Depo - Clay Hill - Sep 24 2003
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at that point consider the use of force reasonable and

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minimizing the risk of physical discomfort, harm, or

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pain to her?

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MR. DAW:
A.

Form.

Again, according to the information I had, I'm

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not willing to agree that the restraint caused the

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suffocation.

And that's -- that's my answer.

O'NEAL * PROBST * WELLS - 713.521.1314

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Q.

(BY MR. COLLMER)

And why are you not willing

to agree to that?

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A.

Well, I just am not sure that's what did.

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Q.

Well, do you have any information which says

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that something else caused her to die during the

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restraint coincidentally immediately proximal in time to

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the restraint being applied to her?

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MR. DAW:

Form.

And that's not how it

happened, and you know that.

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MR. COLLMER:

That's just not true.

You

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know, that is how it happened.

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department reports say one thing.

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massage the people, they say a different story.

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want to get into the issue of whether or not suborning

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was involved, that's a different issue.

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involved in but it sure looks like people's stories

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change radically from what they first told the sheriff's

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people.

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MR. DAW:

You know, the sheriff's
After the lawyers
If you

Not one I'm

Well, yeah, I appreciate you

saying that.

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MR. COLLMER:

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MR. DAW:

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MR. COLLMER:

Yeah, you know --

But the way you just --- you -- you wanted to
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