Within the first several minutes, Hadley moved into critical territory.

Q (HADLEY): Did you see that gentleman that took the stand, Mr. Frank Smith?

A (ZEIGLER): Yes, I did.

Q: Have you ever met that man in your life?

A: No, I haven't.

Q: Before this case came up did you even know of his existence?

A: No, sir, I did not.

Q: In April of 1975 did you talk to Mary Stewart about guns?

A: No, sir, I did not.

Q: Have you ever asked Mary Stewart to help you get some guns?

A: No sir, I have not.

Hadley next brought up the matter of the insurance policies. Zeigler said that in April 1975, Ted Van Deventer had suggested that he and Eunice should begin estate planning.  This became more pressing, he said, after his father's stroke in July.

In August or September, he said, an insurance agent named Hardy Vaughn compiled an estate planning package that showed that the tax liability on his and Eunice's gross estate might run as high as $500,000.

Zeigler said:  "Terry, everything the family had would go either to myself or to Eunice, depending on which one survived the other. This is the way that my family had it set up, and this is the way that Eunice and I set it up....According to Judge Van Deventer when he was discussing this very briefly with both of us, we would have had to have sold off property in order to pay federal inheritance tax in the event that something had happened."

Zeigler said that he intended to buy an  insurance package through Vaughn, who had served with him in the Army Reserve.  But Tom and Beulah—"Papa" and "Mother," as he invariably referred to them—believed that any insurance should be carried through local agents; they wanted to keep their business in the community.

Zeigler said that two Winter Garden agents, Russ Courtney and George Henry, both frequently came into the store to try to sell him insurance.  With each, separately, he applied for policies on Eunice. He did not apply for policies on himself, because he already had $250,000 in  his own name and he still hoped to be able to take out one through Hardy Vaughn, if he could persuade his parents.

Q: Did you ever take out a policy with Mr. Vaughn on yourself?

A: No, sir, I did not.

Q: Why not?