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Q. Tom Tousis testified that after he stuffed the jar with money, Zak Williams came by the gas station to pick it up, did you see that testimony? A. That's what he said. Q. And are you aware of that occurring? A. No. Q. Tom Tousis testified that you made it very clear to him that his contribution was not going to be reported, did you read that testimony? A. I read the testimony. Q. Is that true? Did you make it clear to Mr. Tom Tousis that his contribution was not going to be reported? A. No. Q. Is Mr. Tousis lying about such matters? A. Yes, including the testimony earlier on the house. Q. Pardon me? A. You asked me to read page 62, correct? Q. Yeah. A. He stated that I did something as a realtor that was illegal and impossible to do. Q. That's about the real estate deal that you were involved in concerning a house? A. Correct. Q. And Mr. Tousis was the builder?
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Q. You don't know because you didn't review them in preparation for today? A. Correct. Q. Or ever really? A. For the most part. Q. You just relied upon everyone else to do your job? A. To do their job. MR. COHEN: Objection, assumes facts not in evidence, also calls for a legal conclusion. BY MR. ELDRIDGE: Q. Did you tell Tom Tousis that you were broke, you had just thrown all your money into the campaign and you needed money to do radio advertising, otherwise you were going to lose and he was never going to get his West Racine project done? A. Never told him that. Q. Were you broke in between the primary and the election in 2009? A. We were raising money consistently. Q. Were you broke? A. We were raising money consistently. I don't know how much we had in the account. Q. So there would be no reason for you to take out loans to finance your campaign? A. We may.
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A. I don't know what his relationship was then, but it's impossible for me to do what he said I was able to do. Q. Okay. A. So is he lying? Yes. Q. Okay. Would you agree that Mr. Tousis's description about the campaign contribution was consistent with Zak Williams'? MR. COHEN: Objection to the form of the question. THE WITNESS: I believe you have two pathological liars. Outside of that -BY MR. ELDRIDGE: Q. They are two pathological liars? A. Testimony is pretty evident of that. Q. Or they're truthful and someone else is lying? A. No. MR. COHEN: Objection, argumentative. THE WITNESS: I think they're lying. BY MR. ELDRIDGE: Q. I know what you think. Did you receive any donations or contributions from Tom Tousis in 2009? A. I don't know. Q. Were any reported in your campaign finance reports? A. I don't know.
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Q. Well, did you -- did the campaign need money in between the primary and the special election in 2009 for purposes of advertising? A. The campaign always needs money for advertising. Q. Okay. Were you in a desperate situation to get money for advertising in between the primary and the special election in 2009? A. I don't know that we were in a desperate situation. Q. Do you remember ever telling Tom Tousis that you were broke and you needed money ASAP? A. No. Q. The primary election in 2009 was the first week of April, right? A. I don't recall the exact date. I think it was during the April election. I think the primary was during the April election. Q. And the general election was in May of 2009, true? A. Correct. Q. There was about 30 days between the election, primary and general? A. I believe so roughly. Q. Okay. (Exhibit 1574 marked.) BY MR. ELDRIDGE: Q. I'm going to show you what I've marked as Deposition
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Case 2:14-cv-00208-JPS Filed 09/28/15 Page 18 of 45 Document 229-7