437. Fair believes that Coe’s actions in looking at The Place on 6th evidences Coe’s racially discriminatory intent. (Id. at 253-255).
438. Fair admitted that he has no personal knowledge as to which bars Coe was looking at and did not know whether Coe was on the Common Council at the time of the alleged incident. (Id.).
439. Gallagher relies on the following to support his opinions in his supplemental expert report:
a. E-mail from Michelle Logan—an African-American employee of the City—to Greg Bach referencing the City as “Raysheen.” (Stuart Decl., ¶19, Ex. DDDDDD at 12).
b. Devin Sutherland’s (“Sutherland”) e-mail stating that non-white establishments on 6th Street had “not added any value to the neighborhood.” (Id. at 6). c. Sutherland’s e-mail stating that “[t]he letter was to make sure the Mayor and others were aware of the current situation on Sixth Street and urge them to step up their assistance.” (Id. at 26).
d. Testimony of non-City employee Richard Pramer at Ginger’s due process hearing that Ginger’s attracted “hip hop gang banging types.” (Id. at 17).
e. E-mail from non-City employee Dr. Shove to Chief Howell raising concerns about a country western bar being located near a hip hop bar. (Id. at 18).
f. Testimony from Chief Howell about the Nuisance Property Abatement Vehicle. (Id. at 25). g. Testimony by Chief Howell regarding the Tavern Task Force group. (Id. at 23).
h. Deposition testimony from Penny Sharp that Mayor Dickert said “These niggers need to go back to Waukegan because they are disturbing the revenue here in Racine from the lake, from our vacationers at the lake.” (Id. at 19-20).
Case 2:14-cv-00208-JPS Filed 08/26/15 Page 59 of 68 Document 176 60