Depo - Clay Hill - Sep 24 2003 14 Mr. McCullough and Ms. Houston were properly supervised 15 to ensure their duties were performed adequately? 16 A. Yes, I think we did. 17 Q. Did you disagree that they -- his finding that 18 they did not properly restrain Latasha which led to 19 injuries and death? 20 A. You know, again, based on the information we 21 had, we felt like the restraint was done the way it was 22 supposed to be done. 23 Q. Okay. Why did you disagree with his finding 24 that they were not properly supervised to adequately 25 ensure their -- to ensure their duties were performed O'NEAL * PROBST * WELLS - 713.521.1314 236 1 2 adequately? A. Well, there are no standards that require a 3 supervisor has to be around every staff at all times. 4 And so that has been good for all this length of time; 5 and now all of a sudden -- all of a sudden you have a 6 serious incident and CPS is saying they weren't 7 supervised adequately. 8 Q. What did -- 9 A. If they -- if they wanted to tell us what -- 10 11 12 That's -- that's my answer. Q. Wouldn't you agree that -- A direct-care staff has to have some supervision, correct? 13 A. Yes. 14 Q. Because otherwise you don't know if they are 15 performing their duties adequately, right? 16 A. Correct. 17 Q. And so did you read his finding to conclude 18 that Daystar did not have sufficient staff supervision Page 202