IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

JAMES P. CHASSE, JR.; JAMES P. )
CHASSE; LINDA GERBER; and MARK )
CHASSE, individually and in his )
capacity as Personal Representative )
of the ESTATE OF JAMES P. CHASSE, )
JR.. )
Plaintiffs, )
V. )NO. CV-07-0189-HU
CHRISTOPHER HUMPHREYS; KYLE NICE; )
CITY OF PORTLAND; CITY OF PORTLAND )
JOHN DOE FIREFIGHTERS/PARAMEDICS; )
PORTLAND POLICE BUREAU and OTHER )
PORTLAND JOHN and JANE DOE )
OFFICIALS; BRET BURTON; MULTNOMAH )
COUNTY; MULTNOMAH COUNTY JOHN and )
JANE DOE DEPUTY SHERIFFS and MEDICAL)
PERSONNEL; MULTNOMAH COUNTY JOHN and)
JANE DOE SHERIFF'S OFFICE and OTHER )
OFFICIALS; TRI-COUNTY METROPOLITAN )
TRANSPORTATION DISTRICT OF OREGON; )

and AMERICAN MEDICAL RESPONSE )

NORTHWEST, INC., )

Defendants. )

DEPOSITION OF
ELIZABETH A. ANDERSON
Taken in behalf of Defendants

July 17, 2008

1211 S.W. Fifth, Suite 1900
Po on
Shannon K. Krska, CSR
Court Reporter
400 Columbia, suite 140
Vancouver, WA 98660
Schrmtt&Lehmann,Inc. 121 sw Morr~aonst., Suite 850
Portland,OR 97204
C O U R T R E P O R T E R S
13601 695-5554 15031 2234040
Fox (360) 695-1737 [Link] slinc@[Link]
Elizabeth A. Anderson, 7/17/2008 Chasse v. Humphreys, et al.

APPEARANCES:
For the Plaintiffs: MR. THOMAS M. STEENSON
Attorney at Law
815 S.W. Second, Suite 500
Portland, OR 97204

For the Defendants MR. JAMES RICE

Humphreys, Nice, and Attorney at Law
City of Portland: 1221 S.W. Fourth, Suite 430
Portland, OR 97204
For the Defendants MS. SUSAN DUNAWAY
Burton and Multnomah Attorney at Law
County: 501 S.E. Hawthorne, Suite 502
Portland, OR 97214

For the Defendant MS. JEAN BACK

AMR: Attorney at Law
1211 S.W. Fifth, Suite 1900
Portland, OR 97204
INDEX
EXAMINATION BY: PAGE NO.
Mr. Rice 3 - 34
Ms. Dunaway 35 - 42
Ms. Beck 42 - 47
Mr. Steenson 48 - 50
Ms. Beck 50 - 52

EXHIBITS
[None marked.I

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1 PORTLAND, OREGON; THURSDAY, JULY 17, 2008
2 11:OO AM
3 * * *
ELIZABETH A. ANDERSON
called as a witness in behalf of the Defendants,
having first been sworn by the Reporter,
testifies as follows:
EXAMINATION
BY MR. RICE:
Q. Good morning, Miss Anderson.
A. Hello.
Q. I'm Jim Rice. We just met each other. And
I'm an attorney. I work for the City of Portland.
A. Okay.
Q. And we're here to take your deposition
today. Do you understand that?
A. Yes.

Q. Have you ever had your deposition taken

before?
A. NO.
Q. Have you ever testified in court on
anything?
A. NO.
Q. Has anyone had the chance to talk to you
about what a deposition is?

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A. Yes.
Q. And who have you talked to about that?
A. This gentleman.
Q. Mr. Steenson?
A. Yes.
Q. And did you meet with him before today?
A. Yes.
Q. And when did you meet with him?
A. On Monday.
Q. On Monday?
A. M-hm.
Q. Okay. Did he explain to you that it's a
question-and-answer format?
A. Yes.
Q. And to help our court reporter take down
everything accurately we try and do a couple things.
One is sometimes we nod or shake our heads and the
other person knows what that means, but the court
reporter - -
A. Okay.
Q. - - needs like a verbal answer so she can put
that down.
A. Okay.
Q. No. 2, I'm going to let you finish your
answer before I start to ask my next question. I may

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1 misunderstand that but I'll try not to talk over you.
2 And I would ask you to wait for a pause before I
3 complete my question so the court reporter can
4 accurately take down both the question and the answer.
5 A. Okay.
6 Q. All right. Is there any reason you can't
7 take your deposition today such as you are ill or on
8 prescribed medication, didn't get enough sleep,
9 anything like that, to give us your best answers --

10 A. No.
11 Q. - - here today?

12 And if you were to be asked a question today

13 and let's say the case goes to trial and you were
14 actually called as a witness at trial, if you answered
15 a question differently at trial than you answered here
16 today, the lawyer, whoever it is, would have a right
17 to point that out to the jury. Do you understand
18 that?
19 A. Yes.
20 Q. So it's important that you understand my
21 question. And if I ask a question that you don't
22 understand, maybe it's got a word in it or it's just
23 garbled perhaps, too, would you stop me and say I
24 don't understand your question and I will try and
25 rephrase it?

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1 A. Yes.
2 Q. Is that okay?
3 A. Yes.
4 Q. Great.
5 Lastly, if you want to take a break at any
6 time, a glass of water or anything like that, after a
7 question has been answered you can just say I need to
8 take a five-minute break and you can stand up and
9 we'll go from there. Good enough?
10 A. Yes.
11 Q. All right. Would you tell the court
12 reporter your full name, please.
13 A. Elizabeth Ann Anderson.
14 Q. And have you gone by any other names?
15 A. My maiden name, Elizabeth Ann Salisbury.
16 Q. And what was your maiden name?
17 A. Elizabeth Salisbury, Elizabeth Ann
18 Salisbury.
19 Q. And how do you spell that?
20 A. S-A-L-I-S-B-U-R-Y.
21 Q. Okay. What's your date of birth?
22 A. 9-14-75.

23 Q. Okay. And how tall are you?

24 A. Approximately five four.
25 Q. All right. And where were you born?

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1 A. Fairfax, Virginia.
2 Q. All right. And how long have you been in
3 the Portland metro area?
4 A. Around 1 5 years.
5 Q. Okay. Did you graduate from high school?
6 A. Yes.
7 Q. And where did you do that?
8 A. Spokane, Washington.
9 Q. Okay. And after you went to high school,
10 did you have any kind of additional education or
11 training of any kind?
12 A. Yes.
13 Q. And what was that?
14 A. I graduated from cosmetology school.
15 Q. Okay. And where was that?
16 A. Here in Portland.
17 Q. Okay. Are - - is there more than one kind of
18 a degree someone gets when they graduate from
19 cosmetology school? Seems like it's a pretty broad
2o field.
21 A. Yes.
22 Q. And what kind of a degree did you get?
23 A. I am certified as a hairstylist and
24 esthetician.
25 Q. Okay. And the esthetician part of it, what

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does that entail doing?

A. A skin care specialist.
Q. I gotcha, okay.
If you graduated from school and then went
to work, is there any sort of state licensure or
anything like that that takes place?
A. Yes.
Q. And what kind of a license is that?
A. There's a practical examination as well as a
written examination that you take in Salem.
Q. Okay. And did you take that test and pass
it?
A. Yes.
Q. And when did you do that? When did you get
your certification is what I'm going to call it?
A. Approximately ten years ago.
Q. Okay. And do you have any other formal
education beyond that?
A. A bit of community college.
Q. Okay. And what did you study in community
college?
A. General studies.
Q. Okay. Did you ever get a degree from them?
A. NO.
Q. Okay. Anything else we've not talked about

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1 in terms of education?
2 A. No.
3 Q. Can you go -- kind of go through the last
4 maybe five years of your work history, what that
5 consists of.
6 A. Most recently, for almost two - - in I think
7 August it'll be two years that I've been employed at
8 Rudy's Barbershop.
9 Q. Okay.
10 A. Prior to that I was working at Bishop's
11 Barbershop, and prior to that I was working at a salon
12 downtown called Tonic.
13 Q. Okay. So you've been working downtown in
14 the hairstylist business for approximately five years;
15 is that right?
16 A. Yes, at least.
17 Q. Okay. So the date in question we have here
18 is in September of '06, so you had been working at
19 Rudy's for about a month when this happened?
20 A. M-hm.
21 Q. Is that right?
22 A. M-hm.
23 Q. Okay. Back in September of '06, did you
24 require either a hearing aid or eyeglasses or contact
25 lenses, anything like that, to assist you with either

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1 seeing or hearing?
2 A. Yes. I wear contact lenses.
3 Q. Okay. And when the incident transpired you
observed with Mr. Chasse were you wearing your contact
lenses?
A. Yes.
Q. Do you have any hearing impairment?
A. NO.
Q. Have you ever been in the military?
A. No.
Q. Do you have any training in psychology?
A. No.
Q. How about any paramedic or EMT training?
A. NO.
Q. Medical training of any kind?
A. NO.
Q. Okay. Ever have any law enforcement
training?
A. No.
Q. Have you had any interaction with law
enforcement as an adult?
A. Yes.
Q. And can you describe what that consisted of?
A. When I - - well, when I was in my early 20s I
got a DUI.

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1 Q. How about ever even just calling the police
2 by using a 9-1-1 system or anything like that?
3 A. Yes, I have.
4 Q. Aside from the DUI, would you describe the
5 kinds of interaction you've had with law enforcement?
6 A. Aside from that, I - - my ex-husband was
7 physically abusive and I called the police one night.
8 Q. Okay.
A. And had him - - had to have him removed from
our home.
Q. Okay. And did they respond?
A. Yes, they --

Q. Was that here in Portland --

A. Yes.
Q. -- or someplace else.
It was in Portland?
A. Yes.
Q. Did they generally behave appropriately that
evening?
A. Oh, yes.
Q. Okay.
A. They were great.
Q. Any other interaction with law enforcement
other than that?
A. NO.

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Q. Okay. Prior to the date you observed

Mr. Chasse in the Blue Hour area - -
A. M-hm.
Q. - - had you ever met him or seen him?
A. No.
Q. Have you had any contact with any members of
the Chasse family?
A. No.
Q. Have you given statements, prior to today,
to any person or entity regarding what you observed
that day?
A. Can you rephrase the question?
Q. Sure.
You observed Mr. Chassels interaction with
police or emergency people back in September of ' 0 6 - -
A. Yes.
Q. - - is that right?
A. Yes.
Q. After that date, did anyone come to you and
take a statement from you; an investigator, a police
officer, grand jury, anything like that?
A. Yes.
Q. Could you tell me about that?
A. Two detectives came to Rudy's right -- after
the incident, I don't remember if it was the next day

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1 or a few days after, and took a statement from
2 myself - -

3 Q. Okay.
4 A. --yes
5 Q. Any other people take statements from you?
6 A. Do you mean specifically at the time of the
7 incident?
Q. No. Just since then, but regarding the
incident.
I mean, has someone come, for example, and
taken a taped statement from you or a video statement
from you, interviewed you in any way?
A. An investigator came to my house a few week
ago.
Q. Okay. And did you give that person a
statement?
A. Yes, I did.
Q. How about media, did the media ever come and
get a statement from you?
A. No.
Q. All right. Sometimes in our lives, either
through contact with family members, friends, other
things, we come into contact with people who have a
significant mental illness.
A. M-hm.

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1 Q. Have you had any contact like that?
2 A. No, I haven't.
3 Q. Okay. Let's talk about the incident with
4 Mr. Chasse. You remember that incident?
5 A. Yes.

6 Q. And that incident was on a Sunday I believe.

DO YOU --
A. Yes.
Q. - - agree with that?
A. Yes.
Q. Were you working that day?
A. I was.
Q. Okay. What were your hours that day you
were working?
A. 11 AM to seven PM.

Q. Okay. So Rudy's is open on Sundays; is that

right?
A. Yes, correct.
Q. Is it the kind of - - is it a salon, is that
what it is?
A. Yes.
Q. Okay. Does the salon take reservations
where people come in and also take people coming in
off the street or how does that work?
A. We take appointments day of and also

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1 walk-ins.
2 Q. Okay. Some salons are run by a person and
3 they -- when someone comes in they send them
4 somewhere, other people just keep their own book is
5 what I would call it.
6 A. M-hm, m-hm.
7 Q. Do you maintain your own client base - -
8 A. NO.
9 Q. -- or does it come through Rudy's?
10 A. I'm an employee of the company, yes.
11 Q. And about what time of the day do you
12 believe you saw Mr. Chasse's incident with the police
13 officers?
14 A. It had to be five o'clock or after.
15 Q. Okay. And what was the first thing where
16 you thought something was going on?
17 A. Well, the arrival of police cars coming up
18 the street.
19 Q. Okay. Could you see them coming up off the
20 street or did you hear them or what was the first
21 indicator to you?
22 A. Just seeing them pull up. There was a large
23 window.
24 Q. And when - - if someone walks into Rudy's
25 there's a window that you could look out into the

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1 s t r e e t ; i s that right?

2 A. M-hm.

3 Q. And which s t r e e t does it look o u t on t o ?

4 A. 13th.

5 Q. And a r e t h e r e a number of I ' m going t o c a l l

6 j u s t s t a t i o n s f o r l a c k of a b e t t e r - -

7 A. Sure.

8 Q. - - term where d i f f e r e n t people work? Is

9 that right?

10 A. Yes.

11 Q. How many s t a t i o n a r e t h e r e a t Rudy's?

12 A. I t h i n k t h e r e a r e seven.

13 Q. Okay. And a r e t h e r e seven - - i s a s t y l i s t ,

14 i s t h a t what you would c a l l y o u r s e l f ?

A. Yes.

Q. Are t h e r e seven s t y l i s t s t h a t work t h e r e o r

a r e t h e r e more s t a t i o n s t h a n t h e r e a r e s t y l i s t s ?

A. There a r e more s t y l i s t s t h a n t h e r e a r e

stations.

Q. Okay. Do you always work a t t h e same

s t a t i o n o r does t h a t change from day t o day?

A. I t changes.

Q. Do you remember which s t a t i o n - - a s you I r e

coming i n t h e door, what s t a t i o n - - how would you

d e s c r i b e what s t a t i o n you were a t ?

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1 A. I don't recall on that day.
2 Q. Okay. Were you actually working on a -- is
3 a client the term?
4 A. Yes.
5 Q. Okay. Were you working with a client when
6 you first heard or saw some commotion?
7 A. No.
8 Q. Okay. Were you waiting for someone to come
9 in?
10 A. No. Myself and some of my coworkers were
11 sitting outside.
12 Q. Okay. Sort of taking a break; is that
13 right?
14 A. Yeah. Well, yes.
15 Q. And when you go outside, is it on ground
16 level or is it raised?
17 A. It's raised.
18 Q. Okay. Is that a raised platform off the - -
19 off the sidewalk itself?
20 A. Yes. It's a platform that runs the length
21 of the building.
22 Q. Okay. And about how high do you think that
23 is off the ground?
24 A. Oh, six feet.
25 Q. Okay. So when you saw police cars arriving,

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did you notice Mr. Chasse?

A. Not immediately.
Q. Okay. When you saw the police cars arrive,
what did the officers inside the cars do?
A. Well, we - - we went outside and we saw like
that there was like police cars around and the - - they
were already out of their cars --

Q. Okay.
A. -- yeah.
Q. All right. And when you get outside and the
police officers are outside their cars, what did you
see?
A. It seemed to me like - - it seemed to me like
they were like milling around and kind of talking with
each other.
Q. Okay. Could you hear what they were saying?
A. No, not specifically.
Q. All right. Did you next see them doing
something or did you see Mr. Chasse? What's the next
sort of chronological thing that you observed?
A. My coworker and I walked down to the end of
the platform where Blue Hour is.
Q. Okay. So that would be the intersection
then of Everett and 13th; is that right?
A. Correct.

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1 Q. Okay. And who were you walking with?
2 A. David Lillegaard.
3 Q. All right. So you and Mr. Lillegaard walked
4 to the - - sort of the edge there where the two - -
5 A. Yes.
6 Q. Does the platform continue onto Everett
7 Street or does it end?
8 A. No, it ends.
9 Q. It ends there
10 A. There's a staircase going down.
11 Q. So are you at the staircase at that time?
12 A. Yes
13 Q. Are there other people there as well?
14 A. Yes.
15 Q. And are they on the stairs themselves?
A. I don't remember specifically.
Q. Okay. When you got to the end with
18 Mr. Lillegaard, what did you see?
19 A. Mr. Chasse laying face down in the street
20 Q. Okay. And at that time, what did you notice
21 about him?
22 A. He was not moving. He had his arms and legs
23 bound
24 Q. And just indicating you put your hands sort
25 of behind your back --

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A. Yes.
Q. - - is that correct?

A. Correct.
Q. So were his hands behind his back?
A. Yes.
Q. And were his feet bound as well?
A. Yes.
Q. All right. Different people notice
different things about people.
A. M-hm.
Q. As a hairstylist, did you notice his hair?
A. I didn't.
Q. Did you notice his clothing?
A. It wasn't stand out to me.
Q. Okay. Was he saying anything at that time?
A. No.
Q. Was he moving at that time?
A. No.
Q. When you looked at him, was he outstretched
lying on his back, laying on his side, laying on his
stomach?
A. Face down.
Q. Face down to me would meaning lying on his
stomach?
A. Yes, correct.

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1 Q. And when a person is lying down on their
2 stomach - - and this is on pavement; is that right?
3 A. Yes.
4 Q. How would you describe the location of his
5 face, if you recall?
6 A. It seemed to be turned to the side.
7 Q. Okay.
8 A. I don't -- I don't specifically recall him
9 laying flat face down, but I'm not - - I'm not sure.
10 Q. Okay. And if someone - - and let's also say
11 this happened many months ago --

12 A. Right.
13 Q. -- and sometimes people's -- sometimes we
14 simply forget some details, too.
15 A. Of course.
16 Q. And if you don't remember I just expect you
17 to say I don't remember that detail.
18 A. Okay, yes.
19 Q. And what we're doing is sort of taking a lot
2o of small steps here - -
21 A. Okay.
22 Q. - - I'm trying to, in a chronological order.
23 So when he's lying on his stomach and you
24 think his head is turned - -
25 A. Yes.

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1 Q. -- would his face have been toward you or
2 away from you?
3 A. Away.
4 Q. Okay. And as -- as he's lying there, are
5 the police officers generally standing around him?
6 A. Yes.
7 Q. Okay. And are they saying anything at this
8 time that you recall?
9 A. Not that's audible.
10 Q. All right. And are there any EMTs or fire
11 people or medical people of any kind at the scene at
12 that time?
13 A. There was an ambulance as well as a fire
14 truck at the scene.
15 Q. Okay. They'd arrived at that point?
16 A. Yes.
17 Q. And could you tell, starting looking at what
18 I'm going to call law enforcement people as a general
19 term - -
20 A. Yes.
21 Q. - - were their uniforms all the same or do
22 you remember anything about the uniforms?
23 A. Not everybody's uniform was the same that
24 was in the group.
25 Q. Okay. Are there things you could talk to us

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1 about today or tell us about today distinguishing the
2 uniforms either by color or size or - -
3 A. I don't remember the detail.
4 Q. All right. Did you notice anyone who you
5 thought was either a fire bureau person or an EMT as
6 opposed to a law enforcement officer?
7 A. I didn't - - I don't -- that didn't make the
8 distinction.
9 Q. Okay. Sometimes we look at a group of
10 people and we can distinguish them by saying some were
11 male and some were female.
12 A. Correct.
13 Q. Could you make any distinctions by gender as
14 you looked at this group?
15 A. Yes. It seemed like there were a few
16 females present.
17 Q. A few females present?
18 A. M-hm.
19 Q. All right. And sometimes we can also look
20 at a group of people --

21 A. A female present.
22 Q. A female?
23 A. I don't - - yeah, I don't recall.
24 Q. Okay.
25 A. 1'11 -- 1'11 just go with that.

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1 Q. All right. Sometimes we also look at a

2 group of people and there's just something physical
3 about someone like someone's extremely tall or
4 extremely short or - -
5 A. I don't remember anything specific.
6 Q. Okay.
7 A. Pardon me, I'm sorry.
8 Q. All right. What did you observe happening
9 to Mr. Chasse as he is lying in the street with these
10 police officers and EMTs around him? Do you remember
11 seeing or recalling what they did?
12 A. It didn't seem like they were - - I didn't
13 see anybody attending to him. I didn't see anybody - -
14 I didn't - - it seemed like he was just lying there and
15 they were kind of milling around and then they kind of
16 like would nudge him with their - - somebody nudged him
17 with their foot.
18 Q. Okay. And do you recall whether that person
19 was an EMT or a police officer?
20 A. I don't remember.
21 Q. All right. And sometimes we use words and
22 we don't - - two people don't exactly agree on it. Was
23 it the kind of nudge where you're trying to get
24 someone's attention as opposed to a kick?
25 A. I wouldn't call it a kick.

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1 Q. You would not?

A. No. It was -- yeah, I guess more like, yes,
if you were trying to like wake somebody up or - -
Q. Okay, all right. And you don't know who
that person was; is that right?
A. No.
Q. All right. After that person nudges
Mr. Chasse, what's the next thing that you observed?
A. He continued to lie there.
Q. Okay. And did that -- did something
ultimately happen other than him simply lying there
and the officers and EMTs standing around?
A. I went at that point back up to the salon
and was more so situated in front of the salon versus
the position at Blue Hour.
Q. Okay. And when you were in that - - first of
all, how long do you think you were down at that --

you know, the end of the platform there by the stairs?

How long were you there, do you have an estimate?
A. I don't remember.
Q. Okay. And then you went back to -- did you
go back into the barbershop or you stood out in front
of the barbershop?
A. Outside.
Q. What did you?

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A. Also on the platform.
Q. On the platform. What did you observe from
that vantage point?
A. It seemed like after a while Mr. Chasse kind
of came to and started screaming.
Q. Okay.
A. It sounded like he was saying please help
me.
Q. All right.
A. He continued to scream.
Q. And when he's screaming, is it loud or soft
or is there some way of, you know, describing it?
A. It was loud and very guttural.
Q. Guttural?
A. M-hm.
Q. Using full breath, in other words?
A. I wouldn't say that. It just seemed very --

it seemed like he was in extraordinary pain.

Q. Okay.
A. Very animalistic.
Q. Animalistic sounding?
A. M-hm.
Q. And as he's beginning to make that noise,
are the people around him doing anything differently?
A. They - - I don't recall.

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1 Q. All right. How long did, if you have an
2 estimate, did that go on before something else
3 happened?
4 A. I don't have an estimate.
5 Q. All right. What's the next thing that you
6 observed?
7 A. They picked up Mr. Chasse - -
8 Q. Okay.
9 A. - - and carried him away.
10 Q. All right. Immediately prior to that, is he
11 still in the same position that he's been all along?
12 A. Yes.
13 Q. Okay. So his body essentially stayed the
14 same whether he was still or during the screaming
15 phase; is that right?
16 A. Yes.
17 Q. All right.
18 A. As far as I - - yes.
19 Q. All right. As best you recall?
20 A. Right.
21 Q. All right. And that's all we're asking for
22 today.
23 A. Okay.
24 Q. When he was picked up, did you actually see
25 that?

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1 A. Yes.
2 Q. Okay. How many people picked him up, if you
3 recall?
4 A. I don't recall.
5 Q. Okay. Do you know whether they were law
6 enforcement officers versus EMTs?
7 A. I don't.
8 Q. Okay. Do you remember how they picked him

10 A. Not specifically. I --

11 Q. And when the individuals picked him up, what

12 did they do with him?
13 A. They carried him away.
14 Q. All right. Did you see where he was carried
15 to?
16 A. A police car.
17 Q. Okay. And could you see him being placed in
18 the police car?

20 Q. So was the police car in -- in your visual

21 line of sight or was it around the corner?
22 A. I don't recall
23 Q. During the time that Mr. Chasse was being
24 picked up - -

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Q. -- could you either -- hear anyone in

uniform say anything?
A. I couldn't - - at no point could I
specifically make out what anybody specifically was
saying.
Q. Okay. And how about Mr. Chasse, how was he,
if at all, reacting to being picked up?
A. It seemed like he was in pain.
Q. And - - and how did he seem like he was in
pain?
A. Because he continued screaming.
Q. Okay. Could you see his face at this point
in time?
A. No.
Q. Okay. Did you ever see his face when he was
either lying on the ground or being carried away or at
some other point?
A. Not up close.
Q. Okay. Not up close?
A. NO.
Q. Okay. Did you ever see his face at all that
you actually recall?
A. I saw his face, but not like, you know,
close enough to make out detail or - -
Q. Okay. When you looked at Mr. Chasse, could

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1 you look and see this person somehow has an injury?
2 A. No.
3 Q. All right. After Mr. Chasse was carried out
of your view to --

A. M-hm.
Q. - - wherever he went, did - - what else did
you observe?
A. I went back inside at that point.
Q. Okay. Did you, after he'd been carried
away, look at the ground, either the sidewalk in front
of you or the street in front of you, anything like
that?
A. NO.
Q. Between you walking back inside - -
A. M-hm.
Q. - - and a police officer later talking to

you --

A. M-hm.
Q. - - about this incident, is there anything
else that you've not told us about today that you
remember?
A. No.
Q. Okay. I would assume that the day in
question you were working at Rudy's Barbershop, is it
true you didn't drink any alcohol that day?

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1 A. Yes.
2 Q. Okay. Were you on any prescribed medication
3 that day?
4 A. NO.
5 Q. When you went from the stair area and walked
6 back to the front of Rudy's, did Mr. Lillegaard come
7 with you?
8 A. I don't recall.
9 Q. Okay. When you were making the observations
10 that you've told us about --

11 A. Yes.
12 Q. - - today, you've told us about

13 Mr. Lillegaard.
14 A. M-hm.
15 Q. Is there anyone else you know of as a friend
16 or associate or work with that observed what was going
17 on?
18 A. Not that I'm aware of.
19 Q. Did you ever see anyone punch Mr. Chasse?
20 A. No.
21 Q. Did you ever see anyone strike Mr. Chasse in
22 any way - -
23 A. No.
24 Q. - - other than the nudge of the foot you told
25 us about?

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1 A. Yes, no.
2 Q. Did you see the EMTs, either an ambulance or
3 a fire truck, leave the scene?
4 A. I - - no, I don't recall.
5 Q. And as the police officers were leaving the
6 scene, am I correct you didn't speak with any of them?
7 A. NO.
8 Yes, you are correct.
9 Q. Is there anything that you heard Mr. Chasse
10 say that day that you've not told us about?
11 A. No.
12 Q. How about, did you engage in any
13 conversation with anyone -- is it a patio, is that
14 what you'd called that raised area?
15 A. I don't know. A platform is probably a more
16 accurate description.
17 Q. Okay. With regard to the people on the
18 platform or people on the street, did you engage in
19 any conversation that day with anybody?
20 A. Do you mean in general or - -
21 Q. Talk to them about what had happened, for
22 example.
23 A. Not -- not that I recall.
24 Q. Okay. From what you had seen that day - -
25 A. M-hm.

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1 Q. -- did you come to any conclusions about any
2 conditions that Mr. Chasse may have had?
3 MR. STEENSON: Objection, vague.
4 Q. (By Mr. Rice) He gets to do that for the
5 court reporter, but you can go ahead and answer the
6 question.
7 A. Okay.
8 I don't understand the question.
9 Q. Sometimes when a person's downtown they
10 observe someone else downtown and they might think
11 that person's mentally ill, that person is drunk as
12 they're walking down the street, that person's hurt
13 because their leg is limping as they're walking along.
14 A. M-hm.
15 Q. Sometimes we just arrive at conclusions at
16 people - -
17 A. M-hm.
18 Q. -- we see. What you observed of Mr. Chasse,
19 did you arrive at any conclusions about him?
20 A. No.
21 Q. Did you testify before the grand jury?
22 A. No.
23 Q. Aside from the DUI that you mentioned, have
24 you ever been convicted of a crime?
25 A. No.

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1 Q. Okay. We may at some point want you to

2 testify in court on some lawyer's behalf here.
3 A. M-hm.
Q. Could you tell us what your present address
is?
A.

Q. Okay. If we're going to ask a person to

testify in court some - - like we did today, we try not
to inconvenience people more than we already have to.
A. M-hm.
Q. And typically the way we get ahold of the
person today is either by cell phone or some other
best phone number. If we need to get ahold of you is
there a best phone number to do that with?
A. Yes.
Q. And what would that be?
A. .
Q. Okay. And that's all the questions I have
of you today.
A. Okay.
Q. Thank you for coming down. There's some
other lawyers here in the room and they may have some
questions for you.
A. Okay.

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1 EXAMINATION
2 BY MS. DUNAWAY:
3 Q. I just have a few questions.
4 You described the -- the sounds that
5 Mr. Chasse was making as being guttural or
6 animalistic.
7 A. Yes.
8 Q. What does that mean? Can you give me
9 something that we could both relate to that would give
10 me some idea of what you mean?
11 A. It just sounded, in my opinion, like the - -
12 the cries of somebody in -- genuinely in an
13 excruciating amount of pain.
14 Q. And - - and have you ever heard any sounds, a
15 human being make those kind of sounds before? I mean,
16 did you have a point of reference? Had you heard
17 somebody in pain before and so when you -- making
18 those kind of sounds that when you heard Mr. Chasse
19 making those sounds you had a point of reference?
20 A. Yes.
21 Q. Who - - who would that have been? Somebody
22 previous to Mr. Chasse who made those kind of sounds
23 and you knew that that person was in pain.
24 A. I guess I don't have a specific instance.
25 Q. So there's not some specific person that you

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1 heard before this who had those type of - - who made
2 those type of sounds?
3 A. No, I guess not.
4 Q. Have you ever been around somebody who,
5 prior to, you know, seeing Mr. Chasse - - and then I
6 assume later you found out he died. Correct?
7 A. Yes.
8 Q. When you found out that Mr. Chasse had died,
9 did that news come to you and were you surprised when
10 you heard that?
11 A. Yes.
12 Q. During the time that you were observing
13 Mr. Chasse, did you ever see Mr. Chasse left alone?
14 A. What do you mean?
15 Q. Well --

16 A. Like unattended?
17 Q. Unattended.
18 A. There was always - - there was - - do you mean
19 specifically attended to by one person?
20 Q. Well, he's laying there alone and nobody is
21 near him.
22 A. No. There was a group of people around him.
23 Q. At all times that you were observing him,
24 there were people that were around him?
25 A. Yes.

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1 Q. And the people who you -- it seems like you

2 can't really identify at this point - -
3 A. No.
4 Q. - - did they appear to be watching
5 Mr. Chasse?
6 A. Not -- no. I mean, no.
7 Q. What were they doing then?
8 A. My best description of it would be kind of
9 milling around and speaking with each other.
10 Q. Except for one thing, they nudged him?
11 A. Yes.
12 Q. Okay. And when they nudged him, if I recall
13 what you were saying - -
14 A. M-hm.
15 Q. -- Mr. Chasse's face was facing away from
16 you?
17 A. I don't recall specifically.
18 Q. Did you ever see Mr. Chasse's face?
19 A. Yes, but not - - I mean, his face. His head
20 is attached to his body. I mean, I didn't
21 specifically see his face like - -
22 Q. Okay. I may have misunderstood you.
23 A. Yes.
24 Q. I thought that you had testified that when
25 you walked down to the end of the dock and you saw

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1 Mr. Chasse laying on the ground --

2 A. He was not face down.

3 Q. He was not face down at that point?
4 A. Pardon me, I'm confused.
5 Q. I am, too. And I'mtrying to -- I am trying
6 to understand what it was that you saw.
7 A. M-hm.
8 Q. So you walk down to the end of the dock - -
9 A. M-hm.
10 Q. - - and you see Mr. Chasse?
11 A. M-hm.
12 Q. What position is Mr. Chasse in at that
13 point?
14 A. He was laying on his stomach, his arms and
15 legs behind him, to the best of my recollection, his
16 face was not down in the ground. That's as specific
17 as I can be - -
18 Q. Okay.
19 A. -- without making assumptions.
20 Q. So was his face - - it was on his side
21 turned?
22 A. His face?
23 Q. You're saying he wasn't -- his nose wasn't
24 touching the concrete; is that correct?
25 A. To the best of my recollection, no.

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1 Q. Okay. So if his nose isn't touching the
2 concrete --

3 A. M-hm.
4 Q. -- and his head is turned to one side or the
other - -
A. Yes.
Q. -- could you see the back of his head or his
face, if you can recall?
A. I don't - - I don't recall.
Q. But you -- do you -- you don't have any
specific recollection then of seeing Mr. Chasse's face
at all?
A. Not - - no, no.
Q. No, okay.
And do you have any specific recollection of
seeing the back of Mr. Chassels head?
A. Yes.
Q. You do, okay.
I think that you said at some point that we
went outside, you left Rudy's and went outside on the
dock.
A. Yes.
Q. Who is we?
A. Myself and a few of my coworkers.
Q. Do you remember who that was?

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1 A. The only person - - I don't remember who else
2 was working on that day. Specifically the only person
3 I remember would be David Lillegaard.
4 Q. Were there any customers in - - or in the
5 store at the time?
6 A. I don't -- I was not specifically with a
7 customer. I don't recall if there were any in the
8 store.
9 Q. When you're - - I think you said that you
10 called the police once and because - - because of your
11 ex-husband.
12 A. Yes.
13 Q. Was your husband -- husband arrested?
14 A. Yes.
15 Q. Was there any struggle with the police when
16 your husband was arrested?
17 A. Between myself and the police?
18 Q. No, no. Between - - your husband was
19 arrested, you weren't --

20 A. Yes.
21 Q. --right?
22 Was there any struggle between your husband
23 and the police when - -
24 A. I didn't see the police arrest him. I
25 locked myself in a room separate from him.

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1 Q. And called the police?
2 A. Yes.
3 Q. From behind locked doors?
4 A. Yes.
5 Q. The police came and arrested him, you did
6 not observe?
7 A. I did not observe them arresting him.
8 Q. And you didn't hear anything subsequent to
9 that about the circumstances surrounding the arrest?
10 A. Of my ex-husband?
11 Q. Right.
12 A. Can you re -- I'm sorry, can you repeat
13 that?
14 Q. Neither the police nor your ex-husband, at
15 some point down the road, told you anything about how
16 the arrest occurred, the arrest of your husband?
17 A. No, not specifically.
18 Q. What about when you got your DUI, were - -
19 were you arrested?
20 A. Yes.
21 Q. And how - - just kind of generally, how - -
22 how did the police treat you?
23 A. Fine. I mean, they were doing their job.
24 I -- you know. I don't remember them being rough or
25 abusive. Just be business, straightforward - -

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Q. Okay.
A. - - yeah.
Q. So they weren't physically abusive with you?
A. No.
Q. Or verbally abusive?
A. NO.
Q. Okay. And I just want to make sure I heard
you right. You did not see any injuries on
Mr. Chasse?
A. Not - - no.
Q. Okay. During the time that you were
observing Mr. Chasse, did you make any observations in
regard to whether or not he was breathing?
A. I wasn't close enough to Mr. Chasse to
specifically observe his breathing or breathing
patterns.
Q. So the answer is no, you did not - -
A. Right.
Q. - - make any observations?

That's all I have.

EXAMINATION
BY MS. BACK:
Q. I just have a few questions.
I'm Jean Back. I represent AMR. They're
the paramedics that work for the ambulance company

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1 that was called to the scene that day.
2 And I wanted to know whether -- I think that
3 you've testified that you really couldn't distinguish
4 between the police officers and the paramedics that
5 were there that day - -
6 A. M-hm.
7 Q. -- is that true?
8 A. (Nods head.)
9 Q. Did you observe - - how - - what is the time
10 period that you - - that you observed Mr. Chasse on the
11 ground? I mean, how long do you believe that you were
12 looking at him for?
13 A. It seemed like at least ten minutes.
14 Q. At least ten minutes?
15 At any time during that ten minutes, do
16 you - - did you observe one of the people in the group
17 kneel down or do any sort of medical tests or - -
18 A. No.
19 Q. - - anything like that?
20 A. No.
21 Q. Do you know whether, during the time period
22 that you were observing that, they were waiting for
23 any sort of test results to come back?
24 A. I -- I wouldn't know that.
25 Q. Okay. So you don't know whether, prior to

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1 the time that you got there, one of the paramedics or
2 more than one of the paramedics had been attending to
3 his needs?
4 A. I don't know. Yes, I don't know that.
5 Q. And you - - when you gave your information to
6 the police - -

8 Q, -- when they came out to talk to you that

9 night, you told them that another person named Ann was
10 with you.
11 A. Yes.
12 Q. And what is Ann's name?
13 A. Ann Stevenson.
14 Q. And is she - - and who is she?
15 A. She's the receptionist - - she was the
16 receptionist.
17 Q. And did she go with you and David?
18 A. NO.
19 Q. Okay. Did she just come out and look and
2o then go back in?
21 A. I believe so, yes.
22 Q. Okay. Have you and Ann spoken about this
23 event or what your observations were?
24 A. We might have that day, but no, not
25 recently, no.

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1 Q. Do you remember, that day, any conversations
2 that you had with Ann or David about the events?
3 A. No.
4 Q. And so if you -- if you didn't -- can't
5 really remember whether you saw his face then you
6 don't know whether his eyes were open at all?
7 A. No.
8 Q. Did you observe any communication between
9 like - - I mean, between any of the folks there that
10 might have been paramedics and police? Did you
11 observe any sort of - -
12 A. I wasn't - - at no point could I specifically
13 hear conversations between members of that group down
14 there.
15 Q. But you were able to hear Mr. Chasse?
16 A. Yes.
17 Q. Because he was loud?
18 A. Yes.
19 Q. And do you specifically remember - - is your
20 memory of the words that you stated today that he
21 spoke that day, is that a clear memory for you or is
22 that a guess or a speculation?
23 A. It was a clear memory at the time.
24 Q. And do you --

25 A. I mean, it - -

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1 Q. Do you remember - - you don't remember him
2 saying anything other than - -
3 A. It sounded like he was saying help me.
4 Q. And that's the only thing that you remember
5 him saying?
6 A. Yeah.
7 Q. And do -- who was he - - who was he saying
8 that to?
9 A. I don't know specifically.
10 Q. Do you recall anybody respond -- that
11 anybody responded to him when he said that?
12 A. I don't recall.
13 Q. Do you - - sometimes there's more than one
14 way to respond to someone. Sometimes you can have a
15 verbal response - -
16 A. M-hm.
17 Q. -- sometimes you can have eye contact with
18 somebody or maybe just even hand maneuvers.
19 A. M-hm.
20 Q. Do you remember - -
2I A. I don't recall.
22 Q. -- seeing anything like that?
23 MR. STEENSON: Just objection,
24 argumentative. But she's answered.
25 Q. (By Ms. Back) Certainly not trying to argue

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1 with you. I'm just trying to understand exactly what
2 you know and observed - -
3 A. M-hm.
4 Q. -- SO --
5 Did you see any sort of object like a
6 backpack or anything around Mr. Chasse?
7 A. No, I don't recall.
8 Q. Did you see that the - - did you see any
9 medical kit around the area?
10 A. Not that I observed.
11 Q. Sometimes there's been a lot of construction
12 going on in the area of the Pearl. It's a fairly new
13 area. Was there any construction in that area that
14 day?
15 A. Not that I remember. I couldn't be
16 positive, though. I'm sure there was at some - - I
17 mean, I don't know. I don't remember it specifically
18 being noisy.
19 Q. I'm just looking through to make sure that
20 I've asked you everything that I want to ask you
21 before I'm done here.
22 I may have some more questions but I'm going
23 to let Mr. Steenson, if he has anything for you, I'm
24 going to let him go, and if not --

25 MR. STEENSON: I have a few questions.

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1 EXAMINATION
2 BY MR. STEENSON:
3 Q. I'm looking at the police report that was
4 completed that contains a summary of information that
5 you apparently provided. It seems to indicate that
6 you called the police to offer your --

7 A. Yes.
8 Q. -- assistance?
9 If this happened on a Sunday - -
10 A. M-hm.
11 Q. -- September 17th, according to the report,
12 if I read it correctly, you were talked to on the 28th
13 of September.
14 A. M-hm.
15 Q. It's like ten or 11 days later. Does that
16 sound right or do you recall?
17 A. I don't - - I don't remember.
18 Q. Okay. This report is completed by a
19 Detective Rhodes. Do you recall the name of the
2o person who spoke with you?
21 A. I don't.
22 Q. Was there more than one detective or officer
23 who spoke with you at that time?
24 A. There was two that came to the salon, but
25 only one that I really specifically spoke with.

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1 Q. They were both men, do you recall?
2 A. Yes.
3 Q. In the report it says "Anderson said at that
4 point the subject on the ground did not appear to be
5 moving or breathing."
6 A. M-hm.
7 Q. Did you tell the detective, at that time,
8 that you did not believe that Mr. Chasse was
9 breathing?
10 A. Yes.
11 Q. Okay. Did you hear anyone, it could have
12 been one of the officers or it could have just been
13 standing around, talk about drugs or mention drugs or
14 drug behavior or drug activity in relation to
15 Mr. Chasse?
16 MS. BECK: Objection, argumentative.
17 THE WITNESS: No.
18 Q. (By Mr. Steenson) Did you ever make any
19 observation about any changes in Mr. Chasse's skin
20 color?
21 A. NO.
22 Q. Did you ever see any blood associated with
23 Mr. Chasse either on the ground or on him or on his
24 clothing, anything like that?
25 A. I don't recall.

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1 Q. Okay. In the report it says "Anderson said
2 the subject finally moved and started screaming
3 something to the effect please help me, please help
4 me.
5 A. Yes.
6 Q. Okay. Did you mean by that he said
7 something like please help me more than once or do you
8 recall?
9 A. Yes.
10 Q. All right. Do you remember how many times
11 he said something like that?
12 A. Not specifically.
13 Q. All right. That's all I have. Thank you.
14 MS. BECK: I just have a few more questions.
15 Do you mind if I finish?
16 MR. RICE: You go ahead and finish and then
17 I have maybe a couple.
18 FURTHER EXAMINATION
19 BY MS. BECK:
20 Q. The guttural sounds that you remember him
21 making --

22 A. M-hm.
23 Q. - - do you believe - - do you - - did you hear
24 him moan or groan or anything like that?
25 A. No.

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1 Q. Okay. Do you remember whether he moved,
2 made any movements at all, other than just what you've
3 testified to?
4 A. No. It seemed like he was -- I'm obviously
5 in no way an expert, but it seemed like he was passed
6 out or unconscious, but I wouldn't specifically know.
7 So no, I didn't see him move.
8 Q. So you wouldn't specific - - so sitting here
9 today, you can't specifically say whether he was just
10 sort of laying there quietly or actually passed out?
11 A. I don't know. I'm not a medical expert.
12 Q. And sitting here today, you can't say
13 whether he was just sitting there quietly or not
14 breathing?
15 MR. STEENSON: He wasn't sitting, but --

16 Q. (By Ms. Beck) Laying there quietly or not

17 breathing.
18 A. It appeared to me that he wasn't breathing,
19 but I - - as I've said before, I wasn't close enough to
2o him to observe specifically.
21 Q. Okay. Well, just so that I can understand
22 that, the reason that it appeared to you that he
23 wasn't breathing -- sometimes maybe we don't think
24 people are breathing because we can't see their chest
25 move up and down or -- so I'm just trying to figure

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1 out what it was that made it seem like he wasn't

breathing to you.
A. He just seemed very, very, very still.
Q. Okay. Have you - - and you've never seen
anybody restrained after a struggle with - - with the
police or some other agency; is that right?
A. Not that I recall, no.
Q. Okay. I don't have any further questions.
MR. RICE: Okay. I'm done.
MS. DUNAWAY: Thank you.
MR. STEENSON: Thank you.
(The deposition concluded at 11:50 AM.)

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1 C E R T I F I C A T E
2 STATE OF WASHINGTON )
) ss
3 COUNTY OF CLARK )

4 I, Shannon K. Krska, a Certified Shorthand

5 Reporter for Oregon, do hereby certify that, pursuant
6 to stipulation of counsel for the respective parties
7 hereinbefore set forth, ELIZABETH A. ANDERSON
8 personally appeared before me at the time and place
9 set forth in the caption hereof; that at said time and
10 place I reported in Stenotype all testimony adduced
11 and other oral proceedings had in the foregoing
12 matter; that thereafter my notes were reduced to
13 typewriting under my direction; and that the foregoing
14 transcript, pages 3 to 52, both inclusive, constitutes
15 a full, true and accurate record of all such testimony
16 adduced and oral proceedings had, and of the whole
17 thereof.
18 Witness my hand and CSR stamp at Vanco
19 Washington, this
20

21 " .
22 Shannon K. Krska
23 Certified Shorthand Reporter
24 Oregon CSR No. 90-0216

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