Video Deposition

Case: 25CI1:14-cv-00334-TTG Document #: 115-18 Filed: 08/21/2015 Page 1 of 15

Page 1 Page 3
1 IN THE CIRCUIT COURT OF THE FIRST JUDICIAL DISTRICT 1 INDEX
OF HINDS COUNTY, MISSISSIPPI
2 2 PAGE
3 EARL LADNER PLAINTIFF 3
Appearances.................................. 1
4 4
VS. CAUSE NO.: 14-334
5 5 Index........................................ 3
6 JASBIR BATTH D/B/A QUICK STOP; 6
JASBIR BATTH, INDIVIDUALLY Certificate of Deponent...................... 57
7 AND JOHN DOES #1-5 DEFENDANTS 7
8 **************************************************** 8 Certificate of Court Reporter................ 56
VIDEO DEPOSITION OF GURSHARAN BATTH
9 **************************************************** 9
APPEARANCES NOTED HEREIN EXAMINATIONS
10 10
DATE: April 8, 2015 PAGE
11 PLACE: Copeland, Cook, Taylor and Bush, P.A. 11
1076 Highland Colony Parkway, Suite 1400
12 Concourse 600, Suite 100 12 Examination By Mr. Ogden..................... 4
Ridgeland, Mississippi 39157
13 TIME: 10:33 a.m. 13
Examination By Mr. Russell................... 53
14 14
15 15 Further Examination By Mr. Ogden............. 54
16 16
17 17 EXHIBITS
18 18 PAGE
19 19
(No exhibits)................................
20 20
21 21
REPORTED BY: JULIE BROWN, CSR
22 ____________________________________________________ 22
23 AW Reporting 23
338 Indian Gate Circle
24 Ridgeland, Mississippi 39157 24
601-898-9990
25 www.awreporting.com 25

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1 APPEARANCES:
1 VIDEOGRAPHER: Good morning. This is the
2
J. ASHLEY OGDEN, ESQ. 2 videotaped deposition of Mr. Sonny Gursharan Batth,
3 TYLER ROYALS, ESQ.
Ogden & Associates, PLLC 3 taken by counsel in the matter of Earl Ladner versus
4 500 East Capitol Street, Suite 3
Jackson, Mississippi 39201 4 Jasbir Batth, et al. Today's date is April 8, 2015.
5 E-mail:ashleyogden@aol.com
5 The time is now 10:31.
6 6 Counsel may now introduce themselves on
COUNSEL FOR PLAINTIFF
7 7 record.
8 DALE G. RUSSELL, ESQ. 8 MR. OGDEN: Ashley Ogden and Tyler Royals
ADAM VINCENT GRIFFIN, ESQ.
9 Copeland, Cook, Taylor & Bush, P.A. 9 for Earl Ladner.
Post Office Box 6020
10 Ridgeland, Mississippi 39158 10 MR. RUSSELL: Dale Russell for the
E-mail:drussell@cctb.com
11 11 defendant, Jasbir Batth, D/B/A Quick Stop.
12 COUNSEL FOR DEFENDANT 12 MR. GRIFFIN: Adam Griffin for defendant,
13 13 Jasbir Batth, D/B/A Quick Stop.
14
ALSO PRESENT: Matthew Magee, Videographer
14 VIDEOGRAPHER: Court reporter may now
15 15 swear in the witness.
16 16 GURSHARAN BATTH,
17 17 having been first duly sworn, was examined and
18 18 testified as follows:
19 19 EXAMINATION BY MR. OGDEN:
20 20 Q. Tell me your full name.
21 21 A. Gursharan Singh Batth.
22 ____________________________________________________ 22 Q. And how old are you?
23 AW Reporting 23 A. 28.
338 Indian Gate Circle
24
25
Ridgeland, Mississippi 39157
601-898-9990
www.awreporting.com
24
25
Q. Where do you live?
A. Clinton, Mississippi. R
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1 Q. Do you live with your mother and father? 1 sisters over the age of 18 that live in Hinds
2 A. Yes. 2 County?
3 Q. Your mother is Radjwinder? 3 A. Yes.
4 A. Yes. 4 Q. What are their names?
5 Q. And your father is Jasbir Batth? 5 A. Simran Batth.
6 A. Yes. 6 Q. Okay. Where does he work?
7 Q. And they are the owners of the Quick Stop 7 A. No, it's a she.
8 on Meadowbrook Road? 8 Q. Where does she work?
9 A. Yes. 9 A. She's in medical, Mississippi University.
10 Q. Do you have any -- 10 Q. All right. What does she do there?
11 MR. RUSSELL: McDowell. 11 A. I believe some kind of researcher on the
12 BY MR. OGDEN: 12 cancer or something.
13 Q. I'm sorry. They are the owners of the 13 Q. Okay. Do you have any cousins or close
14 Quick Stop on McDowell Road? 14 relatives that live in Hinds County?
15 A. Yes. 15 A. No.
16 Q. Do you have any ownership interest in 16 Q. Okay. I want to talk to you a little bit
17 that property? 17 about August 5, 2013 when Earl Ladner was attacked
18 A. No. 18 at the convenience store. Tell me what time you got
19 Q. You just are an employee of the property? 19 there that day.
20 A. Yes. 20 A. I got there around 12 o'clock.
21 Q. Okay. Were you born in America? 21 Q. Okay. Do you know about what time he was
22 A. No. 22 attacked?
23 Q. Where were you born? 23 A. I think it was afternoon, like 1:00,
24 A. India. 24 2:00. After 2:00, something like that.
25 Q. All right. When did you move to America, 25 Q. Were you there at the time that he got

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1 what year? 1 attacked?

2 A. '99, '98. 2 A. No.
3 Q. Have you applied for American 3 Q. All right. Tell me about that. Did you
4 citizenship? 4 come in that day and then leave?
5 A. Yes. 5 A. Yes. I came in that day and I left to
6 Q. Has it been approved? 6 grab something to eat and came back in a half an
7 A. Yes. My mom did. I didn't apply for it. 7 hour.
8 I wasn't 18. 8 Q. So while you were gone for lunch --
9 Q. Okay. Did you go to high school anywhere 9 A. Uh-huh (affirmative response).
10 in Hinds County? 10 Q. -- that's when he got attacked?
11 A. No, in California. 11 A. Yes.
12 Q. California. 12 Q. All right. If you would, verify for me
13 What year did you move to Mississippi? 13 the names of the employees who were running the
14 A. 2005. 14 store while you were gone?
15 Q. And where did y'all live in California? 15 A. Mukesh Pandey and Aman Singh Gill.
16 A. Modesto, California. 16 Q. What were their job duties? Do you know
17 Q. What did y'all do in Modesto, California 17 what they were supposed to be doing?
18 before you moved here to Mississippi? 18 A. Stocking, ringing up stuff, looking out,
19 A. My dad, he was a truck driver and I was 19 making sure everything was fine.
20 in high school. 20 Q. The date of the -- the time for the
21 Q. Are you married? 21 occurrence is 1407, that's military time, so I think
22 A. No. 22 that would be 12:07. Does that sound right to you?
23 Q. Do you have any children? 23 MR. GRIFFIN: 2:07.
24 A. No. 24 BY MR. OGDEN:
25 Q. All right. Do you have any brothers or 25 Q. 2:07?

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1 A. Yes. 1 A. This side right here.

2 Q. Does that sound -- so you're telling me 2 Q. So is it towards the front or towards the
3 around 2 o'clock you were not at the store? 3 back?
4 A. Yes. 4 A. Towards the front.
5 Q. Okay. Tell me when you got back to the 5 Q. If I put a square like that I'm going to
6 store what you were told by these two other 6 just call that the booth?
7 employees about what happened. 7 A. Sure.
8 A. They told me the guy got robbed and the 8 Q. Then you're telling me where you have
9 cops came and all that. And they showed me the 9 this "X," I do a circle, I'm going to write
10 video and stuff. 10 "Ladner"?
11 Q. Did they tell you that he got robbed out 11 A. Yes.
12 in the parking lot? 12 Q. Would you consider that on the front of
13 A. Yes. 13 the store, right on the corner, or over on the side?
14 Q. Where in the parking lot was he robbed? 14 A. Right on the corner maybe.
15 A. How do you want me to -- it's outside, I 15 Q. Okay. And my understanding was he had
16 mean. 16 come in his truck, parked his truck, went back to
17 Q. If I was to give you a piece of paper 17 his truck, and that's where he was attacked at his
18 could you draw a picture of the property with the 18 truck. Does that sound right to you?
19 parking lot and put an "X"? 19 A. Yeah, he never came in. He just pulled
20 A. Okay. (Witness complies.) Here's the 20 up and he was parked there. That's where he was
21 store and here's a parking lot too. Here's a 21 attacked at.
22 parking lot too. He got robbed right over here. 22 Q. Okay. Now, you understand that he came
23 MR. RUSSELL: Draw McDowell Road over 23 inside the store and purchased something and went
24 there so we'll have some perspective. 24 back out. Do you know that?
25 BY MR. OGDEN: 25 A. Yes.

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1 Q. All right. I tell you what. Let me do 1 Q. Okay. Do you know when he came to the
2 it like this. 2 store where the two employees were? Do you know if
3 A. How do you want it? 3 they were both behind the counter or in front of the
4 Q. No, you're okay. I'm just going to 4 counter, one's behind the counter, one was stocking?
5 make -- 5 Did she tell you?
6 MR. RUSSELL: We're not making fun of 6 A. When I got back they were both behind the
7 you, artistic abilities. 7 counter, but...
8 BY MR. OGDEN: 8 Q. Did they tell you at the time of the
9 Q. I'm going to make it bigger. 9 attack where they were?
10 And then you have some gas pumps like this. 10 A. They didn't really tell me where they
11 Okay? 11 were.
12 A. Yes. 12 Q. Where is the monitoring camera that you
13 Q. And this is your -- all right. That's a 13 have talked about earlier in Mr. Batth's deposition?
14 more generic version. So if you come out the front 14 A. In the booth.
15 door, if you're facing this door, was he over on the 15 Q. So inside the booth there's a monitoring
16 right side or the left side? 16 camera?
17 A. If you're facing outside towards McDowell 17 A. Yeah.
18 Road it's on the right side. Here's the street, Oak 18 Q. Well, we call it monitor. So if you're
19 Forest. 19 in the booth you can watch the monitor to see what's
20 Q. So let's do this: I'm trying to make it 20 going on in the parking lot, correct?
21 bigger. And I understand it's not to scale. I'm 21 A. Yes.
22 just trying to get a reference. 22 Q. Okay. What all did they tell you? Did
23 A. Okay. 23 they just say, "He got attacked outside"?
24 Q. So where inside the store is the booth 24 A. They just told me some guy was standing
25 where you would be working at? Is it on this -- 25 outside and they robbed him or something.

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1 Q. Okay. 1 A. They usually -- they usually go on.

2 A. That's what he was saying. 2 Q. You've never had a problem running people
3 Q. Did they tell you how long this guy had 3 off before?
4 been outside panhandling or asking for money? 4 A. No.
5 A. No. 5 Q. Have you -- I know you had mentioned
6 Q. Okay. Did they tell you that the guy was 6 earlier that you guys keep guns on you at the
7 outside panhandling and asking for money and had 7 property.
8 approached Mr. Ladner before he came in the store? 8 A. Uh-huh (affirmative response).
9 A. No, because I -- when I left there was 9 Q. Your testimony earlier, or the testimony
10 nobody there. 10 earlier of Mr. Batth, was that you keep a gun on you
11 Q. Okay. Did they tell you whether or not 11 at the property, correct?
12 they had run that guy off earlier that day or had 12 A. Yes.
13 seen him out there earlier that day and asked him to 13 Q. And you leave it at the property, so when
14 leave? 14 you go off the property you leave it at the
15 A. It could be a different person. I'm not 15 property?
16 sure if it was the same person or not. 16 A. When I go out like in the car I'll leave
17 Q. Well, just tell me what you know. Do you 17 it at the property. But when I'm there, I mean, I
18 know if that guy was there earlier that day and he 18 usually have it on me, watching everything, all the
19 had been run off or not? 19 customers are safe and stuff.
20 A. Not that guy, I mean. 20 Q. Okay. And then also Mr. Batth keeps a
21 Q. Okay. Have you had occurrences where 21 gun on him at the property too, correct?
22 you've had to run off people from outside of the 22 A. Yes.
23 front of the store before? 23 Q. Do any other employees keep a gun on them
24 A. Every once in a while. 24 that you know of?
25 Q. Tell me about that. Give me an example. 25 A. They don't tell me. I haven't seen any.

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1 Tell me about the occurrence. 1 Q. Okay. Does your mother, Ms. Batth, when
2 A. Like, "Can you hand me a cigarette" or 2 she works at the store, does she carry a gun on her?
3 something. "Hand me a cigarette," something like 3 A. No.
4 that. 4 Q. Okay. Tell me a little bit about the
5 We tell him to leave. "You can't be 5 loitering issue. When these guys are loitering do
6 panhandling" or something "over here." 6 they loiter inside the store or outside of the
7 Q. Do they ever ask for money? Do they ask 7 store?
8 for alcohol, ask for cigarettes, or everything? 8 MR. RUSSELL: Object to the form.
9 A. I have no clue. I mean, probably money 9 A. Outside and -- but it's hardly every once
10 and cigarettes maybe, something like that. 10 in a while. It's not like a...
11 Q. Well, now, I'm asking you specifically 11 BY MR. OGDEN:
12 about what you remember. Have you had to run 12 Q. Okay. And when they do it do they loiter
13 anybody off yourself? 13 on the front where the gas receptacles are or do
14 A. On that day? 14 they do it on the sides of the store or both?
15 Q. No, no, no, any day before. 15 A. It could be anywhere, I mean. I have no
16 A. Yes, I probably did. 16 clue. I don't remember.
17 Q. So give me an example of when you had to 17 Q. Where are the loitering signs on the
18 run somebody off. Tell me about it. Do you just go 18 store?
19 outside and say, "Hey, you can't be out here 19 A. Front of the store. I mean, front of the
20 panhandling. Go somewhere else"? 20 door, as soon as you walk in.
21 A. "You can't be hanging out around the 21 Q. Okay. Are the loitering signs on the
22 store. You have to go somewhere else." 22 outside of the store?
23 Q. When you tell them to move on down the 23 A. It's on the window.
24 line do they usually comply or do they try to fight 24 Q. So they're --
25 you or what? 25 A. Probably like over here.

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1 Q. -- on the inside of the window, but they 1 A. Usually nothing. I mean, there was
2 face out? 2 probably like four cameras or something like that.
3 A. Yes. 3 Q. Okay. After he was shot, my
4 Q. So if you would, just give me a little 4 understanding from Mr. Batth is that in 2006 they
5 "X" where you think the loitering signs were back in 5 changed security or upgraded security, correct?
6 2013. 6 A. Yes.
7 A. Probably say right here. I'm not really 7 Q. Tell me as best you can remember what
8 sure, but I'm pretty sure here or here, so... 8 security was added after the employee was shot in
9 Q. Okay. I'm going to write "Loiterer 9 2006?
10 signs." 10 A. Bulletproof glass, burglar bars, cameras,
11 What is your understanding of what you're 11 "No Loitering" signs.
12 supposed to do when there's a loiterer? Have you 12 Q. How about the -- I noticed on the list
13 had any training on how to remove them or you just 13 there was that panic button. Was that added then?
14 understand that you don't want them hanging out? 14 A. Yes. It was, yes.
15 A. I don't want them hanging out. I just 15 Q. They also do the magnetic locking of the
16 usually tell them to go on, move. 16 doors.
17 Q. So earlier when you talked to me about 17 A. Yes.
18 having some training -- 18 Q. Was that added too?
19 A. Yeah. 19 A. Yes.
20 Q. -- was that included in it, loitering 20 Q. To get into the store back in 2013 did
21 training? 21 you have to be buzzed in or is the door opened
22 A. I mean, that's the same thing, I mean. I 22 freely?
23 had a training, but we usually tell them, "Hey, come 23 A. It's opened freely.
24 on, man. You can't be hanging out." 24 Q. Okay. Now, after the 2006 upgrade of
25 Q. Did you pass the information on to the 25 security, did you all do anything else in 2007,

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1 other two men who were working that day? Did they 1 2008, 2009, 2010, 2011, or 2013?
2 know that they were supposed to run loiterers off? 2 A. I don't remember. We probably did, but I
3 A. Yes. 3 don't remember what kind.
4 Q. Okay. Did they understand that they were 4 Q. Okay. Tell me about the cameras. You've
5 allowed to go outside in the parking lot and run 5 got a 16-camera system. How many cameras are
6 loiterers off? 6 inside?
7 A. Yes. 7 A. Seven or eight.
8 Q. Okay. Were they authorized by you or 8 Q. And how many record outside?
9 Mr. Batth to run a loiterer off if they needed to 9 A. Half of them. About eight of them, I
10 even though you weren't there? 10 believe.
11 A. Yes. 11 Q. Okay.
12 Q. So they didn't have to have you there to 12 A. Six to eight.
13 ask you what to do and they didn't have to have 13 Q. The camera system records what's going on
14 Mr. Batth there to ask him what to do, they were 14 inside and outside the store, correct?
15 told what to do? 15 A. Yes.
16 A. Yes. 16 Q. Tell me a little bit about who monitors
17 Q. Okay. I went through a list of crimes 17 the camera system.
18 that had occurred on the property, and I want to ask 18 A. All the employees working there. There's
19 you about those. Back in 2006, there was a robbery 19 a monitor screen it goes off, I mean, two different
20 inside the store where a employee was shot. 20 channels.
21 A. Yes. 21 Q. If I was on that property back in August
22 Q. What do you know about that? 22 of 2013 and I wanted to watch Earl Ladner leave the
23 A. I mean, he was shot. 23 store and go to his car, did the cameras cover and
24 Q. Okay. Before he was shot, what type of 24 show the outside area where Earl Ladner parked his
25 security measures did you have in place? 25 car?

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1 A. Yes. 1 haven't heard anybody testify that there was anybody

2 Q. Did you ever watch the video of Earl 2 else in the store?
3 Ladner being attacked? 3 A. There was probably. I'm not sure. I
4 A. Yes. 4 mean, I'm not there at that time. I don't remember.
5 Q. What did it show? 5 Q. Okay. So let me see if I got this right.
6 A. Just saw some guy approached him and got 6 The way you have this set up is you have two
7 the money and walked off like it was nothing going 7 employees behind the counter, correct?
8 on. They were talking to each other. 8 A. Yes.
9 Q. Did it show the man striking Earl across 9 Q. Which allows one of them to take the
10 the head with the gun? 10 money and allows the other one to watch the
11 A. Not that I know of. 11 monitor --
12 Q. How good was the quality of that video? 12 A. Uh-huh (affirmative response).
13 Was it color, black-and-white? 13 Q. -- to make sure that what's going on in
14 A. Color, yeah. 14 the parking lot or in the store --
15 Q. Was it halfway decent quality or was it 15 A. They are not at the monitor the whole
16 grainy? 16 time. They can look outside. The screen is on
17 A. I mean, it's pretty decent. I mean, you 17 always. You can see what's going on.
18 can tell what's going on. 18 Q. Okay. Do you require those store
19 Q. Okay. 19 employees to watch the monitor to make sure that
20 A. You probably can't see the face, but -- 20 they are keeping an eye on what's going on outside?
21 clearly, but you know what's going on. 21 A. Yes.
22 Q. Did the employees who were working that 22 Q. Okay. The safety features on the
23 day tell you whether or not they saw the incident 23 property, as far as the bulletproof glass, is that
24 occur on the video? 24 just an encasing that goes around the front counter
25 A. Yeah, they seen it first. 25 where the money is?

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1 Q. Well, let me -- that was a bad question. 1 A. It goes all the way across, yeah.
2 At the time of the event, did any one of 2 Q. Okay. And I wasn't clear, Mr. Batth, I
3 the employees at the store see -- actually with 3 didn't understand him. Is there bulletproof glass
4 their own eyes see the attack? 4 across the front of the building or is it
5 A. No. 5 bulletproof glass just around the front and side of
6 Q. Do you know if either one of them were 6 the casing inside the store?
7 monitoring the video at the time of the attack so 7 A. It's front of the building also. I mean,
8 they could have seen what was going on? 8 like two glasses where the customer stands and stuff
9 A. I mean, it's on the monitor. I mean, if 9 there's bulletproof also. And where we stand
10 they are looking, working on them, they probably 10 there's a bulletproof glass also.
11 know what's going on. 11 Q. Okay. Did you all install those safety
12 Q. Were they supposed to be watching the 12 features with the understanding that a crime could
13 monitor to make sure that the customers in the 13 occur on the property and somebody could get shot?
14 parking lot were safe? 14 A. Yes. You can say it like that.
15 A. Take customers and watch, I mean. I 15 Q. Did you expect those safety features to
16 don't know what to say about that. 16 prevent somebody from getting shot or injured?
17 Q. Well, what are they supposed to do? Are 17 A. Yes, or break in.
18 they supposed to -- well, there's two people in the 18 MR. RUSSELL: Object to the form.
19 store, right? 19 BY MR. OGDEN:
20 A. Uh-huh (affirmative response). 20 Q. All right. How has the bulletproof glass
21 Q. So one of them can take the money while 21 worked as far as the safety feature? Has it worked?
22 the other one watches the monitor, correct? 22 A. Yes.
23 A. Yes. 23 Q. I think that Mr. Batth told me at one
24 Q. So assuming that there was nobody else in 24 point there was an incident where somebody shot at
25 the store at the time Mr. Ladner was attacked, and I 25 him, but he -- the bullet obviously didn't get to

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1 him because of the bulletproof glass; is that 1 Stop. She had bought a money order and paid her
2 correct? 2 light bill and an unidentified male in a white
3 A. Yeah, probably. It slowed it down. I 3 t-shirt robbed her in the parking lot?
4 mean, it hit the -- hit the wall outside -- I mean, 4 A. No.
5 inside the place. 5 Q. The lady's name was Rhonda Potter.
6 Q. I want to run through these reports real 6 A. No.
7 quick that I've got and see if any of these are 7 Q. I got a business burglary on January 3,
8 familiar to you. These were reports that were 8 2012 that was reported by Jasbir Batth. This one
9 pulled that were written up at the property for 9 says an alarm was sounding and they stole $700 in
10 events that occurred at the property. The first one 10 coins and cigarettes.
11 I had was this July 4, 2012 shooting at the store by 11 A. Yes.
12 Mr. Batth, and I think he talked about that one. Do 12 Q. Does that sound -- do you know about that
13 you remember that? 13 one?
14 A. Yes. 14 A. Yes.
15 Q. Okay. Then there was May 19, 2009, there 15 Q. All right. And then I have a simple
16 was somebody robbed at gunpoint at the store, a 16 assault from April 23, 2012 for Gursharan Batth?
17 Mr. Gustavus McCoy. Do you know anything about 17 A. That's me.
18 that? 18 Q. That's you. And Albertine Bennett, does
19 A. No. 19 that sound familiar to you?
20 Q. I have a March 9, 2010 carjacking in the 20 A. I know it's me, but I don't know about
21 parking lot. Someone had purchased something in the 21 the Albertine. Know who she is.
22 store and went out to the parking lot and got 22 Q. Then I have another one for March 3,
23 robbed. Do you know anything about that? 23 2012. It's a simple assault of a Trina Kyle at the
24 A. No. 24 store.
25 Q. I've got a November 18, 2008 carjacking 25 A. No.

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1 in the parking lot. Same thing, someone was leaving 1 Q. Any of that ring a bell?
2 the store, goes in the parking lot, and someone 2 A. No.
3 carjacked them. Do you know anything about that? 3 Q. Okay. Tell me a little bit about this
4 A. No. 4 thing where you all had requested that the police
5 Q. I have an October 22, 2011 armed robbery 5 officers come by the property. What's that about?
6 of the store. It was reported by Baldev Singh. 6 Why do you have them come by the property?
7 A. Uh-huh (affirmative response). 7 A. If they see anybody hanging out or
8 Q. Do you know anything about that? 8 something they'll tell them move on. Make sure
9 A. He told us about it, but that's about it. 9 everything is fine.
10 Q. Okay. Mr. Ladner's incident was on 10 Q. So you've got them coming by help y'all
11 August 5, 2013, and you've told us that you weren't 11 make sure there's no loiterers out there, any
12 there at the time that occurred, but you do agree 12 trouble going on out there?
13 that it occurred because they told you about it when 13 A. Yes.
14 you got back? 14 Q. You had said that you thought that the
15 A. Yes. 15 police officers were supposed to come by every half
16 Q. Okay. June 5, 2012 there was a strong 16 hour. Tell me if I'm right. You told me earlier
17 armed robbery at the store. A man with a weapon 17 today that you don't remember seeing any police
18 robbed somebody in the parking lot. Do you know 18 officers come by the day of August 5, 2013. That
19 anything about that? 19 was the day that Earl Ladner was attacked.
20 A. No. 20 A. Yes, I seen them afterwards, but I didn't
21 Q. April 8, 2010, there's another strong 21 see them.
22 armed robbery at the store. Do you know anything 22 Q. So in the morning you don't remember
23 about that? 23 seeing any officers come by or before you left the
24 A. Are there any names? 24 property that day you don't remember seeing any
25 Q. It was a lady, black female leaving Quick 25 officers come by?

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1 A. No, no. 1 lighting." Can we agree that this happened during

2 Q. After the incident occurred somebody 2 the day and lighting wasn't the issue?
3 called it in and the police came and took a report, 3 A. Yeah, safety -- I mean, safety features
4 correct? 4 on the property to make people -- the customer feel
5 A. I wasn't there until then. Everybody was 5 safe.
6 gone, but I seen the cops afterwards in the evening. 6 Q. Okay. But lighting isn't an issue.
7 Q. I asked the hours of service of the 7 Y'all aren't arguing that lighting would have
8 property. Isn't it about 6:30 in the morning until 8 prevented this from happening in the middle of the
9 10 o'clock at night? 9 day?
10 A. Yes. 10 A. Yeah.
11 Q. During the day you have two employees at 11 Q. "Panic button." Does the panic button
12 the property, correct? 12 apply to Mr. Ladner?
13 A. Yes. 13 A. Yes.
14 Q. But after 3:00 you have three employees 14 Q. Okay. The "No loitering" signage, I
15 at the property? 15 think we'd argue that applies.
16 A. After 5:00. 16 "Magnetic door locks," would that have
17 Q. After 5 o'clock you have three? 17 applied to Mr. Ladner?
18 A. Yes. 18 A. Yes.
19 Q. Is the fact that you have -- do you have 19 Q. The "Window and door bars," would that
20 two people at the property as a safety measure? 20 have applied to Mr. Ladner?
21 A. It's lot busier. I mean, the store is 21 A. I don't think so.
22 busy also. 22 Q. I'm going to look at Exhibit No. 2.
23 Q. Okay. So is it for safety and because 23 Number 1 was "Fencing." Did that apply to
24 the store is busy -- 24 Mr. Ladner?
25 A. Yes. 25 A. Could have been sort of way, I mean.

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1 Q. -- or is it just busy and not safety? 1 Q. Okay. Number 2, the "16 surveillance
2 A. Both. 2 cameras," I think we could agree that one could be
3 Q. Okay. So you have two people there for 3 involved in this.
4 safety and because it's busy? 4 Number 3 was the "Public view monitor."
5 A. Uh-huh (affirmative response). 5 That would probably be involved in this.
6 Q. All right. Why do you have three people 6 Number 4, "Remote lock-in capability." I
7 after 5 o'clock, because of safety and more busy? 7 don't think that would be related to his issue.
8 A. Yeah, more busy, safety. Watch outside 8 Would you agree or disagree?
9 and stuff. 9 A. It was the same thing with the
10 Q. I want to ask you real quick about 10 monitoring. They can watch what's going on.
11 Exhibit 1 and Exhibit 2. There's some safety 11 MR. RUSSELL: Object to the form.
12 measures that y'all have listed and I want to see 12 BY MR. OGDEN:
13 which one of these would be more specific applying 13 Q. Okay. Number 5, "20 canopy lights and
14 to Mr. Ladner. 14 eight pole lights." Again, I don't think lighting
15 Number 1 you have on Exhibit 1 is 15 is an issue, but you agree with me lighting is not
16 "Fencing." Can we agree that Mr. Ladner's case or 16 an issue in this case?
17 the incident that occurred to him didn't involve the 17 A. Yes.
18 fencing on the property? 18 MR. RUSSELL: Object to the form.
19 A. Yes. 19 BY MR. OGDEN:
20 MR. RUSSELL: Object to the form. 20 Q. Number 6 is "white reflective gas
21 BY MR. OGDEN: 21 canopy." I don't think that's relevant to what
22 Q. Then number 2, "16 monitoring 22 occurred here. Do you agree or disagree?
23 surveillance cameras." I think that those might be 23 A. Yeah, agree.
24 at issue, so we'll move on from that one. 24 MR. RUSSELL: Object to the form.
25 Number 3, "Canopy and building perimeter 25 BY MR. OGDEN:

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1 Q. You agree it does or does not apply to 1 A. Late -- I mean, early afternoon.
2 us? 2 Probably you can say it like that.
3 A. What is it again? 3 Q. Well, if he was attacked at 2 o'clock --
4 Q. "White reflective gas canopy." 4 A. Probably 12:00, 1:00, something like
5 A. Probably the lights on -- the same 5 that.
6 lights. 6 Q. -- you think 12:00 or 1:00. Somebody
7 MR. RUSSELL: Object to form. 7 should have gone out and circled the parking lot,
8 BY MR. OGDEN: 8 run off loiterers, cleaned up everything, made sure
9 Q. "Raised counter." That really doesn't 9 gas wasn't squirting out on the ground?
10 apply because what happened to him was out in the 10 A. There's somebody probably smoking
11 parking lot, correct? 11 cigarettes all the time outside, employee or
12 MR. RUSSELL: Object to the form. 12 something, every five, 10 minutes, 15 minutes. It's
13 A. Yes. 13 about cleaning up the lot.
14 BY MR. OGDEN: 14 Q. Okay. Number 14 is "Two clerks." I
15 Q. The counter near the window, that may 15 think -- no, 15 is "Two clerks" number. We've
16 apply. 16 already discussed that.
17 Number 9, "Bulletproof glass." He was -- 17 Number 16, "Free drinks for police." Tell
18 that's inside, not outside, correct? 18 me about that. If the police come by they can come
19 A. Yes. 19 in and get a free drink?
20 Q. 10 is the "Cash management procedures." 20 A. Yeah, they can. I mean, if we know them
21 Does that apply to Mr. Ladner or not? 21 we will give them free drinks.
22 A. Some kind of way. 22 Q. What kind of drinks can they get for
23 MR. RUSSELL: Object to the form. 23 free, just coffee and water --
24 BY MR. OGDEN: 24 A. Yeah.
25 Q. Okay. Number 11, "Drop safe with time 25 Q. -- or anything in the counter they want?

Page 34 Page 36

1 lock." Does that apply to the facts of Mr. Ladner's 1 A. It's not anything in the counter. It's
2 case? 2 just like water or something. Usually water,
3 A. I don't know. 3 coffee, something like that. But we usually don't
4 MR. RUSSELL: Object to the form. 4 have coffee around noon.
5 BY MR. OGDEN: 5 Q. Number 17 is a "Police substation one
6 Q. Number 12, "Panic button." You've 6 mile away with police cars coming by every half
7 already discussed that one. 7 hour." Where is the substation? Do you know which
8 Number 13, "Parabolic mirrors outside on 8 one it is?
9 the corners of the buildings," right? 9 A. I have no -- I don't know which precinct
10 A. Yes. 10 it is, but I know there's one back there.
11 Q. Helps you see around the corners of the 11 Q. Okay. And we talked about the cars
12 building. That may apply. 12 coming by every half hour, but you've already told
13 Number 14, "Periodic cleanup of parking 13 me that you don't remember seeing any officers
14 lot." Does that one apply? 14 coming by that morning before Earl Ladner was
15 A. Yes. 15 attacked, correct?
16 Q. Okay. Tell me how the -- well, I guess 16 A. Yes.
17 the question I'd have is, do you know if anybody 17 Q. "No loitering" signs. You talked about
18 went out there in the parking lot and did a cleanup 18 that already. You say there were two of them inside
19 sweep before Mr. Ladner was attacked? 19 the building that you could see through the window I
20 A. Earlier that day, I mean. 20 guess?
21 Q. Do you know what time it was done? 21 A. Yes, one or two, I believe.
22 A. I'm not sure what time. 22 Q. Are those signs still there today?
23 Q. Was it in the morning? 23 A. Yes.
24 A. Noon. 24 Q. If I was to come over there next week to
25 Q. Early in the morning? 25 take a picture of the signs those would be the same

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1 signs that were there back in 2013? 1 whatever you want to say.
2 A. Yes. 2 A. Yeah, I would say "yes," because we can
3 Q. Okay. Number 19 is "Enforcement of no 3 lock him in. If he was threatened outside we can
4 panhandling, drinking, loitering signs, and rules." 4 lock the customer in. Tell him hold on until we
5 I would think that that would apply, correct? 5 call the police or something.
6 A. Yes. 6 Q. Okay. "Speakers at pumps." I'm going to
7 Q. Number 20 was "Banning shoplifters by 7 kind of skip that one because it doesn't make that
8 visual identification." 8 much of a point for me that I'm worried about.
9 A. Yes. 9 Number 24, "No firearms at property." Now,
10 Q. Number 21 was "Robbery training." You 10 we talked about that earlier. You're saying that
11 talked about that earlier. Where did you go to get 11 the employees can have firearms, but you don't want
12 that training? 12 customers having firearms, correct?
13 A. That's a little class, I mean. 13 A. Yes.
14 Q. Was it in California? 14 MR. RUSSELL: Object to form.
15 A. Yes. 15 BY MR. OGDEN:
16 Q. Why did you go to a class in California 16 Q. All right. Number 25 was the "Annual
17 to get robbery training? 17 fire safety inspection." Can we agree that the
18 A. Because I used to work at a store there 18 yearly fire inspection really doesn't have anything
19 too. 19 to do with Earl Ladner getting attacked?
20 Q. So you worked at a convenience store in 20 A. Yes.
21 California? 21 Q. Number 26, "Training to report suspicious
22 A. Yes. 22 people." How does that apply to Earl Ladner?
23 Q. Did that store send you? 23 A. If there's somebody panhandling outside
24 A. Yes. 24 we usually tell them to leave.
25 Q. What was the store that you worked at? 25 Q. I guess let me ask it this way: Were the

Page 38 Page 40

1 A. It was my relatives you can say. I was 1 two men that were at the property that day when Earl
2 just helping them part time. 2 was attacked, were they trained to know how to
3 Q. Okay. And what was the name of the class 3 report suspicious people?
4 that they sent you to? 4 A. Yes.
5 A. I have no -- it was just regular security 5 Q. And they were trained by you?
6 guard, I mean. 6 A. Yes.
7 Q. How long was the class? 7 Q. Okay. So they should have known when
8 A. Probably like hour, half an hour, 8 Earl Ladner came in and said, "Hey, there's some
9 something like that. 9 funky looking guy outside" --
10 Q. Okay. Number 22 is "Magnetic door 10 A. He never came in.
11 locks"? 11 Q. All right. That's the second time you
12 A. Yes. 12 said that. How do you know that Earl Ladner never
13 Q. All right. Would that apply to Earl 13 came in the store?
14 Ladner -- 14 A. Because I seen the video.
15 A. Yes. 15 Q. Okay.
16 Q. -- being attacked in the parking lot? 16 A. Because he just parked his truck and
17 MR. RUSSELL: Object to the form. 17 waited over there. He bought the stuff. Then he
18 A. It could be. I don't know. 18 left outside. Then he got robbed. He never came in
19 BY MR. OGDEN: 19 there twice.
20 Q. Well, the question is, would -- do you 20 Q. Oh, no, I'm only saying he came in there
21 think that having magnetic door locks would have 21 once.
22 prevented him from getting attacked in the parking 22 A. Yeah, to shop the stuff, yes.
23 lot? 23 Q. He came -- Earl Ladner parked his truck.
24 A. Yes. 24 A. Uh-huh (affirmative response).
25 Q. I would say "no," but you can say 25 Q. Came into the store. Bought his stuff.

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1 Went out to his truck. And this man attacked him at 1 Q. Who gives you the trouble? Like you've
2 his truck and robbed him at his truck, right? 2 got a loiterer is the loiterer --
3 A. I don't know if they robbed him. I don't 3 A. Some person that's never been there
4 know what he did. Yeah, they were talking to each 4 before.
5 other. 5 Q. It's not the local?
6 Q. Okay. So we do agree or at least you and 6 A. Yes.
7 I agree at this point that we know that Earl Ladner 7 Q. Earl Ladner was not a loiterer at your
8 came into the store, purchased something, and went 8 property. He didn't go just hang out and cause you
9 back out, correct? 9 problems, correct?
10 A. Yes. 10 A. Yes.
11 Q. "Conflict resolution training." Does 11 Q. Yes, he did?
12 that apply to this fact scenario with Earl Ladner or 12 A. No.
13 not? Because there was no conflict between Earl and 13 MR. RUSSELL: Correct.
14 the employees, was there? 14 A. Yeah, I'm sorry.
15 MR. RUSSELL: Object to form. 15 BY MR. OGDEN:
16 A. I don't know. I don't know about that. 16 Q. That's fine.
17 BY MR. OGDEN: 17 Did you ever inspect the property and say
18 Q. All right. "Opening and closing safety 18 to yourself there's some things we can do here to
19 procedures." The attack of Earl didn't occur during 19 make it safer than what we already have?
20 opening and closing times, so I don't think that 20 A. No, I don't think so.
21 applies, but do you think it applies? 21 Q. Who requested that the police were to
22 A. I don't know. 22 come by every half hour and check the property out?
23 Q. All right. Number 29, "Burglar bars." 23 A. Employees or anybody who was there
24 How do burglar bars either prevent Earl from getting 24 usually tell them stop by.
25 attacked or encourage this guy to attack Earl? 25 Q. Do you remember yourself specifically

Page 42 Page 44

1 A. I don't know. 1 talking to the police or Mr. Batth specifically

2 Q. Then the last one, number 37, "Concrete 2 talking to the police and saying, "I want you here
3 vertical ballards in front of the store." 3 every half hour"?
4 A. If someone to run into the building or 4 A. I mean, yeah, I did.
5 something. 5 Q. All right. Now, when you did that who
6 Q. All right. What does that have to do 6 told you to do that? Did you do that on your own or
7 with Earl Ladner getting attacked in the parking 7 did Mr. Batth tell you to do that?
8 lot? 8 A. Yeah. They usually come and stop and get
9 A. I don't know. Maybe someone wouldn't run 9 drinks and stuff, so I just tell them, "Hey, just
10 him over. 10 keep an eye on and make sure everything is fine."
11 Q. Would you agree that those really aren't 11 Q. So what happened was they would stop by
12 a part of Earl Ladner's case? 12 to get a drink or get gas or be a customer of the
13 A. It could be, yeah. I don't know. 13 store and you reached out to them and said, "I would
14 Q. Okay. That was Exhibit 2. So if you had 14 like you to come by the store"?
15 to describe the area around the store, the 15 A. Yes.
16 neighborhood, how would you describe it? Is it a 16 Q. Who established this coming by every half
17 rundown neighborhood, poor neighborhood? Is there 17 hour thing that you're talking about? Was that in
18 HUD housing there? Is it a high-end neighborhood? 18 writing somewhere?
19 How do you describe it? 19 A. No. Just cops's cars we see almost -- we
20 A. Old people. 20 can see almost half an hour, an hour, or something
21 Q. Old people. And what's -- tell me about 21 like that, pass by. There's a precinct back there.
22 the people that come to the store. Are they locals? 22 Q. Okay. So you didn't specifically say to
23 A. Yes, locals. 23 them, "I want you to come on to this property every
24 Q. Do the locals give you any trouble? 24 half hour"?
25 A. No. We know everybody in that area.. 25 A. No.

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1 Q. You just see them coming by -- 1 Q. I have seen on the TV in the last couple
2 A. Yes. 2 years where the Indian community has gotten together
3 Q. -- because the precinct is here? 3 because they own a lot of convenience stores in
4 A. Yes. 4 Jackson, and they've complained about crime at the
5 Q. All right. But you spoke to the officers 5 convenience stores. Were you involved with that
6 and told them, "I want you to stop by as much as 6 group?
7 possible" -- 7 A. No.
8 A. Yes. 8 Q. They went and met with the sheriff's
9 Q. -- "for purposes of safety"? 9 department and asked for specific help to certain
10 A. Yes. 10 convenience stores because they felt like they were
11 Q. Did you say to them, "You get a free 11 being targeted or being robbed more than other
12 drink if you come by," or is that just kind of 12 stores. Do you know anything about that?
13 something you were doing to be nice? 13 A. Yeah, I know about it, but I wasn't part
14 A. Just a favor. Just being nice. 14 of it.
15 Q. Did you have a specific assigned time or 15 Q. Did you participate in it?
16 any specific assigned officer who you can name who 16 A. No.
17 had a time that they specifically came by, like did 17 Q. No? Okay.
18 every day at 12 o'clock officer so and so would 18 Was your store one of the stores that they
19 stick his head in the door? 19 -- that the sheriff's department came to because of
20 A. I don't remember the name. 20 the request by the Indian community?
21 Q. Could you give me the names of any 21 MR. RUSSELL: Object to the form.
22 officers that you spoke to about coming by? 22 A. I don't know.
23 A. I don't remember the name they change 23 BY MR. OGDEN:
24 them so much. 24 Q. Do you know or not know?
25 Q. Could you give me the names of any 25 A. I don't know.

Page 46 Page 48

1 officers that you got to know because they were 1 Q. What about the two guys that were working
2 coming by? 2 there that day, do you know if they had any criminal
3 A. I can't think of a name. 3 history?
4 Q. Okay. Did the commander or a sergeant or 4 A. No.
5 somebody who heads the police department or who 5 Q. How long had they been working there at
6 works at the precinct ever come by and talk to you? 6 the store before the attack in August of 2013?
7 A. Sheriff department. 7 A. One of them was my friend because he was
8 Q. The sheriff's department came by and 8 just taking my place where I could grab something to
9 talked to you? 9 eat for us. And the other guy had been working for
10 A. Yes. 10 a couple years.
11 Q. What did they come by and do? 11 Q. Were they both aware of the fact that
12 A. Make sure everything was fine. If 12 they had the right to run off loiterers if a
13 there's any problem they give us a number, special 13 loiterer was out there?
14 number or something. Call this number or what. 14 A. Yes.
15 Q. Was that before or after Earl Ladner got 15 Q. And did they understand that if they were
16 attacked? 16 -- if they saw the loiterer out there they could
17 A. They come usually all the time before and 17 interact with that loiterer, they didn't have to be
18 after. 18 asked by a customer? They could say, "That guy
19 Q. All right. So talk to me about before 19 looks like a loiterer. We need to go out there and
20 Earl got attacked. Who from the sheriff's 20 deal with it," correct?
21 department was coming by? 21 A. Yes, yes, uh-huh (affirmative response).
22 A. Anybody probably their head or something. 22 Q. Is there any other crimes that you're
23 I have no clue. I don't know who it was. Probably 23 aware of besides the ones that we've gone through on
24 just give us a card or something. "If you guys have 24 these reports that have occurred at the property?
25 any trouble just call this number." 25 A. No.

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1 Q. Have you ever been a victim of a crime 1 Q. Could you describe him if I said, "Tell
2 before? 2 me what Earl Ladner looks like"? How would you
3 A. No. 3 describe him?
4 Q. What kind of crimes occur around the 4 A. Older guy, gentleman.
5 property? Have you ever heard of any crimes 5 Q. Elderly black man?
6 occurring next door, couple doors down from you? 6 A. Yes.
7 MR. RUSSELL: Object to the form. 7 Q. Okay. Have you seen him at the store
8 A. Maybe one or something like that. That's 8 since the attack?
9 the only thing I know of. 9 A. No.
10 BY MR. OGDEN: 10 Q. Have you ever spoken to him about what
11 Q. Have you noticed any drug sales around 11 occurred?
12 your property? 12 A. No.
13 A. I don't know. I didn't see any. 13 Q. Has your father or any of your
14 Q. Has any other person, a customer, anybody 14 employees --
15 else called and complained to you and told you that 15 A. He never came back.
16 you needed a security guard in the parking lot? 16 Q. All right. Did y'all get a statement
17 A. No. 17 from him or talk to him about what happened?
18 Q. Have you ever thought about having a 18 A. No.
19 security guard in the parking lot? 19 Q. All right. You heard me ask this
20 A. No. 20 question to Mr. Batth: Is there anything that
21 Q. Am I correct in saying that your 21 you're aware of that Earl Ladner did to cause
22 understanding of security back in August of 2013 on 22 himself to get attacked?
23 securing the property consisted of the employees 23 A. Not that I know of.
24 primarily? 24 Q. You're not saying that he did -- he
25 A. Yes, sir. 25 brought this on himself, are you?

Page 50 Page 52

1 MR. RUSSELL: Object to the form. 1 A. No.

2 BY MR. OGDEN: 2 Q. All right. You weren't expecting the
3 Q. And I'm not trying to discount the list 3 customers to provide themselves their own security
4 that you have on Exhibit 1 and Exhibit 2, but I'm 4 when they were at the store, were you?
5 looking for like a physical presence. Forget the 5 A. No.
6 cameras and the fences and the lights. Who was the 6 Q. Let me ask you what you would have done.
7 person on the property in charge of securing the 7 Assuming you were at the store, and you saw a man
8 property? Would that be the employees? 8 standing outside hanging out just, you know, asking
9 A. Yes. 9 people for money or just standing around, walk me
10 Q. Earl Ladner, did you know Earl Ladner or 10 through what you would do.
11 would you recognize him? 11 A. I would walk out the door, tell the guy,
12 A. Yes. 12 "Hey, bro, you can't be hanging out over here. Move
13 Q. Tell me about that. How would you know 13 on."
14 Earl Ladner? 14 Q. All right. And if he says, "Well, I'm
15 A. He was a customer. 15 not moving"?
16 Q. How often did he come to your store? 16 A. Call the police while I'm standing there.
17 A. While I'm there my shift, maybe once or 17 Q. Have you ever had that happen before?
18 twice. 18 A. No.
19 Q. Was he a good customer? 19 Q. So every time you've told people move on
20 A. Yes. 20 the loiterers move on, right?
21 Q. Did he ever give you any problems? 21 A. Yes.
22 A. No. 22 Q. They don't mess around, they hit the
23 Q. Did he ever come in there and knock over 23 road?
24 displays or complain about your prices? 24 A. Yes.
25 A. No. 25 Q. When you do that, do you have your gun on

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1 you? 1 A. Sure.
2 A. I mean, I have it all the time. 2 Q. After that, I'm done with your
3 Q. Do you wear it so they can see it? 3 questioning. I don't know if you might want to read
4 A. No. 4 and sign your deposition.
5 Q. You keep it concealed? 5 MR. RUSSELL: Yeah. We want him to read
6 A. Concealed. 6 and sign.
7 MR. OGDEN: Okay. All right. I think 7 MR. OGDEN: All right. That's it.
8 I'm done. You might have a few follow-up questions. 8 THE WITNESS: Thank you.
9 EXAMINATION BY MR. RUSSELL: 9 VIDEOGRAPHER: This concludes his
10 Q. Sonny, I do want to ask you just one kind 10 deposition. The time is 11:13.
11 of clarification question. I think Ashley asked you 11 (Off the record.)
12 about customers and firearms and there's a policy 12 (Time noted: 11:13 a.m.)
13 that he may have been asking you about. Do y'all 13
14 prevent customers from having firearms in their car 14 Original: J. Ashley Ogden, Esq.
15 or out in the parking lot or is that sign meant for 15 Copy: Dale G. Russell, Esq.
16 inside? 16
17 A. Property. 17
18 Q. So what you're saying is there a sign 18
19 somewhere on the property that says that? 19
20 A. I believe it says "No guns on the 20
21 premises." I'm not sure what the exact words. I 21
22 know it says "No guns" with a gun circle on it. 22
23 Q. Okay. All right. Are you saying that 23
24 you don't want customers to have firearms in the 24
25 parking lot? 25

Page 54
1 A. Yes, parking lot and the store, the whole
2 property.
3 MR. RUSSELL: That's all I've got.
4 FURTHER EXAMINATION BY MR. OGDEN:
5 Q. You guys didn't keep a log that you have
6 in writing that would indicate what times, if any,
7 police officers stopped by the store, would you?
8 A. No.
9 Q. The man who attacked Earl Ladner had you
Page 56
1 CERTIFICATE OF COURT REPORTER
2 I, JULIE BROWN, Court Reporter and Notary
3 Public, in and for the State of Mississippi, do
4 hereby certify that the above and foregoing pages
5 contain a full, true and correct transcript of the
6 proceedings had in the aforenamed case at the time
7 and place indicated, which proceedings were recorded
8 by me to the best of my skill and ability.
9 I also certify that I placed the witness

10 ever seen him at the store before? Did you 10 under oath to tell the truth and that all answers
11 recognize him when you looked at him on the video? 11 were given under that oath.
12 A. No. 12 I certify that the witness has chosen his
13 Q. Your video that you have, how long does 13 right to not waive the reading and signing of the
14 it record for? Is it a 30-day loop before it 14 deposition.
15 records over itself, everyday loop? 15 I certify that I have no interest, monetary
16 A. I think it's a 500 gigabytes. I don't 16 or otherwise, in the outcome of this case.
17 know how long it takes. Probably like a week or two 17 Witness my signature and seal this the
18 I believe. I'm not sure. 18 20th day of April, 2015.
19 Q. You don't know how long it rolls over -- 19
20 A. Yeah. 20
21 Q. -- before it records over itself? 21
22 A. Probably a week or two at the most. 22 _________________________
JULIE BROWN, CSR
23 Q. Okay. Same thing with your attorney. I 23
My Commission Expires:
24 would like to go out there and just take a look at 24 April 4, 2016
25 the property to get an understanding of it. 25

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1 CERTIFICATE OF DEPONENT
2 I,_______________________________, do
3 hereby certify that the foregoing testimony is true
4 and accurate to the best of my knowledge and belief,
5 as originally transcribed, or with the changes as
6 noted on the attached Correction Sheet.
7
8
9
10
11
12
13
14
15 Subscribed and sworn to before me, this
16 the ___ day of ______________________, 2015.
17
18
19 _________________________
20 Notary Public
21 My Commission Expires:
22
23 ________________________
24
25

Page 58
1 CORRECTION SHEET
2
3 I, ______________________________, do
4 hereby certify that the following corrections and
5 additions are true and accurate to the best of my
6 knowledge and belief.
7 CORRECTION PAGE LINE REASON______
8 ____________________________________________________
9 ____________________________________________________
10 ____________________________________________________
11 ____________________________________________________
12 ____________________________________________________
13 ____________________________________________________
14 ____________________________________________________
15 ____________________________________________________
16 ____________________________________________________
17
18
19
20 Subscribed and sworn to before me, this
the ___ day of ______________________, 2015.
21
22 _________________________
Notary Public
23 My Commission Expires:
24 ________________________
25

Min-U-Script® AW REPORTING - 601-898-9990 (15) Pages 57 - 58

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