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Q. All right. And is that right, on April 10th? A. Correct. Q. All right. And Doug Nicholson again makes a $50 contribution, right? A. Yup. Q. As does Sarah? A. Yup. Q. And after Doug Nicholson's $50, his year-to-date continues to be $400? A. Yeah. That should have been $450. Sarah should have been $300. Q. So that's a mistake found in your sworn campaign contribution finance statement? A. If that's the numbers. We have to go back and check. Q. And Sarah's $50 donation, again, did not change the ticker on her year-to-date. That's another mistake, right? A. It may have been. I have to go back and check. Q. Are you aware of Doug and Sarah Nicholson ever making contributions by way of check? A. I wouldn't know. Q. What's that? A. I wouldn't know. Q. Okay. You would be able to pull the checks, right? A. If they have them, yeah.
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Q. That he was spreading the money out between Doug and his wife and others? MR. COHEN: Objection to the form of the question. THE WITNESS: Or they simply decided to give $50 at a time. BY MR. ELDRIDGE: Q. What do you think is more likely? MR. COHEN: Objection to the form of the question. THE WITNESS: I don't know. BY MR. ELDRIDGE: Q. Exhibit 244 for you, sir. Could you identify Exhibit 244 for us, please? A. This is the July 20th report. Q. This is a campaign finance report -A. Correct. Q. -- on behalf of John Dickert for Mayor? A. Um-hum. Q. Yes? A. Yes. Q. Signed by Mary Jerger? A. Correct. Q. Who is your treasurer, true? A. Correct.
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Q. Are you required to keep the checks? A. I don't know. Q. Okay. If you flip to the next page, page 5. The second line down shows -- second and third lines down show, again, $50 contributions from Doug and Sarah Nicholson, yes? A. That's what it states. Q. And again, the year-to-date is not updated. It continues to remain at $400 for Doug and $250 for Sarah, true? A. That's what it states, yup. Q. According to campaign finance reports submitted on your behalf, Doug Nicholson and Sarah Nicholson made $50 contributions on April 7th, April 10th and April 13th? A. According to the report, yes. Q. And do you believe that that's true? A. That's what it states. Q. Why would they make three $50 campaign contributions within a period of six days? A. I don't know. Q. Isn't this consistent with Zak Williams' statement? MR. COHEN: Objection to the form of the question. BY MR. ELDRIDGE:
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Q. If you flip to the second page on this exhibit. A. Um-hum. Q. You'll see about 10 lines down there are additional contributions from Doug and Sarah Nicholson, see what I'm referring to? A. Um-hum. Q. Yes? A. Yes, I do. Q. On April 23rd, 2009 Doug Nicholson apparently donated another $50, yes? A. That's what it states. Q. And Sarah Nicholson donated $50 as well on the same day? A. Correct. Q. Flip the page. If you go to about two-thirds of the way down you'll see Doug and Sarah's name show up again, do you see what I'm referring to? MR. COHEN: Date, please? MR. ELDRIDGE: April 27th, 2009. THE WITNESS: Yup. BY MR. ELDRIDGE: Q. For purposes of the record, it's the third page on Exhibit 244, do you see that? A. Yes. Q. And yet again Doug makes a $50 donation, yes?
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Case 2:14-cv-00208-JPS Filed 09/28/15 Page 13 of 45 Document 229-7