In The Matter Of: Griggs v. Chisenhail and Griggs Chisenhali, Mr. William Pat May 24, 2016 Pace Reporting Service, Inc. PO Box 252 Cary, NC 27512 919-859-0000 Original File Chisenhall 5-24-2016.prn 2?1 .. -: Hi. .7 1" -..- 5 ti.? :13 if}; m. EEK. Griggs v. Chisenhali and Griggs Chisenhall, Mr. William Pat May 24, 2016 STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF BARNETT 15 CVS 779 DOLLIE GRIGGS, as Administrator of the I A Estate of CHRISTIAN I I Plaintiff, VS. I I A A WILLIAM PAT CHISENHALL and KATIE GRIGGS, I A Defendants. In Lillington, N.C. May 24 2016 Reported by: Dana C. Dopko Stipulations Page 3 said case at which said deposition might be used, except that an objection as to the form of a question must be made at the time such question is asked, or objection is waived as to the form of the question. (5) That the witness waives the right to read and sign the deposition prior to filing. That the sealed original transcript of this deposition shall be mailed first?class postage or hand- delivered to the party taking the deposition for preservation and delivery to the Court, if and when necessary. (T) That the witness was identified by government? issued photo ID. *Is THE VIDEOGRAPHER: On record at ten-ohv seven A.M. Today's date is May 24th, 2016. This is a videotape deposition of William Pat Chisenhall taken by the plaintiff in the matter of Dollie Griggs, as Administrator of the Estate of Christian Griggs, Plaintiff, versus William Pat Chisenhall and Katie Griggs, Defendants in the General Court of Justice, Superior Court Division, Barnett Stipulations Page 2 I A I It is hereby stipulated and agreed between the parties to this action, through their respective counsel of record: That the videotaped deposition of WILLIAM PAT CHISENHALL may be taken on May 24, 2016, beginning at 10:07 A.M. in the BARNETT COUNTY COURTHOUSE, located at 301 W. Cornelius Harnett Boulevard, Conference Room 2007, Lillington, North Carolina, before Dana C. Dopko, a Notary Public. That the deposition shall be taken and used as permitted by the applicable North Carolina Rules of Civil Procedure. That any objections of any party hereto as to notice of the taking of said deposition or as to the time or place thereof, or as to the competency of the person before whom the same shall be taken, are deemed to have been met. (4) Objections to questions and motions to strike answers need not be made during the taking of this deposition, but may be made for the first time during the progress of the trial of this case, or at any pretrial hearing held before any judge of competent jurisdiction for the purpose of ruling thereon, or at any other hearing of Stipulations Page 4 County, North Carolina, Case No. 15 CVS 779. Would counsel now please introduce themselves? MR. JESSUP: Robbie Jessup of Howard, stallings for the Plaintiff Estate. MR. LEVIN: Robert Levin for the defendant, Mr. Chisenhall. MR4 JOHNSON: Lee Johnson for the defendant, Katie Griggs. THE VIDEOGRAPHER: And would the court reporter please swear in the witness? whereupon, WILLIAM PAT CHISENHALL, having been first duly sworn, was examined and testified as follows: Pace Reporting Service, Inc. (1) Pages 2 - 4 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 5 Mr. Chisenhall Direct Page 7 1 DIRECT EXAMINATION BY MR. JESSUP: 1 and came back, and?-and--after being married, and 2 Good morning, Mr. Chisenhall. My name is Robbie 2 felt a call t0??to go into the ministry at that 3 Iessup, sir. I?m an attorney representing the 3 point and accepted the call. And went to seminary 4 Estate of Christian Griggs, one of the attorneys 4 and began pastoring a church on a part-time basis, 5 representing the Estate. 5 and then started a church. So between the two 6 Today, sir, it's just a chance for us to 6 churches, I've been pastoring for thirty years. 7 get your side of the story and try to understand 7 So you were about twenty when you went into 8 what happened on October 12th of 2013. To start 8 ministry? 9 with, sir, I'd like to get to know you a little 9 A No. I was twenty-nine. So I'm ?fty-nine now. 10 bit. 10 Did you do anything?did you work in another type 11 I do want to say one thing before we get 11 of job before you Went into ministry? 12 going. This is not an endurance contest today. So 12 A Various jobs. 13 if at any point, sir, you?d like a break, you need 13 What kind ofthings did you do? 14 to take a moment out in the hall, feel free. Just 14 A TV repairman for the most of that time. My wife 15 tell me and?53nd I'm happy to take a break and let 15 and I owned a cleaning business. We cleaned houses 16 you step out. 16 and offices and churches. But that?s the-the most 17 A Thank you. 17 of it. 18 Sir, to start with, could you spell your full name, 18 When you say your wife, you're referring to Lydia? 19 state and spell your full name for the court 19 A Lydia. Correct. 20 reporter?s record? 20 You've been married to her about your whole life, 21 A William Pat Chisenhall. W-I-L-L-I-A-M P-A-T 21 Sir? 22 S-E-N-H-A-L-L. 22 A Yes. Married at eighteen. And this will be, I 23 And Mr. Chisenhall, what is your date of birth, 23 think, forty?one years. 24 sir? 24 Do you have two or three children together? Mr. Chlsenhall Direct Page 6 Mr. Chisenhall Direct Page 8 1 A 4?11?57. 1 A Two children, a son and a daughter. 2 Thank you, sir. And are you from this area? 2 And you referred to two churches. Did you?~have 3 A Yes. 3 you started two churches in your life? 4 Okay. Where are you fromolder established church that I 5 A Angier. 5 went to as a part?time ?ll-in type basis. And I 6 Okay. Grew up there? 6 stayed there two--1 think two years. And then I?ve 7 A Uh?huh (yes). Yes, sir. 7 been at??then I started the second church, and 8 Okay. I understand the-?the land you live on been a we?ve been there twenty-eight years. 9 in your family for a while? 9 And is that The Abundant Life?? I 10 A Several generations. Yes. 10 A Worship Center. 11 Okay. What did your parents do? 11 --Worship Center? 12 A My mother was a schoolteacher assistant. My father 12 A That's correct. 13 worked for a building supply company. 13 You have a large ?ock there, Pastor? 14 Understood. And I understand you're a reverend, 14 A About one hundred. 15 sir? 15 And that?s located in Angier? 16 A Yes. 16 A Between Angier and Coats. 1? Should I address you as "Reverend" todayany medication today, Pastor, that would 18 should I address you? 18 affect your ability to understand my questions 19 A Pat's ?ne. 19 and?-and do a deposition? 20 Okay. Pat, can you tell me a little bit about how 20 A No. 21 you became a reverend? 21 And don't be offended. I ask this of everybody. 22 A Well, I was saved when I was a young child and was 22 But have you ever been charged with or convicted of 23 very active in ministry as a child. And drifted 23 a crime? 24 away from the Lord for a while in my teenage years, 24 A NO. ta- Pace Reporting Service, Inc. (2) Pages 5 8 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhafl Direct Page 9 Mr. Chisenhali Direct Page 11 1 Do you have any medical diagnosis as of today, sir, 1 A After graduation. She was expecting during the 2 that would affect your ability to testify here 2 graduation. 3 today? 3 At that time did Christian or Katie have plans for 4 A I'm in care being treated for 4 college or anything after high school? 5 posttraumatic stress disorder. 5 A Yes. He--he had plans for-?to go to college. And 6 Do you currently have a diagnosis of 6 then he??then he decided to go into the Army. And - 7 amnesia? Have you heard that term before? 7 Katie was just going to be a--look after the baby 8 A I've not heard that term. 8 and work. 9 And l--l didn't see that term, but I just wanted 9 What was the reason for the change in those plans? 10 to--to ask. 10 A I don't know. I don't remember why he opted to go 11 To start with, could you tell me a little 11 with the Army. 12 bit about how you came to know Mr. Christian Griggs 12 How ion did Christian live in your house with you, 13 and??and sort of the start of your relationship 13 sir? 14 with him, sir? 14 A He lived with us??he lived with us twice. Once 15 A He just asked my daughter out for a date and came 15 before the baby was born for a little while, stayed 16 to our house to pick her up. And we met him, and 16 there. And then he lived with us several months, I 17 he seemed very pleasant and mannerable and--and we 17 would guess three or four months, possibly longer, 18 liked him. They seemed to like each other, and 18 after the baby was born. 19 they just began dating. That's how we met him. 19 Was that before joining the Army, did he live? 20 When did they start dating? 20 A Uh-huh (yes). 21 A I'm terrible with dates. But I would?J think it 21 ??for several months? 22 was 2006, maybe ?07. 22 A Yes. While he was waiting to?-to go into basic 23 Would that have been your daughter's junior year of 23 training. 24 high school or sophomore year, do you know? 24 What were things like during that time when Mr. Chisenhall Direct Page 10 Mr. Chisenhall Direct Page 12 1 A I think junior. 1 Christian was living with you? 2 And in terms of them-the start of their 2 A Things were happy then. Things were good. I don't 3 relationship in high school, was that--was that 3 remember any problems really. 4 happy? 4 Were you close with Christian, sir? 5 A Yeah. Their early days were happy, yes. 5 A Yes, I think so. I think we bonded. We were 6 Were there ever any incidents of verbal abuse or-? 6 close. 7 or physical abuse or anything like that when they 7 Did you marry Christian and Katie? 8 were in high school? 8 A Yes. I performed the ceremony. 9 A No. Not that I know of. 9 Were you supportive of their marriage? Did you 10 Tell me about the circumstances that led to 10 encourage their marriage? 11 Christian and Katie becoming married. 11 A Yes. I felt it was the best thing under the 12 A She became pregnant with the child. And they did 12 circumstances of having a baby together and wanting 13 not marry until after the baby was born. But he 13 to be together. I supported the marriage and the 14 came and lived with us after the baby was born. 14 wedding. 15 Stayed in??he stayed in his room, and they stayed 15 Tell me about your relationship with Christian's 16 in their room. And??and then when the?~I don't 16 parents during that time period. 17 know how old the baby was when they got married, 17 A There was none. 1 had never met them. They didn't 18 but it was?~she was very small. 18 come to the wedding. They didn't come to the birth 19 Roughly what period of time would that have been 19 of the baby. I had never met them. 20 in, sir? 20 Did you understand they weren't supportive of the 21 A Roughly 2008, I suppose. Again, I'm terrible with 21 marriage? 22 dates. 22 A Yes. 23 Did they get married after they graduated high 23 Do you know why that was? 24 school or before they graduated high school? 24 A don't know. Pace Reporting Service, Inc. (3) Pages 9 12 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 13 Mr. Chisenhall Direct Page 15 1 Tell me about what things were like after Christian 1 And I ask because 1??l didn't see a police report 2 going in the military. 2 from that incident. 3 A At first they seemed to be pretty good. They moved 3 Do you recall, was it Angier PD or was it 4 away to-?he went to basic training in Georgia, and 4 Harnett County Sheriff?s Of?ce that reSponded? 5 Katie got an apartment down there. And they-?they 5 A Hamett County Sheriffs Department. They--they 6 lived in an apartment. And we would visit on 6 may not have at that point. They??they talked to 7 occasion. And it seemed to be pretty good, happy 7 him and talked to him, and he agreed to leave. 8 times. 8 What was the argument about? 9 I understand you baptized Christian? 9 A 1 don't remember. 10 A That's correct. He was deployed to Iraq, I think 10 Did he become physically-?did he?-did he physically 11 it was, and got saved while over there. He told 11 strike you at that time? 12 me. He wrote me. 12 A No. 13 And upon returning, wanted to be baptized 13 Did he physically strike Katie at that time? 14 and wanted me to baptize him. So??we have a 14 A No. 15 swimming pool at our house, so we baptized him, 15 Were Christian and Katie together at that time? 16 among others, at??at our pool. 16 A I don't think so. I think they were separated. 17 Do you recall when that was, sir? 17 Any other events that you witnessed that you would 18 A It was several weeks before the incident. 1 don't 18 characterize Christian being verbally abusive 1 9 remember exactly how long before. Several weeks. 19 towards you? 20 The incident October 12 of 2013? 20 A I don't?J don't think so. Not--not really 21 A Correct. 21 verbally abusive. 22 Was Christian going to your church? 22 Prior to October 12, 2013, had Christian ever been 23 A Some. Not regularly, but he did attend on 23 physically abusive towards you? 24 occasion. 24 A No. Not-?not prior to that. Mr. Chisenhall Direct Page 14 Mr. Chisenhall Direct Page 15 1 Were you Christian's spiritual advisor? 1 Prior to October 12, 2013, had you ever witnessed 2 A 1 would say so. I think that would probably aptly 2 Christian be physically abusive towards anyone? 3 describe it. I tried to be. 3 A Not witnessed, no. 4 Prior to October 12 of2013, was Christian ever 4 Prior to October 12, 2013, you told me about one 5 verbally abusive towards you? 5 incident, had you ever heard Christian be verbally 6 A Not?-not-?well, yes. There was one or two 6 abusive towards anyone? 7 incidences where he was when he was in a heated 7 A Not that I heard, no. 8 argument with--with Katie and-~50 I think there was 8 Did you ever see any bruises or marks on Katie or 9 a couple of incidences where he was verbally 9 anyone that anyone had told you Christian had 10 abusive. 10 in?icted at any point prior to October 12, 2013? 11 To you? 11 A No. 1 never saw any. 12 A To you??to me, yeah. 12 And the month leading into the October 12, 2013, 13 Tell me about those incidents and what he said. 13 incident, was that the same month where you 14 A Well, one-?one was when the police was called. 14 baptized Christian? 15 This was when Katie-they had separated, and Katie 15 A Probably within the same--it could have?-it was?- 16 was living in our house. And he had come, and was 16 no, it was probably September. He was probably 17 irate, was angry. And he was refusing to leave, 17 baptized in September. 18 and the police were called. And I arrived after 18 Okay. Did you have a good relationship with 19 the police arrived. And he just was angry towards 19 Christian during that September, September of 2013? 20 me, you know, didn't want me to, you know, 20 A Well, it was strained a bit because their-~their 21 interject anything or have anything to say. 21 relationship was strained. And I was trying to 22 When was that? 22 help him. So I wouldn't say it was a good 23 A That was a year or more prior to the--to the 23 relationship at that point. 24 shooting. 24 When you say the relationship was strained, Katie "i I :51 Pace Reporting Service, Inc. (4) Pages 13 16 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page Mr. Chisenhall Direct Page 19 1 yesterday talked a little bit about in?delity. 1 there??he was still living there when he was 2 Could you tell me more about how their 2 baptized. So that was early--late September. 3 relationship was strained? 3 Amber and Russ Kozik, I understand they live across 4 A Well, they were just separated, and then they would 4 the street. 5 get back together, and separate. And he was coming 5 Will you??can you tell me a little bit 6 back and then leaving. And he??seemed to be a 6 about how you know them and your relationship with 7 constant turmoil of separating and coming back 7 them? 8 together and-- A Church. She grew up in our church. And we just 9 What was going on with Jaden during that time 9 become close friends and family together. And they 10 period? 10 live on the other side of me. Not across the 11 A She was remarkably shielded from all of the??the 11 street, but on the other side. And I've known them 12 hostility and the upheaval. So she was remarkably 12 since she was a small child. And haven?t known 13 shielded from it and seemed unaffected at that 13 Russ as long, but have gotten to be close with him, 14 point by it. 14 as well, through the church basically, and being 15 Were they sharing custody of Jaden at that time? 15 neighbors. 16 A i I don?t know. I don't know much about that. 16 So if I understand, I was incorrect, they live 17 Do you understand the visitation arrangements that 17 immediately next door to you, not across the street 18 were in place? 18 from you? 19 A No. I didn?t?-I didn't have any information on 19 A That's right. My house is in the middle. My 20 that. 20 mother?s house is on one side. They live on the 21 Do you know whether on October 12, 2013, Christian 21 other side. 22 was scheduled to have aden? 22 And did Amber grow up next door or did she grow up 23 A I don't know. I didn?t know anything about it. I 23 near your home, or?- know he got her and brought her back. 24 A No. She moved there when they got married. So I'm Mr. Chisenhall Direct Page 18 Mr. Chisenhall Direct Page 20 1 When did he get her and bring her back? 1 not sure how long they had lived there at that 2 A That Friday afternoon. He picked her up. And my 2 point. A couple years probably. 3 understanding is that she had been to the zoo with 3 Do you own the house they 1ive??live in--or they 4 a couple of Katie's friends. And she told him she 4 lived in? 5 had been to the zoo, and he asked, "With who?" And 5 A I did. We sold it to them. 6 she told him, and he got mad and brought her back 6 I understood from some notes that I had seen that 7 and left her. 7 you had--you had actually married Amber and Russ, 8 And all I know. I is tha 9 wasn?t aware of any visitation 9 A That's correct. 10 arrangements or--they were living in my mother's 10 Tell me about what you know about Katie's 11 house at that time, Katie was. We lived next door 11 relationship with Amber and Russ. 12 to each other. 12 A Katie and Amber are very close, childhood friends, 13 Had Christian been living in your mother's house 13 almost like sisters. Very close. 14 with Katie? 14 When did Russ come into the picture? 15 A Yes. 15 A Maybe five years ago perhaps, ?ve or six. 16 When did Christian move out of your mothers house 16 Would you say that Amber is Katie's best friend? with Katie? Would that have been sometime in 17 A Yes. 18 September? 18 Is your wife also a pastor? 19 A I would say so. I'm not sure, but I would?-I would 19 A No. 20 guess, yes, moved out in September. I think?- 20 Does she work at the church? 21 IVIR. LEVIN: Don't--don't guess. Either 21 A Yes, quite a bit. 22 you know or you don't know. 22 What does your wife do for a living, sir? Mainly 23 THE WITNESS: Okay. 23 work at the church? 24 A Well, it could have been??he was still living 24 A Yes. Mainly works at the church. Er mat?- Pace Reporting Service, Inc. (5) Pages 17 20 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 21 Mr. Chisenhall Direct Page 23 1 And what is your son's name, sir? 1 was?-was irate and had broken into the house, 2 A Patrick. 2 pulled the air conditioning unit out of the window 3 He's a Junior? 3 and broke into the house and came in through the 4 A No. Just Patrick. Jason Patrick Chisenhall. 4 window. And I don?t know what all-?there was 5 And does he work around the church, as well? 5 yelling and hostility. And I don't know about 6 A No. He doesn?t attend our church. 6 threats and those type things, but it was extremely 7 What does he do for a living, sir? 7 upsetting to her. 8 A He's a correctional officer at the Hamett County 8 She called the??and I think Russ and 9 Prison here in Lillington. 9 Amber came and witnessed this. And they called the 10 Do you mean to say jail? Is there a prison here? 10 9?1?1. And he left. And when we got home, they?- 11 A There's a prison here. 11 Katie and Russ had come to the magistrate, I guess, 12 Okay. And back in October of 2013, do you know 12 or the Sheriffs Departmentwhat your son was doing for a living at that point? 13 restraining order. And--and Amber was keeping-and 14 A I believe he was??that's??he was the same thing, 14 Lydia had laden. And so I came on down myself to 15 correctional officer. 15 the Sheriffs Department or the magistrate's of?ce 16 Did he ever work with Angier Fire Rescue? 16 to see if I needed to get a restraining order since 17 A Yes, volunteer. 17 at that time I owned the house and not knowing if 18 But his primary job was as a corrections of?cer? 18 he would come back to my house. And so that's kind 19 A Right. 19 of what happened on the Friday night. 20 Sir, I want to talk a little bit now about the week 20 My understanding was that a restraining 21 leading up to October 12, 2013. 21 order was taken out, but he also told us we needed 22 I understand from talking to Katie 22 to go to Raleigh the next morning and do the same 23 yesterday that laden had been sick earlier that 23 thing there, Don't know why. But Katie and laden 24 week? 24 spent the night with us. It was a restless night, Mr. Chisenhall Direct Page 22 Mr. Chisenhall Direct Page 24 1 A I believe so, yes. 1 not knowing if he would come back or not. 2 Do you recall what was wrong with her or what 2 When was the ?rst time you were told Jaden was 3 happened? 3 taken to the zoo on October 1 1thmight have been that Friday night. I'm not 5 Did you help take care of her while she was sick 5 sure. 6 that week? 6 Do you know as fact laden was taken to the zoo that 7 A No. 7 day? Do you recall Christian helping take care of her 8 A Yes. She was taken to the zoo. 9 earlier that week, on that Monday? 9 Based only on what peOple have told you? 10 A No. Don't recall. 10 A Right. Correct. 11 Okay. Tell me what you remember about that week, 11 And you didn?t see what happened with?-when--when 12 the week leading up to October 1 and October 12 Christian came over to pick up Jaden that Friday 13 12th? 13 night? You weren?t present? 14 A They were estranged again, and he had moved out. 14 A No. 15 And like I say, that?-I think it was that Friday 15 And you went to the Sheriffs Department that 16 laden was taken to the zoo with two of Katie's 16 evening? 1? friends, Amber being one of them. And he came to 17 A Yes. 18 pick her up, and again was upset that she had been 18 Did you see Katie and Russ at the Sheriff?s 19 taken to the zoo with these two friends, and came-? 19 Department? 20 brought her back and left her and was pretty 20 A Yes. 21 agitated and-and irate. 21 How long were you guys there together? 22 And we had gone out for supper in Cary, 22 A Oh, ?fteen minutes or so. We were told Katie 23 and Katie texted or called my wife and said that 23 would need to do it since she was the one?-you 24 there was trouble at the house, and that Christian 24 know, broke into her house. And so they didn't - . .- Pace Reporting Service, Inc. (6) Pages 21 - 24 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 25 Mr. Chisenhall Direct Page 27 1 really have??not even really say anything other 1 restraining order in place? 2 than ask did Ineed to get a restraining order. 2 A Well, I thought there was with Lillington, 'cause I 3 And he said no, what Katie's doing should be 3 told Christian that??that we had a restraining 4 suf?cient. 4 order against him, that he needed to leave, 5 And Katie communicated to you that Christian 5 thinking that there was. 6 actually came into the house? 6 Did you go into the Wake County Magistrate's office 7 A Uh?huh (yes). Came in through the window. 7 with Katie? 8 Did she tell you what Christian did in the house? 8 A No. 9 A Just ranting and raving and screaming and yelling. 9 You never saw Christian at any point on October 10 That?s all I know. 10 1 1th, correct? 11 Did she tell you how she got him out of the house? 11 A That's correct. 12 A No. I don't remember that. 12 Does Katie regularly drink with Amber and Russ? 13 And I ask you this because there were some text 13 A Not to my knowledge. That-?that was news to me. 14 messages between Russ and Katie about getting 14 Not to my knowledge. 15 together to drink on October I 1th. 15 Did Lydia go with you to the Sheriff?s Department? 16 Did you notice the smell of alcohol on 16 A No. She stayed at home. 17 either of them? 17 Were you aware of any in?delity between Christian 18 A No. 18 and Katie? 19 Did you see Amber at any point that evening? 19 A I had heard that both--there was in?delities with 20 A Uh-huh (yes). She was at my house with the baby. 20 both of them. 21 Did you smell alcohol on her? 21 Can you tell me more about that, sir?? 22 A No. 22 A Don't know-? 23 Did you notice red faces, slurred speech, any??or 23 --what you had heard? 24 bloodshot eyes, any signs of intoxication in Amber, 24 A Just that she had done the same thing he had done. Mr. Chisenhall Direct Page 26 Mr. Chisenhall Direct Page 28 1 Russ or Katie? 1 Do you know who she had done it withidea. 3 And to be clear, there was no restraining order 3 Had Katie ever been in any kind of trouble to your 4 issued on October 11th? 4 knowledge? 5 A That's correct. We thought there was, but all this 5 A No. Never. 6 was new to us, you know. I didn?t--I had never 6 Had you ever seen Katie be verbally abusive towards 7 done this before. We thought there was, but 7 anyone? 8 apparently there was not. 8 A No. 9 And you learned that the next morning when you went 9 Physically abusive? 10 to the Wake County Magistratebelieve so. I can't remember when I learned it, 11 Did she ever get in trouble in high school for 12 that that was not the case. But I was under the 12 anything? 13 understanding that that was the case. No, I don?t 13 A No. 14 think it was the Wake County Magistrate. 14 Had you ever seen Christian or Katie do drugs? 15 don't remember when I learned that we didn't 15 A No. 16 actually have one. 16 Have you ever seen Christian or Katie on drugs to 17 What did the Wake County Magistrate tell you the 17 your knowledge? 18 next morning? 18 A Not to my knowledge, no. 19 A To come back Monday. 19 Did you ever see any evidence of drug use in the 20 Did she tell you they couldn't do restraining 20 house Christian and Katie were living in or smell 21 orders on Saturdays? 21 marijuana smoke coming from the house? 22 A Uh-huh (yes). I think so. Katie talked to themthink that's what they told her. 23 Did you ever see any evidence of drug use while 24 And at that point you realized there wasn't a 24 Christian was living with you? .. ?5 i . . 5.31 1. ?int: 'i'l Pace Reporting Service, Inc. (7) Pages 25 - 28 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 29 Mr. Chisenhall Direct Page 31 1 A Living with me? No. 1 with her phone? 2 On October 12, 2013, were you prescribed any kinds 2 A I don't remember. 3 of medication? 3 Did you move the air condition unit from the front 4 A No. 4 steps? 5 To your knowledge was your wife prescribed any 5 Yeah. I moved it around to the garage, to the 6 kinds of medication? 6 carport. 7 MR. LEVIN: Objection. You can answer. 7 And you say you thought maybe Russ had moved it. 8 You can answer. 8 Why-~why did you think Russ had maybe 9 A Well, just Crestor and blood pressure medicine. 9 moved it? 10 I'm sorry. I did?-I didn?t?? 10 A Well, I was hoping he had moved it, just to try to 11 And what is Crestor? 11 help us out. But he didn't. 12 A Cholesterol. 12 How do you know he didn't? 13 Cholesterol. To your knowledge on October 12, 13 A He told me. - 14 2013, were there any kinds of emergency medications 14 You said the cord was wrapped around it? Did it 15 within your home? I 15 look like somebody was trying to do a favor sitting the air condition unit on the front porch? 17 To your knowledge on October 12, 2013, were there 17 A That?s what I kind of thought. It was just sitting 18 any kinds of medications within your home that 18 there on the front steps. 19 people took on a regular basis other than the 19 Where was it before? 20 Crestor and the blood pressure medicine? 20 A Laying in the yard outside the window, the bedroom 21 A No. 21 window. 22 Did you ever have any discussions with Katie about 22 011 the Side Opposite from your house? 23 whether or not it was Christian?s weekend to have 23 A Opposite, yes. 24 laden prior to the incident itself? 24 Had you ever seen it laying there on the ground Mr. Chisenhal! Direct Page 30 Mr. Chisenhall Direct Page 32 1 A No discussion at all. I was not involved in that 1 outside the bedroom?? 2 at all. 2 A No. 3 So tell me what you remember about the morning, 3 ??window? 4 not??not the incident yet, but the events leading 4 A Uh-uh 5 up to the incident on October 12, 2013. 5 So you're just supposing that's where it wasearly. And Katie and I left as early as 6 don?t know that; you're just supposing? 7 we could for Raleigh to the magistrate's of?seeking a restraining order. Couldn't get it. Was 8 When did you see it? 9 told to come back Monday. Came back home. She was 9 A Friday night, and again early Saturday morning. 10 having some problems with her phone, so we stopped 10 Yeah--I'm sorry. Yeah. I saw it Friday 11 at a cell phone place. 11 night and Saturday morning. 12 We came home early morning still, I would 12 Was there any broken glass around the window? 13 say ten o'clock, ten-thirty, maybe eleven. And 1 13 A Don't think so. I think he just pulled it out and 14 noticed as we drove by her house that the air 14 lifted it up, and?? 15 conditioner, which had been laying in the yard, was 15 Any damaged boards or any other damage to the 16 now sitting on the front steps with the cord wound 16 window? 17 around it. And I thought, well, maybe Russ did it. 17 A Don't believe so. 18 But I had a bad feeling that Christian had been 18 And Katie told us yesterday that that unit would 19 back. 19 have to be removed to be able to pull the window 20 And so we came on in the house. Well, I 20 down and lock it, is that correct? 21 told Katie to go on into?-to my house, and 1 would 21 A Probably, yeah. That's true. 22 go take a look around and see what was going on 22 Do you know if anyone ever actually saw Christian 23 down there, if anything. 23 remove that window unit? 24 A I'm assuming Katie did, but I don?t??you know?- 24 Okay. What--what kind of problems was Katie having -.-: 'n ..: ?1 l? ?3 ri Pace Reporting Service, Inc. (8) Pages 29 32 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 33 Mr. Chisenhall Direct Page 35 1 Okay. What happened when Christian arrived? 1 And you said he was also rummaging through the car? 2 A Okay. Ihad just gottennhadn?t been down there 2 A Katie's car, yeah. 3 long at all, was looking around. And he pulled up 3 How long was he rummaging through the car? 4 and demanded?-he was still in the car, agitated, 4 A Not long. Just seconds. 5 angry, said??demanding to see Katie. 5 Do you know what he was looking for? 6 And I told him going to have 6 A No. 7 to leave. You have to leave. We have a 7 Did he actually open the door to the vehicle? 8 restraining order against you." And as soon as I 8 A Believe so, yes. 9 said that, he just became enraged and jumped out of 9 Did he have a key to the car? 10 the car, and began to curse and threaten me and 10 A I think it was probably unlocked. 11 push me back. He didn't strike me, but he-?he 11 Any supposition as to what he could have been 12 pushed me, my shoulders back, and-?and threatened 12 looking for in the car? 13 me. And I was trying to remain calm. 13 A No idea. 14 And I heard-Katie call my name, and I 14 Okay. Did he knock on the door before or after he 15 turned, and she was standing on the porch of my 15 'rummaged through the car? 16 house with a cell phone. And I said, "Cali 9?1-1. 16 A Yes. He had banged on the door and was yelling 17 Call I didn't realize she had already 17 through the door before going over to the car. 18 called 9~i?l. I'm pretty sure. And when he saw 18 And in the 9-1-1 tape we got from where you were 19 her, he took off running towards herthe yard, he?-his voice was also on that 20 back in the house. And he banged on the door, was 20 tape. 21 to get in the door. 21 Was he standing in close proximity to you 22 So I started calling 9?1-1 on my phone 22 when you called 9-1-1? 23 and had some trouble with the connection. But??so 23 A No. But he was running aroundwas--we were kind of walkinguhe was running 24 least twice and was yelling, "Look at me, look at Mr. Chisenhall Direct Page 34 Mr. Chisenhall Direct Page 36 1 around in the yard, running up on the porch, 1 no.? I don't remember what else he said. 2 banging on the window, banging on the door, yelling 2 But he was standing right close to me 3 for her to come out. And I was on 9?1-1 I guess 3 when I was on?-I?-I stayed on the phone to my to 4 describing the situation. 4 de?ect, and?-and, you know, he was, at that point, 5 He went over to Katie's car and started 5 was close to me. 6 rummaging through her car. And the 9?1-1 operator 6 Did he tell you he was there to pick up Jaden? 7 said, "Do you feel threatened?" And I said, "Yes." 7 A Uh?uh No. 8 And she said, "Can you get to?-get in the house?" 8 Did he say anything about Jaden? 9 And I said, think so.? So at that point I ran 9 A Not that I recall. 10 towards the house. He saw me and ran after me. 10 Did he say anything about something Katie had 11 And I barely got in the door, and he was 11 mailed to him the day before? 12 there pushing on the other side of the door. So 12 A No. 13 Katie came, and Katie and I were pushing on one 13 Are you aware of a separation agreement that Katie 14 side of the door, he was pushing on the other side, 14 had asked him to sign that gave her sole custody 15 and it was a violent struggle of pushing back and 15 over Jaden? 16 forth, trying to get the door shut. 1 6 A I was aware of a separation agreement?nally got it shut and locked. not aware of the speci?cs of it. 18 And that's when the window crashed in seconds later 18 Okay. Did he push you to the ground? 19 to the left of my head. 19 A No. Just pushed me back several steps. 20 I'll stop right there. You said that Christian 20 And you remained out in the yard with him-- 21 was--he--he??he banged on the door and he banged on 21 A Uh-huh (yes). 22 a window. 22 ?-after that? 23 What window did he bang on? 23 A Uh?huh (yes). 24 A Thenthe window he ultimately crashed through. 24 Okay. Pace Reporting Service, Inc. (9) Pages 33 - 36 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 37 Mr. Chisenhall Direct Page 39 1 MR. LEVIN: Is that a yes? 1 have moved out sometime around late September. 2 THE WITNESS: Yes. Sony. 2 Did you ever take a key back from 3 Between the?~your initial discussion with him 3 Christian at any point to that home? 4 outside the vehicle, the knock on the door, the 4 No. 5 rummaging through the car, the 9-1-1 call, how--how 5 Okay. 6 long would you say you were out in the yard with 6 A And he may not have had a key. I'm not--I don't 7 Christian before going inside? 7 know. 8 A Two or three minutes perhaps, a couple of minutes. 8 Did Christian have a key to Katie's vehicle? 9 It's hard to say. 9 A I don't know. 10 Did he do anything to threaten your physical safety 10 Had you ever seen Christian behave this way at any 11 while you were out in the yard? 11 other time? 12 A Yes. He threatened to kick my F-ing ass. 12 A Not to this extent. The other time when the police 13 Anything else? 13 were called, it was pretty bad. But I had never 14 A No. That was it. 14 seen anyone this enraged'before. 15 When did he say that to you when you were out in 15 I'm going to hand you what was marked yesterday as 16 the yard? 16 Exhibit 1. They're some interview notes from when 17 A Soon as he got out of the car. Soon as I said we 17 the police talked to you. That wasn't Exhibit 1, 18 got a restraining order. And he pushed me back, 18 pardon me. 19 and that's when he said that. 19 MR. LEVIN: 10? 20 But you continued to remain out in the yard with 20 MR. JESSUP: 10. 21 him after that? 21 They're some interview notes with you, and I just 22 A Yeah. That's when Katie called and--from the 22 want to ask you about the last paragraph. 23 porch. 23 A It's the last paragraph? 24 Okay. And you told him there was a restraining 24 Yes, sir. I'll give you just a moment to read it. Mr. Chisenhall Direct Page 38 Mr. Chisenhall Direct Page 40 1 order when there was no restraining order? 1 A (Examines paperwritings.) Okay. 2 A Apparently that's the case. Yes. 2 They wrote down that, from an interview with you, 3 Christian a pretty muscular guy? 3 at some point Katie allegedly tried to go inside 4 A Yeah. He was pretty strong. 4 and??and get the gun. 5 Stronger than you and Katie combined? 5 Do you know where that comes from, sir? 6 A Well, it took both of us with a ?erce struggle to 6 A I don't remember if she ever told me that or not. 7 get the door closed. 7 Do you recall Katie going inside at some point and 8 Where was laden at this time? 8 getting the gun, or trying to get the gun, and not 9 A She had gone with her grandmother, Lydia, to the 9 being able to work it? 10 grocery store. 10 A No. No. 11 Had you and Katie talked about any conversation she 11 Where was Katie while all this was going on in the 12 had had with Christian that morning, or any 12 yard? 13 interaction she had had with Christian? 13 A In the house, apparently on 9?-with 9-1-1 most of 14 A No. 14 the time. 15 Did Christian have a key to the house immediately 15 Was there anyone else present at your residence 16 next door to yours? . 16 when this was occurring? 1? A Ithink so, but I'm not, you know, a hundred 17 A No. 18 percent sure. I think he did. 18 Okay. Tell me what happened next. 19 Were you his landlord? I mean, that was-~you owned 19 A Well, we managed to get the door locked. Seconds 20 that proper -- 20 later the window came crashing in to my left of my 21 A Tech-? 21 head. And I don't really remember anything after 22 --next door? 22 that. The incident, the shooting, I don?t remember 23 A Technically, yes. Yeah. 23 any of that. 24 And Katie and Christian??you said Christian would 24 Do you recall doing a reenactment with the Hamett -. . W73: Pace Reporting Service, Inc. (10) Pages 37 - 40 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhali Direct Page 41 Mr. Chisenhall Direct Page 43 1 County Sheriff's Department? 1 calling 9?1-1, but apparently I did. 2 A Yes. All that's hazy and foggy, but I remember 2 But you don't know whether or not what you said in 3 doing a reenactment. 3 those 9?1-1 recordings is true or not? 4 Okay. We--we obtained a video of that reenactment. a A Since I don't remember it, I guess not. 5 I'll show you a picture, what was marked yesterday 5 Had you ever taken Katie hunting before? 6 as Exhibit Nothat reenactment, sir, you stood 7 Has she ever been hunting with Russ? 8 behind that couch and said that you ?red the shots 8 A No. 9 from behind that couch through that window there in 9 Do you know what gun was used to shoot Christian? 10 Exhibit No. 18. 10 A A .22 automatic rifle. 11 Do you recall saying that during the 11 And how do you know that? 12 reenactment? 12 A Because the police told me. 13 A No. . 13 Did the police tell you how they knew? 14 Okay. Once you got in the house, do you remember 14 A It was apparently laying on-?somewhere in the room 15 . going to the bed-room and seeing Katie? 15 there when they came in. And they?-I guess they 16 A No. 16 did tests on it. 17 Do you remember retrieving a gun from the bedroom? 17 Did the police tell you that Christian was coming 18 A No. I remember nothing after the glass crashed in. 18 through a window? 19 What's the next thing you remember after the glass 19 A I don't remember. 20 crashed in? 20 And you said automat--from the weapon I've looked 21 A I remember vaguely the next day. We spent the 21 at, and from your discovery responses, I understand 22 night at a motel that night and-?and the next day. 22 it was a semi-automatic? 23 And the following week is a real haze. 23 A Semi. Semi-automatic. Right. 24 It was a real busy time because I was hospitalized 24 Meaning it's a weapon you have to aim and pull the Mr. Chisenhall Direct Page 42 Mr. Chisenhall Direct Page 44 1 twice that week. And I remember bits and pieces 1 trigger each time you shoot? 2 about that. But as far as the shooting goes, the 2 A Correct. I had had it a long time. I got it when 3 incident itself, anything after the glass broke, I 3 I graduated high school. 4 don't remember anything. 4 Looking as?-at Exhibit No. 16, do you remember 5 Q. Do you remember speaking to a police of?cer on 5 where Christian's body was laying on that porch? 6 your back porchyou remember seeing Tony Griggs that day? 8 Do you remember Christian ever coming through a A No. 9 window? 9 Prior to October 12, 2013, had you ever discharged 10 A No. I don't remember any--anything. 10 that .22 caliber semi?automatic rifle in your front 11 Are you aware of anyone who ever saw Christian 11 yard? 12 coming through a window? 12 A I don't think so. 13 A I don't think Katie was?-would have been the only 13 Are you aware of anyone else ever discharging it in 14 other one. And I think from what I understand, she 14 your front yard? 15 was in the closet. 15 A No. 16 Do you know who shot Christian? 16 After October 12, 2013, are you aware of anyone 17 A I did. 17 discharging that semi-automatic rifle in your front 18 How do you know that? Do you remember it? 18 yardThen how can you say you shot Christian if you 20 Sir, do you recall, was your dog loose in the house 21 don't remember shooting him? 21 when?~when the incident occurred? 22 A Well, ?cause I remember the?-where I?-was told of 22 A (Shakes head.) He was in the backyard and possibly 23 the 9-1?1 call is where I confessed and told them 23 in a pen in the backyard fence. 24 that I had--that I had shot him. I don't remember 24 Okay. As shown there in Exhibit No. . HIP-.3 Pace Reporting Service, Inc. (11) Pages 41 - 44 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 45 Mr. Chisenhall Direct Page 47 1 A That?s it. Yeah, there he is. That's it. 1 it says at this entry your--your son was there to 2 Okay. So there would have been no reason for 2 retrieve medication. 3 anybody to have to secure that animal? 3 Do you know what medication your son 4 A He may have been out in the pen, and somebody put 4 would have been retrieving from the crime scene? 5 him in the-?i mean, the fence, and somebody put him 5 A No idea. None whatsoever. 6 in the pen. I don't remember. Or he may have been 6 Any supposition or anything that makes sense for 7 in there to begin with. 7 your son to be retrieving medication from the crime 8 There's a BOLT lock here on that gate, Exhibit No. 8 scene? 9 14. And it was?- 9 A Nothing makes sense. 10 A Yes. It's right here. 10 Okay. What about securing that dog? Any reason 11 Yes, sir. It was locked at the time. 11 your son would have been there securing that dogthat BOLT lock? 12 Was-did the animal need securing? Would there 13 A Lydia and 1. 13 have been any way for him to secure that dog? 14 Okay. Where do you keep that key? 14 ldon't know. I didn't know he did. Hie-was this 15 A Above the refrigerator?? 15 gate locked? 16 Okay. 16 Yes, sir. That's the BOLT lock we're looking at 17 A ??in a dish. 17 there. 18 Who knows where that key is? 18 MR. LEVIN: Well, objection. We don?t 19 A Just Lydia and I. 19 know that. No one has testi?ed to that. 20 Okay. Did Katie or your son know where that key 20 MR. JES SUP: I'm just taking that from 21 is? 21 the police file. 22 A Probably not. 22 MR. LEVIN: Well, you don't have that to 23 Okay. Do you recall getting that key and letting 23 show him. So if that's your question, I?m--l 24 people through that gate after the?-immediately 24 object. You can answer if you know. Mr. Chisenhail Direct Page 46 Mr. Chisenhall Direct Page 48 1 after the incident occurred? 1 I don?t think there was even a lock on the~-the 2 A I don't, no. 2 pen. There could have been, but 1-?1 know there 3 I'm going to hand you what was marked yesterday as 3 was a lock here. But I don't know that there was 4 Exhibit No. 12. It's a crime scene sign-in log. 4 even a lock on the pen. Probably not. 5 See there, first of all, Angier Fire 5 Going to ask you about No. 17. 6 signed in at eleven-oh-?ve, appears to be the 6 Where was that table before it was in 7 first on the scene, and there?s no name 7 that bush? 8 accompanying that. 8 A Right here. 9 Do you know who was first to arrive on 9 Okay. Do you know what Christian used to-?to, you 10 the scene from Angier Fire? 10 say, knock in the window? 11 A No. 11 I'm assuming that table, but I don?t know. 12 Is that the organization your son was volunteering 12 I want you to think real hard for me, 'cause there 13 with? 13 are some prior interview notes, and we?ll look at 14 A Uh?huh (yes). 14 those in just a minute. 15 Okay. 15 You don't remember, looking here at 16 A Yes. 16 Exhibit No. 18, Christian coming through that 17 And do you see there where your son signed in to 17 window on either side? 18 the crime scene at eleven-forty? I'll show you. 18 A No. I have no recollection of?-of those moments. 19 Patrick Chisenhall, Jr., is that your son? 19 Looking here at Exhibit No. 15, is that the door 20 A Yes. 20 that you and Katie and Christian struggled with? 21 Okay. And you see there where Patrick Chisenhal], 21 A Yes. 22 Jr., also later signed in to the crime scene again 22 And looking here at Exhibit No. 8, is that the air 23 at two?forty-?ve? 23 condition unit? 24 A Yes. 24 A Yes. That's it. Pace Reporting Service, Inc. (12) Pages 45 - 48 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 49 Mr. Chisenhall Direct Page 51 1 Was there any damage to that air condition unit? 1 to be. But that segment is the primary blockage, 2 A I don't think so. 2 the black spot in my brain. 3 Looking here at Exhibit No. 19, is that the closet? 3 How soon after this incident on October 12, 2013, 4 A That's the closet. 4 did you check yourself in for 5 Okay. Were there any other firearms in that 5 treatment? 6 closet? 6 A It was the following Thursday night. 7 A Yes. There was two shotguns in there. 7 Okay. And I don't want to know about anything that 8 Did you typically keep that .22 caliber rifle fully 8 you've talked about with a lawyer, but had you 9 loaded? 9 sought out a criminal lawyer before going and 10 A No. i don't remember how many bullets was in it, 10 checking yourself in for treatment? 11 but I didn't typically keep it fully loaded. 11 A Yes. 12 Okay. What did you use that rifle for? 12 What was the name of that criminal lawyer? 13 A Originally hunting. But I had quit hunting, you 13 A Gerald Hayes. 14 know, years earlier. SO it was just a gift to me 14 Were you given his name by anybody with the Harnett 15 from my-~when I was eighteen years old. So I had 15 County Sheriffs Department or the Harnett County 16 just kept it for sentimental value and I guess home 16 District Attorney's Of?ce? 17 protection. 17 A No. 18 Do you recall ever hearing Christian moaning? 18 Where did you get Mr. Hayes' namefriend ofmine recommended him. 20 Going to hand you one of your records from 20 Who is your friend? 21 treatment we took a look at 21 A Gary Adcock. 22 yesterday. It was Exhibit No. 22. 22 And who is that? 23 I want to look up here at this line that 23 A Another member of my church. 24 says, "Pat reports of permitting escape for his son 24 What does he do for a living? Mr. Chisenhall Direct Page 50 Mr. Chisenhall Direct Page 52 1 and covering for him." 1 A He has a--he's self?employed. He has a power 2 What is that in reference to, sir? 2 washing business. 3 A I have no idea. No clue. I've?- 3 But I have no idea where that's coming 4 Have you ever covered anything for your son? 4 from or what that means, the covering for him, 5 A No. 5 escape for his son. Ihave no idea. 6 See down there at the bottom, December 18th, 2013, 6 I want to look with you now-have you seen the 7 it says your memory has returned in large part? 7 medical??the state medical examiner's af?davit 8 MR. LEVIN: Objection. That's not what 8 before, sir? I'm going to give you just a moment 9 it says. 9 to read it, and then we'll look at some parts in 10 "Pat reports long?term memory has returned in large 10 there together. 11 part"? 11 (Examines paper?writings.) All right. 12 A It has greatly improved. 12 (DEPOSITION EXHIBITS NO. 23 24 13 Tell me about how your memory has improved since 13 MARKED FOR IDENTIFICATION) 14 the incident on October 12, 2013. 14 Sir, I also want to hand you a af?davit done by a 15 A Well, it went from pretty much nothing to I can 15 sheriff?s deputy in support of a search warrant and 16 remember most of my past. Some of it's foggy, 16 the warrant itself marked as Deposition Exhibit No. 17 hazy. My short-term memory is pretty good. And 17 23. 18 it's been a gradual thing, but my long?term memory 18 I'll give you a moment to read the 19 overall has improved and returned. 19 affidavit attached to that search warrant. 20 Other than the actual shooting itself, is there 20 (Examines paperwritings.) 21 anything that--is there anything that you used to 21 Finally, sir, I want to hand you what?s been marked 22 know that you now can?t remember as you sit here 22 as Exhibit No. 24. It's a case summary. 23 today? 23 And for what I'm going to be looking at 24 A I don't know. I'm??my memory is not what it used 24 with you, sir, I'd like you to read Pages 4 to 6 of Pace Reporting Service, Inc. (13) Pages 49 - 52 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 er. Chisenhall Direct Page 53 Mr. Chisenhall Direct Page 55 1 this document. 1 kidney. 2 A (Examines paperwritings.) 2 Another round entered the decedent?s body 3 Have you completed reviewing those documents? 3 cavity in the abdomen on the left side just above 4 A I think??I think so. 4 the top line of the navel and left of the midline. 5 Do you know who called your son to come to the 5 This round had a trajectory which was 6 crime scene? 6 downward with a path of left to right. This 7 A I think he heard it on his radio. 7 projectile stopped about midline near the spine. 8 Has he told you that? Is that how he got there so 8 The next four rounds were in the back. 9 quickly? 9 Dr. Scott advised me that the four rounds were 10 A Yeah. Yeah. 10 separated into two pairs. She stated that each 11 Are you one hundred percent certain that your son 11 pair shared a similar trajectmy and path. 12 was not present at the crime scene at the time the 12 The pair of projectiles that entered the 13 shooting occurred? 13 decedent on the left of the midline of the back had 14 A Yes. Hundred percent. 14 a trajectory path towards the head. She stated the 15 MR. LEVIN: Just note my continuing 15 projectiles went through the abdomen, the 16 objection to the phrase "crime scene.? But you can 16 diaphragm, the left lung, and both came to rest in 17 continue. 17 the muscle under the skin of the left chest. One 18 I'm going to read to you, sir, a brief portion of 18 of the projectiles pierced the spleen and the other 19 Exhibit No. 24. And then I?d like to ask you some 19 hit the edge of the liver. She can't determine 20 questions about it. 20 which projectile did what damage, as the pairs were 21 After I completed this case review, I 21 too close together. She advised the body was 22 learned that the entire living room was searched 22 either in a prone or a bent over position at the 23 and only three shell casings of a .22 caliber were 23 time of injury. 24 located as indicated in the crime scene 24 The second pair of projectiles entered Mr. Chisenhall Direct Page 54 Mr. Chisenhali Direct Page 56 1 photographs. Detective D. Hildreth advised me that 1 the back to the right of the midline. She advised 2 there were three shell casings left inside the .22 2 they too had what was consistent with an upward 3 caliber murder weapon at the time of seizure, which 3 trajectory, but couldn't testify as to what degree. 4 would indicate that if there were ten shots in the 4 She advised this was because both had hit his 5 ri?e at the start of this incident, that one of 5 Spinal cord and spine shattering into fragments. 6 the shots could have been a miss. Detective 6 She stated that when these projectiles hit the 7 Lieutenant J. Webb advised me that there were no 7 spine the damage done was suf?cient enough for her 8 latent prints on or about the window casing, which 8 to say that paralysis would have been caused in 9 is not uncommon since the window had an opening and 9 both of the decedent's legs. 10 the decedent may not have used his hands to brace 10 Dr. Scott advised the abdomen shot would 11 himself on the casing or the window itself in an 11 have been a survivable shot had the decedent had 12 attempt to come in the house. 12 medical aid within about two hours. However, she 13 On October 22, 2013, I, along with 13 stated that the injury coupled with the two fatal 14 Detective D. Hildreth met with the pathologist, Dr. 14 shots into the back whereby two projectiles hit the 15 Scott, who performed the autopsy on the decedent. 15 spleen, liver, diaphragm and left lung, the 16 She advised me of the facts of the decedent's 16 decedent never would have survived. 17 injuries during this meeting, which are explained 17 Then we see--then see from Paragraph 4 of 18 below. 18 the medical examiner's af?davit that: Based upon 19 One round entered through the decedent's 19 the trajectory of the bullets that entered the 20 left shoulder at a downward angle. This round 20 decedent?s back, and assuming the shooter was 21 traveled parallel to the spine and never entered 21 standing at the time of the gun assault, decedent's 22 the body cavity, but instead remained in the muscle 22 body had to be bending or lying face down away from 23 tissue. This was not a fatal shot. This round 23 the shooter, and decedent's body was parallel or 24 stopped about the tOp line of the decedent's left 24 nearly parallel to the ground at the time of the 1 dnf-?in? . Pace Reporting Service, Inc. (14) Pages 53 56 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 57 Mr. Chisenhall Direct Page 59 1 four gunshots to decedent's back. The position of 1 this af?ant received new information from Dr. 2 the decedent?s body in contrast to a standing 2 Scott who conducted the autOpsy at the North 3 shooter is generally inconsistent with the claim of 3 Carolina State Medical Examiner?s Of?ce. Dr. 4 self?defense. 4 Scott advised Detective West who was present for 5 Sir, do you believe you ?red those four 5 the autopsy that in her opinion more than one 6 shots into Mr. Griggs' back? 6 bullet wound occurred while Christian Griggs was 7 I have no memory of it. None whatsoever. 7 laying in a position--was in a laying position, and 8 Based upon your memory of what your relationship 8 this possibly may have occurred while-while Griggs 9 was with Mr. Griggs at the time and your memory of 9 was laying outside the residence on the front porch 10 what had occurred that day, do you believe you 10 of the residence underneath the window. 11 would have-after you shot the ?rst two shots, the 11 This af?ant believes, based on 12 one that struck the shoulder and the one that 12 interviews and investigation, that there is 13 struck the abdomen, do you believe you would have 13 evidence of breaking and entering and shooting 14 intentionally shot Mr. Griggs in the back four more 14 incident at the address of I 1378 NC 210 North, 15 times or do you believe those four shots in the 15 Angier, Harnett County, and that Griggs may have 16 back were an accident? 16 been outside the residence when he was shot in the 17 I don?t know how to answer that since Idon't 17 back area of his body. 18 remember it. 18 Sir, based upon what you observed that 19 Do you believe somebody else shot Mr. Griggs? Do 19 day and what you remember, do you have any 20 you have any reason to believe someone other than 20 supposition or any explanation as to how Mr. Griggs 21 yourself shot Mr. Griggs? 21 was shot four times in the back while either in a 22 A No. I have no reason to believe that. 22 bent over or a laying down position? 23 Do you ever remember standing on the porch with Mr. 23 A No. 24 Griggs and having a ?rearm in your hand? 24 You?ll note-and what I read here, that there-? Mr. Chisenhall Direct Page 58 Mr. Chisenhall Direct Page 60 1 A No. 1 there are only-?there were six bullets that went 2 We?ll look at what I've marked as Exhibit, I 2 into Mr. Griggs? body, and there are only three 3 believe 23, the search warrant af?davit. And I?m 3 shell casings found?-and that was Exhibit No., I 4 just going to read something there to you from the 4 believe, 24. If we look at Exhibit N0. 13 from 5 second to last page. 5 yesterday, it?s a summary report. 1 want to focus 6 This af?ant was advised by Detective 6 on that highlighted portion. 7 1D. West that Christian Griggs had six bullet 7 One factor in this case that is uncertain 8 wounds; one to the left shoulder, two to the left 8 and causes question is the missing shell casings. 9 side of his back that were lodged into his upper 9 While there were six projectiles found in Christian 10 chest cavity, one to his left abdomen that lodged lo Griggs, only three shell casings were located 11 into his intestine, and two to the middle of his 11 inside the residence where Pat Chisenhall reported 12 back that were lodged in his spinal column. 12 he was standing when he had shot Christian. 13 MR. LEVIN: What page are you on? 13 Do you ever remember reporting to anybody 14 MR. JESSUP: It's marked as Bates No. 14 that you were standing behind the couch at any 15 159. 15 point after this shooting, that you had shot 16 MR. LEVIN: That's the third page in, not 16 Christian inside from through a window? 17 the second. 17 A No. I don't remember that. 18 MR. ESSUP: Third. Third to last. 18 Okay. Do you ever--have you ever looked for shell 19 This af?ant was informed that the two in the left 19 casings? 20 back are at a sharp angle and that Christian may 20 A No. 21 I have been laying down. 21 Have you ever found any shell casings? 22 i'm going to skip that paragraph because 22 A No. 23 it's largely procedural. 23 Has anybody ever told you where those other shell 24 During the course of this investigation, 24 casings went? 5 Pace Reporting Service, Inc. (15) Pages 57 6O Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chieenhall Direct Page 61 Mr. Chisenhali Direct Page 63 1 A No. Uh-uh 1 A No idea. I didn't even know that. 2 Your son ever told you he had retrieved sell-~shell 2 Do you have any reason to believe that Christian 3 casings from the crime scene? 3 was armed when he came to your house that day? 4 A No. 4 A Yes. 5 I noticed in the police ?le that it said the crime 5 Tell me about that. 6 scene was allowed to be cleaned up by friends of 6 A He had a handgun. And was sometime prior--I don?t 7 the Chisenhalls. And it doesn't specify who. 7 remember how long. It?s months prior, he had come a Do you know who your friends were that 8 to the house, once again trying to get in, hostile, 9 cleaned the crime scene? 9 irate. And Katie wouldn't let him in, so he went 10 A Not exactly. There were church members that came 10 down into the woods beside oftheir house. 11 over after the police had??had left, and attempted 11 I saw him. I happened to be in the 12 to clean up and ?x the window and-?but I don?t 12 backyard, and I saw him going into the woods. I 13 remember who all was there. 13 thought that's odd. So I walked down there to see, 14 And I noted that these church members were allowed 14 and he was sitting in the woods with his back up 15 to clean the crime scene before the search warrants 15 against a tree, and he had a cross on a chain, and 16 were executed. Do you know the names of any of 16 pictures of laden and Katie on the-Spread out on 17 those church members? 17 the ground, and a handgun laying there. 18 MR. LEVIN: Objection. Asked and 18 And he was extremely deSpondent, 19 answered. You just asked him that. 19 depressed. And I asked him was he suicidal, and he 20 Do you know the names of any of those church 20 said yes, and talking about taking them and himself 21 members that were cleaning the crime scene? 21 together. And it was very alarming. It was very 22 A No. Uh-uh 22 upsetting to me. And talked him out of it. I 23 How do you know they were church members that 23 said, ?Let me have the gun. Just give me the gun, 24 cleaned the crime scene? 24 and we can work this out." Mr. Chisenhall Direct Page 62 Mr. Chlsenhall Direct Page 64 1 I was told that's what happened. 1 So he??he eventually gave me the gun, and 2 Who told you that? 2 I kept it for several weeks. And he came back to 3 Lydia. 3 me, and he said~-he apologized. He said, "I'm okay 4 Okay. Are you aware of any of your family members 4 now. I'm good to go. I will need--I would love to 5 being involved in cleaning up the crime scene? 5 have my gun back.? And I reluctantly gave it back 6 A No. 6 to him. 7 Have you ever had to do any repairs to the interior 7 So based on that, was concerned that he 8 of your home where bullets struck around the window 8 was--he was armed. 9 or struck?-or were lodged in any pieces of wood 9 You didn't know that Katie had that ?rearm at the 10 or??or furnishings in the interior of your home? 10 time of the incidentHave you ever found any projectiles lodged anywhere 12 And you didn?t know that Katie had had possession 13 in the interior of your home? 13 of that ?rearm for some time? 14 A No. 14 A No. Uh?uh 15 Have you ever found any projectiles lodged anywhere 15 And he was talking about killing himself, your 16 on the exterior of your home? 1 6 daughter and his granddaughter [sic]. 17 A No. 17 Did you call the police? 18 Was there any blood that needed to be cleaned from 18 A No. I didn't call the police. 19 the interior of your homeany kind of 20 A No. 20 counseling? 21 Okay. Do you know how Christian Griggs' wallet 21 A I tried. He refused. 22 ended up inside of your home? 22 Okay. Did you let him then go back and live with 23 A His wallet was in my home? 23 your daughter and granddaughter after he talked 24 Yes, sir. 24 about killing them? iv; - as i gt: us:- Pace Reporting Service, Inc. (16) Pages 61 - 64 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 65 Mr. Chisenhali Direct Page 67 1 A I don't remember if he lived with them after that 1 A No. 2 or not. 2 Okay. I want to show you what was marked yesterday 3 Well, you said he lived with them until the end of 3 as Exhibit No. 20. Looking down, she states that, 4 September, right? And you said this was several 4 two weeks ago, meaning your wife--this is a 5 months prior. 5 statement from Lydia Chisenhall, and those are her 6 So he would have lived with them after 6 initials signed there beside each paragraph. And 7 that point, correct? 7 there's her signature on the last page. It says 8 A Right. Right. 8 there that there was a incident with the air 9 Okay. So after he talked about killing your 9 condition two weeks ago. And yesterday Katie was-- 10 daughter and your granddaughter, you then let him 10 Katie looked at that, and said, "Oh, yeah. I 11 go back and live in the same house with them 11 remember an incident with the air condition unit 12 without calling the police and without having him 12 two weeks before the shooting, too.? 13 in any kind of counseling? 13 Do you remember anything about that? 14 A Yes. 14 A No. So there was a second incident with the air 15 Who did you tell about this incident? 15 conditioner? 16 A Just my wife Lydia. I told the police on the day 16 According to your wife's statement and what Katie 1? of the shooting. 17 said yesterday was the ?rst we had heard about it 18 Okay. But other than your wife Lydia, the first 18 from Katie. 19 time you ever told anybody else about this incident 19 A No. I don't know anything about that. 20 was after you had shot Mr. Griggs? 20 At some point did your daughter leave the Sheriff?s 21 A (Nods head.) That's right. 21 Department on October 1 1th of 2013, and come back? 22 What made you believe that Christian was armed on 22 A I don't know. 23 the date of the incident? 23 Do you remember talking to her about any issues 24 A Simply that he??he had a handgun, that I had given 24 with getting warrants issued on October 11th, 2013? Mr. Chisenhall Direct Page 66 Mr. Chisenhali Direct Page 68 1 it back to him. And I was??I would just assume 1 A I don't know. 2 that he probably had it with him. 2 I want to hand you a text message that was marked 3 Prior to the shooting, did Katie ever tell you that 3 yesterday as Exhibit No. 5 between you and Katie. 4 Christian had sexually assaulted her? 4 It said, found the address, we're 5 A After the shooting, she did. 5 going back." And then you responded, ?Great. Do 6 What did she tell you about that? 6 what ever it takes. Shut him down." '7 A Not much. 7 Do you know what that's in reference to, 8 Did she tell you when it occurred? 8 sir? 9 A No. 9 A Ithink that's in reference to his address in 10 And was that the first time you had told Katie 10 Raleigh. He had an apartment in Wake Forest. And 11 about this incident, was after the shooting? 11 she had found the address, which she needed to get 12 A About the suicide?- 12 the restraining order. found the address, we're 13 Yeah. 13 going back." Must mean she went back. 14 A --scare? No. Itold her before. I've told her 14 Do you remember your initial interview at the 15 before that. 15 Sheriffs Department on October 12, 2013? 16 I thought earlier you testi?ed you only told your 16 A Very little. Not-~not really. 17 wife Lydia about that? 17 Do you remember going back to the Sheriff's 18 A Well, I may have misspoke. pretty sure I 18 Department later in that week voluntarily for a 19 told Katie. 19 second interview? 20 I want to look at some??I'm not sure I marked these 20 A Uh-huh (yes). 21 yesterday. Give me just a moment, sir. 21 Do you remember what you said in that second 22 Was there even?well, while I'm talking 22 interview? 23 to you, was there ever any kind of prior incident 23 A No. 24 with the air condition unit? 24 Tell me what you remember about going back to the -. Pace Reporting Service, Inc. (17) Pages 65 - 68 Griggs v. Chisenhail, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhali Direct Page 69 Mr. Chisenhali Direct Page 71 1 Sheriffs Department. 1 A "You??you've got to leave. You can't stay. You 2 A I just remember him questioning me, and 2 have to leave here. We have a restraining order 3 extensively. I don't really remember much about 3 against you. You've got to go." And that just 4 it. 4 seemed to enrage him all the more. Thatback to the Sheriffs Department? 5 said to him. 6 It's noted in the interview that they hadn't asked 6 Were you aware that his grandmother was in town to 7 you to come in and that you-?you were appearing 7 visit with laden that day? 8 there voluntarily. Do you know why you went backjust wanted to help out with the investigation. 9 Have you ever seen Christian?s calendar from that 10 What do you mean by that? 10 day? 11 A I wanted to tell whatever I could dowhatever I could say to help out. I don't really 12 Did that-?did those interview notes refresh any 13 remember why I went back. 13 kinds of recollections about what happened that 14 Had you remembered something that you wanted to 14 day? Did it make you remember anything that you 15 - tell them? 15 didn't remember earlier when we were talking? 16 A No. Not that I know of. 16 A No, not really. It's like reading something that?? 17 Going to hand you some notes from an interview that 17 for the first time. 18 were conducted of you October 12, 2013. I'm 18 MR. ESSUP: I'm going to mark this as 19 marking these as Exhibit No. 25, I believe. 19 Exhibit No. 26, I believe. 20 (DEPOSITION EXHIBIT NO. 25 20 (DEPOSITION EXHIBIT NO. 26 21 MARKED FOR IDENTIFICATION) 21 MARKED FOR IDENTIFICATION) 22 I'll give you just a moment to read these interview 22 When Christian was living in the house next door to 23 notes. 23 you, did he keep this board posted? 24 A (Examines paper-writings.) 24 A Idon't know. Never saw it. Mr. Chisenhall Direct Page 7?0 Mr. Chisenhail Direct Page 72 1 Sir, do these notes refresh your recollection at 1 You never saw Christian with a calendar? 2 all about what you told the police? 2 A Not that I recall, no. 3 A Yes. 3 Okay. Had you had any prior discussions with 4 Okay. Did you tell the police Christian was coming 4 Christian earlier in the week--earlier in that same 5 into the house through a window? 5 week, the week of the incidentApparently. 6 communication with Christian earlier that week that 7 Do you remember saying that? 7 you recalldon't think so that I recall. I don?t think so. 9 Do you remember that happening at all??at all? 9 Do you remember talking about football with himState fan, sir? 11 As you sit here today are you able to tell us 11 A No. We never?? 12 whether you intentionally or accidentally shot Mr. 12 Remember talking to him about his exams and fall 13 Griggs? And I'm referring to the four shots in the 13 break coming up? 14 back, the fatal shots. 14 A (Shakes head.) 15 A No, I'm not, because I don't remember it. 15 No? You don't recall those conversations? 16 Okay. Believe it's possible it was an accident 15 A No. Is that on the 12th? 17 discharging those four shots into Mr. Griggs? back? 17 Yes, sir. 18 A I have no idea. 18 A No. I knew nothing about visitation. 19 Sir, do you ever recall telling Mr. Griggs to shut 19 Have you ever actually seen the separation 20 the up? 20 agreement that your daughter had sent to Christian 21 A No. I don't really recall saying that. 21 apparently, according to her testimony yesterday, 22 What do you recall saying to Mr. Griggs apart from 22 the day before? 23 the stuff about the restraining order when he was 23 A No. Uh-uh 24 in the front yard? 24 I want you to take a look at that. Exhibit it} Pace Reporting Service, Inc. (18) Pages 69 - 72 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhail Direct Page 73 Mr. Chisenhall Direct Page 75 1 I'll hand you a unmarked copy of it. It was 1 A Don?t know. 2 Exhibit No. 2 yesterday. (Hands paperwritings to 2 And you're only diagnosed with 3 witness.) Give you a moment to take a look at 3 A That's correct. That's the official diagnosis. 4 that, sir. 4 But you're not diagnosed with any form of 5 MR. LEVIN: Is there anything 5 amnesia or any other form of amnesia? 6 speci?cally you want him to look at, since he said 6 A Not that I know of. 7 he's never seen it before? 7 Okay. Do you??are you aware of any medical 8 MR. JESSUP: I was just going to ask him 8 explan--explanation from your doctors as to why you 9 questions about how it described custody and 9 can't remember any of this? 10 visitation and how that fit with his 10 A No. 11 understandings. 11 Prior to this event on October 12, 2013, was there 12 A 1 had no understanding, no knowledge of thenof any 12 ever anything else in your life that you?ve ever 13 of this. Never seen it before. Never heard him 13 had trouble remembering? 14 discuss it. . 14 A ldon't think so. 15 And you are Christian's spiritual 15 And after this event on'October 12, 2013, is there 16 counselor? He was very close to you? He discussed 16 anything else at all that you've had trouble 17 his and Katie?s relationship intimately with you, 17 remembering in the week--in your discussions with 18 is that??that correct? 18 the police after it? 19 A The Spiritual counselor was in more the early days, 19 A Can you say that again? 20 not so much in the??the latter days. 20 Other than the events on October 12, 2013, and your 21 You baptized him just several weeks before the 21 subsequent discussions with police of?cers, is 22 shooting, correct? 22 there anything else since then that you?ve had any 23 A Uh?huh (yes). 23 trouble remembering or have any trouble remembering 24 And he--he had recently become saved? 24 as you sit here today? Mr. Chisenhall Direct Page 74 Mr. Chisenhall Direct Page 76 1 A He did that in Iraq. 1 A Well, yes. My overall memory was terrible. And it 2 So it's your testimony that none ofthose custody 2 has gradually come back, gradually improved. But I 3 arrangements were ever discussed with you by 3 had struggled multiple times with remembering 4 Christian or Katie? 4 things of-?of my childhood and current events. But 5 A Correct. 5 that has gradually improved greatly. Not??it's not 6 Okay. I'm going to look at?-l want to 6 perfect, but it has gradually improved. 7 look at some interview notes that were marked '7 Are you able to remember your childhood and current 8 yesterday as Exhibit No. 10. I want to look at the 8 events as we sit here today? 9 second page. I'm trying to ?nd me a copy of those 9 A Pretty well. 10 where I can look on, as well. 10 Okay. As we sit here today, other than the events 11 On the second page, notes that you told 11 of October 12, 2013, and your subsequent interviews 12 the police that Christian??and this was?~this was 12 with police of?cers, is there anything else you 13 later in the week. I believe that's dated October 13 have trouble remembering? 14 15th. You had told the police that Christian had 14 A I don't think so. 15 said, "I'm going to kill you," as he was coming 15 Have you ever had any kind of formal firearms 16 through the window. 16 training, sir? 17 Do you recall that happening, sirprior military experience? 19 You also said that you shot Christian ?cause you 19 A No. 20 were convinced he was going to kill your daughter. 20 No experience in law enforcement? 21 Do you remember saying that, sirHas Katie ever told you she heard Christian 23 Do your doctors have any supposition or expectation 23 moaning? 24 as to when you are going to regain your memory? 24 A No. Not that i recall. ?'iiv'lii- lift ii?; @4132; Pace Reporting Service, Inc. (19) Pages 73 76 Griggs v. Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhall Direct Page 77 Mr. Chisenhall Direct Page 79 1 Thinking back real hard, do you recall hearing 1 A I'll have to look and see. I'm not sure. 2 Christian moan? 2 Could you look and see and produce that to Mr. 3 A Uh?uh No. 3 Levin where discovery? 4 Were the ?rearms in your closet, were?-were they . 4 A Okay. 5 secure? Did you have trigger locks on them or 5 To your knowledge was Christian ever served with 6 anything like that? 6 those warrants that were issued on Friday night? 7 A No. 7 A Idon?t know. 8 Looking back at that crime scene log, I handed it 8 You-- 9 to you a little bit earlier??l can just grab 9 A Prob--probab1y not. I don't know. 10 another copy?-is there anybody else?s name on that 10 Were you aware of Amber ever engaging in any 11 log that you know or recognize or who is a member 11 behavior that made Christian uncomfortable for 12 of your church? 12 Jaden to be with her? 13 A My son Patrick is the only person I recognize. 13 A No. None. 14 Do you have any memory whatsoever of being taken 14 Are you aware of any of Katie's friends that you or 15 out of that-crime scene? i 15 Jaden weren't??that you or Christian weren't 16 A No. 16 comfortable with Jaden being around? 17 And the moment where you lost memory, or where you 17 A NO. None that I was uncomfortable with. 18 don't have memory now, is when you hear the glass 18 Did you and Katie stop anywhere to get food on 19 shatter, and there's nothing beyond that? 19 October 12, 2013? 20 A That?s correct. 20 A Food? No. No. 21 Are you willing to take a polygraph, sir? 21 Your only stops that morning were with Wake County 22 MR. LEVIN: Objection. You don't have to 22 Magistrate and the-- 23 answer that. 23 A Phone store. 24 A (No answer.) 24 That was a Sprint store, right? Mr. Chisenhall Direct Page 78 Mr. Chisenhall Direct Page 80 1 Are you aware of anyone ever going in your yard and 1 A I think I saw that a While ago. Yeah, Sprint. 2 searching for shell casings? 2 Did Katie have more than one cell phone at the 3 A No. 3 time? 4 I noted in your records that at some point Katie 4 A I think she only had one. 5 had written you some kind of letter while you were 5 When was the last time any law enforcement 6 receiving treatment at Holly Hill. 6 interviewed you about the events of October 12, 7 Do you still have a copy of that letter, 7 2013? 8 sir? 8 A I don?t know. I?m not sure. 9 A I think so. She thanked me for saving her life. 9 MR. JESSUP: I have no further questions 10 Could you provide Mr. Levin a copy of that letter 10 at this time, Mr. Chisenhall. 11 for it to be produced in discovery? 11 DIRECT EXAMINATION BY MR. JOHNSON: 12 A I believe so. 12 Mr. Chisenhall, my name is Lee Johnson, and I 13 And I also noted in your?- 13 represent Katie. 14 A 14 A Okay. 15 Go ahead, sir. 15 Ijust have a couple of questions. 16 A I'll look for it, and I?ll send? 16 Prior to the time when you last recall 17 Thank you. And I also noted in your 17 anything about this incident on October 12, did you 18 records that there are some mentions of how you 18 see or--or Katie attempt to hurt or harm Christian 19 were journaling about the incident. 19 Griggs in any way? 20 Do you know what that?s in reference to? 20 A No. 21 A Yeah. I did some journaling-?I?m trying to 21 Did you hear her express any anger or ill will 22 remember how much or what--as part of my therapy. 22 toward him in any way? 23 Do you still have that journaling about the 23 A No. 24 incident, sir? 24 Did you see her attempt to get access to any type Pace Reporting Service, Inc. (20) Pages 77 - 80 Griggs Chisenhall, Mr. William Pat Chisenhall and Griggs May 24, 2016 Mr. Chisenhali Direct Page 81 1 of gun while he was there? ML ?name? 2A APPEARANCES 3 Did you ever see her place her hand upon any .22 or 4 other ri?e or weapon that you owned? the Plaintiff: A No. ?an 6 Did she ever say anything to you about causing any meson, ATKINS, ANGELL DAVIS 7 harm to Christian on that day? P-O- 30" 13347 a A No. None. She was just terri?ed ofhim. Ramigh' mm? camli? 27605 9 MR. JOHNSON: Okay. That's all the 10 questions I have. Thank you very much. For the Dafendantm Mr- Lee 50111150? 11 THE WITNESS: Thank you. 22:23:? 523:3? 12 MR. LEVIN: I don't have any questions. 109 Broadfcot Avenue 13 THE VIDEOGRAPHER: This concludes the FaYettEVille? ?Nth Carolina 23305 14 deposition. The time is Waive-twenty P.M. Fm" Katie Griggs 15 (WITNESS EXCUSED) Mr. Robert E. Levin 16 HAYWOOD, DENNY MILLER 17 (WHEREUPON, THE DEPOSITION WAS CONCLUDED AT 12:20 PM.) 18 19 (05-24-2016) P.O. Box 51429 Durham, North Carolina 27?17 For William Pat Chisenhall The Videographer: Mr. Brent Troublefield STATE OF NORTH CAROLINA Page 82 COUNTY OF WAKE I I A I, Dana C. Dopko, a Notary Public in and for the State of North Carolina, duly commissioned and authorized to administer oaths and to take and certify depositions, do hereby certify that on May 24, 2016, WILLIAM PAT CHISEHHALL, being by me duly sworn to tell the truth, thereupon testified as above set forth as found in the preceding 81 pages, his examination being reported by me verbatim and then reduced to typewritten form under my direct supervision; that the foregoing is a true and correct transcript of said proceedings to the best of my ability and understanding; that I am not related to any of the parties to this action: that I am not interested in the outcome of this case; that I am not of counsel nor in the employ of any of the parties to this action, and that signature of the witness was waived. IN WITNESS WHEREOF, I have hereto set my hand, this the 8th day of June, 2016. Notary Public Certificate No. 20020850292 Dana C. Dopko PACE REPORTING SERVICE P. 0. Box 252 Cary, North Carolina 27512 Telephone: 919/859-0000 Raleigh 910/433-2926 - Fayetteville 910/790-5599 - Wilmington Direct Johnson Page 80 Mr. Chisenhall Examination Direct A I A I I By Whom Page No. Jessup 5 Es i? Pace Reporting Service, Inc. (21) Pages 81 - 80