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contribution in the amount of $1,000 in crisp $100 bills with a bank wrapper on it, don't you think you would know about it? A. That's Zak's job, No. 1. But No. 2, I would ask him to have them write out checks to my campaign. Q. Right. Don't you think if Doug Nicholson in fact gave a contribution of $1,000 in crisp $100 bills, you would know about it? MR. COHEN: Objection to the form of the question. Go ahead and answer him again. THE WITNESS: No, I don't know that I would know about it. BY MR. ELDRIDGE: Q. You don't think he would tell you? A. I would hope he would so that I could correct him. Q. Did you ever ask Doug Nicholson why he pled the 5th when asked these questions? A. No. Q. Why don't you take a look at pages 75 through 77 of Zak Williams' statement. (Witness peruses document.) A. To 77 you said? Q. I did. Have you finished? A. Yeah. Q. You saw that Zak Williams said in his statement that
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Q. And Zak is lying? A. Yes. Q. You saw earlier that Zak said in his statement that he was spreading the money around between Doug Nicholson, Doug Nicholson's wife and other individuals. Do you recall him saying that? A. I don't know if I read that in here. Q. I'll show it to you. Page 64, line 7 through 15. Just so you have some reference. A. Okay. Q. Do you recall him now that you see that he said that? A. He said that. Q. Okay. I'm going to show you Exhibit 243. MR. ELDRIDGE: I do have a copy for you, Michael. BY MR. ELDRIDGE: Q. Can you identify Exhibit 243 for the record, please? A. This is the fall filing 2009. May 1st. Q. This is a campaign finance report? A. Correct. Q. Made on behalf of John Dickert for Mayor? A. Yup. Q. Signed by Mary Jerger who is your treasurer? A. Correct. Q. If you flip to the fourth page of this exhibit, 11
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you pulled him aside after the primary and told him to call Doug Nicholson and see if you could get another $1,000 out of him. Did you do that? A. No. Q. You're denying that? A. Yes. Q. Zak Williams said that he went to the Ivanhoe, and Doug Williams (sic) in fact gave him another $1,000 in bank wrapped $100 bills. Are you aware of that happening? A. No. Q. Do you deny that that happened? A. I don't know what happened with Zak and Doug, but I don't recall or know anything about that. Q. Zak also said in his statement that after he told you about the $1,000 received from Nicholson, you told him, quote, good, end quote. Is that true? A. I don't remember ever saying that to Zak or him ever showing me another $1,000. Q. He might have showed you $1,000 received from Nicholson, you just don't remember? A. I don't recall him ever showing me $1,000. Q. Okay. So you're denying that he showed you $1,000? A. Yes.
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lines down, you see that on April 7th, 2009 there are reported contributions from Doug and Sarah Nicholson? A. Okay. Q. Am I correct? A. That's what it shows. Q. Okay. And is Sarah Doug's wife? A. Yes. Q. And columns to the far right show the purported contribution and then what they have contributed thus far that year? A. Year-to-date, correct. Q. And it shows as of April 7th, 2009 Doug Nicholson made a $50 contribution and which put him up to $400 year-to-date? A. Okay. Q. Right? A. That's what it states. Q. Okay. And on the same date Sarah Nicholson made a $50 contribution which put her up to $250? A. That's what it states. Q. If you go about 10 lines down, there are cash or -Strike that. There are contributions from both Doug and Sarah Nicholson again, a mere three days later? A. Okay.
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Case 2:14-cv-00208-JPS Filed 09/28/15 Page 12 of 45 Document 229-7