Roger Dale Davis Jr. — Direct/Cross/Redirect
548 linesJUDGE NEWMAN: You may call your next witness.
MR. FERNANDEZ: State calls Roger Dale Davis.
The witness, ROGER DALE DAVIS, was first duly sworn and testified as follows:
COURT CLERK: If you would, please, sir, be seated. State your full name for the record, spell your last name, and adjust the microphone so we can hear you.
ROGER DALE DAVIS JR.: My name is Roger Dale Davis, Jr. Last name is D-a-v-i-s.
DIRECT EXAMINATION
BY MR. FERNANDEZ:
MR. FERNANDEZ: And, Mr. Davis, do you go by Dale?
ROGER DALE DAVIS JR.: Dale, Roger, either way.
MR. FERNANDEZ: Okay. Or Mr. Davis?
ROGER DALE DAVIS JR.: It don't matter.
MR. FERNANDEZ: If you would do me a favor? Because it's a little hard to hear some folks in this courtroom, if you would make sure that that microphone is pulled close to you and speak into it, we'd all greatly appreciate it. All right, Dale, why don't you tell us a little bit about yourself. Where were you born? Where were you raised?
ROGER DALE DAVIS JR.: I was born in Hampton County. I was raised in Hampton. Went to Wade Hampton High School.
MR. FERNANDEZ: Okay, and, again, if you would please try to get a little closer to that microphone. I know it's tight in there. All right. What line of work do you -- have you done?
ROGER DALE DAVIS JR.: Construction work all my life.
MR. FERNANDEZ: Do you -- did you ever have an opportunity to work at the farm in Moselle?
MR. FERNANDEZ: Okay. Is that close to where you actually live?
ROGER DALE DAVIS JR.: Mile and a half.
MR. FERNANDEZ: How did you -- how did you get -- how did you become familiar with the Murdaugh family and the Moselle property? How did you start working there?
ROGER DALE DAVIS JR.: I was walking and Alex would stop and talk with me, and he asked me one day about cleaning the kennels for him, and probably a couple of months, six months later, then he asked me to come do it on the weekends.
MR. FERNANDEZ: And that started about four years ago?
ROGER DALE DAVIS JR.: About four years ago.
MR. FERNANDEZ: And walk us through the process. What did you do, and how many times a day did you do it?
ROGER DALE DAVIS JR.: Twice a day. Once in the morning and once in the evening.
MR. FERNANDEZ: What time in the morning generally?
ROGER DALE DAVIS JR.: Average around 7:00.
MR. FERNANDEZ: Do you wake up early?
ROGER DALE DAVIS JR.: Oh, yeah.
MR. FERNANDEZ: So 7:00 a.m., and then what time in the evenings generally?
ROGER DALE DAVIS JR.: Usually around -- I would try to get there around 3:30 or 4:00.
MR. FERNANDEZ: How long does the process typically take you?
ROGER DALE DAVIS JR.: About 45 minutes.
MR. FERNANDEZ: And walk us through what that process is. What do you do out there?
ROGER DALE DAVIS JR.: In the morning times I would take -- go feed all the dogs, give them time to eat. I would feed the chickens. That way the dogs would have time to eat. Then I would wash the pens out. Then I would usually roll the hose up, and then go to the house, and then come back in the afternoon and repeat the process.
MR. FERNANDEZ: Now, you mentioned washing the pens out. Did the dogs, did they -- are dog beds --
MR. FERNANDEZ: -- in their kennels?
ROGER DALE DAVIS JR.: Yeah. Buster, Buster -- excuse me, Grady and Bubba had two dog pens -- beds.
MR. FERNANDEZ: And if you're washing it out, meaning -- are you spraying it with water?
ROGER DALE DAVIS JR.: Sprayed it with water.
MR. FERNANDEZ: What did you do with the dog beds?
ROGER DALE DAVIS JR.: I would stick them up on top of the dog box.
MR. FERNANDEZ: And then did you leave them up there or did you put them back?
ROGER DALE DAVIS JR.: Normally during -- typically once I washed the pens out, I would lay them back down. Especially if it was cold in the wintertime, I would lay them back down on the ground. But during the summertime, you would wait until that afternoon to lay them back down on the ground.
MR. FERNANDEZ: In the four years you worked there, did you get to know the property fairly well?
MR. FERNANDEZ: And did you get to know the folks that lived there pretty well?
MR. FERNANDEZ: Did you get to know Maggie Murdaugh?
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: All right. Well, tell us what your experiences with her were.
ROGER DALE DAVIS JR.: Normally she was just so laid back. She would talk to you like a normal person. We'd sit there and talk about the dogs. She would talk about sometimes where she would be at the beach. And she normally would tell me, you know I'm going to the beach. I'm taking Bubba and Grady with me or whatnot, or I'm going to leave them. Or if it was real hot, she would want to put them over there in the ice house, turn the air condition on where they would have the ice -- the coolers at.
MR. FERNANDEZ: Did Maggie like to spend type with the dogs?
ROGER DALE DAVIS JR.: All the time.
MR. FERNANDEZ: You mentioned the ice house. Was that the processing house kind of on the back of the hangar?
ROGER DALE DAVIS JR.: Property. That was the --
MR. FERNANDEZ: And was it air conditioned? Is that why you said she would put them in there?
ROGER DALE DAVIS JR.: During the summertime if it got real hot.
MR. FERNANDEZ: And that house, does it have air conditioning, that shed?
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: All right. Did you get to know Paul?
MR. FERNANDEZ: All right. What was your experiences with him?
ROGER DALE DAVIS JR.: He was a little wild and crazy, but he would work. That boy would work.
MR. FERNANDEZ: He liked being at the farm?
ROGER DALE DAVIS JR.: He liked getting out and doing things, hunting and -- but he would work on the tractor or whatever Daddy needed him to do.
MR. FERNANDEZ: And did you get to know Alex?
ROGER DALE DAVIS JR.: I did.
MR. FERNANDEZ: Is he here today?
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: Where is he?
ROGER DALE DAVIS JR.: He's sitting right over there.
MR. FERNANDEZ: Would you explain what he's wearing?
ROGER DALE DAVIS JR.: Wearing a suit and a pair of glasses, blue looking shirt.
MR. FERNANDEZ: And what were your experiences with Alex?
ROGER DALE DAVIS JR.: He was always very particular. He would want the dog buckets washed out. If it looked like they started getting any kind of green or brown looking stuff in the water, he wanted to make sure -- which I usually washed them out every two weeks anyway with bleach. But I always dumped them every day.
MR. FERNANDEZ: Was Alex easy to get ahold of?
MR. FERNANDEZ: All right. Explain that. What do you mean by that?
ROGER DALE DAVIS JR.: He would either be in court or doing something with business. It would sometimes be a little bit difficult to get ahold of him.
MR. FERNANDEZ: Who did you see most often when you were out there?
ROGER DALE DAVIS JR.: Ms. Maggie or either Paul.
MR. FERNANDEZ: And how did Maggie and Paul typically come to and from the big house to the kennel area?
ROGER DALE DAVIS JR.: Paul would usually be in his truck. Very --
MR. FERNANDEZ: We've heard a lot about trucks. Which truck was that?
ROGER DALE DAVIS JR.: His white F150 unlessen his daddy had him doing something. Then he would have to drive the F250, but most of the time he would be in his white F150.
MR. FERNANDEZ: And what color was the F250?
ROGER DALE DAVIS JR.: It was also white.
MR. FERNANDEZ: So, two white truck were what he typically used?
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: And how about Maggie?
ROGER DALE DAVIS JR.: She normally drove her Range Rover until he -- she got the black Mercedes.
MR. FERNANDEZ: And then what would she drive after that?
ROGER DALE DAVIS JR.: Most of the time she would drive the black Mercedes.
MR. FERNANDEZ: And would she load her dogs, the house -- first of all let's go back. Which dogs were down there? Do you remember all the dogs.
ROGER DALE DAVIS JR.: Bubba, Grady, Maggie. Then they started letting -- I can't remember his name right off -- Dahlia was there, Armadillo, and I call her Tappy Toes. I don't know what they called her but that's what I always called her.
MR. FERNANDEZ: And I think the other dog, was that a dog owned by one of Paul's friends, Rogan? Is that the one you're referring to?
MR. FERNANDEZ: What type of dog was it?
ROGER DALE DAVIS JR.: A lab, chocolate lab.
MR. FERNANDEZ: And which dogs were the family dogs, the family pets?
ROGER DALE DAVIS JR.: Grady, Bubba, and Maggie.
MR. FERNANDEZ: And what kind of dogs were they?
ROGER DALE DAVIS JR.: Labs.
MR. FERNANDEZ: And colors?
ROGER DALE DAVIS JR.: Bubba was yellow, Grady was black, and Maggie was yellow.
MR. FERNANDEZ: And would they typically -- where would they typically stay, those dogs, those animals?
ROGER DALE DAVIS JR.: It all depend on -- most of the time -- because Bubba was very rambunctious, so they got to where they would lock him up in the kennels at night, and most of the time they would lock all of the labs up in the kennels to keep them from roaming off. But she, Ms. Maggie, would take them out during -- when she was home. Usually a lot of times after I done left, she would take them up to the house and let them roam around the house -- the yard a couple of hours, and then she would bring them back down to the pens.
MR. FERNANDEZ: And if Maggie -- would Maggie load them into her car if she was taking them elsewhere, to the beach or wherever else she was staying?
ROGER DALE DAVIS JR.: Wherever she was staying at, she would load them in the vehicle. Most of the time she would load them right in her vehicle.
MR. FERNANDEZ: Dale, I'm going to hand you what's been marked State's Exhibits --
(Break in proceedings.)
MR. FERNANDEZ: I am going to hand you what's been mark as State's Exhibits 505, 506, 502, 503, 504, and 516. Dale, if you wouldn't mind, please take a moment to review all of these and let me know if you recognize what they show.
ROGER DALE DAVIS JR.: They show the kennels.
MR. FERNANDEZ: And then the -- I believe there's one diagram there, if you recognize what that shows.
ROGER DALE DAVIS JR.: It shows the diagram drawing of the kennel.
MR. FERNANDEZ: Very good.
MR. FERNANDEZ: Your Honor, we would move to place all of those exhibits into evidence, I believe without objection.
MR. GRIFFIN: No objection, Your Honor.
JUDGE NEWMAN: They're admitted without objection.
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 502 WAS RECEIVED INTO EVIDENCE.)
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 503 WAS RECEIVED INTO EVIDENCE.)
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 504 WAS RECEIVED INTO EVIDENCE.)
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 505 WAS RECEIVED INTO EVIDENCE.)
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 506 WAS RECEIVED INTO EVIDENCE.)
(PHOTO MARKED AS STATE'S EXHIBIT NUMBER 516 WAS RECEIVED INTO EVIDENCE.)
MR. FERNANDEZ: All right, Dale, I'm going to show you what's been marked as State's Exhibit 505.
MR. FERNANDEZ: Can we have the ELMO, please?
(Break in proceedings.)
MR. FERNANDEZ: Dale, while we get this loaded up, tell us -- tell me a little bit -- I know -- did you have a particular way of hosing down and, you know, with the -- dealing with the hose? Tell us a little bit about what that was about.
ROGER DALE DAVIS JR.: The particular way of me putting the hose away or --
MR. FERNANDEZ: Right.
ROGER DALE DAVIS JR.: Normally after I got through washing, I would stretch the house straight out.
MR. FERNANDEZ: Into which direction?
ROGER DALE DAVIS JR.: Back towards the shed room right there, the dog feed room.
MR. FERNANDEZ: All right, and we now have the ELMO up, and we're looking at Exhibit 505. And the feed room, I believe, is what you referred to. Is that the structure on the far right?
MR. FERNANDEZ: Okay. All right, and then where -- in this picture where is the hose you're talking about located?
ROGER DALE DAVIS JR.: It's back towards the left-hand side back towards the farthest end.
MR. FERNANDEZ: Is that that yellow, wrapped up --
ROGER DALE DAVIS JR.: That's that yellowish/green looking hose.
MR. FERNANDEZ: All right. Go ahead and explain this, what you would typically do after rinsing off and putting the hose away.
ROGER DALE DAVIS JR.: I would stretch the hose out back towards the feed room. I would cut the valve off at the top, which is right up above as the hose come in. Then I would walk back down and cut the valve on at the end of the hose. That way it would release the pressure, and then I would roll it up slowly until I had it uniform.
MR. FERNANDEZ: Were you pretty particular about how you wound that hose?
MR. FERNANDEZ: And why would you do it that way? And did you do it that way every time?
ROGER DALE DAVIS JR.: Every time.
MR. FERNANDEZ: And why would you do it so particularly?
ROGER DALE DAVIS JR.: Because if you notice how the hose right now is kinked up, it would start making the hose where if you didn't do it right, eventually would it keep kinking. It would start making it where it didn't want to -- and it would cause the hose to start having little splits in them.
MR. FERNANDEZ: The picture that you're seeing there, that hose, is that the way you would rewind it up?
MR. FERNANDEZ: How do you know?
ROGER DALE DAVIS JR.: I'm very particular how I roll that. If you notice the pressure on that hose, somebody used that hose after I did because it's twisted. And the nozzle is too far up. The nozzle, I could always have it and make sure it was laying down flat. That nozzle is too far up.
MR. FERNANDEZ: Dale, I'm going to show you what's been marked as State's Exhibit 516. And, again, please briefly explain what it is we're looking at there.
ROGER DALE DAVIS JR.: The drawing of the kennel.
MR. FERNANDEZ: Okay. I'm going to hand you a pen, and with the Court's permission I'm going to ask you to go ahead and fill in -- well, first of all let's back up. Did you work the -- were you aware of the events surrounding June 7, 2021, where Maggie and Paul were murdered?
ROGER DALE DAVIS JR.: I received a phone call from C.B. that the SLED wanted to see me because Ms. Maggie and Paul had been murdered, and I thought he was joking but he told me no. And I told him give me 5 minutes and I would be up there because I was going to carry my trash off at the time. And I got up there and the dogs was raising Cain, and I asked him could I go ahead and feed the dogs so they would quiet down, and they told me to give them a few minutes, and then they gave me permission to feed them. And as soon as I fed them, they just quiet down. They didn't bark no more.
MR. FERNANDEZ: Okay. So, you were familiar about that incident at the --
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: And you went out there what day?
ROGER DALE DAVIS JR.: That morning.
MR. FERNANDEZ: Was that the 8th, the morning of Tuesday?
ROGER DALE DAVIS JR.: When the murders happened, yes.
MR. FERNANDEZ: Did you work every day leading up to that day?
MR. FERNANDEZ: And did you do that normal routine which you already described?
MR. FERNANDEZ: All right. Did you, in fact, do that normal routine on the Monday of the -- before the murders?
MR. FERNANDEZ: Okay. Walk us through that day. What did you do in the morning?
ROGER DALE DAVIS JR.: I got there probably around 7:00, between 7:00 and 8:00. It all depended on when I got up, but most of the time I got up early. I would be there before 6:30 or 7:00. I would go through there, feed the dogs, feed -- then go feed the chickens. That would give the dogs time to eat their food, and then I would wash the pens out.
MR. FERNANDEZ: And was anything unusual or out of place when you were down there in the morning?
MR. FERNANDEZ: And did you repeat the process again in the afternoon, the evening time?
ROGER DALE DAVIS JR.: I did.
MR. FERNANDEZ: All right. What time did you -- on Monday, June 7th, what time did you go back to the pens?
ROGER DALE DAVIS JR.: I got there before 4:00 o'clock because I remember leaving at 4:30.
MR. FERNANDEZ: All right, and was anyone there at the time you went to the dog kennels that day?
MR. FERNANDEZ: Did you notice anything out of place when you went there to the dog kennels in the evening time?
MR. FERNANDEZ: And what did you do after arriving?
ROGER DALE DAVIS JR.: Well, once I arrived that afternoon, I got out. I fed Grady, Bubba, and Maggie because we fed them twice a day. The hunting dogs only got once a day. Took and fed them. I picked the dog beds up. I dumped all the water out because I washed all of their buckets, gave them fresh water, washed the pens out. Stretched the hose out, cut the water at the valve off at the top. Went down there and cut the water on the valve on down at the end of the hose so the water would come out, rolled the hose up, and at 4:30 I left.
MR. FERNANDEZ: And you rolled -- did you roll the hose up the way you've always done it that day?
ROGER DALE DAVIS JR.: Every time.
MR. FERNANDEZ: Do you remember how the dogs were laid out in the kennels that day when you left?
ROGER DALE DAVIS JR.: When I left, yes, sir.
MR. FERNANDEZ: And with the Court's permission, I'm going to ask the witness to please, if you would, write on that piece of paper, the exhibit -- State's Exhibit 516, beginning with -- first of all on the far right, what does that door signify in the --
ROGER DALE DAVIS JR.: Storage room, storage room/feed room.
MR. FERNANDEZ: Beginning with kennel one next to the feed room, what dog was in there when you left that day at 4:00, or before 5:00?
ROGER DALE DAVIS JR.: Grady.
MR. FERNANDEZ: All right. If you would, please write Grady on there.
ROGER DALE DAVIS JR.: (Witness complies.)
MR. FERNANDEZ: Okay, and then moving on to kennel two, what dog was in kennel two?
ROGER DALE DAVIS JR.: Bubba.
MR. FERNANDEZ: And for our reference, Grady was the black lab?
ROGER DALE DAVIS JR.: Grady is the black lab.
MR. FERNANDEZ: Okay, and Bubba is what?
ROGER DALE DAVIS JR.: Yellow lab.
MR. FERNANDEZ: Okay, and who was next to Bubba in pen three?
ROGER DALE DAVIS JR.: Maggie because she was getting bigger than Bubba.
MR. FERNANDEZ: And Maggie is a what colored lab?
ROGER DALE DAVIS JR.: Yellow. A yellow lab.
MR. FERNANDEZ: All right. Were there any dogs next to Maggie?
ROGER DALE DAVIS JR.: No, there was -- no.
MR. FERNANDEZ: Okay, and that would be kennel four was open?
ROGER DALE DAVIS JR.: That would be -- yeah. That one should have been opened. The next one down should have been Rogan's dog.
MR. FERNANDEZ: All right, can you write that in there? Just right chocolate lab, or Rogan's dog, whatever you want to write.
ROGER DALE DAVIS JR.: (Witness complies.)
MR. FERNANDEZ: That would be kennel five?
ROGER DALE DAVIS JR.: I'm trying to remember what Rogan's dog's name. That one should have been there. I don't remember what Rogan's dog's name was at the time.
MR. FERNANDEZ: Okay. Was there any dog located in kennel six? And if you want to work -- however you want to do it, sir, if you want to just fill out the rest of the dogs, the working dogs, that's fine.
ROGER DALE DAVIS JR.: Well, Dahlia was at the very end of kennel ten. I know that. Then, let's see, Armadillo should have been the next one coming back from ten. Let's see, empty on nine. All right. It should have been -- yeah, Armadillo should have been right past the hose right there. And then it would be Tappy Toes. It would be Tappy Toes right there, because they always kept Rogan's dog and Maggie -- there was a kennel in between them. So, that should have been Tappy Toes right there.
MR. FERNANDEZ: Okay. Thank you. All right, I'm going to put this on the screen and just verify that that was what you filled out. All right, Mr. Dale, I see starting with number one, Grady, then Bubba, Maggie, then five is Rogan's, six is Tappy Toes, seven is Armadillo, and ten is Dahlia. Is that correct?
ROGER DALE DAVIS JR.: That's correct.
MR. FERNANDEZ: And that's the way it was when you left the property at around 5:00 that Monday, June 7th.
MR. FERNANDEZ: And on -- for our reference on this diagram, that green circle, that represents what?
ROGER DALE DAVIS JR.: The hose, garden hose.
MR. FERNANDEZ: I'm going to show you a few more pictures. If you would, just describe what we're seeing. Are you familiar with that angle?
MR. FERNANDEZ: All right. Where are we looking at -- from this angle, where are we looking at things?
ROGER DALE DAVIS JR.: You're looking straight down the kennel where you got the hose and the walkway going down up under the kennels.
MR. FERNANDEZ: And on this picture, where would the feed room be located?
ROGER DALE DAVIS JR.: At the very end on the right hand of this picture.
MR. FERNANDEZ: Okay. When you -- in the four years you were washing out the kennels, did water collect or pool in certain areas?
ROGER DALE DAVIS JR.: It did.
MR. FERNANDEZ: All right. Can you identify in this picture those areas?
ROGER DALE DAVIS JR.: Right under the hose and right there, which should have been Armadillo's pen, there should have right there, and then right below it should have been collected, and maybe one more little spot right down towards the end of the post right there, but that would be about it.
MR. FERNANDEZ: For the record -- I think I neglected to say for the record this is State's 504. Moving on to State's 502, a very similar angle. Dale, do you see those pools of collected water that you mentioned just on the last exhibit?
MR. FERNANDEZ: And also State's 506. And, again, do you see the same angle just pulled a little farther back?
MR. FERNANDEZ: Who's the dog there on the last pen that we can see in the dog shed in the dog house?
ROGER DALE DAVIS JR.: Dahlia.
MR. FERNANDEZ: All right. Did water ever pool over by the feed room?
ROGER DALE DAVIS JR.: No. Because usually when the -- that's the reason I would go in the afternoons. The sun would come down and beat -- it would dry it up a lot quicker, especially in the summertime it would really dry it real quick. In the wintertime the sun would actually still hit the concrete around 3:00 to 4:00. It would be usually around 6:00 or so before the sun wouldn't be hitting on the concrete.
MR. FERNANDEZ: Did water pool in the front of where Bubba would have been located, or Grady?
MR. FERNANDEZ: I'm showing you State's Exhibit 503. Dale, were you able to see the water located in front of the feed room in front of the two kennels, one and two?
MR. FERNANDEZ: Is that how water would normally pool when you washed the kennels for four years?
ROGER DALE DAVIS JR.: Normally, no. There was too much water right there. You can tell where the concrete has already started drying, but there's too much water right there around the second and third pen.
MR. FERNANDEZ: Looking at this picture, what dog do we see in kennel one, and what dog do we see there in kennel two?
ROGER DALE DAVIS JR.: You see Bubba in kennel one and Maggie in kennel two.
MR. FERNANDEZ: And, again, Grady is what kind of dog?
ROGER DALE DAVIS JR.: Grady is a lab.
MR. FERNANDEZ: What color is he?
ROGER DALE DAVIS JR.: Black.
MR. FERNANDEZ: Black. Is that the -- and when we say the spots where you would put them or they were located, were there assigned kennels necessarily to the dogs?
ROGER DALE DAVIS JR.: Not really. But most of the time Ms. Maggie wanted Grady to be in that kennel right next to the feed room, and then we would usually put Bubba or Maggie in the following.
MR. FERNANDEZ: So that was just out of habit, mostly Maggie's habit?
ROGER DALE DAVIS JR.: Yes, sir.
MR. FERNANDEZ: All right. Did anyone else in the family put the dogs in a specific location, or did they put it wherever they could find a spot?
ROGER DALE DAVIS JR.: They would put it wherever they could find a spot.
MR. FERNANDEZ: But Maggie was particular about where she put them up?
ROGER DALE DAVIS JR.: Most of the time, yes.
MR. FERNANDEZ: Dale, I'm going to ask you about firearms in general. Are you familiar generally with firearms?
MR. FERNANDEZ: Did Paul have any firearms that he favored more often than others just in your experience with him?
MR. FERNANDEZ: All right. Are you familiar with an assault rifle style rifle?
MR. FERNANDEZ: All right. Tell us about the one that you observed Paul having with him most often.
ROGER DALE DAVIS JR.: When he went hog hunting, he would have a AR style 300 Blackout.
MR. FERNANDEZ: And what color was it?
ROGER DALE DAVIS JR.: Black.
MR. FERNANDEZ: Did it have a scope on it?
MR. FERNANDEZ: All right. Did Paul also favor a camo shotgun?
ROGER DALE DAVIS JR.: Yes, during turkey season.
MR. FERNANDEZ: The family owned -- as far as you knew, the family owned a lot of firearms. Is that correct?
MR. FERNANDEZ: Did you in your experience -- and did you spend a lot of time primarily down here at this dog pen area?
MR. FERNANDEZ: Twice a day every day.
MR. FERNANDEZ: Did you have occasion -- did they occasionally leave guns at this area?
MR. FERNANDEZ: All right. Where would you have found them? And when I say occasionally, what does that mean to you?
ROGER DALE DAVIS JR.: That would be -- especially when it was during hunting season, they would leave either on the golf cart or . Sometimes they would leave them in the truck. But most of the time it would be on the golf cart or the .
MR. FERNANDEZ: And how often was that if you're there every day?
ROGER DALE DAVIS JR.: Sometimes they could be once; sometimes they could be three or four times.
MR. FERNANDEZ: In a month or --
ROGER DALE DAVIS JR.: In a month. It just all depends on how hurried they got.
MR. FERNANDEZ: But that's during hunting season, right?
ROGER DALE DAVIS JR.: That's during the hunting season.
MR. FERNANDEZ: Okay, and did Alex carry a firearm?
ROGER DALE DAVIS JR.: I never seen him carry a firearm, but I know he carried a pistol in his vehicle.
MR. FERNANDEZ: Did you have a chance to listen to a kennel video in the meeting with law enforcement?
ROGER DALE DAVIS JR.: I did.
MR. FERNANDEZ: And did you identify the voices on that kennel video?
ROGER DALE DAVIS JR.: I did.
MR. FERNANDEZ: Whose voices did you hear?
ROGER DALE DAVIS JR.: Paul, Maggie's, and Alex's.
MR. FERNANDEZ: In all the time that you spent out there in the four years every day, twice a day, did you ever see a gun left in the feed room?
MR. FERNANDEZ: And you went in the feed room every day twice a day for four years?
MR. FERNANDEZ: Beg the Court's indulgence.
(Break in proceedings.)
MR. FERNANDEZ: And when you refer to Alex carrying a pistol in his car, is that because -- how did you know that?
ROGER DALE DAVIS JR.: One time I had to drive his vehicle over to the law firm. And then every once in a while, you, you would have to roll up the window or something or other if it would go to rain or something or other if they happened to not be home.
MR. FERNANDEZ: You mentioned the vehicles. Were the vehicles unlocked, all of the vehicles on the farm?
ROGER DALE DAVIS JR.: All of the vehicles on the farm, keys in them.
MR. FERNANDEZ: Keys in them. So, someone could just open the door and drive them?
ROGER DALE DAVIS JR.: Oh, yeah. If they wasn't in the switch, they would be in the center console.
MR. FERNANDEZ: And in this picture here that's still on, do you see the dog beds located in those pictures?
ROGER DALE DAVIS JR.: Yes. They on top of the dog kennel.
MR. FERNANDEZ: They haven't been put down.
ROGER DALE DAVIS JR.: Haven't been put down.
MR. FERNANDEZ: Nothing further. Thank you.
JUDGE NEWMAN: By the defense.
MR. GRIFFIN: May it please the Court?
CROSS-EXAMINATION
BY MR. GRIFFIN:
MR. GRIFFIN: Good afternoon, Dale.
ROGER DALE DAVIS JR.: Afternoon.
MR. GRIFFIN: I'm Jim Griffin. We've met a few times, haven't we?
ROGER DALE DAVIS JR.: Yes, sir.
MR. GRIFFIN: I want to start by asking you. How long did you work at Moselle for Alex Murdaugh?
ROGER DALE DAVIS JR.: About four years.
MR. GRIFFIN: And twice a day every day?
ROGER DALE DAVIS JR.: No. It started off just the weekends, and then it went full-time with him right as -- right before Ronnie quit.
MR. GRIFFIN: Okay, and that's Ronnie Freeman?
ROGER DALE DAVIS JR.: Whatever his last name is. I know Ronnie. That's all I can tell you.
MR. GRIFFIN: Yes, sir. And a couple of things. You've said you'd never seen guns left in the feed room, but you certainly have seen guns left down in the work shed and --
MR. GRIFFIN: -- and then the, what do you call it, and that's an off road vehicle that two people can sit beside each other?
MR. GRIFFIN: And then I guess they had a golf cart down there?
MR. GRIFFIN: And you have seen guns left in their vehicles.
MR. GRIFFIN: Unlocked, right?
ROGER DALE DAVIS JR.: Unlocked.
MR. GRIFFIN: And hog hunting, there's really no season for hog hunting, is there?
MR. GRIFFIN: And a couple of dogs in that kennel were used for hog hunting.
ROGER DALE DAVIS JR.: We had got -- Paul had got rid of the Bluetick, but he kept Armadillo, but he never really hunted him anymore after that last time he got hurt.
MR. GRIFFIN: Right. Now, this is -- when you're hog hunting with dogs, I don't think you can use a gun, can you?
ROGER DALE DAVIS JR.: Oh, yeah, you can use a gun.
MR. GRIFFIN: Oh, you can? Okay. The --
ROGER DALE DAVIS JR.: Unless you're man enough to go in there and catch him by the foot and bring him out.
MR. GRIFFIN: Well, somewhere along the way I heard you had to use a knife as opposed to a gun, but I don't -- the -- let me ask you the -- I'm going to pull up this video, Exhibit 297. It's the kennel video. And hang on, let me get around here. Dale, it should be on that screen there. And it's --
MR. GRIFFIN: And I'm going to tell you when to stop, Doug, but if you would go ahead and play it. Now, stop right there.
MR. GRIFFIN: Is that Rogan's dog?
MR. GRIFFIN: Dog named Cash, you think?
ROGER DALE DAVIS JR.: Yep, that was it.
MR. GRIFFIN: Cash? And Cash was -- I'm going to show you what you've got labeled on Exhibit 516. Cash would be in kennel number five. Is that right?
ROGER DALE DAVIS JR.: Should have been around --
MR. GRIFFIN: And that's a -- that's a few kennels up from the hose. Is that right?
MR. GRIFFIN: Okay. All right.
MR. GRIFFIN: We're going to run this continuing and I -- get ready to stop when I tell you, Doug.
(The video was played. Audio not transcribed.)
MR. GRIFFIN: All right, stop. Oh, wait, go back, go back, go back a few seconds. All right. Right there.
MR. GRIFFIN: What do you see over there in the top left on that picture, Dale?
ROGER DALE DAVIS JR.: Hose.
MR. GRIFFIN: Is that the hose?
ROGER DALE DAVIS JR.: Yeah.
MR. GRIFFIN: Now, that hose is on the ground, isn't it?
MR. GRIFFIN: It's not rolled up, is it?
MR. GRIFFIN: Okay, and there's water around there, isn't there?
MR. GRIFFIN: So, someone before this video was taken had taken the hose down that you meticulously wrapped it up. Is that right?
MR. GRIFFIN: Okay.
MR. GRIFFIN: You can take that down.
MR. GRIFFIN: Now, you say Mr. Alex was particular about how the hose should be wrapped. Is that right?
ROGER DALE DAVIS JR.: Well, not particularly him. He would like it to be wrapped, but he wouldn't very particular how as long as it was wrapped up out of his way.
MR. GRIFFIN: Okay.
ROGER DALE DAVIS JR.: But I was very particular how I wrapped it.
MR. GRIFFIN: You were very particular.
MR. GRIFFIN: How about Paul? Was he meticulous how he wrapped it?
MR. GRIFFIN: All right. Now, you mentioned that water would not normally accumulate up by Grady and --
ROGER DALE DAVIS JR.: And Bubba.
MR. GRIFFIN: -- Bubba's because that's where the sun would come in the evening.
ROGER DALE DAVIS JR.: Usually beats down. You watched it, because if you didn't be very particular --
MR. GRIFFIN: Right.
ROGER DALE DAVIS JR.: -- they didn't seal up underneath that door, so the inside of the jams started to rot. So, I tried to make sure, because if it was any kind of puddle or whatever, you would have to make sure it was gone.
MR. GRIFFIN: Right.
ROGER DALE DAVIS JR.: So, you would try not to make sure there was no puddle in there. So, puddling doesn't usually happen around the dog feed room. It would -- usually couple of posts back you would have under the hose, usually around about where Armadillo's pen was, and there was a few other little spots around the posts that normally would puddle.
MR. GRIFFIN: Now -- and you were meticulous about not letting water build up around the feed room door because of the rot.
ROGER DALE DAVIS JR.: Yeah.
MR. GRIFFIN: And, in fact, there was sealant in the feed room where you would have to routinely put by the door to keep it from rotting.
ROGER DALE DAVIS JR.: Alex done it the last time.
MR. GRIFFIN: But you had to periodically do that, right?
MR. GRIFFIN: And you do that because water builds up, right?
ROGER DALE DAVIS JR.: Well, because the water would splash. They didn't seal up underneath the door jam right, and it would just run up underneath the plate right there where the cement, it would run and drain off.
MR. GRIFFIN: Now, we would -- can we agree that Paul was not as meticulous as you were about spraying around the kennels?
MR. GRIFFIN: We can or cannot agree?
ROGER DALE DAVIS JR.: We can agree to that.
MR. GRIFFIN: And so -- and we saw the hose out, and you don't know what time that was, but I think the record reflects it was sometime 8:44 in the evening. I mean, that's about sundown, right, in June?
ROGER DALE DAVIS JR.: Oh, yeah.
MR. GRIFFIN: And so there wouldn't be a hot sun burning the water off if the hose had been used, you know, right around that period of time, would there?
MR. GRIFFIN: And if Paul had not been meticulous like you, it wouldn't be unusual to see water build up where you see it in the photo. Isn't that right?
MR. GRIFFIN: Okay, and sometimes the dogs would knock over the water bowl.
ROGER DALE DAVIS JR.: They would.
MR. GRIFFIN: And that would -- and I think maybe we can see in the photos that that would cause water to run off, too, as well, right?
ROGER DALE DAVIS JR.: Oh, yeah, it would run off.
MR. GRIFFIN: Okay. Now, Dale, what's lovey dovey see mean to you?
ROGER DALE DAVIS JR.: What does it mean to me?
MR. GRIFFIN: Well, you used the phrase lovey dovey about Alex and Maggie. What did that mean?
ROGER DALE DAVIS JR.: It means they loved each other.
MR. GRIFFIN: And in your presence you -- I mean, you described them as being lovey dovey, didn't you?
MR. GRIFFIN: And tell the jury what you meant by that.
ROGER DALE DAVIS JR.: Every time I always see them, they, you know -- I've never seen that man even raise his voice at his wife or kids, so -- or his wife. I've never seen him even -- none of them argue. But he always -- anything she wanted or the boys wanted, he would try to get it.
MR. GRIFFIN: And how do you -- what was your observations about his relationship with Paul?
ROGER DALE DAVIS JR.: They liked to hunt and fish together. I mean, they always -- they drank beer together.
MR. GRIFFIN: Okay, and his relationship with Buster?
ROGER DALE DAVIS JR.: I didn't see Buster as much, but it was always friendly. I mean, it's never --
MR. GRIFFIN: Sure.
ROGER DALE DAVIS JR.: -- seen any harmful way or anything with them.
MR. GRIFFIN: Do you remember, Dale, one time one of the hunting dogs got hung up in the one of the kennels --
MR. GRIFFIN: -- choking to death?
MR. GRIFFIN: And that dog was badly injured, wasn't he?
ROGER DALE DAVIS JR.: It was. It didn't survive.
MR. GRIFFIN: And the decision was made, it was mercy to put the dog down, wasn't it?
MR. GRIFFIN: And Mr. Alex couldn't shoot that dog and he asked you to do it, didn't he?
MR. GRIFFIN: And did you do that?
MR. GRIFFIN: Now, on June 7th, the night of June the 7th, you got off work, I think you said, 4:30?
ROGER DALE DAVIS JR.: 4:30.
MR. GRIFFIN: And do you remember what you did? Did you go home?
ROGER DALE DAVIS JR.: I went straight to the house.
MR. GRIFFIN: And did you stay at the house all night?
ROGER DALE DAVIS JR.: I sure did.
MR. GRIFFIN: Did you stay inside?
ROGER DALE DAVIS JR.: I did.
MR. GRIFFIN: And you lived --
ROGER DALE DAVIS JR.: A mile and a half.
MR. GRIFFIN: -- a mile and a half. Driven a lawnmower down that road, I believe, the last time I saw you.
ROGER DALE DAVIS JR.: I did.
MR. GRIFFIN: Did you hear any gunshots that night while you were in your house?
ROGER DALE DAVIS JR.: No, I did not.
MR. GRIFFIN: You mentioned Paul liked to hunt with a Blackout, 300 Blackout, I guess?
ROGER DALE DAVIS JR.: He did, hog hunt.
MR. GRIFFIN: Yeah. Before the murders, when is the last time you saw that gun? Do you remember?
ROGER DALE DAVIS JR.: I cannot remember the exact, but it was quite a few months. He had said something about going hog hunting and he had it in his truck.
MR. GRIFFIN: Right.
ROGER DALE DAVIS JR.: But it's been -- it was a couple of months I know, at least five or six months.
MR. GRIFFIN: All right. What -- two last points. Bubba has been getting a bad name. Bubba was a little stubborn dog?
ROGER DALE DAVIS JR.: Stubborn? No, he was just rambunctious.
MR. GRIFFIN: Right, but would he listen to you?
ROGER DALE DAVIS JR.: Somewhat.
MR. GRIFFIN: Would he listen to Alex?
ROGER DALE DAVIS JR.: He would.
MR. GRIFFIN: And in that feed room, did you keep shock collars back there for the hunting dogs and stuff?
ROGER DALE DAVIS JR.: We did.
MR. GRIFFIN: All right. What, what else was kept in that feed room besides feed?
ROGER DALE DAVIS JR.: Shock collars, feed, chicken feed, the GPS tracking collar.
MR. GRIFFIN: Was there some medicine if you needed it?
ROGER DALE DAVIS JR.: There was medicine. There was all kinds of stuff in it.
MR. GRIFFIN: So, if you needed to put something on a dog's skin for rash or something that -- had that in the feed room?
ROGER DALE DAVIS JR.: Had that.
MR. GRIFFIN: And now, Ms. Maggie would go down there, and you said she would take a Mercedes sometimes, but she would ride her bike down there, too, wouldn't she?
ROGER DALE DAVIS JR.: Bicycle, golf cart, and then sometimes she would walk.
MR. GRIFFIN: She would walk. And she liked to get the dogs out, Grady, and Bubba. And Maggie, I think, was Mr. Randolph's dog, wasn't she?
ROGER DALE DAVIS JR.: Yes, sir.
MR. GRIFFIN: And he -- and she liked to run the dogs in the golf cart sometimes, run behind them?
ROGER DALE DAVIS JR.: She would. Sometimes she would just would get out there and walk with them.
MR. GRIFFIN: All right. Now, those were pet dogs but they stayed at the kennels, right?
ROGER DALE DAVIS JR.: Most of the time they did.
MR. GRIFFIN: And they didn't let those dogs in the house because Buster had eczema. Were you aware of that?
ROGER DALE DAVIS JR.: I wasn't aware of that. I know they would take them up to the house. Now whether they went in, I didn't know.
MR. GRIFFIN: You didn't know whether they went in or went out? You did not?
ROGER DALE DAVIS JR.: I know they stayed outside around the house.
MR. GRIFFIN: And you know they had an electronic fence?
ROGER DALE DAVIS JR.: They did.
MR. GRIFFIN: And sometimes it worked and sometimes it didn't?
MR. GRIFFIN: Okay, but it wasn't unusual for Bubba, Grady, and Maggie to be down at the kennels --
MR. GRIFFIN: -- at night, right?
ROGER DALE DAVIS JR.: It wouldn't.
MR. GRIFFIN: Okay, and they liked to take -- chase the chickens. Was Bubba the one?
ROGER DALE DAVIS JR.: They never would chase chickens until Alex had got a rooster that would roost right over there. If you let that rooster out, that joker would be out there and would taunt them jokers, and they got to where they would -- got to where they would chase the chickens.
MR. GRIFFIN: Because the --
ROGER DALE DAVIS JR.: That rooster --
MR. GRIFFIN: -- rooster would be taunting the dogs?
ROGER DALE DAVIS JR.: Yes. He would aggravate the dogs to death.
MR. GRIFFIN: All right.
MR. GRIFFIN: That's all of the questions I have, Dale. Thank you so much.
JUDGE NEWMAN: You may redirect.
REDIRECT EXAMINATION
BY MR. FERNANDEZ:
MR. FERNANDEZ: Just curious, Dale, what happened to that rooster?
ROGER DALE DAVIS JR.: I can't remember if Grady got him or Bubba got him.
MR. FERNANDEZ: So, the rooster got his apparently?
ROGER DALE DAVIS JR.: One of the dogs ended up getting the rooster.
MR. FERNANDEZ: All right. We heard a little bit about -- well, first of all, did Alex do a lot of hunting?
ROGER DALE DAVIS JR.: I don't know how much hunting he done, but I know he done hunted.
MR. FERNANDEZ: And hunting involved killing animals?
MR. FERNANDEZ: So as far as you knew, he was a hunter?
MR. FERNANDEZ: The slope on the concrete -- I'm sorry, the concrete out there on the dog kennels, did it have a slope to it?
MR. FERNANDEZ: And that would be for what reason?
ROGER DALE DAVIS JR.: To run the water off.
MR. FERNANDEZ: So, water would naturally drain out there even if it wasn't sunny?
ROGER DALE DAVIS JR.: It would.
MR. FERNANDEZ: And I think you mentioned and talked at length about the feed room and how there was issues there, but were the issues caused -- the rotting wood, was that caused because it was actually draining?
ROGER DALE DAVIS JR.: When they done that room, they didn't -- like I told that gentleman over there, they didn't seal that bottom plate like it should have been, and it would allow water -- when you sprayed the concrete off, that water kept just getting -- slowly getting underneath the concrete until it started rotting out around the door jams and stuff.
MR. FERNANDEZ: If Maggie was down there at the kennels, would she put the dog beds down for the dogs?
ROGER DALE DAVIS JR.: She would have.
MR. FERNANDEZ: If the kennel lights and the hangar lights and the underneath lights are on, is it fairly well lit out there?
ROGER DALE DAVIS JR.: It is.
MR. FERNANDEZ: You mentioned -- what is your bedtime? You said you rise early. What's your bed time?
ROGER DALE DAVIS JR.: My bedtime, it never -- it all depends.
MR. FERNANDEZ: Okay. What time are you usually in bed?
ROGER DALE DAVIS JR.: That's a good question. I can tell you my routine.
MR. FERNANDEZ: All right. Tell me your routine.
ROGER DALE DAVIS JR.: Usually around 4:00 or 5:00 I go get a shower, and I'm in my recliner usually the rest of the day.
MR. FERNANDEZ: Okay. So, you're not in bed, you're in that recliner. And after you shower, you're in that recliner?
ROGER DALE DAVIS JR.: That's it.
MR. FERNANDEZ: And the day is done.
ROGER DALE DAVIS JR.: Done.
MR. FERNANDEZ: And June 7th, that was that Monday, you were -- were you done that night at whatever time you took a shower, 4:00 or 5:00?
ROGER DALE DAVIS JR.: I was done at 4:30. 5:00, I had done had my shower and I was in my recliner.
MR. FERNANDEZ: And you were with your wife?
MR. FERNANDEZ: Last question. When you were out there at 5:00 at the kennels at Moselle, were there any firearms anywhere on that property?
ROGER DALE DAVIS JR.: That night? That particular day?
MR. FERNANDEZ: That particular day.
ROGER DALE DAVIS JR.: I did not see none.
MR. FERNANDEZ: Thank you.
JUDGE NEWMAN: Anything further?
MR. GRIFFIN: No, Your Honor.
JUDGE NEWMAN: Thank you, sir.
(The witness exited the stand.)
JUDGE NEWMAN: Call your next witness.