Replies

I'm pretty sure an average 7 year old could enter a motor home. Do you think all the thousands of families who take trips *carry* their children in and out ?!

I was just reminded that when we camped with a child this age he couldn't get in easily without steps being pulled out. I don't recall he ever opened the door by himself without the stairs being out. That was my job.

I'm bored. Can we stipulate that he gets paid to watch bugs ? And get on with the testimony ?

Well, I think the theory that she gained entry on her own was always predicated on the idea that the door was unlocked and/or open. As such the steps would be extended, and if the exterior door was open, just a screen door barrier. I don't anyone here has suggested she 'broke in' to the MH.

"I was just reminded that when we camped with a child this age he couldn't get in easily without steps being pulled out."

Don't under estimate what a child can do when they set their minds to it. As I said before when my daughter was 2-3 years old she climbed onto the roof of the house because her Dad was up there working on putting up an antenna. He heard, "Me help Daddy." He looked and there she was.

Possible opportunity when Danielle may have gotten into the RV

Testimony Susan L. 7/10/02 Morning 2 pg 7917-18

16 WOULD ONLY BE THERE BEFORE YOU WENT CAMPING, WAS THERE ALSO AT
17 LEAST ONE TIME WHEN THE MOTOR HOME WAS THERE AT THE PARK AND YOU
18 WERE DOING SOME ADDITIONS TO IT?
19 A. YES, YES.
20 MR. DUSEK: OBJECTION, VAGUE AS TO TIME.
21 THE COURT: MAKE IT TIME SPECIFIC, COUNSEL.
22
23 BY MR. BOYCE:
24 Q. WITHIN THE PAST YEAR, YEAR AND A HALF?
25 A. YES.
26 Q. THIS WAS THE NEW MOTOR HOME; IS THAT CORRECT?
27 A. CORRECT.
28 Q. THIS WAS AT THE PARK CLOSE TO MR. WESTERFIELD'S

Testimony of Brenda VanDam at PH 3/14/02 pg 549

3 Q IS THERE ANY PARK DOWN AT ONE END OF YOUR 4 STREET?5 A YES. 6 Q TO GET TO THE PARK, YOU HAVE TO CROSS A 7 STREET?8 A YES. 9 Q AND THEN DO YOU HAVE TO GO BY 10 MR. WESTERFIELD'S HOUSE?11 A YES. 12 Q WAS SHE PERMITTED TO GO DOWN THERE?13 A SHE WAS DOWN THERE MAYBE TWO TIMES WITHOUT 14 ME, BUT I WAS IN THE DRIVEWAY WATCHING. 15 Q WOULD SHE ASK PERMISSION TO GO DOWN THERE?16 A YES.17 Q HOW FAR AWAY IS THIS PARK, WOULD YOU SAY? 18 WITHIN EYESIGHT OR --19 A WITHIN EYESIGHT. 20 Q I FORGOT TO SHOW YOU SOMETHING EARLIER. 21 I'VE HAD MARKED AS PEOPLE'S EXHIBIT 6 THIS 22 THREE-PAGE DOCUMENT, LOOKS LIKE A GIRL SCOUT COOKIE 23 FORM. COUNSEL HAS A COPY AND I'VE SHOWN HIM. 24 LET ME ASK YOU TO LOOK AT EXHIBIT 6,