyon out in Sol Smith's pasture; and further tell Hale that Ramsey was going to his home in Ripley....In addition, Ernest Burkhart further stated that his brother, Horace Burkhart, had told him that M. C. Bosarth of Fairfax, Okla., during a conversation between Bosarth and Horace Burkhart, remarked that a short time before Henry Roan was killed he (Bosarth) saw Bill Hale and John Ramsey playing pool in either McElroy's or Evans' pool hall at Fairfax, that Hale put up his cue, telling Ramsey to meet him some place (Horace did not understand where); that Hale and Bosarth went out the front door of the pool hall, and Ramsey went out the back door, Hale and Ramsey meeting a short distance away, when Hale called Ramsey aside and gave him some money...