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In 1939's Days of Jesse James, the title character was played by Don "Red" Barry, with official star Roy Rogers carrying the brunt of the plotline. Two years later, Rogers was cast as ol' Jesse himself in Republic's Jesse James at Bay. Since Jesse is herein depicted as a "good guy", whose train-robbery rampage is motivated by the chicanery of a crooked railroad executive, someone else would have to handle the film's villainy. That someone was also Roy Rogers, cast as Jesse's lookalike, a local outlaw named Clint Burns. Typical of the anachronisms festooning the script of Jesse James at Bay is the presence of not one but two female newspaper reporters, played by Gale Storm and Sally Payne.