IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS MCALLEN DIVISION MARIA GUTIERREZ, ET AL, Plaintiffs vs. CA NO. M-98-299 STATE OF TEXAS, ET AL, Defendants Li TERRONEZ COPY DECEMBER 10, 1999 AUSTIN, TEXAS A Better Court Reporting Service, Inc. TRESSA GRANGER, PRESIDENT Certified Shorthand Reporters 602 WEST QTH STREET seen cove i912 AUSTIN, TEXAS 78701 FA COE (512)eae eee IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS MCALLEN DIVISION MARIA GUTIERREZ, ET AL vs + CANO. M-98-299 STATE OF TEXAS, ET AL ORAL DEPOSITION OF DANIEL G. TERRONEZ DECEMBER 10, 1999 ORAL DEFOSITION OF DANIEL G. TERRONEZ, produced as a witness me at the instance of the PLAINTIFF, MARIA GUTIERREZ, BP AL, and duly sworn, was taken in the above-styled and numbered cause on the 10th day of DECEMBER, 1999, from 11:00 to 12:25, before MELISSA PARKHILL, CSR No. $354 in and for the State of Texas, reported by machine shorthand at the offices of the Attorney General of the State of Texas, 300 W. 15th Street, 7th Floor, Austin, Travis County, Texas pursuant to the Federal Rules of Civil Procedure and the provisions stated on the record or attached therein1 ' COURT REPORTER: Why don't we introdt 2 ourselves for the record. I'm Melissa Parkhill, the 3 court reporter. ‘ MS, MATLOCK: Karen Matlock here 5 representing Officer Terronez. 6 MR, ABREGO: Mr. Abrego for the 7 plaintiffs. 8 MR. KRUEGER: Perri Alkas and Bill 9. Krueger for the county and the county defendants, 10 Perri, can you hear us? " MS, ALKAS: Yeah, 2 MR. LOCKHOOF: Reed Lockhoof with the 13 attorney's general office representing the defendant 14 COURT REPORTER: Okay. Let me swear t 15. witness in. 6 DANIEL G. TERRONEZ, 17 having been first duly sworn to testify the truth, th: 118 whole truth, and nothing but the truth, testified as |19 follows 20 EXAMINATION 21 BY MR.ABREGO: fan ee Lok eR 23. A. Daniel G. Terronez, Text-on-e2, 24... Okay... What's your address? _ 25 A, Wharton, Texas, T aoe 9 Pp St OLS aensey ures Pa Ny bushooee NaATSaES ive-re-e, Texas 77467. 2, Oley, had orn Tesi aes A Itwould be Wharton, Texas. 6 MS. MATLOCK: We object to giving any | 7 residential information based upon the law enforce: 8 privilege. 9 Q. Okay. What's the telephone number there at 10 your business? 11. Area code (409) 532-1740... 12 Have you ever done a deposition before? ‘A. Yes, sir, Ihave. act 14 Q Okay. So you understand I'm going to be Js asking you some questions. and you nced to try an |e answer them as accurately and truthfully as you ca i) A. Yes, sir, Ido. - 18 Q Will you agree to do that? WA. Yes, sir, Fo @ Okay. If you don't understand anything that ask you, please ask me to restate it or rephrase it so that we understand each other because the court rep is going to be taking down the questions and the 4 answers, Will vou do that? AL Yes. sir.