HomeMy Public PortalAboutThrasher Transcript 6/8/2016I
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 9:14-CV-81250-KAM
MARTIN E. O'BOYLE,
Plaintiff,
V.
ROBERT A. SWEETAPPLE and MAYOR
SCOTT MORGAN,
Defendants.
- - - - - - - - - - - - - - - x
DEPOSITION OF WILLIAM THRASHER
TAKEN ON BEHALF OF THE PLAINTIFF
Wednesday, June 8, 2016
Daughters Reporting, Inc.
1515 North Federal Highway
Suite 300
Boca Raton, Florida 33432
1:25 p.m. - 6:03 p.m.
Reported by Felecia Curreri, RPR
Notary Public, State of Florida
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
2
1 APPEARANCES ON BEHALF OF THE PLAINTIFF
2 Martin E. O'Boyle, Pro Se
1280 West Newport Center Drive
3 Deerfield Beach, Florida 33442
Michelle Baez, Esquire
4
5
APPEARANCES ON BEHALF OF THE DEFENDANT SWEETAPPLE
7
Cole, Scott & Kissane
8 1645 Palm Beach Lakes Boulevard
Second Floor
9 West Palm Beach, Florida 33401
BY: JOSHUA GOLDSTEIN, ESQUIRE
10 Tel: 561-681-5523
Email: Joshua.goldstein@csklegal.com
11
12
13
APPEARANCES ON BEHALF OF THE DEFENDANT MORGAN
Johnson, Anselmo, Murdoch, Burke,
14
Piper
& Hochman, P.A.
2455
East Sunrise Boulevard
15
Suite
1000
Fort
Lauderdale, Florida 33304
16
BY:
HUDSON GILL, ESQUIRE
Tel:
954-463-0100
17
Email:
Hgill@jambg.com
18
19
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21
22
23
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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I N D E X
TESTIMONY OF WILLIAM THRASHER
Direct Examination by Mr. O'Boyle
E X H I B I T S
Page
4
No. Description Page
1 (Drawing)
2 (Minutes of Meeting)
(Exhibits Attached)
CERTIFIED QUESTIONS
Page 81 Line 9
S T I P U L A T I O N S
It is hereby stipulated and agreed by and
between counsel present for the respective parties,
and the deponent, that the reading and signing of
the deposition are hereby reserved.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
3
I
1 THE COURT REPORTER: Do you swear or
2 affirm that the testimony you are about to
3 give will be the truth, the whole truth, and
4 nothing but the truth?
5 THE WITNESS: Yes.
6 Thereupon --
7 WILLIAM THRASHER
8 was called as a witness by the Plaintiff and,
9 having been first duly sworn, testified as follows:
10 DIRECT EXAMINATION
11 BY MR. O'BOYLE:
12 Q. Good afternoon, Mr. Thrasher. My name is
13 Martin O'Boyle and I am here along with you this
14 afternoon to take your deposition in a matter
15 pending in federal court styled Martin O'Boyle
16 versus Robert Sweetapple and I believe the Town of
17 Gulf Stream.
18 Are you familiar with that matter?
19 A. Generally.
20 Q. Okay. What does generally mean?
21 A. I know the case number, I know the style
22
and I
believe that
there are
two complaints.
23
Q.
I'm sorry,
I didn't
catch that.
24
A.
I believe
that there
are two complaints to
25 the case. Two, I think.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1
Q.
And what would the two complaints be for?
2
A.
I believe slander, Sweetapple, and
3
retaliation,
Gulf Stream.
4
Q.
I see. Okay.
5
So what you meant, just so I'm clear, is
6
that there
are two counts in the complaint?
7
A.
Okay.
8
Q.
Okay. You've been deposed before?
9
A.
I have.
10
Q.
About how many times?
11
A.
Maybe six.
12
Q.
Six?
13
A.
Maybe, yes. Generally.
14
Q.
Okay. And the six times that you've been
15
-- approximately six times that you have been
16
deposed,
do you remember in connection with what
17
matters?
18
A.
No. No, I can't remember at this time.
19
Q.
Not a one?
20
A.
I do remember one, yes.
21
Q.
And?
22
A.
It was a criminal case, State of Florida,
23
I think,
versus Martin O'Boyle.
24
Q.
Okay. Do you know a Christopher O'Hare?
25
A.
I do.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E
1
Q.
Has he or his counsel ever deposed you?
2
A.
Yes.
3
Q.
Okay. So that's two you remember now?
4
A.
Well, I don't know the case, but I know
5
that his
counsel did depose me.
6
Q•
And what was that about?
7
A.
Frankly, I don't remember.
8
Q.
Could it have been in connection with
9
Officer
Ginsberg?
10
A.
Yes, yes.
11
Q.
Does that refresh your recollection as
12
to --
13
A.
Yes, I still don't know what the case was
14
about,
but, yes, it was -- Officer Ginsberg was
15
part of
the complaint or something about Officer
16
Ginsberg.
17
Q.
And what was the most recent deposition
18
you had?
19
A.
It would be in the State of Florida versus
20
Martin
O'Boyle.
21
Q.
Do you remember being deposed by Robert
22
Gershman?
23
A.
No, I don't remember that. I know that
24
Robert
Gershman represented you in a code
25
enforcement hearing, but I don't know that he
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
7
1 deposed me.
2 Q. Okay. Do you remember -- take that back.
3 Do you recall that I deposed you?
4 A. I'm sorry, I don't.
5
Q.
Okay.
14
remember.
6
A.
Actually, yes,
I do remember.
You deposed
7
me two and a half days
and that was, I
think, on
8
the code
enforcement hearing,
but I'm
not sure of
9
the case,
but, yes, you
did.
Okay. You do remember when I deposed you
10
Q.
If I told you
that that wasn't
on the code
11
enforcement but rather
with a records
suit, would
12 that help your memory?
13
A.
No. I would like to correct that. I do
14
remember.
I think it was about a public records
15
request
lawsuit that you deposed me on. I can't
16
remember
the details but --
17
Q.
Okay. So that's four of the six times.
18
Can you
think of any others?
19
A.
Not at this time.
20
Q.
Okay. You do remember when I deposed you
21
in the past,
correct?
22 A. I remember you deposed me. I don't
23 remember any of the questions. I think it was a
24 rather long deposition covering more than one day.
25 Q. When I deposed you, Mr. Thrasher, do you
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
0
1 recall, I don't remember exactly, I think you told
2 me you were involved in some fashion in a wrongful
3 death suit?
4
A.
I believe I did, yes.
5
Q.
Can you tell me a little bit about that?
6
A.
I was District Director for the Water
7
Control
District and a delivery truck driver
8
drowned
in the canal and I represented the
9
district.
10
Q.
I'm sorry?
11
A.
I represented the district in that case.
12
Q.
As counsel?
13
A.
No, no. You know, I was their face at the
14
trial basically.
I was at the trial.
15
Q.
Okay. And you said -- I don't hear the
16
greatest.
You said it was a delivery truck guy
17
that drowned?
18
A.
I believe it was, yes.
19
Q.
And he drowned?
20
A.
Yes.
21
Q.
And what was your involvement there?
22
A.
I was District Director. That's the time
23
I was the
District Director of the District. I
24
wasn't
there when the accident took place.
25
Q.
I see.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E
1
A.
I just newly hired and they needed
2
representation
there from the District.
3
Q.
Okay. So that's five out of the six. Car
4
you think
of -- well, let me ask you this.
5
Mr. O'Hare and/or Mr. Rader, did they depose you
6
more than once?
7
A.
I don't remember.
8
Q.
Okay.
9
A.
I don't think Mr. O'Hare ever deposed me,
10
but his
legal counsel did.
11
Q.
I'm sorry?
12
A.
I said I do not believe Mr. O'Hare deposed
13
me pro se.
14
Q.
Oh, no, I don't know how he would have
15
deposed
you. I was just asking, I guess, maybe pro
16
se with
counsel.
17
A.
Whatever.
18
Q.
Whatever.
19
A.
Yes.
20
Q.
And he didn't, to your recollection, more
21
than once?
22
A.
I don't recall.
23
The record would speak for itself, I
24
suppose.
25
Q.
Pardon?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 A. The record would speak -- whatever that
2 record is is what I believe it would be. I just
3 don't recall at this time.
4 Q. Well, are you talking about the record I
5 have in my hand?
6 A. I'm thinking the legal record that is
7 associated with actions of that nature.
8
Q.
How would I be pointed
to those?
9
A.
I really don't know.
10
Q.
So really that's not a
source of you don't
11
know where to go, is it?
12
A.
I don't understand that
question.
13
Q.
Okay. Let me see if I
can do a little
14
better
job.
15 A. All right.
16 Q. If somehow in some type of existing
17 deposition, or so forth, or document, and you don't
18 know where that deposition or document is, you
19 really can't find it, can you? I mean, you really
20 can't?
21 A. Me? No, I -- I can't find it.
22 Q. Right. And if you couldn't find it, would
23 you expect me to find it?
24 A. Well, I believe you are capable of finding
25 it.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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11
1
Q.
And are you capable of finding it?
2
A.
I don't know. I'm not as astute at this
3
sort of
thing as you are.
4
Q.
Not as what, I'm sorry?
5
A.
I am not as capable at this sort of thing
6
as you are.
7
Q.
Can you give me your background, and if
8
you don't
mind, I'm just going to ask you to speak
9
a little
slower and a little louder.
10
A.
Okay. I will try. Yes, sir.
11
Q.
Thank you.
12
A.
My background starting when?
13
Q.
Did you go to college?
14
A.
I did.
15
Q.
Okay. Let's start there.
16
A.
I attended FAU. I have a BBA and MBA from
17
there.
18
Q.
And what is your BBA and MBA in, if that's
19
the right
way to say it?
20
A.
I believe my BBA is management and my MBA
21
is concentration in finance.
22
Q.
Did you say concentration in finance?
23
A.
Yes. That's what I think.
24
Q.
Okay. I just want to make sure I have it
25
right. And what was next?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
12
1
A.
My first job was with IT&T.
2
Q.
You say IT&T?
3
A.
IT&T. I was a cost accountant
for a
4
manufacturing line.
5
Q.
Are you certified?
6
A.
A C.P.A.?
7
Q.
Yes.
8
A.
No.
9
Q.
Just curious, why would you not
have
10
gotten
certified?
11
A.
I don't like that type of work.
12
Q.
I'm sorry?
13
A.
I don't like that type of work,
that type
14
of detail.
15
Q.
I see. And what period of time
did you
16
work for IT&T?
17
A.
Frankly I -- I'm going to guess
172 to
18
'74.
19
Q.
And what was next?
20
A.
Motorola, Phoenix. I think I was
the
21
senior
accountant financial analyst for
them.
22
Q.
Senior accountant financial analyst?
23
A.
Yes.
24
Q.
And what period of time?
25
A.
'74 to '76, generally.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
13
1
Q.
And why did you leave Motorola?
2
A.
It was hot.
3
Q.
I'm sorry?
4
A.
It was hot for one thing. I didn't like
5
the area and I was offered an option to purchase a
6
family
business.
7
Q.
And just so that I'm clear, you said hot,
8
H -O -T?
9
A.
Temperature, yes. Very, very hot in the
10
summertime. I didn't like it.
11
Q.
That's in Boynton Beach, am I correct,
12
Motorola?
13
A.
No, I said Phoenix, Arizona.
14
Q.
Phoenix, Arizona. I'm sorry.
15
A.
That's okay.
16
Q.
And you left to take over a family
17
business?
18
A.
To purchase a family business, yes. It
19
wasn't
given to me and it wasn't a takeover, I had
20
to buy
it.
21
Q.
And why did you leave IT&T?
22
A.
I liked the opportunity. I thought it was
23
a good
opportunity and wanted to change.
24
Q.
And when you say it was a good
25
opportunity, are you talking about Motorola?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
14
1
A.
Yes.
2
Q.
Okay. And now we are up to 176. What's
3
goes next?
4
A.
I think I operated the business for
5
approximately
ten years and sold it.
6
Q.
And when you call it and say the business,
7
this is
the family business?
8
A.
The family business that I purchased, yes.
9
Q.
Right. But this was the family business?
10
A.
Uh-huh.
11
Q.
Okay. And you operated it for about ten
12
years?
13
A.
I think so.
14
Q.
And was it just you, anybody in your
15
family?
16
A.
My wife and I were the purchaser.
17
Q.
And who in your family worked there? Was
18
it just
you and your wife?
19
A.
In my family who worked? My wife, myself.
20
Part-time,
I would have my sons work there, I
21
believe.
22
Q.
I'm sorry, I didn't catch that.
23
A.
Part-time my sons worked there. Not much.
24
But primarily
my wife and I as far as the owners of
25
the company.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
15
1 Q. I apologize,
again, I
still -- I
heard you
2 say part-time, my son
and then
something.
I didn't
3 catch the rest.
A.
Well, I don't -- they were there.
I don't
4 A. I'm thinking
that I was saying that
5 primarily my wife and
I worked
there. My
wife
6 didn't work full-time,
she was
part-time.
I was
7 full-time.
Maybe a year.
8
Q.
Okay. And did you say something
about
9
your son
working there part-time?
yes.
10
A.
Well, I don't -- they were there.
I don't
11
know if I
paid them, but I lived very near
the
12
business
and family members would come in
and out
13 of the business.
14 Q. So this takes us to about 1986; am I
15 correct?
16
A.
These
are approximate
years and dates and
17
I'll say
yes.
18
Q.
And what
happened after that?
19
A.
I sold
the businesses
and, in a very short
20
period of
time,
I did nothing.
Maybe a year.
21 Q. So you took it easy for a year?
22 A. It didn't seem easy, but I wasn't working
23 for a year.
24 Q. Okay. So that takes us to approximately
25 1987?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
16
1
A.
Okay.
2
Q.
And?
3
A.
I was requested to help my wife's cousin
4
in a business
that he operated. So I worked for
5
him maybe
one or two years.
6
Q.
So that brings us to 188 or 189.
7
A.
Okay. I don't know, but -- okay.
8
Q.
What was next?
9
A.
I applied for a job at the Loxahatchee
10
Groves
Water Control District.
11
Q.
Did you say Loxahatchee?
12
A.
Yes.
13
Q.
And did you get that job?
14
A.
Yes.
15
Q.
What was your position there?
16
A.
District Director.
17
Q.
And what does a District Director do?
18
A.
I was responsible for budgets, water level
19
controls,
maintenance of roads, supervision of
20
employees,
representation of the district,
21
day-to-day
operations.
22
Q.
You said overseeing employees?
23
A.
Yes.
24
Q.
Now, Mr. Thrasher, unfortunately I guess
25
I'm a
slow writer or a bad hearer.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
17
1 A. That's okay.
2 Q. But I got water level, representation of
3 district, overseeing employees, and you --
4 A. Water level control, budgets, supervision
5 of employees, responsible for day-to-day
6 operations, representations in and out of the
7 district.
8 Q. That would be, excuse me, I don't mean to
9 interrupt, but you say representation in and out of
10 the district? I have representation of district;
11 would that include both of those or is that
12 something --
13
A.
I guess
representation of the district
14
would be
outside
and then represented -- I'm not
15
sure. I
reported
to the board of supervisors,
16
elected
body.
17
Q.
And is the
board of supervisors who hired
18 you?
19 A. Yes.
20 Q. Okay. And how long were you with the
21 Loxahatchee Water Control District?
22 A. Two years.
23 Q. So I have -- that takes us to 190, 191.
24
What was
next,
may
I ask?
25
A.
Well,
our
number of years are off because
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1 I think
I started working
next at Pahokee, City of
2 Pahokee
in 1992, April of
1992.
3 Q.
Okay.
10
4 A.
I think. I could
be wrong on that even.
5 At any
rate, I worked two
years at Loxahatchee
6 Groves
Water Control and I
went to the City of
7 Pahokee.
8
Q.
And how long were you
there?
9
A.
Two years.
10
Q.
Two years?
11
A.
Two years.
12
Q.
So that would take us
to 194, would it?
13
A.
It should take me to '96.
Somehow, in our
14
stretch
of numbers, I guess, I
began work with the
15
Town of
Gulf Stream, April of '96.
16 Q. So would I be right, by making a note to
17 say that as we went through this time period, that
18 we missed two years?
19 A. No. We might -- I don't think we missed
20 my employment activities, but the timeline is off.
21 I just don't know the exact -- where it went askew.
22 Q. But still we missed two years, correct?
23 A. No, I don't -- in regards to employment, I
24 don't think that we did. The numbers are just
25 wrong.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
19
1
Q.
Okay. But the result is -- I don't want
2
to argue
with you.
3
A.
Okay.
4
Q.
The result is that if the numbers are
5
wrong, an
example, if two and two and two equal
6
eight, we're missing two?
7
MR. GILL: Objection; argumentative.
8
MR. GOLDSTEIN: Joined.
9
THE WITNESS: I don't know how to answer
10
your
question, sir.
11
BY MR. O'BOYLE:
12
Q.
Okay. Why did you leave Loxahatchee?
13
A.
I was not reinstated as director.
14
Q.
Does that mean you were fired?
15
A.
No. I had a one-year, year to year
16
contract,
it was not renewed.
17
Q.
Do you know why it was not renewed?
18
A.
I believe that there was some political
19
activity
there. I couldn't articulate to you what
20
it was, but it was definitely politics.
21
Q.
The City of Pahokee, what was your role in
22
the City
of Pahokee?
23
A.
Finance director.
24
Q.
And in the City of Pahokee, what does a
25
finance director do? What are you responsible for?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
20
1 A. Well, the day-to-day financial operations,
2 supervision of employees, preparation of the
3 budget, maintenance of the budget, attend city
4 commission meetings.
5 Am I going to have to repeat that?
6 Q. I apologize. I think I got everything.
7 Did you say something about the commission?
8 A. I attended the city commission meetings as
9 the finance director.
10 Q. And anything beyond that?
11 A. I don't remember.
12 Q. Okay. And why did you depart from that
13 job?
14 A. I applied for a job at the Town of Gulf
15 Stream.
16
Q.
So you left voluntarily;
would that be
17
fair to
say?
18
A.
That is a way to say it,
yes.
19
Q.
Is there another way?
20
A.
I applied for a job at Gulf Stream.
21
Q.
Okay. And I assume you
did it
22
voluntarily; would that be fair?
23
A.
Nobody forced that upon
me. Nobody forced
24
that upon me.
25
Q.
Okay. The Town of Gulf
Stream, if I
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
21
1 recall right, you started out as the finance
2 director?
3 A. I think my title was finance director,
4 assistant to the Town Manager.
5 Q. And how long did you have that position?
6 A. I'm still the finance director, but I
7 don't know when my title changed.
8 Q. Well, were you interviewed for the job of
9 Town -- let me ask you this. Town Manager is your
10 current position?
11 A. I'm still the finance director, but I am
12 the Town Manager, yes.
13 Q. Okay. And what is the difference in
14 responsibilities between the finance director and
15 the Town Manager?
16 A. I'm not sure I know how to answer your
17 question. Not all town managers are also the
1B finance director. The finance director is more
19 involved with supervising the accounting function,
20 whereas the Town Manager could have a finance
21 director that he supervises.
22
Q.
Now, what
you just said, was that a
23
general
statement
as to that title or was that a
24
specific
statement
as to Gulf Stream?
25
A.
It was a
statement in regards to the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
22
1 general duties of most other managers, municipal
2 managers.
3
Q.
At different towns?
4
A.
Yes. Not all managers are also the
5
finance
director, they have mostly a finance
6
director
report to them, however, I don't have a
7
separate
person handle the finances.
8
Q.
So you are the finance director, correct?
9
A.
Yes.
10
Q.
Okay. And you are the Town Manager?
11
A.
Those are two titles, yes.
12
Q.
And they are both yours; is that correct?
13
A.
Yes.
14
Q.
Okay. And there was a time when the Town
15
Manager
and the finance director were two different
16
people,
correct?
17
A.
Prior to me coming to the Town of Gulf
18
Stream,
the Town of Gulf Stream outsourced their
19
accounting
activities.
20
Q.
They outsourced what, I'm sorry?
21
A.
Their accounting activities. The
22
accounting
function and at some point in time,
23
prior to
my arrival, it was determined that they
24
needed a
separate person inhouse to handle the
25
accounting
functions.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. And that person would be the finance
2 director?
3 A. Yes.
4 Q. What is the difference in roles between
5 the finance director and the Town Manager?
6 A. I believe that a finance director, in
7 normal circumstances, reports to the Town Manager.
8 Q. Let's focus on the Town of Gulf Stream
9 instead of normal circumstances, if that's all
10 right, and I hear you when you say the finance
11 director reports to the Town Manager, but my
12 question is not who the finance manager reports to,
13 but rather the difference in their roles.
14 A. Well, for me, it -- I don't know that
15 there's any difference. I perform both functions.
16 Q. Well, you told me that you were finance
17 director under -- at your predecessor Town Manager?
18 A. I was the finance director assistant to
19 the Town Manager, correct.
20 Q. But you were the finance director, would
21 that be correct?
22 A. Yes.
23 Q. And there was a different party who was
24 Town Manager?
25 A. That's correct.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. You both didn't do the same thing, did
2 you?
3 A. No.
4 Q. What is the difference or what was the
5 difference in your roles?
6 A. I'm sure there were several, but I was
7 primarily responsible for the accounting activities
8 of the Town of Gulf Stream, whereas the manager,
9 whom I reported to, had additional
10 responsibilities.
11 Q. So your responsibilities to the Town of
12 Gulf Stream, when you were finance director, were
13 what again, if you don't mind?
14 A. The general accounting activities.
15 Q. Okay. Am I correct to assume that you
16 worked with the outside C.P.A.s?
17 A. We have always had outside auditors.
18 Q. That's what --
19 A. Statutes require that for all
20 municipalities. Is that what you mean?
21 Q. Well, my question is --
22 A. Okay.
23 Q. -- as finance director, did you work with
24 those outside auditors, C.P.A.s, whatever?
25 A. Yes.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. Whoever they are?
2 A. Yes.
3 Q. Yes?
4 A. Yes.
5 Q. Okay. And did you supply them the
6 information for them to, I guess, do their audit,
7 whatever it is they do?
8 A. Yes.
9 Q. And now that you're Town Manager, if I
10 am -- if I am getting it, your jobs have sort of
11 molded into one being the job of finance director,
12 which you still hold, and Town Manager; would that
13 be correct?
14 A. I am ultimately responsible for the
15 financial reporting as well as the day-to-day
16 operations of the Town.
17 Q. And the Town Manager, the only
18 responsibility he has -- Strike that.
19 Am I correct to say that the only
20 responsibility the Town Manager has is overseeing
21 the day-to-day items?
22 A. The only responsibility?
23 Q. Yes.
24 A. No.
25 Q. Okay. Well, what responsibility would the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E.
1 Town Manager have?
2 A. Town Manager is responsible for the annual
3 budget. He's responsible for assuring that
4 policies and/or ordinances are upheld. He
5 represents the Town at commission meetings. He
6 represents the Town on outside activities.
7 Q. Let me stop you there for a moment.
8 A. Okay.
9
Q.
When you say outside activities, could you
10
elaborate
on that for me?
11
A.
Well, the voting delegate at the Florida
12
League
of Cities have been assigned that duty,
13
would
not be something that the -- typically any
14
other
employee would do.
15
Q.
Let me -- excuse me. I heard you say
16
something
about the league and voting delegates?
17
A.
He is the voting -- at times, he is the
18
voting
delegate at the annual Florida League of
19
Cities
meeting.
20
Q.
Go ahead.
21
A.
Could appear before the Palm Beach County
22
Commissioners,
the County Commissioners. Could --
23
Q.
Wait. One second.
24
A.
Okay.
25
Q.
In connection with appearing before the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
27
1 Palm Beach County Commissioners, what was the
2 purpose?
3
A.
I don't recall what it was.
4
Q.
How long ago was it?
5
A.
Several years.
6
Q.
What is a voting delegate at the League of
7
Cities?
8
A.
I'm not sure I know how to explain it to
9
you, other than it's a voting delegate at the
10
annual meeting that they vote on -- it could be
11
resolutions, things of that nature.
12
Q.
Who divined you to be the voting delegate?
13
A.
The commission would do that, if they so
14
chose.
15
Q.
The Gulf Stream Commission?
16
A.
Yes.
17
Q.
And how long have you been a voting
18
delegate?
19
A.
I think each year -- I'm not sure. I
20
think we
have to fill out a form. How many times
21
I've done
that, I do not recall.
22
Q.
Would it be more than ten?
23
A.
No, no, it would be less than ten.
24
Q.
Pardon?
25
A.
It would be less than ten.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 Q. Okay. Would it be less than five?
2 A. I don't remember, Mr. O'Boyle.
3 Q. And did the commission, when they
4 appointed you, did it assume -- for the sake of
5 this question, let's assume it was five years. Did
6 they appoint you five times or just one time and it
7 kept going?
8 A. No, I believe it's required that the form
9 must be filled out every year. Not every year
10 would the commission necessarily decide to send
11 somebody or take that option on. I just don't
12 remember, but it's not -- it's not ongoing. Is
13 that your question?
14 Q. I think it is but --
15 A. Okay.
16 Q. But we may be saying different things.
17 A. Okay.
18 Q. What I'm asking is --
19 A. How many times my name is on that? I
20 don't recall.
21
Q.
Okay. But you
were certainly not a
22
delegate
for ten years,
it was less than ten years?
23
A.
No. In fact, I
believe that we -- it
24
could be
my recollection
that I've only voted once,
25 once, at such an annual meeting, and we only have
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
29
1 one vote in the whole number of delegates, so it's
2 more of an alignment with the activities of the
3 day.
4 Q.
Does
the
commission give you a freehand,
5 and what
I mean
by
that is,
do they direct you? I
6 assume there's
an
agenda when things are coming up
7 for vote
with
the
league of
municipalities or
8 whatever
it's
called;
would
that be correct?
9
A.
I'm not sure
I know what you mean.
10
Q.
Okay. In the
Town of Gulf Stream, there's
11
an agenda
when there's
a meeting?
12
A.
Yes.
20
13 Q. Does the league of -- is it called League
14 of Cities?
15
A.
Yes.
16
Q.
Okay. Do they have an agenda when they
17
are having
a meeting?
18
A.
They -- at the annual meeting, where the
19
votes are
cast, there is an agenda, yes.
20
Q.
And does the commission tell you how to
21
vote in
connection with an item or the items on the
22
agenda
or do they just say go have a ball and vote
23
the way
you wish?
24
A.
Well, I'm sure you're jesting a bit. My
25
commission
has never told me to go to such a
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
30
1 meeting and have a ball. I wish that they would,
2 but they have not. I've only voted once and, no,
3 they did not direct me as to how I would cast that
4 vote.
5 Q. So as the Town Manager, you're a voting
6 delegate and the fashion in which you vote is up to
7 you?
8 MR. GILL: Object to the form of the
9 question; mischaracterizes the testimony and
10 relevance.
11 THE WITNESS: I don't remember your
12 question, but I know that I didn't agree with
13
something in
your
question,
so if
you'd like
14
to do it, if
you
would be so
kind
as to ask me
15
one question
at a
time and
I'll do
my best to
16 answer it for you.
17 MR. O'BOYLE: Okay. Madam Court Reporter,
18 can you read my question back, please.
19 (The question referred to was read by the
20
reporter
as above
recorded.)
21
MR.
GILL: Same
objection.
22
THE
WITNESS:
I am not always the voting
23
delegate.
They assign
me to be the voting
24
delegate
if they
choose to and the answer is,
25
yes, I do
vote as
I believe the town would
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
3]
1 want me to vote, but they didn't give me
2 written orders or verbal orders, you will vote
3 this way on certain resolutions. And, again,
4 it happened once. It was an honor. I go to
5 different meetings, but sometimes they -- I
6 think, but I'm not certain, they assign all
7 five commissioners and myself as voting
8 delegates, but I'm not sure about that.
9 BY MR. O'BOYLE:
10 Q. Okay. The League of Cities --
11 A. Yes.
12 Q. -- what do they do?
13 MR. GILL: Objection; speculation.
14 THE WITNESS: I don't -- I really don't
15 know. I know there's a Palm Beach County
16 League of Cities and there's a Florida League.
17 To describe what they do, I'm unable to do so.
18 BY MR. O'BOYLE:
19 Q. Have you ever received an award or a
20 recognition from the League of Cities?
21 A. Yes.
22 Q. And what was that for?
23 A. I think I've received more than one and I
24 couldn't tell you what they are for.
25 Q. You can't remember any of them?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
32
1
A.
Palm Beach County League I received the --
2
an award
for outstanding achievement. The League
3
of Cities
I have received a -- what they call a
4
home rule
hero reward. There may be others.
5
Q.
Do you think I'm a criminal?
6
A.
I have no idea.
7
Q.
So that means I might be in your eyes?
8
A.
I don't know if you're a criminal.
9
Q.
Can you say that I am a criminal?
10
A.
No.
11
Q.
Can you say that I am not a criminal?
12
A.
No.
13
Q.
Okay.
14
MR. GILL: I would like to order the last
15
three
questions as an expert.
16
MR. GOLDSTEIN: I'll take a copy of that
17
as well.
18
BY MR. O'BOYLE:
19
Q.
Did you ever remember my truck being
20
parked in
the parking lot at the Town Hall with a
21
banner on it, either criticizing the Town,
22
criticizing
you or criticizing the Mayor; do you
23
remember
that?
24
MR. GOLDSTEIN: Object to form.
25
THE WITNESS: I remember on occasion it
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
33
1
was
parked there with banners on it, yes. I
2
don't
recall the banners, what they said or
3
the
color or anything like that.
4
BY MR.
O'BOYLE:
5
Q.
You don't recall the content of any of the
6
banners
that were on the truck at all?
7
A.
No.
8
Q.
Would that be correct?
9
A.
At this point, this sitting, no.
10
Q.
Okay. Do you remember the chief of police
11
telling
me to get out of this Town Hall?
12
A.
No.
13
Q.
Okay. Do you remember me having this
14
camera
in the lobby of the Town Hall and you put
15
your nose
right up against it; do you remember
16
that?
17
MR. GILL: Objection; relevance.
18
THE WITNESS: I don't know if that was the
19
camera, but I know that you had a camera and I
20
came close to the camera, but I did not touch
21
your camera.
22
BY MR. O'BOYLE:
23
Q.
Okay. Why did you come close to it?
24
A.
I don't recall. I don't remember.
25
Q.
Do you remember when the Town put those
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
34
1 two boards in the lobby?
2
A.
Two boards?
3
Q.
Yes. One that said, and it's not exact,
4
but generally, Martin O'Boyle and his alias and
5
Christopher O'Hare, Chris O'Hare and his alias.
6
A.
I remember there were boards placed in the
7
entrance
lobby on the north wall.
8
Q.
Okay.
9
A.
In some form or fashion.
10
Q.
Pardon?
11
A.
In some order. I don't remember the
12
order.
13
Q.
And who ordered those boards to be placed
14
there?
15
A.
I placed them there.
16
Q.
You did?
17
A.
Yes.
18
Q.
Okay. And am I correct in remembering
19
that there were, in many locations, including that
20
center desk there, newspaper articles that were
21
meant to
diminish my standing in the community?
22
MR. GILL: Object to the form of the
23
question.
24
MR. GOLDSTEIN: Joined.
25
THE WITNESS: I don't know that that was
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
35
1 the purpose.
2 BY MR. O'BOYLE:
3 Q. What was the purpose?
4 MR. GILL: Object to the form of the
5 question.
6 THE WITNESS: I believe it was in regards
7 to budget discussions. I'm not sure, but I
8 think so.
9 BY MR. O'BOYLE:
10 Q. The newspaper articles about me had
11 something to do with budgets you say?
12 A. That's my recollection.
13 Q. Can you tell me where the nexus might be?
14 A. The line item on the budget, legal
15 expenses.
16 Q. And that had what to do with a newspaper
17 article demeaning me?
18 MR. GILL: Object to the form of the
19 question.
20 THE WITNESS: I don't know that the
21 article was demeaning. It was relevant to the
22 legal activities and expenditures and relative
23 to the line item legal expenditures.
24 BY MR. O'BOYLE:
25 Q. You didn't put them out there, did you, as
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
36
1 a -- representing the content was a matter of fact,
2 did you?
3 MR. GOLDSTEIN: Object to form.
4 MR. GILL: Join.
5 THE WITNESS: I put them out there because
6 they seemed to resemble illegal activities
7 that created the need to increase our legal
8 budget.
9 BY MR. O'BOYLE:
10
Q.
I'm not sure I'm grasping,
so let me ask
11
you this.
Is what you are saying,
that if those
12
articles
would not have been there,
your legal
13 budget would be different?
14 MR. GOLDSTEIN: Object to form.
15 MR. GILL: Join.
16 THE WITNESS: I'm not saying that at all.
17 I'm saying that the legal budget was very high
18 and I thought that this could allow people to
19 understand why there was a need for the size
20 of the legal budget.
21 BY MR. O'BOYLE:
22 Q. I heard you say something about make
23 people understand?
24 A. No. Allow people to comprehend or have an
25 understanding why the legal budget was as high as
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1 it was being proposed.
2 Q. How would a newspaper article or articles
3 do that?
4 A. At this sitting, I don't know.
5 Q. Back then when you did it, were you the
6 one -- Strike that.
7 Were you the one who put the newspaper
8 articles on the tables to be seen by whoever wanted
9 to look at them?
10 A. I did.
11 Q. Okay. Did you do it at anyone's
12 direction?
13 A. No.
14 Q. And your goal in doing that was what?
15 MR. GILL: Object to the form of the
16 question.
17 THE WITNESS: To provide to those who
18 might need a better understanding, to provide
19 to them an understanding why the legal budget
20 had to be so high.
21 BY MR. O'BOYLE:
22 Q. And if the information in those news
23 articles was false, how would that help you with
24 what you just said?
25 MR. GILL: Object to form of the question.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1
MR. GOLDSTEIN:
Joined.
articles, and I may
2
THE WITNESS:
If it were
false, I don't
3 think
that it would
help me.
and a half hours for
4 BY MR. O'BOYLE:
each one; would that be a true
statement?
the records request, it
5 Q.
I'm sorry?
as
it applies to this
6 A.
If it were false,
I don't
think it would
7 help me.
records request;
is that a
fair statement?
8 Q.
Okay. Was it
false?
9 A.
I don't know.
I thought
it was accurate.
10
Q.
Okay. And one of the
articles, and I may
11
have it
here with me, said that
for each records
12
request,
the Town spends three
and a half hours for
13
each one; would that be a true
statement?
14 MR. GILL: Object to form of the question.
15 THE WITNESS: I don't know if that was a
16 generalization, but I do not believe that in
17 all cases that would be correct.
18 BY MR. O'BOYLE:
19
Q. Okay.
So when it
says what I'm going to
20
call a wholesale
basis that
the records request
21
take three and a
half hours,
that's not a true
22
statement as it
applies to
the records request, it
23
may be a true statement
as
it applies to this
24
records request,
that records
request or some
25
records request;
is that a
fair statement?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
39
1 MR. GILL: Object to the form of the
2 question.
3 MR. GOLDSTEIN: Joined.
4 THE WITNESS: I don't know the answer to
5 your question.
6 BY MR. O'BOYLE:
7 Q. Where are you struggling with the answer?
8 MR. GILL: Object to the form of the
9 question.
10 THE WITNESS: What did you ask me just
11 then?
12 BY MR. O'BOYLE:
13 Q. I'm sorry. I said, where are you
14 struggling with getting the answer?
15 A. I just don't seem to comprehend or
16 understand your question.
17 Q. Okay. What don't you understand about my
18 question?
19 A. Well, if I don't understand your question,
20 I don't know how to answer that question.
21 Q. Okay.
22 MR. GILL: I would like to mark and
23 possibly order all the questions going back to
24 when he asked about the newspaper article.
25 I'll let you know if I'm going to order it at
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
the
end.
2
BY MR.
O'BOYLE:
3
Q.
Mr. Thrasher?
4
A.
Yes, sir.
5
Q.
Let's move over to the boards for a
6
second,
okay?
7
A.
Okay.
8
Q.
They were your idea?
9
A.
I don't recall whose idea that was.
10
Q.
Now, I may be mistaken in what I wrote
11
down, but
I thought you just said it was you?
12
A.
You asked me if I placed the boards there
13
and the
answer to that question was, yes, I placed
14
them there.
15
Q.
And where did they come from, the boards?
16
A.
I believe they came from one of our
17
special
counsel.
18
Q.
And which special counsel would that be?
19
A.
I believe it was Robert Sweetapple.
20
Q.
Okay. Do you remember what the board
21
said?
22
A.
No.
23
Q.
And why were they out there?
24
A.
I believe they were out there for
25
justification
or providing better understanding to
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
41
1 the residents that
attended
the
meeting
as
to the
2 legal expenditures,
the size
of
them and
so
on.
3 Q. And the legal expenditures that you
4 have --
5 A. Yes.
6 Q. -- which category do they fit into? Do
7 they fit into the defending records suits or do
8 they fit into attacking the person who filed the
9 records suits?
10 MR. GOLDSTEIN: Object to form.
11 MR. GILL: Join.
12 THE WITNESS: Attacking is an inaccurate
13 position to take.
14 BY MR. O'BOYLE:
15 Q. How do you know it's inaccurate?
16 A. Because I would not take such a position
17 against anybody and I do not believe that any
18 member of our commission would do that either.
19 Q. Do you know how many either lawsuits or
20 counterclaims that the Town has filed against me
21 this year?
22 A. No.
23 Q. Do you know how much it cost?
24 MR. GILL: Object to the form of the
25 question.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
42
1 MR. GOLDSTEIN: Joined.
2 THE WITNESS: I, individually, the answer
3 is no.
4 BY MR. O'BOYLE:
5 Q. What's does individually mean?
6 A. I don't know what any counterclaim, if
7 they exist, cost. We don't -- we don't accrue
8 expenditures other than in one line item and it
9 just simply says legal.
10 Q. Getting back to those news articles. How
11 was that going to assist or help in the budget and
12 alert the people of where all the money is going if
13 you are only showing them one half of the equation?
14 MR. GILL: Object to the form of the
15 question.
16 MR. GOLDSTEIN: Joined.
17 THE WITNESS: I don't know.
18 BY MR. O'BOYLE:
19 Q. So what good were those newspaper
20 articles? What could the people learn from them?
21 MR. GILL: Object; argumentative,
22 relevance.
23 MR. GOLDSTEIN: Joined.
24 THE WITNESS: I don't know.
25 BY MR. O'BOYLE:
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
43
1 Q. So you don't know what the people could
2 learn from them, right?
3 MR. GILL: Objection; argumentative,
4 relevance.
5 MR. GOLDSTEIN: Joined.
6 MR. GILL: He answered the question, you
7 don't like the answer, that's argumentative.
8 MR. O'BOYLE: Why don't you guys do this:
9 We'll allow you to every question it could be
10 you could make your objection or whatever it
11 is and then after you get the transcript you
12 can decide which ones you want to pursue.
13 This way, we'll go along a lot faster and you
14 don't have to make your statements, you'll
15 already have made them.
16 MR. GILL: I don't think you can agree to
17 standing objections like that, so I'm not
18 going to do it. I'm going to continue to make
19 my objections as I see fit.
20 MR. O'BOYLE: That's fine.
21 THE WITNESS: Excuse me, Mr. O'Boyle, may
22 I have a break?
23 MR. O'BOYLE: Sure.
24
THE
WITNESS:
Thank you.
25
MR.
O'BOYLE:
You are very, very welcome.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 (A brief recess was taken, after which the
2 following proceedings were had:)
3 BY MR. O'BOYLE:
4 Q. Mr. Thrasher, we are back on the record
5 after having taken a short break at your request.
6 A. Thank you.
7 Q. While we took the break, did you speak to
8 anyone?
9 A. Yes, I spoke to Mr. Gill.
10 Q. Can you tell me what you spoke about?
11 MR. GILL: I'm going to object to that,
12 instruct attorney/client privilege.
13 You can't inquire into my conversations
14 with my client.
15 BY MR. O'BOYLE:
16 Q. Okay. And how about Mr. Goldstein, did
17 you speak to him?
18 A. No. No.
19 Q. You seem, maybe I'm mistaken, but you seem
20 somewhat hesitant.
21 A. I was hesitant because prior to us
22 beginning, I thought he asked what the date was and
23 so I wasn't sure of the timing.
24 Q. Got you. Okay.
25 Back to the boards, the content of the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
45
1 boards.
2
A.
Okay.
3
Q.
Where did that come from?
4
A.
I believe it came from special counsel
5
Sweetapple.
6
Q.
Am I correct that the boards, the way they
7
were mounted
on the easels was as Mr. Sweetapple
8
delivered them?
9
A.
No.
10
MR. GOLDSTEIN: Object to form.
11
BY MR. O'BOYLE:
12
Q.
Can you explain to me then?
13
A.
I placed them in position so as to, I
14
guess, to my preference.
15
Q.
I'm sorry?
16
A.
Basically to my preference, as far as how
17
it would
be seen.
18
Q.
Right. I understand that. But my
19
question
is, the content on the board, where did
20
that come
from?
21
A.
I don't know for sure.
22
Q.
Okay.
23
A.
The content itself, I don't know.
24
Q.
You, if I'm mistaken, let me know, you put
25
the boards
up on the easels?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1
A.
I could be wrong, but I think there were
2
two easels
and maybe there was a board that was not
3
on an easel,
but I'm not sure. I cannot remember
4
for sure.
5
Q.
Okay. And the boards, how did they --
6
let's just
assume -- you know one board went on an
7
easel, correct?
8
A.
A board would go on one easel, yes.
9
Q.
And indeed there was at least one board
10
that was
placed on one easel?
11
A.
That's how I think I remember it, yes.
12
Q.
How did it get there?
13
A.
I put it there.
14
Q.
And where did it come from for you to put
15
it there?
16
A.
I don't remember exactly how that
17
happened.
18
Q.
Was it sitting inside of City Hall; do you
19
know, or
Town Hall?
20
A.
I believe they were all, yes, that's what
21
I think.
22
Q.
And where was it sitting in Town Hall; do
23
you remember?
24
A.
No.
25
Q.
Okay. And you said the content of it,
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
47
1 when I
say
you,
I'm
not putting
words
in your
2 mouth,
if I
got
it
wrong, you'll
tell
me.
3 A. I'm not so sure about that.
4 Q. You said that the content of the boards
5 were from Mr. Sweetapple; is that correct?
6 A. I believe the -- I think the boards came
7 from Sweetapple. I don't know how the content got
8 on the boards.
9 Q. If the boards came from Mr. Sweetapple,
10 did they come with the content? Otherwise, you
11 could have went to Kinkos for five bucks.
12 MR. GILL: Object to the form of the
13 question.
14 THE WITNESS: I don't understand that
15 question.
16 BY MR. O'BOYLE:
17 Q. Okay. You know, do you not, that you
18 could buy a mounted piece of paper with nothing on
19 it; am I correct?
20 A. I don't know.
21 Q. You don't know that?
22 A. No, I don't know that.
23 Q. Okay. You know that there are boards, and
24 when I say boards, Styrofoam, 24 by 36 boards that
25 people use for illustration, for display and so
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
wa
1 forth; you know that, correct?
2 A. Yes.
3 Q. Okay. Before that text or graphics or
4 whatever is on that board was put on there, it was
5 just a blank piece of paper, wasn't it?
6 A. I don't know what that paper looked like
7 prior to being attached to the board, if that's
8 your question.
9
Q.
Well,
prior to this pad, that I have in my
10
hand,
which is
a typical eight and a half by 11
11
pad, if
there
was no writing on here, it would be
12
blank;
do you
agree?
13
A.
No.
14
Q.
No.
Tell me why you don't agree.
15
A.
Well,
it has lines on it. So excluding
16
the lines,
it's
blank.
17
Q.
Okay.
Excluding the lines, it's blank.
18
Thank
you.
19 The 24 by 36 boards that were in the
20 lobby, they had no lines on them, did they?
21 A. I don't recall.
22 Q. Okay. Where are they now?
23 A. I don't know.
24 Q. Okay. Who took them down?
25 A. I don't know that either.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1
Q.
What's an alias?
2
MR. GILL: Object to the form of the
3
question.
4
MR. GOLDSTEIN: Joined.
5
THE WITNESS: I don't know.
6
BY MR.
O'BOYLE:
7
Q.
Well, on those boards you said Martin
8
O'Boyle and his aliases?
9
MR. GOLDSTEIN: Object to form.
10
MR. GILL: Join.
11
THE WITNESS: I didn't say anything.
12
BY MR.
O'BOYLE:
13
Q.
Pardon?
14
A.
I didn't say anything.
15
Q.
Well, do you agree that the word aliases
16
was on
my board?
17
A.
I can't confirm nor deny. I don't
18
remember.
19
Q.
Okay. Do you remember anything that was
20
on my board?
21
A.
No.
22
Q.
Nothing?
23
A.
No.
24
Q.
So it could have been a picture of Mickey
25
Mouse?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
50
1
A.
Oh, I know it wasn't that.
2
Q.
Donald Duck?
3
A.
No.
4
Q.
Okay. Was it text?
5
A.
Yes.
6
Q.
Okay. But you have no idea, no idea what
7
it said?
8
A.
I cannot remember a thing about it, no.
9
Q.
Did you ever hear that I was there,
10
meaning
at the Town Hall, and I -- you were at the
11
Town Hall
that night, were you not?
12
A.
There was a Town Hall meeting, I was
13
there.
14
Q.
After the Town Hall meeting was over,
15
where did
you go to?
16
A.
Immediately, I didn't go anywhere.
17
Q.
Okay. Tell me, if you could, sort of step
18
by step
what you did once the Town Hall was over.
19
MR. GILL: Mr. O'Boyle, isn't this the
20
subject
of the criminal proceeding that you
21
refused
to answer questions about when I
22
deposed
you?
23
BY MR. O'BOYLE:
24
Q.
Mr. Thrasher?
25
MR. GILL: Mr. O'Boyle, is that what you
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
51
1 are getting into?
2 BY MR. O'BOYLE:
3 Q. Mr. Thrasher?
4 MR. GILL: Are you conducting discovery in
5 the criminal proceeding? Are you conducting
6 discovery in the criminal proceeding? I'm
7 asking you a question, Mr. O'Boyle.
8 MR. O'BOYLE: I know you are.
9 MR. GILL: Are you going to answer my
10 question?
11 MR. O'BOYLE: I don't think so.
12 MR. GILL: Then I'm going to have him not
13 answer the question at this point. Unless you
14 can tell me how it's relevant to this lawsuit,
15 I don't want to hear about it.
16 MR. O'BOYLE: You want to instruct him not
17 to answer, go ahead.
18 MR. GILL: That question.
19 MR. O'BOYLE: Go ahead. Instruct him not
20 to answer.
21 MR. GILL: I am asserting an objection to
22 that question and having the witness not
23 answer, because I think you are conducting
24 discovery in your criminal proceeding right
25 now.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
52
1 Is it framed in this complaint? If you
2 can tell me if it's framed in the complaint,
3 this is framed in your complaint, you can show
4 me where, maybe we can get into it.
5 MR. O'BOYLE: Mr. Gill, I know how I
6 operate, I know my style and I know my process
7 and if you think you are going to change the
8 way I do things, you are wrong. I'm not going
9 to allow it, so I'm going to proceed. If you
10 want to instruct him not to answer, I don't
11 have a problem in the world with that, you can
12 go ahead and instruct him not to answer and
13 we'll deal with it with the judge, unless we
14 can bring Mr. Thrasher back after we have a
15 meeting and confirm.
16 MR. GILL: I'm giving you an opportunity
17 right now to explain to me how that's relevant
18 to this lawsuit and then I'll consider waiving
19 the objection.
20 MR. O'BOYLE: Yeah, I'm not going to share
21 with you my strategy and I've made that clear
22 in the past and I'm making it clear again and
23 I apologize if that doesn't sit well with you.
24 I apologize.
25 MR. GILL: I'm just giving you the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
53
1
opportunity to discuss with me how this line
2
of
questioning is relevant to the lawsuit. If
3
you
are not going to, then we're going to have
4
to
move onto something else.
5
MR. O'BOYLE: That's fine.
6
MR. GILL: Okay.
7
BY MR.
O'BOYLE:
8
Q.
Mr. Thrasher, you did go to the commission
9
meeting
the night of the boards, correct?
10
A.
If that was a commission meeting, yes.
11
Q.
Okay. While you were in the commission
12
room, how
long were you there?
13
A.
I don't recall.
14
Q.
Was it moments, half hour, an hour, do you
15
have any
idea or no idea?
16
A.
To answer the question effectively, I
17
don't know the answer.
18
Q.
Does the Town Manager, does he set policy
19
for the
Town?
20
A.
No.
21
Q.
Who does?
22
A.
Town Commission.
23
Q.
And when do they set that policy?
24
MR. GILL: Object to the form of the
25
question.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
54
1 THE
WITNESS:
I don't know the answer to
2 that question.
what policy you are referring
11
3 MR.
O'BOYLE:
I apologize very much. Can
4 you read
that answer
back, please?
5 (The
question
referred to was read by the
6 reporter
as above
recorded.)
7 BY MR. O'BOYLE:
8 Q. So you don't know when they set the
9 policy?
10
A.
I don't
know
what policy you are referring
11
to or
policies
you are
referring to, so, no, I
12
don't
know the
answer
to your question.
13 Q. Any policy.
14 A. They establish a policy through a public
15 hearing with a vote of the commissioners,
16 typically.
17
Q.
Tell me, if you will, when
the last
18
commission
meeting was that
they set
policy and
19
what they
-- where they set
policy.
20
A.
I don't remember.
21
Q.
Okay. Tell me, if
you can,
when the last
22
time that
they -- that you
remember
a policy that
23 was set by the commissioners.
24 A. Within the last, I'm going to say, 90 days
25 they -- there was a second reading on an ordinance.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
5C
1 Q. An ordinance is a law, is it not?
2 MR. GILL: Object to the form of the
3 question.
4 THE WITNESS: It becomes -- I don't know
5 the answer to that question.
6 BY MR. O'BOYLE:
7 Q. You don't know if an ordinance is a law?
8 That's what I'm hearing; is that correct?
9 A. I'm going to say --
10 MR. GILL: I object and I would like to
11 mark all the questions about policy.
12 THE WITNESS: I am not able to answer the
13 question about law.
14 BY MR. O'BOYLE:
15 Q. You do know what an ordinance is, though;
16 am I correct?
17 A. I think so, yes.
18 Q. Is it a law?
19 A. I don't know the answer to that question.
20 MR. GILL: Object to the form of the
21 question.
22 BY MR. O'BOYLE:
23 Q. Then what is it?
24 A. Well, for sure it's an ordinance, but
25 other than being able to answer that for you, I
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
56
1 can't say.
2
Q.
Didn't you just say that you knew what an
3
ordinance
was?
4
A.
I don't think I did, but if I did, I can't
5
express to
you what that ordinance is, what an
6
ordinance
is as it relates to law.
7
Q.
Behind the Town Hall building --
8
A.
Yes.
9
Q.
-- someone installed a high row of, I'm
10
going to
call them, hedges, I don't know if they
11
are hedges,
and this would be between the northeast
12
corner of
the Town Hall and going towards County
13
Road and
then I think there's parking spaces that
14
sort of butt
up against it. Do you know where I
15
mean?
16
A.
I believe so.
17
Q.
Why was that installed? Why were they
18
installed?
19
MR. GILL: Object to the form of the
20
question.
21
THE WITNESS: Aesthetics.
22
BY MR. O'BOYLE:
23
Q.
Pardon?
24
A.
Aesthetics.
25
Q.
Aesthetics.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
57
1
Who made the decision to install it?
2
A.
I did.
3
Q.
You did.
4
Now, you've been with the City, if my
5
notes
are correct, about 20 years or so?
6
A.
Correct.
7
Q.
If it's aesthetics that you put them there
8
for, why
did you wait 20 years?
9
A.
Budget.
10
Q.
Budget? They were installed last year,
11
correct?
12
A.
I don't recall when.
13
Q.
Okay. But they were installed within the
14
last year
or two; would you say that?
15
A.
I would say within the last two years.
16
Q.
Okay.
17
A.
I'm not certain. I'm not certain.
18
Q.
I understand.
19
And during the last two years, or whatever
20
period
that they were installed, the Town had a
21
legal
budget of a million dollars, perhaps an
22
amount
less, that you'll tell us about; would that
23
be correct?
24
A.
I don't understand your question.
25
Q.
Okay. The Town had a budget in the year
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E
1 2014, correct?
2 A. It had a budget in 2014, yes.
3 Q. Okay. And in that budget there was a line
4 item for legal?
5 A. Correct.
6 Q. Okay. And what was the amount of that
7 line item for legal?
8 A. Well, 2014, I don't know what the budget
9 was. I think the actual expenditure was 500,000.
10 Q. Okay. And in 2015, the Town had a budget;
11 would that be correct?
12 A. Yes.
13 Q. And was there a line item for legal?
14 A. Yes.
15 Q. Okay. And what was the amount of that
16 line item?
17 A. 2015. I -- I believe that the -- I don't
18 remember the budget. The actual expenditure I
19 think was a little over 800,000.
20 Q. Okay. Now, you said that you didn't put
21 those hedges up, and that's what I'm calling them,
22 because of budget constraints in the past. Have
23 you ever had a legal budget in the last 20 years
24 that you've been either finance director or Town
25 Manager? Have you ever had a legal budget of
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
59
1 greater than $500,000 or I should say greater than
2 499,000?
3
A.
I believe the
answer is yes. I don't --
4
after the fact I'm not
-- I don't recall the
5
budget,
but I know the
legal expenditures are high
6
and the
actual expenditures
are what actually
7
effects
our, you might
say, bottom line. Not the
8
budget,
but the actual
expenditures.
9
Q.
Okay. And where
you had the budget for
10
2014 is
$500,000?
11
A.
I think I said
the actual expenditures.
12
I'm hoping
that all of
my answers as it relates to
13
legal is
talking about
the actual expenditures.
14
Q.
Mr. Thrasher,
I really apologize, but if
15
there's
a way that you
could speak up --
16 A. Okay.
17 Q. -- you'd be helping us both out, I think.
18 A. Okay.
19 Q. All right.
20 A. I'll try. You'll have to keep reminding
21 me, I believe.
22 Q. I'll try to get you a megaphone.
23 A. That will be all right. I work well with
24 a mic here. I'm used to that.
25 Q. So anyway, 500,000 was the budget in 114,
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 right?
IN
2
A.
I don't recall the budget. I'm going to
3
say that
I believe the actual expenditures were
4
approximately
500,000.
5
Q.
Okay. And then in 115 it was 800,000?
6
A.
Actual expenditures are a little over
7
800,000.
8
Q.
And am I correct that I heard you say that
9
there was
a period of, or perhaps more than one
10
period,
where the line item legal fees that were
11
spent was
higher than $500,000 or higher than 499?
12
A.
I believe -- I believe fiscal year, just
13
off the
top of my head, I believe that the fiscal
14
year 2015,
which we just completed, was a little
15
over $800,000
in expenditures.
16
Q.
I'm sorry, it wasn't clear.
17
A.
Okay.
18
Q.
You were with the Town for 20 years --
19
you've been with the Town for 20 years?
20
A.
Yes.
21
Q.
You just told me what the expenditures
22
were for
2014 and '15.
23
A.
Okay.
24
Q.
The 20 years is either '94 or 196?
25
A.
Okay.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
61
1
Q.
In that area?
2
A.
Yes.
3
Q.
Between that period and between
4
December
31st, 2013, was there ever a year when the
5
legal fees
exceeded those in 114, 2014, being
6
500,000
and 2015 being 800,000?
7
A.
No, I don't recall any occurrence like
8
that.
9
Q.
Okay. If that's the case, unless I
10
misunderstood
you, you said that the hedges were
11
put up by you and I don't mean actually dug a hole,
12
but --
13
A.
It was my decision.
14
Q.
Your instruction. They were put up by you
15
and they
weren't put up earlier because you didn't
16
have the
money?
17
A.
I didn't feel as though I could expend the
18
funds at
that time.
19
Q.
And how much, ball park, were those
20
hedges?
21
A.
I will guess between 5 and $8,000.
22
MR. GOLDSTEIN: Move to strike based on
23
guessing.
24
THE WITNESS: Sorry.
25
BY MR. O'BOYLE:
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
62
1 Q.
Were you just
guessing, Mr. Thrasher?
2 A.
I was, yes. I
don't know the exact
3 number.
4 Q.
Pardon?
5 A.
I don't know the exact
number.
6 Q.
Now, I sort of lost my
place a little bit,
7 maybe
you can help me back.
8 A.
I won't do that.
9 Q.
You had said between 5
to 8,000 was the
10 cost of --
11 A. I'm estimating it to be that. I don't
12 recall --
13 Q. Of course.
14 A. -- exactly what it was.
15 Q. But that would be, generally stated, that
16 would be the amount, correct?
17 A. I think that's a good estimate, yes.
18 Q. Okay. And you felt that you couldn't do
19 it earlier, although it needed it for aesthetics,
20 you felt that you couldn't do it earlier because of
21 budget constraints and I say earlier, before 2014?
22 A. I had recognized the need for it maybe two
23 years prior to doing it. I thought it would be a
24 nice addition, but didn't feel comfortable in
25 expending funds for that at the time.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
63
1 Q. At what time?
2 A. At the time I did it.
3 Q. The time you did it, you did expend funds,
4 did you not?
5 A. Yes. I'll try to say it again maybe more
6 clearly.
7 I had recognized the need for the hedges
8
to be
placed
there, in my mind, a couple of years
9
prior
to the
actual planning of the hedges, prior
10
to the
actual
expenditure for the hedges.
11
Q.
You
lost me.
12
A.
Well,
I don't know what else to say.
13
Q.
Can
you just try it again? Maybe I wasn't
14 listening.
15 A. Okay. Approximately two years prior to
16 the actual event, I felt and believed that hedges
17 in that area would be an improvement to the
18
aesthetics of
the property,
and
I only
felt
19
comfortable in
doing so when
I
actually
did it.
20
Q. Didn't you feel
that way
ten
years ago?
21
A. I can't recall.
I don't
know
that I
22
thought of it ten years
ago, no.
I'm
not saying --
23
I just don't know when I
did, but
I thought
of it,
24
in my own mind, as an area
that could
be
25
aesthetically improved,
the view
from
the roadway,
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
z
1 and many
times I
went by the roadway and what you
2 would see
would
be the asphalt parking and it
3 looked as
-- it
looked -- it didn't look
4 aesthetically pleasing and it looked like it would
5 be an area that could be improved upon.
6
Q. And that area that
you are speaking of
7
that could be
improved upon,
it could be improved
8
upon in 2015,
2014, 2010, 2000,
1998, any time
9
while you were
there or even
before you if the
10
person who had
your position
or a different
11
position with
that authority
decided to do it; am I
12
correct?
important to our
residents, landscaping,
13
A. I don't
know the answer to that question.
14
Q. Had you
ever looked at that area, because
15
I know you park
your truck right there, have you
16
ever looked at that
area and said to yourself, we
17
got to do something
here to beautify it before the
18
two years that you
just told me about?
19
A. I can't
say for sure. It's very possible.
20
I try to look at
things like that. I know it's
21
important to our
residents, landscaping,
22
beautification.
It's very important to them.
23
Q. Do you
know where I live, by any chance?
24
A. I'm not
for sure where you live. I
25
believe you have
property or properties on Hidden
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
65
1
Harbor
Drive. I don't know if you live there in
2
either
one of them, but I know you have properties
3
there.
I don't know where you live.
4
Q.
Now, when you say the residents wanted
5
that, the hedges, who?
6
A.
I said residents like improvements of that
7
nature,
like landscaping, beautification.
8
Q.
Has anyone complimented you on that?
9
A.
Complimented me, no.
10
Q.
So when you say that the residents like
11
that kind
of stuff --
12
A.
Yes.
13
Q.
-- where
is that
coming from?
14
A.
Well, it's
coming
from my exposure to ARPB
15
meetings,
reviews,
things
of that nature.
16
Q.
Now, before
those
hedges, bushes, whatever
17
they are,
were put
up, if
I park my truck with a
18
banner where the truck
was
facing north and the
19
banner was
facing
south, it
would be visible from
20
Sea Road,
wouldn't
it?
21 A. Yes.
22 Q. Now it's not, though, right?
23 MR. GILL: Object to the form of the
24 question.
25 THE WITNESS: I suppose, depending on
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 where you parked it and where you were on Sea
2 Road that it would be visible. It's possible.
3 BY MR. O'BOYLE:
4 Q. Wasn't that the intention of putting those
5 hedges up to sort of prohibit me from exercising my
6 First Amendment rights?
7 MR. GILL: Objection to the form.
8 MR. GOLDSTEIN: Join.
9 THE WITNESS: No, it was not.
10 BY MR. O'BOYLE:
11 Q. The Town passed a, I think this was
12 called, parking ordinance?
13 A. Yes, yes, I don't know if it was parking,
14 but generally speaking, yes.
15 Q. Okay. And that parking ordinance
16 prohibits non City or Town, whatever you want to
17 call it, vehicles from parking between 7 p.m. and
18 7 a.m.; would that be correct?
19 MR. GILL: Object to the form of the
20 question.
21 MR. GOLDSTEIN: Joined.
22 THE WITNESS: I don't know the answer to
23 the question.
24 BY MR. O'BOYLE:
25 Q. Okay. Do you remember the parking
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
67
1 ordinance?
2
A.
Not in detail. I just know that there was
3
one.
4
Q.
And besides knowing that there was one, do
5
you remember
nothing else about it?
6
A.
No.
7
Q.
Okay. Do you remember a prohibition for
8
parking
in the four spaces out front?
9
MR. GOLDSTEIN: Object to form.
10
MR. GILL: Join.
11
THE WITNESS: I don't know, prohibition,
12
what
that means, but I don't know.
13
BY MR. O'BOYLE:
14
Q.
Okay. You know I had a truck, correct?
15
A.
You have a lovely truck.
16
Q.
Thank you.
17
A.
Or your wife does. I don't know who.
18
Q.
Pardon?
19
A.
Or your wife.
20
Q.
What?
21
A.
Your wife has, I think, a white Ford F-150
22
truck.
23
Q.
I'm sorry, I'm not hearing you.
24
A.
I believe at one time your wife had and
25
titled in her name a white F-150 Ford truck.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1
Q.
How would you know that?
2
A.
I've seen it in a police incident report.
3
Q.
You've seen it, I'm sorry?
4
A.
Police incident report.
5
Q.
Police incident. Okay.
6
And have you ever seen that truck with a
7
banner on
it?
8
A.
Yes.
9
Q.
Okay. And do you remember saying to me
10
you are
tired at looking at that truck?
11
A.
No.
12
Q.
Okay. You don't deny saying that though,
13
do you?
14
A.
I don't remember saying it, so I guess I
15
deny it.
16
Q.
Pardon?
17
A.
I don't remember it, so, I don't know, I
18
guess I'm
denying it. I don't remember saying it.
19
Q.
That's fine.
20
Are you familiar with a comprehensive --
21
and I'm
not going to say I'm saying it right,
22
hopefully
you'll correct me -- comprehensive land
23
use management
or something like that?
24
A.
Comprehensive plan, yes.
25
Q.
Can you say it, please?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 A. Comprehensive plan?
2 Q. Yes, yes.
3 Have you ever looked at that?
4 A. I have on occasion. It's not a document
5 that I use frequently.
6 Q. Have you ever looked at it, the provision,
7 that talks about recreation and talks about
8 parking?
9 A. I've read it. I don't recall it, but I've
10 read everything in the comprehensive plan.
11 Q. I would like to try to jog your memory and
12 that is the comprehensive plan and tell me if you
13 disagree with me, if you would.
14 "The comprehensive plan provides for the
15 parking in the Town Hall to be open to everyone
16 without restriction."
17 MR. GILL: Object to form of the question.
18 THE WITNESS: I don't recall it saying
19 that. I don't know that it does or not say
20 that.
21 BY MR. O'BOYLE:
22 Q. Can you repeat it? Mr. Gill sneezed, I
23 didn't hear you.
24 A. Could you repeat the question, Court
25 Reporter?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
70
1
(The question referred to was read by the
2
reporter
as above recorded.)
3
THE WITNESS: I don't recall that in the
4
comprehensive plan.
5
BY MR.
O'BOYLE:
6
Q.
Do you recall anything about parking in
7
the comprehensive plan?
8
A.
I believe that it talks about beach
9
parking
specifically. Other than that, I do not.
10
Q.
Have you ever been to the beach at night?
11
A.
Well, I can't say I have.
12
Q.
Would you agree with me that other people
13
have?
14
A.
I have no knowledge of that.
15
Q.
Have you ever been on the beach at all?
16
A.
Yes.
17
Q.
And what was the earliest you were there?
18
A.
I don't know the time, but it was sunrise.
19
Q.
Sunrise?
20
A.
Yes.
21
Q.
And would that have been in the winter,
22
the summer, the fall? When?
23
A.
This is embarrassing, but it was Easter
24
time.
25
Q.
That would have been before 7 a.m.,
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
71
1 wouldn't it?
2
A.
I don't know the time.
3
Q.
Could it have been before 7 a.m.?
4
A.
I don't know, Mr. O'Boyle.
5
Q.
You don't even know if it could have been?
6
A.
No.
7
Q.
So am I correct that we can't say that it
8
was after
7 a.m.?
9
A.
I don't know the time.
10
Q.
Okay. You did say Easter, correct?
11
The sky, was it blue, was it dark? What
12
was it?
13
A.
Well, I was there for the sunrise and I
14
don't
recall anything specific.
15
Q.
And what year would this have been?
16
A.
I don't remember. Some time ago.
17
Q.
The land management or land, whatever you
18
called
it, I think you had it right, I had it
19
wrong,
you did know about the parking provision in
20
there,
correct?
21
MR. GILL: Object to the form of the
22
question.
23
THE WITNESS: I know there's a discussion
24
about beach parking. There is an excerpt
25
about beach parking. What it says exactly, I
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
72
1
do
not recall.
2
BY MR.
O'BOYLE:
3
Q.
Okay. The parking ordinance that was put
4
into effect
recently, when I say recently, maybe
5
last couple
of years.
6
A.
Right.
7
Q.
You, as the Town Manager, the CEO,
8
whatever
your role is, would you have borned that?
9
MR. GILL: Object to the form of the
10
question.
11
THE WITNESS: Is that your question?
12
BY MR.
O'BOYLE:
13
Q.
Yes.
14
A.
What do you mean by born?
15
Q.
Been the father of it. You created it.
16
You made
it happen.
17
A.
The parking ordinance?
18
Q.
Yes.
19
A.
No, I did not.
20
Q.
Who did?
21
A.
The attorneys representing the Town.
22
Q.
And when you say attorney representing the
23
Town,
the town attorney?
24
A.
I don't recall which attorney. I think it
25
was our
general counsel, yes.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
73
1 Q. When you say general counsel, you mean
2 Mr. Randolph?
3 A. Yes.
4 Q. And he would be the town attorney,
5 correct?
6 A. Well, the town attorney is the firm of
7 Jones and Foster, is the representative of the firm
8 at our meetings.
9 Q. So I'm clear, is Mr. Randolph the town
10 attorney or is the firm the town attorney?
11 A. I believe the firm is our representation
12 and he represents the firm at our meetings.
13 Q. Can you speak up? I'm sorry.
14 A. I believe our counsel is Jones and Foster.
15 He represents Jones and Foster at most of our
16 meetings.
17 Q. Okay. This lawsuit, putting aside the
18 Sweetapple portion, is First Amendment retaliation.
19 Do you agree that there's been First Amendment
20 retaliation against me?
21 MR. GILL: Object to the form of the
22 question. I would like the question ordered.
23 You can answer, if you can.
24 MR. GOLDSTEIN: Joined.
25 THE WITNESS: I do not believe so.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
74
1 BY MR. O'BOYLE:
2
Q.
What's your definition of First Amendment?
3
MR. GILL: Same objection.
4
I'll mark that to order possibly.
5
THE WITNESS: I don't have an answer to
6
that.
7
BY MR. O'BOYLE:
8
Q.
Do you know?
9
A.
No.
10
Q.
Okay. Fair enough.
11
The five Commissioners: Are they still
12
Mayor Morgan,
Mr. Stanley, Ms. White, Ms. Orthwein
13
and Mr.
Ganger? Are they the five?
14
A.
Yes.
15
Q.
Okay. And at the last meeting on
16
May 13th,
was everybody there?
17
A.
I believe so.
18
Q.
And you were there, of course; am I
19
correct?
20
A.
Yes.
21
Q.
The public records. Is the League of
22
Cities in
favor of the current law or are they
23
against
the current law?
24
A.
Personally, I don't know.
25
MR. GILL: Object to the form of the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
75
1
question.
2
BY MR. O'BOYLE:
3
Q. Pardon?
4
A. Personally, I don't know.
5
BY MR. O'BOYLE:
6
Q. Were you up in Tallahassee with Mr. Ganger
7
speaking before the legislature, or whoever it
was,
8
the Senate, the government?
9
A. No.
10
Q. He was there by himself?
11
MR. GILL: Object to the form of the
12
question.
13
THE WITNESS: I don't know the answer
to
14
that.
15
BY MR. O'BOYLE:
16
Q. Did he come back and report what went
on
17
up there?
18
A. I don't recall. I think at one time
he
19
did report to the commission or made a comment
in
20
regards to it, but as far as a report, I don't
know
21
of such a thing.
22
Q. I'm sorry?
23
A. I don't know of such a report.
24
Q. When I say a report, I'm not talking
about
25
a booklet, I'm talking about, hey, guys, I was
up
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
76
1 in Tallahassee and here is what happened, I just
2 wanted to keep you guys abreast. That kind of
3 report.
4 A. I think so. I don't recall, but I think
5 so.
6 Q. The Town, if I'm recalling correctly, at
7 the end of each meeting or maybe at the beginning
8 of each meeting, better said, during each meeting,
9 the Mayor usually, or I say usually, every time
10 I've been there, he has asked is there anybody who
11 can't make the next meeting. Did you ever hear him
12 say that?
13 A. He asked the general question of upcoming
14 meetings, yes.
15 Q. For the next one.
16 A. The next one is included in the upcoming
17 meetings are several of them.
18 Q. Yes. And he asked that.
19 Do you know what the reason is that he
20 asked that?
21 A. Make sure we have a quorum, I believe.
22 Q. I see.
23 Is there -- I think there's a meeting
24 coming Friday; am I correct?
25 A. Yes.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
77
1
Q.
Okay. Do you anticipate a quorum based
2
upon the
last meeting?
3
A.
Yes.
4
Q.
Do you anticipate any absences
based upon
5
the last
meeting?
6
A.
I don't recall what was said at
the last
7
meeting.
8
Q.
I understand. But my question
was, do you
9
anticipate any absences? You either do
anticipate
10
or you don't anticipate it, I think.
11
A.
I do.
12
Q.
You do anticipate absence?
13
A.
Yes.
14
Q.
Who would that be?
15
A.
I believe Mayor Morgan.
16
Q.
I see. I see. Okay.
17
Mr. Thrasher --
18
A.
Yes, sir.
19
Q.
-- have you ever heard anyone use
my name
20
in a derogatory fashion?
21
MR. GOLDSTEIN: Object to form.
22
MR. GILL: Join.
23
THE WITNESS: I don't recall.
24
BY MR. O'BOYLE:
25
Q.
Have you ever heard anyone call
me a
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 racketeer?
2
A.
I don't recall.
3
Q.
Have you ever heard anyone call me a
4
criminal?
5
A.
I don't recall.
6
Q.
But it's possible? I know you don't
7
recall,
you said that, but just because you don't
8
recall,
obviously that doesn't mean it didn't
9
happen,
correct?
10
A.
I don't remember it happening, so
11
therefore
I don't know.
12
Q.
But if you don't remember it didn't
13
happen,
that doesn't mean it didn't happen, does
14
it?
15
A.
I think it's a hypothetical question to me
16
and I don't
have an answer for you.
17
Q.
I apologize, I'm getting confused.
18
A.
Perhaps we should conclude.
19
Q.
Perhaps. Perhaps.
20
Is there any chance that you heard anybody
21
refer to
me as a criminal?
22
A.
I don't think so, but I don't recall.
23
Q.
Okay. Now, when you say you don't recall,
24
I understand
that.
25
A.
Good.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
79
1
Q.
But that -- what that means to me is you
2
don't
remember, which means to me that if you don't
3
remember,
that doesn't exclude it, that just means
4
you don't
remember and, am I correct, that you just
5
don't
remember?
6
MR. GOLDSTEIN: Object to form.
7
MR. GILL: Join.
8
THE WITNESS: I think your question is
9
confusing
to me.
10
BY MR.
O'BOYLE:
11
Q.
Can you speak up, please?
12
A.
Your question is confusing to me. You're
13
taking
me into your mind thoughts and I -- I don't
14
know what
you think and I don't know what you are
15
theorizing.
I don't remember hearing such a thing.
16
Q.
Have you ever heard of the Coastal Star?
17
A.
Yes.
18
Q.
Tell me what you know about the Coastal
19
Star.
20
A.
It's a local newspaper.
21
Q.
Do you know anyone involved with the
22
Coastal
Star, meaning the reporters, the owners?
23
A.
I know of them.
24
Q.
Okay. Who do you know of?
25
A.
I think there's Mary Fleming maybe. Danny
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1 Moffitt. I know of them. Maybe a couple of others
2 if I could -- I don't remember right now, but those
3 seem to be associated with the paper.
4 Q. Well, you have spoken to Mr. Moffitt on
5 occasion, have you not?
6 A. I have.
7 Q. Public records. What is that -- what are
8 the public records? What's the law, do you know,
9 that guides the public records?
10 A. No.
11 Q. Okay. Have you ever heard of Chapter 119?
12 A. Yes.
13 Q. And you did not know that that was the law
14 that governed public records, of course, beyond the
15 common law?
16 A. I believe your question asked me if I know
17 of the law or about the law. When you ask such a
18 question, not being an attorney, to me, that's a
19 very broad and open area of which I have no
20 knowledge.
21 Q. Okay. Just so I'm clear, you have no
22 knowledge that Chapter 119 in the Florida statutes
23 is what's commonly known as the records law or is
24 what governs the records request?
25 MR. GILL: Object to the form of the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
a
1 question.
2 THE WITNESS: I know that Chapter 119 of
3 the Florida statutes deals and controls and
4 explains the public records concept and
5 requirements.
6 BY MR. O'BOYLE:
7 Q. Okay. Have you ever read Chapter 119?
8 A. I have.
9 Q. Okay. And are there any areas you think
10 are unfair to the Town of Gulf Stream?
11 MR. GILL: Object to the form of the
12 question.
13 I would like to certify that question.
14 THE WITNESS: I trust the courts. I don't
15 have any idea legally whether they are unfair
16 or have any other reason to say that they are
17 unfair. It is the public records law that
18 organizations, public organizations are bound
19 to uphold and obligate themselves to.
20 BY MR. O'BOYLE:
21 Q. Now, of course, you know there's a
22 legislature in Florida, correct?
23 A. Yes.
24 Q. And are you aware that Chapter 119, its
25 content and any revisions to its content, must go
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
E-
1 through the Florida legislature? Are you aware of
2 that?
3 A. Could you repeat the question?
4 Q. Yes.
5 Chapter 119. Was Chapter 119 -- the
6 Florida legislature developed Chapter 119 and that
7 any modifications will be made by the Florida
8 legislature?
9 A. Yes.
10 Q. You are aware of that, correct?
11 A. Yes.
12 Q. And you just brought up you trust the
13 courts. Do you not trust the legislature?
14 MR. GILL: Object to the form of the
15 question.
16 MR. GOLDSTEIN: Joined.
17 THE WITNESS: I have no reason not to
18 trust them. I have no reason not to trust
19 them. That's what they are there for. They
20 are elected officials and I respect them.
21 BY MR. O'BOYLE:
22 Q. Okay. So if the legislature passes a law,
23 as a good citizen of the State of Florida, you
24 would respect their judgment and abide by that law,
25 correct?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 MR. GILL: Object to form of the question.
2 THE WITNESS: I would obligate myself to
3 current written law, yes. I believe that's a
4 responsibility.
5 BY MR. O'BOYLE:
6 Q. Okay. And when you say current written
7 law, you are talking about statutory law, correct?
8 A. Yes.
9 Q. How many records requests has the Town
10 received in the last two years?
11 A. I don't know the exact number. I would
12 say it's around 1,500 to 2,000.
13 Q. And do you have any problems with that
14 number, 1,500, 2,000?
15 MR. GILL: Object to the form of the
16 question.
17 MR. GOLDSTEIN: Joined.
18 THE WITNESS: It is the individual's right
19 to submit public records request at will.
20 BY MR. O'BOYLE:
21 Q. You said it's the individual right to --
22 A. Submit public records requests at will.
23 Q. At will. Okay.
24 So if I submitted 10,000 records
25 requests --
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
a
1 A. Please don't do that.
2 Q. I won't.
3 MR. GILL: That's on the record, he said
4 he's not going to do it.
5 THE WITNESS: I believe you could do that.
6 BY MR. O'BOYLE:
7 Q. If I submitted 10,000 requests --
8 A. Yes.
9 Q. -- how would the Town react?
10 MR. GILL: Object to the form of the
11 question.
12 I would like to mark all these questions
13 about public records and Chapter 119 that I
14 will order.
15 THE WITNESS: How would the Town react?
16 BY MR. O'BOYLE:
17 Q. Yes.
18 A. I don't know.
19 Q. Has anyone in the Town done an analysis to
20 see how much of the legal fees spent -- were spent
21 defending as opposed to, I use the term attacking,
22 if somebody has a better term, that's fine, but
23 whether it be a counterclaim, filing bar
24 complaints, charging my son with UPL, whatever it
25 is. Has anyone ever done that analysis?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
a
1 MR. GILL: Object to the form of the
2 question.
3 THE WITNESS: May I ask you to repeat the
4 first part of his question?
5 (The question referred to was read by the
6 reporter as above recorded.)
7 THE WITNESS: Okay. I don't know what you
8 mean by Town.
9 BY MR. O'BOYLE:
10 Q. Town of Gulf Stream.
11 A. I could not answer that question.
12 Q. Why not?
13 A. Town of Gulf Stream encompasses a thousand
14 residents.
15 Mr. O'Boyle, may I request another break?
16 Q. Absolutely.
17 A. Thank you.
18 Q. Absolutely.
19 (A brief recess was taken, after which the
20 following proceedings were had:)
21 BY MR. O'BOYLE:
22 Q. Mr. Thrasher, I asked you before the
23 break, and I'm sorry, but I'm not clear on your
24 answer, has the Town or anyone in the Town done an
25 analysis as to the defense versus the counterclaims
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
I or the things that fit into one is defending and
2 the other is, I guess, pursuing? I'm not sure of
3 the right term.
4 A. I don't know.
5 Q. You don't know if anyone has done an
6 analysis?
7 A. No.
8 Q. I assume no one has told you that they did
9 an analysis?
10 A. True.
11 Q. Outside of ordinances and resolutions, is
12 it the City or the Town fathers, the five
13 commissioners who set the policies, or is it you?
14 MR. GILL: Object to the form of the
15 question.
16 THE WITNESS: I think it's both on certain
17 possible issues. I just can't recall.
18 BY MR. O'BOYLE:
19 Q. I'm sorry, Mr. Thrasher?
20 A. I believe it's both, but I cannot
21 articulate an example of either of those
22 activities.
23 Q. Did you say activities?
24 A. Activities, yes, as far as setting policy.
25 Q. Okay. Where is the line of demarkation
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
a
1 applicable to
the policy as
set by the Town
2 Manager, the
policy as set
by the Commission?
3 MR.
GILL: Object
to the form of the
4 question.
5 THE WITNESS: I don't have an answer. I
6 don't know.
7 BY MR. O'BOYLE:
8 Q. But you do set policies?
9 MR. GILL: Object to the form of the
10 question.
11 THE WITNESS: I don't know if it would be
12
considered
policies, potentially
policies as
13
it relates
to, say, for example,
the bottled
14
water will
not be positioned in
this area
15 going forward, it will be positioned in this
16 area, and that's the way I might like it to be
17 carried out.
18 BY MR. O'BOYLE:
19
Q.
And when you say the bottled water, you
20
are talking about one of
those big bottles of water
21
and you
might have it on
the left side of the
22
kitchen
and you move it
to the right?
23
A.
Right. Just as
an example of policy that
24
if it's
truly a policy,
defined as a policy,
25
definition of a policy,
that's something I might
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 do.
2 Q. And who would set the policy as to
3 removing signs?
4 MR. GILL: Object to the form of the
5 question.
6 THE WITNESS: I don't know that we have
7 such a policy, but I would not be that person.
8 BY MR. O'BOYLE:
9 Q. The chief of police, who does he report
10 to?
11 A. Well, I believe he reports to just about
12 everybody, the Town Commission, on occasion he can
13 report to me, and, of course, in certain respects
14 aligns himself with the residents of Gulf Stream.
15 Q. But I'm assuming that he has one boss?
16 I say that because if Fred told him yes
17 and Ned told him no, he wouldn't know what to do;
18 where if Fred was his only boss and he said yes,
19 he'll know exactly what to do?
20 A. I don't believe that functionally the
21
chief
reports to anybody but
the commission.
22
Q.
I'm sorry, I didn't
catch that last part.
23
A.
I don't believe he
reports to anybody
24
other
than the Town Commission.
25
Q.
You are talking about the
chief of police?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
I A. Yes.
2 Q. Okay. So when the Town Commission wants
3 something done where the chief's services are
4 involved, how does that work? Can you help me out
5 here?
6 MR. GILL: Object to the form of the
7 question.
8 THE WITNESS: I have no idea what you are
9 referring to, so I don't have an answer to
10 that question.
11 BY MR. O'BOYLE:
12 Q. Well, if somebody in the hierarchy,
13 yourself, the commission, wanted the chief to
14 patrol Hidden Harbor more, there are robberies,
15 whatever the case is, who would give him that
16 directive?
17 A. I don't -- in that regard, in that
18 instance, that example that you just spoke of, I
19 don't believe anybody would give him that
20 directive.
21 Q. I'm sorry?
22 A. I don't believe anybody would give him a
23 directive, it would be his decision as it relates
24 to safety and providing for the well-being of the
25 residence on Hidden Harbor.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1 Q. Then what would the Town fathers, using
2 yourself and the commissioners, what would they --
3 how would they interact with the chief, and I'm
4 sure they've interacted in the past as you may have
5 interacted
in the past as
well, in what connection
6 would they
interact? What
I think I just heard you
7 say is, and
correct me if
I'm wrong, is where
8
there's a
series
of burglaries,
the chief doesn't
9
have to be
told
to go and patrol
more there, but
10
there are
other
areas where I'm
sure that the chief
11 of police is taking direction from someone; would
12 that be fair?
13 MR. GILL: Object to the form of the
14 question.
15
THE
WITNESS:
No, I
don't
think
that's
16
accurate.
As it
relates
to me,
when
there
17
could be
a situation like that,
hypothetical,
18
I would
ask him to investigate
and give me an
19
incident
report, you know, but
when it comes
20
to legal
matters, state laws, I
can't help
21 him.
22 BY MR. O'BOYLE:
23 Q. So then you are the chief's boss, if you
24 ask him to do something?
25 A. No, I didn't say that. I don't believe we
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
91
1
have that line of organization. I ask him to
2
consider
investigating and make the proper lawful
3
decision.
4
Q.
And if he said no, what would happen?
5
A.
He says no.
6
Q.
So that would be the end of it?
7
A.
That would be the end of it.
8
Q.
I see. I see.
9
The town attorney, who I understand it is
10
Mr. Randolph, has he ever given an explanation to
11
you or any of your subordinates as to what Chapter
12
119 means and how to operate within the confines of
13
it?
14
MR. GILL: Object to the form of the
15
question.
16
THE WITNESS: Has he ever done what?
17
BY MR. O'BOYLE:
18
Q.
Has he ever given an explanation as to
19
what it means and how to operate within the
20
confines
of it?
21
A.
The answer to that would be yes.
22
Q.
And when did he do that?
23
A.
I don't recall.
24
Q.
Okay. Was it this year?
25
A.
No.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 Q. Was it in the past three years?
2 A. I don't recall.
3 Q. So it could have been?
4 A. Yes.
5 Q. Longer than three years ago?
6 A. Oh, I -- I believe that during the time,
7 which I don't know when that is from a calendar
8 perspective, but during the time when we created a
9 -- the term escapes me, a temporary committee, it
10 was the ad hoc committee, that we had established
11 an ad hoc committee and he gave instructions to
12 each member in a group setting as to their
13 responsibilities as related to Chapter 119. I
14 don't know when that was.
15 Q. To your knowledge, Mr. Gill is an
16 insurance company lawyer, is that correct?
17 MR. GILL: Object to the form of the
18 question.
19 THE WITNESS: I don't know.
20 MR. GOLDSTEIN: Joined.
21 THE WITNESS: I don't know what Mr. Gill
22 is.
23 BY MR. O'BOYLE:
24 Q. What?
25 A. I don't know what Mr. Gill is.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
93
1
Q.
Let me ask you then a different way. Is
2
the Town paying Mr. Gill's legal fees?
3
A.
We -- I don't know the answer to that. As
4
he sits
here today?
5
Q.
Well, I don't know what you mean by --
6
A.
Well, he's here --
7
Q.
Yes.
8
A.
-- representing his, I guess, his firm on
9
my behalf
and is he -- is the Town paying for that?
10
Q.
That's my question.
11
A.
Directly? Not paying for it directly.
12
Q.
And are they paying for it indirectly?
13
A.
I believe that we purchase insurance from
14
the Florida
Municipal Insurance Trust who by some
15
method
has Mr. Gill here.
16
MR. GILL: Mark all the questions about my
17
retention
for ordering that.
18
BY MR.
O'BOYLE:
19
Q.
There's a, what they call, a Sunshine suit
20
pending;
am I correct?
21
MR. GILL: Object to form of the question.
22
THE WITNESS: I don't know.
23
BY MR.
O'BOYLE:
24
Q.
Okay. Do you remember Mr. Randolph saying
25
that he
was a defendant in the -- what I'm calling
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
a
1 the Sunshine case, I may be calling it wrong, and
2 that his insurance company wanted $50,000 as a
3 deductible and the Town agreed to pay the $50,000;
4 do you remember that?
5
A.
No.
6
MR. GOLDSTEIN: Object to form.
7
BY MR.
O'BOYLE:
8
Q.
Do you remember that Mr. Sweetapple was
9
sued and
it may have been in that same suit, I just
10
don't
remember, and he had a $25,000 deductible and
11
he asked the Town to pay his deductible and the
12
Town agreed
to pay it; do you remember that?
13
MR. GOLDSTEIN: Object to form.
14
MR. GILL: Join.
15
THE WITNESS: I don't recall exactly, no.
16
BY MR.
O'BOYLE:
17
Q.
I'm sorry?
18
A.
I don't recall exactly, no. I don't know.
19
Q.
Do you recall un -exactly?
20
A.
I just don't know. I'll have to say I
21
don't
know.
22
Q.
That's fair. I'm fine with that.
23
Do you know a Patsy Randolph?
24
A.
I know of her.
25
Q.
Okay. What's the difference between
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
95
1 knowing her and knowing of her?
2 A. Well, we're certainly not friends. We're
3 not associates. We don't spend leisure time
4 together. She's not been in my house. I've not
5 been in her house. Cumulative time around here
6 might be four, five hours. So I don't know her,
7 but I know of her.
8 MR. GILL: I would like to mark ordering
9 all the questions about the Sunshine law,
10 Mr. Randolph.
11 BY MR. O'BOYLE:
12 Q. Ms. Randolph, she's an official in the
13 Town, is she not?
14 A. Not that I'm aware of.
15 Q. Okay. You were up on the dais one day and
16 Ms. Randolph was speaking to you; do you remember
17 that at all?
18 A. I don't know that she's ever spoken to me
19 while I'm on the dais.
20 Q. Okay. So would it be untrue, would this
21 statement be untrue that Ms. Randolph told you that
22 we have to find a way to keep Mr. O'Boyle and
23 Mr. O'Hare out of these meetings, meaning the
24 commission meetings?
25 MR. GILL: Object to the form of the
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
1 question.
2 MR. GOLDSTEIN: Joined.
3 THE WITNESS: I know of nothing like that
4 ever taking place or being said.
5 BY MR. O'BOYLE:
6 Q. Okay. So you are saying nothing -- that
7 didn't happen?
8 A. No, and actually I just don't think it
9 ever did take place.
10 Q. Okay. Fair enough.
11 Back to the signs. There were a slew of
12 signs taken from -- I'm going -- I don't know that
13 they always say this name right, Place Au Soleil?
14 A. Place Au Soleil, yes.
15 MR. O'BOYLE: Going forward, Madam Court
16 Reporter, if I can just say "Place", we'll get
17 along a lot faster.
18 BY MR. O'BOYLE:
19 Q. Who directed that?
20 MR. GILL: Object to the form of the
21 question.
22 MR. GOLDSTEIN: Joined.
23 THE WITNESS: It is my recollection, it
24 may not be correct, but I believe I did.
25 BY MR. O'BOYLE:
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 Q. And why did you?
2 MR. GILL: Object to the form of the
3 question.
4 THE WITNESS: Because -
5 MR. GOLDSTEIN: Joined.
6 THE WITNESS: -- those signs were located
7 in the Town right-of-way.
8 BY MR. O'BOYLE:
9 Q. And those signs, if we can go back to that
10 day and we drove around, would they be, the signs,
11 more of the signs of the incumbent, more of the
12 signs of Marty O'Boyle or about even?
13 MR. GILL: Object to the form of the
14 question.
15 THE WITNESS: I really don't recall. I do
16 believe that there were -- I think they were
17 signs of both you and -- I just don't recall.
18 Sorry. I don't know the answer to your
19 question.
20 BY MR. O'BOYLE:
21 Q. Okay. Did you ever read the police
22 report?
23 A. I'm sure I did.
24 Q. And do you remember at all anything it
25 said?
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 A. No.
2 Q. Why would you remove those signs?
3 MR. GILL: Object to the form of the
4 question.
5 THE WITNESS: I thought that they were
6 inappropriately or unallowed placement of
7 signs.
8 BY MR. O'BOYLE:
9 Q. Now, you did see, I assume, the affidavit
10 of Dr. Brody; do you remember that?
11 A. Yes, I do remember reading it. I don't
12 recall it, but I definitely remember him making a
13 statement that I felt was incorrect.
14 Q. And that statement was that you remove the
15 sign from his property and not from the
16 right-of-way?
17 A. Correct.
18 Q. Just generally stated?
19 A. Correct.
20 Q. Now, if we were in Chicago, they'd call
21 that the day of the Chicago massacre.
22 A. Okay.
23 Q. You removed, when I say you, at your
24 direction --
25 A. Yes.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 Q. Many, many signs were removed?
2 MR. GILL: Object to form of the question.
3 MR. GOLDSTEIN: Joined.
4 THE WITNESS: There's a police report.
5 Whatever that police report states, I obligate
6 myself to its accuracy.
7 BY MR. O'BOYLE:
8 Q. Right. But what you said is, if they were
9 removed at your direction?
10 A. That's how I remember it, yes.
11 Q. And if they were removed at your
12 direction, what was your direction?
13 A. I don't recall, but I do believe in part
14 it's stated in the incident report.
15 Q. Wasn't your direction to remove the signs
16 because you told either the chief or Sergeant
17 Halsey?
18 A. Halsey.
19 Q. Halsey, that they were on the
20 right-of-way?
21 MR. GILL: Object to form of the question.
22 THE WITNESS: I don't -- I don't recall.
23 I'll rely on the police report.
24 BY MR. O'BOYLE:
25 Q. To your knowledge, were any of them -- to
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
100
1 your knowledge, were all of them on private
2 property?
3 MR. GILL: Object to the form of the
4 question.
5 THE WITNESS: Were all of them on private
6 property?
7 BY MR. O'BOYLE:
8 Q. Yes.
9 A. I believe there were some on private
10 property and some that were in the right-of-way.
11 Q. Okay. And where do you get that belief?
12 A. It's the distance that the signs were
13 placed from the edge of pavement or the estimated
14 measurement of the placement of those signs from
15 the edge of pavement.
16 Q. Now, when you say from the edge of
17 pavement, if you could speak up a little bit, I
18 would appreciate it, I'm not sure I understand what
19 that means.
20 A. If I recall, and I'll obligate myself to
21 the police incident report, there were measurements
22 taken on each sign as they were located. The
23 measurement was from either the center line of the
24 road or the edge of pavement, whichever was used, I
25 don't recall, but edge of pavement, the distance
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
101
1 where the
pavement ends and grass begins
and the
2 distance
from that area or center line of
road.
3 Q.
Okay. Which one is it?
4 A.
It could be either. It could be
either.
5 Q.
How about if they didn't -- they
could
6 result in
different answers?
7 A.
They materially should not.
8 Q. Why not?
9 A. Mathematically I think it would work out,
10 if you are reading a survey or plat map accurately,
11 it would mathematically work out appropriately.
12 Q. What does the center line of the road have
13 to do with the edge of the right-of-way and the
14 beginning of the real property?
15 MR. GILL: Object to the form of the
16 question.
17 THE WITNESS: Well, the plat maps, if you
18 use the plat maps, establish a right-of-way
19 measurement and so if a person were trying to
20 use a plat map, find out the width of that
21 right-of-way, divided by two, measure from
22 that point over, he would be able to
23 distinguish, generally speaking, whether the
24 sign was located on private property or public
25 property.
Daughters Reporting, Inc.
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1 BY MR. O'BOYLE:
2 Q. Unfortunately, you were speaking just a
3 tad on the low side. Can you go over that with me
4 one more time?
5 A. I believe I was referring to plat maps.
6 Q. Yes, you were.
7 A. Did you hear that?
8 Q. Yes.
9 A. And that they provide a width of the
10 right-of-way and a person could divide that width
11 in two, establishing the center point of the
12 right-of-way, and it would be his beginning point
13 for measurement towards private property.
14 Q. Width of the right-of-way divided by two.
15 Can you tell me what you said after that? I
16 apologize?
17 A. I don't. I would ask her to respond for
18 me.
19 Q. Okay.
20 MR. O'BOYLE: Mr. Thrasher said divided by
21 two.
22 Would you be kind enough to mark this as
23 Thrasher 1.
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 (Plaintiff's Exhibit No. 1, Drawing, was
2 marked for Identification.)
3 BY MR. O'BOYLE:
4
Q. Mr. Thrasher, we
have just
provided to you
5
a document that the court
reporter
marked as
6
Thrasher 1 and I drew that
by hand
based upon my
7
notes from that which you
were just
describing plat
8
map, width, right-of-way,
divide by
two, and so
9
forth. Is that what you are
talking
about?
10
MR. GILL: Object
to form
of the question.
11
THE WITNESS: I think
it's
in part what
12 I'm talking about.
13 BY MR. O'BOYLE:
14 Q. Okay. Can you -- if I give you a red pen,
15 could you draw on there the other part?
16 MR. GILL: I'm going to object to having
17 him draw anything during this deposition. I
18 don't think it's appropriate.
19 MR. O'BOYLE: That's fine.
20 BY MR. O'BOYLE:
21 Q. Tell me, Mr. Thrasher -- we'll do it the
22 hard way. Tell me where you find that deficient.
23 What more would you like to see on there?
24 A. Identify the pavement area, the paved
25 area.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
103
104
1
Q. May I have it back?
2
A. Yes.
3
THE COURT REPORTER:
I'm sorry, is that
a
4
different one?
5
THE WITNESS: He's
just modified that.
6
MR. GILL: Is this
a different exhibit
or
7
the same exhibit?
8
MR. O'BOYLE: I think
it's the same
9
exhibit, but whatever you
want to do.
10
MR. GILL: But you
made changes to the
11
document that was marked
as Exhibit 1,
12
correct?
13
MR. O'BOYLE: Yes,
I did.
14
BY MR. O'BOYLE:
15
Q. Mr. Thrasher --
16
MR. O'BOYLE: And,
by the way, is it
17
Exhibit 1 or Thrasher 1?
18
THE COURT REPORTER:
I have Plaintiff's
19
Exhibit 1.
20
BY MR. O'BOYLE:
21
Q. That is the little
hand sketch we gave
you
22
a few moments ago. You had
said that, I think your
23
words were, the edge of road
or the edge of
24
pavement, something, was not
shown on there and
if
25
you'll notice there are two
additional lines.
Daughters Reporting, Inc.
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1 There were three before, now there are five and
2 those two additional lines are marked edge of
3 pavement?
4 A. Correct.
5 Q. Okay. Tell me how you could tell what is
6 on private property and what is on public property.
7 MR. GILL: Object to the form of the
8 question.
9 THE WITNESS: If a person knew from the
10 plat maps that the overall width of the
11 right-of-way was X --
12 BY MR. O'BOYLE:
13 Q. Excuse me one second. Can we just, for
14 the sake of our discussion here, can we just say
15 instead of X 50 feet or 60 feet?
16 A. Okay.
17 Q. We'll say 50 feet, unless you have another
18 number.
19 A. Yes, 30.
20 Q. Pardon?
21 A. 30 -foot.
22 Q. The whole right-of-way is 30 feet?
23 MR. GILL: Object to the form of the
24 question.
25 THE WITNESS: You asked me what I wanted
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
106
1
to do, so I chose 30 -foot.
2
BY MR. O'BOYLE:
3
Q.
30 -foot works for me. Okay.
4
A.
So the right-of-way is 30 -foot, the
5
pavement
is 20 -foot.
6
Q.
On each side?
7
A.
Ten -foot on each side.
8
Q.
So 30 -foot and 10 -foot pavement, each
9
side?
10
A.
Yes, of the center line.
11
Q.
Okay. Okay.
12
A.
So the property line would -- the private
13
property
line would be 15 -foot from the center line
14
of the road
or -- or five-foot from edge of
15
pavement.
16
Q.
Got you.
17
Where is the center line of the road?
18
MR. GILL: Object to form of the question.
19
THE WITNESS: I don't know.
20
BY MR. O'BOYLE:
21
Q.
So how would you find out what's on
22
private property and what's not?
23
MR. GILL: Object to the form of the
24
question.
25
THE WITNESS: You would estimate the width
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
107
1 of the pavement and go towards the center or
2 measure and divide it by two and then measure
3 over to the center line. Of that center line,
4 you measure to private property.
5 BY MR. O'BOYLE:
6 Q. Where is your starting point?
7 MR. GILL: Object to the form of the
8 question.
9 THE WITNESS: It would be the starting
10 point as I just described. If the pavement is
11 20 -foot, it measured to be 20 -foot, you would
12 measure then ten feet in from the edge of
13 pavement towards the center of the roadway and
14 that would be your beginning point.
15 BY MR. O'BOYLE:
16 Q. Where is the center of the roadway?
17 MR. GILL: Object to form of the question.
18 THE WITNESS: I don't know.
19 BY MR. O'BOYLE:
20 Q. So how are you going to make that
21 measurement?
22 A. It's an estimate.
23 Q. Pardon?
24 A. It's an estimate.
25 Q. It's an estimate.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
W
1 So
it could be
that the Town,
because they
2 didn't know,
according
to you, they didn't
know
3 where the right-of-way
stopped and the
private
4 property began,
it could
be that they
were removing
5 my signs off
of private
property; am I
correct?
6 MR.
GILL: Object
to form of
the question.
7 THE
WITNESS:
It's possible.
8 MR.
GOLDSTEIN:
Joined.
9 THE WITNESS: I don't believe so.
10 BY MR. O'BOYLE:
11 Q. And why don't you believe so?
12 A. Because in the incident report they made
13 sure that if there was ever a close proximity or un
14 -- any situation where it was not definitely clear,
15 they did not remove it.
16 Q. Tell me and, again, this is not my first
17 time, by the way, tell me how you would know that
18 it's definitely clear based upon what you've been
19 telling me so far?
20 A. Some discretion on the police officer's
21 part.
22 Q. But that's not definitive, that's
23 discretionary, isn't it?
24 MR. GILL: Object to form of the question;
25 argumentative, irrelevant.
Daughters Reporting, Inc.
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1 THE WITNESS: It's generally the way that
2 would give you an approximate location of
3 private property line.
4 BY MR. O'BOYLE:
5 Q. So if I'm hearing you correct, and I hope
6 I am, when the signs were taken, there was no
7 definitive way of determining where the property,
8 the private property line was?
9 MR. GILL: Objection to form of the
10 question.
11 THE WITNESS: There was no survey.
12 BY MR. O'BOYLE:
13 Q. That's not what I asked you, though.
14 MR. GILL: Object to the form of the
15 question.
16 THE WITNESS: I don't know.
17 BY MR. O'BOYLE:
18 Q. You don't know what?
19 A. I don't know the answer to your question.
20 Q. Okay. Based upon what you have in front
21 of you, is there a definitive way of determining
22 where the property line begins and where the
23 right-of-way line ends? Is there a definitive way?
24 MR. GILL: Object to the form of the
25 question.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
THE WITNESS: I don't know.
2
BY MR. O'BOYLE:
3
Q.
Okay. The police, are they trained in how
4
to use a
transit, which is an instrument you see
5
the guys
on the highway out there, are they trained
6
in that?
7
A.
No.
8
Q.
Are they trained in how to read a plat
9
map?
10
A.
Formal training, no.
11
Q.
You were the one who instructed that this
12
be done?
13
A.
Yes.
14
Q.
I'm just curious how, what were you
15
thinking,
knowing full well that those police
16
didn't know what they were doing?
17
MR. GILL: Object to the form of the
18
question; argumentative.
19
And I would like to mark that to order
20
later.
21
THE WITNESS: I believe they knew what
22
they
were doing.
23
BY MR. O'BOYLE:
24
Q.
Pardon?
25
A.
I believe they knew what they were doing.
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
ill
1 Q. Okay. Was there a way for the police to
2 determine a definitive property line the "Place"
3 and, if so, how would they have done it?
4 MR. GILL: Objection; asked and answered.
5 THE WITNESS: Approximate.
6 BY MR. O'BOYLE:
7 Q. Okay. And I think that's where we have
8 been in the approximate and that's fine with me.
9 MR. GILL: Mr. O'Boyle, if you're
10 transitioning into another line of
11 questioning, for planning purposes, how much
12 longer do you think you have?
13 MR. O'BOYLE: You ask me that every single
14 time and I can't -- I can't tell you because I
15 honestly don't know.
16 MR. GILL: Okay. Well, how much longer do
17 you think you intend to go?
18 MR. O'BOYLE: How much --
19 MR. GILL: How much longer time -wise do
20 you think you intend to go?
21 MR. O'BOYLE: Well, you just asked me that
22 question.
23 MR. GILL: Do you think you intend to go
24 beyond 6 o'clock?
25 MR. O'BOYLE: I can't answer that
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
112
1 question.
2 MR. GILL: Okay.
I'm just
letting you
3 know that the Town is
not going
to go beyond
4 normal business hours
for this
deposition.
5 MR. O'BOYLE
6 want, Mr. Gill.
You could do anything you
7 MR.
GILL: I'm
just putting you on notice
8 that we're
--
required
9 MR.
O'BOYLE:
You can put me on all the
10 notices you want and --
11 MR. GILL: -- 6 o'clock.
12 MR. O'BOYLE: -- we'll go back to the
13 magistrate and explain to him we have seven
14 hours and that you are disrupting it.
15 MR. GILL: That's the maximum time. It's
16 not the required time for a deposition,
17 Mr. O'Boyle.
18
MR.
O'BOYLE:
You're right, it's not the
19
required
time and I
agree with you it's not,
20
however,
if that's
the time I need and you are
21
going to
deprive me
of it, we'll have to deal
22
with it.
23
MR.
GILL:
Can
you identify what
questions
24
you need
that
will
go beyond another
two hours
25 or hour and a half?
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1 MR. O'BOYLE: The answer is no, I can't.
2 MR. GILL: Okay.
3 MR. O'BOYLE: And if I could, I wouldn't
4 tell you anyway, because I don't want you
5 going out in the hall chatting with the
6 witness, preparing him. I'm not going to
7 allow that and I'm also not going to give you
8 my strategy for the many the times that I've
9 already told you that. I'm going to continue
10 on with the deposition and the moment I'm
11 done, I'm going to tell you.
12 MR. GILL: Okay. 6 o'clock, Mr. O'Boyle.
13 MR. O'BOYLE: You do what you want.
14 As a matter of fact, why don't we get the
15 magistrate on the phone right now.
16 MR. GILL: Okay. Let's put this on the
17 record. Let's put this on the record.
18 I believe the first part of this
19 conversation was on the record before the
20 break. So let's show it's all on there, let's
21 put it on the record.
22 MR. O'BOYLE: That's fine.
23 We are back on the record. Mr. Gill has
24 announced that he and Mr. Thrasher will be
25 walking out of the deposition at 6 p.m.
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1 Hopefully I'll be finished by then. But if
2 I'm not, my intention is to finish and
3 hopefully he'll reconsider whether he is going
4 to walk out of the deposition. And if he does
5 walk out of the deposition, we'll have to deal
6 with it at that time.
7 MR. GILL: And if you are close at 6 to
8 getting done, we can certainly work with that,
9 but to take seven is what we don't agree with.
10 We'll deal with it as it comes, Mr. O'Boyle.
11 BY MR. O'BOYLE:
12 Q. Mr. Thrasher, getting back to the signs
13 for a moment -- getting back to the signs. Are the
14 political signs in the Town, are they government
15 speech?
16 MR. GILL: Object to the form of the
17 question.
18 THE WITNESS: I don't know.
19 BY MR. O'BOYLE:
20 Q. Who does know?
21 MR. GILL: Object to the form of the
22 question.
23 THE WITNESS: Attorney, I guess.
24 BY MR. O'BOYLE:
25 Q. Okay. So you've never spoken to anyone
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1 about that in the Town?
2 MR. GILL: Well, if you are inquiring into
3 conversation with attorneys with regarding
4 pending lawsuits, I will object to privilege.
5 I don't think that's what you are really
6 asking, but just to clarify.
7 BY MR. O'BOYLE:
8 Q. Except for your counsel.
9 A. Could you ask me the question again,
10 please?
11 Q. Yes.
12 MR. O'BOYLE: Would you mind, Madam Court
13 Reporter? I apologize.
14 (The question referred to was read by the
15 reporter as above recorded.)
16 THE WITNESS: About what?
17 BY MR. O'BOYLE:
18 Q. We were, and I don't know if we passed
19 this already, talking about the signs being
20 government speech and I asked you if you ever spoke
21 to anyone in the Town and Mr. Gill, properly
22 raised, excluding attorneys that represent you.
23 A. I don't recall.
24 Q. Okay. Did you ever hear anyone refer to
25 myself and Mr. O'Hare as the O's?
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1
A.
I did not, no.
2
Q.
Do you know a woman named Kelly Avery?
3
A.
I do.
4
Q.
Has anyone in the community, that you know
5
of -- have you ever heard anyone in the community
6
refer to
me as a racketeer?
7
A.
No, not that I recall.
8
Q.
Would it surprise you if Ms. Avery did?
9
A.
Yes.
10
Q.
Have you ever heard anyone in the Town
11
refer to
me as a criminal?
12
A.
No.
13
Q.
Would it surprise you if Ms. Avery did?
14
A.
Yes.
15
Q.
Have you ever heard the Mayor refer to me
16
as a criminal?
17
A.
Not that I recall.
18
Q.
Have you ever heard of the Mayor referring
19
to me as
a racketeer?
20
A.
Not that I recall.
21
Q.
As a man who practices extortion?
22
A.
I don't remember him saying that, no.
23
Q.
Do you remember anyone saying any of those
24
things?
25
A.
No.
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1
Q.
When you decided to, for lack of a better
2
way of saying
it, invade the signs, why did you
3
only do
it at "Place"?
4
MR. GILL: Object to the form of the
5
question.
6
THE WITNESS: To my recollection, we
7
didn't
only do it at -- in that area.
8
BY MR. O'BOYLE:
9
Q.
What is your recollection?
10
A.
We also did it in a core area.
11
Q.
And how many signs did you either relocate
12
or remove
in the core area?
13
A.
I don't recall.
14
Q.
Okay.
15
A.
I believe a police report, incident report
16
states that a number, perhaps, and, if so, I align
17
myself with
that incident report.
18
Q.
And if not, what would you tell me?
19
A.
If not what?
20
Q.
Well, you said you were talking about an
21
incident
report and you said --
22
A.
If there is no such incident report?
23
Q.
If there is no such incident report or if
24
there is
an incident report that doesn't talk about
25
the numbers.
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1
A.
And you want to know what?
2
Q.
I would like to know how many.
3
A.
Oh, I don't recall.
4
Q.
Okay.
5
A.
There were some in the core. I don't know
6
how many.
7
Q.
Okay. And this is in the core we're
8
talking,
right?
9
A.
In the core primarily, yes.
10
Q.
Was it more than ten?
11
A.
I don't recall, Mr. O'Boyle.
12
Q.
In "Place," was it more than 50?
13
A.
No, I don't believe so.
14
Q.
Was it in equal amounts, approximately
15
now, not
exactly, in the core and in "Place"?
16
A.
I don't know. I don't recall.
17
Q.
Who would know?
18
A.
I really don't know.
19
Q.
Okay. How is my reputation in the Town,
20
Mr. Thrasher?
21
MR. GILL: Object to the form of the
22
question.
23
THE WITNESS: I don't know.
24
BY MR. O'BOYLE:
25
Q.
Good?
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1
A.
I don't know.
2
Q.
Did you ever ask Kelly Avery?
3
A.
No, not that I recall.
4
Q.
Does that mean you might have?
5
A.
It means I don't recall, therefore I don't
6
know.
7
Q.
Right. Okay.
8
I asked you a question akin to this. Do
9
you know
what's protected by the First Amendment?
10
MR. GILL: Object to the form of the
11
question.
12
MR. GOLDSTEIN: Joined.
13
THE WITNESS: No.
14
BY MR. O'BOYLE:
15
Q.
Pardon? I'm sorry.
16
A.
No.
17
Q.
Okay. The Town Hall, is that designated
18
as a free
speech zone?
19
MR. GILL: Object to the form of the
20
question.
21
THE WITNESS: I don't know.
22
MR. GOLDSTEIN: Joined.
23
THE WITNESS: I don't know.
24
BY MR. O'BOYLE:
25
Q.
Who would know?
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1 A. I don't know that.
2 Q. Okay. If you don't know that, are there
3 other properties in the Town that are designated as
4 a free speech zone or a voice designated for free
5 speech?
6 MR. GILL: Object to the form of the
7 question.
8 MR. GOLDSTEIN: Joined.
9 THE WITNESS: I don't know.
10 BY MR. O'BOYLE:
11 Q. Do you remember a meeting, a Town
12 Commission meeting, that is, where I came with two,
13 what I'm going to call, large men; do you remember
14 that meeting?
15 A. Could you describe these large men?
16 Q. They were large.
17 A. That's all?
18 Q. One of them was thinner.
19 A. I think your son is large.
20 Q. One was thinner than the other one, but
21 they were big guys. Do you remember that?
22 A. I know you've been in our meetings with
23 big guys. I don't know what you are referring to.
24 Q. Okay. Do you remember at the end of the
25 meeting they were holding posters of your son out
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1 in the, I don't know what you call it, the common,
2 the vestibule, whatever you are going to call it,
3 now you do remember?
4 A. Yes.
5 Q. Do you remember saying to me: "I see you
6 brought your henchmen." These may not be the exact
7 words, by the way, and "when you come around here
8 from now on, you are going to need them." Do you
9 remember that?
10 MR. GILL: Object to the form of the
11 question.
12 I would like to mark this and the previous
13 question about the sign and the son.
14 THE WITNESS: I remember the first part of
15 that statement about something about henchmen,
16 but I never said you'll need them if you ever
17 come back here again.
18 BY MR. O'BOYLE:
19 Q. So you are denying it?
20 A. Yes.
21 Q. And are you sure about that as you are
22 about the veracity of or the truthfulness of your
23 testimony so far today?
24 A. Yes.
25 Q. Okay. That's fine.
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1 Do you agree that a man's property, his
2 home, the old saying is, the home is the castle, do
3 you believe that a man's home should be, I guess
4 should not be intruded upon, might be a good way of
5 saying it?
6 MR. GILL: Object to the form of the
7 question.
8 I would like to mark that question to be
9 ordered.
10 MR. GOLDSTEIN: Joined.
11 THE WITNESS: I don't know what you mean
12 by intruded upon.
13 BY MR. O'BOYLE:
14 Q. Well, if you came to my house and dug a
15 hole in my front yard, you are intruding on my
16 property. If you removed my bricks or certain
17 bricks from the driveway, that's intruding on my
18 property. That's sort of what I mean.
19 MR. GILL: Object to form of the question.
20 I would like to mark that question to
21 order potentially.
22 MR. GOLDSTEIN: Joined.
23 THE WITNESS: I think that has legal
24 ramifications. I'm not capable of answering
25 that question legally.
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1 BY MR. O'BOYLE:
2 Q. Are you in charge of the underground
3 project?
4 MR. GILL: Object to the form of the
5 question.
6 THE WITNESS: No.
7 BY MR. O'BOYLE:
8 Q. Who is?
9 A. I believe the Town Commission is.
10 Q. What is your role in the underground
11 project?
12 A. Very little. I authorize payment. I
13 communicate with the project engineer.
14 Q. Can you speak up? I'm sorry.
15 A. I communicate with the project engineer.
16 I carry out the directives of the commission, if
17 there are any. Something very general.
18 Q. Okay. Are real estate signs more favored
19 in Gulf Stream than other signs?
20 MR. GILL: Object to the form of the
21 question.
22 THE WITNESS: I don't know.
23 BY MR. O'BOYLE:
24 Q. Would anybody know?
25 MR. GILL: Object to the form of the
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1
question.
2
THE WITNESS: I don't know the answer to
3
that
question.
4
BY MR. O'BOYLE:
5
Q.
Will you agree with me, do you not, that
6
there's a
lot of real estate signs in Gulf Stream,
7
probably
more than we've seen in recent years?
8
Would you
agree with that?
9
A.
I don't know that I have any basis for
10
agreeing
with that or disagreeing with that.
11
Q.
Let me ask it a different way.
12
On AlA, are there more real estate signs
13
now than
in the past few years, past three years,
14
five years?
15
A.
Again, I have no basis to render an
16
answer.
17
Q.
Well, you've driven down AlA, have you
18
not?
19
A.
Yes.
20
Q.
All right.
21
MR. GILL: I would like to mark the
22
question
about the real estate signs to
23
possibly
be ordered.
24
BY MR. O'BOYLE:
25
Q.
Is there a civic association in town?
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1
A.
Yes.
2
Q.
Yes?
3
A.
Yes.
4
Q.
Okay. Have you ever been to one of their
5
meetings?
6
A.
Yes.
7
Q.
Why?
8
A.
There was a few years where they wanted me
9
to report on -- give my view of the status of the
10
Town.
11
Q.
Status of the Town you say?
12
A.
Yes, annual meeting. Asked for any
13
comments
that I might render. A couple of times
14
this happened.
15
Q.
Okay. Did you ever hear anybody comment
16
about me
at the civic association meeting?
17
A.
No.
18
Q.
No. Okay.
19
Is the civic association, to your
20
knowledge, a nonprofit?
21
A.
I don't know.
22
Q.
You don't know. Okay.
23
Jones, Foster.
24
A.
Yes.
25
Q.
I'm still confused by this, so please
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1 excuse me. Are they the town attorney or is
2 Mr. Randolph the town attorney?
3 A. I believe the firm of Jones and Foster is
4 the Town's attorney.
5 Q. When did the firm of Jones, Foster become
6 the town attorney?
7 A. I don't know.
8 Q. Okay. Was it recently?
9 A. I don't -- no, it wasn't recently. As far
10 as I know, it was decades ago.
11 Q. So all of this time -- and when I look at
12 the agendas --
13 MR. O'BOYLE: Madam Court Reporter, could
14 you please mark this 2.
15 (Plaintiff's Exhibit No. 2, Minutes of
16 Meeting, was marked for Identification.)
17 MR. GOLDSTEIN: Can someone identify the
18 document for the record?
19 MR. O'BOYLE: If it will help you, I'm
20 only intending to use the first page.
21 MR. GILL: I just want to make sure there
22 isn't something else in there.
23 This appears to be, it purports to be
24 minutes from the regular meeting and public
25 hearing held by the Town Commission of the
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1 Town of Gulf Stream on Friday, December 12th,
2 2014, at 9 a.m. in the commission chambers of
3 the Town Hall, 100 Sea Road, Gulf Stream,
4 Florida.
5 MR. O'BOYLE: If I may, just to correct
6 Mr. Gill, it's not purported to be the
7 minutes, that's on the Town's website as the
6 minutes.
9 BY MR. O'BOYLE:
10 Q. Mr. Thrasher, I am going to direct your
11 attention to Page 1 and I am going to ask you, are
12 they the minutes from the Town?
13 A. They appear to be.
14 Q. Okay. But you have no reason to believe
15 they are not, correct?
16 A. No.
17 Q. And who prepares that document? And I'm
18 focused primarily on the first page. I'm not
19 really interested in anything else.
20 A. Well, this document appears to be signed
21 by Carole Vitale.
22 Q. But isn't the clerk responsible for that
23 document?
24 A. Yes.
25 Q. And that would be Rita Taylor, would it?
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1
A.
Yes.
2
Q.
And how long has Ms. Taylor been with the
3
Town?
4
A.
26, 27 years.
5
Q.
Okay. And who does she say the town
6
attorney
is?
7
MR. GILL: Object to the form of the
8
question.
9
THE WITNESS: On these minutes, it says
10
the town
attorney is John Randolph.
11
BY MR. O'BOYLE:
12
Q.
I'm sorry, I didn't catch you.
13
A.
John Randolph.
14
Q.
She says John Randolph is the town
15
attorney?
16
MR. GILL: Object to the form of the
17
question.
18
THE WITNESS: This document --
19
BY MR. O'BOYLE:
20
Q.
Right.
21
A.
-- indicates town attorney to be John
22
Randolph.
23
Q.
And it more than indicates it, it says it;
24
am I correct?
25
A.
It says town attorney, John Randolph.
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1 Q. Thank you.
2 Okay. Mr. Randolph, his firm is doing a
3 significant amount of work on this litigation.
4 Does the Town's charter allow Mr. Randolph to give
5 the work, the significant amount of work, the
6 hundreds of thousands of dollars of work to other
7 members of his firm?
8 MR. GILL: Object to the form of the
9 question.
10 THE WITNESS: I don't know.
11 BY MR. O'BOYLE:
12 Q. Do you see it as an ethics violation?
13 MR. GILL: Object to the form of the
14 questions.
15 MR. GOLDSTEIN: Joined.
16 THE WITNESS: I don't know.
17 BY MR. O'BOYLE:
18 Q. Okay. Who is Keith Rizzardi, do you know?
19 A. Yes.
20 Q. And?
21 A. He was an attorney with Jones and Foster.
22 Q. I'm sorry?
23 A. He was an attorney with Jones and Foster.
24 Q. I see. Was or is?
25 A. I believe was.
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1 Q. Okay. Where is he now; do you know?
2 A. No.
3 Q• Okay. And Tray Nisarel (ph), who is he?
4 A. He was a paralegal for Jones and Foster, I
5 believe.
6 Q. And how did he interact with the Town of
7 Gulf Stream; can you tell me?
8 MR. GILL: Object to the form of the
9 question.
10 THE WITNESS: He was a spokesperson
11 between Keith Rizzardi and the Town.
12 BY MR. O'BOYLE:
13 Q. I'm sorry, Mr. Thrasher, I didn't hear
14 that.
15 A. He was a spokesperson, a liaison between
16 Jones and Foster and the Town.
17 Q. The public records. The Mayor doesn't
18 like it when we make a public record, does he?
19 MR. GILL: Object to the form of the
20 question.
21 THE WITNESS: I don't know.
22 MR. GOLDSTEIN: Joined.
23 BY MR. O'BOYLE:
24 Q. Okay. Do you remember a statement akin to
25 this; we're going to file a racketeering lawsuit
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1 because we don't
want to die
of a
thousand
cuts?
2 MR.
GILL: Object to
the
form of
the
3 question.
4 THE WITNESS: I don't recall that.
5 BY MR. O'BOYLE:
6 Q. You don't recall him saying that?
7 A. No.
8 Q. Okay. What was the purpose of the
9 racketeering lawsuit; do you know?
10 A. I do not know.
11 Q. Do you know what the basis was for the
12 racketeering lawsuit?
13 A. No.
14
Q.
Who manages the payment of the legal fees?
15
A.
What do you mean by management?
16
Q.
Well, when legal fees come into -- legal
17
invoices
come into my office, there's someone there
18
that goes
through them line by line by line by line
19
and then
pays whatever we think is appropriate.
20
Who does
that at your shop?
21
A.
The process involves more than one person,
22
including
-- and up to writing the check. I am
23
involved
with giving the invoices to the payment
24
person and
authorizing payment.
25
Q.
So your subordinates can authorize these
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1 50 and $60,000 payments?
2 A. No, I am responsible for the processing
3 approval, but they help me with that process.
4 Q. I see.
5
And do you actually
review
the bills, line
6
by line
by line?
7
A.
I think I do, yes.
8
Q.
Okay. Okay. And I
assume
you make
9
changes
where there's errors
and so
forth, correct?
10
A.
Sometimes.
11
Q.
Gerry Richman, you
know who
he is, right?
12
A.
I know of him.
13
Q.
Okay. Now, I'm told
that he is a, using
14
my words, a high horsepower
lawyer.
Would you kind
15
of agree with that?
16
A.
I don't know.
17 Q. Okay. Have you ever heard anything about
18 Gerry Richman?
19 A. Yes.
20 Q. And what have you heard?
21 A. I don't recall. I just know I heard
22 something as presented at a commission meeting
23 about Gerry Richman. I don't think Gerry Richman
24 was present actually, but I think he was on the
25 telephone, a conference call, but I don't recall
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1 what was said.
2 Q. Now, Mr. Morgan at his deposition, when I
3 asked him who was the town attorney, he gave me a
4 litany of names of, I'm going to say, eight to
5 maybe even 12 names.
6 A. Okay.
7 Q. Which is a little shocking to me, but
8 nonetheless, that's what he gave me.
9 A. Well, he's an attorney. He might know
10 better than me, that's for sure.
11 Q. And one of them was Gerry Richman. Does
12 that sound right, that he's the town attorney?
13 MR. GILL: Object to the form of the
14 question.
15 THE WITNESS: I would describe him as one
16 of the Town of Gulf Stream's special
17 attorneys.
18 BY MR. O'BOYLE:
19 Q. Okay. That's fair enough.
20 And he is an agent of the Town, isn't he,
21 by being a special attorney?
22 MR. GILL: Object to form of the question.
23 MR. GOLDSTEIN: Joined.
24 THE WITNESS: I don't know. I don't know.
25 BY MR. O'BOYLE:
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1 Q. Who would know?
2 MR. GILL: Object to the form of the
3 question.
4 THE WITNESS: I don't know. I don't know.
5 BY MR. O'BOYLE:
6 Q. Okay. Do you -- or did you know that
7 Mr. Richman called me an extortionist and published
8 it?
9 A. I don't know.
10 Q. But when you say you don't know, you don't
11 know yes, you don't know no, correct?
12 A. I don't know if he did.
13 Q. Right, that's what I'm saying, you don't
14 know if he did, you don't know if he didn't?
15 A. I don't know.
16 Q. Right. Okay. Fair enough.
17 Now, I mention to you that Mr. Morgan
18 called me a criminal, an extortionist and a
19 racketeer, and I mention to you that Mr. Richman
20 called me an extortionist. Do you think that
21 that's the way a city should talk about their
22 residents?
23 MR. GILL: Move to strike the testimony of
24 the plaintiff. Object to form of the
25 question.
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1 And I would like to mark that to order
2 possibly.
3 MR. GOLDSTEIN: Join in the objection;
4 motion to strike.
5 THE WITNESS: I don't know.
6 BY MR. O'BOYLE:
7 Q. So it may be the way you want to treat
8 your residents?
9 MR. GILL: Object to the form of the
10 question.
11 MR. GOLDSTEIN: Joined.
12 THE WITNESS: I don't know.
13 BY MR. O'BOYLE:
14 Q. Mr. Thrasher, and I'm not trying to give
15 you a hard time, believe me, but if you don't know,
16 I understand that, but if you don't know that means
17 maybe yes and maybe no; would that be correct?
18 A. I just don't know.
19 Q. Well, no, I understand that.
20 A. I don't know if it's yes, I don't know if
21 it's no.
22 Q. But it's got to be one of the two, you
23 agree with me?
24 A. No, I don't understand that logic. I
25 don't know.
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1
Q.
What else could it be?
2
A.
I don't know.
3
Q.
Okay. Fair enough.
4
Do you know Joel Chandler?
5
A.
I know of him.
6
Q.
Have you ever met him?
7
A.
I haven't officially met him. I've been
8
around
where he was.
9
Q.
Have you unofficially met him?
10
A.
I don't think so. He was in our Town Hall
11
once.
12
Q.
Pardon?
13
A.
He was in our Town Hall once.
14
Q.
And did you meet him there?
15
A.
I don't recall that we introduced
16
ourselves
to each other. I could be wrong.
17
Q.
Okay. Did you ever see any plane banners
18
flying
around Gulf Stream?
19
A.
I don't believe I did.
20
Q.
Okay. What is the time limitation to
21
speak
at public meetings? And that's a commission
22
meeting
I'm speaking of.
23
A.
I think there is a section on the agenda
24
for public
comment. I believe it's three minutes.
25
Q.
Okay. Is that uniformly enforced?
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1 A. It's enforced by the Mayor and how he does
2 it, I don't know.
3 Q. Is it uniformly enforced? You are sitting
4 there.
5 A. I don't think so.
6 Q. Okay. When I ask a question, I am told
7 this is a question and answer -- this is not a
8 question and answer period. Have you ever heard
9 that?
10 A. Yes.
11 Q. Yes. And --
12 A. Under public comment section of the
13 agenda.
14 Q. Yes. And is that uniformly enforced,
15 meaning that no one can make public comments?
16 MR. GILL: Object to the form of the
17 question.
18 MR. GOLDSTEIN: Joined.
19 THE WITNESS: That nobody can make public
20 comments?
21 BY MR. O'BOYLE:
22 Q. Well, I'm sorry, I apologize. Is it
23 uniformly enforced where I might go up to the
24 podium and they say to me, this is public input
25 only, not a question and answer period. You've
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1 heard that, have you not?
2 A. I have.
3 Q. And my question is, are there others that
4 they would allow to speak and ask questions?
5 MR. GILL: Object to the form of the
6 question.
7 THE WITNESS: I can't recall that
8 happening. I don't know. Maybe by mistake.
9 I know that sometimes I might try to engage in
10 a conversation, but usually I get a nudge from
11 the attorney.
12 BY MR. O'BOYLE:
13 Q. You have seen Bill Bordman talk and get
14 answers from the Mayor, have you not?
15
A.
I don't recall. Whatever the minutes say
16
I would
align myself with it, but I don't recall.
17
Q.
Well, those minutes, they are not really a
18
replica
of what occurred?
19
A.
Well, then --
20
Q.
Mr. Thrasher, are they?
21
A.
-- whatever the -- we video them, so
22
whatever
that video says, I would align myself with
23
that recording,
but I don't recall.
24
Q.
What's on the minutes you have as part of
25
that, I
think it's Thrasher 2, whatever it was?
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1
A.
Pardon me?
2
Q.
The minutes.
3
A.
Yes.
4
Q.
That's not representative of what was
5
actually
said, was it or is it?
6
A.
It's represented. I think these are
7
called --
they are not verbatim, no.
8
Q.
They are not even close, are they?
9
A.
I believe they are.
10
Q.
Have you ever examined them and juxtaposed
11
the video to the written word?
12
A.
No, I've not done that, but I usually
13
review all
minutes before recommending for final
14
adoption
or acceptance.
15
Q.
Why was I named in a racketeering suit; do
16
you know?
17
A.
No.
18
Q.
Did you ever discuss it with anyone
19
besides your lawyers?
20
A.
I don't think I even discussed it with
21
lawyers.
I'm just not involved with that part of
22
it.
23
Q.
Did you comment upon it, as an example,
24
hey, guys,
this is going to cost us an awful lot of
25
money, and
we can get rid of these records suits
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1 for, pardon the expression, a proverbial ham
2 sandwich, what are we doing?
3 MR. GILL: Object to the form of the
4 question.
5 THE WITNESS: I've never made such a
6 comment.
7 MR. GOLDSTEIN: Joined.
8 THE WITNESS: I never made such a comment.
9 BY MR. O'BOYLE:
10
Q.
Pardon?
11
A.
I never made such a comment.
12
Q.
Do you think the Town is
taking the right
13
approach,
the prudent approach, or
do you think the
14
Town, with
this racketeering suit
and all of their
15
other suits,
that they are trying
to punish me, and
16
although
he's not involved in the
suit, Mr. O'Hare?
17
MR. GILL: Object to form
of the question.
18
MR. GOLDSTEIN: Joined.
19
MR. GILL: Mark that for
possible
20 ordering.
21 THE WITNESS: I will try to answer your
22 question. I'm not really certain I understand
23 your question, but I do believe that, and I do
24 respect and trust our Town commissioners, that
25 in a public forum based on advice of counsel,
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1 they make good and proper decisions that are
2 good and proper and healthy for the Town of
3 Gulf Stream.
4 BY MR. O'BOYLE:
5 Q. I'm sorry, I heard you say proper and
6 healthy, I didn't hear before that, just a few
7 words before that.
8 A. I believe that the decisions they make are
9 proper and are healthy and are appropriate in their
10 decision-making process.
11 Q. The racketeering suit, do you have any
12 idea how much that cost you?
13 A. No, I just look at legal in the group
14 setting.
15 Q. Is it a good decision?
16 MR. GILL: Object to the form of the
17 question.
18 I would like to mark that one.
19
THE
WITNESS: I'm
not
capable of answering
20
that. It's
a decision
that
the Town
21 Commission made.
22 BY MR. O'BOYLE:
23 Q. Okay. Would it make any difference in
24 your eyes if the Town won the racketeering suit as
25 opposed to lost the racketeering suit?
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1 MR. GILL: Object to the form of the
2 question.
3 THE WITNESS: No.
4 BY MR. O'BOYLE:
5 Q. So, either way, you are good with it?
6 A. I believe that I align myself and trust
7 the Town Commission. Their decisions are good and
8 healthy for the Town of Gulf Stream. I trust their
9 decision-making process or I would have, long ago,
10 left the Town of Gulf Stream.
11 Q. Aren't your bosses really the taxpayers?
12 MR. GILL: Object to the form of the
13 question.
14 THE WITNESS: I don't know the answer. I
15 know I don't report to every taxpayer. Some
16 taxpayers probably believe they pay my wages,
17 but I take direction from the commissioners in
18 a group setting, public setting.
19 BY MR. O'BOYLE:
20
Q.
And
the
commissioners
aren't writing
the
21
checks
here,
it's
the Town with
the money from
the
22 taxpayer; am I correct?
23 MR. GILL:
24 question.
Object to the form of the
25 I would like to mark that question.
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1
THE WITNESS: I believe that the revenues
2
that
come from or into the Town is a composite
3
of
ad valorem taxes, state revenues, service
4
fees
and so on.
5
BY MR.
O'BOYLE:
6
Q.
Why do you videotape the meetings?
7
A.
I don't know. I don't know.
8
Q.
Who decided to do it?
9
A.
All of those actions are my responsibility
10
and so
I did, but I don't know why I did.
11
Q.
Back to Gerry Richman for a moment.
12
You're
aware that he was the lead lawyer in the
13
racketeering
suit?
14
A.
I believe that's correct.
15
Q.
Pardon?
16
A.
I believe that's correct.
17
Q.
Who reviews his bills?
18
A.
I do.
19
Q.
Okay. Now, I made a records request for
20
his bills
and all it says is, if I'm remember
21
correctly,
billings for this, 60,000, billings for
22
that, 50,000.
No breakdown at all. How can you
23
approve
something like that?
24
A.
I did.
25
MR. GILL: Object to the form of the
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1
question.
2
THE WITNESS: I did.
3
BY MR. O'BOYLE:
4
Q. You did approve it?
5
A. Yes, I did.
6
Q. How could you?
7
A. No one else did.
8
MR. GILL: Object to the
form of the
9
question.
10
I would like to mark all
these questions
11
about bills.
12
THE WITNESS: He was the
lead counsel and
13
I trusted his billing.
14
BY MR. O'BOYLE:
15
Q. And what you're really saying is, he's
16
incapable of making a mistake?
17
MR. GILL: Object to the
form of the
18
question.
19
MR. GOLDSTEIN: Joined.
20
THE WITNESS: I'm not saying that, but I
21
approved the bills.
22
BY MR. O'BOYLE:
23
Q. I'm not hearing that.
24
A. I'm not saying that, but
I did approve the
25
issuing of a check to Mr. Richman
for whatever it
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1 was. My responsibility.
2 Q. Who directs Mr. Sweetapple?
3 MR. GILL: Object to the form of the
4 question.
5 MR. GOLDSTEIN: Joined.
6 THE WITNESS: I believe Mr. Sweetapple has
7 been hired by the Town to represent the Town,
8 defend the Town, provide certain counsel to
9 the Town, and if there's any direction as it
10 relates to termination, that would be a Town
11 Commission decision, but he is in charge of
12 representing the Town in special cases.
13 BY MR. O'BOYLE:
14 Q. Are you aware that Mr. Sweetapple was
15 heard or overheard, maybe, saying that the Town is
16 going to get my son as a way of getting me? Are
17 you aware of that?
18 MR. GOLDSTEIN: Object to form.
19 MR. GILL: Join.
20 THE WITNESS: Could you repeat the
21 question?
22 BY MR. O'BOYLE:
23 Q. Yes.
24 Mr. Sweetapple was overheard saying that
25 he is going to get my son as a way of getting me.
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1 A. Did I overhear that?
2 Q. No, I didn't ask you if you overheard it.
3 Are you aware of that? Have you heard it?
4 A. No.
5 Q. Anybody told you?
6 A. No, no, no, not that I can recall.
7 Q. Are you aware that, in connection with my
8 son's law firm, that the Mayor, on the official
9 Town stationery, filed Bar complaints against every
10 single one of them?
11 A. I read that in a -- perhaps in this I've
12 read it somewhere.
13 Q. Okay. What do you think of that?
14 MR. GILL: Object to the form of the
15 question.
16 THE WITNESS: I have no thoughts about it.
17 I'm sure he was advised by counsel and it's
18 really not something that I'm legally capable
19 of commenting on or have legal expertise
20 enough to comment on.
21 BY MR. O'BOYLE:
22 Q. Can you give me just a plain old lay
23 opinion?
24 MR. GILL: Object to the form of the
25 question.
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1 I would like to mark the last three
2 questions, please.
3 THE WITNESS: No, I'm not.
4 BY MR. O'BOYLE:
5 Q. No, you can't?
6 A. No, I have no opinion on it.
7 Q. Okay. That's fine.
8 The videotaping. Why did they change it
9 so it doesn't show the commission, but rather
10 showed the audience? And I ask that because I've
11 never seen it before. Do you have any idea why?
12 MR. GILL: Object to the form of the
13 question.
14 THE WITNESS: You have never seen what
15 before?
16 BY MR. O'BOYLE:
17 Q. I have never seen where a meeting was
18 videotaped, but not the commissioners, the
19 audience, I've never seen it.
20 A. I know that we have looked into improving
21 that video system, gotten quotes --
22 Q. I'm sorry, I didn't catch that.
23 THE WITNESS: Could you repeat the
24 question?
25
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1 (The question referred to was read by the
2 reporter as above recorded.)
3 THE WITNESS: You've never seen it. Okay,
4 you've never seen it.
5 BY MR. O'BOYLE:
6 Q. Yes, I guess my question to you is why?
7 A. The podium or pulpit, or whatever it is,
8 is the focus of the video camera, I believe, and in
9 that process it picks up the audience because it's
10 in that direction. We just have a simple -- maybe
11 not as good as yours, I don't know, but it's one
12 directional.
13 Q. Does Mr. Richman have a -- and I'm not
14 sure I'm going to use the right term, retention
15 agreement with the Town, a retainer, whatever it's
16 called?
17 MR. GILL: Object to the form of the
18 question.
19 THE WITNESS: I don't recall. It was an
20 agreement, but I don't know. At this setting,
21 I don't recall what it was.
22 BY MR. O'BOYLE:
23 Q. Wouldn't you need something like that when
24 you are reviewing bills, reviewing information?
25 A. I approved bills as presented.
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1 Q. Okay. Mr. Sweetapple, where did he come
2 from?
3 MR. GILL: Object to the form of the
4 question.
5 MR. GOLDSTEIN: Joined.
6 THE WITNESS: I don't know where he came
7 from.
8 BY MR. O'BOYLE:
9 Q. I mean, did he -- did his car breakdown
10 and he walked in? What happened?
11 A. Oh, I believe he was independent counsel
12 representing Mayor Morgan on some case in regards
13 and for deposition and that's about all I know.
14 Q. Essentially, if I'm hearing you right and
15 you were whispering again, Mayor Morgan brought him
16 in?
17 A. No, not exactly. I do remember having a
18 conversation with the Mayor where he seems pretty
19 good to me, where did you find him. One thing led
20 to another and it was recommended that Town
21 Commission hire him as a special attorney for the
22 Town.
23 Q. Do you know or can you tell me one
24 instance where the Commission voted down the Mayor,
25 and I'm not sure if I'm saying it right, but the
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1 Mayor said I introduce this ordinance and the
2 Commission voted three to two against the Mayor or
3 four to one against the Mayor, assuming the Mayor
4 was going to vote for himself?
5 A. This current Mayor?
6 Q.
Yes.
that
7 A.
No, I don't
recall such a thing.
8 Q.
So they've
-- every time, he's gotten what
9
he wants; is
that
correct?
10
MR.
GILL:
Object to the form of the
11 question.
12 MR. GOLDSTEIN: Joined.
13 THE WITNESS: I believe that they make
14 that decision in a public hearing, public
15 meeting as a composite group.
16 BY MR. O'BOYLE:
17 Q. Have you ever in your office had more than
18 one commissioner at the same time?
19 MR. GILL: I'm going to object and
20 instruct him not to answer. It's an
21 inappropriate question to ask him that,
22 Mr. O'Boyle. That's an inappropriate
23 question. Let's move onto something else.
24 MR. O'BOYLE: I'm not hearing --
25 MR. GILL: I'm objecting and instructing
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1 him not to answer. Move on. It's an
2 inappropriate question. You are simply trying
3 to trick him into admitting something that you
4 know is inappropriate.
5 MR. O'BOYLE: Well, that's what you say.
6 And you are instructing him not to answer?
7 MR. GILL: Yes.
8 MR. O'BOYLE: That's fine.
9 BY MR. O'BOYLE:
10 Q. What is the legal budget this year?
11 A. Fiscal year 115/'16?
12 Q. I guess.
13 A. Current year we're in. The budget is
14 $1 million.
15 Q. And '15/116 ends when?
16 A. September 30th.
17 Q. And do you have that already made for
18 '16/'17? Is that --
19 A. No. I have a draft budget, but I don't --
20 I don't set the budget, it has to be approved. It
21 will be approved at whatever they establish it to
22 be sometime in September of this year for '16/'17.
23 Q. Have you ever been out, off the dais, have
24 you ever been in the same room with two or more
25 commissioners?
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1 A. No, not that I can recall, no.
2 Q. Okay. That's fine.
3 MR. GILL: I would like to mark that
4 question.
5 BY MR. O'BOYLE:
6 Q. Mr. Thrasher, we talked earlier about the
7 Coastal Star and I told you, my recollection was,
8 that the Town said it was taking three and a half
9 hours per record request and if I can find it
10 quickly, I would like to show that you and ask you
11 if it's a true statement.
12 A. Okay.
13 Q. If I can find it quickly.
14 Mr. Thrasher, I am going to show you an
15 article from the Coastal Star from July 30th, 2014,
16 and ask you if the photograph on the first page
17 looks at all familiar.
18 A. Okay.
19 MR. GILL: I'm going to object to you
20 having the witness comment on something that's
21 not marked as an exhibit, so I think it should
22 to be marked as an exhibit.
23 MR. O'BOYLE: I'm not going to do it.
24 MR. GILL: Okay. Then I would ask for
25 copies of this produced to us.
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1 MR. O'BOYLE: Pardon?
2 MR. GILL: I would ask for copies of this
3 to be produced to us.
4 MR. O'BOYLE: It's online.
5 MR. GILL: I want the date. I just want
6 the one that is the same as this.
7 MR. O'BOYLE: Right. If you go online, it
8 gives all the dates.
9 MR. GILL: So you are refusing to produce
10 a copy of this to us?
11 MR. O'BOYLE: I've answered you.
12 If for some reason you can't get it
13 online, I'll be glad to supply it to you, but
14 you can get it online.
15 MR. GILL: I would like copies of all the
16 documents you are showing to the witness
17 during the deposition.
18 MR. O'BOYLE: I hear you.
19 THE WITNESS: Your question is?
20 BY MR. O'BOYLE:
21 Q. Does that picture in the lower left-hand
22 corner, does that ring a bell, familiarize, jog
23 your memory?
24 A. About what?
25 Q. About the picture.
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1 A. Oh, I have seen this sign before. I don't
2 know where it's -- oh, you backed up into a parking
3 space on the south side of the Town Hall?
4 Q. Yes.
5 A. Okay. I've seen this sign.
6 Q. Okay. That's all I wanted to know.
7 A. You want it back? You want to file it?
8 Play with words.
9 Q. Here is the document that I was looking
10 for, Mr. Thrasher.
11 A. Okay.
12 Q. This is from the Coastal Star dated
13
September
3rd, 2014, and it
says this:
"Taylor
14
says the
clerk's office has
logged 4650
hours
15
handling
the public records
request from
O'Boyle
16 and O'Hare". She says: "The office currently is
17 logging about 145 hours per week or 72 percent of
18 its total work time dealing with the request".
19 Now, that's what she says and if we want
20 to do the arithmetic, we can certainly do it, but
21 luckily Mr. O'Hare did the arithmetic. Here is
22 what he says.
23 "These numbers just don't make sense.
24 1252 requests in 18 months is only 2.3 record
25 requests per day. And given that most of these
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1 requests are for a simple
document, the Town's
2 claim that
they have spent
an average of 3.7 hours
3 responding
to each request
is ludicrous".
4 Now, my question to you is, is Mr. O'Hare
5 correct in the 3.7 hours?
6 MR. GILL: I'm going to object to the
7 question and move to strike the testimony of
8 the plaintiff.
9 THE WITNESS: I don't know.
10 BY MR. O'BOYLE:
11 Q. Is it possible that he's correct?
12 A. I don't know.
13 Q. You don't even know if it's possible? Is
14 it impossible?
15 A. No, I don't think so.
16 Q. So, it can be possible and it can be
17 impossible?
18 A. I don't know. I don't know the answer to
19 your question.
20 Q. Okay. You are trying to humor me. I
21 appreciate that.
22 A. No, I'm not trying to humor you. I think
23 I am just laughing at myself.
24 Q. Well, I appreciate that, but it's got to
25 be one of the two, doesn't it?
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1 MR.
GILL: Objection; argumentative.
2 MR.
GOLDSTEIN:
Joined.
3 THE
WITNESS: I
don't have the ability to
4 analyze
what you are
saying and to come up
5 with a conclusion
at
this setting. I'm sorry.
6 BY MR. O'BOYLE:
7 Q. Okay. And what conclusion do you think
8 I'm trying to --
9 A. Whether or not Mr. O'Hare is accurate.
10 Q. Okay. And what you said is you don't know
11 or --
12 A. At this setting, I don't know, yes.
13 Q. Right. So can we agree that it's not
14 impossible that he's accurate?
15
MR.
GILL: Objection;
argumentative.
16
MR.
GOLDSTEIN: Asked
and answered.
17
THE
WITNESS: I don't
know.
18 BY MR. O'BOYLE:
19 Q. Okay.
20 MR. GILL: I would like to order all the
21 questions that started with him reading from
22 -- well, I would like to mark them for
23 possible order all questions starting when he
24 read from the article.
25 BY MR. O'BOYLE:
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1
Q.
Why is the Town trying to punish me?
2
MR. GOLDSTEIN: Object to form.
3
MR. GILL: Join.
4
THE WITNESS: I don't think the Town is
5
trying
to punish you.
6
BY MR.
O'BOYLE:
7
Q.
How many people in the Town have been
8
charged
with racketeering?
9
MR. GILL: Object to the form of the
10
question.
11
MR. GOLDSTEIN: Joined.
12
THE WITNESS: I don't know that I have an
13
answer
to that.
14
BY MR.
O'BOYLE:
15
Q.
Pardon?
16
A.
I don't know. I don't know. I know that
17
it's possibly
one.
18
Q.
And who would that be?
19
A.
I guess that would be you, but I don't
20
know if
that's the charge. I'm not legally able to
21
decipher racketeering situations.
22
Q.
Okay.
23
A.
So there may be nobody in our Town.
24
Q.
So do you know of anyone else in the Town,
25
besides
myself and Chris O'Hare, who have been sued
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1 for RICO?
2 MR. GOLDSTEIN: Form.
3 MR. GILL: Join.
4 THE WITNESS: I don't know. I don't know.
5 BY MR. O'BOYLE:
6 Q. So there may be?
7 A. There may be, yes, I don't know.
8 Q. Okay. Right. Today, how many
9 un -responded to, it's just a little inarticulate,
10 but records requests are there?
11 MR. GILL: Object to the form of the
12 question.
13 I would like to mark that question to
14 potentially have transcribed.
15 THE WITNESS: I don't know. I don't know
16 how many unresponsive -- what the number of
17 unresponsive --
18 BY MR. O'BOYLE:
19 Q. Un -responded to, I would say, but it's not
20 articulate.
21 A. Okay. I don't know the number.
22 Q. Is it substantial?
23 MR. GILL: Object to the form of the
24 question.
25 THE WITNESS: I don't know what you mean
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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1
by
substantial.
2
BY MR.
O'BOYLE:
3
Q.
Okay. Is it more than 50?
4
A.
I would say no, but I'm not sure.
5
Q.
Is it more than ten?
6
A.
I think so, but I'm not sure.
7
Q.
What would make you think so on ten?
8
A.
Oh, I would have to see the document. We
9
keep a
log of those.
10
Q.
Pardon? I'm sorry.
11
A.
We keep a log.
12
Q.
Right.
13
A.
So I would have to see that log.
14
Q.
So it may be less than ten; is that right?
15
A.
It could be.
16
Q.
Okay. Do you agree that all of the issues
17
in connection with this lawsuit and in connection
18
with some
surrounding issues emanate from the
19
records
requests that I have made and the comments,
20
as I just
represented to you Mr. Sweetapple made,
21
that they
emanate from the records request?
22
MR. GILL: Object to form of the question.
23
MR. GOLDSTEIN: Joined.
24
THE WITNESS: I don't think so.
25
BY MR.
O'BOYLE:
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1 Q. Okay. Because these are a lot of issues
2 that, of course, are costing a lot of money.
3 What's driving them on the Town's side?
4 MR. GILL: Object to the form of the
5 question.
6 MR. GOLDSTEIN: Joined.
7 MR. GILL: I would like to order that
8 question.
9 THE WITNESS: I don't know the answer. I
10 think the Town is being advised by counsel.
11 BY MR. O'BOYLE:
12 Q. You say you think?
13 A. I think. I don't know.
14 Q. Is it possible that the Mayor is making
15 these decisions unilaterally?
16 A. No.
17 Q. No?
18 A. No.
19 Q. How do you know?
20 A. I think he -- he would recognize that he
21 is a liaison or spokesperson for the commission,
22 perhaps, in these matters, but that decisions need
23 to be made in public forum.
24 Q. Didn't the Mayor make all or virtually all
25 of the decisions regarding legal issues?
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Fort Lauderdale, Florida 954-755-6401
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1 MR. GILL: Object to the form of the
2 question.
3 MR. GOLDSTEIN: Joined.
4 THE WITNESS: I believe the Mayor is
5 listening to counsel.
6 BY MR. O'BOYLE:
7 Q. I'm sorry, I'm not catching you.
8 A. Is listening, being advised by his special
9 counsel primarily.
10 Q. But isn't he making all the decisions?
11 And I ask this because I've been to the meetings.
12 I've never heard them take a vote, except way back
13 when with Sweetapple, while they had a call with
14 Gerry Richman, but all of the other stuff I just
15 remember that the Mayor made all of the decisions
16 himself. Does that sound right?
17 MR. GILL: Object to the form of the
18 question.
19 BY MR. O'BOYLE:
20 Q. Pardon?
21 A. No.
22 Q. No. Okay.
23 Who did make the -- who did make the
24 decision?
25 A. I believe that the special counsel was
Daughters Reporting, Inc.
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162
1 entrusted in making those decisions by the Town
2 contracting with them.
3 Q. I'm not disputing that, Mr. Thrasher.
4 What I'm saying is, the person directing those
5 lawyers is Mayor Morgan singularly?
6 MR. GILL: Object to the form of the
7 question.
8 THE WITNESS: I don't believe so.
9 BY MR. O'BOYLE:
10 Q. Okay. Then who else is doing it and when
11 are they doing it?
12 A. I believe that special counsel is taking
13 actions on behalf of the Town and in the best
14 interest of the Town.
15 Q. And, again, I'm not disputing that at all.
16 What I'm saying is if the special counsel says to
17 me, as Mayor, and I'm not Mayor, of course, I think
18 we ought to do this, if I agree with them, I'm then
19 going to put it on the agenda and ask the
20 commissioners to vote. I've never seen the
21 commissioners vote ever. Never.
22 MR. GILL: Move to strike the testimony.
23 Is there a question pending?
24 BY MR. O'BOYLE:
25 Q. Yes. Yes.
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Fort Lauderdale, Florida 954-755-6401
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1 The question is: If the Mayor didn't do
2 it singularly in the context of five commissioners,
3 how was it done?
4 MR. GILL: Object to the form of the
5 questioning.
6 MR. GOLDSTEIN: Joined.
7 THE WITNESS: I believe the special
8 counsel is doing these actions in the best
9 interest of the Town.
10
BY MR.
O'BOYLE:
say,
11
Q.
And I'm
not disputing that, but the Mayor
12
-- has
he gotten
commission's approval?
13
A.
I don't
believe the Mayor is doing
14 anything unilaterally.
15 Q. Tell me, when I say unilaterally in the
16 scheme of the commissioners, not in the scheme of
17 outside counsel or any of that stuff, in the scheme
18 of the commissioners --
19 A. Yes.
20
Q. -- the Mayor does not
say,
in
other words,
21
I've
never seen special counsel
say
to
him and I'm
22
guessing
because I've never heard
this,
I want
23
to
-- I think we ought to file
suit
against
Fred
24
and
the Mayor say, I agree with
you,
I'm
going to
25
put
it on the agenda and we're
going
to
take a vote
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 on it. Have you ever seen that?
2 A. I'm not privy to that type of
3 conversation.
4 Q. Well, sure you are, you are sitting on the
5 dais with them.
6 A. Well, the conversation with the Mayor and
7 the attorney, I may not be.
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q. No, I'm not talking about the attorney,
I'm talking about solely the commissioners.
MR. GILL: Mr. O'Boyle, this has been
asked and answered. He answered it. You
don't like his answer. We're pushing 6
o'clock here. Do you have -- are you getting
nearer to being done?
MR. O'BOYLE: I don't know yet.
MR. GILL: Can you tell me how much more
time you think you have?
MR. O'BOYLE: You ask me this every single
deposition and I give you the same answer
every single deposition. I've given you the
answer. If you are going to instruct him not
to answer, go ahead.
MR. GILL: Okay. The deposition is over.
We told you we were going to end at 6. I
think you've asked enough questions. If you
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
164
165
1 feel you
need more
time, we
can certainly
2 discuss that,
but
the deposition
is over.
3 MR.
O'BOYLE:
Well, if
the deposition is
4 over, I'm
going to
tell you
I am going to make
5 a motion
to the magistrate
17
and ask for
6 sanctions
from you
and, Mr.
Thrasher, I will
7 also ask for sanctions from you.
8 MR. GILL: Can you identify what areas of
9 questioning you feel like you have not been
10 able to go into that are relevant to the case?
11
MR. O'BOYLE: You ask me this every
single
12
time. You see where I am right now, what
I'm
13
asking. I am not an experienced lawyer.
I'm
14
doing the very best I can. If it's not
good
15
enough for you, I apologize.
adjourned
16
MR. GILL: Okay.
17
MR. O'BOYLE: I'm doing the best I
can.
18
You want to end the deposition and walk
out,
19
that's your decision.
20
MR. GILL: Okay. We'll take it up
with
21
the magistrate.
22
MR. O'BOYLE: Thank you.
23
MR.
GILL: We will read if
it
gets
24
ordered.
We'll take
a copy if
it's
ordered.
25
(The
deposition
adjourned
at
6:03 p.m.)
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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CERTIFICATE OF OATH
THE STATE OF FLORIDA
COUNTY OF PALM BEACH
I, Felecia Curreri, Registered
Professional Reporter, Notary Public, State of
Florida, certify that WILLIAM THRASHER personally
appeared before me on the 8th day of June, 2016 and
was duly sworn.
Signed this 23rd day of June, 20
166
FELECIA CURRERI, RPR
Notary Public - State of Florida
Accompanied by Counsel: Hudson Gill, Esquire
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1 CERTIFICATE OF REPORTER
2 THE STATE OF FLORIDA
COUNTY OF PALM BEACH
3
4
I, Felecia Curreri, Registered
5 Professional Reporter, do hereby certify that I was
authorized to and did stenographically report the
6 deposition of WILLIAM THRASHER; that a review of
the transcript was requested; and that the
7 foregoing transcript, pages 4 through 165, is a
true and complete record of my stenographic notes.
8
9 I further certify that I am not a
relative, employee, attorney, or counsel of any of
10 the parties, nor am I a relative or employee of any
of the parties; attorney or counsel connected with
11 the action, nor am I financially interested in the
action.
12
13 The foregoing certification of this
transcript does not apply to any reproduction of
14 the same by and means unless under the direct
control and/or direction of the certifying
15 reporter.
16
Dated his 23re day of June, 2016.
17
18
19
Felecia Curreri, RPR
20 Registered Professional Reporter
21
22
23
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
167
ESM
1
PLEASE ATTACH TO THE DEPOSITION OF: WILLIAM
2
THRASHER
3
IN THE CASE OF: O'BOYLE vs. SWEETAPPLE, 2016
4
ERRATA SHEET
5
INSTRUCTIONS: Please read the original transcript
of your deposition and make note of errors or
6
amendments in transcript on this page. DO NOT MARK
on the original transcript itself. Please sign and
7
date this sheet.
8
PAGE LINE ERROR OR AMENDMENT REASON FOR CHANGE
9
10
11
12
13
14
15
16
17
18
19
20
21
Under penalties of perjury, I declare that I have
22
read the foregoing document and that the facts
stated in it are true.
23
Signature of Deponent:
24
Date:
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
169
1 June 23, 2016
2
3
Re: O'BOYLE vs. SWEETAPPLE
4 Deposition of: WILLIAM THRASHER, taken June 8,
2016
5
Dear Mr. Gill:
6
Please take notice that on the 23rd day of June,
7 2016, your client gave his deposition in the above
referred matter. At that time, he did not waive
8 his signature. It is now necessary that he sign
his deposition.
9
10 Please call our office at the
below -listed number to schedule an appointment
11 between the hours of 9:00 a.m. and 4:30 p.m.,
Monday through Friday.
12
If you do not read and sign the
13 deposition within a reasonable time, the original,
which has already been forwarded to the ordering
14 attorney, may be filed with the Clerk of the Court.
If you wish to waive your signature, sign your name
15 in the blank at the bottom of this letter and
return it to us.
16
17 Vy my yo
18 C11—G
19 FELECIA CURRERI, RPR
Daughters Reporting, Inc.
20 954-755-6401
21 I do hereby waive my signature:
22
23 WILLIAM THRASHER
24
25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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165:25
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APPEARANC...
2:1,6,12
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
1
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
2
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33:19,20,21
148:8
canal 8:8
capable 10:24
11:1,5 122:24
141:19 146:18
car 149:9
Carole 127:21
carried 87:17
carry 123:16
case 1:3 4:21,25
5:22 6:4,13 7:9
8:11 61:9
89:15 94:1
149:12 165:10
168:3
cases 38:17
145:12
cast 29:19 30:3
castle 122:2
catch 4:23 14:22
15:3 88:22
128:12 147:22
catching 161:7
category 41:6
center 2:2 34:20
100:23 101:2
101:12 102:11
106:10,13,17
107:1,3,3,13
107:16
CEO 72:7
certain 31:3,6
57:17,17 86:16
88:13 122:16
140:22 145:8
certainly 28:21
95:2 114:8
154:20 165:1
CERTIFICATE
166:1 167:1
certification
167:13
certified 3:18
12:5,10
certify 81:13
166:8 167:5,9
certifying
167:14
chambers 127:2
chance 64:23
78:20
Chandler 136:4
change 13:23
52:7 147:8
168:8
changed 21:7
changes 104:10
132:9
Chapter 80:11
80:22 81:2,7
81:24 82:5,5,6
84:13 91:11
92:13
charge 123:2
145:11 157:20
charged 157:8
charging 84:24
charter 129:4
chatting 113:5
check 131:22
144:25
checks 142:21
Chicago 98:20
98:21
chief 33:10 88:9
88:21,25 89:13
90:3,8,10
99:16
chiefs 89:3
90:23
choose 30:24
chose 27:14
106:1
Chris 34:5
157:25
Christopher
5:24 34:5
circumstances
23:7,9
Cities 26:12,19
27:7 29:14
31:10,16,20
32:3 74:22
citizen 82:23
city 18:1,6 19:21
19:22,24 20:3
20:8 46:18
57:4 66:16
86:12 134:21
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
3
civic 124:25
125:16,19
claim 155:2
clarify 115:6
clear 5:5 13:7
52:21,22 60:16
73:9 80:21
85:23 108:14
108:18
clearly 63:6
clerk 127:22
169:14
clerk's 154:14
client 44:14
169:7
close 33:20,23
108:13 114:7
139:8
Coastal 79:16,18
79:22 152:7,15
154:12
code 6:24 7:8,10
Cole 2:7
college 11:13
color 33:3
come 15:12
33:23 40:15
45:3,20 46:14
47:10 75:16
121:7,17
131:16,17
143:2 149:1
156:4
comes 90:19
114:10
comfortable
62:24 63:19
coming 22:17
29:6 65:13,14
76:24
comment 75:19
125:15 136:24
137:12 139:23
140:6,8,11
146:20 152:20
commenting
146:19
comments
125:13 137:15
137:20 159:19
commission 20:4
20:7,8 26:5
27:13,15 28:3
28:10 29:4,20
29:25 41:18
53:8,10,11,22
54:18 75:19
87:2 88:12,21
88:24 89:2,13
95:24 120:12
123:9,16
126:25 127:2
132:22 136:21
141:21 142:7
145:11 147:9
149:21,24
150:2 160:21
commission's
163:12
commissioner
150:18
commissioners
26:22,22 27:1
31:7 54:15,23
74:1186:13
90:2 140:24
142:17,20
147:18 151:25
162:20,21
163:2,16,18
164:9
committee 92:9
92:10,11
common 80:15
121:1
commonly 80:23
communicate
123:13,15
community
34:21 116:4,5
company 14:25
92:16 94:2
complaint 5:6
6:15 52:1,2,3
complaints 4:22
4:24 5:1 84:24
146:9
complete 167:7
completed 60:14
complimented
65:8,9
composite 143:2
150:15
comprehend
36:24 39:15
comprehensive
68:20,22,24
69:1,10,12,14
70:4,7
concentration
11:21,22
concept 81:4
conclude 78:18
conclusion 156:5
156:7
conducting 51:4
51:5,23
conference
132:25
confines 91:12
91:20
confirm 49:17
52:15
confused 78:17
125:25
confusing 79:9
79:12
connected
167:10
connection 5:16
6:8 26:25
29:21 90:5
146:7 159:17
159:17
consider 52:18
91:2
considered
87:12
constraints
58:22 62:21
content 33:5
36:144:25
45:19,23 46:25
47:4,7,10
81:25,25
context 163:2
continue 43:18
113:9
contract 19:16
contracting
162:2
control 8:7
16:10 17:4,21
18:6 167:14
controls 16:19
81:3
conversation
113:19 115:3
138:10 149:18
164:3,6
conversations
44:13
copies 152:25
153:2,15
copy 32:16
153:10 165:24
core 117:10,12
118:5,7,9,15
corner 56:12
153:22
correct 7:13,21
13:11 15:15
18:22 22:8,12
22:16 23:19,21
23:25 24:15
25:13,19 29:8
33:8 34:18
38:17 45:6
46:7 47:5,19
48:153:9 55:8
55:16 57:5,6
57:11,23 58:1
58:5,1160:8
62:16 64:12
66:18 67:14
68:22 71:7,10
71:20 73:5
74:19 76:24
78:9 79:4
81:22 82:10,25
83:7 90:7
92:16 93:20
96:24 98:17,19
104:12 105:4
108:5 109:5
127:5,15
128:24 132:9
134:11 135:17
142:22 143:14
143:16 150:9
155:5,11
correctly 76:6
143:21
cost 12:3 41:23
42:7 62:10
139:24 141:12
costing 160:2
counsel 3:216:1
6:5 8:12 9:10
9:16 40:17,18
45:4 72:25
73:1,14 115:8
140:25 144:12
145:8 146:17
149:11 160:10
161:5,9,25
162:12,16
163:8,17,21
166:19 167:9
167:10
counterclaim
42:6 84:23
counterclaims
41:20 85:25
counts 5:6
County 26:21,22
27:131:15
32:156:12
166:4 167:2
couple 63:8 72:5
80:1 125:13
course 62:13
74:18 80:14
81:2188:13
160:2 162:17
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
0
court 1:14:1,15
30:17 69:24
96:15 103:5
104:3,18
115:12 126:13
169:14
courts 81:14
82:13
cousin 16:3
covering 7:24
created 36:7
72:15 92:8
criminal 5:22
32:5,8,9,11
50:20 51:5,6
51:24 78:4,21
116:11,16
134:18
criticizing 32:21
32:22,22
Cumulative 95:5
curious 12:9
110:14
current 2 1: 10
74:22,23 83:3
83:6 150:5
151:13
currently 154:16
Curreri 1:23
166:6,16 167:4
167:19 169:19
cuts 131:1
D 3:1
dais 95:15,19
151:23 164:5
Danny 79:25
dark 71:11
date 44:22 153:5
168:7,24
dated 154:12
167:16
dates 15:16
153:8
Daughters 1:16
169:19
day 7:24 29:3
95:15 97:10
98:21 154:25
166:9,13
167:16 169:6
day-to-day
16:21 17:5
20:125:15,21
days 7:7 54:24
deal 52:13
112:21 114:5
114:10
dealing 154:18
deals 81:3
Dear 169:5
death 8:3
decades 126:10
December 61:4
127:1
decide 28:10
43:12
decided 64:11
117:1 143:8
decipher 157:21
decision 57:1
61:13 89:23
91:3 141:15,20
145:11 150:14
161:24 165:19
decision-making
141:10 142:9
decisions 141:1
141:8 142:7
160:15,22,25
161:10,15
162:1
declare 168:21
deductible 94:3
94:10,11
Deerfield 2:3
defend 145:8
defendant 2:6
2:12 93:25
Defendants 1:10
defending 41:7
84:21 86:1
defense 85:25
deficient 103:22
defined 87:24
definitely 19:20
98:12 108:14
108:18
definition 74:2
87:25
definitive 108:22
109:7,21,23
111:2
delegate 26:11
26:18 27:6,9
27:12,18 28:22
30:6,23,24
delegates 26:16
29:1 31:8
delivered 45:8
delivery 8:7,16
demarkation
86:25
demeaning
35:17,21
deny 49:17
68:12,15
denying 68:18
121:19
depart 20:12
depending 65:25
deponent 3:22
168:23
depose 6:5 9:5
deposed 5:8,16
6:1,217:1,3,6
7:15,20,22,25
9:9,12,15
50:22
deposition 1:14
3:22 4:14 6:17
7:24 10:17,18
103:17 112:4
112:16 113:10
113:25 114:4,5
133:2 149:13
153:17 164:19
164:20,23
165:2,3,18,25
167:6 168:1,5
169:4,7,8,13
deprive 112:21
derogatory
77:20
describe 31:17
120:15 133:15
described
107:10
describing 103:7
Description 3:11
designated
119:17 120:3,4
desk 34:20
detail 12:14 67:2
details 7:16
determine 111:2
determined
22:23
determining
109:7,21
developed 82:6
die 131:1
difference 21:13
23:4,13,15
24:4,5 94:25
141:23
different 22:3,15
23:23 28:16
31:5 36:13
64:10 93:1
101:6 104:4,6
124:11
diminish 34:21
direct 3:3 4:10
29:5 30:3
127:10 167:14
directed 96:19
directing 162:4
direction 37:12
90:11 98:24
99:9,12,12,15
142:17 145:9
148:10 167:14
directional
148:12
directive 89:16
89:20,23
directives
123:16
directly 93:11,11
director 8:6,22
8:23 16:16,17
19:13,23,25
20:9 21:2,3,6
21:11,14,18,18
21:2122:5,6,8
22:15 23:2,5,6
23:11,17,18,20
24:12,23 25:11
58:24
directs 145:2
disagree 69:13
disagreeing
124:10
discovery 51:4,6
51:24
discretion
108:20
discretionary
108:23
discuss 53:1
139:18 165:2
discussed 139:20
discussion 71:23
105:14
discussions 35:7
display 47:25
disputing 162:3
162:15 163:11
disrupting
112:14
distance 100:12
100:25 101:2
distinguish
101:23
district 1:1,1 8:6
8:7,9,11,22,23
8:23 9:2 16:10
16:16,17,20
17:3,7,10,10
17:13,21
divide 102:10
103:8 107:2
divided 101:21
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
5
102:14,20
divined 27:12
document 10:17
10:18 69:4
103:5 104:11
126:18 127:17
127:20,23
128:18 154:9
155:1 159:8
168:22
documents
153:16
doing 37:14
62:23 63:19
110:16,22,25
129:2 140:2
162:10,11
163:8,13
165:14,17
dollars 57:21
129:6
Donald 50:2
Dr98:10
draft 151:19
draw 103:15,17
Drawing 3:12
103:1
drew 103:6
Drive 2:2 65:1
driven 124:17
driver 8:7
driveway 122:17
driving 160:3
drove 97:10
drowned 8:8,17
8:19
Duck 50:2
dug 61:11
122:14
duly 4:9 166:10
duties 22:1
duty 26:12
E 1:5 2:2 3:1,9
earlier61:15
62:19,20,21
152:6
earliest70:17
easel 46:3,7,8, 10
easels 45:7,25
46:2
East 2:14
Easter 70:23
71:10
easy 15:21,22
edge 100:13,15
100:16,24,25
101:13 104:23
104:23 105:2
106:14 107:12
effect 72:4
effectively 53:16
effects 59:7
eight 19:6 48:10
133:4
either 32:21
41:18,19 48:25
58:24 60:24
65:2 77:9
86:2199:16
100:23 101:4,4
117:11 142:5
elaborate 26:10
elected 17:16
82:20
Email 2:10,17
emanate 159:18
159:21
embarrassing
70:23
employee 26:14
167:9,10
employees 16:20
16:22 17:3,5
20:2
employment
18:20,23
encompasses
85:13
ends 101:1
109:23 151:15
enforced 136:25
137:1,3,14,23
enforcement
6:25 7:8,11
engage 138:9
engineer 123:13
123:15
entrance 34:7
entrusted 162:1
equal 19:5
118:14
equation 42:13
ERRATA 168:4
ERROR 168:8
errors 132:9
168:5
escapes 92:9
Esquire 2:3,9,16
166:19
Essentially
149:14
establish 54:14
101:18 151:21
established
92:10
establishing
102:11
estate 123:18
124:6,12,22
estimate 62:17
106:25 107:22
107:24,25
estimated
100:13
estimating 62:11
ethics 129:12
event 63:16
everybody 74:16
88:12
exact 18:2134:3
62:2,5 83:11
121:6
exactly 8:146:16
62:14 71:25
88:19 94:15,18
118:15 149:17
Examination 3:3
4:10
examined
139:10
example 19:5
86:2187:13,23
89:18 139:23
exceeded 61:5
excerpt 71:24
exclude 79:3
excluding 48:15
48:17 115:22
excuse 17:8
26:15 43:21
105:13 126:1
exercising 66:5
exhibit 103:1
104:6,7,9,11
104:17,19
126:15 152:21
152:22
Exhibits 3:15
exist 42:7
existing 10:16
expect 10:23
expend 61:17
63:3
expending 62:25
expenditure
58:9,18 63:10
expenditures
35:22,23 41:2
41:3 42:8 59:5
59:6,8,11,13
60:3,6,15,21
expenses 35:15
experienced
165:13
expert32:15
expertise 146:19
explain 27:8
45:12 52:17
112:13
explains 81:4
explanation
91:10,18
exposure 65:14
express 56:5
expression 140:1
extortion 116:21
extortionist
134:7,18,20
eyes 32:7 141:24
F-150 67:21,25
face 8:13
facing 65:18,19
fact28:23 36:1
59:4 113:14
facts 168:22
fair 20:17,22
38:25 74:10
90:12 94:22
96:10 133:19
134:16 136:3
fall 70:22
false 37:23 38:2
38:6,8
familiar 4:18
68:20 152:17
familiarize
153:22
family 13:6,16
13:18 14:7,8,9
14:15,17,19
15:12
far 14:24 45:16
75:20 86:24
108:19 121:23
126:9
fashion 8:2 30:6
34:9 77:20
faster 43:13
96:17
father72:15
fathers 86:12
90:1
FAU 11:16
favor 74:22
favored 123:18
federal 1:17 4:15
feel 61:17 62:24
63:20 165:1,9
fees 60:10 61:5
84:20 93:2
131:14,16
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
M
143:4
feet 105:15,15
105:17,22
107:12
Felecia 1:23
166:6,16 167:4
167:19 169:19
felt 62:18,20
63:16,18 98:13
file 130:25 154:7
163:23
filed 41:8,20
146:9 169:14
filing 84:23
fill 27:20
filled 28:9
final 139:13
finance 11:21,22
19:23,25 20:9
21:1,3,6,11,14
21:18,18,20
22:5,5,8,15
23:1,5,6,10,12
23:16,18,20
24:12,23 25:11
58:24
finances 22:7
financial 12:21
12:22 20:1
25:15
financially
167:11
find 10:19,21,22
10:23 95:22
101:20 103:22
106:21 149:19
152:9,13
finding 10:24
11:1
fine 43:20 53:5
68:19 84:22
94:22 103:19
111:8 113:22
121:25 147:7
151:8 152:2
finish 114:2
finished 114:1
fired 19:14
firm 73:6,7,10
73:11,12 93:8
126:3,5 129:2
129:7 146:8
first 4:9 12:1
66:6 73:18,19
74:2 85:4
108:16 113:18
119:9 121:14
126:20 127:18
152:16
fiscal 60:12,13
151:11
fit 41:6,7,8 43:19
86:1
five 9:3 28:1,5,6
31:7 47:11
74:11,13 86:12
95:6 105:1
124:14 163:2
five-foot 106:14
Fleming 79:25
Floor 2:8
Florida 1:1,18
1:24 2:3,9,15
5:22 6:19
26:11,18 31:16
80:22 81:3,22
82:1,6,7,23
93:14 127:4
166:3,8,17
167:2
flying 136:18
focus 23:8 148:8
focused 127:18
following 44:2
85:20
follows 4:9
forced 20:23,23
Ford 67:21,25
foregoing 167:7
167:13 168:22
form 27:20 28:8
30:8 32:24
34:9,22 35:4
35:18 36:3,14
37:15,25 38:14
39:1,8 41:10
41:24 42:14
45:10 47:12
49:2,9 53:24
55:2,20 56:19
65:23 66:7,19
67:9 69:17
71:2172:9
73:2174:25
75:11 77:21
79:6 80:25
81:11 82:14
83:1,15 84:10
85:1 86:14
87:3,9 88:4
89:6 90:13
91:14 92:17
93:2194:6,13
95:25 96:20
97:2,13 98:3
99:2,21 100:3
101:15 103:10
105:7,23
106:18,23
107:7,17 108:6
108:24 109:9
109:14,24
110:17 114:16
114:21 117:4
118:21 119:10
119:19 120:6
121:10 122:6
122:19 123:4
123:20,25
128:7,16 129:8
129:13 130:8
130:19 131:2
133:13,22
134:2,24 135:9
137:16 138:5
140:3,17
141:16 142:1
142:12,23
143:25 144:8
144:17 145:3
145:18 146:14
146:24 147:12
148:17 149:3
150:10 157:2,9
158:2,11,23
159:22 160:4
161:1,17 162:6
163:4
Formal 110:10
Fort 2:15
forth 10:17 48:1
103:9 132:9
forum 140:25
160:23
forward 87:15
96:15
forwarded
169:13
Foster 73:7,14
73:15 125:23
126:3,5 129:21
129:23 130:4
130:16
four 7:17 67:8
95:6 150:3
framed 52:1,2,3
Frankly 6:7
12:17
Fred 88:16,18
163:23
free 119:18
120:4,4
freehand 29:4
frequently 69:5
Friday 76:24
127:1 169:11
friends 95:2
front 67:8
109:20 122:15
full 110:15
full-time 15:6,7
function 21:19
22:22
functionally
88:20
functions 22:25
23:15
funds 61:18
62:25 63:3
further 167:9
G
Ganger 74:13
75:6
general 21:23
22:124:14
72:25 73:1
76:13 123:17
generalization
38:16
generally 4:19
4:20 5:13
12:25 34:4
62:15 66:14
98:18 101:23
109:1
Gerry 132:11,18
132:23,23
133:11 143:11
161:14
Gershman 6:22
6:24
getting 25:10
39:14 42:10
51:178:17
114:8,12,13
145:16,25
164:13
Gill2:16 19:7
30:8,2131:13
32:14 33:17
34:22 35:4,18
36:4,15 37:15
37:25 38:14
39:1,8,22
41:11,24 42:14
42:2143:3,6
43:16 44:9,11
47:12 49:2,10
50:19,25 51:4
51:9,12,18,21
52:5,16,25
53:6,24 55:2
55:10,20 56:19
65:23 66:7,19
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
67:10 69:17,22
71:2172:9
73:2174:3,25
75:1177:22
79:7 80:25
81:11 82:14
83:1,15 84:3
84:10 85:1
86:14 87:3,9
88:4 89:6
90:13 91:14
92:15,17,21,25
93:15,16,21
94:14 95:8,25
96:20 97:2,13
98:3 99:2,21
100:3 101:15
103:10,16
104:6,10 105:7
105:23 106:18
106:23 107:7
107:17 108:6
108:24 109:9
109:14,24
110:17 111:4,9
111:16,19,23
112:2,6,7,11
112:15,23
113:2,12,16,23
114:7,16,21
115:2,21 117:4
118:21 119:10
119:19 120:6
121:10 122:6
122:19 123:4
123:20,25
124:21 126:21
127:6 128:7,16
129:8,13 130:8
130:19 131:2
133:13,22
134:2,23 135:9
137:16 138:5
140:3,17,19
141:16 142:1
142:12,23
143:25 144:8
144:17 145:3
145:19 146:14
146:24 147:12
148:17 149:3
150:10,19,25
151:7 152:3,19
152:24 153:2,5
153:9,15 155:6
156:1,15,20
157:3,9 158:3
158:11,23
159:22 160:4,7
161:1,17 162:6
162:22 163:4
164:10,16,23
165:8,16,20,23
166:19 169:5
Gill's 93:2
Ginsberg 6:9,14
6:16
give 4:3 11:7
29:4 31:1
89:15,19,22
90:18 103:14
109:2 113:7
125:9 129:4
135:14 146:22
164:19
given 13:19
91:10,18
154:25 164:20
gives 153:8
giving 52:16,25
131:23
glad 153:13
go 10:11 11:13
26:20 29:22,25
31:4 43:13
46:8 50:15,16
51:17,19 52:12
53:8 81:25
90:9 97:9
102:3 107:1
111:17,20,23
112:3,12,24
137:23 153:7
164:22 165:10
goal37:14
goes 14:3 131:18
going 11:8 12:17
20:5 28:7
38:19 39:23,25
42:11,12 43:18
43:18 44:11
51:9,12 52:7,8
52:9,20 53:3,3
54:24 55:9
56:10,12 60:2
68:21 84:4
87:15 96:12,15
103:16 107:20
112:3,21 113:5
113:6,7,9,11
114:3 120:13
121:2,8 127:10
127:11 130:25
133:4 139:24
145:16,25
148:14 150:4
150:19 152:14
152:19,23
155:6 162:19
163:24,25
164:21,24
165:4,4
Goldstein 2:9
19:8 32:16,24
34:24 36:3,14
38:139:3
41:10 42:1,16
42:23 43:5
44:16 45:10
49:4,9 61:22
66:8,2167:9
73:24 77:21
79:6 82:16
83:17 92:20
94:6,13 96:2
96:22 97:5
99:3 108:8
119:12,22
120:8 122:10
122:22 126:17
129:15 130:22
133:23 135:3
135:11 137:18
140:7,18
144:19 145:5
145:18 149:5
150:12 156:2
156:16 157:2
157:11 158:2
159:23 160:6
161:3 163:6
good 4:12 13:23
13:24 42:19
62:17 78:25
82:23 118:25
122:4 141:1,2
141:15 142:5,7
148:11 149:19
165:14
gotten 12:10
147:21 150:8
163:12
governed 80:14
government
75:8 114:14
115:20
governs 80:24
graphics 48:3
grasping 36:10
grass 10 1: 1
greater 59:1,1
greatest 8:16
group 92:12
141:13 142:18
150:15
Groves 16:10
18:6
guess 9:15 12:17
16:24 17:13
18:14 25:6
45:14 61:21
68:14,18 86:2
93:8 114:23
122:3 148:6
151:12 157:19
guessing 61:23
62:1 163:22
guides 80:9
Gulf 4:17 5:3
18:15 20:14,20
20:25 21:24
22:17,18 23:8
24:8,12 27:15
29:10 81:10
85:10,13 88:14
123:19 124:6
127:1,3 130:7
133:16 136:18
141:3 142:8,10
guy 8:16
guys 43:8 75:25
76:2 110:5
120:21,23
139:24
H
H 3:9
H -O -T 13:8
half 7:7 38:12,21
42:13 48:10
53:14 112:25
152:8
hal132:20 33:11
33:14 46:18,19
46:22 50:10,11
50:12,14,18
56:7,12 69:15
113:5 119:17
127:3 136:10
136:13 154:3
Halsey 99:17,18
99:19
ham 140:1
hand 10:5 48:10
103:6 104:21
handle 22:7,24
handling 154:15
happen 72:16
78:9,13,13
91:4 96:7
happened 15:18
31:4 46:17
76:1 125:14
149:10
happening 78:10
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
D
138:8
Harbor 65:1
89:14,25
hard 103:22
135:15
he'll 88:19 114:3
head 60:13
healthy 141:2,6
141:9 142:8
hear 8:15 23:10
50:9 51:15
69:23 76:11
102:7 115:24
125:15 130:13
141:6 153:18
heard 15:126:15
36:22 60:8
77:19,25 78:3
78:20 79:16
80:1190:6
116:5,10,15,18
132:17,20,21
137:8 138:1
141:5 145:15
146:3 161:12
163:22
hearer 16:25
hearing 6:25 7:8
54:15 55:8
67:23 79:15
109:5 126:25
144:23 149:14
150:14,24
hedges 56:10,11
58:2161:10,20
63:7,9,10,16
65:5,16 66:5
held 126:25
help 7:12 16:3
37:23 38:3,7
42:1162:7
89:4 90:20
126:19 132:3
helping 59:17
henchmen 121:6
121:15
hero 32:4
hesitant 44:20
44:21
hey 75:25
139:24
Hgill@jambg....
2:17
Hidden 64:25
89:14,25
hierarchy 89:12
high 36:17,25
37:20 56:9
59:5 132:14
higher 60:11,11
highway 1:17
110:5
hire 149:21
hired 9:1 17:17
145:7
hoc 92:10,11
Hochman 2:14
hold 25:12
holding 120:25
hole 61:11
122:15
home 32:4 122:2
122:2,3
honestly 111:15
honor 31:4
hope 109:5
hopefully 68:22
114:1,3
hoping 59:12
horsepower
132:14
hot 13:2,4,7,9
hour 53:14,14
112:25
hours 38:12,21
95:6 112:4,14
112:24 152:9
154:14,17
155:2,5 169:11
house 95:4,5
122:14
Hudson 2:16
166:19
humor 155:20
155:22
hundreds 129:6
hypothetical
78:15 90:17
idea 32:6 40:8,9
50:6,6 53:15
53:15 81:15
89:8 141:12
147:11
Identification
103:2 126:16
identify 103:24
112:23 126:17
165:8
illegal36:6
illustration
47:25
Immediately
50:16
important 64:21
64:22
impossible
155:14,17
156:14
improved 63:25
64:5,7,7
improvement
63:17
improvements
65:6
improving
147:20
inaccurate 41:12
41:15
inappropriate
150:21,22
151:2,4
inappropriately
98:6
inarticulate
158:9
incapable
144:16
incident 68:2,4,5
90:19 99:14
100:21 108:12
117:15,17,21
117:22,23,24
include 17:11
included 76:16
including 34:19
131:22
incorrect 98:13
increase 36:7
incumbent
97:11
independent
149:11
indicates 128:21
128:23
indirectly 93:12
individual 83:21
individual's
83:18
individually
42:2,5
information
25:6 37:22
148:24
inhouse 22:24
input 137:24
inquire 44:13
inquiring 115:2
inside 46:18
install 57:1
installed 56:9,17
56:18 57:10,13
57:20
instance 89:18
149:24
instruct 44:12
51:16,19 52:10
52:12 150:20
164:21
instructed
110:11
instructing
150:25 151:6
instruction
61:14
instructions
92:11 168:5
instrument
110:4
insurance 92:16
93:13,14 94:2
intend 111:17,20
111:23
intending
126:20
intention 66:4
114:2
interact 90:3,6
130:6
interacted 90:4
90:5
interest 162:14
163:9
interested
127:19 167:11
interrupt 17:9
interviewed 21:8
introduce 150:1
introduced
136:15
intruded 122:4
122:12
intruding
122:15,17
invade 117:2
investigate
90:18
investigating
91:2
invoices 131:17
131:23
involved 8:2
21:19 79:21
89:4 131:23
139:21 140:16
involvement
8:21
involves 131:21
irrelevant
108:25
issues 86:17
159:16,18
160:1,25
issuing 144:25
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
0
IT&T 12:1,2,3
12:16 13:21
item 29:21 35:14
35:23 42:8
58:4,7,13,16
60:10
items 25:21
29:21
jesting 29:24
job 10:14 12:1
16:9,13 20:13
20:14,20 21:8
25:11
jobs25:10
Joel 136:4
jog 69:11 153:22
John 128:10,13
128:14,21,25
Johnson 2:13
Join 36:4,15
41:1149:10
66:8 67:10
77:22 79:7
94:14 135:3
145:19 157:3
158:3
Joined 19:8
34:24 38:1
39:3 42:1,16
42:23 43:5
49:4 66:21
73:24 82:16
83:17 92:20
96:2,22 97:5
99:3 108:8
119:12,22
120:8 122:10
122:22 129:15
130:22 133:23
135:11 137:18
140:7,18
144:19 145:5
149:5 150:12
156:2 157:11
159:23 160:6
161:3 163:6
Jones 73:7,14,15
125:23 126:3,5
129:21,23
130:4,16
JOSHUA 2:9
Joshua.goldst...
2:10
judge 52:13
judgment 82:24
July 152:15
June 1:15 166:9
166:13 167:16
169:1,4,6
justification
40:25
juxtaposed
139:10
keep 59:20 76:2
95:22 159:9,11
Keith 129:18
130:11
Kelly 116:2
119:2
kept 28:7
kind 30:14 65:11
76:2 102:22
132:14
Kinkos 47:11
Kissane 2:7
kitchen 87:22
knew 56:2 105:9
110:21,25
know 4:21,21
5:24 6:4,4,13
6:23,25 8:13
9:14 10:9,11
10:18 11:2
15:11 16:7
18:21 19:9,17
21:7,16 23:14
27:8 29:9
30:12 31:15,15
32:8 33:18,19
34:25 35:20
37:4 38:9,15
39:4,20,25
41:15,19,23
42:6,17,24
43:145:21,23
45:24 46:6,19
47:7,17,20,21
47:22,23 48:1
48:6,23,25
49:5 50:151:8
52:5,6,6 53:17
54:1,8,10,12
55:4,7,15,19
56:10,14 58:8
59:5 62:2,5
63:12,21,23
64:13,15,20,23
65:1,2,3 66:13
66:22 67:2,11
67:12,14,17
68:1,17 69:19
70:18 71:2,4,5
71:9,19,23
74:8,24 75:4
75:13,20,23
76:19 78:6,11
79:14,14,18,21
79:23,24 80:1
80:8,13,16
81:2,21 83:11
84:18 85:7
86:4,5 87:6,11
88:6,17,19
90:19 92:7,14
92:19,21,25
93:3,5,22
94:18,20,21,23
94:24 95:6,7
95:18 96:3,12
97:18 106:19
107:18 108:2,2
108:17 109:16
109:18,19
110:1,16
111:15 112:3
114:18,20
115:18 116:2,4
118:1,2,5,16
118:17,18,23
119:1,6,9,21
119:23,25
120:1,2,9,22
120:23 121:1
122:11 123:22
123:24 124:2,9
125:21,22
126:7,10
129:10,16,18
130:1,21 131:9
131:10,11
132:11,12,16
132:21 133:9
133:24,24
134:1,4,4,6,9
134:10,11,11
134:12,14,14
134:15 135:5
135:12,15,16
135:18,20,20
135:25 136:2,4
136:5 137:2
138:8,9 139:16
142:14,15
143:7,7,10
147:20 148:11
148:20 149:6
149:13,23
151:4 154:2,6
155:9,12,13,18
155:18 156:10
156:12,17
157:12,16,16
157:16,20,24
158:4,4,7,15
158:15,21,25
160:9,13,19
164:15
knowing 67:4
95:1,1 110:15
knowledge 70:14
80:20,22 92:15
99:25 100:1
125:20
known 80:23
L
L 3:20
lack 117:1
Lakes 2:8
land 68:22 71:17
71:17
landscaping
64:2165:7
large 120:13,15
120:16,19
Lauderdale 2:15
laughing 155:23
law 55:1,7,13,18
56:6 74:22,23
80:8,13,15,17
80:17,23 81:17
82:22,24 83:3
83:7,7 95:9
146:8
lawful 91:2
laws 90:20
lawsuit 7:15
51:14 52:18
53:2 73:17
130:25 131:9
131:12 159:17
lawsuits 41:19
115:4
lawyer 92:16
132:14 143:12
165:13
lawyers 139:19
139:21 162:5
lay 146:22
lead 143:12
144:12
league 26:12,16
26:18 27:6
29:7,13,13
31:10,16,16,20
32:1,2 74:21
learn 42:20 43:2
leave 13:1,21
19:12
led 149:19
left 13:16 20:16
87:21 142:10
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
10
left-hand 153:21
legal 9:10 10:6
35:14,22,23
36:7,12,17,20
36:25 37:19
41:2,3 42:9
57:2158:4,7
58:13,23,25
59:5,13 60:10
61:5 84:20
90:20 93:2
122:23 131:14
131:16,16
141:13 146:19
151:10 160:25
legally 81:15
122:25 146:18
157:20
legislature 75:7
81:22 82:1,6,8
82:13,22
leisure 95:3
let's 11:15 23:8
28:5 40:5 46:6
113:16,17,20
113:20 150:23
letter 169:15
letting 112:2
level 16:18 17:2
17:4
liaison 130:15
160:21
liked 13:22
limitation
136:20
line 3:18 12:4
35:14,23 42:8
53:158:3,7,13
58:16 59:7
60:10 86:25
91:1 100:23
101:2,12
106:10,12,13
106:13,17
107:3,3 109:3
109:8,22,23
111:2,10
131:18,18,18
131:18 132:5,6
132:6 168:8
lines 48:15,16,17
48:20 104:25
105:2
listening 63:14
161:5,8
litany 133:4
litigation 129:3
little 8:5 10:13
11:9,9 58:19
60:6,14 62:6
100:17 104:21
123:12 133:7
158:9
five 64:23,24
65:1,3
lived 15:11
lobby 33:14 34:1
34:7 48:20
local 79:20
located 97:6
100:22 101:24
location 109:2
locations 34:19
log 159:9,11,13
logged 154:14
logging 154:17
logic 135:24
long 7:24 17:20
18:8 21:5 27:4
27:17 53:12
128:2 142:9
longer 92:5
111:12,16,19
look 37:9 64:3
64:20 126:11
141:13
looked 48:6 64:3
64:3,4,14,16
69:3,6 147:20
looking 68:10
154:9
looks 152:17
lost 62:6 63:11
141:25
lot 32:20 43:13
96:17 124:6
139:24 160:1,2
louder 11:9
lovely 67:15
low 102:3
lower 153:21
Loxahatchee
16:9,11 17:21
18:5 19:12
luckily 154:21
ludicrous 155:3
Madam 30:17
96:15 115:12
126:13
magistrate
112:13 113:15
165:5,21
maintenance
16:19 20:3
making 18:16
52:22 98:12
144:16 160:14
161:10 162:1
man 116:21
man's 122:1,3
management
11:20 68:23
71:17 131:15
manager 21:4,9
21:12,15,20
22:10,15 23:5
23:7,11,12,17
23:19,24 24:8
25:9,12,17,20
26:1,2 30:5
53:18 58:25
72:7 87:2
managers 21:17
22:1,2,4
manages 131:14
manufacturing
12:4
map 101:10,20
103:8 110:9
maps 101:17,18
102:5 105:10
mark 39:22
55:11 74:4
84:12 93:16
95:8 102:22
110:19 121:12
122:8,20
124:21 126:14
135:1 140:19
141:18 142:25
144:10 147:1
152:3 156:22
158:13 168:6
marked 103:2,5
104:11 105:2
126:16 152:21
152:22
Martin 1:5 2:2
4:13,15 5:23
6:20 34:4 49:7
Marty 97:12
Mary 79:25
massacre 98:21
materially 101:7
mathematically
101:9,11
matter 4:14,18
36:1 113:14
169:7
matters 5:17
90:20 160:22
maximum
112:15
Mayor 1:8 32:22
74:12 76:9
77:15 116:15
116:18 130:17
137:1 138:14
146:8 149:12
149:15,18,24
150:1,2,3,3,5
160:14,24
161:4,15 162:5
162:17,17
163:1,11,13,20
163:24 164:6
MBA 11:16,18
11:20
mean 4:20 10:19
17:8 19:14
24:20 29:5,9
42:5 56:15
61:1172:14
73:179:8,13
85:8 93:5
119:4 122:11
122:18 131:15
149:9 158:25
meaning 50:10
79:22 95:23
137:15
means 32:7
67:12 79:1,2,3
91:12,19
100:19 119:5
135:16 167:14
meant 5:5 34:21
measure 101:21
107:2,2,4,12
measured
107:11
measurement
100:14,23
101:19 102:13
107:21
measurements
100:21
meet 136:14
meeting 3:13
26:19 27:10
28:25 29:11,17
29:18 30:1
41:1 50:12,14
52:15 53:9,10
54:18 74:15
76:7,8,8,11,23
77:2,5,7
120:11,12,14
120:25 125:12
125:16 126:16
126:24 132:22
136:22 147:17
150:15
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
11
meetings 20:4,8
26:5 31:5
65:15 73:8,12
73:16 76:14,17
95:23,24
120:22 125:5
136:21 143:6
161:11
megaphone
59:22
member 41:18
92:12
members 15:12
129:7
memory 7:12
69:11 153:23
men 120:13,15
mention 134:17
134:19
met 136:6,7,9
method 93:15
mic 59:24
Michelle 2:3
Mickey 49:24
million 57:21
151:14
mind 11:8 24:13
63:8,24 79:13
115:12
minutes 3:13
126:15,24
127:7,8,12
128:9 136:24
138:15,17,24
139:2,13
mischaracteri...
30:9
missed 18:18,19
18:22
missing 19:6
mistake 138:8
144:16
mistaken 40:10
44:19 45:24
misunderstood
61:10
modifications
82:7
modified 104:5
Moffitt 80:1,4
molded 25:11
moment 26:7
113:10 114:13
143:11
moments 53:14
104:22
Monday 169:11
money 42:12
61:16 139:25
142:21 160:2
months 154:24
Morgan 1:9 2:12
74:12 77:15
133:2 134:17
149:12,15
162:5
motion 135:4
165:5
Motorola 12:20
13:1,12,25
mounted 45:7
47:18
Mouse 49:25
mouth 47:2
move 40:5 53:4
61:22 87:22
134:23 150:23
151:1 155:7
162:22
municipal22:1
93:14
municipalities
24:20 29:7
Murdoch 2:13
N 3:1,20
name 4:12 28:19
67:25 77:19
96:13 169:14
named 116:2
139:15
names 133:4,5
nature 10:7
27:1165:7,15
near 15:11
nearer 164:14
necessarily
28:10
necessary 169:8
Ned 88:17
need 36:7,19
37:18 62:22
63:7 112:20,24
121:8,16
148:23 160:22
165:1
needed 9:1
22:24 62:19
never 29:25
114:25 121:16
140:5,8,11
147:11,14,17
147:19 148:3,4
161:12 162:20
162:21 163:21
163:22
newly 9:1
Newport2:2
news 37:22
42:10
newspaper
34:20 35:10,16
37:2,7 39:24
42:19 79:20
nexus 35:13
nice 62:24
night 50:1153:9
70:10
Nisarel 130:3
non 66:16
nonprofit
125:20
normal23:7,9
112:4
north 1:17 34:7
65:18
northeast 56:11
nose 33:15
Notary 1:24
166:7,17
note 18:16 168:5
notes 57:5 103:7
167:7
notice 104:25
112:7 169:6
notices 112:10
nudge 13 8: 10
number 4:21
17:25 29:1
62:3,5 83:11
83:14 105:18
117:16 158:16
158:21 169:10
numbers 18:14
18:24 19:4
117:25 154:23
O
O 3:20
O'Boyle 1:5 2:2
3:3 4:11,13,15
5:23 6:20
19:1128:2
30:17 31:9,18
32:18 33:4,22
34:4 35:2,9,24
36:9,2137:21
38:4,18 39:6
39:12 40:2
41:14 42:4,18
42:25 43:8,20
43:21,23,25
44:3,15 45:11
47:16 49:6,8
49:12 50:19,23
50:25 51:2,7,8
51:11,16,19
52:5,20 53:5,7
54:3,7 55:6,14
55:22 56:22
61:25 66:3,10
66:24 67:13
69:2170:5
71:4 72:2,12
74:1,7 75:2,5
75:15 77:24
79:10 81:6,20
82:2183:5,20
84:6,16 85:9
85:15,21 86:18
87:7,18 88:8
89:1190:22
91:17 92:23
93:18,23 94:7
94:16 95:11,22
96:5,15,18,25
97:8,12,20
98:8 99:7,24
100:7 102:1,20
103:3,13,19,20
104:8,13,14,16
104:20 105:12
106:2,20 107:5
107:15,19
108:10 109:4
109:12,17
110:2,23 111:6
111:9,13,18,21
111:25 112:5,9
112:12,17,18
113:1,3,12,13
113:22 114:10
114:11,19,24
115:7,12,17
117:8 118:11
118:24 119:14
119:24 120:10
121:18 122:13
123:1,7,23
124:4,24
126:13,19
127:5,9 128:11
128:19 129:11
129:17 130:12
130:23 131:5
133:18,25
134:5 135:6,13
137:21 138:12
140:9 141:4,22
142:4,19 143:5
144:3,14,22
145:13,22
146:21 147:4
147:16 148:5
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
12
148:22 149:8
150:16,22,24
151:5,8,9
152:5,23 153:1
153:4,7,11,18
153:20 154:15
155:10 156:6
156:18,25
157:6,14 158:5
158:18 159:2
159:25 160:11
161:6,19 162:9
162:24 163:10
164:10,15,18
165:3,11,17,22
168:3 169:3
o'clock 111:24
112:11 113:12
164:13
O'Hare 5:24 9:5
9:9,12 34:5,5
95:23 115:25
140:16 154:16
154:21 155:4
156:9 157:25
O's 115:25
OATH 166:1
object30:8
32:24 34:22
35:4,18 36:3
36:14 37:15,25
38:14 39:1,8
41:10,24 42:14
42:2144:11
45:10 47:12
49:2,9 53:24
55:2,10,20
56:19 65:23
66:19 67:9
69:17 71:21
72:9 73:21
74:25 75:11
77:2179:6
80:25 81:11
82:14 83:1,15
84:10 85:1
86:14 87:3,9
88:4 89:6
90:13 91:14
92:17 93:21
94:6,13 95:25
96:20 97:2,13
98:3 99:2,21
100:3 101:15
103:10,16
105:7,23
106:18,23
107:7,17 108:6
108:24 109:14
109:24 110:17
114:16,21
115:4 117:4
118:21 119:10
119:19 120:6
121:10 122:6
122:19 123:4
123:20,25
128:7,16 129:8
129:13 130:8
130:19 131:2
133:13,22
134:2,24 135:9
137:16 138:5
140:3,17
141:16 142:1
142:12,23
143:25 144:8
144:17 145:3
145:18 146:14
146:24 147:12
148:17 149:3
150:10,19
152:19 155:6
157:2,9 158:11
158:23 159:22
160:4 161:1,17
162:6 163:4
objecting 150:25
objection 19:7
30:2131:13
33:17 43:3,10
51:2152:19
66:7 74:3
109:9 111:4
135:3 156:1,15
objections 43:17
43:19
obligate 81:19
83:2 99:5
100:20
obviously 78:8
occasion 32:25
69:4 80:5
88:12
occurred 138:18
occurrence 61:7
offered 13:5
office 131:17
150:17 154:14
154:16 169:10
Officer 6:9,14,15
officer's 108:20
official 95:12
146:8
officially 136:7
officials 82:20
A 9:14 50:1
92:6 118:3
149:11 154:1,2
159:8
okay 4:20 5:4,7
5:8,14,24 6:3
7:2,5,17,20
8:15 9:3,8
10:13 11:10,15
11:24 13:15
14:2,11 15:8
15:24 16:1,7,7
17:1,20 18:3
19:1,3,12
20:12,21,25
21:13 22:10,14
24:15,22 25:5
25:25 26:8,24
28:1,15,17,21
29:10,16 30:17
31:10 32:13
33:10,13,23
34:8,18 37:11
38:8,10,19
39:17,2140:6
40:7,20 44:16
44:24 45:2,22
46:5,25 47:17
47:23 48:3,17
48:22,24 49:19
50:4,6,17 53:6
53:1154:21
57:13,16,25
58:3,6,10,15
58:20 59:9,16
59:18 60:5,17
60:23,25 61:9
62:18 63:15
66:15,25 67:7
67:14 68:5,9
68:12 71:10
72:3 73:17
74:10,15 77:1
77:16 78:23
79:24 80:11,21
81:7,9 82:22
83:6,23 85:7
86:25 89:2
91:24 93:24
94:25 95:15,20
96:6,10 97:21
98:22 100:11
101:3 102:19
103:14 105:5
105:16 106:3
106:11,11
109:20 110:3
111:1,7,16
112:2 113:2,12
113:16 114:25
115:24 117:14
118:4,7,19
119:7,17 120:2
120:24 121:25
123:18 125:4
125:15,18,22
126:8 127:14
128:5 129:2,18
130:1,3,24
131:8 132:8,8
132:13,17
133:6,19 134:6
134:16 136:3
136:17,20,25
137:6 141:23
143:19 146:13
147:7 148:3
149:1 152:2,12
152:18,24
154:5,6,11
155:20 156:7
156:10,19
157:22 158:8
158:21 159:3
159:16 160:1
161:22 162:10
164:23 165:16
165:20
old 122:2 146:22
once 9:6,21
28:24,25 30:2
31:4 50:18
136:11,13
one-year 19:15
ones 43:12
ongoing 28:12
online 153:4,7
153:13,14
open 69:15
80:19
operate 52:6
91:12,19
operated 14:4,11
16:4
operations 16:21
17:6 20:1
25:16
opinion 146:23
147:6
opportunity
13:22,23,25
52:16 53:1
opposed 84:21
141:25
option 13:5
28:11
order 32:14
34:11,12 39:23
39:25 74:4
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
13
84:14 110:19
122:21 135:1
156:20,23
160:7
ordered 34:13
73:22 122:9
124:23 165:24
165:24
ordering 93:17
95:8 140:20
169:13
orders 31:2,2
ordinance 54:25
55:1,7,15,24
56:3,5,6 66:12
66:15 67:1
72:3,17 150:1
ordinances 26:4
86:11
organization
91:1
organizations
81:18,18
original 168:5,6
169:13
Orthwein 74:12
ought 162:18
163:23
outside 17:14
24:16,17,24
26:6,9 86:11
163:17
outsourced
22:18,20
outstanding
32:2
overall 105:10
overhear 146:1
overheard
145:15,24
146:2
overseeing 16:22
17:3 25:20
owners 14:24
79:22
P 3:20
P.A 2:14
P.M 1:19,19
66:17 113:25
165:25 169:11
pad 48:9,11
page 3:2,11,18
126:20 127:11
127:18 152:16
168:6,8
pages 167:7
Pahokee 18:1,2
18:7 19:21,22
19:24
paid 15:11
Palm 2:8,9 26:21
27:131:15
32:1 166:4
167:2
paper 47:18 48:5
48:6 80:3
paralegal 130:4
pardon 9:25
27:24 34:10
49:13 56:23
62:4 67:18
68:16 75:3
105:20 107:23
110:24 119:15
136:12 139:1
140:1,10
143:15 153:1
157:15 159:10
161:20
park61:19
64:15 65:17
parked 32:20
33:166:1
parking 32:20
56:13 64:2
66:12,13,15,17
66:25 67:8
69:8,15 70:6,9
71:19,24,25
72:3,17 154:2
part 6:15 85:4
88:22 99:13
103:11,15
108:21 113:18
121:14 138:24
139:21
part-time 14:20
14:23 15:2,6,9
parties 3:21
167:10,10
party 23:23
passed 66:11
115:18
passes 82:22
patrol 89:14
90:9
Patsy 94:23
paved 103:24
pavement
100:13,15,17
100:24,25
101:1 103:24
104:24 105:3
106:5,8,15
107:1,10,13
pay 94:3,11,12
142:16
paying 93:2,9,11
93:12
payment 123:12
131:14,23,24
payments 132:1
pays 131:19
pen 103:14
penalties 168:21
pending 4:15
93:20 115:4
162:23
people 22:16
36:18,23,24
42:12,20 43:1
47:25 70:12
157:7
percent 154:17
perform 23:15
period 12:15,24
15:20 18:17
57:20 60:9,10
61:3 137:8,25
perjury 168:21
person 22:7,24
23:141:8
64:10 88:7
101:19 102:10
105:9 131:21
131:24 162:4
personally 74:24
75:4 166:8
perspective 92:8
ph 130:3
Phoenix 12:20
13:13,14
phone 113:15
photograph
152:16
picks 148:9
picture 49:24
153:21,25
piece 47:18 48:5
Piper2:14
place 8:24 62:6
96:4,9,13,14
96:16 111:2
117:3 118:12
118:15
placed 34:6,13
34:15 40:12,13
45:13 46:10
63:8 100:13
placement 98:6
100:14
plain 146:22
plaintiff 1:6,14
2:14:8 134:24
155:8
Plaintiffs 103:1
104:18 126:15
plan 68:24 69:1
69:10,12,14
70:4,7
plane 136:17
planning 63:9
111:11
plat 101:10,17
101:18,20
102:5 103:7
105:10 110:8
Play 154:8
please 30:18
54:4 68:25
79:11 84:1
115:10 125:25
126:14 147:2
168:1,5,6
169:6,10
pleasing 64:4
podium 137:24
148:7
point 22:22 33:9
51:13 101:22
102:11,12
107:6,10,14
pointed 10:8
police 33:10 68:2
68:4,5 88:9,25
90:1197:21
99:4,5,23
100:21 108:20
110:3,15 111:1
117:15
policies 26:4
54:11 86:13
87:8,12,12
policy 53:18,23
54:9,10,13,14
54:18,19,22
55:11 86:24
87:1,2,23,24
87:24,25 88:2
88:7
political 19:18
114:14
politics 19:20
portion 73:18
position 16:15
21:5,1041:13
41:16 45:13
64:10,11
positioned 87:14
87:15
possible 64:19
66:2 78:6
86:17 108:7
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
14
140:19 155:11
155:13,16
156:23 160:14
possibly 39:23
74:4 124:23
135:2 157:17
posters 120:25
potentially
87:12 122:21
158:14
practices 116:21
predecessor
23:17
preference 45:14
45:16
preparation
20:2
prepares 127:17
preparing 113:6
present3:21
132:24
presented
132:22 148:25
pretty 149:18
previous 121:12
primarily 14:24
15:5 24:7
118:9 127:18
161:9
prior 22:17,23
44:2148:7,9
62:23 63:9,9
63:15
private 100:1,5
100:9 101:24
102:13 105:6
106:12,22
107:4 108:3,5
109:3,8
privilege 44:12
115:4
privy 164:2
pro 2:2 9:13,15
probably 124:7
142:16
problem 52:11
problems 83:13
proceed 52:9
proceeding
50:20 51:5,6
51:24
proceedings
44:2 85:20
process 52:6
131:21 132:3
141:10 142:9
148:9
processing 132:2
produce 153:9
produced
152:25 153:3
Professional
166:7 167:5,20
prohibit 66:5
prohibition 67:7
67:11
prohibits 66:16
project 123:3,11
123:13,15
proper 91:2
141:1,2,5,9
properly 115:21
properties 64:25
65:2 120:3
property 63:18
64:25 98:15
100:2,6,10
101:14,24,25
102:13 105:6,6
106:12,13,22
107:4 108:4,5
109:3,7,8,22
111:2 122:1,16
122:18
proposed 37:1
protected 119:9
proverbial 140:1
provide 37:17,18
102:9 145:8
provided 103:4
provides 69:14
providing 40:25
89:24
provision 69:6
71:19
proximity
108:13
prudent 140:13
public 1:24 7:14
54:14 74:21
80:7,8,9,14
81:4,17,18
83:19,22 84:13
101:24 105:6
126:24 130:17
130:18 136:21
136:24 137:12
137:15,19,24
140:25 142:18
150:14,14
154:15 160:23
166:7,17
published 134:7
pulpit 148:7
punish 140:15
157:1,5
purchase 13:5
13:18 93:13
purchased 14:8
purchaser 14:16
purported 127:6
purports 126:23
purpose 27:2
35:1,3 131:8
purposes 111:11
pursue 43:12
pursuing 86:2
pushing 164:12
put 33:14,25
35:25 36:5
37:7 45:24
46:13,14 48:4
57:7 58:20
61:11,14,15
65:17 72:3
112:9 113:16
113:17,21
162:19 163:25
putting 47:1
66:4 73:17
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O
question 10:12
19:10 21:17
23:12 24:21
28:5,13 30:9
30:12,13,15,18
30:19 34:23
35:5,19 37:16
37:25 38:14
39:2,5,9,16,18
39:19,20 40:13
41:25 42:15
43:6,9 45:19
47:13,15 48:8
49:3 51:7,10
51:13,18,22
53:16,25 54:2
54:5,12 55:3,5
55:13,19,21
56:20 57:24
64:13 65:24
66:20,23 69:17
69:24 70:1
71:22 72:10,11
73:22,22 75:1
75:12 76:13
77:8 78:15
79:8,12 80:16
80:18 81:1,12
81:13 82:3,15
83:1,16 84:11
85:2,4,5,11
86:15 87:4,10
88:5 89:7,10
90:14 91:15
92:18 93:10,21
96:1,2197:3
97:14,19 98:4
99:2,21 100:4
101:16 103:10
105:8,24
106:18,24
107:8,17 108:6
108:24 109:10
109:15,19,25
110:18 111:22
112:1 114:17
114:22 115:9
115:14 117:5
118:22 119:8
119:11,20
120:7 121:11
121:13 122:7,8
122:19,20,25
123:5,21 124:1
124:3,22 128:8
128:17 129:9
130:9,20 131:3
133:14,22
134:3,25
135:10 137:6,7
137:8,17,25
138:3,6 140:4
140:17,22,23
141:17 142:2
142:13,24,25
144:1,9,18
145:4,21
146:15,25
147:13,24
148:1,6,18
149:4 150:11
150:21,23
151:2 152:4
153:19 155:4,7
155:19 157:10
158:12,13,24
159:22 160:5,8
161:2,18 162:7
162:23 163:1
questioning 53:2
111:11 163:5
165:9
questions 3:18
7:23 32:15
39:23 50:21
55:11 84:12
93:16 95:9
112:23 129:14
138:4 144:10
147:2 156:21
156:23 164:25
quickly 152:10
152:13
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
15
quorum 76:21
77:1
quotes 147:21
K
racketeer 78:1
116:6,19
134:19
racketeering
130:25 131:9
131:12 139:15
140:14 141:11
141:24,25
143:13 157:8
157:21
Rader 9:5
raised 115:22
ramifications
122:24
Randolph 73:2,9
91:10 93:24
94:23 95:10,12
95:16,21 126:2
128:10,13,14
128:22,25
129:2,4
rate 18:5
Raton 1:18
react 84:9,15
read 30:18,19
54:4,5 69:9,10
70:1 81:7 85:5
97:21 110:8
115:14 146:11
146:12 148:1
156:24 165:23
168:5,22
169:12
reading 3:22
54:25 98:11
101:10 156:21
real 10 1: 14
123:18 124:6
124:12,22
really 10:9,10,19
10:19 31:14
59:14 97:15
115:5 118:18
127:19 138:17
140:22 142:11
144:15 146:18
reason 76:19
81:16 82:17,18
127:14 153:12
168:8
reasonable
169:13
recall 7:3 8:1
9:22 10:3 21:1
27:3,2128:20
33:2,5,24 40:9
48:2153:13
57:12 59:4
60:2 61:7
62:12 63:21
69:9,18 70:3,6
71:14 72:1,24
75:18 76:4
77:6,23 78:2,5
78:7,8,22,23
86:17 91:23
92:2 94:15,18
94:19 97:15,17
98:12 99:13,22
100:20,25
115:23 116:7
116:17,20
117:13 118:3
118:11,16
119:3,5 131:4
131:6 132:21
132:25 136:15
138:7,15,16,23
146:6 148:19
148:21 150:7
152:1
recalling 76:6
received 31:19
31:23 32:1,3
83:10
recess 44:1
85:19
recognition
31:20
recognize 160:20
recognized
62:22 63:7
recollection 6:11
9:20 28:24
35:12 96:23
117:6,9 152:7
recommended
149:20
recommending
139:13
reconsider 114:3
record 9:23 10:1
10:2,4,6 44:4
84:3 113:17,17
113:19,21,23
126:18 130:18
152:9 154:24
167:7
recorded 30:20
54:6 70:2 85:6
115:15 148:2
recording
138:23
records 7:11,14
38:11,20,22,24
38:24,25 41:7
41:9 74:21
80:7,8,9,14,23
80:24 81:4,17
83:9,19,22,24
84:13 130:17
139:25 143:19
154:15 158:10
159:19,21
recreation 69:7
red 103:14
refer 78:21
115:24 116:6
116:11,15
referred 30:19
54:5 70:185:5
115:14 148:1
169:7
referring 54:10
54:1189:9
102:5 116:18
120:23
refresh 6:11
refused 50:21
refusing 153:9
regard 89:17
regarding 115:3
160:25
regards 18:23
21:25 35:6
75:20 149:12
Registered 166:6
167:4,20
regular 126:24
reinstated 19:13
related 92:13
relates 56:6
59:12 87:13
89:23 90:16
145:10
relative 35:22
167:9,10
relevance 30:10
33:17 42:22
43:4
relevant 35:21
51:14 52:17
53:2 165:10
relocate 117:11
rely 99:23
remember 5:16
5:18,20 6:3,7
6:21,23 7:2,6
7:14,16,20,22
7:23 8:19:7
20:1128:2,12
30:1131:25
32:19,23,25
33:10,13,15,24
33:25 34:6,11
40:20 46:3,11
46:16,23 49:18
49:19 50:8
54:20,22 58:18
66:25 67:5,7
68:9,14,17,18
71:16 78:10,12
79:2,3,4,5,15
80:2 93:24
94:4,8,10,12
95:16 97:24
98:10,11,12
99:10 116:22
116:23 120:11
120:13,21,24
121:3,5,9,14
130:24 143:20
149:17 161:15
remembering
34:18
reminding 59:20
remove 98:2,14
99:15 108:15
117:12
removed 98:23
99:1,9,11
122:16
removing 88:3
108:4
render 124:15
125:13
renewed 19:16
19:17
repeat 20:5
69:22,24 82:3
85:3 145:20
147:23
replica 138:18
report 22:6 68:2
68:4 75:16,19
75:20,23,24
76:3 88:9,13
90:19 97:22
99:4,5,14,23
100:21 108:12
117:15,15,17
117:21,22,23
117:24 125:9
142:15 167:5
reported 1:23
17:15 24:9
reporter 4:1
30:17,20 54:6
69:25 70:2
85:6 96:16
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
16
103:5 104:3,18
115:13,15
126:13 148:2
166:7 167:1,5
167:15,20
reporters 79:22
reporting 1:16
25:15 169:19
reports 23:7,11
23:12 88:11,21
88:23
represent 115:22
145:7
representation
9:2 16:20 17:2
17:9,10,13
73:11
representations
17:6
representative
73:7 139:4
represented 6:24
8:8,11 17:14
139:6 159:20
representing
36:172:21,22
93:8 145:12
149:12
represents 26:5
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reproduction
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
17
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
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Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
19
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Fort Lauderdale, Florida 954-755-6401
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36:16 37:17
38:2,15 39:4
39:10 41:12
42:2,17,24
43:21,24 47:14
49:5,11 51:22
54:1 55:4,12
56:2161:24
65:25 66:9,22
67:1169:18
70:3 71:23
72:1173:25
74:5 75:13
77:23 79:8
81:2,14 82:17
83:2,18 84:5
84:15 85:3,7
86:16 87:5,11
88:6 89:8
90:15 91:16
92:19,21 93:22
94:15 96:3,23
97:4,6,15 98:5
99:4,22 100:5
101:17 103:11
104:5 105:9,25
106:19,25
107:9,18 108:7
108:9 109:1,11
109:16 110:1
110:21 111:5
113:6 114:18
114:23 115:16
117:6 118:23
119:13,21,23
120:9 121:14
122:11,23
123:6,22 124:2
128:9,18
129:10,16
130:10,21
131:4 133:15
133:24 134:4
135:5,12
137:19 138:7
140:5,8,21
141:19 142:3
142:14 143:1
144:2,12,20
145:6,20
146:16 147:3
147:14,23
148:3,19 149:6
150:13 152:20
153:16,19
155:9 156:3,17
157:4,12 158:4
158:15,25
159:24 160:9
161:4 162:8
163:7
woman 116:2
won 141:24
word 49:15
139:11
words 47:1
104:23 121:7
132:14 141:7
154:8 163:20
work 12:11,13
12:16 14:20
15:6 18:14
24:23 59:23
89:4 101:9,11
114:8 129:3,5
129:5,6 154:18
worked 14:17,19
14:23 15:5
16:4 18:5
24:16
working 15:9,22
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
21
18:1
works 106:3
world 52:11
wouldn't 65:20
71:1 88:17
113:3 148:23
writer 16:25
writing 48:11
131:22 142:20
written 31:2
83:3,6 139:11
wrong 18:4,25
19:5 46:147:2
52:8 71:19
90:7 94:1
136:16
wrongful 8:2
wrote 40:10
x 1:11 3:1,9
105:11,15
Y
yard 122:15
Yeah 52:20
year 15:20,21,23
19:15,15 27:19
28:9,9 41:21
57:10,14,25
60:12,14 61:4
71:15 91:24
151:10,11,13
151:22
years 14:5,12
15:16 16:5
17:22,25 18:5
18:9,10,11,18
18:22 27:5
28:5,22,22
57:5,8,15,19
58:23 60:18,19
60:24 62:23
63:8,15,20,22
64:18 72:5
83:10 92:1,5
124:7,13,13,14
125:8 128:4
zone 119:18
120:4
0
13:12 102:23
103:1,6 104:11
104:17,17,19
127:11 151:14
1,500 83:12,14
1:251:19
10 -foot 106:8
10,000 83:24
84:7
100127:3
1000 2:15
1148:10
119 80:11,22
81:2,7,24 82:5
82:5,6 84:13
91:12 92:13
12133:5
1252 154:24
1280 2:2
12th 127:1
13th 74:16
14 59:25 61:5
145154:17
15 60:5,22
15 -foot 106:13
15/'16151:11,15
15151:17
16/'17151:18,22
1645 2:8
165167:7
18154:24
198615:14
198715:25
199218:2,2
1998 64:8
23:13 126:14,15
138:25
2,000 83:12,14
2.3154:24
20 57:5,8 58:23
60:18,19,24
20 -foot 106:5
107:11,11
2000 64:8
2010 64:8
2013 61:4
2014 58:1,2,8
59:10 60:22
61:5 62:21
64:8 127:2
152:15 154:13
2015 58:10,17
60:14 61:6
64:8
20161:15 166:9
166:13 167:16
168:3 169:1,4
169:7
23169:1
23rd 166:13
169:6
23re 167:16
24 47:24 48:19
2455 2:14
25,000 94:10
26128:4
27128:4
3
3.7155:2,5
30105:19,22
30 -foot 105:21
106:1,3,4,8
3001:17
30th 151:16
152:15
31st 61:4
33304 2:15
334012:9
334321:18
33442 2:3
36 47:24 48:19
3rd 154:13
4 3:3 167:7
4:30169:11
4650154:14
499 60:11
499,000 59:2
5
5 61:21 62:9
50105:15,17
118:12 132:1
159:3
50,000 94:2,3
143:22
500,000 58:9
59:1,10,25
60:4,1161:6
561-681-5523
2:10
6
6111:24112:11
113:12,25
114:7 164:12
164:24
6:031:19 165:25
60105:15
60,000132:1
143:21
7 66:17,18 70:25
71:3,8
7212:17 154:17
74 12:18,25
7612:25 14:2
8
81:15 169:4
8,000 61:2162:9
800,000 58:19
60:5,7,15 61:6
813:18
8816:6
8916:6
8th 166:9
93:18 127:2
9:00 169:11
9:14 -CV -8125...
1:3
9017:23 54:24
9117:23
9418:12 60:24
954-463-0100
2:16
954-755-6401
169:20
9618:13,15
60:24
Daughters Reporting, Inc.
Fort Lauderdale, Florida 954-755-6401
7.2