Transcript of investigator's interview with Debbie Buckley

In The Matter Of:

Buckley vs

City of Buffalo School District

Debbie Buckley

February 13, 2012

Original File 021312amk.txt

Min-U-Script® with Word Index

1

1 Statement of DEBBIE BUCKLEY, held in the Law

2 Offices of Bond, Schoeneck & King, PLLC., 40 Fountain

3 Plaza, Suite 600, Buffalo, New York, on Monday,

4 February 13, 2012, at 9:40 a.m. before Ashley M.

5 Kleinschmidt, Notary Public.

6

7 APPEARANCES:

8 LIPSITZ, GREEN, SCIME, CAMBRIA, LLP. BY: PAUL J. CAMBRIA, ESQ.,

9 RICHARD D. FURLONG, ESQ., 42 Delaware Avenue, Suite 120

10 Buffalo, New York 14202 Appearing for Debbie Buckley

11

12 BOND, SCHOENECK & KING, PLLC. BY: JAMES J. ROONEY, ESQ.,

13 ERIN S. TORCELLO, ESQ., 40 Fountain Plaza, Suite 600

14 Buffalo, New York 14202 Appearing for the City of Buffalo School District

15

16

17

18

19

20

21

22

23

METSCHL & ASSOCIATES (716) 856-1906

2

1 INDEX

2

3 THE WITNESS - DEBBIE BUCKLEY

4 EXAMINATION BY: PAGE

5 MR. ROONEY 3

6 MR. FURLONG 178

7 EXHIBITS PAGE

8 A typed letter 53

9 B lease agreement 54

10 C requisition form 75

11 D contact list 79

12 E August 2010 purchase order 80

13 F E&M Enterprises, Inc. August 2010 purchase order 86

14 G meeting agenda 98

15 H Crossroads contract 104

16 I 2010 Spinuzza letter 152

17 J January to August 2010 Spinuzza contract 152

18 K September 2010 to August 2011 Spinuzza contract 152

19 L services rendered invoice 167

20 M another services rendered invoice 171

21 N vender invoices 175

22 O Ahmed recommendation letter 177

23 P lease assignment 179


3

1 D E B B I E B U C K L E Y, 2489 Cayuga Street, Niagara

2 Falls, New York 14304, gave a statement as follows:

3

4 EXAMINATION BY MR. ROONEY:

5

6 Q. Ms. Buckley, I'm Jim Rooney. This is an associate

7 that works with me, Erin Torcello. And as I think

8 you know, the Buffalo School District hired me and

9 directed me to investigate some allegations of

10 potential misconduct on your part.

11 Today I just want to talk to you a little bit

12 and get your side of the story. And so I'm going to

13 ask you a series of questions and ask you to answer

14 them as honestly and as thoroughly as you can.

15 I know you have assistance from two lawyers

16 here, two able lawyers, Mr. Furlong and Mr. Cambria,

17 but I ask that the questions be answered by you, not

18 Mr. Furlong and Mr. Cambria obviously. Okay?

19 A. Okay.

20 Q. Now, I assume these are the representatives of your

21 choice?

22 A. Yes.

23 Q. And I should let you know that if you refuse to


4

1 answer any questions that relate to allegations

2 against you or the performance of your official

3 duties, the district may consider your refusal to be

4 insubordination, subjecting you to possible

5 discipline including possible termination; do you

6 understand that?

7 A. Yes.

8 Q. And I take it you also understand the statements that

9 you make today may be used against you in connection

10 with potential discipline brought by the school

11 district; do you understand that?

12 A. Yes.

13 Q. Okay. What is your full name, ma'am?

14 A. Debbie Buckley.

15 Q. Your legal name is Debbie not Deborah?

16 A. Um-hmm.

17 Q. Where do you reside?

18 A. 2489 Cayuga Street in Niagara Falls, New York.

19 Q. How long have you lived there, ma'am?

20 A. Two years.

21 Q. And your current title at the school district?

22 A. Assistant Superintendant of Federal and State

23 Programs.


5

1 Q. One other thing I want to advise you, when I take a

2 deposition, if there's a question that you don't

3 understand that I ask you, and it's certainly

4 possible, please let me know and I'll try to clarify

5 it. Okay?

6 And if you can, try to answer audibly instead

7 of nodding. We're trying to make a record of this so

8 there's no confusion of what you said. That would be

9 helpful.

10 A. Okay.

11 Q. How long have you held that position?

12 A. Including up to now?

13 Q. Yes. When you got hired into that position.

14 A. March 22nd, 2010.

15 Q. Just very generally, what are your duties and

16 responsibilities in that position?

17 A. To manage or make recommendations to the

18 superintendant regarding grant activities for the

19 district.

20 Q. And do you report directly to the superintendant?

21 A. No, I was reporting to the deputy superintendant and

22 I met weekly with the superintendant.

23 Q. Who was the deputy superintendant?


6

1 A. At the time it was Dr. Oladele, O-L-A-D-E-L-E.

2 Q. Now, was Dr. Oladele there throughout the time that

3 you were actively working prior to your leave?

4 A. She was there until June of 2011.

5 Q. Okay.

6 A. I think, approximately, June '11.

7 Q. So until June 2011 you reported to Dr. Oladele as

8 well as Dr. Williams?

9 A. Yes.

10 Q. Okay. What sort of reporting relationship did you

11 have with Barb Smith?

12 A. I did -- I had requested Barb Smith to actually meet

13 with me monthly. She refused. So I didn't have any.

14 Q. Okay. And when did you make that request?

15 A. I made a request via e-mail in June 2010.

16 Q. Did she tell you why she wouldn't meet with you

17 monthly?

18 A. She said she didn't think she needed to. I asked her

19 if we could review any documents, grants. We did

20 meet, at least, two or three times.

21 Q. Why did you want to meet with her monthly?

22 A. Because it was a new position to me, and I wanted to

23 have her expertise.


7

1 Q. Did you recognize that she did have some expertise in

2 the field?

3 A. She is a chief financial officer, so just in her

4 status. And she had been doing that prior to my

5 appointment, so given that, anything I would need to

6 ask regarding finances I would be able to ask her or

7 pass it by her.

8 Q. So after Dr. Oladele left in June of 2011 who did you

9 report to?

10 A. Dr. Williams.

11 Q. Okay. Dr. Williams exclusively at that point?

12 A. Yes.

13 Q. Now, from time to time in the course of your duties,

14 I take it you had to make arrangements to obtain

15 space within which to run some school program; is

16 that right?

17 A. Yes.

18 Q. Either a building, a room, anything like that?

19 A. Yes.

20 Q. Was there a typical process that you underwent when

21 you did that? In other words, was there a department

22 within the district that you spoke to? Could you do

23 it on your own? I mean, how, generally did that work?


8

1 A. Well, I wasn't sure how it would work.

2 Q. Fair enough.

3 A. But I did know that it was a requirement under

4 Federal and State Law with the nonpublic schools to

5 have services.

6 We -- prior to my appointment as assistant

7 superintendant I had a previous assistant

8 superintendant that I was reporting to. And I took

9 most of my information from what she had done

10 previously.

11 Q. And who was that?

12 A. June Simmons.

13 Q. Is that -- is she also Ms. Burroughs? Does she also

14 go by that last name?

15 A. Yes.

16 Q. I don't know which is the maiden or married name.

17 A. I don't know either.

18 Q. But Simmons and Burroughs are the same person?

19 A. Yes.

20 Q. She is the predecessor in your current role?

21 A. Yes.

22 Q. You said you followed her lead in terms of how to

23 proceed in these sort of issues, correct?


9

1 A. Yes.

2 Q. So how did -- given that you followed her lead, how

3 did you go about these things when you went to obtain

4 space?

5 A. Well, I asked her, because what we were doing is

6 setting up a neutral site for nonpublic school --

7 Q. Well, just so you're clear, I'm not talking -- it

8 sounds like you're leading towards 75 Hickory.

9 A. No.

10 Q. You're talking more generally?

11 A. Generally, yes.

12 Q. Fair enough. Go ahead.

13 A. To establish an access center, a nonpublic access

14 center, we rolled it into the Title 1 ARRA Grant,

15 A-R-R-A, in 2009. It was explicitly written into

16 that grant for the purpose of providing services. We

17 didn't have any space allocated at the time.

18 Q. Was nonpublic Title 1 work being performed prior to

19 2009?

20 A. Yes, but in an audit, it wasn't being performed

21 properly.

22 Q. Do you recall the audit -- who did the audit?

23 A. Um-hmm.


10

1 Q. Who?

2 A. U.S. Department of Education.

3 Q. Okay. And that was a 2009 audit?

4 A. I'm not sure if they were -- I think it might have

5 been early, like, March 2009. And then New York

6 State came in and did an audit at the end of 2009.

7 Q. Okay.

8 A. But they had the same results.

9 Q. Okay. So both the U.S. Department of Education and

10 the New York State, I take it, Department of

11 Education --

12 A. Department of Education.

13 Q. -- conducted audits around 2009, and both of them

14 concluded that the Title 1 nonpublic work was not

15 being properly done?

16 A. Yes.

17 Q. The documents will eventually speak for themselves,

18 but what do you recall more specifically was not

19 allegedly being done correctly?

20 A. We were not giving equitable services to nonpublic

21 schools according to what was required.

22 Q. Okay. Do you know where the services were being

23 provided at the time?


11

1 A. They weren't being provided at all, the professional

2 development for nonpublic school teachers and parent

3 involvement activities for nonpublic school Title 1

4 parents.

5 Q. So you're talking about two things, professional

6 development for nonpublic school teachers and then

7 also parents. Those are two different things, I take

8 it?

9 A. No. They were all encompassed in the Title 1

10 equitable services required for nonpublic schools.

11 Q. So what you're telling me is that there was no Title

12 1 nonpublic work going on at all?

13 A. No, nonpublic professional development and parent

14 involvement activities.

15 Q. Okay. All right. That one category.

16 A. Not instructional services.

17 Q. I understand.

18 A. The instructional services were not being

19 appropriately implemented as well.

20 Q. Okay. So what you're telling me is the 2009 audits

21 both pointed out this failing?

22 A. Yes.

23 Q. All right. And at that point what was your title,


12

1 ma'am?

2 A. Supervisor of Title 1.

3 Q. Prior to the audit taking place were you aware this

4 work was not being done that needed to be done?

5 A. Well, I was doing research, because that particular

6 element became a part of my job, and it was not a

7 part of my job prior to the retirement of the

8 Supervisor of Nonpublic Schools.

9 So there was a Supervisor of Nonpublic Schools

10 and there was an Office of Nonpublic Schools that was

11 dismantled, and all the elements relating to that was

12 tossed to me. So I had to learn it. And I did not

13 have any professional development or anybody to tell

14 me about how these things were to take place, but I

15 was required by Ms. Simmons, June, to have this stuff

16 happen, according to the law.

17 Q. Okay. So prior to this, there actually was an office

18 within the district called the Office of Nonpublic

19 Schools?

20 A. Yes.

21 Q. And it obviously had a supervisor?

22 A. Yes. And it had a secretary specifically working in

23 that --


13

1 Q. Any other employees in that office to your --

2 A. They also had a complete building with storage space

3 for all nonpublic activities. And they also had a

4 spot where the nonpublic school teachers or whoever

5 was working with them could access materials, or to

6 receive any information. So they had everything in

7 place for the nonpublic schools to implement their

8 programming.

9 Q. Okay. So at some point when this Office of Nonpublic

10 Schools existed, was this professional development

11 work that you referenced earlier taking place?

12 A. No.

13 Q. So it wasn't taking place even when the Office of

14 Nonpublic Schools was in existence?

15 A. It's in -- the instructional program was not

16 adequately taking place as well, because they didn't

17 have teachers in place in some of the schools. They

18 were just ordering supplies.

19 According to Title 1 Law, you cannot have an

20 ordering of supplies without a teacher in place in

21 any nonpublic school building. You have to have a

22 program. And that's when I was learning along the

23 way, in conversation with Virginia Berg, B-E-R-G,


14

1 from the U.S. Department of Education. She came in,

2 and Leon Hovicish from the New York State Department

3 of Education.

4 Q. How is his last name spelled?

5 A. H-O-V-I-C-I-S-H. There might be an E in there. I

6 don't know.

7 Q. You said there was a building --

8 A. 64 --

9 Q. Let me finish my question. There's a building that

10 the office used?

11 A. Yes.

12 Q. 64 what?

13 A. 64 Bailey.

14 Q. What happened to 64 Bailey?

15 A. Barbara Smith's office took it over for their use.

16 Q. For entirely different use, I take it?

17 A. Um-hmm.

18 Q. Was 64 Bailey a district-owned building?

19 A. District-owned and purchased with Title 1 funding.

20 Q. So what took place on 64 Bailey?

21 A. All nonpublic activities, Title 1 activities.

22 Q. The instructional work?

23 A. Also, they had bus drivers there.


15

1 Q. Did the instructional work take place there?

2 A. No.

3 Q. Where did the instructional work take place?

4 A. Schools, nonpublic schools.

5 Q. At the nonpublic schools themselves?

6 A. Yes.

7 Q. I interrupted you. You were going to say something

8 else, ma'am?

9 A. There were bus drivers and buses that were housed at

10 64 Bailey as well, Title 1 for parent involvement

11 activities.

12 Q. All right. I'm getting a little confused. You said

13 there were bus drivers and buses for parent

14 involvement activities? I thought you said earlier

15 those activities weren't taking place?

16 A. For district parents, not the nonpublic. The

17 nonpublic parent involvement activities weren't

18 taking place. We had a district parent center.

19 Q. So there was parent involvement for district parents,

20 but not --

21 A. Not for nonpublic Title 1 parents.

22 Q. When did Ms. Smith's office take over 64 Bailey, if

23 you remember?


16

1 A. I'm going to say about June -- maybe January,

2 February, March of 2010. Somewhere in the beginning

3 of 2010.

4 Q. Had you taken on your current position by that time?

5 A. No.

6 Q. No?

7 A. No.

8 Q. All right. So we're talking a little about the

9 process by which you were finding a -- at least,

10 beginning to find some space within which to have

11 these activities which were the subject of the audit,

12 correct?

13 A. Pardon me?

14 Q. Let me ask you this. Was there ever any other time

15 you were working in your current role where you were

16 trying to locate space for some purpose other than

17 Title 1 nonpublic work?

18 A. Yes.

19 Q. Okay.

20 A. We were looking for a -- we were looking to rent the

21 Convention Center for parent conferences. We wanted

22 to rent that. We wanted to have parent conferences

23 there. One of my supervisors had asked her to look


17

1 into talking with them about that.

2 Q. Okay.

3 A. Also, I guess under my role, the Beaver Hollow

4 Conference Center had to be rented --

5 Q. Okay.

6 A. -- for the annual retreat, twice.

7 Q. During either of those occasions or any other

8 occasion did you contact the Plant Department to see

9 if there was space available?

10 A. No.

11 Q. And did you contact the Plant Department when you

12 were trying to find a facility for the nonpublic

13 work?

14 A. I might have. I'm not sure.

15 Q. You don't recall either way?

16 A. Yeah, I might have.

17 Q. And if you did, you don't recall the details of it, I

18 take it?

19 A. I might have called them, but I'm pretty sure I might

20 not have gotten any information from them, but I

21 might have called them or had someone call them.

22 MR. FURLONG: Don't guess.

23 THE WITNESS: Okay.


18

1 BY MR. ROONEY:

2 Q. You are guessing?

3 A. I don't know. But I'm pretty sure.

4 Q. You're pretty sure?

5 A. I'm pretty sure I talked to someone.

6 Q. Who?

7 A. Sue Yaeger, Y-A-E-G-E-R.

8 Q. What's her position?

9 A. Director of Plant.

10 Q. Do you remember anything about the conversation you

11 had with Ms. Yaeger?

12 A. I talked to her a lot. I can't tell you that that

13 one specific conversation was specifically about

14 that. I talked to her about engineers, many

15 different things.

16 Q. So you don't remember anything about any conversation

17 you had with her relating to space for the nonpublic

18 work?

19 A. But I do know that my supervisor spoke with her

20 directly, the Supervisor of Title 1.

21 Q. Okay.

22 A. She spoke with her regarding space.

23 Q. The supervisor being Dr. --


19

1 A. No, the supervisor being Jamie Cohen, C-O-H-E-N.

2 Q. Tell me what you know about that.

3 A. Jamie made some connections with -- once she was

4 hired in September of 2010, she contacted the Plant

5 Department, but --

6 Q. About what, do you know?

7 A. About 75 Hickory.

8 Q. Okay.

9 A. But prior to that the district was already using 75

10 Hickory at no cost to the district.

11 Q. How do you know that Jamie contacted -- by the way,

12 stepping back, what was Jamie's title at the time?

13 A. Supervisor of Title 1.

14 Q. She held the position you previously held?

15 A. Yes.

16 Q. And did you direct her to contact the Plant

17 Department?

18 A. No.

19 Q. How do you know that she did?

20 A. Because e-mails, communication, and probably, we

21 met -- I met with the staff to give me updates on

22 what they were working on. I had given her directive

23 to do what I was supposed to be -- what I was


20

1 initially doing in the beginning.

2 Q. Okay.

3 A. To establish the professional development activities

4 and parent involvement activities. I basically

5 passed the torch to her.

6 Q. Do you know anything more about the communications

7 she had with the Plant Department?

8 A. I know that she had met with Sue Yeager at 75

9 Hickory. I do know that she also met with the IT

10 Department at 75 Hickory. I know that they talked

11 about design and program use at 75 Hickory.

12 Q. And you know this, you believe, from looking at

13 e-mails?

14 A. No.

15 Q. Talking to Jamie?

16 A. Talking to Jamie, talking to IT, talking to Sue

17 Yeager.

18 Q. Do you recall when these meetings between Jamie and

19 Sue Yeager took place?

20 A. Probably in between October and November of 2010. I

21 might note that the District of Nonpublic Schools in

22 June of 2010 had two schools close, which would have

23 been Nazareth Lutheran and St. Joseph -- Mount St.


21

1 Joseph. And because we did not have access to the 64

2 Bailey site --

3 Q. Um-hmm.

4 A. -- all of the Title 1 supplies, materials, computers,

5 televisions, carts, books and everything was moved by

6 the district into 75 Hickory. And 75 Hickory was

7 given a location --

8 Q. I think I understand. The Title 1 equipment that was

9 in Nazareth Lutheran and Mount St. Joseph was moved

10 into 75 Hickory?

11 A. Yes.

12 Q. When did that happen?

13 A. June of 2010. At no cost to the district.

14 Q. Who did the move?

15 A. The district, Sue Yeager.

16 Q. When you say at no cost, you mean you weren't charged

17 for the space at the time?

18 A. They were not charged for the space.

19 Q. Let me see if I can understand a little better the

20 contract protocol at the district as you understood

21 it. Did all payments that were made by the district

22 have to be supported by an actual contract? In other

23 words, if you were going to make a payment to a


22

1 vender, did there always have to be a contract with

2 the vender before the payment could be made?

3 A. Not always.

4 Q. Did you have any understanding as to when a contract

5 was required by district protocol and when it was

6 not?

7 A. Um-hmm.

8 Q. Can you explain your understanding to me?

9 A. Okay. If you were purchasing instructional supplies

10 or you were purchasing equipment you didn't need a

11 contract. If you were purchasing services you would

12 need a contract, or rental space you need a contract.

13 Q. Okay. All right. Well, that's pretty simple. As I

14 understand your answer, if you're purchasing

15 equipment, some tangible good --

16 A. Right, no contract.

17 Q. -- there's an invoice, purchase order and you make

18 the payment?

19 A. That's right.

20 Q. If you're purchasing services or you're making use of

21 some property with some space, then there has to be a

22 contract to support it?

23 A. Yes.


23

1 Q. And I take it the payment is not supposed to be

2 made -- there's no payment made until the contract is

3 in existence?

4 A. Until the contract is in existence?

5 Q. Right.

6 A. You can't make a payment until you have a purchase

7 order. You can't have a purchase order until you

8 have a contract.

9 Q. All right. Can you start using the venders services

10 without the contract?

11 A. You're not supposed to, but everyone -- I -- everyone

12 has.

13 Q. Okay. How do you know you're not supposed to?

14 A. Well, no one said it specifically, but Barbara always

15 wanted to tell everybody -- she told everyone every

16 time she had an opportunity, you cannot start

17 services until after the contracts are signed and all

18 that stuff.

19 Q. Okay. You heard her say that as well?

20 A. Everyone heard her, yeah.

21 Q. Okay. Now, did you have any understanding as to when

22 the control board needed to approve a contract?

23 A. Yup.


24

1 Q. When was that required?

2 A. If it goes over fifty thousand dollars.

3 Q. I'm going to ask you a few questions about an entity

4 called the Mastery Center, M-A-S-T-E-R-Y. Are you

5 one of the principals of the -- does the Mastery

6 Center still exist?

7 A. No.

8 Q. Okay. Over what period of time did it exist?

9 A. 2007. January of 2007 until, I'm going to say

10 February 2010.

11 Q. Was it actually incorporated under New York State?

12 A. There was a d/b/a.

13 Q. It was a d/b/a for what?

14 A. For tutoring.

15 Q. For what?

16 A. Tutoring.

17 Q. So who was involved in it? Who was a principal?

18 A. My mother.

19 Q. Yourself too?

20 A. No, I was helping my mother. I was working with my

21 mother, but it was actually hers.

22 Q. Okay. Did she ever pay you for helping her?

23 A. Sometimes, yes. In other words, yes.


25

1 Q. And when you received payment from your mother, was a

2 payment on her -- you know, from a personal check or

3 was it payroll through the Mastery Center?

4 A. Payroll.

5 Q. Do you have an understanding as to what the legal

6 name of the Mastery Center was?

7 A. What do you mean? The Mastery Center.

8 Q. You said it was a d/b/a.

9 A. The Mastery Center.

10 Q. Were there any other -- so the Mastery Center had its

11 own checking account?

12 A. Um-hmm.

13 Q. Has its own taxpayer ID number?

14 A. Mm-mm. No. It was under her ministry, a d/b/a under

15 her ministry.

16 Q. Love TNATS Ministries?

17 A. Yes.

18 Q. It's Love Thy Neighbor as Thyself?

19 A. Yes.

20 Q. Okay. So when you received a check you received it

21 from Love TNATS; is that right?

22 A. No, the Mastery Center.

23 Q. You received it from the Mastery Center? Did the


26

1 other entity to your knowledge -- did you work for

2 Love Thy Neighbor?

3 A. Sometimes.

4 Q. Just the short name, Love Thy Neighbor.

5 A. Not really.

6 Q. Well, you said sometimes, so not sometimes?

7 A. Not really work. I was kind of helping her. I

8 helped her start it and then I dropped out. And that

9 was way, like, 2001 or something. I was initially

10 with her, because she was in another state.

11 Q. Okay. I think I asked you, your mother's name is

12 Daphney Coleman, C-O-L-E-M-A-N?

13 A. Yes. You didn't ask me, but yes, that's her name.

14 Q. Let's start with Love Thy Neighbor. When was that

15 formed, to your knowledge?

16 A. 2000-2001.

17 Q. What did Love Thy Neighbor do?

18 A. It initially started off with a Solomon's Place for

19 tutoring for kids, and also a home for women, Vashi's

20 House, V-A-S-H-I-S, House, for women and children,

21 homeless. And then she -- my mom is a minister, so

22 she would do spiritual meetings and those types of

23 things.


27

1 Q. Okay. And do you know whether Love Thy Neighbor was

2 incorporated?

3 A. What do you mean?

4 Q. Was it -- did she file papers with New York State to

5 form an entity called Love Thy Neighbor?

6 A. Yeah. Um-hmm. I think.

7 Q. And do you know whether you were ever an officer of


9 A. I was in the beginning.

10 Q. What title did you hold?

11 A. Vice-President.

12 Q. You don't sound entirely confident.

13 A. I don't know what she put me down for.

14 Q. You held some officer position?

15 A. Yes, maybe Secretary.

16 Q. Anybody else?

17 A. Sylvia Wright, I think she was a Secretary. I know

18 she was the Secretary, because she did most of the

19 work, Sylvia.

20 Q. Anyone else?

21 A. I don't remember.

22 Q. And how long -- did the business of Love Thy Neighbor

23 change at any point? Did it start focusing on


28

1 something other than what you described?

2 A. They do different grants and stuff. I don't know. I

3 really can't tell you, because I wasn't following

4 Love Thy Neighbor. I was working.

5 Q. What period of time were you involved with Love Thy

6 Neighbor?

7 A. Maybe up to 2002.

8 Q. Okay.

9 A. I was always there with my mother for anything she

10 asked me as a daughter, but not as a --

11 Q. I understand.

12 A. -- worker or whatever.

13 Q. Were you paid at some point by Love Thy Neighbor in

14 earlier years?

15 A. No. I was never really paid. I'm a volunteer for

16 most of these things.

17 Q. Is Love Thy Neighbor still in existence?

18 A. I think they might have stopped existence recently,

19 and I'm not sure, because again, I have enough

20 problems of my own.

21 Q. Okay. So the Mastery Center was a d/b/a for Love Thy

22 Neighbor as far as you know?

23 A. Um-hmm.


29

1 Q. But it also sounds like it had a somewhat different

2 business?

3 A. There was tutoring.

4 Q. There was tutoring. Okay. When was the Mastery

5 Center formed, to your knowledge?

6 A. I'm trying to think. 2007.

7 Q. Okay. All right. So Love Thy Neighbor recently you

8 believe stopped existing and the Mastery Center --

9 A. The Mastery Center stopped -- the Mastery Center, my

10 mom wanted to do that Solomon's Place, but changed it

11 to the Mastery Center. Because of my educational

12 background, I did a lot to help her try to implement

13 it.

14 Prior to that I used to do tutoring myself.

15 But I have arthritis. And when it started to flare

16 up in 2007 and 2008, I started to get sick. I

17 couldn't help her as much. So I think that might be

18 a little blurry area as to what's going on with the

19 Mastery Center and who is doing what. I started to

20 get sick over that two-year period. So I would be

21 around for things, but I wasn't really around as much

22 as I could have been or -- I couldn't take any real

23 serious roles, in a sense.


30

1 Q. So after 2008 did you ever take on a serious role in

2 the Mastery Program?

3 A. Anything that anybody asked me to do, I would help

4 them.

5 Q. From time to time you still did some work --

6 A. Any --

7 Q. Let me finish my question. From time to time you

8 still did work for the Mastery Center?

9 A. Yes.

10 Q. And from time to time did you still get paid by the

11 Mastery Center?

12 A. I think I only got paid one time.

13 Q. When was that?

14 A. I don't remember when. I wasn't trying to get paid.

15 I think I only got paid one time, but I think it was

16 because of her payroll they had to pay me something.

17 The payroll -- whoever the paycheck person was said

18 they had to pay me something or something. So she

19 just gave me one check. I think it was just one

20 check.

21 Q. Earlier in the process?


23 Q. Okay.


31

1 A. I could find out, but I just don't remember right

2 now.

3 Q. All right. Now, you said Solomon's Place was being

4 changed to this tutoring facility; is that right?

5 A. That was what she initially -- I really wish you had

6 her here. She is the one you need to find out from.

7 I don't know. You're asking me questions that aren't

8 mine.

9 MR. FURLONG: Just answer to the best of

10 your ability. If you don't know, tell him.

11 THE WITNESS: I really don't know.

12 BY MR. ROONEY:

13 Q. But did you say Solomon's Place was being changed to

14 the Mastery Center?

15 A. The concept, not so much the event or place or

16 whomever. It was her concept in her mind.

17 Q. That's where I'm confused. Solomon's Place, did that

18 actually exist in some particular building?

19 A. Yes, 33 Durham.

20 Q. Durham?

21 A. D-U-R-H-A-M.

22 Q. Yup. Okay. So I guess going back to my original

23 question, is the Mastery Center still in existence or


32

1 not?

2 A. No.

3 Q. It definitely is not?

4 A. No. In fact, I think I mentioned to you that it

5 stopped somewhere around February or so of 2010.

6 Q. Okay. I think you did. Do you know whether you were

7 ever -- did the Mastery Center, to your knowledge,

8 have officers as well?

9 A. I don't know.

10 Q. Okay. So it formed around 2007-2008. Did it

11 actually run some activities in those years?

12 A. Yes.

13 Q. Okay. Out of 33 Durham or in other places?

14 A. No. No. It was on Genesee Street, 2925 Genesee.

15 Q. Okay. Is that where it has always been located, 2925

16 Genesee?

17 A. Yes. No. No. Nope. It was actually another spot

18 too. I forget the number. It was another spot on

19 Genesee before that one.

20 Q. Did it ever do business out of 33 Durham?

21 A. No.

22 Q. That was just Solomon's Place?

23 A. I don't -- you're asking me questions I don't know.


33

1 Q. Okay. So wherever it was on Genesee Street, either

2 2925 or prior to that at some other location, what

3 was the Mastery Center doing in those days, 2007 and

4 2008, providing tutoring services?

5 A. Um-hmm.

6 Q. Yes?

7 A. Yes.

8 Q. To whom?

9 A. Students, church, anybody.

10 Q. Anyone?

11 A. Children, adults, whoever.

12 Q. Did it have an affiliation with any private or public

13 school at the time?

14 A. No.

15 Q. Did it advertise?

16 A. Yes.

17 Q. And I take it the tutoring took place right there at

18 2925?

19 A. Yes.

20 Q. All right. Did you do some of the tutoring yourself?

21 A. Of course.

22 Q. And your mom did, as well?

23 A. No.


34

1 Q. How many different people did tutoring services at


3 A. Maybe fifty.

4 Q. Fifty?

5 A. Fifty or more.

6 Q. Okay. You know, in looking at this matter, there's a

7 name that keeps popping up. Gordon Williams. Do you

8 know who he is?

9 A. Yup.

10 Q. Was he ever involved in the Mastery Center?

11 A. He was involved with Love TNATS Ministries.

12 Q. Okay. And what role did he have for the ministries?

13 A. I don't know. I don't know him that well.

14 Q. So you have no idea what his role was?

15 A. I don't know him that well.

16 Q. I understand that, but you have no idea what his role

17 was for Love TNATS Ministries?

18 A. No.

19 Q. Does he live in Buffalo?

20 A. I don't know.

21 Q. Do you --

22 A. I don't know him that well. I don't know where he

23 lives.


35

1 Q. Do you know if he lives in Western New York?

2 A. Honestly, I don't know him. I thought he lived

3 someplace else, and then he was here too, but that's

4 all hearsay.

5 Q. Actually, I think at some point we found a telephone

6 number. It was a Kentucky area code.

7 A. I thought it was Pennsylvania. You're saying

8 Kentucky. I'm thinking Pennsylvania. I don't know

9 him that well.

10 Q. Pennsylvania, Kentucky, it's all the same.

11 A. I don't know him that well, yeah.

12 Q. Do you know whether Mr. Williams was involved in any

13 other entities with which your mother was involved?


15 Q. I mean, was he an employee or did he work or provide

16 services for any other entity?

17 A. I don't know him. I know -- because I think that's

18 where you're going, you're -- because he has the

19 Crossroads entity. I know that. That she

20 transferred this thing to --

21 Q. Okay. What do you know about his involvement with

22 Crossroads?

23 A. He is involved with it.


36

1 Q. That's it? Do you know what he does for Crossroads?

2 A. I think he owns it.

3 Q. Is he the sole owner?

4 A. No, he is not. He is the owner, and there's

5 another -- Rosalind is the other owner.

6 Q. Rosalind Redfield?

7 A. Yes.

8 Q. You said that your mother transferred something to

9 Crossroads. What did she transfer?

10 A. The lease from 75 Hickory Street on May 18th, 2010.

11 Q. How long have you known, in any capacity, Mr.

12 Williams?

13 A. I'm not going to -- I really don't know. I kind of

14 met him in passing, so I don't really know him.

15 Q. I understand you don't know him well.

16 A. I've seen him.

17 Q. Did you know anything about him ten years ago?

18 A. No.

19 Q. Five years ago?

20 A. No.

21 Q. So sometime in the last several years, three years or

22 so?

23 A. Maybe one. I don't really know him that well.


37

1 Q. All right. What about Rosalind Redfield? Do you

2 know her at all?

3 A. I know Rosalind.

4 Q. Okay. You know her better than Mr. Williams, I take

5 it, from your answer?

6 A. Yes.

7 Q. Okay. And you understand that she is a part owner of

8 Crossroads?

9 A. Yes.

10 Q. How long have you known Ms. Redfield?

11 A. I've known her since she was eight years old, but I

12 don't know how old she is now, but from the time she

13 was eight.

14 Q. She will appreciate that.

15 A. From the time she was eight until, we'll just say

16 recently, I --

17 Q. Is she related to you?

18 A. She is not related to me. My mother and her father

19 married for, like, a month.

20 Q. Oh, okay. All right.

21 A. And then they divorced.

22 Q. All right.

23 A. And then I didn't see her, at all, ever --


38

1 Q. All right.

2 A. -- until --

3 Q. So for a month she was a stepsister of yours?

4 A. Yup, one month, just about. She was eight years old.

5 Q. Did you live in the same house for a month?

6 A. Yes.

7 Q. How long did you live in the same house?

8 A. A month or less.

9 Q. Okay.

10 A. They moved in my room, but they had a different last

11 name at the time, so I didn't even know they were the

12 same person, because she had a different last name.

13 I didn't know she had gotten married. I didn't know

14 that she had children or anything about that.

15 Q. Did you stay in contact with Ms. Redfield after that?

16 A. No. I saw her once.

17 Q. How do you -- how did you get back in contact with

18 her?

19 A. My mother.

20 Q. When did that happen?

21 A. I don't know. I can't tell you.

22 Q. 1990s, 2000s?

23 A. I don't know. It wasn't 2000. I don't know. I


39

1 really don't know.

2 Q. Prior to the time the lease was assigned to

3 Crossroads?

4 A. Yes.

5 Q. Do you know the circumstances in which you came

6 reacquainted with Ms. Redfield?

7 A. Mm-mm. No.

8 Q. Do you know of anyone else besides Ms. Redfield and

9 Mr. Williams who had or has a role in Crossroads?

10 A. Nope.

11 Q. As far as you knew it was those two people, Redfield

12 and Williams that were Crossroads; is that right?

13 A. Yes.

14 Q. Do you know anything about the work that

15 Crossroads -- well, let me ask you this. Do you know

16 when Crossroads came into existence?

17 A. No.

18 Q. Do you know what work they performed prior to the

19 assignment of the lease at 75 Hickory?

20 A. Um-hmm.

21 Q. Okay. What sort of work did they perform prior to

22 that?

23 A. They were -- oh, I don't know. You mean before they


40

1 came into 75 Hickory?

2 Q. Yeah. Yeah.

3 A. No, I don't know that.

4 Q. Okay. Do you know if they did anything prior to

5 that?

6 A. I don't know that.

7 Q. Okay. Did Ms. Redfield and Mr. Williams ever have a

8 prior business together?


10 Q. Do you know what Ms. Redfield did prior to becoming

11 involved with Crossroads?


13 Q. Now, was Crossroads ever affiliated in any way with


15 A. No.

16 Q. Okay. So if anyone ever indicated that Crossroads

17 was the former Love Thy Neighbor, that's definitely

18 not accurate, is it?

19 A. That's not accurate.

20 Q. All right. And you don't have any financial interest

21 in Crossroads, do you?

22 A. No.

23 Q. Okay. Okay. I take it you, on behalf of the Mastery


41

1 Center did have some discussions with the owners of

2 75 Hickory prior to the Mastery Center entering into

3 a contractual relationship with them?

4 A. The diocese?

5 Q. Yes.

6 A. Yes.

7 Q. So you had said that you had done work for the

8 Mastery Center in 2008-2009, but you also did some

9 work for the Mastery Center in lining up 75 Hickory?

10 A. Yes.

11 Q. Were you primarily responsible for that, finding that

12 space for the Mastery Center?

13 A. Actually --

14 Q. Was it you or your mom or both?

15 A. It was me doing a lot of the leg work, but it was her

16 directing me to do the leg work.

17 Q. Okay. Sounds like a mother-daughter relationship.

18 So she asked you to do it and she would tell you

19 things to do and what to do, and she would oversee

20 what you were doing?

21 A. Yes.

22 Q. Had you looked at other spaces?

23 A. Yes.


42

1 Q. What were you -- what was the Mastery Center hoping

2 to do at 75 Hickory?

3 A. Well, what the Mastery Center actually did do at the

4 75 Hickory --

5 Q. Actually, that's not my question. What were you

6 thinking about doing when you were getting the space?

7 Did it turn out to be the same thing the Mastery

8 Center actually did?

9 A. Yeah.

10 Q. Tell me what that was.

11 A. Renting space to the -- anybody who wanted to use it

12 for even birthday parties and that type of stuff, and

13 any educational type of activities that were -- so

14 they wanted to do -- I think initially they were

15 looking to do a daycare center and some tutoring, and

16 renting space to anybody else who wanted to do that,

17 and to actually establish their own -- to have their

18 site there.

19 Q. Okay. To move it from 2925 Genesee?

20 A. Um-hmm.

21 Q. So they would actually have some offices there?

22 A. Yes.

23 Q. Why did they want to leave 2925 Genesee, if you know?


43

1 A. I don't know. It wasn't -- I think it was just

2 because it was a bigger spot.

3 Q. Okay. I'm a little unclear. Was the Mastery Center

4 interested in just getting the space and renting it

5 out or were they also -- they were also --

6 A. They were using it themselves.

7 Q. So they were going to use it as offices?

8 A. Yes.

9 Q. They were going to do their own daycare or line up

10 another vender to do the daycare?

11 A. I don't know.

12 Q. Okay.

13 A. That was a conversation, so I don't really know.

14 Q. There was a conversation?

15 A. Yeah.

16 Q. Between whom?

17 A. My mom and other people.

18 Q. You mean, it was something that was just being

19 discussed and hadn't been settled?

20 A. Yes.

21 Q. Who did you first talk to about 75 Hickory? Who

22 represented the diocese?

23 A. Tom Peters.


44

1 Q. Did you ever talk to Tom before?

2 A. I talk to Tom all the time.

3 Q. Okay.

4 A. Tom was the Assistant Superintendant of the Diocese,

5 overall the nonpublic schools, so --

6 Q. All right. And tell me about that communication with

7 Mr. Peters.

8 A. We were just talking and he told me the space was

9 there.

10 Q. Oh, so he is the one that first alerted you of the

11 existence of the space?

12 A. Yeah.

13 Q. And who did you talk to next? Did you talk to the

14 parish?

15 A. Steve Roth, R-O-T-H. I never talked to the parish

16 guy.

17 Q. There's a Father Herberger?

18 A. Yeah, I didn't talk to him until after. Steven Roth

19 is the person at the diocese that handles leases.

20 And also when they were looking for another space at

21 this old St. Lawrence Building, so that was -- Steve

22 Roth was looking -- they were looking at space there

23 too.


45

1 Q. The Mastery Center was?

2 A. Yes.

3 Q. And did -- the St. Lawrence Building was also owned

4 by the diocese?

5 A. Um-hmm.

6 Q. And do you recall what you told Steve Roth about what

7 the Mastery Center was interested in doing?

8 A. Yes.

9 Q. Okay. And what was that?

10 A. They wanted to do tutoring.

11 Q. Okay.

12 A. See, tutoring was the underlying concept.

13 Q. That was the big -- there was a primary intention

14 here, and that was to use it as tutoring?

15 A. Um-hmm.

16 Q. Did you -- by the way, did you tell Mr. Roth that you

17 were an employee of the district?

18 A. Yeah. He knew I was an employee of the district,

19 because even when we were originally looking at the

20 space at St. Lawrence, that was, at least -- that was

21 a longer time ago. I've always been an employee of

22 the district.

23 Q. So when did you talk to Mr. Roth about St. Lawrence?


46

1 A. Maybe 2005, 2006, 2007.

2 Q. When you talked to him about St. Lawrence it was in

3 your capacity as a Mastery Center representative, not

4 as an employee of the district?

5 A. As a daughter. Yes, it was as a daughter for my

6 mother.

7 Q. Did it have anything to do with your role as a

8 district employee?

9 A. No.

10 Q. And when you talked to Mr. Roth about 75 Hickory, did

11 you tell him that the district was in any way

12 interested in using that space?

13 A. I did.

14 Q. What did you tell him?

15 A. I told him that maybe we could use it as the access

16 center, but I didn't have any authority to do

17 anything with it.

18 Q. So when you said the access center, what you're

19 referring to is the facility perform those services

20 that you and I talked about at the beginning, the

21 parent involvement and --

22 A. Yes.

23 Q. -- the teacher professional development for


47

1 nonpublics?

2 A. Yes. Yes.

3 Q. So you had in mind that this was -- this might be

4 good space to use for that purpose when you were

5 first talking to Mr. Roth?

6 A. Yes.

7 Q. Did you say anything else to him about what the

8 school might do with the space?

9 A. No.

10 Q. At this point had you talked to anyone else at the

11 district about possibly using that space for the

12 access center?

13 A. No.

14 Q. All right. So who negotiated this deal between the

15 Mastery Center and the diocese? I take it you and

16 Mr. Roth?

17 A. Um-hmm.

18 Q. Was anyone else involved?

19 A. My mother.

20 Q. She -- did she actually talk to Mr. Roth as well?

21 A. She might have. I'm not sure.

22 Q. Did you have -- were you the primary interface --

23 A. Yes.


48

1 Q. -- with Mr. Roth?

2 A. Yes. Um-hmm.

3 MR. ROONEY: Off the record.

4 (Whereupon, a recess was taken.)

5 BY MR. ROONEY:

6 Q. Did you have any -- was the Mastery Center, to your

7 knowledge, working, at all, with Educational

8 Enterprises?

9 A. Yes.

10 Q. What is Educational Enterprises?

11 A. SES provider, supplemental educational services

12 provider.

13 Q. Prior to getting the space at the Mastery Center did

14 Educational Enterprises do anything -- actually, let

15 me phrase it a different way. Prior to the Mastery

16 Center obtaining the space at 75 Hickory did

17 Educational Enterprises do any work for the Mastery

18 Center?

19 A. No. But I -- no.

20 Q. Okay. I take it you were -- were you interested in

21 having Educational Enterprises get involved at 75

22 Hickory?

23 A. Yes.


49

1 Q. And I think you even told Steve Roth this much?

2 A. Actually, I forgot that they originally wanted --

3 when he asked about the Mastery Center it was

4 actually Educational Enterprises, not the Mastery

5 Center that wanted 75 Hickory Street.

6 Q. Explain that. This is news to me.

7 A. That's -- now that you said it, I'm thinking, oh, it

8 was actually them who wanted it.

9 Q. Did you do any work for Educational Enterprises?

10 A. I was working with them.

11 Q. When were you working for them?

12 A. Not working for them, working with them. Actually,

13 it was in 2009, early 2009.

14 Q. What did you do with them?

15 A. I was working to try to get a collaboration with the

16 Mastery Center and Educational Enterprises for

17 tutoring, because my mother does not tutor. They

18 tutored and --

19 Q. It would be a good fit?

20 A. Yes.

21 Q. So from around 2009 you began having some discussions

22 with Educational Enterprises to get them to provide

23 tutoring services to the Mastery Center?


50

1 A. Yes.

2 Q. Who at Educational Enterprises did you have contact

3 with?

4 A. Dr. Glena Tyler and another guy.

5 Q. Do you know who the other guy was?

6 A. I forget his name.

7 Q. Okay.

8 A. I forget his name.

9 Q. And it had to do with the --

10 A. I --

11 Q. Go ahead, ma'am.

12 A. I have them.

13 Q. Yup. I'm sure you do. Is -- I'm showing you, just

14 for the record, a type-written undated letter. It

15 just says dear Mr. Roth at the top.

16 A. Um-hmm.

17 Q. Is this something you typed, ma'am?

18 A. My mother and I or I.

19 Q. Either you or you with your mother's help?

20 A. Um-hmm.

21 Q. In number two it says in collaboration with

22 Educational Enterprises, free tutoring services will

23 be provided to Buffalo public school students


51

1 targeting students in the surrounding neighborhood.

2 A. That was from Educational Enterprises. That's why I

3 wanted to -- I wanted to almost give you a back

4 question when you asked why the Mastery Center wanted

5 to move from 2925. They actually -- I think that the

6 Mastery Center wasn't really doing any tutoring, so

7 there wasn't anything going on with the Mastery

8 Center.

9 When Educational Enterprises entered the

10 picture, then that's when -- that's why they were

11 coming, so Educational Enterprises would do the

12 tutoring.

13 Q. So prior to moving to 75 Hickory the Mastery

14 Center --

15 A. Wasn't doing --

16 Q. -- wasn't doing anything?

17 A. Right. Because I was sick and I couldn't help my

18 mother to organize anything.

19 Q. That's helpful, so they really hadn't done anything

20 up to that time?

21 A. Right.

22 Q. They had aspirations of doing things?

23 A. I think when Educational Enterprises came in, they


52

1 came in almost as a helper to my mother, where I --

2 because I had really bad exacerbation of the RA and

3 asthma, so I was going back and forth to the doctor.

4 I was really sick. There was no way I could help. I

5 was almost trying to coordinate something where other

6 people could help my mom.

7 Q. Okay. Now, so number two refers to this free

8 tutoring service provided to Buffalo public school

9 students targeting students in the surrounding

10 neighborhood. Had you given some thought as to how

11 that was going to work?

12 A. That wasn't my -- that was her role, Dr. Tyler.

13 Q. Dr. Tyler from Educational Enterprises?

14 A. Yeah. I wouldn't know.

15 Q. Although, this your letter, right?

16 A. This was all suggested. None of this is actually

17 something that -- it wasn't, like, it was leasing the

18 space yet. In addition to --

19 Q. You were interested in leasing the space, right?

20 A. Yes, but that was part of the requirements for the

21 negotiation, was what possible things might you be

22 thinking about to do in the space is what Mr. Roth

23 asked for.


53

1 Q. Okay.

2 A. So he didn't say you -- yes or no or --

3 Q. No, of course, you were giving him ideas. You didn't

4 make it up out of thin air, did you?

5 A. These are the ideas that people said they might want

6 to do. Dr. Tyler, my mom, everyone. And maybe, that

7 might be been a possible spot for the access center.

8 It was all might have been.

9 Q. The other one you're referring to is three, right?

10 A. Yes. And might have done a daycare, but these were

11 just thoughts.

12 Q. It says the via contract with nonpublic school

13 professionals will offer professional development

14 activities. What you're referring to there is

15 something like, the access center that you've

16 referred to, right?

17 A. Yes.

18 MR. ROONEY: All right. Okay. I think

19 I'll have this marked as Exhibit A.

20

21 (Whereupon, Exhibit A, typed letter, was

22 received and marked for identification.)

23


54

1 (Whereupon, Exhibit B, lease agreement,

2 was received and marked for identification.)

3

4 BY MR. ROONEY:

5 Q. Showing you a document we have had marked as Exhibit

6 B. Do you recognize this as the lease agreement

7 between the church and the Mastery Center?

8 A. Yes.

9 Q. Okay. Who drafted the contract, do you recall?

10 A. Steven.

11 Q. Mr. Roth?

12 A. Yes.

13 Q. Okay. And if you look at page twenty-two, I take it

14 that's your signature there?

15 A. Yes.

16 Q. And you had authority to bind the Mastery Center to

17 this contract, right?

18 A. I guess, because I did.

19 Q. Okay. If you look at page three, the financial terms

20 of the arrangement are set forth here, correct?

21 A. Yes.

22 Q. And so it was something that started thirty-two

23 thousand dollars from December 1, 2009 and would


55

1 increase each of the five years of the contract,

2 right?

3 A. Yes.

4 Q. All right. Okay. When you talked to Mr. Roth were

5 you in any way careful to try to separate your role

6 as an employee of the district from your role as an

7 employee -- as a daughter -- an --

8 A. An agent?

9 Q. An agent of the Mastery Center?

10 A. Definitely.

11 Q. What steps did you take to make sure the line wasn't

12 crossed?

13 A. I never told him that I had anything to do with the

14 district in -- and he knew that.

15 Q. And how -- maybe you can explain what you mean by

16 that.

17 A. Well, when I would talk with Steven I would always

18 let him know if I was doing this it was for the

19 Mastery Center.

20 Q. This, being the contract for the Mastery Center?

21 A. Yes. It had nothing do with -- absolutely nothing to

22 do with any district activities.

23 Q. Okay. Did you call -- did you talk to him from your


56

1 own phone or from the district phone?

2 A. My cell phone.

3 Q. Always your cell phone?

4 A. Um-hmm.

5 Q. Okay.

6 A. That's the number he has for me.

7 Q. What's your cell phone number?

8 A. 440-7749, you know.

9 Q. Is your telephone number at work 816-3966?

10 A. That's the broad number.

11 Q. Okay. Just a general number?

12 A. Um-hmm.

13 Q. Now, when you reached this agreement with respect to

14 the financial terms, did you do some research to

15 decide whether to -- to determine whether that was a

16 fair price the Mastery Center was paying?

17 A. I would say -- I don't think I did any of that.

18 Q. Okay. All right. So someone else, whether your mom

19 or someone else did that?

20 A. Yeah, I was sick, so there was really -- at this time

21 I was, probably, just facilitating a paper movement.

22 Q. Over what period of time -- I don't want to delve

23 into your illness, but during what period of time


57

1 were you sick?

2 A. What happens with this particular disease is, it's

3 progressive, so sometimes for a while you don't know

4 you're sick. So in about October or November of 2008

5 I started to really get sick with allergies and

6 having asthma attacks, and just very -- just a

7 variety of different things. I had been in remission

8 with the RA prior to that, so I didn't know that it

9 might be coming back.

10 Q. Um-hmm.

11 A. So what happens is my joints would swell and I would

12 be out for a little while. This would happen -- it

13 was just a big mess. Somewhere in October of 2008 is

14 where it started, but it is so insidious that it hits

15 you at different times, so you really don't know.

16 What happened I think was about June of 2009 I

17 finally got to the rheumatologist. I was going back

18 and forth to my primary. So the primary, I would go

19 in and they would give me the Albuterol treatments,

20 so I'm going back and forth to the primary, and they

21 were treating it with Prednisone things.

22 And they would give me a packet and I would be

23 okay for three or four weeks. Then once the


58

1 Prednisone packet went away, all the symptoms would

2 come back again. So it was going back and forth and

3 back and forth.

4 So in June the rheumatologist said I'm sorry,

5 Deb, it's back in full force. So he put me on a

6 continual Prednisone and put me back on Methotrexate

7 and back on all of the medications to try to control

8 it, but it's still not in control, even yet.

9 Q. Even today?

10 A. Yes.

11 Q. Okay. And so you're saying, though, at the time this

12 lease was entered into on behalf of the Mastery

13 Center, your -- your physical condition really

14 prevented you from doing any research into --

15 A. I was --

16 Q. -- fair market value?

17 A. No.

18 Q. Has that really been true since?

19 A. Yes.

20 Q. So you really haven't been able to make those sorts

21 of determinations since 2009?

22 A. I have been -- I have really been under a lot of

23 compromise in that regard, yes.


59

1 Q. All right. So even since November 2009 your physical

2 condition --

3 A. Has --

4 Q. Hold on. -- your physical condition has prevented

5 you from determining what is fair market value for

6 the property?

7 A. Yeah.

8 Q. Okay. All right. So you enter the lease, I think

9 it's November 2009. What -- what does the Mastery

10 Center do with the space right away?

11 A. They moved their things in.

12 Q. The Mastery Center does?

13 A. Yes. They started doing -- I don't know. I

14 really --

15 Q. Okay.

16 A. I'm telling you I'm sick, so --

17 Q. That's what I'm asking.

18 A. You will find that as of January or so, I'm even off

19 the Mastery Center. I'm off everything, because I'm

20 sick.

21 Q. Okay.

22 A. So even though I helped them to move this as far as

23 paper, I really wasn't able to do a lot of the things


60

1 that --

2 Q. Okay. And was tutoring going on?

3 A. I don't know. I think -- I don't know.

4 Q. Okay. You just would be guessing?

5 A. I would be guessing.

6 Q. All right. I don't want you to do that. When the --

7 at some point the lease was assigned to Crossroads,

8 right?

9 A. Yes.

10 Q. Okay. Do you recall when that happened?

11 A. May 18th, 2010.

12 Q. Okay. And did you participate in any way in that

13 assignment?

14 A. What do you mean when you say participate?

15 Q. Did you sign the --


17 Q. Did you talk to Steve Roth?

18 A. I put out with the parties -- I told Steve that one,

19 I'm not involved with anything, but I tried to put

20 the parties in the same room.

21 Q. What does that mean, you're not involved in anything?

22 A. I wasn't working. I was sick and I wasn't working

23 with anything, so just like I'm telling you, I don't


61

1 know what was going on.

2 Q. You weren't talking to Mr. Roth as a representative

3 of the school district, were you?

4 A. No.

5 Q. And you weren't talking to him as a representative of

6 Crossroads, you were --

7 A. No.

8 Q. -- talking to him as a representative of the Mastery

9 Center?

10 A. No, as a person who knew Steve Roth. I just wanted

11 to make him aware of Debbie Buckley. I was talking

12 to him as me.

13 Q. Okay.

14 A. Not a representative of anyone.

15 Q. Did you suggest to him that they sign the lease with

16 a different entity?

17 A. No, I asked him, because I was sick and because I

18 wasn't involved with the Mastery Center and I had

19 originally signed this with him, I asked him -- and I

20 knew that I wasn't going to be able to help my

21 mother, and I didn't know what was going to go on

22 with anybody else, I asked him if he wanted to

23 dissolve it or did they want to do a reassignment.


62

1 He said after they all -- everyone else

2 discussed it, they wanted to do an amendment. I said

3 dissolve it altogether. That's where I was at,

4 because I knew I wasn't going to be available to him

5 or anybody else.

6 Q. I guess I'm confused. Why would the lease be

7 dissolved? Why would the church have dissolved the

8 lease?

9 A. I don't know, but I was telling him I'm not there for

10 him to call. He did call me, but I was really trying

11 to tell him, I'm not in this. So therefore, whatever

12 happens from here, I'm not here as Debbie Buckley.

13 So therefore, I just didn't want him to have anything

14 else to say to me about it.

15 Q. Okay. How many conversations did you have with him

16 on --

17 A. That was one conversation.

18 Q. Okay. How many conversations did you have with him

19 about the assignment, just this one?

20 A. The one.

21 Q. In person, on the phone?

22 A. In person.

23 Q. So you actually went over to the --


63

1 A. I met him.

2 Q. -- diocese office and met with Mr. Roth?

3 A. I'm not sure if I met him there or someplace else,

4 but I know I met him in person.

5 Q. Was anyone else present at that meeting?

6 A. I think Rosalind was there.

7 Q. Okay. So it was you, Ms. Redfield, and I assume she

8 was there as a representative of Crossroads?

9 A. I don't know at this point.

10 Q. Okay.

11 A. I'm not sure what they were doing at the time.

12 Q. You don't know?

13 A. I don't know if she was representing Crossroads at

14 the time --

15 Q. Okay.

16 A. -- of the conversation. So if I told you that, I

17 would not be telling you the truth.

18 Q. Who invited Ms. Redfield to attend the meeting?

19 A. My mother.

20 Q. Okay.

21 A. My mother might have been there as well.

22 Q. Okay. And what was the ultimate decision that was

23 made, if any, at this meeting?


64

1 A. They were going to do that amendment.

2 Q. Okay. So I guess I'm a little -- I'm unclear. Did

3 any tutoring ever take place --

4 A. I --

5 Q. Hold on. To the best of your knowledge did any

6 tutoring take place while the Mastery Center was on

7 the lease to the property of 75 Hickory?

8 A. I'm pretty sure -- I'm not sure. I'm pretty sure

9 something took place, I just don't know.

10 Q. Did the district provide any services during that

11 period of time at or -- or receive any services

12 during that time at 75 Hickory?

13 A. When you say receive services, please clarify.

14 Q. Did the district in any way benefit from any services

15 or operations that were taking place at 75 Hickory

16 during the time the Mastery Center was --

17 A. Yes.

18 Q. -- on the lease prior to the assignment?

19 A. Yes.

20 Q. Okay. And what was that?

21 A. I think some professional development. They used the

22 space. They used the space for storage. They used

23 the space to -- for deliveries, nonpublic deliveries.


65

1 Q. So some professional development, some storage and

2 some nonpublic deliveries?

3 A. Um-hmm.

4 Q. And that was going on while the Mastery Center had

5 the lease, right?

6 A. Yes.

7 Q. Okay. Anything else?

8 A. Not that I can recall.

9 Q. Okay. I think you may have hit on this a little

10 earlier, but what storage --

11 A. When you -- when 64 Bailey was no longer available --

12 Q. Yeah.

13 A. -- then when schools would request please remove this

14 or please remove that, because I knew the space was

15 there, and as a courtesy to the district, I said you

16 can take it over there.

17 Q. Okay.

18 A. And I might have been overstepping my boundaries for

19 the Mastery Center or whatever, because I just was

20 helping the district.

21 Q. Okay. Was the district charged for that service?

22 A. No.

23 Q. Some professional development took place there?


66

1 A. Um-hmm.

2 Q. What professional development?

3 A. The -- I wasn't there.

4 Q. Just based on your understanding, what you've been

5 told.

6 A. Just doing professional development over there.

7 Q. For whom?

8 A. For the nonpublic schools. The nonpublic schools

9 were using it for professional development

10 activities.

11 Q. Okay.

12 A. I don't know exactly the details of it, I'm sorry.

13 Q. Why are you laughing? Just because --

14 A. Because I don't know, and I probably should know.

15 Q. Fair enough. So this would have been Title 1

16 nonpublic --

17 A. Nonpublic --

18 Q. -- teacher development?

19 A. Yes.

20 Q. And who was providing the teacher development

21 services then, do you know?

22 A. Elaine Hayes, H-A-Y-E-S.

23 Q. And the district had a contract with Ms. Hayes at the


67

1 time?

2 A. Yes.

3 Q. Was it a contract that you had approved?

4 A. I didn't approve contracts at that time.

5 Q. Was it a contract that you signed?

6 A. No.

7 Q. Was it a contract that you had arranged in any way?

8 A. Well, I put it together.

9 Q. Sure. Of course. All right. Now, did the district

10 pay the Mastery Center for that professional

11 development work?

12 A. No.

13 Q. In fact, there was no contract between the Mastery

14 Center and the district, right?

15 A. The district was receiving free use.

16 Q. You didn't answer my question. I understand your

17 point. I'm helping you out here.

18 A. No, there was no contract.

19 Q. The district had no contract with the Mastery Center,

20 right?

21 A. Right.

22 Q. And to your knowledge the district was paying Elaine

23 Hayes -- you knew the district was paying Elaine


68

1 Hayes directly for the teacher development work she

2 was providing at 75 Hickory, right?

3 A. And at 2925 Genesee, and any other spot. She also

4 went to the school buildings as well.

5 Q. Did the Mastery Center have any contract with Elaine

6 Hayes?

7 A. No.

8 Q. Did the Mastery Center and Elaine Hayes ever exchange

9 money at any time?

10 A. No.

11 Q. Did Elaine Hayes ever provide professional

12 development services prior to the -- for the district

13 prior to the time 75 Hickory was made available?

14 A. Yes.

15 Q. And where was that? Where were those services

16 provided?

17 A. She used to work for BOCES.

18 Q. Okay. How about on her own?

19 A. At the schools.

20 Q. Okay. So prior to 75 Hickory she would just do it at

21 the schools, the nonpublic schools themselves, or

22 actually at the public schools?

23 A. I don't know.


69

1 Q. Okay.

2 A. Or at her home. She did -- she was a professional

3 developer.

4 Q. Bottom line, she was providing professional

5 development services you're telling me prior to 75

6 Hickory becoming available?

7 A. Yes.

8 Q. All right. What -- the third thing you mentioned was

9 deliveries, nonpublic deliveries?

10 A. Yes.

11 Q. What -- what is that about? Is that the -- is that

12 the equipment that you referred to?

13 A. Um-hmm.

14 Q. So storage and deliveries is the same thing?

15 A. Yes.

16 Q. Okay. Who drafted the lease agreement amendment?

17 A. I don't know. I wasn't involved with that.

18 Q. Okay. When you -- you said you met with Steve and

19 you believe that Rosalind was there as well?

20 A. Rosalind was there.

21 Q. Okay.

22 A. My mother --

23 Q. And there was a decision about the arrangement. What


70

1 did you tell Steve was the reason why it needed to be

2 assigned to Crossroads?

3 A. I said it had to be assigned to Crossroads?

4 Q. Did you say anything about it?

5 A. I was no longer going to be involved with it.

6 Q. Because of your sickness?

7 A. No, I don't even know if I said that. I told them I

8 was no longer going to be involved with it. That was

9 my recollection.

10 Q. And you never said anything about whether or why the

11 lease should be assigned to anyone?


13 Q. So what was the reason -- I'm unclear. Why did the

14 Mastery Center want to assign the lease?

15 A. Mastery Center dissolved in February of 2010, so it

16 wasn't even in existence, so -- my mom is

17 seventy-something, and she just didn't want anything

18 more to do with it.

19 Q. All right. But the Mastery Center entered into a

20 contract just about six months beforehand for the

21 space. Obviously there was some aspirations to do

22 some tutoring work. What happened during those six

23 months?


71

1 A. Well, I think it was -- it had a lot to do with

2 Educational Enterprises. There was some conflicts.

3 Q. Between Mastery Center and Educational Enterprises?

4 A. Yes.

5 Q. What sort of conflict?

6 A. I don't know.

7 Q. You have no idea?

8 A. I know that -- I do know there's conflicts, because

9 there were just conversations going on. I knew there

10 was a problem. My mother didn't want to have too

11 many more conversations with these guys. And it was

12 just a lot of things and personality conflicts.

13 Adult Ed was there as well. They were doing

14 something there too.

15 Q. Who was providing Adult Ed?

16 A. Adult Ed.

17 Q. Who was doing the Adult Ed? Was it school employees?

18 A. Yes.

19 Q. Using it for free?

20 A. Yes.

21 Q. Where was Adult Ed provided before?

22 A. I don't know, because I don't work in Adult Ed. But

23 I do know that they had one of the offices


72

1 specifically for the Adult Ed teacher and his -- and

2 his supplies or his notes and everything he was

3 keeping records with.

4 And then they had installed computers and they

5 had materials set up in there from, I'm going to say

6 maybe January or February to the end of June.

7 Q. So do you know whether Adult Education was actually

8 taking place there?

9 A. Yes, there was. As a matter of fact, it was listed

10 as a site on the Adult Education brochure.

11 Q. Who made arrangements for Adult Ed to be there?

12 A. The Adult Ed guy, I forget his name, and the Heart

13 Foundation and the Mastery Center.

14 Q. And I take it someone asked you if it was okay?

15 A. Asked me?

16 Q. Yeah.

17 A. They didn't ask me.

18 Q. They asked your mom?

19 A. They must have. It was between my mother and the

20 Heart Foundation and Adult Ed. I'm sick, so I can't

21 help all these people with this. That's why I was

22 taking that back road. Anything that would have

23 taken place during this time I was really too sick to


73

1 make the judgment call or any type of really

2 serious -- that was one of the reasons I tried to get

3 everybody together. I was too ill to make a real

4 statement in any kind of way.

5 Q. The storage, you said the equipment came over from

6 the other nonpubs, right?

7 A. Yes.

8 Q. And it was put in 75 Hickory, right?

9 A. Yes.

10 Q. Did you okay that?

11 A. Yes.

12 Q. Okay. Did you call the Plant Department to see if

13 there was somewhere else the equipment could go?

14 A. Yes.

15 Q. What did they say?

16 A. No.

17 Q. Who said that?

18 A. Sue Yeager.

19 Q. There was nowhere else to go?

20 A. We couldn't use 64 Bailey, and there's no other

21 places to put this stuff.

22 Q. So Sue Yeager said not only can you not use 64

23 Bailey, but there's no other building you can put


74

1 that stuff in?

2 A. No one told me of any.

3 Q. Wait, I --

4 A. No one said you can't use this and use this, so --

5 Q. Did you ask?

6 A. I don't -- I just -- no, I didn't ask.

7 Q. You just put it in 75 Hickory?

8 A. No, I just didn't -- I didn't know where else. I'm

9 not a plant person.

10 Q. Wait a minute, I thought you talked to Sue Yeager

11 about this?

12 A. If she says no, you can't bring it to 64 Bailey,

13 because you can't bring it, I don't know to say jeez

14 where else. I'm --

15 Q. Why wouldn't you know that?

16 A. Because I'm thinking, well, you -- if you're plant --

17 if you called me about Title 1, no one has to ask

18 me -- point to questions about Title 1 activities.

19 If you're the expert of that area, you tell the

20 person what their needs are.

21 So my thought is if we are calling you and

22 we're looking for a place to deliver things to, you

23 have to tell me where to send it to. I'm not going


75

1 to be reaching into that.

2 Q. The bottom line is, you didn't ask if there was any

3 other space, did you?

4 A. No. And she didn't tell me either.

5 Q. Did the Mastery Center to your knowledge use any of

6 the equipment that was being stored there?

7 A. Yup.

8 Q. So it wasn't just sitting in a closet, it was being

9 used by the Mastery Center?

10 A. Yeah. It can be used. You can do that.

11 Q. I didn't ask if you could do that. I asked if it was

12 being used.

13 A. Yes.

14 Q. Did the Mastery Center get charged for the use of

15 that equipment?

16 A. Mm-mm.

17 Q. What sort of equipment was the Mastery Center using?

18 A. Chairs.

19 Q. Anything else?

20 A. Tables. I don't even know if chairs and tables was

21 there. I know there was some computers there. So

22 they might have been using computer chairs and

23 tables.


76

1 MR. CAMBRIA: Don't guess.

2 MR. ROONEY: Let's take a quick break.


4 MR. ROONEY: Let's mark this as the next

5 one.

6

7 (Whereupon, Exhibit C, requisition form,


9

10 BY MR. ROONEY:

11 Q. All right. Ms. Buckley, I'm showing you a document

12 that's marked Exhibit C. And it's a document that's

13 entitled requisition form. There's a signature near

14 the bottom left. I -- it appears to be your

15 signature. Is that yours, ma'am?

16 A. Um-hmm.

17 Q. Do you -- can you tell me what's going on here with

18 this requisition form? It appears to be dated

19 January of 2010, right?

20 A. Um-hmm.

21 Q. And the Mastery Center has the lease at this time,

22 right?

23 A. Yes.


77

1 Q. And there's a whole bunch of property that appears to

2 be set up for delivery to the -- what's called the

3 nonpublic academic center?

4 A. Um-hmm.

5 Q. What's the nonpublic academic center?

6 A. Access center.

7 Q. What's code five hundred? Do you have any idea what

8 that is?

9 A. 75 Hickory Street.

10 Q. Code five hundred is --

11 A. Assigned by the district.

12 Q. How do you get a code assigned to a particular

13 location?

14 A. The Purchase Department.

15 Q. So at this point the district is recognizing this

16 facility as a nonpublic academic center?

17 A. Yes.

18 Q. Did you make any arrangements for that to happen?

19 A. Yes.

20 Q. Okay. And you obviously made those arrangements, you

21 know, by no later than January of 2010, right?

22 A. Yes.

23 Q. Now, what was this equipment being sent to 75 Hickory


78

1 for, do you know?

2 A. The professional development activities.

3 Q. Okay. So there's a TV --

4 A. They never delivered that.

5 Q. That was never delivered?

6 A. Mm-mm.

7 Q. Did you follow up to see why it wasn't delivered?

8 A. No.

9 Q. To your knowledge a TV was being purchased and it was

10 going to be sent to the Mastery Center?

11 A. 75 Hickory, yeah.

12 Q. Okay. For professional --

13 A. This was for professional development.

14 Q. For Elaine Hayes?

15 A. Yes. No, not just her, anybody, like, if any

16 nonpublic school wants to -- I thought they might

17 need a place to sit.

18 Q. Did Elaine Hayes have any role, at all, in the

19 Mastery Center?

20 A. No.

21 Q. Does she have a Mastery Center e-mail address?

22 A. I don't think so, no.

23 Q. Okay.


79

1 A. I think the only person that had a Mastery Center

2 e-mail was me, and I made one up.

3 MR. ROONEY: Can I have that marked as D,

4 please?

5

6 (Whereupon, Exhibit D, contact list, was

7 received and marked for identification.)

8

9 THE WITNESS: I didn't know about that.

10 BY MR. ROONEY:

11 Q. This is an e-mail list that was obtained from the

12 district, provider e-mail address, and obviously you

13 see here that Educational Enterprises and Elaine

14 Hayes has assigned to them [email protected].

15 Is that the e-mail you made up yourself?

16 A. That's my e-mail address.

17 Q. Okay.

18 A. That's why I said I didn't know anything about that.

19 Q. Did anyone at the Mastery Center use that?

20 A. No one.

21 Q. Even your mom?

22 A. No one.

23 Q. Did you have any role in updating this e-mail address


80

1 list?

2 A. No.

3 Q. Do you have any idea who would have put

4 [email protected]?

5 A. It is typical of -- I'm not going to do anything but

6 say no.

7 MR. ROONEY: Let's mark this as E.

8

9 (Whereupon, Exhibit E, August 2010

10 purchase order, was received and marked for

11 identification.)

12

13 BY MR. ROONEY:

14 Q. All right. Ms. Buckley, I'm showing you a document

15 marked Exhibit E. This appears to be a purchase

16 order. Is that signed by you in the lower right?

17 A. Yes.

18 Q. Okay. And it appears to have been signed October

19 26th, 2010?

20 A. To cancel it.

21 Q. To cancel it?

22 A. Yes.

23 Q. Okay. So you think there was another purchase order


81

1 that was signed at a prior time before it was

2 cancelled?

3 A. No, there was no request -- they didn't request --

4 there was no payment to be made.

5 Q. Okay.

6 A. That was made in error.

7 Q. Do you remember the circumstances behind this

8 purchase order at all?

9 A. No.

10 Q. Are you just guessing as to whether payment was made?

11 A. I know no payment was made.

12 Q. Okay.

13 A. But I don't really remember this.

14 Q. Now, the certificate that you signed doesn't say that

15 you certified that it was cancelled. It actually

16 says, I hereby certify that the articles or services

17 listed above were actually delivered to or rendered

18 to the Board of Education.

19 A. When you cancel a purchase order you have to sign it

20 as if even you were signing it for receipt.

21 Q. Okay.

22 A. So this was signed to cancel.

23 Q. So would the purchase -- before you signed it -- when


82

1 the purchase order was first formed, someone signs

2 the purchase order, right?

3 A. I guess. No. No. No. No. They sign a

4 requisition.

5 Q. Okay. So people don't sign purchase orders?

6 A. Only to pay them or to cancel them.

7 Q. Okay. All right.

8 A. This was signed to cancel.

9 Q. So the purchase order is created and then it was

10 cancelled, you signed it and dated it?

11 A. Yes.

12 Q. Okay. So you don't know -- you don't recall why this

13 purchase order was ever put together for building

14 maintenance and usage fees?

15 A. They probably asked -- Rosalind probably --

16 MR. CAMBRIA: Probably?


18 BY MR. ROONEY:

19 Q. At this point Mastery Center is no longer on the

20 lease?

21 A. Right.

22 Q. Is this a nonpublic academic center?

23 A. I don't know why this is messed up. That's why I


83

1 cancelled it. I don't know what they were doing.

2 Q. Why was it messed up?

3 A. There was no vender. I mean, I'm looking at it and

4 I, like, didn't know how it existed in this world

5 here.


7 MR. FURLONG: Jim, if the record doesn't

8 reflect it, it should. The inscription where it says

9 cancel -- on Exhibit D where it says cancel, that is

10 Debbie Buckley's handwriting.

11 BY MR. ROONEY:

12 Q. Okay. So the assignment takes place to Crossroads.

13 All right. At that point does the -- well,

14 Crossroads is on the lease. Does the district use

15 the facility for any purpose?

16 A. They are still using it.

17 Q. Still using it for the same purpose?

18 A. They had the supplies there, deliveries there. We

19 did a pilot summer program there.

20 Q. And the district paid for the summer program, didn't

21 it?

22 A. Yes, they paid the individuals to work and sell the

23 program and paid, at the time, Crossroads for the


84

1 afternoon portion of the services.

2 Q. And who authorized that?

3 A. I did.

4 Q. And was there a morning -- were there morning

5 services in the summer as well?

6 A. Yes.

7 Q. Who provided those services?

8 A. Elaine.

9 Q. Okay.

10 A. I asked her to oversee it.

11 Q. Okay. So she provided -- did she provide the morning

12 services and Crossroads provided the afternoon

13 services?

14 A. They were supposed to.

15 Q. Were there contracts entered into for those services,

16 to your knowledge?

17 A. Yes.

18 Q. Okay. I can show you, but do you recall the

19 purchase -- do you recall paying each of those

20 entities seventy-five hundred dollars for their

21 services that summer?

22 A. What's that?

23 Q. The district --


85

1 A. Yes, it was whatever was agreed upon.

2 Q. Okay. And what did you know about the services that

3 were being provided over the course of the summer?

4 A. They were supposed to do academic math and reading

5 services in the morning and enrichment activities in

6 the afternoon.

7 Q. What are enrichment activities?

8 A. Like, enrichment. Other things that aren't math and

9 reading.

10 Q. You're not sure?

11 A. Yeah, I'm not sure. I don't recall.

12 Q. Okay. You really don't know what enrichment services

13 are?

14 A. Anything that's not math, academic.

15 Q. For example, what would some enrichment services be?

16 Can you give me an example of an enrichment service?

17 A. I don't know, painting, swimming. Anything that's

18 not academic.

19 Q. Okay. So that -- do we know how many students

20 attended in the summer?

21 A. Um-hmm.

22 Q. How many?

23 A. About twelve, thirteen.


86

1 Q. Okay. How do you know that?

2 A. Because Elaine gave me a list of the students.

3 Q. Okay. And did you have to pay for each student or --

4 A. I don't think so.

5 MR. ROONEY: I want to be clear about

6 this. Let's have this marked.

7 THE WITNESS: Did I --

8 MR. ROONEY: Let's mark this.

9

10 (Whereupon, Exhibit F, E&M Enterprises,

11 Inc. August 2010 purchase order, was received and

12 marked for identification.)

13

14 BY MR. ROONEY:

15 Q. I'm showing you a document that's been marked as

16 Exhibit F. Do you recognize this as a purchase order

17 that you signed, ma'am?

18 A. Yes.

19 Q. Okay. And so -- here, actually, similar to what you

20 were just telling me, as opposed to saying cancel,

21 this one has handwriting saying it was paid?

22 A. Yes.

23 Q. And that's probably the time you signed it, Debbie


87

1 Buckley, 8/19/10; is that right?

2 A. Um-hmm.

3 Q. That's right?

4 A. Yes.

5 Q. Obviously it says here -- well, the vender is E&M

6 Enterprises, that's Elaine Hayes's business, right?

7 A. That's her mother's business, which I found out after

8 the fact.

9 Q. At the time you thought it was Elaine's business?

10 A. Yes.

11 Q. What's her mother's name?

12 A. I don't know her mother's name. I didn't even know

13 if she had authorization to work as the --

14 MR. FURLONG: Just you didn't know.

15 BY MR. ROONEY:

16 Q. Did you have any communications with Elaine Hayes

17 about this arrangement?


19 Q. Well, about E&M Enterprises doing a summer

20 registration fee for twenty students.

21 A. I asked her to do that.

22 Q. Did you have to get authorization from anyone else in

23 the district to make that arrangement?


88

1 A. No, besides Dr. Oladele, just making her aware that

2 we're doing a summer program.

3 Q. And you didn't need a contract for this?

4 A. It's a registration fee.

5 Q. Okay.

6 A. You don't need a contract for registration fees. I

7 don't think. If that was done, it was a mistake.

8 Q. If there wasn't a contract?

9 A. If it was needed and I didn't do it, then I didn't

10 know to do that.

11 Q. I guess I'm unclear. Are you paying for the

12 registration fee or the actual services?

13 A. I don't really remember at the time.

14 Q. Well, what was -- do you know what E&M Enterprises

15 was doing?

16 A. I know they were supposed to be doing reading and

17 math.

18 Q. For whom?

19 A. For some students. And they were to put together a

20 summer program.

21 Q. And you asked them to put that program together,

22 right?

23 A. I asked them to put the program together, right.


89

1 Q. And it was for Title 1 nonpubs?

2 A. Yes.

3 Q. So you weren't really just paying for a fee, ma'am,

4 were you?

5 A. Pardon me?

6 Q. You weren't just paying for the fee, you were paying

7 for the services, correct?

8 A. I see where you're going. This is a contract is what

9 you're trying to say.

10 Q. Well, the district was paying for the services, not

11 for the fee, right?

12 A. Well, that's what she proposed to me. I can't tell

13 you why it was that way.

14 Q. Was there some reason you wanted to avoid going

15 through the process of entering into a contract?

16 A. No. I didn't even know I was avoiding it in a sense.

17 Q. Okay. All right. So anyway, the payment was

18 supposed to be twenty -- three hundred seventy-five

19 dollars for each student, right?

20 A. Yes.

21 Q. And you're telling me that you think twelve showed

22 up?

23 A. I don't know. I said from my -- if you were to show


90

1 me the students, I would know. It might have been

2 twenty-five. I don't know.

3 Q. Why did you tell me earlier it was twelve or

4 thirteen?

5 A. I was guessing.

6 Q. I'm going to assume you're not guessing unless you

7 tell me otherwise.

8 A. I was guessing.

9 Q. You agree the district shouldn't pay for twenty

10 students if less than twenty showed up, right?

11 A. I would agree that they -- that she shouldn't have

12 billed for twenty students if less showed up.

13 Q. And if you knew that less than twenty showed up or

14 someone knew that less than twenty showed up, the

15 district shouldn't have paid it, regardless of what

16 this invoice said, correct?

17 A. Yes.

18 Q. Okay. So let me try to get a better feel of what the

19 facility is being used for. You're saying even after

20 the assignment of the lease it's still being used for

21 all the same purposes as when the Mastery had it, but

22 there's additional things, this summer program that

23 you made arrangements for, correct?


91

1 A. Say that again, please.

2 Q. Let me put it another way. A summer program goes on

3 in the summer, right? What happens in the fall? In

4 the fall of 2010 is that facility at 75 Hickory being

5 used for storage, professional development, all those

6 things we talked about before?

7 A. Only nonpublic professional development, and the

8 storage of the materials, only because there was so

9 many materials there.

10 Q. Okay. All right. So at some point the district

11 enters into a contract with Crossroads, right?

12 A. Um-hmm.

13 Q. Can you tell me the circumstances of how that came

14 about?

15 A. There were so many materials there.

16 My role had gotten overloaded with the

17 persistently lowest achieving schools, JIT reports,

18 joint intervention team reports. My role in the

19 district started to evolve under Dr. Oladele to

20 things that were different, which were new to the

21 district that was not there prior, such as the PLA

22 schools coming in. So in September and October and

23 November -- they actually started in August and in


92

1 July started to identify these schools as PLA

2 schools. And Dr. Oladele started giving me a lot of

3 responsibilities relating to the PLA schools.

4 Q. Okay.

5 A. And at that point in time I really was working only

6 on the PLA schools and the JIT reports and those

7 things.

8 So I was pushing this stuff to the side.

9 Anything related to nonpublics I was pushing to the

10 side, because there was nobody in the job until Jamie

11 got in the job. I was looking for someone to take

12 over the job. When Jamie finally got the job, we

13 finally hired her --

14 Q. Was she in the district before?

15 A. Yes, she was working in professional development for

16 the ARRA funds.

17 Q. Okay.

18 A. So she was already in the district. And we went

19 through the process of hiring someone to do this work

20 to -- because it had to get done. So we --

21 Q. So your role remained vacant for that time?

22 A. Yes. It was difficult to get the role filled,

23 because of a lot of things in the district going on.


93

1 Ultimately what happened is this -- as Jamie

2 came in, she is already a staff developer, so that

3 was one of the reasons I wanted to select her, so she

4 could pick up and do the things that -- she is a

5 staff developer, the hole was in staff development,

6 so that's why I wanted to pick her. That's one of

7 the reasons. In addition to her -- she was very

8 organized and she would do things in an organized

9 fashion. She would compliment the things that I was

10 pretty weak in.

11 When she came in, she started doing

12 professional development. I wasn't overseeing it

13 that well.

14 Q. You weren't overseeing it that well until she came

15 in, because you were distracted with these other --

16 A. Even when she came in I gave her the assignment to --

17 Q. Let her run with it?

18 A. This is what I need done. You're behind the eight

19 ball, you can talk to me as much as you want to, but

20 I need you to take the helm of this.

21 Then along the way, Crossroads called me.

22 Q. Who?

23 A. Rosalind. And she said listen, the district has


94

1 every room in here, they have all their stuff here,

2 and is there any way we can get payment for it.

3 Q. What did you tell her?

4 A. Yeah.

5 Q. Okay. You told her that right in that phone call?

6 A. Yeah.

7 Q. Okay. Did you at that point maybe make any effort to

8 call someone else and say maybe we should find some

9 other space for this equipment?

10 A. I talked to Dr. Oladele.

11 Q. What did she say?

12 A. She approved it.

13 Q. When did you talk to her?

14 A. I met with her every week. I don't know exactly

15 which day it was.

16 Q. Shortly after, I assume, Ms. Redfield called you?

17 A. Yup.

18 Q. Okay. All right. So what happened is Ms. Redfield

19 calls, says hey, you got all this equipment here,

20 we're not getting paid, this doesn't seem fair?

21 A. It was exclusive to the district. Everything in

22 there. There was nobody else utilizing the facility

23 besides Crossroads and the district. So because the


95

1 things were already there, that's the reason I

2 thought -- I said well, it's already there. It's a

3 decent spot. Let's look at this facility. Let's

4 get -- because even IT was looking at it and saying

5 we might get some district activities in here. We

6 wanted to get parent involvement activities in there,

7 tutoring, things for kids. We were looking at it as

8 a community site.

9 Dr. Oladele didn't have a problem with it. I

10 spoke with Dr. Williams and he didn't have a problem

11 with it, so I didn't see a problem with it.

12 Q. Okay. When the lease was assigned to Crossroads

13 there was already some district equipment there? We

14 talked about this earlier, correct?

15 A. Yes.

16 Q. So when Crossroads came in, they knew that there was

17 going to be district equipment in the facility,

18 right?

19 A. I don't think they knew that that was district

20 equipment.

21 Q. Fair enough.

22 A. I don't -- it could have -- I don't know.

23 Q. You don't know what they knew, frankly?


96

1 A. I didn't have any idea what they knew.

2 Q. Did you have any conversation or anyone else at the

3 Mastery Center have any conversation with them about

4 the equipment that was at 75 Hickory?

5 A. No.

6 Q. Now, the district paid Crossroads for work

7 previously?

8 A. For the summer program.

9 Q. For the summer program. Did you talk to Barb Smith

10 about the arrangement?

11 A. Barb Smith about what arrangement?

12 Q. About the arrangement of paying Crossroads for use of

13 the facility.

14 A. I did.

15 Q. Okay. Tell me about that.

16 A. Hold on.

17 Q. This is where it gets interesting. Take your time.

18 MR. FURLONG: We need a minute.


20 BY MR. ROONEY:

21 Q. I was asking you about a conversation with Barb --

22 just to be clear on the record here, Barb Smith,

23 about the proposed contractual arrangement for


97

1 Crossroads, and you did have a conversation with her?

2 A. Yes.

3 Q. You're looking at a document.

4 A. This one. When I would meet with Dr. Oladele or

5 Barbara Smith I would prepare what we were discussing

6 prior.

7 Q. Okay. Yup.

8 A. Nonpublic schools probably, January 2010, because I

9 wasn't even in a position, and I never met with her

10 in January of 2010.

11 Q. It was probably you forgot to change the year?

12 A. It was probably 2011.

13 Q. Okay.

14 A. In here we discussed facility cost. That was part of

15 the things we discussed, and went through all these

16 other elements. Cost was one of them.

17 Q. By facility cost, that's the only --

18 A. That's the only facility that I had.

19 Q. Can I have a copy of this before we're done?

20 MR. FURLONG: She has some scribble on

21 the back unrelated to this.

22 MR. ROONEY: We'll just copy the front.

23 MR. FURLONG: Okay.


98

1 (Whereupon, Exhibit G, meeting agenda,


3

4 MR. ROONEY: Okay. For purposes of the

5 record we have marked Exhibit G. Labeled as Exhibit

6 G is the agenda that Ms. Buckley brought with her

7 today. Do you recall anything about the conversation

8 that you had with Ms. Smith?

9 MR. CAMBRIA: I have to leave.

10 THE WITNESS: Yes.

11 BY MR. ROONEY:

12 Q. Tell me what you remember.

13 A. I was talking to her about the different facilities.

14 I talked to her about the nonpublic access center. I

15 talked to her about the 64 Bailey situation.

16 Q. Okay. Now -- so at this point, January of 2010, had

17 the idea yet been raised about entering into a

18 contract with Crossroads for use of the space?

19 A. I'm not sure.

20 Q. Okay.

21 A. I'm thinking yes. I'm thinking yes.

22 Q. Are you guessing again?

23 MR. FURLONG: Are you talking 2010 or


99

1 2011?

2 THE WITNESS: This is actually 2011.

3 MR. ROONEY: I misspoke.

4 Let me ask the question again.

5 MR. FURLONG: Timing does matter.

6 MR. ROONEY: Yes, it does.

7 As of the date of this conversation, which was

8 according to your document and your recollection,

9 sometime around January 21, 2011, was -- were you

10 talking to Ms. Smith about a proposed contract

11 between the district and Crossroads for use of the

12 space at 75 Hickory?

13 THE WITNESS: No.

14 BY MR. ROONEY:

15 Q. That came later; is that right?

16 A. I'm not sure.

17 Q. Did you ever talk to Barb Smith then about the

18 proposed contract between the district and Crossroads

19 for use of the space?

20 A. I'm going to say, probably.


22 THE WITNESS: I'm going to say I talked

23 with Dr. Williams and Dr. Oladele, because I had more


100

1 conversations with them about the proposed contract.

2 BY MR. ROONEY:

3 Q. You remember specifically you did not or you just

4 don't recall?

5 A. I just don't recall.

6 Q. All right. All right. So my understanding of what

7 you're telling me, Ms. Redfield calls -- do you know

8 when Ms. Redfield called to suggest that --

9 A. I don't know.

10 Q. -- Crossroads be paid for the use of the space?


12 Q. It was sometime presumably after January of 2011?

13 A. I'm thinking it was before.

14 Q. Any better idea than before January of 2011?

15 A. No better idea.

16 Q. And she asked if the district would pay, you said

17 yes. And then you went to confirm that with Dr.

18 Oladele and Dr. Williams, right?

19 A. No. What I normally do --

20 Q. Okay.

21 A. -- when I'm speaking with any vender, is I will say

22 to them I will pass this by Dr. Williams and Dr.

23 Oladele and then I'll let you know, but probably yes


101

1 or no.

2 In this case since the materials were already

3 in the building, professional development was being

4 paid for by the district for teachers to do

5 professional development there at the time, I'm

6 saying, probably, yes, you're going to get something

7 for using the building.

8 Q. Do you have a specific --

9 A. And I also told them -- and any time I talk to a

10 vender, I have to pass it by the superintendant, and

11 I meet with them weekly.

12 Q. Do you have a specific recollection of saying that in

13 this conversation with Ms. Redfield?

14 A. Yes.

15 Q. When I asked you earlier about this you just said

16 that you told her yes, we will pay you?

17 A. Um-hmm.

18 Q. That wasn't a fully accurate answer?

19 A. I did tell her, I said yes, but I have to pass it by

20 Dr. Oladele and Dr. Williams. I just didn't

21 elaborate.

22 Q. Okay. So then you did pass it by those two people

23 and they approved it?


102

1 A. Yes.

2 Q. All right. And how long -- how long after she called

3 you did you pass it by them?

4 A. Probably immediately.

5 Q. Okay. And did you immediately then start the process

6 of getting a contract and --

7 A. Well, let me tell you.

8 Q. Okay. Tell me.

9 A. When I said immediate, for a lot of people immediate

10 is one thing, but when you have rheumatoid arthritis,

11 immediate can be a few months.

12 Q. Were you off work?

13 A. No, I was working through the illness. What one

14 person can probably do in say, two or three days, the

15 illness actually can push something to two or three

16 months to just get the same task done.

17 Q. Okay.

18 A. So consequently I might shelf this and then come back

19 to that. Especially if you happen to have something

20 like these JIT reports coming out. Some of the other

21 requirements were taking precedence over this. This

22 is a side situation. This was not a priority, at

23 all, for the district. And it was not a priority, at


103

1 all, for me in my role at the time.

2 Q. Okay. By the way, when you spoke with Dr. Oladele,

3 did you mention that at one point in your life you

4 and Ms. Redfield were stepsisters?

5 A. No.

6 Q. And did you -- were you ever -- did you ever reveal

7 that to anyone at the school district?

8 A. I didn't think it was relevant, because one --

9 MR. FURLONG: Yes or no?

10 THE WITNESS: No.

11 BY MR. ROONEY:

12 Q. Why did you think it was not relevant?

13 A. Because I never saw her. I never met -- I hadn't

14 seen her in years, since she was eight years old.

15 Q. All right.

16 A. She is really not my stepsister is my point.

17 Q. Okay. If she were your stepsister you would agree

18 you would have an obligation to --

19 A. Yes.

20 Q. -- reveal it?

21 A. Yes. Oh, yes. If she was, yes.

22 MR. ROONEY: Let's have this marked as

23 the next exhibit, please.


104

1 (Whereupon, Exhibit H, Crossroads

2 Contract, was received and marked for

3 identification.)

4

5 BY MR. ROONEY:

6 Q. Showing you a document that's been marked as Exhibit

7 H. Do you -- this appears to be -- at least, the

8 first page appears to be a contract checklist?

9 A. Um-hmm.

10 Q. Is that your signature at the --

11 A. Yes.

12 Q. Three-quarters of the way down?

13 A. Yes.

14 Q. Okay. And what are you signifying by signing that,

15 that you're approving the contract?

16 A. No. All of the elements for a contract were there.

17 Q. Okay. And who are the other signatures here?

18 A. Dr. Oladele and Dr. Williams.

19 Q. That's Dr. Oladele's signature?

20 A. Yes.

21 Q. And that's Dr. Williams, below?

22 A. Yes.

23 Q. Now, I see Barbara Smith signed this?


105

1 A. Dr. Williams signed for Barbara, and then she

2 initialed on the bottom.

3 Q. That's where it says okay B. P.?

4 A. Yes.

5 Q. Does the chief financial officer have to sign all of

6 these checklists?

7 A. Yes.

8 Q. Why is it that Dr. Williams signed this on her

9 behalf? Do you know?

10 A. She wasn't there that day.

11 Q. Okay. Do you know where she was?

12 A. Mm-mm.

13 Q. Was there a reason why you didn't wait for her to

14 come back?

15 A. I don't know.

16 Q. Did you -- was it you who presented this to Dr.

17 Williams?

18 A. Yes.

19 Q. Was Ms. Smith -- had you made Ms. Smith -- prior to

20 your having Dr. Williams sign it, had you made Ms.

21 Smith aware of this proposed contract?

22 A. Probably. I don't know.

23 Q. All right. Have there been other occasions where you


106

1 had Dr. Williams sign a contract checklist?

2 A. Yes.

3 Q. Okay. Was it unusual for you to go ask Dr. Williams

4 to sign a contract checklist rather than have Barb

5 Smith sign it?

6 A. No.

7 Q. Now, after Dr. Williams signed it, did you make sure

8 that it went back to Barb Smith to make sure she

9 signed it as well?

10 A. Yes.

11 Q. What was the point of having Dr. Williams sign it at

12 all?

13 A. I don't know.

14 Q. You're the one who brought it to her, right?

15 A. It was just part of getting work done. It was

16 getting work done. It was nothing more than moving

17 things along.

18 Q. You had waited, according to what you testified --

19 you didn't testify, but what you said earlier, three

20 or four months?

21 A. What did I tell you about that? I also told you

22 that's kind of what happens when you're fighting a

23 disease.


107

1 As a matter of fact, at that four or five

2 portion, I did go out sick somewhere around there. I

3 had pneumonia somewhere near there. I was very ill

4 around that time.

5 Q. I guess my point is if you waited that long, why

6 didn't you wait another day for Barb Smith?

7 A. It was nothing personal. I don't know why.

8 Q. All right. So the -- the checklist is attached to

9 the contract; is that right?

10 A. Yes.

11 Q. Is that how they are normally assembled, you have

12 checklists and the contract is attached to it?

13 A. Yes, sir.

14 Q. Who prepared the contract?

15 A. I don't know.

16 Q. You didn't, did you?

17 A. I might have, or I might have had one of my

18 secretaries do it for me.

19 MR. FURLONG: Just answer if you know.

20 Only if you know.

21 MR. ROONEY: I agree with Rich. Do you

22 know?

23 THE WITNESS: I don't recall.


108

1 MR. FURLONG: Then that's the answer.

2 BY MR. ROONEY:

3 Q. Does your office ordinarily prepare the contracts in

4 these circumstances?

5 A. Yes.

6 Q. It's not the -- it usually didn't come from the

7 vender, it comes from your office, right?

8 A. Yes.

9 Q. Do you have any -- never mind.

10 Now, just looking at the contract, the second

11 page of the contract near the top it identifies Ms.

12 Redfield, and it states that she is the building

13 manager at 75 Hickory Street. Is that the position

14 she held?

15 A. I don't know. I don't know if within Crossroads they

16 gave her that designation. I don't know.

17 Q. Was it your understanding that she owned Crossroads?

18 A. At the time I knew she had something to do with it,

19 because she signed for it.

20 Q. Okay. And whenever you dealt with Crossroads, you

21 had always dealt with her, right?

22 A. Um-hmm. She was the only person I knew.

23 Q. How about Gordon Williams, was he involved with


109

1 Crossroads?

2 A. I guess he is.


4 BY MR. ROONEY:

5 Q. Why do you guess he is?

6 A. Because you told me that.

7 Q. Prior to you walking in today do you have any reason

8 to believe that Gordon Williams was associated with

9 Crossroads?

10 A. Now I do.

11 Q. That wasn't my question. Prior to walking in

12 today --

13 A. Yes.

14 Q. So you did have reason to believe he was associated

15 with Crossroads?

16 A. Yes, but not at the time of this.

17 Q. When did you learn he had something to do with

18 Crossroads?

19 A. Somewhere along the way. I don't know. I don't

20 recall.

21 Q. So you said that you had kind of charged Jamie with

22 the task of running with this; is that right?

23 A. Um-hmm.


110

1 Q. Yes?

2 A. Yes.

3 MR. FURLONG: Do we have a last name on

4 Jamie?

5 THE WITNESS: Cohen.

6 BY MR. ROONEY:

7 Q. Who negotiated this contract, you or Jamie?

8 A. I did.

9 Q. Why did you do it?

10 A. I don't know.

11 Q. You said you are very busy, but you chose to handle

12 this?

13 A. She could have. She had a lot of things on her plate

14 too. I had thought I was helping out. Nothing

15 personal. I just thought I was helping out.

16 Q. How did you agree on the financial terms?

17 A. Based on the amount of money that Rosalind asked for.

18 Q. Okay.

19 A. And she thought she should get more, but I tried to

20 bring it down, because I thought it would -- what

21 would be fair. I was looking for something fair for

22 the district.

23 Q. How did you determine whether it was fair or not?


111

1 A. I just thought it was fair.

2 Q. Okay.

3 A. It was just my own concept.

4 Q. Were you aware that it was more than the Mastery

5 Center was paying for the -- was going to pay for the

6 same space at the same time?

7 A. I thought it was equal.

8 Q. You thought it was equal. And that would have made

9 it fair?

10 A. That's what I was trying to make it, fair.

11 Q. So what you really did in terms of fairness is tried

12 to make it the same as the Mastery Center's fee

13 schedule; is that right?

14 A. The contract fee, yes.

15 Q. Yes. All right. Let me show you Exhibit B again.

16 And --

17 A. I saw it.

18 Q. Yeah, but I want you to look at it now. I guess I'm

19 getting confused. Not the first time in my life.

20 A. You and me too.

21 Q. There you go.

22 A. We all know where we're going, but let's go.

23 Q. There you go. The Mastery Center contract and it --


112

1 Exhibit B provides that --

2 MS. TORCELLO: Page two.

3 MR. ROONEY: Thank you.

4 MR. FURLONG: I think it's page three.

5 THE WITNESS: Page three.

6 MR. ROONEY: Yes, you guys are right.

7 BY MR. ROONEY:

8 Q. Year three commencing on December 1, 2011 and ending

9 on November 30, 2012, thirty-six thousand annually

10 payable in twelve-month installments of three

11 thousand dollars. That's what the Mastery was going

12 to pay from December 1, 2011 for another year, right?

13 You don't disagree with that, right?

14 A. No.

15 Q. And the year before that from December 1, 2010 to

16 November 30, 2011 the Mastery Center was going to pay

17 thirty-four thousand dollars?

18 A. Okay.

19 Q. All right. So you would arrange here that the

20 district was going to pay thirty-six thousand dollars

21 during that same period, right?

22 A. I know why.

23 Q. What's the explanation?


113

1 A. There was a telephone and a copier or something, and

2 that's what she asked me about, the telephone and

3 copier. That's why it was a little more. It wasn't

4 the rent or whatever.

5 Q. Was there ever a separate arrangement for the

6 telephone and copier?

7 A. I don't remember. That's why when you're asking me

8 about the difference, I think that's what it was. It

9 was a discussion about the telephone and copier.

10 Q. Okay. So your determination that the figure was fair

11 was based on the fact that you had as close to what

12 you negotiated when you were negotiating on behalf of


14 A. Yeah. Yes.

15 Q. All right. The contract, going back to Exhibit H,

16 ma'am, why don't you just take a look at the first

17 page of the contract. It says provided room rental

18 as requested for district IT. Why -- what is that

19 about?

20 A. Jamie -- when I had mentioned that Jamie was doing

21 all of these -- bringing in people from the district

22 to look into the facility for possible use, I

23 actually met with Sanjay.


114

1 Q. Who is Sanjay?

2 A. Sanjay Galani.

3 Q. Is he an IT guy from the district?

4 A. Um-hmm. And he had asked if the IT Department could

5 use it or set up something there. And then I

6 thought, well, if the district is going to use the

7 facility --

8 Q. Um-hmm.

9 A. -- maybe -- you know, so that was the reason was if

10 they were going to use it they would be able -- if he

11 wanted to they could come in or out. We had a

12 conversation about it. He wanted to use it.

13 Q. You and Mr. Galani did?

14 A. Yes.

15 Q. Do you know whether he ever did use it?

16 A. I don't know, because I wasn't there. I know he went

17 in there. I do know that Bill Russo was in there.

18 Q. Who is Bill?

19 A. Bill was the Supervisor of Technology or something.

20 And they were arranging for drops to be put into the

21 building. They were drops for -- what do you call

22 them. The Internet drops. Those types of things.

23 They were looking at it that closely. So therefore,


115

1 since they were looking at it that closely, I thought

2 let's not leave them out.

3 Q. Okay. The same paragraph refers to Title 1 N and D

4 programs. What is that?

5 A. Neglected and delinquent. I asked Jamie to work on

6 the neglected and delinquent program there.

7 Q. What is the neglected and delinquent program?

8 A. For children who have been incarcerated.

9 Q. And a homeless program service, do you know what that

10 refers to?

11 A. Homeless kids.

12 Q. Okay.

13 A. Anything -- anything that could possibly help the

14 kids and help the community.

15 Q. All right.

16 A. I didn't want to scale it down so that she would say

17 oh, well you only said this. I wanted it to be open

18 to whomever might want to use it at the district. I

19 didn't want it to be, like oh, you only said these

20 guys were coming.

21 Q. Okay. Was it okay for Title 1 money to be used for

22 IT, to your knowledge?

23 A. No.


116

1 Q. It was not?

2 A. No.

3 Q. Okay. And why do you say that?

4 A. You said IT.

5 Q. Yes. It's not Title 1?

6 A. Right. You said is it okay for Title 1 money to be

7 used for IT. We do pay for technology integration

8 specialists. We pay for other types of IT. You said

9 specifically IT. We don't use it for IT.

10 Q. Okay. So how was -- where was the money going to

11 come from for the IT work that was made reference to

12 in the contract?

13 A. The IT Department was going to do some professional

14 development.

15 Q. Okay. So what does that -- and they were going to do

16 professional development for teachers?

17 A. I -- that's what we had talked about doing,

18 professional development.

19 Q. So as a result, then it could come from Title 1

20 money, because it was still professional development?

21 A. It was professional development.

22 Q. So what did they have in mind, computer -- some sort

23 of computer --


117

1 A. We didn't get that far.

2 Q. So when -- when Mr. Galani contacted you, that's

3 really what he was proposing, professional

4 development work be --

5 A. Because --

6 Q. Let me finish my question. -- professional

7 development work be done by his department?

8 A. What I was going to tell you is we were discussing

9 the potential of -- WNED now covers some things. And

10 he wanted to look into the future. So the reason why

11 I'm here is I was putting that into this particular

12 contract was in the future.

13 There are times you might have something

14 funded with Title 1 funds and you have to go back and

15 have it funded by district funds. Same thing. You

16 would have to go back and then have a different fund

17 line if it's a violation.

18 It's not like it was stated well, we're going

19 to do IT here and it's going to be a violation of

20 Title 1 rules. It was set that if IT came in -- if

21 IT wanted to come in, it was available for them to

22 come in. Then another discussion would have taken

23 place.


118

1 Q. As to the funding?

2 A. As to the funding, yes, if it was something that

3 needed to be. But Bill Russo does professional

4 development.

5 MS. TORCELLO: He is a district employee,

6 Bill Russo?

7 THE WITNESS: Yes.

8 BY MR. ROONEY:

9 Q. You said he is Supervisor of IT?

10 A. Supervisor of something.

11 Q. He may not be IT?

12 A. He is IT. He is in that department.

13 Q. Okay. All right. So the -- let's move on. All

14 right.

15 A. Please.

16 Q. I don't blame you. So the lease was entered into --

17 the contract is entered into with Crossroads. Okay?

18 A. By Dr. Williams and Ralph Hernandez --

19 Q. Right.

20 A. -- board President approved it, and Dr. Williams

21 approved it.

22 Q. Do you know how the district used that facility after

23 the contract was entered into?


119

1 A. No.

2 Q. No idea?

3 A. No.

4 Q. Okay. Who would know?

5 A. Jamie.

6 Q. All right. Was it your job to know or is that beyond

7 the scope of your job?

8 A. No, it's my job to know.

9 Q. You just didn't know this particular aspect of --

10 A. I didn't know, because there was quite a few things

11 going on at this time. We had the EPOs going on,

12 lots going on, so I just didn't know.

13 Q. Was there a point that you became aware that the

14 diocese was looking for money from the district?

15 A. Yes. That's probably what was going on here.

16 Q. That's an emphatic yes.

17 A. Steve Roth called me a lot.

18 Q. Tell me about that.

19 A. He just kept calling. When are you going to get some

20 payments. When are you going to get some payments.

21 That might have been what was going on.

22 Q. What did you tell him?

23 A. I told him I'm trying to get payments.


120

1 Q. But why did the district owe the church anything?

2 A. The district didn't owe the church.

3 Q. Why did you not tell him that?

4 A. I did tell him that.

5 Q. You said you told him you were trying to get money.

6 A. I was actually speaking to him, telling him that once

7 these guys got paid, I'm pretty sure they would pay

8 him, but --

9 Q. These guys, being Crossroads?

10 A. Yeah.

11 Q. You didn't tell him you were going to be paying him

12 directly?

13 A. No. No. What I told him was the contracts were in

14 place, were going around. And then he would get his

15 payment I'm pretty sure, once they all worked out. I

16 also told him I think he should call the Crossroads

17 people. He kept calling me.

18 Q. Did he call you before Exhibit H was entered into?

19 A. I don't remember. But I'm pretty sure he -- he

20 called a lot.

21 Q. Why did he call the district looking for money prior

22 to that contract being entered into?

23 A. I don't know.


121

1 Q. Did you ever lead him to believe in any way the

2 district was going to pay the church money directly?

3 A. He might have made an assumption. I don't know. I

4 never told him directly.

5 Q. Did you ever tell him indirectly?

6 A. Oh -- no. I -- I don't know. I really don't know.

7 Q. You said oh. Was there one occasion where you might

8 have told him something?

9 A. I might have slipped or something. I might have said

10 something. I'm not sure.

11 Q. Why do you say you might have slipped? Do you

12 remember a certain conversation?

13 A. One time I had said to him maybe I would change and

14 do the contract, instead of doing it with Crossroads,

15 to do it with the district and --

16 Q. To do it with the diocese?

17 A. Yeah, the diocese, but I didn't think I could legally

18 overstep Crossroads, so there was a portion where I

19 was, like, well, we're using it, so I thought, maybe,

20 we should just pay the diocese, but I didn't know how

21 to get past this.

22 Q. Now, do you know whether Crossroads after the time

23 you entered into this agreement, Exhibit H, provided


122

1 any services?

2 A. I was not there.

3 Q. Jamie would know that?

4 A. Jamie -- I don't know. I really -- this was a side

5 bar. I just have to continue to say, it was

6 something that was on the way back -- far back burner

7 on my priority list. And I was -- I had a director

8 and a supervisor that -- that I was depending upon to

9 pick up on certain areas, such as this. There was

10 quite a few things going on.

11 Q. The director and supervisor being Dr. Oladele and

12 Jamie Cohen?

13 A. Dr. Oladele is the superintendant, she is not a

14 director in my --

15 Q. Is Jamie Cohen?

16 A. No, she is a supervisor.

17 Q. So --

18 A. I had -- Samantha Daniels was the director.

19 Q. Okay. How many times did Mr. Roth contact you?

20 A. I don't know, but it was a lot.

21 Q. Okay. And was it resolved during the time you were

22 still actively working prior to your leave?

23 A. Pardon me?


123

1 Q. Was he still calling you right before you went on

2 leave?

3 A. I'm sure he was. He called a lot.

4 Q. All right. Was there ever any conversation -- Elaine

5 Hayes and Elaine Gist, G-I-S-T, are they the same

6 person?

7 A. Yes.

8 Q. Did you ever think of having her on the Mastery

9 Center Board of Directors?

10 A. I don't know. I don't remember. I don't think so.

11 Q. Oh.

12 A. The Mastery Center, I don't even know if it has a

13 Board of Directors. There was a time I was

14 looking -- I went out in 2008 I was looking to try to

15 establish one.

16 Q. Um-hmm.

17 A. But I don't think it ever happened.

18 Q. Okay.

19 A. And I don't --

20 Q. So you think there might have been a time in 2008 you

21 were thinking of getting a Board of Directors

22 together and it never happened?

23 A. No, it never happened.


124

1 Q. Okay.

2 A. Not from my recollection.

3 Q. Regardless, you don't think Elaine was ever in

4 consideration for that?

5 A. No.

6 Q. You said that pretty fast.

7 A. No.

8 Q. She is -- I think you made some reference earlier, as

9 I understand, she is a principal at a school run by

10 your mother's church; is that right?

11 A. Yes. I didn't make any reference of that, but I do

12 know that.

13 Q. I understand. How long has she held that position?

14 Do you have any idea?

15 A. No.

16 Q. How long have you known Elaine?

17 A. I met Elaine at BOCES --

18 Q. How many years ago was that --

19 A. -- through the district.

20 Q. -- approximately?

21 A. I'm going to tell you as soon as I remember. Maybe

22 2003.

23 Q. Okay. And were you personal friends?


125

1 A. No. That's where I was first introduced to Elaine.

2 She was one of the staff developers for BOCES. I was

3 doing staff development for them. I was teaching

4 them about data.

5 Q. You were doing that in what capacity, as a district

6 employee?

7 A. As a district employee, as a supervisor.

8 Q. Okay. And did you eventually develop a friendship

9 with her?

10 A. No.

11 Q. Ever go out to dinner with her?

12 A. I did after the fact, but not --

13 Q. I'm not just talking about just in that course of

14 that BOCES work, but afterwards did you develop a

15 friendship with her?

16 A. Yes.

17 Q. Are you friends with her still?

18 A. No.

19 Q. Your friendship ended for some reason?

20 A. I was not really pleased with her performance with

21 the summer program.

22 Q. That's the program that the district paid

23 seventy-five hundred dollars for?


126

1 A. Um-hmm.

2 Q. Why weren't you pleased by it?

3 A. Because I -- I got word that it wasn't that

4 professional. And I -- I wanted it to be. I like

5 things to be done when it has something to do with

6 church, academics, I want it to be done very well.

7 She did not do it well, so I really haven't spoken to

8 her since. I felt that she did not represent the

9 district well for me.

10 Q. So I take it it made sense at that point to no longer

11 use Ms. Hayes or E&M Enterprises for any work; is

12 that right?

13 A. Not really, because she was doing a good job for some

14 of the nonpublic entities. And they still wanted her

15 to do some nonpublic professional development work.

16 Q. Oh.

17 A. So there were some schools that did not have

18 complaints. There were some people who still

19 requested her. And I didn't want to interfere with

20 whatever the consultation with the nonpublic -- if

21 they wanted to, I really didn't care whether they

22 used her or not.

23 Q. So any nonpubs she was working for specifically


127

1 requested her after that summer program that you

2 observed was not professionally run?

3 A. That's what I would think they would have had to.

4 Some schools liked her.

5 Q. Do you remember some of the schools that liked her?

6 A. Stanley Falk said they liked her, and some others.

7 But there were some who didn't like her. And so I

8 didn't interfere with that. I thought it would just

9 fizzle itself out.

10 Q. I've asked you a number of questions. I'm starting

11 to get near an ending time anyway, ma'am.

12 I think what you indicated earlier is E&M

13 Enterprises was actually not operated by Elaine, but

14 by her mother?

15 A. Yes.

16 Q. And you just don't know the mother's name?

17 A. No.

18 Q. And you -- did you tell me how you learned that E&M

19 Enterprises was run by her mother?

20 A. I think Barb Smith might have mentioned it to me.

21 Q. All right. When? Not long before your leave?

22 A. June.

23 Q. June of 2011?


128

1 A. Yes.

2 Q. Do you recall a point in which the district stopped

3 paying fees to Elaine Hayes and instead changed it

4 to where the money is paid to E&M Enterprises?

5 A. Nope.

6 Q. Do you recall an instance when Ms. Hayes asked you to

7 make sure that the district paid her as E&M

8 Enterprises rather than Elaine Hayes for tax reasons?

9 A. Yes.

10 Q. Okay.

11 A. I don't know when it was, but I do remember having a

12 conversation.

13 Q. And you did make sure that the payments thereafter

14 went to E&M Enterprises instead of Elaine Hayes,

15 right?

16 A. Yes.

17 Q. You did her a favor in that regard?

18 A. Yes.

19 Q. What did she -- do you specifically remember what she

20 asked you to do? Just please pay me as E&M

21 Enterprises?

22 A. Yes.

23 Q. Is there anything else she said to you about that?


129


2 Q. Did she tell you why it should be paid to E&M

3 Enterprises instead of --

4 A. Taxes.

5 Q. Do you know whether at that time the district had a

6 contract with E&M Enterprises?


8 Q. You was paying for services -- not you, the district

9 was, right?

10 A. Oh, Lord.

11 Q. When you were paying Ms. Hayes you were paying her

12 for her tutoring services, right? Or the district

13 was -- there -- let me ask it a different way.

14 The district had a contract with Ms. Hayes?

15 A. Yes.

16 Q. And you don't know whether or not the district had a

17 contract with E&M Enterprises at that time?

18 A. Right.

19 Q. You agree that if it didn't have a contract with E&M

20 Enterprises, the district shouldn't have been paying

21 them?

22 A. I agree that if -- say what I agree again?

23 Q. I want to make sure you're on the same page.


130

1 A. Tell me what I'm agreeing to.

2 Q. Let's go through it slowly. I can tell you're

3 confused.

4 A. Yes, please.

5 Q. You -- you just told me that at some point at your

6 direction the district stopped paying money to Elaine

7 Hayes and instead paid it to E&M Enterprises, because

8 Ms. Hayes asked that it be changed for tax reasons,

9 right?

10 A. Let me think about what you said. You said at my

11 direction I said to not pay Elaine Hayes?

12 Q. And to pay it to E&M Enterprises.

13 A. Probably, yes.

14 Q. Okay. And you did testify -- you recall that there

15 was a contract -- that the district had a contract

16 with Elaine Hayes at that time, right?

17 A. Yes.

18 Q. Okay. And you don't know whether there was a

19 contract with E&M Enterprises, right, or anything

20 like that? If you don't remember, that's okay.

21 A. Anywhere in the district or just in that office?

22 Q. For that work.

23 A. The same work?


131

1 Q. You were paying -- when you changed the payment from

2 payment to Elaine Hayes to payment to E&M

3 Enterprises, although you were paying E&M for the

4 same --

5 A. Did we cancel the other contract first?

6 Q. I don't know. That's what I'm asking you.

7 A. I don't know what happened to it. You would think we

8 cancelled it.

9 Q. Ordinarily you would cancel that and have a new

10 contract with E&M Enterprises, right?

11 A. Yes.

12 Q. That's how you thought it should have happened?

13 A. That's what I would have thought happened.

14 Q. You just don't recall if that's how it happened?

15 A. I don't remember what happened.

16 Q. Did you know that at the time the change was made

17 from Elaine Hayes to E&M Enterprises the amount that

18 had been paid to Ms. Hayes was forty-nine thousand

19 dollars; does that sound about right?

20 A. Yup.

21 Q. Any significance to that number, forty-nine thousand

22 dollars?

23 A. No.


132

1 Q. If it was another thousand you would need what? You

2 would need control board approval, right?

3 A. Yes.

4 Q. By changing it to E&M Enterprises, the district

5 didn't need control board approval; is that right?

6 A. Yes, it wouldn't.

7 Q. Did that have anything to do with the reason you

8 changed it?

9 A. No.

10 Q. All right. Do you know where E&M Enterprises is

11 based?

12 A. On Lark Street.

13 Q. Is it 52 Lark Street?

14 A. Yes.

15 Q. Now, is that -- there's a company I've run across at

16 some point, it's like a real estate company that your

17 mom is involved in. Is it --

18 MS. TORCELLO: D. F. Coleman.

19 BY MR. ROONEY:

20 Q. Were you involved in that as well?

21 A. Yes.

22 Q. Was 52 Lark Street owned by D. F. Coleman?

23 A. I'm sorry to laugh --


133

1 Q. It's okay.

2 A. -- but come on guys. 52 Lark Street? No.

3 Q. I don't know.

4 A. The reason I'm laughing here is, you guys keep

5 bringing my mom in here. And I'm thinking to myself,

6 what does my mother have to do with E&M, and what

7 does she have to do with Elaine, and what does she

8 have to do with that stuff. That's really what I'm

9 thinking. We done went over my mother. I should

10 have invited her in to answer the questions.

11 Q. You're laughing at me directly. I understand.

12 A. I mean I'm just saying it's getting pretty personal.

13 Did my mother change her socks today? Where are we

14 going with this?

15 MR. FURLONG: Ask the question again.

16 THE WITNESS: No, D. F. Coleman has

17 nothing to do with 52 Lark Street.

18 BY MR. ROONEY:

19 Q. To your knowledge does the district perform services

20 at any location that's owned by that company?

21 A. The district?

22 Q. Yes.

23 A. No.


134

1 Q. Do -- have you ever been to 52 Lark Street?

2 A. Yes.

3 Q. What's there?

4 A. Elaine's house.

5 Q. Okay.

6 A. At the time it was her dog or -- she was living

7 there.

8 Q. Okay. It's just a residential house?

9 A. Yeah. That's why I started laughing. Sorry.

10 Q. That's all right. Where is Crossroads located, do

11 you know?

12 A. I'm pretty sure it's located somewhere where Rosalind

13 or Gordon would live.

14 Q. Okay. Do you know where that is?

15 A. Nope.

16 Q. Were you aware of E&M being located on Humber Street,

17 H-U-M-B-E-R?

18 A. Yes -- E&M is not located on Humber Street. Elaine

19 is renting on Humber Street. Humber Street is a

20 house that is owned by D. F. Coleman. She moved in

21 there, because it was empty. She was looking for a

22 place to live, and I said we have an empty spot. And

23 she moved in.


135

1 Q. Are you charging -- is D. F. Coleman charging her

2 rent?

3 A. Yes.

4 Q. So it had nothing to do with the business?

5 A. No.

6 Q. It's just where she lives?

7 A. That's where she lives.

8 Q. And I've also seen an address for E&M Enterprises of

9 226 Kenview; does that ring a bell?

10 A. Yeah.

11 Q. Okay. Why?

12 A. Because that's where she lived.

13 Q. Before she went to Humber that's where she lived?

14 A. Yes.

15 Q. All right. So she lived at 226 --

16 A. She lived at 52 Lark in -- she was at 52 Lark, and

17 then she moved to the other spot, and now she lives

18 on Humber.

19 Q. All right. Did you ever disclose to anyone that

20 Elaine Hayes, you know, was renting space from a

21 company you were involved in?

22 A. By the time she rented the space she wasn't -- I

23 don't think she was even doing any work.


136

1 Q. When was that?

2 A. I don't know. I don't know when she moved in. I

3 know she moved out of the spot in -- it might have

4 been around the summertime.

5 Q. Summer 2011?

6 A. No, '10. Somewhere in there. It was a while.

7 Whenever the summer program -- she moved in around

8 the time of the summer program.

9 Q. That was 2010. Those various addresses, the only one

10 that D. F. Coleman owns is Humber?

11 A. Yes.

12 Q. Do you agree if she had been doing work at the time

13 that would be something you should disclose --

14 A. Yes.

15 Q. -- that she was renting from a property you had

16 interest in?

17 A. If she was living there, I mean, that's a little far.

18 Q. That's --

19 A. I don't know if I would have been thinking that far,

20 wherever she was living. I didn't think if I lived

21 in an apartment you would have to say -- well, how

22 would you even know who has an interest in an

23 apartment that somebody is living in?


137

1 Q. Okay. Did anyone bring to your attention at any time

2 that E&M Enterprises had listed itself on some papers

3 as being a janitorial company?

4 A. Barbara Smith told me that. Same day.

5 Q. Same day she told you about the mother?

6 A. Yes.

7 Q. And I take it that was news to you?

8 A. Yeah. Well, she told me.

9 Q. Did you ever talk to Elaine about whether she was

10 actually doing janitorial services?

11 A. Guys, I mean, I'm sick. I've got all this --

12 Q. Just the answer.

13 A. The answer is no. Like I've got time to talk to

14 Elaine.

15 Q. Okay. What's the name of your administrative

16 assistant?

17 A. Sandy Wagaman, W-A-G-A-M-A-N.

18 Q. Have you had any contact with Ms. Wagaman since your

19 administrative leave?

20 A. No.

21 Q. Neither electronic contact or --

22 A. She sends me little things. I don't respond to her.

23 Q. Little things, like, little e-mails or something?


138

1 A. Yeah, little things.

2 Q. What do you mean by little things?

3 A. Little, you know, those little heart things or this

4 or that. Those things people send.

5 Q. No one sends me heart things.

6 A. What do they call it when they send them to three or

7 ten people?

8 MS. TORCELLO: Forwards?

9 BY MR. ROONEY:

10 Q. Is this on e-mail?

11 A. Text messages.

12 Q. Okay. All right. Do you have any knowledge -- have

13 you ever heard that she shredded documents after your

14 administrative leave began?

15 A. Mm-mm. No.

16 Q. This is the first time you've ever heard that as a

17 possibility?

18 A. Well, I heard -- let me try and think who I heard it

19 from. I don't know. I did hear somebody say that

20 they stopped her, somebody stopped her. She was

21 trying to shred something.

22 Q. Who did --

23 A. They grabbed it out of her hand. I think it was one


139

1 of the board members.

2 Q. Who did you hear that from?

3 A. I think it was one of the board members.

4 Q. Okay. Do you know which board member?

5 A. Mm-mm.

6 Q. That's a no?

7 A. That's a no.

8 Q. You never directed her to shred any documents?

9 A. No.

10 Q. Were you ever involved in any way in paying salaries

11 for employees of Educational Enterprises through the

12 Buffalo School District?

13 A. Salaries? What do you mean by that? I don't know

14 what that means.

15 MR. FURLONG: Directly?

16 THE WITNESS: What kind of salary?

17 BY MR. ROONEY:

18 Q. The money they made as employees of Educational

19 Enterprises to -- you never made arrangements so the

20 district paid their salaries, did you?

21 A. No.

22 Q. Okay. And I think you said earlier that Educational

23 Enterprises has provided services to the district


140

1 both at 75 Hickory and 2925 Genesee; is that right

2 or --

3 A. That's wrong.

4 Q. Okay. How am I wrong?

5 A. Educational Enterprises are you saying?

6 Q. Yeah.

7 A. No, they looked at both of the sites or -- and I

8 think 75 Hickory, they wanted to do stuff there, not

9 the other one.

10 Q. But Educational Enterprises did provide some services

11 to the district?

12 A. Mm-mm.

13 Q. They never did?

14 A. Never.

15 Q. Have there ever been conversations with Educational

16 Enterprises about providing services?

17 A. Yes.

18 Q. Now, I think you talked to me a little earlier about

19 when you were talking as a Mastery Center

20 representative to Educational Enterprises, I know

21 they were trying to work together and you know,

22 Educational Enterprises provided tutoring services.

23 A. Um-hmm.


141

1 Q. What sort of -- who did you speak to at Educational

2 Enterprises about having them provide services for

3 the district?

4 A. Glena.

5 MR. FURLONG: What was the name?

6 THE WITNESS: Glena Tyler.

7 BY MR. ROONEY:

8 Q. What became of those discussions? You said they

9 never provided services to the district?

10 A. We were talking about having -- which one? Not

11 Educational -- I'm trying to get it clear what you're

12 asking me.

13 Q. Well --

14 A. District services, I was looking for district

15 supplemental services.

16 Q. Right.

17 A. And not only that I had these conversations with her,

18 but with other people.

19 Q. Sure, but ultimately you decided not to go with

20 Educational Enterprises; is that what happened?

21 A. Right.

22 MR. ROONEY: Off the record.



142

1 BY MR. ROONEY:

2 Q. Let's see if we can get on our way and get out of

3 here. Salvatore Spinuzza, S-P-I-N-U-Z-Z-A.

4 A. Yes.

5 Q. You seem to know him?

6 A. Yes.

7 Q. He, as I understand it, is the owner of 2925 Genesee?

8 A. Yes, sir.

9 Q. I've never been out there. How big is that facility?

10 A. It's two separate units.

11 Q. Okay.

12 A. For --

13 Q. They are actually -- two separate buildings actually?

14 A. No, when you walk in there's a larger side and then

15 there's a smaller side.

16 Q. Does the Mastery Center or did it before it dissolved

17 use the facility there?

18 A. Yes.

19 Q. Okay. During what time, do you recall?

20 A. I wrote it down in case you asked. I had to try to

21 remember. I wrote it down. 2005-2008.

22 Q. And what did the Mastery Center do at 2925 Genesee

23 Street? Because you said really the Mastery Center


143

1 wasn't doing anything until it went to 75 Hickory.

2 A. I did not say that.

3 Q. Okay. I misunderstood.

4 A. At the time during 2009 at the beginning it wasn't

5 doing anything --

6 Q. Okay.

7 A. -- at all, although it existed and it was open, it

8 wasn't doing --

9 Q. So from 2005 to 2008 what was the Mastery Center

10 doing?

11 A. Tutoring.

12 Q. And who was actually doing the tutoring?

13 A. There was staff and --

14 Q. Employees of the Mastery Center or venders?

15 A. Employees.

16 Q. Okay. It wasn't Educational Enterprises, was it?

17 A. Oh, no. I mean, I didn't even know them.

18 Q. Okay. How many employees did the Mastery Center have

19 around that time? I think you said at one point

20 there were fifty?

21 A. Yeah. I want to say then, maybe, around four or five

22 teachers.

23 Q. Four or five?


144

1 A. Yes. At varying times, so there might be two that

2 was there, one here, then two more. Maybe not at the

3 exact same time, but during the time there was

4 employees there.

5 Q. Okay. And how much of the space of 2925 Genesee did

6 the Mastery Center use? You said it was divided.

7 Did you use half of it?

8 A. I think they only used half of the one room on the

9 right-hand side. The right-hand side is larger than

10 the left-hand side.

11 Q. Did it continue to use that space even after the move

12 to 75 Hickory?

13 A. It wasn't even using it before the move to 75

14 Hickory.

15 Q. Oh, it stopped using it?

16 A. Yes. That's why I was saying there was nothing going

17 on.

18 Q. So there had at one time?

19 A. Yes.

20 Q. And actually, it was taking place at 2925 Genesee for

21 some time?

22 A. Um-hmm.

23 Q. And then around 2008 I think you said it stopped?


145

1 A. Um-hmm. Yes.

2 Q. Now, at some point did the district start using space

3 at 2925 Genesee?

4 A. Yes.

5 Q. For what purpose?

6 A. Nonpublic.

7 Q. When did that begin?

8 A. Maybe 2009.

9 Q. Was it before or after you took on your current job?

10 A. Before.

11 Q. You obviously were aware of the space at 2925

12 Genesee, right?

13 A. Yes.

14 Q. Did the district start using the space that the

15 Mastery Center had used previously?

16 A. Yes.

17 Q. That same part of the building?

18 A. They used the whole thing.

19 Q. I'm sorry?

20 A. The district used both parts.

21 Q. So they used that part and the other part. Do you

22 know what the other part had been used for prior to

23 the district using it?


146

1 A. Stuff. No. Nobody was there.

2 Q. How long have you known Sal Spinuzza?

3 A. Since 2005, whenever --

4 Q. Whenever what?

5 A. Whenever I first came there about the space.

6 Q. Did the Mastery Center have a lease with Mr.

7 Spinuzza?

8 A. No.

9 Q. Did it have any contractual arrangement with Mr.

10 Spinuzza?

11 A. No.

12 Q. Did it have a contractural arrangement with a company

13 associated with Mr. Spinuzza?

14 A. No.

15 Q. Did it pay Mr. Spinuzza for use of 2925 Genesee?

16 A. Yes.

17 Q. How much did it pay?

18 A. A thousand dollars here, twelve hundred dollars

19 there, five hundred dollars here, eight hundred

20 dollars there.

21 Q. Did your mom know Mr. Spinuzza prior to 2005?

22 A. No.

23 Q. Did you have any indirect contact with Mr. Spinuzza


147

1 prior to 2005?

2 A. I didn't know him.

3 Q. How is it he was going to let you use his space for a

4 thousand here, five hundred here, twelve hundred

5 there?

6 A. I'm going to say something you might not be aware of

7 in Buffalo.

8 MR. FURLONG: Just --

9 THE WITNESS: I'm just going to say it.

10 This gentleman is just a nice person.

11 BY MR. ROONEY:

12 Q. That's fine.

13 A. He is a nice person.

14 Q. That's fine.

15 A. And people can take advantage of him.

16 Q. Did the Mastery Center take advantage of him?

17 A. No.

18 Q. How old is Mr. Spinuzza?

19 A. I don't know. I think he is sixty-something, maybe

20 seventy.

21 Q. Like I said, I haven't been out there. Are there

22 residential quarters out there for him or just a

23 commercial building?


148

1 A. Commercial building.

2 Q. So there was never anything in writing between the

3 Mastery Center and Mr. Spinuzza? It was just an

4 ongoing pay here and there when we can, and he was

5 okay with that; is that right?

6 A. Yes.

7 Q. Okay. Am I correct, there was never a written --

8 A. Never, nothing.

9 Q. Was there even an oral understanding as to how much

10 you were going to pay?

11 A. Mm-mm. No.

12 Q. Okay. So how was it --

13 MR. FURLONG: Hang on one moment.

14 (Discussion off the record.)

15 MR. FURLONG: Go ahead, Jim.

16 BY MR. ROONEY:

17 Q. So how was it that the district started having

18 services provided at 2925 Genesee Street?

19 A. I spoke with June about possibly using the space

20 in --

21 Q. This is June --

22 A. Simmons. About using the space for the access center

23 when it first came up in 2009.


149

1 Q. Yup.

2 A. That was part of the Title 1 ARRA initiative.

3 Q. Is that A-R-R-A?

4 A. Yes.

5 Q. What does it stand for?

6 A. American reinvestment something.

7 Q. Okay.

8 A. But I spoke with her about using the space --

9 Q. Yup.

10 A. -- for the nonpublic access center as the site. And

11 she was okay with it.

12 Q. Okay. And so the nonpublic access center that you

13 later thought might be best suited at 75 Hickory,

14 prior to that you thought, maybe 2925 Genesee Street?

15 A. Because of availability.

16 Q. All right. Was it also a point that the Mastery

17 Center really didn't want to be spending any more

18 money at 2925 Genesee Street around that time?

19 A. I wouldn't know about that.

20 Q. You seem to know they were paying a little here,

21 twelve hundred there. Do you know when they stopped

22 making payments to Mr. Spinuzza?

23 A. Um-hmm. I -- I'm going to tell you that my mom


150

1 was -- made the payments after a certain point,

2 because of my sickness. All of this was going on at

3 the same time. I know my mom was making the payments

4 and arrangements after a certain point. And then

5 there was a point here where the ARRA funds came up.

6 Q. Yup.

7 A. And then I spoke with June about it. And I thought

8 this would be a good spot. And she was okay with it.

9 Q. What happened to the -- did the Mastery Center have

10 any equipment in there at the time?

11 A. Probably.

12 Q. What happened to that equipment?

13 A. It was just there.

14 Q. So the Mastery Center just kept it there?

15 A. It could be. I don't think that anyone was really

16 concerned with who was using what equipment, so it

17 was --

18 Q. What sort of equipment did the Mastery Center have

19 there?

20 A. Chairs.

21 Q. Just some furniture?

22 A. Yeah.

23 Q. Nothing very valuable?


151

1 A. Yeah, nothing serious.

2 Q. All right. So the Mastery Center really didn't care

3 about that particular property is what you're telling

4 me?

5 A. I don't think it was that as much as it was pretty

6 informal as to who used what, so --

7 Q. Yeah.

8 A. -- if nonpublic kids wanted to use something, I don't

9 think the Mastery Center wanted to stop it.

10 Q. Okay. So did the -- was the Mastery Center also

11 looking for someone else to come in and start paying

12 Mr. Spinuzza since the Mastery Center didn't want to

13 be spending more money there?

14 A. I don't know about that.

15 Q. Is it true that the Mastery Center didn't want to be

16 spending more money at 2925 Genesee?


18 Q. Did you talk to your mom about it?

19 A. I don't think she would have been opposed to it.

20 Q. To what?

21 A. Spending money at 2925.

22 Q. What happened when the district came in? Did the

23 district bring equipment there?


152

1 A. Just some things from -- yeah, some of the schools,

2 they were storing stuff there, similar to -- I think

3 one school did not have -- had some things -- oh,

4 boy. You guys are really pushing this.

5 Q. A nonpub?

6 A. Yes, it was, like, another school had some stuff that

7 was there, very similar to on Hickory Street. They

8 were just storing space for time sake.

9 Q. So was there a period when the district was using

10 that facility at 2925 Genesee Street and not paying

11 Mr. Spinuzza anything? Do you know?

12 A. I don't know.

13 MR. ROONEY: Can I have this marked?

14

15 (Whereupon, Exhibit I, 2010 Spinuzza

16 letter, was received and marked for identification.)

17

18 (Whereupon, Exhibit J, January to August

19 2010 Spinuzza contract, was received and marked for

20 identification.)

21

22 (Whereupon, Exhibit K, September 2010 to

23 August 2011 Spinuzza contract, was received and


153

1 marked for identification.)

2

3 BY MR. ROONEY:

4 Q. Let's look first at Exhibit I.

5 A. Okay.

6 Q. Yeah, it appears as though I is a letter sent by Mr.

7 Spinuzza to you, correct?

8 A. Yes, it appears that way.

9 Q. Do you recall having seen this before?

10 A. Um-hmm.

11 Q. All right. Did you have a discussion with him about

12 the topic that's discussed in writing here?

13 A. Yes.

14 Q. Can you tell me about it?

15 A. Barbara asked me to write something like this and get

16 him to sign it.

17 Q. Oh, okay. Tell me about your conversation with

18 Barbara that led to this.

19 A. She said when I met with her about this --

20 Q. This being Exhibit J?

21 A. Yes. The writing at the bottom, she said you have to

22 get something in writing or something. And then I

23 said, fine. And I typed this up. And then I went to


154

1 him and talked to him about it.

2 Q. Okay.

3 A. And then he said that's about right. And I asked him

4 if there was anything different, because I actually

5 wrote this up for him, then I gave it to him.

6 Q. When did you first talk to Mr. Spinuzza about paying

7 for utility service, gas, Internet and snowplowing,

8 things that are depicted in Exhibit I? When did you

9 first talk to him about that?

10 A. Probably in the beginning of the year. Probably

11 earlier in the year.

12 Q. Closer to January?

13 A. Or even before.

14 Q. Maybe even 2009?

15 A. Yeah.

16 Q. And did you tell him that that would be -- that would

17 be something that the district would pay for?

18 A. Yeah.

19 Q. Okay. When did you try to get authorization for

20 paying him?

21 A. When I talked to Dr. Oladele -- when I talked to Dr.

22 Oladele that's always the first time I'm actually

23 trying to get authorization. But I spoke with her


155

1 in -- I'm going to say in April or so of 2010,

2 explaining to her some of the things that needed to

3 be paid and kind of cleaned up, because I was doing a

4 transition into this job. That's when I first

5 brought this up.

6 Q. So you said January 2010?

7 A. Mm-mm. April.

8 Q. April 2010. So sometime later 2009 or early 2010 you

9 told Mr. Spinuzza, yeah, the district will pay you,

10 and a number of months later you talked to Dr.

11 Oladele about it?

12 A. I was -- the reason it probably was -- I was telling

13 him, because the district was already using the space

14 for their own -- they were doing professional

15 development there already, so consequently I told

16 them that somebody is going to eventually pay you,

17 because they are already using it.

18 Q. Okay.

19 A. That's what I told him.

20 Q. Okay.

21 A. I just didn't get around to some of these things. I

22 had very delayed things occurring. And really,

23 because I was so sick, you know, for a lot of people


156

1 it's, like, why didn't you get this done right away.

2 It wasn't because I just didn't get it done, I was

3 sick.

4 Q. Were you able to perform the duties of your job when

5 you were sick?

6 A. I should have been off, but I didn't. I'm one of

7 those people that works through being sick. I didn't

8 realize the extent of it. I was working through

9 being sick, and now I know.

10 Q. In retrospect, now you know?

11 A. Now I know. I didn't realize how much it was

12 affecting me. What was happening, that's what I'm

13 trying to relay to you, is that things were so

14 delayed. And people are, like, why didn't she do it

15 here or in a week. Things were so delayed.

16 In the department I was working in, we didn't

17 have any clerical staff helping. We had a lot of

18 resistance from some of the people in different

19 departments. Things in the district were moving

20 slowly based on the fact that not just that Debbie

21 didn't want to get the work done, there were people

22 actually providing harassment and providing

23 resistance to things going to help ing to getting


157

1 these processes and procedures done for everything.

2 And you can only do so much yourself. So when

3 you have clerical staff that won't type things in or

4 a supervisor that refuses to do work for ELOP or a

5 supervisor that refuses to do other additional work

6 or something, that just sits on the desk for about a

7 month and it gets lost and you have to come find it

8 again. This is what was going on at the time.

9 In addition to, jeez, Debbie didn't get this

10 in, there was a lot of other individuals actively

11 participating in some harassment of me getting the

12 work done.

13 Q. Who was harassing you?

14 A. Some of my staff members, some of the clerical staff

15 just refused. Iona Wilkes, W-I-L-K-E-S, Diane

16 Hildebrand, H-I-L-D-E-B-R-A-N-D, there's a Karen

17 Zimicki, the Special Projects Department. A lot of

18 the Finance Department was providing, like, a

19 blockage in getting things done.

20 I will give a clear example. When I was

21 attempting to get a clerical person to replace the

22 last clerical person, it took eight months, where it

23 would normally take a month. There was a lot of


158

1 harassment going on at the same time. So to give the

2 appearance that jeez, Debbie didn't quite get these

3 through, that to me, I think is not fair to me. So I

4 just had to make that statement.

5 Q. So when you presented Exhibit J to Barb, she wrote

6 these questions for you to answer, right?

7 A. Yes.

8 Q. Was the work bid or quotations received, the answer

9 to that was no?

10 A. Right.

11 Q. And --

12 A. Who picked the vender?

13 Q. Who picked the vender? You did, right?

14 A. Yes.

15 Q. Had you looked at any Buffalo venders for this work?

16 A. No.

17 Q. The work started in January where has the contract

18 been? And you just explained that to me?

19 A. Right.

20 Q. Okay. Now, and so I take it in response to those

21 questions you also drafted the letter?

22 A. Yes.

23 Q. That's Exhibit I?


159

1 A. Yes.

2 Q. And you drafted that for Mr. Spinuzza to help him

3 out?

4 A. Yes.

5 Q. And you presented it to him and he signed it?

6 A. I talked to him. When I brought it to him I said if

7 you see any changes or anything in here that you

8 don't -- that's not true --

9 Q. Um-hmm.

10 A. -- and he said no, that's really where we are. And

11 he agreed. If he had some other things he wanted to

12 say or do I would have just did it for him or I would

13 have said here, let somebody else do it for you. I

14 was trying to help him.

15 Q. Did you tell anyone that the Mastery Center had been

16 using this property?

17 A. Tell who?

18 Q. Anyone in the district.

19 A. No. June knew that at the time we first --

20 Q. June was no longer here at this time, right?

21 A. The access center being at that spot was

22 originally --

23 Q. Right.


160

1 A. -- a conversation between June and I.

2 Q. I understand, but as of June of 2010 June wasn't

3 there, right?

4 A. Right, but at that time I wasn't working at the

5 Mastery Center, so whether it was using the space or

6 not --

7 Q. I know. Okay. And what did you do with this letter

8 then? You gave it to Barb, I take it?

9 A. I'm pretty sure.

10 Q. Did you tell her you wrote it?

11 A. I'm not sure.

12 Q. Okay.

13 A. That's all she asked for.

14 Q. Did she ask for a letter?

15 A. Yeah.

16 Q. She didn't ask for a letter here.

17 A. She told me that. I'm just telling you what she told

18 me.

19 Q. All right. So at this -- I -- what I'm confused

20 about is if we're not paying rent here -- the

21 district is not paying rent, are they?

22 A. I don't know. They are just paying for the -- to

23 reimburse them for stuff. It's like rent.


161

1 Q. But it's not rent.

2 A. I don't know.

3 Q. You helped put this together.

4 A. I know, but you're asking me to actually tell you

5 that --

6 Q. Well, take a look at page one of the contract.

7 A. Is it rent? Probably. Does it say rent? It doesn't

8 say rent, so no.

9 Q. Why was the district -- why should the district pay

10 for snow removal?

11 A. That's what me and him talked about. It was what me

12 and him had negotiated.

13 Q. Why should the district pay for snow removal?

14 A. I don't know why the district should pay for snow

15 removal.

16 Q. You're the one who had the negotiations.

17 A. When we talked about it, that's what he was saying he

18 had to pay for. What I did is I put in there what he

19 was telling me he had expenses for. I thought well,

20 if I put in what he had expenses for, he could get

21 his expenses reimbursed. That's what I was thinking.

22 I wasn't thinking in --

23 Q. I understand. Why should the district reimburse him


162

1 for snow removal?

2 A. I guess maybe then people would have to climb over

3 snow if he didn't remove it. I don't know.

4 Q. Why should the district pay his utilities?

5 A. Because I guess you can't do professional development

6 if the lights are off.

7 Q. That's your answer?

8 A. That's my answer.

9 Q. Okay. Do you know whether anyone else was renting --

10 A. No one else was using the space.

11 Q. Why wasn't this just a rental contract?

12 A. It should have probably been. I think that's why I

13 went to correcting that in the next year. That was,

14 probably --

15 I was learning this job. I'm learning how to

16 do contracts. We did not have any professional

17 development from people. I did not have any help

18 learning how to be an assistant superintendant. All

19 I got was the job and all the tasks, so I think it's

20 relatively unfair.

21 Q. Okay. So at this point, like -- during the period

22 covered by this snow removal/utilities contract I'm

23 still unclear. Who was providing services at 2925?


163

1 A. Elaine.

2 Q. It was all Elaine?

3 A. Yup.

4 Q. Do you know how many days a week?

5 A. I was not -- I was not over there. I'm fighting the

6 district people. I am not over there.

7 Q. Okay. Do you know if it was it almost every day,

8 once a month? Do you have any idea?

9 A. I don't know.

10 Q. Did you try to find out before you -- before you

11 proposed that this contract be entered into, did you

12 try to find out how many days a week the district was

13 actually using 2925 Genesee?

14 A. I'm not sure. I'm mentioning to you, and I think you

15 might have mentioned it yourself, that there was no

16 replacement for me at the time, and that from the

17 time of --

18 Q. There's no --

19 A. I'm getting to the point. Let me get to this point.

20 At the time I took this job from 3/22/2010 and this

21 was coming up, we have a lot of things going on. I

22 have staff members harassing me. I have no

23 professional development on how to put these things


164

1 together. I have Barb Smith in June of 2010 telling

2 me she will not meet with me to assist me in this

3 endeavor. You have a lot of things going on here

4 with people telling me what they are not going to do

5 to help me, and then come along the way and why

6 didn't you do this or oversee that.

7 And nobody -- and the reason I didn't have

8 anyone in that supervisor Title 1 position is because

9 of the same harassment. We're not going to fill

10 these jobs. We're not going to help you have people

11 in place. Then we're going to hold you accountable,

12 Debbie. Everything should have been perfect. And we

13 made sure it wasn't going to be perfect. This is

14 where we are right now. I don't know what else to

15 say.

16 Q. Why did you need -- at this point the district also

17 had access and was using the facility at 75 Hickory?

18 A. I was trying to break these into pieces. If we

19 didn't have all these people telling me, Debbie,

20 we're not going to accept this -- and I know you

21 probably have copies of e-mails. If you looked at my

22 e-mails, you saw a lot of harassment in these

23 e-mails. We're not going to do this, we're only


165

1 going to do this. And after you're done doing this,

2 then you're going to have to do that. You're looking

3 at a whole lot of other things going on.

4 Q. Okay. Back to my question. My question, ma'am,

5 is --

6 A. Yes.

7 Q. -- the district was also receiving services at 75

8 Hickory during the same time, right?

9 A. Yes.

10 Q. Why was there a need to use 2925 Genesee?

11 A. I wanted to have this one as out of district, because

12 there was forty-four schools, and I thought there

13 would be some schools with suburban students that

14 would not want to come all the way to Hickory Street

15 to use the access center.

16 So I'm envisioning now -- which I will never

17 do again -- envisioning an opportunity for people to

18 have access in the Suburban area through Buffalo

19 public schools at a low rate, and then also be able

20 to have enough access still at 75 Hickory, so the

21 community will be able to access books, be able to

22 use computers, maybe be able to learn about some of

23 the district initiatives that are going on, to have


166

1 the community engaged in programming. And that's the

2 reason I wanted to hold onto both spots, in a sense,

3 for the district. To help the district to give a

4 different sense of providing services.

5 Q. So to your knowledge does Title 1 require that Title

6 1 services be provided to suburban schools as well as

7 city schools?

8 A. Yes.

9 Q. Did any of the suburban schools say they would not go

10 to 75 Hickory?

11 A. No one said that. That's my assumption. No one said

12 that.

13 Q. Okay. And then J -- actually, K, ma'am.

14 What are you referring to, ma'am?

15 A. You can go ahead.

16 Q. No. No. What were you going to say?

17 A. I put in there for the out-of-district access center.

18 That's where I was going with it.

19 Q. So this Exhibit K, it -- it's a contract that covers

20 the period -- if you look at the contract -- actually

21 you can look at the term, it covers from September 1,

22 2010 to August 31, 2011, right?

23 A. Yes.


167

1 Q. Okay. Is this essentially a contract for the same

2 services that you had received from Mr. Spinuzza in

3 the prior contract?

4 A. No. What I was trying to do was formalize the

5 relationship between -- I really wanted to have a

6 formal access center at the site, and be able to put

7 up a sign and have everything in place so we could

8 get students and teachers in there to start to do

9 some work there. That was all. That's all I wanted

10 to do.


12

13 (Whereupon, Exhibit L, services rendered

14 invoice, was received and marked for identification.)

15

16 BY MR. ROONEY:

17 Q. All right. Showing you, ma'am, a document that's

18 been marked Exhibit L. Hassan is your son, correct?

19 A. Yes.

20 Q. Spell it.

21 A. Both names, S-A-D-D-I-Q-U-E, H-A-S-S-A-N.

22 Q. So he performed some work for the district, correct?

23 A. Yes.


168

1 Q. What sort of work did he perform?

2 A. Computer -- working with kids.

3 Q. Okay.

4 A. At Timon Bishop.

5 Q. What sort of work was he doing?

6 A. There's a provision for computer-assisted

7 instructing. What he was doing was to help with

8 anything that has to do with computers at the

9 nonpublic schools.

10 Q. Is he actually teaching students?

11 A. No, never do they teach kids.

12 Q. What was he doing, just kind of --

13 A. Anything that has to do -- making sure the

14 instructional modules are up on the computers and --

15 Q. Making sure the computers were working?

16 A. Um-hmm.

17 Q. Was this nonpub work that was going on?

18 A. Yes.

19 Q. Then when he started doing that work I don't think

20 you were in your current position; is that right?

21 A. Nope.

22 Q. What was your prior title?

23 A. Supervisor.


169

1 Q. Supervisor, all right. Title 1 Supervisor, correct?

2 A. Um-hmm.

3 Q. Now, this is an invoice that Hassan submitted to the

4 district; is that right?

5 A. Yes.

6 Q. And you signed off on it, right?

7 A. Dr. Oladele said don't do that.

8 Q. Okay. Tell me about that.

9 A. It was a mistake. And she said that that was

10 inappropriate. She told me at the time that was

11 inappropriate. She told me don't do that.

12 Q. How did she even learn about it? Do you have any

13 idea?

14 A. Because Barb Smith and all the harassers -- I'm just

15 telling the truth -- were screaming at her, telling

16 her Debbie Buckley's son is working and Debbie is

17 signing them. That's why I'm not that surprised at

18 this. She -- so she said -- she came to me and she

19 said to me, I do not want you to be signing this

20 stuff. So there was a lot of -- that's why I keep

21 coming back to that. This is just the same of a

22 bunch of stuff.

23 Q. But you agree, in retrospect, you shouldn't have


170

1 signed it, don't you?

2 A. Yes.

3 Q. All right. It's just something you didn't think

4 about at the time?

5 A. Yes.

6 Q. I -- I haven't looked, so I don't know. Is this the

7 only one you signed?

8 A. I think it's the only one, because she told me after

9 that, don't sign them.


11 A. And then she explained to me that they are supposed

12 to be -- you know, and I also talked to Dr. Williams,

13 because all at the same time I said Dr. Williams, my

14 son is working, situations are coming up, because all

15 of these people are coming after me with stuff.

16 And he said, do you know how many people have

17 these type of relationships in this district? How

18 could you be that worried about it?

19 And I said that people don't like me here, so

20 I have to be worried where other people do not have

21 to be worried. That's why.

22 He said don't worry about it. But obviously I

23 should worry about it.


171

1 MR. ROONEY: Mark that.

2

3 (Whereupon, Exhibit M, another services

4 rendered invoice, was received and marked for

5 identification.)

6

7 BY MR. ROONEY:

8 Q. All right. Let me show you what's been marked as

9 Exhibit M.

10 A. Okay.

11 Q. This looks like an earlier invoice that your son

12 submitted?

13 A. Yes.

14 Q. At this point you did not sign the document, right?

15 A. No.

16 Q. And it looks like it was submitted October 2009.

17 Correct me if I'm wrong, but you were still -- you

18 were still in your old position at that point?

19 A. Yes.

20 Q. Who did -- do you recognize whose signature -- I

21 recognize June's name at the bottom.

22 A. Um-hmm.

23 Q. Who are those other people?


172

1 A. Kathy Ahmed was the original person he was supposed

2 to work for.

3 Q. Who was she?

4 A. She is from Universal School. And I told him -- and

5 I also told all the other subcontractors that they

6 could actually -- and this was my wrong, because I

7 did tell people that they could actually sign for a

8 nonpublic school official. And the reason I said

9 that was basically -- I'm going to explain.

10 Q. Okay.

11 A. Basically a contract with a third-party provider for

12 nonpublic services are only between the district and

13 the provider of the services. And I only put the

14 nonpublic school official line in there as a

15 courtesy.

16 So I told them that if they couldn't get the

17 other people to sign for them, they had to attest for

18 their own time and they could sign it or leave it

19 blank, but I --

20 Q. In other words, you didn't need Kathy's signature?

21 A. No.

22 Q. Because the arrangement --

23 A. I did it as a courtesy, basically. It's actually


173

1 required by law -- it's actually a law that the

2 nonpublic school officials cannot commit the funds.

3 So therefore, I was just putting it there just as a

4 courtesy. So I told any of the venders -- that's why

5 I started taking them out.

6 Q. It looks like in L it is not there.

7 A. I took them out.

8 Q. All right.

9 A. Because I -- I just started to try to clean -- I was

10 trying to get things better as I was going along with

11 the job. As I learned things I tried to make it

12 better.

13 Q. Sure. What's Universal School?

14 A. It's a school, a nonpublic school.

15 Q. In the city?

16 A. Um-hmm.

17 Q. And did you say Kathy was the principal or something?

18 A. Um-hmm.

19 Q. Do you know Kathy?

20 A. I know everybody. I know all of the nonpublic school

21 principals. I had to meet with them. I don't know

22 them personally.

23 Q. Did you know her personally?


174

1 A. No, I didn't. No.

2 Q. Did your son have any involvement at the Universal

3 School prior to this?

4 A. No.

5 Q. All right. So Kathy wouldn't have known necessarily

6 who your son was until he was doing this work, the

7 nonpublic work?

8 A. He wasn't at that school.

9 Q. And he never was at that school?

10 A. No.

11 Q. So she has no idea who he is?

12 A. No. He was at Bishop Timon and Nazareth Lutheran.

13 It was a reassignment. I'm not sure what happened as

14 far as that, but he didn't work at the Universal

15 School at all.

16 Q. Who is -- and that's your son's signature at the top,

17 right?

18 A. Yeah.

19 MR. ROONEY: All right. Let me just take

20 a minute.



23


175

1 (Whereupon, Exhibit N, vender invoices,

2 were received and marked for identification.)

3

4 BY MR. ROONEY:

5 Q. Showing you two invoices, it appears to be E&M

6 Enterprises and the other is a Salvatore Spinuzza

7 invoice. Do you know who prepared these?

8 A. I know Elaine came into my office and she put this

9 one together.

10 Q. The E&M one?

11 A. Yes. And I prepared the second one.

12 Q. You prepared the second one?

13 A. Yes.

14 Q. Why did you prepare the second invoices?

15 A. For Mr. Spinuzza.

16 Q. Mr. Spinuzza wouldn't prepare his own invoice?

17 A. He could have. It wasn't for me, it was for him.

18 Q. Usually the vender will prepare --

19 A. I was trying to help. It was for him.

20 Q. Did you create invoices for anyone else?

21 A. Any time somebody wanted me to I would.

22 Q. Did you create an invoice for Crossroads?

23 A. Yeah.


176

1 Q. Okay. So you created their invoices too?

2 A. Um-hmm.

3 Q. But the -- but the top page is actually -- Elaine

4 created that one?

5 A. Yeah.

6 Q. They look identical; do you see that? Are you using

7 the same program?

8 A. They use the same thing.

9 Q. What do you mean?

10 A. They use the same -- whatever she did --

11 Q. The first page?

12 A. Yeah, then I used it for this.

13 Q. So you had it in Word or something like that, and you

14 just used her --

15 A. She did it on my computer.

16 Q. So Elaine came -- your work computer?

17 A. Um-hmm. She came into the office.

18 Q. And used your program and just drafted the invoice?

19 A. Or she might have had it on a key-chain or something

20 like that. I'm not sure how. I know Elaine -- this

21 is her layout, and I had a copy of her layout.

22 Q. And you just used her layout afterwards?

23 A. Yes.


177

1 Q. Okay. Do you know whether Mr. Spinuzza ever had his

2 own invoices?

3 A. He probably does. I just didn't ask him for it. I

4 was just trying to facilitate getting things done the

5 best I could. I don't know what people think I'm

6 doing. I was just trying to get him his money.

7 Q. All right. Now, one question. I -- I'm not sure you

8 fully answered it. I understood you and I were

9 talking about other issues, but when I presented to

10 you the contract for maintenance services,

11 snowplowing and the like for Salvatore Spinuzza --

12 A. Yes.

13 Q. -- I asked you how many days Elaine had spent working

14 for the district at 2925 during that same period. I

15 think your answer was you don't know.

16 A. I don't know. I would not know.


18

19 (Whereupon, Exhibit O, Ahmed

20 recommendation letter, was received and marked for

21 identification.)

22

23 MR. ROONEY:


178

1 Q. All right. Showing you a document that's been marked

2 as Exhibit O. This appears to be a -- some sort of

3 letter from Kathy Ahmed. It's spelled A-H-M-E-D.

4 Have you seen this before?

5 A. No.

6 Q. Okay. It looks like it's addressed to you, and you

7 just have never seen it?

8 A. I don't remember seeing this.

9 Q. Is it possible you've seen it and you don't remember

10 it?

11 A. Possible. I don't remember seeing it.

12 Q. What you told us before is you don't think she knew

13 him?

14 A. I don't think she knows him. I don't remember her

15 saying it.

16 Q. You don't know Kathy well enough to say whether

17 that's her signature or not, do you?

18 A. I don't know.

19 MR. ROONEY: Okay. That's all.

20

21 EXAMINATION BY MR. FURLONG:

22

23 Q. Let me just do some follow-up. Exhibit O there's no


179

1 date on it. I guess the document speaks for itself.

2 A. I don't know.

3 MR. FURLONG: Have we put in the lease

4 agreement amendment? I don't see that on the record.

5 MR. ROONEY: I didn't. It's not a

6 deposition. I'm just asking her questions.

7 MR. FURLONG: I think you should put it

8 in.

9 MR. ROONEY: Okay. Erin raised the same

10 question, so --

11

12 (Whereupon, Exhibit P, lease assignment,


14

15 BY MR. FURLONG:

16 Q. If you take a look at Exhibit H. All right. And

17 looking now at page eight of the contract, this is

18 Crossroads district contract. I notice Dr. Williams

19 signed it, in addition, Ralph Hernandez. Who is

20 that, just for the record?

21 A. The board President at the time.

22 Q. And it appears that there's Brendan Kelleher's

23 signature. Who is that?


180

1 A. He is legal counsel for the district.

2 Q. Ms. Buckley, generally speaking, was there protocol

3 when you submitted contracts for review by the board

4 President, board superintendant and board counsel?

5 A. Yes.

6 Q. What was that protocol?

7 A. The board President, if it was over --

8 Q. Was there a way -- how did you get it around, if you

9 know?

10 A. We would submit the contract with the contract

11 checklist to Brendan Kelleher first. And then they

12 would bring it back to us after his review. And then

13 they would submit the contract to Dr. Oladele for her

14 review, then to Barbara Smith for her review.

15 Q. And neither Dr. Oladele nor Barbara Smith signed off

16 on this contract; is that right?

17 A. No. And then when it's over a certain amount, Dr.

18 Williams and the board President must approve. And

19 if they have questions they would contact whoever

20 initiated the contract, and they would ask you for

21 any questions that they would have regarding it if

22 they had any concerns regarding the contract prior to

23 them signing it.


181

1 There have been instances where Mr. Hernandez

2 has called me upstairs about any questions that he

3 would have had about any contracts that were

4 submitted to him.

5 MR. FURLONG: I think that's it on my

6 end.

7 MR. ROONEY: Great. All right.

8 (Concluded at 2:07 p.m.)

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23


182

1 STATE OF NEW YORK COUNTY OF ERIE

2

3 I, Ashley M. Kleinschmidt, a Notary Public in and

4 for the State of New York, do hereby certify:

5 That the witness' statement was taken pursuant

6 to notice at the time and place herein set forth;

7 that said statement was taken down in shorthand by me

8 and thereafter under my supervision transcribed into

9 the English language, and I hereby certify the

10 foregoing statement is a full, true and correct

11 transcription of the shorthand notes so taken.

12 I further certify that I am neither counsel for

13 nor related to any parties to said action, nor in

14 anywise interested in the outcome thereof.

15 IN WITNESS WHEREOF, I have hereunto subscribed

16 my name this 21st day of February, 2012.

17

18 ___________________________

19 Ashley Kleinschmidt Notary Public, State of New York

20

21

22

23


Buckley vsCity of Buffalo School District

Debbie BuckleyFebruary 13, 2012

A

ability (1) 31:10

able (12) 3:16;7:6;58:20;59:23;

61:20;114:10;156:4;

165:19,21,21,22;167:6

above (1) 81:17

absolutely (1) 55:21

academic (7) 77:3,5,16;82:22;85:4,

14,18

academics (1) 126:6

accept (1) 164:20

access (22) 9:13,13;13:5;21:1;

46:15,18;47:12;53:7,15;

77:6;98:14;148:22;

149:10,12;159:21;

164:17;165:15,18,20,21;

166:17;167:6

according (5) 10:21;12:16;13:19;

99:8;106:18

account (1) 25:11

accountable (1) 164:11

accurate (3) 40:18,19;101:18

achieving (1) 91:17

across (1) 132:15

actively (3) 6:3;122:22;157:10

activities (24) 5:18;11:3,14;13:3;

14:21,21;15:11,14,15,17;

16:11;20:3,4;32:11;

42:13;53:14;55:22;

66:10;74:18;78:2;85:5,7;

95:5,6

actual (2) 21:22;88:12

actually (52) 6:12;12:17;24:11,21;

31:18;32:11,17;35:5;

41:13;42:3,5,8,17,21;

47:20;48:14;49:2,4,8,12;

51:5;52:16;62:23;68:22;

72:7;81:15,17;86:19;

91:23;99:2;102:15;

113:23;120:6;127:13;

137:10;142:13,13;

143:12;144:20;154:4,22;

156:22;161:4;163:13;

166:13,20;168:10;172:6,

7,23;173:1;176:3addition (4) 52:18;93:7;157:9;

179:19

additional (2) 90:22;157:5

address (5) 78:21;79:12,16,23;

135:8

addressed (1) 178:6

addresses (1) 136:9

adequately (1) 13:16

administrative (3) 137:15,19;138:14

Adult (12) 71:13,15,16,17,21,22;

72:1,7,10,11,12,20

adults (1) 33:11

advantage (2) 147:15,16

advertise (1) 33:15

advise (1) 5:1

affecting (1) 156:12

affiliated (1) 40:13

affiliation (1) 33:12

afternoon (3) 84:1,12;85:6

afterwards (2) 125:14;176:22

again (10) 28:19;58:2;91:1;98:22;

99:4;111:15;129:22;

133:15;157:8;165:17

against (2) 4:2,9

agenda (2) 98:1,6

agent (2) 55:8,9

ago (4) 36:17,19;45:21;124:18

agree (10) 90:9,11;103:17;

107:21;110:16;129:19,

22,22;136:12;169:23

agreed (2) 85:1;159:11

agreeing (1) 130:1

agreement (6) 54:1,6;56:13;69:16;

121:23;179:4

ahead (4)

9:12;50:11;148:15; 166:15Ahmed (3) 172:1;177:19;178:3

A-H-M-E-D (1) 178:3

air (1) 53:4

Albuterol (1) 57:19

alerted (1) 44:10

allegations (2) 3:9;4:1

allegedly (1) 10:19

allergies (1) 57:5

allocated (1) 9:17

almost (4) 51:3;52:1,5;163:7

along (6) 13:22;93:21;106:17;

109:19;164:5;173:10

Although (3) 52:15;131:3;143:7

altogether (1) 62:3

always (10) 22:1,3;23:14;28:9;

32:15;45:21;55:17;56:3;

108:21;154:22

amendment (4) 62:2;64:1;69:16;179:4

American (1) 149:6

amount (3) 110:17;131:17;180:17

annual (1) 17:6

annually (1) 112:9

answered (2) 3:17;177:8

apartment (2) 136:21,23

appearance (1) 158:2

appears (12) 76:14,18;77:1;80:15,

18;104:7,8;153:6,8;

175:5;178:2;179:22

appointment (2) 7:5;8:6

appreciate (1) 37:14

appropriately (1) 11:19

approval (2) 132:2,5

approve (3) 23:22;67:4;180:18

approved (5) 67:3;94:12;101:23;

118:20,21

approving (1) 104:15

approximately (2) 6:6;124:20

April (3) 155:1,7,8

area (4) 29:18;35:6;74:19;

165:18

areas (1) 122:9

around (18) 10:13;29:21,21;32:5,

10;49:21;99:9;107:2,4;

120:14;136:4,7;143:19,

21;144:23;149:18;

155:21;180:8

ARRA (4) 9:14;92:16;149:2;

150:5

A-R-R-A (2) 9:15;149:3

arrange (1) 112:19

arranged (1) 67:7

arrangement (12) 54:20;69:23;87:17,23;

96:10,11,12,23;113:5;

146:9,12;172:22

arrangements (7) 7:14;72:11;77:18,20;

90:23;139:19;150:4

arranging (1) 114:20

arthritis (2) 29:15;102:10

articles (1) 81:16

aspect (1) 119:9

aspirations (2) 51:22;70:21

assembled (1) 107:11

assign (1) 70:14

assigned (9) 39:2;60:7;70:2,3,11;

77:11,12;79:14;95:12

assignment (8) 39:19;60:13;62:19;

64:18;83:12;90:20;

93:16;179:12

assist (1) 164:2

assistance (1) 3:15

Assistant (6) 4:22;8:6,7;44:4;

137:16;162:18associate (1) 3:6

associated (3) 109:8,14;146:13

assume (4) 3:20;63:7;90:6;94:16

assumption (2) 121:3;166:11

asthma (2) 52:3;57:6

attached (2) 107:8,12

attacks (1) 57:6

attempting (1) 157:21

attend (1) 63:18

attended (1) 85:20

attention (1) 137:1

attest (1) 172:17

audibly (1) 5:6

audit (7) 9:20,22,22;10:3,6;12:3;

16:11

audits (2) 10:13;11:20

August (6) 80:9;86:11;91:23;

152:18,23;166:22

authority (2) 46:16;54:16

authorization (4) 87:13,22;154:19,23

authorized (1) 84:2

availability (1) 149:15

available (6) 17:9;62:4;65:11;68:13;

69:6;117:21

avoid (1) 89:14

avoiding (1) 89:16

aware (9) 12:3;61:11;88:1;

105:21;111:4;119:13;

134:16;145:11;147:6

away (3) 58:1;59:10;156:1

B

back (27) 19:12;31:22;38:17;

51:3;52:3;57:9,17,20;

58:2,2,3,5,6,7;72:22;

Min-U-Script® Metschl & Associates(716) 856-1906

(1) ability - back



97:21;102:18;105:14;

106:8;113:15;117:14,16;

122:6,6;165:4;169:21;

180:12

background (1) 29:12

bad (1) 52:2

Bailey (12) 14:13,14,18,20;15:10,

22;21:2;65:11;73:20,23;

74:12;98:15

ball (1) 93:19

bar (1) 122:5

Barb (15) 6:11,12;96:9,11,21,22;

99:17;106:4,8;107:6;

127:20;158:5;160:8;

164:1;169:14

Barbara (10) 14:15;23:14;97:5;

104:23;105:1;137:4;

153:15,18;180:14,15

based (5) 66:4;110:17;113:11;

132:11;156:20

basically (4) 20:4;172:9,11,23

Beaver (1) 17:3

became (3) 12:6;119:13;141:8

becoming (2) 40:10;69:6

beforehand (1) 70:20

began (2) 49:21;138:14

begin (1) 145:7

beginning (7) 16:2,10;20:1;27:9;

46:20;143:4;154:10

behalf (4) 40:23;58:12;105:9;

113:12

behind (2) 81:7;93:18

bell (1) 135:9

below (1) 104:21

benefit (1) 64:14

Berg (1) 13:23

B-E-R-G (1) 13:23

besides (3) 39:8;88:1;94:23

best (4)

31:9;64:5;149:13;

177:5

better (7) 21:19;37:4;90:18;

100:14,15;173:10,12

beyond (1) 119:6

bid (1) 158:8

big (3) 45:13;57:13;142:9

bigger (1) 43:2

Bill (5) 114:17,18,19;118:3,6

billed (1) 90:12

bind (1) 54:16

birthday (1) 42:12

Bishop (2) 168:4;174:12

bit (1) 3:11

blame (1) 118:16

blank (1) 172:19

blockage (1) 157:19

blurry (1) 29:18

board (17) 23:22;81:18;118:20;

123:9,13,21;132:2,5;

139:1,3,4;179:21;180:3,

4,4,7,18

BOCES (4) 68:17;124:17;125:2,14

books (2) 21:5;165:21

both (9) 10:9,13;11:21;41:14;

140:1,7;145:20;166:2;

167:21

Bottom (6) 69:4;75:2;76:14;105:2;

153:21;171:21

boundaries (1) 65:18

boy (1) 152:4

break (2) 76:2;164:18

Brendan (2) 179:22;180:11

bring (6) 74:12,13;110:20;

137:1;151:23;180:12

bringing (2) 113:21;133:5

broad (1)

56:10

brochure (1) 72:10

brought (5) 4:10;98:6;106:14;

155:5;159:6

Buckley (9) 3:6;4:14;61:11;62:12;

76:11;80:14;87:1;98:6;

180:2

Buckley's (2) 83:10;169:16

Buffalo (8) 3:8;34:19;50:23;52:8;

139:12;147:7;158:15;

165:18

building (18) 7:18;13:2,21;14:7,9,18;

31:18;44:21;45:3;73:23;

82:13;101:3,7;108:12;

114:21;145:17;147:23;

148:1

buildings (2) 68:4;142:13

bunch (2) 77:1;169:22

burner (1) 122:6

Burroughs (2) 8:13,18

bus (3) 14:23;15:9,13

buses (2) 15:9,13

business (8) 27:22;29:2;32:20;40:8;

87:6,7,9;135:4

busy (1) 110:11

C

call (13) 17:21;55:23;62:10,10;

73:1,12;94:5,8;114:21;

120:16,18,21;138:6

called (15) 12:18;17:19,21;24:4;

27:5;74:17;77:2;93:21;

94:16;100:8;102:2;

119:17;120:20;123:3;

181:2

calling (4) 74:21;119:19;120:17;

123:1

calls (2) 94:19;100:7

Cambria (5) 3:16,18;76:1;82:16;

98:9

came (24) 10:6;14:1;39:5,16;

40:1;51:23;52:1;73:5;

91:13;93:2,11,14,16;

95:16;99:15;117:20;

146:5;148:23;150:5;

151:22;169:18;175:8;

176:16,17

can (32) 3:14;5:6;21:19;22:8;

23:9;55:15;65:8,16;

73:22,23;75:10,10;76:17;

79:3;84:18;85:16;91:13;

93:19;94:2;97:19;102:11,

14,15;130:2;142:2;

147:15;148:4;152:13;

153:14;157:2;166:15,21

cancel (11) 80:20,21;81:19,22;

82:6,8;83:9,9;86:20;

131:5,9

cancelled (5) 81:2,15;82:10;83:1;

131:8

capacity (3) 36:11;46:3;125:5

care (2) 126:21;151:2

careful (1) 55:5

carts (1) 21:5

case (2) 101:2;142:20

category (1) 11:15

Cayuga (2) 3:1;4:18

cell (3) 56:2,3,7

center (140) 9:13,14;15:18;16:21;

17:4;24:4,6;25:3,6,7,9,10,

22,23;28:21;29:5,8,9,9,

11,19;30:8,11;31:14,23;

32:7;33:3;34:2,10;41:1,2,

8,9,12;42:1,3,8,15;43:3;

45:1,7;46:3,16,18;47:12,

15;48:6,13,16,18;49:3,5,

16,23;51:4,6,8,14;53:7,

15;54:7,16;55:9,19,20;

56:16;58:13;59:10,12,19;

61:9,18;64:6,16;65:4,19;

67:10,14,19;68:5,8;

70:14,15,19;71:3;72:13;

75:5,9,14,17;76:21;77:3,

5,6,16;78:10,19,21;79:1,

19;82:19,22;96:3;98:14;

111:5,23;112:16;113:13;

123:9,12;140:19;142:16,

22,23;143:9,14,18;144:6;

145:15;146:6;147:16;

148:3,22;149:10,12,17;

150:9,14,18;151:2,9,10,

12,15;159:15,21;160:5;

165:15;166:17;167:6

Center's (1) 111:12

certain (5) 121:12;122:9;150:1,4;

180:17

certainly (1) 5:3

certificate (1) 81:14

certified (1) 81:15

certify (1) 81:16

Chairs (4) 75:18,20,22;150:20

change (5) 27:23;97:11;121:13;

131:16;133:13

changed (7) 29:10;31:4,13;128:3;

130:8;131:1;132:8

changes (1) 159:7

changing (1) 132:4

charged (5) 21:16,18;65:21;75:14;

109:21

charging (2) 135:1,1

check (4) 25:2,20;30:19,20

checking (1) 25:11

checklist (5) 104:8;106:1,4;107:8;

180:11

checklists (2) 105:6;107:12

chief (2) 7:3;105:5

children (4) 26:20;33:11;38:14;

115:8

choice (1) 3:21

chose (1) 110:11

church (8) 33:9;54:7;62:7;120:1,

2;121:2;124:10;126:6

circumstances (4) 39:5;81:7;91:13;108:4

city (2) 166:7;173:15

clarify (2) 5:4;64:13

clean (1) 173:9

cleaned (1) 155:3

clear (5) 9:7;86:5;96:22;141:11;


(2) background - clear



157:20

clerical (5) 156:17;157:3,14,21,22

climb (1) 162:2

close (2) 20:22;113:11

closely (2) 114:23;115:1

Closer (1) 154:12

closet (1) 75:8

code (4) 35:6;77:7,10,12

Cohen (4) 19:1;110:5;122:12,15

C-O-H-E-N (1) 19:1

Coleman (7) 26:12;132:18,22;

133:16;134:20;135:1;

136:10

C-O-L-E-M-A-N (1) 26:12

collaboration (2) 49:15;50:21

coming (9) 51:11;57:9;91:22;

102:20;115:20;163:21;

169:21;170:14,15

commencing (1) 112:8

commercial (2) 147:23;148:1

commit (1) 173:2

communication (2) 19:20;44:6

communications (2) 20:6;87:16

community (4) 95:8;115:14;165:21;

166:1

company (6) 132:15,16;133:20;

135:21;137:3;146:12

complaints (1) 126:18

complete (1) 13:2

compliment (1) 93:9

compromise (1) 58:23

computer (6) 75:22;116:22,23;

168:2;176:15,16

computer-assisted (1) 168:6

computers (7) 21:4;72:4;75:21;

165:22;168:8,14,15

concept (4) 31:15,16;45:12;111:3

concerned (1) 150:16

concerns (1) 180:22

concluded (2) 10:14;181:8

condition (3) 58:13;59:2,4

conducted (1) 10:13

Conference (1) 17:4

conferences (2) 16:21,22

confident (1) 27:12

confirm (1) 100:17

conflict (1) 71:5

conflicts (3) 71:2,8,12

confused (6) 15:12;31:17;62:6;

111:19;130:3;160:19

confusion (1) 5:8

connection (1) 4:9

connections (1) 19:3

consequently (2) 102:18;155:15

consider (1) 4:3

consideration (1) 124:4

consultation (1) 126:20

contact (12) 17:8,11;19:16;38:15,

17;50:2;79:6;122:19;

137:18,21;146:23;180:19

contacted (3) 19:4,11;117:2

continual (1) 58:6

continue (2) 122:5;144:11

contract (92) 21:20,22;22:1,4,11,12,

12,16,22;23:2,4,8,10,22;

53:12;54:9,17;55:1,20;

66:23;67:3,5,7,13,18,19;

68:5;70:20;88:3,6,8;89:8,

15;91:11;98:18;99:10,18;

100:1;102:6;104:2,8,15,

16;105:21;106:1,4;107:9,

12,14;108:10,11;110:7;

111:14,23;113:15,17;

116:12;117:12;118:17,

23;120:22;121:14;129:6,

14,17,19;130:15,15,19;

131:5,10;152:19,23;

158:17;161:6;162:11,22;

163:11;166:19,20;167:1,

3;172:11;177:10;179:17,

18;180:10,10,13,16,20,22

contracts (8) 23:17;67:4;84:15;

108:3;120:13;162:16;

180:3;181:3

contractual (3) 41:3;96:23;146:9

contractural (1) 146:12

control (5) 23:22;58:7,8;132:2,5

Convention (1) 16:21

conversation (21) 13:23;18:10,13,16;

43:13,14;62:17;63:16;

96:2,3,21;97:1;98:7;99:7;

101:13;114:12;121:12;

123:4;128:12;153:17;

160:1

conversations (7) 62:15,18;71:9,11;

100:1;140:15;141:17

coordinate (1) 52:5

copier (4) 113:1,3,6,9

copies (1) 164:21

copy (3) 97:19,22;176:21

correcting (1) 162:13

correctly (1) 10:19

cost (6) 19:10;21:13,16;97:14,

16,17

counsel (2) 180:1,4

course (6) 7:13;33:21;53:3;67:9;

85:3;125:13

courtesy (4) 65:15;172:15,23;173:4

covered (1) 162:22

covers (3) 117:9;166:19,21

create (2) 175:20,22

created (3) 82:9;176:1,4

crossed (1) 55:12

Crossroads (53) 35:19,22;36:1,9;37:8;

39:3,9,12,15,16;40:11,13,

16,21;60:7;61:6;63:8,13;

70:2,3;83:12,14,23;

84:12;91:11;93:21;

94:23;95:12,16;96:6,12;

97:1;98:18;99:11,18;

100:10;104:1;108:15,17,

20;109:1,9,15,18;118:17;

120:9,16;121:14,18,22;

134:10;175:22;179:18

current (6) 4:21;8:20;16:4,15;

145:9;168:20

D

d/b/a (5) 24:12,13;25:8,14;28:21

Daniels (1) 122:18

Daphney (1) 26:12

data (1) 125:4

date (2) 99:7;179:1

dated (2) 76:18;82:10

daughter (4) 28:10;46:5,5;55:7

day (6) 94:15;105:10;107:6;

137:4,5;163:7

daycare (4) 42:15;43:9,10;53:10

days (5) 33:3;102:14;163:4,12;

177:13

deal (1) 47:14

dealt (2) 108:20,21

dear (1) 50:15

Deb (1) 58:5

Debbie (13) 4:14,15;61:11;62:12;

83:10;86:23;156:20;

157:9;158:2;164:12,19;

169:16,16

Deborah (1) 4:15

December (4) 54:23;112:8,12,15

decent (1) 95:3

decide (1) 56:15

decided (1) 141:19

decision (2) 63:22;69:23

definitely (3) 32:3;40:17;55:10

delayed (3) 155:22;156:14,15

delinquent (3) 115:5,6,7

deliver (1) 74:22

delivered (4) 78:4,5,7;81:17

deliveries (7) 64:23,23;65:2;69:9,9,

14;83:18

delivery (1) 77:2

delve (1) 56:22

department (22) 7:21;10:2,9,10,12;14:1,

2;17:8,11;19:5,17;20:7,

10;73:12;77:14;114:4;

116:13;117:7;118:12;

156:16;157:17,18

departments (1) 156:19

depending (1) 122:8

depicted (1) 154:8

deposition (2) 5:2;179:6

deputy (2) 5:21,23

described (1) 28:1

design (1) 20:11

designation (1) 108:16

desk (1) 157:6

details (2) 17:17;66:12

determination (1) 113:10

determinations (1) 58:21

determine (2) 56:15;110:23

determining (1) 59:5

develop (2) 125:8,14

developer (3) 69:3;93:2,5

developers (1) 125:2

development (43) 11:2,6,13;12:13;13:10;

20:3;46:23;53:13;64:21;

65:1,23;66:2,6,9,18,20;

67:11;68:1,12;69:5;78:2,

13;91:5,7;92:15;93:5,12;


(3) clerical - development



101:3,5;116:14,16,18,20,

21;117:4,7;118:4;125:3;

126:15;155:15;162:5,17;

163:23

Diane (1) 157:15

difference (1) 113:8

different (19) 11:7;14:16;18:15;28:2;

29:1;34:1;38:10,12;

48:15;57:7,15;61:16;

91:20;98:13;117:16;

129:13;154:4;156:18;

166:4

difficult (1) 92:22

dinner (1) 125:11

diocese (11) 41:4;43:22;44:4,19;

45:4;47:15;63:2;119:14;

121:16,17,20

direct (1) 19:16

directed (2) 3:9;139:8

directing (1) 41:16

direction (2) 130:6,11

directive (1) 19:22

directly (8) 5:20;18:20;68:1;

120:12;121:2,4;133:11;

139:15

Director (5) 18:9;122:7,11,14,18

Directors (3) 123:9,13,21

disagree (1) 112:13

discipline (2) 4:5,10

disclose (2) 135:19;136:13

discussed (5) 43:19;62:2;97:14,15;

153:12

discussing (2) 97:5;117:8

discussion (4) 113:9;117:22;148:14;

153:11

discussions (3) 41:1;49:21;141:8

disease (2) 57:2;106:23

dismantled (1) 12:11

dissolve (2) 61:23;62:3

dissolved (4) 62:7,7;70:15;142:16

distracted (1) 93:15

District (152) 3:8;4:3,11,21;5:19;

7:22;12:18;15:16,18,19;

19:9,10;20:21;21:6,13,

15,20,21;22:5;45:17,18,

22;46:4,8,11;47:11;55:6,

14,22;56:1;61:3;64:10,

14;65:15,20,21;66:23;

67:9,14,15,19,22,23;

68:12;77:11,15;79:12;

83:14,20;84:23;87:23;

89:10;90:9,15;91:10,19,

21;92:14,18,23;93:23;

94:21,23;95:5,13,17,19;

96:6;99:11,18;100:16;

101:4;102:23;103:7;

110:22;112:20;113:18,

21;114:3,6;115:18;

117:15;118:5,22;119:14;

120:1,2,21;121:2,15;

124:19;125:5,7,22;126:9;

128:2,7;129:5,8,12,14,16,

20;130:6,15,21;132:4;

133:19,21;139:12,20,23;

140:11;141:3,9,14,14;

145:2,14,20,23;148:17;

151:22,23;152:9;154:17;

155:9,13;156:19;159:18;

160:21;161:9,9,13,14,23;

162:4;163:6,12;164:16;

165:7,11,23;166:3,3;

167:22;169:4;170:17;

172:12;177:14;179:18;

180:1

district-owned (2) 14:18,19

divided (1) 144:6

divorced (1) 37:21

doctor (1) 52:3

document (12) 54:5;76:11,12;80:14;

86:15;97:3;99:8;104:6;

167:17;171:14;178:1;

179:1

documents (4) 6:19;10:17;138:13;

139:8

dog (1) 134:6

dollars (14) 24:2;54:23;84:20;

89:19;112:11,17,20;

125:23;131:19,22;

146:18,18,19,20

done (27) 8:9;10:15,19;12:4,4;

41:7;51:19;53:10;88:7;

92:20;93:18;97:19;

102:16;106:15,16;117:7;

126:5,6;133:9;156:1,2,

21;157:1,12,19;165:1;

177:4

down (6) 27:13;104:12;110:20;

115:16;142:20,21

Dr (54) 6:1,2,7,8;7:8,10,11;

18:23;50:4;52:12,13;

53:6;88:1;91:19;92:2;

94:10;95:9,10;97:4;

99:23,23;100:17,18,22,

22;101:20,20;103:2;

104:18,18,19,21;105:1,8,

16,20;106:1,3,7,11;

118:18,20;122:11,13;

154:21,21;155:10;169:7;

170:12,13;179:18;

180:13,15,17

drafted (5) 54:9;69:16;158:21;

159:2;176:18

drivers (3) 14:23;15:9,13

dropped (1) 26:8

drops (3) 114:20,21,22

Durham (4) 31:19,20;32:13,20

D-U-R-H-A-M (1) 31:21

During (15) 17:7;56:23;64:10,12,

16;70:22;72:23;112:21;

122:21;142:19;143:4;

144:3;162:21;165:8;

177:14

duties (4) 4:3;5:15;7:13;156:4

E

E&M (31) 86:10;87:5,19;88:14;

126:11;127:12,18;128:4,

7,14,20;129:2,6,17,19;

130:7,12,19;131:2,3,10,

17;132:4,10;133:6;

134:16,18;135:8;137:2;

175:5,10

earlier (15) 13:11;15:14;28:14;

30:21;65:10;90:3;95:14;

101:15;106:19;124:8;

127:12;139:22;140:18;

154:11;171:11

early (3) 10:5;49:13;155:8

Ed (10)

71:13,15,16,17,21,22;

72:1,11,12,20

Education (9) 10:2,9,11,12;14:1,3;

72:7,10;81:18

educational (34) 29:11;42:13;48:7,10,

11,14,17,21;49:4,9,16,22;

50:2,22;51:2,9,11,23;

52:13;71:2,3;79:13;

139:11,18,22;140:5,10,

15,20,22;141:1,11,20;

143:16

effort (1) 94:7

eight (9) 37:11,13,15;38:4;

93:18;103:14;146:19;

157:22;179:17

Either (7) 7:18;8:17;17:7,15;

33:1;50:19;75:4

elaborate (1) 101:21

Elaine (40) 66:22;67:22,23;68:5,8,

11;78:14,18;79:13;84:8;

86:2;87:6,16;123:4,5;

124:3,16,17;125:1;

127:13;128:3,8,14;130:6,

11,16;131:2,17;133:7;

134:18;135:20;137:9,14;

163:1,2;175:8;176:3,16,

20;177:13

Elaine's (2) 87:9;134:4

electronic (1) 137:21

element (1) 12:6

elements (3) 12:11;97:16;104:16

ELOP (1) 157:4

else (34) 15:8;27:16,20;35:3;

39:8;42:16;47:7,10,18;

56:18,19;61:22;62:1,5,

14;63:3,5;65:7;73:13,19;

74:8,14;75:19;87:22;

94:8,22;96:2;128:23;

151:11;159:13;162:9,10;

164:14;175:20

e-mail (9) 6:15;78:21;79:2,11,12,

15,16,23;138:10

e-mails (6) 19:20;20:13;137:23;

164:21,22,23

emphatic (1) 119:16

employee (11) 35:15;45:17,18,21;

46:4,8;55:6,7;118:5;

125:6,7

employees (8) 13:1;71:17;139:11,18;

143:14,15,18;144:4

empty (2) 134:21,22

encompassed (1) 11:9

end (3) 10:6;72:6;181:6

endeavor (1) 164:3

ended (1) 125:19

ending (2) 112:8;127:11

engaged (1) 166:1

engineers (1) 18:14

enough (7) 8:2;9:12;28:19;66:15;

95:21;165:20;178:16

enrichment (6) 85:5,7,8,12,15,16

enter (1) 59:8

entered (11) 51:9;58:12;70:19;

84:15;118:16,17,23;

120:18,22;121:23;163:11

entering (3) 41:2;89:15;98:17

Enterprises (56) 48:8,10,14,17,21;49:4,

9,16,22;50:2,22;51:2,9,

11,23;52:13;71:2,3;

79:13;86:10;87:6,19;

88:14;126:11;127:13,19;

128:4,8,14,21;129:3,6,17,

20;130:7,12,19;131:3,10,

17;132:4,10;135:8;137:2;

139:11,19,23;140:5,10,

16,20,22;141:2,20;

143:16;175:6

enters (1) 91:11

entirely (2) 14:16;27:12

entities (3) 35:13;84:20;126:14

entitled (1) 76:13

entity (6) 24:3;26:1;27:5;35:16,

19;61:16

envisioning (2) 165:16,17

EPOs (1) 119:11

equal (2) 111:7,8


(4) Diane - equal



equipment (21) 21:8;22:10,15;69:12;

73:5,13;75:6,15,17;

77:23;94:9,19;95:13,17,

20;96:4;150:10,12,16,18;

151:23

equitable (2) 10:20;11:10

Erin (2) 3:7;179:9

error (1) 81:6

Especially (1) 102:19

essentially (1) 167:1

establish (4) 9:13;20:3;42:17;

123:15

estate (1) 132:16

even (31) 13:13;38:11;42:12;

45:19;49:1;58:8,9;59:1,

18,22;70:7,16;75:20;

79:21;81:20;87:12;

89:16;90:19;93:16;95:4;

97:9;123:12;135:23;

136:22;143:17;144:11,

13;148:9;154:13,14;

169:12

event (1) 31:15

eventually (3) 10:17;125:8;155:16

everybody (3) 23:15;73:3;173:20

everyone (6) 23:11,11,15,20;53:6;

62:1

evolve (1) 91:19

exacerbation (1) 52:2

exact (1) 144:3

exactly (2) 66:12;94:14

EXAMINATION (2) 3:4;178:21

example (3) 85:15,16;157:20

exchange (1) 68:8

exclusive (1) 94:21

exclusively (1) 7:11

Exhibit (42) 53:19,21;54:1,5;76:7,

12;79:6;80:9,15;83:9;

86:10,16;98:1,5,5;

103:23;104:1,6;111:15;

112:1;113:15;120:18;

121:23;152:15,18,22;

153:4,20;154:8;158:5,23;

166:19;167:13,18;171:3,

9;175:1;177:19;178:2,23;

179:12,16

exist (3) 24:6,8;31:18

existed (3) 13:10;83:4;143:7

existence (9) 13:14;23:3,4;28:17,18;

31:23;39:16;44:11;70:16

existing (1) 29:8

expenses (3) 161:19,20,21

expert (1) 74:19

expertise (2) 6:23;7:1

explain (4) 22:8;49:6;55:15;172:9

explained (2) 158:18;170:11

explaining (1) 155:2

explanation (1) 112:23

explicitly (1) 9:15

extent (1) 156:8

F

facilitate (1) 177:4

facilitating (1) 56:21

facilities (1) 98:13

facility (21) 17:12;31:4;46:19;

77:16;83:15;90:19;91:4;

94:22;95:3,17;96:13;

97:14,17,18;113:22;

114:7;118:22;142:9,17;

152:10;164:17

fact (8) 32:4;67:13;72:9;87:8;

107:1;113:11;125:12;

156:20

failing (1) 11:21

Fair (16) 8:2;9:12;56:16;58:16;

59:5;66:15;94:20;95:21;

110:21,21,23;111:1,9,10;

113:10;158:3

fairness (1) 111:11

Falk (1)

127:6

fall (2) 91:3,4

Falls (2) 3:2;4:18

far (8) 28:22;39:11;59:22;

117:1;122:6;136:17,19;

174:14

fashion (1) 93:9

fast (1) 124:6

father (2) 37:18;44:17

favor (1) 128:17

February (5) 16:2;24:10;32:5;70:15;

72:6

Federal (2) 4:22;8:4

fee (8) 87:20;88:4,12;89:3,6,

11;111:12,14

feel (1) 90:18

fees (3) 82:14;88:6;128:3

felt (1) 126:8

few (4) 24:3;102:11;119:10;

122:10

field (1) 7:2

fifty (5) 24:2;34:3,4,5;143:20

fighting (2) 106:22;163:5

figure (1) 113:10

file (1) 27:4

fill (1) 164:9

filled (1) 92:22

finally (3) 57:17;92:12,13

Finance (1) 157:18

finances (1) 7:6

financial (6) 7:3;40:20;54:19;56:14;

105:5;110:16

find (9) 16:10;17:12;31:1,6;

59:18;94:8;157:7;163:10,

12

finding (2) 16:9;41:11

fine (3) 147:12,14;153:23

finish (3) 14:9;30:7;117:6

first (20) 43:21;44:10;47:5;82:1;

104:8;111:19;113:16;

125:1;131:5;138:16;

146:5;148:23;153:4;

154:6,9,22;155:4;159:19;

176:11;180:11

fit (1) 49:19

Five (9) 36:19;55:1;77:7,10;

107:1;143:21,23;146:19;

147:4

fizzle (1) 127:9

flare (1) 29:15

focusing (1) 27:23

follow (1) 78:7

followed (2) 8:22;9:2

following (1) 28:3

follows (1) 3:2

follow-up (1) 178:23

force (1) 58:5

forget (4) 32:18;50:6,8;72:12

forgot (2) 49:2;97:11

form (4) 27:5;76:7,13,18

formal (1) 167:6

formalize (1) 167:4

formed (4) 26:15;29:5;32:10;82:1

former (1) 40:17

forth (6) 52:3;54:20;57:18,20;

58:2,3

forty-four (1) 165:12

forty-nine (2) 131:18,21

Forwards (1) 138:8

found (2) 35:5;87:7

Foundation (2) 72:13,20

four (5)

57:23;106:20;107:1;

143:21,23

frankly (1) 95:23

free (4) 50:22;52:7;67:15;

71:19

friends (2) 124:23;125:17

friendship (3) 125:8,15,19

front (1) 97:22

full (2) 4:13;58:5

fully (2) 101:18;177:8

fund (1) 117:16

funded (2) 117:14,15

funding (3) 14:19;118:1,2

funds (5) 92:16;117:14,15;

150:5;173:2

Furlong (30) 3:16,18;17:22;31:9;

82:17;83:7;87:14;96:18;

97:20,23;98:23;99:5,21;

103:9;107:19;108:1;

109:3;110:3;112:4;

133:15;139:15;141:5;

147:8;148:13,15;178:21;

179:3,7,15;181:5

furniture (1) 150:21

future (2) 117:10,12

G

Galani (3) 114:2,13;117:2

gas (1) 154:7

gave (7) 3:2;30:19;86:2;93:16;

108:16;154:5;160:8

general (1) 56:11

generally (5) 5:15;7:23;9:10,11;

180:2

Genesee (23) 32:14,14,16,19;33:1;

42:19,23;68:3;140:1;

142:7,22;144:5,20;145:3,

12;146:15;148:18;

149:14,18;151:16;

152:10;163:13;165:10

gentleman (1) 147:10


(5) equipment - gentleman



gets (2) 96:17;157:7

Gist (1) 123:5

G-I-S-T (1) 123:5

given (5) 7:5;9:2;19:22;21:7;

52:10

giving (3) 10:20;53:3;92:2

Glena (3) 50:4;141:4,6

goes (2) 24:2;91:2

good (5) 22:15;47:4;49:19;

126:13;150:8

Gordon (4) 34:7;108:23;109:8;

134:13

grabbed (1) 138:23

grant (3) 5:18;9:14,16

grants (2) 6:19;28:2

Great (1) 181:7

guess (19) 17:3,22;31:22;54:18;

62:6;64:2;76:1;82:3,17;

88:11;99:21;107:5;109:2,

3,5;111:18;162:2,5;179:1

guessing (8) 18:2;60:4,5;81:10;

90:5,6,8;98:22

guy (5) 44:16;50:4,5;72:12;

114:3

guys (9) 71:11;112:6;115:20;

120:7,9;133:2,4;137:11;

152:4

H

half (2) 144:7,8

hand (1) 138:23

handle (1) 110:11

handles (1) 44:19

handwriting (2) 83:10;86:21

Hang (1) 148:13

happen (6) 12:16;21:12;38:20;

57:12;77:18;102:19

happened (19)

14:14;57:16;60:10;

70:22;93:1;94:18;123:17,

22,23;131:7,12,13,14,15;

141:20;150:9,12;151:22;

174:13

happening (1) 156:12

happens (5) 57:2,11;62:12;91:3;

106:22

harassers (1) 169:14

harassing (2) 157:13;163:22

harassment (5) 156:22;157:11;158:1;

164:9,22

Hassan (2) 167:18;169:3

H-A-S-S-A-N (1) 167:21

Hayes (27) 66:22,23;67:23;68:1,6,

8,11;78:14,18;79:14;

87:16;123:5;126:11;

128:3,6,8,14;129:11,14;

130:7,8,11,16;131:2,17,

18;135:20

H-A-Y-E-S (1) 66:22

Hayes's (1) 87:6

hear (2) 138:19;139:2

heard (6) 23:19,20;138:13,16,18,

18

hearsay (1) 35:4

Heart (4) 72:12,20;138:3,5

held (6) 5:11;19:14,14;27:14;

108:14;124:13

helm (1) 93:20

help (20) 29:12,17;30:3;50:19;

51:17;52:4,6;61:20;

72:21;115:13,14;156:23;

159:2,14;162:17;164:5,

10;166:3;168:7;175:19

helped (3) 26:8;59:22;161:3

helper (1) 52:1

helpful (2) 5:9;51:19

helping (8) 24:20,22;26:7;65:20;

67:17;110:14,15;156:17

Herberger (1) 44:17

hereby (1) 81:16

Hernandez (3) 118:18;179:19;181:1

hey (1) 94:19

Hickory (50) 9:8;19:7,10;20:9,10,11;

21:6,6,10;36:10;39:19;

40:1;41:2,9;42:2,4;43:21;

46:10;48:16,22;49:5;

51:13;64:7,12,15;68:2,

13,20;69:6;73:8;74:7;

77:9,23;78:11;91:4;96:4;

99:12;108:13;140:1,8;

143:1;144:12,14;149:13;

152:7;164:17;165:8,14,

20;166:10

Hildebrand (1) 157:16

H-I-L-D-E-B-R-A-N-D (1)

157:16

hired (4) 3:8;5:13;19:4;92:13

hiring (1) 92:19

hit (1) 65:9

hits (1) 57:14

hold (6) 27:10;59:4;64:5;96:16;

164:11;166:2

hole (1) 93:5

Hollow (1) 17:3

home (2) 26:19;69:2

homeless (3) 26:21;115:9,11

honestly (2) 3:14;35:2

hoping (1) 42:1

House (7) 26:20,20;38:5,7;134:4,

8,20

housed (1) 15:9

Hovicish (1) 14:2

H-O-V-I-C-I-S-H (1) 14:5

Humber (7) 134:16,18,19,19;

135:13,18;136:10

H-U-M-B-E-R (1) 134:17

hundred (11) 77:7,10;84:20;89:18;

125:23;146:18,19,19;

147:4,4;149:21

I

ID (1) 25:13

idea (14) 34:14,16;71:7;77:7;

80:3;96:1;98:17;100:14,

15;119:2;124:14;163:8;

169:13;174:11

ideas (2) 53:3,5

identical (1) 176:6

identification (16) 53:22;54:2;76:8;79:7;

80:11;86:12;98:2;104:3;

152:16,20;153:1;167:14;

171:5;175:2;177:21;

179:13

identifies (1) 108:11

identify (1) 92:1

ill (2) 73:3;107:3

illness (3) 56:23;102:13,15

immediate (3) 102:9,9,11

immediately (2) 102:4,5

implement (2) 13:7;29:12

implemented (1) 11:19

inappropriate (2) 169:10,11

Inc (1) 86:11

incarcerated (1) 115:8

including (2) 4:5;5:12

incorporated (2) 24:11;27:2

increase (1) 55:1

indicated (2) 40:16;127:12

indirect (1) 146:23

indirectly (1) 121:5

individuals (2) 83:22;157:10

informal (1) 151:6

information (3) 8:9;13:6;17:20

ing (1) 156:23

initialed (1)

105:2

initially (5) 20:1;26:9,18;31:5;

42:14

initiated (1) 180:20

initiative (1) 149:2

initiatives (1) 165:23

inscription (1) 83:8

insidious (1) 57:14

installed (1) 72:4

installments (1) 112:10

instance (1) 128:6

instances (1) 181:1

instead (6) 5:6;121:14;128:3,14;

129:3;130:7

instructing (1) 168:7

instructional (8) 11:16,18;13:15;14:22;

15:1,3;22:9;168:14

insubordination (1) 4:4

integration (1) 116:7

intention (1) 45:13

interest (3) 40:20;136:16,22

interested (5) 43:4;45:7;46:12;48:20;

52:19

interesting (1) 96:17

interface (1) 47:22

interfere (2) 126:19;127:8

Internet (2) 114:22;154:7

interrupted (1) 15:7

intervention (1) 91:18

into (33) 5:13;9:14,15;17:1;

21:6,10;39:16;40:1;41:2;

56:23;58:12,14;70:19;

75:1;84:15;89:15;91:11;

98:17;113:22;114:20;

117:10,11;118:16,17,23;

120:18,22;121:23;155:4;

163:11;164:18;175:8;

176:17


(6) gets - into



introduced (1) 125:1

investigate (1) 3:9

invited (2) 63:18;133:10

invoice (10) 22:17;90:16;167:14;

169:3;171:4,11;175:7,16,

22;176:18

invoices (6) 175:1,5,14,20;176:1;

177:2

involved (21) 24:17;28:5;34:10,11;

35:12,13,23;40:11;47:18;

48:21;60:19,21;61:18;

69:17;70:5,8;108:23;

132:17,20;135:21;139:10

involvement (11) 11:3,14;15:10,14,17,

19;20:4;35:21;46:21;

95:6;174:2

Iona (1) 157:15

issues (2) 8:23;177:9

J

Jamie (20) 19:1,3,11;20:15,16,18;

92:10,12;93:1;109:21;

110:4,7;113:20,20;115:5;

119:5;122:3,4,12,15

Jamie's (1) 19:12

janitorial (2) 137:3,10

January (16) 16:1;24:9;59:18;72:6;

76:19;77:21;97:8,10;

98:16;99:9;100:12,14;

152:18;154:12;155:6;

158:17

jeez (3) 74:13;157:9;158:2

Jim (3) 3:6;83:7;148:15

JIT (3) 91:17;92:6;102:20

job (17) 12:6,7;92:10,11,12,12;

119:6,7,8;126:13;145:9;

155:4;156:4;162:15,19;

163:20;173:11

jobs (1) 164:10

joint (1) 91:18

joints (1) 57:11

Joseph (3)

20:23;21:1,9

judgment (1) 73:1

July (1) 92:1

June (24) 6:4,6,7,15;7:8;8:12;

12:15;16:1;20:22;21:13;

57:16;58:4;72:6;127:22,

23;148:19,21;150:7;

159:19,20;160:1,2,2;

164:1

June's (1) 171:21

K

Karen (1) 157:16

Kathy (6) 172:1;173:17,19;

174:5;178:3,16

Kathy's (1) 172:20

keep (2) 133:4;169:20

keeping (1) 72:3

keeps (1) 34:7

Kelleher (1) 180:11

Kelleher's (1) 179:22

Kentucky (3) 35:6,8,10

Kenview (1) 135:9

kept (3) 119:19;120:17;150:14

key-chain (1) 176:19

kids (7) 26:19;95:7;115:11,14;

151:8;168:2,11

kind (8) 26:7;36:13;73:4;

106:22;109:21;139:16;

155:3;168:12

knew (19) 39:11;45:18;55:14;

61:10,20;62:4;65:14;

67:23;71:9;90:13,14;

95:16,19,23;96:1;108:18,

22;159:19;178:12

knowledge (14) 26:1,15;29:5;32:7;

48:7;64:5;67:22;75:5;

78:9;84:16;115:22;

133:19;138:12;166:5

known (6) 36:11;37:10,11;

124:16;146:2;174:5

knows (1) 178:14

L

Labeled (1) 98:5

larger (2) 142:14;144:9

Lark (8) 132:12,13,22;133:2,17;

134:1;135:16,16

last (7) 8:14;14:4;36:21;38:10,

12;110:3;157:22

later (5) 77:21;99:15;149:13;

155:8,10

laugh (1) 132:23

laughing (4) 66:13;133:4,11;134:9

Law (5) 8:4;12:16;13:19;173:1,

1

Lawrence (5) 44:21;45:3,20,23;46:2

lawyers (2) 3:15,16

layout (3) 176:21,21,22

lead (3) 8:22;9:2;121:1

leading (1) 9:8

learn (4) 12:12;109:17;165:22;

169:12

learned (2) 127:18;173:11

learning (4) 13:22;162:15,15,18

lease (26) 36:10;39:2,19;54:1,6;

58:12;59:8;60:7;61:15;

62:6,8;64:7,18;65:5;

69:16;70:11,14;76:21;

82:20;83:14;90:20;

95:12;118:16;146:6;

179:3,12

leases (1) 44:19

leasing (2) 52:17,19

least (4) 6:20;16:9;45:20;104:7

leave (10) 6:3;42:23;98:9;115:2;

122:22;123:2;127:21;

137:19;138:14;172:18

led (1) 153:18

left (2)

7:8;76:14

left-hand (1) 144:10

leg (2) 41:15,16

legal (3) 4:15;25:5;180:1

legally (1) 121:17

Leon (1) 14:2

less (5) 38:8;90:10,12,13,14

letter (11) 50:14;52:15;53:21;

152:16;153:6;158:21;

160:7,14,16;177:20;

178:3

life (2) 103:3;111:19

lights (1) 162:6

liked (3) 127:4,5,6

line (6) 43:9;55:11;69:4;75:2;

117:17;172:14

lining (1) 41:9

list (5) 79:6,11;80:1;86:2;

122:7

listed (3) 72:9;81:17;137:2

listen (1) 93:23

little (20) 3:11;15:12;16:8;21:19;

29:18;43:3;57:12;64:2;

65:9;113:3;136:17;

137:22,23,23;138:1,2,3,3;

140:18;149:20

live (5) 34:19;38:5,7;134:13,22

lived (7) 4:19;35:2;135:12,13,

15,16;136:20

lives (5) 34:23;35:1;135:6,7,17

living (4) 134:6;136:17,20,23

locate (1) 16:16

located (5) 32:15;134:10,12,16,18

location (4) 21:7;33:2;77:13;

133:20

long (13) 4:19;5:11;27:22;36:11;

37:10;38:7;102:2,2;

107:5;124:13,16;127:21;

146:2

longer (7) 45:21;65:11;70:5,8;

82:19;126:10;159:20

look (14) 16:23;54:13,19;95:3;

111:18;113:16,22;

117:10;153:4;161:6;

166:20,21;176:6;179:16

looked (5) 41:22;140:7;158:15;

164:21;170:6

looking (28) 16:20,20;20:12;34:6;

42:15;44:20,22,22;45:19;

74:22;83:3;92:11;95:4,7;

97:3;108:10;110:21;

114:23;115:1;119:14;

120:21;123:14,14;

134:21;141:14;151:11;

165:2;179:17

looks (4) 171:11,16;173:6;178:6

Lord (1) 129:10

lost (1) 157:7

lot (25) 18:12;29:12;41:15;

58:22;59:23;71:1,12;

92:2,23;102:9;110:13;

119:17;120:20;122:20;

123:3;155:23;156:17;

157:10,17,23;163:21;

164:3,22;165:3;169:20

lots (1) 119:12

Love (21) 25:16,18,21;26:2,4,14,

17;27:1,5,8,22;28:4,5,13,

17,21;29:7;34:11,17;

40:14,17

low (1) 165:19

lower (1) 80:16

lowest (1) 91:17

Lutheran (3) 20:23;21:9;174:12

M

ma'am (15) 4:13,19;12:1;15:8;

50:11,17;76:15;86:17;

89:3;113:16;127:11;

165:4;166:13,14;167:17

maiden (1) 8:16

maintenance (2) 82:14;177:10

making (6) 22:20;88:1;149:22;


(7) introduced - making



150:3;168:13,15

manage (1) 5:17

manager (1) 108:13

many (16) 18:14;34:1;62:15,18;

71:11;85:19,22;91:9,15;

122:19;124:18;143:18;

163:4,12;170:16;177:13

March (3) 5:14;10:5;16:2

mark (7) 76:4;80:7;86:8;167:11;

171:1;174:22;177:17

marked (30) 53:19,22;54:2,5;76:8,

12;79:3,7;80:10,15;86:6,

12,15;98:2,5;103:22;

104:2,6;152:13,16,19;

153:1;167:14,18;171:4,8;

175:2;177:20;178:1;

179:13

market (2) 58:16;59:5

married (3) 8:16;37:19;38:13

Mastery (120) 24:4,5;25:3,6,7,9,10,22,

23;28:21;29:4,8,9,9,11,

19;30:2,8,11;31:14,23;

32:7;33:3;34:2,10;40:23;

41:2,8,9,12;42:1,3,7;

43:3;45:1,7;46:3;47:15;

48:6,13,15,17;49:3,4,16,

23;51:4,6,7,13;54:7,16;

55:9,19,20;56:16;58:12;

59:9,12,19;61:8,18;64:6,

16;65:4,19;67:10,13,19;

68:5,8;70:14,15,19;71:3;

72:13;75:5,9,14,17;

76:21;78:10,19,21;79:1,

19;82:19;90:21;96:3;

111:4,12,23;112:11,16;

113:13;123:8,12;140:19;

142:16,22,23;143:9,14,

18;144:6;145:15;146:6;

147:16;148:3;149:16;

150:9,14,18;151:2,9,10,

12,15;159:15;160:5

M-A-S-T-E-R-Y (1) 24:4

MasteryCenter@yahoocom (2)

79:14;80:4

materials (7) 13:5;21:4;72:5;91:8,9,

15;101:2

math (4) 85:4,8,14;88:17

matter (4) 34:6;72:9;99:5;107:1

may (6) 4:3,9;36:10;60:11;

65:9;118:11

maybe (24) 16:1;27:15;28:7;34:3;

36:23;46:1,15;53:6;

55:15;72:6;94:7,8;114:9;

121:13,19;124:21;

143:21;144:2;145:8;

147:19;149:14;154:14;

162:2;165:22

mean (21) 7:23;21:16;25:7;27:3;

35:14,15;39:23;43:18;

55:15;60:14,16,21;83:3;

87:18;133:12;136:17;

137:11;138:2;139:13;

143:17;176:9

means (1) 139:14

medications (1) 58:7

meet (8) 6:12,16,20,21;97:4;

101:11;164:2;173:21

meeting (4) 63:5,18,23;98:1

meetings (2) 20:18;26:22

member (1) 139:4

members (4) 139:1,3;157:14;163:22

mention (1) 103:3

mentioned (5) 32:4;69:8;113:20;

127:20;163:15

mentioning (1) 163:14

mess (1) 57:13

messages (1) 138:11

messed (2) 82:23;83:2

met (17) 5:22;19:21,21;20:8,9;

36:14;63:1,2,3,4;69:18;

94:14;97:9;103:13;

113:23;124:17;153:19

Methotrexate (1) 58:6

might (44) 10:4;14:5;17:14,16,19,

19,21;20:21;28:18;29:17;

47:3,8,21;52:21;53:5,7,8,

10;57:9;63:21;65:18;

75:22;78:16;90:1;95:5;

102:18;107:17,17;

115:18;117:13;119:21;

121:3,7,9,9,11;123:20;

127:20;136:3;144:1;

147:6;149:13;163:15;

176:19

mind (4) 31:16;47:3;108:9;

116:22

mine (1) 31:8

minister (1) 26:21

Ministries (4) 25:16;34:11,12,17

ministry (2) 25:14,15

minute (3) 74:10;96:18;174:20

misconduct (1) 3:10

misspoke (1) 99:3

mistake (2) 88:7;169:9

misunderstood (1) 143:3

Mm-mm (10) 25:14;39:7;75:16;78:6;

105:12;138:15;139:5;

140:12;148:11;155:7

modules (1) 168:14

mom (17) 26:21;29:10;33:22;

41:14;43:17;52:6;53:6;

56:18;70:16;72:18;

79:21;132:17;133:5;

146:21;149:23;150:3;

151:18

moment (1) 148:13

money (18) 68:9;110:17;115:21;

116:6,10,20;119:14;

120:5,21;121:2;128:4;

130:6;139:18;149:18;

151:13,16,21;177:6

month (8) 37:19;38:3,4,5,8;157:7,

23;163:8

monthly (3) 6:13,17,21

months (7) 70:20,23;102:11,16;

106:20;155:10;157:22

more (15) 9:10;10:18;20:6;34:5;

70:18;71:11;99:23;

106:16;110:19;111:4;

113:3;144:2;149:17;

151:13,16

morning (4) 84:4,4,11;85:5

most (3) 8:9;27:18;28:16

mother (27) 24:18,20,21;25:1;28:9;

35:13;36:8;37:18;38:19;

46:6;47:19;49:17;50:18;

51:18;52:1;61:21;63:19,

21;69:22;71:10;72:19;

127:14,19;133:6,9,13;

137:5

mother-daughter (1) 41:17

mother's (7) 26:11;50:19;87:7,11,

12;124:10;127:16

Mount (2) 20:23;21:9

move (7) 21:14;42:19;51:5;

59:22;118:13;144:11,13

moved (10) 21:5,9;38:10;59:11;

134:20,23;135:17;136:2,

3,7

movement (1) 56:21

moving (3) 51:13;106:16;156:19

much (11) 29:17,21;31:15;49:1;

93:19;144:5;146:17;

148:9;151:5;156:11;

157:2

must (2) 72:19;180:18

myself (2) 29:14;133:5

N

name (22) 4:13,15;8:14,16;14:4;

25:6;26:4,11,13;34:7;

38:11,12;50:6,8;72:12;

87:11,12;110:3;127:16;

137:15;141:5;171:21

names (1) 167:21

Nazareth (3) 20:23;21:9;174:12

near (4) 76:13;107:3;108:11;

127:11

necessarily (1) 174:5

need (17) 7:5;22:10,12,12;31:6;

78:17;88:3,6;93:18,20;

96:18;132:1,2,5;164:16;

165:10;172:20

needed (7) 6:18;12:4;23:22;70:1;

88:9;118:3;155:2

needs (1) 74:20

Neglected (3) 115:5,6,7

negotiated (4)

47:14;110:7;113:12;

161:12

negotiating (1) 113:12

negotiation (1) 52:21

negotiations (1) 161:16

Neighbor (17) 25:18;26:2,4,14,17;

27:1,5,8,22;28:4,6,13,17,

22;29:7;40:14,17

neighborhood (2) 51:1;52:10

Neither (2) 137:21;180:15

neutral (1) 9:6

New (11) 3:2;4:18;6:22;10:5,10;

14:2;24:11;27:4;35:1;

91:20;131:9

news (2) 49:6;137:7

next (4) 44:13;76:4;103:23;

162:13

Niagara (2) 3:1;4:18

nice (2) 147:10,13

nobody (4) 92:10;94:22;146:1;

164:7

nodding (1) 5:7

None (1) 52:16

nonpub (2) 152:5;168:17

nonpublic (65) 8:4;9:6,13,18;10:14,20;

11:2,3,6,10,12,13;12:8,9,

10,18;13:3,4,7,9,14,21;

14:21;15:4,5,16,17,21;

16:17;17:12;18:17;

20:21;44:5;53:12;64:23;

65:2;66:8,8,16,17;68:21;

69:9;77:3,5,16;78:16;

82:22;91:7;97:8;98:14;

126:14,15,20;145:6;

149:10,12;151:8;168:9;

172:8,12,14;173:2,14,20;

174:7

nonpublics (2) 47:1;92:9

nonpubs (3) 73:6;89:1;126:23

Nope (5) 32:17;39:10;128:5;

134:15;168:21

nor (1) 180:15


(8) manage - nor



normally (3) 100:19;107:11;157:23

note (1) 20:21

notes (1) 72:2

notice (1) 179:18

November (7) 20:20;57:4;59:1,9;

91:23;112:9,16

nowhere (1) 73:19

number (13) 25:13;32:18;35:6;

50:21;52:7;56:6,7,9,10,

11;127:10;131:21;155:10

O

obligation (1) 103:18

observed (1) 127:2

obtain (2) 7:14;9:3

obtained (1) 79:11

obtaining (1) 48:16

obviously (8) 3:18;12:21;70:21;

77:20;79:12;87:5;

145:11;170:22

occasion (2) 17:8;121:7

occasions (2) 17:7;105:23

occurring (1) 155:22

October (6) 20:20;57:4,13;80:18;

91:22;171:16

off (11) 26:18;48:3;59:18,19;

102:12;141:22;148:14;

156:6;162:6;169:6;

180:15

offer (1) 53:13

Office (15) 12:10,17,18;13:1,9,13;

14:10,15;15:22;63:2;

108:3,7;130:21;175:8;

176:17

officer (4) 7:3;27:7,14;105:5

officers (1) 32:8

offices (3) 42:21;43:7;71:23

official (3) 4:2;172:8,14

officials (1) 173:2

Oladele (24) 6:1,2,7;7:8;88:1;91:19;

92:2;94:10;95:9;97:4;

99:23;100:18,23;101:20;

103:2;104:18;122:11,13;

154:21,22;155:11;169:7;

180:13,15

O-L-A-D-E-L-E (1) 6:1

Oladele's (1) 104:19

old (7) 37:11,12;38:4;44:21;

103:14;147:18;171:18

once (6) 19:3;38:16;57:23;

120:6,15;163:8

One (71) 5:1;11:15;16:23;18:13;

23:14;24:5;30:12,15,19,

19;31:6;32:19;36:23;

38:4;44:10;53:9;60:18;

62:17,19,20;71:23;73:2;

74:2,4,17;76:5;79:2,20,

22;86:21;93:3,6;97:4,16;

102:10,13;103:3,8;

106:14;107:17;121:7,13;

123:15;125:2;136:9;

138:5,23;139:3;140:9;

141:10;143:19;144:2,8,

18;148:13;152:3;156:6;

161:6,16;162:10;165:11;

166:11,11;170:7,8;175:9,

10,11,12;176:4;177:7

ongoing (1) 148:4

only (23) 30:12,15;73:22;79:1;

82:6;91:7,8;92:5;97:17,

18;107:20;108:22;

115:17,19;136:9;141:17;

144:8;157:2;164:23;

170:7,8;172:12,13

onto (1) 166:2

open (2) 115:17;143:7

operated (1) 127:13

operations (1) 64:15

opportunity (2) 23:16;165:17

opposed (2) 86:20;151:19

oral (1) 148:9

order (14) 22:17;23:7,7;80:10,16,

23;81:8,19;82:1,2,9,13;

86:11,16

ordering (2) 13:18,20

orders (1) 82:5

ordinarily (2) 108:3;131:9

organize (1) 51:18

organized (2) 93:8,8

original (2) 31:22;172:1

originally (4) 45:19;49:2;61:19;

159:22

others (1) 127:6

otherwise (1) 90:7

out (35) 11:21;26:8;31:1,6;

32:13,20;42:7;43:5;53:4;

57:12;60:18;67:17;87:7;

102:20;107:2;110:14,15;

114:11;115:2;120:15;

123:14;125:11;127:9;

136:3;138:23;142:2,9;

147:21,22;159:3;163:10,

12;165:11;173:5,7

out-of-district (1) 166:17

over (19) 14:15;15:22;24:2,8;

29:20;56:22;62:23;

65:16;66:6;73:5;85:3;

92:12;102:21;133:9;

162:2;163:5,6;180:7,17

overall (1) 44:5

overloaded (1) 91:16

oversee (3) 41:19;84:10;164:6

overseeing (2) 93:12,14

overstep (1) 121:18

overstepping (1) 65:18

owe (2) 120:1,2

own (13) 7:23;25:11,13;28:20;

42:17;43:9;56:1;68:18;

111:3;155:14;172:18;

175:16;177:2

owned (5) 45:3;108:17;132:22;

133:20;134:20

owner (5) 36:3,4,5;37:7;142:7

owners (1) 41:1

owns (2) 36:2;136:10

P

packet (2) 57:22;58:1

page (13) 54:13,19;104:8;

108:11;112:2,4,5;113:17;

129:23;161:6;176:3,11;

179:17

paid (24) 28:13,15;30:10,12,14,

15;83:20,22,23;86:21;

90:15;94:20;96:6;

100:10;101:4;120:7;

125:22;128:4,7;129:2;

130:7;131:18;139:20;

155:3

painting (1) 85:17

paper (2) 56:21;59:23

papers (2) 27:4;137:2

paragraph (1) 115:3

Pardon (3) 16:13;89:5;122:23

parent (12) 11:2,13;15:10,13,17,

18,19;16:21,22;20:4;

46:21;95:6

parents (5) 11:4,7;15:16,19,21

parish (2) 44:14,15

part (12) 3:10;12:6,7;37:7;

52:20;97:14;106:15;

145:17,21,21,22;149:2

participate (2) 60:12,14

participating (1) 157:11

particular (7) 12:5;31:18;57:2;77:12;

117:11;119:9;151:3

parties (3) 42:12;60:18,20

parts (1) 145:20

pass (6) 7:7;100:22;101:10,19,

22;102:3

passed (1) 20:5

passing (1) 36:14

past (1) 121:21

pay (33)

24:22;30:16,18;67:10;

82:6;86:3;90:9;100:16;

101:16;111:5;112:12,16,

20;116:7,8;120:7;121:2,

20;128:20;130:11,12;

146:15,17;148:4,10;

154:17;155:9,16;161:9,

13,14,18;162:4

payable (1) 112:10

paycheck (1) 30:17

paying (29) 56:16;67:22,23;84:19;

88:11;89:3,6,6,10;96:12;

111:5;120:11;128:3;

129:8,11,11,20;130:6;

131:1,3;139:10;149:20;

151:11;152:10;154:6,20;

160:20,21,22

payment (17) 21:23;22:2,18;23:1,2,6;

25:1,2;81:4,10,11;89:17;

94:2;120:15;131:1,2,2

payments (8) 21:21;119:20,20,23;

128:13;149:22;150:1,3

payroll (4) 25:3,4;30:16,17

Pennsylvania (3) 35:7,8,10

people (36) 34:1;39:11;43:17;52:6;

53:5;72:21;82:5;101:22;

102:9;113:21;120:17;

126:18;138:4,7;141:18;

147:15;155:23;156:7,14,

18,21;162:2,17;163:6;

164:4,10,19;165:17;

170:15,16,19,20;171:23;

172:7,17;177:5

perfect (2) 164:12,13

perform (5) 39:21;46:19;133:19;

156:4;168:1

performance (2) 4:2;125:20

performed (4) 9:18,20;39:18;167:22

period (11) 24:8;28:5;29:20;56:22,

23;64:11;112:21;152:9;

162:21;166:20;177:14

persistently (1) 91:17

person (19) 8:18;30:17;38:12;

44:19;61:10;62:21,22;

63:4;74:9,20;79:1;

102:14;108:22;123:6;

147:10,13;157:21,22;

172:1


(9) normally - person



personal (5) 25:2;107:7;110:15;

124:23;133:12

personality (1) 71:12

personally (2) 173:22,23

Peters (2) 43:23;44:7

phone (7) 56:1,1,2,3,7;62:21;94:5

phrase (1) 48:15

physical (3) 58:13;59:1,4

pick (3) 93:4,6;122:9

picked (2) 158:12,13

picture (1) 51:10

pieces (1) 164:18

pilot (1) 83:19

PLA (4) 91:21;92:1,3,6

place (38) 12:3,14;13:7,11,13,16,

17,20;14:20;15:1,3,15,

18;20:19;26:18;29:10;

31:3,13,15,17;32:22;

33:17;64:3,6,9,15;65:23;

72:8,23;74:22;78:17;

83:12;117:23;120:14;

134:22;144:20;164:11;

167:7

places (2) 32:13;73:21

Plant (9) 17:8,11;18:9;19:4,16;

20:7;73:12;74:9,16

plate (1) 110:13

please (10) 5:4;64:13;65:13,14;

79:4;91:1;103:23;

118:15;128:20;130:4

pleased (2) 125:20;126:2

pm (1) 181:8

pneumonia (1) 107:3

point (39) 7:11;11:23;13:9;27:23;

28:13;35:5;47:10;60:7;

63:9;67:17;74:18;77:15;

82:19;83:13;91:10;92:5;

94:7;98:16;103:3,16;

106:11;107:5;119:13;

126:10;128:2;130:5;

132:16;143:19;145:2;

149:16;150:1,4,5;162:21;

163:19,19;164:16;

171:14,18

pointed (1) 11:21

popping (1) 34:7

portion (3) 84:1;107:2;121:18

position (14) 5:11,13,16;6:22;16:4;

18:8;19:14;27:14;97:9;

108:13;124:13;164:8;

168:20;171:18

possibility (1) 138:17

possible (8) 4:4,5;5:4;52:21;53:7;

113:22;178:9,11

possibly (3) 47:11;115:13;148:19

potential (3) 3:10;4:10;117:9

precedence (1) 102:21

predecessor (1) 8:20

Prednisone (3) 57:21;58:1,6

prepare (5) 97:5;108:3;175:14,16,

18

prepared (4) 107:14;175:7,11,12

present (1) 63:5

presented (4) 105:16;158:5;159:5;

177:9

President (5) 118:20;179:21;180:4,7,

18

presumably (1) 100:12

pretty (16) 17:19;18:3,4,5;22:13;

64:8,8;93:10;120:7,15,

19;124:6;133:12;134:12;

151:5;160:9

prevented (2) 58:14;59:4

previous (1) 8:7

previously (4) 8:10;19:14;96:7;

145:15

price (1) 56:16

primarily (1) 41:11

primary (5) 45:13;47:22;57:18,18,

20

principal (3) 24:17;124:9;173:17

principals (2) 24:5;173:21

prior (42) 6:3;7:4;8:6;9:18;12:3,

7,17;19:9;29:14;33:2;

39:2,18,21;40:4,8,10;

41:2;48:13,15;51:13;

57:8;64:18;68:12,13,20;

69:5;81:1;91:21;97:6;

105:19;109:7,11;120:21;

122:22;145:22;146:21;

147:1;149:14;167:3;

168:22;174:3;180:22

priority (3) 102:22,23;122:7

private (1) 33:12

probably (28) 19:20;20:20;56:21;

66:14;82:15,15,16;86:23;

97:8,11,12;99:20;100:23;

101:6;102:4,14;105:22;

119:15;130:13;150:11;

154:10,10;155:12;161:7;

162:12,14;164:21;177:3

problem (4) 71:10;95:9,10,11

problems (1) 28:20

procedures (1) 157:1

proceed (1) 8:23

process (6) 7:20;16:9;30:21;89:15;

92:19;102:5

processes (1) 157:1

professional (41) 11:1,5,13;12:13;13:10;

20:3;46:23;53:13;64:21;

65:1,23;66:2,6,9;67:10;

68:11;69:2,4;78:2,12,13;

91:5,7;92:15;93:12;

101:3,5;116:13,16,18,20,

21;117:3,6;118:3;126:4,

15;155:14;162:5,16;

163:23

professionally (1) 127:2

professionals (1) 53:13

program (26) 7:15;13:15,22;20:11;

30:2;83:19,20,23;88:2,

20,21,23;90:22;91:2;

96:8,9;115:6,7,9;125:21,

22;127:1;136:7,8;176:7,

18

programming (2) 13:8;166:1

Programs (2) 4:23;115:4

progressive (1) 57:3

Projects (1) 157:17

properly (2) 9:21;10:15

property (7) 22:21;59:6;64:7;77:1;

136:15;151:3;159:16

proposed (7) 89:12;96:23;99:10,18;

100:1;105:21;163:11

proposing (1) 117:3

protocol (4) 21:20;22:5;180:2,6

provide (7) 35:15;49:22;64:10;

68:11;84:11;140:10;

141:2

provided (17) 10:23;11:1;50:23;52:8;

68:16;71:21;84:7,11,12;

85:3;113:17;121:23;

139:23;140:22;141:9;

148:18;166:6

provider (5) 48:11,12;79:12;172:11,

13

provides (1) 112:1

providing (12) 9:16;33:4;66:20;68:2;

69:4;71:15;140:16;

156:22,22;157:18;

162:23;166:4

provision (1) 168:6

public (5) 33:12;50:23;52:8;

68:22;165:19

purchase (18) 22:17;23:6,7;77:14;

80:10,15,23;81:8,19,23;

82:1,2,5,9,13;84:19;

86:11,16

purchased (2) 14:19;78:9

purchasing (5) 22:9,10,11,14,20

purpose (6) 9:16;16:16;47:4;83:15,

17;145:5

purposes (2) 90:21;98:4

push (1) 102:15

pushing (3) 92:8,9;152:4

put (27) 27:13;58:5,6;60:18,19;

67:8;73:8,21,23;74:7;

80:3;82:13;88:19,21,23;

91:2;114:20;161:3,18,20;

163:23;166:17;167:6;

172:13;175:8;179:3,7

putting (2) 117:11;173:3

Q

quarters (1) 147:22

quick (1) 76:2

quite (3) 119:10;122:10;158:2

quotations (1) 158:8

R

RA (2) 52:2;57:8

raised (2) 98:17;179:9

Ralph (2) 118:18;179:19

rate (1) 165:19

rather (2) 106:4;128:8

reached (1) 56:13

reaching (1) 75:1

reacquainted (1) 39:6

reading (3) 85:4,9;88:16

real (3) 29:22;73:3;132:16

realize (2) 156:8,11

really (51) 26:5,7;28:3,15;29:21;

31:5,11;36:13,14,23;

39:1;43:13;51:6,19;52:2,

4;56:20;57:5,15;58:13,

18,20,22;59:14,23;62:10;

72:23;73:1;81:13;85:12;

88:13;89:3;92:5;103:16;

111:11;117:3;121:6;

122:4;125:20;126:7,13,

21;133:8;142:23;149:17;

150:15;151:2;152:4;

155:22;159:10;167:5

reason (16) 70:1,13;89:14;95:1;

105:13;109:7,14;114:9;

117:10;125:19;132:7;

133:4;155:12;164:7;

166:2;172:8

reasons (5)


(10) personal - reasons



73:2;93:3,7;128:8;

130:8

reassignment (2) 61:23;174:13

recall (24) 9:22;10:18;17:15,17;

20:18;45:6;54:9;60:10;

65:8;82:12;84:18,19;

85:11;98:7;100:4,5;

107:23;109:20;128:2,6;

130:14;131:14;142:19;

153:9

receipt (1) 81:20

receive (3) 13:6;64:11,13

received (22) 25:1,20,20,23;53:22;

54:2;76:8;79:7;80:10;

86:11;98:2;104:2;152:16,

19,23;158:8;167:2,14;

171:4;175:2;177:20;

179:13

receiving (2) 67:15;165:7

recently (3) 28:18;29:7;37:16

recess (5) 48:4;76:3;96:19;

141:23;174:21

recognize (5) 7:1;54:6;86:16;171:20,

21

recognizing (1) 77:15

recollection (4) 70:9;99:8;101:12;

124:2

recommendation (1) 177:20

recommendations (1) 5:17

record (10) 5:7;48:3;50:14;83:7;

96:22;98:5;141:22;

148:14;179:4,20

records (1) 72:3

Redfield (18) 36:6;37:1,10;38:15;

39:6,8,11;40:7,10;63:7,

18;94:16,18;100:7,8;

101:13;103:4;108:12

reference (3) 116:11;124:8,11

referenced (1) 13:11

referred (2) 53:16;69:12

referring (4) 46:19;53:9,14;166:14

refers (3) 52:7;115:3,10

reflect (1) 83:8

refusal (1) 4:3

refuse (1) 3:23

refused (2) 6:13;157:15

refuses (2) 157:4,5

regard (2) 58:23;128:17

regarding (5) 5:18;7:6;18:22;180:21,

22

regardless (2) 90:15;124:3

registration (4) 87:20;88:4,6,12

reimburse (2) 160:23;161:23

reimbursed (1) 161:21

reinvestment (1) 149:6

relate (1) 4:1

related (3) 37:17,18;92:9

relating (3) 12:11;18:17;92:3

relationship (4) 6:10;41:3,17;167:5

relationships (1) 170:17

relatively (1) 162:20

relay (1) 156:13

relevant (2) 103:8,12

remained (1) 92:21

remember (32) 15:23;18:10,16;27:21;

30:14,22;31:1;70:12;

81:7,13;88:13;98:12;

100:3,11;113:7;120:19;

121:12;123:10;124:21;

127:5;128:11,19;129:1,7;

130:20;131:15;142:21;

151:17;178:8,9,11,14

remission (1) 57:7

removal (4) 161:10,13,15;162:1

removal/utilities (1) 162:22

remove (3) 65:13,14;162:3

rendered (3) 81:17;167:13;171:4

rent (11)

16:20,22;113:4;135:2;

160:20,21,23;161:1,7,7,8

rental (3) 22:12;113:17;162:11

rented (2) 17:4;135:22

Renting (7) 42:11,16;43:4;134:19;

135:20;136:15;162:9

replace (1) 157:21

replacement (1) 163:16

report (2) 5:20;7:9

reported (1) 6:7

reporting (3) 5:21;6:10;8:8

reports (4) 91:17,18;92:6;102:20

represent (1) 126:8

representative (7) 46:3;61:2,5,8,14;63:8;

140:20

representatives (1) 3:20

represented (1) 43:22

representing (1) 63:13

request (5) 6:14,15;65:13;81:3,3

requested (4) 6:12;113:18;126:19;

127:1

require (1) 166:5

required (6) 10:21;11:10;12:15;

22:5;24:1;173:1

requirement (1) 8:3

requirements (2) 52:20;102:21

requisition (4) 76:7,13,18;82:4

research (3) 12:5;56:14;58:14

reside (1) 4:17

residential (2) 134:8;147:22

resistance (2) 156:18,23

resolved (1) 122:21

respect (1) 56:13

respond (1) 137:22

response (1)

158:20

responsibilities (2) 5:16;92:3

responsible (1) 41:11

result (1) 116:19

results (1) 10:8

retirement (1) 12:7

retreat (1) 17:6

retrospect (2) 156:10;169:23

reveal (2) 103:6,20

review (5) 6:19;180:3,12,14,14

rheumatoid (1) 102:10

rheumatologist (2) 57:17;58:4

Rich (1) 107:21

right (165) 7:16;11:15,23;15:12;

16:8;22:13,16,19;23:5,9;

25:21;29:7;31:1,3,4;

33:17,20;37:1,20,22;

38:1;39:12;40:20;44:6;

47:14;51:17,21;52:15,19;

53:9,16,18;54:17;55:2,4;

56:18;59:1,8,10;60:6,8;

65:5;67:9,14,20,21;68:2;

69:8;70:19;73:6,8;76:11,

19,22;77:21;80:14,16;

82:2,7,21;83:6,13;87:1,3,

6;88:22,23;89:11,17,19;

90:10;91:3,10,11;94:5,

18;95:18;99:15;100:6,6,

18;102:2;103:15;105:23;

106:14;107:8,9;108:7,21;

109:22;111:13,15;112:6,

12,13,19,21;113:15;

115:15;116:6;118:13,14,

19;119:6;123:1,4;124:10;

126:12;127:21;128:15;

129:9,12,18;130:9,16,19;

131:10,19;132:2,5,10;

134:10;135:15,19;

138:12;140:1;141:16,21;

145:12;148:5;149:16;

151:2;153:11;154:3;

156:1;158:6,10,13,19;

159:20,23;160:3,4,19;

164:14;165:8;166:22;

167:17;168:20;169:1,4,6;

170:3,10;171:8,14;173:8;

174:5,17,19;177:7;178:1;

179:16;180:16;181:7

right-hand (2) 144:9,9

ring (1) 135:9

road (1) 72:22

role (19) 8:20;16:15;17:3;30:1;

34:12,14,16;39:9;46:7;

52:12;55:5,6;78:18;

79:23;91:16,18;92:21,22;

103:1

roles (1) 29:23

rolled (1) 9:14

room (6) 7:18;38:10;60:20;94:1;

113:17;144:8

ROONEY (64) 3:4,6;18:1;31:12;48:3,

5;53:18;54:4;76:2,4,10;

79:3,10;80:7,13;82:18;

83:11;86:5,8,14;87:15;

96:20;97:22;98:4,11;

99:3,6,14;100:2;103:11,

22;104:5;107:21;108:2;

109:4;110:6;112:3,6,7;

118:8;132:19;133:18;

138:9;139:17;141:7,22;

142:1;147:11;148:16;

152:13;153:3;167:11,16;

171:1,7;174:19,22;175:4;

177:17,23;178:19;179:5,

9;181:7

Rosalind (11) 36:5,6;37:1,3;63:6;

69:19,20;82:15;93:23;

110:17;134:12

Roth (22) 44:15,18,22;45:6,16,

23;46:10;47:5,16,20;

48:1;49:1;50:15;52:22;

54:11;55:4;60:17;61:2,

10;63:2;119:17;122:19

R-O-T-H (1) 44:15

rules (1) 117:20

run (7) 7:15;32:11;93:17;

124:9;127:2,19;132:15

running (1) 109:22

Russo (3) 114:17;118:3,6

S

S-A-D-D-I-Q-U-E (1) 167:21

sake (1) 152:8

Sal (1) 146:2


(11) reassignment - Sal



salaries (3) 139:10,13,20

salary (1) 139:16

Salvatore (3) 142:3;175:6;177:11

Samantha (1) 122:18

same (38) 8:18;10:8;35:10;38:5,

7,12;42:7;60:20;69:14;

83:17;90:21;102:16;

111:6,6,12;112:21;115:3;

117:15;123:5;129:23;

130:23;131:4;137:4,5;

144:3;145:17;150:3;

158:1;164:9;165:8;

167:1;169:21;170:13;

176:7,8,10;177:14;179:9

Sandy (1) 137:17

Sanjay (3) 113:23;114:1,2

saw (4) 38:16;103:13;111:17;

164:22

saying (13) 35:7;58:11;86:20,21;

90:19;95:4;101:6,12;

133:12;140:5;144:16;

161:17;178:15

scale (1) 115:16

schedule (1) 111:13

School (36) 3:8;4:10,21;7:15;9:6;

11:2,3,6;13:4,21;33:13;

47:8;50:23;52:8;53:12;

61:3;68:4;71:17;78:16;

103:7;124:9;139:12;

152:3,6;172:4,8,14;

173:2,13,14,14,20;174:3,

8,9,15

schools (42) 8:4;10:21;11:10;12:8,

9,10,19;13:7,10,14,17;

15:4,4,5;20:21,22;44:5;

65:13;66:8,8;68:19,21,

21,22;91:17,22;92:1,2,3,

6;97:8;126:17;127:4,5;

152:1;165:12,13,19;

166:6,7,9;168:9

scope (1) 119:7

screaming (1) 169:15

scribble (1) 97:20

second (4) 108:10;175:11,12,14

secretaries (1) 107:18

secretary (4) 12:22;27:15,17,18

seeing (2) 178:8,11

seem (3) 94:20;142:5;149:20

select (1) 93:3

sell (1) 83:22

send (3) 74:23;138:4,6

sends (2) 137:22;138:5

sense (5) 29:23;89:16;126:10;

166:2,4

sent (3) 77:23;78:10;153:6

separate (4) 55:5;113:5;142:10,13

September (4) 19:4;91:22;152:22;

166:21

series (1) 3:13

serious (4) 29:23;30:1;73:2;151:1

service (5) 52:8;65:21;85:16;

115:9;154:7

services (65) 8:5;9:16;10:20,22;

11:10,16,18;22:11,20;

23:9,17;33:4;34:1;35:16;

46:19;48:11;49:23;

50:22;64:10,11,13,14;

66:21;68:12,15;69:5;

81:16;84:1,5,7,12,13,15,

21;85:2,5,12,15;88:12;

89:7,10;122:1;129:8,12;

133:19;137:10;139:23;

140:10,16,22;141:2,9,14,

15;148:18;162:23;165:7;

166:4,6;167:2,13;171:3;

172:12,13;177:10

SES (1) 48:11

set (5) 54:20;72:5;77:2;114:5;

117:20

setting (1) 9:6

settled (1) 43:19

seventy (1) 147:20

seventy-five (3) 84:20;89:18;125:23

seventy-something (1) 70:17

several (1) 36:21

shelf (1) 102:18

short (1) 26:4

Shortly (1) 94:16

show (4) 84:18;89:23;111:15;

171:8

showed (5) 89:21;90:10,12,13,14

showing (9) 50:13;54:5;76:11;

80:14;86:15;104:6;

167:17;175:5;178:1

shred (2) 138:21;139:8

shredded (1) 138:13

sick (21) 29:16,20;51:17;52:4;

56:20;57:1,4,5;59:16,20;

60:22;61:17;72:20,23;

107:2;137:11;155:23;

156:3,5,7,9

sickness (2) 70:6;150:2

side (10) 3:12;92:8,10;102:22;

122:4;142:14,15;144:9,9,

10

sign (18) 60:15;61:15;81:19;

82:3,5;105:5,20;106:1,4,

5,11;153:16;167:7;170:9;

171:14;172:7,17,18

signature (10) 54:14;76:13,15;104:10,

19;171:20;172:20;

174:16;178:17;179:23

signatures (1) 104:17

signed (25) 23:17;61:19;67:5;

80:16,18;81:1,14,22,23;

82:8,10;86:17,23;104:23;

105:1,8;106:7,9;108:19;

159:5;169:6;170:1,7;

179:19;180:15

significance (1) 131:21

signifying (1) 104:14

signing (5) 81:20;104:14;169:17,

19;180:23

signs (1) 82:1

similar (3) 86:19;152:2,7

Simmons (4) 8:12,18;12:15;148:22

simple (1)

22:13

sit (1) 78:17

site (7) 9:6;21:2;42:18;72:10;

95:8;149:10;167:6

sites (1) 140:7

sits (1) 157:6

sitting (1) 75:8

situation (2) 98:15;102:22

situations (1) 170:14

six (2) 70:20,22

sixty-something (1) 147:19

slipped (2) 121:9,11

slowly (2) 130:2;156:20

smaller (1) 142:15

Smith (22) 6:11,12;96:9,11,22;

97:5;98:8;99:10,17;

104:23;105:19,19,21;

106:5,8;107:6;127:20;

137:4;164:1;169:14;

180:14,15

Smith's (2) 14:15;15:22

snow (6) 161:10,13,14;162:1,3,

22

snowplowing (2) 154:7;177:11

socks (1) 133:13

sole (1) 36:3

Solomon's (6) 26:18;29:10;31:3,13,

17;32:22

somebody (6) 136:23;138:19,20;

155:16;159:13;175:21

someone (11) 17:21;18:5;56:18,19;

72:14;82:1;90:14;92:11,

19;94:8;151:11

someplace (2) 35:3;63:3

sometime (4) 36:21;99:9;100:12;

155:8

Sometimes (5) 24:23;26:3,6,6;57:3

somewhat (1) 29:1

Somewhere (9) 16:2;32:5;57:13;73:13;

107:2,3;109:19;134:12;

136:6

son (6) 167:18;169:16;170:14;

171:11;174:2,6

son's (1) 174:16

soon (1) 124:21

sorry (5) 58:4;66:12;132:23;

134:9;145:19

sort (11) 6:10;8:23;39:21;71:5;

75:17;116:22;141:1;

150:18;168:1,5;178:2

sorts (1) 58:20

sound (2) 27:12;131:19

sounds (3) 9:8;29:1;41:17

space (61) 7:15;9:4,17;13:2;

16:10,16;17:9;18:17,22;

21:17,18;22:12,21;41:12;

42:6,11,16;43:4;44:8,11,

20,22;45:20;46:12;47:4,

8,11;48:13,16;52:18,19,

22;59:10;64:22,22,23;

65:14;70:21;75:3;94:9;

98:18;99:12,19;100:10;

111:6;135:20,22;144:5,

11;145:2,11,14;146:5;

147:3;148:19,22;149:8;

152:8;155:13;160:5;

162:10

spaces (1) 41:22

speak (2) 10:17;141:1

speaking (3) 100:21;120:6;180:2

speaks (1) 179:1

Special (1) 157:17

specialists (1) 116:8

specific (3) 18:13;101:8,12

specifically (9) 10:18;12:22;18:13;

23:14;72:1;100:3;116:9;

126:23;128:19

Spell (1) 167:20

spelled (2) 14:4;178:3

spending (4) 149:17;151:13,16,21


(12) salaries - spending



spent (1) 177:13

Spinuzza (26) 142:3;146:2,7,10,13,

15,21,23;147:18;148:3;

149:22;151:12;152:11,

15,19,23;153:7;154:6;

155:9;159:2;167:2;175:6,

15,16;177:1,11

S-P-I-N-U-Z-Z-A (1) 142:3

spiritual (1) 26:22

spoke (9) 7:22;18:19,22;95:10;

103:2;148:19;149:8;

150:7;154:23

spoken (1) 126:7

spot (12) 13:4;32:17,18;43:2;

53:7;68:3;95:3;134:22;

135:17;136:3;150:8;

159:21

spots (1) 166:2

St (8) 20:23,23;21:9;44:21;

45:3,20,23;46:2

staff (12) 19:21;93:2,5,5;125:2,3;

143:13;156:17;157:3,14,

14;163:22

stand (1) 149:5

Stanley (1) 127:6

start (10) 23:9,16;26:8,14;27:23;

102:5;145:2,14;151:11;

167:8

started (19) 26:18;29:15,16,19;

54:22;57:5,14;59:13;

91:19,23;92:1,2;93:11;

134:9;148:17;158:17;

168:19;173:5,9

starting (1) 127:10

State (8) 4:22;8:4;10:6,10;14:2;

24:11;26:10;27:4

stated (1) 117:18

statement (3) 3:2;73:4;158:4

statements (1) 4:8

states (1) 108:12

status (1) 7:4

stay (1)

38:15

stepping (1) 19:12

steps (1) 55:11

stepsister (3) 38:3;103:16,17

stepsisters (1) 103:4

Steve (10) 44:15,21;45:6;49:1;

60:17,18;61:10;69:18;

70:1;119:17

Steven (3) 44:18;54:10;55:17

still (20) 24:6;28:17;30:5,8,10;

31:23;58:8;83:16,17;

90:20;116:20;122:22;

123:1;125:17;126:14,18;

162:23;165:20;171:17,18

stop (1) 151:9

stopped (11) 28:18;29:8,9;32:5;

128:2;130:6;138:20,20;

144:15,23;149:21

storage (8) 13:2;64:22;65:1,10;

69:14;73:5;91:5,8

stored (1) 75:6

storing (2) 152:2,8

story (1) 3:12

Street (25) 3:1;4:18;32:14;33:1;

36:10;49:5;77:9;108:13;

132:12,13,22;133:2,17;

134:1,16,18,19,19;

142:23;148:18;149:14,

18;152:7,10;165:14

student (2) 86:3;89:19

Students (15) 33:9;50:23;51:1;52:9,

9;85:19;86:2;87:20;

88:19;90:1,10,12;165:13;

167:8;168:10

stuff (17) 12:15;23:18;28:2;

42:12;73:21;74:1;92:8;

94:1;133:8;140:8;146:1;

152:2,6;160:23;169:20,

22;170:15

subcontractors (1) 172:5

subject (1) 16:11

subjecting (1) 4:4

submit (2)

180:10,13

submitted (5) 169:3;171:12,16;

180:3;181:4

suburban (4) 165:13,18;166:6,9

Sue (8) 18:7;20:8,16,19;21:15;

73:18,22;74:10

suggest (2) 61:15;100:8

suggested (1) 52:16

suited (1) 149:13

summer (19) 83:19,20;84:5,21;85:3,

20;87:19;88:2,20;90:22;

91:2,3;96:8,9;125:21;

127:1;136:5,7,8

summertime (1) 136:4

Superintendant (13) 4:22;5:18,20,21,22,23;

8:7,8;44:4;101:10;

122:13;162:18;180:4

Supervisor (22) 12:2,8,9,21;18:19,20,

23;19:1,13;114:19;118:9,

10;122:8,11,16;125:7;

157:4,5;164:8;168:23;

169:1,1

supervisors (1) 16:23

supplemental (2) 48:11;141:15

supplies (6) 13:18,20;21:4;22:9;

72:2;83:18

support (1) 22:22

supported (1) 21:22

supposed (10) 19:23;23:1,11,13;

84:14;85:4;88:16;89:18;

170:11;172:1

sure (43) 8:1;10:4;17:14,19;

18:3,4,5;28:19;47:21;

50:13;55:11;63:3,11;

64:8,8,8;67:9;85:10,11;

98:19;99:16;106:7,8;

120:7,15,19;121:10;

123:3;128:7,13;129:23;

134:12;141:19;160:9,11;

163:14;164:13;168:13,

15;173:13;174:13;

176:20;177:7

surprised (1) 169:17

surrounding (2) 51:1;52:9

swell (1) 57:11

swimming (1) 85:17

Sylvia (2) 27:17,19

symptoms (1) 58:1

T

Tables (3) 75:20,20,23

talk (22) 3:11;43:21;44:1,2,13,

13,18;45:23;47:20;55:17,

23;60:17;93:19;94:13;

96:9;99:17;101:9;137:9,

13;151:18;154:6,9

talked (27) 18:5,12,14;20:10;

44:15;46:2,10,20;47:10;

55:4;74:10;91:6;94:10;

95:14;98:14,15;99:22;

116:17;140:18;154:1,21,

21;155:10;159:6;161:11,

17;170:12

talking (22) 9:7,10;11:5;16:8;17:1;

20:15,16,16,16;44:8;

47:5;61:2,5,8,11;98:13,

23;99:10;125:13;140:19;

141:10;177:9

tangible (1) 22:15

targeting (2) 51:1;52:9

task (2) 102:16;109:22

tasks (1) 162:19

tax (2) 128:8;130:8

Taxes (1) 129:4

taxpayer (1) 25:13

teach (1) 168:11

teacher (6) 13:20;46:23;66:18,20;

68:1;72:1

teachers (8) 11:2,6;13:4,17;101:4;

116:16;143:22;167:8

teaching (2) 125:3;168:10

team (1) 91:18

Technology (2) 114:19;116:7

telephone (6) 35:5;56:9;113:1,2,6,9

televisions (1) 21:5

telling (20) 11:11,20;59:16;60:23;

62:9;63:17;69:5;86:20;

89:21;100:7;120:6;

151:3;155:12;160:17;

161:19;164:1,4,19;

169:15,15

ten (2) 36:17;138:7

term (1) 166:21

termination (1) 4:5

terms (5) 8:22;54:19;56:14;

110:16;111:11

testified (1) 106:18

testify (2) 106:19;130:14

thereafter (1) 128:13

therefore (4) 62:11,13;114:23;173:3

thin (1) 53:4

thinking (14) 35:8;42:6;49:7;52:22;

74:16;98:21,21;100:13;

123:21;133:5,9;136:19;

161:21,22

third (1) 69:8

third-party (1) 172:11

thirteen (2) 85:23;90:4

thirty-four (1) 112:17

thirty-six (2) 112:9,20

thirty-two (1) 54:22

thoroughly (1) 3:14

though (3) 58:11;59:22;153:6

thought (27) 15:14;35:2,7;52:10;

74:10,21;78:16;87:9;

95:2;110:14,15,19,20;

111:1,7,8;114:6;115:1;

121:19;127:8;131:12,13;

149:13,14;150:7;161:19;

165:12

thoughts (1) 53:11

thousand (11) 24:2;54:23;112:9,11,

17,20;131:18,21;132:1;

146:18;147:4


(13) spent - thousand



three (14) 6:20;36:21;53:9;54:19;

57:23;89:18;102:14,15;

106:19;112:4,5,8,10;

138:6

Three-quarters (1) 104:12

throughout (1) 6:2

Thy (17) 25:18;26:2,4,14,17;

27:1,5,8,22;28:4,5,13,17,

21;29:7;40:14,17

Thyself (1) 25:18

times (5) 6:20;57:15;117:13;

122:19;144:1

Timing (1) 99:5

Timon (2) 168:4;174:12

title (38) 4:21;9:14,18;10:14;

11:3,9,11,23;12:2;13:19;

14:19,21;15:10,21;16:17;

18:20;19:12,13;21:4,8;

27:10;66:15;74:17,18;

89:1;115:3,21;116:5,6,

19;117:14,20;149:2;

164:8;166:5,5;168:22;

169:1

TNATS (4) 25:16,21;34:11,17

Today (7) 3:11;4:9;58:9;98:7;

109:7,12;133:13

together (12) 40:8;67:8;73:3;82:13;

88:19,21,23;123:22;

140:21;161:3;164:1;

175:9

told (39) 23:15;44:8;45:6;46:15;

49:1;55:13;60:18;63:16;

66:5;70:7;74:2;94:5;

101:9,16;106:21;109:6;

119:23;120:5,13,16;

121:4,8;130:5;137:4,5,8;

155:9,15,19;160:17,17;

169:10,11;170:8;172:4,5,

16;173:4;178:12

Tom (4) 43:23;44:1,2,4

took (11) 8:8;14:15,20;20:19;

33:17;64:9;65:23;145:9;

157:22;163:20;173:7

top (4) 50:15;108:11;174:16;

176:3

topic (1) 153:12

Torcello (5) 3:7;112:2;118:5;

132:18;138:8

torch (1) 20:5

tossed (1) 12:12

towards (1) 9:8

transfer (1) 36:9

transferred (2) 35:20;36:8

transition (1) 155:4

treating (1) 57:21

treatments (1) 57:19

tried (5) 60:19;73:2;110:19;

111:11;173:11

true (3) 58:18;151:15;159:8

truth (2) 63:17;169:15

try (14) 5:4,6;29:12;49:15;

55:5;58:7;90:18;123:14;

138:18;142:20;154:19;

163:10,12;173:9

trying (23) 5:7;16:16;17:12;29:6;

30:14;52:5;62:10;89:9;

111:10;119:23;120:5;

138:21;140:21;141:11;

154:23;156:13;159:14;

164:18;167:4;173:10;

175:19;177:4,6

turn (1) 42:7

tutor (1) 49:17

tutored (1) 49:18

tutoring (30) 24:14,16;26:19;29:3,4,

14;31:4;33:4,17,20;34:1;

42:15;45:10,12,14;49:17,

23;50:22;51:6,12;52:8;

60:2;64:3,6;70:22;95:7;

129:12;140:22;143:11,12

TV (2) 78:3,9

twelve (6) 85:23;89:21;90:3;

146:18;147:4;149:21

twelve-month (1) 112:10

twenty (7) 87:20;89:18;90:9,10,

12,13,14

twenty-five (1)

90:2

twenty-two (1) 54:13

twice (1) 17:6

two (19) 3:15,16;4:20;6:20;

11:5,7;20:22;39:11;

50:21;52:7;101:22;

102:14,15;112:2;142:10,

13;144:1,2;175:5

two-year (1) 29:20

Tyler (5) 50:4;52:12,13;53:6;

141:6

type (5) 42:12,13;73:1;157:3;

170:17

typed (3) 50:17;53:21;153:23

types (3) 26:22;114:22;116:8

type-written (1) 50:14

typical (2) 7:20;80:5

U

ultimate (1) 63:22

Ultimately (2) 93:1;141:19

Um-hmm (50) 4:16;9:23;14:17;21:3;

22:7;25:12;27:6;28:23;

33:5;39:20;42:20;45:5,

15;47:17;48:2;50:16,20;

56:4,12;57:10;65:3;66:1;

69:13;76:16,20;77:4;

85:21;87:2;91:12;

101:17;104:9;108:22;

109:23;114:4,8;123:16;

126:1;140:23;144:22;

145:1;149:23;153:10;

159:9;168:16;169:2;

171:22;173:16,18;176:2,

17

unclear (5) 43:3;64:2;70:13;88:11;

162:23

undated (1) 50:14

under (7) 8:3;17:3;24:11;25:14,

14;58:22;91:19

underlying (1) 45:12

understood (2) 21:20;177:8

underwent (1) 7:20

unfair (1) 162:20

units (1) 142:10

Universal (4) 172:4;173:13;174:2,14

unless (1) 90:6

unrelated (1) 97:21

unusual (1) 106:3

up (34) 5:12;9:6;28:7;29:16;

34:7;41:9;43:9;51:20;

53:4;72:5;77:2;78:7;

79:2,15;82:23;83:2;

89:22;90:10,12,13,14;

93:4;114:5;122:9;

148:23;150:5;153:23;

154:5;155:3,5;163:21;

167:7;168:14;170:14

updates (1) 19:21

updating (1) 79:23

upon (2) 85:1;122:8

upstairs (1) 181:2

usage (1) 82:14

use (44) 14:15,16;20:11;22:20;

42:11;43:7;45:14;46:15;

47:4;67:15;73:20,22;

74:4,4;75:5,14;79:19;

83:14;96:12;98:18;99:11,

19;100:10;113:22;114:5,

6,10,12,15;115:18;116:9;

126:11;142:17;144:6,7,

11;146:15;147:3;151:8;

165:10,15,22;176:8,10

used (28) 4:9;14:10;29:14;64:21,

22,22;68:17;75:9,10,12;

90:19,20;91:5;115:21;

116:7;118:22;126:22;

144:8;145:15,18,20,21,

22;151:6;176:12,14,18,

22

using (31) 19:9;23:9;43:6;46:12;

47:11;66:9;71:19;75:17,

22;83:16,17;101:7;

121:19;144:13,15;145:2,

14,23;148:19,22;149:8;

150:16;152:9;155:13,17;

159:16;160:5;162:10;

163:13;164:17;176:6

usually (2) 108:6;175:18

utilities (1)

162:4

utility (1) 154:7

utilizing (1) 94:22

V

vacant (1) 92:21

valuable (1) 150:23

value (2) 58:16;59:5

variety (1) 57:7

various (1) 136:9

varying (1) 144:1

V-A-S-H-I-S (1) 26:20

Vashi's (1) 26:19

vender (12) 22:1,2;43:10;83:3;

87:5;100:21;101:10;

108:7;158:12,13;175:1,

18

venders (4) 23:9;143:14;158:15;

173:4

via (2) 6:15;53:12

Vice-President (1) 27:11

violation (2) 117:17,19

Virginia (1) 13:23

volunteer (1) 28:15

W

Wagaman (2) 137:17,18

W-A-G-A-M-A-N (1) 137:17

Wait (4) 74:3,10;105:13;107:6

waited (2) 106:18;107:5

walk (1) 142:14

walking (2) 109:7,11

wants (1) 78:16

way (30) 13:23;17:15;19:11;

26:9;40:13;45:16;46:11;

48:15;52:4;55:5;60:12;


(14) three - way



64:14;67:7;73:4;89:13;

91:2;93:21;94:2;103:2;

104:12;109:19;121:1;

122:6;129:13;139:10;

142:2;153:8;164:5;

165:14;180:8

weak (1) 93:10

week (4) 94:14;156:15;163:4,12

weekly (2) 5:22;101:11

weeks (1) 57:23

weren't (10) 11:1;15:15,17;21:16;

61:2,5;89:3,6;93:14;

126:2

Western (1) 35:1

What's (14) 18:8;29:18;56:7;76:17;

77:2,5,7;84:22;87:11;

112:23;134:3;137:15;

171:8;173:13

whenever (5) 108:20;136:7;146:3,4,5

Whereupon (21) 48:4;53:21;54:1;76:3,

7;79:6;80:9;86:10;96:19;

98:1;104:1;141:23;

152:15,18,22;167:13;

171:3;174:21;175:1;

177:19;179:12

wherever (2) 33:1;136:20

whole (3) 77:1;145:18;165:3

whomever (2) 31:16;115:18

whose (1) 171:20

Wilkes (1) 157:15

W-I-L-K-E-S (1) 157:15

Williams (33) 6:8;7:10,11;34:7;

35:12;36:12;37:4;39:9,

12;40:7;95:10;99:23;

100:18,22;101:20;

104:18,21;105:1,8,17,20;

106:1,3,7,11;108:23;

109:8;118:18,20;170:12,

13;179:18;180:18

wish (1) 31:5

within (5) 7:15,22;12:18;16:10;

108:15

without (2) 13:20;23:10

WITNESS (17)

17:23;31:11;79:9;86:7;

98:10;99:2,13,22;103:10;

107:23;110:5;112:5;

118:7;133:16;139:16;

141:6;147:9

WNED (1) 117:9

women (2) 26:19,20

word (2) 126:3;176:13

words (4) 7:21;21:23;24:23;

172:20

work (72) 7:23;8:1;9:18;10:14;

11:12;12:4;13:11;14:22;

15:1,3;16:17;17:13;

18:18;26:1,7;27:19;30:5,

8;35:15;39:14,18,21;

41:7,9,15,16;48:17;49:9;

52:11;56:9;67:11;68:1,

17;70:22;71:22;83:22;

87:13;92:19;96:6;

102:12;106:15,16;115:5;

116:11;117:4,7;125:14;

126:11,15;130:22,23;

135:23;136:12;140:21;

156:21;157:4,5,12;158:8,

15,17;167:9,22;168:1,5,

17,19;172:2;174:6,7,14;

176:16

worked (1) 120:15

worker (1) 28:12

working (28) 6:3;12:22;13:5;16:15;

19:22;24:20;28:4;48:7;

49:10,11,12,12,15;60:22,

22;92:5,15;102:13;

122:22;126:23;156:8,16;

160:4;168:2,15;169:16;

170:14;177:13

works (2) 3:7;156:7

world (1) 83:4

worried (3) 170:18,20,21

worry (2) 170:22,23

Wright (1) 27:17

write (1) 153:15

writing (4) 148:2;153:12,21,22

written (2) 9:15;148:7

wrong (4) 140:3,4;171:17;172:6

wrote (5)

142:20,21;154:5;

158:5;160:10

Y

Yaeger (2) 18:7,11

Y-A-E-G-E-R (1) 18:7

Yeager (7) 20:8,17,19;21:15;

73:18,22;74:10

year (7) 97:11;112:8,12,15;

154:10,11;162:13

years (13) 4:20;28:14;32:11;

36:17,19,21,21;37:11;

38:4;55:1;103:14,14;

124:18

York (8) 3:2;4:18;10:5,10;14:2;

24:11;27:4;35:1

Yup (13) 23:23;31:22;34:9;38:4;

50:13;75:7;94:17;97:7;

131:20;149:1,9;150:6;

163:3

Z

Zimicki (1) 157:17

1

1 (38) 9:14,18;10:14;11:3,9,

12;12:2;13:19;14:19,21;

15:10,21;16:17;18:20;

19:13;21:4,8;54:23;

66:15;74:17,18;89:1;

112:8,12,15;115:3,21;

116:5,6,19;117:14,20;

149:2;164:8;166:5,6,21;

169:1

10 (1) 136:6

11 (1) 6:6

14304 (1) 3:2

18th (2) 36:10;60:11

1990s (1) 38:22

2

2:07 (1) 181:8

2000 (1) 38:23

2000-2001 (1) 26:16

2000s (1) 38:22

2001 (1) 26:9

2002 (1) 28:7

2003 (1) 124:22

2005 (5) 46:1;143:9;146:3,21;

147:1

2005-2008 (1) 142:21

2006 (1) 46:1

2007 (6) 24:9,9;29:6,16;33:3;

46:1

2007-2008 (1) 32:10

2008 (9) 29:16;30:1;33:4;57:4,

13;123:14,20;143:9;

144:23

2008-2009 (1) 41:8

2009 (21) 9:15,19;10:3,5,6,13;

11:20;49:13,13,21;54:23;

57:16;58:21;59:1,9;

143:4;145:8;148:23;

154:14;155:8;171:16

2010 (35) 5:14;6:15;16:2,3;19:4;

20:20,22;21:13;24:10;

32:5;36:10;60:11;70:15;

76:19;77:21;80:9,19;

86:11;91:4;97:8,10;

98:16,23;112:15;136:9;

152:15,19,22;155:1,6,8,8;

160:2;164:1;166:22

2011 (16) 6:4,7;7:8;97:12;99:1,2,

9;100:12,14;112:8,12,16;

127:23;136:5;152:23;

166:22

2012 (1) 112:9

21 (1) 99:9

226 (2) 135:9,15

22nd (1) 5:14

2489 (2) 3:1;4:18

26th (1) 80:19

2925 (26) 32:14,15;33:2,18;

42:19,23;51:5;68:3;

140:1;142:7,22;144:5,20;

145:3,11;146:15;148:18;

149:14,18;151:16,21;

152:10;162:23;163:13;

165:10;177:14

3

3/22/2010 (1) 163:20

30 (2) 112:9,16

31 (1) 166:22

33 (3) 31:19;32:13,20

4

440-7749 (1) 56:8

5

52 (7) 132:13,22;133:2,17;

134:1;135:16,16

6

64 (14) 14:8,12,13,14,18,20;

15:10,22;21:1;65:11;

73:20,22;74:12;98:15

7

75 (48) 9:8;19:7,9;20:8,10,11;

21:6,6,10;36:10;39:19;

40:1;41:2,9;42:2,4;43:21;

46:10;48:16,21;49:5;

51:13;64:7,12,15;68:2,

13,20;69:5;73:8;74:7;

77:9,23;78:11;91:4;96:4;

99:12;108:13;140:1,8;

143:1;144:12,13;149:13;

164:17;165:7,20;166:10

8

8/19/10 (1) 87:1

816-3966 (1) 56:9


(15) weak - 816-3966

Documents

Transcript of investigator's interview with Debbie Buckley