***Publisher's Note: With rare exception, the cowardly failure of the community to financially support this publication is stunningly pitiful and selfish. Worse yet, the sickening defense and excuse of cowardice by some is appalling. If readers care so little for this community and each other, why should I? T.C.*** Page 27 Continued Q. Okay. All right. And was that rock quarry around here? A. It was in Llano County, yes. Q. Did you -- were you getting out limestone? A. Granite. Q. Granite? Was it like pink granite? A. Pink granite. Q. I love that pink granite. Okay. So how long did you work in the rock quarry? A. I think about a year and a half, something like that. Q. All right. And when was your next job? A. Mixed cement for a brick mason. Q. Was that still here in Llano? A. Still here in Llano. Q. What was his name? A. Wesley Welgehausen. He's deceased now. Q. Why did you leave the brick -- I mean, the rock Page 28 quarry? A. They had a lot of the layoffs. We lost contracts for this granite that was being shipped to Galveston. Q. All right. So then you went and mixed cement. And how long did you do that? A. I'm going to say about a year. Q. Why did you leave that job? A. I got an opportunity to go to work for Central Texas Electric Co-op. Q. What was the offer from Central Texas Electric co-op? A. Well, it had insurance and holidays, vacation time, retirement. Q. I meant the job. Sounds like good benefits, but I meant the job. A. Good reason for me to leave mixing cement. Q. Sure. So what was the job exactly? A. They have a term called a grunt, someone that stands on the ground and sees to it at that the lineman gets material, and eventually got to where I climbed some posts, too. Q. All right. At this point were you married? A. I was married. Q. Did you already have your daughter? Page 29 A. No, I did not. Q. Okay. Q. And your next question, I guess? Q. Is going to be how long you were there? A. I got drafted while I was there. Q. For Korea? A. Vietnam. Q. Vietnam. I'm sorry. You're not that old. A. Thank you. Q. I apologize. A. Then after I come back from the service, went back to work for the co-op. Q. How long were you in Vietnam, sir? A. Six months. Tour of duty came up. I came home. Mr. Shaunessy: Wait a minute. I want to make sure y'all are talking about the same thing. You said how long was he in Vietnam. Mrs. Morrison: Right. Mr. Shaunessy: He gave you his tour of duty. I suspect he was in the service longer, but I didn't know -- Ms. Morrison: That was going to be my next question. Q. You were drafted. Can you give me kind of a year? Page 30 A. '67 to -- no. I got out in '67. '65 to '67. Q. Okay. So you were in the service from 1965 to 1967? A. Yes. Q. All right. But you had a six-month tour of duty in Vietnam? A. Yes, I did. Then I flew home from that and came home. Q. All right. What kind of job did you have in the military? A. Crane operator and squad leader. Q.. So did you see actual battle? A. I was one of the fortunate few that got shot at all the time and never did know where it came from. Q. Snipers? A. Snipers. Q. I consider that actual battle. A. Makes you crazy. Q. I'm sure. Okay. So you got back in 1967, much to the relief of your wife, I'm sure, and you went back to the electric co-op? A. Yes, I did. Q. Did you get the same job? A. Yes, I did. Page 31 Q. And how long did you continue on with that job? A. I want to say maybe six months. Then I went to work for Buttery Hardware, had the same benefits but had increase in pay. Q. So you left of your own free will? A. Yes, I did. Q. Who did you work for at Buttery Hardware? A. Henry Buttery was our supervisor. Q. I'm trying to remember. I thought there was somebody else in this -- whose deposition I took who worked at Buttery Hardware. Maybe not. Do you know if Mr. Overstreet ever worked at Buttery Hardware? A. He worked at Ace Hardware in Marble Falls. Q. That's probably what it was. So what did you do for Mr. Buttery? A. Sales. Worked in sales, traveled some. Q. Okay. And how long were you with Buttery Hardware? A. Nine and a half years. Q. It was a long time. So we are now what? You got back in 1967. I want you to correct me if I'm wrong on this. I'm just trying to speed this along. You got back in '67. You worked for the co-op for about six months, then you went to Buttery Page 32 Hardware for nine and a half years. So are we up to the late '70's? A. Let's say 1977. Q. All right. Then what happened? A. Formed a partnership with Leonard Storey, and we opened up a gun shop, sporting goods. Q. Here in Llano? A. Here in Llano. Q. What was the name of it? A. Llano Rod-N-Gun Supply. Rod, dash, N, dash, Gun Supply. Q. You were going to say "he"? A. He and I were partners. He also had a shop in Marble Falls -- Q. I see. A. -- that he managed. Q. Okay. So this was your own business? A. Yes. Q. And did you work selling and... A. If it happened, I did it. Q. I'm with you. A. Okay. Q. So is it safe to say, Mr. Lawson, that you're pretty well experienced with guns? A. Yes. Page 33 Q. All right. Would you consider yourself an expert? A. What is an expert? Q. Oh, it doesn't really matter. I mean, I'm -- you're -- you know a lot about guns? A. I'll admit to being knowledgeable about firearms, okay. Q. All right. And this isn't about anybody shooting anybody, so it doesn't matter whether you're an expert or not. So how long were you in business? A. Nine and a half years. Q. Okay. So, let's see, now we're up to mid to late '80's? A. '86. 1986. Q. 1986. What happened with the business? A. It got to the point when we were in an economic slump. I believe the whole country was. Q. Certainly in Texas. A. And it seemed that my good customers were pulling up in front of my store with a pickup load of feed and said I'm sorry. There's all my money out there in the back of that truck. I can't buy anything, but I just come by to see you. Got an opportunity to sell out, sold out, Page 34 got all the bills paid, and everybody was smiling. Best thing I ever done. I fired me. Q. Okay. And did your partner -- did you still have the same partner at that time? A. Well, he and I settled our business, and he continued on into his business in Marble Falls. Q. Okay. Ms. Morrison: Off the record. (Off the record.) Q. I just wanted to make sure, Mr. Lawson, because I forgot to tell you earlier that any time you want to take a break, you know, certainly within reason, just let me know. All right? A. Thank you. Q. Okay. All right. Now we're to 1986. You fired yourself, and you've paid your bills. Everyone is happy. Now what do you do? A. Find another job. Q. And? A. Ended up at the sheriff's department. Q. Okay. Did you apply other places besides the sheriff's department? A. Buttery Hardware. Q. And did they not have a position? A. Not at that time, no. Page 35 Q. All right. So tell me about your application to the sheriff's department. What did you apply -- what position did you apply for? A. Jailer. Q. All right. Did you ever think about applying to be a deputy? A. Eventually. Q. All right. But right now we're at '86, so you -- A. Well, actually, we're in March of '87. We spent all winter not doing anything, deer hunting. Q. Okay. So we're in March of 1987, and you -- was there -- how did you find out -- let me back up. Was there any kind of advertisement or word of mouth about there being an opening for a jailer at the Llano County jail? A. I'm trying to think on how to make this as short as I can. There was a fish fry. There was a dispatcher there and their husbands, Jackie Dahl, Yolanda Jones, and during the meal it was brought up that there was an opening for a jailer, and since I didn't have a job why didn't I apply. Q. Okay. A. I did, and I talked to Sheriff Ligon and I was hired. I went to work March 1, 1987. Page 36 Q. Okay. So you were at a fish fry and -- so you already knew Yolanda Jones and -- A. Oh, yes. Q. --Jackie Dahl? A. I've lived here all my life. They have, too. Q. Are they long-time friends? A. I wouldn't say close friends, no, but people that -- we knew each other. Q. Acquaintances? A. Acquaintances. Q. Friendly acquaintances? A. That's right. Q. Did you know Sheriff Gale Ligon? A. I guess I knew who he was ever since I was a kid. Q. He was sheriff for a long time, wasn't he? A. Long time. Q. Ms. Dahl couldn't remember. She thought it was back to the '50's. Do you think it was that long? A. Well, if you subtract like 26, 27 years of sheriff from the present -- from the date he retired, which I don't recall. Q. Okay. So you knew of him. Did you know him personally before you went in to talk to him about the job? Page 37 A. Let's say passing acquaintances. He knew my first name and I knew his, and we had spoke a time or two through the years. We had made -- or conducted business in my shop. Q. Okay. Was Yolanda Jones the chief jailer at the time? A. Yes, she was. Q. And did you interview with Ms. Jones, or was it just the suggestion at the fish fry? A. I don't recall any interview. I remember Sheriff Ligon. I -- when I went in and told him I wanted to apply for the job and wanted an application, he told me I didn't need an application. If I wanted a job, go ahead and go to work. Q. Okay. A. He knew me and I knew him. Q. All right. A. Then I went and talked to Yolanda, went through the process of fingerprinting, whatever. I was hired. Q. All right. Prior to this time, did you have any law enforcement experience? A. No. Q. Did you have any experience as a jailer? A. No. Q. Okay. Had you ever been arrested? Page 38 A. No. Q. All right. So I assume that there were no other applicants? A. I have no idea. Q. Okay. Since you had never been a jailer before and you didn't have experience as a jailer, I assume that you went through some training. Is that right? A. Yes, I went to jail school at Travis County Sheriff's Department. Q. All right. Did you do that before you started as a jailer? A. No, I did not. Q. All right. So who -- when you started -- was it March 1, 1997? A. 1987. Q. I'm sorry. 1987. March 1, 1987. Did you -- did you receive on-the-job training? A. Yes, I did. Q. Okay. Can you describe that to me? A. I guess we could start out with I was taught what key fit what door, procedures that you went through. At that time you had to learn the basics, make sure that people were fed and why they were fed certain times, certain hours; medication passed out as Page 39 needed, instructed on how to do that; booking procedures. That was before the day of the computer. Q. Right. At least the computer at the jail. Right? A. The county? I think we got a computer as quick as everyone in the county did. Tried to maintain the safety and security of the facility and why. Q. Okay. A. Also -- this come with the job -- mop, sweep floors, do laundry, because we was chief cook and bottle-washer and nurse at the same time in addition to being a jailer; paperwork, such as log-in and stuff for the commissioner's court, itemized list, and I'm sure there's more, but ... Q. Who trained you? A. Yolanda Jones. Q. Okay. Was this -- was she still living at the jail at that time? A. Yes, she was. Q. Okay. So this was before the refurbishing of the jail? A. Yes, it was. Q. All right. What was your normal shift? A. I worked from 7:00a.m. to 7:00p.m., four days on, four days off. Page 40 Q. Okay. Were there any inmate trustees at that time? A. No. Q. Okay. A. I say no. Let me back up on that. Every great once in awhile Yolanda would have a trustee, someone maybe that had to lay out fines or what have you, work their fines off, mostly people -- well, they would have to be misdemeanor fines to do that. Q. Okay. So if she did have an inmate trustee, it would be somebody who was in there for a misdemeanor. Is that right? A. At that time, yes. Q. And that's -- we're talking right when you started? A. We had -- at that time we had sometimes up to four people in jail. Q. Right. A. We didn't have the 19 or whatever that we handle now. Q. Right. All right. So when did you get your official training? A. I don't recall exactly. I was probably working sheriff's department two or three months before I went down to Travis County, and I could look at my Page 41 certificate and tell you the dates, but I don't know what it is offhand. Q. Were the only jailers you and Ms. Jones and Ms. Dahl? A. One other. Q. Who was that? A. There was a Billy Webb that was a night jailer, got a -- he was also a certified peace officer. He left us and went to Palo Pinto as a deputy, and I don't remember who came on after him. I don't remember. Q. Okay. But at least when you began, there were at least four jailers? A. Had to be five, because there was four of us working shifts and then Yolanda. Q. Okay. And she was still living there? A. Yes, she was, but she was chief jailer, and she was not working shifts unless someone is on vacation or sick or what have you. Q. Okay. A. And I don't remember who the jailer was. Q. That's all right. Previously I believe you testified -- correct me if I'm wrong -- that you guys were, you know, chief bottle-washers and, you know, did it all basically. When there was -- and I believe that you Page 42 said that every once in a while, every once in a great while there was an inmate trustee? A. That's correct. Q. What would that inmate trustee -- would that inmate trustee have any duties? A. Yes, they would. Q. And what would he or she be doing? A. Washing patrol cars -- Q. Uh-huh. A. -- sweeping and mopping the floors -- Q. Uh-huh. A. -- help preparing meals, doing laundry. Q. Even when Ms. Jones was still living there? A. Yes. Q. Okay. So they would go into her living quarters and do laundry? A. Into the kitchen, under supervision, yes. Q. All right. (Brief interruption.) Mr. Shaunessy: Go ahead. I'm just going to turn that off. Q. Now, when you first started working as a jailer, you were working for Gale Liggett. Is that right? A. That's right. Page 43 Q. I mean -- yeah, Ligon. I apologize. So what changes were made to the jail or to any jail policies after you got there? And just so you'll understand where I'm going with this, for example, when was the jail remodeled to take out the living quarters, et cetera? A. I think 1992. Q. Okay. So from 1987 to 1992, there were still living quarters in the jail? A. The best of my memory, yes. Q. Okay. So was what it in 1992, then, that the jail was refurbished in the -- A. It was completed in '92, I think. Q. Completed. When would it have been started to your knowledge? A. It would be speculation, but I'd say probably took something like six months to get that work done. Q. So, at the latest, it would be 1991 to end of 1992? A. Yes. Q. All right. Can you tell me exactly what was done within reason, to the best of your knowledge, with regard to the refurbishment of the jail? A. Okay. The living quarters were transformed from the living room, two bedrooms, kitchen at the prior Page 44 location. Then did I say living room? Q. Yes. A. Okay. That was all transformed into two cells. The kitchen was moved to the west side of the building where the bedroom was. The pantry was moved into one of the past bedrooms, and Cells 8 and 9 became what they are today. Q. Okay. And how are Cells 8 and 9 different in structure from the older cells? A. The older cells has steel bars, concrete floors, steel furniture, whereas the new cells, numbers 8 and 9, have fire retardant, five-eighths-inch paneling put in on walls, has stainless steel screens put over the windows, with no bars, and tile on the floor, and they're multi-purpose cells. I say "they," as in Cell No. 8 is a six-bed occupancy cell, where Cell No. 9 is still two bed. They have stainless showers that the older cells don't have. They're just painted steel shower stalls in the old cells. Cell 8 has a large viewing window that the other cells don't have. Q. When you say a "viewing window," do you mean so the jailers can look in? A. Yes. Q. So is the viewing window in 8 larger than the Page 45 viewing window in 9? A. Cell 9 has only the standard viewing window through the observation doors that all cells have. Cell 8 has that on the door also, but it has a -- say, a two-foot-by-three-foot observation window in addition to the other windows. Q. Okay. And I apologize if some of my questions seem rudimentary. I, unfortunately, was not able to be there when y'all went through the jails, so that's why I'm a little unclear. Now, what about the laundry room? I believe you stated that the living area became Cells 8 and 9. The kitchen was moved across the hall. The pantry was made out of -- A. A bedroom. Q. -- a bedroom. What about the laundry area? A. The laundry area remained the same. Q. Okay. It just used to be in the living quarters? A. No. She walked out of the living quarters over to -- well, yes. Yes, I'm -- correction on that. The laundry room was a part of the living quarters. It was not changed in the modification. It still remained the same, although now it is part of the jail. Q. Okay. So would you say, then, from March 1987 Page 46 until the refurbishing began, did Ms. Jones live in that live-in area? A. She moved out naturally prior to the remodeling and what have you, but I want to say she might have moved out a couple of months before they started construction. Q. Sometime in 1991? A. I would think that would be right. Q. All right. And so she was still -- did she remain chief jailer after she moved out of the living quarters? A. No -- well, just for a short period, and then she resigned. Q. Do you know why she resigned? A. It would be speculation. Q. Go ahead. Mr. Shaunessy: No, don't speculate. If you know, you can tell her. If somebody told you why it happened you can tell her, but don't be guessing. A. No. Q. So you never heard anything about why she might have left? A. No. Q. Could it have been because she didn't want to work under Mr. Garrett? Page 47 A. He wasn't sheriff at that time. Q. I know. Could it have been because Mr. Ligon was going to retire? Mr. Shaunessy: Well -- A. Speculation. Q. All right. Okay. All right. So during the time -- Ms. Morrison: Would you like to take a break, Mr. Nelson? Mr. Nelson: Go ahead. No. Ms. Morrison: I'm happy to do so. Q. Okay. So during the time of -- between 1987 and when Ms. Jones left for whatever reason as chief jailer, how many -- are you saying -- I know that you've stated that there were four jailers and her at the beginning, at least when you got there? A. Yes. Q. All right. Did that change at all between March of 1987 and when she left? And when I say "change," it's a multi-faceted question, and I'll break it down. Did jailers come and go? A. I want to say yes. Q. Okay. Can you remember any names? A. Lee Pickett was one. Q. All right. So Ms. Jones -- Page 48 A. Jodie Deathridge -- no, I take that back. Jodie Deathridge stayed there. Terry Mikeulenka. The Reporter: Mikeulenka? Mr. Shaunessy: Can you spell that? The Witness: I used to could spell that, but I can't now. M-i-k-e-u-l-e-n-k-a. Mr. Shaunessy: Anybody else? The Witness: I don't remember. Q. Now, are these people who came and left during that time period? A. Yes. Q. All right. Let me ask you about Mr. Pickett. Do you recall when he was hired the first time? A. I couldn't tell you the date, no. Q. How long after you had been hired approximately? A year? A month? A. I don't remember. Q. Okay. Who to your knowledge trained Mr. Pickett? A. Yolanda Jones. (Continued On Lawson Deposition V3)