1 UNITED STATES DISTRICT COURT 1 FOR THE NORTHERN ...

812345678910111213141516171819202122232425Q. I've had the benefit of reviewing yourdepositions in the Borden and Alvarado cases. Iunderstand the Borden deposition was on July -- well, inJuly of last year, 2005. How many depositions have yougiven since that time?A. Since July of 2005?Q. Right, the Borden one.A. I would estimate four.Q. And what kind of actions were those?A. There was, I believe, a deposition for theAlvarado trial, which was -- involved a death in policecustody. There was a case, I think it was Lewis, wherethere was an allegation of injury in a case involvingpolice use of a TASER.I'm trying to think what the other ones mighthave been. They're not coming to me offhand. I knowI've had a few depositions this past year.Can I throw a lifeline out to my counsel?MR. BURTON: That's fine with me.THE WITNESS: Anything else I'm missing as faras depos?MS. GIBEAUT: We can look at your calendar.Q. BY MR. BURTON: What were the --A. Alvarado and Lewis are the two that come tomind.