The Opening Statement

The 13-page opening statement Vincent Bugliosi handed out to members of the press on the morning of Friday, July 24, 1970.

Vincent Bugliosi, left, and Aaron Stovitz, holding a picture of the buntline revolver, talk to the press at the L.A. County courthouse during the county grand jury hearings.

Your Honor, defense counsel, ladies and gentlemen of the jury. As the court has just stated, the purpose of my opening statement is to give you a very brief preview or outline of what evidence the prosecution intends to introduce at the trial and what we expect to prove by this evidence so as to assist you in following the testimony and the evidence as it comes from the witness stand.

After weeks of extensive voir dire, you probably already have some rather general idea of what this trial is going to be all about. By the time this trial ends, you folks will probably be as familiar or more familiar with the facts and the evidence as we attorneys.

Now and then an attorney will give a rather lengthy opening statement, going into considerable detail on what each witness will testify to. My particular style, if you will, is not to do this. I believe in rather brief opening statements.

In the prosecutions final summation to you three or four months from now, you won’t be quite so lucky. At that time, we will go into considerable depth, reviewing the testimony of each witness, tying each witness’s testimony in with the testimony of the other witnesses, analyzing the evidence, drawing inferences from the evidence, et cetera, et cetera.

But today I am merely going to provide you with a very broad structure of the People’s case. The testimony of the witnesses, given under oath from that witness stand, will supply all the necessary bricks, as it were.

It is the custom of many lawyers to preface everything they say in an opening statement with the repetitious phrase “The evidence will show.” Although I will frequently use this phrase, I do not intend to use it any more than I have to.

However, on those occasions when I do not preface a statement with the words “The evidence will show” please understand that it is implicit – in everything I say.

As you know, there are eight counts to the Grand Jury Indictment in this case. The first seven counts are murder counts; the eighth count charges the crime of conspiracy to commit murder.

The first five counts of the indictment charge murders allegedly occurring on August 9, 1969. These five murders are commonly referred to as the “Tate” murders. Counts six and seven of the indictment charge murders allegedly occurring on August 10, 1969. These two murders were the murders of Mr. and Mrs. Leno La Bianca.

Defendants Charles Manson, Susan Atkins and Patricia Krenwinkel are charged in the indictment with all seven murders, that is, the five Tate murders on August 9, 1969 and the murders of Mr. and Mrs. La Bianca on August 10, 1969. Each of these three defendants are also charged with the eighth counts of conspiracy to commit murder.

Defendant Leslie Van Houten is not charged with the first five murder counts of the indictment; the five Tate murders. She is only charged with the murders of Mr. and Mrs. Leno La Bianca in counts six and seven of the indictment.

So I would remind you that any evidence at this trial which pertains solely to the five Tate murders should not be considered by you against Miss Van Houten for the simple reason that she is not charged with these murders.

In addition to being charged in counts six and seven of the indictment with the murders of Mr. and Mrs. Leno La Bianca, Miss Houten is charged in count eight of the indictment, along with all the other defendants in this case, with the crime of conspiracy to commit murder.

Mr. Stovitz and I, representing, the prosecution, People of the State of California, expect to offer evidence in this case proving that on or before August 8, 1969, defendants Charles Manson, Susan Atkins and Patricia Krenwinkel, together with Charles Watson, who is presently in Texas, entered into a conspiracy to commit murder. Whether or not a fifth person, Linda Kasabian, was a member of the conspiracy, will probably be up to you folks to decide.

Pursuant to the aforementioned conspiracy to commit murder, in the early morning hours of August 9, 1969, Susan Atkins, Patricia Krenwinkel and Charles Watson murdered five human beings at the Roman Polanski residence, a secluded home at the top of a long, winding driveway, located at 10050 Cielo Drive, Los Angeles.

Those five victims were: Sharon Marie Polanski, whose stage name was Sharon Tate, Abigail Folger, Voityk Frykowski, Jay Sebring and Steven Parent. As I’ve previously stated, these five murders are commonly referred to as the “Tate” murders and in the interests of brevity, I will hereafter refer to them as such. I will also refer to the Roman Polanski residence as the Tate residence.

As I’ve indicated, the Tate murders took place in the early morning hours of August 9, 1969. Later that same day, in the late evening of August 9, 1969, another defendant, defendant Leslie Van Heuten, joined the continuing conspiracy to commit murder. Pursuant to that conspiracy, in the early morning hours of August 10, 1969, these defendants murdered Leno and Rosemary La Bianca at their residence located at 3301 Waverly Drive, in the Los Feliz, Griffith Park area of Los Angeles.

What kind of diabolical, satanic mind would contemplate or conceive of these mass murders? What kind of mind would want to have seven human beings brutally murdered? We expect the evidence at this trial to show that defendant Charles Manson owned that diabolical mind. Charles Manson who, the evidence show, at times has had the infinite humility, if you will, to call himself Jesus Christ.

Evidence at this trial will show defendant Manson to be a vagrant wanderer, a frustrated singer and guitarist, a pseudo philosopher, but most of all, the evidence will show him to be a killer who cleverly masqueraded behind the common image of a hippy, that of being peace-loving. The evidence will show Manson to be a megalomaniac who coupled his insatiable thirst for power with an intense obsession for violent death.

The testimony at the trial from several witnesses will show that Charles Manson was the unquestioned leader and overlord of a nomadic band of vagabonds who called themselves “The Family.” All of these-defendants were members of Charles Manson’s family.

At the time of the Tate – La Bianca murders, the Family lived in isolated Spahn Movie Ranch in suburban Chatsworth, California. Although Manson’s Family varied in size from time to time, it invariably consisted mostly of females, and that was by Manson’s design. He felt that to become powerful, he needed men, but he couldn’t attract men to his Family without their being woman to satisfy their every need.

We anticipate – that Manson, in his defense, will claim that neither he nor anyone else was the leader of the Family and that he never ordered anyone in the Family to do anything, much less order them to commit these murders.

We therefore intend to offer evidence showing, that Manson was in fact, the dictatorial leader of the Family, that everyone in the Family was slavishly obedient to him and that he always had his Family do his bidding for him. Eventually, at his command, they committed the seven Tate – La Bianca murders.

This evidence of Mr. Manson’s total domination over the Family will be offered as circumstantial evidence that on the two nights in question, it was he who ordered the seven Tate – La Bianca murders.

Although the evidence will show that Manson did not himself personally kill the Tate-La Bianca victims, we intend to show that since he was a member of the conspiracy to commit these murders, in fact, the leader of the conspiracy, he is equally responsible and equally guilty, under the laws of conspiracy, for these seven murders committed by his co-conspirators.

The principal witness for the prosecution will be Linda Kasabian. Linda is also charged with the seven Tate – La Bianca murders, but we intend to petition the court to grant her immunity from prosecution.

The evidence will show that Mrs. Kasabian was not a hard-core member of the Family, having come to live with the Family only one month before the Tate-La Bianca murders.

In very brief outline form, Mrs. Kasabian will testify that on the evening of August 8, 1969 at Spahn Ranch, Charles Manson instructed her to get a knife, a change of clothing, her driver’s license and told her to go with Charles “Tex” Watson, Susan Atkins and Patricia Krenwinkel and do everything Tex Watson told her to do.

She will testify that pursuant to those instructions, but without being specifically told what Watson, Atkins and Krenwinkel were going to do, she accompanied Watson, Atkins and Krenwinkel to the Tate residence in the late evening of August 8, 1969 and early morning hours of August 9, 1969. Although she did not enter the Tate residence, and did not commit any of the murders, she will testify to her observations, including being an eye-witness to Steven Parent’s being shot to death by Charles Watson in the driveway of the Tate residence, and to the murders of Voityk Frykowski and Abigail Folger by Charles Watson and Patricia Krenwinkel on the lawn of the Tate residence.

The evidence will show that Sharon Tate and Jay Sebring were murdered inside the Tate residence. Mrs. Kasabian did not actually observe these two murders. However, she will testify, for instance, that she observed Susan Atkins coming out the front door of the Tate residence and to Miss Atkins telling her that she had lost her knife inside the residence.

Mrs. Kasabian will testify that, after Tex Watson, Susan Atkins, Patricia Krenwinkel and she left the Tate residence, at Tex Watson’s instruction, she threw the knives which had been used to murder the Tate victims, and the blood spattered clothing the killers wore, over the side of a hill in the Benedict Canyon area of Los Angeles.

When the group returned to Spahn Ranch after the five Tate murders, Manson was waiting for them. Tex Watson reported to Manson what had happened, after which Manson asked each of them if they had any remorse for having committed the murders to which they all replied they did not. Mrs. Kasabian will testify that actually she personally was filled with remorse, but she was afraid to admit this to Charles Manson.

There will be testimony that after the murders, the word “PIG” was found printed in blood on the outside of the front door of the Tate residence.

Among other things, we will introduce into evidence the firearm used to shoot Steven Parent to death, a 22 caliber Longhorn revolver. We will also introduce into evidence the actual clothing the killers wore during the murders of the Tate victims.

Dr. Thomas Noguchi, the coroner of Los Angeles County, will testify that the cause of death of Sharon Tate, Abigail Folger, Voityk Frykowski and Jay Sebring was multiple stab wounds. He will also testify that the fifth victim, Steven Parent, was shot to death. Voityk Frykowski and Jay Sebring, were shot, but their gunshot wounds were not fatal. Both of them died from multiple stab wounds.

The evidence will show that Manson knew the former occupant of the Tate residence, Terry Melcher, a music publisher and record producer who, in a rather subtle and oblique fashion, rejected Manson’s efforts to have him record Manson commercially as a singer-guitarist.

Mrs. Kasabian will, further testify that in the late evening of August 9, 1969, Manson told Tex Watson and the others that they had been too messy the night before and this time he was going to show them how to do it. She will testify that on the evening of August 9, 1969, she accompanied Manson,Tex Watson, Susan Atkins, Patricia Krenwinkel, Leslie Van Houte and one Steve Grogan in a car to various locations in Los Angeles County; their mission – murder.

Linda Kasabian’s testimony will show that on this evening, August 9, 1969, as contrasted to the previous night, when they drove directly to the Tate residence, in this vast, sprawling metropolis of 7,000,000 people, no one, be they in a home, in an apartment or in an automobile, were safe from Manson’s lust for death, blood and murder. The testimony will show that at Manson’s directions, the killer’s roamed about, initially looking for their victims totally at random.

Ultimately, however, Manson directed Linda, who was driving the car, to the address 3267 Waverly Drive in the Los Feliz Griffith Park area of Los Angeles. A year earlier, Manson had on several occasions – visited the former resident at that address, one Harold True. Manson got out of the car alone, walked to the home next door to Harold True’s former residence, the home next door being the residence of Leno and Rosemary La Bianca at 3301 Waverly Drive. When Manson returned to the car minutes later he called Tex Watson, Patricia Krenwinkel and Leslie Van Houten out of the car, told them he had tied the hands of the occupants of the home, and instructed them on how to murder the victims.

Dr. Katsuyama of the County Coroner’s office will testify that Leno and Rosemary La Bianca, like four out of the five Tata victims, died from multiple stab wounds.

Linda Kasabian will also testify that after Tex Watson, Patridia Krenwinkel and Leslie Van Houten left the car and Manson and the others drove off, Manson gave Linda, Rosemary La Bianca’s wallet and eventually instructed her to hide the wallet in the restroom of a gasoline station in Sylmar, which she did.

Later in the night, Manson instructed Linda, Susan Atkins and Steve Grogan to murder a ‘man in his apartment in Venice, a man whom Linda knew, but Linda, prevented the Murder by deliberately knocking on the wrong door.

There will be other evidence connecting Manson with the Tate-La Bianca murders which I will not go into at this time.

Will the evidence show Manson’s motive for these seven murders?

As the court will instruct you at the conclusion of the evidence, but before you deliberate, the prosecution does not have the burden of offering one speck of evidence as to the motive these defendants had in committing these murders. We only have the burden of proving that these defendants committed these murders. We do not have the burden of proving why they did it. However, where we have evidence of motive, we naturally offer it, since if one has a motive for a murder, it is very powerful circumstantial evidence that it was he who committed the murder.

In this trial, we will offer evidences of Manson’s motive for ordering these seven murders. There was more than one. Besides the motives of Manson’s passion for violent death and his extreme anti-establishment state of mind, the evidence at this trial will show that there was further motive which is almost as bizarre as the murders themselves.

Vary brief; the evidence will show Manson’s fanatical obsession with, “Helter Skelter“, a term he got from the English musical recording group, the Beatles. Manson was an avid follower of the Beatles and believed that they were speaking to him through the lyrics of their songs. In fact, Manson told his followers that he found complete support for his philosophies in the words sung by the Beatles in their songs.

To Manson, Helter Skelter, the title of one of the Beatles songs, meant the black man rising up against the white establishment and murdering the entire white race, that is, with the exception of Manson and his chosen followers, who intended to escape from Helter Skelter by going to the desert and living in the Bottomless Pit; a place Manson derived from Revelation 9.

Revelation 9 is the last book of the New Testament from which Manson told others he found further support for his philosophies.
The evidence will show that although Manson hated black people, he also hated the white establishment, whom he called “Pigs.”

As I’ve previously indicated, the word “PIG” was printed in blood on the outside of the front door of the Tate residence. The evidence at the trial will also show that the words “Death to Pigs” and “Helter Skelter” and “Rise” were printed in blood inside the La Bianca residence.

The evidence will show that one of Manson’s principal motives for the Tate – La Biance murders was to ignite Helter Skelter, in other words, start the black-white revolution by making it look like the black people had murdered the five Tate victims and Mr. and Mrs. La Bianca, thereby causing the white community to turn against the black man and ultimately lead to a cival-war between blacks and whites; a war Manson foresaw the black man winning.

There will be some circumstantial evidence in this trial pointing to Manson’s efforts to make it appear that black people had murdered the seven victims. Manson envisioned that black people, once they destroyed the white race and secured the reins of power, would be unable to handle the reins of power because of inexperience and would have to turn over the reins to those white people who had escaped from Helter Shelter, i.e. turn over the reins to Manson and his followers.

In Manson’s mind, his family and particularly he, would be the ultimate beneficiaries of the black-white civil war. When we offer this evidence on Manson’s philosophy on life, please keep in mind that it is not legally necessary to your determination of the guilt or innocence of these defendants. We are simply offering the evidence to help you understand how and why these seven brutal murders came about, and also, we are offering it as circumstantial evidence that it was Manson and these defendants who committed the murders.

I want to add – one further-point. We intend to call not just one, but many witnesses to testify to Manson’s philosophy on life. Among the main witnesses who will testify to Manson’s philosophies on life will be Greg Jacobsen, Paul Watkins and Brookes Posten. We intend to offer the testimony of several witnesses on Manson’s philosophies because the evidence at the trial will show that Manson’s philosophies are so strange and so bizarre that if you heard them from the lips of only one person, you probably wouldn’t believe it. So when we offer this testimony from several witnesses about Helter Skelter, though it will be somewhat repetitious, please understand the reason why Mr. Stovitz and I feel that it is advisable to do so.

What about Manson’s followers, the other defendants in this case?

The evidence will show that they, along with Charles Watson, were the actual killers of the seven Tate – La Bianca victims. We expect the evidence to show that they were very willing participants in these mass murders. That by their overkill tactics, for instance, Voityk Frykowski was stabbed 51 times — they displayed that even apart from Charles Manson, murder ran through their own blood.

As I’ve previously indicated, the evidence will show that the five Tate murders took place in the early morning hours of August 9, 1969. The two La Bianca murders took place in the early morning hours of August 10, 1969. In addition to Linda Kasabian’s testimony implicating defendant Susan Atkins with the Tate – La Bianca murders, the evidence will show that in late October and early November, 1969, approximately 3 months after the murders, while Miss Atkins was incarcerated at Sybil Brand Institute for Women in East Los Angeles, she had conversations with three of her co-inmates, Virginia Graham, Ronnie Howard and Roseanne Walker, in which she told them of her involvement in the Tate -La Bianca murders.

And there will be other scientific evidence connecting Atkins with the five Tate murders. With respect to defendant Patricia Krenwinkel, in addition to Linda Kasabian’s testimony implicating her in the Tate-La Bianca murders, we will offer evidence proving that her fingerprints were found on the inside of the door to the master bedroom of the Tate residence.

REDACTED [There will be other circumstantial evidence connecting Miss Krenwinkle with-these murders. For instance, while Miss Krenwinkle was incarcerated. at Sybil Brand Institute, she was told that the words “Rise,” “Helter – Skelter” and “Death to Pigs” were printed in blood inside the La Bianca residence. She was then asked to print these same words so that her printing could be compared with the printing inside the La Bianca residence. Although she was told that she did not have the constitutional right to refuse to give a printing exemplar, she nevertheless refused to print the requested words. We will offer this as circumstantial evidence showing consciousness of guilt on her part.]

With respect to defendant Leslie Van Houten, who is only charged with the two La Bianca murders, not the five Tate murders, in addition to Linda Kasabien’s testimony implicating her in the La Bianca murders, we will offer evidence that at Death Valley in late September, 1969, she had a conversation with Diane Lake, another Member of the Family, in which she told Diane Lake of her involvement in the La Bianca murders.

With respect to Charles Watson, the co-defendant who is presently, in Texas, in addition to Linda Kasabian’s testimony implicating him with the Tate-La Bianca murders, we will offer evidence that his fingerprints were found on the outside of the front door of-the Tate residence.

The evidence at this trial will show that Charles Manson started his Family in the Haight Asbury District of San Francisco in early 1967. The Family’s demise took place in October of 1969 with their arrest at Barker Ranch, a desolate, secluded, rock-strewn hide-out from-civilization on the shadowy perimeter of Death Valley in Inyo County, California.

Between early 1967 and October, 1969, as I’ve already indicated, the evidence will show that seven human beings and an eight-and-a-half month baby boy fetus in the womb of Sharon Tate met their deaths at the hands of these defendant members of the Family.

The evidence at this trial will show that these seven incredible murders were perhaps the most bazaar, savage, nightmarish murders in the recorded annals of crime. I am of course excluding wartime atrocities.

Mr. Stovitz and I intend to prove, not just beyond a reasonable doubt, which is our only burden, but beyond all doubt, that these defendants are guilty of these murders. In our final arguments to you at the termination of the evidence, we intend to ask you to return verdicts of first degree murder against each of these defendants.

I do not have to tell you folks of the enormous importance and magnitude of this trial. I also don’t have to tell you that it’s going to be a long trial. As my partner Aaron Stovitz has said, borrowing from Tennessee Williams, “It’s going to be a long, hot summer.”

There’s an old Chinese proverb to which I have always subscribed, to the effect that the palest ink is better than the best memory. Because this trial is going to be a long trial with a great number of witnesses, I strongly urge that you take notes during the trial so that later on in the jury room, during your deliberations, you will be able to refresh your memory as to what each witness testified to. Without notes, it’s almost an impossible task to recollect even the highlights of each witness’s testimony much less the details.

Mr. Stovitz and I feel confident you will give your full, undivided attention to all of the evidence during the trial so that you can give both the People and the defendants the fair and impartial verdict to which they are both entitled.

Thank you very much.

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