40

39


of you as the security chief?

A.
My understanding was she had some kind of
problem and she needed -- I got this from Alain. She
needed some rest or some quiet place to recuperate so
that she could come out of whatever it was she was in.

Security involvement, like I mentioned before, if -- if
there was -- if she posed some kind of physical threat
to herself or like harm
herself or harm somebody else,
then we would be involved in that aspect of it, too.
Again, if -— if some assistance was required on ——
let’s say she asked for something, a hamburger or
something. We’d possibly get that, too, see.

The other aspect -- and I don’t know if I
mentioned this or not. If there was a lot of noise, we
would quiet it down so she could sleep or rest.

Q.
Okay. In your report you wrote down here
that you were told that she punched somebody out.

A.
Yep.
Q.
Were you concerned about that as far as the
secured level? You know, you just said that it would
be your responsibility to -- if she’s gonna hurt
somebody. Now, you’ve written down here that she
punched out a caretaker.

A.
Right.
Q.
Did you make any plan at that time if
KANABAY COURT REPORTERS

40