Page 69 Continued A. Yes. Q. Okay. Was that before or after y'all had your conversation about how the jail was run? A. That was at the same time. Q. Okay. So would it be fair to say that you and the sheriff took some time together, looked at the jail together and talked about the jail together? A. I don't remember exactly what took place. I just remember him coming up to the jail, and he made the remark that he would like for me to stay in the jail. Page 70 That's all I can remember. I remember him coming up there. Q. Okay. Did he ask you any questions about how the -- how you were running the jail? A. I don't remember. Q. Did he make any suggestions on ways to run the jail differently? A. I don't remember that. Q. Do you think you would remember? Mr. Shaunessy: Don't guess or speculate. If you know whether you would remember or not, tell her. Q. What I mean by that, Mr. Lawson, is a man is coming on who's going to be your new boss, and that's Mr. Garrett. Right? A. Right. Q. Okay. You're the head jailer. Right? A. Right. Q. Okay. Now, you have been operating the jail in a particular manner for some years prior to this. Correct? A. For sometime. Q. For sometime. A. Correct. Q. All right. And were you operating the jail -- page 71 well, and if your new boss -- do you consider Sheriff Garrett to be your boss? A. Yes. Q. Okay. If your new boss came to talk to you and said Melvin, or Mr. Lawson, or whatever he calls you, I'd like to know exactly how you're running this jail, do you think you'd remember him saying something like that? Mr. Shaunessy: And here's my point, Melvin. She's entltled to know whatever you recall, and what she's asking you right now is whether you think you would recall something. So if you can honestly answer a question, then you need to honestly answer it but if you're guessing or speculating, tell her you can't do that. Now, my intervention may cause you to need her to restate her question because I've talked too much, but that's my instruction to you. Q. Do you remember my question, Mr. Lawson? A. Well, he calls me Melvin. Q. Okay. Mr. Shaunessy: Clarified that. Q. I'm glad, because I was going to ask you anyway. Page 72 So, okay, he calls you Melvin. Do you call him Nathan? A. At times. And in answer to the question, I'm not sure I would remember that, no. Q. All right. So would it be fair then to say, to your knowledge, Sheriff Garrett didn't ask you to make any changes in the jail when he started? A. Like I said, I don't remember. Q. Did you make any changes to the jail when Sheriff Garrett started? A. Not when he started, no. Q. All right. Okay. When Sheriff Garrett started, how many inmate trustees do you think you had at the time, ballpark? A. I don't know. Q. How many would you normally have at one time? And when I san "normally," I mean during the time from 1992 when you became head jailer to the incident which is the basis for this suit which occurred in September 1997. A. One, sometimes two. Q. At a time? A. At a time. Q. All right. And we are now talking about from the time when -- just to be clear, when Sheriff Garrett Page 73 was -- started sheriff to September 23, 1997, when Ms. Wisdom said she was raped. Right? A. You're talking about the number of trustees? Q. Yes. A. Yes. Q. Okay. One, maybe two. During that time -- and all of the questions I'm getting ready to ask you, unless I make it clear otherwise, are going to be from when Sheriff Garrett took over until September 23, 1997. Do you understand what I'm saying? A. Yes. Q. Okay. I don't want to hear anything what's happened after September 23, 1997, until I get to that. okay? A. Yes. Q. All right. Now, you've already stated that you and Sheriff Garrett were friends. Did you have a good working relationship? A. Yes. Q. Okay. Did Sheriff Garrett come up and oversee what you were doing at the jail? A. Yes. Q. All right. About how often would Sheriff Garrett come up to the jail? Page 74 A. I can't tell you how often. Q. Okay. Once a month? A. I recall him coming up at irregular times. Q. Yes, sir. A. I don't recall whether it would be once a month or once every six weeks or what. I just remember him showing up once in a while. Q. Okay. And when he would come up, how long would he normally stay? A. I never kept track of time that he was up there. Q. I understand. Maybe this will make it easier. When he went up there, what was he normally doing? Talking to you? A. He'd come talk to me or he wanted to talk to a certain inmate. He had something specific on his mind when he came up. It wasn't just to come up to visit. Q. I understand. A. He's the sheriff. He had something on his mind. Q. I understand. So did he -- do you recall him ever on one of these irregular visits walking through the jail, checking it out? A. Sure. Q. Okay. Did he do that -- how many times during the time that you -- that Sheriff Garrett has been Page 75 sheriff do you think that he came up to the jail and walked around and checked it out? A. My answer to that is I don't know. Q. More than one? A. More than one, more than two. Q. More than three? A. We could play guessing games. It could be more than 10. It could be less than 10. I don't know. I don't remember. Q. Okay. Would you go down to his office to talk to him? A. Yes, I would. Q. And how often do you think you would normally go down to his office to talk to him? A. It wasn't the how often. It was when I needed to talk to him. Q. So you went when you needed to? A. That's it. Q. All right. And I understand that. How often to your remembrance did you need to talk to the sheriff? I know that it would be different some months than other months, and I'm not -- you know, I'm not trying to pin you down to, you know -- but I'm just saying -- I mean, you know what I'm asking you, Mr. Lawson? Page 76 Mr. Shaunessy: Wait a minute. Only if you know what she's asking, then answer it, but if you're unclear just tell her. A. I don't know. Q. All right. You don't know what? You don't know what I'm asking you or -- A. I know exactly what you're asking me. Q. That's what I thought. A. I don't know the answer. Q. Okay. So you don't have any idea how often you used to go downstairs to the second floor to talk to the sheriff? A. That's it. Q. Well, you have testified that you would go down for a purpose. Correct? A. Correct. Q. Can you give me some examples of things that would cause you to go down and talk to the sheriff? A. One example. I have an inmate that has a medical need that I'm unsure about whether or not we ought to take care of that situation, or how does he want to take care of that? Like, he has an appointment to see a doctor in Marble Falls instead of our clinic here in the county. "Sheriff, do we carry him to Marble Falls and does he see the doctor over there? What do Page 77 you recommend?" Q. Okay. A. And he would go for it, but the thing about it is I've got to clear through my sheriff -- Q. Right. A. -- and that way we could get arrangements made to see to it that he got transported to Marble Falls. Q. Okay. What about inmate trustees? Did you ever ask Sheriff Garrett whether it was okay for you to appoint a particular inmate a trustee? A. Prior to 1993? Q. No. Prior to September 1997. A. Okay. Yes. Q. Okay. How many times did you ask whether it was all right to make somebody an inmate trustee? A. I can't tell you how many times. It was just occasionally. Q. Okay. And was there some special reason why you would go to ask the sheriff whether somebody could be an inmate trustee? A. Because he was the sheriff, and I felt like he needed to know. Q. Okay. So did you do it every time or just sometimes? A. No, I did not. Some of the times. Page 78 Q. All right. Well, if he was the sheriff and he needed to know, why did you ask him sometimes and not other times? A. I don't know the answer to that. It was just the way I did things. Q. All right. What was your understanding of the chain of command? A. Rod Decker, then the sheriff. Q. Rod Decker or John Keith? A. I'm sorry. I'm sorry. Correction. John Keith, then the sheriff. I'm sorry. Q. Well, see, I'm not trying to take advantage. I'm just asking. All right. So would you ever ask John Keith about whether he thought you should make a certain inmate a trustee? A. I don't recall doing that. Q. Okay. So if you were concerned about an inmate trustee or whether to make an inmate a trustee, you'd go straight to the sheriff. Is that right? A. Yes. Q. All right. Let's say one of the jailers had a complaint, what was -- did you tell them what the chain of command should be? Did you instruct your jailers what the chain of command was with regard to who they Page 79 should make their complaints to? A. No. Q. All right. So you never told them that if they had a complaint that they should go to you and then you would go up the chain of command? A. I don't think directly, no. Q. All right. Well, did any of the jailers ever ask you what should I do, Melvin, or Mr. Lawson, if I have a complaint? A. They came to me. Q. All right. And what kind of typical complaints would the jailers have? A. Typical. The ice machine is broke. Who do I call in? Inmate so-and-so wants to make a call after regular calling hours because he can't get ahold of anyone at home until after the calling hours. Can I allow him to do so? You said complaints. Right? Q. Right. Now, is there something besides complaints that they would tell you? A. Well, inmate so-and-so is getting a little rowdy in indoor rec. What do you suggest we do? Q. So they ask you for advice, too? Page 80 A. Yes. Q. Would you take any of these complaints up the chain of command to Mr. Keith or Sheriff Garrett? A. If I thought it was necessary. Q. Okay. What kind of complaints -- can you give me a specific complaint that you took up the line of command that you thought was important to take to Mr. Keith or the sheriff? A. Say the inability to make a long-distance collect call by the inmate, which is our policy. If you're going to make a long-distance call, it has to be collect. No calling cards, no what have you. And this inmate complains that he's not been able to make any phone calls or talk to his people or have contact with his people, or say his attorney, shall we say. I would go to the sheriff and say, "Sheriff, this individual needs to be able to contact so-and-so. May I allow him to go ahead and make a call and allow the sheriff's department to pay for it?" Okay? Q. All right. What about complaints from the inmates? What were some typical complaints from the inmates? And did they complain to you? That's two questions. First, did the inmates normally complain to you personally? Page 81 A. Yes. Q. Rather than some of the other jailers? A. Occasionally. Mr. Shaunessy: Occasionally what? A. Once in a great while I would walk down the runway and an inmate would say I need to do-do-so-and-so or I'm not getting so-and-so. I'm not getting the mop passed to me like I think I should. I prefer a clean mop instead of one that's been used in the cell before mine. Can I get a clean mop? And talk to me about it instead of a jailer. I may go back and ask the jailer has he ever said anything to you about this before? No. They know I'm the chief jailer there, and so sometimes some people just want to go direct. Q. To the head guy? A. To the head guy. They don't want to waste their time talking to -- this is going to be anywhere, any job you're in. That's going to happen. Q. I know I always do that. I want to go straight to the head guy. All right. So -- but if the inmate's complaints weren't directly to you, is it your understanding that if an inmate had a complaint, that the jailers would almost always tell you about that complaint? Page 82 A. I'd say yes. Q. All right. And would you in turn go up the chain of command to Mr. Keith or the sheriff with any of those complaints? A. Not if I could take care of it myself. Q. Okay. Now, after you became head jailer, did you do the hiring and the firing with regard to the other jailers? A. Not by myself. We had a board -- the sheriff, John Keith and myself. Q. Okay. So the board was the sheriff, John Keith and yourself, and so we'll just start out with the hiring. How would you -- if there was a vacancy, if there was a need for a jailer in the jail, what would y'all normally do? A. We'd advertise in the newspaper for a jailer. Q. Okay. A. Put the word out. Q. All right. And how many applicants would you normally get? A. There never was a set number. I mean, we'd get sometimes three, four or five. Q. Would you -- were you looking for people who had prior jail experience, or did -- would somebody with Page 83 prior jail experience or prior peace officer experience, law enforcement experience be more impressive to you? A. Yes. Q. All right. So did the three of you on the board interview people together? A. Yes, we did. Q. Okay. Well, let's take, for example, Holland Ligon. Do you remember what jailer left to leave a space for Mr. Ligon, or did you just want to hire more jailers, or how did it come about that you needed another jailer? A. Right offhand I'd say I don't remember. Q. Do you remember advertising in the newspaper? A. The sheriff took care of that. Q. All right. So do you not have any personal knowledge, then, whether there was a newspaper advertisement when Mr. Ligon was hired? A. I don't remember. Q. All right. Did the three of you interview Mr. Ligon? A. Yes, we did. Q. Okay. Did the three of you at the time -- well, did you yourself know that Mr. Ligon was Gale Ligon's grandson? A. Yes, I did. Page 84 Q. To your knowledge, did Mr. Keith and Mr. Garrett know that? A. Yes, they did. Q. Did Gale Ligon make any phone calls saying that it sure would help him out if someone gave his grandson a job? A. Not to me did he didn't. Q. Do you know if he did to anyone else? Have you heard? A. I do not know that. Q. Okay. When you -- how many people did you interview prior to giving Gale Ligon his job? A. Holland Ligon. Q. Holland Ligon. I apologize. A. I got three on my mind. I don't recall who they were. Seems to me there was three people and three interviews. Q. Okay. Would that be two -- A. Plus Holland. Q. All right. And did Mr. Ligon have any jail or law enforcement experience at all when he got the job? A. No. Q. Okay. Why did Holland Ligon get the job over the other two applicants? A. I guess because he seemed to be the best Page 85 applicant that we had. I guessed at that. Mr. Shaunessy: Don't do it again. I'll have to kill you. The Witness: Yes, sir. Q. Okay. So -- Ms. Morrison: I saw a knife earlier. Mr. Shaunessy: I had my knife out earlier, took me a while to -- Ms. Morison: Made me a little nervous. Q. But isn't it true, Mr. lawson, that part of the reason Mr. Ligon was hired was because his granddaddy was Gale Ligon? A. I don't know that. Q. Well, you had -- does everybody in the board get one vote? A. One vote. Q. Who did you vote for? A. I went along with hiring Holland Ligon. Q. All right. So did the sheriff want to hire Mr. Ligon? Holland Ligon? A. Yes. Q. Did Mr. Keith want to hire Holland Ligon? A. Yes. Page 86 Q. So did you not want to hire Holland Ligon? A. I don't want to say yes or no. Q. I understand. Why don't you explain. A. I just went along with the vote. Q. All right. Now, was your -- okay. So would it be fair to say that the preliminary vote was two to one? Mr. Nelson: I'll object in that it misstates his testimony. Go ahead. Ms. Morrison: I'm not stating his testimony. I'm asking him if it would be fair to say the preliminary vote -- A. That puts us right back to whether I want to say yes or no. Q. Well, why do you not want to say yes or no, sir? A. I had my reservations about hiring him. Q. Please tell me what they were. Mr. Shaunessy: Wait a second. Her original question was why do you not want to say yes or no, and you were saying you had reservations. Was there more that you were going to say? The Witness: No. Q. All right. Why did you have reservations and what were they? A. If I recall, he is my boys' age, and I still Page 87 regarded him as a young teen-ager, and that might not have been fair to him, because I knew my boys were doing well in their work jobs in society. Maybe I wasn't giving him the opportunity at the -- or the -- I wasn't looking at him objectively. Okay? Q. Because of his age? A. And his past. Q. All right. Tell me what there was in his past that caused you to pause. A. He was just a typical boy. Q. Tell me what there was in his past that caused you to have reservations? A. He was a typical boy. Q. What did he do that was typical? A. Drove fast, hot-rodded. What did that have to do with the jail? Nothing. But I just remember him as being Holland Ligon. Q. Do you remember if he was ever arrested? A. No. No, I've never known of that. Q. Did you think that Holland Ligon had -- did you think he was immature? You've already stated you thought he was young. A. Yes. Q. Did you think he was immature? A. At that time, yes. Page 88 Q. When you hired him? A. Yes. Q. Okay. And were you concerned that someone who was immature might have -- might not be up to the kind of stability and good judgment that you need to be a jailer? Mr. Nelson: Objection. Calls for speculation. Mr. Shaunessy: You can answer. A. I was going to say I didn't understand what he said at all. Mr. Shaunessy: Don't worry -- Mr. Nelson: You don't need to worry about what I said. Actually, I said objection. Calls for speculation. Q. But I'm not asking you to speculate, sir. I'm asking you what you believed. Did you believe that perhaps Mr. Ligon -- A. Okay. I believed that he was not jailer material at that time. Q. Okay. But the sheriff and Mr. Keith overruled you? A. I didn't -- Page 89 Mr. Shaunessy: Objection. Mischaracterizes prior testimony. You can answer. Q. But the sheriff and Mr. Keith apparently thought it was all right? A. I didn't challenge that. Q. I see. A. Okay? I told you I went along with the vote. Q. I understand the distinction. All right. Okay. Now, I just want to start with Mr. Ligon because -- well, was Mr. Ligon the first jailer that you hired after Sheriff Garrett took over? A. No. Q. Okay. Who was the first jailer you hired after Sheriff Garrett? You don't remember? A. I don't remember. Q. Okay. It doesn't matter. My question really is what were your training procedures for new jailers? A. Put them on day shift to work with me and Jackie Dahl as a rule, those of us experienced. Q. Okay. And were they also required to do the same kind of formal education that you went through with regard -- A. They had to have their certification by the state, and they got that -- "they," as in Holland, got his certification, I believe, through a correspondence (This website is over 70% full. To conserve space, the Lawson Deposition is continued on _The Llano Ledger 2. It can be found by clicking http://maxpages.com/llanoledger2.)