murder trial, one day after testifying that derek chauvin used excessive force after he had george floyd pinned to the ground, a national expert on use of force will take the stand again first thing this morning. >> son we're hoping to learn whether jody stiger's testimony was abruptly interrupted. and let's begin with josh campbell. tell us what is on the dock at the time today. >> reporter: and there is a big mystery, and in was this is wh court abruptly interrupted. the attorneys conferred with the judge and the judge abruptly adjourned the trial for the day. we're hoping to learn why that was. we believe that it is because the defense objected to that witness' participation. and he weighed in on his view of derek chauvin's actions. take a listen to what he said. >> once he was played in the prone position on the ground, at that point the officers -- ex-officers i should say, they should have slowed down or stopped their force as well. >> this is one of several criticizing the actions saying that there was unnecessary force used. however it is worth noting that the defense did score some points yesterday in their he was to try to cast doubt on whether chauvin was actually in the wrong, it was arguably the best day yet for the defense. they were able to elicit some information including this exchange with another expert. >> have you had people say i can't breathe. >> yes, sir. >> and were there circumstances during the course of your career as a patrol officer where you didn't believe that that person was having a medical emergency? >> yes, sir. >> and that is all part of the analysis in terms of the use of force, right? >> it plays a part, yes, sir. >> use of force has been a key topic. one other key area, forensics. we're still waiting to hear if or when we will hear from the county medical examiner, of course both the prosecution and against have serious questions for that medical examiner about fl george floyd's cause of death. >> and now joining you to discuss, laura coats and charles ramsey. thanks to you both. good to have you on again this morning. laura, a legal question for you. so you have a use of force expert from the los angeles police department, not directly involved, but someone with expertise in this area. testifying as did other minneapolis police officers that the use of force was excessive. why would this be enter represented midway and do we expect him to come back this morning? >> well, it is odded b ed becauu can't just spring an expert on the other side. you have to get what is called expert 23notice. you have to lay out for the other side why this person has expertise, what they will contribute to the testimony. and if there is any reason to suspect that this person is not an expert or their testimony is not somehow accepted in terms of their conclusions in the wider scientific community, you hash all that out before they ever set foot in the courtroom. because you can't put the toos pa toothpaste back into the tube. so i'm surprised that whatever made them end the testimony was not resolved prior to him taking the stand. it may be that because remember the admonition from the judge about the prosecution wanting to bring in different law enforcement officials to get testimony through that might be redundant in some way, this might be a combination of those things, but we're all waiting to see. >> and commissioner, i want you to listen to this from testimony yesterday from an emt named nicole mcken cziekenzie. she is asked about what is an officer supposed to do if someone is not breathing and they can't find a pulse. >> what are officers trained do if they can't find a pulse? >> you immediately start cpr. >> is that getting back to the mpd policy that they are required do this whirl wle wait for the ambulance? >> yes. >> that is just very clear cut. is there anywhere gray area there? because we know chauvin didn't administer cpr. >> there is no gray area. he never even checked to find out if there was a pulse. and so, you know, it is pretty clear that standard in terms of training, dult ofty of care, if have a person in distress and you don't find a pulse, you immediately administer cpr until medics arrive and they perform life saving activities until they can turn it over to a physician. but the police did nothing in this case even though officer lane i believe it was maention f the fact that they needed to roll him over. so there was some concern on part of some of the officers anyway that perhaps mr. floird wa floyd was in distress. but chauvin took no action. >> and laura, to that question, the duty of care as it is known to deliver care in the midst of this, again question of whether the crowd got in the way by distracting the officers, cat calling, et cetera, again, nicole mckenzie was asked and i want to ask you your thoughts. have a listen. >> does it make it more difficult to assess a patient? >> it does. >> does it make more likely that you may missigns that patient is experiencing something? >> yes. >> and so the distraction can actually harm the potential care of the patient? >> yes. >> the it that they are talking about is the crowd. laura, was that convincing testimony, what does that mean for the prosecution's case on that issue? >> it was wholly and entirely unperiph per sway receive. they were not edge ga endaigagi activity that were telling them do something opposite. it this is not that the crowd was so unruly that there were so many distractions that you cannot perform any duty of care. perhaps you relocate, perhaps to check. and the idea to suggest that they were so overwoel helmed by crowd that was not overwhelming and unable to focus on the duty of care owed is belied by the fact that each person in that crowd was imploring them to render aid. emts arrived and somehow with the same crowd brent and all the thought that the person was already dead in that respect, they were able to still focus, provide the care, focus on what they had to do even going beyond that. so why, why was derek chauvin so different from everyone else? what was it about his particular state of mind, his particular role that made it such that he could not seem to focus, could not provide any care. and notice, it may be more difficult, but it wasn't impossible to do so. and i ask everyone, if you were to tell you check your pulse, move your knee, these are very minimal gestures that you have to make. so why was that even overwhelming to do on that street that day. >> how significant to you that none of the officers that have been called to testify yet, whether in director cross-examination, have conceded at all that the actions of officer chauvin were in line with training or protocol? >> that is because these being as actions weren't in line with protocol. you can't defend what he did. so you see officers appearing talking about the policy, talking about the training. and the fact that what he did or failed do is not consistent with policy. and so i'm not surprised at all. i mean, this is not even borderline, not even close where you could give him the benefit of the doubt. so you won't get any testimony. now, the defense will surely find somebody to come in and do the would have, could have, should have, what if this and what if that sort of thing. but again, it will be very difficult to overcome that video because the video is very clear, there was no action taken on 9 part of chauvin and he was the senior oifrn. rem officer. and remember, two of those officers were rookies and even one of them had the sense to know that maybe we should roll this by over. so it will be hard to overcome that. >> thank you both very much. we'll take you live inside the courtroom since the first witness takes the stand. cnn is learning that some states might take until the end of the year to get everyone vaccinated? 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because the situation was far more dire a number of weeks ago and california of course controversial, right, reinstituted a lot of these closed down measures. what made the difference? >> reporter: i think several things have made a difference. if you take a look at where we stand right now, you are looking at the fact that we have hospitalizations that are way down. you look at the fact that we have the virus seeming to be controlled. you look at the number of cases, it is about 2,000 in the state. if you think back to that surge that we had after the holidays, we were about 40,000 cases a day, seeing hundreds of people dying a day. looking at the numbers for yesterday, california reported 7 deaths. there may be a bit of a lag because of the hold day weekend, but the numbers are different. and the other thing that is different is the vaccinations. california has given about -- >> sorry to interrupt. we have to get back to the court room. the expert witness is taking the stand again. >> you testified about 2floyd's resuck labs reluctance to get i squad car? >> yes. >> and you said that he went to the ground and said thank you to the officers? >> yes. >> and it was at that point that the officers pushed flat on the ground into the prone position and you saw mr. floyd kick with one leg while being pushed prone, is that right? >> yes. >> and i believe your testimony is that reasonable officer could have interrupted that kick as active resistance? >> yes. >> i'd like to have you pick up your testimony there. now, sir, making notes of the various times at which things occurred, like to define some of our restraint period, okay? >> yes, sir. >> now based on your review of the body born camera footage and using officer king's footage as a point of reference, can you tell the jury at what point in time in your opinion does the restraint itself begin? >> based on my review of the body worn video, the restraint started at 20:19:14. >> and when does the restraint period end? >> i believe it was 20:28:43. >> and so what is that time restraint period? >> 9 minutes and 29 seconds. >> in your opinion, does the defendant's use of force during that time period need to be reasonable within the entire time period? >> yes. >> have you been able to determine what specific force the defendant applied to george floyd during the restraint period, as in his body position? >> yes. >> and if i could publish exhibit 17. you've already reviewed that. and i believe you indicated that exhibit 17 shows how the defendant was positioned on george floyd. i'll ask you to give some additional detail in that regard based on your analysis, all right? >> yes, sir. >> so at this time, i would like to display to the witness only exhibit 254 for identification. sir, does 254 appear to be a composite of various photos? >> yes. >> could you please at a high level explain what these different photos show starting from upper left to the right and then down. >> upper left photo shows the beginning where the defendant and the other officers removed mr. flid from the police vehicle and were placing them in the prone position. >> and the source of that photo? >> i believe that it was the building camera that was across the street. >> milestone? >> yes. >> and then on the upper right? >> the upper right picture depicts when the emergency medical services responded and they were about to put mr. floyd on to the gurney. >> amgdnd the lower portion? >> that shows the defendant with his knee on mr. floyd's neck and also his left knee on mr. noticed's neck and his right knee on mr. notice's back. >> and the middle? >> middle photo shows the defendant with his left knee on mr. floi's neck. >> and then the final photo? >> the final photo shows the defendant with his knee on mr. floyd's neck and lower neck area as well as his right knee on the back of mr. floyd. >> and would tuse of this exhibt assist you in explaining your analysis of the specific force used by the defendant on mr. floyd during the restraint period? >> yes. >> i'll offer exhibit 254. >> any objection? >> no objection. >> 254 is received. >> let me ask you to publish exhibit 254. and now i'd like you to just in more detail if we could take exhibit 204 and enlarge the upper left photo, first photo, and again this is the milestone footage, is that right? >> yes. >> and the time stamp is 8:19:17. >> yes. >> could you please explain what this shows relative to your analysis? >> relative to my analysis, it shows when the officers initially removed mr. floyd from the vehicle and they placed him in the prone position and they were utilizing body weight to control him. >> and focusing on this individual, is that the defendant? >> yes, sir. >> and are you able to then make out the relative position in his legs relative to mr. floyd in that photo? >> yes. it appears that his knees are in a position where he is utilizing body weight, his left knee being in the neck area of mr. floyd and his right knee being in the back area. >> let's move to the next photo -- i'm sorry, the photo in the lower left. so right beneath that. and please describe what you see here? >> here i believe that the defendant's left knee is on mr. floyd's neck and his right knee is on his back area. >> and if you could use the stylus and place a circle around the left knee of the defendant. and now on the right knee of the defendant. ba based on your review, does this show the relative position of the defendant's knees during the entirety of the restraint period? >> yes. >> you can take that down. now the middle photo, a different think a willing of the angle of the defendant's left knee? >> yes. >> and can you notice anything about the position of his feet? >> his feet are spread apart and on the ground. >> based on your experience and training, where would the majority of the defendant's body weight be given the position of the left knee, the right knee and the feet? >> that would be on his knees and pushing down from his knee area from his body. >> and you can take that down. and this time stamp is at 8:27:49. this is from the milestone video, is that right? >> yes. >> what does this moment in time show? >> this shows the defendant still on mr. floyd and the ems personnel going over to survey what was going on. >> this is shortly before the end of the restraint period. >> yes. >> and were you able to observe the relative position of the defendant using the milestone video from the start of the restraint period to this point? >> yes. >> and did it change? >> no. >> you can take that down, please. all right. and then the last photo lower right, this is from king's body worn camera. why why. >> yes. >> and this is at what you have defined as the end of the restraint period. >> yes. >> and can you please describe to the jury what you see here relative to the defendant's leg position? >> yes, tdefendant's left knee s still on mr. floyd's neck or neck area and his right knee is on his back area. >> and you can take that down, please. and so based on your review, of all of the camera footage, the defendant's body position with respect to that particular force did not change during the entire restraint period? >> correct. >> sir, i ask if you observed the defendant on a body worn camera apply any other type of force upon george floyd other than what you saw with respect to his legs. and body weight. >> yes. towards of beginning of the original restraint, mr. -- correction the defendant used his right hand and he was attempting -- appeared to be attempting to use a pain compliance on mr. floyd's left hand. >> at this time i'd like to publish exhibit 255 which i believe is in evidence. using exhibit 255, can you please explain to the jury, and if the stylus would help, you can use that. >> yes. so here you can see the defendant's right hand grasping the fingers of mr. floyd's left hand. it appears to be squeezing them. >> and you use that term pain compliance. can you describe what that means? >> yes. pain compliance is a technique that officers use to get a subject to comply with their commands as they comply, then they are rewarded with the reduction of pain. >> and how would this positioning induce pain? >> this can induce pain a couple of ways. either by squeezing of the fingers and bringing the nk knuckles together or also basically pulling the wrist in to the handcuff which can cause pain as well. >> and you can see on exhibit 255 where mr. floyd is handcuffed? >> yes. >> you can please put a circle around that? so is if your testimony then that the drawing of the fingers down and the wrist down toward the handcuffs could induce pain? >> yes, especially because the handcuffs were not double locked. double locked meaning that they were not -- they could continue to rasp tchet tighter as the pen moved. >> were you able to hear instances of what you would call ratcheting during your review of the body worn cameras? >> yes. >> and so if i'm to understand your testimony, you would inflict pain for the purpose of having the subject obey your command? >> yes. comply. >> and what if there is no opportunity for compliance? >> then at that point it is just pain. >> you again observed the entirety of the body worn camera footage. did you see whether the defendant discontinued the use of the pain compliance technique during the restraint period that you've defined? >> yes, i did, and no, he did not. >> you can take that down please. sir, i previously testified about the graham versus connor factors, the three different factors you used in your analysis? >> yes, sir. >> and your review of the minneapolis police department policy, does the minneapolis police department integrate these graham connor factors into its procedure manual? >> yes. >> you testified as to these factor, at least one of them, the being as prior to the restraint period. i'd like you to now focus on the restraint period itself. >> being on. okay. >> and if we could publish exhibit 217. i believe this is page two. high light the three bullets. all right. this is from the use-of-force policy and procedure manual? >> yes. >> and you see the different graham versus connor factors outlined here that you previously testified about? >> yes. >> and you've already spoken the first factor the severity of the crime at issue. did that change during the restraint period? >> no. the crime was still that mr. floyd was in possession of a fake $20 bill. >> so i'd like you to focus on the second factor, that is whether mr. floyd posed an 3450e immediate left to the safety of the officer or others. >> no, he did not. >> why? >> because he was in the prone position, he was handcuffed, he was not attempting to resist or assaults the officers, kick, punch or anything of that nature. >> did he ever communicate an intent to do so? >> no, he did not. i didn't hear any verbalization of any threat towards the officers. >> did he ever indicate whether or not he had the ability to do so? will. >> no, he did not. >> you can comment as to the number of other officers on the scene at the time and how that would relate to any opinion you have regarding whether mr. floyd presented a threat? >> yes. another factor that is considered when evaluating use of threat is the number of officers versus the number of subjects. in this instant, there were five officers on scene, three that were using body weight on mr. floyd and there were two additional officers that were on scene as well. >> and in terms of the threat, there is a scripter here and that is that it needs to be an immediate threat. >> correct. >> and sonalysis, mr. floyd would need to be able to presently cause some sort of harm? >> yes, immediate meaning that it is happening right now. >> now, focusing on the third factor, and that is whether mr. floi wa floyd was attempting to evade by threat, can you talk about that third factor? >> becausebased on my analysis, floyd was not resisting in the prone position nor did he communicate to them that he was attempting to resist our evade them. >> are you familiar with the concept of proportionality? >> yes, i am. >> can you please explain that concept as it relates to the use of force? >> yes, proportion naturality basically means that an officer is only allowed to use a level of force that is proportional to the seriousness of the crime or the level of resistance that the subject is using. towards the officers. >> are you familiar with a graphic known as a force continuum that can be used to illustrate this point? >> yes. >> and does the minneapolis police department use a similar item of force continuum to illustrate this point to its officers? >> yes, they do. >> and if i could publish exhibit 110. is this the force continuum that mpd uses? >> yes, sir. >> and if you could take that down. and exhibit 119 is an exhibit to illustrate this concept and i'll ask that that exhibit be published at this point. >> no objection, your honor. >> all right. sir, we're publishing exhibit 919. and what i'd like you do is walk the jury through the concepts of proportionality using 919 de demonstrative to explain. >> and if you look on the far left, you see the subject's behavior. it starts off being active aggression, then active resistance, and then passive resistance. and at the top, if the subject he'd behavior is active aggression, if it could cause serious injury or death, then the officer is allowed to use deadly force. and moving down, if the subject's actions don't meet the deadly force threshold, then an officer is allowed to use a baton. and also stunning strikes and unconscious neck restraint. stunning strike is a type of force that an officer can use when he is being assaults order to temporarily stun the person to try to trcontrol them. and unconscious neck restraint i believe is whenorder to temporarily stun the person to try to control them. and unconscious neck restraint i believe is when using a neck restraint to temporarily make the person unconscious. moving down, as the subject's behavior is less aggressive, moving closer to active resistance, you see an officer is allowed to use a ced, which is a conducted electronic device or is known as a taser or a pepper spray. if the subject behavior doesn't meet that threshold, then an officer can utilize distraction technique, and that is typically similar to a stunning strike but basically a distraction technique is used to temporarily stun the person in order to follow up with another technique to possibly take them down to the ground or use to control them as well. obviously you have a control takedown as well. and a conscious neck restraint to control the person based off of their active resistance. moving down, if the subject's behavior is passive resist tarng ance, then they can yuse other forces in the field. and lastly verbal staigs and jand just the officer's presence when the person is complying or just passively resisting just verbally. >> and if no resistance is offered? >> then just your presence. >> sir, do you have an opinion to a degree of reasonable professional certainty to how much force was reasonable for the defendant to use on mr. floyd after mr. floyd was handcuffed, placed in the prone position and not resisting? >> yes. >> and what is that opinion? >> my opinion is that no force should have been used once he was in that position. >> i see on this continuum the phrase deadly force. is deadly force defined? >> yes. >> is it confined in minneapolis police departmental policy? why yes >> yes, it is. >> i'd like to publish exhibit 216 and if you could move to page two calling out the definition of of deadly force. sir, could you read into the record for the jury what the definition of deadly force is beginning at force which the actor uses? >> yes. force which the actor uses with the purpose of causing or which the actor should reasonably know really krcreates a substantial risk of causing death with great bodily harm. >> i'd like to now republish exhibit 254, the com positive it. and this is the for the applied. i'll ask you, sir, do you have an opinion to a degree of reasonable professional certainty whether the force used as shown in exhibit 254, whether that force being applied then for the resfrant perestraint period would constitute deadly force? >> yes gl. >> and what is that opinion? >> that it would. >> and why is that? >> because he was in the prone position, he was not resisting, he was handcuffed, he was not attempting to evade, he was not attempting to resist. and the pressure that he was -- that was being caused by the body weight could cause positional asphyxia which could cause death. >> is positional asphyxia a known risk in law enforcement? >> yes, it is. >> how long have the dangers of positional asphyxia been known? >> at least 20 years. i can recall a department of justice memo from i believe 1995 that discussed it and i know that i was trained on it in 1995 as well. >> and the risk or the danger of positional asphyxia is the outcome of death? >> yes, sir. >> and when we talk about positional asphyxia and the risk is that risk increased with the increase of pressure on the subject? >> yeah. so propositional asphyxia can or even if there is no body weight on a subject. just being in that position and especially being handcuffed creates a situation where the person has a difficult time breathing which can cause death. when you add body weight to that, then it just increases the possibility of death. >> and what additional weight did you see in your analysis here? >> the defendant's body weight as well as the two other individuals, the two other officers. >> and one of the other officers appeared to be pressing down on mr. floyd? >> yes. >> was that officer king? >> yes. >> and what was officer lane doing? >> he was holding his legs. >> sir, in applying the rules of the use of force and use of reasonable force, the officer has to consider the totality of circumstances, is that right? >> yes, sir. >> and one of the circumstances can be the location, that could be important, is that right? >> yes. >> and are you aware that there was a group of bystanders who eventually began to watch the defendant achnd the other offics use force on mr. floyd? >> yes. >> in your experience with the los angeles police department and in the areas that you were patrolling, have you ever had to use force or apply force or handcuff a suspect in view of bystanders? >> yes, sir. >> have you ever had to handcuff an unwilling suspect in the view of bystanders? >> yes, sir. >> have you ever had to do so in the presence of a hostile crowd? >> yes. >> could you define hostile crowd? >> i would define loss still crowd in the situations i've been in where the crowd or members of the crowd were threatening and/or throwing bottles and rocks at the police. >> have you had that experience? >> yes, sir. >> on more than one occasion? >> yes. >> so if i could publish exhibit 184. getting back to the circumstances of this case. this appeared to be bystanders that were gathered watching the defendant apply force to mr. floyd. >> yes, it does. >> did you see anybody throw any rocks or bottles? >> no, i did not. >> did you see anyone attack, physically attack, the officers? >> no, i did not. >> did you hear foul language or name call something. >> there was some name calling, and some foul language, but that was about the most of it. >> did that factor into your analysis? >> no. d . >> why not? >> because i did not perceive them as being a threat. >> and why is that? >> because they were merely filming and they were -- most of it was their concern for mr. floyd. >> is the officer able to increase the for the on someone based on a third party? >> no, only based on the subject's act.the on someone based on a third party? >> no, only based on the subject's act. >> can loud noise and name calling be ddisdistracting? >> yes. >> and what so what does the officer do in that case? >> they continue to assess the force or they would attempt to lower any type of threat level that they may perceive. >> and based on your review of the materials and on records as of may 25, 2020, how long had the defendant been a minneapolis police officer? >> approximately 19 years. >> and if we can publish exhibit 203. and if you could highlight the top portion. these appear to be workforce training records of the defendant? >> yes. >> and it indicates approximately 866 hours? >> yes. >> of paid training. >> yes. >> do you think that should have been sufficient training to prepare the defendant for this distraction? >> absolutely. >> you can take that down, please. >> you do acknowledge that it would be possible for a loud group to distract the defendant from being attentive to george floyd? >> yes. >> do you believe that occurred? >> no, i do not. >> why is that? >> because in yo the body worn video, you can hear mr. floyd displaying his discomfort and pain and you can also hear the defendant responding to it. >> at this time i'd like to publish exhibit 47. andbly bring us to the point o 20:22 20:2 20:22ment 23. i'd like to play it for the jury. >> water or something. i can't breathe, officer. aah! >> is that the exchange of the defendant responds to statements of mr. floyd? >> yes, sir. >> and approximately how long did the defendant continue to restraint george floyd after the exchange we just heard? >> i believe six minutes. >> that you think. i have no further questions. >> mr. nelson. >> good morning, sergeant stiger. thank you for being here. did you enjoy the rain last night? >> yes. >> a little different than california. >> yes, we don't get that much in california. >> right. sergeant, i have a few questions first and foremost about your experience. have you ever previously testified in any court or in any or federal court as an expert on the police use of force? >> no i have not. >> have you ever been qualified by any court as an expert in the use of police force? >> yes. >> where? >> in los angeles during a trial use of force that i was the investigator for. >> is that the only time in that case? >> yes. >> and you are here in your own personal capacity? >> correct. >> you are not here as a representative of either the los angeles police department or officer of inspector general? >> correct. >> the training that you have experienced and that you have conducted, that has all been by the los angeles police department, correct? >> yes. >> so the training that you received to become a police officer, that is primarily conducted by the los angeles police department, correct? >> yes. >> and you may have gone to some outside vendor training, but those had to be approved by the los angeles police department? >> yes. >> meaning the training that you attended outside of lapd stuff would have to be consistent with los angeles police department's policies? >> not necessarily, no. they have to be in compliance with california post. >> okay. now, you would agree that the policies of the los angeles police department are their policies, correct? >> correct. >> and the policies of every police department are going to be different to some degree? >> to some glome degree, yes. >> and some police departments may authorize a particular form of force while others different 1234. >> to a certain steextent, yes. >> and that is a question of the reasonableness. one department may say that is not a reasonable use of force and another may say this is reasonable use of force? >> based on my training and experience, every agency that i've seen base it on graham versus connor. so it is pretty standard. >> right. but in terms of the actual tactics of the use of force, right? so a department may authorize their use of a particular too many and another department may not authorize that too many. >> correct. >> and thus both uses of force or potential uses of force, and the instruments to use that force may be different. >> yes, but they all have to fall into the standards. >> understood. but one department could determine that that type of an technique is reasonable while another department may not. >> correct. >> so another way of saying that reasonable minds can differ. >> correct. >> you've testified that you have been a trainer for the los angeles police department. >> yes, sir. >> so when you talk about your training experience, are you doing it from like you are teaching, lecturing, or are you doing the training on the mats straining the techniques or both? >> both. >> you've never been trained by the minneapolis police department? >> no, i have not. >> but upon being hired in this case, you received a lot of materials in this case? >> yes, i did. >> and you received an extensive amount of minneapolis police department training materials, right? >> yes. >> and you received investigative reports? >> yes. >> from the bureau of criminal apprehension. >> yes. >> and you received video cameras or videotapes? >> yes. >> and you received materials within the training materials that also contained like videos or examples and i will husband twra difference type of materials as part of the training materials? >> i don't quite understand. >> sometimes there is a video embedded in a power point and that video is an example of a specific move or it may be training exercises or the scenario based trainings. did you see all of those? >> no, i did not. i wasn't able to. because most of the power paint presentations were pdf forms so i was not able to view the videos. >> so you have not seen the training videos prepared by the minneapolis police department? >> yes. >> but all of this material that you received is what you used in part to form your opinions in this case? >> yes, sir. >> you relied on those materials to a certain extent? >> yes. >> and? of those materials were completely irrelevant to this case, agreed? >> yes. >> such as use of the taser, right? >> yes. >> such as the mounted patrol unit, right? >> yes. >> but you received other information that was informative and had an effect on your analysis, agreed? >> yes. >> so those training materials were an important part of how you came to form your opinion? >> yes. >> now, you actually prepared a written report, correct? >> yes, i did. >> and in your written report, you detailed your opinions and findings on the case, correct? >> yes, sir. >> and you also made an exhibit of the materials that you reviewed? >> yes. >> would you agree that your report in total is 461 pages? >> yes. >> i have it here. 461 pages. >> yes. >> of the 461 pages, 26 pages constitute your opinions? >> yes. >> and from page 27 to 461, this is a list of the tirls thof the you reviewed? >> that i received. >> and you reviewed some but not all of these material ssmateria? >> correct. >> ultimately what you concluded that you received a total of 57. different training materials or items to review. >> i don't know the exact number, but if -- >> the last number in your list is 5737, would you dispute that? >> i would have to look at it, but i would -- i wouldn't disagree. >> in addition to your analysis, you are relying on your own training, right? >> yes. >> our own experience as a police officer, right? >> correct. >> your experiences doing both f peer review of use of force with the los angeles police department and your investigation of uses of force, correct? >> correct. >> and you ultimately submitted your report to the state of minnesota on january 31 of this year. >> i believe so, that's correct. >> and since you have submitted your report, have you received any additional information investigative or otherwise about this case? >> no. >> so any training materials that came to us prior -- excuse me, subsequent to january 31, any investigative foreign that was received, you have not had an opportunity to review that? >> correct. >> and you have had several conversations with prosecutors in connection with this case? >> correct. >> i believe that you met with prosecutors or conversed with prosecutors february 1 of this year, march 3 of this year, march 11th of this year and april 3 of this year. would you dispute me? ? >> i would have to look at my calendar, but, no, i believe that that is correct. >> can we have a side bar? >> and we have all been watching together. more testimony, more witness testimony, this, an lapd sergeant who is a use of force expert again on the stand for a second day in the trial of derek chauvin. just a quick side bar and let's jump back in. >> you and i have never met or spoke? >> correct. >> but you are aware that prosecutors gave me summaries of knows meetings? >> yes. >> and you testified yesterday that in your roam le with the l angeles police department and office of inspector general, you have reviewed thousands of use of force cases? >> yes. >> and it is fair to