I am NOT Hostile (I'm just adverse): Trial Witness info for Writers with John Higgins, Esq.

A few of you have written to me asking for an article that explains what a hostile witness is. ThrillWriting friend, John Higgins, has kindly stepped in to illuminate this for us.

John spent 26 years in government, the last 15 years as a Deputy Attorney General and statewide prosecutor. John prosecuted cases in 19 of New Jersey's 21 counties, from simple assault to homicides including writing the plea agreement for the serial killer nurse Charles Cullen. (Information about Cullen HERE) 

Fiona - 
John, welcome and thank you for coming. We've all heard about hostile witnesses on the stand, but I'm assuming this isn't referring to their in-the-moment demeanor. Can you explain how and why a witness would be addressed with that adjective?


John - 
Well actually, it can be in-the-moment demeanor. Depending on the court rules in a specific jurisdiction, there are different requirements for someone to be considered hostile, actually.

Let me go back one step and explain how the whole witness testimony procedure works.

I will do it from a criminal trial perspective. If your readers want to do it in a civil lawsuit setting substitute plaintiff for prosecutor.


In presenting a case, the prosecutor must provide evidence for each of the elements specified in the statute that makes a criminal offense.

Under United States law, an element of a crime (or element of an offense) is one of a set of facts that must all be proven to convict a defendant of a crime. Before a court finds a defendant guilty of a criminal offense, the prosecution must present evidence that, even when opposed by any evidence the defense may choose to present, is credible and sufficient to prove beyond a reasonable doubt that the defendant committed each element of the particular crime charged. The component parts that make up any particular crime vary depending on the crime. (link)

• Mental state (Mens Rea) - intent related blog link
• Conduct (actus Reus) - the illegal act
• Concurrence -  you have an illegal action and the intent to do that action at the same time
• Causation - harm ocurred

Witness testimony is often used to fill those elements, but so can evidence in the forms of documents, pictures, DNA, etc.

The prosecutor always goes first as he or she has the burden of proof.

Witnesses are prepped before trial so we know what they will testify to or about.

Often times, there are statements already given under oath by a witness to a police officer, detective or even in front of the grand jury. (related blog post)



As prosecutors, we

• Expect the witness' testimony to be in accord with their previous statements.
• Prepare a witness close to trial to also make sure they remember.
• Allow them to read any pre-existing statement of their own if need be to refresh their recollection as part of trial prep (this can also be done in while they are on the witness stand – they can review their statement but not read from it). Remember, often a case can take 2 years or more before it goes to trial.

So as we go into trial we know the lay of the land. The prosecutor in putting on his case in chief (meaning his main testimony and evidence supporting his version of the case) must elicit what is known as direct testimony - that is we are required to ask open ended questions.to trial

So as we go into trial we know the lay of the land.

The prosecutor in putting on his case in chief ( meaning he's the one with the burden of proving his case) must elicit what is known as direct testimony - that is we are required to ask open ended questions.

We can do a bit of guided testimony to move along preliminary areas - this means we are looking for yes or no answers, which has in effect the information we are looking for as part of the question.

After we get direct testimony from our witness the defendant's attorney gets to cross examine, which means that they can ask questions that should elicit a yes or no answer.

They can ask open ended questions as well but using the yes or no answers they can box in a witness and confine them to the specific information in the question asked.

Follow me so far?

Fiona -
What if the witness wants to expound beyond a yes or no to indicate a shade of grey?

Are cross questions only supposed to be black and white?

John - 
Well a witness under cross will often try to get the information in and generally a judge will allow them to give a fuller answer to some extent. If that witness gets cut off, I can do what's known as re-direct. I can ask them to fully answer that question after the defense attorney is done with cross examination.

Fiona -
Good thank you.

John -
Now one other parameter, cross examination is limited to the topic areas covered on direct examination unless it's bringing in information like a prior criminal conviction that would impeach their truthfulness.

So redirect is also limited to the areas covered in cross examination. That way a whole new area doesn't open up. If you missed it the first time, you can't then go into it afterwards unless it's some form of rebuttal.

Generally, any witness one calls in the case in chief is a friendly witness - one who supports the prosecutor's view of the case, confirmed of course in pre trial preparation.

Now, there can also be a witness that I would rather not call because they are tied to the defendant in a significant way but for whatever reason I need information that they have and therefore have to call in my case in chief. I'm trying to think of a good example...let's say someone who can put the defendant at the location of the crime, but they are the boyfriend or girlfriend of the defendant. They do not want to testify against their loved one. (And they don't like me, lol.) They would be considered an adverse witness.

• It’s obvious they will not want to testify for me because of their tie to the defendant.
• I know they will be trouble for me.
• I can argue (ask the judge) to call them as an adverse witness. (Remember, I know this ahead of time.)
• So, I get to cross examine them from the very start, eliciting mostly yes or no answers not asking them open ended questions, confining their testimony to the certain topic

Now we get to hostile witnesses

A hostile witness technically is someone who is expected to testify consistently to what they testified to earlier. I believe they will do that but when they get on the stand they change their testimony drastically.


Fiona - 
What are some things that could make them hostile? My mind goes to threats and intimidation.


John -
That could be true, or they are playing games and trying to protect the defendant.

Generally, the prosecutor would ask a couple of questions confirming this change in testimony, and to make obvious this new version. To be safe, us their surprise I would ask for a sidebar, and then argue to the judge that I did not expect this testimony. It came out of nowhere. They had testified much differently before or told me other information.

I would then request that I be allowed to treat the witness as a hostile witness. Then I can keep their testimony much more confined through cross examination type questions.
That can also happen in pre-trial preparation, where you find out that they will be testifying as a hostile witness. Some jurisdictions require you to show more evidence to the judge if you know before hand. Similar to an adverse witness but on steroids.

A wise prosecutor is careful about these things, wanting to keep the judge up to speed. If it goes wrong in front of the jury, you could walk into mistrial territory.

Fiona - 
Really?

John -
You have to be careful what's heard in the jury's presence often in a trial the jury is kept out of the courtroom while these type things are dealt with. Once a jury hears it, they can be given a corrective instruction by the judge, but that only does so much.

If one of your witnesses just becomes really argumentative with you, you can request the court to have the witness just answer the question, but it certainly makes your case weaker.

I know that was a lot to digest....

These things present themselves on a case specific basis. Doing a trial is in many ways an art form.

Sometimes the prosecutor just elicits all the damaging information about their own witness, prior convictions, or weaknesses in the beginning of a case, admitting the problem and not giving the defense attorney the chance to make it appear that we were hiding something from the jury, or that the defense found this gaping hole in the case.

Fiona - 

Okay here they are 2 different scenarios:

1) An ex-wife wants to see ex-hubby go to jail. She is testifying. The guy is innocent, but she can put a spin on things that makes it not so clear that he's innocent - what do you do with her?

John - 
Her testimony would be in support of the state's case from what you describe. So I don't know that I would have her in hostile or adverse witness territory at all.

Now if she was lying, and I knew it. I wouldn't use her as a witness in support of my case at all.

The defense attorney will bring out her lies on cross if I didn't know she was lying. Prosecutors are not omniscient.

Fiona - 
Could the defendant's lawyer say she was hostile?

John - 
No. He gets to cross examine her if I use her as a witness first anyway. If I never called her, and he decided to call her, and he knew she was lying, he could then seek to have her treated an adverse or a hostile witness, yes.

The defense attorney is also confined to direct questions when he puts on his case.

Then I get to cross examine his witnesses.

So ...testimony in a trial goes like this:

• Prosecutions goes first puts on a witness and has to use direct (open ended) questions.
• Defense atty then gets to cross examine..prosecution can than redirect, defense can then recross for each of the state's witnesses.
• After all the State witnesses are called, the State rests its case.
• The defense gets to put on his case and calls a witness. Defense must use direct (open ended) questions.
• Prosecution gets to cross examine.
• Defense gets to do redirect.
• Prosecution gets to recross
• When all of the defense witnesses are done, then the defendant rests its case.

Fiona - 

Whew!

Scenario 2) Defendant's fiance is called to testify against the love of her life. Agh! She witnessed the crime, but she doesn't want Cuddle Bear to rot in the slammer. She is on the witness stand, defiant and protective. What do you do? 

John - 

In scenario #2 she would qualify as an adverse witness right off the bat from what you describe. Mainly because of her status as the defendant’s fiancé. A better example would be: We cut a deal with the fiancée to testify against Cuddle Bear so she gets lesser charges in exchange for testimony against the guy. She remains consistent about testifying against the fiancé all through trial preparation. Now, she gets on the stand and does what you said above, becomes belligerent and now untruthful.

I would then request she be considered a hostile witness. And I would confine her testimony tightly -- get exactly what I needed from her and get her off the stand.

Remember, I can always request that the court advise her to confine her answers to the questions asked. If the defense attorney attempts to follow up on whatever she just mentioned, I can object on the basis that it's beyond the scope of the direct testimony.

Of course, any objection is at the discretion of the trial judge. He may sustain or overrule the objection.

A hostile witness can be fatal to a case.

Fiona - 

Thank you so much for that explanation. Are you sure I can't convince you to write a book - Courtrooms Explained: Information Writers?

John -
Right now, I am working on my memoirs. I'm still in the proposal stage. I'm not sure if that will take two months or two years. 

Fiona - 

In the meantime though, we can listen to your sagesse, John is on Practical Solutions For America at 11 pm EST on the Barb Adams show every Saturday night, discussing problems in american and solutions www.radioamerikanow.com

I know you'll want to tune in. Listening to professionals speak gives you a rhythm and tone quality that you can use in your writing. Word choices, thought processes, all of it adds to depth of character. (And you'll probably enjoy the subject matter, too.)

Here is John's  website 

Thank you to John for sharing his expertise and his willingness to help. 

Fiona Quinn's Newsletter Link, Sign up HERE
Thank you so much for stopping by. And thank you for your support. Cheers,When you buy my books, you make it possible for me to continue to bring you helpful articles and keep ThrillWriting free and accessible to all.

Isn't It Grand? Did You Write a Felony into Your Plotline? Info for Writers with John Higgins, esq.

Fiona - 
After a ThrillWriting reader asked me about Grand Juries,  

I contacted my friend and fellow writer John Higgins. 

John please give us a glimpse at your background. 

John -  

I have had a multifaceted career doing everything from farming to gun sales and repairs, refinishing antiques, developing industrial finishing systems, am a scuba diver, and private pilot.  

I spent 26 years in government, the last 15 years as a Deputy Attorney General and statewide prosecutor. I prosecuted cases in 19 of New Jersey's 21 counties, from simple assault to homicides including writing the plea agreement for the serial killer nurse Charles Cullen. (Information about Cullen HERE) 

Cullen Plea, New York Times

 I dealt with cases from the investigation stage through trial and even defended motions by convicts after all their normal appeals were denied. I also wrote policy papers, worked with governmental committees on timely societal problems and drafted legislation.   Lastly, I even created, and implemented oddball projects such as filming rock stars to prevent substance abuse and a play that was performed by inner city high school students to reduce the incidence of bias crimes. In the week just prior to my retirement, I indicted two cases in State Grand Jury and two cases in one county grand jury and then another two cases in another county’s grand jury, six in all. 

Fiona -  

Can you start with a grand jury primer? What is the purpose of a grand jury? 

John -  

I will base my information on New Jersey's system. It's comparable to most of the other states and Federal system but there may be some differences. 

Grand juries are required by the federal and most if not all states’ constitutions.  

The simplest way to describe the purpose and operation of a grand jury is that it is a safeguard to make sure that the prosecution has enough evidence to establish that it is probable that a person has committed a specific serious crime and should be charged and prosecuted for that crime.  This is to prevent the prosecutor or government from exposing someone who is innocent to the embarrassment, cost, and potential harm of being tried for a serious crime.  

In New Jersey the grand juries are composed of twenty-three citizens who hear the prosecutor’s case.  The number of citizens on a grand jury can vary across the country. 

In New Jersey again, a majority of the grand jurors, 12 or more must find that there is sufficient evidence that a reasonable person would believe that this "target" or person committed that specific crime and that they should be tried in the courts for that charge.   

The number of required grand jurors may also differ in other jurisdictions. It is important to note that the level of proof required is less in a grand jury determination than it is in the petit or trial court jury. At trial the burden of proof is much higher, proof beyond a reasonable doubt as opposed to probable cause. Serious crimes require a prison term of 12 months up to life in New Jersey and what we call serious crimes are called felonies in many other states.  

Fiona -  

"Target" is the correct word for someone going before the grand jury? 

John - 

Yes.  We call them "targets" because often the grand jury is used in the investigation stage, and they may or may not turn into "defendants" with an indictment handed down charging them with a crime. Remember citizens are presumed innocent in our society. 

Fiona -  

Not every case requires a grand jury, surely. 

John -  

In New Jersey we have a wide variety of less serious illegal behaviors which are categorized as petty disorderly persons and disorderly persons offenses.  Most other states call them misdemeanors.  These disorderly persons offenses only expose an accused to a potential of about 6 months in county jail as opposed to being sent to prison. And these offenses are tried in front of just a judge—the accused is not allowed to have a jury trial.  We handle almost all of these types of offenses in municipal court which is also our traffic and parking ticket courts.   

Examples of petty disorderly and disorderly persons offenses here are: 

• simple assault 
• getting into a fist fight
• shoplifting less than $200 worth of goods.  

In some ways it makes things more efficient too as the whole system would be mired down if we had to select juries for all those offenses.  These cases are also brought mostly by police officers that swear that they have either witnessed the offense or have evidence to establish probable cause that this accused person committed it.  

Fiona -  

Who sits on the grand jury? And who brings the cases before the grand jury? 

John -  

In New Jersey Grand Juries are panels composed of 23 jurors selected by mailed jury duty notices. They are subjected to some examination by a judge designated to select or impanel them, and who reviews excuses for not being able to serve because of hardship or conflicts of interest generally.  

The grand jury most often hears cases that are already in process.  In the majority of cases initial charges have already been filed by law enforcement through an arrest, a warrant or sometimes a summons.  But there are also matters that are investigated by a grand jury to determine if anything criminal did occur and if they decide there wasn’t a crime nothing further happens.   

 For example, a police officer can file charges where they have witnessed the offense being committed in their presence and they place the accused under arrest.  Initially, the police file charges of a serious crime if it qualifies, but then the grand jury has to agree with that determination before the accused can be tried.  Of course that allows for further investigation after arrest and before the grand jury makes their determination.  

There are also some cases created when one citizen files charges against someone else where the police have not witnessed the offense.  I can’t think of an instance where that ever made it to the grand jury level, those minor cases are basically dealt with solely in Municipal Court -- usually disputes between neighbors etc.   It is important to realize that only a prosecutor can present a matter before a grand jury and never a private citizen.  

Typically, in cases that have already been charged through an arrest or a warrant, the prosecutor reviews the case file and if he or she believes there is enough evidence to prosecute the matter against that target, he or she then goes and  presents the evidence before the grand jury for their consideration of potential serious charges.  

Fiona - 
The grand jury decides whether or not there is a sufficient case to go forward against a target. A majority needs to believe there is sufficient cause for a trial. Can you talk about that yay or nay process?

John - 

In New Jersey, only a simple majority of the grand jurors have to vote to return what is known as a “True Bill”  here, which means there is probable cause that a crime was committed, and that this defendant committed it, or they were involved in perpetrating the crime. Other states can require a super majority of 2/3 or the like of the grand jurors in their system.  

A fuller definition of Probable Cause - is a reasonable belief based on articulable facts that the person committed or was involved in the criminal act. 

If the grand jury does not believe that there is probable cause, there will not be enough votes to indict the matter which is called a “No Bill.”  Then there is no indictment, and the matter is generally ended.  However, your readers should realize that the prosecutor can always present the case again, providing the statute of limitations has not ended for the crime.  

Many defendants file motions to dismiss the indictment based on a variety of grounds, basically that something went wrong in the grand jury process, or the prosecution did not present enough evidence etc.  Most times, even when a defendant wins that motion, unless the court specifies that the dismissal is “with prejudice” meaning the case is ended, the prosecution can repair the defect and present the case again to a grand jury as long as the statute of limitations does not prevent it.   

So your readers understand what a statute of limitations means, every crime has a period of time after it was committed that allows for the case to be brought.  Again this is a protection for the accused because as time passes, it’s harder to both prove a case or defend against a charge as witnesses die, move away, evidence is destroyed or spoils.  Most crimes in New Jersey are limited by a five year period which means they must be indicted before five years have passed since the crime was committed.  There are a few exceptions such as:

• murder (anytime)  
• official misconduct (7 years) 
• continuing conspiracies (depends on the facts of the case).  

Fiona - 

What is an investigatory grand jury? 

John -  

Investigatory grand juries can be an already sitting grand jury or one assembled for a particular purpose.  Generally, they become fact finders of sorts and look into any evidence that can be gathered to see if anything improper was done and if there was, that the evidence is sufficient to meet the probable cause standard that it was a crime that was committed by that target. They can call witnesses and investigate of course through the prosecutor, directing him or her to compel witnesses or documents through subpoenas for their consideration.  

They are usually used in cases of police shootings or other cases where the facts may not be so clear cut or where a great deal of evidence has to be gathered such as a Watergate break-in type event and there could be a large number of targets. 

  

Fiona - 

You said the grand jury has the power to call witnesses and investigate, what does this include? 

John - 

Grand juries have a broad subpoena power to gather evidence and compel witnesses to testify.  The power is not unlimited.  There are some instances where a witness has a privilege which gives them a reason to not testify or turn over evidence, for example a Fifth Amendment right not to testify against themselves etc.   Or a subpoena may not be legally sufficient in New Jersey for getting electronic communications and data which require a greater amount of scrutiny by a court before that evidence can be required to be turned over to law enforcement, and then presented to a grand jury such as telephonic records and the like. 

The subpoenaed party can file a motion to quash the subpoena and then a court would have to determine whether to compel them to turn over the evidence or to testify.  If someone refuses after the court finds that the motion to quash is denied or that the party simply doesn’t comply, they then can be held in contempt, and punished by the court.   

In New Jersey, we also often use target letters where we would advise someone we are investigating them and offer them the opportunity to testify before the grand jury on their own behalf. However, the target cannot be accompanied by legal counsel in the grand jury room. Legal counsel can sit outside, and the target can take breaks to confer with their counsel if they deem it necessary, but there is no opposing counsel allowed into the grand jury room. Few targets ever appear like that though.  

Grand juries are secret proceedings -- only the grand jurors, stenographer, witnesses and the prosecutor(s) are allowed in the room.  Complex cases often have more than one prosecutor assigned.  

Your readers should also be aware, that contrary to the popular belief that a prosecutor can easily convince a grand jury to “indict a ham sandwich” we are required to provide the grand jury with what’s called exculpatory evidence, that is evidence that tends to show the defendant did not commit the crime.  If we do not present and/or provide exculpatory evidence, it is the easiest grounds to have the indictment dismissed or overturn the conviction later if the case went that far.  It is also considered prosecutorial misconduct which has its own range of sanctions directly against the prosecutor.    

Fiona -  

Is a true bill part of public record? 

John -  

Yes, a “True Billed” indictment becomes a public record, but not always right away.  In larger, more complex cases an indictment can be sealed on the prosecutor’s motion before the grand jury judge and kept secret until law enforcement is ready to arrest the target.   The sealing can be used to make sure the defendant doesn't flee or to allow law enforcement to continue its investigation against other associated targets.  The indictment then will stay sealed until the entire case is indicted, this prevents other targets from fleeing, taking other actions to make it more difficult to prosecute the matter, or destroy evidence.   

. 

Fiona -  

How do they gather a grand jury? 

John -  

They are gathered by a mailed jury duty notice, the same as is used for trial level or petit juries. The term of service for a grand juror is longer though, usually 6 months.   In New Jersey it is required that there is always a grand jury sitting in each of the 21 counties as well as a state grand jury to hear cases.  Sometimes special grand juries can be assembled for a specific case where an investigatory grand jury is required. 

 In New Jersey, we have a state grand jury as well as a grand jury on the county level in each of the 21 counties. In state grand jury indictments, prosecutors request a specific venue or county for the case to be tried in as the cases are all tried on the county level. 

We use the state grand jury often where there is a conflict of interest. Say the target is a member of a county prosecutor’s office or a superior court in a county or family member who is indicted, we move the case outside of that county to prevent the appearance of impropriety. Sometimes cases involve crimes committed in multiple counties or across state lines, we then have to decide which county is best to try the case in after indictment and recommend accordingly.   

As a Deputy Attorney General, I could present cases both before the state grand jury and county grand juries. My choice depended upon the complexity of the case and the caseload.

There are some other wrinkles that may be different across the country.  For example in New Jersey,  if we as prosecutors compel a police officer to testify as a requirement to keep their job while he or she is also a target,  the police officer can later  claim immunity from prosecution through that indictment.  Therefore a prosecutor has to be very aware of these types of pitfalls.  

Fiona - 

Define indicted. 

 John -  
Indicted means that the grand jury determines after hearing evidence that there is probable cause that a crime has been committed by this target. 

The indictment is specific to the charges exactly as voted upon by the grand jury. 

Fiona -  

What is the role of an Attorney General and an Assistant Attorney General? 

John -  

Broadly, Attorneys General across the country are the legal advisors to the Executive Branch and handle matters where the State or Federal Government is sued civilly or administratively. Assistant Attorneys General and Deputy Attorneys General are the subordinates. And yes, it's Attorneys General; its not a rank like a major or colonel. 

In New Jersey, the Attorney General is also the Chief Law Enforcement Official under the Governor. That means in New Jersey all local police, state police, and county prosecutors report to and are under the command of the Attorney General. From what I understand we are the only state to have such centralized control.  

In other states, it's a county based system where the District Attorney or County Prosecutors are in charge of law enforcement within their territorial jurisdiction and are not under the control of their respective Attorney General.  

 As a result, I was a statewide prosecutor as a Deputy Attorney General within our Criminal Division which meant I had jurisdiction across the entire state; whereas the county assistant prosecutors only had jurisdiction in their own county.  They could not handle matters in other counties unless they would temporarily be designated as an acting Deputy Attorney General. 

Fiona - 

Tell me about the roles of the District Attorney (DA) and Assistant District Attorney (ADA)? 

John -  

In New Jersey, County Prosecutors and the Attorney General are appointed by the Governor and confirmed by the State Senate.  

In many other jurisdictions they are elected. 

They only prosecute cases that occur in their counties from assaults all the way to homicides. 

In New Jersey we have the Attorney General as head of law enforcement because it makes it easier to handle complex cases that cross county lines; involve multiple counties; or have organized criminal activity and need a lot of resources to investigate such as the Mafia, skinhead organizations, or gangs ; or where the crimes were committed across state lines. For example, the serial killer nurse we had. He confessed to killed twenty-nine patients in four New Jersey and two Pennsylvania counties.   Or the other nurse case I worked on where she killed hubby here in New Jersey but disposed of the body in Virginia.  

I hope that explains your readers’ questions adequately, if any of your readers have additional questions feel free to drop me an email. 

  

 Fiona -  

It is tradition that ThrillWriting guests tell us a story - either about a scar or a harrowing event. Would you please? 

 John -  

When I was 15 or 16, I was in NYC in a subway with my cousin Ruthie and her boyfriend. We were going back to my aunt's house in Riverdale after leaving the Metropolitan Museum of Art.  We had used the last of our money on subway tokens and were waiting at the platform. This older bowery-type bum walked up to us, approaching with the trough for the subway trains behind him. As he got closer to me, I saw him open up his old grey coat, and I saw a scabbard inside the coat with a Bowie sized knife within it - although it certainly was far from being that fancy of a blade.   As he got closer, he pulled out the knife, pointed the blade at me and said, “Give me all your money."  I looked directly back in his eye as I knew that none of us had any money to give him, all the while my cousin and her boyfriend could not help me as they were off to the side, standing there frozen. I calculated he was going to knife me when I told him I have no money, so I prep myself to take my leg and bring it up to push him backwards into the train trough behind him, figuring that he would miss slashing anything that could be fatal on me. And at that point I would have nothing to lose as I anticipated he was going to knife me anyway.  As I tensed up to strike, he went, "Ha ha ha - only joking."  He then took the knife, put it back into the scabbard and then walked away.  

Fiona - 

Glad you were all safe. 

Please tell us about your writing. 

John -  

My first book series deals with Archangels and the War in Heaven. It’s an epic story with Seven Levels of Heaven, fourteen archangels, nine specific species of angels, with a Human and Angelic love story entwined within it.  

I wanted to write something different from crime as I needed a break from that genre after retiring. I had my own experience with Angels as a toddler and as result have been fascinated by the whole myth about the Angels.  

These Beings of Light, closest to the Almighty did not just disobey the Almighty by not following the instructions to not eat the forbidden fruit like mankind did, but they actually attempted to take over the heavens and overthrow their creator.  The first three books, The Archangel Jarahmael and the War to Conquer Heaven: In the Beginning; In Rebellion; and In Exile, the trilogy in heaven, are already out.   

Book 4, In Pursuit, which moves the story into Hell and the Underworld is with the publisher awaiting edits, I anticipate three trilogies, one in the heavens, one in hell and the last one on earth, nine books in all.   

 Now, I am also writing my memoirs including some of my law enforcement experiences as well as a novel about a corrupt governor running for POTUS and another novel about a serial killer.  

If you want to stay in touch, 

my website   

I can also be heard on my own radio show, (Fiona was a guest for an hour chat go HERE if you'd like to listen.)

Tuesday nights  and also discussing politics and practical solutions for America on the Barb Adams Show on the Genesis network, Saturday nights. 

Fiona -  

Thank you to John for sharing his expertise and his willingness to help. 

Fiona Quinn's Newsletter Link, Sign up HERE

Thank you so much for stopping by. And thank you for your support. When you buy my books, you make it possible for me to continue to bring you helpful articles and keep ThrillWriting free and accessible to all.