***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. And how did they train you? Did they just tell you? Page 28 A. Yes, ma'am. Q. Okay. And when did they tell you this? A. Whenever we first started. Q. When you first started? A. Yes, ma'am. Q. Did you receive any training on how to deal with inmate complaints? A. Normally on an inmate complaint, if it was written down, we passed it through the chain of command. Verbal complaints we also passed along. Q. Who was your direct supervisor? A. Melvin Lawson. Q. Okay. And is that who you would pass complaints on to? A. Yes, ma'am, either him or the sheriff. Numerous times I received -- Mr. Nelson: She's only asked you who you would pass complaints on to. Questions By Ms. Lemanczyk: Q. Do you know if Melvin Lawson would pass those complaints on to Sheriff Garrett? Mr. Shaunesssy: Objection; Page 29 calls for speculation. Ms. Lemanczyk: If you know. Questions By Ms. Lemanczyk: Q. Do you know if he ever passed those complaints on to Sheriff Garrett? A. Yes, ma'am, he did. Q. Okay. And how do you know that? A. I would see him take them downstairs -- Q. Okay. A. -- and place them in his box or I would see them in his box. Q. What type of complaints did you get? Mr. Nelson: You're asking him over the entire time that he worked there? Ms. Lemanczyk: Yes. I'm asking him the types of complaints he would receive. The Witness: Food being cold, food being burned, showers too hot, trash needing to be taken out of the cells, plumbing stopped up, plumbing not working appropriately, lights burned out, stuff of that nature. Questions By Ms. Lemanczyk: Q. How many complaints did you receive during the time you were employed? A. I don't have any idea. Page 30 Q. Is it 100? Mr. Shaunessy: Let me object to the extent that it calls for him to guess or speculate. Mr. Nelson: I mean, you're asking over a, what, three-year period how many complaints he received, and he's answered he doesn't have any idea. And to go further, you really are calling for him to speculate. Questions By Ms. Lemanczyk: Q. Let me ask you this: Do you have any idea about how many? A. No. There's -- there's no way to -- Q. Were the complaints in writing? A. Some of them would be. Q. Okay. And what did you do with those complaints when you received them in writing? A. If it was to me, I would read them and try to handle the situation. If the complaints were not addressed to me, I would put them in their appropriate place. Q. "Appropriate place" being to Melvin Lawson? A. If they were to him, I would put them in his box. If they were to the Sheriff, I would place them in the downstairs box, which would see that they got to him. Page 31 Q. What if the complaints were directed to another jailer? A. I would leave it for them. Q. Okay. When the complaints were directed to you, did you ever tell Melvin Lawson that you received a complaint? A. It would depend on the complaint. Q. Okay. What types of complaints would you tell Melvin Lawson about? A. Plumbing being backed up. Q. What types of complaints would you not tell Melvin Lawson about? A. A light bulb being burned out. Q. Are those things you would take care of yourself? A. Yes, ma'am. Q. Okay. Did the procedures establish when you were supposed to pass on complaints and when you weren't supposed to pass on complaints? Mr. Nelson: Hold on. Let me object. You're asking the procedures. Can you be more specific? What procedures are you talking about? Questions By Ms. Lemanczyk: Q. I think earlier you testified that the procedure when you had an inmate complaint was to pass it Page 32 on to your supervisor; is that correct? A. It would depend on the complaint. Q. Okay. How would you determine which complaint should be passed on and which ones should not be passed on? A. A lot of it would be common sense type. If it -- a lot of times we would receive an envelope that would have a note in it and they'd have their name wrote on the front of it. If the envelope was sealed, you give it the appropriate person if was something like the plumbing where you kind of use the chain of command so that they know there's a problem and they can get a hold of the judge's secretary who can then, in turn, get a hold of the plumber and get him up there. But if it was a light bulb burned out, you just fix it. Q. Okay. Just so I understand, was there a written policy about complaints? A. No, ma'am, not that I know of. Q. Okay. So you used your discretion as to when to pass on a complaint and when not to? A. Yes, ma'am. Q. Okay. Who is Natalie Ashabranner? A. A girl that lives in Llano. Q. Okay. Have you -- you've engaged in sexual intercourse with Ms. Ashabranner, have you not? Page 33 A. Yes. Yes, ma'am, I have. Q. And, in fact, that was while you were on duty at the Llano County Jail; isn't that correct? A. No, ma'am. Q. So you've never had sex with Ms. Ashabranner while you were at the jail? A. No, ma'am. Q. Have you ever engaged in sexual intercourse with her while you were on duty? A. No, ma'am. Q. How old is Ms. Ashabranner? A. I do not know her age. Q. Okay. Isn't it true that you've had an ongoing affair with her? Mr. Nelson: I'm going to object on the grounds of relevancy. The witness has already answered questions about what he did on duty, what happened at the jail. And this is not reasonably calculated to lead to the discovery of admissible evidence, and I'm going to instruct him not to answer that. Ms. Lemanczyk: You're going to instruct him not to answer that? Mr. Nelson: Correct. Ms. Lemanczyk: Can you Page 34 certify that question just for the record, please? The Reporter: Yes. Questions By Ms. Lemanczyk: Q. You've recently visited Ms. Ashabranner, have you not? Mr. Shaunessy: Let me object. He's not my witness and I'm not going to instruct him, but this is completely irrelevant to any allegation in this proceeding; and I can't conceive how it could lead to the discovery of admissible evidence. Mr. Nelson: I'm not going to instruct him, but I am going to make the same objection. This case is not about Mr. Ligon's personal life outside of the jail. If you have questions that pertain to anything that he did at the jail or while he was on duty, you can ask those all day long and you won't hear an objection from me. If you're going to ask him about things that he did outside of the jail that have no relevance to this lawsuit, then we're going to be here a long time on objections. So I'm going to object on relevancy, and you can go on. Ms. Lemanczyk: So are you instructing him not to answer that? Mr. Nelson: I said I'm not going to instruct him not to answer that. Page 35 Questions By Ms. Lemanczyk: Q. You've recently visited Ms. Ashabranner, have you not? A. No, I have not. Q. You haven't recently talked to her about testifying in this case? A. No, ma'am. Q. Isn't it true that you went over there and kissed her on the forehead and told her, "Thank you for not testifying in this case"? A. No, it's not. Q. Mr. Ligon, you were terminated from Llano County for engaging in sexual intercourse with an inmate; is that correct? Mr. Shaunessy: Let me object to the question in that you may know what you're talking about and he may even know what you're talking about, but I'm not sure what you mean by "sexual intercourse." Questions By Ms. Lemanczyk: Q. Do you understand what I mean by "sexual intercourse," Mr. Ligon? A. No, ma'am. Q. Have you ever inserted your penis in the vagina of a female inmate? Page 36 A. Yes, ma'am. Q. And was that inmate Jeannie Lee Rowley? A. No, ma'am. Q. And who was that inmate? A. Dana Cotton. Q. When did that incident occur? A. While she was incarcerated in Llano County Jail. Q. When was that? A. I do not recall the date. Q. Was it this past year? A. Like I said, I do not recall the date. Q. Was it five years ago? Mr. Nelson: He's already answered he doesn't recall the date. Ms. Lemanczyk: I -- Mr. Nelson: And he wasn't employed there five years ago. So that doesn't make sense. Ms. Lemanczyk: Well, I'm trying to get a time frame. Questions By Ms. Lemanczyk: Q. This is while you were employed in Llano County, correct? A. Yes. Page 37 Q. Did it happen when you first started there? A. I'm not sure of the time frame. If you have some document that can show me when she was incarcerated there, we can narrow it down to that. Q. Did you ever engage in sexual intercourse with Jeannie Lee Rowley? A. No, ma'am. Q. Did you ever request sexual favors from Jeannie Lee Rowley? A. No, ma'am. Q. Isn't it true that you put your penis through the bean hole and requested an inmate to perform oral sex? A. No, ma'am. Q. The inmate that you did engage in sexual interecourse, what was her name again? A. Dana Cotton. Q. Dana Cotton? Mr. Shaunessy: Hold on for just a second would you? (Off The Record) Questions By Ms. Lemanczyk: Q. Where did this incident occur? Mr. Nelson: What incident? Ms. Lemanczyk: The sexual Page 38 intercourse with Dana Cotton. Mr. Nelson: Okay. The Witness: In the jail. Questions By Ms. Lemanczyk: Q. Where in the jail? A. In her cell. Q. Who was on duty that night? Mr. Nelson: I think the question assumes facts not in evidence, that it was at night. I don't know when it was. Ms. Lemanczyk: I apologize. Questions By Ms. Lemanczyk: Q. When did -- what time of the day did this incident occur? A. I don't recall. I'm not sure which shift I was working at that time. Q. Do you recall if anyone was on duty with you that evening? A. No, ma'am. Q. Were you the only one on duty? A. Yes, ma'am, I believe so. Q. And how long were you in Ms. Cotton's cell? A. Approximately five minutes. Q. So you engaged in sexual intercourse with Ms. Cotton for five minutes? Page 39 A. No, ma'am. I was approximately in her cell five minutes. Q. Okay. Now, I thought earlier you testified that that's where you engaged in sexual intercourse. Is that correct? A. Yes, ma'am. Q. So if you were in her cell for five minutes, you only engaged in sexual intercourse for five minutes or less; is that correct? A. Yes, ma'am. Q. So you were the only one on duty that night, correct? A. I'm not sure if it was at night. Q. Okay. You were the only one on duty at that time? A. Yes, ma'am. Q. So while you were engaging in sexual intercourse, nobody was watching the jail, is that correct? A. I guess you could say that. Q. Okay. Johnny Pesina was a trustee as an inmate at that time, wasn't he? A. I do not know. Q. Do you recall who was a trustee at that time? A. No, ma'am, I do not. Page 40 (At this time, an instrument was here marked for identification as Exhibit No. 11.) Questions By Ms. Lemanczyk: Q. I'm going to hand you what I've marked as Exhibit 11. Can you identify that document? Mr. Nelson: What she's asking is, have you ever seen it before -- The Witness: No, ma'am. Mr. Nelson: -- when she says, can you identify it. Questions By Ms. Lemanczyk: Q. You have never seen that document before? A. No, ma'am. Q. It was produced as part of your answers to requests that the Plaintiffs made for production of documents. Mr. Nelson: By his attorney in response to a request for production. Questions By Ms. Lemanczyk: Q. And it's your testimony today that you've never seen this document? A. No, ma'am, I have not. Q. Would you agree with me that that appears to be Nathan Garrett's signature at the bottom? A. Yes, ma'am, it does. Page 41 Q. Okay. The memo sets out a conversation or a discussion that happened with Sheriff Garrett. Did you have a discussion with Sheriff Garrett? A. Yes, ma'am, I did. Q. Have you had an opportunity to read this memo? A. Yes, ma'am, I did. Q. Does this memo accurately reflect the events that occurred during that discussion with Sheriff Garrett? A. Yes, ma'am, it does. Q. Okay. It states that Sheriff Garrett asked you what happened between you and a female inmate, Rowley? A. Yes, ma'am. Q. And what did you tell Sheriff Garrett happened -- what happened? A. She had performed oral sex on me. Q. Okay. And where did that incident occur? A. The incident of the oral sex? Q. Yes, sir. A. In the recreation room. Q. And when did that incident occur? A. Sometime during -- during my shift. Q. Okay. Did that happen -- what year did that happen? A. I do not know. Page 42 Q. Okay. So she performed oral sex on you while you were on duty? A. Yes, ma'am. Q. Okay. You requested that she perform oral sex on you; isn't that correct? A. No, ma'am. Q. How did this come about? A. She volunteered it. Q. How did she volunteer it? A. I'm not sure of the exact words, but it was volunteered. Q. Had she requested anything from you in return for that? A. No, ma'am. Q. Was there anybody else in the rec room at the time? A. No, ma'am. Q. Was anybody else on duty at that time? A. No, ma'am. Q. Do you recall if Johnny Pesina was a trustee at that time? A. No, ma'am, I do not. Q. You have no concept of when this incident occurred? A. No, ma'am. Page 43 Q. The memo also states that you admitted to having consensual sex with her one time; is that true? A. The consensual sex would be in reference to the oral sex. Q. Okay. And then it states that you tried one other time but nothing happened? A. Yes, ma'am, I guess. Q. And what did you mean when you told Sheriff Garrett that you tried one other time but nothing happened? A. She had approached me one other time for the same thing. Q. Okay. Did you tell Sheriff Garrett that you both had tried to have it one other time? A. I don't remember exactly what was said. Q. Okay. But you'll agree with me that the memo states that "He stated that they tried one other time but nothing happened"? A. Yes, ma'am. Q. So it's your testimony that she approached you again but you refused? A. I do not remember the circumstances that happened at that time. Q. Did you ever request oral sex from her again after that first time? Page 44 A. No, ma'am, I did not. Mr. Nelson: Just a minute, please. (Brief Interruption) Questions By Ms. Lemanczyk: Q. Were you terminated -- was your employment terminated on April 6th of 1998? A. I do not recall the exact date, but that sounds close to the time. Q. Were you -- was your employment terminated on the same day that you had this discussion with Sheriff Garrett? A. Yes, ma'am, it was. Q. Okay. And what did Sheriff Garrett reply to you when you told him about the incident? A. Can you rephrase the question? Q. Well, he asked you some questions, and you told him what had transpired with Jeannie Lee Rowley, correct? A. Yes, ma'am. Q. And what was his response after you told him what happened? A. He said that something had to be done at that time, and I told him I understood. Q. And did he discharge you at that time? A. Yes, ma'am. Page 45 Q. Is that the first time that Sheriff Garrett ever approached you about the incident with Jeannie Lee Rowley? A. Yes, ma'am. Q. Okay. Did Sheriff Garrett tell you why he was asking you about it now -- at that point? A. No, ma'am. Q. Do you know how Sheriff Garrett found out about it? A. Yes, ma'am, I do. Q. And how did he find out about it? A. Texas Ranger Gordon told him about it. Q. And how did Texas Ranger Gordon know about it? A. I had told him about it. Q. And when did you tell him? A. It was prior to this. Q. Prior to the termination? A. Yes, ma'am. Q. Okay. A. That same day. Q. I'm assuming the date on the memo is correct. On April 6th? A. Yes, ma'am. Q. You told Texas Ranger Gordon on that day? A. Yes, ma'am. Page 46 Q. How did you come about telling Ranger Gordon about it? A. He was conducting an -- or excuse me. I believe he was conducting an investigation on the allegations that had happened in the jail, and this had come about. Q. Do you know when he started that investigation? A. No, ma'am, I do not. Q. This was the first day he had discussed the allegations with you? A. Yes, ma'am. Q. Did you -- A. I believe -- Q. I'm sorry. A. I believe so. I'm not -- I'm not sure if it had been mentioned before. Q. Did you have any discussions with him prior to April 6th of 1998 -- Mr. Nelson: Regarding what? Ms. Lemanczyk: That's going to be one of those tail-whipping ones. It's coming. Questions By Ms. Lemanczyk: Q. -- regarding the incident occurring at the jail with Jeannie Lee Rowley? Page 47 A. Not that I can recall at this time. Q. Did you have discussions with him regarding the rape of Tina Wisdom at the jail? A. Yes, ma'am, I believe so. Q. And when did you have those discussions with him? A. It had been the day that the alleged rape happened -- Q. Okay. A. -- which I believe is September 23rd when it was reported. Q. Okay. And what was your discussion with the Ranger? A. It was -- Mr. Nelson: On which occasion are you talking about? Are you talking about on April 6th or -- Ms. Lemanczyk: On April 23rd -- I'm sorry. September 23rd. Mr. Nelson: Thank you. The Witness: I believe it was involving how Mr. Pesina had gained access into the women's cell. Questions By Ms. Lemanczyk: Q. And what did you tell him? Page 48 A. I don't remember specifically sitting down talking to him. It was an in-general conversation. Q. When you say "an in-general conversation," what do you mean? A. It was not a one-on-one conversation. It was other people around. Q. Who was present? A. To the best of my knowledge, I believe Sheriff Garrett, Melvin Lawson and one of the investigators. I'm not sure which one. Q. Do you recall what time of day this meeting occurred? A. No, ma'am, I do not. It was -- Q. And what was said regarding the admission, Pesina's entry into the cell? Mr. Nelson: The admission? The Witness: Admission? Mr. Nelson: What do you mean? Ms. Lemanczyk: The entry into the cell. The Witness: We were looking at the door, trying to dertermine how it had been gained, and I believe I demonstrated how it had happened. Questions By Ms. Lemanczyk: Page 49 Q. And how did you demonstrate it that it happened? A. By opening the door without a key. Q. And how did you do that? A. With my pocketknife and also with other utensils. Q. What other utensils? A. Utensils that were in the kitchen. Q. And what utensils were those? A. I used a spoon and a kitchen knife and a butter knife. Q. And could you please tell me how you used those utensils to open the door? A. By catching the bottom side of the lock and moving the lock over, you can pull the door open. Q. Okay. Did you discuss anything else with the Ranger at that time? A. Not that I can recall. Q. So Sheriff Garrett was there, Melvin Lawson was there, an investigator was there, you and this Ranger. And you just talked about how to enter into the cell without the keys? A. Yes, ma'am, I believe so. Q. Did you have any other discussions with the Texas Ranger after September 23rd of 1997 -- Page 50 Mr. Nelson: Until what time, Lisa? Questions By Ms. Lemanczyk: Q. -- to April 6th, 1998? A. Not that -- regarding these situations, not that I'm aware of, but Ranger Gordon and I worked in the same building. We would pass and talk. Q. Are you friends with Ranger Gordon? A. Yes, ma'am. I would consider him a friend. Q. And did you socialize with him outside of the workplace? A. No, ma'am. Mr. Nelson: Lisa, how about we take a little quick break? Ms. Lemanczyk: Sure, no problem. (Brief Recess) Questions By Ms. Lemanczyk: (Continued on Ligon Deposition V3)