Shearer, Julie Deposition

7/30/2019 Shearer, Julie Deposition

1/24

In The Matter Of:

Caffrey vs.Gladwin Community Schools, et al.

JULIE SHEARERMay 29, 2013

Mid-Michigan Reporting LLC

1606 W Carpenter StMidland MI 48640

(989)835-9171

Min-U-Script with Word Index


2/24

Mid-Michigan Reporting LLC (989)835-9171

JULIE SHEARER - May 29, 2013

1 STATE OF MICHIGAN

2 IN THE CIRCUIT COURT FOR THE COUNTY OF GLADWIN

3

4 PHILIP CAFFREY,

5 Plaintiff/Counter-Defendant,

6 vs. File No. 12-6665-CZ

7 GLADWIN COMMUNITY SCHOOLS, GLADWIN COMMUNITY SCHOOLS BOARD OF EDUCATION,8 SALLY HIGHTOWER, KELLY GOWER, GREG ALWARD, TREVOR GRAVELLE, BRAD WITHROW,9 LISA SCHWAGER, LINDA WINARSKI, RICK SEEBECK, JULIE A. SHEARER, jointly10 and severally,

11 Defendants/Counter-Plaintiffs. ______________________________________/12

13

14 DEPOSITION OF: JULIE SHEARER

15 May 29, 2013, at 4:35 p.m.

16 401 West Cedar Avenue, Gladwin, Michigan

17

18 APPEARANCES:

19 For Plaintiff/ CLINE CLOSE DYER Counter-Defendant: BY: KURT N. HANSEN (P14622)20

For Defendants/ O'NEILL WALLACE & DOYLE21 Counter-Plaintiffs: BY: DAVID A. WALLACE (P24149)

22 ALSO PRESENT: PHILIP CAFFREY RICHARD SEEBECK23

Reported by: DIANE KRAYNAK, RPR, CRR, CM, SCC24 Certified Shorthand Reporter 2122 (989)835-9171 Fax: (989)835-606425


3/24



1 -----------------------------------------------------------------

2 EXAMINATION INDEX

3 -----------------------------------------------------------------

4 PAGE

5 Examination By Mr. Hansen 3

6

7

8

9

10 -----------------------------------------------------------------

11 EXHIBIT INDEX

12 -----------------------------------------------------------------

13

14 (No exhibits marked.)

15

16

17 JULIE SHEARER,

18 having been first duly sworn,

19 testified on her oath as follows:

20

21

22

23

24

25


4/24



1 EXAMINATION

2 BY MR. HANSEN:

3 Q Would you state your name for the record, please.

4 A Julie Shearer.

5 Q And are you employed by the Gladwin Community Schools?

6 A Yes, I am.

7 Q And in what capacity are you employed?

8 A Director of business.

9 Q And are you also the FOIA official?

10 A Yes.

11 Q And when were you appointed to do that job?

12 A I don't recall.

13 Q Was it some time ago?


15 Q Okay. Do you recall who appointed you?

16 A No.

17 Q Was it Mr. Seebeck or was it prior to that time?


19 Q Okay. Have you received any training about FOIA matters or

20 anything like that?

21 A No.

22 Q Okay. How do you determine then whether or not, when a FOIA

23 request comes in, that you turn the items over or not?

24 A Depending on the request, it may be turned over to the

25 attorney for guidance.


5/24



1 Q And who is the attorney?

2 A It depends what the FOIA request is for.

3 Q You have attorneys that are on retainer for the School for

4 this purpose?

5 A Yes, we do.

6 Q And who is that?

7 A SET SEG -- or I mean Thrun Law Firm. I'm sorry.

8 Q So when a request comes in, if you know the answer, then you

9 deal with it, and if you don't know or you're not sure, then

10 you contact the attorney, is that right?

11 A Yes.

12 Q Now, in this particular case there was a FOIA request, three

13 different ones by Mr. Caffrey for minutes of certain

14 meetings, is that right?

15 A I believe so.

16 Q Okay. And one of the requests was for proposed minutes, do

17 you recall that?

18 A Yes.

19 Q Okay. And one of them was for available minutes, correct?

20 A I don't recall that that -- that wording.

21 Q I show you Exhibit D that's attached to the complaint and

22 let you read that through.

23 A Okay.

24 Q So one of them was for available minutes, right?

25 A Yes.


6/24



1 Q And one for proposed minutes, and the third one was just for

2 minutes, right?

3 A (No response.)

4 Q I'll show you.

5 A Okay.

6 Q I'm referring to Exhibits A, B, C, D, E attached to the

7 complaint.

8 A Okay.

9 Q And you denied all of those requests based upon the fact

10 that you said that the minutes had not been approved, is

11 that correct?

12 A Yes.

13 Q The proposed or draft minutes had been prepared at that time

14 of the request, correct?

15 A I could not answer that. I don't know.

16 Q Okay. You are aware that they are to be prepared within

17 eight working days of the date of a meeting?

18 A Yes.

19 Q Okay. Were you aware of that at the time of the denial?

20 A Yes.

21 Q Why did you deny it then if you were aware that they -- that

22 proposed minutes were supposed to be turned over?

23 A I was -- I believed that the proposed minutes were supposed

24 to have been typed by then, not necessarily turned out --

25 turned over to the public.


7/24



1 Q Well, on the June 4th one they were prepared, weren't they?

2 A (No response.)

3 Q There was a meeting that night that they were approved at,

4 correct?

5 A But they were not approved.

6 Q Okay. But the proposed minutes had been typed up.

7 A Yes.

8 Q So why didn't you turn over the proposed minutes at that

9 time?

10 A Because I did not believe that the proposed minutes should

11 be turned out to the public.

12 Q And what did you base that on?

13 A Prior years of preparing minutes.

14 Q Did you look at the law to see why those weren't turned

15 over?

16 A No, I did not.

17 Q Did you call your attorney and ask him?


19 Q Well, you received three different requests, and you had

20 already denied one of them from the June 4th one because you

21 said they hadn't been approved, and then you received two

22 more, one that specified proposed minutes and one that asked

23 for available minutes.

24 Did you ever wonder, well, why is he asking for this

25 when I've already denied this?


8/24



1 A Yes.

2 Q But that didn't trigger anything that maybe you should check

3 something out?

4 A No.

5 Q So the reason why you didn't do it then is ignorance of the

6 law; is that what we're saying here?

7 A Yes.

8 Q Did you talk to Mr. Seebeck about it?

9 A I don't recall.

10 Q You don't have any recollection as to whether you did that

11 or not?

12 A No.

13 Q They should have been turned over, correct?

14 MR. WALLACE: I'm going to --

15 A From --

16 MR. WALLACE: -- object to the extent you're

17 asking for a legal conclusion.

18 Q Well, from your understanding of the law, they should have

19 been turned over?

20 A From my understanding now, they should have -- the draft

21 minutes can be turned over.

22 Q In your answer to the complaint where you've been sued, you

23 deny that you have a duty to turn those over.

24 Are you changing that now?

25 MR. WALLACE: Counsel, before -- please don't


9/24



1 answer.

2 I'm going to object to the form and foundation, and the

3 legal denial is as written and is part of the record in this

4 case, and this is not a legal expert witness.

5 The denial is based upon the fact, as you well know,

6 that prior to the filing of the instant lawsuit, both the

7 proposed minutes and the approved minutes were in the

8 possession of you and/or your client, and that moots all

9 issues as to the compliance and that is the basis for the

10 denial. So I'm going to object to this line of questioning

11 as irrelevant.

12 MR. HANSEN: Well, we made an allegation that

13 factually -- you know, that those items were available at

14 that time and there was a denial, that they had to turn over

15 what was available at that point in time. What was turned

16 over subsequently doesn't make any difference whatsoever.

17 Q Do you keep phone records?

18 A (No response.)

19 Q Does the School keep phone records?

20 A Phone records? What are you referring to as phone records?

21 Q Phone bills?

22 A Yes.

23 Q And are these from Verizon now?

24 A These, yes.

25 Q And how do you keep these records?


10/24



1 A Filed by year.

2 Q They're paper filings?

3 A Yes.

4 Q Okay. And do these include logs?

5 A No.

6 Q And when did that stop?

7 A I believe March -- I would have to check my records because

8 I don't want to say the wrong date. When we switched to

9 Verizon.

10 Q There was an e-mail that was sent by Mr. Seebeck, and this

11 is only if it jogs your memory, that indicated that there

12 was a changeover to Verizon in April.

13 A Okay.

14 Q So prior to that time it would've been with Nextel?

15 A Nextel.

16 Q And you would have had the records back then, is that right?

17 A (No response.)

18 Q Of Nextel, up until the changeover to Verizon?

19 A We do have those records.

20 Q And that would include logs?

21 A I believe so.

22 Q Okay. What was the reason why you no longer have the logs?

23 MR. WALLACE: Before you answer, I'm going to

24 object. The issue with regard to call logs or activity logs

25 or whatever you call them were the subject of the previous


11/24



1

1 lawsuit that has been dismissed with prejudice against the

2 plaintiffs, and this is irrelevant to this case.

3 My understanding of the allegations in this case relate

4 to phone billings, and I would ask you to limit your

5 questions to phone billings.

6 MR. HANSEN: Well, phone billings, from our

7 perspective, includes everything that's included in the

8 phone bill so --

9 MR. WALLACE: Well, you have a gross

10 misunderstanding of phone records.

11 MR. HANSEN: Well, it's our lawsuit so...

12 Q When did you change the log -- or when did that change?

13 With Verizon?

14 A Starting with Verizon.

15 Q And do you know why that changed?

16 A We get the bill that they send, and we did not ask for call

17 logs. They --

18 Q But you had the bills at that time.

19 A We have the bills.

20 Q And you've always had the bills, is that right?

21 A Um-hum.

22 Q Correct?

23 A Um-hum, the monthly statements.

24 Q Okay. Now, Mr. Seebeck signed an affidavit back then,

25 saying that you didn't have -- they didn't possess, they


12/24



1

1 didn't maintain, and they didn't use phone bills.

2 MR. WALLACE: No.

3 Q Would that be accurate?

4 MR. WALLACE: Stop. I'm going to object. That

5 mischaracterizes the affidavit. It is injecting into this

6 litigation issues that were resolved by a prior litigation

7 in favor of the School District, and you continue to

8 intentionally misdescribe or try to cloud the distinction

9 between call logs and phone bills, and that is

10 objectionable.

11 And if you continue, I'm going to seek sanctions from

12 the Court. And it's the very reason why we have alleged

13 abuse of process by way of the counterclaim in this case,

14 one of the very reasons. So, continue at your peril.

15 Q Your answer is?

16 A Repeat the question, please.

17 Q Okay. You did have those records back then that Mr. Seebeck

18 said was not -- you know, that you never possessed? Well,

19 he didn't say never possessed. He said they didn't possess,

20 use, or maintain these phone records.

21 A I don't know --

22 MR. WALLACE: The --

23 THE WITNESS: I'm sorry?

24 MR. WALLACE: I'm sorry, go ahead and answer.

25 A I don't know which records Mr. Seebeck would have been


13/24



1

1 referring to, so I can't answer that question.

2 Q Okay. Now, when was the last time that you had any

3 conversation with Mr. Caffrey?

4 A I don't know.

5 Q You don't have any idea whatsoever?

6 A No.

7 Q A long time ago? Years or --

8 A I don't know.

9 Q Okay. Were you aware of a motion for protective order that

10 was filed?

11 A Yes.

12 Q Did you seek that?

13 A I believe it was on behalf of me, yes.

14 Q Did you seek it?

15 A Personally, no.

16 Q Are you afraid of Mr. Caffrey?

17 A Yes, I am.

18 Q And what do you base that on?

19 A Telephone conversations, a meeting a couple of times, him

20 being in our office.

21 Q And how long ago was that?

22 A Right now I can't give you a specific date.

23 Q Well, give me an approximation.

24 A Approximately around the time he requested -- did another

25 FOIA for personnel records from one of our staff members.


14/24



1

1 Q Did he threaten you?

2 A I felt threatened.

3 Q Did he threaten you?

4 MR. WALLACE: She answered the question. It's

5 been answered.

6 MR. HANSEN: She said how she felt.

7 Q What did he do that made you feel threatened?

8 A He threw paper back at me and told me -- he swore and told

9 me that wasn't what he was looking for and that I knew that

10 that wasn't what he was looking for.

11 Q And that's it?

12 A Um-hum.

13 Q Has he made any attempt to talk to you since that point in

14 time?

15 A We have spoken on the phone since then.

16 Q And when was that?

17 A I would have to check my -- my notes. I don't have a date

18 in my head for that.

19 Q This was about school business?

20 A FOIA.

21 Q FOIA matters?

22 A Um-hum.

23 Q And you are the FOIA representative, right?

24 A Yes.

25 Q So it's necessary, if he wants to make FOIA requests, that


15/24



1

1 contact be made with you, right?

2 A That's correct.

3 Q And you accept that, right?

4 A Yes.

5 Q He's never threatened any physical harm to you or anything

6 like that, has he?

7 A No.

8 Q On December 24th of this year -- I'm sorry, last year, there

9 was a special meeting of the Board. Do you remember that?

10 A Yes -- I know that there was one but I don't remember it.

11 Q Were you at that meeting?

12 A No, I was not.

13 Q Do you know what the purpose of that meeting was?

14 A Only from reading the minutes.

15 Q Did you prepare the minutes?

16 A I typed the minutes.

17 Q And what did you type them from?

18 A I don't recall. Notes from someone but I don't recall who.

19 Q Did you talk to Mr. Seebeck about the minutes at the time?

20 A I don't remember.

21 Q So all you had was some notes of the meeting, is that right?


23 Q You don't recall anything about that at all?

24 A I would have typed the minutes.

25 Q That's all that you know?


16/24



1

1 A Um-hum. Yes.

2 Q Do you still have those notes?

3 A No.

4 Q Do you know what happened to them?

5 A They would have been shredded.

6 Q Would they have been notes on a computer?

7 A I don't recall.

8 Q Sometimes that would happen, is that right?

9 A Sometimes.

10 Q And who was the secretary?

11 A Mr. -- Pastor Withrow.

12 Q Would he have been the one to do the minutes or would it

13 have been Mr. Seebeck?


15 Q Mr. Seebeck would do the notes at some times?

16 A Sometimes.

17 Q So you don't know which one it was at this time.

18 A No, I don't.

19 Q Okay. Now, there's been a counterclaim by you in this

20 particular situation against Mr. Caffrey, is that right?

21 A Yes.

22 Q You authorized that?

23 A Yes.

24 Q Okay. Did you hire any attorney to represent you to do

25 that?


17/24



1

1 A No.

2 Q Who's your attorney?

3 A Mr. Wallace.

4 Q And what's your relationship to him as far as him being your

5 attorney is concerned?

6 A He is serving as the attorney for the School Board members

7 and myself.

8 Q Okay. So he's being paid by the insurance company then?

9 A No, not for this.

10 Q How is he being paid?

11 A He's not, as far as I know.

12 Q In this counterclaim you're suing Mr. Caffrey for libel and

13 slander; do you understand that?

14 A Yes.

15 Q Okay. And libel is a writing that is false about you that

16 is published to a third person; do you understand that?

17 A Um-hum.

18 Q What writing is there that has been published to a third

19 person that is false about you?

20 A Any FOIA information, FOIA claims, any -- there's been

21 documents written that say that I haven't done my job

22 properly.

23 Q And those are directed to you?

24 A As far as I know.

25 Q Okay. And weren't directed to a third person?


18/24



1

1 A The claim? I don't understand.

2 Q No; the written document that you're saying.

3 A (No response.)

4 Q You're saying that he did some writings where he made false

5 accusations against you. Those were sent to you?

6 THE WITNESS: I guess I can't answer this

7 question.

8 MR. WALLACE: Is it because you don't understand

9 it?

10 THE WITNESS: I don't know what he's looking for.

11 MR. WALLACE: Try a different question, would you

12 please?

13 Q Well, you're claiming that he libeled you by issuing a

14 writing that is false about you.

15 A Um-hum.

16 Q And that he delivered this to a third person. What writing

17 are you referring to?

18 A My mind is totally blank right now, so I apologize.

19 Q Well, you're the one who's filing suit here, you're the one

20 who's making the claim, so if you don't know, you don't

21 know, I guess, but tell us whether you know or not.

22 MR. WALLACE: Well, I think the question has been

23 asked and answered and you just convoluted it when you asked

24 the subsequent question, so the record will speak for

25 itself.


19/24



1

1 Q Do you have a writing from him that is -- that says

2 something that's false?

3 A Not in my possession.

4 Q Who has it?

5 A I -- I don't know. I can't answer the question. I'm sorry.

6 Q Who was it shown to?

7 A I can't answer your question.

8 Q Did you show it to this person, whoever it was?

9 A I can't answer your question.

10 Q Same way with any verbal statements that were made that are

11 false about -- what verbal statements were made?

12 A When Mr. Caffrey was in our office, he -- when he threw the

13 paper back at me, he said that I knew what he was looking

14 for and that I wasn't producing it and swore at me and told

15 me that I wasn't giving him the information that he wanted.

16 Q And what was untrue about that?

17 A That I was giving him the information that he had asked for.

18 Q So you had a disagreement as to whether or not you were

19 giving him what he was asking for.

20 A That's correct.

21 Q So that's the only thing that you're saying -- you're saying

22 that he said this about you and -- I mean, this was just a

23 disagreement between two people, right?

24 A I'm not recalling right now.

25 Q So you don't know.


20/24



1

1 A I don't. I'm not recalling.

2 Q Who was present at the time that heard it?

3 A I -- myself and Mr. Caffrey.

4 Q You also alleged intentional infliction of mental distress

5 by extreme and outrageous and atrocious conduct, utterly

6 intolerable in a civilized society.

7 What are you referring to?

8 A The many FOIA requests, the phone calls asking for

9 information, being in our office and having him say he's not

10 leaving until he gets the information.

11 Q And how long ago was that?

12 A It's been ongoing requests for approximately two years.

13 Q Okay. I'm not leaving until I get what I want, when was

14 that?

15 A I don't have a specific date in my head.

16 Q Well, we have to know. Was it well over a year ago?

17 A I can consult my notes, but I don't want to say a date

18 because I don't know off the top of my head.

19 MR. HANSEN: That's all I have.

20 MR. WALLACE: Thank you.

21 (Deposition concluded at or about 5:00 p.m.)

22

23

24

25


21/24



2

1 STATE OF MICHIGAN

2 COUNTY OF MIDLAND

3 I, Diane Kraynak, Notary Public in and for Midland

4 County, State of Michigan, acting in Gladwin County, State

5 of Michigan, do hereby certify that I stenographically

6 recorded the deposition of JULIE SHEARER, the deponent in

7 the foregoing deposition; that prior to the taking of said

8 deposition the said deponent was duly sworn to tell the

9 truth, the whole truth, and nothing but the truth, and that

10 the foregoing deposition is a true and correct transcript of

11 the testimony of said deponent, to the best of my ability.

12 I further certify that I am not a relative, employee,

13 attorney or counsel of any of the parties, a relative or

14 employee of such attorney or counsel, or am financially

15 interested in the transaction.

16 I further certify that no request was made that the

17 foregoing deposition be submitted to the said deponent for

18 examination and correction by her or that she sign the same.

19

20

_________________________________________21 Diane Kraynak, CSR-2122

Certified Shorthand Reporter22 Registered Professional Reporter Notary Public, Midland County, Michigan23 My Commission Expires: 11-1-13

24

25


22/24


JULIE SHEARMay 29, 2

A

abuse (1)11:13

accept (1)14:3

accurate (1)11:3

accusations (1)17:5

activity (1)9:24

affidavit (2)10:24;11:5

afraid (1)12:16

against (3)10:1;15:20;17:5

ago (5)3:13;12:7,21;

19:11,16

ahead (1)11:24

allegation (1)8:12

allegations (1)10:3

alleged (2)11:12;19:4

always (1)10:20

and/or (1)8:8

answered (3)13:4,5;17:23

apologize (1)17:18

appointed (2)3:11,15

approved (5)5:10;6:3,5,21;8:7

Approximately (2)12:24;19:12

approximation (1)12:23

April (1)9:12

around (1)12:24

atrocious (1)

19:5attached (2)

4:21;5:6

attempt (1)13:13

attorney (8)3:25;4:1,10;6:17;

15:24;16:2,5,6

attorneys (1)4:3

authorized (1)15:22

available (5)4:19,24;6:23;8:13,

15

aware (4)5:16,19,21;12:9

B

back (5)

9:16;10:24;11:17;13:8;18:13

base (2)6:12;12:18

based (2)5:9;8:5

basis (1)8:9

behalf (1)12:13

bill (2)10:8,16

billings (3)10:4,5,6

bills (6)8:21;10:18,19,20;

11:1,9

blank (1)17:18

Board (2)14:9;16:6

both (1)8:6

business (2)3:8;13:19

C

Caffrey (7)4:13;12:3,16;

15:20;16:12;18:12;

19:3

call (5)6:17;9:24,25;

10:16;11:9

calls (1)19:8

can (2)7:21;19:17

capacity (1)3:7

case (5)

4:12;8:4;10:2,3;11:13

certain (1)4:13

change (2)10:12,12

changed (1)10:15

changeover (2)9:12,18

changing (1)7:24

check (3)7:2;9:7;13:17

civilized (1)19:6

claim (2)17:1,20

claiming (1)17:13

claims (1)

16:20client (1)

8:8

cloud (1)11:8

Community (1)3:5

company (1)16:8

complaint (3)4:21;5:7;7:22

compliance (1)8:9

computer (1)

15:6concerned (1)

16:5

concluded (1)19:21

conclusion (1)7:17

conduct (1)19:5

consult (1)19:17

contact (2)4:10;14:1

continue (3)

11:7,11,14conversation (1)

12:3

conversations (1)12:19

convoluted (1)17:23

Counsel (1)7:25

counterclaim (3)11:13;15:19;16:12

couple (1)12:19

Court (1)

11:12

D

date (6)5:17;9:8;12:22;

13:17;19:15,17

days (1)5:17

deal (1)4:9

December (1)

14:8

delivered (1)17:16

denial (5)5:19;8:3,5,10,14

denied (3)5:9;6:20,25

deny (2)5:21;7:23

Depending (1)3:24

depends (1)4:2

Deposition (1)19:21

determine (1)3:22

difference (1)8:16

different (3)4:13;6:19;17:11

directed (2)16:23,25

Director (1)3:8

disagreement (2)18:18,23

dismissed (1)10:1

distinction (1)11:8

distress (1)19:4

District (1)11:7

document (1)17:2

documents (1)16:21

done (1)16:21

draft (2)5:13;7:20

duty (1)7:23

E

eight (1)5:17

e-mail (1)

9:10employed (2)

3:5,7

EXAMINATION (1)3:1

Exhibit (1)4:21

Exhibits (1)5:6

expert (1)8:4

extent (1)

7:16

extreme (1)19:5

F

fact (2)5:9;8:5

factually (1)

8:13false (6)

16:15,19;17:4,14;

18:2,11

far (3)16:4,11,24

favor (1)11:7

feel (1)13:7

felt (2)13:2,6

Filed (2)9:1;12:10

filing (2)8:6;17:19

filings (1)9:2

Firm (1)4:7

FOIA (13)3:9,19,22;4:2,12;

12:25;13:20,21,23

25;16:20,20;19:8

form (1)8:2

foundation (1)8:2

G

gets (1)19:10

giving (3)18:15,17,19

Gladwin (1)3:5

gross (1)10:9

guess (2)17:6,21

guidance (1)

3:25

H

HANSEN (6)3:2;8:12;10:6,11;

13:6;19:19

happen (1)15:8

happened (1)15:4

harm (1)

Min-U-Script Mid-Michigan Reporting LLC (989)835-9171 (1) abuse - ha


23/24



14:5

head (3)13:18;19:15,18

heard (1)19:2

hire (1)15:24

I

idea (1)12:5

ignorance (1)7:5

include (2)9:4,20

included (1)10:7

includes (1)10:7

indicated (1)9:11

infliction (1)

19:4information (5)

16:20;18:15,17;

19:9,10

injecting (1)11:5

instant (1)8:6

insurance (1)16:8

intentional (1)19:4

intentionally (1)11:8

into (1)11:5

intolerable (1)19:6

irrelevant (2)8:11;10:2

issue (1)9:24

issues (2)8:9;11:6

issuing (1)17:13

items (2)3:23;8:13

J

job (2)3:11;16:21

jogs (1)9:11

Julie (1)3:4

June (2)6:1,20

K

keep (3)8:17,19,25

knew (2)13:9;18:13

Llast (2)

12:2;14:8

Law (4)4:7;6:14;7:6,18

lawsuit (3)8:6;10:1,11

leaving (2)19:10,13

legal (3)7:17;8:3,4

libel (2)16:12,15

libeled (1)17:13

limit (1)10:4

line (1)8:10

litigation (2)11:6,6

log (1)10:12

logs (7)9:4,20,22,24,24;

10:17;11:9

long (3)12:7,21;19:11

longer (1)9:22

look (1)6:14

looking (4)13:9,10;17:10;

18:13

M

maintain (2)11:1,20

making (1)17:20

many (1)19:8

March (1)9:7

matters (2)3:19;13:21

may (1)3:24

maybe (1)7:2

mean (2)4:7;18:22

meeting (7)5:17;6:3;12:19;

14:9,11,13,21

meetings (1)4:14

members (2)12:25;16:6

memory (1)9:11

mental (1)19:4

mind (1)17:18

minutes (25)4:13,16,19,24;5:1,

2,10,13,22,23;6:6,8,

10,13,22,23;7:21;8:7,

7;14:14,15,16,19,24;

15:12

mischaracterizes (1)11:5

misdescribe (1)11:8

misunderstanding (1)10:10

monthly (1)10:23

moots (1)8:8

more (1)6:22

motion (1)12:9

myself (2)16:7;19:3

N

name (1)3:3

necessarily (1)5:24

necessary (1)13:25

Nextel (3)9:14,15,18

night (1)6:3

notes (7)13:17;14:18,21;

15:2,6,15;19:17

O

object (5)7:16;8:2,10;9:24;

11:4

objectionable (1)11:10

off (1)19:18

office (3)12:20;18:12;19:9

official (1)3:9

one (17)4:16,19,24;5:1,1;

6:1,20,20,22,22;

11:14;12:25;14:10;

15:12,17;17:19,19

ones (1)4:13

ongoing (1)19:12

only (3)9:11;14:14;18:21

order (1)12:9

out (3)5:24;6:11;7:3

outrageous (1)19:5

over (13)3:23,24;5:22,25;

6:8,15;7:13,19,21,23;

8:14,16;19:16

P

paid (2)16:8,10

paper (3)9:2;13:8;18:13

part (1)8:3

particular (2)4:12;15:20

Pastor (1)15:11

people (1)

18:23peril (1)

11:14

person (5)16:16,19,25;17:16;

18:8

Personally (1)12:15

personnel (1)12:25

perspective (1)10:7

phone (15)8:17,19,20,20,21;

10:4,5,6,8,10;11:1,9,20;13:15;19:8

physical (1)14:5

plaintiffs (1)10:2

please (4)3:3;7:25;11:16;

17:12

pm (1)19:21

point (2)

8:15;13:13

possess (2)10:25;11:19

possessed (2)11:18,19

possession (2)8:8;18:3

prejudice (1)10:1

prepare (1)14:15

prepared (3)5:13,16;6:1

preparing (1)6:13

present (1)19:2

previous (1)9:25

prior (5)3:17;6:13;8:6;

9:14;11:6

process (1)

11:13producing (1)

18:14

properly (1)16:22

proposed (10)4:16;5:1,13,22,23;

6:6,8,10,22;8:7

protective (1)12:9

public (2)5:25;6:11

published (2)16:16,18

purpose (2)4:4;14:13

R

read (1)4:22

reading (1)14:14

reason (3)7:5;9:22;11:12

reasons (1)11:14

recall (14)

3:12,14,15,18;4:1720;6:18;7:9;14:18,

18,22,23;15:7,14

recalling (2)18:24;19:1

received (3)3:19;6:19,21

recollection (1)7:10

record (3)3:3;8:3;17:24

records (13)

Min-U-Script Mid-Michigan Reporting LLC (989)835-9171 (2) head - reco


24/24



8:17,19,20,20,25;

9:7,16,19;10:10;

11:17,20,25;12:25

referring (5)5:6;8:20;12:1;

17:17;19:7

regard (1)9:24

relate (1)

10:3relationship (1)

16:4

remember (3)14:9,10,20

Repeat (1)11:16

represent (1)15:24

representative (1)13:23

request (6)3:23,24;4:2,8,12;

5:14

requested (1)12:24

requests (6)4:16;5:9;6:19;

13:25;19:8,12

resolved (1)11:6

response (5)5:3;6:2;8:18;9:17;

17:3

retainer (1)4:3

right (16)4:10,14,24;5:2;

9:16;10:20;12:22;13:23;14:1,3,21;15:8,

20;17:18;18:23,24

S

Same (1)18:10

sanctions (1)11:11

saying (6)7:6;10:25;17:2,4;

18:21,21

School (5)

4:3;8:19;11:7;13:19;16:6

Schools (1)3:5

secretary (1)15:10

Seebeck (9)3:17;7:8;9:10;

10:24;11:17,25;

14:19;15:13,15

seek (3)11:11;12:12,14

SEG (1)4:7

send (1)10:16

sent (2)9:10;17:5

serving (1)16:6

SET (1)

4:7Shearer (1)

3:4

show (3)4:21;5:4;18:8

shown (1)18:6

shredded (1)15:5

signed (1)10:24

situation (1)15:20

slander (1)

16:13society (1)

19:6

someone (1)14:18

Sometimes (3)15:8,9,16

sorry (5)4:7;11:23,24;14:8;

18:5

speak (1)17:24

special (1)14:9

specific (2)12:22;19:15

specified (1)6:22

spoken (1)13:15

staff (1)12:25

Starting (1)10:14

state (1)3:3

statements (3)10:23;18:10,11

still (1)15:2

stop (2)9:6;11:4

subject (1)9:25

subsequent (1)17:24

subsequently (1)8:16

sued (1)7:22

suing (1)16:12

suit (1)17:19

supposed (2)5:22,23

sure (1)4:9

switched (1)

9:8swore (2)

13:8;18:14

T

talk (3)7:8;13:13;14:19

Telephone (1)12:19

third (5)5:1;16:16,18,25;

17:16

threaten (2)

13:1,3threatened (3)

13:2,7;14:5

three (2)4:12;6:19

threw (2)13:8;18:12

Thrun (1)4:7

times (2)12:19;15:15

told (3)13:8,8;18:14

top (1)

19:18totally (1)

17:18

training (1)3:19

trigger (1)7:2

try (2)11:8;17:11

turn (4)3:23;6:8;7:23;8:14

turned (10)3:24;5:22,24,25;

6:11,14;7:13,19,21;

8:15two (3)

6:21;18:23;19:12

type (1)14:17

typed (4)5:24;6:6;14:16,24

U

Um-hum (7)10:21,23;13:12,22;

15:1;16:17;17:15

untrue (1)18:16

up (2)6:6;9:18

upon (2)5:9;8:5

use (2)11:1,20

utterly (1)19:5

V

verbal (2)18:10,11

Verizon (6)8:23;9:9,12,18;

10:13,14

W

WALLACE (15)

7:14,16,25;9:23;10:9;11:2,4,22,24;

13:4;16:3;17:8,11,

22;19:20

wants (1)13:25

way (2)11:13;18:10

weren't (3)6:1,14;16:25

what's (1)16:4

whatsoever (2)8:16;12:5

Who's (3)16:2;17:19,20

within (1)5:16

Withrow (1)15:11

witness (4)8:4;11:23;17:6,10

wonder (1)6:24

wording (1)4:20

working (1)5:17

writing (5)16:15,18;17:14,16;

18:1

writings (1)17:4

written (3)8:3;16:21;17:2

wrong (1)9:8

Y

year (4)9:1;14:8,8;19:16

years (3)6:13;12:7;19:12

2

24th (1)14:8

4

4th (2)6:1,20

5

5:00 (1)19:21

Documents

Shearer, Julie Deposition