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course. He did not go to the academy because it was not to out-of-county residents anymore.
Q. I see. So you would -- okay. So you would put the new jailers, whoever they were, on the day shift with you or Jackie Dahl, and obviously this was before they were able to finish the course. Right?
A. Yes.
Q. Okay. So you were training them on site with regard to the Llano County jail standards. Correct?
A. Right.
Q. All right. Did you give them any kind of written material?
A. Yes.
Q. Tell me what you --
A. Jail procedures that was approved by Jail standards, also the Texas Jail Standards book. They all had to go through that and read that and understand that, and if there's any question, be sure and ask us about it. I wanted them to be knowledgeable before they started taking their correspondence course, at least know what a warrant was, you see, or what was going on.
Q. I understand. So, tell me -- do you want to take a break?
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A. We'd never get through if we did.
Q. Okay.
Mr. Nelson: I don't think that not taking a break is going to make you get through any shorter. So if you need to take a break, I would suggest --
Ms. Morrison: Yeah, it's going to be a while. I was going to get myself a diet Coke.
Mr. Shaunessy: Sure. Why don't we take a five-minute break.
Ms. Morrison: All right.
(Brief recess.)
Q. Okay. Mr. Lawson, I believe that you previously stated that, when you were training the other jailers, you would start them out on the day shift with either you or Jackie Dahl. Is that right?
A. That's right.
Q. Or -- let me correct myself. Did you and Jackie Dahl usually work together or apart on the day shift?
A. Together.
Q. Okay. Can you tell me during the time period we're talking about -- and that is from when Sheriff Garrett began until
September of 1997 -- what was your normal shift?
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A. 8:00 to 5:00.
Q. How many days a week?
A. Five days a week.
Q. Was it normally Monday through Friday?
A. Yes, it was.
Q. What was Jackie Dahl's normal shift?
A. At that time it was still four on, four off, yeah, and so she would work 7:00a.m. to 7:00p.m.
Q. Okay. When you said "at that time," did you -- during the time period we're talking about, but later on, did you change the jailer shifts?
A. I don't remember doing it at that time.
Q. No, and I didn't mean --
A. Since then, yes.
Q. Okay. Now, since when? Since September 1997?
A. Because we've gone to eight-hour shifts.
Q. All right. But between January 1, 1993, and September 23, 1997, did you pretty much have the same type shifts?
A. Yes.
Q. Okay. And just so I'm clear, and just so the record is clear, when we're talking about the same time shifts, we're talking about all the jailers but you were normally on four days a week, either 7:00 in the morning until 7:00 in the evening or 7:00 in the evening until
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7:00 in the morning, with four days off?
A. That's right.
Q. All right.
A. Now, let me clarify one thing. I do remember some people that we had come on work nights that trained with Betty Graham. She was an older jailer, and she's one of the jailers that I couldn't remember working. Okay?
Q. Uh-huh.
A. Because she had been with us for a while, and she was -- she trained also.
Q. Okay. And so she would train them at night?
A. Yes.
Q. All right. I did not get to go look at the jail, but it's my understanding that you go up the elevator to the third floor, and that as you walk out the elevator is the jailer's office. Is that right?
A. To the right.
Q. To the right.
A. As you come off the elevator.
Q. Okay. And can you tell me from when Mr. Garrett came on until September 1997 what was in the jailer's office? What pieces of furniture and equipment?
A. Two desks. We had a camera to take mug shots.
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Now, the office itself --
Q. Okay. Let's make this an exhibit.
A. All I wanted to do was clarify --
Mr. Shaunessy: Stop. Just remember it's got to be whatever the last number was she used from Jackie, if you have one.
Ms. Morrison: Right.
A. I can do this orally, actually, without having to draw anything.
Q. It would help me if you drew it, because I didn't get to see it.
Mr. Shaunessy: Just pick a number you know you haven't used.
Ms. Morrison: Okay. Well, think, you guys. Think, think, think. The last one was 20-something. Do you want to make it 30?
Mr. Shanessy: Thirty sounds good.
Ms. Morrison: Oh, actually, there's more than 30.
Mr. Nelson: They're your exhibits. You can make it whatever you want.
Ms. Morrison: Okay. 35.
(Lawson Exhibit No. 35 was marked for identification.)
Q. And the reason we're having to do this,
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Mr. Lawson, is, obviously, there have not been 35 exhibits in your deposition, but we, because we're in federal court, are having to number all our exhibits chronologically. And I believe you were just -- and I understand -- let me just say this right now. I am not asking you to be correct -- I'm not asking you to be an architect. Okay? And I'm not asking you to draw everything to scale.
Mr. Shaunesy: Just take as much time as you need. Don't rush.
Q. Maybe while you're drawing you can kind of tell me where we are.
A. This is what I was trying to say. You come off the elevator. You come into the -- you might say this is the foyer here. This also goes into the back to the new cells. This goes in here. You come into the -- here's the booking area.
Q. All right.
A. We have across here a cage.
Q. Can I ask you a question really quick?
A. Yes.
Q. Okay. The booking area, is it not -- is it a room or is it just an open area?
A. I'd call it a room.
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Q. Okay.
A. Like I said, you come off the elevator, come in here. Here is wire cage area. Inside of here is our office. We have shelving here, goes across here, on both sides, and right down through the middle, and it goes all the way to the ceiling, is wire mesh.
Q. All right.
A. Okay. And you would bring someone in here to book them. This would be our office. So what I'm trying to do is establish that we do have an office and booking area here. We have our computer set up on a system here. We talk through the mesh to the inmate in here.
Q. Okay.
A. Inside this office is what I was trying to tell you was a couple of desks; we have a camera in there, needless-to-say, a couple of chairs.
Q. All right. Now, when you're saying "the office" -- and, again, we're talking about not --
A. Right in this area right here.
Q. We're talking about not today but between 1993 and September 1997. Is this supposed to be a desk?
A. Yes.
Q. Okay. That's a desk.
A. Those desks have always been there.
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Q. And that's a desk. All right. And this is the wire mesh?
A. Uh-huh.
Q. And somewhere would be a camera?
A. Somewhere in here would be a camera. At that time, we had one that rolled around on wheels, just a small Sirche camera, S-i-r-c-h-e.
Q. What else?
A. Of course we have shelving over here with papers, booking information papers, okay, suicide watch, whatever -- whatever paperwork would be along this shelf.
Q. All right.
A. A fan, a monitor, where you can hear all the cells.
Q. Okay. All right. Go ahead. I imagine there were chairs?
A. A medicine cabinet. Yeah, we had two chairs.
Q. Medicine --
A. You don't have much room in there. We had a little medicine cabinet. A computer was set on top of a cabinet.
Q. On top of the medicine cabinet?
A. You've got to see it to appreciate it, because we've got very limited space and room in there now.
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Q. I understand. So is it the same size or smaller than this room?
A. It's smaller than this room. Take...
Q. Okay.
A. We're awfully small. I mean, the two desks take up nearly the whole office. When I back up in my chair, I bump the shelving.
Q. So do you have your own desk and everybody --
A. Well, this is supposed to be my desk, but we share. Don't misunderstand.
Q. I understand.
A. When I'm not there, someone else is sitting in it. But this is my desk with all my assorted paraphernalia, shall we say.
Q. Okay.
A. And this is what is known as the jailer's desk.
Q. All right. Was there any other equipment in there? Now, I know you had the monitor. You had --
A. We had drawers, and this had access to a runway that goes back to Cell 8 and past a holding cell. There's a holding cell there.
Q. All right.
A. I'm wrong here. Holding is over here. This is strip and search, or now it's medical evaluation.
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Q. But before was it strip and search?
A. It was strip and search.
Q. Okay. And the holding cell was...
A. And detox.
Q. Okay. And then you'd have to go through this way to get to 8 and 9?
A. Yes.
Q. All right. And was the kitchen also down --
A. Back down in here.
Q. Across from Cell 9, approximately?
A. Cells 8 and 9. Actually, it's right across from the restroom and the -- there's a plumber's tunnel that goes back in there. It's actually -- the entrance to the kitchen is right across from the, say, employees' restroom.
Q. I understand.
A. But, like I said, there's drawers in here underneath this shelf. There's a huge shelf, extends out on both sides of the wire mesh, that comes through here. You understand? This goes all the way to the ceiling. It's our protection. We have a door here that we can slam shut if we have to. We've never had to do it, but to protect us from the inmate that's out here. Should we have someone out here, we're
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booking him, and we're back in here at the computer, talking to this inmate, trying to get him -- whatever, if we have to come out to him, we can. It's just a matter of feet. It looks big here, but it's a a matter of feet.
Q. Okay. So when you said that if you had to slam the door shut like -- for example, if you had an inmate in the booking area and suddenly he pulls knife out of his sock or something, then you guys could run in here and slam the door? Run into the office?
A. It could happen. It's never happened.
Q. I understand. During the time period we're talking about, was the door to the office pretty much always open?
A. Yes.
Q. All right. Was there a TV in here, too?
A. Yes, right here.
Q. Okay. So, it looks like a pretty small one.
A. Don't have much room in there.
Q. Okay. So you had a little TV?
A. Various. There's been a number of them.
Q. Okay. But you usually had it on the second desk. The desk wasn't yours?
A. No.
Q. Okay.
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A. And there's shelving across here.
Q. All right. Where would you normally keep -- well, let's talk about this monitor and the security devices that were in the jail. Can you describe the monitor to me?
A. About 14 inches long, about 10 inches tall. It's got audible switches to -- in other words, we can hear individuals in each cell in the whole jail, all down through Cells 1 through 7 down here and Cells 8 and 9.
Q. Okay.
A. And each one has a separate switch that you can turn off and on to that cell. The idea is to communicate directly to without talking to the other cells if you wish, whatever. But the point is there -- the monitor itself also has the ability to be switched downstairs to the dispatch.
Q. So that if you -- if need be, the dispatchers could listen to the intercom?
A. That's right.
Q. Okay. When you were working as a jailer, you know, during your jailer shifts, would you -- if you needed to talk to somebody in one cell, would you turn off the other cells for a little while to talk?
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A. Turn off the other cells, "Hey, Tim, I need -- your mother just called and wanted to if, by god, you" -- you know, whatever.
Q. Right.
A. "Yeah. Okay." And turn everything back on. That's it.
Q. I understand.
A. Nothing was turned off five minutes, 10 minutes, nothing like that.
Q. Right. Let's say you're sitting in the office and you can hear everybody from all the other cells talking, showering, doing whatever, would it be -- was it ever hard for you to hear what was going on in one cell if there was something louder going on in another cell?
A. It's possible.
Q. Okay. And could you -- could you hear actual conversations or could you just hear sounds when people were talking?
A. Usually when those people get wound up back there and they start talking, you can hear them and you can understand what they're saying and you can pick up on it. Now, if you're talking about excessive noise from one cell to another, well, the thing I'm
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going to do, and I think nearly every jailer we got, is get up and go back there and see what it is. You're not going to just stand up here and play with the monitor, which is a rare occurrence. You're going to go to the back.
Q. Right, and check them to see --
A. You're going to check and see what's going on. "Hey, who -- what did you do?" "Oh, I threw my mattress off the top bunk." They heard it on the second floor, you know. But you went back there to see what was going on. And what I'm trying to tell you is you don't mess with the monitors very much. Leave them on, and you go back and check and see what's going on.
Q. And I understand that, and I really wasn't talking about you turning them on and off. I think you've made that clear.
A. Okay.
Q. What I was really talking about was, in order for you to hear a conversation in one of the particular cells if all the monitors are on like they usually are, would the people probably be -- you said they got riled up. You could hear what they were saying. When you say -- when you mean riled up, you mean they're talking loud pretty loud?
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A. Oh, they're talking to each other or they're talking from one cell to the other or whatever. They can't see each other, but they can talk to each other and that type of thing. You can hear what they're saying, sure. That's normal. As a matter of fact, you go back there and tell them to quiet down a lot.
Q. What if one of your other jailer -- let's say there were two jailers on duty, you and Jackie Dahl. If she went to Cell No. 9 -- because I know, on Cell No. 9 and Cell No. 8 they've got their intercoms right next to the door. Right?
A. Right.
Q. If she opened the door to Cell No. 9, could you hear it on the intercom?
A. Yes. Yes.
Q. Would it be pretty --
A. Clack, the door would open. You could hear the key. The rustle of the keys, you could hear them. You could hear her open the door, and you can say, all right, girls, because 99 percent of the time that's who is going to be in Cell No. 9 is girls, and she would talk to them. You could hear what she was saying.
Q. All right. Now, let's say -- you said you could hear the key. Can you also hear the door? Is it
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a pretty heavy door swinging open?
A. No, you won't hear the door, actually. It's quiet.
Q. All right.
A. But you can hear the door, the keys rattling and the door unlock.
Q. You can hear it unlock?
A. Oh, yeah, you can hear it unlock, and then the actual pull it open, no, you're not going to hear that.
Q. Okay. Now, no one could get in that door without the locking mechanism being opened, could they? You see what I'm saying? Even if they didn't use a key, the locking mechanism would have to open for the door to open.
A. Right.
Q. Okay. Now, let's say somebody was closing the door. No matter -- how heavy would you say that door is?
A. Oh, gosh, it wouldn't surprise me if it -- if you put them on a scale, 60 pounds, 75. They're heavy, and when they swing shut and the door actually locks --
Q. Yeah.
A. -- you're going to hear it.
Q. Okay. All right.
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A. The normal procedure is just taking the door and just pushing it to. Now, you can -- no. You slam that door and then you're going to hear it.
Q. Okay. But what if you're not slamming it? I mean, how hard do you have to pull it?
A. You're still going to have to push it shut, and it's still going to make noise.
Q. Okay. All right. So, let's see, we talked about the intercom and the monitor. Now the cameras, can you show me where some of the cameras are?
A. There's one here, and it looks toward this area.
Q. All right.
A. This is -- this is the old cell section. There's a camera here looking back that way, and you can see through here.
Q. All right.
A. Then there's a camera back here in cell -- by Cell No. 8, which is not on here, that looks back towards the kitchen and Cell 9.
Q. Okay. Now, Cell No. 9, is the door to Cell No. 9 flush with the hallway wall?
A. No, it's not. It's recessed.
Q. How much?
A. Four feet.
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Q. Okay. So can the camera see the door of the cell?
A. No.
Q. Okay. Let's talk about the keys. And remember we're still talking about during the time period of between January of 1993 and September of 1997. How many sets of keys were there? That's a bad question.
A. It is.
Q. Let me rephrase it. I -- okay. Let me back up again. Did you keep -- how did you keep your keys? And when I say that -- okay. Let me rephrase that again. Were the keys in a bunch or were they separate?
A. There's separate rings of keys.
Q. Okay. How many separate rings are there or were there during that time?
A. The keys that we use every day, your food pass key, was an individual key.
Q. And when you say "food pass" --
A. That is to open all the food pass doors and then open into the cells.
Q. And when we've been talking earlier about the food pass doors, we've -- in all the other depositions we've called them the bean hole.
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A. Same -- same thing.
Q. So the bean hole keys were separate?
A. It was an individual key.
Q. Was there just one or more than one?
A. That's one that we kept up in the drawer that we used.
Q. Which drawer? In which desk?
A. Not in any desk.
Q. Oh.
A. Underneath the shelving here there's three drawers, and it's kept in the top drawer.
Q. Okay. Was that drawer locked?
A. No.
Q. Now, how many rings of keys did you have?
A. We had -- let me -- if I may, we had a roof key that was by itself also, which would also unlock the tax office door downstairs on the first floor, and then we had a -- have, have a ring of keys that has three keys on it.
Q. Okay.
A. That's our emergency keys to fire escapes is what this is, and the emergency escape lever that we have back in the old section, and then we have another ring of keys that is used 99 percent of the time that has keys to the Cells 1 through 7 and the keys that open
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8 and 9. And it will have some other keys in there like -- that would open a -- no, they wouldn't open -- there's another ring of keys that would open the janitor's closet and the plumber's closet, so there's another set of ring keys there. Okay? And all those were kept up in this top drawer that was unlocked.
Q. All right.
A. And then you asked me, did you not, about all the keys, or what?
Q. Okay. I want to back up for a minute. Now, we've gone through a bunch of keys now.
A. Yeah.
Q. And the keys that I'm interested in are the keys on the ring that you can open the cells with.
A. Right.
Q. They were also kept in that drawer?
A. Yes.
Q. Was there a second ring of those same keys?
A. There was some more keys that would do the same job as those that we had up in that drawer.
Q. Yeah.
A. Down -- I have another set of drawers over here.
Q. Okay.
(Continued On Lawson Deposition V6)