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Elizabeth Heller

Activity Camp Director at COAC. She was responsible for the hiring, supervision and training of Activity Camp counselors.

Nearly four years after Yoni's death, four years of denying any
responsibility by the defendants, on the first day of trial March 24,
2009, for the first time this defendant admitted (through her attorney)
that she was negligent and the cause of Yoni Gottesman's death. Yet,
in depositions she denied being negligent or any responsibility in
Yoni's death.

Elizabeth Heller
Elizabeth Heller was negligent and the cause of Yoni Gottesman's death.

Elizabeth Heller 12/01/2008

Q. After seeing the video, do you believe you
were responsible for the death of that child?

A. No, I don't.

Q. Do you believe you have any responsibility
for the death of that child?

THE WITNESS: No, I don't know.

Q. None, no responsibility?
Q. Do you sleep well at night, ma'am?

Q. Now, your job also was to make sure that
those kids were safe, right?

A. Right.

Q. But is it fair to say that other than what
you already have told us, you really had no training
in pool safety?

A. Right.

Q. Right?

A. Right.

Q. The club didn't offer any to you, other
than telling you to get your CPR certification,

THE WITNESS: That's correct.

Q. You didn't ask for any, did you?

A. No.

Q. You weren't aware of whether or not there
were emergency protocols for safety at the pool; is
that right?

THE WITNESS: That's correct.

Q. And nobody told you about them, right?

Q. The fact that there was such a thing as an
emergency protocol for pool incidents?

THE WITNESS: No, I don't. No.

Q. And the only thing that you knew about the
pool as far as rules were the pool rules that we
have already discussed; is that right?

A. That's correct.

Q. Now, that is Exhibit 3 there, pool rules?
MR. CAPPELLO: 3, yes. It says "COAC pool

Q. Now, ma'am, as we look at these rules one
last time and you see number 8, "Please do not throw
children or have them sit on your shoulders." Did
you see anybody throw the children when we looked at
the video?

A. No.

Q. It says, "No rough-housing."
Did you see any rough-housing?

A. No.

Q. It says, "No flipping, twisting, diving or
jumping in backwards."
Did you see any of that take place?

A. No.

Q. So as far as you're concerned, these rules
didn't cover what you saw Mr. Shipley doing; is that

A. That's right.

Q. In any event, what Mr. Shipley did was not

A. That's correct.

Q. Now, after the incident, you stayed at the
club for about -- do you remember how long it was?

A. I'm not sure. Probably until the end of
the month. Maybe a little bit into September.

Q. Were any changes made concerning safety
issues at the pool that you were made aware of?

THE WITNESS: No, not that I was made
aware of.

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Yoni Gottesman