A woman who raised the dogs that killed Diane Whipple depicted one as "a big clown" Wednesday, but said the other animal was so unpredictable it should have been put down.

Janet Coumbs, the first witness in the trial of the San Francisco couple charged in Whipple's death, told of the presa canario dogs, Bane and Hera, pulling down fences, killing her livestock and eating a doghouse.

The defense sought to establish through cross-examination that Marjorie Knoller, who is charged with second-degree murder, was unaware of any danger.

But Coumbs said she warned Knoller and Robert Noel about the dogs when they came to pick them up.

"I told them Hera should never have been taken off my property," she testified. "Hera and Fury (another of the dogs she raised) should have been shot because you never knew what they were going to do."

Whipple, 33, a college lacrosse coach, was mauled in the hallway of her San Francisco apartment building on Jan. 26, 2001. The trial of her neighbors was moved to Los Angeles due to extensive publicity in San Francisco.

Knoller, 46, who was walking Bane when he and Hera attacked Whipple, is also charged with involuntary manslaughter and having a mischievous animal that killed a human being. Noel, 60, only faces those two charges. He was not home during the attack.

Coumbs suggested that she was an unwitting pawn in a scheme by Pelican Bay State Prison inmate Paul Schneider to run a business raising the fierce dogs.

"Did you consider Bane to be part of your family?" asked attorney Nedra Ruiz, who represents Knoller.

"Yes," said Coumbs, who added that she never feared the 120-pound animal who would put his paws on her shoulders and lick her face.

"He was a big clown," Coumbs said. "He would get up and jump and dance for people. ... It was a loving relationship. We would go down to the pond and play."

She said the dog had his own pet, a cat named Chewy Chewbaca.

When she sent a picture of Bane and the cat to Schneider, he was furious, she said, accusing Coumbs of creating dogs who were "wusses." He ordered her to turn the dogs over to Knoller and Noel.

She said Knoller called and threatened her on the phone.

"She called me and she told me they could take my home, my farm, my car and any future earnings," Coumbs said. "That made me cry."

"Did you feel threatened by Ms. Knoller?" asked San Francisco Assistant District Attorney Jim Hammer.

"Yes," said Coumbs. "I thought they were going to come and take my home."

"She never took your home, did she?" asked defense attorney Ruiz.

"No," said Coumbs. "Because I turned over the dogs over to her."

In arguments outside the jury's presence it was disclosed that Coumbs is in the federal witness protection program, apparently due to threats from the Aryan Brotherhood.

Another witness, Donald Martin, a 49-year veterinarian who was called to Coumbs' farm, testified that he was shocked by their size.

"I looked in and saw eight dogs, massive, massive dogs," Martin testified. "These dogs could do bodily damage."

He described Bane as an "alpha-type" dog: "In a pack he would be the king — the top dog of the whole group. By himself he might be all right. But I felt in that situation he might be unsafe."

The veterinarian, who had to inoculate the dogs through a cage, said he later wrote to Knoller telling her the dogs would be a liability in any household. Martin said he received a terse thank-you letter from Knoller.