FROM THE MOTION: City Attorney Scott Letteney is a material witness in this case, which involves a fraud
claims. Attorney Letteney, as Deputy City Attorney and City Attorney for the City of Racine,
was and is materially involved in actions, communications and decisions of defendants regarding
the Machinery Row Project for all times relevant to this case. Further, the Racine City Attorney's
Office was and is materially involved in actions, communications and decisions of defendants
regarding the Machinery Row Project for all times relevant to this case. Pursuant to Wis. Stat. S
802.03(2), Plaintiffs are required by Wisconsin statutory law to plead the fraud claims “with
particularity.” City Attorney Scott Letteney is a material witness whose testimony ties facts
together to prove the fraud claims.
