Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL NO. C-0373-17-E 2 3 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 4 VS. 5 INTEG CORPORATION, ET AL. * * * * * * * 275TH DISTRICT COURT OF HIDALGO COUNTY, TEXAS 6 7 --------------------------------------------------ORAL/VIDEOTAPED DEPOSITION OF 8 9 LOUIS HAROLD JONES, JR. 10 11 January 10, 2018 --------------------------------------------------- 12 Oral/Video deposition of LOUIS HAROLD JONES, JR., 13 produced as a witness at the instance of the 14 Plaintiff, and duly sworn, was taken in the above15 styled and numbered cause on the 10th day of January, 16 2018, from 9:10 a.m. to 10:13 a.m. before GERALD 17 SMITH, CSR in and for the State of Texas, reported 18 by oral stenography at the offices of 19 Cowen Mask Blanchard, 3900 N. 10th Street, Suite 20 1080, McAllen, Hidalgo County, Texas, pursuant to the 21 Texas Rules of Civil Procedure and the provisions 22 stated on the record or attached hereto. 23 24 25 Republic Services San Antonio LLC Exhibit D 1 of 54 Page: 1 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A P P E A R A N C E S 2 FOR THE PLAINTIFF: 3 4 5 6 MR. MICHAEL J. BLANCHARD Cowen Mask Blanchard 6243 IH 10 West, Suite 801 San Antonio, Texas 78201 T: (210) 941-1301 efilings@cmbtrial.com 7 8 9 FOR THE DEFENDANT, INTEG CORPORATION AND GODFREY GARZA, JR.: 10 11 12 13 MR. MARCUS C. BARRERA Barrera, Sanchez & Associates 10113 North 10th Street, Suite A McAllen, Texas 78504 T: (956) 287-7555 marcus@bsmlawyers.com 14 15 16 FOR THE DEFENDANT, VALLEY DATA COLLECTION SPECIALIST, INC., ANNIE GARZA, GODFREY GARZA, III AND JONATHAN GARZA: 17 18 19 20 MR. JOHN W. NEWTON, III Roach & Newton, LLP One Westchase Center 10777 Westheimer Road, Suite 212 Houston, Texas 77042 T: (713) 652-2031 jnewton@roachnewton.com 21 22 23 24 25 MR. DENNIS RAMIREZ Law Office of Dennis Ramirez 111 N. 17th Street, Suite D Donna, Texas 78537 T: (956) 461-2890 dramirezlaw@gmail.com Republic Services San Antonio LLC Exhibit D 2 of 54 Page: 2 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL FOR THE WITNESS, LOUIS JONES, JR.: 2 3 4 5 MR. RICHARD D. DEUTSCH McGuireWoods, LLP 600 Travis Street, Suite 7500 Houston, Texas 77002 T: (832) 214-9945 rdeutsch@mcguirewoods.com 6 7 8 9 10 MR. J.A. “TONY” CANALES Canales & Simonson, PC 2601 Morgan Avenue (78405) P. O. Box 5624 Corpus Christi, Texas 78465-5624 T: (361) 883-0601 tonycanales@canalessimonson.com 11 12 ALSO PRESENT: 13 14 MS. LORA BRIONES MR. ANTHONY ROGERS, Videographer 15 16 COURT REPORTER: GERALD SMITH, C.S.R. 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D 3 of 54 Page: 3 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL I N D E X 2 3 Appearances .................................. 2 Stipulations ................................. 7 Examination by Mr. Blanchard ................. 10 Signature and Changes ........................ 42 Reporter’s Certificate ....................... 44 Return Certificate ........................... 48 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D 4 of 54 Page: 4 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 E X H I B I T S 2 NO. DESCRIPTION MARKED 3 4 No. 1 5 No. 2 6 7 No. 3 8 No. 4 9 10 No. 5 11 12 No. 6 13 14 No. 7 15 ..................................... Consulting Services Agreement (VD 00448-00460) ..................................... Consulting Services Agreement (VD 00423-00446) ..................................... Consulting Services Agreement (VD 00403-00422) ..................................... Consulting Services Agreement (VD 00381-00402) ..................................... HCDD No. 1 Agreement for Professional Services with Dannenbaum Engineering (64 pgs) ..................................... HCDD No. 1 Agreement for Professional Services with Dannenbaum Engineering (HCDD - 000020-83 pgs) ..................................... Valley Data Collection Specialists Invoice 355 & 359 (VD 00379-00380) 20 20 20 20 23 24 24 16 (No Exhibits marked 8-12) 17 No. 13 18 19 20 No. 14 ..................................... DIG-TESS Locate Requests (VD 00461-00370) ..................................... 9/3/10 - Letter from L. Jones Re: Submittal of Final Project Documents (Integ 00200-00201) 24 24 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D 5 of 54 Page: 5 Deposition of Louis Jones 1 No. 15 2 No. 16 3 4 5 No. 17 6 No. 18 7 8 9 No. 19 10 11 12 No. 20 13 14 No. 21 15 16 17 No. 22 18 19 No. 23 20 21 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL ..................................... Correspondence Re: 4/7/09 Quantity Resolution Meeting (3 pgs) ..................................... 12/18/07 Check #00001266 $631,693.25 for WA#2, WA#3 and WA#4 Levee Improvement Project (HCDD1 - 001130-001149) ..................................... Valley Data Invoice #359 (HCDD1 - 001150-001151) ..................................... 4/1/08 Check #00001304 $397,826.48 Levee System WA #3-WA#10 (HCDD1 - 010042-010057) ..................................... 6/3/08 Check #00001316 $34,129.11 Levee Task Order #10, Work Authorization #6 (HCDD1 - 010279-010282) ..................................... 3/18/08 Check #00001299 $300,310.78 Levee System WA#2, WA#3 & WA#4 (HCDD1 - 009706-009715) ..................................... 1/30/08 Check #00001280 $196,358.90 Levee System WA#3 & WA#4 (HCDD1 - 009606-009622) ..................................... 4/7/08 Check #00001307 $547,790.29 Levee System WA#2-WA#10 (HCDD1 - 007797-007812) ..................................... 7/1/08 Check #00001328 $17,407.95 Levee Work Authorization #6 (HCDD1 - 010367-010378) 25 26 27 30 31 31 31 31 31 22 23 24 25 Republic Services San Antonio LLC Exhibit D 6 of 54 Page: 6 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Oral/Videotaped deposition and answers of LOUIS 2 HAROLD JONES, JR., who resides in Hidalgo County, 3 Texas, was taken herein by Michael Blanchard, Counsel 4 for the Plaintiff, before Gerald Smith, a Certified 5 Shorthand Reporter in and for the State of Texas, on 6 the 10th day of January, A.D., 2018, pursuant to the 7 Notice issued in the above styled and numbered cause, 8 pursuant to the Texas Rules of Civil Procedure and 9 with the following stipulations and agreements: 10 IT WAS AGREED that no objections need be made by 11 any Party at the time of taking of said deposition; 12 except objections as to leading, form of the 13 question, or the responsiveness of the answer, which 14 if not made during the deposition are waived; but if 15 and when said deposition, or any portion thereof, is 16 offered in evidence at the trial of this cause by any 17 party thereto, it shall be subject to any and all 18 other legal objections, such objections to be made at 19 the time of the tender, the same as though the 20 witness were on the stand personally testifying. 21 IT WAS FURTHER AGREED that the witness must 22 appear in accordance with the Texas Rules of Civil 23 Procedure before any Notary Public or official 24 authorized to administer oaths, for purpose of 25 reading over the deposition and making any Republic Services San Antonio LLC Exhibit D 7 of 54 Page: 7 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 corrections the witness finds to be necessary, such 2 corrections to be recorded on a correction sheet 3 submitted with the original of the deposition. 4 IT WAS FURTHER AGREED by and between Counsel 5 that following delivery of the original deposition 6 herein by the officer to the deponent, for the 7 purpose of signature by deponent, said original 8 deposition shall be returned directly to the court 9 reporter, GERALD SMITH, within twenty (20) days 10 following receipt of same, together with any 11 corrections, additions or changes thereto, at which 12 time the reporter will file a Return Certificate with 13 the Clerk and deliver the signed original deposition 14 to the custodial attorney, Michael Blanchard. 15 IT WAS FURTHER AGREED that should the original 16 deposition herein fail to be returned, signed and 17 notarized, ten (10) days prior to the date of trial 18 in this cause, or prior to any appropriate hearing 19 herein, a certified copy of same may be used herein 20 for all purposes, as though it were the signed 21 original, upon proper notice to opposing Counsel. 22 IT WAS FURTHER AGREED that after said deposition 23 has been returned, in accordance with these 24 stipulations and agreements, it will be treated by 25 the parties hereto and may be used herein with the Republic Services San Antonio LLC Exhibit D 8 of 54 Page: 8 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 same force and effect as though all statutes and 2 rules relating to the taking and returning of 3 depositions had been fully complied with. 4 5 * * * 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D 9 of 54 Page: 9 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 2 VIDEOGRAPHER: LOUIS H. JONES, JR., having been first duly sworn, testified as follows: 5 6 The time is 9:10. 3 4 On the record. E X A M I N A T I O N BY MR. BLANCHARD: 7 Q Good morning. 8 A Morning. 9 Q What is your full name? 10 A Louis Harold Jones, Jr. 11 Q Mr. Jones, my name is Mike Blanchard. I 12 represent the Hidalgo County Drainage District No. 1 13 in a lawsuit it filed against Godfrey, Integ 14 Corporation, and others. Do you understand that? 15 A Yes. 16 Q Have you ever given a deposition before? 17 A No. 18 Q Okay. So if you would answer in "yeses" or 19 "nos", instead of "uh-huhs" or "huh-uhs", that would 20 help a great deal to keep a clear record, okay? 21 A Okay. 22 Q So if I remind you to do that, I'm not 23 trying to be cross with you. 24 sure we get a clear record. 25 you? Republic Services San Antonio LLC I'm just trying to make Is that all right with Exhibit D Page: 10 10 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A Yes. 2 Q I may ask you to speak up from time to time, 3 and that's the same rule, just so the video can 4 capture your voice clearly, okay? 5 A Okay. 6 Q If you don't understand a question that I 7 ask, will you please let me know so that I can ask it 8 in a different way. 9 A Okay. 10 Q All right. 11 A I'm employed with Dannenbaum Engineering 12 How are you currently employed? Corporation. 13 Q What's your current title? 14 A I'm a principal with the firm. 15 Q How long have you been a principal with the 16 17 firm? A I don't even know, to tell you the truth. 18 I've been with the firm 38 years, so probably been a 19 principal maybe 25. 20 21 22 23 Q I don't know the exact time. And were you always employed by the entity called Dannenbaum Engineering McAllen, LLC? A No. I'm actually employed by Dannenbaum Engineering Corporation. 24 Q Okay. 25 A Correct. Republic Services San Antonio LLC That's your employer? Exhibit D Page: 11 11 of 54 Deposition of Louis Jones 1 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL So you don't have -- you don't get pay or 2 any other benefits from Dannenbaum Engineering 3 McAllen, LLC? 4 A Correct. 5 Q Okay. 6 Dannenbaum Engineering McAllen, LLC has an office in McAllen, is that true? 7 A Correct. 8 Q Are the -- are there people in that office 9 10 11 that are employed by Dannenbaum Engineering McAllen? A No. They're all employed by Dannenbaum Engineering Corporation. 12 Q Okay. 13 A Some of them may be independent employers, 14 but, I mean, they're basically employed by Dannenbaum 15 Engineering Corporation. 16 17 18 Q Okay. So Dannenbaum Engineering McAllen doesn't employ anybody? A No. Dannenbaum Engineering McAllen, LLC is 19 wholly owned by a holding company which also owns 20 Dannenbaum Engineering Corporation. 21 22 Q Okay. But, at any rate, it doesn't have any employees, is that true? 23 A Correct. 24 Q Okay. 25 Do you have any -- I'm sure you do, so can you tell us your degrees and certifications Republic Services San Antonio LLC Exhibit D Page: 12 12 of 54 Deposition of Louis Jones 1 2 3 4 5 6 7 8 9 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL that you hold? A I've got a bachelor of science in civil engineering from Lamar University in Beaumont. Q Okay. And do you have any certifications, licenses, or anything -A Yeah, I have a professional engineering license in the state of Texas. Q Okay. And along with being a professional engineer, there are certain ethical obligations you 10 have to comply with, even at a deposition setting, is 11 that true? 12 A Yes. 13 Q And you're familiar with those ethical 14 15 16 17 18 obligations? A I think I am, but I wouldn't say that I'm a hundred percent. Q I'm not gonna ask you to recite anything. just want to kind of know -- 19 A Yeah. 20 Q -- if you're familiar that there are these 21 ethical obligations that do apply in a deposition 22 setting. 23 I A You are, is that true? I guess so. I don't know the -- I couldn't 24 quote them, so -- I know what our ethical 25 requirements are from practicing engineering, but Republic Services San Antonio LLC Exhibit D Page: 13 13 of 54 Deposition of Louis Jones 1 2 3 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL sitting in a deposition, other than I'm under oath -Q You're not familiar with anything beyond what you just talked about? 4 A Correct. 5 Q Okay. 6 7 What type of work does Dannenbaum Engineering do? A We do civil engineering work. Our basic 8 practice is public works, transportation, and land 9 development. 10 11 12 13 14 15 16 Q And can you tell the jury what civil engineering is? A It's -- it's the engineering of civil infrastructure. Q So what does that mean, and kind of in layman's terms -A It can be roads, bridges, subdivisions, wall 17 -- like we did the levee wall for -- for the drainage 18 district, outfall ditches, which we had a contract 19 with the drainage district on that; construction 20 management and inspection, which we do. 21 Q So, basically -- 22 A Like landfills, any kind of -- any kind of 23 infrastructure type work; some buildings, but we're 24 -- we're primarily a horizontal company, not a 25 vertical company. Republic Services San Antonio LLC Exhibit D Page: 14 14 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 Q Okay. 2 A We do vertical work, but it's mostly we do 3 horizontal. 4 Q 5 6 Can you explain what the difference between vertical and horizontal work is? A Vertical would be like a big tall building 7 like this, versus horizontal would be designing that 8 roadway out there. 9 Q And so -- 10 A Or doing a water plant, sewer plant, things 11 12 13 like that. Q So civil engineering is the design of those structures, is that true? 14 A Correct. 15 Q And then Dannenbaum also does non- 16 engineering things, like construction management, is 17 that true? 18 19 20 21 A Correct, but not construction, just construction management and inspection. Q Understood. Dannenbaum does not, you know, have people in backhoes, and cranes -- 22 A Correct. 23 Q -- and things like that? 24 A Correct. 25 Q And just so -- the other thing I didn't Republic Services San Antonio LLC Exhibit D Page: 15 15 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 mention, in order for him to take down everything, 2 it's not like a normal conversation where we can 3 finish each other's sentences. 4 to get my whole question out before you start 5 answering. 6 A Okay. 7 Q Is that all right? 8 A Uh-huh. 9 Q Okay. So please wait for me So Dannenbaum doesn't do the physical 10 construction work that other companies would do with 11 cranes, backhoes, those kinds of things, is that 12 true? 13 A Correct. 14 Q But it sort of oversees the people that's 15 doing that work sometimes, is that true? 16 A Yeah. 17 Q Okay. 18 A And we make -- I mean, we make sure that the 19 contractor builds the project according to the 20 approved plans and specifications. 21 Q Is it true that in every Dannenbaum 22 Engineering contract that Dannenbaum had with the 23 district, that construction management was a feature 24 of those contracts. 25 A I guess I need to read this into the -- Republic Services San Antonio LLC Exhibit D Page: 16 16 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 Q Sure. 2 A -- record, if it's okay. I will do my best 3 to fully cooperate, however, as you know, my ability 4 to do so is limited. 5 subject of an FBI criminal investigation, the breadth 6 of which is uncertain. 7 you, since I do not know the range of the 8 investigation, I may not be able to fully answer 9 questions in this deposition, as anything I say may I've learned that I am the As my lawyer has explained to 10 be used to incriminate me in the criminal proceeding. 11 So in that regard, on advice of my counsel, I invoke 12 the Fifth Amendment Privilege against self- 13 incrimination and respectfully decline to answer. 14 Q Understood. And I'm not -- and I respect 15 your constitutional rights, and I'm going to be 16 respectful of them throughout this deposition, okay? 17 A Okay. 18 Q I'm still gonna have to ask you the 19 questions. 20 A Yes, sir. 21 Q And so whenever you want to invoke your 22 Fifth Amendment right, you can just say you're 23 invoking your Fifth Amendment -- 24 A Okay. 25 Q -- right; is that okay? Republic Services San Antonio LLC Exhibit D Page: 17 17 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A Yes, sir. 2 Q Have you ever heard of Valley Data 3 Collection Systems, Inc.? 4 A I have to invoke the Fifth. 5 Q Okay. 6 MR. BLANCHARD: Rich, I'm not gonna get 7 into an argument with you here about it, but I don't 8 think that's a -- you know, appropriate to invoke the 9 Fifth on that, but would you reconsider your position 10 on that? 11 MR. DEUTSCH: 12 13 Q (Mr. Blanchard) No, we do not reconsider. Okay. Has Dannenbaum Engineering ever hired Valley Data? 14 A Invoke the Fifth. 15 Q What type of work does Valley Data do? 16 A Invoke the Fifth. 17 Q How many times had Dannenbaum hired Valley 18 Data? 19 A Invoke the Fifth. 20 Q Did you ever speak with a Valley Data 21 representative about the work it was doing for 22 Dannenbaum? 23 A Invoke the Fifth. 24 Q Did you ever talk to Godfrey Garza about the 25 work Valley Data did for Dannenbaum? Republic Services San Antonio LLC Exhibit D Page: 18 18 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A Invoke the Fifth. 2 Q Did Dannenbaum ever hire Valley Data to work 3 on projects that were not Hidalgo County Drainage 4 District projects? 5 A Invoke the Fifth. 6 Q Who negotiated the terms of the contracts 7 between Dannenbaum and Valley Data? 8 A Invoke the Fifth. 9 Q How was Valley Data paid, in other words, by 10 the hour or by the job? 11 A Invoke the Fifth. 12 Q Going back to the structure of Dannenbaum, 13 did Dannenbaum have people that could do the same 14 type of work that Valley Data did? 15 A Invoke the Fifth. 16 Q I'm gonna try and capture this in one 17 question so you don't have to keep doing it per 18 question, but can you explain to me the complete time 19 line of Dannenbaum association with Valley Data? 20 A Invoke the Fifth. 21 Q What is Valley Data's reputation in the 22 engineering and construction communities? 23 A Invoke the Fifth. 24 Q Did you ever tell Judge Garcia that Godfrey 25 didn't do any work on certain projects? Republic Services San Antonio LLC Exhibit D Page: 19 19 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A Invoke the Fifth. 2 Q I've got copies of contracts between 3 Dannenbaum and Valley Data. 4 your Fifth Amendment rights and not discuss those 5 contracts? Are you going to invoke 6 A Yes. 7 Q Okay. 8 A Invoke the Fifth. 9 Q And just so the record is clear, I'm going 10 to attach them as Exhibits -- 11 MR. DEUTSCH: 12 MR. BLANCHARD: 13 (Exhibits No. 1 through 4 were marked) 14 Q (Mr. Blanchard) Are these all copies? Yes. All right. So I'm gonna 15 show you Exhibits 1 through 4. 16 few questions to kind of make a record about this, 17 okay? 18 copies of contracts between Dannenbaum and Valley 19 Data? I've got to ask you a Are Exhibits 1 through 4 true and correct 20 A Invoke the Fifth. 21 Q Why did Dannenbaum hire Valley Data? 22 A Invoke the Fifth. 23 Q Valley Data -- I'm sorry -- Dannenbaum hired 24 Valley Data so that it would gain an advantage in 25 getting work from Godfrey Garza; isn't that true? Republic Services San Antonio LLC Exhibit D Page: 20 20 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 MR. NEWTON: 2 MR. BARRERA: 3 A Objection, form. Objection, form. Invoke the Fifth. 4 MR. DEUTSCH: 5 when you hear objections -- 6 WITNESS: 7 MR. DEUTSCH: By the way, I'm sorry, Oh. -- let the objections come 8 out, and you still have to answer the question. 9 just wait until they're done, and then you answer the 10 question. 11 just let them make the objection. So when they object is when you stop, you 12 13 14 WITNESS: Q So Oh, okay. (Mr. Blanchard) Have you ever heard of something called Godfrey's game? 15 A Invoke the Fifth. 16 Q Why did Dannenbaum hire or associate with 17 Dos Logistics in the federal levee rehabilitation 18 projects? 19 A Invoke the Fifth. 20 Q After a certain point, Dannenbaum no longer 21 hired Valley Data directly and used Dos Logistics to 22 hire Valley Data, is that true? 23 A Invoke the Fifth. 24 Q In fact, Dannenbaum had people that were 25 qualified and had the expertise necessary to do the Republic Services San Antonio LLC Exhibit D Page: 21 21 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL work that Dos Logistics did; isn't that true? 2 3 MR. NEWTON: argumentative. Objection, form. That's Objection, form. 4 Q (Mr. Blanchard) 5 A Invoke the Fifth. 6 Q Did Godfrey Garza do construction management You can answer. 7 for any of the projects that Dannenbaum worked on for 8 the district between 2003 to 2014? 9 A Invoke the Fifth. 10 Q Have you had any conversations with 11 commissioners or district board members about 12 Godfrey Garza? 13 A Invoke the Fifth. 14 Q Do you understand or do you have an 15 understanding as to why the district decided to pay 16 Godfrey Garza for construction management? 17 A Invoke the Fifth. 18 Q When did you first meet Godfrey Garza? 19 A Invoke the Fifth. 20 Q How did you meet him, and in what capacity? 21 A Invoke the Fifth. 22 Q Does Godfrey Garza have any degrees or 23 certifications that you know of? 24 A Invoke the Fifth. 25 Q Was Godfrey Garza qualified to do Republic Services San Antonio LLC Exhibit D Page: 22 22 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL construction management? 2 A Invoke the Fifth. 3 Q Do you know Trey Garza? 4 A Invoke the Fifth. 5 Q What is your understanding of the roles that 6 Annie Garza played in the Valley Data organization? 7 A Invoke the Fifth. 8 Q What is your understanding about the role 9 10 that Trey Garza played in the Valley Data organization? 11 A Invoke the Fifth. 12 Q What is your understanding about the role 13 Jonathan Garza played in the Valley Data 14 organization? 15 A Invoke the Fifth. 16 Q Did Annie Garza ever submit invoices to 17 Dannenbaum for Valley Data? 18 A Invoke the Fifth. 19 Q Did Godfrey Garza ever mention that Valley 20 21 Data needed to be paid for something? A Invoke the Fifth. 22 23 (Exhibit No. 5 was marked) Q (Mr. Blanchard) I'm gonna show you what I 24 marked as Exhibit No. 5. 25 correct copy of an agreement between Dannenbaum and Republic Services San Antonio LLC Is Exhibit No. 5 a true and Exhibit D Page: 23 23 of 54 Deposition of Louis Jones 1 2 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL the Hidalgo County Drainage District No. 1? A Invoke the Fifth. 3 (Exhibit No. 6 was marked) 4 Q 5 No. 6. 6 an agreement between Dannenbaum and the Hidalgo 7 County Drainage District No. 1? 8 A (Mr. Blanchard) I'm gonna show you Exhibit Is Exhibit No. 6 a true and correct copy of Invoke the Fifth. 9 (Exhibit No. 7 was marked) 10 Q 11 No. 7. 12 invoices that Valley Data sent to Dannenbaum? (Mr. Blanchard) I'm gonna show you Exhibit Is Exhibit No. 7 a true and correct copy of 13 A Invoke the Fifth. 14 Q How much money did Dannenbaum pay Valley 15 16 Data over -- between 2000 and 2014? A Invoke the Fifth. 17 18 19 (Exhibit No. 13 was marked) Q No. 13. (Mr. Blanchard) I'm gonna show you Exhibit Do you know what that document is? 20 A Invoke the Fifth. 21 Q Are you willing to answer any questions 22 23 about the contents of that document? A Invoke the Fifth. 24 25 (Exhibit No. 14 was marked) Q (Mr. Blanchard) Republic Services San Antonio LLC I'm gonna show you Exhibit Exhibit D Page: 24 24 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 No. 14. 2 a letter sent from Dannenbaum to the Drainage 3 District No. 1? Is Exhibit No. 14 a true and correct copy of 4 A Invoke the Fifth. 5 Q Does Exhibit No. 14 expressly state that 6 Dannenbaum was responsible for construction 7 management? 8 A Invoke the Fifth. 9 Q Did Dannenbaum do construction management 10 11 for the projects referenced in Exhibit No. 14? A Invoke the Fifth. 12 13 14 (Exhibit No. 15 was marked) Q No. 15. (Mr. Blanchard) I'm gonna show you Exhibit Do you recognize that document? 15 A Invoke the Fifth. 16 Q Exhibit No. 15 includes a true and correct 17 copy of a letter from Dannenbaum, is that true? 18 A Invoke the Fifth. 19 Q The contents of Exhibit No. 15 reflect the 20 construction management work that Dannenbaum was 21 doing, is that true? 22 A Invoke the Fifth. 23 Q What is topography? 24 A Excuse me? 25 Q What is topography? Republic Services San Antonio LLC Exhibit D Page: 25 25 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A 2 the ground. 3 Q 4 Topography? It's, basically, elevations of And are there times when surveyors need topography studies? 5 A Invoke the Fifth. 6 Q Did Valley Data do any actual topography 7 work for Dannenbaum? 8 A Invoke the Fifth. 9 (Exhibit No. 16 was marked) 10 Q (Mr. Blanchard) I'm gonna show you Exhibit 11 No. 16. 12 copies of checks issued from Hidalgo County Drainage 13 District No. 1 to Dannenbaum? Does Exhibit No. 16 include true and correct 14 A Invoke the Fifth. 15 Q Included in the invoices that Dannenbaum 16 sent to the district are charges for services that 17 were performed by Valley Data, is that true? 18 A Invoke the Fifth. 19 Q Are you aware of at any time that an 20 employee of the district did work on behalf of Valley 21 Data? 22 A Invoke the Fifth. 23 Q Do you know Asael Pecina? 24 A Invoke the Fifth. 25 Q Is it true that Asael Pecina actually did Republic Services San Antonio LLC Exhibit D Page: 26 26 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL work for Valley Data? 2 MR. NEWTON: 3 MR. BLANCHARD: 4 MR. NEWTON: 5 MR. BLANCHARD: 6 MR. NEWTON: 7 question. The basis is -Go ahead, John. Go ahead. MR. BLANCHARD: Q What's the basis? Reask the I'll reobject. 8 9 Objection, form. (Mr. Blanchard) Okay. Are you aware of people 10 employed by the district, included but not limited to 11 Asael Pecina, doing work for Valley Data? 12 MR. NEWTON: 13 A Invoke the Fifth. 14 Q (Mr. Blanchard) Objection. Okay. It's vague. Are you aware of 15 Asael Pecina drafting meets and bounds descriptions 16 that were then used by Valley Data to get paid for 17 work from Dannenbaum? 18 19 MR. NEWTON: Objection, form; it's vague. 20 MR. BLANCHARD: 21 basis. 22 Q (Mr. Blanchard) 23 A Invoke the Fifth. 24 25 I didn't ask for the You can answer. (Exhibit No. 17 was marked) Q (Mr. Blanchard) Republic Services San Antonio LLC I'm gonna show you Exhibit Exhibit D Page: 27 27 of 54 Deposition of Louis Jones 1 No. 17. HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Do you recognize that document? 2 A Invoke the Fifth. 3 Q Exhibit No. 17 includes a true and correct 4 copy of an invoice that Valley Data sent to 5 Dannenbaum; is that true? 6 A Invoke the Fifth. 7 Q The invoice that's included in Exhibit 17 8 included work that Valley Data didn't actually do, is 9 that true? 10 A Invoke the Fifth. 11 Q What is surveying, as it pertains to your 12 line of work? 13 A Surveying is, in our line of work, 14 identifying existing topography, as you mentioned 15 earlier, elevations, meets and bounds for property 16 acquisition type work; basically, describing the 17 existing terrain and existing infrastructure that 18 might be within that corridor that we may be looking 19 at. 20 Q Including boundary lines; is that true? 21 A Correct. 22 Q So surveyors identify boundary lines, 23 provide meets and bounds descriptions of land 24 parcels, true? 25 A Correct. Republic Services San Antonio LLC Exhibit D Page: 28 28 of 54 Deposition of Louis Jones 1 2 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Provide topography information about the parcel, is that true? 3 A Correct. 4 Q And include terrain features and 5 infrastructure features that's on the -- 6 A Correct. 7 Q -- parcel, true? 8 A Correct. 9 Q What kind of certifications would I need if 10 I wanted to do surveying work? 11 A Invoke the Fifth. 12 Q Valley Data did not employ anybody with the 13 proper certifications to do surveying work; isn't 14 that true? 15 A Invoke the Fifth. 16 Q Trying to cut down on the number of things 17 -- documents I ask you about, so I apologize for the 18 delay, but -- 19 A Okay. 20 21 MR. BLANCHARD: questions? 22 23 MR. NEWTON: Are you passing the witness? 24 25 Do you guys have any MR. BLANCHARD: Well, if I can come back after you guys are done, just so I don't waste time. Republic Services San Antonio LLC Exhibit D Page: 29 29 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 MR. NEWTON: 2 MR. BLANCHARD: 3 VIDEOGRAPHER: 4 Off the record. The time (OFF THE RECORD)(9:37-9:57) 6 VIDEOGRAPHER: On the record. The time is 9:57. 8 Q 9 break. 10 A Yes, sir. 11 Q All right. (Mr. Blanchard) We're back after a short Are you okay to continue? 12 13 Okay. is 9:37. 5 7 Why don't we take a break? (Exhibit No. 18 was marked) Q (Mr. Blanchard) I'm gonna show you Exhibit 14 No. 18, and I'll represent to you that that's a check 15 from Hidalgo County Drainage District No. 1 to 16 Dannenbaum and the underlying data supporting that. 17 Is Exhibit No. 18 a true and correct copy of a check 18 to Dannenbaum and the underlying invoices and backup 19 for the check? 20 A Invoke the Fifth. 21 Q May I see it for just a second? 22 A Sure. 23 Q To the extent that Exhibit No. 18 includes 24 invoices for preliminary engineering, including 25 surveying services, some of those surveying services Republic Services San Antonio LLC Exhibit D Page: 30 30 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL would have been done by Valley Data, is that true? 2 A Invoke the Fifth. 3 Q And Dannenbaum would not have hired Valley 4 5 Data unless Godfrey Garza wanted it to, is that true? A Invoke the Fifth. 6 7 (Exhibits No. 19 through 23 were marked) 8 9 NOTE: Mr. Dennis Ramirez entered the room and was present for the remainder of the 10 deposition. 11 Q (Mr. Blanchard) 12 19 through 23. 13 Exhibits 19 to 23? I'm gonna show you Exhibits Have you had a chance to look at 14 A Yes, sir. 15 Q Are Exhibits 19 to 23 -- or rather do those 16 exhibits include checks from the Drainage District 17 No. 1 to Dannenbaum? 18 A Invoke the Fifth. 19 Q And do those exhibits also contain invoices 20 supporting those checks and other backup material 21 that would support the invoices? 22 A Invoke the Fifth. 23 Q Some of those invoices include work that was 24 25 supposedly done by Valley Data, is that true? A Invoke the Fifth. Republic Services San Antonio LLC Exhibit D Page: 31 31 of 54 Deposition of Louis Jones 1 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL So Valley Data would have received a portion 2 of the money that's identified in Exhibits 18 to 23, 3 is that true? 4 5 6 MR. NEWTON: Would you repeat the question, please? Q (Mr. Blanchard) Valley Data would have been 7 paid at least a portion of the money that's reflected 8 in Exhibits 18 to 23, is that true? 9 10 MR. NEWTON: Objection, form. It's speculative. 11 MR. BLANCHARD: John -- okay. 12 A I'm gonna have to invoke the Fifth. 13 Q (Mr. Blanchard) Okay. As a principal of 14 Dannenbaum, you are familiar with the entity's 15 financial procedures, is that true? 16 A Invoke the Fifth. 17 Q As the principal -- as a principal of 18 Dannenbaum, you know which subcontractors worked on 19 both the laterals and the federal levee project, is 20 that true? 21 A Invoke the Fifth. 22 Q As the -- as a principal of Dannenbaum, you 23 personally know what work, if any, that Valley Data 24 did on any work on any project related to the 25 Drainage District No. 1, is that true? Republic Services San Antonio LLC Exhibit D Page: 32 32 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 A Invoke the Fifth. 2 Q With respect to the checks that are in 3 Exhibits 19 to 23, to the extent Valley Data was paid 4 any money, Dannenbaum would not have paid that money 5 unless Godfrey Garza had told Dannenbaum to hire 6 Valley Data, is that true? 7 A Invoke the Fifth. 8 MR. BARRERA: 9 MR. NEWTON: 10 Q Objection, form. (Mr. Blanchard) Everybody is objecting. Do you know whether the 11 contracts that Dannenbaum had with the Drainage 12 District No. 1 required Dannenbaum to disclose the 13 subcontractors it was using on the drainage district 14 projects? 15 A Invoke the Fifth. 16 Q Did Dannenbaum disclose all of the 17 subcontractors it used on district projects? 18 A Invoke the Fifth. 19 Q Did Dannenbaum have a business relationship 20 with Valley Data? 21 A Invoke the Fifth. 22 Q Did Dannenbaum have a business relationship 23 with Annie Garza, Jonathan Garza, Trey Garza, or 24 Godfrey Garza, Jr.? 25 A Invoke the Fifth. Republic Services San Antonio LLC Exhibit D Page: 33 33 of 54 Deposition of Louis Jones 1 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Dannenbaum has done a great many projects 2 that were funded in part by the federal government, 3 is that true? 4 A Invoke the Fifth. 5 Q Dannenbaum helped draft the grant 6 application that ultimately resulted in the district 7 getting funds toward the border wall levee project, 8 is that true? 9 A Invoke the Fifth. 10 Q You, personally, went to Washington, D.C. to 11 sort of lobby in support of the project, is that 12 true? 13 A Invoke the Fifth. 14 Q Did you have discussions with Godfrey Garza, 15 Jr. about getting the engineering contract that would 16 result from the federal grant application being 17 approved? 18 A Invoke the Fifth. 19 Q Did Godfrey Garza ever tell you before the 20 contract was approved that Dannenbaum would get the 21 engineering contract for the federal levee project? 22 A Invoke the Fifth. 23 Q When did you find out the district was going 24 25 to get the DHS grant? A Invoke the Fifth. Republic Services San Antonio LLC Exhibit D Page: 34 34 of 54 Deposition of Louis Jones 1 2 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Did you have any conversations with Congressman Cuellar about the DHS grant? 3 A Invoke the Fifth. 4 Q Did you have any conversations with any 5 Hidalgo County elected officials, including elected 6 officials of the drainage district, about the DHS 7 grant? 8 A Invoke the Fifth. 9 Q You're aware that Dannenbaum had a dispute 10 with the district that ultimately resulted in 11 settlement, is that true? 12 A Invoke the Fifth. 13 Q What was the nature of the dispute that 14 resulted in the settlement? 15 A Invoke the Fifth. 16 Q Did Godfrey Garza ever discuss the dispute 17 with you before the settlement was reached? 18 A Invoke the Fifth. 19 Q Did Godfrey -- and I mean Godfrey Garza, Jr. 20 -- did Godfrey Garza, Jr. ever discuss closed session 21 information with you about the settlement? 22 A Invoke the Fifth. 23 Q Did Godfrey Garza try to increase the amount 24 25 of the settlement? A Invoke the Fifth. Republic Services San Antonio LLC Exhibit D Page: 35 35 of 54 Deposition of Louis Jones 1 2 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Did Godfrey Garza get a portion of any of the settlement proceeds? 3 A Invoke the Fifth. 4 Q Were any of the settlement proceeds used to 5 pay Valley Data? 6 A Invoke the Fifth. 7 Q Why was Erik Ybarra at the mediation? 8 A Invoke the Fifth. 9 Q Do you believe that Dannenbaum had a 10 contractual obligation to disclose the 11 subcontractors it used on projects for the district? 12 A Invoke the Fifth. 13 Q Do you believe that Dannenbaum had a legal 14 obligation imposed by either a federal statute or a 15 state statute that would have required it to disclose 16 the subcontractors it used on district projects? 17 A Invoke the Fifth. 18 Q You met with Godfrey Garza at a bar before 19 the grant was approved to discuss the federal levee 20 project, is that true? 21 A Invoke the Fifth. 22 Q And at that meeting there were discussions 23 about hiring Valley Data on the project, is that 24 true? 25 A Invoke the Fifth. Republic Services San Antonio LLC Exhibit D Page: 36 36 of 54 Deposition of Louis Jones 1 Q HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL And, in fact, Godfrey Garza either then or 2 at another time made it a quasi requirement of 3 getting the contract that Dannenbaum would hire 4 Valley Data, is that true? 5 MR. NEWTON: 6 MR. BARRERA: 7 MR. NEWTON: Objection, form. Objection, form. I objected, form. The 8 question was extremely vague, and I'm not sure what a 9 quasi requirement is. 10 11 12 13 14 MR. BLANCHARD: objection for you, John. Q (Mr. Blanchard) You can answer the question, though. A Invoke the Fifth. 15 16 I'll true to cure the MR. DEUTSCH: Excuse me a second. is this gentleman down here? 17 MR. NEWTON: I'm sorry. This is Dennis 18 Ramirez. 19 Valley Data Corporation, Annie Garza, Jonathan 20 Garza, and Trey Garza. 21 our defense. He's local counsel that also represents He's -- he's associated with 22 MR. DEUTSCH: 23 MR. BLANCHARD: 24 25 Who Q (Mr. Blanchard) Pardon the interruption. That's okay. Were there meetings where Godfrey Garza told you that you needed to hire Valley Republic Services San Antonio LLC Exhibit D Page: 37 37 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 Data on the district projects that Dannenbaum was 2 hired on? 3 A Invoke the Fifth. 4 Q Was Valley Data on the district's approved 5 list of pool of vendors? 6 A Invoke the Fifth. 7 Q Are you aware that there is something called 8 a vendor pool list? 9 A Invoke the Fifth. 10 Q Why didn't Dannenbaum use somebody on the 11 approved pool list, instead of Valley Data? 12 A Invoke the Fifth. 13 Q I'm gonna let the other folks ask you 14 questions, and I may have some further questions for 15 you, but for right now, thank you for your time. 16 MR. NEWTON: 17 the Valley Data defendants. 18 MR. BARRERA: No question on behalf of We reserve our questions 19 for Integ -- or on behalf of Integ and Godfrey Garza, 20 Jr. 21 MR. BLANCHARD: 22 MR. CANALES: 23 MR. BLANCHARD: 24 MR. CANALES: 25 for the record. Republic Services San Antonio LLC Okay. You're done. Can I have -Oh, sorry. Let me make a statement I want to be sure that the record is Exhibit D Page: 38 38 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 clear there's a factual basis for his invoking the 2 privilege of the Fifth Amendment. 3 Canales. 4 been involved in representing Mr. Jones now for over 5 six months. 6 that there's a basis for his entering the privilege. 7 I have been informed, personally, by members of the 8 Department of Justice, U.S. Attorney's Office, FBI, 9 that Mr. Jones is a target of a criminal My name is Tony I'm his criminal defense lawyer. I have I can personally attest to you, sir, 10 investigation, ongoing criminal investigation. 11 office was subjected to a search warrant. 12 also read in this particular case one of the 13 witnesses in this case has gone to the FBI and 14 complained about activities. 15 but, obviously, it includes Mr. Louis Jones. 16 His I have I do not know of whom, Based on those two things, that he is a 17 subject of a pending criminal investigation, second 18 that I know in this particular case one of the 19 witnesses has complained to the FBI alleging 20 wrongdoing by Mr. -- by Mr. Jones, that it leaves me 21 no choice that any lawyer worth his salt would be -- 22 would advise his client to enter a plea -- enter the 23 privilege of the Fifth Amendment. 24 sir, he would be more than glad to -- if we didn't 25 have this issue on us, we would be -- he would be Republic Services San Antonio LLC Other than that, Exhibit D Page: 39 39 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 more than glad to answer, but at this point in time I 2 just want the record to reflect and for you to 3 understand that we're not making this up. 4 basis for, and that's why I'm here, because I 5 personally -- I've been handling the criminal side. 6 I'm not a civil lawyer, I'm a criminal defense 7 lawyer. 8 9 MR. BLANCHARD: There's a Totally understand, Mr. Canales, and I understand your client's rights and 10 fully support his right to exercise them. 11 to some extent that invocation of the right was 12 appropriate, and we're not gonna argue about it here, 13 but I appreciate what you said. 14 MR. CANALES: I disagree I just want to make sure 15 that if you're gonna have a hearing on it, I would be 16 called to the hearing. 17 testify about what I said right now that there's a 18 basis for it. I would be more than glad to 19 MR. BLANCHARD: 20 MR. CANALES: 21 Absolutely. Thank you, sir. for your courtesies. 22 MR. BLANCHARD: 23 MR. CANALES: 24 Thank you Sure. This concludes the deposition, I take it? 25 Republic Services San Antonio LLC MR. BLANCHARD: It does. Exhibit D Page: 40 40 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 MR. CANALES: 2 VIDEOGRAPHER: 3 Thank you. Off the record. The time is 10:13. 4 5 (The deposition was concluded at 10:13 a.m.) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D Page: 41 41 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL LOUIS HAROLD JONES, JR. - 1/10/18 2 CHANGES AND SIGNATURE 3 PAGE 4 ___________________________________________________ 5 ___________________________________________________ 6 ___________________________________________________ 7 ___________________________________________________ 8 ___________________________________________________ 9 ___________________________________________________ 10 ___________________________________________________ 11 ___________________________________________________ 12 ___________________________________________________ 13 ___________________________________________________ 14 ___________________________________________________ 15 ___________________________________________________ 16 ___________________________________________________ LINE CHANGE REASON 17 18 19 I, LOUIS HAROLD JONES, JR., have read (or have 20 had read to me) the foregoing deposition and hereby 21 affix my signature that same is true and correct, 22 except as noted above. 23 24 __________________________ LOUIS HAROLD JONES, JR. 25 Republic Services San Antonio LLC Exhibit D Page: 42 42 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL THE STATE OF TEXAS * 2 Before me, ___________________, on this day 3 personally appeared LOUIS HAROLD JONES, JR., known to 4 me (or proved to me under oath or 5 through________________) (description of identity 6 card or other document) to be the person whose name 7 is subscribed to the foregoing instrument and 8 acknowledged to me that they executed the same for 9 the purposes and consideration therein expressed. 10 Given under my hand and seal of office this _____ 11 day of ____________, 2018. 12 13 14 15 _________________________ NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS 16 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D Page: 43 43 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 NO. C-0373-17-E 2 3 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 4 VS. 5 INTEG CORPORATION, ET AL. * * * * * * * 275TH DISTRICT COURT OF HIDALGO COUNTY, TEXAS 6 7 8 REPORTER’S CERTIFICATION DEPOSITION OF LOUIS HAROLD JONES, JR. Taken on 1-10-18 9 I, GERALD SMITH, Certified Shorthand Reporter in 10 and for the State of Texas, hereby certify to the 11 following: 12 That the witness, LOUIS HAROLD JONES, JR., was 13 duly sworn by the officer and that the transcript of 14 the oral deposition is a true record of the testimony 15 given by the witness; 16 That the deposition transcript was submitted on 17 _____________, to the witness or to the attorney for 18 the witness for examination, signature and return to 19 me by _______________; 20 That the amount of time used by each party at the 21 deposition was as follows: 22 23 24 25 Republic Services San Antonio LLC Exhibit D Page: 44 44 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 Mr. Michael Blanchard: 0 Hrs; 43 Min; 2 Mr. John Newton: 0 Hrs; 00 Min; 3 Mr. Dennis Ramirez: 0 Hrs; 00 Min; 4 Mr. Marcus Barrera: 0 Hrs; 00 Min; 5 Mr. Richard Deutsch: 0 Hrs; 00 Min; 6 Mr. J.A. “Tony” Canales: 0 Hrs; 00 Min. 7 That pursuant to information given to the 8 deposition officer at the time said testimony was 9 taken, the following includes counsel for all parties 10 of record: 11 12 13 14 15 FOR THE PLAINTIFF: MR. MICHAEL J. BLANCHARD Cowen Mask Blanchard 6243 IH 10 West, Suite 801 San Antonio, Texas 78201 T: (210) 941-1301 efilings@cmbtrial.com 16 17 18 19 20 21 FOR THE DEFENDANT, INTEG CORPORATION AND GODFREY GARZA, JR.: MR. MARCUS C. BARRERA Barrera, Sanchez & Associates 10113 North 10th Street, Suite A McAllen, Texas 78504 T: (956) 287-7555 marcus@bsmlawyers.com 22 23 24 25 Republic Services San Antonio LLC Exhibit D Page: 45 45 of 54 Deposition of Louis Jones 1 2 3 4 5 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL FOR THE DEFENDANT, VALLEY DATA COLLECTION SPECIALIST, INC., ANNIE GARZA, GODFREY GARZA, III AND JONATHAN GARZA: MR. JOHN W. NEWTON, III Roach & Newton, LLP One Westchase Center 10777 Westheimer Road, Suite 212 Houston, Texas 77042 T: (713) 652-2031 jnewton@roachnewton.com 6 7 8 9 10 MR. DENNIS RAMIREZ Law Office of Dennis Ramirez 111 N. 17th Street, Suite D Donna, Texas 78537 T: (956) 461-2890 dramirezlaw@gmail.com 11 12 13 14 15 FOR THE WITNESS, LOUIS JONES, JR.: MR. RICHARD D. DEUTSCH McGuireWoods, LLP 600 Travis Street, Suite 7500 Houston, Texas 77002 T: (832) 214-9945 rdeutsch@mcguirewoods.com 16 17 18 19 20 MR. J.A. “TONY” CANALES Canales & Simonson, PC 2601 Morgan Avenue (78405) P. O. Box 5624 Corpus Christi, Texas 78465-5624 T: (361) 883-0601 tonycanales@canalessimonson.com 21 22 23 I further certify that I am neither counsel for, related to, nor employed by any of the parties or 24 25 Republic Services San Antonio LLC Exhibit D Page: 46 46 of 54 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 1 attorneys in the action in which this proceeding was 2 taken, and further, that I am not financially or 3 otherwise interested in the outcome of the action. 4 Further certification requirements pursuant to 5 Rule 203 of TRCP will be certified to after they have 6 occurred. 7 8 Certified to by me this _______ day of _________, 2018. 9 10 11 12 13 14 15 ______________________________ GERALD SMITH, Texas CSR #2305 Expiration Date: 12-31-19 Republic Services Firm # 649 12108 Radium Street San Antonio, Texas 78216 (210) 298-6300 16 17 18 19 20 21 22 23 24 25 Republic Services San Antonio LLC Exhibit D Page: 47 47 of 54 Deposition of Louis Jones 1 HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL FURTHER CERTIFICATION UNDER RULE 203, TRCP 2 The Changes and Signature pages of LOUIS HAROLD 3 JONES, JR. was/was not returned to the deposition 4 officer on ______________; 5 6 If returned, the attached Changes and Signature page contains any changes and the reasons therefor; 7 8 The original deposition was delivered to Michael Blanchard, Custodial Attorney; 9 That $___________ is the deposition officer’s 10 charge to Michael Blanchard, for preparing the 11 original deposition transcript and any copies of 12 exhibits; 13 That the deposition was delivered in accordance 14 with Rule 203.3, and that a copy of this certificate 15 was served on all parties shown herein and filed with 16 the Clerk. 17 18 Certified to by me this ______ day of _________, 2018. 19 20 21 22 23 24 _____________________________ GERALD SMITH, Texas CSR #2305 Expiration Date: 12-31-19 Republic Services Firm # 649 12108 Radium Street San Antonio, Texas 78216 (210) 298-6300 25 Republic Services San Antonio LLC Exhibit D Page: 48 48 of 54 Deposition of Louis Jones WORD LIST <$> $17,407.95 (1) $196,358.90 (1) $300,310.78 (1) $34,129.11 (1) $397,826.48 (1) $547,790.29 (1) $631,693.25 (1) <“> “TONY” (3) <0> 0 (6) 00 (5) 00001266 (1) 00001280 (1) 00001299 (1) 00001304 (1) 00001307 (1) 00001316 (1) 00001328 (1) 000020-83 (1) 001130-001149 (1) 001150-001151 (1) 00200-00201 (1) 00379-00380 (1) 00381-00402 (1) 00403-00422 (1) 00423-00446 (1) 00448-00460 (1) 00461-00370 (1) 007797-007812 (1) 009606-009622 (1) 009706-009715 (1) 010042-010057 (1) 010279-010282 (1) 010367-010378 (1) 07 (1) 08 (6) 09 (1) <1> 1 (21) 10 (10) 10:13 (3) 10113 (2) HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL 10777 (2) 1080 (1) 10th (5) 1-10-18 (1) 111 (2) 12 (1) 12108 (2) 12-31-19 (2) 13 (3) 14 (6) 15 (5) 16 (4) 17 (5) 17th (2) 18 (10) 19 (6) 361 (2) 38 (1) 3900 (1) 3-WA (1) <2> 2 (4) 20 (6) 2000 (1) 2003 (1) 2014 (2) 2018 (6) 203 (2) 203.3 (1) 21 (1) 210 (4) 212 (2) 214-9945 (2) 22 (1) 23 (9) 2305 (2) 24 (4) 25 (2) 26 (1) 2601 (2) 27 (1) 275TH (2) 287-7555 (2) 298-6300 (2) 2-WA (1) <6> 6 (7) 600 (2) 6243 (2) 64 (1) 649 (2) 652-2031 (2) <3> 3 (8) 30 (2) 31 (5) 355 (1) 359 (2) Republic Services San Antonio LLC <4> 4 (10) 42 (1) 43 (1) 44 (1) 461-2890 (2) 48 (1) <5> 5 (4) 5624 (2) <7> 7 (8) 713 (2) 7500 (2) 77002 (2) 77042 (2) 78201 (2) 78216 (2) 78405 (2) 78465-5624 (2) 78504 (2) 78537 (2) <8> 801 (2) 8-12 (1) 832 (2) 883-0601 (2) <9> 9 (1) 9:10 (2) 9:37 (1) 9:37-9:57 (1) 9:57 (1) 941-1301 (2) 956 (4) A.D (1) a.m (3) ability (1) able (1) Absolutely (1) acknowledged (1) acquisition (1) action (2) activities (1) actual (1) additions (1) administer (1) advantage (1) advice (1) advise (1) affix (1) AGREED (5) Agreement (8) agreements (2) ahead (2) AL (2) alleging (1) Amendment (6) amount (2) ANNIE (6) answer (11) answering (1) answers (1) ANTHONY (1) Antonio (4) anybody (2) apologize (1) appear (1) Appearances (1) appeared (1) application (2) apply (1) appreciate (1) appropriate (3) approved (6) argue (1) argument (1) argumentative (1) Asael (4) Exhibit D 49 of 54 Page: 1 Deposition of Louis Jones associate (1) associated (1) Associates (2) association (1) attach (1) attached (2) attest (1) attorney (3) attorneys (1) Attorney's (1) Authorization (2) authorized (1) Avenue (2) aware (5) bachelor (1) back (3) backhoes (2) backup (2) bar (1) BARRERA (9) Based (1) basic (1) basically (4) basis (7) Beaumont (1) behalf (3) believe (2) benefits (1) best (1) beyond (1) big (1) Blanchard (54) board (1) border (1) boundary (2) bounds (3) Box (2) breadth (1) break (2) bridges (1) BRIONES (1) building (1) buildings (1) builds (1) business (2) HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL C.S.R (1) C-0373-17-E (2) called (4) CANALES (13) capacity (1) capture (2) card (1) case (3) cause (4) Center (2) certain (3) Certificate (4) CERTIFICATION (3) certifications (5) Certified (6) certify (2) chance (1) CHANGE (1) Changes (6) charge (1) charges (1) Check (10) checks (4) choice (1) Christi (2) Civil (9) clear (4) clearly (1) Clerk (2) client (1) client's (1) closed (1) COLLECTION (4) come (2) commissioners (1) communities (1) companies (1) company (3) complained (2) complete (1) complied (1) comply (1) concluded (1) concludes (1) Congressman (1) consideration (1) constitutional (1) construction (13) Consulting (4) Republic Services San Antonio LLC contain (1) contains (1) contents (2) continue (1) contract (6) contractor (1) contracts (6) contractual (1) conversation (1) conversations (3) cooperate (1) copies (5) copy (9) CORPORATION (11) Corpus (2) Correct (25) correction (1) corrections (3) Correspondence (1) corridor (1) Counsel (7) COUNTY (13) COURT (4) courtesies (1) Cowen (3) cranes (2) criminal (8) cross (1) CSR (3) Cuellar (1) cure (1) current (1) currently (1) custodial (2) cut (1) D.C (1) Dannenbaum (74) DATA (56) Data's (1) date (3) day (6) days (2) deal (1) decided (1) decline (1) DEFENDANT (4) defendants (1) defense (3) degrees (2) delay (1) deliver (1) delivered (2) delivery (1) DENNIS (7) Department (1) deponent (2) DEPOSITION (33) depositions (1) describing (1) DESCRIPTION (2) descriptions (2) design (1) designing (1) DEUTSCH (9) development (1) DHS (3) difference (1) different (1) DIG-TESS (1) directly (2) disagree (1) disclose (4) discuss (4) discussions (2) dispute (3) DISTRICT (32) district's (1) ditches (1) document (5) Documents (2) doing (6) Donna (2) Dos (3) draft (1) drafting (1) DRAINAGE (16) dramirezlaw@gmail.co m (2) duly (3) earlier (1) effect (1) efilings@cmbtrial.com (2) either (2) Exhibit D 50 of 54 Page: 2 Deposition of Louis Jones elected (2) elevations (2) employ (2) employed (9) employee (1) employees (1) employer (1) employers (1) engineer (1) Engineering (28) enter (2) entered (1) entering (1) entity (1) entity's (1) Erik (1) ET (2) ethical (4) Everybody (1) evidence (1) exact (1) Examination (2) Excuse (2) executed (1) exercise (1) Exhibit (31) Exhibits (15) existing (3) expertise (1) Expiration (2) explain (2) explained (1) expressed (1) expressly (1) extent (3) extremely (1) fact (2) factual (1) fail (1) familiar (4) FBI (4) feature (1) features (2) federal (7) Fifth (106) file (1) filed (2) HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL Final (1) financial (1) financially (1) find (1) finds (1) finish (1) firm (5) first (2) folks (1) following (5) follows (2) force (1) foregoing (2) form (12) full (1) fully (4) funded (1) funds (1) FURTHER (9) gain (1) game (1) Garcia (1) GARZA (42) gentleman (1) GERALD (7) getting (4) given (4) glad (3) Go (2) GODFREY (30) Godfrey's (1) going (5) gonna (19) Good (1) government (1) grant (6) great (2) ground (1) guess (2) guys (2) hand (1) handling (1) HAROLD (11) HCDD (3) HCDD1 (8) Republic Services San Antonio LLC hear (1) heard (2) hearing (3) help (1) helped (1) hereto (2) HIDALGO (13) hire (7) hired (6) hiring (1) hold (1) holding (1) horizontal (4) hour (1) Houston (4) Hrs (6) huh-uhs (1) hundred (1) identified (1) identify (1) identifying (1) identity (1) IH (2) III (4) imposed (1) Improvement (1) Inc. (1) include (4) Included (4) includes (5) Including (3) increase (1) incriminate (1) incrimination (1) independent (1) information (3) informed (1) infrastructure (4) inspection (2) instance (1) instrument (1) INTEG (8) interested (1) interruption (1) investigation (5) invocation (1) Invoice (4) invoices (8) invoke (103) invoking (2) involved (1) issue (1) issued (2) J.A (3) January (3) jnewton@roachnewton .com (2) job (1) JOHN (6) JONATHAN (5) JONES (20) JR (20) Jr. (1) Judge (1) jury (1) Justice (1) keep (2) kind (6) kinds (1) know (19) known (1) Lamar (1) land (2) landfills (1) laterals (1) Law (2) lawsuit (1) lawyer (5) layman's (1) leading (1) learned (1) leaves (1) legal (2) Letter (3) Levee (13) license (1) licenses (1) limited (2) line (4) lines (2) Exhibit D 51 of 54 Page: 3 Deposition of Louis Jones list (3) LLC (4) LLP (4) lobby (1) local (1) Locate (1) Logistics (3) long (1) longer (1) look (1) looking (1) LORA (1) LOUIS (15) making (2) management (10) MARCUS (3) marcus@bsmlawyers.c om (2) MARKED (14) Mask (3) material (1) McAllen (10) McGuireWoods (2) mean (4) mediation (1) meet (2) Meeting (2) meetings (1) meets (3) members (2) mention (2) mentioned (1) met (1) MICHAEL (7) Mike (1) Min (6) money (5) months (1) Morgan (2) morning (2) name (4) nature (1) necessary (2) need (4) needed (2) HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL negotiated (1) neither (1) NEWTON (21) non (1) normal (1) North (2) nos (1) notarized (1) Notary (2) NOTE (1) noted (1) Notice (2) number (1) numbered (2) oath (2) oaths (1) object (1) objected (1) objecting (1) Objection (13) objections (6) obligation (2) obligations (3) obviously (1) occurred (1) offered (1) Office (7) officer (4) officer’s (1) offices (1) official (1) officials (2) Oh (3) Okay (38) ongoing (1) opposing (1) ORAL (5) Order (2) organization (3) original (8) other's (1) outcome (1) outfall (1) oversees (1) owned (1) owns (1) Republic Services San Antonio LLC

PAGE (2) pages (1) paid (6) parcel (2) parcels (1) Pardon (1) part (1) particular (2) parties (4) Party (3) passing (1) pay (4) PC (2) Pecina (4) pending (1) people (6) percent (1) performed (1) person (1) personally (7) pertains (1) pgs (3) physical (1) Plaintiff (4) plans (1) plant (2) played (3) plea (1) please (3) point (2) pool (3) portion (4) position (1) practice (1) practicing (1) preliminary (1) preparing (1) PRESENT (2) primarily (1) principal (7) prior (2) Privilege (4) probably (1) Procedure (3) procedures (1) proceeding (2) proceeds (2) produced (1) Professional (4) Project (10) projects (12) proper (2) property (1) proved (1) provide (2) provisions (1) Public (3) purpose (2) purposes (2) pursuant (5) qualified (2) Quantity (1) quasi (2) question (12) questions (8) quote (1) Radium (2) RAMIREZ (7) range (1) rate (1) rdeutsch@mcguirewoo ds.com (2) reached (1) read (4) reading (1) Reask (1) REASON (1) reasons (1) receipt (1) received (1) recite (1) recognize (2) reconsider (2) record (16) recorded (1) referenced (1) reflect (2) reflected (1) regard (1) rehabilitation (1) related (2) relating (1) relationship (2) Exhibit D 52 of 54 Page: 4 Deposition of Louis Jones remainder (1) remind (1) reobject (1) repeat (1) reported (1) REPORTER (5) Reporter’s (2) represent (2) representative (1) representing (1) represents (1) Republic (2) reputation (1) Requests (1) required (2) requirement (2) requirements (2) reserve (1) resides (1) Resolution (1) respect (2) respectful (1) respectfully (1) responsible (1) responsiveness (1) result (1) resulted (3) Return (3) returned (5) returning (1) Rich (1) RICHARD (3) right (11) rights (3) Roach (2) Road (2) roads (1) roadway (1) ROGERS (1) role (2) roles (1) room (1) rule (4) Rules (4) salt (1) San (4) Sanchez (2) HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL science (1) seal (1) search (1) second (3) see (1) self (1) sent (4) sentences (1) served (1) Services (11) session (1) setting (2) settlement (7) sewer (1) sheet (1) short (1) Shorthand (2) show (11) shown (1) side (1) Signature (7) signed (3) Simonson (2) sir (7) sitting (1) six (1) SMITH (7) somebody (1) sorry (4) sort (2) speak (2) SPECIALIST (2) Specialists (1) specifications (1) speculative (1) stand (1) start (1) State (8) stated (1) statement (1) statute (2) statutes (1) stenography (1) Stipulations (3) stop (1) Street (9) structure (1) structures (1) studies (1) Republic Services San Antonio LLC styled (2) subcontractors (5) subdivisions (1) subject (3) subjected (1) submit (1) Submittal (1) submitted (2) subscribed (1) Suite (11) support (3) supporting (2) supposedly (1) sure (9) surveying (6) surveyors (2) sworn (3) System (4) Systems (1) take (3) taken (5) talk (1) talked (1) tall (1) target (1) Task (1) tell (5) ten (1) tender (1) terms (2) terrain (2) testified (1) testify (1) testifying (1) testimony (2) TEXAS (29) thank (4) therefor (1) thereof (1) thereto (2) thing (1) things (6) think (2) time (18) times (2) title (1) told (2) Tony (1) tonycanales@canalessi monson.com (2) topography (7) Totally (1) transcript (3) transportation (1) Travis (2) TRCP (2) treated (1) Trey (4) trial (2) true (51) truth (1) try (2) trying (3) twenty (1) two (1) type (5) U.S (1) Uh-huh (1) uh-huhs (1) ultimately (2) uncertain (1) underlying (2) understand (6) understanding (4) Understood (2) University (1) use (1) vague (3) VALLEY (56) VD (6) vendor (1) vendors (1) versus (1) vertical (4) Video (2) Videographer (5) VIDEOTAPED (2) voice (1) VS (2) WA (10) wait (2) Exhibit D 53 of 54 Page: 5 Deposition of Louis Jones HIDALGO COUNTY DRAINAGE DISTRICT NO. 1 VS. INTEG CORPORATION, ET AL waived (1) wall (3) want (5) wanted (2) warrant (1) Washington (1) waste (1) water (1) way (2) Well (1) went (1) we're (5) West (2) Westchase (2) Westheimer (2) wholly (1) willing (1) witness (13) witnesses (2) words (1) Work (32) worked (2) works (1) worth (1) wrongdoing (1) Ybarra (1) Yeah (3) years (1) yeses (1) Republic Services San Antonio LLC Exhibit D 54 of 54 Page: 6