Witness: Yes.

Steuer: In your experience, was this door ever locked during the workday?

Witness: No.

Steuer: Why didn’t someone open this door, then?

Witness: There was so much panic and everyone was pushing. Nobody could open the door. All those girls were pushing and pushing together, it was just so terrible, with the smell of everything burning, hair and clothing and the black smoke everywhere, and everyone was coughing and crying, and they were all pushing at once. There was the terrible smell of burning hair, and the smell of burning flesh, once you smell it, you will know it forever, like cooking meat only so terrible.

Steuer: Would it have been possible to open the door if there hadn’t been so much confusion?

Witness: I don’t know.

Steuer: On a regular day, would it have been possible for anyone to open that door?

Witness: I guess so.

Steuer: Was that door usually locked at closing time?

Witness: No, it was the door we all have to go through, one by one, like I keep saying.

Steuer: So you never knew the door to be locked?

Witness: That was the door we go out, how could it be locked? You ask the same thing a different way but it’s the same thing.

Steuer: Thank you. Please continue. What did you do next after you saw all the girls crowding in such confusion and disorder that they couldn’t open the Washington Place stairway door?

Witness: I had this idea about the other door—it was for the bosses only, not for the girls, on the weekends, it was a rule—but it was by the back side of the building, the Greene Street side. By the freight elevators, they could go up these stairs to the tenth floor, that’s where the offices were. So I go right into the flames to get across. Maybe that was when I got my burn on my face and my hand, I don’t remember. Mr. Jacobs has a waist wrapped around his face like a mask, so he makes it safe to breathe, he knows how to make himself safe, and I see him going to this other door, and he’s got a key, and I see him unlock the door, and he goes in the door but then he closes it behind him.

Steuer: Did you see him take the key from his pocket or was it on a string hanging by the door?

Witness: I am pretty sure I seen him take the key from his pocket.

Steuer: Are you aware that four other people have testified that this key was kept on a string of material, hanging by the door, two of them testifying just this morning in this courtroom, sitting where you are sitting now, having sworn to tell the truth, just as you have sworn to tell the truth?

Bostwick: Objection.

Witness: I never seen any key on any string by that door, and that’s the truth.

Steuer: Had you ever had any occasion to go through this stairway door in your ten months working at the Triangle Waist Company?