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A. I don't know. MR. COHEN: Objection to the form of the question, assumes facts not in evidence. BY MR. ELDRIDGE: Q. You don't think that's consistent with their testimony? A. I don't know the genesis of this email. Q. April 22nd of 2009 was in between the primary and general elections, true? A. It was. (Exhibit 1575 marked.) BY MR. ELDRIDGE: Q. I'll show you Exhibit 1575. It's a short one. Let me know when you've completed reading it. (Witness peruses document.) A. Okay. Q. Have you seen this email before? A. I believe I have. Q. Okay. Again, the first email is Greg Bach's instruction for Zak to call Tom Tousis on April 22nd, right? A. Correct. Q. And Zak Williams responds to Greg Bach saying, quote: If John if there, tell him to go print the labels and go fuck himself, end quote.
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bear out that when we closed on the first session of Mayor Dickert's deposition on July 10th, I approximated that I would have two hours. I can't approximate it to the minute. And so what the Mayor has done here is he's scheduled the deposition to start at 1:30 with a 3:30 meeting, so completely and utterly narrowed my time. And I don't think it's appropriate to adjourn the deposition at this time. I think we should continue and complete the deposition. At a very minimum, I should have been given advance notice that the Mayor had 120 minutes and no more. THE WITNESS: I believe it's approximately 3:37. MR. ELDRIDGE: There is no question pending. MR. COHEN: Hold on. MR. ELDRIDGE: So I think, Michael, that we should complete the deposition and that the Mayor should make other arrangements tonight. MR. COHEN: Well, first of all, he didn't schedule the deposition, the lawyers scheduled the deposition. MR. ELDRIDGE: I was told 1:30. MR. COHEN: Well, he asked me how long it
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Do you see what I'm referring to? A. I do. Q. Do you know what Zak is referring to with respect to the labels? A. I do not. Q. Did Zak have an agenda against you in April of 2009? A. Zak and Mary were fighting, and the fighting was ramping up quite a bit during into the campaign regarding the campaign finance statements. Q. Why were they fighting? A. Mary wanted information that Zak wasn't giving them. Q. Like what? A. I don't know. Ask her. Q. What are you aware of? A. I don't know. All I know is they were fighting. I told them to work it out. Michael, reminder, I'm supposed to be in a meeting. MR. ELDRIDGE: Off the record for a second. THE VIDEO OPERATOR: Off the record, p.m. (Recess taken.) THE VIDEO OPERATOR: We're back on the record, 3:37 p.m. MR. ELDRIDGE: I think the record will
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would take. You said approximately two hours. He scheduled a meeting which he's now late for. So that's the way it is. He's the Mayor of the City. He's busy. He's got a schedule. MR. ELDRIDGE: Well, I'm busy, too, and I would have appreciated starting this deposition earlier if the Mayor had a strict, firm occasion that he had to attend to at 3:30. MR. COHEN: He had meetings this morning, and I had stuff on my schedule, too. MR. ELDRIDGE: Then we should have picked a different day. But it's not fair to make me continue to have to come back to continue this deposition. MR. COHEN: You also didn't ask me does he have time at the end of the day if I'm over two hours. MR. ELDRIDGE: Well, I mean -MR. COHEN: I did tell you this morning that you had better get it done. MR. ELDRIDGE: No, you didn't tell me that this morning, you told me when we arrived here. MR. COHEN: 1:30. MR. ELDRIDGE: When we started I would have appreciated a little advanced notice. Maybe I
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Case 2:14-cv-00208-JPS Filed 09/28/15 Page 20 of 45 Document 229-7