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State vs. Vilchez, Victor
This web site is designed to provide an easy format to access the evidence in
the case of State vs. Vilchez, Victor
State vs. Vilchez, Victor is about the events that happened on February 20, 2008 involving Victor Vilchez and Louis Aloysius Davis.
This Deposition by Louis Davis from April 13, 2009 has hyperlinks that will pop up a new web page with evidence that show the statement given by Louis Davis is inconsistent with statements from independent witnesses and the facts.
Page 2
1 APPEARANCES:
2 FRANK GEORGE, ESQUIRE
Office of the State Attorney
3 415 N. Orange Avenue
Orlando, FL 32801
4 (407) 836-2400
5 APPEARING ON BEHALF OF THE PLAINTIFF
6
DAVID BIGNEY, ESQUIRE
7 The Bigney Law Firm
101 S Wymore Road, Suite 440
8 Altamonte Springs, FL 32714
(407) 772-7876
9
APPEARING ON BEHALF OF THE DEFENDANT
10
11 ALSO PRESENT:
12 KELLY SIMS. ESQUIRE
Law Offices of Kelly Sims Esquire
13 312 Park Avenue North
Winter Park, FL 32789
14 (407) 644-8881
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Page 3
1 INDEX
2
TESTIMONY OF LOUIS DAVIS
3
Direct Examination by Mr. Bigney 4
4 Cross-Examination by Mr. George 50
5
6
6 CERTIFICATE OF REPORTER 54
CERTIFICATE OF OATH 55
7 ERRATA SHEET 56
NOTIFICATION LETTER 57
8
EXHIBITS
9
(None marked.)
10
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20
21 STIPULATIONS
22 It is hereby agreed and so stipulated by and
23 between the parties hereto, through their respective
24 Counsel, that the reading and signing of the transcript
25 is expressly reserved by the deponent.
Page 4
1 ------
2 WHEREUPON:
3 LOUIS DAVIS,
4 having been first duly sworn to tell the truth, was
5 examined, and testified upon his oath as follows:
6 THE WITNESS: Yes, I do.
7 DIRECT EXAMINATION
8 BY MR. BIGNEY:
9 Q. Please tell me your name.
10 A. Louis Davis.
11 Q. Mr. Davis, my name is David Bigney. I’m the
12 attorney for Victor Vilchez, the gentleman in the van.
13 You were involved in an incident. At this point,
14 your case is over. You understand that you’re no longer
15 subject to prosecution on this case, correct?
16 A. Correct.
17 Q. Okay. That being said, I just want to make sure
18 that we go through the whole incident, everything that
19 you remember, everything that you saw.
20 Just like I told the girls, if you don’t remember
21 anything, please don’t guess. I just want to know for
22 sure what you know; and if you don’t remember, by all
23 means tell me. Nothing is meant to trick you. I’m not
24 trying to get you in trouble. Quite frankly, if I
25 wanted to, I couldn’t.
Page 6
1 Q. Okay. Mr. Davis, you remember the incident from,
2 I believe it was, 20th of last year with
3 Mr. Vilchez?
4 A. Yes, it was the 20th. I remember because it was
5 my son’s birthday the day before.
6 Q. Okay. Take me from the time you got in your car
7 to take the girls to school that morning. Who was in
8 the car with you?
9 A. My two girls, Lakala and Lakyah.
10 Q. Okay. And where were they sitting?
11 A. Lakala sits in the front seat because she’s 12,
12 and Lakyah sits in the backseat.
13 Q. All right. And do you recall the first time you
14 saw the van that Mr. Vilchez was driving?
15 A. Yes, I do.
16 Q. What was it doing the first time you saw it?
17 A. The first time I saw the van, it was actually
18 backing out. I was away from the vehicle --
19 Q. Okay.
20 A. -- at that time.
21 Q. All right. And was it still backing out -- at
22 some point, I know you passed the van. Was it still
23 backing out when you passed it, or had it started
24 turning into the road?
25 A. No. It was already gone out to the road
Page 7
1 proceeding northbound.
2 Q. Okay. How long have you lived in this
3 neighborhood for?
4 A. For 12 years now.
5 Q. What is the speed limit in that neighborhood? I
6 guess -- I don’t know if that’s a school zone or not
7 you’re going through. What was the speed limit where
8 you saw-
9 A. Well, it’s actually not a school zone.
10 Q. Oh, okay.
11 A. But the area is 25 miles an hour.
12 Q. Now, on that particular road, is there anything
13 that -- is there any speed bumps?
1 4 A. Yes, there are.
15 Q. Okay. When Mr. Vilchez was backing out, was he
16 backing out of a driveway?
17 A. You know, I actually don’t remember that.
18 Q. Okay.
19 A. All I know is I saw his vehicle because he wasn’t
20 fully in any driveway. His vehicle was already
21 partially in the road, backing out.
22 Q. On that particular day, were you rushing to
23 school?
24 A. No, I was not.
25 Q. Okay. And the road that you were on, is that a
Page 8
1 one-way on each side of the road?
2 A. Yes, it is. Two lanes, yes.
3 Q. Okay. It is a -- is there any markings within
4 the road to indicate that you’re allowed to pass on that
5 road?
6 A. Yes, there are.
7 Q. What would those be? What are the markings?
8 A. The dotted lines.
9 Q. Okay.
10 A. Single-dotted lines.
11 Q. And how far are you away from Mr. Vilchez when
12 you first saw him backing out of wherever he was backing
13 out of?
14 A. I can’t estimate that, can’t exactly say.
15 Q. It’s okay. I’d rather you not guess, like I
16 said.
17 A. But I was not close up on him, you know. I was
18 driving defensively.
19 Q. Did you follow him for a while before you decided
20 that he was driving too slow, that you had to pass; or
21 is it just as you came up on him, you just passed him?
22 A. No, I followed him for a little while. It was a
23 A. matter of seconds.
24 Q. Okay.
25 A. A few seconds.
Page 9
1 Q. Why did you pass him?
2 A. Because he was going ultimately slow.
3 Q. All right. And up to this point, has he done
4 anything to you, or is he just driving too slow?
5 A. Oh, no. He was just driving too slow.
6 Q. Okay.
7 A. And I saw that I could pass him safely.
8 Q. When you passed him, did you say anything to him?
9 A. Of course not, no.
10 Q. Did you gesture to him at all?
11 A. Not at all.
12 Q. Okay. And--
13 A. You still wondering my time passing him, or are
14 we going through the sequence?
15 Q. Well, I’m just -- as you’re passing him.
16 A. Oh, as I’m passing him. No, I’m actually just
17 passing him.
18 Q. Okay. When you got in front of him, did you say
19 anything or gesture to him?
20 A. Now, before I got in front of him, he was pulling
21 over, if I can explain a little bit on that.
22 Q. Sure, go ahead. I’m sorry.
23 A. As I was -- as I was passing him, I wasn’t really
24 going over the speed limit to pass him. That’s how slow
25 he was actually going.
Page 10
1 Q. Okay.
2 A. That he was actually traveling. My daughter--
3 Q. Let me interrupt you just for a second. As you
4 passed him, was that shortly after he started
5 accelerating from backing out, or had he been driving
6 for a long time?
7 A. Okay. I’m gonna have to go back again.
8 Q. Okay.
9 A. Not as I passed him, as I was passing him,
10 because he was -- I’m here (indicating). He’s
11 here (indicating). So as I was passing him. I hadn’t
12 passed him yet.
13 Q. Okay.
14 A. Okay. Start back from there?
15 Q. Sure.
16 A. As I was passing him, my daughter said, Dad,
17 what’s that guy doing? Because he was coming over on
18 me.
19 Q. Which daughter?
20 A. Lakala. She was in the front seat.
21 Q. Okay.
22 A. And then they both looked and said. What’s that
23 guy doing? I said, Well, he doesn’t want me to pass
24 him, Okay. So --
25 Q. Is this while you were on the side of him or
Page 11
1 behind him?
2 A. Yes. I was on the side of him, yes.
3 Q. Okay.
4 A. Okay. So I just looked at him, and I gave him
5 the finger. Okay. And I proceeded to pass. There was
6 a speed bump coming up. and I proceeded and passed him.
7 Q. When you flipped him off were you already past
8 him -- —
9 A. No.
10 Q. -- or were you still passing him?
11 A. No, I was passing him.
12 Q. Okay.
13 A. Because he was trying to compete with me, with
14 his vehicle and my vehicle, and because he sped up and
15 offered me not to pass him.
16 Q. Okay. And you say that because his car was
17 getting closer to you? Or did he say anything or do
18 anything with his body that made you believe that?
19 A. Well, he was saying words. I -- you know, I saw
20 his mouth moving. I couldn’t understand what he was
21 saying.
22 Q. Okay.
23 A. But he was coming closer to me to offend me
24 somewhat.
25 Q. Okay. So then you passed him. What happened
Page 12
1 after you passed him?
2 A. Okay. After he-- after I passed him, let me try
3 to remember exactly.
4 After I passed him, he sped up. Okay. There was
5 another speed bump coining up, so I slowed down; and
6 that’s when he ran right into me.
7 Q. Okay. So that is at a speed bump where he ran
8 into you?
9 A. I passed the speed bump.
10 Q. Okay. So you had just gone over the speed bump?
11 A. Yeah, just gone over the speed bump.
12 Q. Okay.
13 A. Yeah. Then he ran into me.
14 Q. How many speed bumps was it that you went over
15 from the time you actually passed him and flipped him
16 the bird and --
17 A. That was the only speed bump.
18 Q. Just the one?
19 A. It was just that one speed bump.
20 Q. Okay. And what happened after the impact? Did
21 you stop?
22 A. After the impact, my first initial thought was to
23 stop. All right. So I pulled over slow, but I
24 didn’t -- well, I was taking my car to the curb. I
25 didn’t completely stop when I say I pulled over.
Page 13
1 So he passed me at that time, and that’s when I
2 heard a shot ring out.
3 Q. Okay. Hold on a second.
4 A. Okay.
5 Q. You stopped your car? You pulled over and
6 stopped your car?
7 A. Not completely, no.
8 Q. Okay. Did he stop his car at all?
9 A. No.
10 Q. Okay. Did you open your door or --
11 A. No.
12 Q. -- get out or anything along that line?
13 A. No.
14 Q. So you stayed in your car the entire time?
15 A. Yes. The car was -- both the vehicles were still
16 in motion.
17 Q. Okay. And what happened from there?
18 A. What happened from there is he came on the side
19 of me, and then I heard a shot ring out.
20 Q. Okay.
21 A. Then he sped up in front of me, and then he hit
22 his brakes. Okay. Continue.
23 Q. You said you heard a shot ring out.
24 A. Uh-huh.
25 Q. Was the car behind you when you heard the shot
Page 14
1 ring out? Was it on the side of you?
2 A. The car was on the side of me.
3 Q. Did you see the shot, or did you hear the shot
4 ring out?
5 A. I just actually saw his hand. I didn’t see --
6 Q. Did you see anything in his hand?
7 A. I didn’t see anything at that time.
8 Q. Okay. And did you shoot back at that time?
9 A. Of course not.
10 Q. Okay. So you saw his hand with nothing in it?
11 A. Well, I’m not gonna say I saw his hand with
12 nothing in it, you know --
13 Q. Okay. But you —
14 A. --because I’m driving also.
15 Q. All right. But you didn’t see anything in his
16 hand; is that fair to say?
17 A. Yeah, I guess that’s fair to say.
18 Q. Okay. But you heard --
19 A. I wasn’t really looking for something in his
20 hand. I just looked at the vehicle. I wasn’t looking
21 for something in his hand. I just heard the shot ring
22 out, and I’m familiar with weapons so --
23 Q. Okay.
24 A. I know what l heard.
25 Q. All right. And at this point, is he on your side
Page 15
1 of the car or on the other side of the car?
2 A. He’s on my left.
3 Q. Okay. Did you -- do you recall whether or not
4 his window was open or closed?
5 A. I can’t recall.
6 Q. All right. And did that shot or that --
7 A. His driver’s side window was open. I remember
8 that.
9 Q. Okay. But as he’s passing you --
10 A. I can’t remember that.
11 Q. -- his passenger’s side window is next to you,
12 right?
13 A. Yeah, but I can’t remember that.
14 Q. All right. Do you recall if that noise that you
15 believe was a shot hit your car?
16 A. No.
17 Q. No, it didn’t hit your car, or you don’t recall?
18 A. No, it didn’t hit my car.
19 Q. Okay. And so what happens after the van passes
20 you?
21 A. Okay. After the van passes me, he hit his brakes
22 really hard as if he wanted me to run into him. So then
23 he sped up. So thinking quickly, it’s like, I felt like
24 my life was in danger so I --
25 Q. And I’m sorry. I’m going to interrupt you again
Page 16
1 because I thought of something.
2 How many shots did you hear when he was behind
3 you or passing you?
4 A. I only heard one shot.
5 Q. Okay. Back to -- you said he sped up --
6 A. Yeah.
7 Q. -- after he hit his brakes.
8 A. Right. Okay. And then 11 was telling my daughter
9 to get — no. Okay. He sped up, and then I was
10 telling -- yes, I was telling my daughter to get his tag
11 number.
12 Q. Did you have your daughters duck down when you
13 heard the first shot? Did you say anything to them?
14 A. They actually got down themselves.
15 Q. Okay.
16 A. You know, they actually got down themselves. And
17 at one point, I did tell them that; but I don’t remember
18 at that point.
19 Q. Okay. We’ll get to that.
20 A. So you asked your daughter, Lakala, she’s in the
21 front, to get the tag.
22 A. Yes.
23 Q. So did you follow him close enough to get the
24 tag?
25 A. I was trying to, but at that point - well, I did
Page 17
1 catch up to him. Okay. And my initial thought was he
2 was trying to get away, so I decided I was actually
3 gonna aim to shoot his tire, his passenger-side-rear
4 tire, out.
5 Q. Okay. So is that what you tried to do there?
6 A. Exactly.
7 Q. Okay. At this point, when you’re trying to shoot
8 his tire out, and I’m talking now that he’s driving in
9 front of you -
10 A. Uh-huh.
11 Q. -- is he doing anything in the effort to shoot
12 back at you?
13 A. No. He had sped up at that time.
14 Q. All right, How many shots did you take --
15 A. I can’t remember.
16 Q. --at this point?
17 A. I can’t remember because I never kept a full
18 magazine.
19 Q. How many shots did you take as you heard the
20 first shot?
21 A. At him?
22 Q. Yes. This is as he’s passing you we’re talking
23 about?
24 A. No, no, no.
25 Q. The first time you shot was when you were trying
Page 18
1 to shoot his tires out?
2 A. Yes. He was in front of me. I didn’t shoot when
3 he was beside me at all.
4 Q. Okay. So the first time you shoot is when you’re
5 trying to shoot his tires out --
6 A. Exactly.
7 Q. -- as he’s trying to get away?
8 A. Exactly. This is right. Well, not trying to get
9 away. I don’t want to say he was trying to get away.
10 Q. Okay. And I’m sorry that I used that. I thought
11 you said that you thought be was trying to get away.
12 A. No, not that. I didn’t start shooting at
13 him -- or shooting at his tire because he was getting
14 away. I think after I made the initial shot -- shot
15 fired at his tire, that’s when he realized I had a
16 weapon also.
17 Q. Okay.
18 A. So he attempted to flee then, maybe, you know. I
19 would too.
20 Q. Okay.
21 A. Yes.
22 Q. Okay. Did you continue to follow him after you
23 tried to shoot his tires out?
24 A. No, I actually didn’t. To the end of the road,
25 to my daughter trying to get his tag number, I was
Page 19
1 actually on the — I was trying to contact 911.
2 Q. Okay.
3 A. Okay. But with the nervousness and everything
4 going on, I dropped the phone a couple times. But no, I
5 didn’t continue to follow him, though.
6 Q. Okay. Tell me the route that you took home. I
7 I know you dropped off the girls; you’re going down; you
8 try to shoot his tires out.
9 Can you give me an estimate as far as how many
10 shots you took at that point?
11 A. I think I took three.
12 Q. Okay. How many guns did you have on you in the
13 car?
14 A. 11 carry two. They’re my personals.
15 Q. All right. And you said you fired three, and
16 then you took your girls home. Tell me the route you
17 took to get home.
18 A. Okay. Well, with that jump, I’ll have to explain
19 more to you.
20 Q. By all means, go ahead.
21 A. We’re traveling on the road of — called Egan.
22 So that’s a northbound road which we were traveling.
23 That’s the same exact road I take every single day, even
24 until now, that I take my kids to school.
25 So as we travel and Mr. Valchez -- Vilchez, I’m
Page 20
1 not sure, was in front of me, I was — we were heading
2 on the same path. Okay. We came to the end of Egan to
3 Lake Underhill. He made a left. I’m sorry. He made a
4 right. Okay. That’s the same way I have to go take the
5 kids home, make a right -- to school, to make a right.
6 Okay.
7 So I decided, with everything going and
8 everything so forth, I said I was gonna take the kids
9 back home. So in that case, I’ll have to make a right,
10 make another right, which Mr. Vilchez did also. Okay.
11 When I came that - so that road then is
12 Garwood Drive. No, I’m sorry. Goldenrod Road. That’s
13 the main road. So in that — in terms of that, we both
14 made a right onto Goldenrod. And then I would have to
15 make another right onto Autumnvale.
16 Q. To get in your neighborhood?
17 A. To get in my neighborhood.
18 Q. Okay. Let me take a little step back at driving.
19 At some point, it’s my understanding, I guess, speaking
20 with your girls, that you drove through the bank parking
21 lot behind Mr. Vilchez.
22 A. Yeah, I did.
23 Q. Okay. Was that before or after you tried to
24 shoot his tires out?
25 A. That was after.
Page 21
1 Q. Okay. All right. Why did you go through the
2 bank parking lot after you tried to shoot the tires out?
3 A. Because the cars were blocked. The cars were
4 there stopped at the light and so forth, so I just took
5 that way.
6 Q. Did Mr. Vilchez also go through that bank parking
7 lot?
8 A. I can’t remember.
9 Q. Okay. All right. So you then pull into your
10 neighborhood; and I guess at that point, you drop the
11 girls off?
12 A. I turned.
13 Q. During that part of the drive with the girls,
14 when you’re shooting, did you have the girls duck down?
15 A. Yeah, they were down.
16 Q. They were down. Were they down the whole time
17 that you were shooting?
18 A. As a matter of fact, Lakyah was down, I think.
19 Lakala — oh, while we’re shooting?
20 Q. While you were shooting.
21 A. Oh, you know, I can’t even say. It happened so
22 fast. I can’t even say because --
23 Q. I just want to make sure I understand it. From
24 the point that you first saw Mr. Vilchez in the van
25 until the point you drove and dropped off the
Page22
1 girls -- drove the girls home and dropped them off, you
2 remember hearing one bullet from Mr. Vilchez and that
3 was around -- that was right when the accident happened,
4 correct?
5 A. Uh-uh.
6 Q. Okay. So you dropped the girls off. Do you tell
7 them anything at that point? Do you say anything to the
8 girls?
9 A. I told the girls to go into the house to your
10 mother.
11 Q. Okay. And what did you do?
12 A. Well, we made a big jump from that.
13 Q. Okay.
14 A. I need to start --
15 Q. Well, fill in the gaps for me.
16 A. I need to finish from where I made a right turn
17 to go home on Goldenrod to Autumnvale.
18 Q. Okay.
19 A. I made that right. Mr. Vilchez continued
20 straight, you know, because I’m not chasing him.
21 Q. Okay.
22 A. He continued straight. I made that right. So
23 I’m deciding, well, I’m gonna go ahead and take them
24 home. I’m gonna take them to -- no, I’m thinking maybe
25 I should just take them home. So what I did - I was
Page 23
1 thinking about just taking them back to school.
2 So I made a right on Autumnvale, made another
3 right back on Egan to just go and take my route back to
4 school. So I decided just take them all home, you know,
5 because they’re hysterical and crying and so forth. So
6 I was just gonna take them.
7 So I made a quick U-turn from someone’s yard. I
8 made a U-turn to get back onto Autumnvale, and then I
9 was gonna make a right to go back home. So it turns
10 out, when I made that U-turn around, Mr. Vilchez was
11 right in front of me with his weapon pointed right at
12 me.
13 Q. Okay. Are the girls in the car at this point?
14 A. Yes. So that’s when I told them -- that’s when I
15 know for a fact --
16 Q. Tell me where this was.
17 A. I remember telling them to duck.
18 Q. What street is this?
19 A. That was Egan and Goldenrod. No, I’m sorry.
20 Egan and Autumnvale.
21 Q. Okay. So Mr. Vilchez is out of his car pointing
22 his--
23 A. I did not say that.
24 Q. Oh, okay.
25 A. I said — okay. Let’s run through it again.
Page 24
1 Goldenrod headed southbound, I made a right onto
2 Autumnvale, okay?
3 A. Okay.
4 Q. Apparently, Mr. Vilchez continued past
5 Autumnvale. He made a right at the next turn to come
6 back and try to corner me off, and that’s what happened.
7 So he was in pursuit of me.
8 Q. Okay. So you’re going down Goldenrod south?
9 A. Correct.
10 Q. Okay.
11 A. And I make a right onto Autumnvale.
12 Q. Autumnvale. And where was the next time you saw
13 Mr. Vilchez’s car?
1 4 A. When I made a -- I was on -- I saw his car --
15 Autumnvale splits Egan. So he was on the south side of
16 Egan, and I was on the north side with my car pointed
17 towards the south; and he was coming towards me with his
18 gun drawn.
19 Q. Okay.
20 A. And that’s when I know for a fact I told the kids
21 to duck. And I had to escape him by going through
22 someone else’s yard.
23 Q. Okay. So how many shots was it that you heard
24 from Mr. Vilchez?
25 A. I can’t remember now, but he -- I’m saying at
Page 25
1 least four, at least four to five shots.
2 Q. Okay.
3 A. And only one struck my car that I could identify.
4 Q. Okay. So did you cross over Egan on Autumnvale?
5 A. Okay. Once - you’re saying once I was on
6 Autumnvale? Once I was on Autumnvale determining
7 whether to take my kids home or to go ahead and take
8 them to school, I decided, you know, quickly, I was
9 gonna go take them back to school.
10 So I proceeded to take my regular route onto
11 Egan. So I just thought quickly, with them being
12 hysterical, just turn around and take them home. So
13 after I made the U-turn and turned around --
14 Q. Where did you make the U-turn?
15 A. I made the U-turn -- well, it was basically a
16 three-point turn. So I pulled in someone’s driveway and
17 came back out to come back out to Autumnvale.
18 Q. I’m having a real difficult time following you
19 here.
20 A. I can draw it for you.
21 Q. Does this help?
22 A. (Witness reviews document.)
23 No, because I don’t see -- okay. Autumnvale.
24 MR. SIMS: Before you start drawing, do you
25 want to just highlight the route or something?
Page 26
1 THE WITNESS: (Witness complies.)
2 BY MR. BIGNEY:
3 Q. Can you see on that map where the initial
4 incident happened?
5 A. Around about. Around about maybe.
6 Q. Okay. Where was the original incident?
7 A. Where it says Kadel Way -- it was before
8 Kadel Way, I’m pretty sure, around about in there. I
9 can’t determine from the distance on this map compared
10 to the actual --
11 Q. Okay. I understand. Before Kadel Way on Egan?
12 A. Somewhere. I’m not saying for sure before Kadel.
13 Q. Somewhere around Kadel on. Egan?
14 A. On Egan, correct.
15 Q. Okay. All right. And then from there, you went
16 to where? I’m going to get behind you real quick so I
17 can follow you. Are you okay with that?
18 A. Yes. Okay. After we came here (indicating) to
19 Goldenrod --
20 Q. I want to start where the accident happened.
21 A. Okay. Somewhere in here (indicating).
22 Q. Okay.
23 A. Somewhere in there.
24 Q. And you’re pointing over in the general area of
25 Kadel.
Page 27
1 A. Okay. Somewhere in this area. Okay. So we’re
2 traveling here on Egan (indicating).
3 Q. Here. Color that in so we know that’s all part
4 of your route.
5 A. (Witness complies.)
6 So we come here to Lake Underhill. We both make
7 a right.
8 Q. Where is it that you both started shooting at?
9 A. Right here. Right in here (indicating).
10 Q. That’s where you start trying to shoot his tires
11 out?
12 A. Yes.
13 Q. All right. So then you go down Egan?
14 A. Go down Egan; come o Lake Underhill. We both
15 made a right because I go this way to take my kids to
16 school, but I decided 1 was gonna take them to home.
17 Q. Okay. Write “school” and put an arrow on there
18 so we can see that over there, that that’s the direction
19 you take the kids to school.
20 A. (Witness complies.)
21 Q. Okay.
22 A. So l made a right on Goldenrod because I decided
23 I was taking them back home, okay?
24 Q. Okay.
25 A. So this is my turn here. I made a right, right
Page 28
1 here (indicating).
2 Q. Okay.
3 A. Mr. Vilchez was --
4 Q. Was he behind you at the time or ahead of you?
5 A. He was ahead of me.
6 Q. Okay.
7 A. So I came here, and I made a right back on Egan.
8 I was like, you know, because I was determining, should
9 I take them to school? Should I not?
10 Q. Okay.
11 A. So I decided to make a three-point turn
12 here (indicating) and go back out. From Egan, go back
13 out to Autumnvale. Okay.
14 When I made that three-point turn, Mr. Vilchez
15 was right here (indicating) facing me with his weapon
16 drawn.
17 Q. Okay. Is he still in his car, or is he out of
18 his car?
19 A. He’s still inside his vehicle.
20 Q. Okay.
21 A. Both cars were in motion, like I said before.
22 Okay. So what I do to elude him — I told the kids to
23 duck. I know for sure I said it then; and I escaped by
24 cutting through the person’s lawn right here, back on
25 the corner of Egan and Autumnvale, for me to get to
Page 29
1 Garwood.
2 Q. Okay.
3 A. Proceed on?
4 Q. Go ahead.
5 A. Okay. As I turned here, made a right trying to
6 elude him, made a right onto Autumnvale. I was speeding
7 then.
8 Q. Did he make shots over here? Did he fire his
9 weapon as you were coming towards him?
10 A. No, no, no. He fired shots as he got behind me.
11 Okay. So he followed me onto Autumnvale. Well, yeah,
12 on Autumnvale. And he was firing shots, and I was
13 speeding at that time.
14 I got on Garwood, and I was speeding through the
15 speed bumps. But my initial -- I told my daughters I’m
16 gonna take them home. What I want them to do is, as
17 soon as I stop, get Out of the car; go to your morn. I
18 don’t want him to know where I live.
19 Q. Okay.
20 A. So he was following me at that time.
21 Q. Okay. Did he follow you home?
22 A. You know, I’m not sure. I thought - I’m pretty
2 3 sure my car was going faster than his. I not sure
24 exactly where he stopped off
25 Q. Okay.
Page30
1 A. Or if he did, he didn’t come through whole
2 circle; because I think I probably would’ve saw him
3 there unless --
4 Q. So do you agree at some point he stopped
5 following you?
6 A. Pm not gonna say that because --
7 Q. Okay. Well --
8 A. I didn’t see him at the time.
9 Q. At some point, he wasn’t behind you anymore, and
10 you lost him one way or another?
11 A. I guess that’s fair to say.
12 Q. Okay.
13 A. Okay?
14 Q. All right. And so at that point, is that when
15 you went home? Or was that on your way home that you
16 lost him? And when I say, You lost him, I’m not saying
17 that you were successful in maneuvering him on the road
18 or I’m not saying that he stopped, just he was no longer
19 behind you anymore or within your vision.
20 A. I can’t say that because I don’t know.
21 Q. Okay. Well, did you --
22 A. When I dropped my girls off--
23 Q. Well, how about this: When you dropped your
24 girls off, did you see him from where your house is?
25 A. No.
Page 31
1 Q. Okay.
2 A. No.
3 Q. All right. How long were you stopped at your
4 house dropping off the girls?
5 A. I don’t even think I stopped the car from
6 rolling.
7 Q. Okay. And did you go in your house and call the
8 police?
9 A. If I didn’t stop the car from rolling, I didn’t
10 stop.
11 Q. It may sound like a silly question, I understand.
12 But did you go in your house and call the police?
13 A. No, I did not. I was on the phone with 911 after
14 I had recovered my phone. I have records to show I was
15 on the phone with 911.
16 Q. Okay, good. I’m going to want to get those also
17 from you.
18 All right. And were you on the phone with 911
19 when he was coming at you with his weapon drawn?
20 A. You know, it’s hard to say. But I had already
21 contacted them. The reason why I say it was hard to say
22 is because with the nervousness and so forth, I had
23 dropped my phone a couple times. I had a flip phone at
24 the time, so I remember dropping my phone a few times.
25 And I’m not sure if they called back or I had called
Page 32
1 them back, but I know we had to get back in touch with
2 each other through the incident.
3 Q. Okay.
4 A. So I’m pretty sure I was on the phone.
5 Q. Okay. When you left your house -- well, first of
6 all, did you tell your girls to call the police?
7 A. No, I did not. I just told them to hurry up and
8 get in the house. I knew their mother would take care
9 of all that.
10 Q. Okay. Why’d you go back out?
11 A. Because I didn’t want him to know where I live,
12 if that makes sense to you. I didn’t want him to know
13 where I live. I live in a loop. There’s no exit in any
14 area. That’s just one way.
15 Q. Do you have a garage or anything along that line?
16 A. Yes, I do.
17 Q. Do you park your car in your garage ever?
18 A. No, I don’t.
19 Q. Okay. Can you?
20 A. No.
21 Q. Okay. Why not?
22 A. Because I have a refrigerator; I have weight
23 equipment, so forth.
24 Q. All right. And does your driveway --
25 A. Plus I have three cars, so they all can’t fit
Page 33
1 Q. All right. What were you going out to do when
2 you left your house?
3 A. To make sure he didn’t know where I live.
4 Q. Okay.
5 A. Like I said, I would know if he was still behind
6 me or not if it’s just a one way entrance, so I knew
7 mine was a loop.
8 Q. Okay. Now, again, maybe I’ve asked this a few
9 times, but just to clarify.
10 At this point, as you get the girls out of the
11 car -- up to that point rather, how many shots had you
12 heard from Mr. Vilchez?
13 A. At least four shots.
14 Q. Okay. All right. So it would be one at the
15 original scene, and then three more coming as you guys
16 are heading towards each other, as you’re going to drop
17 off your girls?
18 A. Yes.
19 Q. After you did your U-turn?
20 A. Yes.
21 Q. All right. So you leave your house. Where did
22 you go?
23 A. Came back to the end of the road to make sure –
24 Q. Which road?
25 A. I came back to the end of--
Page 34
1 Q. Now, you’re on Garwood Drive, right?
2 A. Yes. So I came back to the end of Garwood, yes.
3 Q. Now, on Garwood, are you on a corner?
4 A. No. We’re to the end where Garwood intersects
5 with Autumnvale.
6 Q. No. Where’s your house? Is it all the way on the
7 back end of the circle, the deepest part?
8 A. No. My house is right here on Garwood, somewhere
9 in here (indicating).
10 Q. Okay. All right. Now, as you got back in your
11 car, could you see Mr. Vilchez?
12 A. No, I didn’t get back in my car.
13 Q. I’m sorry, as you started to go away. I know you
14 said you didn’t even get out.
15 A. Right.
16 Q. Did you see Mr. Vilchez’s car right away?
17 A. No. I came back to the end of the road.
18 Q. End of which road?
19 A. End of Garwood and Autumnvale.
20 Q. Okay. Now, that Garwood Drive, that connects all
21 the way to Autumnvale. right? And it circles around by
22 where your house is?
23 A. Yes. Garwood is a circle and -- yes.
24 Q. And that road leading from Autumnvale to the
25 circle is also part of Garwood? Am I right on that?
Page 35
1 A. The roadway right here (indicating)?
2 Q. This one right here (indicating).
3 A. Okay. This is from Autumnvale to my house right
4 here (indicating).
5 Q. Okay. This whole line you just drew, is that
6 Garwood, that whole line?
7 A. Yes, yes, it is.
8 Q. Now, you said you got back in your car and you
9 drove to Autumnvale?
10 A. I didn’t get back in my car. I was still in my
11 car.
12 Q. I apologize again. You started going again after
13 you dropped off the girls?
14 A. Yes.
15 Q. And you drove all the way to Autumnvale?
16 A. To Autumnvale, yes.
17 Q. Okay. Did you see Mr. Vilchez before you made it
18 to Autumnvale?
19 A. No, I didn’t see him.
20 Q. Okay.
21 A. But when I got to Autumnvale, of course I stopped
22 a complete stop, looked both ways. I saw Mr. Vilchez’s
23 van going away.
24 Q. Which way?
25 A. He was headed --
Page 36
1 Q. Towards Goldenrod?
2 A. Correct. Heading east towards Goldenrod.
3 Q. Okay.
4 A. So what 1 did then, 1 made a left. Okay. I
5 said, It’s all over, you know. I made a left, going
6 away from Mr. Vilchez, heading west.
7 Q. Okay.
8 A. Okay. So I notice in my review that Mr. Vilchez
9 did a quick U-turn in the middle of the road where the
10 four-way stop sign was. He made a quick turn.
11 Q. At Autumnvale and Egan?
1 2 A. Egan, correct.
13 Q. Okay.
14 A. Okay. So as he made a quick turn, he — okay. I
15 made another left. You know, he was catching up to me
1 6 at that time, so I didn’t want him to catch me in my car
17 if he was gonna be shooting at me.
18 So at that time, I parked my car on the side of
19 the road after I made that left. And I got out of my
20 car because he shot at me once again.
21 Q. Where did he shoot at you again? After you got
22 out of the car?
23 A. No. He shot at me as I was in my car. As I was
24 in my car, he shot at me.
25 Q. This is the third time he’s shooting at you
Page 37
1 A. That’s the third time he’s shooting.
2 Q. Where was this that he was shooting at you for
3 the third time?
4 A. The third time -- you see that adjoining road
5 that goes to Garwood right down in front of it,
6 Garwood (indicating)?
7 Q. It looks like a little bit of an L, I guess, the
8 way I’m holding it.
9 A. Yes, right there (indicating). That’s where I
10 made my left turn, in there.
11 Q. Okay.
12 A. Because he was shooting at me. So I made a left
13 turn there, and I got out of my vehicle.
14 He was -- when 1 got out of my vehicle, he still
15 had his gun pointed at me. So I ran across the street,
16 and that’s when 1 fired another shot at Mr. Vilchez’s
17 van.
18 Q. Okay. Just one shot?
19 A. Yes.
20 Q. All right. And you said he’s firing at you as
21 you shoot at him?
22 A. Yes.
23 Q. All right. Did you try to hide at that point, or
24 did you just run out in the middle of the Street for a
25 gunfight?
Page 38
1 A. No. I’m not stupid. I tried to hide.
2 Q. And why is it that you ran out in the middle of
3 the street?
4 A. I didn’t say I ran in the middle of the street.
5 I tried to hide. I ran across the street.
6 Q. Okay. Did you run across Autumnvale?
7 A. No. I ran across that little street
8 there (indicating). I’m not sure what the name of that
9 street is. I just ran across the street, and it was a
10 neighbor’s -- someone’s yard there; and I hid behind a
11 black truck.
12 Q. Okay. And what happened after you hid behind the
13 black truck?
14 A. Actually, Mr. Vilchez crashed into the vehicle.
15 And I think that was --
16 Q. Okay. And is that when you started firing?
17 After he crashed or before he crashed?
18 A. No, before he crashed.
19 Q. Okay. Did you fire your shot at him when you
20 were hiding behind that black car?
21 A. I think that is when I shot -- fired a shot, yes.
22 As matter of fact, yes.
23 Q. And it was just one shot that you fired?
24 A. Yeah. Just one shot, yes.
25 Q. And you said he was shooting at you?
Page 39
1 A. As he was -- yes. As he was driving his vehicle
2 by, he was shooting at me, yes.
3 Q. Okay. And is that the end of the incident for
4 you? What did you do after that?
5 A. After that, I’m not sure if he tried to turn back
6 around real quick or not; but he ran into a car, side
7 swiped a vehicle. And I was running to my house. I had
8 911 on the phone, and I was letting them know what the
9 rest of the incident -- what was going on. And they
10 were just advising me that the police were on their way
11 and so forth.
12 Q. Okay. And is that where you met the police, at
13 your house?
14 A. No. I stayed in the area. I put both my weapons
15 down and
16 Q. Did you use both your weapons?
17 A. Yes.
18 Q. Okay. My count has you taking, I think, four
19 shots during this entire incident, three when you were
20 trying to shoot his tires out from behind him and one
21 shot as you were going across -- as you were hiding
22 behind the black car; is that right?
23 A. That sounds right.
24 Q. Those were the only times you shot?
25 A. Yes, that’s the only two times I shot.
Page 40
1 Q. Four bullets?
2 A. Like I said, I didn’t ever really carry a full
3 magazine, so roughly so.
4 Q. Well, how many were left in the magazine after
5 you were done with the incident?
6 A. You have to ask the sheriffs department that.
7 Q. Okay. And let’s talk a little bit about your
8 employment history.
9 Were you a police officer before?
10 A. Never a police officer, no.
11 Q. Okay. Were you involved in --I guess you worked
12 at a jail?
13 A. A corrections office, yes.
14 Q. What jail did you work at?
15 A. Central Florida Reception Center.
16 Q. Okay. So you worked at the prison system?
17 A. Yes, I did.
18 Q. How long ago was that?
19 A. It’s been -- that’s been about maybe ten years
20 ago. Ten, eleven years ago, something like that.
21 Q. All right. And did you resign? Were you fired?
22 A. No, I resigned.
23 Q. Why’d you resign?
24 A. I was starting my own business.
25 Q. Okay. Is that the business you’re in now?
Page 41
1 A. No. I had started a tow service; and no, I’m not
2 in it now.
3 Q. What are you doing now?
4 A. I was working for a laser company. They had some
5 layoffs, so I was one of the ones -- I was one of the
6 first ones there, so they laid us off first. We were
7 the ones making more money than the other group, so.
8 Q. Okay.
9 A. I’m in school now.
10 Q. Okay. Good. Did you do anything to prepare your
11 daughters for these depositions today?
12 A. No.
13 Q. Okay. Did you tell them what to expect?
14 A. I didn’t know what to expect myself. I just told
15 them they would be asked some questions. I told them
16 that they was going to a deposition, and that’s when
17 they asked, “What’s a deposition?”
18 Q. Did you guys go through what you all remembered
19 about the incident --
20 A. No.
21 Q. -- at any point?
22 A. No. Only that my younger daughter, she wanted to
23 talk about it a lot because, you know, I guess it kind
24 of bothered her. So she’d just bring up little things.
25 I rarely comment on it at all when they bring it up
Page 42
1 Q. Did you ask your older daughter what she
2 remembered?
3 A. In the past, I did.
4 Q. When was the last time?
5 A. I’m not sure.
6 Q. How about this: Was it yesterday? Did you talk
7 to her about it yesterday?
8 A. No. Yesterday I just told them that they gonna
9 be asked some questions if they remember. I told them
10 that last night.
11 Q. And did they tell you what they remember?
12 A. Yeah, they kind of tell me a little bit. And I
13 said, “Okay. Well, just tell the truth.’ Yes.
14 Q. All right.
15 MR. BIGNEY: Frank, do you have any
16 questions?
17 MR. GEORGE; No.
18 MR. BIGNEY: All right. I do. Let me just
1 9 think for another minute or so.
20 BY MR. BIGNEY:
21 Q. At any point, did you have a chance to write down
22 the tag number?
23 A. You know, my daughter, she wrote something down;
24 but you really couldn’t understand what it was. She was
25 hysterical, and I couldn’t.
20Page 43
1 Q. Okay. So you never knew the tag number?
2 A. No, I did not.
3 Q. All right. Tell me about the damage to your car
4 from the actual accident.
5 A. He ran into my bumper pretty hard; and that’s
6 what really, you know, excited the kids. I didn’t see
7 any physical damage. Underneath, there might be some
8 little damage.
9 Q. Okay. There might be or there is?
10 A. Might be.
11 Q. So you don’t know of any actual damage to the
12 car?
13 Q. It’s hard to tell with a lot of cars these days
14 until you actually physically inspect it,
15 Q. Have you actually physically inspected it?
16 A. No. That requires taking the bumper off to see
17 the frame damage and so forth.
18 Q. So do you know of any damage at all to your car
19 from the accident?
20 A. Only a bruised bumper and with the shot that was
21 fired in my trunk.
22 Q. Okay. And what point -- do you recall what point
23 that that shot that was fired in your trunk -- that it
24 actually hit?
25 A. Uh-huh.
Page 44
1 Q. When was that?
2 A. That was when we -- when he was following me onto
3 Garwood, when you turn back around and start on Garwood.
4 Q. Okay. Which would’ve been the second part of the
5 shooting?
6 A. The second, yes.
7 Q. Or the second time that he shot at you?
8 A. Yes.
9 Q. All right. Were the girls in the car at that
10 point?
11 A. They were in the car the whole time until I
12 dropped them off at the house.
13 Q. Were they in the car at the time that bullet hit
14 the trunk?
15 A. I was taking them home on Garwood, so of course
16 they were.
17 Q. Okay. All right. And tell me a little bit about
18 your, I guess, your experience shooting firearms.
19 A. Well, I always had an interest in going into
20 the military actually.
21 Q. Uh-.huh.
22 A. And then law enforcement So I joined the
23 Sheriffs Explorers back in high school.
24 Q. Okay.
25 A. So that was one of my first initial training in
Page 45
1 shooting a weapon. From there I went to the military.
2 And my job was strictly weapons. 1 was an expert
3 shooter.
4 After the military -- I did almost four years in
5 the military, and got out and did reserve. I was an
6 expert AR/MI 6, so forth. Went in corrections. And I
7 was also trained with weapons there also.
8 Q. Okay.
9 A. So that’s been my whole training.
10 Q. All right. Other than this particular incident,
11 have you ever fired your firearm at somebody?
12 A. Never.
13 Q. Excluding military?
14 A. Okay. Excluding military? No.
15 Q. All right. And how often do you shoot? Do you
16 go to the range and all that?
17 A. I haven’t been to a range in years now.
18 Q. Okay. Why is it that you carry two firearms
19 around with you?
20 A. Because I also -- business purposes. I do
21 auctions, sell cars. At times. I carry a good sum of
22 money, and for personal protection.
23 Q. Okay. Why did you carry two that morning?
24 A. Same reason I just told you.
25 Q. Did you have a lot of money on you at the time?
Page 46
1. A. No, but I was going to pick some money up.
2 Q. Okay. And you were working at an auction at the
3 time?
4 A. Yes.
5 Q. Where were you picking up the money from?
6 A. From BB -- Fm sorry. 555 Auto Body & Sales.
7 Q. From whom?
8 A. Bobby.
9 Q. Did you talk to Bobby that morning?
10 A. No, I didn’t talk to him that morning.
11 Q. When was the last time before that morning that
12 you spoke with Bobby?
13 A. I spoke with Bobby, I think, that was two days
14 before that.
15 Q. Okay. What were you picking up money for?
16 A. A car that we had purchased for the auction.
17 Q. Okay. Which car?
18 A. I forgot which one it was. We do so many cars.
19 Q. Okay. You purchased the car?
20 A. No, he purchased it.
21 Q. And when was the auction in relation to this?
22 A. You said when?
23 Q. Uh-huh.
24 A. It was the Monday before that, I think.
25 Q. Which auction?
Page 47
1 A. That’s Orlando Auto Auction.
2 Q. Is that the one out by Ocoee?
3 A. Not that one. The one off of Highway 50 across
4 from the fairgrounds.
5 Q. Okay.
6 A. And I was also picking up some money from
7 Troy Fields to -- for a purchase of a vehicle.
8 Q. Okay. Did you own these cars that you sold to
9 555 and to Troy?
10 A. No. I don’t own them until we buy them and they
11 purchase them.
12 Q. Okay.
13 A. Sometimes I’ll get money ahead of time depending
14 on the vehicle they want. They have to give us a
15 certain amount of money.
16 Q. Okay. Well, with 555 — how did that one work
17 with Bobby over at 555?
18 A. How does the auction work?
19 Q, Well, how did it work with him?
20 A. Either way. It could work different ways with
21 him, with the money.
22 Q. Okay. On this particular one, did you already
23 have the car, or were you picking up money to get the
24 car?
25 A. I was picking up money to get the car.
Page 48
1 Q. So you didn’t have the car yet?
2 A. No. We knew -- let’s see. I got to think
3 because we had different cars, and I haven’t thought
4 about that at all. I can’t remember what it was with
5 that car.
6 Q. Okay. And how often did you do business with
7 Bobby back then?
8 A. All the time, every week.
9 Q. Do you still do business with Bobby?
10 A. Yes.
11 Q. The same thing, the auction?
12 A. Yes.
13 Q. And what about this Troy?
14 A. I still do business with him also.
15 Q. What’s Troy’s last name?
16 A. His name is Fields, I think it is.
17 Q. Okay. And where can I find him at?
18 A. He has a tow service. I’m not sure where he’s
19 living.
20 Q. You got a number for him?
21 A. I could probably find a number for you. I don’t
22 know it by hand.
23 Q. You got it on your cell?
24 A. As a matter of fact, I’m not sure. I might have
25 a card.
Page 49
1 Q. And Bobby’s also.
2 A. Okay. I do have Bobby’s.
3 Q. Go ahead.
4 A. It’s (407) 484-5936.
5 Q. Okay.
6 A. And Troy’s is (407) 367-9670.
7 Q. Okay. Is there anything else about this that I
8 haven’t asked you that you remember?
9 A. No. Other than when Mr. Vilchez crashed, I saw
10 that he was running my way; and I was going away from
11 him and I was telling 911 what was going on and I just
12 tell them that I would defend myself if I have to.
13 Q. What do you mean he was running your way?
14 A. He was running my way means, if I’m coming after
15 you -
16 Q. Was he in his car or out of his car?
17 A. He was out of his vehicle.
18 Q. Okay. So he got out of his vehicle, and he
19 started coming at you?
20 A. Yes.
21 MR. BIGNEY: Don’t get too comfortable. We
22 just started a whole new line.
23 MR. SIMS: I’m not. I just want to sit here
24 fascinated by your questioning.
25 MR. BIGNEY: Thank you. I appreciate that.
Page 50
1
2 BY MR. BIGNEY:
3 Q. Okay. And just to remind me, the time that where
4 you -- that your car got shot in the trunk, that was the
5 time when you guys were heading towards each other?
6 A. How can we be headed towards each other?
7 Q. I don’t know. But I thought you said he was
8 shooting at you with his gun drawn, shooting as you were
9 coming at each other.
10 A. No, that’s impossible. That can’t happen. My
11 trunk is in the back, remember? Not the front.
12 Q. I understand that.
13 A. No. As I turned on Garwood, going to go to my
14 house, that’s when I heard shots ring out; and 1 didn’t
15 know he hit my trunk at the time. I didn’t even know
16 the car was hit, you know.
17 Q. When did you realize the car was hit?
18 A. Actually, after the police had me in the back of
19 the car and we went to the vehicle.
20 Q. Okay. So are you guessing when he hit you?
21 A. Yes, when the shot fired because -- yes.
22 Q. Okay.
23 A. Because I’m thinking that’s the only time he
24 could’ve hit the trunk is when he got behind me.
25 Q. Were you guys ever next to each other driving.
Page 51
1 after the initial passing, when he passed you –
2 A. No.
3 Q. after the incident started?
4 A. No.
5 Q. No? Okay.
6 MR. BIGNEY: I don’t think I’ve got anything
7 else.
8 CROSS-EXAMiNATION
9 BY MR. GEORGE:
10 Q. You were arrested, right?
11 A. Yes, I was.
12 Q. Taken to the jail?
13 A. Yes.
14 Q. Did you have any contact with Mr. Vilchez after
15 your arrest?
16 A. Well, they had us in separate police cars. When
17 we got to the jail, they kind of separated us from maybe
18 -- from here to there (indicating) to his chair. And
19 like a little barricade between and so forth.
20 I just looked at Mr. Vilchez. He put his head
21 down. He just dropped his head, and I was pissed. I
22 have to say, I was pissed. So I just took a stare, and
23 then when he finally did hold his head up, he said, I’m
24 really sorry. Mr. Davis. I just looked at him. And the
25 two police officers that brought us in was there; and
Page 52
1 they just looked a me as he said that, and I just told
2 him that we were both stupid. This could’ve been
3 avoided, you know. It didn’t have to happen that way.
4 And that’s all I said.
5 Q. Did he say anything to you other than that?
6 A. Yes. As we were -- I think we were already
7 booked, and I think that was the next -- no. Before
8 that, we were down in the holding - I’m not sure what
9 they call that area, the booking area. He just
10 mentioned — he said -- I know he said reporters were
11 there; and if I don’t say nothing, he won’t say
12 anything. He did say that.
13 And the next day, I think this was a mistake that
14 he — that they had us in the same area to go before a
15 judge. And they had us in the same area, but I never
1 6 said nothing to him at all.
17 He came over to me and said again that if, you
18 know. I don’t say anything about it, he won’t say
1 9 anything about it, so I guess it’d be squashed. And he
20 also was trying to give me advice on a lawyer to contact
21 and so forth. So Ithink that was it.
22 Iit did have another time where they had us
23 chained together at one time. Not him and I, like,
24 there was a person between us, and I guess they realized
25 that they shouldn’t have been that way. So that was the
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1 contact.
2 MR. GEORGE: Okay. Thank you.
3 MR. BIGNEY: Thanks.
4 MR. GEORGE: Read.
5 COURT REPORTER: Any orders?
6 MR. GEORGE: Yes.
7 (Whereupon the deposition was concluded at
8 3:57 p.m.)
9
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