Gregory Kade Deposition Excerpts

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Q. Do you have a specific recollection of most of or any of the events that day before this call came in?
A. I'm not sure of what you're asking me?

Q. Do you recall what you did during the daytime hours on that July 3rd?
A. I don't.

Q. You heard Mr. Hajash this morning talking about the security job over at the Holiday Inn Express. I'm going to ask you some questions about that. How long had you been working that security position.
A. Not very long. I'm not sure.

Q. From what I understood this morning, was that a Department sanctioned job?
A. It was paid through the department.

Q. It wasn't a moonlighting job that the department didn't know about?
A. Oh, no.

Q. You were there wearing your uniform and with a cruiser on site. Am I correct?
A. That's correct.

Q. So in essence, the Department was okay with showing a law enforcement presence over at the Holiday Inn Express?
A. Yes.

Q. How long would your shift there typically be?
A. I think sometimes we split up into four hour blocks and sometimes it was eight.

Q. Do you recall on July 3rd if you were on an four hour or an eight hour shift?
A. I don't recall.

Q. Was that a regularly scheduled day off from your normal Department duties as a patrol officer?
A. Yes. I was off duty through road patrol.

Q. Do you recall if you worked the day before July 3rd?
A. I don't recall.

Q. Have you ever gone back to look at payroll records or schedule records or anything?
A. No.

Q. Do you recall what time your shift started that day or evening?
A. At the hotel?

Q. Yes.
A. I don't. I don't.

Q. Do you know if you were planning on being there most of the night? Was it a night rotation for you?
A. Night rotation? What do you mean?

Q. The hotel security job on July 3, were you going to be there the rest of the evening?
A. I don't remember if it was a full shift or not. I know it would have been at least four hours.

Q. Without pinning you to a time, can you recall if it was daylight or dark when you started that security job?
A. I'm not sure.

Q. Okay. Do you recall if you were close to the end of the shift when this call comes in sometime after midnight?
A. It possibly could have been close if it was a four-hour block.

Q. Did you have any active responsibilities at the hotel security job other than just be a presence there?
A, Just maintain the security and that's it.

Q. Was it something where you had to make rounds every so often and make sure doors were locked oryou know, things weren't being tampered with?
A. You really couldn't make rounds, no, because it was a construction area.

Q. Just your presence there --
A. Just your presence and just try to see around the building as much as possible.

Q. Do you remember what time then Deputy Hajash arrived at the hotel site and began a conversation with you that evening?
A. I don't.

Q. Can you give us an idea how long you believe he was there before the call came in from dispatch?