Deposition Excerpts.pdf”

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Susan Florio, RPR - Professional Reporting Service - (518)887-2733SueFlorio, RPR

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Video Deposition of MARY MAIORIELLO

UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF NEW YORK----------------------------------------------XP.C. as Administrator of the Estate ofher son K.C.,

Plaintiff,

-against- 5:12 Civ. 1171

LISA TAYLOR, LAURI TOMASSI, SHARON BUTLER,ERIC SADLON, LEKISHA TERRELL, "HERSHANI" DOE,and JOHN AND JANE DOES 1-20,

Defendants.----------------------------------------------X

VIDEOTAPED DEPOSITION of a Non-Party Witness,

MARY MAIORIELLO, held on October 23, 2014,

commencing at 10:40 a.m., at the New York State

Attorney General's Office, Justice Building, 4th

Floor Conference Room, Albany, New York, pursuant

to Subpoena; before Susan Florio, a Registered

Professional Reporter and Notary Public in and for

the State of New York.

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[MARY MAIORIELLO - By Mr. Maazel]

MR. DAGUE: Objection.

Q. And that was in October 2010, right?

A. Correct.

Q. But this is abuse that you had witnessed

for months before, right?

A. Correct.

Q. And so can you just tell me the reason or

the reasons why you didn't feel comfortable coming

forward?

A. Because I was terrified to come forward

and say anything. I was told by Sharon Butler on

one of my first days that I would do fine at O.D.

Heck as an employee if I kept my eyes open and

mouth shut.

Another day K came home. I believe he

had gone to the hospital. He walked in. He had

the biggest black eye I've ever seen in my life

and I said, "Oh, my God, what happened," and I

was told to shut up.

Q. By?

A. By Sharon Butler. I was told, "He fell."

And I said, "He fell?" Because oh, my God, he

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had this giant black eye. What do you -- who

falls on their eye? And she said, "Shut up."

So, I shut up. And I saw what they could do to

somebody who was helpless and frail and non-verbal

and vulnerable. What were they going to do to me?

I was scared. I was wrong for doing that and I

was scared.

Q. By the way, to get off probation after 9

to 12 months, is one thing that State of New York

would look at are evaluations from your supervisors?

A. Yes.

MR. DAGUE: Object. Form.

Q. And so were the very people who were

abusing KC the same people who were going to help

decide whether you got to keep your job?


A. I believe so.

Q. Was that your belief at the time?

A. Yes. Definitely. I'm not -- yes.

Q. Now, I think you said New York State was

writing your paycheck when you worked there,

right?

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holding the door open so her back was to the

dining room where K was sitting at the table with

his plate by himself. At some point during the

morning, during breakfast, he threw it. It went

flying. It was pureed food so it's everywhere.

So, she became angry because, you know, she had

to clean it up, she had to do something about it.

She didn't want to do anything. Well, it appeared

she didn't want to do anything because she was

not doing her job.

Q. So, what did Sharon do when K threw his

food?

A. Sharon took K, held on to him, brought

him over to the gym mat, left him on the gym mat

and told him he was not going to eat until -- he

was not having any more breakfast, he was not

going to eat until lunch. We do not throw our

food. And that's the end of it. And that he

would learn if that's what she did.

Q. Okay. And then you wrote, still AG 5388,

you wrote, "Throughout the day I witnessed Sharon

yell at him, call him the sparrow and the thing,

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hit him with the towel and the blue stick."

A. Um-hmm.

Q. Did I read that accurately?

A. Yes.

Q. And that's all true?

A. Yes.

Q. And so you saw Sharon Butler call K the

thing?

A. Yes.

Q. And was that something she did frequently?

A. Yes. The thing, the sparrow. Yes.

Q. And can you give examples of how Sharon

would call K the thing?

A. The thing over here. I mean, she

referred to him as the thing, you know. "It."

It's getting off the mat again. The thing is up.

The thing threw his plate. The sparrow threw his

plate. Instead of K threw his plate or K got off

the mat, it was the thing, sparrow, it. That's

how.

Q. So, Sharon referred to K as "it" as well?

A. Yes.

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Q. All right. And you also wrote here that

Sharon hit K with a towel on that day. Can you

describe that?

A. Yes. She wrapped up a towel and hit him

with it when he was crawling off the mat.

Q. And why did she do that?

A. Because she didn't want him to get off

the mat. That's what it appeared. From what I

saw it appeared she wanted him to stay on the mat

for her convenience and that was her way of

keeping him there.

Q. And had you seen Sharon hit K with a

towel before?

A. I believe so, yes.

Q. And you also wrote that K hit -- I'm

sorry. Withdrawn.

You also wrote that Sharon Butler hit K

with a blue stick?

A. Yup. The couches, the way the couches

were set in the common area/living room, they had

a groove on the top. There was two, there was a

little groove between the two cushions and she

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would keep the stick right there in the groove.

She would sit in her little rolley chair with

wheels. The mat would be to the left of her.

The television was in front. She'd be watching

television. And when K would act up, she would

do things like hit him with a towel if she had a

towel or she would grab the stick from the groove

and hit him with it.

Q. Okay. And so when K tried to get off the

mat was one of Sharon Butler's ways to keep him

on the mat to hit him with the stick?

A. It appeared that way.

Q. And that's something you saw for a period

of months?

A. Yes. Not just her but, yes.

Q. Okay. We'll get to -- there's another

statement.

A. Okay. I'm sorry. Yes.

Q. With a lot of other people too.

A. Yes.

Q. Okay. Then you wrote, "K signed food/eat

and was headed toward the water fountain. Sharon

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off the mat. She very casually stepped on both

of his hands and in a neutral tone told K to stay

on the mat." Did I read that accurately?

A. Yes.

Q. And you witnessed that as well?

A. Yes.

Q. So, can you describe in your own words

what you saw Lekisha Terrell do?

A. Yes. I can. K was -- again, the gym mat

was on the ground and, as I said previously, he

liked to crawl. He was crawling, had his hands

off the mat. She walked up to him in a very

nonchalant, very casual way, and put one foot on

one hand and the other foot on the other hand and

said, I think she said something along the lines

of get back on the mat or move back or something

like that and he casually... But she did it so

nonchalant and so casually that it was just -- it

appeared very casual. I mean, like she didn't,

you know, yell, she didn't make a scene. She

just went over there and stepped on him.

Q. Okay. And when Ms. Terrell stepped on

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K's hands did she have shoes on?

A. Yes.

Q. And K was on his hands and knees at that

point?

A. Yes. He was.

Q. And he was on the mat?

A. I think his hands were off the mat, his

body was on the mat.

Q. And so Lekisha Terrell put all her weight

on K?

A. Yes.

Q. And how did K react?

A. He pulled back and cowered back, like he

would cower back in the corner when he was, not

all the time but that time he did.

Q. Okay. And did K appear afraid?

A. Afraid, angry, upset. It was hard to

tell exactly what emotion it was. Hurt maybe. I

mean, he cowered in a corner.

MR. DAGUE: Just lodge an objection

on that last question. Sorry for my delay.

Q. And did you believe K was in pain when

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Lekisha Terrell stepped on his hands?

A. Yes.

MR. DAGUE: Object to form.

Q. Do you have any doubt about that?

A. No.

Q. And did Ms. Terrell, did she just

accidentally --

A. No.

Q. -- step on K's hands?

A. No.

Q. Or was it deliberate?


A. It was deliberate.

Q. Explain.

A. Explain? She walked right up to him,

looked at him, put one foot on one hand and

the other foot on the other hand in a very

deliberate -- I mean, if you step on somebody's

hand you know it. It was deliberate. She put

one foot and then put the other foot right after

onto his hands. There was no -- she didn't trip

over him, she didn't fall. She put her feet on

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her -- on his hands and then took her feet off

his hands.

Q. And is this abuse?

A. I think it's abuse.

Q. And what words would you describe what

Ms. Terrell did? Would you say it was cruel what

she did?

A. Yes.

Q. Sadistic?


A. Yeah. Definitely cruel and -- inhumane?

Maybe that's a better word. Inhumane.

Q. Another statement that you gave on

October 20th, 2010, written statement is at

Exhibit 277, 5389 and 5390, right?

MR. DAGUE: Was that 277 still,

Ilann?

MR. MAAZEL: Yes.

A. It's the next page. Right?

Q. Next page and page after that.

A. Okay.

Q. Okay. And is this another -- is this

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statement also your handwriting?

A. Yes. It is.

Q. And is this statement also true?

A. Yes. It is.

Q. And based on your own personal

observations?

A. Yes.

Q. And, again, you prepared this statement

all on your own?

A. Correct.

Q. No help from anyone, right?

A. No.

Q. And so let's go through this one. You

wrote, "Since I have been working days on 9D I

have witnessed abuse several times for KC. K is

regularly referred to as or called 'it,' 'the

thing,' 'the sparrow,' 'the walking plague.'"

I'll just stop there.

A. Okay.

Q. And you witnessed all of that, right?

A. Correct.

Q. And tell me some of the staff that you

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saw call KC "it," "the thing," "the sparrow" or

"the walking plague"?

A. Sharon Butler, Laurie Toma- -- I don't

know her last name.

Q. Tomassi?

A. Tomassi. Lisa Taylor.

Q. Did you see Eric Sadlon call K names as

well sometimes?

A. Yes. Eric has called -- yes. I can't

remember anything, anyone else at this time.

Well, yeah, I'd have to read through this.

Q. And so these people, Sharon, Laurie,

Lisa, Eric, called K names?

A. Correct.

Q. And the names you remember are "it," "the

thing," "the sparrow" and "the walking plague"?

A. Correct.

Q. Where did this "walking plague" come

from?

A. It was my understanding that they thought

he was gross. He wore a pull up. None of the

other consumers -- well, I take that back. I

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Q. Like they would call him "it" to his

face?

A. Yes.

Q. How would Sharon, Laurie, Lisa and Eric

do that?

A. Instead of his name they would say "it,"

you know. "Come on, it's time to go." Get up

"it." It, you know, it -- they would replace his

name with the word "it" or if they weren't

directing it at him or they were talking to

someone right in front of him, oh, it's time to

get the sparrow, come on, or things of that

nature. They would call him "it," "it." He was

never called K. He was never called K. He was

called all these others things in place, whether

it was -- and, yes, he was in the room. And he

could hear. You know, they would have conversations

right in front of him and use those terms in place

of his name.

Q. And your next sentence on AG 5389 you

wrote, "It is made clear among staff on 9D that

they do not like K and often say he 'should go

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the times they would hit him.

Q. Okay. So, did Sharon Butler hit K with

the stick to keep him on the mat?

A. Yes.

Q. Did Laurie Tomassi hit K with the stick

to keep him on the mat?

A. Yes.

Q. Did Lisa Taylor hit K with the stick to

stay on the mat?

A. Yes.

Q. Did Eric Sadlon hit K with the stick to

keep him on the mat?

A. Yes.

Q. And they did this on a number of occasions?

A. Yes.

Q. Is this abuse?

A. I --


A. I believe it's abuse.

Q. And so was K just kept on the mat almost

all the time except for meals and changing?

A. Yes.

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Q. And what did the staff do while K was on

the mat? What were they doing?

A. Talking amongst each other, watching

television, playing games on their phones. There

was one woman on the unit who was not assigned to

K, but she would knit blankets and washcloths and

towels and such. Eat. Whatever they felt like

doing, watch -- you know, just hang out.

Q. Okay. And this went on for hours at a

time that Sharon, Laurie, Lisa and Eric would

just leave K alone on the mat?

A. Yeah. They had that chair on wheels and

whoever was assigned to K generally had the chair

on wheels so they could be right there and if

they chose to put the stick in the couch groove

they could be, you know, have quick access and,

yeah.

Q. And where did Sharon, Laurie, Lisa and

Eric hit K with the blue stick when they did

that?

A. Well, if he was crawling off the mat it

would generally be his back area, shoulders,

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enough -- hitting with enough force to show that

they were in control. But you could hear it.

So, could it have left a black and blue mark?

Could have. Did it? I don't know.

Q. Okay. You then wrote, still AG 5389, "I

heard the stick referred to as the magic wand by

the supervisor, Lisa Taylor."

A. Yes.

Q. And that is true?

A. That is true.

Q. Can you describe that?

A. Yup. It was -- yes. I remember an

occasion where we were in the living room area

and the stick was in the end table closest to

the -- well, closest to the exit that went to the

patio and she was looking for the stick and she

said where's my magic wand, and I had no idea

what she was talking about, and then she opened

the drawer and pulled the stick out and she said

something, I have, you know, my magic wand or

something to that nature. And -- she was looking

for her magic wand and what she produced was the

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blue stick from that drawer.

Q. And that was the blue stick that she had

hit K with?

A. Correct.

Q. Do you remember whether other people

referred to the blue stick as the magic wand?

A. I don't recall any. No. I don't recall.

Q. Okay. Then you wrote, "I have seen

towels and washcloths and socks put in K's face

and mouth when he spits by Laurie Tomassi and

Sharon Butler."

A. Um-hmm.

Q. Is that true?

A. That is true.

Q. And can you describe that?

A. Yup. I can. Yes. I can. He would

often spit if he was upset for, you know,

whatever reason. And, I mean, he spit on

himself. He couldn't even spit. So, why this

bothered them so much. I think, again, it was a

control thing, but he would spit and they would

tell him, "We don't spit here on 9D. We don't do

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that on 9D," and they would shove whatever, the

sock, the washcloth, the towel in his face, in

his mouth and tell him, that we don't spit on 9D,

we don't do this here.

Q. And would K sometimes gag when they

stuffed --

A. Yeah.

Q. -- socks and washcloths into his mouth?

A. Yeah.

Q. And can you describe what would happen

when Laurie Tomassi and Sharon Butler would stuff

socks and washcloths in K's mouth and he would

gag? Could you just describe that, what did you

see?

A. Describe what K looked like?

Q. What K did and what they did.

A. If K spit, they would get a washcloth and

towel, like I said, and put it in his face, in

his mouth, and tell him, "We don't do this on

9D," and K would, you know, back up, gag.

I'm not sure that I'm understanding your

question.

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Q. And how long would that last? Maybe I

should ask that.

A. Five to ten seconds.

Q. So, was this another way for staff to

assert control over K?

A. It appeared that way.


Q. And you wrote, "I have also seen Laurie

and Sharon hit K with towels." Is that true?

A. That is true.

Q. And that's Laurie Tomassi and Sharon

Butler?

A. Correct.

Q. And can you describe, can you describe

that?

A. Yeah. Again, in an effort to keep him on

the mat they would wrap up a towel and they would

fling it at him and hit him with it (indicating).

Q. And where would they hit K with the towels,

if you remember?

A. I don't remember. Wherever was -- it

wasn't -- they weren't aiming for any specific

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spot. They would roll up the towel and hit him

with it. K would continue acting or and they'd

probably hit him again or he would cower back and

cower in the corner. It was no really -- those

were the two -- he would either continue and they

would continue or he would cower back and they'd

"win."

Q. Did Laurie Tomassi and Sharon Butler hit

K with towels hard enough that you would expect K

to experience pain?


A. Yes.

Q. And when K would cower back away from

Laurie and Sharon after they hit him with a towel

what would he do? Where would he go?

A. There wasn't much room for him to go

anywhere because, like I said, it was a corner.

He would, you know, again, it was hit or miss.

He would either stay there fearful. He might

spit. He might bite himself. He might rip his

clothes off. He was very spontaneous. K had a

variety of behaviors, a variety of reactions. Am

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I answering the question?

Q. Yes. I just want your memory.

A. Okay.

Q. And I meant to ask you before when -- how

would K respond when Sharon Butler or Laurie

Tomassi or Lisa Taylor and Eric Sadlon would hit

him with a stick?

A. The same way he would respond with a

towel. He would either cower back or continue

like trying to do whatever his original intention

was. If that was to get off the mat, he may

continue. He may self-injure himself by biting

himself, banging his head. I can't recall what

other behaviors he had. I definitely remember

him banging his head and biting himself in

response to those things. I remember him

spitting in response. I remember him cowering

back in response, um.

Q. And how often did Sharon, Laurie, Lisa

and Eric hit him with a stick, how often would

this happen?


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Compound.

A. I don't recall specific number of times.

Q. Well, let me put it this way, when you

would have a shift and K was there --

A. Um-hmm.

Q. -- on a typical day would one or more of

these staff members be hitting K with a stick?

A. If they were assigned to him?

Q. Yes.

A. Yes. On a typical, yes, that was

typical. And if it wasn't with the stick, they

would hit him in some way or, yes, they would

either -- the towel, the socks, some, one of

those behaviors, one of those actions was very

typical to happen when they were assigned to him.

Q. Did staff sometimes scream at K in order

to get him to stay on the mat?

A. Yeah. They yelled at him. Get back on

the mat.

Q. And who did that?

A. Oh, I don't know. I don't recall

specifically right now.

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A. Bill Murray. Yeah. I don't remember the

specific conversation.

Q. And when you came back, you came back I

guess on October 22nd, 2010?

A. Yeah. That's the date on these.

Q. And who did you see on October 22nd?

A. I believe it was Bill Murray again.

Q. And when you were there on October 22nd,

2010, did you write out a couple more statements?

A. Yes.

Q. So, let's look at AG 5561 in Exhibit 277.

A. 5561. 5561?

Q. Yes.

A. Okay.

Q. Okay. And is this your handwriting?

A. Yes. It is.

Q. And is this a true statement as well?

A. Yes. It is.

Q. And you wrote, "On a Wednesday within the

past few weeks I was working on 9D. I think it

was the same day as the morning fire drill. K

was sitting on the couch. K was spitting.

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Harshanie was on the unit and walked over to K

and bent his fingers backwards. She made a

comment to me along the lines of, 'Don't worry, I

won't leave a mark you will have to write up.'"

Did I read that correctly?

A. Yes.

Q. And is that all true?

A. Yes.

Q. And you saw that yourself?

A. I did.

Q. Is Harshanie, Harshanie Boadnaraine?

A. I have no idea what her last name is.

Q. Was she -- well, how would you -- was she

a young sort of --

A. Indian. I don't know how old she was.

Her first name was Harshanie. I don't know of

any other Harshanie's that worked there.

Q. All right. All right. And I think you

testified that she was usually 9C but occasionally

did a shift in 9D?

A. Correct.

Q. And so can you just describe what Harshanie

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Boadnaraine did?

A. On this? Yes. K was on the couch where

the mat would have been behind him. He was on

the side closest to where the TV was on the wall.

He was here (indicating). I don't know if that

helps. Anyhow, I was assigned to K that morning.

I went over and I'm not sure if she had been

there from the previous night and had done the

night shift, if she had just come over from 9C,

if she was there visiting. I really don't know.

She was there. She walked up to K, who wasn't

acting out or doing anything, and bent his

fingers on his hand backwards and then made a

comment to me that, don't worry, you won't have

to write this up, I won't leave a mark, you won't

have to write this up. And then she walked away

and went and talked to Cathy Chotkowski.

Q. Okay. So, when Ms. Boadnaraine bent K's

fingers backwards, was that deliberate?

A. Yes.

Q. And how far did she bend his fingers

backwards?

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A. I mean far enough that, pretty -- I don't

know.

Q. Far enough to cause him a lot of pain?

A. Yes.

Q. And how did K respond when Harshanie --

A. He pulled away.

Q. And can you describe how he pulled away?

A. He tried to pull his hand away and he

backed up. He was on the couch and he was

pulling away from her and he pulled away.

Q. Would you describe Ms. Boadnaraine's --

would you describe this as abuse?


Q. Cruel?

A. Yes.


Q. Inhumane?


A. Yes.

Q. Disgusting?

A. Absolutely.


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Q. I believe in one of your prior statements

you said that you believe that these defendants

all treated K like an animal?

A. Yes. I -- yes. I agree. I don't know

if I've written it, but I've said it.

Q. Okay.

A. If I haven't written it.

Q. And can you describe, you know, why you

believe --

A. Because I think everyone else they

treated like a person. They didn't make them

stay on the ground on a mat. They didn't keep

them in a corner. They didn't take their food

away. They didn't call them names. They treated

them as humans.

Q. Other individuals?

A. Other individuals.

Q. So, how did they treat, how did these

defendants treat K like an animal?

A. K was put on a gym mat to stay and told

to stay in a corner the size of a gym mat. It

was not a large area. He was supposed to stay

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there. His food was withheld. I guess -- you

know what, I guess worse than an animal. I don't

know. An animal -- I say an animal because I'm

saying less than a human. He was treated awful.

I don't know -- I'm not sure I'm answering your

question.

Q. Okay. When K was on that mat did these

defendants give him things to play with, things

to do or did they just have him sit there?


A. They had him sit there. Occasionally --

you know what, occasionally he had a blanket.

Q. Okay. Other than the occasional blanket

the defendants just had K sit there on the mat?


A. Correct.

Q. Hour after hour?

A. Hour after hour.

Q. Doing nothing?

A. Doing nothing.

Q. While they just ignored him and watched

television?

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A. Correct.

Q. And then when he tried to get off the mat

they would?

A. Direct him back on the mat by hitting

him, yelling at him. Well, Eric was able to

verbally sometimes get him back on the mat.

Usually it was hitting him with the towel, stick.

If he spit, it was the sock, the washcloth in his

mouth. Yeah. That was their interactions.

Q. Did anyone from the investigations unit

explain to you that administrative leave is

usually for people accused of misconduct not the

people who --

A. No. I was told --

Q. -- report misconduct?

A. No.

Q. Now, just to finish this. On October

22nd, 2010, you also signed one more statement

involving a time when K and, I guess, one or two

staff members -- there was some sort of restraint?

A. Yes.

Q. In which you saw a staff member, Tom

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do different things. He would cower back for

maybe five minutes, maybe even less than that,

maybe even -- he would crawl off the mat again

and he would do it again and he'd stay back

longer. He had different behaviors when he was

hit.

Q. And sometimes when he was hit was he

cowering back for as long as an hour?

A. Yes.

Q. And cowering like in a corner of the mat?

A. In the corner of the actual walls.

Q. How would he be, like a fetal position or

how would you describe cowered?

A. Yeah. I wouldn't -- I guess. His hands

would be up and his legs would be up. He would

be guarding himself. His knees would be bent,

like that's what I mean by up.

Q. Now, the part where Bill Murray says,

"I'm a big boy, you can hit me with the stick,"

was that before or after the video?

A. The whole thing was before the video.

Q. Did you give any sort of written

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Q. Is that all true?

A. That is all true.

Q. "Question: What did that do to him?"

And you said, "He would, I saw him cry

before. He usually like cowered back into the

corner." Is that true?

A. That's true.

Q. And you said, "Sometimes he would, you

know, like I said, I saw him cry a couple times.

Sometimes he would just look like, what are you

doing. Sometimes he'd back up, go into the

corner and kind of cover himself." Is that all

true?

A. True.

Q. Those are all ways K reacted when these

staff hit him with the stick and confined him to

the mat?

A. Yes.

Q. And you said, "He got hit and then it

hurt. I mean, I don't know how much more than

that he knew." And then you said, "Well, it had

an effect on him. Okay? Yeah. It absolutely

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had an effect."

Do you believe when the staff hit him

with a stick it absolutely had an effect on K?

A. Yes.

Q. And that he got hurt --

A. I --

Q. -- like he was in pain?

A. Yes.

Q. And you told the police, this is about a

minute and 55:35, one employee, Sharon Butler,

who had worked there I think 21 years, she told

me you'll do just fine, just keep your eyes open

and your mouth shut. That was the nature of the

place. You don't tell on anybody. You shut up."

A. That is true.

Q. And so when you were at O.D. Heck in Unit

9D --

A. I was told by Sharon Butler that I would

be fine if I kept my eyes open and my mouth shut.

Q. Meaning don't report abuse?

A. Yes.

Q. At another point with the police, I

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believe about a minute, 59:15 seconds you said,

"There was another thing that was disturbing to

me with K. K had a huge black eye at one point,

when I say huge, I mean, huge, his whole eye was

black and blue. K is African-American, but he is

light skinned and it was purple and it was his

whole eye. And they did bring him to the

emergency room and when they came back I heard

her saying, oh, my God, what happened to him, and

it was like hush, hush, shut up." And is that

true?

A. That is true.

Q. And who said, "Oh, my God, what happened

to him"?

A. Me. I said that. And Sharon Butler told

me to shut up.

Q. Okay.

A. Not to say anything. She said, "He

fell." And I said, "He fell on his eye?" And

she said, "He fell."

Q. And you believe that Sharon Butler

didn't -- was just telling you that's the story?

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A. She wanted me to stop talking.

Q. Sharon Butler wanted you to have the

story he fell?

A. Yes.

Q. But you believe Sharon Butler knew that

he, K didn't fall at all?


A. Clearly.

Q. Okay. And then also in June 2011 you

spoke with someone at the New York Times, right?

A. Correct.

Q. And why did you do that?

A. Because no one was doing anything. No

one was listening to me. No one was changing

anything. No one cared. There was a non-verbal

individual getting hit by sticks and abused and

no one cared. So, I thought maybe, you know,

they might care after it's in public view.

MR. MAAZEL: Okay. Off the record

for a second.

(Whereupon, a discussion was held

off the record.)

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washcloth in his mouth and he was spitting and

she said, "We don't spit on 9D and this is what

happens to you when you spit on 9D and she was

shoving the washcloth"; is that all true?

A. That is all true.

Q. And who said, "We don't spit on 9D. This

is what happens," was that Sharon or Laurie or

both?

A. They have both said that.

Q. To K --

A. To K.

Q. -- as they were shoving a washcloth into

his mouth?

A. Yes.

Q. Okay. And then you also told the

Inspector General something about when family was

visiting they would put on a show?

A. Um-hmm.

Q. Is that family of KC?

A. Yes.

Q. So, can you describe that?

A. They visited once when I was there.

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Q. "They" being?

A. K's family. I know his mother was there,

his brother was there. I'm not sure who -- I

think one was his sister and there was, I

believe, another girl. I'm not sure who she was.

I don't recall. But Sharon had K that day and

she dressed him up all nice, cleaned him up, made

sure he had a clean pull up. He was not on the

mat. He was sitting on the couch. They talked

to him like he was a person for the day, which

was not a typical occurrence. Especially for

Sharon. Yeah. She acted like, like she enjoyed

him.

Q. In front of the family?

A. In front of the family.

Q. And what was your reaction to the show

that Sharon and others were putting on?

A. It was sickening because it was fake.

Q. And who was putting on this show?

Sharon, was there anyone else you remember

putting on the show?

A. I don't recall who else was there, but I

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know Sharon was assigned to him and I know that

she had him sitting on the couch and was talking

like, like it wasn't even her. Like, she was,

you know, a completely different person that day

while his family was there.

Q. Okay. Were there times when some of the

defendants in this case talked about a Heartspring

video?

A. Yes.

Q. And tell us about that.

A. Apparently there was a video that came.

I never saw it, but there was a video that came

from -- is the Heartspring video the video that

came from Kansas where his previous placement

was?

Q. Kansas. A video from Kansas, Heartspring

video.

A. Yes. Okay. Apparently there was a video

that came and it showed him in the video and I

guess he was -- I didn't see it. So, this is all

secondhand, what they said, but they said he was

happy in the video and they had him --

Documents

Deposition Excerpts.pdf”