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Deposition Transcripts · Segments · #9012
id
9012
deposition id
9
segment index
37
speaker
Page 38
start seconds
end seconds
text
that a count required two individuals to conduct. Is that right? A Yes. Q Was that the same for a round? A For a round, no. Q And you had mentioned that Mr. Thomas had told you earlier in the night in question that he didn't want to do a count. Did he ever make any comments about not wanting to do rounds as well? A So let me explain. So, with a count, the person is on the grille, and then one person goes down and counts. Then you switch places; the other person goes down and counts. With a round, you still need two people because somebody has to open the gate, but the one person can make the round. The one person doesn't have to go behind after. So you still need two people physically going to the tier, but the round can just be one person. The count, you have to cross-count. Ms. Feyerabend. What's the gate that you just mentioned? Ms. Noel. Every cell block has a gate, the grille. So, like, to get in the cell block, you're opening the grille door. Ms. Feyerabend. Okay.