Jeffrey Mark Burden February 19, 2015 Page 1 Page 2 UNITED STATES DISTRICT COURT 1 EASTERN DISTRICT OF KENTUCKY 2 NORTHERN DIVISION AT CASE NO. 2: 1 3 4 5 MARK BURDEN, in his capacity as 6 Personal Representative of the ,7 Estate of and Next Friend of Danny Ray Burden, Deceased PLAINTIFF GRANT COUNTY, KENTUCKY, ET AL DEFENDANT 1 4 5 JEFFREY MARK BURDEN, SR. DEPONENT: JEFFREY MARK BURDEN, SR. 1 6 FEBRUARY 19? 2015 17 8 REPORTER: JESSICA TAYLOR TAYLOR COURT REPORTING KENTUCKY 2 4 2901 SIX MILE LANE 2 5 LOUISVILLE, KENTUCKY 40220 Page 3 Page 4 1 2 APPEARANCES 2 APPEARANCES 3 3 4 4 5 JUMP AND JASON A. HANKINS: 6 Christopher L. Thad-(er, Esq. . ES 7 7 8 153hdmketSUEd: 9 Lexington, Kentucky 40507 9 Lexington, Kentucky 40507 1 0 Te'ephonei (359)235'5240 1 0 Telephone: (859)225-1400 11 11 12 Email: 12 EmailCOUNSEL FOR DEFENDANTS, ADVANCED CORRECTIONAL 4 COUNSEL FOR DEFENDANTS, GRANT COUNTY FISCAL HEALTHCARE, INC, CELESTE KIEFNER (NURSE), COURT, GRANT COUNTY, KENTUCKY, GRANT COUNTY 5 EDNA M. HARRISON (NURSE), UNKNOWN EMPLOYEES OF 15 DETENTION CENTER, AND TERRY PEEPLES, RICHARD ADVANCED INC.) AND CLISE, LTSA MENTRUP, TONYA BEAGLE, TROY HALE, 1 6 DR. NADIR (DOCTOR). 1 6 MEGAN TEETERS, BARRY GREEN, ROBERT HOWELL, ERIC 1 7 MORRIS, FRED JERNIGAN AND ADAM WHITNEY: 7 1 Colleen C. Hartley, Esq. I 1 8 Jeffrey C. Mando, Esq. 9 AND PLLC 1 9 ADAMS, STEPNER, WOLTERMANN AND DUSING, PLLC 2? 20 40RERPResuet 2 455 .So'uth Fomth Sweat 2 1 Covington, Kentucky 41011 2 2 Lou?sv?lles Kentucky 40202 2 2 Telephone: (859)394-6200 23 'Fdephonert502)585-4700 23 2 4 Facsimile: (502)585-4703 24 Email: 2 5 Email: hartleyc@obtlaw.com 2 5 1 (Pages 1 to 4) Taylor Court Reporting Kentucky 671?8110 (502) Jeffrey Mark Burden February 19, 2015 Page 177 Page 178 1 estate. 1 A. So yeah, we can -- I have no 2 A. Well, the estate, but my mom. 2 motive. 3 Q. Okay. And so what is the purpose 3 Q. Yeah. Welt, when you decided to 4 of the lawsuit? 4 ?le this lawsuit, did you sit down with your 5 A. I -- you know, I kind of think that 5 brothers or sisters, the remaining siblings, and 6 at some point something has got to change up 6 talk about this lawsuit? 7 there. And obviously, you know the Grant County 7 A. There was a discussion. A sit?down 8 Iail system, you -- I mean, you guys are with 8 discussion, I don't remember how it was. There 9 or attorneys from that. You know that 9 was a discussion. 1 0 there's been issues up there for a long time, 10 Q. Was evelybody there? 1 1 it's on the news. It's not anything new. 1 1 A. I don't know -- they could have 12 There's nothing changing up there. And if 12 been. Eveiybody was talked to. 13 anything comes out of this that makes a change 1 3 Q. Okay. 1 4 where it's a punitive thing or whatever it may 1 4 A. I can say that everybody was talked 15 be, something needs to change. 1 5 to. I was thinking they was, including Amy. 16 Q. Okay. Well, that's whyI asked the 6 MR. CALDWELL: Okay. I think 17 question. I wanted -- I wanted to feel -- ?nd 17 that's all I have. 1 8 out what your motivation was in relation to -- 1 8 MS. HARTLEY: I just have two more 1 9 A. I have no monetary motivation. 1 9 questions. 20 Q. No, I know that. 2 0 THE WITNESS: Okay. 2 1 A. I don't get nothing out of this. 2 1 (Off the record comments.) 22 Q. Oh, I know that. You'the heirs -- 2 3 2 4 A. Yeahterms of the money. 2 5 Page 179 Page 180 1 EXAMINATION 1 THE VIDEOGRAPHER: Any further 2 BY MS. HARTLEY: 2 questions? 3 Q. Just two more questions. 3 MR. CALDWELL: No. 4 To foliow Mr. Caldwelt's 4 THE VIDEOGRAPHER: We'll now close 5 questioning regarding your personal knowledge of 5 the Video record. The time is approximately 6 the alEegations within the complaint, the same 6 2:25 pm. 7 would be true for my ciients, as welt, in that 7 8 you don't have any personal knowledge. 8 9 Is that correct? 9 (Witness Excused.) 10 A. Ofall ofthe 10 1 1 Q. Of the allegations. ll 12 A. Yes. Yes. It's based upon the 12 13 investigation, so I don't have personal 13 1 4 knowledge. 1 4 15 Q. And then before you ?led this 15 1 6 lawsuit, had you heard of Advanced Correctional 1 6 1 7 HealthcareAnd you don?t personaliy know any 1 9 2 0 of the defense -- any of the defendants in this 2 2 1 case. 2 1 2 2 Is that correctdon't personally. No. 2 3 2 4 MS. HARTLEY: Okay. Those are all 24 2 5 the questions I have. 2 5 45 (Pages 177 to 180) Taylor Court Reporting Kentucky (502) 671*8110