Mr. MANSFIELD. No, sir.

Mr. SOURWINE. So that if you were called on by the United States attorney for an opinion with regard to procedure in connection with a plea in bar, your reply was your own, prepared without any assistance?

Mr. MANSFIELD. Well, I think in that sort of a situation I may have included some citation which was actually found by one of the attorneys.

Mr. SOURWINE. One of what attorneys?

Mr. MANSFIELD. Mr. Brown or one of the assistants to the United States attorneys.

Mr. SOURWINE. You mean one of the SEC attorneys?

Mr. MANSFIELD. Mr. Brown was an SEC attorney.

Mr. SOURWINE. Now, if the United States attorney had written. you or wired you from Topeka, for your information, or in regard to your advice in a plea in bar, and particularly whether you knew of or could find any case on the point of law involved, and if you had then contacted Mr. Brown or any of the SEC lawyers who was not in Florida, in order to secure that information from them, wouldn't you remember having done so?

Mr. MANSFIELD. I couldn't say that I would.

Mr. SOURWINE. Could you say whether you did do so?

Mr. MANSFIELD. I don't have any recollection of the United States attorney wiring me for any such citations.

Mr. SOURWINE. Do you have any recollection of his writing you for any such citations or information?

Mr. MANSFIELD. I am not certain. I have a faint impression that there was one letter from one of the assistants which may have inquired for some case citations but I don't recall of anything more definite than that.

Mr. SOURWINE. Mr. Mansfield, you stated that you had some considerable experience in legal matters, although you were not a lawyer. Do you feel that you are competent to decide legal problems and to make legal researches?

Mr. MANSFIELD. On matters relating to something having a bearing on this mail-fraud case, I think I do.

Mr. SOURWINE. Now in connection with the material which you submitted to the Securities and Exchange Commission, material of this legal nature since obviously you would not get such material from the United States attorney--you submitted it to the SEC; would you say that any such material submitted to the SEC was a product of your own efforts and unaided?

Mr. MANSFIELD. I would think so.

Mr. SOURWINE. Do you ever recall that you received any assistance in connection with the preparation of any such legal material which you thereafter presented to the SEC?

Mr. MANSFIELD. No.

Mr. SOURWINE. Would your recollection then be that you did not receive any such assistance?

Mr. MANSFIELD. I would have no recollection of it, but I think I also have no recollection that there was such assistance, and I think there wasn't.

Mr. SOURWINE. Now, Mr. Mansfield, did you draft any indictments at all in connection with your investigation of the Crummer case?

Mr. MANSFIELD. I assisted in the drafting of the indictments at Topeka.

Mr. SOURWINE. Did you prepare any drafts of any kind?

Mr. MANSFIELD. Well, I have already testified concerning the one at Cincinnati.

Mr. SOURWINE. Did you prepare a draft of an indictment?

Mr. MANSFIELD. Yes.

Mr. SOURWINE. Did you offer it or furnish it to the United States attorney?

Mr. MANSFIELD. Yes.

Mr. SOURWINE. Did you prepare a similar draft of an indictment which was subsequently submitted, either to the SEC or the United States attorney at Topeka?

Mr. MANSFIELD. I prepared, in part, a draft for one of the indictments. A part of the indictment at Topeka.

Mr. SOURWINE. Which indictment was that? Panama City?

Mr. MANSFIELD. Panama City; yes.

Mr. SOURWINE. You prepared that and submitted it to him?
Mr. MANSFIELD. Yes.

Mr. SOURWINE. Now you say you prepared a part of the draft of the indictment. What part did you prepare?

Mr. MANSFIELD. Why, I wouldn't be able to answer that question. Mr. SOURWINE. Well, you prepared it. What did you prepare? Mr. MANSFIELD. (No response).

Mr. SOURWINE. Was it a form of indictment?

Mr. MANSFIELD. Yes. It was an indictment in form, but not complete.

Mr. SOURWINE. It was, then, you would say

Mr. MANSFIELD. And it was actually very much revised at later conferences.

Mr. SOURWINE. In what respect was it not complete?

Mr. MANSFIELD. It did not cover all of the matters of fraud which were finally cited in the indictment.

Mr. SOURWINE. In the indictment. You mean in the indictment which was returned?

Mr. MANSFIELD. Yes.

Mr. SOURWINE. Did it cover all of the matters of fraud, of which you had knowledge at the time you prepared it?

Mr. MANSFIELD. No; I wouldn't say that it did, because it would be next to impossible to cover all the matters of fraud in a mailfraud indictment.

Mr. SOURWINE. What was the purpose for which you prepared it? Mr. MANSFIELD. As a basis upon which an actual indictment might be prepared.

Mr. SOURWINE. You included in it, then, did you, all of the matters which you thought were proper for such an actual indictment?

Mr. MANSFIELD. I included in it such matters which I thought might be-should be charged, and which were at least a portion of themon which I thought we had sufficient evidence to sustain it.

Mr. SOURWINE. You do not mean to say that you left out of it, any material that should be charged and on which you thought you had sufficient evidence to sustain an indictment?

Mr. MANSFIELD. I mean after preparing it, there were other things that were found, or revised, which, later in the conferences, were decided should be included.

Mr. SOURWINE. I am talking about the situation at the time you prepared it. At the time you prepared it, you drew the best indictment you could at that time?

Mr. MANSFIELD. On the things I was attempting to charge. But I wasn't attempting to bar the door to everything else, because I realized that there were other things which possibly should be charged. Mr. SOURWINE. But you were trying to make it as strong as you could, including the charges with respect to which you had evidence to sustain?

Mr. MANSFIELD. I was attempting to make it a correct and definite charge of fraud under the mail fraud statute.

Mr. SOURWINE. Did you have any assistance in the preparation of that indictment?

Mr. MANSFIELD. You mean the original draft which I presented? Mr. SOURWINE. Yes, sir.

Mr. MANSFIELD. No.

Mr. SOURWINE. Do you know how much like the final indictment, your original indictment was?

Mr. MANSFIELD. Well, there was some of it that I think was practically identical.

Mr. SOURWINE. Do you have a copy of that original draft that you prepared?

Mr. MANSFIELD. I offered one, I believe, heretofore, and it was refused. I don't have it with me now.

Mr. SOURWINE. Do you have one anywhere else?

Mr. MANSFIELD. I have one in St. Petersburg.

Mr. SOURWINE. May I submit a request that the committee be furnished with a copy of it so it can be compared with the actual indictment that was returned?

The CHAIRMAN. Will you present that?

Mr. MANSFIELD. What I have is a copy of the indictment as it was finally returned. I don't have a copy of the indictment I prepared. The CHAIRMAN. You just have a copy of the original indictment

returned into court?

Mr. MANSFIELD. Yes.

Mr. SOURWINE. The committee has that.

The CHAIRMAN. It will not be necessary to supply that.

Mr. SOURWINE. Do you have a copy of the indictment which you prepared to the Stuart case?

Mr. MANSFIELD. No.

Mr. SOURWINE. Did you have any assistance in the preparation of that indictment?

Mr. MANSFIELD. No.

Mr. SOURWINE. In the preparation of those indictments, did you use the district attorney's form?

Mr. MANSFIELD. I had numerous copies of forms of indictments in mail-fraud cases which I had accumulated over a long period of years and I filled in the name in one of those forms.

Mr. SOURWINE. Let me rephrase my question. In connection with the Kansas indictments-that is the Panama City case-the indict

ment which you prepared in that case was submitted to the district attorney in Topeka. Did you have the district attorney's form? Was that prepared on the district attorney's form?

Mr. MANSFIELD. At Topeka?

Mr. SOURWINE. Yes.

Mr. MANSFIELD. The final draft of the indictment was; yes.

Mr. SOURWINE. No; the ones that you submitted.

Mr. MANSFIELD. Oh, no.

Mr. SOURWINE. That was not prepared on his form?

Mr. MANSFIELD. No.

Mr. SOURWINE. In the indictment that you drew in the Stuart case and submitted to the district attorney at Cincinnati, did you have the district attorney's form?

Mr. MANSFIELD. No. It is my experience that there is no printed form of indictment used for mail-fraud cases. They all have to be drafted to fit the facts.

Mr. SOURWINE. Who typed those two indictments that you prepared and submitted?

Mr. MANSFIELD. The indictments, I am not sure whether I did it myself or whether the stenographer in the office did it.

Mr. SOURWINE. You mean a stenographer in your office?

Mr. MANSFIELD. Yes.

Mr. SOURWINE. Were either of those indictments which you prepared typed by a legal stenographer?

Mr. MANSFIELD. No.

Mr. SOURWINE. Mr. Mansfield, what lawbooks did you use in preparing those indictments? Do you recall?

Mr. MANSFIELD. I didn't use any particular lawbooks. I looked up the numerous citations in the library of the United States attorney at Jacksonville.

Mr. SOURWINE. What books did you use to look up those citations? Mr. MANSFIELD. I couldn't tell you that, now.

Mr. SOURWINE. Did anyone give you citations to cases?

Mr. MANSFIELD. No.

Mr. SOURWINE. How did you find the cases?

Mr. MANSFIELD. Well, the usual procedure which I followed was to take a case which I know, and found other citations from it and then spread out from that matter to cover a wider field.

Mr. SOURWINE. Mr. Mansfield, do you know what a law digest is? Mr. MANSFIELD. Yes.

Mr. SOURWINE. Will you tell us what a law digest is?

Mr. MANSFIELD. Well, as I understand it, citations of cases on various phases of the law.

Mr. SOURWINE. Mr. Mansfield, do you know anything about the key numbers?

Mr. MANSFIELD. Well, I believe I did know something about it at one time but I have forgotten now.

Mr. SOURWINE. Do you know how to determine whether a case has been overruled or modified by a later case, or a statute has been amended or repealed by a later statute?

Mr. MANSFIELD. Only in the manner which I have outlined a while. ago. By reading cases.

Mr. SOURWINE. Do you know anything about the uses of a citator?

Mr. MANSFIELD. I cannot say that I do.

Mr. SOURWINE. Did you ever hear of a citator?

Mr. MANSFIELD. I think so.

Mr. SOURWINE. Can you name me a citator?

Mr. MANSFIELD. No.

Mr. SOURWINE. Mr. Mansfield, in connection with your investigation of this case, you got a good deal of cooperation from Mr. Giles Patterson, did you not?

Mr. MANSFIELD. I wouldn't say a good deal. I did get some information concerning the Panama City case, in which he had been an attorney, in connection with some of the efforts to refund that debt.

Mr. SOURWINE. Did you ever use Mr. Patterson's law library or consult any lawbooks in his office?

Mr. MANSFIELD. I think there may have been one occasion.

Mr. SOURWINE. Just one?

Mr. MANSFIELD. Where he cited me to some case having a bearing on the matter which we were discussing.

Mr. SOURWINE. And you consulted that case?

Mr. MANSFIELD. I have a recollection, I believe, of one such instance.

Mr. SOURWINE. Did you ever use his office on other occasions to look up cases or citations or make any legal research?

Mr. MANSFIELD. No.

Mr. SOURWINE. Were you aware, at the time of this investigation, that Mr. Patterson was actively advising and counseling the governor's investigating committee, which was also investigating?

Mr. MANSFIELD. My information was that he was not, until some later date, when he became employed by the Governor.

Mr. SOURWINE. Did you have knowledge of the fact that Mr. Patterson, in his capacity as an attorney, represented the du Pont interests of Florida?

Mr. MANSFIELD. No.

Mr. SOURWINE. You did not know that?

Mr. MANSFIELD. I didn't know, I believe-yes; I knew that he had represented Mr. Ball in the Panama City case, in that refunding. What his relationship or relationships were to Mr. Ball or the du Pont interests-beyond that, I didn't know.

Mr. SOURWINE. Did you know that Mr. Ball and the du Pont interests were very antagonistic to Mr. Crummer and his company?

Mr. MANSFIELD. I knew that Mr. Ball was. And I knew, naturally, from Mr. Patterson being the opposing attorney, that he had different view to the Crummer interests.

The CHAIRMAN. It is 12 o'clock, Mr. Sourwine. Before we recess, though, there are one or two questions I would like to ask the witness.

You have been in the postal service a long time, I believe?

Mr. MANSFIELD. Yes, sir; since 19-well, I have been an inspector since 1914. Up until November 1, 1945.

The CHAIRMAN. When you retired?

Mr. MANSFIELD. Yes, sir.

The CHAIRMAN. You have handled a good many mail fraud cases? Mr. MANSFIELD. Yes, sir.