Deposition of Zak Williams

Page 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN

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EXHIBITS Exhibit Description Page Marked/Identified

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THOMAS J. HOLMES, et al.

Plaintiffs, vs.

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Case No. 14-CV-208

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JOHN DICKERT, et al., Defendants.

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Exhibit 1699 ... Press release ................ 87 / 87 Exhibit 1700 ... Journal Times questionnaire for John Dickert ...................... 88 / 88 Exhibit 1701 ... Fund-raising letter for John Dickert p. 90 / 90 Exhibit 1702 ... E-mails between Zak Williams and Greg Bach in April '09 ............ 91 / 92 Exhibit 1703 ... E-mails between Tom Tousis and Zak Williams ................... 114 / 115 Exhibit 1704 ... Article in the Racine Post . 122 / 122

DEPOSITION OF WILLIAM ZACH WILLIAMS TAKEN AT: KOHLER & HART, S.C. LOCATED AT: 735 North Water Street #1212 Milwaukee, Wisconsin September 2, 2015 9:07 a.m. to 4:31 p.m.

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Exhibit 1705 ... E-mail dated 9/22/2009 ..... 134 / 134

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Exhibit 1706 ... E-mails between Zak Williams and Dustin Block dated 4/17/2013 and 4/18/13 .................... 140 / 140

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Exhibit 707 ... March 21, 2014 e-mail ...... 144 / 144

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Exhibit 1708 ... E-mail from Zak Williams to Dustin Block dated 10/25/2010 ..... 146 / 146 Exhibit 1709 ... October 8, 2009 e-mail ..... 138 / 138

REPORTED BY ANNICK M. JAQUET REGISTERED MERIT REPORTER CERTIFIED REALTIME REPORTER

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Exhibit 1710 ... Copy of letter dated 3/23/2010 p. 147 / 147

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A P P E A R A N C E S:

ALSO PRESENT: John Dickert INDEX Page:

Mr. Sanders ................................. 9 Mr. Cohen .................................. 59

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EXHIBITS Exhibit Description Page Marked/Identified

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MEISSNER, TIERNEY, FISHER & NICHOLS, S.C., by Mr. Michael J. Cohen Mr. Dieter J. Juedes 111 East Kilbourn Avenue #1900 Milwaukee, Wisconsin 53202-6622 (414) 273-1300 mjc@mtfn.com djj@mtfn.com Appearing on behalf of the Defendants, except Doug Nicholson.

Examination by: 22 23 24

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KOHLER & HART, S.C., by Mr. Dan H. Sanders 735 North Water Street #1212 Milwaukee, Wisconsin 53202-4105 (414) 271-9595 dhsanders@kohlerandhart.com Appearing on behalf of the Plaintiffs.

GERAGHTY LAW OFFICES, by Mr. David P. Geraghty 2300 North Mayfair Road #470 Milwaukee, Wisconsin 53226-1584 (414) 831-0909 dave@dgeraghtylaw.com Appearing on behalf of William Zachary Williams.

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Exhibit 1711 ... April 26, 2010 e-mail ...... 150 / 150 Exhibit 1712 ... Copy of the letter Zak Williams ghost wrote for Mr. Block ........ 156 / 156 Exhibit 1713 ... Series of e-mails between Zak Williams and Mr. Tousis ............. 152 / 152 Exhibit 1714 ... January 6, 2011 e-mail ..... 157 / 157

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Exhibit 1715 ... January 10, 2011 e-mail .... 160 / 160 Exhibit 1716 ... January 11, 2011 e-mails ... 162 / 162

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Exhibit 1717 ... January 16, 2011 e-mail .... 166 / 166 Exhibit 1718 ... Mail pieces ................ 182 / 182

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Exhibit 1719 ... February 8, 2011 e-mail .... 187 / 187 Exhibit 1720 ... February 11, 2011 e-mail ... 194 / 194

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Exhibit 1721 ... Google alert for Eric Marcus for mayor p. 173 / 173 Exhibit 1722 ... E-mail with walk card attached p. 184 / 185 Exhibit 1723 ... February 13, 2011 e-mail ... 195 / 195

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Exhibit 37

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EXHIBITS

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Exhibit Description Page Marked/Identified 3 4 5

Exhibit Description Page Marked/Identified 3 4

Exhibit 1724 ... February 14 e-mail ......... 198 / 198 Exhibit 1725 ... Jobs4racine.com webpage .... 180 / 180

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Exhibit 1726 ... E-mail ..................... 199 / 199

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Exhibit 1758 ... Series of e-mails .......... 284 / 284

Exhibit 1760 ... June 17, 2013 e-mail ....... 291 / 291 Exhibit 1761 ... July 13, 2013 e-mails ...... 294 / 294

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Exhibit 1733 ... E-mail from Zak Williams to Mr. Scott Sharp ...................... 200 / 200

Exhibit 1762 ... E-mail ..................... 295 / 295 Exhibit 1763 ... Series of e-mails .......... 299 / 299

Exhibit 1734 ... February 18, 2011 e-mail ... 217 / 217 20 21 22

Exhibit 1735 ... E-mails between Zak Williams and Tom Tousis ..................... 218 / 218

Exhibit 1764 ... E-mails .................... 302 / 302 Exhibit 1765 ... December 7, 2014 e-mail .... 303 / 303

Exhibit 1736 ... February 21 e-mail ......... 219 / 219 24 25

Exhibit 1756 ... January 29, 2012 e-mail .... 271 / 271

Exhibit 1759 ... June 14, 2013 e-mail ....... 289 / 289 14 15 16

Exhibit 1731 ... Copy of article ............ 210 / 210 Exhibit 1732 ... February 14, 2011 e-mail ... 216 / 216

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Exhibit 1754 ... E-mail ..................... 264 / 265

Exhibit 1757 ... December 25, 2011 e-mail ... 275 / 275 11 12 13

Exhibit 1729 ... February 9, 2011 e-mail .... 191 / 191 Exhibit 1730 ... Series of e-mails .......... 208 / 209

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Exhibit 1753 ... Copy of e-mail dated 3/29/2011 p. 263 / 263

Exhibit 1755 ... Compilation exhibit ........ 267 / 267

Exhibit 1727 ... E-mail to Zak Williams from Penny Sharp and Tom Reiherzer .... 202 / 202 Exhibit 1728 ... February 25, 2011 e-mail ... 205 / 205

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EXHIBITS

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Exhibit 1737 ... February 25, 2011 e-mail ... 222 / 222

Exhibit 1766 ... December 9, 2014 e-mails ... 306 / 306

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EXHIBITS

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Exhibit Description Page Marked/Identified 3 4 5

Exhibit 1738 ... June 7, 2011 e-mail ........ 226 / 226

Exhibit Description Page Marked/Identified 3 4 5

Exhibit 1739 ... June 8, 2011 e-mail ........ 227 / 227 6 7 8

Exhibit 1740 ... E-mail ..................... 230 / 230

Exhibit 1744 ... July 17, 2011 e-mail ....... 243 / 243 Exhibit 1745 ... Series of e-mails .......... 233 / 234

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Exhibit 1746 ... July 21, 2011 e-mail ....... 247 / 247 Exhibit 1747 ... August 23, 2011 e-mail ..... 250 / 250

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Exhibit 1742 ... July 14, 2011 e-mail ........ 238 /238 Exhibit 1743 ... July 11, 2011 e-mail ....... 241 / 241

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Exhibit 1748 ... December 21, 2011 e-mail ... 252 / 252

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Exhibit 1768 ... E-mail between Zak Williams and centurion8551 .............. 313 / 313

Exhibit 1770 ... Series of Journal Times articles p. 316 / 316

(Also attached are exhibits that were marked at prior depositions in this case.)

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Exhibit 1749 ... July 18, 2011 e-mail ....... 235 / 235 21 22 23

Exhibit 1767 ... March 1, 2011 e-mail ....... 309 / 309

Exhibit 1769 ... February 12, 2014 e-mails .. 314 / 314 Exhibit 1741 ... June 22, 2011 e-mail ....... 232 / 232

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EXHIBITS

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Exhibit 1750 ... September 21, 2011 e-mail .. 254 / 254 Exhibit 1751 ... Series of e-mails .......... 255 / 255

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Exhibit 1752 ... E-mail ..................... 257 / 258

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(The original exhibits were attached to the original transcript. Copies were provided to all counsel.)

(The original transcript was delivered to Attorney Sanders.)

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TRANSCRIPT OF PROCEEDINGS WILLIAM ZACHARY WILLIAMS, called as a witness herein, having been first duly sworn on oath, was examined and testifies as follows: EXAMINATION

BY MR. SANDERS: Q Mr. Williams, my name's Dan Sanders. I represent -- I'm from Kohler and Hart. I represent the plaintiffs in this matter that's termed United States -- or Holmes versus Racine, et al. You're here for a deposition today. We called you for the deposition. You want to introduce yourself?

MR. COHEN: Michael Cohen and Dieter Juedes on behalf of the defendants.

BY MR. SANDERS: Q Mr. Williams, what we're going to do today is I'm going to ask you a series of questions regarding your knowledge of this case, at least certain aspects of it. If you don't understand a question please pause and ask me to repeat it. You have to say "yes" or "no" to the questions or give a narrative response. You can't nod your head or make a "um" or make gestures with your hands. The court reporter

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Correct.

How long were you at Beloit College?

Four years.

Graduated in 1997?

Yes. What was your major?

Political science and communications.

And once you graduated from college what did you do for employment?

After I graduated from college I started working campaigns in the area.

Political campaigns?

Yes. In what capacity?

Low level staffer on, my first campaign was on a congressional race. It's something I had started in college.

Okay. What was the first campaign that you worked on?

It was Joe Wineke.

Was that while you were in college or was that after college?

Oh, after college. The first campaign I worked on was for Judy Robson.

What year was that?

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has to be able to take it down. If you don't know the answer to the question then just say you don't know the answer to the question, all right?

Okay.

Do you have any questions for me?

I do not.

All right. Let's begin.

MR. GERAGHTY: And I'll just, on the record, Dave Geraghty is appearing with Mr. Williams and it's 9:11.

BY MR. SANDERS: Mr. Williams, what's your date of birth?

And where were you born?

Lubbock, Texas.

How long did you live in Texas?

Less than six months.

Okay. Did you ever move to Wisconsin?

Yes. When did you move to Wisconsin?

August of 1993.

What brought you to Wisconsin?

I went to Beloit College.

In Beloit, Wisconsin?

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1994.

Did you say Robson?

Robson, R-O-B-S-O-N. In what capacity did you work for Ms. Robson?

I helped her -- I helped her out on the field.

What types of duties and responsibilities did you have by helping in the field?

I did doors, I interacted with volunteers, helped set up volunteers, I staffed the representative.

Okay. How long did you work on that campaign?

A couple months.

How many campaigns did you work on a year after that, 1994?

Not in 1995, did work on one or several in 1996, and then in spring of '97 while still in college and then in 1998.

Okay. And what kind of work were you doing on the campaigns in '96?

Similar to what I did in '94, doors, phone calls, working with volunteers.

Did that -- did your responsibilities change in the campaigns that you worked on in '97?

No. What about '98?

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A In '98 similar, but I also started to handle the schedule and I was the body guy for the candidate.

Q The what?

A The body guy. I staffed the candidate.

Q Okay. What do you mean by body guy and staffing the candidate?

A I was with the candidate pretty much 24/7, certainly during the campaign, and I was the -the guy who was always with the candidate when he was out campaigning.

Q Okay. And so the first time that you were the body guy or staffing the candidate, that was in 1998?

A Correct.

Q Who was the candidate that you were working for?

A Joe Wineke.

Q Was that a paid position?

A Yes. Q Was that your first paid position?

A No. Q What was your first paid position?

A 1994 with Judy Robson.

Q Okay. And were you paid when you worked in '96

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What was the name of the company?

WZW Consulting.

What did WZW stand for?

It's the initials of my name.

Which are?

William Zachary Williams.

All right. Did you have any employees?

No. What was the purpose of the company?

It's a political consulting company.

Are you familiar with a person by the name of John Dickert?

I am.

How do you know John Dickert?

I have known John Dickert since 1994, mainly through my work on political campaigns.

When did you meet John Dickert in 1994?

October of 1994.

What context?

He was working for Congressman Peter Barca.

What was the setting on which you met him?

I believe we were out doing doors, and then Representative Judy Robson and then Representative Peter Barca or for Congressman Peter Barca did joint doors together, and John

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and '97?

A Yes. Q Okay. Up to this point in 1998 did you have a company or did you just work for the candidates themselves?

A I worked for the candidates themselves.

Q And did you affiliate with a particular political party?

A Yes. Q What party was that?

A The Democratic Party.

Q Were the campaigns that you worked on in '96 and from '94 through '98 were they all in Wisconsin?

A Yes. They were all in Beloit and Rock County.

Q Okay.

A And then in '98 it was in Madison.

Q For Joe Wineke?

A Correct.

Q Did you eventually start your own company?

A I did.

Q When was that?

A 2002.

Q 2002?

A Yes.

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Dickert was with them.

Q All right. So you were doing doors for representative?

A Robson.

Q Robson?

A Yeah.

Q And Dickert was doing doors for Congressman Barca?

A Yes. And the candidates were doing the doors together as well and so that's how we interacted.

Q Okay. So you didn't work with him on Barca's campaign, you were working on Robson's campaign.

A Correct.

Q All right. That was the first time that you met him in October of 1994?

A Yes. Q And do you know what his position was within the Barca campaign?

A I do not. I believe he at one point worked in the congressman's federal office, but I do not know what his title or duties were, and I don't know what his titles or duties were if he worked for the campaign.

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Q Okay. After -- so you worked with him during the campaign. Approximately how long?

A An hour.

Q Oh, so you just met him, on the first occasion you just met him for an hour.

A Correct.

Q Did you have any other contact with him during that campaign -A No. Q -- in 1994?

A No. Q When's the next time you met him?

A Either in 1995 or 1996.

Q In what context?

A Through our interactions of the, trying to find the best way to put this, through the Democratic Party, kind of the regional congressional district party.

Q Were you involved in state, the state's Democratic Party?

A I was a member.

Q Okay. And do you know, at least up to this point in 1995 or 1996, what party John Dickert affiliated with?

A He was also a member of the Democratic Party.

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A Correct.

Q Right. How did you develop a friendship?

A Just from being at the -- at the functions, you know, I think we have similar philosophies, similar political philosophies, and we just -we just clicked.

Q Did you, outside of the meetings did you spend time with him?

A No. Q Did you go to any other social events with him?

A No. Q What about dinners?

A No. Q Out for drinks at all?

A No. Q So just centered on the -- the regional Democratic Party meetings.

A Correct.

Q When's the next -- did you ever work on a campaign with him again?

A Not until -- yes, in 1999.

Q What was that campaign?

A It was Mark Eickhorst for mayor.

Q Where was that?

A It was in Racine.

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So you saw him at Democratic Party functions?

Yes. And you said they were regional?

Yes. Southeast Wisconsin?

It was for the 1st Congressional District.

1st Congressional District?

Yes. What are the boundaries of the 1st Congressional District?

At the time it was Kenosha, Racine, Rock, and Walworth Counties, pretty much the entire -pretty much the entirety of all those counties.

At the time was there a particular county that John Dickert associated with?

Racine.

And you were from Rock?

Correct.

What kind of interaction did you have with him at these regional meetings?

We were friends. We talked about politics.

Now, how did you become friends with him? You had at least up to this point, up to 1995, '96 you'd only had an hour's worth of interaction with him.

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Q How do you spell Eickhorst?

A I believe it's E-I-C-K-H-O-R-S-T or something similar.

Q And was Mr. Eickhorst a candidate?

A Yes. Q A Democratic Party candidate?

A It's a nonpartisan race, but I believe -Q Nonpartisan?

A But I do believe he's a member of the Democratic Party, and the opponent was certainly a member of the Republican Party.

Q And who was the opponent?

A Jim Smith.

Q Was he the current mayor at the time?

A Yes. Q How did you get involved with the Eickhorst candidacy?

A A friend of mine was managing the race and she was having some problems and asked me to help out a little bit in my spare time.

Q Okay. Who's your friend?

A Brenda Kohl. She's married now. I don't know her -- I don't remember her married name.

Q Okay. What was her position within the campaign?

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A She's the campaign manager.

Q What's your understanding of what a campaign manager does?

A The campaign manager runs the day-to-day operations of the campaign.

Q Limiting to local races such as state congressman, state representatives, or assembly members and mayors, up to 1999 you'd been involved at a number of campaigns, correct?

A Correct.

Q What are some of the positions within campaigns of that -- of that nature?

MR. COHEN: Objection, vague.

THE WITNESS: The -- the positions -the positions and those types of campaigns, there are generally not very many. They're low level. A lot of it depends on the size of the budget.

BY MR. SANDERS: Q Okay. Do most of them have a campaign manager?

A Yes. Q All right. What other positions would be in a campaign of those limited size?

A If -- if the budget is high enough you would have someone who would just handle the

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that point, 1999?

No. Had you been a paid campaign manager?

Yes. All right. But you -- you had testified earlier that at least from your earlier campaigns you'd been paid in some context for doing work for campaigns, correct?

Correct.

So when you came into the Eickhorst campaign were you paid -No. -- as a consultant?

I was not.

All right. And what types of things did you do for Brenda Kohl in the Eickhorst campaign?

I helped Brenda with some -- some strategy.

She was having problems with the -- she was having problems with -- with the campaign. It was a tough campaign. Jim Smith is a tough campaigner. Jim Smith was playing a little dirty and she needed my help. I came in just -- I came in every weekend to help her out. I also wrote a couple radio ads for her.

How did you help out with the strategy?

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fund-raising, possibly also someone who would handle the field operation.

Okay. In addition to the campaign manager?

Correct.

And then would the campaign populate with unpaid volunteers?

Correct.

Now, up to this -- this point, 1999 and the Eickhorst mayoral campaign, had you done any fund-raising as a consultant?

No. Had you been a campaign manager up to that point?

Yes. For who?

Dan Shue.

When was that?

1998.

Was that a Beloit area campaign?

Correct. State representative.

And you'd been involved, you previously testified you'd been involved in field operations, correct?

Correct.

Had you ever been a paid field operator up to

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A What areas to focus on, how to best use volunteer time.

Q And you said that that was the next time you worked with -- on a campaign with John Dickert?

A Yes. Q What was John Dickert's function in the campaign?

A He was advising the candidate. He was advising Mark Eickhorst.

Q In what capacity?

A Advising him on strategy.

Q Did you -- did you work with Dickert on -- on advising Eickhorst on strategy?

A Not very much.

Q Why not?

A John had had to take a step away from the campaign because he was working at Foley and Lardner as a lobbyist, and Jim Smith created some problems for him there.

Q In what way?

A I believe he had some problem that Republicans in the legislature call up and in the Thompson administration call up Foley and Lardner and try to get John fired.

Q Do you know if he ever got fired from Foley and

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Lardner?

A I know he left at one point, but I don't know when that was.

Q So when you began working on the Eickhorst campaign was Dickert still there advising or consulting?

A On a very limited basis.

Q All right. So did you come in as his replacement or to supplement what he was doing?

A It was more as a supplement.

Q Did you and Dickert talk about strategy for Eickhorst once you became involved?

A Very limited. I tried not to step on his toes.

I was not trying to do overall strategy. I thought John had a pretty good plan with that and it worked very well. My function was mainly to help Brenda execute that strategy.

Q What was his overall strategy at that point for Eickhorst in the election, if you recall?

A I do not recall.

Q How long were you involved in the campaign?

A Month, month and a half, maybe, and it was only on weekends.

Q So this was the mayoral election in 1999 in Racine, City of Racine?

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Yes. When was that?

2009.

And what campaign was that?

It was John Dickert's campaign for mayor.

In the ten years between 2000 -- or 1999 and 2009 did you have any interaction with John Dickert?

Yes. In what capacity?

We stayed in touch. We talked on the phone several times. I know he called and asked me for money when he ran for the assembly in 2002.

We had coffee several times.

What was the purpose of the coffee meetings?

Just to stay in touch.

You said he ran for assembly in 2002?

Yes. Were you involved in his campaign?

I was not.

Why not?

I was in Georgia managing -- managing a congressional race.

Had you opened or began your business, WZW Consulting?

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Correct.

This is a spring election?

Yes. How often did you talk with Dickert during this campaign?

About every time I was in town.

Personally or on the telephone?

Both.

What types of things did you talk about when you met with him?

I do not recall.

Did you still consider him a friend at that time?

Yes. Outside the campaign did you meet with him?

No. Did you socialize with him?

No. Dinners, drinks?

No. Okay. What was the result of the Eickhorst campaign?

Jim Smith won.

Did you work with John Dickert on any other campaigns after the Eickhorst campaign?

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A Not at that point.

Q You said Dickert called and asked you for a contribution for his campaign?

A Yes. Q Did he call you personally or have somebody call for you?

A He called me personally.

Q Did you contribute?

A I believe I did.

Q Do you recall how much?

A I believe it was $100.

Q Cash or check?

A Check.

Q Do you know the result of that election?

A He lost.

Q Besides this contribution and talking on the telephone did you have any other connection with John Dickert between 1999 and 2009?

MR. COHEN: Other than the coffees?

BY MR. SANDERS: Q And the campaign, the coffees.

A No. The only interaction I had was phone calls and coffees.

Q Okay. Did he talk to you, did John Dickert talk to you about any other campaigns that he

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was working on in that period of time, '99 to 2009?

I'm sure he did.

Okay. Are you aware of a person by the name of Gary Becker?

Yes. How do you know Gary Becker?

I know he was the mayor of Racine.

Did you ever meet him?

No. Did John Dickert ever talk about Gary Becker?

Yes. Do you know through your conversations with John Dickert if he ever worked for Gary Becker for his campaigns?

I -- I do know from my conversations with John Dickert that he did help out Gary Becker.

Do you know in what capacity he helped Gary Becker?

As a general strategist.

What does a general strategist do in a campaign for mayor in a city the size of Racine?

General strategist helps the candidate and the campaign develop overall strategy of message, targeting, fund-raising.

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A At Coldwell Banker and First Weber.

Q Was there a particular area that he -- that he was a realtor in?

A City of Racine.

Q Do you know what kind of real estate he was involved with?

A Houses.

Q Residential?

A Correct.

Q And during that period of time, 1999 to 2009, was he still involved in the Democratic Party?

A Yes. Q On a regional basis?

A Yes. Q How did you become involved in his 2009 mayoral campaign?

A When John Dickert decided to run he gave me a call and asked if I would help him out.

Q Did John Dickert, when he called you to ask to help, did he -- did you ever have conversations with him about running in general for the 2009 mayoral campaign?

A I'm not sure I understand what you mean.

Q Did -- did he consult with you as to whether or not to run?

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Q When you say "targeting" what do you mean?

A Targeting of voters, which voters to go after, how to spend the resources to go after them, prioritizing.

Q Is the strategy, targeting, and messaging dependent on the budget?

A Yes. Q And what about messaging, what do you mean by messaging?

A The message that the candidate is going to use during the campaign to lay out their vision, to lay out what they're going to do as an elected official or what they have done as elected official.

Q Between 1999 and 2009 do you know if John Dickert was employed?

A What were those dates again?

Q Between 1999 and 2009.

A Yes, he was.

Q Do you know where he was employed during that period of time?

A I believe at least a portion of that he was at Foley and Lardner, but I believe most of the time he was a realtor.

Q Do you know where he was a realtor?

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A Yes. Q So prior to you working on the campaign did he actually have -- you had conversations with him about whether to run or not?

A Yes. Q Did he have any particular concerns?

A He had run twice before.

Q For where?

A And lost. In Racine for the -- for state representative. He was worried that running a third time would, and losing would definitely kill his chances of ever being elected.

Q Now, you recounted one -- one race in 2002 where he ran for state assembly?

A Yes. Q Do you know what the other campaign he ran?

A Was also for the state assembly.

Q Do you know when that was?

A I do not offhand. It was either 1998 or 1988, I don't remember offhand.

Q Okay.

A Ironically it was against the same person.

Q That he ran against in 2002?

A Correct.

Q Do you know who that was?

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A Bob Turner.

Q And in the mayoral race in 2009 what prompted him to run?

A There was an open seat. It was wide open. It was probably his best opportunity he was going to have to win a political campaign, but it was going to be a challenge.

Q When you say that it was an open seat who had been the mayor prior to this election?

A Gary Becker.

Q Do you know why Gary Becker was leaving the office of mayor?

A He resigned.

Q Do you know why?

A He was arrested, charged, and then subsequently convicted of child pornography.

Q During your conversations with John Dickert did he talk about the situation with Gary Becker and his resignation?

A Yes. Q What did Dickert say about the resignation?

A He had been close to Gary, still considered Gary a friend, horrified by the situation. He also, in running for office, he wanted to not step on Gary's toes but at the same time not

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work for him?

A February of '09.

Q And in what capacity were you going to work for him?

A I was the general consultant or general strategist and also handled the fund-raising.

Q Was this the first campaign that you'd handled fund-raising on?

A No. Q And you had been a general strategist on other campaigns of this nature prior to 2009, had you -A Correct.

Q What was Dickert's vision of his campaign when you initially got -- when you initially began?

A Sending Racine in a new direction, changing the way things were done, approaching how to run the city, and the direction to take the city in from a business perspective.

Q All right. You said sending Racine in a new direction, correct?

A Correct.

Q And the way the city's run?

A Correct.

Q And what were the other points?

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miss an opportunity.

Q What do you mean by not step on Gary's toes?

A Gary -- Gary was still going back and forth about whether he was going to resign or when he was going to resign, even though it was pretty inevitable that he was going to.

Q So was Dickert reluctant to declare that he was going to run until Becker made up his mind?

A Correct, but at the same time he was making moves and starting to lay the foundation of a campaign.

Q In what way was he making moves?

A Starting the lineup support, starting the layout, how the campaign was -- was going to be structured, what he was going to run on, where the money was going to come from. We're talking about a short time frame here, anyway.

It was a week or so.

Q And when was this -- when were these initial conversations with Dickert taking place?

A I believe February.

Q February of what year?

A 2009.

Q Now, during your initial conversation -- oh, at what point did you formally accept his offer to

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A The way the city was run, sending the city in a new direction, and then approaching how to run the city through a businessman's eyes or how a business -- business experience.

Q All right. What did he -- what was his vision of sending Racine in a new direction? What direction?

A To be more -- to be more attractive to bringing in new -- new businesses, trying to stabilize and expand the housing stock, deal with the crime rate in Racine.

Q Did you have specific conversations with him about this vision?

A Yes. Q What did he say specifically about the way -the way the city was run? What -- what direction was he going to go in?

A He was extremely disappointed about how the City of Racine handled development and how it attracted new businesses.

Q In what way?

A He felt that there were a lot of missed opportunities, and he actually was extremely disappointed with the development director.

Q Do you know who the development director was?

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A Brian O'Connell.

Q Did -- did John Dickert say how he was going to change the way the city was going to bring development and business into the town?

A He was going to use the job as the mayor to actively go out and recruit new businesses. He wanted the city to be a lot more accommodating and work with developers a lot better than they had in the past.

Q Did he give any specifics as to how the city was going to be more accommodating to developers?

A Just that he felt that the city and in particular the development office would -would help and work with developers a little bit more as well as being proactive.

Q Now, you said also -- or let me go back to the way that the city is run and how it -- how it works with development or bringing development in. When did you have these conversations with him?

A I actually had had numerous conversations with him about that over the previous years during our coffee, but during the campaign I had been with him, we were talking about overall

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Q

A Q

A Q A

called, but the central area of Racine would be my term and would be the areas just outside of downtown, just west of downtown, stretching north a little bit.

Based on your experience in Racine and those particular neighborhoods just outside of downtown, west of downtown, and just north of downtown do you know what the predominant race was?

African-American.

Now, you also -- you also stated that part of his vision for the campaign was specifically to address the crime rate in Racine.

Yes. What did he say regarding his vision and the crime rate in Racine?

We needed more police officers, police officers needed to be more integrated and work more with the community and be more integrated into the neighborhoods. I believe under Mayor Becker he had worked with the mayor on creating, I don't know what they call it then, but they're like regional substations where a community police officer could operate within a neighborhood in a house and be an easy way to interact with the

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Q

A

Q A Q A Q A Q A

strategy, also during campaign strategy meetings as well, I believe he was having the same conversations with -- with -- with other people while he was testing the waters, whether he was going to run or not, and asking people's opinion about whether it was a good idea for him to run.

What did he specifically say in your conversations with him when you started working for the campaign about the housing stock? What was his vision for the housing stock?

He wanted to improve the housing stock in Racine. He had in the past worked on rehabbing some houses and trying to use that to stabilize neighborhoods.

Did he talk about particular neighborhoods?

Yes. What particular neighborhoods?

Neighborhoods in the central area of Racine.

Do you have an idea of what he meant by the central area of Racine?

I don't know -In terms of the geographic boundaries?

Correct. I do not know the -- the terms he used or what neighborhoods that they are

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Q A

Q A Q A Q A Q A

community and be accessible and be seen and be visible.

Was there any particular part of Racine that he was concerned about the crime rate?

The same areas that he wanted to stabilize state housing stock or stabilize by upgrading the housing stock.

Central Racine?

Correct.

Predominantly African-American?

Correct.

Did he express any vision regarding downtown, downtown Racine?

Yes. What was his vision about downtown Racine?

He was very proud of what Racine and what part he had played in kind of rebuilding downtown, that Main Street area of downtown. He had -he had been involved in the business association there and it actually had been very successful for the City of Racine, and I know he also worked at that area between downtown and city hall, kind of that, and I don't know what street those are, heading west from downtown towards city hall is, I don't know if

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Q A Q A Q

Q A

that's downtown or kind of like the western part of downtown, and that area had been not as successful as kind of that main strip and he wanted to help kind of stabilize and improve that area. In fact, he'd been very, very involved in that area.

He had been -Yes. -- up to the time he ran for mayor?

Yes. And he didn't consider that his involvement was a success up to that point?

MR. COHEN: Objection to the form of the question.

THE WITNESS: I think he felt it -that he had done some successful things and that the area had been improved, and I would probably agree that it had been improved.

BY MR. SANDERS: What was his concern about the area at the time he ran for mayor?

There were not a lot of businesses in that area, there was not -- the area was not taken care of as well as kind of that Main Street of downtown, wasn't stable.

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A To almost expand that downtown area.

Q Did he express that he wanted those bars to remain in the area west of downtown of Main Street?

A He wanted those bars to leave.

Q Did he say why he wanted those bars to leave?

A He felt that they were a problem to the area and he had had problems when he had been the executive director of this business group.

Q Did he talk about any of the specific bar owners?

A Not to my knowledge.

Q Now, these were businesses that were operating, correct?

A Correct.

Q But he didn't feel that these were the appropriate businesses for downtown?

MR. COHEN: Objection.

THE WITNESS: Correct.

MR. COHEN: Leading.

THE WITNESS: Correct.

BY MR. SANDERS: Q Were you familiar with those businesses?

A I was familiar a little bit with those businesses.

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Q Did he elaborate on what he meant by stable, wasn't stable?

A Well, there were not a -- while there were some businesses there, there were not -- it was a stark contrast to what that main strip in, of downtown, which it bordered was, which did have a lot of, you know, very nice shops and very nice restaurants along and kind of had become a, you know, downtown Main Street, very attractive place to visit in Racine, and this area bordering was -- was not as nice and a bit of a drain and considering, you know, it was almost an extension of that downtown.

Q Did he -- did he -- during the initial part of the campaign did he identify any particular businesses in the city west of Main Street, in the area of downtown west of Main Street?

A There were a couple bars.

Q Did he talk specifically about those bars?

A Just that they were part of this old area or kind of the old way that that area had been set up and -- and operating and he wanted it -that -- that whole section to be more like that Main Street, to almost expand -Q Go ahead.

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Q And were the businesses that he was discussing, were they all bars?

A Yes. Q What types of bars?

A Bars with primarily African-American clientele.

Q Did he specifically say that he had a problem with the African-American clientele?

A I do not recall.

Q How did you know that he was concerned about those particular bars then?

A He was -- he told me that he did not like the way that those businesses were run, felt that they -- that those businesses were creating problems and -- in that area and were preventing that area from having a resurgence.

Q What did he -- what -- what did he not like about how the businesses were run?

A He felt that the businesses were not attracting the type of clientele that would want to go -go to that kind of that main strip of downtown that he was proud of, and it was difficult for him to, or he felt it was difficult for the city to attract those types of businesses into that area.

Q What types of businesses?

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A Restaurants, boutique type shops, art galleries.

Q What did he say was the problem with the clientele that was -- that was going to these bars?

MR. COHEN: Objection, misstates the testimony.

THE WITNESS: He felt that the clientele were creating a fear of people wanting to go that area and also making it difficult for the city to attract the types of businesses that they wanted to put there.

BY MR. SANDERS: Q Now, you previously testified that these bars that he was talking about were -- predominantly served African-Americans?

A Yes. Q And when you say he felt that the clientele was creating a fair -- a fear of other people wanting to go to the area did you take it to mean African-Americans?

MR. COHEN: Objection -THE WITNESS: No. MR. COHEN: -- to the form of the question.

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conversations when we had coffee.

Q Where were the campaign strategy meetings held?

A They were held, I know there was at least one or two at his -- at his house, there were a couple held at the campaign office, and then there were several that were held in Mick Wynhoff's office.

Q You said that -- that you had these conversations with John Dickert about the downtown area during your coffee meetings?

A Yes. Q So this is prior to him asking you to assist in the campaign?

A Correct.

Q And he had the same types of conversations with you on those earlier occasions that he did while he was running for mayor?

A Correct.

Q Voicing a concern about west of downtown Racine?

A Yes. Q And the clientele that was populating that area?

A Yes. Q Did he ever talk with you at the coffee

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Q A Q A Q A Q A Q A

Q

A

THE WITNESS: No.

BY MR. SANDERS: You didn't take it to be African-Americans coming to the area?

That was creating the fear?

Yes. Who was creating the fear?

The African-Americans coming to the area.

A fear to whom? Did he say?

Yes. Who? People from outside of Racine.

Potential developers?

To some extent, but not really. I would say more potential customers or people who do go to that main kind of strip in -- in -- in Racine, kind of that main downtown area, people who go -- go to these nicer restaurants or shop at the boutique shops or go to the art galleries.

When you had these conversations with Mayor Dickert or with John Dickert prior to the campaign where did these conversations take place?

They took place in campaign strategy meetings, they took place in the campaign office, they took place prior to that. We had similar

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A

Q A

Q A Q

meetings or during the campaign of his strategy to -- to make those areas more desirable to other people outside of Racine?

He focused mainly on his -- his efforts, at the earlier meetings in particular about his work with, as executive director of this business group about trying to attract new businesses and to make -- make that area more -- more desirable.

How was he going to make it more desirable to these other businesses, other developers?

To make the place more attractive, to make people safe, feel -- feel safe when -- when they went down there. He felt he had to really, that one of his main jobs as executive director of this group was to try to kind of change people's perception of -- of that area and to kind of help promote the existing businesses while trying to attract some more.

Did he say he wanted to promote the existing bars that were down there?

He did not.

So did he -- did he give a vision or a strategy as to how he was going to make -- make the atmosphere more safe for people?

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A Not in specific terms.

Q What unspecific terms did he use?

A He felt that that section had to be -- had to change and be more like the downtown area.

Q Did his vision include those bars remaining on 6th Street?

A No. Q Or west of downtown?

A No. Q Did he ever specifically say that he didn't want African-Americans downtown?

A No. Q Did he indirectly make that comment to you or observation to you?

MR. COHEN: Objection, vague.

THE WITNESS: I would not say indirectly. I would say that he wanted to -that he had a clear vision on what an attractive downtown should look like and what types of businesses should be there.

BY MR. SANDERS: Q In your opinion based on working with him did that -- did that attractive downtown vision of Dickert include black businesses?

MR. COHEN: Objection, relevance.

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Q Prior to the Dickert's 2009 mayoral campaign did you know Monte Osterman?

A No. Q So you met him for the first time during the campaign?

A Correct.

Q Did you know Mick Wynhoff?

A No. Q Boyd Frederick?

A Yes. Q How did you know Boyd Frederick?

A Similar situations as how I knew John Dickert, by work in that regional, or being involved in that regional democratic organization.

Q And this Rolando, you don't know his last name?

A I do not.

Q Did you know him prior to the campaign?

A I did not.

Q Don Trottier?

A No. Q Doug Nicholson?

A No. Q What did Monte Osterman do for the campaign?

A Essentially whatever needed to be done. He -he was very good friends, if not best friends

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Q

A Q A Q A Q A Q A Q A

THE WITNESS: No.

BY MR. SANDERS: Based on your conversations with John Dickert do you believe that he was referring to African-Americans or black individuals as creating the fear -Yes. -- to that particular area?

Yes. You said that you had, that these topics were discussed at campaign strategy meetings?

Yes. That were held at his home, at the campaign office, and Mick Wynhoff's office?

Yes. Who else was working on the campaign when you began working on the campaign?

In what capacity? In a paid or a volunteer capacity?

Both. Let's start with paid.

Initially I was the only paid personal on the campaign. Volunteer-wise there was Monte Osterman, Mick Wynhoff, Boyd Frederick, Mary Jerger, Rolando, and I don't remember his last name, Don Trottier, and Doug Nicholson.

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Q A

Q A Q A Q A

of John Dickert, wanted to help him get elected, had not had a lot of campaign experience but was very eager. If he was asked to do something he would do it.

What about Mick Wynhoff, what was his -- what was his role in the campaign?

Mick helped with kind of developing Dickert's, or taking Dickert's vision and message and kind of boiling it down to easy talking points for -- for John during -- during the campaign, and kind of, you know, taking -- taking those talking points and doing some of the writing and some of the press releases and...

Okay. What role did Boyd Frederick play?

Boyd helped a lot with strategy.

Rolando?

Rolando helped with Hispanic outreach.

What about Don Trottier?

Don helped a little with developing some message in dealing with downtown, or dealing, excuse me, not with downtown, but dealing with business. He comes from a business background.

He had not had very much, if any, campaign experience. He was a friend of John's, was smart. I felt he had good instincts.

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Q Okay. Doug Nicholson, what was his role?

A Doug also was a friend of John Dickert, a bar owner, a -- his -- his business was in that downtown area. He and John had worked together a lot on that downtown area.

Q You mentioned Mary Jerger?

A Yes. Q What role did she play?

A She was the treasurer.

Q Was she married to any of the other individuals working on the campaign?

A She's married to Monte Osterman.

Q Was there anybody else that eventually became part of the campaign that was paid?

A Greg Bach.

Q And Greg Bach, where did he come from?

A He was helping another client of mine and I talked to that client and told him that I felt that Greg would -- could actually be helpful on this -- this other campaign and asked if -- if it would be okay if I tried to bring Greg on down.

Q So you recruited Greg Bach?

A I did.

Q And what capacity did he play in the campaign?

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Q What about Boyd Frederick?

A Boyd, I believe, was an insurance agent at that time in Kenosha.

Q Rolando, do you know what he did for employment?

A He owned and ran a small grocery store, and I believe maybe a restaurant that was across the street too.

Q What about Don Trottier?

A He was a banker in Kenosha.

Q So he was a banker in Kenosha, but he was assisting his friend John Dickert in the Racine mayoral race?

A Correct. He was his friend and I don't believe he lived in the city, but I think he lived in Caledonia, so just outside of the city.

Q What about Mary Jerger, did she have employment?

A She -- she owned a hat store.

Q And besides working for John Dickert as campaign manager did Greg Bach have any other employment that you were aware of?

A Not while he was campaign manager. He had been working for this other client of mine -Q Okay.

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A He was the campaign manager.

Q So Dickert agreed to pay him?

A I know he -- after my initial conversation with Greg, Greg expressed his interest in working on the campaign. I know he had a brief conversation with this other client of mine and then he came down and had a meeting with -with John so they could talk and get to know each other and see if it was a good fit.

Q Was he hired?

A Yes, he was.

Q And what role did he play?

A He was the campaign manager.

Q What -- what type of employment did Monte Osterman have?

A He owned a granite business.

Q In Racine?

A Yes. Q What about Mick Wynhoff?

A He was the -- he ran a environmental cleaning company.

Q In Racine?

A Environmental product cleaning company.

Q In Racine?

A Yes.

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A -- in a different capacity.

Q Now, were any of these individuals that you just talked about, the campaign workers that we've been discussing, were any of them present during conversations with Dickert about his vision of the city?

A Yes. Q And were they present when he talked about the businesses that he wanted downtown and the businesses that he didn't want downtown?

A Yes. Q Were they present when he was talking about the -- the bars on -- in the area west of downtown that he felt that needed to go?

A Yes. MR. COHEN: Objection, misstates his testimony.

BY MR. SANDERS: Q Did Mayor Dickert indicate that he didn't want those bars to remain downtown?

A Yes. Q And did he make those indications in the presence of these other campaign workers?

A Yes. Q Did anybody question him about it?

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A Q A Q

A Q

A Q

A

Q A Q A

No. Did you question him about it?

No. Did he have any -- were there any African-American campaign workers that assisted him?

No. Did he have any African-American individuals that did outreach to the black community in Racine?

No. Now, as -- as his main strategist what steps did you take or advise him to garner support from the African-American community?

During these conversations it was my advice to, because it was a very large field, well over ten individuals running in this race, that certainly in the initial phase of the campaign that he should focus on the votes he needed to -- to get through to the second round.

Okay. Was he -- did he target any votes in the minority communities of Racine?

There was an effort for Latino outreach.

What about for the African-American community?

No.

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limited, but there was an effort.

Q After the primary did Dickert's vision change as to what he wanted to do to downtown Racine?

A No. Q Did his vision change as to how he wanted to make the area of downtown west of Main Street more attractive to people from outside of Racine?

A Nothing changed.

Q Why don't we take a break at this point.

(Short break was taken.)

EXAMINATION

BY MR. COHEN: Q Mr. Williams, we met before the deposition began. My name's Mike Cohen. I represent the defendants, including John Dickert, in this case. First of all, what is your current address?

A 426 North 12th Avenue East, Duluth, Minnesota.

Q And did you recently move there?

A Yes. Q When?

A June 1 of this year.

Q Did you take a new job?

A No.

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Q Do you recall who some of the other candidates were in the primary?

A Bob Turner, Greg Helding, Jim Spangenberg.

There was another alderman, Gallas, Gallas, something like that. I know there were a lot of people.

Q So you don't remember all ten.

A No. And I believe it was probably more than ten.

Q When was the primary held, do you know?

A April 2009.

Q Who won the primary?

A I don't remember who finished first. It may have been Bob Turner, but this first, the top two were Bob Turner and John Dickert.

Q Do you know the race of Bob Turner?

A Yes. Q What -- what's his race?

A African-American.

Q After the primary did John Dickert's campaign make any efforts to reach out to the African-American community?

A No. Q What about the Hispanic community?

A It's a continuation of outreach. It was

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Q A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q A

Why did you move to Duluth?

My wife took a new job.

Where does she work?

The EPA. And that's the Environmental Protection Agency?

Correct.

What district is that?

It's the one that's in Duluth.

And what is her position there?

She's a post-doc.

What does that mean?

It's a three-year stint doing research at the Environmental Protection Agency.

And your wife's name?

Kathleen Williams.

Where did she get her PhD? University of Wisconsin Milwaukee.

And any present plans to move from that address?

No. You have a Bachelor's of Science degree?

Of -- Bachelor of Arts.

Bachelor of Arts, in political science and communications.

Correct.

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Q A Q A Q A Q A Q A

Q

A Q

You've never gone to law school, correct?

Correct.

You don't have a law degree?

No. You have no training in law, right?

Correct.

You've never held a license to practice law, correct?

Correct.

Tell me, what, if anything, you did to prepare for your deposition.

Talked with my attorney a couple times. I reviewed the statement I gave a year and a half ago, and I did read through a couple of the other depositions.

All right. The statement you're referring to is a statement you gave to Mr. Sanders, correct -Correct.

-- in November of 2014?

MR. GERAGHTY: '13, not to testify.

THE WITNESS: '13. I had to think about that. Yes. It did not sound right, so it was -- it was 2013.

BY MR. COHEN:

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26, 2013 that was?

A No. It was -- it was -- it was on that day.

Q That day, before you began giving your statement.

A Correct.

Q You met with him for a little bit and then the court reporter took down the questions and your answers.

A Correct. It was a five-minute conversation.

Q All right. And you didn't have counsel present, correct?

A Correct.

Q You didn't think you needed to at the time?

A Correct.

Q You had not hired Mr. Geraghty yet, correct?

A Correct.

Q And did you get -- how did you initially get in touch with Mr. Sanders or how did he get in touch with you?

A Santo Galati called me and asked if I had knowledge of John Dickert's campaign and if I would be willing to come in and talk about it.

Q And who is Mr. Galati?

A He's a private investigator.

Q And how do you know him?

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Q November 26, 2013 sound right?

A Correct.

Q And there was a court reporter present, correct?

A Yes. Q But there was no one cross-examining you, correct?

A Correct.

Q No one representing Mayor Dickert or anyone else, correct?

A Correct.

Q And you never raised your hand and swore to tell the truth before that statement, correct?

A I don't believe I did.

Q It's an unsworn statement, correct?

A I -- I don't know.

Q All right. And prior to giving that statement you had occasion to talk with Mr. Sanders about what he was going to ask you?

A I believe we had a brief conversation.

Q Was that by phone or in person?

A In person.

Q And where was that?

A It was in this room, actually.

Q Do you know how -- how much prior to November

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A Q A Q A Q A Q A Q A

Q A Q A Q

He used to be my landlord.

On Pennsylvania?

Yes. And how -- and did he say in what capacity he was operating, who he worked for?

He works for himself.

All right. Had he been retained by Mr. Sanders or lawyers in this firm, do you know?

He said that he had been.

And do you know who he was -- do you know which clients they were representing?

No. And what did he tell you was the purpose of his retention, if he told you?

He said he was -- he said he was working on a case that had to do with Racine and that John Dickert was involved.

And did he interview you before Mr. Sanders took your statement on November 26, 2013?

I don't know if he did or not. I cannot remember.

You met with him before that, didn't you?

I believe I did, but I'm not sure for certain.

You don't recall meeting with him and discussing the matters that you were eventually

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asked by Mr. Sanders during your statement?

A I know I had a brief conversation. I'm not sure if it was in person or if it was over the phone.

Q How did you get a copy of your statement?

A My attorney sent it to me.

Q Did Mr. Sanders give you a copy after he took the statement?

A No. Q Did you ask for one?

A No. Q Have you ever been deposed before?

A No. Q Have you ever given trial testimony before?

A Not in a trial, but I gave testimony during a election investigation. It was not an investigation, it was a hearing on whether to throw someone off a ballot.

Q Who was that?

A David Clarke.

Q The sheriff in Milwaukee?

A Correct.

Q And how were you involved?

A I was -- it was a client of mine, is the one who filed -- the complaint, and I handled a lot

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David Clarke to be placed on a ballot.

Q And had you done some research on the people that had signed the petition papers?

A Yes. Q And whether they in fact had signed them?

A There were a couple cases of that, but it was mainly whether the addresses on the petitions were valid within the city of Milwaukee.

Q Whether they were city of Milwaukee residents.

A Correct.

Q That's the only time other than today you've given testimony?

A Correct.

Q Other than reviewing your statement did you review any other documents in preparation for your deposition?

A I read a couple other transcripts associated with this trial.

Q Which ones?

A John Dickert's, Tom Tousis, Boyd Frederick.

Q Any others?

A Greg Bach's, I believe, and Monte Osterman's and Doug Nicholson's.

Q How did you get those transcripts?

A My attorney sent them to me.

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Q A Q A Q A Q A Q A Q A Q A Q A Q A

of the investigation or kind of the compiling of the data.

And when did you give testimony?

It would have been in December 2003, I believe, maybe 2004. No, I believe it was 2003.

And who was your client?

Vince Bobot.

How did you come to learn of Mr. Bobot?

Through another consultant.

Who was that?

Mary Claire Fagan.

And who is she?

She's someone who's been involved in politics in Milwaukee for a very long time.

What was Mr. Bobot's interest in the David Clarke matter?

He was running for mayor.

And at the time was David Clarke running for mayor as well?

Yes. And who did you give your testimony to?

The Milwaukee Election Commission.

What was the issue that you investigated and formed the basis of the complaint?

Whether there was enough valid signatures for

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Q Did you ask for them?

A No. Q What was your purpose in reviewing all of those depositions?

A Felt I wanted to be prepared for today.

Q Did you ask your attorney to obtain these depositions so you could review them?

A No. Q Do you know how your attorney obtained those transcripts?

A I do not.

Q Did you read both days of Tom Tousis's deposition?

A Yes. Q Did you read both days of John Dickert's deposition?

A Yes. Q How much time would you say you put into reading deposition transcripts in this case?

A Maybe an hour and a half, two hours. I skimmed most of them.

Q Do you know how your attorney obtained those transcripts?

A No. Q Did you review the exhibits?

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q

No. I don't believe I had any exhibits.

Did you talk -- you know Tom Tousis, don't you?

Yes. He's a friend of yours, isn't he?

Correct.

Did you talk to him about his deposition?

No. Did you talk to Mr. Frederick about his deposition?

No. Have you talked to anybody else about their depositions in this case?

No. Do you know who the plaintiffs are in this case?

I know a couple names. I do not know them.

What names do you know?

Thomas Holmes.

Do you know Mr. Holmes?

No. Never met him?

Never met him.

Do you know what bar he operated?

I believe it was Park 6, but I'm not sure.

Do you know what periods of time he operated

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A Q A Q A Q A Q A Q A Q A Q A Q A Q

Election day.

When was that?

Mid May. Do you know the date?

No. If I told you that John Dickert took office on May 20 would that sound about right?

It could.

Were you no longer working for his campaign by the time that he took office?

Correct.

You would never work for someone that you thought was a racist, would you?

No. And you didn't consider John Dickert to be a racist when you worked for him, did you?

No. In fact, you knew he was heavily involved in the Democratic Party like yourself, right?

Correct.

And you shared some of the same political philosophies, correct?

Some of, yes.

The testimony that you gave to Mr. Sanders about John Dickert's vision for downtown

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A Q A Q A Q

A Q A Q A Q

A Q A Q A Q

that bar?

I do not.

What other plaintiffs are you aware of?

That's the only name I know.

You've never spoken to Mr. Holmes?

No. So your testimony is that you read, rather skimmed, nine transcripts to prepare for your deposition today?

Yes. So that you would be prepared for my questions?

Yes. Any other documents that you reviewed other than those transcripts and your statement?

No. You said that you agreed to begin working on John Dickert's campaign for mayor for the City of Racine in February of 2009?

Yes. When exactly was that, what day?

I have no idea.

Was it the middle of the month, the end of the month?

I have no idea.

And when did you stop working for the campaign?

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Q A Q A

Q

Racine, you didn't consider his comments to you to be racist, did you?

No. In fact, he never mentioned African-Americans once during those discussions, correct?

That is not true.

When did he mention them?

During -- during the discussions that we had about -- about those bars.

Well, tell me exactly what he said.

That he felt that the patrons who attended those bars were creating a negative image in that area and harming the -- the ability to -of the ability of the city to improve that area, attract new businesses, and he wanted to clean it up.

When did he tell you that?

He has told me that several times.

Well, tell me, when?

Discussed it during campaign meetings, we discussed it in private, we discussed it several times before he ran for office over coffee.

When? When you met before he ran for office, is that 2008 are you talking about or --

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A Actually, one time was in 2002.

Q Can you tell me what minority-owned bars operated in the City of Racine in 2002?

A I do not.

Q Can you tell me what minority-owned bars operated in the City of Racine in downtown Racine in 2008?

A No. Q During this period of February of '09 to May of, sometime in May '09 can you tell me what African-American owned bars operated in this stretch of area that you talked about with Mr. Sanders?

A I believe Park 6 is the only one I know of. I know there was another one, but I do not know the name.

Q And where do you understand Park 6 was operating?

A In that strip of land between downtown and city hall. It's on the one-way street heading west.

Q Mayor Dickert never mentioned Park 6 specifically in these discussions, did he?

A I believe he did not refer to it specifically, but I know at least in one case in 2002 he -he did point out a bar. I do not know if it

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Q If I told you it was in November of 2009 would that sound right now?

A I have no idea.

Q That was -- that would be months after the election, correct?

A It would be.

Q Now, John Dickert never told you that he wanted to get rid of all minority bars in downtown Racine, correct?

A Specifically, no.

Q He never told you that he wanted to get rid of all black-owned bars in downtown Racine, correct?

A Specifically, no.

Q He never said in your presence that he wanted to get rid of all minority-owned bars in Racine, period, correct?

A Specifically, no.

Q And you don't recall him specifically indicating to you that during this time period, February '09 to May '09, that he thought that Park 6 was a problem bar, correct?

A Specifically, no.

Q So during this period of time, let's just say -- let's just call this the campaign

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was Park 6 or not.

Q You don't know if Park 6 was even operating back then, do you?

A Correct.

Q And you said you believed he mentioned another bar, but you can't remember the name?

A This is during the campaign.

Q Yes. A Yes. Q What was that bar's name?

A I cannot recall.

Q Where was it located?

A In the same general area.

Q Do you know of another bar that was owned by a minority in that area during that time period?

A I do not.

Q Have you ever heard the name Keith Fair before?

A Yes. Q Who do you know him to be?

A I know he's a former alderman.

Q And do you know whether he ran a bar in that area?

A I believe he did.

Q Do you know when he opened that bar?

A I do not.

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period, okay?

A Okay.

Q During the campaign period do you know who actually owned Park 6?

A I have no idea.

Q Do you know whether Thomas Holmes was even involved with Park 6 at the time?

A I do not.

Q Did he mention, the mayor, did John Dickert mention Thomas Holmes' name during your conversation?

A No. Q If I told you that Thomas Holmes did not even become the agent for Park 6 until October of '09 would that surprise you?

A Probably.

Q That would be five months after he was elected, right?

A Yes. Q Are you aware that during this campaign period the licensee and registered agent for Park 6 was a white lawyer from Milwaukee named Jim McCann?

A I have no idea.

Q Did mayor -- excuse me -- did John Dickert

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during the campaign period indicate who he thought owned Park 6?

No. Did he indicate who he thought was the licensee?

No. The name Park 6 never even came up in your discussions, correct?

Correct.

You said that the mayor stated that there were, that there were bars that were causing some problems in the area?

Yes. All right. And what area specifically was he talking about?

The stretch of the city of Racine from that -from that Main Street or that downtown stretch towards city hall.

Do you know what street that is?

Do not. It's actually two streets, one -- one going one way, one going the other way.

All right. And you don't know either name of either street.

No. And you don't know which bars are on either

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A Q A Q

A Q

A Q A

Q A Q A Q

I don't -- I don't recall.

Was it the Business Improvement District?

I don't recall.

If I told you that Park 6 was not even called before the city's public safety and licensing committee until July of 2009 would that surprise you?

I wouldn't -- it would not surprise me.

If I told you that Mr. Holmes never even appeared before the city's public licensing and safety committee until July of '09 regarding Park 6 would that surprise you?

I have no knowledge of that.

Well, what problems do you think John Dickert was talking about?

He -- he specifically mentioned safety issues and that it was creating a negative perception of that area.

But you don't know which bar.

No. There were several, but he did not mention specific names.

And you understood them to be minority owned and/or minority clientele?

Yes. But he didn't specifically say that.

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street, correct?

A Correct.

Q And you don't know which bars were on either street during the campaign period, correct?

A Correct.

Q Did John Dickert indicate how he knew that any bars in that area were problems or were causing problems?

A Yes. Q What did he say in that regard?

A He said that -- that there were bars in that area that were creating a negative perception of that area, that there were safety issues going on, and it was hindering his work from prior when he was executive director of that -of that business organization or that business group and the city specifically on trying to clean up that -- that area.

Q What -- what business group do you think he was executive director of?

A I don't recall what it was.

Q He never told you?

A He did at the time. I don't remember what it is.

Q Was it the Downtown Racine Corporation?

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A He talked about them being hip-hop or rap clubs.

Q Well, what hip-hop clubs existed during the campaign period in that area?

A I don't know. He pointed one out to me.

Q Which one did he point out to you?

A I have no idea.

Q When you say pointed out did he point to it literally and showed you?

A Yes. Q When you were driving by?

A No. I met him at the office of whatever this business group was and he -- he -- he at the time was talking to another business owner and they were talking about kind of safety issues and he pointed the bar out to me and then we went and had coffee.

Q What street?

A It's the one heading towards city hall.

Q Towards city hall on what street?

A I don't know the name of it.

Q And he said that was a hip-hop club?

A I believe so.

Q Did he say who owned it?

A No.

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Q A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q

Did he say who the licensee was?

No. Did you see any African-Americans in the area?

No. It was in the middle of the afternoon.

And you believe that he was referring to at least one other bar?

Yes. But you don't know the name of that bar.

No. And you don't know where it was located.

It was in that general vicinity.

What street?

I do not know.

And you don't know who the licensee of that bar was.

No. And you don't know who the registered agent of that bar was.

No. You don't know anything about that bar.

No. You don't know about any problems associated with that bar.

No. So after John Dickert became mayor in May of

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meetings for Park 6?

A No. Q Are you aware of any communications he's ever had with the public safety and licensing committee about Park 6?

A I am not.

Q Are you aware of any communications he's ever had with public safety and licensing committee about any bars?

A No. Q Are you aware of any communications he's had with the common council for the city about Park 6?

A No. Q Are you aware of any communications he's had with any of the aldermen about Park 6?

A No. Q Are you aware of any communications he's had with any aldermen about any bar?

A No. Q You were a general strategist for the campaign?

A Yes. Q But you can't tell me who -- who came in first place in the primary.

A It was a long time ago.

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A Q A Q

A Q A Q A Q A Q

A Q A Q

'09 did you stay in contact with him?

A little bit, but not for very long.

How often would you talk with him?

A couple times. It was not very regular.

And did you talk to him on those couple occasions about his vision to get rid of the bars in the downtown area?

No. Did you talk with him about what he was doing in that regard?

No. Do you know anything about the public safety and licensing committee?

No. Do you know anything about how it interacts with the common council?

No. Do you know whether John Dickert has ever served on public safety and licensing committee?

I do not.

Are you aware of him ever attending any meetings of that committee?

I am not.

Are you aware of him ever attending any

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Q Has the timing affected your memory?

A No. Q But you can't remember if your candidate was in first place or not.

A No, because we had to finish in the top two.

Q Did you ever tell John Dickert that he should go after the African-American vote?

A No. Q You didn't think it was racist of him not to do so, did you?

A No. Q One of your strategies for the campaign was to focus on the votes that you thought he could get, correct?

A Yes. Q And you knew that Bob Turner had a good proportion of the African-American vote because he was African-American, correct?

A Correct.

Q And he had beaten him -- beat -- he had beaten John Dickert on two other occasions, correct?

A Correct.

Q And had the support of the black voters.

A Correct.

Q And that was one of the reasons you didn't

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A

think he should go after the black voters in the primary election.

Correct.

Or the general election, correct?

Correct.

Had nothing to do with being racist, correct?

Correct.

You're not racist, are you?

No. Have you ever heard John Dickert make a racist comment at any time?

No. As you sit here today do you believe he's a racist?

Explicitly, no.

What do you mean by that?

I think he's uncomfortable around minorities.

And why do you say that?

I've seen him interact with -- with specifically African-American political people.

Who's that?

Bob Turner and Simpsoni (phonetic) out of Racine, political.

Anybody else?

Several, there are kind of several community

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campaign for mayor?

A I probably was.

(Exhibit No. 1699 marked for identification.)

BY MR. COHEN: Q I'm going to show you what we marked as Exhibit No. 1699. Can you identify that document for me?

A Yes. Q What is it?

A It is a press release where John Dickert announces his campaign for Racine mayor.

Q Did you assist in preparing it?

A I believe I did.

Q And it lays out his general platform, correct?

A Yes. Q And it includes jobs, correct?

A Correct.

Q Housing stock, correct?

A Correct.

Q Eradicating gangs and drugs?

A Correct.

Q Returning ethics and openness to our government?

A Correct.

Q And you understood that those were the main --

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Q A Q A Q A Q

A Q A Q A Q A Q A Q

activists. I think Jameel was maybe one. Greg Oliver was another one. I know he was not fans.

He didn't like those two individuals?

Correct, or Bob Turner.

But you're not testifying that he didn't like them because of their race, correct?

Explicitly, no.

Okay. He never told you that he felt uncomfortable around African-Americans, did he?

No. What were the -- there were several main platforms that John Dickert ran under for the city, correct?

Correct.

One was housing, correct?

Correct.

One was crime?

Correct.

One was business development, right?

Or attracting new businesses, correct.

And jobs, right?

And jobs, correct.

Were you involved in the drafting of the press release when John Dickert announced his

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main tenets of his platform, correct?

A Correct.

Q And the press statement doesn't say anything about cleaning up downtown, does it?

A It does not.

Q It doesn't say anything about getting rid of bars, does it?

A No. Q In fact, it doesn't mention bars at all, does it?

A No. Q And that was drafted contemporaneous with the campaign, wasn't it?

A Yes. In fact, it's the style that I use, so I'm actually probably the one who initially wrote it.

Q Show you what's been marked as 1700.

A Okay.

(Exhibit No. 1700 marked for identification.)

BY MR. COHEN: Q Can you identify this, please?

A Yes. It's the Journal Times questionnaire for John Dickert.

Q And did you assist in preparing this?

A I did.

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Q And what was the purpose of the questionnaire?

A The Journal Times asked each of the candidates to answer a number of questions about the campaign.

Q Including the campaign -- campaign's priorities, correct?

A Correct.

Q In fact, that's the number one question, isn't it?

A Yes. Q And this generally talks about the same general tenets of jobs, crime, and housing, correct?

A Among other things.

Q In fact, the first sentence of the first paragraph says just that, "Jobs, crime, and housing are the three key components of growing our city," right?

A Correct.

Q You helped prepare this?

A I did.

Q Doesn't say anything in here about getting rid of bars in downtown Racine, does it?

A Does not. There's not a question about it.

Q In fact, it doesn't even mention bars, does it?

A There was not a question about that.

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campaign, correct?

A Correct.

Q Do you know of any campaign literature that talks about cleaning up the bars in downtown Racine?

A Not specifically.

Q Now, Mary Jerger was the treasurer for the campaign, correct?

A Correct.

Q You didn't get along with her particularly well, did you.

A No. Q In fact, you two would often quarrel, wouldn't you?

A Yes. Q You thought that on occasion she would waste your time with questions, right?

A No. Q No? A No. Q Did you express to others that you hated Mary?

A Probably.

(Exhibit No. 1702 marked for identification.)

BY MR. COHEN: Q I'll show you what's been marked as Exhibit

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Q That was prepared contemporaneous with the campaign, wasn't it?

A Correct.

Q Did you draft that as well?

A I believe I had a hand in it.

(Exhibit No. 1701 marked for identification.)

BY MR. COHEN: Q I show you what we've marked as Exhibit 1701.

Can you identify that, please?

A It is a, looks like a draft of a fund-raising letter or a, yes, a fund-raising letter for John Dickert.

Q Okay. Did you prepare this?

A I did.

Q And does it talk a little bit about his platform here?

A It does.

Q Cleaning up drug houses, correct?

A Correct.

Q Increasing jobs, right?

A Correct.

Q Does it say anything about getting rid of bars in downtown?

A It does not.

Q And this was prepared contemporaneous with the

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A Q

A Q A Q A Q A Q

A Q A Q

1702. Is this a series of e-mails between you and Greg Bach in April of 2009?

It is.

All right. And you sent an e-mail to Mr. Bach on Sunday, April 26, 2009 at 4:38 p.m. and you wrote, "Leaving now to come down. I fucking hate Mary. I just wasted two hours of my life.

Zak." Correct?

Correct.

And you're referring to Mary Jerger, correct?

Correct.

And you thought that she wasted two hours of your life.

Yes. And Bach responds, "Seriously, you two, you just do it and get it over with," right?

Correct.

And John Dickert would talk to you about getting along with Mary during the campaign, right?

I believe we had a couple conversations.

It was more than one, wasn't it?

I believe maybe it was two.

And you knew that he was unhappy that the two of you were quarrelling?

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A Q

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Yes. And he wanted that to stop, right?

Right.

He thought it was a distraction to the campaign?

Yes. And when John was elected in May of 2009 your job was over, you said, right?

Correct.

And you didn't continue to assist the campaign with the filing of the campaign finance forms, did you?

No. Did Mayor Dickert then make it clear to you that he wasn't going to use your services for any future campaigns?

No. Did you leave under good terms?

Right after the campaign ended, yes.

You seem hesitant.

We have -- we did leave on bad terms at a later date.

What later date was that?

It was later that year.

And what happened?

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Q A Q A Q A

Q A Q A

Q

A

How long have you known him?

Since 2009.

And he became a client of yours, correct?

Correct.

How did that come about?

Through the course of the campaign I met -- I met Tom Tousis and then after the campaign I approached him about his West Racine project.

Why did you approach him about that?

I felt I could help him out with the city.

And why did you feel you could help him out with the city?

I felt that Tom needed help with dealing with the city bureaucracy, and I felt that my relationship with John may help.

In fact, you told Mr. Tousis that, that you thought that your relationship with John Dickert would help him get his project approved, right?

I did not use those specific words and that's not what I was referring to. I said that I would assist him because I could talk to John and have conversations with him and -- and help -- help John and do what John had told me that he wanted to do during the campaign, which

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A We just had a disagreement.

Q On what?

A Specifically on the way that he and the City of Racine were handling the West Racine Tousis project.

Q When you say later that year what time period are you talking about?

A Fall.

Q Okay.

MR. GERAGHTY: Of 2009?

THE WITNESS: Of 2009, thank you.

BY MR. COHEN: Q We'll talk about that in depth, but at the time in May you left, you felt like you left under good terms.

A Yes. Q And you don't think that John Dickert was unhappy with your performance?

A No. Q You knew he was unhappy about your relationship with Mary and not being able to work together, correct?

A Correct.

Q Tousis, you said, is a friend of yours?

A Yes.

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Q

A Q A Q A Q A Q A

Q A Q A Q

was, you know, help developers deal with the city bureaucracy and kind of streamline that process and have the city work more with developers rather than what had been going on previously where they had been, in John's word, a barrier.

You specifically told Mr. Tousis that you thought your relationship with John Dickert would help him with his project, correct?

I believe I just answered that.

And do you still have contact with Mr. Tousis?

Yes. How often?

At this point once every couple months.

And has that changed since you moved to Duluth?

Yes. All right. And before that it was more often?

I would say probably for the last six months it's been less infrequent, but prior to that it was more often.

You guys talk about a lot of things, don't you?

Yes. Including this case, correct?

In a limited fashion, yes.

What do you mean by limited fashion?

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A We've had some -- some basic conversations about this case.

Q What have you talked about?

A We -- I told him I gave a statement to -- to Sanders. I gave him some general ideas at the time of what I talked about and said that -that the lawyers may have a conversation with him.

Q In fact, you put him in contact with Santos to talk to him, right?

A Actually, I did not.

Q That happened just organically without your involvement?

A He actually knew Santo.

Q How did he know him?

A I believe that Santo had worked with him on his divorce case.

Q And is it your understanding that Santo took a statement or interviewed Mr. Tousis as well?

A I believe so.

Q Your discussions with Mr. Tousis about this case weren't limited to your giving a statement, were they.

A Probably not.

Q You've talked about this case quite often with

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A Early.

Q And by that what do you mean?

A There was some initial drawings done. He -- he had identified a site and he had had some initial conversations with Brian O'Connell.

Q What were you hired to do?

A Help -- help deal with the city bureaucracy and communicate with the council and help him with the neighbors of the site.

Q How did you communicate with council?

A Phone calls.

Q Are you talking about aldermen?

A Yes. Q Did you ever appear before the common council?

A Yes. Q And were you the mouthpiece for Tom Tousis at that occasion?

A Yes. Q And what date was that?

A I do not recall.

Q And was that at the time when Mr. Tousis had asked the common council to consider his application?

A I believe so.

Q All right. And then it was referred to the

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him, haven't you?

A Not really.

Q Developments that occur on the case that you've seen in the news or he's seen in the news?

A We -- we have sent news articles back and forth to each other, yes.

Q Pretty regularly, wouldn't you say?

A Fairly regularly.

Q What's your interest in following this case?

A I'm involved.

Q As a witness.

A Yes. Q Did you get any remuneration for giving that statement?

A No. Q Have you ever been offered any money by the plaintiffs in this case?

A Only for my travel expenses to come down here.

Q They agree to pay your time too?

A No. Q When were you hired by Mr. Tousis to help him with his West Racine project?

A Either May or early June of 2009.

Q And what stage was the project in at that point?

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redevelopment authority?

A I believe so.

Q All right. So you appeared at the time when the discussion occurred about referring it to the redevelopment authority, correct?

A Correct.

Q All right. And were you hired individually or for the company you were working for?

A I was hired individually. We ran it through a friend of mine who I do some work with on occasion, and I generally run my corporate stuff through there.

Q Who is that?

A Mark Goff, G-O-F-F. Q And that's Goff Communications?

A Correct.

Q And were you an owner of Goff Communications at the time?

A No. Q Were you serving as an independent contractor?

A Yes. Q When you say you do corporate stuff through him what do you mean?

A I have done some economic development work and we've done some marketing work for private

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companies and nonprofits.

Q Occasionally you would work as an independent contractor for him.

A Correct.

Q When you had a client that you wanted to set up through a company.

A Or he would actually bring me on in a limited basis if he needed assistance.

Q And eventually you entered into a contract with Mr. Tousis for your work, right?

A Correct.

Q And that was through Goff Communications?

A Yes. Q And that was structured such that if you -- if the project was approved and you received TIF funding you would get additional compensation, correct?

A Yes. Q And that was an additional $2,000?

A I believe so.

Q All right. And the TIF funding was important to Mr. Tousis for the project, right?

A Yes. Q And can you explain that?

A The site is located within a TIF district.

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A Yes. Q And that's because a undisclosed sewer easement was discovered, right?

A Correct.

Q And that drastically changed the plans, correct?

A Correct.

Q Changed the footprint of the project?

A Correct.

Q And as a result the city assessor had estimated the project far below the estimated value needed for the TIF, correct?

A Correct.

Q And that number was 2.4 million?

A I don't recall.

Q All right. And then did the city indicate that they were willing to work with Mr. Tousis to try to increase the appraised value through development plans?

A I believe there was some discussions about that.

Q And do you believe that was a good faith effort?

A No. Q Why?

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Q And what does that mean for Mr. Tousis in terms of developing the property?

A It's another pot of money that could help develop the property and, you know, TIFs deal -- TIFs can help with infrastructure and other types.

Q And did you understand what the assessed value of the project as built out would have to be eligible for the TIF funding?

A I believe Brian O'Connell expressed at a later, at some point that, yes.

Q And how much was that?

A I believe he said 5 million. I'm not positive.

Q All right. And before Mr. Tousis retained you do you believe he was aware of that?

A I do not.

Q All right. When do you think he became aware of that?

A When Brian O'Connell informed us of it.

Q And when was that?

A Sometime in the fall.

Q Fall of '09?

A Yes. Q And that became an issue with the development, correct?

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A I believe that the city did not want the development to move forward.

Q And why do you believe that?

A It was becoming increasingly difficult to maneuver through the city bureaucracy and there were consistently barriers being put in place.

Q Well, was Mr. Tousis ever able to redevise his plans so he could get the assessed value up to $5 million?

A I don't recall.

Q Do you remember that there was a delay in him even paying his option fee?

A I don't recall.

Q Do you remember him asking for extensions of time to pay his option fee?

A I'll be honest with you, I don't recall.

Q Were you involved in that aspect of it?

A Yes. Q He had other people involved for him too, right?

A Correct.

Q Karen Sorensen?

A Correct.

Q She would appear in front of the development authority?

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A Yes. Q Did you also?

A I believe I did. I don't -- I don't recall specifically. I know I attended several meetings.

Q But as you sit here today you don't know of any problems with him paying his option fee.

A There -- there -- there may have been. I don't -- I don't recall. I know there were discussions about -- about the option fee, but I don't know if there was necessarily a delay or not. I don't recall that.

Q Were you aware of the fact that the option had actually expired and he hadn't paid his fee?

A I don't recall it.

Q Do you remember him asking through his representatives for extensions of time on the agreement?

A I know there were discussions on various timelines at certain points, but I don't recall specifics.

Q At some point in time did Mr. Tousis get concerned about potential environmental problems with the property?

A Yes.

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as much, didn't he?

A I believe so.

Q All right. There was some opposition early on the project voiced by Alderman Spangenberg?

A Yes. Q And he was the alderman in the district?

A Yes. Or one of the aldermen in the district.

There were three.

Q All right. And do you remember what his concerns were?

A He viewed that site as his pet project and had his own ideas of what he wanted that site to be.

Q Did you talk to him?

A I -- I had a couple conversations with him, not necessarily in depth.

Q Did you try to convince him to be more agreeable with the project?

A I believe I did.

Q All right. Do you know how he voted on extending the option?

A I do not, actually.

Q Do you know how he voted on extending the timetables for the project?

A I do not.

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Q All right. And he thought there were some problems with the Phase 1?

A Correct.

Q All right. And he wanted the city to do a Phase 2, correct?

A Correct.

Q And the city wasn't willing to do that?

A Correct.

Q All right. And so being unable to revise his plan because of the easement to reach the assessment value and being concerned with environmental problems he decided to not continue with the project, right?

A Correct.

Q And he asked for his fee back, option fee?

A Correct.

Q And it was paid back to him, correct?

A Correct.

Q So it was a combination of concerns over environmental problems and not being able to reach the assessed value because of the undisclosed sewer easement that caused him not to continue with the project, correct?

A Among -- among other things.

Q And you read his deposition testimony. He said

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Q Did Mayor Dickert have anything to do with the sewer pipe that was discovered?

A I don't believe so.

Q Did he have anything to do with the environmental problems that Mr. Tousis was concerned about?

A I don't believe so.

Q He didn't create them, did he?

A I don't believe so.

Q He wasn't involved in any prior disclosures about environmental problems or the drafting of the Phase 1?

A I don't believe so.

Q Did -- did Mayor Dickert do anything in relation to this project to cause it to fail?

A Yes. Q What?

A He, through Brian O'Connell, created barriers and made it difficult to move the project along.

Q What barriers?

A The -- it was just very difficult to get information out of -- out of Brian O'Connell.

The department was reluctant to work with Tom on -- on -- on the project. I had specific

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Q

A Q A Q A

Q A Q

A Q A Q A

conversations on a couple occasions with John about that and he said he would talk to Brian about it and nothing changed.

All right. But the project failed because of the sewer and the environmental problems, right?

I'm sure that that's -- yes.

And Dickert didn't have anything to do with either one of those, right?

Correct.

So why did you have a falling-out with Mayor Dickert?

It was over this project and about he -- how he and -- and his department heads were handling it.

Mr. O'Connell?

Yes. This lack of getting information out of O'Connell and the department being reluctant to work on the project?

Yes. Those are the things that caused this problem?

Yes. Did you tell him that?

Yes.

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A Correct.

Q Tell me what things you were involved with to attempt to cause harm to John Dickert.

A I was involved in an independent expenditure campaign in 2011. I worked for a client who ran against him this last time in 2015.

Q Anything else?

A I talked to a couple, I did talk to a reporter about a couple issues.

Q Who was that?

A Dustin Block.

Q What issues?

A With some other of the -- the developments that the mayor was pushing forward.

Q Anything else?

A He asked me to look through John Dickert's campaign reports, the ones from the 2011 campaign.

Q He asked you to?

A Yes. Q And why?

A He wanted me to -- to look at them and give him an analysis.

Q Why? A Because he was doing a story on them.

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Q All right. And that caused you to dislike John Dickert quite a bit, didn't it.

A Yes. Q In fact, you dislike him to this day, correct?

A Correct.

Q And you've expressed that numerous times to numerous people, haven't you.

A Yes. Q And you've been very involved in efforts to try to cause problems for John Dickert, haven't you.

A I have been involved. I would say not very involved.

Q Really?

A Yes. Q Have you been the architect of any of those ideas?

A No. Q And you knew that Mr. Tousis was also bitter towards John Dickert regarding the project, right?

A Yes. Q He told you that as well.

A Correct.

Q And you've heard him tell other people that.

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Q And what was -- where? Where was he going to publish the story?

A His online newspaper or whatever you want to call it. I think Racine something. I don't remember what it was.

Q Did he hire you?

A No. Q You did so on your own -A Yes. Q -- without being compensated.

A Correct.

Q So what independent expenditure, what did you say? Independent expenditure?

A Expenditure during the 2011 campaign, correct.

Q And who hired you for that?

A The Racine CRG, the Citizens for Responsible Government.

Q Who is that?

A It's a group of people who are concerned about the city of Racine.

Q What other efforts have you been involved with to cause harm to John Dickert?

A I just told you a number.

Q Any others?

A I don't recall any.

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Q A Q A Q A Q A Q

A Q A Q A Q

A Q A Q A

Well, you're a frequent blogger, aren't you?

No. Really?

Yeah.

Have you used the blog title Johnny Uzick before?

I have.

That's your blog name, isn't it?

Yes. And you're telling me here under oath that you haven't entered blog posts that have been critical of John Dickert?

I have not entered any blog posts.

Really.

Uh-huh.

You think someone else is using Johnny Uzick?

No. All right. We'll talk about those. Anything else that you've done to try to cause harm to John Dickert?

Not that I recall.

How about giving the statement to Mr. Sanders?

Sure.

Anything else?

No.

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Q Would you say you became obsessed with causing harm to him?

A No. Q You've written a lot of e-mails about him, haven't you?

A I've written some e-mails.

Q Quite a few to Mr. Tousis, right?

A Sure.

Q And to Mr. Spodick?

A I've written some, yes.

Q And to Ken Brown.

A Yes. Q All because you dislike John Dickert, right?

A Sure.

Q Show you what we marked as Exhibit 1703. Do you recognize the e-mail address, Better Day BP? A Yes. Q That's Tom Tousis's e-mail address, isn't it?

A Yes. Q And these are a series of e-mails from you to Mr. Tousis and then Mr. Tousis back to you and then you to Mr. Tousis again, correct?

A Correct.

Q And we start from the bottom going up to see

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Q How about being involved with Eric Marcus's campaign?

A I have never been involved in Eric Marcus's campaign.

Q Never did anything for him?

A No. Q Telling the truth?

A Yes. MR. GERAGHTY: You can assume he's telling the truth.

BY MR. COHEN: Q Okay. And all these things that you've just testified that you were involved with to cause harm to John Dickert, that's all because you were mad about the West Racine project?

A Yes. Q Including giving the statement, correct?

A Correct.

Q That's why you would take time out of your busy day and busy life to involve yourself in John Dickert long after you were no longer working with him, right?

A Sure.

(Exhibit No. 1703 marked for identification.)

BY MR. COHEN:

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the chain of events, right?

A Correct.

Q And the bottom one is from you dated October 16, 2009 at 8:29 p.m.?

A Yes. Q And it says, "By the way, this is an attempt by Brian to keep me out of the room." Are you referring there -- Strike that.

Let me go back to the bottom. You've cut and pasted an e-mail from Tim Casey, correct?

A I don't believe I cut and pasted, but I may have.

Q All right. Where did that come from?

A It may have just been a reply. I don't know.

Q Reply to what?

A To this e-mail.

Q Well, you're not communicating with Tim Casey here, are you?

A Probably not. I don't know if I was part of the conversation and I've just -- that was several people and I just -- and I just had a conversation with Tom about -- I mean, I don't -- I don't recall.

Q Tim Casey was who?

A Tim Casey was -- I actually don't remember.

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Q Did he assist the city in relation to the project?

A I believe so.

Q And his quote here is, "Brian asked me to make it clear that we would be happy to meet with the appropriate members of your team at any time. We look forward to working with you on this opportunity." Do you see that?

A Yes. Q And was that an e-mail he had sent to you?

A I -- I don't know if he was cc'd on it or if it was sent to me.

Q And that was expressing to you that he'd be glad, Brian O'Connell would be glad to meet with you, right?

A I believe it actually says the opposite.

Q How do you read that?

A I -- I believe that the reference to appropriate members is a reference to me, and I expressed that in the response to Tom. Q Well, it says, "Brian asked me to make it clear that we would be happy to meet with the appropriate members of your team."

A Right.

Q Are you saying he was trying to exclude you?

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say that?

A I have no idea.

Q Why would just sitting there, making them wonder what you're going to do affect the meeting in any way?

A I have no idea.

Q Why did you communicate that to Mr. Tousis?

A I don't know.

Q And then you say, "John Shannon may be the hammer, but I am the dagger in the back in the dark alley." What did you mean by that?

A That people underestimate me a number of times and I'm -- I'm tough and...

Q You're tough.

A Yes. Q In what way?

A Just tough with the way that I deal with the situations.

Q Well, how were you going to be the dagger in the back in the dark alley in relation to Mr. Tousis's project?

A I don't recall specifics.

Q And who is John Shannon?

A John Shannon is an attorney.

Q And was he involved in the project?

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A Yes. Q That you're not an appropriate member?

A I believe that -- that Brian was trying to use that as a way to keep me out of the room.

Q Doesn't say that, does it?

A That's the way I read it.

Q The appropriate member could be you too, right?

A It could be.

Q And then you say to Mr. Tousis, "By the way, this is an attempt by Brian to keep me out of the room," right?

A Right.

Q Expressing your interpretation of that statement.

A Correct.

Q And then Tousis says, "No Zak, no meeting," right?

A Right.

Q What meeting was that?

A I do not recall.

Q And then you say, "They expect me to throw a fit in the meeting." Why do you say that?

A I don't recall.

Q "I was just going to sit there and make them wonder what I'm going to do." Why would you

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A Q A Q A Q

A Q A Q A Q

A Q A Q

I believe he was.

For who?

For Tom Tousis.

Okay. So when you say he may be the hammer, meaning the legal authority?

Yes. But then you're saying you're much more dangerous as the dagger in the back in the dark alley.

Yes. Well, how were you going to exercise this concept?

I don't -- I don't remember the context at the time.

Why did you say it?

I don't recall.

Were you suggesting that you had something on the city or the mayor that you were going to pull out and use at the appropriate time?

Not on a public meeting.

Sure seems that way.

That's not -- that is not what I'm referencing.

Now, after Mr. -- excuse me -- Alderman Spangenberg expressed some opposition to the project you went on the offensive against him,

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Q A Q

didn't you?

Yes. What did you do?

We riled up the neighbors against him.

That was intentional, wasn't it?

Yes. You wanted to sway the neighbors against him, right?

Yes. Did you think that was devious at all?

No. How did you go about doing that?

We had a number of people within the neighborhood who were for the project. We had them kind of talk to their neighbors. We also ran a, what you would call like a grass roots, a paid grass roots campaign and we sent a mailing to his -- to his district as well as the two neighboring ones with slightly different language telling people to call them.

You were, I'm sorry, you were involved with preparing that mailing, weren't you?

Yes. And Alderman Spangenberg thought it was dirty politics, didn't he?

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Q All right. And you were quoted in the article, weren't you?

A Am I? Probably.

Q Down at the bottom there, "Zak Williams, a spokesman for Tousis, said he hasn't seen the postcard and said Tousis had nothing to do with it. He added Tousis did not pay for the postcard and was unaware it existed until Racine Post called to inquire about it. The postcard likely came from local unions which are backing Tousis's project because he's agreed to use union labor to build the development." It goes on, talks about Spangenberg calling the card sleazy. Do you see that, and inaccurate?

A Yes. Q Because, among other things, it doesn't even reference the fact that Mr. Tousis was planning a gas station, right?

A Yes. Q Now, this statement that you gave to the Racine Post is not accurate, is it?

A It is not.

Q You didn't tell the truth, did you.

A I did not.

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A Q A Q

He did.

He called it sleazy, didn't he?

He did.

And there was an article in the newspaper about it, wasn't there?

A Yes. (Exhibit No. 1704 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as 1704. Is this the article in the Racine Post regarding the postcard that was sent around about Alderman Spangenberg?

A I believe it is.

Q And there's a -MR. GERAGHTY: You couldn't have possibly read. At least look it over before you -THE WITNESS: Well, I've read -- I've read the first page. I'm reading the second right now, but yes.

BY MR. COHEN: Q You recognize that postcard, don't you?

A Yes. Q You helped prepare it, didn't you?

A Correct.

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Q In fact, you had seen the postcard before, correct?

A Correct.

Q You helped develop it?

A Yes. Q And you had shown it to Mr. Tousis.

A Yes. Q And he commented on it.

A Yes. Q And you billed him for it.

A I did.

Q And he paid for it.

A Yes. Q So you lied to the newspaper reporter, correct?

A I did.

Q And then you entered some blog entries here, didn't you?

A Probably.

MR. GERAGHTY: Okay. Stop. Okay.

Just stop. Read what he's directing you to read before you answer. I just don't want -THE WITNESS: Sure.

MR. GERAGHTY: Say that again and Mr. Cohen will show you what he's -THE WITNESS: Sure.

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Q

A Q A Q A Q A Q A Q A

Q

MR. GERAGHTY: Direct you to the right spot.

THE WITNESS: I'm sorry.

BY MR. COHEN: Let me show you one, if you look on the bottom there's some numbering on the pages on the bottom right-hand corner, do you see that?

Yes. There's one that says 6/22. Do you see that?

Okay.

And that's a blog entry by you dated September 22, 2009 at 3:56 p.m., right?

It is not.

That's your name, isn't it?

It is.

Someone else entered this?

No. I entered this. It's not a blog entry.

It's a comment on a -- on a newspaper article.

Okay. What's the difference between a blog entry and a comment on a newspaper article?

A comment on a newspaper article is a comment about the newspaper article. A blog entry would be an independent created entry.

All right. So this was a comment that you did make, right?

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Q A Q A Q A Q A Q A Q

A Q A

Q A Q

You did design it, correct?

Correct.

Tom had seen it, correct?

Correct.

And you did have a clue who Quality Development was.

Correct.

Do you lie a lot?

No. Just to newspaper reporters and comments?

In this instance.

Did part of your attack on Alderman Spangenberg also include ghost writing open records requests?

Yes. Why did you do that?

We had a number of people who wanted to request information, and there was information that we wanted to -- to -- thought it was not to come from myself or Tom Tousis or anyone else from the development team.

Why? We thought it may be more responsive from the city.

Wouldn't it be better to just put your name on

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A Correct.

Q And you used your name, you didn't use Johnny Uzick, did you?

A No. Q And you say to an Omaha, Nebraska, I guess, maybe you're responding to someone who used an anonymous name, perhaps, is that right?

A Probably.

Q "Unlike you, Alderman Spangenberg, when I comment on the Racine Post I use my real name and not hide under the cloud of anonymity."

Are you suggesting that one of the other comments was actually Alderman Spangenberg?

A I believe that's what it says.

Q And then you say, "If you had bothered to read the article you would have read that until someone sent the link to this article to me I have not seen the postcard, nor had Tom. I did not design it. I did not send it out. I have no clue who Quality Development is," and then you go on and talk about some other things. Do you see that?

A I do.

Q None of that's truthful, correct?

A Correct.

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it and be transparent?

A Not necessarily.

Q I show you what's been marked as Exhibit 1552 to Mr. Tousis's deposition. You've seen this before, haven't you?

A I've seen this e-mail. Is that what you're asking me?

Q Yes. A I believe so. I wrote it.

Q Yes. It was an e-mail from you to Mr. Tousis dated September 17, 2009 regarding Spangenberg open records request, correct?

MR. GERAGHTY: Zak, read the first page. Is that what you're referring to, Michael?

MR. COHEN: Yes. THE WITNESS: Oh, okay. Yes.

BY MR. COHEN: Q And attached is your draft of an open records request to Rob Weber, Racine city attorney, correct?

A Correct.

Q All right. And were you paid to prepare this?

A Yes. Q By Mr. Tousis?

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A It was part of my duties with the project.

Q And this was part of an effort to put pressure on Alderman Spangenberg, right?

A Yes. Q You were hoping to intimidate him into approving the project?

A Not -- not necessarily to approve it, but at least to temper his opposition.

Q Who actually signed off -- Strike that.

Did the open records letter get sent?

A I do not recall.

Q Take a look at the last page here.

A Okay.

Q Last two pages, I should say. Your draft now has Keith Deschler's name on it, D-E-S-C-H-L-E-R, correct?

A Yes. Q And who is he?

A I believe he was a neighbor in the community.

Q You said he was one of the people in the area that you had talked to?

A Yes. Q Who else -- who else were neighbors that you were talking with about this project?

A I don't recall any names.

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Q Did you also assist in preparing a letter to Alderman Spangenberg directly?

A I don't recall.

Q By the way, by having Mr. Deschler send the, is it Deschler, is that how you pronounce it?

A I'll be honest with you, I don't remember.

Q By having Mr. Deschler send the open records letter it helped you keep your involvement behind the scenes, right?

A Yes. Q That's how you like to operate, right?

A Not necessarily.

Q I'm going to show you what was previously marked as a compilation Exhibit 1550 at Mr. Tousis's deposition and take a second to look through that, please.

A (Witness complies.) Okay.

Q Okay. This compilation exhibit shows your drafts of the Spangenberg postcard, correct?

A Yes. Q And the fact that you communicated to Mr. Tousis about it, correct?

A Correct.

Q And his comments about it, right?

A It does.

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Q And how did you get him to sign this open records letter?

A I believe he wanted to be helpful and he was expressing his concern about the way Spangenberg was -- his position on the -- on the project and felt that this -- that -- and he wanted to be helpful.

Q You ghost wrote the letter for his signature, fair?

A Yes. Q All right. And the last page here of the exhibit you're confirming to Mr. Tousis, "The open records for Brian and Spanky are in the mail. Keith sent it already," correct?

A That is what it says.

Q All right. And by "Spanky" you're referring to Alderman Spangenberg?

A Yes. Q That was kind of a derogatory term, wasn't it?

A It was.

Q Did you check to see if Mr. Deschler actually lived in the district?

A I did not.

Q Would that have been prudent for you to do?

A Not necessarily.

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Q And your invoice to him for $2,041.10, correct?

A Correct.

Q Were you also involved in ghost writing a letter to send out to union members regarding the project?

A I may have been.

Q And what was the purpose of that?

A To -- to get the union members to support the project and to contact their aldermen.

Q And you wanted -- your design was to have them put pressure on Spangenberg and the city, right?

A Correct.

Q I'll show you what's been marked as Exhibit 1551 in Mr. Tousis's deposition. Is this an e-mail from you to Mr. Tousis dated July 31, 2009 attaching a draft letter to send to the unions?

A Yes. Q All right. And then in your e-mail, the last sentence, you say, "I do not want anyone looking at the electronic fingerprint and tracing it back to us." Do you see that?

A I do.

Q You didn't want John Dickert to know what you

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were up to, right?

A I guess.

MR. GERAGHTY: Well, don't guess.

You're not supposed to guess.

THE WITNESS: Yeah, I'm -specifically I don't -- I don't recall.

BY MR. COHEN: Q Did you coordinate and communicate with Mr. Tousis and others regarding using comments to newspaper articles to paint Aldermen Spangenberg in a negative light?

A Yes. Q And that was to put more pressure on him, right?

A Correct.

Q Who is Dave Stauffacher?

A He's a friend of mine.

Q S-T-A-U-F-F-A-C-H-E-R? A Yes. Q How did you get to know Mr. Stauffacher?

A Went to college together.

Q At Beloit?

A Yes. Q And you got him involved to post a comment, right?

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A Q

A Q A Q A Q A Q A Q A Q A

Racine and he'll be forced to either side with the whackos or get angry at them." Do you see that?

I do.

And you say, "Tom was laughing when he was reading this one to me." That's Tom Tousis, right?

Yes. And you forward it to Tousis and you say, "Devious," right?

I do.

What do you mean by that?

I don't remember. I thought it was pretty funny.

Your intention was to cause harm to Alderman Spangenberg, correct?

I would not use the term "harm."

Why not?

I don't think it's accurate.

You and your friend were plotting to create an image of him that wasn't accurate, right?

Yes. Show you what's been marked as Exhibit 1548.

Have you seen this before?

I believe I have.

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A Yes. Q Why did you do that?

A I felt I needed to get some other voices to post.

Q And did Mr. Stauffacher suggest that he was going to take a position in support of Alderman Spangenberg that showed that he was a family values man?

A I don't remember.

Q I show you what's been marked as Exhibit 1705.

(Exhibit No. 1705 marked for identification.)

BY MR. COHEN: Q Is this -- there's an e-mail dated September 22, 2009 from Mr. Stauffacher, am I pronouncing that?

A Stauffacher.

Q Stauffacher to you, correct?

A Correct.

Q And it talks about an original post that he was going to -- that he was going to post that described himself as a religious family values guy, right?

A Yes. Q And then it says, "Nice. I am serious, man.

Paint him as the family values option for

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Q And it's an e-mail between you and Mr. -e-mails between you and Mr. Block?

A It is.

Q And you're talking about the Mayor John Dickert's ten-year plan, right?

A We are.

Q Your e-mail to him dated March 6, 2010 refers to the mayor's ten-year plan as described in the Journal Times and you say "Dickert is a fucking moron," right?

A That is what it says.

Q And you're saying this to someone who runs a blog site?

A Or an online newspaper.

Q Online newspaper. And then he says, "Just read it. I'm wordless," right?

A Correct.

Q And then you say, "He's having an 'exclusive' with the mirror on what he has done over the past year. How far has he slipped in the eyes of the press that he has to go to them for a story on that scale?"

Who's the mayor?

A I actually don't remember.

Q Then you say, "FYI, his anxiety is so bad he is

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only doing half days. An open records request for his schedule would confirm it. This is beyond the three days he did not get out of bed."

Where is that information coming from?

I don't recall.

Did you have someone inside city hall that was feeding you information?

I don't recall.

Do you know in fact whether he had any anxiety problems?

That's what I was told.

By whom?

I don't remember.

And you say, "Beyond the three days he didn't get out of bed."

You don't know whether that's accurate or not, do you?

I wrote it. I don't remember -That's not --- if it's accurate or not.

-- my question. My question is did you do anything to investigate whether that was true?

I did not.

Did you encourage Dustin Block to send an open

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Q A Q A Q A Q

A Q

A Q A Q A Q A

And what was that about?

I have no idea.

Did you ask him to speak to Mayor Dickert?

I don't recall.

Did you ask Dustin to interview Mayor Dickert about the West Racine project?

I don't recall.

Why would you be inquiring of Mr. Tousis as to whether Dustin Block, who you're communicating with, about open records requests to talk to John?

I have no idea.

Did you ask him to go ask John Dickert about his anxiety or his problems with getting out of bed?

I don't recall.

Did you ask him to do a story about the ten-year plan?

I did.

And did he do one?

I believe he did.

And you asked him to do that to cause harm to John Dickert, correct?

Yes. MR. JUEDES: I think we skipped 1706

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records request on this issue?

A Looks like I did.

Q And you've communicated with him about other open records requests to submit about John Dickert, right?

A Yes. Q All -- all in an effort to cause him harm, right?

A Yes. (Exhibit No. 1709 marked for identification.)

BY MR. COHEN: Q Let me show you what's been marked as Exhibit 1709. Do you recognize that?

A It's an e-mail that I sent.

Q From you to Mr. Tousis, right?

A Yes, it is.

Q Dated October 8, 2009?

A Yes. Q And you say, "Did Dustin talk to John," correct?

A Correct.

Q And Dustin is Dustin Block?

A I believe so.

Q And John is John Dickert.

A Yes.

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to 1708.

MR. COHEN: Oh, sorry.

MR. SANDERS: Yeah.

MR. JUEDES: Just wanted to make sure we're clear.

MR. SANDERS: Yup. MR. GERAGHTY: I don't have 1707.

MR. COHEN: Yeah, I got them here.

(Exhibit No. 1706 marked for identification.)

BY MR. COHEN: Q Let me show you what we marked as Exhibit 1706.

It'll balance out.

MR. GERAGHTY: I know. Thanks.

BY MR. COHEN: Q These are a series of e-mails between you and Dustin Block dated April 17, 2013 and April 18, 2013, correct?

A What -- what were those dates again?

Q April 17 and April 18, 2013.

A Yes. Q All right. And it starts on the bottom on the second page with an e-mail from you to him where you say, "If I can get you the incident report number do you want to file violation of the open records law and Dickert's sex incident

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that the cops stumbled upon," correct?

A Correct.

Q And he responds and says, "I'm so far out of the loop over here in Detroit but would love to see the JT get a tip," right?

A Right.

Q Had you moved to Detroit at that time?

A Yes. Q So you're contacting him outside of the state to see if he would file an open records complaint involving John Dickert, right?

A Yes. Q What's the sex incident you're referring to?

A An incident where a police officer came across John Dickert and another female, not his wife, in a sex act in a parking garage.

Q How do you know that?

A That's what I was told.

Q By whom?

A Tom Tousis.

Q How did Tom Tousis learn of that?

A I have no idea.

Q Did you do anything to verify that?

A I did not.

Q Did you see any police report about it?

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the info," right? Correct?

A Yes. Q And then he says, "Ah, got you, yeah, I'll take a look," right?

A Correct.

Q You say, "Let me see what I can get," right?

A Correct.

Q What were you going to get?

A I don't -- I don't remember.

Q Were you going to draft the complaint for him?

A No. Q Did you do so?

A I don't recall.

Q Did you follow up on this at all?

A I don't recall.

Q This was all to cause more harm to John Dickert, right?

A Yes. Q You don't recall following up on this at all?

A I do not.

Q Do you deny that you did?

A I do not.

Q Show you what's been marked as exhibit -MR. GERAGHTY: Could I just know what this was? Are you talking about the last sex

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A Q A Q

A Q A

Q A Q A Q

A Q

I did not.

Did you talk to an officer about it?

I did not.

You took Mr. Tousis's word and then contacted Dustin Block who runs, at least at one time ran an online newspaper and asked him if he'd file a complaint against John Dickert, correct?

I did.

To cause him harm, right?

Dustin had filed an open records request for the police report and the police had said it didn't exist, so he would be the one who would have to file the complaint.

Could that have been an indication that it never happened?

Possibly.

Right. You didn't know whether it was factually accurate or not, correct?

I told it was.

Mr. Williams, have you ever been concerned that your writings involving John Dickert may cause you to be exposed to a slander suit?

No. You go on to say, "You filed the request so you need to make the complaint, but you can pass on

Page 144 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

incident?

MR. COHEN: Yes. MR. GERAGHTY: Is that what you were talking about?

MR. COHEN: The open records complaint.

(Exhibit No. 1707 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1707. Is this an e-mail from you to Dustin Block dated March 21, 2014?

A It is.

Q And that's almost a full year after your last communication, right?

A Yes. Q Block still living in Detroit, to the best of your knowledge?

A Yes. Q And you say, "Send me your phone number. Some people want to talk to you about your open records request for a certain police report."

Do you see that?

A I do.

Q And you're talking about the same alleged police report that supposedly involved the sex

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incident with John Dickert, correct?

I believe so.

And who are the people you're referring to?

I have no idea.

Isn't it true that it's Jim Spodick?

I have no idea.

So out of the blue a year after talking to Mr. Block you send him an e-mail which is a year ago about some people wanting to talk to him and you have no idea who they are.

I don't -- I don't recall who it was.

Do you remember someone asking you about this?

I don't recall.

Do you remember talking about it with Mr. Spodick?

I don't remember if I did or not.

You have no idea who you're talking about.

At this time, no, I don't.

Did Mr. Block respond to you?

I don't know.

Was it Mr. Sanders who wanted to talk to him?

No. I don't believe so.

You have no recollection.

No. You've made other disparaging remarks about

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Q And you're being critical of the mayor here, aren't you?

A I believe so.

Q That was in effort to get Dustin to write an article about him?

A I don't believe so.

Q Just sharing your views?

A I was responding to an e-mail that Dustin sent me with the article.

Q Did you ask Mr. Block to write an article about the West Racine project?

A I don't remember.

Q Sure about that?

A Yes. (Exhibit No. 1710 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1710.

Starts on the bottom with a copy of a letter from Matt Sadowski to Mr. Tousis, right, dated March 23, 2010?

A Yes. Q And that's about the scheduling of the next plan commission review meeting regarding the project, right?

A It is.

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Mayor Dickert to Dustin Block, haven't you?

A I believe I have.

Q And that was also to cause harm to him, correct?

A Correct.

Q You were hoping that Dustin Block would publish an article that was negative about John Dickert, right?

A Correct.

Q Because you wanted to get him back, didn't you?

A Yes. (Exhibit No. 1708 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1708.

Is this an e-mail from you to Dustin Block dated October 25, 2010?

A It is.

Q And it's attaching a Journal Times, or at least got a link to a Journal Times article which is attached here, has Dickert's explanation for tax levy difference, correct?

A Yes. Q And you're saying, "Unfucking believable," right?

A Yes.

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Q And then Mr. Tousis sends you an e-mail, March 23, 2010, and says, "I think Monte is correct.

I'm going to take this to court." Do you see this? Do you see that?

A I do see that.

Q All right. And Monte is Monte Osterman?

A Yes. Q And what was Mr. Osterman correct about, do you know?

A I have no idea.

Q And when Mr. Tousis says, "I'm going to take this to court," he was going to file a lawsuit against the city?

A I have no idea.

Q And did you forward this to Dustin Block?

A I -- I don't know.

Q Was Mr. Tousis in communications with Mr. Block at this period?

A You would have to ask him.

Q He was your contact, wasn't he? Correct?

A Correct.

Q And you got to know him actually when you were working on John Dickert's campaign for mayor when he was working at the Racine Journal Times, right?

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A Q A Q A

No, I don't think so.

Did you meet him before that?

No. How did you get to meet him?

I believe I met him during -- during this -during the West Racine project.

Did Monte Osterman suggest to Tom Tousis to file a lawsuit?

I have no idea.

And then Dustin says, "Let me know if you want a story on this," right?

He does.

Did he write a story?

I don't recall.

And then you say, "I talked with him. He said the same thing. Talked with Karen. She needs to hear from Ryan and the final piece will be ready for us to move forward."

Karen is Karen Sorensen?

I believe so.

And Ryan is who?

I have no idea.

You wrote an e-mail but you don't know who you're talking about.

I don't.

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that's who is referenced in this e-mail.

Q Well, who else were you talking to named Katie during this time period about Mr. Tousis's project?

A I'm not sure there is anyone, but there may have been.

Q Did your wife talk to Boyd Frederick?

A No. Q Did you speak with Boyd Frederick?

A I probably did at some time.

Q What's the reference to Dickert pressured Dustin?

A I have no idea.

Q You don't know what you meant.

A No. Q No clue.

A Seriously I have no idea.

Q Was Dustin Block talking with John Dickert?

A He was a reporter. I'm sure he was.

Q Okay. Did he run an article?

A I have no idea.

Q Are you expressing that the article was more favorable than you had expressed because Dickert had pressured him?

A I have no idea.

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Q And what's the final piece being ready to move forward?

A I have no idea.

Q Is it the passage of time that's affecting your memory?

A No. It's an e-mail I haven't seen in five years.

Q But you can vividly recall a conversation with Tom, excuse me, with John Dickert in 2009?

A Yes. (Exhibit No. 1711 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1711. Is that an e-mail from you to Mr. Tousis dated April 26, 2010?

A It is.

Q You say, "Just left message after conversation with Boyd. Katie thinks Dickert pressured Dustin."

Do you see that?

A I do.

Q Katie's your wife, right?

A I have no idea.

Q You don't know if Katie's your wife?

A I have a wife named Katie. I don't know if

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(Exhibit No. 1713 marked for identification.)

BY MR. COHEN: Q Show as you what we marked as Exhibit 1713.

MR. SANDERS: 12.

MR. GERAGHTY: We'll catch up.

MR. COHEN: Yeah. Sorry.

Q This is a series of e-mails between you and Mr. Tousis, correct?

A Yes. Q And December 31, 2009 he says, "I bumped into the mayor." You respond, "Did he look at you?"

Answer from Tousis is, "He hugged me," and then you say, "Did you check your wallet," correct?

A Yes. Q That was meant to be disparaging, right?

A It was.

Q You're suggesting that the mayor is a thief, right?

A I was making a joke.

Q After the West Racine project failed you went on the offensive against Mayor Dickert, didn't you?

A I don't recall.

Q And you're telling me you didn't assist Mr. Marcus in his election campaign in any way?

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A Q A Q

A Q A Q

No. Were you ever approached to assist him?

I may have been, but not by Eric.

Show you what's been marked as Exhibit 1553 to Mr. Tousis's deposition. Is this an e-mail from you to Mr. Tousis dated January 11, 2011?

It is.

Project is dead by now, right?

Yes. It died in June of 2010?

I don't recall the exact date.

All right. It says, "I'm going to run an honorable and truthful campaign," and then it goes on, can you read this, talks about John Dickert. Where did this come from?

From me, apparently.

Did you prepare this for Eric Marcus?

I don't think I did.

Does the text indicate to you that it was prepared for a candidate running against John Dickert?

I don't know what it indicates.

Why are you sending this to Tom Tousis?

I don't recall.

Were you assisting someone in their campaign

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Did you draft that?

A I wrote the e-mail.

Q You were the campaign strategist for that campaign, right?

A I was not.

Q The 2009 campaign?

A Oh, for 2009, correct.

Q You're calling your own candidate's campaign the sleaziest campaign the community has ever seen?

A I don't know what that's referring to.

Q You drafted it, right?

A I don't remember drafting it.

Q Do you believe that the work that you did for John Dickert for his campaign in 2009 was sleazy?

A No. Q So that wasn't a truthful statement here?

A I don't know what statement that is.

Q Was Mr. Tousis considering running against John Dickert for mayor?

A I have no idea.

Q Were you involved in soliciting Dustin Block to submit an open records request on John Dickert's vacation days and travel?

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against John Dickert for mayor?

A No. Q You just decided to prepare this out of the blue and send it to Tom Tousis.

A I have no idea why -- why I wrote this e-mail.

Q It says, "Campaigns are about contrasting my record to his. All this is a stunt to draw attention away from the fact that John Dickert has been running the city into the ground, hemorrhaging jobs, and driving away businesses."

Whose record are you referring to there?

A Which sentence?

Q The one I just read.

A Could you reread it?

Q "All this is a stunt to draw attention away from the fact that Dickert," the sentence right before it.

MR. GERAGHTY: Right there.

THE WITNESS: I have no idea.

BY MR. COHEN: Q And says, "I find it ironic that he wants to avoid criticism a year after running the sleaziest campaign this community has ever seen."

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A Q A Q A Q A Q

I believe I was.

Why did you do that?

He asked me.

He being who?

Dustin.

You ghost wrote a letter, didn't you?

I may have.

And you did that to cause harm to John Dickert, didn't you.

A I did it because Dustin asked me to.

Q Answer my question, please.

A I did.

(Exhibit No. 1712 marked for identification.)

BY MR. COHEN: Q Exhibit 1712, is that a copy of the letter you -MR. SANDERS: Can I see the exhibit first?

MR. COHEN: Sure.

(A discussion held off the record.)

MR. GERAGHTY: Read the whole thing.

THE WITNESS: I did.

BY MR. COHEN: Q Is this a copy of the letter you ghost wrote for Mr. Block?

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A Q A Q A Q A Q

Yes. Was it sent?

You have to ask Dustin.

You don't know?

I do not know.

Why did he ask you to prepare it?

I don't -- I don't remember.

Was it because he was going to run a story on it?

A It may have been.

Q Why -- what's the story about Jean Wolfgang?

Was there some suggestion that the mayor was doing something inappropriate with her?

A You'd have to ask Dustin.

Q Well, you drafted the text of this, didn't you?

A Correct.

Q Can I just look at that for a second?

A Sure.

(Exhibit No. 1714 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1714.

This is an e-mail from you to modecoratingmold@gmail.com dated January 6, 2011, correct?

A Correct.

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Q So the three of you talked about ways in which you could potentially cause harm to John Dickert, correct?

A I don't recall.

Q Well, one way was to send this open records request, correct?

A I have no idea.

Q Why -- who told you to send this to Mike Ottelien?

A I assume Mike did.

Q You suggest that it should be sent to the mayor's office, the development office, Brian O'Connell, the city attorney, Coe, and Spangenberg. Why do you say that?

A I don't recall.

Q Was your intention to cause as much harm to the mayor as possible?

A No. Q Well, why would you send it to all these people?

A I have no idea.

Q Did you get paid for this work?

A No. Q Just something you did on your spare time.

A A friend asked me to do it and I did it.

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Q And that is the address, e-mail address of Mike Ottelien?

A Yes. Q And how do you know Mr. Ottelien?

A He is a friend of Tom Tousis.

Q And why were you -- this is the same draft open records request that you had sent to Dustin Block, correct?

A Is it?

MR. GERAGHTY: Check it out.

THE WITNESS: Yeah. It is.

BY MR. COHEN: Q Did Mr. Block indicate that he wasn't willing to send the open records request?

A I don't recall.

Q How did you get in contact with Mr. Ottelien about this?

A I don't recall.

Q And you knew at the time Mr. Ottelien also disliked John Dickert, correct?

A Yes. Q You learned that from Tom Tousis?

A And from Mike.

Q Directly, correct?

A Correct.

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Q Which friend?

A Apparently Mike.

Q Well, you prepared it for Dustin Block. I thought you said he asked for it.

A Apparently he asked for it too.

Q Was it submitted?

A I have no idea.

Q Was this information -- Strike that.

Was this being prepared to gather information to use in support of Eric Marcus's campaign?

A No. Q Did Mike Ottelien support Eric Marcus in his candidacy for mayor against Mayor Dickert in 2011?

A I don't remember.

Q You don't know?

A I don't think I ever had a conversation with Mike about it.

(Exhibit No. 1715 marked for identification.)

BY MR. COHEN: Q Showing you what's been marked as Exhibit 1715.

That's an e-mail from you to Mike Ottelien dated January 10, 2011, correct?

A Yes.

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Q A Q A Q A Q A Q A

Q A Q A Q A Q

You prepared these questions, didn't you?

I believe so.

And what was the purpose?

I believe Mike was going to a candidate's forum and was going to ask a question.

So you were arming Ottelien with questions to pummel Mayor Dickert with, right?

Mike asked me for some questions that he could ask at the campaign forum.

And that campaign forum involved Eric Marcus also, right?

I believe so. 2011, yes.

Your plan with Mr. Ottelien was to try to make the mayor look bad at this forum, right?

No. The plan was for Mike to ask a question during a campaign forum, and he asked my help to do that.

For what purpose?

You would have to ask Mike.

What do you understand the purpose to be?

To ask a question during a campaign forum.

Isn't it true, Mr. Williams, that you thought these questions would embarrass John Dickert?

No. Do you know if Mr. Ottelien contributed to Eric

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Q Right. In fact, you responded by saying, "This is someone who created a Facebook page to specifically give the information."

Do you see that up on top?

A Yes. Q Who were you referring to?

A I have no idea.

Q How did you learn that?

A How did I learn what?

Q That he had created a Facebook page to specifically give this information.

A That who created a Facebook page?

Q That's what I'm asking you.

A I have no idea.

Q You just -- you have no idea what you're referring to here.

A Well, I know who Ken Brown is, but are you referring to Mark Ranger?

Q Well, Mr. Ottelien says to you, "Zak, funny thing this hit the e-mail after the article hit the paper."

What did you understand him to mean there?

A I have no idea.

Q And then you say, "Yeah, this is someone who created a Facebook page to specifically give

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Marcus's campaign?

A I have no idea.

Q Did you communicate with Mr. Ottelien about information that could be used against the mayor in the election?

A I don't recall.

(Exhibit No. 1716 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1716.

It's a series of e-mails between you and Mr. Ottelien dated January 11, 2011, correct?

A I believe it's one e-mail.

Q All right. Do you know why Mr. Ottelien sent this to you?

A No. Q And it's referring to some communications between Mark Ranger and Ken Brown about information involving John Dickert and Emily Ackerman, right?

A Looks to me like it's a conversation between Mark Ranger and Ken Brown.

Q All right. You've seen this before, haven't you?

A I don't recall, but it's an e-mail that I responded to, so I must have.

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A Q

A

Q A Q A Q

A Q A

the information, the info."

Who were you referring to?

I don't know. I know who Ken Brown is.

And the info is a potential or an alleged affair between Emily Ackerman and the mayor, correct?

Is that what this e-mail is saying?

MR. GERAGHTY: Read it again, then.

You're not -- you're -- you need to take time to read them.

THE WITNESS: Okay. Oh, okay. I did -- I missed that. Apparently it is.

BY MR. COHEN: Do you know who Emily Ackerman is?

Yes. That's Monte Osterman's stepdaughter, correct?

Yes. And it says, "Facebook has zero information about Mark Ranger. Expect that he's a fan of Eric Marcus for mayor."

Do you see that?

I do.

Is that you writing that or is that Mr. Ottelien?

It's not me.

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Q A Q A Q A

Q A Q A

Q A Q A Q A

Or is it Ken Brown?

I have no idea.

Did you do anything with this information?

No. What was the purpose of your communications with Mike Ottelien about this subject?

I don't know. He -- he e-mailed -- apparently he e-mailed me a conversation between Ken Brown and Mark Ranger and then I must have looked into it.

Did you communicate with Dustin Block about publishing an article on this issue?

I don't believe so.

Are you sure about that?

I don't recall I did.

(A discussion held off the record.)

BY MR. COHEN: Did you discuss this information about the mayor and Emily Ackerman with anyone else?

I don't recall.

Did you discuss it with Tom Tousis?

I don't recall.

Did you do anything to communicate this rumor to other people?

I don't recall.

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A Q A Q

Q

A

Frederick who was involved with the campaign with you two years earlier and called Dickert and Monte dumb, right?

I have no idea.

For no particular reason.

I don't understand the context.

All right. Why don't we take a lunch break.

Off the record.

(Lunch break was taken.)

BY MR. COHEN: I want to just go back, Mr. Williams, to Exhibit 1716 and the e-mail that Mr. Ottelien had forwarded to you of the conversation between Ken Brown and Mark Ranger regarding a potential affair between Emily Ackerman and the mayor.

Which is actually, and I don't mean to interrupt you, but it's actually good that you brought that up, because I wanted to actually -- I was trying to figure out what the context was or what the actual e-mail was and what -- what -- what ended up happening is Mike sent this to me and because I -- I'm assuming because I've been involved in -- I was involved in the campaign in 2009 that I may know about a

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(Exhibit No. 1717 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1717.

This is an e-mail from you to Boyd Frederick dated January 16, 2011, right?

A Yes. Q You testified earlier that Boyd Frederick was part of John Dickert's election campaign committee, right?

A Yes. Q You knew him to be a friend of John Dickert?

A Yes. Q And you're communicating here that you have to say that Monte and Dickert are dumber than I thought, right?

A That is what it says.

Q Why would you tell someone you knew to be a friend of John Dickert's that Dickert is dumb?

A I don't recall.

Q What are you referring to?

A I have no idea.

Q Did something happen between -- with the two of them that caused you to do this?

A I have no idea.

Q Just out of the blue you sent an e-mail to Boyd

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Q A

Q

A Q

possible affair. I -- I, you know, looked -- I looked at the Facebook page of Mark Ranger, I mean, the guy looks a little -- he's making some, I mean, some pretty wild accusations. I looked at the Facebook page of Mark Ranger, said, you know, it looks like a fake account, which is what the reference is up there, and you know, essentially, you know, alluded to stay away.

Okay. That's something you thought about over the lunch break?

Well, while we were talking about it I didn't know how to -- to -- to express that or in the context of the -- of a question, I don't know if I was -- if it was appropriate for me to go back.

That's fine. Thank you.

One of the items that you said that you were involved with to cause harm to Mayor Dickert was your involvement in looking at an independent investigation of his expenditures for the 2011 campaign; is that right?

Well, I wouldn't necessarily use the term "harm."

I can read back your testimony if you want.

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A Well, I was, you know, you continue to use the word "harm" and, you know, yes, I, you know, initially agreed with you on the word "harm."

I wouldn't necessarily use the word "harm." I would use "discredit," and certainly in this -in this context it's -- it -- it's about beating him in an election.

Q Which election?

A The -- the 2011, the one that you're referring to.

Q I thought you told me a little bit earlier you were not involved in supporting Eric Marcus.

A I said I did not work for Eric Marcus.

Q Who did you work for?

A I worked for an independent expenditure.

Q You worked for who?

A An independent expenditure.

Q What is that?

A It is an -- it is an outside group that spent money during the campaign, separate from -from -- from the candidates.

Q And that was CRG? A Yes. Q And that's Citizens for Responsible Government?

A Uh-huh, it is.

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A Correct.

Q Okay. So although you weren't working directly for Eric Marcus you were working for a cause whose sole purpose was to support Marcus and cause damage to Mayor Dickert, right?

A To support Marcus and to cause John Dickert to lose the election.

Q All right. That's what you wanted, right?

A That's what I was hired to do.

Q And you did so, you agreed to do so because you disliked John Dickert, correct?

A I was hired to work on the independent campaign, and that is what I do for a living.

Q Mr. Williams, I show you what we have marked as Exhibit 1554 to Mr. Tousis's deposition. This is an e-mail from Mr. Tousis -- Strike that.

Mr. Tousis forwarded an e-mail that he had received of a Google alert on Eric Marcus for mayor, right, of a story in the Root River Siren?

A Yes, yes.

Q Are you familiar with the Root River Siren?

A Yes. Q It's an online publication?

A Correct.

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Q And that's Ken Brown, correct?

A Yes. Q And that's who appears in this Exhibit 1716, right?

A Yes. Q Communications with Ken Brown, that ultimately was your client, right?

A Yes. Q Had you started your client relationship by January of 2011?

A I don't -- I don't recall.

Q All right. And you called it an independent expenditure?

A Yes. Q That means someone who's been hired to do what?

A To, on behalf of an organization, conduct a campaign separate and outside of the candidates.

Q But for the purpose to affect the election, right?

A Yes. Q And in this case to affect the election negatively against Mayor Dickert, correct?

A Correct.

Q And in favor of Eric Marcus.

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Q You've read it before, haven't you?

A A couple times, yes.

Q This was an article about David Maack who was an alderman at the time, right -A Yes. Q -- for the City of Racine? Taking -- taking issue with Eric Marcus and his candidacy for mayor, right?

A Yes. Q All right. You read the article, right?

A I believe I did.

Q Okay. Do you know why it is Mr. Tousis had a Google alert for Eric Marcus for mayor at this time?

A I have no idea.

Q Did you?

A No. Q Meaning did you have one?

A No. Q And then he forwards it to you, the article to you, and then what's your answer, sir? What's your response?

A "What a cunt."

Q And you're referring to the author of the Root River Siren.

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A Q A Q

Yes. Do you know who that is?

I don't know her name.

Do you think that's an appropriate term to use about a woman?

A No. Q Do you use that term often?

A No. Q And you're saying, you're using that term in relation to her because you didn't like what she was saying about Eric Marcus, right?

A Probably.

(Exhibit No. 1721 marked for identification.)

BY MR. COHEN: Q In fact, at this time period if anybody's said anything that was contrary to Eric Marcus and his efforts to run for mayor you were taking issue, right?

A No, not necessarily.

Q Show you what we've marked as Exhibit 1721, and this is another Google alert for Eric Marcus for mayor that Tom Tousis forwarded to you with some various blogs, right?

A Yes. Q And this one is from Mino

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Q Show you what's been marked as Exhibit 1555 to Mr. Tousis's deposition. If you can read this series of e-mails and then let me know when you're ready to talk.

A Okay.

Q All right. The first one is an e-mail from you to Mike Ottelien regarding a radio ad final.

Do you see that?

A Yes. Q And was that a radio ad for Eric Marcus's campaign?

A No. Q Was it a radio ad attacking John Dickert?

A Yes. Q And who was that prepared by?

A It was prepared for the independent expenditure group.

Q By you.

A Yes. Q And why are you forwarding it to Mike Ottelien?

A He's the funder.

Q He funded the CRG? A He's the one who provided the funds to the PAC that CRG set up.

Q And what was the PAC that CRG set up?

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A Q A Q A Q A Q

A Q A Q A Q A

B-I-M-A-A-D-I-Z-I-W-I-N, The Good Life -Okay.

-- by David Maack? Do you see that?

Yes. And do you know where this came from?

No. Did you read the article?

I believe I did.

All right. And this was, again, Alderman Maack being critical of Eric Marcus and his candidacy, right?

I believe so.

And then you responded to Mr. Tousis saying, "What a lying sac of shit," right?

Correct.

And are you referring to David Maack?

Yes. And that's because he expressed an opinion that was contrary to Eric Marcus's efforts, right?

I guess, yes.

MR. GERAGHTY: Don't guess. If you don't know or -THE WITNESS: I don't know what the article says, so I don't recall.

BY MR. COHEN:

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A I actually do not recall.

Q How much did he fund?

A I don't recall. Maybe two grand. It was whatever the cost of the radio ad was.

Q And you're sending it to him for final approval?

A Yes. Q And then you forwarded it to Tousis, correct?

A Yes. Q And he says, "The ad looks good," correct?

A Yes. Q Did he also financially support CRG? A No. Q Was he involved?

A No. Q Why did you send it to him for review?

A I wanted him to take a look at it.

Q Why? A Because he's down in Racine and I valued his opinion.

Q And you knew at that time he shared your dislike for John Dickert, right?

A I believe that he wanted to see Eric Marcus win, yes.

Q In fact, he supported Marcus, didn't he?

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A You'd have to ask him.

Q It says he says, "Look at Racine Uncovered."

Do you see that?

A Yes. Q Was that referring to an article?

A It could be. I don't recall.

Q Racine Uncovered is an online newspaper?

A Yes. Q And that's run by Beth David?

A I don't know who it's run by.

Q You know Beth David, don't you?

A No, I never met Beth David.

Q You never communicated with Beth David?

A I don't think I have. Have I? Q Yes, you have.

A Okay.

Q But you're telling me you don't know who she is.

A I don't recall who she is.

Q And then Tousis responds to you and says, "Who is jobs4racine.com?" Do you see that?

A Yes. Q And was that in the radio ad?

A I believe it was.

Q And who's jobs4racine.com?

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Q And then you say, "Still working on the page."

That's referring to the webpage, right?

A Yes. Q And that's a jobs4racine.com webpage for CRG. A For the PAC that CRG set up, correct.

Q And if I'm understanding you correctly that website and the ad wasn't promoting Eric Marcus as -- as much as it was attacking John Dickert.

A Correct.

Q And then you say to Mr. Tousis you're going to use his home number.

A Yes. Q You're referring to John Dickert's number, aren't you.

A Yes. Q And you were going to use his home number on the website so that people who saw the website would call him directly at home.

A Yes. Q Did you think that was a bit sleazy?

A No. Q And you say, "Have Mike give me a call."

Is that Mike Ottelien?

A Yes. Q What did you want to talk to him about?

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A That's the PAC that CRG set up.

Q That was -A Or that is the website that was associated with the PAC that CRG set up. I don't know if that was the actual name of the PAC. Q Did you assist on working on the website?

A My partner did.

Q And your partner's name?

A Matt Pidgeon.

Q How much did you bill CRG? A For the website?

Q For their work.

A For the entire work?

Q Yes. A I don't recall. Around 2,000, maybe a little bit more.

Q How did they come to you?

A I actually don't recall.

Q Was it through Mr. Tousis?

A I don't recall.

Q Had you known Mr. Ottelien before you began work on CRG? A Yes. Q Through Mr. Tousis.

A Correct, yes.

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A Probably about the funding.

Q Had you been paid at that point?

A I don't recall.

(Exhibit No. 1725 marked for identification.)

BY MR. COHEN: Q I'm going to show you what we've marked as Exhibit 1725. What is this?

A This is the webpage, I believe.

Q So this is the webpage for Racine jobs, I'm sorry, jobs4racine.com?

A Right. I believe that's the -- the -- the address of the webpage.

Q And at the bottom it says, "Paid for by Citizens of Responsible Government of Racine, Pam Cox, treasurer." Do you see that?

A Yes. Q Who's Pam Cox? A She's the treasurer for Citizens for Responsible Government of Racine.

Q And you designed this page, didn't you?

A Yes. Q And the purpose was to attack John Dickert, correct?

A The purpose was to criticize John Dickert in that mayoral campaign.

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Q And you used his home telephone number, didn't you.

A Yes. Q Where did you get the information in the text?

A Probably news articles.

Q The reference to settling a frivolous lawsuit filed by a friend costing taxpayers another 50,000, what are you referring to there?

A I don't recall.

Q Do you have any factual basis for that statement?

A I'm sure I do.

Q What is it?

A I don't recall.

Q What friend is he -- are you talking about?

A I don't recall.

Q What lawsuit are you talking about?

A I don't recall.

Q You say here, "Fire the whistleblower who was trying to protect our kids."

Who are you referring to there?

A Bill Bielefeldt.

Q And how did you find out about that?

A The newspaper articles.

Q All right. And isn't it true that

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Q A Q A

Q A Q A

Q A

Q A Q

that I created.

BY MR. COHEN: And was this for CRG? I believe the first two were possible ones that were never actually used, but I'm not -Who's the Coalition for Racine Jobs?

I don't recall if that was going to be the PAC name when we created these or if it was just a placeholder when we created them, but we never used them.

How about the third one, excuse me, fourth one, was that used?

One, two, three, the friends for -No, the fourth page.

Well, it's front/back. So that is a back of a -- of a draft of a mail piece that was not used as a mail piece.

So this text was never published?

That's not what I said. I said that this draft mail piece was not used. We actually took the -- the -- the -- the webpage and the plan was to turn it into a mail piece.

And did that occur?

No. All right. So my statement was correct, it was

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Mr. Bielefeldt was fired because there were problems with monies that he had paid out to contractors for work that had not been done?

A I do not believe that is true.

Q You don't think so?

A No. Q Did you look into it?

A I used the articles that -- that were done.

Q Did you look at any of the city records?

A No. Q Is it your practice to make statements about people without doing a proper investigation?

A I did do a proper investigation.

Q Did you look at any of the city records involving Mr. Bielefeldt's termination?

A No. (Exhibit No. 1718 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1718.

Can you tell me what that is? Wait, what number is that?

MR. GERAGHTY: 1718.

THE WITNESS: Exhibit 1718. These are draft -- some of these are draft mail pieces. Some of them are actual mail pieces

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never published, correct?

A Correct.

Q And are you telling me that the Coalition for Racine Jobs was a name that was -- was going to be used but wasn't used for the PAC? A I don't -- I do not recall whether it was just a placeholder name before they decided on how to do disclosure on the independent expenditure or if it was a future plan that -- plan's name that was never used.

Q Show you what was previously marked as Exhibit 1556 -A Yes. Q -- to Mr. Tousis's deposition. This is entitled, actually, the attachments is, states, "Marcus walk card PDF," right?

A Yes. Q And Matt Pidgeon sends an e-mail to you that says, "Walk card rough draft," and you forward it to Mr. Tousis, right?

A Yes. Q And this was a walk card promoting Eric Marcus for mayor, wasn't it?

A Yes. (Exhibit No. 1722 marked for identification.)

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BY MR. COHEN: Q Show you what we marked as Exhibit 1722. It's the same e-mail with the walk card attached, right?

A Yup. Q And it's addressed to "Vote Eric Marcus for Mayor of Racine," right?

A That's what it says.

Q And you -- you and your partner prepared this walk card, right?

A Yes. Q And it was used for Eric Marcus's campaign, wasn't it?

A I don't believe it was.

Q You don't believe this was ever used?

A No. Q Why? A Because -- because I never actually worked for his campaign.

Q Well, do you know whether CRG ever used it?

A I do not.

Q I mean, you prepared it for the express purpose of it being used in support of Eric Marcus's campaign, correct?

A I don't actually remember that that was going

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line?

A I don't recall.

Q No recollection?

A No. (Exhibit No. 1719 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1719.

Let's start from the bottom. It's an e-mail from you to crgofracine@tds.net dated February 8, 2011 and you indicate, "The website is now live," right?

A Yes. Q That's the website that you prepared and activated to attack John Dickert, right?

A To criticize John Dickert, yes.

Q And by the way, when you're sending an e-mail to crgofracine@tds.net is that Ken Brown?

A I believe it is.

Q He's your client contact even though Mr. Ottelien put up the money to fund the PAC? A Yes. Q Did you consider Mr. Ottelien to be your client contact too?

A Yes. Q And then Mr. Brown writes back to you, "By the

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to be the purpose.

Q Oh, you just spent time working on a walk card for Eric Marcus for fun?

A No. It was my understanding is that we were going to, is that we were creating a walk card to be used for the independent expenditure group on behalf of Eric Marcus, and it does say that it was, you know, the paid for line, the only explanation I can give is that my partner misunderstood me when I told him about it.

Q Not only does it say authorized and paid for by Eric Marcus for mayor, but it also has his website on the top, doesn't it?

A It does.

Q And it's your testimony that this was never used by Eric Marcus in support of his campaign against John Dickert?

A As far as I know.

Q Did you have some conversation with your client about whether it was proper to use John Dickert's home telephone number on the website?

A I probably did.

Q What do you remember about that?

A I don't -- I don't actually remember details.

Q And didn't he ask you if it was crossing the

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A Q A Q

A Q A Q

A Q

way, BTW, where does the phone number go and the data collected on the site? Will that be accessible to me as well or will it go to CRG?" And you answer with respect to the data and you say, "The phone number is Dickert's home," and he says, "LOL." Do you understand that to be laughing out loud?

Yes. And then he says, "Isn't that crossing the line just a bit," right?

Correct.

And you say, "It's a published number. I know he will hear about them if his wife gets the messages as opposed to the rude man secretary," right?

Yes. And you're referring to Greg Bach as the rude man secretary?

Yes. And you wanted Mayor Dickert to hear complaints from those who looked at your website through his wife.

Yes. And then you say, "I'm waging a psychological war as well as communicating to voters. I am

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winning on both counts."

Mr. Williams, were you waging a psychological war against Mayor Dickert?

Well, that's what I wrote.

And that's what you believed at the time, right?

Yes. And why do you think that you were winning on both counts?

I don't recall.

You weren't winning at all, were you.

No. Do you enjoy this?

No. The psychological war is you want to cause as much harm to John Dickert as possible, right, that's what you enjoy doing.

That is not true.

Was -- who's Scott Sharp?

He is a labor leader for one of the AFSCME locals.

And you knew that he was a long-time opponent of Mayor Dickert as well, right?

Yes. And his wife, Penny Sharp?

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A Yes. Q That's how you got to know him?

A Yes. (Exhibit No. 1729 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1729.

This is an e-mail from you to Mr. Sharp dated February 9, 2011 and you inform him that the website is up and running, radio is running, and then you say, "I'm going to have an e-mail later today and go out announcing the website and asking people to sign up to send Dickert a message." Do you see that?

A Yes. Q By this point had Scott Sharp told you that he wasn't going to participate in the funding of the PAC? A I don't recall. I was trying to get him to -to fund the -- the PAC and he -- he -- after the primary.

Q And when was the primary going to be concluded?

A Mid February, so it was shortly after this e-mail was sent.

Q All right. Was that the purpose of this e-mail?

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Q A Q A Q A

Q

Yes. She didn't like John Dickert either, right?

No. And you knew that for some time, right?

I wouldn't say for some time.

Were they both involved with the CRG? No. Neither one of them?

I tried to get Scott's union to fund a portion of the independent expenditure, but I was not able to do so.

Who else did you contact to fund the PAC? I also contacted a couple of the building trades -Who? -- through Tom Reiherzer. I don't know exactly which unions.

Who is Tom Reiherzer?

He is -- he runs the building alliance, which is a -- kind of a liaison between the building trades and the -- and the contractors and he -he comes out of the building trades, very well respected. He kind of is the lead guy for the building trades in southeast Wisconsin.

Was he involved in the West Racine project?

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A Yes. Q You wanted to inform him of what you were doing to see if he would contribute.

A Correct.

Q At some point in time did you come to learn that Mr. Tousis had set up a Google alert for John Dickert as well?

A I believe so.

Q Did you do so as well?

A No. Q Did you ask him to do so?

A I don't believe so.

Q Show you what was previously marked as Exhibit 1557 to his deposition, he being Mr. Tousis.

Mr. Tousis forwards you on February 10, 2011 a Google alert involving John Dickert which was a link to an article about Governor Walker announcing major Racine County projects, right?

A Yes. Q And a quote here from John Dickert about economic development, right?

A Yes. Q All right. And then you respond and say, "You need to have a talk with your boys." That's what you said to Mr. Tousis, right?

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A Yes. Q Who are his boys?

A I was making a joke about his close relationship with people within the Walker administration.

Q Did you want him to have a talk with his boys?

A I didn't think a talk would actually happen.

Q So this was a joke?

A Yes. Q Meaning that the Republicans shouldn't be making John Dickert look good?

A Correct.

Q That's how you felt, right?

A Yes. Q Was one of his boys Van Waangard that you're referring to?

A I don't believe I was.

Q Do you know that Mr. Tousis has a relationship with Van Wanggaard, right?

A Yes. Q And he -- he and you had talked to Van Waangard about the West Racine project, correct?

A Correct.

Q And he's Republican, right?

A He is.

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justice are also scheduled to attend, Sharp said," right?

A Yes. Q All right. And then you give some advice to Penny Sharp, right?

A I do.

Q "Make sure that there are signs there." Were those signs for Eric Marcus?

A I believe so.

Q "The press is going to be at this meeting." So you're giving advice to the chairman of the campaign for Eric Marcus on how to promote her candidate, right?

A I'm making a suggestion, yes.

(Exhibit No. 1723 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1723, e-mail from you to Dustin Block dated February 13, 2011, two days after your communication with Penny Sharp. You say, "What time and where on Monday? Make sure you bring Dickert's last two campaign reports."

Are you meeting him?

A Yes. Q And what's the purpose of the meeting?

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Q Did you ever -- Strike that.

Did Penny Sharp become actively involved in Eric Marcus's campaign?

A I believe she did.

Q And did you ever communicate with her to give her some advice on her work on the campaign?

A I may have.

(Exhibit No. 1720 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1720.

Do you know what position Penny Sharp had in Eric Marcus's campaign team?

A She may have been the campaign manager.

Q You knew that, didn't you?

A I believe she was. I don't know for sure.

Q And you have an e-mail here dated February 11, 2011 and you've got a link here to an article in the Journal Times. Do you know what that refers to?

A Yes. Q What?

A The state Democratic Party chairman was speaking in Racine.

Q Great. And it says, "Mayoral candidate Eric Marcus and a few candidates for Supreme Court

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A Dustin asked me to go over the more recent Dickert campaign reports and give an analysis.

Q For what purpose?

A He was writing an article about the -- the campaign finances for the -- for the -- for the campaigns.

Q Did he write the article?

A I don't recall. I assume he did.

Q Did you review the reports?

A I did.

Q Were you paid by Dustin Block?

A No. Q This is just something you did on your own.

A He asked -- he asked for my help and I gave it to him, yes.

Q And why did you -- you charged the CRG for your work. Why didn't you charge Dustin Block for your work?

A It's -- it's a friendly reporter who's asking a favor of me.

Q To review the campaign reports of your former boss and give him information for an article.

A For his current campaign reports for that current campaign that I was not involved in, yes.

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Q And you were hoping that he would publish a negative article that would help Eric Marcus, correct?

A I was hoping he would write an article about the campaigns.

Q Negative to John Dickert.

A Not necessarily.

Q That's the only purpose you were involved, right?

A No. A friendly reporter asked me for a favor of -- in my line of work, of course I'm going to -- to help them out.

Q Well, did you do a critical analysis of the reports?

A No. I -- I went through and he asked me about industries, he asked me about certain donors, and -- and I gave that analysis.

Q And sitting here today you don't know whether that information was used by him in a report.

A I don't remember if it was or not.

Q So that was a Sunday. You were meeting him on Monday, right?

A I don't recall. Yes, yes that is -Q It says in the e-mail, right?

A Correct.

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exploiting that information could cause the public not to like John Dickert and vote for him, correct?

A It would cause the public not to vote for John Dickert, correct.

(Exhibit No. 1726 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1726. I want to refer your attention to the bottom of the page, an e-mail to Mr. Brown at CRG of Racine regarding Dickert mail and you ask, "Can you scan and e-mail me a copy of the Dickert mailing that he sent out?"

Do you see that?

A I do.

Q And why were you asking for that?

A Because I'm being paid to communicate in that campaign on behalf of the independent expenditure, and having pieces of the candidates is helpful in that.

Q At this point in time you're looking for any information you can regarding John Dickert to try to discredit him, correct?

A I'm looking for any information that I can use to criticize him in an election, yes, because

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(Exhibit No. 1724 marked for identification.)

BY MR. COHEN: Q So I show you what's been marked as Exhibit 1724, which is Monday, February 14, and you say to Penny Sharp, "Don't forget to send me the Becker transcript." Do you see that?

A Yes. Q All right. And then she says, "Tom told me that you had it, otherwise I would have done it last week. Sorry," and then you said, "I thought you had, but I was mistaken."

What are you referring to?

A I'm referring to a transcript of Gary Becker.

Q And what about it? Why were you asking for it?

A I actually don't recall. I never received it.

Q You were asking for it because you thought there was something mentioned about John Dickert in that transcript, right?

A Correct.

Q And what was that something?

A That he was an alibi -- that Becker was trying to use him as an alibi witness.

Q And you wanted to exploit that, didn't you.

A Yes, in the campaign. It's a valid criticism.

Q And you thought that by exploiting, potentially

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that is what I'm being paid to do.

(Exhibit No. 1733 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1733.

This is an e-mail from you to Mr. Scott Sharp regarding labor, "Racine labor IE." Do you know what "IE" stands for?

A Yes. Q What?

A Independent expenditure.

Q So is this further on the possibility of his labor group paying for the PAC? A Yes. Q And you say, "How did Saturday go?"

What are you referring to there?

A I don't recall. It may be a campaign forum.

Q And then you say, "You and I should sit down and start to map out the different pots of money. When are you available this week?"

What are you referring to with respect to the different pots of money?

A Different labor unions.

Q As contributing to the PAC? A Yes. Q And you say, "Dickert is reacting to everything

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A Q A Q A Q A

Q A

we do. His radio ad is a direct response to ours. We need to keep him on the defensive."

Do you see that?

Yes. And the "we" means you and all the other people that are in opposition of John Dickert like Scott Sharp, right?

No. It's the PAC. I'm referring to the PAC and hopefully Scott would be part of the PAC. All right. And then Scott says, "I agree," right?

Yes. At this point in time he had not decided not to contribute through the union to your PAC? Correct.

And why is it, did he explain to you why he didn't want to contribute eventually?

Well, initially it was because his labor union doesn't get involved in primaries and so they were waiting until after the primary, and then the primary election was so lopsided that it didn't make any sense to continue on.

When you say it was so lopsided do you remember what the percentages were?

It was significant. 70s, maybe, 60s, 70,

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q

Yes. And did you ask Penny Sharp to get it for you?

Yes. Why? I actually don't -- don't recall.

Why not just get it yourself, sir?

I'm not -- I'm not going to walk into city hall and ask for John Dickert's campaign report.

You want to do everything behind the scenes so no one knew you were involved, right?

No. No? No. What complaint were you going to file?

I actually do not recall.

Well, it had to deal with his finance report, right?

Yes. Had you talked to the Sharps about filing a complaint against Dickert?

I am in this e-mail.

Had you talked to them before that?

I don't recall.

Then you reference Becker's documents again with Dickert's name in it, right?

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probably 70s.

Q And by that point in time Eric Marcus was no longer a viable candidate?

A Correct.

Q So it didn't make sense to spend more time and effort attacking John Dickert on his behalf, right?

A Correct.

Q And so you stopped in all efforts after that point.

A Yes. Q Sure about that?

A Yes. (Exhibit No. 1727 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1727.

This is an e-mail to you from Penny Sharp and Tom Reiherzer. For the record it's R-E-I-H-E-R-Z-E-R. And you're asking for an electronic copy of Dickert's report, and you say, "I need it so I can get the complaint put together and filed ASAP." What are you doing here?

A Apparently looking at John Dickert's report.

Q Campaign Finance Report?

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A Yes. Q You're gathering as much information as you can to try to create problems for John Dickert, aren't you.

A I would not say cause problems.

Q Really?

A Yes. Q You're about -- you're going to file a complaint about him?

A Yes. Q Who's Scott? Is that -- who's that reference to, Scott Sharp?

A Yes. Q And who's Wes? A Gable.

Q Who is Wes Gable?

A He's the head of the Teamsters union.

Q Who's Gary Burns?

A I don't recall.

Q And what are you referring to about being there? Some meeting?

A Actually, I don't recall.

Q At some point did you attempt to gain some information about John Dickert from Mick Wynhoff?

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A I don't recall.

Q You testified earlier Mr. Wynhoff was part of John Dickert's mayoral campaign staff, right?

A Yes, yes.

Q And you knew him to be a friend of John Dickert, right?

A Yes. Q Did you try to get some information out of him that was negative about John Dickert?

A I don't recall.

(Exhibit No. 1728 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1728.

This is an e-mail from you to Ken Brown at CRG dated February 25, 2011, correct?

A Yes. Q And you say, "Can you tell me exactly how your conversation with Mick went?"

That's Mick Wynhoff, isn't it?

A Yes. Q And what was your understanding of why Mr. Brown was meeting with Mr. Wynhoff?

A Mick was trying to get information out of Kenosha about the independent expenditure.

Q And how did you learn that?

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A I don't recall.

Q Who is Bill Bielefeldt?

A He is the whistleblower who was fired by the City of Racine.

Q And he filed a lawsuit against Mayor Dickert alleging slander, correct?

A Yes. Q And that was filed shortly before the election between he and Eric Marcus, right?

A I don't recall.

Q You don't recall?

A I don't.

Q Were you involved in any discussions with Mr. Bielefeldt or anyone else about him filing the complaint?

A No. Q Did you urge him to file?

A No. Q Did you meet with Mr. Bielefeldt before he filed his complaint?

A I had lunch with Mr. Bielefeldt. I don't know if it was before the complaint was filed.

Q What was the purpose of the lunch?

A He and Tom were having lunch and I walked into the restaurant.

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A Q A Q A Q

A Q

A Q A Q A Q A Q A Q

Ken told me.

And what did he tell him?

I don't -- I actually do not recall.

What did Kenosha tell you about his conversation with Mr. Wynhoff?

I don't recall.

"I'm curious at what they think they know about our project."

Are you referring to Dickert there?

Dickert and his campaign team.

And then it says, "Also my name came up several times in Tom's meeting with Dickert, so I'm curious how that went as well."

What are you referring to?

Tom had a meeting with John Dickert.

About what?

I don't recall.

By then the West Racine project was long over with, right?

Correct.

What was the purpose of the meeting?

I don't recall.

What did Tom tell you occurred at the meeting?

I don't recall.

What was said about you at the meeting?

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Q When?

A I don't recall.

Q And you don't know whether it was before or after he filed the lawsuit?

A I don't.

Q He had already been fired by the city, right?

A Yes. Q And were you involved in assisting Mr. Bielefeldt in getting an attorney to file that lawsuit?

A No. Q You knew that Tom Tousis recommended Mr. Santarelli to him, right?

A Yes. Q You heard that from Mr. Tousis, right?

A Correct.

Q Do you know how it is that Mr. Tousis got to discuss with Mr. Bielefeldt the referral of an attorney to file a lawsuit against the mayor?

A I don't.

Q You knew that Mr. Bielefeldt was going to file that slander lawsuit before he filed it, didn't you.

A I actually don't recall.

(Exhibit No. 1730 marked for identification.)

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BY MR. COHEN: Q I'll show you what's been marked as Exhibit 1730, a series of e-mails here. Let's start at the bottom. There's an e-mail from you to Boyd Frederick dated Monday, February 21, subject, "Dickert lawsuit," and then there's a link to Racine Uncovered. That's referring to a link to Racine Uncovered's website which had a story on the lawsuit, correct?

A Yes. Q Why are you sending this to Boyd Frederick?

A I thought he would be interested.

Q Why? A I just thought he would.

Q Did you understand that Boyd Frederick had a falling-out with Mayor Dickert?

A I understood he was not happy.

Q Did you know why?

A Not specifically, no.

Q How did you learn that he was not happy?

A He told me.

Q What did he tell you?

A He was unhappy with the way he was treated.

Q How? A I don't know specifically.

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A I assume he means Wayne Clingman.

Q And you know Mr. Clingman also to be an opponent of Mayor Dickert?

A Yes. I never met Wayne, though.

Q He's a member of the Racine Equality Project?

A I -- I have no idea.

Q And then you say, "And -- and Boyd says why did Tommy do it?"

Do you see that?

A Yes. Q What's he referring to?

A Tom Tousis.

Q What about Tommy doing what? Why did Tommy do what?

A He's -- he's making a reference to Tom helping Bill Bielefeldt.

Q And you say, "Tom -- Tommy Santarelli went to school with family." That's -- I'm sorry, you say, "Do what," and he says, "Tommy Santarelli went to school with family," and then you explain, "He's the lawyer we found for Bill."

Do you see that?

A Yeah.

Q So you were involved.

A No. I've actually never met Santarelli.

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Q Was it that he thought he would get a job from the mayor after the election if the mayor was elected?

A I think that was one.

Q All right. And Mayor Dickert told him that there were no jobs for him, right?

A Correct.

Q You expected a job too, didn't you?

A No. Q Did you tell the mayor that?

A No. (Exhibit No. 1731 marked for identification.)

BY MR. COHEN: Q I'm going to show you what's been marked as Exhibit 1731. Is that a copy of the article, if you look at page 3 of 11, about the lawsuit with a copy of the lawsuit attached?

A It is.

Q Now, let's go back to 1730, please. So you forwarded this to Boyd Frederick and he responds to you at 1:11 p.m., "Wayne already told me."

Do you see that?

A Yes. Q Who's Wayne?

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Q Why did you say, "He's the lawyer we found for Bill"?

MR. GERAGHTY: Didn't Boyd Frederick state that?

MR. COHEN: No. Zak did.

THE WITNESS: I don't know.

BY MR. COHEN: Q By "we" you meant you and Tousis, didn't you?

A I was referencing Tousis, yes.

Q You didn't say "Tousis," you said "we," didn't you.

A I did.

Q And it's your testimony you weren't involved at all before the lawsuit was filed in analyzing potential claims against the mayor?

A Yeah.

(John Dickert enters proceedings.)

MR. COHEN: Let the record reflect that John Dickert is here.

Q I show you what's been marked previously as Exhibit 1563. That's an e-mail from you, Mr. Williams, to Tom Tousis dated February 13, 2011, right?

A Yes. Q And if you look at the prior Exhibit 1770

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Q

Q

A Q

A

you'll see that the lawsuit was filed on -MR. SANDERS: Mr. Cohen, I'm going to object. I'd like to see the exhibit.

MR. COHEN: Sorry. Moving too fast.

MR. SANDERS: Thank you.

MR. COHEN: You okay?

MR. SANDERS: Yup.

BY MR. COHEN: All right. If you look at Exhibit 1770 you see that the lawsuit was filed on March 21, correct?

MR. SANDERS: Objection. 1770?

MR. COHEN: I'm sorry, 1730. Can't read my own handwriting. Let me start over.

If we go back to Exhibit 1730 you forwarded to Boyd Frederick the Racine Uncovered article about the filing of the lawsuit against Mayor Dickert on February 21, correct?

Yes. Exhibit 1563 is an e-mail from you to Mr. Tousis dated February 13, 2011 articulating comments that you prepared about Mr. Bielefeldt's claim against Mayor Dickert, correct?

He asked my opinion about -- about the

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Q A Q A Q

A Q A Q

A Q A Q A Q A

Do you know who paid for Mr. Santarelli's fees?

No. Mr. Tousis ever tell you he did?

No. Did Mr. Tousis tell you why he referred Bill Bielefeldt to Tom Santarelli to file the lawsuit against the mayor?

Yes. Why? He felt that Bill Bielefeldt was getting a raw deal.

And at the time the both of you wanted to see what the mayor's chances of being reelected are, right?

I don't think it had anything to do with the reelection.

Just so happened to be filed right before the reelection, right?

I had nothing to do with the filing.

Did you think that the filing of the lawsuit would help Eric Marcus in the election?

I probably did.

In fact, you shared that opinion with other people, didn't you?

I probably did.

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Q A Q A Q A Q A Q A Q A Q A Q A Q A

slander -- about a potential slander and I gave my answer.

You had no legal training, did you?

No. Did someone assist you with this?

No. Did you understand that Mr. Tousis was going to pass this on to Mr. Santarelli?

No. Was this going to be used for Mr. Bielefeldt's lawsuit that had not yet been filed?

No. Why are you taking time to talk about this?

Because Tom asked me a question about it.

You say, "Textbook slander."

Have you read many textbooks on slander?

No. Did Mr. Tousis financially participate in Mr. Bielefeldt's lawsuit?

I don't believe so.

Did he pay Mr. Santarelli?

No. Did you ever see the retainer agreement between Santarelli and Bielefeldt?

No.

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Q Including your partner, right?

A Who? Q Matt Pidgeon?

A Yes. Q Was he your partner?

A Yes. Q All right.

(Exhibit No. 1732 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1732.

This is an e-mail from you to Matt Pidgeon dated February 14, 2011. It's before the lawsuit was filed, right?

A Yes. Q And you say, "This is the whistleblower," and you give Mr. Bielefeldt's information, right?

A No. This is -- he went on the -- the website that you referenced earlier, the one paid for by the Citizens for Responsible Government and signed up to be on the e-mail list, and he sent that to me and asked me as a, because I was collecting the information, and I responded to him that this is who it was, because I had referenced it before.

Q You put the information on the website?

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A My partner and I did. I did not physically do it. My partner is the more technical.

Q And that was to bring public attention to Mr. Bielefeldt's claim against the mayor, right?

A No. Q What was the purpose of it?

A It's -- it's the -- the website for the independent expenditure.

(Exhibit No. 1734 marked for identification.)

BY MR. COHEN: Q I'm going to show you what we've marked as Exhibit 1734. It's an e-mail from you to Penny Sharp dated February 18, 2011 and you say, "Dickert's name is not mentioned." Do you know what you're referring to?

A I do not.

Q Did you advise Penny Sharp that you had learned that Mr. Bielefeldt was going to file a lawsuit against the mayor for slander?

A I don't recall.

Q Did you have communications with Scott and Penny Sharp about that before Mr. Bielefeldt filed the lawsuit?

A I don't recall.

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A Q A Q A Q

I have no idea.

Why did Boyd Frederick tell you that?

I have no idea.

Did you use this information against the mayor?

No. Did you engage Dustin Block in the Bill Bielefeldt lawsuit so he would write a story?

A I don't recall.

(Exhibit No. 1736 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1736.

That's an e-mail from you dated February 21 -MR. SANDERS: Mr. Cohen, I've got to see the exhibit first. Thank you.

MR. COHEN: I'm sorry.

MR. SANDERS: It's all right.

MR. COHEN: What number is that?

MR. GERAGHTY: 1736, I think.

MR. SANDERS: Yup.

BY MR. COHEN: Q 1736. It's an e-mail from you to Dustin Block and you're forwarding to Mr. Block the link to Beth David's article on Racine Uncovered that attached Mr. Bielefeldt's lawsuit, correct?

A I don't know what the article's actually about.

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Q You have no idea what you're referring to here?

A I do not.

(Exhibit No. 1735 marked for identification.)

BY MR. COHEN: Q What was the date of the primary?

A I don't recall.

Q Show you what we've marked as Exhibit 1735.

These are a series of e-mails from you, between you and Mr. Tousis regarding John Dickert, right?

A Yes. Q And you say on February 20, 2011, "He repeated the -- he repeated the Bill is an embezzler comment at a meeting today," and Tousis says, "What meeting," and you respond, "His minions."

Do you see that?

A Yes. Q Where did you get that information?

A Boyd Frederick.

Q And what did Boyd Frederick tell you?

A That he had repeated that Bill was an embezzler.

Q To him?

A At a campaign meeting.

Q Who else was present?

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Q A Q A Q A Q A Q

A

Q

Well, you just saw it a minute ago.

Oh, it's the previous exhibit?

Yes. Is it 1731?

Yes. Okay. Yes. And that's the same day that the lawsuit's filed, right?

I have no idea. Is it?

Well, if you want to look back at Exhibit 1730 or the picture on the website actually shows the complaint with the filing date.

Okay.

MR. GERAGHTY: Maybe look here. This is the complaint.

THE WITNESS: Okay.

MR. GERAGHTY: Is that what you're talking to, Michael?

MR. COHEN: Yes. MR. GERAGHTY: Okay. There it is, up there.

THE WITNESS: February 21, yes.

BY MR. COHEN: And your hope was by forwarding this to Dustin Block that he'd run a story on Bielefeldt's

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lawsuit against the mayor, right?

A Yes. Dustin had written an article about Bill being fired before.

Q And your interest here is creating more negative publicity about the mayor, correct?

A Because Dustin had written an article on the issue before I thought he might be interested.

Q Did you ever talk to Tom Santarelli about Bielefeldt's suit?

A No. I've never met Tom Santarelli.

Q Did you review a copy of the complaint before it was filed?

A No. Q Did you follow up with Dustin Block with any other information regarding Mr. Bielefeldt's claims?

A I don't recall.

Q Do you remember getting a copy of the radio broadcast?

A I believe I may have.

Q The broadcast at which the alleged slanderous statement was made?

A I believe so.

Q What was your purpose in getting that?

A I was interested.

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A Q

He ran an online newspaper? He doesn't need to get that from you, does he.

He asked me for it.

Do you know of anybody who contributed to Mr. Bielefeldt's legal fees?

No. So the election occurred in May, right, 2011?

No. When did the election occur?

Which -- which election?

Mayoral election of Eric Marcus.

Which -- April 2011.

April of 2011. And Mayor Dickert won reelection, right?

Yes. And it was pretty much a landslide, wasn't it?

It was.

Was 73 to 27?

Yes. Dickert got 73 percent, Marcus got 27.

Yes. But your interest in the Bielefeldt lawsuit continued after the election, didn't it.

Yes. I was interested.

And you were no longer working for the CRG at

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Q Who gave it to you?

A I don't recall.

Q Did you get it from the radio station?

A No. Q Did you get it from Mr. Bielefeldt?

A I don't think so.

Q Who did you get it from?

A I don't remember.

Q Mr. Tousis obtain it?

A I don't remember.

(Exhibit No. 1737 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1737.

This is an e-mail dated February 25, 2011 from you to Mr. Block forwarding an audio clip of the WRJN interview with Mayor Dickert, correct?

A Yes. Q And the purpose of you giving this to him was so he could run a story, right?

A He asked me for it.

Q Why didn't he get it himself?

A I have no idea.

Q He would know how to do that, right?

A Yes. Q He worked for the Racine Journal Times, right?

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the time, were you.

A No. Q Nor did you have any involvement in assisting anyone associated with the Marcus campaign, right?

A Correct.

Q Because that was over.

A Correct.

Q I show you what we marked as Exhibit 1564 to Mr. Tousis's deposition.

A Yup. Q All right. Starts with an e-mail from you to Mr. Tousis dated June 4, 2011. This is months after the election, right?

A Correct.

Q And you're forwarding a site to CCAP, right?

A Yes. Q And that included the -- the answer that was filed in the lawsuit, right?

A Correct.

Q And then you say, "Is the affirmative defense May 31 that he was acting as mayor?" Right?

A Yes. Q So you're taking time out of your busy day to review pleadings in the Bielefeldt case and

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talking to Mr. Tousis about it, right?

A Yes. Q And then Tousis says that's the only thing that they got, right?

A Yes. Q And then you say, "Just talked to Boyd." Do you see that?

A Yes. Q What did you talk to Boyd about?

A Talked to him about the lawsuit.

Q Was Boyd Frederick assisting Mr. Bielefeldt in the lawsuit?

A No. Q What did -- what did you and Boyd talk about?

A We talked about the lawsuit.

Q What did you talk about about the lawsuit?

A I don't recall specifically, but we probably talked about what Dickert was telling people about the lawsuit.

Q You wanted to see Mr. Bielefeldt win, correct?

A Yes. I thought he got a raw deal.

Q And you wanted to see him win because it would cause harm to John Dickert, right?

A No. I thought -- I thought Bielefeldt got a raw deal.

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to the editor of the JT." That's Journal Times, right?

A Yes. Q Okay. Well, election's over. Ottelien has already funded the PAC. The PAC's no longer active. Why are you having this communication with Mike Ottelien?

A He asked me what he could do because he was unhappy with the way that the city and the taxpayers were paying for Dickert's lawsuit.

Q Did he pay you for this advice?

A No. Q You're taking time out of your day to come up with these ideas for him.

A It took all of three minutes.

Q Did you follow up with him?

A I don't believe I did, but I may have.

(Exhibit No. 1739 marked for identification.)

BY MR. COHEN: Q I show you what was marked as Exhibit 1739.

It's an e-mail from you to Mr. Ottelien dated June 8, 2011, correct?

A Correct.

Q And you say to him, "You need to get someone to subpoena Beth Pramme's private e-mails

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Q But you knew nothing really about the facts, did you?

A I knew what I read in the newspaper.

Q Do you believe everything you read in the newspaper?

A Sometimes.

(Exhibit No. 1738 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1738.

This is an e-mail from you to Mr. Ottelien dated June 7, 2011, correct?

A Yes. Q And you say, "Three things that need to be done by average citizens with the Dickert lawsuit.

One: People need to show up at the next council meeting and probably the one after that and express dismay that Dickert would try to use taxpayer dollars to cover his mistake, implore the council to stop him (judge already ruled that he was not on city time and it was a candidate interview/part of a three-part series). Two: Send e-mails and call city council members asking them (very politely, do not accuse) to stop Dickert from taking city money for personal use. Three: Write letters

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A Q A Q A

Q A Q A

regarding the WRJN interview. If she was involved at all in setting up the interview or communicating with the host Dickert could not have been operating under city time."

Do you see that?

Yes. Was Mr. Ottelien talking to Mr. Bielefeldt or Mr. Santarelli at this time?

I have no idea.

Why are you giving this information to him?

I believe he asked me a question about -- about whether Dickert was on city time or campaign time.

What's your interest at this time?

My interest is helping out a friend who's asking me a question.

Did he pay you?

No. MR. GERAGHTY: I don't think there's going to be a convenient time.

THE WITNESS: Can we -MR. GERAGHTY: He needs a bathroom break. I thought maybe we were going to move onto something. You know, if this is okay we'll just take a break.

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Q

A Q A Q

A

Q A Q

MR. COHEN: This is fine.

MR. GERAGHTY: Quickly.

(Short break was taken.)

BY MR. COHEN: Back on Exhibit 1739, Mr. Williams, you tell Mr. Ottelien that he needs to get someone to subpoena Beth Pramme's private e-mails regarding the WRJN interview. How is Mr. Ottelien involved in the lawsuit?

I don't think he is.

Well, how could he subpoena e-mails if he's not involved in the lawsuit?

I must have used the wrong word.

Were you suggesting to him that he advise Mr. Bielefeldt's lawyer to take this course of action?

I don't believe I was.

MR. SANDERS: What exhibit are you referring to, Mr. Cohen?

MR. GERAGHTY: 1739.

BY MR. COHEN: It's your testimony that you don't know who was behind the Bill Bielefeldt lawsuit?

Correct.

Sure about that?

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Q You just thought you would spend your free time giving advice to people who are unhappy about the city paying legal fees for the mayor's slander lawsuit.

A Yes. Q Did you have a meeting?

A I don't believe I did.

Q Were these the people that funded Mr. Bielefeldt's lawsuit?

A I have no idea.

Q Who were you referring to?

A The people in the e-mail.

Q George Myers?

A I believe so.

Q Mr. Tousis is on the e-mail too, isn't he?

A It looks like he is.

Q Do you know any of these other people?

A I know Penny Sharp.

Q We've talked about her, right?

A Right.

Q Eric Marcus is on the e-mail too, isn't he.

A Is he?

Q Yup, eric.marcus@werfdorf.com, right before George Myers on the fourth line, right by Tom Tousis.

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A Yes. (Exhibit No. 1740 marked for identification.)

BY MR. COHEN: Q Let me show you what's been marked as Exhibit 1740. This is an e-mail that originated with George Myers regarding a comment on the mayor's slander lawsuit costing the citizens $100,000, and it's forwarded to you by Mr. Tousis, right?

A Yes. Q And you respond to Mr. Tousis on May 26, 2012 and you say, "You need to set up a meeting with a couple of people who are the driving force behind this and myself. It needs to be outside of Racine."

Who are the people that are the driving force behind this?

A I believe I'm referencing the people who are unhappy with the legal fees being paid by the city.

Q And why did you want a meeting with them?

A I thought I could offer my advice.

Q For what purpose?

A I thought it would be helpful.

Q Did you want a job?

A No.

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A Q A Q

Oh, yes, he is.

So this is -I've actually.

Well a year after the election and Mr. Marcus is still involved with this subject matter, huh?

A I have no idea. I've never met Eric.

Q Did you encourage Mr. Block to write an article about the Bielefeldt lawsuit?

A I don't recall.

(Exhibit No. 1741 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1741.

This is an e-mail from you to Ken Brown at CRG, correct?

A Correct.

Q Dated June 22, 2011, correct?

A Correct.

Q And you're no longer working for CRG, correct?

A Correct.

Q It says, "Are you going to do a blog posting on Dickert using tax dollars to fund his personal lawsuit? I would take the strategy of encouraging people to call their aldermen and then list phone numbers and e-mails."

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A

Q A Q A Q A Q A Q

A Q A Q A Q

Why did you communicate this to Mr. Brown?

I know he was interested in the issue and so I was curious if he was going to write a blog posting.

Was a blog posted?

I don't remember.

Did you review it before it was posted?

I don't remember.

Did you have any further follow-up with him on this?

I don't remember.

You seem overly involved in this Bielefeldt lawsuit. Is there a reason?

I don't think I'm involved at all.

You're e-mailing a lot of different people about it and suggesting various courses of action. What's the purpose?

No idea.

Did you talk with your wife about the Bielefeldt lawsuit?

I'm sure I did.

It's a subject of conversation between the two of you, wasn't it?

I think we had a couple.

A couple.

Page 235 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

on the radio again?

I don't recall.

How did you learn that?

I don't recall.

What efforts did you make to get the tape?

I don't recall.

What efforts did you make to figure out whether that's a truthful statement?

A I don't recall.

Q Did you subsequently work up a script for people to complain about the city's use of fees to pay for the defense of the mayor in the slander lawsuit?

A I believe I was asked for some talking points, yes.

Q Who were you asked by?

A I don't recall.

Q You don't recall who asked you to do that.

A I don't remember if it was Ken Brown or Mike.

It was one of the two.

Q Were you paid?

A No. Q Just something you did on your spare time.

A Yes. (Exhibit No. 1749 marked for identification.)

A Q A Q A Q

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A Probably did.

(Exhibit No. 1745 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1745.

It's a series of e-mails between you and your wife, isn't it?

A Yes. Q And you start the conversation string here on June 24, 2011, you say, "Word is Dickert just slandered Bill on the radio again and your wife says someone needs to get that tape. That guy never learns. It needs to go to the judge on Monday. What is up with that guy?" And you say you're working on it, right?

A It does.

Q Why would you be working on it?

A I have no idea.

Q Did someone hire you to do this work?

A No. Q Just something you decided to do on your own spare time.

A Yes. Q Did you get the tape?

A I don't believe I did.

Q Who told you that the mayor had slandered Bill

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BY MR. COHEN: Q Show you what's been marked as Exhibit 1749.

That's an e-mail from you to Mr. Tousis dated July 18, 2011, correct?

A Yup. Q And the title of the attachment is "Dickertlawsuitrobocall.doc." Do you see that?

A Yup. Q And you say, "Attached script, still have not heard, but like I said, I have not talked to anyone who was on the list."

This is something you prepared, right?

A It is.

Q And you wanted to encourage people to get out and complain about the city's payment of Mayor Dickert's defense fees and the slander suit, right?

A Yes. Q And it says, "Paid for by working families for a better Racine." Do you see that?

A Yes. Q Who is that?

A I have no idea.

Q So you drafted a script, you put, "Paid for by working families for a better Racine," and you

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A Q A Q A

Q A Q A Q A Q

A Q A Q A

have no idea who that is.

I don't -- I don't recall.

Come on. Are you telling me the truth?

Yes. Why did you put that name down?

I don't recall. I don't know if it was a possible future independent expenditure. I have no idea.

Who asked you to prepare this script?

I don't recall.

Why did you send it to Tom Tousis?

I thought he would be interested.

You thought he would be interested. Why? I don't recall. We obviously had a conversation about it, but I don't recall.

You say you still have not heard, "But like I said, I have not talked to anyone who is on the list." What list are you referring to?

I don't recall.

And what haven't you heard?

I don't recall.

Was there a list of people who were going to hire you at the time?

I have no idea what this e-mail is referencing there.

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A I sent a couple e-mails.

Q A couple? All right. This is to Mr. Ottelien and Mr. Tousis, right?

A Yes. Q Need some help in the comments. "Monte and Mick are trying to draw me out. Attack the council on the previous ruling over and over again. Other people would pick up the mantel."

Is this some blog site or comments on a newspaper article?

A It must be comments on a newspaper article.

Q How was Monte -- Monte's referring to Monte Osterman, right?

A Yes. Q And Mick is Mick Wynhoff?

A Yes. Q How were they trying to draw you out?

A I don't recall.

Q Were you communicating on a blog or comments to an article that they were responding to?

A Or they were commenting on an article and thought I was commenting on it.

Q Well, do you know?

A I -- I don't recall.

Q Who should attack the council? Who were you

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Q Were you waiting to hear whether you were going to be hired?

A I don't recall.

Q Do you know anybody associated with the working families for a better Racine?

A I don't remember -- I have no idea who that is.

Q Was that another PAC? A I have no idea.

Q You typed this, didn't you?

A I did. I don't recall.

(Exhibit No. 1742 marked for identification.)

BY MR. COHEN: Q I'll show you what we've marked as Exhibit 1742. It's an e-mail from you to Mr. Tousis dated July 14, 2011. By the way, did you have a job at this time?

A Yes. Q What were you doing?

A I was working as a political consultant.

Q For who?

A For a variety of candidates.

Q But you had enough time in your day to be on an almost daily basis sending e-mails and other communications and drafts of things out regarding the mayor's slander lawsuit, right?

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referring to there?

A I have no idea.

Q When you say, "Other people pick up the mantel," what are you referring to?

A Other people probably would besides Tom and Mike.

Q Were they commenting on this?

A They may have been.

Q Was this a Journal Times article?

A I have no idea.

Q It says, "JT," on top, does it?

A Then it must have been a Journal Times article.

Q Were you using Johnny Uzick?

A Probably.

Q Do you use other names?

A No. Q Where does Johnny Uzick come from?

A It's just a made up name.

Q Did you suggest to Mr. Ottelien to file an open records request to get Mayor Dickert's, copies of Mayor Dickert's defense bills?

A Yes. Q Why did you do that?

A Because he asked me to.

Q But he wasn't paying you.

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A Q A Q A Q

No. Was anyone paying you?

For this?

Yes. No. Did anyone pay you anything for any of your advice or work associated with Bill Bielefeldt's lawsuit?

A No. (Exhibit No. 1743 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1743.

This is an e-mail from you to Mr. Ottelien dated July 11, 2011, correct?

A Yes. Q And you drafted an open records request to the city attorney's office for my firm's law -- law fees, law firm's fees for the defense of Mayor Dickert in the Bielefeldt case, right?

A Yes. Q And Mr. Ottelien asked you to do this?

A Yes. Q Why didn't he do it himself?

A Probably wasn't comfortable writing the open records request.

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question. Could you repeat it? I'm sorry.

BY MR. COHEN: Q You have no idea one way or the other whether or not Eric Marcus asked you to be involved in this issue.

A I don't recall if Eric Marcus ever asked me to do anything.

(Exhibit No. 1744 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1744.

Starts on the bottom with an e-mail from Beth David dated July 17, 2011 to Mr. Ottelien, right?

A Yes. Q And does that refresh your recollection that she's the person who runs the Racine Uncovered website?

A I've never met her. I don't know.

Q Okay. And Mr. Ottelien then forwards that e-mail to you, right?

A Yes. Q And he's looking for your opinion on the city's position on the open records request, right?

A Yes. Q All right. So does this refresh your

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Q Why didn't you do it yourself?

A I felt I didn't have standing. I'm not a taxpayer of Racine.

Q So why would you be upset about the city using taxpayer money to pay for the defense of the lawsuit if you weren't even a taxpayer?

A I didn't think it was right.

Q Do you know whether this was sent?

A I do not.

Q Did you ever look at any of the information that was obtained?

A I don't recall.

Q Do you remember talking to Beth David about the propriety of the city's position in response to this open records request?

A I don't recall.

Q Did you have any communications with Eric Marcus during this time period?

A No. Q Did he ask you to get involved?

A I have no idea.

Q You have no idea whether he did or didn't?

A I have no idea.

Q You have no idea whether Eric Marcus -MR. GERAGHTY: Listen to the

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A Q

Q A Q A Q A Q A Q

A

recollections that your request was made, right?

Which -- which -The open records request?

MR. GERAGHTY: Did you read -- have you read that -THE WITNESS: Yes. MR. GERAGHTY: -- e-mail?

THE WITNESS: Yes, yes.

MR. GERAGHTY: Okay.

BY MR. COHEN: And now you're asserting your opinion here on the propriety of the city's position, correct?

Yes. Is that based on legal theory?

No. Just my opinion.

Did you do any legal research?

Just my opinion.

Did Mr. Ottelien ask you to give your opinion?

He forwarded me an e-mail.

And you say, "It's inappropriate to claim privilege," and that Beth -- and that's Beth David, right, you're referring to? Last sentence.

Yes.

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Q So contrary to what you told me earlier you know who she is, right?

A He forwarded me an e-mail message from her that he sent -- about -- about an open records request that she sent to the city attorney and so I'm responding to that e-mail.

Q I get it. But your advice to him is that Beth should write a letter to that effect and CC the DA. A Yes. Q You're telling Mr. Ottelien that Ms. David should contact the district attorney about this, right?

A It was my opinion.

Q And you wanted to cause more harm to the mayor, didn't you.

A It's just a disruption. It's causing a disruption.

Q For what purpose, Mr. Williams? The election's over. You're mad at the mayor over the West Racine project and you're just trying any way you can to seek retribution; isn't that right?

A No. Q Did she contact the DA? A I have no idea.

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Do you remember being involved after these dates?

MR. GERAGHTY: Could you give us a date? Are you talking about 7 -- July of '11?

MR. COHEN: Yeah.

MR. GERAGHTY: Okay.

MR. COHEN: Right.

THE WITNESS: I don't recall.

(Exhibit No. 1746 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1746.

It's an e-mail dated July 21, 2011 from you to Mr. Ottelien, right?

A Yes. Q Now you're talking about me too, right?

A Yes. Q We had never met before this, right?

A No. Q And you're basically stating your opinions on legal issues again, aren't you.

A Yes. Q Why did you do this?

A Mike wasn't happy with the fact that the taxpayers were paying the -- John Dickert's legal fees and he wanted to know if there was

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Q Do you know if there would be any basis to do so?

A I have no idea.

Q Over a claim for privilege over an open records law? Why did you even suggest that?

A It was my opinion.

Q You thought that warranted criminal investigation?

A That was my opinion.

Q Based on what?

A That was my opinion.

Q I'm asking you, what was your opinion based on?

Why would it warrant criminal investigation by the district attorney's office over a claim of privilege in a lawsuit that you're not involved with?

A It's just my opinion.

Q Did you seek legal advice?

A No. Q Your involvement on this issue didn't end, did it.

A I don't recall.

Q Well, let me ask it a little different way.

We've seen six, seven, eight different ways that you're involved in the Bielefeldt lawsuit.

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Q A Q A Q A Q

A Q A Q A Q

A Q

any other possible course of action, and this was my suggestion.

And what did you attach?

I actually don't recall.

You didn't produce those letters, did you.

This was all in the stuff that you pulled out of my e-mail.

The attachments were?

All e-mails were.

So then you say, at least one of the attachments appears to be, "See attachment e-mail from Rob Weber regarding open records request." Do you see that, number 8?

Yes. Where did you get that?

I don't recall.

Was that from Mr. Ottelien?

Probably was.

And then you provide some legal advice on whether Dickert needed to have a notice of a claim against the city to file suit. What suit are you talking about?

I actually don't recall.

Then you give him the advice that he should tell Racine Uncovered not to engage Dickert's

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people on the JT. JT is Journal Times, right?

A Yes. Q What are you referring to there?

A Apparently Racine Uncovered should not engage the people in the comments in the articles.

Q Is that something you read?

A It may have been. I don't recall.

Q And who were Dickert's people who made comments?

A I don't recall.

Q Did you comment?

A I don't recall.

Q Did you use Johnny Uzick when you posted on the JT? A I did.

Q That was to hide your identity, wasn't it.

A Yes. Q And then you suggest that Racine Uncovered should do an open records request for any instance of the City of Racine stepping into a personal lawsuit involving one of their employees. Now you're giving advice to Racine Uncovered?

A I'm giving advice to Mike to pass onto her, yes.

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A Q A Q A Q A Q

A Q A Q A Q A

Q A

draft this?

Yes. Where did you get the legislative file number?

He provided it to me, probably.

Who's paying you for this work?

No one's paying me.

How much time did you spend on the Bielefeldt lawsuit?

I don't think I spent any time on the Bielefeldt lawsuit.

You didn't. We've looked at at least three or four open records letters. You didn't spend any time drafting those?

For taxpayers in the City of Racine.

Well, that's my question. Were you hired by someone?

No. You weren't a taxpayer.

Correct.

What are you doing the work for?

A friend asked me for help with open records requests on an issue that he was concerned about with the City of Racine.

Was the letter sent?

I -- I have no idea.

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Q A Q A Q

Did he?

I have no idea.

Did you ever talk to Beth David about it?

I've never talked to Beth David at all.

Did you suggest further courses of action to Mike Ottelien on these issues?

A I don't recall.

Q Did you draft another letter for him to send to the city?

A I don't recall.

(Exhibit No. 1747 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1747.

That's an e-mail dated August 23, 2011 from you to Mr. Ottelien with a draft letter to the clerk of courts, Janice Johnson-Martin, right?

A Yes. Q And that's to request access to and a copy of a signed letter that the Racine City Council voted to require John Dickert to sign, and then you've got a legislative file number relating to Bielefeldt v. Dickert. You're also asking for the date the letter was drafted and presented to John Dickert, as well as the date he signed it. Did Mr. Ottelien ask you to

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Q Wasn't this intended to draw more attention, negative attention towards Mayor Dickert?

A You have to ask Mike.

Q Well, that's the purpose, wasn't it?

A You would have to ask Mike.

Q You just blindly drafted the letter without any knowledge of what its intent was.

A He asked me for help drafting an open records request. I took a standard template that I have and I just plugged in the information.

Q Did you continue to communicate with Ken Brown and CRG about the Bielefeldt lawsuit?

A I probably did.

Q Why? A Because they were interested and I was interested.

(Exhibit No. 1748 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1748.

On the bottom is an e-mail from you to Mr. Brown dated December 21, 2011, correct?

The subject is "Root River"?

A Yes. Q That's the online publication we referred to earlier, right?

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A Correct.

Q And you say, "You need to let that woman know that as much as she wants to blame this on Marcus he's not the one who made Dickert say what he said. Who cares who convinced Bielefeldt to file the lawsuit. That does not change the fact that Dickert lied on the radio with the intent to cause malice."

You're offering some legal advice there too, aren't you?

A It's not legal conclusion.

Q The conclusion that Dickert lied on the radio with the intent to cause malice? Sounds pretty legal to me.

MR. SANDERS: Objection. Move to strike your opinion, Mr. Cohen.

BY MR. COHEN: Q And then Ken Brown says, "I agree. I'll make a comment today."

Is that a comment that he was going to make on the Root River online publication?

A That is what I take from his comment, yes, or from his e-mail, yes.

Q Is that the same woman that you referred to earlier as a cunt?

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A

Q A Q A Q

A Q A

on September 22, "She is seriously stupid.

Political and legal are two different things.

Whether you think Dickert will prevail in court is irrelevant to blaming Marcus for what Dickert said because he told Bielefeldt about the incident."

Why did you say this?

I don't recall, but I was offering advice to Kenosha on how to respond to her or to her blog posting.

(Attorney Juedes reenters proceedings.)

BY MR. COHEN: And that was just advice to another friend, right?

Yes. A common denominator seems to be John Dickert, though, right?

Sure.

Did there come a point in time where -- Strike that.

Did you and Mr. Tousis continue to talk about the Bielefeldt lawsuit?

Yes. Was he as interested in the matter as you?

Yes.

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A It is.

Q Did you ever tell your wife that that's what you called her?

MR. SANDERS: Objection, relevance.

THE WITNESS: I don't recall.

(John Dickert exits proceedings.)

(Attorney Juedes briefly exits proceedings.)

BY MR. COHEN: Q Did you continue to engage with Mr. Brown on this subject?

A I believe I did.

Q What do you remember?

A I don't remember anything.

Q Well, what were you just referring to?

A The fact that you're pulling out an e-mail.

(Exhibit No. 1750 marked for identification.)

BY MR. COHEN: Q I show you what we have marked as Exhibit 1750.

An e-mail to Ken Brown dated September 21, 2011, right, from you?

A Yes. Q You say, "You need to let that woman know that as much as she wants to blame this," we already talked about that one. All right.

And then he responded and then you answer

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(Exhibit No. 1751 marked for identification.)

BY MR. COHEN: Q I show you what we've marked as Exhibit 1751, e-mails between you and Mr. Tousis. He's forwarding to you, it looks like, an article from Journal Times titled "Alderman Marcus Subpoenaed as Witness in Suit Against Dickert," and you respond by e-mail dated September 21, 2011, "I bet Dickert had someone leak it to the paper." The fact that Marcus was involved, are you referring to?

A That he was subpoenaed.

Q You have no basis for that statement, do you?

A No. It was my opinion.

Q "It is all about trying to convince the public that Eric Marcus is behind it and unfortunately for him that is going to result in him losing his lawsuit." Do you see that?

A I do.

Q That was your opinion too, right?

A Yes, it was.

Q That didn't happen, did it.

A It was my understanding there was a settlement.

Q You don't know the terms, do you?

A I don't, actually.

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Q There come a point in time where you got involved with Mr. Ottelien in assisting him in filing a complaint with the GAB regarding Mayor Dickert?

A Yes. Q Tell me about that.

A He wanted my assistance in filing a complaint.

Q Did you draft it?

A I don't recall.

Q What was the basis of the complaint?

A I actually don't recall.

Q Did you get paid?

A No. Q What was the response from the GAB? A I think they were interested, but they felt that the DA would be a better avenue to take it.

Q Was that in a letter?

A I don't recall.

Q What's the basis of what you just told me?

A I'm trying to remember our conversation.

Q Was Beth David involved in that complaint?

A I don't recall.

Q Your involvement was simply because your friend asked you.

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Q Which one?

A I do know there was another complaint filed with the GAB. I don't remember who did it.

Q Did that involve an ethics complaint?

A No. Q Did it involve Mayor Dickert?

A Yes. Q What do you remember about that one?

A It was a campaign finance complaint that was filed.

Q Did you review what Ms. David submitted before she submitted it?

A I don't believe I did.

Q Were you invited to attend a fundraiser for Eric Marcus for mayor?

A I don't recall.

Q Did you receive a copy of an invitation from Mr. Tousis?

A I don't recall.

Q Did you attend any fundraisers?

A No. Q I show you what's been marked as Exhibit 1559 at Mr. Tousis's deposition. I'm taking you back to March of 2011. The campaign is still ongoing, right, with Eric Marcus and John

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A Yes. (Exhibit No. 1752 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1752.

It appears that Mr. Ottelien had forwarded to you an e-mail she had received -- he had received from Beth David regarding an ethics complaint she filed with the GAB regarding Mayor Dickert and the payment of his legal fees in the Bielefeldt action.

A Yes. Q And did you give Ms. -- did you give -- Strike that.

Did you give Mr. Ottelien some advice to pass onto Ms. David about that complaint?

A I don't recall.

Q Where did the information that you mentioned a few minutes ago that they thought that they were interested but they thought the DA would be a better -- better suited to address the issue, where did that information come from?

A I actually was a mistake. That's not -- it was not in relation to this complaint.

Q Is that in relation to some other complaint?

A Yes.

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Dickert?

A Yes. Q All right. And this is an e-mail from you to Mr. Tousis and you say, "Boyd called me last night." That's referring to Boyd Frederick, correct?

A Yes. Q And you say, "Dickert had 50 people at his event in Kenosha and there were some of the local heavy hitters there. Looks like Bozman was really pushing people to be there and G John and Barca did some work as well. Dickert was apparently very giddy all night and thinks he's going to beat Marcus three to one."

Do you see that?

A Yes. Q And then Mr. Tousis replies, "Fuck him and Bozeman," right?

A Correct.

Q And he's referring to Dickert, correct?

A Correct.

Q And you say, "I would like to," right?

A Yes. Q Again, shows your dislike and Mr. Tousis's dislike for John Dickert, right?

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A Correct.

Q Did you or Mr. Tousis engage Mick Wynhoff to post something on his Facebook site about the Bielefeldt lawsuit?

A No. Q Did you engage or did Mr. Tousis engage him to make negative comments about John Dickert on his Facebook site?

A I did not. I don't know if Tom did or not.

Q Have you seen such comments on Mick Wynhoff's Facebook site?

A No. Q I show you what's been marked previously as 1565 at Tom Tousis's deposition. It appears there's a Facebook site for Michael Wynhoff.

You know him as Mick, right?

A Yes. Q And then he's talking about something about you got this friend you've known for years, helped out in the past, loaned money to. I'll let you read that. And then you say to Mr. Tousis, "We are devious," -A Yes. Q -- up on top. What are you referring to?

A I don't know.

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A

He probably felt that I thought it would be interesting.

Q This is referring to the Bielefeldt suit, isn't it?

A It is.

Q Did Mr. Tousis ask or Mr. Frederick ask Mr. Wynhoff to make that post?

A I have no idea.

Q Did you ghost write a letter for Mr. Ottelien to submit an open records request regarding John Dickert's Campaign Finance Reports?

A Yes. Q Is that because he asked you to do so?

A Yes. (Exhibit No. 1753 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1753.

Is this a copy of your e-mail to him of March 29, 2011 with the draft open records law request to the city clerk for John Dickert's campaign finance reports?

A Yes. Q What was the purpose of this?

A Mike wanted to take a look at his campaign reports.

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Q A Q A Q A Q

A Q

A Q A Q

You have no idea?

I don't.

Was Mr. Wynhoff talking about John Dickert?

I don't know.

Well, what were you and Mr. Tousis being devious about?

I don't know. I don't remember the context for this.

Showing you what's been marked as Exhibit 1566 to Mr. Tousis's deposition, that's another e-mail from you to Mr. Tousis, this one dated August 4, 2011 regarding another posting on Mr. Wynhoff's Facebook site, right?

That's what it looks like.

And it says, "Is it slander to accuse someone of embezzlement when what they were really -what they really committed was fraud. I'm just asking not related to any current events or anything."

Why did you send this to Mr. Tousis?

I think because somebody sent it to me and I thought he might be interested.

Who sent it to you?

Boyd Frederick.

Do you know why?

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Q Did you suggest this course of action to him?

A I don't believe I did.

Q Were you doing this as part of your work for Eric Marcus's campaign?

A I was not working for Eric Marcus's campaign.

Q Were you doing this as part of your work for the CRG? A No. Q This was separate?

A You'd have to ask Mike what he wanted to do for them.

Q Well, I'm asking you. You drafted it. Was your purpose in drafting this for work for the CRG or because Mike, your friend, asked you to do it?

A Probably because Mike, my friend, asked me to do it.

Q Do you know who submitted this open records request?

A I do not.

Q Do you know -- Strike that.

Did you come to learn that Beth David's daughter submitted the open records request?

A I don't recall.

Q Do you know Mike -- excuse me -- Beth David's

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daughter?

A I do not.

(Exhibit No. 1754 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1754.

Beth David forwards to you -- I'm sorry -Mr. Ottelien forwards to you an e-mail from Beth David with the files that were obtained through the city clerk's office, right? You say, actually, "Nothing attached."

A Correct.

Q Did you understand this to be related to the open records request letter that you had drafted?

A I don't recall what it's about, but there's nothing in the e-mail -- I don't remember the e-mail and there's nothing in the e-mail that leads me to believe that's what it was.

Q Do you see -A It very well could be.

Q Do you know who Donna Deuster is?

A I have no idea.

Q Do you know if she was a clerk at the City of Racine?

A Her e-mail signature says, "Assistant clerk."

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Q A Q A Q A

Why didn't it succeed?

I don't recall.

Do you remember being contacted?

I may have been contacted.

Did you offer some advice?

I don't recall.

(A discussion held off the record.)

(Exhibit No. 1755 marked for identification.)

BY MR. COHEN: Q I show you what has been marked now as Exhibit 1755. It's a compilation exhibit. I want to start with the first page. That's an e-mail from you dated October 27, 2011 to info@recallmayordickert.org, right?

A Yes. Q Does this refresh your recollection as to your involvement in an effort to recall Mayor Dickert?

A It does.

Q And who are you communicating with?

A Whoever's running the webpage.

Q Not a good answer. Who are you communicating with?

A I don't know.

Q You don't know.

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Q And do you know who "awonakmccue" is?

A No. Q Do you know that name to be Beth David's daughter?

A No. Q Did you suggest to Mr. Ottelien that Ms. David should have her daughter submit the request?

A I don't recall.

Q Did you get involved in an effort to recall John Dickert?

A Yes. Q Who contacted you about that?

A Jim Spodick.

Q When did he contact you?

A Oh, wait. The recall of John Dickert?

Q Yes. A No, I don't believe I did.

Q You had no involvement?

A I -- I don't recall.

Q Are you aware of an effort to recall John Dickert?

A I think I remember.

Q What do you remember?

A I think there was an effort and it did not succeed.

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A No. Q You're offering advice to someone who you don't know.

A Apparently.

Q How did you get involved?

A This is the extent that I recall being involved.

Q Did someone ask you to get involved?

A No, I don't believe so.

Q So out of the blue you sent this e-mail suggesting how to set up a website, right?

A Well, apparently either someone sent me, someone sent me this website and I looked at it and then sent an e-mail to whatever the generic contact us e-mail is and made -- made some suggestions.

Q That's my question. How did you get involved?

Who sent you this information?

A I don't -- I don't recall.

Q Who asked you to do this?

A I don't recall.

Q Did Mr. Tousis?

A He -- he may have. I don't recall.

Q You make a recommendation here to set up a volunteer contact page to capture people's

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information, right?

A Yes. Q So that you can -- so that you can get volunteers to collect signatures, right?

A Yes. Q And then the next e-mail is an e-mail from you to Mr. Tousis on the same day with a bunch of data, right?

A Yes. Q And where did that data come from?

A Apparently I went to Who Is and found out who paid for the hosting or who registered the website and sent it to Tom Tousis.

Q Why? A I assume because Tom is the one who told me about the recallmayordickert.org.

Q Who's Corey Becker?

A I have no idea.

Q How did you get this information?

A I went to whois.org or whatever it is where you find out who the hosting provider is and I cut and paste what was there. It's what you do, how you find who has registered a webpage.

Q Who are you communicating with on this advice?

A Whoever -- whatever the standard comment or

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A Yes. Apparently I did.

Q Are the last three pages copies of, four pages, three pages copies of what the website looked like?

A I believe so.

Q Titles such as "He Approves the Process?"

"Dickert and the Unwinnable Racine."

"Dickert Leaves Residents in the Dark."

"Does Dickert Know Anything? Just Because He Says So Doesn't Make" -- who drafted these?

A I have no idea.

Q Did you participate?

A No. Q Was Mr. Spodick involved in this?

A I have no idea.

Q Did you do anything else for this recall effort?

A No, I don't think so.

Q Did you continue to discuss with Mr. Ottelien Mr. Bielefeldt's lawsuit?

A I don't recall.

(Exhibit No. 1756 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1756.

This is an e-mail from you to Mr. Ottelien on a

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Q A Q A Q

A

Q

contact us e-mail address that is on the -that is on the website.

Did Mr. Tousis ask you to get involved?

Not that I recall.

Did you do anything else for the recall effort?

I don't think I did.

So I'm a -- having a hard time understanding your testimony. As you sit here today out of the blue you just sent an e-mail with some advice on how to get organized for this recall effort to this e-mail address and followed up with Mr. Tousis on information about the website.

My testimony is, is I think that Tom Tousis found the website, e-mailed it to me and asked who it was and I went to the Who Is to find out who the -- who registered the website, copied and pasted it, sent it to Tom Tousis, which is why I assume he's the one who sent it to me, and then I went to the, you know, whatever the contact us or there's got to be some e-mail thing and clicked it and sent that e-mail with some suggestions on how to make their website a little better.

Did you look at their website?

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Sunday, January 29, 2012, right?

A Yes. Q And you say, "Can you pass this on? She needs to tie the street lights to the legal fees the city of paying for in John Dickert's lawsuit.

What the city has paid for his personal legal fees, which they are not supposed to pay for anyway, would keep the lights on. That is how you want to frame it. Dickert's lawsuit is causing the lights to be turned off."

You're asking Mr. Ottelien to pass this on to Beth David?

A I believe so.

Q "The lawsuit angle is the way to frame it."

Why are you doing this?

A I must have read an article that she wrote about this and I gave advice on how to frame the next article.

Q To make Mayor Dickert look bad, right?

A To show the consequences.

Q You wanted to make Mayor Dickert look bad, isn't that true, sir?

A Showing the consequences of paying his legal fees with tax dollars.

Q Well, at this time you were not a taxpayer,

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right?

A I am not.

Q Show you what was previously marked as Exhibit 1560 at Mr. Tousis's depositions. This is an e-mail from you to Mr. Tousis dated March 22, 2011, correct?

A Yes. Q And you're reminding Mr. Tousis to call JJ. That's the clerk of the circuit court, right, clerk of the city, right?

A Yes. Q And then you're telling him what he should say to her about preelection finance reports, right?

A Yes. Q Why were you giving him this advice?

A Because apparently he was going to talk to JJ. Q Did he tell you that?

A He must have.

Q Why was he gathering this information?

A I don't think he was the one who was gathering the information.

Q Well, it says, "Remember to call JJ. Here is what you need to tell her."

Did you draft this for Mr. Tousis to give

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A Yes. Q You say, "We want to do it prior to your meeting with Dickert." Who's we?

A I think he was making reference to him and myself.

Q What meeting with Dickert?

A Apparently he was sitting down with Dickert.

Q And you thought that that would give him some leverage in that discussion?

A I believe so.

Q So you're giving advice on how to leverage his position on his assessment in a meeting with Dickert.

A I believe so.

Q Is there anybody in this world that you hate more than John Dickert?

MR. SANDERS: Objection, argumentative.

MR. COHEN: It's not argumentative.

THE WITNESS: I have no idea. Could be.

BY MR. COHEN: Q Can you think of anyone that you dislike more than him?

A I probably could.

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A Q

A Q

A Q

A

Q

to someone else who was going to be calling her?

No. He -- he was the one who was going to talk to her.

Show you what was marked as Exhibit 1561 at Tom Tousis's deposition. I'm going to show you Exhibit 1652 as well, which is the article I think you're referring to. This is an e-mail dated March 30, 2011 from you to Mr. Tousis, correct?

Yes. And it has a link to this proof and hearsay article from the Journal Sentinal regarding a Supreme Court assessment challenge law unconstitutional. Do you see that?

Yes. And you're saying to Mr. Tousis, "Don't forget to challenge that today."

What are you -- what are you referring to?

Tom had been talking about challenging his assessment because the city assessor said in a city council meeting or a -- or one of the commission meetings that his gas station on Douglas Avenue was overassessed.

You were encouraging him to file a challenge?

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Q Can you name anybody?

A I probably could.

(Exhibit No. 1757 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1757.

This is an e-mail on Christmas, December 25, 2011, and it starts with Mr. Tousis sending you a reference to a Christmas card he got from John Dickert saying, "Merry Christmas," right?

A Yes. Q It says, "Ha-ha, Merry Christmas to you and the wife," and then you respond by saying, "Seriously, go fuck yourself. All I want for Christmas is John Dickert being someone's bitch in federal prison."

Isn't that what you said?

A It is.

Q All this dislike stems from the West Racine project?

A I have no idea. I don't know how to answer that.

Q Was there anything else that John Dickert did to you that would cause you to make such a statement?

A There very well could be.

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Q A Q A Q A

Q A Q A

Q

What did he do?

Put me in an uncomfortable position.

Because you didn't get the project through?

That's not what I'm referring to.

What was it?

Referring to the fact that he had me go pick up cash for his campaign and put me in an uncomfortable position.

You're basically suggesting that you want him to be sodomized in prison, right?

I am.

Your efforts in getting back at John Dickert didn't stop, did it?

I don't recall.

MR. GERAGHTY: Where -- can we just -- where did we leave off? Where are you in the world of -MR. COHEN: Oh, let's just say -MR. GERAGHTY: -- Dickert attacks?

MR. COHEN: -- Christmas.

MR. GERAGHTY: Of 2011. Okay. So we're at Christmas 2011.

BY MR. COHEN: You went to work for the Racine Equality Project, didn't you?

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A

Project, right?

I did not know that.

You know he's a plaintiff in this case?

I did know that.

Do you know Thomas Holmes is a member of the Racine Equality Project?

I did not know that.

Do you know who Ken Lumpkin is?

Yes. Who's he?

I think he's a newspaper reporter and I think he also used to be a county board supervisor.

You're aware that he's a member of the Racine Equality Project?

I was not.

How about Ken Yorgan, do you know who he is?

The name's familiar. I can't place who he is.

You've read some of his stuff, haven't you?

I may have. I don't know. I don't know who he is.

You've commented on some of these stuff, haven't you?

I may have.

How about Kate Remington, do you know her?

The name's familiar. I've never met her.

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A Yes. I did a little work for them.

Q And you were hired to file an ethics or to help on the filing of an ethics complaint against Mayor Dickert?

A No, I was not hired to do that.

Q Did you consult them regarding that?

A I may have given some advice.

Q That's not why you were hired?

A No. Q Why were you hired?

A The only work I did for them was a piece they did in one of the aldermanic recalls.

Q Against Jim Kaplan.

A I believe so.

Q You've also given them advice about John Dickert, though, haven't you.

A Yes. Q Was that part of the scope of your work?

A No. Q And who's the Racine Equality Project?

A Jim Spodick is the only one I know.

Q Do you know -- you said you knew who Keith Fair is, right?

A Yes, I know who he is.

Q You knew he was a member of the Racine Equality

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Q Ken Brown, was he a member?

A I don't know if he was or not. He may have been.

Q Were you asked some advice on strategies about an ethics complaint that was filed against Mayor Dickert with the city?

A I don't recall.

Q You're aware of the fact that Jim Spodick was Thomas Holmes' landlord?

A I was not, actually.

Q Didn't know that?

A No. Q That's news to you?

A Yes. Q Show you what was previously marked as Exhibit 1567 at Mr. Tousis's deposition. It's kind of a complicated e-mail. We'll start with, do you see there's, about halfway down the page it says on 4/29/2013 7:48 p.m. Communicator Racine wrote, that's to you, right?

A I believe so.

Q And that's from Mr. Spodick?

A Yes. Q He is Communicator Racine?

A Yes.

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Q And he says, "This letter was given to Mary Wyant, W-Y-A-N-T, chairman on Saturday. The ethics committee met today and dismissed ethics complaints on all individuals. It was a setup, one of the worst displays in government I've ever seen. We did tape the meeting which will be valuable in the future. Doug did not recuse himself, almost acting as 'how dare anyone question me.' Keith Fair is in contact with the GAB. We want to move forward. Jim." Jim's Jim Spodick, right?

A Yes. Q This told you that Keith Fair was involved, right?

A Yes. Q All right. Doug is Doug Nicholson, right?

A Yes. Q And he didn't recuse himself, right?

A That's what the e-mail says.

Q And the letter is from Doc Yorgan, right?

A Yes. Q Person I just mentioned to you? And the -- if you look at the second page of the letter the paragraph beginning, "Unfortunately," the last sentence says, "Allegations have been brought

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Q "Plus Doug not recusing himself helps you in the next step."

What's the next step?

A I believe filing the complaint with the GAB. Q "First, it taints him and Dickert with illegal activity. Second, it shows that it was rigged game from the beginning and the process was illegal."

Did you get legal advice on this?

A I did not.

Q You come to a lot of legal conclusions, don't you.

A It's my opinion.

Q They have never -- never have had any chance of looking at the allegations and just went through the motions. You had no basis for that, did you.

A It was based on comments that Jim Spodick told me about the meeting.

Q You have no idea what the ethics committee looked at or didn't look at.

A Correct.

Q And then you pass this onto Mr. Tousis.

A I did.

Q Why?

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A Q A Q A Q

A

Q

A

to our attention by a very credible source that someone on the committee made some substantial illegal contributions to Mayor Dickert's campaign on three separate occasions."

Do you see that?

Yes. That's information you provided Mr. Spodick, right?

Yes. And you then say, "Don't send the letter," right?

I did.

You say, "They already made their decision and now they are irrelevant, tipping Dickert off, which is what her first phone call is going to be, will give them time to form a story."

What did you mean by that?

Tipping Dickert off to the fact that Ken Yorgan knew about the illegal contributions that Doug Nicholson made to Dickert's campaign.

And then you say, "That does not mean you do not use it. Move forward with the GAB." So you're making -- you're giving advice to Mr. Spodick, right?

Yes.

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A Because I thought he would be interested.

Q You thought he would be interested because he equally disliked Mayor Dickert, right?

A He also disliked Mayor Dickert, yes.

Do you mind if we take like a two minute bathroom break?

Q Sure.

(Short break was taken.)

(Exhibit No. 1758 marked for identification.)

BY MR. COHEN: Q I'm going to show you what we've marked as Exhibit 1758. Mr. Williams, this is a series of e-mails between you and Mr. Spodick, correct?

A Yes. Q And the subject is John Schubert?

A Yes. Q And who is John Schubert?

A John Schubert is -- John Schubert is a man who John Dickert was, I don't know the good way to put it, but was the -- he's not competent, I guess, to, you know, live on his own, control his own finances, and after his father died I think John was close to his father and was named the one who controls his finances.

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Q Guardian.

A Thank you.

Q And Mr. Spodick sends you an article about abuse, fraud, and waste, misuse of benefits by representative payee? Do you see that?

A Yes. Q And then he says, "Thought this may be of interest on the John Schubert donation," right?

A Yes. Q He's referring to John Schubert's donation to John Dickert's campaign.

A Yes. Q And you say, "Yes. File it. At the very least they will investigate it. Remember, it's -- it is about creating a shit storm." Right?

A Yes. Q And by that you meant it's all about creating negative attention toward John Dickert, correct?

A Yes. Q And then to his credit Mr. Spodick says, "Do you know for a fact John Schubert's incompetent to handle his finances and that John Dickert is the payee? How would I get more information?"

You say, "Court documents," right?

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Q And did the walk card or mail piece take issue with Mr. Kaplan's vote on the payment of Mayor Dickert's defense costs in the Bielefeldt lawsuit?

A I believe it did.

Q That's something you drafted, right?

A Yes. Q I'm going to show you what's been marked as Exhibit 1568 to Mr. Tousis's deposition. This is an e-mail from you to Mr. Tousis, copy Matt Pidgeon, right?

A Yes. Q Your partner at the time?

A Yes. Q June 10, 2013. You say you have your designer in tomorrow. That's for the walk card or mail piece?

A Yes. Q "So I need your stuff in the morning."

Whose stuff, Mr. Tousis's?

A I believe so.

Q He's gathering information for you for the attack piece on Jim Kaplan, right?

A He must have. I don't recall what that was.

Q Where was he getting the information from?

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A Correct.

Q So basically you were communicating to Mr. Spodick it didn't matter what the real facts were, it was all about creating negative publicity for John Dickert, right?

A No, that's not what I said.

Q Well, the idea was to create negative publicity about him, right, that's the shit storm you're referring to.

A Yes. Q And draw attention to him, right?

A Yes. Q And that was the objective, right?

A Yes. Q What services did you provide to the Racine Equality Project regarding the recall of Jim Kaplan?

A I put together a, either walk card or mail piece. I can't remember exactly what it was.

Q When did that effort start?

A I actually don't recall.

Q I'm sorry, a walk card or what?

A Or a mail piece. They would have been similar, but one obviously goes in the mail and the other one does not.

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A I don't recall.

Q Says nothing about the car ride yet. What's that referring to?

A I believe, you know, I don't -- I don't recall.

I believe it was personal with Tom. Q Then you say, "The Racine boys are going to play by our timetable." Who are you referring to?

A The equality project.

Q All right. What was your timetable?

A It was about designing the timetable for designing the piece. They had certain -- that they had to get us certain information by a certain amount of time and approval.

Q And why was timing important?

A Because if they wanted to use it during the election they couldn't sit on it.

Q And you say, "They understand why." Is that what you're referring to -A Yes. Q -- just what you told me? "And are pulling a couple things back." What does that mean?

A I actually don't know.

Q Does this refresh your recollection of when you started work on the project?

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A It does.

Q Is it roughly that timetable?

A It was.

Q Did you have a contract with them?

A No. Q Did they pay you?

A Yes. Q How much did you charge them?

A I believe it was $100 just to design it.

Q That's all you charged?

A For this, yes.

(Exhibit No. 1759 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1759.

This is an e-mail from you to Mr. Tousis dated June 14, 2013, right?

A Yes. Q And you say you never got the stuff you or your guy were going to send over on Monday. That's the stuff on the attack piece on Jim Kaplan, right?

A Actually, I think I know what this is about. I believe I know what that's about.

Q Okay.

A Tom had talked to me about putting together a

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particular, right?

A Yes, yes, I believe so. He's the only one I had contact with.

Q And you shared that view with Mr. Tousis, right?

A Yes. Q And you didn't actually even understand what the real criticisms of Jim Kaplan were, right?

A Correct.

(Exhibit No. 1760 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1760.

These are e-mails between you and Mr. Spodick, June 17, 2013, regarding a draft of the walk piece that you were preparing on the attack on Jim Kaplan, right?

A Yes. Q And the title is "Kaplan's Vote to Pay Mayor's Legal Fees," right?

A Yes. Q And Mr. Spodick obtained for you some information from the common council minutes about the vote on the common council's vote on paying for Mayor Dickert's defense costs in the Bielefeldt lawsuit, right?

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Q A Q

A

Q A Q

A Q A Q

website for his air freshener business that I actually ended up not doing.

Okay. Second paragraph is about the Kaplan attack piece, though, right?

Correct.

And you say you're not sure they have their full act together yet, "But I'm going to be able to figure it out by helping them on this piece." What did you mean by that?

Exactly what I said there. I didn't necessarily think that they fully, they fully had their act together. They weren't organized and was not necessarily something that was going to be successful.

Did you think that they weren't always grounded -I didn't catch that. I'm sorry?

I'll say it again. Did you think that they were, the Racine Equality Project guys were not always grounded in reality?

Yes. And what did you mean by that?

I thought that they were a little -- I thought that they focused on petty little rumors and...

And you're referring to Mr. Spodick in

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A Yes. Q Did you interview Mike -- do you know who Mike Shields is?

A I do.

Q Have you ever talked to him?

A Several times.

Q Did you talk to him about this?

A I don't know if I did or not, to be honest. I may have.

Q Do you know whether or not he shares your dislike for Mayor Dickert?

A He does.

Q He's told you that, right?

A Yes. Q And on what other occasions did you speak with him?

A Could you repeat the question?

Q What other -- what other times or events would you have talked to Mike Shields?

A I've talked to Mike a couple times.

Q About what?

A About -- about Dickert, about the City of Racine, about the NAACP down there. I talked to him about one of my clients.

Q What did you talk to him about Dickert about?

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A Q A Q A Q A Q A Q A Q A Q

A Q A Q A

Just his interactions with him being on the council.

What was the purpose of asking him that?

Just making conversation. Wasn't necessarily anything in particular.

It didn't have anything to do with any of these items that -No. -- we've talked about?

No, I don't think so.

Was there a petition filed for recall of Jim Kaplan?

I believe there was.

Were you involved in that petition?

No. Did you help draft it?

I don't believe so.

Are you familiar with the fact that it alleged that Alderman Kaplan engaged in discriminatory practices in his official capacity as alderman?

I was not aware of that.

Do you know any facts to support that?

No. I was not aware of it.

Do you know who prepared the petition?

I do not.

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A Yes. (Exhibit No. 1761 marked for identification.)

BY MR. COHEN: Q I'll show you what's been marked as Exhibit 1761. It's an e-mail -- e-mails between you and Mr. Spodick, correct?

A Yes. Q Dated July 13, 2013.

A Yes. Q And you give him some advice that you guys need to pull, put up on that website some sort of way for people to contact you guys. Does that refresh your recollection that there was a website on attacking Jim Kaplan?

A I believe so.

Q You're giving advice with respect to that, right?

A I am, but I did not do the website.

Q Treasurer is Kate Remington for the Racine Equality Project. Do you see that?

A Yes. This is a -- he was providing the information I needed for the walk card.

(Exhibit No. 1762 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1762.

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Q Do you know -- Strike that.

Do you know if Mr. Spodick prepared it?

A I do not know if he did.

Q Was there a website that you assisted on with respect to the attack on Jim Kaplan?

A There may have been. I don't recall.

Q Were you relying on Mr. Spodick entirely for the information on the attack piece on Jim Kaplan?

A Yes. Q What did you do to check the facts?

A In this case I, you know, when he sent this to me I glanced at it to make sure that it -that -- that it met -- that it said what he said it did.

Q Isn't it fair to say, Mr. Williams, that you accepted as truth the information that Jim Spodick provided you about Alderman Kaplan and didn't do anything else outside of what he gave you to check to see if it was true?

A I would say that I did not -- I would not say that I did nothing, but I did not do a full analysis of what he sent me.

Q And you realize that what you helped prepare was published to the public, right?

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A Q A Q A Q A Q A Q A Q A Q A Q A Q A

This is an e-mail from you to Mr. Spodick with a copy of the final walk card on the attack piece on Jim Kaplan, right?

Yes. And you say, "Don't forget to send me the stuff for Q.A." Do you see that?

I do.

And that's referring to Q.A. Shakoor?

It is.

And he's an alderman for the city, right?

Yes. Was he next on the hit list for Racine Equality Project?

He's someone that they had mentioned that they may be going after.

And what were they going to go after him about?

I actually don't recall.

Did you ever get the information?

I don't recall.

Did you do anything?

I don't -- no, I didn't.

Why were they going to go after him?

I don't recall.

He's African-American, isn't he?

He is.

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Q You've met him before?

A I don't know if I have. I've been in the same room as him, though.

Q Did you tell Mr. Spodick that you'd be willing to help in an attack on Q.A. Shakoor?

A Yes. Q Just another job for you, right?

A Yes. Q You were involved also in assisting in Janice Hand's campaign against John Dickert for mayor in 2015, right?

A I was.

Q And were you asked to be involved by Scott and Penny Sharp?

A I was asked by Penny Sharp, yes.

Q And was she campaign manager for that campaign?

A I don't know if necessarily she was the campaign manager, but she certainly was someone who would maybe fit that role. She did not -she didn't have anyone else who would fit into that role.

Q Even before being retained by -- were you retained by Janice Hand or by Penny Sharp?

A By Janice Hand.

Q Before being retained by Janice Hand you also

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against the mayor?

A No, I don't believe I was.

Q Who's Sam Whalen?

A Sam Whalen is, I believe, the former police chief's son.

Q Did you communicate with him about looking for candidates to run for mayor?

A He was hired by someone that I sat down with who was thinking of running for mayor.

Q Who was that?

A I can't remember the gentleman's name. I sat down with him and his wife. Tom connected us.

He was an attorney. I think he had been a former assistant district attorney for Racine County. I -Q How did -- I'm sorry.

A But I -- I don't recall his name.

Q How did Tousis find out that this individual may be interested?

A I don't know if he contacted Tom or if someone contacted Tom about him. The gentleman is a Republican and so it may have been in that context.

Q Was the individual who was friends with Sam Whalen named Chris?

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A Q A Q A Q A Q A Q A Q A Q A Q A Q

had communications about looking for candidates to run against Mayor Dickert.

Yes. Who did you talk with?

Tom Tousis.

Who else?

I don't recall.

Did Mr. Tousis put you in touch with anybody?

I don't recall if he did or not.

And did he have some ideas on who may run against the mayor?

He may have mentioned the police chief at some point.

Art Howell?

I believe so.

Did he talk to Art Howell about running for mayor?

Or -- I don't think so. I think he had heard a rumor.

You heard a rumor or is that something Mr. Tousis told you?

No, I think he heard a rumor is what I said.

Did you follow up with Art Howell?

No. I never contacted him.

Were you actively looking for candidates to run

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A I'll be honest, I do not recall.

(Exhibit No. 1763 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1763.

Are these a series of e-mails between you and Sam Whalen about finding a potential candidate to run against Mayor Dickert?

A Yes, it is.

Q All right. And Whalen says to you he can't find any candidate. "Deal won't listen." Do you know who Deal is?

A I believe he was one of the candidates for mayor.

Q And then he actually did run, though, didn't he?

A I believe he did.

Q And they he says, "The worst part is that Dickert has been very beatable, and if there was a half decent candidate we -- we could win." Do you see, "We"?

A Yes. Q And then you respond by saying, "If you have any other nonpartisan races I would enjoy working with you. Keep plugging along. We both know eventually he's going to be out.

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A Q

A Q A Q A

Whether that is from an election or federal prison remains to be seen."

That's a statement that you made to Sam Whalen about John Dickert, correct?

Yes. Did you have any concern when you made this statement that it could result in a slander lawsuit against you?

No. Did you get a response from Mr. Whalen?

I don't know if I did or not.

Did Mr. Tousis support Janice Hand?

He did not.

MR. GERAGHTY: I just wanted to know on that 1763, like the last few pages you couldn't possibly read, but I think Mr. Cohen only looked at page 1?

MR. COHEN: I did. I mean, I have other e-mails.

MR. GERAGHTY: Just don't want to waste time. The other ones you can't read because they're -MR. SANDERS: They're like this.

MR. COHEN: Yeah. Actually, here, give me that other -- let's put it in the

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Q "I understand that you met with my good friend Chris Simonds"?

A Yes, yes. So that is who we were referring to, met with him and his wife, several months before that e-mail, I believe.

Q And it's your testimony that Mr. Tousis did not contribute to Janice Hand's campaign?

A Not to my knowledge. That's what Tom -- Tom told me he did not.

Q Did you tell Janice that Tom was going to come up with a list of people who would contribute to her campaign?

A Yes. (Exhibit No. 1765 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1765, an e-mail from Penny Sharp dated December 7, 2014 inviting people to attend the first, to discuss the campaign of Janice Hand for mayor, right?

A Yes. Q Mr. Tousis on this list?

A He is.

Q Mr. Spodick's on the list?

A He is.

Q Beth David's on the list?

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record.

MR. JUEDES: We just printed it out however it was.

MR. GERAGHTY: It's not a problem.

I'm not objecting to anything. I'm just saying you only referred to page 1 and that's fine and that's all readable, okay, it's just the rest of it sort of isn't, so...

(Exhibit No. 1764 marked for identification.)

BY MR. COHEN: Q I'm going to show you what's been marked as 1764. Does that contain more readable copies, at least on the backside, of some of your e-mails?

A It does.

Q Okay. Chris Simonds, is that the individual that Sam Whalen was friends with?

S-I-M-O-N-D-S? A Let me double check.

Q If you look, let me help you.

A Yeah.

Q The third from last page, 543 is the Bates number, the bottom it says, "Zak, you're doing well -- hope you're doing well." Sorry.

A Yes.

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Q A

She is.

Michael Shields is on the list?

He is.

Ken Brown's on the list?

He is.

Ken Lumpkin's on the list?

He is.

George Meyer's on the list?

MR. GERAGHTY: He is.

THE WITNESS: Where?

MR. GERAGHTY: Over here.

THE WITNESS: Oh, yes.

BY MR. COHEN: Bill Bielefeldt's on the list?

He is.

And you're on the list, right?

Yes. And you knew these to be all supporters of Janice Hand?

No. I think that they are people that Penny Sharp wanted to get involved in Janice's campaign. It was an e-mail out of the blue.

Certainly.

How did she come up with the list?

I have no idea. You'd have to ask her.

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Q So it's your testimony that Mr. Tousis had not committed to putting a list of potential donors together for her?

A No. My testimony is he told me he would do it and then he did not.

Q I see. Show you what was previously marked as Exhibit 1572 to Mr. Tousis's deposition, a series of e-mails between you and Janice Hand about her election campaign, correct?

A Yes. Q And it says, "Great, glad to be on board."

Would that reference the date that you start working for her?

A Yes. Q All right.

A It was on or about that day, yes.

Q Fair enough. And in the second paragraph there you say you did already reach out to Tom Tousis last night and he is putting a list together of potential business people who are unhappy with Dickert and should want to give, right?

A Yes. Q And what role did you serve for her?

A I was a campaign consultant.

Q And was fund-raising one of your

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A Q

A Q

A Q A Q

A Q A Q

This is e-mails dated December 9, 2014 by and between you and Penny Sharp, right?

Yes. And in the bottom e-mail which is yours to her you talk about great seeing her and Scott.

Scott's her husband, Scott Sharp, right?

Yes. And the third paragraph you say, "I want to help out, but she needs to pull the trigger.

Dickert is vulnerable and I think that Janice is the best opportunity we have to take him out," right?

Yes. And there's some issue about your fees and who's going to pay for them, right?

I don't necessarily who's going to pay for them.

Well, if you look above there there's an e-mail back and she says she may have to go and talk to Janice's siblings to see if they would pay for it? Do you see that?

I do.

Who actually did pay you?

Janice did.

And then the last sentence in the last

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responsibilities?

No. Who handled that?

I believe she did it herself.

How much did you charge her campaign?

I actually don't recall. It wasn't a lot. I believe that I charged her -- I know I charged her a consulting fee up front, may have charged one other one, and then I charged her for the direct mail that I did and the walk card.

Q Why didn't Mr. Tousis contribute to her campaign?

A Could you repeat the question?

Q Why didn't Mr. Tousis contribute to her campaign?

A You'd have to ask Tom that.

Q You wanted to take Mayor Dickert out, didn't you.

A I wanted to beat him in election, yes.

Q Did you express to other people that you wanted to take him out?

A I may have.

(Exhibit No. 1766 marked for identification.)

BY MR. COHEN: Q Show you what's been marked as Exhibit 1766.

A Q A Q A

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A Q A Q A Q A Q A Q

A Q A

paragraph of her e-mail back to you says, "Thank you again. I can see the moment John finds out you are involved his face will be gray and he will plop down in his chair and realize his days are numbered." Did you agree with that sentiment?

I don't know if I do or not.

Penny Sharp didn't fare so well, did she.

Did you mean Penny Sharp?

I'm sorry, getting tired. Janice Hand did not fare so well, did she.

Correct.

In fact, she didn't make it out of the primary, did she.

Correct.

Do you remember what the percentage vote she got was?

I don't.

After she lost the primary did you get involved in helping any other candidates against Mayor Dickert?

I did not.

Who's McRenolds?

I don't know. Is it the county exec or the former county exec? I don't know.

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Q Who's Ladwig?

A I believe Ladwig's the current county exec of Racine? Is that -- I honestly don't know. I can't remember.

(Exhibit No. 1767 marked for identification.)

BY MR. COHEN: Q I show you what's been marked as Exhibit 1767.

That's an e-mail from you to Mr. Tousis dated March 1, 2011, right?

A Yes. Q And you say, "Did you make sure that McRenolds and Ladwig relayed to Dickert that no one, Monte and Mick specifically, should know about the conversation or the bullets are put back in the chamber." Do you see that?

A Yes. Q McRenolds is the former county exec for Racine?

A Yes. Q And Ladwig is the current one?

A Correct.

Q And Monte is Monte Osterman?

A Yes. Q Mick is Mick Wynhoff?

A Yes. Q What is the conversation you're referring to?

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this lawsuit was filed, right?

A Yes, we did.

Q In fact, you knew it was going to be filed before it was actually even filed, didn't you.

A I don't recall.

Q The two of you talked about that, right?

A I don't recall.

Q How did you find out the lawsuit was going to be filed?

A I don't recall.

Q Did Mr. Tousis have conversations with Mr. Sanders' office about it?

A I believe he had a conversation with Mr. Sanders. I don't know what the conversation was about.

Q Did any of the plaintiffs tell you that they were going to file a lawsuit before it was filed?

A I've never met any of the plaintiffs.

Q After the lawsuit was filed you gathered a bunch of articles and media pieces about the lawsuit and forwarded them to Tom Tousis, right?

A Yes. Q I show you what's been marked as Exhibit 1571

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A I have no idea.

Q What's the reference to the bullets are put back in the chamber?

A I have no idea.

Q Why did you want Mr. Tousis to have this communication with McRenolds and Ladwig?

A I have no idea. I don't know what this e-mail is about.

Q Is this some sort of a threat?

A No, I don't think so.

Q You have no idea what this means?

A No. It's a metaphor for something, but I don't know what it's a metaphor for. I don't recall.

Q Why -- why are you instructing Tousis to have this conversation with the county former and I don't know, the election would have been in probably about that time period, right?

A I think so.

Q Is that when Ladwig became county exec?

A I believe so.

Q Were you consulting with either one of them?

A No. Q You have no idea what this is about?

A I honestly have no idea.

Q You and Mr. Tousis shared some e-mails when

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A Q A Q A Q A Q

A Q

to Mr. Tousis's deposition. You were searching the Internet for any articles about the lawsuit, right?

I believe so.

And then there's a second e-mail where you added CBS and Fox references, 620 AM, right?

Yes. And the last page of the exhibit, it's a composite exit, is an e-mail that Mr. Tousis forwarded to you of an e-mail that he had received on the lawsuit from the tavern league about the dismissal of the complaint, right?

Yes. At the time Mr. Tousis was a member of the tavern league?

Yes. I believe so.

Why did he share this with you?

He thought I would be interested.

Did you talk about it?

That in particular we may have.

In fact, you made several comments online on the Journal Times using Johnny Uzick about the effect of the judge's decision, right?

I may have.

How much time did it take you to gather all

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these news articles?

A I don't know. Five minutes.

(Exhibit No. 1768 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1768.

This is an e-mail between you and centurion8551. Who's that?

A That is Santo Galati.

Q And are you forwarding to him some e-mails you received?

A Text messages.

Q Do you know the date that the lawsuit was filed?

A I do not.

Q Did Santo tell you when it was going to be filed before it was filed?

A No. Q Are these e-mails you received?

A They're not e-mails. They're text messages.

Q I'm sorry, text messages. Are they text messages that you received?

A Yes. Q So Ken Brown sent you a text message that said, "I'm sure you are abreast of the lawsuit. I found the Dickert donors and loaners the most

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Exhibit 1769. These are e-mails between you and Mr. Galati, correct?

Yes. February 12, 2014?

Yes. And you're giving Mr. Galati some information, aren't you, here?

I am.

"This is the guy"? And that guy was Caleb Robinson, right?

I believe so.

And he was looking for some information for the lawsuit, right?

Yes. And you gave him the website, right?

I did.

And then you say, "Any update on time frame," right?

I did.

And what you're asking about is any update on the time frame for filing the lawsuit.

Yes. That's before it was filed, right?

Correct.

Did there come a time where you and your wife

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potentially damaging. Hmm." And then he says, "Not from Mick and I haven't even asked him yet." Do you know what that's referring to?

A No. Q Did you ask him how he found out about it?

A I may have.

Q And then the response, is that your response?

A It may have been.

Q "Mick won't let you tell me"? What does that refer to?

A It was probably a reference to the earlier text message.

Q "Haven't heard anything. What have you heard?

I'm hearing rumors of big news in Racine. Any insight you can."

How would you know -- how would you have known about the filing of this lawsuit before it occurred?

A I -- I don't think I did.

Q Did Ken Brown ask you what -- whether you used Johnny Uzick as your handle?

A He may have. I don't recall.

(Exhibit No. 1769 marked for identification.)

BY MR. COHEN: Q I'm going to show you what's been marked as

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talked about the AG, Attorney General, taking action against Mayor Dickert?

A I don't recall.

Q Did someone tell you that happened?

A I don't recall.

Q Do you recall her telling you that?

A I don't recall.

Q Do you know anything about that at all?

A I don't recall.

Q Do you know whether that's true?

A I don't recall.

(Exhibit No. 1770 marked for identification.)

BY MR. COHEN: Q Show you what we've marked as Exhibit 1770.

It's a series of Journal Times articles. We'll just go through those. This is you, right, on the first page, Johnny Uzick?

A Yes. Q And these are all comments you're making about John Dickert and the lawsuit, right?

A I don't know what they're in reference to. Do you have the article it was attached to?

Q Not this particular one.

A Okay.

Q Generally speaking --

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A They could be.

Q -- that you would enter comments about these articles? Were they disparaging of John Dickert?

A They were.

Q That was your practice, right?

A Yes. Q You would often write -- write comments about payoffs to Mayor Dickert's friends, right?

A Yes. Q And you made disparaging comments about Monte -A Yes. Q -- Osterman?

A Yes. Q And about his cronies getting deals?

A Yes. Q And your purpose in writing these comments was to create negative information about the mayor, right?

A Yes. Q And I don't want to go through each one of these, but every time there would be an entry for Johnny Uzick it would be you, correct?

A I would assume so.

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STATE OF WISCONSIN ) ) ss.

COUNTY OF MILWAUKEE ) I, ANNICK M. JAQUET, RMR, CRR, Notary Public in and for the State of Wisconsin, do hereby certify that the preceding deposition was recorded by me and reduced to writing under my personal direction.

I further certify that said deposition was taken at KOHLER & HART, S.C., Milwaukee, Wisconsin, on the 2nd day of September, 2015, commencing at 9:07 a.m. and concluding at 4:31 p.m.

I further certify that I am not a relative or employee or attorney or counsel of any of the parties, nor a relative or employee of such attorney or counsel, or financially interested directly or indirectly in this action.

In witness whereof, I have hereunto set my hand at Milwaukee, Wisconsin, this 22nd day of September, 2015. <%Signature%> ANNICK M. JAQUET, RMR, CRR Notary Public in and for the State of Wisconsin My commission expires September 29, 2017.

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Q No one else knew that you were using it and used it with your permission, correct?

A No. Tom knew that it was me, but no one had -I don't believe anybody used it.

Q I'm looking at one right here, it says, "Dickert has been able to siphon off city money to his friends and cronies for payoffs."

That's the type of comments you made, right?

A That is a comment I made.

Q Since 2010 all your involvement and your discussions about John Dickert and the actions you took did you ever once think that maybe what you were doing was crossing the line legally?

A No. Q Why don't we take a break. I think I'm just about done.

(Short break was taken.)

MR. COHEN: That's all the questions I have at this time.

MR. SANDERS: I have nothing further.

(Proceedings concluded at 4:31 p.m.)

Veritext Legal Solutions 1 North Franklin Street - Suite 3000 Chicago, Illinois 60606 Phone: 312-442-9087 September 22nd, 2015 To: David P. Geraghty Case Name: Holmes, Thomas J., et al. v. Dickert, John, et al.

Veritext Reference Number: 2074644 Witness: William Zach Williams Deposition Date: 9/2/2015 Dear Sir/Madam: The deposition transcript taken in the above-referenced matter, with the reading and signing having not been expressly waived, has been completed and is available for review and signature. Please call our office to make arrangements for a convenient location to accomplish this or if you prefer a certified transcript can be purchased.

If the errata is not returned within thirty days of your receipt of this letter, the reading and signing will be deemed waived.

Sincerely, Production Department

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DEPOSITION REVIEW CERTIFICATION OF WITNESS

1

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ASSIGNMENT NO: 2074644 CASE NAME: Holmes, Thomas J., et al. v. Dickert, John, et al.

DATE OF DEPOSITION: 9/2/2015 WITNESS' NAME: William Zach Williams In accordance with the Rules of Civil Procedure, I have read the entire transcript of my testimony or it has been read to me.

I have made no changes to the testimony as transcribed by the court reporter.

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_______________ ________________________ Date William Zach Williams Sworn to and subscribed before me, a Notary Public in and for the State and County, the referenced witness did personally appear and acknowledge that:

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They have read the transcript; They signed the foregoing Sworn Statement; and Their execution of this Statement is of their free act and deed.

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I have affixed my name and official seal 16

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this ______ day of_____________________, 20____.

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___________________________________ Notary Public ___________________________________ Commission Expiration Date

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1

ERRATA SHEET VERITEXT LEGAL SOLUTIONS MIDWEST ASSIGNMENT NO: 2074644 PAGE/LINE(S) / CHANGE /REASON ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ ___________________________________________________ _______________ ________________________ Date William Zach Williams SUBSCRIBED AND SWORN TO BEFORE ME THIS ________ DAY OF ________________________, 20______ . ___________________________________ Notary Public

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___________________________________ Commission Expiration Date

DEPOSITION REVIEW CERTIFICATION OF WITNESS

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ASSIGNMENT NO: 2074644 CASE NAME: Holmes, Thomas J., et al. v. Dickert, John, et al.

DATE OF DEPOSITION: 9/2/2015 WITNESS' NAME: William Zach Williams In accordance with the Rules of Civil Procedure, I have read the entire transcript of my testimony or it has been read to me.

I have listed my changes on the attached Errata Sheet, listing page and line numbers as well as the reason(s) for the change(s).

I request that these changes be entered as part of the record of my testimony.

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I have executed the Errata Sheet, as well as this Certificate, and request and authorize that both be appended to the transcript of my testimony and be incorporated therein. _______________ ________________________ Date William Zach Williams

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Sworn to and subscribed before me, a Notary Public in and for the State and County, the referenced witness did personally appear and acknowledge that: They have read the transcript; They have listed all of their corrections in the appended Errata Sheet; They signed the foregoing Sworn Statement; and Their execution of this Statement is of their free act and deed.

I have affixed my name and official seal this ______ day of_____________________, 20____. ___________________________________ Notary Public

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Casey 116:10,17,24,25 cash 28:12 277:7 catch 152:5 290:17 cause 108:15 110:10 111:3 112:22 113:19 114:13 135:15 138:7 139:22 142:9,21 143:16 146:3 156:8 159:2,16 168:19 171:3,5,6 189:15 199:1,4 204:5 225:23 245:15 253:8,13 276:23 caused 106:22 109:22 110:1 166:23 causing 77:11 78:7 115:1 245:17 272:10 CBS 312:6 CC 245:8 cc'd 117:11 CCAP 224:16 centered 19:16 central 38:19,21 39:1 40:8 centurion8551 8:6 313:7 certain 9:20 64:23 105:20 144:21 197:16 288:12,13,14 certainly 13:9 20:11 57:18 169:5 297:18 304:23 Certificate 322:11 CERTIFICATION 321:1 322:1 certified 1:24 320:16 certify 319:5,8,13 chain 116:1 chair 308:4 chairman 194:22 195:11 281:2 challenge 33:7 274:14,18 274:25 challenging 274:20 chamber 309:15 310:3 chance 283:14 chances 32:12 215:13 change 12:22 37:3 48:17 49:4 59:2,5 253:7 323:3 change(s) 322:8

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level 11:15 21:17 leverage 275:9,11 levy 146:21 liaison 190:20 license 61:7 licensee 76:21 77:5 81:1 81:14 licensing 79:5,10 82:13 82:19 83:4,8 lie 127:8 lied 124:14 253:7,12 life 92:7,13 114:20 174:1 light 133:11 lights 272:4,8,10 limited 21:23 25:7,13 59:1 96:24,25 97:22 101:7 Limiting 21:6 line 186:8 187:1 188:9 197:11 231:24 318:13 322:7 lineup 34:13 link 126:17 146:19 192:17 194:17 209:6,7 219:22 274:12 list 216:20 232:25 236:11 237:18,18,22 296:12 303:11,21,23,25 304:2 304:4,6,8,14,16,24 305:2,19 listed 322:7,17 listen 242:25 300:10 listing 322:7 literally 80:9 literature 91:3 little 20:20 23:21 37:15 39:4 43:24 52:19 63:6 82:2 90:15 168:3 169:11 178:15 246:23 270:24 278:1 290:23,24 live 10:17 187:11 284:22 lived 55:15,15 130:22 living 144:16 171:13 loaned 261:20 loaners 313:25 lobbyist 24:18 local 21:6 123:10 260:10 locals 189:21

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27:15 38:2 46:23 47:2 47:10 48:1,5 50:11 72:20 82:23 83:1 105:5 274:23 MEISSNER 2:7 member 17:21,25 20:9 20:11 118:2,7 211:5 278:25 279:5,13 280:1 312:14 members 21:8 117:6,19 117:23 132:4,8 226:23 memory 84:1 150:5 mention 72:7 76:9,10 79:20 88:9 89:24 mentioned 53:6 72:4 73:21 74:5 79:16 198:17 217:15 258:17 281:22 296:14 298:12 MERIT 1:23 Merry 276:9,11 message 29:24 30:10 52:8,20 150:17 191:13 245:3 313:23 314:12 messages 188:14 313:11 313:19,20,21 messaging 30:5,8,9 met 15:21 16:17 17:4,5 17:12 26:10 51:4 59:14 63:6 64:22 69:21,22 72:24 80:12 95:6,7 149:5 177:12 211:4,25 221:10 232:7 243:18 247:17 279:25 281:3 294:14 297:1 303:1,4 311:19 metaphor 310:12,13 Meyer's 304:8 Michael 2:7 9:14 128:15 220:18 261:15 304:2 Mick 47:6 50:14,23 51:7 52:5,7 54:19 204:24 205:18,19,23 239:6,15 239:15 261:2,10,16 309:13,23,23 314:2,9 Mid 71:3 191:22 middle 70:22 81:4 MIDWEST 323:1 Mike 59:15 158:1,23

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predominantly 40:10 45:15 preelection 273:13 prefer 320:16 preparation 67:15 prepare 61:10 70:8 89:19 90:13 122:24 128:23 153:17 154:3 157:6 237:9 294:24 prepared 68:5 70:11 90:1 90:25 153:20 160:3,9 161:1 175:15,16 185:9 185:22 187:13 213:22 236:12 293:24 294:2 preparing 87:12 88:24 121:22 131:1 291:15 presence 56:23 75:15 present 2:18 56:4,8,12 60:18 62:3 63:11 218:25 presented 250:24 press 3:4 52:13 86:24 87:10 88:3 136:21 195:10 pressure 129:2 132:11 133:13 pressured 150:18 151:11 151:24 pretty 13:8 18:12,13 25:15 34:5 98:7 135:13 168:4 223:16 253:13 prevail 255:3 preventing 44:15 previous 37:23 220:2 239:7 previously 22:21 45:14 96:5 131:13 184:11 192:13 212:20 261:13 273:3 280:15 305:6 primaries 201:19 primarily 44:5 primary 58:2,10,12,20 59:2 83:24 85:2 191:20 191:21 201:20,21 218:5 308:13,19 printed 302:2 prior 8:19 32:2 33:9 35:11 46:20,25 47:12

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202:19 R-O-B-S-O-N 12:3 race 11:16 20:7,18 27:23 32:13 33:2 39:8 55:13 57:17 58:16,18 86:7 races 21:6 300:23 Racine 3:13 9:11 18:11 18:16 19:25 25:25,25 29:8,22 31:4 32:9 35:16 35:20 36:6,11,19 38:13 38:19,21 39:1,5,13,16 40:3,8,13,15,16,21 42:10 46:11,15 47:20 48:3 54:17,22,24 55:12 57:10,22 59:3,8 64:16 70:18 72:1 73:3,6,7 75:9,12,17 77:16 78:25 85:23 87:11 89:22 91:5 94:4,4 95:8 98:22 112:4 112:16,20 114:15 122:10 123:9,21 126:10 128:20 135:1 139:6 147:11 148:24 149:6 152:20 172:6 176:19 177:2,7 180:9,14,19 183:6 184:4 185:7 190:25 192:18 193:22 194:23 199:11 200:6 206:18 207:4 209:7,8 211:5 213:16 219:23 222:25 230:14 236:20 236:25 238:5 242:3 243:16 245:21 248:25 249:4,18,20,22 250:19 251:14,23 265:24 271:7 276:18 277:24 278:20 278:25 279:6,13 280:19 280:24 286:15 288:6 290:19 292:23 295:19 296:12 299:14 309:3,17 314:14 racist 71:13,16 72:2 84:9 85:6,8,10,14 radio 23:24 175:7,10,13 176:4 177:23 191:9 201:1 221:18 222:3 234:10 235:1 253:7,12 raised 62:12

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6 6 4:9 69:24 73:14,17,21 74:1,2 75:22 76:4,7,14 76:21 77:2,7 79:4,12 83:1,5,13,16 136:7 157:23 6/22 125:9 60606 320:2 60s 201:25 620 312:6

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Case 2:14-cv-00208-JPS Filed 09/28/15 Page 115 of 115 Document 235-1