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Speaker 1: Crime Stories with Nancy Grace. Page one. Alec Baldwin probable

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Speaker 1: Cause Statement, State of New Mexico, County of Santa Fe,

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Speaker 1: First Judicial District Court, State of New Mexico, Plaintiff versus

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Speaker 1: Alexander Ray Baldwin, the third defendant Statement of probable cause

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Speaker 1: background synopsis. On October twenty one, twenty twenty one, in

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Speaker 1: the County of Santa Fe, State of New Mexico, a

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Speaker 1: shooting involving a handgun revolver firearm occurred that resulted in

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Speaker 1: the death of Helena Hutchins and the serious injury of Joelsuza.

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Speaker 1: The shooting involved a forty five caliber revolver and occurred

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Speaker 1: on a western movie set located in rural Santa Fe County,

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Speaker 1: referred to and known as Bonanza Creek Ranch, fifteen County Road,

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Speaker 1: forty five, Santa Fe, New Mexico eight seven five year

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Speaker 1: oh eight five forty five Bonanza Creek Ranch Road on

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Speaker 1: this date being filmed and or rehearsed at this location

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Speaker 1: was a film at the time named referred to as Rust.

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Speaker 1: Through interview statements and evidence, it was learned that defendant

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Speaker 1: Alexander Alec Baldwin here and after Baldwin was the lead

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Speaker 1: actor in the film. Through these statements, interviews, and evidence,

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Speaker 1: it was determined that after lunch on October twenty first,

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Speaker 1: twenty twenty one, their crew, production staff, camera crew, and

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Speaker 1: actors were preparing for a scene set in the church.

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Speaker 1: This was not an established rehearsal, nor had filming commenced

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Speaker 1: at this point. Baldwin was seated in what is referred

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Speaker 1: to and appears to be a church. On this movie set,

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Speaker 1: Baldwin was in possession of a forty five long cult

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Speaker 1: caliber revolver type firearm, one of a type and kind

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Speaker 1: often used and or seen in or on Western genre

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Speaker 1: type movies and or sets. The firearm is a single

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Speaker 1: action revolver handgun which requires the cocking of the exposed

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Speaker 1: which then rotates the cylinder, and then the pressing of

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Speaker 1: the trigger is required to fire the weapon. In front

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Speaker 1: of Baldwin standing were victims Helena Hutchins and Joel Susa.

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Speaker 1: Hutchins and Susa were viewing and moving a camera for

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Speaker 1: a possible setup for a later scene to occur at

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Speaker 1: a later undetermined date and or time. Through these same statements,

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Speaker 1: interviews in physical evidence, it was learned that Helena Hutchins

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Speaker 1: was the director of photography for the film and Joel

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Speaker 1: Susa was the director writer for the film. Information and

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Speaker 1: evidence obtained showed that Baldwin was seated in a pew

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Speaker 1: facing in a northerly direction towards the front of the church.

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Speaker 1: In front of him was Helena Hutchins and page two

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Speaker 1: Joel Susa and a camera operator along with other crew

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Speaker 1: i e. Sound, script, costume, etc. Baldwin was wearing a

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Speaker 1: shoulder holster right hand draw which was securing holding the

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Speaker 1: forty five long Colt caliber single action six shot revolve.

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Speaker 1: Baldwin was practicing drawing and pointing the weapon for the

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Speaker 1: scene with guidance and instruction from Helena Hutchins and Joel Susan.

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Speaker 1: The setup was to be a close up on Baldwin

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Speaker 1: and the firearm as he drew the weapon and pointed it.

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Speaker 1: Helena Hutchins and Joel Susa were reviewing the practice scene

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Speaker 1: on a monitor attached to the camera. Baldwin drew the

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Speaker 1: revolver from the holster, pointed it at Helena Hutchins, and

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Speaker 1: fired the weapon. When reviewing the script and witness interviews

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Speaker 1: for this particular scene and close up shot, evidence indicates

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Speaker 1: the scene shot did not require the weapon to be fired.

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Speaker 1: It was also determined by consultation with expert armorers that

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Speaker 1: in a rehearsal, a plastic gun or a replica gun

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Speaker 1: should be used, as no firing of blanks as required. However,

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Speaker 1: Baldwin fired the single action forty five long cult Revolver,

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Speaker 1: resulting in the discharge of a projectile that struck and

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Speaker 1: traveled through the right armpit area of Helena Hutchins, exited

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Speaker 1: her back from the OMI. Official report then struck Joel

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Speaker 1: Susa in the right shoulder and lodged into his right

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Speaker 1: back At approximately one forty eight PM. The shooting was

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Speaker 1: reported to Santa Fe County Regional Emergency Communications Center via

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Speaker 1: nine one one. This resulted in the response of fire, emergency,

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Speaker 1: medical and Santa Fe County Sheriff's Office personnel. This further

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Speaker 1: resulted in a case number CAD Incident number being generated

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Speaker 1: two zero two one zero zero seven nine four nine.

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Speaker 1: The Santa Fe County Sheriff's Office conducted an investigation into

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Speaker 1: the shooting under this case number as a quote death investigation.

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Speaker 1: UNE Detective Alexandra Hancock was assigned as the primary investigator.

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Speaker 1: The response of emergency personnel resulted in Joel Susa being

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Speaker 1: transported by ambulance to Saint Vincent Regional Medical Center located

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Speaker 1: at four fifty five Saint Michael's Drive within the city

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Speaker 1: limits of Santa Fe, New Mexico. Helna Hutchins was transported

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Speaker 1: from the scene by air ambulance helicopter to the Level

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Speaker 1: one Trauma Center at the Universe City of New Mexico

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Speaker 1: Hospital located in Berna Leio County, Albuquerque, New Mexico. Helena

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Speaker 1: Hutchins was pronounced deceased at approximately three thirty seven PM

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Speaker 1: by attending medical personnel. Joelsuza was treated and released, but

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Speaker 1: not before a projectile was removed from his back. The

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Speaker 1: projectile appeared to be a led projectile of the type

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Speaker 1: and kind found in quote live unquote ammunition. This item

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Speaker 1: was secured and turned over to the Santa Fe County

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Speaker 1: Sheriff's Office. As noted above and confirmed by the evidence

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Speaker 1: and analysis, the recovered projectile first struck and then passed

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Speaker 1: entirely through Helena Hudgins and then struck Joel Susa. There

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Speaker 1: was no evidence that the bullet ricochette struck any object

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Speaker 1: or person before striking Helena Hutchins. The projectile then penetrated

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Speaker 1: through the front of Joelsusa's right shoulder and became lodged

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Speaker 1: under the skin on his back. The Office of the

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Speaker 1: Medical Examiner State of New Mexico listed Helena Hutchins cause

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Speaker 1: of death preliminarily as gunshot wound of the chest after

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Speaker 1: conducting an autopsy on October twenty second, twenty twenty one.

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Speaker 1: The following additional information and evidence is provided in further

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Speaker 1: support of probable cause of the enumerated crimes having been

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Speaker 1: committed by Baldwin. Crime Stories with Nancy Grace page three Firearm,

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Speaker 1: ammunition and Baldwin as actor and shooter. Statements and evidence

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Speaker 1: show Baldwin was not present for required firearms training prior

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Speaker 1: to the commencement of filming. Statements, depositions from motion, and

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Speaker 1: evidence show Baldwin was provided only minimal training on firearms,

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Speaker 1: even after Read requested more training for Baldwin. In the

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Speaker 1: deposition taken from Reach, she stated Baldwin had very limited

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Speaker 1: training on the cross draw that was required for the

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Speaker 1: scene on the twenty first, and limited training in firearms

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Speaker 1: and how to check his own firearm as to whether

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Speaker 1: it was unloaded or loaded, in which Reid felt it

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Speaker 1: was very important in his role as RUST. A training

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Speaker 1: session for at least an hour or more in length

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Speaker 1: was scheduled, but the actual training consisted of only approximately

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Speaker 1: thirty minutes, as according to Reid, Baldwin was distracted and

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Speaker 1: talking on his cell phone to his family during the training.

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Speaker 1: Baldwin approached responding deputies on the day of the shooting,

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Speaker 1: wanting to talk to them because he was the one

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Speaker 1: who quote fired unquote the gun. He was referred to

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Speaker 1: and later interviewed by detectives. Baldwin later asserted that he

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Speaker 1: never fired the revolver and that it had just quote

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Speaker 1: gone off. Baldwin made this assertion public as well in

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Speaker 1: multiple media interviews conducted after the shooting. Many media interviews

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Speaker 1: and law enforcement interviews were conducted by Baldwin, and he

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Speaker 1: displayed very inconstant accounts of what happened during the incident

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Speaker 1: when firing the gun that killed Hutchins. Photo and video

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Speaker 1: evidence from inside the church on the day of the

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Speaker 1: shooting shows some of the rehearsal up to and including

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Speaker 1: moments before the shooting. The photo and videos depict the

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Speaker 1: above described actions of Baldwin prior to the shooting, practicing, drawing,

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Speaker 1: and pointing the weapon. The photos and videos clearly show

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Speaker 1: Baldwin multiple times with his finger inside of the trigger

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Speaker 1: guard and on the trigger, while manipulating the hammer, and

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Speaker 1: while drawing, pointing, and ulstering the revolver. The revolver involved

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Speaker 1: in the shooting was seized by detectives as evidence. It

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Speaker 1: was later submitted to the Federal Bureau of Investigation FBI

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Speaker 1: Crime Lab for examination and analysis. As part of that

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Speaker 1: examination analysis, the FBI conducted a function malfunction check of

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Speaker 1: the revolver. This involved trying to get the weapon to

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Speaker 1: fire without the trigger being depressed, ie striking the hammer

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Speaker 1: at various multiple angles against a solid object, and striking

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Speaker 1: the hammer of the revolver with an actual hammer or mallet.

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Speaker 1: The revolver did not malfunction I fire when it should

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Speaker 1: not accidentally. This analysis clearly showed that the weapon could

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Speaker 1: not accidentally fire. For the weapon to fire, the trigger

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Speaker 1: had to have been depressed pressed. The analysis additionally included

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Speaker 1: testing of and documentation of the seer engagement points of

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Speaker 1: the hammer as it moved from the position of at

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Speaker 1: rest all the way down against the frame in its

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Speaker 1: lowest position through each engagement of the single action hammer mechanism.

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Speaker 1: The firearm possessed one quarter and one half cock position

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Speaker 1: safeties and were found to function as designed I, keeping

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Speaker 1: the hammer from striking a cartridge primer without pulling the trigger. Additionally,

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Speaker 1: at half cock, the cylinder was partially rotated, making it

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Speaker 1: impossible for the hammer and attached firing pin to strike

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Speaker 1: a primer Page four. The FBI additionally analyzed various types

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Speaker 1: and kinds of ammunition seized from the scene, including the

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Speaker 1: prop truck. This included dummy rounds, blank rounds, and suspected

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Speaker 1: live ammunition. A total of five suspected live rounds one

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Speaker 1: spank casing of a live round that was discharged causing

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Speaker 1: the shooting were seized by investigators. Evidence and statements indicate that,

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Speaker 1: aside from what Hannah Gautier has read, Armor Rust production

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Speaker 1: may have brought to the set with her, all weapons

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Speaker 1: and ammunition blank dummy for the production were obtained from

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Speaker 1: a supply company in Albuquerque. PDQ Arms and Prop LLC

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Speaker 1: detectives investigated these facts, including service of a search warrant

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Speaker 1: at the place of business of PDQ Arms and Prop

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Speaker 1: in Albuquerque, who was the supplier of the dummies and

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Speaker 1: blanks to rust. Several suspected live rounds of forty five

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Speaker 1: long cult caliber cartridges were seized as a result, some

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Speaker 1: supplied by the company owner to the investigators and some

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Speaker 1: found at the place of business. These rounds were submitted

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Speaker 1: to the FBI for comparison with the suspected live rounds

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Speaker 1: found at the shooting scene. The explosives chemistry examination of

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Speaker 1: the rounds showed that the smokeless powder in the live

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Speaker 1: rounds found at the scene did not match the live

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Speaker 1: round sees from the prop's arms supplier in question. This

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Speaker 1: means the live rounds on rust did not match the

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Speaker 1: rounds explosive chemistry taken from PDQ Arms I PROP. The

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Speaker 1: FBI lab determined that the five suspected live rounds recovered

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Speaker 1: at the scene of the shooting were indeed quote live

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Speaker 1: unquote rounds, each possessing an unfired primer, powder and bullet

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Speaker 1: as part of the cartridge. These five rounds were found

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Speaker 1: by detectives and crime scene technicians while processing the scene.

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Speaker 1: The five unfired rounds were found in the following locations,

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Speaker 1: one from SFSO Lieutenant Ben Venita's patrol vehicle that he

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Speaker 1: had seized from Read upon his arrival, two from the

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Speaker 1: top of the armorer's cart, including the one spent live

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Speaker 1: round casing, one from a bandalier on the cart, one

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Speaker 1: from Baldwin's holster located inside the church, one from an

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Speaker 1: ammunition box located on the armorer's cart. Along with the

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Speaker 1: casings and fired projectile, there were a total of six

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Speaker 1: forty five quote live unquote rounds that were discovered in

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Speaker 1: various locations on the rust set. Evidence further shows that Baldwin,

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Speaker 1: as an actor who has extensive experience in the film

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Speaker 1: industry involving firearms, failed to demand at least two safety

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Speaker 1: checks in between the armor and himself and witnessing the

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Speaker 1: handling of firearms by a first assistant director. Standard protocol

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Speaker 1: is the armorer is to show the actor the firearm,

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Speaker 1: pull the bullets out in front of the actor and

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Speaker 1: demonstrate there are no live rounds but dummies in the firearm.

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Speaker 1: Baldwin knows this is standard safety protocol, as he has

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Speaker 1: mentioned it in media interviews and in law enforcement interviews.

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Speaker 1: Hannah Gautierre is read here and after Reid did not

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Speaker 1: do this protocol in front of Baldwin, Baldwin did not

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Speaker 1: object to this action. Read discusses in her interviews with

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Speaker 1: OSHA and law enforcement, this shouldn't have occurred. Reid also

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Speaker 1: acknowledges in her interviews she should have been in the

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Speaker 1: church with the firearm at all times. Instead, she left

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Speaker 1: the church while Baldwin was in possession of a firearm

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Speaker 1: in close proximity to the cast and crew. Baldwin further

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Speaker 1: acknowledges that it is standard protocol for armors to stay

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Speaker 1: with the firearm at all times in the media and interviews. Finally,

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Speaker 1: Baldwin directly pointed a firearm at Hutchins and SUSA, whether

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Speaker 1: guided by her directions or not. Baldwin knew the first

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Speaker 1: rule of gun safety is never pointing a gun at

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Speaker 1: page five someone you don't tend on shooting. In addition,

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Speaker 1: always assume a gun is loaded. Had Baldwin performed the

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Speaker 1: required safety checks with the armorer, Read, this tragedy would

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00:14:10,640 --> 00:14:14,880
Speaker 1: not have occurred. In addition, if Baldwin had not pointed

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Speaker 1: the gun at Hutchins and SUSA, this tragedy would not

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00:14:18,760 --> 00:14:23,440
Speaker 1: have occurred. This reckless deviation from known standards and practices

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Speaker 1: and protocol directly caused the fatal shooting. By not receiving

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Speaker 1: the required training on firearms, deviating from the required duties

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00:14:31,920 --> 00:14:35,560
Speaker 1: of checking the firearm with the armorer, letting the armorer

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00:14:35,760 --> 00:14:39,520
Speaker 1: leave the church against protocol, deviating from the practice of

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Speaker 1: only accepting the firearm from the armorer, not dealing with

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00:14:43,720 --> 00:14:47,520
Speaker 1: safety complaints on the set, not making sure the protocol

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00:14:47,560 --> 00:14:51,200
Speaker 1: of safety meetings was occurring, putting his finger on the

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00:14:51,240 --> 00:14:54,720
Speaker 1: trigger of a real gun, not using a replica for

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Speaker 1: our arm for the unscheduled rehearsal, pointing the gun at

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Speaker 1: Hudgins and SUSA, and overall handling of the firearm in

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Speaker 1: a negligent manner. Baldwin acted with willful disregarded the safety

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00:15:06,160 --> 00:15:09,320
Speaker 1: of others, and in a manner which endangered other people,

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Speaker 1: specifically Hutchins and SUSA. Baldwin clearly should have known of

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Speaker 1: the danger of his actions, which led to the death

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Speaker 1: of Hutchins. Baldwin as producer, industry standards, best practices, common practices,

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Speaker 1: historical practices, policies and or procedures, and Union guided policies

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00:15:27,400 --> 00:15:31,440
Speaker 1: and or procedures require and or mandate certain members of

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Speaker 1: a filming crew have assumed or are assigned certain obligations

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00:15:35,680 --> 00:15:40,760
Speaker 1: and responsibilities industry experts and or armorers were consulted for

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00:15:40,920 --> 00:15:44,880
Speaker 1: information and evidence in this industry. Baldwin asserted and is

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00:15:44,920 --> 00:15:48,520
Speaker 1: clearly shown to be a producer on this particular film

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00:15:48,600 --> 00:15:52,760
Speaker 1: based on his position. Baldwin, through acts and or omissions,

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00:15:52,840 --> 00:15:57,160
Speaker 1: contributed to or failed to mitigate or address multiple significant

243
00:15:57,200 --> 00:16:01,600
Speaker 1: safety violations, issues, and or concerns that resulted in multiple

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00:16:01,680 --> 00:16:05,960
Speaker 1: noted instances of recklessness leading up to, contributing to, and

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00:16:06,480 --> 00:16:11,200
Speaker 1: causing the shooting. Since the shooting, Baldwin has asserted publicly

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Speaker 1: that he is an expert in the realm of firearms

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00:16:14,440 --> 00:16:19,280
Speaker 1: and filmmaking. Investigation has revealed that Baldwin has been involved

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00:16:19,280 --> 00:16:22,960
Speaker 1: in at least forty films or TV productions that involve firearms,

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00:16:22,960 --> 00:16:27,000
Speaker 1: with Baldwin either directly handling firing a weapon, or in

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00:16:27,040 --> 00:16:31,240
Speaker 1: a scene with firearms being directly handled and or fired

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00:16:31,280 --> 00:16:35,400
Speaker 1: by someone else. Further investigation of this list revealed a

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00:16:35,560 --> 00:16:39,240
Speaker 1: multitude of instances, either from the movie itself or from

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Speaker 1: the movie poster, showing Baldwin with his finger in the

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00:16:42,600 --> 00:16:46,640
Speaker 1: trigger guard and on the trigger in instances where according

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00:16:46,640 --> 00:16:49,960
Speaker 1: to industry standards and common firearms safety standards it should

256
00:16:49,960 --> 00:16:53,960
Speaker 1: not have been. Experts industry standards and basic firearm safety

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00:16:54,000 --> 00:16:59,120
Speaker 1: protocols and training. Consider this reckless behavior requiring immediate remediation.

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00:17:00,480 --> 00:17:04,480
Speaker 1: Shows Baldwin failed to appear for mandatory firearms training and

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00:17:04,600 --> 00:17:08,639
Speaker 1: firearms safety training prior to filming. Evidence also shows that

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00:17:08,760 --> 00:17:13,280
Speaker 1: Baldwin requested and was afforded a training session on set

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00:17:13,480 --> 00:17:16,560
Speaker 1: and that through statements, the training was estimated to be

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00:17:16,640 --> 00:17:19,520
Speaker 1: thirty minutes in length due to the distraction of him

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00:17:19,560 --> 00:17:22,680
Speaker 1: talking to his family on his cell phone during the training.

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00:17:23,240 --> 00:17:26,640
Speaker 1: The onset and limited time of training does not comport

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00:17:26,680 --> 00:17:30,560
Speaker 1: to industry standards, and evidence shows Baldwin was in a

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00:17:30,600 --> 00:17:34,800
Speaker 1: position to manage oversea come ins and require safety training

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00:17:35,040 --> 00:17:40,040
Speaker 1: too industry standards. Baldwin's failure to ensure minimum standards were

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00:17:40,119 --> 00:17:46,040
Speaker 1: met is considered reckless in the industry. Page six. Basic

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00:17:46,119 --> 00:17:51,000
Speaker 1: firearms safety protocols and industry standards are provided during this training,

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00:17:51,119 --> 00:17:55,359
Speaker 1: which includes basic firearms safety rules and mindset, including but

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Speaker 1: not limited to, not touching pressing the trigger until the

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00:17:59,280 --> 00:18:01,960
Speaker 1: shooter is to fire and is sure of his or

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00:18:02,000 --> 00:18:05,320
Speaker 1: her target, treating all firearms as if they are loaded,

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00:18:05,400 --> 00:18:09,320
Speaker 1: and not covering anything with the muzzle of a firearm.

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00:18:09,359 --> 00:18:13,200
Speaker 1: The shooter is not willing to destroy. The Evidence clearly

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00:18:13,240 --> 00:18:18,280
Speaker 1: indicates that Baldwin recklessly ignored those rules on multiple occasions,

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00:18:18,320 --> 00:18:22,960
Speaker 1: resulting in the fatal shooting. Evidence shows that the production

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00:18:23,000 --> 00:18:26,400
Speaker 1: company hired Read as the lead armorer for the production.

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00:18:26,840 --> 00:18:31,200
Speaker 1: Evidence shows that Reid possessed no certification or certifiable training

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00:18:31,320 --> 00:18:35,120
Speaker 1: or union card for this practice, and that she admitted

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00:18:35,160 --> 00:18:37,960
Speaker 1: she was the armorer for only one film prior to

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Speaker 1: this production, approximately in April of twenty twenty one, as

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00:18:42,280 --> 00:18:45,840
Speaker 1: the producer of a firearm intense film. Evidence shows that

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Speaker 1: Baldwin allowed, through axtra omissions, the hiring of an inexperienced

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00:18:50,640 --> 00:18:55,040
Speaker 1: and unqualified Read for this production, failed to mitigate or

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00:18:55,200 --> 00:18:59,040
Speaker 1: establish more precautions to protect against reads and experience, or

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00:18:59,520 --> 00:19:03,199
Speaker 1: failed to demand the minimum safety standards, protocols and requirements

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00:19:03,200 --> 00:19:06,800
Speaker 1: on set. Reid was assigned by a production to be

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00:19:06,920 --> 00:19:10,240
Speaker 1: an assistant prop master in addition to her armorer duties.

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00:19:10,560 --> 00:19:14,479
Speaker 1: Evidence shows that this resulted in Read not focusing her

291
00:19:14,640 --> 00:19:19,080
Speaker 1: entire attention on her primary responsibility as armorer. Evidence shows

292
00:19:19,320 --> 00:19:24,240
Speaker 1: Baldwin violated industry standards and practices by allowing this reckless

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00:19:24,280 --> 00:19:28,399
Speaker 1: and generally prohibited practice, resulting in reckless actions. Taking place

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00:19:28,520 --> 00:19:32,000
Speaker 1: prior to and on the day of the shooting. Evidence

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00:19:32,040 --> 00:19:34,960
Speaker 1: shows that Sarah Zachary was hired as the prop master

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00:19:35,080 --> 00:19:38,160
Speaker 1: for the production. It also shows that she was assigned

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00:19:38,200 --> 00:19:42,000
Speaker 1: to assist Read with her armoring duties. Evidence and statements

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00:19:42,000 --> 00:19:46,040
Speaker 1: show that Sarah Zachary possessed little to no experience with firearms,

299
00:19:46,119 --> 00:19:51,000
Speaker 1: firearms safety, armorer duties and responsibilities, etc. It also shows

300
00:19:51,000 --> 00:19:54,960
Speaker 1: that Sarah Zachary was assigned to allowed to load and

301
00:19:55,080 --> 00:19:59,480
Speaker 1: unload ammunition in firearms, handle firearms, and act as an

302
00:19:59,600 --> 00:20:04,159
Speaker 1: armor went on set with actors doubles taking possession of

303
00:20:04,160 --> 00:20:08,360
Speaker 1: the firearms. Evidence shows this was done multiple times and

304
00:20:08,520 --> 00:20:11,960
Speaker 1: without Read being on the set as well. Evidence shows

305
00:20:12,000 --> 00:20:15,080
Speaker 1: that despite the production team's awareness of the safety issues,

306
00:20:15,119 --> 00:20:19,560
Speaker 1: Baldwin did not address this reckless process procedure that is

307
00:20:19,680 --> 00:20:23,880
Speaker 1: contrary to industry standards and safety protocols and commonly understood

308
00:20:23,920 --> 00:20:28,520
Speaker 1: firearms safety procedures. Prior to the shooting incident, Sarah Zachary

309
00:20:28,560 --> 00:20:32,280
Speaker 1: had a negligent discharge while handling a revolver intended to

310
00:20:32,280 --> 00:20:34,959
Speaker 1: be used by an actor in the filming. This weapon

311
00:20:35,040 --> 00:20:39,240
Speaker 1: was not Baldwin's weapon, but had similar same mechanical function

312
00:20:39,280 --> 00:20:43,240
Speaker 1: and appearance single action revolver and was intended for use

313
00:20:43,320 --> 00:20:47,600
Speaker 1: by the quote marshals. Unquote statements show that Sarah Zachary

314
00:20:47,720 --> 00:20:50,879
Speaker 1: was holding and manipulating the weapon while walking, and she

315
00:20:51,119 --> 00:20:54,440
Speaker 1: discharged a blank cartridge into the ground next to her foot.

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00:20:55,160 --> 00:20:59,840
Speaker 1: Industry standards, practices and protocol consider negligent discharges reckless in

317
00:21:00,080 --> 00:21:04,400
Speaker 1: nature that require immediate action and or swift mediation up

318
00:21:04,400 --> 00:21:09,480
Speaker 1: to and including remedial training, demotion, removal from the set, termination, etc.

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00:21:10,320 --> 00:21:14,200
Speaker 1: Evidence shows Baldwin failed to act to address this reckless

320
00:21:14,240 --> 00:21:18,679
Speaker 1: situation or to direct Read to mitigate or address the situation.

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00:21:30,160 --> 00:21:36,320
Speaker 1: Crime Stories with Nancy Grace Pay seven. Also prior to

322
00:21:36,359 --> 00:21:39,879
Speaker 1: the shooting incident, another negligent discharge was committed by a

323
00:21:39,960 --> 00:21:43,760
Speaker 1: stunt double as he was handling, manipulating a lever action

324
00:21:43,800 --> 00:21:47,880
Speaker 1: period rifle loaded and left unattended with the stunt performer

325
00:21:48,119 --> 00:21:51,320
Speaker 1: while in a holding ten. Baldwin failed to act, the

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00:21:51,359 --> 00:21:54,639
Speaker 1: evidence shows to address this reckless situation or to direct

327
00:21:54,680 --> 00:22:00,000
Speaker 1: Read to mitigate or address the negligent discharge. Through evidence

328
00:22:00,080 --> 00:22:03,320
Speaker 1: and interviews, these reckless and serious safety violations were deemed

329
00:22:03,320 --> 00:22:07,560
Speaker 1: negligent by the investigation as there was no indication or

330
00:22:07,600 --> 00:22:12,280
Speaker 1: evidence that the firearms in question malfunctioned at any time. Rather,

331
00:22:12,320 --> 00:22:16,159
Speaker 1: there is evidence the weapons fired because of mishandling or

332
00:22:16,160 --> 00:22:20,120
Speaker 1: misuse by those handling the firearm ie pressing the trigger

333
00:22:20,160 --> 00:22:23,840
Speaker 1: when it should not be in his producer's position. The

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00:22:23,880 --> 00:22:27,639
Speaker 1: evidence indicates Baldwin also did not act to address the

335
00:22:27,760 --> 00:22:30,199
Speaker 1: lack of daily safety meetings that are required to be

336
00:22:30,240 --> 00:22:34,440
Speaker 1: conducted by the first assistant director. Evidence indicates that honor

337
00:22:34,480 --> 00:22:37,320
Speaker 1: about the thirteenth day of filming, only three or four

338
00:22:37,400 --> 00:22:41,320
Speaker 1: safety meetings were conducted by the assistant director. Practice and

339
00:22:41,400 --> 00:22:46,000
Speaker 1: standards investigated indicate that a daily safety meeting should be

340
00:22:46,040 --> 00:22:49,199
Speaker 1: conducted with the crew, regardless of the scenes for the

341
00:22:49,280 --> 00:22:52,119
Speaker 1: day's shoot. The lack of meetings and the lack of

342
00:22:52,160 --> 00:22:56,520
Speaker 1: appropriate content of said meetings resulted in a climate of recklessness,

343
00:22:56,600 --> 00:22:59,800
Speaker 1: as evidenced by the conduct of the cast and crew

344
00:23:00,040 --> 00:23:04,440
Speaker 1: documented through statements and evidence. In addition, no safety meeting

345
00:23:04,520 --> 00:23:07,440
Speaker 1: was conducted on the day of the incident. Safety meetings

346
00:23:07,480 --> 00:23:10,159
Speaker 1: were supposed to be listed on the call sheet daily

347
00:23:10,200 --> 00:23:13,440
Speaker 1: but were not. Meetings were called randomly throughout the day

348
00:23:13,480 --> 00:23:17,600
Speaker 1: with no mandatory attendance required. The meetings were impromptu. These

349
00:23:17,640 --> 00:23:21,199
Speaker 1: meetings should pursue it to standard protocols be conducted in

350
00:23:21,240 --> 00:23:23,720
Speaker 1: the morning prior to the beginning of the day, where

351
00:23:23,760 --> 00:23:26,200
Speaker 1: all members of the cast and crew should be required

352
00:23:26,240 --> 00:23:30,480
Speaker 1: to attend. On October twenty twenty one, the original camera

353
00:23:30,520 --> 00:23:35,680
Speaker 1: crew resigned citing safety concerns, commute times and distances, pay,

354
00:23:35,840 --> 00:23:38,880
Speaker 1: and other issues. On October twenty first, twenty twenty one,

355
00:23:39,080 --> 00:23:41,879
Speaker 1: a new crew was brought in to begin filming right away.

356
00:23:42,400 --> 00:23:45,720
Speaker 1: Evidence indicates that during the church scene in question, the

357
00:23:45,880 --> 00:23:49,520
Speaker 1: director and director of photography should have been outside the church,

358
00:23:49,640 --> 00:23:52,280
Speaker 1: viewing the scene from a large monitor covered by a

359
00:23:52,400 --> 00:23:56,479
Speaker 1: tent shade screen commonly referred to as a quote video village.

360
00:23:56,560 --> 00:24:00,520
Speaker 1: Unquote statements indicate that Joel Susa and Helena Hutchins decided

361
00:24:00,560 --> 00:24:03,600
Speaker 1: to be in the church with the camera crew. Due

362
00:24:03,680 --> 00:24:07,119
Speaker 1: to the abrupt change of the camera crew, evidence indicates

363
00:24:07,119 --> 00:24:10,199
Speaker 1: that Baldwin failed to act to address any safety or

364
00:24:10,240 --> 00:24:14,160
Speaker 1: continuity concerns with the new crew, causing a reckless situation

365
00:24:14,280 --> 00:24:17,159
Speaker 1: to occur on the day of the shooting. On the

366
00:24:17,240 --> 00:24:20,480
Speaker 1: day of the shooting, evidence and statements show that impromptu

367
00:24:20,600 --> 00:24:23,960
Speaker 1: plans were made to rehearse and then shoot a scene

368
00:24:24,000 --> 00:24:28,160
Speaker 1: inside of the church and for this particular scene, it

369
00:24:28,240 --> 00:24:32,320
Speaker 1: was to only involve Baldwin. Evidence and statements show that

370
00:24:32,680 --> 00:24:36,959
Speaker 1: the first Assistant Director, David Halls hereinafter Halls, was present

371
00:24:37,000 --> 00:24:41,359
Speaker 1: on the set as with Baldwin. Evidence, common standards, protocol

372
00:24:41,440 --> 00:24:44,639
Speaker 1: and statements show that Halls had the additional duty of

373
00:24:44,680 --> 00:24:49,200
Speaker 1: safety coordinator by virtue of his position. However, that position

374
00:24:49,280 --> 00:24:54,400
Speaker 1: does not afford the handling or manipulation of firearms. Evidence

375
00:24:54,440 --> 00:24:58,040
Speaker 1: and statements also show that Halls, by virtue of his position,

376
00:24:58,320 --> 00:25:00,760
Speaker 1: is the first point of contact for an armorer when

377
00:25:00,920 --> 00:25:03,320
Speaker 1: they bring a firearm on the set, and is the

378
00:25:03,320 --> 00:25:06,560
Speaker 1: first person required to conduct safety check with the armor

379
00:25:06,720 --> 00:25:13,520
Speaker 1: and weapons industry. Standards and procedures require page eight that

380
00:25:13,640 --> 00:25:16,560
Speaker 1: the armorer, in the presence of the first assistant director,

381
00:25:16,920 --> 00:25:20,600
Speaker 1: show the weapon is clear and safe. Then, if applicable,

382
00:25:20,840 --> 00:25:23,919
Speaker 1: show the firearm is loaded with blanks or dummy rounds,

383
00:25:24,000 --> 00:25:28,440
Speaker 1: visually and physically checking each round individually for safety by

384
00:25:28,480 --> 00:25:31,480
Speaker 1: pulling each round out of the firearm and showing the

385
00:25:31,560 --> 00:25:35,720
Speaker 1: first assistant director and the actor. The first assistant director

386
00:25:35,960 --> 00:25:39,560
Speaker 1: then allow follows the queue of the armorer calling cold

387
00:25:39,680 --> 00:25:44,400
Speaker 1: or hot weapon on set, then broadcasting that statement across

388
00:25:44,480 --> 00:25:48,520
Speaker 1: the radio which notifies all cast and crew. Evidence clearly

389
00:25:48,600 --> 00:25:51,880
Speaker 1: shows this did not occur on the day of the shooting.

390
00:25:52,080 --> 00:25:56,240
Speaker 1: At least two times, Baldwin failed to address these reckless

391
00:25:56,280 --> 00:26:01,280
Speaker 1: incidents and deviations from industry standards and farm safety rules

392
00:26:01,320 --> 00:26:05,879
Speaker 1: directly contributing to the fatal shooting. Halls did not adequately

393
00:26:06,000 --> 00:26:09,240
Speaker 1: check the firearm with Read prior to handing it to Baldwin,

394
00:26:09,359 --> 00:26:12,440
Speaker 1: who additionally did not check it with the armorer read.

395
00:26:13,160 --> 00:26:16,199
Speaker 1: Halls is further required to announce to crew when a

396
00:26:16,280 --> 00:26:19,520
Speaker 1: firearm will be fired in the scene. I announced quote

397
00:26:19,520 --> 00:26:22,680
Speaker 1: fire in the hole, unquote, or other common phrase to

398
00:26:22,720 --> 00:26:26,360
Speaker 1: put the crew on notice for shooting, loud noise, hearing protection, etc.

399
00:26:27,440 --> 00:26:31,159
Speaker 1: The evidence and statements show that this requirement did not

400
00:26:31,280 --> 00:26:35,400
Speaker 1: meet safety and industry standards, and further shows that Baldwin

401
00:26:35,720 --> 00:26:41,120
Speaker 1: failed to address and or mitigate this reckless and dangerous practice. Hall's,

402
00:26:41,280 --> 00:26:45,520
Speaker 1: again by virtue of his position and industry standards and practices,

403
00:26:46,000 --> 00:26:50,399
Speaker 1: is prohibited and or strictly discouraged from handling any of

404
00:26:50,400 --> 00:26:55,000
Speaker 1: the firearms on a set. As such, industry standards, policies

405
00:26:55,000 --> 00:26:58,080
Speaker 1: and practices call for the armorer to be on set

406
00:26:58,200 --> 00:27:02,440
Speaker 1: and to stay on set anytime a firearm is on set.

407
00:27:03,119 --> 00:27:06,600
Speaker 1: This practice and standard were not conducted on the day

408
00:27:06,600 --> 00:27:11,240
Speaker 1: of the shooting and was allowed by Baldwin prior to lunch.

409
00:27:11,440 --> 00:27:15,359
Speaker 1: Statements and evidence show that Halls requested Baldwin's firearm be

410
00:27:15,480 --> 00:27:18,520
Speaker 1: prepped and brought to the set by the armorer. Read.

411
00:27:19,119 --> 00:27:22,320
Speaker 1: Reid states that she loaded the firearm with dummy rounds

412
00:27:22,400 --> 00:27:25,880
Speaker 1: prior to lunch, so she didn't perform a second safety

413
00:27:25,960 --> 00:27:28,840
Speaker 1: check on her own or with Halls and the firearm,

414
00:27:29,359 --> 00:27:32,360
Speaker 1: just showing him the barrel and not removing the bullets

415
00:27:32,400 --> 00:27:35,080
Speaker 1: to show the firearm was safe, and then Halls took

416
00:27:35,119 --> 00:27:38,720
Speaker 1: possession of the firearm from Read. Read departed the church.

417
00:27:39,320 --> 00:27:42,920
Speaker 1: Halls provided Baldwin with the firearm so he could rehearse

418
00:27:43,119 --> 00:27:48,240
Speaker 1: practice with the weapon. However, there are contradictory statements that

419
00:27:48,480 --> 00:27:51,840
Speaker 1: Read brought an empty gun to Halls and at some

420
00:27:52,040 --> 00:27:55,520
Speaker 1: point loaded it with dummy rounds while in the church.

421
00:27:56,080 --> 00:28:01,199
Speaker 1: Read then showed Halls the firearm again. Read did not

422
00:28:01,480 --> 00:28:05,120
Speaker 1: do a proper safety check with halser Baldwin. Read then

423
00:28:05,400 --> 00:28:09,639
Speaker 1: left the church. Read leaving the set and Hall's handling

424
00:28:09,640 --> 00:28:15,120
Speaker 1: the firearm are considered very reckless actions. According to industry standards, expectation,

425
00:28:15,240 --> 00:28:20,160
Speaker 1: and common firearms safety protocols and considerations. There is no

426
00:28:20,359 --> 00:28:25,200
Speaker 1: evidence or information that Baldwin addressed or acted to mitigate

427
00:28:25,520 --> 00:28:30,320
Speaker 1: these reckless actions. In addition, for a rehearsal, a rubber

428
00:28:30,440 --> 00:28:33,879
Speaker 1: or replica firearms should have been used only when the

429
00:28:33,920 --> 00:28:36,919
Speaker 1: actual scene was to be filmed. Should the weapon have

430
00:28:37,080 --> 00:28:41,800
Speaker 1: been loaded with dummy rounds. Baldwin, Halls and read All

431
00:28:41,960 --> 00:28:46,360
Speaker 1: knew this was standard protocol. Further evidence and statements show

432
00:28:46,720 --> 00:28:49,840
Speaker 1: that when the crew took a break for lunch, firearms,

433
00:28:49,840 --> 00:28:54,040
Speaker 1: including Baldwin's, were secured in the prop trucks safe Outside

434
00:28:54,040 --> 00:28:56,520
Speaker 1: of the church was a cart used by the armorer

435
00:28:56,560 --> 00:29:00,720
Speaker 1: and propmaster, contrary at standard protocol, that contained leather gear

436
00:29:00,880 --> 00:29:05,480
Speaker 1: rigs like holsters, belts, and ammunition. Evidence clearly indicates this

437
00:29:05,640 --> 00:29:09,240
Speaker 1: cart and associated items was not secured during the break

438
00:29:09,240 --> 00:29:12,040
Speaker 1: and was not in visual range of read or Sarah

439
00:29:12,120 --> 00:29:16,800
Speaker 1: Zachary for safety and security. The unsecured cart with the equipment,

440
00:29:16,920 --> 00:29:22,760
Speaker 1: ammunition and firearm is page nine considered very reckless by

441
00:29:22,800 --> 00:29:26,640
Speaker 1: industry standards and by common firearms safety standards and protocol.

442
00:29:27,120 --> 00:29:31,080
Speaker 1: Evidence indicates that Baldwin failed to act to address and

443
00:29:31,280 --> 00:29:36,560
Speaker 1: or mitigate these serious and reckless safety violations. Upon returning

444
00:29:36,600 --> 00:29:40,320
Speaker 1: from lunch, evidence and statements show that Read retrieves Baldwin's

445
00:29:40,320 --> 00:29:45,320
Speaker 1: preferred revolver, but Read does not perform another safety check. Additionally,

446
00:29:45,800 --> 00:29:49,400
Speaker 1: Read again is asked and complies with Halls by handing

447
00:29:49,440 --> 00:29:53,360
Speaker 1: him the firearm once inside the church. There are also

448
00:29:53,400 --> 00:29:57,440
Speaker 1: contradictory statements that Read brought in the firearm empty, showed

449
00:29:57,440 --> 00:29:59,760
Speaker 1: it to Halls, and ultimately later loaded it with dummy

450
00:29:59,800 --> 00:30:04,400
Speaker 1: roun Regardless, the evidence is consistent that Read failed to

451
00:30:04,440 --> 00:30:07,600
Speaker 1: show Halls each dummy round and pull them out for safety,

452
00:30:07,880 --> 00:30:11,040
Speaker 1: nor did Halls request it. Reid did not show Baldwin

453
00:30:11,120 --> 00:30:14,520
Speaker 1: the loaded firearm either, nor did he request to see

454
00:30:14,560 --> 00:30:17,960
Speaker 1: the rounds, which is standard protocol. Read left the church.

455
00:30:18,320 --> 00:30:22,360
Speaker 1: Evidence and statements also indicated that an after lunch safety

456
00:30:22,440 --> 00:30:25,240
Speaker 1: check of the firearm to industry standards between Read and

457
00:30:25,280 --> 00:30:28,840
Speaker 1: Halls did not occur. This after lunch sequence of events

458
00:30:29,000 --> 00:30:32,560
Speaker 1: is documented to have had no less than four extremely

459
00:30:32,600 --> 00:30:37,600
Speaker 1: reckless violations of industry standards, safety protocol best practices, and

460
00:30:37,760 --> 00:30:41,600
Speaker 1: common firearms safety protocols in a very short compressed period

461
00:30:41,640 --> 00:30:44,720
Speaker 1: of time. On the day of the shooting alone, evidence

462
00:30:44,720 --> 00:30:47,240
Speaker 1: shows that no less than a dozen acts or omissions

463
00:30:47,280 --> 00:30:50,240
Speaker 1: of recklessness occurred in the short time prior to lunch

464
00:30:50,320 --> 00:30:53,320
Speaker 1: and the time of the shooting. This does not include

465
00:30:53,360 --> 00:30:57,120
Speaker 1: the reckless handling of the firearm by Baldwin. Baldwin, by

466
00:30:57,120 --> 00:30:59,720
Speaker 1: act or omission or failure to act in his position

467
00:30:59,760 --> 00:31:04,160
Speaker 1: as a producer, directly contributed and or failed to mitigate

468
00:31:04,280 --> 00:31:09,960
Speaker 1: numerous reckless and dangerous actions during a very short time period. Finally,

469
00:31:10,520 --> 00:31:14,160
Speaker 1: industry standards protocols in common firearms safety procedures on the

470
00:31:14,240 --> 00:31:18,560
Speaker 1: movie sets require the armorer, after conducting a safety check

471
00:31:18,640 --> 00:31:21,959
Speaker 1: with the first assistant director, to conduct a second safety

472
00:31:22,000 --> 00:31:25,040
Speaker 1: check with the actor to be handling the firearm. This

473
00:31:25,200 --> 00:31:29,720
Speaker 1: reckless violation of standards and firearm safety occurred two times

474
00:31:29,800 --> 00:31:32,600
Speaker 1: leading up to the shooting, and Baldwin failed to act

475
00:31:32,640 --> 00:31:35,920
Speaker 1: to mitigate or correct the reckless safety violations, neither in

476
00:31:35,960 --> 00:31:40,360
Speaker 1: his capacity as actor nor producer. This reckless deviation from

477
00:31:40,480 --> 00:31:44,280
Speaker 1: known standards and practices and protocol directly caused the fatal shooting.

478
00:31:44,800 --> 00:31:49,320
Speaker 1: Baldwin acted with reckless disregard and or more than mere

479
00:31:49,400 --> 00:31:54,480
Speaker 1: negligence in this incident. Baldwin acted with willful disregard of

480
00:31:54,520 --> 00:31:57,680
Speaker 1: the safety of others and in a manner that endangered

481
00:31:57,760 --> 00:32:01,120
Speaker 1: other people, and he clearly should known the danger of

482
00:32:01,160 --> 00:32:04,719
Speaker 1: his actions which led to the death of Hutchins. Furthermore,

483
00:32:05,200 --> 00:32:09,440
Speaker 1: Baldwin handled the weapon in a negligent manner. Evidence exists

484
00:32:09,480 --> 00:32:12,920
Speaker 1: to clearly show that on October twenty first, twenty twenty one,

485
00:32:13,120 --> 00:32:17,320
Speaker 1: Helena Hutchins was killed when Baldwin fired a firearm that

486
00:32:17,360 --> 00:32:20,480
Speaker 1: he pointed at her. The evidence and statements documented in

487
00:32:20,520 --> 00:32:25,080
Speaker 1: this affidavit confirmed many instances of extremely reckless acts or

488
00:32:25,120 --> 00:32:29,080
Speaker 1: reckless failures to act by Baldwin in a ten day period.

489
00:32:29,480 --> 00:32:33,320
Speaker 1: Evidence clearly shows that none of the incidents or issues

490
00:32:33,440 --> 00:32:36,880
Speaker 1: were addressed by Baldwin in his position as actor or

491
00:32:37,000 --> 00:32:42,120
Speaker 1: producer to mitigate future occurrences of recklessness, correct reckless behavior,

492
00:32:42,360 --> 00:32:48,360
Speaker 1: or correct training deficiencies. Baldwin's deviation from known standards, practices

493
00:32:48,400 --> 00:32:51,960
Speaker 1: and protocol directly caused the fatal death of Hutchins by

494
00:32:52,080 --> 00:32:56,360
Speaker 1: not receiving the required training on firearms, not checking the

495
00:32:56,480 --> 00:33:01,080
Speaker 1: firearm with the armorer, letting the armor the firearm in

496
00:33:01,200 --> 00:33:06,320
Speaker 1: the church without being page ten present, deviating from the

497
00:33:06,400 --> 00:33:09,320
Speaker 1: practice of only accepting the firearm from the armor and

498
00:33:09,440 --> 00:33:12,600
Speaker 1: not dealing with the safety complaints onset and or making

499
00:33:12,600 --> 00:33:16,000
Speaker 1: sure safety meetings were held. Putting his finger on the

500
00:33:16,000 --> 00:33:18,760
Speaker 1: trigger of a real firearm when a replica or a

501
00:33:18,800 --> 00:33:22,000
Speaker 1: rubber gun should have been used, pointing the firearm at

502
00:33:22,080 --> 00:33:26,080
Speaker 1: Hutchins and Susa, and the overall handling of the firearm

503
00:33:26,120 --> 00:33:30,480
Speaker 1: in a negligent manner. Baldwin acted with wilful disregard for

504
00:33:30,640 --> 00:33:34,600
Speaker 1: the safety of others and in a manner which endangered

505
00:33:34,640 --> 00:33:38,640
Speaker 1: other people, specifically Hutchins and Susa. Baldwin clearly should have

506
00:33:38,720 --> 00:33:40,880
Speaker 1: known the danger of his actions was led to the

507
00:33:41,000 --> 00:33:46,280
Speaker 1: death of Hutchins. Probable cause exists that Baldwin committed involuntary

508
00:33:46,320 --> 00:33:50,760
Speaker 1: manslaughter contrary to and defined in in him Essay thirty

509
00:33:50,840 --> 00:33:55,400
Speaker 1: Dash two Dash three quote manslaughter in the commission of

510
00:33:55,400 --> 00:33:58,320
Speaker 1: a lawful act which might produce death in an unlawful

511
00:33:58,360 --> 00:34:02,400
Speaker 1: manner or without due caution and circumspection, or during the

512
00:34:02,520 --> 00:34:06,640
Speaker 1: unlawful act, not amounting to a felony to it negligent

513
00:34:06,800 --> 00:34:11,920
Speaker 1: use of a deadly weapon. Robert Schilling, Special Investigator, First

514
00:34:12,080 --> 00:34:15,960
Speaker 1: Judicial District Attorney's Office, three two seven Santovall Street, Santa Fe,

515
00:34:16,080 --> 00:34:16,640
Speaker 1: New Mexico,