Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA - - - - - - - - - - - - - - - - - - - X AMERICAN SOCIETY FOR THE PREVENTION OF CRUELTY TO ANIMALS, et al., Plaintiffs, v. : : : Civ. No. : 03-02006 RINGLING BROTHERS AND BARNUM & BAILEY : (EGS) CIRCUS, et al., Defendants. : : - - - - - - - - - - - - - - - - - - - X Washington, D.C. Wednesday, October 24, 2006 Videotaped deposition of GARY JACOBSON, called for examination by counsel for the Plaintiffs in the above-entitled matter, pursuant to notice, the witness being duly sworn by CARLA L. ANDREWS, a Notary Public in and for the District of Columbia, taken at the offices of Meyer, Glitzenstein & Crystal at 1601 Connecticut Avenue, Northwest, Suite 700, Washington, D.C. 20009-1056, at 10:11 a.m., Wednesday, October 24, 2007, and the proceedings being taken down by Stenotype by CARLA L. ANDREWS and transcribed under her direction. WC 175 Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 APPEARANCES: On behalf of the Plaintiffs: KATHERINE A. MEYER, ESQ. KIMBERLY D. OCKENE, ESQ. TANYA M. SANERIB, ESQ. Meyer, Glitzenstein & Crystal 1601 Connecticut Avenue, Northwest Suite 700 Washington, D.C. 20009-1056 (202) 588-5206 On behalf of the Defendants: LISA ZEILER JOINER, ESQ. MICHELLE C. PARDO, ESQ. JULIE ALEXA STRAUSS, ESQ. Fulbright & Jaworski, L.L.P. 801 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2623 (202) 662-0200 ALSO PRESENT: CONWAY BARKER, Videographer Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 C-O-N-T-E-N-T-S WITNESS GARY JACOBSON By Ms. Meyer E-X-H-I-B-I-T-S NO. Exhibit 1 Exhibit 2 Exhibit 3 IDENT. 6 6 6 EXAMINATION BY COUNSEL FOR PLAINTIFFS 5 Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 P-R-O-C-E-E-D-I-N-G-S THE VIDEOGRAPHER: In the United States District Court for the District of Columbia in the matter of American Society for the Prevention of Cruelty to Animals et al., versus Ringling Brothers and Barnum and Bailey Circus et al., Case No. 03-2006 EGS/JMF. This is the deposition of Gary Jacobson. Today's date is October 24, 2007. The location of the deposition is Meyer, Glizenstein & Crystal, 1601 Connecticut Avenue, Northwest, Washington, D.C. Will counsel please identify yourselves and state whom you represent? MS. MEYER: Yes. I'm Katherine Meyer, and I represent the plaintiffs. MS. OCKENE: Kimberly Ockene, also representing the plaintiffs. MS. JOINER: Lisa ZEILER JOINER, Fulbright & Jaworski, on behalf of the defendant and witness Mr. Jacobson. MS. PARDO: Michelle Pardo, Fulbright & Jaworski, on behalf of Feld Entertainment and the Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. In where? Ocala, Florida. Okay. So was the plan, as I understand it, to get some African elephants from Mr. Jones and exchange those elephants for Joyce? A. I told you I cannot remember for sure if we were talking about some that were coming in because several people were importing at that time, or if we were going to acquire some from Arthur Jones. Q. A. Q. Okay. And, Mr. Jacobson, where do you work? The CEC. And the CEC is the Center for Elephant Conservation? A. Q. A. Q. A. Q. manager? A. Q. Not really. I think I saw on a document somewhere that Yes. And that's owned by Feld Entertainment? Yes. And what are your duties there? I'm the general manager. Do you have any other titles besides general Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 you're also the director of training; is that correct? A. Q. A. Q. Yeah. That was an old card. Excuse me? That was on old business card. But that's not a title that you currently use -- director of training? A. Q. A. Q. manager? A. Q. A. years. Q. January 2000 is when you became the general I think it was January 2007 or February. January 2007 is when you -I mean 2001 -- 2000. I'm sorry. Seven Not anywhere. Okay. Right. And how long have you been the general Just the general manager? manager of the CEC? A. Q. Uh-huh. And did you work at the CEC before you became the general manager? A. Q. Yes. When did you start at the CEC? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. June 26th. What year? 1995. And when you started at the CEC, what was your title? A. Q. Director of training. And who was the general manager at the CEC when you started at the CEC in 1995? A. Q. A. Q. A. James Williams. And he's still there, right? Yes. And what is his title now? It's very long. I don't think I've seen it on paper in a long time. Q. the CEC? A. Q. No. He's not. Are you above him in the hierarchy Okay. Is he above you in the hierarchy at at the CEC? A. Q. Yes. Can you describe your duties for me as the general manager of the CEC? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. elephants. Q. A. Q. the CEC? A. Q. A. Q. I oversee the current management of the Anything else? That pretty well describes it all. Okay. Do you supervise other employees of Yes. Who do you supervise? All of them. Okay. Can you tell me the names of the How many employees are individuals and what they do? there at the CEC? A. I believe at the present time there are 14 counting myself. Q. Could you name the employees and tell me what each employee's basic responsibilities are? A. Q. A. Q. A. Q. Sure. Okay. Jim Williams. And his responsibilities? He is sort of my right-hand man. All right. And then there would be Pat Harned. Pat Harned? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. elephants. Q. elephants? A. Q. A. Q. A. Q. Harned, right. H-a-r-n-e-d? I believe that's correct, yes. What are his duties? He is the operations manager. What does that mean? He helps me handle the day-to-day operations. Okay. Who else? Then it would be Kathy Jacobson. She's your wife? Yes. What is she -- what are her responsibilities? She takes care of mainly some of the young She takes care of some of the young Yes. And it's Kathy with a K, right? (Nodding.) Okay. Who else? Trudy Williams. Is she related to Jim Williams? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. sure. Q. A. Q. And what is his job? He is also an elephant handler. And when did he start to work at the CEC? I think it was '98, I believe. I'm not quite Did he precede Shawn Quinn or? They came at about the same time. Okay. Had they known each other before they started working at the CEC? A. Q. I don't think so. And does Mr. Garcia have responsibility for any of the young elephants? A. Q. No. And when I say "young elephants" and you're answering my questions about young elephants, which elephants are we talking about? MS. ZEILER JOINER: BY MS. MEYER: Q. When you are referring to the young Objection to form. elephants, which elephants are you referring to? A. Q. The ones that would be like 10 or less. Okay. Let me read off some names, and you Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 tell me if these are -- you consider these to be young elephants, okay? A. Q. A. Q. Irvin? A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Yes. Arie? Yes. PT? Yes. Asha? Yes. Rudy? Yes. Gunther? Yes. Sarah? Sarah? Osgood? Yes. Yes. Okay. Mable? Yes. Bertha. I'm sorry. Bertha is deceased. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Angelica? Yes. Doc? Yes. Kelly Anne? Yes. Shirley? Yes. Bonnie? Yes. Romeo? Yes. Juliet? Yes. Are there any others that I haven't named that you consider to be young elephants? A. You read those pretty fast. I think that was all of them, wasn't it? Q. I think that was all of them. You probably know them better than I do. That's my list of the elephants that That's my list. were born at the CEC. A. Yes. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. Q. before? A. Q. A. Q. A. Q. A. But it is a casino? Sort of, yeah. What elephant were you acquiring? An elephant named Petely. Is that different than the Pete you mentioned No, the same one. And where did you acquire Pete from? Rex Williams. Who is Rex Williams? He is deceased. Who was Rex Williams? A good friend of mine. He was the elephant trainer on Circus Vargus. Q. A. Q. Did you train under him at all? No. And it seems from your testimony so far that your specialty is training young elephants; is that correct? A. Q. elephants? I guess so. I mean, yes. Okay, yes. And where did you learn how to train young Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. under him? A. Q. William Woodcock. Is he also known as Buckles Woodcock? Yes. And when did you work with Mr. Woodcock or The first time was 1972. And was that the first time that you had any training in handling elephants? A. Q. Yes. And how did you come to work for Mr. Woodcock? A. I was on Carson and Barnes Circus, and Mr. Woodcock came there right after Labor Day as near as I can recollect. Q. Circus? A. Q. A. Q. A. Handling their elephants. Oh, you were handling their elephants? Yes. What were your responsibilities? To feed, water, clean up, general management, What were you doing on Carson and Barnes care and management. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. them? A. Q. A. Q. And Mr. Woodcock was hired to come and train They were partially trained. Who were they partially trained by? I do not have a clue. But Mr. Woodcock was hired to come in and further train them? A. Q. Yes. And is that how you learned initially to train young elephants under Mr. Woodcock when he was training Bunny and Betty? A. Q. No. It was the start of it. And did you That was the start of it, okay. receive your training from anyone else besides Mr. Woodcock? A. Q. Robert Smokey Jones. Okay. And when did you train under Robert Smokey Jones? A. I didn't actually work for him. I just kind of helped him. Q. A. And when was that? 1982. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 104 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. I am just trying to find out what methods you would use to correct an elephant? A. have done. Q. elephant? A. Q. elephant? A. Q. A. Q. Yes. How would you use it to correct an elephant? It depends on what they are doing. What if they were not doing what you wanted I carry a bull hook. Would you ever use one to correct an Would you ever use a bull hook to correct an All that would probably depend on what they them to do? A. Normally, you can just pull them to you, and they will stop. Q. A. Q. A. Q. A. Pull them how? Like this. With your hand? No. Pull them how? With the hook. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 105 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. With the hook at the end of the bull hook? Uh-huh. You would use the hook to grab the elephant by its skin and pull it towards you? A. Q. Yes. And if that didn't work and the elephant still was not doing what you wanted it to do? A. Q. That would work. That would always work. Have you ever had to hit an elephant with a bull hook to correct it? A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Yes. When is the last time you had to do that? Probably six months ago. Which elephant was it? Smokey. Smokey? Uh-huh. You own Smokey; don't you? Yes. How long have you owned Smokey? Since '92 or '93. How did you come to own Smokey? Which elephant? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 153 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. And how much time do the elephants spend per day grazing? A. Q. A. Q. A. Q. A. Q. A. Q. A. Jewel. The ones that go outside, from about 7 to 3. And which ones go outside? You want the names? Yes. Okay. Yes. Icky, Alana, Mala, Joskey, Sally, Louis. Lilly? Louis. Louis. Sid. And Toba, Litsy, Susan, Mysor, Zyna, Ready? And sometimes the young elephants when they are with their mothers go out. Q. A. How often is that? Normally it is every day when we have cows that have calves nursing with them. Q. A. I am sorry? It's Normally every day that we have cows If the calves are with their with calves out there. mothers, they go out there and feed with them. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 154 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. When you say if the calves are with their Is that what mothers, you mean if they are nursing. you mean? A. Q. Right. But if they are not nursing, they wouldn't be outside with their mothers? A. Q. No. And you said before -- I think you said before that the male elephants are never chained at the CEC; is that correct? A. Q. A. Q. The adult males. The adult males. The ones that are not handled. I see. Are the younger males chained at all during the day? A. Q. A. Yes. How long are they chained for? They get turned outside about seven and come in about three. Q. A. Q. And the rest of the time they are in chains? Yes. And how are they chained? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 155 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. chained? A. Q. A. Front and back. And are they kept in stalls when they are Most of them, no. Where are they kept? There's actually, none of the -- Doc is in the big barn. Q. Other than Doc, where are the other young elephants who are chained kept when they are chained? A. awning. Q. A. Q. A. Who is that? I mean under a tent actually. PT, okay. Then there is another one, Gunther, under a PT. There is one on a cement slab under an shade structure. Q. A. Q. A. Q. A. Is that also a concrete structure? Yes. Or a flooring? Uh-huh. Okay. And then the rest -- Smokey is tied in the Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 156 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 barn. Q. A. Q. barn? A. Q. A. Q. A. Q. A. Q. A. Q. males now? A. Right. Ervin is in the main barn, but he is Right, the main barn. So is Smokey in chains? Yes. And is it also just two legs? Yes. Front and back? Correct. And Doc, you said, is in the big barn? Right. Anybody else? We are just talking about the Is that the same barn that Doc is in? Yes. That's one that you referred to as the big loose in a paddock or a pen. Q. A. Q. A. Is he with his mother? No. Who is his mother? Alana. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 157 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. All right. Who else? And is that -- in the main barn, is there a concrete floor as well? A. Q. A. Q. A. barns. Q. These are the -- The other males you are Yes. Who else? And the other males are all loose. Loose? In the yards or in the barn -- in the male talking about now are the males that are not handled? A. Q. A. Q. list. A. Q. A. Q. A. Q. A. He doesn't go on the grass yards. Oh. Where does Smokey get to go? Right, that are not handled, correct. And Does Smokey get to go outside, too? In the yards, yes. He does, because I don't think he was on your In the other yards. They are not grass yards, though? No. What kind of substrate? Sand. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 158 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. the grass? A. Q. A. Q. A. Sand. Why is Smokey treated differently? Than what? Than the other elephants who get to go out on None of the males go out on the grass. Oh, none of the males go out on the grass? Except when they are young. And why is that? Because they will probably tear the yard down and go out of the yard. Q. What about at nighttime? Are the male elephants chained during the night? A. Q. A. Q. elephants? A. Q. A. Q. A. The older males? Yes. They are out in the yards loose. They sleep out there? Yes. Which males? The young elephants. Yes. Yes. Okay. And what about the older Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 159 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. What about the female elephants, other than-Do they spend what about the young female elephants? time outside? A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Yes. How much time do they spend outside? Every day from about 7 to 3 or 3:30 or 4. And where are they when they are not outside? They are under a tent. Are they together? Yes. Are they chained? Yes. They are under a tent? Uh-huh. Is the tent-The tent is under a metal building. Is the tent actually under a metal building -A. Q. Yes. Or is the metal building what you are referring to as the tent? A. No. There is a tent under the metal roof. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 160 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. And how many female elephants spend time under the tent? A. Q. A. Q. Three. And who are they? Angelica, Asha, and Ruby. And when they are chained, are they chained on two legs? A. Q. A. Q. Yes. Front and back? Yes. And what about during the night? Are they chained during the night? A. Q. A. Q. Yes. If the same area? Yes. So that -- And does that area also have a concrete substrate? A. Q. Yes. And what about the adult males -- or sorry, You mentioned that they spend some time adult females. outside, I think you said, between 7 and 3 as well; is that correct? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 161 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. Roughly, right. And where are the adult females when they are not outside? A. Q. A. Q. A. Q. A. Q. They come into the main barn. And do they each have their own stall? Some of them are in stalls. Okay. Emma. Emma? Is in a stall. I don't have her on the list. Does Emma get Which ones are in stalls? to spend time outside? A. Q. A. Q. A. Yes. From Seven to three? No. How much time does she get to spend outside? She is outside for about an hour in the morning, hour and a half in the morning. Q. A. Q. A. When she is not outside, where is she? She in the barn -- main barn. Okay. Uh-huh. The main barn. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 162 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. a half? A. Q. A. Q. And she is in her own stall? Yes. And is there a concrete substrate? Yes. And is she on chains? Yes. Front and back? Yes. And is she also chained throughout the night? Yes. In the same area? Uh-huh. Why is Emma only allowed out for an hour and Because she baby-sits Shirley and her calf. Who is Shirley's calf? Mabel. Does that mean Shirley's calf and Shirley are also in the same place as Emma-- at the same place as Emma? A. Q. Yes -- not in the same place; next to. Is there some kind of -- Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 163 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Partition. -- partition between them? Uh-huh. What kind of partition is it? Pipes. Can they actually interact with each other? Yes. And how do they do that? Reach in through the pipes. With their trunks? Yes. Is there any other way that they can interact I mean, is it just with their trunks? with each other? A. Well, they can stick their legs through there if they want to. Q. A. But you said Emma was on chains. That doesn't make any difference. They can still stick their legs through there. Q. Oh, okay. And is -- are Shirley and her baby also on chains? A. Q. Shirley is. I am sorry? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 164 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. Shirley is. Shirley is. No. And is the stall that they are in, does it But Mabel is not? also have a concrete substrate? A. Q. A. Yes. And how long is Shirley on chains? Most of the day, except when she is outside with her calf. Q. A. Q. night? A. Q. night? A. Q. elephants? A. Q. A. No, no. So the elephants don't do any swimming there? No. Absolutely. Is there a place to swim at the CEC for the Yes. And does the calf stay with her during the How many hours a day does she spent outside? Probably about an hour and a half. Is she, is Shirley also chained during the Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 173 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 said you use the bull hook sometimes to bring an elephant to you. A. Q. do that? A. Q. Yes. And so do you actually hook the bull hook Yes. Do you use the hooked end of the bull hook to into the skin of the elephant and pull the elephant toward you? A. Normally, you are saying come here and then you move the hook. Q. But does the hook have physical contact with the elephant when you are doing that? A. Q. they? A. Q. Yes. Does that cause any discomfort to the Sometimes. And elephants have sensitive skin, don't elephant when you do that? A. Q. You would have to define discomfort. Do you think the elephant feels that bull hook on its skin when you use the bull hook in that Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 197 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 them, so I don't use them. Q. But if you wanted to use one, you could; is that correct? A. Q. I don't know. I never -- As far as you know, there is no policy against it; is that correct? A. so -Q. A. I am sorry? It wouldn't be for training them, anyway. It wouldn't be for training them, anyway, Whips are mainly just for show. Q. You are familiar with a tool called an electric prod or a hot shot? A. Q. Yes. Is that the same thing -- an electric prod and a hot shot? A. Q. A. Sure. What is it? They are used for moving around cattle and hogs and various other animals. Q. A. And how do they work? They produce an electric shock. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 198 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. Q. A. Q. years? A. Q. A. Have you ever seen one? Yes. When have you seen one? Almost every day for 35 years. Where? Everywhere. You see them everywhere every day for 35 You see them at the CEC? Yes. Oh. What are they used for at the CEC? To make sure the males don't jump on me when I am collecting semen. Q. A. Oh, you use them on the male elephants? No, We do not use them on the males. We have them for safety only. Q. I don't know what that means. Can you explain that to me? A. Certainly. When I am on my knees under the males collecting semen, there's a hot shot nearby in case it tries to jump on me or grab me or kick me around or I should have a heart attack and fall underneath it or something. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 199 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. I see. Have you ever had to use a hot shot on an elephant? A. Q. A. semen. Q. A. Q. A. Q. When was that? A month ago. Okay. Raja. And when was the -- before that when was the Which elephant? Yes. When was that? Whoo -- the last time. I guess collecting last time you had to use a hot shot on an elephant? A. Q. A. Q. A. Q. A. Q. truck? A. Well, I don't know if it's a matter of him A year ago last November. Which elephant? It was loading Casey. To go to the Forth Worth Zoo? Uh-huh. Why did you have to use a hot shot? So he would get up in the truck. Because he didn't want to get up in the Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 200 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 not wanting to get up in the truck. Q. A. Q. A. Q. He wasn't getting up in the truck? He did not get up in the truck. Okay. And-- Rather than drug them. Okay. Can you recall any other times you have used a hot shot on an elephant? A. them. Q. A. Q. When you collect semen? Yes. Oh, okay. What do you mean by that -Collect the males? Occasionally with a male when we collect correct them for what purpose? A. Q. Occasionally when you collect semen. Oh. Did you mean anything else other than collect semen -A. Q. A. Q. No. -- when you said that? No. Okay. Collect is to collect semen. And have you ever seen anyone else who works for Feld Entertainment use a hot shot on an elephant? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 218 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 back into the corner. You do that for a couple of weeks, and they are used to being up steadied against something. You move them four or five feet from the corner, do it again, and they automatically go up. There is nothing to it. Q. Simplest thing in the world. Okay, but you can make a 14,000 pound-- I How much do they weigh when you guess they are little. are training them? A. Q. Two or 3,000. Okay. You can make a 3,000 pound animal back up into a corner just by holding its trunk? A. Q. A. Yes, absolutely. Why would that make the elephant back up? Because I have asked him to. He is trained to back up. Q. A. Q. A. How do you train him to back up? I already went through that. Oh, okay. That was the -If you see wild They back up really easy. elephants or zoo elephants or circus elephants, they spend half of their time backing up. Q. Now, did you learn how to teach an elephant Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 219 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 to do these commands from Smokey Jones? A. Q. A. Most of it. The ones that we have gone through? Most of it because it was just -- it was more scientific. Q. And did you use the methods that he used as well for elephants? A. Q. A. Q. Smokey? Yes. Yes. And what about -- is standing up, as you described it, by an elephant on its hind legs, a natural position for an elephant? A. They climb on one another. They will climb up into a tree. They will be virtually straight up. They will stand up on their hind legs and pull fruit out of a tree, pull limbs down. Q. It is fairly common. But I am asking whether or not standing up just on two hind legs with the two front legs in the air is a natural position for an elephant? A. Q. Yes. They can walk on their hind legs. Now, what about is "sit up" a command? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 239 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. point? A. Q. program? A. Q. program? A. Q. No. So she may go back out on the road at some She may. Is Angelica being used in the breeding No. Is she going to be used in the breeding Probably. What about Mysor? Is Mysor being used in the breeding program? A. Q. A. Q. A. Q. No. Why not? She is 65 years old. So she is too old for it? Yeah. How long was the quarantine by the State of Florida imposed on the CEC? A. Q. Pardon? You said there was a quarantine imposed by the State of Florida on the CEC -- Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 240 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Yes. -- because of TB? Yes. How long was the quarantine for? Indefinite. Is it still in operation? Yes. When was it imposed? I am not even sure. You have no idea? It has probably been a year and a half. And when -- under what circumstances will the quarantine be lifted? A. When all of the elephants are treated in accordance with the guidelines. Q. A. Q. elephants? A. It means that the bulk of them -- the Which guidelines? The USDA guidelines. And what does the quarantine mean for the CEC elephants in the main barn cannot leave. Q. Cannot leave the CEC or leave the main barn? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 241 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. anyway. Q. A. Cannot leave the CEC. And what about the other elephants? The males, of course, wouldn't go anywhere Older males? Right. And there is young elephants that are housed away from the other elephants. Q. Which young elephants are housed away from the other elephants? A. Q. A. Q. A. Q. Gunther, PT, Rudy, Asha, and Angelica. And where are they housed? In separate quarters. Are they all together? No. Can you be more specific about where each of Let's start with these elephants is housed at the CEC? Gunther. A. All right. He lives at night under a metal roof on a cement slab. Q. A. Q. Is he chained? Yes. Is he by himself? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 242 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. A. Q. A. Q. A. Yes. Where is he during the day? He goes in one of the yards. Is he with other elephants during the day? No. Is he chained? No. Why is he kept by himself? He is a very aggressive six-year-old male that will either get hurt or hurt another an elephant. Q. A. Q. A. Has he come into musth yet? No. PT. Where is PT? The other four are kept under a tent under a metal roof. Q. substrate? A. Q. Yes. And are they together in one area or do they Okay. And that's also on a concrete each have their own separate stalls? A. Q. No, they're in one area. And are they chained? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 243 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. At night, yes. How about during the day? During the day they are loose in the yard. I think we may have talked about some of these before, right? A. Q. Yes. Are Gunther's parents -- is Gunther's mother at the CEC? A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Yes. Who is his mother? Mawa. But Gunther is not kept with Mawa? No. And is PT's mother at the CEC? Yes. Who is his mother? Joskey. And they are not kept together? Nope. And Rudy's mother there? Yes. Who is Rudy's mother? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 244 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. Sally. And they are not kept together, either? Nope. And Asha's mother is? Alana. Is Asha's mother at the CEC? Yes, Alana. And they are not kept together, either? Nope. And Angelica's mother is who? Yes, Icky. And they are not kept together, either? No. How many elephants at the CEC have tested positive for TB? A. Q. A. Q. A. Q. A. Five. Which ones? Smokey, Ozzie, Mala. Three? Vance and Shirley. Shirley has tested positive for TB? Uh-huh. How many is that? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 245 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. months. Q. When did she test positive for TB? Sometime in the last four or five months, six Is she the most recently -- is she the elephant that's most recently tested positive for TB? A. Q. A. Q. A. Q. A. Q. A. Q. TB? A. Q. Shirley? A. you. Q. Have you ever had any discussions with anyone I am not a medical doctor. I couldn't tell Yes. She is not weaned. Yes. Has Mable been tested for TB? No. Why not? She is a wild little thing with her mother. Who is may Mable's mother? Shirley. She is with Shirley right now? Uh-huh. Even though Shirley has tested positive for Is there a risk that Mable will get TB from Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 246 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 about that? A. Q. A. Q. A. Yes. Who have you had discussions with? Dr. Schmitt. What were the discussions? We can't treat Shirley because of the drugs So Mable is at a interacting in the milk with Mable. critical age for herpes, so. Q. You are totally losing me. I'm sorry. Can you explain that? A. The drugs will come out through the milk and There is more risk in that possibly hurt the calf. than there is of her picking up TB. Q. A. Q. A. Q. This is what Dr. Schmitt told you? Yes. When did you have this conversation with him? Sometime in the last few months. So does that mean Shirley is not being treated for the TB? A. Q. She is not being treated at this time. And how old is Mable? She was born in April of 06; is that correct? Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 271 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. And is that something that's written down somewhere -- the procedure that's used during the birthing process? A. yes. Q. Have you ever seen any written procedure for You know, I don't know. It probably is now, the birthing process. A. by heart. Q. But you may have seen some written I am not sure if I have. I certainly know it procedures. A. Q. I may have. I may have, but I am not sure. Now, at some point a baby is separated from its mother; is that correct? A. Q. A. Q. Yes. When is it decided what that point is? It depends on the mother and the calf. What is the purpose of separating the baby from the mother? A. So you can manage it. The mothers get pretty They start tired of them when they hit about two. kicking them around. The aunties in particular start Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 273 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 daylights out of these calves when they hit about two years of age. Q. If they are males, sooner. So you say that's part of the reason for the separation process is to protect calves from the other elephants? A. That. And it is time for the calves to start becoming elephants. Q. A. Q. What does that mean? Well, they end up being trained. So part of the reason you separate the babies from the mother is so that you can start training them? A. Right. Some you can train with the mothers; some you can't. Q. Now, when they are separated from the mothers by you, are you involved in that process? A. Q. A. Q. Yes. Are you always involved in that process? Yes. And when they are separated from the mothers, are they still nursing at that point? A. Q. Yes. And at what age are they typically separated Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 274 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 from the mothers? A. Q. Around two. Because before you were suggesting that And so I am having a baby nurse is good for the baby. questioning why you would want to separate a baby who is still nursing from its mother? A. They will nurse till they are eight feet tall They will get on their if their mother will let them. knees and they will lay down under them and nurse. Q. A. And would they be too old, then, to train? It wouldn't be a very healthy situation for man or beast having something that size around hands off. It all depends on the elephants and the calf. Q. But, I mean, is part of the reason that you take them away at the age you take them away from their mother because they are more easily trained at that age? A. Q. Yes. Can you describe the process that's used to separate the babies from the mothers? A. Q. It depends on the mother and the baby. Is there a normal process that you typically Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 275 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 use? A. I've changed the process time and time again since I have been there. Q. Okay. When is the last time that you did the separation process? A. Q. A. Q. A. Q. Six months ago. And who was the baby? Arie and Irvin. You did them at the same time? Yes. And Arie's mother is Mala. And Irvin's mother is Alana, correct? A. Q. Correct. And how did you separate Arie from Mala and Irvin from Alana? A. Q. A. Q. A. Q. A. We just grabbed them and tied them up. You grabbed the babies and tied them up? Yes. Tied them up where? Each in a separate paddock inside the barn. By themselves? Yes. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 276 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Q. A. Q. A. Q. A. Q. A. Q. A. Q. legs? A. Q. barn? A. Q. A. Q. A. And how long were they tied up for? For approximately 10 days. And were there chains used as well? At first there were only ropes and bands. I'm sorry? Ropes and cotton bands. Where were the ropes? On their legs. The rope on all four legs? The first night, four legs. I am sorry? The first night, four legs. And then after the first night, how many Two. And why did you have to tie them up in the Because they are wild. What does that mean? They can hurt themselves. Would they want to get back to the mother? They run around. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 277 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. A. Would they want to get back to their mother? Well, the one's mother was right next to it. And he didn't have to go very far. Q. A. Q. barn? A. Q. A. Q. A. Q. Uh-huh. But he was tied up? Right. For 10 days? Right. And how did Alana react to her brand new baby Whose mother was right next to it? Irvin's. Irvin's mother was right next to him in the being tied up for two 10 days right next to her? A. Q. A. Q. A. Q. at all? A. Stress and anxiety are strange words. How Not bad. Not bad at all? No. Not distressed in the least? It is the fourth time she went through it. She exhibited no signs of distress or anxiety Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 278 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 about a little excitement, something that would be normal. This isn't really a horrible situation like you are making it out to be. Q. A. No, I am just asking? The next day she is out in the field with the other elephant without any thoughts about it. Q. And when you say she was right next to him, was there a barrier between the two of them? A. Q. A. Q. Yes. What kind of barrier? Pipe. And what about Arie? Same situation. Was Mala also-A. Q. A. Q. Mala was on the other side of Alana. And where was Arie? On the other side of Irvin. And were Irvin and Arie tied up in separate stalls from each other? A. Q. A. Q. Right, right. And they were both tied up for 10 days? Right. And what was being done about feeding them Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 279 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 during that time period? A. Q. A. Q. A. What do you mean? What were they being fed? The same thing they always were fed. Which is what? They start eating solid food in about 10 So by the time this happens, they days-- these guys. have been eating solid food for almost two years. Q. milk? A. Q. A. elephants. Q. And then after the 10 days, what happened to They are no longer getting any milk. You don't pump the mother for milk? No. It would be extremely difficult with Okay. But they are no longer getting any Arie and Irvin? A. Irvin is turned completely loose and Arie was on one chain. Q. A. And how long was Arie on one chain? Probably four months, except when I was working here -- working with her and turning her loose, walking her around. But now, just for the record, she Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 280 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 is completely loose. Q. A. Q. A. Q. She was on one chain for four months? Uh-huh. And which leg was chained? Alternate legs. You mean you would take the one chain and switch it to various legs? A. Q. like that? A. Q. Except when she was loose with me. How how many hours was she loose with you Right, to the front legs. And was she chained all day and all night during the day during this four months? A. Q. A. Q. Probably about 40 minutes a day. Okay. Right. And was Irvin chained at all during the So other than that, she was chained? separation process? A. Q. involved? A. Once in a while I would put a chain on him. He was tied up for about 10 days. Just ropes, though, or were there chains Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 281 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 But basically just ropes. Q. But I am specifically asking about Irvin. Did he have a chain on him? A. Once in a while. But basically we just had ropes on him. Q. Okay. Sometimes you used a chain, but other times it was just the ropes? A. Q. Right, affixed to a band. And now are Arie and Irvin, do they spend any time at all with their mothers? A. Q. No. And when you said you have used different ways of separate babies from their mothers over time, how does the way you used it the last few times you did it differ from ways you have used it in previous years? A. Sometime we would move them to the other end It depends on the cow and of the barn; sometimes not. the calf. Q. A. Q. A. They dictate most of that. But were ropes used? Yes. Always with the separation process? Sometimes. Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43 Gary Jacobson CONFIDENTIAL October 24, 2007 Washington, DC Page 314 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. And where are the elephants kept during Winter Quarters? A. Q. A. Q. A. Q. A. Q. A. In the portable building. And are they on chains? Some of the time. How much of the time are they on chains? Probably about 12 hours a day there. And are they on chains during the night? Yes. They are only tied at night. Excuse me? They are only tied at night. During the day they are loose. Q. In the portable building, they are all loose together in the portable building? A. It is at a large fairgrounds, and they have portable yards. Q. A. along. Q. A. Q. Are they in separate stalls -- the elephants? They are in groups according to how they get They are in the hot wire yards, on dirt. And are they outside during the night? No, they are inside during the night. And what does the inside quarters look like Alderson Court Reporting 1-800-FOR-DEPO 3a478211-0d15-4a87-b265-3f3a418f2a43