Mr. Pierce.

It is impossible for it not to have been locked.

Mr. Hubert.

It is impossible for it not to have been locked, and that was--that check was made prior to the shooting?

Mr. Pierce.

Prior.

Mr. Hubert.

How much prior? Do you know?

Mr. Pierce.

That would be difficult to say just exactly how much prior, but it was--to give an actual time on it, of course, when we went to the main floor, the first floor on the elevator prior to the shooting, in this corridor, that is a four-way corridor there. There is an information desk sits right in the intersection of the two corridors, and the several elevators is in the corridor that leads--that is the reason I say it takes a little describing because it was facing that corridor and that gate when you get off the elevator, and that was 9:30, probably 9:30.

Mr. Hubert.

All right, now, what other way is it possible to go from the first floor of the municipal building into the police building?

Mr. Pierce.

From the first floor to the police building, the only way from the first floor that you can get into the police and courts building is to leave the municipal building first floor, that is the only way you can get to it.

Mr. Hubert.

And go where?

Mr. Pierce.

And go either outside on the only other way you can get to it is to go outside on either Main Street or Commerce Street and go down to the police and courts building and use one of their entrances, or take the service elevator down to the basement, which you have the model here, and walk across that garage area and the ramp area to the basement. Two ways, but no other way you can get there from the first floor.

Mr. Hubert.

About--what about the fire escape stairs?

Mr. Pierce.

No fire escape.

Mr. Hubert.

Isn't there a fire ease where----

Mr. Pierce.

The enter--staircase, you still can't get there. It is impossible to get there, because that staircase is always locked from the municipal building. That stairway is inside the building proper. It is not an outside stairway • like this.

Mr. Hubert.

Yes; I understand.

Mr. Pierce.

And the entrance to it is always locked.

Mr. Hubert.

There are two staircases that open onto the main floor of the municipal building, isn't that correct, or three?

Mr. Pierce.

One on Commerce Street. One back in the building, and then another one up on Main Street which goes up into a second floor, but the see-end floor they are faced also with the same proposition on weekends, which you are speaking of here. That entire building is separated.

Mr. Hubert.

Well, now, as to both of those staircases, is it not a fact that they do not go down into the basement at all. Only one goes down to the basement?

Mr. Pierce.

Only one goes down to the basement?

Mr. Hubert.

And that one is a staircase just off the corridor on the Main Street side?

Mr. Pierce.

Right. That goes down.

Mr. Hubert.

Now, they have doors that--two doors, sort of swinging doors, are they not?

Mr. Pierce.

Not to the first floor; no, sir.

Mr. Hubert.

Can't you at all times use those doors to get into the staircase and go either up or down?

Mr. Pierce.

When you say "those doors," you are referring to the single door on each stairway, of which there are two, or still speaking of a one single door which leads to the stairway which goes down to the basement?

Mr. Hubert.

To the basement, the other two do not go down into the basement. It is the single that is what I mean, when I said you would have to leave the first floor and go down into the basement, you could take that stairway, so that a person getting into the main floor, can get to the police basement by using that stairway?

Mr. Pierce.

That's right. He can come down it and go out, but he cannot leave the basement area and go up, because it is always locked. The entrance to the building is locked. That door is always locked.