Case 2:11-cv JCZ-SS Document 79 Filed 03/26/15 Page 1 of 2 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

Transcription

1 Case 2:11-cv JCZ-SS Document 79 Filed 03/26/15 Page 1 of 2 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA JANE DOE, Individually and on behalf of * CIVIL ACTION her minor son, JOHN DOE NO VERSUS * JERRY DANTIN, THE TOWN OF GRAND ISLE, DAVID CARMADELLE * SECTION "A" and EURIS DUBOIS JUDGE ZAINEY MAG. 1 * * * * * * * * * * * * * * * * EX PARTE MOTION FOR LEAVE OF COURT TO FILE SUPPLEMENTAL EXHIBIT TO PLAINTIFFS MEMORANDUM IN OPPOSITION TO MOTION TO EXTEND DISPOSITIVE MOTION DEADLINE FILED ON BEHALF OF THE TOWN OF GRAND ISLE, DAVID CAMARDELLE and EURIS DUBOIS NOW INTO COURT, through undersigned counsel, come plaintiffs, Jane Doe and her minor son John Doe, who file this Motion for the purpose of opposing the Motion to Extend Dispositive Motion Deadline filed by The Town of Grand Isle, David Camardelle and Euris Dubois (the Grand Isle defendants), (Rec. Doc. 73) and to supplement plaintiffs opposition memorandum (Rec. Doc. 78). Plaintiffs respectfully move the Court for leave to file the attached Exhibit 3, the deposition transcript of Euris Dubois, which undersigned counsel just recently received.

2 Case 2:11-cv JCZ-SS Document 79 Filed 03/26/15 Page 2 of 2 RESPECTFULLY SUBMITTED, _/s/ Richard C. Trahant RICHARD C. TRAHANT (LSBA 22653), T.A. T. PETER BRESLIN (LSBA 3436) ATTORNEYS AT LAW 2908 Hessmer Ave. Metairie, LA (504) (504) fax trahant@cavtel.net tpb@tpbreslinlaw.com CERTIFICATE OF SERVICE I hereby certify that on March 26, 2014, I electronically filed the foregoing with the Clerk of Court by using the CM/ECF system which will send a notice of electronic filing to all counsel of record I further certify that I mailed the foregoing document and the notice of electronic filing by first-class mail to the following non-cm/ecf participants: None /s/ Richard C. Trahant RICHARD C. TRAHANT (Bar No ) ATTORNEY AT LAW 2908 Hessmer Ave. METAIRIE, LOUISIANA TELEPHONE: (504) FACSIMILE: (504) trahant@cavtel.net 2

3 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 1 of 152 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA JANE DOE, Individually* CIVIL ACTION and on behalf of her * minor son, JOHN DOE * NO * VERSUS * SECTION A * JERRY DANTIN, THE TOWN* JUDGE ZAINEY OF GRAND ISLE, DAVID * CARMADELLE and EURIS * MAG. 1 DUBOIS * * ******************************************* The videotaped deposition of EURIS DuBOIS, taken in the above-entitled cause pursuant to the following stipulation before Michael W. Franco, Certified Court Reporter, in the Federal Courthouse, Hale Boggs Building, Room 245, 500 Poydras Street, New Orleans, Louisiana 70130, on the 20th day of March REPORTED BY: Michael W. Franco Certified Court Reporter

4 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 2 of I N D E X Exhibits Appearances Stipulation Examination By Mr. Trahant Reporter s Page Reporter s Certificate E X H I B I T S Exhibit No Exhibit No Exhibit No Exhibit No Exhibit No Exhibit Nos. 6 and

5 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 3 of A P P E A R A N C E S RICHARD C. TRAHANT, Esq Hessmer Avenue Metairie, Louisiana For: JANE DOE, Individually and on behalf of her minor son, JOHN DOE KEITH M. DETWEILER, Esq. Neilsen Carter and Treas, LLC 3838 North Causeway Boulevard Three Lakeway, Suite 2850 Metairie, Louisiana For: THE TOWN OF GRAND ISLE, MAYOR DAVID CAMARDELLE, and EURIS DUBOIS ROBERT TOALE, Esq. 505 Weyer Street Gretna, Louisiana For: JERRY DANTIN Also Present: HARRY CHIP CAHILL 3361 General DeGaulle Drive Suite C New Orleans, Louisiana TODD MAYSONAVE Persuasion, LLC Videographer

6 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 4 of S T I P U L A T I O N It is stipulated and agreed by and between all parties that the videotaped deposition of EURIS DuBOIS, is hereby being taken pursuant to the Federal Rules of Civil Procedure, pursuant to notice, for all purposes. All formalities, including those of signing, sealing, certification, and filing, are waived. All objections except those as to the form of the question and the responsiveness of the answer are reserved until the time of the trial of the cause Michael W. Franco, Certified Court Reporter, in and for the Parish of Orleans, State of Louisiana, officiated in administering the oath to the above-named witness.

7 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 5 of Euris DuBois 2 P. O. Box Grand Isle, Louisiana 70358, 4 a witness having been first duly sworn in 5 the cause, testified on his oath as 6 follows: 7 E X A M I N A T I O N 8 MR. TRAHANT: 9 Good morning. I introduced 10 myself to you off the record. 11 Tell me your last name so I 12 make sure I pronounce it 13 correctly. 14 WITNESS: 15 DuBois. 16 MR. TRAHANT: 17 Okay. So it is not DuBois? 18 WITNESS: 19 DuBois or whatever. 20 MR. TRAHANT: 21 I want to pronounce it the 22 way you are comfortable with 23 it. 24 WITNESS: 25 It is French.

8 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 6 of MR. TRAHANT: 2 That is fair enough. So is 3 mine, but it is not pronounced 4 that way. 5 WITNESS: 6 Yes. 7 MR. TRAHANT: 8 What I want to attach as 9 Exhibit No. 1 to the deposition 10 is the notice of deposition. 11 You may or may not have seen 12 that. But for housekeeping 13 purposes, I m going to attach 14 that as Exhibit No. 1. Have 15 you ever given a deposition 16 before? 17 WITNESS: 18 Yes, sir. 19 MR. TRAHANT: 20 And what case was that in? 21 WITNESS: 22 It was a case where two (2) 23 officers came to arrest me on a 24 false arrest. 25 BY MR. TRAHANT:

9 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 7 of Q. And what case was that in? 2 A. That was back, let me see, about, and 3 I m just guessing, about twelve (12) 4 years ago. 5 Q. You were sued in that case? 6 A. I was sued, and I won the case, 7 though. 8 Q. And that was a case filed by Mr. 9 Bradberry? 10 A. Yes, sir. 11 Q. And do you remember who took your 12 deposition, Mr. DuBois? 13 A. No, sir. 14 Q. Is that the only time, other than, and 15 I do not want to talk about court 16 testimony yet, but is that the only 17 time you have given depositions, other 18 than today? 19 A. Yes, sir. 20 Q. Do you remember who defended you in 21 that case? 22 A. On the deposition, it was State Farm, 23 my insurance agent. 24 Q. Do you remember the lawyer s name? 25 A. No, sir.

10 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 8 of Q. And you do not remember the lawyer who 2 represented Mr. Bradberry? 3 A. No, sir. 4 Q. Can you tell me what, if any, 5 documents or things you have reviewed 6 in order to testify here today? 7 A. Well, I looked at, when I went to 8 court, I reviewed some of the stuff 9 that they asked me in court. 10 Q. Are you talking about the transcripts 11 from the criminal trials against Mr. 12 Dantin? 13 A. Yes, sir. 14 Q. And can you tell me what it was that 15 you reviewed? 16 A. Well, they had asked me a few 17 questions, and I answered them to the 18 best of my ability. And I am just 19 guessing I had like twenty (20) or 20 thirty (30) pages of it. 21 Q. Well, I don t want you to guess at 22 anything, and I would guess it has 23 been a while since you have given a 24 deposition. So let me just give you 25 the ground rules really quickly. I

11 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 9 of don t want you to guess at anything. 2 You are doing great so far. If you 3 permit me to finish my question, I 4 will attempt to permit you to finish 5 your answer so we do not talk over one 6 another. Mr. Franco here has to get 7 everything down, so it makes his job 8 easier. You can consult with your 9 lawyer, but not when there is a 10 question pending. If I ask you a 11 question, you have to answer that. If 12 you want to take a break at any time, 13 or if you want to go to the bathroom, 14 or if you want to get something to 15 drink, this is not an endurance 16 contest. We may be here for a while. 17 But if you tell me, I want to take a 18 break, I will respect that, the same 19 with anybody in the room. And so, I 20 would guess that having been said, I 21 don t want you to guess at what it was 22 that you read. Did you read your 23 testimony from both of the trials, the 24 one in July of 2011 and the one in 25 September of 2011?

12 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 10 of A. Yes, sir. 2 Q. When did you do that? 3 A. I would say maybe two (2) or three (3) 4 weeks ago. I just went through it. I 5 did not read everything, but I just 6 glanced at some questions. 7 Q. Alright. Well I mean, we are going to 8 talk about that some, and I have those 9 transcripts here. But can you tell me 10 what you recall about what you read, 11 if you read part of it? 12 A. Well, the parts that I remembered a 13 little bit was like, if I read Mr. 14 Dantin, Mr. Jerry Dantin, if I read 15 him his rights before I questioned 16 him. And that is the part that I did 17 not remember. I know I read his 18 rights after the fact. I could have 19 read his rights before, but I am not 20 sure. Like I said, I know I read his 21 rights after he told us whatever 22 happened. 23 Q. And understand that I am not yet 24 trying to test your recollection. We 25 will get to what happened on April 6,

13 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 11 of But what I m trying to figure 2 out, because by the time we get to the 3 transcripts, I would like to know what 4 it was you read and what it was you 5 did not read. Do you understand? 6 A. Yes, sir. 7 Q. And so, if you are telling me you 8 glanced at some of it, you read parts 9 of it, can I ask you if there was a 10 particular reason why you would have 11 read some parts and not other parts? 12 A. I really can t answer that because I 13 just went through it. I felt that I 14 went through all of this before, and I 15 am the type of person that could 16 review a piece of paper and figure the 17 half of it. I do not have a 18 photostatic memory. I have to look at 19 it two (2) or three (3) times to kind 20 of remember. But the parts that I 21 remembered is, you know, looking at 22 it. I glanced through it. And that 23 is what I can tell you. 24 Q. Maybe a better question from me would 25 be, did you take the transcript from

14 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 12 of the July of 2011 trial and read your 2 testimony from the front page to the 3 end? 4 A. No, sir. 5 Q. On the September of 2011 trial 6 testimony, did you read your testimony 7 from the front to the back? 8 A. No, sir. 9 Q. Is there any particular reason you did 10 not do that, knowing that you were 11 going to be asked about it today? 12 A. Well, like I told you from a while 13 ago, I could read and read it. I just 14 don t remember. I mean, I am telling 15 you the truth. I cannot keep nothing 16 in memory. If you ask me questions of 17 the trial, maybe I can tell you. But 18 insofar as, even though I read it in 19 front of me, if I put it down and you 20 ask me questions, I still do not quite 21 remember what I read. 22 Q. And I understand that, and I 23 appreciate that information. But my 24 question was, and I m trying to figure 25 out if you only read certain parts of

15 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 13 of it. Why would you have read certain 2 parts and not other parts? 3 A. I cannot answer that, sir. I am just 4 telling you the truth right here. It 5 is like a book when I was going to 6 school. I might have read the front, 7 the middle, and the end of it. And I 8 will judge it in between. I just went 9 through it like that. 10 Q. You would agree with me that it is 11 better to have more information than 12 less? Is that correct? 13 A. Yes, sir. 14 Q. And in particular, if you are doing 15 police work, you want to read all the 16 reports. You want to read everything 17 that is given to you in the form of a 18 statement to come to a logical 19 conclusion as a police officer. You 20 would want to read more than less, 21 correct? 22 MR. DETWEILER: 23 Objection. 24 WITNESS: 25 Yes.

16 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 14 of BY MR. TRAHANT: 2 Q. I guess what I m trying to ask is, how 3 do you prioritize? I understand that 4 you said you read the part about 5 whether or not you read Mr. Dantin s, 6 and I am mispronouncing his name, and 7 I apologize. But when you read him 8 his rights, and you said you do not 9 remember that, and I appreciate that. 10 But what I m trying to figure out is, 11 why would you have read certain parts 12 and not others? 13 A. Well, to get into this, like I said, I 14 went through all of this. And if I 15 was going to look at the transcript of 16 paper and try to memorize it, I might 17 be telling you something. I might be 18 lying. I don t want to do that. I 19 want to tell you the truth, what I 20 remember. 21 Q. Alright. Did you review anything 22 other than parts of the two (2) 23 criminal trial transcripts? 24 A. Well, like I said, I had the first 25 hearing. I went through it. And then

17 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 15 of I had the second hearing, and I went 2 through it. I just browsed over it. 3 And like I said, I felt that if I was 4 going to try to memorize it, it would 5 be just, you know, saying well, you 6 studied the case and you are trying to 7 remember everything that happened. It 8 is impossible. I cannot do that. I 9 really, I just, I m sorry. But I just 10 cannot remember all of these things. 11 Q. But I am asking you, aside from the 12 transcripts, your testimony, what 13 other documents you may have reviewed? 14 A. I looked at the case. Well, not 15 really the case. I looked at the 16 paperwork from when we made the 17 arrest. I looked at it again to make 18 sure everything was right. And I 19 could see nothing wrong with it. It 20 was accepted by the District Attorney, 21 the DA s office, and everybody. We 22 went to court on it, so I really 23 cannot see that I was trying to do 24 anything wrong. 25 Q. My question was, what did you review

18 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 16 of in addition to the trial transcripts? 2 Do you have this case on a file? 3 A. I have it at my office. 4 Q. Alright. And what is in that file? 5 A. Well Q. What do you recall, as you sit here, 7 having reviewed from that file? 8 A. Are you talking about when we went to 9 court? 10 Q. I am talking about anything contained 11 within this file that you referenced 12 that you would have reviewed, not your 13 court testimony. 14 A. The only thing, like I have just told 15 you, is the paperwork we did when we 16 arrested Mr. Dantin. 17 Q. And that s what I m asking you. What 18 paperwork? 19 A. The arrest report. I looked. I 20 reviewed the arrest report, what we 21 charged him with. We charged him with 22 sexual battery, and I wanted to make 23 sure that everything was up to par. 24 And like I said, I am just saying that 25 if the paperwork would have been

19 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 17 of wrong, the District Attorney would not 2 have accepted it. 3 Q. Let me explain this to you, and I am 4 going to do it very respectfully. 5 That is the third time you have said 6 the paperwork must have been right in 7 response to a question about what you 8 have reviewed. I know what you want 9 to say, and you are going to have a 10 full opportunity to say it. But it is 11 going to be a lot easier if you answer 12 the question that I am asking you. 13 And then we can move on to the next 14 question. Do you understand that? 15 A. Okay. Yes. Alright. 16 Q. And I understand this is a formal 17 occasion, and I just think it will go 18 a lot quicker if you focus on the 19 question and answer the question. And 20 respectfully, you have already said 21 three (3) times that you think your 22 paperwork was right. And we will talk 23 about that. 24 A. Okay. 25 Q. Did you discuss Mr. Camardelle s

20 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 18 of deposition testimony? 2 A. Well, I was MR. DETWEILER: 4 Objection to the question. 5 BY MR. TRAHANT: 6 Q. With Mr. Camardelle? 7 A. Well like I said, I was waiting for 8 him to come back that afternoon 9 because I wanted to know what had 10 happened. So the next morning, he 11 came, he was in his office. I went 12 upstairs, and I went up to him, and I 13 said, can you tell me what kinds of 14 questions you asked him. He said, 15 chief, he said, I just cannot answer 16 that. If you want to know any 17 information, you can call Mr. Keith 18 right here. So I never asked him 19 anything about it. 20 Q. You understand that both you and him 21 have been named in a lawsuit, correct? 22 A. Yes, sir. 23 Q. And you all have the same lawyer 24 representing you, right? 25 A. Yes, sir.

21 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 19 of Q. And so when you said, what was the 2 deposition like, he would not talk to 3 you about it? 4 A. He told me, he said, if you want to 5 know about the deposition, he said, 6 call Keith. Keith can tell you, which 7 I never did call him. So Q. And so that was the extent of the 9 conversation you had with Mr. 10 Camardelle about his deposition? 11 A. Yes, sir. 12 Q. Okay. Did you have any meetings with 13 him in preparation for your testimony 14 today? 15 A. No, sir. 16 Q. How long did you spend preparing for 17 your deposition? 18 A. Really and truthfully, I did not get 19 prepared for it. I have talked with 20 my attorney yesterday. 21 Q. And so, as you sit here, did you ask 22 for a copy of the transcript of Mr. 23 Camardelle s deposition? 24 A. No, sir. 25 Q. Would you like to have read that?

22 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 20 of A. Not really. 2 Q. Okay. You wanted to know what it was 3 like? 4 A. I just Q. But you did not want to read it? 6 A. Well, I was never asked of me that 7 question. And like I said, if it was 8 to hurt my case or his case, and when 9 he told me just to go ahead and ask my 10 attorney, I backed off, you know. I 11 did not ask nobody until yesterday 12 when Mr. Keith came into my office. 13 Q. And let me make this clear, too. I do 14 not want to know anything that you 15 talked about with either Mr. Detweiler 16 or Mr. Cahill. But what I would want 17 to know is, did you have any 18 discussions with Mr. Cahill about Mr. 19 Camardelle s deposition? 20 A. No, sir. 21 Q. Alright. Why not? 22 A. I just, being that I could not get no 23 information from the beginning, why 24 ask at the end? 25 Q. What do you mean you could not get no

23 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 21 of information at the beginning? 2 A. Well, I asked the mayor, and he told 3 me that he could not tell me anything 4 and to talk to the attorney. 5 Q. Okay. 6 A. So I did that. 7 Q. Did he tell you he would not tell you 8 anything? 9 A. No. He said, you know, he said, I 10 just do not want to talk about it. He 11 said, I prefer you talking to Keith. 12 Q. Do you remember in 2011 when you were 13 served with the lawsuit? 14 A when I was served with the 15 lawsuit? 16 Q. Do you A. Yes. 18 Q. Do you remember meeting my process 19 server up in Raceland? 20 A. I could have. I m sorry. 21 Q. Okay. 22 A. I don t remember that. 23 Q. When you got the lawsuit, Mr. DuBois, 24 did you read it? 25 A. Yes, sir.

24 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 22 of Q. Did you discuss it with Mr. 2 Camardelle? 3 A. That I don t remember. 4 Q. You knew that both you and he had been 5 named in the lawsuit, correct? 6 A. Yes, sir. 7 Q. And he is the mayor, correct? 8 A. Yes, sir. 9 Q. And my understanding, and correct me 10 if I am wrong, is that he is the only 11 boss you have in Grand Isle? 12 MR. DETWEILER: 13 Objection. 14 BY MR. TRAHANT: 15 Q. Is that right? 16 A. I don t know. I don t know how that 17 could happen because I understand he, 18 well, it is the City Council that 19 controls my budget. But as far as him 20 telling me what to do with this job, 21 he never did tell me. 22 Q. Alright. And so, you got the lawsuit, 23 and you read it, correct? 24 A. Yes, sir. 25 Q. And we are talking back in 2011, the

25 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 23 of same year these criminal trials 2 occurred. Did you go to him and say, 3 David, you know, we need to talk about 4 what is being alleged in this lawsuit? 5 A. It is a possibility I did that. 6 Q. Do you remember anything about where 7 those discussions took place? What 8 you all talked about? 9 A. No, sir. I can t remember. 10 Q. Okay. But before Mr. Detweiler was 11 assigned to represent you and Mr. 12 Camardelle and the Town of Grand Isle, 13 certainly you had discussions about 14 the lawsuit with Mr. Camardelle, 15 correct? 16 A. At some point, we did. 17 Q. Alright. And I m talking about the 18 point where you get sued. Let me ask 19 you this. You do not get sued very 20 often, do you? 21 A. No, sir. 22 Q. And it is not a normal occurrence, 23 correct? 24 A. No, sir. 25 Q. It is a pretty big deal?

26 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 24 of A. Yes, sir. 2 Q. And what was your reaction when you 3 got served with the lawsuit? 4 A. To be honest with you, I was crying, 5 and I did not know why I was getting 6 sued because everything I did was 7 telling the truth, you know. And that 8 is what really got me upset. I tried 9 to do what was right, and I m getting 10 sued. 11 Q. Okay. My question is, when you get 12 the lawsuit, it is a big deal to you 13 obviously? 14 A. It sure was. 15 Q. And you see in the lawsuit that David 16 Camardelle is named as a defendant as 17 well, correct? 18 A. Yes, sir. 19 Q. And you guys work right up and down 20 stairs from one another, correct? 21 A. Yes, sir. 22 Q. And so, do you get together with him 23 and say, we got sued? 24 A. Yes, sir. 25 Q. In fact, was he with you up in

27 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 25 of Raceland when you got served? Do you 2 remember that? 3 A. No, sir, I don t. I don t remember. 4 Q. Okay. 5 A. All I can tell you is like you just 6 said. When I got this paperwork, I 7 went upstairs, and I brought it to 8 him. And I said, did you read this? 9 Q. And what did he say? 10 A. He said, yes. He said, I just don t 11 understand it. 12 Q. Alright. And so, when you had that 13 discussion with him, that would have 14 been pretty close in time to when you 15 got served with the lawsuit, correct? 16 A. Yes, sir, that is what I m saying. 17 When I got my paperwork, yes. 18 Q. Alright. And so, clearly to you from 19 speaking with Mr. Camardelle, both of 20 you understood what the allegations of 21 the lawsuit were, correct? 22 MR. DETWEILER: 23 Objection. 24 WITNESS: 25 Yes, sir.

28 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 26 of MR. TRAHANT: 2 Okay. I would ask Keith, 3 and especially having gone 4 through Camardelle s 5 transcript, you make a lot of 6 objections, but not to the 7 form. If you are going to 8 object to the form, I would 9 appreciate your doing that. I 10 think my question was pretty 11 clear. And so, you guys 12 definitely had at least one (1) 13 discussion before a lawyer came 14 in to represent you all, 15 correct? 16 WITNESS: 17 Yes, sir. I would say 18 that, yes. When I got this 19 paper, I was very upset. And I 20 really did not know what to do 21 in the beginning. 22 BY MR. TRAHANT: 23 Q. To the best of your recollection, what 24 did Mr. Camardelle say when you all 25 got served with the lawsuit?

29 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 27 of A. I don t quite remember what he said at 2 that moment. He just said, I really 3 cannot answer that. I really don t 4 know. 5 Q. What was he like? What did you 6 observe? 7 A. He was upset like me. 8 Q. Alright. And before Mr. Detweiler 9 came in to represent you and Mr. 10 Camardelle and the Town of Grand Isle, 11 did you have any discussions or 12 meetings with Mr. Cahill? 13 A. That is what I was just fixing to say. 14 I am pretty sure I called Chip and 15 asked him for advice. I am not 16 positive, but that is the only that I 17 know that represents us with the town. 18 So I called him. 19 Q. Do not tell me what he told you. I do 20 not want to know what he told you. 21 A. I don t remember what he told me. But 22 I m just saying, I am pretty sure I 23 must have called him. 24 Q. Do you recall whether, shortly after 25 being served with that lawsuit, and as

30 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 28 of you say, Mr. Cahill is the attorney 2 for the Town of Grand Isle. And 3 rationally, you called him. Do you 4 remember if, during that period of 5 time, you and he and Mr. Camardelle 6 had a meeting? 7 A. I can t remember. 8 Q. Do you document any of this, Chief? 9 A. No, sir. 10 Q. And so, any discussions, meetings, do 11 you have a calendar? 12 A. Yes, sir. 13 Q. And so, if you, and I know you want to 14 answer me. Let me finish my question. 15 If you have a meeting with Mr. Cahill 16 and possibly Mr. Camardelle to discuss 17 the lawsuit, would that be on your 18 calendar? 19 A. Yes, sir. But what I am trying to 20 say, I would mark it on my calendar 21 like you said. But every month, when 22 the month is over, I just tear it and 23 put it into the garbage. 24 Q. Your calendar? 25 A. Yes, sir. It is on my desk.

31 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 29 of Q. So then, from month-to-month A. I tear it and put it into the garbage. 3 Q. Why do you do that? 4 A. I don t know. I have been doing that 5 for eleven (11) years. 6 Q. Do you have any A. Now, there is a possibility that maybe 8 my secretary might have that on her 9 calendar because, you know, a lot of 10 times I will tear it off. You know, I 11 had a meeting here, she will mark it 12 down to let me know. Sometimes I will 13 do it myself if I remind her. But 14 insofar as keeping it, I don t. 15 Q. Alright. Do you have any type of 16 written or verbal record retention 17 policy in the Grand Isle Police 18 Department? 19 A. We have a protocol that we have in our 20 coffee shop that they have to follow 21 through. 22 Q. Tell me about that. 23 A. Well, all my police officers are 24 entitled to give out citations or to 25 go out on complaints and all different

32 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 30 of types of arrests or traffic accidents 2 or whatnot and so forth. 3 Q. Alright. I would like to get a copy 4 of that from you, if I could. But my 5 question was regarding a policy of 6 retaining records, like your calendar 7 or s or things that don t 8 necessarily go into an arrest folder. 9 Let me ask this question first. Do 10 you have a written record retention 11 policy? 12 A. I think I do. 13 Q. Alright. Tell me about that. 14 A. Now, can I say something maybe not 15 pertaining to the case, but my 16 secretary passed away about two (2) 17 weeks ago. 18 Q. I understand. 19 A. I am training a new one right now. My 20 secretary is the type of person, Peggy 21 would save everything. If I would ask 22 her for something, she would probably 23 have it. As we speak today, my new 24 secretary probably would not know at 25 all where these files or these things

33 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 31 of would be at. 2 Q. Alright. 3 A. You can come to my office and ask my 4 new secretary. Maybe she could find 5 you all of this information. 6 Q. Let me see if I can better explain 7 what it is I am trying to ask. As far 8 as a written document that says all 9 appointments, all calendars, all 10 s are to be retained for X 11 amount of time. A written document 12 retention policy? 13 A. I am pretty sure that I do not have 14 that. 15 Q. And likewise, there is probably no 16 collective understanding of, hey, we 17 have to save all s relative to 18 any case? 19 A. Well, as far as that, that is a 20 possibility that we have that. 21 Anything concerning an arrest or 22 accident, we should have all of that 23 on file. 24 Q. And so, there would have been s 25 that went back and forth relative to

34 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 32 of this case, correct? 2 A. Yes, sir. 3 Q. And when I say this case, let me be 4 clear on that. The arrest of Mr. 5 Dantin, there would have been s 6 sent back and forth about that, 7 correct? 8 A. The only time that anything that was 9 concerning Mr. Jay was like a subpoena 10 for court and stuff like that. I have 11 a few of those. But as far as 12 paperwork, I don t have too much 13 paperwork about that. 14 Q. Alright. 15 A. With those s sent. 16 Q. I m talking about s having to do 17 with anything. If you had s back 18 and forth with Mr. Toale during that 19 period of time. 20 A. I Q. You met with Mr. Toale, correct? 22 A. I met with Mr. Toale, I think, one (1) 23 time. 24 Q. And that is an example of what I am 25 trying to determine if your office has

35 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 33 of s relative to that case. 2 A. The only one that would have that 3 would be Peggy that probably saved 4 that. But as far as finding them 5 today, I would not know where to start 6 looking for it. 7 Q. And so, if we get to the point where 8 we need to find out what Peggy did and 9 did not save, who would be the best 10 person now to do that? 11 A. Cheryl. 12 Q. And what is Cheryl s last name? 13 A. McCormick. 14 Q. And what is Cheryl s current position? 15 A. Secretary. 16 Q. And how long has she been with the 17 Grand Isle Police Department? 18 A. Eleven (11) years. 19 Q. What was, or go ahead. 20 A. She started at the same time that I 21 did. 22 Q. And what was her position before 23 becoming secretary? 24 A. Dispatcher. 25 Q. Okay. Alright. If you would real

36 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 34 of quickly, and we kind of jumped right 2 into it. Give me a brief rundown of 3 your educational background. 4 A. A high school education. 5 Q. What grade? 6 A. The twelfth. 7 Q. Okay. Did you graduate? 8 A. Yes, sir. 9 Q. From where? 10 A. South Lafourche. 11 Q. Any education after that? 12 A. No, sir. 13 Q. And give me, as best you can, a 14 rundown on your employment background 15 before you became Chief of Police. 16 A. Back in, and I m saying 1972, 1973, I 17 worked with Lafourche Parish as 18 traffic, and sometimes I would go do 19 undercover drugs. I would work with 20 detective, and let me see, Doucet, 21 Kenneth Doucet (spelled phonetically). 22 He was working for the Narcotics 23 Division at that time. I would go 24 ride with him, and I would also do 25 water patrol whenever they had

37 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 35 of functions, fairs, and whatnot. 2 Q. What do you mean water patrol? 3 A. Whenever we had like the Cajun 4 Festival, they would have like parades 5 in the water in front of the South 6 Lafourche High School. And they 7 always had people riding their boats 8 fast. So I was doing a water patrol 9 then to slow them down. 10 Q. Who were you doing that for? 11 A. Lafourche Parish Sheriff s Office. 12 Q. Were you at any point A. This was all volunteer. I was not on 14 a payroll or nothing. 15 Q. Alright. At no point did you have any 16 formal police training, correct? 17 A. No, sir. 18 Q. That is a correct statement, right? 19 A. Yes, sir. 20 Q. Okay. And so, anything you did back 21 in the early 1970s, how long did that 22 last? 23 A. Well, I moved to Grand Isle back in or I was working for 25 Texaco at the time.

38 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 36 of Q. What were you doing for Texaco? 2 A. I was working a gas compressor. I 3 would sell gas to New Orleans and 4 Golden Meadow. That was compressed 5 gas. 6 Q. How long did you do that? 7 A. I did that for the last four (4) 8 years. But the five (5) years before, 9 I was working in the Drilling 10 Department. 11 Q. And so, for how many years did you 12 work for Texaco? 13 A. Nine (9) years. I quit Texaco, like I 14 said, back in, I would say, 1979 or I built a shrimp boat. 16 Q. And then what did you do from 1980 on? 17 A. I did commercial shrimping offshore. 18 Q. And A. For twenty seven (27) years. 20 Q. Do you still have your shrimp boat? 21 A. No, sir. I sold it about twelve (12) 22 years ago. 23 Q. What was the name of your boat? 24 A. Night Star. 25 Q. Alright. And so, tell me what you did

39 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 37 of after you sold your shrimp boat. 2 A. Okay. Well, when I was still 3 shrimping, that was, let me see, back, 4 I think it was, I was elected 5 as a City Councilman. I did two (2) 6 terms. 7 Q. Until when? 8 A. Okay to And then 1998 to 9 about Right now, all together, 10 I am saying two (2) terms on the City 11 Council, three (3) terms as Chief of 12 Police. And right now, I have 13 nineteen (19) years total. So back 14 that up. 15 Q. The math does not have to be right. 16 A. Well, let me see. Eleven (11) years I 17 am Chief of Police, and eight (8) 18 years as a City Councilman. So that 19 would bring back from the time I 20 started. 21 Q. When was the last time you shrimped 22 commercially? 23 A. When I was elected, I sold the boat, 24 and I did full time police work. 25 Q. How many times have you been married?

40 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 38 of A. Twice. 2 Q. Tell me about the sale of your house 3 on Grand Isle. 4 A. Well, I had my house up for sale, and 5 I m just guessing, maybe a year or a 6 year and a half. And I sold it in 7 October or November. 8 Q. How much did you clear off of that 9 sale? 10 A. Four hundred twenty thousand dollars 11 ($420,000). 12 Q. And you did not have a mortgage to pay 13 off? 14 A. Yes, sir, I had a mortgage on my other 15 house. 16 Q. And that is the one in Chackbay? 17 A. Yes, sir. 18 Q. Is that in your name? 19 A. Well, it is underneath my wife and I. 20 Q. If you don t mind, I am going to 21 pronounce Mr. Dantin s name as Dantin 22 because that is how we have been 23 pronouncing it. And I am not trying 24 to be disrespectful to him or you. 25 But for completeness of what we have

41 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 39 of been doing here, that is how we 2 pronounced it. He has been a friend 3 of yours and always has been for about 4 forty (40) years, correct? 5 A. Yes, but can I make a statement on 6 that? 7 Q. Sure. 8 A. I will tell you how I met Mr. Dantin. 9 That was back in 1974 or I am 10 just ball-parking these years. He had 11 built a house in our subdivision where 12 I stayed at. He had a housewarming 13 party. He invited me, which was the 14 first time I had ever met him. We got 15 to be, I mean, I considered myself a 16 friend. But I sold my house after 17 that, about maybe three (3) years 18 after. I had not seen Mr. Jay until 19 he started going out with David s 20 mother. And that is about, and I m 21 just guessing again, ten (10) or 22 twelve (12) years or maybe longer. I 23 don t know. But insofar as me going 24 to some places with Mr. Jay, I never 25 did. I see him like that. I tell him

42 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 40 of hello and goodbye. But insofar as, or 2 I mean, I will say he is my friend. 3 But we never had a close relationship. 4 Q. But you talked to him every day before 5 this happened, didn t you? 6 A. Not quite every day because the times 7 that I would see him would be by Mr. 8 Camardelle s RV park, a little camping 9 place. I would see him there. He 10 would go there. But I mean, I never 11 talked to him every day. I would see 12 him and say hello or goodbye. But 13 that was about it. 14 Q. Okay. 15 MR. TRAHANT: 16 I am going to mark as 17 Exhibit No. 2 Mr. DuBois 18 testimony from the July trial. 19 And then as Exhibit No MR. DETWEILER: 21 He is going to ask you 22 questions about this. 23 MR. TRAHANT: 24 And that is for the sake of 25 the record, that is July of

43 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 41 of And then Exhibit No. 3 2 is Mr. DuBois testimony from 3 September of MR. DETWEILER: 5 You have trial 1, and trial 6 2, and trial MR. TRAHANT: 8 What is that? 9 MR. DETWEILER: 10 How many transcripts do you 11 have there? 12 MR. TRAHANT: 13 Two (2). 14 MR. DETWEILER: 15 Okay. Trial 1 and trial 2? 16 MR. TRAHANT: 17 Yes. 18 MR. DETWEILER: 19 Okay. 20 MR. TRAHANT: 21 And Trial No. 1 is marked 22 as Exhibit No. 2. And Trial 23 No. 2 is marked as Exhibit No MR. DETWEILER:

44 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 42 of Okay. 2 MR. TRAHANT: 3 And if you would take a 4 look at the one marked as Trial 5 No. 2, which is Exhibit No. 3, 6 Mr. DuBois MR. TOALE: 8 Do you have a copy for me? 9 MR. TRAHANT: 10 I think I do, Robert. Hold 11 on for one (1) second. This is 12 No MR. TOALE: 14 I have No MR. TRAHANT: 16 Okay, thanks. And I want 17 you to take a look at the 18 testimony you gave in this 19 trial at Page No. 93. And at 20 the top of that page, the 21 question was, All right. 22 Before this event, did you talk 23 to him on a fairly regular 24 basis? Your answer was, Yes. 25 Always did. The next question

45 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 43 of was, At least once a week? And 2 do you see what your answer was 3 there? 4 WITNESS: 5 Yes, sir, I sure do. 6 MR. TRAHANT: 7 You said, Oh, yeah. Once a 8 day. And so, you would agree 9 with me, Mr. DuBois, that your 10 memory was better in September 11 of 2011 than it is right now. 12 BY MR. TRAHANT: 13 Q. Correct? 14 A. I know the statement that I just told 15 you, maybe the explanation on here was 16 not quite what you asked me. 17 Q. Alright. And for clarity sake, this 18 is the prosecutor in the criminal 19 trial asking you these questions. And 20 I asked you today if you talked to him 21 every day. And you denied that. And 22 now I am showing you testimony where 23 when you were asked if you talked to 24 him once a week, your response was 25 once a day, correct?

46 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 44 of A. On here, yes. 2 Q. And you also testified that you were 3 good friends with Mr. Dantin. 4 A. Well, I just said he is my good 5 friend. A lot of people are good 6 friends, but that does not mean that I 7 talk to them all the time. 8 Q. Okay. Well, that s what I m trying to 9 figure out, Mr. Dubois, how good a 10 friend Mr. Dantin was because under 11 oath in September of 2011, you said he 12 was your friend. He was your neighbor 13 and that you spoke to him every day. 14 Are you denying that as a fact now? 15 A. No, I am not really denying it because 16 I cannot keep tabs of every time that 17 I talk to him. But I mean, he lives 18 next to me. A lot of times when I am 19 going to my house, he lives maybe a 20 couple of hundred feet away from me. 21 And I make a turn, he waves to me, and 22 I wave to him, and that is about it. 23 That is why I maybe said that I see 24 him every day or once a day. I mean, 25 I am not trying to deny what I said as

47 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 45 of far as I have really closer friends 2 than Mr. Jay. 3 Q. Alright. 4 A. I am just saying he is a good friend. 5 Q. He is a good friend, and you had 6 rephrased that testimony, saying you 7 may see him every day. But you 8 understand that that was not the 9 question asked of you in Exhibit No.3? 10 And by your own words, you talked to 11 him at that point in time, once a day, 12 correct? That is what you said, 13 Chief, isn t it? 14 A. I understand. But I don t know how to 15 really, I guess whatever I said. But 16 I am just telling you I lived next to 17 him. When he is outside, I pass. He 18 will tell me hello. And that is about 19 what I mean there, you know. 20 Q. You, or you earlier referenced what 21 you arrested Mr. Dantin for. And I 22 want to talk to you about that. What 23 is your understanding of what you 24 charged him with? 25 A. Sexual battery.

48 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 46 of Q. Alright. Do you know the Revised 2 Statute number? 3 A. It is 14, and I don t remember, sir. 4 Q. Alright. Does ring a bell? 5 A. Yes, sir. 6 Q. Before you charged him, did you look 7 at that statute? 8 A. Well, I mean, we want to make sure 9 that we do things right. We do review 10 it to make sure we do not make an 11 error on the state statute law. 12 Q. Okay. Had you ever read that statute 13 before that day, April 6, 2010? 14 A. No, sir. 15 Q. Okay. And so, if you had not read 16 that statute, Mr. DuBois, you could 17 not have known what the elements of 18 the statute were, correct? 19 A. Well I mean, I read it after the fact. 20 Well like I said, I said after the 21 fact. We wanted to make sure, and 22 really it was Stacy who wrote the 23 paperwork. She was the arresting 24 officer. And I had asked her, what 25 did he charge Mr. Dantin with? Yes,

49 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 47 of Mr. Dantin. And she told me with 2 sexual battery. And when she said 3 that the statute was Q ? 5 A. Okay. I looked at it to see what it 6 had said. And it matched up fairly 7 well. 8 Q. Where did you look at it? 9 A. In my booking room. 10 Q. And you have statute books in there? 11 A. Yes, sir. 12 Q. At what point did you look at it? 13 A. I probably did that on that day or the 14 day after. 15 Q. And that would have been after you 16 cuffed him. Is that right? 17 A. Yes, sir. 18 Q. And so, what I am trying to figure 19 out, and maybe you have already told 20 me, and I am not understanding it. At 21 the time you put the cuffs on Mr. 22 Dantin and read him his rights and 23 arrested him, you had not read that 24 statute, correct? 25 A. No, sir.

50 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 48 of Q. And so, you would not really have 2 known what the elements of that 3 statute were, correct? 4 A. No, sir. 5 Q. Okay. And so, you made an arrest, not 6 really even knowing what you were 7 arresting him for, correct? 8 A. My officer put the handcuffs on Mr. 9 Dantin. She was the arresting 10 officer. She did the paperwork. 11 Q. Are you aware of the fact that 12 everybody who has testified in this 13 case, including you, and I can show 14 you your testimony, said that you put 15 the cuffs on him. 16 A. I don t remember. 17 Q. But that is pretty important, isn t 18 it? 19 A. I don t remember. 20 Q. Alright. 21 A. I really don t. 22 Q. And so, when you, when you looked at 23 what I am going to mark MR. TRAHANT: 25 When you looked at what I m

51 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 49 of going to mark as Exhibit No. 4, 2 and for the record, I am 3 marking a copy of Louisiana 4 Revised Statute 14: BY MR. TRAHANT: 6 Q. Can you tell me, Mr. DuBois, which of 7 the parts of this particular statute 8 Mr. Dantin violated? 9 A. The touching of the anus and the 10 genitals. 11 Q. Are you talking about A2? 12 A. No. It s A1, but wait. Let me read 13 it right here. It would be No. 1. It 14 would be A1. 15 Q. A1, the touching of the anus or the 16 genitals by the victim of the offender 17 using any instrumentality or any part 18 of the body of the offender. And so 19 that would mean the victim, the young 20 boy got his anus or genitals touched 21 by the offender, correct? 22 A. Yes, sir. 23 Q. That would mean that the victim, in 24 this case the little boy, got his anus 25 and genitals touched by the offender,

52 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 50 of correct? 2 A. That is what it says right here. 3 Q. Okay. 4 A. But I thought it was the opposite. 5 Q. Sure. And that would be No. 2 and not 6 No. 1, correct? 7 A. Yes. 8 Q. And so, as you sit here, Chief, you do 9 not even really have an understanding 10 of which part of the statute Mr. 11 Dantin had violated, even after having 12 arrested him, correct? 13 A. But doesn t the state statute cover 14 this? 15 Q. I am asking you, as you sat here, you 16 thought you had arrested him under 17 14:43.1, Section A1. And now you 18 acknowledge that, based on what was 19 said, and we are going to talk about 20 what was said. It really would have 21 been A2, correct? 22 A. Yes, sir, according to this right 23 here, yes. 24 Q. Okay. Now, I want to talk to you, Mr. 25 DuBois, about the period of time

53 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 51 of leading up to April 10 or April 6, I m 2 sorry, of Did you become aware 3 that Mr. Camardelle knew about these 4 allegations for several days before 5 you became aware of that? 6 A. No, sir. I did not know nothing about 7 it. 8 Q. Okay. You don t remember him 9 acknowledging that he already knew 10 about it when you called him down to 11 go pick Mr. Dantin up? 12 A. When maybe I called the mayor to go 13 pick up Mr. Dantin, maybe he said, 14 well it is because of, and I am trying 15 to think of the man s name that talked 16 to him. But I did not know nothing. 17 Q. (John Doe s father)? 18 A. (John Doe s father). I do not know 19 nothing before that lady came to my 20 office. 21 Q. Okay. Now, if Mr. Camardelle has 22 admitted that he knew about these 23 allegations for five (5) days before 24 April 6, 2010, is that something you 25 were aware of before today?

54 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 52 of A. Yes. He had told me that. I learned 2 that after, but I mean, insofar as me 3 knowing about these allegations about 4 Mr. Dantin, no, I did not know nothing 5 until that lady came into my office. 6 Q. I understand that. And what I am 7 talking about right now is when you 8 found out that the mayor had known 9 about this for five (5) days and did 10 not tell you, as the police chief, 11 what was your reaction? 12 A. I asked him, I said, mayor, I said, 13 why you didn t let me know or why, and 14 what is that man s name again? 15 Q. (John Doe s father). 16 A. (John Doe s father), why didn t he 17 come tell me? And he said, well 18 chief, he said we were upstairs, and 19 he said, let s go downstairs and tell 20 the chief what is going on. And the 21 mayor told me, he said, no. He did 22 not want to do that. He wanted to 23 wait until he wants to get more 24 information to make sure that this 25 happened.

55 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 53 of Q. When did you have that conversation 2 with Mr. Camardelle? 3 A. After the fact that I had been told. 4 Q. And when you say after the fact, can 5 you be a little bit more specific? 6 A. That was after when the ladies who 7 were at my office to tell me about it. 8 That was when I found out, after. 9 Q. Okay. 10 A. That (John Doe s father), whatever his 11 name is, went to David and talked to 12 him about it. 13 Q. When did you have that conversation 14 with David? 15 A. That was after that lady told me. 16 Q. Alright. But before you sent him to 17 pick up Dantin? 18 A. I don t know if he told me right at 19 that time or after that. But I know 20 that I did not know nothing about it. 21 Q. When you, and what was your response 22 to that? You are the police chief of 23 Grand Isle? 24 A. I said, after that I said, I cannot 25 believe this is happening, you know.

56 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 54 of I said, I mean, really? 2 Q. Okay. But aside from not believing 3 that it happened, you are the police 4 chief, right? 5 A. Yes, sir. 6 Q. And this is a felony, correct? 7 A. Yes, sir. 8 Q. And he was arrested for a felony? 9 A. Correct. 10 Q. And so, when you find out that the 11 mayor has failed to inform you for 12 five (5) days of a felony, does that 13 make you mad? 14 A. Yes, it sure did. 15 Q. Alright. And so, when you had the 16 discussion with the mayor when the 17 ladies were there on April 6, about going to pick up Mr. Dantin, you 19 had a discussion with Mr. Camardelle 20 as to what this was all about, 21 correct? 22 A. After the fact. 23 Q. Okay. When you say after the fact, I 24 need to know which fact you are 25 referring to.

57 Case 2:11-cv JCZ-SS Document 79-1 Filed 03/26/15 Page 55 of A. Okay. Well, this is what I told 2 David. I said, David, you have three 3 (3) ladies down here that would like 4 to talk to Mr. Dantin. I said because 5 he did something. I said, I don t 6 want to go by your mama s house and 7 get a police unit out there. Your 8 mama is already sick. I do not want 9 to get her all excited and maybe get a 10 heart attack. I said, if you don t 11 mind, go pick up Mr. Dantin and bring 12 him to my office. I have got to talk 13 to him. 14 Q. Alright. But my question was more 15 along the lines of, what did you tell 16 Mr. Camardelle they were saying Mr. 17 Dantin had done? 18 A. I don t remember telling the mayor 19 about what they had told me about it. 20 Q. Okay. 21 A. There is a possibility I might have 22 told him. And like I said, I don t 23 remember, you know. I said, they told 24 me that maybe Mr. Jay molested a six 25 (6) year old child here. There is a