Page 110 A. Underneath this -- where we keep our computer and all that stuff. Q. Yes. A. It, too, has two drawers in it. Q. Yes. A. Okay? And there was a bottom drawer to that -- Q. Uh-huh. A. -- and in that we had extra keys in case something happened to the others and everything, and they were locked up. I had the key to them. I kept that key in my desk. In other words, those keys were forgot about. They were there but never used them really. Q. All right. Now, you kept a key to the drawer where the second set of keys were locked in in your desk. Was your desk locked? A. No. Q. Okay. Let me ask you this, Mr. Lawson. Let's say there was an emergency and somebody lost the first set of keys they got -- they went down the toilet or something -- would any of the jailers have known to go to your desk and get the key out of your desk to unlock the other keys? Mr. Shaunessy: Objection. Calls for Page 111 speculation. Q. Did you tell any of the other jailers that you'd locked the second set of keys in a particular drawer and how to get the other key to unlock them? A. I've told some of the other jailers that it was there, yes. Q. Okay. And the only reason I'm asking that is there's no point in having a second set of keys if no one can get to it. A. Exactly. Q. Okay. All right. Now, let's talk about the trustees and their duties, and I just have a list of duties that I've kind of gleaned over a period of time so that I don't have to make you -- you know, you can just tell me if they did do this or they didn't do this. A. Okay. Q. Did they collect dirty clothes? A. Yes, they did. Q. Okay. Now, how did they collect the dirty clothes? For example, from the two cells that -- now, I understand that the older cells had the bars. A. That's right. Q. Someone could just put the dirty clothes through the bars? A. That's right. Page 112 Q. But the cells that didn't have the bars, the cells that had the bean hole, is that -- how did they get their dirty clothes from the -- from those cells? A. How did who? Q. The trustees. A. Well, you go back there and you can open the door for the trustee, and he could have a laundry basket there and say, all right, you guys, throw your dirty clothes in here, and you throw them in there, or they could pass them through the bean hole if you opened the bean hole. It would just depend on whatever key you had on you at the time. Q. So did -- were the trustees ever given the bean hole key? A. Not to my knowledge. Q. All right. So did they -- the trustees also do laundry? A. Yes. Q. Okay. And I believe that -- well, let me ask you. Where was the laundry room located? A. Directly across from Cell No. 8. Q. All right. A. In the new part. Q. So it was in the same hallway with the kitchen and Cells No. 8 and 9? Page 113 A. Right. Q. Okay. When the trustees were doing the laundry -- now we're getting to that "supervised" word that Mr. Stewart said he didn't understand. I'm going to be real clear. Was a jailer standing over them every moment while they were doing the laundry? A. I'd say no. Q. Okay. How -- okay. How about taking out the trash? Did the inmate trustees take out the trash? A. Yes, they did. Q. Now, how did they get the trash from the cells? A. After lunch we had shower time. Q. Okay. A. You go through each cell; you pass the mops; you ask for the trash; you get the trash; the trustee is working with you, or, actually, you're making it accessible for the trustee because you're standing with the key and you open the cell doors. Q. Right. A. You can't pass the trash through the bars. It can't go through bean hole because it's not big enough. Q. Right. A. Okay. You've got one, two people in a cell, six people in a cell. They're going to accumulate Page 114 gargage. You know that . You carry some out at home now, I'm sure. Q. You have no idea how much garbage is in my home. A. But the point is that you've got to open the door to get the trash out of there. Q. Yeah. A. Okay. And so you've got to have the door open. You've got to have a jailer there with a key there to open the door. Q. Right. A. Okay? Does that answer your question? Q. Yes, it does with regard to how they get the trash. Now, what about taking the trash out? A. Okay. Accumulate all the trash in big garbage bags. Okay? Q. Yes. Yes. A. You have the small bags for the cells, and you put them all in big garbage bags. Of course, we have three barrels up there, too, that -- you pull those and then you put the others in there if you've got room for it and everything. All right? And then the trustee takes it downstairs. Q. Okay. A. Carries it out. Page 115 Q. Does a jailer walk down with the trustee during that time period? A. No. Q. Okay. Can -- during that time period, did a jailer always watch a trustee walk down to take out the trash? A. Always walk down? You mean always -- Q. Always watch them -- A. Always watch -- Q. -- like from the window, yes. The Reporter: One at a time, please. The Witness: I'm sorry. I apologize. The Reporter: Could you please start again? Ms. Morrison: You want me to repeat my question? The Reporter: Yes. Thank you. Q. All right. During the time period that we're talking about, trustees would be going down to take out the trash. A jailer would not walk down there with them. Correct? A. Correct. Q. Okay. Would they observe them taking out the trash? Page 116 A. The answer to that would be occasionally. Q. Okay. That's my only question. Ms. Morrison: Do you have something to say, Mr. Shaunessy? Mr. Shaunessy: I need to object to the form of the last question. Q. Washing patrol cars. Do the trustees wash patrol cars? A. Do they? Q. Did they during that time period? A. Yes, they did. Q. All right. And when they were washing these patrol cars, were the jailers normally down there with them? A. No. Q. Okay. Where were the patrol cars normally washed? A. The time period that you're talking about, the early part, they were washed on the courthouse square, right out here by the pump house. Q. All right. A. And you could walk over in the jail, look out the windows. You could see the trustee or trustees washing a car or cars, and then later -- and I can't tell you how much later, but now they're being washed Page 117 right down below the jail now, on the south side of the building there. Q. Okay. How about preparing the food? Did the trustees help prepare the food? A. Yes. Q. Okay. What kind of food during that time period did you serve at the Llano County jail? A. Primarily TV dinners, supplemented by cakes, pies, beans -- cooked beans -- salads, Jello, always something, in addition to their drinks, which may be tea and coffee, orange juice. Q. Did the trustees make these other special things like the cakes and Jello and that sort of thing? A. Yes. Q. Were the trustees -- were jailers right there with them when they were in the kitchen, at all times? A. Not at all times, no. Q. In what way when they were cooking the food were the trustees supervised? A. Personal experience, go back to the kitchen before meal time. "So I hear this is what we're going to have. I need for you to start preparing this. I've got to book in so and so. I'll be back to check on you Page 118 and see how you're coming. If you need anything, let me know," and then when you get a -- not get, but, say, take the time, the opportunity, what have you, go back to the kitchen, see how it's going, make sure everything is going as it should. I feel like they were under our direct supervision. Q. I understand. And I assume that there were cooking utensils in the kitchen? A. Yes, there was. Q. Spoons, knives, forks? A. Yes. Q. Okay. Were there knives other than regular butter knives? A. I recall -- yes. In answer to your question, yes. Mr. Shaunessy: Let's go off the record for just a second. (Off the record.) Q. How many of those knives were there to your recollection? A. I don't remember. More than one. Q. All right. Was there a window in the kitchen? A. One window in the kitchen. Q. What does it look out at? Page 119 A. Towards the west, towards the bank. Q. Okay. A. Arrowhead Bank. Q. Okay. Did the inmate trustees deliver drinks? A. Yes, they did. Q. Was the door to the recreation room normally unlocked? A. I can't say normally. It has been unlocked, yes. Q. Okay. Would it have been possible for an inmate trustee to take drinks to female inmates in the room? A. Would it have been possible? Yes. Q. Okay. Would it have been possible without a jailer being right there? Mr. Shaunessy: Objection. Calls for speculation. You can answer. Q. Go on. Mr. Shaunessy: Go on. A. Would you repeat that, please? Q. Yes, sir. Would it have been possible for an Page 120 inmate trustee to be taking drinks around to the different inmates in cells and walk into the recreation room to deliver drinks to female inmates without a jailer being right there? A. Yes, it's possible. Q. All right. Mr. Shaunesy: Object to the form of the last question. Object it calls for speculation. Q. Okay. So -- I just want to make sure. It's your testimony that the trustees were never given keys to the bean hole? A. I never saw it happen. Q. All right. Did the trustees deliver cleaning supplies to inmates in their cells? Mops, brooms? A. If you recall a while ago, I told you we opened the doors and we went down through there. Q., Sorry. How about mopping and waxing the floors? Did the trustee inmates mop and wax the jail floors? A. Yes, they did. Q. All right. And let's say -- have you yourself personally been on duty when an inmate trustee has mopped and waxed some of the floors in the jail? A. Yes. Q. All right. Let's say an inmate trustee was Page 121 only going to mop and wax the hallway right there between the kitchen and the laundry room and Cells 8 and 9, how long do you think that would take? A. I'd be guessing at that. I don't know. Q. All right. Well, have you ever -- during all your time as a head jailer, have you ever told an inmate to mop and wax that hallway? A. No, I have not. Q. All right. Why not? A. Okay. I have told an inmate to mop and wax the floors. Q. Yes, sir. I see what you're saying. How long would it take an inmate to -- and when you say "the floors," what exactly are you referring to? You're not talking about mopping and waxing the cell floors, are you? A. No. Q. All right. A. No. Q. So what floors are you talking about when you were telling the inmate to mop and wax the floors? A. Booking area, the office, the runways. I want to call this the entrance into the jail off the elevator. Q. I understand. Page 122 A. It could be foyer, entrance, what have you. Q. Okay. A. This is all tile in here. This is tile. This is tile. The runway back here is concrete, but it's mopped and waxed also, and these runways, and, of course, the hallway that goes back towards the kitchen. Q. All right. Let's say you told -- from your personal knowledge, let's say you told a trustee inmate to mop and wax the floors, how long would it take for -- you know, just average, normally, take for an inmate trustee to mop and wax everything we've just talked about? A. It could take some time because of the traffic that you'll have. You've got officers bringing in people. You might have an inmate trying to get all those floors done. It may take three days, because you have to have drying time. You have to have the mopping and cleaning before you start putting the wax on, buffing of the floors. You're going to have some time involved. I can't tell you the answer to that. I don't know. Q. Okay. Were inmate trustees kept locked up in their cells when they weren't doing their duties? A. No. Q. Tell me about head counts. How did that work Page 123 exactly? A. We did head counts at least one every hour, and I feel like most times more often, sometimes every 15 minutes, sometimes every 30 minutes, 45 minutes. Q. And were there sheets that you filled out with regard to the head counts? A. Yes, there was. Q. And what was your policy? Was it your policy that those sheets needed to be filled out as soon as the head count was done or an officer could wait -- a jailer could wait until the end of his shift or what? A. Definitely not wait until the end of his shift. Q. Okay. A. It needs to be wrote down as you complete your head count. Q. So if somebody did not write down their -- their head counts until the end of the shift, that would be against your policy? A. Until the end of the shift? Q. Yeah. A. Twelve-hour shift? Q. Yes, sir. A. I would think so, yes. Q. Okay. Tell me exactly how -- let's say Page 124 somebody was mopping and waxing, going back to the old mopping and waxing deal. A. Yes. Q. Okay. When you were doing your head counts, would you try to avoid the place that was being mopped and waxed so you wouldn't ruin their floors? A. The best you could, but if you had to, you walk right through the middle of it. It can be -- the inmate has nothing better to do than to clean it up. He's not going anywhere. Q. What about medication? Now, I believe that you stated that you had a medication -- what did you call it? A. Drawer? Q. Oh. Did you say drawer? A. Yes. Q. Okay. Was that drawer locked? A. Yes. Q. All right. Who had the key? A. It was in my desk drawer. Q. And your desk drawer was unlocked? A. Yes. Q. And to your knowledge, the other jailers knew where that key was? A. They had to know where it was. Page 125 Q. Right. So were any forms filled out when -- let's say an inmate came in who was on prescription medication. What was your procedure for that? A. Verify the best we could that that was their medication and then see to it that it's administered as prescribed by the doctor. And then you mentioned forms, and then we have our own medication log, form, for each individual inmate, and we would log when and how much and why it was taken. Q. All right. And what about a non-prescription medication? What kind of non-prescription medication did y'all have? A. Insect bite, Tylenol, or, shall we say, non-aspirin, acetaminophen. We keep a generic Benadryl for sneezes and what have you, allergies. We also keep some ibuprofen should we get someone that goes to a doctor, dentist, what have you, and they recommend that they take such and such amount of ibuprofen. We keep that on hand. Q. Okay. Were the trustees allowed to deliver medication to the inmates? A. No. Q. That certainly wasn't your procedure. Correct? A. That's -- that's right. Page 126 Q. All right. So, to your knowledge, they were not allowed to? A. That's right. Q. All right. Was it your procedure that the forms that were filled out with regard to the prescription medication be filled out simultaneously with the -- you know, immediately subsequent to the giving of the medication? Right after the medication given, was the jailer supposed to come back and write down that he gave so-and-so their medication and how much? A. Well, if it was a perfect world, it probably happened that way. Q. Okay. Was that procedure? A. Yes. Q. All right. Did you ever come on duty and look at the medication log and look at -- and the next time you were supposed to give the inmate medication you looked at the medication bottle and it was obvious that they hadn't -- that there were too many pills in there for them having received what they were supposed to receive? Mr. Nelson: Objection to form. A. No. Q. No. (More To Be Posted)