steven cooley, wcso - vol i - full transcript

Steven Cooley, March 11, 2014Paul Murphy v. Whatcom County

3206 Wetmore Avenue, Suite 12 - Everett, Washington 98201BMA Court Reporters, (425) 252.7277

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7 UNITED STATES OF DISTRICT COURT

8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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10 PAUL MURPHY, together with his ) marital community, )

11 Plaintiffs, ) )

12 vs. ) NO. 2:13-CV-00727 )

13 WHATCOM COUNTY, WASHINGTON, a ) VOLUME I government entity; WHATCOM COUNTY )

14 SHERIFF'S DEPARTMENT; WILLIAM J. ) ELFO, together with his marital )

15 community, ) Defendants. )

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17 DEPOSITION UPON ORAL EXAMINATION OF

18 STEVEN COOLEY, VOLUME I

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20 11:30AM - 12:15PM March 11TH, 2014

21 Whatcom County Courthouse 311 Grand Avenue

22 Bellingham, Washington 98225

23 Reported by Kristen M. Uhlig

24 Certified Court Reporter, CCR, CSR Washington CCR #1934

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

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3 FOR THE PLAINTIFFS:Robert Butler & Emily Beschen

4 Law Offices of Robert Butler103 East Holly Street Suite 512

5 Bellingham, Washington 98225360.734.3448

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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

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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

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1 I N D E X

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3 EXAMINATION: PAGE

4 BY MS. BESCHEN...............................................4

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7 EXHIBIT DESCRIPTION PAGE

8 29....E-mail from Doug Chadwick, Dated 10/20/2011............8 Fwd: RE: Fb page - status update

9 30....E-mail from Steven Cooley, Dated 3/3/2008.............14 RE: Murphy MDT

10 31....E-mail from Steve Cooley, Dated 11/19/2012............18 Paul Murphy Post

11 32....E-mail from Daniel Gibson, Dated 12/21/2011...........20

12 33....E-mail from Steve Cooley, Dated 12/21/2011............22 RE: Murphy Facebook

13 34....E-mail from Jeff Parks, Dated 3/20/2012...............23 Fwd: Murphy Facebook Koran reference

14 35....E-mail from Steve Cooley, Dated 10/19/2011............25

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1 STEVEN COOLEY,

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

3 was examined and testified as follows:

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5 DIRECT EXAMINATION

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7 BY MS. BESCHEN:

8 Q Can you state and spell your name for record?

9 A Steven Cooley. Do you want me to spell both names?

10 Q Yes, please.

11 A S-T-E-V-E-N C-O-O-L-E-Y.

12 Q Did you have a chance to review any documents in preparation

13 for this deposition?

14 A I skimmed through the investigation, the main investigation

15 that I conducted on Don -- Deputy Murphy, former Deputy Murphy,

16 but that's all.

17 Q Okay. Did you have a chance to review your transcript from the

18 prior deposition?

19 A No.

20 Q Okay.

21 A I don't think that I've ever seen it.

22 Q Okay. You did do a prior deposition during the civil service

23 case; correct?

24 A Correct.

25 Q And you were aware that Paul Murphy was involved in a Facebook



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1 page group where the shared interest was the Whatcom County

2 sheriff's election?

3 MR. KAMERRER: Object to the form of the question.

4 It's vague as to shared.

5 THE WITNESS: I -- yeah. I don't understand.

6 Q (By Ms. Beschen) Are you aware that Paul had involvement in a

7 Facebook page that was essentially about Sheriff Elfo?

8 A Yes.

9 Q Okay. In 2011, you were monitoring that Facebook page;

10 correct?

11 A Yes.

12 Q And you were monitoring that page at Sheriff Elfo's direction;

13 correct?

14 A Yes.

15 Q Prior to 2011, were you ever tasked to monitor a website called

16 Whatcom Uncovered?

17 A I don't believe that I was tasked to monitor that Facebook --

18 that page, no.

19 Q Okay. Did you monitor it?

20 A Yes.

21 Q Why did you monitor it?

22 A Because I heard that it existed and I heard that there were

23 things on it that were disparaging about the sheriff's office

24 and some of its employees.

25 Q Okay. Do you remember what those things were?



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1 A All of them? No. I don't remember all of them. I remember

2 some.

3 Q What do you remember?

4 A I remember that there were some things about a situation with

5 one of our former deputies who was stationed over at Newhalem

6 and a situation surrounding his housing up there.

7 Q Okay. Any others that initially sparked your attention to the

8 page?

9 A Let me think. That's all that's coming to mind right now. I

10 know that there was other stuff on there, but no.

11 Q Okay. Was there anything about you on the page?

12 A Yes.

13 Q Was that early on in the page when you became aware of it?

14 A I don't recall when that was, but I know that there was

15 something about me on there, yes.

16 Q What did it say about you on the page?

17 A I know that I was mentioned in the context of the subject that

18 I just mentioned, the whole Newhalem housing thing.

19 Q Okay.

20 A I know that my name was mentioned in that particular subject.

21 Q Okay. Any other places that your name was mentioned that you

22 were aware of?

23 A Probably. But, again, I'm not thinking. I can't think what

24 those circumstances are right now.

25 Q Okay. In 2012, you were tasked with doing an administrative



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1 investigation against Paul Murphy; is that correct?

2 A I wouldn't use the word against but, yes. I did an

3 investigation of his conduct.

4 Q Okay. You were assigned to be the investigator of that

5 conduct?

6 A Yes.

7 Q And you had concerns about your ability to be fair, the

8 appearance of fairness; is that correct?

9 MR. KAMERRER: Object to the form of the question.

10 It's vague and argumentative. Go ahead.

11 Q (By Ms. Beschen) You can still answer.

12 A I did not have concerns about my ability to be fair, no.

13 Q Did you have any concerns about there being a conflict with you

14 being the investigator of an investigation involving Paul

15 Murphy?

16 A No.

17 Q Okay. You didn't bring any concerns to Sheriff Elfo?

18 A I did, yes.

19 Q Okay. What were the concerns that you brought to Sheriff Elfo?

20 A I was concerned that were we to be -- to find ourselves in a

21 situation that we are in today, that Deputy Murphy would use

22 whatever past he felt that we shared to try to use that against

23 the sheriff's office.

24 Q Okay.

25 A To discredit me, the sheriff, the sheriff's office in an



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1 attempt to excuse his own conduct.

2 Q So the concern was an appearance of a conflict?

3 A Correct.

4 Q Okay. Sheriff Elfo told you to do the investigation anyway; is

5 that correct?

6 A That's correct.

7 Q Okay. Have you ever contacted Facebook yourself to have any

8 content removed?

9 A No.

10 Q Do you know if Sheriff Elfo has ever contacted Facebook to have

11 content removed?

12 A I have no knowledge of that, no.

13 Q Okay.

14 (Marked Deposition Exhibit No. 29)

15 Q (By Ms. Beschen) Go ahead and take a look at all of the pages

16 in there.

17 A Okay.

18 Q Let me know when you're done.

19 A You want me to read everything or just skim?

20 Q You don't have to read through it.

21 A Okay.

22 Q Just -- are you familiar with the document is what I'm going to

23 ask you.

24 A Okay.

25 MR. KAMERRER: Read as much as you need to to



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1 familiarize yourself with it.

2 THE WITNESS: Okay.

3 Q (By Ms. Beschen) Okay. Have you seen this e-mail before?

4 A Yes.

5 Q Would you agree that this is starting out as an -- it's an

6 e-mail from Doug Chadwick to you on October 20th, 2011?

7 A Yes. It looks -- it appears to be.

8 Q Okay. On Page 2, have you ever seen that e-mail before?

9 A Oh, your first question was pertaining to the first e-mail on

10 the top page?

11 Q Correct. So Page 1 --

12 A Yeah.

13 Q -- is an e-mail from Doug Chadwick to you on October 20th,

14 2011?

15 A Okay. That e-mail, I don't recall seeing, but it appears to be

16 to me, yes.

17 Q Okay.

18 A From Doug.

19 Q The subject title is Facebook Page Status Update.

20 A Right.

21 Q And then if you turn to Page 2.

22 A Yes.

23 Q The same subject line.

24 A Yes.

25 Q Facebook page status update?



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1 A That I recall seeing, yes.

2 Q This is from Bill Elfo to Doug Chadwick and Jeff Parks;

3 correct?

4 A Correct.

5 Q Okay. What's this e-mail about?

6 MR. KAMERRER: What do you mean what is it about? Are

7 you referring to Page 1 or --

8 Q (By Ms. Beschen) Page 1 and 2 -- Page 2 and 3. This was

9 forwarded over to you why?

10 A I believe that it was part of a public disclosure request.

11 Q Okay.

12 A That I was assigned to gather documents for. I believe that

13 that's why Chadwick forwarded it to me was because it was in

14 his possession and he was responding to the public disclosure

15 request and I was gathering the documents.

16 Q Okay. Got it. Did you review the documents and submit

17 everything for the public disclosure request?

18 A I don't have a specific -- a specific recollection of doing

19 that, but I would imagine that would have been my job here,

20 yeah.

21 Q Would you agree that on Page 2 and 3 towards the end, Tara

22 Adrian-Stavik is sending an e-mail to Bill Elfo saying, "It

23 needs to be removed," referencing the Facebook comments by Paul

24 Murphy?

25 A It appears to me that she's not happy with what Paul Murphy



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1 posted, yes.

2 Q She's asking Bill Elfo to call Facebook and have it removed.

3 A It appears that she provides a phone number and says that, "It

4 needs to be removed." I don't see the place where it says that

5 I would like you to call them and have them remove it. But,

6 yes --

7 Q Sure. Fair enough.

8 A -- it seems that she is implying that.

9 Q The next communication. Do you see from Bill Elfo, he says, "I

10 will make the call tonight."

11 A I'm sorry, where are you at? Where is that? Page 2?

12 Q Page 2 in the middle. It starts out, "Hi Tara."

13 A Okay.

14 Q I have been in back to back meetings in Seattle since yesterday

15 and will get back -- and will get back until town until

16 tonight. I will make the call. (As Read).

17 A I do see that, yes.

18 Q Okay. Are you aware of any other circumstances where Bill Elfo

19 has contacted Facebook to have content removed?

20 MR. KAMERRER: I object. This is -- that's a

21 misstatement of testimony. This is irrelevant. It's not

22 calculated to lead to admissible evidence. He's not going to

23 answer any more questions about it.

24 MS. BESCHEN: Okay.

25 MR. BUTLER: Oh.



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1 MS. BESCHEN: That was my last question about it

2 anyways.

3 MR. BUTLER: You're advising your client to not answer

4 a question at the deposition?

5 MR. KAMERRER: He's not my client. He's not my

6 client.

7 MR. BUTLER: Then you can't advise him, can you?

8 MR. KAMERRER: Well, I think this is completely

9 irrelevant. This is calculated to be disruptive, to be in bad

10 faith. And it has no basis of -- it has nothing to do with

11 this case. It's beyond the pale.

12 MR. BUTLER: You've made your record.

13 Madam, court reporter --

14 MR. KAMERRER: Let's go off the record. I'm going to

15 take a break. You're coming with me.

16 MR. BUTLER: Madam court reporter.

17 THE REPORTER: Hang on a second.

18 MR. BUTLER: If you would make a note of the slamming

19 of the hand, and if you would also make a note of the page

20 number, because we will be ordering this up. It is 11:44.

21 (Recess Taken)

22 (Deposition Resumed)

23 MS. BESCHEN: Before we get back into questions, I

24 just want to put on the record who is present in the room. We

25 are deposing Steve Cooley. We have Dale Kamerrer present in



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1 the room. Liz Gallery, Sheriff Elfo, Tara Adrian-Stavik,

2 Robert Butler, myself Emily Beschen, and the court reporter.

3 THE WITNESS: And I would be happy to answer any

4 questions that you have for me about Exhibit 29.

5 MS. BESCHEN: Okay.

6 MR. KAMERRER: I just want to put on the record that

7 my objection is to the utter sleaziness of bringing up this

8 subject and questioning Mr. Cooley about it.

9 And it's beneath the dignity of anyone who is admitted

10 to the Bar in the State of Washington or the federal district

11 court, but it's what I've been told to expect from you.

12 MR. BUTLER: Well, isn't that a great character

13 assassination. I won't even put on the record what I've been

14 told about you.

15 Q (By Ms. Beschen) Okay. So on the topic of the Facebook page,

16 are you aware that the sheriff's office has a Facebook page?

17 A The sheriff's office's official Facebook page?

18 Q Correct.

19 A Yes, I am.

20 Q Okay. Do you have any involvement in that page?

21 A Other than reading it, no.

22 Q Okay. Do you read it regularly?

23 A Very rarely.

24 Q Do you like it on your personal Facebook page?

25 A My wife and I share a Facebook page and we might have liked it.



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1 I don't remember.

2 Q Okay.

3 A We might have.

4 Q Have you ever heard from anybody directly rumors or anything

5 about content being removed from the sheriff's office Facebook

6 page?

7 A No.

8 Q Who do you know to be the administrators or in charge of

9 running that Facebook page?

10 A I am not certain actually. I think Undersheriff Parks and

11 Sergeant Gatterman, but I'm not sure.

12 Q Okay. Do you know if there's any rules surrounding that

13 Facebook page?

14 A Not to my knowledge.


16 Q (By Ms. Beschen) Okay. Go ahead and take a look at this. You

17 can just probably read through this whole thing and let me know

18 when you're done.

19 A Okay.

20 Q Before we talk about Exhibit 30, I want to talk about what went

21 on in the hall for a second. So when you just left the room,

22 did you speak with counsel?

23 A Mr. Kamerrer?

24 Q Yes.

25 A Yes.



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1 Q What did you two speak about?

2 A You want everything or --

3 Q Mm-hm. Everything. Yes.

4 A Okay. Basically, he just wanted a moment to calm down and then

5 he basically said that I could go in and answer any questions

6 that I wish to answer about Exhibit 29.

7 Q Okay. Is it your understanding that you have a lawyer present

8 in this room who is representing --

9 A No.

10 Q -- your personal interests?

11 A No.

12 Q Okay. You know that there's not a lawyer representing your

13 interests in this room?

14 A That is correct.

15 Q Back to Exhibit 30.

16 A Okay.

17 Q Do you recall receiving this e-mail?

18 A I do.

19 Q And then -- so it appears to me and let me know if I'm

20 characterizing this wrong. This is an e-mail first from Larry

21 Flynn to you on March 1st, 2008 and then a response from you to

22 Flynn also on March 3rd, 2008.

23 A That's correct.

24 Q What caused Flynn to send you this e-mail? Do you know?

25 A You would have to ask Sergeant Flynn that question.



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1 Q Okay. Do you know if there were any conversations or

2 communications not in e-mail prior to him sending you this?

3 A No. Hm-mm.

4 Q Was there any investigation going on into Murphy at the time

5 that he sent you this?

6 A I don't recall.

7 Q Okay. At the very bottom of the page, the last paragraph

8 starts out, "When I told Paul about having to leave his MDT at

9 Cascade at the end of his shift that starts Monday night so

10 that IT could upgrade it and get it back to him once he came

11 back to work on Tuesday he became concerned."

12 A (Witness Indicating).

13 Q Why is he telling you about this?

14 MR. KAMERRER: Objection, calls for speculation.

15 THE WITNESS: Yeah. Again, you would have to ask

16 Sergeant Flynn that, but I think that the rest of the paragraph

17 kind of explains the point of this e-mail that he says in the

18 paragraph above that.

19 The point of his e-mail is to let me know that there's

20 files on one of our -- one of the sheriff's office computers

21 that Paul claims are quote, unquote classified, and that we

22 should probably know what those are.

23 Q (By Ms. Beschen) Okay. On the second page, it says in the

24 middle of the paragraph, "He said that they will not be able to

25 do anything without him here. I am of the impression that



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1 modifying the Bios and password protecting it is something that

2 people shouldn't be doing."

3 Is it true that the county doesn't want their computers

4 password protected?

5 MR. KAMERRER: Object, calls for speculation.

6 THE WITNESS: As a blanket statement, I would say, no,

7 that's not true.

8 Q (By Ms. Beschen) Are you aware of any policies that were in

9 place in 2008 that prevented Paul from putting a password on

10 his computer?

11 A No.

12 Q Okay. The second to last sentence. It states, "I thought we

13 might want to see what he actually has on his computer and see

14 what he is actually up to in reference to this investigation

15 before bringing up the rules about computer modifications."

16 What were the rules about computer modifications in

17 2008?

18 A Not sure which ones he's referring to. You would have to ask

19 Sergeant Flynn.

20 Q Okay. Is there more than one rule about computer modifications

21 presently?

22 A The county has a couple of policies on computers in general.

23 Q What about modifications specifically?

24 A I would have to look at them to see what is in them. I don't

25 know off the top of my head.



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1 Q Did this start an investigation from you, this e-mail from

2 Flynn?

3 A No. It did not start an official investigation.

4 Q Did it start an unofficial investigation?

5 A No.

6 Q Back to Page 1, your response to him.

7 A Mm-hm.

8 Q Was, "For now, your solution about getting Murphy's laptop

9 updated is a good one. I'll let you know how we're going to

10 proceed, once we've decided."

11 A Mm-hm.

12 Q Do you recall how you did decide to proceed?

13 A I briefed then Chief Deputy Parks.

14 Q Mm-hm.

15 A I think that that all culminated in eventually, I believe, that

16 it was Lieutenant Rossmiller and Sergeant Flynn himself getting

17 Deputy Murphy's computer and looking to see what was on it.

18 Q Did they find anything?

19 A Not to my knowledge, but I don't recall the specifics because I

20 wasn't there.

21 Q Okay. Do you remember people guessing or speculating or rumors

22 about what they thought would be on his computer that he was

23 trying to hide?

24 A No.




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1 Q (By Ms. Beschen) Okay. Let me know when you've had a chance

2 to take a look.

3 A I'm good.

4 Q So this appears to be an e-mail from you to Dan Gibson on

5 November 19th, 2012.

6 A Mm-hm.

7 Q This is after Murphy's termination; is that correct?

8 A Um, I don't remember the exact date. I think so.

9 Q Okay. You are sending Dan Gibson information about Murphy's

10 Facebook page post; is that correct?

11 A Yes.

12 Q Why?

13 A Because he was still in one stage or another fighting his

14 termination.

15 Q He was still what?

16 A Objecting to his termination from the sheriff's office.

17 Q Okay. So what was the relevance of what he was posting in

18 November of 2012?

19 A This is more evidence of the fact that he shouldn't have been a

20 law enforcement officer.

21 Q Okay. Because he held these particular beliefs?

22 A No. Because he's advocating armed resistance against the

23 government.

24 Q In the post, did you remember, did it actually state: I am

25 advocating armed resistance? Or is that your inference of what



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1 was posted?

2 A That was my understanding of what these people were doing, yes.

3 Q What -- okay. Then in about the middle of the e-mail where it

4 says, "How many has this been? How many more will we sit back

5 and watch like this?"

6 Is that part of the post or is that your e-mail?

7 A It's part of the post.

8 Q Okay. All right. Just wanted to clarify that. Do you recall

9 if Gibson responded to this?

10 A I don't recall. I don't remember.

11 Q Rough estimate, how many e-mails about Paul's Facebook page

12 have you sent to Dan Gibson?

13 A Five or less.


15 Q (By Ms. Beschen) Have you had a chance to review?

16 A I have.

17 Q Okay. At the bottom of the e-mail, it appears that this is

18 sent originally from Bill Elfo to you on December 18th, 2011 at

19 2:06 PM. It states, I just glanced at Murphy's Facebook page.

20 In his profile picture, he is featured in a WCSO uniform with

21 his rifle in a patrol vehicle wearing a Santa hat. The

22 comments he espouses on the page may tend to diminish the

23 reputation of the WCSO and our confidence with the public.

24 Again, please have the PA review. (As Read)

25 A Mm-hm.



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1 Q Do you know what PA is meant to stand for in that sentence?

2 A I assumed that it was the prosecuting attorney.

3 Q Okay. And he says, "Again, please have the PA review."

4 How many times prior to December of 2011 had you asked

5 the prosecuting attorney to review Paul Murphy's Facebook page?

6 A It would be the same type of estimate that I gave you before, a

7 rough guess, so it would be five or less.

8 Q Okay.

9 A Very few.

10 Q And then the middle of the page, it appears that you then

11 forward this over to the prosecuting attorney; correct?

12 A Correct.

13 Q So then there's a response to you from Dan Gibson that

14 essentially says, you can't punish him for this; is that

15 correct?

16 MR. KAMERRER: Objection, misstates the content of the

17 e-mail.

18 Q (By Ms. Beschen) Well, the question will be: What did you

19 understand the response to be telling you?

20 A He has a bunch of questions that would lead to further

21 discussion essentially.

22 Q Okay. The last sentence, it says, "That's my first reaction,

23 but let's talk further."

24 A Mm-hm.

25 Q Did you have a face-to-face conversation with him?



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1 A I don't recall a face-to-face. I believe that I talked with

2 him on the phone.

3 Q Okay. And what did you talk about?

4 A Oh, I can't remember the specifics of that conversation. Like

5 I say, I'm pretty sure that we talked on the phone about it

6 but, yeah. I can't remember the actual specifics of that.

7 Q Do you remember just in general?

8 A Expanding upon the questions that he asked, you know, was the

9 picture -- was the concern the picture or the comments? And we

10 talked about the fact that it was the association of the

11 uniform with the comments.

12 Q Do you recall what the comments were?

13 A I don't, no.

14 Q Do you recall whether Dan Gibson rendered an opinion as to

15 whether you could go forward and continue investigating?

16 A I don't.

17 Q Okay.


19 Q (By Ms. Beschen) After reading Exhibit 33, does this refresh

20 your recollection at all as to the conversation that you had

21 with Mr. Gibson?

22 A Yes, it does.

23 Q Okay. Now, what do you recall about that conversation?

24 A We discussed the questions that Dan had raised in that e-mail.

25 And after discussing it, we agreed that -- that there was no



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1 disciplinary action certainly that could be taken.

2 Q Okay.

3 A In relation to that particular issue.

4 Q Okay. And then you also say, "We should address this in a

5 social networking policy that we have on our list for the first

6 of the year." Correct?

7 A Correct.

8 Q Did that happen yet?

9 A We drafted a policy and it has -- we forwarded it to the deputy

10 sheriff's guild and the other unions and it is in the, I think,

11 stalled in the bargaining process would be the proper way to

12 describe where it is.

13 Q Okay.


15 Q (By Ms. Beschen) The court reporter has just handed you

16 Exhibit No. 34. Go ahead and take a chance to look at all of

17 the pages.

18 A Okay.

19 Q Okay. So starting from the last page of this exhibit, which

20 appears to be an e-mail from Dan Gibson to Bill Elfo and Jeff

21 Parks, do you recall receiving this e-mail as well?

22 A I did not get the e-mail myself, but I did. It was forwarded

23 to me so, yes, I have seen it.

24 Q Okay. In that e-mail, they're talking about Paul's comments on

25 religion; is that right?



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1 A They're talking about a specific post that he made about the

2 burning Koran.

3 Q Okay. Did that start an investigation?

4 A I believe that we would call it a preliminary inquiry, the

5 briefest of preliminary inquiries. I did not really do an

6 investigation per se.

7 Q Okay. Did it get an investigation number?

8 A Yes.

9 Q Was that investigation number AI2012-002?

10 A Yes. I believe that it was.

11 Q Were you later asked by the guild for a copy of that

12 investigation?

13 A Yes. I think so.

14 Q What was your response?

15 A Mm. Well, when we -- let me back up. I don't know if I was

16 directly asked or if the undersheriff -- I remember that there

17 was some contentious issue about that particular thing.

18 Eventually, they got a copy.

19 Q Okay.

20 A But yeah. I don't recall how that all went down, but I think

21 that eventually I gave them a copy via a public disclosure

22 request, if I remember.

23 Q Was there initially any concerns about letting the guild know

24 about that investigation?

25 MR. KAMERRER: Object. Vague.



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1 THE WITNESS: I don't -- what do you mean by letting

2 them know? I don't understand.

3 MR. KAMERRER: Object. Vague.

4 Q (By Ms. Beschen) Well, after they asked and you became aware

5 that they had asked. Did you have any concerns about providing

6 the investigation to the guild?

7 MR. KAMERRER: Objection, vague.

8 Q (By Ms. Beschen) No?

9 A I was not involved in that particular discussion. I know that

10 there was some discussion between the undersheriff and the

11 sheriff and the guild about that particular issue. I wasn't

12 involved in that. I simply stood by until that all was

13 resolved and eventually the public disclosure request was made

14 and I fulfilled that request, so that's the bottom line.

15 Q Okay. What was the discussion that you were just referring to

16 about?

17 A Again, I wasn't involved. I'm trying to think of what I knew

18 about it. Yeah. I am not remembering. There was some kind of

19 conflict there, but I'm not remembering what it was over.

20 Q Okay.

21 A So --


23 Q (By Ms. Beschen) You can go ahead and review it and let me

24 know when you're done.

25 A Okay.



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1 Q Would you agree that this is an e-mail from you to Dan Gibson?

2 A Yes.

3 Q The date that it was sent was October 19th, 2011?

4 A Yes.

5 Q Where in the timeline of the election does that fall?

6 A I have no idea. I mean, I would assume that that would be a

7 couple of weeks before.

8 Q The first line states, "The Sheriff wanted me to make you aware

9 of some of the posts that have been made to the subject

10 Facebook page."

11 You're referring to Paul's Facebook page; is that

12 correct?

13 A No. We're referring to the campaign to Un-Elect Sheriff Elfo

14 page.

15 Q Okay. Do you know what started the watch of that campaign to

16 Un-Elect Sheriff Elfo page?

17 A I'm sorry, say that again?

18 Q What started the sheriff's office watching the campaign to

19 Un-Elect Bill Elfo page?

20 A I started watching it because I had been watching Deputy

21 Murphy's Facebook page and he often crosslinked to it.

22 Q Okay.

23 A So that's what drew my attention to it, and he would often post

24 some of his stuff on that page and vise versa.

25 Q Do you remember the first conversation that you had with Bill



27

1 Elfo about that particular Facebook page?

2 A No.

3 Q Do you remember whether he came to you to talk about it versus

4 you going to him to talk about it?

5 A No.

6 Q In the middle of that paragraph, it says that, Is there

7 anything that can be done about the group's identification of

8 Sergeant Mede and the implications they are making about his

9 motives for supporting the sheriff? (As Read)

10 A Mm-hm.

11 Q Do you know what the implications were that you're referring to

12 in that sentence?

13 A I don't remember.

14 Q The second paragraph, it states on the first sentence, "While

15 the Sheriff is mindful and supportive of the free speech issues

16 at play here, this group of insiders continues to attack other

17 members of the Sheriff's Office by name."

18 Can you describe what you meant by attack?

19 A Not without seeing the posts.

20 Q Okay.

21 A I can't remember.

22 Q Okay. Do you know what came of this e-mail? Did you have a

23 phone call with Dan Gibson after this?

24 A Yeah. I can't remember.

25 MS. BESCHEN: All right. This is probably a good



28

1 breaking point if we want to stop for lunch and then.

2 (Discussion Held Off The Record)

3 (Deposition Continued, Volume I Concluded)

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29

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





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15:6

33 10:8,213/20/2012 3:133/3/2008 3:930 3:9 14:15,20

15:1531 3:10 18:25311 1:21 2:1232 3:11 20:1433 3:12 22:18,1934 3:13 23:14,1635 3:14 25:22360.734.3448 2:5360.754.3480 2:93rd 15:22

44 3:4

5



512 2:4

6

7

88 3:8

998225 1:22 2:5,1398512 2:9

steven cooley, wcso - vol i - full transcript

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