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1 "IN ITS STATEMENT OF
2 ORGANIZATION, DEFENDANT R.O.W.
3 P.A.C. CLAIMED THAT IT HAD 'NOT YET
4 QUALIFIED' AS A COMMITTEE. UPON
5 INFORMATION AND BELIEF, DEFENDANT
6 R.O.W. P.A.C. HAS SINCE QUALIFIED
7 AS A COMMITTEE BY VIRTUE OF RAISING
8 AND SPENDING $2,000 OR MORE IN
9 CONNECTION WITH A POLITICAL
10 CAMPAIGN, BUT NEVER FILED AN
11 AMENDED STATEMENT OF ORGANIZATION
12 SETTING FORTH THE DATE IT QUALIFIED
13 AS A COMMITTEE."
14 DO YOU HAVE PERSONAL KNOWLEDGE OF THAT?
15 A. OF THE VIOLATION OF -- FACT OF THE VIOLATION?
16 Q. NO. THE ALLEGATION THAT YOU MAKE THAT
17 "R.O.W. P.A.C. HAS SINCE QUALIFIED AS A COMMITTEE BY 18 VIRTUE OF RAISING AND SPENDING $2,000 OR MORE."
19 A. YEAH. YES, I DO.
20 Q. OKAY.
21 A. I DO REMEMBER GOING THROUGH THE FIRST ROUND OF
22 SIGNS THAT WERE DISTRIBUTED WITH NO DISCLAIMERS OF A 23 P.A.C., AND THEN THE -- AND THE NEXT ROUND OR THE
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24 FOLLOWING ROUND OF SIGN PRODUCTION HAD STARTED TO
25 INCLUDE THAT ON THERE; AND AT THAT POINT IS WHEN I WAS 123
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1 STARTING TO LEARN MORE ABOUT HOW THIS WORKED AND THAT 2 MAGIC NUMBER OF HOW YOU HAVE TO GET TO THAT IN ORDER TO 3 GO TO THAT NEXT LEVEL.
4 Q. OKAY. AND IN THE MARCH ELECTION,
5 MR. NEHRENHEIM WAS IN A CAMPAIGN THAT INCLUDED AT LEAST 6 TWO OTHER CANDIDATES, CORRECT? DO YOU REMEMBER THAT?
7 A. YES.
8 Q. OKAY. AND ONE OF THEM WAS MARTHA BARBEE. DO
9 YOU REMEMBER HER BEING ONE OF THE CANDIDATES?
10 A. YES.
11 Q. SHE WAS THE APPOINTED COUNCILMEMBER FOR
12 DISTRICT 1, WASN'T SHE?
13 A. YEAH.
14 Q. DID YOU WORK ON HER CAMPAIGN?
15 A. I DID.
16 Q. AND WHAT WERE -- WHAT WERE THE ACTIVITIES THAT
17 YOU ENGAGED IN IN CONNECTION WITH WORKING ON HER
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18 CAMPAIGN?
19 MR. HERTZ: I'LL OBJECT BASED ON RELEVANCE.
20 BUT YOU CAN ANSWER.
21 THE WITNESS: I AGREE.
22 Q. BY MR. COLIN: YOU CAN ANSWER. WHAT WERE YOUR
23 ACTIVITIES?
24 A. I'M AGREEING WITH MY ATTORNEY.
25 MR. HERTZ: NO, I'M NOT INSTRUCTING YOU NOT TO
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1 ANSWER, SO -- I'M JUST SAYING IT'S NOT RELEVANT FOR THE 2 RECORD, BUT --
3 THE WITNESS: WELL, I DON'T, SO -- I'LL GIVE
4 AN ANSWER, BUT I FEEL LIKE GOING DOWN A ROAD OF THINGS 5 THAT HAVE NO RELEVANCE TO IT COULD, YOU KNOW, JUST NOT 6 BE USEFUL USE OF OUR TIME; BUT YES, I DID. I WORKED ON 7 DOOR KNOCKING --
8 Q. BY MR. COLIN: OKAY.
9 A. -- AND I WORKED ON DISTRIBUTING AND MAKING
10 SURE SIGNS WERE PLACED AT ALL PLACES WHICH WERE
11 REQUESTED.
12 Q. WERE THERE EVER ANY OCCASIONS WHERE YOU WERE
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13 PLACING SIGNS IN LOCATIONS WHERE NOBODY DID REQUEST
14 MARTHA BARBEE SIGNS?
15 A. NO.
16 Q. WERE THERE EVER -- WERE THERE EVER ANY
17 OCCASIONS WHERE YOU WERE REMOVING SIGNS OF THE
18 NILS NEHRENHEIM CAMPAIGN FROM LOCATIONS THAT HADN'T
19 ASKED YOU TO REMOVE THEM?
20 A. NO.
21 Q. DO YOU RECALL A SPECIFIC INCIDENT NEAR THE
22 INTERSECTION OF PCH AND, I BELIEVE, KNOB HILL WHERE YOU 23 WERE INVOLVED IN AN ALTERCATION OR AN INTERACTION WITH 24 CANDACE NAFISSI ABOUT SIGNS?
25 A. YES.
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1 Q. OKAY. AND AT THAT PARTICULAR ALTERCATION,
2 WERE YOU REMOVING MR. NEHRENHEIM'S SIGNS WHEN -- WHEN 3 MS. NAFISSI CAUGHT YOU DOING SO?
4 A. NO.
5 MR. HERTZ: I'M GOING TO OBJECT TO THE TERM
6 "ALTERCATION" AS VAGUE AND AMBIGUOUS AND ALSO
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7 ARGUMENTATIVE AS TO THE TERM "CAUGHT YOU DOING SO."
8 Q. BY MR. COLIN: OKAY. DID YOU NOTICE -- WELL,
9 YOU REMEMBER SOME KIND OF AN INTERACTION WITH
10 MISS NAFISSI AT THAT LOCATION, DO YOU NOT?
11 A. I DON'T -- ACTUALLY, I DON'T BELIEVE I SAW HER
12 SPECIFICALLY THERE.
13 Q. OKAY. WELL, WHO DID YOU SPECIFICALLY SEE
14 THERE WHEN THE INCIDENT TOOK PLACE?
15 A. I KNOW THAT NILS WAS THERE, AND I DON'T KNOW
16 THE OTHER NAMES BY SPECIFICS THAT WERE WORKING ON IT; 17 BUT THE ONLY THING THAT I DID DO THERE WAS GO TO REPLACE 18 A SIGN THAT WAS REQUESTED BY ONE OF TWO BUSINESSES IN 19 THAT PLAZA TO BE PLACED IN FRONT OF THEIR BUSINESS,
20 DIRECTLY IN FRONT OF IT.
21 Q. WHAT WERE THE BUSINESSES?
22 A. WANNA CHILL AND AVENUE A BAR & GRILL.
23 Q. OKAY. AND WHEN YOU WERE REPLACING THESE
24 SIGNS, DID YOU NOTICE WHETHER ANYBODY WAS VIDEOTAPING 25 YOU?
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1 A. NO. LATER I SAW A PICTURE POST OF ME.
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2 Q. OKAY. THAT WAS MY NEXT QUESTION.
3 DID YOU NOTICE WHETHER ANYBODY WAS TAKING
4 PHOTOGRAPHS OF YOU AT THAT LOCATION?
5 A. NOT AT THE TIME.
6 Q. OKAY. MARTHA BARBEE LOST THE ELECTION. WHEN
7 SHE -- WHEN SHE LOST THE ELECTION TO NILS NEHRENHEIM, 8 DID IT UPSET YOU?
9 MR. HERTZ: OBJECTION; VAGUE AND AMBIGUOUS AS
10 TO THE TERM "UPSET."
11 Q. BY MR. COLIN: YOU CAN ANSWER.
12 A. IT WAS DISAPPOINTING BECAUSE I WORKED ON HER
13 CAMPAIGN.
14 Q. ALL RIGHT. DID YOU EVER CONGRATULATE
15 MR. NEHRENHEIM FOR WINNING?
16 A. I DON'T THINK I'VE EVER REALLY SEEN HIM TO
17 CONGRATULATE HIM; NO.
18 Q. WELL, WAS HE NOT HERE THIS MORNING?
19 A. AFTER ALL THIS WAS GOING ON, I'VE BEEN
20 INSTRUCTED NOT TO INTERACT WITH MR. NEHRENHEIM.
21 Q. OKAY. ALL RIGHT. AT PARAGRAPH 20 OF THE
22 COMPLAINT, THIS IS ON PAGE 5. IT READS:
23 "UPON INFORMATION AND BELIEF,
24 DEFENDANTS BILL BRAND AND
25 NILS NEHRENHEIM EXERTED SIGNIFICANT
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127
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1 INFLUENCE AND CONTROL OVER
2 DEFENDANT R.O.W. P.A.C. AND WERE
3 CONTROLLING CANDIDATES WITH REGARD
4 TO R.O.W. P.A.C. UNDER THE RELEVANT
5 PROVISIONS OF THE POLITICAL REFORM
6 ACT, BUT DEFENDANTS FAILED TO
7 DISCLOSE BRAND'S AND NEHRENHEIM'S
8 CONTROLLING CANDIDATE STATUS ON
9 THEIR CAMPAIGN REPORTS."
10 MY FIRST QUESTION TO YOU IS: ARE YOU FAMILIAR
11 WITH THE RELEVANT PROVISIONS OF THE POLITICAL REFORM ACT 12 AS IT -- AS IT RELATES TO THIS COMPLAINT?
13 MR. HERTZ: OBJECTION; THE COMPLAINT SPEAKS
14 FOR ITSELF. IT WAS DRAFTED BY HIS ATTORNEY AND REVIEWED 15 BY HIM. THERE'S NO OBLIGATION FOR HIM TO UNDERSTAND
16 EVERY ASPECT OF THE RELEVANT PROVISIONS, BUT HE CAN
17 ANSWER WHAT HE KNOWS.
18 Q. BY MR. COLIN: YEAH, ESPECIALLY SINCE HE
19 VERIFIED THE COMPLAINT.
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20 MR. HERTZ: RIGHT, AND IT'S UPON INFORMATION
21 AND BELIEF --
22 MR. COLIN: OKAY.
23 MR. HERTZ: -- SO WE'LL SEE WHAT INFORMATION
24 AND BELIEF HE HAD.
25 MR. COLIN: OKAY.
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1 THE WITNESS: I BELIEVE THAT IT WAS A
2 VIOLATION IN IT, AND I TALKED TO AN EXPERT, MY ATTORNEY, 3 WHO HELPED TO EDUCATE AND SHOW THAT HE -- EXCUSE ME -- 4 CLEARLY WAS A VIOLATION OF THIS.
5 Q. BY MR. COLIN: OKAY. SO YOU TALKED TO YOUR
6 ATTORNEY ABOUT THAT, AND I DON'T WANT TO GET INTO ANY OF 7 THAT RIGHT NOW; BUT ARE YOU REFERRING TO MR. HERTZ?
8 A. CORRECT.
9 Q. OKAY. HAD YOU SPOKEN TO OTHER -- ANY OTHER
10 LEGAL EXPERTS ABOUT BILL BRAND AND NILS NEHRENHEIM
11 VIOLATING, THROUGH THEIR ACTS, PROVISIONS OF THE
12 POLITICAL REFORM ACT?
13 MR. HERTZ: I'LL OBJECT ON THE GROUNDS THAT
14 THAT THEY MAY INVADE THE ATTORNEY/CLIENT PRIVILEGE TO
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15 THE EXTENT HE WAS TALKING WITH ATTORNEYS OR DID TALK TO 16 ATTORNEYS; AND INSTRUCT THE WITNESS NOT TO ANSWER; AND 17 HIS SILENCE WILL BE AN AGREEMENT OF MY INSTRUCTION.
18 Q. BY MR. COLIN: OKAY. WELL, DID YOU TALK TO
19 ANY OTHER LAWYERS?
20 MR. HERTZ: SAME OBJECTION AND SAME
21 INSTRUCTION.
22 Q. BY MR. COLIN: ALL RIGHT. I ASKED YOU EARLIER
23 IN THIS DEPOSITION, MR. VOISEY, IF YOU HAD WRITTEN
24 LETTERS TO -- TO THE EDITOR, SOME OF THE LOCAL
25 NEWSPAPERS, AND YOU TOLD ME THAT YOU HAD; AND I ASKED 129
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1 YOU IF WHAT YOU HAD WRITTEN WAS TRUE, AND YOU TOLD
2 ME "YES."
3 DO YOU REMEMBER THAT?
4 A. I SAID I DO BELIEVE THAT EVERYTHING I --
5 Q. OKAY.
6 A. -- SAID HAS BEEN TRUE THAT I HAVE WRITTEN.
7 Q. OKAY. I'M GOING TO MARK AS EXHIBIT 9 -- THIS
8 IS A PHOTOCOPY OF A LETTER TO THE EDITOR OF "THE BEACH
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9 REPORTER," AND THE TOP OF THE LETTER SAYS "PLAINTIFF
10 OFFERS EXPLANATION." AND DID YOU WRITE THIS LETTER?
11 A. YES.
12 (THE AFOREMENTIONED DOCUMENT
13 WAS MARKED BY THE COURT REPORTER
14 AS DEFENDANTS' EXHIBIT 9 FOR
15 IDENTIFICATION; ATTACHED HERETO.)
16 Q. BY MR. COLIN: OKAY. AND IT READS "CHRIS
17 VOISEY" AT THE BOTTOM, AND IT READS:
18 "AS ONE OF THE PLAINTIFFS IN
19 THE LAWSUIT AGAINST R.O.W. AND ITS
20 MEMBERS FOR VIOLATING THE STATE'S
21 POLITICAL REFORM ACT, I WRITE THIS
22 LETTER IN RESPONSE TO LAST WEEK'S
23 ARTICLE. AFTER REVIEWING READERS'
24 COMMENTS, IT'S TIME TO SET THE
25 RECORD STRAIGHT. THE LAWSUIT IS
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1 NOT AGAINST THE CITY, BUT INSTEAD
2 IS DIRECTED TOWARD THOSE WHO
3 VIOLATED CAMPAIGN LAWS AND MISLED
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4 THE VOTERS DURING THEIR CAMPAIGNS
5 FOR MAYOR, CITY COUNCIL, AND
6 MEASURE C."
7 DO YOU RECALL WRITING THIS?
8 A. UH-HUH.
9 Q. OKAY. IS THAT A "YES"?
10 MR. HERTZ: YOU HAVE TO SAY "YES."
11 THE WITNESS: "YES." YEAH, I CAUGHT THAT.
12 Q. BY MR. COLIN: NEXT PARAGRAPH READS:
13 "THE LAWSUIT, KNOWN AS A
14 'PRIVATE ATTORNEY GENERAL' LAWSUIT,
15 IS ENCOURAGED UNDER THE STATE'S
16 CAMPAIGN LAWS SO PRIVATE
17 PARTIES --" AND IN PARENTHESES --
18 "(IN THIS CASE," COMMA,
19 "ARNETTE TRAVIS AND I)," CLOSED
20 PARENTHESES, "CAN ASSIST THE
21 GOVERNMENT AND THE PUBLIC IN
22 EXPOSING ILLEGALLY RUN POLITICAL
23 CAMPAIGNS. REDONDO CITIZENS ARE
24 ENTITLED TO MAKE THEIR VOTING
25 DECISIONS BASED ON CAMPAIGNS THAT
131
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1 COMPLY WITH THE POLITICAL
2 TRANSPARENCY LAWS. THE DEFENDANTS
3 HID THE BALL DURING THEIR
4 CAMPAIGNS, AND OUR LAWSUIT SIMPLY
5 ASKS THE COURT TO ORDER THEM TO SET
6 THE RECORD STRAIGHT ABOUT THE
7 FUNDING AND RUNNING OF THEIR
8 DECEPTIVE CAMPAIGNS. I AM PROUD OF
9 OUR COMMUNITY, AND I WANT TO ENSURE
10 THAT ALL REDONDO RESIDENTS CAN MAKE
11 CHOICES BASED ON ACCURATE
12 INFORMATION AND TRUE FACTS."
13 AND THEN THE NEXT PARAGRAPH
14 READS:
15 "AS FOR THE LAW FIRM THAT WE
16 RETAINED, THEY ARE ALREADY FAMILIAR
17 WITH MEASURE C AND THE CHARACTERS
18 WHO BACKED IT. IT MADE SENSE THAT
19 WE WOULD SEEK OUT AND RETAIN THE
20 ATTORNEYS WHO WORKED ON THE NO ON C
21 EFFORT, AS THEY ARE ABLE TO HIT THE
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22 GROUND RUNNING AND WITH OUR GOAL OF
23 SEEKING JUSTICE FOR THE CITIZENS OF
24 REDONDO BEACH."
25 THAT WAS YOUR LETTER, CORRECT?
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1 A. THAT IS CORRECT.
2 Q. OKAY. WHEN DID YOU RETAIN YOUR LAWYERS TO
3 REPRESENT YOU IN THIS ACTION?
4 MR. HERTZ: OBJECTION, SAME INSTRUCTION --
5 SAME OBJECTION WITH REGARD TO VIOLATING THE
6 ATTORNEY/CLIENT PRIVILEGE; AND SAME INSTRUCTION NOT TO 7 ANSWER.
8 Q. BY MR. COLIN: OKAY. DO YOU EVER RECALL,
9 MR. VOISEY, THAT YOU WERE INTERVIEWED BY ANOTHER
10 NEWSPAPER REPORTER, A GENTLEMAN BY THE NAME OF ROSENFELD 11 WITH THE "EASY READER," WHERE YOU TALKED ABOUT HOW YOU 12 RETAINED YOUR LAWYER? DO YOU REMEMBER THAT?
13 A. YES.
14 Q. OKAY. AND YOU'VE READ THE ARTICLE IN THE
15 NEWSPAPER, HAVEN'T YOU?
16 A. I HAVE, YES.
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17 Q. OKAY. AND IN -- AND IN YOUR INTERVIEW, IT WAS
18 WRITTEN DOWN THAT YOU HAD INTERVIEWED SEVERAL OTHER
19 LAWYERS BEFORE SELECTING YOUR CURRENT ATTORNEY; IS THAT 20 TRUE?
21 MR. HERTZ: OBJECTION; SAME INSTRUCTION NOT TO
22 ANSWER. THE ARTICLE SPEAKS FOR ITSELF AS HEARSAY; AND 23 I'M GOING TO INSTRUCT THE WITNESS NOT TO ANSWER.
24 Q. BY MR. COLIN: OKAY. IN THIS LETTER TO THE
25 EDITOR, YOU -- YOU SAY THAT YOU WANT TO EXPOSE FOR THE 133
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1 PUBLIC THE "ILLEGALLY RUN POLITICAL CAMPAIGNS."
2 WHICH -- WHICH CAMPAIGNS WERE ILLEGALLY RUN, IN YOUR
3 MIND?
4 A. AS PER THE LAWSUIT, I FEEL LIKE THE CAMPAIGN
5 FOR THE YES ON MEASURE C, THE BILL BRAND FOR MAYOR, AND 6 THE NILS NEHRENHEIM FOR COUNCIL DISTRICT 1 IN THAT THEY 7 WERE NOT FULLY DISCLOSING THEIR -- THEIR EFFORTS
8 TOGETHER AND BEING TRUTHFUL.
9 Q. OKAY. AND AS A RESIDENT OF REDONDO IN 2017,
10 YOU BECAME AWARE THAT TODD LOEWENSTEIN WAS RUNNING FOR
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11 CITY COUNCIL IN DISTRICT 2, DID YOU NOT?
12 A. YES.
13 Q. OKAY. AND AT SOME OF THESE EVENTS WHERE YOU
14 SAW MR. -- MR. NEHRENHEIM AND WHERE YOU SAW MR. BRAND 15 AND MR. CRAIG AND MARTIN HOLMES, DID YOU SEE
16 MR. LOEWENSTEIN?
17 A. I DON'T RECALL SEEING HIM.
18 Q. DID YOU EVER SEE ANY OF MR. LOEWENSTEIN'S
19 POLITICAL FLIERS THAT WERE SENT OUT TO THE -- TO THE 20 CITY?
21 A. I DON'T RECALL SEEING ANY OF THEM, NO.
22 Q. OKAY. DO YOU RECALL SEEING ANY OF THE ADS --
23 THE POLITICAL ADS IN LOCAL NEWSPAPERS THAT
24 MR. LOEWENSTEIN HAD PRINTED THAT PROMOTED THE PASSAGE OF 25 MEASURE C?
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1 A. I DON'T RECALL SPECIFICS FROM HIM. I WASN'T
2 PAYING ATTENTION BECAUSE HE WASN'T THE COUNCILMAN FOR MY 3 DISTRICT.
4 Q. OKAY. SO YOU DECIDED THAT YOU WERE ONLY GOING
5 TO SUE THE COUNCILMEN FROM YOUR DISTRICT, BUT NO OTHERS?
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6 MR. HERTZ: OBJECTION, CALLS FOR A LEGAL
7 CONCLUSION; AND MAY VIOLATE THE ATTORNEY/CLIENT
8 PRIVILEGE; AND I'LL INSTRUCT HIM NOT TO ANSWER.
9 Q. BY MR. COLIN: ALL RIGHT. DID YOU SEE
10 MR. LOEWENSTEIN PROMOTING AND COORDINATING WITH ANY OF 11 THE OTHER DEFENDANTS NAMED IN THIS LAWSUIT DURING THE 12 CAMPAIGN SEASON FROM JANUARY 1 THROUGH MARCH 7 OF 2017? 13 A. I DID NOT SEE OR WITNESS HIM DOING ANYTHING
14 WITH THEM, NO.
15 Q. OKAY. LET ME MAKE SURE THAT WE MARK AS AN
16 EXHIBIT THE COMPLAINT. THIS WILL BE -- NO. 10,
17 EXHIBIT 10? EXHIBIT 10 WILL BE A COPY OF THE VERIFIED 18 COPY OF THE COMPLAINT.
19 MR. HERTZ: I THOUGHT WE HAD ALREADY MARKED
20 THAT AS EXHIBIT 2.
21 THE WITNESS: "2."
22 MR. COLIN: OH, EXHIBIT -- DID WE GET THAT? I
23 KNOW THAT WE DID YESTERDAY. EXHIBIT 1 IS THE DEPO
24 NOTICE; EXHIBIT -- WELL, I GUESS WE CAN CHECK. WE'LL 25 CHECK IT LATER. GETTING BACK TO THE COMPLAINT --
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021318.txt
1 (A DISCUSSION WAS HELD OFF THE RECORD.)
2 Q. BY MR. COLIN: GOING BACK TO PARAGRAPH 20,
3 WHERE IT SAYS THAT -- IT ALLEGES:
4 "UPON INFORMATION AND BELIEF,
5 DEFENDANTS BILL BRAND AND
6 NILS NEHRENHEIM EXERTED SIGNIFICANT
7 INFLUENCE AND CONTROL OVER
8 DEFENDANT R.O.W. P.A.C."
9 WHAT IS -- WHAT IS IT THAT YOU OBSERVED THAT
10 LEADS YOU TO BELIEVE THAT BILL BRAND AND NILS NEHRENHEIM 11 EXERTED SIGNIFICANT CONTROL -- I'M SORRY -- SIGNIFICANT 12 INFLUENCE AND CONTROL OVER R.O.W. P.A.C.?
13 MR. HERTZ: OBJECTION, CALLS FOR A LEGAL
14 CONCLUSION; BUT HE CAN ANSWER. ALSO, COMPOUND.
15 THE WITNESS: YEAH, IT IS.
16 Q. BY MR. COLIN: OKAY. LET'S GET IT REAL CLEAR.
17 WHAT DID BILL BRAND DO TO EXERT SIGNIFICANT
18 INFLUENCE OVER R.O.W. P.A.C.?
19 MR. HERTZ: OBJECTION, A LEGAL CONCLUSION.
20 BUT YOU CAN ANSWER.
21 THE WITNESS: FOR ONE, THE R.O.W. P.A.C. WAS
22 FOCUSED ON RECEIVING SEPARATE CAMPAIGN OF YES ON C,
23 WHICH WAS VERY DIFFICULT TO TELL THE DELINEATION OF
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24 WHERE THAT WAS BETWEEN EVERYBODY. YET ALL OF THE
25 BILL BRAND, NILS NEHRENHEIM, AND, OF COURSE, ALL
136
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1 THE "YES ON C" SIGNS AND BROCHURES WERE ALL PROMOTING 2 THE SAME INFORMATION, USING THE "YES ON C" LOGO, USING 3 THE SAME INFORMATION, AS I ALREADY MENTIONED, TO GO
4 ACROSS THE CAMPAIGN. AND IT APPEARS THAT THIS
5 INFORMATION FROM WHAT WE WERE SAYING -- SEEING WAS
6 COMING DIRECTLY OUT OF BILL BRAND AND NILS NEHRENHEIM BY 7 THE STATEMENTS THAT THEY -- WELL, THAT NILS WAS MAKING 8 FOR SURE IN PERSON BEFORE THAT THEY WERE GOING INTO
9 PRINT.
10 Q. BY MR. COLIN: OKAY. SO WHEN YOU SAY THAT IT
11 APPEARS -- LIKE BEFORE IT WENT TO PRINT?
12 A. SO THE STATEMENTS WERE MADE BY
13 NILS NEHRENHEIM, AND THEN IT WOULD WIND UP APPEARING THE 14 NEXT -- WELL, A COUPLE OF WEEKS LATER OR WHATEVER IN 15 PRINT ADS THAT WERE COMING OUT FROM EITHER CAMPAIGN, 16 WHETHER IT BE A WEEK OR TWO, SOMEWHERE IN THERE.
17 Q. OKAY. WELL, LET'S GET -- GET AWAY FROM
18 NILS NEHRENHEIM RIGHT NOW. LET'S FOCUS ON BILL BRAND.
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19 ALL RIGHT? AND MY QUESTION AGAIN IS WHAT IS IT THAT YOU 20 SAW BILL BRAND DO THAT EXERTED SIGNIFICANT INFLUENCE 21 OVER R.O.W. P.A.C.?
22 A. IT WAS CONSTANT COMMUNICATION WITH THEM.
23 Q. OKAY.
24 A. THE CONVERSATIONS AND WITHOUT HEARING TO --
25 THAT SPECIFICALLY, I DID NOT HEAR THE WORDS --
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1 Q. OKAY.
2 A. -- BUT THERE WAS CONSTANT COMMUNICATION,
3 DIALOGUE AND FACE TO FACE BETWEEN ALL OF THE PEOPLE -- 4 OR BETWEEN BILL AND THE FOLKS THAT WERE RUNNING THE
5 R.O.W. P.A.C.
6 Q. AND YOU OBSERVED THAT PERSONALLY?
7 A. I SAW -- I SAW THEM TALKING BEFORE CITY
8 COUNCIL MEETINGS --
9 Q. OKAY.
10 A. -- AND AT VARIOUS PLACES WHERE I WOULD SEE
11 THEM OUT.
12 Q. AND YOU LISTENED IN TO ALL OF THOSE
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13 CONVERSATIONS?
14 A. I ALREADY STATED I DID NOT HEAR THE SPECIFICS.
15 Q. OKAY. AND THEN YOU ALSO ALLEGE IN THE SAME
16 PARAGRAPH THAT HE -- THAT HE, MEANING BILL BRAND,
17 EXERTED CONTROL OVER R.O.W. P.A.C. IS THERE ANYTHING 18 MORE THAT YOU WANT TO ADD THAT YOU HAVEN'T ALREADY TOLD 19 ME ABOUT THAT LEADS YOU TO BELIEVE THAT HE EXERTED
20 SIGNIFICANT CONTROL OVER R.O.W. P.A.C.?
21 MR. HERTZ: OBJECTION TO THE PHRASE
22 "SIGNIFICANT CONTROL" BECAUSE IT'S UNCLEAR WHETHER THE 23 SIGNIFICANT ONLY MODIFIES THE TERM "INFLUENCE" OR IF IT 24 ALSO MODIFIES THE TERM "CONTROL," SO I WANT TO MAKE SURE 25 THE WITNESS UNDERSTANDS THE QUESTION; AND, ALSO, CALLS 138
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1 FOR A LEGAL CONCLUSION AS TO WHAT CONSTITUTES CONTROL 2 UNDER THE POLITICAL REFORM ACT.
3 YOU CAN ANSWER IF YOU HAVE ANY THOUGHT --
4 THE WITNESS: YEAH. MY BASIS FOR THIS IS
5 ACTUALLY IN SPEAKING WITH MY ATTORNEY TO UNDERSTAND -- 6 MR. HERTZ: WELL, DON'T --
7 THE WITNESS: -- TO UNDERSTAND WHAT THIS MEANS
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8 AND REVIEWING THE FURTHER DOCUMENTS THAT WERE TO SHOW 9 THE CAMPAIGN CONTRIBUTIONS AND 460'S, WHICH IS REALLY 10 ALLOWING ME TO UNDERSTAND THAT THIS DOES MEAN MORE -- 11 THESE ARE QUESTIONS THAT WE WERE ASKING BASED ON THIS 12 AND TALKING TO ARNETTE, WHO WAS PULLING A LOT OF
13 RECORDS, LOOKING AT THE INFORMATION, AND JUST, YOU KNOW, 14 PULLING THEM UP AND LOOKING AT THE FILINGS THAT WERE 15 COMING IN THROUGH THE CITY CLERK AND JUST SEEING SOME 16 ODDITIES THAT JUST SEEMED VERY SPECIFIC, AND THEN LATER 17 ASKING FOR ADVICE AND WHETHER I WAS SEEING SOMETHING 18 THAT THERE WAS A TREND HERE.
19 Q. BY MR. COLIN: SO YOU ARE EQUATING FRIENDS AND
20 ODDITIES WITH CONTROL?
21 MR. HERTZ: OBJECTION; MISSTATES THE
22 TESTIMONY.
23 Q. BY MR. COLIN: LET ME GO BACK AND ASK YOU
24 AGAIN BECAUSE THIS IS A VERIFIED COMPLAINT.
25 WHAT IS IT THAT YOU OBSERVED THAT LED YOU TO
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1 PLEAD IN THIS COMPLAINT THAT BILL BRAND EXERTED CONTROL
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2 OVER R.O.W. P.A.C.? ANYTHING MORE THAN WHAT YOU'VE
3 ALREADY TOLD ME?
4 MR. HERTZ: I'LL OBJECT JUST TO QUALIFY THAT
5 THAT PARAGRAPH IS UPON INFORMATION AND BELIEF --
6 MR. COLIN: OKAY.
7 MR. HERTZ: -- AND "CONTROL" IS A TERM OF ART,
8 SO IT CALLS FOR A LEGAL CONCLUSION.
9 Q. BY MR. COLIN: I'M ASKING FOR THE INFORMATION.
10 SO TELL ME -- TELL ME THE INFORMATION THAT YOU HAVE THAT 11 LEADS YOU TO PLEAD THIS.
12 A. IT WAS THE BELIEF THAT I JUST STATED OF THE
13 VARIOUS THINGS PUT ALL TOGETHER AND THROUGH EXPERT
14 OPINION THAT THIS SEEMS LIKE IT.
15 Q. OKAY. SO IT SEEMS LIKE IT.
16 OKAY. NOW, LET'S GET TO NILS NEHRENHEIM, SAME
17 PARAGRAPH. YOU ALLEGE THAT HE EXERTED SIGNIFICANT
18 INFLUENCE OVER R.O.W. P.A.C., SO TELL ME WHAT IT IS THAT 19 YOU OBSERVED MR. NEHRENHEIM DO THAT LED YOU TO PLEAD 20 THAT HE EXERTED SIGNIFICANT INFLUENCE OVER R.O.W. P.A.C. 21 MR. HERTZ: SAME OBJECTION WITH REGARD TO
22 "SIGNIFICANT INFLUENCE" BEING A TERM OF ART THAT CALLS 23 FOR A LEGAL CONCLUSION, BUT YOU CAN ANSWER.
24 THE WITNESS: IT'S REALLY A HISTORICAL
25 TIMELINE OF HAVING NILS HELPING TO FORM R.O.W., BEING A
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140
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1 KEY PART OF IT, BEING A KEY PERSON THAT IS WRITING IT, 2 COLLABORATING WITH BILL BRAND, EVEN ON SUBMITTING
3 PAPERWORK CONSTANTLY TO THE COASTAL COMMISSION, THE
4 COMPLAINT REGARDING THE BOAT LAUNCH, THE CONSTANT EVENTS 5 WHERE THEY'RE ALL WORKING AND TALKING TOGETHER,
6 PRESENTING, WHICH I VIEWED THE VIDEOS ONLINE POST THESE 7 EVENTS, AND THE -- YOU KNOW, CONSTANTLY SEEING HIM CARRY 8 IN ONE HAND A "NILS FOR DISTRICT 1" OR WHATEVER THE -- 9 THE SIGN FOR HIM RUNNING FOR THE COUNCIL SEAT IN
10 DISTRICT 1, AND THE OTHER HAND HOLDING A BANNER THAT'S 11 FOR RESCUE THE WATERFRONT, YES ON C.
12 Q. BY MR. COLIN: OKAY. IN ALL OF THESE THINGS
13 THAT YOU HAVE JUST DELINEATED FOR ME THAT SIGNIFIES OR 14 LEADS YOU TO BELIEVE THERE IS CONTROL OVER
15 R.O.W. P.A.C. -- LET ME -- LET ME GO BACK. STRIKE THAT. 16 YOU'RE TALKING ABOUT R.O.W., BUT YOUR
17 COMPLAINT SAYS "R.O.W. P.A.C.," AND SO WE NEED TO BE 18 VERY CAREFUL ABOUT WHAT IT IS THAT YOU'RE REFERRING TO, 19 THE POLITICAL ACTION COMMITTEE OR THE GRASS ROOTS GROUP 20 THAT WAS FORMED PRIOR TO THE ELECTION.
021318.txt
21 SO IF YOU CAN JUST CLARIFY THAT, ARE YOU --
22 ARE YOU MAKING COMMENTS ABOUT HIS INTERACTIONS WITH
23 R.O.W. OR WITH THE R.O.W. P.A.C. THAT WAS FORMED IN
24 2- -- IN LATE 2016?
25 MR. HERTZ: THE WITNESS, I BELIEVE, HAS
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1 TESTIFIED SEVERAL TIMES THERE WAS CONFUSION IN HIS MIND 2 AND PERHAPS THE PUBLIC'S MIND AS TO THE DISTINCTIONS
3 BETWEEN R.O.W. AND R.O.W. P.A.C. AND THE TIMING AS
4 BETWEEN THEM. AND, ALSO, TO THE EXTENT IT WAS FORMED IN 5 JULY OF 2016, IT MAY OR MAY NOT BE CONSIDERED LATE 2016. 6 IF YOU HAVE A REPRESENTATION AS TO WHEN R.O.W.
7 TERMINATED AND R.O.W. P.A.C. BEGAN, THAT MAY HELP THE 8 CLIENT -- THE WITNESS TESTIFY.
9 MR. COLIN: WELL, I DON'T REPRESENT R.O.W. OR
10 R.O.W. P.A.C., SO I DON'T WANT TO STATE ANYTHING ABOUT 11 WHEN ONE -- ONE ENDED BECAUSE THEY DON'T THINK R.O.W. 12 HAS -- HAS CEASED TO EXIST, AND WITH R.O.W. P.A.C., I 13 DON'T KNOW IF R.O.W. P.A.C. HAS CEASED TO EXIST.
14 Q. SO I'M TRYING TO GET FROM YOU, MR. VOISEY,
021318.txt
15 WHAT YOU SAW NILS NEHRENHEIM DO THAT CONSTITUTED THIS 16 CONTROL OVER R.O.W. P.A.C., THE POLITICAL ACTION
17 COMMITTEE, IF YOU'RE ABLE TO DISTINGUISH HIS ACTIONS AS 18 AGAINST R.O.W. OR THE POLITICAL ACTION COMMITTEE.
19 A. AGAIN, IT WAS DIFFICULT BECAUSE OF THE SIGNAGE
20 AND THINGS THAT WERE BEING CARRIED AND DISTRIBUTED AT 21 FIRST DURING THE CAMPAIGN. IT'S UNCLEAR WHETHER THEY 22 WERE THE COMMITTEE OR THE P.A.C., AS ALREADY STATED
23 SEVERAL TIMES; BUT I DO KNOW THAT I HAD CONSTANTLY SEEN 24 NILS ON MANY TIMES, INCLUDING AT THE COASTAL COMMISSION 25 ON FEBRUARY 7 -- I BELIEVE 7TH OR 9TH, SPEAKING ON
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1 BEHALF OF R.O.W. IN WHATEVER CAPACITY IT WAS.
2 AND, TYPICALLY, IN, YOU KNOW, COMMON LAYMEN,
3 NONEXPERT TERMS, TO ME, R.O.W. IS R.O.W. THROUGHOUT THE 4 JOURNEY OF THIS BECAUSE THEY WEREN'T USING THE
5 R.O.W. P.A.C. ON ANY OF THEIR LITERATURE OR SIGNAGE.
6 Q. WELL, WHEN YOU TESTIFIED EARLIER TODAY THAT
7 YOU HAD GONE TO ONE OF THE R.O.W. MEETINGS AND YOU
8 BELIEVE YOU HAD RECEIVED SOMETHING THAT LOOKED LIKE THE 9 KING HARBOR CARE ACT, DID THAT HAVE A DISCLAIMER THAT IT
021318.txt
10 WAS PART OF R.O.W. P.A.C. OR DISTRIBUTED BY
11 R.O.W. P.A.C.?
12 A. I DON'T RECALL.
13 Q. OKAY. AND YOU'RE REFERENCING MR. NEHRENHEIM'S
14 APPEARANCE AT AT LEAST ONE COASTAL COMMISSION. IS THAT 15 A PUBLIC HEARING?
16 A. IT WAS IN PUBLIC COMMENT.
17 Q. OKAY. AND WAS THE COASTAL COMMISSION MEETING
18 OPEN TO THE PUBLIC?
19 A. YES.
20 Q. OKAY. AND YOU WERE PRESENT?
21 A. YES.
22 Q. ALL RIGHT. AND NILS NEHRENHEIM WAS PRESENT.
23 WHAT ABOUT BILL BRAND, WAS HE PRESENT?
24 A. NO.
25 Q. AND THIS TOOK PLACE IN FEBRUARY OF 2017?
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1 A. CORRECT.
2 Q. PRIOR TO THE MARCH 7TH ELECTION?
3 A. CORRECT.
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4 Q. OKAY. AND DID -- DID YOU ASSUME THAT BY
5 MR. -- BY MR. NEHRENHEIM BEING AT THAT COASTAL
6 COMMISSION MEETING, THAT HE WAS EXERTING CONTROL OVER 7 R.O.W. P.A.C.?
8 MR. HERTZ: SAME OBJECTION WITH REGARD TO A
9 LEGAL CONCLUSION.
10 YOU CAN ANSWER.
11 THE WITNESS: AM I SAYING HE WAS ON
12 R.O.W. P.A.C. AT THAT POINT? IT APPEARS SINCE WE WERE 13 INTO THE FULL SWING OF THE CAMPAIGN, TO ME, IT WOULD 14 APPEAR THAT HE IS PART OF THE R.O.W. P.A.C.
15 Q. BY MR. COLIN: OKAY. THAT WAS JUST AN
16 ASSUMPTION ON YOUR PART, CORRECT?
17 A. WELL, THE ASSUMPTION BASED ON WHAT I WOULD
18 KNOW, YES.
19 Q. OKAY. AND YOU KNEW THAT HE WAS CONTROLLING
20 R.O.W. P.A.C. FROM WHAT HE SAID AT THE COASTAL
21 COMMISSION?
22 MR. HERTZ: OBJECTION; MISSTATES THE
23 TESTIMONY.
24 Q. BY MR. COLIN: YOU CAN ANSWER.
25 A. I AGREE. THAT'S NOT WHAT I SAID. I SAID HE
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1 INTRODUCED HIMSELF AS PART OF R.O.W.
2 Q. R.O.W.?
3 A. RESCUE OUR WATERFRONT, SPECIFICALLY.
4 Q. OKAY. AND AT THAT MEETING DIDN'T YOU GET UP
5 AND SPEAK?
6 A. I DID.
7 Q. OKAY. AND AT THAT MEETING -- MEETING, DIDN'T
8 YOU ALSO STATE THAT YOU WERE THERE ON BEHALF OF
9 CENTERCAL?
10 A. NO.
11 Q. WAS THAT MEETING VIDEOTAPED, IF YOU KNOW?
12 A. YES.
13 Q. DID YOU VIDEOTAPE IT?
14 A. I DID NOT VIDEOTAPE IT.
15 Q. OKAY. HAVE YOU SEEN ANY RECORDINGS OF THAT
16 MEETING?
17 A. I HAVE SEEN -- I DID WATCH MYSELF, YES.
18 Q. OKAY. AND DID YOU WATCH YOURSELF INDICATE
19 THAT YOU WERE THERE ACTING ON BEHALF OF CENTERCAL?
20 A. NO, I DON'T REMEMBER THAT.
21 Q. OKAY.
22 A. THAT WOULD BE A MISREPRESENTATION IF I HAD
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23 SAID SOMETHING LIKE THAT.
24 Q. OKAY. ALL RIGHT. YOU ALSO IN THAT SAME
25 PARAGRAPH 20 ALLEGE THAT THE:
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1 "DEFENDANTS FAILED TO DISCLOSE
2 BRAND'S AND NEHRENHEIM'S
3 CONTROLLING CANDIDATE STATUS ON
4 THEIR CAMPAIGN REPORTS."
5 DID YOU REVIEW ALL OF THE R.O.W. P.A.C.
6 CAMPAIGN REPORTS?
7 A. I HAVE LOOKED THROUGH THEM, YES.
8 Q. OKAY. AND DID YOU ALSO LOOK THROUGH THE BRAND
9 FOR MAYOR 2017 REPORTS?
10 A. I HAVE LOOKED AT THEM, YES.
11 Q. OKAY. AND ALSO THE NEHRENHEIM CAMPAIGN
12 REPORTS, HAVE YOU LOOKED AT THOSE?
13 A. YES.
14 Q. ALL RIGHT. AND WHEN YOU ALLEGE THAT THEY
15 "FAILED TO DISCLOSE BRAND'S AND NEHRENHEIM'S CONTROLLING 16 CANDIDATE STATUS ON THEIR REPORTS," DID YOU FORM AN
021318.txt
17 OPINION THAT THAT WAS NECESSARY FOR R.O.W. TO DO?
18 MR. HERTZ: OBJECTION TO THE TERM "NECESSARY"
19 AS VAGUE AND AMBIGUOUS.
20 Q. BY MR. COLIN: OR REQUIRED UNDER THE
21 POLITICAL REFORM ACT?
22 A. I WOULD ASSUME THAT THEY WOULD HAVE TO BE
23 REPORTING EVERYTHING.
24 Q. WELL, AND THAT WAS YOUR -- YOUR OPINION OR IS
25 IT AN ASSUMPTION?
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1 A. I AM NOT AN EXPERT IN THAT FIELD.
2 Q. OKAY. AND THEN PARAGRAPH 22 OF THE COMPLAINT,
3 THIS IS PAGE 6, YOU ALLEGE:
4 "UPON INFORMATION AND BELIEF,
5 NOTWITHSTANDING DEFENDANT
6 R.O.W. P.A.C.'S AND ITS AGENTS'
7 KNOWLEDGE THAT --" "THAT IT WAS A
8 'PRIMARILY FORMED' COMMITTEE, ON OR
9 ABOUT FEBRUARY 23, 2017, DEFENDANT
10 R.O.W. P.A.C. FILED A RECIPIENT
11 COMMITTEE CAMPAIGN STATEMENT
021318.txt
12 (FORM 460) STATING THAT IT WAS A
13 GENERAL PURPOSE COMMITTEE, AND
14 FAILED TO INCLUDE 'YES ON
15 MEASURE C' OR WORDS TO THAT EFFECT,
16 IN ITS NAME."
17 MY QUESTION TO YOU IS: DID ANYBODY EVER TELL
18 YOU, WHO YOU ASSUME TO BE A PART OF R.O.W. OR R.O.W. 19 P.A.C., THAT THEY WERE THE ONES WHO WERE A PART OF A YES 20 ON MEASURE C POLITICAL ACTION COMMITTEE?
21 A. RESTATE THE -- THERE WAS A LOT IN THERE.
22 Q. DID ANYBODY EVER TELL YOU THAT R.O.W. P.A.C.
23 WAS A PART OF THE -- WAS, IN FACT, THE YES ON C CAMPAIGN 24 COMMITTEE?
25 A. DID ANYBODY TELL ME OR NOTIFY ME OF THAT?
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1 Q. YEAH.
2 A. NO.
3 Q. AND DID YOU EVER OBTAIN ANY INFORMATION
4 THAT -- THAT LED YOU TO BELIEVE THAT R.O.W. P.A.C. WAS 5 THE YES ON C CAMPAIGN COMMITTEE?
021318.txt
6 MR. HERTZ: OTHER THAN THROUGH CONVERSATIONS
7 WITH COUNSEL?
8 Q. BY MR. COLIN: OTHER THAN TALKING WITH YOUR
9 LAWYER.
10 A. I INQUIRED WHY -- ACTUALLY, WHEN I DISCOVERED
11 THIS, I INQUIRED WHY THERE WAS NO FPPC NUMBER ON THE 12 SIGNS AND THEIR LITERATURE AND FOUND OUT LATER THAT IT 13 WAS -- THAT THAT WAS NOT CORRECT, THAT THERE SHOULD HAVE 14 BEEN SOMETHING THERE, AND THAT THIS IS TECHNICALLY -- I 15 ASSUMED THAT THERE WAS A YES ON MEASURE C COMMITTEE
16 SPECIFICALLY PUT TOGETHER, BUT LATER HAD FOUND OUT THAT 17 THIS IS BEING RUN BY THE R.O.W. P.A.C., OR TO BE HONEST, 18 TO RESCUE OUR WATERFRONT SPECIFICALLY -- THE WORD P.A.C. 19 WAS NOT ENTERING IN OR OUT OF IT AT THAT POINT -- AND, 20 YOU KNOW, CAME TO LEARN THROUGH LATER UNDERSTANDING OF 21 THIS THAT THIS IS AN ABSOLUTE VIOLATION ALL THE WAY
22 AROUND WHERE THESE WERE -- THEY SHOULD HAVE BEEN LABELED 23 DIFFERENTLY. THERE SHOULD HAVE BEEN A SPECIFIC YES ON 24 C GROUP.
25 Q. DID YOU BECOME AWARE OF THE YES ON C GROUP, AS
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1 YOU USED THAT PHRASE, DID YOU BECOME AWARE OF THAT GROUP 2 HAVING A CAMPAIGN HEADQUARTER?
3 A. SPECIFIC HEADQUARTER? NO.
4 Q. OKAY. AND YOU SAID -- AND WHO WAS IT THAT
5 TOLD YOU THAT THE YES ON C CAMPAIGN WAS BEING RUN BY
6 R.O.W.?
7 A. OH, I -- I JUST BASICALLY FIGURED IT OUT
8 EVENTUALLY THROUGH ONLINE POSTINGS BY THEM.
9 Q. OKAY. BUT EARLIER YOU SAID THAT YOU HAD BEEN
10 TOLD BY SOMEBODY THAT THE YES ON C CAMPAIGN WAS RUN BY 11 R.O.W. WHO TOLD YOU THAT?
12 A. OH, TOLD, IT WOULD HAVE BEEN THROUGH -- TOLD
13 THROUGH READING IT ON THE INTERNET. I'M NOT SAYING
14 SOMEBODY SPECIFICALLY SAID, "CHRIS, THIS IS IT."
15 Q. OKAY. SO NOBODY TOLD YOU THAT. YOU JUST
16 ASSUMED FROM READING MATERIAL THAT R.O.W. WAS THE
17 YES ON C CAMPAIGN; IS THAT CORRECT?
18 A. I CONCLUDED, YEAH.
19 Q. OKAY. ALL RIGHT. AND AT PARAGRAPH 23 OF THE
20 COMPLAINT, YOU ALLEGE THAT "R.O.W. P.A.C. AND BILL BRAND 21 COORDINATED FUNDRAISING EVENTS AND OPERATED
22 SIDE-BY-SIDE."
23 WHAT DID YOU MEAN BY THAT?
24 A. THE FUNDRAISERS THAT WERE HELD AT R/10 --
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25 WHAT'S IT CALLED? -- SAMBA, AND ONE AT SHADE, IF I
149
EXCEL COURT REPORTERS
1 RECALL CORRECTLY, WERE ALL -- FOR ALL OF THESE CAMPAIGNS 2 TOGETHER.
3 Q. OKAY. WHEN WERE THESE FUNDRAISERS HELD?
4 A. THROUGHOUT FEBRUARY -- THROUGHOUT JANUARY,
5 FEBRUARY, MARCH, TO THE BEST OF MY RECOLLECTION --
6 Q. OF WHAT YEAR?
7 A. -- EARLY MARCH, OBVIOUSLY.
8 Q. WHAT YEAR?
9 A. 2017.
10 Q. DID YOU ATTEND ANY OF THESE FUNDRAISERS AS
11 R/10, SAMBA'S OR SHADE?
12 A. NO.
13 Q. OKAY. YOU ALSO ALLEGE IN PARAGRAPH 23 THAT
14 THEY WERE "SHARING INFORMATION, CAMPAIGN MESSAGES, AND 15 OTHER RESOURCES." WHAT DID YOU MEAN BY THAT?
16 A. CAMPAIGN RESOURCES, THE FEET ON THE FEET WERE
17 COMMINGLED AND ALL, ALL BEING DISTRIBUTED AND TALKED TO 18 AT THE SAME TIME BY THE SAME CANVASSERS. BROCHURES WERE
021318.txt
19 WRITTEN IN A WAY THAT THEY COULD BE FOR CANDIDATE OR YES 20 ON C.
21 Q. OKAY. DO YOU KNOW THE NAMES OF ANY OF THE
22 SAME CANVASSERS THAT YOU CLAIM WERE OUT DISTRIBUTING 23 MATERIAL FOR THESE DEFENDANTS JOINTLY?
24 A. THE NAMES OF THE CANVASSERS?
25 Q. THAT YOU OBSERVED.
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EXCEL COURT REPORTERS
1 A. OH, THAT I -- THAT I OBSERVED? I'M REALLY BAD
2 WITH FACES TO NAMES. I CAN'T GIVE YOU A SPECIFIC NAME. 3 I COULD RECOGNIZE AND ACKNOWLEDGE THAT THERE WAS A
4 PERSON --
5 Q. OKAY.
6 A. -- BUT NOT BY NAME.
7 Q. OKAY. AND CAN YOU STATE WITH CERTAINTY
8 WHAT -- WHAT BROCHURES OR WHAT MATERIAL THESE UNNAMED 9 CANVASSERS WERE -- WERE DISTRIBUTING WHEN YOU SAW THEM 10 DOING THIS?
11 A. YEAH; BECAUSE I WAS FOLLOWING -- I WAS BEHIND
12 THEM IN SOME CASES --
13 Q. OKAY.
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14 A. -- DOING -- DROPPING THE SAME THING FOR OTHER
15 CANDIDATES.
16 Q. YOU WERE DROPPING OFF MATERIAL FOR
17 MARTHA BARBEE AND --
18 A. KNOCKING ON DOORS AND STUFF.
19 Q. -- AND THE NO ON C?
20 A. YES.
21 Q. SO YOU WERE DOING THE SAME THING?
22 A. YES.
23 Q. BUT YOU CAN'T TELL ME --
24 A. NOT FOR -- I WAS NOT DOING IT FOR THE NO ON C.
25 Q. OKAY. WELL, WHO WERE YOU DOING IT FOR?
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1 A. FOR MARTHA OR STEVE ASPEL AT ONE POINT.
2 Q. STEVE ASPEL FOR MAYOR?
3 A. YES.
4 Q. AND THIS IS THE SOMEWHAT FRIEND THAT YOU
5 DESCRIBED EARLIER?
6 A. YEAH.
7 Q. OKAY.
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8 A. YES.
9 Q. AND HE WAS RUNNING FOR MAYOR AGAINST
10 BILL BRAND, CORRECT?
11 A. CORRECT.
12 Q. ALL RIGHT. AND DID YOU SEE SOME OF THESE SAME
13 CANVASSERS THROUGHOUT THE AREA WHERE YOU WERE
14 CANVASSING?
15 A. YES.
16 Q. AND IN LOOKING AT ALL THE ARTICLES AND
17 PHOTOGRAPHS ON THE INTERNET THAT YOU LOOKED AT TO PUT 18 TOGETHER THIS LAWSUIT, YOU'RE UNABLE TO NAME ANY OF THE 19 PEOPLE WHO -- OR ANY OF THESE SAME CANVASSERS THAT YOU 20 SAW DISTRIBUTING ITEMS?
21 MR. HERTZ: OBJECTION; ARGUMENTATIVE.
22 Q. BY MR. COLIN: OKAY. ALL RIGHT.
23 MR. HERTZ: YOU CAN ANSWER.
24 THE WITNESS: SIMPLE ANSWER IS THAT LOOKING AT
25 A NAME AND LOOKING AT PHOTOS, I DON'T GO AND LOOK AT WHO 152
EXCEL COURT REPORTERS
1 IS WHO; AND THE PHOTOS ARE JUST LITTLE, TINY STAMPS
2 THAT -- NO, AND I DON'T WANT TO MISREPRESENT A NAME
021318.txt
3 UNOFFICIALLY.
4 Q. BY MR. COLIN: RIGHT. OKAY. ALL RIGHT.
5 AT PAGE 7 OF THE COMPLAINT, PARAGRAPH 28, IT
6 READS:
7 "UPON INFORMATION AND BELIEF,
8 GOVERNMENT CODE SECTION 82047.5
9 DEFINES A PRIMARILY FORMED
10 COMMITTEE AS A COMMITTEE WHICH IS
11 FORMED OR EXISTS PRIMARILY TO
12 SUPPORT OR OPPOSE, AMONG OTHER
13 THINGS, A SINGLE BALLOT MEASURE."
14 AND THE NEXT PARAGRAPH 29
15 READS:
16 "UPON INFORMATION AND BELIEF,
17 2 CALIFORNIA CODE OF REGULATIONS,
18 SECTION 18247.5(F)," IN PARENS,
19 "REQUIRES COMMITTEES SUCH AS
20 R.O.W. P.A.C. TO FILE AS PRIMARILY
21 FORMED COMMITTEES."
22 MY QUESTION IS WHAT -- WHAT INFORMATION DO YOU
23 HAVE THAT LEADS YOU TO ALLEGE THAT R.O.W. P.A.C. WAS 24 REQUIRED TO FILE AS A PRIMARILY FORMED COMMITTEE?
25 MR. HERTZ: OBJECTION, VAGUE AND AMBIGUOUS;
153
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EXCEL COURT REPORTERS
1 AND MORE IMPORTANTLY, CALLS FOR A LEGAL CONCLUSION WITH 2 REGARD TO THE TERM "PRIMARILY FORMED COMMITTEE."
3 BUT YOU CAN ANSWER.
4 THE WITNESS: WELL, I BELIEVE THAT THEY WOULD
5 HAVE BEEN REQUIRED TO -- REQUIRED TO REGISTER PROPERLY 6 FOR -- FOR, FIRST OF ALL, THE YES ON C CAMPAIGN ITSELF 7 IN USING THAT NAME WITH IT; AND, SECOND, FOR THE AMOUNT 8 OF EXPENDITURE AND, YOU KNOW, GUESSTIMATES OF -- YOU
9 KNOW, WELL, OVER $2,000 THAT WOULD HAVE BEEN TO -- TO 10 RUN THE CAMPAIGN.
11 Q. BY MR. COLIN: OKAY. DO YOU HAVE ANY LEGAL
12 TRAINING?
13 A. NO.
14 Q. DID YOU ATTEND LAW SCHOOL?
15 A. NO.
16 Q. OKAY. AND YOU SAID THAT THEY WOULD HAVE BEEN
17 REGISTERED OR REQUIRED TO REGISTER AS A YES ON C
18 CAMPAIGN COMMITTEE. IS THAT JUST AN ASSUMPTION THAT
19 YOU'RE MAKING?
20 A. I HAVE ASKED OTHERS ABOUT THAT, BECAUSE I
021318.txt
21 ASKED WHY THE TWO HAVE COORDINATED, AND PEOPLE HAVE TOLD 22 ME THAT YOU DO HAVE TO REGISTER IT THAT WAY.
23 Q. OKAY. WITHOUT INVADING ON ANY CONVERSATIONS
24 YOU MAY HAVE HAD WITH YOUR ATTORNEY, WHO WERE THESE
25 OTHER PEOPLE -- WHO WERE THESE OTHER PEOPLE THAT TOLD 154
EXCEL COURT REPORTERS
1 YOU THAT -- THAT R.O.W. P.A.C. SHOULD HAVE -- SHOULD
2 HAVE BEEN REQUIRED TO FILE AS A PRIMARILY FORMED
3 COMMITTEE?
4 MR. HERTZ: I'LL OBJECT.
5 AND, ALSO, INCLUDE ANY OTHER ATTORNEYS YOU MAY
6 HAVE SPOKEN TO ABOUT THAT THAT YOU SHOULD -- THAT I
7 RECOMMEND YOU EXCLUDE THAT IN CASE --
8 THE WITNESS: OKAY.
9 MR. HERTZ: -- YOU HAD AN ATTORNEY/CLIENT
10 RELATIONSHIP.
11 MR. COLIN: RIGHT. HE'S ALREADY SAID HE
12 CONSULTED WITH MULTIPLE ATTORNEYS.
13 Q. SO WITHOUT DISCLOSING ANY ATTORNEYS, WHO WERE
14 THESE OTHER PEOPLE THAT TOLD YOU R.O.W. P.A.C. WAS
15 REQUIRED TO FILE AS A PRIMARILY FORMED COMMITTEE?
021318.txt
16 A. I TALKED TO TWO CAMPAIGN MANAGERS --
17 Q. GIVE ME THEIR NAMES.
18 A. -- THAT I MET UP AND -- YOU KNOW, AT EVENTS.
19 LARRY FOX AND -- I AM DRAWING A BLANK.
20 Q. ALL RIGHT. WELL, MAYBE YOU'LL THINK OF THE
21 OTHER NAME.
22 LARRY FOX, WAS LARRY FOX CONSULTING?
23 A. YES.
24 Q. THE GUY WITH THE HOLE IN HIS THROAT?
25 A. THAT WOULD BE ACCURATE, YES.
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EXCEL COURT REPORTERS
1 Q. LIVES DOWN ON THE ESPLANADE?
2 A. YES.
3 Q. MR. FOX IS NOT AN ATTORNEY, IS HE?
4 A. HE'S A CAMPAIGN SPECIALIST.
5 Q. OKAY. HE'S NOT AN ATTORNEY, IS HE?
6 A. I DIDN'T SAY I WAS TALKING ABOUT ATTORNEYS.
7 Q. RIGHT.
8 A. YOU ASKED WHO.
9 Q. RIGHT. NO, OKAY.
021318.txt
10 AND SO LARRY FOX TOLD YOU THAT R.O.W. P.A.C.
11 WAS PRIMARILY FORMED. DID HE TELL YOU WHAT HE WAS
12 BASING HIS OPINION ON?
13 A. OKAY. SO YOU ARE PUTTING WORDS IN MY MOUTH.
14 I ASKED HIM IF IT WAS TRUE THAT YOU HAD TO HAVE THE NAME 15 COINCIDE WITH IT, AND HE HAD SAID THAT "YES, THAT'S THE 16 WAY THAT YOU FORM THESE COMMITTEES."
17 Q. OKAY. SO HE WAS DISPENSING LEGAL ADVICE TO
18 YOU?
19 A. HE WAS ADVISING --
20 MR. HERTZ: OBJECTION; THAT MISSTATES THE
21 TESTIMONY.
22 THE WITNESS: YEAH, EXACTLY.
23 Q. BY MR. COLIN: OKAY. WAS MR. FOX THE
24 CONSULTANT FOR THE MARTHA BARBEE CAMPAIGN?
25 A. I DON'T BELIEVE SO.
156
EXCEL COURT REPORTERS
1 Q. WAS LARRY FOX --
2 A. NO.
3 Q. -- A CONSULTANT FOR ANY OF THE STEVE ASPEL'S
4 CAMPAIGNS?
021318.txt
5 A. I DON'T THINK SO.
6 Q. OKAY. MR. FOX WAS ONE OF THE CONSULTANTS THAT
7 THE NO ON C CAMPAIGN PAID FOR CONSULTING SERVICES,
8 WASN'T HE?
9 A. I'M NOT FAMILIAR WITH THAT SIDE OF IT.
10 Q. YOU REVIEWED ALL OF THE CAMPAIGN STATEMENTS OF
11 THE DEFENDANTS. DID YOU REVIEW THE CAMPAIGN STATEMENTS 12 OF THE NO ON C CAMPAIGN?
13 A. NO.
14 Q. OKAY. ALL RIGHT. SO OTHER THAN LARRY FOX
15 TELLING YOU THAT R.O.W. P.A.C. SHOULD HAVE BEEN A
16 PRIMARILY FORMED COMMITTEE, WAS THERE ANYBODY ELSE THAT 17 YOU CAN RECALL NOW? DO YOU RECALL THAT SECOND NAME?
18 A. I DON'T.
19 Q. OKAY.
20 A. MY APOLOGIES.
21 Q. AND IN PARAGRAPH 31 YOU SAY:
22 "UPON INFORMATION AND BELIEF,
23 AT ALL RELEVANT TIMES DEFENDANT
24 R.O.W. P.A.C. ILLEGALLY OPERATED,
25 AND CONTINUES TO OPERATE, AS A
157
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1 GENERAL PURPOSE COMMITTEE IN
2 VIOLATION OF REGULATION
3 18247.5(F)."
4 OKAY. WHAT INFORMATION -- BECAUSE IT SAYS
5 "UPON INFORMATION." I'M WONDERING WHAT INFORMATION YOU 6 HAVE THAT LEADS YOU TO PLEAD THAT R.O.W. P.A.C. IS
7 OPERATING ILLEGALLY AS A GENERAL PURPOSE COMMITTEE?
8 MR. HERTZ: OBJECTION TO THE TERM "GENERAL
9 PURPOSE COMMITTEE" AS A LEGAL TERM OF ART; AND,
10 THEREFORE, CALLING FOR A LEGAL CONCLUSION.
11 BUT YOU CAN ANSWER AS TO YOUR INFORMATION.
12 THE WITNESS: UPON INFORMATION AND BELIEF
13 THAT -- THAT I BELIEVE I ASKED AN ATTORNEY TO HELP
14 VERIFY THIS, AND I WAS GIVEN THE ADVICE THAT IT WAS. 15 Q. BY MR. COLIN: OKAY. THE ATTORNEY WASN'T YOUR
16 CURRENT ATTORNEY, WAS IT?
17 MR. HERTZ: I'LL OBJECT AND INSTRUCT HIM NOT
18 TO ANSWER TO THE EXTENT THAT INVADES THE ATTORNEY/CLIENT 19 PRIVILEGE.
20 Q. BY MR. COLIN: OKAY. SO OTHER THAN ANYTHING
21 THAT YOU MIGHT HAVE BEEN TOLD BY LAWYERS, DO YOU HAVE 22 ANY PERSONAL INFORMATION THAT LEADS YOU TO BELIEVE THAT
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23 R.O.W. P.A.C. IS OPERATING CURRENTLY, ILLEGALLY, AS A 24 GENERAL PURPOSE COMMITTEE?
25 A. LEGALLY, I AM NOT ABLE TO SAY THAT THEY ARE OR
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EXCEL COURT REPORTERS
1 NOT. I CAN ONLY ASK THE OPINIONS OF MY ATTORNEY --
2 Q. OKAY.
3 A. -- OR ATTORNEYS THAT I CONSULT WITH, AND
4 THAT'S WHERE I'M GETTING MY INFORMATION.
5 Q. ALL RIGHT. AND EARLIER YOU MENTIONED THIS
6 LARRY FOX. HE ALSO GOES BY THE NAME OF LAWRENCE FOX,
7 DOESN'T HE?
8 A. I ONLY KNOW HIM AS -- CASUALLY, AS "LARRY."
9 Q. OKAY. LET ME JUST INDICATE TO YOU ON
10 SCHEDULE E OF THE CALIFORNIA FORM 460 THAT WAS FILED BY 11 THE NO ON MEASURE C, SAVE THE WATERFRONT WITH MAJOR
12 FUNDING BY REDONDO BEACH WATERFRONT, LLC, AND MR. HERTZ 13 IS THE ASSISTANT TREASURER OF THIS CAMPAIGN COMMITTEE. 14 IT INDICATES THAT FOR THE STATEMENT PERIOD OF JANUARY 1, 15 2017, TO JUNE 30TH, 2017, A LAWRENCE FOX WAS PAID $7,000 16 AND AN ADDITIONAL $781.59.
17 DID MR. FOX EVER TELL YOU THAT HE HAD BEEN
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18 PAID MONEY BY THAT CAMPAIGN COMMITTEE?
19 A. IT WOULDN'T HAVE BEEN APPROPRIATE CONVERSATION
20 OF ASKING THAT.
21 Q. OKAY. ALL RIGHT. NOW I'M GOING TO ASK YOU TO
22 TURN TO PAGE 10 OF YOUR COMPLAINT. THIS IS THE PRAYER, 23 AND IT'S THE LAST PAGE BEFORE YOUR VERIFICATION AND
24 ARNETTE TRAVIS' VERIFICATION, AND IT READS:
25 "WHEREFORE, PLAINTIFFS PRAY --"
159
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1 AND YOU'RE ONE OF THE PLAINTIFFS --
2 "THAT THIS COURT ISSUE A TEMPORARY
3 RESTRAINING ORDER, PRELIMINARY
4 INJUNCTION, AND PERMANENT
5 INJUNCTION ORDERING DEFENDANTS --"
6 "ORDERING DEFENDANTS TO COMPLY WITH
7 THE APPLICABLE PROVISIONS OF THE
8 POLITICAL REFORM ACT AND RELATED
9 REGULATIONS AS DESCRIBED ABOVE.
10 "NO. 2, THAT THE COURT AWARD
11 PLAINTIFFS COSTS, INCLUDING
021318.txt
12 ATTORNEYS' FEES, PURSUANT TO
13 GOVERNMENT CODE SECTION 91003,"
14 COMMA, "TO BE RECOVERED FROM
15 DEFENDANTS."
16 OKAY? DO YOU SEE THAT? OKAY.
17 HOW MUCH HAVE YOU SPENT IN ATTORNEYS' FEES
18 PROSECUTING THIS ACTION AS OF TODAY'S DATE?
19 MR. HERTZ: OBJECTION, THAT VIOLATES THE
20 ATTORNEY/CLIENT PRIVILEGE; AND I'LL INSTRUCT THE WITNESS 21 NOT TO ANSWER.
22 Q. BY MR. COLIN: OKAY. MR. VOISEY, DID YOU SIGN
23 A RETAINER AGREEMENT WITH YOUR ATTORNEY TO REPRESENT YOU 24 IN THIS MATTER?
25 MR. HERTZ: SAME OBJECTION AND SAME
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1 INSTRUCTION.
2 Q. BY MR. COLIN: OKAY. IS THIS LAWSUIT BEING
3 FUNDED BY CENTERCAL PROPERTIES, LLC?
4 MR. HERTZ: SAME OBJECTION AND SAME
5 INSTRUCTION.
6 Q. BY MR. COLIN: IS THIS LAWSUIT BEING FUNDED BY
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7 WESTPORT CAPITAL?
8 MR. HERTZ: SAME OBJECTION AND SAME
9 INSTRUCTION.
10 Q. BY MR. COLIN: IS THIS LAWSUIT BEING FUNDED BY
11 REDONDO WATERFRONT, LLC?
12 MR. HERTZ: SAME OBJECTION AND SAME
13 INSTRUCTION.
14 Q. BY MR. COLIN: OKAY. HAVE YOU RECEIVED
15 ANYTHING OF VALUE FROM FRED BRUNING OR JEAN PAUL WARDY 16 TO PROSECUTE THIS ACTION AGAINST THESE DEFENDANTS?
17 A. NO.
18 Q. OKAY. NOW, EARLIER I ASKED YOU IF YOU KNEW A
19 RICHARD SCHMIDT AND YOU SAID "NO." DO YOU KNOW THAT
20 MR. SCHMIDT HAD BEEN PAID BY CENTER- -- BY THIS CAMPAIGN 21 COMMITTEE -- THE NO ON C CAMPAIGN COMMITTEE AS AN
22 EMPLOYEE FOR THE POLITICAL ACTION COMMITTEE? DID YOU 23 KNOW THAT?
24 A. NO.
25 Q. OKAY. DID YOU EVER SEE RICHARD SCHMIDT AT THE
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1 BAY CLUB OFFICES WHERE THE NO ON C CAMPAIGN WAS BEING 2 RUN?
3 A. THE NAME IS NOT FAMILIAR TO ME.
4 Q. OKAY. WHAT ABOUT THE NAME MICHAEL CAHALAND,
5 C-A-H-A-L-A-N-D, 506 SOUTH GERTRUDA AVENUE IN REDONDO; 6 DO YOU KNOW HIM?
7 A. IS HE THE ONE THAT FILED A COMPLAINT AT -- IN
8 FRONT OF CITY COUNCIL?
9 Q. WELL, I'M ASKING YOU IF YOU KNOW HIM.
10 A. I DON'T KNOW HIM, NO.
11 Q. OKAY. HAS ANYBODY EVER TOLD YOU THAT
12 MICHAEL CAHALAN FILED A COMPLAINT WITH SIMILAR
13 ALLEGATIONS TO WHAT'S INCLUDED IN THIS COMPLAINT, BUT 14 ONLY THAT COMPLAINT WENT TO THE FPPC?
15 A. I REMEMBER -- IF THIS IS WHO IT WAS, I DO
16 REMEMBER A COMPLAINT, BUT I DON'T REMEMBER IT BEING
17 ANYTHING TO DO WITH THIS. I DO REMEMBER IT AGAINST, IF 18 I RECALL, THE R.O.W. CAMPAIGN, BUT NOT RECALLING ANY 19 SPECIFICS. I DON'T THINK I EVER SAW THAT.
20 Q. OKAY. HAVE ANY MEMBERS OF THE CURRENT CITY
21 COUNCIL EVER ENCOURAGED YOU TO PROSECUTE YOUR LAWSUIT 22 AGAINST THESE DEFENDANTS?
23 A. NO.
24 Q. HAS STEVE ASPEL EVER ENCOURAGED YOU TO
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25 PROSECUTE THIS LAWSUIT AGAINST THE NAMED DEFENDANTS? 162
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1 A. NO.
2 Q. OKAY.
3 A. CAN WE TAKE A BREAK HERE? OR --
4 Q. OH, SURE. LET'S GO AHEAD AND TAKE TEN
5 MINUTES. I'M SORRY.
6 A. OH, AND I DO HAVE THAT -- GOOD TIMING?
7 Q. OKAY.
8 MR. HERTZ: TEN MINUTES? ALL RIGHT. THANKS.
9 (A 12-MINUTE RECESS WAS TAKEN.)
10 MR. COLIN: OKAY. SO LET'S GO BACK ON THE
11 RECORD.
12 IT'S APPROXIMATELY 3:15 AND WE HAVE LEARNED
13 THAT THE DEPONENT HAS A FAMILY EMERGENCY THAT HE NEEDS 14 TO GET TO, AND WE HAVE TALKED OFF -- OFF THE RECORD THAT 15 THERE REMAINS ABOUT ANOTHER THREE AND A HALF HOURS
16 THAT'S AVAILABLE TO DEPOSE MR. VOISEY. SO AT THIS POINT 17 WE'RE GOING TO STOP THE DEPOSITION, AND I'M GOING TO ASK 18 THAT THE TRANSCRIPT BE LABELED AS VOLUME I, AND WE'LL 19 AGREE TO RECONVENE AT A LATER DATE AGREEABLE TO THE
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20 PARTIES.
21 AND I'LL PROPOSE THIS STIPULATION, AND THAT IS
22 THAT THE ORIGINAL TRANSCRIPT, VOLUME I, WILL BE PREPARED 23 AND FORWARDED TO MR. HERTZ' OFFICE; THAT MR. VOISEY WILL 24 THEN HAVE 30 DAYS FROM RECEIPT OF THE TRANSCRIPT TO READ 25 IT, TO MAKE ANY CHANGES OR CORRECTIONS TO IT, AND SIGN 163
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1 IT UNDER PENALTY OF PERJURY. MR. HERTZ WILL THEN ADVISE 2 ALL COUNSEL OF ANY CHANGES OR CORRECTIONS THAT HAVE BEEN 3 MADE AND OF THE FACT THAT IT'S BEEN SIGNED UNDER PENALTY 4 OF PERJURY; THAT HE WILL RETAIN CUSTODY OF THE ORIGINAL, 5 AND UPON REQUEST, I'LL ASK THAT IT BE PRODUCED AT THE 6 TIME OF TRIAL OR ANY OTHER PROCEEDINGS IN THIS MATTER. 7 HE WILL KEEP THE ORIGINAL; AND IN THE EVENT THE ORIGINAL 8 ISN'T PRODUCED, CAN'T BE LOCATED OR FOR SOME REASON IS 9 STOPPED, THAT AN UNSIGNED CERTIFIED COPY MAY BE USED IN 10 LIEU OF THE ORIGINAL.
11 MR. HERTZ: BEFORE STIPULATING, JUST SO I
12 DON'T FORGET, MAY I INCLUDE MY OBJECTIONS AS AN EXHIBIT 13 TO THIS VOLUME I?
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14 MR. COLIN: YES. THAT WILL BE EXHIBIT 10.
15 MR. HERTZ: THANK YOU.
16 (THE AFOREMENTIONED DOCUMENT
17 WAS MARKED BY THE COURT REPORTER
18 AS PLAINTIFFS' EXHIBIT 10 FOR
19 IDENTIFICATION; ATTACHED HERETO.)
20 MR. HERTZ: AND SO STIPULATED.
21 MR. COLIN: ALL RIGHT. SO STIPULATED. THANK
22 YOU.
23 MS. ZIMMER: SO STIPULATED.
24 MR. NAYEBDADASH: SO STIPULATED.
25 (THE DEPOSITION ADJOURNED AT 3:14 P.M.)
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1 * * *
2 3
4 I DECLARE UNDER PENALTY OF
5 PERJURY UNDER THE LAWS OF THE STATE
6 OF CALIFORNIA THAT THE FOREGOING IS
7 TRUE AND CORRECT AND THAT THIS
8 DECLARATION WAS EXECUTED ON THE
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9 ______ DAY OF _________ , 2018, AT
10 _______________, CALIFORNIA.
11 12
13 _______________________
CHRISTOPHER VOISEY
14 15
16 17
18 19
20 21
22 23
24 25
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1 C E R T I F I C A T E
2
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3 I, LAURA D. GUERRERO, CSR NO. 7684, DO HEREBY
4 CERTIFY:
5 THAT CHRISTOPHER VOISEY, THE WITNESS WHOSE
6 DEPOSITION IS HEREINBEFORE SET FORTH, WAS DULY SWORN BY 7 ME TO TESTIFY THE TRUTH, THE WHOLE TRUTH, AND NOTHING 8 BUT THE TRUTH;
9 THAT SAID VOLUME I DEPOSITION WAS TAKEN DOWN
10 BY ME IN SHORTHAND AT THE TIME AND PLACE THEREIN NAMED, 11 AND THEREAFTER REDUCED TO PRINT BY MEANS OF
12 COMPUTER-AIDED TRANSCRIPTION UNDER MY DIRECTION, AND THE 13 SAME IS A TRUE, CORRECT, AND COMPLETE TRANSCRIPT OF SAID 14 PROCEEDINGS.
15 I FURTHER CERTIFY THAT I AM NOT OF COUNSEL OR
16 ATTORNEY FOR EITHER OR ANY OF THE PARTIES IN THE
17 FOREGOING DEPOSITION AND CAPTION NAMED, OR IN ANY WAY 18 INTERESTED IN THE OUTCOME OF THE CAUSE NAMED IN SAID 19 CAPTION.
20 IN WITNESS WHEREOF, I HAVE HEREUNTO SUBSCRIBED
21 MY NAME THIS 12TH DAY OF MARCH, 2018.
22 23 _________________________
24 LAURA D. GUERRERO, CSR
25 166
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1 CORRECTION SHEET
2 3 TRAVIS VS. BRAND
CHRISTOPHER VOISEY
4 FEBRUARY 13, 2018
5 6 PAGE/LINE FROM TO
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