Mr. Pierce.

operators, and in building maintenance also called--that's a step above building maintenance six, technically speaking.

Mr. Hubert.

Now, those two buildings actually join together----

Mr. Pierce.

Right.

Mr. Hubert.

They join, as I understand it, in several ways, and I would like you to explain first of all how a person who is--was on the first floor of the municipal building could get to the other building, the police building?

Mr. Pierce.

On the first floor of the municipal building?

Mr. Hubert.

Right. How could he get through under normal circumstances?

Mr. Pierce.

To the first floor of the police and courts building?

Mr. Hubert.

Or to any part of the police building?

Mr. Pierce.

Police department. Very well, sir; simplest way would be to take the first floor corridor of the municipal building which goes immediately to the police and courts building. On the weekends, however, on this particular day; that is on the normal operation any day of the week they are connected and open, and on the weekends, or after regular municipal building hours in every night there is an expansion type steel gate closes that municipal building off, the corridor.

Mr. Hubert.

Does it lock?

Mr. Pierce.

From the--it remains locked.

Mr. Hubert.

But was it locked that day?

Mr. Pierce.

It was locked.

Mr. Hubert.

Did you test it yourself?

Mr. Pierce.

Possibly I did.

Mr. Hubert.

Could anyone open it but yourself?

Mr. Pierce.

I don't have the only key.

Mr. Hubert.

Did you see that door open?

Mr. Pierce.

To my knowledge, that door was never open the entire day.

Mr. Hubert.

And you did test it to see that it was locked?

Mr. Pierce.

It was locked.

Mr. Hubert.

Did you test it prior to the shooting?

Mr. Pierce.

Not prior to the shooting.

Mr. Hubert.

You----

Mr. Pierce.

I saw that the gate was across the corridor, as it should be. I was on the first floor, a matter of walking about as far as from here, a little further to the wall, and I didn't walk up to it prior to the shooting to see that it was locked, but it was in place and latched.

Mr. Hubert.

Could have been open?

Mr. Pierce.

It was locked. That lock--when that latch was engaged, it was in place, latched.

Mr. Hubert.

From what you could see of it, then--although you didn't come up to it, but came to within a distance, which I suggest to you now from the reference you made a moment ago was about 40 feet, 30 feet?

Mr. Pierce.

60 foot, probably.

Mr. Hubert.

You came to within 60 feet of it, and you saw that the latch was in?

Mr. Pierce.

In place and latched, and in that position the door is locked.

Mr. Hubert.

It is locked and you would need a key to open it?

Mr. Pierce.

That is my sworn statement.

Mr. Hubert.

Right. And you did not open it?

Mr. Pierce.

I never saw it open at any time.

Mr. Hubert.

And you did not open it yourself?

Mr. Pierce.

No; but like I say; I checked it, but it was after we knew that everything had happened, and all of sudden, security got to be of such an utmost importance, or the urgency of security was such that I pulled on it to see if it was, but when you said, "prior to,"---prior to that time, I hadn't, but I do know it was latched at that time. Was actually locked when I checked it manually to see if for some peculiar reason the latch was open.

Mr. Hubert.

What you are saying, in effect, is that while you actually tugged on the door after the shooting and found it to be locked, that your check of it prior to the shooting was visual, but that in your opinion it was in a position that it was locked?