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Deposition Transcripts · Segments · #9008
id
9008
deposition id
9
segment index
33
speaker
Page 34
start seconds
end seconds
text
A 12:00 -- Q -- 12:00 a.m. -- A -- 3:00, 5:00. Q And were you responsible for each of those counts -- A Yes. Q -- from August 9th to August 10th? A Correct. Q Okay. A Let me just clarify. So, on the 4:00, there's three of us working, so there's two people that have to count. So I don't necessarily have to count. It just has to be two people. Q And this was the same requirement, the counts and the rounds, for all inmates that were housed in the SHU? A SHU. Correct. Q Okay. What was the difference between a round and a count in terms of what you were actually doing or looking for or your responsibilities at that time? A Because a count, you're counting and also making sure you're seeing a live, breathing body. But a round is just seeing a live, breathing body; you're not necessarily counting how many people are in there. Q So the rounds were a bit more relaxed, so to speak? A Correct. Q Okay. So what were the goals or purposes of a round and a count? I know you just mentioned, but if you could -- A A round would be to make sure that everyone's okay. A count would be to account for