Case 2:11-cv-04855-WJM-MF Document 59-11 Filed 07/13/12 Page 104 of 152 PageID: 690 Page 311 1 A. Q. Yes. Do you know of any public announcement Are you aware of any? and whether 2 3 4 5 6 7 8 about that potential in 2010? A. Well, certainly not from us, or not Essex County had announced their discussions with ICE, that's certainly possible. Okay. But as you sit here today, you're Q. not sure? A. 9 No. MR. O'CONNOR: Now, the next exhibit 10 11 will be 53. (Exhibit Clancy-53, E-mail string Bates No. CEC--0121633-0121634 was received and marked for identification.) (Witness reviews document.) 12 13 14 15 16 17 Q. Clancy-53 is November 7, '09 e-mail from you to Miss Mathias, and she was asking for a review of background information to be used in the offering memorandum? A. Right. Okay. And with respect to Mr. 18 19 20 21 22 23 24 25 Q. Palatucci, it said in the offering memorandum he was a member and ultimately a partner at Dughi, Hewit & Palatucci serving in lobbying and general counsel capabilities (sic) thereafter. Case 2:11-cv-04855-WJM-MF Document 59-11 Filed 07/13/12 Page 105 of 152 PageID: 691 Page 312 1 2 3 4 5 6 7 And then you had asked her to consider focusing on Bill's government service gndlobbying efforts and the fact that he had ju~t been named chairman of the inaugural festivities :for Governor-elect Christie? A. Q." Yes. And to suggest that Christie was his 8 9 former law partner? A. Q. I don't see that. Well, look at the last sen'tence,"for 10 11 12 13 Governor-elect Christie, his former law partner." A. Q. law partner? A. Yes. And so you wanted to play that up? MS. WOOD: A. Correct. Was he, in fact, Mr. Palatucci's former 14 15 16 Q. 17 18 19 20 21 22 Object to the form. I think it's suggesting missing~ Well, again, that there was something Q. Well, you wanted to use it; right? MS. WOOD: Object to form. A, Q. ! I wanted her to include it. Yeah. And that's something you wanted know,~that 23 24 the potential investors to you had a guy 25 on the inside that knew the incoming governor; Case 2:11-cv-04855-WJM-MF Document 59-11 Filed 07/13/12 Page 106 of 152 PageID: 692 Page 313 1 2 correct? MS. WOOD: Objec?tion to form. an 3 A. Yeah, I ~hinkth.atfs 4 5 over-characterization-of it. Q. sir? A. that. Q. Well, why else would you want to add it, 6 7 Because I think he would be proud of 8 9 Oh, okay. Isn't Xt true that throughout 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2010 you discussed with upper management at CEC the potential contract with Essex County and the revenues, and how you '-c'ould use that to negotiate the best refinancing deal possible? A. Again, E~sex County, we had an existing contract with Essex County that we have had, I -tonight I will be, you- know, hopefully at a freeholder meeting where they will approve a new five-year contract. end of that. So we were in the fourth year of a five-year contract, one of a hundred contracts, and we would have been discussing, I would think, So we're at the absolute last anything -- any of them that would have perceived by me to be relevant, or others to be perceived as relevant or important. 24 25