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1 2 3 IPPERWASH PUBLIC INQUIRY 4 5 6 7 ******************** 8 9 10 BEFORE: THE HONOURABLE JUSTICE SIDNEY LINDEN, 11 COMMISSIONER 12 13 14 15 16 Held at: Forest Community Centre 17 Kimball Hall 18 Forest, Ontario 19 20 21 ******************** 22 23 24 April 25th, 2005 25

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1 Appearances 2 Derry Millar ) (np) Commission Counsel 3 Susan Vella ) 4 Donald Worme, Q. C ) 5 Katherine Hensel ) 6 Jodi-Lynn Waddilove ) (np) 7 8 Murray Klippenstein ) (np) The Estate of Dudley 9 Vilko Zbogar ) George and George 10 Andrew Orkin ) (np) Family Group 11 Basil Alexander ) (np) Student-at-Law 12 13 Peter Rosenthal ) Aazhoodena and George 14 Jackie Esmonde ) Family Group 15 16 Anthony Ross ) Residents of 17 Kevin Scullion ) Aazhoodena (Army Camp) 18 William Henderson ) (np) Kettle Point & Stony 19 Jonathon George ) Point First Nation 20 Colleen Johnson ) (np) 21 22 Kim Twohig ) (np) Government of Ontario 23 Walter Myrka ) (np) 24 Susan Freeborn ) (np) 25 Michelle Pong )

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1 APPEARANCES (cont'd) 2 Janet Clermont ) Municipality of 3 David Nash ) (np) Lambton Shores 4 5 Peter Downard ) (np) The Honourable Michael 6 Bill Hourigan ) (np) Harris 7 Jennifer McAleer ) 8 9 Ian Smith ) (Np) Robert Runciman 10 Alice Mrozek ) (np) 11 Harvey Stosberg ) (np) Charles Harnick 12 Jacqueline Horvat ) (np) 13 Douglas Sulman, Q.C. ) Marcel Beaubien 14 Trevor Hinnegan ) (np) 15 16 Mark Sandler ) (np) Ontario Provincial 17 Andrea Tuck-Jackson ) Ontario Provincial Police 18 Leslie Kaufman ) (np) 19 20 Ian Roland ) (np) Ontario Provincial 21 Karen Jones ) Police Association & 22 Debra Newell ) K. Deane 23 Ian McGilp ) (np) 24 Annie Leeks ) (np) 25

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1 APPEARANCES (cont'd) 2 3 Julian Falconer ) (np) Aboriginal Legal 4 Brian Eyolfson ) Services of Toronto 5 Julian Roy ) (np) 6 Clem Nabigon ) (np) 7 Adriel Weaver ) (np) Student-at-Law 8 9 Al J.C. O'Marra ) Office of the Chief 10 Robert Ash, Q.C. ) (np) Coroner 11 12 William Horton ) (np) Chiefs of Ontario 13 Matthew Horner ) (np) 14 Kathleen Lickers ) (Np) 15 16 Mark Frederick ) (np) Christopher Hodgson 17 Craig Mills ) (np) 18 Erin Tully ) 19 20 David Roebuck ) (Np) Debbie Hutton 21 Anna Perschy ) (np) 22 Melissa Panjer ) (np) 23 Danya Cohen-Nehemia ) (np) 24 25

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1 LIST OF APPEARANCES (cont'd) 2 3 Kelly Graham ) Malcolm Gilpin, Mark Watt, 4 Jill Sampson ) John Tedball, Cesare 5 DiCesare and Robert Kenneth 6 Scott 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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1 TABLE OF CONTENTS 2 Page 3 Exhibits 6 4 5 MARK WATT, Resumed 6 Continued Examination-In-Chief by Mr. Donald Worme 7 7 Cross-Examination by Ms. Jackie Esmonde 40 8 Cross-Examination by Mr. Kevin Scullion 71 9 Cross-Examination by Andrea Tuck-Jackson 92 10 Cross-Examination by Ms. Karen Jones 102 11 12 ERNEST JOHN TEDBALL, Sworn 13 Examination-In-Chief by Ms. Katherine Hensel 114 14 Cross-Examination by Ms. Jackie Esmonde 181 15 Cross-Examination by Mr. Kevin Scullion 205 16 Cross-Examination by Ms. Andrea Tuck-Jackson 208 17 Cross-Examination by Ms. Karen Jones 210 18 19 CESARE DICESARE, Sworn 20 Examination-In-Chief by Ms. Katherine Hensel 218 21 Cross-Examination by Ms. Jackie Esmonde 273 22 Cross-Examination by Mr. Kevin Scullion 291 23 Cross-Examination by Ms. Andrea Tuck-Jackson 296 24 Cross-Examination by Ms. Karen Jones 299 25 Certificate of Transcript 306

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1 EXHIBITS 2 No. Description Page 3 P-352 Ambulance incident report (Forest 4 District Ambulance) September 06/'95 5 vehicle No. 1146 possible gun shot 6 wound to Nick Cottrelle 9 7 P-353 Document 1002615 statement of Mark 8 A. Watt to C.A. Martin, Det. Const. 9 No. 6842 September 08/'95 1700 hours 10 and anticipated evidence of Mark Watt 11 September 20/'95 11:45 hours to 12 12:12 hours interviewed by SIU 13 Investigators Bob Muir and Jim Kennedy 16 14 P-354 Document No. 1000043 Ambulance call 15 report (Forest District) written by 16 John Tedball, September 06/'95 re 17 gunshot trauma to Nick Cottrelle 208 18 19 20 21 22 23 24 25

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1 --- Upon commencing at 10:35 a.m. 2 3 THE REGISTRAR: This Public Inquiry is 4 now in session. The Honourable Mr. Justice Linden 5 presiding. Please be seated. 6 MR. DONALD WORME: Good morning, 7 Commissioner. 8 COMMISSIONER SIDNEY LINDEN: Good morning 9 everyone. Good morning. 10 MR. DONALD WORME: Commissioner, you'll 11 recall from the last day that Mark Watt, the ambulance 12 attendant, is still on the stand. 13 14 MARK WATT, Resumed 15 16 CONTINUED EXAMINATION-IN-CHIEF BY MR. DONALD WORME: 17 Q: Good morning, Mr. Watt. 18 A: Good morning. 19 Q: Mr. Watt, the last day we had heard 20 from you in your testimony that you had arrived in 21 Ambulance Number 1146; is that correct? 22 A: Yes. 23 Q: To the MNR parking lot, according to 24 the instructions of your dispatch from the Wallaceburg 25 CACC?

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1 A: Yes. 2 Q: You indicated to us, sir, that you 3 were initially stopped, I think, to use your words, at a 4 barricade, which essentially is a checkpoint at the 5 entrance to the MNR parking lot, that was manned of 6 staffed by OPP officers? 7 A: Yes. 8 Q: That you were directed into the MNR 9 parking lot and advised where you ought to park your 10 vehicle. And you've told us as well that a second 11 ambulance, that being 1145 and operated by Mr. Gilpin? 12 A: Yes. 13 Q: Was also following you? 14 A: Yeah, Matt Gilpin and Ceasor 15 DiCesare. 16 Q: And that you had observed 17 approximately twenty (20) to thirty (30) officers and a 18 number of vehicles, the officers being dressed in what 19 you described as black fatigues? 20 A: Yes. 21 Q: Sir, this morning we were provided 22 with a document and, in fact, just minutes ago. And I 23 have provided a copy to you to be reviewed. It's -- it's 24 titled, Ambulance Incident Report to Accompany ACR. 25 Copies were made, Commissioner, and were

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1 distributed to Counsel. They have them now in front of 2 them. 3 And, Mr. Watt, you had an opportunity to 4 review a document that bears your signature? 5 A: Yes. 6 Q: And it's numbered consecutively 1 7 through 4, being the last four (4) pages of that series 8 of documents in front of you? 9 A: Yes. 10 Q: You recognize that document and your 11 signature on that? 12 A: Yes. 13 Q: I'll ask, Commissioner, that this be 14 marked as an exhibit, please. Perhaps we can mark the 15 entire thing, as I take it the other witnesses who are 16 referenced in the document will also be directed to this. 17 THE REGISTRAR: Exhibit P-352. 18 COMMISSIONER SIDNEY LINDEN: 352. 19 20 --- EXHIBIT NO. P-352: Ambulance incident report 21 (Forest District Ambulance) 22 September 06/'95 vehicle No. 23 1146 possible gun shot wound 24 to Nick Cottrelle 25

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1 CONTINUED BY MR. DONALD WORME: 2 Q: And, you've had an opportunity, Mr. 3 Watt, to review that document and, firstly, you've 4 acknowledged that that is your document? 5 A: Yes. 6 Q: And, does it assist you in refreshing 7 your memory with respect to your observations that 8 evening? 9 A: Yes, as much as I've read, it's 10 helped a bit, yes. 11 Q: All right. Similarly, sir, I direct 12 your attention to Tab Number 6 in the Book of Documents - 13 - the document brief beside you, that is Inquiry Document 14 1002615. 15 I believe, sir, that you acknowledged last 16 day that this is a transcript of a statement that you had 17 provided to Detective Constable Martin on September the 18 8th of 1995 relative, again, to the events you are 19 testifying here about? 20 A: Yes. 21 22 (BRIEF PAUSE) 23 24 Q: I'm just wondering, sir, if you 25 recall being approached by an individual by the name of

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1 Wade Lacroix? 2 A: Sergeant Lacroix? 3 Q: Yes. 4 A: Yes. 5 Q: And, was he in the company of -- of 6 other officers -- and, first of all, when you were 7 approached by Sergeant Lacroix, that was at the MNR 8 parking lot? 9 A: Yes. 10 Q: Okay. And, go ahead and just tell us 11 what it is that you can recall in terms of any 12 conversation or instructions that was -- that was had 13 with him. 14 A: Well, Sergeant Lacroix and Ted Slomer 15 at the MNR parking lot were just filling us in exactly 16 what our -- what our situation was and what we were 17 expected to do, to park in the parking lot and he 18 debriefed exactly what was -- what was our -- our -- what 19 we were expected to do, I mean, did you want me to go 20 further than that, or... 21 Q: What was it that you were expected to 22 do? 23 A: Well, I think basically what Ted 24 Slomer was mentioning is, he just wanted to make sure, 25 comfortable what our limitations were with first aid and

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1 CPR and -- and our knowledge -- 2 Q: Just before you go on, who is Ted 3 Slomer? 4 A: Ted Slomer would be the TRU Team 5 medic. 6 Q: All right. And, how did you come to 7 the conclusion that he was the TRU Team medic? 8 A: He introduced himself that way. 9 Q: All right. I believe you had 10 mentioned last day that he was dressed in the same 11 fashion as others? 12 A: Yes. 13 Q: And he had -- 14 A: He had a -- 15 Q: -- you say he had fatigues on, did 16 he? 17 A: Yes, he had a helmet on, a black 18 helmet and fatigues, the same as the other officers. 19 Q: Do you know whether or not he carried 20 any arms, whether a long rifle as you've described some 21 had, or side arm? 22 A: I could recall that he didn't have a 23 rifle or anything like that with him, but I can't recall 24 if he had a side arm on him or not. 25 Q: Okay. So, Mr. Slomer is giving you

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1 instruction as what is expected of you? 2 A: Yes. 3 Q: And, go ahead and tell us what it was 4 that he said? 5 A: Well, he said if there's anyone 6 seriously injured, they'll bring them to us and to remain 7 in the MNR parking lot. And he did brief us; he asked us 8 about our first aid capabilities, such as Mass-Trousers, 9 IV therapy and intubation, which was advanced first aid. 10 We did not have the capability to do 11 intubation or we didn't have any Mass-Trousers. I also 12 asked Ted Slomer very shortly about pepper spray and -- 13 and different other things that we might experience. 14 Q: You mentioned Mass-Trousers, I wonder 15 if you just might explain that for us? 16 A: Mass trousers are trousers that you 17 put on your lower extremities that would cause some 18 pressure; they'll increase your blood pressure. The 19 reason why with a serious gunshot wound you can lose your 20 -- a lot of blood and your blood pressure can lower. 21 Q: You described this as being an 22 advanced first aid technique? 23 A: Yes. 24 Q: You were not trained for this or you 25 didn't have the equipment, is that what I understand you

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1 to say? 2 A: We weren't -- we weren't trained for 3 intubation or any major drugs or mass trousers. 4 Q: Given the absence of training or that 5 particular equipment, did you get the sense whether there 6 was any concern on the part of Medic Slomer? 7 A: Well, I think Medic Slomer was just 8 basically debriefing us to find out where our 9 capabilities were at that time. 10 Q: Were you given any instructions, sir, 11 on how it was that you would retrieve any injured 12 parties, any casualties? 13 A: The casualties, if they happened in 14 the scene where -- from the MNR parking lot, they would 15 be brought to us and that would be the most safe -- we -- 16 we would not be going in to wherever the incident was 17 happening. They would be brought to us because of being 18 safer at the MNR parking lot. 19 Q: All right. So, you remained on a 20 Code 8, that is on standby in the MNR parking lot; what 21 happens next, Mr. Watt? 22 A: Very shortly after that, we were 23 directed from the MNR parking lot to go to the police -- 24 OPP blockade, and just before we left the MNR parking lot 25 to go there, I heard a couple of very, you know, pop,

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1 pop, pop kind of sounds. 2 Myself not being a hunter or anything like 3 that, I couldn't specifically tell that those are 4 gunshots or anything like that. 5 My other fellow ambulance attendant, 6 Ceasor DiCesare, he also aware, he heard those, too. And 7 very shortly after that, we went to the OPP blockade and 8 then from there we were directed back to the MNR parking 9 lot. 10 Q: All right. Now ,help us out here, 11 Mr. Watt, when you say you went to the OPP blockade, 12 where would that be located? 13 A: That was the blockade that we first 14 came into the -- the MNR parking lot, those few -- 15 Q: This would be on East Parkway Drive-- 16 A: Yes. 17 Q: -- just outside and adjacent to the 18 entrance to the MNR parking lot? 19 A: Yes. 20 Q: And at that blockade, as you put it, 21 what happened? 22 A: We -- I can't recall how long we 23 stayed there, but we were directed back to the MNR 24 parking lot, and when we went back to the MNR parking 25 lot, very shortly from that, Ted Slomer approached us.

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1 Q: Okay. Now, you'd indicated in your 2 statement, that's at Tab 6, and perhaps, Commissioner, I 3 should ask that this be made an exhibit in these 4 proceedings as well. 5 THE REGISTRAR: P-353, your Honour. 6 COMMISSIONER SIDNEY LINDEN: 353. 7 8 --- EXHIBIT NO. P-353: Document 1002615 statement of 9 Mark A. Watt to C.A. Martin, 10 Det. Const. No. 6842 11 September 08/'95 1700 hours 12 and anticipated evidence of 13 Mark Watt September 20/'95 14 11:45 hours to 12:12 hours 15 interviewed by SIU 16 Investigators Bob Muir and 17 Jim Kennedy 18 19 CONTINUED BY MR. DONALD WORME: 20 Q: The very first line of your statement 21 that you -- it indicates that you were approached by Mr. 22 Slomer, the TRU Team medic at approximately 23:10 hours. 23 A: Yes. 24 Q: Now, would that be the time when you 25 were first approached and -- and debriefed as to the

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1 situation or would this be the approach that you're now 2 telling us about? 3 A: This would be the situation when he 4 approached us the first time. 5 Q: Right. Can you give us an 6 estimation, sir, if you know, as to what time it was that 7 he approached you then, the second time on the second 8 instance where you were just getting into... 9 A: Well, 23:10 is when he approached us 10 initially; that's when we were advised about the gunshot 11 -- or the two (2) seriously injured parties at the Army 12 Camp Road and Ipper -- Ipperwash Road; at 23:10 hours, 13 that's when he first approached us. 14 And very shortly after that, we went Code 15 8 or 10-8 to the situation. 16 Q: 10-8 meaning? 17 A: Well, we were on our way to the -- 18 the scene. 19 Q: And do you recall the route that you 20 would have taken, then, to the scene, after you were 21 advised by Mr. Slomer of the two (2) injured parties? 22 A: Yes. We would come out of the MNR 23 parking lot, turn left on the Parkway Drive and go up to 24 Ipperwash Road, turn left and head that all the way up to 25 Highway 21.

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1 Q: Okay. 2 A: Turn left from there and then proceed 3 to Army Camp Road and Highway 21. 4 5 (BRIEF PAUSE) 6 7 Q: You had indicated, earlier, sir, that 8 you were accompanied or your vehicle was accompanied by a 9 second ambulance operated by Mr. Gilpin. 10 Where was that ambulance when you were 11 dispatched, then, to the intersection of Army Camp Road 12 and Highway 21? 13 A: They were following us behind. 14 Q: And we've heard some testimony, sir, 15 that there was little, if any, communication with your 16 CACC, with your dispatch centre. 17 Can you help us out there at all? 18 A: Well, as soon as we got that -- that 19 initial notification of Ted Slomer, we went 10-8 to the 20 scene and my partner, John Tedball, would have gone to 21 the dispatch and advised them that we were heading 22 towards there. 23 Q: Okay. 24 A: That was a normal situation, anytime 25 we got any directions like that, before we moved we'd

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1 actually notified Wallaceburg dispatch. 2 Q: All right, we -- or at least I 3 understood that, typically, the ambulances would not move 4 unless there was your dispatch that was giving you the 5 instruction? 6 A: In that situation it was Ted Slomer 7 that told us about the situation. And I don't -- at that 8 time we just notified Wallaceburg dispatch that we are 9 proceeding to that scene. 10 And I think -- I think that 10-8 was at 11 23:11 hours, which is at one (1) minute after Ted Sloane 12 notified us about what was going on at Army Camp -- Army 13 Camp Road and Highway 21. 14 Q: And, again, his -- his information to 15 you was...? 16 A: There was two (2) seriously injured, 17 possibly gunshot victims on Army Camp Road and Highway 18 21. 19 Q: And did he describe who the 20 casualties were at all? 21 A: No. All we had is gunshot victims 22 possibly. 23 Q: Having arrived at the scene then, 24 that is at Army Camp and Highway 21, Mr. Watt, could you 25 describe to us what it is that you did, what it is that

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1 you seen? 2 A: As we were approaching the scene I 3 noticed a dark-colour car in the north ditch. I also 4 noticed -- I -- it was about eighty (80) to a hundred 5 (100) feet away from Army Camp Road and noted -- realized 6 there was two (2) or three (3) TRU Team members that had 7 their rifles pointed in the vicinity of the car, with two 8 (2) individuals at the back bumper with their hands up. 9 At that time a TRU Team member was yelling 10 at us -- or motioned us to park our car behind his 11 cruiser, which was on a south ditch. 12 13 (BRIEF PAUSE) 14 15 Q: Sir, in the document that's been 16 marked as P-352, the Ambulance Incident Report that you 17 prepared -- yes; that document that -- 18 A: This one? 19 Q: -- in your hand. 20 A: Yes. 21 Q: On page 3 of that document there is a 22 diagram or a sketch? 23 A: Yes. 24 Q: I take it that's a sketch that you 25 prepared in the context of preparing this report?

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1 A: Yes. 2 Q: And having reviewed that, did it 3 assist you in your recollection of the events that you 4 are describing and will describe for us? 5 A: Yes. 6 Q: Now, clearly it's not to scale but I 7 would suggest to you, at the bottom right-hand corner of 8 that diagram, that is the Army Camp Road and Highway 21 9 intersection? 10 A: Yes. 11 Q: And the vehicles that are depicted at 12 the very bottom of that sketch, these are the vehicles 13 that you are describing, included, I trust, your vehicle, 14 number 1146? 15 A: Yes. 16 Q: Just continue, if you would then, 17 sir, describing what it is that was going on at the time. 18 A: Well, from us being motioned or waved 19 to -- to park behind a OPP cruiser, we actually exited 20 our vehicle and went to the ditch, which would be the 21 south ditch. 22 Q: Why did you exit your vehicle and go 23 to the ditch? 24 A: Because the scene wasn't clear, I 25 don't think it was. The people with the -- the guns

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1 being drawn towards the vicinity of -- of the vehicle; I 2 don't think the scene was very safe. So myself and John 3 Tedball, my partner, along with 1145, which was Ceasor 4 DiCesare and Matt Gilpin, we all went to the ditch. 5 Q: I take it you would have did that 6 under instruction? 7 A: I can't recall that but I know that 8 coming upon a situation like that was not normal for 9 myself or for John, and we knew that it was possibly 10 unsafe. 11 Q: I'm going to draw your attention, 12 sir, to Tab number 5, and that has been marked in these 13 proceedings at P-345, being the various ambulance logs. 14 15 (BRIEF PAUSE) 16 17 Q: And if I can take you to -- there's 18 a number at the top that's called a Front Number. And I 19 would draw your attention to 0009543. 20 21 (BRIEF PAUSE) 22 23 COMMISSIONER SIDNEY LINDEN: What tab 24 number is this? 25 MR. DONALD WORME: This would be at Tab

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1 Number 5, Commissioner. 2 COMMISSIONER SIDNEY LINDEN: 5. Thanks 3 4 (BRIEF PAUSE) 5 6 CONTINUED BY MR. DONALD WORME: 7 Q: The Front Number being 0009543 and 8 I'll suggest to you, Mr. Watt -- your with me on that? 9 A: Yes. 10 Q: That that is under Number 2, your 11 Unit Number 1146? 12 A: Yes. 13 Q: Your OASIS Number 51201? 14 A: Yes. 15 Q: As well as Mr. Tedball's? 16 A: Yes. 17 Q: It would indicate that you were 18 notified at 23:11 and twenty-eight (28) seconds? 19 A: Yes. 20 Q: That you were enroute simultaneous 21 with the call, essentially? 22 A: Yes. 23 Q: That you arrived at the scene some 24 four (4) -- three-and-a-half (3 1/2) minutes thereabouts 25 later?

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1 A: Yes. 2 Q: Pardon me, four-and-a-half (4 1/2) -- 3 A: About five (5) -- yeah, yes. 4 Q: And, that you spent, it would appear 5 to be, approximately sixteen (16) minutes at the scene? 6 A: Yes. 7 Q: Or eighteen (18) minutes, perhaps. 8 Having entered the ditch, then, let's -- we'll go back to 9 listening to your testimony, Mr. Watt. 10 Having entered the ditch and making the 11 observations that there two (2) persons beside the dark- 12 coloured vehicle with TRU officers' weapons drawn and 13 pointed in the general vicinity of these -- of these two 14 (2) individuals at the dark car, first of all, did you 15 determine the -- who these people were at the dark car? 16 A: No. 17 Q: Whether they were male or female? 18 A: Not at the point, no. 19 Q: And, could you hear any conversation, 20 any orders, anything being exchanged as between the 21 police officers and these two (2) individuals? 22 A: No, while we were in the ditch we 23 were too far away from the -- the scene. 24 Q: Okay. 25 A: We were on a south ditch and the

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1 vehicle's on the north ditch. 2 Q: Go ahead and tell us from there, Mr. 3 Watt, what happens? 4 A: Well, from there we had one (1) of 5 the TRU team members yelled out that the situation was 6 cleared and at that time we -- my partner John Tedball 7 and myself went to the back of the ambulance to retrieve 8 our stretcher, first aid equipment, trauma bag and 9 proceed to the car. 10 Q: I terms of the length of time spent 11 in the ditch awaiting instruction that the scene was 12 clear -- 13 A: About two (2) minutes. 14 Q: -- what's your estimation on that? 15 A: About two (2) minutes, approximately. 16 17 (BRIEF PAUSE) 18 19 Q: And, after waiting that two (2) 20 minutes, collecting your equipment and attending, then, 21 to the vehicle, what happens? 22 A: Me, and at this point, the other crew 23 was there, 1145. Me and Ceasor approached the vehicle. 24 At that time, we had one (1) of the TRU Team members yell 25 out that a possible victim was in the passenger side of

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1 the vehicle, so we -- we went to the passenger side of 2 the vehicle and observed the young male that was there. 3 Do you want me to go farther, or...? 4 Q: Yes, go ahead. 5 A: As we opened up the door, I was 6 asking certain questions and the TRU Team member said 7 that it was possibly a gunshot, so I asked him what 8 happened. He says, He has been shot and I said, Where? 9 And, he said, The back and then we went and started 10 assessing. 11 At that point, I cut his shirt off and my 12 partner, well, not John Tedball but Ceasor DiCesare, my 13 fellow ambulance attendant oscillated his lungs to find 14 out if there was any problems with his lungs at all. 15 At that time, I observed there was a -- he 16 had an abrasion on his left side, his left flank area, 17 and at that time I observed there was a puncture wound on 18 his right posterior back. 19 Q: You're indicating the lower -- lower 20 back on your right-hand side? 21 A: Right. At that time, it was around 22 the fifth or sixth -- about midway in his ribs, about the 23 fifth or sixth rib area. It was a puncture wound about 24 the size of a pen, if you want to say. 25 So, we went ahead and bandaged that. From

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1 that point, asked him -- we did a very fast assessment on 2 him to make sure he had not problems with his extremities 3 or his back. 4 And at that time, after we did an 5 assessment there, we proceeded to stabilise his neck with 6 a C-collar and from there, we lifted him very carefully 7 onto a spine board, taped his -- head down with some 8 towel rolls, stabilized him on the spine board and from 9 there we proceeded to the back of the ambulance. 10 Q: Okay. Continue. 11 A: From the back of the ambulance -- I 12 went to the back of the ambulance, we loaded the victim 13 and from that point we had a constable, I think it was 14 Constable Boon that actually was in the back of the 15 ambulance with us, to escort us. 16 From that point on, we closed the back of 17 the ambulance doors and proceeded or my -- John Tedball 18 went ahead and proceeded to Strathroy Hospital, Code 4. 19 We also had a -- a police cruiser escort us to Strathroy 20 Hospital. 21 Q: The indication on the chart that's up 22 on the wall, and P-345 on the big screen, rather, would 23 indicate that there's a departure from the scene at 24 23:39:14? 25 A: Yes.

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1 Q: Do you know the route, sir, that was 2 driven to get from Army Camp Road and Highway 21 to 3 Strathroy Hospital? 4 A: No, I would not recall. I was too 5 focussed on the victim that we had in the back of the 6 ambulance or the patient. 7 Q: And in terms of your focus on the 8 patient in the back, can you tell us what it is that you 9 did, what it is that you would have seen, observed? 10 A: The back of the ambulance -- back of 11 the ambulance I would assess, did a full assessment on 12 the patient. From that point, I would determine his 13 level of consciousness; if he had any breathing problems. 14 At that point, I administered some oxygen 15 with him and also further assessment. He had no -- he 16 was stable. He was calm; he wasn't agitated at all. His 17 pulse, respirations and -- was stable. Both his 18 extremities had good strength and his lungs were very -- 19 they were clear and bilaterally and then we proceeded to 20 Strathroy Code 4. 21 In transport, I don't know at which time 22 it was I would report to the Strathroy Hospital, his 23 vital signs and what I had observed on the way to the 24 hospital. 25 But, overall, the patient was stable. I

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1 also asked him a few questions about if he was standing 2 or sitting or bending over when he may have got shot, 3 because I wanted to know the trajectory if it was a 4 bullet, where it would actually end up, because I was 5 concerned more of his, you know, his liver, his spleen 6 and different major organs. 7 But I didn't find a exit wound, I just 8 found an entrance wound. 9 Q: All right. And part of the reason 10 for collecting this various information, as much info as 11 you can on the patient, is so that that could be supplied 12 to the -- to the emergency department once you arrive at 13 the hospital, correct? 14 A: Correct. 15 Q: And I take it from that, that that 16 perhaps would inform the manner of treatment that a 17 patient would receive? 18 A: Exactly. 19 Q: All right. I trust that that 20 information, then, that you had collected during the 21 course of your full assessment was passed along? 22 A: Yes. 23 Q: And that would be done by way of 24 verbal reports or written reports? 25 A: Yes. I would do it at the Patch it's

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1 called, on the way and by the time I got to the hospital, 2 as we approached Emerg., I would give that report to the 3 nurse and then she would pass that on to the doctor. 4 And if any changes had happened with his 5 blood pressure or any of his vital signs, and if the 6 patient's deteriorated at all, that would be passed on at 7 that point. 8 Q: If I can refer you again back to your 9 Tab Number 5, P-345, the Front Number is 0009546. 10 So, if you go in two (2) pages from where 11 you were, Mr. Watt. 12 A: I have it. 13 Q: That is the narrative of your 14 dispatch with respect to this particular call, is it? 15 A: Yes. 16 Q: And you'll note that the second note 17 on that at 23:56:50; I wonder if you just might that and 18 tell us what that says. 19 A: It says: 20 "Code 4 -- well, 11:46, it's 21 Code 4, a sixteen (16) year old male. 22 Lower posture, gunshot wound from a 23 .223 rifle shell. Vital signs stable. 24 Alert times three (3). Lungs sounds 25 clear bilaterally; patient fully

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1 immobilized, on O2." 2 Q: I take it that that's the information 3 that you would have then provided to your dispatcher, to 4 the call-taker, who would then put this information onto 5 the computer? 6 A: Yes. 7 Q: And, in particular, that a sixteen 8 (16) year old male, you would have found that out from 9 asking the patient? 10 A: Yes. 11 Q: And the injury you've just described 12 for us. What I'm interested in is the gunshot wound from 13 a .223 rifle shell; how is it that you came to that 14 information or that conclusion, Mr. Watt? 15 A: Possibly I would have got that 16 information from the officer who was in the back of the 17 ambulance. Since it was a gunshot wound, I wanted to 18 know what size; because I didn't have a lot of education 19 on size of shells or weapons or anything like that, so I 20 got that information possibly at this time, I would have 21 more -- more or less gotten that from the police officer 22 in the back of the vehicle. 23 Q: All right. Just so I'm clear, you 24 mentioned earlier you are not a hunter? 25 A: No.

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1 Q: And you've just mentioned now that 2 you didn't have a lot of education with respect to 3 ballistics, to caliber, that sort of thing? 4 A: Exactly. 5 Q: And when you say, Possibly got it 6 from the police officer, I -- I take it you have no 7 present recollection? 8 A: No. 9 Q: Fair enough. During the course of 10 the trip into the Strathroy Hospital, did you hear any 11 conversation as between Constable Boon and your patient? 12 A: Yes. Constable Boon wrote -- read 13 the patient's rights in the back of the ambulance. 14 Q: All right. Did it appear to you that 15 that was understood or that was heard first of all? 16 A: Yes, I would have -- yes, I heard 17 that. 18 Q: Okay. And in terms of reading those 19 rights, sir, can you recall for us today what it was that 20 -- and I don't mean the exact words but even in a general 21 sense, do you have any recollection of what was said; 22 whether he was reading from a card, whether he was simply 23 providing this information? 24 A: I can't recall. 25 Q: Can you describe the patient that you

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1 were doing the assessment in terms of his mannerisms, in 2 terms of his emotional state? 3 A: He was very calm, he wasn't agitated, 4 and he was very cooperative on the way to -- to the 5 Emerg., or Strathroy Hospital. 6 Q: And you were asked at some point 7 whether or not you detected if this patient had been 8 using alcohol? 9 A: No, I didn't smell any alcohol on him 10 at all. 11 Q: We know from the record, sir, that 12 you would have arrived at your destination at about six 13 (6) minutes past midnight; does that accord with your 14 recollection? 15 A: Yes. 16 Q: Having arrived at the Strathroy 17 Hospital, I take it you would have went to -- to the 18 Emergency entrance? 19 A: Yes. 20 Q: Tell us what happens from there then? 21 A: As we received -- or got to the 22 Emerg. we would -- I -- well, take the -- I would take 23 the patient out of the ambulance, go to the front in 24 Emerg. rooms and pass the report on to the nurse. 25 Q: Do you recall which nurse you would

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1 have provided your -- or passed your report on to? 2 A: Can't recall. 3 Q: Go ahead. 4 A: And from there, after we gave them a 5 full rundown, exactly what we've assessed what his 6 problem is, then we would fight up our reports, finish up 7 our paperwork, and then we would report back to dispatch 8 to find out where to go from there. 9 Q: All right. While you were in the 10 process of doing this and before you left the Strathroy 11 Emergency area, did you make any further observations, 12 Mr. Watt? 13 A: Yes. There's a -- a vehicle that 14 came very fast into Emerg., it was a white car, you could 15 realize that it was possibly going very fast because it 16 was heating, it had a tire that was flat, and it pulled 17 very fast into Emerg. 18 Q: Continue. 19 A: From that point on, I realized that 20 people were yelling out that there was a patient -- or a 21 person in the back seat that has been shot. So, I went 22 over there to help out. At that time people in Emerg. 23 were notified and they brought a stretcher out. 24 I took an individual, I didn't know who it 25 was initially, and that -- realized that he was

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1 unconscious, his colour was not very good at all, and so 2 we helped him onto the stretcher. I did realize in his 3 upper chest that he did have blood. 4 Q: Okay. And did you note where the -- 5 where the blood was aside from simply upper chest? 6 A: Left -- 7 Q: Do you recall today, sir? 8 A: -- left chest. 9 Q: In terms of the amount of blood you 10 observed, do you have any recollection of that? 11 A: It was just basically maybe a four 12 (4) by five (5) inch section of blood. 13 Q: Okay. Did you see who was operating 14 the vehicle that pulled -- the white vehicle that pulled, 15 overheating and a flat tire? 16 A: I can't recall, I was more focussed 17 on helping that individual. 18 Q: You don't know how many other 19 individuals beside the injured party, besides the 20 casualty that were in this vehicle? 21 A: I can't recall exactly. 22 Q: And, when -- 23 A: All I recall is they were very 24 agitated and quite nervous, or they were really... 25 Q: In their state of agitation, do you

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1 recall whether they were saying anything as to what might 2 have happened? 3 A: Well, all I can recall later is 4 saying that he was shot. 5 Q: And, I take it your observations of 6 the individual were consistent with that? 7 A: Yes. 8 Q: Had you ever seen a gunshot victim 9 before, sir, or treated a gunshot victim? 10 A: No. 11 Q: And, aside from your assisting the 12 individual from the back of the vehicle, I take it, onto 13 a stretcher, what was your role? 14 A: My role was just, you know, stabilize 15 or as much as we could getting him on the stretcher and 16 helping other individuals bring him into Emerg. as fast 17 as we could. 18 Q: Do you recall who the other 19 individuals were that assisted in bringing him into the 20 Emerg.? 21 A: I can't recall. 22 Q: I take it that would be hospital 23 personnel, not one of your fellow ambulance attendants? 24 A: I don't know where my partner John 25 was. I can't recall if he helped. I mean, most of the

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1 time if something like that happens he's usually pretty 2 close, but I can't recall that. 3 Q: Did you have any further dealings 4 with the patient that you assisted from the white vehicle 5 onto a stretcher into the Emerg.? 6 A: No, all we did is we put him on a 7 stretcher, brought him in the Emerg. and I may have just 8 reported to him they think they had a gunshot. 9 Q: Okay. And, beyond that, sir, what's 10 -- what's the next thing that happened? 11 A: After we reported that to the nurse, 12 we were -- we went back to our vehicle and at that point 13 we were sent back to Ravenswood or Army Camp Road and 14 Highway 21 for standby. 15 Q: Army Camp and Highway 21? 16 A: Yes. 17 Q: The location that you had just left 18 from? 19 A: Yes. 20 Q: All right. So, you returned there -- 21 A: See, in my report it says Ravenswood, 22 Ravenswood Road and Highway 21, so I -- I -- like now, 23 the names have changed so, in my report I have Ravenswood 24 Road and Highway 21, so I know that -- that Ipperwash 25 Road has changed names some time, so -- but that's where

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1 we went to. 2 Q: Okay. So, you didn't go back to the 3 Army Camp where you had picked up the patient, Nicholus 4 Cotrelle? 5 A: No, we went to Ravenswood Road and 6 Highway 21. 7 Q: And, you remained there for how long? 8 A: I can't recall. 9 Q: Was there any further events in 10 connection with this incident that you were involved in, 11 Mr. Watt? 12 A: No. 13 14 (BRIEF PAUSE) 15 16 Q: Mr. Watt, just taking you back to the 17 -- to the scene when you were I -- I take it taking cover 18 in the ditch and there was some two (2) minute delay 19 according to your account of arriving at the scene and 20 then actually attending to the patient Nicholus Cotrelle, 21 is there anything in your mind that might have been done 22 different such that that delay would not have been 23 occasioned. 24 A: You mean in the situation, the two 25 (2) minute delay? The main reason why the two (2) minute

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1 delay was that the scene wasn't clear; it wasn't safe to 2 approach the patient. 3 Do you want me to elaborate more on that, 4 or... 5 Q: Well, if there's -- if there is 6 anything that you can add to that; if there's not, that's 7 quite understandable. 8 Q: Well, it was a dangerous situation. 9 I mean, in most cases that -- something that dangerous 10 you may have been farther away from the scene before it's 11 cleared. We were, I mean, thinking back now is that we 12 were too close in the vicinity and at that point where 13 it's clear we're so close, we should have been farther 14 away at that time. 15 Q: All right. I think those are all my 16 questions, Mr. Commissioner, for this Witness. 17 COMMISSIONER SIDNEY LINDEN: Okay. Does 18 anybody wish to examine this Witness? 19 Okay. Ms. Esmonde...? 20 MS. JACKIE ESMONDE: Presumably, a half 21 an hour. 22 COMMISSIONER SIDNEY LINDEN: And Mr. 23 Scullion...? 24 MR. KEVIN SCULLION: I think twenty (20) 25 minutes to half an hour, depending.

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1 COMMISSIONER SIDNEY LINDEN: Ms. Tuck- 2 Jackson...? 3 MS. ANDREA TUCK-JACKSON: Five (5) 4 minutes. 5 COMMISSIONER SIDNEY LINDEN: Ms. 6 Jones...? 7 MS. KAREN JONES: Fifteen (15) minutes. 8 COMMISSIONER SIDNEY LINDEN: All right. 9 Ms. Esmonde...? 10 11 (BRIEF PAUSE) 12 13 CROSS-EXAMINATION BY MS. JACKIE ESMONDE: 14 Q: Good morning. 15 A: Morning. 16 Q: My name is Jackie Esmonde. I'm one 17 of the lawyers representing a group from Stoney Point, 18 under the name Aazhoodena and George Family Group. 19 Now, my questions for you this morning 20 will mainly be just to get some more detail about some of 21 the events that you've described. 22 Now, I'd like to go back to the MNR 23 parking lot. Oh, actually before you were dispatched 24 there, what information did you have about what was going 25 on that evening and about why ambulances were required?

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1 A: Well, initially we just got called 2 from home to our Forest district base for standby, a Code 3 8. 4 Q: Okay. 5 A: One of the -- I recall that there was 6 something going on down at Ipperwash. 7 Q: Okay. That was the extent of the 8 information, that there was something going on? 9 A: Yes. 10 Q: Okay. And then you were told to go 11 the MNR parking lot? 12 A: Yes. 13 Q: And are you told why you're going 14 there? 15 A: What you mean, from the blockade to 16 the MNR? 17 Q: Well, I take it you were at the 18 Forest detachment first? 19 A: Yes. 20 Q: And then you were sent to the MNR 21 parking lot? 22 A: Yes. 23 Q: And were you told why? 24 A: Why? 25 Q: Yes.

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1 A: Well, it was an altercation, possibly 2 there will be something going in the Ipperwash Camp, 3 police officers were there, and we were there for more 4 first aid. 5 Q: Okay. 6 7 (BRIEF PAUSE) 8 9 Q: Okay. So -- and you've told us that 10 once you were in the MNR parking lot, you spoke with a 11 Sergeant Lacroix -- 12 A: Yes. 13 Q: -- Lacroix? 14 A: Yes, and Todd -- and Ted Slomer. 15 Q: Okay, now focussing on the 16 conversation you had with Sergeant Lacroix, and I'm 17 taking a look at the ambulance incident report that was 18 provided to Counsel this morning -- 19 A: Hmm hmm. 20 Q: -- which is marked as P-352. 21 A: I've only gone over maybe half of 22 what I just got this morning, so... 23 Q: Okay, do you have a page marked 2? 24 A: Two (2). Both of these -- I have 25 three three (33), four four (44) here, so I don't know

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1 which one... 2 Q: I'm looking at the report that you 3 completed at page 2. You don't have that in front of 4 you? 5 A: What does it look it? That one? 6 7 (BRIEF PAUSE) 8 9 Q: It says at the top in handwriting, 10 "Action Taken At Scene. 11 A: Action Taken At Scene. 12 Q: And there's a two (2) at the top in 13 the right hand corner. 14 A: Okay. 15 Q: You don't have that? 16 A: Well, I've got this one that's marked 17 four (4) at the top and it says, Action Taken At Scene, 18 but it's -- it's actually rubbed out. 19 Q: Okay. So -- 20 A: Both of these forms that I have here 21 in front of me here, I have two (2) number 3's which are 22 identical, and I have two (2) number 4's which are 23 identical. 24 Q: Okay. 25 A: So, maybe I might be missing what

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1 you're talking about. 2 3 (BRIEF PAUSE) 4 5 A: Oh, there we go. We're all set. 6 Q: Okay. And have you had a chance to 7 review this page? 8 A: No. 9 Q: You haven't? Okay. Would you like a 10 moment just to read what you haven't seen yet this 11 morning? 12 A: Okay. 13 Q: I would like to ask you some 14 questions about page 2 and 3. 15 A: 2 and 3, okay. 16 17 (BRIEF PAUSE) 18 19 COMMISSIONER SIDNEY LINDEN: Mr. Worme, 20 as I understand it, you didn't have this document before 21 this morning. 22 MR. DONALD WORME: That document was 23 provided to us just shortly after 10:00 a.m. this 24 morning, Mr. Commissioner -- 25 COMMISSIONER SIDNEY LINDEN: That's fine.

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1 MR. DONALD WORME: -- and I apologize -- 2 COMMISSIONER SIDNEY LINDEN: That's fine. 3 MR. DONALD WORME: -- for the lateness of 4 producing this, but that is the best that we could do -- 5 COMMISSIONER SIDNEY LINDEN: We'll take a 6 minute and give the Witness a chance to look at it. 7 MR. DONALD WORME: -- at this moment. 8 9 (BRIEF PAUSE) 10 11 COMMISSIONER SIDNEY LINDEN: It's his 12 writing, so he should be able to read it. I think it's 13 his writing. 14 15 (BRIEF PAUSE) 16 17 CONTINUED BY MS. JACKIE ESMONDE: 18 Q: So, you've had a chance to review 19 page 2? 20 A: Yes, very quickly. I don't know. 21 Yes, I've got -- I've gone over it. 22 Q: Okay. 23 A: Right. 24 Q: Now, I'm looking in the first -- the 25 first chunk at the top of the --

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1 A: Yes. 2 Q: -- page, and just over half way 3 through, it says: 4 "Sergeant Macroix..." 5 And I take it that -- that you understood 6 that -- that was his name. It's actually Sergeant 7 Lacroix? 8 A: So, we're going over page 2? 9 Q: I'm at page 2. 10 A: Okay. 11 Q: It says: 12 "Sergeant Macroix which debriefed 13 us about situation and responsibilities 14 at scene." 15 Do you see that? 16 A: Is that this section up here? 17 Q: Yeah, it's in that section; it's 18 about halfway down and the sentence starts -- 19 A: Right, okay. 20 Q: -- halfway over. 21 A: Approached by OPP TRU; right, okay. 22 Q: Okay? Now, I'm at -- wanted to ask 23 you about the debriefing about the situation. 24 Can you recall what he told -- what he 25 told you when he debriefed you about the situation?

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1 A: Well, they -- at that point, he was 2 just mentioning that they -- about going into Ipperwash 3 Park -- 4 Q: Yes. 5 A: -- at some point, during that night. 6 Q: Okay. 7 A: And we were there in case something 8 happened. 9 Q: Okay, and then it says: 10 "He mentioned that TRU Team members 11 will be deployed in groups (possibly 12 two (2) groups) that we would follow 13 safe distance from behind and all the 14 injured bodies will be delivered behind 15 the groups ahead to us." 16 Does that refresh your memory about the 17 discussion that you had that evening with Sergeant 18 Lacroix? 19 A: See, the discussion I had with -- at 20 this point, is very foggy. 21 Q: Yes. When was this report prepared? 22 A: At that time. It was very shortly 23 after the -- after the situation, the same date. 24 Q: The same date? 25 A: September the 6th, '95, so it would

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1 have been the same time and so my recollection at that 2 time would have been very good. 3 Q: Right, okay. So, you have no reason 4 to dispute that this is an accurate -- 5 A: Yes. 6 Q: -- description of what occurred? 7 A: Should be, yes. 8 Q: Okay. And then it appears that you 9 then spoke with Ted Slomer? 10 A: Right. 11 Q: The TRU Team medic. 12 A: Hmm hmm, that's right. 13 Q: And looking in the second chunk 14 there -- 15 A: Right. 16 Q: "Ted Slomer said at no time should we 17 leave the safety of MNR parking lot." 18 A: Right. 19 Q: And that -- that accords with what 20 you've told us -- 21 A: Yes. 22 Q: -- already today. And then you had a 23 discussion about the kind of capabilities that you had 24 for first aid? 25 A: Right.

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1 (BRIEF PAUSE) 2 3 Q: And you also make reference to the 4 St. John Ambulance? 5 A: Yes. 6 Q: And they arrived after you? 7 A: Yes. 8 Q: And you saw them have a discussion 9 with Ted Slomer? 10 A: Yes. 11 Q: But you -- I take it you didn't hear 12 the nature of that discussion? 13 A: No. 14 Q: And what was your understanding about 15 what St. John Ambulance was there to do? 16 A: I think, well, just basically to help 17 out with some minor stuff, because their capabilities is 18 not too advanced. 19 Q: Right. You understand it's a -- it's 20 a volunteer organization -- 21 A: Exactly. 22 Q: -- and they're not trained as 23 paramedics? So, your understanding was that they were 24 there to provide minor first aid? 25 A: Exactly.

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1 Q: Now, Ted Slomer, had you met him 2 before? 3 A: No. 4 Q: Okay. And at any time were you told 5 that your position was confidential and you weren't to 6 advise the Communication Centre of where you were or what 7 you were doing? 8 A: No. 9 Q: Now, if we could go to page 3 in your 10 incident report. Okay. In the -- I'm looking in the 11 second half of the page in the -- the narrative that 12 you've provided. 13 A: Right. 14 Q: On the third line, and I take it this 15 is after you heard the, pop, pop, pop sound? 16 A: Right. 17 Q: It says: 18 "Shortly after -- after, heard from 19 other TRU members that possibly two (2) 20 individuals hit, possibly by gunfire?" 21 A: How far down is that? 22 Q: Sorry. I'm on the third line of -- 23 of writing. 24 A: Oh, third line, okay. 25 Q: Beginning, "shortly after."

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1 A: Okay, yes. Yeah. 2 Q: Okay. So, shortly after you'd heard 3 this pop, pop, pop sound and people had come back to the 4 parking lot; is that right? 5 A: Yes. Well, we were at the MNR 6 parking lot and we got directed to come out towards the 7 blockade. 8 Q: Right. 9 A: Just as we were heading to the 10 blockade, that's when we heard these pop, pop, pop 11 sounds, yes. We went to the blockade, came back to the 12 MNR parking lot and very shortly after that, that's when 13 we were deployed to the scene. 14 Q: Okay. And, then you -- it says 15 according to this that you heard from other TRU Team 16 members that there were possibly two (2) individuals hit 17 by gunfire? 18 A: Yes. 19 Q: And, where they directing that to you 20 or this is something you overheard. 21 A: Ted Slomer advised us at 23:10 that 22 that's what happened. I don' have that -- 23 Q: Okay. But, it appears here you're 24 not speaking about Ted Slomer; would you agree? 25 A: Okay.

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1 Q: It says, "from other TRU members" 2 that possibly two (2) individuals hit. 3 A: Okay. That's true. 4 Q: Can -- can you recall today how you 5 came to hear that information? Was it a TRU Team member 6 or TRU Team member speaking directly to you or you 7 overheard that? 8 A: Well, over the loudspeakers it -- it 9 was -- you could hear different things going on, so we 10 knew something was going on. 11 Q: Right. 12 A: And, at that time -- but, we really 13 knew what was going on when Ted Slomer came up to us and 14 told us exactly what transpired. 15 Q: Okay. Well, if we could go on from 16 where I was reading it says: 17 "TRU members required us to move 18 upwards closer to dirt road and 19 possibly drive down road towards 20 confrontation scene." 21 A: Right. Yes. 22 Q: Okay. So, it appears there was some 23 conversation and -- between you and TRU Team members who 24 were asking you to move your vehicle again? 25 A: Yes.

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1 Q: And, does that refresh your memory? 2 Does that assist you in remembering who you had that 3 conversation with? 4 A: No. 5 Q: Okay. It wasn't Sergeant Lacroix and 6 it wasn't Ted Slomer, is that right? 7 A: What's -- what you read here -- 8 Q: Yeah. 9 A: -- that seems -- yes. 10 Q: Okay. But, you don't remember now? 11 A: I can't recall who exactly that was. 12 Q: Okay. And, then it goes on that John 13 Tedball said: 14 "We were required to remain in MNR 15 parking lot until possibly Ted Slomer 16 will bring any injured to us." 17 A: Yes. 18 Q: So, at this time: 19 Short period -- a short period had..." 20 Can you read that? 21 A: At this time, short period -- yeah. 22 Q: A TRU -- 23 A: "Had a TRU team member with a rifle 24 in the back of the ambulance --" 25 Q: Okay. So, for --

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1 A: "-- for possible escort to scene." 2 Q: Okay. So, at this time you were 3 still considering going to the scene and there was a TRU 4 Team member in the ambulance with you; can you recall 5 that now? 6 A: I can't -- like, reading this I 7 recall it, but before, no, I couldn't recall that right 8 now. 9 Q: Okay. 10 A: Since it's been so long, I can't 11 recall exactly that. I remember John going 10-8 to the 12 scene, but I can't totally recall unless I read this. 13 Q: Okay. Do you remember anything 14 beyond what is written here in terms of who was in the 15 back with you? 16 17 (BRIEF PAUSE) 18 19 A: You mean like the TRU Team member 20 with the rifle -- 21 Q: Right. 22 A: -- in the back of the ambulance? I 23 can't recall that, no. 24 Q: Okay. Okay. And then finally, the 25 last part I want to refer you to is the last three (3)

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1 lines on that page 3, okay, I guess beginning at the end 2 of the fourth line up. 3 "Back to MNR parking lot location when 4 Ted Slomer stopped us and mentioned two 5 (2) vehicles respond to Army Camp Road 6 and Highway 21 north, Code 4 for two 7 (2) Natives, serious injuries." 8 A: Right. 9 Q: Okay. So, this is where Ted Slomer 10 asks you to go to Highway 21 and Army Camp Road? 11 A: Yes. 12 Q: And you had information that it was - 13 - they believed it was Natives who were injured? 14 A: See, I can't totally recall right now 15 by my memory that it was Natives. 16 Q: Okay. But, you remember being told 17 possibly two (2) seriously injured people by gunshot 18 wounds? 19 A: Yes. 20 Q: And do you know how he came to have 21 that information? 22 A: No. 23 24 (BRIEF PAUSE) 25

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1 Q: Okay. Now, at any point in the 2 evening, can you recall being approached by Sergeant 3 Cousineau of the OPP with respect to a 911 call from 9780 4 Army Camp Road? 5 A: No. 6 Q: Or any OPP officer? 7 A: No. 8 Q: No. 9 A: The only one I knew about that -- is 10 the one that we went to. 11 Q: Okay. Okay. Now, I -- I'd like to 12 ask you a few questions about the situation at Army Camp 13 Road and Highway 21. Now, you've told us that you 14 thought it was an unsafe situation that had to be cleared 15 before -- 16 A: Yes. 17 Q: -- you could approach the injured 18 person? 19 A: Yes. 20 Q: And I take it you believed it was 21 unsafe because you saw officers with their long guns out? 22 A: Yes. 23 Q: And you didn't have any other 24 information with respect to why it may or may not be 25 safe?

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1 A: Exactly. 2 Q: Now, you've told us that you couldn't 3 hear any conversation between the two (2) women who were 4 by the car and the OPP officers? 5 A: When we were in the ditch? 6 Q: When you were in the ditch. 7 A: Yes. We were too far away. 8 Q: Okay. Did you -- can you recall that 9 they were being told to lay down on the ground and they 10 were refusing to do so? 11 A: All I can recall was they were 12 standing with their hands up in the air. 13 Q: Okay. And did you hear the OPP -- an 14 OPP officer say words to the effect of, You bitches, put 15 your arms in the air? 16 A: No. 17 Q: Now, did you recognize one of the 18 women as Gina George -- 19 A: No. 20 Q: -- or a provide of home-care services 21 that -- 22 A: No. 23 Q: -- you had before? 24 A: No. 25 Q: And I take it the -- the guns were

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1 pointed at the women the whole time that you were there? 2 A: Yes. In the vicinity. I can't 3 exactly say they were pointed right at them -- 4 Q: Right. 5 A: -- but they pointed -- 6 Q: How -- how close were they to the 7 women? 8 A: I can't recall exactly. If I -- if I 9 was going to take a guess -- is that -- you want me -- 10 approximately? 11 Q: Approximately. 12 A: Thirty (30) feet, twenty-five (25) 13 feet. 14 Q: Okay. So, when you were able to 15 approach the injured person in the car, I take it you 16 asked -- asked him his name at that time? 17 A: I think at that time I wouldn't ask 18 his -- I -- I can't recall. 19 Q: Okay. When did you learn that he was 20 sixteen (16) years old? 21 A: Well, at the time that we started 22 going towards the hospital; at that time I would want to 23 know his age. 24 Q: Okay. So, you -- you asked him that 25 once he was in the ambulance, in --

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1 A: Yes. 2 Q: -- in transport? 3 A: Because as you're just going to pull 4 a Patch, you definitely will want to know the person's 5 name or their -- their age. 6 Q: Okay. 7 A: But, looking at him initially, my 8 first concern is -- is looking at him, he's a young 9 individual, knowing his exact date -- you know, his -- 10 how old he is, I could have possibly asked what his name 11 is, so it makes him more comfortable than now I'm saying, 12 Hey. 13 Q: Okay. But -- so you could tell he 14 was young? 15 A: Yes. 16 Q: You could tell he was a teenager? 17 A: Yes. 18 Q: And I take it it was your desire to 19 get him into the ambulance as quickly as you could? 20 A: Yes. 21 Q: And away from that situation? 22 A: Yes. 23 Q: Now, when you were putting him in the 24 ambulance, did you observe one of the women wanted to 25 come with you and she said that was her son?

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1 A: I can't recall. 2 Q: You don't recall that. Now, you've 3 told us that Constable Boon accompanied you and at some 4 point he read Nicholus Cotrelle his rights or told him 5 his rights? 6 A: Yes. 7 Q: Can you recall how long you had been 8 on the road when that happened? 9 A: Can't recall. 10 Q: And it was clear at that point that 11 Nicholus Cotrelle was under arrest? 12 A: Yes. 13 Q: And was that the first time that you 14 observed him to be informed of that fact? 15 A: I can't recall exactly at the time 16 that I determined when he was under arrest or not; I can 17 recall that he was told his rights. 18 Q: Okay. At any time prior to that, did 19 you hear Officer Boon or any other officer tell him that 20 he was under arrest? 21 A: I can't recall. My focus was him. 22 Q: Okay. And did you hear any officer 23 tell him what he was under arrest for? 24 A: No. 25 Q: And, the information you had about

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1 the gunshot wound being from a .223, you -- I take it 2 you're sure that you didn't get that information from 3 Nicholus Cotrelle? 4 A: No, I didn't get -- I definitely 5 didn't get it from him, no. 6 I was just trying to -- I was looking at 7 the -- the puncture wound and I can't recall, but I 8 would have -- since I have a police officer there, he has 9 more understanding what kind of weapons or, you know, 10 what kind of shells or whatever; that's whatever I've 11 would have got, but I can't recall exactly where I got 12 that information from. 13 I was just trying to form a -- more of an 14 understanding that if I could the Emerg. kind of an idea 15 what they're looking for in the size, maybe the Emerg. -- 16 Emerg. doctor would know, well, that's a size of shell, 17 it might cause this kind of damage or whatever. I was 18 just trying to get as much information as possibly I 19 could. 20 Q: And, you used a Code 4 for transport? 21 A: Yes. 22 Q: With lights and sirens? 23 A: Yes. 24 Q: And, before you placed him the back 25 of the ambulance he was bordered -- boarded and collared;

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1 is that right? 2 A: Yes. 3 Q: Okay. And, you did this because 4 there was a possible back injury? 5 A: Well, being a gunshot wound, you 6 don't know if it's gone in; it's touched his spine or 7 anything like that. Since it's in his back and very 8 close to the spine, you don't know what's going to 9 transpire, so that would be normal treatment. 10 Q: Right. That's a precaution you'd 11 take? 12 A: Yes. 13 Q: As you don't know the full extent of 14 his injuries? 15 A: Exactly. 16 Q: And, if he had a serious back injury 17 to his spine, it would have been dangerous to move him 18 without those, right? 19 A: Yes, well, we're collaring him -- we 20 put him on -- normally on a -- on a -- on a C-collar, we 21 would take precautions. I can't recall if we used a KED, 22 which is a device to go around him, but at one point 23 there during the transport I asked him what happened and 24 at that time he said he was standing, he was shot. I 25 said, Well, how did you get to the car? He walked on his

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1 own accord to the car. I don't know if it was that car 2 that we picked him out of -- 3 Q: Hmm hmm. 4 A: -- or what. But, normally if we put 5 him on a C-collar we're not just going to get him to walk 6 onto the stretcher; we're going to stabilize him, make 7 sure his back's nice and straight and stabilize his neck. 8 If Ceasor was there, he would have 9 stabilized his neck, whole straight, nice unit and move 10 him onto the stretcher very softly or very cautiously. 11 Q: Right. So, then he's moving as 12 little as possible? 13 A: Exactly. 14 Q: Okay. Now, going back to the -- 15 you're at the hospital and you had told us about helping 16 to bring in the man who you later learned was Dudley 17 George into the hospital. 18 A: Yes. 19 Q: Now, I take it you were -- you were 20 actually inside the hospital when the car arrived; is 21 that not the case? 22 A: I can't -- looking at my reports, 23 that what it says. I can't totally recall that I ran out 24 of the -- out of the Emerg. or not, but looking at my 25 notes and just reading them over very fast is that that's

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1 what happened. I came out of the Emerg. and saw the car 2 approaching and just helped out, yes. 3 Q: Can I ask you to turn to your Tab 6, 4 it's the SIU statement that you gave on the 20th of 5 September, 1995. All right. 6 A: Okay. Is that 1002615? 7 COMMISSIONER SIDNEY LINDEN: Yes. 8 9 (BRIEF PAUSE) 10 11 CONTINUED BY MS. JACKIE ESMONDE: 12 Q: Is that what you have? Is the -- is 13 that the SIU statement or the OPP statement? 14 MR. DONALD WORME: It goes into the 15 fourth page. 16 17 CONTINUED BY MS. JACKIE ESMONDE: 18 Q: If you turn to the fourth page in 19 that tab. 20 A: Is that 1002615? 21 Q: Yes, and Front Number... 22 A: The one I've got here is 18682. 23 Q: Yes, that's correct. 24 THE REGISTRAR: That's P-353. 25

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1 CONTINUED BY MS. JACKIE ESMONDE: 2 Q: Okay. If I could ask you to turn to 3 page 14 of that statement. 4 A: Yes. 5 Q: Now, first of all, do you recall 6 giving a statement to the SIU on -- on September 20th, 7 1995? 8 A: Yes. 9 Q: And I take that statement was 10 recorded? 11 A: Yes. 12 Q: And this appears to be the 13 transcription of that recording. 14 A: Yes. 15 Q: Have you had a chance to review it? 16 A: Yes. 17 Q: Okay. And in your view, is it an 18 accurate transcription of what was said? 19 A: Yes. 20 21 (BRIEF PAUSE) 22 23 Q: Pardon me, page 14, did I tell you 24 16 -- 25 A: Yes.

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1 Q: -- or 14? Okay -- 2 A: Page 14, yes. 3 Q: Page 14. I just wanted to direct 4 your attention to one (1) passage there, to see if that 5 assists in refreshing your memory. 6 About half way down the page it says: 7 "Watt"? 8 A: Yes. 9 Q: It says: 10 "Well, I was at Strathroy Hospital. A 11 car apparently pulled up into the 12 Emerg. and at that time I was in 13 Strathroy Emerg., and there was quite a 14 commotion. So I came outside and saw a 15 white car and apparently there was an 16 individual, which I didn't know who it 17 was and they were yelling out that he 18 was shot and stuff like that, so I 19 actually helped that individual onto 20 the stretcher and from that point on, 21 they brought him into Strathroy 22 Hospital." 23 Now, the reason I -- my -- so my question 24 is: Were you in -- it's not entirely clear from this 25 passage, were you in -- you were inside when the car

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1 pulled in? 2 A: Reading that -- 3 Q: Were you inside -- 4 A: -- it looks like -- 5 Q: -- when you heard a commotion? 6 A: Yes. 7 Q: And then you went outside to see what 8 was the cause of the commotion? 9 A: Yes. 10 Q: And can you recall how much time 11 there was between when you heard the commotion and you 12 went outside? 13 A: I can't recall. I would, seeing if I 14 saw some commotion, I would have gone out there as fast 15 as I could. 16 Q: And how long would it have taken you 17 to get outside? 18 A: From Emerg. where I was? 19 Q: Yes. 20 A: Thirty (30) seconds at most, not very 21 long at all. 22 Q: Okay. So, when you got outside, 23 then, you saw the white car -- that's when you saw the 24 white car? 25 A: Yes.

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1 Q: And I take it you're assuming that 2 the commotion you heard was the arrival of the car? 3 A: Well, looking back we knew that there 4 was a car coming to Strathroy. 5 Q: Okay. 6 A: All right. So, I may have been 7 waiting at that time, right? 8 Q: Well, what was the commotion that you 9 heard? 10 A: The car pulls up. 11 Q: It was the sound of the car pulling 12 up? 13 A: Yes. 14 Q: Okay. And you say that there was 15 yelling out and he was shot; and who was yelling? 16 A: I can't recall. It was just -- there 17 was maybe three (3) or four (4) people around the car. 18 It could have been the driver. I -- I can't recall. 19 Q: Okay. 20 A: Anyways, someone was yelling out he 21 had been shot and they were very excited and -- 22 Q: Okay. So, it wasn't hospital staff 23 that were yelling? 24 A: No. 25 Q: And it wasn't OPP officers that were

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1 yelling? 2 A: No. They just pulled up. I ran 3 outside and that's when I heard yelling. 4 Q: Okay. 5 A: It was someone from that vehicle that 6 was saying, He's been shot, he's been shot. 7 Q: Okay. And what did you do 8 immediately -- what did you do then? 9 A: What did I do? 10 Q: Yes. 11 A: I went to the back passenger side to 12 find out what was going on. 13 Q: Okay. And you saw the individual in 14 the back seat? 15 A: Yes. 16 Q: And then what did you do? 17 A: I think at that time someone may have 18 got a stretcher in the Strathroy Hospital in Emerg., 19 brought it out, and at that time I was asking maybe few 20 questions what happened. 21 Q: And who were you asking? 22 A: The people in the car. What 23 happened? He's been shot. It was very, very fast that 24 we got -- I looked at him, right from there under the 25 stretcher from the stretcher into Emerge.

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1 Q: Okay. 2 A: I knew that was a serious situation, 3 because looking at him and seeing the blood and feeling 4 the chest, which is a very delicate spot, and if it is a 5 shot -- gunshot, it would have been very serious, we'd 6 have to get him in Emerg. as fast as possible. 7 Q: Okay. Now, the people that you saw 8 who were yelling, they were outside of the car? 9 A: I can't totally recall that. I -- 10 I'd be guessing if I said outside the car. I just 11 remember the commotion. I was just maybe tunnel visioned 12 onto the patient. 13 Q: Okay. So, I take it, then, you can't 14 recall if they were in police custody at that time or 15 not? 16 A: What, the people that were calling? 17 Q: Yes. 18 A: No. They -- they -- they just showed 19 up with the car and from the car it could have been -- 20 someone from that car was yelling, He's been shot, and 21 from there we just loaded up, did our action and got him 22 on the stretcher into the Emerg. 23 Q: Okay. Thank you very much, those 24 are all my questions. 25 COMMISSIONER SIDNEY LINDEN: Thank you.

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1 Mr. Scullion...? 2 3 (BRIEF PAUSE) 4 5 CROSS-EXAMINATION BY MR. KEVIN SCULLION: 6 Q: Good morning, Mr. Watt. 7 A: Good morning. 8 Q: My name is Kevin Scullion and I'm one 9 of Co-Counsel for the Residents of Aazhoodena, which you 10 probably know as Stoney Point. 11 A: Okay. 12 Q: All right. And there's probably 13 going to be some overlap; I'm going to try to go 14 chronologically with you but there's a couple of follow- 15 up questions I have following Ms. Esmonde's questions for 16 you. 17 You've indicated that you were put on 18 standby and assigned to the MNR parking lot? 19 A: Yes. 20 Q: And that was done by your dispatch; 21 is that correct? 22 A: Yes. 23 Q: All right. And you understood that 24 that was as a result of a request from the OPP? 25 A: Yes.

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1 Q: In -- in particular, was it Sergeant 2 Lacroix or do you know if it was someone that made that 3 request? 4 A: I can't recall. 5 Q: Okay. But, when you arrived at the 6 MNR parking lot, you've indicated that you met both 7 Sergeant Lacroix and this OP -- or the TRU Team medic, 8 Mr. Slomer? 9 A: Yes. 10 Q: And you received some instructions 11 from them as to what was expected of you and where you 12 should park the ambulance and what you should do as you 13 wait for something to happen? 14 A: Yes. 15 Q: It is fair to say that at this point 16 in time you and the other ambulance that came with you to 17 the MNR parking lot were under direction from the OPP? 18 A: Yes. 19 Q: All right. And you were waiting for 20 them to tell you what to do or how you could assist with 21 what they were doing? 22 A: Yes. 23 Q: All right. In that conversation, you 24 mentioned something about mass-trousers? 25 A: Yes.

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1 Q: And I've gone through your other 2 statements that you gave to the OPP and the SIU and 3 there's no indication of mass-trousers but there's some 4 indication that you had discussions with Mr. Slomer about 5 your capabilities or your limitations. 6 And my question for you is: When he 7 talked of mass-trousers, did he indicate to you that 8 there was a possibility there would be some shooting 9 involved in whatever they were doing? 10 A: I think there was a concern because 11 there's -- of course, there's police officers around with 12 rifles, so something's going to happen, and he was just 13 asking what our limitations were, if we had any trauma or 14 anything like that, right. 15 Q: Right. He was checking to see what 16 your experience was with injuries and, I guess, how many 17 years on the job you've been -- 18 A: Yes. 19 Q: -- doing this type of thing? 20 A: Exactly. 21 Q: All right. And they told you, Wait 22 here until you hear further, and then you heard further 23 and you were reassigned down the street, to the -- the 24 other OPP area? 25 A: Yeah. Where the blockade was, yes.

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1 Q: Right. And, if I understand from 2 your evidence to Ms. Esmonde, there was some discussion, 3 some incident at that other area that you don't recall 4 all that much about today and, in fact, it's only when 5 you read your Ambulance Incident Report that you sort of 6 remembered what happened at that point? 7 A: Exactly. 8 Q: All right. And, if I understood you 9 correctly, this Ambulance Incident Report was prepared 10 shortly after this matter? 11 A: Yes. 12 Q: All right. And it would best reflect 13 what you knew at the time, and it was prepared accurately 14 by you? 15 A: Yes. 16 Q: All right. And you don't have any 17 independent recollection of that particular moment in 18 time other than what's in this Ambulance Report? 19 A: Exactly. 20 Q: All right. And, just for my 21 clarification, I think we've marked all of this as P-352, 22 and maybe I can just check that. There's -- 23 THE REGISTRAR: The Ambulance Incident 24 Report? 25

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1 CONTINUED BY MR. KEVIN SCULLION: 2 Q: -- there's eight (8) 3 A: Hmm hmm. Okay. 4 Q: And you had referred earlier to a 5 couple of different segments or sections of that, that 6 you had before you; do you have all eight (8) pages? 7 A: Are you talking about just my 8 statement or all of John Tedball's, or -- 9 Q: No, no. We had a document listed as 10 page -- or Exhibit P-352; I just want to make sure you 11 have the whole document in front you. 12 All right. I'm advised by Mr. Worme that 13 you do have it there and I'll get to that in a second. I 14 just wanted to clarify that part. 15 16 (BRIEF PAUSE) 17 18 Q: May I just ask you to put that to the 19 side -- 20 A: Oh, okay. Sorry. 21 Q: -- for a second. 22 A: Sorry. 23 Q: When you returned to the MNR parking 24 lot, I understand that you were there for a few minutes 25 before Mr. Slomer came up and gave you some instructions?

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1 A: Exactly. 2 Q: All right. And if you can just walk 3 me through that particular moment in time, to the best of 4 your recollection, did he return to the MNR parking lot 5 and a minute or two (2) passed before he came over to 6 you? 7 A: I can recall that we were there, at 8 the scene, I -- I think he filled us in and very shortly 9 after that I observed him in a suburban with another 10 individual in his suburban, they took off. 11 Q: They took off from the MNR parking 12 lot? 13 A: Yes, and then they returned. 14 Q: They came back at some point? 15 A: Yes. 16 Q: And, was it both suburbans returned 17 at that point? 18 A: I can't recall. 19 Q: All right. 20 A: I know he came back and there's -- I 21 don't know what the lapse there was until we were 22 actually filled in what exactly about the injured 23 parties. 24 Q: All right. When you first spoke with 25 Mr. Slomer, did he tell you what they were going to be

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1 doing other than they were going towards the Park? 2 A: You mean what -- what -- what was -- 3 Q: What the OPP were going to be doing 4 as they moved -- 5 A: At one (1) point there were supposed 6 to go in from where they -- where they were into 7 Ipperwash Camp -- 8 Q: Into the Provincial Park? 9 A: I can't recall. Ipperwash Park; 10 where they were going to go into with the police 11 officers. 12 Q: All right. You were just told that 13 you were required for backup? 14 A: Exactly. 15 Q: All right. When he came back to the 16 MNR parking lot, when he drove his suburban back to your 17 area, did he tell you that there was an individual with 18 them that required assistance? 19 A: No. 20 Q: He just told you, We require both 21 ambulances to go up to Army Camp and Highway 21? 22 A: Yes. 23 Q: All right. And that's what you did? 24 A: Yes. 25 Q: And, your recollection, I think, was

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1 that your partner, Mr. Tedball, called CACC and advised 2 them that you were leaving? 3 A: Yes. 4 Q: But, that wasn't you that did that, 5 we should look to Mr. Tedball to explain? 6 A: Yes. John did that. 7 Q: All right. Now, if I can take you to 8 21 and Army Camp Road. 9 A: Right. 10 Q: And, I can take you back to what 11 we've marked as Exhibit P-352. 12 A: Right. 13 Q: Is it fair to say that when you left 14 the MNR parking lot with a Code 4, you expected to arrive 15 and assist somebody or, perhaps, two (2) individuals that 16 had gunshot wounds? 17 A: Yes. 18 Q: Is it fair to say that when you 19 arrived at Army Camp Road and Highway 21 that you found 20 an incident a little bit different than what you 21 expected? 22 A: Yes. 23 Q: All right. Because when I look at 24 your drawing -- and I wasn't sure if we were able to put 25 this on the screen. Mr. Worme said it might be possible.

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1 COMMISSIONER SIDNEY LINDEN: Do we have 2 this document electronically? 3 MR. DONALD WORME: We don't have it 4 electronically. I just asked if they might be able to 5 scan that document and e-mail it me, in which case I'd be 6 able to put it up. I don't have that yet. 7 MR. KEVIN SCULLION: I got there a 8 little quicker. 9 COMMISSIONER SIDNEY LINDEN: How long 10 would that take? 11 MR. DONALD WORME: If we're taking our 12 morning break at some point soon, that may well be 13 possible during the break. 14 COMMISSIONER SIDNEY LINDEN: Do you want 15 us to do that, Mr. Scullion? 16 MR. KEVIN SCULLION: That would be 17 helpful. I -- I wanted to have a visual for the Witness. 18 COMMISSIONER SIDNEY LINDEN: Let's take a 19 morning break, then. 20 THE REGISTRAR: This Inquiry will recess 21 for fifteen (15) minutes. 22 23 --- Upon recessing at 11:51 a.m. 24 --- Upon resuming at 12:05 p.m. 25

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1 THE REGISTRAR: This Inquiry is now 2 resumed, please be seated. 3 COMMISSIONER SIDNEY LINDEN: Okay. 4 5 CONTINUED BY MR. KEVIN SCULLION: 6 Q: Thank you, Mr. Commissioner. I was 7 just about to go to a map, but over the break I found 8 another comment that I'd like to ask you about. 9 You've got Exhibit P-352 in front of you; 10 it should be stapled with eight (8) pages? 11 A: Yes. 12 Q: On the second-to-last page that Ms. 13 Esmonde was asking you about with the three (3) in the 14 top right corner; do you have that in front of you? 15 A: Right. 16 Q: Yeah. If you can go down to the -- 17 the commentary, it seems to be you're describing leaving 18 the MNR parking lot for Army Camp Road and 21 north on a 19 Code 4 for two (2) natives seriously injured; both 20 vehicles response Code 4 at 23:11 hours. 21 Do you see that comment? 22 A: At the very bottom? 23 Q: At the very bottom. 24 A: Yes. 25 Q: If you, then, flip the page, can you

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1 read that writing for me? 2 A: At the top? 3 Q: Yeah, I'd read it, but I'd probably 4 butcher it a little bit. What does that say? 5 A: "At first no lights and sirens due to 6 decreasing attention. Surrounding 7 balance (phonetic) centres and 8 residences near by." 9 That's the reason why we don't turn the 10 lights and sirens on to... 11 "Proceed Code 4 down East Parkway Drive 12 towards Ipperwash Road and then to 13 Highway 21 north proceeding northbound 14 to Army Camp Road and Highway 21 15 north." 16 Q: Okay. So, is it fair to say that 17 when you're leaving the MNR parking lot to go on this 18 other -- to this other location, you don't have the 19 sirens or the lights on at that point? 20 A: Yes. 21 Q: Do you know when the lights were 22 turned on, or were they turned on as you went up to Army 23 Camp and Highway 21? 24 A: Can't total -- if I was going to 25 mention, I would be guessing.

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1 Q: I don't want you -- I don't want you 2 to guess -- 3 A: I can't recall. 4 Q: All right. So, we'll look to Mr. 5 Tedball to see if he is able to help us there. 6 So, then you go up to Army Camp Road and 7 Highway 21 -- and what I'd asked to have put on 8 electronically, if I could have that flipped open, 9 there's a map... 10 11 (BRIEF PAUSE) 12 13 Q: Okay. We have up on the screen, it's 14 part of P-352, is a map that you drew of the area to the 15 best of your recollection. 16 That was drawn shortly after this as part 17 of your ambulance report? 18 A: Yes. 19 Q: Now is it -- I'm trying to place 20 where the ambulance, your ambulance parks in relation to 21 the question, the black or blue TransAm. 22 A: Right. 23 Q: It appears from this drawing, as well 24 as drawings prepared by Mr. DiCesare and another 25 ambulance attendant that the ambulance is actually across

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1 the road from the blue TransAm. 2 A: Yes. 3 Q: And it's in front of the police 4 vehicles as opposed to actually being behind them in 5 comparison to the blue TransAm; is that fair? 6 A: Say that again. 7 Q: It's in front the police vehicles, 8 and in fact, is the closest vehicle, out of the ambulance 9 and the police vehicles, to the blue TransAm? 10 A: Yes. 11 Q: All right. Is it fair to say that 12 when you arrived at the scene, if you were aware of what 13 was going on, you would have parked behind the police 14 vehicles? 15 A: Yes. 16 Q: All right. And the fact that you 17 parked in front of the police vehicles is a good 18 indication that you were a little surprised at what was 19 going on at that intersection? 20 A: Yes. 21 Q: All right. And when you realized, 22 looking over and seeing the police with their guns drawn 23 on occupants in the car, that you got out of your 24 ambulance and jumped into the ditch for your own safety? 25 A: Yes.

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1 Q: All right. But that ditch is still - 2 - how far away from the actual car itself? 3 A: Twenty/thirty (20/30) feet. 4 Q: Right. It's pretty close. It's 5 across Highway 21? 6 A: Yeah. 7 Q: All right. 8 A: Yes. 9 Q: At that point, you're speaking with 10 the police and they say, Don't move towards that car 11 until we give you the clearance? 12 A: Yes. 13 Q: All right. And you watched as they 14 had their guns drawn on the occupants of the car and 15 waited for them to say clear? 16 A: Yes. 17 Q: All right. And it's not until you 18 heard 'clear' that you went over and assisted, in fact, 19 Nick Cotrelle who was in that car? 20 A: Yes. 21 Q: We've heard evidence from Gina 22 George, who's Nick Cotrelle's mother, that she was one of 23 the people standing outside of the blue TransAm and that 24 she was calling across to the ambulance attendants, of 25 which you'd be one, to come over and help.

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1 Do you recall that happening? 2 A: No. 3 Q: You don't -- 4 A: I can't recall. 5 Q: Okay. So it's not that it didn't 6 happen, or that she's wrong, it's simply that you just 7 don't recall that as part of this incident? 8 A: Exactly. 9 Q: All right. And I just wanted to be 10 sure of the timing. It went a little bit quick for me to 11 follow, but it seemed to me from the reports that you 12 arrived in around 11:16. 13 Do you recall that Mr. Worme took you to-- 14 A: Yes, 23:11. Yes. 15 Q: Okay. And you left at 23:39? 16 A: Yes. 17 Q: And that part of that, and I'll 18 suggest it was a delay, of twenty-three (23) minutes to 19 take somebody from the back of the car into the ambulance 20 and to leave -- 21 A: Right. 22 Q: -- was due to the fact that you're in 23 the ditch, waiting for the go-ahead, to go assist this 24 individual? 25 A: Well, a combination of that, and plus

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1 the assessment that we did with the party that was in 2 that vehicle. 3 Q: Okay. So, it's a combination of the 4 two that took te twenty-three (23) minutes to leave the 5 area? 6 A: Yes. A combination of the delay and 7 the assessment, if you add that altogether, yes, that 8 would be correct. We -- 9 Q: Okay. 10 A: -- we left the scene -- well, I think 11 we got there to the scene at, was it 23:16, saw the 12 patient at 23:18 and then we left the scene at 23:39. 13 So, yeah, if you add that up. 14 Q: Okay. And I appreciate you're 15 working from your notes for the most part because it's 16 been nine (9) or ten (10) years; it's -- 17 A: Yeah. 18 Q: -- pretty difficult to remember 19 exactly what happened. But, at the same time, I'm going 20 to suggest to you that Gina George testified that when 21 you did come over to assess Nick Cotrelle in the car, 22 that there weren't a lot of questions asked of her or Mr. 23 Cotrelle, at least that she would have expected to be 24 asked, such as, Who is it, How old is he, and his basic 25 condition; is that fair?

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1 A: If we went to the passenger side and 2 looked at the patient, we would have -- I would have 3 asked him all those different questions, not -- not his 4 name, how old he is, but specifically what was going on. 5 The TRU Team members said that he was 6 possibly shot and he was in the passenger side, so I did 7 approach him, I would have ask him, Have you been shot, 8 he said he was. At that point, that's when me and Ceasor 9 started assessing him. 10 We took his, you know, cut his shirt off 11 and started doing our assessment. Because there's no way 12 we're going to move him from the passenger side right 13 onto the stretcher without knowing exactly what his 14 injuries are. 15 Q: Right. No, I understand that. And 16 you did a -- a verbal assessment to determine how serious 17 the situation was -- 18 A: Right. 19 Q: -- and once you determined that, you 20 decided a C collar and -- and a stretcher wasn't required 21 for this purpose? 22 A: Yes. 23 Q: All right. Is it fair to say that 24 you didn't speak to Gina George or don't recall speaking 25 with Gina George at that point in time?

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1 A: No, I didn't talk to her. 2 Q: Okay. What I'm interested in is when 3 you found out when Nick Cotrelle was only sixteen (16) 4 years old. 5 And I mention that to you because he seems 6 to be loaded onto the ambulance, and Gina George has 7 testified that she asked to come with you or with the 8 ambulance at point and was told that she couldn't do 9 that? 10 A: That's exact -- well -- 11 Q: Is that what you recall happening? 12 A: Oh yes. The only time we would have 13 a -- a patient, you know, the last thing I -- I needed in 14 the back of the ambulance is a very agitated mother. 15 She's going to get in the way, she's always focussed on - 16 - that's just the -- the normal thing that we normally 17 do. Yeah. 18 Q: Okay. So, the normal thing that you 19 would do is determine whether or not you want to have an 20 agitated mother in the back of the ambulance with you 21 with, with an injured teenager? 22 A: Yes. 23 Q: All right. 24 A: The only -- just to elaborate on 25 that, the only difference with that would be if we have a

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1 situation that it's a female, right, and if the female 2 has anything that's in her genitals or anything like 3 that, then that would be something that would be very 4 concern, right; we might have in that case. 5 Or if the patient is very, very young, it 6 might be a benefit to have the mother there; a very young 7 individual. Because sometimes they can calm the baby 8 down or whatever, right. It really -- 9 Q: Depends on the situation. 10 A: -- the difference in situation, yes. 11 Q: Fair enough. Have you had a -- a 12 situation where you've had a minor, and I refer to a 13 teenager as a minor, travelling in the back of an 14 ambulance with a police officer and the minor's being 15 arrested -- 16 A: That's the first time -- 17 Q: -- or read his rights? 18 A: -- first time for me. 19 Q: All right. So the fact that he was 20 being arrested or there's a potential for him to be read 21 rights, that's not something that you were thinking about 22 at that time? 23 A: No. 24 Q: All right. If you thought about 25 that, and I appreciate it's ten (10) years ago, would

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1 that have changed your opinion on having the mother come 2 with you? 3 A: No. I still wouldn't have had her 4 come. Because I could just imagine if I -- I was injured 5 and having my mom in the back of the ambulance, she would 6 just get in the way. I'm sitting there; I want to be 7 focussed on him. There's not so much room in the back of 8 an ambulance to begin with. 9 So if I have to move around and he's -- if 10 I have to suction him or anything to deal with that, or a 11 defibrillate him, or whatever happens in the midst, I 12 don't need to hear a hysterical mother. Nothing against 13 her, but that's just a normal situation I would do in any 14 case, right. 15 Q: Understood. And I think you've 16 mentioned that Nick Cotrelle was -- was calm? 17 A: Yes. 18 Q: And should I say polite to you -- 19 A: Yes. 20 Q: -- during this trip from the corner 21 of Army Camp and 21 all the way to Strathroy? 22 A: Yes. 23 Q: Okay. When he was speaking or when 24 Officer Boon was speaking to him, did he ever advise him 25 that he had a right to have his mother or a -- an adult

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1 with him? 2 A: Can't recall. 3 Q: All right. 4 5 (BRIEF PAUSE) 6 7 Q: Just one moment. 8 9 (BRIEF PAUSE) 10 11 Q: If I could skip ahead. When you 12 returned from Strathroy Hospital -- 13 A: Yes. 14 Q: -- after dealing with Mr. Cotrelle 15 and Mr. George, when you returned to the area I was a 16 little confused as to where you parked the ambulance and 17 how long you were there. 18 Did you go back to the MNR parking lot? 19 A: No -- 20 Q: No, it was -- 21 A: Ravenswood Road and Highway 21. 22 Q: All right. And at no point in time 23 were you called upon to do anything else in that area; 24 you just were there on standby? 25 A: Yes.

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1 Q: All right, so you couldn't shed any 2 light on what we've seen a little earlier as to an 3 evacuation or a situation where an evacuation of the Park 4 was occurring. 5 A: Can't recall. 6 Q: Okay. Those are all my questions, 7 Mr. Commissioner. 8 COMMISSIONER SIDNEY LINDEN: Thank you 9 very much. 10 Ms. Tuck-Jackson...? 11 12 (BRIEF PAUSE) 13 14 MS. ANDREA TUCK-JACKSON: Good afternoon, 15 Commissioner. 16 COMMISSIONER SIDNEY LINDEN: Good 17 morning. Good afternoon, I'm sorry. 18 MS. ANDREA TUCK-JACKSON: I carefully 19 checked the clock before I came before you. 20 COMMISSIONER SIDNEY LINDEN: Yes, I 21 should have paid attention. 22 23 CROSS-EXAMINATION BY MS. ANDREA TUCK-JACKSON: 24 Q: Good afternoon, Mr. Watt. My name is 25 Andrea Tuck-Jackson. I'm going to ask you some questions

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1 on behalf of the OPP. 2 A: Okay. 3 Q: And I want to take you, if I could 4 initially, back to the discussions that you were having 5 in the area of the MNR parking lot with Ted Slomer, the 6 individual we've heard is the medic, who was there with 7 the TRU Team. 8 And as you've already told us, you were 9 having discussions about the degree of preparedness of 10 everybody there, what in particular the level of first 11 aid abilities you and your colleagues had. 12 And I'm going to suggest to you, sir, that 13 you took it from the context of the conversation, that 14 Mr. Slomer and you and your colleagues were, in effect, 15 preparing for a worst case scenario; would that be fair? 16 A: Yes. 17 Q: Okay. It wasn't as if Mr. Slomer was 18 conveying to you that there was definitely going to be 19 gunshots exchanged, it was just that everyone in question 20 was preparing for the worst case scenario? 21 A: Exactly. 22 Q: Thank you. Now, I understand, sir, 23 that you and your partner arrived at the MNR parking lot 24 at 9:53 p.m.? 25 A: 9:53 p.m. I can't recall, but if

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1 that's the time you have. 2 Q: A moment's indulgence, Mr. 3 Commissioner. I'll try and assist Mr. Watt's 4 recollection. 5 If you look at Tab 5 of your materials, 6 they've been marked as Exhibit P-345 in these 7 proceedings, we know that you arrived -- yes, go to page 8 0009531, the Front Number in the top left-hand corner, 9 9531. 10 11 (BRIEF PAUSE) 12 13 A: Got it. 14 Q: Okay. And it indicates here that you 15 and Mr. Tedball, in unit 1146, arrived at 21:53:42? 16 A: Right. 17 Q: So, does that assist you in -- in 18 recalling that, indeed, you arrived at that parking lot 19 at about seven (7) minutes to 10:00 that night? 20 A: Yes. 21 Q: All right. And as you've already 22 testified, you remained in the vicinity of the parking 23 lot or even a little bit closer towards the blockade, 24 until you were dispatched to go down to the intersection 25 of Army Camp Road and Highway 21 at 11:11?

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1 A: Yes. 2 Q: Okay. And I'm going to suggest to 3 you, sir, that prior to the point and when I say -- I'm 4 directing you to a particular timeframe, just to get you 5 focussed in a timeframe. 6 In the timeframe up to the point where the 7 officers actually moved down East Parkway Drive, I'm 8 going to suggest to you that the atmosphere in the 9 parking lot around you was one of calmness. 10 A: Yes. 11 Q: Thank you. And in response, sir, to 12 requests that were being made of you in terms of possible 13 injuries that were taking place further down the road, 14 once you could overhear on the radio that there was 15 clearly some type of a confrontation going on, I'm going 16 to suggest to you, sir, that for you on the ground, at no 17 point did an officer prevent you from proceeding forward 18 to assist anyone in the area towards the Park. 19 A: Towards the call that we had or... 20 Q: No, I'm not talking about the call 21 that you responded to shortly after eleven o'clock, I'm 22 talking about before that point. 23 I'm going to suggest to you, at no point, 24 did an OPP officer prevent you from assisting anyone who 25 had been injured down towards the area of the Park.

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1 A: Towards where -- the day the 2 confrontation all happened? The only concern that we had 3 is we wanted to remain in the MNR parking lot because we 4 didn't know the safety. 5 Q: Exactly. You had some security 6 concerns for yourselves -- 7 A: Yes. 8 Q: -- but at no point, leaving that 9 issue aside, at no point did an officer prevent you from 10 attending anybody who was injured down towards the Park 11 area. 12 A: No, we didn't have a police officer 13 come up and say, You cannot go past this point. 14 Q: Right. If I could take you, 15 actually, to your report which in fairness, it's been 16 marked as Exhibit P-352 and it appears to be two (2) 17 individuals' reports, one (1) prepared by Mr. Gilpin, 18 from whom we'll be hearing, and one (1) prepared by you. 19 And in particular, I'm interested in page 20 3 of -- of your report. 21 A: Yes. 22 23 (BRIEF PAUSE) 24 25 Q: And you'll see, about four (4) lines

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1 in, that you received some information that there are 2 possibly two (2) individuals hit by gunfire. 3 And you have an indication here that TRU 4 members actually required you to move upwards, closer to 5 the dirt road, and possibly drive down the road towards 6 the confrontation scene, right? 7 A: Yes. 8 Q: And it was actually not an OPP 9 officer who intervened and said, No, you can't go down, 10 it was actually your partner, Mr. Tedball, who said, hang 11 on a second, we're supposed to remain back at the MNR 12 parking lot until, possibly, Mr. Slomer brings back any 13 injured to us. 14 A: Yes. 15 Q: So, indeed, there seemed to be a 16 suggestion by some officers that they wanted you to 17 actually go up to help somebody, but your partner pulled 18 back and said, Hang on, there's a different protocol in 19 place. Mr. Slomer wants us to stay back and the injured 20 will be bring -- brought to us. 21 A: Yes. 22 Q: And you understood that that was 23 primarily to protect your safety? 24 A: Yes. 25 Q: Because we haven't heard about it

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1 yet, sir, but I understand on that night, neither you nor 2 your partner nor the other two (2) ambulance attendants 3 who were there, had any protective gear that you could 4 wear? 5 A: Yes, that's correct. 6 Q: That's right. 7 8 (BRIEF PAUSE) 9 10 Q: You also told us, sir, that when you 11 arrived at the intersection of Army Camp Road and Highway 12 21, you had some concerns about your safety and security? 13 A: Yes. 14 Q: And that was because you noticed that 15 the officers, certain officers, had rifles drawn? 16 A: Yes. 17 Q: All right, and you indicated that you 18 weren't aware of any other information that might have 19 assisted you in explaining the context of that situation; 20 is that correct? 21 A: You mean like the drawn weapons and-- 22 Q: Why there was a perception or a 23 perceived need on the part of the officers to actually 24 draw their weapons? 25 A: No, we did -- I didn't know what was

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1 going on. 2 Q: Okay. Could I take you to page 4 of 3 your report? 4 5 (BRIEF PAUSE) 6 7 Q: Starting about four (4) lines down 8 from the top, you've written: 9 "Approaching closer, noticed 10 approximately two (2) to three (3) OPP 11 cruisers with TRU team members outside 12 behind vehicles. Apparently they 13 pulled over dark car with three (3) 14 occupants, two (2) female and one (1) 15 male, natives people, which apparently 16 were at confrontation site and the male 17 party was shot in the Park, hopped in 18 the car and fled the scene and was 19 stopped at Highway 21 North and Army 20 Camp Road. 21 And TRU Team presently have rifle drawn 22 to secure the scene for ambulance 23 personnel to move in and treat patient, 24 et cetera." 25 Obviously, at some point you received this

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1 information that the police at the time understood that 2 the car in question had come from the scene of the 3 confrontation and that it contained an individual who 4 they were concerned had suffered a gunshot wound? 5 A: Yes. 6 Q: Do you recall when you learned this 7 information? 8 A: At the time when we were approaching 9 the vehicle, the -- the -- one (1) of the TRU Team 10 members says that the passenger or the victim is in the 11 passenger seat -- seat, possibly with a gunshot. 12 Q: Okay. I'm more interested in 13 knowing, when did it come to your attention? Excuse me, 14 when did it come to your attention that the officers at 15 the scene understood that this vehicle had actually been 16 at the confrontation? 17 A: I can't recall that at all. 18 Q: Okay, but obviously -- 19 A: They didn't specifically say, This 20 vehicle is from the -- from the confrontation. All -- we 21 just came up to the vehicle where it was sitting, I 22 didn't know exactly where it came from. 23 Q: Okay. Let's go back to the passage, 24 then, that I just read to you. 25 A: Okay.

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1 Q: "They pulled over a dark car with 2 three (3) occupants, two (2) female and one 3 (1) male, which apparently were at 4 confrontation site. 5 Now, it may be that -- and you'll have to 6 assist us whether 'were' is referring to the individuals 7 or the car or both. 8 A: 'Were'; I'm talking about people 9 there were at the confrontation. 10 Q: All right. So, what I'm interested 11 in knowing, sir, because I think it's important that 12 everyone understand what was in the heads and the minds 13 of the officers at that intersection before you arrived-- 14 A: Right. 15 Q: And you've obviously -- you've 16 written this down in your report; you've gotten the 17 information from somewhere and I'm trying to ascertain 18 when you learned that the officers believed that these 19 three (3) individuals had actually been at the 20 confrontation scene. 21 A: These individuals? I can't recall. 22 Q: All right. So, it may have been 23 either at the very time when you approached the 24 intersection or it may have been at some point after? 25 A: Exactly.

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1 Q: Okay. Thank you, Mr. Watt, those are 2 my questions. 3 A: Thanks. 4 COMMISSIONER SIDNEY LINDEN: Thank you, 5 Ms. Tuck-Jackson. Ms. Jones...? 6 7 (BRIEF PAUSE) 8 9 CROSS-EXAMINATION BY MS. KAREN JONES: 10 Q: Good afternoon, Mr. Watt. 11 A: Good afternoon. 12 Q: My name's Karen Jones and I'm one (1) 13 of the lawyers who acts for the Ontario Provincial Police 14 Association. 15 A: Okay. 16 Q: And I just had some questions for 17 you. 18 I wanted to take you back, you had talked 19 a little bit earlier about the briefing that you got from 20 Ted Slomer and Sergeant Lacroix? 21 A: Yes. 22 Q: And I've been listening to you and -- 23 and one (1) of the things it sounds to me like is that 24 you have a fairly hazy recollection of some of the 25 specifics of what went on that night; it happened a long

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1 time ago. 2 A: Oh, definitely. 3 Q: Yeah, and you've talked a little bit 4 about what you recall Sergeant Lacroix saying about the 5 situation and is it fair to say that you recollection of 6 that is quite hazy as well? 7 A: Yeah, it'd be foggy, yes. 8 Q: Okay. When I looked at your 9 ambulance incident report and that's that document, I 10 think, that's in front of you. 11 A: Yes. 12 Q: And, if you look at page 2 of that 13 report on the top third of the page and I'm looking at 14 the bottom four (4) lines. Sorry, just to go back a 15 little bit, if you go up about seven (7) lines, you see a 16 reference to a Sergeant Lacray or Lacroix and I -- 17 A: Yes. 18 Q: -- take it by that you mean Sergeant 19 Lacroix? 20 A: Yes. 21 Q: Okay. You're speaking in your 22 statement there about Sergeant Lacroix debriefing us 23 about the situation and responsibilities and you go on a 24 little bit and then you say: 25 "At this time, Mac Gilpin asked

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1 Sergeant some questions about the 2 situation." 3 Do you see that? 4 A: Yes. 5 Q: And do I take it that that's the 6 period of time where you got the information about what 7 the OPP were doing and what might happen, when Mr. Gilpin 8 was there? 9 A: Yes. He -- Mac was asking a little 10 more specifics, exactly what was -- 11 Q: Right. 12 A: -- going to transpire. 13 Q: And -- and I've looked at all of your 14 statements and all of your notes, and I haven't seen 15 anything specifically in those statements or notes that 16 would indicate what Sergeant Lacroix told you, to help 17 you refresh your memory; and I'm not sure if you've had a 18 chance to look at everything in your binder. 19 A: That's -- that's true. 20 Q: All right. 21 A: I haven't seen it. 22 Q: And what Mr. Gilpin noted in his 23 Ambulance Incident Report, you see, and for the 24 assistance of Counsel, this is Inquiry Document Number 25 5000471, at page 1705.

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1 A: Did you want me to look at that too, 2 or...? 3 Q: I'm not sure that it's in the package 4 that was handed out to you. 5 A: Yeah, I don't think I have it. 6 Q: No, I don't think you do. But maybe 7 we can put it up and I can certainly read to you what it 8 says, and see if that assists you in refreshing your 9 memory at all. 10 11 (BRIEF PAUSE) 12 13 Q: What Mr. Gilpin says in his Ambulance 14 Incident Report is: 15 "Officer Lacroix indicated the purpose 16 tonight was not to remove the Natives 17 from the Park and he was not aware." 18 And he sort of goes on and talks about 19 more things. And I'm wondering if that assists you at 20 all or helps you recall what Sergeant Lacroix spoke to 21 you about? 22 A: It doesn't recall at all. All I know 23 is Mac was my boss and if he was -- 24 Q: Sure. 25 A: -- walking over to one (1) of the top

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1 sergeants, I was -- 2 Q: Sure. 3 A: -- if I needed to know whatever he 4 was saying, he would have told me, but I can't recall, 5 no. 6 Q: You can't recall specifically what 7 Sergeant Lacroix said? 8 A: No. 9 Q: No, okay. And I wanted also to ask 10 you just a couple questions about when you first assessed 11 Nicholas Cotrelle, when you were at the blockade and you 12 were approaching the dark car -- 13 A: Yes. 14 Q: -- that had the two (2) women and the 15 boy in the car. And you were asked some -- and I take it 16 that when you were approaching the car, what you saw was 17 the two (2) women standing by the car with their hands 18 up? 19 A: Yes. 20 Q: Okay. There was nobody on the 21 ground? 22 A: No. 23 Q: Okay. And you were asked, earlier, 24 some questions about whether or not you heard what the 25 women were saying ord what the police were saying when

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1 you were at the ditch, and you had told us that you 2 couldn't hear? 3 A: Yes. While I was in the ditch -- 4 Q: Yes. 5 A: -- while there was discussion that 6 was going on between -- 7 Q: Right. 8 A: -- either side? Couldn't hear 9 anything. 10 Q: Okay. The question I had for you 11 was: When you were then approaching the car, could you 12 hear any conversation or any -- anything that was being 13 said by either the two (2) women or by the OPP officers? 14 A: See, most -- my recall is I was just 15 listening to the police officers; they had control of the 16 scene. 17 Q: Right. 18 A: See, if I listen to the -- it's 19 because the situation -- 20 Q: Yeah. 21 A: -- and guns drawn, everything else, I 22 was scared about my safety. 23 Q: Sure. 24 A: So I wanted to listen to him because 25 he's got the rifle, right.

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1 Q: Sure. 2 A: So he said that everything was clear. 3 And as I -- 4 Q: Right. 5 A: -- walked up there, I -- I think I 6 would have asked him where the patient is, that's when he 7 yelled out, The patient is in the passenger side. So 8 other than that, I didn't hear anything what the -- the 9 females said; I can't recall. 10 Q: Okay. And you've described the 11 mother as being very agitated; can you tell us why you 12 described her as very agitated? 13 Was there something that you heard -- 14 A: I don't know if there's a mother -- 15 Q: -- or something that you saw -- 16 A: -- all I know is those two (2) 17 bystanders were very excited -- agitated. 18 Q: Okay. 19 A: But, I can't recall exactly what they 20 were saying. 21 Q: Okay. And also just to clarify, 22 you've told us that as at that point in time, you had 23 never seen a bullet wound. 24 A: Exactly. 25 Q: And I take it that you wouldn't be

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1 able to recognize one, because you hadn't seen one 2 before? 3 A: Exactly. I've seen pictures, maybe, 4 but I haven't -- 5 Q: Sure. 6 A: -- seen anything... 7 Q: Sure. And so at the time that you 8 examined Nicholus Cotrelle, you could make some 9 observations but you didn't know what caused the wound 10 that you saw? 11 A: Well, exactly. 12 Q: Right. 13 A: I just went from the TRU Team member, 14 what they said, what he told me. 15 Q: Sure. So, you had a bunch of 16 information and you made an assumption, but you didn't 17 know? 18 A: Didn't know for sure, no. 19 Q: Right. Okay. 20 A: But I had to tell Emerg. something. 21 Q: Something. 22 A: Yeah. 23 Q: Right. 24 25 (BRIEF PAUSE)

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1 Q: And when I looked at your statement 2 from the SIU which, let's see, and if you want to refresh 3 your memory, if you look in your binder it's at Tab 6 of 4 your binder, and this is Inquiry Document Number 1002503. 5 A: 250 -- 6 Q: Okay? 7 A: Say that number again. 8 Q: It's at your Tab 6 -- 9 A: Tab 6? 10 Q: -- of your binder. 11 A: And what's the number? 12 MR. DONALD WORME: 353. 13 14 CONTINUED BY MS. ANDREA TUCK-JACKSON: 15 Q: It's -- sorry, P-353, that's the 16 exhibit number. 17 A: Oh, so -- 18 Q: And the Inquiry Document Number is 19 1002503. 20 A: P-353. 21 Q: And you told us a little bit about -- 22 THE REGISTRAR: 2615. 23 COMMISSIONER SIDNEY LINDEN: 2615 is the 24 number we've got, Ms. Jones. 25 THE WITNESS: Yeah.

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1 COMMISSIONER SIDNEY LINDEN: 1002615. 2 MS. KAREN JONES: Okay, okay. 3 THE WITNESS: Yes. 4 5 CONTINUED BY MS. KAREN JONES 6 Q: In any event, when Mr. Cotrelle was 7 telling you what happened to him -- 8 A: Yes. 9 Q: -- do you recall what he said? 10 A: Well, the time that I was talking to 11 him, if -- 12 Q: Yeah. 13 A: -- and finding out exactly how the 14 entry of his wound was, he says he was standing, he was 15 shot in the back -- 16 Q: Okay. 17 A: -- and then he walked to the car. 18 Q: Sure, okay. 19 20 (BRIEF PAUSE) 21 22 Q: And Ms. Tuck-Jackson asked you some 23 questions about whether or not, when you were at the MNR 24 parking lot, whether or not you were ever refused access 25 or refused to -- or were not allowed to move up to the

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1 confrontation area and assist people and you told her 2 that no one stopped you. 3 In fact, it was your partner that said you 4 should stay at the MNR parking lot? 5 A: Yes. 6 Q: Yeah. And similarly, you've told us 7 again this morning that when you got to Highway 21 and 8 Army Camp Road that you waited for the police to tell you 9 that the scene was secure, but I take it once that 10 happened, you were allowed full access to do what you 11 needed to do? 12 A: Yes. 13 Q: And similarly I take it that when you 14 were at the hospital, you were not impeded in any way 15 from assisting or helping anyone -- 16 A: Yes. 17 Q: -- by the police? Right. Okay. 18 Thank you very much. 19 A: Thanks. 20 COMMISSIONER SIDNEY LINDEN: Thank you 21 very much. 22 Mr. Worme...? 23 MR. DONALD WORME: I don't have any 24 re-examination, Mr. Commissioner. 25 I wish to thank Mr. Watt for his

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1 attendance and his testimony. 2 COMMISSIONER SIDNEY LINDEN: Thank you 3 very much, Mr. Watt. You've finished now. 4 5 (WITNESS STANDS DOWN) 6 7 COMMISSIONER SIDNEY LINDEN: I think it's 8 too early to break for lunch. I think the next witness 9 is here, we should start. 10 11 (BRIEF PAUSE) 12 13 COMMISSIONER SIDNEY LINDEN: We'll go 14 through to about one o'clock and then break for lunch. 15 MS. KATHERINE HENSEL: Until one o'clock? 16 COMMISSIONER SIDNEY LINDEN: Because of 17 this -- the late start, it's always hard to know of a 18 good time to stop, but if that makes sense, about one 19 o'clock? 20 MS. KATHERINE HENSEL: Okay. 21 22 (BRIEF PAUSE) 23 24 MS. KATHERINE HENSEL: The Commission 25 calls as its next witness Ernest John Tedball.

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1 THE REGISTRAR: Good afternoon, Mr. 2 Tedball. Do you prefer to swear on the Bible, sir, or 3 affirm? 4 THE WITNESS: Yes, the Bible, sir. 5 THE REGISTRAR: The Bible. Very good, 6 sir. State your name in full for us, please? 7 THE WITNESS: Ernest John Tedball. 8 THE REGISTRAR: Thank you. 9 10 ERNEST JOHN TEDBALL, Sworn 11 12 EXAMINATION-IN-CHIEF BY MS. KATHERINE HENSEL: 13 Q: Good afternoon, Mr. Tedball. We are 14 just going to get started here and then we will break for 15 lunch, but we should be able to get a little ways through 16 your testimony. 17 I understand, sir, that you were born on 18 March 29th, 1951 -- 19 A: Yes. 20 Q: -- is that correct? And, that you 21 attended Conestoga College in Kitchener attaining a 22 degree or a diploma, sorry, in Ambulance and Emergency 23 Care in June of 1984 -- 24 A: Yes. 25 Q: -- that's correct? Can you tell us

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1 what you -- what that program would have entailed? 2 A: Emergency care, looking after sick 3 and injured people. 4 Q: Okay. And did you learn about 5 anatomy? 6 A: Yes. 7 Q: And, transporting patients? 8 A: Yes. 9 Q: Okay. What did you learn about 10 transporting -- briefly, if you can describe in a general 11 way what you learned about transporting patients? 12 A: Expect the worst until otherwise 13 proven. 14 Q: And how long was that program? 15 A: It was from August to June. 16 Q: Okay. So, that would be roughly -- 17 A: About ten (10) months. 18 Q: Ten (10) months. 19 A: Probably closer to nine (9). 20 Q: Okay. And, I understand that prior 21 to entering that program, you were a farmer and a cabinet 22 maker, among other things? 23 A: Yes. 24 Q: As well as a volunteer firefighter? 25 A: Yes.

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1 Q: And, you were a volunteer firefighter 2 for roughly how long prior to 1984? 3 A: Fourteen (14) years. 4 Q: Fourteen (14) years. Okay. And, 5 did you receive any medical or emergency first aid 6 training as -- as part of your training as a volunteer 7 for firefighter? 8 A: First aid. 9 Q: First aid? 10 A: And CPR. 11 Q: Basic first aid? 12 A: Yes. Basic and CPR. 13 Q: Okay. Okay. And, did you continue 14 to serve as a volunteer firefighter once you entered the 15 program in 1980 -- well, you would have entered it in 16 1983? 17 A: Yes. 18 Q: Okay. And, for how long did you 19 serve as a volunteer firefighter? 20 A: Until '84. 21 Q: Okay. 22 A: Hmm hmm. 23 Q: And, I understand that you are 24 currently also a volunteer firefighter? 25 A: Yes, I am.

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1 Q: And, how long -- how long have you 2 been a volunteer -- when did you start doing that -- 3 A: Three (3) years. Three (3) years. 4 Q: Three (3) years? 5 A: Hmm hmm. 6 Q: So, since 2002? 7 A: Yes. 8 Q: Okay. All right. And, I understand 9 that in 1995 you were employed as a Paramedic Level I 10 with the Forest Ambulance Service in -- in Forest, 11 Ontario? 12 A: Yes. 13 Q: Okay. In 1995, how long had you been 14 doing that? 15 A: Almost eleven (11) years. 16 Q: Okay. So, since 1984? 17 A: Yes. 18 Q: Okay. And had you lived in Forest 19 the entire time that you'd served in that capacity as a 20 paramedic? 21 A: Yes. 22 Q: Okay. And, are you currently also 23 employed as a Paramedic Level I? 24 A: Yes. 25 Q: Still with the Forest Ambulance

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1 Service, or...? 2 A: Lambton County Ambulance Service, hmm 3 hmm. 4 Q: All right. So, the -- the ambulance 5 service has changed -- has changed hands, so to speak? 6 A: Yes. 7 Q: Okay. And, roughly when would that 8 have occurred? 9 A: It was in 2000 -- the year 2000. 10 Q: Okay. 11 A: I believe it was December of 2000. 12 Q: Okay. But, you've been employed 13 continuously since 1984 in your capacity as an ambulance 14 attendant or driver in Forest, Ontario? 15 A: Yes. 16 Q: Okay. Can you describe for us what 17 other emergency medical training you have had in addition 18 to those you have described at Conestoga College and as a 19 volunteer firefighter? 20 A: I've been trained in what we call 21 symptom relief, medication and automatic defibrillator. 22 Q: Okay. All right. And do any of -- 23 does any of that training involve the administration of 24 medication? 25 A: Yes.

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1 Q: Which? 2 A: Symptom relief. 3 Q: Symptom relief. And can you describe 4 briefly what medications you would be trained to 5 administer? 6 A: For allergic reaction, Epinephrin. 7 Q: Hmm hmm. 8 A: For heart problem would be Nitro or 9 ESA. For a diabetic problem, Glucagon. And for a 10 breathing problem, Medrol. 11 Q: Okay. And that's the extent of the 12 medications that you're trained to administer? 13 A: Yes. 14 Q: All right. And are you currently 15 permitted to administer any medications that you're not 16 trained or certified in the use of? 17 A: No. 18 Q: Okay. Moving now to September of 19 1995, on September 6th, I understand that you worked the 20 day shift? 21 A: Yes. 22 Q: And what hours would that have 23 encompassed? 24 A: From 8:00 in the morning until 6:00 25 at night.

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1 Q: Okay. All right. And I understand 2 that you received a call later that day from your 3 dispatcher -- or were you paged or were you called? 4 A: Paged. 5 Q: Paged. Okay. And do you recall 6 approximately at what time you would have received that 7 page? 8 A: Possibly eight o'clock that night. 9 Q: Okay. Okay. And what did you do as 10 a result of being paged? 11 A: Dave told us to go our ambulance 12 base. 13 Q: Okay. So, you called in to the -- 14 the dispatcher? 15 A: Once we got up to the ambulance base. 16 Q: Okay. 17 A: Hmm hmm. 18 Q: All right. And that would have been 19 Wallaceburg dispatch? 20 A: Yes. 21 Q: Okay. And what happened once you got 22 -- what did you learn when you got to the ambulance base? 23 A: They put us on a standby at the 24 ambulance base and said that we could be possibly going 25 out to the Ipperwash area.

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1 Q: Okay. Do you recall at approximately 2 what time you would arrived at the ambulance base? 3 A: Probably five (5) minutes, six (6) 4 minutes. 5 Q: Okay. If I could take you, sir, to 6 Tab 8 in the Brief of Documents in front of you -- which 7 is, for the record, Document Number 1002002, and that has 8 been marked as Exhibit P-345, I believe. 9 10 (BRIEF PAUSE) 11 12 Q: Okay. And you'll notice, it's on the 13 second page of the documents in front of you, Mr. Tedball 14 -- and that is Front Number 9532 for those of you trying 15 to locate it in the database. 16 That document indicates that -- I believe 17 it's called you oasis number, which is 75894; is that 18 correct? 19 A: Yes. 20 Q: Okay. That dispatch report notes 21 that you were notified on September 6th, 1995, at 22 20:56:50, which would have been 8:56 p.m.? 23 A: Yes. 24 Q: Now, by your understanding, would 25 that have been then time -- of how dispatch reports are

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1 completed, would that have been the time that you were 2 paged at your home? 3 A: Yes, it would. 4 Q: Okay. And does that refresh your 5 memory as to the time that you were paged? 6 A: Yes. 7 Q: Okay. All right. We will be 8 returning to that document but -- so I understand that 9 you attended with your partner, who has testified here 10 today, Mr. Mark Watt? 11 A: Hmm hmm. Yes. 12 Q: And this was to the Forest ambulance 13 base; is that correct? 14 A: Yes. 15 Q: Could you tell us, if you would, 16 where -- where that's located in Forest? 17 A: That's located at 112 King Street 18 East. 19 Q: Okay. 20 A: The north end of 21 Highway or King 21 Street. 22 Q: Okay. And you did describe that -- 23 that you were told to standby on Code 8? 24 A: Yes. 25 Q: Standby. And were you told any --

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1 and for possible attendance at Ipperwash, were you told 2 anything further by dispatch about what was happening or 3 could be happening at -- at Ipperwash? 4 A: No. 5 Q: All right. Were you told 6 approximately -- were you told to attend in that area 7 immediately, on standby, or to -- to stay on standby at 8 the -- at the Forest ambulance base? 9 A: Stay on standby at the Forest base. 10 Q: Okay. And at some point, you were 11 directed, however, to -- to attend in the area. What 12 were you told about why you were travelling to -- to that 13 area, as opposed to staying in the Forest ambulance base? 14 A: I believe it was the police wanted us 15 in that area. 16 Q: Okay. You were told this by 17 dispatch? 18 A: Yes. 19 Q: Okay. And I could take you back to 20 the document I referred to earlier, which I see you still 21 have in front of you, which is Front 9532 in Exhibit P- 22 345. 23 In that dispatch -- that dispatch report 24 notes that you were enroute at 21:41 and eleven (11) 25 seconds.

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1 (BRIEF PAUSE) 2 3 Q: Would that accord with your memory of 4 when you would have travelled or left the ambulance base 5 to travel to the Ipperwash area? 6 A: I would believe so. 7 Q: Yeah. So, that would have been 8 roughly forty-five (45) minutes after you first -- were 9 first paged? 10 A: Yes. 11 Q: Okay. Okay. And you were told by 12 your dispatch where to go at -- in the Ipperwash area? 13 A: I believe so. 14 Q: Okay. 15 A: Hmm hmm. 16 Q: And you were told -- directed to 17 attend the Ministry of Natural Resources parking lot? 18 A: Yes. 19 Q: And that's located on East Parkway 20 Drive? 21 A: Yes. 22 Q: Okay. And were you told anything 23 further beyond the fact that police had requested your 24 presence about what might be happening in the area? 25 A: I don't recall that, no.

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1 Q: Okay. Were you briefed as to the 2 best route that you should take? 3 A: No. 4 Q: All right. Okay. Were you aware, at 5 that point, of what was going on at Ipperwash Provincial 6 Park? 7 A: Only because of the news that we'd 8 been listening to, we presumed what was happening. 9 Q: Okay. And at that point, did you 10 have any concerns about travelling into that area? 11 A: As travelling out, no. 12 Q: No. All right. Do you recall being 13 stopped at a police checkpoint along the way at any 14 point? 15 A: I think it was just as we turned onto 16 Parkway, off of centre Ipperwash Road. 17 Q: Okay. And did you have any 18 conversations with the police officers manning that 19 checkpoint? 20 A: Just directed us into the parking lot 21 which is right close by. 22 Q: All right. All right. And on your 23 arrival at the MNR parking lot, what did you observe? 24 A: There was some police vehicles there, 25 seemed to be further back than where we were eventually

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1 stopped. 2 Q: Okay. And did you notice any groups 3 of police officers -- 4 A: If I did -- 5 Q: -- of the vehicles? 6 A: -- if I did, they were, like, farther 7 back. 8 Q: Okay. 9 A: Hmm hmm. 10 Q: And was it dark by this time, by the 11 time you arrived? 12 A: Yes, I think it was. 13 Q: Okay. And do you recall if you could 14 see, with what natural lighting that existed at the time, 15 could you see the entire parking lot? 16 A: I don't remember that. 17 Q: Okay. Do you recall if there was any 18 artificial lighting? 19 A: I don't recall that neither. 20 Q: Okay. All right. And, so you 21 arrived at the MNR parking lot and who did -- to whom did 22 you report? 23 A: Sergeant Lacroix. 24 Q: Okay. And what did he tell you? 25 A: He was surprised the way we were

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1 dressed. He asked if we had any body armour and we said 2 no, and also he said that the reason why we were there 3 was possibly they were concerned of firebombs. 4 Q: Okay. And did he have any other -- 5 did he tell you any other reasons, aside from firebombs, 6 for his concern about the way you were dressed? 7 A: Well, he was just concerned that we 8 didn't have any armour on, whatever you want to call it, 9 bullet-proof vests or anything. He was just surprised we 10 didn't have them. 11 Q: Okay. At that time, did your service 12 -- your ambulance service keep that type of equipment in 13 its inventory -- 14 A: No. 15 Q: -- for your use? 16 A: No. 17 Q: Does it now? 18 A: No. 19 Q: Okay. And were you offered at that 20 point -- 21 A: Not at that -- 22 Q: -- the use of any protective 23 equipment? 24 A: -- not at that point, nope. 25 Q: Did that make you anxious, the fact

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1 that he was concerned that you didn't have protective 2 gear? 3 A: Yes. 4 Q: Okay. Did you express your anxiety 5 to him? 6 A: No, I don't -- I don't think I did. 7 Q: Okay. And the officers -- first of 8 all, you had a conversation with Mr. Lacroix; did you see 9 any other officers at that point in the area? 10 A: If I did, I can't recall who they 11 were. 12 Q: Okay. All right. And do you have 13 any recollection of what the police officers -- but you 14 did see some police officers -- 15 A: Yes. 16 Q: -- in the parking lot? do you recall 17 what they were wearing? 18 A: A blue-type uniform, looked like it 19 was, like, for their protection -- 20 Q: Hmm hmm. 21 A: -- helmet, they had a shield, and I 22 think I recall, like, a -- a gun or something on the side 23 of them. 24 Q: And you noticed these -- or these 25 officers when you first arrived?

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1 A: Probably not right at first, like, as 2 we stood around and looked around. 3 Q: And did you see any officers carrying 4 long guns? 5 A: I can't recall that? 6 Q: Okay. All right. So, Officer 7 Lacroix had a conversation with you about protective 8 gear; what did he -- what, if anything, did he direct you 9 to do next? 10 A: He told us, Stay here, in the Park. 11 Q: Did he direct you where to park your 12 vehicle -- 13 A: Yes. 14 Q: -- or were you already situated by 15 that point? 16 A: I think we already were parked and... 17 Q: Okay. And where were you parked, 18 roughly, in -- in the MNR parking lot? 19 A: Just nicely off the -- off Parkway 20 Drive, probably a couple hundred feet off. 21 Q: Couple hundred feet away from East 22 Parkway Drive? 23 A: Yes. 24 Q: Okay. All right. I am going to move 25 to a slightly different area, so this might be an -- a

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1 good time to break for lunch, Mr. Commissioner. 2 COMMISSIONER SIDNEY LINDEN: That's fine. 3 We'll break for lunch now. 4 THE WITNESS: Thank you. 5 THE REGISTRAR: This inquiry stands 6 adjourned until 2:15. 7 8 --- Upon recessing at 1:01 p.m. 9 --- Upon resuming at 2:16 p.m. 10 11 THE REGISTRAR: This Inquiry is now 12 resumed. Please be seated. 13 MS. KATHERINE HENSEL: Good afternoon, 14 Commissioner. 15 16 CONTINUED BY MS. KATHERINE HENSEL: 17 Q: Good afternoon Mr. Tedball. 18 A: Katherine. 19 Q: Just before the break you had 20 discussed your arrival in the MNR parking lot and your 21 conversation with Wade -- Sergeant Lacroix. 22 I understand at some point you came to be 23 speaking to a man that would have been identified as an 24 OPP medic; is that correct? 25 A: Yes.

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1 Q: Okay. Actually, perhaps, I should go 2 back. Did Officer Lacroix introduce you to a man who you 3 -- you understood to be an OPP medic? 4 A: I don't remember that. 5 Q: Okay, but you knew that the person 6 that you were speaking to was an OPP medic? 7 A: Yes. 8 Q: Okay, did you know his name at that 9 time? 10 A: Yes. 11 Q: And what was it? 12 A: Ted Slomer, Ted Slomer. 13 Q: Okay. And can you describe the 14 conversation that you would have had with that person? 15 A: Ted was speaking to us on -- if there 16 was anybody injured, casualties that they would be 17 brought to the MNR parking lot or where we were situated 18 there and they could be intubated or they could have an 19 IV running. 20 Q: Okay. And were you capable of -- did 21 he ask you whether you were capable of intubating or... 22 A: No, no. These patients would be 23 prior incubated if -- in that case; we're not trained in 24 that. 25 Q: Okay. So, did he indicate that he

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1 would be able to perform those? 2 A: Well, we just presumed that he would. 3 Q: You presumed that he would? 4 A: Hmm hmm. 5 Q: Okay. And did he give you any 6 explanation or description of his training or level of 7 expertise with respect to those technologies? 8 A: No. 9 Q: No? Okay. But he did indicate to 10 you that if intubation or an IV were necessary that he -- 11 that the patients would be brought to you with the 12 intubation or IV already performed? 13 A: Well, he sort of said that how would 14 we feel with the patient being intubated with an IV 15 going, and we said we'd be okay with that. 16 Q: Okay, and you took that to mean you'd 17 be okay transporting such a patient? 18 A: Yes. 19 Q: Not initiating those treatments? 20 A: No. 21 Q: Okay. Okay. Did you have any other 22 conversations with -- with him with respect to your 23 ability or capacity to transport patients? 24 A: No, he -- just the fact that he would 25 bring them to us.

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1 Q: Okay. Did he instruct you to stay in 2 the same spot in the MNR parking lot? 3 A: Just stay in the MNR parking lot. 4 Q: All right. Did he instruct you to 5 stay near your vehicle? 6 A: I don't recall that. 7 Q: Okay. But he -- he nevertheless made 8 it clear that any patients would be brought to you -- 9 A: Yes, that was -- 10 Q: -- rather than having you travel to 11 those patients? 12 A: -- that was our understanding. 13 Q: Okay. Were you instructed to turn 14 off your vehicle lights and engine? 15 A: Yes. 16 Q: And was that by Mr. Slomer or Mr. 17 Lacroix? 18 A: I think it was Sergeant Lacroix. 19 Q: Okay. And did he indicate why you 20 should do that? 21 A: So we wouldn't be visible. 22 Q: Okay. And, now I understand that on 23 September 6th you were in -- Operating Unit 1146? 24 A: Yes. 25 Q: And Mr. Watt was driving that?

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1 A: No, I was driving. 2 Q: You were driving that? 3 A: Hmm hmm. 4 Q: I'm sorry. And, there was another 5 ambulance, I understand in the MNR parking lot while you 6 were there, Unit 1145? 7 A: Yes. 8 Q: And that was staffed by Mr. DiCesare 9 and Mr. Gilpin? 10 A: That's right. 11 Q: Okay. Do you recall when that unit 12 arrived? 13 A: I think we just arrived at the same - 14 - same time. 15 Q: Okay. All right, and was it your 16 understanding that you would be on standby, sort of 17 indefinitely, while you were there? 18 A: That's right. 19 Q: Okay. And at any point did Sergeant 20 Lacroix tell you anything about what the police operation 21 was going to be or was possibly going to be that evening? 22 A: Not to me. 23 Q: Okay. At any point did he indicate 24 to you that police would be marching down the road 25 towards Ipperwash Provincial Park?

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1 A: No, he didn't. 2 Q: No, he didn't? And describe for us, 3 if you will, what you saw while you were on standby, 4 prior to your being approached to assist with any 5 patients? 6 A: Well, we did see some movement around 7 eleven o'clock -- 8 Q: Hmm hmm. 9 A: We were -- just presumed that the 10 police had left the MNR campground or the -- 11 Q: Hmm hmm. 12 A: -- parking lot, because we could see 13 these vehicles moving -- 14 Q: Okay. 15 A: -- just from the outline; it was 16 dark. 17 Q: Okay. Could you see officers moving? 18 A: No. 19 Q: All right, at any point, did you see 20 officers moving in formation that evening? 21 A: I don't remember that. 22 Q: Okay. Okay. You mentioned seeing 23 police vehicles leave in the darkness at around eleven 24 o'clock? 25 A: Yes.

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1 Q: Okay. Did you see where they were 2 going? 3 A: No, I just presumed they went down 4 Parkway. 5 Q: But, you didn't see which direction 6 they headed? 7 A: No, I didn't. I can't recall that at 8 all. 9 Q: And what did those vehicles look 10 like? 11 A: I thought they were black in colour. 12 Q: Hmm hmm. 13 A: Black in colour, that's all. 14 Q: But it was dark, so -- 15 A: Yeah. 16 Q: -- it could have been any dark 17 colour? 18 A: Hmm hmm. 19 Q: Yeah. All right. And what is the 20 next thing of significance that happened after you saw 21 those vehicles leave? 22 A: It was approximately just -- I'm not 23 quite sure, say ten (10) minutes later, something -- 24 Q: Hmm hmm. 25 A: -- like that, there was a gentleman

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1 in army fatigues, as I'd call it, camouflage outfit -- 2 Q: Hmm hmm. 3 A: -- jumped in our ambulance and told 4 us to drive -- 5 Q: Hmm hmm. 6 A: -- down Parkway. 7 Q: Okay. You were in your ambulance at 8 the time? 9 A: Yes. 10 Q: Okay. And just in terms of his 11 appearance, was -- you said he was wearing camouflage; 12 was he wearing any headgear? 13 A: I don't -- I don't recall that -- 14 Q: Hmm hmm. 15 A: I remember his face being painted. 16 Q: How was it painted? 17 A: Like maybe a green all over. 18 Q: And was he armed? 19 A: I think he was carrying a -- a -- 20 what you call, long gun? 21 Q: Hmm hmm. All right. And you -- you 22 can't be any more specific -- 23 A: No. 24 Q: -- about the type of gun? 25 A: No.

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1 Q: Okay. And, I'm sorry, what did he -- 2 what did he -- 3 A: He instructed us -- 4 Q: -- what did he do next? 5 A: -- to go down towards where, I would 6 say, where the confrontation was taking place -- 7 Q: Hmm hmm. 8 A: And I said we couldn't go there right 9 then because, first of all we were told to stay put and 10 the patients would be brought to us if there was any -- 11 Q: Hmm hmm. 12 A: And also, there was an environmental 13 safety hazard for us to go into something like that, that 14 we weren't sure. 15 Q: Okay. 16 A: Hmm hmm. 17 Q: All right. And what did he -- what 18 did he -- how did he respond? 19 A: I don't remember how he responded. 20 Q: Okay. And what did you do? 21 A: It seemed like a short moment, if not 22 a minute, and he said that was okay, you weren't needed 23 and -- 24 Q: Hmm hmm. 25 A: -- well -- well, when he was there, I

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1 said well, we'll pull our ambulance a little closer to 2 Parkway -- 3 Q: Hmm hmm. 4 A: -- so we'd be ready to leave if a 5 patient does arrive. 6 Q: Hmm hmm. 7 A: And then he said, No, it's okay, 8 you're not needed. So we backed our vehicle back -- 9 Q: Okay, so -- 10 A: -- vis-a-vis -- 11 Q: So, prior to that, you did actually 12 move your vehicle? 13 A: Yes, just up a couple of hundred 14 feet. 15 Q: Okay. A couple of hundred feet...? 16 A: From where we were parked. 17 Q: Okay. And did you move actually onto 18 East Parkway Drive? 19 A: No. 20 Q: Okay. 21 A: No. 22 Q: So you were merely closer to the 23 entrance -- 24 A: Hmm hmm. 25 Q: -- to the MNR parking lot?

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1 A: Hmm hmm. 2 Q: Okay. Okay. And just to take you 3 back, prior to that man arriving in your unit or at any 4 time, did you hear anything that sounded to you like they 5 could have been gunshots? 6 A: Hmm hmm. 7 Q: Any sounds? 8 A: No. 9 Q: No. Did any of your colleagues 10 remark to you on hearing any sounds? 11 A: They did say they heard something. 12 Q: Okay. Do you recall roughly when 13 that would have been? 14 A: No. 15 Q: No. 16 A: Because it probably be a couple of 17 days later they said this. 18 Q: Okay. And who -- who is 'they'? 19 A: I think Ceasor mentioned it. 20 Q: Okay. Okay. So you mentioned you 21 returned your vehicle back to its initial positioning; is 22 that correct? 23 A: Yes. 24 Q: And what happened next? 25 A: Well, it wasn't very long and Ted

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1 Slomer -- 2 Q: Hmm hmm. 3 A: -- appeared and said that there was 4 two (2) casualties at the -- near the army camp -- 5 Q: Hmm hmm. 6 A: -- and for us to respond with two (2) 7 ambulances. 8 Q: Okay. And was he speaking to you 9 directly, or speaking to all of you? 10 A: I think he spoke to me. 11 Q: Okay. Were you in your vehicle at -- 12 A: Yes. 13 Q: -- the time? 14 A: Hmm hmm. 15 Q: All right. And, I'm sorry, you may 16 have answered this already but did he -- did he say that 17 the other unit, 1145, should also respond? 18 A: Yes, as there was two (2) -- 19 Q: Hmm hmm. 20 A: -- injured. 21 Q: Okay. And so what did you do next? 22 A: Well, then I responded right away and 23 we headed that direction. 24 Q: Okay. Did you notify your dispatch 25 at that time?

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1 A: Yes. 2 Q: Okay. And do you recall 3 approximately what time that would have been? 4 A: It was just a little after 11:00, say 5 about eleven (11) minutes after. 6 Q: About eleven (11) minutes after? 7 A: According to the dispatch that I have 8 in this book. 9 Q: Okay. Perhaps I should take you to 10 that document. It is at Tab -- that is at Tab 8, and 11 that's been identified as Exhibit P-345 in these 12 proceedings. It should be the first page in front of 13 you. 14 A: Hmm hmm. 15 Q: And it's Front Number 9544 in 16 Supertext. That dispatch report indicates that you and 17 Mr. Watt were notified at 23:11:28. 18 And, by your account, as you've indicated, 19 you received those instruction directly from the OPP 20 medic? 21 A: Yes. 22 Q: Rather than from your dispatcher? 23 A: That's right. 24 Q: So, the time here would actually 25 indicate what time, from your understanding anyway, that

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1 -- that you would have notified your dispatcher rather 2 than the other way around? 3 A: That could be, but I notified the 4 dispatcher. 5 Q: Okay. Okay. And do you recall what 6 route you took? 7 A: Yes. We took the same road that we 8 came in back to centre Ipperwash, or Ravenswood Road, and 9 up to 21 Highway and down to Army Camp -- 10 Q: Okay. 11 A: -- Road and 21 Highway. 12 Q: All right. And perhaps if we could - 13 - if Mr. Emery could put a map on -- on the screen here - 14 - I'll just change the input. Okay. 15 And we are going to be attempting on this 16 map, Mr. Tedball, to trace your movements from the time 17 that you went to the Forest ambulance base. So, just to 18 retrace for a moment, if you could indicate -- there's a 19 -- a laser pointer in front of you on the desk. 20 Hopefully you've got the one that -- with 21 the batteries that work. Is that -- are you able to 22 operate that -- that laser pointer? 23 A: Yeah. Hmm hmm. 24 Q: Oh, there you are. Okay. If you 25 could indicate on the map, you -- you can see at the

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1 bottom of the map, the Forest ambulance station is 2 identified in yellow print? Okay. 3 A: Can I move? 4 Q: Yeah. 5 6 (BRIEF PAUSE) 7 8 A: Yes, I see that. 9 Q: Okay. And you had previously 10 indicated, and it is recorded in the dispatch report, 11 that you had moved -- or that you had moved from the 12 Forest ambulance station to the MNR parking lot, which -- 13 if you could identify -- oh, it's already identified -- 14 at 21:41 and eleven (11) seconds, that's when you 15 departed the Forest ambulance station. 16 And you arrived in the MNR parking lot at 17 21:53:42; is that correct? If you want to have a look... 18 A: 21:53. 19 Q: Yes. 20 21 (BRIEF PAUSE) 22 23 Q: Okay. And the journey that you've 24 just described, leaving the MNR parking lot and going 25 towards the intersection of Highway 21 and Army Camp

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1 Road -- 2 A: From here to here. 3 Q: If Mr. Emery could trace that route. 4 MR. KEVIN EMERY: Do you want me to trace 5 it from Forest to the MNR parking lot? 6 MS. KATHERINE HENSEL: Yes. Yes, please. 7 Thank you. 8 9 (BRIEF PAUSE) 10 11 CONTINUED BY MS. KATHERINE HENSEL: 12 Q: Thank you. Actually, if you could 13 indicate which way you went from the Forest Ambulance 14 Station to the MNR parking lot? 15 A: This is 21 North, I take it? 16 Q: Yeah. 17 A: This is 21 North and then up to 18 Ipperwash -- centre Ipperwash Road to the MNR parking 19 lot. 20 Q: Yeah. Okay. And, Mr. Emery, I have 21 put the times on the record and Mr. Tedball has, so I can 22 -- okay. And, if you could also trace your route from 23 the MNR parking lot to the Army Camp once again? 24 A: Okay. If this is the MNR parking 25 lot, came down to Centre Ipperwash to 21 Highway, which

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1 is Ravenswood, up 21 Highway to -- right about to here -- 2 Q: Okay. 3 A: -- not quite to Army Camp Road. 4 Q: And, the dispatch report for that 5 call indicates that you arrived at 23:16? 6 A: That's right. 7 Q: All right. And, does that accord 8 with your recollection and understanding of how long it 9 would take to make that journey; that's roughly four-and- 10 a-half (4 1/2) minutes? 11 A: That's possible -- that's true. 12 Q: Yeah. Okay. You can have a seat 13 now, thanks. 14 Would you have travelled that route on a - 15 - on a Code 4 status? 16 A: Yes, I did. 17 Q: Okay. And, what speed approximately 18 would you normally travel for a Code 4? 19 A: The safe speed that it's -- it would 20 be different speeds. 21 Q: Hmm hmm. Okay. And, do you recall 22 how fast you were travelling when you left the MNR 23 parking lot towards Army Camp Road or -- 24 A: No. 25 Q: No. Okay. Would it be safe to say

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1 that you would likely exceed the speed limit on any road 2 that you were travelling on? 3 A: If it was possible, I would be. 4 Q: Okay. And, when you say, "possible" 5 and you mentioned earlier you travelled at a rate that 6 was safe? 7 A: Yes. 8 Q: Can you tell us a little bit more 9 about how you would determine how -- how fast that would 10 be? 11 A: Well, if the roads are dry and -- and 12 no rain, which I -- I don't think there was that night -- 13 Q: Hmm hmm. 14 A: -- and, also from one stopped area to 15 the next stopped area, you could increase your speed. 16 Q: Okay. All right. And, when you 17 arrived at -- at the intersection of the -- of Highway 21 18 and Army Camp Road -- I'm wondering if we could get a 19 blown-up image of that intersection? Thank you, Mr. 20 Emery. 21 Can you indicate where you would have 22 parked your vehicle? 23 A: I think it was roughly right about 24 here some place. 25 Q: Okay. All right. Could you keep

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1 your pointer there for -- for Mr. Emery's benefit? 2 A: It was right about here. 3 Q: Okay. Thank you. And, for the 4 record, he's indicating a point -- I'm not sure how the - 5 - how far that would be. It will be recorded in this -- 6 this exhibit, to the east of Army Camp Road on -- sorry, 7 to the west of Army Camp Road on Highway 21. Okay. 8 And for the record, the electronic version 9 of this map is -- has been identified in these 10 proceedings as Exhibit P-349(B). 11 Okay. And can you tell us what happened 12 once you parked your vehicle there? 13 A: We were told to get in the ditch -- 14 Q: Hmm hmm. 15 A: -- by the police. 16 Q: Okay. Just to take you back for a 17 moment, what did you see when you arrived? 18 A: A couple of police cruisers, possibly 19 -- I think there was three (3) police officers and, 20 again, they seemed to be dressed in a camouflage-type 21 outfit. 22 Q: Okay. And, where were those cruisers 23 parked? 24 A: Right where I was parked, like, on 25 that same side of the road, the south side.

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1 Q: All right. And, what were the 2 officers doing? 3 A: They had their -- I call them rifles 4 and long guns pointed toward the direction of this 5 vehicle that was parked on the opposite side of the road. 6 Q: Okay. Did you see any people -- any 7 non-police officers there? 8 A: I quickly observed a couple of ladies 9 standing behind a vehicle, a dark coloured vehicle. 10 Q: Okay. And where was the dark 11 coloured vehicle parked? 12 A: It was parked on that on-ramp -- 13 Q: Okay. 14 A: -- just near the end of it. 15 Q: Okay. Perhaps, if you could indicate 16 on Exhibit P-349(B) where that would have been. 17 A: Right about there. 18 Q: Can you -- yeah, keep it there for 19 Mr. Emery for a moment. There. Okay. You got it. 20 Okay. And you indicated that the women 21 you saw were standing behind, was that on the opposite 22 side of the vehicle from police, or were they closer to 23 police between -- 24 A: No, they -- they were close to that 25 car.

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1 Q: Okay. Were they standing on the 2 pavement? 3 A: I can't recall that. 4 Q: All right. And what were they doing? 5 A: Standing with their hands up. 6 Q: With their hands up, okay. All 7 right. So, once you parked your vehicle, you were 8 instructed -- do you recall who instructed you to get in 9 the ditch? 10 A: No, it would probably be one of those 11 three (3) police officers. 12 Q: Did you recognize any of the police 13 officers -- 14 A: No. 15 Q: -- that were there? 16 A: No. 17 Q: Okay. And what did you do? 18 A: Exactly that. We went into the 19 ditch -- 20 Q: Okay. 21 A: -- in behind our vehicle or to the 22 side of our vehicle. 23 Q: Okay. You said "we", was that you 24 and Mr. Watt? 25 A: Yes.

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1 Q: Okay. And had the other ambulance 2 unit, 1145, had it arrived when you arrived or -- 3 A: Yes. 4 Q: -- did it -- 5 A: They were there first. 6 Q: They were there first. Were they 7 already -- were the operators of that unit, Mr. DiCesare 8 and Mr. Gilpin, were they already in the ditch when you 9 arrived? 10 A: Yes, we just arrived right behind 11 each other. 12 Q: Okay. And so once you were in the 13 ditch, what did you observe? 14 A: Nothing. 15 Q: Nothing? 16 A: No, just the police were standing 17 there. Our vehicles were in front of us. 18 Q: Okay. 19 A: Hmm hmm. 20 Q: And could you hear anybody talking -- 21 A: No. 22 Q: -- at all? Could you hear anything - 23 - were the -- were the women saying or doing anything? 24 A: Not when we were in the ditch. You 25 couldn't hear or see them.

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1 Q: Okay. 2 A: Hmm hmm. 3 Q: But you could observe police officers 4 from the ditch? 5 A: Yes. 6 Q: All right. And they kept their -- 7 their rifles or long guns raised -- 8 A: Yes. 9 Q: -- as far as you could see? How long 10 would you say that you -- you remained in the ditch? 11 A: Oh, it wouldn't be any longer than 12 five (5) minutes. 13 Q: Okay. 14 A: Two (2) to five (5) minutes. 15 Q: Between two (2) and five (5) minutes? 16 A: Yes. 17 Q: Okay. 18 19 (BRIEF PAUSE) 20 21 Q: Okay. Okay. And were you instructed 22 by a police officer that it was safe to leave the ditch? 23 A: Yes, we were. 24 Q: Okay. 25 A: Yeah.

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1 Q: At any point up to then, were you 2 given any information about why you -- why you would have 3 been directed to the ditch? 4 A: No. 5 Q: No. 6 A: Hmm hmm. 7 Q: Okay. And why did you understand at 8 the time that you had been directed to the ditch? 9 A: Well, the scene probably wasn't 10 stable -- 11 Q: Hmm hmm. 12 A: -- safe -- 13 Q: Okay. 14 A: -- with police with their guns 15 pointing at something. 16 Q: Right. Okay. But, the police didn't 17 communicate to you at any point -- 18 A: Just told us to get in the ditch. 19 Q: Okay. Okay. Once -- once you were 20 advised that it was safe to proceed, what did you do? 21 A: Well, we unloaded our stretcher and 22 took our first response kit out -- 23 Q: Hmm hmm. 24 A: -- and -- 25 Q: When you say "we", do you mean --

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1 A: Mark and I -- 2 Q: Hmm hmm. 3 A: And -- 4 Q: Mr. Watt? 5 A: -- by that time, Cesare was there to 6 help. 7 Q: Hmm hmm. 8 A: And Cesare and Mark got to the 9 vehicle first, was talking to the patient and then they 10 required extra equipment, so I went back to the vehicle 11 to retrieve the extra equipment. 12 Q: Okay. Did you have any conversation 13 with the patient? 14 A: No. 15 Q: Did you have any conversation with 16 either of the two (2) of the women? 17 A: No. 18 Q: Okay. And -- all right. So, you 19 went back to -- to your unit to get, you indicated, a 20 stretcher and -- 21 A: We went back -- I went back to get a 22 back board and -- 23 Q: Hmm hmm. 24 A: -- some collars to immobilize the 25 patient.

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1 Q: Okay. And then what did you do? 2 A: Then we went back and at that point, 3 rather, I think Mac and Cesare were called away on 4 another -- another call. 5 Q: Okay. 6 A: And so Mark and I continued packaging 7 the patient, as putting a collar on, putting on a back 8 board and getting ready for transport. 9 Q: Okay. And we will come again to the 10 call that you mentioned that the other two (2) attendants 11 received. If I could take you first to Tab Number 1 in 12 your Brief of Documents; it's Inquiry Document Number 13 1000043, it's an Ambulance Call Report. 14 First of all, I should ask you, Mr. 15 Tedball, do you recognize this Ambulance Call Report? 16 A: Yes, I do. 17 Q: Okay. Did you, in fact, complete it? 18 A: No. 19 Q: Fill it out? 20 A: No, I didn't. 21 Q: Who was it filled out by? 22 A: Mark Watt. 23 Q: Okay. And I note that your -- your 24 name and signature appears at the bottom of the second 25 page.

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1 (BRIEF PAUSE) 2 3 Q: Is it the regular practice that the 4 attendant would fill out such a call report? 5 A: That's right. 6 Q: Okay. And you would be signing off, 7 merely, as the driver? 8 A: That's right. 9 Q: And not the author of the report? 10 A: No. 11 12 (BRIEF PAUSE) 13 14 Q: Okay. You mentioned that Mr. 15 DiCesare and Mr. Gilpin were called away at the point 16 that you had taken the backboard and collars over -- you 17 had joined the other attendants where the patient was, at 18 the car -- 19 A: I can't remember that -- 20 Q: -- is that correct? 21 A: -- exactly what time it was. 22 Q: Okay. You can't remember exactly 23 what time it was -- 24 A: But did -- did it happen just after I 25 took the backboard over, was I there a couple minutes or

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1 a minute or -- I -- I don't know. 2 Q: Okay. And, at any time, did you 3 perform any assessments on -- directly on the patient 4 there? 5 A: No. I just put a C-collar on the 6 patient's neck. 7 Q: All right. And -- and did you 8 understand at that time that Mr. Watt and Mr. DiCesare 9 had already performed an assessment on him? 10 A: I could see that there was some 11 dressings on the patient. 12 Q: Okay. Where were those dressings? 13 A: To the lower right back area. 14 Q: Okay. And at some point did you come 15 to move the patient onto the backboard? 16 A: Yes. 17 Q: All right. Did you do that with the 18 assistance of Mr. DiCesare and Mr. Gilpin? 19 A: No. 20 Q: No. And they had left by then? 21 A: They had left by then. 22 Q: All right. 23 A: Hmm hmm. 24 25 (BRIEF PAUSE)

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1 Q: At any point, did you have any kind 2 of conversation with the patient? 3 A: No. 4 Q: No. Okay. 5 6 (BRIEF PAUSE) 7 8 Q: All right. And did you hear any of 9 the other attendants, Mr. Watt or Mr. DiCesare, 10 discussing with the patient how he may have come by his 11 injuries? 12 A: No, I didn't. 13 Q: Okay. Did you hear any conversations 14 with any of the people present with any -- with the two 15 (2) ladies that were present on the road? 16 A: I remember the police saying 17 something, Don't move, Keep you hands up. 18 Q: Okay. And was that while you were 19 with the patient? 20 A: Yes. 21 Q: All right. And were they making -- 22 did you perceive them to be making attempts to -- to come 23 closer to the patient or -- 24 A: No. 25 Q: -- join the patient?

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1 A: No, I never perceived that. I don't 2 -- I didn't notice anything like that. 3 Q: All right. So once the patient was 4 on the stretcher, what did you do? 5 A: Once the patient's on the stretcher, 6 we placed him in the back of the ambulance. 7 Q: All right. And Mr. Watt has 8 testified this morning that he was joined in the 9 ambulance with -- or by an OPP officer; do you recall 10 that? 11 A: Yes. 12 Q: Okay. And do you recall that 13 officer's name? 14 A: Boon. 15 Q: Boon? 16 A: Boon. 17 Q: Okay. And do you recall if you were 18 instructed by the OPP that he would be joining you or 19 whether you requested his presence? 20 A: If I remember right, I asked if there 21 would be any police officer going with us in the 22 ambulance. 23 Q: Okay. And why did you ask? 24 A: Well, under the situation that we 25 were in right then --

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1 Q: Hmm hmm. 2 A: -- it was for unknown reasons why 3 this -- what was happening, so it's better to have 4 somebody with you for -- 5 Q: Okay. 6 A: -- to go -- to go to the hospital 7 with. 8 Q: Okay. And were you under the 9 impression at this time that the patient was suffering 10 from a gunshot wound or wounds? 11 A: Yes. 12 Q: Okay. 13 14 (BRIEF PAUSE) 15 16 Q: All right. If I could take you back 17 to Tab 8 of the book of documents in front of you, it's - 18 - a portion of what has been -- identified as Exhibit P- 19 345, if I could take you Front 9544? 20 A: Yes. 21 Q: There, the dispatch report indicates 22 that you departed at 23:39:14. 23 A: That's right. 24 Q: Okay. And that would have you at the 25 scene for approximately twenty-three (23) minutes. Does

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1 that -- 2 A: That's right. 3 Q: Does that accord with your 4 recollection of events? 5 A: Yes. 6 Q: All right. Do you recall, roughly, 7 how long prior to your departure Mr. DiCesare and Mr. 8 Gilpin would have left? 9 A: I don't know. 10 Q: You don't know? 11 A: Don't know. 12 Q: Okay. 13 A: It was just -- it wasn't -- like, it 14 wasn't part of my call. 15 Q: Okay. 16 A: You hear it, but you don't pay 17 attention. 18 Q: All right. And did you witness at 19 any time, Officer Boon having any kind of conversation 20 with the patient, either while you were getting into the 21 -- loading him into the ambulance or -- or at any point? 22 A: No, I didn't. 23 Q: No? Okay. So, once you were en 24 route, you would have notified your dispatch that you 25 were en route?

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1 A: That's right. 2 Q: Okay. And would you have done that 3 immediately on your departure from the scene there? 4 A: Yes. 5 Q: And would you have informed the 6 dispatcher that you had a police escort in the ambulance? 7 A: That's right. 8 Q: Okay. All right, if we could get the 9 map again up, Mr. Emery? Okay. 10 Now, Mr. Tedball, if you could describe 11 for us, if you will, the route that you would have taken 12 from the corner of Army Camp Road and Highway 21? 13 First of all, where were -- where were you 14 going when you departed, which direction? 15 What was your destination? 16 A: Going to Strathroy. 17 Q: Okay. And, how did you decide that 18 Strathroy would be the appropriate destination? 19 A: Just -- in that area, we just 20 automatically presumed that that's the best hospital to 21 go to. 22 Q: Do you recall having any 23 conversations with OPP Medic Slomer or anyone else about 24 which hospital was closest? 25 A: I don't recall that.

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1 Q: All right. And if you could grab the 2 pointer and you may want to get up again. And, if you 3 could trace for us, if you would, you indicated that you 4 departed at 11:39 and -- 5 A: Right here? Right here, is this the 6 Army Camp Road and 21 Highway? 7 Q: Yes. Okay. 8 A: Is that it? 9 Q: Yes. 10 A: So, we came back to Ravenswood, came 11 down -- I think we're further north because we came in 12 through Thedford this way here. 13 Q: Hmm hmm. 14 A: And in through Arkona and into 15 Strathroy. 16 Q: If -- if you could slow down a little 17 bit for -- 18 A: So the -- the north part isn't 19 showing. 20 Q: All right. 21 A: I think I'm missing something there. 22 Q: All right. 23 MR. KEVIN EMERY: Give me just a 24 second... 25 MS. KATHERINE HENSEL: Okay, thank you.

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1 MR. KEVIN EMERY: Come down Ravenswood 2 Road... 3 MS. KATHERINE HENSEL: Okay. For the 4 record, Mr. Emery is indicating -- 5 THE WITNESS: That's Ravenswood right 6 there? 7 MR. KEVIN EMERY: There's Ravenswood. 8 THE WITNESS: Okay. There's where we 9 were, then, sorry, and we came down here. 10 11 CONTINUED BY MS KATHERINE HENSEL: 12 Q: Yeah. And where is, "here?" 13 A: Here is Ravenswood. 14 Q: Yeah? 15 A: And, down Ravenswood Road into 16 Thedford, through Thedford -- 17 Q: Hmm hmm. 18 A: -- onto -- this would be 79 Highway 19 at that time into Arkona. 20 Q: Hmm hmm. 21 A: Then through to Townshead Line onto 22 81 Highway and right into Strathroy Hospital. 23 Q: Okay. Thank you, Mr. Tedball. And 24 for the record your -- the dispatch report in Exhibit P- 25 30 -- 345, indicates that you arrived at your destination

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1 at six (6) minutes after midnight? 2 A: Yes. 3 Q: does that accord with -- with your 4 recollection? 5 A: Yes. 6 Q: That would have been a trip of 7 approximately twenty-seven (27) minutes? 8 A: Yes. 9 Q: And by your understanding today, and 10 your recollection, is that roughly how long it should 11 take, travelling -- first of all, were you travelling on 12 a Code 4? 13 A: Yes, I was. 14 Q: Okay. And would a Code 4 be standard 15 practice for any -- why were you travelling -- continuing 16 to travel on a Code 4, perhaps I should let you -- 17 A: Because the unknown extent of the 18 injury. 19 Q: Okay. What were your concerns in 20 terms of the urgency that you ascribe to it? 21 A: Just that it was a possible gunshot. 22 Q: Okay. Did you have any concerns 23 about the proximity or would it be standard to travel 24 with any gunshot injury victim by Code 4 or would the 25 location of the -- the injury play any role in that

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1 assessment, on the patient's body? 2 A: That's a hard call. You'd have to 3 assess each one individually. 4 Q: Okay. 5 A: But I would think because of the 6 location of this possible gunshot wound, that was the 7 reason why. 8 Q: All right. So, there was really no 9 question for you that you would be travelling at a code 10 4? 11 A: Oh, no, no. 12 Q: Okay. So, just to return to my 13 previous question, travelling at a Code 4 at that time of 14 night on dry roads -- were all of the roads that you'd 15 indicated, were they all paved? 16 A: Yes. 17 Q: Okay. So, travelling on dry, paved 18 roads after dark at that time of night, would twenty- 19 seven (27) minutes be an appropriate amount of time to -- 20 to spend on that journey? 21 A: That was -- that was good time, hmm 22 hmm. 23 Q: Yeah, okay. Hmm hmm. Can you recall 24 how quickly you would have been travelling? 25 A: I don't recall that, but --

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1 Q: Okay. 2 A: -- it -- it would be fast. Like, I - 3 - I would -- you know -- 4 Q: Hmm hmm. 5 A: -- hesitate to say, there could be 6 seventy (70) mile an hours speeds. 7 Q: Okay. And did you have any 8 conversations with -- directly with the hospital while 9 you were enroute? 10 A: No. 11 Q: Hmm hmm. 12 13 (BRIEF PAUSE) 14 15 Q: Okay. Did you have any further 16 conversations with your dispatcher while you were 17 enroute? 18 A: Yes. 19 Q: And what were the nature of those 20 conversations? 21 A: We had to switch over -- 22 Q: Hmm hmm. 23 A: -- to London dispatch and I would 24 tell Wallaceburg dispatch I was switching to London 25 dispatch.

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1 Q: Okay. And on the way to the 2 hospital, can you recall hearing that the unit driven -- 3 that Unit 1145's call had been cancelled? 4 A: Yes. 5 Q: Do you recall where you were when you 6 heard that? 7 A: No. 8 Q: No. Okay. And do you recall hearing 9 why it would have been cancelled -- why that call was 10 cancelled? 11 A: I -- I don't know if I remember. 12 Probably because the patient had left the -- the area. 13 Q: Okay. But, you -- you can't remember 14 precisely? 15 A: No. 16 Q: Okay. On your arrival at the 17 hospital, what did you observe in the parking lot to the 18 hospital, first of all? 19 A: There was some police standing 20 around. 21 Q: Hmm hmm, okay. Actually, I should go 22 back and ask you whether you observed or passed through 23 any police checkpoints enroute to that hospital, at any 24 point in your journey? 25 A: There might have been one at

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1 Ravenswood. 2 Q: At Raven's Wood, and... 3 A: 21 and Ravenswood Road. 4 Q: Okay. And -- 5 A: Or -- 6 Q: -- did you stop at that checkpoint at 7 the time? 8 A: No. 9 Q: Okay. Do you recall any other 10 checkpoints? 11 A: No. 12 Q: Okay. All right. So, in the parking 13 lot, again, I'm sorry to interrupt, what did you see 14 there? 15 A: Just police. 16 Q: Police. 17 A: There was -- there was some police. 18 I don't know how many, I can't recall that. 19 Q: Okay. Did you see police cruisers? 20 A: I don't recall that. 21 Q: All right. And what did you do once 22 you arrived in the parking lot there? 23 A: We unloaded our patient into the 24 emergency department. 25 Q: Okay. Did you accompany him all the

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1 way into the Emergency department? 2 A: Yes. 3 Q: Okay. And what did you do next? 4 A: Well, we were directed to an 5 observation room with the patient. 6 Q: Hmm hmm. And what happened next? 7 A: Then the -- we transported the 8 patient up onto the hospital bed and then left. 9 Q: All right. Roughly how long would 10 have you have spent inside the hospital? 11 A: According to this it was about 12 twenty-three (23) minutes. 13 Q: If we could go back to Tab 8, then. 14 A: Twenty-four (24) minutes. 15 Q: Twenty-four (24) minutes. That is 16 Exhibit P-345, Document Number 1002002, Front 9544 17 indicates... 18 19 (BRIEF PAUSE) 20 21 Q: Indicates that you -- it says: 22 "Clear destination thirty (30) minutes 23 after midnight -- thirty (30) minutes 24 and twelve (12) seconds." 25 A: That's right.

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1 Q: Does that accord with your 2 recollection of the events of that evening, that you 3 would have spent that long in the hospital? 4 A: Yes. 5 Q: Okay. And -- and was that the last 6 that you saw of that particular patient? 7 A: Yes. 8 Q: Okay. And during your time with the 9 patient, who has been identified by Mr. Watt and others 10 as Nicholus Cotrelle, can you describe his demeanour? 11 A: The way he was acting? 12 Q: Yeah. 13 A: A young gentleman. 14 Q: Hmm hmm. 15 A: He was -- for what he had gone 16 through, he was a -- he was a young gentleman. He 17 answered all our questions. 18 Q: Hmm hmm. Okay. And did he appear 19 afraid to you? 20 A: Not of us. 21 Q: Not of us, okay. And did he 22 cooperate with all of your -- any requests that were made 23 of him? 24 A: Yes. 25 Q: Okay. Did you have any other contact

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1 with any other patients in the hospital that evening? 2 A: No. 3 Q: Okay. Did you observe a white car at 4 any point in the hospital parking lot? 5 A: Yes. 6 Q: Okay. And when did you first observe 7 that car? 8 A: When we were leaving the hospital. 9 Q: Okay. Toward -- walking from the 10 hospital to your unit? 11 A: Yes. 12 Q: Okay. And did you observe any 13 activity or people around that car? 14 A: There was some people standing there 15 with their hands on the wall, by the car. 16 Q: Okay. Can you -- how many people 17 were standing? 18 A: I thought there was two (2). 19 Q: Okay. 20 A: From what I can remember. 21 Q: Okay. And can you -- could you make 22 out their -- their gender or their appearances or -- 23 A: No, I can't remember that. 24 Q: Okay. Did you observe a younger 25 person in the -- in proximity around that vehicle at any

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1 time? 2 A: No. 3 Q: Okay. And did you approach that 4 vehicle yourself? 5 A: No. 6 Q: Okay. And did you see, at any point, 7 a patient being -- or an injured person being taken from 8 that vehicle? 9 A: No. 10 Q: Okay. 11 12 (BRIEF PAUSE) 13 14 Q: Okay. And what did you do on leaving 15 the hospital? 16 A: Just left. Headed out to, as advised 17 by Wallaceburg dispatch, to go back to Ravenswood for 18 standby, Code 8. 19 Q: Okay. All right. And did you have 20 to perform any service or maintenance on your vehicle, 21 clean up the back or anything, because you had been 22 transporting a patient? 23 A: Yes. 24 Q: All right. And where did you perform 25 that?

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1 A: Oh, it had been done at the hospital. 2 Q: In the hospital -- 3 A: Hmm hmm. 4 Q: -- parking lot. 5 A: Hmm hmm. 6 Q: Okay. And while you were at the 7 hospital did you fill out any forms or do any -- make any 8 reports? 9 A: No. 10 Q: No. Okay. All right. And you will 11 have in front of you an Ambulance Incident Report, 12 actually a set of Ambulance Incident Reports which have 13 been referred to earlier today by Mr. Watt and my 14 colleague Mr. Worme. They've been identified for the 15 record as Exhibit P-352. 16 You'll note that the first two (2) pages 17 of that set of documents -- well, first of all, do you 18 recognize that document? 19 A: Yes. 20 Q: Okay. Was it completed by you? 21 A: Yes, it is. 22 Q: Okay. You'll note that your 23 signature appears -- or I should ask, is that your 24 signature at the bottom of the second page? 25 A: Yes, it is.

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1 Q: Okay. When would you have completed 2 this report? 3 A: It's says "95-09-07" on this form, so 4 it would be the 7th of September. 5 Q: Okay. I'm sorry, I'm just not seeing 6 -- I -- what I see is "Date 10-09-95" beside Mr. Gilpin's 7 name at the bottom there. 8 A: Well, on the first page, at the top - 9 - 10 Q: Yeah. 11 A: -- second row -- 12 Q: Hmm hmm. 13 A: -- on the left-hand side -- 14 Q: Okay. 15 A: -- "Report date, Year, Month, Day." 16 Q: Okay. And you -- can you recall what 17 time of day you would have completed that report? 18 A: No. 19 Q: Would it have been while you were 20 still on shift? 21 A: Yes. 22 Q: Okay. And so what time did you go 23 off shift approximately? 24 A: But I was back on that day too, so it 25 could have been done sometime that day.

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1 Q: All right. But, you don't have, 2 presently, any recollection of filling out this report? 3 A: No, it was done on that date. 4 Q: Okay. All right. All right. And, 5 so you returned to Ravenswood and Highway 21, I think you 6 -- you said -- 7 A: That's right. 8 Q: -- for -- to -- for -- for Code 8 9 standby? 10 A: Yes. 11 Q: Okay. And, just for thoroughness' 12 sake, if we could return to the map that would place you 13 there. 14 15 (BRIEF PAUSE) 16 17 Q: Okay. And I don't know if you can 18 make out on that map -- if we could return to the larger 19 map showing Strathroy as well, sorry. 20 21 (BRIEF PAUSE) 22 23 Q: Okay. Do you recall the route that 24 you would have taken to return to that lobation? 25 A: I don't -- don't recall, but I'm sure

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1 it's probably the same way as I came in to the hospital. 2 Q: Seems reasonable. And, do you recall 3 how long you would have remained on -- on standby there? 4 A: It was quite a while. 5 Q: Hmm hmm. Okay. Quite a while -- 6 A: It would be -- it could be up til 7 five o'clock in the morning, if I recall right. 8 Q: Okay. And, did you perform any other 9 medical services or ambulance services that night? 10 A: Yes, we did. 11 Q: Okay. And, can you describe those 12 for us? 13 A: I was -- I guess, from what I 14 understand, there was people being evacuated from that 15 area and we had to transport an elderly gentleman from 16 his home -- 17 Q: Hmm hmm. 18 A: -- because he was -- I guess he's 19 been confined to the home for quite a while, we had to 20 take him to the hospital. 21 Q: Okay. Do you recall where his home 22 was, approximately? 23 A: I think it was Richardson (phonetic) 24 Drive, which is in that area. 25 Q: Okay. And, where was he transported?

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1 A: To Sarnia General Hospital. 2 Q: All right. And, at that point, were 3 you still with Mr. Watt as you partner? 4 A: No, some time during the evening or 5 the morning -- early morning there, Mark switched with 6 Mac Gilpin. 7 Q: Okay. And, why did he do that? 8 A: Because Mac was coming back on duty 9 that morning and if I recall I -- I was going back on 10 duty, too, so we might as well get together and be ready 11 to do whatever. 12 Q: Okay. So, at the time you 13 transported the elderly gentleman, you were travelling 14 with Mr. Gilpin? 15 A: Yes. 16 Q: Okay. And, was any explanation 17 provided to you as to the reason for the evacuation? 18 A: No. No. 19 Q: But, this person's medical condition 20 was such that he required an ambulance to be transported 21 if he was to be transported? 22 A: Yes. 23 Q: Okay. And, at any point -- you've -- 24 you've described that you were stopped much earlier in 25 the evening at a checkpoint at the -- at the -- at the

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1 corner -- at the corner of, I believe, East Parkway Drive 2 and -- and Ravenswood, is that -- prior to your arrival 3 at the MNR parking lot? 4 A: I think the only time we were stopped 5 is right at the MNR parking lot. 6 Q: Okay. And, that's -- 7 A: Or at that intersection there. 8 Q: -- and that's the only time all 9 evening during that entire night that you were ever 10 impeded by police? 11 A: That's right. Except for hiding in 12 the ditch there for a few minutes. 13 Q: That's right. Okay. And, just one 14 (1) final question, Mr. Tedball, is there -- given the 15 events as they unfolded that evening, do you have any 16 concerns about how they unfolded or would you have liked 17 to have seen anything happen differently? 18 A: Well, I think one (1) thing would -- 19 well, the only thing that really of interest to me alone 20 is that the ambulances shouldn't be called into a 21 situation until it's a lot clearer and a lot safer for 22 them to be there. 23 Q: Okay. And, by that you mean -- 24 A: Like, present day is -- similar to 25 what I'm suggesting is a lot of times when there's an

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1 incident happening we stay back quite a ways; we're not 2 right with the police until the scene is clear and then 3 they'll call us in. 4 Q: Okay. All right. Thank you, Mr. 5 Tedball. I have no further questions for you. 6 A: Thank you. 7 Q: But some of My Friends here will have 8 some, so... 9 COMMISSIONER SIDNEY LINDEN: Thank you 10 very much, Ms. Hensel. 11 Anybody wish to examine Mr. Tedball? 12 Ms. Esmonde...? 13 MS. JACKIE ESMONDE: Approximately a half 14 an hour. 15 COMMISSIONER SIDNEY LINDEN: Mr. 16 Scullion...? 17 MR. KEVIN SCULLION: Maybe ten (10) to 18 fifteen (15) minutes. 19 COMMISSIONER SIDNEY LINDEN: Ms. Tuck- 20 Jackson...? 21 MS. ANDREA TUCK-JACKSON: Five (5) 22 minutes. 23 COMMISSIONER SIDNEY LINDEN: Ms. 24 Jones...? About the same, okay. 25 Ms. Esmonde...?

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1 (BRIEF PAUSE) 2 3 CROSS-EXAMINATION BY MS. JACKIE ESMONDE: 4 Q: Good afternoon. 5 A: Hi. 6 Q: My name is Jackie Esmonde. I'm going 7 to be asking you some questions on behalf of the 8 Aazhoodena and George Family Group. 9 A: Yes. 10 Q: Now, I take it from the evidence 11 you've given that you had very little information about 12 what the OPP was planning to do that evening? 13 A: That's right. 14 Q: Before you went to the MNR parking 15 lot, all you knew was that possibly something could 16 happen in the Ipperwash area? 17 A: Yes. 18 Q: And that the police wanted you there? 19 A: Yes. 20 Q: And that you were then sent to the 21 MNR parking lot and -- 22 A: Yes. 23 Q: -- and I understand you were given 24 directions about how you should get there? 25 A: No.

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1 Q: I see. Were you told that you 2 shouldn't take Army Camp Road to get there? 3 A: No. 4 Q: Okay. 5 6 (BRIEF PAUSE) 7 8 Q: Now, you arrived at the parking lot 9 and you had a conversation with Sergeant Lacroix? 10 A: Yes. 11 Q: Do you know how long that 12 conversation was? 13 A: It wasn't very long. 14 Q: Not very long. And can you recall 15 today what, as best you can, the words that he used in 16 telling you what was going to take place? 17 A: Well, as I said before, he was 18 concerned about our safety -- 19 Q: Right. 20 A: -- the way we were dressed; pretty 21 well the way I'm dressed right now. And also that they 22 were concerned about firebombs. 23 Q: Right. His main concern in terms of 24 injuries was the possibility of firebombs? 25 A: Yes.

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1 Q: And what did you understand that to 2 mean? 3 A: Somebody throw fire at them. 4 Q: Okay. Now, I believe you said 5 earlier you were asked what did Sergeant Lacroix tell you 6 they were going to do, and you had indicated he didn't 7 say anything to you about what the OPP was going to do? 8 A: No. 9 Q: Do -- do you know if he told one of 10 your colleagues? 11 A: I'm not sure of that. 12 Q: I take it though you understood that 13 there was going to be some kind of OPP operation? 14 A: Yes. Hmm hmm. 15 Q: And that they were going to march 16 towards Ipperwash Park? 17 A: No. 18 Q: You didn't even have that much 19 information? 20 A: Unless -- until they left. 21 Q: Okay. And when they left did you 22 understand that they were going towards -- 23 A: No. 24 Q: -- Ipperwash Park? 25 A: Just from what I surmised.

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1 Q: You surmised that? 2 A: Yes. 3 Q: Based on what you knew from the 4 media, for example? 5 A: No. Just, as it was, it was dark but 6 it was in that far corner of the Park. 7 Q: Okay. And I take it you don't recall 8 ever receiving an explanation as to why the OPP was 9 carrying out this operation in the dark of night? 10 A: No. 11 Q: Now, you told us about a conversation 12 you had with Ted Slomer? 13 A: Yes. 14 Q: And did you know him? Had you met 15 him previously? 16 A: If I did, it was quite a while ago. 17 As a matter of fact, I've been kind of thinking about him 18 lately and -- and I -- I probably did know of him and 19 know -- no, but not personally. 20 Q: Okay. You understood him to be a 21 trained paramedic? 22 A: Yes. 23 Q: Did you understand that to be a Level 24 2 paramedic? 25 A: No.

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1 Q: Okay. You understood him to have 2 more training than you, I assume, in -- in the sense that 3 he could do an intubation? 4 A: Yes. 5 Q: And do you recall a conversation with 6 him about, I believe, they're called Mass-Trousers? 7 A: No. 8 Q: No. Now, you saw a St. John 9 Ambulance vehicle -- 10 A: Yes. 11 Q: -- at the MNR parking lot as well? 12 A: Yes. 13 Q: And they arrived after you? 14 A: Yes. 15 Q: And were they -- you met the two (2) 16 attendants who were staffing that vehicle? 17 A: Yes. 18 Q: A Glen Morgan and a Karen Bakker? 19 A: I'm not sure of their names. 20 Q: Okay. 21 A: But that's -- if you say that's what 22 their names are, okay. 23 Q: Okay. And do you know if they were 24 present with you when you were having these conversations 25 with Ted Slomer and Sergeant Lacroix?

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1 A: I don't recall that. 2 Q: You don't recall that. 3 A: No. 4 Q: Now, you understand of course that 5 St. John Ambulance is a volunteer-run organization? 6 A: From what I've been hearing, yes. 7 Hmm hmm. 8 Q: But, did you know that at that time? 9 A: Yes, I guess I did. I -- 10 Q: Yeah. 11 A: -- hmm hmm. 12 Q: And that they could provide basic 13 first aid? 14 A: Yes. 15 Q: But, they weren't trained paramedics? 16 A: No, that's right. 17 Q: And that was something you would know 18 as a -- being a paramedic yourself? 19 A: Yes. 20 Q: And were you present when the two (2) 21 St. John Ambulance attendants spoke with Ted Slomer and 22 told him of the limitations on their first aid abilities? 23 A: No. 24 Q: But I take it you would have expected 25 Ted Slomer to understand the limitations of a St. John

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1 Ambulance attendant? 2 A: Yes. 3 4 (BRIEF PAUSE) 5 6 Q: And did you have any understanding 7 about what -- why they were there and what their role was 8 to be? 9 A: No. 10 Q: Were you ever told by an OPP officer 11 that your position was confidential and that you were not 12 to speak on the radio frequencies about where you were or 13 what you were doing? 14 A: No. 15 16 (BRIEF PAUSE) 17 18 Q: Okay. Now, you told us that a -- an 19 OPP officer who had a face -- his face was painted and he 20 was wearing camouflage and he carried a long gun, he came 21 up to speak with you -- 22 A: Hmm hmm. 23 Q: -- and this was around eleven 24 o'clock? 25 A: Yes.

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1 Q: Can you tell me anything else about 2 his appearance? 3 A: Well, he was camouflaged. 4 Q: Okay. You -- 5 A: Like the green face and green 6 outfits. 7 Q: Okay. And he was -- he was white? 8 A: I don't know. 9 Q: A white man? You couldn't even 10 tell -- 11 A: I couldn't tell you that, no. 12 Q: Could you tell how tall he was? 13 A: No. 14 Q: Could you tell if he had a moustache 15 or a -- 16 A: No. 17 Q: -- beard? No. 18 Okay. I guess that camouflage really 19 works, then? 20 21 (BRIEF PAUSE) 22 23 Q: So, he told you that somebody had 24 been hurt and he wanted you to take your ambulance down 25 the road?

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1 A: From what I understand, he said you 2 have to -- you should go down the road this way, and I'm 3 not -- I can't remember if he said there was somebody 4 hurt or not. 5 Q: Oh, I see -- 6 A: Yeah. 7 Q: -- okay, so -- 8 A: Hmm hmm. 9 Q: -- you didn't know why he wanted you 10 to go down the road? 11 A: Well, I presumed -- 12 Q: You presumed somebody had been 13 injured? 14 A: Yes, or somebody had been injured or 15 something. 16 Q: Did you form any impression as to 17 whether it was a First Nations person injured or a police 18 officer? 19 A: No. No. 20 Q: And are you aware of the basis of any 21 knowledge he may have had about what had happened down 22 there? Did -- 23 A: No. 24 Q: -- he say -- 25 A: No, no.

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1 Q: -- they'd have reports of any person 2 injured? 3 A: No. 4 5 (BRIEF PAUSE) 6 7 Q: Now, we heard this morning from your 8 colleague, Mr. Watt -- 9 A: Hmm hmm. 10 Q: -- he had described an OPP -- OPP 11 officer with a gun in the back of the ambulance and is it 12 this person -- 13 A: That's right, yeah. 14 Q: -- this person you're speaking of? 15 A: Yeah. 16 Q: Okay. And I take it from what we 17 heard from Mr. Watt this morning, it was his 18 understanding this officer remained in the back of the 19 vehicle so as to possibly provide an escort down the 20 road. 21 A: That's possible. 22 Q: That was your understanding as well? 23 A: I -- I can't remember that, but it's 24 -- it's possible that he stayed there. 25 Q: Okay. And then at some point very

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1 soon afterwards, you've told us he communicated something 2 to you that you were no longer needed -- 3 A: Hmm hmm. 4 Q: -- and do you recall him saying, The 5 scene is okay, and you weren't needed? 6 A: To that effect, yes. 7 Q: To that -- okay. And when -- when -- 8 you understood, then -- well, what did you understand 9 from that remark that, The scene is okay and you weren't 10 needed? 11 A: Exactly what it says. 12 Q: Okay. 13 A: We weren't needed, we weren't needed. 14 Q: But did you understand from that, 15 that they -- he didn't believe there was anyone injured? 16 A: Oh, I don't know, I -- 17 Q: You just didn't know anything -- 18 A: -- never -- 19 Q: -- from -- 20 A: No. 21 22 (BRIEF PAUSE) 23 24 Q: And then it was after that that Ted 25 Slomer --

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1 A: Shortly after. 2 Q: Shortly after that, asked you to 3 proceed to Army Camp Road and Highway 21 and he had told 4 you that there were two (2) seriously injured parties 5 there? 6 A: Yes. 7 Q: And did he tell you how he had 8 learned that information? 9 A: No. 10 Q: Now, we've heard a lot about Code 4 11 over the past week. Now, code 4 is when there's a very 12 urgent medical need? 13 A: Yes. 14 Q: And you use your lights and sirens? 15 A: That's right. 16 Q: And you do that so that you can 17 travel more quickly? 18 A: And be seen. 19 Q: And be seen. 20 A: Hmm hmm. 21 Q: And you're more confident in moving 22 at a -- at a -- over the speed limit, because people can 23 see you coming and they can get out of the way? 24 A: That's right. 25 Q: So when your lights and sirens are

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1 off, then you can't travel as quickly? 2 A: Well, it all depends. Yes, you can. 3 Q: I see. 4 A: You can, yes. 5 Q: But you would be a bit more careful, 6 I assume? 7 A: Oh, yes. 8 Q: Now, I understand from Mr. Watt that 9 when you were travelling at Code 4 to the -- the 10 intersection of Highway 21 and Army Camp Road that your 11 lights and sirens were off? 12 A: I don't recall that. 13 Q: Do you recall -- 14 A: I don't recall if they were on or 15 off. 16 Q: Okay. That -- 17 A: Yeah. 18 19 (BRIEF PAUSE) 20 21 Q: I believe -- do you have the 22 ambulance incident reports in front of you? 23 A: Yes. 24 Q: Okay. If you could turn to page 3 of 25 Mr. Watt's report, which I think, is the last one. There

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1 should be a three (3) in the top right-hand corner? 2 A: Yes. 3 Q: I'm just going to -- I'm going to 4 read -- you didn't author this report, but may help to 5 refresh your memory. 6 A: Hmm hmm. 7 Q: Just the last sentence at the end of 8 the page there. It says: 9 "Both vehicles respond Code 4 at 23:11 10 hours. At first, no light or sirens 11 due to decreasing attention 12 (surrounding bystanders and residents 13 near by)." 14 A: Yes, I read that. 15 Q: Does that assist you? 16 A: No, I -- I don't -- I don't remember 17 if the lights were activated or not on the ambulance. 18 Q: Okay. Do you -- do you recall being 19 asked by the OPP to not use your lights or sirens when 20 you were travelling to that location? 21 A: No, the only time that we were asked 22 about lights were when we were sitting idling in the 23 parking lot. 24 Q: Okay, and that's when you were told 25 to turn your lights off?

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1 A: Hmm hmm. Hmm hmm. 2 Q: Okay. Now, before you left the MNR 3 parking lot in your discussions with Ted Slomer, did he 4 indicate to you that he had an injured person in the 5 parking lot -- 6 A: No. 7 Q: That needed transport to hospital? 8 A: No. 9 Q: Did you see any such person? 10 A: No. 11 Q: And at any point -- do you know a 12 Sergeant Cousineau? 13 A: No. 14 Q: Okay. At any point that evening, 15 were you approached by an OPP officer and asked about 16 responding to a 911 call from 9780 Army Camp Road? 17 A: No. 18 Q: So, I'd like to move on, then, to 19 when you arrive at the intersection of Army Camp Road and 20 Highway 21. 21 I take it it caused you some anxiety from 22 what you've told us when you arrived there and you saw 23 police officers with their guns aimed at people by a car? 24 A: Yes. 25 Q: And you were already anxious, I -- I

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1 take it from what you had been told by Sergeant Lacroix 2 at the MNR parking lot about the possibility of fire 3 bombs? 4 A: Yes. 5 Q: And you had a concern that the Native 6 protesters could be violent? 7 A: No. 8 Q: No? 9 A: No, we never had any concerns. 10 Q: Okay, what was your -- what was the 11 cause of your anxiety, then? 12 A: Oh, just the situation around us 13 at... 14 Q: Okay. 15 A: And then, also out at the -- as 16 you're saying, at 21 and Army Camp Road -- 17 Q: Right. 18 A: -- with the guns pulled. 19 Q: That caused you anxiety to see those 20 guns pulled and you thought the scene was not safe? 21 A: Well, we were a little concern; we 22 were a little concerned. 23 Q: Okay. 24 25 (BRIEF PAUSE)

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1 Q: Now, you've told us that you couldn't 2 really hear any conversation that was going on while you 3 were in the ditch? 4 A: That's right. 5 Q: At any point, though, while you were 6 at that intersection, did you hear shouting back and 7 forth between the two (2) women there and the police 8 officers? 9 A: Yes. 10 Q: Okay. And, can you tell us what you 11 heard? 12 A: Well, I didn't really hear anything 13 in general, expect the odd time, you know, like when 14 somebody uses the "F" word, it kind of pops in your head 15 and then, you know, like, you hear it and that's it. 16 Q: Okay. So, you heard the "F" word? 17 A: Yes. 18 Q: And that was coming from -- 19 A: From the ladies. 20 Q: Okay. 21 A: I presumed it was. 22 Q: You presumed it was? 23 A: I -- I can't say it was, for sure, 24 but, you know... 25 Q: But you heard shouting from both

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1 sides. 2 A: From the police it was -- all I can 3 remember about the police is, Keep you hands up; don't 4 move. 5 Q: Right. Did you hear the police 6 officers use words to the effect of, You bitches put your 7 arms in the air? 8 A: No. 9 Q: Now, do you know -- did you recognize 10 one (1) of the women there? 11 A: No. 12 Q: Okay. Do you -- have you ever met a 13 woman named Gina George in the your -- in the course of 14 your -- 15 A: I -- I have met the lady since. 16 Q: Oh, you've met -- 17 A: I'm not, I mean I -- I didn't 18 recognize her at the -- not -- didn't recognize either 19 one that night. 20 Q: Okay. Now, did you understand in the 21 course of hearing the "F" word used and the shouting, did 22 you understand that the police were asking the women to 23 lay on the ground, and they were refusing to do so? 24 A: I never heard that. 25 Q: And the OPP officers had their

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1 firearms pointed at -- in the direction of the car the 2 entire time you were there? 3 A: Yes, I believe they did. 4 Q: So, when you were permitted to cross 5 the road and attend to the patient, that's when you 6 realized the injured person was in the car? 7 A: Yes. 8 Q: And I take it all four (4) ambulance 9 paramedics crossed the road and went over to the person - 10 - went over to the car? 11 A: I'm aware that three (3) of us did. 12 Q: Three (3) of you did? So, during 13 that period when you arrived at the intersection, you got 14 out of your ambulance -- 15 A: Yes. 16 Q: -- and you were away from the 17 ambulance until you went back to get the backboard? 18 A: Hmm hmm. 19 Q: Is that right? 20 A: Yes. 21 Q: Do you know how long that was? 22 A: Not very long. 23 Q: Not very long? 24 A: No, it wouldn't be -- probably 25 wouldn't be a minute.

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1 Q: Okay, and how long did it take you to 2 get the backboard and then return to the car? 3 A: Less than a minute, no doubt. 4 Q: And -- and then how long was it 5 between the time that you returned to the car and you 6 took Nicholas Cotrelle back to your ambulance? 7 A: I think, according to this -- 8 Q: Yes. 9 A: -- time on Tab 8, when we left the 10 scene it was twenty-three (23) minutes. 11 Q: Okay. So, from the -- while you -- 12 while you were at the scene you were outside of the 13 ambulance almost the entire time, I take it, then? 14 A: Yes. 15 Q: And so you would have been away from 16 your radio? 17 A: No. 18 Q: No, how -- 19 A: I don't -- no, because I -- if I 20 remember right, we would have the radio on us. 21 Q: Oh, you would have the radio on you? 22 A: Yes. 23 Q: Okay. 24 A: I would think. 25 Q: You -- so you remember?

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1 A: I don't remember, but just thinking 2 of today, yes, you would have your radio on you. 3 Q: Okay. 4 A: Hmm hmm. 5 6 (BRIEF PAUSE) 7 8 Q: Now, I understand that you didn't 9 have any conversation with Mr. Cotrelle yourself -- 10 A: No. 11 Q: -- but you did describe him as, you 12 called him a young gentleman? 13 A: Yes. 14 Q: So you understood he was a young 15 person? 16 A: Yes. 17 Q: He was a teenager? 18 A: I don't know. I couldn't -- I don't 19 know how I found out, but I did know he was sixteen (16). 20 Q: Okay. You don't know how you learned 21 that? 22 A: No. 23 Q: Okay. 24 25 (BRIEF PAUSE)

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1 Q: Now, prior to placing -- well, let me 2 rephrase that. I take it you did not hear any 3 communication between the OPP officers and Mr. Cotrelle? 4 A: No. 5 Q: So -- and you were with him to put 6 him in the ambulance -- 7 A: Hmm hmm. 8 Q: -- so you did not, at any time, hear 9 any officer tell him that he was under arrest? 10 A: No, I didn't. 11 12 (BRIEF PAUSE) 13 14 Q: And you moved him using the -- the 15 back board -- 16 A: Yes. 17 Q: And it's a C-Collar -- 18 A: Yes, a -- 19 Q: Have I got that right? 20 A: Hmm hmm. 21 Q: Okay. And you used those because you 22 were concerned that there was a possibility he had a back 23 injury? 24 A: Yes. 25 Q: And it's important in those

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1 circumstances to keep a person immobile? 2 A: That's right. 3 4 (BRIEF PAUSE) 5 6 Q: And while you were on -- you were en 7 route to the hospital, did you at any time see a white 8 car with a flat tire? 9 A: No. 10 Q: You didn't pass one? 11 12 (BRIEF PAUSE) 13 14 Q: Now when you -- while you were in 15 emergency -- the emergency department, did you hear a 16 commotion outside, at any time? 17 A: No. 18 19 (BRIEF PAUSE) 20 21 Q: So -- and you arrived at the 22 hospital, we've heard, around 12:06 -- 23 A: That's -- 24 Q: -- a.m.? 25 A: That's right.

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1 Q: And how long was it -- how long was 2 it that you then went outside and you saw the white car 3 and the scene you've described to us earlier? 4 A: It was when we were leaving. 5 Q: Okay. So it was around 12:30, is 6 that -- 7 A: Yes. 8 Q: -- right? Okay, so about twenty-five 9 (25) minutes later? 10 A: Yes. 11 Q: And was there -- could you see if 12 there was anyone in the vehicle? 13 A: No, I couldn't -- I didn't see, 14 couldn't see. 15 Q: You couldn't see? 16 A: No, I couldn't see. 17 Q: Okay. And finally, you were asked 18 about a -- transporting an elderly gentleman to Sarnia 19 Hospital? 20 A: Yes. 21 Q: And can you tell us why he would have 22 been taken to the Sarnia Hospital, if the Strathroy 23 Hospital was closer? 24 A: This -- this gentleman dealt with -- 25 he wanted to go to St. Joe's hospital in Sarnia, and if I

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1 can recall right, the emergency situation wasn't -- I'm 2 not sure. I'd have to read my form, why we did that, 3 but -- 4 Q: I see -- 5 A: We took him to Sarnia General. He 6 would be a little, closer, in that area. It's -- it's 7 not much difference, though. 8 Q: I see. Thank you very much, those 9 are all my questions. 10 A: Thank you. 11 COMMISSIONER SIDNEY LINDEN: Thank you 12 very much. 13 Mr. Scullion...? 14 15 (BRIEF PAUSE) 16 17 MR. KEVIN SCULLION: You'll be happy to 18 hear I'll be pretty quick. 19 20 CROSS-EXAMINATION BY MR. KEVIN SCULLION: 21 Q: Just in regards to the last line of 22 questioning on the elderly gentleman, I don't what to 23 know who it was or what house he came out of, all I want 24 to know is the evacuation did occur. 25 Is it fair to say that this took place

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1 within a couple of hundred feet of Army Camp Road? The 2 intersection of Army Camp Road and East Parkway? Or it 3 was fairly close? 4 A: I'm not sure. 5 Q: Okay. 6 A: Not sure. 7 Q: Was it between your location at the 8 MNR parking lot and Army Camp Road? 9 A: That's possible, yeah. Hmm hmm. 10 Q: But you don't recall? 11 A: I don't recall that. Hmm hmm. 12 Q: Okay. 13 A: If I looked on the map I could tell 14 you, but... 15 Q: If it helps, we'll just prop the map 16 back on the screen. 17 A: Hmm hmm. 18 19 (BRIEF PAUSE) 20 21 Q: Is that Richardson Drive there that 22 you're pointing with -- pointing with the cursor? 23 A: Okay. Hmm hmm. 24 Q: I'm having some assistance in the 25 background. Can you use the pointer that you have there,

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1 the laser pointer, just to show the general area where 2 the evacuation took place, if you could? 3 4 (BRIEF PAUSE) 5 6 Q: Now, you say this is Richardson? 7 A: Yes, it is. Hmm hmm. And that was 8 the street we were on, and this is East Parkway. 9 Q: I'm just looking for the general area 10 where you recall the evacuation taking place. 11 A: It wasn't too far up this road. 12 Q: Okay. So it was off of Richardson? 13 A: Yes. It's -- this is Richardson, and 14 it was just off of East Parkway. 15 Q: Okay. Thank you. 16 A: Okay. 17 Q: Those are all my questions. 18 COMMISSIONER SIDNEY LINDEN: Thank you, 19 Mr. Scullion. Ms. Tuck-Jackson...? 20 21 (BRIEF PAUSE) 22 23 MS. KATHERINE HENSEL: Just for the 24 record, Mr. Scullion was referring the Witness to Exhibit 25 Number P-349(B).

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1 (BRIEF PAUSE) 2 3 CROSS-EXAMINATION BY MS. ANDREA TUCK-JACKSON: 4 Q: Good afternoon, Mr. Tedball. 5 A: Good afternoon. 6 Q: My name is Andrea Tuck-Jackson. I'm 7 going to ask you very few questions on behalf of the OPP. 8 Mr. Commissioner, if I could begin with a 9 housekeeping matter, I note that the document at Tab 1 of 10 the materials, which is Document 1000043, is the 11 Ambulance Call Report for Nicholas Cotrelle. I don't 12 believe it's been made an exhibit yet. 13 COMMISSIONER SIDNEY LINDEN: No, I don't 14 think it has. 15 MS. ANDREA TUCK-JACKSON: And, in my 16 respectful submission, it ought to be. 17 COMMISSIONER SIDNEY LINDEN: I think you 18 should. 19 THE REGISTRAR: P-354. 20 COMMISSIONER SIDNEY LINDEN: P-354. 21 22 --- EXHIBIT NO. P-354: Document No. 1000043 23 Ambulance call report (Forest 24 District) written by John 25 Tedball, September 06/'95 re

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1 gunshot trauma to Nick 2 Cottrelle 3 4 MS. ANDREA TUCK-JACKSON: Thank you, Mr. 5 Commissioner. 6 7 (BRIEF PAUSE) 8 9 CONTINUED BY MS. ANDREA TUCK-JACKSON: 10 Q: And, Mr. Tedball, if I could take you 11 to Tab 9 of the book in front of you, and I understand, 12 sir, that this is a transcript of an audio-taped 13 interview that took place on September the 16th, 1995? 14 A: Yes. 15 Q: Do you recall that interview taking 16 place? 17 A: Yes. 18 Q: All right. And I notice, sir, that 19 on the very last page, page 21, you were asked, sir, 20 about whether or not throughout the event on the evening 21 of September the 6th, into the early morning hours of the 22 7th, whether or not you had any concerns as to whether or 23 not the police, in any way, interfered with your ability 24 to respond to patients and treat them. 25 A: Hmm hmm.

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1 Q: And as I understand, sir, apart from 2 the issue of the brief delay when they secured the scene 3 at the intersection of Army Camp Road and Highway 21, 4 apart from that minor delay, at no time, -- thank you -- 5 did the police in any way interfere with your ability to 6 deal and respond to patients? 7 A: No. 8 Q: Thank you. Those are my questions. 9 COMMISSIONER SIDNEY LINDEN: Thank you. 10 Ms. Jones...? Oh, I'm sorry, Ms. Jones has still got to 11 go. 12 MS. KATHERINE HENSEL: Ms. Jones, are you 13 still -- do you have any questions for this witness, Ms. 14 Jones? Okay. I'm sorry to interrupt. 15 MS. KAREN JONES: No, no, it's okay. 16 17 (BRIEF PAUSE) 18 19 CROSS-EXAMINATION BY MS. KAREN JONES: 20 Q: Good afternoon, Mr. Tedball. 21 A: Good afternoon. 22 Q: My name is Karen Jones and one (1) of 23 the lawyers for the Ontario Provincial Police 24 Association. 25 A: Yes.

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1 Q: And, Mr. Tedball, you've talked, on a 2 few occasions, about contacts that -- that you had with 3 Staff Sergeant Lacroix and OPP Medic Ted Slomer. 4 And I understand from looking at your 5 statements, one (1) of which Ms. Tuck-Jackson has taken 6 you to, that you found both of those officers to be very 7 professional during the course of your dealings with 8 them? 9 A: Yes. 10 Q: And you talked a little bit about 11 your concerns for your safety that night? 12 A: Yes. 13 Q: And I take it in your view, that you 14 would not, and you should not need to go where there is a 15 concern that you would be unsafe; that's not part of your 16 job? 17 A: That's right. 18 Q: Yeah. 19 A: Hmm hmm. 20 Q: And you've spoken briefly about the 21 time that you spent in the ditch at the corner of Highway 22 21 and Army Camp Road, and you gave an estimate of time 23 as being somewhere between two (2) and five (5) minutes. 24 And I just wondered if I could take you to 25 your ambulance incident report and, specifically, page 2

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1 of that report. And you'll see up at the, I think it's 2 six (6) lines from the top, and I believe in that 3 document that you indicated within approximately two (2) 4 minutes after your arrival you were allowed to check the 5 patient? 6 A: Yes. 7 Q: Yeah. Is that -- does that still 8 seem accurate to you? 9 A: Yes. 10 Q: The two (2) minutes? 11 A: Hmm hmm. 12 Q: Okay. And I think that you told us 13 that what you -- when you were at the corner of Army Camp 14 Road and Highway 21, that there were two (2) people 15 standing behind the car, two (2) women? 16 A: Yes. 17 Q: And that you heard the police tell 18 them not to move? 19 A: Yes. 20 Q: And in your -- the document that Ms. 21 Tuck-Jackson took you to, Tab 9 of your book, when you 22 were talking to the SIU, I think you had described them 23 as being highly excited. Do you recall that? 24 Do you recall what -- how the two (2) 25 women were behaving?

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1 A: I'd -- I'd say they were upset. 2 Q: Okay. 3 A: Yeah, whatever the term is . 4 Q: Okay. And I take it from your 5 ambulance incident report that the only obscenities that 6 you heard came from those two (2) women? 7 A: Yes, I -- that's all I heard was... 8 Q: Yeah, okay. And you were asked some 9 questions about a gunshot and the patient at the corner 10 of Army Camp Road and Highway 21. And I noticed you, in 11 your responses, were very careful to talk about a 12 suspicion of gunshot or languages -- language to that 13 effect. 14 And I take it, at the time, you didn't see 15 the patient's wounds, themselves? 16 A: No, I didn't. 17 Q: And you had no idea what caused them? 18 A: Just -- we were told that there were 19 possibly two (2) gunshot wounds. 20 Q: Right, and that was the only 21 information that you had? 22 A: And the -- and there was a dressing 23 applied on it when I saw the area. 24 Q: Right. 25 A: Hmm hmm.

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1 Q: And you'd also made a comment that in 2 that area, that is, in about the area, I think, of 3 Highway 21 and Army Camp Road, that you would assume 4 Strathroy was the best hospital to go to? 5 A: Yes. 6 Q: And -- and why is that? 7 A: Oh, just that we discussed that that 8 would be the area, and I think dispatch would have sent 9 us there, too. 10 Q: Because of the distance? 11 A: The proximity of the area. 12 Q: Yeah, okay. And, lastly, I just 13 wanted to ask you briefly, Mr. Tedball, in your -- 14 actually two (2) more things. 15 Again, if you go -- you talked a little 16 bit about some of the things that you took part in after, 17 during the course of the day on September the 7th and you 18 talked about transporting a man who needed oxygen to 19 Sarnia. I noted in your summary -- the -- the summary of 20 your interview with the SIU that you also talked about 21 attending at a confrontation at Kettle Point where a 22 newsman had been involved. 23 Do you recall that? 24 A: It wasn't a confrontation -- 25 Q: Okay.

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1 A: -- it was a medical call. 2 Q: I'm sorry? 3 A: It was a medical call -- 4 Q: Yes. 5 A: -- involving a newsman. 6 Q: Okay. 7 A: Hmm hmm. 8 Q: So you were just picking someone up-- 9 A: Yes. 10 Q: -- at Kettle Point? 11 A: Hmm hmm. 12 Q: Okay. And, lastly, I just wonder if 13 you could run us through briefly, based on your 14 experience, the steps that you would take if you were 15 first assessing a patient prior to transporting them? 16 What would your basic protocol be? 17 A: For what type of a incident? 18 Q: Would -- would it matter or would 19 there be some steps that you would -- 20 A: ABCs -- 21 Q: -- go through in any event? 22 A: Airway, breathing, circulation. 23 Q: Right. 24 A: Spinal. 25 Q: Yeah.

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1 A: And -- 2 Q: Do you do vital signs? 3 A: Yes, vital signs would be there, 4 right after. 5 Q: Yeah. 6 A: What happened. 7 Q: Yeah. 8 A: Mechanism of the injury. 9 Q: Yeah. 10 A: And patient's conscious, alert, they 11 can ask all those questions. 12 Q: Okay. The level of consciousness, so 13 if the person's oriented to date, time, and place? 14 A: Yes. 15 Q: Yeah. 16 A: And then you'd treat from there. 17 Q: Right, based on that initial 18 assessment? 19 A: On the information. 20 Q: Okay, but I take it that any prudent 21 person would go through those steps? 22 A: I'm sorry? 23 Q: Any prudent person in your position 24 would go through those steps? 25 A: Yes, the first --

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1 Q: Yeah, they're very -- 2 A: -- steps are your ABCs -- 3 Q: -- very basic. 4 A: Yes. 5 Q: Yeah, okay. Thank you very much. 6 A: You're welcome. 7 COMMISSIONER SIDNEY LINDEN: Thank you 8 very much. 9 MS. KATHERINE HENSEL: Thank you, Mr. 10 Tedball. I have no further questions, Commissioner, for 11 this witness. 12 COMMISSIONER SIDNEY LINDEN: Thank you, 13 Mr. Tedball; that completes your evidence. Thank you for 14 giving us your -- 15 THE WITNESS: Thank you. 16 COMMISSIONER SIDNEY LINDEN: -- evidence. 17 THE WITNESS: Thank you. 18 MS. KATHERINE HENSEL: Thank you. 19 20 (WITNESS STANDS DOWN) 21 22 COMMISSIONER SIDNEY LINDEN: I think 23 we'll take a break now. We've got another witness lined 24 up for this afternoon. 25 THE REGISTRAR: This Inquiry will recess

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1 for fifteen (15) minutes. 2 3 --- Upon recessing at 3:38 p.m. 4 --- Upon resuming at 3:53 p.m. 5 6 THE REGISTRAR: This Inquiry is now 7 resumed, please be seated. 8 MS. KATHERINE HENSEL: Good afternoon, 9 Mr. Commissioner. 10 COMMISSIONER SIDNEY LINDEN: Good 11 afternoon. 12 MS. KATHERINE HENSEL: The Commission 13 calls as its next witness, Ceasor DiCesare. 14 THE REGISTRAR: Good afternoon, sir. 15 MR. CESARE DICESARE: Good afternoon. 16 17 CESARE DICESARE, Sworn 18 19 EXAMINATION IN-CHIEF BY MS. KATHERINE HENSEL: 20 Q: Mr. DiCesare, is that correct -- the 21 correct pronunciation? 22 A: It is, but some people find it 23 difficult to say and pronounce. 24 Q: Hmm hmm. 25 A: And I'm all right with you calling me

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1 DiCesare. 2 Q: All right. 3 A: Thank you. 4 Q: I'll do my best, sorry. I 5 understand, Mr. DiCesare, that you were born on May 8th, 6 1967? 7 A: Yes. 8 Q: And that you graduated from Fanshawe 9 College with a certificate in emergency medical care in 10 1987? 11 A: Yes. 12 Q: Okay. That was a one (1) year 13 program? 14 A: Yes. 15 Q: Okay. And if you could describe in 16 very general terms the type of training you received as 17 part of that program. 18 A: We received, in general, training -- 19 Q: Hmm hmm. 20 A: -- on anatomy and physiology, 21 ambulance service operations, physical education. We 22 received training -- a general physical education program 23 and we had some courses in English, on how to write 24 technical papers, things of that nature. 25 Q: Hmm hmm.

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1 A: Oxygen therapy and assessment of 2 patients, and so forth. 3 Q: Okay. Did you receive any training 4 in how to transport patients? 5 A: Yes, we did. 6 Q: Okay. And I understand that you are 7 currently employed by Lambton County as a Level 1 8 paramedic? 9 A: Yes. 10 Q: Okay. And that in 1995, you were 11 employed by the Forest Ambulance Service for eight (8) 12 years, or since 1987, as a paramedic? 13 A: Yes. 14 Q: Okay. And have you been employed 15 continuously as a paramedic since 1987 in this area, in 16 Forest? 17 A: Yes. 18 Q: Thanks. Okay. Now, I understand on 19 September 6th that -- first of all, were you on shift on 20 September 6th, 1995? 21 A: The day of September the 6th I do not 22 recall working. 23 Q: Okay. But, in the evening at some 24 point, you did come to be on duty. Can you describe how 25 that happened?

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1 A: Yes. On the evening of -- of -- of 2 that night, I was telephoned by Dispatch and I was asked 3 if I was able to upstaff a -- a unit -- 4 Q: Okay. 5 A: -- which I was and I committed myself 6 to that detail and proceeded to the Forest Ambulance 7 Station. 8 Q: Okay. You said upstaff? 9 A: Yes. 10 Q: And, can you describe for us -- we 11 have heard evidence from Mr. Connors on that -- I believe 12 on that term, but by upstaffing you mean...? 13 A: Yes. At that time the Forest 14 Ambulance Station housed two (2) ambulances; one (1) was 15 committed to the Forest area from eight o'clock in the 16 morning until six o'clock in the afternoon. At six 17 o'clock in the afternoon, that car was on call at night, 18 usually by the two (2) paramedics who worked there that 19 day. 20 The second ambulance would proceed at 21 eight o'clock in the morning to the satellite station in 22 Watford and it would return in Forest at six o'clock. 23 Occasionally, at the time, if a few of the 24 paramedics were willing or able to, they would volunteer 25 their time and upstaff the second car if the first car

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1 were to be committed on a call or if resources in the 2 area were to be depleted, the two (2) paramedics at home 3 or sometimes they would be telephoned, would be available 4 to staff that car, the -- the Watford car. 5 Q: Okay. And, I understand that's on a 6 volunteer basis? 7 A: Well, the -- the act of being 8 available was on a volunteer basis. Once we were 9 committed to a call, of course, we would be compensated 10 for that. 11 Q: Okay. Thank you. All right. Do you 12 recall at approximately what time you would have been 13 contacted at home? 14 A: I recall it was late in the evening 15 at approximately 9:30. 16 Q: Okay. And, would you have been paged 17 or received a telephone call? 18 A: At that time, I received a telephone 19 call. 20 Q: And, that was from Dispatch? 21 A: Yes. I -- I recall being telephoned. 22 Q: Okay. And, what did you do as a 23 result of that telephone call? 24 A: I put my uniform on -- 25 Q: Hmm Hmm.

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1 A: -- well, first of all I committed 2 myself to the call, put my uniform on and informed my 3 wife that I would be going out on an ambulance call and 4 proceeded to the ambulance station. 5 Q: Okay. What were you told by the 6 caller? 7 A: That we were to upstaff for a standby 8 at the Ipperwash area. 9 Q: All right. Were you told anything 10 further about what was happening or what might be 11 happening that evening? 12 A: No, I don't -- I don't recall the 13 specifics of the call. 14 Q: Okay. Do you recall the -- who it 15 was who called you? 16 A: No. 17 Q: The individual? 18 A: No, I'm sorry, I do not recall the 19 person I spoke to that evening. I didn't... 20 Q: Okay. All right. So, you proceeded 21 to the Forest Ambulance Station? 22 A: Yes. 23 Q: All right. And, what happened when 24 you got there? 25 A: When I was at the Forest Ambulance

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1 Base my partner for the evening, Mr. Gilpin, was also 2 available there and the other ambulance was also staffed 3 and ready to go. 4 Q: Hmm hmm. 5 A: The four (4) of us proceeded out on 6 the call. 7 Q: All right. And -- all right, you 8 proceeded directly out as soon as -- as soon as you were 9 ready. 10 Did you spend any time waiting in the 11 ambulance station? 12 A: No, once the garage doors were up and 13 once we were both inside the -- the unit, we booked on 14 the air, informed our dispatch centre, and proceeded with 15 the call. 16 Q: Okay. And, you were with Mr. Gilpin? 17 A: That evening I was ,yes. 18 Q: All right. And, that was in unit 19 1145? 20 A: Yes. 21 Q: Okay. If I could just take you, Mr. 22 DiCesare, I handed you a package of documents earlier 23 today that contained dispatch reports or excerpts; do you 24 have those with you still? 25 A: Yes.

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1 Q: And, for the record, these are a 2 portion of Document 1002002, which have been earlier 3 identified in these proceedings as Exhibit P-345. 4 5 (BRIEF PAUSE) 6 7 Q: And, if I could just take you to 8 Front Number 9536, which I believe would be -- one (1), 9 two (2), three (3), four (4) -- roughly the sixth page; 10 do you have that in front of you? 11 A: 9 -- 12 Q: That's -- 13 A: -- 9536, yes. 14 Q: Okay. Yes. Okay. And if we could 15 just get that document up on the screen, it would be 16 helpful; Document 1002002, Front 9536. 17 18 (BRIEF PAUSE) 19 20 Q: Thank you. And you'll see that 21 you're identified there -- I believe it's -- it's termed 22 an OASIS number? 23 A: Yes. 24 Q: 37533? 25 A: 37533.

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1 Q: Yes. Okay. And this dispatch report 2 indicates that you were notified of this call at 3 21:34:32? 4 A: Yes. 5 Q: Does that accord with your 6 recollection of the time you would have received the 7 telephone call at home? 8 A: Yes. 9 Q: Okay. Actually, it notes that you're 10 en route at 21:41:11? 11 A: Yes. 12 Q: The destination or PU commonplace is 13 identified as Ipperwash Road, Lambton. 14 And so there's less than a seven (7) 15 minute gap between the time you're -- or it indicates you 16 were notified and the time it indicates you were enroute? 17 A: Yes. 18 Q: Is that -- is that correct, that you 19 would have, in less than seven (7) minutes, been able to 20 make it out the door of the ambulance station -- 21 A: Yes. 22 Q: -- from the time you received the 23 phone call at home? 24 A: Yes. 25 Q: That's very quick.

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1 All right. Okay. What were you told when 2 you were at the ambulance base in terms of where you were 3 going? 4 A: We were told that we would -- that we 5 were going to be going to the Ipperwash Provincial Park 6 area for a standby because the police had requested our 7 services there. 8 Q: Okay. Were you directed to proceed 9 to the Ministry of Natural Resources parking lot? 10 A: Yes. That is where we ultimately 11 went and parked our vehicles, at that -- at that area. 12 Q: All right. We you instructed to do 13 so at -- while you were at the base? 14 A: I don't recall. 15 Q: Okay. Would it have been -- while 16 you were at the base, would it have been Mr. Gilpin that 17 was communicating with the dispatcher primarily? 18 A: Yes. 19 Q: Yeah. Do you recall having any 20 direct conversations with the dispatcher yourself while 21 you were at the ambulance base? 22 A: No, I do not. 23 Q: All right. Okay. And do you recall 24 whether you were advised of the route you should take to 25 attend at the MNR parking lot?

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1 A: No. There was no specific route 2 given to us. 3 Q: Okay. And were you told anything 4 further at that time about what was occurring or might 5 possibly occur that evening in the Ipperwash area? 6 A: No. 7 Q: Okay. Now, I understand Mr. Gilpin 8 was the driver for Unit 1145 that evening? 9 A: Yes. 10 Q: Okay. All right. And so you 11 travelled to the MNR parking lot; can you recall the 12 route that you took to do so? 13 A: Yes. 14 Q: What route was that? 15 A: We proceeded north on Highway 21 16 right up to the Ipperwash Road area and we turned down 17 Ipperwash Road towards the lake, proceeded right down to 18 the end, to the area of the Provincial Park. 19 Q: Okay. Do you recall encountering any 20 police checkpoints at any point? 21 A: I do not recall that, no. 22 Q: Okay. All right. And were you 23 travelling -- do you recall if you were travelling in -- 24 ahead of Unit 1146, carrying Mr. Watt and Mr. Tedball? 25 A: I remember -- I remember travelling

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1 behind them. 2 Q: Behind them. Okay. 3 So, they arrived in the -- in the parking 4 lot ahead of you? 5 A: Just seconds. 6 Q: Just seconds. 7 A: We were just seconds... 8 Q: Okay. And what did you see when you 9 first arrived at the MNR parking lot? 10 A: Upon arrival at the parking lot, I 11 noted that there was a St. John Ambulance unit there, 12 there was some police vehicles there, and some police 13 officers. 14 Q: Okay. And, can you recall roughly 15 how many police officers you -- you could see? 16 A: No, I cannot. 17 Q: Okay. And, do you recall what the 18 lighting in the parking lot was like when you arrived? 19 A: I actually don't -- I can't say that 20 there was any lighting there. 21 Q: Okay. So it was dark? 22 A: Yes, it was past 9:30 in the evening 23 by this point. 24 Q: Okay. And, to refer you back to the 25 same document, it indicates that you arrived at 21:53:42?

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1 A: Yes. 2 Q: And, that's when you arrived at the 3 MNR parking lot, just to be clear; is that -- is that 4 correct? 5 A: I believe that would be the time, 6 yes. 7 Q: Okay. And, the dispatch report 8 indicates Ipperwash Road Lambton. 9 This dispatch report, given the timing, 10 would it be your understanding it refers to your being 11 dispatched to the MNR parking lot rather than Ipperwash 12 Road? 13 A: I can't say. 14 Q: Okay. On your arrival in the parking 15 lot, what happened? Who did -- first of all, who did you 16 first speak to while you were there? 17 A: Upon arrival at the parking lot, we 18 did exit our vehicles just to have a look and see what 19 was around us. 20 Q: Hmm hmm. 21 A: We were greeted by a Sergeant 22 Lacroix. 23 Q: Hmm hmm. 24 A: He was present with another gentleman 25 by the name of Ted Slomer. He introduced himself and to

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1 what his rank was and Mr. Slomer also introduced himself 2 and to what his function was there that night. 3 Q: What did Mr. Slomer say his function 4 was that night? 5 A: He informed us that he was a medic 6 with the OPP and that he would be attending to casualties 7 -- if there were to be casualties, he would be attending 8 to them and he would be responsible for bringing anybody 9 that needed any assistance to us. 10 Q: Okay. Just to go back, did he -- did 11 you discuss with him the protocol that would be involved 12 in -- in him bringing patients to you? 13 Was there any discussion of you travelling 14 to the patients rather than patients being brought to 15 you? 16 A: No, I -- no, there was no discussion 17 of any Ministry of Health paramedic actually going out to 18 meet any patients. 19 Q: Okay. Was there any discussion of 20 you, in fact, staying put and having patients brought to 21 you? 22 A: At that time, yes. 23 Q: Okay. And that was with the OPP 24 medic, Slomer? 25 A: Yes.

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1 Q: Okay. Was Mr. Lacroix still around 2 when -- when you had this conversation? 3 A: Yes, he -- he was -- he was in that 4 area. I don't recall if he was right with us or not, but 5 he was -- he was present there. 6 Q: All right. Okay. And, was that -- 7 did you have any other conversations, first of all, with 8 Mr. Lacroix? 9 A: I -- I personally did not speak to 10 Sergeant Lacroix. 11 Q: Hmm hmm. 12 A: But he was asking us as to what type 13 of protective equipment we had available to us -- 14 Q: Hmm hmm. 15 A: -- and wanted to know if we could put 16 it on. 17 Q: And, did he say why he thought you 18 should have protective gear? 19 A: Apparently, there was -- there was a 20 fear of, perhaps the area being -- there was a concern 21 that people could have thrown Molotov cocktails at us or 22 large rocks. 23 Q: Okay. Did he indicate that this 24 activity was already occurring or just that it might 25 occur?

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1 A: I -- I don't recall whether or not 2 there was a history of that. 3 Q: Okay. And, in terms of the -- so was 4 that the extent of your conversations with Lacroix and 5 Slomer? 6 A: That -- that's all I -- I recall that 7 evening speaking with them. Other than Mr. Slomer 8 mentioning to us that he had the capabilities of 9 intubating patients and using IVs if necessary and, 10 perhaps, if somebody were to be transported that he would 11 accompany us. 12 Q: Okay. And, so how long did you 13 remain on standby in that location? 14 A: For approximately -- approximately 15 two (2) hours. 16 Q: Two (2) hours. Okay. 17 And what did you observe while you were on 18 standby there? 19 20 (BRIEF PAUSE) 21 22 A: Like I said before, I observed a St. 23 John Ambulance unit there. 24 Q: Hmm hmm. 25 A: There was a few police officers and

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1 some police vehicles and I just stayed close to my 2 ambulance that night. 3 Q: All right. Okay. And at any point 4 did you see police -- first of all, how were the police 5 that you did observe, the police officers, how were they 6 dressed, if you can recall? 7 A: Most of the officers I seen were 8 dressed with camouflage material and some of them, if not 9 most of them, were wearing -- I don't know what it's 10 called; it -- it was some sort of body armour that was 11 attached -- 12 Q: Hmm hmm. 13 A: -- with velcro. 14 Q: Okay. All right. And at any point 15 did you see them moving in formation or in large groups 16 together? 17 A: No, I didn't. I did not. 18 Q: Okay. At any point, did you see 19 officers or a number of vehicles leaving the parking lot 20 together? 21 A: I cannot recall that, no. 22 Q: Okay. All right. And at -- at any 23 point while you were on standby, prior to your leaving 24 the parking lot, did you hear anything that would have 25 sounded like gunshots to you --

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1 A: Yes. 2 Q: -- or could have been. 3 A: Yes, I did. 4 Q: Can you describe what you heard? 5 A: It was a series of popping noises in 6 rapid succession. 7 Q: Okay. And can you estimate how many 8 popping noises you would have heard? 9 A: Perhaps ten (10) to twelve (12). 10 Q: Okay. And do you recall when you 11 heard them? 12 A: I don't recall the time, no. 13 Q: Okay. Okay. And eventually you did 14 come to leave the parking lot? 15 A: Yes, that is correct. 16 Q: Can you tell us how that came to be? 17 A: We left the parking lot to attend to 18 a call on Ipperwash -- I'm sorry, Highway 21 and Army 19 Camp Road. 20 Q: Okay. And were you directed there by 21 an OPP officer or by your dispatch? 22 A: I recall being sent out there by 23 dispatch. 24 Q: Okay. And would you have had that 25 conversation yourself with the dispatcher?

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1 A: No, I did not have that conversation. 2 Q: Okay. But, you believed or you 3 understood Mr. Gilpin to have had that conversation or 4 had a conversation with a dispatcher? 5 A: Yes. 6 Q: Okay. So, you proceeded, as you've 7 indicated, to the corner of Highway 21 and Army Camp 8 Road? Is that -- 9 A: Yes. 10 11 (BRIEF PAUSE) 12 13 Q: And can you describe the route that 14 you took to get there, first of all? 15 A: Yes, we went back up -- well, it was 16 south, that's better. We went south on Ipperwash Road to 17 Highway 21 and then proceeded north to Army Camp Road. 18 Q: And for the record, Mr. Emery has put 19 up the electronic version of the map that has been marked 20 here in these proceedings as Exhibit P-349(B). 21 22 (BRIEF PAUSE) 23 24 Q: Okay. All right. And if we could 25 just get another close up view of the actual

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1 intersection, as soon as -- as soon as you're ready, Mr. 2 Emery. 3 4 (BRIEF PAUSE) 5 6 Q: First of all, Mr. DiCesare, can you 7 indicate or describe for us what you saw as you 8 approached Highway 21 -- or the intersection there? 9 A: Yes, there was a number of police 10 vehicles there -- 11 Q: Hmm hmm. 12 A: There might have been two (2) or 13 three (3) police cars there. 14 Q: Hmm hmm. 15 A: There was a car on the north side of 16 the Highway 21 intersection with -- 17 Q: Hmm hmm. 18 A: -- some OPP officers there. 19 Q: Hmm hmm. Okay. And if you could 20 just -- there's a laser pointer in -- on the desk in 21 front of you. 22 A: Hmm hmm. 23 Q: And if you could just indicate where 24 at that intersection you saw the officers, or the police 25 vehicle that you're describing.

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1 A: I recall seeing vehicles parked here 2 on this side of the road. 3 Q: Okay. Both vehicles? You mentioned 4 two (2) or three (3) vehicles. They were each on that 5 side of the road? 6 A: To my recollection. 7 Q: Yeah. And where did you park your 8 ambulance? 9 A: On the same side of the road -- 10 Q: Okay. 11 A: -- right in that area with the police 12 vehicles. 13 Q: Okay. In front of them or behind 14 them? 15 A: I don't recall. 16 Q: Okay. And did you see anything else 17 as you approached the -- that intersection? 18 A: Yes. There was a car here. 19 Q: All right. There? Yeah. 20 A: To my recollection. 21 Q: Yeah. For the record, he's 22 indicating a spot on the turnoff from Army Camp Road onto 23 Highway 21. 24 Did you see any -- did you see any police 25 officers outside of their vehicles?

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1 A: Yes, I did. 2 Q: And what were they doing? 3 A: There was a group of police officers 4 in this area where this car was and they had their -- 5 they were outside of their vehicles, standing very close 6 to the car, with their guns drawn. 7 Q: And where were their guns pointed? 8 A: At a car that was at -- at this area. 9 Q: Okay. Did you see any -- any other 10 people outside of the vehicle? 11 A: There -- there were two (2) women 12 that were outside of the vehicle. 13 Q: Where were they standing in relation 14 to the vehicle? 15 A: Very close to the vehicle. This is - 16 - at the time, this was a little fence. 17 Q: Hmm hmm. 18 A: And the women were very close to the 19 fence, very close to the car, outside of the car, in that 20 area. 21 Q: Okay. And what were they doing? 22 A: They were outside of the vehicle with 23 their hands in the air because the police has instructed 24 them to do so. 25 Q: Okay. Did you hear the police

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1 instruct them to do so? 2 A: No, I did not. 3 Q: Okay. So you're assuming that that's 4 why they had their hands in the air? 5 A: Yes. 6 Q: Okay. Just to go back a bit, when 7 you proceeded to that intersection from the MNR parking 8 lot, to your recollection, did you do so at a Code 4? 9 A: Yes, we did. 10 Q: Okay. And what were you told by 11 dispatch as to the reason for your attending at that 12 location? 13 A: There had been a shooting and there 14 were injured people there. 15 Q: Okay. All right. So, it was your 16 understanding that you were proceeding to attend to 17 gunshot -- a gunshot victim or victims? 18 A: Yes. 19 Q: Okay. Do you roughly -- or do you 20 recall what time you would have arrived at that 21 intersection? 22 A: I believe it was close to 11:00 in 23 the -- 24 Q: Okay. 25 A: -- late evening.

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1 Q: Just one moment. 2 3 (BRIEF PAUSE) 4 5 Q: If you could turn, in the documents 6 in front of you, to -- it's towards the end, it's Front 7 9543. 8 A: 9543, yes. 9 Q: Okay. You've got in front of you? 10 For the -- 11 A: Yes, Front 9543. 12 Q: That's right. 13 A: Yes. 14 Q: That is part of the document that's 15 been identified as Exhibit P-345. You'll see there: 16 "DiCesare and Gilpin, PU commonplace 17 Ipperwash Park, Lambton." 18 And: "Notified, 06 September '95, 19 23:11:38." 20 And: "En route, 23:11:38." 21 Does that accord with your recollection of 22 what time you would have departed the MNR parking lot? 23 A: Yes. Those times are really close to 24 my recollection. 25 Q: Okay.

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1 Okay. And so once you had parked your 2 vehicle, first of all, was the other unit, Unit 1146, was 3 it travelling with you at that time? 4 A: Yes, it was. 5 Q: Okay. Did they arrive before or 6 after you? 7 A: I -- I cannot say for certain. 8 Q: Just roughly at the same time as you 9 did? 10 A: Almost at exactly the same time, yes. 11 Q: And what did you do on -- on parking 12 your vehicle? 13 A: We had parked our vehicle, we had 14 existed our vehicles, and a police officer had advised us 15 to go into a ditch because the area was not safe for us. 16 Q: Okay. All right. And what did you 17 do? 18 A: I did as what was requested of us. 19 Q: You went into the ditch? 20 A: Yes. 21 Q: And that would have been the ditch on 22 the same side of Highway 21 that you were parked on? 23 A: Yes. Want me to show you? 24 Q: Yes. 25 A: Right in here.

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1 Q: All right. 2 3 (BRIEF PAUSE) 4 5 Q: And he's described -- or he's 6 indicating, for the record, the ditch to the immediate 7 south of Highway 21 where he has previously indicated 8 that he had parked his ambulance. 9 All right. Could you hear -- once you had 10 exited the vehicle, first of all, were you accompanied by 11 the -- by Mr. Gilpin into the ditch? 12 A: Yes, Mr. Gilpin was with me. 13 Q: All right. And, was Mr. Watt and Mr. 14 Tedball, were they also with you? 15 A: Yes, the four (4) of us were present. 16 Q: Okay. And, approximately how long 17 did you spend in the ditch? 18 A: Not very long; a minute or two (2), 19 perhaps. 20 Q: Okay. And, what did you observe 21 while you were waiting there? 22 A: The side of the ambulance. 23 Q: All right. That's all you could see? 24 A: Yes, because the ambulance was here 25 and I was in the ditch and I made sure I was beside the

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1 ambulance. 2 Q: Okay. So, you were between -- was 3 your ambulance between you and any police officers that 4 were present? 5 A: I was. 6 Q: Yeah. It was between you and other - 7 - any police officers? 8 A: Yes, I -- when we were told to go 9 into the ditch I made sure that not only was I in the 10 ditch, but I also was behind something. 11 Q: All right. 12 A: Like the ambulance. 13 Q: Okay. So, could you hear anything 14 from behind the ambulance? 15 A: No, I could not. 16 Q: Okay. And, how did you come to leave 17 the ditch? 18 A: Somebody had said that it would be 19 all right for us to proceed with the people that were 20 there. 21 Q: That would have been one (1) of the 22 OPP officers present? 23 A: Yes. 24 Q: Okay. Do you recall which one? 25 A: Not all, no.

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1 Q: And, did you recognize any of the OPP 2 officers there? 3 A: Not the officers that were there at 4 that time, no. 5 Q: Okay. And, what did you do on -- on 6 leaving the ditch? 7 A: I proceeded to the back doors of the 8 ambulance, opened up the ambulance and grabbed some of 9 our equipment that we carry. 10 Q: Okay. And, had you had any -- had 11 you formed any opinion or belief at that point as to the 12 condition of any patients or location of any patients for 13 that matter? 14 A: Had I formed any opinions of -- 15 Q: Yeah. 16 A: -- any patients? 17 Q: Did you know where the patient was at 18 that point? 19 A: I suspected the patient was in this 20 general area because that's where we were dispatched to. 21 Q: Okay. All right. And, so what did 22 you do next? 23 A: Well, we proceeded with some of our 24 equipment and some other larger pieces of equipment, like 25 a backboard and the stretcher and we went -- we crossed

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1 the highway and went into the area of the car. 2 Q: Okay. And, were you the first one to 3 arrive at that car or had another -- any other ambulance 4 personnel arrived prior to that? 5 A: I actually believe that I was the 6 first one to make contact with the patient there. 7 Q: Okay. And, we've heard from other 8 witnesses that that patient was Nicholus Cotrelle? 9 A: Yes. 10 Q: Is that -- did you -- what was the 11 nature of your conversation with him? 12 A: I asked him what -- what had 13 happened, asked him how he was feeling. 14 Q: And -- 15 A: I asked him what was going on. He 16 was awake, he was alert and he was able to speak and I 17 gathered some information from him. 18 Q: What did he tell you? 19 A: He had told us that he -- that they 20 had been shot on -- that he -- that they had been shot at 21 and that he had hurt his back. 22 Q: All right. And, at this point, where 23 were the two (2) women that you'd seen earlier? 24 A: The two (2) women that -- that I had 25 seen were still in this area here next to the car, close

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1 to the fence with the police officers near them. 2 Q: Okay. And, for the record, he's 3 indicating to the immediate -- a point to the immediate 4 west of the car that he's identified earlier on Exhibit 5 P-349(B). 6 And, at that point, did you hear any 7 conversation between -- between the women and the police? 8 A: I did not hear conversation between 9 the women and the police per se. 10 Q: What did you hear? 11 A: I -- the -- the women were quite 12 upset at what had happened. 13 Q: Okay. And, so could you make out 14 what they were saying? 15 A: A little bit, yes. 16 Q: And, what was that? 17 A: They were very upset and they were 18 saying that they had been shot at and they were using 19 some vulgar language to describe what had happened. 20 Q: Okay. And, were police -- do you 21 recall what police were -- were saying to them? 22 A: I didn't hear any of the officers 23 speak to the women at all. 24 Q: Okay. At not point while you were at 25 that scene?

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1 A: No, I did not. 2 Q: Okay. Okay. Going back to Mr. 3 Cotrelle -- 4 A: Yes? 5 Q: -- did you proceed to perform a full 6 assessment of him onsite there? 7 A: Yes. He has -- he, like I said, he 8 was conscious, he was alert, he was breathing on his own, 9 he had good skin colour and good respirations. 10 Q: Hmm hmm. 11 A: He had complained of, like I said, 12 pain in his lower back area. 13 Q: Okay. Did you observe any wounds? 14 A: Yes. We -- yes, Mark and I did -- 15 did remove his -- I think he was wearing a T-shirt and it 16 was removed, and we did have a look at his back area. 17 Q: Okay. And what did you see? 18 A: He had -- he had sort of laceration 19 types, almost puncture-type wounds to his lower back. I 20 think they were on the right side of his back. 21 Q: Hmm hmm. Okay. And if I could just 22 take you -- you should also have with you, Mr. DiCesare-- 23 A: Really, DiCesare is fine. 24 Q: All right. I am going to give up. 25 A: That's okay.

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1 Q: A package of documents that's been 2 previously identified in these proceedings as Exhibit P- 3 352. And if you just turn to the third page there -- 4 A: You're asking me to? 5 Q: Yes. Do you have those documents in 6 front of you? 7 A: I don't know what P -- 8 Q: It's Ambulance -- 9 A: Oh, the incident reports. 10 Q: -- Incident Reports. 11 A: Yes. Yes. 12 Q: That's right. 13 A: They're not labelled as such but I do 14 have incident reports here. 15 Q: Okay. If you could just turn in that 16 package, that would be the fifth page. And, for the 17 record, these documents do appear in the super text 18 database at Document Number 5000470. 19 A: Is this the incident report written 20 by Mr. Watt? 21 Q: Actually, no, it would be the one 22 that was completed by you. 23 A: My package is -- it starts on page 3 24 and it ends on page 4. 25 Q: We -- we did have some photocopying

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1 issues -- 2 A: Yes. 3 Q: -- this morning. If you could locate 4 the -- 5 A: Yes. Yes. 6 Q: -- incident report that you 7 completed, it notes at the top, just for identification 8 purposes, vehicle number 1145?" 9 A: Yes. 10 Q: I'm just going to see if I can get 11 that up on the screen. 12 A: Yes. 13 Q: Okay. Did you in fact complete this 14 -- this incident report yourself? 15 A: Yes, I did. 16 Q: Do you recall when you would have 17 done that? 18 A: I did this a couple of days after the 19 incident. 20 Q: Okay. And on the second page of the 21 -- the document, at the bottom, is that your signature 22 that appears there? 23 A: Yes, it is. 24 Q: Okay. All right. Taking you now on 25 the first page of the document, towards the bottom --

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1 A: Yes. 2 Q: -- you've noted there that the 3 patient was -- I believe it's conscious, it's C-O-N-S-C, 4 is that short -- abbreviation for conscious? 5 A: Yes. Yes. C-O-N-S-C -- 6 Q: Hmm hmm. 7 A: -- and there's a slash and 'Alert,' 8 yes, conscious/alert. 9 Q: "Appears well rested and calm?" 10 A: Yes. 11 Q: Does that accord with your 12 recollection? 13 A: Yes, it does. 14 Q: Okay. And you go on to say that, he 15 had what appeared to be an entry wound -- 16 A: Hmm hmm. 17 Q: -- "Right side of back, in the area 18 of kidney?" 19 A: Yes. 20 Q: Okay. Also noted, "A laceration left 21 side back, same area?" 22 A: Yes. 23 Q: You note that: 24 "The right side wound was small and 25 circular, approximately half a

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1 centimetre. Small amount of blood 2 loss." 3 A: Yes. 4 Q: "The patient has good?" 5 A: "Respirations." 6 Q: "Respirations." 7 A: "And good colour." 8 Q: "And good colour." And you go on to 9 say that he was cooperative and? 10 A: "Did complain of back pain." 11 Q: Okay. All right. So does that 12 accurately reflect what you would recall your assessment 13 having been of his condition at that time? 14 A: Yes. 15 Q: Okay. And did you assist Mr. Watt in 16 or did you yourself dress these wounds? 17 A: Yes. This -- this patient was -- was 18 looked after by Mark and I for -- for a few moments. I 19 did apply some dressings to the area and did assist with 20 starting to prepare him for transport. 21 Q: Okay. And did you in fact assist in 22 loading him onto the stretcher? 23 A: I -- I started to assist to prepare 24 him on the backboard, and to my recollection, no, I don't 25 -- I don't recall placing him on a stretcher, but I do

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1 recall dressing the wounds and getting him read for 2 placement on a spine board. 3 Q: All right. Okay. 4 5 (BRIEF PAUSE) 6 7 Q: And were you present when Mr. 8 Cotrelle was moved, actually moved, onto the stretcher 9 and into the ambulance? Into an ambulance, I should say. 10 A: As he was being moved into the 11 ambulance, yes, but I do not remember him being loaded up 12 into the ambulance per se. 13 Q: Okay. And do you recall being 14 present when Mr. Cotrelle departed the scene -- 15 A: No. 16 Q: -- by ambulance. 17 A: No, I don't recall being present when 18 he -- 19 Q: All right. 20 A: -- departed. 21 Q: And he wasn't loaded into your 22 ambulance? 23 A: No, he was not. 24 Q: Okay. Was there any discussion 25 amongst the ambulance crew there as to -- to which unit

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1 he would best travel in? 2 A: I don't recall any -- 3 Q: Hmm hmm. 4 A: -- discussion as to which unit he 5 would be going in, no. 6 Q: Okay. At some point, however, you 7 would have come to understand that he'd be travelling in 8 Unit 1146? 9 A: Yes. 10 Q: The other unit? 11 A: Yes, yes. 12 Q: Okay, at some point while you were on 13 scene there -- 14 A: Yes. 15 Q: -- I understand you would have 16 received a communication about another ambulance call? 17 A: Yes, we did. 18 Q: All right. Did you have any 19 communication with dispatch about that call yourself, 20 while you were on the scene there at Highway 21 and Army 21 Camp Road? 22 A: No. 23 Q: No? So Mr. Gilpin would have been 24 communicating with ambulance dispatch? 25 A: Yes.

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1 Q: Okay. How did you come to know that 2 you would be leaving on another ambulance call? 3 A: I heard the call come in over the 4 radio. 5 Q: All right, what did you hear? 6 A: I heard that we were being dispatched 7 priority 4 to Nauvoo Road. 8 Q: All right. 9 A: I don't recall the exact address, but 10 it's in my notes someplace. It was -- I can look on the 11 map and tell you, but it was an address on Nauvoo Road. 12 Q: Okay. And perhaps it would assist 13 you if I took you to the dispatch record. 14 A: Okay, what page is that? 15 Q: That would be Front Number 9521 and 16 Exhibit P-345. 17 A: 9531? 18 Q: Hmm hmm. 19 A: Yes. 20 Q: And that's Document Number 1002002. 21 22 (BRIEF PAUSE) 23 24 Q: And if you go -- just one (1) moment. 25

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1 (BRIEF PAUSE) 2 3 Q: Just a moment's indulgence, Mr. 4 Commissioner. 5 6 (BRIEF PAUSE) 7 8 Q: That dispatch reports that you would 9 have been notified at -- you are identified there again 10 by your OASIS number -- 11 A: Yes. 12 Q: 37533, and there is a note at the top 13 of this document, PU-6840 Nauvoo Road. Does that refresh 14 your memory -- 15 A: Yes. 16 Q: -- as to the address you would have 17 been dispatched to? 18 A: Yes. 19 Q: Okay. 20 21 (BRIEF PAUSE) 22 23 24 Q: All right, and it indicates you were 25 notified at 23:31:03?

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1 A: Yes. 2 Q: And en route at 23:32:28? 3 A: Yes. 4 Q: Okay. And do you recall the route 5 that you would have taken on leaving the scene there? 6 A: I recall travelling south on 7 Northville Road and -- 8 Q: Hmm hmm. 9 A: -- from the location where we were to 10 Northville Road, I do not recall. 11 Q: Okay. And you were travelling, you 12 mentioned, code 4 or priority 4? 13 A: Yes. 14 Q: Those mean the same thing; priority 4 15 and code 4? 16 A: Yes. 17 Q: Okay. And can you recall how fast 18 you would have been travelling? 19 A: I -- unfortunately, I was not driving 20 the ambulance -- 21 Q: Hmm hmm. 22 A: -- at the time, but I would guess we 23 would be travelling a hundred and ten (110), maybe 120 24 kilometres an hour. 25 Q: All right. And did you end up

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1 reaching the destination at Nauvoo Road -- 6804 Nauvoo 2 Road? 3 A: No, we did not. 4 Q: Okay. And so the call was cancelled? 5 A: Yes. 6 Q: Do you recall what was communicated 7 to you when the call was cancelled? 8 A: That the people who had called for 9 ambulance had left the scene and - 10 Q: All right. 11 A: -- proceeded on. 12 Q: All right. And the call was 13 cancelled at that time when you were notified that they'd 14 left the scene? 15 A: The -- the call was cancelled to us 16 when Dispatch told us to cancel the call. 17 Q: Sure. And do you recall where you 18 were when you would have received that call? 19 A: I recall being on Northville Road, 20 north of Townshead Road. 21 Q: Okay. Do you recall the time that it 22 would have been -- that that call would have been 23 cancelled, how long after you would have left Highway 21 24 and Army Camp Road? 25 A: It seemed like it was a short while

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1 after we were dispatched that we were actually cancelled. 2 Q: Okay. And, first of all, just going 3 back to when you heard the -- the call come over the 4 radio, did you leave immediately on -- on hearing that 5 call? 6 A: Not immediately, no. 7 Q: How long between the time you 8 received the call and the time you left the site there? 9 A: Perhaps a minute. 10 Q: Okay. And what were you doing during 11 that minute? 12 A: We were gathering up the trauma bags 13 and any other equipment that we had used on that call and 14 were putting our things back in the ambulance. 15 Q: Okay. And so you left the scene at 16 Highway 21 and Army Camp Road at that point? 17 A: Yes. 18 Q: You'd indicated earlier that you were 19 travelling at a hundred and ten (110) to a hundred and 20 twenty (120), is that -- was that your evidence -- 21 kilometres per hour? 22 A: I don't want to say that's my 23 evidence, but that would be my -- my best -- I don't want 24 to say the word, "guess," but I would say that -- 25 Q: Approximation?

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1 A: Yes. 2 Q: Okay. All right. And can you recall 3 how long it was between -- how many minutes it would have 4 been between the time you left Highway 21 and Army Camp 5 Road and the time the call was cancelled? 6 A: It didn't seem very long; it seemed 7 like it was maybe ten (10) minutes and we were cancelled. 8 Q: Okay. And just to take you back to 9 Front Number 9521, which was the document I'd referred 10 you to earlier. 11 A: 9521? 12 Q: Yes. It indicates the call was 13 cancelled at 23:55. 14 A: Yes. 15 Q: Now, I should tell you in all 16 fairness that we did hear evidence from Mr. Connors 17 earlier this week to the effect that that may not have 18 been an accurate time. But just for the record, it notes 19 that you were en route at 23:32 and the call was 20 cancelled at 23:30, or 23:55. 21 Would -- by your recollection, would you 22 have been driving for twenty-three (23) minutes at the 23 speed you described -- 24 A: No. 25 Q: -- prior to the call being cancelled?

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1 A: No, I don't recall -- I don't recall 2 driving priority 4 at those speeds for that long. 3 Q: All right. And you have been an 4 ambulance driver in this area for a number of years, as 5 you've described. 6 A: Yes. 7 Q: Could you estimate, if you would, how 8 long it would take you to drive from the location at 9 Highway 21 and Army Camp Road, and I understand this 10 would be an approximation, to 6840 Nauvoo Road? 11 A: May I? 12 Q: Yes, if you'd like, we can put it up 13 on the screen and you can use a pointer? 14 A: Sure. 15 Q: Okay. 16 17 (BRIEF PAUSE) 18 19 Q: And there's also a mic that you can 20 use if you're going to be speaking. 21 22 (BRIEF PAUSE) 23 24 A: This is -- this appears to be the 25 address that we were dispatched to.

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1 Q: For -- for the record, he is pointing 2 to the marked location of 6840 Nauvoo Road on Exhibit P- 3 349(B) and he is going up -- if you could indicate the -- 4 the names of the roads that you're tracing there, Mr... 5 A: This is the MNR parking lot. 6 Q: Hmm hmm. 7 A: Is that better? I'm sorry. This is 8 the Army Camp Road area and Highway 21. When we received 9 the call, we -- I remember coming down Northville Road; 10 from here to here, I think I was looking at the map and 11 writing the instructions and the problems down. 12 Q: Hmm hmm. All right. 13 A: My best estimation would be about 14 twenty (20) minutes travelling that -- travelling this 15 distance. 16 Q: And -- and, that would be travelling 17 that distance at Code 4? 18 A: I -- I'm estimating to the best -- 19 Q: Okay. 20 A: -- of my knowledge and that's what I 21 would have to say. 22 Q: All right, and for the record, the -- 23 the route that Mr. Emery has traced, based on DiCesare's 24 narration is the route that he would have taken or that 25 he would expect to take rather than the route that you

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1 actually took, because you didn't actually proceed all 2 the way to Nauvoo Road? 3 A: Well, that's the only way to get 4 there from -- 5 Q: Hmm hmm. 6 A: -- Northville Road. This -- 7 Q: Okay. 8 A: -- this is a paved road -- 9 Q: Yeah. 10 A: This is a paved road. These other 11 roads here -- 12 Q: Hmm hmm. 13 A: -- these are all gravel concession 14 roads. 15 Q: For the record, he's indicating the 16 roads to the west of Northville Road. 17 A: Well, all I -- I'll tell you, all of 18 these roads are all gravel roads. To my knowledge, 19 Townshead Line is paved. 20 Q: Okay. 21 A: Northville Road is paved. 22 Q: Okay, and -- 23 A: This is paved, and that little bit's 24 paved. So, that would be the way that we went. I 25 remember being cancelled in this area.

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1 Q: Okay. And if -- 2 A: On Northville Road. 3 Q: If Mr. Emery could indicate -- could 4 you indicate again on the map, Mr. DiCesare, where -- 5 where it was that you were cancelled? 6 A: I recall being cancelled in this area 7 here. 8 Q: Okay. If there's anywhere -- 9 A: The exact address, the -- 10 Q: Hmm hmm. 11 A: -- exact concession road, I don't 12 know, but it was just north of Townshead Line, right 13 around this area here. 14 Q: Is there a way we can draw a box 15 around that area? Yes, thank you. 16 17 (BRIEF PAUSE) 18 19 Q: Okay, and so after the call was 20 cancelled, what did you do? 21 A: We asked dispatch for direction and 22 they wanted us to proceed back on a standby. 23 Q: Okay, and where did you go? 24 A: In this area here. I can't see it 25 from where I'm sitting at this angle, but I -- I remember

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1 being sent back to the Ravenswood, Highway 21 area. 2 Q: Okay, would you have taken the same 3 route that you'd... 4 A: Would we have taken the same route 5 back? 6 Q: Yes. 7 A: Yes, we just -- 8 Q: Okay. 9 A: -- turned around and went back up. 10 Q: Okay, and Mr. Emery has actually put 11 up an enlargement of, I believe, it's Ravenswood and 12 Highway 21. 13 Is -- is that where the checkpoint was 14 that you recalled? 15 I'm sorry, I'm being premature here. Was 16 there a police checkpoint at Ravenswood and Highway 21, 17 that you can recall? 18 A: When we went back to this area, I 19 immediately don't remember seeing a police checkpoint, 20 no. 21 Q: Okay. And where were you stationed 22 on standby in relation to that intersection there? 23 A: In this area here. 24 Q: Okay. 25 A: I don't remember the exact address or

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1 the exact building we were in front of, but we were -- 2 Q: Okay. 3 A: -- just generally in this area, 4 parked off to the side of the road somewhere. 5 Q: Okay. And for the record, Mr. 6 DiCesare is indicating the general area of the 7 intersection of Highway 21 and Ravenswood on Exhibit P- 8 349(B). 9 And how long did you remain there on 10 standby? 11 A: Until about 4:30 in the morning. 12 Q: What did you do at that time? 13 A: I went home. 14 Q: And at any point during the evening, 15 did you have any further contact or any contact at all, 16 other than the contact you've described with Mr. 17 Cotrelle, with any of the First Nations people involved 18 in the incidents that occurred that night? 19 A: No, I did not. 20 Q: And you didn't have any contact with 21 Mr. Anthony Dudley George or Cecil Bernard George at any 22 point? 23 A: No, I did not. 24 Q: You never attended at Strathroy 25 Hospital?

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1 A: No. 2 Q: Okay. And we anticipate that we will 3 hear evidence that Mr. George had a bullet wound to his 4 upper left shoulder with a broken clavicle and no exit 5 wound. 6 Had you encountered Mr. George in that 7 condition, what would you have done in terms of his 8 treatment and assessment? 9 A: If we had made it to Nauvoo Road and 10 found the gentleman in that condition, would have had to 11 proceed with, again, with a primary assessment. 12 I would have had to have made sure that 13 his airway was open and that he was, in fact, breathing. 14 Q: Hmm hmm. 15 A: If he had not been breathing on his 16 own, we would have inserted either an oral pharyngeal 17 airway or nasal pharyngeal airway. 18 My partner most likely would had to have 19 mechanically ventilate him. We could have obviously 20 closed the wound using various dressings. He most likely 21 would have been rapidly, what we call in the business, 22 rapidly extricated, perhaps onto a spine board, with a 23 collar, perhaps not. 24 I can't say for sure, I didn't see exactly 25 what he looked like. And had he presented in a condition

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1 of pulselessness, CPR would have been started on him. 2 Q: Okay. And you don't -- just -- just 3 to clarify, do you have any -- any training or ability to 4 insert a chest tube? 5 A: No, I do not. 6 Q: All right. Okay. Just one (1) final 7 question, Mr. DiCesare. Do you have any -- given the 8 events as they unfolded that evening and your knowledge 9 of them and recollection of them -- 10 A: Hmm hmm. 11 Q: -- do you have any concerns about 12 how things happened? 13 A: Yes. Perhaps some notification a 14 little bit earlier would have been all right as to some 15 of the staging areas. Perhaps having a look back at it 16 now, but I -- I remember the part about the Molotov 17 cocktails and I would -- thinking what would happen if 18 something actually happened of that nature, I believe we 19 would have been ill-equipped to deal with such a thing. 20 It was dark, perhaps something in the daytime would be 21 more familiar to the people there. 22 Q: Hmm hmm. Okay. You -- you mentioned 23 prior notification, do you mean -- what do you mean by 24 that? 25 A: If -- if an event is being planned,

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1 if something was going to happen, I think various 2 agencies that are going to be involved should be given 3 notification as to when it may happen, what may happen 4 and what services may be required. 5 Q: Okay. And you also described your -- 6 or yourself as being ill-equipped to deal with something 7 like Molotov cocktails? 8 A: Yes. 9 Q: Do you mean in terms of the services 10 you would be able to provide to anyone injured or -- 11 A: No, no. No, no. If -- if somebody 12 had in fact come out and thrown something at us, we just 13 have some little small fire extinguishers in the 14 ambulance. 15 Q: Hmm hmm. 16 A: I can't imagine putting a fire out 17 with one (1) of those. 18 Q: Yeah. All right. Thank you, Mr. 19 DiCesare. Those are all my questions. 20 A: Thank you. 21 MS. KATHERINE HENSEL: Perhaps, 22 Commissioner, if we could canvass the parties as to their 23 intention to cross-examine. 24 COMMISSIONER SIDNEY LINDEN: Who expects 25 to cross-examine this Witness?

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1 Yes, Ms. Esmonde...? 2 MS. JACKIE ESMONDE: Approximately half 3 an hour. 4 COMMISSIONER SIDNEY LINDEN: Mr. 5 Scullion...? 6 MR. KEVIN SCULLION: Probably about 7 fifteen (15) minutes. 8 COMMISSIONER SIDNEY LINDEN: Ms. Tuck- 9 Jackson...? 10 MS. ANDREA TUCK-JACKSON: Five (5) 11 minutes. 12 COMMISSIONER SIDNEY LINDEN: Ms. 13 Jones...? 14 MS. KAREN JONES: Fifteen (15) minutes. 15 MS. KATHERINE HENSEL: Thank you. I'm in 16 your hands, Commissioner, as to whether we should -- we 17 should begin or would -- would you like to adjourn for 18 the -- for the evening? 19 COMMISSIONER SIDNEY LINDEN: My concern 20 is, I understand that -- 21 MS. KATHERINE HENSEL: Hmm hmm. 22 COMMISSIONER SIDNEY LINDEN: -- we're 23 going to take a break from this Witness tomorrow -- or 24 we're going to finish this Witness tomorrow -- 25 MS. KATHERINE HENSEL: Mr. Worme actually

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1 has an announcement. 2 COMMISSIONER SIDNEY LINDEN: You have to 3 give me some idea as to what our plan is. If we start 4 this witness now, can we finish him tomorrow morning? 5 MR. DONALD WORME: We would potentially 6 be able to finish tomorrow morning, Commissioner. The 7 difficulty we do have is we have presently scheduled Dr. 8 Alison Marr and Dr. Elizabeth Saettler for tomorrow. 9 We see those witnesses as being unable to 10 move and we're hopeful that we can get through both of 11 them tomorrow. If we continue with Mr. DiCesare, there 12 is some likelihood that -- that those -- the intention 13 may be unfulfilled. 14 The alternative is this -- and I can tell 15 Counsel that we do have, obviously, some amendments -- 16 adjustments that are necessary to the draft schedule that 17 had been distributed last week. As I've mentioned, 18 tomorrow we have scheduled Dr. Allison Marr and Dr. 19 Elizabeth Saettler. 20 For Wednesday, the 27th, and again this is 21 at your convenience, Commissioner, we could have Mr. 22 DiCesare back. We would then have Malcolm Gilpin and 23 Robert Scott. 24 And on Thursday the 28th, rather than the 25 current line-up, which would include Ms. Jacqueline

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1 Derbyshire, Ms. Bergman and Ms. Ladell, who are nurses 2 from the Strathroy Emergency Unit, that we would 3 reschedule those or postpone them to a later date, and 4 call on Thursday instead, Dr. Michael Shkrum, who is the 5 -- the pathologist, or the coroner. 6 Now, with respect to our obligation to 7 provide disclosure, that is production of statements and 8 list of documents, we -- it is our intention to have 9 those distributed as early as this evening electronically 10 to Counsel. And we apologize for the lateness of that 11 but there has been a fair bit of juggling that we've been 12 obliged to do. 13 COMMISSIONER SIDNEY LINDEN: I'd like to 14 try to finish Mr. DiCesare, am I saying it right, today, 15 if it's possible. So, it's ten (10) to 5:00. If we 16 start now, we would go quite late. 17 MR. DONALD WORME: Well, we're certainly 18 prepared to sit a little bit further today. Given the 19 late start, I think Counsel would accommodate that. 20 COMMISSIONER SIDNEY LINDEN: Let's get 21 started and see how far we get. Sometimes it doesn't 22 take as long as you anticipate. 23 MR. DONALD WORME: Thank you, 24 Commissioner. 25 COMMISSIONER SIDNEY LINDEN: Let's get

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1 started and see how long it takes. 2 MR. DONALD WORME: Thank you. 3 COMMISSIONER SIDNEY LINDEN: It would be 4 nice if we could finish your evidence -- 5 THE WITNESS: Yeah, I -- I understand, 6 thank you. 7 COMMISSIONER SIDNEY LINDEN: -- and not 8 have to call you back, so let's try it. 9 Ms. Esmonde...? 10 11 CROSS-EXAMINATION BY MS. JACKIE ESMONDE: 12 Q: Good afternoon. 13 A: Good afternoon. 14 Q: My name is Jackie Esmonde. I will be 15 asking you some questions on behalf of the Aazhoodena and 16 George Family Group. 17 A: Yes. 18 Q: Now, you told us that when you came 19 into the MNR parking lot you saw a St. John Ambulance 20 vehicle? 21 A: Yes. 22 Q: Was that the ambulance that you saw 23 or was it the trailer? 24 A: I don't know. 25 Q: You don't know? Could you describe

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1 what you saw? 2 A: It was a vehicle with St. John 3 Ambulance marking on them. 4 Q: Okay. Was it a large five (5) wheel 5 trailer? 6 A: No, it was a -- it was, what I could 7 best describe is, as a large cube van. 8 Q: A large cube van? 9 A: Yes. 10 Q: Okay. Now, you were asked some 11 questions about your conversation with Sergeant Lacroix. 12 A: I -- I had no conversation with him, 13 he spoke to us and I was present during him speaking. 14 Q: Okay. Now -- and I take it today you 15 don't remember very much about what he said to you? 16 A: Well, he -- he spoke to us about what 17 -- what we had in terms of our own protection. He spoke 18 to us about the possibility of having rocks thrown at us 19 or Molotov cocktails and that was really about it. 20 Q: Okay. Did he not talk to you about 21 some activities that had occurred earlier in the day? 22 A: I don't recall. 23 Q: Okay. Perhaps I could assist you by 24 refreshing your memory with a statement that you gave to 25 the SIU.

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1 A: Sure. 2 Q: I think you should find it in your 3 book at Tab 6. 4 5 (BRIEF PAUSE) 6 7 A: I'm on Tab 6, yes. 8 Q: Okay. Now, do you recall giving a 9 statement to the SIU? 10 A: Yes, I do. 11 Q: Okay. And, this appears to be dated 12 the 25th of September, 1995? Does that sound about 13 right? 14 A: Yes. 15 Q: And, you recall that that interview 16 was recorded? 17 A: Well, it's printed in front of me, so 18 it must have been recorded. 19 Q: Okay. Have you had a chance to 20 review this? 21 A: Yes, I have. 22 Q: Okay. And it does -- it does 23 generally accord with your recollection of the interview? 24 A: Yes. Yes. 25 Q: If I could turn your attention to

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1 page 3? 2 A: Yes. 3 Q: You're already there? 4 A: I'm already there and -- and yes, I - 5 - I did state that there were people having rocks thrown 6 at them and some of the police cruisers damaged. 7 Q: Okay. So -- 8 A: Yes. 9 Q: -- for the record, it would be of 10 assistance if I -- if it was read. 11 A: Yes. No, no, yes, I -- I remember it 12 now, yes. 13 Q: Okay. So, we're referring to a 14 passage about halfway down the page, some statements 15 attributed to you that: 16 "Sergeant Lacroix told us that they 17 were there because of the activities 18 that had happened earlier in the day 19 with people having --" 20 A: Yes. 21 Q: "-- rocks thrown at them --" 22 A: Yes. 23 Q: " -- and some of the police cruisers 24 were damaged." 25 And you go on to say:

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1 "I remained in the car where we were 2 parked and some of the other ambulance 3 guys were talking to him." 4 A: Yes. 5 Q: Okay. So, this has refreshed your 6 memory, then? 7 A: Yes, yes, it has, and yes. 8 Q: And -- 9 A: -- it's in front of me, I have read 10 it. 11 Q: Okay. 12 A: It may have passed my mind, but yes. 13 Q: Okay, and, so your understanding was 14 that there were -- it was more that one (1) person that 15 had a rock thrown at them? 16 A: Perhaps, yes. 17 Q: And, that some police cruisers were 18 damaged? 19 A: Yes. 20 Q: And, that that was why the OPP was 21 there at that time? 22 A: Yes. 23 Q: And, then it sounds as though you did 24 not hear the rest of the conversation because you 25 remained in your vehicle?

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1 A: Yes. 2 Q: Okay. So, from what you understood, 3 the main concern was with rocks and the possibility of 4 Molotov cocktails? 5 A: Yes. 6 Q: Now, did you have an opportunity to 7 speak with any of the attendants with the St. John 8 Ambulance vehicles? 9 A: No, I did not. 10 Q: You did not. Did you have any 11 understanding as to why they were there? 12 A: Absolutely not. 13 Q: Okay. And I take it you know, as a 14 paramedic, that St. John Ambulance is a volunteer based 15 service? 16 A: Yes. 17 Q: Yes. That they're not staffed by 18 trained paramedics such as -- as Ministry vehicles are? 19 A: That's correct. 20 Q: Now, you told us as well about 21 meeting Ted Slomer. 22 A: Yes. 23 Q: And had -- did you know him before 24 that evening? 25 A: Yes.

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1 Q: You did? And how did you know him? 2 A: I met him on one (1) occasion when he 3 was working for the Sarnia General Hospital -- Base 4 hospital program. 5 Q: Okay. And what position did he have 6 at that time? 7 A: I really don't know. 8 Q: You did know him to be a trained 9 paramedic -- 10 A: No, I -- 11 Q: -- on this particular evening? 12 A: -- I -- I didn't -- I didn't know 13 very much about Ted Slomer. I remembered him because he 14 was employed as one of the Base hospital coordinators at 15 the time, but I really didn't know very much about his 16 background, where he was from, why he was here or 17 anything of that nature. 18 Q: I see. Now, we heard from Mr. 19 Tedball earlier today, and I take it you were here to 20 hear his evidence? 21 A: I'm sorry? 22 Q: Did you hear Mr. Tedball's evidence 23 earlier today? 24 A: No. 25 Q: Okay. Then I -- we heard from him

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1 that around eleven o'clock he was approached by an OPP 2 officer in camouflage and with paint on his face. 3 Did you see such an individual around 4 eleven o'clock approach the ambulances? 5 A: They were officers that were dressed 6 in that fashion and camouflaged, yes. 7 Q: Okay. Now do you recall being 8 approached by such an officer and told that you may have 9 to take your ambulance down the road to treat some 10 injured persons? 11 A: Myself at that time, no. 12 Q: No. 13 14 (BRIEF PAUSE) 15 16 Q: Now, we heard last week when Mr. 17 Connors was here -- 18 A: Hmm hmm. 19 Q: -- we heard a tape recording of the 20 communications from the communications centre... 21 A: Yes. 22 Q: And For the assistance of My Friends, 23 I'm going to be referring to a transcript of that 24 communications tape, which has been marked as P-351 and 25 is Document Number 5000215.

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1 Now, in that transcript, there is -- it 2 appears to be the recording of Mr. Gilpin who -- who 3 states to the communications centre that: 4 "That cruiser or that Cousineau guy 5 came over to see us. He wanted us to 6 respond to that residence that you had 7 on Army Camp Road, 9780." 8 Now, Mr. Gilpin was your partner that 9 evening? 10 A: Yes. 11 Q: And do you recall being approached by 12 an OPP officer named Sergeant Cousineau? 13 A: No. 14 Q: So, at no time -- at any time were 15 you approached by an OPP officer regarding a 911 call 16 from 9780 Army Camp Road? 17 A: I was not approached of such a call, 18 no. 19 Q: And didn't -- Mr. Gilpin did not 20 advise you of any such conversation? 21 A: I don't recall that happening. I -- 22 I was not right beside Mr. Gilpin throughout the whole 23 thing. I may have been from me to you away. I may have 24 been a few feet away. 25 I may have been inside the ambulance when

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1 he was talking to an officer. I have no knowledge of 2 that. 3 Q: So, when you left the MNR parking 4 lot, you were going on a Code 4? 5 A: Yes. 6 Q: And have your lights and sirens on? 7 A: I don't recall having the siren on, 8 but the lights were on. 9 Q: Okay. Is it normal to have both 10 lights and sirens on when you're responding to a code 4? 11 A: Sometimes it is, yes. 12 Q: Sometimes? And can you explain -- 13 A: Well, if there's no other traffic on 14 the road and if you're not at an intersection, sometimes 15 the siren's not used. 16 Q: And were you given any instructions 17 by the OPP before you left the MNR parking lot with 18 respect to whether you should have your lights and sirens 19 on? 20 A: I don't recall. 21 22 (BRIEF PAUSE) 23 24 Q: Okay. Now, moving on to the 25 assessment that you did of Nicholus Cotrelle.

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1 A: Yes. 2 Q: Now, I take it during -- during that 3 time you were very focussed on the patient? You weren't 4 paying as much attention to what was going on around you; 5 is that right? 6 A: I was focussed on the patient, but I 7 was mindful of my surroundings for a little while, yes. 8 Q: Right. I take it you were somewhat 9 concerned about the situation you found yourself in? 10 A: Yes. 11 Q: Because you saw police officers with 12 their long guns out, pointed at people that -- who were 13 near a car? 14 A: Yes. 15 Q: And that caused you some concern? 16 A: Yes. 17 Q: Now, when you approach Mr. Cotrelle, 18 did he tell you his name, or you asked him his name? 19 A: I -- I recall speaking to him and 20 having some good rapport with him. I knew what his name 21 was after I had attended to him, and I don't remember if 22 he told me his full name or just his full (sic) name, but 23 I -- I do remember speaking to him quite nicely. 24 Q: Okay. Because his -- his name and 25 his age appear in the Ambulance Incident Report.

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1 A: Yes. Yes. 2 Q: And is that because you obtained that 3 information from him -- 4 A: Oh yes. Yes. 5 Q: -- at that time? 6 A: Oh yes. Yes, yes, yes. 7 Q: So, you knew that he was sixteen (16) 8 years old? 9 A: Yes. That's what he said. 10 Q: Right. And were there any OPP 11 officers close by when he gave you that information, 12 close enough to hear that? 13 A: I don't know if they were close 14 enough to hear that but there were officers in the 15 vicinity. 16 Q: Right. And I take it he -- he looked 17 like a young person? 18 A: If I recall correctly, yes, he did. 19 Q: Now, prior to crossing the road to 20 assess Mr. Cotrelle, when -- when you were told it was 21 safe to go over there -- 22 A: Yes. 23 Q: -- what other information were you 24 given? 25 A: That there was somebody in the car

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1 that needed our help. 2 Q: Okay. And they -- did they -- and 3 who told you that? 4 A: One of the officers. 5 Q: And did that officer tell you what to 6 expect when you got there? 7 A: I don't -- no, I don't recall being 8 told of a specific problem. I don't recall that. 9 Q: So, I take it -- you told us that Mr. 10 Cotrelle told you that the police had shot at him or, 11 sorry, that he had been shot at? 12 A: No, I didn't really hear it first 13 from Mr. Cotrelle because the women were saying that they 14 had been shot at and there was somebody in the car that 15 was in pain and before I even heard it from Mr. Cotrelle 16 I had an idea of what to expect. 17 Q: Okay. And you understood that they - 18 - that it was the -- they were saying that it was the 19 police that had shot at them? 20 A: That's what they were saying, yes. 21 22 (BRIEF PAUSE) 23 24 Q: And at any time while you were 25 dealing with Mr. Cotrelle, did you observe a police

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1 officer tell him that he was under arrest? 2 A: No, I did not. 3 4 (BRIEF PAUSE) 5 6 Q: Now, when you left to answer the call 7 from Nauvoo Road, your lights and sirens were on then? 8 A: Yes. I don't recall the siren 9 blaring away at that time of night with no traffic on the 10 road, but we -- we responded with the lights on. 11 Q: Okay. Now, you showed us on the map 12 earlier the general area where you believe you were when 13 you -- the call was cancelled? 14 A: Yes. 15 Q: Do you know -- do you know how long 16 it would have taken you to get to the address at Nauvoo 17 Road from that location? 18 A: I -- I believe that if we would have 19 proceeded straight through, it would have taken maybe 20 fifteen (15) minutes, maybe twenty (20) minutes; I can't 21 say with great certainty. 22 Q: That's all right. And is that -- 23 that in total, fifteen (15) to twenty (20) minutes? 24 A: I would have to -- 25 Q: Or from the position at which the

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1 call was cancelled? 2 Perhaps it would be of assistance -- 3 A: From the -- 4 Q: -- for this Witness. 5 A: -- from the Army Camp Road and 6 Highway 21 area, I -- my best guess would be 7 approximately fifteen (15) to twenty (20) minutes. I 8 can't say for certainty because ultimately I did not know 9 where that residence was. 10 Q: Okay. My question though is, if you 11 know, could -- 12 A: Well, I know now but at the time I 13 didn't know. So, now I'm going to say maybe twenty (20) 14 minutes. 15 Q: Okay. But my question is: From the 16 position you were at when the call was cancelled -- 17 A: Yes. 18 Q: -- how -- how far in time were you 19 from the -- the Nauvoo Road address? 20 A: May I have a look? 21 Q: Yes. 22 23 (BRIEF PAUSE) 24 25 A: I'm saying -- yeah -- yes, I had --

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1 this was the area where I believe to have been cancelled. 2 The -- the distance in time here, perhaps four (4) 3 minutes. 4 5 (BRIEF PAUSE) 6 7 Q: Now, when you -- when you left to 8 answer that call, you knew that your -- it was a possible 9 gunshot wound? 10 A: Yes. 11 Q: And would you have expected the OPP 12 to be attending at that location as well -- 13 A: Yes. 14 Q: -- given the nature of the call? 15 A: Yes. 16 Q: And did you have any information 17 about whether the OPP were or were not attending that 18 location? 19 A: I don't recall if I had that 20 information or not. 21 Q: You don't recall? Okay -- 22 A: I -- I don't remember, right now, 23 asking for backup and I don't remember if dispatch said 24 that they were also en route, but typically on such a 25 call we would have OPP backup.

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1 Q: Okay. 2 3 (BRIEF PAUSE) 4 5 Q: Now, I take it in situations such as 6 this where -- let's take the Army Camp Road and Highway 7 21 example, there were some safety concerns for you -- 8 A: Yes. 9 Q: -- in arriving at that situation? 10 A: Yes. 11 Q: And in your view, it's the role of 12 the OPP to assess whether a situation is safe or not? 13 A: When that type of call comes in, yes. 14 Q: Yes. 15 A: The OPP do not come out on every call 16 that we do. 17 Q: Right, and -- and you follow their 18 direction? If they tell you that an area is not safe, 19 then you don't question that, I assume? 20 A: Well, no, I'd like to know why it's 21 not safe. 22 Q: But if they tell you not to go into a 23 particular direct -- location, you would not -- 24 A: No. 25 Q: -- disobey that order, right?

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1 A: Generally speaking, no. 2 Q: Okay. And you've told us that, 3 pardon me, so you would expect them to clear a scene and 4 make it safe for you to attend before you arrive at the 5 location? 6 A: Yes. 7 Q: And then you would either attend the 8 location or an injured person could be brought to you? 9 A: Typically we would attend that scene. 10 Q: Right, because it's -- I assume it's 11 -- you would say that because -- 12 A: I -- I -- 13 Q: -- it's best for you to deal with the 14 patient -- 15 A: If you're specifically speaking -- 16 Q: -- initially? 17 A: -- about the gentleman that presented 18 at that house, I -- I really don't think the police 19 officers would have dragged him out of the car and 20 brought him to us, no. 21 Q: Right. 22 A: Once it was determined it was safe, 23 we would have gone to his aid. 24 Q: Now, I take it, though, that if a 25 scene is -- if the OPP tell you that a scene is unsafe,

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1 and they want to take some time to -- to clear a scene 2 before you arrive there, then that's the kind of 3 situation and there may be some delay in providing 4 medical care to someone? 5 A: Naturally. 6 Q: Thank you. You'll be pleased to know 7 those are all my questions. I don't think I took the 8 full half hour. 9 COMMISSIONER SIDNEY LINDEN: Thank you 10 very much. 11 Yes, Mr. Scullion...? 12 I know we're going a little late, but I 13 think I'd like to continue and finish the witness. 14 MR. KEVIN SCULLION: I think we'll be 15 okay, Mr. Commissioner. 16 COMMISSIONER SIDNEY LINDEN: That's fine, 17 let's go. 18 19 CROSS-EXAMINATION BY MR. KEVIN SCULLION: 20 Q: I trust you won't be offended but I'm 21 not even going to try to -- 22 A: Not a problem, sir. 23 Q: -- pronounce your name. 24 A: I understand. 25 Q: All right. Mr. DiCesare, I've heard

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1 some evidence regarding discussions that you had with 2 Sergeant Lacroix and with Ted Slomer when you arrived at 3 the MNR parking lot, either directly or you overheard the 4 discussions? 5 A: Yes. 6 Q: I trust that your expectations were 7 that you weren't going to be expected to go into whatever 8 was going on, but that Mr. Slomer was going to bring out 9 any casualties to you? 10 A: Yes, at the MNR parking lot area. 11 Q: Right. 12 A: That's what was understood. 13 Q: Okay. That was your expectation? 14 A: Yes. 15 Q: And your ambulance remained in the 16 MNR parking lot, although I understand it moved, at one 17 (1) point, to a different location and then moved back 18 again? 19 A: Yes. 20 Q: It just relocated, but it stayed in 21 the MNR parking lot? 22 A: Yes. 23 Q: All right. At some point, Mr. Slomer 24 came up to the ambulances and advised you that there was 25 something up at Army Camp Road and Highway 21?

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1 A: I don't recall hearing that from Mr. 2 Slomer, but somebody did mention something. 3 Q: All right, well, I'll help you in 4 terms of -- we've heard evidence from Mr. Tedball and we 5 also have -- 6 A: Yes. 7 Q: -- dispatch recordings -- 8 A: Oh, yes, yes, yes. I was not right 9 beside Mr. Tedball when that had happened, though. 10 Q: No, no, I'd -- to be fair to you, 11 there's been evidence -- 12 A: Yes. 13 Q: -- that -- 14 A: If there has -- 15 Q: -- Mr. Slomer came over. 16 A: Yes, yes. 17 Q: And, in fact, you testified earlier 18 that you thought that your dispatch had dispatched you up 19 to Highway 21 and Army Camp Road. And there is evidence 20 so far that, in fact, it was Mr. Slomer that relocated 21 the ambulances and directed them to respond to a call. 22 What I wanted to hear from you is when you 23 left the MNR parking lot, did your ambulance leave with 24 the other ambulance? Do you recall? 25 A: The first ambulance, 1146, left and

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1 we left behind them. 2 Q: You were -- 3 A: At the same time. 4 Q: You were the second ambulance, but -- 5 A: Yeah. 6 Q: -- both of you left in succession, 7 from the MNR parking lot? 8 A: Yes. 9 Q: All right, and you left behind the 10 St. John's Ambulance workers with their vehicle? 11 A: I'm sorry, could you ask that again. 12 Q: You left behind the St. John's -- in 13 other words, they were still in the parking lot -- 14 A: I don't know. 15 Q: -- when you left? 16 A: I don't know. I -- I never did see 17 the St. John Ambulance workers. I don't know where they 18 were, but they did not follow us out. 19 Q: All right. So you can't help us in 20 that regard, where they were when you left the MNR? 21 A: I don't -- I don't recall seeing the 22 St. John people there at all. 23 Q: Okay. And I just wanted to clarify 24 one (1) thing. We have an exhibit listed as P-352 that 25 has your Ambulance Incident Report attached to it, and

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1 you may have a copy in front of you. I'm looking at 2 pages 3 and 4. 3 A: Yes. 4 Q: There's a drawing on page 3 -- 5 A: Yes. 6 Q: -- that has ambulances, police, 7 bystanders in the intersection of Army Camp Road and 8 Highway 21. 9 A: Yes. 10 Q: Is that your handiwork? 11 A: Yes. 12 Q: All right. And it's accurate as best 13 as you could recall when you were putting this report 14 together? 15 A: Yes. 16 Q: All right. And it's fair to say that 17 the ambulances were parked, if not directly across from 18 the vehicle on the other side of Highway 21, very close 19 to it? 20 A: Yes. 21 Q: All right. So you're within thirty 22 (30) to forty (40) feet of that vehicle? 23 A: As long -- 24 Q: The width -- 25 A: -- as long as the road is wide and a

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1 little bit for the ditch, yes. 2 Q: All right. Those are all my 3 questions, Mr. Commissioner. 4 COMMISSIONER SIDNEY LINDEN: Thank you, 5 Mr. Scullion. 6 THE WITNESS: Thank you. 7 COMMISSIONER SIDNEY LINDEN: Ms. Tuck- 8 Jackson...? 9 10 (BRIEF PAUSE) 11 12 CROSS-EXAMINATION BY MS. ANDREA TUCK-JACKSON: 13 Q: Good afternoon, Mr. DiCesare. I'm 14 going to ask you -- my name is Andrea Tuck-Jackson. I'm 15 going to ask you some questions on behalf of the OPP. 16 A: Okay. 17 Q: I'm going to ask you, sir, if you 18 could turn to Tab 7 of your materials, which is Document 19 5000185. 20 A: Tab 7. 21 Q: Yes. 22 A: Document? 23 Q: Oh, don't worry about the document 24 number. 25 A: Okay.

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1 Q: That's just for the benefit of the 2 record. 3 A: Okay. 4 Q: And I understand, sir, that this is a 5 transcript of an interview of you that was conducted on 6 February the 12th, 2002? 7 A: Hmm hmm. 8 Q: And it was I the context of an 9 investigation that was being conducted at the behest of 10 the Chief Coroner; is that correct? 11 A: Yes. 12 Q: Okay. And in particular, sir, I'm 13 interested in an exchange of question and answer that is 14 found at pages 4 and 5 of that statement. You'll see 15 towards the bottom of page 4, you were asked by Detective 16 Armstrong: 17 "At any point in time were you impeded 18 from assisting the victim by members of 19 the Ontario Provincial Police?" 20 And in reference to "victim", they're 21 referring to Mr. Cotrelle who was treated, as we've 22 heard, at Army Camp Road and Highway 21. Okay? 23 A: What page are you on? 24 Q: Four (4). 25 A: Four (4) or five (5)? Number 4,

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1 okay. 2 Q: Do you see the passage that I read 3 out to you just a moment ago? 4 A: Yes, I do now. 5 Q: All right. And you agree with me, 6 sir, I trust, that in response to the question: 7 "At any point in time were you impeded 8 from assisting the victim [referring to 9 Mr. Cotrelle] by members of the Ontario 10 Provincial Police?" 11 And you responded: "No." 12 A: No. 13 Q: And I trust that you stand by that 14 response? 15 A: Yes, I stand by that. 16 Q: Thank you. And then turning to page 17 5, sir, you were asked, in reference to the call to which 18 you were dispatched at Nauvoo Road, again halfway down 19 the page: 20 "Anywhere en route were you prevented 21 from continuing to the farmhouse or 22 obstructed in any way by members of the 23 police?" 24 And you responded: 25 "No, I don't recall any delay

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1 responding en route to the call." 2 Question by Detective Armstrong: 3 "If you had have been prevented from 4 going, do you think that something 5 would -- you would have recalled? 6 A: Oh yeah, I think so." 7 So I trust again, sir, that your answer 8 was that at no time were you in any way impeded in your 9 transport to the call at Nauvoo Road by the police? 10 A: No. 11 Q: Thank you, sir. Those are my 12 questions. 13 COMMISSIONER SIDNEY LINDEN: Thank you, 14 Ms. Tuck-Jackson. 15 Yes, Ms. Jones...? 16 17 (BRIEF PAUSE) 18 19 CROSS-EXAMINATION BY MS. KAREN JONES: 20 Q: Good afternoon. 21 A: Hello. 22 Q: And I'll try and be brief because I 23 know that everybody would like to go home. 24 I'm Karen Jones, I'm one (1) of the 25 lawyers for the Ontario Provincial Police Association and

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1 I just had a few questions for you. 2 You were talking about when you got to the 3 area of Army Camp Road and Highway 21 -- 4 A: Hmm hmm. 5 Q: -- and after you got out of the ditch 6 and you were approaching the car, you were asked if you 7 heard any conversation or any of the talk that was going 8 on. And I think that your response had been that you 9 heard some talk from the two (2) women that were by the 10 car. 11 And I'm just wondering can you recall any 12 more specifically what they said? 13 A: They were upset because they -- they 14 had said they had been shot at. They were using some 15 vulgar language to describe the officers and that sort of 16 talk. 17 Q: Okay. I'm wondering if you turn, in 18 your book to Tab 6, which is a Summary of Anticipated 19 Evidence. And for the assistance of Counsel, it's 20 1002449, and you turn to page 5 of that document, and you 21 look at the top paragraph about partway down, you are 22 describing the other two (2) ladies were -- were up 23 walking around using vulgar language and asking what was 24 going on and things like that, you know, what -- what the 25 "F" are you doing? You're here to, you know, cause

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1 trouble and that sort of stuff. 2 A: Yeah. 3 Q: Were those comments being directed 4 towards you or towards the police or both or could you 5 tell? 6 A: I couldn't tell. 7 Q: Okay. Is it fair to say that the 8 only obscenities or bad language that you heard, at that 9 point, were from those two (2) ladies? 10 A: Yes. 11 Q: Yeah, okay. I also wanted to ask 12 you, in your ambulance incident report and I'm sorry to 13 skip you around from document to document, but that 14 happens a little bit. 15 A: Yeah. 16 Q: You have, close to the top under the 17 nature of emergency dispatched as gunshot injury and the 18 nature of emergency found as gunshot injury. 19 I take it that that was put down based on 20 the information that you had been given or what you 21 heard? 22 A: Yes. 23 Q: Okay. So, you didn't have any 24 person or direct knowledge or you couldn't tell one (1) 25 way or the other what had caused the injuries to Mr.

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1 Cotrelle's back? 2 A: That's what he said had happened and 3 that's -- 4 Q: Right, okay. 5 A: -- what it was discussed as. 6 Q: And you were asked some questions 7 about the interventions that you could have performed had 8 you ended up at the farmhouse -- 9 A: Yes. 10 Q: -- on Nauvoo Road and had you 11 attended to Mr. Anthony "Dudley" George, and I just 12 wanted to clarify a few of those things. 13 I take it that you were, at the time, a 14 primary care paramedic -- a Level I paramedic? 15 A: Yes. 16 Q: And I understand that the 17 interventions that you could perform in that role were, 18 you've told us, CPR -- 19 A: If necessary. 20 Q: If necessary, and you could do a 21 basic general assessment and we've heard that earlier 22 described as -- 23 A: Well, -- 24 Q: -- airway, breathing, circulation, 25 vital signs, level of consciousness, that kind of thing?

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1 A: A primary and a secondary assessment, 2 yes. 3 Q: And in terms of intervention, I take 4 it the interventions that you've described are really 5 sort of basic first aid. 6 If, for example, someone was bleeding, you 7 could apply pressure or put a bandage on; you could 8 splint? 9 A: Well, I -- I wouldn't say inserting a 10 nasal pharyngeal airway is basic first aid or using -- 11 Q: Oh, sorry. 12 A: -- an oral airway is basic first aid, 13 but applying a large pressure dressing, perhaps, that 14 could be -- 15 Q: Sure. 16 A: -- yes. 17 Q: And, just -- just to clarify your 18 language when you say, "oral pharyngeal airway or nasal 19 pharyngeal airway" -- 20 A: Yeah. 21 Q: -- you're talking about a fairly 22 short curved piece of plastic with a hole in it, right? 23 A: Well, the adult oral airway is 24 approximately -- one (1) of them is approximately 10 25 centimetres long.

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1 Q: Sure. 2 A: And -- 3 Q: And the purpose of that -- 4 A: Is -- 5 Q: -- is essentially to keep the tongue 6 from falling back -- 7 A: It's -- 8 Q: -- into the throat? 9 A: It's to maintain an airway. 10 Q: Right. What you can't do, and I 11 think you've told us quite fairly, is you don't insert 12 chest tubes? 13 A: I do not do chest tubes. 14 Q: Or start IV's? 15 A: I do not start IV's, no. 16 Q: Or give blood? 17 A: I'm sorry, give...? 18 Q: If blood was ordered, that's not 19 something that you would administer? 20 A: I'm not aware of -- 21 Q: No. 22 A: -- of anybody doing that right now. 23 Q: Or intubate? 24 A: No. 25 Q: And if someone had internal bleeding

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1 I -- 2 A: Yes. 3 Q: -- take it that there would be 4 little, if anything, that you could do to stop or treat 5 that internal bleeding? 6 A: Ultimately, no. 7 Q: Okay. And those are my questions. 8 Thanks very much. 9 A: Okay. 10 COMMISSIONER SIDNEY LINDEN: Thank you 11 very much, Ms. Jones. 12 Yes, Ms. Hensel; any re-examination? 13 MS. KATHERINE HENSEL: No, I have no 14 further questions for this witness. 15 Thank you, Mr. DiCesare, very much, for 16 your time today. 17 THE WITNESS: Thank you. 18 COMMISSIONER SIDNEY LINDEN: Thank you 19 very much. I'm glad we were able to complete your 20 evidence. You're finished. Thank you very much. 21 THE WITNESS: Thank you, sir. 22 23 (WITNESS STANDS DOWN) 24 25 COMMISSIONER SIDNEY LINDEN: It is almost

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1 5:25, so we'll call it a day. 2 MS. KATHERINE HENSEL: Yes. 3 COMMISSIONER SIDNEY LINDEN: And we'll 4 adjourn until tomorrow morning at 9:00 a.m. Thank you 5 very much. 6 THE REGISTRAR: This Public Inquiry is 7 adjourned until tomorrow, Tuesday, April 26th, at 9:00 8 a.m. 9 10 --- Upon adjourning at 5:23 p.m. 11 12 13 14 15 16 17 Certified Correct 18 19 20 21 22 _____________________ 23 Dustin Warnock 24 25