SUPERIOR COURT OF THE STATE OF CALIFORNIA HALL OF JUSTICE SAN DIEGANS FOR OPEN GOVERNMENT, ) ) Plaintiff, ) ) vs. )Case No.: )37-2012-00088065-CU-MC-CTL ) CITY OF SAN DIEGO, et al., ) ) Defendants. ) _____________________________________) VIDEOTAPED DEPOSITION OF RICHARD LAWRENCE San Diego, California NOVEMBER 17, 2014 REPORTED BY BRIDGET L. MASTROBATTISTA, CSR NO. 7715, REGISTERED MERIT REPORTER CERTIFIED REALTIME REPORTER Peterson Reporting, Video & Litigation Services Richard Lawrence, 11-17-14 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 HALL OF JUSTICE 3 4 5 6 7 8 9 SAN DIEGANS FOR OPEN GOVERNMENT, ) ) Plaintiff, ) ) vs. )Case No.: )37-2012-00088065-CU-MC) CITY OF SAN DIEGO, et al., ) ) Defendants. ) _____________________________________) 10 11 12 VIDEOTAPED DEPOSITION OF RICHARD LAWRENCE, 13 taken by the Attorneys the Defendant San Diego Tourism 14 Marketing District Corporation, commencing at the hour 15 of 10:06 a.m. on Monday, November 17, 2014, at 530 B 16 Street, Suite 350, San Diego, California, before Bridget 17 L. Mastrobattista, Certified Shorthand Reporter, No. 18 7715, RMR, CRR, in and for the State of California. 19 20 21 22 23 24 25 Peterson Reporting, Video & Litigation Services 2 Richard Lawrence, 11-17-14 1 2 3 4 5 6 APPEARANCES: For the Plaintiff: BRIGGS LAW CORPORATION BY: CORY J. BRIGGS, ESQ. 99 East C Street, Suite 111 Upland, California 91786 t.619.949.7115 For the Defendant San Diego Tourism Marketing District Corporation: 7 8 9 10 11 12 13 14 COLANTUONO, HIGHSMITH & WHATLEY, PC BY: JENNIFER L. PANCAKE, ESQ. 300 South Grand Avenue, Suite 2700 Los Angeles, California 90071-3137 t.213.542.5717 f.213.542.5710 For the Defendant City of San Diego: CITY ATTORNEY'S OFFICE CITY OF SAN DIEGO BY: CARMEN BROCK, ESQ. 1200 Third Avenue, Suite 1100 San Diego, California 92101 t.619.236.6220 f.619.236.7215 15 16 17 18 Also Present: HONORABLE WILLIAM PATE Judge of Superior Court (Ret.), Discovery Referee The Videographer: Abel Sibrel 19 20 21 22 23 24 25 Peterson Reporting, Video & Litigation Services 3 Richard Lawrence, 11-17-14 1 I N D E X 2 WITNESS: RICHARD LAWRENCE 3 4 EXAMINATION 5 BY MS. PANCAKE 6 BY MR. BRIGGS 186 7 BY MS. PANCAKE 187 8 9 10 EXHIBITS: Amended Notice of Deposition of Richard Lawrence and Requests for Production of Documents 23 2 Notice of Deposition of [blank]; Request for Documents; Subpoena Duces Tecum 42 3 Articles of Incorporation of All People's Breakfast Organizing Committee 52 4 Certificate of Amendment of Articles of Incorporation 62 5 Bylaws of San Diegans for Open Government A California Public Benefit Corporation 75 6 Statement of Information 77 7 Statement of Information 78 8 Letter from the Franchise Tax Board dated 10/26/12 102 9 Document entitled "Richard Lawrence Day" Present by Council President Anthony Young 107 15 16 MARKED 1 13 14 9 E X H I B I T S 11 12 PAGE 17 18 19 20 21 22 23 24 25 /// Peterson Reporting, Video & Litigation Services 4 Richard Lawrence, 11-17-14 1 10 Article titled "How San Diego's Most 110 Disruptive Lawyer Makes His Money," by Liam Dillon, May 27, 2014 11 Document from California Secretary of State, Business Entity Detail 12 Copy of a check from the City of San 154 Diego 6 13 199N e-Postcard Confirmation 160 7 14 Third Amended Complaint for Relief Under Reverse-Validation Statutes, Etc. 172 2 3 134 4 5 8 9 10 QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER 11 PAGE LINE 12 32 13 13 37 11 14 38 4 15 40 14 16 76 8 17 86 2 18 90 16 19 100 5 20 101 5 21 105 5 22 116 4 23 121 19 24 129 24 25 136 24 Peterson Reporting, Video & Litigation Services 5 Richard Lawrence, 11-17-14 1 QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER 2 PAGE 3 137 13 4 138 17 5 149 24 6 163 2 7 169 15 8 177 8 9 LINE INFORMATION REQUESTED 10 PAGE 11 160 LINE 13 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Peterson Reporting, Video & Litigation Services 6 Richard Lawrence, 11-17-14 1 MONDAY, NOVEMBER 17TH, 2014, 10:06 A.M., SAN DIEGO, CA 2 THE VIDEOGRAPHER: 3 the record is 10:06 a.m. 4 2014. 5 6 Good morning. The time on Today's date is November 17th, My name is Abel Sibrel with Peterson Reporting, Video & Litigation Services. 7 The court reporter today is 8 Bridget Mastrobattista of Peterson Reporting located at 9 530 B Street, Suite 350, San Diego, California 92101. 10 This begins the videotaped deposition of 11 Richard Lawrence testifying in the matter of San Diegans 12 for Open Government versus City of San Diego, et al., 13 Case No. 37-2012-00088065, taken at Peterson Reporting. 14 15 Will counsel please identify yourselves and state whom you represent. 16 17 MS. PANCAKE: San Diego Tourism Marketing District Corporation. 18 19 Jennifer Pancake on behalf of MR. BRIGGS: Cory Briggs on behalf of San Diegans For Open Government. 20 HON. PATE: And I'm Judge William Pate 21 appointed by the court as the discovery referee for this 22 deposition. 23 THE VIDEOGRAPHER: 24 The court reporter may now swear in the 25 Thank you. witness. Peterson Reporting, Video & Litigation Services 7 Richard Lawrence, 11-17-14 1 MR. BRIGGS: Just for the record, Judge Pate. 2 I don't think the court appointed you. 3 selected as one of three possible discovery referees by 4 the TMD Corp. 5 could do it, but Judge Wohlfeil I don't -- at least to 6 my knowledge hasn't actually appointed a discovery 7 referee in this matter. 8 9 There was a stipulation that said they HON. PATE: it came about. You were Just wanted you to -- Doesn't matter. I'm here however My impression was that it was that the 10 judge had ordered there be a discovery referee for this 11 deposition. 12 MS. PANCAKE: And for the record, I will make a 13 clarification. 14 discovery referees were mutually agreed upon by the 15 parties. 16 that the court signed on August 14th, 2014, ordering 17 that the depositions of the members and the deposition 18 of San Diegans For Open Government PMK be conducted with 19 the assistance of a discovery referees. 20 There was a stipulation whereby three That stipulation was then turned into an order MR. BRIGGS: There is just no general reference 21 I guess I should have said. 22 /// 23 /// 24 /// 25 /// Peterson Reporting, Video & Litigation Services 8 Richard Lawrence, 11-17-14 1 2 RICHARD LAWRENCE, having been first duly sworn, testified as follows: 3 4 5 EXAMINATION BY MS. PANCAKE: 6 Q 7 spell it. 8 A 9 Please state your name for the record and Richard Lawrence. R-I-C-H-A-R-D L-A-W-R-E-N-C-E. 10 Q 11 A Mr. Lawrence, what is your home address? 12 13 Q Mr. Lawrence, I'm Jennifer Pancake. We've 14 met previously. 15 Marketing District Corporation in the lawsuit that's 16 entitled San Diegans for Open Government versus City 17 of San Diego. 18 I represent San Diego Tourism Are you familiar with this lawsuit? 19 A Yes. 20 Q Mr. Lawrence, what is your occupation? 21 A I'm a Methodist clergyman. 22 Q Do you have an active ministry? 23 A I'm retired. 24 Q Can you describe your educational 25 background. Peterson Reporting, Video & Litigation Services 9 Richard Lawrence, 11-17-14 1 2 A I graduated from Patrick High School in Hanover, Massachusetts. 3 I got a Bachelor's degree from Albion College 4 in Albion, Michigan, with a Master's in English. 5 also had a minor in German should it ever come in handy, 6 which it never has to date. 7 And I And I then did graduate work at the University 8 of Chicago and got a Master of Divinity degree with a 9 specialty in social ethics. 10 Q Did you say Master's in Divinity? 11 A Yes. 12 Q Let me go over some of the rules of the 13 deposition that we're here today on. 14 15 Do you understand that you took an oath to tell the truth to -- 16 A Oh, yes. 17 Q -- to any of the questions that I ask or 18 any of the other attorneys may ask? 19 A Yes. 20 Q And that's the same oath that you would 21 take as if you were sitting in a courtroom 22 testifying on the stand? 23 A Yes. 24 Q Will you be able to tell the truth to the 25 questions that are asked of you here today? Peterson Reporting, Video & Litigation Services 10 Richard Lawrence, 11-17-14 1 A I certainly plan to. 2 Q And one issue that we've already come up 3 against is sometimes you may anticipate how I'm 4 going to ask my question, and you know the answer 5 and you speak immediately when I'm finished, or 6 sometimes you may cut me off. 7 It's important that as we go through the 8 proceedings today that we speak very clearly. 9 deposition is being videotaped. The There's also a court 10 reporter who's transcribing all of the written sounds 11 that are made here today. 12 13 The court reporter cannot transcribe two people talking at the same time. 14 A Of course. 15 Q So it's important that you let me finish my 16 question, and by the same token, I will let you 17 finish your answer. 18 Sometimes we may be getting back and forth, and 19 the flow may be going, and we're going through things 20 rather quickly, but if we start tripping over each 21 other, the court reporter will basically tell us to slow 22 down. 23 A I feel confidant I can do that. 24 Q Okay. 25 So will you be able to do that today? And the other thing that's important is you need to understand that you should not answer Peterson Reporting, Video & Litigation Services 11 Richard Lawrence, 11-17-14 1 one of my questions unless you understand it. 2 it's confusing, you need to let me know so that I 3 can ask a question that you understand. 4 If Your attorney may object to some of the 5 questions that I -- I ask, and he will interpose his 6 objection and may or may not instruct you to answer it 7 or not to answer it. 8 that if you answer a question, it is understood and it 9 is assumed that you understand the question that you're 10 11 12 13 14 But the rule in depositions is answering. A I understand that I should not respond unless I understand. Q Okay. And you will be able to do that today? 15 A Sure. 16 Q Okay. Also I've explained to you that 17 there's a court reporter here. 18 all of the questions, all of the answers, all of the 19 objections, all of the judge's rulings, if he ends 20 up making a ruling on an objection, and all of the 21 commentary that's going to go on here today. 22 She is transcribing She will prepare a transcript in a booklet form 23 and that will be sent to you for your review. You'll 24 have a certain amount of time to review that. You will 25 be asked to sign the transcript under penalty of perjury Peterson Reporting, Video & Litigation Services 12 Richard Lawrence, 11-17-14 1 that you have reviewed it. 2 You'll also be given the opportunity to make 3 changes to this transcript if you feel that a change 4 needs to be made. 5 There's spellings. 6 transcribed properly, and you can change anything from a 7 typo to, you know, giving a different answer. 8 9 Oftentimes there's terms of art. There's words that aren't So you have -- you have the opportunity to do that, but you need to understand that if you make any 10 changes that are substantive in nature, that I or any of 11 the other attorneys in this lawsuit will be able to 12 comment on the fact that you changed your testimony. 13 So do you understand that? 14 A I do understand. 15 Q Mr. Lawrence, are you on any medication 16 today that would cause you to be unable to tell the 17 truth in the answers that you're giving today? 18 A Not that I know of. 19 Q Okay. And are -- do you suffer from any 20 physical or other issues that would cause you not to 21 be able to the truth in answers to the questions? 22 A No. 23 Q Do you -- are you taking any medication 24 that would cause you to be unable to recall things 25 that may have happened in the past? Peterson Reporting, Video & Litigation Services 13 Richard Lawrence, 11-17-14 1 A No. 2 Q And do you suffer from any physical or 3 other issues that would prevent you from recalling 4 things that may have happened in the past in order 5 for you to be testifying about them? 6 A Only aging. 7 Q As you sit here right now, do you think 8 9 that that would be a problem for you? A Well, obviously at 78 years of age, I 10 notice that there are some things that I remember 11 better than others, but I don't think it's a 12 problem. 13 Q 14 Is there any reason that we would not be able to get your best testimony here today? 15 A None that I'm aware of. 16 Q Mr. Lawrence, have you ever given a 17 deposition before? 18 A Yes, I have. 19 Q On how many occasions? 20 A I don't know. I've been active in the 21 civil rights movement since 1965. And there have 22 been a number of occasions when I've appeared in 23 court because of demonstrations and other incidents 24 involving civil disobedience, and there have been 25 trials I would think maybe half a dozen times. Peterson Reporting, Video & Litigation Services 14 Richard Lawrence, 11-17-14 1 Q Okay. You've mentioned that you've 2 appeared in court and you've given testimony in 3 court. 4 your estimate for how many times you've appeared in 5 court previously? 6 7 A No. Is that That's my estimate for the number of times that I have given depositions. 8 9 Is -- you said a half dozen times. Q Okay. And you mentioned a good concept that we should -- we should go over. I and the 10 other attorneys that are asking questions here today 11 are entitled to get your -- your best testimony. 12 Sometimes you may not have an exact recollection 13 about something, but I'm entitled to get your best 14 estimate. 15 What I don't want to have happen is I don't 16 want to have you speculating about something. And so 17 it's important that you give me an estimate rather than 18 your speculation or your guess. 19 The difference between an estimate and a guess 20 is if I ask you how long this table is, you can look at 21 it. 22 and give me exactly how long it is, but based on your 23 knowledge of the facts that you see before you or that 24 you've experienced before, you can give me an estimate. 25 You can see it, and you may not have a tape measure If I ask you how long the table is in my dining Peterson Reporting, Video & Litigation Services 15 Richard Lawrence, 11-17-14 1 room at my home, you would have to guess, because you've 2 never seen it. 3 between what a guess is and what an estimate is? 4 A So do you understand the difference I don't think it's necessarily exactly 5 clear, but I get the idea of what the difference is 6 and believe I can consistently apply estimate when 7 you request it. 8 9 MS. PANCAKE: And for the record, Ms. Brock just came. 10 MS. BROCK: 11 MS. PANCAKE: 12 MS. BROCK: 13 appearance? 14 City of San Diego. 15 BY MS. PANCAKE: 16 Okay. Q Hi. Do you want to just say -- Do you want me to state my Carmen Brock, Deputy City Attorney for the Mr. Lawrence, you testified that you have 17 given, you believe, half a dozen depositions in the 18 past. 19 that you gave? 20 21 22 23 24 25 A How long ago was the most recent depositions I would think maybe it was three years ago. I'm -- I'm not sure. Q In what capacity did you give that deposition? A As a member of CREED, Citizens for Responsible Equitable Environmental Development. Peterson Reporting, Video & Litigation Services 16 Richard Lawrence, 11-17-14 1 2 Q Have you ever given any depositions in the past on behalf of SDOG? 3 A Not that I recall. 4 Q Have you ever given any depositions in the 5 past on an SDOG matter? 6 A Not that I recall. 7 Q Of the six depositions that you estimated 8 you've had experience with, how many of those have 9 been with respect to CREED? 10 A One. 11 Q And can you tell me the nature of the other 12 13 depositions that you've given. A They all related to trials previously 14 around civil disobedience, demonstrations in 15 Chicago. 16 depositions were all in Chicago around civil rights 17 issues. 18 19 Q I think in every case, yes, the Other the CREED one and the one that you're here today on? 20 A Uh-huh. 21 Q And you testified earlier that you've 22 testified in court in the past. 23 A Yes. 24 Q On how many occasions has that happened? 25 A I think there's only been two actual Peterson Reporting, Video & Litigation Services 17 Richard Lawrence, 11-17-14 1 trials. 2 Q What was the nature of those trials? 3 A One had to do with the shooting of a police 4 officer in Chicago. 5 situation in Ferguson, Missouri. 6 resident was shot by a police officer, and there was 7 no plan for any kind of hearing with regard to the 8 officer's engagement in the shooting. 9 Reminds me greatly of the An unarmed black So there were a number of demonstrations. I 10 appeared at the police officer's house and was arrested 11 and appeared in court on that matter. 12 Subsequently, I became active in Operation 13 Bread Basket in Chicago. 14 of National Foods, and we went to their offices, 15 corporate offices, tried to get a meeting with the 16 president about a covenant that we wanted to reach with 17 the company around increasing the number of minority 18 employees in the store -- in their stores. 19 We were carrying out a boycott And we were asked to leave. We decided we 20 weren't leaving. 21 was a trial which lasted a very short time. 22 were dropped. 23 24 25 Q I was subsequently arrested, and there The charges When did the two trials take place that you testified about? A In the '60s and '70s. I don't remember the Peterson Reporting, Video & Litigation Services 18 Richard Lawrence, 11-17-14 1 2 3 specific dates. Q Mr. Lawrence, have you ever filed any lawsuits in your personal capacity? 4 A No. 5 Q Are you represented by counsel here today? 6 A Yes. 7 Q Who is your counsel? 8 A Cory Briggs. 9 Q When did you retain Mr. Briggs or his law 10 11 corporation to represent you at this deposition? A I don't know the answer to that. As part 12 of the organization's existence, he serves as our 13 attorney and thereby represents us in occasions such 14 as this. 15 Q So other than your involvement in the 16 organization SDOG, do you have any recollection of 17 specifically retaining Mr. Briggs to represent you 18 in the deposition that is occurring here today? 19 A No, I don't. 20 Q Mr. Lawrence, what did you do to prepare 21 22 for today's deposition? A I read through the subpoena and checked to 23 see if there were any of the materials that were 24 requested that I had in my possession. 25 I tried to find some emails on the subject of Peterson Reporting, Video & Litigation Services 19 Richard Lawrence, 11-17-14 1 the Tourism Marketing District that I had sent to the 2 newspaper as letters to the editor as the request for 3 materials to and from the City. 4 I did not know if letters to the editor would 5 be considered communication with the City. 6 those were incorporated in comments I made to the City 7 Council I made on this subject some time ago. 8 could not find any. 9 10 11 Q And some of And I What is your best recollection as to when these emails were sent? A The Tourism Marketing District issue came 12 to my attention when it was first conceived because 13 the Affordable Housing Coalition, of which I'm a 14 co-chair, had been working with the City Council 15 attempting to get transient occupancy tax designated 16 for affordable housing, as some piece of that -- 17 funds from that source had been used for that 18 purpose previously and had been taken away. 19 And in the opinion of the Affordable Housing 20 Coalition, it's tourism that helps to create the demand 21 for affordable housing by creating low-paying jobs that 22 require workers in the industry to have subsidies in 23 order to be able to afford to rent or buy a home in the 24 city. 25 So if you know when the first sort of Peterson Reporting, Video & Litigation Services 20 Richard Lawrence, 11-17-14 1 discussions in the City about the Tourism Marketing 2 District came -- I don't know the date, but it was in 3 the earliest days of discussions about the TMD. 4 5 6 Q Do you have an estimate as to when that was from a date perspective? A I'm terrible with dates. At this point it 7 would be really tough, but I would assume, if I 8 remember anywhere near -- I've only been here 9 15 years, and I think TMD came up maybe -- I'd 10 11 estimate maybe eight years ago? Q So the emails that you were trying to find 12 with respect to your letters to the editor and the 13 emails that contained your comments that you made at 14 City Council meetings, it's your best estimate that 15 those would have been dated eight years ago? 16 A It's my best estimate, yes. 17 Q Other than reading through the subpoena and 18 attempting to locate the materials that were 19 requested, did you do anything else to prepare for 20 today's deposition? 21 A No. 22 Q When did your review of the subpoena and 23 your attempt to locate emails occur? 24 A Within the last couple weeks. 25 Q Do you have a better estimate than that? Peterson Reporting, Video & Litigation Services 21 Richard Lawrence, 11-17-14 1 A No. 2 Q Other than your review within the last 3 couple of weeks, had you previously undertaken any 4 preparation or any review to -- for purposes of 5 appearing at a deposition which may have been 6 scheduled earlier in time than today? 7 A No, I hadn't. 8 Q Why not? 9 A Because I did not think that the deposition 10 11 would actually ever occur. Q 12 13 And why is that? MR. BRIGGS: Objection. Attorney-client privilege. 14 You can answer if you can. 15 THE WITNESS: 16 17 18 On the advice of my attorney. BY MS. PANCAKE: Q Mr. Lawrence, have you ever been convicted of a felony? 19 A No. 20 Q Have you been convicted of any crimes of 21 moral turpitude? 22 A No. 23 Q Have you ever been convicted of a crime 24 25 that relates to truthfulness or veracity? A No. Peterson Reporting, Video & Litigation Services 22 Richard Lawrence, 11-17-14 1 2 3 Q Do you hold any licenses other than a California -- or a driver's license? A Hmm. The Methodists issue a thing called 4 the local preacher's license. 5 preacher's license, but I don't know of any other 6 license that I have. 7 Q So I do have a local Mr. Lawrence, I'm going to give you a 8 document that we've marked as Exhibit -- that I have 9 marked as Exhibit 1 to today's deposition. 10 (Exhibit 1 was marked.) 11 12 13 BY MS. PANCAKE: Q Mr. Lawrence, can you take a look at Exhibit 1 -- 14 A Uh-huh. 15 Q -- and tell me, is this the subpoena that 16 you reviewed. 17 document that you reviewed? 18 A 19 20 Let me rephrase that. Yeah, I recognize it now. MR. BRIGGS: Is this the Yep, I think so. Are you planning to give him his witness fees right now? 21 MS. PANCAKE: In a minute. I'm going through 22 my questions to make sure that I cover everything. 23 BY MS. PANCAKE: 24 25 Q Was Exhibit 1 -- was the subpoena that's attached to Exhibit 1 served on you personally? Peterson Reporting, Video & Litigation Services 23 Richard Lawrence, 11-17-14 1 A Yes. 2 Q Mr. Lawrence, I'm giving you a check in the 3 amount of $38.40 -- excuse me, $37.40, which 4 constitutes the witness fees that are due for your 5 testimony here today. 6 under California law is $35, plus 20 cents per mile 7 for your trip to and from the place of the 8 deposition. 9 10 11 The witness fee statutorily We calculated that to be $37.40. Are you satisfied that that is the correct calculation for your mileage? A In that I took the trolley and it's a $1.25 12 each way, it may be slightly off by 10 cents, I 13 think, but otherwise I'm satisfied. 14 Q So we okay to proceed today? 15 A Sure. 16 Q All right. 17 18 19 20 21 Thank you. What did you do when you received the deposition subpoena? A It was dinnertime, so I went back to the kitchen and continued cooking. Q Okay. Did you take any action as a result 22 of receiving the deposition subpoena with respect to 23 the deposition? 24 25 A Is the question still immediately upon receiving the deposition? Peterson Reporting, Video & Litigation Services 24 Richard Lawrence, 11-17-14 1 Q Well, I'm assuming that you finished 2 dinner. Let's talk about after that. What did you 3 do with respect to the deposition after receiving 4 the deposition subpoena? 5 A I'm sorry. I don't understand. 6 Q Did you talk to anybody about your receipt 7 of the deposition subpoena which is attached as 8 Exhibit 1 to this deposition? 9 A Yes. 10 Q When did that happen? 11 A The next day. 12 Q Who did you speak to? 13 A At that moment I spoke to Allison -- I 14 I called Briggs Law Corporation. forgot Allison's last name. 15 MR. BRIGGS: Into the camera. 16 know, tell her you don't know. 17 THE WITNESS: If you don't I don't know Allison's last name, 18 but I left a message that I wanted to talk to Cory and 19 he called me back later in the day. 20 BY MS. PANCAKE: 21 Q Other than speaking to Allison and Cory, 22 did you speak to anybody else about the deposition 23 subpoena? 24 A No. 25 Q Did you bring any documents with you today? Peterson Reporting, Video & Litigation Services 25 Richard Lawrence, 11-17-14 1 A No, I did not. 2 Q And why not? 3 A Because I didn't find any that fit the 4 5 request that I had understood in the subpoena. Q And other than going through your emails to 6 locate potentially responsive documents, did you 7 search in any other locations for documents? 8 9 A No. I -- I obviously spent some time thinking about where documents might be and having 10 come up with a blank, I didn't just go scurrying 11 through the house seeing what I could find. 12 13 Q So you do not maintain any documents at your home related to SDOG? 14 A No, I don't. 15 Q And this leads me to another clarification 16 that I would like to make. 17 in this case are quite long. 18 San Diego Tourism Marketing District Corporation, 19 and I refer to that as the TMD. 20 acronym TMD, will you understand that I'm talking 21 about the San Diego Tourism Marketing District 22 Corporation? 23 24 25 A The names of the parties My client is the And so if I use the I will understand. MR. BRIGGS: I think up to this point we've said that the TMD is the tax and TMD Corp is your Peterson Reporting, Video & Litigation Services 26 Richard Lawrence, 11-17-14 1 client. 2 depositions, you've asked about the TMD, and you were 3 not asking about your client. 4 money. 5 Because knowing your other questions from other You were asking about the So I just want to make sure we're using -- just 6 so you know, I think you're proposing something that is 7 different from what we've done in the past. 8 your depo. 9 BY MS. PANCAKE: 10 Q But it's Do you understand the difference between 11 the Tourism Marketing District and the Tourism 12 Marketing District Corporation? 13 A No, I don't. 14 Q Okay. Well, I will try to make sure that 15 when I'm talking about my client, which is the 16 entity, that you understand that I often refer to my 17 client as the TMD. 18 By the same token, plaintiffs in this lawsuit 19 go by the name San Diegans For Open Government, which is 20 also a long -- relatively long title, and so I refer to 21 that entity as SDOG as an acronym. 22 "SDOG," will you understand that I'm referring to the 23 San Diegans For Open Government? 24 A I will. 25 Q Okay. If I use the term And I think your testimony was that Peterson Reporting, Video & Litigation Services 27 Richard Lawrence, 11-17-14 1 you do not personally keep any records that relate 2 to SDOG; is that accurate? 3 A That's accurate. 4 Q You said that you were thinking about where 5 documents would be. 6 documents that are responsive to the requests that 7 are attached to the deposition subpoena, where would 8 they be located? 9 A Where do you believe that Because I'm engaged in a number of 10 organizations in -- in San Diego, I keep files from 11 those organizations, and I thought, obviously, about 12 whether there would be a file or material about SDOG 13 in the file cabinets that I have around my desk. 14 Q Do you keep a file on SDOG? 15 A No, I don't. 16 Q Why not? 17 A The way we operate, our business is really 18 done in the meeting itself at which our attorney is 19 always present, and our communications are really 20 fairly efficient, and I don't find a need for a 21 file. 22 Q You testified that you're engaged in a 23 number of other organizations and that you keep 24 files for those organizations. 25 A That's true. Peterson Reporting, Video & Litigation Services 28 Richard Lawrence, 11-17-14 1 2 3 Q What other organizations are you talking about? A The Center on Policy Initiatives. The 4 Interfaith Committee for Worker Justice. Community 5 Coalition for Responsible Development. 6 Affordable Housing Coalition of San Diego County. The 7 Q Are there any others? 8 A Not currently that I'm active in. 9 Q You mentioned CREED. 10 11 Is CREED an organization that you're involved in? A Yes. But the question was whether I had a 12 file on the organization, and I don't have a file on 13 CREED either. 14 Q Okay. I apologize. I thought my question 15 was just to what were the organizations that you 16 were thinking of when you were -- you had commented 17 that you're engaged in a number of other 18 organizations. 19 But let me follow-up on that. So is it -- is it accurate to say that you do 20 keep files for the Center on Policy Initiatives, 21 Interfaith Committee for Justice, committee -- or 22 Community Coalition for Responsible Development, and the 23 Affordable Housing Coalition of San Diego County? 24 A Yes. 25 Q And there are other -- are there other Peterson Reporting, Video & Litigation Services 29 Richard Lawrence, 11-17-14 1 organizations that you're involved with that you do 2 not keep files? 3 A Yes. 4 Q What are they? 5 MR. BRIGGS: Hang on just one sec. I'm not so 6 sure what his private associational activities have to 7 do with the TMD. 8 private information that's protected by his First 9 Amendment rights, not to mention his privacy rights 10 And I think you're getting into under the California constitution. 11 So I'm going to remind the witness that I don't 12 think he has to answer any of your questions about his 13 organizational activities other than with SDOG. 14 If you want to answer, that's -- I will leave 15 that to you. 16 BY MS. PANCAKE: 17 Q But I'm going to state that objection. You can answer. 18 MR. BRIGGS: 19 THE WITNESS: So repeat the question. 20 MS. PANCAKE: Ms. Reporter, can you repeat the 21 24 25 It's up to you. question, please. 22 23 Or not. (The pending question was read.) BY MS. PANCAKE: Q And to refresh your recollection, these are the organizations that you belong to that you do not Peterson Reporting, Video & Litigation Services 30 Richard Lawrence, 11-17-14 1 2 keep records for. A There -- there are a number of 3 organizations that I'm no longer as active in as I 4 was before. 5 for instance, a Community Budget Alliance. 6 the only one at the moment I can think of that I 7 don't currently have a file in -- an active file on. 8 9 Q There was, for instance -- there is, That's So it's your testimony that other than SDOG and CREED and the Community Budget Alliance group 10 that you just testified about, you're not involved 11 in any other organizations? 12 A No, that is not my testimony. I don't know 13 what other organizations I'm involved in or was 14 involved in that I have files on in my -- at my 15 home. 16 Although I just thought of one. 17 Overcoming Boundaries. 18 San Diego Organizing Project. Justice Here's a second one. It's the 19 Q Are you able to recall any more? 20 A That is it for now. 21 Q And are these -- all the organizations that 22 you testified about, are these organizations that 23 you are currently involved in? 24 A Yes. 25 Q So take a look at the document requests, Peterson Reporting, Video & Litigation Services 31 Richard Lawrence, 11-17-14 1 Mr. Lawrence, and I understand that your testimony 2 is that you do not currently have any files or you 3 do not currently maintain any documents that are 4 responsive to this request. 5 A Correct. 6 Q But my question is, do you know whether any 7 documents that are responsive exist? 8 A I don't know if any of these exist. 9 Q Have you ever seen any documents that are 10 responsive to any of the requests that are included 11 in the deposition subpoena? 12 A Not -- not that I know of. 13 Q Have you ever discussed any of the 14 documents that are listed as requests in the 15 subpoenas? 16 MR. BRIGGS: Hang on. I'm going to object on 17 attorney-client privilege grounds. 18 someone other than his attorney or do you just mean with 19 anybody in the world? 20 MS. PANCAKE: 21 MR. BRIGGS: 22 I mean with anybody in the world. In that case I'm going to repeat the objection and instruct the witness not to answer. 23 MS. PANCAKE: 24 HON. PATE: 25 Do you mean with Your Honor? I think it's proper for him to exclude any discussions with his attorney. If he can Peterson Reporting, Video & Litigation Services 32 Richard Lawrence, 11-17-14 1 answer the question without attorney discussions at the 2 moment, then I think he should do so. 3 MR. BRIGGS: So if you can answer the question 4 without revealing any discussions between you and my 5 office, you may. 6 going to answer the question. 7 8 9 If you can't, just tell her you're not THE WITNESS: I'm not going to answer. BY MS. PANCAKE: Q Have you ever discussed any of the 10 documents that are requested with any members of 11 SDOG? 12 A 13 14 I would have to go through all of these again just to be sure, but to my knowledge, no. Q Have you ever discussed the documents that 15 are requested, any of the documents that are 16 requested, with any of the corporate officers of 17 SDOG? 18 A No. 19 Q After reviewing the depo -- the document 20 list and thinking about whether you've had 21 discussions with -- any of these documents with 22 anyone other than your attorneys, does anything 23 refresh your recollection as to whether or not any 24 of these categories of the documents actually do 25 exist? Peterson Reporting, Video & Litigation Services 33 Richard Lawrence, 11-17-14 1 A No. 2 Q Is it your testimony that you still do not 3 know whether the documents requested exist or not? 4 A That is correct. 5 Q Have you reviewed any of the court 6 documents that have been filed in this case? 7 A I don't think so. 8 Q You seem a little hesitant about that, is 9 10 there something that you may have reviewed? A I'm trying to think of whether there was 11 anything that I had reviewed in this case. 12 believe I did. 13 14 Q I don't Have you ever reviewed any of the discovery documents that have been generated in this case? 15 A I'm not sure what a discovery document is. 16 Q Have you ever reviewed any sets of written 17 questions that either side may have prepared? 18 A No. 19 Q Have you ever signed a verification? 20 A Yes. 21 Q Or, I'm sorry, let me -- 22 A I'm sorry. 23 Q No. 24 25 That's okay. I will go on. Have you ever signed a verification with respect to any documents that were prepared for this Peterson Reporting, Video & Litigation Services 34 Richard Lawrence, 11-17-14 1 case? 2 A I did sign a verification. 3 Q And what was that verification for? 4 A The specifics of the document I can't 5 6 7 8 9 10 11 recall. Q How do you know that you signed a verification for this case? A One of the documents that I see fairly frequently is -- are verifications. So I tend to remember those. Q And what were the circumstances that were 12 occurring that caused you to sign a verification for 13 this case? 14 A My attorney requested it. 15 Q But you have no recollection as to what it 16 was for? 17 A In the broadest sense, I knew what it was 18 for. 19 Marketing District and that we wanted to pursue 20 legal action. 21 Q We had some concerns about the Tourism So let me ask you: What is your 22 understanding of the term a verification? 23 that mean to you? 24 25 A What does That the issues raised in the document I'm signing are a true representation of my position. Peterson Reporting, Video & Litigation Services 35 Richard Lawrence, 11-17-14 1 Q When did this verification get signed? 2 A I don't know. 3 Q Was it sometime this fall? 4 A I really don't know. 5 Q When you signed the verification, did you 6 review a document in connection with your signature 7 of the verification? 8 A Not that I recall. 9 Q Do you recall whether you just signed a 10 blank verification that could be used at some time 11 in the future? 12 13 14 15 A No. It wasn't blank. There was content in the document that I signed. Q But you have no recollection as to what that is at this point? 16 A I do not. 17 Q Is there anything that could refresh your 18 19 20 21 22 recollection? A You could show me the verification that I signed, that would do it. Q Okay. Anything else besides finding that particular document? 23 A I don't think so. 24 Q Have you ever authorized anybody to sign 25 documents for you -- Peterson Reporting, Video & Litigation Services 36 Richard Lawrence, 11-17-14 1 A Yes, I have. 2 Q -- in your capacity as a member or a member 3 of the board of directors of SDOG? 4 A Yes, I have. 5 Q And on what occasions did that occur, if 6 that happened more than once? 7 A I do not remember any specific occasions. 8 Q But you know that you have authorized 9 others to sign? 10 A Yes, I do. 11 Q Whom have you authorized to sign for you? 12 MR. BRIGGS: I'm going to object. If you want 13 to give answers other than answers about your attorneys 14 or people in the attorney's office, that's fine, but her 15 question gives you the substance of the communication 16 and any communications with the attorneys are 17 confidential. 18 So to the extent your answer requires you to 19 disclose attorney-client communications, I'm instructing 20 you not to answer. 21 non-attorneys, you're free to answer. 22 23 24 25 If there are any communications with THE WITNESS: I cannot answer. BY MS. PANCAKE: Q So let me -- let me back up a little bit. Have you ever authorized anyone other than Peterson Reporting, Video & Litigation Services 37 Richard Lawrence, 11-17-14 1 someone who may be in your attorney's office to sign 2 documents for you with respect to SDOG matters? 3 A No, I have not. 4 Q On how many occasions have you authorized 5 others to sign documents for you? 6 MR. BRIGGS: 7 MS. PANCAKE: 8 MR. BRIGGS: 9 same instruction. Others other than attorneys or -Anybody. Well, then, same objection and We're not going to disclose to you 10 any sort of communications, numbers of communications 11 that involve the witness and his lawyers. 12 MS. PANCAKE: Well, Cory, if this was something 13 that would be a privileged communication, I'm entitled 14 to get a privilege log of the communications about which 15 you claim that there's privilege. 16 privilege log, you have the date that this occurs, and I 17 think I'm entitled to that. 18 19 MR. BRIGGS: MS. PANCAKE: 21 MR. BRIGGS: 22 MS. PANCAKE: 24 25 Well, you just ask the number of occasions. 20 23 And so typically in a Okay. That's why I -And I think I'm entitled to that as well under the same rationale. MR. BRIGGS: We're not going to give you any answers that reveal attorney-client communications, the Peterson Reporting, Video & Litigation Services 38 Richard Lawrence, 11-17-14 1 content of them, the number of them. 2 between the attorney and the client is going to remain 3 confidential. 4 answer in any way that would reveal an attorney-client 5 communication. 6 Anything that is And I'm instructing the witness not to MS. PANCAKE: Your Honor, can we get a ruling 7 on it? I understand that we're not entitled to the 8 content of an attorney-client communication, but I think 9 in the context of asserting the privilege, if asked, the 10 law requires a privilege log which typically has the 11 date of whenever the communications are if any such 12 exist. 13 dates of them I think are fair game. 14 And so the number of communications and the MR. BRIGGS: Actually the law doesn't require a 15 privilege log. It is customary in certain 16 circumstances. You subpoenaed Mr. Lawrence as a 17 third-party witness. 18 Regardless of what you might get out of a party 19 and regardless of whether a privilege log is 20 appropriate, a privilege log is a document in writing. 21 It's not answers from the witness. 22 The witness is not going to answer your 23 questions about the content or the frequency of 24 communications with his counsel. 25 HON. PATE: The objection will be sustained. Peterson Reporting, Video & Litigation Services 39 Richard Lawrence, 11-17-14 1 The -- if he has documents that are responsive to your 2 request and some of those are attorney-client privilege, 3 then a privilege log may be one way to approach the 4 issue. 5 But he's indicated so far he doesn't have any 6 documents at all, and thus, there are no documents, then 7 there would be no basis for a privilege log. 8 9 So if we're just dealing with verbal communications, I've never -- I've never seen a 10 privilege log for verbal communications. 11 objection would be sustained. 12 13 14 MS. PANCAKE: So the Thank you. BY MS. PANCAKE: Q Mr. Lawrence, have you authorized anyone to 15 sign documents for you and has your authorization 16 been in writing at any time? 17 MR. BRIGGS: I'm going to object, again. 18 You're asking about anyone. 19 attorneys or anyone in my office or any other attorneys 20 for that matter, I'm going to instruct the witness not 21 to answer on attorney-client privilege grounds. 22 MS. PANCAKE: To the extent that includes Well, Your Honor, I'm trying to 23 determine if there's any documents that exist that 24 relate to this, which I understand your prior ruling on 25 whether or not his authorization may have been verbal, Peterson Reporting, Video & Litigation Services 40 Richard Lawrence, 11-17-14 1 but -- 2 HON. PATE: The issue -- 3 MS. PANCAKE: 4 HON. PATE: -- the existence. -- whether or not he has the 5 documents. And he says he doesn't have any documents. 6 If he's a party, then he has got obligations to go 7 search so that you can ask him about whether or not he 8 asked his attorneys to provide any documents to him, 9 that if he made any requests to get documents that go to 10 verifications, but seems to me if there was a 11 verification, it would be in the court file somewhere or 12 filed someplace. 13 MR. BRIGGS: Thank you. This is a fishing 14 expedition. 15 served it in this case, you would have it and you would 16 be showing it to him to refresh his recollection. 17 If he signed a verification and filed it or MS. PANCAKE: So, Your Honor, did you rule on 18 my -- did you rule on Mr. Briggs's objection to my 19 question about whether any documents exist regarding 20 Mr. Lawrence's authorization for others to sign 21 documents for him? 22 MR. BRIGGS: You're supplying the content of 23 the communication, and if you're going to include the 24 content in a question that includes attorneys and 25 attorneys' staff, it is objectionable. Peterson Reporting, Video & Litigation Services 41 Richard Lawrence, 11-17-14 1 HON. PATE: 2 MS. PANCAKE: 3 4 5 The objection is sustained. Thank you, Your Honor. BY MS. PANCAKE: Q Mr. Lawrence, do you recall being subpoenaed for a deposition last summer? 6 A No. 7 Q I'm going to show you a document that I've 8 marked as Exhibit 2. 9 HON. PATE: 10 11 12 I got it. (Exhibit 2 was marked.) BY MS. PANCAKE: Q And, Mr. Lawrence, let me represent to you 13 this is document is a notice of deposition that was 14 served by my office last June. 15 the name of -- your name does not appear on this, 16 because this was at a time when your name was secret 17 pursuant to a protective order, which we have now 18 gotten an order from the judge that we can refer to 19 you by your actual identity. 20 21 If you will notice, So do you recall being served with the subpoena which is attached to Exhibit 2? 22 MR. BRIGGS: No. 1, there is no court order 23 yet. 24 representation about what this document is. 25 No. 2, we are not going to accept your As you've been told previously, you hired a Peterson Reporting, Video & Litigation Services 42 Richard Lawrence, 11-17-14 1 process server who was largely incompetent who falsified 2 proofs of service, who left documents on people's cars, 3 who served the wrong packages on witnesses. 4 to have redacted the name and then just accept -- expect 5 us to accept that representation is a mistaken 6 representation and is not going to be accepted. 7 MS. PANCAKE: Okay. And for you I appreciate your 8 grandstanding right now, but what you have just 9 described is, in fact, not true. 10 11 BY MS. PANCAKE: Q And so I will ask the witness, 12 Mr. Lawrence, do you recall being served with a 13 subpoena last June? 14 A I do. 15 Q And -- 16 A However, this document that I got did not 17 have my name on it, and it was about this thick 18 (indicating). 19 which you're referring or not. So I don't know if that's the one to 20 Q Do you still have that document? 21 A I do not. 22 Q What did you do with that document? 23 A I put it in my recycle bin. 24 Q Why? 25 A Because it didn't refer to me. Peterson Reporting, Video & Litigation Services 43 Richard Lawrence, 11-17-14 1 Q Who did it refer to? 2 A Pedro Quiroz. 3 Q Did you -- did you call Mr. Quiroz? 4 A I did not. 5 Q Why not? 6 A Because I didn't -- I did not know I had 7 any responsibility to do any such thing. 8 Q Do you know Mr. Quiroz? 9 A Yes, I do. 10 Q Did you do anything other than put the 11 package of information into the recycle after you 12 got it? 13 A Not immediately. I later talked to my 14 attorney. 15 Q 16 attorney? 17 A Several days after the document arrived. 18 Q And did you make any decisions about how When was that that you talked to your 19 you were going to respond to the subpoena that was 20 served on you in June? 21 MR. BRIGGS: Objection. He just told you he 22 wasn't served with a subpoena in June. 23 was served with something else that wasn't even directed 24 at him. 25 He told you he So you're mischaracterizing what he said. Furthermore, when you said did you make any Peterson Reporting, Video & Litigation Services 44 Richard Lawrence, 11-17-14 1 decision, that is ambiguous. 2 the witness and his attorney, I'm going to object on 3 attorney-client privilege grounds. 4 5 6 If you mean you, plural, If you just mean you singular to the witness, that part of the question is okay. MS. PANCAKE: Well, Mr. Briggs, I know what 7 decisions you made as a result of the service of these 8 subpoenas because we have tons of emails going back and 9 forth, and we had a motion, and so I understand what 10 your decisions were with respect to the service of that 11 subpoena. 12 My question, though, asked the witness what did 13 you decide after being served with that subpoena that 14 you testified came to you. 15 MR. BRIGGS: 16 MS. PANCAKE: So you is singular. Yes. I'm not sure why it would 17 be any other way, and I don't think that it's proper for 18 you to instruct the witness by making speaking 19 objections. 20 MR. BRIGGS: 21 MS. PANCAKE: There is no -Your Honor, can we get a 22 statement from you as to that there should not be 23 speaking objections made in an effort to coach the 24 witness before he has a chance to answer the question? 25 MR. BRIGGS: There's no coaching going on here. Peterson Reporting, Video & Litigation Services 45 Richard Lawrence, 11-17-14 1 The answer to you, to the question preceding what 2 decisions did you make, the answer was I spoke to my 3 lawyer. 4 make? You immediately then said what decision did you 5 It's natural for what one to think, especially 6 given our course of dealings in these depositions where 7 you repeatedly ask for information that is privileged, 8 it was entirely proper for me to say that the term "you" 9 is ambiguous because you might have meant it to include 10 the witness and the attorney and I just wanted that 11 clarified, "you" subsequently clarified. 12 HON. PATE: Let me just interject a comment and 13 an observation and maybe a ruling. 14 counsel, Mr. Briggs' comments, were coaching the 15 witness. 16 and I didn't see that any of the discussion really moves 17 this deposition forward. 18 I didn't think I think they were just a discussion with you I mean I'm here just to call balls and strikes. 19 But it could be a much more efficient deposition if 20 editorial comments are kept to a minimum. 21 The question was not objectionable. It didn't 22 seem to be ambiguous. 23 it, he seems very competent to state that he doesn't 24 understand it. 25 If the witness didn't understand So I would overrule the objection to it and Peterson Reporting, Video & Litigation Services 46 Richard Lawrence, 11-17-14 1 direct the witness to answer the question as phrased. 2 3 4 THE WITNESS: And the question was? BY MS. PANCAKE: Q What decision did you make, if any, with 5 respect to the subpoena that was served on you in 6 June? 7 A I think I already mention that I'd made one 8 decision, which was since it wasn't addressed to me 9 that it should go into my recycle bin, and then 10 secondly, I subsequently called my attorney. 11 are the decisions that I made. 12 BY MS. PANCAKE: Those 13 Q 14 SDOG? 15 A Yes. 16 Q When did you become a member of SDOG? 17 A Oh, all I know it was several years ago 18 19 20 Mr. Lawrence, are you currently a member of when Ian Trowbridge was still alive. Q And could you give me an estimate as to what you mean by several years ago? 21 A Six or seven years ago would be my 22 estimate. 23 Q Who is Ian Trowbridge? 24 A Who is he? 25 Q Yes. I almost said guess. It is an estimate. Peterson Reporting, Video & Litigation Services 47 Richard Lawrence, 11-17-14 1 A He is an independent activist in San Diego 2 who has subsequently died who was very concerned 3 about issues of open government and transparency. 4 Q Did you know him personally? 5 A Yes, I did. 6 Q When did you meet him? 7 A We met a number of years ago. Actually I 8 first heard him at a presentation before the city 9 council where both of us appeared fairly frequently. 10 11 Q What was your relationship with Mr. Trowbridge prior to his death? 12 A We were friends and colleagues. 13 Q And when you say "colleagues," what do you 14 15 mean by that? A Well, we were both members of San Diegans 16 for Open Government. 17 committed to publicly trying to address the issues 18 around open government. 19 guess, of our relationship. 20 Q We were both very, very That's the substance, I Other than your involvement with 21 Mr. Trowbridge with respect to SDOG, were you 22 involved with any other activist issues where 23 Mr. Trowbridge was also involved? 24 A Not directly that I recall. 25 Q How about indirectly? Peterson Reporting, Video & Litigation Services 48 Richard Lawrence, 11-17-14 1 A Well, Mr. Trowbridge was also outspoken 2 around issues of affordable housing, and so on those 3 issues, we shared a common commitment in an attempt 4 to address what is characterized in Chicago as a 5 severe shortage of affordable housing constituting a 6 state of emergency. 7 Q And is there a particular organization that 8 you were both involved in that dealt with those 9 issues? 10 A Well, he was not a member of the Affordable 11 Housing Coalition which was the organization that I 12 was co-chair of, but he was a vocal supporter of it 13 on occasion. 14 15 16 17 18 Q What about CREED? Did you share any work on behalf of that organization with Mr. Trowbridge? A I believe Ian attended a number of CREED meetings as well. Q Now, is CREED just one organization or are 19 there multiple CREED organizations that you're 20 involved in? 21 A Well, there is technically CREED, and then 22 there is CREED 2011, '12, '13 -- I forget what the 23 year is that we reconstituted the organization. 24 it's the same people. 25 Q But And when you say "it's the same people," do Peterson Reporting, Video & Litigation Services 49 Richard Lawrence, 11-17-14 1 you mean it's the same people that are part of SDOG 2 are also a part of CREED? 3 A No. I mean there's the same people in 4 CREED who were -- who were reconstituted as CREED 5 2012, '13, whatever year it was that we 6 reconstituted the organization. 7 8 Q If I mention an organization that's called CREED 21, does that refresh your recollection -- 9 A Yes, it does. 10 Q -- as to the new name of the CREED 11 organization -- 12 A It does. 13 Q -- that you testified about as being 14 reconstituted? 15 A Yes. 16 Q Okay. Thank you. And just what happened right now 17 with me asking and you answering sort of as we're 18 talking -- 19 A That's difficult. 20 Q -- the court reporter is not smiling right 21 22 now. Actually she is. Mr. Lawrence, you testified that you've been 23 involved with SDOG for six or seven years was your best 24 estimate. 25 When you first became involved with this Peterson Reporting, Video & Litigation Services 50 Richard Lawrence, 11-17-14 1 organization, was it called San Diegans for Open 2 Government or was it called All People's Breakfast 3 Organizing Committee? 4 5 6 7 A I've only known the organization as San Diegans For Open Government. Q Have you ever seen any documents related to All People's Breakfast Organizing Committee? 8 A Yes. 9 Q Describe for me what you've seen 10 11 previously. A I don't know what to call it. I think it 12 was a copy of the original Articles of Incorporation 13 for All People's Organizing Committee. 14 Q Okay. And what was the circumstances that 15 surrounded your familiarity with that particular 16 document? 17 A If I'm not mistaken, this was introduced at 18 a meeting of CREED when a question was raised I 19 think by the Secretary of State's office about our 20 organization. 21 22 Q And you testified that this occurred at a meeting of CREED? 23 A Yes. 24 Q And you said that there was a question by 25 the Secretary of State about "our organization." Peterson Reporting, Video & Litigation Services 51 Richard Lawrence, 11-17-14 1 Are you talking about SDOG being our organization -- 2 A No, I'm talking -- 3 Q -- or CREED? 4 A I'm talking about CREED. 5 Q I'm going to show you a document that I've 6 marked as Exhibit 3. 7 8 9 10 11 12 13 14 15 (Exhibit 3 was marked.) BY MS. PANCAKE: Q you: A Mr. Lawrence, is Exhibit 3 -- let me ask Do you recognize Exhibit 3? I believe that's the document that I saw, yes. Q And have you ever seen this document in connection with any meetings of SDOG? A Excuse me. I just don't know. I 16 participated in both SDOG and CREED, as you know, 17 and I thought it was raised at a CREED meeting. 18 I may be mistaken. 19 Q And Are the meetings that happened with SDOG, 20 did they happen at the same time as the CREED 21 meetings? 22 A They do on occasion, yes. 23 Q And so if you're at a meeting, how do you 24 know if you're at a CREED meeting or if you're as an 25 SDOG meeting? Peterson Reporting, Video & Litigation Services 52 Richard Lawrence, 11-17-14 1 2 3 4 A Because the issue on the table clearly defines which organization is currently at work. Q So does the -- describe to me how the meetings occur. 5 A We get notice, usually by email. 6 Q From whom? 7 A From our attorney's office. And gather and 8 then look at the agenda and convene as CREED, and 9 then if there is SDOG business, we reconvene as 10 SDOG. 11 Q But the meetings happen at the same -- on 12 the same day, and once you're finished with business 13 for one organization, then you turn -- 14 A To another. Although, there are a number 15 of meetings at which there is only CREED business 16 and there had been fewer, I would say, where there 17 was only SanDOG business. 18 19 Q How many meetings would you estimate were there meetings where there was only SDOG business? 20 A Maybe half a dozen. 21 Q And can you give me an estimate as to how 22 many meetings occur -- have occurred that you've 23 attended where both CREED and SDOG business is 24 conducted? 25 A Probably 40. Peterson Reporting, Video & Litigation Services 53 Richard Lawrence, 11-17-14 1 Q How -- what's the -- what's the time frame 2 that the meetings have occurred in? And let me ask 3 you, as to -- how long have you been going to these 4 meetings? 5 A For six or seven years. 6 Q Okay. And you talked about the six 7 meetings where SDOG business alone is conducted and 8 40 meetings where SDOG and CREED business has 9 occurred. 10 Are those 46 meetings, did they occur within the last six or seven years? 11 A Yes. 12 Q Has there been any -- is there any 13 14 regularity to the meetings? A Well, the closest thing to regularity would 15 be about monthly, but obviously not every month, but 16 pretty nearly every month. 17 Q And to your knowledge, have you attended 18 every meeting of SDOG in the last six or seven 19 years? 20 A No, I don't believe so. 21 Q Can you give me an estimate as to what your 22 personal attendance has been at SDOG meetings? 23 A Sure. 24 meetings. 25 Q Probably 80 or 90 percent of the Have you ever gotten notice of a meeting Peterson Reporting, Video & Litigation Services 54 Richard Lawrence, 11-17-14 1 from anyone other than your attorney's office? 2 A No, I have not. 3 Q Who prepares the agenda for the meeting, if 4 you know? 5 A The Chair in conjunction with our attorney. 6 Q So is the agenda provided by the Chair of 7 the committee? 8 provided by the Chair of SDOG? 9 A Let me rephrase that. Is the agenda The question assumes that there is a 10 document that, you know, is put out on the table as 11 an agenda, and that is typically not the case. 12 The -- the Chair convenes the meeting, and then 13 we are introduced to a number of issues, part of which 14 are organizational issues we've been dealing with, and 15 then if there are new agenda items, those are added. 16 do not necessarily see a written agenda. 17 18 19 Q Have you ever seen a written agenda for any meetings of SDOG and CREED? A It depends on how you define agenda, I 20 guess. 21 we review typically at our meetings that certainly 22 constitute a significant part of accurate agenda. 23 We Q We have a log of business, legal cases that When you say there's a log of business, is 24 this sort of a notebook or some sort of written 25 memorialization of what the business is? Peterson Reporting, Video & Litigation Services 55 Richard Lawrence, 11-17-14 1 2 3 A It's a sheet of paper on which our current cases are listed. Q And is the log of business, this sheet of 4 paper that you're talking about, is that different 5 than the agenda that you testified about earlier? 6 A No, it's not. 7 Q It's the same thing? 8 A Uh-huh. 9 Q And do you know if the agenda is prepared 10 11 by the Chair? A I believe it's prepared by the Chair in 12 consultation with our attorney. 13 legal cases there which the Chair would need to talk 14 with Cory about in order to know whether there's 15 anything that constitutes business around any of the 16 cases that we have active. 17 Q Obviously there are Have you ever seen anything on a business 18 agenda, other than the legal cases that the 19 organization is involved in? 20 MR. BRIGGS: 21 THE WITNESS: 22 MR. BRIGGS: Hang on just a second. Sure. I'm going to object on 23 attorney-client privilege grounds because that's a very 24 clever way of finding out what is on a document that the 25 witness has already established is attorney-client Peterson Reporting, Video & Litigation Services 56 Richard Lawrence, 11-17-14 1 privilege. 2 So if you're going to start asking questions 3 about what is or is not on documents that obviously my 4 office is preparing and giving to the client, I'm going 5 to object and instruct the witness not to answer. 6 7 MS. PANCAKE: Your Honor? 8 9 Can I be heard on this, HON. PATE: Well, I'm going to overrule it, because seems to me just to be an advisory opinion as to 10 what he's going to do. 11 if you can. 12 MR. BRIGGS: 13 HON. PATE: 14 What is advisory? That you're going to be objecting if she goes into documents that you provided. 15 16 So you can answer the question, MR. BRIGGS: But she just asked whether he's ever seen anything on one of these logs. 17 MS. BROCK: Actually the question was have you 18 ever seen anything on a business agenda other than the 19 legal cases that the organization is involved in? 20 MR. BRIGGS: 21 thought you were -- 22 HON. PATE: 23 may proceed. 24 BY MS. PANCAKE: 25 Q So maybe I misunderstood. I So the objection is overruled. You Do you understand the question, Peterson Reporting, Video & Litigation Services 57 Richard Lawrence, 11-17-14 1 Mr. Lawrence? 2 A I do. 3 Q Okay. 4 A I don't recall seeing anything other than 5 the business for which we gather, which are legal 6 cases on our agenda. 7 Q Is there any other purpose for you 8 gathering other than to -- other than the legal 9 cases which you testified about? 10 A I would suppose were we in need of 11 financial support for the organization, that would 12 be a reason to meet, but at the moment I have no 13 recollection of ever having had to do that. 14 our focus is on our -- is on the legal cases which 15 we're trying to advance. 16 Q But no, And you testified that you supposed if the 17 organization needed financial support, that is 18 something that possibly would be on an agenda. 19 20 21 My question is: Has that item of financial support for the organization ever been on an agenda? A No, it has not. And I know that in the 22 early days if SanDOG, Ian Trowbridge, made a general 23 contribution to the organization to take care of 24 minor expenses. 25 off his generosity, but all of us are prepared, if And so I think we're still living Peterson Reporting, Video & Litigation Services 58 Richard Lawrence, 11-17-14 1 needed, to raise funds if we have to to assure that 2 the cases which we care about are advanced. 3 4 Q Do you know the amount of the contribution that Ian Trowbridge made? 5 A I don't. 6 Q How do you know it was generous? 7 A Well, I may have misspoken. I assume it's 8 generous since it's been several years since the 9 contribution was made and we haven't been called 10 upon to have to pony up in order to keep the 11 incidental expenses of the organization current. 12 So I would say take "generous" out of there. 13 He made a contribution which so far has enabled the 14 organization to survive without having its current 15 members raise any money. 16 Q When did this contribution occur? 17 A I don't know. Early on in his engagement 18 with SanDOG, but I don't know when. 19 date. 20 Q 21 22 I don't know a Do you know if the contribution was a one-time gift? A I don't know what his intentions were, 23 whether it was his intention to do it one time or 24 whether he -- if he had survived, whether he would 25 have done it again. I'm inclined to think he Peterson Reporting, Video & Litigation Services 59 Richard Lawrence, 11-17-14 1 2 probably would. Q I don't know. Well, I'm just -- I need to ask questions 3 about the testimony that you gave about Ian's -- was 4 it a monetary contribution? 5 A As opposed to? 6 Q Baking cookies for the meeting? 7 a bottle of wine for the meeting? 8 I mean, I don't know, coffee. Providing Doing whatever. 9 A It was a monetary contribution. 10 Q And how do you know that Mr. Trowbridge 11 made a contribution? 12 A Because I talked about this with my 13 attorney. 14 Q Other than discussing Ian's monetary 15 contribution with your attorney, did you ever 16 discuss it with Ian? 17 A No. 18 Q Have you ever discussed it with anyone 19 other than your attorney? 20 A No. 21 Q Do you know whether Mr. Trowbridge was 22 making ongoing monetary contributions to the 23 organization up until the time he died? 24 A No, I do not. 25 Q Other than the monetary contribution made Peterson Reporting, Video & Litigation Services 60 Richard Lawrence, 11-17-14 1 by Ian Trowbridge that you testified about already, 2 are you aware of any other monetary contributions 3 that have been made to the organization? 4 A No. 5 Q Have you ever made a monetary contribution 6 to the organization? 7 A No. 8 Q Have you ever made any monetary 9 10 contributions to other organizations which you know have been then forwarded to SDOG? 11 A No. 12 Q Have you made any non-monetary 13 contributions such as in-kind donations to SDOG? 14 A Other than my time? 15 Q Other than your time. 16 A No. 17 Q Have you ever received any monetary 18 payments from SDOG? 19 A No. 20 Q Have you ever received any monetary 21 payments from Mr. Briggs's law office? 22 A No. 23 Q Are you aware of whether any other 24 organizations have made monetary contributions to 25 SDOG? Peterson Reporting, Video & Litigation Services 61 Richard Lawrence, 11-17-14 1 A I'm not aware that any have. 2 Q Are you aware of whether any other 3 organizations have made any non-monetary 4 contributions? 5 A No, I'm not. 6 Q Are you aware of whether or not any other 7 organizations have ever provided indirect financial 8 assistance to SDOG? 9 A I'm not aware that any organizations have. 10 Q Prior to today, have you -- in your 11 capacity with your involvement with SDOG, have you 12 reviewed the Articles of Incorporation for SDOG? 13 A Actually I have not. 14 Q Mr. Lawrence, I'm giving you a document 15 that I premarked as Exhibit 4. 16 17 (Exhibit 4 was marked.) BY MS. PANCAKE: 18 Q Have you seen Exhibit 4 before today? 19 A I believe so. 20 Q What were the circumstances that surrounded 21 22 your review of this document prior to today? A It's -- I think it was part of the document 23 I mentioned earlier. Well, I'm not sure. I thought 24 it was part of the package I mentioned earlier that 25 was attendant to this document on the copy of the Peterson Reporting, Video & Litigation Services 62 Richard Lawrence, 11-17-14 1 Articles of Incorporation for the All People's 2 Breakfast. 3 Q And you're referring to Exhibit 3? 4 A Correct. 5 Q Do you remember the name being changed from 6 All People's Breakfast Organizing Committee to SDOG? 7 A No, I don't. 8 Q Were you involved in the organization at 9 the time when that change occurred? 10 A I don't know. 11 Q Have you ever reviewed the bylaws of the 12 All People's Breakfast Organizing Committee? 13 A No. 14 Q Have you ever reviewed the bylaws of 15 San Diegans For Open Government? 16 A No. 17 Q Could you give me a history of your 18 involvement with SDOG, including any leadership 19 positions that you may have held with that 20 organization at any time. 21 A I think it's important to mention here that 22 this organization is really different from any you 23 may be familiar with and that the only reason we 24 meet is to advance the cause of open government. 25 And it is phenomenal, actually, that we have Peterson Reporting, Video & Litigation Services 63 Richard Lawrence, 11-17-14 1 the capacity through the court to work on this issue 2 with the support of an attorney who cares deeply about 3 the same issue and does not require of us anything more 4 than is absolutely necessary so that we're able to use 5 the court to tackle some terribly complex issues which 6 if we did not have an attorney working with us, we 7 couldn't get close to. 8 9 So I was asked by Ian some years ago and to join, as I say it's six or seven years ago, I do 10 believe. 11 attempt to keep detailed minutes of our meetings. We 12 don't have to worry about financial transactions. We 13 can commit ourselves to trying to identify issues that 14 need attention and that can be addressed through the 15 court. 16 I've attended meetings since. We don't So the best I can do in terms of history is I 17 attend meetings, think as hard as I can think between 18 meetings about issues that the City needs to address, 19 and contribute those thoughts when we are together. 20 I don't -- other than attending meetings and 21 thinking as hard as I can about what is important, there 22 isn't much else of a history. 23 Q Have you ever held any leadership positions 24 in SDOG? 25 A Yes. Again, secretary of the organization. Peterson Reporting, Video & Litigation Services 64 Richard Lawrence, 11-17-14 1 I don't think I held any other offices. 2 Q When did you hold the office of secretary? 3 A Well, I'm the secretary now. But I don't 4 know actually when my term as secretary -- my 5 designation actually as secretary came about. 6 7 Q You don't know when your designation of secretary began? 8 A No. 9 Q Can you give me an estimate as to when that 10 11 12 13 14 was? A Again, I think it was four or five years ago. Q And why do you believe that you are secretary of the organization? 15 A Why do I believe I am? 16 Q Yes. 17 A Because in a meeting, it was agreed that I 18 19 20 would serve as secretary. Q When you said it was agreed that you would serve as secretary, did you attend that meeting? 21 A Yes. 22 Q Was there a vote? 23 A No. 24 Q There was just a collaborative discussion 25 and the result of that was that it was agreed that Peterson Reporting, Video & Litigation Services 65 Richard Lawrence, 11-17-14 1 you would serve as secretary? 2 A That's correct. 3 Q Who participated in that discussion from -- 4 with respect to the SDOG -- SDOG members or board 5 members? 6 A I really don't know who was there. 7 believe Ian was there. 8 was present at that particular meeting. 9 Q I But I don't know who else So is it your testimony that you've been 10 secretary of the organization for the last four or 11 five years? 12 A Yes. 13 Q Describe the duties that you've undertaken 14 with respect to acting as secretary for the 15 organization. 16 A Well, as I mentioned before, there are no 17 minutes because we conduct our business in direct 18 consultation with our attorney, and so the decisions 19 we make relate to the legal items on our agenda, and 20 I hold the title of secretary as a response to the 21 obligation of a corporation obviously to have a 22 secretary by State law. 23 Q What is your understanding as to the 24 obligations of the organization with respect to the 25 duties of a secretary? Peterson Reporting, Video & Litigation Services 66 Richard Lawrence, 11-17-14 1 A My duties would be those that any -- 2 started to say normal secretary in an organization 3 would perform when requested. 4 minutes, I would be asked to keep them. 5 needed correspondence, I would be asked to prepare 6 and send it. 7 8 9 Q So if we needed If we But that has not been the case. Do you know what State law requires with respect to the keeping of minutes? A It's the Secretary of State's office that 10 has, I suspect, an -- articles around -- legal 11 articles around incorporation. 12 13 Q Do you know what is required by State law with respect to keeping minutes of an organization? 14 A No. 15 Q Do you know what is required by the bylaws 16 of the corporation with respect to the duties of a 17 secretary? 18 A Other than what I just recited, no. 19 Q I want to go back to something that you 20 testified about earlier. 21 the SDOG organization was different from ones that I 22 may be familiar with. 23 different? 24 25 A You testified that SDOG -- And what do you mean by Specifically, the organization functions by a deep trust in one another and in our attorney and Peterson Reporting, Video & Litigation Services 67 Richard Lawrence, 11-17-14 1 with a single-minded focus on how most effectively 2 to advance legal action to address, redress -- to 3 address any issues that we see really compromise the 4 City's use of its authority to collect and spend 5 taxes. 6 Q And your testimony was that the SDOG 7 organization was different from ones that I may be 8 familiar with. 9 would be familiar with? 10 A How do you know what organizations I I would assume that you may not have had 11 the pleasure that we have had of a small group of 12 folks who gather with a single-minded function and 13 who do not have to protect each other by minutes and 14 bylaws, who are committed to a cause that unifies 15 us. 16 Period. Q So is it accurate to say that you believe, 17 based on your experience, that SDOG -- the SDOG 18 organization is different from other nonprofit 19 corporations? 20 A Yes. 21 Q And what -- you said you have deep trust in 22 one another. 23 A Uh-huh. 24 Q Who is one another? 25 Who are the individuals or -- one another meaning the members or Peterson Reporting, Video & Litigation Services 68 Richard Lawrence, 11-17-14 1 one another meaning somebody else? 2 A Particularly the board. 3 Q Who currently serves on the board? 4 A Pedro Quiroz and I. 5 Q Anyone else? 6 A Not that I know of. 7 Q And what is Pedro Quiroz's title? 8 A He's the chairman, in my view. 9 10 11 12 I think the articles probably refer him to as the chief executive officer. Q And it's your testimony that you serve in the capacity as secretary -- 13 A I do. 14 Q -- currently? 15 A Yes. 16 Q Have you ever served as the CEO or chairman 17 of the board? 18 A No. 19 Q Are you aware of any other board members 20 21 22 23 that are currently serving? A Sure. Our treasurer. And I know her first name is Karin, but I don't know any more than that. Q You also testified that SDOG acts with a 24 single-minded function. 25 testimony? Do you recall that Peterson Reporting, Video & Litigation Services 69 Richard Lawrence, 11-17-14 1 A Yes. 2 Q What is the single-minded function? 3 A To assure that taxes collected in the City 4 of San Diego are used in the most responsible way 5 with regard to the public's needs. 6 Q Are there any other functions, other than 7 what you have just testified about, that you're 8 aware of? 9 A Well, when it comes to open government, I 10 suspect that on occasion we may come across some 11 other issue or concern, but at the moment, those 12 issues that we are working on I would say fall under 13 the characterization I just recited. 14 Q To date, are you aware of any times when 15 any issue other than the taxation issue that you 16 testified about have been the function of SDOG? 17 18 MR. BRIGGS: Can you read that question, please. 19 (The pending question was read.) 20 MR. BRIGGS: 21 THE WITNESS: Go ahead. Sorry. I did not mean to characterize 22 the organization's function as being focused on taxation 23 but on the appropriate use of taxes collected to meet 24 the most urgent needs of the City. 25 So it isn't just the taxation that's the focus Peterson Reporting, Video & Litigation Services 70 Richard Lawrence, 11-17-14 1 of this organization but whether the resources that the 2 City has, the resources are being used to address the 3 most critical issues the City is facing. 4 And in order to engage the public in that, we 5 try to raise legal issues about projects and plans that 6 the City has that fail to meet what we think is 7 consistent with this organization's goals. 8 BY MS. PANCAKE: 9 Q What do you mean by raising legal issues? 10 A We will go to court. 11 12 That is what I mean by legal issues, by raising legal issues. Q And so other than raising legal issues 13 about the use of the City's resources, are there any 14 other functions or activities of SDOG that you're 15 aware of? 16 17 MR. BRIGGS: I will object that the question is vague, but you can answer, if you know. 18 THE WITNESS: As far as directly is concerned, 19 I don't know of any other issues that really get our 20 attention. 21 whether or not the most responsible use of resources is 22 being met is plenty to keep us busy. 23 BY MS. PANCAKE: 24 25 Q I would add that I think the issues around Do you raise legal issues that you testified about in any way other than filing Peterson Reporting, Video & Litigation Services 71 Richard Lawrence, 11-17-14 1 lawsuits? 2 MR. BRIGGS: The question is also vague. 3 You can answer if you know. 4 THE WITNESS: I don't know what other way of 5 raising legal issues there is, so... 6 BY MS. PANCAKE: 7 Q Did you think that my previous question was 8 vague? Did you -- I mean I want to make sure that 9 you understand my question. Your attorney raised a 10 vagueness objection, so I want to make sure that you 11 understand what my question was. 12 rephrase that. 13 And let me Does SDOG do anything other than filing 14 lawsuits in order to raise the legal issues about which 15 you previously testified? 16 MR. BRIGGS: Yeah, same objection. I don't 17 understand the question, but you can answer if you 18 understand. 19 THE WITNESS: I think I said before, I don't 20 know -- if it's in the -- if it's a legal issue, I don't 21 know how we would raise it other than legal action, that 22 is to say, preparing a court case. 23 we do anything other. 24 as the mechanism by which we address our concerns. 25 /// So I don't know that Our focus has been on the courts Peterson Reporting, Video & Litigation Services 72 Richard Lawrence, 11-17-14 1 2 3 BY MS. PANCAKE: Q issues that SDOG has been involved with? 4 5 And are there any issues other than legal MR. BRIGGS: That question is also vague, but you can answer, if you know. 6 THE WITNESS: I don't -- I don't recall. My 7 memory is that our energies are spent because we think 8 the courts are the most effective way of getting action 9 on issues has been the focus of our energies. 10 11 12 BY MS. PANCAKE: Q And my question is, other than filing lawsuits and utilizing the courts -- 13 A Not that I know of. 14 Q Let me finish. Other than filing lawsuits 15 and using the courts to redress the issues that SDOG 16 is involved with, are there any other activities 17 that SDOG has undertaken to redress those issues? 18 A Not that I'm aware of. 19 Q You also testified earlier that the only 20 reason you meet is to advance the cause of open 21 government. I'm paraphrasing your prior testimony. 22 A That's fine. 23 Q And that the attorney does not require 24 anything of us, anything other than what is 25 absolutely necessary. Peterson Reporting, Video & Litigation Services 73 Richard Lawrence, 11-17-14 1 Do you recall that testimony? 2 A Yes. 3 Q What do you mean by the attorney does not 4 require anything of you other than what is 5 absolutely necessary? 6 A What I mean is in the early days at the 7 Affordable Housing Coalition, we had met Cory and 8 wanted his help on a case that we thought we needed 9 to bring against the Maryland Hotel for failure to 10 meeting a City ordinance to replace SRO units. 11 In our early discussions it was clear that we 12 would need to raise money as an organization to cover 13 court costs, as an example. 14 that. 15 And so we agreed to do In the case of SanDOG, we haven't had to do 16 that, and so that's the primary distinction I make. 17 haven't had to generate money to cover the court costs 18 and other costs related to our legal actions. 19 Q And why not? 20 A Because our attorney is prepared to advance 21 those as-needed in his support of the causes at 22 hand. 23 MR. BRIGGS: 24 MS. PANCAKE: 25 We Are we at a bathroom break point? I'm happy to take a short break. We can go off the record. Peterson Reporting, Video & Litigation Services 74 Richard Lawrence, 11-17-14 1 THE VIDEOGRAPHER: This ends Media No. 1 in the 2 deposition of Richard Lawrence. 3 is 11:54 a.m. The time off the record 4 (Lunch break taken.) 5 THE VIDEOGRAPHER: 6 the deposition of Richard Lawrence. 7 record is 12:23 p.m. 8 9 10 This begins Media No. 2 in The time on the (A lunch recess was taken.) BY MS. PANCAKE: Q Mr. Lawrence, we're back on the record 11 after a quick lunch break. 12 still under oath? 13 A Yes. 14 Q Okay. You realize that you are I believe you testified earlier that 15 you had never read the bylaws of San Diegans For 16 Open Government; is that correct? 17 A That is. 18 Q Okay. 19 20 23 24 25 I've marked a document as Exhibit 5. A 21 22 There we go. Uh-huh. (Exhibit 5 was marked.) BY MS. PANCAKE: Q Can you take a quick look at Exhibit 5, sir. Have you had a chance to take a look at Peterson Reporting, Video & Litigation Services 75 Richard Lawrence, 11-17-14 1 Exhibit No. 5? 2 3 Mr. Lawrence, have you ever discussed the duties of the corporate officers with Mr. Quiroz? 4 A No. 5 Q Have you ever discussed the duties of 6 corporate officers with Mr. Trowbridge? 7 A No. 8 Q Have you ever discussed the duties of 9 corporate officers with anyone? 10 MR. BRIGGS: I'm going to object on 11 attorney-client privilege grounds and instruct the 12 witness not to answer. 13 to exclude attorneys, that would be fine; otherwise, 14 don't answer the question. 15 HON. PATE: If you would like to narrow it Why don't you rephrase it to 16 exclude reference to counsel, after which the objection 17 would be sustained. 18 BY MS. PANCAKE: 19 Q Mr. Quiroz, other than your attorneys -- 20 MR. BRIGGS: 21 MS. PANCAKE: I'm sorry. 22 THE WITNESS: That's all right. 23 24 25 Mr. Lawrence you mean? Thank you. BY MS. PANCAKE: Q Mr. Lawrence, excluding your attorneys, have you discussed the duties of corporate officers Peterson Reporting, Video & Litigation Services 76 Richard Lawrence, 11-17-14 1 with anyone? 2 A No, I haven't. 3 Q Okay. After having looked through the 4 bylaws, which are marked as Exhibit 5, is it still 5 your testimony that you've never seen this document 6 before? 7 A Not to my knowledge. 8 Q Sir, have you ever acted as the chief 9 executive officer of SDOG? 10 A No. 11 Q I'm showing you a document that we've 12 marked as Exhibit 6. 13 14 15 16 (Exhibit 6 was marked.) BY MS. PANCAKE: Q Have you seen Exhibit 6 before, Mr. Lawrence? 17 A No. 18 Q Are you -- can you look and see where you 19 are listed as chief executive officer? 20 A Yes. 21 Q Did you ever give anyone permission to 22 appoint you as chief executive officer? 23 A No. 24 Q Did the board ever vote to make you chief 25 executive officer? Peterson Reporting, Video & Litigation Services 77 Richard Lawrence, 11-17-14 1 A No. 2 Q Have you ever supervised and controlled the 3 corporation's affairs and the activities of the 4 officers? 5 A No. 6 Q Have you ever del- -- have you ever 7 delegated this authority to somebody else to do? 8 A No. 9 Q Are you aware of why your name was stated 10 as the chief executive officer as of September 11th, 11 2013? 12 A I'm not aware. It looks like the names 13 were switched between Pedro Quiroz and myself. 14 assume a mistake was made. 15 Q I I'm going to -- I'm going to ask you on 16 Exhibit 6, do you recognize the signature on Exhibit 17 6e to be that of Karin Langwasser? 18 A I don't. 19 Q I'm going to show you Exhibit 7. 20 A Okay. 21 22 (Exhibit 7 was marked.) BY MS. PANCAKE: 23 Q Do you recognize Exhibit 7? 24 A No. 25 Q Let me ask you this. I may have asked you Peterson Reporting, Video & Litigation Services 78 Richard Lawrence, 11-17-14 1 this already, but I've forgotten. 2 3 With respect to Exhibit 6, have you seen this document before today? 4 A Not that I can recall. 5 Q Okay. 6 And have you seen Exhibit 7 before today? 7 A No. 8 Q Were you aware that as of July 1st, 2011, 9 Ian Trowbridge was listed as all three officers, 10 chief executive officer, secretary and chief 11 financial officer? 12 A No, I was not aware. 13 Q Okay. 14 Is that contrary to your understanding? 15 A It is. 16 Q Do you recognize the signature as being 17 that of Ian Trowbridge? 18 A I don't know. I don't know his signature. 19 Q So you couldn't identify his signature? 20 A I could not, no. 21 Q Okay. Are you aware of whether or not 22 there were any changes to the corporate structure of 23 SDOG between July 1st, 2011, and September 11th, 24 2013? 25 A I'm not aware of any changes, no. Peterson Reporting, Video & Litigation Services 79 Richard Lawrence, 11-17-14 1 Q Are you aware of any other changes in the 2 officers of SDOG between July 1st, 2011, and 3 September 11th, 2013? 4 A As I testified earlier, I thought I was 5 selected to be the secretary sometime earlier than 6 2011 and apparently I was not. 7 Q Okay. Are you aware of any changes to the 8 officers of SDOG that have -- that have been voted 9 upon after September 11th, 2013? 10 11 MR. BRIGGS: Can you read that question again, please. 12 (The pending question was read.) 13 MR. BRIGGS: 14 THE WITNESS: 15 regard to those specific dates. 16 BY MS. PANCAKE: 17 18 19 Q You can answer that. I'm not aware of any changes with Are you aware of any changes other than with regards to those specific dates? A Well, and in addition, those officers 20 typically are not voted on. 21 a meeting, but there's generally no vote. 22 some point between the dates you mentioned, I was 23 asked to serve as secretary. 24 25 Q They're agreed upon at And at You were asked to serve as secretary between 2011 and 2013? Peterson Reporting, Video & Litigation Services 80 Richard Lawrence, 11-17-14 1 A As I said earlier, I think it was earlier 2 than that, but at the very least, I would say, yes, 3 sometime between the dates you've mentioned. 4 Q 5 Has your activity -- let me rephrase that. Has there been a change in your activities with 6 SDOG that has occurred after the death of 7 Mr. Trowbridge? 8 9 MR. BRIGGS: Objection. Vague as to the date, but if you know, you can answer. 10 THE WITNESS: Well, I don't know the date of 11 Mr. Trowbridge's death, but since he has not been 12 attending meetings, my role hasn't changed. 13 attend, participate as I have since I became a member. 14 BY MS. PANCAKE: 15 Q I just So it's your testimony that the death of 16 Mr. Trowbridge did not result in a change of your 17 activities personally with SDOG? 18 A No, it did not. 19 Q Has the death of Mr. Trowbridge changed the 20 way decisions get made by SDOG? 21 A No, it hasn't. 22 Q Has the death of Mr. Trowbridge resulted in 23 24 25 a change in any membership activities? MR. BRIGGS: Objection. Vague. If you know what the question means, you can answer it. Peterson Reporting, Video & Litigation Services 81 Richard Lawrence, 11-17-14 1 THE WITNESS: 2 activities means. 3 BY MS. PANCAKE: I don't know what membership 4 Q Does SDOG have members other than you? 5 A Yes. 6 Q And how do members join? 7 A Formally I don't know and by statement of 8 interests and they're added to essentially an email 9 list that then receives email communications from 10 the organization. 11 Q What did you do to become a member of SDOG? 12 A I just met with Ian and that was all there 13 14 15 was to it. Q Did you have to fill out any membership application? 16 A No. 17 Q Did you do anything other than have a 18 discussion with Ian to become a member? 19 A No. 20 Q Did you receive a membership card? 21 A No. 22 Q Did you receive any other -- any kind of 23 indicia of membership, such as a congratulatory 24 email or a letter or any kind of written 25 documentation? Peterson Reporting, Video & Litigation Services 82 Richard Lawrence, 11-17-14 1 A No, I didn't. 2 Q Is there a particular membership criteria 3 that is used to determine whether someone can be a 4 member of SDOG or not? 5 A There are no written criteria of which I am 6 aware. I mentioned earlier that there is a -- sort 7 of a test that is very guttural with regard to 8 commitment to the organization's goals. 9 Q What is the test? 10 A It's evidence of a concern for open 11 12 government. Q And who determines whether the person 13 submitting a request or an application to join SDOG 14 will actually be admitted as a member? 15 A Well, I need to make a distinction between 16 member and board. 17 is all that's required to be added to the members of 18 SDOG. 19 a number of meetings that an individual would attend 20 and an indication of their interest in the 21 organization that is sort of authenticated by one of 22 the current board members. 23 Q I think an indication of interest But in the case of board, there is typically Okay. Other than becoming a board member, 24 I want my questions to focus on just being sort of a 25 regular member -- Peterson Reporting, Video & Litigation Services 83 Richard Lawrence, 11-17-14 1 A Uh-huh. 2 Q -- of SDOG. And the question that I had 3 asked previously was do you know who determines 4 whether a person that is submitting a request to 5 join or an application to join meets the criteria 6 that is necessary for them to become a member? 7 A I do not. 8 Q For as long as you've been on the board, 9 10 which is I believe you testified for the last six or seven years -- 11 A Uh-huh. 12 Q -- is that accurate? 13 A Yes. 14 Q -- has the board ever admitted any new 15 members? 16 A No. 17 Q Are you aware of whether or not there have 18 been any new members of SDOG during the time that 19 you've been on the board, which was the last six or 20 seven years? 21 A Yes. 22 Q And how are you aware of that? 23 A Only by report from Attorney Briggs' 24 25 office. Q Other than any information that you may Peterson Reporting, Video & Litigation Services 84 Richard Lawrence, 11-17-14 1 have received from your attorney, do you have any 2 independent knowledge of whether or not there have 3 been new members who have joined SDOG in the last 4 six or seven years? 5 A No. 6 Q Has the issue of any new members -- you 7 know what? 8 9 I'm going to withdraw that question. MR. BRIGGS: Let's take a break while you're looking that up. 10 MS. PANCAKE: Actually, do you need to take a 11 break? 12 Would you like to take a break right now? 13 14 MR. BRIGGS: Yes, let's take a break. THE VIDEOGRAPHER: MS. PANCAKE: 18 THE VIDEOGRAPHER: Do you want to go off the Yes, we can go off the record. Off the record. (Pause in the proceedings.) 21 THE VIDEOGRAPHER: 22 time is 12:48 p.m. 23 BY MS. PANCAKE: 25 The time is 12:43 p.m. 20 24 Just a record? 17 19 I can go forward. couple minutes. 15 16 I don't need to look it up. Q Back on the record. The Mr. Lawrence, you realize you're still under oath? Peterson Reporting, Video & Litigation Services 85 Richard Lawrence, 11-17-14 1 A I do. 2 Q All right. After having taken a break with 3 your attorney off the record, is there any testimony 4 that you have given that you would like to change at 5 this time? 6 MR. BRIGGS: Hang on. I'm going to instruct 7 him not to answer the question, because you are making 8 it sound like I'm somehow telling him what to say. 9 only is that inappropriate, but you've done it in pretty 10 much every prior deposition. 11 have told you you shouldn't do it. 12 MS. PANCAKE: 13 MR. BRIGGS: 14 Not And the discovery referees So -- Oh --- we're not going to do that again today, Jenni. 15 MS. PANCAKE: 16 You're misrepresenting things. 17 break at a particularly important point in the testimony 18 and you take a five-minute break with your client out of 19 the room, I think I'm entitled to ask after taking a 20 break with your attorney out of the room, sir, is there 21 any testimony that you believe should be changed as a 22 result of your leaving the room with the attorney? 23 MR. BRIGGS: 24 not to answer. 25 not to answer. Okay. You know something, Cory? And when you guys take a I'm going to instruct the witness You're not -- I'm going to instruct him Peterson Reporting, Video & Litigation Services 86 Richard Lawrence, 11-17-14 1 HON. PATE: 2 witness can answer. 3 MR. BRIGGS: 4 not to answer. 5 BY MS. PANCAKE: 6 7 The objection is overruled. Q I'm still going to instruct him Mr. Lawrence, are you aware of whether or not SDOG has a membership application? 8 A Yes. 9 Q And does SDOG have a membership 10 The application? 11 A Yes. 12 Q When did you become aware of that fact? 13 A Over the course of the -- 14 (Cell phone interruption.) 15 THE WITNESS: 16 Excuse me, please. 17 BY MS. PANCAKE: I forgot to turn this back off. 18 Q No problem. 19 A It's really been in the last couple of 20 years that individuals who are interested in 21 becoming a member of SanDOG would usually attend the 22 meeting and request membership after having made 23 application, so... 24 25 But really before the last couple years, I wasn't aware of membership applications. And I'm Peterson Reporting, Video & Litigation Services 87 Richard Lawrence, 11-17-14 1 assuming it's because we've gotten additional visibility 2 and folks have wanted to be supporters. 3 Q Well, I think prior to the break that you 4 took, you testified that for the past six or seven 5 years you were not aware of any new members joining 6 SDOG. 7 A 8 9 10 11 I think if you check the transcript you will see that isn't what I said. Q Okay. Can you -- can you rephrase what you said about -A What I said was there were meetings at 12 which folks who were interested in SDOG attended a 13 meeting and in the course of that presented 14 themselves as the candidates for membership, and in 15 at least one case, an interest in becoming a member 16 of the board. 17 Q And did this happen -- did this discussion 18 or request to become a member happen at a meeting 19 that you attended? 20 A Yes. 21 Q And how long ago was that? 22 A As I say, two or -- that specific incident, 23 24 25 I'd say within the last year. Q And the person that you're talking about, who is that person? Peterson Reporting, Video & Litigation Services 88 Richard Lawrence, 11-17-14 1 A Linda Perine. 2 Q And is it your testimony that Linda Perine, 3 made a verbal request at a meeting to become an SDOG 4 member? 5 A Yes. 6 Q Are you aware of whether or not any action 7 8 9 10 was taken upon her request? A I don't -- no, I don't know what action was taken. Q Did the board take any action at the 11 meeting where Ms. Perine made a verbal request 12 within the last year to become a member of SDOG? 13 A Not that I know of. 14 Q Did you participate in any determination 15 regarding whether Ms. Perine would or would not 16 become a member of SDOG? 17 A No, I didn't. 18 Q Are you aware of whether or not SDOG has a 19 written membership form? 20 21 Let me rephrase that. Are you aware of whether or not SDOG has a written membership application form? 22 A I've never seen a written application form. 23 Q Okay. 24 25 My question was, are you aware of whether it has one? A I am aware that it has one, yes. Peterson Reporting, Video & Litigation Services 89 Richard Lawrence, 11-17-14 1 2 Q And how -- how are you aware that it has one? 3 A Conversations with law office staff. 4 Q When was the first time that you became 5 aware that SDOG had a written membership application 6 form? 7 A 8 As I say, I think it was about a couple years ago. 9 Q A couple years ago or a year ago? 10 A I think I said before and was -- that it 11 was a couple years ago. 12 ago. 13 14 Q I think it was couple years Was membership applications something that was discussed by the board at any of its meetings? 15 A No, not that I recall. 16 Q What were the circumstances that occurred 17 that caused you to become aware of the issue of a 18 membership application form? 19 MR. BRIGGS: Now I'm going to object because 20 he's already told you how he learned about it. 21 not going to get into the circumstances. 22 Attorney-client privilege. 23 HON. PATE: So we're Don't answer the question. Well, to the extent that it calls 24 for conversations with attorneys, sustained. 25 otherwise, he can answer. If it's Peterson Reporting, Video & Litigation Services 90 Richard Lawrence, 11-17-14 1 MR. BRIGGS: If you can answer without 2 disclosing any conversations between you and my law 3 office, you should; if you can't, tell her you are not 4 going to answer the question. 5 6 THE WITNESS: conversation with the -- the law office. 7 8 9 I thought I had said it was in MR. BRIGGS: You did say that. BY MS. PANCAKE: Q So other than discussions with the law 10 office, were there any other circumstances that were 11 occurring with respect to SDOG business that caused 12 you to become aware that there was a membership 13 application form? 14 A No. 15 Q And you testified you have never seen the 16 membership application form? 17 A I have not, no. 18 Q Are you aware of who generated the content 19 of the form? 20 A No, I'm not. 21 Q Do you have a belief that Ian Trowbridge 22 had anything to do with the creation of a membership 23 application form? 24 A I have no knowledge of that. 25 Q Did you ever discuss it with him? Peterson Reporting, Video & Litigation Services 91 Richard Lawrence, 11-17-14 1 A No. 2 Q Have you ever seen a blank form? 3 A No. 4 Q Have you ever seen a form that's been 5 filled out by anyone? 6 A No. 7 Q Have you ever seen a membership form that's 8 allegedly been filled out by Linda Perine? 9 A No. 10 Q Have you ever discussed membership in SDOG 11 with Linda Perine? 12 A No. 13 Q How did you find out that Linda Perine -- 14 let me ask you: Is Linda Perine a member of SDOG? 15 A I don't know. 16 Q Since the meeting that you testified about 17 where Linda Perine came and requested to be a member 18 of SDOG, has she come to any other meetings where 19 you've also been there? 20 A No. 21 Q Has anyone ever been dismissed from 22 membership? 23 A Not to my knowledge. 24 Q Does SDOG advertise the availability of 25 memberships in its organization? Peterson Reporting, Video & Litigation Services 92 Richard Lawrence, 11-17-14 1 A We have a website. 2 Q Is that the WordPress website? 3 A Yes. 4 Q Other than the WordPress website, are there 5 any other means by which -- well, let me back up. 6 7 Does SDOG advertise memberships in its organization on the WordPress website? 8 A I don't know. 9 Q Other than the WordPress website, are there 10 any other potential ways that SDOG can advertise or 11 does advertise memberships in its organization? 12 A None of which I'm aware. 13 Q Do you know if SDOG maintains a list of its 14 members? 15 A I don't know, but I believe there is an 16 email list that we use on occasion for email blasts 17 to members. 18 Q And in all of your years of acting as 19 secretary of the organization, have you ever used 20 the email list to -- to undertake communications 21 with the other members? 22 A I have not. 23 Q Have you seen any email correspondence 24 going between members that did not include 25 Mr. Briggs or his law office? Peterson Reporting, Video & Litigation Services 93 Richard Lawrence, 11-17-14 1 A I have not. 2 Q Have you ever communicated by email with 3 Linda Perine? 4 A No, I have not. 5 Q Other than the meeting that you testified 6 about where she came and verbally requested to 7 become a member of SDOG, have you ever had any other 8 discussions with her on any other topic subsequent 9 to that time? 10 A No, I haven't. 11 Q Did you have a discussion with her at that 12 meeting? 13 A No, not directly with her. I participated 14 in the discussion in general, but I don't -- I did 15 not have a one-to-one conversation with her, no. 16 17 Q Did she have a conversation with the board, with the board members? 18 A Yes. 19 Q And were you included in that 20 conversation -- 21 A Yes. 22 Q -- as a board member? 23 A Yes. 24 Q But she did not have any discussions with 25 you at that meeting other than her discussion with Peterson Reporting, Video & Litigation Services 94 Richard Lawrence, 11-17-14 1 the board? 2 A That's correct. 3 Q And you've never had a discussion with her 4 subsequent to that time? 5 A Not that I know of. 6 Q Do you know whether or not she's still a 7 member of SDOG? 8 A I do not know. 9 Q And do you know whether or not she 10 ultimately became a member after making that 11 request? 12 A No. 13 Q How many names are listed on the email list 14 that you described? 15 A I don't know. 16 Q Can you give me an estimate? 17 A No, I can't. 18 Q Is it more than ten? 19 A I don't know. 20 Q Have you received these email -- emails 21 from the email blast list? 22 A I have not, no. 23 Q Then how do you know that there is an email 24 list? 25 A As I indicated earlier, the conversation Peterson Reporting, Video & Litigation Services 95 Richard Lawrence, 11-17-14 1 2 with the staff at the law office. Q So you've never received an email notice 3 for an SDOG meeting? 4 MR. BRIGGS: 5 misstates his prior testimony. 6 7 I'm going to object. That You can answer. BY MS. PANCAKE: 8 Q I don't think -- 9 A I have -- I have received an email notice 10 of an SDOG meeting, yes, but that is not what I'm 11 referring to when I'm talking about the email blast 12 that goes out to members that bring them up to date 13 on current activities. 14 Q Okay. So you receive email notices about 15 meetings, but it's your testimony that you don't 16 receive the email blast? 17 A No, I don't. 18 Q Why is that, if you know? 19 A I don't know. I, frankly, don't think I 20 need to know because the way the organization works, 21 I think I know everything and anything that the 22 organization is involved in and what the current 23 status is. 24 Q Do you know how many members SDOG has? 25 A No. Peterson Reporting, Video & Litigation Services 96 Richard Lawrence, 11-17-14 1 Q Can you give me an estimate? 2 A No. 3 Q Why not? 4 A Well, I don't know. That would be like 5 my -- my trying to estimate like you said before 6 something that I'd never seen before. 7 seen the membership list. 8 9 Q I've never How many meetings has SDOG had in the last two years? 10 A Two years? 11 Q Okay. 12 A Or so, yes. 13 Q And have you attended all 12 of those 14 meetings? 15 A I'm not sure, but I think so. 16 Q Do you know any meetings that you've 17 I would estimate about 12. And is that once every other month? definitely missed within the last two years? 18 A I don't, no. 19 Q At the meetings, the 12 meetings that you 20 testified about, how many members were in attendance 21 for each of those meetings? 22 A Those were board meetings. 23 Q Okay. 24 25 Do you make a distinction between board meetings and regular meetings? A If you are referring to meetings of the Peterson Reporting, Video & Litigation Services 97 Richard Lawrence, 11-17-14 1 membership, then I don't know when, or if, there are 2 meetings of the membership. 3 board. 4 organization requests to be present, they obviously 5 are welcomed. 6 Q I am a part of the The board meets and when a member of the So in the last six or seven years that 7 you've been involved with SDOG, have there been any 8 meetings of the membership as a whole? 9 A Not that I'm aware of. 10 Q And on how many occasions in the last six 11 or seven years have there been a board meeting where 12 someone -- where a member other than somebody 13 serving on the board attended? 14 A 15 meetings. 16 two or three who are not members of the board. 17 18 Q I would estimate probably half of the There's a -- an additional participant or And in the last two years, how many meetings have there been additional participants? 19 A Maybe half. Half of our meetings. 20 Q Have there been any meetings that have 21 occurred where someone who was not a member and 22 someone other than your attorneys have attended? 23 A Not that I can recall. 24 Q How has the composition of the board 25 changed over your tenure as a board member? Peterson Reporting, Video & Litigation Services 98 Richard Lawrence, 11-17-14 1 A Obviously with Ian's death, we lost his 2 participation on the board. 3 member of the board. 4 actually, Theresa Quiroz was a member of the board, 5 but I don't know of any other changes. 6 Q Pedro Quiroz became a I believe before Pedro, After Mr. Trowbridge passed away, how many 7 meetings occurred prior to there being a change in 8 the board leadership? 9 A I don't think there were any. I'm fairly 10 sure that after his death at the next board meeting, 11 we asked Pedro to take on the job of the Chair, but 12 it may have -- but there may have been a meeting in 13 between, but I think it was the next meeting after 14 his death. 15 16 Q Have you attended all the board meetings that have occurred after Mr. Trowbridge's death? 17 A I think so. I'm not sure. 18 Q Has an individual by the name of 19 Dell Cunamay come to any board meetings since the 20 death of Mr. Trowbridge? 21 A Not that I'm aware. 22 Q Are you -- do you know an individual named 23 24 25 Dell Cunamay? A No. I've heard the name, but I don't know him personally. Peterson Reporting, Video & Litigation Services 99 Richard Lawrence, 11-17-14 1 Q Has the board ever taken action to request 2 documents that Mr. Trowbridge may have kept in his 3 personal belongings that related to SDOG? 4 A Not that I'm aware. 5 Q Have you ever had any discussions with 6 anybody about documents that Mr. Trowbridge may have 7 kept that relate to SDOG? 8 9 MR. BRIGGS: I'm going to object on attorney-client privilege grounds and instruct the 10 witness not to answer. 11 question. 12 attorneys, I'm going to instruct the witness not to 13 answer. 14 BY MS. PANCAKE: 15 Q You are welcome to tailor the If you are going to leave it broad to include Has the board ever discussed the issue with 16 anyone other than its attorneys, if at all, about 17 whether or not there were documents that were 18 maintained by Mr. Trowbridge relating to SDOG? 19 A We have not. 20 Q Has the board made any decisions about 21 documents that may have belonged to Mr. Trowbridge 22 that related to SDOG? 23 A No. 24 Q Mr. Lawrence, are you aware of whether or 25 not SDOG has ever been out of compliance with the Peterson Reporting, Video & Litigation Services 100 Richard Lawrence, 11-17-14 1 Secretary of State? 2 A Yes. 3 Q And what do you know about this? 4 A Only what my attorney has told me. 5 Q Are you aware that -- of whether or not 6 SDOG was ever suspended as a corporation? 7 MR. BRIGGS: Hang on. He just told you that 8 the extent of what he knows came from me. 9 to object on attorney-client privilege grounds and 10 instruct the witness not to answer. 11 BY MS. PANCAKE: 12 13 Q So I'm going Are you going to follow your attorney's instruction? 14 A I am. 15 Q As secretary, did you ever take any steps 16 to revive the corporation from suspension? 17 A I did not. 18 Q Did you ever participate in any discussions 19 at the board level with respect to reviving the 20 corporation? 21 A No. 22 Q Do you know the current status of whether 23 or not SDOG is currently suspended or not? 24 A Only because of conversations with my 25 attorney. Peterson Reporting, Video & Litigation Services 101 Richard Lawrence, 11-17-14 1 MR. BRIGGS: 2 anything else. 3 BY MS. PANCAKE: 4 Q Don't -- so don't tell her But other than conversations you may have 5 had with your attorney, do you have any independent 6 knowledge about whether or not SDOG is currently 7 active or suspended? 8 A I do not. 9 Q Do you have any information about -- well, 10 let me rephrase that. 11 12 13 Are you aware of whether or not SDOG is in good standing with the Franchise Tax Board? A 14 15 I am not. MR. BRIGGS: THE WITNESS: 17 that subject. 18 BY MS. PANCAKE: 20 Q I do not have any information on Mr. Lawrence, I'm showing you a document that I've marked as Exhibit 8. 21 22 She asked whether you have any information. 16 19 I'm not or do not? (Exhibit 8 was marked.) BY MS. PANCAKE: 23 Q Sir, have you ever seen Exhibit 8 before? 24 A No. 25 Q Okay. If you take a look at Paragraph 2 of Peterson Reporting, Video & Litigation Services 102 Richard Lawrence, 11-17-14 1 Exhibit 8, it says, "The specific purposes as stated 2 in your Articles of Incorporation are not consistent 3 with the statement of purposes and the statement of 4 programs and activities furnished with your 5 application." 6 Do you see that? 7 A Yes, I do. 8 Q Prior to today -- we're looking at this 9 right now -- were you aware that the purposes stated 10 in the Articles of Incorporation were not consistent 11 with a Statement of Purpose that was submitted to 12 the Franchise Tax Board? 13 14 MR. BRIGGS: Objection. That calls for a legal conclusion. 15 You can answer, if you know. 16 THE WITNESS: 17 that issue, no. 18 BY MS. PANCAKE: 19 Q I didn't -- I had no knowledge of Do you know whether or not the Articles of 20 Incorporation have been revised subsequent to the 21 date of this letter, which is October 26th, 2012? 22 23 24 25 A Yes, I do know because of conversations with my attorney. Q Okay. Have the Articles of Incorporation been revised? Peterson Reporting, Video & Litigation Services 103 Richard Lawrence, 11-17-14 1 A Yes. 2 Q When did that occur? 3 A I don't know the date. 4 Q Can you give me an estimate? 5 A No, I cannot. 6 Q Have the Articles of Incorporation, the 7 revised Articles of Incorporation, been voted upon 8 by the board of directors? 9 A No. 10 Q Has the board of directors taken any action 11 to revise the Articles of Incorporation? 12 A No. 13 Q Do you know whether or not the revised 14 Articles of Incorporation have been submitted to the 15 Franchise Tax Board? 16 A No. 17 Q Just for -- I apologize. I think I said 18 the wrong thing. 19 whether the Articles of Incorporation have been 20 amended in any way subsequent to October 26, 2012? 21 22 A Do you know when -- or do you know Only in conversation with my attorney, and if I -- 23 MR. BRIGGS: 24 say anything more. 25 /// That's fine. You don't need to do Peterson Reporting, Video & Litigation Services 104 Richard Lawrence, 11-17-14 1 2 3 BY MS. PANCAKE: Q So has amendment of the Articles of Incorporation actually occurred? 4 A I do not know. 5 Q Has amendment of the Articles of 6 Incorporation been something that the board has 7 taken action on? 8 9 MR. BRIGGS: I'm going to object on attorney-client privilege grounds, because any 10 conversation with the board on amending the articles 11 would have taken place with me present. 12 If you want to ask him that question about that 13 conversation in the absence of counsel present, that's 14 fine. 15 counsel present, I will object and instruct him not to 16 answer. If you're going to ask it generically to include 17 MS. PANCAKE: Well, I'm asking a little bit of 18 a different question. 19 or any legal advice that you may have given the board in 20 connection with this issue is protected by the 21 attorney-client privilege, and I'm not seeking to get 22 the content of any discussions or any -- any 23 confidential communications from you to the board. 24 question is whether or not the board has taken action to 25 amend the Articles of Incorporation? I understand that any discussions My Peterson Reporting, Video & Litigation Services 105 Richard Lawrence, 11-17-14 1 MR. BRIGGS: 2 answer that question. 3 THE WITNESS: Well, that's different. You can In fact, he already has. The board really has placed 4 enormous trust in our attorney to take care of things 5 like the Articles of Incorporation, and as a 6 consequence, we typically don't spend a whole lot of 7 time discussing matters of that sort. 8 BY MS. PANCAKE: 9 Q Are you finished with your answer? 10 A Yes. 11 Q Okay. That's interesting to know, but my 12 question is: Has the board taken action to amend 13 the Articles of Incorporation subsequent to 14 October 26, 2012? 15 A Not to my knowledge. 16 Q Mr. Lawrence, have you ever participated in 17 any correspondence with the Franchise Tax Board on 18 behalf of SDOG? 19 A No. 20 Q Have you ever reviewed any documents 21 relating to Franchise Tax Board issues that may 22 affect or may have affected SDOG? 23 A Not that I recall. 24 Q Have you ever signed any documents related 25 to issues between SDOG and the Franchise Tax Board? Peterson Reporting, Video & Litigation Services 106 Richard Lawrence, 11-17-14 1 A Not that I recall. 2 Q Have you ever authorized anyone to sign 3 documents for you with respect to issues between 4 SDOG and the Franchise Tax Board? 5 A Not that I recall. 6 Q Mr. Lawrence, I'm showing you a document 7 8 that will be marked as Exhibit 9? A 9 10 Uh-huh. (Exhibit 9 was marked.) BY MS. PANCAKE: 11 Q Do you recognize Exhibit 9? 12 A Yes. 13 Q What is Exhibit 9? 14 A It's a council resolution honoring me with 15 16 a Richard Lawrence Day. Q Is this the actual resolution or is this 17 a -- just the text as something that was prepared by 18 somebody else other than the City? 19 A Gosh, I don't know. I don't remember what 20 the actual text was. 21 thought it was the actual text. 22 Q But I -- on a quick read, I My question -- I'm just -- I'm not trying 23 to trick you or anything. I'm just trying to 24 understand. 25 entitled "Richard Lawrence Day," and do you know who Exhibit 9 is a document that is Peterson Reporting, Video & Litigation Services 107 Richard Lawrence, 11-17-14 1 2 prepared Exhibit 9? A I don't know who prepared it. I'm looking 3 at the document, and I assume Council President 4 Young's staff prepared it. 5 Q Okay. Are you aware that -- whether or not 6 this document has been submitted in the court papers 7 on -- 8 A I'm not aware -- I'm sorry. 9 Q -- with respect to this SDOG case that 10 11 12 13 we're here today about? A I'm not aware whether it's been submitted or not. Q Okay. This document lists a number of 14 achievements that you've accomplished during your 15 lifetime, and it also lists a number of 16 organizations that you're involved in. 17 18 19 20 21 22 Is there a reason that neither CREED nor SDOG are listed on Exhibit 9, that you're aware of? A I would -- I'm not aware of what reason there might be. Q Did you submit any biographical information to assist the City in preparing Exhibit 9? 23 A I believe I submitted my résumé. 24 Q And do you know whether or not your 25 involvement in CREED and SDOG are contained on your Peterson Reporting, Video & Litigation Services 108 Richard Lawrence, 11-17-14 1 résumé? 2 A I believe they are. 3 Q Okay. Were they -- were your involvement 4 in CREED and SDOG contained on your résumé at the 5 time that you submitted it to the City as you 6 previously testified? 7 8 9 A I don't know with certainty, but I would believe, yes, they were. Q Now, you testified earlier about the way 10 that SDOG was sort of a different type of 11 organization from your typical nonprofit. 12 Do you recall that line of testimony? 13 A I do. 14 Q Okay. And is it also your testimony that 15 CREED and SDOG are both that type of different 16 organization? 17 A Yes, I would say so. 18 Q Are there any differences between CREED and 19 SDOG in terms of their structure, to your knowledge? 20 MR. BRIGGS: Objection. Vague. 21 You can answer, if you know. 22 THE WITNESS: My experience would be that they 23 both operate very much the same way with a small board 24 and tend to take care of business on the spot and 25 entrust the implementation of actions in the one hand Peterson Reporting, Video & Litigation Services 109 Richard Lawrence, 11-17-14 1 around environmental issues and on the other around open 2 government to Briggs Law Corporation. 3 BY MS. PANCAKE: 4 Q Other than your testimony that one 5 organization, which is CREED, focuses on 6 environmental issues -- 7 A Yes. 8 Q -- and the SDOG focuses on open government 9 issues -- 10 A Correct. 11 Q -- are there any other differences between 12 13 14 15 16 the organizations in terms of how they operate? A mind at the moment. Q And have you been involved in both organizations for around the same time? 17 A 18 time. 19 Q 20 None that are striking enough to come to my I would say, yes, about the same amount of Which organization were you involved in first? 21 A I believe I was involved in CREED first. 22 Q Mr. Lawrence, I'm marking the next exhibit 23 as Exhibit 10. 24 (Exhibit 10 was marked.) 25 MS. PANCAKE: And it looks like -- I'm trying Peterson Reporting, Video & Litigation Services 110 Richard Lawrence, 11-17-14 1 to put the sticker in a location where there's no text. 2 Hang on a second. 3 BY MS. PANCAKE: 4 5 Q I think I've accomplished that. Can you take a look at Exhibit 10, Mr. Lawrence. 6 A Uh-huh. 7 Q Have you seen Exhibit 10 before? 8 A Well, certainly not as Exhibit 10, but I've 9 10 11 seen this story before. Q Right. A Yes. 13 Q Okay. 15 16 17 18 19 20 21 So this was a -- was this a newspaper story? 12 14 Okay. And it was published on or around May 27th, 2014? A According to this document it is. wouldn't know that, but it says so. Q I So... Is that consistent with your recollection of when this story came out? A I already said I'm terrible with dates, but I take the document's word for it. Q Okay. Can you turn to -- these pages are 22 not numbered, so I'm sorry, but it's the fifth page 23 of the article. 24 statement, "This is a carefully designed mechanism 25 by which we want to affect change." At the bottom of the page is the Peterson Reporting, Video & Litigation Services 111 Richard Lawrence, 11-17-14 1 A Uh-huh. 2 Q Do you see that? 3 A I do. 4 Q And is that a quote that was attributed to 5 you? 6 A Yes. 7 Q Is that quote accurate based on what you 8 told the reporter? 9 A I -- I think so. 10 Q In other words, you weren't misquoted? 11 A No. 12 Q Okay. 13 14 What do you mean by "a carefully designed mechanism"? A I mean that as I stated earlier, the 15 history of engagement in the civil rights movement 16 gave me a perspective which said that to accomplish 17 social change, we may have to use legal action 18 through the courts. 19 the impact of the courts is obvious. And in terms of desegregation, 20 And so when I look at the -- at CEQA, for 21 instance, it's obvious to me that it is a piece of 22 legislation that when really boosted by a citizen's 23 group attention and willingness to stick their chins out 24 to assure that it is implemented faithfully and fully, 25 that it is a mechanism that could have enormous impact. Peterson Reporting, Video & Litigation Services 112 Richard Lawrence, 11-17-14 1 Q Okay. And when you talk about it's a 2 carefully designed mechanism, you're talking about 3 the existence of CREED or the existence of SDOG; is 4 that accurate? 5 A That is accurate. 6 Q And the -- have you ever heard the term 7 responsible and equitable environmental development 8 before? 9 A Yes. 10 Q What does that mean to you? 11 A It means that it is not our prerogative to 12 stop development but that the development must be 13 done responsibly and that responsibly is defined by 14 CEQA, which requires it to be equitable and 15 sensitive to its impact on the quality of life. 16 17 18 19 Q And when you talk about the concept of development, what does that mean? A That is any activity obviously that results in physical changes -- 20 Q Meaning -- 21 A -- to the landscape. 22 Q I'm sorry. 23 finished? 24 A Sure. 25 Q And so that would be building, I interrupted you. Are you Peterson Reporting, Video & Litigation Services 113 Richard Lawrence, 11-17-14 1 construction? 2 in that? 3 A Any other concepts that are included Surely. There are issues of public 4 transportation, for instance, and an attempt to 5 reduce greenhouse gas emissions and carbon gas 6 emissions, you know, by increasing the use of public 7 transportation and decreasing the use of individual 8 vehicles. 9 a matter of concern. 10 So that the whole transportation issue is There is obviously also the use -- land use so 11 that hopefully we can really preserve some of the open 12 space that is so critical to a quality environment, 13 quality living environment. 14 Q What does this lawsuit, San Diegans For 15 Open Government versus City of San Diego and the 16 lawsuit related to the San Diego Tourism Marketing 17 District Corporation, what does this lawsuit have to 18 do with equitable environmental development as 19 you've just described it? 20 21 22 23 A In -- in this lawsuit you're talking about, the one in San Bernardino County. Q No, the lawsuit that you're here today testifying about. 24 MR. BRIGGS: 25 MS. PANCAKE: The TMD case. The TMD case. Peterson Reporting, Video & Litigation Services 114 Richard Lawrence, 11-17-14 1 2 MR. BRIGGS: She wants you to connect the dots for her for TMD. 3 THE WITNESS: I mentioned earlier that there is 4 a real concern that arose in me about affordable 5 housing. 6 aware, an extreme shortage of affordable housing that 7 has been captured as a state of emergency. 8 9 10 And there is in San Diego, as you're surely And the environment then that folks of lower income are required to endure is a really serious responsible development issue. 11 In addition, dislocation of residents and jobs 12 and their inability, other than by purchasing of an 13 automobile, if they can afford one, to close that gap 14 are also a significant part of that. 15 BY MS. PANCAKE: 16 Q 17 lawsuit? 18 What does CEQA have to do with this MR. BRIGGS: Objection. 19 conclusion. 20 have anybody suing under CEQA. It calls for a legal And I would note that this lawsuit does not 21 You can answer, if you know. 22 THE WITNESS: 23 24 25 I don't know. BY MS. PANCAKE: Q You don't know or do you believe -- do you believe that this lawsuit has anything to do with Peterson Reporting, Video & Litigation Services 115 Richard Lawrence, 11-17-14 1 CEQA? 2 A 3 4 I do. But that's not a legal opinion. Obviously I'm not a lawyer. Q Well, you're on the board of an 5 organization that is suing my client. 6 question to you is: 7 do with CEQA as you had previously testified what 8 CEQA was in your prior testimony? 9 So my What does this lawsuit have to MR. BRIGGS: Objection. Hang on. 10 getting argumentative. 11 this case. 12 what would be permissible in discovery. 13 weird fishing expedition. Now we're There isn't even a CEQA claim in So your question's even beyond the scope of 14 MS. PANCAKE: 15 MR. BRIGGS: You're on some Don't answer the question. I don't agree, but... Well, that's -- you don't have to 16 agree, but he's already answered the question once. 17 He's not going to answer it again. 18 case. 19 20 MS. PANCAKE: This isn't a CEQA Well, I understand that that's your position and that's your argument but -- 21 MR. BRIGGS: 22 MS. PANCAKE: Read the --- I'm not taking your 23 deposition. I'm taking the deposition of the -- of a 24 board member who's described to me what the terms 25 equitable environmental development means to him. Peterson Reporting, Video & Litigation Services 116 Richard Lawrence, 11-17-14 1 He included in that as a very prominent part of 2 his explanation issues describing CEQA matters. 3 asking the witness what does this lawsuit have to do 4 with what you testified earlier about CEQA matters? 5 MR. BRIGGS: It's beside the point. So I'm Outside 6 the scope of discovery. 7 could be asking him what he thinks about the, you know, 8 Sarbanes-Oxley. 9 either. 10 It's not a CEQA case. You This isn't a Sarbanes-Oxley case So it's just not even discoverable. MS. PANCAKE: You're -- Well, I dis- -- I disagree, 11 because the witness himself used CEQA as an indicia of 12 describing what equitable economic -- excuse me, 13 equitable environmental development meant to him. 14 that's the reason I'm using the term CEQA because the 15 witness testified about it. 16 MR. BRIGGS: So But he didn't say that this was a 17 CEQA case. 18 defined by the pleadings. 19 any CEQA questions and there aren't going to be any CEQA 20 answers. 21 Jenni. 22 And it's not a CEQA case. And the case is So there aren't going to be You don't even do depositions in CEQA cases, MS. PANCAKE: What does that have to do with 23 anything? Your Honor, I don't want to argue anymore. 24 Can I get a ruling on this? 25 HON. PATE: Why don't you rephrase and leave Peterson Reporting, Video & Litigation Services 117 Richard Lawrence, 11-17-14 1 out the word CEQA -- 2 MS. PANCAKE: 3 HON. PATE: -- and I think you can get the 4 information that way. 5 BY MS. PANCAKE: 6 7 Q Mr. Lawrence, what does this case have to do with environmental issues? 8 9 Okay. Okay. MR. BRIGGS: Objection. Calls for a legal conclusion. 10 You can answer, if you know. 11 THE WITNESS: From my perspective -- I think 12 I'm repeating myself, but from my perspective, 13 affordable housing and the diversion of possible sources 14 of public revenues to promote tourism rather than to 15 promote affordable housing constitute an environmental 16 issue because of the quality of housing and the quality 17 of the living environment that working families in this 18 community are subjected to by our failure to address a 19 state of emergency around affordable housing. 20 BY MS. PANCAKE: 21 Q Mr. Lawrence, what does this lawsuit have 22 to do with development as you previously described 23 what that term means to you? 24 MR. BRIGGS: 25 Same objection. Calls for a legal conclusion. Peterson Reporting, Video & Litigation Services 118 Richard Lawrence, 11-17-14 1 You can answer, if you know. 2 THE WITNESS: The development issue, so far as 3 I'm concerned, has to do with whether or not we spend 4 money that belongs to the public on promoting tourism or 5 we spend money building affordable housing. 6 kind of development are we going to use public resources 7 to pursue. 8 MS. BROCK: 9 MS. PANCAKE: 10 11 It's what Jenni, can I take a break? Sure. THE VIDEOGRAPHER: Off the record. The time is 1:41 p.m. 12 (A recess was taken.) 13 THE VIDEOGRAPHER: 14 time is 1:50 p.m. 15 BY MS. PANCAKE: Back on the record. The 16 Q Mr. Lawrence, we're back on the record. 17 A Yes. 18 Q And you understand that you are still under 19 oath? 20 A I do. 21 Q Okay. You testified earlier that Linda 22 Perine came to one of the SDOG meetings and 23 requested to the board that she wanted to be a 24 member. 25 Do you recall that testimony? Peterson Reporting, Video & Litigation Services 119 Richard Lawrence, 11-17-14 1 A I do. 2 Q Why did she want to be a member? 3 A I don't know. 4 Q Did she explain to the board why she wanted 5 6 to be a member? A No. She simply participated in the 7 discussion about the issues that were on our agenda 8 that day, but the board doesn't typically judge the 9 quality of a member's application. 10 The -- the general membership is pretty much open. 11 The general membership is pretty much open that 12 anybody says that they are interested in SanDOG. 13 real test, as I mentioned earlier, comes if someone is 14 wanting to go from the membership to the board of 15 directors. 16 17 18 Q The So would I be -- would I be able to join SDOG if I wanted to? A If you agreed -- if you attended a meeting, 19 participated in the issues that we were concerned 20 about in a -- well, as a member, I don't think you 21 even have to do that. 22 indicate that you wanted to be a member of SDOG and, 23 yes, you could be. 24 25 Q I think you could just How would I get to know about when the meetings are? Peterson Reporting, Video & Litigation Services 120 Richard Lawrence, 11-17-14 1 A Well, as I've indicated earlier, there 2 aren't general membership meetings. 3 board meetings. 4 them unless we change our practice, which is to 5 advertise the board meeting to the general 6 membership, which we generally don't do. 7 8 Q There are only So you wouldn't get to know about So there's really no way for me to participate in any SDOG meetings. 9 A Not -- not in the sense that there is a 10 membership meeting that you could come to and 11 contribute. 12 believe I indicated earlier, entertained individuals 13 at board meetings who express an interest on 14 something we're either currently on or something 15 that they think we might want to work on. 16 means they know enough to get ahold of one of the 17 board members or Briggs Law to find out when a 18 meeting was that they could attend. 19 Q 20 You can, obviously, and we have, as I But that When is the next meeting? MR. BRIGGS: I'm going to object. You're not 21 going to be invited to the meetings, and when we meet is 22 none of your business and it's outside the scope of 23 discovery and the witness is not going to answer the 24 question. 25 /// Peterson Reporting, Video & Litigation Services 121 Richard Lawrence, 11-17-14 1 BY MS. PANCAKE: 2 Q Are you going to follow your -- 3 A I am. 4 Q -- attorney's advice? 5 MS. PANCAKE: 6 HON. PATE: 7 MR. BRIGGS: Your Honor, can I get a ruling? I would overrule the objection. He's still not going to tell you 8 when our next meeting is. 9 BY MS. PANCAKE: 10 Q As you sit here today, is there a meeting 11 that's actually been planned where there's a date 12 that's been identified for the next meeting? 13 A No. 14 Q What were the issues that were being 15 16 17 18 discussed at the meeting where Linda Perine came? A I don't -- I don't remember the specific issues. Q Well, you testified I thought that you said 19 that she came and spoke about the issues that were 20 on your agenda at the same time that she requested 21 to be become a member. 22 A What was -- All I'm saying is I can't tell you what was 23 on any specific agenda that Linda Perine or anybody 24 else attended. 25 Q I just don't know. Well, what were the issues that she was Peterson Reporting, Video & Litigation Services 122 Richard Lawrence, 11-17-14 1 concerned about that she came and expressed to the 2 board as a reason for her wanting to become a member 3 of SDOG? 4 A I just have trouble identifying what 5 specifically she was advancing at the meeting. 6 just don't -- I just don't remember. 7 Q I You also testified before the break, 8 Mr. Lawrence, that you thought that the issue of 9 affordable housing was related to this lawsuit 10 because there has been a diversion of sources of 11 public revenue that should be better spent on 12 affordable housing. 13 words, but I'm trying to summarize the testimony 14 that you gave to kind of refresh your recollection 15 as to that testimony. 16 Do you recall that testimony? 17 A I do. 18 Q Okay. 19 I know that's not your exact What -- what public revenues do you believe are being diverted? 20 A Transient occupancy tax. 21 Q And other than transient occupancy tax, are 22 there any other public revenue diversions that 23 you're aware of? 24 A Not that I'm aware of. 25 Q Do you believe that the Tourism Marketing Peterson Reporting, Video & Litigation Services 123 Richard Lawrence, 11-17-14 1 District is taking general taxpayer revenue and 2 spending it on hotel marketing activities? 3 A Would you repeat the question? 4 Q Do you believe that there has been a 5 diversion of public revenues because the 6 Tourism Marketing District is taking general tax 7 dollars and spending it on hotel marketing 8 activities? 9 A I don't know if you would consider TOT to 10 be general tax dollars, but the funds do go into the 11 general fund. 12 diverting general tax dollars to promoting tourism. 13 Q So, yes, I would say, then, TMD is Do you believe that the money collected as 14 part of the Tourism Marketing District program comes 15 from any other sources other than TOT tax? 16 A I don't know if there are other sources. 17 Q Do you know whether or not any of the 18 moneys collected as part of the TMD program could be 19 redirected to other programs other than tourism 20 marketing activities? 21 A I don't know. 22 Q Do you know whether any revenues or any -- 23 any money collected by the 24 Tourism Marketing District program could be 25 redirected to affordable housing needs? Peterson Reporting, Video & Litigation Services 124 Richard Lawrence, 11-17-14 1 2 MR. BRIGGS: Objection. Vague and calls for a legal conclusion. 3 You can answer, if you know. 4 THE WITNESS: To the degree that -- that the -- 5 you know, that there is a cap on what you can raise from 6 tourism transient occupancy tax and in light of the fact 7 that twice in the city there were elections to try to 8 direct a portion of TOT to affordable housing that 9 failed because of the objections largely of hoteliers 10 and other tourism-related organizations, I understand 11 that TOT is a true diversion of what could be available 12 from -- from TOT to support affordable housing. 13 That was one of the purposes, including public 14 safety. 15 being a purpose for increasing TOT, the increase 16 occurred instead to support Tourism Marketing District. 17 BY MS. PANCAKE: 18 19 Q Despite public safety and affordable housing What is your understanding of what -- let me rephrase that. 20 What programs are funded by the TOT tax -- 21 MR. BRIGGS: 22 Objection. BY MS. PANCAKE: 23 Q -- based on your understanding? 24 A Off the top of my head, I don't know what 25 TOT supports. Peterson Reporting, Video & Litigation Services 125 Richard Lawrence, 11-17-14 1 Q Are there any other revenues that are 2 generated by the Tourism Marketing District other 3 than TOT taxes? 4 A I don't know. 5 Q Can we go back to Exhibit No. -- I think 6 it's Exhibit No. 10. 7 the front of the newspaper article? 8 A It's ten. 9 Q Exhibit 10? Can you check the number on 10 On the same page, in the second-to-last 11 paragraph, which also has quotes that you are attributed 12 with, it says that "At the group's monthly meetings, 13 Briggs brings forward possible suits from around 14 Southern California. 15 who have been in touch with Briggs and live near in the 16 development to create a subsidiary organization based in 17 that city. 18 files the lawsuits." 19 MR. BRIGGS: 20 21 paragraph. The group links up with citizens The local subsidiary of the San Diego group There's no quote in that You said there was a quote. MS. PANCAKE: Oh. I'm sorry. Then it -- I 22 don't know how to explain what this says. 23 "Lawrence said" -- I guess it's the reporter's report of 24 what you told him. 25 THE WITNESS: It says, Apparently. Peterson Reporting, Video & Litigation Services 126 Richard Lawrence, 11-17-14 1 BY MS. PANCAKE: 2 Q Do you understand that? 3 A Yes. 4 Q Is that paragraph accurate, from your 5 standpoint? 6 A Generally so. 7 Q Okay. 8 (Interruption in proceedings.) 9 MR. BRIGGS: 10 continue. It's a false, right? 11 MS. PANCAKE: 12 MR. BRIGGS: 13 to get outside. 14 15 16 17 I guess that means we can It's a false fire alarm. Fortunately we're close to a door Let's keep going. MS. PANCAKE: Let's go back. BY MS. PANCAKE: Q Do you believe that you were misquoted in any way in this paragraph? 18 A Not substantially so, no. 19 Q Okay. 20 21 22 23 Okay. What about this paragraph, if anything, is inaccurate? A Well, obviously I knew a little bit about development in Murrieta. Q Not nothing. Well, focusing on the part of the paragraph 24 that deals with the process by which the 25 organizations operate, is -- is it accurate to say Peterson Reporting, Video & Litigation Services 127 Richard Lawrence, 11-17-14 1 that your description of how cases are discovered is 2 equally applicable to how SDOG runs things? 3 MR. BRIGGS: Hang on. I'm going to object. 4 First of all, there are no organizations plural in this 5 paragraph. 6 referring to Citizens for Responsible Equitable 7 Environmental Development. 8 paragraph. 9 There's one organization. And it's So you're misquoting the The paragraph doesn't say anything about SDOG. 10 So to the extent you were perhaps -- well, I will assume 11 it was just an accident. 12 paragraph or mischaracterized the paragraph. 13 can answer, if you understand what she was getting at. 14 But you misquoted the But you I guess you're also assuming facts not in 15 evidence about subsidiary groups, among other things, 16 but you can answer if you know. 17 THE WITNESS: 18 again. 19 BY MS. PANCAKE: 20 Q 21 I'd have to hear the question Let me ask a different question. Does SDOG make its decisions of which lawsuits 22 to file in the same manner that's described in this 23 paragraph that describes the process that CREED 24 apparently goes through? 25 A The disagreement with that paragraph is Peterson Reporting, Video & Litigation Services 128 Richard Lawrence, 11-17-14 1 that the interest in possible lawsuits doesn't come 2 strictly from Briggs Law Corporation. 3 other organizations across California and who make 4 contact with us and want support in their taking up 5 a legal issue. 6 There are But substantially, yes, the -- the sensitivity 7 to where the organization's influence can be felt is 8 certainly greater with our -- with our legal consultants 9 than they are with any one of us individually who is on 10 11 the board. Q Since your involvement in SDOG, has there 12 ever been a lawsuit filed where the source of that 13 lawsuit was -- came from someone other than your 14 attorney? 15 16 MR. BRIGGS: source? 17 Objection. What do you mean by You mean the person who told him about it? MS. PANCAKE: Well, I'm trying to figure out a 18 way -- it says, "At the group's monthly meetings, Briggs 19 brings forward possible suits from around Southern 20 California." 21 MR. BRIGGS: 22 about a SanDOG meeting, right? 23 BY MS. PANCAKE: 24 25 Q You understand it's not talking But I'm trying to establish or what I'm trying to ask the witness is does SDOG's Peterson Reporting, Video & Litigation Services 129 Richard Lawrence, 11-17-14 1 decision-making with respect to where it gets its 2 lawsuits from differ from the process that is 3 described in this paragraph of Exhibit 10. 4 5 6 MR. BRIGGS: I guess I'm going to object on a couple grounds. Number 1, I, for the life of me, can't figure 7 out what the organization's decision-making process has 8 to do with this particular lawsuit. 9 whether the board voted to authorize this one or not, 10 11 If you want to ask that's fine. But in general, how the board thinks, I can't 12 figure out what that has to do with the price of tea in 13 China or with this case and how it would be 14 discoverable. 15 And second of all, if you buy the premise of 16 that paragraph, that I'm the one involved in it, it's 17 attorney-client privilege and I will instruct the 18 witness not to answer. 19 MS. PANCAKE: 20 HON. PATE: Your Honor, can I get a ruling? Well, the question was, as I 21 understood it, have you had the occasion where some 22 person other than the Briggs law firm, has brought a 23 legal -- an issue to the attention of SDOG or SanDOG, 24 depends on how you want to use the term, such that they 25 have gone ahead and filed a lawsuit. Peterson Reporting, Video & Litigation Services 130 Richard Lawrence, 11-17-14 1 2 MR. BRIGGS: question. 3 4 I wouldn't have objected to that HON. PATE: My understanding that was the essence of the question you've been trying to get to. 5 MS. PANCAKE: 6 HON. PATE: 7 MS. PANCAKE: 8 HON. PATE: 9 MR. BRIGGS: 10 13 Is that accurate? -- that's accurate. Can you answer that question, sir? Yeah. Basically do other people bring forward information other than my office? 11 12 That's -- THE WITNESS: No -- absolutely, yes. BY MS. PANCAKE: Q Okay. Well, the question that you just 14 answered that your attorney asked is a little bit 15 different. 16 brought to the organization by anyone other than 17 Mr. Briggs or his law firm? 18 A Has SDOG ever filed a lawsuit that was My difficulty at the moment is I've been 19 active in CREED and I've been active in SanDOG. And 20 at the moment I can't -- there was an organization 21 from Orange County that I recall very clearly coming 22 to us and wanting support on a lawsuit that we then 23 supported, but I don't know if that was a SanDOG 24 lawsuit. 25 details of whether it was with CREED or with SanDOG. And so it happens, but I can't remember Peterson Reporting, Video & Litigation Services 131 Richard Lawrence, 11-17-14 1 Q And why is it difficult for you to make 2 that distinction between whether it's a SanDOG or a 3 CREED? 4 A Because as I said, typically we have 5 meetings where the agenda for one organization and 6 the -- for both organizations are before us. 7 Q Do the agendas overlap? 8 A They don't overlap. 9 They're issues related to, as I've characterized them before, responsible 10 development, and then there is issues related to 11 open government. 12 kinds of issues at the same meeting. 13 Q And we often will deal with both You testified that there were other 14 organizations across California that come to you, 15 come to SDOG for assistance. 16 A Yes. 17 Q What organizations are those? 18 A Well, the one I can remember in particular 19 is an organization called OCCORD. And the reason I 20 remember OCCORD -- and it's Orange County Citizens 21 for Responsible Development, I think, is because it 22 is so close to an organization called ACCORD, which 23 is an organization I was involved in and I think 24 referred to earlier, in San Diego. 25 were hardly forgettable. So the two names Peterson Reporting, Video & Litigation Services 132 Richard Lawrence, 11-17-14 1 2 3 4 Q Is the OCCORD organization connected with Mr. Briggs? A Well, in -- to the sense that we participated jointly in a lawsuit with them, yes. 5 Q And "we," you don't know if it's SDOG or -- 6 A I do not. 7 Q -- it's CREED? 8 A I do not. 9 Q What does this case that we're here about 10 today have to do with open government? 11 A My position -- and this isn't a legal 12 opinion. 13 taxes are raised and then relegated to a special 14 group to dispose of, that is a violation of the 15 citizens' right to be able to hold their elected 16 officials accountable for revenues. 17 It's my position as a citizen is that when Because there's nothing in the world that 18 requires the corporation, TMD corporation, in this case, 19 from going what they do in the context of their right to 20 privacy. 21 Publicly, however, that's a different story. 22 Decisions have to be made in an open forum, and as a 23 consequence, there are clear issues of open government. 24 25 Q And what does this case have to do with governmental transparency, if anything? Peterson Reporting, Video & Litigation Services 133 Richard Lawrence, 11-17-14 1 A I'm not sure if it makes sense for me to 2 repeat myself or not, but what I just said was that 3 if the government allows revenues which are 4 effectively tax dollars to be diverted to a private 5 enterprise, then there is no way that the average 6 citizen has recourse. 7 Whereas if it remains in the public treasury, 8 there are laws with regard to open government that give 9 citizens access and influence over decisions about how 10 11 12 those revenues will be spent. Q I marked as Exhibit 11. 13 14 MR. BRIGGS: MS. PANCAKE: 19 20 And to Mr. Briggs. You can look at it too, Cory. 17 18 You will want to show it to Mr. Lawrence, I suspect. 15 16 Mr. Briggs, I'm showing you a document that (Exhibit 11 was marked.) BY MS. PANCAKE: Q Mr. Lawrence, I'm showing you a document that I've marked as Exhibit 11. 21 Have you ever seen this document before? 22 A I don't believe so. 23 Q Do you recognize what's portrayed on this 24 document? 25 A No. Peterson Reporting, Video & Litigation Services 134 Richard Lawrence, 11-17-14 1 Q All right. Well, I can represent to you 2 that this is a screen shot of the California 3 Secretary of State's business entity web page? 4 A Okay. 5 Q And the entity in question is San Diegans 6 For Open Government. 7 Do you believe that all of the information 8 contained on Exhibit 10 -- excuse me, Exhibit 11 is 9 accurate based on your independent knowledge? 10 MR. BRIGGS: I'm going to object. That calls 11 for speculation. 12 document before and doesn't know what it is. 13 BY MS. PANCAKE: 14 Q Okay. He just told you he's not seen the My question is not that. My 15 question is after looking at the document and seeing 16 the information that's contained on the business 17 entity detail, do you have a belief that the 18 information shown on this document is accurate? 19 A Are you referring to what's in this box? 20 Q Yes, I am. 21 A Well, I don't know if the entity number is 22 accurate. 23 was filed. 24 25 I have no knowledge of when this thing I believe San Diegans For Open Government were active in California. I don't know if the entity Peterson Reporting, Video & Litigation Services 135 Richard Lawrence, 11-17-14 1 address is correct. 2 I don't know what that agent for service of 3 process means. 4 sorry. 5 6 The entity city looks correct. Or the address there. That's the -- That's the law corporation's address. So, yes, those matters I do recognize. Q Okay. Do you know when, if at any time, 7 the entity address was changed to 4833 Santa Monica 8 Avenue, No. 7878, San Diego? 9 A I don't. 10 Q Do you have any knowledge of what the 11 office space, if any, looks like at this address? 12 A I don't. 13 Q Do you have any knowledge of whether or not 14 15 16 17 this address is just a P.O. Box? A Well, that jogs my memory. I think that may be an address for a P.O. Box we have. Q Did you participate in the decision to list 18 the entity address as a P.O. Box with the California 19 Secretary of State? 20 A No, I did not. I think I've said before 21 that in matters of caring for the corporate health 22 of the organization, we leave that to Briggs Law 23 Corporation. 24 25 Q Has the board abdicated all responsibilities for corporate health to Peterson Reporting, Video & Litigation Services 136 Richard Lawrence, 11-17-14 1 Mr. Briggs's law corporation? 2 MR. BRIGGS: I'm going to object. Not only 3 does the question call for a legal conclusion, it's 4 argumentative. 5 going to instruct the witness not to answer the 6 question. Nobody's abdicated anything, and I'm Nobody's abdicated anything, Jenni. 7 MS. PANCAKE: 8 HON. PATE: 9 I would overrule the objection and have the witness answer. 10 MR. BRIGGS: 11 question. 12 BY MS. PANCAKE: 13 Your Honor? Q Still not going to answer the Mr. Lawrence, has the board instructed 14 Mr. Briggs to take over all responsibilities for the 15 corporate organization? 16 MR. BRIGGS: That I'm going to object to on 17 attorney-client privilege grounds. 18 the content of the instruction, assuming it to be true, 19 which would be a confidential communication, and I 20 instruct the witness not to answer. 21 22 23 HON. PATE: You just supplied It would be sustained. BY MS. PANCAKE: Q Mr. Lawrence, has the board -- is the board 24 currently responsible for all matters of corporate 25 governance? Peterson Reporting, Video & Litigation Services 137 Richard Lawrence, 11-17-14 1 A Yes. 2 Q Did the board make a decision to change the 3 corporation's reporting -- excuse me, to change the 4 corporation's address as reported to the Secretary 5 of State? 6 A As I said earlier, the details of the 7 organization's status are left with Briggs Law 8 Corporation. 9 determination. 10 Q So, no, we did not make that What does the board -- how does the board 11 consider whether a matter is a detail which will be 12 handled by the law corporation and something that is 13 not a detail which the board would take 14 responsibility for? 15 16 17 18 A Typically it would require our being uneasy about something and questioning the matter. Q Okay. Can you give me an example? MR. BRIGGS: 19 just before? 20 the question. Hang on. Can you give me an example, please? Read I'm sorry. 21 (Question read.) 22 MR. BRIGGS: 23 (Answer read.) 24 MR. BRIGGS: 25 Can you ask the question And the answer was? Okay. I'm going to object on attorney-client privilege grounds. He's not going to Peterson Reporting, Video & Litigation Services 138 Richard Lawrence, 11-17-14 1 give you an example of something that he thinks my 2 office should be responsible for and something that 3 shouldn't be. 4 board, and I'm going to instruct the witness not to 5 answer. That would be between my client and the 6 MS. PANCAKE: 7 HON. PATE: 8 MR. BRIGGS: Okay. He's not going to answer the question. 11 THE WITNESS: 12 advice. 13 BY MS. PANCAKE: 14 I would overrule the objection and have the witness answer. 9 10 Your Honor? Q I will follow my attorney's Mr. Lawrence, what matters of corporate 15 organization or corporate governance have not been 16 delegated to the law firm to handle on behalf of the 17 board? 18 MR. BRIGGS: Objection. 19 "corporate governance." 20 BY MS. PANCAKE: 21 Q Vague as to the term Do you understand the question, sir? 22 MR. BRIGGS: 23 THE WITNESS: You can answer, if you understand. I believe I do. I think we've 24 entrusted the -- totally the responsibility with our 25 attorney. Peterson Reporting, Video & Litigation Services 139 Richard Lawrence, 11-17-14 1 BY MS. PANCAKE: 2 Q Responsibility for what? 3 A Taking care of the documents and filings 4 required to keep the corporation in good standing 5 with the Secretary of State's office. 6 Q Okay. Other than what you have just 7 testified about of handling the documents and 8 filings with the Secretary of State's office, what 9 responsibilities does the corporation still have for 10 matters relating to the corporation? 11 MR. BRIGGS: Objection. It calls for a legal 12 conclusion, and it's vague, and you're not allowed the 13 ask questions like that in depositions where you're 14 expecting the witness to list every single thing that he 15 can remember. 16 17 You can answer to the extent you know what she's getting at. 18 THE WITNESS: 19 think I have anything to offer. 20 BY MS. PANCAKE: 21 Q I don't -- I don't -- I don't I don't know. Maybe I need to ask it in a different way. 22 Does the board have any responsibility or does the 23 board take any responsibility for corporate matters? 24 25 MR. BRIGGS: Objection. Vague and calls for a legal conclusion. Peterson Reporting, Video & Litigation Services 140 Richard Lawrence, 11-17-14 1 2 3 4 You can answer, if you know what she means. BY MS. PANCAKE: Q Sir, you're listed as the CEO of the corporation. 5 A Which corporation are you talking about? 6 Q San Diegans For Open Government. 7 MR. BRIGGS: I think she's referring you to 8 this exhibit here, which I think he told you was a typo, 9 but I think she's referring you to that. 10 THE WITNESS: I did indicate that I believed 11 that this listing of me as the chief executive officer 12 or chairman and Pedro Quiroz as the secretary was a 13 mistake. 14 BY MS. PANCAKE: 15 Q I am the secretary. Okay. Pedro is the Chair. But you have participated as a 16 member of the board of directors for quite some 17 time, correct? 18 A Yes, of course. 19 Q And so my question is, what 20 responsibilities does the board of directors take 21 for corporate affairs? 22 A We trust that any issue that requires the 23 board's attention will be brought forward by our 24 attorney. 25 When I said we were a different organization, Peterson Reporting, Video & Litigation Services 141 Richard Lawrence, 11-17-14 1 that's part of the difference I'm talking about. 2 intend for the organization to focus its energy and 3 resources on the issues at hand, and the details of 4 keeping us healthy as far as legal filings and 5 operations are concerned are left with our attorney. 6 We We don't have any competition among us to be 7 one of the officers or to throw somebody out or to -- so 8 that the organization runs, as I mentioned before, with 9 real trust and -- and harmony, and so we don't have to 10 worry about changes in the bylaws or technical changes 11 in our address or issues of that sort. 12 13 14 If there is an issue that affects us, we believe we'll hear about it and we'll deal with it. Q When you say that if there's an issue that 15 affects us you believe that you will hear about it, 16 is it your expectation that you would hear about it 17 from anyone other than Mr. Briggs or his office? 18 A We certainly would count on Attorney Briggs 19 as a primary source, but clearly if there's a 20 problem that reaches the realm of being a public 21 issue, whether it's with the Secretary of State or 22 Finance Tax Board or whomever, that we would hear 23 about those. 24 else we would -- we would know of problems we're 25 facing. But otherwise, I -- I don't know where Peterson Reporting, Video & Litigation Services 142 Richard Lawrence, 11-17-14 1 Q Historically, have you heard about any 2 issues that affect SDOG from anyone other than 3 Mr. Briggs or his office? 4 A I have not. 5 Q Who is the current treasurer of SDOG? 6 MR. BRIGGS: 7 You can answer again, if you want. 8 THE WITNESS: 9 Asked and answered. I just saw her name. As I said earlier, I know it's -- the first name is Karin, and I 10 still have trouble remembering her last name. 11 not usually attend board meetings. 12 BY MS. PANCAKE: She does 13 Q Does the name Karin Langwasser -- 14 A Yes. 15 Q -- sound like the name of the person who's 16 designated as the corporate treasurer? 17 A That is -- that is familiar, yes. 18 Q Have you ever met Ms. Langwasser in person? 19 A Yes. 20 Q On how many occasions? 21 A Two or three. 22 Q And when was the last time that you met 23 with her? 24 A Last year. 25 Q Was it in relation to an SDOG matter? I don't remember the occasion. Peterson Reporting, Video & Litigation Services 143 Richard Lawrence, 11-17-14 1 A No. 2 Q Where was the meeting? 3 A At Mr. Briggs's home. 4 Q Was Mr. Quiroz there? 5 A I believe so. 6 Q At that meeting? 7 A Yes. 8 Q Was Mrs. Quiroz there? 9 A Yes, I believe so. 10 Q Was Mr. Cunamay there? 11 A I -- as I say, I don't know -- I don't know 12 It was a social gathering. who Mr. Cunamay is. 13 Q Was Ms. Perine there? 14 A I believe so. 15 Q What was the occasion of the meeting? 16 A I don't recall. 17 Q Have you ever spoke to Ms. Langwasser on 18 19 20 21 22 the phone? A No. MS. PANCAKE: We can take a break right now so you can change your tape. THE VIDEOGRAPHER: This ends Media No. 2 in the 23 deposition of Richard Lawrence. 24 is 2:29 p.m. 25 The time off the record (Recess taken.) Peterson Reporting, Video & Litigation Services 144 Richard Lawrence, 11-17-14 1 THE VIDEOGRAPHER: 2 the deposition of Richard Lawrence. 3 record is 2:34 p.m. 4 BY MS. PANCAKE: 5 6 Q This begins Media No. 3 in The time on the Mr. Lawrence, we're back on the record. You realize you're still under oath? 7 A Yes. 8 Q You testified about a social gathering at 9 10 Mr. Briggs's house. Was that also the occasion of an SDOG meeting? 11 A No. 12 Q Has Karin Langwasser ever attended an SDOG 13 14 meeting where you've attended also? A Not where I was present, no. And I think 15 you maybe understand that the reason for that is the 16 treasurer, we don't have any funds. 17 treasurer doesn't have any reports to make. 18 don't intend to get any funds. 19 as simply and cleanly as possible. 20 21 22 Q So the We We want to operate Why doesn't the organization want to get any funds? A Because there's -- we don't need funds to 23 do what it is we're trying to accomplish. We 24 currently are able to function essentially as a zero 25 budget organization, and there's nothing better in Peterson Reporting, Video & Litigation Services 145 Richard Lawrence, 11-17-14 1 my mind, having a long history of working with 2 nonprofits that have had to raise money, often at 3 the expense of being able to do the job they were 4 intending to do than having the capacity to have an 5 effect on what we think is the spectrum of issues 6 around justice and not raise money to do so. 7 because of the support of Briggs Law. 8 Q 9 Law"? 10 A Partly What do you mean by "the support of Briggs Well, as I had mentioned earlier, Cory and 11 his colleagues take leadership for us on assuring 12 that whatever fees are needed in order to advance 13 lawsuits are advanced. 14 or his law firm to get that done. 15 obviously an issue of whether you win the lawsuit 16 and collect the expenses at the end. 17 18 19 20 21 22 23 Q And we don't have to pay him They become When you say "you," you mean SDOG collecting the -A No. Whether it's -- sorry. "You" being Cory collects the expenses at the end. Q So why do you believe that raising funds would impact the function or the message of SDOG? A There isn't really a short answer to that, 24 but as I've said, there are lots of nonprofit 25 organizations with which I have been associated. Peterson Reporting, Video & Litigation Services 146 Richard Lawrence, 11-17-14 1 And it is a real pleasure, as somebody who cares 2 about the issues we've been discussing, to be able 3 to see energy spent on the mission for which we're 4 organized as opposed to having to divert that energy 5 to other purposes, like raising money. 6 And lots of nonprofits have gone out of 7 business because they've had to raise money, and I don't 8 think that's any surprise to anybody. 9 do so is a enormous benefit. 10 Q So not having to So you testified that money -- money being 11 spent on your mission, what money is spent on your 12 mission? 13 A 14 15 16 17 If I said spending money on my mission, on our mission, then I made a mistake. Q Okay. I -- and I'm trying to just understand what you -A I said that -- I thought I said that 18 instead of raising money, the energy that would 19 ordinarily go to that task was devoted to carrying 20 out our mission. 21 Q And other -- other than funds that are 22 given to the organization by Mr. Briggs and the 23 funds that you testified earlier were contributed to 24 the organization by Mr. Trowbridge, who else spends 25 money on the SDOG organization? Peterson Reporting, Video & Litigation Services 147 Richard Lawrence, 11-17-14 1 MR. BRIGGS: Objection. He never said that I 2 gave money to the organization. 3 words in his mouth. 4 And/or assuming facts not in evidence. 5 that I give money. 6 BY MS. PANCAKE: 7 8 9 Q So please don't put You are misstating testimony. He never said Mr. Lawrence, does Mr. Briggs or his office spend money on behalf of SDOG? A On behalf of SDOG, yes. Do they give SDOG 10 money as an organization in our treasury? 11 don't have a -- we don't have a dime in the 12 treasury. 13 treasury. 14 Q 15 treasury? 16 A 17 treasury. 18 the -- with the sweat that Briggs Law is willing to 19 put into the cases we think are important. 20 21 22 Q No. We We don't want to have a dime in the Why don't you want to have a dime in the Because we don't need to have a dime in the We can advance our work currently with So if there was a liability that SDOG incurred, how would that get paid for? A I think I indicated earlier that we know 23 that there may come a point where we no longer enjoy 24 the tremendous luxury we enjoy now of not having to 25 raise money. So it is possible that at some point Peterson Reporting, Video & Litigation Services 148 Richard Lawrence, 11-17-14 1 we may have to do it as a board. 2 current arrangement, we don't. 3 benefit to us as individuals and to the cause we're 4 trying to advance. 5 Q But now, in the And it is a terrific What would the circumstances have to be for 6 the board to have to raise money to pay for 7 liability? 8 9 MR. BRIGGS: I'm going to object. outside the scope of discovery. This is It also is a 10 hypothetical. How the board raises money for some 11 future liability has nothing to do with its standing or 12 capacity to sue. 13 of discovery. This is completely outside the scope 14 MS. PANCAKE: 15 HON. PATE: 16 17 18 Q Mr. Lawrence, are you aware of whether or not there are any judgments against SDOG? A 20 SDOG. 21 Q I have not heard of any judgments against Is that something that you would rely on your attorneys to advise you about? 23 A Absolutely. 24 Q Okay. 25 Sustained. BY MS. PANCAKE: 19 22 Your Honor? Have you heard of any sanctions orders that are -- that have been made against SDOG? Peterson Reporting, Video & Litigation Services 149 Richard Lawrence, 11-17-14 1 MR. BRIGGS: I'm going to object. He just told 2 you he relies on his attorney for this sort of thing. 3 So you're now invading on the attorney-client privilege 4 realm. 5 MS. PANCAKE: 6 MR. BRIGGS: 7 MS. PANCAKE: 8 MR. BRIGGS: 9 please. 10 Now actually -Secondly --- I'm not. -- let me finish my objection, Yeah, you are. Secondly, this is not a debtor exam. How they 11 raise money for some future thing has nothing to do with 12 this lawsuit or anything remotely related to this 13 lawsuit. 14 You may have a sanctions order. It's not of an 15 amount that's immediately appealable. You do not have a 16 judgment. 17 pursue the money, that you could pursue it in accordance 18 with the judgment collection procedures in the Code of 19 Civil Procedure, and every time you've asked an officer 20 of this organization the same question, every discovery 21 referee has sustained the objection. Judge Wohlfeil told you if you wanted to 22 You are wasting time. 23 the witness not to answer the question. 24 MS. PANCAKE: 25 MR. BRIGGS: I'm going to instruct I disagree -You're fishing. Peterson Reporting, Video & Litigation Services 150 Richard Lawrence, 11-17-14 1 MS. PANCAKE: -- with your -- Cory, you know 2 what? 3 as I am not harassing the witness. 4 harassing him. 5 Discovery is about fishing. I can fish as long And I'm not He has testified that the organization is 6 crafted in a way whereby they do not have any money, and 7 I'm asking him legitimate questions that he, as a member 8 of the board and as a member of somebody who is listed 9 as the point person, the CEO of the organization with 10 respect to state regulators, that he may have a concern 11 about, because I believe that the State would go to him 12 for any irregularities and not you. 13 MR. BRIGGS: 14 MS. PANCAKE: 15 Well, the State -Listen. Just a minute. Let me finish my -- my discussion. 16 I understand this is not a judgment debtor 17 exam. 18 that with respect to the defenses that we've raised, 19 which are -- include not only a standing but the alter 20 ego and the ultra vires defenses, I'm entitled to find 21 out what this board member knows or doesn't know about 22 how the board deals with liabilities. 23 I do not pretend that it is. But I do believe I asked him whether or not he was aware of any 24 judgments. He said he was not and that that was 25 something that he would expect you, as his lawyer, to Peterson Reporting, Video & Litigation Services 151 Richard Lawrence, 11-17-14 1 advise him about. I am now asking him about whether he 2 is aware of any sanctions orders. 3 MR. BRIGGS: Okay. 4 MS. PANCAKE: And so I believe that this is a 5 legitimate issue that a board member of an organization 6 would want to know about. 7 MR. BRIGGS: Well, it -- maybe it would be, but 8 we're suing over the TMD tax. 9 Nobody has asserted a claim against SanDOG. SanDOG is not being sued. It is the 10 plaintiff. 11 entirely beside the point. 12 actually gave those legal materials to Judge Pate. 13 sure you just gave him your version of the story, not 14 what we've given to prior referees. 15 Your ultra vires, alter ego arguments are I would be surprised if you In any event, it doesn't matter. I'm You're making 16 my point. You're asking him questions about what an 17 officer or board member would like to know under 18 hypothetical circumstances that have nothing to do with 19 whether this tax should have gone to the voters and 20 whether SanDOG has standing. 21 MS. PANCAKE: 22 HON. PATE: Your Honor, can we get a ruling? Now, you both raise interesting 23 points. 24 It seems to be pretty far afield. 25 I really don't see how this goes to standing. This is, however, California. Fishing is Peterson Reporting, Video & Litigation Services 152 Richard Lawrence, 11-17-14 1 encouraged, not only permitted but it is encouraged. 2 I'm usually pretty liberal where I allow people to go. 3 I think you can ask him is he aware of any sanction 4 orders, but I don't see it going beyond that. 5 BY MS. PANCAKE: 6 7 Q Are you aware, sir, of whether or not SDOG has been sanctioned by the court monetarily? 8 A I am not aware of any sanctions. 9 Q And it's your testimony that SDOG has no 10 current money available to pay for any sanctions 11 orders? 12 MR. BRIGGS: I'm going to object. You just 13 went beyond what the judge said you could ask. 14 not asking judgment debtor questions. 15 to ask about their money. 16 this case, Jenni. 17 It has nothing to do with You're all done with this topic. HON. PATE: I will sustain the objection. on to something a little bit more fruitful. 19 BY MS. PANCAKE: Q You're You're not going 18 20 So Move Since you've been involved on the SDOG 21 board, Mr. Lawrence, has SDOG ever received any 22 other -- any revenue from settlement of one of its 23 lawsuits? 24 A No. 25 Q Has SDOG ever authorized settlement money Peterson Reporting, Video & Litigation Services 153 Richard Lawrence, 11-17-14 1 to be paid directly to Karin Langwasser? 2 A No. 3 Q Mr. Lawrence, I'm showing you a document 4 that I've marked as Exhibit 12. 5 6 (Exhibit 12 was marked.) BY MS. PANCAKE: 7 Q Have you seen Exhibit 12 before? 8 A No. 9 Q Have you ever seen any settlement checks 10 that have been issued relating to SDOG lawsuits? 11 A I don't believe so. 12 Q Are you aware of whether or not the board 13 has authorized settlement money to be paid to 14 Karin Langwasser? 15 16 17 A I'm not aware of any such authorization, and I'm sure I would be aware if such had occurred. Q Do you know whether money -- money coming 18 from the settlement of an SDOG lawsuit has, in fact, 19 been paid to Karin Langwasser? 20 A I do not. 21 Q Are you aware of whether or not money 22 coming from the settlement of an SDOG lawsuit has 23 been paid to anyone other than SDOG? 24 25 MR. BRIGGS: Can you read that question, please. Peterson Reporting, Video & Litigation Services 154 Richard Lawrence, 11-17-14 1 (The pending question was read.) 2 MR. BRIGGS: 3 Vague. Are you including me in the term SDOG or are you -- 4 MS. PANCAKE: 5 MR. BRIGGS: 6 Objection. No, I'm not. -- or are you talking about the organization? 7 MS. PANCAKE: 8 MR. BRIGGS: No, the organization itself. So the question is, is the witness 9 aware -- is the witness aware of money paid to settle an 10 SDOG lawsuit that went only to the organization and not 11 to anybody else? 12 BY MS. PANCAKE: 13 Q 14 15 16 Is that -- My question is -MR. BRIGGS: Is that what you're getting -- BY MS. PANCAKE: Q -- are you aware of whether or not money 17 coming from the settlement of an SDOG lawsuit gets 18 paid to anyone other than SDOG, the entity? 19 MR. BRIGGS: 20 THE WITNESS: I think you can answer that. I'm not aware of any settlement 21 money being paid to SDOG. 22 BY MS. PANCAKE: 23 Q Are you aware of where the settlement money 24 gets paid in the -- when historically there have 25 been SDOG settlements? Peterson Reporting, Video & Litigation Services 155 Richard Lawrence, 11-17-14 1 MR. BRIGGS: Let me just also object for the 2 record here. 3 make it sound like the settlement was exchanging money 4 for a release, like happens in personal-injury cases. 5 If that's what you're suggesting, I'm going to object 6 that the term is vague and ambiguous. 7 When you talk about settlement moneys, you If you're talking about reimbursement of 8 attorneys' fees and you just mean that as part of the 9 settlement, that's fine. 10 11 If you understand what she's getting at, you're free to answer the question. 12 THE WITNESS: I'm not sure I do understand. 13 Because I have said, again and again, that SDOG is an 14 organization that doesn't have any money, has never had 15 any money, and therefore, payment to SDOG is not an 16 issue. 17 BY MS. PANCAKE: 18 19 Q I've never -- I know of no such payments. Since the time that you've been involved with the board, has SDOG settled any lawsuits? 20 A Yes. 21 Q And how are those settlements structured 22 with respect to any moneys that would be payable as 23 a result of the settlement? 24 25 A I don't know the particulars of any of the settlements, but I will repeat that none of that Peterson Reporting, Video & Litigation Services 156 Richard Lawrence, 11-17-14 1 money went to SDOG. 2 have no funds in our treasury. 3 4 Q Obvious by the fact that we Are you aware of whether or not any moneys have been paid at all -- 5 A I know -- 6 Q -- with the settlement of SDOG cases? 7 A I know there have been settlement of SDOG 8 cases and funds have been paid for attorneys' fees 9 and expenses. 10 Q And who do those funds get paid to? 11 A I assume to the Briggs Law Corporation. 12 Q And other than the Briggs Law Corporation, 13 has any member of SDOG ever received any funds from 14 the settlement of a lawsuit? 15 A Not that I know of. 16 Q Do you know if SDOG has a retainer 17 agreement with Mr. Briggs' Law Corporation for the 18 representation of SDOG in connection with this 19 lawsuit? 20 A I don't know. 21 Q Did you, as a board member, authorize the 22 retention of Mr. Briggs for the filing of this 23 lawsuit? 24 A 25 When it comes specifically to this lawsuit, I guess the answer is no, but we retained Briggs Law Peterson Reporting, Video & Litigation Services 157 Richard Lawrence, 11-17-14 1 Corporation to pursue such cases. I don't know that 2 there was an individual action. 3 retainer was general, not particular to this 4 particular case. I think the 5 Q Is there a written document? 6 A I believe so. 7 Q And when was that entered into? 8 A I don't know. 9 Q Was it preexisting your involvement with 10 the SDOG board? 11 A I believe so. 12 Q Since your involvement on the SDOG board, 13 has the board ever specifically entered into an 14 agreement retaining Mr. Briggs? 15 A No. We've had a continuing relationship 16 that, as I said, I believe was covered by an earlier 17 agreement. 18 19 20 Q Does SDOG undertake any other activities other than filing lawsuits? A Well, there are issues that come up in the 21 business of the City that we attempt to address one 22 way or another prior to legal action and letters 23 that we may address to council members or to the 24 mayor's office or to the redevelopment agency or 25 what have you. Peterson Reporting, Video & Litigation Services 158 Richard Lawrence, 11-17-14 1 And obviously there are appearances at City 2 Council where we express our opinion about issues that 3 come up. 4 it's been individual members of SDOG who have actually 5 appeared before the council. 6 the other activities that I can recollect. 7 Q I'm not sure if we've done that as SDOG or if But that's, in general, Do the issues that are the basis for the 8 letters that could be sent or the appearances that 9 could be made, are they different than what the 10 11 issues are in a lawsuit that ultimately gets filed? A They could be. And there are cases 12 obviously where an issue may be raised. 13 be -- I don't know if technically it's a settlement 14 conference or not, but a conference between the 15 organization and the -- between SanDOG and the City 16 about that issue that gets the matter resolved. 17 Q There may Based on your experience, historically what 18 issues have been different from -- excuse me. 19 issues that were raised in letters or appearances 20 have been different than issues contained in a 21 lawsuit filed by SDOG? 22 A I don't remember particular examples of 23 this matter. 24 you, but I don't have them in my head. 25 Q What I'm sure we could dig them out for I'm going to ask the court reporter to Peterson Reporting, Video & Litigation Services 159 Richard Lawrence, 11-17-14 1 leave a space in the deposition transcript, and sir, 2 when you go back and review it, if your review of 3 the transcript refreshes your recollection as to 4 what issues there are that differ in any way from 5 those underlying any lawsuits that SDOG has filed, I 6 would appreciate if you could fill that in for me? 7 8 MR. BRIGGS: And what if he can't remember? What is he going to put on the line? 9 MS. PANCAKE: Then he just leaves it blank. 10 THE WITNESS: Okay. 11 MR. BRIGGS: 12 THE WITNESS: 13 (Requested Information: _ Okay. I will be glad to do that. _ 14 15 16 17 18 19 .) BY MS. PANCAKE: Q information? A 20 21 Where would you go to dig out the To Briggs Law Corporation. MR. BRIGGS: Just as a reminder, we turn into pumpkins in 45 minutes. 22 MS. PANCAKE: 23 (Exhibit 13 was marked.) 24 25 We are on No. 13. BY MS. PANCAKE: Q I'm good to show you a document that I've Peterson Reporting, Video & Litigation Services 160 Richard Lawrence, 11-17-14 1 marked as Exhibit 13, Mr. Lawrence. 2 3 Mr. Lawrence, have you seen Exhibit 13 before today? 4 A No. 5 Q Do you know what Exhibit 13 is? 6 A No. 7 Q Okay. Well, if I represented to you that 8 it's a postcard tax return that was submitted on 9 behalf of SDOG for the 2013 tax year, are you aware 10 that you were listed as the contact person for the 11 dealings with the Franchise Tax Board? 12 A 13 No. Not having seen it, I wasn't aware. MR. BRIGGS: I think that also misstates what 14 is stated in this document. 15 BY MS. PANCAKE: 16 17 Q Okay. Do you see where you're listed as the contact person? 18 A Yes. 19 Q And the telephone number (909)949-7115, is 20 that your telephone number? 21 A No. 22 Q Do you know whose telephone number that is? 23 A That's the law office, I think. 24 Q Is the address listed for the principal 25 officer's information, is that also the address of Peterson Reporting, Video & Litigation Services 161 Richard Lawrence, 11-17-14 1 the law office? 2 A Yes. 3 Q Did you give your permission to be listed 4 as the contact person for the Franchise Tax Board on 5 behalf of SDOG? 6 A Not specifically, but I obviously 7 authorized the office to use my name in those cases 8 and places where the secretary's signature would be 9 expected. 10 So I'm guessing this is use of that general authorization. 11 Q And you mean -- are you talking about 12 secretary of SDOG or Secretary of State where you 13 have -- 14 A Secretary of SDOG. As the secretary, 15 typically I assume that there are numbers of forms 16 where the secretary's signature or in this case I 17 don't know whether it required my signature or not, 18 but a name is required. 19 authorization, obviously, where those occasions 20 present themselves to go ahead and submit. 21 Q 22 your name? 23 And the law firm has the Did -- did you authorize anyone to sign MR. BRIGGS: 24 your question? 25 /// I'm going to -- were you done with Peterson Reporting, Video & Litigation Services 162 Richard Lawrence, 11-17-14 1 BY MS. PANCAKE: 2 3 Q Have you ever authorized anyone to sign your name for -- 4 5 MR. BRIGGS: BY MS. PANCAKE: 6 Q 7 filings? -- for purposes of Franchise Tax Board 8 9 10 Hang on. MR. BRIGGS: Sorry. Can you read the full question? I think I cut her off and may have screwed things up. 11 (The pending question was read.) 12 MR. BRIGGS: Are you -- so I'm going to object 13 on attorney-client privilege grounds. 14 which would include lawyers. 15 lawyers, I'm going to instruct the witness not to 16 answer. 17 your question supplies the content of the communication. 18 I am instructing him not to answer unless you rephrase 19 it. 20 21 22 You said anyone, If you meant it to include If you want to rephrase it, that's fine, but HON. PATE: I also sustain the objection. BY MS. PANCAKE: Q Mr. Lawrence, have you ever authorized 23 anyone somebody from Mr. Briggs' office or 24 Mr. Briggs himself to sign your name to any 25 documents related to the Franchise Tax Board and Peterson Reporting, Video & Litigation Services 163 Richard Lawrence, 11-17-14 1 SDOG? 2 A No, I haven't. 3 Q Are you aware of whether or not anyone has 4 ever signed your name on any Franchise Tax Board 5 documents? 6 A Not specifically, no. 7 Q Are you aware of the allegations that have 8 been made in this lawsuit? 9 A I'm not sure what you mean by allegations. 10 Q What is the issue that this lawsuit is 11 about? 12 13 MR. BRIGGS: Objection. Calls for a legal conclusion. 14 If you understand, you can tell them. 15 THE WITNESS: From my perspective, this lawsuit 16 has to do with whether or not funds raised effectively 17 as taxes can be relegated to a private corporation and 18 used at their direction. 19 BY MS. PANCAKE: 20 Q Is it your understanding that the San Diego 21 Tourism Marketing District Corporation is a private 22 corporation? 23 A Yes. 24 Q Did you participate in any vote to file the 25 lawsuit in this case amongst the SDOG board members? Peterson Reporting, Video & Litigation Services 164 Richard Lawrence, 11-17-14 1 A Again, I have to say as far as votes are 2 concerned, we rarely, if ever, vote, but, yes, there 3 was a consensus to pursue this lawsuit. 4 5 6 7 8 Q And who amongst the board members participated in the consensus? A I'm not fully sure, but I'm fairly sure that it was Pedro Quiroz and I. Q Do you know that you were identified as an 9 SDOG member who could potentially confer standing 10 upon SDOG in order for SDOG to be able to maintain 11 this lawsuit? 12 A Yes. 13 Q When did you first become aware of the fact 14 that you were identified as a member who could 15 potentially confer standing upon SDOG? 16 A I don't know. This matter has been on our 17 agenda for months, and someplace over that time, 18 that issue came up. 19 20 21 Q When did you first become aware that SDOG was going to file this lawsuit? A Again, I don't know specifically a date or 22 time that we determined that we were going to pursue 23 this case. 24 Q 25 Do you know if it was before or after the death of Mr. Trowbridge? Peterson Reporting, Video & Litigation Services 165 Richard Lawrence, 11-17-14 1 2 MR. BRIGGS: Objection. Vague. Why don't you give him the date of Ian Trowbridge's death. 3 MS. PANCAKE: You know what? I'm not going to 4 do that. 5 of Mr. Trowbridge as a milestone and are you aware of 6 whether or not the lawsuit was filed before or after his 7 death? 8 9 10 I'm going to ask the witness to use the death THE WITNESS: I guess I don't know. And it would be irresponsible to guess on the matter. BY MS. PANCAKE: 11 Q Do you have an estimate? 12 A I'd say my estimate would be that it was 13 14 filed before his death. Q Okay. Was the first time that you heard 15 that you, as an individual, were going to be listed 16 as one of the members who could potentially confer 17 standing on SDOG, was that before or after 18 Mr. Trowbridge's death? 19 A I think that was after. 20 Q Was the time that you first became aware 21 that SDOG was going to file this lawsuit before or 22 after Linda Perine came to the member meeting that 23 you described? 24 A Before. 25 Q So the decision to file was before she came Peterson Reporting, Video & Litigation Services 166 Richard Lawrence, 11-17-14 1 to the meeting? 2 A Yes. 3 Q And was the decision to file, was it -- how 4 long after the decision to file the lawsuit did the 5 lawsuit actually get filed? 6 MR. BRIGGS: Objection. Vague. He doesn't 7 even know when the lawsuit was filed because you 8 wouldn't give him any of those dates. 9 MS. PANCAKE: Well, I understand that we don't 10 have an exact date, but I'm trying to place in time 11 different milestones that we could be able to determine 12 when the lawsuit was filed. 13 MR. BRIGGS: But we do have an exact date. 14 You've got the pleading right there that has the filing 15 date on it, Jenni. 16 instead of trying to trick the guy. 17 18 19 Why don't you tell him the date MS. PANCAKE: This is not -- this is not -- this date on this says 8/22/2014. MR. BRIGGS: It says action filed right below 20 the caption, December something of 2012. 21 just give the guy the date instead of trying to play 22 games with him. 23 MS. PANCAKE: Okay. Why don't you The documents that I have 24 on my side of the table are not -- I'm asking the 25 questions here, and I am not going to give the witness a Peterson Reporting, Video & Litigation Services 167 Richard Lawrence, 11-17-14 1 specific date. 2 witness knows and if he is able to determine how long 3 after the board decided that it was going to file this 4 lawsuit did the lawsuit actually get filed. 5 I am trying to find out what this I don't think knowing the exact date is going 6 to help him. 7 how long after the board decided to file the lawsuit do 8 you know when the lawsuit actually got filed. 9 10 I want to find out from him if he knows MR. BRIGGS: So you're going to play hide the ball and make the guy guess. 11 MS. PANCAKE: I'm not -- Cory, let me ask the 12 questions to the witness. 13 date. 14 own when it's your turn to ask questions, you may ask 15 your own witness questions. 16 I do not have to give him a If you want to ask the witness questions on your Right now, I am asking the witness if he knows 17 approximately how long after the decision to file did 18 the lawsuit actually get filed. 19 MR. BRIGGS: Does the witness understand that 20 if you want to a precise date, you're entitled to ask 21 her to give it to you? 22 THE WITNESS: 23 MR. BRIGGS: I did not know that. You may. If you don't know and 24 you would like to know before you answer the question 25 you're entitled to ask her to clarify. Peterson Reporting, Video & Litigation Services 168 Richard Lawrence, 11-17-14 1 2 3 THE WITNESS: Would you clarify for me, please. BY MS. PANCAKE: Q Mr. Quiroz -- I mean Mr. Lawrence, you 4 testified that you don't know the exact time when 5 the board decided to file the lawsuit; is that 6 accurate? 7 A That's correct. 8 Q Okay. 9 Do you know when the lawsuit was actually filed? 10 A I do not. 11 Q Okay. Do you know how long after -- how 12 long was it between the board's decision and the 13 actual filing? 14 A I have no idea. 15 Q Okay. Was -- was the fact that the lawsuit 16 was filed something that was discussed at the board 17 level after it actually happened? 18 MR. BRIGGS: With or without the attorney 19 present? Because he's already told you that all the 20 meetings were with the attorney present -- 21 MS. PANCAKE: 22 MR. BRIGGS: 23 MS. PANCAKE: Okay. -- so -Just because the attorney is 24 present doesn't mean that it's confidential -- that 25 there's been a confidential communication. Peterson Reporting, Video & Litigation Services 169 Richard Lawrence, 11-17-14 1 MR. BRIGGS: Given that it's about whether the 2 lawsuit was filed, yeah, it does. 3 object on attorney-client privilege grounds and instruct 4 him not to answer. 5 So I'm going to If you want to exclude any conversations where 6 the attorney was present, I will be happy to allow that, 7 but you keep going back to this attorney-client 8 privilege stuff and I'm just not going to allow it. 9 you're wasting time. 10 And The witness is not going to answer that question. 11 MS. PANCAKE: 12 HON. PATE: Your Honor, can I get a ruling? Yeah, Mr. Briggs' analysis is 13 incorrect. 14 meeting discussing board topics, the fact that there's 15 an attorney present does not make it automatically an 16 attorney-client privilege situation. 17 If it's a board meeting and they're having a If the attorney there is advising the board on 18 a topic, what the attorney says could be privileged. 19 And if the board members are directing questions to the 20 attorney to clarify things, that can be privileged. 21 the discussion among the board members themselves would 22 not be privileged. 23 But So as a matter of law that the -- anything that 24 occurs in that meeting is not automatically subject to 25 attorney-client privilege. You haven't differentiated Peterson Reporting, Video & Litigation Services 170 Richard Lawrence, 11-17-14 1 clearly what it is you are seeking, so I don't know if 2 it falls into the privilege or not. 3 MR. BRIGGS: The judge makes a fair point 4 because I'm actually supplying some information that I 5 know. 6 conversation with the board involved the attorney or 7 not, then we can perhaps circumvent this privilege 8 issue. 9 BY MS. PANCAKE: 10 If you would like to ask, first, whether that Q Mr. Lawrence, did the board ever discuss 11 the filing of this lawsuit amongst itself without 12 being in a direct conversation with the attorneys? 13 A No. 14 Q If I represented to you that the lawsuit 15 was filed in December of 2012, does that refresh 16 your recollection? 17 A Not really. 18 Q Okay. Does it refresh your recollection as 19 to whether or not the filing of the lawsuit was 20 before or after Ms. Perine came to the board 21 meeting? 22 A I think it was before. 23 Q You think the lawsuit was filed before she 24 25 As I said before. came to the board meeting? A I think so. Peterson Reporting, Video & Litigation Services 171 Richard Lawrence, 11-17-14 1 Q And what's the basis of your recollection? 2 A That I think her participation was within a 3 year from today. 4 but I think so. 5 Q I could be wrong about that too, Mr. Lawrence, I'm showing you a document 6 that I'm marking as Exhibit No. 14. 7 on No. 14, right? 8 9 A Well, geez, these are in the exact -- I think it is. 10 MR. BRIGGS: 11 MS. PANCAKE: 12 (Exhibit 14 was marked.) 13 14 I think we're Fourteen. No. 14. I've marked. BY MS. PANCAKE: Q Mr. Lawrence, I will represent to you that 15 Exhibit 14 is the Third Amended Complaint for Relief 16 Under Reverse Validation Statutes, which is the 17 operative complaint in this case. 18 Have you seen Exhibit 14 before? 19 A Yes. 20 Q When did you see this document prior to 21 22 23 24 25 today? A Well, I will be dipped if I know, but I'm quite sure I'm seen it. Q What were the circumstances around when you've seen this document before? Peterson Reporting, Video & Litigation Services 172 Richard Lawrence, 11-17-14 1 2 A Probably at a SanDOG board meeting or I may have actually received this electronically. 3 Q From someone other than your attorney? 4 A Nope. 5 Q Do you currently own any housing units such From my attorney. 6 as a hotel or vacation rental that you rent out to 7 tenants for periods of less than 30 days within the 8 City of San Diego? 9 A No, I don't. 10 Q Have you in the past owned any housing 11 units such as a hotel or vacation rental in the City 12 of San Diego? 13 A No. 14 Q Do you operate any housing units such as a 15 hotel or vacation rental that you rent out to 16 tenants for periods of less than 30 days in the City 17 of San Diego? 18 A No. 19 Q And have you ever operated any hotels or 20 vacation rentals within the City of San Diego? 21 A No. 22 Q Do you serve as a representative of any 23 hotelier or any person who rents out housing units 24 to tenants for periods of less than 30 days in the 25 City of San Diego? Peterson Reporting, Video & Litigation Services 173 Richard Lawrence, 11-17-14 1 A No. 2 Q Have you ever served as a representative of 3 a hotelier or any person who rents out housing units 4 to tenants for periods of less than 30 days? 5 A No. 6 Q Have you ever filed a certificate of hotel 7 registration with the City of San Diego? 8 A No. 9 Q Have you ever filed any transient occupancy 10 registration certificate with the City of San Diego? 11 A No. 12 Q Have you ever submitted any transient 13 occupancy tax or any other bed tax within the City 14 of San Diego? 15 A No. 16 Q Have you ever submitted a claim for a TOT, 17 a transient occupancy tax or bed tax overpayment 18 refund to the City of San Diego? 19 A No. 20 Q Do you have copies of any receipts or any 21 other materials received from the City of San Diego 22 relating to the Tourism Marketing District? 23 A No. 24 Q Did you receive a ballot for the approval 25 of the Tourism Marketing District assessment Peterson Reporting, Video & Litigation Services 174 Richard Lawrence, 11-17-14 1 renewal? 2 A No. 3 Q Did you vote in the election for the 4 approval of the Tourism Marketing District 5 assessment renewal? 6 A No. 7 Q Do you claim that you should have received 8 a ballot for the approval of the Tourism Marketing 9 District assessment renewal? 10 A No. 11 Q Why do you believe that you were listed as 12 somebody who confers standing on SDOG in this 13 lawsuit? 14 MR. BRIGGS: I'm going to object on 15 attorney-client and work product privilege grounds. 16 You're asking him a question that is going to require 17 him to divulge information. 18 BY MS. PANCAKE: 19 Q Okay. Other than information that you may 20 have received from your attorney, do you have any 21 independent knowledge of why you were listed as an 22 individual who may be able to confer standing upon 23 SDOG? 24 A 25 I don't fully understand what it means to confirm standing for one thing. And I have been Peterson Reporting, Video & Litigation Services 175 Richard Lawrence, 11-17-14 1 really very actively opinionated about TOT and in 2 that I've made my feelings about that known 3 publicly. 4 factor in my contributing to having standing. 5 Q I would hope that that may have been a Are you aware that there's a list of 6 members that was provided to my office and the City 7 Attorney's Office by Mr. Briggs's office? 8 A Yes. 9 Q Did you participate in the formulation of 10 that list? 11 A No. 12 Q Are you aware of the individuals who are on 13 14 that list other than yourself? A No, not -- I'm aware of the individuals, 15 but I do not remember all of the individuals who are 16 on that list. 17 Q Who are the individuals that you do 18 remember? 19 A 20 for sure. 21 Q Richard Lawrence, Pedro Quiroz I remember I'm afraid that's about it. Has the board authorized any changes to 22 that list, to your knowledge? 23 MR. BRIGGS: I'm going to object. If a change 24 had been authorized, Jenni, it would have come to me, 25 which would be an attorney-client privilege Peterson Reporting, Video & Litigation Services 176 Richard Lawrence, 11-17-14 1 communication. 2 What are you doing? MS. PANCAKE: I disagree with you, Cory. The 3 board can take action and the actions of the board just 4 because you're at the meeting doesn't mean that it gets 5 attorney-client privilege. 6 decided. 7 BY MS. PANCAKE: 8 9 Q I'm asking what the board Has the board made any decisions about changing the list, Mr. Lawrence? 10 MR. BRIGGS: I'm going to object. You're now 11 invading into clearly attorney-client and work product 12 domain and I'm going to instruct the witness not to 13 answer. 14 MS. PANCAKE: 15 HON. PATE: 16 overruled. 17 privileged. 18 Your Honor, can I get a ruling? Yeah. The objection will be If it was just board business, it's not MR. BRIGGS: If -- why don't you ask the 19 witness whether any such decisions were made by the 20 board without their attorney present involved in the 21 conversation. 22 supplying that factual premise. 23 MS. PANCAKE: I get the judge's point and I keep Okay. But before I do that, the 24 judge overruled your objection to my question about 25 whether the board has made any decisions about -- excuse Peterson Reporting, Video & Litigation Services 177 Richard Lawrence, 11-17-14 1 me. I think. Let me -- can you read back the question 2 that I actually asked? 3 rather than confidential communication between the board 4 and you, Cory. I was trying to focus on action 5 (The pending question was read.) 6 MR. BRIGGS: And he's -- for the objections 7 that I gave, because the judge's right, I'm not 8 asserting an objection as a matter of law in the 9 abstract. I happen to know the answer to the factual 10 question about whether I was present in any such 11 conversations. 12 MS. PANCAKE: 13 MR. BRIGGS: Okay. If you want to get at that factual 14 premise by asking whether those conversations took 15 place, just with the board or with their attorney 16 present, you're free to do that. 17 But you're not going to ask any questions -- 18 this would be like me asking your ED whether they 19 authorized a settlement communication to my office. 20 That would clearly be inappropriate. 21 question about what goes into the discovery responses. 22 23 24 25 MS. PANCAKE: Okay. And so is your Well, I asked a question; you made objections -MR. BRIGGS: He's not going to answer your question. Peterson Reporting, Video & Litigation Services 178 Richard Lawrence, 11-17-14 1 2 MS. PANCAKE: -- the judge overruled the objection. 3 MR. BRIGGS: That's fine. 4 general reference. 5 not to answer the question. 6 BY MS. PANCAKE: 7 8 Q And this is not a I'm still instructing the witness Are you going to follow your attorney's advice? 9 A I'm going to follow my attorney's advice. 10 Q Are you aware of whether or not there's 11 been any changes made to the list? 12 A I'm not aware of any changes. 13 Q Mr. Lawrence, can you look at the 14 complaint, and I'd like you to look at page 4, 15 paragraph 8 and 9. 16 what I'm going to do is to go through the 17 subparagraphs of paragraph 8 and 9, and I'm going to 18 be asking you whether you believe you fall into the 19 category of persons that is described in paragraph 20 8, sub A through sub G and paragraph 9-A and B. 21 Okay? 22 A Okay. 23 Q Do you believe that you are a person who is 24 25 And I'm just going to tell you described in paragraph 8-A? A Yes. Peterson Reporting, Video & Litigation Services 179 Richard Lawrence, 11-17-14 1 2 Q Do you believe that you are a person who's described in paragraph 8-B? 3 A No. 4 Q Okay. 5 Going back to paragraph 8-A, you're currently registered to vote in San Diego? 6 A Yes. 7 Q Were you registered to vote in San Diego as 8 of December 19th, 2012? 9 A Yes. 10 Q And have you consistently been registered 11 to vote from December 19th, 2012, until now? 12 A Yes. 13 Q Going on to paragraph 8-C, are -- do you 14 believe that you are a person who's described in 15 paragraph 8-C? 16 A No. 17 Q Do you believe that you're a person who's 18 described in paragraph 8-D? 19 A No. 20 Q Do you believe that you are a person who is 21 described in paragraph 8-E? 22 A No. 23 Q Do you believe that you are a person who's 24 25 described in paragraph 8-F? A No. Peterson Reporting, Video & Litigation Services 180 Richard Lawrence, 11-17-14 1 2 Q Do you believe that you are a person described in paragraph 8-G? 3 A No. 4 Q Moving on to paragraph 9, do you believe 5 6 7 8 that you are a person described in paragraph 9-A? A that paragraph is "it"? Q 9 10 Could you tell me why the first word in I did not draft this. MR. BRIGGS: Your attorney did -- It refers to plaintiff. BY MS. PANCAKE: 11 Q -- but I believe it refers to plaintiff 12 SDOG. So you can replace -- and Mr. Briggs will 13 correct me if I'm wrong, but I think you can replace 14 the word "it" with SDOG. 15 MR. BRIGGS: 16 THE WITNESS: 17 18 19 She's right about that. Yes. BY MS. PANCAKE: Q And what is the basis of your answer that you believe -- 20 A My attorney told me so. 21 Q Okay. 22 23 Who is -- MR. BRIGGS: You may have misunderstood. BY MS. PANCAKE: 24 Q -- the member that was eligible -- 25 A There was one member -- Peterson Reporting, Video & Litigation Services 181 Richard Lawrence, 11-17-14 1 Q -- to vote on the TMD tax. 2 3 4 THE COURT REPORTER: BY MS. PANCAKE: Q I'm sorry. 5 6 7 I'm sorry? Let me ask the question. Who is the member that you believe was identified as being eligible to vote on the TMD tax? A Well, it goes on to say "and was not 8 provided with ballot materials." 9 is no. 10 Q Okay. The answer to that Let me back up a little bit because 11 I think we may have gotten off on sort of a tangent, 12 but I just want to make sure that we're clear about 13 this. 14 Do you believe that you were a person 15 identified by the City as being eligible to vote on the 16 TMD tax? 17 MR. BRIGGS: Let me see if I can help. She 18 wants to know whether you're the member who's described 19 after the word "who" in all of these. 20 figure out whether you're this person. 21 22 THE WITNESS: She's trying to No. BY MS. PANCAKE: 23 Q You do not believe you were the person? 24 A No. 25 Q Do you know who that person is? Peterson Reporting, Video & Litigation Services 182 Richard Lawrence, 11-17-14 1 A No. 2 Q And other than information that may have 3 been given to you by your attorney, do you have any 4 independent knowledge of whether SDOG has any 5 members who fall within the criteria listed in 6 paragraph 9-A? 7 A I believe so. 8 Q And what is that knowledge? 9 MR. BRIGGS: 10 your attorney, right? 11 THE WITNESS: 12 attorney. 13 BY MS. PANCAKE: Independent of what you get from Only what I've heard from my 14 Q So you don't have any other information? 15 A I don't. 16 Q You have no independent knowledge? 17 A No, I don't. 18 Q Are you aware of whether there is more than 19 one member who falls within the criteria of 20 paragraph 9-A? 21 A I am not. 22 Q You do not know? 23 A I am not aware, no. 24 Q Okay. 25 Are you a member who's described in paragraph 9-B? Peterson Reporting, Video & Litigation Services 183 Richard Lawrence, 11-17-14 1 A No. 2 Q Are you aware of whether or not SDOG has a 3 member who is described in paragraph 9-B? 4 A I am not aware. 5 Q Mr. Lawrence, are you -- do you have an 6 interest in any trust that owns any hotel or 7 vacation rental property in the City of San Diego? 8 A No. 9 Q Do you, sir, have any obligation to pay the 10 assessment that relates to the Tourism Marketing 11 District? 12 A Would you repeat that, please. 13 Q Do you have any obligation to pay the 14 assessment that is -- that relates to the 15 Tourism Marketing District? 16 A No. 17 Q Do you have any obligation to pay any 18 transient occupancy tax to the City? 19 A No. 20 Q Have you ever paid any assessment 21 pertaining to the Tourism Marketing District? 22 A No. 23 Q Have you ever paid any transient occupancy 24 25 tax related to the Tourism Marketing District? A No. Peterson Reporting, Video & Litigation Services 184 Richard Lawrence, 11-17-14 1 2 3 4 5 6 Q Have you ever paid any fees pertaining to the Tourism Marketing District? A I am afraid I don't understand what fees those might be. Q Okay. I'm just talking about any fees generally. 7 A Not so far as I know. 8 Q Have you ever made any monetary payments as 9 a result of the Tourism Marketing District renewal? 10 A Monetary payments? 11 Q Yes. 12 A No. 13 Q Have you ever received any request or any 14 notification that you should make a monetary payment 15 as a result of the Tourism Marketing District? 16 17 A No. MS. PANCAKE: I'd like to take a quick break 18 because I believe I am almost done with my questions. 19 So I just want to look through and see if there is 20 anything else going. 21 MR. BRIGGS: 22 MS. PANCAKE: 23 THE VIDEOGRAPHER: 24 25 What time is it? 3:35. Okay. Off the record. The time is 3:31 p.m. (Recess taken.) Peterson Reporting, Video & Litigation Services 185 Richard Lawrence, 11-17-14 1 THE VIDEOGRAPHER: 2 time is 3:35 p.m. 3 BY MS. PANCAKE: 4 5 Q Back on the record. The Mr. Lawrence, we're back on the record. You realize that you're still under oath? 6 A Yes. 7 Q And now that you have had the opportunity 8 to sit through the entire deposition, is there 9 anything that -- any testimony that you gave earlier 10 today that you would want to change for any reason? 11 12 13 A Setting aside eloquence in my longer comments, I'd say no. Q Thank you. I have no further questions. 14 MS. BROCK: I have no questions. 15 MR. BRIGGS: I have one question. 16 17 18 19 EXAMINATION BY MR. BRIGGS: Q Mr. Lawrence, you said earlier that you 20 recall a meeting about a year ago involving SanDOG 21 board members and Linda Perine. 22 Did I hear that correctly? 23 A Yes. 24 Q Was that an official SanDOG board meeting 25 or was it Ian Trowbridge's memorial service that was Peterson Reporting, Video & Litigation Services 186 Richard Lawrence, 11-17-14 1 attended by Linda Perine and other members on the 2 SanDOG board, if you recall? 3 A I believe that it was at Ian's memorial 4 service that Linda and I had our conversation, not a 5 regular SanDOG board meeting. 6 Q Was that in the spring of 2013? 7 A Yes, it was. 8 9 MR. BRIGGS: I don't have any further questions. 10 MS. PANCAKE: I have a few follow-ups. 11 12 13 14 FURTHER EXAMINATION BY MS. PANCAKE: Q Mr. Lawrence, was it at the memorial 15 service in the spring of 2013 when Linda Perine 16 indicated to you that she wanted to become a member 17 of SDOG? 18 A No. Actually we did not talk about SDOG in 19 particular. 20 course, came up, but the request for membership was 21 not a part of that conversation, as I now recall. 22 Q We talked more about Ian. So Ms. Perine did come to a meeting of SDOG 23 and asked for -- to become a member. 24 accurate? 25 SDOG, of MR. BRIGGS: Objection. That's still You're misstating his Peterson Reporting, Video & Litigation Services 187 Richard Lawrence, 11-17-14 1 testimony. 2 You can go ahead and answer. 3 THE WITNESS: I'm not certain that the meeting 4 I was referring to was an actual SanDOG board meeting 5 where she and I had our conversation. 6 the memorial service that she and I chatted. 7 BY MS. PANCAKE: I think it was at 8 Q You and she chatted about what? 9 A About Ian in particular and SanDOG in 10 general and her interest in the work of the 11 organization, but there wasn't any request. 12 was no discussion about membership. 13 Q There Was it your understanding that Ms. Perine 14 was a member of SDOG at the time that she had the 15 conversation with you at Ian's memorial? 16 A I believe she was a member of SanDOG, yes. 17 Q Okay. And you testified earlier that there 18 was a board meeting where Linda came to the board 19 and requested to become a member. 20 21 22 23 Do you recall that testimony? A I do. And I think I was mistaken. I don't think that that occurred at a board meeting. Q So when did that request to become a board 24 mem- -- excuse me, a request to become an SDOG 25 meeting happen? Peterson Reporting, Video & Litigation Services 188 Richard Lawrence, 11-17-14 1 A I think I'm mistaken, period, about her 2 requesting membership in SanDOG. 3 already a member in SanDOG when I met her. 4 5 6 Q Okay. When is the first time that you met her? A I'm not sure that I met her before that 7 memorial service. 8 first time I met her. 9 10 11 Q I'm pretty sure that was the And how do you know that she was already a member of SDOG at the time that you met her? A I think what I testified was that I thought 12 she was already a member of SDOG. 13 know it. 14 Q 15 16 17 18 19 20 21 22 I think she was I really didn't What made you think that she was already a member of SDOG? A Because of her relationship with Ian in particular. Q And what did she tell you during your conversation at Ian's memorial service? A How much his sort of wild energy and commitment were going to be missed. Q And other than that general discussion 23 about Mr. Trowbridge, what else led you to believe 24 that Ms. Perine was a member of SDOG at the time 25 that she had this conversation with you at Peterson Reporting, Video & Litigation Services 189 Richard Lawrence, 11-17-14 1 2 Mr. Trowbridge's memorial service? A Well, other than what I just said was 3 because of their -- what appeared to be a really 4 strong connection to Ian, I assumed she was a member 5 of SanDOG. 6 Q But you up until -- is it accurate to say 7 that until the memorial service of Mr. Trowbridge, 8 had you ever heard Ms. Perine's name being 9 discussed? 10 11 Well, let me rephrase that. Hold on one second. 12 Prior to Mr. Trowbridge's memorial service, 13 were you aware that Ms. Perine had anything to do with 14 SanDOG or not? 15 16 17 A I was not aware of whether she had anything to do with SanDOG. Q Okay. Prior to the time of the memorial 18 service, were you aware of whether or not Ms. Perine 19 was a member of SDOG? 20 A No, I was not. 21 Q And other than Ms. Perine discussing with 22 you her friendship and relationship with Ian 23 Trowbridge, was there anything else that led you to 24 believe that she was a member of the SDOG 25 organization as of the time of the memorial service? Peterson Reporting, Video & Litigation Services 190 Richard Lawrence, 11-17-14 1 A Well, again, she spoke really very 2 affectionately of Ian and enthusiastically about the 3 work of SDOG and that gave me a hint that she might 4 very well be a member. 5 6 Q Did you ever discuss that with her during that conversation? 7 A I don't think so. 8 Q Have you discussed it with her after that 9 conversation? 10 A I have not. 11 Q Have you had any discussions with her after 12 13 that conversation at the memorial? A As I said earlier, I thought that she had 14 come to a board meeting, and I'm now not convinced 15 that my memory on that score is accurate. 16 think not. 17 Q So I Are there any other items of your testimony 18 that you would like to change before we conclude 19 your deposition? 20 A No. 21 MS. PANCAKE: 22 MR. BRIGGS: 23 24 25 I have no further questions. Shall we just incorporate the same stip that we used last time Bridget was our reporter? MS. PANCAKE: Well, you know what? I think when we do that, the names of the witnesses get Peterson Reporting, Video & Litigation Services 191 Richard Lawrence, 11-17-14 1 embroidered into this. 2 this witness. 3 MR. BRIGGS: 4 MS. PANCAKE: So let's just do it fresh for Okay. Mr. Lawrence, the stipulation 5 that we've agreed to in the past is that after 6 transcribing today's testimony into a booklet form, the 7 court reporter will be relieved of her statutory duties 8 with respect to the handling of the transcript. 9 What we've agreed will happen is the court 10 reporter will send the original transcript to the office 11 of Mr. Briggs. 12 transcript to you. 13 the time that Mr. Briggs receives the transcript, you 14 and he will have 30 days to have the transcript sent to 15 you, to have you review the transcript, make any changes 16 that you feel are necessary, and sign the transcript 17 under penalty of perjury. Mr. Briggs will then send that You will have 30 days to -- or from 18 Does that time frame work for you? 19 THE WITNESS: So far as I know, yes. 20 MS. PANCAKE: Okay. 21 You don't have any international vacations planned in the next 30 days? 22 THE WITNESS: No, unfortunately, no. 23 MS. PANCAKE: So then we've also agreed that -- 24 do you agree that you will review the transcript, sign 25 it under penalty of perjury. You will advise Mr. Briggs Peterson Reporting, Video & Litigation Services 192 Richard Lawrence, 11-17-14 1 of two things: One that you signed the transcript and, 2 two, if you have any changes, Mr. Briggs will 3 communicate that to my office within that 30-day time 4 period. 5 THE WITNESS: 6 What do I do with the transcript after I've 7 I understand that. signed it? 8 MR. BRIGGS: You will give it back to me. 9 MS. PANCAKE: You will send it back -- either 10 deliver it in person or send it back to Mr. Briggs's 11 office. 12 THE WITNESS: Okay. 13 MS. PANCAKE: We'll stipulate that Mr. Briggs 14 may maintain custody of the original transcript, that he 15 will agree to bring it to any court proceedings or any 16 other proceedings upon reasonable notice by any party. 17 That if the original transcript is not signed 18 by you or if the signed transcript is lost, stolen, 19 destroyed, or for any other reason unavailable, that an 20 unsigned certified copy can be used in its place. 21 MR. BRIGGS: So stipulated. 22 MS. BROCK: 23 MS. PANCAKE: 24 MR. BRIGGS: 25 MS. PANCAKE: So stipulated. So stipulated. Thank you. Thank you, Mr. Lawrence. Peterson Reporting, Video & Litigation Services 193 Richard Lawrence, 11-17-14 1 THE VIDEOGRAPHER: This ends the videotaped 2 deposition of Richard Lawrence. 3 is 3:45 p.m. The time off the record 4 (Whereupon, the deposition adjourned at 5 3:45 p.m.) 6 7 I, RICHARD LAWRENCE, declare under 8 penalty of perjury under the laws of the State of 9 California that the foregoing is true and correct; that 10 I have read my deposition and have made the necessary 11 corrections, additions or changes to my answers I deem 12 necessary. 13 14 15 16 Executed on this________day of___________________, 2014. _____________________________ RICHARD LAWRENCE 17 18 19 20 21 22 23 24 25 Peterson Reporting, Video & Litigation Services 194 Richard Lawrence, 11-17-14 1 C E R T I F I C A T E 2 3 I, BRIDGET L. MASTROBATTISTA, Certified Shorthand 4 Reporter for the State of California, do hereby certify: 5 6 That the witness in the foregoing deposition was by me 7 first duly sworn to testify to the truth, the whole 8 truth and nothing but the truth in the foregoing cause; 9 that the deposition was taken by me in machine shorthand 10 and later transcribed into typewriting, under my 11 direction, and that the foregoing contains a true record 12 of the testimony of the witness. 13 14 Dated: This 15 California. day of , 2014, at San Diego, 16 17 18 19 ________________________________ 20 BRIDGET L. MASTROBATTISTA 21 C.S.R. NO. 7715, RPR, CRR, RMR 22 23 24 25 Peterson Reporting, Video & Litigation Services 195 Richard Lawrence, 11-17-14 161:1,2,5 $ $1.25 24:11 134 5:3 $35 24:6 136 5:25 $37.40 24:3,8 137 6:3 $38.40 24:3 138 6:4 139 9:11 1 1 4:10 23:9,10,13,24, 25 25:8 42:22 75:1 130:6 14 5:7,15 172:6,7,11,12, 15,18 80:3,9,25 161:9 187:6,15 2014 1:16 2:15 5:2 7:1,4 8:16 111:14 194:15 195:14 21 50:8 23 4:10 24 5:24,25 6:5 47th 9:11 5 5 4:17 5:19,20,21 75:19,21,23 76:1 77:4 9 9 4:5,23 107:7,9,11,13, 24 108:1,18,22 179:15,17 181:4 52 4:14 90 5:18 54:23 530 2:15 7:9 90071-3137 3:9 4833 136:7 149 6:5 26 104:20 106:14 1:41 119:11 14th 8:16 26th 103:21 1:50 119:14 15 6:7 21:9 27 5:2 10 5:1 24:12 110:23,24 111:4,7,8 126:6,9 130:3 135:8 154 5:4 2700 3:8 16 5:18 27th 111:14 10/26/12 4:22 169 6:7 10:06 2:15 7:1,3 17 1:16 2:15 6:4 3 4:14 52:6,7,9,10 63:3 145:1 100 5:19 172 5:7 3:31 185:24 101 5:20 177 6:8 102 4:21 70s 18:25 17th 7:1,3 3:35 185:21 186:2 105 5:21 3:45 194:3,5 75 4:17 186 4:6 107 4:23 187 4:7 11 5:3,13 134:12,17,20 135:8 19 5:23 30 173:7,16,24 174:4 192:12,14,21 1951 9:11 11:54 75:3 160 5:6 6:11 163 6:6 3 6 909)949-7115 161:19 6 4:19 77:12,13,15 78:16 79:2 91786 3:4 60s 18:25 92102 9:12 62 4:16 99 3:4 6e 78:17 9-A 179:20 181:5 183:6,20 7 9-B 183:25 184:3 7 4:20 78:19,21,23 79:5 92101 3:13 7:9 A a.m 2:15 7:1,3 75:3 76 5:16 abdicated 136:24 137:4,6 77 4:19 Abel 3:18 7:5 300 3:8 7715 1:20 2:18 195:21 1965 14:21 30-day 193:3 78 4:20 14:9 110 5:1 199N 5:6 32 5:12 7878 136:8 1100 3:13 19th 180:8,11 350 2:16 7:9 111 3:4 1st 79:8,23 80:2 37 5:13 able 10:24 11:22 12:13 13:11,21 14:14 20:23 31:19 64:4 120:16 133:15 145:24 146:3 147:2 165:10 167:11 168:2 175:22 116 5:22 11th 78:10 79:23 80:3,9 12 5:4 49:22 97:10,13,19 154:4,5,7 12:23 75:7 2 2 4:12 5:17 6:6 42:8,10,21,23 75:5 102:25 144:22 2:29 144:24 2:34 145:3 12:43 85:19 20 24:6 12:48 85:22 2011 49:22 79:8,23 80:2,6,25 1200 3:13 121 5:23 129 5:24 13 5:6,12 6:3,11 49:22 50:5 160:22,23 2012 50:5 103:21 104:20 106:14 167:20 171:15 180:8,11 2013 78:11 79:24 37-2012-000880 65 7:13 37-2012-000880 65-CU-MCCTL 1:6 2:6 38 5:14 4 4 4:16 5:14,22 62:15,16,18 179:14 8 8 4:21 5:16 6:8 102:20,21,23 103:1 179:15,17,20 8/22/2014 167:18 80 54:23 86 5:17 8-A 179:24 180:4 absence 105:13 absolutely 64:4 73:25 74:5 131:11 149:23 abstract 178:9 8-B 180:2 accept 42:23 43:4,5 8-C 180:13,15 accepted 43:6 8-D 180:18 access 134:9 8-E 180:21 accident 128:11 42 4:12 8-F 180:24 45 160:21 8-G 181:2 accomplish 112:16 145:23 40 5:15 53:25 54:8 46 54:9 Peterson Reporting, Video & Litigation Services accomplished 196 Richard Lawrence, 11-17-14 108:14 111:2 158:18 159:6 ACCORD 132:22 activity 81:4 113:18 accordance 150:17 acts 69:23 According 111:15 accountable 133:16 accurate 28:2,3 29:19 55:22 68:16 84:12 112:7 113:4,5 127:4,25 131:6,7 135:9,18,22 169:6 187:24 190:6 191:15 achievements 108:14 acronym 26:20 27:21 actual 17:25 42:19 107:16,20,21 169:13 188:4 actually 8:6 22:10 33:24 39:14 48:7 50:21 57:17 62:13 63:25 65:4,5 83:14 85:10 99:4 105:3 122:11 150:5 152:12 159:4 167:5 168:4,8,18 169:9,17 171:4 173:2 178:2 187:18 add 71:20 across 70:10 129:3 132:14 added 55:15 82:8 83:17 acted 77:8 addition 80:19 115:11 acting 66:14 93:18 action 24:21 35:20 68:2 72:21 73:8 89:6,8,10 100:1 104:10 105:7,24 106:12 112:17 158:2,22 167:19 177:3 178:2 actions 74:18 109:25 177:3 active 9:22 14:20 18:12 29:8 31:3,7 56:16 102:7 131:19 135:25 actively 176:1 activist 48:1,22 activities 30:6,13 71:14 73:16 78:3 81:5,17,23 82:2 96:13 103:4 124:2,8,20 additional 88:1 98:15,18 additions 194:11 address 9:10 48:17 49:4 64:18 68:2,3 71:2 72:24 118:18 136:1,3,4,7,11, 14,16,18 138:4 142:11 158:21,23 161:24,25 addressed 47:8 64:14 adjourned 194:4 admitted 83:14 84:14 advance 58:15 63:24 68:2 73:20 74:20 146:12 148:17 149:4 advanced 59:2 146:13 advancing 123:5 advertise 92:24 93:6,10,11 121:5 advice 22:15 105:19 122:4 139:12 179:8,9 advise 149:22 152:1 192:25 advising 170:17 advisory 57:9,12 affairs 78:3 141:21 affect 106:22 111:25 143:2 affected 106:22 affectionately 191:2 affects 142:12,15 afford 20:23 115:13 ago 16:18,20 20:7 21:10,15 47:17,20,21 48:7 64:8,9 65:12 88:21 90:8,9,11,12 186:20 agreed 8:14 65:17,19,25 74:13 80:20 120:18 192:5,9,23 agreement 157:17 158:14,17 ahead 70:20 130:25 162:20 188:2 ahold 121:16 al 1:7 2:7 7:12 alarm 127:11 Albion 10:3,4 affordable 20:13,16,19,2 1 29:6,23 49:2,5,10 74:7 115:4,6 118:13,15,19 119:5 123:9,12 124:25 125:8,12,14 alive 47:18 afield 152:24 allow 153:2 170:6,8 afraid 176:20 185:3 against 11:3 74:9 149:18,19,25 152:9 age 14:9 agency 158:24 agenda 53:8 55:3,6,7,11,15, 16,17,19,22 56:5,9,18 57:18 58:6,18,20 66:19 120:7 122:20,23 132:5 165:17 agendas 132:7 agent 136:2 aging 14:6 allegations 164:7,9 allegedly 92:8 Alliance 31:5,9 Allison 25:13,21 Allison's 25:14,17 allowed 140:12 allows 134:3 alone 54:7 already 11:2 47:7 56:25 61:1 79:1 90:20 106:2 111:19 116:16 169:19 189:3,9,12,14 alter 151:19 152:10 am 65:15 83:5 89:25 98:2 101:14 102:13 122:3 135:20 141:13 151:3 152:1 153:8 163:18 167:25 168:1,16 Peterson Reporting, Video & Litigation Services 183:21,23 184:4 185:3,18 ambiguous 45:1 46:9,22 156:6 amend 105:25 106:12 amended 4:10 5:7 104:20 172:15 amending 105:10 amendment 4:16 30:9 105:2,5 among 128:15 142:6 170:21 amongst 164:25 165:4 171:11 amount 12:24 24:3 59:3 110:17 150:15 analysis 170:12 And/or 148:4 Angeles 3:9 answer 5:10 6:1 11:4,17,25 12:6,7,8 13:7 19:11 22:14 30:12,14,17 32:22 33:1,3,6,7 37:18,20,21,2 2 39:4,22 40:21 45:24 46:1,2 47:1 57:5,10 71:17 72:3,17 73:5 76:12,14 80:13 81:9,25 86:7,24,25 87:2,4 90:22,25 91:1,4 96:6 100:10,13 101:10 103:15 105:16 106:2,9 109:21 115:21 116:13,17 118:10 119:1 121:23 125:3 128:13,16 130:18 131:8 137:5,9,10,20 138:22,23 197 Richard Lawrence, 11-17-14 139:5,8,9,22 140:16 141:1 143:7 146:23 150:23 155:19 156:11 157:25 163:16,18 168:24 170:4,9 177:13 178:9,24 179:5 181:18 182:8 188:2 133:25 137:4,6 140:19 150:12 170:23 185:20 186:9 190:13,15,23 anywhere 21:8 apologize 29:14 104:17 apparently 80:6 126:25 128:24 argue 117:23 argument 116:20 argumentative 116:10 137:4 arguments 152:10 arose 115:4 arrangement 149:2 arrested 18:10,20 answered 116:16 131:14 143:6 appealable 150:15 answering 12:10 50:17 appear 42:15 art 13:4 appearance 16:13 article 5:1 111:23 126:7 appearances 3:1 159:1,8,19 articles 4:14,16 51:12 62:12 63:1 67:10,11 69:9 103:2,10,19,2 4 104:6,7,11,14, 19 105:2,5,10,25 106:5,13 answers 12:18 13:17,21 37:13 38:25 39:21 117:20 194:11 Anthony 4:24 anticipate 11:3 anybody 25:6,22 32:19,20 36:24 38:7 100:6 115:20 120:12 122:23 147:8 155:11 anymore 117:23 anyone 33:22 37:25 40:14,18,19 55:1 60:18 69:5 76:9 77:1,21 92:5,21 100:16 107:2 131:16 142:17 143:2 154:23 155:18 162:21 163:2,13,23 164:3 anything 13:6 21:19 33:22 34:11 36:17,21 39:1 44:10 56:15,17 57:16,18 58:4 64:3 72:13,23 73:24 74:4 82:17 91:22 96:21 102:2 104:24 107:23 115:25 117:23 127:20 128:9 appeared 14:22 15:2,4 18:10,11 48:9 159:5 190:3 appearing 22:5 applicable 128:2 application 82:15 83:13 84:5 87:7,10,23 89:21,22 90:5,18 91:13,16,23 103:5 120:9 arrived 44:17 aside 186:11 as-needed 74:21 asserted 152:9 asserting 39:9 178:8 apply 16:6 assessment 174:25 175:5,9 184:10,14,20 appoint 77:22 assist 108:22 appointed 7:21 8:2,6 assistance 8:19 62:8 132:15 appreciate 43:7 160:6 associated 146:25 approach 40:3 associational 30:6 applications 87:25 90:13 appropriate 39:20 70:23 approval 174:24 175:4,8 approximately 168:17 aren't 13:5 117:18,19 121:2 assume 21:7 59:7 68:10 78:14 108:3 128:10 157:11 162:15 assumed 12:9 190:4 assumes 55:9 assuming 25:1 88:1 128:14 137:18 148:4 assure 59:1 70:3 112:24 assuring 146:11 attached 23:25 25:7 28:7 42:21 attempt 21:23 49:3 64:11 114:4 158:21 attempting 20:15 21:18 attend 64:17 65:20 81:13 83:19 87:21 121:18 143:11 attendance 54:22 97:20 attendant 62:25 attended 49:16 53:23 54:17 64:10 88:12,19 97:13 98:13,22 99:15 120:18 122:24 145:12,13 187:1 attending 64:20 81:12 attention 20:12 64:14 71:20 112:23 130:23 141:23 attorney 12:4 16:13 19:13 22:15 28:18 32:18,25 33:1 35:14 39:2 44:14,16 45:2 46:10 47:10 55:5 56:12 60:13,15,19 64:2,6 66:18 67:25 72:9 73:23 74:3,20 84:23 85:1 86:3,20,22 101:4,25 102:5 103:23 104:21 106:4 129:14 131:14 139:25 141:24 142:5,18 Peterson Reporting, Video & Litigation Services 150:2 169:18,20,23 170:6,15,17,1 8,20 171:6 173:3,4 175:20 177:20 178:15 181:8,20 183:3,10,12 attorney-client 22:12 32:17 37:19 38:25 39:4,8 40:2,21 45:3 56:23,25 76:11 90:22 100:9 101:9 105:9,21 130:17 137:17 138:25 150:3 163:13 170:3,7,16,25 175:15 176:25 177:5,11 attorneys 10:18 13:11 15:10 33:22 37:13,16 38:6 40:19 41:8,24,25 76:13,19,24 90:24 98:22 100:12,16 149:22 156:8 157:8 171:12 attorney's 37:14 38:1 53:7 55:1 101:12 122:4 139:11 179:7,9 Attorneys 2:13 Attorney's 3:12 176:7 attributed 112:4 126:11 August 8:16 authenticated 83:21 authority 68:4 78:7 authorization 40:15,25 41:20 154:15 162:10,19 authorize 130:9 157:21 162:21 198 Richard Lawrence, 11-17-14 authorized 36:24 37:8,11,25 38:4 40:14 107:2 153:25 154:13 162:7 163:2,22 176:21,24 178:19 automatically 170:15,24 automobile 115:13 availability 92:24 available 125:11 153:10 Avenue 3:8,13 136:8 average 134:5 aware 14:15 61:2,23 62:1,2,6,9 69:19 70:8,14 71:15 73:18 78:9,12 79:8,12,21,25 80:1,7,14,17 83:6 84:17,22 87:6,12,25 88:5 89:6,18,20,23, 25 90:1,5,17 91:12,18 93:12 98:9 99:21 100:4,24 101:5 102:11 103:9 108:5,8,11,18, 19 115:6 123:23,24 149:17 151:23 152:2 153:3,6,8 154:12,15,16, 21 155:9,16,20,2 3 157:3 161:9,12 164:3,7 165:13,19 166:5,20 176:5,12,14 179:10,12 183:18,23 184:2,4 190:13,15,18 away 20:18 99:6 B Bachelor's 10:3 background 9:25 Baking 60:6 ball 168:10 ballot 174:24 175:8 182:8 balls 46:18 based 15:22 68:17 112:7 125:23 126:16 135:9 159:17 basically 11:21 131:9 basis 40:7 159:7 172:1 181:18 Basket 18:13 bathroom 74:23 became 18:12 50:25 81:13 90:4 95:10 99:2 166:20 68:16 75:14 84:9 86:21 93:15 99:3 108:23 109:2,8 110:21 115:24,25 121:12 123:19,25 124:4,13 127:16 134:22 135:7,24 139:23 142:13,15 144:5,9,14 146:21 151:11,17 152:4 154:11 158:6,11,16 175:11 179:18,23 180:1,14,17,2 0,23 181:1,4,11,19 182:5,14,23 183:7 185:18 187:3 188:16 189:23 190:24 believed 141:10 become 47:16 82:11,18 84:6 87:12 88:18 89:3,12,16 90:17 91:12 94:7 122:21 123:2 146:14 165:13,19 187:16,23 188:19,23,24 belong 30:25 becoming 83:23 87:21 88:15 beside 117:5 152:11 bed 174:13,17 besides 36:21 begins 7:10 75:5 145:1 best 14:14 15:11,13 20:9 21:14,16 50:23 64:16 behalf 7:16,18 17:2 49:15 106:18 139:16 148:8,9 161:9 162:5 belonged 100:21 belongings 100:3 belongs 119:4 benefit 4:18 147:9 149:3 Bernardino 114:21 better 14:11 21:25 123:11 145:25 belief 91:21 135:17 beyond 116:11 153:4,13 believe 16:6,17 28:5 34:12 49:16 52:11 54:20 56:11 62:19 64:10 65:13,15 66:7 bin 43:23 47:9 biographical 108:21 bit 37:24 105:17 127:21 131:14 153:18 182:10 black 18:5 blank 4:12 26:10 36:10,12 92:2 160:9 blast 95:21 96:11,16 blasts 93:16 board 4:21 37:3 66:4 69:2,3,17,19 77:24 83:16,18,22,2 3 84:8,14,19 88:16 89:10 90:14 94:16,17,22 95:1 97:22,24 98:3,11,13,16, 24,25 99:2,3,4,8,10,1 5,19 100:1,15,20 101:19 102:12 103:12 104:8,10,15 105:6,10,19,2 3,24 106:3,12,17,2 1,25 107:4 109:23 116:4,24 119:23 120:4,8,14 121:3,5,13,17 123:2 129:10 130:9,11 136:24 137:13,23 138:2,10,13 139:4,17 140:22,23 141:16,20 142:22 143:11 149:1,6,10 151:8,21,22 152:5,17 153:21 154:12 156:19 157:21 158:10,12,13 161:11 162:4 163:6,25 164:4,25 165:4 168:3,7 169:5,16 170:13,14,17, 19,21 171:6,10,20,2 Peterson Reporting, Video & Litigation Services 4 173:1 176:21 177:3,5,8,16,2 0,25 178:3,15 186:21,24 187:2,5 188:4,18,22,2 3 191:14 board's 141:23 169:12 booklet 12:22 192:6 boosted 112:22 bottle 60:7 bottom 111:23 Boundaries 31:17 box 135:19 136:14,16,18 boycott 18:13 Bread 18:13 break 74:23,24 75:4,11 85:8,11,12,13 86:2,17,18,20 88:3 119:8 123:7 144:20 185:17 Breakfast 4:14 51:2,7 63:2,6,12 Bridget 1:20 2:16 7:8 191:23 195:3,20 Briggs 3:3 4:6 7:18 8:1,20 19:8,9,17 22:12 23:19 25:9,15 26:24 30:5,18 32:16,21 33:3 37:12 38:6,8,18,21,2 4 39:14 40:17 41:13,22 42:22 44:21 45:6,15,20,25 46:14 56:20,22 57:12,15,20 70:17,20 71:16 72:2,16 73:4 74:23 76:10,20 199 Richard Lawrence, 11-17-14 80:10,13 81:8,24 84:23 85:8,13 86:6,13,23 87:3 90:19 91:1,7 93:25 96:4 100:8 101:7 102:1,14 103:13 104:23 105:8 106:1 109:20 110:2 114:24 115:1,18 116:9,15,21 117:5,16 118:8,24 121:17,20 122:7 125:1,21 126:13,15,19 127:9,12 128:3 129:2,15,18,2 1 130:4,22 131:1,9,17 133:2 134:11,13,15 135:10 136:22 137:2,10,14,1 6 138:7,18,22,2 4 139:9,18,22 140:11,24 141:7 142:17,18 143:3,6 146:7,8 147:22 148:1,7,18 149:8 150:1,6,8,25 151:13 152:3,7 153:12 154:24 155:2,5,8,14,1 9 156:1 157:11,12,17, 22,25 158:14 160:7,11,19,2 0 161:13 162:23 163:4,8,12,23, 24 164:12 166:1 167:6,13,19 168:9,19,23 169:18,22 170:1,12 171:3 172:10 175:14 176:23 177:10,18 178:6,13,24 179:3 181:9,12,15,2 2 182:17 183:9 185:21 186:15,18 187:8,25 191:22 192:3,11,13,2 5 193:2,8,13,21, 24 Briggs's 41:18 61:21 137:1 144:3 145:9 176:7 193:10 bring 25:25 74:9 96:12 131:10 193:15 brings 126:13 129:19 broad 100:11 broadest 35:17 C C.S.R 195:21 CA 7:1 cabinets 28:13 calculated 24:8 calculation 24:10 California 1:1,15 2:1,16,18 3:4,9,13 4:18 5:3 7:9 23:2 24:6 30:10 126:14 129:3,20 132:14 135:2,25 136:18 152:25 194:9 195:4,15 camera 25:15 candidates 88:14 cap 125:5 74:8,15 83:18 88:15 108:9 114:24,25 116:11,18 117:6,8,17 118:6 130:13 133:9,18,24 153:16 158:4 162:16 164:25 165:23 172:17 Chair 55:5,6,8,12 56:10,11,13 99:11 141:13 chairman 69:8,16 141:12 chance 45:24 75:25 cases 55:20 56:2,13,16,18 57:19 58:6,9,14 59:2 117:20 128:1 148:19 156:4 157:6,8 158:1 159:11 162:7 change 13:3,6 63:9 81:5,16,23 86:4 99:7 111:25 112:17 121:4 138:2,3 144:21 176:23 186:10 191:18 categories 33:24 changed 13:12 63:5 81:12,19 86:21 98:25 136:7 category 179:19 cause 13:16,20,24 63:24 68:14 73:20 149:3 195:8 changes 13:3,10 79:22,25 80:1,7,14,17 99:5 113:19 142:10 176:21 179:11,12 192:15 193:2 194:11 Brock 3:12 16:9,10,12,13 57:17 119:8 186:14 193:22 capacity 16:22 19:3 37:2 62:11 64:1 69:12 146:4 149:12 caused 35:12 90:17 91:11 brought 130:22 131:16 141:23 caption 167:20 Center 29:3,20 captured 115:7 cents 24:6,12 characterization 70:13 carbon 114:5 CEO 69:16 141:3 151:9 characterize 70:21 CEQA 112:20 113:14 115:16,20 116:1,7,8,10,1 7 117:2,4,6,11,1 4,17,19,20 118:1 characterized 49:4 132:9 budget 31:5,9 145:25 building 113:25 119:5 business 5:3 28:17 53:9,12,15,17, 19,23 54:7,8 55:20,23,25 56:3,15,17 57:18 58:5 66:17 91:11 109:24 121:22 135:3,16 147:7 158:21 177:16 card 82:20 care 58:23 59:2 106:4 109:24 140:3 carefully 111:24 112:12 113:2 cares 64:2 147:1 caring 136:21 Carmen 3:12 16:13 causes 74:21 Cell 87:14 certain 12:24 39:15 188:3 changing 177:9 charges 18:21 chatted 188:6,8 check 5:4 24:2 88:7 126:6 checked 19:22 checks 154:9 carrying 18:13 147:19 certainly 11:1 55:21 111:8 129:8 142:18 Chicago 10:8 17:15,16 18:4,13 49:4 busy 71:22 cars 43:2 certainty 109:7 buy 20:23 130:15 case 1:6 2:6 7:13 17:15 26:17 32:21 34:6,11,14 35:1,7,13 41:15 55:11 67:6 72:22 certificate 4:16 174:6,10 chief 69:9 77:8,19,22,24 78:10 79:10 141:11 bylaws 4:17 63:11,14 67:15 68:14 75:15 77:4 142:10 certified 1:22 2:17 193:20 195:3 certify 195:4 Peterson Reporting, Video & Litigation Services China 130:13 chins 112:23 circumstances 200 Richard Lawrence, 11-17-14 35:11 39:16 51:14 62:20 90:16,21 91:10 149:5 152:18 172:24 circumvent 171:7 citizen 133:12 134:6 clever 56:24 client 26:17 27:1,3,15,17 39:2 57:4 86:18 116:5 139:3 close 64:7 115:13 127:12 132:22 closest 54:14 citizens 126:14 133:15 134:9 coach 45:23 citizen's 112:22 coaching 45:25 46:14 Citizens 16:24 128:6 132:20 city 1:7 2:7 3:11,12 5:4 7:12 9:16 16:13,14 20:3,5,6,14,24 21:1,14 48:8 64:18 70:3,24 71:2,3,6 74:10 107:18 108:22 109:5 114:15 125:7 126:17 136:1 158:21 159:1,15 173:8,11,16,2 0,25 174:7,10,13,1 8,21 176:6 182:15 184:7,18 City's 68:4 71:13 civil 14:21,24 17:14,16 112:15 150:19 claim 38:15 116:10 152:9 174:16 175:7 clarification 8:13 26:15 clarified 46:11 clarify 168:25 169:1 170:20 cleanly 145:19 clear 16:5 74:11 133:23 182:12 clearly 11:8 53:1 131:21 142:19 171:1 177:11 178:20 clergyman 9:21 Coalition 20:13,20 29:5,6,22,23 49:11 74:7 21:13 46:14,20 186:12 commit 64:13 commitment 49:3 83:8 189:21 committed 48:17 68:14 committee 4:15 29:4,21 51:3,7,13 55:7 63:6,12 common 49:3 communicate 193:3 co-chair 20:14 49:12 communicated 94:2 Code 150:18 communication 20:5 37:15 38:13 39:5,8 41:23 137:19 163:17 169:25 177:1 178:3,19 coffee 60:8 COLANTUON O 3:7 collaborative 65:24 colleagues 48:12,13 146:11 collect 68:4 146:16 collected 70:3,23 124:13,18,23 collecting 146:18 collection 150:18 collects 146:20 College 10:3 comes 70:9 120:13 124:14 157:24 communications 28:19 37:16,19,20 38:10,14,25 39:11,12,24 40:9,10 82:9 93:20 105:23 community 29:4,22 31:5,9 118:18 company 18:17 competent 46:23 competition 142:6 conceived 20:12 concept 15:8 113:16 concepts 114:1 concern 70:11 83:10 114:9 115:4 151:10 concerned 48:2 71:18 119:3 120:19 123:1 142:5 165:2 concerns 35:18 72:24 conclude 191:18 conclusion 103:14 115:19 118:9,25 125:2 137:3 140:12,25 164:13 conduct 66:17 conducted 8:18 53:24 54:7 confer 165:9,15 166:16 175:22 consider 124:9 138:11 considered 20:5 consistent 71:7 103:2,10 111:17 consistently 16:6 180:10 constitute 55:22 118:15 constitutes 24:4 56:15 constituting 49:5 constitution 30:10 construction 114:1 consultants 129:8 consultation 56:12 66:18 contact 129:4 161:10,17 162:4 confers 175:12 contained 21:13 108:25 109:4 135:8,16 159:20 confidant 11:23 contains 195:11 confidential 37:17 39:3 105:23 137:19 169:24,25 178:3 content 36:12 39:1,8,23 41:22,24 91:18 105:22 137:18 163:17 confirm 175:25 context 39:9 133:19 conference 159:14 Confirmation 5:6 continue 127:10 confusing 12:2 continued 24:20 congratulatory 82:23 continuing 158:15 completely 149:12 conjunction 55:5 contrary 79:13 connect 115:1 complex 64:5 connected 133:1 contribute 64:19 121:11 comment 13:12 46:12 compliance 100:25 commentary 12:21 composition 98:24 connection 36:6 52:14 105:20 157:18 190:4 commented 29:16 compromise 68:3 coming 131:21 154:17,22 155:17 commencing 2:14 comments 20:6 complaint 5:7 172:15,17 179:14 consensus 165:3,5 consequence 106:6 133:23 Peterson Reporting, Video & Litigation Services contributed 147:23 contributing 176:4 contribution 58:23 59:3,9,13,16,2 201 Richard Lawrence, 11-17-14 0 60:4,9,11,15,2 5 61:5 contributions 60:22 61:2,9,13,24 62:4 controlled 78:2 convene 53:8 convenes 55:12 conversation 91:6 94:15,16,20 95:25 104:21 105:10,13 171:6,12 177:21 187:4,21 188:5,15 189:19,25 191:6,9,12 conversations 90:3,24 91:2 101:24 102:4 103:22 170:5 178:11,14 129:2 133:18 136:23 137:1 138:8,12 140:4,9,10 141:4,5 157:11,12,17 158:1 160:19 164:17,21,22 corporations 68:19 corporation's 78:3 136:4 138:3,4 correct 24:9 32:5 34:4 63:4 66:2 75:16 95:2 110:10 136:1 141:17 169:7 181:13 194:9 corrections 194:11 correctly 186:22 correspondence 67:5 93:23 106:17 cooking 24:20 Cory 3:3 7:18 19:8 25:18,21 38:12 56:14 74:7 86:15 134:16 146:10,20 151:1 168:11 177:2 178:4 copies 174:20 costs 74:13,17,18 copy 5:4 51:12 62:25 193:20 council 4:23 20:7,14 21:14 48:9 107:14 108:3 158:23 159:2,5 convicted 22:17,20,23 convinced 191:14 cookies 60:6 Corp 8:4 26:25 corporate 18:15 33:16 76:3,6,9,25 79:22 136:21,25 137:15,24 139:14,15,19 140:23 141:21 143:16 corporation 2:14 3:3,6 4:18 7:17 9:15 19:10 25:9 26:18,22 27:12 66:21 67:16 101:6,16,20 110:2 114:17 counsel 7:14 19:5,7 39:24 46:14 76:16 105:13,15 count 142:18 County 29:6,23 114:21 131:21 132:20 couple 21:24 22:3 85:14 87:19,24 90:7,9,11 130:5 course 11:14 46:6 87:13 88:13 141:18 187:20 court 1:1 2:1 3:16 7:7,21,24 8:2,16 11:9,12,21 12:17 14:23 15:2,3,5 17:22 18:11 34:5 41:11 42:22 50:20 64:1,5,15 71:10 72:22 74:13,17 108:6 153:7 159:25 182:2 192:7,9 193:15 114:12 142:13 CRR 2:18 195:21 dealing 40:8 55:14 CSR 1:20 dealings 46:6 161:11 Cunamay 99:19,23 144:10,12 current 56:1 59:11,14 83:22 96:13,22 101:22 143:5 149:2 153:10 deals 127:24 151:22 dealt 49:8 death 48:11 81:6,11,15,19, 22 99:1,10,14,16, 20 165:25 166:2,4,7,13,1 8 courts 72:23 73:8,12,15 112:18,19 currently 29:8 31:7,23 32:2,3 47:13 53:2 69:3,14,20 101:23 102:6 121:14 137:24 145:24 148:17 173:5 180:5 covenant 18:16 custody 193:14 decide 45:13 cover 23:22 74:12,17 customary 39:15 decided 18:19 168:3,7 169:5 177:6 courtroom 10:21 cut 11:6 163:9 covered 158:16 crafted 151:6 create 20:20 126:16 creating 20:21 creation 91:22 CREED 16:24 17:9,18 29:9,13 31:9 49:14,16,18,1 9,21,22 50:2,4,8,10 51:18,22 52:3,4,16,17,2 0,24 53:8,15,23 54:8 55:18 108:17,25 109:4,15,18 110:5,21 113:3 128:23 131:19,25 132:3 133:7 crime 22:23 crimes 22:20 criteria 83:2,5 84:5 183:5,19 critical 71:3 D date 7:3 10:6 21:2,5 38:16 39:11 59:19 70:14 81:8,10 96:12 103:21 104:3 122:11 165:21 166:2 167:10,13,15, 18,21 168:1,5,13,20 dated 4:22 21:15 195:14 dates 19:1 21:6 39:13 80:15,18,22 81:3 111:19 167:8 day 4:23 25:11,19 53:12 107:15,25 120:8 195:14 debtor 150:10 151:16 153:14 December 167:20 171:15 180:8,11 decision 45:1 46:3 47:4,8 136:17 138:2 166:25 167:3,4 168:17 169:12 decision-making 130:1,7 decisions 44:18 45:7,10 46:2 47:11 66:18 81:20 100:20 128:21 133:22 134:9 177:8,19,25 declare 194:7 decreasing 114:7 deem 194:11 deep 67:25 68:21 deeply 64:2 Defendant 2:13 3:6,11 days 21:3 44:17 58:22 74:6 173:7,16,24 174:4 192:12,14,21 Defendants 1:8 2:8 deal 132:11 define 55:19 Peterson Reporting, Video & Litigation Services defenses 151:18,20 202 Richard Lawrence, 11-17-14 defined 113:13 117:18 defines 53:2 definitely 97:17 degree 10:3,8 125:4 del 78:6 delegated 78:7 139:16 deliver 193:10 Dell 99:19,23 demand 20:20 demonstrations 14:23 17:14 18:9 depends 55:19 130:24 depo 27:8 33:19 deposition 1:14 2:12 4:10,12 7:10,22 8:11,17 10:13 11:9 14:17 16:23 19:10,18,21 21:20 22:5,9 23:9 24:8,18,22,23, 25 25:3,4,7,8,22 28:7 32:11 42:5,13 46:17,19 75:2,6 86:10 116:23 144:23 145:2 160:1 186:8 191:19 194:2,4,10 195:6,9 depositions 8:17 12:7 15:7 16:17,18 17:1,4,7,12,16 27:2 46:6 117:20 140:13 Deputy 16:13 describe 9:24 51:9 53:3 66:13 described 43:9 95:14 114:19 116:24 118:22 128:22 130:3 166:23 179:19,24 180:2,14,18,2 1,24 181:2,5 182:18 183:24 184:3 describes 128:23 describing 117:2,12 description 128:1 desegregation 112:18 designated 20:15 143:16 designation 65:5,6 designed 111:24 112:13 113:2 desk 28:13 Despite 125:14 destroyed 193:19 detail 5:3 135:17 138:11,13 detailed 64:11 details 131:25 138:6 142:3 determination 89:14 138:9 determine 40:23 83:3 167:11 168:2 determined 165:22 determines 83:12 84:3 development 16:25 29:5,22 113:7,12,17 114:18 115:10 116:25 117:13 118:22 119:2,6 126:16 127:22 128:7 132:10,21 8:18 9:16 27:19,23 48:15 51:1,5 63:15 75:15 114:14 135:5,24 141:6 Diego 1:7,15 2:7,13,16 3:6,11,12,13 5:5 7:1,9,12,17 9:11,14,17 16:14 26:18,21 28:10 29:6,23 31:18 48:1 70:4 114:15,16 115:5 126:17 132:24 136:8 164:20 173:8,12,17,2 0,25 174:7,10,14,1 8,21 180:5,7 184:7 195:14 discussing 60:14 106:7 147:2 170:14 190:21 dining 15:25 discussion 46:15,16 65:24 66:3 82:18 88:17 94:11,14,25 95:3 120:7 151:15 170:21 188:12 189:22 dinner 25:2 dinnertime 24:19 dipped 172:22 direct 47:1 66:17 125:8 171:12 directed 44:23 directing 170:19 direction 164:18 195:11 directly 48:24 71:18 94:13 154:1 directors 37:3 104:8,10 120:15 141:16,20 dis 117:10 Diego's 5:1 disagree 117:10 150:24 177:2 differ 130:2 160:4 disagreement 128:25 difference 15:19 16:2,5 27:10 142:1 disclose 37:19 38:9 differences 109:18 110:11 different 13:7 27:7 56:4 63:22 67:21,23 68:7,18 105:18 106:1 109:10,15 128:20 131:15 133:21 140:21 141:25 159:9,18,20 167:11 differentiated 170:25 difficult 50:19 132:1 devoted 147:19 difficulty 131:18 died 48:2 60:23 dig 159:23 160:17 Diegans 1:4 2:4 4:17 7:11,19 dime 148:11,12,14, 16 Dillon 5:2 disclosing 91:2 discoverable 117:9 130:14 discovered 128:1 discovery 3:17 7:21 8:3,6,10,14,19 34:13,15 86:10 116:12 117:6 121:23 149:9,13 150:20 151:2 178:21 discuss 60:16 91:25 171:10 191:5 discussed 32:13 33:9,14 60:18 76:2,5,8,25 90:14 92:10 100:15 122:15 169:16 190:9 191:8 Peterson Reporting, Video & Litigation Services discussions 21:1,3 32:25 33:1,4,21 74:11 91:9 94:8,24 100:5 101:18 105:18,22 191:11 dislocation 115:11 dismissed 92:21 disobedience 14:24 17:14 dispose 133:14 Disruptive 5:1 distinction 74:16 83:15 97:23 132:2 District 2:14 3:6 7:17 9:15 20:1,11 21:2 26:18,21 27:11,12 35:19 114:17 124:1,6,14,24 125:16 126:2 164:21 174:22,25 175:4,9 184:11,15,21, 24 185:2,9,15 diversion 118:13 123:10 124:5 125:11 diversions 123:22 divert 147:4 diverted 123:19 134:4 diverting 124:12 Divinity 10:8,10 divulge 175:17 203 Richard Lawrence, 11-17-14 document 4:23 5:3 23:8,17 31:25 33:19 34:15 35:4,24 36:6,13,22 39:20 42:7,13,24 43:16,20,22 44:17 51:16 52:5,11,13 55:10 56:24 62:14,21,22,2 5 75:18 77:5,11 79:3 102:19 107:6,24 108:3,6,13 111:15 134:11,19,21, 24 135:12,15,18 154:3 158:5 160:25 161:14 172:5,20,25 documentation 82:25 documents 25:25 26:6,7,9,12 28:5,6 32:3,7,9,14 33:10,14,15,2 1,24 34:3,6,14,25 35:8 36:25 38:2,5 40:1,6,15,23 41:5,8,9,19,21 43:2 51:6 57:3,14 100:2,6,17,21 106:20,24 107:3 140:3,7 163:25 164:5 167:23 document's 111:20 Documents 4:11,12 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155:11 185:20 189:23 190:23 email 53:5 82:8,9,24 93:16,20,23 94:2 95:13,20,21,2 3 96:2,9,11,14,1 6 emails 19:25 20:10 21:11,13,23 26:5 45:8 95:20 embroidered 192:1 emergency 49:6 115:7 118:19 domain 177:12 editorial 46:20 emissions 114:5,6 donations 61:13 educational 9:24 employees 18:18 done 27:7 28:18 59:25 86:9 113:13 146:14 153:16 159:3 effect 146:5 enabled 59:13 effective 73:8 encouraged 153:1 effectively 68:1 117:12,13 128:6 especially 46:5 ESQ 3:3,8,12 essence 131:4 essentially 82:8 145:24 establish 129:24 engagement 18:8 59:17 112:15 established 56:25 enthusiastically 191:2 estimate 15:4,6,14,17,1 9,24 16:3,6 21:4,10,14,16, 25 47:19,22 50:24 53:18,21 54:21 65:9 95:16 97:1,5,10 98:14 104:4 166:11,12 entire 186:8 estimated 17:7 entirely 46:8 152:11 et 1:7 2:7 7:12 entitled 4:23 9:16 15:11,13 38:13,17,22 39:7 86:19 107:25 151:20 168:20,25 event 152:15 entity 5:3 27:16,21 135:3,5,17,21, 25 136:1,7,18 155:18 exact 15:12 123:12 167:10,13 168:5 169:4 172:8 entrust 109:25 exactly 15:22 16:4 entered 158:7,13 enterprise 134:5 entertained 121:12 entrusted 139:24 environment 114:12,13 115:8 118:17 environmental 16:25 110:1,6 113:7 114:18 116:25 117:13 118:7,15 128:7 e-Postcard 5:6 ethics 10:9 everything 23:22 96:21 evidence 83:10 128:15 148:4 exam 150:10 151:17 EXAMINATIO N 4:4 9:4 186:17 187:12 example 74:13 138:17,19 139:1 examples 159:22 equally 128:2 exchanging 156:3 equitable 16:25 113:7,14 114:18 116:25 exclude 32:25 76:13,16 170:5 Peterson Reporting, Video & Litigation Services 204 Richard Lawrence, 11-17-14 excluding 76:24 expense 146:3 excuse 24:3 52:15 87:16 117:12 135:8 138:3 159:18 177:25 188:24 expenses 58:24 59:11 146:16,20 157:9 Executed 194:14 executive 69:10 77:9,19,22,25 78:10 79:10 141:11 exhibit 23:8,9,10,13,2 4,25 25:8 42:8,10,21 52:6,7,9,10 62:15,16,18 63:3 75:19,21,23 76:1 77:4,12,13,15 78:16,19,21,2 3 79:2,5 102:20,21,23 103:1 107:7,9,11,13, 24 108:1,18,22 110:22,23,24 111:4,7,8 126:5,6,9 130:3 134:12,17,20 135:8 141:8 154:4,5,7 160:23 161:1,2,5 172:6,12,15,1 8 EXHIBITS 4:9 experience 17:8 68:17 109:22 159:17 experienced 15:24 explain 120:4 126:22 falls 171:2 183:19 false 127:10,11 falsified 43:1 familiar 9:18 63:23 67:22 68:8,9 143:17 familiarity 51:15 families 118:17 explained 12:16 fee 24:5 explanation 117:2 feel 11:23 13:3 192:16 express 121:13 159:2 feelings 176:2 expressed 123:1 extent 37:18 40:18 90:23 101:8 128:10 140:16 extreme 115:6 F f.213.542.5710 3:10 f.619.236.7215 3:14 facing 71:3 142:25 fact 13:12 43:9 87:12 106:2 125:6 154:18 157:1 165:13 169:15 170:14 exist 32:7,8 33:25 34:3 39:12 40:23 41:19 factor 176:4 existence 19:12 41:3 113:3 factual 177:22 178:9,13 expect 43:4 151:25 fail 71:6 expectation 142:16 failure 74:9 118:18 expected 162:9 fair 39:13 171:3 expecting 140:14 fairly 28:20 35:8 48:9 99:9 165:6 expedition 41:14 116:13 fall 36:3 70:12 179:18 183:5 facts 15:23 128:14 148:4 failed 125:9 faithfully 112:24 fees 23:20 24:4 146:12 156:8 157:8 185:1,3,5 felony 22:18 felt 129:7 Ferguson 18:5 fewer 53:16 fifth 111:22 figure 129:17 130:6,12 182:20 file 28:12,13,14,2 1 29:12 31:7 41:11 128:22 164:24 165:20 166:21,25 167:3,4 168:3,7,17 169:5 filed 19:2 34:6 41:12,14 129:12 130:25 131:15 135:23 159:10,21 160:5 166:6,13 167:5,7,12,19 168:4,8,18 169:9,16 170:2 171:15,23 174:6,9 files 28:10,24 29:20 30:2 31:14 32:2 126:18 filing 71:25 72:13 73:11,14 157:22 158:19 167:14 169:13 171:11,19 filings 140:3,8 142:4 163:7 fill 82:14 160:6 filled 92:5,8 Finance 142:22 financial 58:11,17,19 62:7 64:12 79:11 finding 36:21 56:24 fine 37:14 73:22 76:13 104:23 105:14 130:10 156:9 163:16 179:3 finish 11:15,17 73:14 150:8 151:15 finished 11:5 25:1 53:12 106:9 113:23 fire 127:11 firm 130:22 131:17 139:16 146:14 162:18 first 9:2 20:12,25 30:8 48:8 50:25 69:21 90:4 110:20,21 128:4 143:9 165:13,19 166:14,20 171:5 181:6 189:4,8 195:7 fish 151:2 fishing 41:13 116:13 150:25 151:2 152:25 fit 26:3 five 65:11 66:11 five-minute 86:18 flow 11:19 Peterson Reporting, Video & Litigation Services focus 58:14 68:1 70:25 72:23 73:9 83:24 142:2 178:2 focused 70:22 focuses 110:5,8 focusing 127:23 folks 68:12 88:2,12 115:8 follow-up 29:18 follow-ups 187:10 Foods 18:14 foregoing 194:9 195:6,8,11 forget 49:22 forgettable 132:25 forgot 25:14 87:15 forgotten 79:1 form 12:22 89:19,21,22 90:6,18 91:13,16,19,2 3 92:2,4,7 192:6 Formally 82:7 forms 162:15 formulation 176:9 forth 11:18 45:9 Fortunately 127:12 forum 133:22 forward 46:17 85:11 126:13 129:19 131:10 141:23 forwarded 61:10 Fourteen 172:10 frame 54:1 192:18 Franchise 4:21 102:12 103:12 104:15 106:17,21,25 107:4 161:11 162:4 163:6,25 205 Richard Lawrence, 11-17-14 164:4 frankly 96:19 free 37:21 156:11 178:16 frequency 39:23 frequently 35:9 48:9 fresh 192:1 friends 48:12 friendship 190:22 front 126:7 fruitful 153:18 full 163:8 fully 112:24 165:6 175:24 function 68:12 69:24 70:2,16,22 145:24 146:22 functions 67:24 70:6 71:14 fund 124:11 funded 125:20 funds 20:17 59:1 124:10 145:16,18,21, 22 146:21 147:21,23 157:2,8,10,13 164:16 furnished 103:4 Furthermore 44:25 future 36:11 149:11 150:11 G game 39:13 games 167:22 58:22 94:14 120:10,11 121:2,5 124:1,6,10,11, 12 130:11 158:3 159:5 162:10 179:4 188:10 189:22 generally 80:21 121:6 127:6 185:6 generate 74:17 generated 34:14 91:18 126:2 governmental 133:25 generically 105:14 graduate 10:7 generosity 58:25 generous 59:6,8,12 German 10:5 gets 130:1 155:17,24 159:10,16 177:4 getting 11:18 30:7 73:8 116:10 128:13 140:17 155:14 156:10 gift 59:21 given 13:2 14:16 15:2,7 16:17 17:1,4,12 46:6 86:4 105:19 147:22 152:14 170:1 183:3 grandstanding 43:8 greater 129:8 greatly 18:4 greenhouse 114:5 grounds 32:17 40:21 45:3 56:23 76:11 100:9 101:9 105:9 130:5 137:17 138:25 163:13 170:3 175:15 group 31:9 68:11 112:23 126:14,17 133:14 giving 13:7,17 24:2 57:4 62:14 group's 126:12 129:18 glad 160:12 goals 71:7 83:8 gas 114:5 Gosh 107:19 gather 53:7 58:5 68:12 gotten 42:18 54:25 88:1 182:11 general 8:20 Grand 3:8 groups 128:15 gone 130:25 147:6 152:19 geez 172:8 graduated 10:1 gives 37:15 gap 115:13 gathering 58:8 144:1 145:8 2:4 4:18 7:12,19 8:18 9:16 27:19,23 48:3,16,18 51:2,5 63:15,24 70:9 73:21 75:16 83:11 110:2,8 114:15 132:11 133:10,23 134:3,8 135:6,24 141:6 governance 137:25 139:15,19 government 1:4 guess 8:21 15:18,19 16:1,3 47:22 48:19 55:20 126:23 127:9 128:14 130:4 157:25 166:8,9 168:10 guessing 162:9 guttural 83:7 guy 167:16,21 168:10 health 136:21,25 H half 14:25 15:3 16:17 53:20 98:14,19 HALL 1:2 2:2 hand 74:22 109:25 142:3 handle 139:16 handled 138:12 handling 140:7 192:8 handy 10:5 healthy 142:4 hear 128:17 142:13,15,16, 22 186:22 heard 48:8 57:6 99:24 113:6 143:1 149:19,24 166:14 183:11 190:8 hearing 18:7 held 63:19 64:23 65:1 Hang 30:5 32:16 56:20 86:6 101:7 111:2 116:9 128:3 138:18 163:4 help 74:8 168:6 182:17 Hanover 10:2 Here's 31:17 happen 15:15 25:10 52:20 53:11 88:17,18 178:9 188:25 192:9 he's 40:5 41:6 57:10,15 69:8 90:20 116:16,17 122:7 135:11 138:25 139:9 169:19 178:6,24 happened 13:25 14:4 17:24 37:6 50:16 52:19 169:17 happens 131:24 156:4 happy 74:24 170:6 harassing 151:3,4 helps 20:20 hereby 195:4 hesitant 34:8 Hi 16:10 hide 168:9 High 10:1 HIGHSMITH 3:7 hint 191:3 hard 64:17,21 hired 42:25 hardly 132:25 historically 143:1 155:24 159:17 harmony 142:9 haven't 59:9 74:15,17 77:2 94:10 164:2 170:25 having 9:2 26:9 58:13 59:14 77:3 86:2 87:22 146:1,4 147:4,8 148:24 161:12 170:13 176:4 head 125:24 159:24 guys 86:16 Peterson Reporting, Video & Litigation Services history 63:17 64:16,22 112:15 146:1 Hmm 23:3 hold 23:1 65:2 66:20 133:15 190:10 home 9:10 16:1 20:23 26:13 31:15 144:3 HON 7:20 8:8 32:24 39:25 206 Richard Lawrence, 11-17-14 41:2,4 42:1,9 46:12 57:8,13,22 76:15 87:1 90:23 117:25 118:3 122:6 130:20 131:3,6,8 137:8,21 139:7 149:15 152:22 153:17 163:20 170:12 177:15 Honor 32:23 39:6 40:22 41:17 42:2 45:21 57:7 117:23 122:5 130:19 137:7 139:6 149:14 152:21 170:11 177:14 HONORABLE 3:16 honoring 107:14 hope 176:3 hopefully 114:11 hotel 74:9 124:2,7 173:6,11,15 174:6 184:6 hotelier 173:23 174:3 hoteliers 125:9 hotels 173:19 hour 2:14 house 18:10 26:11 145:9 housing 20:13,16,19,2 1 29:6,23 49:2,5,11 74:7 115:5,6 118:13,15,16, 19 119:5 123:9,12 124:25 125:8,12,14 173:5,10,14,2 3 174:3 hypothetical 149:10 152:18 I Ian 47:18,23 49:16 58:22 59:4 60:16 61:1 64:8 66:7 79:9,17 82:12,18 91:21 166:2 186:25 187:19 188:9 189:16 190:4,22 191:2 Ian's 60:3,14 99:1 187:3 188:15 189:19 I'd 21:9 47:7 88:23 97:6 128:17 166:12 179:14 185:17 186:12 idea 16:5 169:14 identified 122:12 165:8,14 182:6,15 identify 7:14 64:13 79:19 identifying 123:4 identity 42:19 I'm 7:20 8:8 9:13,21,23 11:3,5 14:15 15:13 16:21 20:13 21:6 23:7,21 24:2,13 25:1,5 26:20 27:15,22 28:9 29:8 30:5,11,15 31:3,13 32:16,21 33:7 34:10,15,21,2 2 35:24 37:12,19 38:13,17,22 39:3 40:17,20,22 42:7 45:2,16 46:18 51:17 52:2,4,5 56:22 57:4,8 59:25 60:2 62:1,5,9,14,23 65:3 73:18,21 74:24 76:10,21 77:11 78:12,15,19 79:25 80:14 85:7 86:6,8,19,23,2 4 87:3,25 90:19 91:20 93:12 96:4,10,11 97:15 98:9 99:9,17,21 100:4,8,12 101:8 102:14,19 105:8,17,21 107:6,22,23 108:2,8,11,19 110:22,25 111:19,22 113:22 116:3,22,23 117:2,14 118:12 119:3 121:20 122:22 123:13,24 126:21 128:3 129:17,24 130:4,16 134:1,11,19 135:10 137:2,4,16 138:20,24 139:4 142:1 147:15 149:8 150:1,7,22 151:3,7,20 152:12 153:2,12 154:3,15,16 155:4,20 156:5,12 159:3,23,25 160:25 162:9,23 163:12,15 164:9 165:6 166:3,4 167:10,24 168:11 170:2,8 171:4 172:5,6,22,23 175:14 176:14,20,23 177:5,10,12 178:7 179:4,9,12,15, 16,17 181:13 182:2,4 185:5 188:3 189:1,6,7 191:14 immediately 11:5 24:24 44:13 46:3 150:15 impact 112:19,25 113:15 146:22 implementation 109:25 implemented 112:24 important 11:7,15,24 15:17 63:21 64:21 86:17 148:19 impression 8:9 inability 115:12 inaccurate 127:20 inappropriate 86:9 178:20 incident 88:22 incidental 59:11 106:5,13 incorrect 170:13 increase 125:15 increasing 18:17 114:6 125:15 incurred 148:21 independent 48:1 85:2 102:5 135:9 175:21 183:4,9,16 indicate 120:22 141:10 indicated 40:5 95:25 121:1,12 148:22 187:16 indicating 43:18 indication 83:16,20 indicia 82:23 117:11 indirect 62:7 incidents 14:23 indirectly 48:25 inclined 59:25 individual 83:19 99:18,22 114:7 158:2 159:4 166:15 175:22 include 41:23 46:9 93:24 100:11 105:14 151:19 163:14 included 32:10 94:19 114:1 117:1 includes 40:18 41:24 including 63:18 125:13 155:3 income 115:9 individually 129:9 individuals 68:25 87:20 121:12 149:3 176:12,14,15, 17 industry 20:22 incompetent 43:1 influence 129:7 134:9 incorporate 191:22 information 4:19,20 6:9 30:8 44:11 46:7 84:25 102:9,15,16 108:21 118:4 131:10 135:7,16,18 160:13,18 161:25 171:4 175:17,19 183:2,14 incorporated 20:6 incorporation 4:14,16 51:12 62:12 63:1 67:11 103:2,10,20,2 4 104:6,7,11,14, 19 105:3,6,25 Peterson Reporting, Video & Litigation Services Initiatives 207 Richard Lawrence, 11-17-14 29:3,20 in-kind 61:13 instance 31:4,5 112:21 114:4 instead 125:16 147:18 167:16,21 instruct 12:6 32:22 40:20 45:18 57:5 76:11 86:6,23,24 87:3 100:9,12 101:10 105:15 130:17 137:5,20 139:4 150:22 163:15 170:3 177:12 instructed 5:10 6:1 137:13 instructing 37:19 39:3 163:18 179:4 instruction 38:9 101:13 137:18 intend 142:2 145:18 intending 146:4 intention 59:23 intentions 59:22 interest 83:16,20 88:15 121:13 129:1 184:6 188:10 interested 87:20 88:12 120:12 interesting 106:11 152:22 interests 82:8 Interfaith 29:4,21 interject 46:12 international 192:21 interpose 12:5 interrupted 113:22 55:13 invading 150:3 177:11 invited 121:21 involve 38:11 involved 29:10 30:1 31:10,13,14,2 3 48:22,23 49:8,20 50:23,25 56:19 57:19 63:8 73:3,16 96:22 98:7 108:16 110:15,19,21 130:16 132:23 153:20 156:18 171:6 177:20 involvement 19:15 48:20 62:11 63:18 108:25 109:3 129:11 158:9,12 involving 14:24 186:20 irregularities 151:12 irresponsible 166:9 isn't 64:22 70:25 88:8 116:10,17 117:8 133:11 146:23 issue 11:2 20:11 23:3 40:4 41:2 53:1 64:1,3 70:11,15 72:20 85:6 90:17 100:15 103:17 105:20 114:8 115:10 118:16 119:2 123:8 129:5 130:23 141:22 142:12,14,21 146:15 152:5 156:16 159:12,16 164:10 165:18 171:8 interruption 87:14 127:8 issued 154:10 introduced 51:17 issues 13:20 14:3 17:17 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jogs 136:15 join 64:9 82:6 83:13 84:5 120:16 joined 85:3 joining 88:5 jointly 133:4 judge 3:16 7:20 8:1,5,10 42:18 120:8 150:16 152:12 153:13 171:3 177:24 179:1 judge's 12:19 177:21 178:7 judgment 150:16,18 151:16 153:14 judgments 149:18,19 151:24 July 79:8,23 80:2 Peterson Reporting, Video & Litigation Services June 42:14 43:13 44:20,22 47:6 justice 1:2 2:2 29:4,21 31:16 146:6 K Karin 69:22 78:17 143:9,13 145:12 154:1,14,19 kinds 132:12 kitchen 24:20 knew 35:17 127:21 knowledge 8:6 15:23 33:13 54:17 77:7 85:2 91:24 92:23 102:6 103:16 106:15 109:19 135:9,22 136:10,13 175:21 176:22 183:4,8,16 known 51:4 176:2 L land 114:10 landscape 113:21 Langwasser 78:17 143:13,18 144:17 145:12 154:1,14,19 largely 43:1 125:9 last 21:24 22:2 25:14,17 42:5,14 43:13 54:10,18 66:10 84:9,19 85:3 87:19,24 88:23 89:12 97:8,17 98:6,10,17 143:10,22,24 191:23 lasted 18:21 later 25:19 44:13 208 Richard Lawrence, 11-17-14 195:10 law 3:3 19:9 24:6 25:9 39:10,14 61:21 66:22 67:7,12 90:3 91:2,6,9 93:25 96:1 110:2 121:17 129:2 130:22 131:17 136:4,22 137:1 138:7,12 139:16 146:7,9,14 148:18 157:11,12,17, 25 160:19 161:23 162:1,18 170:23 178:8 Lawrence 1:14 2:12 4:2,10,23 7:11 9:1,8,10,13,20 13:15 14:16 16:16 19:2,20 22:17 23:7,12 24:2 32:1 39:16 40:14 42:4,12 43:12 47:13 50:22 52:9 58:1 62:14 75:2,6,10 76:2,20,24 77:16 85:24 87:6 100:24 102:19 106:16 107:6,15,25 110:22 111:5 118:6,21 119:16 123:8 126:23 134:14,19 137:13,23 139:14 144:23 145:2,5 148:7 149:17 153:21 154:3 161:1,2 163:22 169:3 171:10 172:5,14 176:19 177:9 179:13 184:5 186:4,19 187:14 192:4 193:25 194:2,7,16 L-A-W-R-E-N- C-E 9:9 86:22 Lawrence's 41:20 led 189:23 190:23 laws 134:8 194:8 legal 35:20 55:20 56:13,18 57:19 58:5,8,14 66:19 67:10 68:2 71:5,9,11,12,2 4 72:5,14,20,21 73:2 74:18 103:13 105:19 112:17 115:18 116:2 118:8,24 125:2 129:5,8 130:23 133:11 137:3 140:11,25 142:4 152:12 158:22 164:12 lawsuit 9:15,18 13:11 27:18 114:14,16,17, 20,22 115:17,19,25 116:6 117:3 118:21 123:9 129:12,13 130:8,25 131:15,22,24 133:4 146:15 150:12,13 154:18,22 155:10,17 157:14,19,23, 24 159:10,21 164:8,10,15,2 5 165:3,11,20 166:6,21 167:4,5,7,12 168:4,7,8,18 169:5,8,15 170:2 171:11,14,19, 23 175:13 lawsuits 19:3 72:1,14 73:12,14 126:18 128:21 129:1 130:2 146:13 153:23 154:10 156:19 158:19 160:5 lawyer 5:1 46:3 116:3 151:25 lawyers 38:11 163:14,15 leadership 63:18 64:23 99:8 146:11 legislation 112:22 legitimate 151:7 152:5 119:21 122:15,23 166:22 186:21 187:1,4,15 188:18 line 5:11 6:2,10 109:12 160:8 lots 146:24 147:6 listed 32:14 56:2 77:19 79:9 95:13 108:18 141:3 151:8 161:10,16,24 162:3 166:15 175:11,21 183:5 Listen 151:14 listing 141:11 little 34:8 37:24 105:17 127:21 131:14 153:18 182:10 liabilities 151:22 liability 148:20 149:7,11 Litigation 7:6 live 126:15 living 58:24 114:13 118:17 local 23:4 126:17 locate 21:18,23 26:6 located 7:8 28:8 location 111:1 leads 26:15 Liam 5:2 locations 26:7 learned 90:20 liberal 153:2 least 8:5 81:2 88:15 license 23:2,4,5,6 licenses 23:1 log 38:14,16 39:10,15,19,2 0 40:3,7,10 55:20,23 56:3 leave 18:19 30:14 100:11 117:25 136:22 160:1 life 113:15 130:6 logs 57:16 lifetime 108:15 leaves 160:9 Linda 89:1,2 92:8,11,13,14, 17 94:3 long 15:20,22,25 16:18 26:17 27:20 54:3 84:8 88:21 146:1 151:2 167:4 leaving 18:20 light 125:6 lost 99:1 193:18 list 33:20 82:9 93:13,16,20 95:13,21,24 97:7 136:17 140:14 176:5,10,13,1 6,22 177:9 179:11 let's 25:2 85:8,13 127:13,14 192:1 level 101:19 169:17 Los 3:9 lot 106:6 lists 108:13,15 letters 20:2,4 21:12 158:22 159:8,19 longer 31:3 148:23 186:11 links 126:14 less 173:7,16,24 174:4 letter 4:21 82:24 103:21 168:2,7,17 169:11,12 Peterson Reporting, Video & Litigation Services lower 115:8 low-paying 20:21 lunch 75:4,8,11 luxury 148:24 M machine 195:9 maintain 26:12 32:3 165:10 193:14 maintained 100:18 maintains 93:13 manner 128:22 marked 4:9 23:8,9,10 42:8,10 52:6,7 62:16 75:18,21 77:4,12,13 78:21 102:20,21 107:7,9 110:24 134:12,17,20 154:4,5 160:23 161:1 172:11,12 marketing 2:14 3:6 7:17 9:15 20:1,11 21:1 26:18,21 27:11,12 35:19 114:16 123:25 124:2,6,7,14,2 0,24 125:16 126:2 164:21 174:22,25 175:4,8 184:10,15,21, 24 185:2,9,15 marking 110:22 209 Richard Lawrence, 11-17-14 172:6 Maryland 74:9 Massachusetts 10:2 Master 10:8 Master's 10:4,10 Mastrobattista 1:20 2:17 7:8 195:3,20 material 28:12 materials 19:23 20:3 21:18 152:12 174:21 182:8 matter 7:11 8:7,8 17:5 18:11 40:20 114:9 138:11,16 143:25 152:15 159:16,23 165:16 166:9 170:23 178:8 matters 38:2 106:7 117:2,4 136:5,21 137:24 139:14 140:10,23 may 5:2 7:24 10:18 11:3,6,18,19 12:4,6 13:25 14:4 15:12,21 22:5 24:12 33:5 34:9,17 38:1 40:3,25 52:18 57:23 59:7 63:19,23 67:22 68:7,10 70:10 78:25 84:25 99:12 100:2,6,21 102:4 105:19 106:21,22 111:14 112:17 136:16 148:23 149:1 150:14 151:10 158:23 159:12 163:9 168:14,23 173:1 175:19,22 176:3 181:22 182:11 183:2 193:14 maybe 14:25 16:20 21:9,10 46:13 53:20 57:20 98:19 140:21 145:15 152:7 mayor's 158:24 mean 32:17,18,20 35:23 45:1,4 46:18 47:20 48:14 50:1,3 60:8 67:22 70:21 71:9,10 72:8 74:3,6 76:20 112:12,14 113:10,17 129:15,16 146:8,17 156:8 162:11 164:9 169:3,24 177:4 meaning 68:25 69:1 113:20 means 81:25 82:2 93:5 113:11 116:25 118:23 121:16 127:9 136:3 141:1 175:24 meant 46:9 117:13 163:14 measure 15:21 mechanism 72:24 111:24 112:13,25 113:2 Media 75:1,5 144:22 145:1 94:5,12,25 96:3,10 98:11 99:10,12,13 120:18 121:5,10,18,1 9 122:8,10,12,1 5 123:5 129:22 132:12 144:2,6,15 145:10,13 166:22 167:1 170:13,14,24 171:21,24 173:1 177:4 186:20,24 187:5,22 188:3,4,18,22, 25 191:14 meetings 21:14 49:17 52:14,19,21 53:4,11,15,18, 19,22 54:2,4,7,8,9,13 ,22,24 55:18,21 64:10,11,17,1 8,20 81:12 83:19 88:11 90:14 92:18 96:15 97:8,14,16,19, 21,22,24,25 98:2,8,15,18,1 9,20 99:7,15,19 119:22 120:25 121:2,3,8,13,2 1 126:12 129:18 132:5 143:11 169:20 medication 13:15,23 meets 84:5 98:3 meet 48:6 58:12 63:24 70:23 71:6 73:20 121:21 member 16:24 37:2 47:13,16 49:10 81:13 82:11,18 83:4,14,16,23, 25 84:6 87:21 88:15,18 89:4,12,16 92:14,17 94:7,22 95:7,10 98:3,12,21,25 99:3,4 116:24 119:24 120:2,5,20,22 meeting 18:15 28:18 51:18,22 52:17,23,24,2 5 54:18,25 55:3,12 60:6,7 65:17,20 66:8 74:10 80:21 87:22 88:13,18 89:3,11 92:16 mem 188:24 122:21 123:2 141:16 151:7,8,21 152:5,17 157:13,21 165:9,14 166:22 181:24,25 182:5,18 183:19,24 184:3 187:16,23 188:14,16,19 189:3,10,12,1 5,24 190:4,19,24 191:4 members 8:17 33:10 48:15 59:15 66:4,5 68:25 69:19 82:4,6 83:17,22 84:15,18 85:3,6 88:5 93:14,17,21,2 4 94:17 96:12,24 97:20 98:16 121:17 158:23 159:4 164:25 165:4 166:16 170:19,21 176:6 183:5 186:21 187:1 member's 120:9 membership 81:23 82:1,14,20,23 83:2 87:7,9,22,25 88:14 89:19,21 90:5,13,18 91:12,16,22 92:7,10,22 97:7 98:1,2,8 120:10,11,14 121:2,6,10 187:20 188:12 189:2 memberships 92:25 93:6,11 memorial 186:25 187:3,14 188:6,15 189:7,19 190:1,7,12,17, Peterson Reporting, Video & Litigation Services 25 191:12 memorialization 55:25 memory 73:7 136:15 191:15 mention 30:9 47:7 50:7 63:21 mentioned 15:1,8 29:9 62:23,24 66:16 80:22 81:3 83:6 115:3 120:13 142:8 146:10 MERIT 1:21 message 25:18 146:22 met 9:14 48:7 71:22 74:7 82:12 143:18,22 189:3,4,6,8,10 Methodist 9:21 Methodists 23:3 Michigan 10:4 mile 24:6 mileage 24:10 milestone 166:5 milestones 167:11 mind 110:14 146:1 minimum 46:20 ministry 9:22 minor 10:5 58:24 minority 18:17 minute 23:21 151:14 minutes 64:11 66:17 67:4,8,13 68:13 85:14 160:21 mischaracterize d 128:12 mischaracterizin g 44:24 misquoted 112:10 127:16 210 Richard Lawrence, 11-17-14 128:11 misquoting 128:7 misrepresenting 86:16 157:1 moneys 124:18 156:2,22 157:3 Monica 136:7 110:13 121:22 156:25 non-monetary 61:12 62:3 nonprofit 68:18 109:11 146:24 missed 97:17 189:21 month 54:15,16 97:11 mission 147:3,11,12,1 3,14,20 monthly 54:15 126:12 129:18 months 165:17 nor 108:17 Missouri 18:5 moral 22:21 normal 67:2 misspoken 59:7 morning 7:2 note 115:19 misstates 96:5 161:13 motion 45:9 notebook 55:24 mouth 148:3 nothing 127:22 133:17 145:25 149:11 150:11 152:18 153:15 195:8 misstating 148:3 187:25 Move 153:17 mistake 78:14 141:13 147:14 movement 14:21 112:15 mistaken 43:5 51:17 52:18 188:21 189:1 moves 46:16 misunderstood 57:20 181:22 moment 25:13 31:6 33:2 58:12 70:11 110:14 131:18,20 Murrieta 127:22 mutually 8:14 notices 96:14 myself 78:13 118:12 134:2 notification 185:14 Moving 181:4 multiple 49:19 Monday 2:15 7:1 monetarily 153:7 National 18:14 money 5:1 27:4 59:15 74:12,17 119:4,5 124:13,23 146:2,6 147:5,7,10,11, 13,18,25 148:2,5,8,10,2 5 149:6,10 150:11,17 151:6 153:10,15,25 154:13,17,21 155:9,16,21,2 3 156:3,14,15 Nope 173:4 notice 4:10,12 14:10 42:13,14 53:5 54:25 96:2,9 193:16 N narrow 76:12 monetary 60:4,9,14,22,2 5 61:2,5,8,17,20, 24 185:8,10,14 nonprofits 146:2 147:6 natural 46:5 nature 13:10 17:11 18:2 nearly 54:16 necessarily 16:4 55:16 necessary 64:4 73:25 74:5 84:6 192:16 194:10,12 neither 108:17 newspaper 20:2 111:11 126:7 Nobody 152:9 Nobody's 137:4,6 non-attorneys 37:21 none 14:15 93:12 November 1:16 2:15 7:1,3 O oath 10:14,20 75:12 85:25 119:19 145:6 186:5 object 12:4 32:16 37:12 40:17 45:2 56:22 57:5 71:16 76:10 90:19 96:4 100:8 101:9 105:8,15 121:20 128:3 130:4 135:10 137:2,16 138:24 149:8 150:1 153:12 156:1,5 163:12 170:3 175:14 176:23 177:10 objected 131:1 objecting 57:13 objection 12:6,20 22:12 30:15 32:22 38:8 39:25 40:11 41:18 42:1 44:21 46:25 57:22 72:10,16 76:16 81:8,24 87:1 103:13 109:20 115:18 116:9 118:8,24 122:6 125:1,21 129:15 137:8 139:7,18 140:11,24 148:1 150:8,21 153:17 155:2 163:20 164:12 166:1 167:6 177:15,24 178:8 179:2 187:25 objectionable 41:25 46:21 145:9 occasions 14:19,22 17:24 19:13 37:5,7 38:4,19 98:10 143:20 162:19 OCCORD 132:19,20 133:1 occupancy 20:15 123:20,21 125:6 174:9,13,17 184:18,23 occupation 9:20 occur 21:23 22:10 37:5 53:4,22 54:9 59:16 104:2 occurred 51:21 53:22 54:2,9 63:9 81:6 90:16 98:21 99:7,16 105:3 125:16 154:16 188:22 objections 12:19 45:19,23 125:9 178:6,23 occurring 19:18 35:12 91:11 obligation 66:21 184:9,13,17 October 103:21 104:20 106:14 obligations 41:6 66:24 offer 140:19 observation 46:13 obvious 112:19,21 157:1 obviously 14:9 26:8 28:11 54:15 56:12 57:3 66:21 98:4 99:1 113:18 114:10 116:3 121:11 127:21 146:15 159:1,12 162:6,19 occasion 49:13 52:22 70:10 93:16 130:21 143:24 144:15 Peterson Reporting, Video & Litigation Services occurs 38:16 170:24 office 3:12 33:5 37:14 38:1 40:19 42:14 51:19 53:7 55:1 57:4 61:21 65:2 67:9 84:24 90:3 91:3,6,10 93:25 96:1 131:10 136:11 139:2 140:5,8 142:17 143:3 148:7 158:24 161:23 162:1,7 163:23 176:6,7 178:19 192:10 193:3,11 officer 18:4,6 69:10 211 Richard Lawrence, 11-17-14 77:9,19,22,25 78:10 79:10,11 141:11 150:19 152:17 officers 33:16 76:3,6,9,25 78:4 79:9 80:2,8,19 142:7 officer's 18:8,10 161:25 offices 18:14,15 65:1 official 186:24 officials 133:16 Oftentimes 13:4 Oh 10:16 47:17 86:12 126:21 okay 11:24 12:13,16 13:19 15:1,8 16:8 24:14,21 27:14,25 29:14 34:23 36:21 38:20 43:7 45:5 50:16 51:14 54:6 58:3 75:14,18 77:3 78:20 79:5,13,21 80:7 83:23 86:15 88:9 89:23 96:14 97:11,23 102:25 103:24 106:11 108:5,13 109:3,14 111:10,13,21 112:12 113:1 118:2,6 119:21 123:18 127:7,11,19 131:13 135:4,14 136:6 138:17,24 139:9 140:6 141:15 147:15 149:24 152:3 160:10,11 161:7,16 166:14 167:23 169:8,11,15,2 1 171:18 175:19 177:23 178:12,22 179:21,22 180:4 181:21 182:10 183:24 185:5,22 188:17 189:4 190:17 192:3,20 193:12 ones 67:21 68:7 one-time 59:21 one-to-one 94:15 ongoing 60:22 open 1:4 2:4 4:17 7:12,19 8:18 9:16 27:19,23 48:3,16,18 51:1,5 63:15,24 70:9 73:20 75:16 83:10 110:1,8 114:11,15 120:10,11 132:11 133:10,22,23 134:8 135:6,24 141:6 operate 28:17 109:23 110:12 127:25 145:18 173:14 operated 173:19 Operation 18:12 operations 142:5 operative 172:17 opinion 20:19 57:9 116:2 133:12 159:2 opinionated 176:1 opportunity 13:2,8 186:7 opposed 60:5 147:4 Orange 131:21 132:20 order 8:15 14:4 20:23 42:17,18,22 56:14 59:10 71:4 72:14 146:12 150:14 165:10 ordered 8:10 ordering 8:16 orders 149:25 152:2 153:4,11 ordinance 74:10 ordinarily 147:19 62:3,7,9 68:8 108:16 110:12,16 125:10 127:25 128:4 129:3 132:6,14,17 146:25 organization's 19:12 70:22 71:7 83:8 129:7 130:7 138:7 organization 19:16 29:10,12 49:7,11,15,18, 23 50:6,7,11 51:1,4,20,25 52:1 53:2,13 56:19 57:19 58:11,17,20,2 3 59:11,14 60:23 61:3,6 63:8,20,22 64:25 65:14 66:10,15,24 67:2,13,21,24 68:7,18 71:1 74:12 82:10 83:21 92:25 93:7,11,19 96:20,22 98:4 109:11,16 110:5,19 116:5 126:16 128:5 131:16,20 132:5,19,22,2 3 133:1 136:22 137:15 139:15 141:25 142:2,8 145:20,25 147:22,24,25 148:2,10 150:20 151:5,9 152:5 155:6,7,10 156:14 159:15 188:11 190:25 organized 147:4 organizational 30:13 55:14 owns 184:6 organizations 28:10,11,23,2 4 29:1,15,18 30:1,25 31:3,11,13,21, 22 49:19 61:9,24 P p.m 75:7 85:19,22 119:11,14 144:24 145:3 185:24 186:2 Organizing 4:14 31:18 51:3,7,13 63:6,12 original 51:12 192:10 193:14,17 others 14:11 29:7 37:9 38:5,6 41:20 otherwise 24:13 76:13 90:25 142:23 ourselves 64:13 outside 117:5 121:22 127:13 149:9,12 outspoken 49:1 Overcoming 31:17 overlap 132:7,8 overpayment 174:17 overrule 46:25 57:8 122:6 137:8 139:7 overruled 57:22 87:1 177:16,24 179:1 owned 173:10 Peterson Reporting, Video & Litigation Services 194:3,5 P.O 136:14,16,18 package 44:11 62:24 packages 43:3 page 4:4 5:11 6:2,10 111:22,23 126:10 135:3 179:14 pages 111:21 paid 148:21 154:1,13,19,2 3 155:9,18,21,2 4 157:4,8,10 184:20,23 185:1 Pancake 3:8 4:5,7 7:16 8:12 9:5,13 16:8,11,15 22:16 23:11,21,23 25:20 27:9 30:16,20,23 32:20,23 33:8 37:23 38:7,12,20,22 39:6 40:12,13,22 41:3,17 42:2,3,11 43:7,10 45:6,16,21 47:3,12 52:8 57:6,24 62:17 71:8,23 72:6 73:1,10 74:24 75:9,22 76:18,21,23 77:14 78:22 80:16 81:14 82:3 85:10,17,23 86:12,15 87:5,17 91:8 96:7 100:14 101:11 102:3,18,22 103:18 105:1,17 106:8 107:10 110:3,25 111:3 114:25 115:15,23 116:14,19,22 212 Richard Lawrence, 11-17-14 117:10,22 118:2,5,20 119:9,15 122:1,5,9 125:17,22 126:21 127:1,11,14,1 5 128:19 129:17,23 130:19 131:5,7,12 134:15,18 135:13 137:7,12,22 139:6,13,20 140:1,20 141:2,14 143:12 144:20 145:4 148:6 149:14,16 150:5,7,24 151:1,14 152:4,21 153:5,19 154:6 155:4,7,12,15, 22 156:17 160:9,16,22,2 4 161:15 163:1,5,21 164:19 166:3,10 167:9,17,23 168:11 169:2,21,23 170:11 171:9 172:11,13 175:18 177:2,7,14,23 178:12,22 179:1,6 181:10,17,23 182:3,22 183:13 185:17,22 186:3 187:10,13 188:7 191:21,24 192:4,20,23 193:9,13,23,2 5 paper 56:1,4 papers 108:6 paragraph 102:25 126:11,20 127:4,17,19,2 3 128:5,8,9,12,2 3,25 130:3,16 179:15,17,19, 20,24 180:2,4,13,15, 18,21,24 181:2,4,5,7 183:6,20,25 184:3 paraphrasing 73:21 participant 98:15 participants 98:18 participate 81:13 89:14 101:18 121:8 136:17 164:24 176:9 participated 52:16 66:3 94:13 106:16 120:6,19 133:4 141:15 165:5 participation 99:2 172:2 particular 36:22 49:7 51:15 66:8 83:2 130:8 132:18 158:3,4 159:22 187:19 188:9 189:17 particularly 69:2 86:17 particulars 156:24 parties 8:15 26:16 Partly 146:6 57:8,13,22 76:15 87:1 90:23 117:25 118:3 122:6 130:20 131:3,6,8 137:8,21 139:7 149:15 152:12,22 153:17 163:20 170:12 177:15 PC 3:7 Pedro 44:2 69:4,7 78:13 99:2,3,11 141:12,13 165:7 176:19 penalty 12:25 192:17,25 194:8 play 167:21 168:9 permitted 153:1 pleading 167:14 person 83:12 84:4 88:24,25 129:16 130:22 143:15,18 151:9 161:10,17 162:4 173:23 174:3 179:23 180:1,14,17,2 0,23 181:1,5 182:14,20,23, 25 193:10 pleadings 117:18 personally 23:25 28:1 48:4 81:17 99:25 past 13:25 14:4 16:18 17:2,5,22 27:7 88:4 173:10 192:5 percent 54:23 planned 122:11 192:21 permission 77:21 162:3 people 11:12 37:14 49:24,25 50:1,3 131:9 153:2 per 24:6 plan 11:1 18:7 planning 23:19 personal 19:3 54:22 100:3 passed 99:6 plaintiffs 27:18 permissible 116:12 pending 30:22 70:19 80:12 155:1 163:11 178:5 party 39:18 41:6 193:16 placed 106:3 plaintiff 1:5 2:5 3:2 152:10 181:9,11 perjury 12:25 192:17,25 194:8 payments 61:18,21 156:16 185:8,10 piece 20:16 112:21 places 162:8 pay 146:13 149:6 153:10 184:9,13,17 payment 156:15 185:14 physical 13:20 14:2 113:19 period 68:15 189:1 193:4 Pause 85:20 payable 156:22 phrased 47:1 Perine's 190:8 periods 173:7,16,24 174:4 Patrick 10:1 people's 4:14 43:2 51:2,7,13 63:1,6,12 Pate 3:16 7:20 8:1,8 32:24 39:25 41:2,4 42:1,9 46:12 119:22 122:15,23 144:13 166:22 171:20 186:21 187:1,15,22 188:13 189:24 190:13,18,21 personal-injury 156:4 persons 179:19 perspective 21:5 112:16 118:11,12 164:15 plans 71:5 please 7:14 9:6 30:21 70:18 80:11 87:16 138:19 148:2 150:9 154:25 169:1 184:12 pleasure 68:11 147:1 plenty 71:22 plural 45:1 128:4 plus 24:6 PMK 8:18 point 21:6 26:24 36:15 74:23 80:22 86:17 117:5 148:23,25 151:9 152:11,16 171:3 177:21 points 152:23 police 18:3,6,10 perform 67:3 pertaining 184:21 185:1 perhaps 128:10 171:7 Peterson 7:5,8,13 pony 59:10 phenomenal 63:25 portrayed 134:23 phone 87:14 144:18 position 35:25 116:20 Perine 89:1,2,11,15 92:8,11,13,14, 17 94:3 Peterson Reporting, Video & Litigation Services Policy 29:3,20 portion 125:8 213 Richard Lawrence, 11-17-14 133:11,12 presented 88:13 positions 63:19 64:23 preserve 114:11 possession 19:24 possible 8:3 118:13 126:13 129:1,19 145:19 148:25 president 4:23 18:16 108:3 pretend 151:17 privileged 38:13 46:7 170:18,20,22 177:17 probably 53:25 54:23 60:1 69:9 98:14 173:1 possibly 58:18 pretty 54:16 86:9 120:10,11 152:24 153:2 189:7 postcard 161:8 prevent 14:3 problems 142:24 potential 93:10 previous 72:7 potentially 26:6 165:9,15 166:16 preacher's 23:4,5 previously 9:14 15:5 17:13 20:18 22:3 42:25 51:10 72:15 84:3 109:6 116:7 118:22 Procedure 150:19 preceding 46:1 price 130:12 precise 168:20 primary 74:16 142:19 practice 121:4 preexisting 158:9 premarked 62:15 premise 130:15 177:22 178:14 preparation 22:4 prepare 12:22 19:20 21:19 67:5 principal 161:24 prior 40:24 48:11 62:10,21 73:21 86:10 88:3 96:5 99:7 103:8 116:8 152:14 158:22 172:20 190:12,17 problem 14:8,12 87:18 142:20 procedures 150:18 proceed 24:14 57:23 proceedings 11:8 85:20 127:8 193:15,16 public's 70:5 published 111:13 pumpkins 160:21 purchasing 115:12 purposes 22:4 103:1,3,9 125:13 147:5 163:6 Production 4:11 program 124:14,18,24 programs 103:4 124:19 125:20 Project 31:18 prominent 117:1 prepares 55:3 privilege 22:13 32:17 38:14,15,16 39:9,10,15,19, 20 40:2,3,7,10,21 45:3 56:23 57:1 76:11 90:22 100:9 101:9 105:9,21 130:17 137:17 138:25 150:3 163:13 170:3,8,16,25 171:2,7 175:15 176:25 177:5 promoting 119:4 124:12 presentation 48:8 publicly 48:17 133:21 176:3 product 175:15 177:11 private 30:6,8 134:4 164:17,21 present 3:16 4:23 28:19 66:8 98:4 105:11,13,15 145:14 162:20 169:19,20,24 170:6,15 177:20 178:10,16 public 4:18 71:4 114:3,6 118:14 119:4,6 123:11,18,22 124:5 125:13,14 134:7 142:20 purpose 20:18 58:7 103:11 125:15 privacy 30:9 133:20 prerogative 113:11 Providing 60:6 process 43:1 127:24 128:23 130:2,7 136:3 prepared 34:17,25 56:9,11 58:25 74:20 107:17 108:1,2,4 preparing 57:4 72:22 108:22 57:14 62:7 176:6 182:8 pursuant 42:17 pursue 35:19 119:7 150:17 158:1 165:3,22 projects 71:5 promote 118:14,15 proofs 43:2 proper 32:24 45:17 46:8 properly 13:6 property 184:7 proposing 27:6 protect 68:13 protected 30:8 105:20 protective 42:17 provide 41:8 provided 55:6,8 Q quality 113:15 114:12,13 118:16 120:9 question 11:4,16 12:3,8,9 24:24 29:11,14 30:19,21,22 32:6 33:1,3,6 37:15 41:19,24 45:5,12,24 46:1,21 47:1,2 51:18,24 55:9 57:10,17,25 58:19 70:17,19 71:16 72:2,7,9,11,17 73:4,11 76:14 80:10,12 81:25 84:2 Peterson Reporting, Video & Litigation Services 85:7 86:7 89:23 90:22 91:4 100:11 105:12,18,24 106:2,12 107:22 116:6,13,16 121:24 124:3 128:17,20 130:20 131:2,4,8,13 135:5,14,15 137:3,6,11 138:18,20,21 139:10,21 141:19 150:20,23 154:24 155:1,8,13 156:11 162:24 163:8,11,17 168:24 170:10 175:16 177:24 178:1,5,10,21, 22,25 179:5 182:4 186:15 questioning 138:16 questions 10:17,25 12:1,5,18 13:21 15:10 23:22 27:1 30:12 34:17 39:23 57:2 60:2 83:24 117:19 140:13 151:7 152:16 153:14 167:25 168:12,13,14, 15 170:19 178:17 185:18 186:13,14 187:9 191:21 question's 116:11 QUESTIONS 5:10 6:1 quick 75:11,23 107:20 185:17 quickly 11:20 Quiroz 44:2,3,8 69:4 76:3,19 78:13 99:2,4 141:12 144:4,8 165:7 169:3 176:19 214 Richard Lawrence, 11-17-14 Quiroz's 69:7 150:4 quite 26:17 141:16 172:23 REALTIME 1:22 quote 112:4,7 126:19,20 reason 14:13 58:12 63:23 73:20 108:17,19 117:14 123:2 132:19 145:15 186:10 193:19 quotes 126:11 R raise 59:1,15 71:5,24 72:14,21 74:12 125:5 146:2,6 147:7 148:25 149:6 150:11 152:22 raised 35:24 51:18 52:17 72:9 133:13 151:18 159:12,19 164:16 raises 149:10 raising 71:9,11,12 72:5 146:21 147:5,18 rarely 165:2 rather 11:20 15:17 118:14 178:3 rationale 38:23 reach 18:16 reaches 142:20 reading 21:17 real 115:4 120:13 142:9 147:1 realize 75:11 85:24 145:6 186:5 really 21:7 28:17,19 36:4 46:16 63:22 66:6 68:3 71:19 87:19,24 106:3 112:22 114:11 115:9 121:7 146:23 152:23 171:17 176:1 189:12 190:3 191:1 realm 142:20 reasonable 193:16 134:23 136:5 recollect 159:6 recollection 15:12 19:16 20:9 30:24 33:23 35:15 36:14,18 41:16 50:8 58:13 111:17 123:14 160:3 171:16,18 172:1 158:15 189:16 190:22 referring 27:22 43:19 63:3 96:11 97:25 128:6 135:19 141:7,9 188:4 relatively 27:20 refers 181:9,11 relegated 133:13 164:17 refresh 30:24 33:23 36:17 41:16 50:8 123:14 171:15,18 release 156:4 Relief 5:7 172:15 relies 150:2 relieved 192:7 refreshes 160:3 rely 149:21 refund 174:18 remain 39:2 regard 18:7 70:5 80:15 83:7 134:8 remains 134:7 recall 13:24 17:3,6 31:19 35:5 36:8,9 42:4,20 43:12 48:24 58:4 69:24 73:6 74:1 79:4 90:15 98:23 106:23 107:1,5 109:12 119:25 123:16 131:21 144:16 186:20 187:2,21 188:20 reconstituted 49:23 50:4,6,14 recalling 14:3 receipt 25:6 records 28:1 31:1 regular 83:25 97:24 187:5 receipts 174:20 recourse 134:6 Reminds 18:4 receive 82:20,22 96:14,16 174:24 recycle 43:23 44:11 47:9 regularity 54:13,14 redacted 43:4 regulators 151:10 received 24:17 61:17,20 85:1 95:20 96:2,9 153:21 157:13 173:2 174:21 175:7,20 185:13 redevelopment 158:24 reimbursement 156:7 renewal 175:1,5,9 185:9 redirected 124:19,25 relate 28:1 40:24 66:19 100:7 redress 68:2 73:15,17 receives 82:9 192:13 reduce 114:5 related 17:13 26:13 51:6 74:18 100:3,22 106:24 114:16 123:9 132:8,10 150:12 163:25 184:24 receiving 24:22,25 25:3 recent 16:18 recess 75:8 119:12 144:25 185:25 recited 67:18 70:13 recognize 23:18 52:10 78:16,23 79:16 107:11 reconvene 53:9 record 7:3 8:1,12 9:6 16:8 74:25 75:2,7,10 85:16,17,18,2 1 86:3 119:10,13,16 144:23 145:3,5 156:2 185:23 186:1,4 194:2 195:11 refer 26:19 27:16,20 42:18 43:25 44:1 69:9 referee 3:17 7:21 8:7,10 150:21 referees 8:3,14,19 86:10 152:14 reference 8:20 76:16 179:4 referred 132:24 regarding 41:19 89:15 regardless 39:18,19 regards 80:18 registered 1:21 180:5,7,10 registration 174:7,10 relates 22:24 184:10,14 relating 100:18 106:21 140:10 154:10 174:22 relation 143:25 relationship 48:10,19 Peterson Reporting, Video & Litigation Services remember 14:10 18:25 21:8 35:10 37:7 63:5 107:19 122:16 123:6 131:24 132:18,20 140:15 143:24 159:22 160:7 176:15,18,19 remembering 143:10 remind 30:11 reminder 160:20 remotely 150:12 rent 20:23 173:6,15 rental 173:6,11,15 184:7 rentals 173:20 rents 173:23 174:3 repeat 30:19,20 32:21 124:3 134:2 156:25 184:12 repeatedly 46:7 repeating 118:12 rephrase 23:16 55:7 72:12 76:15 81:4 88:9 89:20 102:10 117:25 215 Richard Lawrence, 11-17-14 125:19 163:16,18 190:10 replace 74:10 181:12,13 report 84:23 126:23 reported 1:20 138:4 reporter 1:21,22 2:17 7:7,24 11:10,12,21 12:17 30:20 50:20 112:8 159:25 182:2 191:23 192:7,10 195:4 reporter's 126:23 reporting 7:5,8,13 138:3 reports 145:17 represent 7:15 9:14 19:10,17 42:12 135:1 172:14 representation 35:25 42:24 43:5,6 157:18 representative 173:22 174:2 represented 19:5 161:7 171:14 represents 19:13 request 4:12 16:7 20:2 26:4 32:4 40:2 83:13 84:4 87:22 88:18 89:3,7,11 95:11 100:1 185:13 187:20 188:11,23,24 requested 6:9 19:24 21:19 33:10,15,16 34:3 35:14 67:3 92:17 94:6 119:23 122:20 160:13 188:19 requesting 189:2 requests 4:10 28:6 31:25 32:10,14 41:9 98:4 require 20:22 39:14 64:3 73:23 74:4 138:15 175:16 required 67:12,15 83:17 115:9 140:4 162:17,18 137:24 139:2 responsibly 113:13 responsive 26:6 28:6 32:4,7,10 40:1 result 24:21 45:7 65:25 81:16 86:22 156:23 185:9,15 resulted 81:22 results 113:18 requires 37:18 39:10 67:7 113:14 133:18 141:22 résumé 108:23 109:1,4 resident 18:6 retain 19:9 residents 115:11 retained 157:25 resolution 107:14,16 retainer 157:16 158:3 resolved 159:16 retaining 19:17 158:14 resources 71:1,2,13,21 119:6 142:3 respect 17:9 21:12 24:22 25:3 34:25 38:2 45:10 47:5 48:21 66:4,14,24 67:8,13,16 79:2 91:11 101:19 107:3 108:9 130:1 151:10,18 156:22 192:8 respond 12:11 44:19 response 66:20 responses 178:21 responsibilities 136:25 137:14 140:9 141:20 responsibility 44:7 138:14 139:24 140:2,22,23 responsible 16:25 29:5,22 70:4 71:21 113:7 115:10 128:6 132:9,21 Ret 3:16 retention 157:22 retired 9:23 return 161:8 revise 104:11 revised 103:20,25 104:7,13 revive 101:16 reviving 101:19 Richard 1:14 2:12 4:2,10,23 7:11 9:1,8 75:2,6 107:15,25 144:23 145:2 176:19 194:2,7,16 R-I-C-H-A-R-D 9:8 rights 14:21 17:16 30:9 112:15 RMR 2:18 195:21 role 81:12 room 16:1 86:19,20,22 RPR 195:21 reveal 38:25 39:4 rule 12:7 41:17,18 revealing 33:4 rules 10:12 revenue 123:11,22 124:1 153:22 ruling 12:20 39:6 40:24 46:13 117:24 122:5 130:19 152:21 170:11 177:14 revenues 118:14 123:18 124:5,22 126:1 133:16 134:3,10 Reverse 172:16 ReverseValidation 5:7 review 12:23,24 21:22 22:2,4 36:6 55:21 62:21 160:2 192:15,24 reviewed 13:1 23:16,17 34:5,9,11,13,1 6 62:12 63:11,14 106:20 reviewing 33:19 21 115:5 126:17 132:24 135:5,24 136:8 141:6 164:20 173:8,12,17,2 0,25 174:7,10,14,1 8,21 180:5,7 184:7 195:14 sanction 153:3 sanctioned 153:7 sanctions 149:24 150:14 152:2 153:8,10 SanDOG 53:17 58:22 59:18 74:15 87:21 120:12 129:22 130:23 131:19,23,25 132:2 152:8,9,20 159:15 173:1 186:20,24 187:2,5 188:4,9,16 189:2,3 190:5,14,16 Santa 136:7 Sarbanes-Oxley 117:8 satisfied 24:9,13 saw 52:11 143:8 scheduled 22:6 rulings 12:19 School 10:1 runs 128:2 142:8 scope 116:11 117:6 121:22 149:9,12 S safety 125:14 San 1:4,7,15 2:4,7,13,16 3:6,11,12,13 4:17 5:1,4 7:1,9,11,12,17, 19 8:18 9:11,14,16,17 16:14 26:18,21 27:19,23 28:10 29:6,23 31:18 48:1,15 51:1,5 63:15 70:4 75:15 114:14,15,16, Peterson Reporting, Video & Litigation Services score 191:15 screen 135:2 screwed 163:9 scurrying 26:10 SDOG 17:2,5 19:16 26:13 27:21,22 28:2,12,14 30:13 31:8 33:11,17 37:3 38:2 47:14,16 48:21 50:1,23 52:1,14,16,19, 25 216 Richard Lawrence, 11-17-14 53:9,10,19,23 54:7,8,18,22 55:8,18 61:10,13,18,2 5 62:8,11,12 63:6,18 64:24 66:4 67:20,21 68:6,17 69:23 70:16 71:14 72:13 73:3,15,17 77:9 79:23 80:2,8 81:6,17,20 82:4,11 83:4,13,18 84:2,18 85:3 87:7,9 88:6,12 89:3,12,16,18, 21 90:5 91:11 92:10,14,18,2 4 93:6,10,13 94:7 95:7 96:3,10,24 97:8 98:7 100:3,7,18,22, 25 101:6,23 102:6,11 106:18,22,25 107:4 108:9,17,25 109:4,10,15,1 9 110:8 113:3 119:22 120:17,22 121:8 123:3 128:2,9,21 129:11 130:23 131:15 132:15 133:5 143:2,5,25 145:10,12 146:17,22 147:25 148:8,9,20 149:18,20,25 153:6,9,20,21, 25 154:10,18,22, 23 155:3,10,17,1 8,21,25 156:13,15,19 157:1,6,7,13,1 6,18 158:10,12,18 159:3,4,21 160:5 161:9 162:5,12,14 164:1,25 165:9,10,15,1 9 166:17,21 175:12,23 181:12,14 183:4 184:2 187:17,18,19, 22 188:14,24 189:10,12,15, 24 190:19,24 191:3 SDOG's 129:25 79:2,5 89:22 91:15 92:2,4,7 93:23 97:6,7 102:23 111:7,9 134:21 135:11 154:7,9 161:2,12 172:18,23,25 selected 8:3 80:5 sec 30:5 send 67:6 192:10,11 193:9,10 second 31:17 56:20 111:2 130:15 190:11 sense 35:17 121:9 133:3 134:1 search 26:7 41:7 secondly 47:10 150:6,10 second-to-last 126:10 secret 42:16 secretary 5:3 51:19,25 64:25 65:2,3,4,5,7,14 ,18,20 66:1,10,14,20, 22,25 67:2,9,17 69:12 79:10 80:5,23,24 93:19 101:1,15 135:3 136:19 138:4 140:5,8 141:12,13 142:21 162:12,14 secretary's 162:8,16 seeing 26:11 58:4 135:15 seeking 105:21 171:1 seem 34:8 46:22 seems 41:10 46:23 57:9 152:24 seen 16:2 32:9 40:9 51:6,9 52:13 55:17 56:17 57:16,18 62:18 77:5,15 sensitive 113:15 sensitivity 129:6 settlement 153:22,25 154:9,13,18,2 2 155:17,20,23 156:2,3,9,23 157:6,7,14 159:13 178:19 settlements 155:25 156:21,25 seven 47:21 50:23 54:5,10,18 64:9 84:10,20 85:4 88:4 98:6,11 several 44:17 47:17,20 59:8 sent 12:23 20:1,10 159:8 192:14 severe 49:5 September 78:10 79:23 80:3,9 shared 49:3 serious 115:9 she's 95:6 140:17 141:7,9 156:10 181:15 182:19 serve 65:18,20 66:1 69:11 80:23,24 173:22 share 49:14 sheet 56:1,3 shooting 18:3,8 162:8,16,17 signed 8:16 34:19,24 35:6 36:1,5,9,13,20 41:14 106:24 164:4 193:1,7,17,18 significant 55:22 115:14 signing 35:25 simply 120:6 145:19 single 140:14 single-minded 68:1,12 69:24 70:2 singular 45:4,15 sir 75:24 77:8 86:20 102:23 131:8 139:21 141:3 153:6 160:1 184:9 sit 14:7 122:10 186:8 sitting 10:21 situation 18:5 170:16 six 17:7 47:21 50:23 54:5,6,10,18 64:9 84:9,19 85:4 88:4 98:6,10 served 23:25 41:15 42:14,20 43:3,12 44:20,22,23 45:13 47:5 69:16 174:2 short 18:21 74:24 146:23 server 43:1 shot 18:6 135:2 slow 11:21 serves 19:12 69:3 showing 41:16 77:11 102:19 107:6 134:11,19 154:3 172:5 small 68:11 109:23 service 43:2 45:7,10 136:2 186:25 187:4,15 188:6 189:7,19 190:1,7,12,18, 25 Services 7:6 serving 69:20 98:13 sets 34:16 Setting 186:11 settle 155:9 settled 156:19 shortage 49:5 115:6 shorthand 2:17 195:3,9 shown 135:18 Sibrel 3:18 7:5 sign 12:25 35:2,12 36:24 37:9,11 38:1,5 40:15 41:20 107:2 162:21 163:2,24 192:16,24 signature 36:6 78:16 79:16,18,19 Peterson Reporting, Video & Litigation Services slightly 24:12 smiling 50:20 social 10:9 112:17 144:1 145:8 somebody 69:1 78:7 98:12 107:18 142:7 147:1 151:8 163:23 175:12 somehow 86:8 someone 32:18 38:1 83:3 98:12,21,22 120:13 129:13 217 Richard Lawrence, 11-17-14 173:3 someplace 41:12 165:17 sometime 36:3 80:5 81:3 somewhere 41:11 specifics 35:4 spectrum 146:5 speculating 15:16 speculation 15:18 135:11 spell 9:7 statement 4:19,20 45:22 82:7 103:3,11 111:24 State's 51:19 67:9 135:3 140:5,8 spellings 13:5 status 96:23 101:22 138:7 spend 68:4 106:6 119:3,5 148:8 Statutes 5:7 172:16 spending 124:2,7 147:13 statutorily 24:5 spends 147:24 steps 101:15 sort 20:25 38:10 50:17 55:24 83:6,21,24 106:7 109:10 142:11 150:2 182:11 189:20 spent 26:8 73:7 123:11 134:10 147:3,11 stick 112:23 spoke 25:13 46:2 122:19 144:17 191:1 stip 191:23 sound 86:8 143:15 156:3 spot 109:24 sorry 25:5 34:21,22 70:20 76:21 108:8 111:22 113:22 126:21 136:4 138:20 146:19 163:9 182:2,4 sounds 11:10 source 20:17 129:12,16 142:19 sources 118:13 123:10 124:15,16 South 3:8 Southern 126:14 129:19 space 9:11 114:12 136:11 160:1 speak 11:5,8 25:12,22 speaking 25:21 45:18,23 special 133:13 specialty 10:9 specific 19:1 37:7 80:15,18 88:22 103:1 122:16,23 168:1 specifically 19:17 67:24 123:5 157:24 158:13 162:6 164:6 165:21 spring 187:6,15 statutory 192:7 sticker 111:1 stipulate 193:13 stipulated 193:21,22,23 162:20 submitted 103:11 104:14 108:6,11,23 109:5 161:8 174:12,16 submitting 83:13 84:4 subparagraphs 179:17 subpoena 4:12 19:22 21:17,22 23:15,24 24:18,22 25:4,7,23 26:4 28:7 32:11 42:20 43:13 44:19,22 45:11,13 47:5 standing 102:12 140:4 149:11 151:19 152:20,23 165:9,15 166:17 175:12,22,25 176:4 store 18:18 Street 2:16 3:4 7:9 9:11 subsidies 20:22 standpoint 127:5 strictly 129:2 substance 37:15 48:18 start 11:20 57:2 strikes 46:18 started 67:2 striking 110:13 state 1:1 2:1,18 5:3 7:15 9:6 16:12 30:15 46:23 49:6 51:25 66:22 67:7,12 101:1 115:7 118:19 136:19 138:5 142:21 151:10,11,13 162:12 194:8 195:4 strong 190:4 stated 78:9 103:1,9 112:14 161:14 subjected 118:18 subject 19:25 20:7 102:17 170:24 submit 108:21 supplying 41:22 171:4 177:22 support 58:11,17,20 64:2 74:21 125:12,16 129:4 131:22 146:7,8 supported 131:23 supposed 58:16 stand 10:22 sub 179:20 supplies 163:17 subsequent 94:8 95:4 103:20 104:20 106:13 stop 113:12 stuff 170:8 supplied 137:17 supports 125:25 stolen 193:18 structured 156:21 supervised 78:2 subpoenas 32:15 45:8 staff 41:25 90:3 96:1 108:4 structure 79:22 109:19 Superior 1:1 2:1 3:16 supporter 49:12 SRO 74:10 story 111:9,11,18 133:21 152:13 summer 42:5 subpoenaed 39:16 42:5 stipulation 8:4,13,15 192:4 stores 18:18 summarize 123:13 subsequently 18:12,20 46:11 47:10 48:2 subsidiary 126:16,17 128:15 substantially 127:18 129:6 substantive 13:10 sue 149:12 sued 152:8 suffer 13:19 14:2 suggesting 156:5 suing 115:20 116:5 152:8 Suite 2:16 3:4,8,13 7:9 suits 126:13 129:19 Peterson Reporting, Video & Litigation Services supporters 88:2 suppose 58:10 sure 12:15 16:21 23:22 24:15 27:5,14 30:6 33:13 34:15 45:16 54:23 56:21 62:23 69:21 72:8,10 97:15 99:10,17 113:24 119:9 134:1 152:13 154:16 156:12 159:3,23 164:9 165:6 172:23 176:20 182:12 189:6,7 surely 114:3 115:5 surprise 147:8 surprised 152:11 surrounded 51:15 62:20 survive 59:14 survived 59:24 suspect 67:10 70:10 134:14 suspended 218 Richard Lawrence, 11-17-14 101:6,23 102:7 144:21 t.619.236.6220 3:14 taxes 68:5 70:3,23 126:3 133:13 164:17 testified 9:2 16:16 17:21,22 18:24 28:22 31:10,22 45:14 50:13,22 51:21 56:5 58:9,16 61:1 67:20 69:23 70:7,16 71:25 72:15 73:19 75:14 80:4 84:9 88:4 91:15 92:16 94:5 97:20 109:6,9 116:7 117:4,15 119:21 122:18 123:7 132:13 140:7 145:8 147:10,23 151:5 169:4 188:17 189:11 t.619.949.7115 3:5 taxpayer 124:1 testify 195:7 tea 130:12 testifying 7:11 10:22 14:5 114:23 suspension 101:16 sustain 153:17 163:20 sustained 39:25 40:11 42:1 76:17 90:24 137:21 149:15 150:21 swear 7:24 sweat 148:18 switched 78:13 sworn 9:2 195:7 T t.213.542.5717 3:9 table 15:20,25 53:1 55:10 167:24 task 147:19 120:13 tax 4:21 20:15 26:25 102:12 103:12 104:15 106:17,21,25 107:4 123:20,21 124:6,10,12,1 5 125:6,20 134:4 142:22 152:8,19 161:8,9,11 162:4 163:6,25 164:4 174:13,17 182:1,6,16 184:18,24 taxation 70:15,22,25 technical 142:10 tackle 64:5 technically 49:21 159:13 tailor 100:10 Tecum 4:13 taking 13:23 86:19 116:22,23 124:1,6 129:4 140:3 telephone 161:19,20,22 talk 25:2,6,18 56:13 113:1,16 156:2 187:18 talked 44:13,15 54:6 60:12 187:19 talking 11:13 26:20 27:15 29:1 50:18 52:1,2,4 56:4 88:24 96:11 113:2 114:20 129:21 141:5 142:1 155:5 156:7 162:11 185:5 ten 95:18 126:8 tenants 173:7,16,24 174:4 tend 35:9 109:24 tenure 98:25 term 27:21 35:22 46:8 65:4 113:6 117:14 118:23 130:24 139:18 155:3 156:6 terms 13:4 64:16 109:19 110:12 112:18 116:24 terrible 21:6 111:19 terribly 64:5 tangent 182:11 terrific 149:2 tape 15:21 test 83:7,9 testimony 13:12 14:14 15:2,11 24:5 27:25 31:8,12 32:1 34:2 60:3 66:9 68:6 69:11,25 73:21 74:1 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title 27:20 66:20 69:7 titled 5:1 TMD 8:4 21:3,9 26:19,20,25 27:2,17 30:7 114:24,25 115:2 124:11,18 133:18 152:8 182:1,6,16 today 7:7 10:13,25 11:8,11,22 12:14,21 13:16,17 14:14 15:10 17:19 19:5,18 22:6 24:5,14 25:25 62:10,18,21 79:3,6 86:14 103:8 108:10 114:22 122:10 133:10 161:3 172:3,21 186:10 today's 7:3 19:21 21:20 23:9 192:6 token 11:16 27:18 tons 45:8 top 125:24 topic 94:8 153:16 170:18 topics 170:14 TOT 124:9,15 125:8,11,12,1 5,20,25 126:3 174:16 176:1 totally 139:24 touch 126:15 tough 21:7 tourism 2:13 3:6 7:17 9:14 20:1,11,20 21:1 26:18,21 27:11 35:18 219 Richard Lawrence, 11-17-14 114:16 118:14 119:4 123:25 124:6,12,14,1 9,24 125:6,16 126:2 164:21 174:22,25 175:4,8 184:10,15,21, 24 185:2,9,15 tourism-related 125:10 transactions 64:12 transcribe 11:12 transcribed 13:6 195:10 transcribing 11:10 12:17 192:6 transcript 12:22,25 13:3 88:7 160:1,3 192:8,10,12,1 3,14,15,16,24 193:1,6,14,17, 18 transient 20:15 123:20,21 125:6 174:9,12,17 184:18,23 trolley 24:11 trouble 123:4 143:10 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