(Testimony of Cecil E. Talbert)
Mr. Hubert.
to have a 3-day written notice personally directed to him prior to the taking of his deposition, but the rules also provide that any witness may waive that 3-day written. notice if they wish.
Captain TALBERT. I wish to waive.
Mr. Hubert.
I will ask you now if you are willing.
Captain TALBERT. Please.
Mr. Hubert.
Will you stand and raise your right hand? Do you solemnly swear that the testimony you are about to give will be the truth, the whole truth, and nothing but the truth, so help you God?
Captain TALBERT. I do.
Mr. Hubert.
Captain Talbert, you have previously given a deposition in this matter, which I think was on March 24, 1964, isn't that correct?
Captain TALBERT. I gave a previous deposition; yes, sir. The date is correct.
Mr. Hubert.
For that reason, I will not make any attempt to take any information concerning who you are and so forth. I take it you are still with the police department in the capacity you were when your deposition was last taken?
Captain TALBERT. Yes, sir.
Mr. Hubert.
Now, I want to inquire about a number of matters that were touched upon, I think, last time concerning which we need some elaboration, and that is the reason for calling you back. As I recall the matter, you came on duty on November 24 early in the morning to relieve Captain Frazier, is that not so?
Captain TALBERT. That is true.
Mr. Hubert.
What time, do you remember, did you come on duty?
Captain TALBERT. I would have to give you an approximation, sir, between 6 and 6:15 a.m.
Mr. Hubert.
What shift was it that you were coming on?
Captain TALBERT. It is referred to as the second platoon, working days, as it operates from 7 to 3.
Mr. Hubert.
But you came on sometime before the actual beginning?
Captain TALBERT. Yes.
Mr. Hubert.
Captain Frazier was there when you came?
Captain TALBERT. Yes.
Mr. Hubert.
Now I understand also that you proceeded to set up certain security measures in the entire building?
Captain TALBERT. No, sir.
Mr. Hubert.
You did not? What security measures did you begin to set up in the morning when you got there?
Captain TALBERT. Later in the morning at approximately 9 o'clock I instructed Lieutenant Pierce to get squads in to set up security measures in the basement.
Mr. Hubert.
The basement being referred to as the automotive drive area and the area where the prisoner, if he were transferred, would be exposed? That is to say, the basement would be the two ramps and the parking area, is that correct?
Captain TALBERT. Yes, sir; and the approach to the jail.
Mr. Hubert.
It is actually below the first floor?
Captain TALBERT. Yes, sir.
Mr. Hubert.
You had not taken any kind of security precautions prior to that?
Captain TALBERT. No, Sir.
Mr. Hubert.
Now what security precautions did you initiate at about 9 o'clock, you say, on November 24?
Captain TALBERT. I instructed Lieutenant Pierce to--
Mr. Hubert.
That is Rio Pierce?
Captain TALBERT. Yes; Rio Sam Pierce. I instructed him to go over the detail and pull three squads from each of the three outlying stations and four from central stations to acquire as many men as possible by utilizing two-man squads, and search the basement area, clear it, and then keep it cleared of everything but authorized personnel.
Mr. Hubert.
Now did you do that--
Captain TALBERT. By basement area, let me refer back again to the area that we previously defined.
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