Mr. Hubert. You realized the door had to be closed?
Chief Batchelor. I realized the door had to be closed and we hadn’t told anybody to close it, so as soon as they brought him out and I saw them bringing him out, I turned and started up the ramp to close the door on the truck, and that is when the shooting happened.
Mr. Hubert. Do you remember having any conversation or giving any instructions with reference to the position of the press and other news media on the west side of the railing that divided the ramp from the basement?
Chief Batchelor. Yes.
Mr. Hubert. That is to say, the Harwood side of the railing?
Chief Batchelor. I don’t follow you. There is not any Harwood Street side of the railing. The railing is on the other side of the driveway.
Mr. Hubert. That’s right, but if you take the railing as a central point—I will put it this way. The jail side of the ramp, does that make sense to you?
Chief Batchelor. Yes.
Mr. Hubert. Which I think is really the west side of the railing?
Chief Batchelor. West side of the ramp; yes, and it would also be west of the railing.