The State Of Mississippi V. Dixon - Madison County School District

Transcription

The State ofMississippiv.DixonGermantown Middle School8th Grade Anti-Bullying Mock Trail2018 1st Nine-Weeks Cross-Curricular UnitBased on Illinois State Bar Association Mock Trial

8th Grade Cross-Curricular Unit Plan:Mock Trial Preparation Schedule 2018-Social Studies : September 17th – 21st-Students read through court documents, annotate, discuss, etc.-Students write “cross-examination” questions and assess reliability of witnesses-Science: September 24th – October 5th-Students apply scientific method to evidence (DNA, broken arm x-ray, etc.)-STEM: September 24th – September 28th-Students write questions for an anonymous, online survey about bullying.-STEM teachers use these questions to create an online survey that includes data points such asgender, race, school activities, etc.-This will be in conjunction with the STEM anti-cyber bullying unit.-Math: October 1st – October 5th-Students will examine, interpret, justify, etc. data collected from online survey.-This information will be used as evidence by both sides during mock trial.-ELA: October 15th – October 29th-Last names A-L PROSECUTION; last names M-Z DEFENSE)*Subject to change if an ELA class has an uneven split-Students will write arguments for mock trial-Student will listen to guest speakers in preparation for oral closing argument-Mock Trial: Tuesday, October 30th-Jurors will volunteer using an online signup site (we will need multiple jurors for all 14 ELAsections).-Jurors will listen to closing arguments and deliberate during a 94-minute block.2

TABLE OF CONTENTSCASE DESCRIPTION3INDICTMENT, CHARGES5JURY INSTRUCTIONS & STATUTES6PROSECUTION WITNESS TESTIMONY:CRISS LYMAN10DR. TERRY POTTER14LEWIS JOHNSON17DEFENSE WITNESS TESTIMONY:TAYLOR DIXON20RILEY DWIGHT23DR. BLAIR GRAHAM26EXHIBITS IN EVIDENCE:A. NOTE RECEIVED BY CRISS LYMAN28B. EXCERPTS FROM CRISS LYMAN’S DIARY29C. GSD ANTI-BULLYING POSTER31D. GSD HANDBOOK POLICY32E. X-RAY OF CRISS LYMAN’S BROKEN ARM33F. INSTAGRAM POST ABOUT CRISS LYMAN343

IN THE CIRCUIT COURT OF STRAWBERRY COUNTYSTATE OF MISSISSIPPITHE STATE OF MISSISSIPPI,Prosecution))vs.) Case No. 2018 424)Taylor Dixon,)Defendant))This is a fictional case. None of the characters in this mock trial are real. Any similarities to actualevents are unintentional.Witnesses for the Prosecution:(1) Criss LymanCriss Lyman, alleged victim, will testify that she has been a victim ofbullying since entering the school district as a transfer student duringsixth grade and continuing through her eighth-grade year.(2) Dr. Terry PotterDr. Terry Potter, an expert on childhood psychology who has experiencein treating those who have been bullied as well as bullies themselves, willtestify about incidences discussed in various sessions with Criss Lyman,including the journal entries that are exhibited as evidence.(3) Lewis “Steve Man” JohnsonLewis “Steve Man” Johnson, school custodian, will testify regarding thecourtyard incident where Criss Lyman was allegedly bullied by TaylorDixon and others regarding her shoes. Johnson will also testify that hehas overheard plans stated by Taylor Dixon to bully Criss Lyman outsideof school by means of social media.Witnesses for the Defense:(1) Taylor DixonTaylor Dixon, defendant, will testify that most of what was done to CrissLyman was good natured and that Criss Lyman is afraid of her ownshadow and is paranoid. Dixon claims that what happened on January26 was just an unfortunate accident.(2) Riley DwightRiley Dwight, cousin of Taylor Dixon, will add that Taylor would neverintentionally hurt anyone. Riley will state that Taylor likes to have thingsher own way and is sometimes ill-tempered, but Riley insists that any4

teasing that may have occurred was good natured and not meant toharm.(3) Dr. Blair Graham, school social workerDr. Blair Graham, school social worker and clinical psychologist, willtestify that Taylor has been a good student with no complaints againsther on the school records. Dr. Graham will testify that Criss Lyman neversought school counseling assistance, never reported any instances ofbullying, and that the school has a policy against bullying that requiresvictims to report problems within 5 days of the incident.Stipulations:1. All affidavits are accurate and may not be disputed at trial.2. Taylor Dixon was 14 years old when she broke Criss Lyman’s arm and isbeing tried to determine whether she will be required to go to a juveniledetention center and/or the Academic Options Center for the remainder of theschool year and possibly one semester of the next school year.5

IN THE CIRCUIT COURT OF STRAWBERRY COUNTYSTATE OF MISSISSIPPITHE STATE OF MISSISSIPPI,Prosecutionvs.Taylor Dixon,Defendant)Case No. 2018 424)))INDICTMENT))The Grand Jury, in and for the County of Strawberry, State of Mississippi, upon theiroath and in the name and by the authority of the State of Mississippi, does herebycharge the following offenses under the Criminal Code of the State of Mississippi:That on January 26, 2018 at and within the County of Strawberry in the State ofMississippi, defendant, Taylor Dixon committed the crime ofCount IHARASSMENTIn that the defendant, Taylor Dixon, did, on several instances, willfully, maliciously,and repeatedly follow or harass or threaten Criss Lyman with the intent to place in herin reasonable fear of death or bodily injury.Count IIRECKLESS CONDUCTIn that the defendant, Taylor Dixon, did, on January 26, 2018, recklessly perform anact which caused bodily harm to Criss Lyman.Count IIIBATTERYIn that the defendant, Taylor Dixon, did, on January 26, 2018, intentionally orknowingly cause bodily harm to Criss Lyman, contrary to the Law and againstthe peace and dignity of the State of Mississippi.Count IVAGGRAVATED BATTERYIn that the defendant, Taylor Dixon, did, on January 26, 2018, commit aggravatedbattery, intentionally or knowingly causing great bodily harm, or permanent disabilityof disfigurement, to Criss Lyman on or about a public way, public property, or publicplace of accommodation or amusement.Dated this 14th day of March, 2018A TRUE BILL:State’s AttorneyForeperson of the Grand Jury6

JURY INSTRUCTIONS AND STATUTESMississippi Pattern Jury Instructions – CriminalHarassmentDefinition of Harassment:A person commits the offense of harassment when he/she willfully, maliciously, andrepeatedly follows or threatens another person with the intent to place that person inreasonable fear of death or bodily injury.Issue in HarassmentTo sustain a charge of harassment, the State must prove the following proposition:That the defendant purposefully committed a pattern of actions that created anenvironment of emotional and physical fear to another person.If you find from your consideration of all the evidence that this proposition hasbeen proved beyond a reasonable doubt, you should find the defendant guilty.If you find from your consideration of all the evidence that this proposition hasnot been proved beyond a reasonable doubt, you should find the defendant notguilty.Reckless Conduct:Definition of Reckless Conduct:A person commits the offense of reckless conduct when he recklessly performsany act which causes bodily harm to another person.A person (is reckless) (acts recklessly) when he consciously disregards asubstantial and unjustifiable risk that circumstances exist or that aresult will follow, and such disregard constitutes a gross deprivationfrom the standard of care which a reasonable person would exercise inthe situation.Issue in Reckless ConductTo sustain a charge of reckless conduct, the State must prove the followingproposition: That the defendant recklessly performed an act which causedbodily harm to Criss Lyman.If you find from your consideration of all the evidence that this proposition hasbeen proved beyond a reasonable doubt, you should find the defendant guilty.If you find from your consideration of all the evidence that this proposition hasnot been proved beyond a reasonable doubt, you should find the defendant notguilty.7

Battery:Definition of BatteryA person commits the offense of battery when he intentionally, or knowinglyand without legal justification, and by any means, causes bodily harm toanother person.Issue in BatteryTo sustain the charge of battery, the State must prove the followingproposition: That the defendant knowingly and/or intentionally caused bodilyharm to Criss Lyman.If you find from your consideration of all the evidence that this proposition hasbeen proved beyond a reasonable doubt, you should find the defendant guilty.If you find from your consideration of all the evidence that this proposition hasnot been proved beyond a reasonable doubt, you should find the defendant notguilty.Aggravated Battery:Definition of Aggravated Battery--Great Bodily HarmA person commits the offense of aggravated battery when he intentionally,knowingly and without legal justification, and by any means causes greatbodily harm or permanent disability to another person on or about a publicway, public property, or public place of accommodation or amusement.Issue in Aggravated Battery--Great Bodily HarmTo sustain the charge of aggravated battery, the State must prove the followingproposition: That the defendant intentionally and knowingly caused greatbodily harm or permanent disability to a person in a public place.Note: some of the language may differ (for mock trial purposes) from the actualMississippi Pattern Jury Instructions.Mississippi Compiled Statutes/Criminal OffensesCriminal Code of 1967Harassment.(a) “bullying or harassing behavior” is any pattern of gestures or written, electronic orverbal communications, or any physical act or any threatening communication, or anyact reasonably perceived as being motivated by any actual or perceived differentiatingcharacteristic (1) Places another person in actual and reasonable fear of harm to hisor her person or damage to his or her property; or (2) Creates or is certain to create ahostile environment by substantially interfering with or impairing another person’sperformance, opportunities or benefits. For purposes of this section, “hostileenvironment” means that the victim subjectively views the conduct as bullying orharassing behavior and the conduct is objectively severe or pervasive enough that areasonable person would agree that it is bullying or harassing behavior.(b) Sentence. Harassment is a Class A misdemeanor.8

Reckless conduct.(a) A person who causes bodily harm to or endangers the bodily safety of anindividual by any means, commits reckless conduct if he performs recklesslythe acts which cause the harm or endanger safety, whether they otherwise arelawful or unlawful.(b) Sentence. Reckless conduct is a Class A misdemeanor.Battery.(a) A person commits battery if he intentionally or knowingly without legaljustification and by any means, (1) causes bodily harm to an individual or (2)makes physical contact of an insulting or provoking nature with an individual.(b) Sentence. Battery is a Class A misdemeanor.Aggravated Battery.(a) A person who, in committing a battery, intentionally or knowingly causesgreat bodily harm, or permanent disability or disfigurement on or about apublic way, public property, or public place of accommodation or amusementcommits aggravated battery.(b) Sentence. Aggravated battery is a Class 3 felony.9

Criss Lyman - Prosecution Witness1. My name is Criss Lyman and I am a junior at Germanville MiddleSchool. I’ve been bullied for years. It all ended when Taylor broke my arm onTuesday, January 26th. It happened outside in one of the school’s courtyardareas in front of lots of people. It took getting my arm broken for things tofinally come to a head, and now I am worried that this whole ordeal willbackfire, that no one will believe what I’ve been going through, and that I’llhave to go back to school and face Taylor Dixon again if this court doesn’t dosomething to straighten things out.2. I understand horsing around. I understand teasing and good-naturedname-calling, but what I have experienced for the past couple of years goesbeyond anything that could be considered friendly teasing or good naturedname-calling. Taylor Dixon consistently, went out of her way to make me feelinsecure, intimidated, excluded, and victimized.3. It all started when I transferred to the Germanville school district as a sixthgrade student. My parents are in the military. We travel a lot and have lived inabout five different places during my lifetime. Some of those places have beengreat; others have been less exciting. No matter where my family has beenlocated, I’ve gone to either military base schools or local schools and have hadlittle or no trouble fitting in. I have quite a few friends from other states andcountries whom I e-mail, write to, and visit, but no one wants to hang aroundwith me here, and that’s all because of Taylor Dixon. I usually make friendseasily -- or I did until I came to this district. Once I became Taylor Dixon’starget for bullying, I found it much harder to make or keep friends. Everyonehas been afraid to be around me. During this school year and last, my parentshave been deployed to Iraq. I’ve been living with my grandmother, who hasbeen wonderful through all of this.4. I am a typical middle schooler. I am a good student, but not exceptional. Theonly things that I can think of that make me at all different from the studentshere is that I have moved frequently, and I am not extremely wealthy. I don’talways follow the latest clothing trends. I’m still considered an outsider, eventhough we’ve lived in this area for some years now. I didn’t go to elementaryschool with all these kids, so I guess I don’t have much of a shared history. Butthat didn’t seem to hurt me in the other places we’ve lived.5. Looking back, there were some things that may have made me seemdifferent. I realized quite young that spending quality time with my parentswas important to me. They are away so often that, when we are all together, it’sspecial. So, they would often walk me to school or drive me to school and we’dsit and talk before I’d go into the school buildings. I think other kids may havefound this odd. And, once in a while, I’d wear something of my Mom or Dad’s toschool, like one of their military shirts or one of their hats. This may have setme apart. I think I’m the only military kid at this school right now. I also look10

different than other kids because I have hair dyed pink in honor of mygrandmother’s battle with breast cancer.6. Since seventh grade, I’ve been in various classrooms with Taylor Dixon andRiley Dwight. Taylor has always had something against me. Taylor seemed tohave taken an instant disliking to me. I remember the first day I wasintroduced in class: Taylor laughed out loud at my name. Since then, I’ve beenplagued by name-calling, which didn’t bother me when that’s all it was, but ifyou add in all the other things that Taylor has done or instigated, it’s prettybruising.7. My family name is Lyman. I’ve been called all kinds of namesthroughout the years based on the fact that some of the kids think I’m tooclose to my parents. Nothing really awful, but like I said, it all adds up. Thelist of things Taylor, specifically, has done and said is a long one.8. It started, as I said, in sixth grade. Taylor called me names, pushed me inhallways, pulled my hair daily, locked me in the janitor’s closet, and bloodiedmy nose countless times. School trips were also a nightmare on the bus. I hadto sit directly behind the driver for protection and had things thrown at meconstantly. I had books stolen and homework ruined by Taylor and Taylor’scousin, Riley, who never really joined in but was always there watching andlaughing at Taylor’s meanness. There was no escape. As a student, it wasn’tlike there was an option to leave. We weren’t ever allowed to leave the gym,lunchroom, hallways, locker rooms or whatever. I felt trapped and afraid.9. During this school year and last, both my parents have been deployed.I’ve been living with my grandmother, which has been good for her, too, as sheneeds my support during her treatment for breast cancer. We’ve always beenclose as she’s taken care of me often when my parents have been out of thecountry. I told my grandmother about the problems I was having this schoolyear. Naturally, she was concerned and offered to intervene. My parents offeredto transfer me to a private school in the area, but I know that money would bean issue, so I declined. I kept thinking it would end.that Taylor would growout of it. I never made a formal report against Taylor. I sort of thought it wouldmake things worse for me. Taylor as an angry bully was something I didn’twant to think about. My grandmother has been wonderfully supportive. Shehelps keep me sane. I don’t want my parents to know how bad things havebeen this year. They have enough to worry about where they are.10. There is a long list of humiliating and hurtful things that were done tome as the target of Taylor’s constant bullying. The hair pulling, name-calling,bloody noses, arm twisting, even being locked in the janitor’s closet, so I wouldbe late to class. I had insulting, humiliating remarks and pictures posted aboutme all over Instagram and Snapchat. These weren’t once or twice occurrences.They happened daily during some weeks. Sometimes notes would be stuffedinto my backpack. One recent note said something like “After school. You andme. Let’s get bloody.” I thought I’d faint when I saw that one. I finally turnedthat one over to one of our school counselors when all this came to a head.11

Unfortunately, the note was created using letters that had been cut out of amagazine instead of being handwritten. It looked like maybe they cutthemselves with the scissors while they did it because the note had actualblood on it. Or worse, maybe they really meant there to be blood 11. At the beginning of eighth grade, I was able to get an Instagram accountand Snapchat on my phone. It wasn’t long after that when Taylor beganposting pictures of me making fun of how I dress and writing very hurtfulremarks about how I probably wasn’t even sure what bathroom to use while atschool.12. After Taylor’s name had been given to the police, I started being followedhome by Taylor and Riley, who were sometimes joined by others in their groupof friends. None of those friends seemed willing to stop Taylor fromharassing me. They all seemed a bit afraid of Taylor and thought better ofcrossing her. Then some “Here’s Lyman” signs with alien bathroom signsstarted showing up on walls in the hallways. They were taken down prettyquickly by the school staff, but they still hurt.13. There was also an incident the week we returned from Christmas breakwhere Taylor Dixon, Riley Dwight, and a few other friends of theirs surroundedme in courtyard after lunch and began to make fun of the knock-off Yeezys thatmy parents got me for Christmas. Let’s be honest, not many parents can affordto buy their children shoes that cost hundreds of dollars. Taylor evenconvinced one of them to pour out the rest of their juice on my shoes before theteachers realized there was a problem.14. I began to develop some awful stomach problems as I was trying todecide what to do about the bullying. I knew something had to be done. Itwasn’t going to stop on its own. I had trouble sleeping. My Grandmother tookme to doctors and I was diagnosed with anxiety issues. My self-esteemhad suffered, and I questioned whatever I was doing. I became timid and afraidto go anywhere without someone I trusted being with me. I know in my heartthat I have a right to an education and the right to feel safe at school, but Idon’t ever feel safe. I’m pretty much always afraid. Taylor has done that to me.15. I started to obsess about how to end the pattern of Taylor’s violence towardme. The only options I could think of were pretty much unacceptable. I don’twant to harm others the way I’ve been harmed. I began researching bullyingon the Internet and started trying some of the coping skills. I found that Iwasn’t all that good at it because nothing seemed to get better. I felt like I hadno way to control or affect what was happening to me. So I’m relying on thelegal system to force Taylor to stop.16. That’s when the worst thing happened.but maybe it’s the best thing.Taylor grabbed me one day outside in the courtyard at school so hard that shebroke my arm. It was right after third lunch. It was right around one p.m. or alittle after. I’d just thrown away my trash and helped clean tables. I rememberfeeling my arm being grabbed from behind, and I turned and saw it was Taylor.12

I had a moment of absolute terror and I tried to get away. That’s when I heardmy arm break. I think that changed things forever. Taylor actually lookedworried when she saw the way my arm was bent. And, there were witnesses. Ithappened right outside in the courtyard. Our school custodian, Mr. Johnsonsaw the entire thing. Finally, I was able to press formal charges against Taylor.17. In a perfect world, the courts would restrain Taylor from getting near me,but I’d also like the courts to demand that Taylor undergo some therapy toaddress the aggressiveness and downright violent nature she manifests. Anapology would be nice too.18. I am pretty sure I’m Taylor’s only target. If I am, I’m glad. At least othersare spared this agony. If I’m not the only target, then I’m also glad thatsomething has finally happened to stop all of this. Maybe other lives will beeasier if Taylor can be stopped. I’ve heard that some people in situations likemine are suing and asking for damages and restitution for the pain andsuffering like I’ve endured. I’m not going to do that. I just want the violence tostop.19. One of the hardest things about being a victim has been talking about it.Talking about it makes it so real. And it makes you re-live every embarrassing,hurtful situation. And you’re afraid to tattle. really afraid. Tattling could soeasily backfire and make things worse. And the last thing I ever wanted wasfor things to be worse.20. I heard that Riley is saying that I may have hurt my arm in gym classearlier in the day during dodgeball. That’s just plain dumb. I did fall, but Irolled onto my other arm, not the arm that Taylor grabbed.13

Dr. Terry Potter, Psychologist – Prosecution Witness1. My name is Terry Potter; I hold a Ph.D. in Psychology and am apracticing psychologist. I graduated from the University of Mississippi atOxford, where I also received my Master’s degree and my Ph.D. I conducted myresidency in Jackson at Blair E. Batson Children’s Hospital, and have practicedin this area for the past ten years. I’ve been in practice for a total of twelveyears and have extensive experience with adolescents and teens.2. My Master’s thesis focused on the long-term effects of bullying, both on theperson who is bullied and on the person who is doing the bullying. It was afascinating research project and in my practice I have found that theconclusions I reached over fifteen years ago were frequently stable. Bulliesroutinely bully well into adulthood unless there is some sort of intervention.Conversely, those who fall victim to bullying carry the scars their entire lives.3. In October of 2017, after the cyberbullying incidents targeting Criss, I wascontacted by Criss Lyman’s grandmother who indicated she was concernedabout Criss. Mrs. Lyman is caring for Criss while her parents are servingin Iraq. This, no doubt, adds to Criss’s stress.4. We first met as a family and then I met privately with Criss. While Criss’sgrandmother was present, Criss was hesitant to discuss the full extent of whatwas happening at school; however, after some weeks of regular sessions, Crissopened up and told me about the bullying that had been taking place since shetransferred to Germanville in the sixth grade. I believe Criss had only been inthe school a few weeks when Taylor began to taunt Criss. Following myprofessional protocol and moral obligations, I encouraged Criss to report theseinstances to her school at once.5. Criss showed me pages from the journal she had been keeping forsome time. Criss used writing as a form of release. The entries were quiterevealing. Criss has an adult level comprehension of the effects of bullying andI am quite proud of the way Criss has handled the situation. There are manywho would have completely buckled under the stress of such negativeattention, and there are those who would have sought to retaliate. Criss hasdone neither. Criss has avoided confrontation at the expense of her sociallife and has, until very recently, never considered lashing out.6. Criss’s journal also reflects an understandable level of concern over thesafety of her parents who are out of the country serving in the military. Ido not believe that Criss’s concern is extreme, out of control, or unnatural inany way. Nothing in the journal entries regarding her concern overher parents, or expressed during our discussions, would lead me to theconclusion that Criss is manufacturing these bullying accusations to try tobring her parents’ home.14

7. Criss has an uncanny ability to understand the way a bully works andrealized early on that confrontation can serve to elevate the severity of theactions taken against the person being bullied. Any aggravation can set thebully off and exacerbate the problem. Criss worked to avoid confrontation,altering schedules, walking different routes to and from class, etc. This was avery adult response to what she was going through.8. Most bullying behavior is done so as not to be detected by authorityfigures. Thus, the fact that Taylor had a clean disciplinary record is notsurprising. The fact that Taylor is usually surrounded by a friend or friendswho outwardly support the actions taken is also part of a profile for bullying.The bully likes an audience. They like to exhibit the power they have overothers. It’s important to remember that the bully’s very presence can be aperceived threat, or a sort of weapon, to the person being bullied.9. Based on what I have heard from Criss, Taylor seems to manifest a numberof attributes common to bullies. Taylor is action-oriented. That means Taylorlikes to physically pick on her target by pulling hair, pushing, damagingproperty and the like. Taylor also has verbal bullying tendencies, as many ofthe attacks against Criss were oral. The name-calling and teasing areindications that Taylor is a verbal bully. And Taylor also seems to be what iscalled a relational bully, in that Taylor likes to have witnesses, or an audience,to see how powerful Taylor can be when teasing and bullying. Taylor haseffectively cut Criss off from others in the class because anyone affiliated withCriss could become another target for Taylor. Kids understand this at the mostprimal level.10. While I have not interviewed Taylor and have had no direct contact withher, I trust Criss and Criss’s Grandmother. The daily journal that Crisskeeps is quite revealing and has helped greatly in keeping Criss grounded. Fewchildren lie about being bullied. Criss’s experiences are very real and havedone great harm to her social skills and personal behaviors. Criss has beendenied access to friendships during her school years because others wereafraid to become targets through affiliation. This is so unfortunate, but couldbe rectified if Taylor Dixon gets the help she so desperately needs and is able tochange.11. In one of our first sessions, I mentioned to Criss that there are somecoping skills for dealing with bullies, and she wasn’t surprised. Criss had beendoing some on-line research and had tried many of the techniques I was goingto suggest, including avoiding Taylor as much as possible, trying to always benear other people, etc. Criss was well aware that she needed to change frombeing vulnerable, or appearing vulnerable, to exhibiting some backbone.However, Criss admitted that this all seemed outside the realm of possibility.12. Following the incident in the courtyard after lunch, Criss’s grandmothercalled me, and I rushed straight to the hospital. We had a session at thehospital room immediately after Criss’s arm was set by the doctor. Criss washighly agitated and fearful. Even in the safest of settings, a private hospital15

area with doctors, nurses, and Mrs. Lyman present, Criss was still afraid. Aftersome dialogue, Criss finally said she was afraid that it would seem like it wasCriss’s own fault that the arm was broken. Criss was afraid that Taylor wouldnot be blamed. That’s when I called Mr. Johnson, the school custodian, andasked if it would be possible for him to come to the hospital to meet with Criss.After all, he was the only adult witness.13. Mr. Johnson came that same evening and met with Criss, Criss’sgrandmother, and me. Mr. Johnson assured Criss that, besides himself, anumber of students also had seen what had happened and everyone believedthat Taylor’s grip on Criss and the awkward way that Taylor twisted Crissaround was what broke the arm, not Criss trying to get away. And, even ifCriss’s reaction to being grabbed had aggravated the matter and contributed tothe break, it didn’t matter. Taylor instigated the action and Taylor was at fault.14. Mr. Johnson told Criss that Taylor had been arrested and was beingcharged with four counts. Mr. Johnson explained what would probably happenbased on what he heard the sheriff’s deputy tell Taylor that Criss may have totestify in court. Criss gave a statement at that time, explaining the bullyingthat had been going on for years, ending with the breaking of the arm at theschool.15. We are now working to see that Criss doesn’t carry the scars from thisbullying into her adult life. None of us want to see Criss become a timid,retiring adult, afraid to go into new situations. Criss especially wants to be freeof the terror that’s been overshadowing her life for so many years. And,much to Criss’s credit, she also

Lewis "Steve Man" Johnson, school custodian, will testify regarding the courtyard incident where Criss Lyman was allegedly bullied by Taylor Dixon and others regarding her shoes. Johnson will also testify that he has overheard plans stated by Taylor Dixon to bully Criss Lyman outside of school by means of social media. Witnesses for the .