“Can you tell the jury what that is?”

“Dyslexia manifests itself in an inability to process certain visual signals, usually symbols, letters, and written words. It can affect verbal abilities as well, but that’s not as common.”

“Is it curable? Can it be treated?”

“Not in the ordinary sense. You can’t prescribe medication for it. There’s no pill you can take. It can be overcome in some cases, but depending on the severity it can be very difficult, very frustrating, and in some cases it can take years. Basically what you’re doing is therapy, educational intervention, but it’s usually more effective in early childhood. The older the person is, the more difficult it may be to treat.”

“What about in Carl’s case?”

“Carl had a problem,” she says. “Because no one knew he suffered from dyslexia. He managed to hide it very well. His parents didn’t know. He didn’t know himself until he was tested and diagnosed in our office.”

“And how old was he then?”

“I think he was twenty or twenty-one years old.”

“So he went all the way through school with dyslexia, and he never knew it.”

“Unfortunately, that’s not uncommon, especially years ago. It went undiagnosed in many cases.”

“Can you explain to the jury what it’s like to suffer from dyslexia?”

“The best example I can give,” she says, “is a ciphering machine. It would be as if every written message that you received was enciphered in a code and everyone else in the world was given a decoding machine, except you. They would be getting and sending messages constantly. You would be getting messages, but you wouldn’t be able to understand any of them. And you wouldn’t be able to send any either, because you didn’t understand how to encode them.”

“So I imagine that would be very frustrating.”

“That’s the problem,” she says. “It’s the frustration and constant anxiety that generally overwhelms the person. But it’s a very slow, agonizing process.”

“How do you mean?”

She explains that it generally starts in childhood when the sufferer is just beginning to socialize with other children. As they all begin school, the other children progress, because the learning process is so heavily dependent upon reading skills. This leaves the person suffering from dyslexia looking at those around him and wondering why they’re progressing and he’s not. This results in a multitude of other problems-acting out in an effort to compensate for the inability to learn, aggression, feelings of inadequacy, depression, a whole range of psychological problems. “Depending on the child, many of these attendant problems become worse as the child gets older with major problems in adolescence, in the teenage years.”

“Can the frustration result in violence?”

“It can, and there are many documented cases of this. Studies show that a considerable number of inmates incarcerated in correctional facilities suffer from dyslexia. Of course, it’s not possible to know how their lives might have changed had this been diagnosed in early childhood and the disorder remedied.”

“Does dyslexia have anything to do with intelligence, how smart or how bright a person may be?”

“Albert Einstein suffered from dyslexia. Does that answer your question? There is absolutely no correlation at all between intelligence and dyslexia. Go online sometime and check the lists of names-celebrities, inventors, writers. Agatha Christie, if you can imagine. Alexander Graham Bell and Thomas Edison were both dyslexic.”

“How do you account for the fact that some people are able to cope with and overcome the disorder and others aren’t?”

“That’s impossible to say. In some cases it may have to do with the severity of the disorder. In others it may have more to do with the fact that they had someone around them in their early developmental years who was willing and able to spend the enormous amount of time that is required to overcome dyslexia.”

“With regard to Carl, based on your testing and evaluation, can you tell the jury how severe the dyslexia was in his case?”

“Severe. On a scale of one to ten, with ten being the most severe, I would rate Carl at nine.”

I walk to the evidence cart and collect Scarborough’s book, Perpetual Slaves. I show the witness the cover. I call her attention to the bold lettering, the title. In your opinion, if I were to show this to Carl, the title of this book, would he be able to read it?”

She shakes her head. “I don’t mean this in a bad way, Carl.” Then she looks back at me. “There isn’t a chance.”

“And if there was some correspondence-say, a letter, a handwritten letter-and I told Carl to go and find that letter, would he have the ability to distinguish that letter based on the writing from other letters and correspondence that might be at that location?”

“No.”

“Thank you. Your witness.”

Tuchio gets up, looks at the witness. “Ms. Lafair, is it?”

“Yes.”

“Would the defendant’s condition, dyslexia, interfere with his ability to watch television or process visual images such as video, news programs, things like that?”

“Generally, no. But if there was any writing on the screen, he wouldn’t be able to read it.”

“But he could understand the sounds coming from the television, the spoken words and the pictorial images?”

“Generally, yes.”

“Let me ask you about the hypothetical situation that Mr. Madriani raised, the handwritten letter in the room and the defendant’s ability to distinguish it from other correspondence. Let me give you a little variation on the theme. If there was a handwritten letter in that room and the letter in question was written in a unique color of ink, say, a tobacco color, brown as opposed to blue or black. If I told Carl to go and get the letter written in the brown ink and there was no other letter written in that color ink, would he be able to distinguish that letter from other letters?”

“Dyslexia generally doesn’t affect the ability to distinguish colors.”

“So he would be able to distinguish in that case?”

“In the circumstances that you outlined, yes.”

“I have no further questions, Your Honor.”

Tuchio has taken half of the loaf away from me. He will argue that it didn’t matter that Carl couldn’t read Scarborough’s book, because what fired him up and sent him over the edge were the television interviews with the victim. And as for the letter, if he knew the color of the ink, he would be able to find the Jefferson Letter. Of course, this begs the question: Why would someone suffering from severe dyslexia want a handwritten letter, especially if it had no intrinsic value because it was a copy, not the original?

The end of the day, and we do battle in chambers over Quinn’s desk. There are two issues, the restaurant videotape showing Ginnis and Scarborough quibbling over the letter spread out on the middle of the table and the Jefferson Letter itself.

To be honest, it’s a hard call. The video, if Quinn would let me have it, shows the victim with Ginnis across the table, as well as the letter in the middle between them. With a little maneuvering room, Teddy Nons’s transcript, and a few carefully timed winks and twitches as the jury watches the video, it wouldn’t be difficult to get them leaning in the right direction, into Ginnis’s lap over dinner.

The only problem is, I promised them a shocker in my opening statement, and moving pictures of Ginnis, even with a scowl, isn’t going to cut it. And there’s no group on earth less forgiving than twelve angry people sleeping in hotel rooms who have been promised a punch line that isn’t delivered.

Right out of the box, Quinn is worried that disclosure regarding the contents of the letter is the equivalent of tossing jet fuel on a fire.

“Can you guarantee that there won’t be violence if that letter is read?” Quinn is looking at me.