HomeMy Public PortalAboutWilliam Thrasher Transcript 07/09/13 - Vol. 3Certified Copy
In the Matter Of:
O'BOYLE vs. TOWN OF GULF STREAM
502013CA00675OXXXXMB AO
WILLIAM H. THRASHER, CGFO
July 09, 2013
Vol. III
C)ESQUIRE 800.211.DEPO (3376)
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S O L U T I O N S
WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 200
1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2
CASE NO. 502013CA00675OXXXXMB AO
3
MARTIN E. O'BOYLE
4
Plaintiff,
5 VS.
6 TOWN OF GULF STREAM,
7 Defendant,
8
9
10
11
CONTINUED DEPOSITION OF WILLIAM H. THRASHER, CGFO
12
13
VOLUME III, PAGES 200-255
14
15 TUESDAY, JULY 9th, 2013
100 SEA ROAD
16 GULF STREAM, FLORIDA
1:37 p.m. - 2:54 p.m.
17
18
19
20
21
22 STENOGRAPHICALLY REPORTED BY:
VALERIE LEHTO, REGISTERED PROFESSIONAL REPORTER
23 NOTARY PUBLIC, STATE OF FLORIDA
ESQUIRE DEPOSITION SERVICES
24 FORT LAUDERDALE OFFICE
25
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
APPEARANCES:
APPEARING ON BEHALF OF THE PLAINTIFF:
July 09, 2013
201
COMMERCE GROUP.
BY: MARTIN E. O'BOYLE, PRO SE.
BY: MARRETT W. HANNA, ESQUIRE, LIMITED APPEARANCE.
1280 WEST NEWPORT CENTER DRIVE
DEERFIELD BEACH, FLORIDA 33442
(954) 570-3518
MOBOYLE@COMMERCE-GROUP.COM
MHANNA@COMMERCE-GROUP.COM
APPEARING ON BEHALF OF THE DEFENDANT:
JONES, FOSTER, JOHNSTON & STUBBS, P.A.
BY: JOHN C. RANDOLPH, ESQUIRE.
505 SOUTH FLAGLER DRIVE, SUITE 1100
WEST PALM BEACH, FLORIDA 33401
(561) 659-3000
JRANDOLPH@JONES-FOSTER.COM
ESQUIF E
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 202
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
203
1 Continued Deposition of WILLIAM H. THRASHER, CGFO,
2 taken before VALERIE LEHTO, Court Reporter/Registered
3 Professional Reporter and Notary Public in and for the
4 State of Florida at Large, in the above cause.
8 MR. RANDOLPH: Mr. O'Boyle, before you begin,
9 I would like to make a statement at the outset of
10 the deposition.
11 We have now been in deposition with
12 Mr. Thrasher seven hours and ten minutes excluding
13 any breaks that we may have taken and this is over
14 a simple public records case which includes four
15 elements: One, did you receive the documents
16 requested, two, was there an illegal redaction,
17 three, were you charged inappropriately for labor
18 and, four, were the documents provided
19 electronically as you had requested.
20 I encourage you to tailor your questions to
21 those issues at the outset of this deposition so
22 you can be sure to get all your questions asked.
23 I believe in the seven hours you have had with
24 Mr. Thrasher you've had an opportunity to cover all
25 these issues. It's my opinion you have turned this
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
204
1 deposition into a fishing expedition. I advised
2 you of this previously and gave you an opportunity
3 to explain how your questions were reasonably
4 calculated to lead to discoverable evidence, but
5 you refused to answer. At least you didn't answer
6 in the way I thought was appropriate.
7 Therefore, please be advised if you continue
8 to stray from the issues in this case and insist on
9 continuing on your fishing expedition I intend to
10 terminate this deposition.
11 At the last session I let you go on and I
12 believed that you were going to conclude on that
13 day. I believe you thought you were as well.
14 I have no intentions today, however, of
15 letting the depo continue if you continue on a
16 fishing expedition.
17 Thank you.
18
19 Thereupon,
20 WILLIAM H. THRASHER, CGFO
21 having been first duly sworn or affirmed, was examined
22 and testified as follows:
23 DIRECT EXAMINATION
24 BY MR. O'BOYLE:
25 Q. Good afternoon, Mr. Thrasher. My name is
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
205
1 Martin O'Boyle. How are you?
2 A. Good.
3 Q. Mr. Thrasher, I asked you this before, but are
4 you familiar with Chapter 119 of the Florida Statutes?
5 A. Generally, yes.
6 Q. What does generally yes mean?
7 A. I don't consider myself an expert on it.
8 Q. Okay, but aside from being an expert you're
9 well versed in it; is that correct?
10 MR. RANDOLPH: Object to the form of the
11 question.
12 THE WITNESS: I have a basic understanding of
13 it.
14 1 BY MR. O'BOYLE:
15
Q.
And what
does a
basic understanding mean?
16
A.
I have a
general
knowledge of it.
17
Q.
And what
does a
general knowledge mean?
18
A.
I don't
have an
answer.
19
Q.
Okay, if
someone
were to ask you a question
20 under Chapter 119, as an example how much are we to
21 charge for copies, would you be able to answer that
22 question?
23 A. I probably would refer to the --
24 Q. Pardon?
25 A. I probably -- I would refer to the Chapter
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WILLIAM H. THRASHER, CGFO Vol_ III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 206
1 Q. But if somebody asked you how would you answer
2 that question if the Chapter wasn't available?
3 A. That the copies are on an eight and a half by
4 eleven, eight and a half by thirteen fifteen cents each.
5 If they were double -sided they would be twenty cents, an
6 additional five cents for the second half of the page
7 and that if the copies had to be spatially produced, by
8 that I mean going to a printer who had a different type
9 of equipment, larger equipment than what we could
10 duplicate that the cost would be our cost, the Town's
11 cost for duplication and that on what might be
12 determined to be excessive investment of Town staff time
13 there would be a charge for that, excessive, meaning
14 generally one and a half, two hours, maybe.
15
Q.
I'm sorry?
in and they asked
16
A.
Generally one and a half,
two hours, perhaps.
17
Q.
Okay, so in your opinion
an excessive period
18
of time
would be one and a half to
two hours?
19
A.
It might be an hour, you
know. I don't have a
20
real --
I think the statute talks about unusual or
21 1 excessive.
22
Q. Right,
but if someone came
in and they asked
23
for a document, a
special document as
you just described
24
and it was going
to take the staff an
hour would they be
25
charged a fee, a
special I think you
called it an
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
1 extensive charge?
July 09, 2013
207
2
I don't remember the words you used.
3
A. If somebody came in to me I actually
would
4
refer them to Rita.
5
Q. I'm sorry?
6
A. If somebody came in to me and asked me
that
7
question or for that information I would refer
them to
8
our Town Clerk, Rita Taylor.
9
Q. Okay, and how would Miss Taylor make
the
10
determination of whether the billing commences
at an
11
hour, commences in an hour and fifteen minutes,
an hour
12
and a half, two hours? How would she make that
13
determination?
14
A. You'd have to ask her. I don't know.
She's
15
the custodian of records.
16
Q. So you don't have an idea?
17
A. No.
18
Q. Okay, so whatever the Clerk -- And by
the way,
19
she is the custodian of records; am I correct?
20
A. Yes.
21
Q. Okay, so whatever the custodian of records
22 1 decides to charge you're okay with it?
23 A. Yes.
24 Q. Okay, so if she charged a hundred dollars an
25 hour for fifteen minutes or ten minutes worth of work
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
1 1 you're okay with it?
July 09, 2013
208
2 MR. RANDOLPH: Objection. Object to the form
3 of the question.
4 THE WITNESS: No. I would not under those
5 circumstances be okay with it.
6 1 BY MR. O'BOYLE:
7
Q.
Where would the limitations be?
8
A.
You would have to ask her.
9
Q.
Pardon?
10
A.
You'll have to ask her.
11
Q.
In your mind where would the limitations be?
12
MR. RANDOLPH: You're not -- You don't have to
13
guess at a deposition. If you know you can answer
14
yes,
if you don't know --
15
THE WITNESS: I don't know.
16
BY MR. O'BOYLE:
17
Q.
Okay, if she charged a hundred dollars an hour
18
for ten minutes worth of work would you consider that
19
reasonable?
20
A.
No.
21
Q.
Okay, what would you consider reasonable?
22
A.
I just don't have an answer for you. I would
23
refer you
to Rita.
24
Q.
Okay, if she charged ninety dollars for ten
25 1 minutes would you consider that reasonable?
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
209
1 A. I don't have an answer fox you.
2 Q. But a hundred dollars would not be reasonable?
3 A. I don't have an answer for you, Mr. O'Boyle.
4 Q. But you've already said a hundred dollars
5 would not be reasonable.
6 A. I did.
7 Q. Am I correct?
8 A. I don't have any other answer for you.
9 Q. I understand. I just want to make sure that I
10 correctly understood you.
11 You did say a hundred dollars would not be
12 reasonable?
13-__- A. For ten minutes I thought you said.
14 Q. Yes.
15 No. I said a hundred dollars an hour for ten
16 minutes.
17 A. i did say I didn't think that would be
18 reasonable.
19 Q. You did say you didn't think it would be?
20 A. Yes.
21 Q. But ninety dollars you're not sure?
22 A. I don't have an answer for you.
23 Q. Well, you have to give me an answer.
24 MR. RANDOLPH: He indicated -- He gave you an
25 answer. He said he would have to refer to the
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
1 I records custodian.
July 09, 2013
210
2 MR. O'BOYLE: I understand that, but if he's
3 not sure it's either a yes, no or I'm not sure. He
4 can refer to the records custodian all he wants.
5 THE WITNESS: I don't know.
:1♦fi'iui�ilQi)��
7 Q. So you don't know whether ninety dollars would
8 be?
9 A. No.
10 Q. Okay, under Chapter 119 what is a reasonable
11 time to fulfill a request?
12 A. I would refer that to the Town custodian of
13 records.
14
Q.
What do you think. a reasonable time is?
15
A.
I would refer you to the custodian of the
16
records.
17
Q.
And I will ask the custodian of records, but
18
I'm asking you now: What do you think a reasonable
19
period of
time is?
20
A.
I don't know.
21
Q.
Okay, if I came in, as an example, on your
22
front table there you have a sign -in sheet; am I
23
correct?
24
A.
In the lobby, yes.
25
Q.
Okay, if I asked for - made a records request
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
211
1 for that sign -in sheet what would you think would be a
2 reasonable period of time to respond?
3 A. I would refer you to the custodian of the
4 records.
5 Q. I understand that, but what would you think?
6 A. I don't have an answer.
7 Q. You have no answer?
8 A. I don't know.
9 MR. RANDOLPH: Excuse me, and this is in the
10 form of an objection. Is one of the points in this
11 existing lawsuit that these records were not
12 produced in a reasonable period of time?
13 I don't believe it is.
14 MR. O'BOYLE: Okay, I think the point in the
15 existing lawsuit are shown in the Complaint.
16 MR. RANDOLPH: They are, and there's nothing
17 in the Complaint that indicates that these records
18 were not produced in a reasonable period of time.
19 MR. O'BOYLE: Well, that's what you say.
20 MR. RANDOLPH: Well, we can look at the
21 Complaint.
22 MR. O'BOYLE: Okay, you can look at the
23 Complaint. Meanwhile, I'm going to continue.
24 BY MR. O'BOYLE:
25 Q. Do you know if Chapter 19 (sic) requires any -
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
212
1 if there's any obligations under Chapter, I'm sorry, 119
2 to fulfill a request?
3 A. Yes.
4
MR. RANDOLPH: Did you finish your question?
5
MR. O'BOYLE: Yes.
6
BY MR.
O'BOYLE:
7
Q.
Yes, you do know that?
8
A.
To fulfill records, provide records?
9
Q.
Yes.
10
A.
Yes.
11
Q.
Okay, and what would that be?
12
A.
I don't have an answer.
13
I would refer you to the custodian of records.
14
Q.
Then how do you know?
15
A.
And I don't know.
16
Q.
You don't know if Chapter 19 (sic) has a
17
requirement?
18
A.
No, I don't know.
19
Q.
What are the charges for the copies if you're
20
also charging a, I'm not sure what the term is,
21
excessive
fee, special fee? You had said the charges
22
for eleven -by -fourteen and eleven -by -eight?
23
MS. HANNA: Eight and a half.
24 BY MR. O'BOYLE:
25 Q. Eight and a half, yes, were fifteen cents, so
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
1 I what would be the charges?
July 09, 2013
213
2 A. I don't know the answer.
3 Q. Okay, would it be fair to say that your
4 knowledge of Chapter 119 is, I'll use the term thin?
5 A. I have a general knowledge of it.
6 MR. RANDOLPH: Object to the form of the
7 question.
8 BY MR. O'BOYLE:
9 Q. And would you call it a good knowledge, an
10 excellent knowledge, a fair knowledge, a bad knowledge?
11 What would you call it?
12 A. I don't know.
13 Q. You don't know?
14 So general knowledge to you has no meaning?
15 A. I don't know.
16 Q. You don't know if general knowledge to you has
17 no meaning?
18 A. No.
19 Q. Okay, do you have any other knowledge besides
20 general knowledge?
21 A. No.
22 MR. RANDOLPH: Do you mean in regard to
23 Chapter 119?
24 MR. O'BOYLE: Yes.
25 I'm sorry. Yes.
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WILLIAM H THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
THE WITNESS: No.
July 09, 2013
214
BY MR. O'BOYLE:
Q. Okay, is there a policy here at the Town of
Gulf Stream relative to special service charges or what
you called excessive charges?
A. A written policy?
Q. Yes. We'll start there.
A. No.
Q. A verbal policy?
A. No.
Q. Okay, why did you -- I'm just curious. Why
did you distinguish?
A. I was sure about written.
Q. Pardon?
A. I was sure about written.
Q. And you're not sure about verbal?
A. I had to think about it.
Q. I see.
Okay, but now you've thought about it?
A. I answered.
Q. How then would you know how to charge?
A. I would refer that situation to the custodian
of the records.
Q. And whatever she decided you would support?
A. I would trust that her understanding would be
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 215
1 1 correct.
2
Q.
Pardon?
3
A.
I would trust that her understanding of the
4
statute would be correct.
5
Q.
Okay, our request number 332, are you familiar
6
with that,
Mr. Thrasher?
7
A.
Somewhat.
8
Q.
Okay, I see we're playing dentistry again.
9
What does somewhat mean?
10
A.
Somewhat.
11
Q.
What does somewhat. mean?
12
A.
I have no further answer. I don't know.
13
MR. RANDOLPH: Well, have you seen it? Have
14
you
seen the request or not?
15
THE WITNESS: Yes, I have seen it.
16
MR. RANDOLPH: Do you recall what it asked
17
for?
18
I'm sorry.
19
THE WITNESS: Generally it asked for all
20
communications
to and from Marty Minor and William
21
Thrasher.
22
MR. RANDOLPH: Do you want to read it?
23
THE WITNESS: Yeah.
24 BY MR. O'BOYLE:
25 Q. Okay, I think this has been marked as an
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O'BOYLE vs. TOWN OF GULF STREAM
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1 exhibit, although the copy I'm going to give you has not
2 been marked as an exhibit, although if you'd like we can
3 refer to --
4 MR. RANDOLPH: There's no need to do that. I
5 mean, I think I can look at this and remember,
6 although if you want for the purposes of the record
7 to identify the exhibit you can, but we can look at
8 this and see whether it's the one.
9 MR. O'BOYLE: That would be Plaintiff's
10 Exhibit Three if you would like to see it,
11 Mr. Randolph.
12 MR. RANDOLPH: All right, then why don't we
13 look at Plaintiff's Exhibit Three.
14 THE WITNESS: Okay, it says that --
15 MR. RANDOLPH: A question is not pending, or
16 maybe it is.
17 THE WITNESS: Oh.
18 Is the question pending? Is there a question
19 pending?
21 Q. Have you familiarized yourself with it?
22 A. Yes.
23 Q. Okay, and when was the first time you seen
24 that again?
25 A. I don't know. I don't remember.
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
217
Q. Okay, now if you -- When you saw it I assume
the custodian of records would have brought it in to see
you or you would have went in to her office and saw it?
Would that be a correct statement?
MR. RANDOLPH: Object to the form of the
question.
THE WITNESS: I don't know specifically how I
came to be aware of this.
BY MR. O'BOYLE:
Q. Okay, how about un -specifically?
A. I don't know.
Q. You don't know?
A. No.
Q. Okay, could you have seen it on the floor?
A. I guess I could have, but I didn't do that.
Q. Do you remember seeing it on the floor?
A. No.
Q. Okay, in the men's room on the sink?
A. No.
Q. In the men's room on the floor?
A. No.
Q. Okay, anywhere in the building on the floor?
A. No.
Q. Okay, anywhere in the building outside of
those double french doors leading in to where you and
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 218
Miss Taylor sit?
A. No.
Q. Okay, where else could it have been?
A. It was in there somewhere.
Q. Pardon?
A. It was in there somewhere. I just don't
remember exactly where.
Q. Okay, in there starting with the back and
moving forward your office is in the back, correct?
A. It's in the north.
Q. But it is in the back. Is that correct or no?
A. Side.
I don't know.
Q. Does it face this rear wall here? Do you have
a window in this rear wall which would be the north
wall?
A. I have a window on the north wall and the west
wall.
Q. Okay, so it's the furthest one back, otherwise
you'd be outside?
A. The furthest one to the north.
Q. To the north?
A. Yes.
Q. Which is -- Okay.
And was it in there that you first saw it?
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WILLIAM H. THRASHER, CGFO Vol. III
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219
A.
I
do
not remember. I
don't
know.
Q.
If
it
would have been
would
Rita have brought
it in to you?
MR. RANDOLPH: Object to the form of the
question.
THE WITNESS: I don't know that either.
BY MR. O'SOYLE:
Q. Okay, what is the policy, the process for
fulfilling records requests in the Town of Gulf Stream?
A. I would refer that question to the custodian
of records, Rita Taylor.
Q. Okay, what is your understanding of the policy
for fulfilling records requests in the Town of Gulf
Stream?
A. I provide that information to Rita Taylor, the
Town Clerk.
Q.
You
provide
it to her?
A.
If
there's
something that were sent to me I
would, yes.
Q. Okay, but the process, the policy, how is it
done? You know, as an example a bill comes in my
office, it goes to this person, they fill it out, they
staple a voucher on it, it goes to accounting and they
always say to me if you want to know what happens you
just staple yourself to that bill and follow it and it
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WILLIAM H. THRASHER, CGFO Vol. III
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1 will tell you exactly what happens. What happens here?
2 A. I believe public records requests are directed
3 to the Town Clerk, the custodian of the records.
4 Q. Okay, and I think that's clear, but my
5 question is what happens next?
6 A. You'd have to ask the custodian of the
7 records. I don't know.
8 Q. Okay, would it be possible that the custodian
9 of .records would get a request for a record to say give
10 me Bill Thrasher's personnel file and her come to you
11 and say I don't want to give this up, it's in violation
12 of the law but I don't want to give it up? Is it
13 possible?
14
A.
No.
15
Q.
Okay,
so if someone were
to come and ask for
16
your personnel
file she would come
presumably to you?
17
A.
No.
18
Q.
No?
19
A.
No.
20
Q.
Okay,
if someone came
and said give me all of
21
Bill Thrasher's
communications
in the Marty O'Boyle file
22
would she
come
to you and say I
don't want to give them
23
up? I know it's
unlawful, but
let's not give them up?
24
A.
No.
25
Q.
Okay,
would you say,
sure, here they are?
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1 A. I would not touch them. I just don't mess in
2 her records.
3 Q. But they're your records.
4 A. They're in the Town file.
5 I don't go into those two rooms. I never have
6 since working here.
7 Q. But --
8 A. I don't take them out, I don't put them back.
9 Q. But if they're electronic they're on your
10 machine?
11 A. Oh, yeah.
12 Q. Right?
13 A. Yeah.
14 Q. Okay, so let's talk about electronic records
15 on your machine. When she walks in she says I want to
16 get these records, I don't have them at all, I assume
17 you have them electronically on your machine. However,
18 I don't think we ought to give them up. Would that be
19 possible?
20 A. No.
21 MR. RANDOLPH: Object to the form of the
22 question.
23 BY MR. O'BOYLE:
24 Q. No?
25 A. No.
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1
Q.
Okay, if she came in and said I've had a
2
request
for these records, I believe they're on your
3
machine,
I need to fulfill this response what would
4
happen?
5
A.
I would provide them to her.
6
Q.
And how would you provide them to her?
7
A.
Print them out, give them to her.
8
Q.
Now, would you look at the request or would
9
you take
her summary?
10
A.
I would look at the request.
11
Q.
You would look at the request.
12
Okay, let's look if we can and I'm going to --
13
Well, you can look at it. It's Number Three, I think.
14
No. You can look at it. I don't need to look
15
at it.
16
A.
Three?
17
MR. RANDOLPH: Are you talking about 332?
18
MR. O'BOYLE: Yes.
19
MR. RANDOLPH: Go back to where you were.
20
MS. HANNA: Go to the end. It says exhibits.
21 1 BY MR. O'BOYLE:
22 Q. I'm sorry. You've read through that?
23 A. Yes.
24 Q. Okay, did Rita bring this in to you?
25 A. I don't remember. I don't know.
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WILLIAM H. THRASHER, CGFO Vol. III
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Q. Okay, how would this have gotten fulfilled?
Is there anyone other than you and Rita?
This asks for William Thrasher's documents.
Rita is the custodian. How else would it have gotten
fulfilled?
A. Through the custodian of the records.
Q. But where would she get the documents?
A. You'd have to ask her. I don't know.
Q. But if they're on your machine where would she
get them?
A. She would not be able to as fax as I know.
She does have access to my files, but --
Q. Okay; that's fair enough.
Do you see the language at the bottom that's
underlined about the middle - or I should say about four
or five inches up from the bottom that starts it is
requested? Can you read that paragraph into the record,
please.
MR. RANDOLPH: She can't take down a head nod,
Bill, so you have to answer verbally.
Do you see that?
THE WITNESS: Yes.
Actually, the other reporter did but, yes.
MR. RANDOLPH; Well, you need to answer
audibly.
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WILLIAM H. THRASHER, CGFO Vol. III
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THE WITNESS: Okay. I'll do my best.
BY MR. O'BOYLE:
Q. Go ahead.
A. "It is requested that this records request be
fulfilled in electronic form. If not available in
electronic form it is requested that this records
request be fulfilled on eleven -by -seventeen paper.
Note, in all cases unless impossible the copy should be
two-sided and should be billed in accordance with
Section 119.07 (4) (a) (2). All electronic copies are
requested to be sent by E-mail delivery."
Q. Okay, when we made this request what we
received was an E-mail, and I know you'll take exception
to it, but it had been doctored. The bottom half of the
E-mail had been covered up and not exposed, hidden, if
you will.
MR. RANDOLPH: Object to the form.
BY MR. O'BOYLE:
Q. And it was a hard copy. As a matter of fact,
Mr. Randolph was kind enough to send me a full copy but
nonetheless a hard copy.
This requests an electronic copy. Where did
the breakdown in communication come?
A. I don't know.
Q. Well, the Clerk or the custodian came in to
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WILLIAM H. THRASHER, CGFO Vol. III
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you, it's your machine, the documents are on your
machine. They're electronically on your machine. Did
she not ask you for them?
A. I think she was answering this request 332
based on her understanding of the request, and what that
understanding was you'll have to ask her.
Q. All right, you submitted at the last
deposition multiple documents in response to this
request. Do you recall that, Mr. Thrasher?
A. Yes.
MR. RANDOLPH: Object to the form of the
question.
Excuse me, Marty.
In response to what request? In response to
the subpoena duces tecum?
MR. O'BOYLE: In response to the subpoena
duces tecum which I believe echoed request number
332.
MR. RANDOLPH: Object to the form.
THE WITNESS: I provided records in regards to
the duces tecum.
22 BY MR. O'BOYLE:
23 Q. Okay, and the last time that we had a
24 deposition here was - you provided those documents was?
25 MR. RANDOLPH: 6/19/13.
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WILLIAM H. THRASHER, CGFO Vol. III
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BY MR. O'BOYLE:
Q. 6/19/13.
This request was made 4/15/13. How in the
world did it take you two months and four days?
A. I was responding to the duces tecum.
Q. So you didn't think that any of the duces
tecum documents were responsive to request number 332?
Is that your testimony?
A. I don't know. I don't know.
Q. You don't know if that's your testimony?
A. Yeah, I don't know. I don't know.
Q. Did you ever look at the documents?
A. Yes. On the duces tecum response.
Q. Let's look at them now.
A. Okay.
Q.
One
second.
A.
May
I ask for
a restroom break?
Q.
Pardon?
A.
May
I ask for
a restroom break?
Q.
Yes.
Of course.
MR.
O'BOYLE:
Just remember, you're not
allowed to speak to
your attorney.
THE
WITNESS:
Okay.
25 1 (Whereupon, there was a brief recess observed
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1 by all parties present, after which the deposition
2 resumed).
3
4 BY MR. O'BOYLE:
5 Q. Mr. Thrasher, you're back feeling good, are
6 you?
7 A. Yes.
8 Q. Good.
9 By the way, you're not under any type of
10 medication that would prevent you from answering
11 questions, remembering, not being able to comment on
12 questions and so forth, are you?
-13_.- A. No.
14 Q. No?
15 A. No.
16 Q. Okay, Mr. Thrasher, what we're going to give
17 you is the deposition exhibits that were tendered by you
18 at your June 19th deposition and we're going to ask
19 you -- Or you've told us that the exhibits were produced
20 pursuant to our subpoena duces tecum; is that correct?
21 A. May I see the copy?
22 Q. Yes. You're going to be able to see them.
23 A. No. The duces tecum as well.
24 Q. Pardon?
25 A. The notice, the subpoena.
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O'BOYLE vs. TOWN OF GULF STREAM 228
1 Q. Absolutely. Just to show you what kind of
2 1 sport I am.
3 A. I'd also like to see 332 again, please.
4 Q. Sure.
5 Well, here's a copy.
6 MS. HANNA: Can we take a five minute break?
7 MR. O'BOYLE: Let's take less than that.
8
9 (Whereupon, there was a brief recess observed
10 by all parties present, after which the deposition
11 resumed).
12
13 BY MR. O'BOYLE:
14
Q.
Mr. Thrasher, you wanted to see, if
I recall
15
correctly,
the duces tecum request or was it
the records
16
request?
17
A.
The duces tecum. You showed me the
public
18
records request.
19
Q.
Okay, here you go. Here is a duces
tecum
20 request but it has not been marked and if you'd like we
21 can have it marked again, but I can assure you it's the
22 same document.
23 MR. RANDOLPH: As far as I'm concerned you
24 don't have to have it marked.
25 It's up to you.
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229
1 I mean, I trust the fact that this is the
2 subpoena duces tecum that was given to him.
3 MR. O'BOYLE: Actually, I have good news.
4 BY MR. O'BOYLE:
5 Q. There is Exhibit Two.
6 The documents that are to be produced pursuant
7 to this document which is Plaintiff's Exhibit Three, I
8 think it's the Marty Minor Plaintiff's Exhibit Three
9 only because I have another document from you which is
10 Plaintiff's Exhibit Three, so that's the request and now
11 you have the duces tecum.
12 Okay, the documents in connection with the
13 duces tecum, do you see those as the documents or as
14 documents that are required pursuant to the records
15 request designated as records request 332 and marked as
16 Exhibit Three?
17 A. I would leave that to the custodian of public
18 records.
19 Q. But they're your documents.
20 A. But it's her responsibility. You'll have to
21 ask her.
22 Q. Okay, and I will.
23 A. Okay.
24 Q. In the meantime, here is a document titled
25 Plaintiff's Exhibit Three, Thrasher dated 6/17/13. Do
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 230
you see this document as being in response to the
records request 332?
A. I would leave that up to the custodian of the
public records.
Q. I understand.
My question is do you see it?
A. I don't know.
Q. You don't know if it's a response.
Okay, let's look at 332 again and let's read
what the request is.
A. Do you want me to read it outloud again?
Q. Sure.
A. Or read it outloud.
"Please provide a copy of any reports or
writings authored by Martin Minor or William Thrasher in
regard to application number one on the agenda of the
Town Commission meeting dated April 12th, 2013 for the
premises known as 3211 North Ocean Boulevard, Gulf
Stream, Florida."
Q. Now, does that document which is Plaintiff's -
which is Thrasher Three, does that have your writing
anywhere on it?
A. Yes.
Q. It does?
A. Yes.
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1 Q. Okay, now can we look back at the request and
2 see if you can find the word writing.
3 A. No.
4 Q. No?
5 A. No.
6 Q. Okay.
7 MR. RANDOLPH: How about writings?
8 THE WITNESS: Yes.
9 BY MR. O'BOYLE:
10 Q. Okay, those S's will get you each and
11 everytime.
12 Okay, so what makes you say that Thrasher
13 Three is not in fulfillment of Plaintiff's Three which
14 again I think is a Minor document, but what makes you
15 says it's not?
16 MR. RANDOLPH: He didn't say that. He said he
17 would rely on the public records custodian.
18 MR. O'BOYLE: I understand that, but then I
19 asked him what does he say. I mean, he can rely --
20 Every question I ask him he can say I rely on my
21 uncle to answer it, but that's not why we're here.
22 We're here for him to answer.
23 MR. RANDOLPH: Well, I don't think you're here
24 for him to answer questions that he indicates he
25 relied upon the records custodian for. I don't
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1 think you can take him through this deposition one
2 by one and ask him whether he thinks it's
3 responsive when he relied upon the public records
4 custodian for that.
5 MR. O'BOYLE: Well, with all due respect,
6 Mr. Randolph, that's nonsense. He's a grown man,
7 he knows how to read, he has an MBA and he knows
8 what the word writing means. He can tell whether
9 or not that is responsive.
10 If the records custodian said it's not and it
11 is he should fulfill it. If the records custodian
12 says it is then he should fulfill it, but he can't
13 sit here and say I'm going to put my head in the
14 sand and I'm not going to answer the question.
15 BY MR. O'BOYLE:
16 Q. My question to you, Mr. Thrasher, is is this
17 document, Thrasher Three, is it responsive to request
18 332?
19 MR. RANDOLPH: And I'm going to object on the
20 basis that he's already answered it, number one,
21 and, number two, you're asking -- You're invading
22 the province of the Court. It will be the Court's
23 determination as to whether or not that's
24 responsive or not.
25 MR. O'BOYLE: I'm not sure I understood, but I
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WILLIAM H. THRASHER, CGFO Vol. III
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July 09, 2013
233
MR. RANDOLPH: It's on the record.
MR. O'BOYLE: -- it's in the Court's province
as to whether he knows the answer, and he's playing
hide the ball.
MR. RANDOLPH: Object to the -- If that's a
question or statement I object to it.
BY MR. O'BOYLE:
Q. Okay, so, Mr. Thrasher, is it your answer then
that that document, you don't have a clue whether it's
responsive or not?
A. I've answered.
Q. Pardon?
A. I've answered that I would refer that question
to the custodian of records.
Q. Okay, now I'm going to ask you again: Do you
have a clue? Is there a chance that that's responsive?
A. I'd refer that to the custodian of the
records.
Q. Is there a chance it's not responsive?
A. I don't know.
Q. Okay, what happens if the custodian of records
passes away?
A. I'm not sure what would happen.
Q. You'd have to answer the questions, wouldn't
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 234
you?
MR. RANDOLPH: Object to the form.
BY MR. O'BOYLE:
Q. You'd have to fulfill them, wouldn't you?
You're the boss, aren't you?
A. No.
Q. Who's the boss?
A. The Town Commission.
Q. The Town Commission gets involved in records
requests?
MR. RANDOLPH: Well, that wasn't your
question.
MR. O'BOYLE: No. I understand. I'm asking
him.
THE WITNESS: Only when asked.
BY MR. O'BOYLE:
Q. Okay, and give me an example of when they
might be asked.
A. If there is a public records request involving
their information.
Q. Okay, but this isn't a request involving their
information?
A. Pardon?
Q. This isn't a request involving their
information, right?
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235
1
A.
No.
2
Q.
Okay, let's go on to the next one which is, I
3
think I'm
reading it right, 3A, Thrasher and it's an
4
E-mail from
Benjamin Schreier to Bill Thrasher several
5
E-mails dated Tuesday, May 28th, 2013 at 2:19. Would
6
you look
at this document and tell me whether you think
7
it's in response
to 332.
8
A.
I'd refer that question to the custodian of
9
records.
10
Q.
Okay, tell me whether you think it's in
11
response
to 332.
12
A.
I would respond -- I would refer that to the
13
custodian
of records. It's not my job.
14
Q.
But tell me whether you think it's in
15
response,
not whether it's the custodian of records'
16
response.
17
A.
I don't know.
18
Q.
You don't know.
19
Okay, what would make you -- You seem to, and
20
I don't mean this disrespectfully, but you seem to know
21
nothing.
You're the Town Manager, the records - public
22
records are a constitutional right and you seem to have
23
your head
in the sand.
24
MR. RANDOLPH: Object to the form of the
25
question.
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1 1 BY MR. O'BOYLE:
July 09, 2013
236
2 Q. You seem to not know anything.
3 Now, my personal opinion is you know better
4 and you're just being evasive; am I right?
5 MR. RANDOLPH: Object to the form of the
6 question.
7 You can answer that question.
8 He asked if he's right that you're being
9 evasive.
10 THE WITNESS: No, you're not right.
11 BY MR. O'BOYLE:
12 Q. Okay, convince me I'm wrong.
13 MR. RANDOLPH: Object to the form of the
14 question. That's not a question.
15 BY MR. O'BOYLE:
16 Q. I'm going to show you now which is Plaintiff's
17 Exhibit Five and I think this is a Minor document, but
18 I'm not sure. What can you tell me about that document?
19 MR. RANDOLPH: Object to the form of the
20 question.
21 You can answer.
22 THE WITNESS: It's an E-mail from Marty Minor
23 to Bill Thrasher dated March 27th, 2013 and it
24 says, "Yes, I will be there with regards to the
25 terracotta roof color for 3211 North Ocean. As we
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1 discussed, the color is not consistent with code
2 and that's why there is an application for a
3 variance. As Benjamin Schreier has shown" --
4 MR. RANDOLPH: Wait a minute, if I might.
5 Do you want him to read that --
6 MR. O'BOYLE: No.
7 MR. RANDOLPH: -- or do you want him to tell
8 you what he knows about that document?
9 BY MR. O'BOYLE:
10 Q. That document there, is that document that you
11 have in your hand responsive to 332?
12 A. I would refer that to the custodian of the
13 records: -
14 Q. But I'm asking you.
15 A. I would refer that question to the custodian
16 of the records.
17 Q. You cannot answer it? Is that what you're
18 telling me, Mr. Thrasher?
19 A. I would refer it to the custodian of the
20 records.
21 Q. You didn't answer my question.
22 My question is you cannot answer it? Is that
23 what you're telling me?
24 A. I think I've answered your question.
25 Q. You have not answered my question.
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1 A. You have to speak with the custodian of the
2 records.
3 Q. I want to know --
4 MR. O'BOYLE: Can you read back what I want to
5 know.
F.7
7 (Whereupon, the requested portion of the
8 record was read back, after which the deposition
9 resumed).
10
11
THE WITNESS:
I don't know if it's responsive.
12
You
have to speak to
the custodian of the records.
13
BY MR. O'BOYLE:
14
Q.
And are you as
sure about that -- How sure are
15
you about
that answer?
16
A.
I don't know.
That's my answer.
17
Q.
But you don't
know how sure you are?
18
A.
No.
19
Q.
Okay, and you
know absolutely nothing about
20 1 it, correct?
21 MR. RANDOLPH: Object to the form of the
22 question.
23 THE WITNESS: My answer?
24 BY MR. O'BOYLE:
25 Q. You know nothing about whether or not that
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1 document is in response - is responsive to that
2 document?
3 A. I would refer that to the custodian of the
4 records.
5 Q. Right, but you. You.
6 A. I would refer that to the custodian of the
7 records.
8 Q. But you know you don't know; is that correct?
9 A. The same answer. I would refer it to the
10 custodian of the records.
11 Q. That's not the question I asked you.
12 MR. O'BOYLE: Mr. Randolph, you heard the
13 question I asked him. Would you kindly instruct
14 your client to answer the question. He's avoiding,
15 he's evasive, he's making me go through dentistry
16 and we're going to make this deposition not last
17 seven hour's but it will be seventy hours if he
18 keeps it up.
19 MR. RANDOLPH: Well, I don't believe that he
20 is being evasive. I believe that he's in good
21 faith relying upon the decision of the records
22 custodian in determining whether or not this was
23 responsive to the records and I don't believe that
24 he has engaged in that decision making process and
25 that's why he's referencing this, and this isn't a
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1 speech, Mr. O'Boyle. I just -- At the beginning of
2 the deposition I indicated that I'd probably have
3 to leave about ten to 3:00 to get to Federal Court,
4 so I'd urge you to -- And I can't tell you how to
5 conduct your deposition, so don't think I'm doing
6 that, but I just wanted you to get in as much as
7 you can today in hopes that we would not have to
8 come back for -- We're in the ninth hour -- In
9 hopes that we wouldn't have to come back to
10 continue this deposition.
11 MR. O'BOYLE: And there's nothing that I would
12 like better because to schlep up here with all
13 these bags for an hour of dentistry and no answers
14 is not at all what I had in mind.
15 I had in mind getting answers and hopefully
16 finishing the deposition.
17 BY MR. O'BOYLE:
18 Q. Mr. Thrasher, were you truthful with your
19 answer a moment ago?
20 A. I believe so.
21 Q. If someone asked you the same question before
22 and you answered differently would that be not truthful?
23 A. I --
24 MR. RANDOLPH: If you're trying to use his
25 deposition, the same deposition that he's in to
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1 attack his credibility please let him know the line
2 and page that you're talking about.
3 BY MR. O'BOYLE:
4 Q. Okay, can you answer my question, please.
5 A. What was your question?
6 MR. O'BOYLE: Can you read it back.
7 MR. RANDOLPH: He asked if you were truthful
8 with your answer that you didn't know.
9 THE WITNESS: Yes.
10 BY MR. O'BOYLE:
11 Q. And you --
12 A. I believe I was.
13 Q. If you were asked before you were equally as
14 truthful, correct?
15 A. I would hope so, yes.
16 Q. Well, it's either yes or no.
17 A. Yes.
18 Q. Yes. Good.
19 Okay, let's go on to Thrasher 3B. Kindly take
20 a look at it and ask -- And kindly tell me if you
21 believe that that document is in response to request 332
22 which I believe is Exhibit Three.
23 MR. RANDOLPH: Objection. This line of
24 questioning is I believe inappropriate under the
25 circumstances because of the fact that he has given
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 242
1 you his answers to each one of these and you must
2 reasonably believe that his answers are going to be
3 consistent with each document that you give him and
4 we're going to be here for hours if you continue
5 with this line of questioning.
6 MR. O'BOYLE: Well, unfortunately,
7 Mr. Randolph, what you just said was just not true.
8 His answers have been inconsistent, his conduct has
9 been duplicitous and his credibility is at great
10 stake and I intend to go through it.
11 Now, that's where we are.
12 I appreciate you're defending your client, but
13 what you said isn't true, so --
14 MR. RANDOLPH: I believe it is.
15 We're wasting --
16 MR. O'BOYLE: You can believe it's true all
17 you want because you see this here?
18 MR. RANDOLPH: Yes.
19 MR. O'BOYLE: This is a certified transcript.
20 MR. RANDOLPH: Yes, but you've got the
21 obligation when you asked him --
22 MR. O'BOYLE: When you have read that
23 transcript you will see what I'm telling you.
24 MR. RANDOLPH: Yes, but you have the
25 obligation when you're trying to attack somebody's
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 243
credibility to show him what you're relying upon in
that regard and you haven't done that and I believe
you've got that responsibility if you're going to
attack the credibility of a witness.
MR. O'BOYLE: Well, thank you for sharing
that.
MR. RANDOLPH: But you're not going to do
that.
MR. O'BOYLE: Thank you for sharing that with
me.
MR. RANDOLPH: Well, you're welcome.
MR. O'BOYLE: As always I appreciate your
advice.
Just off the record a second.
(Whereupon, there was an off the record
discussion had, after which the deposition resumed).
BY MR. O'BOYLE:
Q. Okay, Mr. Thrasher, the last document that I
gave you which is document -- Can you read it? I can't
see it.
I'm sorry.
A. 3B.
Q. 3D as in dog?
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WILLIAM H. THRASHER, CGFO Vol III
O'BOYLE vs. TOWN OF GULF STREAM
A. B as in boy.
July 09, 2013
244
Q. Boy.
Okay, is that document in your opinion,
assuming that the custodian of records passed away this
morning, is that document in your opinion responsive to
332?
A. I would refer to the living custodian of the
records.
Q. But there would not be none.
MR. RANDOLPH: Did you say there would not be
none?
MR. O'BOYLE: Well, if the custodian passed
away.
MR. RANDOLPH: I was just checking on your
grammar what you said there.
I don't know.
MR. O'BOYLE: I don't know either.
BY MR. O'BOYLE:
Q. So what you're saying is you're just not going
to answer; is that right?
A. I said I would refer that question to the
custodian of the records.
Q. But she'd be in a casket.
A. It's just a hypothetical situation that you're
presenting to me.
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
245
Q. Yes.
A. She's alive.
Q. I know.
A. I have no response to that question.
Q. Okay, so without her you don't know?
A. I said I would refer the question to the
custodian of the records as it relates to public records
number 332.
Q. Right, and as -- If she were not here, if she
were on vacation, if she did not give you the response
you just don't know the answer, do you?
A. It's not something that I'm responsible for.
Q. I understand.
Now can you answer my question?
A. I have no answer. I don't know what to say.
MR. RANDOLPH: Other than what you said that
you're not responsible for it.
THE WITNESS: Right.
BY MR. O'BOYLE:
Q. So you're not responsible for it?
MR. O'BOYLE: Can you read my question back,
madam.
24
(Whereupon,
there
was
an off the
record
25
discussion had, after
which
the
deposition
resumed).
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 246
THE WITNESS: There would be a replacement for
the custodian of the records and it would be her
responsibility.
BY MR. O'BOYLE:
Q. Right, but until there was a replacement you
don't know the answer, do you?
A. No.
Q. If there was no custodian of records you do
not know the answer, do you?
A. I don't know.
Q. You don't know?
A. As it relates to 332, public records request
332.
Q. And you don't know the answer as to whether or
not this is responsive?
A. I would refer that to somebody who has the
responsibility of being the custodian of the records. I
am not.
Q. Okay, and I know you're not, but do you think
it's responsive? Yes or no?
I don't care what the custodian thinks. I
care what you think.
MR. RANDOLPH: He's asked and answered it to
the best of his ability.
MR. O'BOYLE: I don't think he has.
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 247
1
THE WITNESS:
I've answered it to the best of
2
my ability.
3
BY MR. O'BOYLE:
4
Q. I don't think
you have.
5
MR. O'BOYLE:
And by the way, if you'd like to
6
testify, we have a
few minutes left, you're more
7
than welcome to because right now it's puppetting.
8
MR. RANDOLPH:
It's what?
9
MR. O'BOYLE:
Puppetting.
10
MR. RANDOLPH:
No, it's not.
11
MR. O'BOYLE:
You're making a statement and
12
he's echoing it.
13
MR. RANDOLPH:
That's not true.
15 Q. Do you know whether or not this is responsive,
16 3B I think it is to 332? Do you know?
17 MR. RANDOLPH: Mr. O'Boyle, I think you're
18 harassing the witness.
19 It's ten till. I've got to get to Federal
20 Court and I would like to conclude this deposition
21 at this time.
22 MR. O'BOYLE: Well, you said you would wait
23 till 3:00.
24 MR. RANDOLPH: I said possibly, but that's
25 really pushing me. I've got to be at the Veteran's
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
248
1 Administration at 4:00 and I don't know exactly
2 where in that building it is.
3 MR. O'BOYLE: Okay. Well, let me ask one more
4 question.
5 BY MR. O'BOYLE:
6 Q. The word responsive, have you ever heard it?
7 A. Yes.
8 Q. Yes?
9 A. Yes.
10 Q. What does it mean?
11 A. To respond.
12 Q. Okay, if I said give me these documents as
13 responsive documents what would that mean to you,
14 responsive?
15 A. I don't know what that would mean.
16 Q. You don't know?
17 A. No.
18 Q. Okay, in what context would you know what
19 responsive means?
20 A. I would associate it with public records.
21 Q. Okay, and keep going.
22 A. That's my answer.
23 Q. So you would associate responsive with public
24 records and when someone says, oh, responsive with
25 public records, I understand, and when they say but what
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
249
does it mean you would say I don't know, I have to ask
the custodian? I don't know. I think there was a third
one. What would be your response?
MR. RANDOLPH: Object to the form. He's
answered the question.
We've got to go.
I believe you're badgering the witness and I'd
like to terminate the deposition at this time for
purposes of my going to Federal Court.
MR. O'BOYLE: I understand. Okay.
MR. RANDOLPH: I'll leave -- As far as whether
we're going to continue into a tenth hour with
Mr. Thrasher on this particular case I'll reserve
my judgment on it with regard to whether we want to
continue the deposition.
MR. O'BOYLE: Well, if you can let us know
tomorrow we would appreciate it because we are as
you know taking Miss Taylor's deposition on
Thursday.
MR. RANDOLPH: Right.
MR. O'BOYLE: And now I think we intend to
file a summary judgment, do we not? And we'd like
to finish Mr. Thrasher.
MR. RANDOLPH: I wish we could finish today, I
really do, and you did, too.
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 250
1
MR.
O'BOYLE: Why don't you
come back. You
2
can come
over to my house and look
at the artwork.
3
MR.
RANDOLPH: I've really
got to be in
4
Federal
Court. I've really got
to get going.
5
THE
COURT REPORTER: Is the
transcript
6
ordered?
7
8
9
10
14
15
16
17
18
19
20
21
22
23
24
25
copy?
MR. O'BOYLE: I think so.
MS. HANNA: Yes.
THE COURT REPORTER
Do you want to order a
MR. RANDOLPH: Please. Please.
(Whereupon, signature and formalities not
having been waived, the deposition concluded at
2:54 o'clock p.m.)
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
CERTIFICATE OF OATH
STATE OF FLORIDA
COUNTY OF BROWARD
July 09, 2013
251
I, VALERIE LEHTO, the undersigned authority,
certify that WILLIAM H. THRASHER, CGFO personally appeared
before me and was duly sworn.
Dated this 9th day of July, 2013,
I W 0 4r 'NOW,
VALERIE LEHTO, RPR
NOTARY PUBLIC - STATE OF FLORIDA
My Commission Expires: 8/22/2014
My Commission No.: EE 009474
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 252
1 I CERTIFICATE
2
3 STATE OF FLORIDA
4 COUNTY OF BROWARD
5 I, VALERIE LEHTO, Registered Professional
6 Reporter, do hereby certify that I was authorized
7 to and did stenographically report the foregoing
8 deposition as hereinabove shown, and the testimony
9 of said witness was reduced to computer transcription
10 under my personal supervision and direction and that
11 the record is a true record of the testimony given
12 by the witness.
13
I further
certify that I am not a relative,
14
employee,
attorney
or counsel of any of
the parties,
15
nor am I
a relative
or employee of any
of the parties'
16
attorney
or counsel
connected with the
action, nor
17 am I financially interested in the action.
1B Dated this 9th day of July, 2013.
19
20
21
oG1
VALERIE LEHTO
22
Registered Professional Reporter
COMMISSION NO. EE 009474
23
MY COMMISSION EXPIRES 8/22/2014
rza
25
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM 253
1 DEPOSITION ERRATA SHEET
2
3 1 ASSIGNMENT NO. 383260
4 O'BOYLE vs. TOWN OF GULF STREAM
5
6 DECLARATION UNDER PENALTY OF PERJURY
7 I declare under penalty of perjury
8 that I have read the entire transcript of
9 my Deposition taken in the captioned matter
10 or the same is true and accurate, save and
11 except for changes and/or corrections, if
12 any, as indicated by me on the DEPOSITION
13 ERRATA SHEET hereof, with the understanding
14 that I offer these changes as if still under
15 oath.
16 Signed on the day of
17 2013.
RU
19
20
21
22
23
24
25
WITNESS NAME
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
DEPOSITION ERRATA SHEET
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WILLIAM H. THRASHER, CGFO
ESQT j1RE
July 09, 2013
254
DATE:
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
DEPOSITION ERRATA SHEET
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WILLIAM H. THRASHER, CGFO
CESQJIRE
July 09, 2013
255
DATE:
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
Index: 119 -boy
229:15
238:19
artwork
bad 213:10
1
230'2'9
access
250:2
badgering
_____--- _.__..
232:18
223:12
asks 223:3
249:7
235:7,
119 205:4,
237:11
accordance
associate
bags
20 210:10
241:21
224:9
248:20,23
240:13
212:1
213:4,23
244:6
accounting
assume
ball 233:5
245:8
219:23
217:1
119.07
246:12,13
221:16
based
224:10
247:16
additional
225:5
12th
3:00 240:3
206:6
assuming
basic
230:17
247;23
Administrat
244:4
205:12,15
19 211:25
3A 235:3
ion 248:1
assure
basis
212:16
advice
228:21
232:20
3B 241:19
243:13
attack
19th
243:24
241:1
begin
227:18
247:16
advised
203:8
242:25
31) 243:25
204:1,7
243:4
beginning
2
affirmed
240:1
attorney
-
204:21
226:22
believed
4
2 224:10
afternoon
204:12
audibly
2013
4 224:10
204:25
223:25
Benjamin
230:17
agenda
235:4
235:5
4/15/13
230:16
authored
237.3
226:3
230:15
236:23
ahead
bill
27th
4:00 248:1
224'3
avoiding
219:21,25
239:14
236:23
alive
220:10,21
28th 235:5
6
245:2
aware
223:20
217:8
235:4
2:19 235:5
allowed
236:23
6/17/13
226:22
—_---
2:54
229:25
B
billed
250:15
answering
-
224:9
6/19/13
225:4
225:25
227:10
back
billing
3
226:2
218:8,9,
207:10
-"
answers
11,19
boss
240:13,15
221:8
3211
A
242:1,2,8
222:19
234:5,7
230:18
236:25
application
227:5
bottom
ability
230:16
231:1
223:14,16
332 215:5
246:24
237:2
238:4,
224:14
222:17
247:2
240:8,9
Boulevard
225:4,18
absolutely
April
241:6
230:18
226:7
230:17
245:21
228:3
228:1
250:1
boy 244:1,
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WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
Index: break -custodian
2
CGFO 203:1
clue
continue
240:3
i
break
204:20
233:10,17
204:7,15
247:20
226:17,19
chance
code 237:1
211:23
249:9
228:6
233:17,20
240:10
250:4,5,9
color
242:4
Chapter
236:25
249:12,15
Court'sbreakdown
224:23
205:4,20,
237:1
232.22
25 206:2
Continued
233:3
breaks
commences
203:1
203:13
210:10
207:10,11
cover
211:25
continuing
203:24
bring
212:1,16
comment
204:9
222:24
213:4,23
227:11
covered
convince
224:15
brought
charge
Commission
236:12
219:2
205:21
230:17
credibility
building
206:13
234:8,9
copies
241:1
205:21
242:9
217:22,24
207:1,22
communicati
206:3,7
243:1,4
248:2
214:21
on 224:23
212:19
curious
charged
communicati
224:10
214:11
C
203:17
ons 215:20
copy 216:1
206:25
220:21custodian
224:8,19,
207:24
207:15,
calculated
208:17,24
Complaint
20,21,22
19,21
204:4
211:15,
227:21
210:1,4,
call
charges
17,21,23
228:5
12,15,17
212:19,21
230:14
213:9,11
213:1
concerned
250:10
211:3
called
214:4,5
228:23
212:13
correct
214:22
206:25
charging
conclude
205:9
217:2
214:5
212:20
204:12
207:19
219:10
carechecking
247:20
209:7
220:3,6,8
246:21,22
244:14
concluded
210:23
223:4,6
250:14
215:1,
224:25
case
circumstanc
217:4
229:17
203:14
as 208:5
conduct
218:9,11
230:3
204:8
241:25
240:5
238:20
231:17,25
249:13
clear
242:8
239:8
232:4,10,
cases
220:4
connection
241:14
11
224:8
Clark
229:12
correctly
233:15,
casket
207:16
consistent
209:10
18,22
244:23
219:16
237:1
228:15
235:8,13,
15
cents
220:3
242:3
coat
237:12,
206:4,5,6
224:25
constitutio
206:10,11
15,19
212:25
client
nal 235:22
Court
238:1,12
certified
239:14
context
203:2
239:3,6,
242:19
242:12
248:18
232:22
10,22
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WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM Index: dated..Excuse
244:4,7,
238:8
228:22
17,19
212:22
12,22
239:16
229:7,9,
229:2,11,
eleven -by -
245:7
240:2,5,
24 230:1,
13
fourteen
246:2,8,
10,16,25
20 231:14
due 232:5
212:22
17,21
243:17
232:17
249:2
245:25
233:10
duly
eleven -by -
247:20
235:6
204:21
seventeen
249:8,15,
236:17,18
duplicate
224:7
D
—
18 250:14
237:8,10
206:10
encourage
designated
239`1'2
203:20
dated
241:21
duplication
229:25
229:15
242:3
206:11
end 222:20
230:17
determinati
243:20,21
duplicitous
engaged
235:5
on 207:10,
244:3,5
242:9
239:24
236:23
13 232:23
documents
equally
day 204:13
determined
203:15,18
E
241:13
days 226:4
206:12
223:3,7
------
determining
225:1,8,
equipment
decided
24 226:7,
E-mail
206:9
214:24
239:22
12 229:6
224:11,
decides
differently
12,13,14,
13,15
evasive
236:4,9
207:22
240:22
19
235:4
239:15,20
DIRECT
246:12,13
236:22
decision
everytime
239:21,24
204:23
dog 243:25
E-mails
231:11
defending
directed
dollars
235:5
evidence
242:12
220:2
207:24
echoed
204:4
discoverabl
208:17,24
225:17
delivery
e 204:4
209:2,4,
echoing
EXAMINATION
224:11
11,15,21
a
2-7'12
204:23
dentistry
discussed
210:7
examined
237:1
electronic
215:8
doors
221:9,14
204:21
239:15
discussion
217:25excellent
224:5,6,
240:13
243:17
10,22
213:10
245:25
double
depo
217:25
electronics
exception
204:15
disrespect£
lly 203:19
224:13
ul
double-
deposition
23
235:20
sided
221:17
excessive
203:1,10,
206:5
225:2
206:12,
11,21
distinguish
204:1,10
214:12
duces
elements
13,17,
208:13
225:15,
203:15
212:21
225:8,24
doctored
17,21
eleven
214:5
227:1,17,
224:14
226:5,6,
206:4
excluding
1B 228:10
document
13
eleven -by -
203:12
232:1
206:23
227:20,23
eight
Excuse
226:15,
E" DIRE 800.21 i.DEPO (3376)
EsquireSolutions.com
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
211:9
205:4
230:19
225:13
215:5
follow
exhibit
familiarize
219:25
216:1,2,
d 216:21
form
7,10,13
Federal
205:10
229:5,7,
240:3
208:2
8,10,16,
247:19
211:10
25 236:17
249:9
213:6
241:22
250:4
217:5
exhibits
219:4
fee 206:25
222:20
221:21
212:21
227:17,19
224:5,6,
feeling
17
existing
211:11,16
227:5
225:11,19
fifteen
234:2
expedition
206:4
235:24
204:1,9,
207:11,
236:5,13,
16
212:25
19 238:21
expert
249:4
file
205:7,8
220:10,
formalities
explain
16,21
250:13
204:3
221:4
forward
exposed
249:22
218:9
224:15
files
french
extensive
223'12
217:25
207:1
fill
front
219:22
210:22
F
find 231:2
fulfill
finish
210:11
face
212:4
212:2,8
218:14
249:23,24
222:3
232:11,12
fact
finishing
234:4
224:19
240:16
229:1
fulfilled
fishing
223:1,204:1,9,
241:25
224:5,7
fair
16
213:3,10
fulfilling
223:13
floor
219:9,13
217:14,
faith
16,20,22
fulfillment
239:21
231:13
Florida
familiar
205:4
full
224:20
July 09, 2013
Index: exhibit..hidden
furthest
218:19,21
G
gave 204:2
209:24
243:21
general
205:16,17
213:5,14,
16,20
generally
205:5,6
206:14,16
215:19
get all
203:22
give
209:23
216:1
220:9,11,
12,20,22,
23 221:18
222:7
227:16
234:17
242:3
245:10
248:12
good
204:25
205:2
213:9
227:5,8
229:3
239:20
241:18
grammar
244:15
great
242:9
grown
232:6
guess
208:13
21'7:15
Gulf 214:4
219:9,13
230:18
half
206:3,4,
6,14,16,
18 207:12
212:23,25
224:14
hand
237:11
HANNA
212:23
222:20
228:6
250:8
happen
222:4
233:24
harassing
247:18
hard
224:19,21
head
223:19
232:13
235:23
heard
239:12
248:6
hidden
224:15
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
WILLIAM H THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
Index: hide -Minor
hide 233:5
inappropria
judgment
left 247:6
236:23
hope
tely
249:14,22
LEHTO
marked
203:17
241:15
June
203:2
215:25
hopes
inches
227:18
letting
216:2
240:7,9
223:16
___..
204:15
228:20,
includes21,24
R
hour
limitations
229:15
206:19,24
203:14
208:7,11
Martin
207:11,25
inconsisten
kind
living
208:17
t 242:8
224:20
205:1
244:7
230:15
209:15
information
228:1
240:8,13
lobby
Marty
207:7
kindly
249:12
210:24
215:20
219:15
239:13
hours
234:20,
241:19,20
-- --
220:21
203:12,23
22,25
225:13
knowledge
__ M _._.
229:8
206:14,
insist
205:16,17
236:22
16,18
204:8
213:4,5,
machine
207:12
9,10,14,
221:10,
matter
239:17
instruct
16,19,20
15,17
224:19
242:4
239:13
222:3
MHA 232:7
house
intend
223:9
250:2
204:9
L
225:1,2
meaning
242:10
206:13
hundred
madam
213:14,17
249:21
labor
207:24
245:22
208:17
intentions
203:17
means
made
232:8
209:2,4,
204:14
language
210:25
248:19
11,15
invading
223:14
224:12
meantime
hypothetica
232:21
Large
226:3
1 244:24
investment
203:4
make
229:24
medication
206:12
larger
207:9,12
227:10
T
involved
206:9
209:9
235:19
meeting
234:9
law 220:12
239:16
230:17
idea
involving
lawsuit
207:16
234:19,
211:11,15
makes
men's
identify
21,24
231:12,14
217:18,20
lead 204:4
216:7
making
mess 221:1
issues
leading
24
239:15,middle
illegal
203:21,25
217:25
247:11
203:16
204:8
223:15
impossible
leave
man 232:6
mind
229:17
224:8
J
240:3
Manager
208:11
235:21
240:14,15
inappropria
249:11
to 241:24
job 235:13
March
Minor
ESQUIRE 800.211.DEP0 (3376)
EsquireSolutions. com
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
215:20
229:8
230:15
231:14
236 : 17, 22
minute
228:6
237:4
minutes
203:12
20'7:11,25
208:18,25
209:13,16
247:6
moment
24 0: 19
months
226:4
morning
244:5
moving
218:9
multiple
225:8
news 229:3
ninety
208:24
209:21
210:7
ninth
240:8
nod 223:19
nonetheless
224:21
nonsense
232:6
north
218:10,
15,17,21,
22 230:18
236:25
Notary
203:3
Note 224:8
notice
22'7:25
number
215:5
222:13
225:1'7
226:7
230:16
232:20,21
245:8
0
O'boyle
203:8
204:24
205:1,14
208:6,16
209:3
210:2,6
211:14,
19,22,24
212:5,6,
24 213:8,
24 214:2
215:24
216:9,20
217:9
219:7
220:21
221:23
222:18,21
224:2,18
225:16,22
226:1,21
227:4
228:7.13
229:3,4
231:9,18
232:5,15,
25 233:3,
8 234:3,
13,16
236:1,11,
15 237:6,
9 238:4,
13,24
239:12
240:1,11,
17 241:3,
6,10
242:6,16,
19,22
243:5,9,
12,19
244:12,
17,18
245:19,21
246:4,25
24'7:3,5,
9,11,14,
17,22
248:3,5
249:10,
16,21
250:1,7
object
205:10
208:2
213:6
217:5
219:4
221:21
224:17
225:11,
232:19
233:6,7
234:2
235:24
236:5,13,
19 238:21
249:4
July 09, 2013
Index: minute -playing
objection
208:2
211:10
241:23
obligation
242:21,25
obligations
212:1
observed
226:25
228:9
Ocean
230:18
236:25
office
217:3
218:9
219:22
opinion
203:25
206:17
244:3,5
opportunity
203:24
204:2
order
250:9
ordered
250:6
outloud
230:11,13
outset
203:9,21
P
p.m.
250:15
paper
224:7
paragraph
223:17
Pardon
205:24
208:9
214:14
215:2
218:5
226:18
227:24
233:13
234:23
parties
22'7:1
228:10
passed
244:4,12
passes
233:23
pending
216:15,
18,19
period
206:17
210:19
211:2,12,
18
person
219:22
personal
236:3
personnel
220:10,16
Plaintiff's
216:9,13
229:7,8,
10,25
230:20
231:13
236:16
playing
215:8
ESQUIRE 800.211.DEPO (3376)
q19V I'll, EsquireSolutions. com
WILLIAM H. THRASHER, CGFO Vol. III July 09, 2013
O'BOYLE vs. TOWN OF GULF STREAM Index: point -records
233:4
219:15,17
208:3
209:24
241:6
point
222:5,6
212:4
211:9,16,
242:22
211:14
230:14
213:7
20 212:4
245:21
Provided
216:15,18
213:6,22
reading
points
P
217:6
215:13,
211:10
203:18
219:5,10
16,22
235:3
policy
225:20,24
220:5
216:4,11,
real
214:3,6,9
province
221:22
12,15
206:20
219:8,12,
232:22
225:12
217:5
rear
20
233:3
230:6
219:4
218:14,15
public
231:20
221:21
portion
203:3,14
232:14,16
222:17,
reasonable
238:7
220:2
233:7,14
223:19,24
208:19,
possibly
229:17
234:12
224:17,20
21,25
247:24
230:4
235:8,25
225:11,
209:2,5,
231:17
236:6,7,
19,25
12,18
P remises
14,20
228:23
210:10,
230:18
232:3
237:15,
231:7,16,
14,18
234:19
present
235:21
21,22,24,
23 232:6,
211:2,12,
227:1245:7
25 236:22
19 233:2,
18
228:10
246:12
239:11,
6 234:2,
recall
presenting
248:20,
13,14
11 235:24
215:16
244:25
23,25
240:21
236:5,13,
225:9
241:4,5
19 237:4,
228:14
prevent
puppetting
244:21
7 238:21
227:10
247:7,9
245:4,6,
239:12,19
receive
previously
purposes
14,21
240:24
203:15
204:2
216:6
248:4
241:7,23
received
249:9
249:5
242:7,14,
224:13
Print
questioning
18,20,24
222:7
pursuant
243:7,11
recess
227:20
241:24
244:10,14
226:25
printer
229:6,14
242:5
228:9
206:8
245:16
pushing
questions
246:23
record
process
247:25
203:20,22
247:8,10,
216:6
219:8,20
204:3
13,17,24
220:9
239:24
put 221:8
227:11,12
249:4,11,
223:17
produced
232:13
231:24
20,24
233:2
206:7
---------
233:25
250:3,11
238:8
211:12,18
4
read
243:14,16
227:19
R
222:22
245:24
229:6
question
223:17
records
Professiona
205:11,
Randolph
230:9,11,
203:14
1 203:3
19,22
203:8
13 232:7
207:15,
206:2
205:10
237:5
19,21
provide
207:7
238:4,8
210:1,4,
zlz:e
zoe:z,lz
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
Index:
July 09, 2013
records'..Schreler
13,16,17,
208:23
218:7
requests
233:11,
25 211:4,
209:25
219:1
219:9,13
17,20
11,17
210:4,12,
222:25
220:2
238:11
212:8,13
15 211:3
226:21
224:22
239:1,23
214:23
212:13
remembering
234:10
244:5
217:2
214:22
227:11
required
246:15,20
219:9,11,
216:3
247:15
13 220:2,
219:10
replacement
229:14
248:6,13,
3,7,9
233:14,18
246:1,5
requirement
14,19,23,
221:2,3,
235:8,
reporter
212:17
24
14,16
237:12,
203:3
requires
restroom
222:2
15,19
223:23
211:25
226:17,19
223:6
239:3,6,9
250:5,9
224:4,6
244:7,21
reserve
resumed
225:20
245:6
Reporter/
249:13
227:2
228:15,18
246:16
registered
respect
228:11
229:14,
referencing
203:2
232:5
236:9
15,18
239:25P
re orte
243:17
230:2,4
230:14
respond
245:25
231:17,25
refused
211:2
232:3,10,
204:5
request
235:12
Rita
11
210:11,25
248:11
207:4,8
regard
212'2
208:23
233:15,
213:22
rea responding
ondin
219:2,11,
19,22
230:16
215:5,14
226:5
15 222:24
234:9,19
243:2222:2,8,response223:2,4
220:9
235:9,13,
21,22
249:14
10,11
222:3
roof
237:13,
relates
224:4,7,
225:8,14,
236:25
16,20
245:7
12 225:4,
16 226:13
238:2,12
246:12
5,9,14,17
230:1,8
room
239:4,7,
226:3,7
235:7,11,
217:18,20
relative
10,21,23
214:4
228:15,
15,16
rooms
244:4,8,
16,18,20
239:1
221:5
22 245:7
relied
229:10,15
241:21
246:2,8,
231:25
230:2,10
245:4,10
12,17
232:3
231:1
249:3
S
248:20,
iely
232'17
responsibil
24,25
231:17,
234:19,
ity 229:20
S's 231:10
records
19,20
21'24
246:3,17
sand
241:21
232:14
235:15
relying
246:12
responsible
redaction
239:21
245:12,
235:23
243:1
requested
17,20
schlep
203:16
203:16,19
refer
remember
223:17
responsive
240:12
205:23,25
207:2
224:4,6,
226:7
Schreier
207:4,7
216:5,25
11 238:7
232:3,9,
235:4
217:16
17,24
237:3
ESQUIRE 800.211.DEPO (3376)
EsquireSolutions. com
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
Index: Section -time
Section
232:13
statute
Taylor
testimony
224:10
situation
206:20
207:8,9
226:8,10
send
214:22
215:4
218:1
thin 213:4
224:20
244:24
Statutes
219:11,15
thinks
service
somebody's
205:4
Taylor's
232:2
214:4
242:25
stray
249:18
246:21
session
spatially
204:8
tecum
thirteen
204:11
206:7
Stream
225:15,
206:4
17,21
seventy
speak
214:4
226;5,7,
thought
219:9,14
239:17
226;22
13
204:6,
sharing
238:1,12
230:19
227:20,23
209:13
243:5,9
special
submitted
228:15,
214:19
206:23,25
225:7
17,19
Thrasher
she'd
212:21
subpoena
229:2,11,
203:1,12,
244:23
13
214:4
225:15,16
24
sheet
speci£icall
227:20,25
telling
204:20,25
210:22
y 217:7
229:2
237:18,
205:3
211:1
242:23
215:6,21
speech
p
summary
225:9
show 228:1
240:1
222:9
ten 203:12
236:16
249.22
207:25
227:5,16
243:1
sport
208:18,24
228.2
support
229:25
showed
214:24
209:13,15
230:15,21
228:17
staff
240:3
231:12
206:12,24
sworn
247:19
232:16,17
shown
204:21
211:15
stake
tendered
233:9
237:3
242:10
227:17
235:3,4
sic 211:25
staple
Ttenth
----- --
236:23
212:16
219:23,25
249:12
240:18
table
241:19
Side
start
210:22
term
243:20
218:12
214:7
212:20
249:13,23
tailor
213:4
sign -in
starting
203:20
Thrasher's
210:22
218:8
terminate
220:10,21
211:1
taking
204:10
223:3
starts
249:18
249:8
signature
223:16
Thursday
250:13
talk
terracotta
249:19
State
221:14
236:25
simple
203:4
till
203:14
talking
testified
247:19,23
statement
222:17
204:22
sink
203:9
241:2
time
217:18
217:4
testify
206:12,18
233:7
talks
247:6
210:11,
sit 218:1
247:11
206:20
14,19
ESQUIRE. 800.211.DEPO (3376)
EsquireSolutions.com
WILLIAM H. THRASHER, CGFO Vol. III
O'BOYLE vs. TOWN OF GULF STREAM
July 09, 2013
Index: titled -wrong
211:2,12,
Tuesday
urge 240:4
242:15
18 225:23
235:5
west
247:21
turned
V
218:17
249:8
203:25
William
titled
twenty
vacation
203:1
229:24
206:5
245:10
215:20
today
two-sided
VALERIE
223:3
204:14
224.9
203.2
230:15
240:7
249:24
type 206:8
variance
window
227:9
237:3
218:15,17
told
227:19
--- --
verbal
word 231:2
232:8
tomorrow
II
214:9,16
248:6
249:17
verbally
words
touch
223.20
207`2
upecificall
221:1
versed
y 217:10
work
205:9
Town
uncle
207:25
206:12
Veteran's
206:18
231:21
207:8
247:25
210:12
underlined
working
violation
221:6
214:3
223:15
220:11
219:9,13,
understand
world
16 220:3
209:9
voucher
226:4
221:4
219:23
210:2
worth
230:17
230:5
-
207:25
234:8,9
231:18
W
208:18
235:21
245:13
writing
Town's
248:25
wait 237:4
230:21
206:10
249:10
247:22
231:2
transcript
understandi
waived
232:8
242:19,23
ng 205:12,
250:14
writings
250:5
15 214:25
215:3
walks
230:15
true
219:12
221:15
231:7
242:7,13,
225:5,6
wall
written
16 247:13
214:6,13,
understood
218:14,
trust
209:10
15,16,17,
15
214:25
232:25
18
wrong
215:3
229:1
unlawful
wanted
236:12
220:23
228:14
truthful
240:6
240:18,22
unusual
241:7,14
206:20
wasting
ESQUIRE 800.211.DEP0 (3376)
EsquireSolutions.com