Case: Document 51-4 Filed: 06/22/17 Page 1 of 34 PageID #:1004 EXHIBIT 41 Deposition of Clementine Frazier Case: Document 51-4 Filed: 06/22/17 Page 2 of 34 PageID #:1005 CLEMENTINE FRAZIER April 07, 2017 Page 1 1 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS 2 EASTERN DIVISION 3 RAFAELA ALDACO, 4 Plaintiff, 5 VS. NO. 1:16 CV 05754 6 RENTGROW, INC. D/b/a Yardi Resident Screening, 7 Defendant. 8 9 The deposition of CLEMENTINE FRAZIER, called by 10 the Defendant for examination pursuant to notice and 11 pursuant to the Rules of Civil Procedure for the United 12 States District Courts pertaining to the taking of 13 depositions, taken before Barbara Perkovich, a notary 14 public within and for the County of Cook and State of 15 Illinois, at Suite 3500, 70 West Madison Street, 16 Chicago, Illinois on the 7th day of April 2017U.S. Legal Support, Inc. (312) 236-8352 Case: Document 51-4 Filed: 06/22/17 Page 3 of 34 PageID #:1006 CLEMENTINE FRAZIER April 0 7 2 17 Page 2 Page 4 2 ZAMPARO LAW GROUP, pc BY: ms. STEPHANIE TATAR 2 WINE. FRAZER 3 2300 Barrington Road 3 having been first duly sworn, was examined and testified suite 140 4 as follows: 4 Hoffman Estates, Illinois 60169 (224) 375-3202 5 WMTION 5 stephanie@za.mparolaw.com 6 BY MR. DUFFEY: Appearing on behalf of the Plaintiff; 7 mo . 6 . Good min . NIXON PEABODY, LLP 8 A. Good morning. 7 MR- PATRICK DUFFEY 9 Q. Could you state your full name, please. MS. LAURA BACON 1 a 70 West Madison Street 10 ementine raZIer. Suite 2500 11 Q. Thanks, Ms. Frazier. Have you ever given a 9 Chicago, Illinois 60602 12 deposition (312) 977-4388 10 pduffey?nixonpeabody.com 13 lbbacon?nixonpeabody.com 14 Q. I'm going to go over a few of the ground rules 11 Appearing on behalf of the Defendantwith you. I In Just gong to be asking you a series of 13 16 questions today and you're going to be giving the 14 1'7 answers. When you provide answers, it's really :2 18 important that you give verbal answers. So nodding your 17 19 head or words like inn-1mm or uh-huh, that's hard for us 18 20 to translate on the record. 80 if you could answer with maybe or an explanation, that would 21 22 be helpful. DO you understand? 2: 23 A. Okay. 24 24 Q. The other thing would be helpful is, the court Page 3 Page 5 1 INDEX 2 WITNESS: PAGE 2 could wait for me to finish the question before you CLEMENTINE FRAZER 3 provide the answer, that will make her 3013 a lot easrer. 3 4 A. Okay. Examination by: 5 Q. And if at any point today, you don't understand a 4 6 question that I ask, will you tell me that? Mr. Duffey 4, 85 ,7 A Oka 5 Ms. Tatar you tell me that you don't understand, 9 I'll go ahead and do my best to rephrase the question, 8 10 so that you understand it. If you provide an answer to 9 11 a question, we'll just assume that you understood the I I 12 question. Is that fair? 10 NUMBER FOR IDENTIFICATION 11 (None so marked.) 13 Yes? 12 14 Q. Have you taken any drugs or alcohol this morning 13 15 that would prevent you testifying truthfullythere anyOther reason you wouldn't be able to 17 18 give truthful testimony today? 13 19 A. Not that I can think ofdeposition this morning? 2: 22 A. No, only Rafaela lmew that I was coming. 23 23 That was not this morning. 24 24 Q. When did you speak with Rafaela about your U.S. Legal Support, 236-8352 (312) Inc. Case: Document 51-4 Filed: 06/22/17 Page 4 of 34 PageID #:1007 CLEMENTINE FRAZIER April 07, 2017 Page 6 Page 8 1 depositionAllison? 2 A. I guess when I received it last month. 2 A. 25. 3 Q. When you say it, what are you referring to? 3 Q. Do you mirrently work? 4 A. The deposition. 4 A. Yes. I started a job maybe, this will be 5 Q. Ihe subpoena? 5 six months for me. 6 A. Yes. 6 Q. Where do you work? '7 Q. And what did you and Rafaela talk about during 7 A. I work at Fieldwork, it's a marketing 8 that conversation? 8 research company. 9 A. Nothing. It was the fact of how I would get 9 Q. Is that in Schatmlburg? 10 here. 'I'hat's basically it. 10 A. Schaumburg, but they have a Chicago office 11 Q. Have you ever spoken with any of Rafaela Aldaco's 11 also. But I?m in Schaumburg. 12 lawyers? 12 Q. And what do you do theremarket research recruiter. 14 Q. And did you speak with any family members or 14 Q. And what do you do as part of that job? 15 friends about your deposition today? 15 A. Well, we -- I interview people for focus 16 A. Only my husband, who came with me. He 16 groups, interviews to qualify them to participate 1'7 needed to know where we were going, but that's it. 17 for the client in focus groups and one-on-one 18 Q. Have you spoken to anyone at the Fellowship 18 interviews. 19 Housing Corporation about your deposition? 19 Q. Is that a full-time position? 20 A. No. 20 A. Part-time. 30 hours. 21 Q. Did you do anything to prepare for your 21 Q. And prior to Fieldwork, did you work anywhere 22 deposition this Homing? 22 else? 23 A. No. 23 A. Well, I stayed with my family member that 24 Q. Did you review any documents or anything to 24 was terminally ill for two, almost two years, but I Page '7 Page 9 1 refresh your muory before the deposition? 1 have had a career in human resources, about 20 2 A. No. 2 years. 3 Q. I would like just to talk a little bit about your 3 Q. And where did you work as part of that human 4 background, if we could. What is your current address? 4 resources career? 5 A. 5 A. My last job was at Empire Today. I was a 6 Lane. 6 corporate recruiter. '7 Q. Do you have any plans to move anytime soon? 7 Q. That was Empire Today? 8 A. No. 8 A. Yeah, Empire Today, carpeting. 9 Q. Do you rent or own that home? 9 Q. How long did you work at Expire lIbday? 10 A. Own. 10 A. I worked there for one year, but because we 11 Q. How long have you lived there? 11 had so many recruiters, I was only there one year 12 A. Since 1987. 12 and a month or so, so I was laid off. 13 Q. And have you owned the hate that entire time? 13 Q. Prior to Elmira Today, where did you work? 14 A. Yes. 14 A. I should have brought my resume, I'm trying 15 Q. Are you married? 15 to think. I'm a little nervous and I know I lmow. 16 A. Yes. 16 I worked as a recruiter for healthcare, recruiting 17 Q. How long have you been married? 1'7 for LPG. I worked there are as a healthcare 18 A. June will be 48 years. 18 recruiter. 19 Q. Andwhat isyourhusband's name? 19 Q. Anddoyouhave ofhow longyouworked 20 A. Robert. 20 there? 21 Q. And do you and Robert have any children? 21 A. I worked there probably three months, but 22 A. One daughter. 22 then I stopped to go to take care of my family 23 Q. And what is her name? 23 member, to be a caregiver. 24 A. Allison. 24 Q. Ms. Frazier, have you ever been arrested? U.S. Legal Support, 236-8352 (312) Inc . Case: Document 51-4 Filed: 06/22/17 Page 5 of 34 PageID #:1008 CLEMENTINE FRAZIER April 07 2 017 Page 10 Page 12 1 A. No. 1 the church with her boys one Sunday and she wanted 2 Q. Have you ever been convicted of a crime? 2 to give her heart to God. So she went down to the 3 A. No. 3 altar and I was the one that went there with her and 4 Q. Are you involved in any commnity activities? 4 led her to the Lord. 5 A. Yes, I teach a life group, actually tonight, 5 Q. How would you describe your relationship with 6 I teach a ladies life group about maybe 20 ladies. 6 Rafaela? 7 I worked for 14 years as a bible study teacher at my 7 A. I would say over the years I've been more of 8 church and I I've helped out with the food pantry at 8 a mentor, mom, in a way, spiritual mom over the 9 church. So I'm very involved with things 9 years, a mentor. Because she was a young mom and I 10 that is involved with the church. 10 had more experience in marriage and parenting, so I 11 Q. What church is that? 11 would assist her in those areas. 12 A. Evangel Assembly of God in Hanover Park. 12 Q. When you say you would help her in marriage and 13 Q. You mentioned you were involved in a life group? 13 parenting what do you mean by that? 14 A. Life group teacher. I teach bible study, we 14 A. Well, not marriage so much because she's not 15 have prayer. Encourage thewomen, empower them and 15 married, but just raising children, you know? I had 16 help them just living life. 16 a father, mother, I grew up in a home with a father 17 Q. And how long have you been doing that? 17 and a mother. So my mom taught me a lot of things 18 A. Well, I've been teaching at church for 14 18 and I would pass a lot of those things on to her, 19 years. I started the life group, which is still 19 being a new mom and not having the advantage of 20 part of the church, about a year, year and a half. 20 having someone to teach her. 21 Q. How often does that life group meet? 21 So I would do that. And my-husband also. He 22 A. We meet twice a month, first and the third 22 would help the boys, you know, as a father figure. 23 Friday of the month. 23 And we've done that over the years with them. We've 24 Q. Are there any other activities or 24 watched them grow. Page 11 Page 13 1 church activities that you are involved in? 1 Q. I'm handing you what has already been marked as 2 A. Prayer team. I'm intercessory prayer team 2 Defendant's Exhibit 4 in this case. This is Plaintiff's 3 leader. Whatever is needed. But those basically, 3 responses to first interrogatories. Do you understand 4 you know, things that I actually do. I sometimes 4 what the term Plaintiff means? 5 fill in when they need someone to teach people about 5 A. Yes. 6 baptism, things like that. What does it mean. 6 Q. Do you understand that Rafaela Aldaco is the 7 Q. What does the work of a prayer team leader 7 Plaintiff in this lawsuit? 8 entail? 8 A. Yes. 9 A. What we do, when you go to say church, you 9 Q. Have you ever seen this document before? 10 know the minister will have an altar call for 10 A. No. 11 someone who may want to know the Lord, join the 11 Q. If you could turn to Page 11 of the 12 church or if you need prayer because you are sick. 12 A. Okay. 13 Then I would be the one to go to the front and then 13 Q. And No. 3 at the bottom of the page, do you see 14 I would pray with you. Talk to you later if you 14 your name listed there? 15 decide you want to know the Lord, tell you what it 15 A. Yes, I do. 16 means, take your name all the info and follow-up 16 Q. I would just like to read that. It says, 17 with you. 17 Clementine Frazier, a close personal friend of and 18 Q. Do you know Rafaela Aldaco? 18 mentor to the Plaintiff that has personal knowledge of 19 A. Yes. 19 the Plaintiff 's entire process of applying for the 20 Q. How long have you lmown Ms. Aldaco? 2O Fellowship Program and the affects the facts of this 21 A. Probably since 2002. 21 cause had on the Plaintiff after the Yardi report caused 22 Q. How did you meet Ms. Aldaco? 22 her to loss her acceptance in the fellowship housing 23 A. Again, I've been very active in my church, 23 program. 24 I've been a member for 35, 36 years and she came to 24 I would like to take that in parts, if I could. U.S. Legal Support, Inc. (312) 236-8352 Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 6 of 34 PageID #:1009 CLEMENTINE FRAZIER April 07 2 017 Page 14 Page 16 1 That first section there, would you describe yourself as 1 can't think of the name of it right now. 2 a close personal friend of and mentor to the Plaintiff? 2 Q. If you can't think of the name, that's okay. 3 A. Yes. 3 A. But the pastor is Pastor Winston. But she's 4 Q. And then the second portion there -- well, first 4 a member of the church that I attend. 5 of all, what is the Fellowship Program? 5 Q. And that's Evangel? 6 A. I'm not real sure, but from my understanding 6 A. Evangel Assembly of God. 7 it's a program that help women that maybe had 7 Q. I would like to break up the question about how 8 children to find housing. I'm not real sure about 8 often you see Ms. Aldaco into two time periods, if I 9 it, but that's what my interpretation of it is. 9 could. The first time period would be before January accurate to say that you have 10 2016 and then the second time period is going to be 11 knowledge of Rafaela's process of applying for that 11 after January of 2016. So, prior to Jannary of 2016, 12 program? 12 how often would you say that you saw Ms. Aldaco? 13 A. Only the knowledge of what she had told me 13 A. The sameabout it. I mean, I didn't go with her, I didn't 14 visiting, I mean, I see -- I'm just not. We live 15 hear anyone talk with her, but she told me she was 15 we were given advice when we first got married to 16 going and was excited. Most of the times if I have 16 more or less keep people out of your marriage 17 any type of personal knowledge, it would be to pray i7 relationship and I sort of took that advice. 18 with her about a situationdo, because I am a mentor to so many women, 19 whatever. And in this case, I just knew that she 19 I'm there for them, they will e~mail me or call, but 20 was applying. Thought it was a good idea kind of 20 as far as visiting, we don't a lot of that. 21 thing. 21 Q. So, is it your testimony today that the frequency 22 Q. So, did you ever speak with anyone that worked at 22 with which you seen Ms. Aldaco has been the same before 23 the Fellowship Housing Corporation? 23 January of 2016 and after January of 2016Yeah, I would say it's about consistent. Page 15 Page 1'7 1 Q. And finally, the last part on the bottculof Page 1 Q. You mentioned that Ms. Aldaco participates in the 2 11, No. 3 there it says that you have personal knowledge 2 life group? 3 of the affects the facts of this cause had on Plaintiff 3 A. Yes. 4 after the Yardi report caused her to loss her acceptance 4 Q. Do you do any other sorts of activities with her? 5 in the Fellowship Housing Program. 5 A. Occasionally her son may want to take me out 6 Is it accurate to say that you have knowledge of 6 to dinner because he's working now, so I'm sort of 7 the affect -- the effect of not being able to move into 7 like I'm their godmother, I would say, so he 8 the Fellowship apartment had on Rafaela? 8 likes to take me to his restaurant that he works at. 9 A. Knowledge, again, what she told me how it 9 So I may see her then, she may go with us or in the 10 affected her. She was crying and quite devastated 10 summer? 11 because she was all excited about it, when we would 11 Q. And who is Ms. Aldaco?s son? 12 talk on the phone on moving here and so forththen when it didn't happen, she was devastated. 13 Q. Yeah, what is it? 14 Because she had nowhere to go. 14 A. Christian and Adrian. 15 Q. About how often do you see Ms. Aldaco? 15 Q. You mentioned that one of the sons takes you out 16 A. Maybe once a week, if that. Sometimes she 16 to dinner and works at a restaurant which one is that? 17 attends another church. So maybe once -- because, 17 A. Christian, that's the youngest, I think he's 18 again, she is in the life group, so I see her maybe, 18 about 17, going on 17. Or in the summer, if I have 19 I would say maybe once every two weeks, maybe. And 19 a barbecue, I might invite a couple of ladies over 20 then if she comes to church, to, you knowthem. 21 church, then I would see her there. 21 Q. When Ms. Aldaco attends the life group, how does 22 Q. Do you know what other church she attends? 22 she typically get there? 23 A. It's pastor Winston I know the name, too, 23 A. She drives. 24 but I just can't remember, it's Forest Park. I 24 Q. Does she drive her own car? U.S. (312) Legal Support, 236-8352 Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 7 of 34 PageID #:1010 CLEMENTINE FRAZIER April 07, 2017 Page 18 Page 20 1 A. Yes. 1 Q. Did you ever notice any change in her attendance, 2 Q. And when she attends your church, how does she 2 the frequency with which she would attend the meetings, 3 get there? 3 after January of 2016? 4 A. Drives. 4 A. No, not really. 5 Q. And again, with her own car? 5 Q. Would you say that she attends the meetings 6 A. Yes, um?hmn. 6 regularly? 7 Q. When you go out to dinner with Christian, does 7 A. Yes. 8 Rafaela typically go too? 8 Q. And by regularly, how would you describe that? 9 - A. Yes. 9 A. Twice a month, first and third Friday of the 10 Q. Who pays for those meals? 10 month. 11 A. Well, Christian paid for my meal. He was 11 Q. So she's usually there for every meeting? 12 treating me, but she pays for her meal and her other 12 A. Unless something comes up where she can't be 13 son is Adrian. 13 there, but most of the time she?s there. 14 Q. How often do you go out to meals like that 14 Q. If she's not going to be able to attend a meeting 15 together? 15 does she usually let you know ahead of time? 16 A. Well, so.far he's been working and saving 16 A. Yes. Most ladies do, they e?mail or call 17 his money, so he's taken me out twice to his 17 me. 18 restaurant is vanitti's, a nice Italian restaurant. 18 Q. Has she ever said she couldn't attend the meeting 19 And then he also took me to Longhorn Steakhouse. 19 because she was having headaches? 20 Q. The life group that we've discussed a few times 20 A. There have been times, maybe you can count 21 today, how many peqple typically attend those meetings? 21 on one hand, where she was a little stressed. But 22 A. I've had about 20 to 25 ladies, but 22 when that happens, I usually know why. I mean, the 23 sometime, not every week because sometimes they have 23 other ladies don't, but I would know why. 24 things with their children, they say be sick. Not 24 Q. I guess my question was a little bit different? Page 19 Page 21 1 every week. Say on the average maybe about 15. 1 A. Okay. 2 Which is a large, because my pastor wants it to be 2 Q. Has she ever specifically called and said that 3 more personal so 8 to 12, maybe, but I usually have 3 she is unable to attend because she has been 4 a very large, because I teach a women's life group 4 experiencing a headache? 5 where a lot of the other life groups are husband 5 A1 Yes. 6 wife type thing. Mine is mostly all women. 6 Q. When did that occur? 7 Q. What do you typically discuss at these meetings? 7 A. You used the -- you said before January or 8 A. First of all, we have fellowship where we 8 after January? I would say after January, maybe. 9 eat, we bring all kind of dishes, for half an hour. 9 Q. How many times has that happened? 10 And after that we go into worship and praise, I have 10 A. Maybe once or twice. You know, I'm not 11 music and we just sing and praise God. And then I 11 really sure. 12 go into the teaching and this particular teaching I 12 Q. When she would let you know she wouldn't be able 13 have a DVD where we?ll listen to. And from there, 13 to attend, was that a phone call? 14 we I'll teach the word and we have discussion and 14 A. Phone call, yes. 15 then we close in prayer. 15 Q. Has she ever sent you an e?mail saying she 16 Q. Has us. Aldaco ever discussed any of the facts of 16 wouldn't be able to attend? 17 this lawsuit at these life group meetings? 17 A. Yesyou know what reason she gave for not being 19 Q. Before January of 2016, was us. Aldaco attending 19 able to attend? 20 these life group meetings? 20 A. Circumstances of life. 21 A. Yes. 21 Q. When you say circumstances of life? 22 Q. Has she continued to attended the life group 22 A. I knew you were going to have me explain. 23 meetings, since she started going in January of 2016? 23 Situations that she's going through. I would say 24 A. Yes. 24 probably this situation was real heavy on her. U.S. Legal Support, 236?8352 (312) Inc. Case: Document 51-4 Filed: 06/22/17 Page 8 of 34 PageID #:1011 CLEMENTINE FRAZIER April 07, 2017 Page 22 Page 24 1 Q. When you say this situation, what do you mean? 1 their parents that much. But they come to church 2 A. With the fellowship housing. Because she 2 with her and go out to dinner with her. And so I 3 was all set and excited about, you know, moving in. 3 would say probably, in today's society, would just 4 Q. When was the last time that you saw Ms. Aldaco 4 be an average kind of interaction. 5 prior to today? 5 You know, she can't kiss them and hug them 6 A. Not this Sunday, I saw her last Sunday at 6 and all of that anymore, but, you know, boys don't 7 church. 7 want that anyway. My daughter doesn't even want. 8 Q. Did you speak to her on Sunday at church? 8 But as far as coming to church, they sit with her 9 A. Yes. 9 and they go out and they go to movies. She said the 10 Q. What did you talk about? 10 other day she was taking them to see a movie, so 11 A. Usually we just meet and greet kind of thing 11 probably average. 12 between the next service. Most of the ladies do 12 Q. Did you have the opportunity to see her interact 13 that, they look at me like the mom. So she would 13 with her children both before January of 2016 and after - 14 come over and hug me, kiss me and say hi. Those 14 January of 2016? 15 kind of things. 15 A. Yes. 16 Q. Did you mention your deposition at all? 16 Q. Did you notice any change with the way they 17 A. Well, she already knew about the deposition, 17 interacted between those two time periods? 18 I guess. 18 A. When you say before January and after 19 Q. Did she mention her deposition at all? 19 January, I guess I'm not sure where I would draw the 20 A. She just said she was kind of lost trying to 20 line as far as her behavior with them. She has been 21 come downtown, get downtown. 21 stressed, I like I said, and that affects the 22 Q. You mentioned that you are the Godmother?_ 22 children, it affects everyone in the home. 23 A. To her children. When she first came to the 23 Q. Have you ever seen Ms. Aldaco lose her temper 24 church, I led her to the Lord, but I also she 24 with her children? Page 23 Page 25 1 wanted her children dedicated.- I know a lot of A. Yes. 2 different religions, they baptize and so forth. We 2 Q. How often would you say that happens? 3 dedicate the children, and then when they get to the 3 A. Rarely. When they start maybe talking back 4 age of accountability, then they can get baptized. 4 a little. 5 So she wanted me to stand up with her, my husband 5 Q. Before January of 2016 did you ever see her lose 6 and I, as Godparents, to help her raise the kids. 6 her temper with her children? 7 Q. How often do you see Ms. Aldaco's children? 7 A. I don't see her doing that as much, because 8 A. Now, teenagers, you know, you don't see them 8 I'm not around her as much, okay. At church you 9 too often. I would say maybe once a month, maybe, 9 naturally going to have your nice little church 10 if that. 10 face, but I'm sure both times, before and after, 11 Q. How old are Ms. Aldaco's children? 11 during certain circumstances, I might have seen her 12 A. Adrian, who is the oldest, he's 21. And 12 or on the phone. Or they may call me and say 13 Christian, I think is 16 and a half, maybe 17. 13 Ms. Clem, mom is upset with me about something, you 14 Q. You mentioned that Christian works in 14 know, like that. 15 restaurants. Do you know where Adrian works? 15 Q. How often would you say that happens where 16 A. Adrian, he has a job at T?Mobile, but I'm 16 somebody calls you and says, Mom is upset with me? 17 not sure where 1 think it's maybe in Hanover 17 A. Maybe once or twice. Not that often. 18 Park, but I'm not sure. 18 Q. When did that occur? 19 Q. Do you ever get to see He. Aldaco interact with 19 A. We are in '17 now, right? When you say 20 her children? 20 before and after, I guess that's where I'm having a 21 A. Yes. 21 problem. 22 Q. How would you describe their interaction? 22 Ms. TATAR: Can we provide some context as to 23 A. I think it's probably the normal for 23 what happened in_January 2016, so then maybe it will 24 teenagers, you know. They don't like to be around 24 be easier for her. U.S. Legal Support, 236-8352 (312) Inc. Case: Document 51-4 Filed: 06/22/17 Page 9 of 34 PageID #:1012 CLEMENTINE FRAZIER April 0 '7 2 0 17 Page 26 Page 28 1 THE WITNESS: It's confusing to me and that's 1 where do we go? Mom, where are we going to live 2 why I hesitate to answer because you say before and 2 kind of thing. And she's like, I'm looking, I'm 3 after. Before what and after what? 3 trying to find, that kind of stress. That kind of 4 BY MR. DUFFEY: 4 upset. He knew he couldn't blame her for itguess instead of saying before January of 5 still was in a situation where, Where are they we 6 2016, I?ll say before the situation with the Fellowship 6 going to live? 7 Housing Corporation, when she was told that she could 7 Q. Now, is that something that, again, was conveyed 8 not move into the apartment. Before that, had you ever 8 to you in a specific conversation or is that just your 9 seen Ms. Aldaco lose her tamper with her children? 9 interpretation of the situation as someone who lmows the 10 A. Rarely. Once in a while, maybe. 10 family? 11 Q. After that, have you seen that occur? And by 11 A. Yeah, I think she called and told me that 12 that I mean lose her tamper with her children? 12 Christian was upset and he was crying and then I 13 A. After the Fellowship housing? 13 talked to him and tried to calm him down and said, 14 Q. Yes, ma'am. 14 Your mom is doing the best she can. 15 A. Like I said, she was stressed. The kids 15 Q. When did that conversation occur? 16 were stressed because for one thing they didn't know 16 A. This happened when they were I guess 1? where they were going to live. And children like 17 when weren?t going to move to, what was the place? 18 some stability. So, I guess they started getting on 18 I don't even know the place, Fellowship housing. 19 each other's nerves. 19 Q. About how long after they found out that they 20 Q. Do you remember any specific conversation was 20 were not going to be able to move in there did that 21 Ms. Aldaco where she said anything along the lines of -- 21 conversation occur? 22 do you remember any specific conversations with 22 A. I would say probably a week. It was 23 Ms. Aldaco in which she had told you that she had lost 23 immediate. 24 her tanner with her children? 24 Q. After that conversation, within a week, of being - Page 27 Page 29 A. Not so much told me, but I guess because I 1 unable to move into the Fellowship apartment, did you 2 know them, I know she had been stressed. Sometimes 2 ever have any other conversations that were similar 3 when she was stressed with this situation, Christian 3 about stress in the family? 4 would be upset because he, you know, didn't know 4 A. Not so many conversations. If I see them 5 where they were going to live and, you know, ho 5 she might mention it to me or she would call. She 6 and he would say, Mom, you know, I don't know, that 6 would always call me for prayer. Talk to and 7 kind of thing. And then she would say, Well, I'm 7 encourage her. I did a lot of that. I do that with 8 doing the best that I can, kind of thing. 8 a lot of women. 9 Q. Is that -- what you just described is that 9 And her situation, no one knew about it, it 10 sanething that you personally witnessed or was that 10 was very confidential. So, they wouldn't understand 11 something that was relayed to you in a conversation with 11 why she's reacting a? certain way, but I would know. 12 Christian? 12 And I would talk to "her and encourage her and tell 13 A. He talks to me sometimes. He might call me. 13 her, It's going to be okay, you know, God will work 14 on the phone, but because I've known him for so many 14 something out for you. 15 years, he feels comfortable telling me certain 15 Q. How often would she call and ask for prayers? 16 things and he was upset. 16 A. During this time, I would say probably once 1'7 Q. And so he called you to tell you that he was 17 a week for a little bit, you know, until she got 18 upset about the situation? 18 someplace to live. 19 A. Yeah. I think, if I had to say, I think 19 Q. Do you know how long it was in between the time 20 everybody in the house was upset. 20 that she could not move into the Fellowship apartment, 21 Q. Why would you say that? 21 until the time that she found a place to live? 22 A. Because if you plan on moving somewhere, 22 A. No, because like I said, I don't see her 23 you're get everything ready, especially being a kid, 23 always and I don't get into peoples' business, I try 24 and then all of a sudden it's snatched from you, 24 not to because I have my own affairs. But if I know U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 10 of 34 PageID #:1013 CLEMENTINE FRAZIER April 07, 2017 Page 30 Page 32 1 that this situation and I did.know about it, I may 1 Q. Did she pay you back? 2 call her and ask her how you doing, something like 2 A. I think the 700 she did, but the other times 3 that. So maybe about when she found someplace, 3 I didn't want payment. 4 though, she moved.around a lot, I think with her mom 4 Q. So you mentioned one time you thought that you 5 and another couple that helped wayward people. So 5 gave her $700 and she paid that back and then you 6 maybe about two weeks, maybe. I'm just guessing, 6 nentioned 300? 7 now. - 7 A. $300 to help on something that she needed, 8 Q. Has MB. Aldaco ever discussed her personal 8 the kids, school. Sometimes I would help her with 9 finances with you? 9 school clothes, buy things for them. It wasn't that 10 A. Not really. 10 often. She always tried to keep a job. She?s a 11 Q. Does she ever talk with you about money at all? 11 hard workerdon't think so. 12 Q. I just want to make sure I have the facts 13 Q. Has she ever mentioned having trouble 13 straight here. So you motioned that maybe three times 14 financially? 14 you gave her money and then there were other times in 15 A. Finding what? 15 which you helped her out getting school clothes or 16 Having trouble financially, has me. Aldaco ever? 16 things of that nature? 17 A. Oh, yes, she has discussed that with me. 17 A. Yeah, other things. 18 Q. How often would you say that you talked about 18 Q. And then there was a time you gave her $700; is 19 that? 19 that correct? 20 A. Only when maybe she didn't have a job and 20 A. Yes. 21 didn't have money for rent or something like that. 21 Q. And another time you gave her $300? 22 Q. Has she ever mentioned any credit card debt? 22 A. Um?hmm. 23 A. No, I think she was okay with that. She 23 Q. What I'm unclear on is, you mentioned three 24 didn't mention it to me. 24 times, do you remember how much money you gave her that Page 31 Page 33 1 ltmh?the? 2 whatsoever? 2 A. Sometime maybe 50 or something like that. 3 A. No. I think probably in our relationship 3 And I want to be very honest with you, it may have 4 some things were always discussed or personal and 4 been more than that, but I don't keep track, you 5 then things were real personal. I knew her 5 know, of how I bless someone. 6 financial situation when she told me, but I don't go 6 Q. When you would give her money, would you expect 7 into it, how many credit cards she had, that sort of 7 her to pay you back? 8 thing because I know that is sort of personal. I 8 A. No, no. It's just that with the 700, I 9 like to keep some boundaries, even in a friendship. 9 forgot the circumstances, she said I will pay you 10 Q. Has she ever asked you for a loan or any money? 10 back. But other than that, I would just give out 11 A. Years and years ago, when she really, you 11 the goodness of my heart, didn't expect anything in 12 know, was financially in situations. My husband and 12 return. I3 I would try to help her out. 13 Q. Has Ms. Aldaco ever spoken to you about her job? 14 Q. How many times would you say that that happened? 14 A. Which job? Any job? 15 A. Maybe about three. Three times or more.. 15 Q. we'll start with her present job. 16 Whenever we could help her. 16 A. No, other than the_fact that she has it. I 17 Q. So would you and your husband give her money when 17 don't even know where she works. I know she works 18 she asked? 18 as a customer service person, I think. 7 19 A. If we knew she needed it, yes. 19 Q. So you know that she currently has a job; is that 20 Q. How much money would you say that you gave her? 20 correct? 21 A. You know, over the years, I would say one 21 A. Yes, I knew that. 22 time it was $700 and maybe 300. Not big amounts, 22 Q. And she works in custcne: service? 23 just enough to help with food or whatever she may 23 A. Yes, I think she does. 24 have needed. 24 Q. But you don't know where? U.S. Legal Support, Inc. (312) 236?8352 Case: 1:16-Cv-05754 Document 51-4 Filed: 06/22/17 Page 11 of 34 PageID #:1014 CLEMENTINE FRAZIER April 07, 2017 Page 34 Page 36 1 A. Because it really didn't matter to me, as A. No, I think she left there for the job she 2 long as I knew she was working. 2 has now. 3 Q. Do you know how long she's been working in that 3 Q. Did she ever tell you why she left her job at 4 job? 4 Window Works? 5 A. You know that, I don't know either. Maybe A. No, I surmised that it might have been just 6 six months, four months, maybe longer. Like I said, 6 a mutual agreement because the people thereget too involved in peoples' lives. 7 Alex, the manager, but a lot of the coworkers were 8 Q. Do you Jmow if she ever worked for a coupany 8 goofing off and doing crazy kind of things, 9 called Window Works? 9 according to her. That's hearsay. And now that I'm 10 A. Yes. 10 thinking about it, I think she felt she wasn't being 11 Q. Do you Imow what she did there? 11 treated fairly there because I got the impression 12 A. Most of her jobs are customer service or 12 that she would go in and do her work and a lot of 13 customer specialist and sales kind of thing, she's 13 them would goof off and then she would have to do 14 really good at that. 14 some of their work and this was a constant kind of 15 Q. When she was working at Window Works did she ever 15 thing, I believe. 16 speak with you about that job? 16 Q. You mentioned it was a nutual agreement? A. Occasionally. 1'7 A. When I say that because they weren't 18 Q. What would you talk about? 18 treating her fair, I don't think and so she just 19 A. The job itself, you know, what she was 19 decided to, you know, leave. This is what -- 20 required to do and maybe occasionally about the 20 Q. So, is it your understanding that she decided to 21 people there. 21 leave that job on her own? 22 Q. Do you remember the names of any of the people 22 A. No, I guess when I say mutual agreement 23 that she worked with there? 23 means that, okay, when the employer decides maybe 24 A. I think I would hear her mention a guy named 24 it's better that you look for something else, you Page 35 Page 37 1 Alex. I think he might have been a manager, her 1 will agree rather than say you fired me or I quit 2 manager or something like that. Alex, I guess 2 it's a mutual thing.: That's what I mean by that. 3 that's his name. 3 Q. So did she ever tell you that she was asked to 4 Q. And what would she tell you about Alex? What 4 leave? 5 would you discussrI'hat he was a fair supervisor or manager. 6 Q. So is it just your impression that it was a 7 Q. At any point while Ms. Aldaco was working at 7 mutual agreement? Did you ever -- 8 Window Works, did she ever mention to you that she had 8 A. That's just my impression, simply because 9 been missing a lot of work? 9 when she would talk to me about how the employees 10 A. No. No more than maybe just to go to the 10 were doing there and then she was treated there, she 11 doctor or take one of her children. 11 just wasn't happy. 12 Q. You mentioned that she would miss work to go to 12 Now, her manager depended on her a lot and 13 the doctor. Did she ever tell you why she was going to 13 got along well with her according to her, but it was 14 the doctor? 14 the other employees that had been there for a long 15 A. Just a regular physical or, you know, 15 time. And I guess I probably understood because I 16 females do these once a year thing. Nothing l6 know that on every job there are people that would 17 serious. do the work and some will more or less perpetrate 18 Q. And the other reason that you gave that she said 18 and pretend that they're going it and that's the 19 she missed work was to take one of her kids to the 19 impression that I got. 20 doctor? 20 But as far as being asked to leave, I didn't 21 A. Yeah, take the kids to the doctor, something 21 get that impression. I thought it was just 22 like that. 22 something that you decided and they thought it was 23 Q. Did Ms. Aldaco ever -- well, sorry. 23 best, you know. And a lot of times employers will 24 Does Ms. Aldaco still work at Window Works? 24 do that. U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 12 of 34 PageID #:1015 CLEMENTINE FRAZIER April 07, 2017 Page 38 Page 40 1 Q. Did she ever mention to you that other employees 1 Q. Since we. Aldaco stopped working at Window works, 2 were being laid off? Other employees at Window WOrks, 2 have you spoken to anybody that works there? 3 ?ddmemrmm?m? 3 4 A. No. 4 MR. DUFFEY: WE've been going for about an hour 5 Q. I may just ask that again. 5 now, do you need to take a break? 6 A. Give me a chance to think for a second, that 6 THE: Oh, no, I'm okay. 7 other employees were being laid off? 7 BY MR. DUFFEY: Q. So I'll just go ahead and reask the question. 8 Q. Have you ever been to us. Aldaco's home? 9 Did we. Aldaco ever, at any point, ever mention to you 9 A. Yes. 10 that other enployees, so, any coworkers, were being laid 10 Q. How many times would you say you visited her 11 off at Window 11 home? 12 A. I'm not sure, really not sure. 12 A. I think I went when she showed me the place 13 Q. Did she ever mention to you any concerns that she 13 and one other time. Not that often. Like I said, I 14 was afraid that she may be laid off? 14 don't do a lot of visiting. 15 A. At one point, I think she did. 15 Q. And just to be clear, are you talking about where 16 Q. When did that occur? 16 she currently lives? 17 A. When the employees, her coworkers, started 17 A. Is that what you're talking about? 18 goofing off in their work, according to her. And 18 Q. That's a good point. Have you ever been to visit 19 she would get blamed for certain things and she 19 her where she currently lives? 20 would try to -- and what I told her, I said, maybe 20 A. Yeah, she had a birthday party for Christian 21 document, so that you can take it to management if 21 and she invited me. 22 you need to prove that you were doing certain 22 Q. When was that birthday party? 23 things. I do remember that. 23 A. Isn't that terrible, I don't know my 24 Q. Do you reumnber if she ever documented? 24 Godchild's birthday. Maybe sometime in September. Page 39 Page 41 1 A. She said she had documented things. 1 I think that's when his birthday is. He always 2 Q. Did you ever see? 2 said, Ms. Clem, you forget my birthday. 3 A. No, I never saw it, I just told her to do 3 Q. And how many times have you been to visit her at 4 that. 4 that current address? 5 Q. Have you ever spoken to anyone else that worked 5 A. Where she lives now? Let's see. Maybe 6 at Window works? 6 twice. 7 A. No. Oh, yes, I'm sorry. Alex, her manager. 7 Q. Do you know how long she's been living at the 8 She was telling me what a nice place it was to work 8 current address? 9 and at the time I thought about looking for a job, 9 A. I think over a year, I'm not sure when she 10 so I had sent my resume to him and he called me to 10 moved in, but I think maybe about a year, maybe a 11 have me come in, he was very interested. But I 11 little longer. 12 declined, I told him I had changed my mind. 12 Q. Do you know where she lived before that? 13 Q. And why did you change your mind? 13 A. Let me think. After this situation, I know 14 A. Because it was too much confusion going on 14 she was staying with her mom some and she was 15 there and I didn't want to walk into any of that. 15 staying with her sister and then she was moved with 16 Q. What do you mean by confusion? 16 Ben and Cindy, that's a couple that sometimes help 17 A. With the coworkers doing crazy things and 17 women that have children. I think that may have 18 she was always having to talk to a manager or say 18 been her last place before she moved in. 19 something and I thought, no, I don't want that. And 19 Q. So let's take that in parts, if we could. Do you 20 it may not have been that way, but that was my 20 know how long she was living with her moving 21 impression, so I didn't want to walk into any 21 into her current address? 22 ccnpeny like that. He would have hired me, I knew, 22 A. A short time because it's all the way in 23 because he had already, you know, but I declined the 23 Chicago and the neighborhood wasn't too good. So I 24 position. 24 would say maybe a month. The kids didn't like it U.S. (312) Legal Support, 236?8352 Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 13 of 34 PageID #:1016 CLEMENTINE FRAZIER April 07, 2017 Page 42 Page 44 1 because it was dangerous to walk the streets. 1 lives? 2 Q. Did you ever go visit her at that address? 2 A. Yes, yesDid you ever visit her more than once at the 4 Q. Do you know where that address is in Chicago? 4 apartment in Bloam'ngdale? 5 A. No, it's around 25th and she just always 5 A. I think I went with her just to look at the 6 told me it was really rough and Christian didn't 6 place and then I went once to visit her because they 7 like it because he was scared to go out. 7 had a big dog next door and I was scared of dogs. 8 Q. And then you mentioned that she lived with her 8 It was only one time I think I went there. And it 9 sister for a while? 9 was off Lake Street I think it was. I don't know 10 A. Not lived with her, maybe just a short time, 10 the address, though. You know what, I'm trying to 11 just two weeks, maybe. Not even. 11 think if it's Bloomingdale, if it was a border. It 12 Q. Do you know what her sister's name is? 12 was on Lake Street. Glen Ellyn? No. I think Glen 13 A. Lorena. 13 Ellyn was where I would turn, Glen Ellynyou know where Lorena lives? 14 believe it was in Bloomingdale. I better stick with 15 A. Plainfield, that's all I know, way out. 15 that, because that sounds very familiar to me. 16 Q. Did you ever go visit her when she was living 16 Q. So your recollection is she lived in an apartment 17 with Lorena in Plainfield? 1'7 in Blooudngdale? 18 A. No, I've never been to Lorena's house. 18 A. Off Lake Street. 19 Q. And you also mentioned Ben and Cindy. Do you 19 Q. Off Lake Street near Glen Ellyn? 20 know what their last name is? 20 A. Street, yeah. 21 A. No, I always heard her refer to them as Ben 21 Q. And that she lived at that address for about a 22 and Cindy, but I don't know their last name. 22 year? 23 Q. Do you know how long she lived with them? 23 A. I think about a year. 24 A. Maybe about six months, I'm guessing now. 24 Q. Do you ever remember a time when Ms. Aldaco did Page 43 Page 45 1 Q. And do you know where they live? 1 not have a place to live? 2 A. All I know is they live in Schaumburg. You 2 A. When I said she was with her sister, her 3 know what, I just thought of something and I want to 3 mom, Ben and Cindy, she didn't have place to live. 4 go back. You asked me where, after she was declined 4 Q. Do you ever remember a time in which she was 5 here and where she's living now is what you said. I 5 living in her car? 6 think there was an apartment in between in 6 A. I'm not sure. Because I know that she was 7 Bloomingdale. I just remembered that. 7 sort of homeless there for a while. But she might 8 Q. So to clarify, after she did not move into the 8 not have mentioned that to me. I know this was a 9 Fellowship Housing apartment. She moved to another 9 very bad situation for her, because she didn't know 10 apartment in is that what you said? 10 where she was going to go. 11 A. Bloomingdale. But I don't know the address, 11 Q. So I want to make sure that I'm clear on the 12 I remember going there one time. 12 timeline here. So, starting with when Ms. Aldaco did 13 Q. Do you remember how long she lived there? 13 not move into the Fellowship apartment, after that, you 14 A. Probably a year, until the next lease or 14 mentioned that she lived in several different locations? 15 something. I think it was about a year. 15 A. um-hmm. 16 Q. So you believe she lived in an apartment in 16 Q. So for a little while she stayed with her mom; is 17 for about a year after she -- 17 that correct? 18 A. After she left Ben and Cindy. These were 18 A. Yes. 19 transient kind of places, when I say her sister, her 19 Q. And then you recalled a little bit of time that 20 mom, Ben and Cindy and then she moved into an 20 she stayed with her sister? 21 apartment for about a year. I think it was about a 21 A. Uh?hmm. 22 year because I went there one time to visit. 22 Q. And then a little bit of time where she stayed 23 Q. And this apartment in Bloomingdale that you want 23 with Ben and Cindy? 24 to visit, is that different she currently 24 A. Yes. But time wise I don?t know how long. U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 14 of 34 PageID #:1017 CLEMENTINE FRAZIER April 07, 2017 Page 46 Page 48 1 I just know that she had mentioned that she was 1 names of the people trying to help her or whatever 2 staying in their home. 2 and I just didn't make note of, you know, who it 3 Q. And then after the time that she was staying with 3 was. . 4 Ben and Cindy, your recollection is that she moved into 4 Q. Do you remember helping Ms. Aldaco with her 5 an apartment in Bloomingdale? 5 application to join the fellowship housing corporation 6 A. Yeah. 6 program in any way? 7 Q. And then after the time that she lived in 7 A. No. 8 Bloomingdale, is that when she moved into her current 8 Q. So I'm showing you what has previously been 9 address? . 9 marked as Defendant's Exhibit 7. 10 A. I think that's it, mn?hmm. Hanover Park. 10 A. Um-hmm. 11 Q. We've talked a little bit about this already 11 Q. If you want to take a minute to look over that. 12 today, but have you heard of an organization called the reference, but I 13 Fellowship Housing Corporation? 13 really don't recall talking to anyone. She might 14 A. I hadn't until she just mentioned it. I 14 have just, I don't know. 15 still don't know much about them or who they are, 15 Q. Have you ever seen this document before? 16 it's just what she told me. 16 A. No. 17 Q. Based on your understanding, what do you 17 Q. Do you recognize any of the handwriting on the 18 understand the Fellowship Housing Corporation to be? 18 document? 19 A. From her telling me, I understood it to be 19 A. The handwriting? I see her signature, but I 20 an organization, I guess, to help women with 20 don't know about the printing. But I see her 21 children of a certain age, move into different 21 signature is here, that's about all I recognize. 22 housing. And they will assist with their rent and the second page on 23 helping them get on their feet for about a year, I 23 Exhibit 7 your name is listed as a reference? 24 think it is or two years. And help them to manage 24 A. Yes, I see that. Page Page 49 1 their finances and all of those things. That's 1 Q. And it says relationship to you, friend, slash, 2 basically all I know about it. 2 mentor. would you say that's an accurate description of 3 Q. And the information that you have about the 3 your relationship? 4 Fellowship Housing Corporation, did that come fnon 4 A. Yes. 5 Rafaela? 5 Q. And then there is a telephone number listed 6 A. Yes, it came from her. 6 there. Is that -- was that your telephone number at one 7 Q. Have you ever spoken with anyone else about the 7 point in time? 8 Fellowship Housing Corporation? 8 A. Yes, that is still my telephone number, my 9 9 10 Q. Have you ever done any independent reading or 10 Q. And then just above the names and Keith 11 research into the Fellowship Housing Corporation? 11 McPherson it says, May we contact this person? And 12 A. I was interested, naturally, because she's 12 there is an in the line next to yes. 13 someone that I love. But I never really pursued 13 A. Um-hmm. l4 finding out who are these people. I just didn't. 14 Q. were you ever contacted by anyone at the 15 Have you ever met anyone that works at the 15 Fellowship Housing Corporation? 16 Fellowship Housing Corporation? 16 Al I don't recall. I don't recall. I know 17 A. No. 17 that when people ask me for employment reference, 18 Q. Have you ever spoken to anyone there? 18 like a resume or something, but I don't really 19 A. No. 19 recall talking to anyone regarding, from this place. 20 Q. Have you ever heard the name Heather Corens? 20 Q. Is there anything that would refresh your 21 A. No, she mentioned.like names, but I didn't 21 recollection as to whether you ever spoke with anyone at 22 make note of them. 22 the Fellowship Housing Corporation? 23 Q. Have you ever heard of the name Rachel Paul? 23 A. Probably maybe if I knew what they may have 24 A. No. But again she would make mention of 24 wanted any names, I don't U.S. Legal Support, 236-8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 15 of 34 PageID #:1018 CLEMENTINE FRAZIER April 07, 2017 Page 50 Page 52 1 recall. 1 hard time, what do you mean by that? 2 Q. Did Ms. Aidaco ever tell you that the Fellowship 2 A. I guess I understood that it was an 3 Housing Corporation had found her an apartment to live 3 apartment and being an apartment, she would have to 4 in? 4 meet him and he would give her the key and show her 5 A. Yes, she did tell me that. And she called 5 where to move in, but something with him not wanting 6 me the day when she was going there to move in. 6 to have her move in until he checks something, I 7 Q. So, she told you that they had found her an '7 guess. And she was upset because she felt that the 8 apartment to live in. Did she tell you that the day she 8 sponsor who was there with her, they had already 9 was going to move in or was there a conversation before 9 done that, so he was asking for something that was 10 the day that she was going to move in, where she gave 10 unnecessary. 11 you that information? 11 Q. Do you remember what it was that needed to be 12 A. She might have told me a few days before, 12 done before she could move in? 13 oh, I found something, they approved me and I'm 13 A. I guess a reference, reference check or 14 going to move in. That's how the conversation went. 14 reference or something with reference, I guess. A 15 Q. How would you describe her reaction to the 15 background check, maybe that's what I should say. 16 information that she was going to be roving into the 16 Q. So, are you aware of any dispute regarding a 1'7 apartment? 17 background check? 18 A. I think she was very excited, you know, 18 MS. TATAR: I'm just going to object to the 19 especially when you moving around, she was excited, 19 question that it's vague and ambiguous. Form of the 20 Christian was excited. 20 question, but go ahead. 21 Q. So did you speak with Christian also about the 21 BY MR. DUFFEY: 22 fact -- 22 Q. You can answer the question. Are you aware of 23 A. No, I didn't talk to him. 23 any dispute regarding a background check? 24 Q. So it was just your general impression that 24 A. No, not really. I'm just saying from the Page 51 . Page 53 1 Christian was excited? I moment she was supposed to meet, the sponsor was 2 A. Yeah, I guess I shouldn't have said that, 2 with her, they were there and then I guess all of 3 huh? And I'm saying that because I know he was 3 this developed and that's it, but I don't know 4 really upset about having somewhere to live and then 4 anything else. 5 when his mom told him that you and I are going to 5 Q. The information you have about Ms. Aldaco's 6 live there. I know him and I know he was excited. 6 interaction with the landlord, were you present for any '7 Q. Did Ms. Aldaco ever move into the Fellowship '7 of that? 8 Housing Corporation apartment? 8 A. Oh, no. No.1 9 A. Not to my knowledge. 9 Q. Is the information that you have, was that all 10 Q. Do you lmow why not? 10 canmmicated to youby Ms. Aldaco? 11 A. I thought she told me that they had denied 11 A. Yes, um?hmm. 12 her moving in or there was some trouble with her 12 Q. Has Ms. Aldaco ever told you that a background 13 moving in. 13 check that was conducted on her showed a criminal 14 Q. Do you remember what the trouble was with her 14 record? 15 moving in? 15 A. No. I'm surprised of this myself. 16 A. Let me think for a moment. She was going to 16 Q. I'm showing you what's previously been mark as 17 move in and then she said something about when she 17 Defendant's Exhibit 9 and it is a certified statement of 18 got there with whoever the sponsor was, from 18 conviction, slash, disposition from Case 19 Fellowship Housing, that the landlord there was 19 No. 96401466301, People of the State of Illinois versus 20 giving her a hard time. And supposedly what the 20 Rafaela Aldaco? 21 landlord wanted had already been done, as far as 21 A. Um?hmm. 22 reference checks and all of that. That's about what 22 Q. Have you ever seen Exhibit 9 before? 23 she told me on the phone. 23 A. This? No. 24 Q. When you said that the landlord was giving her a 24 Q. You'll see near the top of the document, there is U.S. Legal Support, Inc. (312) 236-8352 Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 16 of 34 PageID #:1019 CLEMENTINE FRAZIER April 0 '7 2 0 1'71 Page 54 Page 56 1 sane language there that says the State's Attorney of 1 Q. When did you have this conversation where she 2 Cook County, slash, local prosecutor has filed a 2 mentioned that Adrian's father used to beat her? 3 canplaint with the clerk of the circuit court charging 3 A. When I first met her, way back when, maybe 4 the above named defendant with MR, battery. 4 back in 2002 when I first met her or maybe 2003. 5 Do you see that language? Do you see that language? 5 They were young and they had, I guess, little spouts 6 A. Yes, I do. 6 or whatever. 7 Q. Has Ms. Aldaco ever told you that at one point in 7 Q. You mentioned a more recent conversation in which 8 time she was charged with battery? 8 Ms. Aldaco told you that there was some confusion with 9 A. No. 9 court recordslittle bit further down the docmnent, 10 A. Um-hmm. 11 you'll see some dates with sane words next to them. And 11 Q. When did that conversation occur? 12 one date is December 17th, 1996. And in all capital 12 A. I think maybe after she was denied the 13 letters there, it says plea of guilty. 13 housing. She may have mentioned something about a 14 A. Plea of guilty, I don't see that. Oh, yeah, 14. background check. I didn't go into it, because I 15 I see it, 12/17/96. 15 don't like to be snooping in people's business, but 16 Q. Has Ms. Aldaco ever told you that she pled guilty 16 I just let her tell me and she said something they 17 to a crime? had found, but I didn't know exactly what it was. 18 A. No. That's one of those boundary kind of 18 Q. Do you remember any specific words that she used 19 things, you know. I never heard her say nothing 19 in that conversation? 20 about that. 20 A. She did say batter, but I was thinking that 21 Q. A few lines beneath that, it says 12/17/96, 21 she was talking about her boyfriend battering, they 22 finding of guilty. 22 got into a spout or something, the policemen had to 23 A. Yes, I see that. 23 be called. And that was what was found on her 24 Q. Has she ever mentioned that there was a finding 24 record. Page 55 Page 57 1 of guilty in a case that involved her and a charge of 1 Q. Do you remember if this was a telephone call? 2 battery? 2 A. Yeah, it was on the phone. 3 A. No. 3 Q. Have you spoken with anyone else about this 4 Q. And then beneath that it says 12/17/96, sentenced 4 situation? 5 to camuinity service. Has Ms. Aldaco ever told you that 5 A. No. Because it's confidential and I don't 6 at one point in time she was sentenced to conmunity 6 do that. I'm surprised to see her name on here. 7 service by a court? '7 Q. Do you know if Ms. Aldaco was still involved in 8 A. No. 8 any way with the Fellowship Housing Corporation? 9 Q. Has Ms. Aldaco ever told you that she received a 9 A. The last time I talked with her, which I 10 document from the court saying that she had been charged 10 don't remember, they were trying to, I guess, 11 with battery or that she pled guilty to battery? 11 rectify the situation, maybe find her someplace to 12 A. No. She did mention about, I guess, the 12 live, I don't know for sure or help her. 13 boyfriend or Adrian's father would beat her or 13 Q. Has Ms. Aldaco ever mentioned to you that she is 14 batter her or something, but that was as far as that 14 no longer involved in the Fellowship Housing 15 went. I didn't know all of this, none of this. 15 Corporation? 16 Q. Did she ever say anything to you about Adrian's 16 A. No, I thought she was still involved. I 17 father battering her and the court making a mistake and 17 didn't know. 18 putting her name on the court record? 18 Q. So do you know, one way or the other, whether or 19 A. She did say something just recently about 19 not she is still allowed to participate in the 20 that and I didn't know what she was talking about, 20 Fellowship Housing Corporation? 21 but I think he used to beat her and that's all I 21 A. I don't know, because she hasn't said 22 know about that. He used to beat her, but I didn't 22 anything, so I don't know. 23 know that she was charged with that, I didn't know 23 Q. We talked a little bit earlier today about 24 anything about that. 24 changes in Ms. Aldaco's behavior after she couldn't move U.S. Legal Support, 236?8352 (312) Inc . Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 17 of 34 PageID #:1020 CLEMENTINE FRAZIER April 07, 2017 Page 58 Page 60 1 into the Fellowship Housing's apartment. Can you 1 standpoint, she was depressed. And she said that 2 describe any changes you've noticed in her behavior 2 she would sleep a lot and cry or couldn't sleep. 3 since the time that she did not move into the Fellowship 3 So, I knew that wasn't her normal self because she's 4 apartment? 4 usually a bubbly kind of person and I knew something 5 A. Disappointment, frustration, anger, 5 was going on and she had headaches, too. She would 6 helpless. - 6 have headaches. I told her to go see a doctor I did 7 Q. So you mentioned disappointed, frustration, anger 7 recommend that. 8 and helpless. Are these things that you've observed or 8 Q. Do you know if she ever went to go see a doctor? 9 are these things that Ms. Aldaco has connmnicated to 9 A. I think she did. 10 you? 10 Q. Do you law who that doctor is? 11 A. She has communicated and I've already 11 A. No. No, I don't. I really don't. His 12 observed. 12 name, I don't know. 13 Q. Has she ccnumnicated these things to you? 13 Q. Do you know where he's located? 14 A. When she would come to class, I noticed she 14 A. No. I didn't know any of that. 15 would cry sometimes and no one knew what was going 15 Q. You mentioned that Ms. Aldaco had headaches, have 16 on, but I knew that she was just frustrated and what 16 you ever actually seen her experience one of these 17 am I going to do, kind of thing. Sometimes at 17 headaches? 18 church she might ask me to pray for her or she'll 13 A. Sometimes maybe in class she would be so 19 call me on the phone. I probably would say she 19 quiet and I knew she was having one, because like I 20 wasn't herself. 20 said, she's very outgoing, she's an extrovert, but 21 Q. After Ms. Aldaco did not move into the Fellowship 21 she was very like in herself. And she would say she 22 Housing apartment, did you ever notice her 22 had a back headache or I'm not sleeping and that's 23 depressed? 23 when I recommended her to go to see a physician. 24 A. Yes. 24 Q. How many times have you seen her experienced one Page 59 Page 61 1 Q. Have you noticed her become more anxious? 1 of these headaches? 2 A. Yes, I would probably say depression and 2 Maybe two or these times. 3 anxiety go hand in handthose two or three times, has this all 4 either. 4 been after she did not move into the Fellowship Housing 5 Q. That was going to be my next question. 5 apartments? 6 A. Have you got a degree in it? No, I haven't, 6 A. It's a culmination of her not moving in, 7 but I know enough about ladies' personalities and 7 having nowhere to live and just not knowing what 8 moods and things like that, so I'm making it from a 8 she's going to do. 9 layman's, probably, observation. 9 Q. My question is more just based on the actual 10 Q. And just to clarify. Do you have any medical or 10 timeframe that the headaches occurred. So, would you 11 mental health training? 11 say that when you've witnessed these headaches, every 12 A. No. Other than in college, I took 12 time that you've witnessed them it has been after she 13 and took but other than 13 didn't move into that apartment or did this ever occur 14 that, no. 14 before she did not move into the apartment? 15 Q. Do you have the ability to medically diagnose 15 A. After. 16 depression or anxiety? 16 Q. Did you ever keep any notes or records of having 17 A. From a layman's standpoint I would say. 17 witnessed her have these headaches? 18 Q. But from.a professional standpointDid Ms. Aldaco ever tell you she, in fact, did go 20 Q. Since Ms. Aldaco did not move into the fellowship 20 see a doctor for these headaches? 21 housing apartment, have you ever told her at any point 21 A. Yes. And I'm thinking -- I think I might 22 that you thought that she should seek medical treatment? 22 have gone with her to see a doctor, because I'm 23 A. YES, I did, because she was very, very, I 23 sitting here looking at you and I'm thinking one 24 felt, again, this is observation from a layman's 24 time I did go with her, but I waited out in the Legal Support, Inc. (312) 236~8352 Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 18 of 34 PageID #:1021 CLEMENTINE FRAZIER April 07, 2017 Page 62 Page 64 1 waiting room. I didn't go in because I insist on 1 might have gone out to lunch and sat and talked, 2 her going to the doctor, so I said I'll go with you, 2 because we did do that a few times. 3 but who it was, it's been a while. 3 Q. Do you renumber where you went to lunch when you 4? Q. Do you have any recollection of where you went 4 talked about these issues? 5 with her to see the doctor? Was it a hospital? 5 A. We might go to Denny's, something like thatmedical center, I think. You 6 A place where you could sit and talk for a while '7 know like an office, that's office. But where I do 7 without them wanting you to leave. 8 not know. I guess because I never thought one day I 8 Q. And when you would go to these lunches and talk 9 would have to sit here, and say. I have no clue. 9 about these issues of her being ashamed or upset to talk 10 Q. Is there anything that would refresh your 10 to her children about the apartment situation, was it 11 recollection as to where this doctor visit occurred? 11 usually just you and her or would other people also be 12 A. No, not even his name. 12 at the lunch? 13 Q. Did you ever witness Ms. Aldaco vunit due to one 13 A. Oh, no, she was very private. She confided 14 of these headaches? 14 in me, so it would just be us and I wouldn't tell 15 A. I'm not sure. 15 anyone. 16 Q. Did she ever tell you -- 16 Q. Did she ever say anything or did she ever tell 17 A. I know she would tell me sometimes she was 1'7 you that she felt she had failed her children because 18 sick to her stomach. 18 she could not move into the Fellowship Housing 19 Q. And when she would tell you that she was sick to 19 apartnent? . 20 her stomach, did she also say she was having headaches 20 A. Maybe not in so many words, but the 21 at that time? 21 inpression because they were upset and it's like, 22 A. Yes, urn-1mm. 22 what do I tell them, 7 what do I do. That's mainly. 23 Q. About how many times would you say that she told 23 Q. So just to clarify, was it your impression that 24 you that she was vomiting because of headaches? 24 she felt that way? Page 63 Page 65 1 A. Maybe a couple times. 1 A. She would tell me when we talked like, you 2 Q. Did Ms. Aldaco ever say to you that she was 2 know, I hate to tell- them or I hate that we're going 3 ashamed or embarrassed to talk to her children about not 3 through this again. Kind of thing. She would say 4 being able to move into the Fellowship apartment. 4 something like that to me. 5 A. Yes. I would say yes. 5 Q. Did she ever tell you that she felt guilty about 6 Q. How rany times would you say that you had a 6 not being able to live at the apartment? 7 conversation where she mentioned that? 7 A. Not so much guilty. I think she felt, it's 8 A. Maybe about three times. 8 not my fault kind of thing. 9 Q. Do you remember any of those conversations 9 Q. Has Ms. Aldaco ever described herself as homeless 10 Specifically? 10 to you? 11 A. As I mentioned earlier, Christian was going 11 A. In all the years I?ve known them, you mean? 12 to move in with her and she was concerned that, you 12 9. Yes. 13 know, she would have to tell him that we're not 13 A. I think way back when she might have been 14 going to move and the disappointment there and the 14 and even in this situation, but because she had 15 schools and all of that. 15 people she could call, you might not necessarily 16 And Adrian was disappointed because they had 16 define it as homeless, but because I have always had 17 to move so many times and she was like here we go 17 a home, I would say it was homeless. And she would 18 again. They think that I'm not stable and I don't 18 say it too, you know, she would say, I just don?t 19 know where I'm going to live kind of thing. And I 19 know where I'm going to live. I'm homeless. 20 think I might have responded like, you know, it 20 Q. And just to clarify, you mentioned first this 21 happens, you just explain the best you can to them. 21 happened way back when. When you say way back when, 22 Q. 'And did that conversation happen over the phone 22 what do you mean by that? 23 or was it in person? 23 A. So many years ago. 24 A. Mainly over the phone. And then, too, we 24 Q. Would you say more than five years ago? U.S. (312) Legal Support, 236?8352 Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 19 of 34 PageID #:1022 CLEMENTINE FRAZIER April 07, 2017 Page 66 Page 68 1 A. Oh, yes, 2002 it goes way back. 1 standpoint because I'm a different kind of person, 2 Q. So, right when you very first met MB. Aldaco? 2 but her self esteem suffered and she didn't have a 3 A. I think there was a circumstance where she 3 lot of confidence in herself. 4 had to live with her mom one time. But the 4 Q. You mentioned a couple of times today some 5 circumstances, I don't remember. 5 unprofessional work at Window works. Did Ms. Aldaco 6 Q. And then you mentioned a second time, more. 6 ever commn?oate to you any specific instances of '7 recently? 7 unprofessional behavior? 8 A. With this situation. . 8 A. Yes, she did. 9 Q. Has she specifically described herself as 9 Q. What were those -- what sorts of behavior would 10 homeless to you, with regard to the Fellowship Housing 10 you -- what sorts of behavior did she conmmicate to you 11 situation? 11 that you have characterized at unprofessional? 12 A. She said, I don't know where I'm going to 12 A. For one thing, the coworkers, people that 13 live. I don't know if you could consider that 13 had been there for a while, they would go out and 14 saying I'm homeless because she had nowhere to go. 14 smoke pot and she could smell it and sometimes she 15 So, I probably say that would be homeless. She was 15 would get headaches from it and the management 16 at the mercy of people. 16 didn't do anything. Or else they would talk nasty 17 Q. Has Ms. Aldaco, since not moving into the 17 to her or give her work that wasn't her that they 18 Fellowship apartment, has she ever described herself to 18 should have been doing those kind of things. And I 19 you as having low self esteem? 19 told her that she should go to HR, but being a small 20 A. She did, but I would try to encourage her, 20 company like that, HR didn't seem to do very much. 21 tell her, you know. 21 Q. Do you know if she ever did go to HR at Window 22 Q. Has many times has she told you that she feels 22 Works? 23 she has low self esteem? 23 A. She said she didProbably a couple of times in our 24 the record that she went. And I think she even Page 67 Page 69 1 conversations. 1 talked to Alex her manager but, again, he wanted to 2 Q. WUuld these conversations be in person or over 2 keep peace and this is just my, keep peace, so 3 the phone? 3 .sometimes she would be frustrated there. And they 4 A. Most of the time it was phone. Like I say, 4 would swear and I say unprofessional, because I am 5 I didn?t meet with her a lot, just more over the 5 very professional and plus I was in HR for years. 6 phone. 6 So I did consider the things at that she was telling 7 Q. And you said that when these conversations 7 me as unprofessional because you don't do that at a 8 happened, you would offer her encouragement, is that 8 company. - 9 correct? 9 Q. Do you remember Ms. Aldaco ever being bedridden 10 A. Yes, because she felt, you know, that I 10 after the Fellowship Housing incident? 11 think a lot of times I think she felt from the jobs, 11 A. No. Maybe I should ask you, if I could, 12 you know, because she looked at herself, sometimes 12 what do you mean by bedridden, because I think of 13 neybe like a doormat and I would tell her don't let 13 bedridden as someone that is ill and can't get out 14 people walk over youhas some kind of sickness, is that what 15 floor, that kind of thing, but she felt that. 15 you mean? 16 Q. Before she -- before the Fellowship Housing 16 Q. I guess I'll rephrase it. Do you ever remember 17 incident, had she ever described herself as having low 1'7 her sleeping all day after the incident? And by the 18 self esteem before that? 18 incident I mean when she did not some into the 19 A. Probably maybe at Window WOrks because they 19 Fellowship Housing apartment. 20 would -- I felt when she would tell me things that 20 A. Like I said, my opinions of her being 21 they were doing, I thought it was very 21 depressed was that she would not want to do 22 unprofessional and she would go to human resources 22 anything. You know, she would sleep and I know that 23 and try to tell them, but she would also take 23 to be one of the because my sister years 24 whatever they did. And I may be saying that from a 24 ago had that and she didn't want to clean the house, U.S. Legal Support, 236-8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 20 of 34 PageID #:1023 CLEMENTINE FRAZIER April 07, 2017 Page '70 Page 72 1 do anything. Just lay in bed and I told her, get 1 after the situation? 2 up, get up and pull yourself together. But it 2 A. Many times. You need a number, maybe 10 3 wasn't a long period of time where she was 3 times. And I would try to console her and I'm not 4 bedridden. She might for a week just be depressed. 4 too good at that because I'll cry with you. 5 Q. I've 5 Q. 6 been laying in bed all week or what were those 6 meetings or over the phone or both? 7 conversations like? '7 A. I would say both. 8 A. She would call me and say, Clem, I'm not 8 Q. And how long would she typically cry while you 9 sleeping and I just don't want to do anything, I. 9 were talking to her? 10 feel like I just want to sleep kind of thing and I 10 A. She would cry long enough and hard enough 11 knew those were of depression, a mild form 11 that I felt I needed to console her. She was 12 of depression, I should say. 12 talking and beginning to cry. And I felt like when 13 Q. Did you ever visit her at her bane when she was 13 she was doing that, what am I going to do about my 14 experiencing these or not getting out of bed? 14 situation, and I would encourage her and just tell 15 A. No. 15 her it's going to get better, that kind of crying. 16 Q. Do you ever remanber a Ms. Aldaco seeming 16 Q. Would she ever stop crying during these 17 particularly tired after the Fellowship Housing 17 conversations after you gave her some encouragement? 18 incident? 18 A. Yeah, she would, but then she might go home 19 A. Tired. And her she was showing all 19 and cry some more and call me back and say, you 20 go together. Tired, not wanting to do your dishes, 20 know. I think maybe it was certain moments would 21 wanting just to sleep, I consider them all together. 21 bring on certain things. 22 Q. Do you remember Ms. Aldaco gaining any weight? 22 Q. What sort of would bring on this crying? 23 A. Yeah, she has put on some weight, compared 23 A. When she would look at situation, whatever 24 to how she was. And I surmised that to be sometimes 24 it may he, didn't have the job or people were doing Page '71 Page '73 1 people can be depressed and they will either not eat 1 certain things or where am I going to live, kids are 2 or they will eat and I felt that she was more or 2 upset, those kind of situations. 3 less just eatingfair to say that you've seen her cry in 4 Q. When did this weight gain start? . 4 more circumstances other than those related to the 5 A. Over the year that you notice a lot of it. 5 incident where she did not move into the Fellowship 6 Q. So, over the past year? 6 apartment. 7 A. Yes, somewhere in there. 7 MS. TATAR: Objection to the question as vague, 8 Q. How much weight would you say she gained? 8 but you can answer the question. 9 A. Maybe about 50 pounds. And I'm not too good 9 THE WITNESS: Over the years I've known her, she 10 at that, because I need to lose weight myself, but I 10 would cry, but not hard cry. She was hurting, 11 just noticed that she was heavier than I had ever 11 that's probably the way I would say. There is 12 seen her before. 12 different ways people cry. And when. you're hurting 13 Q. In the time, the entire time that you've known 13 there is a different cry because you can feel that 14 Ms. Aldaco, did you ever notice any fluctuations or 14 person's heart and I think when she would cry, I 15 changes in her weight prior to this past year? 15 would feel her heart. If that explains it to you. 16 A. No. Not to the degree that she is now. 16 BY MR. DUFFEY: Maybe a pound here or whatever, but it wasn't so Q. I guess. Other than when she did not move into 18 noticeable. 18 the fellowship housing apartment, are there any other 19 Q. Did you ever see Ms. Aldaco cry at any point 19 things that you have witnessed that have made her cry? 20 after the Fellowship Housing situation? 20 A. Oh, sure, sure. 21 A. She cried, yeah, a lot. 21 Q. What sorts of things? 22 Q. How many times -- 22 A. When her mom was sick and had surgery. When 23 A. She is a cry baby. 23 her dad needs open heart surgery now, so -- or when 24 24 she was sad about the kids, she would cry. Q. How many times would you say you've seen her cry U.S. Legal Support, Inc. (312) 236?8352 Case: 1:16-cv-05754 Dooument 51-4 Filed: 06/22/17 Page 21 of 34 PageID #:1024 CLEMENTINE FRAZIER April 07, 2017 Page 74 Page 76 1 MR. DUFFEY: I think it might be a good time to A. I think she had more long?term type 2 take a break. 2 situation, I think. "That's been a little while. 3 THE: WITNESS: I'm okay, unless you need a break, 3 Q. Do you remember where she lived before the 4 we can keep going. 4 Fellowship Housing apartment availability happened? 5 MR. DUFFEY: I need a break. 5 A. I'm not sure if I'm confusing the last -- 6 (Break taken.) 6 not this apartment, but the last one with where it 7 BY MR. DUFFEY: 7 was before she moved in, I'm not sure. She had a 8 Q. So, over the course of the day, you've told me a 8 regular permanentplace, but I'm not sure if was 9 few different places that Ms. Aldaco has lived. At any 9 before or if it was after. I thought it was after, 10 point in time, has she ever lived with you? 10 but I'm not sure. 11 A. No. Not because I didn't want her to, but 11 Q. So, in terms of the regular permanent place, 12 because my husband felt that that's our home and 12 would that be the apartment in Bloaningdale that you 13 even as close as we were, maybe a night or so, early 13 referenced before? 14 on, when I first met her or something, and the kids, 14 A. That may be what I'm thinking, I'm not sure. 15 but not move in. 15 Q. So, is it your testiuoxw that it could have been 16 Q. So she may have stayed with you for a night at 16 before the Fellowship Housing apartment became available 17 sane point in time? 17 that she lived at that Blomu'ngdale address? 18 A. Yeah, something, years and years ago, maybe. 18 A. Yes, that may be, I'm not sure. I guess I 19 Q. Did she ever stay with you for a night after she 19 have to say that, that way. 20 did not move into the Fellowship Housing apartnent? 20 Q. Do you ever remember Ms. Aldaco's housing 21 A. No. 21 situation, before the fellowship housing apartment 22 Q. You've also mentioned a number of times today 22 became available, do you ever remember her housing 23 that the Fellowship Housing situation caused stress on 23 situation at that time causing stress? 24 Rafaela and her family; is that fair to say? 24 A. No, because she had places to live and Page '75 . Page 77 1 A. Yes. 1 long?term. Because she lived, way before that, 2 Q. Over the time that you've known Ms. Aldaco have 2 at where was it, 'Schaumburg, Palatine, it's on 3 there ever been any other situations that have caused 3 the border. She had a nice place there. But that 4 her stress? 4 was way before the housing. 5 A. I'm sure. Probably financial situationnice place in or around Schamnburg 6 Not having enough money. 6 or Palatine? '7 Q. So would she call you and say that she was 7 A. Yeah, somewhere in that area. 8 stressed because she didn't have enough money or did she 8 Q. And that was before the Fellowship Housing 9 cmmicate this stress to you? 9 Corporation housing became available? 10 A. She would probably communication to me, 10 A. Yes. 11 that, you know, I don't have enough money, something 11 Q. And was she still living at that nice place 12 like that. 12 before the fellowship housing apartment became 13 Q. Did any of her children ever camw?cate stress 13 available? 3 14 about the family's money situation to you? 14 A. She might have moved to the one I'm talking 15 A. No. Kids don't usually -- they think their 15 about in Bloomingdale. 16 parents are rich most of the time, they don't -- 16 Q. Okay. Do you ever remember Ms. Aldaco's children 17 they didn't do that. 1'7 at any point, before this Fellowship Housing apartment 18 Q. Before Ms. Aldaco was going to move into this 18 incident, do you ever remember them calling you and 19 fellowship apartment, do you remember what her living 19 expressing any stress about the family situation? 20 situation was? 20 A. No, not really. 21 A. In what way? 21 Q. Does Ms. Aldaco ever speak with you about 22 Q. Do you lmow if she had long-term housing before 22 romantic interests or relationships with men? 23 that or was it a more transient situation like you 23 A. No. I have to say she didn't have that. 24 described after she did not move into the apartment? 24 And I think she didn't have it because she was a U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 22 of 34 PageID #:1025 CLEMENTINE FRAZIER April 07, 2017 Page 78 Page 80 1 Christian. And she always would say, I want to live 1 MR. DUFFEY: Well, I think that's all the 2 a certain way, so my boys will see me and respect 2 questions that I have. 3 me. So I can absolutely, without doubt, say she 3 EXAMINATION 4 didn't have any. 4 BY MS. TATAR: 5 Q. And is that in the entire time that you've known 5 Q. I just have a couple of points of clarification. 6 her? 6 You had said earlier that she wasn't herself. And I 7 A. well, the entire time I've known her, I do 7 think you described her as being bubbly before. And 8 remember some guy at church tried to he took her 8 when I say before, the relevant time period here is 9 out to dinner and that was about it. It didn't 9 prior to the Fellowship Housing issue and then after the 10 work. He was controlling and manipulative and she 10 Fellowship Housing issue. So tell me what she was like 11 just said no, that's not going to work. She would 11 before the Fellowship Housing issue. 12 call me and I'd give her my advice and I would say 12 A. She's usually well, before she was 13 run. 13 pleasant and not that she wasn't pleasant 14 Q. Do you ramber what that man's name was? 14 afterwards, but not so stressed, I would say. She 15 A. Oh, Lord, no. No, I don't because it wasn't 15 would come to church and she would call and things 16 that long of a relationship. Maybe about two weeks. 16 were going well for her, I would say. Things were 1'7 That's about it. 17 good. 18 Q. And if you could remember, when did this 18 Q. She was a happy person? 19 relationship occur? 19 A. She is a happy person. But like I said, she 20 A. Maybe about five years ago, maybe. 20 has moments, but as a whole, I would say she's a 21 Something like that. 21 very personable person. You can meet her and you 22 Q. Have you at any point seen Ms. Aldaco's 22 can talk to her and that kind of thing. 23 deposition transcript in this case? 23 Q. And did that change after everything happened 24 A. No. 24 with Fellowship Housing? Page '79 Page 81 1 Q. Do you know what a deposition transcript is? A. For a while it did. 2 A. Isn't it this? 2 Q. Can you describe that for me? 3 Q. no. So a deposition transcript is much like the 3 A. Like I said, she became stressed because she 4 court reporter is doing right now, she has been typing 4 was worried about where to live. And I had to tell 5 out our conversation. 5 Christian, he can?t go to the school. Or what am I 6 A. Oh, no, she didn't show me, she just told me 6 going to do kind of thing. And she was a little 7 she came down. But like I said, I only want her to 7 depressed and she had the headaches. And like I 8 tell me what she wants to tell me or show me what 8 said, I told her, let's go to the doctor and let's 9 she wants to show me, but I haven't sew it. 9 see, you know, if we can find out what's going on. 10 Q. Has she shown you any documents related to this 10 And she wouldn't sleep and gained, she gained 11 lawsuit? 11 a lot of weight. I didn't tell her that, because 12 A. No. 12 you know that hurts peoples' feelings, but I know 13 Q. What specifically, if anything, has she told you 13 she gained a lot of weight. 14 about this lawsuit? 14 Q. You had mentioned that she had missed several 15 A. That she came down and she stayed most of 15 meetings at the church, after the Fellowship Housing 16 the day. She called me asking about parking and I 16 situation happened. And I'm just trying to get a 17 told her park in the garage. She asked me was I 17 clarification on that. Are you aware that she missed 18 supposed to come and I said you guys had canceled, 18 those meetings because she was unwell because come today, that was it. we didn't 19 Fellowship Housing situation or was she missing the 20 discuss anything, because I don't want to get too 20 meetings for some other reason? 21 involved in it, in what's going on. I really don't. 21 . A. As a whole, she missed the meetings because 22 Q. Did she mention anything that she discussed in 22 she didn't want to be around people. I knew, but 23 her deposition? 23 the ladies didn't knowdidn't ask her. 24 Q. You said she didn't want to be around people. U.S. Legal Support, 236-8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 23 of 34 PageID #:1026 CLEMENTINE FRAZIER April 07, 2017 Page 82 Page 84 1 Did she generally want to be around people? 1 have to change, all of these things, circumstances, 2 A. She is a people person but just that period 2 just took its toll on her. 3 in her life and I like I saidwhen she would cry, it was a cry from the 4 define before '16, because I don't know that. But 4 heart, you know, like she was hurting. That's the 5 when you say after the Fellowship Housing, then that 5 way I can explain it, she was hurting. 6 helps me have a, you know, a point to look at. 6 Q. Ybu said also earlier that occasionally she -- I 7 There were times that she wouldn't come she 7 think you mentioned that she was tired as a result of 8 missed maybe a couple of months and the ladies would 8 this situation. What did she sound like when she told 9 ask where she was and so forth. But she just didn't 9 you she was too tired to case, to do whatever it was 10 want to be around people. I knew that she was going 10 that she was supposed to be doing? 11 through an anxiety period, but no one else knew. 11 A. She sound like she was, again, and me not 12 Q. And you said she was stressed. What did you -- 12 being a she was depressed. Didn't 13 how did you know she was stressed? Other than her 13 want to get out of bed or didn't want to eat, or eat 14 telling you that she was stressed? Did you observe her 14 too much in her case, she was overeating or just 15 in any way showing signs of stress? is eating. Trying to figure out what am I going to do 16 A. Because I know her. And for her not to want 16 kind of thing. 17 to be around people is not her personality, you 17 Q. Did she sound tired to you? 18 know, because she likes the fellowship, she likes 18 A. Yeah, she did. So much so with her 19 the things, you know, with church and all the other 19 I never said I would go to the doctor 20 things and she just didn't want to do that for a 20 with her because I got concerned. 21 while. So I told her just take time, you know, stay 21 Q. She looked like she was stressed or tired? 22 by yourself a little bit and try to figure things 22 A. Around other people she put on a good face, 23 out. 23 but I knew. I knew. 24 Q. Do you think after this situation that happened 24 MS. TATAR: That's all I have. Page 83 Page 85 1 with Fellowship Housing, was she asking you to pray for 1 MR. DUFFEY: I just have a few more questions to 2 her more often than she did before the Fellowship 2 follow-up. 3 Housing situation? 3 FURTHER EXAMINATION 4 A. Yes. I've always, over the whole time, 4 BY MR. DUFFEY: 5 2002, I've always prayed for her, but, you know, 5 Q. Are you aware of her ever being diagnosed by a 6 maybe little general things like pray for me, I'm 6 doctor with depression? 7 going for an interview, those kinds of things. But 7 A. No. 8 this, when she didn't have anywhere to go and the 8 Q. Are you aware of her being diagnosed by a doctor 9 situation, it was more serious and so I would pray 9 with anxietyencourage herthink right before the break you were 11 Q. Are you aware of her being diagnosed by a doctor 12 describing her crying and you said it was a really hard 12 with posttraumatic stress disorder? 14 A. Um~hmm. 14 Q. I believe we talked earlier, you said you saw 15 Q. I think I understand what you mean by that. But 15 Ms. Aldaco on Sunday; is that correct? 16 I wanted to clarify, because I'm not sure it was clear. 16 A. And life groups when she came, which she's a 17 When did you observe her with this, not just this cry, 17 regular now, and on Sundays for church. 18 but as you described, this hard cry? was it before the 18 Q. Sorry to clarify, when is the last time that you 19 Fellowship Housing situation or was it after the 19 saw Ms. Aldaco? 20 Fellowship Housing? 20 A. Not this Sunday, but last Sunday. 21 A. After, only because her circumstances were 21 Q. In your more recent interactions with MS. Aldaco, 22 so dire. And because of that she had the last month, is she still stressed about her 23 plate. And I think the pressure, with the kids and 23 housing situation? 24 where are they going to live, what school and do I 24 A. I don't think so now. U.S. Legal Support, Inc. (312) 236?8352 Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 24 of 34 PageID #:1027 CLEMENTINE FRAZIER April 07, 2017 Page 86 Page 88 approved her for housing, and she is supposed to 1 Q. Has she told you why? 1 2 A. I think she's concerned because she's, you 2 move in, and you've taken the person all the way up 3 know, brought it up about I didn't know the 3 to bags in the car, just need the key, and then all 4 decision, because I would say what did they decide? 4 of a sudden it fell through, that's some what a 5 What did they decide? And she said they decided not 5 disappointment. I didn't know why, but I feel that 6 to, but she didn't walk around every day feeling 6 it may be discrimination and I could be very wrong, '7 down and depressed about it. It's still present, '7 but that's what it sounds like to me. 8 you know, this situation, but not to the point where 8 Q. Do you know who she is suing in this lawsuit? 9 it limits her from doing the things she needs to do 9 A. No, I don't. I heard the Fellowship 10 or being friendly with people. It doesn't do that. 10 Housing, you mentioned that, but I don't know who 11 Q. So just to clarify, after the fellowship housing 11 we don't discuss that. 12 situation, there was a period of time in which she 12 MR. DUFFEY: Okay. I think that's all I've got. 13 wasn't able to interaction with people that she 13 14 typically did; is that fair? 14 (Ending Time: 12:39 IS A. I would say yes, that's fair. 15 16 Q. And would you say that that's no longer the 16 3.7 situation now? 1'7 18 A. She has moments, if that's -- you know, 18 19 moments. 19 20 Q. What do you mean by mutants? 20 21 A. It's not present all the time, like, Oh, no, 21 22 it's just moments that she has. And I guess I can 22 23 use the scenario, my mom passed away, I didn't 23 24 constantly cry, cry, cry and then I would go to 24 Page 87 Page 89 1 church or be somewhere and I have moments and I 1 2 would just breakdown and cry and cry. I think she 2 3 has moments. . 3 I, BARBARA PERKOVICH, No. 84-004070, 4 Q. So is it testimony 4 Certified Shorthand Reporter, certify: A. It's better for her now, naybe her, you 5 That the foregoing proceedings were taken before 6 know, living situation, but it's Still something 6 me at the time and place therein set forth. At 7 that's hanging over her head. 7 which time the witness was put under oath by me: 8 Q. When was the last time that you've seen her 8 That the testimony of the witness, the questions 9 experience one of these where she breaks down? 9 propounded, and all objections and statements made 10 at the time of the examination were recorded 10 A. I can't remember. I know when I see her she 11 stenographically by me and were thereafter 11 doesn't -- you know, she knows I know all the 12 transcribed; 12 things, bUt She doesn't jug: cry and then maybe 13 That the foregoing is a true and correct 13 Shell call me and say? you mow? Clem? I'm 14 transcript of my shorthand notes so taken. 14 really that's about; it? 15 I further certify that I am not a relative or 15 If had you to estimate, is the laSt time 16 employee of any attorney of the parties, nor 16 that She's called You and mressed Stress about this 17 financially interested in the action. 17 Situation? 18 I declare under penaltyr of perjury under the laws 13 A. PrObablY a few months baCk- Maybe firSt 0f 19 of Illinois that the foregoing is true and correct. 19 last year, maybe somewhere in there. 20 Dated this day of._April__, 2017. :2 . Q- It'll-lat is your understanding about what Ms. Aldaco 21 .. 1CL is claiming happened in this lawsuit, do you understand 22 22 what her claims are? How would you describe those BARBARA PERKOVICH, C.S.R. No. 84-004070. 23 claims? 23 24 A. From what she's told me, if they had 24 U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 25 of 34 PageID #:1028 CLEMENT INE FRAZ IER April 07. 2017 Index: $300..baby 20 9:1 10:618:22 2002 11:21 58:4 88:1 83:5 2003 58:4 2016 19:19.23 20:3 24:13.14 25:5,23 26:6 21 23:12 25 8:218:22 25th 42:5 720-5/1 23A1 54:4 8 19:3 824 7:5 9 9 53:17.22 96401466301 53:19 3 A $300 32:7,21 3 13:1315:2 ability 59:15 $700 31:22 32:5, 30 8:20 absolutely 78:3 18 300 31 :22 32:8 acceptance 35 1124 13:2215:4 1 - . . accountability 36 11.24 23:4 10 72:2 4 accurate 14:10 11 13:1115:2 15:8 49:2 12 19:3 4 132 active 11:23 12/17/96 54:15. I activities 10:4. 2155;4 48 7:18 2411:1 17:4 12:39 88:14 5 actual 61:9 14 1o;7_13 address 7:4 41:4.8.21 42:2,4 15 19:1 50 331271;?) 43:1144:10.2148:9 16 23:13 82:4 76117 17 17:18 23:13 5 Adrian 17114 25:19 18:13 23:12.15.18 17th 54:12 50173 715 A6316 . ran 5 55:13, 1987 7312 7 165612 1996 54:12 advantage 12:19 7 48:9,23 2 700 32,2 33_8 adVIce 18:15.17 78:12 affairs 29:24 affect 15:7 affected 15:10 affects 13:20 15:3 24:21.22 afraid 38:14 age 23:4 46:21 agree 37:1 agreement 37:7 ahead 5:9 20:15 38:8 52:20 alcohol 5:14 Aldaco 11:18.20. 2213:815:1518:8, 12,2217:1,21 19:18.19 22:4 23:19 24:23 26:9,21,23 30:8,18 33:13 35:7, 23,24 33:9 40:1 44:24 45:12 48:4 50:2 51:7 53:10.12, 20 54:7,18 55:5,9 58:8 57:7.13 58:9, 21 59:20 88:15 81:19 82:13 83:2 85:9 66:2,17 88:5 89:9 70:18,22 71:14.19 74:9 75:2, 18 77:21 85:15.19, 21 87:20 Aldaco's 8:11 17:11 2327.11 40:8 53:5 57:24 78:20 77:18 78:22 Alex 35:1.2.4 38:7 39:7 69:1? Allison 7:24 8:1 allowed 57:19 altar 11:1012:3 ambiguous 52:19 amounts 31:22 anger 58:5.7 answers 4:17.18 anxiety 59:3,18 82:11 85:9 anxious 59:1 anymore 24:8 anytime 7:7 apartment 15:8 28:8 29:1.20 43:8,9, 10.15.21 ,23 44:4.16 45:13 46:5 5023.8, 17 51 :8 52:3 58:1,4. 22 59:21 81:13.14 83:4 84:10.19 85:8 66:18 69:19 73:6.18 74:20 75:19.24 76:4.6.12.16.21 77:12.17 apartments 81 :5 application 48:5 applying 13:19 14:11.20 approved 50:13 88:1 area 77:7 areas 12:11 arrested 9:24 ashamed 83:3 84:9 Assembly 10:12 16:6 assist 12:11 48:22 assume 5:11 attend 18:4 18:21 20:2,14,18 21 3,13, 18,19 attendance 20:1 attended 19:22 attending 19:19 attends 15:17.22 17:21 18:2 20:5 Attorney 54:1 availability 76:4 average 19:1 24:4.11 aware 52:18.22 81 :17 baby 71 :23 U.S. Legal Support, (312) 236u8352 Inc . Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 26 of 34 PageID #:1029 CLEMENTINE FRAZIER April 07, 2017 Index: back..confidential back 25:3 32:1,5 33:7,10 43:4 56:3,4 60:22 65:13,21 66:1 72:19 87:18 background 7:4 52:15,17,23 53:12 56:14 bad 45:9 bags 63:3 baptism 11:6 baptize 23:2 baptized 23:4 barbecue 17:19 based 46:17 61:9 basically 6:10 11:3 47:2 batter 55:14 56:20 battering 55:17 56:21 battery 54:4,3 55:2,11 beat 55:13,21,22 56:2 bed 69:14 70:1,6, 14 34:13 bedridden 69:9, 12,13 70:4 beginning 72:12 behavior 24:20 57:24 58:2 68:7,9, 10 Ben 41:16 42:19, 21 43:16,20 45:3,23 46:4 beneath 54:21 55:4 bible 10:7,14 big 31:22 44:7 birthday 40:20, 22,24 41:1,2 bit 7:3 20:24 29:17 45:19,22 46:11 54:10 57:23 62:22 blame 23:4 blamed 33:19 bless 33:5 Bloomingdale 43:7,11,17,23 44:4, 11,14,17 46:5,3 73:12,17 77:15 Bloomingfield 43:10 border 44:11 77:3 bottom 13:13 15:1 bounda?es 31 :9 boundary 54:16 boyfriend 55:13 56:21 boys 12:1 ,22 24:6 73:2 break 16:7 40:5 74:2,3,5,6 63:11 breakdown 87:2 breaks 67:9 bring 19:9 72:21, 22 brought 9:14 66:3 bubbly 60:4 60:7 business 29:23 56:15 buy 32:9 call 11:1016:19 20:16 21:13,14 25:12 27:13 29:5,6, 15 30:2 57:1 53:19 65:15 70:5,8 72:19 75:7 78:12 80:15 87:13 called 21:2 27:17 28:11 34:9 39:10 46:12 50:5 56:23 79:16 37:16 calling 77:16 calls 25:16 calm 23:13 canceled 79:13 capital 54:12 car 17:24 18:5 45:5 88:3 card 30:22 cards 31:7 care 9:22 career 9:1,4 caregiver 9:23 carpeting 9:3 case 13:214:19 53:18 55:1 78:23 84:14 caused 13:21 15:4 74:23 75:3 causing 76:23 center 62:6 certified 53:17 chance 33:6 change 20:1 24:16 39:13 80:23 34:1 changed 39:12 characterized 66:11 charge 55:1 charged 54:3 5510,23 charging 54:3 check 52:13.15, 17,23 53:13 56:14 checks 51:22 52:6 Chicago 3:10 41:23 42:4 children 7:21 12:1514:313:24 22:23 23:1,3,7,11, 20 24:13,22,24 25:6 26:9,12,17,24 35:11 41:17 46:21 63:3 64:10,17 75:13 77:16 Christian 17:14, 1713:7,1123:13,14 27:3,12 23:12 40:20 42:6 5020,21 51:1 63:11 78:1 81:5 church 10:6,9,10, 11,13,2011:1,9,12, 2312:1 15:17,20, 21,2216:413:2 22:7,6,24 24:1,3 25:6,9 56:16 76:6 60:15 61:15 62:19 85:17 87:1 Cindy 41:16 42:19,22 43:13,20 45:3,23 46:4 circuit 54:3 circumStance 66:3 circumstances 2120,21 25:11 33:9 66:5 73:4 63:21 64:1 claiming 67:21 claims 8722,23 clarification 60:5 61 :17 clarify 43:3 59:10 64:23 65:20 83:16 65:13 36:11 class 53:14 60:16 clean 69:24 clear 40:15 45:11 83:16 Clem 25:13 41:2 70:8 87:13 Clementine 4:2, 1013:17 clerk 54:3 client 3:17 close 13:1714:2 19:15 74:13 clothes 32:9,15 clue 62:9 college 59:12 comfortable 27:15 communicate 68:6,10 75:9,13 communicated 53:10 53:9,11,13 communicatio 75:10 community 10:4,9,24 55:5,6 company 6:3 34:6 39:22 63:20 69:6 compared 70:23 complaint 54:3 concerned 63:12 64:20 66:2 concerns 38:13 conducted 53:13 confided 64:13 con?dence 68:3 con?den?al 29:10 57:5 U.S. Legal Support, (312) 236-8352 Inc . Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 27 of 34 PageID #:1030 CLEMENTINE FRAZIER April 07, 2017 Index: confusing..embarrassed confusing 28:1 County 54:2 24:7 describing documents :10 76'5 couple 17:19 day 24:10 50:8,8, 8312 624 79 confusmn 30:5 41:18 63:1 10 82:8 89:17 74:8 description dog 44:7 39:14,18 58:8 79:1888:8 49:2 dogs 44:? consistent days 50:12 devastated door 18:24 court 4:24 54:3 debt 3022 15:10,13 79.4 December 54:12 doubt 78-3 constant 38:14 coworkers 36:7 decide 11:15 diagnose 59:15 downtown constantly 38:10,17 39:17 88:45 diagnosed 85:5, 86:24 68:12 . 8 11 22:21 deCIded 38:19,2o Dracut 7.5 contact 49:11 crazy 38:8 39:17 37:22 88:5 dinner 17:8,18 2 contacted 49:14 credit 30:22 31:1, decides 38:23 18:7 24:2 78:9 draw 24?19 context 25:22 7 . decision 88:4 dire 83:22 drive 1724 . cried 71:21 . - . . continued 19:22 declined 39:12, drives 1723184 . crime 10:2 54:17 23 43:4 drugs 5:14 controlling - - disappOintmen 78:10 criminal 53:13 dedicate 23:3 due 82:13 79:19 conversation 8:8 28:20 27:11 cry 58:15 60:2 71 :19,23,24 72:4,5, dedicated 23:1 defendant 54:4 58:5 83:14 88:5 discrimination DUFFEY 4:8 28:4 40:4,7 52:21 73:18 (312) 236?8352 28:8,15,21,24 50:9, 8,10,12,1973:3,10, 8815 74:1,5,780:185:1,4 12.13.14,19,24 Defendant's discuss 19:7 88:12 83:7,22 79:5 83:13,17,18 84:3 13:2 48:9 53:17 35:5 7920 88:11 dul 4.3 . 88:24 87:2,12 . conversations . define 85:18 82:4 discussed DVD 1913 26:22 292,4 63:9 crying 15110 de ree 59.6 18:2019:1830:8,17 87:1 27 70:7 72:17 28:12 72:15,16,22 71916 31:4 79:22 83:12 conveyed 28:7 . discussmn . culmination enie 51-? . conVIcted 10:2 616 58:12 19-14 . - - - dishes ?19-9 7020 e-mail 16:19 current 7:4 41:4, Dennys 84:5 . - - 20:1821:15 8.214628 depended 37:12 disorder 85112 earlier 57:23 COOK 542 customer 33:13, deposition 4:12 disposition 83:11 80:8 84:8 Corens 47:20 22 34:12.13 5:218:1,4,15,19,22 53:18 7 85'? corporate 9:8 early 74:13 corporation doctor 35:11,13, eaSIer 5:3 25:24 . . . epresse 14,20,2180:8,8,10 . 61914-2326.? 58236016921 eat 19.9 71.12 48:13,1847:4,8,11, D-R-A-C-U-T 61?20?22'6252'5'? 84:13 . . 70-471-181-7 81:8 84:19 85:8,8, 18 48.5 4915,22 7,5 . 20 779 depressmn document 13:9, effect 15:7 . an erous 42:1 59:2,1870:11,12 . . correct 32.19 9 85.6 ?.38'2138'15318 Ellyn 44:12,13,19 33:20 45:17 87:9 date 54:12 - 53-24 54-?055-10 85:15 describe 12:5 documented embarrassed dates 54:11 . . . 83:3 count 20:20 14-1 20-8 2322 38:24 39:1 daughter 7:22? 50:15 58:2 81:2 EW22 U.S. Legal Support, Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 28 of 34 PageID #:1031 CLEMENTINE FRAZIER 'April 07, 2017 Index: Empire..guess Empire 9:5.7.8.9. 1.3 employees 37:9.14 17 employer 33:23 employers 37:23 employment 49:17 empower 10:15 encourage 10:15 29:7.12 33:20 72:14 33:10 encouragemen 37:8 72:17 ending 88:14 entail 11:8 entire 7:1313:19 71:13 78:57- esteem 33:19.23 67:18 68:2 estimate 87:15 Evangel 10:12 16:5.6 EXAMINATION 4:5 80:3 85:3 examined 4:3 excited 14:13 15:11 22:3 50:18. 19.20 51:1.3 Exhibit 13:2 48:9. 23 53:17.22 expect 33:3,11 expe?ence 12:10 30:13 87:9 expenenced 60:24 experiencing 21 :4 70:14 explain 21:22 63:21 84:5 explains 73:15 explanation 4:21 expressed 87:16 expressing 77:19 extrovert 30:20 face 25:10 84:22 fact 3:9 33:13 50:22 31:19 facts 13:20 15:3 19:13 32:12 failed 34:17 fair 5:12 35:3 33:18 73:3 74:24 83:14.15 fairly 33:11 familiar 44:15 family 3:14 8:23 9:22 28:10 29:3 74:24 77:19 family's 75:14 father 12:13.22 55:13.17 53:2 fault 35:8 feel 70:10 73:13. 15 88:5 feeling 86:6 feelings 81:12 feels 27:15 33:22 feet 43:23 fell 88:4 fellowship 3:18 13:20.22 14:5.23 15:5.8 19:8 22:2 26:6,13 28:18 29:1. 20 43:9 45:13 46:13.18 47:4.8.11, 16 48:5 49:15.22 50:2 5127.19 57:8, 14.20 58:1.3.21 59:20 61:4 63:4 64:18 66:10.18 67:16 69:10.19 70:17 71:20 73:5,18 74:20.23 75:19 77:8,12, 17 8029.10.11.24 81:15.19 8225.18 83:1 ,2.19,20 86:11 88:9 felt 33:10 52:7 59:24 34:17.24 35:5.7 20 71:2 72:11.12 74:12 females 35:13 Fieldwork 8:7, 21 figure 12:22 82:22 84:15 filed 54:2 fill 11:5 finally 15:1 finances 30:9 47:1 financial 31 :3 75:5 financially 30:14.13 31:12 find 14:8 28:3 57:11 81 :9 finding 30:15 47:14 54:22.24 finish 5:2 fired 37:1 floor 37:15 fluctuations 71:14 focus 8:15.17 follow-up 11:13 85:2 food 10:8 31:23 Forest 15:24 forget 41:2 forgot 33:9 form 52:19 70:11 found 28:19 29:21 30:3 50:3.7, 13 53:17.23 Frazier 42.10.11 9:24 13:17 frequency 13:21 20:2 Friday 10:23 20:9 friend 13:17 14:2 49:1 friendly 83:10 friends 3:15 friendship 31:9 front 11:13 frustrated 58:13 69:3 frustration 58:5, 7 full 4:9 - full-time 8:19 gain 71 :4 gained 71:8 81:10.13 gaining 70:22 garage: 79:17 gave 21:18 31:20 35:18 50:10 72:17 general 50:24 83:3 generally 82:1 give 4:18 5:18 12:2 31:17 33:6.10 38:6 52:4 68:17 78:12 giving 4:13 51:20, 24 Glen 44:12,13,19 God 10:1212:2 13:319:1129:13 Godchild?s 40:24 godmother 17:7 22:22 Godparents 23:6 good 4:7.8 14:20 34:14 40:18 41 :23 71 :9 72:4 74:1 80:17 84:22 goodness 33:11 goof 33:13 goofing 33:8 38:18 greet 22:11 grew 12:13 ground 4:14 group 1025.6,13, 14.19.21 15:18 1722,21 18:2019z4, 17.20.22 groups 8:16.17 19:5 85:16 grow 12:24 guess 6:2 20:24 22:18 24:19 25:20 26:5,18 27:1 28:16 35:2 36:22 37:15 46:20 51 :2 522.7, 13.14 53:2 55:12 56:5 57:10 62:8 U.S. Legal Support, 236?8352 (312) Inc . Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 29:0f 34 PageID #:1032 CLEMENTINE FRAZIER April 07, 2017 Index: guessing..ladies 69:16 73:17 76:18 86:22 guessing 30:6 42:24 guilty 54:13,14, 16,22 55:1,11 65:5, 7 guy 34:24 73:3 guys 79:13 half 10:20 19:9 23:13 hand 20:21 59:3 handing 13:1 handwriting 4317,19 hanging 37:7 Hanover 10:12 23:17 46:10 happen 15:13 63:22 happened 21 :9 25:23 23:16 31 :14 65:21 67:8 76:4 30:23 31 :16 32:24 37:21 happy 37:11 3013,19 hard 4:19 32:11 51:20 52:1 72:10 73:10 33:12,13 hate 65:2 head 4:19 37:7 headache 21 :4 60:22 headaches 20:19 60:5,6,15,17 61:1,10,11,17,20 62:14,20,24 63:15 81:7 health 59:11? healthcare 9:16, 17 hear 14:15 34:24 heard 42:21 46:12 47:20.23 54:19 33:9 hearsay 36:9 heart 12:2 33:11 73:14,15,23 34:4 Heather 47:20 heavier 71:11 heavy 21:24 helped 10:3 30:5 32:15 helpful 4:22,24 helping 46:23 48:4 helpless 53:6,3 helps 32:6 hesitate 26:2 hired 39:22 home 7:9,13 12:16 24:22 40:3,11 46:2 49:9 65:17 70:13 72:13 74:12 homeless 45:7 65:9,16,17,19 66:10,14,15 honest 33:3 hospital 62:5 hour 19:9 40:4 hours 3:20 house 27:20 42:13 69:24 housing 6:19 13:2214:3,2315:5 22:2 23:7,13 23:13 43:9 46:13,13,22 47:4,3,11,16 43:5 49:15,22 50:3 51:3, 19 56:13 57:3,14,20 58:22 59:21 61:4 64:18 66:10 67:16 69:10.19 70:17 71:20 73:18 74:20, 23 75:22 76:4,16, 20,21 ,22 77:4,8,9, 12,17 80:9,10,11,24 81:15,19 82:5 83:1, 13,1920 85:23 86:11 88:1 ,10 Housing?s 53:1 HR 63:19,20,21 69:5 hug 22:14 24:5 human 9:1,3 67:22 hurting 73:10,12 34:4.5 hurts 31:12 husband 6:16 12:21 19:5 23:5 31:12,17 74:12 husband's 7:19 idea 14:20 ill 3:24 69:13 Illinois 7:6 53:19 important 4:13 impression 36:11 37:6,8,19,21 39:21 50:24 64:21, 23 incident 67:17 69:10,17,18 70:13 73:5 77:13 independent 47:10 info 11:16 information 47:3 50:11.16 53:5, 9 insist 62:1 instances 63:6 interact. 23:19 24:12 interacted 24:17 interaction 23:22 24:4 53:6 86:13 interactions 35:21 intercessory 11:2 interested 39:11 47:12 interests 77:22 interpretation 14:9 28:9 interrogatories 13:3 interview 3:15 33:7 interviews 3:16, 13 invite 17:19 invited 40:21 involved 10:4,9, 55:1 57:7,14,16 79:21 issue 30:9,10,11 issues 64:4,9 Italian 13:13 January 16:9,11, 23 1919,23 20:3 21:7,3 24:13,14,13, 19 255,23 26:5 job 5:3 3:4,14 9:5 14:13 23:16 30:20 32:10 33:13,14,15, 19 34:4,16,19 36:1, 3,21 37:16 39:9 72:24 jobs 34:12 67:11 join 11:1143:5 June 7:13 keeping 5:1 Keith 49:10 key 52:4 33:3 kid 27:23 kids 23:6 26:15 32:3 35:19,21 41:24 73:1,24 74:14 75:15 33:23 kind 14:20 19:9 22:11,15,20 24:4 27:7,3 23:2,3 34:13 36:8,14 43:19 54:18 53:17 60:4 63:19 65:3,8 67:15 63:1, 13 59:14 70:10 72:15 73:2 30:22 81:6 34:16 kinds 33:7 kiss 22:1424:5 knew 5:22 14:19 21:22 22:17 28:4 29:9 31:5,19 33:21 34:2 39:22 49:23 53:15.16 60:3,4,19 70:11 31:22 32:10, 11 34:23 knowing 61:7 knowledge 13:1314:11,13,17 15:2,6,9 51:9 ladies 10:617:19 13:22 20:16,23 U.S. Legal Support, 236?8352 (312.) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 30 of 34 PageID #:1033 CLEMENTINE FRAZ IER April 07, 2017 Index: ladies'..move 22:12 81 :23 82:8 ladies' 59:7 laid, 9:12 38:2.7. 10,14 Lake 44:9,12,18, 19 landlord 51:19, 21.24 53:5 Lane 7:5 language 54:1,5 large 19:2.4 lawsuit 13:7 19:17 79:11,14 87:21 88:8 lawyers 5:12 lay 70:1 laying 70:5 layman's 59:9. 17,24 leader 11:3,7 lease 43:14 leave 3519,21 37:4,20 54:7 led 12:4 22:24 left 35:1,3 43:18 letters 54:13 life 1o:5,5,13,14. 15,19,21 15:18 17:2,21 18:2019:4, 5,17,20,22 21:20.21 82:3 85:16 likes 17:8 82:18 limits 85:9 lines 25:2154:21 listed 13:14 48:23 49:5 listen 19:13 live 15:14 25:17 27:5 28:1.6 29:18, 2143:1,2 45:1.3 5023.8 5124.6 57:12 61 :7 63:19 65:6,19 66:4.13 73:1 76:24 78:1 81:4 83:24 lived 7:1141:12 43:13.15 44:15.21 45:14 45:7 74:9,10 75:3,17 77:1 lives 34:7 49:15, 19 41:5 42:14 44:1 living 10:15 41:7, 20 42:15 43:5 45:5 75:19 77:11 87:5 loan 31:10 local 54:2 located 50:13 locations 45:14 long 7:11.17 9:9, 1910:1711z20 28:19 29:19 34:2,3 37:14 41:7,20 42:23 43:13 45:24 70:3 72:5,10 78:15 long-term 75:22 76:1 77:1 longer 34:5 41:11 57:14 85:15 Longhorn 18:19 looked 57:12 84:21 Lord 11:11.15 12:4 22:24 78:15 Lorena 42:13.14, 17 Lorena's 42:18 lose 24:23 25:5 25:9,12 71:10 loss 13:2215:4 lost 22:20 25:23 lot 5:312:17,18 15:13,2019:5 23:1 29:7,8 30:4 35:9 3617,12 3711223 40:14 60:2 67:5,11 68:3 7125,21 81:11, 13 83:22 love 47:13 low 55:19,23 57:17 LPC 9:17 lunch 54:1,3,12 lunches 54:8 49:10 made 73:19 make 5:3 32:12 45:11 47:22.24 48:2 making 55:17 59:8 - man's 78:14 manage 45:24 management 38:21 68:15 manager 35:1,2, 5 35:7 37:12 39:7. 18 59:1 manipulative 78:10 mark 53:15 marked 13:148:9 market 8:13 marketing 8:7 marriage 12:10, 12,1415:15 married 7:15,17 12:1515:15 matter 34:1 Mcpherson 49:11 meal 18:11,12 meals 18:10.14 means 36:23 medical 59:10.22 52:5 medically 59:15 meet 10:21.22 11:22 22:11 52:4 53:1 57:5 80:21 meeting 20:11, 14,18 meetings 18:21 20:2. 5 72:5 81 :15,18,20. . 21 member 8:23 9:23 11:2415:4 members 5:14 memory 7:19:19 men 77:22 mental 59:11 mention 22:15, 19 29:5 30:24 34:24 35:8 38:1 ,3,9,13 47:24 55:12 79:22 mentioned 10:1317:1,15 22:22 23:14 30:13,22 31:1 3245.13.23 35:12 35:15 42:8,19 45:8, 14 45:1,14 47:21 54:24 55:27.13 57:13 58:7 50:15 53:7,11 55:20 55:5 58:4 74:22 81:14 84:7 88:10 mentor 12:8,9 13:1814:215:18 49:2 mercy 55:15 met 47:15 55:3,4 66:2 74:14 mild 70:11 mind 39:12,13 Mine 19:5 minister 11:10 minute 48:11 missed 35:19 81:14,17,21 82:8 missing 35:9 81:19 mistake 55:17 mom 12:8,9,17,19 22:13 25:13,16 27:6 28:1,14 30:4 41:14, 20 43:20 4513,16 51:5 66:4 73:22 86:23 moment 51:15 53:1 moments 72:20, 22 80:20 85:18.19, 20,22 87:1 ,3,9 money 18:17 30:11.21 31:10.17, 20 32:14.24 33:5 75:5,8,11,14 month 5:2 9:12 10:22.23 20:9.10 23:9 41 :24 85:22 months 8:5 9:21 34:5 42:24 82:8 87:18 moods 59:8 morning 4:7,8 5:14.21.23 5:22 mother 12:15.17 move 7:715:7 26:8 28:17,20 29:1. 20 43:8 45:13 46:21 5069.10.14 51:7, 17 57:24 58:3,21 59:20 61:4, 13,14 63:4,12,14,17 64:18 69:18 73:5,17 74:15,20 75:18.24 88:2 U.S. Legal Support, 236?8352 (312) Inc . Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 31 of 34 PageID #:1034 CLEMENT INE FRAZ IER April 07, 2017 Index: moved..prayer moved 30:4 43:9,20 46:4,6 76:7 77:14 movie 24:10 movies 24:9 moving 15:12 22:3 27:22 41:20 50:16.19 51:12.13, 15 61:6 66:17 music 19:11 mutual 36:6,16, 22 37:27 named 34:24 54:4 names 34:22 47:21 48:1 49:10.24 nasty 66:16 naturally 25:9 47:12 nature 32:16 necessarily 65:15 needed 6:17 11:3 31 :19,24 32:7 52:11 72:11 neighborhood 41 :23 nerves 26:19 nervous 9:15 nice 16:16 25:9 39:8 77:3,5,11 night 74:13,16,19 nodding 4:16 normal 23:23 60:3 note 47:22 46:2 notes 61:16 notice 20:1 24:16 56:22 71:5,14 noticeable 71:16 noticed 58:2.14 59:1 71:11 number 49:5,6,8, 9 72:2 74:22 0 object 52:16 Objection 73:7 observation 59:9,24 observe 62:14 63:17 observed 56:6, 12 occasionally 17:5 34:17,20 64:6 21:6 25:18 26:11 28:15.21 38:16 56:1161:13 78:19 occurred 61:10 62:11 offer 67:6 office 6:10 62:7 oldest 23:12 one-on-one 8:17 open 73:23 opinions 69:20 opponun?y 24:12 organization 46:12,20 other's 26:19 outgoing 60:20 overeating 64:14 owned 7:13 pm. 66:14 paid 16:1132:5 Palatine 77:2,6 pantry 10:6 parenting 12:10, 13 parents 24:1 75:16 park 10:1215:24 23:16 46:10 79:17 parking 79:16 part 6:14 9:310:20 15:1 Part-time 6:20 participate 6:16 57:19 participates 17:1 parts 13:24 41:19 party 4020,22 pass 12:16 passed 66:23 past 71:6.15 pastor 15:23 16:3 19:2 Paul 47:23 pay 32:133:7,9 payment 32:3 pays 16:1o,12 peace 69:2 people 8:1511:5 16:1616:2130:5 3421,22 36:6 37:16 47:14 48:1 49:17 53:19 64:1165:15 66:16 67:14 68:12 71:1 72:24 73:12 8122,24 82:1 210, 17 84:22 86:10,13 people's 56:15 peoples' 29:23 34:7 61:12 period 16:9,10 70:3 60:6 62:2,11 66:12 periods 16:6 24:17 permanent 76:8,11 perpetrate 37:17 personi 33:16 49:11 60:4 63:23 67:2 66:1 72:5 60:16,19,21 62:2 66:2 person's 73:14 personable 80:21 personal 13:17, 1814:2,1715:2 19:3 30:6 31:4.5.8 personalities 59:7 personality 62:17 personally 27:10 phone 15:12 21:13.14 25:12 27:14 51:23 57:2 56:19 63:22.24 67:34.6 72:6 physical 35:15 physician 60:23 place 28:17.18 29:21 39:6 40:12 41:18 44:6 45:13 49:19 64:6 76:8.11 77:3,5,11 places 43:19 74:9 76:24 Plainfield 42:15, 17 Plaintiff 13:4,7, 16,21 14:215:3 Plaintiff's 13:2, 19 plan 27:22 plans 7:7 plate 63:23 plea 54:13.14 pleasant 60:13 pled 54:16 55:11 point 5:5 35:7 38:9.15 40:18 49:7 54:7 55:6 59:21 71:19 74:10.17 77:17 78:22 82:6 86:8 points 60:5 policemen 56:22 portion 14:4 position 6:19 39:24 posttraumatic 85:12 pot 66:14 pound 71:17 pounds 71:9 praise 19:1o,11_ pray 11:1414z17 58:18 83:1,6,9 prayed 63:5 prayer 10:15 29:6 U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 32 of 34 PageID #:1035 CLEMENTINE FRAZIER April 07, 2017 Index: prayers..showed prayers 29:15 recent 55:7 85:21 relayed 27:11 romantic 77:22 prepare 5:21 0 recently 55:19 relevant 30:8 room 52:1 present 33:15 qualify 3-15 667 religions 23:2 rough 42:5 :721 53686 t' remember 15:24 rug 57:14 pressure 33:23 ques 5:25:93: 25:20.22 32:24 rules 4.14 pretend 37-13 11:121f5'7 2?24 recollection 34:22 3323,24 - 38:8 523192922 44:15 45:4 49:21 43:12,13 44:24 45:4 run 73:13 prevent 5:15 59-5 61-9 7375 524,11 48:4 51:14 52:11 - ques?ons 416 56H85h1j0639 pgeeygously 48'8 30:2 35:1 riggmmend 54:3 55:5 59:9,15 . 70:15.2275:19 43:20 qule 50-19 recommended 75:3,20,22 77:15,13 sad 7324 prior 8:219:13 qu1t 37:1 60-23 78.3,14,1887.10 sa es 34.13 15:11 22:5 71:15 record 4:20 5:1 remembered 30:9 53:14 55:13 55:24 43:7 sat - 64:1 private 64:13 682? rent 7:9 30:21 savin918=16 problem 2521 Rachel 47:23 rg?og?ds 55:9 46:22 scared 42:7 44:7 31? Rafaela 522,24 't ?Phrase 519? scenario 35:23 . . . . 9:51513 Schaumburg 14:11 113-6158188415 report.13:2115:4 . . . 53.20 7424 recruiters 7.5 3.9,10,11 43.2 professional reporter 79:4 77:25 59:18 695 a ae a 14'? 9316 required 3420 3218,9,15 . raise 23:5 . 31:5 83:24 . . rectify 57.11 research 3:313 486 .5, 5.5 12:15 refer 42:21 47:11 63:15 Rarel 25:3 25:10 . . section 14:1 prosecutor 542 reference. 43.12, 9.1,4 prove 3322 reacting 29:11 - seek 59:22 7 provide 417% reaction 50:15 referenced respect: 7812 sentenced 55:4, 6 10 25:22 read 13:13 75:13 - - ep em er readm 47:10 - - 9 referring 5.3 responses 13:3 4024 - - rea 27:23 . . . refresh 7.149.20 restaurant 17:3, sertes 4.15 real 14-5321-24 52.10 1513-13 59:13 31,5 - seerce 22:12 5 chothera egar 56-10 restaurants 33:18,22 34:12 py reask 38:8 regular 35:15 23:15 55:5,? 59:13 75311 85-17 pull 702 reason 5:17 - - result 347 set 22:3 pursued 21:1835:1881:20 reQUIarly 20:63 resume 9:14 Shel" 5821887113 47:13 . . . related 73.4 39.10 49.13 short 41.22 42.10 pu 68.237023 - . . 79.10 return 33:12 show 52-47953 34:22 . . . . recalled 45:19 relationship review 524 9 putting 55:18 received 52 12:515:17 31:3 55.9 49:1,3 73:15,19 rich 75:15 Showed 40:12 . . 53:13 relationships Robert 7:20.21 7722 U.S Legal Support, Inc4 (312) 236-8352 Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 33 of 34 PageID #:1036 CLEMENTINE FRAZ IER April 07, 2017 Index: showing..thinking showing 48:8 53:18 70:19 82:15 shown 79:10 sick 11:1218:24 62:18,19 73:22 sickness 59:14 signature 45:19. 21 signs 82:15 similar 29:2 simply 37:8 sing 19:11 sister 41:15 42:9 43:19 45:2.20 59:23 sister's 42:12 sit 24:8 82:9 84:5 sitting 81:23 situation 14:18 21:24 22:1 26:6 27:3.18 28:5.9 29:9 30:131:5 41:13 45:9 57:4.11 84:10 85:14 55:8,11 71:20 72:1 ,14,23 74:23 755.14.20.23 75:2. 21.23 77:19 81:16, 19 82:24 83:39.19 84:8 85:23 86:8.12. 17 87:5,17 situations 21:23 31:12 73:2 75:3 slash 49:1 53:18 54:2 sleep 80:2 89:22 70:10.21 81:10 sleeping 80:22 89:17 70:9 small 58:19 smell 88:14 smoke 58:14 snatched 27:24 snooping 55:15 society 24:3 someplace 29:18 30:3 57:11 5011 17:5,1118:13 17:15 sort 15:1717:5 31:7,8 45:7 72:22 sorts 17:4 88:9.10 73:21 sound sounds 44:15 88:7 speak 5:20.24 8:14 14:22 22:8 34:16 50:21 77:21 specialist 34:13 specific 25:20.22 28:8 56:18 88:8 specifically 21:2 83:10 88:9 79:13 spiritual 12:8 spoke 49:21 spoken 8:11.18 33:13 39:5 40:2 47:7,18 57:3 sponsor 51:18 52:8 53:1 spout 58:22 spouts 58:5 stability 25:13 stable 83:18 stand 23:5 standpoint 59:17.18 80:1 88:1 start 25:3 33:15 71:4 started 8:410:19 19:23 26:18 38:17 starting 45:12 state 4:9 53:19 State's 54:1 statement 53:17 stay 74:19 82:21 stayed 8:23 4515.20.22 74:18 79:15 staying 41:14.15 45:2.3 Steakhouse 18:19 stick 44:14 stomach 82:18, 20 stop 72:1-5 stopped 9:22 40:1 straight 32:13 Street 19,20 streets 42:1 stress 28:3 29:3 74:23 75:49.13 78:23 77:19 82:15 85:12 87:18 stressed 20:21 24:21 28:15.18 27:23 75:8 80:14 81:3 8212.13.14 84:21 85:22 study 10:7,14 subpoena 8:5 sudden 27:24 88:4 suffered 58:2 suing 88:8 summer 17:10, 18 Sunday 12:1 22:5,8 85:15.20 Sundays 85:17 supervisor 35:8 supposed 53:1 79:18 84:10 88:1 supposedly 51 :20 surgery 73:22.23 surmised 35:5 70:24 surprised 53:15 57:8 swear 59:4 sworn 4:1.3 59:23 70:11.14.19 84:19 23:18 takes 17:15 taking 24:10 talk 5:7 7:311:14 14:1515:12 22:10 29:5.12 30:11 34:18 37:9 39:18 50:23 53:3 54:5.8.9 58:15 80:22 talked 28:13 30:18 45:11 57:9.23 54:1,4 85:1 59:1 85:14 talking 125:3 40:15,17 48:13 49:19 55:20 55:21 72:9.12 77:14 talks 27:13 TATAR . 25:22 52:18 73:7 80:4 84:24 taught 12:17 teach 10:5.5.14 11:512:2019:4,14 teacher 10:7,14 teaching 10:18 19:12 team 11:2.7 teenagers 23:8. 24 telephone 49:5, 6.8 57:1 telling 27:15 39:8 45:19 59:5 82:14 temper 24:23 25:5 25:9.12.24 term 13:4 terminally 8:24 terms 78:11 terrible 40:23 testified 4:3 testifying 5:15 testimony 5:18 15:21 78:15 87:4 thing 4:2414:21 19:6 22:1126:16 27:7.8 28:2 31:8 34:13 35:16 36:15 37:2 58:17 63:19 65:3,8 67:15 68:12 70:10 80:22 81 :6 84:16 things 10:911:4. 512:17,1818:24 22:15 27:18 31:4.5 32:9.16.17 38:8 38:19.23 39:1.17 47:1 54:19 58:8.9. 13 59:8 57:20 88:18 89:5 72:21 73:1,19. 21 80:15.18 82:19, 20.22 83:5.7 84:1 85:9 87:12 thinking 35:10 55:20 81:21.23 78:14 U.S. Legal Support, 236?8352 (312) Inc. Case: 1:16-cv-05754 Document 51-4 Filed: 06/22/17 Page 34 of 34 PageID #:1037 CLEMENTINE FRAZIER Index: April 07, 2017 thought..youngest thought 14:20 32:4 37:21.22 39:9, 19 43:3 51:1157:15 59:22 62:8 67:21 76:9 time 7:1315:3.9. 1O 20:13.15 22:4 24:17 31:22 33:1 37:15 39:9 40:13 41:22 42:10 43:12.22 44:3.24 46:3. 7 49:7 51 :20 52:1 54:8 55:6 57:9 58:3 61:12.24 62:21 66:4,6 67:4 70:3 71:13 75:2.16 76:23 78:5, 7 80:8 82:21 83:4 85:18 86:12.21 87:8.15 88:14 timeframe 51:10 timeline 45:12 times 14:1513:20 20:20 21 :9 25:10 31:14.15 32:2,13. 14.24 37:23 40:10 41 :3 50:24 51 :2.3 52:23 54:2 55:22.24 57:11 53:4 71:22.24 72:2, 3 74:22 32:7 tired today 4:15 5:513 5:15 15:21 13:21 22:5 45:12 57:23 53:4 74:22 79:19 today's 24:3 told 14:13.1515:9 25:72:; 27:1 23:11 1 31 :5 33:20 39:3,12 42:5 45:15 50:7,12 51:5.11.23 53:12 54:7,15 55:5.9 55:3 59:21 60:6 62:23 55:22 53:19 70:1 74:8 81:8 82:21 84:8 86:1 87:24 toll 34:2 Tom 7:5 tonight 10:5 top 43:22 53:24 track 33:4 training 59:11 transcript 73:23 79:1.3 transient 43:19 75:23 translate 4:20 treated 35:11 37:10 treating 13:12 35:13 treatment 59:22 trouble 30:13.15 51:12.14 truthful 5:13 truthfully 5:15 turn 13:1144:13 type 14:1719:5 75:1 typically 17:22 13:3.21 19:7 72:3 35:14 typing 79:4 uh-huh 4:19 um-hmm 4:19 13:5 32:22 45:15.21 45:10 43:10 49:13 53:11.21 55:10 52:22 33:14 unable 21:3 29:1 unclear 32:23 understand 4:22 525,8,10 13:3.6 29:10 45:13 33:15 37:21 understanding 14:5 35:20 45:17 37:20 understood 5:1137:15 45:19 52:2 unnecessary 52:10 unprofessional 57:22 53:57.11 59:4.7 unwell 31:13 upset 25:13.15 27:4.15.13.20 23:4, 12 51 :4 52:7 54:9, 21 73:2 vague 52:19 73:7 Vanitti's 13:13 verbal 4:13 versus 53:19 visit 40:13 41:3 42:2,15 43:22.24 44:3.5 52:11 70:13 visited 40:10 visiting 15:14.20 40:14 vomit 52:13 vomiting 52:24 wait 5:2 waited 51 :24 waiting 52:1 walk 39:15.21 42:1 57:14 35:5 wanted 12:1 23:1.5 49:24 51:21 59:1 33:15 wanting 52:5 54:7 70:20.21 watched 12:24 ways 73:12 wayward 30:5 week 15:1513:23 19:1 23:22.24 29:17 70:4.5 weeks 15:19 30:5 42:11 78:16 weight 70:22.23 71:4.3.10.15 31:11. 13 whatsoever 31 :2 wife 19:5 Window 34:9,15 35:3,24 35:4 33:2. 11 39:5 40:1 57:19 53:5.21 Winston 15:23 15:3 wise 45:24 witnessed 27:10 73:19 women 10:15 14:716:1819:6 29:8 41:17 46:20 women's 19:4 word 19:14 words 4:19 54:11 55:13 54:20 work 3:35.721 9:3.9.1311:7 29:13 35:9,12,19,24 35:12.14 37:17 38:18 39:8 68:5,17 78:10.11 worked 9:10.15, 17.19.21 10:714:22 34:3.23 39:5 worker 32:11 working 17:5 13:15 34:23.15 35:7 40:1 works 17:3,15 23:14.15 33:17.22 34:9,15 35:3.24 35:4 33:2,11 39:5 40:1,2 47:15 57:19 53:5,22 worried 31:4 worship 19:10 wrong 33:5 Yardi 13:21 15:4 year 9:10.11 10:20 35:16 4129.10 44:22.23 46:23 71:5.6.15 87:19 years 7:18 8:24 9:210:7.1911:24 27:15 31:11.21 46:24 65:11,23,24 69:5.23 73:9 74:18 78:20 young 12:9 56:5 youngest 17:17 0.8. Legal Support, (312) 236?8352 Inc.