Answer Brief of Appellee - Florida State University College of Law

Through DNA testing, the blood was identified as Dorothy
Berger’s. (R659-60).
Sarver spoke with Hoskins’ father, Rufus Jones (sic).
(R667). Jones (sic) said his son had arrived at his house at
5:00 a.m. on October 18 and was driving a car that “seemed
unusual for him to have.” Jones (sic) described the car to
Sarver who determined the car fit the description of Berger’s
missing car. (R667, 668).
Sarver also spoke with James Hoskins, the defendant’s
brother. James told him he had seen the vehicle his brother
Johnnie had been driving, and there was “an area around the
driver’s side wheel well that ... appeared to be dripping
blood.” (R668). Johnnie told his brother he had driven over a
possum. (R669). James Hoskins identified Berger’s car as the one
driven by his brother. (R669).
Sarver spoke with Johnnie Mae Hoskins, the defendant’s
mother. When her son had arrived at her home on October 18, he
borrowed a shovel and then left for a short time. He returned
and subsequently changed his clothes. (R670).
On October 21, 1992, Dorothy Berger’s body was discovered
in a very remote area near Cordele, Georgia, approximately one
mile from Hoskins’ parents’ home. (R670, 675). A group of
investigators, along with Hoskins and his father, went to a
location which Hoskins pointed out himself. (R671). There,
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