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4].


damage herself with, yes.

Q.
Okay. I think Sam has said that she had
actually come out one time and he guided her back, and
he used the same term, “guided her back,” and then
another time she came to the door and opened it and
attempted to knee him in the groin and poke him in the
eyes. Did you, as security chief, have a plan in
effect if she bolted from the room to run away?

A.
I have to fall back on the -- I would say yes
to that question just from the viewpoint that Sam had
the instructions from me if she comes out, help guide
her back in again. That’s all. The application of
force or what could occur, we didn’t actually discuss
that. It was like “I hope she stays calm.”

Q.
All right.
A.
You see what I mean? We didn’t actually
discuss any like horrendous scenarios that could
possibly have come up.

Q.
Yet -- yet we have Sam saying that he had to
go in and hold her down while they squirted some type
of medication into her mouth. Apparently, there was
physical force being used by your security force.

A.
Okay. I honestly don’t remember him telling
me that.

Q.
Okay.
KANABAY COURT REPORTERS

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