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IN THE SUPERIOR COURT OF THE STATE OF NEW YORK

The State vs. Damon “Marionette” Locke

October 12, 2009

Judge: Honorable Florence Weber presiding

Defendant: Damon Locke

Defense Counsel: Mark Carlson, Esq.

Prosecution: Assistant District Attorney Rachel Kim

Court Reporter: William J. Burke

Transcript - Direct Examination of Witness Elizabeth Granger

Prosecution: ADA Rachel Kim

Defense Counsel: Mark Carlson, Esq.

ADA Rachel Kim:

Ms. Granger, can you tell the court what happened on the morning of March 4th, 2009?

Elizabeth Granger:

Yes. I was working at the First Union Bank on 42nd Street. It was around 9:30 AM. I was at my desk, and I noticed a man, uh, later identified as... Mr. Locke, standing by the entrance.

Kim:

What did you notice about Mr. Locke?

Granger:

I... didn’t think anything of him at first. He was just standing there, like a customer would. Then, uh, he looked at me, and... I don’t really know how to describe it. There was this... pressure? And the next thing I knew, I was standing up from my desk.

Kim:

Standing up from your desk—did you make that decision consciously?

Granger:

No. It felt like—like my legs moved before I could even think about it.

Kim:

Did you attempt to stop yourself from standing?

Granger:

I mean, in my head I did. I didn’t want to. But I couldn’t stop it. My legs just—just moved, and I couldn’t stop them.

Kim:

What happened after you stood up?

Granger:

I walked to the vault.

Kim:

Did anyone give you instructions to do that?

Granger:

No... not verbally. I just walked. Like my body knew what it was supposed to do, but it wasn’t me deciding.

Kim:

And what happened when you reached the vault?

Granger:

I opened it. I used the key and the combination, and I opened it.

Kim:

Did you want to open the vault?

Granger:

No. Of course not.

Kim:

Were you aware of what was happening as you opened the vault?

Granger:

Yes. I knew exactly what I was doing. I could see everything... but I couldn’t stop it. I—it felt like my body wasn’t mine. Like when your foot falls asleep and you try to move it but it doesn’t respond, only this was my whole body.

Kim:

Once the vault was open, what happened?

Granger:

I started taking the money out. Stacks of it. I walked back toward the front of the bank with it in my hands, and I... I put it into the bags. The bags Mr. Locke brought.

Kim:

Did anyone say anything to you during this time?

Granger:

No. Everyone just—everyone just stood there, like they couldn’t believe what they were seeing.

Kim:

And during all of this, did you ever feel in control of your actions?

Granger:

No. Not at all.

Kim:

Thank you, Ms. Granger. No further questions, Your Honor.

Cross-Examination by Defense Counsel Mark Carlson

Mark Carlson:

Ms. Granger, good morning.

Elizabeth Granger:

Good morning.

Carlson:

You said that you weren’t in control of your actions that day. That’s correct?

Granger:

Yes.

Carlson:

But you were aware of what was happening, weren’t you? I mean, you knew you were walking to the vault, right?

Granger:

I knew, yes.

Carlson:

And you knew you were opening it?

Granger:

Yes, I did.

Carlson:

But despite knowing, you’re telling this court that you couldn’t stop yourself?

Granger:

That’s right.

Carlson:

Interesting. And when you were taking the money out of the vault, you were fully conscious, correct?

Granger:

Yes.

Carlson:

So, you knew what you were doing—there was no blackout, no gap in your memory?

Granger:

No, no gaps. I knew what I was doing, but I wasn’t in control of it.

Carlson:

I see. Now, Ms. Granger, earlier you described feeling... pressure. Is that how you would describe it? Pressure?

Granger:

Yes. It was like a pressure pushing me.

Carlson:

And was that pressure physical? Did you feel it on your skin, or in your muscles?

Granger:

No, not exactly like that. It’s... it’s hard to describe. It wasn’t like someone pushing me with their hands. It was more like... something inside my body was forcing me to move.

Carlson:

So, you felt this "pressure," but you don’t believe it was physical?

Granger:

No, I—it was physical in a way, but it wasn’t like being touched. It was more like my body was moving on its own.

Carlson:

But you were aware, and you didn’t lose control of your mind, correct?

Granger:

I... my mind was mine, but my body wasn’t.

Carlson:

Thank you, Ms. Granger. No further questions.

Later in the Trial - Testimony from Dr. Alan Thorne, Neurophysiologist

ADA Rachel Kim:

Dr. Thorne, you’re a neurophysiologist, correct?

Dr. Alan Thorne:

Yes, I specialize in the study of motor control and the neural pathways that dictate voluntary movement.

Kim:

In your professional opinion, how would you describe the experience reported by Ms. Granger?

Dr. Thorne:

Based on what I’ve reviewed, it sounds like Ms. Granger experienced a form of involuntary motor control, where her voluntary motor functions were overridden by an external influence. It’s similar to what we see in certain neurological conditions, like alien hand syndrome, where patients experience movement they didn’t initiate themselves.

Kim:

But in Ms. Granger’s case, this was induced externally, by another person—specifically, by Mr. Locke?

Thorne:

That’s correct. Based on the descriptions provided by the witnesses and victims, it seems likely that Mr. Locke’s power involves an advanced form of neuromotor manipulation, effectively hijacking the voluntary motor control of his victims while leaving their cognitive awareness intact.

Kim:

So, Ms. Granger was fully aware of what was happening, but physically incapable of resisting?

Thorne:

Yes. Her cognitive awareness was unaffected, but the neural commands controlling her muscles were being overridden by Mr. Locke’s ability.

Kim:

Thank you, Dr. Thorne. No further questions.

Cross-Examination by Mark Carlson

Mark Carlson:

Dr. Thorne, you mentioned something called alien hand syndrome. Can you explain that in more detail?

Dr. Thorne:

Certainly. Alien hand syndrome is a rare neurological disorder where a person’s limb, typically a hand, moves involuntarily, often performing complex actions without the individual’s conscious control. The person can see what’s happening, they’re fully aware of it, but they can’t stop the movement.

Carlson:

Would you say that the experiences of Mr. Locke’s victims are similar to alien hand syndrome?

Thorne:

In a way, yes. The victims described experiencing movements that they didn’t initiate or control. However, unlike alien hand syndrome, which is caused by neurological damage or disorder, this was induced by an external force—Mr. Locke’s ability.

Carlson:

So, it’s not exactly the same, is it?

Thorne:

No, it’s not identical. But the principle is similar: voluntary movement being overridden by an external influence.

Carlson:

But you’d agree that alien hand syndrome and what Ms. Granger experienced are both examples of the body acting independently of the mind, correct?

Thorne:

Yes, in both cases, the body is moving without conscious initiation from the individual.

Carlson:

Thank you, Doctor. No further questions.

Closing Arguments

Prosecution - Assistant District Attorney Rachel Kim

ADA Rachel Kim:

Ladies and gentlemen of the jury, I want to start by reminding you that this case is not about the victims. They are not on trial here. We’ve heard powerful testimony from each of them, and the thread connecting their stories is painfully clear. The defendant, Damon Locke, stripped these people of their most fundamental right: control over their own bodies.

Elizabeth Granger, Robert Vasquez, and the others—each of them knew exactly what they were doing. They watched, helpless, as their bodies moved, their limbs betrayed them, their hands executed actions they never wanted to perform. They were aware, but they were powerless. Damon Locke made them that way. He turned them into tools for his own gain, without their consent and without any regard for the psychological toll it would take.

I want you to remember Elizabeth Granger's testimony. She described the experience of walking toward the vault, of reaching out with her own hand to unlock it, all while her mind screamed for her to stop. This is the heart of the case, ladies and gentlemen. Locke's power—this puppeteering—is not just an attack on the body. It’s an assault on the very essence of a person’s autonomy. Every victim who took the stand shared this experience: watching their own bodies perform crimes while their minds were locked in terror.

Locke knew exactly what he was doing. He didn’t need to be at the scene of the crime physically—he sent his victims in his place, turning them into unwilling accomplices. But make no mistake: those crimes were his, not theirs. Locke’s power might not leave bruises or scars, but the damage is there. His victims are left to live with the memories of their actions—actions they had no control over.

The defense will tell you that Locke wasn’t "present" for these crimes, that he didn’t lift the money, or pull the trigger, or open the vault himself. But I’m asking you to see through that technicality. Damon Locke was present—he was there through the actions of every person he controlled. And because of that, he is responsible for every single crime committed under his influence.

When you deliberate, I ask that you consider the facts we’ve presented, the testimony of these victims who have lived with the horror of being forced to commit crimes they could not prevent. Hold Damon Locke accountable for the choices he made, not the choices they were denied. Thank you.

Defense - Mark Carlson, Esq.

Mark Carlson:

Ladies and gentlemen, we’ve heard some very emotional testimony over the course of this trial. The victims shared their experiences with us, and no one here is denying the pain and distress they felt. But you’re here today to determine whether Damon Locke is guilty beyond a reasonable doubt, and I submit to you that there’s far more complexity here than the prosecution would have you believe.

The facts are clear: Mr. Locke never stepped foot into those banks. He never touched the money. He never personally committed any of the physical acts we’ve been discussing for weeks. What we are left with, ladies and gentlemen, is the question of how much control he truly had, and what his power actually did.

We heard from Dr. Thorne, the neurophysiologist, about how Mr. Locke’s ability works. He explained that the victims retained their mental faculties, their awareness, and—importantly—their ability to process decisions, even if their bodies were acting beyond their control. Now, I’m not saying that what Mr. Locke did wasn’t wrong. But I am saying that the line between coercion and participation is not as clear-cut as the prosecution wants you to believe.

Take Elizabeth Granger’s testimony, for example. She told you that she knew what she was doing when she opened that vault. Her mind was active. Her actions were deliberate, even if she didn’t feel in control of her body. I ask you, was Ms. Granger a complete puppet, or did she have some agency in those moments? Could she have tried to resist, even mentally? These are the kinds of questions we have to ask when dealing with a power like Mr. Locke’s.

Let me be clear: Mr. Locke did not act with the same intent as a bank robber who storms in with a gun and demands cash. He didn’t terrorize his victims into compliance; he didn’t even need to be there. His power is different from any traditional criminal act, and that should be taken into account. This is not a case of grand larceny or violent assault as we’ve traditionally understood them. This is about a unique form of influence, one that blurs the lines of free will and intention.

The prosecution wants to paint Locke as a master manipulator, but they’ve failed to prove that he had the same kind of direct, violent intent we associate with these charges. Locke’s power is psychological. It’s neurological. We are in uncharted territory here, and it’s not enough to convict him of the crimes his victims committed under influence without a deep understanding of how much control they still had.

At the very least, I ask you to consider whether Locke's actions rise to the level of the intentional, premeditated crimes he’s been charged with. There’s more than enough reasonable doubt here to prevent a conviction on the most serious charges.

Thank you.

Judge Florence Weber's Final Instructions to the Jury

Judge Florence Weber:

Members of the jury, it is now your duty to deliberate based on the evidence presented to you. You’ve heard from the witnesses, the experts, and both counsel. You must now decide whether the State has proven, beyond a reasonable doubt, that Damon Locke is guilty of the charges brought against him.

Keep in mind, you are to consider the facts and evidence presented during the trial and apply them to the law as I have instructed you. The question of free will, of autonomy, and the influence Mr. Locke had over the victims, is critical. Consider the testimony of the witnesses carefully, and weigh the arguments presented by both the prosecution and the defense. You are the ultimate judges of fact in this case.

Thank you. You may retire to deliberate.