HomeMy Public PortalAboutWilliam Thrasher Deposition1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT, IN AND FOR PALM
BEACH COUNTY, FLORIDA
CASE NO.: 50-2013-CA-018101-XXXX-MB-AO
CHRISTOPHER F. O'HARE,
Plaintiff,
vs.
TOWN OF GULF STREAM,
Defendant.
_________________________________/
100 Sea Road
Gulf Stream, Florida
Friday, 11:35 a.m.
April 7, 2017
VIDEOTAPED DEPOSITION of WILLIAM THRASHER,
a witness herein, taken pursuant to the Rules and Notice
hereinbefore filed, before SHAWN R. REMENAR, Court
Reporter and Notary Public in and for the State of
Florida at Large, at the Gulf Stream Town Hall, 100 Sea
Road, Gulf Stream, Florida, on Friday, April 7, 2017,
commencing at or about 11:35 a.m.
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 APPEARANCES:
2 LOUIS ROEDER, ESQUIRE
7414 Sparkling Lake Road
3 Orlando, Florida 32819
(407) 758-4194
4 Of Counsel
On behalf of the Plaintiff
5
EDWARD (TREY) C. NAZZARO, ESQUIRE
6 100 Sea Road
Gulf Stream, Florida 33483
7 (561) 276-5116
Of Counsel
8 On behalf of the Defendant
9
PRESENT:
10
WILLIAM THRASHER
11 Deponent
12 CHRISTOPHER F. O'HARE
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REPORTED BY:
14
SHAWN R. REMENAR
15 Court Reporter and
Notary Public
16 101 Northeast 3rd Avenue
Suite 1500
17 Fort Lauderdale, Florida 33301
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1 I N D E X
2 WITNESS EXAMINATION PAGE
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WILLIAM THRASHER Direct 4
4 (By Mr. Roeder)
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12 E X H I B I T S
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1 MR. O'HARE: Yes, please. This is a video
2 recording of deposition of Mr. William Thrasher
3 on April 7, 2017, in the case of O'Hare vs.
4 Town of Gulf Stream, Case No.: CA-018101.
5 THEREUPON:
6 WILLIAM THRASHER
7 having been first duly sworn, was examined and testified
8 as follows:
9 THE WITNESS: Yes.
10 DIRECT EXAMINATION
11 BY MR. ROEDER:
12 Q And your name for the record?
13 A William Harrison Thrasher, Jr.
14 Q Your professional title and address here
15 at the town?
16 A Town manager, 100 Sea Road, Gulf Stream,
17 Florida 33483.
18 Q And again as I told Rita, we've had
19 depositions before. If you got any questions about
20 anything, Bill, please stop and ask for clarification.
21 I'll be more than happy to give it. And if you don't
22 know the answer, just say you don't know the answer.
23 A Okay.
24 Q What are your responsibilities as town
25 manager?
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1 A They are described in our code, but in my
2 recollection of that, it is the day-to-day operation of
3 the town. I carry out the policies, both written and
4 oral, given to me by town commission or by the code book.
5 Q Do one of those duties include partici-
6 pating and responding to public records requests?
7 A I think inherently it does. Yes.
8 Q How many hours do you spend approximately,
9 or can you tell me how many hours you spent between
10 October, 2015, and September, 2016 in evaluating,
11 researching, and answering public records requests?
12 A You're asking me if I can tell you how
13 many hours.
14 Q Yeah. Can you?
15 A No.
16 Q Any idea? Was it more than a hundred?
17 A More than a hundred what?
18 Q Hours.
19 A In a three-year period?
20 Q No, from 2000--October, 2015, to
21 September, 2016, a one-year period.
22 A I don't know.
23 Q How about between the time period October
24 1, 2014, and September, 2015?
25 A I'm not--
6
Fort Lauderdale, Florida 954-755-6401
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1 Q Any idea?
2 A --able to recall that.
3 Q Do you have any idea about how much time
4 has been spent by you in all of Mr. O'Hare's public
5 records requests?
6 A No.
7 Q Have you ever been overwhelmed in your job
8 because of Mr. O'Hare's public records requests?
9 A No.
10 Q Have you ever had to shut down your office
11 during normal hours because of Mr. O'Hare's public
12 records requests?
13 A From time to time, we close town hall
14 during town commission meetings or A.R.P.B. meetings if
15 we're short on staff. I can't say that it's directly
16 related to such a request of Mr. O'Hare.
17 Q Little confused about that one, but let
18 that one--
19 A I'm--
20 Q --stand.
21 A I'm sorry. I didn't hear you.
22 Q I say, "Have you ever had to shut down the
23 town?" I understand maybe shutting down the town
24 operations because of commission meeting. But have you
25 ever had to--have you ever had to shut down the town
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1 because of requests, public records requests, being made
2 by Mr. O'Hare?
3 A You mean--
4 MR. NAZZARO: Object to form.
5 THE WITNESS: --shut down the whole town?
6 BY MR. ROEDER:
7 Q Or shut down your office.
8 A Shut down town hall as it relates to the
9 offices, we have.
10 Q You've had to shut them down.
11 A Whether or not it's related directly to
12 Mr. O'Hare or anybody's public records request, I cannot
13 say.
14 Q Okay. And--and when you did shut down
15 town hall, specifically, what did that have to deal with?
16 What caused the town hall to shut down?
17 A Staff capabilities or short, shortness of
18 staff.
19 Q So--so you've actually had the functions
20 of town hall shut down one time because of staff being
21 unable to perform.
22 A I think we've done it more than once.
23 Q And you--can you say whether that ever had
24 to do with any of the requests, public records requests,
25 Mr. O'Hare made?
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Fort Lauderdale, Florida 954-755-6401
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1 A Not--I cannot say it's directly related.
2 Q And when was that, that, that happened?
3 A I don't--I don't recall.
4 Q But you say it's happened several times.
5 A It's happened, I would say, a few times.
6 Q Few times? How long does that occur
7 usually when it shuts down?
8 A During--during the time of the public
9 hearing, public meeting.
10 Q Oh, so just let me go back. What you're
11 saying is that the town hall shuts--functions of town
12 hall shut down during a public commission meeting. But
13 as far outside of the public commission meeting, has town
14 hall functions ever shut down?
15 A Well, if town hall's closed, I would say
16 the function of town hall--
17 Q During regular business hours, has it ever
18 had to shut down for anything other than a commission
19 meeting?
20 A Yes.
21 Q When it--when that happened, did it happen
22 because of any public records requests that Mr. O'Hare
23 made?
24 A Not that I recall.
25 Q Oh, okay. But you can't remember exactly
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1 when that happened or for how long the shutdowns oc-
2 curred.
3 A No.
4 MR. O'HARE: Here and last year.
5 BY MR. ROEDER:
6 Q Yeah. It's--I guess we're trying to do is
7 get down the--you're saying you can't recall when, but
8 just try and see if I can narrow it down. You're saying
9 you do remember there's a time that the office has had to
10 shut down, a time or times the office has had to shut
11 down outside of shutting down for a commission meeting.
12 And you can't say how many times that
13 happened for sure or for how long it happened for sure.
14 But do you know any idea what year that may have hap-
15 pened?
16 A No.
17 Q So you just know that it's happened. It
18 was shut down, but you can't tell for what purpose. But
19 what you have said is that it has not happened because of
20 the requests that Mr. O'Hare has made.
21 A I'm not so sure that's how I phrased it.
22 But I think I said something to the effect that I cannot
23 say that it was directly related to any public records
24 request made by Mr. O'Hare.
25 Q Okay. Then you may not know when the
10
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1 shutdown--the shutdown or shutdowns may have happened.
2 But is there anybody who may know exactly when that was
3 or how we may be able to find out when that happened?
4 A I don't think so.
5 Q And other than your testimony here today,
6 is there any other proof we might be able to obtain as to
7 the town hall shutting down?
8 A I don't think so.
9 Q So there's no proof. There's no way you
10 know of that we could try and discover when that hap-
11 pened.
12 A I think I've answered that. I don't think
13 so.
14 Q Okay. Apart and separate from the shut-
15 down during normal business hours and performance of your
16 duties, have you ever had to refuse providing any of your
17 customary services because you're overwhelmed in your job
18 duties?
19 A Have I--
20 Q Yes.
21 A --been forced to shut down town hall?
22 Q No, been--been forced to refuse--have you
23 been forced to refuse any of your customary services
24 because of being overwhelmed?
25 A No.
11
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Okay. Have you ever had to shut down or
2 refuse your services due to any request, public records
3 request, made by Mr. O'Hare?
4 A I think so, but I can't be for sure. And
5 I couldn't tell you what the instance was.
6 Q And do you know of the clerk, town clerk,
7 ever shutting down her office because of any public
8 records request being made by Mr. O'Hare?
9 A Not shutting down, no, but not being able
10 to perform duty, certain other duties. I think that's
11 happened.
12 Q So they haven't been able to perform their
13 other duties.
14 A Yeah.
15 Q Do you know what other duties those were?
16 A The associated duties of a town clerk
17 generally speaking.
18 Q Has anyone in your office ever told you
19 they were scared because of public records requests made
20 by Mr. O'Hare?
21 A I've been told they're scared, but not
22 specifically associated with public records requests by
23 Mr. O'Hare.
24 Q And getting back to being--you're saying
25 that shutdowns that you've had unrelated to commission
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1 meetings, what is the procedure for shutting down? When
2 you shut down, what does that entail? Do you lock the
3 doors? Do people go home? What's entailed with shutting
4 down?
5 A We have no policy as it relates to that,
6 but the doors were locked. Sign was posted to the door.
7 Q And what did, basically, that say?
8 A I don't recall.
9 Q Some of the same general questions here,
10 just one second. I'll keep going on here. Do you con-
11 sider Gulf Stream to be a small town?
12 A By what consideration or gauge are you
13 speaking of?
14 Q Well, there--different counsel for the
15 town refer to Gulf Stream as being a small town. Dif-
16 ferent newspaper articles interviewing different people
17 from Gulf Stream administration referring to Gulf Stream
18 as a small town, I just wondered do you consider Gulf
19 Stream to be a small town.
20 A Yes.
21 Q And do you--even if it's a small town, in
22 your opinion, it has the same powers granted to it as any
23 other municipality within the state of Florida.
24 MR. NAZZARO: Object to form.
25 THE WITNESS: I think that's a complicated
13
Fort Lauderdale, Florida 954-755-6401
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1 question. It calls for a legal conclusion, and
2 I don't know.
3 BY MR. ROEDER:
4 Q You don't know. Do you know of any powers
5 that Gulf Stream may have i.e. to legislate, or regulate,
6 tax, or enforce codes, any powers that they may not have
7 because they're a small--because they're a small size?
8 MR. NAZZARO: Object to form.
9 THE WITNESS: I think that's a similar
10 answer, calls for a legal conclusion. And I
11 don't know.
12 BY MR. ROEDER:
13 Q When you say, "Gulf Stream is a small
14 town," not asking for a legal conclusion, just asking in
15 your opinion, if it's a small town. Do you consider it
16 to be--
17 A I--I have no opinion.
18 Q Well, finish the question. As a small
19 town, does Gulf Stream--because you consider it to be a
20 small town, do you consider Gulf Stream to be exempt from
21 any of its obligations under Florida Statute 119?
22 MR. NAZZARO: Object to form.
23 THE WITNESS: Again, a legal question,
24 but--
25 BY MR. ROEDER:
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Fort Lauderdale, Florida 954-755-6401
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1 Q Not asking in your--
2 A --exemption, I don't know what exemption
3 means.
4 Q Do you think even though Gulf Stream's a
5 small town, in your opinion, not a legal opinion, but in
6 your opinion as administrator, basically, covering all
7 these duties within Gulf Stream, do you consider any of
8 the obligations that the town may have under one nineteen
9 to be different because it's a small town?
10 MR. NAZZARO: Object to form.
11 THE WITNESS: I believe that the town of
12 Gulf Stream is obligated to fulfill the duties,
13 obligations stated in Florida Statute 119.
14 BY MR. ROEDER:
15 Q So in your opinion, there's no reason that
16 Gulf Stream should be excused from complying with any
17 parts of one nineteen.
18 MR. NAZZARO: Object to form.
19 THE WITNESS: Question, am I required to
20 give an opinion?
21 BY MR. ROEDER:
22 Q You're not required. I'm asking in your
23 opinion, do you think that because it--it has--
24 A I don't want to give an opinion.
25 Q You don't want to give an opinion.
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Fort Lauderdale, Florida 954-755-6401
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1 A I'm not going to give an opinion.
2 Q So to the extent that your opinion about
3 whether or not Gulf Stream is obligated underneath
4 Florida Statute 119, regardless of size, you don't think
5 that, that has--your opinion on that may have an in-
6 fluence on whether or not people under you will--will
7 abide by one nineteen or not.
8 A I believe we are obligated to fulfill the
9 obligations and requirements of Statute 119.
10 Q Regardless of size?
11 MR. NAZZARO: Object to form.
12 THE WITNESS: My answer remains the same.
13 We are obligated to fulfill the requirements
14 and--
15 BY MR. ROEDER:
16 Q In your opinion, this is self-reflection
17 of your job. In your opinion, do you think that there
18 are any of your job functions you can't provide because
19 of the limitation of the town size?
20 A Yes.
21 Q Like what?
22 A Financial.
23 Q An example?
24 A Budget.
25 Q You mean there's some budget items you
16
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1 can't afford because of your size.
2 A Because of the size of our budget.
3 Q And that keeps you from performing some of
4 your duties as town manager.
5 A Not duties. I'm obligated to fulfill my
6 duties as outlined by our town code.
7 Q But size doesn't affect your ability to
8 perform your duties.
9 A It--I'm obligated to fulfill the duties as
10 prescribed in our code.
11 Q And as far as your oversight of public
12 records, let me just keep this in. That's--that's the
13 preamble to all these questions here coming up. Is it
14 your understanding the custodian of records can charge a
15 requester the cost of producing those records?
16 A I think that's a legal question and--
17 Q It's an operational question. If that's
18 the case, then I guess every time somebody submits a
19 request, you got to run to an attorney and ask if you can
20 charge to produce the record. Or do you--is it your
21 understanding that as--as your job as you know it, can
22 you charge a requester a fee for producing a public
23 record?
24 MR. NAZZARO: Object to form.
25 THE WITNESS: Can the town charge a fee?
17
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1 BY MR. ROEDER:
2 Q Yes, for producing a public record.
3 A Not--not all the time.
4 Q What would be those times when not?
5 A If we're able to, under our current
6 policy, provide a public record within fifteen minutes of
7 town staff work effort.
8 Q Even if you had fifteen minutes, are
9 you--aren't you still entitled to charge the actual cost
10 of duplication for the public record?
11 A I think in some instances, we are, but I'm
12 not sure.
13 Q Are you entitled to charge for extensive
14 clerical or supervisory assistance required to produce
15 the record?
16 MR. NAZZARO: Object to form.
17 THE WITNESS: Extens--I don't know what
18 you mean by excessive. Could you define that
19 for me?
20 BY MR. ROEDER:
21 Q It's called extensive clerical supervisory
22 assistance. It says "stated in the statute". Just
23 wondering is it your understanding that you can charge--
24 you're entitled to charge for those type of services.
25 MR. NAZZARO: Object to form.
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1 THE WITNESS: I--I still really don't know
2 what extensive means.
3 BY MR. ROEDER:
4 Q Are you entitled to be paid for providing
5 a--for providing--I'm getting dry. Are you entitled to
6 be paid for providing an estimate for producing records?
7 MR. NAZZARO: Object to form.
8 THE WITNESS: I don't know the answer, but
9 I don't believe so.
10 BY MR. ROEDER:
11 Q Do you know whether the town has ever
12 charged or sought to charge for an estimate to produce a
13 public record?
14 MR. NAZZARO: Object to form.
15 THE WITNESS: You mean charge for the cost
16 of preparing the estimate. Is that what you're
17 asking me?
18 BY MR. ROEDER:
19 Q Yes.
20 A I don't think so.
21 Q So the town has never charged for it.
22 Then in your opinion, the town is, basically, not en-
23 titled to be paid for an estimate for the cost to produce
24 a public record.
25 A No. I--I was referring to the time it
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1 would take to prepare an estimate for the requester.
2 Q And you think the--
3 A Just that time there.
4 Q And you think that time is the town--is
5 the town entitled to charge for that?
6 A I don't think so.
7 Q Okay.
8 A Could be wrong, but I don't think so.
9 Q And if you don't think so, do you think
10 that, that then is the policy for the town?
11 MR. NAZZARO: Object to form.
12 THE WITNESS: I believe so. I think
13 that's the practice of the town.
14 BY MR. ROEDER:
15 Q And if you come up with an estimate--
16 A Yes.
17 Q --and then tell the requester he needs to
18 make a deposit before you can provide the record, he
19 chooses not to pay the deposit. Are you still entitled
20 to charge for it even though you're not producing the
21 record?
22 MR. NAZZARO: Object to form.
23 THE WITNESS: Charging could mean sending
24 a bill and requiring a--a payment. Is that
25 what you mean?
20
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1 BY MR. ROEDER:
2 Q Correct, correct.
3 A We are to be paid for that which is
4 produced if it meets the requirements of Statute 119.
5 Q And is there a time when--you may have
6 already answered this, but just want to be explicit. Is
7 there a time or circumstance under which the town may
8 choose not to charge for producing a public record?
9 A By policy, I--I don't--I don't think so.
10 Q Have you ever expressed a dissatisfaction
11 with the job performance of anybody working under you
12 regarding public records?
13 A Yes.
14 Q Who was that?
15 A I believe her name was Liz. I don't
16 remember her last name.
17 Q And do you know when that might have been?
18 A 2016.
19 Q What were the circumstances?
20 A If I recall correctly, a temp person who
21 had been instructed that Social Security numbers were to
22 be redacted. And in this specific case, the individual
23 that had basic supervision of this person noticed that
24 the records were askewed on our web site, askewed, lop-
25 sided, not clearly uniformly placed.
21
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1 Those records had Social Security numbers
2 redacted. She was instructed to straighten up the ap-
3 pearance on the web site. She did that, but in the pro-
4 cess, she forgot to redact the Social Security numbers,
5 something like that.
6 Q Any other occasion?
7 A I've had general conversations with pro-
8 bably everybody involved with public records, not to the
9 extent of making it a note to the file or part of their
10 personnel files, but certain encouragements.
11 Q With respect to Liz in that 2016 occur-
12 rence, who was her supervisor at the time?
13 A That would be the--in essence, I was her
14 supervisor. I said "the person that was taking care of
15 basic supervision and instruction".
16 Q So was the temporary worker reprimanded or
17 any action taken?
18 A She was not called back to work.
19 Q I got it. So--
20 MR. O'HARE: Exclusively?
21 BY MR. ROEDER:
22 Q --yes. I--you said that you were the
23 supervisor of that worker. Was that exclusively you were
24 the supervisor?
25 A No.
22
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1 Q Who else may have been?
2 A Rebecca Tew.
3 Q Has the mayor ever expressed dissatis-
4 faction with anyone's job performance regarding public
5 records?
6 A I--I don't know that.
7 Q If he did, he would talk to you about it
8 as being town manager. Were you ever--
9 A That would be the proper thing to do.
10 Q Well, he ever talk to anybody else about
11 it?
12 A I don't know if he did or didn't. You'd
13 have to ask him.
14 Q So it would be proper for him to express
15 it to you.
16 A I believe so.
17 Q So besides Liz and the supervision of
18 Rebecca Tew, has there ever been anybody else underneath
19 your supervision that may have, in your opinion, had an
20 unsatisfactory job performance regarding the production
21 of public records?
22 A Not materially.
23 Q This is not calling for a legal opinion,
24 just as you understand the adjective. But has any of the
25 public records requests submitted by Mr. O'Hare, have you
23
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1 considered any of those to be frivolous?
2 MR. NAZZARO: Objection, object to form.
3 THE WITNESS: That is a legal conclusion.
4 I'm not going to make it.
5 BY MR. ROEDER:
6 Q Well, I'm going to think of a different
7 word. As unnecessary, pointless?
8 A I have no opinion.
9 Q So regardless of his motivation, it's--you
10 consider it your job to produce the public record.
11 A It's the town's responsibility to produce
12 public records.
13 Q Have you ever expressed any opinions to
14 anybody, either staff or anyone else, as to what dealing
15 with Mr. O'Hare and public records, what that--what
16 effect that may have on you?
17 A Not that I recall.
18 Q You never told anybody it makes your head
19 spin.
20 A Not that I recall.
21 Q Okay. So to your knowledge, Mr. O'Hare's
22 made requests for public records regarding code enforce-
23 ment items. Correct?
24 A Yes.
25 Q He's made public records regarding town
24
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1 policies. Correct?
2 A Yes.
3 Q He's made public records requests re-
4 garding commission decisions.
5 A Yes.
6 Q He's made public records requests re-
7 garding public meetings.
8 A Yes.
9 Q And why do you think he makes his request
10 and expect these kind of public records?
11 A I don't know. You'd have to ask him.
12 Q Have you ever expressed your obligations
13 to comply with one nineteen or Florida's open government
14 law to be burdensome?
15 A Not that I recall.
16 Q Have you ever referred to your duties
17 under one nineteen or under Florida's open government to
18 be unreasonable?
19 A Not that I recall.
20 Q And this is a question that's probably--
21 you, Bill, probably--complimentary, probably the only
22 person who could probably answer this one. But do you--
23 do you have any idea how much money the town has spent in
24 training, computers, and software to create and/or update
25 your Public Records Department?
25
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1 A Repeat the question please.
2 Q Do you know how much money the town has
3 spent in training, computers, software, to create and/or
4 update your Public Records Department?
5 A I--I only have a general idea, a few
6 hundred thousand.
7 Q When you say "a few", more than a hundred?
8 A More than a hundred.
9 Q More than two hundred?
10 A I think so.
11 Q Can I try and bracket it more than three
12 hundred?
13 A I--I don't know.
14 Q Somewhere at least north of two hundred
15 thousand?
16 A Believe so.
17 Q And how much of that expense I'll refer to
18 as to create and update, how much of that expense in your
19 opinion, in your knowledge as town manager, was related
20 to catch-up regarding technology?
21 A I would say seventy-five thousand.
22 Q Do you have any idea whatsoever re-
23 garding--or can you put an estimate on how much money the
24 town may have spent to respond to collect the lead to Mr.
25 O'Hare's public records request?
26
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1 A No.
2 Q Let me just back up here. Of the two
3 hundred thousand dollars north of--as far as to create
4 and update Public Records Department and seventy-five
5 thousand for technology, is there any part of that ex-
6 pense which was directly attributable to responding to
7 Mr. O'Hare's public records request?
8 A I don't know.
9 Q Do you know how much--of all those
10 expenses you gave, do you know how much of that has been
11 spent creating the publicly accessible on-line archive of
12 public records that the town has?
13 A No.
14 Q And were any of these costs that we've
15 spoken about here in the last couple of questions, the
16 two hundred thousand, the seventy-five thousand, none of
17 those you can make direct--directly attributable to re-
18 sponding to Mr. O'Hare's public records requests.
19 A Not able to, no.
20 MR. ROEDER: Chris, you got anything else?
21 MR. O'HARE: Yeah, next page--
22 MR. ROEDER: Oh, whole page, that's right.
23 MR. O'HARE: --and this.
24 BY MR. ROEDER:
25 Q Have you ever attended commission meetings
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Daughters Reporting, Inc.
1 in which Mr. O'Hare asked questions to the commission?
2 A Yes.
3 Q And any of those times, has the commission
4 instructed Mr. O'Hare to direct his questions to you?
5 A Once or twice, the mayor has.
6 Q And to your knowledge, has Mr. O'Hare
7 followed up and sent you correspondence--
8 A Yes.
9 Q --to ask--ask these questions?
10 A Yes.
11 Q Did you respond to all of his correspon-
12 dence?
13 A No.
14 Q Why not?
15 A Advice of counsel.
16 Q So then Mr. O'Hare has made public records
17 requests to you or to you, the town's public records
18 custodian, with regards to the subject matters he's
19 usually asked you about.
20 MR. NAZZARO: Object to form.
21 BY MR. ROEDER:
22 Q Let me rephrase that. Are you aware of
23 Mr. O'Hare having--you said you did not respond to all of
24 his requests.
25 A Yes.
28
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Are you aware of any requests that he may
2 have been made to the public records custodian in order
3 to get answers to the questions that he put to you?
4 A I don't know.
5 Q And just to go back and clarify, when you
6 shut down, we're using that term rather loosely. I don't
7 mean to be the windows boarded up. But when you shut
8 down the town hall, the functions of town hall during
9 commission meetings, do you--are you turning residents
10 away during regular business hours during the commission
11 meeting?
12 A On a couple occasions, yes.
13 Q And that--you put up signs in the door
14 during those times that, basically, says that the town is
15 shut down.
16 A On the office doors.
17 Q Okay. And at the times, you mentioned
18 that you had shut down at least once or twice. I forget
19 now how many times you referred to it. But you had shut
20 down the town on occasions other than commission
21 meetings.
22 A (Witness nods head).
23 Q Have you turned people away during those
24 times as well?
25 A Yes.
29
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 Q Posted signs during those times as well?
2 A Yes.
3 Q And when you shut down the town during any
4 normal business hours, are you required to post this any-
5 where, any type of journal, or any kind of record?
6 MR. NAZZARO: Object to form.
7 THE WITNESS: I don't know the answer to
8 the question.
9 BY MR. ROEDER:
10 Q Have you ever notified the mayor whenever
11 the town has had to shut down during normal business
12 hours?
13 A Don't recall.
14 Q Have you ever notified the Police Depart-
15 ment when you've had to shut down the town during normal
16 business hours?
17 A Yes.
18 Q What do you usually tell them?
19 A Town hall will be closed.
20 Q Have you ever notified anyone else about
21 the town shutting down during normal business hours?
22 A Not that I recall.
23 MR. ROEDER: Chris, you have any more
24 questions?
25 MR. O'HARE: We got everything we need.
30
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 MR. ROEDER: All right, Bill. That's it.
2 THE WITNESS: Okay. Thank you.
3 COURT REPORTER: Do you want these tran-
4 scribed both?
5 MR. ROEDER: Yeah. Both of these tran-
6 scribed?
7 MR. O'HARE: Oh, yeah.
8 MR. ROEDER: Yeah.
9 COURT REPORTER: Okay. Regular service?
10 MR. ROEDER: Yes.
11 COURT REPORTER: Okay. Do you want
12 copies?
13 MR. NAZZARO: Yeah, if they're ordered,
14 and we'll read. Yeah. If they order, we'll
15 read, and we'll take a copy.
16 (Whereupon, the videotaped deposition was
17 concluded at 12:15 p.m.)
18
19
20
21
22
23
24
25
31
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 CERTIFICATE OF OATH
2
3
4 STATE OF FLORIDA )
5 ) SS
6 COUNTY OF BROWARD )
7
8
9 I, the undersigned authority, certify that
10 WILLIAM THRASHER personally appeared before me and was
11 duly sworn.
12
13 WITNESS my hand and official seal this 21st
14 day of April, 2017.
15
16
17
18
19
20
21 ______________________________
SHAWN R. REMENAR, COURT REPORTER
22 Commission No.: FF925834
Expires: December 7, 2019
23
24
25
32
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 REPORTER'S DEPOSITION CERTIFICATE
2
3
4
5 I, SHAWN R. REMENAR, Registered Professional
6 Reporter, certify that I was authorized to and did
7 stenographically report the videotaped deposition of
8 WILLIAM THRASHER; that a review of the transcript was
9 requested; and that the transcript is a true and complete
10 record of my stenographic notes.
11
12 I further certify that I am not a relative,
13 employee, attorney or counsel of any of the parties, nor
14 am I a relative or employee of any of the parties'
15 attorney or counsel connected with the action, nor am I
16 financially interested in the action.
17
18 Dated this 21st day of April, 2017.
19
20
21
22 ___________________________________
23 SHAWN R. REMENAR, COURT REPORTER
24
25
33
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 DEPOSITION ERRATA SHEET
2 Page No. __________Line No.__________Change to:__________
3 _________________________________________________________
4 Reason for change:_______________________________________
5 Page No.___________Line No. _________Change to:__________
6 _________________________________________________________
7 Reason for change:_______________________________________
8 Page No.___________Line No.__________Change to:__________
9 Reason for change:_______________________________________
10 Page No.__________Line No.___________Change to:__________
11 _________________________________________________________
12 Reason for change:_______________________________________
13 Page No.__________Line No.___________Change to:__________
14 _________________________________________________________
15 Reason for change:_______________________________________
16 Page No.__________Line No.___________Change to:__________
17 _________________________________________________________
18 Reason for change:_______________________________________
19 Page No.__________Line No.___________Change to:__________
20 _________________________________________________________
21 Reason for change:_______________________________________
22 SIGNATURE:______________________DATE:____________
WILLIAM THRASHER
23
Please forward the original signed errata sheet to this
24 office so that copies may be distributed to all parties.
25
34
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1 DAUGHTERS REPORTING, INC.
101 Northeast 3rd Avenue
2 Suite 1500
Fort Lauderdale, Florida 33301
3
(954) 755-6401
4
April 21, 2017
5
Mr. William Thrasher
6 c/o Edward (Trey) C. Nazzaro, Esquire
100 Sea Road
7 Gulf Stream, Florida 33483
8 RE: CHRISTOPHER F. O'HARE VS. TOWN
OF GULF STREAM
9 Case No.: 50-2013-CA-018101-XXXX-MB-AO
10 Dear Mr. Thrasher:
11 Relative to the above, please be advised that your
deposition taken on April 7, 2017, is available at our
12 office for reading, the making of any corrections,
additions or alterations, and signing your deposition
13 here at this office.
14 The deposition will be forwarded to LOUIS ROEDER,
ESQUIRE, as required, with or without your signature by
15 noon on May 5, 2017.
16 Please call this office to make an appointment to read
your deposition to assure that we will have someone here
17 to assist you.
18 Sincerely,
19
20 Shawn R. Remenar
Court Reporter
21
cc: Louis Roeder, Esquire
22 Edward (Trey) C. Nazzaro, Esquire
23
24
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
1
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
A
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27:7
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18:15,23
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2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
32:13,15
COUNTY 1:2
31:6
couple 26:15
28:12
Court 1:1,17
2:15 30:3,9,11
31:21 32:23
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D 3:1
DATE 33:22
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DAUGHTERS
34:1
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day-to-day 5:2
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December 31:22
decisions 24:4
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deposition 1:15
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32:7 33:1
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17:10
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8:8
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fifteen 17:6,8
file 21:9
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1:19,20 2:3,6
2:17 4:17
12:23 13:21
14:13 15:4
31:4 34:2,7
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followed 27:7
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13:8,22 14:10
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happened 8:2,4
3
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
8:5,21 9:1,13
9:13,17,19
10:1,3 11:11
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13:8,22 14:10
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18:7,14 19:11
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8:25 9:25
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4
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
28:17 30:2,9
30:11
on-line 26:11
once 7:22 27:5
28:18
one--6:18
one-year 5:21
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operations 6:24
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14:5,6,15,20
14:23,24,25
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opinions 23:13
oral 5:4
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ordered 30:13
original 33:23
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page 3:2 26:22
33:2,5,8,10,13
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part 21:9 26:5
partici-5:5
parties 32:13
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parties'32:14
parts 14:17
pating 5:6
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15:6 28:23
perform 7:21
11:10,12 16:8
performance
10:15 20:11
22:4,20
performing 16:3
period 5:19,21
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person 20:20,23
21:14 24:22
personally 31:10
personnel 21:10
phrased 9:21
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produce 16:20
17:14 18:12,23
23:10,11
produced 20:4
producing 16:15
16:22 17:2
18:6 19:20
20:8
production
22:20
professional
4:14 32:5
proof 10:6,9
proper 22:9,14
provide 15:18
17:6 19:18
providing 10:16
18:4,6
providing--I'm
18:5
public 1:18 2:15
5:6,11 6:4,8,11
7:1,12,24 8:8,9
8:12,13,22
9:23 11:2,7,19
11:22 16:11,22
17:2,6,10
18:13,24 20:8
20:12 21:8
22:4,21,25
23:10,12,15,22
23:25 24:3,6,7
24:10,25 25:4
25:25 26:4,7
26:12,18 27:16
27:17 28:2
publicly 26:11
purpose 9:18
pursuant 1:16
put 25:23 28:3
28:13
Q
question 13:1,18
13:23 14:19
16:16,17 24:20
25:1 29:8
questions 4:19
12:9 16:13
26:15 27:1,4,9
28:3 29:24
R
R 1:17 2:14
31:21 32:5,23
34:20
re-24:3,6 25:22
26:17
read 30:14,15
34:16
reading 34:12
really 18:1
reason 14:15
33:4,7,9,12,15
33:18,21
Rebecca 22:2,18
recall 6:2 8:3,24
9:7 12:8 20:20
23:17,20 24:15
24:19 29:13,22
recollection 5:2
record 4:12
16:20,23 17:2
17:6,10,15
18:13,24 19:18
19:21 20:8
23:10 29:5
32:10
recording 4:2
records 5:6,11
6:5,8,12 7:1,12
7:24 8:22 9:23
11:2,8,19,22
16:12,14,15
18:6 20:12,24
21:1,8 22:5,21
22:25 23:12,15
23:22,25 24:3
24:6,10,25
25:4,25 26:4,7
26:12,18 27:16
27:17 28:2
redact 21:4
redacted 20:22
21:2
refer 12:15
25:17
referred 24:16
28:19
referring 12:17
18:25
refuse 10:16,23
11:2
refuse--have
10:22
regarding 20:12
22:4,20 23:22
23:25 25:20
regardless 15:4
15:10 23:9
regards 27:18
Registered 32:5
regular 8:17
28:10 30:9
regulate 13:5
related 6:16 7:11
8:1 9:23 25:19
relates 7:8 12:5
relative 32:12,14
34:11
remains 15:12
remember 8:25
9:9 20:16
Remenar 1:17
2:14 31:21
32:5,23 34:20
rence 21:12
Repeat 25:1
rephrase 27:22
report 32:7
REPORTED
2:13
Reporter 1:18
2:15 30:3,9,11
31:21 32:6,23
34:20
REPORTER'S
32:1
5
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
REPORTING
34:1
reprimanded
21:16
request 6:16
7:12 9:24 11:2
11:3,8 16:19
24:9 25:25
26:7
requested 32:9
requester 16:15
16:22 19:1,17
requests 5:6,11
6:5,8,12 7:1,1
7:24,24 8:22
9:20 11:19,22
22:25 23:22
24:3,6 26:18
27:17,24 28:1
required 14:19
14:22 17:14
29:4 34:14
requirements
15:9,13 20:4
requiring 19:24
researching 5:11
residents 28:9
respect 21:11
respond 25:24
27:11,23
responding 5:6
26:6
responsibilities
4:24
responsibility
23:11
review 32:8
right 26:22 30:1
Rita 4:18
Road 1:11,20
2:2,6 4:16 34:6
Roeder 2:2 3:4
4:11 7:6 9:5
13:3,12,25
14:14,21 15:15
17:1,20 18:3
18:10,18 19:14
20:1 21:21
23:5 26:20,22
26:24 27:21
29:9,23 30:1,5
30:8,10 34:14
34:21
Rules 1:16
run 16:19
S
S 3:12
saying 8:11 9:7,8
11:24
says 17:22 28:14
scared 11:19,21
scribed 30:4,6
Sea 1:11,19 2:6
4:16 34:6
seal 31:13
second 12:10
Security 20:21
21:1,4
see 9:8
self-reflection
15:16
sending 19:23
sent 27:7
separate 10:14
September 5:10
5:21,24
service 30:9
services 10:17
10:23 11:2
17:24
seventy-five
25:21 26:4,16
Shawn 1:17 2:14
31:21 32:5,23
34:20
sheet 33:1,23
short 6:15 7:17
shortness 7:17
shut 6:10,22,25
7:5,7,8,10,14
7:16,20 8:12
8:14,18 9:10
9:10,18 10:21
11:1 12:2 28:6
28:7,15,18,19
29:3,11,15
shut-10:14
shutdown 10:1
shutdown--the
10:1
shutdowns 9:1
10:1 11:25
shuts 8:7
shuts--functions
8:11
shutting 6:23
9:11 10:7 11:7
11:9 12:1,3
29:21
sided 20:25
sider 12:11
Sign 12:6
signature 33:22
34:14
signed 33:23
signing 34:12
signs 28:13 29:1
similar 13:9
Sincerely 34:18
site 20:24 21:3
size 13:7 15:4,10
15:19 16:1,2,7
small 12:11,15
12:18,19,21
13:7,13,15,18
13:20 14:5,9
small--because
13:7
So--21:19
So--so 7:19
Social 20:21
21:1,4
software 24:24
25:3
somebody 16:18
sorry 6:21
sought 18:12
Sparkling 2:2
speaking 11:17
12:13
specific 20:22
specifically 7:15
11:22
spend 5:8
spent 5:9 6:4
24:23 25:3,24
26:11
spin 23:19
spoken 26:15
sponding 26:18
SS 31:5
staff 6:15 7:17
7:18,20 17:7
23:14
stand 6:20
state 1:18 12:23
31:4
stated 14:13
17:22
statute 13:21
14:13 15:4,9
17:22 20:4
stenographic
32:10
stenographica...
32:7
stop 4:20
straighten 21:2
Stream 1:7,11
1:19,20 2:6 4:4
4:16 12:11,15
12:17,17,19
13:5,13,20
14:7,12,16
15:3 34:7,8
Stream's 14:4
Stream--beca...
13:19
subject 27:18
submits 16:18
submitted 22:25
Suite 2:16 34:2
supervision
20:23 21:15
22:17,19
supervisor 21:12
21:14,23,24
supervisory
17:14,21
sure 9:13,13,21
11:4 17:12
sworn 4:7 31:11
T
T 3:12
take 19:1 30:15
taken 1:16 21:17
34:11
talk 22:7,10
tax 13:6
technology
25:20 26:5
tell 5:9,12 9:18
11:5 19:17
29:18
temp 20:20
temporary 21:16
term 28:6
testified 4:7
testimony 10:5
Tew 22:2,18
Thank 30:2
That's--that's
16:12
that--what
23:15
that--you 28:13
the--19:2
the--in 21:13
the--you're 9:7
there--different
12:14
thing 22:9
think 5:7 7:22
9:22 10:4,8,12
10:12 11:4,10
12:25 13:9
14:4,23 15:4
15:17 16:16
17:11 18:20
19:2,4,6,8,9,9
19:12 20:9
23:6 24:9
25:10
6
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
thousand 25:6
25:15,21 26:3
26:5,16,16
Thrasher 1:15
2:10 3:3 4:2,6
4:13 31:10
32:8 33:22
34:5,10
three 25:11
three-year 5:19
time 5:23 6:3,13
6:13 7:20 8:8
9:9,10 16:18
17:3 18:25
19:3,4 20:5,7
21:12
times 8:4,5,6
9:10,12 17:4
27:3 28:14,17
28:19,24 29:1
title 4:14
titled 18:23
to--have 6:25
today 10:5
told 4:18 11:18
11:21 23:18
town 1:7,19 4:4
4:15,16,24 5:3
5:4 6:13,14,23
6:23,25 7:5,8
7:15,16,20
8:11,11,13,15
8:16 10:7,21
11:6,16 12:11
12:15,15,18,19
12:21 13:14,15
13:19,20 14:5
14:8,9,11
15:19 16:4,6
16:25 17:7
18:11,21,22
19:5,10,13
20:7 22:8
23:25 24:23
25:2,19,24
26:12 28:8,8
28:14,20 29:3
29:11,15,19,21
34:8
town's 23:11
27:17
town--is 19:4
training 24:24
25:3
tran-30:3,5
transcript 32:8,9
Trey 2:5 34:6,22
true 32:9
try 9:8 10:10
25:11
trying 9:6
turned 28:23
turning 28:9
twice 27:5 28:18
two 25:9,14 26:2
26:16
type 17:24 29:5
U
unable 7:21
underneath 15:3
22:18
undersigned
31:9
understand 6:23
22:24
understanding
16:14,21 17:23
uniformly 20:25
unnecessary
23:7
unreasonable
24:18
unrelated 11:25
unsatisfactory
22:20
update 24:24
25:4,18 26:4
usually 8:7
27:19 29:18
V
video 4:1
videotaped 1:15
30:16 32:7
vs 1:6 4:3 34:8
W
want 14:24,25
20:6 30:3,11
way 10:9
we'll 30:14,14,15
we're 6:15 9:6
17:5 28:6
we've 4:18 7:22
26:14
web 20:24 21:3
whatsoever
25:22
when--you 20:5
will--will 15:6
William 1:15
2:10 3:3 4:2,6
4:13 31:10
32:8 33:22
34:5
windows 28:7
witness 1:16 3:2
4:9 7:5 12:25
13:9,23 14:11
14:19 15:12
16:25 17:17
18:1,8,15
19:12,23 23:3
28:22 29:7
30:2 31:13
wondered 12:18
wondering
17:23
word 23:7
work 17:7 21:18
worker 21:16,23
working 20:11
written 5:3
wrong 19:8
X
X 3:1,12
Y
yeah 5:14 9:6
11:14 26:21
30:5,7,8,13,14
year 9:4,14
you--24:22
you--are 28:9
you--aren't 17:9
you--can 7:23
you--even 12:21
you--is 16:20
your--14:1
Z
0
1
1 5:24
100 1:11,19 2:6
4:16 34:6
101 2:16 34:1
11:35 1:12,21
119 13:21 14:13
15:4,9 20:4
12:15 30:17
1500 2:16 34:2
15TH 1:1
2
2000--October
5:20
2014 5:24
2015 5:10,20,24
2016 5:10,21
20:18 21:11
2017 1:12,20 4:3
31:14 32:18
34:4,11,15
2019 31:22
21 34:4
21st 31:13 32:18
276-5116 2:7
3
32819 2:3
33301 2:17 34:2
33483 2:6 4:17
34:7
3rd 2:16 34:1
4
4 3:3
407 2:3
5
5 34:15
50-2013-CA-0...
1:3 34:9
561 2:7
6
7
7 1:12,20 4:3
31:22 34:11
7414 2:2
755-6401 34:3
758-4194 2:3
8
9
954 34:3