Lisa McPherson Files - Statement of Joan Stevens

This is the statement of Joan Stevens, who spent time with Lisa McPherson at the Fort Harrison.

                       KANABAY COURT REPORTERS - (813) 821-3320


 1         IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA

 2

 3

 4

 5     _______________________________________________________________

 6

 7                    STATE ATTORNEY INVESTIGATION

 8
                          RE:  LISA McPHERSON
 9

10     _______________________________________________________________

11

12          SWORN
            STATEMENT OF:       JOAN STEVENS.
13
            TAKEN BY:           Mark McGarry,
14                              Assistant State Attorney.

15          DATE:               April 10, 1997.

16          BEFORE:             Lynne J. Ide, RPR, RMR
                                Notary Public,
17                              State of Florida at Large.

18          PLACE:              Office of State Attorney
                                Criminal Justice Center
19                              B200
                                Clearwater, Florida.
20

21

22

23
                         KANABAY COURT REPORTERS
24                TAMPA AIRPORT MARRIOTT (813)224-9500
                ST. PETERSBURG, CLEARWATER (813) 821-3320
25


2

 1    APPEARANCES:

 2

 3    MARK McGARRY, ESQUIRE
      Assistant State Attorney
 4    Attorney for State of Florida.

 5
      ALLAN "LEE" STROPE,
 6    Special Agent,
      Florida Department of Law Enforcement
 7    28870 U.S. Highway 19 North
      Suite 200
 8    Clearwater, Florida 34621

 9
      JORGE CARRASQUILLO,
10    Detective,
      Clearwater Police Department
11    Clearwater, Florida.

12
      ROBERT P. POLLI, ESQUIRE
13    Barnett Bank Plaza
      101 East Kennedy Boulevard
14    Suite 3130
      Tampa, Florida 33602
15    Counsel for the Witness.

16
                ____________________________________
17

18
                       INDEX TO PROCEEDINGS
19
      Examination by Mr. McGarry                Page  3
20    Examination by Agent Strope               Page 26
      Examination by Detective Carrasquillo     Page 37
21    Continued Examination by Agent Strope     Page 51

22

23

24

25


               KANABAY COURT REPORTERS - 813-821-3320


3
 1                        (Witness sworn).
 2                  MR. McGARRY:  Do you want to put something
 3    on the record as you usually do?
 4                  MR. POLLI:  Thanks very much.
 5                  We are here today pursuant to a State
 6    Attorney Office investigation subpoena.
 7                  And I have discussed the protections that
 8    are provided by Florida Statute 914.04 with Miss Stevens,
 9    she understands what those protections are, and we are
10    here to proceed accordingly.
12                  MR. McGARRY:  Okay.
13                         JOAN STEVENS,
14    the witness herein, being first duly sworn, was examined
15    and testified as follows:
16                          EXAMINATION
17    BY MR. McGARRY:
18         Q.  May I call you Joan?  My name is Mark McGarry.
19    I'm a prosecutor.
20             We are conducting an investigation into the
21    death of Lisa McPherson. Your name came up as a person
22    that might have some information relating to her last
23    seventeen days, I believe that was at the church. So
24    we're going to ask you some questions in reference to that
25    involvement.
                            
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 1              Before I do, I would like to get a little
 2    background information on you.
 3              Your birth date is?
 4        A.    June 11th, 1948.
 5        Q.    And where are you from originally?
 6        A.    Originally I was born in Virginia.
 7        Q.    Okay.  And you reside now in Clearwater?
 8        A.    Yes, is that right.
 9        Q.    How long have you lived in Clearwater?
10        A.    Since '93.
11        Q.    Okay.  And the reason -- did you come from
12    Virginia to Clearwater?
13        A.    No, I have lived -—
14        Q.    All over?
15        A.    —— different places, yes.
16        Q.    Okay.  Why did you come to Clearwater in '93?
17    Was that because of the church?
18        A.    I came to work here, yes.
19        Q.    Were you affiliated with the church prior to
20    1993?
21        A.    I have been a church staff member since '75.
22        Q.    Since '75?
23        A.    Yes.
24        Q.    You are a long-timer.
25        A.    Yes.
                            
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 1         Q.   That is like almost the very beginning, right?
 2         A.   No.  It started in '68.
 3         Q.   '68?
 4         A.   Yes.
 5         Q.   Okay.  How did you become involved in the
 6    church, if I may ask?
 7         A.   Well, I was working in New York.  And a friend
 8    of mine introduced me to Scientology.   And I went down to
 9    the organization, and I have been there ever since.
10        Q.   Okay.  When did you become a staff member?
11        A.   Either '75 or '76.  I came on staff in '75.  And then I
12   joined the Sea Org. in '76.
13        Q.   That is 0 R G, I believe?
14        A.   That's right.
15        Q.   Did the church request you transfer to
16   Clearwater sometime before '93, or during the year of
17   1993?
18        A.   Yes.
19        Q.   For what purpose was that?
20        A.   Well, it is simply part of the Sea Org. Part of
21   the church I work for.  Part of the agreement you make is
22   you work wherever you are needed to go, so...
23        Q.   All right.  What duties specifically in '93 were
24   you requested to do in Clearwater as a staff member?
25        A.   I deal with personnel.
                           
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 1         Q.   Okay. So you are upper level as far as moving
 2    people around and personnel staff members, right?
 3         A.   Staff members, that is right. It is not
 4    necessarily moving people around, it is making sure they
 5    are trained for their job, yes.
 6         Q.   Who is your supervisor at the church now?
 7         A.   My boss, you mean?
 8         Q.   Yes, well, boss, supervisor, whatever you want
 9    to call it.
10         A.   Leslie Woodcraft.
11         Q.   Leslie Woodcraft?
12         A.   Yes.
13         Q.   So over the years since 1975 have you taken
14    numerous courses at the church?
15         A.   I have done several, yes.
16         Q.   Have you achieved a certain level?
17         A.   In training? Or processing?
18         Q.   I'm not sure I know the difference, but you can
19    answer both if you would like.
20         A.   It is different. Well, in training I have done,
21    you know, we have these large books, right. And I have
22    been through the full one for the division that I work in,
23    so I have that data, I am trained in that.
24         Q.   Okay. How about as far as teaching, regular
25    teaching courses, have you progressed through certain
                            
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 1     levels in that, as well?
 2         A.   I have trained for the jobs I have done.  We
 3     have courses for every job that a person has. And I have
 4     trained on those.
 5         Q.   Okay.  I'm not sure I ever got an answer as far
 6     as your level of training, as far as courses you have
 7     obtained. Is there a Level 1, 2, 3, 4, 5, up to --
 8         A.   Not exactly.  There is training for executives
 9     and that type of thing. I have Executive Status 1 and I'm
10     what is called, like you get to a level when you do these
11     volumes.
12         Q.   Yes?
13         A.   You reach a certain level that we call a staff
14     status.
15         Q.   I got you.
16         A.   And for me that is Staff Status 3.
17         Q.   Okay.
18                   AGENT STROPE:  Excuse me, I think what you
19     are referring to —— he's referring to the bridge.
20         A.   Training? Technical training?
21                   AGENT STROPE:  Yes, right.
22         A.   No, I haven't done a lot of that at all.
23                   AGENT STROPE:  Thank you.
24     BY MR. McGARRY:
25         Q.   Have your duties changed much from '93 until now
                            
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 1     as far as with the church?
 2         A.   (Shakes head).
 3         Q.   The same stuff?
 4         A.   Yes.
 5                  MR. POLLI:   You have to answer yes.
 6         A.   Yes.
 7     BY MR. McGARRY:
 8         Q.   All right, prior to Lisa being in the cabana in
 9     November of '95, had you ever met her before?
10        A.   No.
11        Q.   You had not? When was the first time you have
12    ever heard her name?
13        A.   Heard her name?
14        Q.   Yes, when was the first time somebody said, hey,
15    Lisa McPherson? How did you become involved in this?
16        A.   I think probably the first time I heard it was
17    the night I was with her.
18        Q.   Okay. Somebody asked you to come see her?
19        A.   Yes. My senior was with her and asked me if I
20    couldn't come and relieve my senior.
21        Q.   Who is your senior?
22        A.   Leslie Woodcraft.
23        Q.   So Leslie Woodcraft was with Lisa?
24        A.   Uh-huh.
25        Q.   And she contacted you and asked if you could
                            
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 1    come relieve ——
 2        A.   Basically take over for her.
 3        Q.   Okay.  And that was the first contact you had
 4    ever had with Lisa McPherson?
 5        A.   Yes, that is right.
 6        Q.   Now, I know you probably had an opportunity to
 7    look as a calendar and discuss with your lawyer, have you
 8    been able to figure out exactly what day that was in
 9    November, or maybe it was even December, I don't know.
10        A.   Not really.  The closest I could get is I know
11    it was a holiday. I'm pretty sure it was Thanksgiving.
12        Q.   Okay.
13        A.   Because I know it wasn't Christmas.
14        Q.   Right.  So that is somewhere around the 23rd of
15    November?
16        A.   Right.
17        Q.   And do you recall what time of day that was?
18        A.   When I was called?
19        Q.   Yes.
20        A.   It was actually quite late at night.   I was
21    working late.
22        Q.   Okay, you got a call from Miss Woodcraft, and
23    she said, "Can you come over and give us a hand?"
24        A.   Yes, basically.  As my boss, right.   I wouldn't
25    have her, like, do that, I would do it for her so she
                         
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 1     wouldn't have to be there.  So she called me and asked me
 2     if I could come over and relieve  her, and I did.
 3          Q.   Okay.  Did she tell you you are coming over to
 4     do what?  Did she tell you what the situation was?  Did
 5     she give you a synopsis of what was going on here?
 6               What did you think you were coming to do?
 7          A.   Well, frankly, I wasn't quite sure because I had
 8     no experience prior with this.   Right?
 9          Q.   With what?  I mean, that is what I want to know,
10    with what?
11         A.   With actually the way it turned out that Lisa
12    was.   I had like never experienced anything like that.
13              Leslie Woodcraft called me and she just asked me
14    if I could come over and relieve her, which I did.
15         Q.   All right.  The question I had, though, I think
16    I probably did not articulate it very well, is when you
17    had the conversation with Leslie, did she tell you —- what
18    did she tell you?   "I am here doing ..." something?
19              I'm trying to get the information of what she
20    told you she was doing.  Did you have any expectation of
21    what you were going into?  What did she tell you this was?
22         A.   What she told me——I knew that Lisa was, you
23    know, she was there, we were taking care of here, right.
24         Q.   That is kind of what I'm getting at.
25         A.   But when I saw Leslie, she basically told me
                           
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 1    that Lisa was, you know, she wasn't, in so many words,
 2    right.  This isn't exact.  That she wasn't like
 3    particularly coherent.  And that the best thing I could do
 4    was just to like be there, you know, not get freaked out
 5    by anything, just be there for Lisa.
 6         Q.   All right.  So it was late at night that you
 7    came over there?
 8         A.   Yes.
 9         Q.   And relieved her?
10         A.   Uh-huh.
11         Q.   And was Leslie there by herself?
12         A.   She was there and Janice Johnson was there.
13         Q.   Okay. And who is Janice Johnson?
14         A.   Janice works with the church.
15         Q.   Okay. In what capacity, as far as you know?
16         A.   She works in our medical liaison office.
17         Q.   Okay. When you came into the room, can you
18    describe the room for me?
19         A.   Sure. Inside there was a bed, it was a double
20    bed just as you come in the door.  Then there was a
21    dresser and a chair.  And then in the left—hand corner was
22    kind of a potted plant.  Then in the back was kind of a
23    dressing room, bathroom, closet.  Then there was kind of
24    like a —— like windows, sliding doors.
25         Q.   Did this room require a key to get into?
                            
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 1         A.   No.
 2         Q.   It was unlocked?
 3         A.   (Shakes head).
 4         Q.   Was there anybody at the door?
 5         A.   There was Sam Ghiarna was outside the door.
 6         Q.   Who is Sam?
 7         A.   He works with the church. He's a staff member.
 8         Q.   What capacity does he work in?
 9         A.   He's right now posted in security.  At that time
10     I don't know.
11         Q.   So you just came, walked into the room?
12         A.   Yes.
13         Q.   In the room there was Janice and Lisa?
14         A.   That's right.
15         Q.   And Leslie?
16         A.   Well, no, because I walked —— I was in a
17     different building, so I walked from the building I was in
18     to the Ft. Harrison, and Leslie met me in basically like a
19     little hallway in the Ft. Harrison building.
20         Q.   Oh, okay. Where in the room was Lisa when you
21     entered the room, if you can remember?
22         A.   I think she was -- I don't know, I think she was
23     like kind of in the middle of the room.
24              There was a chair -- you go in, there was a bed,
25     then a chair in the middle of the room. And I believe she
                             
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 1    was like around the chair, or standing, walking. She was
 2    active most of the time so it is kind of hard to pinpoint
 3    exactly where she was.
 4         Q.  Did she acknowledge your entry?
 5         A.  Mmm, well, in a fashion.   It wasn't like she
 6    went like, "Hi, how are you." That wasn't the case at
 7    all.
 8             But I was wearing a jacket that had a blue
 9    emblem on it.  And she looked at it and she came up and
10    she touched it like that (indicating).  She goes, "Oh,
11    that is beautiful."
12             I mean, if you call that an acknowledgment of my
13    presence, that is what she did.
14         Q.  Did you and Janice Johnson have a conversation?
15         A.  Conversation?  I talked to her a bit.
16         Q.  Okay.   Did she tell you -- did she give you
17    update or status of what was occurring and what you were
18    expected to do?
19         A.  Not exactly like that.   You know, I came in, for
20    example, I heard water running, you know.  And Janice
21    said, "Well, sometimes she likes to go in and run the
22    water. And we let her do that because it seems to calm
23    her down."
24             Or, you know, "We have given her camomile tea."
25             That is about it.
                          
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 1        Q.   But your understanding is you were there for her
 2   assistance and comfort and care, correct?
 3        A.   (Nods head).
 4                  THE REPORTER: Your answer?
 5        A.   Yes.  I'm sorry.
 6        Q.   And would those responsibilities cover, for
 7   example, feeding her or giving her medicine?
 8        A.   Well, I would want to make sure she ate.
 9   Medicine, no.
10        Q.   While you were there did Dr. Johnson administer
11   any care that you observed?
12        A.   Who?
13        Q.   Dr. -- Janice Johnson?
14        A.   No.
15        Q.   So Janice Johnson was just there observing her
16   and looking after her?
17        A.   In fact, she was there briefly, I mean, from the
18   time I got there.  She didn't stay the whole time I was
19   there.  She was there maybe, I don't know, max, half hour.
20        Q.   So how long -- what would you describe this?
21   Some people have described it as a watch, or shift, or
22   this duty.  How long were you there?
23             What would you describe this, as a watch? Or
24   shift? Or duty? Or something to that effect?
25        A.   I don't know, for me personally the word that
                           
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 1    best describes it is watch, but that is only my --
 2        Q.   That is all right.
 3             How long was your watch?
 4        A.   It is really rather hard to judge.  I know I
 5    came in late at night, and I was there until in the
 6    morning. And I think it was around until about ten or
 7    eleven o'clock the next morning.
 8        Q.   So it would have been almost a full twelve
 9    hours?
10        A.   Uh-huh.
11        Q.   Can you describe what went on with Lisa for that
12    twelve—hour period?  What did she do?
13        A.   Well, what she did was talked and moved, and, I
14    mean, continuously, all of the time.  There was like no
15    stop, do you know what I mean?  It was just (gesturing).
16    And, you know, the things she was saying were like -- it
17    wasn't like a conversation or a lecture or, you know, or
18    anything, it was just talk.
19        Q.   Was it your practice, as with some of the
20    others, to not have any direct communication with Lisa?
21    Were you instructed in that fashion?  Or did you not pay
22    any attention to that?
23        A.   No, I didn't have any communication with her.
24        Q.   That is by design, correct?
25        A.   Yeah.
                          
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 1        Q.   At any time during this eleven or twelve hours
 2   or thereabouts did she indicate that she wanted to leave
 3   the cabana area of the hotel?
 4        A.   No.  I mean, it is kind of -- when you say that,
 5   nothing that she did made any sense particularly.  Do you
 6   know what I mean?
 7        Q.   Right, well, all I can do is ask a question.  If
 8   she said, "I would like to leave," you would remember
 9   that, or if she tried to leave, you would remember that,
10   correct?
11        A.   Yes.
12        Q.   Did she do any self-destructive behavior or any
13   violent behavior toward herself or you in your presence?
14        A.   For me, yes.   I was belted a couple of times.
15   More than -— I mean, several.  She at one point came at
16   me, you know that potted plant I mentioned, she came at me
17   with that like (gesturing), you know.  And she was --
18   tried to poke my eye out, I wouldn't have it except I
19   turned my head.  But I had got a nice shiner from that.
20        Q.   How did you react to this?  I mean, what was
21   your response?
22        A.   Well, I didn't do anything, you know what I
23   mean?  It was kind of like the girl was in the state she
24   was in, you know, and I'm sure, you know, did not know
25   what she was doing.  And the most that I ever did was
                              
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 1    deflect, you know.
 2        Q.   Did you ever call Sam to give you a hand?
 3        A.   I did that, yes. Yeah.
 4        Q.   Okay. Did he come in and assist you?
 5        A.   No, he didn't come in.
 6        Q.   So what would be the purpose of calling him?
 7        A.   Well, because there was one point where she was
 8    —— you know how I mentioned there were like glass doors,
 9    and there was one point where she stripped and was
10    standing in front of the window, you know, pulled the
11    curtain open and was standing there.  Then she was like ——
12    I had to close the curtain and get her away from the
13    window.
14        Q.   Right.
15        A.   And then I was standing by the door and she was
16    like about trying -- trying to go out, do you know? And
17    it was no state for her to go out in.  And I asked Sam to
18    help me keep her in at that point.
19        Q.   Okay. So he didn't come in, or he did come in?
20        A.   Well, as far as the need to come to the door,
21    but that is not like in the room.
22        Q.   Okay. Did she ever sleep while on your watch?
23        A.   No. No.  We tried.  Early on, Janice and I
24    actually tried to —- like I think it was Janice, at one
25    point I think we had her in bed for about three minutes.
                          
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 1        Q.  Okay.  Did she ingest any food or fluids while
 2   you were there?
 3        A.  Well, you know, about seven o'clock in the
 4   morning or so I realized she hadn't eaten. And I called
 5   to have somebody bring some food over for her.
 6            And I had like I think we got pancakes or
 7   something that would be simple to eat. But when she
 8   started to eat it, it was like she grabbed it and was
 9   stuffing the whole thing down her throat. It was scary.
10   It wasn't like she was eating like a normal person.
11        Q.  Yes?
12        A.  And I had to take the -- well, I took the
13   plastic fork and spoon and that type of thing away from
14   her because it just appeared she was -- had the capacity
15   to do something destructive to herself.
16        Q.  All right.
17        A.  And some of the pancakes she ate.  But the way
18   she was actually eating it, it was scary. It was like
19   she could like choke herself with it.  So she had a bit,
20   then I took it away because I didn't know what to do at
21   that point, you know.
22        Q.  Okay.  At some point the following day were you
23   -— was your watch relieved by somebody else?
24        A.  Mmm, it was —- I was relieved.  Actually, let's
25   see, Heather Hof came, Rita Boykin came. Yeah, I mean, I
                          
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 1    was relieved. I mean actually toward the end of the time
 2    I was there she was more active and I called for
 3    assistance. Then at that point, you know, I left because
 4    I was actually pretty wiped out --
 5        Q.    Yes?
 6        A.    -— then.
 7        Q.    Was that your only day on this watch?
 8        A.    That is right.
 9        Q.    There apparently was a system in place for
10    taking notes or making reports about shifts.  Did you
11    write a report on this?
12        A.    I don't know of any system. I personally
13    originated a report that I sent to her folder, her
14    confessional folder.
15        Q.    Oh, you did?
16        A.    Yes.
17        Q.    And that was your observations of that night?
18        A.    That is right.
19        Q.    Okay. Have you seen that since you wrote it?
20        A.    No. I wouldn't expect to see it since I sent it
21    to, you know, her confessional folder.
22                  MR. McGARRY: Do we have one of those, Lee?
23                  AGENT STROPE: I don't.
24                  DETECTIVE CARRASQUILLO: Would you look
25    through these reports and see if any of those might be the
                             
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 1   one you are speaking of?
 2   BY MR. McGARRY:
 3        Q.   Yes, see if they're in there.
 4        A.   No, it isn't.
 5        Q.   Okay. In the event that -- do you have any
 6   problem with us looking and reading that report in the
 7   event we obtain it?
 8        A.   Well, it is in a confessional folder. It is
 9   priest penitent data.
10        Q.   So your report went through another channel?
11   Because we received a bunch of reports from a lot of the
12   other caregivers?
13        A.   Right.
14        Q.   And theirs went through apparently another
15   channel than yours. Do you know why yours went to a
16   different area?
17        A.   Because that is where I sent it. There was no
18   system set up at the time I did it, but I'll be glad to
19   tell you anything in there.
20        Q.   Oh --
21        A.  No problem.
22        Q.   But, you know why as investigators we like to
23   have the reports, because obviously it contained
24   information that is more timely. It is obviously about
25   events transpiring now.  And obviously now we are going
                            
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 1   back and using your memory a year and a half later.
 2        A.   You are right, of course.
 3        Q.   Is there anything in those reports you can
 4   recall that I could ask you that would be helpful to our
 5   investigation?
 6        A.   I don't think so. I think the main thing I
 7   communicated in there and had my personal attention on was
 8   just that she needed help, do you know?  I have never
 9   personally seen anyone in that condition before in my
10   life.
11        Q.   And--
12        A.   You know, I mean, it was --
13        Q.   You are referring to her mental state?
14        A.   Mental, yeah. I mean, just like she just didn't
15   stop talking. And it was nothing that really made any
16   sense particularly, you know, just like for hours and
17   hours and hours.
18             Then, you know, things she would do, like go in
19   and turn on the water and listen to it run, or throw
20   clothes in the toilet or in the sink, or whatever she was
21   doing, you know, it was just kind of --
22        Q.   Did you notice any physical aspects to her
23   condition that you thought needed attention, other than
24   her mental state?
25        A.   No, not particularly, other than probably about
                           
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22
 1    —- when I requested assistance, because she was actually
 2    like stronger than me and becoming more than I could
 3    handle because she was quite active.  Do you know how
 4    somebody looks after they have like run a mile, you know,
 5    they are like flushed.  Like that.
 6         Q.  Uh-huh.
 7         A.  Probably around between ten and twelve the next
 8    morning I would say she had that kind of flushed look, but
 9    she had also been like active all night long.
10         Q.  Right.
11         A.  But that was the only thing.   And she was also
12    at that point -- she was like hot.
13         Q.  Were you aware that she was there for I guess
14    the term is isolation, and then if that went well, then a
15    procedure would be implemented called introspective
16    rundown, were you aware that was going to take place?
17         A.  I knew we wanted to get her in session.
18         Q.  Is that what that is called, session?
19         A.  Yes, it is.
20         Q.  Never got there because of her mental status,
21    correct?
22         A.  I don't really know why.
23         Q.  Okay.  Well, if this is the only day you were
24    there, then -- well, let me ask you this.  Did you have
25    any further contact with Lisa after that particular date
                           
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23
 1   you are talking about, presumably Thanksgiving day?
 2        A.   No, I didn't.
 3        Q.   There was a meeting that was later held at the
 4   church after Lisa died, I believe it was called by either
 5   Alain Kartuzinski, or might have been one of the head
 6   security guys, Kellerhous or Baxter.
 7             Did you attend such a meeting?
 8        A.   I'm not exactly clear on what you are referring
 9   to.
10        Q.   Well, there was a gathering of people that were
11   in contact with Lisa presumably to tell them that she had
12   died and that they may be at risk for some reason or
13   another for an infectious disease. And many people have
14   described this meeting and indicated that they wrote a
15   report at such meeting. And I was wondering if you were
16   invited.
17        A.   I went to a briefing. It wasn't —- there was
18   nothing mentioned to me about any infectious diseases. I
19   wrote a separate report.
20        Q.   For that?
21        A.   Yes. Because that was —- that was the night I
22   believe she passed away, right?
23        Q.   Okay.
24        A.   Or something like that.
25        Q.   That would have been December 5th.
                           
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24
 1        A.   Mmm, I don't know.
 2        Q.   Okay.  Well, if I told you that was the day she
 3    died, then that would have been it.
 4        A.   Okay.
 5        Q.   And that report was to Mr. Kartuzinski, right?
 6        A.   No, I wrote it to Marcus Quirino.
 7        Q.   Yes, Marcus Quirino. I knew that.
 8             Do you recall if Mr. Kartuzinski was at that
 9    meeting?
10        A.   I don't know because actually it wasn't like we
11    were all gathered around the table. It wasn't that type
12    of thing. I was asked to come up there, and I saw
13    Mr. Quirino and a couple of other people. It wasn't like
14    a gathering.
15        Q.   And Mr. Quirino's position in the church is
16    what?
17        A.   Right now? He's what we call a director of
18    processing.
19        Q.   And then?
20        A.   He was, Mmm, a deputy executive.
21        Q.   Okay.  Is he still with the church now?  I
22    assume he is.
23        A.   Oh, yes. Yes.
24        Q.   During your period there with Lisa did you
25    notice that she had any visitors either from her family or
                           
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25
 1   anybody else from the church that came to visit her that
 2   you ever mentioned aside from Janice and Leslie, and I
 3   think you mentioned Heather and Rita, anybody else that
 4   you noticed that had contact with Lisa during that
 5   twelve-hour period?
 6        A.  You mean other than staff members that were with
 7   her?
 8        Q.  Right.
 9        A.  That I know about?
10        Q.  Other than the ones you just mentioned.
11        A.  I mean, there were other staff members that came
12   like later on, like Paul Kellerhous, but no one outside
13   the church I know of.
14        Q.  Okay.  Are you aware of Lisa going home to get
15   some clothing? I know she went -- at least I think she
16   did, somebody had to go get some additional clothing from
17   the clothing she had from the day of this accident that
18   precipitated this cabana stay. Do you know anybody who
19   did that, accompanied her home to get her clothes or her
20   personal effects?
21        A.  I know nothing about that.
22        Q.  Okay.  Is there anything else that you can
23   recall about this twelve—hour period or this —— around
24   this period of time that I have neglected to ask you that
25   you might find important or relevant toward this
                          
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26
 1    investigation?
 2        A.   I don't think so, Mr. McGarry.
 3                 MR. McGARRY:  Okay, would you afford the
 4    same courtesy to these detectives. They might have some
 5    questions to ask you that I forgot.
 6                 THE WITNESS:  Yes, of course.
 7                         EXAMINATION
 8    BY AGENT STROPE:
 9        Q.   Do you have any medical training?
10        A.   No, I don't.
11        Q.   None whatsoever?
12        A.   Uh-uh.
13        Q.   So you don't know why you were picked for this
14    duty?
15        A.   I was picked because I'm a staff member. And we
16    felt our responsibility to help this person.
17        Q.   Okay, but you have no medical training?
18        A.   No, I don't.
19        Q.   Now, you said to Mr. McGarry that you had no
20    experience dealing with people the way that Lisa was.
21    Could you explain that for me more?
22        A.   Lisa —— well, yes, I mean, I don't know what
23    else to say other than I have never met a person that was
24    in that condition before or come across it. I don't know
25    if you have or —— do you know what I mean?
                            
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27
 1             But the only way I can describe her is she
 2   wasn't there, she was just talking, talking, talking,
 3   talking, talking, talking; moving, moving, moving, moving,
 4   moving.  There was like giving herself —- there was no
 5   direction to what she was doing, no sense to it.
 6        Q.   So in your twenty-one years with this
 7   organization, have you ever before been involved in a
 8   watch?
 9        A.   No.
10        Q.   Have you been involved since?
11        A.   No.
12        Q.   So this is the first incident of this kind you
13   have been involved in?
14        A.   That is right.
15        Q.   Who was in charge of this watch, do you know?
16   Who was the person making schedules or doing whatever had
17   to be done to make sure the job would get done?
18        A.   I am really not sure.  I have no idea.
19        Q.   Are you familiar with Janice Johnson?
20        A.   I know her.
21        Q.   Are you a friend of Janice Johnson?
22        A.   Friend?  I know her as a staff member.
23        Q.   Do you know Janice Johnson as a medical doctor,
24   as a doctor?
25        A.   No.
                           
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28
 1        Q.   You described the bed, the room.  Could you do
 2    that, describe that again for me? Was it like a hotel
 3    room?
 4        A.   Yeah. Yes.   Yeah.
 5        Q.   Was there a telephone?
 6        A.   Mmm, I don't remember.
 7        Q.   Was there a double bed?
 8        A.   There was.
 9        Q.   One double bed?
10        A.   I -- well, you know, I know -- what I recall
11    when I came in, I know there was one, you know. There was
12    the door, and I have a later recollection of, toward the
13    end when I left, the bed was in a different location. So
14    I tend to want to think we moved it, rather than there
15    were two. I think there was only one but I think it got
16    moved.
17        Q.   So it was a double bed?
18        A.   Yeah.
19        Q.   I mean, you were to spend the night there,
20    right? Did you spend that night that you were there,
21    whether it be Thanksgiving or whatever, by yourself?
22        A.   Mmm, Janice Johnson was there for a bit. And
23    then she left shortly after I got there.  For several
24    hours I was alone. And then toward the morning there were
25    people that came in.
                            
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29
 1        Q.      Who would those people be?
 2        A.      At first when Lisa was getting more active I
 3    asked for assistance and there were two maids, hotel
 4    maids, that were there.    And they basically came in and
 5    were there for a bit.    Then Barbro came.
 6        Q.      Do you know the maids' names?
 7        A.      No.
 8        Q.      You say she got more active.  Was there a time
 9    when she was sleeping?
10        A.      There was never a time when she was sleeping.
11        Q.      She was just more active than other times?
12        A.      Yes.
13        Q.      Was there a time when she would sit on the bed,
14    lay on the bed?
15        A.      Mmm, no.  I mean, she wouldn't —— there was no
16    time when —— as I said, maybe once we got her to lie down
17    for about three minutes and that was it.    There was a
18    chair she would sit in, sometimes she would sit in that
19    chair.    But —-
20        Q.      Do you remember the number of this room, what
21    room that was?
22        A.      No, I don't.
23        Q.      Describe to me how you get there.
24        A.      Because I know generally where it is, and there
25    is, Mmm, when you come through the Ft. Harrison, there is
 
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30
 1    a breezeway, right, and like it is where the poolside
 2    cabana is. And that is where I met Leslie Woodcraft and
 3    she took me to the room.
 4        Q.   Which way did you go to the room?
 5        A.   I came past -- well, past the poolside cabana,
 6    down the little way, then turned, well, turned that way,
 7    (indicating).
 8        Q.   Turned right?
 9        A.   Yeah.
10        Q.   Now, Sam Ghiarna was outside the room?
11        A.   Uh-huh.
12        Q.   Yes?
13        A.   Yes.
14        Q.   Was he dressed in a security type uniform?
15        A.   Oh, I don't know.  I don't remember.
16        Q.   You don't remember that?
17        A.   No.
18        Q.   You say you had to call him into the room one
19    time?
20        A.   Uh-huh.
21        Q.   What was that for?
22        A.   That was shortly after Lisa had stood in the
23    windows naked and then was just trying to leave. And as I
24    recall, she was about half dressed at the time. And she
25    was——

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31
 1         Q.  So she was standing in the window naked, she
 2    tried to leave and she was half dressed?
 3         A.  Yeah, half or full, I don't really recall except
 4    I know I had my attention to that fact.
 5         Q.  Well, she was either naked or she was half
 6    dressed.
 7         A.  Yes, you are right. Like either I got some
 8    jeans on her or something, but she was like -— in any
 9    case, she wasn't presentable is the main point.
10         Q.  Did you call Sam to help you with her and not
11    allow her to leave?
12         A.  I asked him to help me, yes.
13         Q.  Did you feel at this time that Lisa needed any
14    medical attention, not psychiatric but medical attention?
15         A.  I had no indications that she needed medical
16    attention.
17         Q.  And you were struck by her several times, you
18    said?
19         A.  Yes.
20         Q.  Were you by yourself when that happened?
21         A.  Yes, several times.
22         Q.  There was no one in the room with you when that
23    happened?
24         A.  No.
25         Q.  Did you call for help when that happened?

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32
 1         A.   No.   It wasn't like -- I would have called for
 2    help if she had like grabbed my throat or something like
 3    that.  She didn't do that.  But she did like take a
 4    wallop, boom (indicating).
 5         Q.   But you could —- Sam was outside the door,
 6    right?
 7         A.   Yes.
 8         Q.   Did you ever have to subdue her, either alone or
 9    with someone else?  Other people have told us they have
10    had to.
11         A.   Well, at one point she went into the bathroom.
12    And she would go in and out of the bathroom. And, Mmm, I
13    heard something break in there.  And I was very concerned
14    that she would like cut herself, hurt herself.
15              And I went and took her out of the bathroom.
16    forced her out because there was like broken plastic or
17    something on the floor, and she wasn't in any condition
18    where she would see it.   She could have stepped on it, she
19    could have jabbed it -- I don't know.
20         Q.   So it was broken plastic on the floor?
21         A.   Plastic or glass.  There were things around.
22         Q.   So did you get that cleaned up?
23         A.   Yeah.   Yup.
24         Q.   Have you gone over your testimony today here
25    with anyone other than your attorney?

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33
 1        A.   No.
 2        Q.   Is the term "priest penitent privilege"
 3    something used often?
 4        A.   No, that is only because I'm usually with staff
 5    who have the same idea and concept so it doesn't come up.
 6    Do you know what I mean?
 7        Q.   So you haven't discussed your testimony with
 8    anybody other than your attorney?
 9        A.   No.
10        Q.   Have you gone over your reports before today?
11        A.   What reports?
12        Q.   The reports you wrote?  You said you wrote a
13    report concerning your Thanksgiving day watch with Lisa.
14    Did you go over that report for today's testimony?
15        A.   I sent that to the PC folder the day I did the
16    watch.
17        Q.   But you haven't seen it since?
18        A.   No, I haven't.
19        Q.   Was there a reason that you sent your report to
20    that file and everyone else sent their reports to Alain
21    Kartuzinski?
22        A.   I have no idea.
23        Q.   Did anybody tell you to write a report about
24    this?
25        A.   No.   It just seemed like the right thing to do.
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34
 1        Q.   Did Lisa ever tell you, "I want to leave, I'm
 2    out of here, I'm leaving"?
 3        A.   She never said anything coherent. That would
 4    have been coherent.
 5        Q.   What if she would have said, "I'm out of here,
 6    bye, I'm leaving"?
 7        A.   I don't know.   It is -- I -- I have no way to --
 8        Q.   Would you have let her go?
 9        A.   Let her go? I have no idea what I would have
10    done. She wasn't —— the state she was in, it would have
11    been dangerous for her to go out.
12        Q.   Did anybody tell you not to let her go out?
13        A.   No.
14        Q.   You said Mr. Kellerhous came there. What was
15    his duty there?
16        A.   He came because around the time he came Lisa was
17    getting far more active than I was able to handle, far
18    more. And it was getting to the point being dangerous for
19    her.
20             For example, you know, as I said, she would
21    leave the water running, right? And we had tile floors in
22    there, and water had like gone all over the tiles, and she
23    came running out and slipped. And, you know, it was just
24    like I could not handle that.
25             And at one point she jumped on the bed, she
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35
 1     cracked the --
 2          Q.  So why -- why --
 3          A.  So I asked Paul Kellerhous to help me because I
 4     could not.
 5              And by the time he came in, you know, she was
 6     like —— I mean, he helped, he did help, definitely, subdue
 7     her, because I could not.
 8          Q.  Tell me what he did.
 9          A.  Mmm, well, he came in.   She was -- the first
10    thing that happened, he went over, she had like actually
11    grabbed a pen out of his shirt pocket and was going to go
12    to stab him with it.   He deflected that like put his arms
13    around her.
14             Then he put her down on the bed.  Right?  Held
15    her down. She was close to the -- at that point was close
16    enough to the wall that she was actually banging her head
17    against the wall.   So we moved the bed back so she
18    wouldn't hurt herself, right.
19         Q.  How long was she subdued there before she calmed
20    down?
21         A.  I don't know when she did calm down, sir.  I
22    have no idea.  I know that ——
23         Q.  Well, how long did Mr. Kellerhous hold her down?
24         A.  He was there -- it is really rather vague.  I
25    don't recall exactly.   I would say an estimate, about
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36
 1    forty-five minutes to an hour.
 2         Q.  So he held her down for forty—five minutes to an
 3    hour before she calmed down?  Did you help him do that?
 4         A.  There were three of us.
 5         Q.  Who is the third person?
 6         A.  What occurred, I called for Paul Kellerhous.  He
 7    came in and he helped like put her down in the bed.
 8    Right?
 9             Then Barbro was there, she had come in about
10   seven o'clock with me. And then a little bit later but
11   while Paul was there and Barbro, Heather Hof came in and
12   also Rita Boykin.  Not all those people were all holding
13   her at once. And also there was another, umm, Alphonso
14   Barcenas.
15        Q.  So everyone was there?
16        A.  Everyone   was there.   And at the point when Lisa
17   was most active and we had to like hold her down on the
18   bed literally, Paul was, umm, —— at first it was Paul, and
19   he held her down, and Alphonso had her feet because she
20   was kicking madly.  Right?
21            Then it kind of phased over to, umm, Barbro and
22   Paul, then Heather and Barbro, then me, Heather and
23   Barbro, then Rita came in.  So kind of like in that short
24   time sequence it is those kinds of shifts, because I was
25   actually trying to get out.
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37
 1          Q.   When you said she took her clothes off and stood
 2     in front of the window you called Sam, why didn't you call
 3     Sam this time?   Why did you call Mr. Kellerhous?
 4          A.   Mmm, no real reason other than I have known Paul
 5     for like many years and -— and I just know him.
 6          Q.   Is Kellerhous Sam's senior?
 7          A.   Uh-huh.
 8          Q.   So you called him instead of Sam?
 9          A.   Yes.   Not necessarily because he was senior.
10         Q.   How did you call him?
11         A.   I asked Sam to please get him.
12                   AGENT STROPE:  I don't have anything else.
13                           EXAMINATION
14    BY DETECTIVE CARRASQUILLO:
15         Q.   I have a couple questions.
16         A.   Sure.
17         Q.   At the beginning of the deposition you stated
18    that the first time you heard or met Lisa was the 23rd,
19    which you believe was Thanksgiving, it was a holiday, is
20    that correct?
21         A.   Yes.   I mean, other than I may have heard her
22    name at graduation or something.
23         Q.   Then later on you stated you knew she was there.
24    When you were asked more questions you said "I knew Lisa
25    was there."
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38
 1              How did you know that if the first time you
 2    heard her or met her was on the 23rd of November, how did
 3    you know Lisa was already there?
 4         A.   Umm, it is not uncommon to know if staff have to
 5    do a watch.  It is not necessarily that you know exactly
 6    who it is.
 7         Q.   Okay.
 8         A.   You just know it is occurring because staff
 9    members are asked to do it.
10         Q.   When did you find out that Lisa was there then,
11    if you knew it prior to the 23rd, what day was that?
12         A.   I don't know, sir.
13         Q.   A week before?
14         A.   I have no clue.  It is something that, you know,
15    you know it is occurring because I -- I deal with staff
16    members, and if staff members have to go off and help
17    somebody in a case like this I recognize it because
18    they're not there.  That is how I would know. Do you
19    understand what I mean?
20         Q.   But you would know who the person was in the
21    case?
22         A.   Not necessarily.
23         Q.   Okay, so you said your job is staff personnel?
24         A.   Yes.
25         Q.   Expound on that a little bit.
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39
 1        A.   Okay.  So I'm responsible for making sure that
 2    new staff, when they come in, they get like basic
 3    training, organizational training, they get put on correct
 4    posts, something like personnel director, basically, all
 5    right? Then they get trained for the job they are on.
 6        Q.   So if they were assigned a watch, you would make
 7    sure they got to that watch?
 8        A.   No, that is not necessarily my job.
 9        Q.   Okay.  How many more times did you see
10    Dr. Johnson that night?
11        A.   Janice?
12        Q.   Yes.
13        A.   Just that once.
14        Q.   And she never came back?
15        A.   No.
16        Q.   You only did it for one day?
17        A.   That is right.
18        Q.   Okay.  And you said Sam was outside the door but
19    you don't recall what uniform he had on or if any uniform?
20        A.   That's right.
21        Q.   Okay.  How did you call Sam?
22        A.   How did I call him?
23        Q.   Well, I want to make sure I picture this
24    correctly. You got Lisa taking swings at you, she struck
25    you a couple of times, she tried to hit you with a potted
                          KANABAY COURT REPORTERS - 813-821-3320

40
 1    plant, and you are calling that active. I would call that
 2    violent. Was she violent?
 3        A.   If you want to call it that, that is fine.
 4        Q.   Well, let's look at her actions. Were her
 5    actions violent?
 6        A.   To me violent is something different. To me
 7    violent is coming at me with a knife. Hitting me, it is
 8    -- that is the way she was.
 9        Q.   So she hit you?
10        A.   Uh-huh.
11        Q.   She tried to hit you with a potted plant and she
12    struck you several times?
13        A.   Yeah.
14        Q.   Was she being violent?
15        A.   When you say that, it -- it denotes a concept of
16    her being that way on a continuous basis, which wasn't the
17    case.
18        Q.   For the time she was doing it?
19        A.   For the time she was doing it, I guess you could
20    call it violent.
21        Q.   Is that when you called Sam, when she was acting
22    like that?
23        A.   When I was concerned that it would start to get
24    worse, yes.
25        Q.   How did you call him? Did you scream?
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41
 1        A.    No, I opened the door and I said, "Can you help
 2   me?"  It wasn't —— you know, it wasn't like "Hey!"
 3        Q.    So you were able to break away from Lisa, come
 4   over to the door, open the door and call Sam, and she
 5   stayed where she was at?
 6        A.    Umm, I don't recall that.   She was moving
 7   around.  She was constantly moving.
 8        Q.    Okay, Sam comes into the room, and I want to
 9   make sure I'm picturing this correctly.    You are telling
10   me she's out of it, being irrational, swinging, she's just
11   acting really bizarre, correct?
12        A.    Uh-huh.
13        Q.    Sam comes into the room, doesn't say a word and
14   she immediately calms down, is that what happened?
15        A.    No, not at all.
16        Q.    What happened?
17        A.    What happened, the time when Sam came in, it was
18   actually like this.   She was -- actually, she was near the
19   door.   All right?
20        Q.    All right.
21        A.    Because she had been standing in that window,
22   that large window that faces out onto the sidewalk, right.
23   And I was standing near the door.    So it was like this,
24   like here is the door (gesturing), here are the windows,
25   here is the bed.   Lisa was standing here.   I was standing
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42
 1     by this door, and Sam was out here.
 2              So he was like right there, right? So it wasn't
 3     like I had to go, "Sam!" What he did basically is helped
 4     me move her body back into the room.
 5         Q.   Well, if I remember correctly you said he didn't
 6     come into the room, he just opened the door and stood by
 7     the door and looked in.
 8         A.   I didn't say that.
 9         Q.   No?
10         A.   No.  He -- when I called for help and she was
11     going out, right --
12         Q.   She was going out the door?
13         A.   Yeah.  It was like she reached for the door
14     knob, right? And I was like at that point a bit freaked
15     out, right? So I did ask Sam for help.
16         Q.   And he stopped her from going out the door?
17         A.   Yeah, he put her back in.
18         Q.   Did Sam stop her from going out the door?
19         A.   Yes.
20         Q.   Okay.  So you and Sam did not allow her to go
21     out the door, yes, or no?
22         A.   In that state, we did not allow her to go out,
23     right.
24         Q.   You mentioned earlier when you were talking to
25     Agent Strope that she was partly dressed and that she
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 1    wanted to leave, is that correct?
 2         A.  Uh-huh.
 3                  THE REPORTER:   Your answer?
 4         A.  Yes.
 5         Q.  Did she tell you she wanted to leave?
 6         A.  She never —— no, it was never like she, you
 7    know, she goes, "I want out of here, let me leave."  It
 8    was just total like impulse after impulse after impulse.
 9         Q.  Well, how did you know she wanted to leave?
10         A.  She grabbed the door knob.
11         Q.  So by her actions, sometimes the actions speak
12    louder than words?
13         A.  That is right.
14         Q.  So by her actions it told you that she wanted to
15    leave?
16         A.  Uh-huh.
17         Q.  Did she get dressed herself, or did you dress
18    her?
19         A.  Umm, I am thinking, because there were more than
20    one time when she took off her clothes.
21         Q.  We are talking about this time when she wanted
22    to leave out the front door.  Did she dress herself, or
23    did you dress her?
24         A.  I am not totally certain on that.   As I recall,
25    I believe that she had put on blue jeans, but that is all.
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 1        Q.   Well, it would make sense if she wanted to leave
 2    she would get dressed.
 3        A.   Well, she would have put on a shirt, too.
 4        Q.   Did she have an opportunity to put on a shirt?
 5        A.   She had plenty of clothes in there.
 6        Q.   Did she have an opportunity to put on a top, a
 7    shirt, or did you stop her from putting on a top or shirt?
 8        A.   Certainly not. She put on her blue jeans.
 9        Q.   But you did stop her from going out the door?
10        A.   Yeah, she was half naked.
11        Q.   Okay, if you had a problem with Lisa, who would
12    you call?
13        A.   I don't really know. That was why I asked for
14    Paul.
15        Q.   Now, when Mrs. —— Janice, I call her
16    Dr. Johnson, when she briefed you, she did brief you a
17    little at the onset when you took over the watch?
18        A.   Briefed me? Yeah, that they gave her camomile
19    tea and—-
20        Q.   Did she tell you, "If there is a problem I want
21    you to call me," or, "I want you to call Paul," who did
22    she tell you to call if there was a problem?
23        A.   That didn't come up.
24        Q.   There was no ground rule laid down if you were
25    having a problem to contact somebody, a problem you
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 1   couldn't handle, to contact somebody?
 2        A.  Didn't come up at all.
 3        Q.  Was Lisa screaming?  Was she screaming at the
 4   top of her lungs?
 5        A.  No.
 6        Q.  When they were trying to subdue her, was she
 7   screaming?
 8        A.  She was I could say —- maybe she was —— well, I
 9   don't —— no, not screaming, she was never like screaming.
10   She just talked.
11        Q.  Well, let's just picture you for a second.  You
12   have five people trying to hold you down, wouldn't you say
13   "Get off me," or at least make that being vocally known?
14   And she was being vocal?
15        A.  Totally, didn't stop talking.
16        Q.  So her voice didn't escalate when they were
17   trying to hold her down?
18        A.  Well, it is not that it was ever calm, do you
19   know what I mean? It was ——
20        Q.  Was it loud?
21        A.  Yeah, but that wasn't different from the way it
22   was before. She may have gotten a bit louder or
23   something, you know, but it wasn't —— it was tense the
24   whole time.
25        Q.  Was her voice loud enough to be heard outside
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 1    the room by Sam?
 2        A.   I don't know.
 3        Q.   Do you think it could have carried through?
 4        A.   I have no idea.
 5        Q.   Was it that loud?
 6        A.   I have no idea.
 7        Q.   You said you wrote a report and sent it to the
 8    confessional folder, and I know Lee touched on this a
 9    little bit, but that report was dealing strictly with her
10    behavior that night and her activities?
11        A.   Um-huh.
12        Q.   Why her confessional folder?
13        A.   Well, it seemed to me that is the place it ought
14    to go.
15        Q.   Okay, why? Explain to me why.  Why would you --
16    what would they do with it there? What would be the next
17    step?
18        A.   Well, if it had been planned -— we had been
19    trying to get her in session, then that data would be
20    needed.
21        Q.   Then why didn't all of the other reports go
22    there if the idea was to help her down the road?
23        A.   I don't know.
24        Q.   Never asked?
25        A.   No.  I mean, I did that off my own volition and
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 1     that is where it should go.  No one told me to write a
 2     report, or if I did, where to send it.
 3          Q.   Okay.  You said that when you saw Lisa, it kind
 4     of surprised you because you had never seen anybody like
 5     that, is that correct?
 6          A.   Uh-huh.
 7          Q.   They need you to answer out loud.
 8          A.   Yes.
 9          Q.   And you said she needed help, in your
10    estimation?
11         A.   That is right.
12         Q.   What kind of help?
13         A.   She at least -- I have really no clue.  I'm not
14    trained in handling somebody like that particularly. I
15    have never come across it so it would be hard for me to
16    say what kind of help she needed.   I know minimally just
17    as a person she should have somebody with her.
18         Q.   Okay.  You said, and I'm only asking you to
19    explain your adjectives to me, okay?   You said in your
20    opinion she needed help?
21         A.   Uh-huh.
22         Q.   In your opinion, what kind of help did she need?
23         A.   Help in the sense that -- well, I don't know,
24    what is the definition of help, you know?  When somebody
25    is stressed, even if you have somebody there with you, it
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 1    is helpful.
 2        Q.   So --
 3        A.   That is what I mean.
 4        Q.   Did she need more help than she was getting?
 5        A.   I have no clue.
 6        Q.   It is your statement, I'm just trying to find
 7    out, did she need more help than was there at that time,
 8    in your opinion? Because you are the one that said, "Boy,
 9    I looked at her and she needed help." More than was there
10    at the time?
11        A.   I actually don't have any way to judge that. I
12    don't know.
13        Q.   Then why would you make that statement?
14        A.   Because from my —— my own statement what I mean
15    by help is that at least to be there for her.
16        Q.   Well, she was receiving that?
17        A.   Yeah.
18        Q.   You were there for her?
19        A.   That's right.
20        Q.   Janice was there for her?
21             Why would you still say she needed help,
22    although she was receiving what you said she should get?
23        A.   Because she —— she obviously wasn't there as a
24    person. That was why I would say she needed help. Anyone
25    who has, you know, got themselves into the position where
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 1    they were in the state that she was needed some kind of
 2    assistance.
 3         Q.  Okay.  And physically how was she?
 4         A.  How do you mean?
 5         Q.  How did she look to you physically?
 6         A.  Physically, she looked healthy.
 7         Q.  Did she have any bruises on her?
 8         A.  No.
 9         Q.  She was smacking her head against the wall, she
10   hit you. You said she slipped on the floor?
11        A.  Yes.
12        Q.  And not a bruise?
13        A.  Now, wait a minute, because I am under the
14   impression you are asking me when I first came in.
15        Q.  I'm asking you physically --
16        A.  Through the whole thing?
17        Q.  At any time what was her physical condition
18   like?
19        A.  Well, active.  Totally active all of the time.
20        Q.  Any bruises on her body?
21        A.  Mmm, bruises?  I don't know.  She fell and
22   slipped and hit her head on the floor and she may have
23   gotten some kind of bruise from that, but that would be my
24   assumption.
25        Q.  How did she hit you?  Describe that to me, the
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 1    actual strike. How did you get hit?  What did she hit you
 2    with and how, with what?
 3        A.   In the face.
 4        Q.   With what?
 5        A.   Her hand.
 6        Q.   Closed?  Or open?
 7        A.   No, wide open, full force.
 8        Q.   One time?  Two times?  Three times?
 9        A.   No, more like, I don't know, six to eight.
10        Q.   She slapped you six to eight times in the face
11    and you never called Sam for help?
12        A.   It happened once, I mean, you know, in the unit
13    of time she would do it and then stop and go on to
14    something else, so it wasn't six or eight in succession,
15    do you see what I mean?  It wasn't like she had me in a
16    corner and was beating me up.
17             It would come in the middle, she would be
18    talking, talking, all of a sudden boom, then talk, talk,
19    talk, talk, talk.
20        Q.   What did she say when she slapped you?  "I want
21    out of here"? "I'm pissed off at you"?  "I hate you, you
22    make me sick"? Anything like that?
23        A.   No, it was just part of the continuous whatever
24    it was that she was talking. You know, it was just words,
25    words, words, then it would calm ——
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 1         Q.  But you don't remember none of the words?
 2         A.  No.
 3         Q.  Couldn't even begin to tell me words?
 4         A.  Well, one phrase that came up that she said a
 5    lot is "I'm having a bad hair day."
 6         Q.  She's having a bad hair day?
 7         A.  Yeah.
 8                  DETECTIVE CARRASQUILLO:  I don't have any
 9    more questions.
10                  AGENT STROPE:  Just one.
11                     CONTINUED EXAMINATION
12    BY AGENT STROPE:
13         Q.  What do you think, personally think, should have
14    been done differently here?
15         A.  I have no clue.
16         Q.  Do you have any idea?
17         A.  No clue.  No idea whatsoever.
18         Q.  And you haven't talked your testimony over here
19    today with anyone other than your attorney?
20         A.  No, I haven't.
21         Q.  Until today, back to the day you wrote the
22    report for Mr. Quirino, you haven't discussed this case
23    with anybody?
24         A.  No.
25         Q.  Have you discussed Lisa with anybody?
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 1         A.  Umm, no.
 2         Q.  So nobody has discussed Lisa with you since she
 3    passed away?
 4         A.  I am thinking.  No.  I think I might have
 5    probably asked once or twice how she was doing after ——
 6    like days later. But --
 7         Q.  But after she died you haven't talked about her
 8    since then with anybody?
 9         A.  Umm, not —— I don't recall having done that.
10         Q.  Has your attorney discussed with you the meaning
11    of the word "perjury" and its consequences?
12         A.  I know what it is.
13                  AGENT STROPE:  Okay, I don't have anything
14    further.
15                  MR. McGARRY:  All right. Thank you.
16             ____________________________________________
17             WHEREUPON, THE STATEMENT WAS CONCLUDED

18             _____________________________________________

19

20

21

22

23

24

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 1                          CERTIFICATE OF OATH

 2    STATE OF FLORIDA        )

 3    COUNTY OF PINELLAS      )

 4             I, the undersigned authority, certify that JOAN
     STEVENS personally appeared before me and was duly sworn.
 5
               WITNESS my hand and official seal this 10th day
 6   of April, 1997.

 7

 8                              (signature)
                              LYNNE J. IDE, RPR, RMR
 9                            Notary Public - State of Florida.

10                                       LYNNE J.IDE
                                      COMMISSION # CC 467604
11                                    EXPIRES JUN 14,1999
                                           BONDED THRU
                                  ATLANTIC BONDING CO. INC.
12                    REPORTER'S CERTIFICATE

13   STATE OF FLORIDA         )

14   COUNTY OF PINELLAS       )

15             I, LYNNE J. IDE, Registered Professional
     Reporter, certify that I was authorized to and did
16   stenographically report the statement of JOAN STEVENS; and
     that the transcript is a true and complete record of my
17   stenographic notes.

18             I further certify that I am not a relative,
     employee, attorney or counsel of any of the parties, nor
19   am I a relative or employee of any of the parties'
     attorney or counsel connected with the action, nor am I
20   financially interested in the action.

21             DATED this 10th day of April, 1997.

22
                                 (signature)
23                            LYNNE J. IDE
                              RPR, RMR.
24

25