See also: Lisa Bradford CFPD
See also:
Lisa Bradford Criminal Trial


1 Lisa Ann Bradford,
2 being produced, sworn as heinafter certified and
3 examined on behalf of the Plaintiffs Farrell,
4 Kleinheksel and Hill and Defendants Farrell,
5 testified as follows:
8 Q. Could you tell us your name, address and
9 social security number, please?
10 A. Lisa Ann Bradford , 626 Eagle Ridge Road,
11 Cedar Falls, and my Social Security is xxx xx xxxx.
12 Q. what is your date of birth?
13 A. 12-19-67.
14 Q. Are you married?
15 A. Yes, I am.
16 Q. And your husband's name?
17 A. William Bradford.
18 Q. And do you have children?
19 A. Yes, two.
20 Q. Two children. Boys, girls?
21 A. Two girls.
22 Q. Okay. What's your educational
23 background?
24 A. Finished high school and two years at
25 Hawkeye Tech.

Page 5
1 Q. Studying what?
2 A. Marketing.
3 Q. Are you employed outside of the home?
4 A. GMAC Mortgage.
5 Q. Doing what?
6 A. Fart-time originations. Originate
7 loans.
8 Q. You are a friend of Tracy and Delonna
9 Rokes?
10 A. That's correct.
11 Q. How long have you known Mr. and Mrs.
12 Rokes?
13 A. Approximately ten years.
14 Q. How did you come to make their
15 acquaintance?
16 A. I worked with Delonna at The Limited.
17 Q. The Limited clothing store?
18 A. Yes.
19 Q. When did you work with Delonna?
20 A. Ten years ago.
21 Q. For how long?
22 A. I would say close to three years.
23 Q, What did you do at The Limited and what
24 did she do?
25 A. We were both co-managers.

Page 6
1 Q. You met at work, but after that it
2 became a friendship and you became social
3 acquaintances?
4 A. That's correct.
5 Q. did you and your husband go out with the
6 Rokeses socially as couples?
7 A, Ut would have been probably after
8 Delonna and Tracy were married, that me and my
9 husband met. Then we did go out with them
10 socially, yes.
11 Q. In other words, you and Delonna worked
12 together, then you both were married after that?
13 A. Right.
14 Q. You were both single at the time?
15 A. Yeah, we were both single at the time we
16 worked at The Limited.
17 Q. And you married you respective husbands
18 and socialized as couples?
19 Right.
20 Q. Describe you relationship with the
21 Rokeses.
22 A. Very close with them. At this time our
23 children play together, and in the beginning we
24 spent probably about every weekend together.
25 Q. Do you live near each other?

Page 7
1 A. We do at this time, yes.
2 Q. Where in relation to the Rokeses do you
3 live, how far?
4 A. I would say about two miles.
5 Q. Do you continue to see them?
6 A. Not as often.
7 Q. Not every weekend?
8 A. No, not every weekend anymore.
9 Q. A couple time a month?
10 A. At least, yes.
11 Q. All right. More than two times a month?
12 A. More than two times a month, yes.
13 Q. What types of things do you do typically
14 as couples?
15 A. As couples now we do -- we do a lot with
16 our children, so we do a lot of dinners. We'll go
17 out for dinner with the kids and adults.
18 That's really about it at this point that we do.
19 Q, Do Tracy and your husband to things
20 together without the wives?
21 A. No, not very often. No, I wouldn't say
22 at all.
23 Q. Is Delonna one of your best friends?
24 A. She is, yes.
25 Q. Have you ever seen Tracy intoxicated?

Page 8
1 A. Yes, I have.
2 Q. How many times have you seen Tracy
3 intoxicated?
4 A. I would say maybe a handful of times
5 over the years that I've known him.
6 Q. Were these on special occasions?
7 A. Yeah, special occasions.
8 Q. Like what?
9 A. Well, like maybe their housewarming
10 party or maybe his birthday. I guess I can't
11 recall every -- every time.
12 Q. Have you observed his -- when you saw
13 him intoxicated, how did he appear? What was he
14 doing that led you to believe that he was
15 intoxicated?
16 A. He was very talkative, which he is not
17 normally.
18 Q. When you say talkative, you mean he was
19 chattering on?
20 A. Just happy, chatty, yeah. Nothing
21 obnoxious or nothing like that,. Just very happy.
22 Q. Was it had to get a work in edgewise
23 with him?
24 A. Yes.
25 Q. Would you ever observe that he was

Page 9
1 chatting away and other people are telling min,
2 "Now wait a minute, be quiet, Tracy, I'm trying to
3 say something," or anything like that?
4 A. Oh, no. Just a lot of conversation was
5 all.
6 Q. Okay. Would he repeat himself a lot?
7 A. No. Just a lot more conversation than
8 usual,
9 Q. Okay. Did you ever observe him fumbling
10 or stumbling or having trouble with controlling his
11 movements?
12 A. No, I never have, no.
13 Q. Okay. When you have been out together,
14 have you had an opportunity to observe what his
15 habits and routine is with respect to drinking
16 alcohol?
17 A. I've never seen him doing like
18 excessively. Just casually.
19 Q. Do you know what his favorite beverage
20 is?
21 A. I have no idea.
22 Q. You don't know whether he drinks hard --
23 A. He would probably have a been before
24 anything else.
25 A. Okay. When you are out, how many beers

Page 10
1 does he typically have on a typical night?
2 A. I couldn't tell you that.
3 Q. Do you remember October 4th, 1996?
4 A. Yes, I do.
5 Q. What had you been doing that day?
6 A. I worked that day and then was home in
7 the afternoon. And that's about it. Let's see, I
8 had a three-month-old. I think she was three
9 months old then. Yeah.
10 Q. Do you recall what day of the week this
11 was?
12 A. A Friday.
13 Q. And where had you worked?
14 A. At GMAC Mortgage.
15 Q. Okay. Did you see Delonna Rokes during
16 the day?
17 A. No.
18 Q. Did you have any conversation with her
19 during the day?
20 A. Yeah, I had talked to her on the phone
21 that afternoon.
22 Q. About what time?
23 A. I don't even remember. I'd say probably
24 early afternoon.
25 Q. What did you talk about?

Page 11
1 A. That we had got a sitter that night and
2 that me and Bill were planning on going out for the
3 evening, and if they were interested we would be up
4 at Brooster's.
5 Q. Was Brooster's a regular place where you
6 went?
7 A. Not real regular. Just every once in a
8 while.
9 Q. Was it a place where you and Tracy and
10 Delonna would go to and socialize?
11 A. Yeah.
12 Q. And you recall that this conversation
13 happened in the early afternoon?
14 A. Somewhere in the afternoon, yes. I
15 don't recall what time exactly.
16 Q. Did you call Delonna or did Delonna call
17 your?
18 A. I called her.
19 Q. Okay. Do you remember telling the
20 police that you called Delonna around noon?
21 A. No, I don't.
22 Q. If that's what you told the officer -- I
23 mean, you do recall talking to the police?
24 A. Yeah, I do. But I guess I don't recall
25 exactly what time I mentioned at the time. It was

Page 12
1 a while ago.
2 (Deposition Exhibit 33 marked for
3 identification, as requested.)
4 You have in front of you what has been
5 marked as Exhibit 33.
6 A. Okay.
7 Q. Do you see on the second paragraph of
8 that statement it says, "On 10-4-96 around
9 12 o'clock noon, I called Delonna at home." do you
10 see that?
11 A. Yeah.
12 Q. And by the way, is Exhibit 33 the
13 statement you gave to the police?
14 A. Okay.
15 Q. Is it? I mean, do you recognize it as
16 such?
17 A. Yeah, I do.
18 Q. Okay, so that statement indicates that
19 you told the officer that you had talked to Delonna
20 around noon; correct?
21 A. Okay. Okay.
22 Q. What did -- did you have any firm
23 arrangements with Delonna? In other words, did she
24 say, "Okay, we'll meet there"?
25 A. No. They weren't for sure. They didn't

Page 13
1 I guess have a sitter arranged or anything at that
2 point, so it was up in the air.
3 Q. What did you do the rest of the
4 afternoon?
5 A. I don't remember. I have no idea.
6 Q. All right. Did your husband and you go
7 to Brooster's?
8 A. Yes, we did.
9 Q. Do you recall what time you left your
10 home for Brooster's?
11 A. Probably a little before -- probably
12 around 7 if we had the baby-sitter come at 7, so it
13 was probably around a quarter after, 7:30,
14 somewhat in there.
15 Q. All right. Had either you or your
16 husband had anything of an alcoholic nature to
17 drink prior to leaving for Brooster's?
18 A. No.
19 Q. No cocktails or anything before you
20 left?
21 A. Nope.
22 Q. When you left your home, did you go
23 directly to Brooster's?
24 A. Yes, we did.
25 Q. And do you recall what time you arrived?

Page 14
1 A. Somewhere before 7:30, I know.
2 Q. Okay. When you arrived at Brooster's,
3 did you see anybody you knew?
4 A. Craig and Connie, our friends, were
5 already there waiting for us.
6 Q. Were Tracy and Delonna Rokes already
7 there?
8 A. No.
9 Q. Had you talked to the Youngs at al
10 before then?
11 A. No.
12 Q. In other words, this was just a surprise
13 to you that they were there?
14 A. I know Delonna was going to talk to some
15 other couples that we did things with, but I never,
16 you know, made sure or talked to her as to who it
17 might be. So I left it up to her.
18 Q. Okay. Did you have anything to drink
19 right away when you got there?
20 A. Yes, I did.
21 Q. What did you have?
22 A. Beer.
23 Q. By the way, when you talked to Delonna
24 earlier in the day, and I'm leapfrogging around a
25 little bit, but when you talked to Delonna around

Page 15
1 noon, had she mentioned being out with any other
2 friends?
3 A. During the day?
4 Q. During the day.
5. A. No.
6. Q. All right. She didn't indicate that
7 she'd been out to lunch or anything like that?
8 A. I don't recall that, no.
9 Q. Do you know the Brauns?
10 A. Yeah. I do.
11 Q. Delonna did not mention seeing Tracey
12 Braun that day?
13 A. No, she didn't, not to me.
14 Q. Okay. Were the Brauns at Brooser's
15 when you arrived?
16 A. No. They came quite a bit later, I
17 believe. It was I would say closer to *:30 they
18 arrived.
19 Q. The Rokeses did arrive; correct?
20 A. Yes.
21 Q. Approximately what time did they arrive
22 at Brooster's?
23 A. It was about half an hour after us, so
24 probably close to 8.
25 A. Had you had more than one beer by the

Page 16
1 time they arrived?
2 A. No.
3 Q. Still on the first one?
4 A. Still on the first one.
5 Q. How about your husband?
6 A. He doesn't drink much. He probably had
7 maybe one drink. I mean, I know he had one drink,
8 but I'm sure that's all he had at that point.
9 Q. Okay. After the Rokeses arrived what
10 did you do?
11 A. The girls kind of sat together and
12 talked and when the guys kind of got together and
13 talked as well.
14 Q., And this would have been -- when you say
15 the girls, it would have been yourself, Connie
16 Young, Delonna Rokes, and then at some point Tracey
17 Braun?
18 A. Right.
19 Q. All right. Initially were you all on
20 the Brooster's side of the place?
21 A Yes.
22 Q. As I understand it, the guys were
23 watching a game?
24 A. Yeah. World Series, maybe.
25 Q. And the girls were just talking amongst

Page 17
1 themselves?
2 A. Yes.
3 Q. All right. While you were talking with
4 Connie and Tracy and Delonna, were you paying any
5 attention to what the guys were doing?
6 A. No.
7 Q. All right. So you couldn't tell me
8 what, if anything, any of them had to drink while
9 you were all talking?
10 A. No, I couldn't.
11 Q. Okay. Did you have any conversation
12 with Tracy while you were -- Tracy Rokes while you
13 were still on the Brooser's side of the bar?
14 A. Maybe, "Hi, how you doing?", but not
15 until we get over to the Celebration's side did I
16 stand next to him and talk to him for a short
17 period.
18 Q, And the greetings would have been when
19 they came in?
20 A. Right.
21 Q. Approximately what time did you go over
22 to the Celebration's side, if you can recall?
23 A. I would say it was probably about (,
24 because that's when the band starts over there, and
25 there was music over there. So probably a little

Page 18
1 after 9.
2 Q. Okay. So you had been there by then an
3 hour and a half, going on two hours?
4 A. Yeah, uh-huh.
5 Q. All right. How much had you had to
6 drink yourself by then?
7 A. Maybe two beers, if that.
8 Q. After you went over to the Celebration's
9 side, is that the first time that you had any
10 conversation of anything beyond just exchanging
11 greetings with Tracy Rokes?
12 A. Yes.
13 Q. You were standing next to each other for
14 a period of time?
15 A. Yes.
16 Q. Hit was a brief conversation?
17 A. Yes.
18 Q. Do you remember what you talked about?
19 A. No, I couldn't tell you that.
20 Q. Tracy Rokes, was he drinking? Did he
21 have a drink in his hand?
22 A. I think when I was standing up next to
23 him he was maybe getting a drink.
24 Q. Okay.
25 A. I'm not for sure.

Page 19
1 Q. Do you know how much he had had to drink
2 by then?
3 A. No.
4 Q. So he was getting a drink, you had a
5 brief conversation, and then you went off to talk
6 to the girls again?
7 A. Actually, I think there was some other
8 friends of our there that we had spoken with, but
9 I don't remember exactly who. I mean, there were
10 other people there as well.
11 Q. All right.
12 A. Just acquaintances and that.
13 Q. When you say "we had spoken to," was
14 your husband there then?
15 A. Yes.
16 Q. did he go over with you to talk to these
17 other folks?
18 A. Yes.
19 Q. You don't recall who they were?
20 A. No, I don't.
21 Q. Did you and your husband stay together
22 then when you were talking to these other folks?|
23 A. Yes.
24 Q. Did you ever go back and talk to Tracy
25 Rokes?

Page 20
1 A. No, because him and Delonna had gone out
2 to the dance floor then, and then we had left by
3 then. So we didn't have much conversation with
4 them after that.
5 Q. So after you had the brief conversation
6 with Tracy, you and your husband Bill went over to
7 talk to these other friends, Tracy Rokes and
8 Delonna went out on the dance floor, and that's
9 pretty --
10 A. Basically, we left then.
11 Q. And then you left?
12 A. Right.
13 Q. Okay. Do you have any way of knowing
14 how much beer Tracy Rokeses had while on the
15 Celebration's side?
16 A. No.
17 Q. Approximately what time did you leave?
18 A. We left I believe it was by 10, because
19 I think we had to have the baby-sitter home by
20 10:30 that night. So, yeah, we were home by a
21 a little after 10.
22 Q. Oh you were home by 10?
23 A. Yeah.
24 A. All right. How long did it take for you
25 to get from Brooster's to home?

Page 21
1 A. About 10, 15 minutes.
2 Q. So would you have actually left
3 Brooster's before 10 o'clock?
4 A. I would say right at about 1o.
5 Q. Okay. Obviously, you would have no way
6 of knowing how much or what Tracy Rokes had to
7 drink after you left.
8 A. No.
9 Q. I think I asked you this, but I just
10 want to clarify in my own mind, Bill was with you,
11 in other words, you had the brief conversation with
12 Tracy, you and your husband both went over to talk
13 to these other folks, and then you both would have
14 lost contact with the Rokeses at that point?
15 A. Yeah. We were in the same general area,
16 but I mean everyone kind of did their own thing.
17 Q. Were you able to tell one way or the
18 other whether or not the beer that Tracy had
19 consumed that evening while you were there was
20 affecting him in any way?
21 A. No.
22. Q. I mean, is this something you just can't
23 tell one ay or the other?
24 A. No, other than what I told you, he was
25 maybe talking a little bit more, you know. But

Page 22
1 no, he seemed fine to me, basically.
2 Q. Was he talking a little bit more?
3 A. Not at this point.
4 Q. At any point?
5 A. Not then I was there, no.
6 Q. And, obviously, if he had anything to
7 drink at some point in time when you weren't able
8 to observe him, you wouldn't be able to comment on
9 what he had to drink?
10 A. Correct.
11 Q. In your statement to the police you
12 indicated that Delonna was drinking, but you're not
13 sure how much she had; correct?
14 A. Correct.
15 Q. You indicated that she was upset and was
16 talking about her mother, is that correct?
17 A. That's correct.
18 Q. And you say that "Her mom was
19 having some heart problems and she was talking
20 about that." And then you also say, "Delonna didn't
21 seem herself, but I don't know if the alcohol had
22 anything to do with it." Do you mean by that that
23 you just didn't form an impression one way or the
24 other?
25 A. No. I didn't now if she was upset or

Page 23
1 if she just -- I don't know, I just didn't know if
2 she was depressed or trying to like cover it up,
3 that she wasn't upset. I don't know if that makes
4 sense.
5 Q. In other words, you knew she had been
6 drinking, and you knew there was something going on
7 with her mother?
8 A. Right.
9 Q. But you weren't able to determine how
10 much of her emotional response was due to her
11 concern over her other or the alcohol?
12 A. Correct.
13 Q. Whether it was the alcohol or her
14 concern over her mother or a combination of both?
15 A. Right.
16 Q. All right. You state in your statement
17 that she had been crying during the day. When had
18 you been in a position to observe her crying during
19 the day?
20 A. When I talked to her at noon, or
21 over that afternoon.
22 Q. She was crying over the phone?
23 A. Yeah, she was upset.
24 Q. Do you know how much your husband, Bill,
25 had been drinking that night?

Page 24
1 A. No, I don't
2 Q. Who drove home?
3 A. My husband.
4 Q. How did you find out about the
5 collision.
6 A. in the newspaper.
7 Q. When was that?
8 A. Sunday.
9 Q. Did you talk to the Rokeses about it?
10 A. No, I didn't. I didn't call them. I
11 didn't want to bother them. I guess I didn't know
12 what the situation was.
13 Q. Did you ever talk to -- well, let me ask
14 you this: You've got the statement in front of
15 you, this Exhibit 33.
16 A. Uh-huh.
17 Q. It's dated October 10th, 1996.
18 A. Uh-huh,
19 Q. Between the time of the collision and
20 when you gave this statement, did you talk to
21 either Tracy or Delonna Rokes?
22 A. I would have talked to Delonna.
23 Q. When did you talk to her?
24 A. I don't recall the date.
25 A. Do you recall where this conversations

Page 25
1 took place?
2 A. It would have been over the phone.
3 Q. Do you recall what you said to her and
4 what she said to you?
5 A. I don't.
6 Q. Did she tell you what happened?
7 A. Not really. I think I basically asked
8 what the situation was and she said that they, you
9 know, had a collision, but she didn't really know
10 what had happened. She just kind of remembered a
11 car coming at her. I mean, she was on the
12 passenger's side and she remembers something coming
13 towards her and she just remembers she was talking
14 to Tracy and the next thing you know they were in
15 an accident. And that's basically all at that
16 point we talked about. She wasn't really clear of
17 what had happened at that point.
18 Q. Your testimony is that when you talked
19 to Delonna she really didn't know the details of
20 what had happened?
21 A. No.
22 Q. Q. Did she say anything to you about how
23 fast their car was going and how fast the other car
24 was going?
15 A. No.

Page 26
1 Q. Did she say anything to you about the
2 lights and whether they were red or yellow or green
3 or anything like that?
4 A. Not really. She was pretty quiet, so I
5 didn't ask many questions.
6 Q. Did she say anything to you about Tracy
7 and whether he was intoxicated or not?
8 A. No.
9 Q. Did you know in that conversation that
10 Tracy had been charged with a criminal offense?
11 A. No.
12 Q. Did you talk with Delonna or Tracy after
13 you gave this statement of October 10th, 1996 about
14 the collision?
15 A. I'm sure, but I don't remember when or
16 what we talked about.
17 Q. You continued to see them socially and
18 you still see them socially' right?
19 Q. Right. But it's something we don't talk
20 about too often.
21 Q. Prior to the criminal trial, did you
22 talk to them about what had happened?
23 A. Not really. I probably would have
24 probably talked to our friends more than them,
25 because I just didn't feel comfortable talking to

Page 27
1 about it.
2 Q. Why is that?
3 I didn't know the situation, what was
4 going on. I just didn't feel it was by place to
5 ask questions.
6 Q. Did either they or anybody else that
7 you're aware of ask you to express any opinion as
8 to whether or not you thought Tracy was under the
9 influence?
10 A. No.
11 Q. Did you observe Tracy and Delonna
12 dancing?
13 A. Yes, I did.
14 Q. Do you know how long they were dancing?
15 A. No, I don't.
16 Q. Do you know if they were still dancing
17 when you left the bar?
18 A. No, I don't
19 Q. They might have stopped by then?
20 A. They might have. I'm not sure.
21 Q. Okay. And where they went you don't
22 know?
23 A. No.
24 Q. In other words, when they left the dance
25 floor, you don't know what they did?

Page 28
1 A. No.
2 MR. LIABO: Okay. I think that's all I
3 have.
6 Q. We have been introduced, and I represent
7 Tammy Kleinheksel. I'll make this short,
8 First of al, you've seen Mr. Rokes
9 intoxicated before?
10 A. Yes.
11 Q. And he talks lot, staggers a little,
12 maybe, unsure on his feet, is that fair?
13 A. No.
14 Q. Okay. How do you recognize him being
15 intoxicated?
16 A. Just very outgoing, talkative.
17 Q. A little louder than usual, maybe?
18 A. Maybe a little louder.
19 Q. And as I understand your testimony
20 today, you have no opinion as to whether or not he
21 was intoxicated that night?
22 A. No.
23 Q. Is that correct, you don't know?
24 A. No, I don't know.
25 Q. Okay. And you don't know whether

Page 29
1 Delonna was intoxicated either?
2 A. No, I don't know.
3 MR. LIABO: the answer would have been
4 "Yes, I don't know."
5 THE WITNESS: Yes, I don't know. You
6 guys are starting to confuse me. That's your job.
7 MR. LIABO: Very tricky question.
8 Q. You couldn't give testimony, because you
9 really don't know whether either of them were
10 intoxicated?
11 A. No.
12 Q. Correct?
13 A. No,m I do not know. I'm sorry.
14 Q. You don;t have any opinion today, do
15 you?
16 A. No.
17 Q. And you left about 10 o'clock, as I get
18 it?
19 A. Yes.
20 Q. And they were still there?
21 A. Yes.
22 Q. So you don't know what either Delonna or
23 Mr. Rokes had to drink after you left?
24 A. No.
25 MR. GALLAGHER; That's all I have.

Page 30
1 MR. TEMPLE: I don't have any
2 questions.
3 MR. HELLMAN: I don't have anything.
4 thank you.
7 Q. I want to to that confusing area.
8 A. Okay. I know I was confused before on
9 it too.
10 Q. When you last observed Tracy Rokes on
11 the evening of October 4, 1996, did you or do you
12 have an opinion as to whether or not he was
13 intoxicated?
14 A. Do think he was or do I --
15 Q. Do you have an opinion is what I'm
16 asking.
17 A. I don't think he was. But that's my
18 opinion. Okay?
19 MR. BEVEL: I don't have any other
20 questions.
23 A. I've just got one to follow up.
24 In your trial testimony you were asked a
25 question, "Did you form an opinion about whether or

Page 31
1 not the Defendant was intoxicated?" And your
2 answer was "No".
3 MR. BEVEL: Which page?
4 MR. GALLAGHER: Page 765, lines 4
5 through 6.
6 Q. That's what you said at the time of the
7 trial.
8 A. Right. And I remember that was a
9 confusing statement for me at that point too,
10 because ha had to reword it as well.
11 A. But you were asked directly did you have
12 an opinion and your answer was no, you didn't have
13 an opinion, right?
14 A. Right. But at that point I thought we
15 were talking about Delonna. Then he corrected
16 himself saying, no, we were talking about Tracy.
17 Q. You knew that you were testifying in a
18 trial at which Tracy Rokes was the Defendant,
19 didn't you?
20 A. Right. But at that point we were
21 talking about Delonna and then he made that
22 statement and I thought he was talking about
23 Delonna at the time.
24 A. You're saying that's just a
25 misunderstanding and you didn't understand the

Page 32
1 question?
2 A. And he corrected me at the time.
3 MR. GALLAGHER: Okay. That's all I
4 have.
7 !Q. I apologize for this, Mr. Bradford, but
8 let me just show you a copy of the transcript. And
9 let me start at the beginning on page 764 of the
10 series of questions that dealt with your opinions.
11 And the question was on page 764, "You also
12 indicated to the Cedar Falls Police Department that
13 you saw him drinking that night, but you weren't
14 really sure how much he had to drink?"
15 A. Right.
16 Q. And your answer was: "That's correct."
17 Then the next question was: "And did -- do you
18 believe you've ever seen the defendant
19 intoxicated?" Your answer was" "Yes, I have."
20 Question: "And do you think that you've ever seen
21 Delonna Rokes intoxicated?" Your answer: "Yes, I
22 have." Question: "Did you have an opinion about
23 whether or not Delonna Rokes was intoxicated on
24 October 4th at Brooster's?" Your answer was: "No,
25 I don't." Question: "You didn't have an

Page 33
1 opinion?" Answer: "No." Question: "So you don't
2 know one way or the other whether Delonna Rokes was
3 intoxicated or not?" Answer: No. I just knew
4 she was upset that night." Question: "Did you
5 form an opinion about whether or not the Defendant
6 was intoxicated?" Your answer was what?
7 A. "No." But --but I know at that point I
8 still thought he was still talking about Delonna.
9 But when he said Defendant, I was thinking
10 Delonna. I didn't -- that that's who he was
11 talking about. Is that what you were getting to?
12 Q. All right. So when the question was
13 asked, do you have an opinion or did you have an
14 opinion as to whether or not the Defendant was
15 intoxicated, you thought he was referring to
16 Delonna?
17 A. Yes.
18. Q. Delonna was not the Defendant, though.
19 A. I know. That's why he had to go back
20 and correct himself.
21 Q. The questioning goes on where you
22 discuss the purpose of the gathering.
23 A. Right.
24 MR. BEVEL: We're sill on page 765?
25 MR. LIABO: On page 765.

Page 34
1 Q. And he states, question: "And that
2 certainly wasn't the point of going out, as it?",
3 to get drunk?
4 A. Right.
5 Q. Your answer: "No. It was just a very
6 social, casual atmosphere." And the point was that
7 as you were talking to Mr. Rokes you weren't
8 deliberately trying to determine on way or the
9 other whether he was intoxicated?
10 A. When I was talking to him at the bar,
11 you mean?
12 Q. Yes.
13 A. No.
14 Q. You were just having a conversation with
15 him?
16 A. Right.
17 Q. And you would have had no way of
18 knowing, based upon what you had observed to him,
19 whether or not he had had enough to drink to affect
20 his ability to operate a motor vehicle?
21 A. Right.
22 MR. LIABO: Okay. Thank you.

Page 35
3 Q. Let me go to page 762. The question at
4 line 3, you were asked apparently by Mr. Correll,
5 "Did you have any conversation with Tracy Rokes on
6 the Celebration's side?" And your answer was?
7 A. "Yes, I did."
8 Q. And then to the next question at line 6,
9 "And do you recall, what was the nature of the
10 conversation that you had with him?"
11 A. "No."
12 Q. And you answer was, "No. It was just
13 casual chitchat," is that right?
14 A. That's correct.
15 Q. And then the next question was: "Was
16 there any -- when you had your conversation with
17 him, was there ever any indication of him slurring
18 words in any way?" And your answer was?
19 A. "No."
20 Q. Then the next question was: "Was there
21 ever any indication of him saying things that were
22 inappropriate or anything such as that?" And your
23 answer was?
24 A. "Not at all."
25 Q. And then the next question: "Was there

Page 36
1 anything that you observed, whether it was an
2 observation, anything he said, tat caused you for
3 an instant to think that he was in any fashion
4 intoxicated or under the influence of alcohol?"
5 And what was your answer?
6 A. "No."
7 Q. Okay, Now on page 767 at line 3 you
8 were asked: "Mrs. Bradford, is there any doubt in
9 your mind that Tracy Rokes was not under the
10 influence or not intoxicated on October 4th?" And
11 what was your answer?
12 A. "No, he was not"
13 MR. BEVEL: I don't have any other
14 questions
17 I just have one question. Does that
18 question make any sense to you?
19 A. Which one?
20 Q. "Is there any doubt in your mind that
21 Tracy Rokes was not under the influence or not
22 intoxicated on October 4th?"
23 A. And I replied, "Not at all"?
24 Q. Does that even make sense?
25 A. Well that didn't make sense to me,

Page 37
1 half of anything he said.
2 MR. BEVEL: Which guy?
3 THE WITNESS: That lawyer guy.
4 Q. I''m not trying to be unfairly, but when I
5 read that question before and that answer, I
6 couldn't figure out what the question was and what
7 it was you were answering.
8 A. I know Because I couldn't understand
9 what he was trying to get through to me.
10 MR. LIABO: Okay. Thanks.
11 (Deposition concluded at 3:03 p.m.)



updated 01/21/17