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1 IN THE CIRCUIT COURT OF THESECOND JUDICIAL CIRCUIT, IN
2 AND FOR LEON COUNTY, FLORIDA
3
4 JAMES GREER,
5 Plaintiff,
6 vs. CASE NO. 2012-CA-0962
7 REPUBLICAN PARTY OF FLORIDAMIKE HARIDOPOLOS, and
8 JOHN THRASHER,
9 Defendant.
___________________________/10
11 VOLUME 2
12 DEPOSITION OF: JAMES GREER
13 TAKEN AT THE INSTANCE OF: Defendant Haridopolos
14 DATE TAKEN: May 24, 2012
15 LOCATION: 909 E. Park AvenueTallahassee, Florida
16COMMENCING: 12:58 p.m.
17CONCLUDING: 5:16 p.m.
18
19 REPORTED BY:
20 PEGGY OWENS
21 REGISTERED PROFESSIONAL REPORTER
22 REGISTERED MERIT REPORTER
23
24
25
PEGGY OWENS & ASSOCIATES (850)222-6010
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1 A P P E A R A N C E S
2 DAMON CHASE, Attorney at Law, of the law
3 offices of Chase?Freeman, 1525 International Parkway,
4 Suite 4021, Lake Mary, Florida 32746; appeared on
5 behalf of the Plaintiff.
6 STEPHEN S. DOBSON, III, Attorney at Law, of
7 the law offices of Dobson, Davis & Smith, 610 N. Duval
8 Street, Tallahassee, Florida 32301; appeared on behalf
9 of the Republican Party of Florida.
10 DEAN LEBOEUF, Attorney at Law, of the law
11 firm of Brooks, LeBoeuf, Bennett, Foster & Gwartney,
12 P.A., 909 East Park Avenue, Tallahassee, Florida
13 32301; appeared on behalf of the Defendant Haridopolos.
14 KENNETH W. SUKHIA, Attorney at Law, Sukhia
15 Law Group, 2846 Remington Green Circle, Suite B,
16 Tallahassee, Florida 32308; appeared on behalf of
17 Defendant Thrasher.
18
19 I N D E X
20 WITNESS PAGE
21 James Greer
22 Direct Examination by Mr. LeBoeuf 178
23
24
25
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1 E X H I B I T S
2 NO. PAGE
3 6 - Fundraising Services Agreement 188
4 7 - Victory Strategies, LLC, State Filing 198
5 8 - Gray/Robinson Letter dated 2/13/09 217
6 9 - SunTrust Business Account Signature Card 219
7 10 - Forward Strategies Fundraising Services
8 Agreement 233
9 11 - E-mail Dated 4/7/09 236
10 12 - E-mail Dated 3/9/09 & Attachments 279
11 13 - E-mail Dated 3/25/09 & Attachments 285
12 14 - E-mail Dated 4/9/09 & Attachments 295
13 15 - SunTrust Account Statement & Attachments 301
14 16 - E-mail Dated 6/15/09 306
15 17 - VS March 2009 Invoice & Attachments 307
16 18 - E-mail Dated 8/26/09 & Attachments 312
17 19 - Memo To Swartz & Attachments 312
18 20 - Memo To Swartz & Attachments 318
19 21 - Memo From Swartz & Attachments 322
20 22 - 1099-MISC Copies 334
21 23 - VS Detailed Analyses Year Ended 12/31/09 335
22 24 - SunTrust Account Statement 336
23
24
25
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1 D E P O S I T I O N
2 Whereupon,
3 JAMES A. GREER,
4 called as a witness; after having been first duly
5 sworn, was examined and testified as follows:
6 DIRECT EXAMINATION
7 BY MR. LeBOEUF:
8 Q Okay. A couple housekeeping issues,
9 Mr. Greer. Going back on the record, as we sit here
10 now, is there anything about your testimony this
11 morning, as we've had a break and had lunch, that you
12 think, oh, gee, that was a mistake, I didn't mean that.
13 This is what I meant to say. Anything you would like
14 to change about what we already talked about?
15 A I don't believe so.
16 Q Okay. You understand we are still on the
17 record? You are still under oath?
18 A Yes.
19 Q Okay. I want to talk about Victory
20 Strategies, okay? You told me before the break that
21 you had a discussion with Mr. LeMieux where you said he
22 suggested it was his idea during a phone conversation
23 when you were in your driveway, it was his idea that
24 you take over fundraising responsibilities for RPOF; is
25 that right?
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1 MR. CHASE: Object to form.
2 THE WITNESS: Yes.
3 BY MR. LeBOEUF:
4 Q Okay. Now, Mr. LeMieux did not suggest that
5 you create Victory Strategies or any other corporation
6 to do that, did he?
7 A No.
8 MR. CHASE: Object to form.
9 BY MR. LeBOEUF:
10 Q And when he had this discussion with you, you
11 suggested that Delmar Johnson also be involved with you
12 with the fundraising for the Party, right?
13 MR. CHASE: Object to form.
14 THE WITNESS: No. I don't, I don't recall
15 whether it was my suggestion or George's
16 suggestion. I do recall George made a comment
17 that Delmar is great at that, and you and Delmar
18 will do a great job at it.
19 BY MR. LeBOEUF:
20 Q Okay. And though we can agree that in terms
21 of this communication with Mr. LeMieux, the idea would
22 be that you alone or you and Delmar, whoever brought up
23 that discussion, would be doing the fundraising for the
24 Party?
25 A Yes.
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1 MR. CHASE: Object to form.
2 BY MR. LeBOEUF:
3 Q And I believe we talked this morning about
4 your role as Chairman. And I think you told me that it
5 was not part of your duties, responsibilities, or job
6 description as Chairman to do any fundraising up until
7 this point; is that correct?
8 MR. CHASE: Object to form.
9 THE WITNESS: I don't believe that's what my
10 response was.
11 BY MR. LeBOEUF:
12 Q Okay.
13 A I said that initially for the first year and
14 a half -- and I use that time frame -- Meredith handled
15 everything. She scheduled the events. I had very
16 little involvement. I was told where to be. Who to
17 introduce. And she would tell me how much we had
18 raised at the conclusion of events.
19 Q Okay. And you told me that something
20 changed. I thought the change was precipitated by this
21 communication with Mr. LeMieux. Obviously that was an
22 assumption I made that was not correct.
23 So you said for about a year and a half
24 Meredith did everything and told you where to be and
25 told you how much was raised. Tell me how that changed
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1 and when.
2 MR. CHASE: Object to form.
3 THE WITNESS: The 2008 presidential election
4 caused significant hardship on the Party, the
5 general party. Because a lot of money that was
6 heading to the general party got misdirected --
7 well, not misdirected, got directed to other parts
8 of the Party.
9 And when I say it changed, there just was
10 different efforts on Meredith O'Rourke's part
11 where the fundraising was going to go.
12 BY MR. LeBOEUF:
13 Q Okay.
14 A At some point in time, you know, I was going
15 to the Governor explaining -- you know, he was very
16 interested in how much we brought in, who it came from,
17 so on.
18 So at some point in time I was having to
19 inform the Governor that, you know, the general Party
20 needs help.
21 Q When you say the general Party you are
22 talking about RPOF?
23 A Yes.
24 MR. CHASE: Object to form.
25 THE WITNESS: Although, I was told it was
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1 illegal for the general Party, for the Republican
2 Party of Florida to have earmarked accounts, we,
3 in fact, did have earmarked accounts.
4 BY MR. LeBOEUF:
5 Q Who told you it was illegal?
6 A The General Counsel.
7 MR. CHASE: Object to form.
8 THE WITNESS: The General Counsel, the
9 Finance Director.
10 BY MR. LeBOEUF:
11 Q So when you say General Counsel, you are
12 talking about Jason Gonzalez?
13 A Yes.
14 Q When you say the Finance Director, who are
15 you talking about?
16 A Richard Swartz.
17 Q Okay.
18 A Anytime there was an effort to talk about
19 money being earmarked, everyone would panic and inform
20 me I should never use that term because that's against
21 the law.
22 Q And earmarking would be specifically
23 identifying money from donors for the Republican Party
24 of Florida?
25 MR. CHASE: Object to form.
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1 THE WITNESS: Not identifying donors, but
2 identifying who is the recipient of the money
3 within the Party.
4 BY MR. LeBOEUF:
5 Q I'm sorry, I thought that's what I said.
6 A I'm sorry.
7 Q In terms of it was illegal, it was your
8 understanding from Jason Gonzalez and from Richard
9 Swartz that it was illegal for a donor to designate
10 their donation to the Republican Party of Florida?
11 MR. CHASE: Object to form.
12 THE WITNESS: Yes.
13 BY MR. LeBOEUF:
14 Q So how was the Republican Party of Florida
15 supposed to get money?
16 MR. CHASE: Object to form.
17 THE WITNESS: Well, the Party, itself, as a
18 legal entity, from my understanding, was supposed
19 to get contributions. And the way the Party
20 operated is you had -- and prior to the leadership
21 funds that they now have, that were created by the
22 legislature to not have to answer to the structure
23 of RPOF, prior to that there was the House
24 fundraising, the Senate fundraising, the general
25 Party.
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1 People would write checks and earmark it to
2 go to the House, to go to the Senate, to go to the
3 general campaign, to go to the victory account.
4 And whenever that would occur, you know,
5 there would be some concern that we cannot earmark
6 this money. Chairman, you need to never use that
7 term. Jim, never use that term because it is
8 illegal; but, in fact, it occurs.
9 BY MR. LeBOEUF:
10 Q Okay. Let's move on to Victory Strategies.
11 I think we've had discussion regarding Mr. LeMieux's
12 communication about you taking over fundraising and the
13 other issues associated with that.
14 How did that then ultimately become embodied
15 in the creation of Victory Strategies?
16 MR. CHASE: Object to form.
17 THE WITNESS: Well, after I consulted with
18 GrayRobinson, their recommendation was to form an
19 LLC versus a corporation. We formed an LLC.
20 My position was I wanted to do it right. I
21 wanted to have a corporation. I wanted to have a
22 contract with the Party. I wanted to make sure we
23 had the tax issues in order. And that we did
24 everything that we were supposed to do as it
25 relates to having that relationship with the
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1 party.
2 GrayRobinson recommended the LLC. We formed
3 the LLC. Delmar Johnson handled everything to do
4 with that LLC. I didn't even know where we opened
5 the bank account up, how much money we had in the
6 bank.
7 He would inform me of what Victory
8 Strategies' commission was. And you know, I don't
9 know, I don't believe I even ever signed any
10 documents. I think it was Delmar.
11 But the idea came from talking to
12 GrayRobinson about what is the proper thing to do.
13 And the proper thing at their recommendation was
14 forming an LLC.
15 BY MR. LeBOEUF:
16 Q Okay. Let's back up on that.
17 A Sure.
18 Q You said the first communication with
19 GrayRobinson was actually with John Harris, right?
20 A Yes.
21 MR. CHASE: Object to form.
22 BY MR. LeBOEUF:
23 Q You acknowledge that Mr. Harris is not a
24 lawyer. You knew that, right?
25 MR. CHASE: Object to form.
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1 THE WITNESS: Yes.
2 BY MR. LeBOEUF:
3 Q Okay. Who initiated the communication with
4 Mr. Harris?
5 A I did.
6 Q Okay.
7 MR. CHASE: Object to form.
8 BY MR. LeBOEUF:
9 Q And in that communication did you tell me it
10 was on the phone and you and Delmar were on the phone
11 with Mr. Harris?
12 MR. CHASE: Object to form.
13 THE WITNESS: Yes. Delmar was in my office
14 on the couch, sitting on the couch.
15 BY MR. LeBOEUF:
16 Q Okay. So you called from your office at
17 RPOF?
18 MR. CHASE: Object to form.
19 THE WITNESS: Yes.
20 BY MR. LeBOEUF:
21 Q All right. And tell me about what transpired
22 in that communication.
23 MR. CHASE: Object to form.
24 THE WITNESS: Well, I wanted to make sure we
25 did everything right. Got John Harris on the
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1 phone. Told him we were going to be setting up a
2 fundraising political consulting firm.
3 And he talked about the pros and cons of
4 corporations, the pros and cons of LLCs. He then
5 said, I will get you another, I will get you --
6 there was an attorney that he later called back
7 and said he spoke to.
8 And then an attorney called me from
9 GrayRobinson. I don't remember the attorney's
10 name. And the attorney discussed with me setting
11 up the corporation versus the LLC.
12 And it was ultimately decided, upon their
13 recommendation, to set up the LLC.
14 BY MR. LeBOEUF:
15 Q Okay. Now, I want to be clear on this. The
16 communications about whether you do an LLC or a
17 corporation, are you saying that started with John
18 Harris, even though John is not a lawyer?
19 A No.
20 MR. CHASE: Object to form.
21 THE WITNESS: No. The initial discussion was
22 I told Delmar, prior to getting John Harris on the
23 phone, that I wanted to do it the right way. And
24 we should form a corporation for tax purposes.
25 And we should have a contract with the Party.
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1 But I didn't know what was the right way to
2 go. And I said, John Harris -- who I had worked
3 with for many, many years was a good friend, very
4 honorable person -- he, I called him.
5 I explained what we were doing. He said, let
6 me get back to you. He spoke to one of his
7 attorneys in the firm. He called me back I think
8 a day later. Another attorney called me back,
9 discussed it with me. Then the attorney started
10 dealing with Delmar after that.
11 MR. CHASE: Object to the form.
12 BY MR. LeBOEUF:
13 Q So it is your testimony that Delmar is
14 actually the person who engaged GrayRobinson on behalf
15 of Victory Strategies to form Victory Strategies?
16 MR. CHASE: Object to form.
17 THE WITNESS: No. I engaged GrayRobinson. I
18 was the person who picked up the phone, called
19 GrayRobinson, asked GrayRobinson questions.
20 Wanted legal advice from GrayRobinson. Talked to
21 the attorney. Talked to John Harris.
22 Once the decision had been made, then the
23 administrative side of Victory Strategies Delmar
24 took over. But Delmar did not talk to them
25 initially. Delmar was not -- he was sitting on
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1 the couch, but he didn't open his mouth.
2 BY MR. LeBOEUF:
3 Q Okay. Do you know when Victory Strategies
4 was created?
5 MR. CHASE: Object to form.
6 THE WITNESS: I don't, I don't recall the
7 exact date.
8 BY MR. LeBOEUF:
9 Q Okay. Let me show you a document, which we
10 will refer to for identification purposes as Exhibit 6.
11 Do you recognize this document.
12 A I do.
13 (Whereupon, the document was marked as
14 Deposition Exhibit No. 6.)
15 BY MR. LeBOEUF:
16 Q What is it?
17 A It is the --
18 MR. CHASE: Object to form.
19 THE WITNESS: It is the contract between
20 Victory Strategies and the Republican Party of
21 Florida.
22 BY MR. LeBOEUF:
23 Q Okay. And what is the date of the agreement?
24 MR. CHASE: Object to form.
25 THE WITNESS: I believe it is February 1st.
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1 BY MR. LeBOEUF:
2 Q 2009?
3 A Uh-huh.
4 Q And who signed the document?
5 MR. CHASE: Object to form.
6 THE WITNESS: Myself and Delmar Johnson.
7 BY MR. LeBOEUF:
8 Q So you signed the contract on behalf of the
9 Republican Party of Florida?
10 A I did.
11 MR. CHASE: Object to form.
12 BY MR. LeBOEUF:
13 Q And Mr. Johnson signed on behalf of Victory
14 Strategies?
15 A He did.
16 MR. CHASE: Object to form.
17 BY MR. LeBOEUF:
18 Q Okay. And by this contract, it would
19 indicate that Victory Strategies was a corporation,
20 correct, on page one?
21 MR. CHASE: Object to form.
22 THE WITNESS: Let me see, where does it say
23 that?
24 BY MR. LeBOEUF:
25 Q First paragraph, just before, just above P O
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1 Box 1735. It says Victory Strategies, Inc.
2 A Yes.
3 Q Okay. But on the last page where Mr. Johnson
4 signed, it says Victory Strategies, LLC; right?
5 MR. CHASE: Object to form.
6 THE WITNESS: Yes.
7 BY MR. LeBOEUF:
8 Q You drafted this agreement, right?
9 A I didn't draft it.
10 MR. CHASE: Object to form.
11 BY MR. LeBOEUF:
12 Q Who prepared it?
13 A It was in the computer. It had been utilized
14 with other fundraisers.
15 Q Well, what you are saying is you had some
16 form language, but you ultimately are the individual
17 who took the information from the computer and
18 substituted other parties' names and other paragraphs
19 and put in Victory Strategies into this fundraising
20 agreement; right?
21 MR. CHASE: Object to form.
22 THE WITNESS: I think I instructed my
23 secretary to do that.
24 BY MR. LeBOEUF:
25 Q Okay. And who would that have been?
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1 A I believe that was Lela Whitfield.
2 Q Lela Whitfield?
3 A Uh-huh.
4 Q Did you have any other secretaries?
5 MR. CHASE: Object to form.
6 THE WITNESS: No.
7 BY MR. LeBOEUF:
8 Q Anybody else you would have do this if it
9 wasn't Lela Whitfield?
10 A No.
11 MR. CHASE: Object to form.
12 BY MR. LeBOEUF:
13 Q Okay. So it is your belief that you had Lela
14 Whitfield go into the form contracts RPOF had in its
15 computers and modified one of those form contracts to
16 create the document that we've identified as Exhibit 6
17 to your deposition?
18 MR. CHASE: Object to form.
19 THE WITNESS: Not any form contract. The
20 fundraising contracts we had used previously.
21 BY MR. LeBOEUF:
22 Q Fair enough. And you instructed her to put
23 in the name Victory Strategies and to identify Victorty
24 Strategies, LLC, as the consultant and you had signed
25 as the Party --
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1 MR. CHASE: Object to form.
2 BY MR. LeBOEUF:
3 Q -- on behalf of the Republican Party of
4 Florida.
5 MR. CHASE: Object to form.
6 THE WITNESS: I believe so.
7 BY MR. LeBOEUF:
8 Q All right. Did you tell Lela Whitfield that
9 you had any ownership interest in Victory Strategies?
10 MR. CHASE: Object to form.
11 THE WITNESS: No.
12 BY MR. LeBOEUF:
13 Q With regard to your instructions, you
14 instructed Ms. Whitfield of all the information to
15 include in this fundraising services agreement?
16 MR. CHASE: Object to form.
17 THE WITNESS: Well, when you say all this
18 information, a significant portion of it was the
19 standard language we had used in previous
20 fundraising agreements.
21 BY MR. LeBOEUF:
22 Q Right.
23 A I had her remove a monthly fee and simply
24 have a 10 percent commission. And that P. O. Box 1735
25 is not my handwriting. So I don't know whose
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1 handwriting that is. But it was a standard fundraising
2 contract that we had used with other fundraisers.
3 Q Well, you certainly reviewed and approved all
4 of the language in this fundraising services agreement
5 with Victory Strategies; correct?
6 MR. CHASE: Object to form.
7 THE WITNESS: I reviewed it, yes.
8 BY MR. LeBOEUF:
9 Q Okay. And you helped create it based on what
10 we talked about, right?
11 MR. CHASE: Object to form.
12 THE WITNESS: Yes.
13 BY MR. LeBOEUF:
14 Q All right. And let's go to paragraph four of
15 the agreement.
16 A Okay.
17 Q The heading on paragraph four is
18 Confidentiality, right?
19 A Uh-huh.
20 MR. CHASE: Object to form.
21 BY MR. LeBOEUF:
22 Q And the last sentence of paragraph four says,
23 "In addition to the terms of the Non-delegable -- non-
24 disclosure agreement, Consultant" -- which would be
25 Victory Strategies, right?
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1 A Uh-huh.
2 Q "Acknowledges that all matters related to the
3 finance plan, income received and all financial
4 information or discussions related to these topics
5 shall not be disclosed to any person, including major
6 donors or members of the RPOF Finance Committee without
7 the express approval of the Chairman or Executive
8 Director of the RPOF."
9 A Uh-huh.
10 Q Correct?
11 A Uh-huh.
12 MR. CHASE: Object to form.
13 THE WITNESS: Yes.
14 BY MR. LeBOEUF:
15 Q You authorized and directed that language be
16 included in this agreement, correct?
17 MR. CHASE: Object to form.
18 THE WITNESS: No. That language is included,
19 and in some agreements much more extensive,
20 requiring confidentiality. All fundraising
21 agreements that the Party had, had a very strong
22 confidentiality provision.
23 That language came from some other agreement.
24 It is not logical for me to bind myself to not
25 tell anyone. So it was language that was pulled
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1 out from any other agreement.
2 BY MR. LeBOEUF:
3 Q Well, sir, is it your testimony that the
4 language we just read from paragraph four is included
5 in all of the fundraising services agreements?
6 MR. CHASE: Object to form.
7 THE WITNESS: No.
8 BY MR. LeBOEUF:
9 Q Okay. And isn't it true that none of the
10 other fundraising service agreements with RPOF have the
11 inherent conflict of interest that this contract has,
12 because in this contract you are an owner of the
13 consulting company that RPOF is contracting with?
14 MR. CHASE: Object to form.
15 THE WITNESS: There is no conflict because we
16 performed a service. This was a confidentiality
17 provision that all fundraising agreements had.
18 And we weren't disclosing not only from this
19 agreement; but when you presented to me my oath
20 today, it says I was not allowed to disclose
21 anything to outside parties relating to RPOF
22 activities.
23 So as the fundraiser, I not only would have
24 violated this agreement, I would have violated my
25 oath if I disclosed it.
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1 BY MR. LeBOEUF:
2 Q You acknowledge in this fundraising
3 agreement, you are the Chairman of the RPOF; correct?
4 MR. CHASE: Object to form.
5 THE WITNESS: Yes.
6 BY MR. LeBOEUF:
7 Q You are the majority owner in the consulting
8 company in this contract, Victory Strategies.
9 MR. CHASE: Object to form.
10 BY MR. LeBOEUF:
11 Q Right?
12 A Yes, that's correct.
13 Q And you don't see that as a conflict of
14 interest?
15 MR. CHASE: Object to form.
16 THE WITNESS: I do not because we were
17 performing a --
18 MR. CHASE: He didn't ask you why.
19 BY MR. LeBOEUF:
20 Q Why not?
21 MR. CHASE: Object to form.
22 BY MR. LeBOEUF:
23 Q Why isn't it a conflict of interest?
24 MR. CHASE: Object to form.
25 THE WITNESS: Because we were performing a
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1 specific and additional service to the Republican
2 Party that I had advised the Governor of. I had
3 advised George LeMieux of. And more importantly,
4 if I had wanted to do anything that was
5 inappropriate, I would not have to have entered
6 into this agreement.
7 I wanted to make sure that we did everything
8 right and had an agreement binding. I handed it
9 to the Chief Financial Officer and told him to
10 file it.
11 BY MR. LeBOEUF:
12 Q You did this -- told him to file what?
13 A This agreement.
14 MR. CHASE: Object to form.
15 BY MR. LeBOEUF:
16 Q And there is nothing about this agreement
17 that identifies your ownership interest in Victory
18 Strategies, is there?
19 THE WITNESS: No.
20 MR. CHASE: Object to form.
21 BY MR. LeBOEUF:
22 Q So no one who looks at this agreement,
23 Exhibit 6 to your deposition, has anyway of knowing
24 that you, Mr. Greer, had any interest in Victory
25 Strategies, do they?
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1 MR. CHASE: Object to form. And I would ask
2 counsel to lower his tone.
3 THE WITNESS: That's correct.
4 BY MR. LeBOEUF:
5 Q Let's go back to the incorporation of Victory
6 Strategies. Victory Strategies didn't even exist on
7 February 9 -- February 1st, 2009, did it?
8 MR. CHASE: Object to form.
9 THE WITNESS: I don't know because
10 Mr. Johnson took care of that.
11 MR. LeBOEUF: I would like to show you
12 another document which we will -- I have a
13 document we will identify as Exhibit No. 7 to your
14 deposition.
15 (Whereupon, the document was marked as
16 Deposition Exhibit No. 7.)
17 BY MR. LeBOEUF:
18 Q Can we agree that Exhibit No. 7 is a
19 certification from the State of Florida, Department of
20 State, indicating that the Articles of Incorporation of
21 Victory Strategies, Incorporated, a limited liability
22 company under the laws of the State of Florida were
23 filed on February 4th, 2009?
24 MR. CHASE: Object to form.
25 THE WITNESS: It appears that's when
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1 GrayRobinson filed the Articles of Incorporation.
2 BY MR. LeBOEUF:
3 Q Okay. And with regard to Victory Strategies,
4 unlike the other corporations that you have been
5 involved in, you didn't participate in or draft these
6 articles, did you?
7 MR. CHASE: Object to form.
8 THE WITNESS: No. This was in conjunction
9 with seeking legal advice from GrayRobinson of
10 what would be the appropriate method to create
11 this entity.
12 BY MR. LeBOEUF:
13 Q Whose idea was it to conceal your name from
14 any of the official documents recorded on behalf of
15 Victory Strategies?
16 MR. CHASE: Object to form.
17 THE WITNESS: The suggestion to not make
18 anyone aware initially was Delmar Johnson's.
19 BY MR. LeBOEUF:
20 Q So it was Delmar's idea that none of the
21 public disclosures associated with Victory Strategies
22 should contain any reference to your majority ownership
23 interest?
24 MR. CHASE: Object to form.
25 THE WITNESS: His suggestion was that if
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1 Meredith O'Rourke became aware that we were
2 assuming responsibility for fundraising, that she
3 would interfere in our ability to raise money for
4 the Party.
5 BY MR. LeBOEUF:
6 Q And how would she do that?
7 MR. CHASE: Object to form.
8 THE WITNESS: As she had been, as she had
9 done many times before that other fundraisers had
10 concerns about. Fundraising is a dog-eat-dog
11 world. One fundraiser will kill off another
12 fundraiser in a heartbeat to get that commission
13 check.
14 BY MR. LeBOEUF:
15 Q Okay. It is your understanding at that time
16 that Ms. O'Rourke was being paid a commission and not a
17 flat fee?
18 MR. CHASE: Object to form.
19 THE WITNESS: During this time?
20 BY MR. LeBOEUF:
21 Q Yes, sir.
22 A I don't believe that she was being -- well,
23 yes. The Governor had told me to pay her $5,000 a
24 month to keep the bitch's mouth shut. So she continued
25 to -- that was the quote he used.
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1 MR. CHASE: Object to form.
2 THE WITNESS: She still was a contracted
3 fundraiser with the Party.
4 BY MR. LeBOEUF:
5 Q But she wasn't on commission, was she?
6 MR. CHASE: Object to form.
7 THE WITNESS: I don't recall what that last
8 contract said. I thought it had a commission
9 provision in it.
10 BY MR. LeBOEUF:
11 Q Referring to Page two of Exhibit No. 7.
12 A Okay. This?
13 Q Yes.
14 A Who is Marie-Anne Luber.
15 MR. CHASE: Object to form.
16 THE WITNESS: I do not know.
17 BY MR. LeBOEUF:
18 Q Have you ever met her?
19 A No.
20 MR. CHASE: Object to form.
21 BY MR. LeBOEUF:
22 Q Do you know why she is designated as the
23 authorized representative for Victory Strategies?
24 MR. CHASE: Object to form.
25 THE WITNESS: I assume she is an employee of
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1 GrayRobinson.
2 BY MR. LeBOEUF:
3 Q Did you ever have a conversation with
4 Ms. O'Rourke in 2008, before the formation of Victory
5 Strategies, where you asked her if she would like to go
6 into business with you; and that if she did, the two of
7 you could make a lot of money as fundraisers?
8 MR. CHASE: Object to form.
9 THE WITNESS: Absolutely not.
10 BY MR. LeBOEUF:
11 Q So if she were to testify that you had this
12 conversation and she turned you down, she would be
13 lying?
14 A She would be lying.
15 MR. CHASE: Object to form.
16 BY MR. LeBOEUF:
17 Q And just for the record, when Victory
18 Strategies was created, it was created with you as the
19 majority shareholder with 60 percent interest?
20 MR. CHASE: Object to form.
21 BY MR. LeBOEUF:
22 Q The limited liability company.
23 MR. CHASE: Object to form.
24 THE WITNESS: Yes.
25 BY MR. LeBOEUF:
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1 Q And Mr. Johnson had a 40 percent interest?
2 MR. CHASE: Object to form.
3 THE WITNESS: Yes.
4 BY MR. LeBOEUF:
5 Q And whose idea was that?
6 MR. CHASE: Object to form.
7 THE WITNESS: Mr. Johnson initially felt that
8 he should get half, 50/50; but at the conclusion
9 of it -- I don't recall how it came to be -- but
10 at the end I would have 60 percent and he would
11 have 40.
12 BY MR. LeBOEUF:
13 Q Well, obviously if he started out wanting to
14 have half, you negotiated him down to an interest less
15 than half; right?
16 MR. CHASE: Object to form.
17 THE WITNESS: Negotiated is not, I don't
18 think, the proper term. But the end conclusion
19 was that I would have 60 and he would have 40.
20 BY MR. LeBOEUF:
21 Q What would be the proper term?
22 MR. CHASE: Object to form.
23 BY MR. LeBOEUF:
24 Q Is it because it was your idea and your
25 corporation and he was lucky to get 40 percent?
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1 MR. CHASE: Object to form.
2 THE WITNESS: No. It was actually, you know,
3 it was thought processed that I would get 60 and
4 he would get 40.
5 BY MR. LeBOEUF:
6 Q Whose process?
7 MR. CHASE: Object to form.
8 THE WITNESS: Both.
9 BY MR. LeBOEUF:
10 Q How did it change if he started out wanting
11 50 percent? How did it become his thought process that
12 he would get 40 percent and you would get 60 percent?
13 MR. CHASE: Object to form.
14 THE WITNESS: I don't recall.
15 BY MR. LeBOEUF:
16 Q If he said that you indicated that it was
17 your idea and that he was lucky to get 40 percent,
18 would he be wrong?
19 MR. CHASE: Object to form.
20 THE WITNESS: If he made that statement, he
21 would be wrong.
22 BY MR. LeBOEUF:
23 Q That wouldn't be true?
24 A That wouldn't be true.
25 MR. CHASE: Object to form.
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1 BY MR. LeBOEUF:
2 Q Whose idea was it that Mr. Johnson would be
3 the only officer and the sole manager of Victory
4 Strategies?
5 MR. CHASE: Object to form.
6 THE WITNESS: Mr. Johnson.
7 BY MR. LeBOEUF:
8 Q And whose idea was it that your name wouldn't
9 appear on any of the public documents associated with
10 Victory Strategies?
11 MR. CHASE: Object to form.
12 THE WITNESS: It was his suggestion that the,
13 when we sat down and talked about it.
14 BY MR. LeBOEUF:
15 Q Okay. Who else was present in that time?
16 MR. CHASE: Object to form.
17 THE WITNESS: Only him and I.
18 BY MR. LeBOEUF:
19 Q Okay. And why did he suggest that?
20 MR. CHASE: Object to form.
21 THE WITNESS: Because he said if Meredith
22 finds out that we are doing the fundraising for
23 the Party, she will kill us off, was the exact
24 term he used.
25 BY MR. LeBOEUF:
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1 Q Well, wasn't there a concern that the
2 Republican Party of Florida or the Governor would have
3 concerns that you were engaged in fundraising as the
4 Chair and taking a commission for that activity?
5 MR. CHASE: Object to form.
6 THE WITNESS: That was not part of the
7 discussion. I had already talked to the Governor
8 about this on several occasions. It was the fact
9 that when the conclusion was made that we would
10 assume responsibility for doing fundraising,
11 Delmar said, and I agreed, that Meredith would try
12 and kill us off and we wouldn't be able to raise a
13 dime.
14 BY MR. LeBOEUF:
15 Q Mr. Greer, isn't it true that you never had
16 any discussions with the Governor about your
17 fundraising on behalf of the Party through a separate
18 organization such as Victory Strategies?
19 MR. CHASE: Object to form.
20 THE WITNESS: The Governor was never aware of
21 the company name. The Governor was aware and
22 approved and directed me to take over fundraising
23 for the Republican Party of Florida and pay myself
24 a commission. We discussed it no less than three
25 times.
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1 BY MR. LeBOEUF:
2 Q Did you ever tell the Governor that you were
3 doing the fundraising through Victory Strategies, and
4 that you were a majority owner in Victory Strategies?
5 MR. CHASE: Object to form.
6 THE WITNESS: Charlie and I never discussed
7 the corporate entity name.
8 BY MR. LeBOEUF:
9 Q That didn't directly answer my question. Did
10 you ever discuss with the Governor and tell the
11 Governor that you weren't going to do the fundraising
12 for the Party in your own name; but instead, you were
13 forming Victory Strategies and that you were a majority
14 owner in Victory Strategies, and you were going to
15 conceal your fundraising activities through that
16 corporation?
17 MR. CHASE: Object to form.
18 THE WITNESS: I never informed the Governor
19 of the name of the corporate entity Victory
20 Strategies.
21 BY MR. LeBOEUF:
22 Q Okay. Did you ever tell the Governor that
23 you had a majority ownership interest in Victory
24 Strategies?
25 MR. CHASE: Object to form.
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1 THE WITNESS: If I had never told him about
2 Victory Strategies, I wouldn't tell him I had the
3 majority ownership.
4 BY MR. LeBOEUF:
5 Q So we can agree that the Governor never had
6 any idea that you were the majority owner of Victory
7 Strategies, correct?
8 MR. CHASE: Object to form.
9 THE WITNESS: The Governor did not know the
10 name Victory Strategies.
11 BY MR. LeBOEUF:
12 Q Did the Governor know you had a majority
13 interest in any fundraising company doing fundraising
14 for the Republican Party of Florida?
15 MR. CHASE: Object to form.
16 THE WITNESS: The Governor knew I was going
17 to be doing fundraising for the Party, and I was
18 receiving a commission to do so.
19 BY MR. LeBOEUF:
20 Q But he had no idea you had a majority
21 interest in any corporation, including Victory
22 Strategies; correct?
23 MR. CHASE: Object to form.
24 THE WITNESS: The Governor did not know the
25 name Victory Strategies.
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1 BY MR. LeBOEUF:
2 Q Or any other corporation that you were doing
3 fundraising through?
4 MR. CHASE: Object to form.
5 THE WITNESS: He did not know that I was
6 doing fundraising through a legal entity called
7 Victory Strategies.
8 BY MR. LeBOEUF:
9 Q Did anyone, other than Delmar Johnson and the
10 lawyers at a GrayRobinson, know that you were doing
11 fundraising for the Republican Party of Florida
12 through -- strike that.
13 Did anyone, other than the lawyers at
14 GrayRobinson and Delmar Johnson, know that you had a
15 majority interest in Victory Strategies?
16 MR. CHASE: Object to form.
17 THE WITNESS: Jason Gonzalez knew I had an
18 interest in Victory Strategies. I don't believe
19 that I told him it was a majority interest.
20 BY MR. LeBOEUF:
21 Q When did Jason Gonzalez learn you had an
22 interest in Victory Strategies?
23 MR. CHASE: Object to form.
24 THE WITNESS: There was a meeting in my
25 office in which Gonzalez, Rimes -- I believe Eric
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1 might have been there. That was in late
2 afternoon. And it was a, it was a meeting that I
3 was upset because we had just come from a meeting
4 where the political consultants and the political
5 staff talked about voter suppression and keeping
6 blacks from voting. And it had been a very tense
7 day.
8 And they came in to my office and sat down
9 and started asking me numerous questions that were
10 being circulated about fundraising in New York
11 City, limousines, paying bills for the Governor, I
12 believe was some of the questions. I don't
13 remember the exact conversation.
14 But Jason Gonzalez asked me if I had an
15 ownership in Victory Strategies. And I was
16 already frustrated because of this previous
17 meeting about keeping blacks from voting. And I
18 said, I was angry, I responded very angrily to
19 him. I said, no, I don't have an interest in
20 Victory Strategies. I told him that for several
21 reasons.
22 One, he had been telling me all these rumors
23 going on about how this gang of five was going to
24 try to remove me from being Chairman. There were
25 also two people that were not part of RPOF in that
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1 meeting, and had no right to have the information
2 to that. I think that was Eric and Jim Rimes.
3 And I answered that question. And I also
4 told him in the context of that broader discussion
5 of all these accusations that were going around
6 that I did not have an interest in Victory
7 Strategies.
8 BY MR. LeBOEUF:
9 Q Okay. When did this conversation occur?
10 A I want to say it was in the --
11 MR. CHASE: Object to form. You didn't
12 answer the question. The original question was
13 when did you tell him that you had an interest in
14 Victory Strategies. And you said, you just said
15 that you did not.
16 THE WITNESS: When --
17 BY MR. LeBOEUF:
18 Q My question to you now is --
19 MR. CHASE: We can read --
20 MR. LeBOEUF: I am moving to strike as
21 non-responsive.
22 BY Mr. LeBoeuf:
23 Q I'm accepting your answer. The answer you
24 gave me was true, wasn't it?
25 A Yes.
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1 Q When was the communication with you and
2 Mr. Gonzalez where you told him and you were angry that
3 you did not have an ownership in Victory Strategies?
4 When did that occur?
5 A It was in, it was shortly after that meeting.
6 Him and I walked to the door together. We talked about
7 going to dinner that night. And I believe my wife was
8 in Tallahassee.
9 I told him that, I said, Jason, I do have a
10 interest in Victory Strategies. And he said that's not
11 a problem. No, he said, I don't think that's a
12 problem.
13 Q Hold on a second. You said that you were in
14 the meeting with Mr. Gonzalez, Mr. Rimes. You think,
15 Eric might have been there. Eric Eikenberg, right?
16 A Uh-huh.
17 Q And you were upset. You said in front of
18 those other people, Mr. Rimes and Eric, that Jason
19 Gonzalez asked you if you had an ownership interest in
20 Victory Strategies. And you said no.
21 A Correct.
22 Q All right. When was that meeting when you
23 said no?
24 A Oh, I'm sorry. I believe that meeting was in
25 September. I don't remember the exact date, to be
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1 honest with you.
2 Q It was 2009?
3 A Yeah, it was when, it was when, you know.
4 Q So September 2009, that's fine. When you
5 answer no, that wasn't truthful, was it?
6 A That's correct.
7 Q It is your testimony that after that meeting
8 when everybody else was gone, that you then told
9 Mr. Gonzalez that your earlier comment wasn't true?
10 A Right.
11 Q And that, in fact, you did have an ownership
12 interest?
13 A I said I have a part of Victory Strategies.
14 Q Okay. Did you say anything more than that?
15 A No.
16 Q Okay. By saying a part of Victory
17 Strategies, would it be safe for Mr. Gonzalez to assume
18 you were not the majority owner?
19 MR. CHASE: Object to form.
20 BY MR. LeBOEUF:
21 Q You didn't tell him you were a majority
22 owner, did you?
23 A Correct.
24 MR. CHASE: Object to form.
25 BY MR. LeBOEUF:
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1 Q And it is your testimony that he told you
2 that wasn't a problem?
3 A He said, I don't think that's a problem.
4 MR. CHASE: Object to form.
5 BY MR. LeBOEUF:
6 Q Did you have any other discussions with him
7 about you having any ownership interest in Victory
8 Strategies?
9 MR. CHASE: Object to form.
10 THE WITNESS: Not till he prepared the
11 severance agreement and included Victory
12 Strategies in the first two or three drafts of the
13 agreement.
14 MR. CHASE: Finally we get to the severance
15 agreement. I conclude objecting.
16 MR. LeBOEUF: Oh, I doubt that.
17 BY MR. LeBOEUF:
18 Q Let me do a little catching up with you.
19 MR. CHASE: Give me a second to read it.
20 (Brief recess.)
21 BY MR. LeBOEUF:
22 Q Back on. Mr. Greer, I've shown you another
23 document. Do you recognize that as a letter from
24 GrayRobinson to you dated February 13th, 2009?
25 A I do.
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1 Q Okay. The letter is written to you from
2 Richard Blau with the GrayRobinson firm?
3 A It is.
4 Q And in the first paragraph the letter
5 confirms your request that GrayRobinson, PA, represents
6 Victory Strategies, LLC, (Victory) in connection with
7 the above-referenced matter. Is that right?
8 A Yes.
9 Q Okay. And the scope of the representation
10 will be to provide assistance in the creation and
11 maintenance of a for-profit limited liability company
12 to do the business, to do business in Florida?
13 A That's correct.
14 Q This is a true and accurate copy of that
15 letter?
16 A It is.
17 Q Okay. And the letter was copied to John
18 Harris and William Boyles?
19 A It is.
20 Q This letter, this engagement, was never
21 shared with anyone with the Republican Party, other
22 than Delmar Johnson, was it?
23 MR. CHASE: Object to form.
24 THE WITNESS: It was not.
25 MR. LeBOEUF: Okay. If I could introduce
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1 this to your deposition as Exhibit 8.
2 (Whereupon, the document was marked as
3 Deposition Exhibit No. 8.)
4 BY MR. LeBOEUF:
5 Q Did you ever fulfill the request in Exhibit
6 No. 8 and sign and return this letter to Mr. Blau or
7 anyone with GrayRobinson?
8 MR. CHASE: Object to form.
9 THE WITNESS: Yes, I believe I did.
10 BY MR. LeBOEUF:
11 Q Okay. You think you signed it and returned
12 it?
13 A (Nodding head.)
14 Q What about the Victory Strategies bank
15 account?
16 MR. CHASE: Object to form.
17 BY MR. LeBOEUF:
18 Q Isn't it true that you -- I haven't finished.
19 MR. CHASE: There was a pause.
20 BY MR. LeBOEUF:
21 Q Isn't it true you directed Mr. Johnson to set
22 up the Victory Strategies bank account with SunTrust?
23 A No.
24 MR. CHASE: Object to form.
25 BY MR. LeBOEUF:
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1 Q Did Victory Strategies, LLC, maintain a bank
2 account with SunTrust?
3 MR. CHASE: Object to form.
4 THE WITNESS: Yes.
5 BY MR. LeBOEUF:
6 Q Okay. Whose decision was it that you use
7 SunTrust?
8 MR. CHASE: Object to form.
9 THE WITNESS: I don't recall. The Party had
10 an account there. I think I had a personal
11 account there. And I think Delmar might have had
12 a personal account there.
13 BY MR. LeBOEUF:
14 Q Didn't you tell Mr. Johnson to set up the
15 Victory Strategies account at SunTrust and direct him
16 to ask for Trisha Miller, the SunTrust employee that
17 you had a relationship with?
18 MR. CHASE: Object to form.
19 THE WITNESS: I might have. I don't recall.
20 BY MR. LeBOEUF:
21 Q If Mr. Johnson were to testify that you told
22 him to contact Trisha Miller at SunTrust and set up the
23 Victory Strategies account there, would he be lying?
24 MR. CHASE: Object to form.
25 THE WITNESS: I don't believe he would be
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1 lying. It may have occurred.
2 MR. LeBOEUF: Let me show you another
3 document which we will identify as Exhibit No. 9.
4 (Whereupon, the document was marked as
5 Deposition Exhibit No. 9.)
6 BY MR. LeBOEUF:
7 Q Do you recognize this to be the arrangement
8 between Victory Strategies, LLC, and SunTrust for the
9 establishment of Victory Strategies' account with
10 SunTrust?
11 MR. CHASE: Object to form.
12 THE WITNESS: I've never seen this document
13 before.
14 BY MR. LeBOEUF:
15 Q In reviewing Exhibit NO. 9 to your
16 deposition, the only authorized signatores on the
17 Victory Strategies account is Delmar Johnson, III,
18 correct? Actually, Delmar W. Johnson, III?
19 MR. CHASE: Object to form.
20 THE WITNESS: That's correct.
21 BY MR. LeBOEUF:
22 Q Do you have a majority interest in any other
23 corporation that you have ever been a part of, or that
24 you had ever formed, where you did not have check
25 writing authority on that company's bank accounts?
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1 MR. CHASE: Object to form.
2 THE WITNESS: I don't think I've ever been
3 advised by legal counsel to, that the managing
4 member was the only person that had to be listed,
5 as I was by GrayRobinson.
6 BY MR. LeBOEUF:
7 Q Is it your testimony that a counselor with
8 GrayRobinson told you that you could not or should not
9 have check writing authority with Victory Strategies,
10 LLC?
11 MR. CHASE: Object to form.
12 THE WITNESS: GrayRobinson told me the only
13 person who would need to be listed under an LLC
14 was the managing member.
15 BY MR. LeBOEUF:
16 Q I understand that, that the managing member
17 is the only person that has to be listed.
18 What I want to know is, have you ever had a
19 majority interest in any LLC or any other corporation
20 where you did not have check writing authority?
21 MR. CHASE: Object to form.
22 THE WITNESS: I don't believe so.
23 BY MR. LeBOEUF:
24 Q So out of all the corporations that you've
25 formed, all the companies that you have been the
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1 president of, all of the LLCs that you have been
2 associated with, this is the only time where you've had
3 a majority interest in the company and didn't have
4 check writing authority for the company.
5 MR. CHASE: Object to form.
6 THE WITNESS: This is the only time that
7 there has been a person that fulfilled Delmar
8 Johnson's role of managing the company, overseeing
9 all the financial aspects of the company.
10 I've never had a person that fulfilled a role
11 like Delmar Johnson did with Victory Strategies.
12 So the answer to the question is no.
13 MR. LeBOEUF: Okay. We'll attach that to
14 your deposition as Exhibit No. 9.
15 BY MR. LeBOEUF:
16 Q You've already testified regarding your
17 concerns in connection with Ms. O'Rourke and how you
18 felt that since she had been a fundraiser of RPOF, that
19 she wouldn't want to see you or Victory Strategies
20 being successful as a fundraiser, right?
21 MR. CHASE: Object to form.
22 THE WITNESS: Yes.
23 BY MR. LeBOEUF:
24 Q Okay. Your concerns about Ms. O'Rourke had
25 nothing to do with Victory Strategies' bank account,
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1 did it?
2 MR. CHASE: Object to form.
3 THE WITNESS: No.
4 BY MR. LeBOEUF:
5 Q So she couldn't do anything to find out or
6 discover about your interest in Victory Strategies just
7 by being included on the bank account, could she?
8 MR. CHASE: Object to form.
9 THE WITNESS: No, but I had no need to be on
10 the bank account because Delmar Johnson was the
11 managing member of the LLC.
12 MR. CHASE: He didn't ask you that.
13 THE WITNESS: I'm sorry.
14 BY MR. LeBOEUF:
15 Q And when GrayRobinson disclosed your interest
16 in Victory Strategies, you sued them, didn't you.
17 MR. CHASE: Object to form.
18 THE WITNESS: Yes.
19 BY MR. LeBOEUF:
20 Q Why did you sue them?
21 MR. CHASE: Object to form and privilege.
22 MR. LeBOEUF: You are instructing him not to
23 answer why he sued GrayRobinson?
24 MR. CHASE: That's between me and him on a
25 separate case. That has nothing do with this.
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1 That's privileged.
2 MR. LeBOEUF: That wasn't my question. Are
3 you instructing him not to answer?
4 MR. CHASE: I am saying you don't have to
5 discuss with him anything you discussed with me
6 that you reasonably believe was confidential about
7 the GrayRobinson case.
8 BY MR. LeBOEUF:
9 Q Let me rephrase the question, sir. I'm not
10 asking you about any communications you had with
11 Mr. Chase. Okay? I don't want to know anything about
12 your discussions with him.
13 I want to know why you -- without any
14 discussions, without you telling me anything that
15 Mr. Chase told you, I don't want to know what he told
16 you, other than that -- can you tell me why you sued
17 GrayRobinson?
18 MR. CHASE: Object to form.
19 THE WITNESS: I sought out GrayRobinson for
20 legal advice. GrayRobinson advised me that the
21 proper and lawful way to form Victory Strategies
22 was by forming an LLC.
23 They handled the entire process for me. And
24 then later, when anyone raised any impropriety
25 about Victory Strategies, they tried to distance
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1 themselves from the fact that they provided me
2 legal counsel.
3 They formed Victory Strategies. And I
4 believe that is a violation of my attorney-client
5 privilege.
6 I also believe it enhanced this outrageous
7 idea that I committed a crime. And that's why I
8 want to sue GrayRobinson -- not only for my own
9 personal relief, but I want all of their clients
10 to know that they will not hesitate to violate
11 attorney-client privilege if it protects their own
12 self-interest.
13 BY MR. LeBOEUF:
14 Q Okay. And it is your understanding then that
15 you were the client in the creation of Victory
16 Strategies?
17 MR. CHASE: Object to form.
18 THE WITNESS: Without exception.
19 BY MR. LeBOEUF:
20 Q Okay. So what role, if any, did Delmar
21 Johnson play in the relationship with GrayRobinson?
22 MR. CHASE: Object to form.
23 THE WITNESS: He became an administrative
24 person after, after I sought their legal advice,
25 after I had several communications with them,
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1 after they gave me counsel to form Victory
2 Strategies. He simply handled certain parts of
3 the administrative elements to it, but I was the
4 client.
5 BY MR. LeBOEUF:
6 Q Okay. And you were the client who directed
7 that your name not be associated with or connected with
8 any of the documents associated with Victory Strategies
9 in any public arena, correct?
10 MR. CHASE: Object to form.
11 THE WITNESS: I did not direct GrayRobinson.
12 They provided me legal counsel that an LLC does
13 not have to list all of its members.
14 BY MR. LeBOEUF:
15 Q Well, why would they direct you in that
16 regard if you hadn't asked them whether or not you
17 could establish the corporation without your name ever
18 appearing anywhere?
19 MR. CHASE: Object to form.
20 THE WITNESS: I asked them what type of legal
21 entity is best to be formed. And they recommended
22 an LLC.
23 BY MR. LeBOEUF:
24 Q Understood. Okay. But just by recommending
25 that you form an LLC, someone had to make a decision
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1 about whose name would be disclosed in connection with
2 the LLC; correct?
3 MR. CHASE: Object to form.
4 THE WITNESS: Yes.
5 BY MR. LeBOEUF:
6 Q And you had established multiple prior
7 corporations, prior LLCs, where your name always
8 appeared as a registered agent or as an initial member
9 of the Board of Directors, or as a managing member, in
10 all of the prior corporations you have been involved
11 in. We've already covered that in one of the exhibits
12 to your deposition, right?
13 MR. CHASE: Object to form.
14 THE WITNESS: Yes.
15 BY MR. LeBOEUF:
16 Q Okay. So someone had to come up with the
17 concern or suggestion that your name not appear
18 anywhere in any public forum associated with Victory
19 Strategies, right?
20 MR. CHASE: Object to form.
21 THE WITNESS: Yes.
22 BY MR. LeBOEUF:
23 Q Certainly the lawyers at GrayRobinson never
24 said, Mr. Greer, you should not put your name out
25 there. You should not disclosure your name. We need
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1 to conceal your name. That wasn't their idea, was it?
2 MR. CHASE: Object to form.
3 THE WITNESS: No. No, they did not.
4 BY MR. LeBOEUF:
5 Q You are the one who said, I would like to set
6 up this corporation, or this LLC, whatever you
7 recommend. And I don't want my name to appear anywhere
8 on the documents, right?
9 MR. CHASE: Object to form.
10 THE WITNESS: That wasn't how the
11 conversation occurred. However, Delmar suggested,
12 so that Meredith could not sabotage our
13 fundraising effort, that my name not appear. And
14 in communication with my attorneys, GrayRobinson,
15 they suggested forming an LLC.
16 BY MR. LeBOEUF:
17 Q And they said that if you don't want your
18 name to appear anywhere, we can set up an LLC. And we
19 can put everything in Delmar's name, and no one will
20 know that you have a majority interest in this LLC;
21 right?
22 MR. CHASE: Object to form.
23 THE WITNESS: No, that's not how their
24 response was. They told me, they simply said LLCs
25 do not have to list all of the individuals, and
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1 that would be the best way to go.
2 BY MR. LeBOEUF:
3 Q And then you understood that and took that to
4 mean that you could set up the LLC, put it all in
5 Delmar's name, and your involvement with Victory
6 Strategies wouldn't be available in the public eye
7 anywhere; correct?
8 MR. CHASE: Object to form.
9 THE WITNESS: Most importantly, wouldn't be
10 available to Meredith O'Rourke.
11 BY MR. LeBOEUF:
12 Q But you knew and set this up with the
13 assistance of counsel, you set up Victory Strategies so
14 that your name would not appear anywhere on any public
15 documents.
16 MR. CHASE: Object to form.
17 THE WITNESS: Yes.
18 BY MR. LeBOEUF:
19 Q Good. Going back to Exhibit 6, the
20 Fundraising Services Agreement. I don't intend go over
21 what we've already discussed.
22 You told me that you signed the agreement on
23 behalf of the RPOF, and that Mr. Johnson signed on
24 behalf of the consultant. I just want to make sure I
25 understand that this Fundraising Services Agreement was
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1 not reviewed or approved by Mr. Gonzalez or any other
2 legal counsel on behalf of RPOF; correct?
3 MR. CHASE: Object to form.
4 THE WITNESS: No, not at the time that it was
5 entered into. Mr. Gonzalez later became fully
6 aware that I was the owner of Victory Strategies,
7 but not at the time this agreement was entered
8 into.
9 BY MR. LeBOEUF:
10 Q We've established this agreement was entered
11 into in February, February 1st of 2009; right?
12 A Uh-huh.
13 MR. CHASE: Object to form.
14 BY MR. LeBOEUF:
15 Q And RPOF started paying fees to Victory
16 Strategies pursuant to this agreement, Exhibit No. 6,
17 shortly thereafter, right?
18 A Uh-huh.
19 MR. CHASE: Object to form.
20 BY MR. LeBOEUF:
21 Q Mr. Gonzalez had no idea about this contract
22 at that time, correct?
23 MR. CHASE: Object to form.
24 THE WITNESS: Correct, but the most important
25 person that did was my boss, the Governor of the
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1 state.
2 BY MR. LeBOEUF:
3 Q Is it your testimony that Charlie Crist knew
4 about this Fundraising Services Agreement between
5 Republican Party of Florida and Victory Strategies in
6 February of 2009?
7 MR. CHASE: Object to form.
8 THE WITNESS: Charlie Crist knew the content
9 of this agreement, but he did not know the legal
10 entity name Victory Strategies.
11 BY MR. LeBOEUF:
12 Q All Charlie Crist knew was that you were
13 going to start taking over fundraising responsibilities
14 for the Republican Party of Florida; right?
15 MR. CHASE: Object to form.
16 THE WITNESS: No.
17 BY MR. LeBOEUF:
18 Q He didn't know that?
19 A He knew that, but he also knew that I would
20 be paid a commission for doing so.
21 Q But he never knew and you never discussed
22 with him that you would be paid a commission through a
23 corporation or an LLC, Victory Strategies, because you
24 never discussed that with him.
25 MR. CHASE: Object to form.
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1 BY MR. LeBOEUF:
2 Q Correct?
3 A Correct.
4 Q Likewise, I think you just answered this.
5 You told me the only person with the Republican Party
6 of Florida who had any knowledge about your involvement
7 with Victory Strategies was Charlie Crist?
8 MR. CHASE: Object to form.
9 BY MR. LeBOEUF:
10 Q Is that right?
11 A There were persons who had knowledge that I
12 was taking over fundraising. I was going to be paid a
13 commission. That was Charlie Crist, Harry Sargeant at
14 this time. Jay Burmer knew I was going to be doing
15 fundraising. He was a confidant of the Governor. But
16 no one knew the legal entity name.
17 Q No one knew that you were going to be taking
18 those commissions through Victory Strategies?
19 A No, they might have thought --
20 MR. CHASE: Object to form.
21 THE WITNESS: -- I was just going to write
22 myself a check, personally, myself. They all
23 approved it. It was fine with them. They just
24 didn't know I was going to take it personally as a
25 check, I was going to put it through a
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1 corporation.
2 BY MR. LeBOEUF:
3 Q So as we sit here today, back in February of
4 2009, no one other than Delmar Johnson knew you would
5 be taking a commission for fundraising through Victory
6 Strategies; is that correct?
7 MR. CHASE: Object to form.
8 THE WITNESS: That's correct.
9 BY MR. LeBOEUF:
10 Q And it is your belief that the RPOF policies
11 and procedures did not obligate you to make a full
12 disclosure of this fact to Mr. Gonzalez, the General
13 Counsel?
14 MR. CHASE: Object to form.
15 THE WITNESS: It did not because I made a
16 full disclosure to the Governor and the head of
17 our Party, and to the Finance Chairman, that I
18 would be receiving fundraising -- I would be
19 taking over fundraising and receiving a
20 fundraising commission.
21 The reason Victory Strategies was entered
22 into is because I wanted to do it the right way.
23 I wanted to do it the lawful way. And that was to
24 enter into a contract and have it placed in the
25 files of RPOF.
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1 BY MR. LeBOEUF:
2 Q And you didn't think it would be right or
3 lawful to just do it straight up and say that you and
4 Delmar Johnson would be working together and doing
5 fundraising and taking a commission for it? You didn't
6 think that was right or lawful?
7 MR. CHASE: Object to form.
8 THE WITNESS: Counselor, fundraising is a
9 cutthroat business. And it is my belief that
10 Meredith O'Rourke would have interfered with our
11 ability to raise money for the Party.
12 Particularly, at that time when she was being
13 terminated. She was being ostracized from the
14 Governor.
15 She was very hostile. And it would have been
16 very difficult for us to be successful if we had
17 informed her of this fact.
18 MR. LeBOEUF: Sir, let me show you another
19 document. We will mark this as No. 10.
20 (Whereupon, the document was marked as
21 Deposition Exhibit No. 10. )
22 BY MR. LeBOEUF:
23 Q Do you recognize this as a Fundraising
24 Services Agreement proposed to Meredith O'Rourke's
25 company, Forward Strategies, Inc., in January of 2009?
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1 A I believe this is one of several that was
2 given to Ms. O'Rourke for consideration.
3 Q And this was prepared by you, right, or at
4 your direction?
5 A I believe so.
6 Q And the compensation in this agreement was a
7 flat fee of $5,000 per month to Ms. O'Rourke?
8 MR. CHASE: Object to form. You guys are
9 asking questions while I was reading. I objected
10 to those, as well, any questions about this
11 document for the same stated objection.
12 BY MR. LeBOEUF:
13 Q The rate of compensation for her was $5,000
14 per month?
15 MR. CHASE: Object to form.
16 THE WITNESS: Yes.
17 BY MR. LeBOEUF:
18 Q And there was no commission, correct?
19 MR. CHASE: Object to form.
20 THE WITNESS: Not in this agreement.
21 BY MR. LeBOEUF:
22 Q So in this agreement that you were proposing
23 to her, she was to get $5,000 per month with no
24 commission. So how would you receiving a commission
25 have anything to do with her?
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1 MR. CHASE: Object to form.
2 THE WITNESS: Because she would have, she was
3 known, had a reputation even prior to becoming the
4 RPOF fundraiser of interfering and hindering other
5 fundraisers from being successful.
6 The only reason that this $5,000 was offered
7 to her, knowing she would not perform any services
8 for it, nor did she, was the Governor directed,
9 Charlie directed that we pay her $5,000 a month to
10 keep the bitch's mouth shut.
11 BY MR. LeBOEUF:
12 Q I think you've already told me that. But you
13 would agree that by this agreement she wasn't being
14 compensated on a commission, so whether or not you
15 raised money or not wouldn't interfere with her
16 compensation whatsoever, would it?
17 MR. CHASE: Object to form. Dean, he has
18 answered that over and over today.
19 THE WITNESS: No.
20 BY MR. LeBOEUF:
21 Q Okay. This will be number 10 to your
22 deposition.
23 Now, this woman who you described as an
24 uncooperative bitch, I would like to --
25 A Not uncooperative.
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1 Q -- show you another document marked for
2 identification as Exhibit No. 11.
3 (Whereupon, the document was marked as
4 Deposition Exhibit No. 11.)
5 BY MR. LeBOEUF:
6 Q Do you recognize this as an e-mail from Ms.
7 O'Rourke to you on April 7, 2009?
8 MR. CHASE: Object to form.
9 THE WITNESS: I do. I don't recall it, but I
10 believe I remember this.
11 BY MR. LeBOEUF:
12 Q You received it, didn't you?
13 A Well, it was sent to John Rood, who was the
14 Finance Chairman at the time. I see that it was cc'd
15 to me.
16 Q Okay, because your e-mail at the time was
18 A Yes.
19 Q You did, in fact, received it on that date,
20 didn't you?
21 A I don't recall.
22 MR. CHASE: Object to form.
23 BY MR. LeBOEUF:
24 Q And in this e-mail doesn't Ms. O'Rourke say,
25 "Good morning, Chairmen! I just thought I would reach
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1 out directly to both of you regarding upcoming events,
2 et cetera. I've requested updates in terms of
3 coordination of calls, event pledges, et cetera from
4 staff, but haven't received any updates to date. Just
5 wanted to offer a helping hand with any events,
6 leadership calls, et cetera. Please just let me know
7 what I can do to help. Would love to be part of
8 anything you have coming up."
9 And then she lists her cell number, and all
10 the best, Meredith. Right?
11 MR. CHASE: Object to form.
12 THE WITNESS: She does.
13 BY MR. LeBOEUF:
14 Q Okay. Doesn't this correspondence reflect
15 her willingness to cooperate and assist in any way in
16 fundraising?
17 MR. CHASE: Object to form.
18 THE WITNESS: It does not.
19 BY MR. LeBOEUF:
20 Q Okay. How do you take this e-mail?
21 A I take it as a bunch of words on a piece of
22 paper.
23 Q So you don't think it is the truthful?
24 A No.
25 MR. CHASE: Object to form.
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1 BY MR. LeBOEUF:
2 Q Do you think she drafted this e-mail with the
3 idea that it would be an exhibit to your deposition to
4 refute your testimony?
5 MR. CHASE: Object to form.
6 THE WITNESS: I don't recall exactly the time
7 frame, but I think she probably drafted it to keep
8 getting her $5,000 and to, to demonstrate that she
9 was still active.
10 MR. LeBOEUF: I will attach that to your
11 deposition as Exhibit 11.
12 BY MR. LeBOEUF:
13 Q Going back to Exhibit No. 6, your Fundraising
14 Services Agreement where you signed on behalf of RPOF
15 and Mr. Johnson signed for Victory Strategies, LLC.
16 Were you concerned at all that by executing
17 this agreement you were violating your Republican Party
18 of Florida oath of loyalty?
19 MR. CHASE: Object to form.
20 THE WITNESS: No. Actually I thought I was
21 saving the Republican Party about $250,000 a year.
22 And that I, in fact, was going to be able to
23 implement various fundraising programs that
24 Meredith had obstructed in the past.
25 BY MR. LeBOEUF:
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1 Q Okay, good. Let's talk about that. It is
2 your testimony that when you signed the agreement on
3 February 1st, 2009, between RPOF and Victory
4 Strategies, that you would be saving the Party $250,000
5 a year?
6 MR. CHASE: Object to form.
7 THE WITNESS: Well, she was making $30,000 a
8 month. So that was, that was $360,000 a year
9 before the Governor told me to give her the $5,000
10 a month contract.
11 BY MR. LeBOEUF:
12 Q Okay. But when you signed the agreement in
13 February of 2009, Exhibit No. 6 to your deposition, her
14 contract had already been terminated. She wasn't
15 making $30,000 a month then, was she?
16 A I don't remember when we terminated her
17 contract because we offered her a $15,000 a month
18 contract that she declined. Then I brought her back
19 in.
20 MR. CHASE: Listen to the question.
21 BY MR. LeBOEUF:
22 Q You offered her a $15,000 a month contract
23 that she declined; but she didn't keep getting 30,000 a
24 month, did she?
25 MR. CHASE: Object to form.
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1 THE WITNESS: I don't recall when the 30,000
2 a month contract ended.
3 BY MR. LeBOEUF:
4 Q Let's look at Exhibit No. 10 to your
5 deposition, when you offered her $5,000 a month with no
6 commission in January of 2009. She certainly wasn't
7 still getting 30,00 a month then, was she?
8 MR. CHASE: Object to form.
9 THE WITNESS: I don't believe this agreement,
10 I don't know when the last $30,000 a month payment
11 was to her; because it was my hope that we could
12 terminate the whole relationship, but the Governor
13 wanted to keep paying her something.
14 BY MR. LeBOEUF:
15 Q Do you have any reason to believe that the
16 documents maintained by the Republican Party of Florida
17 showing when they made her last $30,000 payment was
18 inaccurate?
19 MR. CHASE: Object to form.
20 THE WITNESS: Inaccurate may not be the case;
21 but when I left, it was my understanding that she
22 was telling the Party she was owed money still.
23 BY MR. LeBOEUF:
24 Q Okay, but as you sit here today, you don't
25 know when her last $30,000 payment was made?
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1 A No, I don't.
2 MR. CHASE: Object to form.
3 BY MR. LeBOEUF:
4 Q And you have no reason to believe that the
5 documents maintained by the Party are inaccurate with
6 regards to when she was paid the last $30,000 monthly
7 stipend, do you?
8 MR. CHASE: Object to form.
9 THE WITNESS: I don't know.
10 BY MR. LeBOEUF:
11 Q Now, Mr. Johnson, Delmar Johnson, did he have
12 any fundraising experience prior to his employment by
13 the Party?
14 MR. CHASE: Object to form.
15 THE WITNESS: He had been very active in
16 fundraising for Governor Crist during the
17 gubernatorial campaign. And I believe he had done
18 other fundraising for other entities. He had a
19 very good personable personality that helped raise
20 money.
21 BY MR. LeBOEUF:
22 Q When did you first meet him?
23 MR. CHASE: Object to form.
24 THE WITNESS: 2006.
25 BY MR. LeBOEUF:
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1 Q In what context?
2 MR. CHASE: Object to form.
3 THE WITNESS: He was the Director of Field
4 Operations for the Charlie Crist for Governor
5 campaign.
6 BY MR. LeBOEUF:
7 Q For the whole state?
8 A No.
9 MR. CHASE: Object to form.
10 BY MR. LeBOEUF:
11 Q Who made the decision to hire him at RPOF?
12 MR. CHASE: Object to form.
13 THE WITNESS: At RPOF? Initially that was
14 George LeMieux.
15 BY MR. LeBOEUF:
16 Q Who actually hired him?
17 MR. CHASE: Object to form.
18 THE WITNESS: I did.
19 BY MR. LeBOEUF:
20 Q So you are saying you hired him on George
21 LeMieux's recommendation?
22 MR. CHASE: Object to form.
23 THE WITNESS: When I was running for
24 Chairman, George wanted him to be my assistant.
25 So he became an RPOF employee during that period
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1 of time. Then when I got elected Chairman, he was
2 made a full-time employee of RPOF.
3 BY MR. LeBOEUF:
4 Q In what position?
5 MR. CHASE: Object to form.
6 THE WITNESS: He was initially, I think he
7 had the title of Deputy Director. Yeah, Deputy
8 Director.
9 BY MR. LeBOEUF:
10 Q And then when you were elected Chairman, at
11 some point you hired him as your Executive Director?
12 A No. He was promoted.
13 MR. CHASE: Object to form.
14 THE WITNESS: He was promoted to Deputy
15 Assistant -- Deputy Executive Director and served
16 in that for a year. And then he became Executive
17 Director when I was the Chairman, my second term.
18 BY MR. LeBOEUF:
19 Q To your knowledge, did Mr. Johnson have any
20 other fundraising experience, other than working as the
21 director of -- Field Director for Charlie Crist's run
22 for Governor?
23 MR. CHASE: Object to form.
24 THE WITNESS: I think he raised money for
25 FSU, too, when he was -- something to do
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1 affiliated with FSU.
2 BY MR. LeBOEUF:
3 Q Was there anything else about Delmar
4 Johnson's experience that you felt qualified him to
5 take on a role as a fundraiser for RPOF?
6 MR. CHASE: Object to form.
7 THE WITNESS: Yes, he had a very good
8 personality. People enjoyed being with him. He
9 was always kind of a fun, jovial kind of guy. And
10 people were always willing to write checks if
11 Delmar showed up and asked them.
12 BY MR. LeBOEUF:
13 Q So did he raise any money for RPOF before
14 Victory Strategies?
15 MR. CHASE: Object to form.
16 THE WITNESS: It wasn't his primary function.
17 BY MR. LeBOEUF:
18 Q I didn't ask you that. Did he raise any
19 money for RPOF before he got involved with Victory
20 Strategies?
21 A No, that was primarily Meredith's bailiwick.
22 He might have gone and picked up checks if she asked
23 him to pick up checks.
24 Q So if he were to testify he was engaged in
25 fundraising for the Party and he did raise funds for
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1 the Party prior to Victory Strategies, that would not
2 be truthful?
3 MR. CHASE: Object to form.
4 THE WITNESS: I don't whether it would be
5 truthful or not.
6 BY MR. LeBOEUF:
7 Q Did you do any fundraising, other than what
8 we talked about today, for RPOF before Victory
9 Strategies?
10 MR. CHASE: Object to form.
11 THE WITNESS: In a limited manner, yes.
12 BY MR. LeBOEUF:
13 Q Anything other than what we've already talked
14 about today?
15 MR. CHASE: Object to form.
16 THE WITNESS: I would make phone calls at
17 times.
18 BY MR. LeBOEUF:
19 Q To individuals?
20 MR. CHASE: Object to form.
21 THE WITNESS: Meredith would give me a list
22 to call.
23 MR. CHASE: Object to form.
24 BY MR. LeBOEUF:
25 Q You would call people and ask for money?
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1 MR. CHASE: Object to form.
2 THE WITNESS: Yes.
3 BY MR. LeBOEUF:
4 Q Now, when you did that, Meredith gave you a
5 list and you called people and asked for money, did
6 Meredith get any commission for any of those funds that
7 you raised?
8 MR. CHASE: Object to form.
9 THE WITNESS: I believe during that time it
10 was, I believe that she -- I don't remember
11 what -- there was a $30,000 contract with
12 Meredith. Then there was some other incentives.
13 I don't recall during those time frames what
14 Meredith's contract was.
15 The only thing I do recall is Richard Swartz
16 as CFO coming down a regular basis stressed out
17 that we have to pay Meredith O'Rourke her $30,000.
18 BY MR. LeBOEUF:
19 Q Right, because when she was getting $30,000 a
20 month, she did not get a commission on top of that, did
21 she, from RPOF?
22 MR. CHASE: Object to form.
23 THE WITNESS: I don't recall.
24 BY MR. LeBOEUF:
25 Q Did you ever tell anyone that allowing
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1 Mr. Johnson to take over fundraising would save RPOF
2 money?
3 MR. CHASE: Object to form.
4 THE WITNESS: I don't recall.
5 BY MR. LeBOEUF:
6 Q Did you ever make the statement to anyone
7 that Mr. Johnson was going to take a big pay cut, and
8 that is why you were giving him the fundraising
9 contract?
10 MR. CHASE: Object to form.
11 THE WITNESS: No.
12 BY MR. LeBOEUF:
13 Q Do you know what Mr. Johnson's starting
14 salary was with RPOF?
15 MR. CHASE: Object to form.
16 THE WITNESS: I know what it was supposed to
17 be.
18 BY MR. LeBOEUF:
19 Q What's that?
20 MR. CHASE: Object to form.
21 THE WITNESS: His starting with RPOF?
22 BY MR. LeBOEUF:
23 Q Yes.
24 A I don't know. No. I don't know what that
25 was.
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1 Q If the records show that his starting salary
2 was to be $68,000 a year, do you have any documents or
3 information to dispute that?
4 MR. CHASE: Object to form.
5 THE WITNESS: No.
6 BY MR. LeBOEUF:
7 Q Do you know what he was doing or how much
8 money he was earning before he went to work for RPOF?
9 MR. CHASE: Object to form.
10 THE WITNESS: There was a, when he came over
11 from where he was to the Crist campaign, and then
12 there was an issue about he wanted to make a
13 certain amount of money, and I don't remember.
14 BY MR. LeBOEUF:
15 Q Did he come directly from the Crist campaign
16 to RPOF?
17 A Yes.
18 MR. CHASE: Object to form.
19 BY MR. LeBOEUF:
20 Q And was he a paid consultant or employee of
21 the Crist campaign?
22 MR. CHASE: Object to form.
23 THE WITNESS: Yes.
24 BY MR. LeBOEUF:
25 Q But --
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1 A I believe so.
2 Q But you don't know what he earned in that
3 position?
4 A No.
5 MR. CHASE: Object to form.
6 BY MR. LeBOEUF:
7 Q Is that correct?
8 A Yes.
9 Q If the RPOF records show that Mr. Johnson was
10 elevated to the position of Deputy Executive Director
11 on January 1st, 2008, with a salary of $80,000, do you
12 have any records or information to dispute that?
13 MR. CHASE: Object to form.
14 THE WITNESS: No.
15 BY MR. LeBOEUF:
16 Q The RPOF records then seem to indicate his
17 base salary was to be cut effective August 1st, 2008,
18 to $65,000 a year.
19 Do you know if that reduction ever occurred?
20 MR.
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