Latest / Crime Stories with Nancy Grace / HEAR IT: HOLLYWOOD STAR Alex Baldwin's incendiary manslaughter charging documents

Transcript

HEAR IT: HOLLYWOOD STAR Alex Baldwin's incendiary manslaughter charging documents · Crime Stories with Nancy Grace

• 0:05
  Speaker 1: Crime Stories with Nancy Grace. Page one. Alec Baldwin probable
• 0:18
  Speaker 1: Cause Statement, State of New Mexico, County of Santa Fe,
• 0:22
  Speaker 1: First Judicial District Court, State of New Mexico, Plaintiff versus
• 0:26
  Speaker 1: Alexander Ray Baldwin, the third defendant Statement of probable cause
• 0:31
  Speaker 1: background synopsis. On October twenty one, twenty twenty one, in
• 0:35
  Speaker 1: the County of Santa Fe, State of New Mexico, a
• 0:38
  Speaker 1: shooting involving a handgun revolver firearm occurred that resulted in
• 0:42
  Speaker 1: the death of Helena Hutchins and the serious injury of Joelsuza.
• 0:46
  Speaker 1: The shooting involved a forty five caliber revolver and occurred
• 0:50
  Speaker 1: on a western movie set located in rural Santa Fe County,
• 0:53
  Speaker 1: referred to and known as Bonanza Creek Ranch, fifteen County Road,
• 0:57
  Speaker 1: forty five, Santa Fe, New Mexico eight seven five year
• 1:00
  Speaker 1: oh eight five forty five Bonanza Creek Ranch Road on
• 1:04
  Speaker 1: this date being filmed and or rehearsed at this location
• 1:07
  Speaker 1: was a film at the time named referred to as Rust.
• 1:11
  Speaker 1: Through interview statements and evidence, it was learned that defendant
• 1:15
  Speaker 1: Alexander Alec Baldwin here and after Baldwin was the lead
• 1:19
  Speaker 1: actor in the film. Through these statements, interviews, and evidence,
• 1:22
  Speaker 1: it was determined that after lunch on October twenty first,
• 1:25
  Speaker 1: twenty twenty one, their crew, production staff, camera crew, and
• 1:29
  Speaker 1: actors were preparing for a scene set in the church.
• 1:32
  Speaker 1: This was not an established rehearsal, nor had filming commenced
• 1:36
  Speaker 1: at this point. Baldwin was seated in what is referred
• 1:39
  Speaker 1: to and appears to be a church. On this movie set,
• 1:42
  Speaker 1: Baldwin was in possession of a forty five long cult
• 1:45
  Speaker 1: caliber revolver type firearm, one of a type and kind
• 1:49
  Speaker 1: often used and or seen in or on Western genre
• 1:52
  Speaker 1: type movies and or sets. The firearm is a single
• 1:56
  Speaker 1: action revolver handgun which requires the cocking of the exposed
• 2:00
  Speaker 1: which then rotates the cylinder, and then the pressing of
• 2:03
  Speaker 1: the trigger is required to fire the weapon. In front
• 2:07
  Speaker 1: of Baldwin standing were victims Helena Hutchins and Joel Susa.
• 2:11
  Speaker 1: Hutchins and Susa were viewing and moving a camera for
• 2:15
  Speaker 1: a possible setup for a later scene to occur at
• 2:18
  Speaker 1: a later undetermined date and or time. Through these same statements,
• 2:22
  Speaker 1: interviews in physical evidence, it was learned that Helena Hutchins
• 2:26
  Speaker 1: was the director of photography for the film and Joel
• 2:28
  Speaker 1: Susa was the director writer for the film. Information and
• 2:32
  Speaker 1: evidence obtained showed that Baldwin was seated in a pew
• 2:36
  Speaker 1: facing in a northerly direction towards the front of the church.
• 2:39
  Speaker 1: In front of him was Helena Hutchins and page two
• 2:44
  Speaker 1: Joel Susa and a camera operator along with other crew
• 2:48
  Speaker 1: i e. Sound, script, costume, etc. Baldwin was wearing a
• 2:52
  Speaker 1: shoulder holster right hand draw which was securing holding the
• 2:56
  Speaker 1: forty five long Colt caliber single action six shot revolve.
• 3:00
  Speaker 1: Baldwin was practicing drawing and pointing the weapon for the
• 3:03
  Speaker 1: scene with guidance and instruction from Helena Hutchins and Joel Susan.
• 3:08
  Speaker 1: The setup was to be a close up on Baldwin
• 3:10
  Speaker 1: and the firearm as he drew the weapon and pointed it.
• 3:14
  Speaker 1: Helena Hutchins and Joel Susa were reviewing the practice scene
• 3:17
  Speaker 1: on a monitor attached to the camera. Baldwin drew the
• 3:20
  Speaker 1: revolver from the holster, pointed it at Helena Hutchins, and
• 3:24
  Speaker 1: fired the weapon. When reviewing the script and witness interviews
• 3:28
  Speaker 1: for this particular scene and close up shot, evidence indicates
• 3:31
  Speaker 1: the scene shot did not require the weapon to be fired.
• 3:35
  Speaker 1: It was also determined by consultation with expert armorers that
• 3:39
  Speaker 1: in a rehearsal, a plastic gun or a replica gun
• 3:42
  Speaker 1: should be used, as no firing of blanks as required. However,
• 3:46
  Speaker 1: Baldwin fired the single action forty five long cult Revolver,
• 3:51
  Speaker 1: resulting in the discharge of a projectile that struck and
• 3:54
  Speaker 1: traveled through the right armpit area of Helena Hutchins, exited
• 3:58
  Speaker 1: her back from the OMI. Official report then struck Joel
• 4:02
  Speaker 1: Susa in the right shoulder and lodged into his right
• 4:05
  Speaker 1: back At approximately one forty eight PM. The shooting was
• 4:09
  Speaker 1: reported to Santa Fe County Regional Emergency Communications Center via
• 4:13
  Speaker 1: nine one one. This resulted in the response of fire, emergency,
• 4:16
  Speaker 1: medical and Santa Fe County Sheriff's Office personnel. This further
• 4:20
  Speaker 1: resulted in a case number CAD Incident number being generated
• 4:24
  Speaker 1: two zero two one zero zero seven nine four nine.
• 4:28
  Speaker 1: The Santa Fe County Sheriff's Office conducted an investigation into
• 4:31
  Speaker 1: the shooting under this case number as a quote death investigation.
• 4:35
  Speaker 1: UNE Detective Alexandra Hancock was assigned as the primary investigator.
• 4:41
  Speaker 1: The response of emergency personnel resulted in Joel Susa being
• 4:44
  Speaker 1: transported by ambulance to Saint Vincent Regional Medical Center located
• 4:48
  Speaker 1: at four fifty five Saint Michael's Drive within the city
• 4:51
  Speaker 1: limits of Santa Fe, New Mexico. Helna Hutchins was transported
• 4:55
  Speaker 1: from the scene by air ambulance helicopter to the Level
• 4:58
  Speaker 1: one Trauma Center at the Universe City of New Mexico
• 5:00
  Speaker 1: Hospital located in Berna Leio County, Albuquerque, New Mexico. Helena
• 5:04
  Speaker 1: Hutchins was pronounced deceased at approximately three thirty seven PM
• 5:08
  Speaker 1: by attending medical personnel. Joelsuza was treated and released, but
• 5:13
  Speaker 1: not before a projectile was removed from his back. The
• 5:16
  Speaker 1: projectile appeared to be a led projectile of the type
• 5:19
  Speaker 1: and kind found in quote live unquote ammunition. This item
• 5:23
  Speaker 1: was secured and turned over to the Santa Fe County
• 5:25
  Speaker 1: Sheriff's Office. As noted above and confirmed by the evidence
• 5:29
  Speaker 1: and analysis, the recovered projectile first struck and then passed
• 5:34
  Speaker 1: entirely through Helena Hudgins and then struck Joel Susa. There
• 5:39
  Speaker 1: was no evidence that the bullet ricochette struck any object
• 5:42
  Speaker 1: or person before striking Helena Hutchins. The projectile then penetrated
• 5:47
  Speaker 1: through the front of Joelsusa's right shoulder and became lodged
• 5:50
  Speaker 1: under the skin on his back. The Office of the
• 5:53
  Speaker 1: Medical Examiner State of New Mexico listed Helena Hutchins cause
• 5:57
  Speaker 1: of death preliminarily as gunshot wound of the chest after
• 6:01
  Speaker 1: conducting an autopsy on October twenty second, twenty twenty one.
• 6:06
  Speaker 1: The following additional information and evidence is provided in further
• 6:09
  Speaker 1: support of probable cause of the enumerated crimes having been
• 6:13
  Speaker 1: committed by Baldwin. Crime Stories with Nancy Grace page three Firearm,
• 6:34
  Speaker 1: ammunition and Baldwin as actor and shooter. Statements and evidence
• 6:38
  Speaker 1: show Baldwin was not present for required firearms training prior
• 6:42
  Speaker 1: to the commencement of filming. Statements, depositions from motion, and
• 6:46
  Speaker 1: evidence show Baldwin was provided only minimal training on firearms,
• 6:50
  Speaker 1: even after Read requested more training for Baldwin. In the
• 6:54
  Speaker 1: deposition taken from Reach, she stated Baldwin had very limited
• 6:57
  Speaker 1: training on the cross draw that was required for the
• 7:00
  Speaker 1: scene on the twenty first, and limited training in firearms
• 7:03
  Speaker 1: and how to check his own firearm as to whether
• 7:06
  Speaker 1: it was unloaded or loaded, in which Reid felt it
• 7:09
  Speaker 1: was very important in his role as RUST. A training
• 7:13
  Speaker 1: session for at least an hour or more in length
• 7:15
  Speaker 1: was scheduled, but the actual training consisted of only approximately
• 7:19
  Speaker 1: thirty minutes, as according to Reid, Baldwin was distracted and
• 7:24
  Speaker 1: talking on his cell phone to his family during the training.
• 7:27
  Speaker 1: Baldwin approached responding deputies on the day of the shooting,
• 7:31
  Speaker 1: wanting to talk to them because he was the one
• 7:34
  Speaker 1: who quote fired unquote the gun. He was referred to
• 7:38
  Speaker 1: and later interviewed by detectives. Baldwin later asserted that he
• 7:42
  Speaker 1: never fired the revolver and that it had just quote
• 7:46
  Speaker 1: gone off. Baldwin made this assertion public as well in
• 7:50
  Speaker 1: multiple media interviews conducted after the shooting. Many media interviews
• 7:55
  Speaker 1: and law enforcement interviews were conducted by Baldwin, and he
• 7:58
  Speaker 1: displayed very inconstant accounts of what happened during the incident
• 8:02
  Speaker 1: when firing the gun that killed Hutchins. Photo and video
• 8:05
  Speaker 1: evidence from inside the church on the day of the
• 8:07
  Speaker 1: shooting shows some of the rehearsal up to and including
• 8:10
  Speaker 1: moments before the shooting. The photo and videos depict the
• 8:14
  Speaker 1: above described actions of Baldwin prior to the shooting, practicing, drawing,
• 8:18
  Speaker 1: and pointing the weapon. The photos and videos clearly show
• 8:21
  Speaker 1: Baldwin multiple times with his finger inside of the trigger
• 8:25
  Speaker 1: guard and on the trigger, while manipulating the hammer, and
• 8:28
  Speaker 1: while drawing, pointing, and ulstering the revolver. The revolver involved
• 8:33
  Speaker 1: in the shooting was seized by detectives as evidence. It
• 8:36
  Speaker 1: was later submitted to the Federal Bureau of Investigation FBI
• 8:39
  Speaker 1: Crime Lab for examination and analysis. As part of that
• 8:43
  Speaker 1: examination analysis, the FBI conducted a function malfunction check of
• 8:47
  Speaker 1: the revolver. This involved trying to get the weapon to
• 8:51
  Speaker 1: fire without the trigger being depressed, ie striking the hammer
• 8:55
  Speaker 1: at various multiple angles against a solid object, and striking
• 8:59
  Speaker 1: the hammer of the revolver with an actual hammer or mallet.
• 9:03
  Speaker 1: The revolver did not malfunction I fire when it should
• 9:06
  Speaker 1: not accidentally. This analysis clearly showed that the weapon could
• 9:11
  Speaker 1: not accidentally fire. For the weapon to fire, the trigger
• 9:16
  Speaker 1: had to have been depressed pressed. The analysis additionally included
• 9:21
  Speaker 1: testing of and documentation of the seer engagement points of
• 9:25
  Speaker 1: the hammer as it moved from the position of at
• 9:29
  Speaker 1: rest all the way down against the frame in its
• 9:32
  Speaker 1: lowest position through each engagement of the single action hammer mechanism.
• 9:37
  Speaker 1: The firearm possessed one quarter and one half cock position
• 9:41
  Speaker 1: safeties and were found to function as designed I, keeping
• 9:45
  Speaker 1: the hammer from striking a cartridge primer without pulling the trigger. Additionally,
• 9:49
  Speaker 1: at half cock, the cylinder was partially rotated, making it
• 9:54
  Speaker 1: impossible for the hammer and attached firing pin to strike
• 9:57
  Speaker 1: a primer Page four. The FBI additionally analyzed various types
• 10:04
  Speaker 1: and kinds of ammunition seized from the scene, including the
• 10:07
  Speaker 1: prop truck. This included dummy rounds, blank rounds, and suspected
• 10:12
  Speaker 1: live ammunition. A total of five suspected live rounds one
• 10:16
  Speaker 1: spank casing of a live round that was discharged causing
• 10:19
  Speaker 1: the shooting were seized by investigators. Evidence and statements indicate that,
• 10:24
  Speaker 1: aside from what Hannah Gautier has read, Armor Rust production
• 10:28
  Speaker 1: may have brought to the set with her, all weapons
• 10:31
  Speaker 1: and ammunition blank dummy for the production were obtained from
• 10:35
  Speaker 1: a supply company in Albuquerque. PDQ Arms and Prop LLC
• 10:39
  Speaker 1: detectives investigated these facts, including service of a search warrant
• 10:43
  Speaker 1: at the place of business of PDQ Arms and Prop
• 10:46
  Speaker 1: in Albuquerque, who was the supplier of the dummies and
• 10:49
  Speaker 1: blanks to rust. Several suspected live rounds of forty five
• 10:53
  Speaker 1: long cult caliber cartridges were seized as a result, some
• 10:57
  Speaker 1: supplied by the company owner to the investigators and some
• 11:00
  Speaker 1: found at the place of business. These rounds were submitted
• 11:04
  Speaker 1: to the FBI for comparison with the suspected live rounds
• 11:07
  Speaker 1: found at the shooting scene. The explosives chemistry examination of
• 11:11
  Speaker 1: the rounds showed that the smokeless powder in the live
• 11:15
  Speaker 1: rounds found at the scene did not match the live
• 11:18
  Speaker 1: round sees from the prop's arms supplier in question. This
• 11:22
  Speaker 1: means the live rounds on rust did not match the
• 11:27
  Speaker 1: rounds explosive chemistry taken from PDQ Arms I PROP. The
• 11:31
  Speaker 1: FBI lab determined that the five suspected live rounds recovered
• 11:35
  Speaker 1: at the scene of the shooting were indeed quote live
• 11:38
  Speaker 1: unquote rounds, each possessing an unfired primer, powder and bullet
• 11:43
  Speaker 1: as part of the cartridge. These five rounds were found
• 11:46
  Speaker 1: by detectives and crime scene technicians while processing the scene.
• 11:51
  Speaker 1: The five unfired rounds were found in the following locations,
• 11:54
  Speaker 1: one from SFSO Lieutenant Ben Venita's patrol vehicle that he
• 12:00
  Speaker 1: had seized from Read upon his arrival, two from the
• 12:04
  Speaker 1: top of the armorer's cart, including the one spent live
• 12:08
  Speaker 1: round casing, one from a bandalier on the cart, one
• 12:12
  Speaker 1: from Baldwin's holster located inside the church, one from an
• 12:16
  Speaker 1: ammunition box located on the armorer's cart. Along with the
• 12:20
  Speaker 1: casings and fired projectile, there were a total of six
• 12:24
  Speaker 1: forty five quote live unquote rounds that were discovered in
• 12:27
  Speaker 1: various locations on the rust set. Evidence further shows that Baldwin,
• 12:32
  Speaker 1: as an actor who has extensive experience in the film
• 12:35
  Speaker 1: industry involving firearms, failed to demand at least two safety
• 12:39
  Speaker 1: checks in between the armor and himself and witnessing the
• 12:42
  Speaker 1: handling of firearms by a first assistant director. Standard protocol
• 12:47
  Speaker 1: is the armorer is to show the actor the firearm,
• 12:50
  Speaker 1: pull the bullets out in front of the actor and
• 12:53
  Speaker 1: demonstrate there are no live rounds but dummies in the firearm.
• 12:57
  Speaker 1: Baldwin knows this is standard safety protocol, as he has
• 13:01
  Speaker 1: mentioned it in media interviews and in law enforcement interviews.
• 13:05
  Speaker 1: Hannah Gautierre is read here and after Reid did not
• 13:09
  Speaker 1: do this protocol in front of Baldwin, Baldwin did not
• 13:13
  Speaker 1: object to this action. Read discusses in her interviews with
• 13:17
  Speaker 1: OSHA and law enforcement, this shouldn't have occurred. Reid also
• 13:21
  Speaker 1: acknowledges in her interviews she should have been in the
• 13:25
  Speaker 1: church with the firearm at all times. Instead, she left
• 13:29
  Speaker 1: the church while Baldwin was in possession of a firearm
• 13:32
  Speaker 1: in close proximity to the cast and crew. Baldwin further
• 13:36
  Speaker 1: acknowledges that it is standard protocol for armors to stay
• 13:40
  Speaker 1: with the firearm at all times in the media and interviews. Finally,
• 13:45
  Speaker 1: Baldwin directly pointed a firearm at Hutchins and SUSA, whether
• 13:49
  Speaker 1: guided by her directions or not. Baldwin knew the first
• 13:52
  Speaker 1: rule of gun safety is never pointing a gun at
• 13:57
  Speaker 1: page five someone you don't tend on shooting. In addition,
• 14:02
  Speaker 1: always assume a gun is loaded. Had Baldwin performed the
• 14:06
  Speaker 1: required safety checks with the armorer, Read, this tragedy would
• 14:10
  Speaker 1: not have occurred. In addition, if Baldwin had not pointed
• 14:14
  Speaker 1: the gun at Hutchins and SUSA, this tragedy would not
• 14:18
  Speaker 1: have occurred. This reckless deviation from known standards and practices
• 14:23
  Speaker 1: and protocol directly caused the fatal shooting. By not receiving
• 14:27
  Speaker 1: the required training on firearms, deviating from the required duties
• 14:31
  Speaker 1: of checking the firearm with the armorer, letting the armorer
• 14:35
  Speaker 1: leave the church against protocol, deviating from the practice of
• 14:39
  Speaker 1: only accepting the firearm from the armorer, not dealing with
• 14:43
  Speaker 1: safety complaints on the set, not making sure the protocol
• 14:47
  Speaker 1: of safety meetings was occurring, putting his finger on the
• 14:51
  Speaker 1: trigger of a real gun, not using a replica for
• 14:54
  Speaker 1: our arm for the unscheduled rehearsal, pointing the gun at
• 14:58
  Speaker 1: Hudgins and SUSA, and overall handling of the firearm in
• 15:01
  Speaker 1: a negligent manner. Baldwin acted with willful disregarded the safety
• 15:06
  Speaker 1: of others, and in a manner which endangered other people,
• 15:09
  Speaker 1: specifically Hutchins and SUSA. Baldwin clearly should have known of
• 15:13
  Speaker 1: the danger of his actions, which led to the death
• 15:15
  Speaker 1: of Hutchins. Baldwin as producer, industry standards, best practices, common practices,
• 15:22
  Speaker 1: historical practices, policies and or procedures, and Union guided policies
• 15:27
  Speaker 1: and or procedures require and or mandate certain members of
• 15:31
  Speaker 1: a filming crew have assumed or are assigned certain obligations
• 15:35
  Speaker 1: and responsibilities industry experts and or armorers were consulted for
• 15:40
  Speaker 1: information and evidence in this industry. Baldwin asserted and is
• 15:44
  Speaker 1: clearly shown to be a producer on this particular film
• 15:48
  Speaker 1: based on his position. Baldwin, through acts and or omissions,
• 15:52
  Speaker 1: contributed to or failed to mitigate or address multiple significant
• 15:57
  Speaker 1: safety violations, issues, and or concerns that resulted in multiple
• 16:01
  Speaker 1: noted instances of recklessness leading up to, contributing to, and
• 16:06
  Speaker 1: causing the shooting. Since the shooting, Baldwin has asserted publicly
• 16:11
  Speaker 1: that he is an expert in the realm of firearms
• 16:14
  Speaker 1: and filmmaking. Investigation has revealed that Baldwin has been involved
• 16:19
  Speaker 1: in at least forty films or TV productions that involve firearms,
• 16:22
  Speaker 1: with Baldwin either directly handling firing a weapon, or in
• 16:27
  Speaker 1: a scene with firearms being directly handled and or fired
• 16:31
  Speaker 1: by someone else. Further investigation of this list revealed a
• 16:35
  Speaker 1: multitude of instances, either from the movie itself or from
• 16:39
  Speaker 1: the movie poster, showing Baldwin with his finger in the
• 16:42
  Speaker 1: trigger guard and on the trigger in instances where according
• 16:46
  Speaker 1: to industry standards and common firearms safety standards it should
• 16:49
  Speaker 1: not have been. Experts industry standards and basic firearm safety
• 16:54
  Speaker 1: protocols and training. Consider this reckless behavior requiring immediate remediation.
• 17:00
  Speaker 1: Shows Baldwin failed to appear for mandatory firearms training and
• 17:04
  Speaker 1: firearms safety training prior to filming. Evidence also shows that
• 17:08
  Speaker 1: Baldwin requested and was afforded a training session on set
• 17:13
  Speaker 1: and that through statements, the training was estimated to be
• 17:16
  Speaker 1: thirty minutes in length due to the distraction of him
• 17:19
  Speaker 1: talking to his family on his cell phone during the training.
• 17:23
  Speaker 1: The onset and limited time of training does not comport
• 17:26
  Speaker 1: to industry standards, and evidence shows Baldwin was in a
• 17:30
  Speaker 1: position to manage oversea come ins and require safety training
• 17:35
  Speaker 1: too industry standards. Baldwin's failure to ensure minimum standards were
• 17:40
  Speaker 1: met is considered reckless in the industry. Page six. Basic
• 17:46
  Speaker 1: firearms safety protocols and industry standards are provided during this training,
• 17:51
  Speaker 1: which includes basic firearms safety rules and mindset, including but
• 17:55
  Speaker 1: not limited to, not touching pressing the trigger until the
• 17:59
  Speaker 1: shooter is to fire and is sure of his or
• 18:02
  Speaker 1: her target, treating all firearms as if they are loaded,
• 18:05
  Speaker 1: and not covering anything with the muzzle of a firearm.
• 18:09
  Speaker 1: The shooter is not willing to destroy. The Evidence clearly
• 18:13
  Speaker 1: indicates that Baldwin recklessly ignored those rules on multiple occasions,
• 18:18
  Speaker 1: resulting in the fatal shooting. Evidence shows that the production
• 18:23
  Speaker 1: company hired Read as the lead armorer for the production.
• 18:26
  Speaker 1: Evidence shows that Reid possessed no certification or certifiable training
• 18:31
  Speaker 1: or union card for this practice, and that she admitted
• 18:35
  Speaker 1: she was the armorer for only one film prior to
• 18:38
  Speaker 1: this production, approximately in April of twenty twenty one, as
• 18:42
  Speaker 1: the producer of a firearm intense film. Evidence shows that
• 18:46
  Speaker 1: Baldwin allowed, through axtra omissions, the hiring of an inexperienced
• 18:50
  Speaker 1: and unqualified Read for this production, failed to mitigate or
• 18:55
  Speaker 1: establish more precautions to protect against reads and experience, or
• 18:59
  Speaker 1: failed to demand the minimum safety standards, protocols and requirements
• 19:03
  Speaker 1: on set. Reid was assigned by a production to be
• 19:06
  Speaker 1: an assistant prop master in addition to her armorer duties.
• 19:10
  Speaker 1: Evidence shows that this resulted in Read not focusing her
• 19:14
  Speaker 1: entire attention on her primary responsibility as armorer. Evidence shows
• 19:19
  Speaker 1: Baldwin violated industry standards and practices by allowing this reckless
• 19:24
  Speaker 1: and generally prohibited practice, resulting in reckless actions. Taking place
• 19:28
  Speaker 1: prior to and on the day of the shooting. Evidence
• 19:32
  Speaker 1: shows that Sarah Zachary was hired as the prop master
• 19:35
  Speaker 1: for the production. It also shows that she was assigned
• 19:38
  Speaker 1: to assist Read with her armoring duties. Evidence and statements
• 19:42
  Speaker 1: show that Sarah Zachary possessed little to no experience with firearms,
• 19:46
  Speaker 1: firearms safety, armorer duties and responsibilities, etc. It also shows
• 19:51
  Speaker 1: that Sarah Zachary was assigned to allowed to load and
• 19:55
  Speaker 1: unload ammunition in firearms, handle firearms, and act as an
• 19:59
  Speaker 1: armor went on set with actors doubles taking possession of
• 20:04
  Speaker 1: the firearms. Evidence shows this was done multiple times and
• 20:08
  Speaker 1: without Read being on the set as well. Evidence shows
• 20:12
  Speaker 1: that despite the production team's awareness of the safety issues,
• 20:15
  Speaker 1: Baldwin did not address this reckless process procedure that is
• 20:19
  Speaker 1: contrary to industry standards and safety protocols and commonly understood
• 20:23
  Speaker 1: firearms safety procedures. Prior to the shooting incident, Sarah Zachary
• 20:28
  Speaker 1: had a negligent discharge while handling a revolver intended to
• 20:32
  Speaker 1: be used by an actor in the filming. This weapon
• 20:35
  Speaker 1: was not Baldwin's weapon, but had similar same mechanical function
• 20:39
  Speaker 1: and appearance single action revolver and was intended for use
• 20:43
  Speaker 1: by the quote marshals. Unquote statements show that Sarah Zachary
• 20:47
  Speaker 1: was holding and manipulating the weapon while walking, and she
• 20:51
  Speaker 1: discharged a blank cartridge into the ground next to her foot.
• 20:55
  Speaker 1: Industry standards, practices and protocol consider negligent discharges reckless in
• 21:00
  Speaker 1: nature that require immediate action and or swift mediation up
• 21:04
  Speaker 1: to and including remedial training, demotion, removal from the set, termination, etc.
• 21:10
  Speaker 1: Evidence shows Baldwin failed to act to address this reckless
• 21:14
  Speaker 1: situation or to direct Read to mitigate or address the situation.
• 21:30
  Speaker 1: Crime Stories with Nancy Grace Pay seven. Also prior to
• 21:36
  Speaker 1: the shooting incident, another negligent discharge was committed by a
• 21:39
  Speaker 1: stunt double as he was handling, manipulating a lever action
• 21:43
  Speaker 1: period rifle loaded and left unattended with the stunt performer
• 21:48
  Speaker 1: while in a holding ten. Baldwin failed to act, the
• 21:51
  Speaker 1: evidence shows to address this reckless situation or to direct
• 21:54
  Speaker 1: Read to mitigate or address the negligent discharge. Through evidence
• 22:00
  Speaker 1: and interviews, these reckless and serious safety violations were deemed
• 22:03
  Speaker 1: negligent by the investigation as there was no indication or
• 22:07
  Speaker 1: evidence that the firearms in question malfunctioned at any time. Rather,
• 22:12
  Speaker 1: there is evidence the weapons fired because of mishandling or
• 22:16
  Speaker 1: misuse by those handling the firearm ie pressing the trigger
• 22:20
  Speaker 1: when it should not be in his producer's position. The
• 22:23
  Speaker 1: evidence indicates Baldwin also did not act to address the
• 22:27
  Speaker 1: lack of daily safety meetings that are required to be
• 22:30
  Speaker 1: conducted by the first assistant director. Evidence indicates that honor
• 22:34
  Speaker 1: about the thirteenth day of filming, only three or four
• 22:37
  Speaker 1: safety meetings were conducted by the assistant director. Practice and
• 22:41
  Speaker 1: standards investigated indicate that a daily safety meeting should be
• 22:46
  Speaker 1: conducted with the crew, regardless of the scenes for the
• 22:49
  Speaker 1: day's shoot. The lack of meetings and the lack of
• 22:52
  Speaker 1: appropriate content of said meetings resulted in a climate of recklessness,
• 22:56
  Speaker 1: as evidenced by the conduct of the cast and crew
• 23:00
  Speaker 1: documented through statements and evidence. In addition, no safety meeting
• 23:04
  Speaker 1: was conducted on the day of the incident. Safety meetings
• 23:07
  Speaker 1: were supposed to be listed on the call sheet daily
• 23:10
  Speaker 1: but were not. Meetings were called randomly throughout the day
• 23:13
  Speaker 1: with no mandatory attendance required. The meetings were impromptu. These
• 23:17
  Speaker 1: meetings should pursue it to standard protocols be conducted in
• 23:21
  Speaker 1: the morning prior to the beginning of the day, where
• 23:23
  Speaker 1: all members of the cast and crew should be required
• 23:26
  Speaker 1: to attend. On October twenty twenty one, the original camera
• 23:30
  Speaker 1: crew resigned citing safety concerns, commute times and distances, pay,
• 23:35
  Speaker 1: and other issues. On October twenty first, twenty twenty one,
• 23:39
  Speaker 1: a new crew was brought in to begin filming right away.
• 23:42
  Speaker 1: Evidence indicates that during the church scene in question, the
• 23:45
  Speaker 1: director and director of photography should have been outside the church,
• 23:49
  Speaker 1: viewing the scene from a large monitor covered by a
• 23:52
  Speaker 1: tent shade screen commonly referred to as a quote video village.
• 23:56
  Speaker 1: Unquote statements indicate that Joel Susa and Helena Hutchins decided
• 24:00
  Speaker 1: to be in the church with the camera crew. Due
• 24:03
  Speaker 1: to the abrupt change of the camera crew, evidence indicates
• 24:07
  Speaker 1: that Baldwin failed to act to address any safety or
• 24:10
  Speaker 1: continuity concerns with the new crew, causing a reckless situation
• 24:14
  Speaker 1: to occur on the day of the shooting. On the
• 24:17
  Speaker 1: day of the shooting, evidence and statements show that impromptu
• 24:20
  Speaker 1: plans were made to rehearse and then shoot a scene
• 24:24
  Speaker 1: inside of the church and for this particular scene, it
• 24:28
  Speaker 1: was to only involve Baldwin. Evidence and statements show that
• 24:32
  Speaker 1: the first Assistant Director, David Halls hereinafter Halls, was present
• 24:37
  Speaker 1: on the set as with Baldwin. Evidence, common standards, protocol
• 24:41
  Speaker 1: and statements show that Halls had the additional duty of
• 24:44
  Speaker 1: safety coordinator by virtue of his position. However, that position
• 24:49
  Speaker 1: does not afford the handling or manipulation of firearms. Evidence
• 24:54
  Speaker 1: and statements also show that Halls, by virtue of his position,
• 24:58
  Speaker 1: is the first point of contact for an armorer when
• 25:00
  Speaker 1: they bring a firearm on the set, and is the
• 25:03
  Speaker 1: first person required to conduct safety check with the armor
• 25:06
  Speaker 1: and weapons industry. Standards and procedures require page eight that
• 25:13
  Speaker 1: the armorer, in the presence of the first assistant director,
• 25:16
  Speaker 1: show the weapon is clear and safe. Then, if applicable,
• 25:20
  Speaker 1: show the firearm is loaded with blanks or dummy rounds,
• 25:24
  Speaker 1: visually and physically checking each round individually for safety by
• 25:28
  Speaker 1: pulling each round out of the firearm and showing the
• 25:31
  Speaker 1: first assistant director and the actor. The first assistant director
• 25:35
  Speaker 1: then allow follows the queue of the armorer calling cold
• 25:39
  Speaker 1: or hot weapon on set, then broadcasting that statement across
• 25:44
  Speaker 1: the radio which notifies all cast and crew. Evidence clearly
• 25:48
  Speaker 1: shows this did not occur on the day of the shooting.
• 25:52
  Speaker 1: At least two times, Baldwin failed to address these reckless
• 25:56
  Speaker 1: incidents and deviations from industry standards and farm safety rules
• 26:01
  Speaker 1: directly contributing to the fatal shooting. Halls did not adequately
• 26:06
  Speaker 1: check the firearm with Read prior to handing it to Baldwin,
• 26:09
  Speaker 1: who additionally did not check it with the armorer read.
• 26:13
  Speaker 1: Halls is further required to announce to crew when a
• 26:16
  Speaker 1: firearm will be fired in the scene. I announced quote
• 26:19
  Speaker 1: fire in the hole, unquote, or other common phrase to
• 26:22
  Speaker 1: put the crew on notice for shooting, loud noise, hearing protection, etc.
• 26:27
  Speaker 1: The evidence and statements show that this requirement did not
• 26:31
  Speaker 1: meet safety and industry standards, and further shows that Baldwin
• 26:35
  Speaker 1: failed to address and or mitigate this reckless and dangerous practice. Hall's,
• 26:41
  Speaker 1: again by virtue of his position and industry standards and practices,
• 26:46
  Speaker 1: is prohibited and or strictly discouraged from handling any of
• 26:50
  Speaker 1: the firearms on a set. As such, industry standards, policies
• 26:55
  Speaker 1: and practices call for the armorer to be on set
• 26:58
  Speaker 1: and to stay on set anytime a firearm is on set.
• 27:03
  Speaker 1: This practice and standard were not conducted on the day
• 27:06
  Speaker 1: of the shooting and was allowed by Baldwin prior to lunch.
• 27:11
  Speaker 1: Statements and evidence show that Halls requested Baldwin's firearm be
• 27:15
  Speaker 1: prepped and brought to the set by the armorer. Read.
• 27:19
  Speaker 1: Reid states that she loaded the firearm with dummy rounds
• 27:22
  Speaker 1: prior to lunch, so she didn't perform a second safety
• 27:25
  Speaker 1: check on her own or with Halls and the firearm,
• 27:29
  Speaker 1: just showing him the barrel and not removing the bullets
• 27:32
  Speaker 1: to show the firearm was safe, and then Halls took
• 27:35
  Speaker 1: possession of the firearm from Read. Read departed the church.
• 27:39
  Speaker 1: Halls provided Baldwin with the firearm so he could rehearse
• 27:43
  Speaker 1: practice with the weapon. However, there are contradictory statements that
• 27:48
  Speaker 1: Read brought an empty gun to Halls and at some
• 27:52
  Speaker 1: point loaded it with dummy rounds while in the church.
• 27:56
  Speaker 1: Read then showed Halls the firearm again. Read did not
• 28:01
  Speaker 1: do a proper safety check with halser Baldwin. Read then
• 28:05
  Speaker 1: left the church. Read leaving the set and Hall's handling
• 28:09
  Speaker 1: the firearm are considered very reckless actions. According to industry standards, expectation,
• 28:15
  Speaker 1: and common firearms safety protocols and considerations. There is no
• 28:20
  Speaker 1: evidence or information that Baldwin addressed or acted to mitigate
• 28:25
  Speaker 1: these reckless actions. In addition, for a rehearsal, a rubber
• 28:30
  Speaker 1: or replica firearms should have been used only when the
• 28:33
  Speaker 1: actual scene was to be filmed. Should the weapon have
• 28:37
  Speaker 1: been loaded with dummy rounds. Baldwin, Halls and read All
• 28:41
  Speaker 1: knew this was standard protocol. Further evidence and statements show
• 28:46
  Speaker 1: that when the crew took a break for lunch, firearms,
• 28:49
  Speaker 1: including Baldwin's, were secured in the prop trucks safe Outside
• 28:54
  Speaker 1: of the church was a cart used by the armorer
• 28:56
  Speaker 1: and propmaster, contrary at standard protocol, that contained leather gear
• 29:00
  Speaker 1: rigs like holsters, belts, and ammunition. Evidence clearly indicates this
• 29:05
  Speaker 1: cart and associated items was not secured during the break
• 29:09
  Speaker 1: and was not in visual range of read or Sarah
• 29:12
  Speaker 1: Zachary for safety and security. The unsecured cart with the equipment,
• 29:16
  Speaker 1: ammunition and firearm is page nine considered very reckless by
• 29:22
  Speaker 1: industry standards and by common firearms safety standards and protocol.
• 29:27
  Speaker 1: Evidence indicates that Baldwin failed to act to address and
• 29:31
  Speaker 1: or mitigate these serious and reckless safety violations. Upon returning
• 29:36
  Speaker 1: from lunch, evidence and statements show that Read retrieves Baldwin's
• 29:40
  Speaker 1: preferred revolver, but Read does not perform another safety check. Additionally,
• 29:45
  Speaker 1: Read again is asked and complies with Halls by handing
• 29:49
  Speaker 1: him the firearm once inside the church. There are also
• 29:53
  Speaker 1: contradictory statements that Read brought in the firearm empty, showed
• 29:57
  Speaker 1: it to Halls, and ultimately later loaded it with dummy
• 29:59
  Speaker 1: roun Regardless, the evidence is consistent that Read failed to
• 30:04
  Speaker 1: show Halls each dummy round and pull them out for safety,
• 30:07
  Speaker 1: nor did Halls request it. Reid did not show Baldwin
• 30:11
  Speaker 1: the loaded firearm either, nor did he request to see
• 30:14
  Speaker 1: the rounds, which is standard protocol. Read left the church.
• 30:18
  Speaker 1: Evidence and statements also indicated that an after lunch safety
• 30:22
  Speaker 1: check of the firearm to industry standards between Read and
• 30:25
  Speaker 1: Halls did not occur. This after lunch sequence of events
• 30:29
  Speaker 1: is documented to have had no less than four extremely
• 30:32
  Speaker 1: reckless violations of industry standards, safety protocol best practices, and
• 30:37
  Speaker 1: common firearms safety protocols in a very short compressed period
• 30:41
  Speaker 1: of time. On the day of the shooting alone, evidence
• 30:44
  Speaker 1: shows that no less than a dozen acts or omissions
• 30:47
  Speaker 1: of recklessness occurred in the short time prior to lunch
• 30:50
  Speaker 1: and the time of the shooting. This does not include
• 30:53
  Speaker 1: the reckless handling of the firearm by Baldwin. Baldwin, by
• 30:57
  Speaker 1: act or omission or failure to act in his position
• 30:59
  Speaker 1: as a producer, directly contributed and or failed to mitigate
• 31:04
  Speaker 1: numerous reckless and dangerous actions during a very short time period. Finally,
• 31:10
  Speaker 1: industry standards protocols in common firearms safety procedures on the
• 31:14
  Speaker 1: movie sets require the armorer, after conducting a safety check
• 31:18
  Speaker 1: with the first assistant director, to conduct a second safety
• 31:22
  Speaker 1: check with the actor to be handling the firearm. This
• 31:25
  Speaker 1: reckless violation of standards and firearm safety occurred two times
• 31:29
  Speaker 1: leading up to the shooting, and Baldwin failed to act
• 31:32
  Speaker 1: to mitigate or correct the reckless safety violations, neither in
• 31:35
  Speaker 1: his capacity as actor nor producer. This reckless deviation from
• 31:40
  Speaker 1: known standards and practices and protocol directly caused the fatal shooting.
• 31:44
  Speaker 1: Baldwin acted with reckless disregard and or more than mere
• 31:49
  Speaker 1: negligence in this incident. Baldwin acted with willful disregard of
• 31:54
  Speaker 1: the safety of others and in a manner that endangered
• 31:57
  Speaker 1: other people, and he clearly should known the danger of
• 32:01
  Speaker 1: his actions which led to the death of Hutchins. Furthermore,
• 32:05
  Speaker 1: Baldwin handled the weapon in a negligent manner. Evidence exists
• 32:09
  Speaker 1: to clearly show that on October twenty first, twenty twenty one,
• 32:13
  Speaker 1: Helena Hutchins was killed when Baldwin fired a firearm that
• 32:17
  Speaker 1: he pointed at her. The evidence and statements documented in
• 32:20
  Speaker 1: this affidavit confirmed many instances of extremely reckless acts or
• 32:25
  Speaker 1: reckless failures to act by Baldwin in a ten day period.
• 32:29
  Speaker 1: Evidence clearly shows that none of the incidents or issues
• 32:33
  Speaker 1: were addressed by Baldwin in his position as actor or
• 32:37
  Speaker 1: producer to mitigate future occurrences of recklessness, correct reckless behavior,
• 32:42
  Speaker 1: or correct training deficiencies. Baldwin's deviation from known standards, practices
• 32:48
  Speaker 1: and protocol directly caused the fatal death of Hutchins by
• 32:52
  Speaker 1: not receiving the required training on firearms, not checking the
• 32:56
  Speaker 1: firearm with the armorer, letting the armor the firearm in
• 33:01
  Speaker 1: the church without being page ten present, deviating from the
• 33:06
  Speaker 1: practice of only accepting the firearm from the armor and
• 33:09
  Speaker 1: not dealing with the safety complaints onset and or making
• 33:12
  Speaker 1: sure safety meetings were held. Putting his finger on the
• 33:16
  Speaker 1: trigger of a real firearm when a replica or a
• 33:18
  Speaker 1: rubber gun should have been used, pointing the firearm at
• 33:22
  Speaker 1: Hutchins and Susa, and the overall handling of the firearm
• 33:26
  Speaker 1: in a negligent manner. Baldwin acted with wilful disregard for
• 33:30
  Speaker 1: the safety of others and in a manner which endangered
• 33:34
  Speaker 1: other people, specifically Hutchins and Susa. Baldwin clearly should have
• 33:38
  Speaker 1: known the danger of his actions was led to the
• 33:41
  Speaker 1: death of Hutchins. Probable cause exists that Baldwin committed involuntary
• 33:46
  Speaker 1: manslaughter contrary to and defined in in him Essay thirty
• 33:50
  Speaker 1: Dash two Dash three quote manslaughter in the commission of
• 33:55
  Speaker 1: a lawful act which might produce death in an unlawful
• 33:58
  Speaker 1: manner or without due caution and circumspection, or during the
• 34:02
  Speaker 1: unlawful act, not amounting to a felony to it negligent
• 34:06
  Speaker 1: use of a deadly weapon. Robert Schilling, Special Investigator, First
• 34:12
  Speaker 1: Judicial District Attorney's Office, three two seven Santovall Street, Santa Fe,
• 34:16
  Speaker 1: New Mexico,