Whereas, complaint upon the oath has been made by B. F. Pruitt that in Chesterfield County in the State aforesaid, on the 21st day of September 1941, one Wade A. Outlaw did commit the offense of reckless homicide, by operating an automobile in a carless and reckless manner, thereby causing said car to strike an automobile being driven by one James Allred, wrecking the Allred car and killing the said James Allred. That the said Wade A. Outlaw was operating the said automobile without a drivers license and while under the influence of intoxicants.
FIRST WITNESS, J. W. KEISLER, DULY SWORN, TESTIFIED AS FOLLOWS: I am the owner of the car that was in collision with J. W. Allred Sr. Wade Outlaw was driving my car. I was drunk when I left Columbia, I dint remember when Mr. Outlaw took the wheel. Last been I drank was in Columbia, I think Mr. Outlaw drank beer with me. It doesn't take much beer to make be drink; I don't know what time we left Columbia. We drank beer there, we must have left Columbia about dark. We drank beer after the dance . . . I don't remember anything before accident, I remember after the wreck. . .
FIFTH WITNESS, WADEA. OUTLAW, DULY SWORN, TESTIFIED AS FOLLOWS: I was driving car, Chevrolet this A. M. that had collision with Allred car. I didn't have a drivers license. I was practically stopped when cars hit, I can't say why car went on. I was not drunk. I drank a bottle of beer after bring man to doctor. Which was first bottle I drank since yesterday at 3:00P. M. I didn't drink beer with Keisler at the blue Gable in Colombia. . . I was going down grade. I saw car a good piece down road, I slowed down. I figured I was far enough on my side of the road. I don't know state law concerning my driver's license. I know that you are supposed to have a driver's license. He asked me to drive car, I heard doctor say that the man was going to die. I drank after brining man to doctor, one bottle of beer. I didn't drink beer with other boys. I told officers I was going to drink a bottle of beer. Sailor and I went to caf_. I saw car some distance off. Both lights of Allreds car were burning. Lights didn't blind me. I thought I was far enough over to miss car. I am not an experienced driver. . . Mr. Keisleer was under influence of alcohol. He drank beer. He drove good all the way until he woke me up and asked me to drive. He drove good. I heard him testify that he was drunk and didn't remember anything about driving. I shouldn't have driven for I had no driver's license.