Mr. Hubert.

But, going the other way, that is to say, from the main building down to the basement via that staircase, you would need no key, and that door is open all the time?

Mr. Pierce.

Right, sir.

Mr. Hubert.

Even on weekends?

Mr. Pierce.

Right, sir. That is one of the other means?

Mr. Hubert.

Well, that leaves, I think, one other entrance to the municipal building, and the entrance in the back on the alleyway. Now, are you familiar with that entrance and that door?
Mr. PIERCE, Yes, sir.

Mr. Hubert.

Will you tell us about that--how that door operates?

Mr. Pierce.

It is a door--double door.

Mr. Hubert.

A double door?

Mr. Pierce.

Comes together and has a lock on it, which when locked is locked both from the inside-you can't get out, and the outside you can't get in.

Mr. Hubert.

So, when locked you need a key to go either way, is that correct?

Mr. Pierce.

That's right.

Mr. Hubert.

All right, now, suppose someone had a key and went out that door, and simply let the door slam behind him, well, would that door be, at that time, locked or unlocked?

Mr. Pierce.

It will be unlocked.

Mr. Hubert.

To lock it you must use a key to turn the lock?

Mr. Pierce.

You have to step outside the door and turn around and use your keys to lock it back.

Mr. Hubert.

And, if you don't do that, it is an open door?

Mr. Pierce.

It is an open door.

Mr. Hubert.

That is to say, it might be closed, but all you'd have to do is turn the knob and go on in?

Mr. Pierce.

That's what I mean. It is open until you take your key and relock yourself out. No one else can get in without a key.

Mr. Hubert.

Now, do you know whether anyone did go through that door from the first floor into the alleyway that day from your own knowledge?

Mr. Pierce.

Not from actually having seen them, but as a matter of my knowledge, I am quite sure that that door was opened and closed probably several times prior to the shooting because the porters work. In their normal assigned work, now, they take out trash and paper sacks and garbage and whatnot. Mr. Servance, the head porter, always has a key to that door for the removal of trash.

Mr. Hubert.

What is the custom with respect to locking or not locking the door when they routinely perform the porter duties?

Mr. Pierce.

The normal custom is to unlock the door and take their trash out, and their receptacle for the trash is immediately on the other. side of the door, and as a matter of habit and routine, while they are they take a garbage can out on four- wheel dollies and leave the door open there until they can set the cans over in there, or as close as from here to that door from the door-they have just left open, and they set the full cans off onto the dolly and pick up the four clean cans and set them back on the dolly and push them back into the building, and it is only for that period of time, but they relock it when they come back in.

Mr. Hubert.

But, normally, it is an open door while they are performing----

Mr. Pierce.

While they are performing their duties.

Mr. Hubert.

Do you know whether the Main Street entrance to the municipal building was locked that day?

Mr. Pierce.

It was locked; yes, sir.

Mr. Hubert.

You tested it yourself?

Mr. Pierce.

And I inadvertently did. Not purposely, for any purpose, but I did.

Mr. Hubert.

You say that you inadvertently did?

Mr. Pierce.

And I am glad it happened that way.

Mr. Hubert.

Well, tell us about that, briefly.

Mr. Pierce.

The Main Street door is comprised of a revolving door with two