officer x5 - deposition transcript (federal) - redacted

Jeremy Freeman , March 14, 2014Paul Murphy v. Whatcom County

3206 Wetmore, Suite 12, Everett, WA 98201BMA Court Reporters 425-252-7277

UNITED STATES OF DISTRICT COURT

WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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PAUL MURPHY, together with his ) marital community, ) Plaintiffs, ) ) vs. ) NO. 2:13-CV-00727 ) WHATCOM COUNTY, WASHINGTON, a ) government entity; WHATCOM COUNTY ) SHERIFF'S DEPARTMENT; WILLIAM J. ) ELFO, together with his marital ) community, ) Defendants. ) ---------------------------------------------------------------

DEPOSITION UPON ORAL EXAMINATION OF JEREMY FREEMAN

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3:40PM - 4:15PM March 14, 2014 Whatcom County Courthouse 311 Grand Avenue Bellingham, Washington 98225

Reported by Kristen M. Uhlig Certified Court Reporter, CCR, CSR

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1 A P P E A R A N C E S

2

3 FOR THE PLAINTIFFS:Emily Beschen

4 Law Offices of Robert Butler103 East Holly Street Suite 512

5 Bellingham, Washington 98225360.734.3448

6

7 FOR THE DEFENDANTS WHATCOM COUNTY & SHERIFF'S DEPARTMENT & ELFODale Kamerrer

8 Law Lyman Daniel Kamerrer Bogdanovich2674 RW Johnson Blvd SW

9 Tumwater, Washington 98512360.754.3480

10

11 FOR WHATCOM COUNTY:Elizabeth Gallery

12 Whatcom County Prosecutor's Office311 Grand Avenue

13 Bellingham, Washington 98225

14ALSO PRESENT:

15 William ElfoTara Adrian-Stavik

16

17 I N D E X

18 EXAMINATION: PAGE

19 BY MS. BESCHEN...............................................3

20 BY MR. KAMERRER.............................................22

21

22 EXHIBIT DESCRIPTION PAGE

23 62....Whatcom County Sheriff's Memorandum re: Deputies......21

24

25

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1 JEREMY FREEMAN,

2 having been first duly sworn, was called as a witness herein and

3 was examined and testified as follows:

4

5 DIRECT EXAMINATION

6

7 BY MS. BESCHEN:

8 Q Can you please state your full name for the record?

9 A Jeremiah James Freeman.

10 Q Mr. Freeman, where are you currently employed?

11 A Lynden Police Department.

12 Q Prior to the Lynden Police Department, where were you employed?

13 A The Whatcom County Sheriff's Office.

14 Q What was your position at the Whatcom County Sheriff's Office?

15 A As a deputy sheriff.

16 Q And what years were you with Whatcom County for?

17 A 2001 to 2013.

18 Q During your time at the Whatcom County Sheriff's Office, did

19 you hold any special assignments?

20 A I did.

21 Q What special assignment did you have?

22 A I was in the K9 unit. I was assigned SRT, Special Response

23 Team. I was a first aid instructor and assigned to the Honor

24 Guard.

25 Q Okay. During your time at the Whatcom County Sheriff's Office,

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1 did you ever have any part in any internal investigations?

2 A Yes.

3 Q How many times?

4 A I don't know. I was there for 12 years, a lot of internals got

5 done.

6 Q Were you ever involved in any internal investigations into

7 Kevin Mede?

8 A I don't know what they called -- right before I left, they did

9 an administrative inquiry. I don't know if they're calling

10 that an internal or an admin inquiry.

11 Q Sure. Fair enough. Were you interviewed in connection with

12 that internal or administrative whatever type of investigation

13 that that was labeled as?

14 A I was.

15 Q Do you know how many times you were interviewed?

16 A Once.

17 Q Who interviewed you?

18 A I think that it was Chief Chadwick and Lieutenant Rossmiller.

19 Q Do you recall whether that interview was recorded?

20 A I don't believe so.

21 Q During that interview, do you recall what the topics they were

22 asking you about included?

23 A I think that they asked me if I had any information on whether

24 or not Kevin Mede had done anything to -- I think they asked if

25 it was Brady material, anything that I had any knowledge of

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1 that he had done.

2 Q Do you recall what your response was?

3 A I -- I don't recall my exact response. I didn't write it down

4 or keep a recording of it. I don't think that I knew of

5 anything that was Brady material on Kevin Mede at that point in

6 time, no.

7 Q What does Brady material mean to you?

8 A Information where you have been -- well, what it means to me?

9 Well, there have been a time or two when I've had

10 attorneys in criminal cases -- Mr. Butler was one of them. I

11 believe that he brought it up that I had been Brady'ed in a

12 suppression hearing where he was trying to get some evidence

13 suppressed.

14 So my understanding of that is that they think that

15 you're a liar and they don't want anything that you have to say

16 to be admissible. You can no longer be a police officer

17 because you're not trusted to testify in court.

18 Q Prior to that situation with Mr. Butler, did you have a

19 different understanding of Brady material?

20 A No. That's about it.

21 Q Okay. So going back to the investigation of whatever type of

22 investigation it was into Kevin Mede, did you give any

23 information to Chadwick and Rossmiller that you knew about

24 Kevin Mede's activities?

25 A I think that they asked me if I had any knowledge of whether or

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1 not he had lied and I brought up that, you know, we were

2 involved in guild activities together. And it had -- it was

3 guild related material that had nothing to do with actual

4 police work, and that he had been untruthful with me.

5 Q Okay. So my next question, which I think that you just in part

6 answered: Has Kevin Mede ever lied to you?

7 MR. KAMERRER: I object to the form of the question.

8 It's argumentative, calls for speculation, and calls for

9 hearsay. Go ahead.

10 Q (By Ms. Beschen) So throughout the deposition -- I didn't go

11 through all of the rules -- he may object and you still can

12 answer the question afterwards. He's just making a record for

13 the transcript.

14 A Okay. Can you ask the question again?

15 Q Yes. Has Kevin Mede ever lied to you?

16 MR. KAMERRER: Same objection, but go ahead.

17 THE WITNESS: I believe he has, yes.

18 Q (By Ms. Beschen) Okay. Can you tell me about that time that

19 you believe that he has lied to you?

20 A It's -- I don't know if I can disclose it because it has to do

21 with guild activities from other employees. I -- it's been two

22 or three years now, so I don't recall all of the detail of it.

23 But, yes, I believe that he's lied to me.

24 Q Okay. We've -- I think your deposition No. 25 or 26 throughout

25 this week. So we have heard from other people that he had made

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1 statements trying to pass a social media policy through the

2 guild. Is that what you're referring to or is this a different

3 instance?

4 A That would be the one.

5 Q Okay. Now, having me said that, does that help refresh your

6 memory at all into what the situation was with Kevin Mede and

7 the social media policy in the guild activities?

8 A It does.

9 Q Okay. Can you tell me what you recall about that social media

10 policy?

11 A I don't remember much detail of it.

12 Q Do you recall what Kevin Mede said to you that makes you

13 believe that he lied?

14 A Just that he -- at that point in time, I believe that he was

15 the guild president. I believe that he came to us as the guild

16 executive board and said that the -- that the staff was trying

17 to push the social media policy through. And that he went to

18 them and he told them no -- but...

19 Q When he said that the staff was trying to push the social media

20 policy through, who did you understand the staff to include?

21 A I believe that it was Undersheriff Parks was the only one that

22 was brought up.

23 Q Can you give me as much background as you're aware of, of how

24 does a policy like that go through the guild? What's the

25 guild's responsibility in policies?

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1 A Basically, if the staff develops a new policy for the office,

2 they generally will before it's enacted, they'll notify the

3 guild, hey, we're coming up with the new schedule policy or

4 whatever it may be. And then they send it to the guild to see

5 if they have any issue with it. And then if there's no

6 objection or even if there is -- I mean, my understanding is

7 that they can still enact a policy and, you know, the guild can

8 object and fight it later on.

9 Q Okay. So when a policy comes to the guild, do all of the

10 members vote or are there a certain number of members who vote

11 or how does that work?

12 A I think that it depends on what it's -- what's being voted on

13 or what -- there are things where you need the general

14 membership of the guild to vote on and there are things that

15 the executive board can vote on and make a decision.

16 Q Okay. At that time, do you recall whether Kevin Mede was the

17 guild president or not?

18 A I don't. I think that he might have been, but I don't recall.

19 Q Any other statements that you recall telling Chadwick and

20 Rossmiller in the investigation into Mede about lies that he

21 told to you, yourself?

22 A I don't recall off the top of my head.

23 Q Have you heard rumors or talked to anybody else who has worked

24 in the Whatcom County Sheriff's Department, either now or in

25 the past, who has been told a lie by Kevin Mede?

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1 MR. KAMERRER: Object. Calls for speculation, calls

2 for hearsay. You can answer.

3 THE WITNESS: Yeah. I mean, we -- it's a close group

4 of people and you talk to them and -- yeah. I've talked to

5 many people. I've heard gossip and all of that stuff. But do

6 I recall specific details of what people have said? No, I

7 don't.

8 Q (By Ms. Beschen) Okay. Do you believe that you have worked

9 enough with Sergeant Mede in order to form an opinion as to his

10 reputation for truthfulness? Does that question make sense?

11 A Ask it again?

12 Q Okay. Do you have an opinion as to Kevin Mede's reputation for

13 truthfulness?

14 A I do.

15 Q What is your opinion of his truthfulness?

16 A My opinion is that he is a liar and a coward.

17 Q Other than the situation that we just talked about with the

18 guild and the social media policy, are there -- what other

19 circumstances or situations have there been that have caused

20 you to form that opinion about Kevin Mede?

21 MR. KAMERRER: Objection, asked and answered.

22 THE WITNESS: It's -- I have known Kevin for, 10 to 15

23 years. I mean, we've been friends. We have worked together.

24 I don't recall specific details of all of the conversations

25 that we have had over the years.

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1 Q (By Ms. Beschen) At any point during your time at the Whatcom

2 County Sheriff's Office, were you ever -- I guess, do you guys

3 have partners at any point? Do you work on cases together?

4 A It differs everyday.

5 Q Okay.

6 A I mean, you go to calls with different deputies all of the

7 time.

8 Q Okay. Has there been a point during the time that you were at

9 the Whatcom County Sheriff's Office where you knew Kevin Mede

10 to lie in a police report?

11 A No.

12 Q Was there ever a point where Kevin Mede directed or encouraged

13 you to lie in a police report?

14 A No.

15 Q Was Kevin Mede your supervisor when you were at the Whatcom

16 County Sheriff's Office?

17 A It would depend. My direct supervisor was the K9 supervisor

18 until I left, but I would work -- I worked split between a

19 swing shift and a graveyard, so I would work for four different

20 supervisors at different times throughout my work week.

21 Q Okay. Who was the K9 supervisor?

22 A Larry Flynn.

23 Q And did you believe Flynn to be credible?

24 A Yes.

25 Q Did you ever work under Sean Crisp?

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1 A Yes.

2 Q Did you believe Sean Crisp to be truthful and credible?

3 A Yes.

4 Q What about Beth Larson? Did you ever work with Beth Larson?

5 A I did.

6 Q Were you able to form a reputation as to Beth Larson's

7 truthfulness?

8 A Yes.

9 Q What is your opinion about Beth Larson's truthfulness?

10 A I believe that she's a liar and a coward.

11 Q Can you recall any circumstances where Sergeant Larson has lied

12 to you?

13 A Lied to me? No.

14 Q Any circumstances where you have observed her lie to others?

15 A Yes.

16 Q Can you explain those circumstances to me?

17 A I had a log entry that she wrote about me that was about

18 two-and-a-half pages that I would say about 90 percent of it

19 was a complete and total lie.

20 Q Do you recall approximately what year that occurred?

21 A 2011 or 2012.

22 Q And what was the log entry regarding?

23 A She sent me an e-mail. It was about -- she called me out for

24 violating several policies in the e-mail and it was CC'ed to

25 the K9 supervisor Flynn.

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1 So I went to her and I asked her why she sent me an

2 e-mail as opposed to coming and talking to me. She wouldn't

3 look me in the eye at that point in time. When I asked her

4 questions, I was told that I needed to mind my own business.

5 I mean, we had a brief conversation that -- it was at

6 one of the substations. I got called in the next night and I

7 believe that it was her and Kevin Mede that were in there. I

8 got confronted and they tried baiting me into going off.

9 And then the next thing that I know, about a year later

10 when I was getting my employee evaluation, I see in the

11 evaluation that I'm being rated substandard on certain

12 categories. And this log entry that she wrote is being

13 referenced, but it was not attached to the evaluation. So I

14 had to ask for it.

15 And when it was given to me, I read it. Like I said,

16 about 90 percent of it, the things that she put in there, were

17 false.

18 Q Can you recall specifically any of the statements that she made

19 in that log entry which were false?

20 A I guess the part that was shocking to me is that I was

21 described in that log entry as one would describe a suspect

22 that's about ready to attack an officer and that did not

23 happen. I believe that she made some comment about

24 insubordination or something like that and that -- the comments

25 that she made about that were not true.

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1 Q Among the co-workers that you had at Whatcom County Sheriff's

2 Office, roughly how many of them do you think would share your

3 opinion that Beth Larson is not credible and truthful?

4 MR. KAMERRER: I just want to insert an objection that

5 that calls for speculation and hearsay. Go ahead.

6 THE WITNESS: I don't know how many people would share

7 that one.

8 Q (By Ms. Beschen) Do you know how long Beth Larson has been a

9 sergeant for?

10 A Since maybe 2010 or 2011, somewhere around there.

11 Q What about Kevin Mede? Do you know how long he's been a

12 sergeant for?

13 A I don't, maybe five or six years. I don't know.

14 Q Okay. Do you have any knowledge as to whether or not Beth

15 Larson supported Sheriff Elfo in the election?

16 A I believe that she did.

17 Q Do you have any knowledge as to whether Kevin Mede supported

18 Bill Elfo in the election?

19 A I don't.

20 Q Are you aware of any internal or administrative or any level of

21 investigations into Beth Larson's credibility at the Whatcom

22 County Sheriff's Office?

23 A Not that I'm aware of.

24 Q Are you aware of whether anybody has ever made complaints about

25 Beth Larson being untruthful to the Whatcom County Sheriff's

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1 Office?

2 A Can you ask the question again, please?

3 Q Are you aware of any complaints that have been made to the

4 Whatcom County Sheriff's Office about Beth Larson's

5 truthfulness? And by complaint, I mean, broad -- not some sort

6 of written formal complaint.

7 A Yes.

8 Q What complaints are you aware of?

9 A I made a, you know, I went and spoke to supervisors in

10 reference to the log entry and then I talked to another deputy

11 who shared a similar experience.

12 Q Who was that deputy that shared a similar experience?

13 A Oaks.

14 Q Did you ever speak with Sheriff Elfo about it?

15 A About Deputy --

16 Q Deputy Larson?

17 A Oaks?

18 Q About Beth Larson. Sorry.

19 A Yes, I did.

20 Q Do you recall when that was?

21 A It was right before I left the sheriff's office.

22 Q Did you provide Sheriff Elfo any information about Beth

23 Larson's credibility or truthfulness during that meeting?

24 A I told him about my log entry and he said that he would look

25 into it.

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1 Q Do you know whether he ever looked into it or not?

2 A I don't. I wasn't -- it wasn't a -- I think it was right

3 before I left the sheriff's office, so I didn't check to see if

4 he checked into it.

5 Q Okay. Did you resign from the sheriff's office?

6 A I quit to go work somewhere else.

7 Q Okay. Was that due to issues that you had with Larson or Mede?

8 A Yes.

9 Q Do you know if you or others thought that Larson and/or Mede

10 were protected by Sheriff Elfo?

11 A I don't know that.

12 Q Has the sheriff's office ever done any sort of internal

13 investigation into you for telling a lie?

14 A Mm-hm.

15 Q Do you recall when that was?

16 A I think that it was after 2009. I had been sued. The Justice

17 Department did a -- came and did a big investigation on me and

18 the prosecutor's office was involved and the sheriff's office

19 supplied them with information. I think that they checked all

20 my computers and I was not found to have been untruthful.

21 Q Okay. At any point during your career at the Whatcom County

22 Sheriff's Office, were you ever directed by anybody from the

23 prosecuting attorney's office to lie?

24 A No.

25 Q During your time at Whatcom County Sheriff's Office, were you

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1 ever directed by anybody within the sheriff's department to

2 lie?

3 A No.

4 Q Were you ever encouraged to lie?

5 A No.

6 Q Did you ever enter into any sort of stipulation at the

7 direction or encouragement of Deputy Watts and -- Deputy

8 Prosecuting Attorney Watts, I think.

9 MR. KAMERRER: I'll insert an objection that it calls

10 for a legal conclusion.

11 Q (By Ms. Beschen) Do you know what a stipulation is?

12 A Yes. But can you ask the question again?

13 Q Were you ever asked to enter into any sort of stipulation with

14 Randy Watts or by Randy Watts?

15 A By Randy Watts.

16 MR. KAMERRER: Same objection.

17 Q (By Ms. Beschen) And what stipulation did Randy Watts ask you

18 to enter into?

19 A He -- I don't believe that we entered into a stipulation. He

20 -- it was in reference to a lost boot with Brian Wiederspohn

21 over the stairs versus ramp. He told the other deputy and I

22 that we were going to lose the case and that nobody believed us

23 that there was stairs there.

24 I was not willing to concede that there was not stairs

25 there because that's what I saw that day that we were there

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1 and, yeah. On the stand, I did not -- I did not concede that

2 there was a ramp there.

3 My testimony and what I truly believe to this day was

4 that we were standing on stairs. But the fact that I didn't

5 have photographs of those stairs and the fact that they had

6 about 50,000 photos of stairs and apparently everybody coming

7 out of the woodworks testifying to it.

8 I said, hey, you guys have proven in your case -- you

9 have shown proof. We don't have any proof other than our word.

10 So that was my testimony on that and that was what I recall of

11 that.

12 Q With regards to the testimony that you're speaking about right

13 now, was that in the criminal case or the civil case?

14 A The civil case.

15 Q Before you testified in the civil case, did Randy Watts direct

16 you as to what your testimony needed to be?

17 A No. I had not discussed it with him prior to the civil case.

18 Q Okay. Did you ever discuss your testimony with Sheriff Elfo?

19 A About the civil case?

20 Q Yes.

21 A Yes.

22 Q Did he give you any advice or direction as to what your

23 testimony needed to be?

24 A No. This was after the civil case was done that I spoke to

25 Sheriff Elfo.

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1 Q Okay. After the civil case was done and you spoke with Sheriff

2 Elfo, what about the case did the two of you discuss?

3 A I discussed with him that if I was a liability or if it was

4 ever a point in time where I was -- if he felt that I was

5 dragging the sheriff's office down, that he would just have to

6 say the word and I would step down.

7 Q Did he ask you to step down?

8 A No.

9 Q Did you at any point believe that Sheriff Elfo wanted you to

10 step down?

11 A No.

12 Q Did you believe that Beth Larson did not want you to be working

13 at the Whatcom County Sheriff's Office?

14 A I don't know that.

15 Q Who did you support in the 2011 election?

16 A That's my political preference.

17 Q Did you openly support anybody for sheriff in the 2011

18 election?

19 A You mean standing on a street corner?

20 Q No. Did you tell other people who you would be voting for

21 within the Whatcom County Sheriff's Office?

22 A Some close friends and maybe some family. I didn't -- I am not

23 a very political person. I did not get involved in any of the

24 political stuff in the department.

25 Q Okay. Did you endorse any candidate?

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1 A What do you mean endorse?

2 Q Apparently, there's some formal endorsements that people can

3 fill out and --

4 A I did not fill out any formal endorsements.

5 Q Did you donate money to any of the candidates?

6 A I don't know if my wife made a donation, but I know the sheriff

7 has different, what is it, I believe it's Pass The Hat that the

8 sheriff is involved in. My wife contributes money to that.

9 Q Who of the people that we have talked about have you -- is

10 there anybody currently working at the Whatcom County Sheriff's

11 Department whose credibility is in question to you?

12 MR. KAMERRER: Objection. Vague and overbroad, calls

13 for speculation.

14 Q (By Ms. Beschen) Does that question make sense?

15 A Yes.

16 Q Do you want me to re-ask it?

17 A No. Other than -- other than Beth and Kevin, I'm not concerned

18 about anybody else's credibility.

19 Q Did you ever work with Paul Murphy?

20 A I did.

21 Q Did you work with him enough to form an opinion as to his

22 credibility?

23 A I did.

24 Q Do you believe him to be a credible officer?

25 A I do. Your previous question about the endorsements. I had a

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1 sign in my front yard for a candidate.

2 Q Okay. Who was the sign for?

3 A Bill Elfo.

4 Q Okay. While you were still at the Whatcom County Sheriff's

5 Office, were you aware that Sheriff Elfo was himself, or other

6 people that he had directed, monitoring Paul Murphy's Facebook

7 page?

8 A I was not aware.

9 Q Were you aware that Paul Murphy had a Facebook page that

10 related to un-electing Bill Elfo?

11 A I was not. I saw a picture of -- I saw a picture of the

12 sheriff sitting on a unicorn that somebody showed me.

13 Q Do you recall who showed it to you?

14 A I don't. I think several people showed it to me. Sorry.

15 Q Are there any other internal investigations that occurred while

16 you were at the Whatcom County Sheriff's Office that you recall

17 that we haven't already talked about?

18 A Yes.

19 Q Which other internal investigations can you recall that we

20 haven't discussed?

21 A I have been investigated for several allegations.

22 Q Anything that didn't involve you as the subject of the

23 investigation?

24 A I believe they did an internal on Andy Koch, a former deputy,

25 but that was probably maybe eight or ten years ago.

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1 Q Do you know what he was investigated for?

2 A I don't recall.

3 MS. BESCHEN: Okay. Let's go off the record and take

4 just a five minute break. I think I'm almost done. I just

5 want to run through my notes really quick.

6 (Brief Pause In Proceedings)

7 (Deposition Resumed)

8 (Marked Deposition Exhibit No. 62)

9 Q (By Ms. Beschen) The court reporter has just handed you what's

10 been marked as Exhibit No. 62. If you turn, it looks like the

11 pages are not numbered, but if you would turn midway through

12 the part where it says, "Deputy Freeman" towards the bottom of

13 the exhibit. Did you find it?

14 A Mm-hm.

15 Q Okay. So looking down to the third paragraph where it says,

16 "Deputy Freeman. On February 26th, Lieutenant Rossmiller and I

17 spoke with Deputy Freeman at the Laurel Fire Hall."

18 Go ahead and read that paragraph through to the next

19 page. And then after that, I'm going to ask you if that is

20 what you recall about that conversation and if you recall

21 anything else that didn't get reported in here.

22 MR. KAMERRER: Let me get that page, just so that I --

23 MS. BESCHEN: It doesn't have a page number, but this

24 is it.

25 MR. KAMERRER: Okay.

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1 MS. BESCHEN: It's about midway through.

2 THE WITNESS: I'm done reading.

3 Q (By Ms. Beschen) Okay. Does that match your exact

4 recollection of what occurred during that interview with -- was

5 it Chadwick or Rossmiller?

6 A I believe both of them were there.

7 Q Okay.

8 A I don't have an exact recollection of our conversation that we

9 had. I mean, with changes of words like saying not accurate as

10 opposed to a bold faced lie, which was the wording that I used,

11 I don't see any. And then we spoke a majority of the time

12 about Sergeant Larson and I don't think that any of that is in

13 here. It's mostly on Kevin Mede.

14 Q Anything else that you recall discussing that you don't see in

15 that paragraph?

16 A Other than that, no.

17 Q Okay.

18 MS. BESCHEN: I have no further questions. He may

19 have some though.

20 MR. KAMERRER: I've got a couple of questions.

21

22 EXAMINATION OF JEREMY FREEMAN MR. KAMERRER

23

24 BY MR. KAMERRER:

25 Q You mentioned a Pass The Hat donation, was that for a charity?

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1 A I believe it is. I don't know. My wife told me about it and I

2 know that -- I don't believe that Sheriff Elfo runs it, but

3 it's a -- I believe that it is a charity, yes.

4 Q Is it something that is a solicitation within the sheriff's

5 office?

6 A No. Not that I'm aware of, no.

7 Q Okay. So it's a community charity or solicitation?

8 A I don't even know that it was a solicitation. I think that it

9 was something that my wife saw on Facebook or something like

10 that. I don't do Facebook, so I couldn't tell you much about

11 it.

12 Q Do you have any knowledge that Sheriff Elfo asked employees of

13 the Whatcom County Sheriff's Office for political donations?

14 A No.

15 Q Were you ever asked for a donation to Sheriff Elfo's political

16 campaign?

17 A No.

18 Q The photograph of Bill Elfo on a unicorn, was that something

19 that you understood to be from an Un-Elect Bill Elfo page

20 maintained online by Paul Murphy?

21 A I don't know. I -- the photo that I saw was printed off and

22 stuck on the wall in an office.

23 MR. KAMERRER: All right. That's all of the questions

24 that I have.

25 MS. BESCHEN: Okay. Thank you. You're done.

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1 (Signature Reserved)

2 (Deposition Adjourned)

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1 C E R T I F I C A T E

2 STATE OF WASHINGTON ) ) ss.

3 COUNTY OF ISLAND )

4 I, Kristen M. Uhlig, the undersigned CCR in and for the Stateof Washington, do hereby certify:

5 That the annexed and foregoing deposition of the witness

6 named herein was taken stenographically before me and transcribedby me;

7 I further certify that the witness examined, read, and signed

8 the deposition after the same was transcribed, unless indicated inthe record that the parties and the witness waive the signature;

9 I further certify that all of the objections made at the time

10 of said examination to my qualifications or the manner of takingthe deposition, or to the conduct of any party, have been noted by

11 me upon said deposition;

12 I further certify that I am not a relative or employee orattorney or counsel of any of the parties to said action or

13 counsel, and that I am not financially interested in the saidaction or the outcome thereof;

14 I further certify that the deposition, as transcribed, is a

15 full, true, and accurate transcript of the testimony, including allquestions and answers, and all objections, motions and exceptions

16 of counsel made and taken at the time of the foregoing examination;

17 I further certify that I am sealing the deposition in anenvelope with the title to the above cause thereon and marked

18 "Deposition Upon Oral Examination" of said witness and promptlycausing the same to be delivered or forwarded to Counsel for the

19 Opposing Party;

20 IN WITNESS THEREOF, I have hereunto set my hand and affixedmy official seal this ___ day of____________, 2014.

21

22 __________________________

23 Kristen M. Uhlig, #1934 Certified Court Reporter,

24 Residing in Clinton, Washington.

25

Paul

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