Grand Jury Testimony

of Sheriff’s Deputy Jessica Brothers

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              YOU MAY CALL YOUR NEXT WITNESS.

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       MR. HUM:  THANK YOU.

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              PEOPLE CALL DEPUTY JESSICA BROTHERS.

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              (PAUSE IN THE PROCEEDINGS.)

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              (THE WITNESS ENTERED THE GRAND JURY

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              HEARING ROOM.)

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       MS. PRIVER:  IF YOU WOULD WALK TOWARDS THE WITNESS

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STAND, MA'AM.  REMAIN STANDING.  RAISE YOUR RIGHT HAND

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FOR US.

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              FACE THE GENTLEMAN IN THE CENTER.

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                    JESSICA BROTHERS,

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CALLED AS A WITNESS BEFORE THE GRAND JURY OF THE COUNTY

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OF LOS ANGELES, WAS SWORN AND TESTIFIED AS FOLLOWS:

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       THE FOREPERSON:  DO YOU SOLEMNLY STATE THAT THE

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EVIDENCE YOU SHALL GIVE IN THIS MATTER NOW PENDING BEFORE

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THE GRAND JURY OF THE COUNTY OF LOS ANGELES SHALL BE THE

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TRUTH, THE WHOLE TRUTH, AND NOTHING BUT THE TRUTH, SO

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HELP YOU GOD?

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       THE WITNESS:  YES.

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       MS. PRIVER:  THANK YOU.

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              PLEASE BE SEATED.

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              WOULD YOU STATE AND SPELL YOUR FULL NAME

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FOR THE RECORD.

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       THE WITNESS:  MY FULL NAME IS JESSICA PAIGE

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BROTHERS.  J-E-S-S-I-C-A.  MIDDLE NAME IS PAIGE,

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P-A-I-G-E.  AND THE LAST NAME IS BROTHERS,

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B-R-O-T-H-E-R-S.

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       MS. PRIVER:  THANK YOU.

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              MR. HUM.

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       MR. HUM:  THANK YOU.

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                       EXAMINATION

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BY MR. HUM:

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       Q      GOOD MORNING, DEPUTY BROTHERS.

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       A      GOOD MORNING.

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       Q      MA'AM, WHAT IS YOUR OCCUPATION AND

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ASSIGNMENT?

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       A      I AM A DEPUTY SHERIFF FOR THE COUNTY OF LOS

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ANGELES, LOMITA STATION.

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       Q      AND WERE YOU SO EMPLOYED AND ASSIGNED ON

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WEDNESDAY, NOVEMBER 8TH OF 2000?

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       A      YES, I WAS.

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       Q      HOW MANY YEARS HAVE YOU BEEN A DEPUTY

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SHERIFF?

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       A      I HAVE BEEN A DEPUTY SHERIFF FOR EIGHT

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YEARS.

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       Q      NOW, ON WEDNESDAY, NOVEMBER 8TH OF 2000, AT

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ABOUT 3:00 O'CLOCK IN THE AFTERNOON, WERE YOU WORKING?

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       A      YES, I WAS.

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       Q      WERE YOU ON PATROL?

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       A      YES, I WAS.

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       Q      WERE YOU IN UNIFORM?

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       A      YES.

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       Q      WERE YOU IN A MARKED BLACK-AND-WHITE POLICE

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CAR?

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       A      YES, I WAS.

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       Q      WERE YOU BY YOURSELF OR WERE YOU WITH A

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PARTNER?

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       A      I WAS WITH A PARTNER.

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       Q      AND WHAT WAS YOUR PARTNER'S NAME?

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       A      HIS NAME IS KLAUS GIRMES.

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       MS. PRIVER:  CAN YOU SPELL THAT FOR US?

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       THE WITNESS:  ABSOLUTELY.  K-L-A-U-S.  AND HIS

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LAST NAME IS G-I-R-M-E-S.

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       MS. PRIVER:  THANK YOU.

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       Q      BY MR. HUM:  AT THE TIME THAT YOU WERE ON

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PATROL WITH DEPUTY GIRMES, HOW LONG HAD YOU BEEN OUT

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ACTUALLY ON THE STREETS, THAT IS, ON PATROL?

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              AND WHEN I SAY "HOW LONG," I DON'T MEAN HOW

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MANY HOURS; I MEAN WHAT PERIOD OF TIME, A WEEK, A MONTH.

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       A      APPROXIMATELY FIVE WEEKS.

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       Q      PRIOR TO THAT HAD YOU BEEN ASSIGNED TO THE

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CUSTODY DIVISION, THE JAILS?

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       A      YES.

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       Q      NOW, AT ABOUT 3:00 O'CLOCK IN THE AFTERNOON

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ON NOVEMBER 8TH OF 2000, HAD YOU JUST STARTED YOUR SHIFT?

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       A      YES, AT 2:00 P.M.

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       Q      AND DOES PART OF THE AREA OF YOUR

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RESPONSIBILITY INCLUDE THE AREA OF ABALONE COVE,

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PORTUGUESE POINT AND INSPIRATION POINT?

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       A      THAT IS PART OF OUR STATION'S AREA THAT WE

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COVER, YES.

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       Q      AT APPROXIMATELY 3:00 O'CLOCK IN THE

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AFTERNOON ON WEDNESDAY, NOVEMBER 8TH OF 2000, DID YOU

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RECEIVE A RADIO CALL?

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       A      YES, I DID.

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       Q      WHAT WAS THE NATURE OF THAT RADIO CALL?

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       A      IT WAS A RESCUE CALL, AND THE CALL STATED

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THAT A CHILD WAS OVER THE CLIFF.

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       Q      AND WERE YOU DIRECTED TO RESPOND TO ANY

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PARTICULAR LOCATION?

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       A      YES, WE WERE.  IT WAS -- WE WERE DIRECTED

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TO RESPOND TO AN AREA OFF OF PALOS VERDES DRIVE SOUTH

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BETWEEN, I BELIEVE IT WAS, CHERRY HILL AND PEPPERTREE.

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       Q      AND HOW WERE YOU DIRECTED TO RESPOND?

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       A      CODE 3, WHICH MEANS WITH LIGHTS AND SIRENS.

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       Q      AND APPROXIMATELY HOW LONG DID IT TAKE YOU

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TO GET TO THAT LOCATION ONCE YOU RECEIVED THE CALL?

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       A      IT TOOK APPROXIMATELY EIGHT MINUTES.

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       Q      WHAT'S THE MAIN STREET THAT YOU WERE

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DRIVING ON IN THAT AREA TO GET TO THE LOCATION?

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       A      ACTUALLY WE RESPONDED FROM GRANVIA ALTAMIRA

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AND HAWTHORNE IN RANCHO PALOS VERDES.  WE TOOK HAWTHORNE

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TO PALOS VERDES DRIVE SOUTH.

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       MS. PRIVER:  THE ROAD THAT YOU SAID YOU WERE AT,

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THE INTERSECTION --

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       THE WITNESS:  THE INTERSECTION WAS GRANVIA

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ALTAMIRA.

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       MS. PRIVER:  -- WOULD YOU SPELL THAT.

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       THE WITNESS:  I WILL TAKE A STAB AT IT.

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G-R-A-N-V-I-A, AND THEN THE NEXT WORD IS A-L-T-A-M-I-R-A.

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       MS. PRIVER:  THANK YOU.

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       Q      BY MR. HUM:  YOU SAID THAT AFTER OR DURING

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THE TIME THAT YOU WERE GOING TO THE LOCATION YOU WERE

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DRIVING ALONG PALOS VERDES DRIVE SOUTH?

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       A      CORRECT.

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       Q      CAN YOU DESCRIBE THAT ROAD FOR US?

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       A      THAT ROAD TRAVELS ALONG THE PENINSULA IN

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SORT OF A BLUFF-TYPE/CLIFF-TYPE AREA.  YOU CAN SEE THE

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PACIFIC OCEAN AND THE PALOS VERDES PENINSULA.  YOU WILL

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FOLLOW THE PENINSULA, AND THE OCEAN IS ON ONE SIDE AND

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THE BLUFFS ARE ON THE OTHER SIDE.

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       Q      IN THE AREA WHERE YOU WERE RESPONDING IS

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THE ROAD DOWN ALONG THE OCEANFRONT?

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       A      NO, IT IS NOT.  IT IS UP ABOVE THE

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OCEANFRONT.

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       Q      SO IT WOULD BE ALONG THE TOP OF THE

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BLUFFS --

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       A      CORRECT.

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       Q      -- OR ALONG THE TOP OF THE CLIFFS?

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       A      CORRECT.

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       Q      AND AS YOU WERE DRIVING ALONG PALOS VERDES

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DRIVE SOUTH, TELL US WHAT YOU SAW AND WHERE YOU WENT.

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       A      AS WE DROVE ALONG PALOS VERDES DRIVE SOUTH,

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WHEN WE GOT NEAR -- IN BETWEEN CHERRY HILL AND

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PEPPERTREE, I BELIEVE, I BELIEVE IT WAS BETWEEN THOSE TWO

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ROADS, WE WERE HEADED TO THAT AREA WHEN WE SAW AN L.A.

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COUNTY FIRE ENGINE PARKED ALONGSIDE PALOS VERDES DRIVE

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SOUTH, SO WE STOPPED THERE.

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       Q      WAS THE FIRE ENGINE PARKED ALONG THE OCEAN

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SIDE OR THE OTHER SIDE?

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       A      IT WAS PARKED ALONG THE OCEAN SIDE.

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       Q      AND TELL US WHAT YOU SAW AND WHAT YOU DID

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ONCE YOU STOPPED BY THE FIRE TRUCK.

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       A      ONCE WE STOPPED, WE WERE DIRECTED DOWN THE

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BLUFF-TYPE AREA, DOWN A TRAIL TO AN ARCHERY RANGE AND

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SOME PICNIC TABLES -- A PICNIC AREA AND PICNIC TABLES

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WITHIN THAT ARCHERY RANGE.

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       Q      WHEN YOU LEFT PALOS VERDES DRIVE SOUTH AND

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YOU HEADED TOWARDS THE ARCHERY RANGE, WERE YOU WALKING

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ON LEVEL GROUND?

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       A      NO.  IT'S A FAIRLY STEEP INCLINE.  THERE IS

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A TRAIL, BUT IT'S ABOUT A QUARTER MILE DOWN FROM THE

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ROAD.

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       Q      AND ARE THERE BLUFFS OR CLIFFS ON BOTH

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SIDES AS YOU WALK DOWN TO THE ARCHERY RANGE?

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       A      THERE IS.  THERE IS A CLIFF-TYPE BLUFF ON

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THE --

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              WHEN WE WERE WALKING DOWNRANGE, IT WOULD

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HAVE BEEN ON THE RIGHT SIDE.  ON THE LEFT THERE IS ONE,

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BUT IT IS A LITTLE FURTHER AWAY.  IT IS NOT IN THE

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IMMEDIATE AREA OF IT.

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       Q      AS YOU GOT TO THE ARCHERY RANGE, DESCRIBE

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FOR US WHAT YOU SAW.

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       A      WHEN I GOT TO THE ARCHERY RANGE, I SAW

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PARAMEDICS SURROUNDING A PICNIC TABLE, AND A SMALL CHILD

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WAS LYING ON TOP OF THE TABLE.  THEY WERE -- THEY WERE

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WORKING ON HER.  AND THEN I SAW A WHITE MALE STANDING

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NEAR AN ADJACENT PICNIC TABLE.

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       Q      THE LITTLE GIRL THAT YOU SAW ON THE PICNIC

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TABLE, I WOULD LIKE YOU TO LOOK OVER TO THE BOARD THERE,

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TO THE PHOTO ON THE RIGHT, WHICH IS EXHIBIT NO. 3.  IS

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THAT THE LITTLE GIRL YOU SAW?

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       A      YES, IT IS.

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       Q      AND THE MALE THAT YOU SAW STANDING NEARBY,

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DIRECTING YOUR ATTENTION TO THE PHOTO WHICH IS EXHIBIT

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NO. 2, IS THAT THE MALE THAT WAS STANDING NEARBY?

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       A      YES, IT IS.

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       Q      NOW, YOU SAID THE PARAMEDICS WERE WORKING

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ON THE LITTLE GIRL?

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       A      YES.

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       Q      ABOUT HOW FAR AWAY WAS THE PERSON IN THE

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PHOTO, EXHIBIT 2, FROM LAUREN, THE LITTLE GIRL?

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       A      MAYBE THREE FEET.

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       Q      WAS HE TRYING TO GET CLOSE TO HER?  WAS HE

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TRYING TO GO OVER TO HER?

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       A      NO.  HE WAS JUST STANDING THERE.

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       Q      I WANT TO SHOW YOU A MAP AND SOME PHOTOS

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AND HAVE YOU IDENTIFY THOSE FOR US.

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       A      OKAY.

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       Q      FIRST OF ALL, JUST SHOWING YOU WHAT'S BEEN

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MARKED AS EXHIBIT NO. 4, DO YOU RECOGNIZE THE AREA SHOWN

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IN THAT MAP?

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       A      YES, I DO.

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       Q      IF YOU COULD JUST COME DOWN HERE.

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       MS. PRIVER:  KEEP YOUR VOICE UP IF YOU ARE GOING

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TO BE BY THE BOARD, PLEASE.

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       THE WITNESS:  YES, MA'AM.

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       Q      BY MR. HUM:  JUST USING THE POINTER FOR US,

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CAN YOU SHOW US THE AREA THAT YOU DROVE AS YOU WERE

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RESPONDING TO THE RADIO CALL?

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       A      WHEN WE WERE ON PALOS VERDES DRIVE SOUTH,

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WE ACTUALLY CAME DOWN THIS WAY (POINTING), WHICH ISN'T

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OBVIOUSLY ON THE MAP; BUT THEN WE CAME EASTBOUND ON PALOS

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VERDES DRIVE SOUTH, AND WE STOPPED APPROXIMATELY HERE

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(POINTING).

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       Q      AND YOU ARE INDICATING AN AREA WHICH WOULD

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BE JUST TO THE RIGHT OF WHERE IT SAYS "GATE FOR

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PEPPERTREE"; IS THAT CORRECT?

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       A      CORRECT.

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       Q      OKAY.  NOW, THE TWO POINTS THAT ARE

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STICKING OUT INTO THE OCEAN, THE ONE ON THE RIGHT AS WE

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LOOK AT THE MAP, IS THAT INSPIRATION POINT?

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       A      YES, IT IS.

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       Q      AND THE ARCHERY RANGE THAT YOU SAID THAT

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YOU WALKED DOWN OR HIKED DOWN THE PATH TO, WHICH SIDE OF

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INSPIRATION POINT IS THAT ON?

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       A      IT'S ON THE RIGHT SIDE.  IT'S APPROXIMATELY

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HERE (POINTING).

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       MS. PRIVER:  CAN YOU STAND MAYBE A LITTLE TO THE

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SIDE.

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       THE WITNESS:  SORRY.

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              THE ARCHERY RANGE WOULD BE APPROXIMATELY

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HERE (POINTING).

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       Q      BY MR. HUM:  SO AS WE ARE LOOKING AT THE

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MAP, IT'S ACTUALLY TO THE RIGHT OF INSPIRATION POINT; IS

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THAT CORRECT?

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       A      CORRECT.

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       Q      NOW SHOWING YOU WHAT'S BEEN MARKED AS

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EXHIBIT NO. 5, PHOTOS A AND B, DOES THAT SHOW THE AREA

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THAT YOU HAVE REFERRED TO AS THE ARCHERY RANGE?

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       A      YES, IT DOES.

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       Q      AND WHY DON'T YOU GO AHEAD, JUST BEGINNING

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WITH PHOTO A, AND TELL US WHAT WE SEE IN EACH ONE OF

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THOSE.

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       A      THE PHOTO IN PICTURE A IS THE PICNIC AREA I

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DESCRIBED.  IT'S COVERED.  IT'S ABOUT A QUARTER MILE FROM

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THE ROAD, WHICH IS UP TOP HERE, WHICH IS PALOS VERDES

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DRIVE SOUTH.  YOU HAVE TO HIKE DOWN OVER HERE (POINTING),

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BUT THEN YOU CAN COME IN TOWARDS THE PICNIC TABLE AREA.

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AND IT'S, LIKE THE PICTURE DEPICTS, A COVERED PATIO AREA

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WITH SEVERAL -- IT LOOKS LIKE ABOUT SEVERAL PICNIC

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TABLES, FOUR OR FIVE PICNIC TABLES.

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       Q      AND WHAT DO WE SEE IN PHOTO B?

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       A      IN PHOTO B, THAT'S A PHOTO TAKEN FROM

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INSIDE OF THE COVERED PATIO.  THIS PHOTO RIGHT -- THE

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PICNIC TABLE RIGHT HERE (POINTING) IS THE PICNIC TABLE

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THAT LAUREN WAS LYING ON WHEN I WALKED UP TO THE AREA.

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       Q      AND THAT'S BASICALLY THE PICNIC TABLE IN

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THE CENTER WITH WHAT APPEARS TO BE A STAIN AT ONE END; IS

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THAT CORRECT?

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       A      CORRECT.

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       Q      AND THEN WHAT ARE WE LOOKING AT AS WE GO

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THROUGH PHOTOS C, D, E AND F?  WOULD THAT JUST BE THE

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PATH DOWN TO THE BEACH?

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       A      YES, IT IS.

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       Q      OKAY.  AND THE AREA IN PHOTO C AND D, THE

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ROCKY AREA ON THE RIGHT, IS THAT INSPIRATION POINT?

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       A      I'M SORRY, ON C AND D?

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       Q      YES.

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       A      YES, IT IS.  IT IS THE UPPER POINT BY WHERE

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THERE IS A LITTLE -- IT LOOKS LIKE A BLUR FROM HERE, BUT

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IT'S A BUSH.  AND THAT'S THE TOP OF INSPIRATION POINT.

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       Q      WHY DON'T YOU GO AHEAD AND HAVE A SEAT.

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       A      OKAY.

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       Q      NOW, AFTER YOU AND YOUR PARTNER WALKED DOWN

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AND SAW WHAT WAS GOING ON, DID YOU AND YOUR PARTNER

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CONTACT THE PERSON WHO YOU LATER FOUND OUT TO BE CAMERON

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BROWN?

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       A      YES, I DID -- WE DID.

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       Q      DID YOU ASK CAMERON BROWN WHAT HAD

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HAPPENED?

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       A      YES, WE DID.

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       Q      AND WHAT DID HE TELL YOU?

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       A      HE SAID HE AND HIS DAUGHTER WERE WALKING,

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THEY WALKED ALONG THE CLIFF, AND THEY WERE AT THE TOP OF

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INSPIRATION POINT; LAUREN WAS THROWING ROCKS OFF THE EDGE

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OF INSPIRATION POINT WHEN SHE SUDDENLY FELL.

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       Q      DID YOU ASK HIM WHERE, WHAT AREA HE WAS

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TALKING ABOUT, WHEN HE SAID INSPIRATION POINT?

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       A      YES, I DID.  AND HE INDICATED TO ME THAT

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INSPIRATION POINT WAS THE AREA DEPICTED IN C AND D AND,

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IN FACT, HE HAD INDICATED -- HE HAD POINTED OUT THAT BUSH

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THAT I POINTED OUT A MINUTE AGO AS TO WHERE IT WAS.

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       MS. PRIVER:  C AND D OF EXHIBIT 5, FOR THE RECORD.

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       Q      BY MR. HUM:  AND HE SAID THAT IT WAS

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ACTUALLY NEAR THAT BUSH THAT YOU POINTED OUT TO US AT THE

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END OF THE POINT WHERE HE AND LAUREN WERE WHEN LAUREN WAS

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THROWING ROCKS AND SUPPOSEDLY SLIPPED?

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       A      CORRECT.

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       Q      WHAT DID MR. BROWN TELL YOU HE DID AFTER HE

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SAID LAUREN SLIPPED?

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       A      HE SAID THAT AFTER HE REALIZED THAT SHE WAS

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GONE HE WALKED TO THE -- IT WOULD BE THE WEST SIDE OF

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INSPIRATION POINT, DOWN TOWARDS AN AREA WE KNOW AS THE

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NUDE BEACH, AND ASKED TO USE A CELLPHONE TO CALL FOR

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HELP.

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       Q      AND WHAT DID HE SAY HAPPENED THEN?

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       A      HE SAID HE USED THE PHONE, CALLED FOR HELP,

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THEN WALKED BACK UP OVER THE CLIFF, AROUND TO THE OTHER

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SIDE BY THE ARCHERY RANGE, AND WENT TO RETRIEVE LAUREN.

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       Q      AND WHERE DID HE SAY HE TOOK LAUREN AFTER

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HE RETRIEVED HER OUT OF THE WATER?

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       A      AFTER HE RETRIEVED HER FROM THE WATER HE

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PUT HER ON THE PICNIC TABLE.

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       Q      NOW, AT THE TIME THAT YOU WERE SPEAKING

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WITH MR. BROWN, DID THERE APPEAR TO BE SOME MEDIA

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ATTENTION?

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       A      YES.

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       Q      AND WERE THERE ACTUALLY HELICOPTERS, NEWS

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HELICOPTERS, FLYING OVERHEAD?

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       A      YES, THERE WERE.

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       Q      DID CAMERON BROWN ASK YOU TO DO ANYTHING?

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       A      YES.  HE ASKED ME TO CALL HIS WIFE TO LET

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HER KNOW THAT -- APPARENTLY HE WAS SUPPOSED TO BE HOME,

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AND HE DIDN'T WANT HER TO SEE HIM ON THE NEWS, SO HE

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WANTED TO CALL HER AND LET HER KNOW HE WAS GOING TO BE

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LATE.

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       Q      DID HE TELL YOU THAT HE DIDN'T WANT HIS

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WIFE TO FIND OUT WHAT HAD HAPPENED BY SEEING IT ON THE

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NEWS?

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       A      YES.

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       Q      AT THAT POINT IN TIME, WHEN YOU WERE

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SPEAKING WITH CAMERON BROWN, DID YOU KNOW THAT HIS WIFE

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WAS NOT LAUREN'S MOTHER?

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       A      NO, I DID NOT KNOW THAT.

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       Q      DID HE INDICATE TO YOU AT THE TIME HE WAS

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ASKING YOU TO CALL HIS WIFE, BECAUSE HE DIDN'T WANT HER

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TO SEE IT ON TV, THAT HIS WIFE WAS NOT LAUREN'S MOTHER?

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       A      HE MADE NO INDICATION THAT SHE WAS NOT HER

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MOTHER.

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       Q      DID HE ASK TO CALL LAUREN'S MOTHER AND TELL

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HER WHAT HAD HAPPENED?

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       A      NO.

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       Q      DID HE INDICATE TO YOU IN ANY WAY THAT HE

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WAS CONCERNED THAT LAUREN'S MOTHER MIGHT FIND OUT WHAT

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HAD HAPPENED BY SEEING IT ON THE NEWS?

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       A      NO.  AS FAR AS PHONE CALLS GO, HE ONLY

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WANTED TO CALL HIS WIFE.  THAT'S THE ONLY PERSON HE

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WANTED TO CALL.

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       Q      DID CAMERON BROWN INDICATE ANYTHING TO YOU

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ABOUT ANY CONCERN WITH REGARD TO THE MEDIA HELICOPTERS?

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       A      HE DID NOT WANT TO BE FILMED BY ANY OF THE

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MEDIA HELICOPTERS AND ASKED IF WE COULD ENSURE THAT HE

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WAS NOT GOING TO BE ON CAMERA.

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       Q      AT SOME POINT DID YOU FIND OUT THAT CAMERON

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BROWN'S WIFE WAS NOT LAUREN'S MOTHER?

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       A      AT SOME POINT I DID.

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       Q      AND HOW DID YOU FIND THAT OUT?

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       A      WHEN I ASKED FOR HIS NAME AND LAUREN'S FULL

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NAME, I NOTICED THAT HER -- LAUREN'S LAST NAME WAS

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DIFFERENT THAN CAMERON BROWN'S NAME AND ASKED WHY, AND

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THEN I FOUND OUT.

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       Q      SO THAT WAS THE FIRST INDICATION THAT YOU

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HAD THAT HIS WIFE WAS NOT LAUREN'S MOTHER, CORRECT?

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       A      CORRECT.

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       Q      DID CAMERON BROWN INDICATE TO YOU THAT HE

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HAD TRIED TO PERFORM ANY TYPE OF RESCUE MANEUVERS ON

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LAUREN?

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       A      YES, HE SAID HE TRIED TO PERFORM C.P.R.

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       Q      AND HOW DID THAT TOPIC COME UP?

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       A      THAT TOPIC CAME UP ACTUALLY AS WE WENT OVER

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WHAT HAD HAPPENED, HIS ACTIONS FROM THE TIME THAT HE --

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ACTUALLY LEADING UP TO THE TIME WHERE SHE LEFT THE CLIFF

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AND AFTER HE REALIZED SHE WAS AT THE BOTTOM OF THE CLIFF.

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WE GO OVER EVERYBODY'S ACTIONS.

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              AND DURING THAT TIME HE HAD SAID THAT AFTER

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HE HAD REMOVED HER FROM THE WATER THAT HE ATTEMPTED

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C.P.R., AND THEN HE ASKED IF HE HAD BLOOD IN HIS MUSTACHE

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AND GOATEE.

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       Q      SO HE WANTED YOU TO CHECK TO SEE IF HE HAD

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ANY BLOOD IN HIS MUSTACHE AND GOATEE?

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       A      YES.

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       Q      DID YOU SEE ANY?

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       A      NO.

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       Q      DID YOU SEE ANY BLOOD ON CAMERON BROWN'S

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CLOTHING?

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       A      YES.  HE HAD A LARGE CIRCLE OF BLOOD ON THE

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BACK OF HIS SHIRT.  AND THEN THAT WAS THE MAJOR BLOOD

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THAT I NOTICED.

4

       Q      DID YOU NOTICE --

5

              LET ME ASK IT THIS WAY:  HE TOLD YOU THAT

6

HE WENT INTO THE WATER AND ACTUALLY RETRIEVED LAUREN'S

7

BODY?

8

       A      HE SAID HE DID.

9

       Q      DID YOU NOTICE ANYTHING UNUSUAL ABOUT HIS

10

CLOTHING WITH REGARD TO WHAT HE HAD TOLD YOU?

11

       A      YES.  HIS SHOES WERE WET.  AND HIS CLOTHES,

12

HE WAS WEARING SHORTS AND A T-SHIRT, THEY WERE DRY.

13

       Q      DID YOU ASK CAMERON BROWN ABOUT THAT?

14

       A      YES, I DID.  HE SAID THAT AFTER HE LEFT THE

15

NUDE BEACH AND WALKED TO THE OTHER SIDE, AROUND TO WHERE

16

LAUREN'S BODY WAS, HE TOOK OFF HIS CLOTHES, HE STRIPPED

17

TO HIS UNDERWEAR, SAT HIS CLOTHES ASIDE, LEFT HIS BOOTS

18

ON AND THEN HE ENTERED THE WATER TO RETRIEVE LAUREN.  AND

19

THEN HE SAT HER -- ONCE HE PICKED HER UP OUT OF THE

20

WATER, HE SET HER ON THE GROUND AND THEN HE TOOK HIS WET

21

UNDERWEAR OFF AND PUT HIS CLOTHES, HIS DRY CLOTHES, BACK

22

ON.

23

       Q      AND DID HE TELL YOU HOW IT WAS THAT HE

24

CARRIED LAUREN'S BODY BACK TO THE ARCHERY RANGE?

25

       A      HE AT FIRST HAD PUT HER OVER HIS SHOULDER,

26

WHICH IS WHERE THE BLOOD HAD COME FROM, KIND OF LIKE, I

27

CALL IT, SACK OF POTATOES.  I'M NOT SURE WHAT ELSE IT

28

WOULD BE CALLED.  AND THAT IS HOW THE BLOOD WAS ON HIS

64

1

SHIRT.  AT SOME POINT HE HAD CHANGED HER TO A CRADLE

2

POSITION, BUT I BELIEVE THAT WAS AS HE SAT HER ON THE

3

TABLE.

4

       Q      AFTER CAMERON BROWN GAVE YOU THIS

5

INFORMATION ABOUT WHAT HAD HAPPENED, DID HE LEAVE WITH

6

ANOTHER DEPUTY TO GO DOWN TO THE BASE OF THE CLIFF?

7

       A      HE WENT WITH MY SERGEANT AT SOME POINT.

8

       Q      AND WHAT WAS YOUR SERGEANT'S NAME?

9

       A      SERGEANT ERICKSON.  I BELIEVE RICH

10

ERICKSON.

11

       Q      WHEN MR. BROWN AND SERGEANT ERICKSON WENT

12

TOWARDS THE CLIFF, WHERE DID YOU GO?

13

       A      I STAYED WITH LAUREN.

14

       Q      AFTER SOME PERIOD OF TIME DID CAMERON BROWN

15

COME BACK UP TO THE AREA WHERE YOU WERE?

16

       A      YES, HE DID.

17

       Q      WAS LAUREN'S BODY STILL ON THE TABLE?

18

       A      YES, IT WAS.

19

       Q      WAS IT COVERED WITH ANYTHING?

20

       A      IT WAS COVERED WITH A, I BELIEVE IT WAS,

21

PAPER; BUT IT WAS SOME SORT OF BLANKET THAT THE

22

PARAMEDICS HAD LEFT.

23

       Q      AND WERE YOU ASSIGNED TO STAY WITH CAMERON

24

BROWN AND WITH LAUREN UNTIL THE HOMICIDE DETECTIVES

25

ARRIVED?

26

       A      YES, I WAS.

27

       Q      WHERE DID YOU AND CAMERON BROWN WAIT FOR

28

THE HOMICIDE DETECTIVES?

65

1

       A      IN THE PICNIC AREA WITH LAUREN.

2

       Q      ABOUT HOW FAR FROM LAUREN'S BODY WAS IT

3

THAT CAMERON BROWN WAITED FOR THE HOMICIDE DETECTIVES?

4

       A      HE SAT AT AN ADJOINING TABLE, APPROXIMATELY

5

THREE FEET AWAY.

6

       Q      DID HE EVER MAKE ANY ATTEMPT TO GO OVER TO

7

LAUREN, TO REMOVE THE SHEET, TO DO ANYTHING TO GET CLOSE

8

TO HER?

9

       A      NO.

10

       Q      CAN YOU DESCRIBE FOR US CAMERON BROWN'S

11

DEMEANOR AS YOU WERE WAITING FOR THE HOMICIDE DETECTIVES?

12

       A      THE BEST WAY TO DESCRIBE HIS DEMEANOR WAS

13

MATTER OF FACTLY, NOT -- FOR THE MOST PART HE WOULD JUST

14

SPEAK TO ME ABOUT VARIOUS THINGS, AND IN JUST A

15

MATTER-OF-FACT TONE OF VOICE.  MAYBE TWO OR THREE TIMES

16

HE WOULD -- HE WOULD APPEAR TO BE SOBBING, BUT THEN IT

17

WOULD QUICKLY -- THEN HE WOULD STOP ALL OF A SUDDEN, AND

18

THEN HE WOULD TALK ABOUT SOMETHING ELSE.

19

              BUT, AS I SAID, WE WERE THERE FOR --

20

ACTUALLY WE WERE THERE FOR QUITE SOME TIME BEFORE

21

HOMICIDE ARRIVED; AND HE CRIED OR SOBBED MAYBE TWO TIMES,

22

POSSIBLY THREE.

23

       Q      DO YOU REMEMBER ABOUT HOW LONG IT WAS THAT

24

YOU WAITED?  WOULD IT HAVE BEEN A COUPLE OF HOURS AT

25

LEAST?

26

       A      IT WAS AT LEAST A COUPLE OF HOURS.  SHE WAS

27

PRONOUNCED, I THINK, AROUND NEAR 3:30 AND HOMICIDE DIDN'T

28

ARRIVE UNTIL 6:30.

66

1

       Q      DURING THE TIME THAT YOU WERE SITTING AT

2

THE TABLES, DID CAMERON BROWN PROVIDE YOU WITH MORE

3

DETAILS OF WHAT HE CLAIMED HAPPENED?

4

       A      HE DID.

5

       Q      AND CAN YOU TELL US WHAT ADDITIONAL DETAILS

6

HE GAVE YOU?

7

       A      HE SAID THAT HE AND LAUREN -- INITIALLY

8

THEY WENT TO A PLAYGROUND AT ABALONE COVE, WHICH IS WEST

9

OF OUR LOCATION, ON THE OTHER SIDE OF PORTUGUESE POINT.

10

IT IS KIND OF HARD FOR ME TO DESCRIBE WITHOUT A MAP.  BUT

11

IT'S IN THE ABALONE COVE AREA, WHICH ACTUALLY LEADS TO

12

SOME TIDE POOLS.  THERE IS A PLAYGROUND THERE, AND A

13

PRESCHOOL IS FOR SOME REASON THERE.  AND THEY WERE THERE

14

FOR A WHILE.  LAUREN PLAYED ON SOME OF THE PLAYGROUND

15

EQUIPMENT, SWINGING, I BELIEVE, AND THE SLIDE AND THAT

16

SORT OF THING.  AND AT SOME POINT THEY DECIDED TO GO FOR

17

A HIKE, SO THEY HIKED FROM ABALONE COVE TO INSPIRATION

18

POINT, WHERE THEY WALKED OUT TO INSPIRATION POINT.  HE

19

SAT ON A ROCK WHILE SHE THREW SMALLER ROCKS OFF OF THE

20

CLIFF BEFORE IT HAPPENED.

21

       Q      AND YOU SAID THAT HE POINTED -- HE ACTUALLY

22

POINTED TO A BUSH WHICH WE CAN SEE IN EXHIBIT NO. 5,

23

PHOTO C AND D, UP ON THE TOP OF INSPIRATION POINT AND

24

SAID THAT WAS THE AREA THAT HE WAS; IS THAT CORRECT?

25

       A      CORRECT.

26

       Q      IN ADDITION TO POINTING TO THE BUSH, DID HE

27

DESCRIBE THE AREA TO YOU AT ALL?

28

       A      HE SAID THAT THERE WAS A LARGE ROCK THAT HE

67

1

WAS SEATED ON -- AND THEN, AT THE TIME, IT DIDN'T MEAN AS

2

MUCH TO ME -- BUT THAT LAUREN WAS A LITTLE CLOSER TO THE

3

EDGE OF THE CLIFF AND SHE WAS THROWING ROCKS FROM THERE.

4

              I CAN GIVE YOU A BETTER DESCRIPTION.  I

5

HAVE BEEN THERE SINCE THAT TIME, OBVIOUSLY, SO I AM

6

FAMILIAR WITH WHAT HE WAS REFERRING TO.

7

       Q      SURE, WHY DON'T YOU GO AHEAD AND DESCRIBE

8

IT FOR US.

9

       A      UP AT THE TOP OF INSPIRATION POINT, WHERE

10

THE BUSH IS, THERE IS -- IT IS NOT A TALL ROCK, BUT IT'S

11

A BOULDER THAT'S SORT OF -- IT ALMOST SEEMS LIKE SOMEBODY

12

TURNED IT INTO A SEAT.  IT'S PRETTY FLAT ON TOP, SO YOU

13

CAN SIT THERE.

14

              I KIND OF HAVE TO USE A LITTLE HAND

15

GESTURE.  BUT THE BUSH AND THE ROCK WOULD BE UP HERE AT

16

THE TOP.  WELL, THE CLIFF GOES DOWN JUST A LITTLE BIT

17

MORE; AND FROM MY UNDERSTANDING, LAUREN WAS A LITTLE

18

FURTHER DOWN ON THE CLIFF, AND THAT'S WHERE SHE WAS

19

THROWING THE ROCKS, ACCORDING TO THE DESCRIPTION THAT

20

CAMERON BROWN GAVE ME.

21

       Q      SO THE ROCK AREA THAT YOU WERE DESCRIBING

22

WITH YOUR HANDS IS MORE OF A FLATTER-TYPE AREA?

23

       A      IT IS MORE OF A FLATTER-TYPE AREA.

24

       Q      AND THEN WITH YOUR OTHER HAND YOU ARE

25

SHOWING THAT THE CLIFF ACTUALLY SEEMS TO ANGLE DOWNWARDS

26

MORE --

27

       A      IT ANGLES DOWN.

28

       Q      -- TOWARDS THE OCEAN?

68

1

       A      CORRECT.

2

       Q      AND CAMERON BROWN TOLD YOU THAT LAUREN WAS

3

FURTHER DOWN THAT ANGLED PORTION WHEN HE CLAIMS SHE FELL?

4

       A      YES.

5

       MS. PRIVER:  THE RECORD SHOULD REFLECT IN TERMS OF

6

THE HAND GESTURES SHE IS MAKING, SHE IS HOLDING ONE HAND

7

OUT FLAT, WITH THE FINGERS TOGETHER, BUT MAKING A FLAT

8

SURFACE WITH HER HAND.  SHE PUT THE FINGERTIPS OF HER

9

OTHER HAND AGAINST IT AND ANGLED THAT HAND DOWN SO AS TO

10

CREATE A SLOPE.

11

       THE WITNESS:  THANK YOU.

12

       Q      BY MR. HUM:  DID CAMERON BROWN VOLUNTEER

13

ANY INFORMATION ABOUT ANY DOCUMENTATION THAT HE HAD TO

14

SHOW THAT LAUREN WAS IN ANY PARTICULAR MOOD?

15

       A      HE SAID HE HAD PICTURES AND SHOWED ME A

16

DISPOSABLE CAMERA.

17

       Q      AND HAD YOU ASKED HIM IF HE HAD ANY TYPE OF

18

DOCUMENTATION OR CAMERA OR PICTURES?

19

       A      TO BE HONEST, I WOULDN'T HAVE ASKED HIM.

20

CONSIDERING THE SITUATION, TO BE HONEST, EVEN FOUR YEARS

21

LATER I WOULDN'T HAVE ASKED.

22

       Q      BUT HE VOLUNTEERED --

23

       A      HE VOLUNTEERED AND SAID HE HAD PICTURES TO

24

SHOW THAT EVERYTHING WAS FINE.

25

       Q      DID CAMERON BROWN ENGAGE IN ANY OTHER

26

CONVERSATION THAT STRUCK YOU AS UNUSUAL, GIVEN THE FACT

27

THAT YOU WERE ABOUT THREE FEET FROM HIS DAUGHTER'S BODY?

28

       A      WE TALKED ABOUT A VARIETY OF THINGS, BUT

69

1

THE THING THAT HAS STOOD OUT TO ME THE MOST IS AT THAT

2

TIME IT WAS -- WE STILL DIDN'T KNOW WHO THE PRESIDENT

3

WAS.  IT WAS THE BUSH/GORE ELECTION TIME, AND IT WAS A

4

DAY OR TWO AFTER THE ELECTION, AND SO WE WERE ALL WAITING

5

TO HEAR WHO THE PRESIDENT WAS.  AND HE ASKED ME IF I HAD

6

HEARD WHO THE PRESIDENT WAS.  AND THAT STRUCK ME AS VERY

7

ODD SINCE I WAS AT THE TIME -- ACTUALLY ALMOST THE ENTIRE

8

TIME I SAT ON THE SEAT OF THE PICNIC TABLE WHERE LAUREN'S

9

BODY WAS.

10

       Q      DID MR. BROWN COMPLAIN ABOUT ANYTHING

11

DURING THE PERIOD OF TIME YOU WERE WAITING THERE?

12

       A      HE CONTINUALLY COMPLAINED ABOUT HIS BOOTS

13

BEING WET.  AND THEY WERE WET.

14

       Q      DID THAT STRIKE YOU AS UNUSUAL, GIVEN THE

15

SITUATION?

16

       A      VERY UNUSUAL.

17

       Q      NOW, DID YOU REMAIN WITH LAUREN AND WITH

18

MR. BROWN UNTIL THE HOMICIDE DETECTIVES ARRIVED AT ABOUT

19

6:20 IN THE EVENING?

20

       A      YES.

21

       Q      AND AFTER THAT WERE YOU DETAILED TO GO OUT

22

TO THE ROCKY AREA AT THE BASE OF THE POINT TO WATCH OVER

23

ANY POTENTIAL EVIDENCE DOWN THERE UNTIL THE HOMICIDE

24

DETECTIVES GOT THERE?

25

       A      YES.

26

       Q      THANK YOU, DEPUTY BROTHERS.

27

       MS. PRIVER:  ANY QUESTIONS BY ANY MEMBER OF THE

28

GRAND JURY?

70

1

              (PAUSE IN THE PROCEEDINGS.)

2

3

       Q      BY MR. HUM:  DEPUTY BROTHERS, A COUPLE OF

4

ADDITIONAL QUESTIONS.

5

              DID CAMERON BROWN INDICATE TO YOU THAT HE

6

TRIED TO STOP LAUREN WHEN SHE WAS THROWING ROCKS?

7

       A      NO.  HIS INITIAL STATEMENT WAS THAT HE WAS

8

SITTING ON THE ROCKS AND THEN WHILE -- ON THE ROCK WHILE

9

SHE WAS THROWING ROCKS AND SUDDENLY SHE WAS GONE.

10

       Q      DID HE INDICATE TO YOU THAT HE ACTUALLY LET

11

HER CONTINUE TO THROW ROCKS FROM THAT AREA, DOWN CLOSER

12

TO THE EDGE, WHILE HE SAT ON THE ROCK?

13

       A      DO YOU MEAN DID HE REPRIMAND HER FOR DOING

14

THAT?

15

       Q      RIGHT.  DID HE INDICATE TO YOU --

16

       A      NO.

17

       Q      -- THAT HE TRIED TO STOP HER IN ANY WAY?

18

       A      NO.

19

       Q      AND, DEPUTY BROTHERS, OBVIOUSLY THE

20

INVESTIGATION WAS FURTHER CONDUCTED BY HOMICIDE

21

DETECTIVES, CORRECT?

22

       A      CORRECT.

23

       Q      AND THAT WOULD GENERALLY INCLUDE, TO YOUR

24

KNOWLEDGE, TAKING MEASUREMENTS OF DISTANCES AND THINGS OF

25

THAT NATURE?

26

       A      CORRECT.

27

       Q      DID YOU TAKE ANY MEASUREMENTS OF DISTANCES

28

BETWEEN, SAY, ABALONE COVE AND INSPIRATION POINT?

71

1

       A      NO, I DID NOT.

2

       Q      BUT HOMICIDE DETECTIVES WOULD HAVE DONE

3

THAT?

4

       A      ABSOLUTELY.  AND I KNOW THAT THEY WALKED

5

THE TRAIL SEVERAL TIMES SINCE THE INITIAL INCIDENT; AND,

6

TO MY KNOWLEDGE, THEY MEASURED IT OUT.

7

       Q      DO YOU KNOW AN APPROXIMATE DISTANCE AT THIS

8

POINT IN TIME, OR WOULD WE NEED TO WAIT FOR THE HOMICIDE

9

DETECTIVE TO TELL US?

10

       A      DEFINITELY MORE THAN A MILE.  BUT ANY MORE

11

THAN THAT, HONESTLY --

12

              I WALKED IT WITH HOMICIDE MORE THAN ONCE,

13

AND I HAD DIFFICULTY.  I AM NOT IN THE GREATEST SHAPE.  I

14

HAD DIFFICULTY WITH IT.  BUT I KNOW THEY TOOK

15

MEASUREMENTS.

16

       Q      OKAY.

17

       MS. PRIVER:  FOLLOW-UP QUESTIONS?

18

19

              (PAUSE IN THE PROCEEDINGS.)

20

21

       Q      BY MR. HUM:  DEPUTY BROTHERS, DO YOU

22

RECALL -- I THINK YOU TOLD US THAT CAMERON BROWN

23

INDICATED HE LEFT INSPIRATION POINT AND WENT DOWN TO THE

24

NUDE BEACH TO GET A CELLPHONE; IS THAT CORRECT?

25

       A      CORRECT.

26

       Q      AND THEN HE WENT BACK OVER TO THE ARCHERY

27

RANGE SIDE OF INSPIRATION POINT TO GO AROUND TO LAUREN'S

28

BODY?

72

1

       A      CORRECT.

2

       Q      DID HE INDICATE TO YOU WHETHER HE WALKED

3

ALL THE WAY AROUND THE CLIFF OR WHETHER HE WENT OVER THE

4

CLIFF, THAT BEING INSPIRATION POINT; OR DID HE INDICATE

5

HOW HE DID THAT?

6

       A      HE COULDN'T ACCESS WHERE HER BODY WAS FROM

7

THE NUDE BEACH, SO HE HAD TO WALK -- TAKE THE TRAIL BACK

8

UP TO THE TOP, WHICH IS NOT THE POINT PART OF INSPIRATION

9

POINT, BUT MORE A BASE OF INSPIRATION POINT CLOSER TO

10

PALOS VERDES DRIVE SOUTH.  AND SO HE HAD TO TAKE THE

11

TRAIL BACK UP FROM THE NUDE BEACH, CROSS THE TOP OF THE

12

BASE OF INSPIRATION POINT AND THEN TAKE THE TRAIL BACK

13

DOWN TO THE ARCHERY RANGE AND AROUND THE COVE.  THAT WAS

14

DUE TO THE FACT THAT IT'S A ROCKY COVE AREA AND THERE ARE

15

SEVERAL PLACES -- MY EXPERIENCE WORKING ON THE PENINSULA,

16

THERE ARE SEVERAL PLACES YOU CANNOT JUST FOLLOW THE

17

PENINSULA ALL THE WAY FROM SAN PEDRO TO TORRANCE.  THERE

18

ARE A LOT OF PLACES THAT JUST ARE NOT ACCESSIBLE DUE TO

19

THE FACT THAT THE TIDE POOLS ARE AT VARYING DEPTHS AND IT

20

IS JUST NOT ACCESSIBLE.

21

       Q      AND SO DID HE INDICATE TO YOU THAT HE

22

ACTUALLY TOOK THE TRAIL BACK UP TO THE TOP OF INSPIRATION

23

POINT, WHICH WOULD HAVE BEEN CLOSER TO THE ROAD, AND THEN

24

OVER THE TOP?

25

              DO YOU UNDERSTAND MY QUESTION?

26

       A      I DO.

27

              THERE ARE A COUPLE OF DIFFERENT PATHWAYS.

28

YOU CAN TAKE THE PATH FROM THE NUDE BEACH DIRECTLY UP TO

73

1

THE ROAD.  AND I AM NOT POSITIVE IF HE INDICATED THAT HE

2

WALKED DIRECTLY ALONG PALOS VERDES DRIVE SOUTH OR IF -- I

3

BELIEVE THERE IS A SMALLER WALKING PATH MAYBE 20 YARDS

4

FROM PALOS VERDES DRIVE SOUTH, TOWARDS -- HOLD ON.  LET

5

ME PICTURE THE AREA REAL QUICK.

6

              I DON'T REMEMBER HIS EXACT WORDS, TO BE

7

HONEST.  I KNOW THAT FROM THE NUDE BEACH, THOUGH, THAT

8

PATH ON THE BASE OF INSPIRATION POINT BEFORE YOU GO OUT

9

TO THE POINT, YOU NEED TO WALK BACK TO PALOS VERDES DRIVE

10

SOUTH TO ACCESS THE ARCHERY RANGE.  THAT TRAIL IS

11

ACTUALLY A DRIVEWAY THAT YOU HAVE TO WALK DOWN TO GET TO

12

THE ARCHERY RANGE.

13

              SO I DON'T BELIEVE HE SPECIFICALLY STATED

14

THAT HE WENT ON ANY UNMARKED PATH TO THE ARCHERY RANGE.

15

              I HOPE THAT HELPS.

16

       MS. PRIVER:  ALL RIGHT, MA'AM.  THERE AREN'T ANY

17

ADDITIONAL QUESTIONS.

18

              BEFORE YOU GO, OUR FOREPERSON, THE

19

GENTLEMAN SITTING NEXT TO YOU, IS GOING TO GIVE YOU AN

20

ADMONITION REGARDING THE CONFIDENTIALITY OF THE GRAND

21

JURY.

22

              MR. FOREPERSON.

23

       THE FOREPERSON:  YOU ARE ADMONISHED NOT TO REVEAL

24

TO ANY PERSON, EXCEPT AS DIRECTED BY THE COURT, WHAT

25

QUESTIONS WERE ASKED OR WHAT RESPONSES WERE GIVEN OR ANY

26

OTHER MATTERS CONCERNING THE NATURE OR SUBJECT OF THE

27

GRAND JURY'S INVESTIGATION WHICH YOU LEARNED DURING YOUR

28

APPEARANCE BEFORE THE GRAND JURY UNLESS AND UNTIL SUCH

74

1

TIME AS THE TRANSCRIPT OF THIS GRAND JURY PROCEEDING IS

2

MADE PUBLIC.

3

              I WISH TO ADVISE YOU THAT A VIOLATION OF

4

THIS ORDER CAN BE THE BASIS OF A CONTEMPT OF COURT CHARGE

5

AGAINST YOU.

6

              DO YOU UNDERSTAND THIS ADMONITION?

7

       THE WITNESS:  YES, I DO.

8

       MS. PRIVER:  THANK YOU, MA'AM.

9

              YOU ARE EXCUSED.

10

       THE WITNESS:  THANK YOU.

11

12

              (THE WITNESS EXITED THE GRAND JURY

13

              HEARING ROOM.)

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28