0001 1 2 HIGHLY CONFIDENTIAL 3 4 UNITED STATES DISTRICT COURT 5 SOUTHERN DISTRICT OF NEW YORK 6 -----------------------------------x 7 IN RE SEPTEMBER 11 LITIGATION 8 No. 21 MC 97 (AKH) 9 -----------------------------------x 10 February 14, 2007 11:38 a.m. 11 12 Videotaped Deposition of DANA G. 13 TURNER, taken by Plaintiffs, pursuant 14 to Notice, at the offices of Debevoise 15 & Plimpton, 919 Third Avenue, New York, 16 New York, before ERIC J. FINZ, a 17 Shorthand Reporter and Notary Public 18 within and for the State of New York. 19 20 21 22 23 24 25 0002 1 2 A P P E A R A N C E S: 3 MOTLEY RICE LLC Attorneys for Plaintiffs 4 28 Bridgeside Boulevard P.O. Box 1792 5 Mt. Pleasant, SC 29465 6 BY: ELIZABETH SMITH, ESQ. 7 8 CLIFFORD LAW OFFICES Attorneys for Plaintiffs 9 120 North LaSalle Street Chicago, Illinois 60602 10 BY: TIMOTHY S. TOMASIK, ESQ. 11 (Telephonically) 12 GREGORY P. JOSEPH LAW OFFICE LLC 13 Attorneys for Plaintiffs 805 Third Avenue 14 New York, New York 10022 15 BY: DOUGLAS J. PEPE, ESQ. 16 17 ZELLE HOFMANN VOELBEL MASON & GETTE Attorneys for Property Plaintiffs 18 1201 Main Street Dallas, Texas 75202 19 BY: STEVEN J. BADGER, ESQ. 20 (p.m. only) 21 FLEMMING ZULACK WILLIAMSON 22 ZAUDERER LLP Attorneys for World Trade Center 23 Properties One Liberty Plaza 24 New York, New York 10006 25 BY: ANDREW J. SCHOLZ, ESQ. 0003 1 2 A P P E A R A N C E S: (Continued) 3 MAYER BROWN ROWE & MAW Attorneys for United Air Lines, Inc. 4 71 South Wacker Drive Chicago, Illinois 60606 5 BY: JOSHUA P. KOLAR, ESQ. 6 7 DEBEVOISE & PLIMPTON LLP 8 Attorneys for American Airlines 919 Third Avenue 9 New York, New York 10022 10 BY: MAURA KATHLEEN MONAGHAN, ESQ. -and- 11 TERRIANNE MUENZEN, ESQ. 12 13 GALLAGHER GOSSEEN FALLER & CROWLEY Attorneys for Delta Air Lines, Inc. 14 350 Fifth Avenue New York, New York 10118 15 BY: MICHAEL J. CROWLEY, ESQ. 16 17 SEIDEN WAYNE LLC 18 Attorneys for Continental Airlines Two Penn Plaza 19 New York, New York 07105 20 BY: DOUGLAS H. AMSTER, ESQ. 21 22 SATTERLEE STEPHENS BURKE & BURKE LLP Attorneys for Airtran Airways 23 230 Park Avenue New York, New York 10169 24 BY: VERONICA L. MAGINNIS, ESQ. 25 0004 1 2 A P P E A R A N C E S: (Continued) 3 CAMPBELL CAMPBELL EDWARDS & CONROY Attorneys for U.S. Airways 4 One Constitution Plaza Boston, Massachusetts 02129 5 BY: CHRISTOPHER B. PARKERSON, ESQ. 6 7 JONES HIRSCH CONNORS & BULL P.C. 8 Attorneys for Globe Aviation Services Corp. 9 One Battery Park Plaza New York, New York 10004 10 BY: PETER S. READ, ESQ. 11 12 SIMPSON THACHER & BARTLETT LLP 13 Attorneys for Argenbright 425 Lexington Avenue 14 New York, New York 10017 15 BY: LAURA D. MURPHY, ESQ. 16 17 PERKINS COIE LLP Attorneys for Boeing 18 1201 Third Avenue Seattle, Washington 98101 19 BY: ERIC S. LENT, ESQ. 20 21 GALLAGHER GOSSEEN FALLER & CROWLEY 22 Attorneys for Port Authority of NY & NJ, Operator of Newark Airport 23 350 Fifth Avenue New York, New York 10118 24 BY: AMY L. RUINA, ESQ. 25 0005 1 2 A P P E A R A N C E S: (Continued) 3 DOMBROFF & GILMORE, P.C. Attorneys for Metropolitan 4 Washington Airports Authority 1676 International Drive 5 McLean, Virginia 22102 6 BY: MICHAEL W. KERNS, ESQ. 7 -AND- 8 DOMBROFF & GILMORE, P.C. Attorneys for Metropolitan 9 Washington Airports Authority 40 Broad Street 10 New York, New York 10004 11 BY: KAREN M. BERBERICH, ESQ. 12 13 O'MELVENY & MYERS LLP Attorneys for Massachusetts Port 14 Authority 7 Times Square 15 New York, New York 10036 16 BY: MICHAEL P. HATZIMICHALIS, ESQ. 17 18 SCHIFF HARDIN LLP Attorneys for Port Authority of 19 NY & NJ 623 Fifth Avenue 20 New York, New York 10022 21 BY: DONALD A. KLEIN, ESQ. 22 SUSMAN GODFREY, LLP 23 Attorneys for Huntleigh USA 1901 Avenue of the Stars 24 Los Angeles, California 90067 25 BY: NICHOLAS F. DAUM, ESQ. (Telephonically) 0006 1 2 A P P E A R A N C E S: (Continued) 3 KEEGAN WERLIN LLP Attorneys for Fiberlock Technologies 4 265 Franklin Street Boston, Massachusetts 02110 5 BY: RICHARD B. KIRBY, ESQ. 6 7 MOUND COTTON WOLLAN & GREENGRASS 8 Attorneys for Amec Construction Management, Inc. 9 855 Franklin Avenue Garden City, New York 11530 10 BY: DOUGLAS EISENSTEIN, ESQ. 11 (Telephonically) 12 UNITED STATES DEPARTMENT OF JUSTICE 13 U.S. ATTORNEY'S OFFICE SOUTHERN DISTRICT OF NEW YORK 14 86 CHAMBERS Street New York, New York 10007 15 BY: BETH E. GOLDMAN, ESQ. 16 17 18 ALSO PRESENT: 19 MATTHEW CHAVEZ, Videographer 20 21 22 23 24 25 0007 1 2 IT IS HEREBY STIPULATED AND 3 AGREED by and between the attorneys for 4 the respective parties herein that 5 filing and sealing be and the same are 6 hereby waived. 7 IT IS FURTHER STIPULATED AND 8 AGREED that all objections, except as 9 to the form of the question, shall be 10 reserved to the time of the trial. 11 IT IS FURTHER STIPULATED AND 12 AGREED that the within deposition may 13 be signed and sworn to before any 14 officer authorized to administer an 15 oath with the same force and effect as 16 if signed and sworn to before the 17 Court. 18 19 20 21 22 23 24 25 0008 1 2 THE VIDEOGRAPHER: This is 3 the video operator speaking, Matthew 4 Chavez of TC Reporting, New York, New 5 York. Today is February 14, 2007 and 6 the time is 11:38 a.m. 7 We are at the offices of 8 Debevoise & Plimpton, to take the 9 videotape deposition of Dana Turner, in 10 the matter of in re September 11th 11 Litigation, United States District 12 Court, Southern District of New York. 13 Will counsel please voice 14 identify themselves. 15 MR. PEPE: Douglas J. Pepe 16 from Gregory P. Joseph Law Offices for 17 the plaintiffs. 18 MS. MONAGHAN: Maura 19 Monaghan from Debevoise & Plimpton for 20 the witness and American Airlines. 21 THE VIDEOGRAPHER: Will the 22 court reporter, Eric Finz, please swear 23 in the witness and you may begin. 24 25 0009 1 DANA G. TURNER - CONFIDENTIAL 2 D A N A G. T U R N E R, 3 having been first duly sworn by the 4 Notary Public (Eric J. Finz), was 5 examined and testified as follows: 6 EXAMINATION BY 7 MR. PEPE: 8 Q. Good morning, ma'am. 9 A. Good morning. 10 Q. My name is Douglas Pepe 11 from Gregory P. Joseph Law Offices, I 12 represent the plaintiffs in this case. 13 Could you please state your 14 name for the record? 15 A. Dana Turner. 16 Q. Could you spell it, please? 17 A. D-a-n-a, T-u-r-n-e-r. 18 Q. Ms. Turner, a few ground 19 rules, I'm sure your counsel has gone 20 over them with you. But if there are 21 any questions that I ask you today that 22 you're unsure of or you need 23 clarification, you can feel free to 24 seek clarification from me and I'll 25 rephrase the question or have it read 0010 1 DANA G. TURNER - CONFIDENTIAL 2 back. 3 A. Okay. 4 Q. If at any time you want to 5 take a break, please feel free to tell 6 me and we will take a break. 7 You understand that you are 8 here to give a deposition in the 9 September 11th Litigation; correct? 10 A. I do. 11 Q. And you were a ground 12 security coordinator for American 13 Airlines at Dulles on September 11, 14 2001; is that right? 15 A. Yes, sir. 16 Q. And GSC means the 17 coordinator or American's coordinator 18 for ground security related issues on 19 September 11th; correct? 20 MS. MONAGHAN: Object to 21 form. 22 You can answer the question. 23 A. That's correct. 24 Q. And as a GSC for American, 25 you received training in proper 0011 1 DANA G. TURNER - CONFIDENTIAL 2 screening techniques prior to 9/11; is 3 that right? 4 MS. MONAGHAN: Object to the 5 form. 6 A. I do. 7 Q. I'm sorry, is that correct? 8 A. Yes. 9 Q. And prior to 9/11, as a GSC 10 for American, you observed checkpoints 11 at Dulles when screening was being 12 conducted; is that right? 13 MS. MONAGHAN: Object to the 14 form. 15 A. I have observed security 16 procedures at Dulles. 17 Q. Yes. 18 A. Absolutely, yes. 19 Q. Prior to 9/11? 20 A. Yes, I did. 21 Q. Please describe for the 22 jury the proper way to conduct hand 23 wanding of a passenger on and before 24 September 11th. 25 MS. MONAGHAN: Object to the 0012 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. I'm not trained in hand 4 wanding. That is a purpose of -- a 5 function of our security screeners. 6 Q. Did you oversee or 7 supervise security screeners in any way 8 prior to September 11, 2001 as a ground 9 security coordinator for American? 10 MS. MONAGHAN: Object to the 11 form. 12 A. I did not supervise security 13 personnel, no, sir. What was the 14 second portion of your question? 15 MR. PEPE: We can have it 16 read back. 17 (Record read as requested.) 18 A. No, I did not supervise. 19 Q. Did you oversee any? 20 A. I'm sorry? 21 Q. Did you oversee any? 22 A. No, sir. 23 Q. Describe your role with 24 respect to -- as a GSC for American 25 prior to September 11, 2001 with 0013 1 DANA G. TURNER - CONFIDENTIAL 2 respect to checkpoint security. 3 A. My role as a ground security 4 coordinator would be to oversee 5 departures for American, to ensure that 6 what the FAA set forth for us to follow 7 was carried out on a daily basis. 8 Q. And is it correct that one 9 of the things the FAA set forth on and 10 before September 11, 2001 for you to 11 follow on a daily basis were -- 12 included hand wanding procedures? 13 MS. MONAGHAN: Object to the 14 form. 15 A. As a GSC, we oversaw or were 16 to oversee that those procedures were 17 followed out, but it was not my -- my 18 sole responsibility as a GSC, it was a 19 shared function to oversee security 20 procedures. 21 Q. I understand. But you 22 oversaw them? 23 A. Yes. As a job function, 24 yes. A collaborative effort, yes. 25 Q. So in order to oversee and 0014 1 DANA G. TURNER - CONFIDENTIAL 2 ensure that proper hand wanding 3 procedures were being followed at the 4 checkpoint at Dulles prior to 9/11, you 5 had to know what the proper procedures 6 were; is that correct? 7 MS. MONAGHAN: Object to the 8 form. 9 A. Yes. However, at Dulles, 10 the layout of Dulles does not allow one 11 individual to oversee two different 12 places. So yes, we had a collaborative 13 team of GSCs all trained. 14 Q. I'm just speaking about you 15 and your training as a GSC and your 16 experience as a GSC. And my question 17 is, at Dulles prior to September 11, 18 2001, did you know the proper 19 techniques that screeners were supposed 20 to use in hand wanding passengers at 21 the checkpoint? 22 MS. MONAGHAN: Object to the 23 form. 24 A. Yes, it was available to me 25 in the COG, definitely. 0015 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And could you please 3 describe for the jury on and before 4 September 11, 2001, what were the 5 proper procedures for hand wanding a 6 passenger at Dulles at the checkpoint. 7 MS. MONAGHAN: Object to the 8 form. She just said that she knew that 9 the procedures were available to her in 10 the COG. You can put the COG before 11 her. 12 Q. If you understand the 13 question you can answer. 14 A. They are available to me in 15 the COG. And if you would like me to 16 look at those, I can. It's been a very 17 long time. 18 MR. PEPE: I would like to 19 state any objection on the record to 20 counsel's speaking objection which then 21 led to the witness reciting exactly 22 what counsel said in response to my 23 question. 24 Could we have my question 25 read back, please. I move to strike 0016 1 DANA G. TURNER - CONFIDENTIAL 2 the prior answer as nonresponsive. 3 MS. MONAGHAN: She answered 4 the question. 5 (Record read as requested.) 6 MS. MONAGHAN: Are you 7 repeating that question? 8 MR. PEPE: Yes. I moved to 9 strike the prior answer as 10 nonresponsive, so I would like an 11 answer. 12 MS. MONAGHAN: The objection 13 is asked and answered. 14 MR. PEPE: Fair enough. 15 Q. You can answer if you 16 understand the question. 17 THE WITNESS: Could you 18 re-read it once more, please. 19 (Record read as requested.) 20 A. Today there would be no way 21 without looking at the COG that I could 22 recite that and tell you exactly what 23 should be done. 24 Q. Can you tell me some of 25 them? 0017 1 DANA G. TURNER - CONFIDENTIAL 2 A. Yes. 3 Q. Why don't you explain to 4 the jury what some of the procedures as 5 you remember them were. 6 MS. MONAGHAN: Object to the 7 form. 8 MR. AMSTER: Object to the 9 characterization of the jury. This is 10 a discovery deposition. 11 Q. You can answer. 12 Just so you know, we will 13 back up to some of the background for a 14 deposition, then I'll have the question 15 re-read. If there is an objection, 16 unless your counsel instructs you not 17 to answer, then you can answer the 18 question. TSA, sitting right over 19 there, may also instruct you not to 20 answer when certain SSI related issues 21 are implicated. 22 MS. MONAGHAN: Instruct you 23 not to answer. 24 MR. PEPE: Not to answer. 25 But unless you receive an instruction 0018 1 DANA G. TURNER - CONFIDENTIAL 2 from your counsel or TSA, you can 3 answer the question. 4 THE WITNESS: Okay. 5 MR. PEPE: I would like to 6 say you can ignore the objections, you 7 can listen to them, but they are 8 irrelevant for purposes of whether you 9 can answer or not. 10 Why don't we have the 11 question read back. 12 THE WITNESS: Yes, sir. 13 (Record read as requested.) 14 MS. MONAGHAN: Object to the 15 form. You mean hand wanding 16 procedures? 17 MR. PEPE: Yes. This is all 18 in the prior line of questioning. 19 MS. MONAGHAN: That's so far 20 afield from the original question. The 21 question is can you describe some of 22 the hand wanding procedures as they 23 existed before 9/11. Is that right? 24 MR. PEPE: The question is 25 what the question is. 0019 1 DANA G. TURNER - CONFIDENTIAL 2 A. I can, but I'm not 100 3 percent sure that what I say today 4 would be clear, because it has been a 5 very long time since I've done any of 6 that. Or been involved with any of 7 that. 8 Q. Let's show you Exhibit 1-C. 9 MR. PEPE: I'm sorry, let's 10 go off for one second. 11 THE VIDEOGRAPHER: Going off 12 the record, 1:48. 13 (Discussion off the record.) 14 THE VIDEOGRAPHER: We are 15 back on the record, the time is 11:50. 16 BY MR. PEPE: 17 Q. Ma'am, I've placed before 18 you Exhibit 1-C, which is the 19 Checkpoint Operations Guide. If you 20 could please find the section in that 21 guide that relates to hand wanding. 22 While you are looking for 23 that, on September 11, 2001, is it your 24 testimony that you were thoroughly 25 familiar with the procedure for hand 0020 1 DANA G. TURNER - CONFIDENTIAL 2 wanding as a GSC for American? 3 A. Yes. 4 Q. And those procedures are 5 set forth in the Checkpoint Operations 6 Guide? 7 A. Yes. 8 Q. I'm sorry, you just, for 9 the video, you need. 10 A. Yes, sir. 11 Handheld detector 12 procedures? 13 Q. Yes. This is AALTSA 9526. 14 Are you with me? 15 A. Yes, sir. 16 Q. So if you want to peruse 17 this and then explain to the jury what 18 the proper procedures were on September 19 11th, we would appreciate it. 20 MS. MONAGHAN: Object to the 21 form. 22 A. I can read it to you. If 23 that's what you're asking. They are 24 first supposed to test the handheld 25 detector to make sure it is active. 0021 1 DANA G. TURNER - CONFIDENTIAL 2 And wanding -- 3 Q. I'm sorry, this is prior to 4 using the hand wand on the passenger? 5 A. Correct. To test that it is 6 actually working, yes. 7 Q. So how are they supposed to 8 test how it was working, the screeners 9 on duty at Dulles on and before 10 September 11th? 11 A. To test it against something 12 that they know is going to set it off, 13 to make sure that it actually does 14 work. 15 Q. Like a watch or a piece of 16 metal? 17 A. Yes. 18 Q. And that was the first 19 step? 20 MS. MONAGHAN: Object to the 21 form. 22 A. Yes. 23 Q. You can proceed. 24 A. They first ask the 25 passenger's permission to conduct the 0022 1 DANA G. TURNER - CONFIDENTIAL 2 search. Ask the passenger to remove 3 any of their outer garments that would 4 interfere with the search. Retain 5 control of the hand carried items, and 6 they put them in a bucket, a tray. 7 Ensure that the search is done in a 8 location that wouldn't interfere with 9 traffic and passengers walking through 10 the metal detector. 11 Direct the customer to face 12 forward and reach his or her arms 13 straight out, use the metal detector 14 until -- never touch passenger's body 15 with the hand wand. To use the same 16 search path and procedures each time. 17 Start from the top of the 18 head moving down around the passenger's 19 body in a clockwise direction. Until 20 the customer's body has been outlined 21 completely. Then hold the handheld 22 device parallel to the body, move the 23 detector from the passenger's 24 shoulders, then up within two to three 25 tracks from the front of the customer's 0023 1 DANA G. TURNER - CONFIDENTIAL 2 body, and completely inspect the 3 individual. Move around the passenger 4 and repeat the procedure to the 5 customer's back. 6 To ensure that you screen 7 the passenger all the way to the 8 customer's feet, inside and out. 9 Q. Front and back; right? 10 A. Yes, sir. 11 If the handheld detector did 12 detect something, you were required to 13 clear the detection. Conclude the 14 detection and then resume at that 15 point. Continue the procedure until 16 the passenger had been completely 17 screened and all the sources of the 18 alarms had been identified and cleared. 19 Q. Okay. So having read that 20 and seeing the COG which is before you, 21 does that refresh your recollection as 22 to what the proper procedures for hand 23 wanding were on September 11, 2001 at 24 Dulles? 25 MS. MONAGHAN: Object to the 0024 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. Yes, sir. 4 Q. And you understood that -- 5 strike that. 6 Please turn to page 4-8, 7 which is AAL 14323. And the section 8 entitled "special note." Please read 9 that into the record. 10 A. "Special note. To ensure 11 that the search is thorough, screen all 12 the way to the passenger's feet, the 13 inside and outside of each foot, front 14 and back. By the time the screener has 15 completed the handheld detector 16 inspection, he or she should be near 17 the floor eight times." 18 Q. Does that refresh your 19 recollection as to the proper procedure 20 in place at Dulles for American flights 21 on September 11, 2001? 22 MS. MONAGHAN: Object to the 23 form. 24 A. Yes, sir. 25 Q. And as you understand it as 0025 1 DANA G. TURNER - CONFIDENTIAL 2 a ground security coordinator for 3 American at Dulles on September 11th, 4 that the proper procedure was for the 5 screener to near the floor with the 6 handheld metal detector eight times 7 when screening a passenger; is that 8 right? 9 MS. MONAGHAN: Object to the 10 form. 11 MR. CROWLEY: Object to the 12 form. 13 Q. I believe you answered, but 14 I would like to get the answer on 15 verbally. 16 A. Yes, sir. 17 Q. Turn to page 4-6, AALTSA 18 9528. On September 11, 2001, at Dulles 19 Airport, the proper procedure for hand 20 wanding passengers included starting at 21 the top of their head, moving down and 22 around the passenger's body in a 23 clockwise direction until the 24 passenger's body has been completely 25 outlined; is that correct? 0026 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MURPHY: Object to the 3 form. 4 MS. MONAGHAN: Object to the 5 form. 6 A. Yes, sir. 7 Q. And next page. On 8 September 11, 2001, at Dulles, the 9 proper procedure for hand wanding a 10 passenger included using the active 11 area of the handheld metal detector 12 parallel to the passenger's body, 13 moving the detector from the 14 passenger's shoulder down, then up in 15 two and three inch wide tracks until 16 the front area of the passenger's body 17 had been completely inspected; is that 18 correct? 19 MS. MONAGHAN: Object to the 20 form. 21 A. Yes, sir. 22 Q. Next page. At Dulles 23 Airport for American flights on 24 September 11, 2001, the proper 25 procedure for hand wanding a passenger 0027 1 DANA G. TURNER - CONFIDENTIAL 2 included moving around the passenger 3 and repeating the procedure on the 4 passenger's back; is that correct? 5 MS. MONAGHAN: Object to the 6 form. 7 A. Yes, sir. 8 Q. And repeating the procedure 9 means repeating the procedures that we 10 just described that were supposed to be 11 performed in front of the passenger; is 12 that right? 13 MS. MONAGHAN: Object to the 14 form. 15 MS. MURPHY: Object to the 16 form. 17 A. That's correct. 18 Q. And on September 11, 2001, 19 at Dulles Airport for American flights 20 at the checkpoint, screeners were 21 supposed to pay particular attention to 22 the foot and ankle areas because 23 weapons could be hidden in those areas; 24 is that correct? 25 MS. MURPHY: Object to the 0028 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 MR. CROWLEY: Object to the 4 form. 5 MS. MONAGHAN: Object to the 6 form. 7 A. Yes, sir. 8 Q. And on September 11, 2001, 9 at Dulles, at the checkpoint with 10 respect to American flights, every 11 source of metal was supposed to be 12 identified on the passenger in 13 connection with a handheld metal 14 detector search; is that right? 15 MR. CROWLEY: Object to the 16 form. 17 MS. MURPHY: Object to the 18 form. 19 MS. MONAGHAN: Object to the 20 form. 21 A. There are items that are so 22 very small that are not detectable. 23 Q. Smaller than a watch? 24 MS. MONAGHAN: Object to the 25 form. 0029 1 DANA G. TURNER - CONFIDENTIAL 2 A. I would say smaller than a 3 watch. But. 4 Q. Well, they tested the metal 5 detectors on their watches; correct? 6 MR. CROWLEY: Object to the 7 form. 8 MS. MONAGHAN: Object to the 9 form. She didn't testify to that. 10 MR. PEPE: I believe she 11 did. 12 MR. CROWLEY: Mischaracterization 13 of the testimony. 14 Q. On September 11, 2001 at 15 the American checkpoints at Dulles, is 16 it your understanding as a GSC that if 17 a passenger passed through the metal 18 detector once, alarmed it, passed 19 through the metal detector again, 20 alarmed it, that that passenger had to 21 undergo the hand wanding procedures 22 that we just described? 23 MS. MURPHY: Object to the 24 form. 25 MS. MONAGHAN: Object to the 0030 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. The source of detection had 4 to be cleared. 5 Q. Using the procedures we 6 just described? 7 MS. MONAGHAN: Object to the 8 form. 9 A. Yes, they had to be cleared. 10 Q. Using the procedures we 11 just described? 12 MS. MONAGHAN: Object to the 13 form. 14 A. Yes, they had to be cleared. 15 Q. Ma'am -- 16 MS. GOLDMAN: I'm having a 17 little trouble hearing. 18 Q. I just want to make sure 19 the record is clear, because when I ask 20 the question and you say yes, they had 21 to be cleared, and when I ask the 22 question were they cleared using those 23 procedures, you can answer however you 24 see fit. But it doesn't answer my 25 question. 0031 1 DANA G. TURNER - CONFIDENTIAL 2 So my question is, had to be 3 cleared using the procedures that we 4 just discussed; is that right? 5 MS. MONAGHAN: Object to the 6 form. 7 MR. CROWLEY: Object to the 8 form. 9 A. Correct. 10 Q. Thank you. 11 A. You're welcome. 12 Q. What was your date of 13 birth, ma'am? 14 A. 6/14/60. 15 Q. And where were you born? 16 A. Alexandria, Virginia. 17 Q. What is your current 18 address? 19 A. 310 Archer Court, 20 Barryville, Virginia. 21 Q. And how long have you been 22 there? 23 A. 1995. 24 Q. And do you have any 25 intention to move from that address? 0032 1 DANA G. TURNER - CONFIDENTIAL 2 A. I hope to. I don't want to 3 retire there. 4 Q. Any present intention to 5 move, are you moving, you know, are you 6 looking right now? 7 A. No. 8 Q. You are represented by 9 counsel today; is that correct? 10 A. Yes, sir. 11 Q. Is your counsel also 12 American's counsel? 13 A. Yes, sir. 14 Q. And is American paying your 15 counsel fees? 16 A. Yes, sir. 17 Q. And do you currently work 18 for American? 19 A. Yes, sir. 20 Q. What's your position at 21 American? 22 A. Currently? 23 Q. Yes. 24 A. Base manager, Washington, 25 flight service. 0033 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Base manager, you said? 3 A. Yeah. 4 Q. Is that just for Dulles or 5 is for that all of Washington? 6 A. For the three cities, 7 Baltimore, Washington Dulles and Regan. 8 Q. So you are in a managerial 9 position, a high level managerial 10 position right now? 11 MS. MONAGHAN: Object to the 12 form. 13 MR. CROWLEY: Object to the 14 form. 15 A. Yes. I'm not sure what high 16 is, but I'm in a managerial position, 17 yes. 18 Q. How many people report to 19 you directly or indirectly? 20 MS. MONAGHAN: Object to the 21 form. 22 A. For two days now, seven 23 managers and 400 and some odd flight 24 attendants. Prior to February 12, two 25 managers and approximately 110 flight 0034 1 DANA G. TURNER - CONFIDENTIAL 2 attendants. 3 Q. Did you get a promotion two 4 days ago? 5 A. I did. 6 Q. And what was the -- what 7 was your position prior to the 8 promotion two days ago? 9 A. Purser flight service 10 manager. 11 Q. And are you now in a 12 position to oversee purser flight 13 service managers? 14 A. As of two days ago? 15 Q. Yes. As of today. 16 A. As of today. I oversee the 17 managers who oversee our flight 18 attendants. So yes, indirectly I do. 19 Q. How many people in between 20 you and the president of the company in 21 your chain of command? 22 MS. MONAGHAN: Object to the 23 form. 24 If you know. 25 Q. If you know. 0035 1 DANA G. TURNER - CONFIDENTIAL 2 A. I really do not. 3 Q. Who is your immediate 4 supervisor? 5 A. John Tiliacos. 6 Q. What's John's position? 7 A. Regional managing director. 8 Q. What's the region? 9 A. Northeast region. 10 Q. So you report to the person 11 that's responsible for what in the 12 northeast region? 13 A. Flight service in the 14 northeast region. 15 Q. So all flight attendants? 16 A. And managers, yes. 17 Q. Have you met with counsel 18 to prepare for your deposition? 19 A. Yes, sir. 20 Q. How many times? 21 A. Twice. 22 Q. When? 23 A. Yesterday and a couple of 24 weeks ago. 25 Q. Did you get a raise two 0036 1 DANA G. TURNER - CONFIDENTIAL 2 days ago? 3 A. I did. 4 Q. Significant? 5 A. No. 6 Q. How much? 7 A. I really don't know. I 8 could give you a guess and a 9 percentage. 10 Q. Well, how much do you make 11 now? 12 A. 56,000 in a year. 13 Q. And how much was your last 14 paycheck? 15 A. I don't know. 16 Q. How much did you make last 17 year? 18 A. 56,000 last year. 19 Q. How much do you make today? 20 A. I don't know. 21 Q. Okay. 22 A. As I said, I can take a stab 23 at that as a percentage, but I don't 24 know. 25 Q. Better not to guess. 0037 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: I'm going to 3 hold you to that. 4 MR. PEPE: If I ask for a 5 guess I'm entitled to it. 6 THE WITNESS: It's not 7 important. 8 Q. Who was at the meetings 9 with counsel? 10 A. Just Maura and I the first 11 time. And Maura, I and Terrianne 12 yesterday. 13 Q. Only counsel? 14 A. Correct. 15 Q. And you? 16 A. And me, yes. 17 Q. Did you review any 18 documents to refresh your recollection 19 in preparation for your deposition? 20 A. Yes, sir. 21 Q. Did you review any items 22 that were not documents to refresh your 23 recollection in preparation for your 24 deposition? 25 A. No, sir. Items that were 0038 1 DANA G. TURNER - CONFIDENTIAL 2 not documents? 3 Q. Right. Well, documents, we 4 lawyers use documents in a very broad 5 sense. But documents and any tangible 6 items, knives, weapons, anything like 7 that. 8 A. We looked at a couple of 9 nonpaper pieces, yes. 10 Q. Tangible things? 11 A. Tangible stuff, yes, sir. 12 Q. So what documents did you 13 review? 14 A. The ACSSP. The COG. The 15 manifest, the passenger manifest for 16 77. 17 Q. Anything else? Training 18 file? 19 A. Yes. Thank you. 20 Q. We've been here before. 21 A. I'm sure other things that 22 I'm not thinking of that you will bring 23 to my attention later. 24 Q. That's all right. Let's 25 try and think of them. Is there 0039 1 DANA G. TURNER - CONFIDENTIAL 2 anything that comes to mind? 3 A. No, not at this particular 4 moment, no. 5 Q. This was at the meeting -- 6 sorry, I interrupted. 7 A. Not at this particular 8 moment nothing else is coming to me. 9 Q. This was at the meeting two 10 days ago? 11 A. Yesterday. 12 Q. The meeting yesterday. I'm 13 sorry, I blanked out. What were the 14 two meeting dates? 15 A. Yesterday and then a couple 16 of weeks ago. I don't recall the date. 17 Q. So let's just talk about 18 the meeting a few weeks ago. Did you 19 review the ACSSP at that meeting? 20 A. Yes, sir. 21 Q. Did you review the COG at 22 that meeting? 23 A. Yes. 24 Q. Did you review the manifest 25 for Flight 77 at that meeting? 0040 1 DANA G. TURNER - CONFIDENTIAL 2 A. Yes. 3 Q. Did you review your 4 training file at that meeting? 5 A. No. 6 Q. Did you review anything 7 else at that meeting, anything? 8 A. Not that I recall. 9 Q. Did you review those 10 tangible items we were talking about at 11 that meeting? 12 A. No, no tangible pieces. 13 Q. Did you review the section 14 of the COG at that meeting that we just 15 referred to relating to hand wanding? 16 A. No, sir. 17 Q. Let's go to the meeting 18 yesterday. Did you review the ACSSP 19 again yesterday? 20 A. Yes, sir. 21 Q. What sections? 22 A. GSC section. And I looked 23 at so many things yesterday, I'm not 24 100 percent sure. I'm sure a number of 25 other things as well, but that comes to 0041 1 DANA G. TURNER - CONFIDENTIAL 2 my mind. 3 Q. How about the COG, what 4 sections? 5 A. Not coming to me right now. 6 Q. Was it a chart? 7 A. Yes. 8 Q. Chart listing prohibited 9 items? 10 A. Correct. 11 Q. Anything else come to mind? 12 A. Or allowed. Prohibited or 13 allowed. 14 Q. Two charts? 15 A. Correct. 16 Q. Anything else? 17 A. Not at this time. 18 Q. You reviewed the manifest 19 yesterday? 20 A. I did, yes. 21 Q. Training file? 22 A. Yes, sir. 23 Q. Any other documents you, 24 you said you reviewed a lot of 25 documents, those are only four 0042 1 DANA G. TURNER - CONFIDENTIAL 2 documents. So anything else come to 3 mind? 4 A. Not at this time. 5 Q. How thick was the stack of 6 documents you reviewed? That's about 7 right. 8 Tangible things. What did 9 you look at? 10 A. Swiss Army knife, pair of 11 scissors. A smaller Swiss Army knife. 12 I believe that's it. 13 Q. Did you look at box 14 cutters? 15 A. Not tangibly. 16 Q. Did you look at pictures? 17 A. Um-hum. 18 Q. I'm sorry? 19 MR. CROWLEY: Just note my 20 objection. You are allowed to ask the 21 witness what she reviewed to refresh 22 her recollection to testify, you are 23 not allowed to ask the witness 24 everything she went over with her 25 counsel. 0043 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Did you review anything 3 else to refresh your recollection? 4 A. No, sir. 5 Q. So you told me Swiss Army 6 knives, scissors, small Swiss Army 7 knife. No other tangible items? 8 A. Not that I -- 9 MS. MONAGHAN: Object to the 10 form. 11 Q. Let's jump back. You were 12 talking about, I assume, and I want you 13 to tell me, did you look at pictures? 14 A. I did look at pictures. 15 Q. What pictures did you 16 review to refresh your recollection in 17 anticipation of your testimony? 18 A. Some knives. Utility 19 knives. 20 Q. Before you said box 21 cutters, box cutters was part of -- 22 A. It's a utility knife. 23 Q. Same thing; right? 24 MS. MONAGHAN: Object to the 25 form. 0044 1 DANA G. TURNER - CONFIDENTIAL 2 MR. CROWLEY: Objection to 3 the form. 4 A. In my mind, yes. 5 Q. And a box cutter is not a 6 pocket utility knife; right? 7 MR. CROWLEY: Object to the 8 form. 9 MS. MONAGHAN: Object to the 10 form. 11 A. A box cutter is not a pocket 12 knife, is that what you said? 13 Q. A pocket utility knife, 14 right. 15 A. I guess you can call it 16 whatever you'd like. To me they look 17 the same, utility knife. 18 Q. Is a utility knife the same 19 as a pocket utility knife? 20 MS. MONAGHAN: Object to the 21 form. 22 A. Utility knife the same as a 23 pocket utility knife? 24 Q. Yes. 25 A. You'd have to show me what 0045 1 DANA G. TURNER - CONFIDENTIAL 2 you're talking about. 3 Q. Well, just describe as you 4 understood it as a GSC on duty on 5 September 11, 2001, what was a box 6 cutter? 7 MS. MONAGHAN: Object to the 8 form. 9 Q. Just describe a box cutter 10 for me. 11 A. A box cutter to me would be 12 a blade with what you could open the 13 box. 14 Q. With a razor? 15 A. Could be a razor. 16 Q. Could it be anything else? 17 MS. MONAGHAN: Object to the 18 form. 19 A. Certainly can open a box 20 with a knife. 21 Q. So knives are box cutters 22 on September 11, 2001? 23 MR. CROWLEY: Object to the 24 form. 25 MS. MONAGHAN: Object to the 0046 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. A knife could open a box. 4 Is it a box cutter, no. The answer 5 would be no. 6 Q. Well, there was a specific 7 thing that was a box cutter that was a 8 prohibited item on September 11, 2001 9 as you understood it; correct? 10 MS. MONAGHAN: Object to the 11 form. 12 A. Yes. 13 Q. What was that thing? 14 MR. CROWLEY: Objection; 15 asked and answered. 16 MS. MONAGHAN: Object to the 17 form. 18 A. What was a box cutter? 19 Q. That was prohibited on 20 September 11, 2001, yes. 21 A. A razor blade of such, 22 encased in, it would be a plastic that 23 you could hold. 24 Q. We'll show you some box 25 cutters later. 0047 1 DANA G. TURNER - CONFIDENTIAL 2 A. Okay. 3 MS. MONAGHAN: Object to the 4 form. You can show her some things and 5 ask her what they are. 6 Q. What else did you review to 7 refresh your recollection, what other 8 pictures? Let's start with the knives, 9 what did the knives look like? 10 MS. MONAGHAN: Object to the 11 form. 12 A. The pictures of the knives? 13 Q. Yes. 14 A. Pocket knives. 15 Q. Anything else? 16 A. Utility knife. 17 Q. Anything else? 18 A. No. 19 Q. Did they have little 20 stickers on the bottom of them saying 21 exhibit? 22 A. The pictures did, yes. 23 Q. Did the knives have 24 stickers on them? I'm sorry, strike 25 that. 0048 1 DANA G. TURNER - CONFIDENTIAL 2 Did the tangible items, the 3 Swiss Army knife, the smaller Swiss 4 Army knife, did they have exhibit 5 stickers on them? 6 A. No. No, sir. 7 Q. Scissors didn't because we 8 don't have any scissors in this case. 9 Any other pictures other 10 than the ones you've told us about? 11 A. No, sir. 12 Q. Any other items other than 13 the documents you've told us about, the 14 tangible things you've told us about 15 and the pictures that you've told us 16 about that you've reviewed to refresh 17 your recollection in anticipation of 18 your testimony? 19 A. I can't think of anything 20 right this very second, but I'm certain 21 that you'll bring them to my attention. 22 Q. Well, I wasn't there, so I 23 might not be able to. 24 A. You've done it before. 25 Q. Did the pictures indicate 0049 1 DANA G. TURNER - CONFIDENTIAL 2 on the picture what the item was? Did 3 it say like, you know, this is a pocket 4 knife, this is a utility knife or 5 something of that nature? 6 A. No, they did not. 7 I did think of something. 8 Security directives, I did look at some 9 security directives. 10 Q. Do you remember how many? 11 A. No, sir. 12 Q. Do you remember what year 13 they were from? 14 A. '98 through 2001. Early 15 2001. 16 Q. Did they all relate to 17 CAPPS procedures? 18 A. I don't recall if all of 19 them related to that. 20 Q. Did two of them? 21 A. Yes. 22 Q. What did the other ones 23 relate to? 24 A. I don't recall at this 25 moment. 0050 1 DANA G. TURNER - CONFIDENTIAL 2 Q. The two relating to CAPPS 3 procedures, prior to reviewing them -- 4 strike that. 5 The two relating to CAPPS 6 procedures that you reviewed to refresh 7 your recollection, after reviewing them 8 did you have an independent 9 recollection of those procedures? 10 MS. MONAGHAN: Object to the 11 form. 12 Do you understand the 13 question? 14 A. Could you repeat it for me, 15 rephrase it. 16 MR. PEPE: Let's have it 17 read back. 18 (Record read as requested.) 19 Q. Independent of the 20 document. 21 A. Absolutely. 22 Q. Did you produce documents 23 to your counsel at any time for 24 production here? 25 MR. PEPE: Strike that, I'll 0051 1 DANA G. TURNER - CONFIDENTIAL 2 go back to that. 3 We'd request that all 4 documents that were produced to the 5 witness or that the witness reviewed to 6 refresh her recollection be produced in 7 the litigation. 8 Q. Did you produce documents 9 to counsel at any time? 10 A. No, sir. 11 Q. Do you have any documents 12 at home concerning your pre-9/11 13 employment? 14 A. Not that I recall. 15 Q. Training files, anything 16 like that? 17 A. No, sir. 18 Q. Handouts? 19 A. I can't say for sure. 20 Q. Were you asked to check? 21 A. No. 22 Q. So you didn't check? 23 A. If I had things at home that 24 related to this? 25 Q. Yes. 0052 1 DANA G. TURNER - CONFIDENTIAL 2 A. No. 3 Q. Were you asked to preserve 4 documents? 5 A. No. 6 MS. MONAGHAN: Object to the 7 form. 8 Q. So you didn't preserve 9 documents? 10 MS. MONAGHAN: Object to the 11 form. He is asking you if you 12 destroyed any documents relevant to the 13 litigation. 14 MR. PEPE: No, I did not. I 15 asked if she preserved them. 16 MS. MONAGHAN: If things are 17 not saved, there is an option besides 18 destroyed? 19 MR. PEPE: Your objection is 20 noted. 21 Q. You can answer. 22 A. Preserve? 23 Q. Did you preserve your 24 documents relating to your pre-9/11 25 employment or the events of 9/11? 0053 1 DANA G. TURNER - CONFIDENTIAL 2 MR. CROWLEY: Objection to 3 form. 4 MR. AMSTER: Objection. 5 MS. MONAGHAN: The documents 6 that you don't have that you don't know 7 about, he is asking you if you saved 8 them. 9 A. No. 10 Q. And is the no an answer to 11 my question? Because we will need it 12 read back. Because counsel is not 13 entitled to ask questions while I'm 14 asking. 15 (Record read as requested.) 16 MR. CROWLEY: Objection to 17 form. 18 MR. AMSTER: Objection to 19 form. 20 MR. CROWLEY: Objection to 21 no foundation. If the witness has any 22 documents related to pre-9/11 23 activities. 24 MR. PEPE: Ma'am, we will 25 have to have it read back again, and 0054 1 DANA G. TURNER - CONFIDENTIAL 2 the objections can carry forward for 3 the new reading. 4 (Record read as requested.) 5 A. No. 6 Q. When did you first start 7 your employment at American? 8 A. 1988. 9 Q. Where did you work before 10 that? 11 A. Prior to American? 12 Q. Yes. 13 A. Prior to American? 14 New York Air, Piedmont. 15 Q. Piedmont. 16 On 9/11, did you have access 17 to -- strike that. 18 On 9/11, did you have 19 work -- strike that. I apologize. 20 On September 11, 2001, did 21 you have an E-mail account at work? 22 A. Yes, sir. 23 Q. As you sit here today, do 24 you have any recollection of sending or 25 receiving an E-mail relating to the 0055 1 DANA G. TURNER - CONFIDENTIAL 2 events of September 11, 2001 from 9/11 3 to present? 4 MS. MONAGHAN: Object to the 5 form. 6 A. No, sir. 7 Q. Were you the GSC for Flight 8 77? 9 A. I was. 10 MS. MONAGHAN: Doug, are you 11 about to start a new line? 12 MR. PEPE: I might. You 13 want to take a break? 14 MS. MONAGHAN: Yes. 15 THE VIDEOGRAPHER: Off the 16 record, the time is 12:22. 17 (A recess was taken.) 18 THE VIDEOGRAPHER: Back on 19 the record, the time is 12:37. 20 BY MR. PEPE: 21 Q. Let's talk a little bit 22 about the events of 9/11 from your 23 perception. What time did you arrive 24 at work that morning? 25 A. Approximately 4:30 a.m. 0056 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And what was the first 3 thing you did when you arrived at work? 4 A. Quite typically check voice 5 mail for sick calls. 6 Q. I'm sorry, let's just back 7 up. Not typically, on that day. 8 A. I would have to answer the 9 same. 10 Q. You had an office? 11 A. I did. 12 Q. Where was your office? 13 A. Lower level, under gate 14 D-19. 15 Q. How many checkpoints 16 serviced Flight 77 that morning? 17 A. We have one security 18 checkpoint. 19 Q. And how did you refer to 20 that checkpoint, did it have a name? 21 A. West end. 22 Q. How far was your office 23 from the west end checkpoint on 24 September 11th? 25 A. Approximately half a mile. 0057 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Different floor or same 3 floor? 4 A. Different building 5 completely. 6 Q. So you got to work, checked 7 your voice mail. 8 MS. MONAGHAN: Object to the 9 form. 10 Q. What did you do after you 11 got to work again, so I don't have 12 LiveNote so I can't. 13 A. Checked voice mail. 14 Q. Anything else when you 15 first got to work? 16 A. I don't recall exactly what 17 I did that day. 18 Q. Let's try and bring out. 19 A. I was attempting to tell you 20 what a typical day for me was, but you 21 stopped me. So I don't know if you 22 wanted me to continue. 23 Q. I would like to know what 24 you remember on that morning. 25 A. As I said, I will tell you 0058 1 DANA G. TURNER - CONFIDENTIAL 2 what I did on a typical day. 3 Q. We may be able to get to 4 that, for now just focus on what you 5 did that morning, if you remember. 6 After you checked your voice 7 mail, do you remember doing anything on 8 September 11, 2001 at work? 9 A. I checked each terminator on 10 each gate. 11 Q. You checked each terminator 12 did you say? 13 A. I did. Or originator, 14 however you prefer to say it. An 15 airplane that terminates originates on 16 the same gate. 17 Q. Why don't you explain that, 18 because those are terms that are 19 unfamiliar to me. What was a 20 terminator, or what was it on September 21 11, 2001? 22 A. It's an airplane that came 23 in one night. Therefore terminating. 24 Q. Um-hum. 25 A. All of the servicing that 0059 1 DANA G. TURNER - CONFIDENTIAL 2 takes place on an overnight aircraft, 3 readying it for the morning departure, 4 which is called an originator. 5 Q. And Flight 77 was a 6 terminator on September 10th and an 7 originator on September 11th; is that 8 right? 9 A. No. 10 Q. Why don't you explain to me 11 what it was. 12 A. The aircraft itself was a 13 terminator and an originator. 14 Q. The aircraft with the tail 15 number that became Flight 77 on the 16 morning of September was a terminator 17 on September 10th; is that right? 18 A. Yes. 19 Q. And that same aircraft was 20 an originator for Flight 77 on the 21 morning of September 11th; is that 22 right? 23 A. Correct. 24 Q. So that morning on 25 September 11, 2001, after you checked 0060 1 DANA G. TURNER - CONFIDENTIAL 2 your voice mail, you said you checked 3 the terminator and the originators. 4 A. Yes. 5 Q. The terminators and the 6 originators. 7 A. Yes, sir. 8 Q. What did you -- what do you 9 specifically remember doing that 10 morning to check the terminators and 11 originators? 12 A. We can clarify this for you 13 I guess and make it easier. They are 14 originators. Because we are talking 15 about the morning departures. It's an 16 originator. 17 Q. I understand. 18 A. To check each of the 19 originators, albeit 77 included in 20 that. I would check for cleanliness, 21 supplies or lack thereof. And 22 servicing, I mean potable water, the 23 beautiful blue water. And all those 24 other supplies; soap, towels. Had it 25 been stripped of its catering 0061 1 DANA G. TURNER - CONFIDENTIAL 2 overnight. Had it been catered for the 3 morning departure. 4 Q. Okay. How many originators 5 were there on the morning of September 6 11, 2001? 7 A. I can't be certain, but 8 around ten. 9 Q. Were you the GSC for all 10 those originators? 11 A. I was one of the GSCs for 12 all of those originators. 13 Q. Well, were there GSCs 14 assigned to particular originators on 15 September 11, 2001? 16 A. No, there was just more than 17 one GSC on duty. 18 Q. And did they have 19 particular assignments? You're 20 responsible for this flight, somebody 21 else is responsible for that flight. 22 MS. MONAGHAN: Object to the 23 form. 24 A. No, we typically, because of 25 Washington Dulles setup, we typically 0062 1 DANA G. TURNER - CONFIDENTIAL 2 had a GSC at the ticket counter and a 3 GSC at the departure gates. 4 Q. And on September 11, 2001, 5 did you have a GSC at the ticket 6 counter? 7 A. Yes. 8 Q. Was that you? 9 A. No, sir. 10 Q. Who was it? 11 A. John Evans. 12 Q. And did you have a GSC at 13 the departure gates on September 11th? 14 A. Yes, sir. 15 Q. Was that you? 16 A. Yes, sir. 17 Q. Were there any other GSCs 18 on duty on September 11th in the 19 morning? 20 A. Not that I recall. 21 Q. So you checked all ten 22 originators that morning? 23 A. I did. 24 May I interject something 25 else as well? 0063 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Of course. 3 A. I was also responsible or a 4 part of that check was I was just 5 thinking what was gated, because all of 6 them were not gated. At some point 7 right before September 11th we took 8 over TWA, so we had four gates and then 9 we went to five. So the others would 10 not have typically been gated obviously 11 because we couldn't fit them. So we 12 would have, I don't remember if we had 13 four or five gates at that point, it 14 didn't matter, if we had five, we had 15 five at the gate and the other five 16 were remotely parked. 17 Q. So five of the ten would be 18 sitting at the gate and five of the ten 19 would be somewhere else? 20 A. Exactly. But I was also 21 responsible for ensuring that, and I 22 did this, I would typically walk around 23 on the ground, because our Super 80, 24 MacDonnell Douglas Super 80 have aft 25 stairs. I was required to make sure 0064 1 DANA G. TURNER - CONFIDENTIAL 2 that those were up. 3 Q. Were you the GSC -- strike 4 that. 5 Were you a GSC on duty at 6 Dulles on September 10th? 7 MS. MONAGHAN: 2001? 8 MR. PEPE: 2001. 9 A. I'm not certain. What day 10 of the week was it? 11 Q. Monday. 12 A. I'm still not certain. 13 Q. Did you -- do you recall 14 having any responsibilities with 15 respect to the plane that became Flight 16 77 on September 11th, on September 17 10th? Sorry, it's a little bit 18 cumbersome. 19 MS. MONAGHAN: Object to the 20 form. 21 MR. AMSTER: Object to the 22 form. 23 A. Was I on duty for the 24 terminator which turned the originator 25 77, not that I recall. 0065 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Much better than my 3 question. I'm learning some new words 4 today. 5 When you checked the 6 originators on September 11, 2001, you 7 gave a list of things that you did. 8 Let's focus specifically on Flight 77. 9 Do you remember what gate Flight 77 was 10 at? 11 A. I do. 12 Q. What gate? 13 A. D-26. 14 Q. How did you board the 15 plane? 16 MR. AMSTER: We are having 17 trouble hearing the questions and the 18 answers. 19 MR. PEPE: I'll speak up. 20 MR. AMSTER: It's not going 21 to help with the sirens. 22 Q. So how did you board Flight 23 77? 24 MS. MONAGHAN: Object to the 25 form. Do you mean how did she 0066 1 DANA G. TURNER - CONFIDENTIAL 2 personally get on board or do you mean 3 how did American Airlines conduct the 4 boarding of Flight 77? 5 MR. PEPE: No. 6 Q. How did you personally 7 board Flight 77 on the morning of 8 September 11th? 9 A. When I was doing my checks? 10 Q. Yes. 11 A. Via the jet bridge stairs. 12 Q. Is there anything in 13 between the time you checked your voice 14 mail when you arrived in the morning 15 and the boarding of, by you, on Flight 16 77 on the morning of September 11, 17 2001, that you can recall that you 18 haven't told us? 19 MS. MONAGHAN: Object to the 20 form. 21 A. Nothing specifically on 22 September 11th. Again, a typical day. 23 Q. Tell me a typical day. 24 A. As a customer service 25 manager at Washington Dulles, and I 0067 1 DANA G. TURNER - CONFIDENTIAL 2 know this doesn't speak for every city, 3 it's based on size. At Washington 4 Dulles a customer service manager is 5 responsible for folks inside and 6 outside, ticketing agents or agents and 7 clerks. So a typical day had me 8 involved in numerous things, be it 9 inside or out. 10 Q. You were the, you 11 testified, I will try and find, you 12 were the GSC of the departure gates on 13 September 11th. When you typically 14 were the GSC at the departure gates, 15 would you also involve yourself or be 16 involved in the ticketing process? 17 MS. MONAGHAN: Object to the 18 form. 19 A. Ticketing process, are you 20 talking about at the ticket counter or 21 the ticketing process of putting people 22 on an airplane at a gate? 23 Q. You said a customer service 24 manager is responsible for folks inside 25 and outside, ticketing agents or agents 0068 1 DANA G. TURNER - CONFIDENTIAL 2 and clerks. When you were the 3 departure gate GSC, would you typically 4 have those duties or responsibilities? 5 MS. MONAGHAN: Object to the 6 form. 7 A. Let me clarify for you. 8 Q. Sure. 9 A. There are ticket agents at 10 the ticket counter who produce tickets. 11 So maybe it's terminology on my part 12 that's confused you. They are agents 13 at the gate. They collect tickets. I 14 was responsible for both agents and 15 clerks. So was I at the ticket counter 16 and responsible for those people, the 17 answer would be no. 18 Q. Were you at the ticket 19 counter at any point from -- strike 20 that. 21 Were you at the ticket 22 counter at any time during the morning 23 of September 11, 2001? 24 A. No. 25 Q. Were you at the checkpoint 0069 1 DANA G. TURNER - CONFIDENTIAL 2 at any time during the morning of 3 September 11, 2001? 4 A. No. 5 Q. Were you at the -- strike 6 that. 7 When you boarded Flight 77 8 on the morning of September 11, 2001, 9 were there any passengers on it? 10 A. Not when I did the security 11 checks that I did, the originator 12 checks. 13 Q. So when you did the 14 originator checks, the plane was empty? 15 A. Correct. 16 Q. And explain to me the 17 checks that you remember doing, 18 specifically remember doing on 19 September 11, 2001, with respect to 20 Flight 77. 21 A. I thought that I just did 22 that. 23 Q. Well, we were talking a bit 24 generally, and you said it includes 25 Flight 77, I want to make sure the 0070 1 DANA G. TURNER - CONFIDENTIAL 2 record is clear as to what you remember 3 doing with respect to Flight 77 when 4 you boarded it on September 11, 2001. 5 MS. MONAGHAN: Object to the 6 form. 7 A. As I boarded the aircraft on 8 Flight 77, I entered the forward lav, I 9 would have flushed the toilet to make 10 sure the water was blue and not green. 11 I would have turned the water on to 12 make sure there was potable water 13 coming out so you would be able to wash 14 your hands. I would check to make sure 15 that there were paper towels in the 16 paper towel holders, Kleenexes in the 17 Kleenex holder, toilet paper on the 18 roll. I did that in every lavatory 19 that was on 77. 20 I went into the galley, I 21 would open the cupboards to make sure 22 there were plastic and styrofoam cups, 23 I would make sure there was coffee. I 24 would make sure there were SOS kits, an 25 SOS kit means, had Sweet'N Lo, tea 0071 1 DANA G. TURNER - CONFIDENTIAL 2 bags, and the more absorbent paper 3 towels, not the ones used in the lav. 4 I would go to the back of 5 the aircraft once I had checked all of 6 the lavatories, and I would walk 7 forward from back to front, making sure 8 that the literature in the seat back 9 pockets was in each seat back pocket, 10 because -- 11 Q. Let's stop there. 12 Physically or look? 13 A. Look. 14 Q. Okay, keep going. 15 A. It's a fineable offense if I 16 didn't have a safety briefing card in 17 the seat back pocket of every seat. 18 That was my job. One of many. 19 I would make sure that the 20 movies or did make sure that the movies 21 were on board Flight 77. 22 Q. Let's just back up. Was 23 there a safety briefing card missing in 24 any seat on September 11th? 25 A. Not that I recall. 0072 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Movies. What next? 3 A. I had the potable water 4 gauge. And that's it, that I can 5 recall right now. 6 MR. KLEIN: What was that 7 last response? 8 THE WITNESS: Potable water 9 gauge. Water gauge. 10 Q. Anything else? 11 A. Not that I can recall right 12 now. 13 Q. Then did you leave the 14 plane the same way you came on board? 15 A. Typically I would walk up 16 the bridge to the next airplane. But I 17 don't recall what way I went that day, 18 no. 19 Q. Did you service, service in 20 the sense that we are using here, did 21 you do these -- strike that. 22 Did you perform these duties 23 with respect to any other planes prior 24 to Flight 77 on the morning of 25 September 11th? 0073 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Object to the 3 form. 4 A. Let me make sure I 5 understand your question. On September 6 11th did I do the same thing I did on 7 Flight 77 to all the other originators? 8 Q. Was it the first originator 9 you went to? 10 A. No. 11 Q. What was the first one you 12 went to? 13 A. The first one of the day, 14 and I don't recall what one that was. 15 I always did it in order of departure. 16 Q. And judging from departure 17 gate -- departure time or gate? 18 A. Time. 19 Q. How did Flight 77 fit in 20 with respect to the originators at 21 Dulles on September 11th in terms of 22 departure time? 23 MS. MONAGHAN: Object to the 24 form. 25 A. You don't have an RGG for 0074 1 DANA G. TURNER - CONFIDENTIAL 2 that day; do you? 3 Q. I'm sure your counsel does, 4 I don't. 5 A. I don't recall a specific 6 order. I would say third or fourth. 7 Maybe fourth. 8 Q. Well, that would be a 9 matter of record; right? 10 A. Sure, absolutely. 11 Q. On the RGG? 12 A. Yes. 13 Q. What's that an acronym for? 14 A. I don't know that it has 15 one. 16 Q. How long did it take you to 17 perform these functions with respect to 18 Flight 77 on September 11, 2001? 19 MS. MONAGHAN: Object to the 20 form. 21 A. Well, I would say probably 22 about fifteen minutes. 23 Q. Do you lock the door of the 24 plane after you leave? 25 A. The aircraft door? 0075 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Yes. 3 A. No. 4 Q. How long does it take you 5 to walk from your office to the gate 6 where Flight 77 was located on 7 September 11th? 8 A. Two minutes or less. 9 Q. So we are roughly in the 10 time period of 5:40? 11 MS. MONAGHAN: Object to the 12 form. 13 Q. By the time you are walking 14 out of Flight 77? 15 A. You are asking me to 16 speculate. I would assume somewhere 17 around there. It was early. 18 Q. Do you remember what time 19 it was? 20 A. No, I don't. 21 Q. What happened next? 22 A. After what? 23 Q. After you left Flight 77. 24 A. I would have gone to the 25 next departure. And done the same 0076 1 DANA G. TURNER - CONFIDENTIAL 2 exact thing that I did on 77. 3 Q. And each plane would take 4 approximately fifteen minutes? 5 A. Approximately. Depending on 6 the size. How many times I had to 7 flush. 8 Q. Whether it's green or blue? 9 A. Green or blue. 10 Q. And do you remember doing 11 anything on September 11, 2001 from the 12 time you went to the first plane to the 13 time you finished with the last plane? 14 MS. MONAGHAN: Object to the 15 form. 16 Q. Other than your 17 responsibilities with respect to the 18 planes themselves. 19 MS. MONAGHAN: Eric, could 20 you read that back. 21 MR. PEPE: I can rephrase 22 it. We can go on for hours with this 23 sort of thing. I'm just trying to get 24 time lines. 25 Q. Was there anything you did 0077 1 DANA G. TURNER - CONFIDENTIAL 2 other than performing these services 3 with respect to the planes from the 4 first one to the last one on September 5 11th? 6 MS. MONAGHAN: All day? 7 MR. PEPE: No, there were 8 ten planes. She started with one, and 9 I'm trying to find out from the time 10 she started with one to the time she 11 finished with the last one, if she 12 remembers doing anything else. 13 MS. MONAGHAN: Object to the 14 form. 15 But you can answer if you 16 understand. 17 THE WITNESS: I understand 18 the question. 19 A. You are asking me something 20 for a very particular day. 21 Q. Yes. 22 A. I can tell you what a 23 typical day was. 24 Q. Um-hum. 25 A. But specific to 9/11, 0078 1 DANA G. TURNER - CONFIDENTIAL 2 typically I did those airplanes, and 3 after I did the ones that were on the 4 gate, I was responsible for making sure 5 that the aircrafts got loaded properly. 6 Q. With the bags? 7 A. Bags, cargo, mail. 8 Q. What do you mean loaded 9 properly? 10 A. We had crew chiefs outside 11 on the ramp who were responsible for 12 the clerks, kind of a, how shall I say? 13 I'm the supervisor on duty. You have a 14 crew chief and you have clerks. So the 15 crew chief was responsible for the 16 clerks to make sure that the 17 aircrafts -- had a load plan to make 18 sure that the bags were loaded 19 properly, freight, mail, cargo. I 20 would ensure with the crew chief that 21 that had been done. Just as I would 22 with agents to make sure that all was 23 well with our world upstairs. 24 Q. Was American Airlines 25 responsible for ensuring that there 0079 1 DANA G. TURNER - CONFIDENTIAL 2 were no prohibited items on board the 3 aircraft on September 11, 2001, prior 4 to passengers boarding them? 5 MS. MONAGHAN: Object to the 6 form. 7 A. Can you rephrase it for me? 8 Q. We can have it read back. 9 A. Sure. 10 (Record read as requested.) 11 A. Yes. 12 Q. And as the departure gate 13 GSC on duty on September 11, 2001, at 14 Dulles, with respect to American 15 flights, was it your responsibility to 16 ensure that no prohibited items were on 17 board the aircraft prior to passengers 18 boarding them? 19 MS. MONAGHAN: Object to the 20 form. 21 A. If you're asking me if the 22 buck stopped here? 23 Q. Yes. 24 A. It did, yes. I am not the 25 sole person. 0080 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Who were the others on 3 September 11th who had that 4 responsibility? 5 A. We had policies and 6 procedures at American Airlines, just 7 as I'm sure they do everywhere else, 8 that people are trained to do what they 9 do. And if they see things or hear 10 things or observe things that they are 11 uncomfortable with, they are trained, 12 and I am the sole responsible person 13 that they would come to to resolve the 14 issue. 15 Q. And on September 11, 2001, 16 with respect to Flight 77, did anyone 17 come to you with respect to -- strike 18 that. 19 On September 11, 2001, as 20 the GSC at the departure gates with 21 whom the buck stopped, did anyone 22 indicate to you that there was anything 23 suspicious with respect to what was on 24 board the planes prior to passengers 25 boarding them? 0081 1 DANA G. TURNER - CONFIDENTIAL 2 A. No, sir. 3 MS. MONAGHAN: Object to the 4 form. Belatedly. 5 Q. And you have no knowledge 6 of any prohibited items being on board 7 the planes -- strike that. 8 You have no knowledge of any 9 prohibited items being on board Flight 10 77 prior to the passengers boarding 11 them; is that correct? 12 MS. MONAGHAN: Object to the 13 form. 14 A. That is correct. 15 Q. Who was the GSC supervising 16 the checkpoint on September 11, 2001? 17 MS. MONAGHAN: Object to the 18 form. 19 A. They have their own CSS 20 overseeing the security checkpoint. I 21 had a GSC at the ticket counter if 22 that's what you're asking me. 23 Q. I'm just asking who was the 24 GSC on September 11th who supervised 25 the checkpoint? 0082 1 DANA G. TURNER - CONFIDENTIAL 2 MR. CROWLEY: Object to the 3 form. 4 MS. MONAGHAN: Object to the 5 form. 6 A. We aren't supervisors of the 7 checkpoint. The checkpoint has its own 8 supervisor. I have a GSC at the ticket 9 counter and a GSC at the departure 10 gate. 11 Q. Which GSC, or who, if 12 anyone, on September 11, 2001, did the 13 buck stop with concerning checkpoint 14 security? 15 MR. CROWLEY: Object to the 16 form. 17 MS. MONAGHAN: Object to the 18 form. 19 A. Had a GSC been called to the 20 checkpoint, it would have been the one 21 at the ticket counter. 22 Q. So the ticket counter GSC 23 is the GSC responsible for overseeing 24 the checkpoint? 25 MS. MONAGHAN: Object to the 0083 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. Is the GSC -- say it again. 4 Q. Sure, let's have it read 5 back. 6 (Record read as requested.) 7 Q. On September 11th. 8 A. We have a GSC who was 9 responsible for -- who took 10 responsibility for monitoring that or 11 testing them or I'm not certain of the 12 terminology. But as I said before, and 13 I'll say it again, they have security 14 checkpoint supervisors. 15 Q. Understood. 16 On September 11, 2001, was 17 it a federal aviation regulation 18 requirement that a ground security 19 coordinator at each airport must daily 20 review all security related functions 21 for effectiveness and compliance with 22 applicable regulations, the certificate 23 holder's security program and 24 applicable security directives? 25 A. Do you have a short version? 0084 1 DANA G. TURNER - CONFIDENTIAL 2 Q. No, we have to have it read 3 back. 4 A. Okay. 5 (Record read as requested.) 6 A. I don't recall. That was 7 not my job function. 8 Q. You mean your job function 9 as the gate GSC? 10 A. Correct. 11 Q. Whose job function was it? 12 A. It would have been a 13 function of the GSC at the ticket 14 counter. 15 Q. Had you been a GSC at the 16 ticket counter before September 11, 17 2001? 18 A. No. 19 Q. You were always at the 20 gate? 21 A. I was always at the gate. 22 Q. On September 11, 2001, as 23 an American GSC, were you aware that a 24 ground security coordinator was 25 responsible under the applicable 0085 1 DANA G. TURNER - CONFIDENTIAL 2 federal aviation regulations to daily 3 initiate corrective action for each 4 instance of noncompliance with the 5 federal aviation regulations, the 6 certificate holder's security program 7 and applicable security directives? 8 MS. MONAGHAN: Object to the 9 form. 10 MR. CROWLEY: Object to the 11 form. 12 A. Was I aware that a GSC had 13 to oversee the supervisor at the 14 checkpoint? 15 Q. No. Let's have it read 16 back so that you have the full context. 17 (Record read as requested.) 18 A. Yes. 19 MR. PEPE: I would like to 20 mark an exhibit. 21 (Turner Exhibit 287 for 22 identification, standards for security 23 oversight.) 24 MR. PEPE: Marking as an 25 exhibit, Exhibit No. 287, which is the 0086 1 DANA G. TURNER - CONFIDENTIAL 2 Code of Federal Regulations Title 14, 3 Chapter 1, Subchapter F, Part 108, 4 Section 108.29, standards for security 5 oversight. 6 Q. If you could please take a 7 look at that. Just let me know when 8 you're done. 9 All set? 10 A. All set. 11 Q. On September 11, 2001, as 12 an American GSC, you were trained in 13 applicable federal regulations, 14 including Section 108.29, which is 15 Exhibit 287; is that right? 16 MS. MONAGHAN: Object to the 17 form. 18 A. I am trained as a GSC, yes. 19 Q. And were you trained in 20 regulations that governed the 21 checkpoint, including Section 108.29 22 that I've just presented to you? 23 MS. MONAGHAN: Object to the 24 form. 25 A. I was trained but not on 0087 1 DANA G. TURNER - CONFIDENTIAL 2 September 11th was I over there doing 3 this, if that's what you're asking me. 4 Q. No, I'm asking if you 5 received training as to whether these 6 were the requirements for ground 7 security coordinators. 8 A. Yes. 9 Q. As you sit here today, is 10 it your testimony that you don't know 11 who performed these duties on September 12 11th? 13 MS. MONAGHAN: Object to the 14 form. Mischaracterizes her testimony. 15 MR. PEPE: I'm asking what 16 her testimony is. 17 MS. MONAGHAN: Well then 18 it's asked and answered. 19 MR. PEPE: Can I have the 20 question read back. 21 (Record read as requested.) 22 A. John Evans was the GSC at 23 the ticket counter on September the 24 11th. I was the GSC on September 11th 25 of the departure gates. And no, it was 0088 1 DANA G. TURNER - CONFIDENTIAL 2 not me. And you are asking me to 3 answer for John. 4 Q. I'm just asking you if you 5 know who did it. 6 A. No. 7 Q. What time did you hear 8 that -- strike that. 9 When was the first moment 10 that you learned that something unusual 11 happened on September 11, 2001? 12 A. Early in the day. You are 13 asking me for a time? 14 Q. Exact, approximate. Give 15 us the best you can do. 16 A. Somewhere between 8 and 17 8:30. 18 Q. And what did you hear? 19 A. I heard an aircraft 20 maintenance gentleman come up and say 21 to me that something has happened in 22 New York, an aircraft has hit a 23 building. And that's all I really 24 heard at that point. 25 Q. Okay, so where were you? 0089 1 DANA G. TURNER - CONFIDENTIAL 2 A. D-24. 3 Q. At the gate, on the plane? 4 Where were you? 5 A. At the gate D-24. 6 Q. Ticket counter? 7 A. At the gate. Departure 8 gate. 9 Q. The gate is a big place, 10 though, where at the gate? Standing 11 behind the booth? 12 MS. MONAGHAN: You mean the 13 podium thing? 14 MR. PEPE: I don't know 15 where physically at the gate you were. 16 MS. MONAGHAN: I'm going to 17 object to the form. Ticket counter is 18 different from the date. 19 Q. Where at the gate were you, 20 was it at the place where they collect 21 tickets from passengers or was it 22 somewhere else? 23 A. It was not behind the 24 podium. It was standing -- podium. 25 Door to the jet bridge. Seating area. 0090 1 DANA G. TURNER - CONFIDENTIAL 2 Seating area. Aircraft maintenance 3 came through that door. 4 MS. MONAGHAN: Dana, the 5 court reporter can't get down when you 6 point to places. If you could verbally 7 describe it. 8 MR. PEPE: I don't think 9 this is important for purposes of the 10 record. 11 Q. I'm just trying to 12 understand where you were. So a 13 maintenance employee came up to you at 14 that location? 15 A. He came through the door. I 16 don't think he came specifically 17 looking for me. 18 Q. Who was it? 19 A. I don't recall. I don't 20 remember his name. 21 Q. Had Flight 77 taken off? 22 A. Yes. 23 Q. How long prior to you 24 hearing that? 25 A. Not very long before. 0091 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Ten minutes, half an hour? 3 A. Maybe around 20 minutes. 4 20, 25 minutes. 5 Q. What did you do when you 6 heard that? 7 A. I asked the agent who was 8 standing at D-24, who was due off at 9 9 or 9:30, I don't really remember, that 10 until we determined what was actually 11 going on, she would need to stay on the 12 clock. 13 Q. What flight was leaving 14 D-24 that morning? 15 A. I don't recall. 16 Q. Had the flight left? 17 A. No. 18 Q. Had it been boarded? 19 A. Yes. 20 Q. Fully boarded? 21 A. I don't recall passengers in 22 the lounge, no. 23 Q. Well, do you remember, do 24 you have an actual recollection as to 25 whether it was fully boarded or not? 0092 1 DANA G. TURNER - CONFIDENTIAL 2 And if the answer is you don't 3 remember, that's fine. I just need to 4 know. 5 A. That's the answer. 6 Q. Which is? 7 A. I do not recall. 8 Q. Did that plane take off? 9 A. I do not recall. 10 Q. What happened next? 11 MS. MONAGHAN: Object to the 12 form. 13 MR. PEPE: What's wrong with 14 it? 15 MS. MONAGHAN: Next after 16 what? 17 MR. PEPE: I'm sorry. 18 Q. What happened after you had 19 the conversation with the American 20 Airlines person who was at gate D-24? 21 A. I went downstairs to 22 operations. 23 Q. Okay. Did you hear 24 anything else in between the time that 25 you left the gate and the time you went 0093 1 DANA G. TURNER - CONFIDENTIAL 2 to operations? 3 A. No. 4 Q. All right. What happened 5 next? 6 A. We began to get calls for 7 diversions. 8 Q. Okay. What else? 9 MS. MONAGHAN: Object to the 10 form. 11 A. Almost immediately or 12 shortly thereafter we began getting 13 numerous airplanes or calls from 14 airplanes coming our way. Because we 15 have longest runways on the east coast. 16 Q. Were planes allowed to fly 17 over the White House on September 11th? 18 MS. MONAGHAN: Object to the 19 form. Generally? 20 Q. If you understand my 21 question, you can answer. 22 MS. MONAGHAN: I don't 23 understand it. I object to the form. 24 MR. CROWLEY: Object to the 25 form also. 0094 1 DANA G. TURNER - CONFIDENTIAL 2 MR. AMSTER: Object to the 3 form. 4 A. I don't recall. 5 Q. Were American flights 6 allowed to fly over the White House on 7 September 11th? 8 MS. MONAGHAN: Object to the 9 form. 10 A. It wouldn't be air carrier 11 specific, I wouldn't believe. But I 12 don't recall. 13 Q. Do you know whether there 14 were any airspace restrictions over the 15 White House on September 11, 2001, as a 16 GSC for American? 17 MS. MONAGHAN: Object to the 18 form. 19 A. I don't recall. 20 Q. Do you recall any training 21 you received on that? 22 A. No. 23 Q. Did any American employees 24 to your knowledge have meetings with 25 the Secret Service about the airspace 0095 1 DANA G. TURNER - CONFIDENTIAL 2 restrictions that were imposed over the 3 White House, if any, on September 11, 4 2001 and prior? 5 MS. MONAGHAN: Object to the 6 form. 7 A. No, sir. 8 Q. Did you ever hear of a man 9 named Samuel Byck? 10 A. No, sir. 11 Q. Did you ever hear of a man 12 that attempted to hijack a plane out of 13 BWI Airport and dive bomb it into the 14 White House? 15 MS. MONAGHAN: Object to the 16 form. 17 A. As we sit here today I don't 18 recall, no. 19 Q. Did you ever receive any 20 training on that issue? 21 MS. MONAGHAN: Object to the 22 form. 23 A. On what issue? 24 Q. A plot by Samuel Byck to 25 hijack a plane out of BWI Airport and 0096 1 DANA G. TURNER - CONFIDENTIAL 2 crash it into the White House. 3 MS. MONAGHAN: Object to the 4 form. 5 A. I don't recall that specific 6 training today, no. 7 MS. MONAGHAN: Doug, are you 8 about to start a new line? 9 MR. PEPE: Not a whole line. 10 But I would like to continue with this 11 for a couple of minutes unless you 12 absolutely need a break. 13 MS. MONAGHAN: We can go 14 another five or ten minutes. 15 MR. PEPE: Let's mark 16 another exhibit. 17 (Turner Exhibit 288 for 18 identification, articles, production 19 numbers BYCK 001 through BYCK 008.) 20 Q. I'm going to show you 21 what's been marked as Exhibit 288, 22 which is a compilation of news articles 23 from 1974, Bates stamped BYCK 1 through 24 BYCK 8. Which include documents 25 indicating where the news articles were 0097 1 DANA G. TURNER - CONFIDENTIAL 2 purchased from, archives of the 3 Washington Post and New York Times 4 available on the internet. 5 Ma'am, 1974 was more than 6 twenty years ago; is that right? 7 A. Yes. 8 Q. Can you please read the 9 first paragraph into the record of the 10 first document. 11 A. "A gunman who shot his way 12 aboard a jet airliner last week at the 13 Baltimore Washington International 14 Airport intended to crash dive the 15 plane into the White House." 16 Q. Prior to September 11, 17 2001, did anyone at American Airlines 18 that a gunman who shot his way aboard a 19 jet airliner in 1974 at the Baltimore 20 Washington International Airport 21 intended to crash dive the plane into 22 the White House? 23 MR. CROWLEY: Objection; 24 asked and answered. 25 MS. MONAGHAN: Object to the 0098 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. I don't recall that, no. 4 Q. Did you ever hear of the 5 play Assassins? 6 A. I'm sorry, the play 7 Assassins? 8 Q. Play Assassins, yes. 9 A. No, sir. 10 Q. So we were talking about 11 your conversation at gate D-24, and 12 then you went down to operations. And 13 I would like you to tell me everything 14 you remember occurring at operations. 15 What did you hear? 16 MS. MONAGHAN: Object to the 17 form. 18 Q. What did you see? 19 Everything. Who told you what? 20 MS. MONAGHAN: Object to the 21 form. It just keeps getting worse. 22 If you understand the 23 question, you can try and answer. 24 MR. PEPE: I don't know what 25 happened that day. 0099 1 DANA G. TURNER - CONFIDENTIAL 2 MR. CROWLEY: Objection. 3 MS. MONAGHAN: You've just 4 got to ask questions. 5 Go ahead. 6 (Witness and counsel 7 confer.) 8 MR. PEPE: I'll withdraw it 9 and we will come back. 10 THE VIDEOGRAPHER: Off the 11 record, the time is 1:22, and this is 12 the end of tape No. 1. 13 (Luncheon recess: 1:22 p.m..) 14 15 16 17 18 19 20 21 22 23 24 25 0100 1 DANA G. TURNER - CONFIDENTIAL 2 A F T E R N O O N S E S S I O N. 3 2:32 p.m. 4 THE VIDEOGRAPHER: We are 5 back on the record, the time is 2:23. 6 D A N A G. T U R N E R, 7 resumed, having been previously duly 8 sworn, was examined and testified 9 further as follows: 10 CONTINUED EXAMINATION 11 BY MR. PEPE: 12 Q. Ms. Turner, in your 13 capacity as a GSC for American prior to 14 September 11th, did you have occasion 15 to receive training from American 16 Airlines? 17 MS. MONAGHAN: Objection to 18 form. 19 A. Ground security coordinator 20 training? 21 Q. Yes. 22 A. Yes. 23 Q. Did you receive initial 24 training? 25 A. Yes. 0101 1 DANA G. TURNER - CONFIDENTIAL 2 Q. When did you receive that 3 initial training? 4 A. '95. 5 Q. And did you receive 6 recurrent training? 7 A. Yes. 8 Q. Did you receive it every 9 year? 10 A. Yes. 11 Q. When was the recurrent 12 training that you had immediately 13 preceding September 11th? 14 A. The month? 15 Q. Month, season. 16 A. Early 2001. Mid-2001. 17 Q. During your training, did 18 you receive handouts? 19 A. Yes. 20 Q. Where was the training 21 conducted? 22 A. Dallas-Fort Worth. FSU. 23 Q. And it was conducted by 24 American Airlines employees? 25 A. Yes. 0102 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Who gave you your recurrent 3 training in 2001? 4 A. I don't know. 5 Q. One person or two? 6 A. As I recall, one. 7 Q. Man, woman? 8 A. Man. 9 Q. Let me show you what's been 10 marked as Exhibit 276. This is a 11 document Bates range -- it's already 12 been marked. 13 Is this the recurrent 14 training handout that you received at 15 your recurrent training in 2001? 16 A. Appears to be, yes. 17 Q. If you could turn to page 2 18 of this document, please. 19 MR. CROWLEY: Counsel, which 20 exhibit is it? 21 MR. PEPE: This is 276. 22 MR. CROWLEY: Thank you. 23 Q. There are a number of 24 questions on this document. Do you 25 recall being quizzed using these 0103 1 DANA G. TURNER - CONFIDENTIAL 2 questions in your recurrent training in 3 2001? 4 A. I'm sure that we were as a 5 part of the class. But do I recall 6 specifics, no, I don't. 7 Q. Well, let's look at 8 question 20. Could you please read 9 question 20 into the record. 10 A. "Who does the U.S. State 11 Department recognize as the number 1 12 terrorist whom is bankrolling events 13 against U.S. interests?" 14 Q. And what's the answer to 15 that question, as it was when you took 16 the test in 2001? 17 A. Osama Bin Laden. 18 Q. If you could turn to the 19 next page, please. Question 21, what 20 were the total FAA alleged fines for AA 21 and AE first quarter 1999 and what were 22 the top seven violations. That's 21 23 and 22, I think. 24 Can you answer those 25 questions? 0104 1 DANA G. TURNER - CONFIDENTIAL 2 A. No, I can't. 3 Q. Do you know whether it was 4 in the millions? 5 A. I don't know. 6 Q. I will show you what's been 7 marked as Exhibit 275. Please turn to 8 page 16385. 9 Do you see this slide? 10 A. I do. 11 Q. Do you remember seeing this 12 slide in your recurrent training? 13 A. Specifically, no. It if it 14 was a part of the training then I saw 15 it. 16 Q. Does this refresh your 17 recollection as to whether the fines 18 AA -- reported fines for AA and AE in 19 the year 2000 were in the millions? 20 MR. AMSTER: Object to the 21 form. 22 A. It does refresh my memory 23 having read this, yes. 24 Q. And does it refresh your 25 recollection as to whether the first 0105 1 DANA G. TURNER - CONFIDENTIAL 2 quarter fines for 170 alleged 3 violations in 2000 were $1,940,900? 4 MS. MONAGHAN: Object to the 5 form. 6 A. That's what it reads, yes. 7 Q. That's a lot of fines; 8 right? 9 MS. MONAGHAN: Object to the 10 form. 11 MR. CROWLEY: Object to the 12 form. Compared to what? 13 MR. PEPE: I strenuously, 14 and I don't often use that word, object 15 to your putting statements on the 16 record and coaching the witness. 17 MR. CROWLEY: It's not my 18 witness, I'm not coaching anybody, 19 counsel. I'm saying compared to what, 20 you have no foundation to your 21 question. 22 MR. PEPE: Then you can 23 object to foundation, don't suggest 24 answers. 25 MS. MONAGHAN: Can you read 0106 1 DANA G. TURNER - CONFIDENTIAL 2 back the question. 3 MR. PEPE: Sure. 4 (Record read as requested.) 5 MS. MONAGHAN: I still 6 object to the form. 7 A. With regard to? Compare it 8 to something for me. 9 Q. 170 alleged violations 10 first quarter, 175 alleged violations 11 second quarter, 170 alleged violations 12 in the third quarter. That's three 13 quarters, total of $5.649 million in 14 fines, I'm asking you if as a GSC for 15 American Airlines prior to September 16 11, 2001, you thought that was a lot of 17 fines. 18 MS. MONAGHAN: Object to the 19 form. 20 MR. CROWLEY: Object to the 21 form. Object, no foundation. 22 MS. MONAGHAN: You can 23 answer. 24 A. Am I supposed to? 25 Q. Yes. 0107 1 DANA G. TURNER - CONFIDENTIAL 2 A. I thought you were looking 3 for something else. 4 (Record read as requested.) 5 MS. MONAGHAN: Object to the 6 form. 7 If you can answer the 8 question, you can go ahead and answer 9 the question. 10 A. So any fine would be more 11 than any of us would like to see, so. 12 Q. And certainly $5.6 million 13 in fines is significant, in three 14 quarters, is significantly more than 15 you would like to see; correct? 16 MR. CROWLEY: Object to the 17 form. 18 MS. MONAGHAN: Object to the 19 form. 20 A. I would certainly like to 21 see a smaller dollar figure; yes. 22 Q. And you would like to see 23 fewer fines? 24 A. Without a doubt. 25 Q. Now, the FAA doesn't 0108 1 DANA G. TURNER - CONFIDENTIAL 2 fine -- strike that. 3 Prior to September 11, 2001, 4 it wasn't your experience that the FAA 5 fined American Airlines for every 6 violation; correct? 7 MS. MONAGHAN: Object to the 8 form. 9 MR. CROWLEY: Objection to 10 the form and foundation. 11 A. I would have no idea. 12 Q. Well, let me refresh your 13 recollection with a document. 14 MS. MONAGHAN: She didn't 15 say she didn't recollect. 16 Q. Let's look at Exhibit -- 17 I'm sorry, I have to mark this one. 18 (Turner Exhibit 289 for 19 identification, TSA Document Request 20 No. 3, production numbers TSA 0551 21 through TSA 0649.) 22 MR. PEPE: I'm sorry, that 23 is the wrong document. We will mark 24 the big one as 290. 25 (Turner Exhibit 290 for 0109 1 DANA G. TURNER - CONFIDENTIAL 2 identification, TSA Document Request 3 No. 3, production numbers TSA 001 4 through TSA 0375.) 5 MR. PEPE: Let's just put 6 that one to the side for now. 7 Document 290 is a document 8 bearing Bates range TSA 1 through 375. 9 Which was produced by the 10 Transportation Security Administration 11 in this case. The document is bound, 12 we bound it. It was -- it contains 13 binder 2-A of TSA's response to items 14 No. 2 and 3 from document request No. 3 15 from the 9/11 Commission. 16 Q. If you could please turn 17 to -- strike that. 18 On March 19, 2001, do you 19 recall an incident where you were 20 contacted by a Special Agent Long from 21 the Federal Aviation Administration? 22 MS. MONAGHAN: Object to the 23 form. 24 A. No. 25 Q. Let's turn to page TSA 5, 0110 1 DANA G. TURNER - CONFIDENTIAL 2 please. 3 MR. AMSTER: This is Exhibit 4 290? 5 MR. PEPE: Yes, 290. 6 Q. If you could please read 7 the box to yourself on the top 8 right-hand corner. 9 All set? 10 A. No. 11 Okay. 12 Q. Was AA fined for that 13 incident? 14 MS. MONAGHAN: Object to the 15 form. 16 A. I don't know. 17 Q. Was United? 18 A. I don't know. 19 Q. Do you recall an incident 20 where a special agent in July of 2001 21 walked down the jet bridge past two 22 AALA customer service agents, at the 23 door of an aircraft, boarded an 24 American Airlines flight to Los 25 Angeles, with no boarding pass, walked 0111 1 DANA G. TURNER - CONFIDENTIAL 2 the entire length of the passenger 3 compartment undetected? 4 A. I don't. 5 Q. Did AA have a system for 6 advising its GSCs of violations, 7 alleged violations? 8 A. Yes. 9 Q. What was that system? 10 A. We were informed by the 11 general manager. However, I was never 12 told nor were we, if we were fined or 13 not. We were informed of the 14 infraction and we were to correct the 15 infraction had there been one. But not 16 of the dollar figure attached. 17 Q. How were you informed of 18 the infractions by the general manager, 19 orally, written, memoranda? 20 A. Generally orally to begin 21 with, followed by written. 22 Q. So you would as a matter of 23 course, pattern and practice prior to 24 September 11, 2001, receive memoranda 25 concerning security violations? 0112 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Object to the 3 form. 4 A. What I said was I was 5 informed by the general manager had 6 something occurred. Then he would 7 reinforce it by saying this is what 8 happened, to a memorandum. I don't 9 know what you're looking for, or what 10 you're asking me. 11 Q. I'm asking you prior to 12 September 11, 2001, was it American's 13 pattern and practice to provide 14 security related -- strike that. 15 Prior to September 11, 2001, 16 was it American's pattern and practice 17 to provide memoranda to its GSCs 18 concerning alleged violations? 19 MS. MONAGHAN: Object to the 20 form. 21 A. The answer would be yes. 22 Q. Do you know where those 23 were kept? 24 A. I do not. 25 Q. Were they kept in a central 0113 1 DANA G. TURNER - CONFIDENTIAL 2 location? 3 A. I don't recall. 4 Q. Do you have the copies that 5 you received? 6 A. No. 7 Q. Do you recall receiving 8 training in 2001 that the failure to 9 perform continuous searches at security 10 checkpoints was the big one to stress 11 because the FAA was concentrating on 12 that violation? 13 MS. MONAGHAN: Object to the 14 form. 15 A. Read it once more. 16 MR. PEPE: Let's have it 17 read back. 18 (Record read as requested.) 19 A. It's very difficult to 20 remember back to 2001. So I am certain 21 it was stressed to us. But do I recall 22 having that conversation, no, I don't. 23 Q. But you're certain it was 24 stressed to you? 25 A. Yes. 0114 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And it was stressed to you 3 because the FAA was concentrating on 4 it? 5 MS. MONAGHAN: Object to the 6 form. 7 MR. CROWLEY: Object to the 8 form. 9 Q. Is that what you 10 understood? 11 A. The FAA concentrated on 12 numerous things with regard to safety. 13 Which we were to enforce, and we did. 14 Q. But you stressed the things 15 that they were concentrating on; is 16 that right? 17 MS. MONAGHAN: Object to the 18 form. 19 A. Yes. 20 Q. Was there a page or a group 21 of pages on American's corporate 22 security web site titled the FAA is 23 coming? 24 A. I don't recall. 25 Q. Were you notified in 0115 1 DANA G. TURNER - CONFIDENTIAL 2 advance that the FAA was coming when 3 they were coming? 4 A. Generally no. 5 Q. How about on occasion? 6 A. Typically -- no, no. 7 Q. Who was the greatest threat 8 to U.S. civil aviation on September 9 11th? 10 MR. CROWLEY: Object to the 11 form. 12 MR. KOLAR: Objection to the 13 form and foundation. 14 MS. MONAGHAN: Object to the 15 form. 16 A. Osama. 17 Q. Would that include Al 18 Qaeda? 19 MS. MONAGHAN: Object to the 20 form. 21 MR. CROWLEY: Object to the 22 form. 23 A. Yes. 24 Q. Do you recall receiving 25 training about the Miami incident? 0116 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Objection to 3 the form. 4 A. No, I don't. 5 Q. Could you please look at 6 page AAL 16366 in Exhibit 275. 7 A. I'm sorry, could you give me 8 the page again? 9 Q. Sure. 16366. 10 MS. MONAGHAN: I'm just 11 going to object based on foundation, 12 you haven't established this is a 13 document she's ever seen before in her 14 life. 15 MR. PEPE: The objection is 16 noted. 17 Q. Are you there? 18 A. I'm right here. Did you ask 19 me something? 20 Q. No, not yet. I was waiting 21 to make sure you were there. 22 On the top it says 23 PowerPoint, PP fines, it's got PP 24 advance for use, below that it's got 25 some information in various quarters. 0117 1 DANA G. TURNER - CONFIDENTIAL 2 And it says "let's not forget we are 3 probation." In the original is the 4 typographical error, "because of the 5 Miami incident." 6 Do you know what that is 7 referring to? 8 MS. MONAGHAN: Again, I 9 object to the lack of foundation. 10 But if you can answer, you 11 can answer. 12 A. Today I do not. 13 Q. Do you know whether 14 American Airlines was on probation on 15 September 11, 2001 or at any point in 16 the year prior? 17 MS. MONAGHAN: Objection to 18 form. 19 A. Miami was on probation, but 20 you asked me what for and I can't 21 answer the question. 22 Q. Okay. Miami was on 23 probation? 24 A. Probation because of Miami 25 incident. 0118 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Are you 3 recalling that or are you just reading 4 it off of the document? 5 THE WITNESS: No, I'm 6 reading it off of the document. 7 MS. MONAGHAN: If you don't 8 know, say you don't know. 9 Q. Say you don't recall. 10 A. I don't recall. 11 Q. Were badge violations a 12 problem prior to September 11, 2001 for 13 American Airlines? 14 MS. MONAGHAN: Object to the 15 form. 16 MR. CROWLEY: Objection to 17 the form. 18 A. What kind of badge problems? 19 Q. Well, let's look on the 20 page. It says AAL 16366. It says 21 "let's take a look at examples of FAA 22 security violations. These are also 23 listed in your guide. We will discuss 24 them in detail later." The first entry 25 is badge violations. I'm curious, were 0119 1 DANA G. TURNER - CONFIDENTIAL 2 badge violations a problem for American 3 prior to September 11th? 4 MS. MONAGHAN: Object to the 5 form. 6 MR. CROWLEY: Object to the 7 form. 8 A. We had issues with badges 9 with regard to having them on your 10 outer most garment, chest level, simply 11 because of Washington's cold weather. 12 So they would be tucked underneath your 13 jacket versus on the outer most part of 14 your garment. So that's what that's 15 referring to. 16 Q. So it's tucked in it means 17 it can't be seen? 18 A. Correct. 19 Q. And that was a problem at 20 Dulles? 21 MS. MONAGHAN: Object to the 22 form. 23 MR. CROWLEY: Objection to 24 the form. 25 A. I wouldn't say it was a 0120 1 DANA G. TURNER - CONFIDENTIAL 2 problem. I would say that yes, it did 3 occur. 4 Q. How about failure to 5 positive bag match? 6 MS. MONAGHAN: Object to the 7 form. 8 Q. Was that a problem? 9 A. I don't recall that being a 10 problem, no. 11 Q. You never were responsible 12 as a GSC for the checkpoint or at any 13 time prior to that; is that right? 14 A. No. 15 MS. MONAGHAN: Object to the 16 form. 17 Q. What was a continuous 18 search, as you understood it, on 19 September 11, 2001? 20 MS. MONAGHAN: Objection to 21 the form. 22 A. Are you speaking about the 23 checkpoint at Dulles? 24 Q. At Dulles, yes. 25 A. It is my understanding, as I 0121 1 DANA G. TURNER - CONFIDENTIAL 2 recall, it was exactly what it says, a 3 continuous search at the security 4 checkpoint, that they had to be -- you 5 know, I'm not 100 percent sure today, 6 so I'm not going to answer it. I'm not 7 100 percent sure, I don't recall. 8 Q. What's your best 9 recollection? 10 MS. MONAGHAN: Object to the 11 form. 12 A. I'm getting confused 13 pre-9/11 and post-9/11. So I apologize 14 for that. 15 Q. It's okay. 16 A. That they continually had 17 someone who was going through a search 18 at the security checkpoint. 19 Q. Prior to September 11, 2001 20 at Dulles, was there a requirement that 21 a given number of bags -- strike that. 22 Prior to September 11, 2001, 23 did American Airlines -- I'm sorry. 24 Prior to September 11, 2001 25 at Dulles Airport, was there a 0122 1 DANA G. TURNER - CONFIDENTIAL 2 requirement that every X number of bags 3 had to be searched? 4 MS. MONAGHAN: Object to the 5 form. 6 MR. CROWLEY: Objection to 7 the form. 8 A. I'm not hundred percent 9 sure. 10 Q. Where would I look to find 11 that? 12 MS. MONAGHAN: Don't 13 speculate. If you don't know an 14 answer, you don't know it. 15 Q. I may ask you to speculate, 16 but for right now I'm not asking you 17 to. 18 MS. MONAGHAN: I'm going to 19 instruct you not to speculate. 20 Q. Where would I look to find 21 that information? 22 MS. MONAGHAN: Object to the 23 form. What information? 24 Q. Do you understand the 25 question? 0123 1 DANA G. TURNER - CONFIDENTIAL 2 A. In what document would you 3 look to find out if we had to do a 4 continual search? 5 Q. What the requirements were 6 for continuous searches on September 7 11th at Dulles. 8 A. The COG or the ACSSP. 9 Q. Anywhere else? 10 A. Not to my knowledge. 11 Q. Were you trained in the -- 12 strike that. 13 As a GSC for American 14 Airlines, were you trained in 15 identifying the types of persons who 16 might cause a threat? 17 MS. MONAGHAN: Objection to 18 the form. 19 MR. CROWLEY: Object to the 20 form. 21 A. Types of people? We were 22 trained what to look for, are you 23 talking about ethnic backgrounds, are 24 you talking about little old people? 25 Is that? 0124 1 DANA G. TURNER - CONFIDENTIAL 2 Q. I'm asking you what were 3 you trained. 4 MS. MONAGHAN: Object to the 5 form. 6 A. We were trained to look for 7 things that were out of the ordinary. 8 Q. Such as? 9 MS. MONAGHAN: Object to the 10 form. This is before September 11, 11 2001 what were they trained to look 12 for? 13 MR. PEPE: I believe that 14 was clear. But if it's not, yes. 15 Q. And please tell me if your 16 prior two answers change based on that 17 assumption. 18 A. We were trained to look for 19 things, people. Not necessarily 20 people, but out of the ordinary, should 21 it be summer, why are you wearing a 22 winter coat. Are you nervous, are you 23 sweating, are you not giving me eye 24 contact. Those types of things. 25 Q. Anything else that you 0125 1 DANA G. TURNER - CONFIDENTIAL 2 remember being trained prior to 3 September 11th on this issue? 4 A. That's all that's coming to 5 my head right now. 6 Q. American was permitted to 7 prevent any passenger from boarding 8 that American believed presented a 9 threat to the aircraft prior to 10 September 11th; correct? 11 MS. MONAGHAN: Object to the 12 form. 13 A. I didn't hear the last thing 14 that you said. 15 Q. It's just correct, but 16 let's have the whole question read 17 back. 18 MR. PEPE: And your 19 objection is noted for this question. 20 (Record read as requested.) 21 Q. Correct? 22 A. Yes. 23 Q. Did you speak with any of 24 the ticket agents that were on duty on 25 September 11th about the events of that 0126 1 DANA G. TURNER - CONFIDENTIAL 2 day? 3 A. On September 11th? 4 Q. At any time from September 5 11th to today. 6 A. No, I didn't. We never sat 7 down and had a conversation about it, 8 no. 9 Q. Did you ever have any 10 communications of any type? 11 MS. MONAGHAN: Object to the 12 form. With anyone about anything in 13 her life? 14 MR. PEPE: It's a reference 15 to my prior question. 16 Q. Did you ever have 17 communications of any type with any of 18 the individuals who were ticket agents 19 on duty on September, 2001, from 20 September 11th, 2001 to today? 21 A. Sure. I'm sure I had casual 22 conversations with them. 23 Q. About the events of 24 September 11th? 25 MS. MONAGHAN: Objection; 0127 1 DANA G. TURNER - CONFIDENTIAL 2 asked and answered. 3 A. No. 4 Q. Were there different ways 5 to select -- strike that. 6 Were there different ways on 7 September 11, 2001 for passengers to be 8 selected for additional screening? 9 MS. MONAGHAN: Objection to 10 the form. 11 A. Were there different ways 12 for passengers to become select -- to 13 become selectees? 14 Q. Sure. You know what a 15 selectee is; right? 16 A. Um-hum. 17 MS. MONAGHAN: You have to 18 answer verbally. 19 A. Yes. 20 Q. You knew what a selectee 21 was on September 11th? 22 A. Yes. 23 Q. Was there different ways 24 that a passenger could become a 25 selectee on September 11th? 0128 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Objection. 3 A. Yes. 4 Q. What were those different 5 ways? 6 MS. GOLDMAN: Objection. To 7 the extent that you are going to be 8 describing the CAPPS program, we would 9 advise you not to give any testimony 10 regarding the basis for making somebody 11 a selectee. 12 MR. PEPE: Fair enough. Is 13 it okay to have the question just were 14 there different ways? 15 MS. GOLDMAN: Yes. 16 Q. Were there different ways? 17 A. Yes. 18 Q. Was one of the ways 19 computerized? 20 A. Yes. 21 Q. Was one of the ways 22 manually? 23 MS. MONAGHAN: Objection to 24 the form. 25 A. Yes. 0129 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Do you know if any of the 3 hijackers on Flight 77 were manually 4 selected? 5 MS. MONAGHAN: Objection to 6 the form. 7 A. I'm not certain. 8 Q. How many video cameras were 9 there -- strike that. 10 How many video cameras were 11 there observing the checkpoint through 12 which the hijackers passed on September 13 11th? 14 MS. MURPHY: Objection to 15 the form. 16 MS. MONAGHAN: Objection to 17 the form. 18 MS. GOLDMAN: Can we pause 19 for a second. 20 MR. PEPE: It's in a 21 document. 22 A. I have no idea. 23 Q. More than one? 24 MS. MONAGHAN: Object to the 25 form. She said she had no idea, she 0130 1 DANA G. TURNER - CONFIDENTIAL 2 doesn't know. 3 MR. PEPE: I asked how many, 4 she said she has no idea. I'm asking 5 if there is more than one, that's a 6 different question. 7 MS. MONAGHAN: You haven't 8 established that there is any, so there 9 is lack of foundation on both ends. 10 A. I have no idea. 11 Q. Are knives and serrated 12 blades prohibited on September 11th? 13 MS. MONAGHAN: Objection. 14 A. Were knives with serrated 15 blades? 16 Q. Yes. 17 A. If they were less than four 18 inches. 19 MS. MONAGHAN: They were 20 prohibited if they were less than four 21 inches? 22 MR. PEPE: I'm sorry, Maura, 23 you can ask on redirect. 24 MS. MONAGHAN: They were 25 prohibited if they were less than four 0131 1 DANA G. TURNER - CONFIDENTIAL 2 inches? 3 THE WITNESS: If they were 4 less than four inches you could carry 5 them on. 6 Q. Even if they were serrated? 7 A. Yes. 8 Q. Describe a menacing knife 9 for me. 10 MS. MONAGHAN: Object to the 11 form. 12 Go ahead if you can. 13 Q. As it existed on -- strike 14 that. 15 As a GSC on duty on 16 September 11, 2001, at Dulles, can you 17 describe for me what your understanding 18 of what a menacing knife was on 19 September 11th? 20 MS. MONAGHAN: Object to the 21 form. 22 Go ahead, if you can. 23 A. I don't -- define the word 24 menacing. 25 Q. Are you familiar with the 0132 1 DANA G. TURNER - CONFIDENTIAL 2 term menacing knife as it's used in the 3 Checkpoint Operations Guide on 4 September 11th? 5 A. I'm familiar with the term. 6 Q. Describe it for me. 7 MS. MONAGHAN: Object to the 8 form. 9 A. I can't describe it for you. 10 Q. Well, you were trained in 11 what menacing knives were; weren't you? 12 MS. MONAGHAN: Object to the 13 form. 14 A. To me menacing would look 15 awfully jaggedy or -- I don't know what 16 the word menacing was. Did I ever see 17 a menacing knife at Washington Dulles, 18 I did not. 19 Q. That wasn't my question. 20 My question was what was a menacing 21 knife? 22 MS. MONAGHAN: That's her 23 answer. Object to the form; asked and 24 answered. 25 Q. If someone presented a 0133 1 DANA G. TURNER - CONFIDENTIAL 2 knife to you on September 11, 2001 and 3 asked you to look at it and determine 4 whether it was menacing, what criteria 5 would you use? 6 MS. MONAGHAN: Object to the 7 form. 8 You can answer. 9 A. Extremely jagged edged is 10 what comes to my mind. 11 Q. So serrated? 12 MS. MONAGHAN: Object to the 13 form. 14 A. No. 15 Q. Is there a difference 16 between serrated and jagged? 17 A. In my mind, yes. 18 Q. What's the difference in 19 your mind? 20 A. The looks of serrated and 21 jaggedy. 22 Q. So jaggedy blades were 23 prohibited but serrated blades were 24 allowed? 25 MS. MONAGHAN: Object to the 0134 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 A. I didn't say that. 4 Q. I'm asking. 5 MS. MONAGHAN: Objection to 6 form. 7 A. No, you asked -- 8 Q. I'm asking now. Jaggedy 9 blades were prohibited by serrated 10 blades were allowed? 11 MR. CROWLEY: Object to the 12 form. 13 Q. I'm not trying to trip you 14 up, I'm trying to understand what a 15 menacing knife was as you understood it 16 as a GSC. 17 A. And I answered the question. 18 Jaggedy, in my mind. 19 Q. And were knives with 20 jaggedy blades prohibited on September 21 11, 2001? 22 MS. MONAGHAN: Object to the 23 form. 24 A. Menacing knives were not 25 allowed. 0135 1 DANA G. TURNER - CONFIDENTIAL 2 Q. How about knives with 3 jaggedy blades? 4 MS. MONAGHAN: Object to the 5 form. 6 A. A knife less than four 7 inches was allowed through. 8 Q. Under all circumstances? 9 MS. MONAGHAN: Object to the 10 form. 11 A. Unless determined to be 12 menacing. 13 Q. By whom? 14 A. The security. 15 Q. What training did you 16 receive prior to September 11, 2001 17 that enabled you to determine whether a 18 knife was menacing or not menacing? 19 MS. MONAGHAN: Object to the 20 form. 21 A. I received GSC training. 22 Q. And what specific aspect of 23 your GSC training enabled you to 24 determine whether a knife was menacing 25 or not menacing on and before September 0136 1 DANA G. TURNER - CONFIDENTIAL 2 11th? 3 A. I don't recall. 4 Q. Do you remember receiving 5 any such training? 6 MS. MONAGHAN: Object to the 7 form. 8 A. I remember receiving GSC 9 training, yes. And we did look at 10 certain pictures. 11 Q. Examples of menacing 12 knives? 13 A. I don't recall. 14 MS. MONAGHAN: Object to the 15 form. 16 Q. Well, they had a gallery at 17 the training facility, right, that had 18 some prohibited items in it? 19 MS. MONAGHAN: Object to the 20 form. 21 Q. Is that right? 22 A. I don't recall a gallery. 23 Q. What special procedures 24 were supposed to be employed with 25 persons on crutches for American 0137 1 DANA G. TURNER - CONFIDENTIAL 2 flights? 3 MS. MONAGHAN: Object to the 4 form. Prior to September 11, 2001? 5 Q. Yes. Unless I otherwise 6 specify, every question is prior to 7 September 11th. On and before 8 September 11th. 9 A. So I'm sorry, repeat it 10 again. 11 MR. PEPE: Let's have it 12 read back. 13 (Record read as requested.) 14 A. Pre-boarding? 15 Q. Security. Screening. 16 MS. MONAGHAN: You are 17 asking how were people with crutches 18 screened before September 11, 2001? 19 MR. PEPE: Yes. 20 Q. What were the special 21 procedures for people on crutches? 22 A. They came through with their 23 crutches. And if their crutches or if 24 they alarmed, then they were hand 25 wanded to determine what set the alarm 0138 1 DANA G. TURNER - CONFIDENTIAL 2 off, to clear it. 3 Q. Let's turn to page 16539. 4 A. What are we in? 5 Q. The same document. This is 6 Exhibit 275. In lesson objectives, the 7 first bullet point, it says "after 8 completing this lesson, participants 9 will be able to meet the following 10 objectives: Identify the many types of 11 weapons via video guidelines and a 12 gallery walk." 13 Do you remember walking a 14 gallery where there were weapons on 15 display? 16 MS. MONAGHAN: Object to the 17 form. 18 A. I do not. 19 Q. Do you remember seeing a 20 video during your training called "the 21 tools of terror"? 22 A. I don't recall the specific 23 video, no. 24 Q. Do you remember seeing a 25 video, though? 0139 1 DANA G. TURNER - CONFIDENTIAL 2 A. I remember seeing lots of 3 videos. 4 Q. With weapons on it? 5 MS. MONAGHAN: Object to the 6 form. 7 A. Not specifically, I don't. 8 Q. If you could please turn to 9 page 16570. While your counsel is 10 flipping for that, let's just ask you, 11 do you know what a news flash was? 12 A. Do I know what a news flash? 13 Q. Um-hum. As it relates to 14 security at American Airlines prior to 15 September 11th. 16 A. I don't recall. I can make 17 a guess at it, but I don't recall. 18 Q. Well, let's see if this 19 refreshes your recollection. Let's 20 look at 16570 and right next to the 21 icon that says PowerPoint, it reads 22 "you will find a news flash" -- I'm 23 sorry, let's go up. "PowerPoint, PP 24 FAA, 'the FAA is coming!!!'," end 25 quote. Scrolling back to the top of 0140 1 DANA G. TURNER - CONFIDENTIAL 2 this page, "let's see what happens when 3 we click on FAA is coming. You will 4 find a news flash," bold, all caps. 5 "This report informs you that," quote, 6 "the FAA is coming to your," all caps, 7 "station to conduct access control 8 testing," all caps, end quote. 9 Does that refresh your 10 recollection as to what a news flash 11 was on and before September 11th? 12 MS. MONAGHAN: Object to the 13 form to form. 14 A. I can't place it right now, 15 no. 16 Q. Did you have access to AA's 17 corporate web site on and before 18 September 11, 2001, with respect to 19 security? 20 MS. MONAGHAN: Object to the 21 form. 22 A. Did I have access to the 23 ACSSP? 24 Q. No, did you have access to 25 the corporate web site, the corporate 0141 1 DANA G. TURNER - CONFIDENTIAL 2 security web site for American 3 Airlines. 4 A. Yes. 5 Q. Did you access that web 6 site on and before September 11, 2001 7 as a regular practice? 8 MS. MONAGHAN: Objection to 9 the form. 10 A. I'm not sure what regular 11 means. But I have accessed the web 12 site. 13 Q. I didn't ask if you had 14 access, I asked if you accessed it, 15 regularly. 16 MR. CROWLEY: Objection to 17 the form. 18 A. Your definition of regular? 19 Q. How do you define regular? 20 MR. CROWLEY: Objection. No 21 question. 22 A. I think regularly might be 23 once a week. 24 Q. Okay. Let's use your 25 definition. 0142 1 DANA G. TURNER - CONFIDENTIAL 2 A. I don't recall. 3 Q. Did you receive training in 4 CTX machines prior to September 11th? 5 MS. MONAGHAN: Objection. 6 A. I remember being exposed to 7 the CTX machine. I wouldn't say I was 8 trained in the CTX machine. 9 Q. Did you ever physically 10 view them in operation? 11 A. I'm not sure. I'm certain 12 that I had seen them. Whether they 13 were in operation and it was -- because 14 they were new to us. I don't recall if 15 we were watching them as a test where 16 we actually went and sat there. I 17 don't recall. 18 Q. But you weren't the person 19 responsible in any way for CTX of 20 carry-on baggage or checked baggage -- 21 strike that. 22 You weren't the person 23 responsible on and before September 11, 24 2001 in any way for operation of the 25 CTX machine? 0143 1 DANA G. TURNER - CONFIDENTIAL 2 A. No. 3 Q. Who was that person? 4 A. I don't know. 5 Q. Can you describe -- strike 6 that. 7 As an American GSC on duty 8 on September 11, 2001, can you tell me 9 what your understanding was on that 10 date of a sterile area? 11 MS. MONAGHAN: Object to the 12 form. 13 You can answer. 14 A. After passing through 15 security. 16 Q. Was the purpose of security 17 screening to ensure that there were no 18 prohibited items in the sterile area? 19 MS. MONAGHAN: Object to the 20 form. 21 You can answer. 22 A. Yes. 23 Q. Did you ever test any -- 24 strike that. 25 Did you ever test 0144 1 DANA G. TURNER - CONFIDENTIAL 2 Argenbright screeners prior to 3 September 11th, personally? 4 MS. MONAGHAN: Object to the 5 form. 6 A. Yes. 7 Q. How many times? 8 A. I don't recall how many 9 times. 10 Q. Ballpark? This is one of 11 those situations where I'm asking you 12 to speculate. 13 MS. MONAGHAN: On this 14 occasion I will permit you to 15 speculate. But I'll instruct you if 16 it's not to be done. 17 A. Me personally, a handful of 18 times. 19 Q. Who was the person 20 principally responsible at American 21 Airlines for testing the security at 22 the checkpoints? 23 MS. MONAGHAN: Object to the 24 form. If anyone. 25 MR. PEPE: There you go 0145 1 DANA G. TURNER - CONFIDENTIAL 2 again. 3 A. That typically is the GSC at 4 the ticket counter. 5 Q. The GSC at the ticket 6 counter? 7 A. Yeah. 8 Q. Were you at any time in a 9 briefing or otherwise made aware of the 10 FAA's conclusions with respect to a 11 special emphasis assessment conducted 12 on Argenbright from July 19th to July 13 27, 2001? 14 MS. MURPHY: Object to the 15 form. 16 MS. MONAGHAN: Object to the 17 form. 18 A. Was I part of a briefing? 19 MS. MONAGHAN: That was the 20 question. 21 Q. Were you ever made aware of 22 anything about it? 23 A. Okay. 24 THE WITNESS: Can you read 25 it back, sir? 0146 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Special emphasis assessment 3 conducted by the FAA, prior to 4 September 11th, were you aware of it? 5 A. Nothing coming to my mind 6 right this second. 7 Q. Were the FAA's conclusions 8 with respect to its audits of 9 Argenbright ever communicated to you 10 and the other GSCs, to your knowledge? 11 MS. MONAGHAN: Objection to 12 the form. 13 A. An audit of Dulles, or 14 Argenbright, period? 15 Q. Either/or. 16 A. Which one do you want me to 17 answer first? 18 Q. Start Dulles. 19 A. Dulles, no. 20 Q. Argenbright generally? 21 A. Yes. 22 Q. When? 23 A. I don't know. 24 Q. Before September 11th? 25 A. Yes. 0147 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Was that at a meeting? 3 A. Yes. 4 Q. Who was there? 5 A. General manager, I'm certain 6 the CSMs that report to him. I 7 couldn't tell you specifically. 8 Q. Do you remember any one 9 person that was there that you can name 10 for us? 11 A. The general manager. 12 Q. Who is that? 13 A. Dennis. 14 Q. What's Dennis's last name? 15 A. Hazell. 16 Q. He's the general manager 17 for American Airlines? 18 A. Yes. 19 Q. You said there were some 20 CSMs. Anyone come to mind? 21 A. Donna Thompson. 22 Q. Anyone else? 23 A. I'm just trying to get my 24 time frames in order. I'm not going to 25 say because I'm not sure. 0148 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Okay. You said time frames 3 in order. What was the approximate 4 time frame? 5 A. I was speaking prior to 6 2001. 7 Q. That's fine. That just 8 triggered the question in my mind. You 9 said it was pre-2001. Do you recall 10 when pre-2001? 11 A. No. 12 Q. A year prior, less than a 13 year or more than a year? 14 MS. MONAGHAN: Objection to 15 form. 16 MR. PEPE: I'm just trying 17 to get a time frame, that's all. 18 General time frame. 19 A. It would be speculation. 20 Q. Go ahead. 21 A. I would say less than a 22 year. 23 Q. And was a PowerPoint 24 presentation made during this 25 discussion? 0149 1 DANA G. TURNER - CONFIDENTIAL 2 A. Not that I recall. 3 Q. Were all the GSCs there? 4 MS. MONAGHAN: Object to the 5 form. 6 A. No. 7 Q. Were a number of GSCs 8 there? 9 A. Two that I can tell you 10 right now. Actually three. 11 Q. Did you discuss at all 12 during this meeting the FAA's 13 conclusions with respect to the 14 Argenbright audits? 15 MS. MONAGHAN: Objection to 16 form. 17 A. I don't recall the length or 18 the depth of the discussion. 19 Q. Why don't you tell me what 20 you do remember about the discussion. 21 A. That Argenbright had issues 22 at other city, a different city. 23 Q. What city? 24 A. Philly. 25 Q. I'm sorry? 0150 1 DANA G. TURNER - CONFIDENTIAL 2 A. Philly. 3 Q. Okay. What else? 4 A. That's really all I 5 remember. 6 Q. What were the issues? 7 A. I don't remember specifics. 8 Q. Was any corrective action 9 or any action at all taken as a result 10 of this meeting? 11 MS. MONAGHAN: Object to the 12 form. 13 A. At Washington Dulles? 14 Q. The meeting we are talking 15 about, yes. I'm sorry, you're asking. 16 Yes, any corrective action anywhere. 17 A. I don't recall. 18 Q. Any corrective action in 19 Washington? 20 A. No. 21 Q. If you could please look at 22 290, page TSA 362. 23 Were you aware prior to 24 September 11, 2001 that the FAA 25 conducted two audits in November of 0151 1 DANA G. TURNER - CONFIDENTIAL 2 2000 of Argenbright? 3 A. Now that you bring it to my 4 attention, yes. 5 Q. Have you ever seen -- 6 MS. MONAGHAN: Hold on a 7 second. Do you know that or are you 8 just reading it off the document? 9 THE WITNESS: After having 10 looked at the document, I recall. 11 MS. MONAGHAN: Okay. 12 Q. Have you ever seen this 13 document before? 14 A. Not to my recollection, no. 15 Q. Do you recall that out of 16 100 records on screeners, 14 records 17 with triggers were sent for criminal 18 history checks? 19 MS. MURPHY: Object to the 20 form. 21 A. Say it again, I'm sorry. 22 Q. Sure. Do you recall -- go 23 ahead, we will have it read back. 24 (Record read as requested.) 25 A. I don't recall that, those 0152 1 DANA G. TURNER - CONFIDENTIAL 2 numbers, no. 3 Q. Do you recall the concept, 4 though? 5 MS. MONAGHAN: Object to the 6 form. 7 Q. That there were records 8 with triggers that had to be re-sent 9 for criminal history checks? 10 A. What comes to my head that I 11 recall is they -- there were issues 12 with their background check. That's 13 what comes to my mind. 14 Q. So is it fair to say that 15 there were Argenbright screeners 16 operating at checkpoints who hadn't had 17 criminal history checks as required? 18 MS. MURPHY: Object to the 19 form. 20 MR. CROWLEY: Object to the 21 form. 22 MS. MONAGHAN: Objection to 23 the form. 24 A. That's not what I said. 25 Q. I'm asking you now if it's 0153 1 DANA G. TURNER - CONFIDENTIAL 2 fair to say that. 3 MR. PEPE: Let's have the 4 question read back. 5 (Record read as requested.) 6 MS. MONAGHAN: Object to the 7 form. 8 MR. CROWLEY: Objection to 9 the form. 10 MR. KERNS: Objection to the 11 form. 12 A. Because I'm not trained in 13 criminal background checks, obviously 14 they found something. I don't know. I 15 can't speak to it. 16 Q. Did you ever audit any 17 background checks? 18 MS. MONAGHAN: Objection to 19 the form. 20 Q. Prior to September 11th? 21 A. No. 22 Q. Did American? 23 MS. MONAGHAN: Objection to 24 the form. 25 Q. To your knowledge. 0154 1 DANA G. TURNER - CONFIDENTIAL 2 A. I have no idea. 3 Q. Is that a GSC's 4 responsibility? 5 MS. MONAGHAN: Objection to 6 the form. 7 A. No. 8 Q. Is it a GSC's 9 responsibility to audit the checkpoint, 10 prior to September 11th? 11 MS. MONAGHAN: Objection. 12 A. Yes. 13 Q. Did that audit include 14 auditing screener records? 15 MS. MONAGHAN: Objection to 16 the form. 17 A. As a GSC that was not my 18 involvement, so I don't -- I don't know 19 what the involvement for the audit was. 20 That was not my job function. 21 Q. If you could please turn to 22 TSA 0367. Just let me ask you a few 23 preliminary questions. Do you recall 24 that prior to September 11, 2001 the 25 FAA had noted discrepancies in findings 0155 1 DANA G. TURNER - CONFIDENTIAL 2 concerning regulatory violations of 3 Argenbright? 4 MS. MURPHY: Object to the 5 form. 6 MS. MONAGHAN: Object to the 7 form. 8 A. I don't recall. 9 Q. Do you recall that the FAA 10 had noted discrepancies concerning 11 security weaknesses with Argenbright 12 prior to September 11, 2001? 13 MS. MONAGHAN: Object to the 14 form. 15 MS. MURPHY: Object to the 16 form. 17 A. I don't recall. 18 Q. I'm sorry? 19 A. I don't recall. 20 Q. Do you recall the FAA 21 finding, in connection with its audits 22 of Argenbright, that training records 23 do not reflect classroom training or 24 observation period for screeners 25 certified to use ETD equipment, do you 0156 1 DANA G. TURNER - CONFIDENTIAL 2 remember that or anything like it? 3 MS. MURPHY: Object to the 4 form. 5 MS. MONAGHAN: Objection to 6 form. 7 A. I don't recall, no. 8 Q. So you don't remember being 9 told that by anybody at American? 10 MS. MONAGHAN: Objection to 11 form. 12 A. I don't recall. 13 Q. Meaning you don't remember 14 being told it? 15 MR. CROWLEY: Objection to 16 the form. 17 MS. MONAGHAN: Objection to 18 the form; asked and answered. 19 Q. If you remember being told 20 it, please say yes. If you don't 21 remember being told it, please say I 22 don't recall, which means that you 23 cannot remember actually being told 24 that. 25 MS. MONAGHAN: Objection to 0157 1 DANA G. TURNER - CONFIDENTIAL 2 the form. 3 MR. AMSTER: Objection to 4 the form. 5 MR. CROWLEY: Object to the 6 form; asked and answered. 7 Q. You can answer again. 8 A. I don't recall. 9 Q. Thank you. 10 A. You're welcome. 11 Q. Who was the air carrier 12 responsible for testing the Dulles 13 checkpoints? 14 MS. MONAGHAN: Objection to 15 the form. 16 Q. On September 11, 2001 and 17 prior. 18 MS. MONAGHAN: Objection to 19 the form. You mean the Dulles 20 checkpoint that American's passengers 21 passed through? 22 MR. PEPE: If there is any 23 question, you can feel free to seek 24 clarification. It gets tedious to have 25 to do this with every question. I'm 0158 1 DANA G. TURNER - CONFIDENTIAL 2 talking about the Dulles checkpoint 3 that serviced Flight 77 on September 4 11th. 5 Q. Do you understand that to 6 be what I'm talking about? 7 A. Your question is were we the 8 only carrier to test security? 9 Q. No. Let's have the 10 question read back. 11 A. Thank you. 12 (Record read as requested.) 13 MR. KOLAR: Objection to 14 form. 15 A. All carriers were 16 responsible for testing the checkpoint. 17 Q. Including American? 18 A. Absolutely. 19 Q. Do you recall that prior to 20 September 11, 2001 one of the security 21 weaknesses identified by the FAA with 22 respect to Argenbright was that 23 employees were hired who have an 24 unverifiable foreign diploma or cannot 25 produce their diploma? 0159 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MURPHY: Objection to 3 form. 4 MS. MONAGHAN: Objection to 5 form. 6 A. I don't remember. 7 Q. Please turn to TSA 03771. 8 First bullet. Reads "employees hired 9 who have an unverifiable foreign 10 diploma or cannot produce their 11 diploma," under the heading 12 "Argenbright audit security weaknesses 13 No. 1." 14 Does that refresh your 15 recollection? 16 MS. MONAGHAN: Object to the 17 form. 18 A. No, sir. 19 Q. Were you ever told prior to 20 September 11, 2001 that Argenbright 21 screeners needed retest due to failing 22 their initial certification test? 23 MS. MURPHY: Objection to 24 the form. 25 MS. MONAGHAN: Objection to 0160 1 DANA G. TURNER - CONFIDENTIAL 2 the form. 3 A. No. 4 Q. Were you ever told prior to 5 September 11, 2001 that Argenbright had 6 numerous pen/ink changes on their 7 initial/recurrent certification tests, 8 and the FAA requested that the test 9 should be taken in pencil and graded in 10 ink? 11 MS. MURPHY: Objection to 12 the form. 13 MS. MONAGHAN: Objection to 14 the form. 15 A. No. 16 Q. American was responsible 17 for auditing those tests; right? 18 MS. MONAGHAN: Objection to 19 the form. 20 MR. CROWLEY: Objection. 21 A. You asked me about the 22 auditing function earlier, and it's not 23 a function that I performed. 24 Q. But you were a trained GSC, 25 and I'm asking you if American was 0161 1 DANA G. TURNER - CONFIDENTIAL 2 responsible for auditing those tests. 3 MR. CROWLEY: Objection to 4 the form and foundation. 5 MS. MONAGHAN: Objection to 6 the form. 7 A. We did audit -- we did audit 8 the checkpoint, yes. 9 Q. Did you also audit the 10 tests taken by the checkpoint? 11 MS. MONAGHAN: Objection to 12 the form. 13 MR. CROWLEY: Objection. 14 Q. Screeners, not you 15 personally, I'm talking about American 16 now. 17 MR. CROWLEY: Objection to 18 form and foundation. 19 A. I guess I'm confused. Are 20 you talking about the test objects that 21 we tried to pass through? 22 Q. No, written tests taken by 23 screeners in connection with their 24 certification or recurrent training, 25 I'm asking you, was it American 0162 1 DANA G. TURNER - CONFIDENTIAL 2 Airlines' responsibility to audit those 3 tests? 4 MS. MONAGHAN: Objection to 5 form. 6 MR. CROWLEY: Objection to 7 form and foundation. 8 Q. Prior to September 11th. 9 A. I don't recall. 10 Q. Okay. Do you recall the 11 FAA -- strike that. 12 Do you recall ever being 13 told or gaining knowledge of the fact 14 that the FAA had identified as a 15 security weakness that air carrier 16 testing records indicated that tests 17 were being conducted unrealistically? 18 MR. CROWLEY: Objection to 19 the form. 20 MS. MURPHY: Objection to 21 the form. 22 MS. MONAGHAN: Objection to 23 the form. 24 A. No. 25 Q. So because you weren't told 0163 1 DANA G. TURNER - CONFIDENTIAL 2 any of these things, you didn't take 3 any corrective action personally as a 4 GSC? 5 MS. MURPHY: Object to the 6 form. 7 MS. MONAGHAN: Objection to 8 the form. 9 MR. CROWLEY: Objection to 10 the form. Objection to the line of 11 questioning. You are implying that 12 these records relate to Dulles. And 13 that hasn't been established. 14 MR. PEPE: Was that a 15 speaking objection or a form objection? 16 MR. CROWLEY: That's an 17 objection to your whole line of 18 questioning. 19 MR. PEPE: Noted. 20 We should have it read back, 21 because there was a little bit of an 22 interruption. 23 (Record read as requested.) 24 MS. MURPHY: Object to the 25 form. 0164 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Object to the 3 form. Mischaracterizes the prior 4 testimony. 5 If you can answer it, you 6 can answer it. 7 A. I did not. 8 Q. Thank you. 9 MS. MONAGHAN: Let's take a 10 five-minute break. 11 THE VIDEOGRAPHER: Off the 12 record, the time is 3:25. 13 (A recess was taken.) 14 THE VIDEOGRAPHER: We are 15 back on the record, the time is 3:44. 16 BY MR. PEPE: 17 Q. Can you tell me who 18 Mr. Sidhu is? Do you know a person 19 named Sidhu? 20 A. No. 21 Q. I can't pronounce the name, 22 so I will spell it. It is 23 G-u-r-i-n-d-e-r-j-i-t is the first 24 name, Sidhu, S-i-d-h-u, is the second 25 name. 0165 1 DANA G. TURNER - CONFIDENTIAL 2 A. No. 3 Q. Were you ever -- strike 4 that. 5 Was the west checkpoint 6 understaffed and very busy on the 7 morning of September 11th? 8 MS. MURPHY: Object to the 9 form. 10 MS. MONAGHAN: Objection to 11 the form. 12 A. I have no idea. 13 Q. Were decisions regarding 14 the carriage of knives into the sterile 15 area overturned by air carrier GSCs 16 prior to September 11, 2001? 17 MS. MONAGHAN: Objection to 18 the form. 19 MS. MURPHY: Object to the 20 form. 21 A. I don't know. 22 Q. Do you know if that was 23 often done? 24 MS. MONAGHAN: Objection to 25 the form. 0166 1 DANA G. TURNER - CONFIDENTIAL 2 Do you understand the 3 question? 4 THE WITNESS: No. Can you 5 read it to me again, please? 6 MR. PEPE: Sure. 7 Q. Do you know whether prior 8 to September 11, 2001, American GSCs 9 often overturned screener or supervisor 10 decisions concerning the carriage of 11 knives into the sterile area? 12 MR. AMSTER: Object to the 13 form. 14 MS. MURPHY: Objection to 15 form. 16 MS. MONAGHAN: Objection to 17 the form. 18 A. Do we overturn decisions 19 made by the security checkpoint people? 20 Q. No. Let's have it read 21 back. 22 (Record read as requested.) 23 A. No. 24 Q. Do you know whether, prior 25 to September 11, 2001, American GSCs 0167 1 DANA G. TURNER - CONFIDENTIAL 2 often overturned the decisions of duty 3 managers concerning carriage of knives 4 into the sterile area? 5 MR. AMSTER: Objection to 6 form. 7 MS. MURPHY: Objection to 8 form. 9 MS. MONAGHAN: Objection to 10 form. 11 A. Not that I recall. 12 Q. Do you know whether 13 Argenbright screeners were found at any 14 point prior to September 11, 2001 to be 15 sleeping on duty? 16 MS. MURPHY: Objection to 17 the form. 18 MR. AMSTER: Object to the 19 form. 20 MS. MONAGHAN: Object to the 21 form. 22 A. This is Argenbright in 23 general? 24 Q. At Dulles. 25 A. I'm not aware of that, no. 0168 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And by at Dulles, I mean 3 the Dulles checkpoint that serviced 4 Flight 77. Same answer? 5 A. Same answer. 6 Q. Did you ever hear that 7 Argenbright screeners were sleeping on 8 duty prior to September 11, 2001? 9 MS. MONAGHAN: Objection to 10 the form. 11 MS. MURPHY: Object to the 12 form. 13 A. No. 14 Q. If the checkpoint duty 15 manager on duty on September 11, 2001 16 said that, would you have any reason to 17 doubt him? 18 MS. MURPHY: Object to the 19 form. 20 MR. CROWLEY: Object to the 21 form. 22 MS. MONAGHAN: Objection to 23 the form. She said she -- 24 A. I never heard that at all. 25 Q. Would you have any reason 0169 1 DANA G. TURNER - CONFIDENTIAL 2 to doubt him, is my question? 3 MR. CROWLEY: Objection to 4 the form. 5 MS. MURPHY: Object to the 6 form. 7 MS. MONAGHAN: Objection to 8 the form. 9 A. I can't think of a reason to 10 doubt him, no. 11 Q. Duty manager is a person in 12 charge of the screeners and supervisors 13 at the checkpoint; right? 14 MS. MURPHY: Objection to 15 the form. 16 MS. MONAGHAN: Objection to 17 the form. 18 A. I don't know their titles, 19 no. I don't know duty manager, no. 20 I'm not sure of the checkpoint people's 21 titles. 22 Q. Do you know what a screener 23 is? 24 A. Yes. 25 Q. On September 11, 2001, did 0170 1 DANA G. TURNER - CONFIDENTIAL 2 you know what a supervisor was or CSS? 3 A. Yes. 4 Q. Who was the person on and 5 before September 11, 2001 at Dulles at 6 that checkpoint that serviced Flight 7 77, that supervised the CSSs? 8 A. I don't know the answer. 9 Q. Were you ever told anything 10 about a Middle Eastern woman at Dulles 11 on September 10, 2001 who was very 12 large and wearing sport shoes and 13 didn't appear to be wearing the usual 14 attire for a Middle Eastern woman? 15 MS. MONAGHAN: Objection to 16 the form. 17 MR. KOLAR: Objection to the 18 form. 19 A. No, sir. 20 Q. Did you have frequent 21 contact with the CSSs prior to 22 September 11, 2001? 23 MS. MONAGHAN: Objection to 24 the form. 25 MS. MURPHY: Objection to 0171 1 DANA G. TURNER - CONFIDENTIAL 2 the form. 3 A. No, sir. 4 Q. Do GSCs in general at 5 Dulles -- strike that. 6 Did American GSCs in general 7 at Dulles have frequent contact with 8 the CSSs on and before September 11, 9 2001? 10 MS. MONAGHAN: Objection to 11 the form. 12 MS. MURPHY: Object to the 13 form. 14 MR. CROWLEY: Object to the 15 form. 16 A. GSCs in general? American 17 Airlines GSCs in general? 18 Q. We can have it read back. 19 There were a few other qualifiers in 20 there. 21 (Record read as requested.) 22 A. This GSC did not. 23 Q. Was Dulles in a heightened 24 state of alert on the morning of 25 September 11, 2001 for the possibility 0172 1 DANA G. TURNER - CONFIDENTIAL 2 of a hijacking? 3 MS. MONAGHAN: Objection to 4 the form. 5 MS. MURPHY: Object to the 6 form. 7 MR. AMSTER: Objection to 8 the form. 9 A. No different than the alert 10 that we had been in since 1998. 11 Q. Let's have the question 12 read back. 13 (Record read as requested.) 14 A. No. 15 Q. Was Dulles at AVSEC Alert 16 Level III on September 11th? 17 A. As I recall, yes. 18 Q. Is that a heightened state 19 of alert? 20 MS. MONAGHAN: Objection to 21 form. 22 A. As I said, it was the same 23 level of alert we had been in for 24 years. 25 Q. Was it a high level? 0173 1 DANA G. TURNER - CONFIDENTIAL 2 A. Level III. 3 MS. MONAGHAN: Objection to 4 form. 5 Q. Was that a high level of 6 alert? 7 A. It's Level III. 8 Q. Do you know what Level III 9 meant on September 11th? 10 A. No. 11 Q. Information indicates a 12 terrorist group or other hostile entity 13 with a known capability of attacking 14 civil aviation is likely to carry out 15 attacks against U.S. targets. 16 Does that refresh your 17 recollection? 18 MS. MONAGHAN: Objection to 19 form. 20 A. Everything that we had heard 21 previously about possible attacks were 22 on foreign countries, not on the U.S. 23 MR. PEPE: I move to strike 24 as nonresponsive. 25 Can we have my question read 0174 1 DANA G. TURNER - CONFIDENTIAL 2 back. 3 (Record read as requested.) 4 MS. MONAGHAN: Objection to 5 form. You want to put a document in 6 front of her to refresh her 7 recollection, you can. 8 Q. You can answer. 9 A. I told you what I 10 remembered. So. 11 Q. Was Dulles at AVSEC IV on 12 September 11th, 2001? 13 MS. MONAGHAN: Objection to 14 form. She already said they were at 15 AVSEC Level III. 16 Q. I said in the morning in my 17 first question. This is a question at 18 any point on September 11th. 19 A. At any point on September 20 11th were we at IV? 21 Q. Yes, ma'am. 22 A. We were at Level III on 23 September 11th. It went to IV after 24 the events of September 11th. My day 25 was so skewed at that point in that 0175 1 DANA G. TURNER - CONFIDENTIAL 2 day, I couldn't tell you if it went to 3 IV. 4 Q. Do you know if the FAA 5 required that Dulles go to AVSEC IV on 6 September 11th? 7 MS. MONAGHAN: Objection to 8 form. 9 A. I think I just answered 10 that. If it went to IV during that 11 day. 12 Q. I'm just trying to 13 establish whether you knew one way or 14 the other whether the FAA required 15 Dulles to go to AVSEC IV on September 16 11th. 17 MS. MONAGHAN: Objection to 18 form. 19 Q. If you don't know, the 20 answer is I don't know. If you know, 21 please tell me. 22 A. I know we were at Level III 23 on September 11th. 24 Q. During the morning? 25 A. Yes. 0176 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And you don't know if it 3 changed one way or the other from III 4 to IV on September 11th; correct? 5 A. I do not recall. 6 Q. Okay. And you don't know 7 one way or the other whether the FAA 8 mandated or didn't mandate that Dulles 9 go to alert Level IV on September 11th; 10 correct? 11 MR. CROWLEY: Objection to 12 the form. 13 MS. MONAGHAN: Objection to 14 the form. 15 A. On the afternoon of 16 September 11th, my concern at that 17 particular moment, because I had 18 airplanes on the ground, nothing 19 moving, was not an AVSEC level. It was 20 human beings. 21 Q. That I understand. The 22 question is, do you know whether they 23 did it or didn't? 24 MS. MONAGHAN: Objection. 25 It's asked and answered. 0177 1 DANA G. TURNER - CONFIDENTIAL 2 MR. PEPE: I don't think 3 it's been answered, which is why I keep 4 asking. 5 A. In the afternoon of 6 September 11th, I'm not certain if it 7 was IV or III. 8 Q. Thank you. 9 A. You're welcome. 10 Q. Is that what you were 11 trained prior to September 11th, that 12 Dulles wasn't at a heightened state of 13 alert? 14 MS. MONAGHAN: Objection to 15 the form. 16 MR. CROWLEY: Objection to 17 the form. 18 MR. KOLAR: Objection to the 19 form. 20 THE WITNESS: Can you repeat 21 his question, please, sir. 22 (Record read as requested.) 23 A. Dulles was always at a 24 heightened state of alert, Level III, 25 yes. 0178 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Including on September 3 11th? 4 A. Yes. Level III. 5 Q. Do you know whether the 6 security rules for checkpoint screening 7 were in the process of being changed 8 during the summer of 2001? 9 MS. MONAGHAN: Objection to 10 form. 11 MS. MURPHY: Objection to 12 form. 13 A. I don't recall, sir. 14 Q. Could you please take a 15 look at the exhibit that's placed 16 before you, that's Exhibit 69. 17 Unfortunately someone has absconded my 18 marked up copy, so I'm going to have to 19 do this slowly. 20 Did you ever see this 21 document before? 22 A. No, sir. 23 Q. Did you follow the news 24 prior to September 11th about the 25 Columbine incident? 0179 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Objection to 3 form. 4 A. I remember hearing it on the 5 news, yes. 6 Q. Do you remember hearing on 7 the news that part of their plan was to 8 hijack a plane and crash it into the 9 World Trade Center? 10 MS. MONAGHAN: Objection to 11 form. 12 A. No, not at all. 13 Q. Do you recall reading that 14 in the news? 15 MS. MONAGHAN: Objection to 16 form. 17 A. No, not at all. 18 Q. Okay. Did you receive any 19 training in prior hijackings prior to 20 September 11, 2001? 21 MS. MONAGHAN: Objection to 22 form. 23 MR. PEPE: I can't for the 24 life of me imagine what's wrong with 25 that form. 0180 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: You have a 3 limited imagination. 4 Go ahead. 5 A. Did I receive training in 6 any other hijacking? 7 Q. Did you receive any 8 training related to hijackings, prior 9 hijackings that had occurred, on and 10 before September 11, 2001, as an 11 American GSC? 12 MR. KOLAR: Objection; form. 13 A. This would be so much easier 14 if I were GSC qualified now. I do 15 remember watching videos about previous 16 things that had happened, yes. 17 Q. Other than the videos? 18 A. I remember talking -- I 19 don't remember specifics, I really do 20 not. But talking about previous 21 occurrences, yes. 22 Q. I'm going to go through a 23 list of things, I'm going to ask you if 24 you can recall anything about them. 25 A. Okay. 0181 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Do you recall any training 3 whatsoever. 4 A. Okay. 5 Q. If you answer no, that 6 means you don't recall any training. 7 Okay? 8 A. Okay. 9 Q. Southern Airways Flight 49? 10 MS. MONAGHAN: Objection to 11 form. 12 A. No. 13 Q. Delta Airlines Flight 523? 14 MS. MONAGHAN: Objection to 15 form. 16 A. No. 17 Q. Fed Ex Flight 705? 18 MS. MONAGHAN: Objection to 19 form. 20 A. No. 21 Q. Air France Flight 8969? 22 MS. MONAGHAN: Objection to 23 form. 24 A. No. 25 Q. No? 0182 1 DANA G. TURNER - CONFIDENTIAL 2 A. No. 3 Q. The Bojinka plot? 4 A. Bojinka plot? 5 Q. The Manila plot. The Murad 6 plot, the Youssef plot. There are 7 different words for it. 8 MS. MONAGHAN: Objection to 9 form. 10 Q. Do you recall anything any 11 of those things? 12 A. Too long ago. 13 Q. All Nippon Airways Flight 14 61? 15 MS. MONAGHAN: Objection to 16 form. 17 A. No. 18 Q. What can you tell me about, 19 if anything, about airspace 20 restrictions that were imposed over the 21 G8 Summit in Genoa, Italy in the summer 22 of 2001? 23 MS. MONAGHAN: Objection to 24 form. 25 A. I can tell you nothing. 0183 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Did you receive any 3 training -- strike that. 4 Did you receive any GSC 5 training with respect to the Olympics 6 in 2000? 7 MS. MONAGHAN: Objection to 8 form. 9 A. Not that I recall. 10 MR. PEPE: Let's mark your 11 training file then and see if we can't 12 refresh your recollection. 13 (Witness and counsel 14 confer.) 15 Q. You know what kamikaze 16 pilots are; right? 17 MS. MONAGHAN: Objection to 18 form. 19 A. I've heard the terminology, 20 but I'm not 100 percent sure what it 21 means, no. 22 Q. Do you have any sense? 23 A. Not really. 24 Q. You don't know what a 25 kamikaze pilot was? 0184 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Objection to 3 form. 4 A. It's not something I 5 studied, no. 6 Q. I didn't ask you if you 7 studied it, I asked if you knew what it 8 is. 9 MS. MONAGHAN: Objection to 10 form. 11 A. No. 12 MR. PEPE: Can you mark 13 that. 14 (Turner Exhibit 291 for 15 identification, computer printout, 16 production number AAL 016714.) 17 MR. PEPE: I've just marked 18 as Exhibit 281, and I will now mark 19 281. 20 (Turner Exhibit 292 for 21 identification, document headed 22 "Application for Employment," 23 production numbers AALTSA 007083 24 through AALTSA 007101.) 25 MS. MONAGHAN: 291 and 292. 0185 1 DANA G. TURNER - CONFIDENTIAL 2 MR. PEPE: 291 and 292. 3 291 is a document bearing 4 Bates range AAL 016714. Document 292 5 is a document bearing Bates range AAL 6 5683 through 5701. 7 Will counsel stipulate that 8 292 consists of portions of the 9 witness' personnel file? 10 MS. MONAGHAN: Oh, you mean 11 because it's redacted? I would 12 stipulate that this relates to Dana 13 Turner. 14 MR. PEPE: Is it her 15 personnel file? I understand that some 16 things have been taken out of the 17 personnel files produced by American. 18 But this is Dana Turner's personnel 19 file with those things taken out? 20 MS. MONAGHAN: This is Dana 21 Turner's personnel file, correct. 22 Q. If you could please turn to 23 page 7098, AALTSA 7098. About a third 24 of the way down the page, center 25 column, it says "05-2000 Olympics and 0186 1 DANA G. TURNER - CONFIDENTIAL 2 ETAS." 3 Can you tell me what that's 4 a reference to? 5 A. I know what the 2000 6 Olympics are. And ETAS means to me 7 estimated time of arrivals. But I 8 don't recall. 9 Q. This had nothing to do with 10 security? 11 MS. MONAGHAN: Objection to 12 form. 13 A. In looking at this it 14 didn't. 15 Q. Well, do you remember 16 receiving any training on that? I 17 believe this is your employee training 18 record. 19 MS. MONAGHAN: Are you 20 asking her to confirm that? 21 MR. PEPE: Yeah. 22 MS. MONAGHAN: He wants you 23 to say correct, is this your employee 24 training record, or a portion of it? 25 A. It is mine. 0187 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And do you remember that 3 training that you received? 4 A. In August of 2000? Not 5 today I don't. 6 Q. Were you present -- strike 7 that. 8 Were you present at or ever 9 informed about a presentation made by 10 the FAA to American or airport 11 representatives at Dulles, prior to 12 September 11, 2001, concerning 13 terrorist threats? 14 MS. MONAGHAN: Objection to 15 the form. 16 A. No. 17 Q. I'm going to show you 18 what's been marked as Exhibit 168, 19 please. And I'm also going to show you 20 what's been marked as Exhibit 279. We 21 will start with 168. 22 On Exhibit 168, I'm going to 23 ask you to look to page number, and I 24 apologize, the Bates stamps are 25 difficult to read, it ends with 554. 0188 1 DANA G. TURNER - CONFIDENTIAL 2 And I can actually flip you to it. 3 It's the beginning of the squares. 4 Did you ever see a 5 presentation -- strike that. 6 Did you ever see this 7 presentation? 8 A. No. 9 Q. Did you ever speak with 10 anyone who saw this presentation? 11 A. No. 12 Q. Did you ever have occasion 13 prior to September 11, 2001 to speak 14 with Mr. Bidwell? 15 MS. MONAGHAN: Objection to 16 form. 17 A. I don't recognize that name. 18 Q. Did a gentleman by the name 19 of Mr. Bidwell or Christopher Bidwell 20 ever provide threat information to you 21 as a GSC prior to September 11th? 22 MS. MONAGHAN: Objection to 23 form. 24 A. I don't recall Mr. Bidwell. 25 Q. Where did you get your 0189 1 DANA G. TURNER - CONFIDENTIAL 2 threat information from as a GSC? 3 MS. MONAGHAN: Objection to 4 form. 5 A. The company. 6 Q. Who specifically? 7 A. Headquarters. 8 Q. Who at headquarters? 9 A. Don't know. 10 Q. How would it come to you? 11 A. Via E-mail. 12 Q. Any other way? 13 A. SABRE. 14 Q. SABRE was the on line 15 system? 16 A. It's American's computer 17 system. 18 Q. Was SABRE web based or was 19 SABRE a different system? 20 A. SABRE is American's 21 reservation system, computer system. 22 Q. Any other way? 23 A. Not that I recall. 24 Q. Would the E-mails typically 25 come from one person or one place, one 0190 1 DANA G. TURNER - CONFIDENTIAL 2 address, prior to September 11th? 3 A. I don't remember today. But 4 typically things came from the same 5 place, yes. 6 Q. If you could please turn to 7 the first page of 168. It's reference 8 to slide 4-A. It says "you are 9 probably aware that civil aviation has 10 long been a favored target of terrorist 11 groups and state sponsors of terrorism. 12 An air carrier's flag establishes it as 13 a symbol of the nation or the 14 government of the nation that 15 terrorists want to strike." 16 Was that your understanding 17 on September 11, 2001? 18 MS. MONAGHAN: Objection to 19 form. 20 MR. CROWLEY: Object to the 21 form. 22 A. My understanding in 23 September 2001 was it was abroad, it 24 was not U.S. based. 25 Q. Well, let's turn to slide 0191 1 DANA G. TURNER - CONFIDENTIAL 2 4. I'm sorry, 4-B. 3 A. I'm sorry, 4-B? 4 Q. 4-B. 5 A. Okay. 6 Q. It's the next page. 7 A. It starts at the bottom. 8 Q. Right. I'm going to point 9 you to a specific sentence. 10 A. Okay, sorry. 11 Q. The last paragraph of 4-B, 12 it says "of the groups, we're concerned 13 about the Lebanese Hizballah, which is 14 a surrogate of Iran, and the groups 15 which are part of the International 16 Islamic Front for Jihad against 17 Crusaders and Jews formed by Osama Bin 18 Laden. These groups have 19 representatives in most parts of the 20 world, including North America." 21 Was that your understanding 22 on September 11, 2001? 23 MR. CROWLEY: Object to the 24 form. 25 MR. KERNS: Objection to 0192 1 DANA G. TURNER - CONFIDENTIAL 2 form. 3 MS. MONAGHAN: Objection to 4 form. 5 MR. AMSTER: Object to the 6 foundation as well. 7 MR. PEPE: I don't know how 8 you lay a foundation for a witness' 9 understanding other than asking the 10 witness what her understanding was. 11 MR. CROWLEY: She already 12 testified she hasn't seen the 13 presentation. You are asking her 14 questions about a presentation she says 15 she has no familiarity with. That's 16 improper and it has no foundation. 17 MR. PEPE: I disagree. 18 Let's have the question read back. 19 We are going to strike the 20 last question. 21 Q. Was it your understanding 22 on September 11, 2001 that groups 23 constituting significant threats to the 24 United States had representatives in 25 most parts of the world, including 0193 1 DANA G. TURNER - CONFIDENTIAL 2 North America, specifically including 3 the International Islamic Front for 4 Jihad against Crusaders and Jews formed 5 by Osama Bin Laden? 6 MS. MONAGHAN: Objection to 7 the form. 8 MR. AMSTER: Objection to 9 the form and foundation. 10 A. I think you're asking me to 11 speculate on something, I've never seen 12 this, I don't know -- I've never seen 13 this form. Sometimes there are 14 agencies bigger than us, and we don't 15 get fed this information. So the 16 information that I was fed or we were 17 fed was a threat outside of the U.S. 18 Q. I'm just asking what your 19 understanding was. 20 A. I just gave it to you. 21 MR. AMSTER: Objection; 22 she's asked and answered and told you 23 what her understanding was four or five 24 times. 25 MR. PEPE: I'll state my 0194 1 DANA G. TURNER - CONFIDENTIAL 2 prior objection, which I've stated a 3 couple of times today, that speaking 4 objections that coach the witness as to 5 how to answer a question are improper. 6 THE WITNESS: No one is 7 coaching me, I just answered it. I 8 have not seen this here. This is not 9 information that I was given or we were 10 given. So it wasn't provided to us. 11 My understanding was it was overseas, 12 not in the U.S. 13 Q. Because American never told 14 you that, that there was a domestic 15 threat? 16 MS. MONAGHAN: Objection to 17 form. 18 A. You are asking me to say if 19 American knew it or didn't know it and 20 they just didn't share. I don't know 21 the answer to that question. 22 Q. I'm just asking if they 23 ever told you that, that there was a 24 domestic threat on September 11th, and 25 prior to it. 0195 1 DANA G. TURNER - CONFIDENTIAL 2 MS. MONAGHAN: Objection to 3 the form. 4 Q. Did they or did they not 5 tell you that there was a domestic 6 threat? 7 A. No. Because American wasn't 8 aware of it, to my knowledge. And if 9 they were, I don't have -- I don't have 10 this knowledge. 11 Q. Fine, but you don't know 12 what American knew or didn't know, what 13 you know is what they told you; 14 correct? 15 MS. MONAGHAN: Objection to 16 form. 17 MR. AMSTER: Objection to 18 form. 19 A. I'm going to get you to ask 20 it again because you are asking it 21 different ways each time, attempting to 22 get me to say something. You're 23 confusing me, so ask it one way and 24 let's see if I can answer the question 25 for you, please. 0196 1 DANA G. TURNER - CONFIDENTIAL 2 Q. You already answered the 3 question. My question to you is: 4 A. Okay, thank you. 5 Q. You don't know, is it 6 correct that you do not know what 7 American did or did not know about the 8 domestic threat, what you do know is 9 what American told you; is that a true 10 statement? 11 MS. MONAGHAN: Objection to 12 form. 13 MR. AMSTER: And foundation. 14 A. What I know is what I 15 already stated. 16 Q. Let's go back to the 17 morning of September 11th. We were at 18 the operations center when we last 19 spoke about this topic. When you were 20 at the operations center on September 21 11, 2001, did you receive any 22 information concerning phone calls from 23 Flight 77? 24 A. No. 25 Q. Have you at any point in 0197 1 DANA G. TURNER - CONFIDENTIAL 2 time received information concerning 3 phone calls from Flight 77? 4 A. No. 5 Q. Have you ever read the 9/11 6 Commission Report? 7 A. Have I read it, no. 8 Q. Do you know who Renee May 9 was? 10 A. One of our flight 11 attendants. 12 Q. Did you ever hear anything 13 from September 11th forward about a 14 phone call made by Renee May from the 15 flight? 16 MS. MONAGHAN: Objection. 17 It was asked and answered. It's a 18 lesser included question than the 19 earlier question. 20 Q. I'm just asking for a yes 21 or no answer. Did you ever hear 22 anything about that? 23 A. Still no. 24 Q. Who is Patty Carson? 25 A. She was a former, I believe 0198 1 DANA G. TURNER - CONFIDENTIAL 2 her job title was an MOD. Manager on 3 duty. 4 Q. And what does that job 5 title entail, on September 11th? 6 A. There are folks who answer 7 flight attendant's questions over the 8 phone. 9 Q. Who is Christopher 10 Christensen? Not the attorney at 11 Condon & Forsyth. 12 A. That's exactly what I was 13 going to say. I don't know. 14 Q. So we are in the ops 15 center. 16 A. Okay. 17 Q. Tell me what you can 18 remember. 19 A. Sure. After the aircraft 20 maintenance gentleman had said 21 something to me and asking the agent to 22 stay, I went downstairs. At that point 23 we started getting radio calls for 24 aircraft that were going to divert to 25 Washington Dulles. At that point, 0199 1 DANA G. TURNER - CONFIDENTIAL 2 sometime in that time frame, someone 3 did come and tell me that an airplane 4 had crashed into the center, into the 5 World Trade Center. 6 Q. What time frame? 7 A. I don't know, early. 8 Q. Did you have any evidence 9 or knowledge at that point that Flight 10 77 may have been hijacked? 11 A. No. It was later in the, 12 later in the morning, and before I 13 had -- before I personally had gone to 14 meet any of the diversions, that I got 15 a phone call from airport operations 16 that they said have you heard that 17 something may have happened to 77. And 18 my response was no, I haven't. 19 Q. Can you give me a sense of 20 the timing, how long was it between the 21 time that you first heard that an 22 aircraft had been crashed into the 23 World Trade Center until the time that 24 you first heard that 77 may have had a 25 problem? 0200 1 DANA G. TURNER - CONFIDENTIAL 2 A. Fifteen, twenty minutes. 3 Q. And when you heard that 77 4 might have had a problem, what exactly, 5 if you can recall, if you can't recall 6 exactly just give us your best 7 recollection, what was conveyed to you 8 at that moment during that 9 conversation? 10 A. What I just said? 11 Q. Yes. 12 A. That have I heard that 13 something may have happened to 77, my 14 answer was no, I haven't heard that. 15 No, not yet. I'm beginning to get 16 diversions left and right, and no, I 17 haven't. 18 Q. Who was -- 19 A. It was slightly later, I 20 know you are going to ask me for 21 minutes, but slightly later that we did 22 have confirmation that 77 had gone into 23 the Pentagon. And that's the point 24 where I had folks that I had to gather 25 and say you can't get emotional right 0201 1 DANA G. TURNER - CONFIDENTIAL 2 now, not right now. So at that point 3 we went on because we had, like I said, 4 numerous diversions that landed that we 5 had to get the people off of. 6 Q. We will go to the 7 diversions. 8 A. Sure. 9 Q. In a minute. But I want to 10 make sure I'm getting the full record 11 of what you recall. 12 A. Sure. 13 Q. Who was the person you 14 spoke with, who told you that something 15 may have happened to 77, the name? 16 A. His first name is Bobby, it 17 was airport operations. For the life 18 of me I can't think of his last name. 19 He's since retired. 20 Q. Was he an American 21 employee? 22 A. Airport operations. 23 Q. That's for the airport? 24 A. Um-hum. 25 Q. For Washington airport? 0202 1 DANA G. TURNER - CONFIDENTIAL 2 A. Um-hum. 3 Q. Who did you receive 4 confirmation that 77 went into the 5 Pentagon from? 6 A. Shar Angle. 7 Q. Shar? 8 A. Shar, S-h-a-r. 9 Q. Last name? 10 A. Angle. 11 Q. What did she tell you? 12 A. That 77 had gone into the 13 Pentagon. 14 Q. Anything else? 15 A. Um-um. And MJ was on it. 16 Q. Who is MJ? 17 A. Secretary. 18 Q. MJ was on it? 19 A. Um-hum. 20 Q. On the flight? 21 A. On the flight. 22 Q. Did you have any 23 conversations in between those two 24 about -- 25 A. No. 0203 1 DANA G. TURNER - CONFIDENTIAL 2 Q. About possible hijacking 3 events of 9/11, what can you tell me 4 that happened in between this? 5 A. No, nothing. 6 Q. Did you ever have any 7 discussions with anyone about what the 8 hijackers may have had on board in 9 terms of weapons or prohibited items? 10 MS. MONAGHAN: Objection to 11 form. 12 A. Are you, first on that day? 13 Q. At any point, from that day 14 forward, except your counsel. 15 A. Again, it's been so long 16 ago, I'm certain there is -- ourselves 17 speculated. But I don't remember 18 specifics, no. 19 Q. Okay, so from the time you 20 spoke with Shar? 21 A. Shar. 22 Q. Sorry. 23 A. Okay. 24 Q. What happened after that? 25 Did you watch TV, did you have a TV in 0204 1 DANA G. TURNER - CONFIDENTIAL 2 there? 3 A. There was a TV, I didn't 4 watch TV, no. I didn't have time to 5 watch TV. 6 Q. Did you hear any reports 7 coming back about, you know, from 8 screeners or from anyone that was on 9 duty that day, about their impressions 10 of the day or what happened? 11 A. No. 12 Q. You spoke about Flight 77 13 going into the Pentagon. Had 93 gone 14 down yet? 15 A. I don't know. 16 Q. When did you learn 93 went 17 down? 18 MS. MONAGHAN: Objection to 19 form. 20 A. I couldn't even tell you. 21 Probably late in the day, that day. 22 Q. Who was in the operations 23 center? I already asked you that, I 24 apologize. 25 Were you on the phone in the 0205 1 DANA G. TURNER - CONFIDENTIAL 2 operations center with SOC? 3 A. No, I wasn't. 4 Q. Who was responsible for the 5 hijacking response at Dulles? 6 MS. MONAGHAN: Objection to 7 form. 8 Q. For American. 9 A. Someone who was responsible 10 to have an open phone line when stuff 11 like that happens. And I was 12 responsible for the operation at that 13 point. You are asking -- I can't be 14 100 percent sure, but Mr. Hazell I 15 would say had the open phone line for 16 SOC. 17 Q. So you weren't on with SOC? 18 A. No. 19 Q. And the information was 20 getting filtered through, to and 21 through SOC in terms of the hijacking 22 response, when information was coming 23 in? 24 A. I wasn't on the call, but 25 that's what should happen. 0206 1 DANA G. TURNER - CONFIDENTIAL 2 Q. That's what SOC is there 3 for? 4 A. Correct. 5 Q. Were you interviewed by the 6 FBI? 7 A. Yes. 8 Q. When? 9 A. I think a million times that 10 week. 11 Q. And obviously a million -- 12 A. More. Thank you for the 13 opportunity. 14 Q. It felt like it. 15 A significant number of 16 times or a number of times? 17 A. Yes, a number of times, yes. 18 Q. Was it the same agent that 19 interviewed you? 20 A. I don't remember. No, there 21 were numerous people. No. 22 Q. Were you interviewed by the 23 FAA? 24 A. Yes. Don't know who. 25 Q. Were you interviewed by the 0207 1 DANA G. TURNER - CONFIDENTIAL 2 Secret Service? I'm sorry? 3 MS. MONAGHAN: She's 4 thinking. 5 A. I remember NTSB, I don't 6 remember Secret Service, per se. 7 Q. Were you involved in any 8 way in the coordination of, you know, 9 facilitating FBI, FAA, NTSB interviews 10 of other employees at American, or 11 Argenbright? 12 A. No. 13 Q. Did you tell anything to 14 the FBI that you haven't told us about 15 the events of September 11th? 16 A. No, sir. 17 Q. Did you have a written 18 statement? 19 A. I don't recall. 20 Q. So you've never seen a 21 copy, transcript, copy, notes, of 22 anything about your statement? 23 A. If they had asked me for one 24 I certainly would have provided it. 25 But I don't recall having done that. 0208 1 DANA G. TURNER - CONFIDENTIAL 2 Q. Same thing with the FAA and 3 NTSB? 4 MS. MONAGHAN: Objection to 5 the form. 6 A. Yes, sir. 7 Q. Did you tell anything to 8 the FAA or the NTSB that you didn't 9 tell us? 10 A. No. 11 Q. Did you speak with the 9/11 12 Commission? 13 A. No. 14 MR. PEPE: Ma'am, I have no 15 further questions. Thank you for your 16 time. One of my colleagues may, but I 17 don't. I reserve my right to have 18 redirect if we are going to have 19 redirect. 20 THE WITNESS: Thank you. 21 MR. PEPE: Take a couple of 22 minutes. 23 THE VIDEOGRAPHER: Off the 24 record, the time is 4:27, and this is 25 the end of tape 2. 0209 1 DANA G. TURNER - CONFIDENTIAL 2 (A recess was taken.) 3 THE VIDEOGRAPHER: We are 4 back on the record, the time is 4:42, 5 and this is the beginning of tape 6 No. 3. 7 MR. PEPE: We have no 8 further questions at this time. 9 MS. MONAGHAN: I just have 10 very few. 11 Let me ask the court 12 reporter to mark an exhibit for 13 identification, please. 14 (Turner Exhibit 293 for 15 identification, computer printout, 16 production numbers AAL 000672 through 17 AAL 000673.) 18 EXAMINATION BY 19 MS. MONAGHAN: 20 Q. Ms. Turner, I'm showing you 21 what's been marked as Exhibit 293 for 22 identification, which bears Bates 23 numbers AAL 000672 through 673. Do you 24 recognize this document? 25 A. I do. 0210 1 DANA G. TURNER - CONFIDENTIAL 2 Q. What is it? 3 A. Passenger manifest for 4 Flight 77 on September 11th departing 5 Washington Dulles. 6 Q. Let me direct your 7 attention to the passenger listed at 8 number 1 on this list. Do you know who 9 that passenger is? 10 MR. PEPE: Objection to 11 form. 12 A. One of the hijackers. 13 Q. And do you see to the right 14 of the passenger listed at number 1, 15 the designation club? 16 A. I do. 17 Q. What does club mean on the 18 passenger list like this? 19 A. A member of our Admiral's 20 Club. 21 Q. Let me direct your 22 attention to the passenger listed at 23 number 12, Al Hazmi. Do you know who 24 that was? 25 A. One of the hijackers. 0211 1 DANA G. TURNER - CONFIDENTIAL 2 Q. And do you see to the right 3 of his name the designation club? 4 A. I do. 5 Q. And again, what does club 6 mean? 7 A. A member of our American 8 Airlines Admiral's Club. 9 Q. And do you see below that 10 and slightly to the left of it, this is 11 a code that says HNML? 12 A. I do. 13 Q. What does HNML mean? 14 A. Ordered a special meal, 15 Hindu meal. 16 Q. And let me direct your 17 attention to the passenger listed at 18 number 13. Do you know who that is? 19 A. Also one of the hijackers. 20 Q. And going to the right of 21 his name, again, do you see the 22 designation club? 23 A. I do. 24 Q. And again, what does club 25 mean? 0212 1 DANA G. TURNER - CONFIDENTIAL 2 A. A member of the American 3 Airlines Admiral's Club. 4 Q. And do you see next to his 5 name the designation HNML, the code 6 actually appears twice? 7 A. I do. 8 Q. And again, what does HNML 9 mean? 10 A. That they ordered a special 11 meal in advance, Hindu meal. 12 Q. Let me direct your 13 attention to the passenger listed at 14 number 20. Do you recognize that name? 15 A. One of the hijackers. 16 Q. And moving to the right of 17 his name, do you see the code AD 18 reflected there? 19 A. I do. 20 Q. What does AD mean? 21 A. He was an Aadvantage member. 22 Q. What is Aadvantage? 23 A. It's our frequent flyer 24 program. 25 Q. A little bit earlier, 0213 1 DANA G. TURNER - CONFIDENTIAL 2 Ms. Turner, you testified regarding 3 information that American received that 4 may or may not have been passed on to 5 you. Do you recall that testimony? 6 MR. PEPE: Objection to 7 form. 8 A. I do. 9 Q. And do you know, if 10 American received a security directive 11 from the FAA, was that security 12 directive passed on to you? 13 MR. PEPE: Objection to 14 form. 15 A. It was. 16 Q. Was it passed on to all 17 GSCs? 18 A. Yes, ma'am. 19 MR. PEPE: Objection to 20 form. 21 Q. And if American received an 22 information circular from the FAA, was 23 that passed on to you? 24 MR. PEPE: Objection to 25 form; foundation. 0214 1 DANA G. TURNER - CONFIDENTIAL 2 A. It was. 3 Q. And was that passed on to 4 all GSCs if American received an IC 5 from the FAA? 6 MR. PEPE: Objection to 7 form. 8 A. Yes, ma'am. 9 MS. MONAGHAN: No further 10 questions. 11 MR. PEPE: I have no 12 questions. 13 MS. MONAGHAN: We are done. 14 THE VIDEOGRAPHER: Off the 15 record, the time is 4:47. 16 (Time noted: 4:47 p.m.) 17 18 19 _______________________ 20 DANA G. TURNER 21 Subscribed and sworn to before me 22 this _____ day of _________, 2007. 23 24 __________________________________ 25 0215 1 DANA G. TURNER - CONFIDENTIAL 2 STATE OF NEW YORK ) ss: 3 COUNTY OF NEW YORK ) 4 I wish to make the following changes, for the following reasons: 5 PAGE LINE 6 ____ ____ CHANGE ______________________ REASON:______________________ 7 ____ ____ CHANGE ______________________ 8 REASON:______________________ 9 ____ ____ CHANGE ______________________ REASON:______________________ 10 ____ ____ CHANGE ______________________ 11 REASON:______________________ 12 ____ ____ CHANGE ______________________ REASON:______________________ 13 ____ ____ CHANGE ______________________ 14 REASON:______________________ 15 ____ ____ CHANGE ______________________ REASON:______________________ 16 ____ ____ CHANGE ______________________ 17 REASON:______________________ 18 ____ ____ CHANGE ______________________ REASON:______________________ 19 ____ ____ CHANGE ______________________ 20 REASON:______________________ 21 _______________________ 22 DANA G. TURNER Subscribed and sworn to before me 23 this _____ day of _________, 2007. 24 25 __________________________________ 0216 1 DANA G. TURNER - CONFIDENTIAL 2 C E R T I F I C A T E 3 STATE OF NEW YORK ) : ss. 4 COUNTY OF NEW YORK ) 5 6 I, ERIC J. FINZ, a Shorthand 7 Reporter and Notary Public within and 8 for the State of New York, do hereby 9 certify: 10 That DANA G. TURNER, the witness 11 whose deposition is hereinbefore set 12 forth, was duly sworn by me and that 13 such deposition is a true record of the 14 testimony given by the witness. 15 I further certify that I am not 16 related to any of the parties to this 17 action by blood or marriage, and that I 18 am in no way interested in the outcome 19 of this matter. 20 IN WITNESS WHEREOF, I have hereunto 21 set my hand this ____ day of 22 ___________, 2007. 23 24 _______________ 25 ERIC J. FINZ 0217 1 DANA G. TURNER - CONFIDENTIAL 2 E X H I B I T S 3 DESCRIPTION PAGE 4 (Turner Exhibit 287 for 85 5 identification, standards for 6 security oversight.) 7 (Turner Exhibit 288 for 96 8 identification, articles, 9 production numbers BYCK 001 10 through BYCK 008.) 11 (Turner Exhibit 289 for 108 12 identification, TSA Document 13 Request No. 3, production 14 numbers TSA 0551 through TSA 15 0649.) 16 (Turner Exhibit 290 for 108 17 identification, TSA Document 18 Request No. 3, production 19 numbers TSA 001 through TSA 20 0375.) 21 (Turner Exhibit 291 for 184 22 identification, computer 23 printout, production number AAL 24 016714.) 25 0218 1 DANA G. TURNER - CONFIDENTIAL 2 E X H I B I T S (Continued) 3 DESCRIPTION PAGE 4 (Turner Exhibit 292 for 184 5 identification, document headed 6 "Application for Employment," 7 production numbers AALTSA 007083 8 through AALTSA 007101.) 9 (Turner Exhibit 293 for 209 10 identification, computer 11 printout, production numbers AAL 12 000672 through AAL 000673.) 13 14 15 16 17 18 19 20 21 22 23 24 25