Page 1
CAUSE NO. C-0373-17-E
HIDALGO COUNTY DRAINAGE § IN THE DISTRICT COURT OF
DISTRICT NO. 1,
§
§
Plaintiff,
§ HIDALGO COUNTY, TEXAS
§
VS.
§
§
INTEG CORPORATION, ET
§ 275TH JUDICIAL DISTRICT
AL.,
§
§
Defendants.
§

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ORAL AND VIDEOTAPED DEPOSITION OF GODFREY GARZA, JR.
JANUARY 24, 2018
VOLUME 1 OF 1

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ORAL AND VIDEOTAPED DEPOSITION OF GODFREY GARZA,
JR., produced as a witness at the instance of the
Plaintiff and duly sworn, was taken in the above styled
and numbered cause on Wednesday, January 24, 2018, from
10:11 a.m. to 3:26 p.m., before Tamara Chapman, CSR, RPR,
CCR (LA) in and for the State of Texas, reported by
computerized stenotype machine, at the offices of Shaw
Cowart, LLP, 1609 Shoal Creek Boulevard, Austin, Texas,
pursuant to the Texas Rules of Civil Procedure and the
provisions stated on the record herein.

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Job No. 35973

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APPEARANCES
REPRESENTING PLAINTIFF:
Michael J. Blanchard
Michael Cowen
COWEN MASK BLANCHARD
6243 IH 10 West, Suite 801
San Antonio, Texas 78201
210-941-1301
mike@cmbtrial.com
Michael@cmbtrial.com
REPRESENTING DEFENDANT:
Ethan L. Shaw
SHAW COWART, LLP
1609 Shoal Creek Boulevard, Suite 100
Austin, Texas 78701
877-303-0383
elshaw@shawcowart.com
REPRESENTING DEFENDANT:
John W. Newton, III
ROACH & NEWTON, L.L.P.
One Westchase Center
10777 Westheimer Road, Suite 212
Houston, Texas 77042
713-652-2031
jnewton@roachnewton.com
ALSO PRESENT:
Jeremy Garrett, Videographer

APPEARANCES................................ 2
GODFREY GARZA, JR.
EXAMINATION
By Mr. Cowen........................... 4
By Mr. Newton.......................... 150
By Mr. Cowen........................... 154

EXHIBITS
NO.
DESCRIPTION
PAGE
Exhibit 1 Integ Corporate Documents
18
Exhibit 5 2/6/07 Integ - HCDD1
Agreement
50
Exhibit 6 2/6/07 Transcribed Minutes 43
Exhibit 7 4/14/08 Integ Invoice
62
Exhibit 21 Agenda Items
140
Exhibit 29 GG Final Memorandum re
Shredded Docs
108
Exhibit 30 GG Memo to Claudette
109
Exhibit 39 Federal Financial
Assistance Award
121
Exhibit 41 GG E-mail
122
Exhibit 42 GG E-mail
125
Exhibit 44 2013 Related Party
126
Exhibit 45 2012 Related Party
126
Exhibit 46 2011 SAS 99 Fraud
Questions
126
Exhibit 47 2012 SAS 99 Fraud
Questions
126
Exhibit 48 2013 SAS 99 Fraud
Questions
126
Exhibit 49 2007 SAS 99 Fraud
Questions
126
Exhibit 50 2007 SAS 99 Fraud
Questions
126

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INDEX

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THE VIDEOGRAPHER: It is January 24th, 2018,
10:11 a.m., and we are on the record.
(Discussion off the written record.)
MR. SHAW: Let me say one thing before we
get started, Godfrey Garza, Jr. had a subdural hematoma
back in 2015. He's fine. He certainly can testify. We
will probably need to take a break about every hour or so
just to make sure. There is a tendency -- he does have a
tendency, as the day may wears on and he gets tired, it
may start affecting his speech in some particular way. I
just wanted to alert you to that. We don't anticipate it
happening, but I wanted to say, just in case it does.
Okay?
MR. COWEN: Any time you need a break, just
take a break.
MR. SHAW: Yeah. We'll do it about every
hour or so.
GODFREY GARZA, JR.,
having been first duly sworn, testified as follows:
EXAMINATION
BY MR. COWEN:
Q. What is your name?
A. Godfrey Garza, Jr.
Q. Mr. Garza, how are you currently employed?
A. I work for Integ.

1 (Pages 1 to 4)

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Q. Since you have parted ways with the Hidalgo
County Drainage District, have you been employed with
anyone other than Integ?
A. GG Consulting.
Q. Does Integ currently have any customers?
A. No, sir.
Q. So what are you doing being employed for Integ
right now?
A. Keeping up with pending litigations going on.
Q. Anything else?
A. Keeping track of income that comes in from rental
properties.
Q. Okay. Does Integ own rental properties?
A. Yes, sir.
Q. Give me your educational background.
A. I graduated from high school, McAllen High, got
my applied science degree while I was in the military,
went to college for about a year.
Q. What was your applied science degree in?
A. It was just applied science in -- applied
science.
Q. Was that an associate's or a bachelor's?
A. It was just called applied science.
Q. Okay. So it's not a bachelor's degree?
A. No, sir.

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Q. Where did you go to college?
A. Pan American University.
Q. Did you graduate?
A. No, sir.
Q. What did you study there?
A. Basics.
Q. What was the first job you had after you stopped
going to Pan Am?
A. I worked for Melden & Hunt Engineering.
Q. And from what years to what years did you work
for Melden & Hunt?
A. I would say '79 to '85, best recollection.
Q. What did you do for Melden & Hunt?
A. Started off as a draftsman, then worked my way up
as a designer, project manager.
Q. What did you do as a draftsman there?
A. Basically designed the projects based on the
direction from the engineer, guidance from the engineer.
Q. What types of projects?
A. Subdivisions, water lines, place water plants,
water plants, storm sewers, drainage.
Q. Can you name any drainage projects you worked on?
A. The major project was Hidalgo County drainage
projects. North Main drains, South Main drains, master
drain system.

Q. And then as a designer what did you do?
A. Basically design the projects.
Q. And what does that entail?
A. Providing cross sections, drawing the plans,
doing quantity takeoffs, designing the storm sewer lines,
placing the -- the lines, assisting in preparation of
specs.
Q. And then when did you become a project manager at
Melden & Hunt?
A. About two years after working there.
Q. So around 1981?
A. More or less.
Q. Did you stay a project manager until you left in
1985?
A. Yes, sir.
Q. What were your job duties as a project manager at
Melden & Hunt?
A. Besides designing, I would coordinate with the
actual construction of the projects. I would meet with
clients, try to generate work. Coordinate the survey
crews, make sure work was being done appropriately, make
sure work was scheduled properly.
Q. What do you mean by "coordinated with actual
construction"?
A. Assisted in receiving the bids, preparing the

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plans and specs, went out with a field crew to make sure
the construction was done properly, make sure it was being
complied with the plans that were being designed, they
were meeting the guidelines that were laid out.
Q. And what did you have to do to coordinate with
survey crews?
A. Basically schedule the survey crews, make sure
the crews went out to the proper site, research, got the
proper documentation to give to the crews to go out,
receive the information the crews brought back in, make
sure all the information was properly laid out in the
books, the field books, so they could be handed down to
the draftsman, so the draftsmen could draw out the
information that was brought in by the field crew.
Q. And what did you do to make sure that work was
scheduled properly?
A. Make sure that the crews got out on time, make
sure the crews have the information they needed, answered
any particular question they might have, coordinate that
with the -- the surveyor that we had in-house. If they
had any specific questions they might have regarding
information they found out in the field.
Q. What are some projects that you served as project
manager on for Melden & Hunt?
A. Numerous subdivisions. Again, a lot of the

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drainage projects, if not all of the drainage projects
they were doing for the District, the Drainage District.
Projects over in the city of Santa Rosa, projects in
Edinburg, projects in Pharr.
Q. What are some of the drainage projects you worked
on?
A. Main floodwater channel, west main drain,
Pharr/San Juan/Alamo drain, master drainage -- excuse me,
main floodwater channel Phase 1, Phase 2, Phase 3,
Phase 4, north main drain, south main drain, Mission
lateral.
Q. Would the main floodwater channel, what was your
involvement while you were with Melden & Hunt? What did
you do?
A. Basically, the project manager.
Q. And what did you do as project manager for the
main floodwater channel?
A. Basically, coordinated with the area work, the
surveyors, the draftsmen, the engineer, the contractor,
the -- the Drainage District itself.
Q. How often did you have to go out to the jobsite?
A. Probably at least once or twice a week.
Q. On all these projects, did you have to go out at
least once or twice a week when you were project manager?
A. When they were under construction.

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Q. Was Melden & Hunt an engineering firm?
A. Yes.
Q. Were there licensed engineers there?
A. Yes.
Q. After you left Melden & Hunt, what was your next
employment?
A. Phase V Engineering.
Q. What was Phase V Engineering?
A. Civil engineering firm.
Q. What did you do there?
A. I became a partner with the firm and basically
did similar work that I was doing at Melden & Hunt.
Q. What do you mean by "similar work"?
A. Project manager, design work, coordinating survey
crews, coordinating with the engineer, going out in the
field, managing projects.
Q. And how often would you actually, during the
construction phase of the project, have to go out in the
field and observe the construction in order to properly
management it?
A. It depends on how much work was being done.
Usually twice a week, I would go out.
Q. And you were a partner in an engineering firm
without being an engineer?
A. Uh-huh.

Q. Is that a "yes"?
A. Yes, sir.
Q. How long were you at Phase V Engineering?
A. About ten years.
Q. Who else was involved with Phase V Engineering as
owners or partners?
A. Mr. Samuel H. Faris.
Q. And who was he?
A. He was a -- the engineer and the surveyor for the
firm.
And the other partner was Jesus Garza.
Q. And who is Jesus Garza?
A. Jesus Garza was a surveyor.
Q. Any relation between you -A. No, sir.
Q. -- and Jesus Garza?
And do you have a brother that worked at Phase V
Engineering at any point?
A. Uh-huh.
MR. SHAW: Is that a "yes"?
A. Yes.
Q. (BY MR. COWEN) Who was that?
A. Jaime Garza.
Q. What did Jaime Garza do there?
A. He basically worked out in the field as a crew

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chief.
Q. Doing what?
A. Managing a crew.
Q. What kind of crew?
A. Survey crew.
Q. Is Mr. Jaime Garza a licensed surveyor?
A. No, sir.
Q. Why did you cease to work with Phase V
Engineering?
A. The Drainage District hired me to go work.
Q. And what was your initial -- when did you go work
for the Drainage District?
A. Sometime in '95, '96.
Q. What was your initial position?
A. District manager.
Q. During the times that you considered yourself an
employee, were you always a district manager?
A. Yes, sir.
Q. And what were your job duties when you were
employed as district manager?
A. Manage the employees of the District, make sure
that the District was operating and functioning properly,
make sure that the system was operating properly.
Q. And were you paid a salary at that time?
A. Yes, sir.

3 (Pages 9 to 12)

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Q. And what was your initial salary?
A. I don't recall.
Q. How long did you remain in a position where you
considered yourself an employee of the District?
A. Until sometime in 2000.
Q. What happened in 2000?
A. I went under contract with Integ as a district
manager duties.
Q. Didn't your duties change at all when you went
from being someone paid as an employee to someone paid
through Integ?
A. Some of the duties changed. Not much. Most of
the change was regarding the amount of time that I needed
to spend there.
Q. And what -- tell me about that.
A. I was no longer basically required to be there 40
hours.
Q. Why not?
A. I was only required to spend as much time as was
needed to fulfill the requirements of my contract.
Q. I want to take a step back and ask you some
questions about Integ. Is that okay?
A. Yes.
Q. Do you remember when Integ was formed?
A. No, sir, not exactly.

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Q. Okay. If the Texas Secretary of State records
show that it was formed around June 20th of 1991, would
you disagree with that?
A. If that's what the records indicate, sir.
Q. When Integ was originally formed, who were the
shareholders?
A. Myself, Godfrey Garza, Jr., and Jesus Garza.
Q. Is that the same Jesus Garza that you worked with
at Phase V Engineering?
A. Yes, sir.
Q. Were there any other shareholders when it was
originally formed?
A. No, sir.
Q. Any other officers or directors when it was
originally formed?
A. Not that I recall.
Q. What did Integ do when it was originally formed?
A. Integ was being -- was formed to provide
construction management services and also to be a real
estate management company.
Q. How long was Mr. Jesus Garza a shareholder in
Integ?
A. I think -- I don't recall exactly.
Q. At some point in time, Mr. Jesus Garza ceased to
be a shareholder in Integ. Is that correct?

A. He was never -- yes, sir. I'm sorry. Yes, sir.
Q. You were about to say he was never a what?
A. I was about to say he was never a shareholder in
Integ, but, yes, he was a shareholder in Integ.
Q. And then at some point, you acquired his shares?
A. Yes, sir.
Q. How did that happen?
A. Just bought his shares out.
Q. When did you buy his shares out?
A. I don't recall the date.
Q. How much did you pay for them?
A. I don't recall the amount.
Q. Do you have an approximation?
A. No, sir.
Q. Was it more than a million dollars?
A. I don't recall the amount, sir.
Q. Okay. Well, did you have a million dollars back
then to pay him?
A. No.
Q. Okay. Did you have a hundred thousand dollars to
pay him?
A. No, sir.
Q. So it would have been less than a hundred
thousand. Did you have ten thousand dollars to pay him?
A. No, sir.

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Q. So it was not a large amount of money you paid?
A. No, sir.
Q. You -- did you pay him something?
A. I don't recall, sir.
Q. You do not recall whether you paid him any money
or not?
A. No, sir, I don't.
Q. Do you have any records that would show that?
A. Only what is shown in the corporate books.
Q. And do you know approximately when Mr. Jesus
Garza was no longer a shareholder in Integ?
A. It would have to show in the corporate books. I
don't recall.
Q. Was it before or after you went to work for the
Drainage District?
A. Repeat the question, please.
Q. Was it before or after you went to work for the
Drainage District?
A. What was the question?
Q. Okay. Did Mr. Jesus Garza cease to be a
shareholder in Integ either before or after you went to
work for the Drainage District?
A. Before.
Q. What construction management projects did Integ
do prior to the year 2000?

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A. They built some apartments, plus they did some
management work in Mexico.
Q. What apartments did it build?
A. It built a fourplex in Mission and a fourplex in
Edinburg.
Q. Who -- who owned those fourplexes?
A. Integ.
Q. So both the fourplexes that it built, it built
for itself?
A. Uh-huh.
Q. Is that a "yes"?
A. Yes, sir.
Q. And what was the management work that Integ did
in Mexico prior to 2000?
A. Basically, they did some management work for
Emerson Electric on a warehouse.
Q. What did -- what did Integ do for Emerson
Electric on the warehouse?
A. They provided the management, the construction
management and the construction component.
Q. Was that in Reynosa or where in Mexico?
A. Reynosa.
Q. And what did -- did Integ have any employees,
other than you, at the time it did that management work
for Emerson Electric?

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A. Just Jesus Garza and myself.
Q. Okay. So Jesus Garza was still there when that
happened?
A. Yes, sir.
Q. And what -- what work did you and Mr. Jesus Garza
do with respect to the Emerson Electric project?
A. Project management.
Q. And what did that entail?
A. Supervising the construction of the project,
making sure it was being built properly, making sure that
the people did the project regarding the construction of
the cement, the installation of the cement, the walls went
up properly. Construction management.
Q. How often would you have to go over there during
construction?
A. Maybe three times a week.
Q. And Mr. Jesus Garza, how often would he have to
go?
A. We would alternate. Either him or myself would
go over there.
Q. So between the two of you, was it three times a
week or three times a week each?
A. I couldn't recall.
Q. Could you look at Exhibit 1 in that notebook.
And there's a page that has the Bates number HCDD-1647.

MR. SHAW: 1647?
MR. COWEN: Uh-huh.
MR. SHAW: Okay.
Look at the entire document -THE WITNESS: Okay.
MR. SHAW: -- Exhibit 1. And then he wants
you to focus on 1647.
THE WITNESS: Okay.
Q. (BY MR. COWEN) And if you need any time to read
over it before I ask any questions, you're welcome to take
all the time you need.
MR. SHAW: Just let him know what it is.
A. (Pause.)
Okay. On 47. Yes, sir.
Q. (BY MR. COWEN) Is that the minutes of a special
meeting of Integ Corporation held on June 1st, 1992?
A. Yes, sir.
Q. And is that the meeting where Mr. Jesus Garza
advised that he no longer wanted to be a shareholder in
the company?
A. Yes, sir.
(Discussion off the written record.)
A. Yes, sir.
Q. (BY MR. COWEN) And it says that Mr. Jesus Garza
sold the shares back to the corporation for $10?

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A. Yes, sir.
Q. Is that accurate?
A. If that's what the meeting notes say, sir.
Q. And was the management work done for Emerson
Electric prior to this June 1st, 1992, meeting?
A. I don't know the exact date when the Emerson work
was done, sir.
Q. Did Mr. Jesus Garza continue to do any work with
Integ after he gave up his shares?
A. No, sir.
Q. From 1992 to the present, have there been any
other shareholders in Integ?
A. No, sir.
Q. Are you married?
A. Yes, sir.
Q. To whom are you married?
A. To Annie Garza.
Q. How long have you been married to Annie Garza?
A. 44 years.
Q. And never divorced?
A. No, sir.
Q. So you were married to Annie Garza at the time
you formed Integ. Correct?
A. Yes, sir.
Q. You were married to Annie Garza at the time that

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your sons transferred their shares in Valley Data
Collections to your wife?
A. Yes, sir.
Q. Do you have any kind of written agreement with
your wife setting out your shares in Integ as separate
property?
A. We've had understanding that whatever companies
she's had, I've had no interest in, and whatever companies
I've had, she's had no interest in.
Q. Anything in writing that reflects that
understanding?
A. We've had some documents drawn up in the past
when she's had her company where I had no interest in her
companies.
Q. Okay. What documents were drawn up that says
that you have no interest in Valley Data?
A. None that I recall.
Q. Okay. And is there any written document showing
that she has no community property interest in your shares
in Integ?
A. None that I recall.
Q. Now, you said you and your wife had an
understanding that you each had no interest in the other's
companies?
A. Uh-huh.

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MR. SHAW: Is that "yes"?
Q. (BY MR. COWEN) Is that a "yes"?
A. Yes.
Q. Tell me about how you reached that understanding?
A. Basically, she would operate her company and I
would operate my company.
Q. And when did you discuss that understanding?
A. Since back in the -- I guess in 2000s when she
opened up her company on an adult daycare center that she
was operating a corporation, Heavenly Days Corporation,
that she formed and licensed and operated, that I had no
interest in and she had no interest in any of my
companies, and I sold and did what I needed to do and she
never got involved in it.
Q. Did you ever have any agreements that if you
divorced, that any interest in your companies would not
count as community property for division of the marital
estate?
A. No, sir. We did not, but we had an understanding
that as far as the corporations were, in doing everyday
business, no.
Q. For personal banking, did you have a joint
checking account?
A. Yes.
Q. Did you have -- maintain separate personal

checking accounts?
A. No.
Q. And from all times from 2000 to the present, you
and your wife had a joint checking account?
A. Yes.
Q. And at all times from 2000 to present, you and
your wife did not have separate personal checking
accounts?
A. I do not know if my wife had a different checking
account on her own.
Q. You did not have a personal checking account that
your wife was not a signatory on at any time from the year
2000 to the present -A. No.
Q. -- isn't that true?
A. No.
Q. Okay. Let me -MR. SHAW: Is what he's saying correct?
THE WITNESS: Yes.
MR. COWEN: Let me re-ask the question.
Q. (BY MR. COWEN) Did you have a separate personal
checking account on which your wife could not sign at any
time from the year 2000 to the present?
A. No.
MR. SHAW: You need to add something,

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Godfrey?
THE WITNESS: Yes, I do.
A. I -- I don't recall if -- I'd -- I'd -- I'd have
to ask Annie on one account.
MR. SHAW: Okay.
Q. (BY MR. COWEN) Do you want to take a break and
ask her?
A. Yes, sir.
MR. COWEN: Okay. We'll take a break.
THE VIDEOGRAPHER: It is 10:40, and we're
off the record.
(Break.)
THE VIDEOGRAPHER: It is 10:52. We're back
on the record.
MR. SHAW: You want to -- you want to
clarify something?
THE WITNESS: Yes, sir.
A. I want to clarify two items. One of the items is
that basically when we were doing work -- or when Integ
was doing -- or when Phase V was doing work in Mexico, it
was under -- Phase V was not under Integ, so the work
being done on the Macillas was under Phase V, not under
Integ.
And, secondly, that I never had any accounts,
bank accounts on my own. As far as Annie, you'll have to

6 (Pages 21 to 24)

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ask Annie as far as any personal checking accounts.
Q. (BY MR. COWEN) Did you ever receive any money
from Integ while you worked for Integ?
A. Yes.
Q. What would you do -- would you receive it in the
form of checks or cash or both?
A. Both.
Q. When you got checks from Integ, what would you do
with them?
A. I would deposit them in my personal account.
Q. And is that a personal account on which your wife
Annie is also an account owner -A. Yes.
Q. -- holder?
And did you do anything to segregate the money
you received from Integ to make sure your wife didn't have
access to it or spend it?
A. No.
Q. And did your wife ever receive any money from
Valley Data?
A. I would say -- I would have to speculate that she
would receive her payroll checks.
Q. Any distributions or dividends from Valley Data?
A. You would have to ask her.
Q. And do you know where she would deposit her

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payroll checks from Valley Data?
A. I would speculate into our joint checking
account.
Q. Was any of the money you received from Integ used
to pay household bills for you and your wife?
A. I would speculate, yes.
Q. Why are you saying you're speculating?
A. Because I don't usually follow where all the
payments are made. My wife usually makes the payments.
Q. Now, your wife testified in her prior deposition
that she was a signatory on Integ's bank account. Is that
true?
A. Yes, sir.
Q. And your wife actually -- at certain periods of
time actually prepared the checks for signature from Integ
to pay things. Correct?
A. Yes, sir.
Q. And she was also an employee of Integ?
A. Yes, sir.
Q. Were you ever a signatory on any account for
Valley Data?
A. No, sir.
Q. Did you ever have any personal involvement with
the business of Valley Data?
A. No, sir.

Q. I want to go back to Integ and what it did prior
to entering into a contract with the District. So prior
to entering into a contract the District, Integ built two
fourplexes. Correct?
A. Yes, sir.
Q. And then it managed and collected rent for those
two fourplexes?
A. Yes, sir.
Q. Did it do anything else, other than those two
fourplexes, before entering into a contract with the
District?
A. Basically they were the -- did some remodeling
work on the building and that was it.
Q. What building?
A. A building that Integ purchased to turn into an
office building.
Q. Where was that office building?
A. In Mission.
Q. What was the address?
A. 2014.
Q. 2014 what?
A. Highway 83, Mission.
Q. And does Integ still own that building?
A. No, it was sold.
Q. When was it sold?

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A. Eight years ago, ten years ago.
Q. How did the District go from paying you as an
employee to entering into a contract with Integ?
A. Through action of the Board of Directors.
Q. Whose idea was it?
A. It was an idea from the Board of Directors.
Q. So the Board of Directors brought you in and
said, We want you to -- to not be an employee anymore. We
want to hire a corporation you own?
A. Basically it was that or I was leaving.
Q. Okay. So let's back up a little bit. How did
the Board of Directors know you were leaving? Did they
tell you that they were going to fire you unless you
switched to being a contractor?
A. No. Basically I told the Board of Directors that
I wanted to go back into the private sector.
Q. Okay. And when was that?
A. Sometime in 2000.
Q. Why did you want to go back into the private
sector?
A. The economy was picking up, and I felt I could
make more money on the private sector.
Q. And so who did you tell that you wanted to go
into the private sector?
A. My district liaison Board member.

7 (Pages 25 to 28)

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Q. Who was that?
A. Commissioner Oscar Garza, Jr.
Q. What do you mean he was your liaison Board
member?
A. Basically every department at the County has a
liaison, one of the commissioners on the court. That is
who you talk to of any issues you might have, and it's his
responsibility to go and discuss it with the rest of the
commissioners.
Q. Okay. And you ended up, then, entering into a
contract between Integ and the District in 2000?
A. Integ entered into a contract with the District
sometime in 2000.
Q. Okay. Who signed that contract on behalf of
Integ?
A. I did.
Q. And at that time what employees did Integ have?
A. Myself.
Q. Who was the shareholder of Integ at that time?
A. Godfrey Garza, Jr.
Q. You were the only shareholder?
A. Yes, sir.
Q. The only officer?
A. Yes, sir.
Q. The only director?

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A. Yes, sir.
Q. From 2000 to the present has Integ had any other
employees?
A. Just my wife, and sometimes when I would hire
contract laborers to help out.
Q. Okay. So your wife, Annie Garza, was also an
employee?
A. Yes, sir, of Integ.
Q. And you said you hired contract laborers?
A. Uh-huh. If I needed some help to go and work at
the ranch or if I needed some help doing odds and ends,
painting or whatever.
Q. Do you consider those contract laborers to be
employees?
A. No. I just -- laborers.
Q. Did you -- did Integ ever hire any contract
laborers to perform any construction management work?
A. No, sir.
Q. Did Integ ever hire any contract laborers to
perform any work that was being done by Integ on behalf of
the Drainage District?
A. No.
Q. So during the time that Integ was paid millions
of dollars by the District, you and your wife were the
only employees?

A. Yes, sir.
Q. What in the world did you do that was worth
millions of dollars?
MR. SHAW: Objection; form.
A. I managed the project as per my contract
requirements.
Q. (BY MR. COWEN) What do you mean by that?
A. My contract stipulated the job performance that I
needed to do in order for Integ to get paid the fees that
were associated with it.
Q. And what is your interpretation of what that job
performance was required?
A. Basically to provide the construction management
of the services related to the implementation of the
Hidalgo County Drainage District Master Drainage System
Phase II.
Q. But what did you actually do? What work did you
do? You got paid millions of dollars. What work did you
do?
A. I basically prepared the District and its
personnel to gets its system organized to manage the
construction documentation related for the implementation
of the Hidalgo County Drainage -- Master Drainage
Phase II. I made sure that the employees were hired, they
were going to be required to do that in-house.

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I made sure that they knew what they needed to
do. I also made sure that the engineers did the job that
they were required to do. I made sure that the
contractors were doing the work that they were contracted
to do. I went out there and provided the inspection, with
the assistance of the engineers, to make sure that the
project was being done on time. I made sure that all the
compliance was being done according to the contracts. I
made sure that all the documentation was being forwarded.
I made sure that the Commissioner's Court was aware that
everything was being done in compliance. I made sure that
the bills were being sent in properly and being reviewed
properly. I made sure that the auditors were doing their
job of getting things audited. I made sure that the
reports were being completed on time.
Q. And you think that was worth millions of dollars?
MR. SHAW: Objection; form.
A. I made sure that I complied with the work that
was done on the project, and I made sure that I got paid
what was in the contract.
Q. (BY MR. COWEN) Do you believe that you provided
millions of dollars of value to the District?
A. Yes, sir.
Q. You do?
A. Yes, sir.

8 (Pages 29 to 32)

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Q. How many hours a week were you working during the
period of time in which Integ was being paid millions of
dollars to do construction management?
A. I couldn't tell you the amount of hours because
some of the work was being done 24/7.
Q. By you?
A. The contractors were out there 24/7, so it was
not that I was going out there 40 hours a week, or that I
was going out at 8:00 in the morning, or I was going out
at 10:00, or if I was going out on Saturdays or Sundays.
The project was being done at an accelerated time. This
project did not just consist of going out there,
construction, but during a period of almost five years
closeout time.
Q. What I'm asking you, though, is the work that you
did personally, how many hours a week did you personally
spend working during this period of time?
A. I couldn't tell you.
Q. Can you give an estimate?
A. No.
Q. Do you have any idea?
A. No.
Q. You don't know -- what time would you normally
get up in the morning?
A. 7 o'clock.

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Q. Okay. What time would you usually get home at
night?
A. Probably about 9 o'clock.
Q. Okay. Every day?
A. Most of the days.
Q. Okay. And you'd be working that whole time?
A. Yes, sir.
Q. Had you ever had a job that paid a million
dollars a year before?
A. I had a company that generated a million dollars
a year.
Q. Okay. How many employees did that company have?
A. Five, six, eight employees.
Q. Okay. How many -- were you the sole shareholder
of that company?
A. Yes, sir.
Q. Okay. Which company was that?
A. Phase V Engineering.
Q. Okay. And was it a million dollars in profit or
a million dollars in gross revenue?
A. A million dollars in gross revenue.
Q. And what kind of profit would you get from a
million dollars in gross revenue?
A. 40 percent, 45 percent.
Q. Okay. Have you ever had anyone since you've --

since Integ has no longer been contracting with the
District, have you had anyone else offer you a million
dollars or more a year to do any work, you personally?
A. Not with all this pending litigation accusations
I've had.
Q. Has anyone told you if this litigation wasn't
there they'd pay you more than a million dollars a year to
do work for them?
A. I would hate to go and ask somebody.
Q. Okay. But no one's said "Godfrey Garza, you're
such a great, knowledgeable person in construction
management, just get this litigation behind you and we'll
pay you more than a million dollars. You can start as
soon as this is over." Did anyone ever tell you that?
MR. SHAW: Besides Hidalgo County?
MR. COWEN: I said anyone.
A. I would hate to say "yes," for the simple reason
that everybody is so scared of saying anything right now
because of Hidalgo County.
Q. (BY MR. COWEN) Okay. You're not a licensed
professional engineer?
A. No, sir.
Q. You're not a licensed surveyor?
A. No, sir.
MR. SHAW: Let him finish his question,

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Godfrey, so you don't talk over him, please.
THE WITNESS: Yes, sir.
Q. (BY MR. COWEN) Did you do anything to document
the construction management work that Integ did on behalf
of the District?
A. Yes, sir.
Q. What did you do to document the work?
A. There should be files inside the District's
computer system where meetings took place, where reviews
took place, where I attended meetings, where I met with
the contractors, where I met with the engineers, where we
received reports, where I attended Board meetings, where I
attended meetings with the Department of Homeland
Security, where we met with the independent auditors,
where we went into arbitrations or mediations.
Q. From 2000 up to 2006, what did Integ do for the
District?
A. The contract delineated certain management items
that Integ was responsible for doing for the District.
And basically those were the items that I did.
Q. What were those items?
A. I do not have the contract specifically in front
of me to list you item by items, but in general, provided
them as general management of the District, made sure the
District complied with all of the requirements set forth,

9 (Pages 33 to 36)

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as far as maintenance of the District, personnel of the
District. Made sure that people were hired properly, made
sure the budgets were done, made sure the audit reports
were done, made sure the District was maintained properly.
Q. What's the difference between those job duties
and what you were doing when you were an employee of the
District?
A. The duties were basically the same, except for
the time involved on it.
Q. You just didn't have to work as many hours?
A. Yes, sir.
Q. But you got paid more money?
A. The difference was that while I was an employee,
I was covered by insurance, I was covered by retirement, I
was covered by health, I was provided a vehicle, I was
given vacation, I was given workmen's comp, I was given
everything.
When I went under contract, there was no more
retirement, there was no more medical, there was no more
vehicle, there was no more anything. So there was an
increase in salary, but I no longer had any of the
benefits of an employee associated with the District.
So there was a jump in salary, but if you look at
the cost of the salary that I would make prior to going
under contract, and you add that to all of the benefits

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that I lost, you'll probably find out it's almost an
equitable number.
Q. And later the District started paying you a
vehicle allowance to compensate you for the use of a
vehicle?
A. Yes, sir.
Q. And then also started paying a cell phone
allowance?
A. Yes, sir.
Q. Did Integ own any vehicles?
A. Yes, sir.
Q. And did you drive a vehicle owned by Integ?
A. Yes, sir.
Q. Did you drive it only when you were on Integ
company business or were you also allowed to drive it for
personal use?
A. I was allowed to drive it for personal use.
Q. Did your wife, Annie Garza, ever drive a vehicle
owned by Integ?
A. Sometimes.
Q. Which vehicle did she drive that was owned by
Integ?
A. Probably the pickup.
Q. Okay. Is that a pickup that she had for daily
use or was it --

A. Oh, no.
Q. It was just yours and she'd drive it sometimes?
A. Yes, sir.
Q. It was yours and she'd drive it sometimes?
A. Yes, sir.
Q. Now, at some point in time there was a new
contract entered in 2007 that also provided an agreement
where Integ would perform construction management
services?
A. Yes, sir.
Q. And Integ would then get compensation for
construction management services. Correct?
A. Yes, sir.
Q. But Integ did not hire any additional employees
once it started doing the construction management
services, did it?
A. No, sir.
Q. And you were the only one at Integ that ever did
any work that would be considered construction management
services. Correct?
A. Yes, sir.
Q. Whose idea was it to have Integ get paid for
construction management services?
A. I presented the idea to the Board of Directors,
or to the District liaison officer.

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Q. Okay. So you first presented it to whom -which -- who was the -- was that Oscar Garza?
A. Oscar Garza, Jr.
THE REPORTER: Make sure, for your purposes
and mine, so everything's clear -MR. SHAW: Take a half-second step.
THE WITNESS: Yes, sir.
Q. (BY MR. COWEN) At that time what was anticipated
that the Phase II construction project was going to
entail?
A. The Phase II Master Drainage System project
entailed numerous drainage improvements throughout the
county based on numerous presentations that had been done
to the Board of Directors, entailing about $900 million
worth of work that needed to be done within the District,
in which the Board made a decision of doing about
$100 million worth of work and equated that split within
the precincts, and $100 million was delineated out, which
included numerous projects throughout the District.
Q. Was there anywhere where there is a list of those
projects?
A. Yes, sir.
Q. Where would I find that list?
A. There is a report in a presentation that was done
to multiple cities and communities, identifying, one, the

10 (Pages 37 to 40)

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$900 million worth of work, and also the $100 million
worth of drainage improvements.
Q. Now, the 900 million would not be done all in one
phase, would it?
A. No, sir.
Q. The Phase II, at that time, was going to be what
was going to be done with the $100 million bond issue?
A. Yes, sir.
Q. Back at the time that you presented the idea of
Integ doing construction management to the Board, no one
knew that the federal government was going to come in and
do the levy improvement project, did they?
A. The levy improvement project was delineated as an
IBWC project that needed to be done, and it impacted the
Drainage District.
Q. But it was not originally going to be part of the
$100 million bond issue?
A. Yes, sir, it was.
Q. $100 million was going to be spent on the levies?
A. No, sir, a portion of the $100 million was.
Q. Okay. What was going to be done -- what portion
was going to be done with the levies?
A. The most critical part of the levy system around
Mission was scheduled to be improved out of the
$100 million.

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contract with you.
A. Uh-huh.
Q. Was there someone from TEDSI there as well at
that meeting?
A. The audience.
Q. Okay. Did he speak at that meeting?
A. I think Commissioner Garza asked him some
questions.
Q. Why was he there?
A. I don't know why he was there, sir.
Q. He just -- and who was it from TEDSI who was
there?
A. Mr. Mark Lupher.
Q. And Mr. Lupher just happened to say that this was
a good deal for the District?
A. You would have to ask Mr. Lupher that.
Q. You didn't talk to Mr. Lupher about being there
before he got there?
A. No, sir, I did not.
Q. I'd like you to look at Exhibit 6.
MR. SHAW: You can familiarize yourself with
it, and then he'll ask you questions.
MR. COWEN: Yeah. Why don't we go off the
record so you can just read through it.
THE VIDEOGRAPHER: It is 11:18 and we are

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Q. And how much of the 100 million would be spend on
that?
A. They were estimating $10 million.
Q. Any other levy improvements that were part of the
100 million?
A. No, sir.
Q. Now, it's called Phase II. What was Phase I?
A. Phase I was basically the 1976/'78 original
master plan that the District did when it was originally
created.
Q. And were bonds issued for that?
A. There was deferral series of bonds issues done
during the period of '76 through the '90s.
Q. So Phase I, how long did it take to do? How long
were people working on Phase I?
A. 20-some-odd years probably.
Q. And was -- was it the expectation, back in 2007,
that Phase II would take 10 to 20 years?
A. Probably so.
Q. And I've been reading through the transcript of
the -- of a meeting back in December of 2014, where you
were discussing the possible -- I'm sorry. That's the
wrong date.
I was reading the transcript of the meeting where
the Drainage District was talking about doing this

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off the record.
(Break.)
THE VIDEOGRAPHER: It is 11:26. We're back
on the record.
Q. (BY MR. COWEN) So at the time that you were
discussing this contract with the commissioners, what was
being discussed was being paid out of a portion of the
money on $100 million bond issue. Correct?
MR. SHAW: Objection; form.
A. What was being discussed was getting a contract
to include one and a half percentage of the bond issuance
of the Phase II for the construction management of the
project.
Q. (BY MR. COWEN) Well, you said that we'll put out
to the public on the bond issue while anticipating about
40 percent of the bond issuance of $100 million is going
to be land acquisition. Did you say that?
A. Yes, sir.
Q. Okay. And you weren't going to be paid any money
on land acquisition. Correct?
A. Yes.
Q. So you were talking about one and a half percent
on about $60 million at that time?
A. Yes, sir.
Q. Now the -- and then you were talking about this

11 (Pages 41 to 44)

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could take 10 to 20 years?
A. Yes, sir.
Q. And so one and a half percent of $60 million, do
you know how much that is?
A. Not offhand, sir.
Q. Okay. And just because I didn't sleep enough
last night, I'm going to do the math instead of doing it
my head.
MR. NEWTON: One and a half percent is -Q. (BY MR. COWEN) That would be about $900,000.
Does that sound right?
A. Yes, sir.
Q. So for 10 years, that would be about 90,000 a
year?
A. Okay, sir.
Q. And over 20 years, that would be about 45,000 a
year. Does that sound about right?
A. Okay, sir.
Q. During this meeting when you were discussing
the -- being -- the contract back in 2007, was there any
discussion of you being paid on a federal project to do
the border wall?
A. No, sir.
Q. And you said that it's just a coincidence that
your liaison, Mr. -- Commissioner Garza called on the

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representative of TEDSI who happened to be in the audience
that day?
MR. SHAW: Objection; form.
A. Mr. Lupher -- Commissioner Garza is the one that
called on Mr. Mark Lupher. Why, I don't know.
Q. (BY MR. COWEN) That wasn't something that you
and Commissioner Garza and Mr. Lupher had arranged before
the meeting?
A. No, sir.
Q. Had you spoken to Mr. Lupher before the meeting?
A. No, sir.
Q. Now, TEDSI, the company that -- whose
representative spoke up on -- in support of your deal,
they ended up being one of the contractors on these
projects you managed. Correct?
A. Yes, sir.
Q. TEDSI also ended up hiring Valley Data as a
subcontractor. Correct?
A. Yes, sir.
Q. And is it your position that's all just a
coincidence?
A. Yes, sir.
Q. You also represented that there would be checks
and balances. Correct?
A. Yes, sir.

Q. And did the auditor -- an independent auditor
actually audit whether or not Integ had done the work to
get paid?
A. I believe the auditor did his auditing as
required by law.
Q. And what did the auditor audit? What was the
scope on that audit?
A. Whatever they're required to audit.
Q. Do you know?
A. Not specifically, sir.
Q. Isn't it true that auditors typically don't look
to see whether the money was actually earned? They just
look to see if the checks match up with what's in the
accounting system?
A. I don't know.
MR. SHAW: Objection; form.
Q. (BY MR. COWEN) And Lora Briones, what was her
position with the District at that time?
A. She was a financial officer.
Q. Okay. Who did she report to?
A. She reported to -- to the Drainage District Board
of Directors and she was basically under me at the
Drainage District.
Q. Okay. So the person that's supposed to be
providing a check and balance as to payments to your

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company is someone that is supervised by you. Correct?
A. But she also was an employee of the District. So
she had her own fiduciary obligations to the Board of
Directors.
Q. But she also was supervised by you. Correct?
A. Yes, sir.
Q. Did Lora Briones ever question whether or not
Integ should be paid the money it was being paid?
A. Not to me.
Q. Did you ever hear Lora Briones questioning the
money that Integ was being paid?
A. No, sir.
Q. When you were an employee prior to 2000 of the
District, would you agree that you owe the District a
fiduciary duty?
MR. SHAW: Objection; form.
A. I owe the District whatever I'm required to owe
them as an employee.
Q. (BY MR. COWEN) Okay. Given that you continued
being in the same position of trust and confidence in
doing the same work as the District manager after Integ
started getting paid by a contract, wouldn't you have the
same obligations?
MR. SHAW: Objection; form.
A. No, sir. I was basically working for Integ and

12 (Pages 45 to 48)

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Integ was a corporation that was providing a service based
on a contract.
Q. (BY MR. COWEN) Do you think Integ had any duties
of loyalty to the District?
MR. SHAW: Objection; form.
A. I think Integ's responsibilities was laid out in
the contract.
Q. (BY MR. COWEN) So Integ could -- could lie,
cheat, and steal all it wanted as long as it could get
itself paid under the contract. Is that your position?
MR. SHAW: Objection; form.
A. I think Integ's responsibilities is what was laid
in the contract.
Q. (BY MR. COWEN) Okay. So you're denying that you
had any fiduciary duty owed being that you were acting as
the manager of the District at all times?
MR. SHAW: Objection; form.
A. I'm saying that I had the responsibility or Integ
had the responsibility of the items that were delineated
in the contract.
Q. (BY MR. COWEN) Which included managing the
District?
A. I'm responding that whatever was laid out in the
contract for the responsibility of Integ, those were the
obligations that Integ had.

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Q. Well, Integ was responsible for general
administration of the District. Correct?
A. If that's what was delineated in the contract.
Q. Is that correct?
A. If that's what was delineated in the contract.
Q. You don't remember?
A. I'd have to read the contract.
Q. Okay. Well, what -- what is your understanding
of what Integ was supposed to do?
A. Basically, whatever was written in the contract.
Q. Okay. What was that?
A. If I have a look at the contract, I can read the
contract verbatim.
Q. It's in -- it's Exhibit 5. Does that set out
what Integ's responsibilities were?
MR. SHAW: What's the date?
MR. COWEN: That's the February 7th.
MR. SHAW: Okay.
MR. COWEN: I mean February 2007.
A. Would you like for me to read them?
Q. (BY MR. COWEN) Well, I was -- first of all, on
the second page -- on the bottom of the first page going
to the second page, it says, "Subject to the direction of
the Board of Directors of the District, Integ shall
perform the duties of the manager of the District."

Correct?
A. It says under "Agreement and Terms," "in
accordance with the terms and provisions hereof," on the
first page under "Obligations of Integ."
Q. Right. But it says that "Integ shall perform the
duties of the manager of the District." Correct?
A. I believe under Item 1, "Obligations of Integ,"
"Integ agrees to provide the following services to the
District during the term of this Agreement in accordance
with the terms and provisions hereof."
Q. Right. Then 1.1, the heading is "Management."
Correct?
A. Correct.
Q. It says, "Subject to the direction of the Board
of Directors of the District, Integ shall perform the
duties of the manager of the District." Correct?
A. Yes, sir.
Q. And then it lists a bunch of duties that Integ
has to perform. Correct?
A. "Including, but not limited to the following."
Q. Right. And -- and the District didn't hire a new
manager or district director when it entered into
contracts with Integ, did it?
A. The District hired Integ and used -- using
Godfrey Garza, Jr. to provide the services as listed under

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this contract.
Q. And you were the person that provided the
services. Correct?
A. Under Integ Corporation.
Q. But there were no other human beings, besides
you, that performed the services as manager of the
District. Correct?
A. That provided these services as listed in the
contract.
Q. And included "exercising discretion and
judgment." Correct, under Subsection A(10)?
A. It says under A(10), "exercise discretion and
judgment in matters not covered by this Agreement and/or
policies of the District."
Q. A(1), "perform the overall management and
compliance of the programs." Correct?
A. Which item, sir?
Q. A(1). You were to perform overall management and
compliance of the District's programs. Correct?
A. Yes, sir.
Q. You were establishing -- under A(4), establishing
and maintaining "necessary standards of performance" for
the District. Correct?
A. That they "comply with the plans, applicable
laws, and regulations."

13 (Pages 49 to 52)

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Q. But you were establishing and maintaining the
necessary standards of performance. Correct?
A. As long as they complied with those requirements
as laid out there.
Q. And it was your job to "coordinate the
responsibilities and assignments" of the staff. Correct?
A. Yes, sir.
Q. "Recommend policies on organization, finance
programs, personnel, and all other function." Correct?
A. Which item was that?
Q. That is 9.
A. Yes, sir.
Q. Basically, under the contract, you had to do
everything you had to do as an employee and more?
A. And a lot of these basically were "recommend,"
but they still had to be approved by the Board.
Q. But they were the same job duties you had when
you were an employee. Correct?
A. No, sir.
Q. They were more job duties than you -- than you
had as an employee. Correct?
A. Yes, sir.
Q. But all the job duties you had as an employee,
other than showing up 9:00 to 5:00, 40 hours a week, you
still had through Integ?

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A. Yes, sir.
Q. In fact you would even serve and communicate on
the District's behalf with the District's attorney
regarding litigation matters?
A. I was doing that before.
Q. And after?
A. Yes, sir.
Q. And regarding contract matters. Correct?
A. Yes, sir.
Q. So the District entrusted you to have privileged
communications with its attorney. Correct?
A. Yes.
MR. SHAW: Objection; form.
Let me make sure I get -THE WITNESS: Yes, sir, I'm sorry.
MR. SHAW: -- an objection in.
I object to the form of the question.
A. I would discuss with the attorney based on the
direction from the Board of Directors regarding what items
were pertinent to the District, and the attorney would
give us the opinion to comply with whatever the District
needed to comply with.
Q. (BY MR. COWEN) Did the District provide the
computer you used to do the work as the manager or
director?

A. Yes, sir.
Q. Okay. Did you have a District e-mail address?
A. Yes, sir.
Q. And did you use that e-mail account?
A. Yes, sir.
Q. And on your signature line for e-mails, did you
put "Integ" or did you put "Godfrey Garza, director"?
A. I don't recall.
Q. You don't recall?
A. I recall that it was Drainage District manager.
Q. Okay.
A. And I recall the address was HCDD No. 1.
Q. Did the office supplies there in your office at
the District, were those purchased by the District or by
Integ?
A. By the District.
Q. The employees that -- that assisted you, were
those District employees?
A. Yes, sir.
Q. Did Integ have to purchase anything, equipment,
software, supplies in order to do this contract?
A. No.
Q. Did Integ have any other customers from 2007 to
2014?
A. No.

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Q. So Integ's sole source of revenue from 2007 to
2014 was the income received under the contract from the
District?
A. No.
Q. What were the other sources of revenue?
A. Rental.
Q. And rental income.
But Integ performed no other construction
management services?
A. No.
Q. And what was the rental income being received on?
A. The apartments.
Q. The two fourplexes?
A. Yes, sir.
Q. Anything else?
A. Basically on -- whenever there was income
available from some rental property on an office building.
Q. And that was the -- the office building rented to
Valley Data?
A. That they were utilizing and they would pay rent
whenever they had money available.
Q. Okay.
A. And also that office building that we had in
Mission.
Q. Okay. And who was renting that?

14 (Pages 53 to 56)

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A. That was being renting by Heavenly Days, the
corporation that my wife had.
Q. Okay. And that was the adult day care?
A. Uh-huh.
Q. Is that a "yes"?
A. Yes, sir.
Q. And would that pay rent every month or just when
it had the money?
A. Every month.
Q. Okay. Was there a written lease agreement
between Heavenly Days adult daycare and Integ?
A. Yes.
Q. Was there a written lease agreement between
Valley Data and Integ?
A. No.
Q. Would Valley Data pay the rent every month?
A. No.
Q. Was the rent the same every month?
A. No.
Q. What was the rent?
A. There was no rent.
Q. It's just whatever they -- they wanted to pay?
A. Whatever they could pay.
Q. And Integ had never worked on a multimillion
dollar project as construction manager before, had it?

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A. No.
Q. The relationship between -- contractual
relationship between Integ and the District lasted 14
years?
A. It could have been 15 years.
Q. Okay. The District's letterhead actually listed
Godfrey Garza, Jr., as the manager. Correct?
A. Yes, sir.
Q. The District letterhead did not list Integ as the
manager?
A. No, sir.
Q. And so throughout the 15 years during which Integ
had contracted with the District to provide management
services, the letterhead always said "Godfrey Garza, Jr.,
manager." Correct?
A. Yes, sir.
Q. And you never directed anyone to change that?
A. I believe the letterhead stayed from the time
that we were -- I was an employee, that the letterhead
just stayed the same.
Q. And during those 15 years, you never asked anyone
to change the letterhead?
A. No, sir.
Q. And when you signed letters that went out on
behalf of the District, you did not sign them noting that

you were signing on behalf of Integ?
A. No, sir.
Q. You signed them as the director?
A. District manager.
Q. District manager.
Did Integ pay a salary to your wife at any time?
A. Only when she did work for Integ.
Q. What periods of time did your wife do work for
Integ?
A. Periodically.
Q. What years?
A. Every year, periodically.
Q. Okay. Was it a specific salary or how was she
paid?
A. She would get paid on a weekly basis when she did
work.
Q. Okay. Would taxes be withheld or would she be
paid as a contractor?
A. Taxes would be withheld.
Q. But Integ didn't pay any wages to anyone other
than you or your wife. Correct?
A. Yes, sir.
Q. There was a bond issue done for $100 million by
the District. Correct?
A. Yes, sir.

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Q. Did that bond issue set out what the Phase II
projects were going to be?
A. The bond issue itself by Bond Counsel did not.
Q. Okay. By what the public voted on?
A. That's correct.
Q. It did or did not?
A. Did not.
Q. I want to ask you some about some of the Phase II
projects. There's a W-06-00 La Villa project. Did that
project ever get completed?
A. I don't recall.
Q. Okay. How about the Weslaco drain?
A. I don't recall.
Q. How about the Monte Christo, did that ever get
completed?
A. The Monte Christo changed by Commissioner Garza.
It was scheduled to be constructed a certain way, and then
Commissioner Garza changed the project and constructed it
in a different form so the ditch, instead of being dug, he
reconstructed and dug detention ponds.
Q. Okay. And was that project finished?
A. I don't know if it was finished.
Q. Was the McAllen Pharr South drain project
finished?
A. I don't know if they finished construction on it.

15 (Pages 57 to 60)

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Q. Was the Jackson drain project finished?
A. I believe it was 80 or 90 percent complete.
Q. Was the Penitas drain project finished?
A. Yes, sir.
Q. When was it finished?
A. I don't recall the date.
Q. Was the Raymondville industrial project finished?
A. They started construction on it about two, three
months ago.
Q. Now, the contract, if you look at Exhibit A to
the contract -(Discussion off the written record.)
A. Yes, sir.
Q. (BY MR. COWEN) Okay. It talks about paying one
and a half percent of actual construction costs. Correct?
A. Yes, sir.
Q. It doesn't say total construction costs?
A. No, sir.
Q. Does it define the term "actual construction
costs" in the contract?
A. No, sir.
Q. Valley Data Collection was not a licensed
engineering company. True?
A. No, sir.
Q. And it was not a licensed surveying company?

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A. No, sir.
Q. It did not employ any licensed engineers?
A. No, sir.
Q. It did not employ any licensed surveyors?
A. No, sir.
Q. I want to go through some of these invoices with
you, and let's start with Exhibit 7.
Okay. Exhibit 7 starts with a check that was
paid to Integ for $119,861.72. Correct?
A. Yes, sir.
Q. And that was for services performed by these
construction management services?
A. It says "Services performed as per master
drainage system contract."
Q. And then there is an invoice, which is the second
page. Correct?
A. Yes, sir.
Q. Who prepared that invoice?
A. Integ did.
Q. Who at Integ prepared it?
A. My wife.
Q. So your wife actually prepared the -- that
invoice?
A. Yes, sir.
Q. And what computer did she use?

A. Integ's computer.
Q. Okay. So that wasn't a District computer?
A. No, sir.
Q. How was -- how did the invoice get from Integ to
the District?
A. It was either given to me to take over to the
District.
Q. Or?
A. Or it was faxed. But more than likely it's
original, so I must have taken it over there to him
myself.
Q. And who did you give it to?
A. I would usually give it either to Lora or I would
give it to Sylvia Sanchez.
Q. Who is Sylvia Sanchez?
A. Sylvia Sanchez was chief of staff or
administrative assistant to the District.
Q. Okay. And then on the third page -- I want to
ask you a question. Were any of the invoices ever faxed?
A. I don't recall.
Q. Who would know?
A. I guess the invoice itself would show if it was
faxed.
Q. Because it would have the little fax line on the
top?

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A. Yeah.
Q. On the third page it says Hidalgo -- Hidalgo
County Drainage District #1, Engineering Cost as of
December 31st, 2007. Correct?
A. Yes, sir.
Q. Now, this is -- these are costs for which Integ
charged 1.5 percent for construction management. Correct?
A. Yes, sir.
Q. What was Integ's overhead, by the way? I mean,
who all did it have to pay and what all did it have to pay
at that time?
A. Basically it would be my overhead, my -- my
salary and whatever I would pay Annie.
Q. Okay. That was the only overhead, is what you
paid yourself and your wife?
A. Yes, sir.
Q. Okay.
A. And whatever gasoline I was paying or my vehicle
payment or my insurance payment or whatever medical
insurance I paid or whatever my costs were.
Q. Okay. But it didn't have -- it didn't lease an
office anywhere?
A. No, sir.
Q. It didn't advertise?
A. No, sir.

16 (Pages 61 to 64)

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Q. So the first thing there was some work done by
S&B Infrastructure, Ltd. for preliminary engineering,
$159,713.67 worth of work. What did you or Integ do to
manage that preliminary engineering work?
A. Reviewed the reports that were being done by S&B,
reviewed the delineation of what they were doing on those
reports, reviewed any work that was being done by S&B on
the preparation of those reports regarding either
environmental, regarding the schematics, any meetings that
took place. I would have to look at the actual report to
give you direct input as to what I did on them.
Q. And for this $8,379.03 you spent -- you billed on
this engineering work, how much time do you think you
spent on it?
A. I'd have to look at the report itself to see how
much time I spent on it.
Q. What qualifies you to tell whether the
engineering work was being done of -- to the proper
quality for an engineer?
A. My 30-some-odd years' experience of working with
engineers.
Q. But you're not an engineer. Correct?
A. No, sir.
Q. There was nothing actually built that was being
billed for on Page 3. Correct?

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A. No, sir.
Q. There was not actual construction, this was
engineering?
A. Yes, sir.
Q. And then the next page are additional engineering
costs. Is that correct?
A. Yes, sir.
Q. Also by S&B Infrastructure?
A. Yes, sir.
Q. And what did you do to earn your $186 on this
part?
A. Basically just go out there and verify that the
construction was being done properly, they provided
inspection, I went out to provide the inspection and
reviewed and made sure that the gates were going to be
operating properly and that also they were installed
properly.
Q. Did you do that kind of work back when you were
an employee at the District, go look at projects that were
being done?
A. Yes, sir.
Q. Okay. And that's back when you were just getting
a salary?
A. Yes, sir.
Q. And then TEDSI, what was TEDSI doing on the next

page, Page 5, that they billed for? Was that preliminary
engineering work?
A. TEDSI was doing preliminary engineering work the
Monte Christo project.
Q. And so none of this was actual construction going
on, this was all engineering work?
A. That is correct, sir.
Q. And what work did you or Integ do with regard to
this engineering work being done by TEDSI?
A. Basically coordinating the route that TEDSI was
delineating, meeting with Commissioner Garza on the route
where the drainage ditch was going to be going, meeting
with the Irrigation District in which this project was
being done, looking at where the minimum amount of impact
this project was going to go with the land owners, looking
at whatever utility adjustments were needing to be done
and just looking at the route which was going to be less
expensive to build the project on.
Q. Then the next page, is that more work for
engineering?
A. Yes, sir.
Q. And no actual construction at this point?
A. No, sir.
Q. Then the next page starts with -- it says
"Penitas Drain Basin." Was this also engineering work?

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A. Yes, sir.
Q. No actual construction being billed for here?
A. No, sir.
MR. SHAW: Let me object to the form of the
question.
MR. COWEN: That's fine.
MR. SHAW: You can ask me to clarify it.
MR. COWEN: I don't want to ask you to
clarify it.
MR. SHAW: Okay. Then I object to the form
of the question.
A. Basically what, again, is basically engineering
work that the engineer was engaged in and services that
the engineer was doing regarding the work and just making
sure that everything was being done properly.
Q. (BY MR. COWEN) Okay. Go to the next page. Next
page was additional -- was engineering work being done on
the levy system. Correct?
A. Yes, sir.
Q. And that was over $4.3 million dollars being done
on the levy system?
A. Yes, sir.
Q. What were the cultural resources that Dannenbaum
was paid $159,011.54 for?
A. The cultural resources consist of going in there

17 (Pages 65 to 68)

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and evaluating to make sure that there was not any
historical or environmental issues impacted on the levies.
You have to make sure that where the footprint of the
levies are, that itself does not fit over a historical
site.
Q. Weren't the levies already there?
A. It doesn't matter if the levies were there. When
you have a levy system and you're going to put dirt on top
of a historical site, it's not a problem. When you're
going to start digging into the levies and start moving
dirt up from it, then you could have a historical problem
because you're going to be moving problem. But if you're
putting dirt on top of it, you don't have an issue on
historical sites.
So you have to make sure that if it is a
historical site that you're going to have a plan in place
to identify that you're putting dirt on top of it; but if
you're digging underneath it, you have to communicate with
any historical society and get an update and get a time
and get a permit and make sure all of that is in
compliance.
Q. And no one knew where the historical sites were
from the original levy construction?
A. No, because the levies were done back in the
1930s and the 1950s, and the issue on historical and

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environmental issues are not something that were being
considered very highly back in the '30s or in the '40s the
way we look at it today.
Q. So the District paid $159,011.54 so someone could
look at the levies to see if any of them were historical
sites?
A. Yeah, it's probably going to be more money than
that spent on environmental issues to make sure that you
meet all the environmental criteria.
Q. And then you got -- you got 1.5 percent of that
for managing their seeing if any of the levies were
historical sites?
A. Making sure that they comply with all the
requirements.
Q. And Page 9, that was -- I'm sorry, Page 8, the
work that was done by Dannenbaum and L&G, that was all
work being done on the levy system. Correct?
A. Yes, sir.
Q. Then Page 9 there's additional engineering work
being done on the Jackson drain project by L&G and
Dannenbaum?
A. Yes, sir.
Q. Page 10 is engineering work being done by
Dannenbaum on the Weslaco Outfall? I'm sorry, by TEDSI.
A. By TEDSI.

Q. The preliminary engineering and field survey
billing entries, was that the kind of work that Valley
Data Collection Services did?
A. It would be a combination of what the engineer
would do and Valley Data would do. Valley Data, or any
other surveying company they would hire, would go out with
the engineers and start doing whatever preliminary work
they needed to look. An engineer would -- traditionally
would go out there and look at the site and then start
collecting whatever data they needed to start developing
their plans.
Q. Do you know if TEDSI used any surveying companies
other than Valley Data?
A. You would have to check with TEDSI on that.
Q. Did TEDSI ever disclose who their subcontractors
were?
A. Basically you would check with TEDSI on that, who
their contract -- subcontractors were.
Q. Given that there was a contractual obligation for
the contractors to disclose their subs, did you ever ask
TEDSI who their subs were?
MR. SHAW: Objection; form.
MR. NEWTON: Yeah, I'm going to object;
form.
A. I've never asked any contract -- sub -- any

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contractor who their subs were, for the simple reason that
legal counsel had always told us that whoever the subs
were was none of our concern.
Q. (BY MR. COWEN) Page 11 of the invoice, Alamo
Drain is divided between engineering costs and
construction costs. Correct?
A. Yes, sir.
Q. Did you pay yourself only on the construction
cost or on both the construction and the engineering?
MR. SHAW: Let me object to the form of the
question.
A. The invoice that I have here was basically
prepared by Ms. Lora Briones and the accounting. So I
didn't prepare these invoices. These invoices were
prepared by the District financial officer, and these
invoices were given to me, or to Integ, to attach to our
billing. So she or the District accounting department is
the ones that prepared the invoices. So I didn't prepare
them.
Q. (BY MR. COWEN) So you had the District's
employees prepare the invoices for Integ?
A. That's what the contract identified, that they
were the ones to prepare billing.
Q. And those were people you supervised. Correct?
A. That's the way the contract read.

18 (Pages 69 to 72)

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Q. So employees of the District, being paid by the
District, on District time, at your direction prepared
invoices for Integ?
A. Not in my direction. The contract identified
that the District financial officer would prepare the
payments.
Q. And this particular one differentiates
construction costs from engineering costs. Correct?
A. That is the way the financial officer prepared
it.
Q. But Integ, when it sent the invoice, did 1.5
percent of both the engineering and the construction
costs. Correct?
A. Integ sent the $21,993.51. I cannot tell you,
without looking in detail, if that included the 29,000 or
not.
Q. The next page, 12, also there is a
differentiation between engineering costs and construction
costs. Correct?
A. The bill that was prepared by the financial
officer identifies engineering costs and construction
costs being separated. Yes, sir.
Q. Did she ever ask you whether they should both be
included on the 1.5 percent?
A. No, sir.

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Q. You never told her to include both on the 1.5
percent?
A. No, sir. It was her job to prepare the bills to
identify what intake was supposed to be paid.
Q. And the last page, 13, actually lists -- they are
listed as construction costs. Correct?
A. Yes, sir.
Q. Okay. So this first invoice that we're talking
about that's dated April 11th, 2008, what period of time
does this cover?
A. (Pause.)
The ending period of 12/31/07. And the first
invoice shows a 3/31/07 or 12/31/07. 3, 8, 6. It's got
various -- I'd have to look through to see how long -Q. Work done in 2007, though?
A. Yes, sir.
MR. SHAW: Okay. If we're at a convenient
stopping point, if that's the end of that particular
exhibit, we can maybe think about what we're going to do
about lunch.
MR. COWEN: Whenever you want.
(Discussion off the written record.)
THE VIDEOGRAPHER: It's 12:05. We're off
the record.
(Break.)

THE VIDEOGRAPHER: This is the start of
Disk 2. It is 1:14, we're back on the record.
MR. SHAW: Godfrey, was there something you
wanted to clarify?
THE WITNESS: Yes, sir.
A. I wanted to -- to clarify the question earlier
regarding Integ doing any work for anybody else. And I
wanted to clarify that Integ had done work between 2000
and -- 2000 and 2015. They had a contract with the
Hidalgo County Regional Mobility Authority that served as
the executive director for numerous years, so they had a
contract also to do work for them.
Q. (BY MR. COWEN) And for what years did Integ have
a contract with Hidalgo County Regional Mobility
Authority?
A. I cannot be exact, but I think it was maybe 2009
to 2011, '12.
Q. And what work did Integ do for the Hidalgo County
Regional Mobility Authority?
A. It served as the executive director in assisting
it in the preparation of the development of the loop
system for Hidalgo County, which consisted of developing a
toll road, which was about a billion-dollar project.
Q. How was it paid?
A. How was Integ paid?

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Q. Yeah.
A. Integ was paid on a salary, plus it was paid on a
commission.
Q. What kind of -A. A percentage.
Q. A percentage of what?
A. A percentage of the funds that Integ was able to
generate in finding grants or finding federal funds
available for it.
Q. Did Integ hire any additional employees to
do -- to work with Hidalgo County Regional Mobility
Authority?
A. No. It had a similar contract with the Mobility
Authority to provide an office space, to provide a
secretary, to provide staffing needs.
Q. So from 2009 to either 2011, 2012, would just you
and your wife, as needed, Integ served as the director for
both the Drainage District and the Regional Mobility
Authority?
A. Yes, sir.
Q. And also served as a construction manager on all
these projects?
A. Yes, sir.
Q. Do you have diaries or anything else that keep
track of, you know, what you did each say?

19 (Pages 73 to 76)

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A. No, sir. There are calendars at the District
where my secretary would keep track of meetings or
appointments that I had besides whatever other information
came in, reports and so forth.
Q. Who were the decision-makers who hired
you -- hired Integ to do work with the Hidalgo County
Regional Mobility Authority?
A. The Board of Directors.
Q. And who were the Board of Directors there?
A. They have changed now. I don't recall who the
Board of Directors are there now, but the chairman is
appointed by the governor. The other Board members are
appointed by the elected officials of the county. And
another Board member is appointed by the largest city of
the county.
Q. Were any of the Board members on the Hidalgo
County Regional Mobility Authority also commissioners on
the bus- -- Drainage District?
A. No, sir.
Q. Whose idea was it for you -- for Integ to
contract with the Hidalgo County Regional Mobility
Authority?
A. The commissioners saw that there was a vacancy on
the Board of directors at the RMA and asked me if I would
be interested to apply.

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Q. As a director?
A. Yes, sir.
Q. And what did you say?
A. I said sure.
Q. Which commissioners, the Regional Mobility
Authority commissioners or the -A. No, the County commissioners.
Q. The County commissioners.
And which commissioner suggested that?
A. I don't remember who it was back then.
Q. As part of your work with Integ, did you ever
review the contract between Dannenbaum and Valley Data?
A. No, sir.
Q. You never looked at it?
A. No, sir.
Q. As part of your work with Integ, did you ever
review the contract between the District and Dannenbaum?
A. Yes, sir.
Q. And did you communicate on a regular basis with
anyone from Dannenbaum?
A. I communicated with Mr. Richard Sites, I
communicated with Mr. Louie Jones, I communicated with
several of their engineers that were there, some of their
inspectors. I can't remember who they are now.
Q. Did you recommend that Dannenbaum be one of the

companies hired to work on the project?
A. I don't remember if I recommended, but Dannenbaum
was one of the engineers that was on the list.
Q. Were you aware of any of the controversy
involving Dannenbaum at the Port of Brownsville?
A. That was common knowledge throughout the whole
South Texas area.
Q. That Dannenbaum had been paid tens of millions of
dollars on a project where ground never broke?
A. Again, that was just a lot of hearsay, a lot of
information that came out in the media.
Q. And were you aware that Dannenbaum, around the
same time that they were doing work for the District
actually, paid a $1 million civil forfeiture to the
Cameron County district attorney to resolve the issues
involving the bridge to nowhere in Port of Brownsville?
MR. SHAW: Objection; form.
A. I don't know anything about that.
Q. (BY MR. COWEN) You never read that in the paper?
A. I don't remember reading anything of that.
Q. And that Louis Jones also paid an additional
amount out of his own pocket as a civil forfeiture to
resolve the potential criminal matters?
A. Don't know anything about it.
Q. And were you aware that --

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MR. SHAW: Let me get my objection in.
THE WITNESS: I'm sorry -MR. SHAW: Objection.
Q. (BY MR. COWEN) And were you aware that the Port
of Brownsville had actually sued Dannenbaum over that
deal?
A. Only what I read in the paper.
Q. And were you aware there were issues that
Dannenbaum was involved in corruption, governmental
corruption and kickbacks involving the Port of Brownsville
deal?
A. Only what was put in the paper.
Q. Are you aware that Dannenbaum has recently been
raided by the federal law enforcement authorities?
A. Only what I've read in the paper.
Q. You don't have any idea what that's about?
A. Only what the papers put out.
Q. And what did you learn from the paper?
A. That their office was raided.
Q. Did that come as a surprise to you?
A. Yes.
Q. Have you heard any other rumors involving
Dannenbaum doing anything improper or illegal?
A. Only what the papers put out.
Q. Were you aware that any contractor or

20 (Pages 77 to 80)

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subcontractor working on -- on the District project was
subcontracting with Valley Data?
A. Could you repeat the question?
Q. Sure. Were you aware that Valley Data was doing
any work related to District projects?
A. I had heard that Valley -- yes.
Q. How did you hear about that?
A. In conversations that were -- that were made out
there.
Q. That were what?
A. That were made out there.
Q. Okay. Because your wife also worked for Valley
Data even before she became the owner of it. Correct?
A. Yes.
Q. And before your wife owned it, your sons owned
it. Correct?
A. Yes.
Q. How often would you see your son -- your
children?
A. I'd I run into my son maybe every two, three
weeks.
Q. Did you ever, at a public meeting, disclose to
the District commission that Valley Data was owned by your
children or your wife?
A. I've mentioned it at functions.

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Q. Okay. I'm asking you, though, at a -- at a
official meeting -A. No.
Q. -- when the whole commission was there?
A. No.
Q. Did you ever disclose in writing to the District
that Valley Data was owned by either your wife or your
children?
A. No.
Q. Did you ever get a written approval from the
District to have a company owned by family members of
yours receiving money on a project the District was
funding?
A. I never felt it was required, no.
I'd like to clarify one item. It was brought up
when Judge Garcia mentioned it, it was in December,
regarding my wife's ownership in the company.
Q. And what year was that?
A. 2014, I believe.
Q. Prior to 2014, at a meeting of the commission,
did you ever disclose to the District that a company owned
by either your wife or your children was being paid as a
subcontractor?
A. No.
Q. And did you ever get approval from the commission

to have Valley Data paid as a subcontractor?
A. I don't think -MR. SHAW: Object -MR. NEWTON: Object to the form -MR. SHAW: Objection; form.
MR. NEWTON: -- on that.
Are you asking on -- paid by the county?
MR. COWEN: That's an improper -MR. NEWTON: Well, I -MR. COWEN: No, no. "Objection; form" is
the rule. You're coaching at this point.
MR. NEWTON: Okay. Objection; form.
MR. COWEN: Thank you.
MR. NEWTON: The question is vague. It
doesn't designate by -MR. COWEN: No, that is also improper. You
can say "Objection; form," and I said, I have to -- unless
I ask you, that's all you get to say. That's the rules.
And because people coached witnesses like this before
1999, that's why we have the rule.
A. Can you repeat the question, please?
Q. (BY MR. COWEN) Sure.
Did you ever get authority from the Board, the
commissioners of the District for Valley Data to be paid
as a subcontractor on any District contract?

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MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
A. I don't think it was required based on my
contract to get any of the subs' approval to get paid
because my contract did not have an interpretation in
there by me regarding the subs getting approval by the
Board to get paid.
Q. (BY MR. COWEN) You don't believe it was a
potential conflict of interest to have contractors that
you're managing pay money to a company owned by either
your wife or your children?
A. Not according to -MR. SHAW: Objection; form.
Let me get my objection in, Godfrey, please.
You can go ahead now.
A. Not according to my contract.
Q. (BY MR. COWEN) And you never felt like it was a
potential conflict?
A. No.
Q. And you never felt like it was something you
needed to disclose to the District that not only were you
getting paid millions of dollars through Integ for
so-called construction management, but that your wife and
children were also getting millions of dollars through
their company as subcontractors?

21 (Pages 81 to 84)

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MR. NEWTON: Objection; form.
MR. SHAW: Objection; form.
A. No, because it was not so-called construction
management because I was complying with the language of my
contract on the management of it.
Q. (BY MR. COWEN) But as -- in your capacity acting
as the manager of the District, you never felt like you
had an obligation to tell the Board that a company owned
by first your children and later your wife was being paid
as a subcontractor on a District project?
MR. NEWTON: Objection; form.
MR. SHAW: Objection; form.
A. No, based on my understanding of my contract and
my obligations on my contract.
Q. (BY MR. COWEN) And you never told the District
that when it was paying these contractors like Dannenbaum
and TEDSI that in turn were hiring your wife or your
children's company as a subcontractor, that some of that
money was going to flow through to your family through
Valley Data?
MR. NEWTON: Objection; form.
MR. SHAW: Same objection.
A. It was not in my contract's understanding that it
was my responsibility. I followed what was my
understanding in my contract and the financial officers

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were auditing the bills according to their requirements,
and the invoices were being processed and placed on the
agenda for payment.
Q. (BY MR. COWEN) Did anyone disclose to the
financial officers that Valley Data was owned by either
your wife or your children?
MR. NEWTON: Objection; form.
MR. SHAW: Same objection.
A. That would be something that needs to be talked
to with the financial officers, which were the ones that
were processing the invoices that were being submitted by
the consultants.
Q. (BY MR. COWEN) And who are the financial
officers?
A. Financials, Lora Briones.
Q. Did you ever tell Lora Briones that Valley Data
was owned by either your children or your wife?
A. I was never asked who the owners or who the subs
were on any contract, and it was never my understanding
that it was our responsibility to be telling them who the
subcontractors were on any of the projects.
Q. My question is, did you ever tell Lora Briones
that Valley Data was owned by either your wife or your
children?
A. No.

Q. Do you know if anyone else told her that Valley
Data was owned by either your wife or your children?
A. I do not know.
Q. But to be clear, as someone that was acting as a
manager of the District, you had actual knowledge that a
company owned by your family members was being paid as a
subcontractor and you did not reveal that fact to either
Ms. Briones or to the Board. Correct?
MR. NEWTON: Objection; form.
MR. SHAW: Same objection.
A. I was going by my understanding of what was -- my
requirements were based on what was written in my
contract.
Q. (BY MR. COWEN) But you did not inform
Ms. Briones. Correct?
A. No.
Q. You did not inform the Board?
A. I went by what was written in my contract, had to
comply with whatever my obligations were.
Q. That wasn't my question.
Did you inform the Board?
A. I went by what was required in my contract to
comply with stipulations in there.
MR. COWEN: Objection, nonresponsive.
Q. (BY MR. COWEN) My question is simple. Yes or

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no, did you inform the Board?
A. I went by what was required in my contract.
Q. I didn't ask what -- about your contract. I
asked whether or not you informed the Board.
A. I went by what the requirements were in my
contract. If my contract required me to do it, then I
would have done it.
Q. Did you do it?
A. My contract did not require me to do it.
Q. So did you do it?
A. My contract did not require me to do it.
Q. Okay. This is a yes-or-no question. Did you
ever inform the Board that a company owned by your family
members was being paid as a subcontractor?
A. I informed some of the Board members.
Q. Okay. Who did you inform?
A. Commissioner Oscar Garza.
Q. Anyone else?
A. No, sir.
Q. When did you tell Commissioner Oscar Garza?
A. At functions that we would attend.
Q. What functions?
A. Functions that the elected officials would have.
Q. Like what kind of functions?
A. They would have political functions, they would

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have get-togethers.
Q. Okay. And so what did you tell Mr. Garza?
A. Basically my son would show up at the function;
"This is my son, he is the owner of Valley Data." The
engineers would be there. They would say, "Yes, he's
doing work with us."
Q. Okay. And which engineers said that?
A. Whatever engineers were there.
Q. What -- what were the dates of these things?
A. I could -- I couldn't tell you what dates. I
couldn't tell you what specific engineers.
Q. Did you tell any other commissioner?
A. Commissioner Hector "Tito" Palacios.
Q. Where did you tell "Tito" Palacios?
A. At political functions that they would have,
barbecues that they would have.
Q. Okay. And where were these held?
A. Somewhere in his precinct.
Q. What were the dates of the conversation?
A. I couldn't tell you the dates of the
conversations.
Q. Do you have any witnesses who can back up your
story that you told Commissioner Garza and
Commissioner Palacios?
MR. NEWTON: I'm going to object to the form

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of that.
MR. SHAW: Same objection.
A. You would have to talk to the commissioners
themselves or talk to all the engineers that are around
about.
Q. (BY MR. COWEN) Were there any witnesses in -that you can name that could back you up that -- that's -that would have been there that would have heard you tell
them that "My son owns this company and this company is
getting paid as a subcontractor on District projects"?
A. I didn't say that I told them that they were
getting paid on District projects. I said that they were
working for the consultants.
Q. Did you say specifically they were working for
the consultants on the project for the District?
A. I don't recall if I told them specifically for
the District projects. That would be something you need
to talk to the consultants.
Q. Because the engineering firms had other projects.
Correct?
A. Yes, they did.
Q. Okay. And so just -- even if you told one
commissioner that a company owned by your family was
working with a contractor does -- that doesn't follow that
they were necessarily working on the District project.

Correct?
A. True.
Q. Did you ever specifically tell any commissioner
that Valley Data was working as a subcontractor on the
District projects and that it was owned by your family?
A. I do not recall.
Q. At some point did -- was there a transfer of
money from Integ to Valley Data?
A. There was a loan, yes.
Q. When was that loan made?
A. I think it was around 2008 or 2009.
Q. Okay. Why was that loan made?
A. My son had bought a piece of property or a
building, and the bank was going to foreclose on it.
Q. And so Integ then transferred money to -- not to
your son directly but to Valley Data?
A. That's correct.
Q. Why to Valley Data and not your son directly?
A. Because Valley Data was the one that was buying
the building.
Q. And what building was that?
A. The office building that he bought.
Q. Okay. Where is that located?
A. In McAllen.
Q. What's the address?

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A. I don't know the address.
Q. What street's it on?
A. 23rd Street.
Q. That's -- who did he buy it from?
A. Apparently, he bought it from the bank or
from -- I think it was an attorney by the name of Mark
Cantu.
Q. Okay. How much money did Integ lend to Valley
Data in either 2008 or 2009?
A. It was between 75,000 and 100,000.
Q. How was the money -- was it a check? Was it a
wire? Was it cash? How did it -A. I think it was a check.
Q. Was it just one check?
A. I don't recall.
Q. Was it just one loan?
A. For the building it was one loan.
Q. Were there ever any other loans from Integ to
Valley Data?
A. We would let him borrow money if he needed $1,000
or $500 or $2,000, and he would pay it back as needed if
he was shy on money.
Q. Okay. And so when your son needed money, Integ
would then lend money to Valley Data so that Valley Data
could give it to your son?

23 (Pages 89 to 92)

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A. If that's what he needed it for, yes, sir.
Q. Was any of the money lent so that Valley Data
could get up and going and hire people and -A. It was probably to make payroll or if he had a
light bill or if he had something he had to pay.
Q. Was there ever any written agreement between
Integ and Valley Data regarding these loans?
A. No, sir.
Q. Was there ever any repayment made from Valley
Data to Integ?
A. Yes, sir.
Q. Are there -- is there any documentation of what
payments were made and when?
A. Only whatever check would show up showing that
we -- Integ would let him borrow $1,000 or -- and he would
write the check back to Integ.
Q. Without having the checks in front of you, can
you give us the details of what checks were written and
when and how much?
A. No, sir.
Q. Okay. Do you still have access to those checks?
A. No, sir.
Q. Would those checks be entered in the Peachtree
accounting system for either company?
A. They could be.

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Q. Do you still have access to Integ's Peachtree
accounting system?
A. Maybe for a year or two years back.
Q. What happened to the other data?
A. Some of the data got corrupted and some of
Peachtree doesn't go very far back. They only go back a
year or two years and it clears out and moves on forward.
Q. Do you know if Valley Data still owes any money
to Integ?
A. I don't think Valley Data owes any money to
Integ.
Q. How did you keep track of whether or not Valley
Data had paid back all the money it owed Integ?
A. On our tax returns.
Q. Okay. Loans and repayments show up on the tax
returns?
A. On money due or money out.
Q. Okay. Anywhere else other than your annual tax
return where you'd keep track of what was borrowed or what
was paid?
A. No.
Q. You didn't have a ledger somewhere you kept?
A. (Nods.)
MR. SHAW: You need to answer out -A. No.

Q. (BY MR. COWEN) How much money was repaid by -from Valley Data to Integ?
A. I couldn't tell you the dollar figure. All I
know is whatever we -- Integ let Valley Data borrow, which
the majority was that -- that building loan, that it was
paid back.
Q. Okay. And so some of the money, then, that the
subcontractors paid Valley Data on the District project
then Valley Data would have used to repay Integ?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
Q. (BY MR. COWEN) Isn't that true?
A. I wouldn't know because they did work for other
projects that were not related to the Drainage District.
Q. Did Integ charge any interest to Valley Data for
these loans?
A. No, sir.
Q. Have you had any other business deals where a
corporation lends money without interest that you've been
involved in?
A. Yes.
Q. Tell me about them.
A. When -- when Integ deposited money in its
accounts, it had money in the bank for four or five years
drawing zero money because it didn't invest it. It just

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had it sitting there.
Q. Okay.
A. So it's not unusual for Integ to have had money
sitting in a brokerage account not drawing any money.
Q. But as far as lending it to other people and not
charging interest.
A. Well, the bank used it to lend to other people.
So what's the difference between Integ letting somebody
borrow it and the bank having it there. They don't just
sit on it.
Q. Did Integ lend money to anybody else besides
Valley Data?
A. Not that I'm aware of.
Q. Did Integ ever lend any money directly to either
your wife or any of your children?
A. I don't recall.
Q. Would you agree that it would be improper for
Integ to be hired as a subcontractor on a District project
without disclosing it to the District?
MR. SHAW: Objection; form.
A. According to my understanding of my contract, it
would have been improper, if Integ was hired by a
consultant that was doing work for the District, and Integ
not disclose it to the District, and then the District, at
that time, would have the option to either let Integ

24 (Pages 93 to 96)

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continue the work or not continue the work, or if Integ
had received compensation, then it would be up to the
District to tell Integ to give the money back to the
consultant.
So there is a clause in there which allows Integ
to do work for consultants that are doing work for the
District. And that was the whole reason why the contract
was written for Integ to have the ability to do work.
Q. (BY MR. COWEN) And if you go to Exhibit 5, and
the page that's 350, Bates No. 350. So it says "Prior to
entering into any contract or business relationship or
receiving any payment from any individual or entity who is
financially interested in a contract or project with the
District or who is a director or employee of any such
individual or entity, Integ shall disclosed the proposed
contract, business relationship or payment to the Board of
Directors of the District." Did I read that correctly?
A. Yes, sir.
Q. "Integ's disclose shall be entered into the
minutes of a meeting of the District." Correct?
A. Yes, sir.
Q. This is the conflict of interest section you were
talking about?
A. Yes, sir.
Q. Okay. Did Integ ever disclose that it had -- to

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the District that it had loaned money to a subcontractor,
Valley Data?
MR. SHAW: Objection; form.
A. That's where I do not believe that the intent of
this contract was related to lending money but for Integ
doing work with any consultant or any contractor. It is
y'all's interpretation that that is related to any type of
other business venture, and this contract was specifically
written for Integ to be doing work. Integ already had
real estate, had already had ventures out there. So the
contract was written in an attempt for Integ to be doing
or if it was going to do construction management work.
Q. My question was did you ever inform the Board of
Directors of the District that Integ had lent money to one
of the subcontractors, Valley Data?
A. No, because it was not in violation of the
contract.
Q. Did you ever inform the Board of Directors of the
District that Integ was receiving payments, repaying that
loan from Valley Data, one of the subcontractors on the
contract -- on the project?
A. No, because I don't know if the payments that
were being given to Integ were being -- funds were being
used from any project that Valley Data might have been
doing for the Drainage District or if even it was in

violation of the contract.
Q. But you agree that Valley Data received money as
a subcontractor on a District project. Correct?
A. I agree that Valley Data was doing work on
contracts that were being funded by the District.
Q. So the money gets paid from the District to the
contractor and then the contractor pays Valley Data.
Correct?
MR. SHAW: Objection; form.
MR. NEWTON: Objection.
A. I don't -- I don't know where the contractor was
paying Valley Data from.
Q. (BY MR. COWEN) But Valley Data was doing work on
the project as a subcontractor?
A. It appears, from the information that I've seen,
Valley Data was doing work with subcontractors, as a
subcontractor, for work that was being done at the
District.
Q. And if you wanted to find out more details, you
lived in the same home as your wife, who was also employed
by Valley Data at the same time. Correct?
MR. NEWTON: Objection; form.
A. Yes, she worked for Valley Data, but it does not
mean that we have a conversation on every work or job that
she does.

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Q. (BY MR. COWEN) I know. But if you wanted to
find out what Valley Data was doing, whether it was
related to the District or not, you would just ask your
wife or ask your kids.
MR. NEWTON: Objection; form.
Q. (BY MR. COWEN) Correct?
MR. SHAW: Same objection.
A. If I wanted to find out or if I needed to know.
Q. (BY MR. COWEN) But did -- you never disclosed to
the Board of Directors of the District that you were
receiving loan payments from Valley Data. Correct?
A. No.
Q. Okay. Let me re-ask it, because it might be a
double negative.
Did you ever disclose to the Board of Directors
of the District that Integ was receiving loan payments
from Valley Data?
MR. NEWTON: Objection; form.
A. No, because I did not feel that according to the
contract, there was a conflict of interest there.
Q. (BY MR. COWEN) And you would agree that Valley
Data was financially interested in the project with the
District because it was being paid as a subcontractor,
wouldn't you?
MR. NEWTON: Objection; form.

25 (Pages 97 to 100)

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MR. SHAW: Same objection.
A. Can you ask that again?
Q. (BY MR. COWEN) Valley Data was being paid as a
subcontractor on the project. Correct?
MR. NEWTON: Again, objection; form.
A. On some projects.
Q. (BY MR. COWEN) Therefore, it was financially
interested in the project because it was being paid as a
subcontractor. Wouldn't you agree?
MR. NEWTON: Objection; form.
MR. SHAW: Same objection.
A. On some projects.
Q. (BY MR. COWEN) On some projects Valley Data was
financially interested in the project. Correct?
A. Yes.
Q. Would you agree that it would be -- that if you
personally, Gilbert Godfrey, Jr. (sic), wanted to work as
a consultant for one of the contractors on the project,
that you would have had to have disclosed that to the
District?
MR. SHAW: Objection; form.
A. Could you ask it again, please?
Q. (BY MR. COWEN) Yeah. Okay. Hypothetically,
let's say Dannenbaum said, "Hey, we want to hire you as a
consultant to help us on this project and we want to pay

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you $100,000 to do it." Would you have an obligation to
disclose that to the Board of Directors at the District?
A. Are you asking Godfrey Garza, Jr. or are you
asking Integ?
Q. I'm asking Godfrey Garza, Jr.
A. I think I would have because Godfrey Garza is
part of the contract. So I would bear to go on the
critical side, knowing what I'm knowing now, the way y'all
are interpreting the contract, that I would be very
hesitant on everything and present everything questioning
to the Board.
Q. But do you believe that you would have an
obligation, if during the time that Integ, the company
that you solely owned and managed, was contracted to be
the District manager and project manager -- construction
manager on this project, if someone wanted to hire you
individually, not Integ, but you individually, to work on
one of these projects as a sub, would you agree you'd have
an obligation to disclose and get approval from the
District first?
MR. SHAW: Objection; form.
A. Based on the contract, I would tend to go to the
side and say I would go talk to the Board.
Q. (BY MR. COWEN) Because you agree that it doesn't
pass -- it wouldn't pass a smell test to have

subcontract -- I'm sorry.
You would agree it doesn't pass -- it would not
pass a smell test to have a contractor paying Gilbert
Godfrey (sic) money individually while a company owned
solely by Gilbert Godfrey (sic) -- I can’t even talk.
MR. NEWTON: He's a comedian.
(Discussion off the written record.)
Q. (BY MR. COWEN) Can you see the possibility for
bad things happening if a company can be managed on the
construction management side by Integ, which is owned by
Godfrey Garza, but yet would still be able to pay Godfrey
Garza individually as a consultant on the same deal?
MR. NEWTON: Objection; form.
MR. SHAW: Objection; form.
A. I could see there would be some questions.
Q. (BY MR. COWEN) But you don't think there is any
questions if they hire a company that's owned by your
wife?
MR. NEWTON: Objection; form.
MR. SHAW: Same objection.
A. No, I don't, because I'm not the one that owns
that company, and I'm complying with the requirements in
my contract.
Q. (BY MR. COWEN) And are you familiar with the
Texas concept of community property?

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MR. NEWTON: Objection; form.
A. I am more -- I can speculate on the community
property because it was always my belief that the
community property law only came into play when you got
divorced or you died. And it appears that there is more
questions to the issue on community property laws.
Q. (BY MR. COWEN) I'll give you an example. I am
the sole owner of my law firm, of the corporation. If I
did something stupid and stepped out on my wife, do you
think she'd say it was yours or do you think she'd want
half of it?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
A. I don't know your wife.
Q. (BY MR. COWEN) Okay. What would you think?
A. I don't know your wife.
(Discussion off the written record.)
Q. (BY MR. COWEN) I will tell you she would want
half or more. She would not say "it's all yours."
The other leases of real property that Integ did,
the fourplexes and whatever else it had, did it have
leases with the tenants?
A. Uh-huh.
MR. SHAW: Is that a "yes"?
Q. (BY MR. COWEN) Is that a "yes"?

26 (Pages 101 to 104)

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A. Yes. Sorry.
Q. Okay. So let's go back in the period 2007 to
2014. What rental properties did Integ own, again?
A. I think all of the properties were sold by then.
Q. Okay. But back when Integ had offices to lease,
it would have a written lease. Correct?
A. Uh-huh. Yes.
Q. But with Valley Data, Integ did not have a
written lease?
A. No.
Q. Or a set rent?
A. Or a set rent.
Q. Because Valley Data would pay whatever it could
afford?
A. Yes.
Q. And if it didn't have any money that month, it
wouldn't pay anything?
A. Yes.
Q. What was the period of time when your wife was
working for both Integ and Valley Data at the same time?
MR. SHAW: Objection; form.
A. I guess forever. Okay.
Q. (BY MR. COWEN) Okay. So basically everybody in
the -- let me rephrase the question.
From 2007 to 2014 your wife worked for both Integ

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and Valley Data?
A. As -- as Integ needed her to either type up an
invoice for me or -- or for Integ, or type a letter for
Integ, or write some checks for Integ, she would spend her
hour, or for 45 minutes, or two hours to do that. And I
would assume that she would do the same thing for Valley
Data if she needed to go and work for them for an hour, or
two hours. Neither company -- and I'll speak on Integ -was she there 8:00 to 5:00 every day. She wasn't there at
Integ 8:00 to 5:00 every day.
Q. Do you know what Dos Logistics did on these
projects, on the Drainage District projects?
A. Dos Logistics was a subcontractor.
Q. And who did they subcontract through?
A. Through Dannenbaum Engineering.
Q. And do you know what -- what Dos Logistics did as
a subcontractor?
A. They did both engineering, surveying, inspection,
management, I would assume.
Q. There was an allegation made by someone at
Dannenbaum that they had to cut Dos Logistics in for
40 percent of their money to get the -- to get the deal.
Have you ever heard of that?
A. No, sir.
Q. You're not aware of that?

A. No, sir.
Q. Did you actually see anyone from Dos Logistics
doing work on the project?
A. Oh, definitely.
Q. What did you see them do?
A. I saw their trucks out there doing inspection. I
saw their engineers out there doing design work. I saw
their engineers at Dannenbaum doing design work. I saw
their plan sheets with their names on them. I saw them
attending meetings with DHS. I saw letters of
recommendation from DHS on the quality of work they did.
Q. How did you have time to be the manager for the
Regional Mobility Authority -- or the director for the
Regional Mobility Authority, the manager for the District,
and do construction management?
A. I'm very good at what I do.
Q. So you had enough hours in the day to do all
three of those jobs?
A. (Nods.)
MR. SHAW: Is that a "yes"?
A. Yes.
Q. (BY MR. COWEN) And how much did you end up
getting paid by the Regional Mobility Authority?
A. Oh, I don't know, maybe 6-, $700,000.
Q. Did you ever delete any of your e-mails on your

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Drainage District e-mail account?
A. No, sir.
Q. Never?
A. (Nods.)
Q. Did you ever -MR. SHAW: Is that a "no"?
A. No.
Q. (BY MR. COWEN) Did you ever direct any documents
to be shredded at the District?
A. No, sir.
Q. Did you ever shred any documents at the District?
A. No, sir.
(Exhibit 29 was marked.)
Q. (BY MR. COWEN) Let me show you what I've marked
as Exhibit 29. And I'm only going to ask you about the
cover page right now. Is that a letter that's on
letterhead, Exhibit 29, from the District?
A. Yes, sir.
Q. And does it, in the upper left-hand corner, say
"Godfrey Garza Jr., Manager" on the letterhead?
A. Yes, sir.
Q. And did you sign that letter?
A. Yes, sir.
Q. And what is under your name?
A. Godfrey Garza, Jr., CFM, District manager,

27 (Pages 105 to 108)

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Floodplain Administrator.
Q. What does "CFM" mean?
A. Certified Floodplain Manager.
Q. Is Integ on there at all?
A. No, sir.
Q. You're not saying Integ Corporation by Godfrey
Garza?
A. No, sir.
Q. You're signing it Godfrey Garza. Correct?
A. Yes, sir.
Q. And then putting your position with the District?
A. Yes, sir.
Q. And I'm going to hand you what I'm marking
Exhibit 30, which is an e-mail -- a printout of an e-mail
you sent.
(Exhibit 30 was marked.)
Q. (BY MR. COWEN) On Page 2 of that document -A. This one, sir?
Q. Yes, sir. On the second page. Is that -- was
that your e-mail signature you normally used?
A. Yes, sir.
Q. And it said "Godfrey Garza, Jr., CFM, District
Manager" -A. Yes, sir.
Q. -- "Hidalgo County Floodplain Administrator."

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Correct?
A. Yes, sir.
Q. So when you signed off on e-mails, the e-mail
signature said that you were the District Manager for the
Hidalgo County Drainage District No. 1?
A. Yes, sir.
Q. It did not mention Integ anywhere. Correct?
A. No, sir.
Q. And the address that's listed there is the
Drainage District's address?
A. Yes, sir. Below the signature, it had Hidalgo
County Drainage No. 1 902 North Dittle -- Doolittle.
Q. You don't have Integ's address on there anywhere?
A. No, sir.
Q. And you actually -- the -- the "from" -- the
e-mail account G.G.HCDD1.org, this is actually a Drainage
District e-mail account you were sending it from.
Correct?
A. Yes, sir.
Q. Now, the contracts where Integ was being paid for
construction management said it was going to be paid
1.5 percent of actual construction costs on the Phase II
drainage project. Correct?
A. Yes, sir, the actual construction costs
considered -- consisted of everything related to the

project save and except the land acquisition cost.
Q. Okay. Is there ev- -- any document that says
that Integ is going to be paid money on the Federal Border
Infrastructure Improvement Project?
A. It said that Integ was going to get paid the one
and a half percent of everything related to the Hidalgo
County Drainage No. 1, Master Drain Plan Phase II.
Q. But anything that specifically -- a new contract
or anything that referenced by name the Federal Border
Infrastructure Improvement Project?
A. No, sir. It just included everything on the
Phase II.
Q. Did you ever go on any trips with any contractors
that worked on these projects?
A. When we refer to "contractors," is the question
the building contractors or are you considering the
engineers' contractors?
Q. Anyone, including the engineers.
A. Yes, sir.
Q. Tell me about that.
A. We did numerous trips to El Paso.
Q. Okay.
A. And trips up to Austin and trips up to
Washington, D.C.
Q. Why did you go to El Paso?

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A. To El Paso we went with the County Judge JD
Salinas, Commissioner "Tito" Palacios, Commissioner Oscar
Garza, Dannenbaum, representatives of Dannenbaum to meet
with the International Boundary and Water Commission,
that's where their headquarters is it, to facilitate the
development of a Memorandum of Understanding to be able to
work on the levy system.
To Austin, we went to meet with the governor's
office. It was Governor Perry with JD Salinas, Judge,
Hector Palacios, myself, staff from the judge to receive
support to move forward with the possibility of partnering
with the Department of Homeland Security.
To Washington, D.C. we went with a delegation of
Judge JD Salinas, commissioners, representatives from
Dannenbaum to meet with the Department of Homeland
Security, Congressman Henry Cuellar, other representatives
to meet with DHS on the possibility of working together on
the development of the border wall issue along the levy
system.
Q. Did you ever go on any other trips with any
contractor or subcontractor on the project?
A. I don't recall.
Q. You never went on any vacations with them?
A. I went on vacation -- personal vacations.
Q. Okay. What personal vacations had -- did you go

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on with any contractor or subcontractor?
A. I went on fishing trips with -- with Mark Lupher.
Q. Who else?
A. That's it.
Q. Where did you and Mr. Lupher go fishing?
A. We went fishing in Cabo.
Q. Cabo San Lucas?
A. Uh-huh.
Q. How many times?
A. Once.
Q. Any other fishing trips?
A. No.
Q. Who paid for the trip?
A. I paid for my trip.
Q. He didn't pay for anything?
A. Nope.
Q. When was this trip?
A. Oh, God. This was, I don't know, early 2000, I
believe.
Q. And no other fishing trips other than that?
A. Uh-uh.
MR. SHAW: Is that a "no"?
A. No.
Q. (BY MR. COWEN) Ever go hunting with any of the
contractors or subcontractors?

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A. I have my own place to go hunting. Oh, yes, I
did go hunting with Mr. -- Judge Salinas -Q. Okay.
A. -- at his place, didn't shoot anything.
Q. Okay. When was that?
A. Sometime in the 2000s. I went hunting with
Commissioner Garza.
Q. Did you ever receive any gifts from any
contractor or subcontractor?
A. Such as -Q. Anything.
A. Oh, suppers, some bottles of wine.
Q. Okay.
A. Candies.
Q. Okay.
A. That type of deal.
Q. Did you ever take any of the commissioners on any
trips?
A. No.
Q. Ever give any -A. I went with them.
Q. Okay. With you paying or Integ paying?
A. No, them paying.
Q. Did you ever give any commissioners any gifts?
A. Yes, sir, I would give them -- at Christmastime I

would give them a bottle of wine, I'd give them a ham, I'd
give them a turkey.
Q. Did you directly or indirectly share any of the
money that Integ or Valley Data got with any elected
official?
A. No, sir.
MR. NEWTON: Objection; form.
A. No, sir.
Q. (BY MR. COWEN) What did Integ do with the money
that it made on this project?
MR. SHAW: Objection; form.
A. Keep it.
Q. (BY MR. COWEN) Does Integ still have it?
A. No.
Q. Okay. Where -- what -- what happened to it?
A. Spent it, living expenses.
Q. Your own living expense. Correct?
A. Uh-huh.
MR. SHAW: Is that a "yes"? Is that a
"yes"?
A. Yes.
Q. (BY MR. COWEN) So the money flowed to you as the
owner?
A. It flowed to me as the owner or we acquired
properties or we spent it.

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Q. Okay. And the properties acquired would have
been in your name or in Integ's name?
A. Integ's name.
Q. Does Integ still have any properties?
A. Uh-huh. Yes, sir.
Q. Okay. What properties does it have?
A. It has a 400-acre ranch, and it has a rental
property on Zenaida [phonetic], and that is all the
property that Integ has.
Q. Do you know what happened to the money that
Valley Data made?
MR. NEWTON: Objection; form.
A. I would have no knowledge of what Valley Data did
with their money. Oh, excuse me. And we have a beach
house.
Q. (BY MR. COWEN) Where?
A. At the island.
Q. South Padre?
A. Uh-huh.
Q. Is that a "yes"?
A. I'm sorry, yes.
MR. SHAW: Why don't we take a break?
THE VIDEOGRAPHER: It's 2:06. We're off the
record.
(Break.)

29 (Pages 113 to 116)

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THE VIDEOGRAPHER: It is 2:29 and we are
back on the record.
Q. (BY MR. COWEN) Are you aware that the contract
between the District and Dannenbaum called for Dannenbaum
to perform construction management services?
A. Yes, sir.
Q. Did you tell anyone at the District that
Dannenbaum was being paid for doing the same thing that
Integ was doing?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
A. Dannenbaum's contract called to do construction
management at a certain level. Those contracts or those
supplementals are items that were negotiated with
Dannenbaum to do construction management were not a
duplicate of the work that Integ was going to be doing on
the project.
Q. (BY MR. COWEN) Did you ever tell the Board of
Directors of the District that, "Hey, you know, Integ is
charging you millions of dollars to do construction
management, but Dannenbaum is really doing the work and
I'm spending most of my time managing the RMA and the
District"?
MR. NEWTON: Objection; form.
MR. SHAW: Objection; form.

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A. No, because Dannenbaum was not the only one doing
the construction management. So was Integ.
Q. (BY MR. COWEN) Do you have any way to kind of
parse out how many hours a week you spent doing management
things for the District, how many hours a week you spent
doing management stuff for the RMA, and how many hours a
week you spent doing construction management for the
District?
A. All I can say, that during the time that the
levies were under construction, I would say 90 percent of
the time was spent related to the levy work.
Q. And how -- do you have any documentation to prove
that?
A. No. Just the volume of paperwork and the amount
of work that was being done by the District or by myself
related to the levy and the documentation coming in and
out of the office, trailers coming in and out of the
office, the amount of time out of the office, the calendar
identifying meetings that I was going to.
Q. How many times a week were you actually out at
construction sites actually supervising what they were
doing?
A. I would say 90 percent of the time you were out
in the field.
Q. 90 percent of the time you were out of the

office?
A. (Nods.)
MR. SHAW: Is that a "yes"?
Q. (BY MR. COWEN) Is that a "yes"?
A. Yes. I'm sorry.
Q. Who else could -- could testify to that, to back
you up?
A. I guess checking on my calendar, the calendar the
District had there.
Q. And was it electronic or paper calendar?
A. It was paper.
Q. Have you ever been convicted of a felony?
A. Many years ago I had an issue.
Q. Okay. Tell me about that?
A. I had an issue regarding the writing of an
insufficient check, and I got convicted. I did my
adjudication and it was clear.
Q. But it was a felony conviction?
A. It was adjudicated, so it didn't show up on the
record.
Q. So you're saying it doesn't show up on your
record?
A. No, sir.
Q. But it was a felony, wasn't it?
A. I think. I don't recall. I was -- I was 20

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years.
Q. When you applied to go work as an employee
initially with the District, did you disclose that you had
a felony conviction?
A. They didn't ask for it in the application.
Q. But did you ever disclose to anyone in the
District that you were -- that you had a felony?
A. No, sir.
Q. Are there any other companies or entities in
which you or any family member of yours, including your
wife or your children, received payment for any kind of
work related to a District project?
MR. SHAW: Objection; form.
A. Run that by again.
Q. (BY MR. COWEN) Okay. We know that Valley Data
received payment as a subcontractor on the project.
Correct?
A. Okay.
Q. Are there any other companies owned by you or any
of your family members that received any payment related
to this project, from anyone?
A. No.
Q. When the District paid Integ, would it send the
check by mail?
A. Yes.

30 (Pages 117 to 120)

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Q. At what banks did Integ have accounts?
A. Integ had accounts at Security and at Compass.
(Exhibit 39 was marked.)
Q. (BY MR. COWEN) I'm going to hand you what we've
marked as Exhibit 39. Do you recognize that document?
A. Yes, sir.
Q. What is it?
A. It is the grant application. It's called Federal
Financial Assistance Award.
Q. And who is the recipient of the award?
A. Hidalgo County Drainage District No. 1.
Q. Okay. And it was issued by the United States
Department of Homeland Security?
A. And U.S. Customs and Border Patrol -- Protection.
I'm sorry.
Q. And the title of the -- of the grant is "Hidalgo
County Border Infrastructure Improvement Program."
Correct?
A. Yes. It was in their -- it went in the top of a
cooperative agreement.
Q. It doesn't saying anything about Drainage
District Phase II on this document.
A. No, sir.
Q. And as the recipient contact, it says "Godfrey
Garza, Program Manager, Hidalgo County Drainage District

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No. 1." Correct?
A. Yes, sir.
Q. It does not list Integ.
A. No, sir.
Q. Did you or anyone else from Integ ever notify the
federal government that Integ was going to receive
1.5 percent of the federal funds spent on this project?
MR. SHAW: Objection; form.
A. Integ never received 1.5 percent of the federal
funds.
Q. (BY MR. COWEN) Okay. Did you ever -- or Integ
ever inform the federal government that Integ was going to
receive any money on this project?
A. No, sir.
(Exhibit 41 was marked.)
Q. (BY MR. COWEN) I'm going to hand you what I've
marked as Exhibit 41.
MR. SHAW: Godfrey, there is 41.
Q. (BY MR. COWEN) And do you recognize that
document?
A. (Pause.)
No, I don't remember it.
Q. Okay. Does it look like something you wrote?
A. No, it doesn't.
Q. Okay. It's got your name on the bottom, doesn't

it?
A. Yes, it does.
Q. Okay. Do you know why you would be sending any
kind of e-mails from your wife's e-mail account to a Patty
Rodriguez at the District?
A. No, I don't.
Q. Who is Patty Rodriguez?
A. My secretary.
Q. Your secretary at the District?
A. Yes, sir.
Q. A District employee?
A. Yes, sir.
Q. And do you remember ever wanting her to do the
things listed on this e-mail?
A. Can I finish reading it?
Q. Sure.
A. (Pause.)
The only thing that I -MR. SHAW: Can I see that, please?
THE WITNESS: Yes, sir.
MR. SHAW: Has this been produced?
MR. BLANCHARD: Yes.
MR. SHAW: It doesn't have a Bates stamp
number on it.
MR. BLANCHARD: It's in the PSD file that we

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sent you guys a long time ago, the Outlook file.
A. The only thing I can say on that is the
following: That it's dated May 7th, 2008, and my birthday
was May 6, that we might be out of town somewhere and I
had my wife type it up and e-mail it from wherever we were
at.
Q. (BY MR. COWEN) And who is the "Sylvia" that the
e-mail refers to?
A. Sylvia Sanchez.
Q. One thing you -- you noted in the first paragraph
to Sylvia is, "I do not appreciate hearing from the
independent auditor the comments listed on his e-mail."
What were you talking about?
A. The independent auditor was probably complaining
about Lora.
Q. Okay. What about her?
A. That she was not submitting her paperwork on time
for the independent auditor or Ricky, which was the
independent auditor, to submitting in his paperwork for
the completion of the audit.
Q. And that's because he was focusing on the DHS
project?
A. (Reviewing document aloud.)
That was apparently the excuse that she
was -- that Lora was giving to the independent auditor.

31 (Pages 121 to 124)

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Q. And the term you used was "DHS project."
Correct?
A. Department of Homeland Security.
Q. You didn't say Phase II?
A. No, sir.
Q. I'm going to hand you what we've marked as
Exhibit 2 -- I'm sorry. -- 42.
(Exhibit 42 was marked.)
A. (Pause.)
Okay.
Q. (BY MR. COWEN) What is that e-mail?
A. I have no idea.
Q. Okay.
A. I don't know who these gentlemen are.
Q. Okay. Who is Daniel Rios?
A. Danny -- Daniel Rios is a VP for S&B
Infrastructure.
Q. Okay. It says "Information you requested for
Trey." Is Trey -- you have a son named Trey. Correct?
A. Yes, sir, uh-huh.
Q. Okay. Are you requesting contact information for
Trey so Trey can get business for Valley Data?
A. I don't know who these gentlemen are.
Q. Okay. Did Trey own Valley Data back in 2008?
A. Yes, sir.

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Q. And you don't know who any of those people are?
A. No, sir.
Q. Okay. Why would you be requesting people's phone
numbers for your son?
A. My son might have asked me for something. I
don't recall who these individuals are.
Q. You don't think it -- if you're asking for
information for your son to get business, it creates the
impression that you want Valley Data, his company, to get
the business?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
A. I don't know who these gentlemen are. If my son
asked me to get some names, I don't know who they are or
what they're for.
Q. I'm going to go ahead and hand you 44 to 47 and
49 to 50.
(Exhibits 44 through 50 were marked.)
MR. COWEN: Just to make it go more quickly,
let's take a break so you can look at them and then
we'll -- I'll go ask you about them.
THE VIDEOGRAPHER: It is 2:42, we're off the
record.
(Break.)
THE VIDEOGRAPHER: It's 2:47, we're back on

the record.
Q. (BY MR. COWEN) What is Exhibit 45?
A. 45 is a cover letter that was sent to me by
Ms. Lora Briones regarding a affidavit or a form that
we -- we at the District would submit to the independent
auditor regarding any potential questions or conflicts
that we would see during the year at the District
regarding any impacts or transactions that might have
taken place during the year.
Q. All right. And you filled this out as
"Mr. Godfrey Garza, Jr., CFM, District Manager"?
A. I signed it as "Godfrey Garza, Jr., District
Manager."
Q. Yeah, you did not have -- "Integ" is not written
anywhere on this document?
A. No, sir.
Q. Okay. And Question No. 1 you were asked, "Have
you or any related party of yours had any material
interest, direct or indirect, in any of the following
transactions or pending transactions since January 1st,
2012, to which the Hidalgo County Drainage District No. 1
was, or is to be, a party?"
Correct?
A. Yes, sir.
Q. And you put "no" for every -- you put "no" for

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every category. Correct?
A. Yes, sir.
Q. You did not disclose any interests that Valley
Data had as -- working as a subcontractor?
A. I didn't have any interest in Valley Data.
Q. Okay. But your wife owned it in 2012. Correct?
A. I didn't have any interest in Valley Data.
Q. Okay. It said "any related party." Is your wife
related to you?
A. Yeah, but she's the owner of the corporation.
Q. Okay.
A. I didn't have any interest in the corporation.
Q. So you did not disclose it. Correct?
A. I did not have any interest in Valley Data.
Q. And what was your understanding of the -- of the
meaning of the term "related party"?
MR. SHAW: Objection; form.
A. That if I had any interest in that.
Q. (BY MR. COWEN) So you don't think your wife is
a related party?
A. She was an owner of a corporation, and to me
that's a separate entity.
Q. Okay. So you didn't disclose it?
MR. SHAW: Objection; form.
A. Because it was a separate corporation.

32 (Pages 125 to 128)

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Q. (BY MR. COWEN) And the next exhibit is 44?
A. Yes, sir.
Q. You also did not disclose anything about payments
to Valley Data on your 2013 conflict of interest form.
Correct?
A. Yes, sir.
Q. Now, No. 2 you said "yes" "you or a related party
has been indebted or had a receivable from...Hidalgo
County Drainage District No. 1 at any time."
And you said, "Pending final closure of contract,
if required."
What -- what is that talking about?
A. I don't recall why I put that on there in 2013.
Q. Prior to 2012, did you have to fill out these
forms every year?
A. Similar form but I also -- back to that one. I
also did sign that as "District Manager and Consultant."
I don't know why.
Q. Okay. But you don't have the word "Integ" on
there any- -- anywhere. Correct?
A. But I did sign it as "District
Manager/Consultant."
Q. All right. As both. Correct?
A. Yes, sir.
Q. And then the next Exhibit, 46, was a Fraud

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Questionnaire. Is that correct?
A. I think 46 replaced -- were the forms that were
utilized prior to these forms that were utilized.
Q. Okay. And then you had -- again, it was issued
to "Godfrey Garza, District Manager." Correct?
A. 2011.
Q. And you signed it "Godfrey Garza, Jr., District
Manager." Correct?
A. Yes, sir.
Q. You don't have "Integ" on there at all?
A. No, sir.
I think my contract read on it that I was serving
as a district manager for Hidalgo County Drainage District
No. 1.
Q. Because you were. Correct?
A. Yes, sir.
Q. Serving as district manager?
A. According to my -MR. SHAW: Objection; form.
A. According to my contract, I was serving as a
stipulation that's laying in there.
Q. (BY MR. COWEN) And you said you were not aware
of any actual instances of fraud or you did not have any
reason to suspect that fraud would -- may be occurring.
Correct?

A. Only what I delineated in the form.
Q. So you did not disclose that Integ and Dannenbaum
had been paid for doing the same construction manage
work -- management work?
MR. NEWTON: Objection; form.
MR. SHAW: Objection; form.
Q. (BY MR. COWEN) Correct?
A. We were not doing the same construction
management. I was doing the duties as laid out in my
contract, and Dannenbaum was doing the duties as laid out
in their contract.
Q. And you also did not disclose that a company
owned by your wife or your children had been paid as a
subcontractor. Correct?
A. I had no interest in that company. That was a
corporation in itself.
Q. And you didn't disclose it. Correct?
A. I was complying with what was in my contract.
Q. But you did not disclose it. Correct?
A. I was complying with my contract.
Q. Yes or no, did you disclose -- disclose it?
A. I did not disclose it because it was not in my
contract to do so.
Q. Now, Question No. 8 someone asked -- you were
asked, "If someone were going to steal and cover it up,

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how would they do it?"
Can you read your answer?
A. "Submittal of fraudulent invoices, through
collusion between two district employees with
authorization ability or with a District consultant,
engineer, contractor or supplier."
Q. So one way to steal from the District is to have
someone enter in -- submit invoices that weren't proper.
Correct?
A. Yes, sir.
Q. And weaknesses in the District's internal
controls included the -- "Possible in...accounting"
because "of lack of separation of duties due to small
staff"?
A. Where -- what -Q. No. 11.
A. No. 11. "Possible accounting, lack of separation
of duties due to small staff." That's in 2011, yes, sir.
Q. And, again, on all these fraud questionnaires you
never disclosed that Valley Data, a company owned by your
family, was getting paid as a subcontractor. Correct?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
A. No, I do not disclose because I didn't know at
that time if they were doing work for the District or not.

33 (Pages 129 to 132)

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Q. (BY MR. COWEN) Earlier you testified that
Valley Data paid a variable amount of rent to Integ. What
was the lowest and the highest rent payments you remember?
A. I don't remember.
Q. You don't remember the range of any of them?
A. No, sir.
Q. Hundred thousand?
A. No, sir.
Q. More or less?
A. No, sir.
Q. You have no idea what they were?
A. No, sir.
Q. If we wanted to find out how much those payments
were, where would you look?
A. I'd -- I'd have to go try to find some record or
some check identifying how much they paid.
Q. And where would you go to find those records?
A. Probably to the bank.
Q. Okay. Now, you're -- you have complained that
the District did not provide appropriate insurance for
Integ. Is that correct?
A. I have -MR. SHAW: Objection; form.
A. I have complained that the District has not
complied with certain conditions as stipulated in my

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contract, and one of those conditions has been that the
District has not provided the proof of the insurance that
they were required to provide for me.
Q. What type of -(Simultaneous speaking.)
Q. (BY MR. COWEN) What type of insurance are you
complaining about?
A. Basically the insurance that's delineated in my
contract that they were supposed to provide.
Q. How have you been harmed by not having that
insurance?
A. Basically on the claims that the District has
filed against me, Integ is having to pay for its own legal
defense because there are no insurances that have been
made available to Integ. And TML, which is the insurance
carrier, has sent notice to Integ that there is no carrier
coverage.
Q. What evidence do you have that these claims would
be covered by insurance?
MR. SHAW: Objection; form.
A. I'm not an insurance agent, but in the past, in
other contracts that I've -- or Integ has had, we
presented our contracts to insurance agent and the
insurance agent provides the insurance coverage to protect
any and all claims that are delineated or could come out

out of the contract.
Q. (BY MR. COWEN) And has Integ been sued before
by anyone else?
A. No.
Q. Okay. Do you -- do you have actual knowledge as
to whether or not a -- an insurance policy, as
contemplated by the contract, would cover a lawsuit for
breach of fiduciary duty or for breach of contract?
MR. SHAW: Objection; form.
A. I do not understand the issue because I am not an
insurance agent, and related as it is to fiduciary duty I
do not believe that Integ or myself had a fiduciary duty
because we were never employees of the District. And
related to potential claims, I would leave that up to an
insurance agent to delegate the actual coverages and the
claims that the -- the District might have on us.
Q. (BY MR. COWEN) As the manager of the District,
what steps did you take to make sure that the District
provided the insurance for Integ for your company?
MR. SHAW: Objection; form.
A. The contract indicated that the District would
provide the insurance required as stipulated in the
contract. I never had any doubt that the District would
provide the required insurance as every year I provided a
copy of the insurance requirement that the District had of

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Integ, was required, our general workmen's comp and our
insurance policy, so I gave that to them.
So I gave the District what Integ was required to
give to them and I just trusted the District because I had
been working with them for all these years, and I assumed
that they were providing the coverage that was required
under the contract.
Q. Who do you think got the coverage?
A. Financial officers who I turned over my insurance
requirements to.
Q. Did you ever ask for a -- a declarations page or
a copy of the contract?
A. When I left I asked them for some copies or a
copy of the insurance, which is what I turned over to our
legal counsel, which is what they submitted over to the
TML, and that when we first found out that there was no
coverage, there was no endorsement.
Q. But what I'm asking you is while you were a
District director, did you ever direct anyone to purchase
insurance?
A. I trusted the District.
Q. Did you ever direct anyone to do it?
A. No, I didn't.
Q. Okay. But you were the one running the District.
Right?

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A. I was there for the District as the manager of
the District, and I assumed that everybody had their
responsibilities to do.
Q. Did you ever check to see if the insurance had
been purchased?
A. No, I did not.
Q. And while you were working there, did you ever
ask to see a copy of the -- of a certificate of coverage
or a dec page?
A. No, I did not.
Q. How much in attorneys fees has Integ paid so far?
A. A little over $500,000.
MR. SHAW: Not just to me. Talking, from
the beginning for my -- for the 202.
Q. (BY MR. COWEN) Are there other ways in which you
believe that the District has breached its contract with
Integ?
A. I believe -- and, again, I'm not an
attorney -- but I believe in the way that the District has
publicly relayed itself and has exposed itself and my firm
has been a -- a very tragic experience and not dealing
itself in a very professional manner as to the work that
I've done for the District and dragging myself and my firm
and my reputation and the work I've done for so many years
for the District. I think the District should be very

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ashamed of itself, especially Mr. Ramon Garcia.
Q. Okay.
MR. SHAW: I think the question he's asking
you are really more about the legal claims -Q. (BY MR. COWEN) Yeah, do you -MR. SHAW: -- that you're asserting.
Q. (BY MR. COWEN) Has the -- has -- any other way
that you believe the District has violated the contract -A. I think that's it.
Q. Okay.
A. I'm not an attorney to tell you any of the other
legalities within it, but I think there should be some
clauses in there.
Q. So you don't think the taxpayers have a right to
investigate and question the fact you were paid millions
of dollars to do a part-time job because you had two other
full-time jobs?
MR. SHAW: Objection; form.
MR. NEWTON: Objection; form.
MR. SHAW: You don't have to even answer the
question.
Q. (BY MR. COWEN) You don't think the taxpayers
have a right to investigate and bring this claim?
MR. SHAW: Yeah, you don't need to answer
the question. It's argumentative. I instruct you not to

answer.
Q. (BY MR. COWEN) Have you had any -- or Integ had
any harm due to a lis pendens being filed?
A. Yes.
Q. What harm was that?
A. In the issue regarding moving properties, trying
to sell some properties.
Q. Okay. What properties were you trying to sell?
A. We were trying to generate seen -- some cash to
continue the cost of legal fees.
Q. Okay. And what -- what is the specific sales
that you were unable to close on?
A. We were transferring a contract we had on that
office building that I referred to in Mission.
Q. Okay.
A. And we were unable to proceed until the lis
pendens was cleared up.
Q. Okay.
A. And we are now proceeding with the sale on
that -Q. You are now proceeding with the sale.
A. (Nods.)
Q. Is that correct?
A. Yes, sir.
Q. You have not lost a sale?

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A. We are proceeding. Hopefully we'll close on it.
Q. Has the building lost any value?
A. I don't know.
Q. You can't say the building is worth any less
today than it was a year ago, can you?
A. No, sir.
Q. And the price hasn't changed on the contract, has
it?
A. No, sir.
Q. How much are you selling it for?
A. 400-some-odd thousand.
Q. Who are you selling it to?
A. To some company out of Arkansas.
Q. What's the name of the company?
A. I don't recall offhand.
Q. Do you have any way to show what work
specifically you did on the federal project, like the
itemized, and show how much time you spent?
A. No, sir.
MR. SHAW: Objection; form.
A. No, sir, only the -- the time that's associated
with what's on the calendar and the time that I was out of
the office inspecting the projects.
Q. (BY MR. COWEN) I'd like you to look at
Exhibit 21.

35 (Pages 137 to 140)

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A. (Pause.)
Okay.
Q. What is Exhibit 21?
A. Basically Exhibit 21 is a request that was being
put together by the financial officer regarding an invoice
from Integ for the amount of $83,574.08 regarding the
purchase of assets by the Drainage District from the
County on the Raymondville Drain that S&B Infrastructure
was doing, and two, the request of approval of the budget
amendment in the District general fund of the same amount.
Q. Was this ever actually submitted?
A. According to the notes here, it was not
submitted.
Q. Why not?
A. According to the notes, says, "Lora -- This does
not go on the agenda until we clear on the Raymondville
Drain -- language will not be the same -- as per GG."
Q. Who is GG?
A. Godfrey Garza.
Q. And why did you instruct that this not go on the
agenda?
A. Because apparently the language on the
Raymondville Drain had not been cleared on the board yet,
which would have been the purchase of the assets.
Q. Did the purchase ever happen?

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A. Yes, sir.
Q. Did you ever invoice the District for this money?
A. I invoiced the District.
Q. Did you ever get paid?
A. No.
Q. Did you ever complain about it?
A. That's when I basically left the District.
Q. Okay. Exhibit -- I'm sorry, page 5 of
Exhibit 21, it's handwritten. So keep the same exhibit,
just go to -- one more, another one, right there.
Whose handwriting -- the handwritten part.
A. Okay.
Q. Whose handwriting is that?
A. Not mine.
Q. It's not yours?
A. Huh-uh. Nope. I don't write that good.
Q. On these documents though, it says -- for
department head it says Godfrey Garza, Jr.?
A. Uh-huh.
Q. Yes?
A. Yes, sir.
Q. And did you ever instruct Lora Briones to submit
this invoice?
A. I submitted the invoices to Ms. Briones and then
she is the one that processes the invoices. I don't.

Q. But didn't you tell her not to put it on the
agenda and process it?
MR. SHAW: Objection; form.
A. Until the actual acquisition of the asset was
done.
Q. (BY MR. COWEN) Okay. Did you ever tell her to
process it?
A. I gave instruction based on the memo that's
attached here to wait until that language was clear.
Q. Okay. And after it's cleared, did you ask that
it be done?
A. No, sir.
Q. Why not?
A. But it -- because it said wait until the language
is clear.
Q. Was the language ever clear?
A. Well, the asset was purchased.
Q. Okay.
A. So that means that the language was clear.
Q. Did you ever ask that it be done?
A. She had the invoice in her hand -- or in -- in -if the District had the invoice, they should have
processed the invoice because the instructions they had
was to wait for the language to be cleared.
Q. Did you ever ask that it be put on the agenda at

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an open meeting?
A. No, sir.
Q. Are you sure you did not?
A. It was dis -- it was discussed at an open
meeting.
Q. Okay. And were you the one that asked it be
placed on the agenda?
A. I do not recall.
Q. Okay. Did you place it on the agenda?
A. I do not recall.
Q. The $500,000 you say that had been incurred in
attorneys' fees, is that just for Integ or does that also
include attorneys' fees for you personally?
A. I don't know which -- what the difference is
between me and Integ.
Q. Okay. How about any attorneys' fees for your
wife, your children, or Valley Data? Have those been
separate or is that included in the 500?
A. There, you need to discuss Valley Data with
Valley Data.
Q. Did you ever meet with the prime contractors on
the Phase II project at Lansky & Brats in McAllen?
MR. SHAW: Objection; form.
A. I would meet with numerous people at Lansky &
Brats.

36 (Pages 141 to 144)

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Q. (BY MR. COWEN) Did you ever meet with all the
prime contractors at once?
A. I wouldn't say all of them. I probably met with
40 percent of them.
Q. And -A. 50 percent.
Q. -- would you ever, when you were there at
Lansky & Brats, pull one person or individuals to another
table to talk business in private?
A. If they had some discussions, we would pull aside
from the other group.
Q. If Hugo Gonzalez says he was at progress meetings
where you and Trey were present and there was no one else
from the District present, would you agree or disagree
with that statement?
MR. SHAW: Objection; form.
A. I would agree.
Q. (BY MR. COWEN) Why would Trey be -A. Oh, wait a minute. Excuse me.
I'm sorry. Rephrase the question.
Q. Yeah. Were there progress meetings where you and
your son Trey were present with contractors?
A. What do you mean by con- -- are you talking about
the engineers or are you talking about construction
contractor?

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Q. Either way.
A. Well, one of the -- one of the questions is Trey
would not be present at a meeting with a construction
contractor because I don't think Valley Data did any work
with a construction contractor.
Q. Was Trey ever present at any meetings that you
had with engineers that worked on the project?
A. Yes.
Q. Okay. How many times?
A. I don't know.
Q. More than once?
A. I would say yes.
Q. And the engineers knew that he was your son?
A. Yes, sir.
Q. And they knew that he was owner of Valley Data?
A. Yes, sir.
Q. Do you know who Bernard Nizinsky,
N-I-Z-I-N-S-K-Y, is?
A. Nope.
Q. Or Herman Properties, LLC?
A. Nope.
MR. SHAW: Is that a "no"?
A. No.
Q. (BY MR. COWEN) When did you first learn that
Valley Data was working as a sub on the project?

A. I do not remember.
Q. Do you know what year?
A. No, sir, I don't.
Q. Was it fairly early in the process?
A. I couldn't tell you.
Q. Have you ever been interviewed by the FBI on this
matter?
A. No, sir.
Q. When you and your son Trey met with engineers,
where would you meet?
A. The only time that I remember Trey being at
meetings with engineers was either at functions that we
would have with the elected officials, if they were having
a political function, and Trey would show up there, or
Trey would drop by while we were having a drink there at
Lansky's.
Q. So sometimes you'd be having a drink at Lansky &
Brats steakhouse with engineers that were working on the
project. Correct?
A. Uh-huh.
Q. Yes?
A. Yes.
Q. And your son, Trey, would show up and meet with
you guys?
A. He would be there with a friend of his and he'd

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come by and say hi at the table and go on his merry way.
Q. Okay. And do you know when that happened, that
Trey met with you and engineers at Lansky & Brats?
A. No, sir.
Q. You can't give us a year?
A. No, sir.
Q. An estimate of what year it could have been?
A. It was more than once, so I'm sure it was more
than one year.
Q. And do you have an estimate what years they were?
A. No, sir.
Q. Was Trey ever present at formal progress meetings
with engineers?
A. Not that I recall.
MR. COWEN: I'm think I'm done. I just want
to break to go through my notes, if we can.
THE VIDEOGRAPHER: The time is 3:13. We're
off the record.
(Break.)
THE VIDEOGRAPHER: It's 3:19 and we're back
on the record.
Q. (BY MR. COWEN) Did Integ ever have Atlas & Hall
do any legal work for Integ?
A. No, sir.
Q. Or Steve Crane do any legal work for Integ?

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A. No, sir.
Q. Did you personally have either Atlas & Hall or
Steve Crane do any legal work for you?
A. No, sir.
Q. Did Steve Crane or Atlas & Hall ever do any legal
work for Valley Data?
A. No, sir.
Q. Did Steve Crane or Atlas & Hall ever do any legal
work for your wife or your children?
A. No, sir.
MR. COWEN: Thank you. I'll pass the
witness.
THE WITNESS: I want to -- I want to clarify
one item regarding the -- you made a comment regarding
claims on the insurance. I do have a claim regarding the
insurance on that $84,000 that I haven't gotten paid yet.
MR. SHAW: A claim that you've asserted for
84,000.
THE WITNESS: That I've asserted for 84,000.
MR. SHAW: I think he talked to you about
that. You talked to him about that earlier. But he had
asked -- you had asked him what claims -MR. COWEN: Yeah.
MR. SHAW: -- when he went into all
this stuff --

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MR. COWEN: Yeah, I remember.
MR. SHAW: -- and then I said -MR. COWEN: I know what he's talking about.
MR. SHAW: -- it's the claim. But I just
want to make sure you-all know that is -- it's 84,000, the
lis pendens, and the insurance.
MR. COWEN: Okay.
MR. SHAW: Okay. I don't have anything.
EXAMINATION
BY MR. NEWTON:
Q. Let me ask a few questions, Mr. Garza. Just for
the record, let me introduce myself. I'm John Newton, and
as you know, I represent Valley Data, your sons, Trey and
Jonathan, and your wife, Annie.
Mr. Cowen characterized in a series of questions
what he called meetings that you attended with engineers
that, on occasion, Trey would -- would attend. And I want
to follow that up.
Over what period of time, year span, are we
talking about these meetings occurring?
A. The -- the commissioners, myself, and engineers
would sometimes get together, what we would call a
watering hole, Lansky & Brats was one of them. We would
get together over, I don't know, maybe 12 years, 15 years,
16 years. We would go there during the week. But it was

not set meetings. We show up there on Tuesdays or
Thursdays or Wednesdays, whenever, and the engineers would
show up, and the commissioner would show up. We'd sit
there and have some drinks. On occasions Trey would show
up and he'd be there with his friends, come over to the
table, say hi, sit for a while, and move on his merry way.
Q. All right. So as I understand your answer, these
weren't prescheduled meetings, where there were invitees
of certain engineers or certain commissioners or certain
people?
MR. COWEN: Objection; form, leading.
A. Commission -- some of the commissioners -- one of
the commissioners who would mostly show up would be
Commissioner Hector "Tito" Palacios. Then later on in the
time, Commissioner Joseph Palacios would show up. There
was a couple of times that Jeff Ramon Garcia showed up
there at Lansky. He didn't sit with us, but he showed up
there.
Q. (BY MR. NEWTON) Okay. And I guess my question
is, is this a routine weekly or scheduled meeting or
gathering at a water hole?
A. Well, for me it was. I used to drink. I don't
drink anymore because of my surgery and stuff.
Q. Okay.
A. So usually I'd be there once or twice a week to

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go have a drink, and most of the engineers or people that
wanted to see me would go by and say -- check out and see
if I'm there or not.
Q. All right. And it's during working hours or
after working hours?
A. Again, my hours were fluctuating. Sometimes I'd
be there at 7 o'clock in the evening. Sometimes it would
be at 5 o'clock.
Q. Okay.
A. So there was no specific time.
Q. And so would commissioners show up?
A. Yes, sir.
Q. And would engineers show up?
A. Yes, sir.
Q. And was there any preset agenda that was to be
discussed?
A. It was not an official meeting or anything. It
was just getting together, shoot the breeze, and talk
about what was going on.
Q. If you would have to classify these get-togethers
as -- as business or social, how would you characterize
it?
A. I would classify them more as 20 percent business
and 80 percent social.
Q. Okay. And tell me about the times, if you

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recall, that Trey would show up.
First, was he ever specifically invited to show
up?
A. No, sir. Mostly he would just show up. And I
guess if he was doing work with a consultant, come over
and say hello and -- say hi, and have a drink, and move
on.
Q. Okay. Now, there were times, I imagine, that
business was discussed at -- at these get-togethers?
A. Probably discussions on how the projects were
coming along and the problems they might be having on
projects.
Q. All right. Would -- for example, would there be
multiple engineers there from -- or engineers -representatives from different engineering companies?
A. There would be representatives from different
engineers there, sir.
Q. All right. For example, would you talk about
Dannenbaum business in front of L&G representatives or how
did that occur?
A. Well, you try not to because usually an engineer
didn't want to be talking about his project in front of
another engineer. So you move around to another table and
talk to them about whatever they wanted to talk to.
Q. Okay. And you mentioned Ramon Garcia would show

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REASON

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up?
A. Yes, sir. He showed up a couple of times, but he
basically stuck to himself. Usually he would go over to
the lounge area while your table was being prepared over
in the restaurant area.
Q. And what about the predecessor county judge?
Would he show up?
A. JD would -- Rene would show up there. Rene
Ramirez [phonetic] would show up there also.
Q. Okay. Okay. I think that clarifies it. Thank
you.
MR. SHAW: I don't have anything. Do you
have anything else?
EXAMINATION
BY MR. COWEN:
Q. But you would agree that the engineers knew that
Valley Data was owned by your family. Correct?
A. Yes, sir.
MR. COWEN: I'll pass the witness.
MR. SHAW: All right. We'll reserve our
questions until a later date. Thank you very much.
THE VIDEOGRAPHER: It's 3:25 p.m.. We're
off the record.
(Deposition concluded at 3:26 p.m.)

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SIGNATURE PAGE
I, GODFREY GARZA, JR., have read the foregoing
deposition and hereby affix my signature that same is true
and correct, except as noted on the correction page.

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____________________________
GODFREY GARZA, JR.
THE STATE OF TEXAS )
COUNTY OF _____________ )
Before me ____________________ on this day personally
appeared _____________________ known to me [or proved to
me on the oath of __________________ or through
_____________________ (description of identity card or
other document)] to be the person whose name is subscribed
to the foregoing instrument and acknowledged to me that
he/she executed the same for the purposes and
consideration therein expressed.
Given under my hand and seal of office this ______
day of _______________, 2018.

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__________________________________
NOTARY PUBLIC IN AND FOR
THE STATE OF T E X A S
My Commission Expires:
_______________________

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39 (Pages 153 to 156)

 Page 157
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CAUSE NO. C-0373-17-E
HIDALGO COUNTY DRAINAGE § IN THE DISTRICT COURT OF
DISTRICT NO. 1,
§
§
Plaintiff,
§ HIDALGO COUNTY, TEXAS
§
VS.
§
§
INTEG CORPORATION, ET
§ 275TH JUDICIAL DISTRICT
AL.,
§
§
Defendants.
§
REPORTER'S CERTIFICATION
DEPOSITION OF GODFREY GARZA, JR.
TAKEN JANUARY 24, 2018
I, Tamara Chapman, Certified Shorthand Reporter in
and for the State of Texas, hereby certify to the
following:
That the witness, GODFREY GARZA, JR., was duly sworn
by the officer and that the transcript of the oral
deposition is a true record of the testimony given by the
witness;
That the deposition transcript was submitted on
_________________ to the witness or to the attorney for
the witness for examination, signature and return to
REPUBLIC SERVICES SAN ANTONIO, LLC, by __________________;
That the amount of time used by each party at the
deposition is as follows:
MICHAEL COWEN - 03:17
MICHAEL BLANCHARD - 00:00
ETHAN L. SHAW - 00:00
JOHN W. NEWTON - 00:04

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That pursuant to information given to the deposition
officer at the time said testimony was taken, the
following includes counsel for all parties of record:

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MICHAEL COWEN - REPRESENTING PLAINTIFF
MICHAEL BLANCHARD - REPRESENTING PLAINTIFF
ETHAN L. SHAW - REPRESENTING DEFENDANT
JOHN W. NEWTON - REPRESENTING DEFENDANT
I further certify that I am neither counsel for,

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FURTHER CERTIFICATION UNDER RULE 203 TRCP
The original deposition was/was not returned to the
deposition officer on __________________________;
If returned, the attached Changes and Signature page
contains any changes and the reasons therefor;
If returned, the original deposition was delivered to
MICHAEL COWEN, Custodial Attorney;
That $ ______________ is the deposition officer's
charges to Plaintiff for preparing the original deposition
transcript and any copies of exhibits;
That the deposition was delivered in accordance with
Rule 203.3 and that a copy of this certificate was served
on all parties shown herein and filed with the Clerk.
Certified to by me this _______ day of
__________________, 2018.

__________________________________
Tamara Chapman, CSR, CRR, RPR
Texas Cert #7248 (Exp. 12/31/18)
Republic Services San Antonio LLC
12108 Radium Street
San Antonio, TX 78216
Telephone: 210-298-6300
Fax: 210-298-6303
Firm Reg. No. 563

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action in which this proceeding was taken, and further
that I am not financially or otherwise interested in the
outcome of the action.
Further certification requirements pursuant to Rule
203 of TRCP will be certified to after they have occurred.
Certified to by me this 25th day of January, 2018.

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__________________________________
Tamara Chapman, CSR, CRR, RPR
Texas Cert #7248 (Exp. 12/31/18)
Republic Services San Antonio LLC
12108 Radium Street
San Antonio, TX 78216
Telephone: 210-298-6300
Fax: 210-298-6303
Firm Reg. No. 563

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40 (Pages 157 to 159)
related to, nor employed by any of the parties in the