The Clay Shaw trial testimony of Lyndal Shaneyfelt
February 14, 1969
MR. OSER: Two of the Assistant United States Attorneys requested permission to sit in the court room while Mr. Shaneyfelt testifies from the FBI.
MR. DYMOND: No objection.
LYNDAL L. SHANEYFELT, having been first duly sworn by the Minute Clerk, was examined and testified as follows:
DIRECT EXAMINATION BY MR. OSER:
Q: Would you state your full name for the record, please.
A: My name is Lyndal L. Shaneyfelt, L-y-n-d-a-l, middle initial L, S-h-a-n-e-y-f-e-l-t.
Q: Where do you reside, Mr. Shaneyfelt?
A: I reside at 6125 Vernon Terrace, Alexandria, Virginia.
Q: By whom are you employed?
A: As a Special Agent for the Federal Bureau of Investigation.
Q: How long have you been a member of the Federal Bureau of Investigation?
A: I have been employed by them since 1940, December of 1940, I have been a Special Agent since 1951.
Q: What are your present duties as a Special Agent for the Federal Bureau of Investigation at this time?
A: I am assigned as a Document Examiner and Photographic Specialist in the FBI Laboratory.
Q: During the year 1963, what were your duties with the FBI?
A: The same, as a Document Examiner and Photographic Specialist.
MR. OSER: If the Court please, the State is going to attempt to qualify Agent Shaneyfelt as an expert in the field of Photography and a Photographic Specialist with the FBI. THE COURT: Proceed.
BY MR. OSER:
Q: Can you describe for the Jury and for the Court what your duties consist of as a Photographic Specialist for the Bureau?
A: Yes, I assist in the training of our agents in photographic matters, I have worked in photographic work in the FBI almost entirely since I have been there, in early years as a photographer and as a Special Agent Document Examiner, and I handled photographic assignments. I was a newspaper photographer before entering the FBI in 1940 for approximately three years. My present duties in the laboratory for the past several years have been the examination of photographic evidence submitted by local law enforcement agencies as well as our own officers and an example would be the comparison of film recovered from a victim of a theft of his camera with the camera recovered perhaps in a pawn shop or from a suspect, to identify that film as having been exposed in that camera, that is a photograph to determine whether or not they are composites or fraudulent or fake photographs, things of that type.
Q: Mr. Shaneyfelt, during a one-year period approximately how many photographic examinations would you make, approximately?
A: Oh, I would have to guess, I would guess in the neighborhood of seventy-five to one hundred.
Q: And you have been in the photographic field for some thirty-odd years, is that correct?
A: Yes.
Q: Have you ever been called upon to testify and be qualified as an expert in the field of photography before any Commission or Board, such as maybe the Federal Trade Commission, or things of this type?
A: Yes, I have testified before the Federal Trade Commission, the Immigration and Naturalization Service hearings, as well as Federal and District Courts, local courts.
MR. OSER: I tender him on the point.
MR. DYMOND: No questions.
THE COURT: Is it permitted?
MR. OSER: Yes, Your Honor.
THE COURT: Now the Court will rule that the witness has qualified as an expert in the field of photography and can give his opinion with respect thereto.
BY MR. OSER:
Q: In the course of your employment as a Special Agent with the FBI, did you have occasion to assist in the investigation of the assassination of President John F. Kennedy?
A: Yes, I did.
Q: Are you familiar, sir, with the location commonly known as Dealey Plaza, Dallas, Texas?
A: Yes, I am.
Q: Mr. Shaneyfelt, I direct your attention to "State Exhibit No. 34," and ask if you can identify what is depicted in this photograph, sir. You may step down, if you wish.
A: yes, I would recognize that as Dealey Plaza, an aerial photograph of Dealey Plaza.
Q: I direct your attention to "State Exhibit No. 36," a model mock-up, and ask if you are familiar with what is depicted in this exhibit. You may step down.
A: Yes, I recognize it as a generally, generally a mock-up or model of Dealey Plaza. There are some areas of it that I don't feel represent it exactly, but it is generally a mock-up.
Q: It is not to scale, sir?
A: No.
Q: I now direct your attention to "State Exhibit No. 35," a large plaque over here, and I ask if you can identify what is depicted on this particular plaque. You may step down, sir.
THE COURT: I notice that you haven't blotted out that hearsay that Mr. Dymond objected to.
MR. OSER: I think we will handle that matter with this particular witness. I spoke to Mr. Dymond.
THE WITNESS: Yes, I recognize the plaque.
BY MR. OSER:
Q: Would that plaque purport to be a certain portion of Dealey Plaza, Dallas, Texas?
A: Yes.
Q: Mr. Shaneyfelt, during your investigation, did you have occasion to examine various photographic matter that was taken allegedly at the time of the assassination in Dealey Plaza?
A: Yes, I did.
Q: I am going to show you and ask you to review this film and tell the Court and the gentlemen of the Jury whether or not you are familiar with the contents of this particular film, as to whether or not you have seen it before and as to whether or not you used any portion or contents thereof in your investigation.
MR. DYMOND: At this point, if the Court please, we have an objection which we feel should properly be made out of the presence of the Jury.
THE COURT: Out of the presence of the Jury?
MR. DYMOND: Yes.
THE COURT: Take the Jury upstairs, please.
(Whereupon, the Jury was removed.)
MR. DYMOND: If the Court please, at this time we object to a re-showing of the Zapruder film in the presence of the Jury. They have seen it three times already, once in regular motion, once in slow motion, and once frame by frame. I feel there is no reasonable, there is no reason for re-showing this bit of State's Evidence. We feel that this expert witness is undoubtedly familiar with the Zapruder film, has worked with the Zapruder film, and if asked whether he has worked with it, will know what is meant by the Zapruder film. I think he can testify to that but we object in the presence of the Jury to the showing of the film because it is repetitious.
MR. OSER: This is State's Exhibit which has been introduced into evidence. I think the State has a right to show this film as it sees fit in the proof of its case and certainly in connection with the testimony of Mr. Shaneyfelt. It will be tied up as to how important it is in Mr. Shaneyfelt's work at the time of his investigation.
THE COURT: The Court cannot direct the State to not prove its case, if he needs the exhibit in connection with his case, I don't see how the State cannot show the exhibit because it may or may not be necessary. Perhaps Mr. Shaneyfelt will have to see it to know whether it is the film he is familiar with.
MR. DYMOND: I think the witness does know what is on the Zapruder film.
THE COURT: How does he know?
MR. DYMOND: It has been identified as such, you can show it to him out of the presence of the Jury and let him see whether it is.
THE COURT: I can't control the way that the State will try to prove its case.
MR. DYMOND: You can control what may be accentuated to the Jury, if the Court please, that every time you show the Jury the film, that is accentuating a particular piece of evidence and that is what we are objecting to. You have shown it three times already.
THE COURT: I can't tell the State how to prove its case and you know I can't. I overrule your objection. If he thinks it's necessary to show it to the witness, I will permit him to show it to the witness and apparently he does, as his statement indicates, he feels it is necessary. I will overrule your motion.
MR. DYMOND: I think it is up to Your Honor to determine if that is necessary to do that before the Jury or out of the presence of the Jury.
THE COURT: Is it your purpose first to Mr. Shaneyfelt the film to see if he recognizes it and then after the Jury comes back, to show it again like we did with Mr. Zapruder?
MR. OSER: That is correct, Your Honor, and to use certain portions of the particular film. Mr. Shaneyfelt is the one that did the reconstruction, he can testify as to the hearsay matter that was on here before.
THE COURT: Let's work it first like we did yesterday with Mr. Zapruder, show the film to the witness so he can first identify that is the film and when the Jury comes back, you can show it again and let him testify. We have a Sheriff on the lights.
MR. DYMOND: We would also like to make an objection on the grounds of relevancy as we did yesterday.
THE COURT: I ruled on that yesterday.
(Whereupon, the film was run.)
THE COURT: Do you wish to question the witness out of the presence of the Jury?
MR. OSER: Yes, a couple of questions, Your Honor.
BY MR. OSER:
Q: Mr. Shaneyfelt, after having reviewed this film, can you tell us whether or not you had occasion to view a film containing the same scenes as you saw this morning during our investigation?
A: Yes, this appears to be the same sequence of events.
Q: Can you tell us whether or not any particular things are missing out of this particular film from your --
A: I cannot tell that from viewing it on the screen. I would have to count the frames and study the film more thoroughly.
MR. OSER: That's all.
THE COURT: Bring the Jury back in.
(Whereupon, the Jury was brought in.)
MR. DYMOND: What is the exhibit number on that film?
MR. OSER: Thirty-seven.
MR. DYMOND: At this time we object to the repetitious showing of the "State Exhibit 37," known as the Zapruder film, on the grounds, first, it is irrelevant to the proceedings, secondly on the grounds that the Court has repeatedly ruled during the last approximately two years of these proceedings that the incidents in Dallas had no connection between this case and those incidents, and thirdly that on the voir dire in this case, Your Honor ruled that we could not question prospective jurors as to any fixed opinions, as to incidents in Dallas.
THE COURT: I overrule the objection.
MR. DYMOND: To which ruling Counsel reserves a bill of exception, making all showings of "State Exhibit S-37," the testimony of this witness, the Defense objection, the Court's ruling, and the entire record up until this time, parts of the bill, also including "Exhibit "S-37."
BY MR. OSER:
Q: Mr. Shaneyfelt, we ask you to review this particular film and tell us whether or not you had occasion to use what is depicted in this film during your investigation of the assassination of President Kennedy, if you would.
(Whereupon, the film was shown.)
BY MR. OSER:
Q: From having viewed the particular film, can you tell the Court and the Gentlemen of the Jury whether or not you had occasion to view a film depicting the same scenes in your investigation?
A: Yes, this appears to be the same sequence of events as the film that I worked with in my investigation.
Q: Can you tell us whether or not the Bureau also had a ballistics expert working along with you in your investigation?
A: Yes, they did.
Q: Who is that, sir?
A: Mr. Robert Frazier.
Q: Was anyone particularly in charge of the investigation or were the duties split up between you and Mr. Frazier on the photographs and the ballistics work?
A: The members of the Warren Commission were in charge of the re-enactment investigation. Mr. Frazier and I had specific duties relative to what we did for the Commission.
Q: In other words, am I correct in stating you did the basic -- you did basically the photographic work and Mr. Frazier did the ballistics work?
A: Yes.
Q: In conjunction with each other?
A: That's right.
Q: Can you tell us what type of film this is, Mr. Shaneyfelt, what millimeter?
A: Eight millimeter.
Q: Will you define for us what is meant by frames in an eight millimeter film in the field of photography?
A: Yes. Motion picture films are made up of a series of still pictures taken in rela- tively rapid sequence. In each one, each picture on the film is a separate still picture and is considered as a frame or one frame of the motion picture is one still picture, and these are recorded by the camera in rapid sequence in such a way as when they are projected at their proper speed, you get the sensation of a constant picture, the eye does not see each individual picture being flashed on the screen but sees instead photographs of a moving subject.
Q: I show you what the State has marked for purposes of identification "S-33," and I ask you to view this photograph, tell me whether or not you had an occasion to use what is represented in this photograph during your investigation, sir.
A: Yes, I recognize this as a photograph that I examined.
Q: Mr. Shaneyfelt, during your investigation did you have occasion to make any reprints or prints from the film that you viewed and that you recognized this morning in court, any black and white photographs or color photographs?
A: Yes, I made a set of black and white prints of a number of selected frames of the Zapruder film that I examined.
Q: In using this particular film that you have identified this morning as having seen before, did you have any occasion to number the frames in that film which you used, sir?
A: Yes, I did.
Q: How did you go about that, Mr. Shaneyfelt?
A: In order to be able to relate the various frames to each other and to keep track of specific frames, I numbered them beginning with No. 1 at the first frame on the motion picture film that I examined that shows any part of the Presidential parade, or the first time he comes into view, well, the first part of the film were personal pictures, pictures of a personal nature, and I disregarded those and went down the film, the motorcycles first came into view on the motion picture film, the first frame of that I numbered it No. 1 and I numbered the frames consecutively through to the end of where you last see the Presidential limousine go out of sight.
Q: How many frames did this film contain, sir? You may refer to your notes.
A: I doubt that I have that figure in my notes. I would have to estimate that it went into the late three hundreds or early four hundred frames, I don't believe it is in my notes.
Q: So somewhere around four hundred frames that -- would that be a safe estimate?
A: That would be a safe estimate.
Q: Now, pursuant to your investigation, did you have occasion to go to Dealey Plaza in Dallas, Texas, and conduct any type of examination of this area?
A: Yes, I did.
Q: When did you go there, sir?
A: On May 24, 1964.
Q: Did Mr. Robert A. Frazier, a ballistics man from the FBI, accompany you?
A: Yes.
Q: Basically, can you first tell us what you did in Dealey Plaza that particular time, sir, what was your purpose in going there?
A: The purpose in going to Dealey Plaza was to re-enact, using a car, and individuals of the approximate size of the President and Governor Connally, to reposition the car as it is shown in the Zapruder film and other photographs, in order to establish if possible the direction of the shots, the sequence of the shots, the timing between shots, if possible, the location of the car at the time a particular shot was fired, in an effort to obtain any information that would assist the Warren Commission in reaching a conclusion in their investigation. That was in general what the purpose was.
Q: From your examination of the Zapruder film and the work you did at Dealey Plaza were you able to ascertain the average speed of the Presidential limousine, the President's limousine, while it was on Elm Street?
A: Yes. The average speed was ascertained in one specific --
MR. DYMOND: We object unless this witness ascertained the speed of it.
BY MR. OSER:
Q: Did you examine the Zapruder film and ascertain the average speed of the President's limousine on Elm Street yourself, sir?
A: Yes, I did, yes.
Q: How did you go about this, sir, what was the result of your examination?
A: This complete finding was based on a determination first of the average speed of the Zapruder camera, and a determination of the speed with which the sequence of events took place based on the speed of the camera, then during the re-enactment, measurements were made on Elm Street from the specific frame numbers, once they were ascertained, and I took the frame, the frames from Frame 161 to Frame 313 and determined -- it took the distance, computed this base don the number of frames involved, the speed at which the Zapruder camera operated, found that the average speed over that period as between 161, Frame 161 and Frame 313 was 11.2 miles per hour.
Q: What was the speed of the Zapruder camera as you found, sir, when you examined it?
A: The average speed of the camera was 18.3 frames per second.
Q: How did you ascertain this, sir?
A: Using Mr. Zapruder's camera, I loaded it with film and photographed a clock that had a sweep second hand. I then, by examining the film after it was processed, under the microscope I could see when the second had was on right up at 12:00 o'clock and counted the frames until the hand got down and made a full circle, giving the number of frames per minute and breaking that down to the number of frames per second. This was done on successive rolls of film and averaged throughout the film, and motion picture cameras almost all slow down toward the end of the run when the spring, this was a spring-wind camera, and when the spring runs down, there is a tailing off. I average the speed without taking the tailing off into account because of the fact that the film was taken with the film full -- with the camera fully wound. This averaged out to be 18.3.
Q: Now, at the time that you were in Dealey Plaza in may of 1964, -- do you want me to put the -- may I put the screen down?
THE COURT: Yes. Do you wish that aerial photograph to be put up there?
BY MR. OSER:
Q: During the construction that you testified that you conducted, was Mr. Robert West present, the surveyor from Dallas County?
A: Yes, he was.
Q: Did he assist you all in this capacity as Surveyor?
A: Yes.
Q: During the reconstruction, Mr. Shaneyfelt, in relation to the Zapruder film where did you all start, at what frame, sir?
A: We started the re-enactment at a point earlier than is shown on the Zapruder film the first frame that we designated in which the Presidential limousine appears was Frame 161, to the best of my recollection.
Q: During your reconstruction, did you have occasion to use Frame 168?
A: Yes, we did.
Q: What did you do in regard to Frame 168, what type of examination and reconstruction did you all do?
A: Could I step down and look at the plaque?
Q: Yes.
A: That is marked Frame 168.
Q: How did you all mark that frame, sir, how did you arrive at that position?
A: We knew the position of Mr. Zapruder, we knew the position of the Presidential limousine from the photograph as being in between the white lines of Elm Street, and with Mr. Frazier in the window, with the Presidential limousine positioned in the street on the route that was established from the film, and with Mr. Frazier, Robert A. Frazier of the Laboratory in the sixth floor window of the Book Depository building, with the rifle that was recovered from that building, he viewed through the rifle and watched through the telescopic sight of the rifle as the car moved down Elm Street, when the car reached a point where the President was about to go out of sight under an elm tree that covered the street, or a tree that covered Elm Street, I am sorry, the car was stopped, asked that the car be stopped and we positioned it exactly at the point just before the President would go under the tree from where the rifle, where he was viewing with the rifle, and once the positioning of the car in that place, I then with still photographs made from Mr. Zapruder's film took a position on the abutment where Mr. Zapruder took his motion pictures, and by going through the photographs and aligning objects in the background with individuals in the car, particularly the President, determining where a part of the building was directly above his head or a tree was just to the side of his head, I established through the photographs that this was representative of the spot that the car was in at the time Frame 168 was in focus.
Q: Now, Mr. Shaneyfelt, where 168 appears on that plaque, am I correct in stating that the dot next to 168 represents the position of the location of President Kennedy within the limousine at that time. Is that correct?
A: That is correct, the limousine that we were using for the re-enactment was not the limousine that the President was riding in, and we had to make an adjustment because the stand-in was sitting ten inches higher than the President was sitting, ten inches higher from the street, so after positioning Frame 161, we moved the car forward until we could just barely see the spot on the back of the -- the approximate spot where the President was hit on the back, this appeared based on a ten-inch adjustment, so that we take into account the last clear place that the President could have been shot just before going under the tree.
Q: No --
A: That was the established -- we established Frame No. 171.
Q: Which car was used for the reconstruction?
A: The car that we referred to as the car which was a Lincoln, yes, a Lincoln.
Q: I show you again that which is marked as "S-33," and ask you whether or not the car that you used during the reconstruction appears in that
photograph.
A: Yes, the car that the men are standing on the running board of.
Q: Mr. Shaneyfelt, during the re-enactment, did you have occasion to deal with and compare around Frame 207 and 208 and 210?
A: Oh, yes.
Q: And what did you all do in regard to those particular frames?
A: The Frames 207 and 208 specifically were used as the points where the Presidential limousine emerged from under the tree and the agent Frazier in the window first would get a clear shot of the stand-in for the President to see him through the rifle scope, and that position was ascertained by Mr. Frazier from the window and then using the Zapruder film, I established that as being Frame 207 and Frame 208 on the Zapruder film.
Q: What other frames did you deal with that are related on that plaque?
A: Well, we dealt with Frame 185 and 186, and Frames 185 and 186 represent the position of the President in the limousine where Mr. Frazier in the window could see him through the rifle scope as it passed under an opening in the tree. There was an area in the tree that there were no leaves, and looking through the scope, he got a momentary look at the stand-in for the President in the limousine, indicating a clear shot could have been fired from there. And Frame 185 and 186 are the frames that I have determined them to be standing at the Zapruder spot and checking them with the photographs, 185 being the frame and adjusted frame based on the ten-inch difference in the two cars.
Q: Now, which frames did you all deal with after the 210 series?
A: 208 was the last one?
Q: Yes.
A: Frame 222 was the next frame that -- that was, I might say, Frame 208 is the last frame that we established by having Mr. Frazier view through the rifle, all of the rest of the frames were established, beyond that point were established by other landmarks, by me when I was standing here with Zapruder was standing. The next frame was Frame 222 which represents the first frame where Governor Connally's face comes into view after the Presidential limousine had gone past the signboard, so they were out of view from Mr. Zapruder's camera at the frames 205 and 206 they disappeared behind the signboard, and that signboard and that signboard until Frame 222, and of course the Governor Connally, Governor Connally's face, the next frame that we have established was 225 or 223, 223 is the next frame that is on here, 225 is the actual frame, the next frame we established as being the first frame of where President Kennedy emerged, we first see his face, it is listed as 225 in the chart, and the next frame we have located was Frame 231, which was a frame that the Commission wanted established based on the evidence indicating --
Q: Nothing hearsay.
A: Well, Frame 231, 235, 240, 249, 255 were all established based on the request of the Commission. The last frame to be established was Frame 313, which is the frame of the Zapruder film where the shot hit the President, President Kennedy, in the head and it is quite obvious on the film.
Q: Frame 313 is the one where we see the red halo, is that correct?
A: Yes.
Q: Now, Mr. Shaneyfelt, from your examination of the Zapruder film in this area and dealing with frames around 207 and 208, in this the area in which the President disappeared behind the sign in the Zapruder film?
A: Yes.
Q: Is this the last time you can see him?
A: The last time? It is not the last time you can see him because you can still see the top of his head, but it is the last time you see, well, at Frame 205 or Frame 206 are the frames where you last, as I recall, the frames where you last see the face, his face, and then he disappears behind the sign, you can still see the top of his head for several frames, as I recall.
Q: At Frame 205 and 206, can you describe for us what President Kennedy is doing as depicted in the Zapruder film?
A: I am not sure I could do that based on my recollection without having those photographs, specific frame photographs in front of me. My recollection is that as he disappeared behind the signboard, he is turned slightly to his right, his arm is up and he is waving and smiling. Now, that is still in progress, my recollection is that is the last we see of the President as he goes behind the signboard, he is still waving and smiling to the crowd and turned slightly to his right.
Q: What is the first frame that you saw the President come from behind the sign?
A: That is Frame 225, when we first see the President's face.
Q: And what are the President's reactions or actions or motions at that particular time that you saw the Zapruder film?
A: It would be frames -- I would have to relate it to Frames 225 or 226 and 227, because the first frame is a rather indefinite frame because you don't get the movements and you have to see the motions of those first frames to get the feeling of it, but I get the impression of a reaction as he is coming out from behind, he is no longer smiling and he is -- his face appears to be more tense and seems to be reacting to something.
Q: In Frame 225, Frame 226, did you see him still waving?
A: No.
Q: What was he doing in regards to his hands, as you recall?
A: Of course, Frame 225, only the face is visible, just emerged from the signboard, the shoulder is not visible, and in Frames 226 and 227 his hands are more in a position as -- he was going to -- his left hand before he went behind the signboard was on his left lapel with this hand raised, and as he comes out this other hand was more over towards the right lapel or this position and in the succeeding frames, 226, 227, 228, he is going into -- his arms are coming up and he is going into a position with his arms raised and his hand raised towards his coat lapel or towards the center of his body.
Q: Now, in using Frame 208, you say the last frame you could see the President before he goes behind the sign, Frame 225 and Frame 226 as he comes out from behind the sign, how many frames is that, Mr. Shaneyfelt, 208 to 225?
A: Your question was that I said he went behind the sign at 208, I said he went behind the sign at 205 and 206, I believe.
Q: All right.
A: To 225?
Q: Right.
A: That is twenty frames.
Q: Now, using the Zapruder camera, the pictures at an average of 18.3 frames per second, how much time elapsed during that period between 205 and 225?
A: That would be slightly more than one second, since you have 18.3 frames per second, twenty frames would be just two frames past or about one-ninth of a second, approximately.
Q: At Frames 225, 226 and 227, can you tell us what the reactions are, what Governor Connally was doing?
A: Governor Connally was, when we first see Governor Connally in Frame 222, in the film, he is turned slightly to his right, as I recall, and then in succeeding frames his body is turned more straight and slightly to the left, as I recall, I can't be too sure of that because --
Q: After Governor Connally, as you have testified, seemed more straight, what was Governor Connally doing in succeeding frames after this?
A: He falls over into his wife's lap.
Q: Can you tell us at what frame this is?
A: No, I can't, without reference to the exhibits or some photographs.
Q: From having viewed this photographic evidence, Mr. Shaneyfelt, what is your expert opinion, sir, as to when President Kennedy was hit for the first time, between what frames?
A: Well, I am not sure that my expertise is in that field, but he is waving before he goes being the sign at 205 and 206, and that Frames 225, 226 and 227 he appears to be reacting, and it is my impression the shot would have occurred then somewhere between Frame 205, and 206, 210, up to Frame 222 or even as far as 230, I could not pinpoint it any closer than that because I haven't experience in that field.
Q: At which time the car, the Presidential limousine was behind the sign in the Zapruder film. Is that correct?
A: The majority of that time it is behind the sign.
Q: And further having examined the Zapruder film, can you give us your expert opinion as to when Governor Connally was hit, and approximately what frame does it reflect?
A: In my examination of the photographs, I found no particular frame where there is any specific reaction, and my opinion would have to be based more on his position and obviously it is before he feel into his wife's lap, but I fee that it is my opinion that he was hit about Frame 2-- well, I feel that he had been hit by Frame 231 to 232, by that time he had been hit, somewhere prior to that I feel -- my opinion is that he was hit about the same time as President Kennedy was, there is not such a marked reaction so there is nothing in the film that can tell me at what frames he was hit, not knowing enough about human reactions, I really have difficulty answering that.
Q: In relation to Governor Connally's reaction, did you have occasion in your examination of the Zapruder film to measure the area of Governor Connally's shoulders as to whether or not there was an quick movement or downward movement in Governor Connally's shoulders as it appears in the Zapruder film?
A: I found nothing of that nature during my examination of the film.
Q: Did you measure this to ascertain it?
A: I did not measure it.
Q: Did you have occasion in your examination of the Zapruder frames in relation to Governor Connally to examine the facial area of Governor Connally as he appears in the Zapruder film to ascertain as to whether or not there is a sudden puffing of his cheek area?
A: I did not measure that.
Q: Between Frames 205 and Frame 232 of the Zapruder film, approximately how much time elapsed using the Zapruder film, the Zapruder camera on the clock, 205 and 232?
A: That would be twenty-seven frames, approximately 1.4 seconds, between Frames 205 and Frame 232.
Q: Now, in doing these frames, I think you had marked on there 207 and 208 on the plaque, is that correct?
A: I believe that is right, 207 and 208.
Q: Between Frames 207 and 208 of the Zapruder film and Frame 223 and 225 on the plaque, were you able, were you all able to calculate what the vertical angle was from the sixth floor of the Texas School Book Depository?
A: Yes. The angle measured at Frame 207 and 208 and then 222 -- you said 227 and 228?
Q: 225.
A: 225, yes, all right, that vertical angle to the window of the sixth floor of the Depository building was determined.
Q: And what was that angle?
A: I can get it from the plaque. You asked for the average --
Q: The average --
THE COURT: This might be a good time for us to take a break, Sheriff. Take the Jury upstairs. We have not coffee for them. We will take a five-minute recess.
(Whereupon, a recess was taken.)
AFTER THE RECESS:
THE COURT: Is the State and the Defense ready to proceed?
MR. DYMOND: Yes, Your Honor.
MR. OSER: Yes.
(Whereupon, the question was re-read by the reporter.)
THE WITNESS: Yes, I computed the average angle from Frames 210 to -- from 210 to Frame 225, and determined that average angle to be 17 degrees, 43 minutes and 30 seconds. This takes into account a 3 degree, 9 minute grade of Elm Street.
BY MR. OSER:
Q: Now, Mr. Shaneyfelt, can you tell us whether or not you calculated the angle from the sixth floor of the Texas School Book Depository in regard to Frame 313 of the Zapruder film?
A: Yes, I did. That angle, taking into account the street grade, is 12 degrees and 12 minutes.
Q: Now, speaking of the angle, Mr. Shaneyfelt, that you all calculated, these were the angles from the sixth floor of the Texas School Book Depository down to the very spot as indicated on this plaque. Is that correct?
A: That is correct.
Q: And which would be the vertical angle. Is that right, sir?
A: Yes, this is measured on the vertical axis.
Q: Up and down?
A: Up and down toward the direction of the window.
Q: Did you all calculate on any one of these positions as indicated on Elm Street the lateral angle at any time, the sideways angle, if I may call it that?
Q: Did you all calculate that?
A: From what? In other words, the angle from what to where?
Q: From the sixth floor of the Texas School Book Depository to any one of the frames on this plaque.
A: Well, I mean the lateral angle from what to what?
Q: Well, from the sixth floor of the Texas School Book Depository to, say, Frame 313?
A: Now, that is a straight line, so there is no lateral angle involved. Now, if you mean the lateral angle from the street or the curve or the centerline of the car over to that window --
Q: From having viewed the Zapruder film, can you tell us whether or not Governor Connally and President Kennedy were in line with each other, by that I mean one in front of the other, basically?
A: Basically, Governor Connally was sitting in the jump seat immediately in front of President Kennedy, yes.
Q: If I may use Mr. Dymond as Governor Connally and I as President Kennedy, the sixth floor of the Texas School Book Depository would be behind me and to my right. Am I correct?
A: Right.
Q: Did you all calculate the lateral angle from me over to the sixth floor of the Texas School Book Depository? That is the question I am asking you.
A: I still have to have a basis upon which to calculate the lateral angle, because between, you being one point and the window being another point, it is a straight line involved, no lateral angle.
Q: And Mr. Shaneyfelt --
A: Yes.
Q: -- let's see at Frame 313, you said that Governor Connally and President Kennedy were basically one in front of the other.
A: Yes.
Q: If you drew a perpendicular line through these two men at Frame 313 way across this chart, taking that perpendicular line, did you all then draw a horizontal line from the sixth floor down to Frame 313 and calculating that angle --
A: No, we did not.
Q: Did you all do that at any other frames?
A: No, we did not.
Q: Now, you described to the Jury and the Court what type of setup or arrangement you all had with the stand-in models in the car that you all were using. In other words, am I correct in stating that you had one live model representing President Kennedy in the follow-up car. Is that correct?
A: That is correct.
Q: You had another live model representing Governor Connally in the follow-up car that you were using?
A: That is correct.
Q: Now, in regards to the gentleman that was standing in for President Kennedy, did you all do anything in relation to him with any marks on his body so you all could calculate the measurements you were calculating?
A: Yes, the basic setup which we used, we used in the re-enactment, because that was selected, we selected a man of the approximate statute and build of Governor Connally, one of our Special Agents, his height and build, and he wore Governor Connally's coat that he was wearing at the time he was shot on November 22nd. We selected another Special Agent of the approximate stature and size of President Kennedy to sit in his position or be the stand-in for President Kennedy. We placed a mark on the back of the stand-in for President Kennedy at the point of the wound on his back.
Q: You mean the skin wound, into the body?
A: I have no personal knowledge of how that was established, but it was my understanding that it was based on the skin wound.
Q: All right.
A: And we -- all of the measurements that were made, angle and distance and the calculations, everything we calculated in connection with the re-enactment and distances and angles were related to that spot right there, and when the mark was placed in the street for Frame 210, that really meant the spot directly vertically above 210 at a point where that mark on Kennedy's back -- allowing again for this ten-inch difference in the seat height of the follow-up car.
Q: And did you also mark the stand-in or the back of the stand-in for Governor Connally?
A: No, we used the bullet hole in the coat of the stand-in for Governor Connally. We made essentially our measurements primarily from this other spot on the stand-in for President Kennedy, and none of the measurements were made based on -- none of the measurements that were on the plat or the angles to the window were based on anything of Governor Connally because we did not mark Governor Connally, we used the hold in the coat.
Q: Am I correct in stating that you all used the skin hole of President Kennedy and you used the bullet hole in Governor Connally's coat because the stand-in was using Governor Connally's coat. Is that correct?
A: That is my recollection, yes.
Q: Why did not you use President Kennedy's coat?
A: I don't know that.
Q: Why did you not use the actual location of the skin hole in Governor Connally as opposed to --
MR. DYMOND: Objection, the State is trying to impeach its own witness.
MR. OSER: I am asking him what they were doing, Your Honor.
THE COURT: Rephrase your question.
BY MR. OSER:
Q: I will ask you this way, sir: Did at any time you all use the skin hole of Governor Connally?
A: Not to my knowledge, or I have no knowledge of that, no.
MR. OSER: No further questions.
CROSS-EXAMINATION BY MR. DYMOND:
Q: Mr. Shaneyfelt, to the best of your recollection, will you review for us the entire mechanics of this re-enactment from beginning to end, and tell us everything that was done, that you personally know about throughout.
A: Yes. We started the re-enactment quite early in the morning on Sunday, May 24, in order to avoid the traffic problem, and the re-enactment itself, in its entirety, was based on instructions from the Commission which I carried out my portion and others, other individuals carried out their portions and we worked as a team doing the re-enactment, and the re-enactment was based on the evidence available to the Commission so that these things that we did were done for the Commission at their instructions based on some reason that they had for doing it. One of the first things that we determined was the location of the car at the first point that a rifle went from the sixth floor of the School Book Depository building in the corner window would get the -- receive a mark on the back of the stand-in for the President and could have shot and fired a shot into the President's back, and that point was first established.
Q: Now, where was that on the film?
A: That was up just as they rounded the corner, just as they came around the corner from Houston into Elm.
Q: Would you be able to tell us at what frame that would be?
A: Well, the Zapruder pictures do not include that, and therefore we designated it as for, or as Point A on the plaque.
Q: Would you be able to mark that point which has been --
THE COURT: I suggest you use an "S" instead of an "X."
MR. DYMOND: "State 35."
THE COURT: Mark it with an "S."
THE WITNESS: It is already marked as "Station A" or "Point A" on this.
MR. DYMOND: Will you mark, put a circle around that, sir.
BY MR. DYMOND:
Q: Before you go on with your account of the re-enactment, Mr. Shaneyfelt, at this time was there a man up in the sixth floor window of the Texas Book Depository with a rifle with a telescopic
sight?
A: At the time of the re-enactment, when we were there, yes, Mr. Robert A. Frazier, as I previously testified, was up in that window with the rifle, the Mannlicher-Carcano rifle, with the rifle, with the telescopic sight on it that was the actual rifle recovered in the Texas School Book Depository building.
Q: It was the actual rifle?
A: Yes.
Q: Go ahead with your account of the re-enactment.
A: The next position they asked that we ascertain and they were interested in, at what points in the Zapruder film a person in the Texas School Book Depository building could have shot and had a clear view of the President, so that we took into account the tree that was over Elm Street that I previously testified about, and the next positions that we found are located based on the man in the window with the rifle, Mr. Frazier and myself with the Zapruder films established the position that would be the last point on Elm Street where President Kennedy disappeared under the tree. Now, I used the word "disappeared." I probably should not have because the tree, you could actually see through it, but you could actually have seen the President and this -- his car go under the tree on Elm Street.
Q: Would that be around Frame 185?
A: No, I believe that was around Frame 161, 168, the adjusted numbers,
then.
Q: And let me interrupt you once more. Is that point represented on this plaque?
A: Yes.
Q: Would you mind stepping down and putting a circle around that point?
A: Yes, I circled the numbers 168 and 171 on the plaque, I am not completely clear because it has been sometime ago, but it is my recollection that 161 and 168 were the frame numbers when it went under, in that general area of the film.
Q: And that is when you could see the President through the opening in the tree?
A: No, that is before he went under the tree the first time.
Q: Oh, I see.
A: And then the next position was when you could see him through a very small opening in the tree.
Q: And what would that frame number be, if you know, sir? I hate to keep you walking up and down.
A: That's all right, that is Frame 185 and 186, the one, the frame as it was on that car, the adjusted frame for the ten-inch difference.
Q: Would you put a circle around there.
A: Yes.
Q: Thank you. Please go on with your account of the re-enactment.
A: The next frames that we have located were the points where the President emerged from under the tree so that the man with the rifle in the window got the first clear shot of President Kennedy.
Q: And what frame number would that be, sir?
A: That frame number on the plaque is marked as Frame 207 and 208.
Q: Would you please circle those?
A: The next frame that we located was the frame in the Zapruder film where the President first came into -- where Governor Connally first came into view, his face first appears from behind the signboard.
Q: What frame number is that?
A: That is Frame 222.
Q: Would you circle that, please?
A: Yes. The next frame was the frame where President Kennedy's face first came into view.
Q: Would that be 225?
A: That would be 225.
Q: Would you circle that?
A: I would like to point out on the plat map it is marked as Frame 223, that is not correct.
MR. DYMOND: With the State's permission, we will change it.
THE WITNESS: 225.
BY MR. DYMOND:
Q: Would you change that to 225 and circle it?
A: Yes, it is listed as 225 on the chart, not 223.
Q: What is the next point of reference that you have, sir?
A: The next point of reference is Frame 231.
Q: And what would that represent, Mr. Shaneyfelt?
A: I can only say at this time -- I don't have a clear enough recollection of that, but Frame 231, Frame 238 and Frame 240 and 249 were related to -- were points that the Commission desired based on --
MR. OSER: I object to "based on." I object to what the Commission based their request on.
THE COURT: Just tell us what they wanted you to do.
THE WITNESS: They asked those positions be ascertained.
BY MR. DYMOND:
Q: For what purpose were they ascertained, if you know?
MR. OSER: Objection --
BY MR. OSER:
Q: Do you know what you were looking for when you determined those spots?
A: Yes.
Q: What did they represent to you when you determined them?
A: They represented positions of Governor Connally, the last position of where he could have received a shot from the Book Depository building because of his body position.
Q: I see. All right, sir, and after that?
A: And they are all related to that particular area.
Q: And I take it from the next point of reference that you have there, the next is Frame 313, or do you have any in between?
A: Frame 255.
Q: What is that?
A: As I recall, it is a frame that they asked me to locate based on the --
MR. OSER: Object, Your Honor, "based on."
BY MR. DYMOND:
Q: For what purpose did you yourself locate that 255, to show what?
A: To show where a photograph taken by an Associated Press photographer had been made, at what point in the motorcade.
Q: Would you circle 255, please. What is the next point of reference?
A: The next point of reference is Frame 313.
Q: That is the spot where President Kennedy was hit in the head?
A: That is the frame which shows he was hit in the head.
Q: Is there a circle on the plaque on that 313?
A: No, there is not.
Q: Would you please put a circle. After finding that point of reference, did you find any other points of reference?
A: Not on Elm Street, no.
Q: You can return to the stand. Now, Mr. Shaneyfelt, would you tell us the mechanics of just how you arrived at the points of reference, that is, at a certain spot and would a signal be given to the car to stop or just how was it done?
A: That is correct, the first -- first the positions that were located relative to the tree, they would signal to stop the car, the signal was given by Mr. Frazier looking to the right, he was the one that determined whether or not a shot could be fired before they went under the tree or at the opening of the tree or as they cleared the tree, so he issued the order to stop the car and rolled it back or forth until he got it in a position that he felt was the last point or the first point, whatever reference he had, and after he established that point, then I, using the Zapruder photographs, individual frame pictures, compared what I saw with the set of pictures I had until I found the one that most closely matched that, and not only using the pictures, but looking through Mr. Zapruder's camera at this re-enactment, I established it was, it most closely conformed to a specific frame number, and we instructed Mr. West to mark that spot on the street.
Q: Now, Mr. Shaneyfelt, were there any known areas of error which were not taken into account by you or when no attempt was made to compensate for?
A: I don't understand the question.
Q: Well, to give you as an example, you cited one known error, and that was the difference in the height of the Presidential Vehicle and the re-enactment vehicle. Were there any such known errors for which you did not attempt to compensate or compensated?
A: Of course there were areas that had been -- we had to rely on estimates, the exact location of the car in the street, whether it was real close to the -- was close to the white line or away from the while line, and you could see as related from where Mr. Zapruder was standing, because looking at Mr. Zapruder's film, you can see it was, it is a certain position down Elm Street, it was difficult to place it in a vertical axis away from his camera, and certain estimations had to be done, and also we had certain photographs, the AP photograph gave guidelines for that, so we felt we were reasonably accurate in the placing of the car, but there was an estimation there.
Q: Now, in placing the car in relation to the white line, did you place it as accurately as you felt that you could with the material that you had at hand?
A: Yes, certainly.
Q: Go ahead with what you were saying.
A: The placing of the rifle in the window, the investigation, through investigation, the amount of the area of the window that was open, but it no way, we had no way of knowing whether the rifle man was on the left or right side of the window or what position in the window, that of course would have to be estimated. When the position of Frame 313 was located, Mr. Zapruder's photographs had nothing in the background except plain grass to locate that frame, so photographs of two other photographers, motion pictures were used to assist us in establishing that frame so that we had three, actually three different points to help us establish that, but it all is based on the accuracy of the interpretation of the photographs which are two-dimensional and not three-dimensional.
Q: I see. Now, Mr. Shaneyfelt, would you give us the vertical angle on Frame 313, that is, the angle between the ground and the Depository window?
A: Yes, the angle from the street is based on the incline in the street and not on the horizontal, perfectly horizontal, the angle to the window from the spot where the shot would have entered President Kennedy, yes, or President Kennedy was sitting to the window was 12 degrees and 12 minutes.
Q: Now, was any allowance made for the lateral movement of the automobile? Reference has been made here to lateral angles. I would ask you was an allowance made for lateral movement of the automobile?
A: No, of course the angle that we took was at a lateral angle to the axis of the car, to the axis of the centerline of the street, and it went off at an angle from the car up, but it was only measured in the vertical, it was not measured in the lateral.
Q: Did you obtain any measurement in feet on a straight line from the spot where the President was sitting in the Presidential vehicle in Frame 313 to the sixth floor window in the Book Depository?
A: Did we make any --
Q: Do you know how many feet it was?
A: Oh, yes.
Q: From point to point?
A: Yes.
Q: What is the figure on that, sir?
A: I would have to refer to the map.
Q: Would you, please.
A: 265.3 feet line of sight from the rifle in the window to the President in Frame 313, 265 feet is the line of sight distance from the rifle in the window to the President in Frame 313 down on Elm Street.
Q: Would you please tell us what the other measurements are which are reflected by that chart.
A: The measurements on the chart are all of the measurements that Mr. West made for us at the re-enactment for each position that was established, giving the angle to the horizon and the line of sight distance from the President at a given spot to the rifle in the window, and the angle and the line of sight distance to a rifle man on the overpass in front of the Presidential limousine, and the distances from a point that we marked off as "Station C," which represented the long-distance curve of Houston, and measured to each individual point which would give us a distance that the car traveled from point to point, and that is basically it.
Q: I ask you, sir, would you please stay there, Mr. Shaneyfelt, you did then take into consideration positions other than a position in the sixth floor Book Depository window. Is that correct?
A: That is correct.
Q: Now, what line of sight did you get between the spot where the President was sitting in Frame 313 in your point of reference on the triple overpass?
A: 260.6 feet, line of sight distance from the President in Frame 313 to the handrail of the triple overpass.
Q: Mr. Shaneyfelt, approximately how much time was consumed in this re-enactment?
A: The portion of the re-enactment that was done on Elm Street on May 24 took, as I recall, from about 6:00 a.m. until around 1:30 p.m. This is after some initial studies and details had been established on the prior day, on the preceding Saturday some studies were made and plans worked out so that the re-enactment would not take too long and hold up traffic too long.
Q: Was there office work performed in connection with this, in addition to the work that was actually done out on Elm Street?
A: Well, yes, there were preparations made for it prior to going, and studies made afterwards on the basis of the results, that type of office work.
Q: Could you tell us approximately how many people participated in the re-enactment?
A: I would have to guess, but I would guess, I would estimate around twenty to twenty- five.
Q: Twenty --
A: I would have to guess because there were certain -- I know how many from the Commission were there, Mr. Frazier and I were there, and I had an assistant, then there were other agents running errands, so about twenty to twenty-five would be my estimate.
Q: To your knowledge, was a motion picture film made of this re-enactment?
A: Yes, sir, there was.
Q: Does that film have a popular name? what is it called, if you know, sir, is that the Nix film?
A: Oh, no.
Q: It is not?
A: No.
Q: Does the film have any popular name that you know of, sir?
A: The re-enactment film?
Q: Yes.
A: No, no, the re-enactment film was made, well, there were several films made of the re-enactment, and that was a part of the study, was to photograph the re-enactment, it was after making the position on the street, determining what the positions were, and where they were, and we then at this time, based on an estimate by the people in the limousine that the car was going about twelve miles an hour, this was before it was accurately determined through motion picture film, we asked that they drive the limousine along that course at approximately twelve miles an hour with no attempt being made by the participants, the stand-ins, to try to conform to the body position, merely to drive the car through the -- in the same route at the same approximate speed, and while doing this, this was done two or three times, possibly more, I can't exactly recall the number of times, in order that we could photograph the re-enactment, this re-enactment with Mr. Zapruder's camera, with Mr. Nix's camera and Mr. and Mrs. Muchmore's camera, from the positions that they had at the time the assassination took place, so that the films we made could be compared with the re-enactment photographs to be determined how accurately we established the various things, various points.
Q: Now, let me interrupt you one moment. After doing that, did you determine whether or not you had established these points with a good degree of accuracy?
A: Yes, they were consistent with the films that we made of the re-enactment, these I think went to the sixth floor window of the Book Depository building, mounted a 16-millimeter motion picture camera on the gun that had been recovered from the -- the Mannlicher-Carcano rifle that Mr. Frazier had been using, mounted a reflex, a 16-millimeter reflex motion picture camera on it in such a way that you could view through the camera so that you could see through the camera and through the lens of the camera, through the scope and photograph the motorcade or the stand-ins on the limousine we were using.
Q: I take it then what you saw through the camera then would be the same thing that a person would see through this gun sight. Am I correct?
A: It represented what the person saw, and we made, I think, about three different runs through this re-enactment, photographing it at that angle to show the view that the rifleman would have had.
Q: Now, after the films of the re-enactment were made, were they developed and presented to the Warren Commission?
A: Yes, they were.
(Whereupon, a recess was taken so the reporter could change his stenotype pad.)
BY MR. DYMOND:
Q: Now, did you testify before the Warren Commission yourself, sir?
A: Yes, I did.
Q: Do you k now whether or not the Zapruder film was shown to the Warren Commission, that is, "State Exhibit No. 37," what has been marked --
MR. OSER: If he was there when it was shown, that is.
BY MR. DYMOND:
Q: Was the Zapruder film to your personal knowledge shown to the Warren Commission?
A: You have referred to this exhibit as the Zapruder film?
Q: No, one containing the same material this contains of which this is a copy.
A: Yes, many times.
Q: It was?
A: Yes, the original was shown to us, me, other members of the Warren Commission, representatives of the Warren commission studied it for some time, various runs through it, then the copy of the film that the FBI had was used on numerous occasions, all of which time I was present.
Q: I see. Now, did you blow up each frame of the Zapruder film and make a still picture of it?
A: Yes, I did.
Q: Were those presented to the Warren Commission?
A: Yes, they were.
Q: Did you examine them thoroughly?
A: Yes, I did.
Q: Now, as a result of all of the examinations which you have made, as an expert have you found any photographic evidence to indicate that the shots which hit President Kennedy came from any direction other than his right rear?
A: I did not.
MR. DYMOND: That's all, sir.
REDIRECT EXAMINATION BY MR. OSER:
Q: In referring to Frame 313, did you have occasion to measure the distance between the shoulders of President Kennedy as depicted in the Zapruder film in relation to the back of the seat at the time of Frame 313?
A: I did not measure it, no.
Q: Did you have occasion to measure the distance between the back of the seat and President Kennedy's back as reflected in Frame 312, the frame immediately prior to Frame 313?
A: I did not measure it, no.
Q: Did you have occasion to measure the distance between President Kennedy's back and the back of the seat at Frame 314 on through, say, Frame 330?
A: I did not measure them, no.
MR. OSER: That's all.
RECROSS-EXAMINATION BY MR. DYMOND:
Q: Mr. Shaneyfelt, you did not measure these distances between the spot where President Kennedy's shoulders appeared on the film and the back of the seat. Did you closely observe the distances?
A: Yes.
Q: Did you take these distances into account in analyzing just what action was depicted by the films?
A: Yes, all of the studies that I made of the Zapruder film, I examined and considered every position of both occupants, every movement, turning and so on, everything that I could possibly find to examine, in those instances where the photograph would show a jiggle or a bump or something where it could not be established with any accuracy whether it was a movement of the motion picture camera, a sudden jerk of the car or some other thing, that had to be ruled out because I could not in my own mind find any reason to rely on it if I can't determine definitely what caused a particular reaction, so that every motion and every frame was studied extremely closely, both in motion and as still photographs.
Q: Mr. Shaneyfelt, the Zapruder film with which you worked, was it a complete film or were there any frames missing?
A: The frames from which I worked was a complete film, yes.
Q: Now, as an expert, Mr. Shaneyfelt, did you find any photographic evidence indicating to you in what direction the shots which hit President Kennedy came from?
A: Yes.
Q: Would you please tell us what that was.
A: Obviously the main search of the re-enactment was to establish the shot or shots that hit President Kennedy in the back came out of his necktie and caused Governor Connally's wounds, the film just does not show, does not give an -- only by reactions which have to be estimated, but in Frame 313 the shot is in the still photograph of that particular frame, the shot is an explosion of his head, and in looking at the photograph, the fragment that you see streaking through the air in two different spots are going in a forward direction from the vertical line drawn through the President's head, and the burst of pink is in the forward area. This to me has to be, as a layman, since I have no experience in wounds and ballistic wounds and so on, as a layman studying that one frame, it indicates to me he was shot --
MR. OSER: Objection, he stated he is not an expert in the field of ballistics.
MR. WILLIAM WEGMANN: He was asked as a photographic expert if he had an opinion.
MR. OSER: He said he himself is not qualified in the area of ballistics.
THE COURT: In your opinion as an expert photographer or examiner of photographs.
THE WITNESS: As an expert photographer, as an expert in examining photographs, my impression of that photograph is that the shot came from the rear.
BY MR. DYMOND:
Q: Arriving at this conclusion, did you take into consideration the movements of the President's body as shown in Frame 313?
A: No, no, because specifically in Frame 313 there is no movement of the President's body.
Q: Well, let's say as shown on the frames surrounding Frame 313 and immediately after.
A: No, I did not take into consideration the movement of his body in reaching that conclusion, merely the direction of the explosion from his head and the portions of matter or whatever is flying through the air.
Q: As an expert in photography, were you able to identify in these photographs the material from the -- which seems to be going forward from the President's head in those photographs?
A: Identify them, no, I was not able to identify the material.
Q: I mean as to --
A: There is an explosion of his head and there is something streaking through the air. It is a pink color that streaks forward, there is one that goes more directly forward or had a greater angle forward than the other, the other is slightly off of the perpendicular, but still forward.
MR. DYMOND: That's all, Your Honor.
THE COURT: Do you have any further need of Mr. Shaneyfelt?
MR. OSER: The State asks he be excused from his subpoena.
THE COURT: You are excused.