Page 1 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE-OPELOUSAS DIVISION

CASEY ARCENEAUX, ET AL VERSUS LAFAYETTE CITY POLICE DEPARTMENT * * *

CIVIL ACTION NO. 09-CV-01236 JUDGE HAIK MAGISTRATE JUDGE HILL

* * * * * * * * * * * * * * * * * * * * * * * * * *

The deposition of ROBERT KEY, taken in connection with the captioned cause, pursuant to the following stipulations before CONNIE MARKS, Certified Court Reporter, at the offices of DOUCET-SPEER, APLC, 617 St. John Street, Lafayette, Louisiana, on the 26th day of April, 2012, beginning at 5:17 p.m.

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Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: Mr. Gautreaux, IT technician MR. JASON B. BOUDREAUX GIBSON-GRUENERT, PLLC 600 Jefferson Street, Suite 600 Lafayette, Louisiana 70502 E-mail: Jboudreaux@gibson-gruenert.com FOR THE DEFENDANTS, JIM CRAFT, MICHAEL ANTHONY MILLAZO, LAFAYETTE CITY PARISH CONSOLIDATED GOVERNMENT: MR. JEFFERY F. SPEER MR. MICHAEL A. RAINEY DOUCET-SPEER, APLC 617 St. John Street Lafayette, Louisiana 70502-4303 E-mail: jefferyferralspeer@gmail.com E-mail: michael@raineylaw.net FOR THE PLAINTIFF, CASEY ARCENEAUX, ET AL: APPEARANCES:

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Page 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 S T I P U L A T I O N It is hereby stipulated by and among counsel for plaintiff and counsel for defense that the deposition of ROBERT KEY Be taken before CONNIE MARKS, Certified Court Reporter, by counsel for the plaintiff for all purposes, pursuant to notice and to the provisions of the appropriate statutes of the Federal Rules of Civil Procedure. The parties hereto waive all formalities in connection with the taking of said deposition, including the reading and signing thereof, except the swearing of the witness, and the reduction of the questions and answers to typewriting. Counsel for all parties reserve all objections, except as to the form of the question and responsiveness of the answer, at the time of taking said deposition, but they also reserve the right to make objections at the time said deposition or any part thereof may be offered in evidence, with the same rights as if the testimony had been taken and given in Open Court. * * *

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Page 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EXHIBITS: Exhibit 1 Exhibit 2 Exhibit 3 (Maintenance records). . . . . . . .114 (Photo of office). . . . . . . . . .116 (Driver's license) . . . . . . . . .116 OBJECTIONS: BY MR. SPEER . . . . . . . . . . . . . . . . 81, 94 . . . . . . . . . . . . . . . .131 EXAMINATION BY MR. SPEER . . . . . . . . . . . . . 5 EXAMINATION BY MR. BOUDREAUX . . . . . . . . . . .37 EXAMINATION BY MR. RAINEY . . . . . . . . . . . .117 RE-EXAMINATION BY MR. BOUDREAUX . . . . . . . . .132 RE-EXAMINATION BY MR. RAINEY. . . . . . . . . . .136 FURTHER EXAMINATION BY MR. BOUDREAUX. . . . . . .137 INDEX

BY MR. BOUDREAUX

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Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q A Q A Q A Q ROBERT KEY, Who resides at 1020 Dautreuiel Lane, St. Martinville, Louisiana 70582, after having been duly sworn, was examined and did testify as follows: EXAMINATION BY MR. SPEER: Q Mr. Key, my name is Jeff Speer. I represent

the Damond family as a result of a shooting of a Shane Damond that happened at a Circle K store at the corner of Louisiana Avenue and Mudd on July 26, 2008. Would you state your

full name for the record, please? Robert Key, K-e-y. I've been putting an "s" on it; it's just Key? Correct. Okay. Mr. Key, where do you currently reside?

1020 Dautreuiel Lane. And where is that? St. Martinville. All right. And where are you employed?

I'm not; retired. Okay. On July 26, 2008, did you work for

Circle K? I think so. Okay. I might have went back there.

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Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q Q A Q A Q A A A Q Q Were you the store manager at the time of the shooting that occurred at that Circle K? Yes. Were you present at the scene on July 26, 2008, either before or after the shooting? Well, after the shooting I was present because the police department called me and asked me to come out and secure the store because there had been an incident. Okay. Do you know who it was that called you?

I want to say Mr. Brown, you know, I'm not certain, but I want to say it was him because after I got to the store, there was tape. I

couldn't pull into the lot, so I circled the block and I got and parked my vehicle over by the golf course. They had tape -And Mr. -I'm sorry, go ahead. And Mr. Brown met me halfway on the block on the far side of the street. And at that time, what was your position with Circle K? Store manager. Of that particular store?

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Page 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A Q A A Q A Q Yes. Was you also manager of other stores or just that one? Just that one, at that time. All right. As the store manager of that

store -- well, before I go any further, let me ask you: Did you have an employee working for

you at that time named Sandra Broussard? Yes. Okay. As a matter of fact, I think she was working the midnight shift. All right. As you sit here today, are you

familiar with, still remember, the surveillance equipment used in that store? I don't know the name of it; I know we changed it about a year after that. About a year after the shooting? Yes, it was after the shooting. At the time of the shooting, it's my understanding, as the computer screen there shows, that there was a surveillance system that had six different cameras. Can I turn that here? Yes, of course you may. That had six different

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Page 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A Q A A Q A A Q cameras that focused on the cashier, various aisles of the store, the storeroom, the office and the parking lot; would that be correct? That's correct, sir. And that system, do you know who manufactured that system or not? You asked me a difficult question, I truly don't know. Okay. Well, tell me this: Was it the kind of

system that all the cameras operated at one time? You turn it on, all the cameras came on

or did you have to go and turn on one camera at a time? No, all the cameras are on. Now, if you had a

malfunction that particular camera wouldn't be operative to the building, you know. We did --

they were really good with the maintenance for getting those things fixed. You had good maintenance? Yes, sir. Okay. Because I did -- I seen that everything was working. Tell me what kind of system was it. Did it

record all of the video that it took onto a DVR

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Page 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A A or did it record it onto a VHS tape or DVD or what? You got me with those names. About the only

thing I can tell you is just that if an incident took place at, say, at say the island and -MR. BOUDREAUX: I'm sorry, at the what? On the island, where we sell gasoline. MR. BOUDREAUX: Oh, okay. Okay. I'm sorry.

And if the system was working, we could go back to the system, to the DVR, and we would put a tape in there and we calibrate the signals from beginning to ending. If it said from 4:00 to

6:00 that we need to look at, that's what we put in, from 4:00 to 6:00, and then we could tape that. BY MR. SPEER: Q Now, when you say "tape," was it on a tape or was it like a round CD or DVD? Round, you got it. Okay. So, it was like a CD or DVD?

Yes, sir. It was not a tape?

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Page 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A Q A Q No. Okay. I said that wrong. But, no, that's just a question though;

correct? Yeah, you're right. All right. You're right.

So, but when the store manager, say

you go to work and you turn the system on, you get there, all six of those cameras are working all the time? All the time. All of those cameras should be running synchronized at the same time? Correct. Okay. I have an issue and I would like -MR. SPEER: Wayne, just back up and press play on all of them, if you can do it. BY MR. SPEER: Q Now, I'm looking at this and there's six different little screens. (Witness reviews video on computer). Okay.

And it's different, there's time and date on each one, correct? Well, the time should synchronize, like you said. All of them?

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Page 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q BY MR. SPEER: Q Okay. Well, all the cameras operate at the A BY MR. SPEER: Q This is a question I got: MR. BOUDREAUX: Jeff, can I ask a question? something about the island and -MR. SPEER: He's talking about the gas pumps. MR. BOUDREAUX: And he said he didn't see the island. My question is: Should you be seeing the He said We obtained -Q A Regardless of what's going on in front of that particular camera. Okay. MR. SPEER: Stop it.

island on those cameras? You should. MR. BOUDREAUX: That's it.

same time? Yes. They should all have the same time on each camera?

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Page 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q Q A Q A Q A Q A Q A Same time. little bit. How much? Three or four seconds, something like that. Okay. off? Have you ever seen them be ten minutes Well, here, let me ask you this -Well, I've seen them be off a

I tell you what, I've seen them off at the time change, like a time go -- I've seen them off about an hour. Okay. Right. Okay. Here's the issue I have, and you were When the time changed?

store manager for how long over there? I think I had been with them pretty close to thirty years. Thirty years. So, you're very familiar with

the store and the operation and all of that? Yes. On the night that you got called out by the police to secure that location, did you, number one, when you got onto the scene, did you talk to the police? Mr. Brown met me halfway the block, over by the golf course. Now, is Mr. Brown a black police officer?

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Page 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q Q A A A Q A Q A Q A Q Yes. Lafayette City Police officer? Yes. Okay. And you talked to him?

Yes, sir. Did you talk to anybody else? Nobody else. Did you go and look at the surveillance system with any other police officers at that time? I don't know if I looked that night, but that following morning -Yes, sir. -- I don't know if it was a detective or police officer, but we did review that -- that's why --that's the first time I took a look at it. Did you, at any time, that night of the shooting, the next day, any time, take one of those round DVD, CDs and make a copy of what happened that night and give to the police? I didn't make a copy, but the police department came in and made a copy and that's when I looked at the camera, and I could vaguely see what was going on out there at night. Now, we talking about the camera in the parking lot?

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Page 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A Q A Q Yes. And you could see what was going on vaguely in the parking lot? Correct. Okay. Let me -- I don't want to put words in So, I'm

your mouth, but it's important, okay?

going to back up and I'm going to ask you again. Well, I'm not going to let you put words in my mouth. No, no, no, I'm not going to, I don't want to. As I understand it, you just said the police went and got a copy off of the machine? Yes. Now, listen, I remember Mr. Brown stating

he said the police department was responsible for all the cash and all the merchandise that was in the store. And he said for me to go in

the store, check the money, and do a random check of everything in the store to make sure there was nothing missing. Yes, sir. And he said, "I'll be back to do a report." Okay. Well, back to my question we were

talking, I asked you if you gave a copy of what happened off of that surveillance equipment to

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Page 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A Q Q A Q A A Q A Q the police, and I believe you said, the police went and got a copy. Yes. And I was there at the time.

And you watched -Yes. -- and saw vaguely what happened in the parking lot? Well, when I say "vaguely," you couldn't see anything out there. The only thing I know, it

was a car sitting there, or a truck, or whatever. Okay. You could see that. Well, --

All right.

See, it was in the morning. Yes, sir. There were lights on the exterior of

that store, was the parking lot lit up? Yes. I think it was pretty well litted (sic).

At any time -- as I understand your testimony, at no time did you personally make a copy off of that surveillance machine to give to the police; the police did it themselves? Yes. Do you know what police officers did it? I really don't know the guy's name. Okay. I know it wasn't Brown though.

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Page 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q Q A A A Q A Q A Q Q A Q Q A Q A It was not Brown? No, it was not. Was it a white man? That's a good question. question. Was it more than one? Just one. When you watched the video and you saw it that morning, whatever was there, how many people were there watching it with you? Just myself and the officer. And that one other officer? Right. The one who made the copy? Right. Okay. Do you think you could pick that officer That's a good

out of a crowd if you saw him today? No. I would be lying to you. I said I would

be lying to you if I said I could, sir. Okay. Well, --

The reason why I could pick Brown out, because I knew Brown for a long time. Yes, sir. Yes. Okay. Here's the issue I have, on that He worked that part of town?

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Page 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q computer that was playing a second ago, is a copy of the recording that both sides of this case were given as the recordings of the surveillance equipment that were taken that night at the Circle K at the time of the shooting. And I have some issues that I don't

understand and maybe you can help me with. Okay? Okay. Number one, the register number one, the store floor -- well, the store floor is visible, the register, where the girls is working the register, -Yeah. -- on camera number one, -The entrance. Right. If we play that camera, it starts at

1:19:02 in the morning, as reflected on that camera right there, -Okay. -- and it goes until 1:41:23, 1:41 in the morning 23 seconds, and then it skips nine minutes and thirty-five seconds and goes to one minute -- excuse me -- 1:50 in the morning. Would you know where that nine minutes went on

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Page 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q that video? I sure don't, sir. You didn't take that nine minutes off of that video? Well, no, I'm not that talented. All right. My understanding is, is that if you

look at the camera that shows the back office where the surveillance equipment is, that it shows that the camera ran from 1:19 in the morning until -- well, let me back that up. The storeroom, the storeroom on there shows it ran from 1:19 in the morning until 1:52 in the morning, and there's no break in that video, from 1:19 to 1:52. With that said, if it runs

from 1:19 to 1:52, would it be correct that that cash register camera ought to also show the same amount of time? That's right. That's right.

And if there's a nine-minute gap in one, there ought to be a nine-minute gap in the other or vice versa? That's right. And the fact that the storeroom is a constant video feed throughout the entire time means that you can't explain that nine-minute gap on

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Page 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A Q A Q A Q A Q the cash register. No. That would be correct? That's right. All right. Now, in addition, there's a camera

on this that is the front door, and I believe it's the one right in the middle on the top. Okay. Now, I have looked at that with great effort, all right? My recollection of your testimony

is that although it was dark, you could make out a truck out there in the parking lot and see that there was something there? Correct. Okay. If the video that we got shows no data

on that camera and it's blank, that would be -But that's not what I saw. That's not what you saw? I didn't see anything. it was something there. Yes, sir. Yeah, it was something there. But if this video shows that that camera, whatever video feed was there, is no longer there, that would be inconsistent with what you It wasn't a blank spot;

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Page 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A A Q A Q saw? Correct. And you ain't had nothing to do with that? Nothing. Besides the police officer that was in there with you, do you know of anybody else that would have touched that machine that could have deleted that video footage? No one is going to go -- what you're trying to express to me is no one would do anything like that but the maintenance man, you know, but I don't think he would go back and try to distort that area. Okay. Well, who was the maintenance man?

Wayne Gauthier. Okay. It's my understanding that if we go on

that program there is a section that says "audit entry" that records when the machine is turned off or turned on. And according to what

we've been able to figure out, it appears that the machine was turned off or disconnected at 2:26 in the morning and sixteen seconds. we don't have -Excuse me, sir, the morning of the accident? Of the shooting, yes, sir. We have -- as I And

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Page 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q Q A A started out, what we do know is, is that if we look at the storeroom, it's the longest amount of video on there, and it runs from 1:19 in the morning until 1:52 in the morning. You should be able to see me then because the store was locked when I got there, and I got the key from the cashier and opened the door. You should have seen me. time. I don't know what

I don't know if it was --

Let's run it through. It had to be between at least 2:00 and 3:00 when I got there. Mr. Key, do you know which camera should have picked you up or should it have been all of them? No, just that front door. Well, as you travel

through the store, that's when the cameras picked you up. So, if you got there after Officer -- I forget his name -Brown. -- Brown called you, and you went to the store, then you should have been, basically, in every camera that was shown on that surveillance system?

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Page 22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A A Q Q A I don't think the cooler. I may not have been

-- I don't think the cooler shows on here, but if it does, I wouldn't have went in the cooler, but everywhere else, you're right. So, anywhere where those cameras are pointing, you should have showed up? I should have showed up. What would you say if I told you that I couldn't find you anywhere on all six of those cameras? Would you have any explanation for

that, that you know of? Well, you know, the number one reason why that would have happened is the system was down. Okay. there? Well, it had to be between 2:00 and 3:00 o'clock. Okay. Before you got there, before you went Well, what time did you arrive over

and looked at the camera with the police officer, are you aware of whether or not anybody was back there looking at that video or did you have to go show them where it was at? I think I had to show him. Okay. Mr. Key, as long as you were store

manager and an employee of Circle K, I would

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Page 23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A Q A Q assume that there were a couple of times when somebody was shoplifting or there was a fight or there was some incident in the parking lot that you had to go back and had to review tape. Right. That would be correct? Especially at that store. Okay. Would that have happened with that

equipment that you reviewed those incidents for shoplifting or fights, that kind of thing? Yes, sir. At any time in the course of your twenty-two years -About thirty. Thirty, your thirty years over there, have you ever seen a time when that equipment had a nine-minute gap in the cash register video and did not reflect a nine-minute gap in every other video? No. Are you aware of a time when you got a reproduction of the video and it came up and showed a blank screen like appears at the front door camera on this computer in front of you? Now, if the camera is working, it shouldn't

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Page 24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q Q A A Q Q show that. But we know on this night, because you saw with your eyes, that although it was dark you could see a vehicle there? Oh, it was something there. Okay. All right. Assume for a moment, because

I see you're not studying that computer real hard, but assume for a moment that middle camera on the top is completely void of any data whatsoever, would it be correct to say, sir, that there's never been a time in -Unless there was a malfunction with that camera. Yes, sir. Are you aware of any malfunction

with that camera that night? No. If we had a true and accurate copy of the video that you saw that night, would it be correct to say we ought to be able to see something? That's right. If we can't see something, -And you say you didn't see me come in, I know I was there. Yes, sir. When you walked through the store,

did you walk through the store with a police

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Page 25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q Q A Q A officer to go show them where that thing was at? What, the camera? Yes. When he came in, I think the guy said he would like to make a copy, you know, of the incident that took place. Yes. Do you know if that police officer, do

you know if he was Lafayette City Police? Oh, yeah, had to be, had to be. Okay. All right. Was they all wearing the

same kind of uniforms or? See, I'm not certain about that. thought about that. I often

I don't know if he was in

plain clothes or uniform, but I know it was someone there. All right. On that night, on that night, and I

keep focusing "on that night" because a man died that night. Yeah, I understand. Okay. And it's obviously important on that

particular night, are you aware of the incident you talked to us about, about watching the video and the police officer taking a copy of that video off of the machine?

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Page 26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A A Q Yes. Are you aware of any police officer coming at any time after that to get a copy off of that machine, whether it be the next day, a week later or whatever? No, I don't think so. Now, I'm not sure now

before I got there, I don't know, they might have went back there and took a copy before I got there. Okay. But my night person should know. All right. Sandra. All right. I have a maintenance log that we

got from Circle K for the time period before and after the shooting, and you probably are much more familiar with this stuff than me, but I could not find anywhere on there that reflected that there was a damaged surveillance system on July 26, 2008. And if I understood

your testimony correctly, there was -- all those cameras were working when you got there? Correct. Mr. Key, besides - and obviously, you're going to testify about what you saw, I'm not asking

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Page 27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q Q A Q A Q A you to speculate, that kind of thing, but besides you and the police officer that watched that tape with you and got a copy of it, are you aware of anybody else that did go and get a copy of that? No, I sure don't. Now, but I'm going to -- I

know where Sandra work and I'm going to go by and ask her, did anyone go back there and take a copy of that, you know, before I got there. Yes, sir. Because someone could have. But we know because -- we know that when you got there, you were able to see something? But you should have seen that. yeah. No doubt about that. Oh, yeah. Oh,

The video that you saw when you got there, I know you said you could see a truck or vehicle parked out there. It was something parked there. Yes. Did -- when you were watching it, were

you able to see the shooting that took place? No, because I definitely looked for that. Okay. But you saw something out of that front

door camera? Yes. It's on the outside of the building.

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Page 28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q Q A A Q Well, you know better than I do. it was labeled as "Front door." I know that And it's

labeled on that computer program under second camera, when all six of them are pulled up, the second one in the middle, it says "Front door." Now, if this camera is inside or outside, I really don't know. I mean what part of the

store was it placed in? Okay. Going into the store, it would be on the

right hand side at the roof. Okay. But it shined out into the parking lot? It's a dome camera. That's the best

Oh, yes.

thing, that dome camera. It's a wide angle? Yes. So, it will get everything out there? Uh huh (affirmative response.) And would it be correct that in a well-lit day, when everything is working right, it ought to catch both sides of the store and the whole parking lot and the street out front? Yes. All right. And forgive me, sir, but I think I

asked you the question but it's important, there wasn't any damaged cameras that night?

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Page 29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q BY MR. SPEER: Q A Q A Mr. Key, how long have you been retired? Ever since October; they ran me off. Why did they run you off? Well, the market manager they came in the first of the month and he said to me, he said, "You know, I'm fed up with you," just like that. And he caught me off guard because he and I, we never really had any frictions, you know. thought we were good friends, you know. If I A Q No. Excuse me. Let's go off the record. --OFF THE RECORD--

there was an issue, he could come to me and talk to me. If I had a problem, I would go to So, I mean, he just

him and talk with him.

caught me off guard and I went in my pocket and gave him the store keys and I left. After thirty years? Yeah. That fast. Just like that. Wow. You look at those maintenance logs,

they're in front of you, and you've already said that all those cameras were working that

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Page 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q Q A A A Q night -Yes. I couldn't find an incident where there was a broken camera. We did take the deposition

testimony of Ms. Broussard, and I'm sure I'll be corrected if I'm wrong, but is it a store policy that if a camera broke, that there was a technician on call twenty-four hours a day, seven days a week, and you would call that person to come fix a camera? Now, I don't know if that were feasible at that time, but now it is. Okay. But it don't matter --

Normally, we have a maintenance log, and I would review it in the morning, you know, and I would call it in. And there was nothing broken on that surveillance camera? No. None of them? No, none. All right. And I know I asked about a register

and I asked about some other things, but let me just point out that I've got one, two, three, four, five, six different gaps in video between

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Page 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q Q A Q A those six cameras at 1:41:22, 1:42:30, 1:46:24, 1:48:37, 1:49:09, 1:50:34, six different gaps in those cameras. If you --

And the dates on that? On that day, July 26, 2008. Oh, okay. on. So, something might have been going

Give me those times again.

Well, these are the times, and I'll give you the whole printout because it has the time that the camera starts and the time it stops. And

if you look at this one, it has it starts with the register, it runs from 1:49 to the last time it stops is 1:51, but there's a break between 1:41 and 1:50 of nine minutes and thirty-five seconds that does not appear a break on the storeroom. And the equipment is It says "audit

shutoff at 2:26 in the morning.

entry" where the machine is turned off at 2:26 in the morning, but we don't have any video whatsoever from 1:52 to 2:26. That's not good. What do you mean by "not good"? Now, I hate to

make you say what's obvious, but you go ahead and tell me because you know better than me. Yeah, well.

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Page 32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q A Q A Q A Q Q A Q Q A What does that say to you? Somebody's playing. Some of this might be a

game plan, you know, a game plan. Somebody tampered with it? Yeah, it sound like that. Did you turn that equipment off that morning at the instruction of the police? No. Did you delete any video under the instruction of the police? No. And you already said that they recorded their own copy; you did not record a copy for the police? Correct. Mr. Key, you've understood all my questions? I understand them. Before I stop, and I'm sure this other gentleman here is going to have some questions for you, do you recognize either that police officer or that police officer? (Witness reviews photographs.) familiar. Okay. This guy looks

I don't recall him though.

Well, --

This guy looks familiar.

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Page 33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q Q -- either one of them is the ones you watched the videotape with, if you remember? want to -No, I truly don't. Then don't worry about it. You know that you I don't

were placed under oath and you've been sworn to tell the truth, the whole truth and nothing but the truth? That's all I know. All your answers have been correct? Yes, sir. I hate to ask you this because I already know the answer, but I'm obligated to, okay? I

don't want to offend you, but I've got to ask you a couple of background questions just to make sure. Okay. Have you ever been convicted of a crime? Served time in the penitentiary? No, I never served time in the penitentiary. All right. As a kid, I was in a reformatory school. You got in trouble as a kid? Yeah. Okay. I did too. That happens. How old were Okay?

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Page 34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A Q A you? I think I was about 16 or 17. of years. All right. You answered the truth to all my It's been a lot

questions to the best of your ability, correct? Yes, sir. Do you have anything you would like to add? Not a thing. truly do. Well, I think you have. have done just fine. Okay? I think you I wish I could help you more. I

By any chance, did you

know the boy that got killed out there, Shane Damond? No, sir. They tell me that I've seen him

before, but of course there's a lot of people that I don't know by name but -- like this gentleman here, I don't know his name but next time I see him, I'll know it's him. Yes, sir. there? Anybody tell you what happened out

You don't remember or did you pay much I mean, number one, you didn't

attention or?

see the shooting, correct? No. No.

You got there well afterwards, and have we discussed everything that you did while you was

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Page 35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q Q A Q A Q A Q Q A A out there? Yes. all. Okay. Yeah. I came on around, Officer Brown escorted Well, I didn't go out to the vehicle at

me right to the store door. Okay. I unlocked it and went in the store. Okay. What time did you leave over there and

go home? Let's see. I left but I came back. I just

went home and took a shower, you know, because I didn't take a bath before I left work. I would imagine -I mean before I left home. Did that scene stay the same throughout the whole time? How long --

Say that again. How long were the police there, where they kept the vehicles there, and the tape around the store and all -You know when I got there, everything was cleaned up except the vehicle sitting there by the pumps. This was after you went back the second time?

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Page 36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Oh, when I went back the second time, nothing was there. Okay. Okay. When you went the first time, I

think I asked you about this, about what time of the morning you went and you said it was 2:00 or 3:00 o'clock in the morning? It had to be. It had to be. It had to be

because my night person gets there between 11:00 and 11:30. Okay. And I hadn't been asleep long. Okay. How long was it before you could re-open

the store, if you remember? It was somewhere like 7:00, something like that. Would there have been any reason, as a store manager, for you to disconnect the surveillance equipment at any point throughout any of that? No. You don't do things like that.

You don't do stuff like that? No. No. What if you got robbed or something

like that? Yes, sir. Thirty years with the store, you

would never do something like that? No. No.

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Page 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q Q Q A Okay. I didn't have a perfect background, but I think I had a good enough background to stay with them for thirty years. My momma used to say they only made one perfect man and nailed him to the cross. Yes. They didn't like him being perfect. Well, I greatly appreciate you I'm sure this

That's right.

answering my questions.

gentleman is going to have a number of questions for you. Okay. If I can make you comfortable in some way, it's my building, I'll be more than happy to do it. If you need to take a break at some point, you just let us know and you can take a break. Okay? Okay. I'm going to let this man ask you some questions; I'm going to go to the bathroom. -- MR. SPEER EXITS THE ROOM -EXAMINATION BY MR. BOUDREAUX: Q Do you want to take a break now or you want to keep going? Yeah. We can continue because I've got to go Okay?

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Page 38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Q A Q A Q A Q A Q to Baton Rouge in the morning. Okay. Mr. Key, my name is Jason Boudreaux. I represent the We

met when you first got here.

Lafayette City Parish Consolidated Government, Chief Craft, and Officer Milazzo, who was the officer who shot Mr. Damond in this case. is your date of birth? 06/10/1944. And your Social Security number? XXX-XX-5758. 5758? Correct. Are you taking any medications today? No, no medication today, but I do take medicine at night. Okay. In the last twenty-four hours, what kind What

of medications have you taken? I take a blood thinner. Okay. I take two baby aspirins. Is that it? No, I take another, cholesterol. Okay. Is that it?

That's it. Okay. Have you had any alcohol today?

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Page 39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q Q A I don't drink, period, don't drink, don't smoke. Okay. I did when I was young, though. Did you meet with anyone in advance of

today to prepare for the deposition? No. Did you discuss your deposition with any members of the family of Shane Damond? No. Okay. I don't know that family. Did you review any documents to prepare

for the deposition today? No. Have you ever given any statements regarding this case to anybody, anybody with the police department? No. Nobody has ever sat down and recorded your statement? No. Okay. When you first started talking about

cameras, you said "the island." Yes. And when I asked you what "the island" was earlier you said that is the gas pumps. Yes. Is there a camera out on the island where the

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Page 40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A Q Q A gas pumps are? No. That camera we spoke about when you're

entering the store, it's gonna be on the right hand side, that dome camera, I think that's the only thing we had at that time. Is it on the interior of the store or on the exterior? It's on the exterior. Okay. Yes. Is there also a camera when you walk in the front doors that picks up who's coming in the front door? Yes. All right. Let's see. one. Okay. Register one is the camera that faces down behind the cash register, right? (Witness reviews video on computer.) Okay. I I'm gonna try not to screw this up. Six cameras listed here: register It's outside the store?

It's been a while since I looked at it.

don't know if they changed them around or not. Okay. Well, this is from back when the

incident happened.

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Page 41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q Q A Q A A Q A Q A Q A Q A Q Okay. Okay.

So, this is footage from when the incident happened. Okay. There's one that says "storeroom," that would be back in the storeroom, right? Yes. Yes.

There's one that says "back office." There's one in the office. And that's where the actual system is where you can see the footage and it's downloaded, right? Correct. Okay. Then there's one that says "fast food,"

what is that? Fast food, that's where you sell hot dogs and sandwiches. So there's a camera back there? I think it is. Okay. store? Right, correct. Front door. Front door is the one that's Sales floor, that's just out in the

showing the black screen here; is that the one that's facing the front doors inside the store? Yes.

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Page 42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Q Q Why is the dome camera you told me about not showing up on here? it? I don't see it. Did you have a dome camera at the time this occurred? Oh, yeah. We couldn't have seen the island if It's not even on here, is

it wasn't there. It's not showing up on here. idea why? Do you have any It's not even

It's not even listed.

listed as a camera. Well, that's the storeroom there. make sense. outside. That don't

You should be able to see on the

That front door camera --

You know, I've been in convenience stores before. You walk in and you can look up,

there's a camera there and a lot of times there's a monitor where you can look at yourself on the monitor. Yes, but we wasn't set up that way, but we should have been able to see outside because I seen it. You say we should have been able to see outside. Yes.

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Page 43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A Q A Q Q Are you sure that you had an operating camera outside at the time that this occurred? Oh, yeah. Oh, yeah. No doubt about that.

Are you sure? Oh, yeah. And you're sure it was working? Yes. So, why does it not show up on here? That's a good question. If there was such a camera operating, why is it not showing up on here? you know. I mean, I'm confused,

Front door camera to me means that And you're

the camera facing the front door.

telling me that there was a camera facing the front door? Yes. Did you ever watch the footage from that camera to see if it showed anything? That's the only camera we could have seen. That's the only camera that was going to show the outside. Well, I'm talking about the one facing the front door, that camera, could you have seen what was going on outside through that camera at 1:30 in the morning?

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Page 44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A A Q A Q A Q A Q No. You wouldn't have been able to -No, everything was pitch dark out there. Even with the lights on outside? Yeah. Now, you said you saw the footage from this camera that you say was outside hanging above the door? Yes. But you said you couldn't hardly see anything correct? Right. You said you saw a truck parked? It was a vehicle. truck or a car. One vehicle? Just one. You saw one vehicle parked in that parking lot in the camera? Right. Other than that, the parking lot was empty? When I got there, when I got there, it was a couple of police officers out there. think they was by that car. But I'm talking about the footage. When you I don't I don't know if it was a

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Page 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q Q A Q A Q A Q A A Q A were watching the footage on the video, you said you watched on the video and you could vaguely see something. Right. What did you vaguely see? Like it was a vehicle, but I couldn't see nobody moving around out there. You couldn't see anything? No. It didn't look like anything to you was moving? Correct. And you -Because I replayed it, I replayed it, and replayed it, trying to see. I said, wait a It wasn't.

minute now, I don't see anything happening out there. And you're sure -And I talked with Paula Manuel, which is my market manager at the time, and like I told her, it was so dark that I couldn't see anything. So whatever was on the video didn't show you anything? Right. You didn't see the shooting?

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Page 46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A Q A Q Q A Q A A Q No. And this was the video on the exterior of the store? Correct. And it didn't show anybody moving around? I couldn't see anything moving around out there. And that footage was supposedly the footage taken at the time that shooting occurred? Yes. And was the time running? Like what we watched

earlier, were you watching it, was the time running? Yes. The time was running, and it was showing nothing on the screen? Correct. replayed. Okay. The front door camera on the night of It was replayed and replayed and

this incident, the one that's the front door camera that's inside the store I'm talking about, was that one working? All cameras were working that night. You're sure? Oh, yeah, all of them.

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Page 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q A Q A Q Q Okay. We took Mary Guillory's deposition

several weeks ago. Yeah. She works as my assistant.

She testified that you didn't get there until 4:00 or 4:30 in the morning. maybe that's correct? Do you think

You think maybe you're

mistaken about what time you got there? Well, it could have been. It could have been. You may not

The incident happened at 1:30.

have gotten there until 4:00 or 4:30 in the morning? I could have. She was pretty adamant that you -- they couldn't track you down. She went out there And she was

and then you got there later.

pretty adamant that it was, you know, 4:00 or 5:00. Yeah. Well, she said that Sandra called her

and she went back to the store, because she had got off work at, I think, at 11:00 o'clock. And she went because you weren't there. She

was like the next in command, so she went out there. She was the assistant manager, yes. Okay. All right. Do you know Officer Brown's

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Page 48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q Q Q A A A Q first name? No, I don't. Okay. Is he an older officer? Is he a younger

officer? I think Officer Brown probably at that time was in 40s. Okay. Yes. He's a black officer? I didn't know he was still working for

the force because somebody said, one of my friends told me that he had cancer. Mr. Speer asked you earlier, anytime in your thirty years whether there had ever been a nine-minute gap on this video before? No, I don't recall that. But over thirty years, have you ever gone to look to see if there was a nine-minute gap in the video? An hour gap, you know, but not nine minutes. Okay. That's because of the time change. Okay. But have you ever gone and just reviewed You don't

the video to see if there were gaps?

review every minute of every video that's produced, do you? No.

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Page 49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Q A Q A Q Q So, there may have been nine-minute gaps before and you just don't know about it? Correct. That's fair to say that, right? Yeah, I think so. Now, we talked earlier about when you let the officer come and download the video from the system, are you sure it was the same morning of the shooting that you let the officer download the video of the system? Because we have

documentation that shows that the video wasn't downloaded until like two weeks later. think an officer may have -Two weeks? Two weeks later -- came and met with you and downloaded the video? Two weeks later, that don't make sense. Do you think it's possible and you just don't remember? It could be. All right. A man got - a person got killed and wait two weeks later to come make -- do a video, no. But the video, you, yourself, have said the video didn't show anything. You couldn't see I mean, it's not making sense. You

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Page 50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A A Q A Q A Q anything on the video, right? I just saw like a blur spot. And you couldn't see anything? No. At the time you saw the blur spot, was the police officer with you watching it? Yeah. To your knowledge, before you got there, did anybody watch the video or go back there or -Like I said, I turned on -- she said I got there about 4:30. before then. Okay. But to your knowledge, did anybody else I thought it was maybe

go back there and look at the video? Not to my knowledge. Unless, you know,

somebody might have went back there before I got there that morning, you know. Anybody else that works there knows how to operate that equipment? Well, yeah. They had other people that know

how to operate it. Did Sandra know how to operate it? I would say so because she worked as a manager before, you know, not for Circle K but for other companies.

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Page 51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A Q A Q Q A Q What if she said she didn't know how to work it? Well, maybe she doesn't, you know, because I don't have any proof or any evidence that she does. How about Mary Guillory, do you think she knew how to work it? She probably doesn't. Yeah. Because I'm going to tell you, she said

she didn't know how to work it. Yeah, she probably don't. Okay. So as far as you know, before anybody

could even watch any video that morning, you had to go out there and fire it up and rewind it or get to a particular part, correct? Well, they got the police officer, they pretty much know how to operate those. Did you get any indication from anybody out there that the police officers had already looked at that video? No. They asked -Now, Sandra, if they did that, Sandra would know because she was out there that night. Okay. We've taken her deposition.

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Page 52 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Q A Q A Q A Q Okay. There's no indication that -- but did you get any indication that the police had seen the video before you got there? No. So, as far as you know, the police saw the video for the first time when you went and cued it up? Correct. And, again, just so the record is clear, that video did not show the shooting, correct? No. You couldn't see anything? No. And, in fact, all you could see was one vehicle, vaguely? That's right. I didn't see any movement, no

people out there, no one was moving around. The dome camera we talked about, that you said is outside the front door, are there any other cameras outside? I think that's the only one that's out there at that time. Yeah. It had to be. I think it

was just that camera. Okay. Since then, did they add cameras out

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Page 53 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Q Q A Q A A there? I don't know. I don't know. I know they

changed the system and they -- see, I was transferred to another store. When was that? That's a good question. Ballpark, I mean, it's not a test. Let's see. I think I went to St. Landry and

University, St. Landry and right across from Channel 10, and I was there about, I guess, about three years. So, just so we get something straight, you said you worked as a manager for thirty years for Circle K? Yes. How many years at the Mudd location? I was there three times. The incident was July 26, 2008. Before that

date, how long had you worked at that location as the manager? all? Or worked at that location at

And I'm talking about continuous time.

Continuous time? Continuous time. I probably was there about three or four years. Before?

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Page 54 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A A Q A Q Yes. Before the incident? Uh-huh (affirmative response.) Okay. And after the incident, how long were We're talking about July 26, 2008

you there? again.

About two years.

And I'm guessing on that.

think it was about two years. Now, you said earlier it seemed like somebody had a game plan, and Mr. Speer suggested you meant somebody had tampered with the video. What leads you to believe that somebody might have tampered with the video? Well, with the time, throwing the time off like that, you know, somebody had to be doing something back there to throw that time off like that. But could it -Now, I don't think that -- now, the maintenance man but I don't think he would -- he would probably call somebody, he would come out and take a look at it, and he would probably call the technician out to come, you know, but there's no evidence to that, so. Okay. But that's the only thing you base it

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Page 55 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A A Q A Q A Q A Q on -- if the time is off, you think somebody had to do something to it? Yes. Okay. Yes. But like we said earlier, --

Unless they had electrical problems. And like we said earlier, but you didn't watch the video all the time, you don't know. go pull video now and there may be some nine-minute gaps? That's right. You have no way of knowing that, right? No. Okay. Now, if you got there at 4:00 to 4:30 as We may

Mary Guillory said, and I think you've admitted that she could be correct, -I'm sure she could be. -- you said you left and you came back? Yes. What time did you come back? Probably about between 7:00 and 8:00. went and showered up. When you went there the first time, did they have crime scene tape up and everything? Yes. Was the vehicle Mr. Damond was driving still Yeah, I

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Page 56 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A A Q A Q A Q Q Q A A there? That might have been the vehicle that I couldn't see that good on the camera, but I think that was it. Was it at an angle in the parking lot? Okay, this is Louisiana Avenue here and this is Mudd. The vehicle was pulled in like this

(indicating) with the front of the car pointed toward Louisiana Avenue. Okay. It was away from the gas pumps with the

back end pointed towards that nursery? Yes. The daycare center? Yes, daycare center. Okay. And you said the video you watched, that

that may have been the vehicle in the video? I think that was it. Was it in that position? When you watched the

video, was the car where you described it? Yeah. Okay. It was in that position. And could you --

And now, you know what, I'm thinking back, it might have been a truck. Okay. No. You don't have any idea?

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Page 57 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q Q A Q Q A Q A You couldn't tell what you were seeing? Well, thinking about it, it might have been a truck. I seen it when I entered the store now.

I seen it sitting there. Right. Yeah, but I'm thinking back now, it might have been a truck. That you saw in the video? Yes. Okay. But you really don't know what you saw

in the video? You're right. How did you actually find out that a shooting occurred out there? From my cashier. I even questioned Mr. Brown, He said,

I said, "What could have happened?" "I can't talk with you right now."

So, before you got out there, you didn't know what had happened? Well, when I got out there, the phone call I received, I'm thinking it was Mr. Brown, and you know I believe it was him because he the only one that knew my phone number, and he said that there had been an incident at the store and they needed me to come out and secure the

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Page 58 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q Q A store. And when I got out there, he met me

halfway on the block, on the opposite side of the store, and he said that the police department closed the store and that made them responsible for the merchandise and cash. Okay. And he did come back and ask me, I guess I had been in the store about forty-five minutes, he asked me was the cash okay. everything's okay?" He said, "Is He said, I

I said, "Yes."

"What about your cash, your cash all right?" said, "Yes." So he met -- you said he met you down the block, like behind the store? The store is here, the golf course is over

here, he met me about half or halfway the block on the side of the golf course. Down Mudd or down Louisiana? Mudd. Down Mudd? Uh-huh (affirmative response.) Down Mudd towards Moss Street? Correct. Okay. And you think Officer Brown is the one

who called you to come out?

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Page 59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q Q A Q A A Q A Q Q A It might not have been him, but I'm thinking it was him. Okay. If it wasn't him, it was a police

officer? Oh, yes. Yes.

It was definitely a police officer? Yes. Okay. The recordings of the video footage,

where is that kept at the Circle K? In a cabinet. In a cabinet? Yeah. If we have an issue, we put it in a file

-- we had a file cabinet and we would put everything in the file cabinet. That would be if you go and download a specific time period, you put it on a disc and you put in the file cabinet? Yes. Otherwise, is it always recording? Yes. It's always recording.

And it's recording this recording to a computer server or what? That's a good question. You don't know? No.

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Page 60 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A A Q Q A Q A Q You just know it's going somewhere? Yes. Okay. And if you want a particular period of

time, you would -Have to go back in there, put the tape in, and ask the system to give you from 6:00 a.m. to 8:00 a.m. Okay. Let's use those time periods. You go in

there and you want to download from 6:00 a.m. to 8:00 a.m. Okay. When you do that, it takes everything off of all six cameras and records it? No, just the spot that you -- just the camera you asking for. Okay. You have to ask for each camera

individually? Yeah. That's right. You got to bring that

camera up in the system. Well, here we have a recording of six cameras. Can you do all six at one time or do you have to do them individually? Individually. Okay. So, you would have to do - you would

pick time 6:00 a.m. to 8:00 a.m. camera, front

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Page 61 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A A Q Q A Q A Q A door camera, and then you would do that one and then if you want to do 6:00 a.m. for every other camera in the store, -I'm thinking, you know, maybe you can do two. Can you maybe do all of them at the same time? I never tried that myself. So, maybe so? Well, maybe, you know. myself. Okay. Were you with the officer when he I never tried it

downloaded what was being recorded? Yes. Yes.

Did he do camera by camera or did he do all at one time? Just the incident, one camera, one camera. He just downloaded one camera? The camera that showed the island where the incident was supposed to take place. And if

I'm not mistaken, either Ms. Mary or the other young lady, we might have reviewed it together. With the officer there? No. No. I think he was gone then.

After he left? Yes. Because the market manager she had called

me and, you know, she wanted me to take a look

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Page 62 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q Q A Q A Q Q A A Q Q A at it. And I got back with her and I told her

I couldn't see anything out there. That was the same day the officer took it? Same day but different time, different time of the day. So you think it might have been two weeks after the shooting happened? Oh, no. I mean, she called on like the same

day it happened. It was the same day? Yes. She probably wanted to know, she wanted

information on it now, not two weeks later. So, Paula Manuel went to -- her name is Paula Manuel, right? Yes. No, she called me.

And she went to the store? No, she didn't come to the store; she called me. Okay. But you told me that she went and

reviewed the video or did she just tell you to review the video? She just said for me to review it. And that was the first time you reviewed it, is when Paula called? No. I reviewed it before she called.

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Page 63 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q A Q Q Q A Q A Q A You had seen it already? Yes. And she told you to review it again? No, she didn't ask me to review it a second time. She just asked you what you saw? Yes. And I explained to her that it was, you

know, it was dark out there, you know, I couldn't see anything, couldn't see nobody moving around out there. Okay. And the officer that you say downloaded

the video, he only downloaded that one camera? I think that was it, just that one camera. Do you have any idea why that camera is not showing up on here? The only thing I can say is that it was down. That it wasn't working? Right, it wasn't working. Normally, at the store, if you went and looked at the monitor, then the cameras, the surveillance cameras were showing, would you normally be able to see that? Yes. That camera? Yes.

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Page 64 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q Q A Q A Q And would there be a place on here where you could check off to just look at that one camera, like we did earlier, where you scroll and you have "Front door, storeroom?" Yeah. What would that one have been called? Well, you just bring it up on the screen, you know, and this will monitor everything that took place on that particular camera. -- MR. SPEER ENTERS ROOM -That's not what I'm asking you. I'm asking

you -- you can't really see from here but here there's some words for what the different cameras are. Yes. What would be the word that would be there for that front camera you're talking about? Probably front door. So, okay. What about the one aimed and facing

the front door, what's that one called? The one on the outside? I'm talking about the one on the inside; what's that one called? MR. SPEER: The one that's pointing out.

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Page 65 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A Q A Q BY MR. BOUDREAUX: A Well, the front door would be the one sitting, when you open that door there's going to be one sitting there. But you told me there's a camera on the inside facing the front door, right? Yes. Okay. What would that camera be called?

That camera picks up the front door plus a big portion of that island. What would that camera be called on here? would think it would be called front door. It's the front door. Yeah. It's the same. I

It's listed like they are here. Okay. But you're telling me there's a camera

missing, the one outside? Yeah. I don't have an understanding about that

camera not showing up on there. Okay. Mary Guillory talked about changing

tapes each shift with regard to the surveillance system. about? Changing tapes each shift? She said each shift when she would come on, she had to change the tapes dealing with the What was she talking

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Page 66 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A A Q Q A surveillance system. Changing tapes each shift, not making sense. What tape would we change? that. Were there ever any tapes involved with utilizing the surveillance system? No. Would she be calling tapes CDs? Would it be I don't understand

CDs or DVDs that you rotate those out, where you recorded, you know -- how many shifts were there a day? shifts? We don't rotate them or anything like that. All right. So, you didn't -Three shifts, three eight-hour

That information set there for about, I think it was thirty or sixty days. Okay. So, you don't know what tapes she's

talking about? No, I sure don't. During the course of a day at the store, during the course of a twenty-four hour period, does anybody monitor what's going on, on the cameras? If you have a cash shortage, theft. But that would be a particular situation where

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Page 67 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A A Q you would go and pull video from that time period and try to look at it? Right. Right.

But I'm talking about just during the course of the day, somebody watching to see if cameras are working or looking to see what's going on in the store, is there anybody doing that? Well, the maintenance man, he'll pass by to make sure everything is functioning correctly. But other than him, -No. -- nobody is really paying attention? No. Is it the responsibility of anybody who's working in the store during the day to go and check and make sure that the feeds are actually working and recording? Well, I normally make sure that the cameras are on and functioning. And that's -Because we can see them, see all. They look

like here, the camera here, and we can see them, you know, in the back of the store, we can see whether or not they were functioning or not.

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Page 68 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A Q Q A A A Q Q Okay. Did you ever have any occasion where any

of the cameras weren't working? Oh yeah, we've had that a few times. Have you ever had a time when the screen looked like this, where there was one camera was black? And then that means you've got a malfunction with that particular camera. That's what that means? Yes, sir. You got to get the maintenance

person out, the technician out. Okay. If a camera is out, it's not working, is

it possible that it just shuts down completely and it's not -- it doesn't have a rolling time period or anything? Well, -If you know. Well, the camera, I think the camera picks up the information, send it to the office. Okay. And if the camera is out, you don't have no information. Okay. The interior camera facing the front

door, on the day of this shooting was that camera working?

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Page 69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Q A Q Yes. Can you explain why we don't have any video footage here on that camera? No, I sure can't. But what we show here would be indicative of a camera that's not working, correct? Correct. Correct.

You remember ever watching the footage from that camera on the inside facing the front doors from the time of the incident? I think that's where we were picking up that vehicle sitting in the parking lot, I think that's where we were picking that up. Because

we went back and kept going back and forth, back and forth, just continue like that walking around. We were looking for, you know, a

gunshot out there. You said you were going back and forth. You

were going back and forth between two cameras? No. From like 6:00 a.m., then we would go back

from 6:00 a.m. and start over again, go back again, start over again from that point. Correct me if I'm wrong, and maybe I misunderstood you or maybe I'm misunderstanding you now, when you were talking about earlier

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Page 70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A you would watch them on the camera and you couldn't see anything, my understanding was you were talking about the camera outside. Yes. Okay. And just now we were talking about --

I mean the view outside. From the camera that's outside. Yes, sir, that's why I'm thinking we were picking it up from there but evidently we were picking it up from that door camera. Okay, all right. Do you remember looking at

the video from the camera outside? No. You didn't look at that one? I'm not -- like I said, I'm confused now on where that camera was, which area it was showing this information from. But I do know

we looked at that spot outside where that vehicle was at and we couldn't find anything, no moving people. But I'm asking you, did you look through both those cameras or did you just look through the camera outside or did you just look through the camera inside? I'm going to have to say the one at the door.

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Page 71 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A A Q A Yes. Q A Q A On the inside? Yes. Facing the front door? Correct. MR. SPEER: That's a dome camera. We had switched over to those, our I think

maintenance person had switched them.

we had one camera, one of the old cameras, which was not a good camera. BY MR. BOUDREAUX: Q Okay. camera? Yes. And the one on the outside. The camera on the inside was a dome

So, you had a dome camera facing the door on the inside and you had a dome camera outside? On the outside. Okay. And I think the one in the office was a dome camera. Now, the dome camera that you watched and you said that you could vaguely see something on, which camera was that? I'm pretty much sure that was that dome camera. From the inside?

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Page 72 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A A Q A Q A A Q Yes. Okay. Did you check to see if the outside

camera showed anything? No, I didn't. Like I said, I don't know which

number it comes in on, looking at this here. Were there times before this shooting occurred where either one of those two cameras went out? Say that again. I'm sorry, did I interrupt you? Yeah. MR. SPEER: Yeah, he was counting, trying to count how many cameras. BY MR. BOUDREAUX: Q Oh, go ahead. Please do. Tell me how many

cameras there were. One on the outside, one by the, two of them, one in the storeroom, one in the office, one in the snack area. I'm confused now. Yeah, well -That's two of us, huh? Yeah. Well, it's a new system -You know the new system I think they changed They had six. Six cameras.

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Page 73 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Q A Q A Q A Q the new -- I think they put a new system in there about a year after, a year, a year and a half after that incident, if I'm not mistaken. When they put the new system in, did they add any cameras? The only thing I can say, they went to all dome cameras because they found out that that's the best camera. And I don't think we had one on

the walkway, and I think that's when they put the one on the outside. Was when you went to the new system? Yes. After this incident occurred? That's what I'm thinking. Okay. Okay. So we talking about one camera

facing the front doors, -Yes. -- on the interior? Yes. Okay. Sit down and talk about, it comes together. Okay. So, at the time this incident happened,

there was no camera outside? Yes. Okay. All right.

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Page 74 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A A A A Q A Q A Makes sense. wait so long? So, when we talked about earlier what you could see on the camera, every time we talked about that, you were talking about the camera that was facing the front door -Yes. -- from the inside of the store, correct? Yeah, correct. MR. SPEER: Even when we were talking about the island? And it doesn't show across Mudd Street, but I think it catches about halfway up Mudd Street. MR. SPEER: It shows a parking lot. It shows the parking lot and some of Mudd Street. MR. SPEER: Okay. You can't see the golf course though. It's been a long time, why y'all

BY MR. BOUDREAUX: Q How about at night, you can see that far at night from that camera? Oh, no. It's not good. We need better

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Page 75 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Yeah. Q A Q A Q lighting out there at night so we can see better. But they didn't at that time? Correct. All right. going on? Well, I didn't see any movement of people moving around out there. All right. MR. SPEER: Could you see the gas pumps from that camera? Yeah, sure can. So you couldn't really see what was

BY MR. BOUDREAUX: Q A Could you see the gas pumps that night? Vaguely. night. It must have been kind of foggy that They need better lighting out there,

definitely need better lighting. And we know in this case Shane Damond was shot in the parking lot, right? here to talk about today. Yes. Has anyone else ever been shot in that parking lot and died? MR. SPEER: That's what we're

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Page 76 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A If you know. BY MR. BOUDREAUX: Q Before the incident. MR. SPEER: We don't want you to guess. whatever you know. I can't say yes. I used to manage the one down Just If you know.

the street there and there was a guy that got shot there, and he died at the hospital. BY MR. BOUDREAUX: Q But I'm talking about specifically of this Circle K? No. No.

Has anybody else ever been killed in the parking lot at the Circle K? Not that I recall. And we established earlier you were the manager of the Circle K for the three or four years before this incident, right? Yes. How often were you working during that time period? Every day? Just about every day. I'm surprised I wasn't

there when that incident took place, because I'm in there twenty, seventeen, eighteen hours,

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Page 77 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A A Q A Q A Yeah. Q whatever I had to do, I did it. Every day, wow. MR. SPEER: That's a lot of work. It was a lot. I had a family to take

care of. BY MR. BOUDREAUX: Q And in the couple of weeks before this happened, you didn't go on vacation or you weren't on sick leave or anything like that? No. You were working during that time period? Yes. I think Mr. Speer earlier showed you maintenance logs, I don't know if they were attached to the -- I'm going to give you one, I've highlighted something on mine. entry here. There's an

The date of the entry is 7/21/08.

I want you to read for me what that entry says. (Witness reviews log.) "Camera front door." I

don't know what this here, "I-N-O-P." I-N-O-P -- do you think that means inoperable? It could be. Okay. It could be.

Can you read the rest?

"The store scared for safety, person was killed

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Page 78 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A BY MR. BOUDREAUX: A This is the store number here? MR. SPEER: I don't know. I don't know. What The store A Q outside the store the night before." Now, was somebody killed outside the store on July 20th? This might not be the right report. MR. SPEER: Off the record. MR. BOUDREAUX: We can go off the record for a minute. --OFF THE RECORD--

store number was that Circle K?

number where you was a manager at the time of that shooting? Oh, that's a good question. find out that. I would have to

I have some documents at home. I

I have to find out which store number it is. think they might have gave you some bad information on that. BY MR. BOUDREAUX: Q Let me ask you this: On this chart they have a site number, 2701715.

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Page 79 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Okay. That's the site number.

Every entry has the same site number. 1715. Which is the same site number again. entry has 2701715. to look through it. the same site number. Okay. Okay. 1715, that's our store number. Okay. Let me see that. For the record, I'm Yeah. You right. Every

And I'll give you a chance Every entry in there has

going to read the entry. MR. SPEER: Attach it. MR. BOUDREAUX: I'm gonna. BY MR. BOUDREAUX: Q "Camera at front door, INOP.," and then there's a period after that, "store scared for safety. Person was killed outside the store the night before." MR. SPEER: What was the date? BY MR. BOUDREAUX: Q The date on the entry is July 21, 2008. And

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Page 80 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yeah. A Yes. MR. SPEER: Regardless of the date? I don't know about this one. A Yes. MR. SPEER: -- that was killed? Q A A Q A Q A what I'm asking you is was anybody killed outside in the parking lot at the Circle K the day before July 21, 2008? And you telling me that this gentleman that was killed, what was the date on that? The date he got killed was July 26, 2008. No, that's wrong. The only person you know that was killed out in the parking lot was killed on July 26, 2008? The person that we talking about -- I don't know exactly the date, but the person that we're talking about. Okay. Yes. MR. SPEER: Just to be clear, you only know about one person -The person we're talking about today?

BY MR. BOUDREAUX:

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Page 81 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q Q A Q Regardless of the date? Correct. Okay. Who inputs the information in these

maintenance logs? Corporate. Corporate does? information from? From the store. Somebody has to call -Somebody had to call this in. Okay. Do you think that it's possible that the Where do they get the

date's just wrong on there and that it should be a different date? MR. SPEER: I object to that because he's not produced that. MR. BOUDREAUX: A Q I don't think nobody got killed that day. Just like Mr. Speer asked you, the only person you're aware of that got killed is the person that was -The person --- involved in this case? Correct. And the store number that's listed on --

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Page 82 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A in? They call it in. Q A A A Q That's the correct store number, 1715. And the information that is put into that form is given by somebody at your store? It had to be for them -- unless the maintenance man called this in. happened. And that's Mr. Gautreaux? Gautreaux, Wayne Gautreaux. have called it in. MR. SPEER: Do they call it in or do they type it Yeah, he could Now, that could have

BY MR. BOUDREAUX: Q But they had to get that information from somewhere? Yes. Now, these logs are maintained at corporate, you say? Well, from store level they go to maintenance and I think that was is Shreveport. Shreveport had this area at the time. And the store you worked at on Mudd, did they keep these records there? Yes. Yes. I think

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Page 83 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A Q A Q A Q Were they kept in a computer? No, in the file cabinet. Okay. Is it just a printout of what we have

here or is it a separate record? It's a separate record that the maintenance that's been taking place and that's there. Who maintains those records? I did. Okay. So, at your store where you worked at on

Mudd, there should be a record that has this same information on it? Correct. It should -I don't know if you're going to find that though, because I don't recall that. Okay. You think there would -- you think you

just don't remember it and it did happen? I MR. SPEER: He just said that he that don't. I would remember if somebody got killed on that -- other than this other person, I would have known about it. BY MR. BOUDREAUX: Q Okay.

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Page 84 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q Q A Q A Q A A Q A Even though it's been a few years back, you know, no one got killed. Information that's provided to put into this form, does it have to run through you or could it have come from Mary Guillory or the maintenance person or it could have come from anybody there, correct? At this particular time, it would have had to go through me. Okay. See now, they're on a 24 hour period, call-in period. If something happen at 1:00 o'clock in

the morning, they can call it in. During this time period? During this time period here, I would have to be the one to call it in, because they don't open until 6:00 o'clock in the morning. But you're saying you didn't call in that? Oh, no, I didn't call this in, somebody getting killed, uh-uh. Do you have any idea how it got into the records? No. If we wanted to get the records that you used to keep at the Circle K, are they called a

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Page 85 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q certain thing? Maintenance logs. Maintenance logs? Uh-huh (affirmative response.) When Mr. Speer subpoenaed the maintenance logs, should those have been produced, you think? MR. SPEER: Where did that subpoena go? MR. RAINEY: Corporate. MR. SPEER: It didn't go to the store? MR. RAINEY: No. MR. SPEER: Why don't you ask him to clarify it. We sent the subpoena to the corporate office; if we would have sent it to the store, Mr. Key, would it have got the records you prepared, if there would have been any? This probably going to be the records you yeah. If you sent it to the store, yeah, That's the

that's the records you needed.

records you would have been requesting.

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Page 86 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A A Yes. MR. SPEER: And then corporate keeps another record? Right. MR. SPEER: Okay. The respond that they receive from the store. MR. SPEER: Got you. BY MR. BOUDREAUX: Q You said those records were kept in a filing cabinet. Was that something that you handwrote MR. SPEER: So, the original records of whatever needs to be done at the store is kept at the store?

and put in a filing cabinet? Yes. So, it was just a printed log where you wrote in what you needed to put -Correct. -- and you put it in? Correct. And the file was called maintenance logs or

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Page 87 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A Q A Q maintenance records? Yes, maintenance logs. Did you have maintenance records specific to equipment? Like, would you have specific

maintenance records specific to just cameras or would it be just maintenance records specific to anything in the -Period, yeah. Okay. So, anything generally in the store?

Whether it was a camera or a ice machine or whatever, it would be in the maintenance -Yes. -- records in one place? Yes. Okay. I don't understand "store scared for safety, person was killed outside the store at night before." I don't understand that.

MR. SPEER: Mr. Key, I just want you to testify, and that's all anybody wants, testify just about what you know. BY MR. BOUDREAUX: Q I just want to know what you know, yeah. MR. SPEER:

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Page 88 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. MR. SPEER: The black -A A A Yes. MR. SPEER: And don't let nobody try to talk you into saying anything that's not -Oh, no. And if there's something that you can't explain, it's perfect that you say, "I don't know it. I can't explain it,"

because we just want what you know and nothing more. Okay?

BY MR. BOUDREAUX: Q A I just want to know what you know. Yes. MR. SPEER: The music is starting outside for the festival anyway. jammed in here. We're about to get There are people starting

to park in our parking lot. Well, I couldn't park. the back. MR. SPEER: You're in a truck? I parked right here in

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Page 89 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A All right. A A Black, yeah. MR. SPEER: Okay. that was. I hope they don't get -MR. SPEER: That's fine. That's my property. Good. I was wondering who

I didn't know but that vehicle

belong to my daughter, and I don't what her tires to get taken off of it. MR. SPEER: Right, right. right there. BY MR. BOUDREAUX: Q Mr. Key, are you aware of any other killings in the parking lots of any of the Circle K's in this area around this time period? No. Is it possible that malfunction in the equipment and stuff may have not made it to your log? Not the cameras, the cameras was working. Were there times when the cameras weren't working that it just didn't get put on your log, ever? Well, you're okay

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Page 90 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A A Yes. A Q A A Q No. No. No.

If a camera wasn't working, it would have had to have been on your log? Correct. Were there situations -Especially at that store, you know. very tense store. MR. SPEER: A lot of traffic? A lot of attitudes. MR. SPEER: Yes, sir. You got it. Near the bars. That was a

BY MR. BOUDREAUX: Q Did anybody else maintain the log you did regarding malfunctioning equipment? Well, all people had access to the log, but it was my duty to call it in and make sure that the work got done. Okay. So, if a camera was down, whoever

noticed the camera was down had the responsibility to go and put it in the log? Right. All right. And how did that information make

it to you?

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Page 91 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A No. A Yeah. A wife? She's going to be okay. MR. SPEER: Do you want to take a break? My wife, she's -MR. SPEER: Do you want to take a break and call your wife? I'll be okay. MR. SPEER: All right. BY MR. BOUDREAUX: Q A We can take a break if you want to talk to her. No. It will be okay. I'll be okay. My wife -Q A Q A Q A Q A By me picking the log up and seeing whether or not I had any issues, I would call it in. How often did you review the log? Every morning. Every morning? Yes. So if you had a problem, you would call it in? That's right. Okay. MR. SPEER: Mr. Key, did you ever talk to your

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Page 92 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A June 10th. MR. SPEER: Oh, well, I got one coming up too. You won't be 68 though. MR. SPEER: No, sir. I'll get there soon enough. A A A MR. SPEER: Yeah. late -Yeah, but she's. MR. SPEER: -- but when I'm downtown, she's going to get mad, she thinks I'm out there having a good time -Well, she's -MR. SPEER: -- instead of sitting in here with Jason. MR. BOUDREAUX: Nothing could be further from the truth. Well, she know I'll be 68 on my birthday, so she know it's -MR. SPEER: When's your birthday? Mine always expects me to be

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Page 93 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A BY MR. BOUDREAUX: Q So, Mr. Key, if somebody knows the camera wasn't working but chose not to put it into the log, it's possible you wouldn't know about it, correct? Oh, yeah. When I sit down in that seat, look

at the monitor, I see a screen that's out, I go check. When that camera is out, we need to go

check it. Okay. What if you go home for the night and

you don't come back until the next morning, and at some time during that period a camera stops working and they start having problems with it, and the employee there sees that there's problems, but they don't put it in the log, would you have any way of knowing that there were problems with that camera? Not until I get to work. And then you would have to actually see the problem happening at the time, correct? Yes. All right. MR. SPEER: Jason, just so I don't have to interrupt you, I'm going to make this a

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Page 94 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Okay. MR. SPEER: Because I am. -- MR. SPEER EXITS THE ROOM -BY MR. BOUDREAUX: Q Mary Guillory testified earlier and she said that the workers who changed out those tapes we talked about earlier, and I think we standing objection about repetition because Mr. Key has already testified that all those cameras were working at the time and so I don't have to interrupt you, I'm just going to state my objection because -MR. BOUDREAUX: Yeah, that's fine. MR. SPEER: -- I find it repeatedly at this point. MR. BOUDREAUX: Not a problem. MR. SPEER: And I'll be back. bathroom. you want. You can go to the

We can take a break whenever

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Page 95 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A Q A Q Q A established you don't really know what tapes she's talking about, was supposed to enter information on logs showing that the tapes were changed. No. Do you know anything about that? I

She would have to explain that to me.

don't understand that. she's speaking about.

I don't understand what

Was there anything at the beginning of every shift that an employee was supposed to do with regard to the cameras? No. They just ran continuously? Correct. The employees didn't have any responsibility to do anything in connection with the cameras? But if there was a problem, log it. a camera out, log it. But that was the only responsibility? Yeah. I got you. So you don't know anything about If there's

logs having to do with an employee doing something at the beginning of every shift? Well, if there was a problem, they needed to log it on the worksheet. Did they have to log that they had checked the

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Page 96 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q Q A cameras every time or no? No. No. I mean, yeah, I see what you're saying. But if number one was out, they would log

number one camera need to be looked at. So, the only time there was a responsibility to log anything is if there was a problem? Right. Okay. Fair enough. I think you said earlier

you looked at the camera footage with a police officer that morning after the incident? Yes. Was it just one police officer? Just one. And as we sit here today, you remember that he downloaded the camera feed that day? Yes, that morning. Okay. And you don't remember if it was a white

police officer or a black officer? No, I sure don't. You just know it wasn't Mr. Brown. No, it wasn't him. Okay. Yes. And do you remember another police officer coming a couple of weeks later and downloading It was somebody other than Mr. Brown?

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Page 97 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A A Q A Q A Q A Q A Q that camera footage? I truly don't recall anyone. You don't remember? No. Okay. Two weeks later, doesn't make sense, not to me. Have you ever had an occasion to go into the system and delete any of the footage? I didn't know you could do that. As far as you knew, you couldn't do it? Right. Okay. Who was allowed to work that computer

system back there, where the surveillance was done? Myself, market manager, and that's it -- oh, the maintenance man, Wayne Gautreaux. Who was the market manager? Paula Manuel. Okay. Mary Guillory referred to a district

manager during her deposition. It's the -Is it the same thing? -- same thing, yeah. Those were the only three people that could go back there and operate that computer?

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Page 98 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A That was supposed to, but if there was an emergency I'm pretty sure -- and the person that needed some footage from it could operate it, I'm pretty sure they would probably call me, maybe not, you know. Was it in a locked room? We could lock it. Did you lock it? Sometimes. But there was times when it wasn't locked? Correct. There were times when anybody could have went back there? Yes. Without you noticing? Well, I mean, if anybody passed you up, you know. Very seldom someone else would push, We could lock the office.

pass through that area, they either usually going to the bathroom and that's it. But I'm

not saying that someone didn't go in there, you know. If one person is working and a person says they're going to the bathroom and the door is open, -Yeah, they could sneak in there.

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Page 99 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q A Q A Q A Q Q A Q -- they could -They could sneak in there. -- sneak in there and they could get on the computer and they could do whatever they want, right? Right. Up until the time you catch them? Right. Okay. So, really anybody had access to that

computer? Yes. Not authority to use it, but access? Right. That computer is where, in relation to the rest of the store? Let's say you walk in the front

door, you walk past the register, there's a doorway right there, -Make a right turn. -- and when you go in that right, you make that right turn, you walk in there, the bathrooms are right there, right? Uh-huh (affirmative response.) Where's the bathroom, on the right or the left? When you walk through that door, the bathroom is going to be sitting on the right hand side.

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Page 100 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Q A Q A A Q Q When you walk in and go left, that's the office. So the bathroom is on one side, the office is on the other side? Correct. Okay. And the office is where the computer

system is? Correct. It's in the office.

Where's the storeroom in relation to all this? Well they call the -- where the bathroom are, they call that storeroom. Okay. So, the storeroom is on the same side as

the bathroom? Yes. Okay. So, there's a bathroom and a storeroom Is

or the bathroom is part of the storeroom? it two different rooms? Yes. Well, you know it's --

But it's on the same side? Right. Okay. I got you. Now, when you observed the

police officer download the video, tell me exactly what you saw him do. I wasn't watching what he was doing. Did you have to tell him how to get in the

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Page 101 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q Q A A Q Q A Q A Q A system? No. He knew already? Oh, yeah. Okay. Most all the -- most every police officer know how to operate those systems. Okay. And then did he have to put a disc in

the computer? Yes. Okay. You have to put a disc in there. And he puts the disc in the computer and

then what did he do? You set the footage that you want to watch, want it to record, and press the button. That's it. And the way you pick the footage you want to record is you pick a time period? Yes. Date and time period.

And we talked earlier, you said you thought you could only do one camera at a time, but -That's what I'm thinking. I never tried to do

two, but you know then I can look back, you know, maybe you could do two, you know. You could maybe do all of them, right? Maybe you can, I don't know.

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Page 102 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q Q A Q A Q A Q A Q A You don't know? No, I sure don't. Okay. No. Because you never had to do that? You know, to be honest with you, I never What I

did get any basic training on it.

learned, I learned from the technician. Who was the technician? No. Somebody else? Yeah. Somebody from corporate? No, it's a guy outside of corporate. a contract to do the electronics. Okay. When you had problems with the camera They have Is that Mr. Gautreaux?

system, was it Mr. Gautreaux that came and worked on them? Sometimes. Sometimes he would come in and look

at it since he was -- now, he worked for Circle K. He was a maintenance man for Circle K; he

would go to all stores. And all you remember about the police officer is him putting the disc and then downloading the time period he needs? Yes. And then he took the disc and he left?

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Page 103 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A Q A Q A Right. How long did that all take? I guess I gave him, what, twenty minutes, fifteen, twenty minutes, something like that. It took that long? I would think. I'm guessing now.

It takes that long to burn that video to disc, you think? Depending on how much footage you have to -You've done it before, right? Yes. You told me you kept a file. Yes. If you wanted to burn a -Fifteen minutes? No, not that long.

A little over twenty minutes. I say twenty minutes, yeah, it would take you a little while to burn twenty minutes. wouldn't take a long time. No, it

It wouldn't take,

it wouldn't take -- I guess, about eight minutes. About eight minutes? Yes, sir. And, then, did he sit there and go through the video with you while you were there?

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Page 104 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A A Q A Q A Q A Q No. No. Yes. And he didn't watch anything or mess around with it, did he? I don't recall him doing anything but that. Just putting it on a disc? Yes. Okay. Were you there the whole time he was Did you stay in there He just put the disc in and downloaded it?

sitting at the computer? with him? I want to think I was.

There's a possibility I

went out, you know, and did some work but, I mean, somebody at the register might have took a payments or a customer might have had a problem, you know, I might have left out. Did you -- after the police officer left, did you notice if there were any issues with the computer? No. Were there any problems after that?

No, there were no problems.

And until today, until Mr. Speer told you about the nine-minute gap and those other gaps, did you know anything about that? No. And if we wanted to go to the store and see

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Page 105 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Q A Q Q A that video now, that would be impossible, correct? Oh, yeah. I think it last in the system from

thirty to sixty days, I think I was told. And then like it rotates out? Like the oldest

video footage kind of disappears? Yes. Yes. It kind of fades out.

It's kind of like a TV DVR? Yes. Okay. Now, Mary Guillory during her deposition

testified that a gentleman that identified himself as Shane Damond's first cousin came to the Circle K and he demanded to see the videotape from the day of this shooting. you know anything about that? No, I don't. Did any member -She might have mentioned that to me, you know, but I don't recall her doing that. You don't remember that at all? No. Did you ever have any communications with somebody who represented themself to be a member of Shane Damond's family, -No. Do

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Page 106 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q BY MR. BOUDREAUX: Q A Q A Q We almost done. Okay. And you can blame it all on me. Yes, sir. Has anybody else asked -- after the incident, other than the police department or the police officer and Ms. Manuel, has anybody else ever asked you to see that video? No. Did you ever show that video to anybody? Nobody. Other than the two times you watched it with the -- once with the police officer and I think A Q A Q Q A Q -- come in and demand to see the video? No. Anybody that ever claimed to be friends with Shane Damond that wanted to see? No. Outside of Ms. Manuel and the police officers, has anybody else ever asked you to see that video? No. (Phone ringing.) Excuse me.

Why don't you answer it. --OFF THE RECORD--

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Page 107 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q Q Q A A Q A Q A you said you watched it again? I think with Ms. Mary and the cashier that worked that night. together. Sandra Broussard? Broussard, yeah. Okay. So, you, Sandra Broussard and Mary I think we looked at it

Guillory, watched it together? I think Sandra Broussard and myself. sure about Ms. Mary. Okay. Because I asked Sandra what took place out there, you know. As a matter of fact, she said I don't know I'm not

she was standing by the register.

if that was in her deposition, but I want to say that's what she told me, that she was standing by the register when it happened. Okay. But you would have watched it one time

either with one or both of them, -Yes. -- and you would have watched it with the police officer? I didn't watch it with him, but I was there at the time he was doing the recording. Okay. You watched it before the police officer

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Page 108 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A Q A Q A downloaded it, or after? I watched it before he downloaded it that morning, and then when he came out, I didn't watch it then. You didn't watch it again after that? No. Other than you watched it with Sandra and/or Ms. Mary? It was Sandra or Ms. Mary that morning. think it was Sandra because she was on. That was before the police officer came or after? Before. Because Sandra was gone when the I

police officer got there. And this was on the same day as the shooting? Yeah. How far did you go in school, Mr. Key? Ninth grade. How old are you now? Sixty-seven. Sixty-seven. Yeah right. Did you ever get your GED? No, sir. And you're currently retired? Still young.

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Page 109 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q A Q A Q A Q A Q A Q A Q Yes. And your last job was with Circle K, correct? Correct. And which one was that at? Right across from Channel 10. Okay. Is that Eraste Landry maybe?

Eraste Landry. Eraste Landry and Foreman? You got it. Yeah. Okay. How long had you been working at

that one before you were let go? You have to give it at least three years. So, it wasn't long after this shooting happened you went to work over there? Right. Yeah. The shooting, it will be four years ago

in July, and you had been there for three years, and you said you left there in October of 2011? I don't exactly know the month and date I left, but I was in St. Landry at least three years. When you say "St. Landry", you mean the one by Channel 10? Channel 10, yeah. That's fine. Eraste Landry. I'm sorry.

After this occurred, during Ms.

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Page 110 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A Q A Q A Guillory's deposition, she says that not long after this you got real sick; is that true? Yes. What -I had diverticulosis. Diverticulitis? Diverticulosis of the colon. Oh, okay. You're doing better now?

Oh, yeah, doing a lot better. How much time from work did you miss? About three weeks. got a bit weak. I lost a lot of blood. I

That's what happened to me.

That's part of the reason why I got terminated, you know, I had took sick. But I had a problem

before I took sick, and I thought I had took care of the problem, concerning paperwork. I took sick, I was out about three week. I came back, some forms hadn't been done. Have you ever talked to anybody with the Louisiana State Police about this incident? No, sir. Before today, have you ever talked to Mr. Rainey or Mr. Speer about this case? No. I don't think I ever seen him before. Any conversations And When

How about on the telephone?

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Page 111 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A A on the telephone with Mr. Rainey or Mr. Speer? I think Mr. Speer, it might have been Mr. Speer, there was someone I talked to in this office. MR. RAINEY: That was me. That was you? Okay. Yeah.

BY MR. BOUDREAUX: Q Okay. And what did you talk about? Just that

you wanted to reset your deposition? Well, that, and I had explained to him what I knew. Okay. So you told him what you said today?

You told him the same things you told us today? I told him that I recalled I received a phone call. I thought it was between 2:00 and 3:00, And an

but you said it might have been 4:30.

officer called me and said they needed me to come out to the store and to secure the store, that there had been an incident. And after I

got out there, I think I told him that Officer Brown met me on the far side of the street by the golf course, and he said that they had closed the store. Well, he said the police

department had closed the store and they wanted

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Page 112 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Q A Q Q me to come in and verify that the cash and the merchandise because the police department was responsible for it because they closed the store. Okay. And do you know any members of the

family of Shane Damond? No, sir. And other than Mr. Rainey and somebody from this office, you didn't talk to anybody about you coming to give a deposition in this case, correct? No. Oh, my wife. Okay. That's fine. Other than the

All right.

times we've talked about, have you ever talked with anybody with the city police department about anything in this case? No. I never even seen Mr. Brown since I left

from over there, since I transferred. Anybody with the sheriff's department? No. Anybody with Lafayette City Parish Government? No. In your testimony here today is the video that you saw did not show a shooting, correct? No. No.

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Page 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A Q Q A Q A In fact, you couldn't see anything? No movement around that vehicle at all. Could you even tell it was a vehicle? Well, it was kind of blurry, you know. I

wouldn't have known the vehicle would have been there, sitting there, if I wouldn't have seen it when I came in the store. Why do you think it was blurry? it was foggy outside? I think it was foggy and then it was night, you know. Yeah. There could have been condensation on And I'm just -Do you think

the windows in the front? I don't know.

You're inside the store, you

know, there shouldn't have been any. Yeah. And what -Well, it was in

I'm in the air conditioning. the summer month, wasn't it? Yeah, it was summer.

It was July.

What I'm

thinking is with the air conditioning running, you know, it's possible that it was starting to get some condensation with humidity and stuff on the doors, but I'm not trying -- I'm just making an observation. for thirty years, -You worked at the store

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Page 114 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A A Q A Q A Q Well, not that store, but I worked for -For many years. Yeah. And it was just an observation. Have you ever

talked to anybody about the surveillance video or anything that happened in the Circle K? Anybody that claimed to you that they were part of the family of Shane Damond or that they represented the family of Shane Damond? No. Has anybody ever told you that they saw what happened that night? Excuse me. The young lady that worked that

night, she seems to think she saw the fire from the gun. Sandra Broussard? Yeah. (Coughing). You okay? Yeah, I'm all right now. Anybody else? No. No one else. Thank you.

We're just about finished, Mr. Key. MR. BOUDREAUX: And before I forget, I want to attach the maintenance records as an exhibit.

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Page 115 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q Q Q A A BY MR. BOUDREAUX: Q Mr. Key, I'm going to show you a photograph. It's a still photograph. Is that -That's the

(Witness reviews photograph.) office. That's where the computer is?

It's been a long time since I've been in there. It's been a long time, but that looks like it, though. I'm going to represent to you that that's just a still photo of what you looked at, were looking at earlier. here says 1:38:49. And the timestamp down That's about the time;

we've kind of narrowed it down to that's the time the shooting occurred. Okay. Is that the monitor here (indicating) that would show the video footage? the cameras? That looks like the computer there. Okay. Is it a different monitor? Yes, I think it's sitting It's been a That would show

That's the desk.

back here, if I'm not mistaken.

long time since I've been in there. Now, you say the monitor would be --

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Page 116 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A Q A Q A Q Q A That's the computer there. That's my desk there. Okay. If you were sitting at the desk and That's the desk.

facing the computer, where would the monitor be? My mind went to -Eraste Landry? Yeah. That's exactly where my mind went to.

If you don't recall, it's okay. Yeah. That screen right there, though, would be a computer? Yeah, that's my computer. That's not the monitor? No. That's my desk. MR. BOUDREAUX: Since we talked about it, I guess I should attach it. I'll attach it as the

next numbered exhibit. BY MR. BOUDREAUX: Q Mr. Key, do you have your driver's license with you? Yes. We're going to attach it as an exhibit to the deposition.

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Page 117 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have. -- MR. SPEER EXITS THE ROOM -A A Q A Q A Q A Q A Okay. You're going to do a copy?

Yeah, we'll do a copy. Okay. MR. BOUDREAUX: We'll attach his license as the next exhibit.

BY MR. BOUDREAUX: Q Mr. Key, have you understood all of my questions here today? Yes. Do you feel like there's anything you need to go back and explain about what we talked about? I sure don't. Have you told me everything that you know about that camera that night? Yes. And the footage, the video footage that was taken that night? Have you told me about

everybody you've talked about with the Lafayette Police Department? Yes. MR. BOUDREAUX: I think that's all the questions I

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Page 118 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A EXAMINATION BY MR. RAINEY: Q I've just got a couple. You said you got a

call the night of the shooting from Officer Brown. Brown. I kind of seem to think, I'm thinking

it was Officer Brown, you know. Okay. Yes. And you left your house in St. Martinville? Yes, St. Martinville. Okay. Did you leave right away or did you take Well, it was somebody from the police?

a shower or brush your teeth or anything like that? No. No. I didn't. I went back and took a

shower.

I didn't brush my teeth or anything I got up and got dressed.

like that.

So, you got dressed and you -Yes. -- went straight over there? Uh-huh (affirmative response.) Okay. So you don't know what time you got the

call, you don't know what time you got there, but -The only thing I can say, I think I mentioned to you, the only thing I can say is it was

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Page 119 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q Q A A Q A Q Q A A Q Q after 12:00 midnight. Okay. So it's whenever you got the call, we

don't know what time it was, -No, I sure don't. -- you got there however long it takes to get from St. Martinville to the store? Correct. And no traffic there so, so you come

right on in. How long does it take you to get from St. Martinville to the store? In no traffic, say about thirteen minutes. Okay. So, whatever time you got the call, you

got to the Circle K about thirteen minutes after that call? Right. Okay. You left quick; you said you didn't even

get a chance to brush your teeth? Well, I mean, they said you know there had been an incident. I'm thinking robbery, you know.

And you left and went back to your house and took a shower? Yes. Okay. that? Yes. And you went back to the store after

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Page 120 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A A Q A Q A Q A Q A Q Q Was the sun up when you went back to the store the second time? Yes. Okay. Oh, yeah. Now, the day of the shooting, you said

the police took their own footage off the system? Correct. You didn't help them? No. They didn't ask you for help? No. Okay. So, they already knew how to work it

themselves? Oh, yeah. Okay. And you say that the officer only

downloaded one camera the day of the shooting? That's what I'm thinking. Okay. What makes you think that?

Well, I mean, it didn't take him that long, you know. Okay. Yes. in. Okay. It would take multiple discs if there Based on the amount of time it took? And I didn't see but one disc that he put

were multiple cameras?

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Page 121 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Well, the thing is -- I don't exactly know how that thing work, you know. I'm not sure that

he downloaded two different cameras at the same time. Okay. I'm not sure about that. But your recollection is he only

downloaded one camera? One, that's what I'm thinking. what I'm thinking, one. If video was downloaded that night, would that prevent someone from downloading that footage again later on? Oh, no. Okay. So, they could have downloaded -Yeah, that's

You have access to that, for what, between thirty and sixty days. Okay. So, if someone downloaded footage the

night of the shooting, they can come back two weeks later and download it again? Oh, yeah. Like I said, they got, what, thirty

to sixty days, if I'm not mistaken. I might have heard you wrong earlier, did you say that sometimes footage was pulled off of the system and burned onto a disc and then stored? If you had a problem, shoplifting, you know,

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Page 122 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q Q A A Q A Q problem at the cash register. So, that would burn onto a DVD and you would save the DVD itself? Yes. Okay. Right. morning. Right. And if you had a problem at the cash register, you know, a bad cash shortage, you know, you can go back and monitor that. Okay. So, for all you know, and I think it was In case you needed it past sixty days? Well, in case you needed it the next

either Mary Guillory or Sandra Broussard, said that she was changing tapes, as far as you know, it could have been that she was preserving footage from her shift and then saving the DVD? I don't know how she would have done that, because you would have to go back there to the system and set the -- and you said she didn't know how to do it, I think that's what Mr. Speer said, she said she didn't know how to record. Fair enough. MR. BOUDREAUX:

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Page 123 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A A A One question, Mike? MR. RAINEY: Sure. MR. BOUDREAUX: Was there ever a system out there where you had some kind of tapes? Say that again. MR. BOUDREAUX: Was there ever a system out there for the surveillance where you used tapes? I don't recall. I truly don't.

BY MR. RAINEY: Q Okay. And you didn't have any hand in creating

these maintenance logs right here, correct? Well, I had a log similar to this one. Those are handwritten? Yes. Okay. But I never received anything like this. Yeah, In

I know what Ms. Mary was talking about now. the mornings, but I don't know if we were set

up like that at that time, you changed over the daily. I know what she's talking about now.

What was she talking about? It's a tape about that long (indicating).

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Page 124 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Yes. MR. BOUDREAUX: Like a VCR tape? The size you're

showing to me looks like a VCR tape. And they date it, 1st, 2nd, 3rd, on down But that lasted, what, a month, for

the line.

a month, and then you have to reuse those same tapes, record over those same tapes. BY MR. RAINEY: Q A Q A Q A Q What was recording to those tapes? Any everyday activity for twenty-four hours. Okay. Would that record all six cameras? It should.

That's a good question. But you don't remember? No.

But there were some tapes that were recording something? Yeah. We were keeping those, but we don't do

that anymore. When did you stop doing that? I think when they went to the new system. So you were using that system at the time of the shooting? Yes. Alongside that DVR system? Yes.

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Page 125 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Yes. MR. BOUDREAUX: Where did you get it from? Did you A A Q A Okay. I remember that now. MR. BOUDREAUX: And just to clarify for me, you were using both of them at that time or were you using the VCR system? Well, we could go back and print up anything, any information we need. MR. BOUDREAUX: I'm not following you. In other words, we had an incident in the store, we could go back there and print it up, what it recorded. MR. BOUDREAUX: At the time of this incident?

get it off the tape or did you get it off the computer? The computer, we got it off the computer. MR. BOUDREAUX: So, at this time, were you still using tapes or did you have both systems running?

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Page 126 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A BY MR. RAINEY: Q A Q A Q It sounds to me like it was a back-up system? It could very much be. Okay. Yeah, you're right. Ms. Mary was right. A Yes. MR. BOUDREAUX: I'm sorry, Mike. I didn't mean -A A I think we had both of them, if I'm not mistaken. MR. BOUDREAUX: Were the -- was what was recording on the tapes the same thing that was being recorded to the computer? It should have been. MR. BOUDREAUX: As far as you know?

I know you said multiple times throughout this deposition that the camera facing the front door was working that night. Yes. If it was broken, you would have called it in? Yes. Okay. No. And you didn't call it in?

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Page 127 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q A Q A Q A Q Q A Q Because it was working? Correct. Okay. I know you said that it's possible that

there could be a black screen like the one you saw on that laptop there, because the camera was not functioning but -Correct. -- could it also have been that way if someone just didn't pull any footage off the camera? Say that again. That screen on that laptop there shows six different cameras and one of them was black. Correct. You said earlier that it could appear black if the camera was broken? Correct. Could it also appear black if someone just didn't pull the footage off of the camera? I don't think so. question. Okay. You said that that camera was working, I don't understand that

but it's not showing any footage. Right. You said one reason it might not be showing anything is because the camera was broken?

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Page 128 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A A Q Right. Could another reason be that someone just didn't download any footage? No. The only way that could have been black is

if something was wrong with that camera. There's no other reason. It's just like going

out there, unplugging the wire on the camera and it's not working. Okay. But you have to go and select footage

from the camera -Okay. -- for it to show up, correct? If it's not recording, you're wasting your time, right? If the camera is not recording,

you're wasting your time trying to get footage from it. But to preserve the footage -- strike that. The cameras are recording and it's storing to a system somewhere in the store, right? Okay. And you can download specific portions of that footage, correct? Pass it by me one more time. Okay. MR. BOUDREAUX:

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Page 129 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Okay. MR. BOUDREAUX: He wants you to -- he's asking you to concentrate on where you go into the system and you download a time increment, like from 6:00 to 8:00, like we talked about earlier. Yes, okay. On a disc. A Okay. MR. BOUDREAUX: Where he's going from there, I don't know, but that's what he just asked you. A Okay. MR. BOUDREAUX: That's where he's at now. He's asking you what I talked to you about earlier. He's saying that you can

go on there and you can take time increments and download it from the computer for those time periods.

BY MR. RAINEY: Q So, if someone was to pull footage, let's say from 1:19 in the morning to 1:51 in the morning, off of five cameras and not download anything from the sixth camera, could it appear

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Page 130 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A A No. A Q A Q black or could there appear to be nothing showing from a sixth camera, if someone only asked the system to produce footage from five of the cameras? Okay. That's all you're going to get.

So, you would have a blank space there -Right. -- where a sixth camera would be? downloaded. MR. BOUDREAUX: If you don't know, I mean -I mean I don't want to mislead him. It If it was

sounds like he's saying something that's not -MR. BOUDREAUX: And look, he's not trying to mislead you, but if he's asking you a question you don't know the answer to, I mean it's perfectly fine to say "I don't know." Well, but I think I understand what he's saying. MR. BOUDREAUX: Okay. You have five --

BY MR. RAINEY: Q There's six cameras that you can ask the system

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Page 131 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q A Q A Q A Q A Q to put on a DVD. Okay. If you only ask the system to pull -Five. -- five of them, -Okay. -- you would have a blank space -Correct. -- where the sixth camera would be; is that correct? Right. Okay. That's correct. So that's a possible reason for that

sixth camera to be showing a blank space? MR. BOUDREAUX: Object to the form of the question. but if you're not asking for but five, and you have six there, you're only going to get five. BY MR. RAINEY: Q Right. So, there would be nothing in the space It would be

where the sixth camera would be? just like that (indicating)?

If it's broken, yeah, you won't want anything to be there. Or if you just didn't ask for it to give you any footage from the sixth camera?

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Page 132 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A A Q A A Okay. A Q A Right. Okay. I think that's it. MR. RAINEY: Okay. That's all I have. Right.

You owe me a Coke for that.

RE-EXAMINATION BY MR. BOUDREAUX: Q Yeah, I'm not sure what your answer is, though, but let me ask you. If you didn't download the

sixth camera, what I understood you to say is the sixth camera wouldn't show up on here, correct? Or are you saying --

If you're asking for --- that you would get a black screen? If you asking information from five cameras, but you have six, you're only going to get information from five cameras, right? That's for you to answer that. Yes. So, the sixth camera would be missing? Right. You wouldn't see anything? Right. Okay. Because you're only asking for five.

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Page 133 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q Q A Q A Q Q A Q A I understand you. Okay. If -But if you ask for six and only get five, you're going to have that black space there -Okay. -- because you have a malfunction there. Okay. Yes. Okay. If Mary Guillory testified -- and I'm So that indicates a malfunction?

not representing to you that she did -- she testified you got there after 4:00 o'clock, you have no reason to disagree with that, right? Oh, no. No.

Because you don't know what time you got the call that morning? I don't, I don't. But you -I know it was after 12:00. But once you got the call, you got out there fast? Yes. But you don't know what time you got the call? No. Okay. These tapes, that security footage that

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Page 134 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q A Q A Q A Q A Q were downloaded to, how long did y'all hang on to those tapes? For one month. And you -Then you start recording over those same tapes. Okay. So, even if we still had those tapes, we

could only go back a month? Correct. So, like today is April 26th, you might have March 27th or later? That's right. Okay. Okay. When you stopped working there, did y'all still have both systems? And I'm not sure I That's right.

I understand you.

understand why, why was the footage being downloaded to videotapes and to the computer? Is there a reason that that was being done? I'm trying to think did we have both systems or not. both. When I left there, I don't think we had I mean, from by Channel 10, I don't I don't think we were using

think we had both. both systems then.

But when you were at the one on Mudd Avenue? Yes. I think we were using them.

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Page 135 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A A Q Q And the video footage that the officer downloaded, it was from the computer; it wasn't from the videotape? Right, from the computer. And those tapes, you would just have thirty days back, I think we just established that. Okay. You could go to the system for thirty days back. I think it's sixty days, but I'm going

to say thirty. You could go farther back on the computer than you could on the tapes; is that right? Yes. Because the computer -- I mean the tapes

only last about thirty days, thirty-one days. Now, you said you would make copies of certain time increments and keep them when something happened in the store? Yeah, like a theft, a shoplifting or something like that. Why didn't you do that in this case? I don't know if I did or not. I don't recall.

It's possible that you did and the -It's possible. You think that DVD would still be sitting over there at the Circle K?

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Page 136 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Now, I don't know. I would have to talk with She might have trashed

Paula Manuel, you know.

everything in the file cabinets, you know. How long would you usually hang on to those DVDs? Until I was satisfied with the outcome of what I was investigating? Do you think that this is the kind of incident that you would have made a DVD for and kept it? I think so. You just don't remember as we sit here today? No. MR. BOUDREAUX: Okay. That's it. I don't have

anymore questions. MR. RAINEY: Just one second. record real quick. -- OFF THE RECORD -RE-EXAMINATION BY MR. RAINEY: Q Just one last time, Mr. Key, is there any doubt in your mind that the camera was working on the night of the shooting? That it wasn't working? That it -- you said that it was working, Let's go off the

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Page 137 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Q A Q A correct? It was working. Is there any doubt in your mind about that? None at all. MR. RAINEY: Okay. No more questions.

FURTHER EXAMINATION BY MR. BOUDREAUX: Q And that camera, it did not show the shooting, correct? No. You couldn't see anything on that camera, correct? Well, I could see that it was something in that parking lot. But you didn't even see movement? No, I didn't see any movement at all. I just have a last couple of questions. All right. Your deposition was previously set in this case and you didn't show up. up? Well, I had gone to Alabama. I hate getting Okay. And I Why didn't you show

into this, but my mother passed.

found out that she didn't have life insurance. And me and my oldest sister, we had to get

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Page 138 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q Q A A Q A Q Q money to bury her. And when was that? And I don't want to get

into any specifics about it, just when was that? A couple of weeks ago. A couple of weeks ago? Yes, sir. When you talked to Mr. Rainey about why you didn't come for your deposition, did you give him a different story? I don't know what I said to him, but I didn't tell him about my personal business. Did he ask you why you didn't show up the first time? I'm not certain. I'm not sure.

Do you remember telling him why you didn't show up? I don't recall what I said. Okay. You just remember telling him about what

you remember from this case? Yes, I explained that to him. I told him, you I think

know, I didn't see anything, you know.

I told him when I got there, they had the yellow tape around the pumps. You couldn't

drive on the lot, and I circled the store, and

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Page 139 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A Q A Q Mr. Brown met me on the opposite side of the street. And I think he said to me that they

had to close the store because there had been an incident. And he said when they close the

store, that mean that the city was responsible for the merchandise and the money in the store. Okay. When your deposition was going to be

here the first time, did you call and tell him you were coming and then you didn't show up? I called and told him that. You told him -But my wife had called him and explained to them the reason why I -- well, my wife was the one that called -- my wife called here and she was supposed to get a date and time when I was going to come in, but she said whoever she talked to didn't call her back. Okay. But that was right before the deposition Was that the same day? I really

was supposed to occur?

I don't know if it was the same day. don't recall the date and time. Okay. I don't have anymore questions.

But she's one of those people, she writes down everything and, you know. Okay.

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Page 140 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Yeah. Q A A My wife is a bishop and she's strict about everything. Okay. She going to give me hell when I get home. MR. RAINEY: Mr. Key, you don't recall telling me that you had a religious objection to testifying? I told, I did tell him that.

BY MR. BOUDREAUX: Q Okay. Why didn't you just tell me that just

now when I asked you about it? Well, -You know you're sworn to tell the truth just like you're in a court of law, right? Yeah. Okay. I know that. What did you tell him?

I explained to him the type of church that I was brought up in and that we had -- my wife was Catholic when I met her and she convinced me to start going to Catholic church and I got kind of deeply rooted in the Catholic church. Then we found out that all that was taught in the Catholic church is not true. Okay.

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Page 141 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q Q A Q A And my wife is, like I said, my wife is a minister and we just, you know, some of it just -- it's not best to go to court, you know, and testify against your fellow man. Okay. Yes. That's the reason you didn't show up the first time? No, the first time I went to Alabama. Okay. See, I was born in Birmingham, Alabama. Okay. And you didn't want to come this time And that was the reason?

because of your religious beliefs? Yes. Okay. But once you were served by the court

and you knew you had to come, then you decided to just come in and go ahead and tell your story, correct? Well, my daughter set me down and talked to me, you know, and she said, "Dad, best thing," -as a matter of fact, today I left the book fair early to try to get here. Okay. Well, we appreciate you coming in. Thank you for coming and giving us

Thank you.

your testimony and we're done.

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Page 142 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A You're not going to keep my license? We just need a copy of it. Okay.

THE WITNESS WAS EXCUSED. DEPOSITION CONCLUDED AT 7:34 P.M.

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Page 143 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 _______________________________ Connie Marks Certified Court Reporter # CERTIFICATE This certification is valid only for a transcript accompanied by my seal stamped in blue ink on this page. I, CONNIE M. MARKS, a Certified Court Reporter in and for the State of Louisiana, as the officer before whom this testimony was taken, do hereby certify that ROBERT KEY, after having been duly sworn by me upon authority of R.S. 37:2554, did testify on the 26th day of April 2012, at Lafayette, Louisiana, as hereinabove set forth in the foregoing 142 pages; that this testimony was reported by me in the stenomask reporting method, was prepared and transcribed by me or under my personal supervision, and is true and correct to the best of my ability and understanding; that I am not related to counsel, I am in no manner associated with counsel for any of the interested parties to this litigation, and I am in no way concerned with the outcome thereof. This 1st day of May 2012, Lafayette, Louisiana.

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