The Clay Shaw trial testimony of Lyndal Shaneyfelt, continued
February 14, 1969
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?
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 --
Q: -- let's see at Frame 313, you said that Governor Connally and President Kennedy were basically one in front of the other.
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?
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?
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.
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?
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?
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?
Q: Does the film have any popular name that you know of, sir?
A: The re-enactment film?
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?
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?
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.
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