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Transcript of Haase, Leslie | Testimony transcript
Transcript of the Testimony of Leslie Haase
Date: November 6, 2013Volume: I
Case: In Re: Joplin Critical Investigation
Printed On: November 13, 2013
Holliday Reporting Service, Inc.Phone: 417-358-4078
Fax: 417-451-1114Email:[email protected]
Internet:
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 1
IN RE: JOPLIN CRITICAL INVESTIGATION
SWORN STATEMENT OF
LESLIE HAASE
Taken on Wednesday, November 6, 2013, from 1:34 p.m. to 2:22
p.m., at the law offices of Juddson H. McPherson, LLC, 626
S. Byers, in the City of Joplin, County of Jasper, State of
Missouri, before
SHARON K. ROGERS, C.C.R.650,
a Certified Court Reporter and a Notary Public within and
for the County of Jasper, and State of Missouri.
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 2
APPEARANCES
MR. THOMAS E. LORAINE
Loraine & Associates, LLC
4075 Osage Beach Pkwy., Suite 300
Osage Beach, MO 65065
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
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S T I P U L A T I O N
IT IS HEREBY STIPULATED that this Sworn Statement may be
taken by steno-mask type recording by SHARON K. ROGERS, a
Certified Court Reporter, and afterwards reduced into
typewriting.
It is further stipulated that the signature of the
witness is hereby waived, and that said Sworn Statement of
said witness shall be of the same force and effect as
though said witness had read and signed Sworn Statement.
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 4
I N D E X
Page/Line
DIRECT EXAMINATION BY MR. LORAINE . . . 5-4
E X H I B I T S
Exhibit #A. . . . . . . . 5-8
Advice of Rights
Exhibit #18 . . . . . . . 6-20
Spreadsheet
Note: Exhibits in separate binder
(sic) - typed as spoken
(ph.) - phonetic
Leslie Haase In Re: Joplin Critical Investigation
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Holliday Reporting Service, Inc.
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1 LESLIE HAASE
2 Having been first duly sworn and examined,
3 testified as follows:
4 DIRECT EXAMINATION BY MR. LORAINE:
5 Q. Ms. Haase, we briefly met. As you know my
6 name is Tom Loraine and I'm doing some
7 investigation on behalf of the City. I've
8 given you Exhibit #A which is an Advice of
9 Rights form. Have you read that?
10 A. Yes.
11 Q. Do you understand that?
12 A. Yes.
13 Q. I'm going to read it for you because I say
14 I'm going to do that. "I wish to advise you
15 that you are being questioned as part of an
16 official investigation by the City of Joplin.
17 You will be asked questions related and
18 specifically directed to the performance of
19 your official duties of fitness for office.
20 You are entitled to all the rights and
21 privileges guaranteed by the laws of the
22 Constitution of the State and the
23 Constitution of the United States, including
24 the right not to be compelled to incriminate
25 yourself. I further wish to advise you that
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 6
1 if you refuse to testify or to answer
2 questions relating to the performance of your
3 official duties, you will be subject to
4 departmental charges, which could result in
5 your dismissal from your official duties. If
6 you do answer, these statements may be used,
7 against you in relation to subsequent
8 departmental charges, but not in any
9 subsequent criminal proceedings." Did you
10 understand what you were signing here on
11 Exhibit #A as to your rights under the
12 Garrity?
13 A. I do.
14 Q. Okay. And you've complied with my request to
15 sign this and print your name on here, is
16 that right?
17 A. That's correct.
18 Q. And it appears on Exhibit #A?
19 A. Yes.
20 Q. I've marked Exhibit #18. Can you tell me
21 what #18 is? I know it's a spreadsheet. Go
22 from there. Tell me what it tells me.
23 A. It's a spreadsheet of the land that the JRC,
24 which is the Joplin Redevelopment
25 Corporation, of the properties that they've
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 7
1 bought through the end of July. I will get
2 you an updated one through the end of
3 October. This represents the majority of the
4 property, but there are a few other
5 properties that they've bought.
6 Q. Does that tell me the total amount paid is 8
7 million dollars?
8 A. It tells you the total amount paid is 5.3 and
9 at this point we had committed another 2.6
10 million dollars. We had not closed on them
11 yet. We've since closed on them.
12 Q. That's the ones that are missing off of here?
13 A. Yes.
14 Q. So ultimately we've got 8 million dollars
15 worth of property?
16 A. Right.
17 Q. Have all of these gone through
18 Wallace-Bajjali?
19 A. No, they all go through the Joplin
20 Redevelopment Corporation. Wallace-Bajjali
21 negotiates the purchase on behalf of the
22 Joplin Redevelopment Corporation. They bring
23 the proposed to the JRC board, the JRC board
24 entertains whether they actually want to
25 purchase it, and then they pass a resolution
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 8
1 to purchase the property, and that's the
2 process.
3 Q. And Wallace-Bajjali has obtained a fee in the
4 amount of what?
5 A. Their fee is 5.75 percent on each property.
6 Q. So what's the total of their fee so far?
7 Would it be 5.6 percent?
8 A. 5.75 percent.
9 Q. 5.75 percent of 8 million would be their fee?
10 A. Yes.
11 Q. So that would be something like 400 grand?
12 A. Yes, however, I think we're closer to 9 or 10
13 million. The JRC took out another loan to buy
14 more property so I think it's higher than
15 that, however on one of the pieces of
16 property Wallace-Bajjali has not gotten their
17 fee yet because we ran out of money so
18 they're waiting on their fee on that.
19 Q. So eventually they're going to get 5.76?
20 A. 75. 5 and three quarters.
21 Q. 5.75 percent of whatever the total dollar
22 amount of the transaction is?
23 A. Yes, purchased.
24 Q. You're a CPA. Is that a reasonable fee for
25 them?
Leslie Haase In Re: Joplin Critical Investigation
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Page 9
1 A. Well, that was the fee that the City Council
2 approved in the Master Developer Agreement.
3 Q. That didn't answer my question. What my
4 question is, is it reasonable for them to get
5 a fee when they buy a piece of property and
6 then when they sell it they also get a fee?
7 A. Yes, they're going to get their fee twice.
8 They get a fee when they buy the property,
9 and then when they actually do a project they
10 get a fee again.
11 Q. Even if they buy the property back themselves
12 they will still get a fee?
13 A. Now when they just buy the property back they
14 will not get a fee. When a project is
15 substantially complete they'll get the fee
16 again.
17 Q. So my understanding is right now they haven't
18 bought any property back?
19 A. They've not bought any property back and they
20 have not started a project.
21 Q. So they've gotten $400,000.00 worth of fee
22 here or there plus or minus, you know, if you
23 will for what they've done so far?
24 A. Right, but they've gotten other money, also,
25 besides this.
Leslie Haase In Re: Joplin Critical Investigation
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Holliday Reporting Service, Inc.
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1 Q. What other money have they gotten?
2 A. In that Master Developer Agreement the City
3 agreed to repay them pursuit costs up to a
4 million dollars.
5 Q. What's that?
6 A. Pursuit costs, so up to a million dollars.
7 They had to spend 2 million to get a million
8 back, so it was a 50 percent reimbursement.
9 We have paid them just shy of $800,000.00 in
10 pursuit costs reimbursement plus --
11 Q. Plus the $400,000.00?
12 A. Plus that, plus we created the largest tiff
13 in the State of Missouri, Tiff District as
14 part of this process, and they have gotten
15 some reimbursements for some costs that they
16 had on the tiff development.
17 Q. How much is that?
18 A. Probably shy of $200,000.00. Just shy of
19 $200,000.00.
20 Q. Any other fees that they've been paid?
21 A. That should be it.
22 Q. Now go back to my question. As a CPA do you
23 believe that's reasonable value?
24 A. I don't know how to answer that. That was
25 the City Council's decision, not my decision.
Leslie Haase In Re: Joplin Critical Investigation
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Holliday Reporting Service, Inc.
Page 11
1 Q. Was the City Attorney involved in the
2 development of these contracts with
3 Wallace-Bajjali?
4 A. He was, and he made it very clear at the
5 meeting where they were entertaining the
6 agreement, the Master Developer Agreement, he
7 made it abundantly clear repeatedly that
8 basically Wallace-Bajjali was getting a
9 double fee so everybody understood what they
10 were approving.
11 Q. You say the City Attorney made that?
12 A. Yes, the City Attorney made that abundantly
13 clear.
14 Q. Now you work not under the City Attorney?
15 A. No, I work for the City Manager, Mark Rohr.
16 Q. Did Mark approve this fee structure?
17 A. I assume so.
18 Q. And who negotiated that fee structure?
19 A. I don't know. I wasn't part of that.
20 Q. There's been some statements that one of the
21 Councilmen, Mr. Woolston, has been involved
22 in some of the acquiring of property. Are
23 you aware of that?
24 A. Yeah, I go to all the Council meetings and I
25 know that he abstains from some things. I
Leslie Haase In Re: Joplin Critical Investigation
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1 mean obviously I know what his profession is.
2 Q. He's a real estate agent?
3 A. He's a real estate agent. My office is
4 actually in charge of business licensing and
5 he was with Pro 100 for many years, but
6 recently he contacted our office and started
7 the application process to get a new business
8 license for a new company that he has
9 started.
10 Q. And what is that name?
11 A. I can't remember the name.
12 Q. Is it Four Star or Four State or something
13 like that?
14 A. No, that's a different company. I can't
15 remember what the name of his new company is.
16 Q. All right. Has he been reimbursed by the
17 Council for purchases of property that he's
18 acquired for the City?
19 A. Has he been reimbursed by the City?
20 Q. Yes.
21 A. No.
22 Q. Has the City bought any property off of him?
23 A. No.
24 Q. Off of Woolston?
25 A. The City hasn't bought any property. The JRC
Leslie Haase In Re: Joplin Critical Investigation
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1 has bought property.
2 Q. When I say the City I meant the JRC.
3 A. The JRC has bought property from Four State
4 Homes. Many of these properties were owned
5 by Four State Homes.
6 Q. Four State Homes would have gotten a fee
7 then?
8 A. I assume so.
9 Q. And he's a member of Four State Homes?
10 A. I don't really understand the connection with
11 Four State Homes. I understand that Charlie
12 Kuehn owns Four State Homes. I don't know
13 where Mr. Woolston falls into all of that.
14 Q. But you do know he's a member of some sort of
15 ownership or interest in Four State Homes?
16 A. I don't know that.
17 Q. But he does work for them?
18 A. He has some sort of a working relationship
19 with Charlie Kuehn, but I don't know exactly
20 what it is.
21 Q. JRC is the ultimate holder of the property?
22 A. They are.
23 Q. And that's a wholly owned --
24 A. Wholly owned subsidiary of the City.
25 Q. When you submit, if you have a notepad there,
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 14
1 --
2 A. Sure.
3 Q. When you submit, if you will, mark the
4 remaining balance #18A for me.
5 A. Okay.
6 Q. We'll identify that in record as Exhibit #18A
7 and that's yet to be submitted. Is there
8 anything else that you're gathering for me?
9 A. Yes, I'm copying all the contracts on these
10 for you.
11 Q. Are the contracts, the copy of the contracts
12 would be the same thing as this spreadsheet?
13 A. It will show you who JRC purchased them from,
14 Four State Homes or whoever they bought them
15 from.
16 Q. And this does not show that?
17 A. This does not show that.
18 Q. Okay. When you submit those contracts could
19 you give me a summary statement of, you know,
20 just some kind of a spreadsheet on Four State
21 Homes and anybody else that has a majority?
22 A. Yes.
23 Q. That would be helpful to me. And if you can
24 you can call that #18B.
25 A. Okay.
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
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1 Q. I'm going to switch gears for a minute on
2 you. There's been some inference that - and
3 by the way, when you leave here you're not to
4 discuss what we talk about in here.
5 A. Sure.
6 Q. There's been some discussion, and for lack of
7 a better term I'm going to call it bullying,
8 that's the word I'm going to use, and that's
9 been used in reference to Mark Rohr. Are you
10 aware of any of that, and if so to what
11 extent?
12 A. I guess I understand where they get the word
13 bullying, I guess. I don't know that's the
14 appropriate word.
15 Q. Okay. What word would you use?
16 A. Certainly I think if you ask any of the
17 department heads if we do something that
18 necessarily the City Manager doesn't agree
19 with he's not necessarily going to be very
20 happy. Well, we all work for him obviously
21 so I would say that there is some pressure to
22 not voice things in a different way. I don't
23 want to say that he just wants yes people
24 because that's not true. I mean he and I
25 have a very unique relationship. I think he
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
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1 and I have a different relationship than many
2 of the other departments, and I totally know
3 plenty, and that's fine. But, you know,
4 certainly since this it's a little more
5 difficult and probably what he tends to do is
6 just cut you out of things for a little
7 while.
8 Q. Until he's pleased with you again?
9 A. That's just my take.
10 Q. Well, this is some sort of management style,
11 I assume?
12 A. Yes. I mean --
13 Q. Is it a difficult working environment with
14 him?
15 A. Not usually for me. Now this week I happened
16 to have done something that I've never done
17 and I would say that yesterday I felt the
18 backlash from that somewhat.
19 Q. What was the backlash?
20 A. Well, I refused to sign a green sheet which
21 is what goes along with our Council bills and
22 I did not sign one because I did not agree
23 with it, and I've never done that in my
24 entire time with the City.
25 Q. What was it that you did not agree?
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
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1 A. It's we're reorganizing our Public Works
2 Department and what I didn't agree with was
3 the placement of some new positions and the
4 pay plan, I felt that they were out of
5 context with the other positions, and I did
6 not think that was right. So I did not sign
7 it and I went to him and I told him and he
8 was fine. I mean what he said exactly was I
9 promise you I'll think about it. I'm not
10 saying I'll change my mind, but I promise
11 I'll think about it. And he did and he
12 responded to me the next day and he said I've
13 thought about it, I'm still going to go the
14 direction that I'm going. He said you and I
15 usually agree, but this is one of the rare
16 instances where you and I are going to agree
17 to disagree. And I have no problem with
18 that. Then Monday was the Council meeting
19 and it became very public and then Council
20 tabled the issue.
21 Q. Because of this disagreement?
22 A. Yes, Brian also did not sign it.
23 Q. Brian?
24 A. Head.
25 Q. And what then occurred to you?
Leslie Haase In Re: Joplin Critical Investigation
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Holliday Reporting Service, Inc.
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1 A. So then yesterday I got an email from Mark
2 that I don't think I normally would have
3 gotten. I mean it wasn't a horrible email,
4 but - so we took over utility billing in
5 January where we're generating 18,000 sewer
6 bills a month, generally collecting 18,000
7 bills a month, and I hired one person to do
8 that. There was not enough people. So it's
9 been, you know, people have been somewhat
10 unhappy. So the email I got out of the blue
11 was our office has received two complaints in
12 three days about not being to reach a human
13 being in the Finance Department, and so I
14 responded to that, but that's - and then I
15 said I know what you're talking about. Many
16 times we get calls where people won't leave
17 their phone numbers, and he responded back
18 and said, well, I'll have say on who is the
19 Assistant City Manager, get you the
20 specifics. Well, then Sam sent me the
21 specifics and one of them was a lady that he
22 had already addressed with me last week and I
23 find it ironic that following Monday night
24 you're going to bring up something you've
25 already addressed with me.
Leslie Haase In Re: Joplin Critical Investigation
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1 Q. So you knew if nothing else that's a vale
2 threat that here is you're not doing your job
3 properly and it's over an issue that's
4 already been discussed and dismissed?
5 A. Yes, that's how I felt.
6 Q. This is the first time ever that you've felt
7 that with him?
8 A. That, yes.
9 Q. You work under more pressure than you believe
10 should be there, though, with him?
11 A. I don't know. I mean --
12 Q. Well, you supervise people. Do you supervise
13 them the same way?
14 A. No.
15 Q. Has being exposed to his supervision, has
16 that caused you some kind of health problems?
17 A. I don't think so.
18 Q. You don't go to doctors over it?
19 A. No, I don't do that.
20 Q. When we started talking you were having
21 difficulty expressing your thoughts about
22 this. I guess that peaks my interest because
23 I've heard that complaint more than once here
24 and I want to get to the bottom of it.
25 A. Well, surely you can understand we all work
Leslie Haase In Re: Joplin Critical Investigation
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1 for him so this is not easy by any means.
2 Q. No, I don't think any of us are having fun
3 here.
4 A. So I was just trying to choose my words
5 wisely.
6 Q. Well, would you say that he acts with a
7 certain amount of vindictiveness then? Would
8 that be a fair assessment?
9 A. I would say that he could, yes.
10 Q. Let me push this one step further. Have you
11 seen him do similar acts of vindictiveness
12 with other employees or department heads?
13 A. Yes.
14 Q. And have you seen it with members of the
15 public, also?
16 A. No.
17 Q. How about vendors?
18 A. Oh, yes.
19 Q. Huh?
20 A. Yes.
21 Q. Okay. So you have seen that with people that
22 might sell stuff to the City?
23 A. Yes, one instance.
24 Q. Let's talk about the one instance. What can
25 you tell me about it?
Leslie Haase In Re: Joplin Critical Investigation
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Holliday Reporting Service, Inc.
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1 A. Well, here's what I can tell you. So
2 following the tornado Mark came to me and
3 said the City will no longer - because I'm
4 over purchasing - so he came to me and said
5 the City will no longer do business with
6 Goodyear Tire. He said they did not service
7 my vehicle, he said I needed I think some
8 nails out of his tires after the tornado and
9 he said they didn't help him. And then I
10 kind of just let it go because I just thought
11 he was kind of talking in the heat of the
12 moment so I didn't really do anything, and
13 honestly I was so busy doing everything with
14 the tornado that it just wasn't my top
15 priority not to mention it. I would never do
16 that.
17 Q. Do what?
18 A. I would never redirect our business. As the
19 Finance Director I would never do that.
20 Q. As a matter of self interest?
21 A. Right.
22 Q. So how did he redirect that?
23 A. So I just kind of let it go in one ear and
24 out the other and didn't give it another
25 thought until later we were actually looking
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417-358-4078
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1 at the garage for other reasons and I saw the
2 Firestone order, we were using Firestone for
3 all the police tires instead of Goodyear. We
4 were actually doing a internal audit on the
5 garage and I was going over that audit with
6 Mark and I said, and I had really forgotten
7 about the Goodyear thing because like I said
8 really just in one ear and out the other
9 because just heat of the moment kind of
10 comment is what I thought. Well, he said
11 they changed from Goodyear because of me, and
12 then it all came back to me and I'm like, oh,
13 yeah.
14 Q. So the Police Department changed tires from
15 Goodyear to Firestone?
16 A. Well, the garage did because the City Manager
17 told Tim Nyander, who used to be our fleet,
18 used to be our Public Works Operations
19 Manager over the Fleet Department, and he
20 must have told Tim to switch. I mean he told
21 me, he said they changed because of me.
22 Q. Because of the incident of not getting all
23 the service he thought he ought to get from
24 some Goodyear dealer?
25 A. Yes.
Leslie Haase In Re: Joplin Critical Investigation
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1 Q. Who was the Goodyear dealer?
2 A. It's Goodyear on 20th and Range Line.
3 Q. Have you seen that kind of conduct before?
4 A. Never.
5 Q. Did you report that conduct to anybody?
6 A. I think I told Brian.
7 Q. You told Brian?
8 A. I think so at some point. Understand during
9 the tornado there was so much going on.
10 Q. What other department heads should I talk
11 with concerning Mr. Rohr's vindictiveness or
12 maybe what we call difficult, making it
13 difficult to deal with him on a department
14 head? Who else would feel that way?
15 A. I would talk to two of them.
16 Q. Who are they?
17 A. Dan Pekarek, the Health Director.
18 Q. Dan who?
19 A. Dan Pekarek, P-E-K-A-R-E-K.
20 Q. Health Director?
21 A. Uh-huh.
22 Q. And who else?
23 A. Chris Cotten, the Parts Director. You've
24 already talked to the Police Chief, right?
25 Q. Yes, I have. Do you think I should talk to
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1 the Police Chief about that incident, that
2 matter?
3 A. I just know the Police Chief has sat across
4 from me and described Mark Rohr, so --
5 Q. What does he say?
6 A. I found it a very interesting description.
7 Q. What did the Police Chief say about Mark
8 Rohr?
9 A. I can't remember everything he said, but he
10 started off by saying he respects Mark and
11 Mark has done a lot of good and he does let
12 us do our jobs. He gives us a lot of
13 latitude. I mean he started off in that way
14 and then he said, but, you know, he also has
15 some faults. I believe he did say was, I
16 think his word was he's a bully.
17 Q. What has Chris Cotten told you that would
18 lead you to believe that I should talk with
19 him?
20 A. It's not what Chris has told me, it's what I
21 saw.
22 Q. What did you see?
23 A. I seen the City Manager be very angry with
24 Chris.
25 Q. Angry in what fashion?
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1 A. Yelling at him.
2 Q. Well, you know, what does yelling mean?
3 A. I mean screaming.
4 Q. Screaming?
5 A. Uh-huh.
6 Q. In front of other people?
7 A. I was in the room.
8 Q. Anybody else?
9 A. No.
10 Q. What about Pekarek?
11 A. Before the tornado we had the homeless
12 initiative that Dan was in charge of and I
13 know that was particularly difficult. I know
14 the City Manager had a very certain vision in
15 his head and he put Dan in charge of this
16 task force, and I'm not sure the vision
17 always matched the task force and so Dan, he
18 may have some insight.
19 Q. Did Dan get yelled at, too?
20 A. I don't know.
21 Q. Do you know of any incident involving the
22 Police Department with some investigation on
23 some kind of home problem with Mark?
24 A. I don't know.
25 Q. Have you ever heard of that?
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1 A. Oh, I've heard of it plenty.
2 Q. What have you heard?
3 A. I heard that Mark, you know, abuses his wife
4 and that the Police Department goes and
5 nothing ever happens and nothing ever comes
6 out. That's what I heard. It doesn't mean
7 it's right, that's just what I've heard.
8 Q. Do you know his wife?
9 A. Uh-huh.
10 Q. Have you ever met her?
11 A. Uh-huh.
12 Q. Have you ever heard her complain about him?
13 A. No. I mean I don't like really --
14 Q. You don't socialize with them?
15 A. No.
16 Q. And you would not, I assume?
17 A. No.
18 Q. There is such a word as hostile work
19 environment. Have you ever heard that term?
20 A. Sure.
21 Q. I mean is this kind of where we're on the
22 verge of talking about? Is this what we're
23 talking about?
24 A. I don't know. Here is how I would describe
25 it. I would describe Mark not as a bully,
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1 but the word that I would use would be he
2 likes to be in control of everything. I
3 don't know that that's any different than any
4 other City Manager in the world. He has a
5 vision and he wants to see that vision
6 happen, but he likes to control things and
7 that's the word that I would use.
8 Q. His control is to the extent that it
9 certainly has made it unpleasant for you on
10 more than one occasion?
11 A. A few occasions.
12 Q. Difficult for you to talk to me about this?
13 A. Well, it is difficult because I like Mark and
14 like I said Mark and I have a good
15 relationship and I like working for Mark. He
16 lets me do my job for the most part. So, you
17 know, - and I'm not here to get Mark in
18 trouble.
19 Q. I think the record will reflect I asked you a
20 question. You certainly didn't volunteer
21 anything. You know, maybe Mark has been here
22 too long. Do you think?
23 A. I definitely think that. I've been with the
24 City 16 years. I worked under Steve Lewis,
25 our former City Manager. And when all this
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1 happened my only response every time has been
2 City Managers really have a life cycle of
3 about 7 years. Steve Lewis said that when he
4 was here and I didn't really get it, but I do
5 get it now. I've been here long enough where
6 I understand. Steve Lewis' last year here
7 was miserable. He had a miserable
8 relationship with the Council. He couldn't
9 get anything done. And it wasn't any fault
10 of his own, it's just like it's time to move
11 on. And I can't put my finger on why, it
12 just is, and I think it's - but I also don't
13 want Mark to go either because, you know,
14 he's done good things for the City and like I
15 said he and I have a good relationship, but,
16 yeah, for whatever reasons City Managers,
17 they just have a life cycle and he's been
18 here, you know, even longer than Steve Lewis
19 was here. But Steve Lewis' last year was
20 miserable. And not for anything that you
21 could even point your finger at. He didn't
22 do anything, Council didn't do anything, they
23 just - it's kind of like the seven year itch.
24 Q. Okay. I would remind you I don't want you
25 talking about what we've talked about here.
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1 At some point this will result in some kind
2 of report and there will probably be some
3 sort of disclosure of this stuff, so right
4 now is not the time to talk about this, okay?
5 A. Don't worry.
6 Q. All right. In regards to Woolston has there
7 been anything from a financial viewpoint that
8 you have viewed during this process of
9 purchasing property for the JRC, has there
10 been any kind of as a CPA that you would say,
11 well, you know, if I was an outside auditor
12 it would kind of shock me a little bit or I
13 might make a comment about that? Is there
14 anything like that with the Woolston matters?
15 A. Not that I could see.
16 Q. Have you had any dealings with Councilmen
17 Scearce?
18 A. Oh, yeah.
19 Q. And what comments would be appropriate for
20 you to make in that regard, if any?
21 A. About? I mean --
22 Q. Do you have any first-hand knowledge about
23 any of his dealings?
24 A. On the whole renting the building and all of
25 that?
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1 Q. Yes, all that.
2 A. No.
3 Q. Do you know of any illicit contacts or
4 criminal dealings that he's been involved
5 with?
6 A. No.
7 Q. Do you have any comments as an employee of
8 the City towards the City Council that would
9 be pertinent to any of these issues other
10 than maybe it's time for Mark to move on?
11 A. Not that I know of.
12 Q. Okay. All right, thank you. I appreciate
13 your assistance and these are confidential
14 matters at this stage. We're still looking
15 at stuff. Thank you.
16 A. Thank you. I'll get you those.
17 Q. Okay.
18
19 (SWORN STATEMENT CONCLUDED)
20
21
22
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REPORTER'S CERTIFICATE
STATE OF MISSOURI
ss.
COUNTY OF JASPER
I, SHARON K. ROGERS, Certified Court Reporter in the
State of Missouri, do certify that pursuant to the
foregoing Stipulation the witness came before me on the 6th
day of November, 2013, was duly sworn by me, and was
examined. That examination was then taken by me by
steno-mask recording and afterwards transcribed; said Sworn
Statement is subscribed by the witness as hereinbefore set
out on the day in that behalf aforesaid and is herewith
returned.
I further certify that I am not counsel, attorney, or
relative of either party, or clerk, or stenographer of
either party or of the attorney of either party, or
otherwise interested in the event of this suit.
________________________
SHARON K. ROGERS, CCR-650