Part 25

Mr. COUCH. Some of the pictures, I remember, the camera was pointing south--because I was standing on the little knoll which is just at the foot and west of the Depository Building, where the little park area begins. There's a sidewalk that runs between the Book Depository property, I would assume and the park. And I was standing on that little sidewalk.

Mr. BELIN. And your camera was pointing south?

Mr. COUCH. Pointing south. That's right. Now, after I had taken I don't know how many feet of film of people standing around, I--uh--we--I think there was one or two other fellows with me and who they were, now, I can't remember; they were photographers--we stopped a car that was going by with a boy in it--a young boy of about high school age--and asked him to take us out to Parkland. And as the car started off, I started my camera and I have a sweeping shot moving west from about--uh--maybe the middle of the Book Depository Building from ground level on past the park area--a sweeping shot with the car moving.

Mr. BELIN. And that's about it insofar as the School Book Depository Building is concerned?

Mr. COUCH. Well, no. After we got out to Stemmons--they'd set up a roadblock just as you entered Stemmons Expressway.

Mr. BELIN. Uh-huh.

Mr. COUCH. We jumped out of the car and I took, I believe it was, a 2-inch lens shot of the Book Depository Building of the west wall.

Mr. BELIN. Of the west wall?

Mr. COUCH. Yes.

Mr. BELIN. Not of the front entrance?

Mr. COUCH. No.

Mr. BELIN. Is there any particular reason, Mr. Couch, why you didn't take your first pictures of the School Book Depository Building itself when you say you saw a rifle being withdrawn?

Mr. COUCH. Well, uh--as best I can recall, the excitement on the ground of people running and policemen "revving" up their motorcycles--and I have a real nice shot of a policeman running toward me with his pistol drawn--the activity on the ground kept my attention. The reason I did not stay and take pictures of the Depository Building--which I had originally intended to do when I got out of the motorcade--was that--uh--another cameraman from our station, A. J. L'Hoste--[spelling] L-'-H-o-s-t-e--he came running up and--uh--when he ran up, why I said, "You stay here and get shots of the building and go inside--and I'm going to go back--I'm going to follow the President."

Mr. BELIN. All right. Was he also a moving picture cameraman?

Mr. COUCH. Yes; right.

Mr. BELIN. Where was he at the time you made this statement?

Mr. COUCH. Uh--he was standing on that little sidewalk that runs between the--I met him on the little sidewalk between the Book Depository property and the beginning of the parkway.

Mr. BELIN. That would be the west side of the Depository Building?

Mr. COUCH. That's right; that's right. It's there that I saw the blood on the sidewalk.

Mr. BELIN. All right. Now, you say you saw blood on the sidewalk, Mr. Couch?

Mr. COUCH. That's right.

Mr. BELIN. Where was that?

Mr. COUCH. This was the little walkway--steps and walkway that leads up to the corner, the west corner, the southwest corner of the Book Depository Building. Another little sidewalk, as I recall, turns west and forms that little parkway and archway right next to the Book Depository Building.

Mr. BELIN. Did this appear to be freshly created blood?

Mr. COUCH. Yes; right.

Mr. BELIN. About how large was this spot of blood that you saw?

Mr. COUCH. Uh--from 8 to 10 inches in diameter.

Mr. BELIN. Did people around there say how it happened to get there, or not?

Mr. COUCH. No; no one knew. People were watching it--that is, watching it carefully and walking around it and pointing to it.

Uh--just as I ran up, policemen ran around the west corner and ran--uh--northward on the side of the building. And my first impression was that--uh--that they had chased someone out of the building around that corner, or possibly they had wounded someone. All the policemen had their pistols pulled. And people were pointing back around those shrubs around that west corner and--uh--you would think that there was a chase going on in that direction.

Again, the reason that I didn't follow was because A. J. had come up, and my first concern was to get back with the President.

Mr. BELIN. This pool of blood--about how far would it have been north of the curbline of Elm Street as Elm Street goes to the expressway?

Mr. COUCH. I'd say--uh--well, from Elm Street, you mean, itself?

Mr. BELIN. Yes. This is from that part of Elm Street that goes into the expressway?

Mr. COUCH. I'd say--uh--50 to 60 feet, and about 15 feet or 10 to 15 feet from the corner of the Texas Depository Building.

Mr. BELIN. It would have been somewhere along that park area there?

Mr. COUCH. Right.

Mr. BELIN. Was there anything else you noticed by this pool of blood?

Mr. COUCH. No. There were no objects on the ground. We looked for something. We thought there would be something else, but----

Mr. BELIN. There was nothing?

Mr. COUCH. Huh-uh.

Mr. BELIN. Now, this A. J.----?

Mr. COUCH. L'Hoste. That's "L" apostrophe.

Mr. BELIN. Yes; I have that. I have made a note of the spelling, along with the phonetic sound.

Do you know if he got any pictures of the south side of the School Book Depository?

Mr. COUCH. No; I don't recall what he got--as I recall--now, I may be wrong, this is a guess--that he did not take any pictures.

Mr. BELIN. He did not take any?

Mr. COUCH. No.

Mr. BELIN. Do you know of anyone that took any pictures of the south side of the School Book Depository Building, particularly the front entrance of the building, shortly after the assassination?

Dr. COUCH. No; only what I have seen in Time magazine.

Mr. BELIN. Only what you've seen in Time magazine?

Mr. COUCH. Right.

Mr. BELIN. Now, did you ever know or hear of Lee Harvey Oswald before any of this?

Mr. COUCH. No.

Mr. BELIN. Have you ever met Jack Ruby?

Mr. COUCH. No.

Mr. BELIN. There is an FBI report that states that you had heard hearsay statements that someone had seen Jack Ruby emerge from the rear of the Texas School Book Depository Building around that time. Did anyone ever tell you that?

Mr. COUCH. Yes. Uh--where I first heard it, I could not now recall; but--uh--the story went that--uh--Wes Wise, who works for KRLD----

Mr. BELIN. TV?

Mr. COUCH. Yes--saw him moments after the shooting--how many moments, I don't know--5 minutes, 10 minutes--coming around the side of the building, coming around the east side going south, I presume.

Mr. BELIN. Did you ever talk to Wes Wise as to whether or not he actually saw this, or is this just hearsay?

Mr. COUCH. No; I didn't. This is just hearsay.

Mr. BELIN. Let me ask you this: Is there any observation, other than hearsay, that you have about this entire sequence of events that you have not related here?

Mr. COUCH. No; I can't think of anything. No.

Mr. BELIN. In this same FBI report of an interview with you, it states that--and by the way, I did not show this to you when you first chatted about this--is that correct?

Mr. COUCH. Uh-huh; that's right.

Mr. BELIN. There is a statement as to the time sequence--that you heard, first, two loud noises about 10 seconds apart. And you related here that it would have been 5 seconds apart or less. Do you remember whether or not at the time you gave your first statement to the FBI you said 10 seconds or would you have said about 10 seconds or would you have said less than 10 seconds--or could this be inaccurate, as sometimes happens?

Mr. COUCH. I don't recall now. Ten seconds is not a reasonable time; even if I said "about 10 seconds." I know a little bit more about timing than that. We have to time our stories pretty close--and that's a long time.

Mr. BELIN. And what's your best recollection now as to the amount of time between shots?

Mr. COUCH. Well, I would say the longest time would be 5 seconds, but it could be from 3 to 5.

Mr. BELIN. And would this be true between the first and the second shots as well as between the second and third--or would there have been a difference?

Mr. COUCH. As I recall, the time sequence between the three were relatively the same.

Mr. BELIN. Now, Mr. Couch, shortly before we commenced taking this deposition, you and I met for the first time. Is that correct?

Mr. COUCH. That's correct.

Mr. BELIN. And then we came to this room and we chatted for a few minutes before we started taking a formal deposition. Is that correct?

Mr. COUCH. That's correct.

Mr. BELIN. Now, is there anything that we talked about pertaining to the assassination that in any way differs or conflicts with the testimony that you have just given?

Mr. COUCH. No; no.

Mr. BELIN. What is the fact as to whether or not I questioned you in great detail about each question or whether or not I just asked you to relate the story to me?

Mr. COUCH. You asked me to give general highlight impressions before we began.

Mr. BELIN. And then, after you gave those to me, we started taking the deposition--is that correct?

Mr. COUCH. That's correct.

Mr. BELIN. And then you repeated on the deposition what we had talked about--is that right?

Mr. COUCH. That's right--in more detail.

Mr. BELIN. Is there anything else that you can think of at this time which, in any way, would affect the investigation of the assassination of President Kennedy?

Mr. COUCH. No; I cannot think of anything.

Mr. BELIN. Well, we want to thank you very much for taking your time to come down here. We know that you're a busy man. We also would like you to convey our thanks to station WFAA-TV for allowing you to come down here. We appreciate it very much.

Mr. COUCH. Thank you, sir.

Mr. BELIN. Mr. Couch, we're going back on the record again. You're still under oath--and I'm not quite sure whether I asked this question, but I had better ask it again.

When you saw this rifle being withdrawn. About how much of it could you see at first?

Mr. COUCH. I'd say just about a foot of it.

Mr. BELIN. And in what direction was the barrel pointing at the time you saw it being withdrawn?

Mr. COUCH. Approximately a 45° angle westward--which would be pointing down Elm Street.

Mr. BELIN. Down Elm Street as it goes into the expressway there?

Mr. COUCH. That's right.

Mr. BELIN. And when you say "45° angle" would that be up or down, or are you referring to the angle of incline, or the angle of west and south?

Mr. COUCH. The angle of incline--from a horizontal position.

Mr. BELIN. All right. So, you would estimate about a 45° angle downward pointing in what would be a southwesterly direction?

Mr. COUCH. Uh--westerly direction. From looking straight on at the building, one could not tell the--uh--angle, whether it was more southward or not. In other words, something sticking out the building, I couldn't tell. It was not--it did not appear to me that it was sticking straight out the window, so to speak.

Mr. BELIN. Yes. Is there anything else that you noticed about the gun?

Mr. COUCH. No.

Mr. BELIN. All right. Thank you. I just wanted to make sure I got that on the record.

TESTIMONY OF TOM C. DILLARD

The testimony of Tom C. Dillard was taken at 9:15 a.m., on April 1, 1964, in the office of the U.S. attorney, 301 Post Office Building, Bryan and Ervay Streets, Dallas, Tex., by Mr. Joseph A. Ball, assistant counsel of the President's Commission.

Mr. BALL. State your name.

Mr. DILLARD. Tom C. Dillard.

Mr. BALL. Will you stand and raise your right hand, please?

Mr. DILLARD (Complying).

Mr. BALL. Do you solemnly swear the testimony given before this Commission will be the truth, the whole truth, and nothing but the truth, so help you God?

Mr. DILLARD. I do.

Mr. BALL. My name is Joseph A. Ball. I am staff counsel for the President's Commission on the Assassination of President Kennedy. You have already been requested to be present have you not----

Mr. DILLARD. By letter; yes.

Mr. BALL. By letter which you received last week?

Mr. DILLARD. Yes, sir.

Mr. BALL. What is your occupation?

Mr. DILLARD. I am a photographer.

Mr. BALL. I might state the purpose of questioning you is to ask you questions as to any knowledge you might have as to the facts concerning the assassination of President Kennedy on November 22, 1963, at Dallas, Tex.

Mr. DILLARD. I understand. My occupation is journalist; I am chief photographer of the Dallas Morning News, do some aviation writing but my primary job is head of the photographic department and, of course, I do outside work for the paper on photographic work.

Mr. BALL. How old are you?

Mr. DILLARD. I'm 49.

Mr. BALL. What has been your general education?

Mr. DILLARD. High school, very few college courses.

Mr. BALL. What?

Mr. DILLARD. High school and very few college courses.

Mr. BALL. Where did you go to school?

Mr. DILLARD. I didn't go to school. I graduated Fort Worth, from the old Central High School, went to the Officer Candidate School in the Military and Air University.

Mr. BALL. How long have you been with the paper?

Mr. DILLARD. The Dallas News since 1947 and I was with the Star Telegram, went to work in 1929.

Mr. BALL. Have you been a photographer for the papers all these years?

Mr. DILLARD. Well, yes; of course, the first years, when I was started at the age of 15, I was a copy boy and did various reporting and whatever we could do on the paper. I was 15 when I started.

Mr. BALL. On November 22, you were in the motorcade who followed President Kennedy, weren't you?

Mr. DILLARD. That is correct. I understand our car was about number six in the line.

Mr. BALL. Did you meet the President at Love Field?

Mr. DILLARD. That's right.

Mr. BALL. And then you rode in the motorcade from Love Field into Dallas?

Mr. DILLARD. Right.

Mr. BALL. Who was in your car?

Mr. DILLARD. I remember Jim Underwood, he's an announcer for KRLD-TV and cameraman, acting as a cameraman that day; and Bob Jackson of the Times-Herald, cameraman; and Couch with our TV station, Channel 8, and did you have information his name is Couch?

Mr. BALL. That's right; and the man that drove----

Mr. DILLARD. Channel 5--Darnell, I think his name is, and the driver of the car which I don't believe I remember his name. It was a Chevrolet convertible.

Mr. BALL. Your car was about sixth, was it?

Mr. DILLARD. I believe.

Mr. BALL. From the President's car?

Mr. DILLARD. From the President's car. We lost our position out at the airport. I understood we were supposed to have been quite a bit closer. We were assigned as the prime photographic car which, as you probably know, normally a truck precedes the President on these things and certain representatives of the photographic press ride with the truck. In this case, as you know, we didn't have any and this car that I was in was to take any photographs which was of spot-news nature.

Mr. BALL. As you turned from Main Street onto Houston, was the President's car in sight at that time?

Mr. DILLARD. No; and the whole parade, the whole trip to town, I could only distinguish the President's car on very few occasions in high rises in the ground, when we got on hills. It was difficult because the people in the cars ahead of me were sitting on the backs of cars which pretty well covered the President's car for me. We had a very, very poor view of the President's car at any time from the time the parade started.

Mr. BALL. Can you tell me whether or not the President's car had made the turn off Houston Street when your car turned north on Houston?

Mr. DILLARD. It had.

Mr. BALL. It had?

Mr. DILLARD. No; I won't say it had. I think it had because, like I say, I could never see the car very well. I believe it had.

Mr. BALL. Where were you sitting in the car?

Mr. DILLARD. I was sitting in the right front.

Mr. BALL. Who was in the front seat with you?

Mr. DILLARD. Oh, I don't remember; I think Jackson was sitting beside me--no; I believe Jackson was sitting in the back. I don't remember what our locations were.

Mr. BALL. But you know you were in the right front?

Mr. DILLARD. Yeah.

Mr. BALL. Did you hear something unusual as you were driving north on Houston?

Mr. DILLARD. Yes; I heard an explosion which I made the comment that I believe, in my memory, I believe I said, "My God, they've thrown a torpedo" and why I said "torpedo", I don't know. If you wish, I'll go ahead----

Mr. BALL. Go ahead with your story.

Mr. DILLARD. Well, then I later estimated, immediately later, estimated, oh, 4, about 3 or 4 seconds, another explosion and my comment was, "No, It's heavy rifle fire," and I remember very distinctly I said, "It's very heavy rifle fire."

Mr. BALL. How many explosions did you hear?

Mr. DILLARD. I heard three--the three approximately equally spaced.

Mr. BALL. What is the best estimate of the position of your car with reference to the turn at Main and Houston when you heard the first explosion?

Mr. DILLARD. Perhaps, oh, just a few feet around the corner and it seems we had slowed a great deal. It seems that our car had slowed down so that we were moving rather slowly and perhaps just passed the turn when I heard the first explosion.

Mr. BALL. Did you hear anyone in your car say anything?

Mr. DILLARD. Well, after the third shot I know my comment was, "They killed him." I don't know why I said that but Jackson--there was some running comment about what can we do or where is it coming from and we were all looking. We had an absolutely perfect view of the School Depository from our position in the open car, and Bob Jackson said, "There's a rifle barrel up there." I said, "Where?" I had my camera ready. He said, "It's in that open window." Of course, there were several open windows and I scanned the building.

Mr. BALL. Which building?

Mr. DILLARD. The School Depository. And at the same time I brought my camera up and I was looking for the window. Now, this was after the third shot and Jackson said, "There's the rifle barrel up there," and then he said it was the second from the top in the right-hand side, and I swung to it and there was two figures below, and I just shot with one camera, 100-mm. lens on a 35-mm. camera which is approximately a two times daily photo twice normal lens and a wide angle on a 35-mm. which took in a considerable portion of the building and I shot those pictures in rapid sequence with the two cameras.

Mr. BALL. You shot how many pictures?

Mr. DILLARD. Two pictures.

Mr. BALL. With one camera or two different cameras?

Mr. DILLARD. Two different cameras--one daily photo, not extreme daily photo, but twice the normal lens.

Mr. BALL. You say your cameras were ready? How were they ready?

Mr. DILLARD. Hung around my neck and held in my hand.

Mr. BALL. You brought them up and focused and shot?

Mr. DILLARD. Well, on the whole ride, I had been watching the tops of buildings and watching for any signs or anything unusual which, of course, is a newsman's chore on a parade like that. We were badly--in a very bad position from our viewpoint to cover anything on the parade, so we were all, as any news photographer is, rather tense when he is covering a Presidential or an affair of that sort and he is trying to get whatever pictures possible and watching for every possibility, and so we all tried for a number of things. Incidentally, the only unusual thing in the parade that I noticed was the President--I understand the President stopped his car at Lemmon and Loma Alta, which is out in the near suburbs of Dallas, as I understand, at the request of a sign that said, "Mr. President, stop and shake hands with us." I jumped out of the car--it was a convertible with the top down--and tried to run to get pictures of it but by that time the parade started and I was unable to get up that far.

Mr. BALL. When you shot these two pictures of the Texas School Book Depository Building, how far were you from the building, would you say?

Mr. DILLARD. From the window or from the----

Mr. BALL. From the building. That would be, I suppose, a measurement along the street.

Mr. DILLARD. I would say it was just before we reached the corner of Elm and Houston Streets.

Mr. BALL. You were south of Elm and Houston, were you?

Mr. DILLARD. Yes.

Mr. BALL. About how far? Well, perhaps as a photographer, you can give me a more accurate estimate this way; tell me how far you think your camera was from the upper windows when you shot that picture?

Mr. DILLARD. Oh, it wasn't over 50, 60 yards.

Mr. BALL. Did you see anything in the windows?

Mr. DILLARD. No.

Mr. BALL. You didn't see a rifle barrel?

Mr. DILLARD. No.

Mr. BALL. But you did see some figures or forms in the window?

Mr. DILLARD. Only in the windows which was the windows below.

Mr. BALL. How many forms did you see in the windows below?

Mr. DILLARD. I saw two men in the windows, at least the arched windows. I saw them in my picture. I was making the picture my eyes were covering.

Mr. BALL. You saw them as you were taking the picture?

Mr. DILLARD. I may have; I don't know.

Mr. BALL. Do you remember if you saw two or three figures?

Mr. DILLARD. I don't remember.

Mr. BALL. But you did see some figures and you cannot be accurate?

Mr. DILLARD. Right.

Mr. BALL. Your car stopped where?

Mr. DILLARD. I remember, we were stopping and starting down Houston Street or moving very slowly while this shooting was going on, and I know we came around the corner of Houston and Elm and saw people lying on the ground down the hill on the sides of the lawns there in the plaza, and I jumped out of my car. The car stopped then and I got out and I don't know what happened.

Mr. BALL. What did you do after you go out?

Mr. DILLARD. Well, I made a picture of cars moving into the sun under the underpass, somebody chasing the car and I looked at the situation in that area and saw absolutely nothing of the Presidential car or anything that appeared worth photographing to me at the time.

Mr. BALL. How long did you stay around there?

Mr. DILLARD. Perhaps 2 minutes.

Mr. BALL. Then where did you go?

Mr. DILLARD. Another car, Chevrolet convertible, of the party came by with, I assume, dignitaries in it and I jumped on the back of it and we started--I told them, of course, who I was and we started out Stemmons Expressway toward the Trade Mart and I explained to them what I knew and tried to hold onto the back of that car at rather high speed. I never saw the Presidential car.

Mr. BALL. Do you have any idea or any impression as to the source of the explosions--what direction it was coming from?

Mr. DILLARD. Yes, I felt that, at the time, I felt like it was coming from a north area and quite close, and I might qualify I have had a great deal of experience. I am a gun nut and have a great number of high-powered rifles at home, so I know a little bit about guns.

Mr. BALL. You have had experience with rifles?

Mr. DILLARD. Yes, I have shot a great deal, so I am familiar with the noise that they made in that area. We were getting a sort of reverberation which made it difficult to pinpoint the actual direction but my feeling was that it was coming into my face and, in that I was facing north toward the School Depository--I might add that I very definitely smelled gun powder when the car moved up at the corner.

Mr. BALL. You did?

Mr. DILLARD. I very definitely smelled it.

Mr. BALL. By that you mean when you moved up to the corner of Elm and Houston?

Mr. DILLARD. Yes; now, there developed a very brisk north wind.

Mr. BALL. That was in front of the Texas School Book Depository?

Mr. DILLARD. Yes, it's rather close--the corner is rather close. I mentioned it, I believe, that it was rather surprising to me.

Mr. BALL. Who did you mention it to?

Mr. DILLARD. Bob, I'm sure.

Mr. BALL. Bob Jackson?

Mr. DILLARD. Yeah, Bob and I were talking about it.

Mr. BALL. You developed your pictures, didn't you?

Mr. DILLARD. I don't remember.

Mr. BALL. Or did you turn them over?

Mr. DILLARD. I printed them.

Mr. BALL. You printed them?