Byers 8: Anderson Court Seattlefl'acoma. Washington SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR KING COUNTY AMY SHOBLOM, individually, DIANA NEFF, individually, LOU CABALLERO, individually, Plaintiffs, KING COUNTY, a political Subdivision of Washington vs. No. 15-2-09687?7 SEA 3 State, Defendant. DEPOSITION OF JESSE ANDERSON (Volume II) TRANSCRIPT CONTAINS CONFIDENTIAL DESIGNATIONS October 31, 2016 Seattle, Washington Byers Anderson, Inc. Court One Union Square 2208 North 30th Street, Suite 202 600 University St. Tacoma, WA 98403 Suite 2300 (253} 627-6401 Seattle, WA 98101 (253) 383?4884 Fax (206) 340?1316 scheduling0byersanderson.com (800) 649?2034 Serving Washington's Legal Community since 1980 Jesse Anderson October 31, 2016 Byers Anderson Court ReporterledeoNideoconferencing Seattlen'acoma. Washington 1 APPEARANCES 1 EXAMINATION 2 Forthe Plaintiffs: 2 EXAMINATION BY: PAGE NO. 3 Julie A. Keys :1 5 Connetiy Law Of?ces 3? 4 2301 North 30th Street 4 Mr. thterbauer 62 5 96403 5 Mr. Davis 75 25359310330 Fax 6 Kai?s 77 6? 7 MY- Winterbauer 79 1' For the Defendant: 3 Mr. Davis 80 8 Steven H. Winterbauer 9 Winterbauer 8. Diamond 10 9 1200 Fifth Avenue Suite 1700 ?1 INDEX 1" 931?? 12 EXHIBIT NO. DESCRIPTION PAGE NO. 11 13 Exhibit No. 5 2-page note titted Sheriff Urquhart 8 12 For the Witness: conversations. Bates-labeied ?3 Davis 14 KC 136134335 and KC AS102168 In Pacta PLLC ?5 14 801 2nd Avenue Suite 800 ?5 15 Seattle. Washington 96t04 17 206.360.0173 13 '5 nd@inpacta.corn ?3 Also present: Diana Neff Page 2 Page 3 1 CONFIDENTIAL DESIGNATIONS 1 BE tT REMEMBERED that on Monday. 2 BEGINNING: 2 October 31. 2016. at 506 Second Avenue. 33rd Floor, 3 Page 12; Line 1 Page 19; Line 12 3 Seattle, Washington 98104, at 9:36 am. before Michetle 4 Page 25; Line 22 Page 30; Line 18 4 D. Etam, Certi?ed Court Reporter. appeared JESSE 5 Page 32: Line 7 Page 32: Line 17 5 ANDERSON. the witness herein: 6 Page 37; Line 9 Page 40; Line 4 5 WHEREUPON. the following proceedings 7 Page 41: Line 25 Page 61: Line 20 7 were had. to wit 8 Page 62: Line 3 Page 70: Line 23 8 9 Page 74: Line 13 Page 74: Line 21 9 10 Page 75: Line 18 Page 76: Line 16 1? 11 Page 78: Line 15 Page 78: Line 22 ?1 JESSE ANDERSON, having been first duly sworn by 12 Page 83: Line 24 Page 85: Line 3 ?2 the Certi?ed Court Reporter, 13 13 testi?ed as foltows: 14 14 15 15 EXAMINATION 15 '3 BY MS. KAYS: 17 '7 Good morning. Captain Anderson. 18 13 you please state your first and last name for 19 19 the record. 7-0 2? It?s Jesse Anderson. 21 21 And, Captain Anderson. we got together for the ?rst 22 2? part of your deposition. I don't know. seems like a 23 23 month ago. 24 24 is that about fair? 25 25 A Yes. Page 4 Page 5 2 (Pages 2 to 5) Jesse Anderson October 31, 2016 Byers 8. Anderson Court Sea?ttlerl?a?coma, Washington don't know what they may have found on my computer the hadn't come to me. I had mentioned. why me? I don't 1 1 2 I'm not aware of. 2 want to be involved with this. But it's our 3 0 Okay. With respect to the ?rst two paragraphs here. 3 responsibility to make sure that we do what we're 4 let's talk about it since we couldn't talk about it the 4 supposed to do. and that's inform the sheriff if any 5 last time you were deposed. 5 allegations of misconduct or performance issues come to 3 Tell me about - how did you learn this infonnalion 5 our attention that ill! ls involved in. 7 about the allegation against the sheriff of sexual 7 So basically it wasn't like. oh. gosh,l really 5 assault? 3 don't want to go. It's. like. well. this is what we 9 A So Sergeant Mike Mullinax had come to me and said that 9 have to do. lmean. let me rephrase that. 10 he had received a call from the FBI. Mike is 10 ididn't want to be in the situation. But because '1 sharing this information and he wanted to - he wasn't 11 of my role and my responsibility. 1 have no other option 12 sure what to do with it. So he wanted my advice on how 12 than to share this with him. 13 we should proceed with this information. 13 Did you feel comfortable sharing it with him? In other '4 And what was your advice. Captain Anderson? 14 words, I know the FBI had given permission to 15 A My advice was we need to - well. first of all. he 15 Mr. Mullinax that you could share it with the sheriff. 1'5 ?lled me in on that it was okay for us. after he got *5 but did you. as the fill commander. feel that thatwas ?7 permission. I guess. by the FBI agent. to share this ?7 the appropriate step to take? ?3 with the sheriff. said. "We need to go talk with the "3 A it's the only stop that we could take. 19 sheriff and let him know about this information so he's 19 0 Explain that. 2" informed.? 2? A So the FBI had shared that they did not plan on opening 2? How did you feel about going in with Sergeant Muilinax 21 up an investigation. So if the outside agency is not 1?2 to share with the sheriff that an allegation of rape had 1'2 going to do anything with this, there?s nothing else 23 been made against him? 23 that I can do with it at this point other than advise 24 A Well. as I testified previously. i was a couple weeks ?24 the sheriff. make my recommendations leaving so I was - i wish this information 25 documentation of it. Page 14 Page 15 There's really nobody else to go to that I can 1 Ct Anything else that he said regarding 2 think of at that point that could have any in?uence 2 A There may have been some discueslons about her menta 3 over these accusations. 3 health. but i don?t recall anything specific on that. 4 When you described your reaction as kind ofthe why now. 4 it could hays happened before that. No. There was .. 5 why me. more or less when you went in with Sergeant 5 yeah. there was some conversation about her mental 6 Mullinax to share this information with the sheriff. 8 health. and i don?t remember specifics about that. 7 describe how that conversation Went. 7 Did you bring that up. or the sheriff or Mr. Mullinax? 8 A 80 Mike and I walked into the sheriff?s office 3 A I believe the sheriff had brought that up. 9 when he was alone and said. "We have some information we 9 What was the sheriffs demeanor when you were having 10 need to share with you." ill this conversation with him? 11 And I allowed Mike to share that because he had the 11 A He was fairly calm. He was sitting at his desk. 12 ?rsthand information rather than getting some type of 12 listened to what we had to say. He didn?t seem to be 13 ?ltered version or from what] had heard from Mike. it ?3 upset. other than just frustrated kind of or. like. 14 was better for him to share that lnfonnation directly to 14 having to deal with accusations like this. He wasn?t '5 the sheriff. And then. of course. ljumped in after he 15 angry. i don't remember him being angry. 15 had advised the sheriff on what he was told by the FBI is Okay. Was the sheriff advised that he could not have 17 agent. 17 contact with 13 And then how did you - what was the sheriff's response 13 A Yes. he was. 19 when he was informed that a rape allegation had been 19 And by whom was he advised? 20 made against him? 20 A Mike Mullinax. 2? A he was disgust :3 about it. He 21 What did you mean by. told him that lthink maybe 22 mentioned that& who was 1% at 22 someone else put her up to it?? 23 the time. had worked for him and that she was supportive 23 A Well. up to this point. you know. almost two years in 24 of him. And he didn't know why she would be coming 24 internal investigations. there had been a number of 25 2-5 folks throughout the department who had made complaint forward with these allegations. Page 16 Page 17 5 (Pages 14 to 17) Jesse Anderson October 31. 2016 Eye's a Andaman Conn Reoonars Sunlefllcoml. WasnIngIon I nvbvouam eonouna aooum. anon". I ml n. "In I mn, you know -InIs noI Ian I I .noom hid Ilnrd :hwl I umbihly llu um mo InvoIv-o In mom a amuuflans -- nocm- 1y no- .oouanuana, I I In oI um. naa plus-d and mum. nna I huuhtn wa: Wm- typ- mum-n --or and that via lam-body um um I som woo cu mum lam-ml"; hllwun In. I In had II outwalml Inano van-fl Io ouno mm mun-Ian: up Io nIamnInok I okay. Ana max~ yuu Io Ina oIIegeo - I or noweuav youwnnua I. ma yuu mm a I wnon you made -- am you make InaI summer" damn I A mom. Ia (he calm: nlyuw communion mm In: sherifl a! II 0 Wu Ina you were In or pm" In "Inanuacny wnaI I slld. Eul o-nmIIy aooaklno. m. I2 (Eno or oannoonIIaI I: HI lam. mm -- whit I: II lay II om yan know. I'm cone-moo I. oaIno I: (By Ml. Kay.) Ana wnaIwomno unou II Io cam- uo . .Isomo ooInI, Ind II ooqu In I Is which you new non-I know mun. llcould a. on Him! I It In Shariban and [mm donumlnl InIs, :owl--al II A no mn a comoIaInI horn a Icon-rowan, In I: discuss-fl. w. oonk moan onIIau- llvnIamwm .wan om male II oonuInoo mnuconmna fir . 2v navl hmughl II to ynur alt-"Hem Ano yun. :0 mum. II sank. Inld.smII-bndy I IusI InouonI Inn A 2I okay. And |o ynur lawllecfion' was Inm a IImo Imn. 22 urn-non, .Iu wu InkoIv-o In ncsIuoa -- 21 on when was aflalr-- alleged allaIr hllween m: I: - I oIon-I IIav- any <Byers a. 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