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October 24, 2016 CONFIDENTIAL Page 141 CONFIDENTIAL Page 143 1 Q. And this is maybe two weeks, two and a half 1 Monday, Tuesday, Wednesday, Thursday, Friday? 2 weeks alter she?s commenced the divorce 2 A. I don't know. 3 action? 3 Q. And do you know what you were doing the 4 A. Correct. 4 evening before? 5 Q. Is she still in the home, too? 5 A. No, 1 do not. 6 A. Yes. 6 Q. Eventually you had a physical science class; ?7 Q. And your daughter, Jacquelyn, is there? . '7 is that right? a A. Yes. i 8 A. During the day? 9 Q. Anyone else? 9 Q. Yes. .10 A. No. 10 A. Yes. 11 Q. You get to work and what do you do? 11 Q. Do you know the initials or the name of the 12 A. Get ready for my day. Make coffee. 12 man who assaulted you that day? If you want 513 Q. in your classroom, or in the teachers' 13 to use initials we can do that, too. 14 lounge, or where always had a pot of coffee in the 15 Q. Are those some initials sometimes used for 16 classroom. A lot of teachers came to get 16 him, or not, or do you know? 17 eotfee done on my end. 17 A. At school? 18 Q. After you've made your pot of coffee, what 18 Q. Well, no, in this case. 19 are you doing? 19 A. FD. 20 A. Getting ready for the daythat, are you going over a lesson 21 A. I don't know. 22 plan, or what are you doing? 22 Q. Does he have a brother, too, that you're 23 A. Making Sure I got any handouts I need handed 23 aware of? 24 out, going over the grade book,just getting 24 A. I don't know either of these guys, I don't 25 prepared. 25 know. CONFIDENTIAL Page 142 CONFIDENTIAL Page 144 1 Q. Did you operate on semesters, quarters, 2 trimesters back then, or what did you use? 3 A. I think we were on quarters then. I think we 4 were on quarters. 5 Q. And your ?rst period of the day, did you 6 have, as you put it, a professional learning 7 group meeting, or not? a A. We usually met. We either met with a social 9 worker. Those were -- Sometimes we'd have 10 like staff development through the social 11 worker, but] always We met just about 12 every day. 13 Q. Who did you meet with? 14 A. Lisa Houdck was my PLC partner, and then Can youjust, for the reporter's sake, spell 17 Houdek? 18 A. 19 Q. Who elseDecember? 21 Q. The 4th. The day of this assault. 22 A. I don't even recall if we met on that day, 23 but the usual days, we would meet. I'm not 24 sure that we met on that day. 25 Q. Do yOu know if the 4th of December was a 310 Q. Was he in any ofyour classes? 1 Q. Just for the record, 2 Does that sound about right? A. I think so. Q. Before the assault, did you know at all? A. on recall ever knowing him. I couldn't pick him out of a lineup. 11 A. No. 12 Q. Ever? 13 A. Never. 14 Q. Okay. How about do you know if he had a '15 brother or sibling at the school, or not? 16 A. Yeah, he had a brother. 17 Q. Do you know what his name is or was? 19 A. I don't. Same last name, though, 1 think. 19 Q. Same last name? 20 A. Ithink soyou know if you had his brother in any of 24 your classes? 25 A. Idid not. Min-U-Script? Herbert L. Peterson 8: Associates (36) Pages 141 - 144 952-543-6910 ms", mimuummsm JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL Page 145 CONFIDENTIAL Page 147 1 Q. did you have any history 1 correctly? 2 with him in terms of discipline, working the 2 A. Yes. 3 halls, site work, cafeteria work, anything a Q. cannot recall the assault nor have I seen 1 before the assault? 4 any police reports regarding the assault." 5 A. I don't recall any. 5 Did I read that correctlyyou ever exchange words, or, 6 A. Yes. 7 you know, physically interact with each other 7 Q. Up to the present time, have you still not a before the assault? a seen any police reports? 9 A. [don't recall. . 9 A. That's correct. 10 Q. When you say you don't recall, is that 10 Q. Okay. To the best of your knowledge, do you 11 because of the injuries, or is it because, 11 see that, Plaintiff's knowledge? 12 you know, it's not because of the injuries, 1 12 A. Yes. 13 just don't remember meeting this kid? 13 Q. Mr. Ekblad "has not had any contact with 14 A. 1 don't remember meeting him. I don't. I 14 F.S.0. other than the assault on December 4, 15 don't even - I couldn't tell you what he 15 2015." Did I read that correctly? 16 looked like. 16 A. Yes. 17 Q. In looking at Exhibit 1, page 3, 17 Q. So this wasn't an instance where? 18 Interrogatoty Number 2, do you have that in 18 knew you before December 4th and there were 1?9 front of you? 1 9 words exchanged between the two of you 20 A. Uh-huh. 2O prefatory to this assault; am 1 correct? Do 21 Q. That's a yes? 21 you want to have it read back? 22 A. Yes. 22 A. Idid not know I didn'tknow him. The 23 Q. The says, "Identify in detail 23 only thing i knew was I didn't know he 24 your personal relationship with and 24 played football. I don't know who hit me. I 25 I'll tell you those are initials the courts 25 don't know who assaulted me. CONFIDENTIAL Page 146 CONFIDENTIAL Page 148 1 use fo_okay?? 1 Q. When?assaulted you, he might say 2 A. Okay. 2 he was acting in self-defense or his parents 3 Q. "State with particularity and Ee?ailI oneI 3 may say that. When the two of you had your 4 all contacts bethen you and 4 altercation on December 4th, you didn't have 5 outside the workplace, two, the names, 5 a clue ahead of time that such was going to 6 addresses, telephone number, email address 6 happen; is that fair? 7 and employer of every person who has '7 A. Correct. 8 knowledge as to those facts, and all Q. You didn't have words wit_you 9 documentation that re?ects, refers or 9 know, like egging each other on that we're 10 relates to your personal relationship with 10 going to duke it out or anything like that, 11 Did 1 read that correctly? 11 correct? 12 A. Yes, sir. 12 A. I remember nothing of that day except for one 13 Q. And you understood .80. is- 13 student asking me if I was okay, and then -- 14 14 lmean, the [remember nothing except 15 A. Okay. 15 watching my glasses ?y off my head in a slow 16 Q. Your answer you put is that you were a 16 motion video and watching them crash to the 17 full-time teacher at Central prior to 17 floor, and then it was gone. 16 December 4, 20l 5, correct? 18 Q. Before your glasses flew off, you don't 19 A. Correct. 19 recall an history, though, between you and 20 Q. And then you put, "On December 4, 2015 I 20 ?that let you know I'm going to 21 was assaulted by who is this 21 be in a ?ght with this kidCorrect. 23 Q. I'm correct, right? 24 Q. "And he pleaded guilty to the charges brought 24 A. Yes. 25 forth against him." Did I read that 25 Q. Okay. In other words, this assault was a Minih?icripn?i Herbert L. Peterson Associates (37) Pages 145 - 148 952-543-6910 th mtmnommam H?iiaye?a?m JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 EONFIDENTIAL Page 149 CONFIDENTIAL Page 151 1 surprise? 1 Q. Before the assault? 2 A. I would say yes. 2 A. Correct. 3 Q. Okay. The fourth page of Exhibit 1 here asks 3 Q. And that?s what I'm asking about. After the 4 you to describe every occasion ou met, 4. assault, there's been some mention that not 5 interacted or associated withh . 5 you but maybe Mark Krois heard this- 6 Do you see that? 6 say something to the effect he beat up that 7 A. Are you on number three? 7 fucking white teacher or something to that 8 Q. Page 4,1nterrogatory3 -- 3 effect, correct? 9 A. Yep. 9 A. Yes. 10 Q. -- of Exhibit 1. Do you see that? 10 Q. There was no language like that before the 11 A. Yeah, if you just read the first line on page 11 assault; is that correct? 12 4, Interrogatory 3. 12 A. I don't know -- I mean, once I -- No. 13 Q. Yep. 13 don't know. 14 A. Okay. 14 Q. Yep. And?this isnAnd you refer us back to that interrogatory 15 met or interacted or associated with at all 16 answer I just road, which was that you had 16 prior to the assault; is that fair? 17 had no contact wi_other than 17 A. I didn?t know him. . 18 that December 4th assault; is that fair? 18 Q. You didn't know? I?m sorry. 19 A. From my recollection Idon?t know. 19 A. I didn't know him before. That doesn't mean 20 Q. Are you aware omhaving any 20 that he's not one out of a group that, you 21 hatred or ill feelings toward you prior to 21 know, if you want kids to -- No, I didn't 22 the assault? 22 know him. 23 MR. PRIEBE: I object as it calls 23 Q. You're not aware, and when I say that, 24 for the state of mind of another. You 24 "you're not aware." John Ekbiad is not aware 25 can answer if you know. 25 of?having some hatred or ill CONFIDENTIAL Page 150 CONFIDENTIAL Page 152 1 MR. ROCHEFORD: No, I?m not asking 1 will for you prior to him assaulting you, 2 fo F50 I'm asking for John 2 correct? 3 Ekblad's. He can read it back to you if 3 A. Correct. 4 you want. 4 Q. Still on Exhibit 1, page 5, Interrogatory 5, 5 THE WITNESS: Will you read it back 5 in your lawsuit, there are, I think, fear 6 to me? 6 claims asserted, or they're captioned as 7 THE COURT REPORTER: Yep. '7 such. One of them is negligence or negligent a (The reporter read from the a supervision by my clients. Do you understand 9 record as requested.) 9 that? 10 THE WITNESS: I don't know ifhe 10 A. Yes. 11 did or he didn?t. 11 Q. Do you understand that in this particular 12 BY MR. ROCHEFORD: 12 instance, you cannot sue the school district 13 Q. Well, let me ask it this way: You den't have 13 or Dr. Battle or Superintendent Silva for 14 any facts or information as we sit here today 14 negligence, but you may be able to state a 15 that he had some hatred or personal animosity 15 claim for gross negligence? Do you 16 I'll even call it, he had that before the 1 6 understand that? 17 assault oi?you? 17 MR. PRIEBE: object as to it 18 A. ldon?t know if this is a legitimate answer. 16 calls for a legal conclusion. You can 19 His actions and his alleged statements 19 answer. 20 a?er -- 20 BY MR. ROCHEFORD: 21 Q. We'll get into those in just a second. 21 Q. If you don't know, that's year answer. 22 A. -- might indicate that, butI have no 22 A. I don't know. I don't know what you're 23 knowledge that he wanted to do what he did to 23 talking. 24 me, whatever they did to me, to put me where 24 Q. That's fine. You've alleged in your lawsuit 25 I am today. 25 that my clients failed to take adequate Min?U-Sc riptth?.? Herbert L. Peterson Associates (38) Pages 149 - 152 952-543-6910 CASE CASE0:16-cv-00834-DSD-SER 0:16-cv-00834-DSD-SER Document Document105 44 Filed Filed03/21/17 06/09/17 Page Page40 40of of100 100 CASE CASE0:16-cv-00834-DSD-SER 0:16-cv-00834-DSD-SER Document Document105 44 Filed Filed03/21/17 06/09/17 Page Page41 41of of100 100 CASE CASE0:16-cv-00834-DSD-SER 0:16-cv-00834-DSD-SER Document Document105 44 Filed Filed03/21/17 06/09/17 Page Page42 42of of100 100 H-Tii??ili?imgll?? Wil?a?m JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 6_25, ET AL. October 24, 20 I6 CONFIDENTIAL Page 165 Page 1 employed in the district, if you can't have 1 Q. Door 15? 2 somebody there monitoring, you can't monitor 2 A. Not the only door that was a magnetic door 3 what?s coming in. 3 that was left unlocked. a Q. Exhibit 9 here in the upper left-hand comer, a Q. And then there's a mention "we need key card 5 it says, "Kraus, Ekblad." Can you read those 5 readers on elevators? as well; is that 6 other names across there? 6 correct? 1 A. Nordquist, Modelli, Duane Dutrieulle. I got 7 A. And, and I'm not - That's true, too. a hurt in ?15, '14-?15. It says Dutrieulle. a Q. And then it says, "iPad rollout, 9 Flanders, Steve Collins, Tracy Funk. Look 9 accountability, communication. Phones went 10 for a name on that list that starts with an 10 down, systems fail.? I can?t read thatThey have all our phones tied into the 12 Q. What are you looking at? 12 intemct. If the internet goes down and you 13 A. Right before -- Between Funk and It says 13 have an emergency in your room - Say a 14 Funk. 14 science teacher is doing something in their 15 Q. It's crossed out. 15 classroom. Something blows up. They're 1s A. Funk dash. 16 doing an experiment, and the phones are down 17 Q. Nelson? 17 because the internet is down, which happened 18 A. Kim Nelson. 1 don't know who Kim Nelson is. 18 quite often, there was no way to contact 19 Q. Klopp? 19 anybody. 20 A. Andrew, special ed guy. . 20 I mean, send a couple kids on the run if 21 Q. And Krois?? 21 you want. Like for softball, you have a 22 A. And Krois. 22 safety plan, you know, two kids go here, 23 Q. Are these meeting minutes, or do you know 23 direct the ambulance in a certain direction. 24 what these are? 24 Two kids go ?nd the athletic director. Two 25 A. These have to be meeting minutes, what we 25 kids go to the principal's of?ce, you know, Page 186 CONFIDENTIAL Page 168 1 talk about. This is 'l4. 11/ 17/14. '15. 1 and somebody always had to have a phone. So Q. They're talking about a door that's open; is 2 if the phones are down and the internet is 3 that right? a down, what the hell. We can't contact 4 A. Yeah. 4 anybody. 5 Q. that door doesn't have anything to do with 5 Q. And there ought to be a plan to be able to do 6 your assault, does it? 6 the contact when the internet is down? 7 A. No, but it's a safety concern in the '7 A. Somehow the hard lines still have to be a building, a huge one. functioning. There has to be some way for a 9 Q. Do you see where it says in parenthesis, is 9 teacher in distress to be able to call for 10 it "mags" or what is that word? Do you see 10 help, and it's not there. 11 that? 11 Q. This assault by -f you didn't have 12 A. Mags is magnets. We used to have magnets 12 anything to do with the internet going down, 13 that wer -- They - '13 though, correct? 14 Q. They're on a door? 14 A. Number -- 15 A. They?re on a door, and if the magnets are 15 Q. No, no. Answer the question, if you can. 16 engaged, yeah, the kids could get cut, but 16 A. ldon't know if the internet was up or down 17 you'd really have to kick the door to get the 17 when 1 got hurt. 18 magnet - to kick it with enough force to 18 Q. Did the internet have anything to do with 19 break that ?eld, but from the outside, you 19 your getting hurt? 20 couldn't get in. 20 A. [can?t speak to that. Idon't know what 21 They took -- They didn't take the 21 would make anybody that angry to attack me 22 magnets off. They disabled the magnets. So 22 like that. 23 the doors were unlocked and there was no key 23 Q. Okay. The next item says "cyberbullying 24 card, no nothing. So anytime during the day, 24 harassment." 25 it was an in and out doorway. 25 A. Big deal. Huge deal. Min-U-Scripttii) Herbert L. Peterson Associates (42) Pages 165 168 952643-6910 [DImumm?ttJ?DfB HWIEIUGIIBRIQZIW mandates JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 Page 169 CONFIDENTIAL Page 171 1 Q. "No privacy rights. Personal 24-hour lock, 1 you haven?t asked. I mean, you were usually 2 iPad embedded curriculum." 2 sworn at about 7:45 in your room just for 3 A. All the kids get iPads. The ?rst part of my 3 asking kids to do what they need to do. 4 day is the check-in question. So I plug in a Q. So in November of '14, dcpendin on your 5 my daily question and I open my -- All the 5 color or race, is that what you're saying, 6 kids, when they come in my room, they log 6 some kids could do whatever they wanted to do 7 onto my password and then they all have to do 7 in the school? a the same question. - 8 A. Yeah. 9 So I get instantaneous knowledge of, 9 Q. Did that, in your estimation, have anything 10 number one, who guessed right or who answered 10 to do with your December 4th assault? 11 correctly, who didn?t answer correctly, and 11 A. I can't really speak to that, but I can 12 so that -- But the iPad rollout was an 12 This kid pled guilty to assaulting me and I 13 absolute crazy wild time, because the kids, 13 read an article in the paper, or it was off 14 there was no ?lters on the net. So you had 14 some report, and Excuse me. He looked at 15 kids sitting in your class trying to watch 15 the judge and said, thought you were 16 some Net?icks ?lm and if you ask them to 16 supposed to care about me," and I read that 17 turn it off, they I mean, it's not like 17 and I cared -- I don't know who hit me, but 18 when we were in school. 18 you want to know what? 1 still care about 19 MR. PRIEBB: John, I?m going to 19 that kid who hit me, you know, because either 20 remind you to just answer his question. 20 you read a really good book or you find a 21 THE WITNESS: Okay. Sorry. 21 great mentor. That?s how lives are shaped. 22 MR. PRIEBE: And wait till a 22 MR. PRIEBE: l'll remind you to 23 question is posed before you respond, 23 think back to his question and answer 24 okay? 24 his question. 25 THE WITNESS: Sony. 25 THE WITNESS: Can you ask it again, CONFIDENTIAL Page 170 CONFIDENTIAL Page 172 1 BY MR. ROCHEFORD: 1 Larry? I'm getting a headache. 2 Q. The cyberbullying and the iPad atcrial that 2 MR. ROCHEFORD: Do you want to take 3 didn't have anything to do with? 3 a minute? 4 assaulting you, though, did it? 4 THE WITNESS: No, that pill will 5 A. Ican't speak to that either. 5 kick in. 6 Q. Then it says, and if I'm not reading this 6 MR. ROCHEFORD: Can you read that 7 correctly -- I don't know whose handwriting 7 back, Mr. Boos? 8 this is, but I'll give it a try here, "We 8 (The reporter read from the 9 have to stop allowing the behavior where 9 record as requested.) 10 students think the -- 10 THE WITNESS: If the kids comment 11 A. "Can do." 11 about the fucking white teacher, I 12 Q. can do whatever they want." Did I read 12 really don't think it -- 1 don't know. 13 that correctly? 13 I can't answer that, Larry. 14 A. Yes, you did. 14 BY MR. ROCHEFORD: 15 Q. What's that talking about? 15 Q. The last item on Exhibit 9 says, "Steps need 16 A. Just the fact that the consequences, the 16 to take stronger steps" - 17 negative behaviors, they weren't consistent. 17 A. "With.? 16 They weren't consistent across race. 18 Q. I'm thinking it says "dealing," but I?m not 19 Q. Sex? 19 sure, "dealing with behavior affecting other 20 A. You know, I can't really speak to -- It 20 students and staff." Did I translate that 21 depended on what color you were if it was 21 handwriting on Exhibit 22 sex. If it was race, it was -- If you were 22 A. Yeah. 23 of a certain color, you had different 23 Q. And what is that discussion about? 24 behavioral consequences, and the kids 24 A. I think it?s -- Not this one, but the 25 mean, I don't want to answer any questions 25 (pointing) but the student handbook. The Herbert L. Peterson 6; Assoclates (43) Pages 169 - 172 952-543-6910 JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL Page 173 Page 175 1 student handbook. Just follow the rules in 1 A. Somebody must have known. You don't. He 2 the student handbook irrespective of color, 2 doesn't. I don't. Somebody knew. 3 irrespective of -- Just follow the rules, you 3 Q. Certainly John Ekblad didn't know that this a know. Ithink that's what that -- Have a 4 kid would assault him on the 4th of December, 5 consistent - If one group is being not 5 fair? 6 chastised for behavior, itjust leads to 6 A. Fair. 7 escalated behavior. It emboldens them to do 7 Q. Are you aware of anyone who has come a more, and it?s not because they're teenagers. 8 forward and said, "Mr. Ekblad, I knew that 9 It's not because of their home life. It's 9 _was going to attack you on 10 not because of anything. 10 December 4, 2015 and I knew that before it 11 I'm a physics teacher. Nothing happens 11 happ ened"? 12 unless all the forces are there. Ultimately, 12 A. Idon?t know if there is anyone. Maybe 13 if I throw the ball and hit you in the head, 13 somebody in the group knew. 14 yeah, the ball hit you in the head. You can 14 Q. But you?re not aware of anyone? 15 argue physics that I had nothing to do with 15 A, No. 16 the ball hitting you in the head because it 16 Q. Let me show you Exhibit 10. Exhibit 10 17 wasn?t touching. It was the fact that you 17 appears to be some handwriting dated 18 had your head there. Do you know what 1 16 November 17, 2014; is that fair? 19 mean? 19 A. Yeah. 20 There was more than my thing. There 20 Q. By the way, any of these handwritten notes, 21 were kids being and other teachers being 21 do you recognize any of the handwriting, or 22 punched and stuff before me. It wasn?t like 22 not? 23 all of a sudden we came up with this idea 23 A. I don't recognize it. 24 that somebody is going to get hurt, seriously 24 Q. Okay. Exhibit 10 at the top, it talks about 25 hurt, and we didn't know who it was going to 25 ?nal tire drill is in the spring; is that CONFIDENTIAL Page 174 CONFIDENTIAL Page 176 1 be, and that?s part of policy stuff. It?s 1 right? 2 closing your eyes to the truth. 2 A. Yeah. 3 Q. Are you saying that you had a population of 3 Q. And it talks about intruder during passing in 4 students, you may not be able to say who, but 4 lunch. What is that talking about? 5 you had students whose behavior was not 5 A. I'm pretty sure that's our -- Well, if you go 6 compliant with the student handbook? 6 to the line below where we discussed how will 1 A. Yes. 7 we deal with it, because And you had students, even without a trespassing in the building that was going 9 handbook, that were unruly and vioient and 9 on. So this was what are we going to do if 10 foulmouthed and inappropriate for normal 10 some of this street stuff spills into the 11 society? 11 building? If somebody does come in, how are 12 A. Yes. 12 we going to deal with it? "Lockdowns, 13 Q. And something had to be done to get them 113 alarms, bells, for realistic drill." 1a compliant with the rule of law and 1-1 I mean, we had at one time -- You know, 15 appropriate behavior in a high school? 15 the kids think it's a bi joke. Well, not 16 A. Yes. 16 all the kids. You're supposed to get all the 17 Q. Was this _vcn in Central in the 1'7 kids huddled in the back corner of your room. 18 2014-2015 school year, or do you know? 18 They?re supposed to be quiet. You?re 19 A. Idon't know, because I got hurt '15-'16 19 supposed to turn the lights off in your room. 20 is when I got hurt, so I don't know where he 20 You're supposed to lock the door. 21 was before. 21 Well, I had an incident in mine where 22 Q. And we don't know, you or] don't know, your 22 I'm on the Safety Committee and my PA, my 23 lawyer doesn't know if as one 23 public address in my room didn't work. So 24. of these unruly kids, violent kids before 24 when the alarm went off, I didn't hear about I: December 4, 2015, fair? 25 it. When they came to my room, there's John. Herbert L. Peterson Associates (44) Pages 173 - 1'76 952-543-139 10 i manometer]? H?iaaye?u?m JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFLDENTIAL Page 177 CONFIDENTIAL Page 179 1 There's I ohn's class. I?m teachingthe lunch. I didn't hear it. 2 walked in and he says, ?You're dead," and I'm 2 I saw her waving me over and I came over and 3 like, "Why?" "Because you didn?t do the 3 then got sucker punched. That's all I 4 lockdown." says, is not working," you 4 recall. I don't even know if I got sucker 5 know. 5 punched. I don't know what hit that wasn?t working in your classroom, 6 head. 7 that didn't have anything to do witl_ 7 Q. I?m going to give you a sheet of paper, which a assaulting you, though, on the 4th of a [will eventually put a sticker on. Could 9 December, fair? 9 you do a bird's-eye view of the lunehroom 10 A. I wasn't there. IWas in the Iunchroom. 10 where you were assaulted, where the tables 11 Q. The items listed here on Exhibit 10, for 11 were and that sort of thing? And I'll give 12 example, they talk about if you hear 12 you a pen. 13 gunshots, get out of the building however you 13 A. There's three tables, three tables. 14 can. These are all items you guys discussed you want me to do it? 15 in this November 17, 2014 meeting? 15 A. You think that handwriting is bad. 16 A. Yeah, assuming -- I don?t recall the speci?c 16 Q. Okay. Let me -- 17 meeting, but these are notes. It?s an exit 17 A. Here is like a -- Here is a trophy case, like 13 nightmare from our lunchroom. We've got 800 18 a cabinet, atrophy cabinet. 19 kids in a 700.plus maybe lunchroom. We get a 19 Q. Let's do this first off, like Lexington 20 lot of kids in there, overbooked, and that's 20 Avenue, or north, south, east. 21 a policy issue. 21 A. Lexington (pointing), Marshall. 22 I mean, that?s a ratio Lexington is over here. 23 we have one exit door. We have an opening 23 A. Marshall. 24 that takes you to the front doors. If the 24 Q. Does Marshall have one 25 person is coming in that way, there's only 25 A. I don?t know. CONFIDENTIAL Page 178 Page 180 1 one other exit out of that lunchroom, and 1 MR. PRIEBE: I think it's two. 2 it's a single door, and that's a lot of 2 THE WITNESS: Okay. So there's 3 bodies to getjammed down a set of steps 3 tables running this way here, and then 4 three feet wide. 4 there was a short thin little alley and 5 Q. There's other notes here about cursing and 5 then there's a bunch of tables here, and 6 disrespectful and other what I'd call 6 these guys come all the way down by the 7 inappropriate behavior by students to others, 7 front door. a to each other and to staff. That was 8 BY MR. ROCHBFORD: 9 discussed at your meetings? 9 Q. It's a rectangular building? 10 A. If that's what's on the notes, that's what we 10 A. Yeah. The lunchroom is kind of L-shaped, so 11 talked about. Where are you on that, page 11 it goes like this. 12 two? 12 Q. Is it on the ?rst floor? 13 Q. Well, two and three. 13 A. Second floor. 14 A. Okay. 14 Q. Second ?oor. 15 Q. Disrespect?il language betWeen students to 15 A. There's one exit here. There's a trophy case 16 staff and teachers, that doesn't necessarily 16 here. So Iremember the tight starting right 17 lead to violence, does it? 17 here (pointing), and I'm being waved over by 18 A. It can. It has. I'm evidence of that. 18 the special ed lady because she sees it going 19 Q. There were words exchanged between some young 1 9 on and I come over item here (pointing). 20 students that precipitated the assault on 20 Q. We can't get any of this on the record when 21 you; is that right? 21 you point to stuff, so we need to put some 22 A. I couldn't hear any words. I was waved over 22 more landmarks in. 23 by a special ed support girl, like here's the 23 A. Put trophy case right there (pointing). 24 ?ght. Here is the table of physically and 24 Q. Trophy case. 25 mentally handicapped kids who wipe tables off 25 A. And that's our exit (pointing). Min-U-Srriptth Herbert L. Peterson Associates 952-543-691 0 (45) Pages 177 180 CASE CASE0:16-cv-00834-DSD-SER 0:16-cv-00834-DSD-SER Document Document105 44 Filed Filed03/21/17 06/09/17 Page Page47 47of of100 100 mime mem JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 6?15, ET AL. October 24, 2016 CONFIDENTIAL Page 185 CONFIDENTIAL Page 187 1 A. 5/4. I?ve got May 4, '15. 1 Q. What policies? 2 Q. Yeah, May 4, 2015. 2 A. I would say not dealing with kids 3 A. Maybe it was what do we think or why are 3 irrespective of color, by having one set of 4 things the way they are. Our feeder school 4 ground rules. The blame game is pretty 5 is Ramsey, number one. Ramsey had serious 5 serious with under the tutelage of Paci?c 6 issues and they feed Central, because we've 6 Education Group where I don't know of a 7 gene to the neighborhood school. 7 teacher in the building that doesn't want the a I think there were nine upwards plus 8 best for every kid there. 9 teachers that walked from their employment at 9 Q. You're saying Paci?c Education Group, 10 Ramsey because the behavior was what the 10 sometimes I think it's called PEG, did 11 behavior was and there were no policy changes 11 something to St. Paul schools to create 12 at Ramsey until our then superintendent was 12 violent students? 13 in the building, requested a kid to follow 13 A. I think that -- They didn't do it to the 1a the behavior in the student handbook and he 14 schools. 1 think the schools allowed it to 15 basically told her to off and asked her 15 happen based on the .. I can't think of the 16 what her name was, and then stuff started to 16 word -- the paradigm they want people to act 1'7 happen. 17 under. 18 Q. The behavior these kids who are 18 Q. I don't understand. 19 disrespectful, use bad language and so forth, 19 A. Institutional racism. I don't care what 20 are you saying the school is creating that 20 color you are in my classroom. I'm a physics 21 behavior, or the kids come there with those 21 teacher. I tell the kids you're not the 22 behaviors? 22 color you've been checking forever because 23 A. Well, if you talk to a lot of parents, the 23 the color you?re showing is the color you're 24 parents will say, well, they never act that 24 not. You don't have gray hair. You have 25 way at home. 25 every other color but gray hair, because the CONFIDENTIAL Page 186 CONFIDENTIAL Page 188 1 Q. Do you believe that? You've been doing this 1 only light I see coming of? your head is 2 21 years. 2 gray, therefore it's not gray, and they 3 A. I've kind of got the you are what you come 3 scratch their heads. 4 from, and until you get a good book or ?nd a 4 I pour my heart out to those kids, 5 great mentor, you know, ifthat?s what's 5 Larry. They scratch their heads, but by the 6 going down at home, you're going to come to 6 end of the year, they ?gure out that they '1 school and you?re going to act the same Way, 7 don't really -- and they never did. They a but the policies have diminished the respect it didn't care what I knew until they knew that 9 level that kids show towards teachers because 9 I cared about them. 10 it gives them maybe a sense of power and at 10 Q. I'm not tracking with you at all actually. 11. school because they can exhibit those 11 A. Okay. Paci?c Education Group discusses 12 negative behaviors and in some way make 12 institutional racism, and whether it exists 1a themselves feel more powerful, because an 13 or not, I am not a racist. I don?t care what ,14 adult is powerless to -- I mean, what do you 14 color you are. You have to go to school. '15 do? I mean, a kid looks at you and y0u ask 15 Your circumstances, I'll talk to you about 16 them what their name is and they tell you, 16 them all you want to talk about your 17 U. You go, "Hey, I just met your brother. 17 circumstances. This is when I had a job, 13 He's right over there. It's just like George 18 could do my job. My story matches a lot of 19 Foreman. He's got the same name you do." 19 theirs, and I made it because I got a good 20 The intercity -- And I?m not saying 20 education. 21 Minneapolis is better or anyplace else is 21 Q. Are you saying that some policy of the 22 better, but I know the policies that we've 22 Paci?c Educational Group caused? 23 got, whether written or unwritten, are 23 to assault you on December 4th? 24 leading to a very unsafe environment for 24 A. I can?t speak to whether it caused him to, as anybody who is in the building. 25 but I think it does, in an of?tanded way, Herbert L. Peterson Associates (47) Pages 185 188 952-543-6910 VI. H-TIEIUGEERIQZIZW JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL page 139 ICONFIDENTIAL Page 191 allow kids based on their color or behavioral choice an avenue to act out in any way they want irrespective of the district policies that are written in the handbook. Q. I?m going to show you Exhibit 13 here. That looks like it?s a February 26, 2016 meeting minute from yoor Safety Committee; is that right? Yep. That would have happened after your assault; is that right? Yep. . Okay. Showing you Exhibit 14, another meeting minute from April 21, 2016. Again, that would be after your assault; is that right? Yeah. Yes. 18 Q. Then I think the last one I've got here is 19 Exhibit 15. It's another meeting minute, but 20 it has your name on there. It says October 21 6th, and it has Some other names there, so 22 I'm assuming that it had to be, you know, 23 either 2014 or 20] 5. So that must have been 24 a meeting minute before your assault, is that as fair? ODOQQUQMMH 5.: to? 40501th high was supposed to be reconstituted under the guidelines of No Child Left Behind because it was a low-performing school. Then the district unilaterally decided that because we were a complex, they were going to reconstitute the high school at the same time, and when they reconstituted Humboldt Senior, they also reconstituted a number of different high schools in the city of St. Paul. When they did that, the vast majority of us were 45 and older. There were only, I think, two people that were over 45 that were left at Humboldt. We Were told to ?nd employment in the district at a different high school. At the same time under Carstarphen, they were hiring community experts, which were people who were not trained speci?cally in teaching. So you would set up an interview and you would go to these other high schools and interview, but they had already earmarked that position for a community expert. So it was kind of a -- I didn?t get involved in that. I mean, I went to the CONFIDENTIAL Page 190 1 A. Uh?huh. 2 Q. That's ayes? 3 A. Yes. 4 Q. The last item there that's asterisked, 5 "Identify students for staff that are threats 6 to staff. Stat? walks by because of safety 7 concerns/harms way." Do you see that? a A. Yes. 9 Q. Was there ever a mention in this meeting 10 aboutF 50- do you know? 11 A. 1 don?t recall. 12 Q. Or any student? 13 A. From the notes, no. 14 Q. Okay. 15 A. i?m going to grab a water. 16 MR. .PRIEBE: Do you want to take a 17 ?ve-minute break? 18 THE WITNESS: No, that's okay. 19 BY MR. ROCHEFORD: 20 Q. Did you have a human rights claim against the 21 school district? 22 A. I think when we did the restructuring -. When 23 the district under Carstarphen did the 24 restructuring of Central High School -- or 25 not Central, Humboldt High School, the junior QimU?thNH looks like you grieved the Humboldt layoff Page 192? meeting that they had with all the older teachers, and these guys were -- I think the spectrum, but the guys who were 55 to 60, they were, you know, they were caught, and then they came on with the buyout. They put a buyout thing connected with it, because most of these teachers that were older were at the top of the salary schedule. I get it. School is a business. So I don't know how that thing all played out, because then I went to work at Highland. I finally got thejob at Highland, and that was a very late in the year appointment, and I really didn't like teaching chem, but they got me into a chem spot. I'll call it or reduction in force on about September 4, 2009. Does that sound right? Yeah. And then there would have been a Your complaint or whatever proceeded through the US. Equal Employment Opportunity Commission and it was denied; is that right? Min-ti-Scripte?) Herbert L. Peterson Associates 952-543-6910 (48) Pages 189 - 192 H-TIEIUGIRIRIBZIW JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL Page 193 CONFIDENTIAL Page 195 1 A. If you've got the paperwork on it. 1 BY MR. ROCHEFORD: 2 Q. Is that what Exhibit 16 is? 2 Q. But from your knowledge, you?re not aware of 3 A. Yeah, that was all about the reconstitution. 3 him having any personal vendetta or hatred 4 Q. Superintendent Silva was the superintendent 4 against you, true? 5 at that time? 5 A. From his statements after, which I did not 6 A. No, this was - I think her name was Meria 6 hear, he seemed to take great pleasure in the 7 Carstarphen. I don't think Silva was in. I 7 fact that I was the white teacher. a thought it was Carstarphen at that time. . a Q. The statements that were attributed to him 9 Q. Let's look at -- 9 after your assault. There was no mention of 10 A. It says at the bottom of the ?rst page that 10 anything like that before your assault, true? 11 it was Silva. 11 A. The situation was - Once that stuffgoes, 12 Q. Yeah. 12 people are ?ghting to stand on tables to 13 A. That went -- I can't remember the exact dates 13 ?ll. The noise is ablur. I didn?t hear 14 on this. She might have been superintendent 14 nor do I recall anything. I wish I could. 15 when they ?nished. I thought Carstarphen 15 Q. So you don't have any facts or information 16 was allegedly the big union breaker and she 16 that anybody had any notice or knowledge you 17 went to Texas after that, a?er us. We were 17 were going to be assaulted before its 18 just a stepping stone for her, but I don't 1e occurrence? ?19 see her. 19 MR. PRIBBE: Object as asked and 320 Q. In any event, at some point in the process, 20 answered on multiple occasions. You can 21 Superintendent Silva was -- 21 answer again. 22 A. [know -- 22 WITNESS: Somebody might know. 23 Q. the superintendent? 23 I don?t. 24 A. Yeah. 24 BY MR. ROCHEFORD: 25 Q. And Exhibit I7, is that a copy of your letter 25 Q. You're not aware of anybody? CONFIDENTIAL Page 194 Page 196 1 to Ramsey County District Court Judge Clark 1 A. (Witness shakes head.) 2 regarding y0ur desires as it re ards the 2 THE COURT REPORTER: What was the 3 punishment to be given to? 3 answer? 4 A. Yeah. 4 MR. PRIEBE: I didn?t hear any 5 Q. I just wanted to get through those items 5 answer. 6 quick. I just want to ask you, because we 6 THE WITNESS: I?m not aware 7 really haven't gotten it out here in great 7 personally of anybody. 8 detail, at the time of the November -- Excuse 8 BY MR. ROCHEFORD: 9 me. At the time of the December 4, 2015 9 Q. Thank you. When you worked in that 10 assault, do you agree you were on the job, on 10 cafeteria, part of your job is to supervise 11 the clock working for 625 when you were 11 the cafeteria, isn't it? 12 assaulted? 12 A. Yeah. 13 A. I do agree with that statement, but! 13 Q. And to provide appropriate security? 14 still reiterate that the beating] took on 14 A. There is nothing -- I got - On December 4, 15 December 4, 2015 had absolutely nothing to do 15 2015, I got assaulted by this kid. It had 16 with the duties ofmyjob. 16 nothing to do with myjob. It had nothing to 17 Q. And it also had nothing to do with 1?7 do with my job duties. I?ve been a teacher 18 an ersonal animosity on the part of 18 for 21 years. I have -- It had nothing to do 19 gainst you, true? 19 with my job. 20 MR. PRIEBB: I object to the form 20 MR. PRIEBE: Did you understand 21 of the question. It calls for state of 21 his -- 22 mind of another. You can answer. 22 MR. ROCHEFORD: We've heard that 23 THE WITNESS: I can?t speak his 23 about ?ve times. 24 state of mind. 24 THE WITNESS: Isn't that your 25 25 question? Min?ILSt?rIpttib Herbert L. Peterson Associates (49} Pages 193 - 196 952-543-6910 th mtmnummnm 9153395]le JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 Page 197 CONFIDENTIAL Page 199 1 MR. Why don't you read 1 something has got to be done. 2 back the question? 2 BY MR. ROCHEFORD: 3 (The reporter read from the 3 Q. So you're saying that Superintendent Silva, 4 record as requested.) 4 Dr. Battle or the school district should 5 THE WITNESS: No. 5 exercise its discretion to spend more money 6 BY MR. ROCI-IEFORD: 6 for lunchroom supervision, including hiring 7 Q. You were not to provide security for the 7 an outside security firm, if necessary? a cafeteria or lunchroorn? a MR. PRIEBB: 1?11 object to the 9 A. I contest the word appropriate. I don't 9 form of the question as using the term 10 understand what appropriate security I could 10 discretion. If you understand, you can 11 have provided in that situation. 11 answer. 12 Q. Because it happened so quick? 12 THE WITNESS: The ratio is The 13 A. Because it happened the way it happened. 1.3 ratio of kids to supervision is not 14 Q. Well, tell me, how did it happen, to your 14 adequate. It'sjust not adequate. 1 1s knowledge? 15 mean, anybody could have got caught up 16 A. I walked down andl got hit in the left 16 in that melee. Anybody could have got 17 temple. ldon't know where it came from. I 17 caught up in that melee, and we are 18 don?t know if it was a foreign object. I 18 without the tools to protect ourselves, 19 know - I have no recollection of what hit 19 you know, let alone, what do you do, put 20 me, but whatever it was, it was hard, and it 20 us behind a fence? They can?t put us 21 was damaging. 21 behind a fence. 22 Q. Prior to the assault, were you responsible 22 BY MR. ROCHEFORD: 23 for supervising the premises or students in 23 Q. So whoever set that ratio of two lunchroom 24 the lunchroom? 24 supervisors per several hundred students, you 25 A. Yes. 25 need more adults or teachers or supervisors CONFIDENTIAL Page 198 CONFIDENTIAL Page 200 1 Q. What would have been, in your estimation, 1 for that number of students? 2 reasonable policy, procedures or 2 A. Yes. 3 precautionary measures, education or training 3 Q. So whoever is making that decision or 4 that would have prevented _from a designation two for several hundred students, 5 assaulting you? 5 that?s, in your observation, not a good 6 MR. PRIEBE: I object as to 6 decision? 7 compound, overly broad and vagueyears of experience, I would say a can answer. a that is not a good decision, but is that a 9 THE WITNESS: [think a student 9 building-level decision based on a budget and 10 staff supervision ratio that would be 10 how to appropriate those funds, and to me, 11 less - that would ensure the safety of 11 safety - 12 more people. Two lunchroom supervisors 12 Q. Is it -- 13 for 900 kids, that's crazy, and that's 13 A. Two? 14 all budget. That's all safety budget. 14 Q. Is it, you know, whoever is running the high 15 It costs them, on your exhibit whatever, 15 school, is it their decision? 16 eighteen hundred bucks for a lunchroom 16 A. I have no clue how it goes. I know that 17 supervisor. ;17 recommendations that we've sent before up to 18 If this would have happened to a ?18 the district of?ce, it's -- I mean, I look 1 9 student, if my injuries were to a 19 at that one, your exhibit after I left, and 20 student -- And we've far exceeded that 20 the discussion seems to be like, "Okay. Now 21 amount for my supervision pay in medical 21 we've got to do something because Ekblad got 22 bills. There should be staf?ng such 22 his ass kicked," where before, it was 23 that we could do a far better job 23 climbing there. It was climbing there, and 24 detecting. I mean, 1 don't care if you 24 now it's here, and, "Oh, no, what are we 25 hire an outside security ?rm, but 25 going to do now?" Did I answer your Mln~UeScripl? Herbert L. Peterson Associates 9532-5436910 (50) Pages 197 200 th?? JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 BONFIDENTIAL Page 201 CONFIDENTIAL Page 203 1 question? 1 A. Enforce the policies the way they're written 2 Q. Let me ask you another one. I'll try it this 2 in the handbook and not have a different set 3 way. Ifwe had one more lunchroom 3 of rules just because somebody is of a 4 supervisor, would that have been adequate? 4 di??erent race. 5 MR. PRIEBE: Object, speculation. 5 Q. Was there notice and an opportunity to 6 THE WITNESS: On that given day, I 6 enforce those rules before 7 don't know. 7 assaulted you? 3 BY MR. ROCHEFORD: a A. If there was a behavior record -- Do you have 9 Q. How about if we had ten more? 9 any behavior records for him prior to 10 A. Kids will be safer. 10 December 4, 2015 during the 2015-2016 school 11 Q. It's still possible, though, that you could 11 year so we could see that? Do we have any 12 have been assaulted? 12 records of any misbehavior from any other 13 A. I don't know. Idon't know. 13 high schools that?Was at that 14 Q. Because you just couldn'tpredic_14 came to us that I could look at that 1 could 15 jumping you and assaulting you? 15 try to assess that information to try to keep 16 A. I didn't know he was going to do what he did. 16 myself safer and my other colleagues safer 17 He had the propensity. 17 and the other students safer. 18 Q. He had a propensity to assault people? 18 Q. Assuming there are none, would you agree 19 A. His behavior would indicate that. 19 there is nothing to look at to share with 20 Q. What behavior? 20 others to alert people that one day 21 A. He pled guilty to assaulting me. 21 ?may assault teachers or staff 22 Q. That was after the fact, though, true? 22 or other students? 23 A. Well, yeah. 23 A. I'm doing my hestjust to answer your 24 Q. Okay. Are you aware of him having any known 24: question. Can you read it back to me? 25 propensity before December 4th to assault 25 THE COURT REPORTER: Yep. CONFIDENTIAL Page 202 CONFIDENTIAL Page 204 1 people? 1 (The reporter read from the 2 A. 'I'ltat I do not know. 2 record as requested.) 3 Q. Would you agree if ad poor 3 THE WITNESS: If we assume there . 4 grades 4 aren't any, but it?s still not any 5 A. I didn't know what his rades were. 5 direct correlation that he will not do 6 Q. Let me ?nish. If ?had poor 6 that, if we assume there are zero. 7 grades before your December 4th assault, that 7 BY MR. ROCHEFORD: 8 isn?t knowledge that he has a propensity to a Q. Today we know that?went through 9 assault, is it? 9 an expulsion, trueSt. Paultruancy issue, 11 Q. Yes. 12 failure to attend school, and that was known 12 A. Yes. 13 before your December 4th, does that mean he 13 Q. And we know he went through the court system 14 had a propensity to be assaultivc? 14 in Ramsey County for this assault as well, '15 A. No. 15 true? 16 Q. And if as de?ant, would get up 16 A. Correct. 17 from a classroom, go to the bathroom, was 11 Q. Today we could say that mud a 18 disrespectful to fellow students or teachers 18 prior instance of an assau an we con put 19 or sta??, does that mean he was known to be 19 that in maybe a cumulative ?le so peeplc 20 assaultive? 20 could look at his cumulative ?le and say 21 A. No, but it's a good indicator that you should 21 maybe this is someone we out to watch more 22 be careful. 22 closely or maybe he shouldnyou know he?s de?ant, what should you do 23 public schools. Is that fair? 24 if you're the school district, Dr. Battle or 24 A. If he can't comply with the rules, maybe that 25 Superintendent Silva? 25 is an outcome somebody needs to look at. I Min?U-Scrinlt?i) Herbert L. Peterson Associates (51) Pages 201 - 204 952-543?691 0 th mrmuummym W?wm JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL Page 205 CONFIDENTIAL Page 207 1 Q. But we didn't have that knowledge with 1 people have knowledge of ?being 2 F-SO- efore December 4th, did we? 2 assaultive or that he was about to attack 3 A. I didn't. 3 you? 4 Q. Do you have any facts to indicate the school 4 MR. PRIEBE: Object as it calls for 5 district did? 5 the state of mind of another. You can 6 A. I can't speak to what the school district has 6 answer. 7 or doesn't have. 7 THE WITNESS: I think that 8 Q. Let's look at Exhibit 2, which is your everybody on that list right now on this 9 supplemental answers to our interrogatories. 9 day knows that this kid has all those 10 Could you turn to page three? In Exhibit 1, 10 qualities. .11 you answered this interrogatory whatever way 11 BY MR. ROCHEPORD: 12 you answered it, true? 12 Q. Today. 13 A. In Exhibit 1? Okay. 13 A. I'm not sure if anybody had any before. I 14 Q. We went through that earlier in the 14 was not privy to it. 1 still could not 15 deposition, true? 15 identify this kid. I have no recollection of 16 A. Which one? 16 being beat. All I know is the outcome. What 17 Q. lnterrogatory Number 5. 17 page are you on, Larry? 1a A. Okay. Not lnterrogatory 1. 18 Q. Page four of Exhibit 2. 19 Q. That?s Exhibit Exhibit 1. Okay. 20 went through that earlier, correct? 20 Q. Go ahead and look at page four. Is there 21 A. Correct. 21 anybody there who to y0ur knowled knew of 22 Q. You mentioned at page three, Exhibit 2 a 22 assaultive behavior on the part 0% 23 number of policies including but not limited 23 before your December 4th assault? 24 to responses and level of behavior violations 24 A. I'm not sure that any one of them would have 25 and so forth. What policies do you say in 25 that information. Maybe some of them do. I CONFIDENTIAL Page 206 Page 208 1 layperson's terms that my clients violated? 1 do not know. 2 A. Supervision. Their supervision of how 2 Q. Who prepared that list of people, you or 3 quickly behavioral incidents are put into the 3 someone else? 4 computer, that the teachers, you're front 4 A. That was me. 5 line in the battle, need up?to-date 5 Q. Why is Chief Axtell listed? 6 information of student behavior and possible 6 A. In my opinion, I think that the relationship 7 threats to their own well-being. 7 between the St. Paul Police Department, the a Q. Are on aware of some information about 8 community, the students in all our high 9 Khmer didn't get put into a 9 schools needs to be a positive one, not a 10 computer, wasn't recorded somewhere such that 10 negative one. 11 it would have prevented the assault on you? 11 1 think that we need --1 think that our 12 A. Whether or not it could have prevented the 12 SRO that we had prior to Of?cer Atorc had an 13 assault on me I can't predict, but I think 13 excellent, excellent relationship with kids, 14 not having the information if it was there, 14 and I think that if Todd can speak to the 15 or having knowledge of a student who could 15 positive aspects, because we need - We need 16 exhibit violent behavior towards a teacher, 16 to have SRO's in the building and we need the 17 if the knowledge is there, teachers should be 17 district to not run from that but to embrace 18 informed of somebody's past. Not that that?s 18 it. 19 a direct indicator that they?re going to hurt to Q. You're talking about policy, though, school 20 somebody else, but so you can at least have 20 policy, right? 21 the knowledge. 21 A. I'm talking about the fact that it's a 22 Q. There are on page four a list of 34 names, 22 supportive relationship between the two 23 and then on page ?ve, you list members of 23 instead of kind of trying to distance 24 the Safety Committee, the PPC and other 24 yourself from the guys who you call when you 25 employees of the district. Do any of those 25 need help, you know? You call the police Herbert L. Peterson Associates 952-543-6910 (52) Pages 205 - 208 mmimmamumm madame) JOHN EKBLAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 615, ET AL. October 24, 2016 CONFIDENTIAL Page 209 CONFIDENTIAL Page 211 1 when you need help. You don?t say, well, 1 know. I met with John Choi and talked to him 2 maybe we don't need in the building. 2 about the committee working to try to make a 3 As a member of the PPC, as a member of the 3 safer environment after I was heat, and I 4 Safety Team, as a teacher in the St. Paul 4 talked to a woman, and I do not remember her 5 schools, I know that you need police in the 5 name, but she's part of that committee that 6 building. - 6 was formed to try to discuss the 20 plus 7 Q. What you're talking, though, the police or 7 assaults of students -- of student upon 8 SRO's and the children or students in the a teacher reported violence in Ramsey County. 9 building, you're talking about what would be 9 Q. Sol didn't hear in your answer anywhere that 10 good policy for all involved? 10 Mr. Choi is aware of facts that would 11 A. With Todd, yes. 11 indicate ?was a known assailant 12 Q. And that may or may not prevent an assault; 12 and was going to attack you before it 13 is that fair? 13 actually occurred; is that fair? 14 A. I think that having a uniformed of?cer in 10 A. I do not know what information the district 15 the building is a deterrent. 15 supplied to him or to what degree that 1.6 Q. Are you saying that if there had been a 16 information was supplied to him. Upon 1'2 uniformed of?cer in the lunchroom on 1? request, he was doing press conferences with 18 December 4th, you would not have been 18 Superintendent Silva about school climate. 19 assaulted? 19 Q. The others listed there, I'm not going to go 20 A. If he would been standing there before me, I 20 through all 37, is there anybody there to 21 don't think he would have been assaulted. I 21 your knowledge who has personal knowledge of 22 know that I was there and I did get 22 this assault and how it could have been 23 assaulted. 23 prevented? 24 Q. You're saying whoever assaulted you, 24 A. In a broad-brushed how this thing could have 25 _would not assault a police 25 been prevented? CONFIDENTIAL Page 210 Page 212 1 officer? 1 Q. Sure. 2 A. Ican't speak to who he would assault or not 2 A. I mean, the way you asked me the question was 3 assault. I know that the police of?cers 3 a pretty broad brush. How do you prevent it? 4 across this country are being targeted. 4 I know it happened. [know it had nothing to 5 Q. Okay. You also mention a number of SRO's, 5 do with my job. How can you prevent it? 6 three and four in there. Do they have any 6 Deterrents, better accountability for student 7 facts or information abou_ 7 behavior, not brushing it off for an a assault of you, to your knowledge? a achievement gap issue, being consistent, ?rm 9 A. Dustin Atore, number fourand fair. 10 duty at Central on 12/04/15. Bill Kraus was 10 Q. Sir, the St. Paul Central High School could I11 our SRO before that and was subsequently 11 have been surrounded by the National Guard on ?12 moved back into the building after my thing 12 December 4th, could have had metal detectors 13 went down. Bill was there. They moved him 13 you had to go through on December 4th before 14 over to Como. After the Como riot, moved 14 you got in the lunchroom and you could have 15 Atore to Central. I got beat up. I don't 15 had a handful of St. Paul SRO 1 6 know what happened to Of?cer Atore, but Bill 16 yourself and other teachers 8.115% 17 came back. 17 and his cohorts may still have argued; is 18 Q. Sir, the first four people there, John Choi 18 that fair? 19 and the pol ice people or SRO people, do they 19 A. I don?t know. 20 have any facts or information, to your 20 Q. And they still could have fought and you 21 knowledge, of something that was done or 21 would have reacted and tried to break up the 22 could have been done to prevent your assault? 22 ?ght and maybe got assaulted; is that fair, 23 A. I met with John Choi and John Choi has the 23 or not? 24 information that was supplied to him, factual 24 A. Idon?t know. 25 knowledge that was supplied to him. I don't 25 Q. We do know that not a single person listed in Herbert L. Peterson Associates {53) Pages 209 - 212 952-543-6910 101330- Writil?b JOHN EKB LAD vs. CONFIDENTIAL JOHN EKBLAD INDEPENDENT SCHOOL DISTRICT 625, ET AL. October 24, 2016 CONFIDENTIAL Page 21 a CONFIDENTIAL Page 215 1 your Exhibit 1 or 2 had a factual basis to 1 you. Is 18 a six?page exhibit? 2 say they knew you were going to get assaulted 2 A. Six pages. 3 on December 4th before its occurrence? 3 Q. Is it six? 4 MR. PRIEBE: Object to the form of 4 A. Six. 5 the question. It calls for the state of 5 Q. And the ?rst page appears to be a check from 6 mind of another. us Mr. Rocheford 6 CCMSI on behalf of St. Paul Public Schools; 7 testifying as to what other people know is that right? a or what we absolutely know from this a A. Yes. 9 document and we don't. You can answer. 9 Q. it's payable to you? 10 BY MR. 10 A. Yes, it is. 11 Q. I'm asking for, from your Answers to 11 Q. And then it also has a back side with your 12 lnterrogatories and what you're telling us, 12 signature on it; is that right? 13 you don't know of anybody who knet 13 A. Yep. 14 was going to assault you before it occurr 14 Q. And was that a workers' compensation check 15 A. Once again, there might have be somebody who 15 you received and cashed? 16 knows, but 1 know that I did not feel that 16 A. Yes. 17 getting my -- all my - all this had anything 17 Q. And then the second page of Exhibit l8 - 18 to do with my job. 18 MR. ROCHEFORD: Tom, maybe it would 19 Q. Sir, unless you're in boxing or some sort 19 be easier. Can you just write in the 20 of -- 20 lower right-hand corner one, two, three, 21 A. Obviously, [didn't do well at it that day. 21 four, ?ve, six? It would be quicker, I 22 Q. Well, no. 22 think, if you could do that. 23 A. Larry -- 23 MR. Since you just got 24 Q. Here -- 24 these on Friday, Mr. Rocheford, these 25 A. -- come on. 25 have not been produced yet? CONFIDENTIAL Page 214 Page 216 1 Q. You're saying being assaulted and getting a 1 MR. ROCHEFORD: Correct. 2 brain injury or other injuries is not part of 2 MR. PRIEBE: I assume that those 3 a job. I'm not aware of anybody having that 3 bank account numbers are not my clients? 4 as part oftheirjob, are you? 4 If they are, then we're going to have 5 A. There?s a lot of guys in the military that 5 some issues. 6 end up that way. And girls. 6 THE WITNESS: That's bad. That is 7 (Exhibit Number 23 was marked 7 mine. 8 and later withdrawn.) 8 MR. ROCHEFORD: We're going to seal 9 BY MR. ROCHEFORD: 9 the whole transcript. I don't know - 10 Q. I'm showing you what's been marked as 10 THE WITNESS: I know that 29107001, 11 Exhibit 23. Have you seen that document 11 that's mine. 12 before? 12 MR. PRIEBE: If we couldjust go 13 A. Not this piece of paper, but the checks, yes. 13 off the record real quick. 14 Q. Let me hold on here a second. Would you 14 (Whercupon, a discussion was 15 check to see if Exhibit 23 is identical to 15 had off the record.) 16 Exhibit 18 there, because if it is, I'm just 15 BY MR. ROCHEFORD: 17 going to go with 18. 17 Q. Looking at Exhibit 18, in the lower 18 MR. PRIEBE: Yep. 1e right-hand corner, there are numbers one 19 BY MR. ROCHEFORD: 19 through six; is that right? 20 Q. I?m going to withdraw Exhibit 23 and show you 20 A. Yes, there are. 21 what?s been marked as Exhibit 18. 1 just got 21 Q. Okay. And all of the checks that are 22 these, 1 think, Monday. No, not Monday. 22 contained in Exhibit 18 hear your signature 23 Friday. Today is Monday. 23 as well? 24 A. Do you want this back? 24 A. Yes, they do. 25 Q. Why don't you keep Exhibit 18 in front of 25 Q. In other words, you cashed all the checks you MinJI?SeripN?) Herbert L. 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