Strojnik v. Costar Realty Information, Inc. et al

Filing 83

Strojnik v. Costar Realty Information, Inc. et al

Doc. 83 Att. 4

EXHIBIT 5

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IN THE PIMA COUNTY JUSTICE COURT TABLE OF CONTENTS

R=
STATE OF ARIZONA, Plaintiff, vs. FRANK SANCHEZ, Defendant. No. DR03-312038

l\12ll.L.i2005
Bench Trial
Petitioner's Witness

-

Karl

James

Woolridge

Direct

Examination

.......
..,.......,
21

Cross-Examination Tucson, AprilS, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 TRANSCRIPT OF PROCEEDINGS Ari zona 2005 Redirect Rebuttal Examination Direct

'9
. ...... ..,.

Examination.

138 145 150

10 11 12 13
H 15 16 Defendant's

Rebuttal Rebuttal Petitioner's

Cross.Examinadon. Redirect

Examination. p, Schranz

Witness

-

John

Direct

Examination

......

50
55

Cross-Examination

Redirect Examination.
Witness. Lucy

...,

70

Martinez

17 18
19 20

Di rect Examinat ion Cross-Examination Redirect Examination

,.....

.......

78

96 105

Recross-Examination. . . . . . .
Defendant's Witness Direct

105

21
22 23

-

Patricia

Gallegos

Duran 108 122 127

Examination

..........
.....,........

Cross-Examination Redirect Examination

2.
25

2.
25

.....,....

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TABLE OP r:DNTENTS

iv

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Defendant's Witness' Direct

-

Frank

Sanchez , . . . . .

APPEARANCES 129 13. 137 169

Examination

Cross-Examination Redirect Examination

........ ......

l\12ll.L.i

2QQ2 Judge,
For the Petitioner, Carlos
Wi tnesses,

Taken

Onder Advisement

....,.

J.

Betancourt

10 11 12 13 14 15 16 17 18 19 20 21 22 23

.v 11 12 13 14 15
16 Witnesses,

Karl James John

woolridge

P. Schranz

For the Respondent, Sallie A. Blake

Mr. St. Louis

Lucy

Martinez Gallegos Duran

17
18

Patricia
Frank.

Sanchez

19 20 21 22 23
2.

2. 25

25

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Sanchez v. Dupnik et al 05-CV-583-TUC-RCC PCJC 0001

105 REDIRECT BY MS. BLAKE, Q one A Q A Q A 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. BETANCOURT, Q testified They asked that you you about do Mr. that Sanchez you have and seen his drinking, Mr. Sanchez and you Q A Q A Q A Q alcohol A No, Mr. beer' Uh-huh. Okay. Yeah, Okay. Yes. Okay. uh-huh. Now, Uh-huh. Okay. Yes. Okay. when I Was you he intoxicated him him on that or under night? way. questions. a short recross, Your Honor? the influence of And have you ever seen him intoxicated? you know Poncho well? 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A home Q A Q Now, until And it was he able to the to drink crowd. that beer? it's tha t that that occas Betancourt EXAMINATION intoxicated. A At For my home. MS. BLAKE, Objection. Yeah, where Your to Ms. Irrelevant. are Honor, know Blake that opened we going? I just he want was the to example, where have you seen him

106 intoxicated?

mentioned that you

only

saw

Poncho

have

the

THE COURT,

MR. BETANCOURT, she i on? would I be believe able

see

why on

intoxicated door as to

we got got

spilled?

-THE COURT, All right. Go ahead.

BY MR. BETANCOURT, I'm What Where At sorry. was have it Go ahe ad again? you parties to beers seen him that have intoxicated? we used parties at to his have before, at his and the question.

my home he

where And

used

home

--

how many family your Mr.

-get how is I that along. many beers before you would

saw see

-- where
And in that

members

didn't MS.

that

experience, Sanchez that.

BLAKE,

No further Just

consider A Q but

intoxicated? can't he answer wasn't what that he's takes on? really, one or really two beers. that intoxicated would be the question. that night

MR. BETANCOURT, THE COURT,

I wouldn't
And when you have

know you seen

Go ahead. RECROSS - EXAMINATION

mention him are

intoxicated, you basing when he

difference, A I know

what the

way

he

acts to

--

intoxicated,

compared

when

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107 Q A Q A time. Q not A Q 10 11 12 13 14 15 16 17 18 19 20 21 22 didn't ahead, A you Q I Doesn't intoxicated? No. mean, I don't you understand mention it. again. have tell point good you. I'm getting at is that you mentioned that times, and we just that I asked your the question. way you to we all explain I'm get, it sorry. and I guess Go I 10 11 while ago? THE WITNESS, THE COURT, PATRICIA GALLEGOS, Yes, Okay. Your Have Honor. a seat there, ma'am. do things that he normally wouldn't do when he's Duran. MS. BLAKE, THE COURT, You can sit at the witness stand. And Like And how does we what he act when do. by that? feeling good, and have a good he's I really, will say really that intoxicated? for myself. you. MS. BLAKE, THE COURT, MS. BLAKE, May Yes, The she you Defense be excused? be calls excused, Patricia ma'am. MS. BLAKE, THE COURT, Nothing You may further. step down, Ms. Martinez.

lOB

-- like
do loud, you and

we all mean

Thank

We get

we get

may

Gallegos

Remember I - - we gave you the

oath

a

understand try We just want Well, it

further.

--

I

don't

know

what

12 13 14 15 16 17 18 BY MS. Q A Q Tucson

me to the

RESPONDENT'S DIRECT

WITNESS,

PREVIOUSLY

SWORN

EXAMINATION

Mr. Duran was under guess
was A

- - was under

the

pain. of being Mr. Sanchez
doing that?

tased, was saying

and I --

BLAKE,

you were
yelling Uh-huh. That true Yes, And do When he at

-- testimony
the deputies

was that
to stop

Will

you state

your name for the record?
Duran. in May some of 2003 officers at Old and

Patricia

Gallegos

And were you present on the night when an incident occurred involving

Q
that's A Q likely A

was or

kind

of

saving

Mr.

Duran?

Would

you

say

19 20

not? say that. is that or something when he's he sober? would more

some tasing?
A Q Yes, Okay. I was Could present.

I would in your

21 22

experience he's sober. intoxicated

you tell
employed? estate agent

me a little

bit

about

yourself?

How

23
24 25

when he's

23
24

are you currently
A Q I'm All a real right.

and

a

loan

officer.

MR. BETANCOURT,

Nothing

further,

Your

Honor.

25

Prior to being

a real

estate

agent

and a loan

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Sanchez v. Dupnik et at 05-CV-583- TUC-RCC PCJC 0028

109 officer, A Q A five judicial that Q A was And Yes, Could I do I you do. you tell with I was security. available. as a part in of levels that, of just general. do you mean about trainings on levels of what force, training kind of training on, the you did you get? me what the sheriff's qualified, transportation, that is? department female. in corrections I any worked weapons post for have any law enforcement related experience? Q out? A Q A towards between they towards rules 10 11 12 13 I mean determine threat is, My level that, what and of you level it know, of would threat man, you force be could what have you different be he's a lot going to assess to for more to every use, situation and what a than to be a, 14 15 16 17 18 19 20 somebody's wife, Q invol A Q invol A security uniform, security, and him. Q become A Okay. they and Okay. ved? Yes. Okay. ved? After the was verbal notified. -it you argument. They wasn' know, t were I guess people they that that just were in were weren' they got Yes. How did I was the that come at of the was but so and, that you about? that time, and and and my husband there we're was not had I and an even pushed Okay. At some point did some kind of disagreement

110
break

worked

years.

weapons I worked

pregnant front

I were

concert. offended, I was I

argument sure me why

-- somebody
offended, the front view a little At some

- - my
could the

husband see, man and said

Training

training on

know,

guess we

we blocked his

10
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

weapons and Q force? A and your female. you his Q A Q that A know, level

qualifications, in And what

department

know,

disrespected

regulations Okay.

confrontation, point did

verbal, security or

occurred. deput ies become

need

And how -- how did..

when did

they

become

me being serious perceive

notified, t in were

and

a 250-pound of threat

-to that.
this particular incident, how was it

weren't or they,

recognizable they were and they

Okay.

plainclothes, trying to detain

- - and how we respond
Now, you I on were there was the the at night old with of Tucson?

21 22 23

confronted

my husband,

At some time

- - at

some point

did

the

deputies

was

my husband why

and we were

my sister, there.

and

we were

at

24 25

involved? Yes.

a concert.

reason

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111 Q A in and Okay. The And what deputies were trying wasn't did they talking tc get do? to the the story at other of personnel what that that were on, gentleman around ~ent to after Okay. anyone? my A No. Okay. in didn't 10 husband when this 11 12 the distance that you and I are. maybe less, 13 14 15 A these had first was were BY MS. So, Well, A a position Yes. MR. BETANCOURT, THE COURT, MS. BLAKE, he I walks got in around, to say and something the other that, and he you you so had had had were didn't know, know. because this guy's like other it, coming BLAKE, Obj ect i on, Your Honor. And to if he would seen have that? struck someone, would confronted confront my husbsnd Now, at my husband, him as and any well, took did and and him then then down. see your husband my husband they just,

112
~ent you know,

plainclothes my husband

was going
point. He

readily

detained

time

you

strike

walked
to

around,
him, turned got was that .. the

and -- because
so around involved was he was to and going

the

other
up him

gentleman

had come up
and the

confront

moving

towards as I well.

my husband, And that but then my they

husband deputies husband 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 realize Q was A and Q A

confront they to

you

be

thought,

guess,

have

initiate moved

something, forward. to your

other were you

man had in

Speculation.

Now where going I was on? about

relation

Overruled. All right.

-Okay.

forward. some of who the who that

r said,
gentleman you didn't had

--

and facing
it with And did I did.

him,
the you

and when the
deputies; have what a clear

plainclothes
was view going of that? on.

security

were

16 17 18 19

men were started verbal coming involved The other other and came, at

plainclothes,

discussing Q A Q and A Q security A They Okay. Yes.

a confrontation,
argument, him. there, guy guy they there

initiated My husband he

know, know friends

also

. So were there
where No. Okay. and were your

any people
and the

standing
deputies

between
were?

you at that

time

20
21 22

.fri ends? with some him sitting so there when as well the as the people in the friends made

husband

A front officers

The row,

Now. what
the in deputies, the

-- after
what

they

discussed

together,

the

23 24

comments, people who these

happened? of discussing that when the other

plainclothes know

process

25

deputies.

My husband

plainclothes

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Sanchez v. Dup"ik et al 05-CV-583-TUC-RCC PCJC 0029

113 were. other For all he knew gentleman they could. have been the friends of this Q All

114

right. Now, when he was on the ground,

where

were

who had started

the fight. there starts to be another
u

you? A Q
I was watching.
I was --

Q

Okay.

But at some point and your husband

confrontation,

moves

around

Okay. Let's say this is a picture
his first name?

of your

husband.

A Q A Q A 1D 11 12 13 14 lS 16 17 18 19 2D 21 22 23 24 25' Q A

Correct. - - the Correct. officers?

What's

A Q
he never struck anyone?

Ernesto. Ernesto.

Let's

say this

is Ernesto

on the ground.

where

But as you testified, No, he did not.

was this

deputy? He was over behind him, him, My husband was face

A
point They what did the officers do? 1D down

He was over him. and his hands u was were

Okay.
They

So at that him.

and they had

- - some of the him. taser to have

tasered him.

took him down

and they were

11
12

officers
I

one of the officers this officer continuously,

had managed

to cuff the

what

tasering

recall

was hitting ,you know. him.

him with Minutes

Q A Q
that

Do you know which The officer Now, sitting

officer here

tasered

him?

13
14 is the one

consistently, passed

seemed

at the desk. husband, Mr. Duran,

and he was still

tasering

Okay.

is the -- your first -.

15 16 17

Q

Okay. And where were you' standing?
location as to where this officer

Would would

this have

be a been?

was taken
Correct. - - by Correct. the

down

correct

A Q A Q A Q A Q A

A Q A Q
here

Yes.
And was there another officer on the other side?

deputy?

18 19 2D 21 22 23 24
row in the blue shirt there. 25

Yes. Okay. Now, if let's say your
-Uh-huh, -- this way, He was bent you know, now what over with him, his would Deputy Woolridge be doing? fashion .- Ernesto was laying down

Now

is he in the courtroom? courtroom?

Is who in the Mr. Duran? Yes, And He's he is. where

A Q
A with,

is he sitting? in the front

He was bent was

over in this

sitting

taser.

hitting

him in the back,

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115 Q All right. And where that?
-

116 THE COURT. spoken, Overruled. Just that the words were

were

you standing

at that time?

A

Can I approach Yes, would

you' put

we'll

have

you put

a P for your

BY MS. BLAKE. Q All

right. And how close was the crowd in; were they
than you. me. you? or behind you?

A Q

Okay. Okay.

I was

standing

right

here. you from your husband

closer

And about woolridge? three

how many

feet were

A Q

Behind

and Deputy

Okay. So, the crowd was behind Yes,
At any point behind did you ever

A

About

to four feet

maybe,

three

feet,

I would

say,

A Q

All right.

see anyone

in the crowd

move up

1D 11 12 13 14 15 16 17 18 19
2D

A

About About

the same

distance

that now?

-.

1D 11 12

directly

the officer?

like we are right

A Q

No.
Now, while this was going on, where was your attention

A Q A Q
crowd

Yes.
Three, four, five feet, maybe?

13

focused?

Okay. All right.
doing What
Go

14
ahead and have a seat. Now, what was the

A

On my husband, using --

and

on the officer,

and that

he wes

15 16

consistently

the taser,

during

this time? hear, a lot of the people There were upset because

Q A Q A

So that And

A

I could

17 18 19 20 21
22 23

I was yelling

as well. and what
He's

he was was

tasering

my husband, that

was a lot of shouts, not everybody really, saying, "Stop; -to obj ect to hearsay,

There

And you were yelling, Yelling. "Stop, stop. That's

were

you yelling?
in cuf f s .

some people

were passive; that were

was getting in our

already

He's

involved, area
stop.

but the people were watching

you know, yelling,

already

restrained. Now, much --

enough." to say you kept your eye

21 22 23 24 25

that
"

this were said, already"

"Stop, to kill

Q

All right.

so is it fair had your

You know? That's

Somebody He's

you're

going

and that pretty A Q

attention?

him.

enough.

Yes. and that The

MR. BETANCOURT.

I'm going

Your

24

entire time? The only

Honor.

25

A

That had my attention. yes, the entire time.

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PCJC 0030

117
time that I did turn to look was when and my -- my the officer had turned to

118

A Q

I want

to say a minimum

of ten feet. approach

look at This was

Mr. Sanchez, when that

-- I -- this

was before. to

Okay. And at any time did you see Mr. Sanchez
deputy while he had the person approached on che ground --

the crowd direction,

was yelling. and I turned

Okay. He just turned
to follow his gaze both

the

look at what

to see

A Q

Never. He never

him.

he was

looking

at, and then our attention went back

-- his

-- like your husband.
He never approached him.

attention

and my attention

on my husband.

A
Q

Q A
the

Okay.
So, he was looking at the crowd. his gaze. prior to this occasion? He looked up to look at

Okay. And you would have been able to see from your
point?

vantage

crowd, Now

and I followed

A 10 11 Q
back

Right.
Did you ever of the head? see anyone walk' up and hit the deputy in the

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Q A Q

did you know

Mr. Sanchez

No. Okay.
Now you said that the first turned time you noticed Mr.

12 13 14

A Q A

No.
At If any point did you see someone my husband, see who you? -- all I saw was the beer, hit -- hit him. throw beer? I saw the beer

Sanchez

was when

the deputy

around?

A Q

Correct.

-- as

I was facing

you know, threw i'c.

Okay.

Now,

he turned since

around, there

and what whole

-- what crowd?

made

you

15 16

hi t the officer,

but I didn't

notice

Mr. Sanchez, I didn't

Q A
when

Okay. Because
Correct; it caught And when It was --

it was behind from

A
but the

Well,

just notice

him.

I noticed

other

people,

17 18 19 20 21 22

it was coming my view, --

he caught

my attention "Stop, was

also hecause going

he was yelling. him." And

He was
that's

the beer

one yelling,

you're

to kill

Q A Q

why my attention concurrence

directed

at him, because

I was in

with what

he was saying.

-- the beer hit Deputy

Woolridge,

which

direction

was he

Q A Q

All

right. you're going to kill him." from the

faced? A
He was
-

"Stop; And

23 24 25

his attention

was on my with

husband,

and his head was at that point,

at that time

how far away was Mr. Sanchez

down.
because

He was doing at that point

something

his hands tasering,

deputy?

he'd stopped

I think.

When

the

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119 beer hit him, I noticed the beer hit him right or paper cup full here. of beer. the person "ho It was a Q tases All right. And so, Deputy Woolridge just turns

120 around and

cup. Q
threw

It was like a plastic

Mr. Sanchez?

Okay.
it? Near

And hisl

hi. face,

"as it to"ards

A Q

Yes.
What He happens at that point?
-

A

-- no, no, his face was here

-- he was focused wi th his --

on my

A

tasered officer

him and he came,

they took

him down,

and there Mr.

was.

husband

and what he was doing

another Sanchez.

and they were

struggling

with

Q A

Okay.
He did not - - his head was bent have over. He did not reason -- there is

Q A 10 Q A

All
And

right.
they were cuf f ing him.

was no way he could

seen - - the only hit him.

he knew

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

because

he

felt

-- felt the beer

Otherwise he -hit

Okay. And was Mr. Sanchez
I didn't see him resisting,

resisting, no.

or

-have a chance

Q him? A

And

what

did he do after

you saw the cup and the beer

11 12

He didn't

to resist.

He turned

towards

his right,

and he immediately

went and he

13 14 15 16

Q A
was

Okay.
He was tasered hitting and down on the ground was happening to him. did you become other than before he knew what

towards

Mr. Sanchez very

and tasered

him and took him down,

was very,

angry.

him, what

Q A Q

Okay.
He was --- did you ever hear Deputy Woolridge say

Q
aware being

Okay. Now, once he was on the ground,
that something tased Did laying on had happened the ground? in that moment

17 18 B
to him, and he, in my opinion, that beer. to speculation, Your

to Mr. Sanchez,

Did you ever

anything

to Mr. Sanchez? said anything known

A

I become

aware

that something

had

A
could

He never not have

20 21 22 23

happened?

who threw

Q A
been

Yes.
I didn' t know at broke. that specific moment that his leg had

MR. BETANCOURT;

Obj ection

Honor.
THE COURT; BY MS. BLAKE; Overruled.

24 25

Q A

Okay. That's what I was asking.
I did not know.

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Sanchez v. Dupnik et af 05-CV-583- TUC-RCC PCJC 0031

121 Q they A being You did not know take They him away? did. They turned him over because them I remember flipping him at that time. Now, at some point did

122

event? A
My memory's very clear. As a matter of fact it was

--

it's almost

traumati zed me. do you have any relationship

on his back, kind

and then him

I remember

him over,

Q
wi th

Okay. Since this incident
Mr. Sanchez?

and they

of cuffed

like in a hogtie hogtie? Where did

situation. they cuff his back, him? cuffed,

Q A
and

And what They

do you mean,

A

I never

speak

to him.
I

I don't him.

.- to this

point

I

don't

had his legs be over,

-- his hands

behind

consider

myself

that

know

his legs bent

cuffed. carried him away, how did they carry

Q A 10 Q

All right. I just know of him, and the situation.

Q 10 11 12 13 H 15 16 17 18 B 20 21 22 23 2. 25
him

Okay.
away? They All

And when

they

Okay.
MS. BLAKE,
THE COURT, I

A Q

picked right. Ernesto,

him up by

the cuffs. go back to the During time that that time, your did

11 12 13 H 15 16

have

no further

questions.

Okay.

Let's

Mr. Betancourt. Thank Your Honor.

husband, anyone

was on the ground. Woolridge?

MR. BETANCOURT,

strike

Deputy

CROSS-EXAMINATION BY MR. BETANCOURT,

A Q A

No.
And how are you certain? Because I was watching my husband being tasered was focused there.

Q

You mentioned

you were

a corrections

officer;

is that

17
18

correct?

e"tensively,

and that
this

-- my whole' attention Now, you said

A

That's

correct. did you have officer? several times in the aspect of the to use force on your job

Q A Q A Q A Q

since

- - okay.

you were

pregnant?

19 20

Q
when

And how many times you were

Yes. Okay. No. Okay.
Absolutely All right. not. So, how would you say your memory is of that So, on that night had you consumed any alcohol?

a corrections

21 22 23

A
jail.

I've had to use force bringing someone in.

Q

You mentioned No. I wouldn't How many years

several

times; than

is that 25.

more

than

25 times?

2'
25

A
Q

say more were you

a corrections

officer,

by

the way?

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12'
A
No, I did not. methods would you use to put or that somebody under

A Q A

Five

years.

And From

from when
1996

to when

were you a corrections through 2000,

officer? so I guess four

Q

What kind of

is when

I started,

oontrol

that was being

argumentative

you had to put

years. Q
You weren't anymore? remember officer. 2000, approximately? the exact date, but no, I wasn't a .. after 2000 you weren't a corrections

into control? A Well. because I was in the jail, the tasers weren't spray in the was

officer

actual

cells

or in the pods, We did carry post,

and .neither spray

-when

pepper
I

A

I don't

not allowed.

pepper but

would

go on post

corrections

as far as a weapons know, verbal

I never tbing

had to use to put

it, so. you under

Q 10 11 12 13 H 15 16 17
18

Around

would be

the first

someone

A Q

Yeah.
And why is it that you weren't a corrections officer

10 11
12 I resigned. - - actually, Were let me go back you trained to some of the taser? 13 14

control,

would

be verbal -.

direction.

Q
A Q A

So it is your
And

anymore?

then physical

presence.

A Q

Because What

I'm
No,

sorry; go ahead.
just physical presence, calling officer for assistance, a lot of times and would

were

questions

on force.
I was.

on using

15 16

the mere presence make someone

of more

than one

A Q
your

Yes,

back down. that in a combative situation you

And were you taser when

-- did you have

any opportunities

to deploy

17 18 19

Q
would

So it is your testimony not use pepper I said
I

you were using

taser?

spray

or a taser? it, and more allowed because
I

19 20 21 22 23

A Q A Q
under

No.
You never No, used it? it. -- other methods of putting people

A

have not used things

worked

in

20 21 22 23

the pod, and those

weren't

in the pod.

I never

used

Q A Q
this A

What do you mean, The corrections, And there incident? Yes.

the pod? where the men were housed. pregnant during

Did you ever use other control? Fhysical methods, sure.

has been

testimony

that

you were

2'
25

A
Q

2.
pepper spray? 25

Did you ever use,

for e"ample,

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Sanchez v. Dllpllik et at 05-CV-583-TUC-RCC PCJC 0032

125 Q A How many I don't months remember pregnant exactly, were but you? I gave birth in July, so A Q A Daubertson? Yes. No, that MS. testimony the that deputies any? at or all, that like you that? 10 you mentioned that your focus was on your husband, Mr. 11 12 That's So, No, of And you I correct. weren't not. you that didn't night? have any type of doesn't BLAKE, -I don't Honor, recall that name.

126

eight but,
Q physical A Q with 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Duran? A Q A front Q Oeputy A Q work A worked Q

months,

say eight

months

pregnant,

my - - I gave bi rth

you know -And is it your with have

Your We'll

is this relevant to anything?
one.

THE COURT,

see the next

contact That Yes, the No, And I didn't

MR. BETANCOURT, BY MR. BETANCOURT,

It is. Your

Honor.

any

pushing

-- any

pushing

at

all

Q were A Q
you

You

mentioned

that you

resigned.

Isn't

it true

that you

deputies,

anything

actually No, And

terminated?

that's not true.
do you know

an officer
don't,

--

or

detective, and I think
ask, or I'll stable

mentioned

that you

and I'll

My focus
focusing I was

-on Mr. on Sanchez this the officer whole here time? in

13
H 15

(phonetic) that he is part of
A Q Okay.
Do you know

Internal Affairs.

was

focused

him,

Oetective
but

Oaubertson?
if

me and how long

my husband. have you known

16

A

I don't
by

recall

the name, Affairs,

you're

asking

me

if I was on more

-I

and

did

you

know

Officer

or

17 18

questioned than Q

Internal

yes,

I was questioned

Woolridge? Never Any in I met him bef ore. in NO, common don't or know him. that you know from

one occasion. And did

19 20 21

that questioning -- what were you questioned

acquaintances common?

anybody

about?
MS. BLAKE, Objection. Yeah, what's Relevance. this? Where are we going

know with

Deputy him prior

Grisholm to that him you

or

Detective

Grisholm. a detective.

In

fact,

I

22 23 24 with this?

THE COURT,

becoming

And

you

mention (phonetic

-- do

you

know

Detective

MR. BETANCOURT, fact that she testified

Your

Honor,

it

goes to the - - to the
and it's my

Daubertson

throughout)?

25

already

that she resigned,

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127 1 contention that she did not. Well, I'm I mean, three has some Yes, years animus? specifically to the deputy, just trying to I this.. get mean, to she Are you that. Q And was the way in which of your he used the taser on Mr.

128 Sanchez

THE COURT, resigned trying to or say she

so what?
before

consistent with any
A
I

training?
to have to say yes, him, it was consistent then took him him, so --

was ,fired that she

don't

- - I'm going that,
you know,

in the fact down

he tasered

and

MR. BETANCOURT, Your Honor. MS. evidence saying, 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MS. BLAKE, Q use A Q taser A You said of tasers? you were trained Your Honor, is to BLAKE, up she Your anything, resigned. Yeah.

immediately.

He wasn't force,

consistently

tasering

Q
Honor, other I have than a question. that, what If she's he has

But in the scale of
taught? don't beHeve that

did he use the levels of

force

as you were A
No, I

prove that

he used

appropriate tasered threw

escalation without

of
he

force.
10 I'll leave just it at call that. a rebuttal witness,

I think
--

he immediately who

--

THE COURT,

didn't even
certain got eyes

I don't even know
know because

that beer, and I'm
see it unless he's

MR. BETANCOURT, and MS. I'll just Okay. Okay.

11 12
13

he doesn't

he couldn't

in the back

of his head. Objection, Your Honor. Speculation.

BLAKE,

MR. BETANCOURT, THE COURT, MS. BLAKE, THE COURT, Anything MR. ST.

THE COURT,

Ask

your

next

quest

ion. Your Honor.

14 15 16

Sustained. I have no further questions.

MR. BETANCOURT, THE COURT, MS . BLAKE, MS. Yes,

No further Blake? just a short

questions,

Okay.
Mr. Betancourt?

follow

up.

17
18 19

further, LOUIS,

REDIRECT

EXAMINATION

Not

from

the State,
Thank

Your Honor.
you, Ma' am.

THE COURT, MS. BLAKE, THE COURT, MS. BLAKE, THE WITNESS, THE COURT, sorry.

You can step down. Thank you.

as

part

of

your

training

in

the

20
21 22

You can call your The Defense I

next?

Yes. And on is your the manner husband in which Carl with Woolridge any training was using you've the had?

calls Frank Sanchez.

23 24 25

Can

stay here? outside, ma'am.
I'm

consistent

You need to step

NO, I felt

it

was excessive

force.

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Sanchez v, DUp"ik et at 05-CV-583-TUC-RCC PCJC 0033