1.

Can you please state your name and occupation

- Name is Sydney Little and I am the director of Play and Learn

2.Can you tell us what occurred on July 28th ?

- On July 28th, at around 2:30, the children in the Jiraffe room were asked to sit in their designated seats
and they were about to be served their afteroon snack, that is when Junior Wright attempted to climb
the changing table and fell and broke his arm.

3.Who was in the room during the incident?

- The teacher, Lorraine and the assistant Lee Morrisson

4. What happened after the insident?

- When Junior fell, Lee went immediatley to help, and the lead teacher has called an Ambulance and
paged for me to come, which is standard procedure and its exactly what she was taught to do. His
teacher even went to the hospital with him, and I began an investigation to see what happened.

5. Have you had any incidents prior to this?

- No, In my 10 we have never had an incident like this before, and this is the first time ever we’re being
sued.

6. What did you Observe in Junior’s behavior the first time you saw him?

- I noticed that Junior was very active and couldn’t focus on one thing. He quickly went from toy to toy
and didn’t look at any of the books I’ve given him.

7.Do you recognize this document?

- Yes.

8.Can you elaborate on this document?

This is the document that Shawn Right has signed in order to registrate his son. It contains multiple
questions in which we ask all parents, and some of the questions are asked in order to inform ourselves
about the kid. Questions with topics such as allergies, medications, learning disabilities and more were
asked, and Shawn Right has filled in everything with No. Except from the fact that Junior is allergic to
bendadrol.
9.Do you recognize this document?

-Yes. This is our Policy manual.

10.Can you elaborate on this document?

-Here it states the maximum amount of children per class, and how many teachers and assistants should
be in the classroom.

11.How many teachers and assistants were present in Junior’s class on July 28th?

- According to the mannual, there should be one lead teacher and one assistant. However, on the day of
the incident, there was one lead teacher and TWO assistants because there is a child diagnosed with HID
and has one assistant just for him in order to maximize his safety and provide his needs.