Ca-00412 Case

IN THE CIRCUIT COURT FOR THE SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA

RENE ROMO, ET AL. CASE NO.: 2012-CA-00412 PLAINTIFFS, VS.

KEN DETZNER AND PAM BONDI,

DEFENDANTS.

THE LEAGUE OF WOMEN VOTERS OF FLORIDA, ET AL., CASE NO.: 2012-CA-00490 PLAINTIFFS, VS.

KEN DETZNER, ET AL.,

DEFENDANTS.

COALITION PLAINTIFFS’ OPPOSITION TO NON-PARTIES’ MOTIONS FOR PROTECTIVE ORDER

The Coalition Plaintiffs respectfully request this Court deny the Motion for Protective

Order of Data Targeting, Inc., Pat Bainter, Matt Mitchell, and Michael Sheehan (together “Data

Targeting”), and the Amended Motion for Protective Order of Frank Terraferma (“Terraferma”),

as deficient efforts to delay and avoid proper discovery.

I. INTRODUCTION

These motions for protective order are the latest act in a play that has gone on far too long. Even putting aside the contemptuous conduct of Data Targeting – which is being addressed separately – the core issues raised by these motions have already been analyzed and rejected multiple times by this Court, and now also by the First District Court of Appeal.1 It is

1 The First District’s Order denying Data Targeting’s petition for writ of certiorari is attached as Exhibit A. Romo, et al. v. Detzner, et al.

now beyond dispute in this case that the requested documents are relevant, and that production of

those documents will not cause irreparable harm. There is simply nothing left to argue and the

documents should be produced forthwith.

Ironically, in this latest round of motions, Data Targeting and Terraferma attempt to

drape themselves in the Constitution as a basis for refusing to produce their responsive

documents. Their associational privilege, privacy and trade secret claims are entirely unfounded.

But we suspect they already know this.

First, this is nothing like cases where activist groups have shown discovery likely would

squelch lawful association. Data Targeting and Terraferma, as well as other like-minded

political consultants (collectively, “Political Operatives”), are in the lucrative business of ensuring that Republican candidates prevail in elections. They are political insiders, well known and well paid for promoting Republican causes, and enjoy close access and influence among

Republican legislators and staff. They cannot show the discovery sought would discourage

lawful efforts to petition the government. To the contrary, it is evident their secret work aided

the Legislature in analyzing and preparing redistricting plans to secure partisan favoritism in

violation of the Florida Constitution. To argue that this improper conduct should be protected

from discovery under the associational privilege is absurd on its face.

Second, their claim of privacy is no basis to preclude relevant discovery in civil litigation.

The requested discovery is the most practical, and to date the only, means to discern the extent to

which the Political Operatives’ secret work with legislative insiders injected partisan intent into the legislative redistricting process.

Third, trade secret protection is inapplicable where, as here, the party seeking discovery

is not a business competitor. Moreover, the information sought is not secret and does not relate to any formula, process, device or other business information that is kept confidential to maintain

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an advantage over competitors. In fact, the information at issue here was actually shared with

other consultants who are Data Targeting’s competitors. It is also evident that the Political

Operatives’ work entailed analyses of law and data compiled from government information,

which the law does not consider trade secrets. Data Targeting’s trade secret claims, accordingly,

provide no basis to avoid discovery. And in the end, Data Targeting has waived its privilege

claims due to its contemptuous refusal to obey this Court’s discovery orders.

II. BACKGROUND

On November 2, 2010, voters approved Amendments 5 and 6 (codified as article III,

sections 20 and 21) of the Florida Constitution, which set strict mandates on the Legislature’s

redistricting plans. Among the mandates are that “(1) no apportionment plan or district shall be

drawn with the intent to favor of disfavor a political party or an incumbent.” art. III, § 20.

Accordingly, whether a redistricting plan is constitutional depends on if the Legislature prepared

or adopted the plan with intent to favor (or disfavor) a political party or an incumbent. Critical to

uncovering that issue is discovery into the involvement, activities, and communications of

political insiders who took part in internal legislative efforts related to the Legislature’s

redistricting plans.

Data Targeting claims it is part of an “Association” with Terraferma, Marc Reichelderfer,

Richard Heffley, and other Republican operatives, who worked together in “formulating a

strategy for a particular outcome” in the redistricting process. (See Data Targeting’s Motion for

Protective Order (“MPO”) at 12); (Data Targeting’s Amended Privilege Log at n.1) (identifying

members of alleged “Association”). Data Targeting acknowledges “the potential relevance and

value of a document provided to the Legislature or its staff for purposes of commenting on or contributing to the redistricting process,” and claims to have produced all such documents. (See

Data Targeting MPO at 19). Yet it has withheld, as privileged and irrelevant, 1833 pages of

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“internal deliberations” of its self-declared “Association,” admittedly prepared “for or in relation to the Legislature’s redistricting actions.” (See id. at 12, 20). Terraferma has taken much the

same position refusing to produce an undisclosed number of documents, but without going so far

as to claim trade secret protection over his efforts.

Limited discovery in this case reveals that key legislative staff including Alex Kelly

(Staff Director of the House Redistricting Committee)2 and Chris Clark (staff member of Senator

Gaetz, Chair of the Senate Redistricting Committee) privately met with Republican consultants, including the Political Operatives, to “brainstorm” about redistricting in early December 2010.

See Exhibit 2 to Reichelderfer Dep. (attached hereto as Exhibit B). For instance, Reichelderfer confirmed in his deposition that Rich Heffley called, among others, Alex Kelly, Chris Clark,

Reichelderfer, Terraferma, and Bainter (Data Targeting’s President) to a meeting on December

3, 2010 at the offices of the Republican Party of Florida, about which Reichelderfer gave the following testimony:

Q: Tell me what you remember about that meeting.

A: There was a specific conversation about going forward on the redistricting process on the issue of privilege, and what conversations would or would not be privileged, and how that would work. I think there was some discussion generally about that. And then there was going to be a follow-up on kind of, I think there were a list of questions. That is the one that sticks out.

* * *

Q: Right. You wanted to be able to participate in the process, you consultants, but you didn’t want anybody to know what you were saying or doing, right?

2 In its interrogatory answers, the House described Mr. Kelly’s role in redistricting as “the staff director responsible for managing the staff, coordinating the public hearings, presenting proposals to the committee, interacting with the public, creating proposals, interacting with Senate staff, and related tasks.” See House’s Responses and Objections to LOWV Plaintiffs’ First Request for Production of Documents and Interrogatories dated July 27, 2012. Notably absent from the House’s description is any mention of Mr. Kelly’s interaction with the Political Operatives.

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A: I suppose that would be a fair representation.

(Reichelderfer Dep. at 64:20-23; 77:12-20; 89:5-9) (emphasis added).3

Reichelderfer’s testimony also uncovered that a key legislative staffer, Kirk Pepper, aide

to then Speaker of the House Dean Cannon, provided Reichelderfer (and apparently others,

including Heffley) with seven versions of the Legislature’s draft congressional redistricting maps weeks before they were made public, and asked for and received Reichelderfer’s and Heffley’s

political advice and input:

Q: So your friend, Mr. Kirk Pepper, evidently sent you those seven maps something like two weeks before the general public ever saw them, right?

A: According to these documents.

* * *

Q: And you got them for a reason, isn’t that right?

A: I assume it was for a reason.

* * *

Q: Well, you could determine how these maps performed, right –

A: I could.

Q: -- politically?

A: I could have done that, yes, sir.

* * *

Q: So you are being exposed to a discussion about how the congressional plan is being formed, right?

A: Appears to be, yes, sir.

Q: But I thought that was something you weren’t supposed to be involved with?

3 A copy of the Reichelderfer deposition transcript is attached as Exhibit C.

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A: I don’t know. The e-mail says that I am.

* * *

Q: Okay. Then I show you, sir, Exhibit 33 in the chain. And Dean Cannon responds back to what you wrote on November 27, 2011, to both you and Mr. Pepper, right?

A: Yes, sir.

Q: And Mr. Reichelderfer, what he says is, quote, “Well as long as the Senate accommodates the concerns that you and Rich [Heffley] identified in the map that they put out tomorrow, then we are in fine shape. How confident are you that they are going to do that?” Is that what he said, sir?

A: Yes, sir.

Q: So evidently, you and Rich Heffley had identified in the maps that evidently the Senate was going to put out on the 28th some concerns, right?

A: Apparently, yes sir. * * *

Q: I mean, Dean Cannon was saying that if the Senate is okay with your concerns, your and Rich’s concerns, then we are going to be in fine shape.

A: That’s what the Speaker says there.

Q: And he was relying heavily on you and Mr. Heffley, Republican political consultants, to look over these maps carefully and advise him about what he ought to do, right?

A: I don’t know that I agree with that.

Q: Well, you had been advising him about what he ought to do, isn’t that right?

A: Correct, yes, sir.

Q: You had advised him about what your and Rich’s concerns about the maps were, isn’t that right?

A: That’s what the e-mail says, yes, sir.

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(Reichelderfer Dep. at 164:22-165:1; 168:15-17; 169:12-16; 178:5-11; 191:24-192:14; 193:16-

194:5) (emphasis added) (objections omitted).

The fodder for such conversations about the Legislature’s redistricting plans likely came from what Data Targeting has dubbed “internal deliberations” of its self-declared “Association.”

Reichelderfer admits sharing information with the Political Operatives about how proposed districts would perform politically. (Reichelderfer Dep. at 69:19-70-18). The Political

Operatives, however, cannot be relied upon to recount the particulars of all such matters.

Terraferma, for instance, admits exchanging redistricting maps and performance data with

Heffley, Bainter, Reichelderfer, and others, but not knowing their purpose; and he has denied even knowing what his own written comments on such matters mean. (See, e.g., Exhibit B;

Terraferma Dep. at 147:4-13, 205:15-208:8, 220:19-221:18; 229:22-230:17).4

III. LEGAL ANALYSIS

The scope of discovery encompasses virtually all information that “appears reasonably calculated to lead to the discovery of admissible evidence.” Fla. R. Civ. P. 1.280(b)(1). This follows from a “fundamental maxim” of the common law “that the public has the right to every man’s evidence.” Guerrier v. State, 811 So. 2d 852, 855 (Fla. 5th DCA 2002). Exceptions are few and narrow; Florida recognizes only a few exclusive statutory and constitutional privileges, and federal law recognizes privileges only when a “public good transcend[s] the normally predominant principal of utilizing all rational means for ascertaining the truth.” Id.

In light of these principals, the Political Operatives have failed to meet their burden to show good cause for a protective order. They have failed to show that the requested discovery would unconstitutionally diminish associational rights. Privacy rights yield where, as here, the

4 A copy of the Terraferma deposition transcript is attached as Exhibit D.

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information sought fits the scope of proper discovery. Data Targeting’s trade secret claims also

provide no basis to prevent disclosure of, much less to withhold, underlying facts relevant to the

2012 redistricting process.

A. THE POLITICAL OPERATIVES HAVE NOT AND CANNOT ESTABLISH ASSOCIATIONAL PRIVILEGE RIGHTS.

A person asserting associational privilege “must demonstrate an objectively reasonable

probability that compelled disclosure will chill associational rights, i.e. that disclosure will deter

membership due to fears of threats, harassment or reprisal from either government officials or

private parties which may affect members’ physical well-being, political activities, or economic

interests.” In re Motor Fuel Temp. Sales Practices Lit., 707 F. Supp. 2d 1145, 1152 (D. Kan.

2010) (citing collected federal and state cases). If, and only if, the proponent meets that burden,

the party seeking discovery must show a compelling need for the requested information. Id.

1. The Political Operatives’ Improper Conduct Is Not Protected Under The Associational Privilege.

It is farcical to suggest the associational privilege protects from discovery the Political

Operatives’ secretive efforts to assist the Legislature in circumventing the Florida Constitution.

Cases where associational privilege has been upheld against discovery involve lawful campaigns,

not conspiracies designed to thwart the will of the voters. See, e.g., Perry v. Schwarzenegger,

591 F.3d 1147 (9th Cir. 2009) (involving citizen association’s ballot initiative to enact

constitutional amendment defining marriage); NAACP v. Alabama, 357 U.S. 449 (1958)

(involving early civil rights campaigns in Alabama soon after desegregation).

There is no lawful public petitioning activity at issue here. As highly paid mercenaries, the Political Operatives are the last group to which an associational privilege should apply. The privilege is intended to protect citizens who petition their government for change, not those who earn their living by advancing the political agendas of paying clients. At best, the Political

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Operatives are attempting to shield from public disclosure “political shenanigans” and, at worst, constitutionally outlawed conduct. Either way, this is not the type of conduct the privilege protects. Here, the Political Operatives seek to turn the privilege on its head by applying it to conduct that circumvents the constitutional prohibition against gerrymandering. No court has ever applied the privilege to such improper activity.

2. The Political Consultants Have Presented No More Than Self-Serving Subjective Claims That Do Not Satisfy Their Prima Facie Evidentiary Burden.

Terraferma offers no evidence, and Data Targeting’s President Bainter has merely offered a self-serving claim that “it would have to seriously reconsider its decision to participate in the legislative process for fear of threats, harassment, or reprisals.” (See Bainter Aff. ¶ 4). That claim is belied by the fact Data Targeting is a political consulting firm that is entrenched with the

Republican Party (one of its largest clients), and that was paid almost $3 million from the

Republican Party for political activities from January 2011 through November 2012. (Bainter

Dep. at 65:4-7; 66:21-67:8). Data Targeting is not likely to withdraw from the political process – its very means of making a living – and it certainly has not shown any objective threat of public hostility so extreme (particularly over the redistricting issue) as to cause similar political operatives to forego legitimate legislative political activities. The Court should therefore deny the Political Operatives’ associational privilege claims as unfounded.

3. Public Interests Overcome The Political Operatives’ Alleged Interest.

Moreover, the Political Operatives’ claims are no match for the compelling public interest in enforcing the Florida Constitution’s redistricting mandates. As this Court has already noted:

I find it difficult to imagine a more compelling, competing government interest… represented by the [Coalition] [P]laintiffs’ claim[, which is]… based upon a specific constitutional direction to the Legislature, as to what it can and cannot do with respect to drafting legislative reapportionment plans.

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Order Granting in Par and Denying in Part Motion for Protective Order dated October 3, 2012 at

5-6; see also, In re Apportionment Law – 2012, 83 So. 3d 597, 600 (Fla. 2012) (“the right to elect

representatives – and the process by which we do so – is the very bedrock of our democracy”).

Moreover, the Florida Supreme Court has recently found that the addition of article III, sections

20 and 21 established that “the framers and voters clearly desired more judicial scrutiny [of the

redistricting process], not less.” Florida House of Representatives v. League of Women Voters, et al., 2013 WL 3466819, at *6 (Fla. Jul. 11, 2013).

Even upon a prima facie showing, associational privilege must yield when a balance of the following factors favors disclosure: (a) the relevance of the information sought; (b) plaintiffs’ need for the information; (c) whether the information is available from other sources; (d) the nature of the information sought; and (e) whether the proponent of the privilege has placed the information into issue. See In re Motor Fuel, 707 F. Supp. 2d at 1160-61. Each of these factors must be evaluated in light of the compelling governmental interest at issue in this case.

a. The information sought is particularly relevant.

The Florida Constitution mandates that legislative redistricting plans not be prepared or adopted with intent to favor any political party, and evidence shows that legislative leaders and staff secretly sought and deferred to input from the Political Operatives in preparing or adopting redistricting plans. For example, in an email, Speaker of House Dean Cannon writes that “… as long as the Senate accommodates the concerns that you [Reichelderfer] and Rich [Heffley] identified in the map that they put out tomorrow, then we are in fine shape.” See Exhibit E

[Reichelderfer 33]. Evidence of such behind-the-scenes, partisan efforts is particularly relevant to discerning the extent to which the Legislature’s redistricting plans were imbued with partisan favoritism.

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b. The information sought is needed.

Need is established because the information sought bears on the central issue in the case

– the Legislature’s intent. The requested discovery is necessary to determine the extent to which

the Political Operatives’ partisan efforts factored into the Legislature’s redistricting plans. The information may, in whole or part, establish their claims that the Legislature violated the Florida

Constitution’s redistricting mandates.

c. The information sought is not available from alternative sources.

Legislators and their staff are the only other sources from whom the Coalition Plaintiffs might discern the extent to which the Political Operatives’ partisan efforts factored into the

Legislature’s redistricting plans. But until the Florida Supreme Court rules otherwise, the

Coalition Plaintiffs cannot compel such information from the legislators or their staff, and it may be insufficient in any event, as the legislators and their staff apparently preferred to communicate orally about sensitive issues. (See, e.g., Reichelderfer Dep. at 116:7-12) (discussing email about seemingly non-controversial redistricting issues in which senate staffer says, “I think [draft document] is getting into some pretty specific and sensitive issues that may not be good to be in writing”). The substance of the Political Operatives’ partisan input must, therefore, be derived from the source – that is, internal written communications and draft analyses residing in the files of individuals who were part of Data Targeting’s self-described “Association.”

d. The nature of the information sought is not legitimate petitioning.

The Florida Constitution’s redistricting mandate provides zero tolerance for partisan intent. In re Apportionment Law – 2012, 83 So. 3d at 617 (finding, under new Amendments,

“there is no acceptable level of improper intent”). So, in secretly working with the Legislature or its staff throughout the redistricting process, the Political Operatives worked up analyses for legislators and staff whose very constitutional duty was to avoid partisan or incumbent

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favoritism and to avoid secretly engaging such partisan political insiders in the redistricting

process to ensure politically favorable redistricting plans. The surreptitiousness of the effort, particularly while legislative leaders staged a public charade of transparency, highlights the illegitimacy of such behind-the-scenes shenanigans. Further, the Political Operatives’ claim that

portions of analyses remained entirely internal is immaterial, as that would satisfy only a single

factor in a broader test favoring compelled disclosure. See In re Motor Fuel Temp., 707 F. Supp.

2d at 1163 & n.25 (finding factor was satisfied but insufficient to withhold internal matters).

e. The Political Operatives placed their activities and communications at issue.

The Political Operatives opened themselves to scrutiny by secretly meeting with and aiding legislators and staff in the 2012 redistricting process. They surely anticipated legal scrutiny. In fact, Bainter considered the matter highly susceptible to litigation, however the process turned out (Bainter Dep. at 41:12-14); and Reichelderfer specifically recounted privilege being raised as a concern in an early meeting with legislative insiders on December 3, 2010, after which House lawyers advised that communications with legislative insiders would be discoverable (Reichelderfer Dep. at 64:20-23; 77:12-20, 90:15-23). By exposing their thoughts or analyses to legislators, staff, or others in contact with legislators or staff, the Political

Operatives placed into issue the information sought – particularly in light of the mandate against political favoritism and the prospect of legal challenges to the legislature’s redistricting plans.

The overall balance of factors thus decisively favors disclosure of the information sought.

The Political Operatives, after all, have not made the prima facie showing required for associational privilege in the first instance, and when the mitigating factors are considered disclosure must be compelled. Accordingly, the Court should reject the Political Operatives’ associational privilege claims, and compel production of the information sought.

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B. PRIVACY DOES NOT PRECLUDE THE DISCOVERY SOUGHT IN THIS CASE.

The Political Operatives’ privacy claims likewise present no impediment to discovery.

The right to privacy begins where the broad scope of permissible discovery ends in civil litigation. See Friedman v. Heart Inst. of Port St. Lucie, Inc., 863 So. 2d 189, 193-94 (Fla.

2003). The discovery rules provide a framework bounded only by the broad concept of

relevance, and certain safeguards against undue burden, etc., subject to trial court’s discretion.

Id. So, for instance, sensitive personal financial information is “fully discoverable” when such

“materials sought by a party ‘would appear to be relevant to the subject matter of the pending

action.’” Id. at 194. In that regard, “trial courts are guided by the principals of relevancy and practicality.” Id.

As previously discussed, it is evident that the Political Operatives secretly worked with

legislators and staff, who sought and apparently relied on their partisan analyses. The only

currently available means to discern the extent to which such efforts affected the Legislature’s

redistricting plans is to compare events in the 2012 redistricting process to the voluminous

materials the Political Operatives have withheld and described as “analyses … of legislative or

congressional district boundaries” and “internal deliberations” prepared “for or in relation to the

Legislature’s redistricting actions.” (See Data Targeting MPO at 12, 21). The information

sought from the Political Operatives, therefore, fits the proper scope of discovery, and their

claims of privacy present no impediment.

C. TRADE SECRET CLAIMS PROVIDE NO BASES TO WITHHOLD DISCOVERY, AND THERE IS NO BASIS TO PREVENT DISCLOSURE OF THE MATTERS WITHHELD.

Data Targeting’s last-ditch attempt to avoid discovery is to characterize its work as trade

secrets. Data Targeting fundamentally misses the point, however, that “internal deliberations” or

“analyses … of legislative and congressional district boundaries” as to the 2012 legislative

Romo, et al. v. Detzner, et al. redistricting process are not considered to have ongoing use or value in business operations, nor does trade secret protection offer a complete bar to discovery.

Contrary to Data Targeting’s expansive notion of trade secrets, “[n]ot all business information falls within the privilege afforded to a trade secret.” Summitbridge Nat. Invests.

LLC v. 1221 Palm Harbor LLC., 67 So. 3d 448, 450 (Fla. 2d DCA 2011). The Second District continued:

[Trade secret] differs from other secret information in a business ... in that it is not simply information as to single or ephemeral events in the conduct of the business, as, for example, the amount or other terms of a secret bid for a contract or the salary of certain employees, or the security investments made or contemplated, or the date fixed for the announcement of a new policy or for bringing out a new model or the like. A trade secret is a process or device for continuous use in the operation of the business.

Id. (emphasis added and citation omitted). The premise for trade secret protection is “to prohibit a party to a suit from obtaining valuable information that could be used to its own [business] advantage.” Freedom Newspapers Inc. v. Egly, 507 So. 2d 1180, 1184 (Fla. 2d DCA 1987).

At issue, here, is a past event (the 2012 redistricting process) the underlying facts of which will be different the next time redistricting occurs. The Coalition Plaintiffs do not compete in Data Targeting’s business; and, rather than being focused on business techniques, the

Coalition Plaintiffs are concerned with map permutations, the existence of improper intent, and the resulting effect of Data Targeting’s work in the 2012 redistricting process. In sum, Data

Targeting has failed to establish that the discovery sought warrants trade secret protection. See

Summitbridge, 67 So. 3d at 450 (finding underlying fact about a single past transaction is not a trade secret); Freedom Newspapers, 507 So. 2d at 1184 (finding no compelling basis for trade secret protection where non-competitor’s discovery was focused on underlying facts).

Furthermore, Data Targeting is mistaken to the extent it claims any proprietary interest in electoral redistricting data or analysis of legal compliance. Bainter admits Data Targeting gets

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its electoral data from publically available sources. (See Bainter Dep. at 46:3-24, 47:8-25; 49:2-

6; 49:8-19) (testifying that Data Targeting primarily uses voter registration files, political-

district-of-residence information maintained by the State, election data from the State Division of

elections, and “online” electoral performance data from the State House). 5 A self-professed

methodology presenting and interpreting public laws or “data compiled from government

information generally available to the public” does not constitute a trade secret, because such

matters are considered “readily ascertainable by proper means.” See Health Care Mgmt.

Consulting v. McCombes, 661 So. 2d 1223, 1226 (Fla. 1st DCA 1995) (finding proponent’s self-

professed confidential methodology of interpreting Medicare regulations to clients does not

constitute trade secret, as it regarded public laws and data compiled from government

information). Thus, for these and the foregoing reasons, the Court should reject Data Targeting’s

trade secret claims.

D. DATA TARGETING’S CLAIMS SHOULD BE REJECTED AS WAIVED.

Finally, there is a practical reason to compel disclosure of the requested discovery, aside from the evident legal deficiency of Data Targeting’s claims -- Data Targeting has contemptuously refused to comply with this Court’s discovery orders.

Most recently, the Court entered a May 31, 2013 order (the “Order”), requiring Data

Targeting to produce a privilege log in the following manner:

The log shall identify each document by type, who prepared the document, with whom each document was shared, and, for each document, the log shall specify the alleged privilege or basis for confidentiality. The log shall be served on Coalition Plaintiffs' counsel simultaneously with its delivery to the Court.

5 Bainter could not recall any other data that Data Targeting has; he left open the possibility “We may” have performance data; but he said “it would be pretty spotty,” if there was any. (See id. 48:1-3; 49:25). In addition, as to what the data would cover, Bainter testified: “I don’t know. If I have it, it’s some kind of special request from somebody somewhere, maybe years gone by.” (Id. 50:1-5). Such information surely was not a central or meaningful basis for Data Targeting’s analyses, as Bainter would surely have known if had been.

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(Order at 2, § 1.b.). In that regard, the Court was well within its discretion. See Alterra

Healthcare Corp. v. Estate of Shelley, 827 So. 2d 936, 947 (Fla. 2002) (finding it appropriate to

require a custodian of non-party records to provide the requesting party with a log detailing

information withheld based on privacy, so as “to enable the parties to fully address the issue at

the trial level and to challenge the court’s ruling, if necessary”).

Rather than comply with the Court’s Order, however, Data Targeting delayed, and then

ultimately produced a worthless log, which merely divided 1833 pages of withheld materials into

62 bates ranges, all alleged to be trade secrets, and labeled with compound descriptions

suggesting further divisions are possible. See Amended Log, Exhibit F hereto. Only one entry references a document type or date (albeit without specificity) – that is, “Correspondence in

February of 2012.” (Id. at 4). Instead of specifying each document’s type, date, author, and recipient(s), and how each document or discrete subpart constitutes a trade secret or other protected matter, the log references underlying events, maps, data, and other facts, using labels such as “[i]nformation, ideas, opinions …,” that are meaninglessly abstract.

Data Targeting has been given numerous opportunities to establish its privilege claims

and obviously has no interest in enabling any meaningful review of its claims, as the Court

ordered. This cat-and-mouse game has gone on long enough, as the foregoing legal analysis

confirms. The Court should reject Data Targeting’s claims as legally deficient, and because Data

Targeting has contemptuously abused the legal process as a practical matter.

IV. CONCLUSION

The Political Operatives have failed to establish a prima facie associational rights claim,

and relevant factors would favor compelled disclosure in any event. Their privacy claims are likewise unavailing as the requested discovery is currently the only means to discern whether

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their secret work with the Legislature injected partisan intent into the 2012 redistricting process.

Trade secret protection does not apply to the underlying factual information sought, and Data

Targeting’s analyses of legal issues and government data are not legally considered trade secrets.

Data Targeting has also contemptuously failed to detail and permit meaningful review of its privilege claims. The Political Operatives’ Motions for Protective Order should therefore be denied, and the requested discovery should be compelled.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 20, 2013 I filed the foregoing using the State of Florida ePortal Filing System. I further certify that a copy of the foregoing has been served via email on all counsel of record listed on the Service List below.

/s/ Adam M. Schachter Gerald E. Greenberg Florida Bar No.: 440094 [email protected] Adam M. Schachter Florida Bar No.: 647101 [email protected] GELBER SCHACHTER & GREENBERG, P.A. 1441 Brickell Avenue, Suite 1420 Miami, FL 33131 Telephone: (305) 728-0950 Facsimile: (305) 728-0951

and

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David B. King Florida Bar No.: 0093426 Thomas A. Zehnder Florida Bar No.: 0063274 Frederick S. Wermuth Florida Bar No.: 0184111 KING, BLACKWELL, ZEHNDER & WERMUTH, P.A. P.O. Box 1631 Orlando, FL 32802-1631 Telephone: (407) 422-2472 Facsimile: (407) 648-0161 [email protected] (Primary) [email protected] (Primary) [email protected] (Primary) [email protected] (Secondary) [email protected] (Secondary)

Counsel for the Coalition Plaintiffs

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SERVICE LIST

Ronald G. Meyer Michael B. DeSanctis Lynn Hearn Jessica Ring Amunson MEYER, BROOKS, DEMMA and BLOHM, P.A. Paul Smith 131 North Gadsden Street JENNER & BLOCK, LLP Post Office Box 1547 1099 New York Ave NW, Suite 900 Tallahassee, FL 32302 Washington, DC 20001 [email protected] [email protected] [email protected] [email protected] [email protected] J. Gerald Hebert 191 Somervelle Street, #415 Counsel for Coalition Plaintiffs Alexandria, VA 22304 [email protected]

Counsel for Coalition Plaintiffs J. Andrew Atkinson Blaine Winship Ashley Davis Timothy D. Osterhaus General Counsel Office of the Attorney General of Florida Florida Department of State The Capitol, Suite PL-01 R.A. Gray Building Tallahassee, FL 32399-1050 500 S. Bronough Street [email protected] Tallahassee, FL 32399

Counsel for the Attorney General [email protected] [email protected] [email protected] [email protected]

Counsel for Florida Secretary of State

George T. Levesque Charles T. Wells General Counsel George N. Meros, Jr. THE FLORIDA SENATE Jason L. Unger 404 South Monroe Street, Suite 409 Andy Bardos Tallahassee, Florida 32399 GrayRobinson, P.A. [email protected] P.O. Box 11189 (32302) [email protected] 301 South Bronough Street, Suite 600 [email protected] Tallahassee, Florida 32301 [email protected] Michael A. Carvin [email protected] Louis K. Fisher [email protected] JONES DAY [email protected] 51 Louisiana Avenue N.W. [email protected] Washington, D.C. 20001 [email protected] [email protected] [email protected] [email protected]

Romo, et al. v. Detzner, et al.

Raoul G. Cantero Daniel Nordby Jason N. Zakia General Counsel Jesse L. Green Florida House of Representatives WHITE & CASE LLP 422 The Capitol Southeast Financial Center, Ste. 4900 Tallahassee, FL 32399-1300 200 South Biscayne Boulevard [email protected] Miami, FL 33131 [email protected] [email protected] [email protected] Miguel De Grandy [email protected] 800 Douglas Road [email protected] Coral Gables, FL 33134 [email protected] [email protected]

Counsel for the Florida Senate Counsel for Florida House of Representatives

Stephen Hogge Florida Bar No. 718238 STEPHEN HOGGE ESQ., LLC 117 South Gadsden Street Tallahassee, Florida 32301 [email protected]

Charles G. Burr Jon L. Mills Florida Bar No. 0689416 Elan Nehleber BURR & SMITH, LLP BOIES, SCHILLER & FLEXNER, LLP Grand Central Place 100 S.E. 2nd Street, Suite 2800 442 W. Kennedy Blvd., Suite 300 Miami, FL 33131-2144 Tampa, FL 33606 [email protected] [email protected] [email protected] [email protected] Allison J. Riggs, Admitted Pro Hac Vice Anita S. Earls Karen C. Dyer SOUTHERN COALITION FOR SOCIAL JUSTICE BOIES, SCHILLER & FLEXNER, LLP 1415 W. Highway 54, Suite 101 121 South Orange Ave., Suite 840 Durham, NC 27707 Orlando, FL 32801 [email protected] [email protected] [email protected]

John M. Devaney Victor L. Goode Mark Erik Elias Dorcas R. Gilmore PERKINS COIE, LLP NAACP 700 Thirteenth Street, NW, Suite 700 4805 Mt. Hope Drive Washington, D.C. 20005 Baltimore, MD 21215-3297 [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Counsel for Intervenor/Defendant, NAACP

Romo, et al. v. Detzner, et al.

Abha Khanna Harry O. Thomas Kevin J. Hamilton Christopher B. Lunny PERKINS COIE, LLP Radney, Thomas, Yon & Clark, PA 1201 Third Avenue, Suite 4800 301 South Bronough St., Ste. 200 Seattle, Washington 98101-3099 Tallahassee, FL 32301-1722 [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] Mark Herron, Esq. Robert J. Telfer III, Esq. Counsel for Intervenors/Defendants Negron, Angelina Perez, Esq. Suarez, Rodriguez, Pinder, Mathiri, Mount, Messer, Caparello & Self, P.A. Barnes, Butler, and Wise Post Office Box 1876 Tallahassee, FL 32302-1876 D. Kent Safriet [email protected] Thomas R. Philpot [email protected] HOPPING GREEN & SAMS, P.A. [email protected] P.O. Box 6526 [email protected] Tallahassee, Florida 32314 [email protected] Telephone: (850) 222-7500 [email protected] Facsimile: (850) 224-8551 [email protected] Counsel for Romo Plaintiffs [email protected]

David Healey, Esq. David Healey, Esq. 2846 Remington Green Cir #B 2846 Remington Green Cir #B Tallahassee, Florida 32308-3763 Tallahassee, Florida 32308-3763 [email protected] [email protected]

Daniel C. Brown, Esq. Counsel for Non-parties Pat Bainter, Matt Carlton Fields Mitchell, Michael Sheehan and Data 215 S. Monroe Street Targeting, Inc. Suite 500 Tallahassee, Florida 32301-1866 [email protected] [email protected]

Counsel for Non-party Frank Terraferma,

EXHIBIT A DATA TARGETING, INC., PAT IN THE DISTRICT COURT OF APPEAL BAINTER, MATT MITCHELL, FIRST DISTRICT, STATE OF FLORIDA AND MICHAEL SHEEHAN, Petitioner, NOT FINAL UNTIL TIME EXPIRES TO v. FILE MOTION FOR REHEARING AND DISPOSITION THEREOF IF FILED THE LEAGUE OF WOMEN VOTERS OF FLORIDA, CASE NO. 1D13-966 COMMON CAUSE FLORIDA, JOAN ERWIN, ROLAND SANCHEZ-MEDINA, JR., J. STEELE OLMSTEAD, CHARLES PETERS, OLIVER D. FINNIGAN, SERENA CATHERINA BALDACCHINO, DUDLEY BATES, RENE ROMO, BENJAMIN WEAVER, WILLIAM EVERETT WARINNER, JESSICA BARRETT, JUNE KEENER, RICHARD QUINN BOYLAN, BONITA AGAN, KENNETH W. DETZNER, IN HIS OFFICIAL CAPACITY AS FLORIDA SECRETARY OF STATE, THE FLORIDA SENATE, MICHAEL HARIDOPOLOS, IN HIS OFFICIAL CAPACITY AS PRESIDENT OF THE FLORIDA STATE SENATE; THE FLORIDA HOUSE OF REPRESENTATIVES, AND DEAN CANNON, IN HIS OFFICIAL CAPACITY AS SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES, AND PAM BONDI, IN HER OFFICIAL CAPACITY AS ATTORNEY GENERAL OF THE STATE OF FLORIDA, Respondents. 1 ______/

Opinion filed July 17, 2013.

Original Proceedings - Petition for Writ of Certiorari.

D. Kent Safriet and Thomas R. Philpot of Hopping Green & Sams, P.A., Tallahassee, for Petitioner.

Jon L. Mills, Andrew D. Manko, and Elan Nehleber of Boies, Schiller & Flexner, LLP. Miami; Karen C. Dyer of Boies, Schiller & Flexner, LLP, Orlando; Marc Erik Elias of Perkins Coie, LLP, Washington, D.C.; Mark Herron, Robert J. Telfer III and Angelina Perez of Messer, Caparello & Self, P.A., Tallahassee; Miguel De Grandy of Miguel De Grandy, P.A., Coral Gables; Daniel Nordby, Tallahassee; Charles T. Wells, George N. Meros, Jr., Jason L. Unger, and Andy Bardos of Gray Robinson, P.A., Tallahassee; Stephen Hogge of Stephen Hogge Esq., LLC, Tallahassee; Charles G. Burr of Burr & Smith, LLP, Tampa; Harry O. Thomas and Christopher B. Lunny of Radey, Thomas, Yon & Clark, P.A., Tallahassee; Gerald E. Greenberg, Adam M. Schachter of Gelber, Schachter & Greenberg, P.A., Miami; Blaine Winship and Timothy D. Osterhaus, Tallahassee; J. Andrew Atkinson and Ashley Davis, Tallahassee; George T. Levesque, Tallahassee; Raoul G. Cantero, Jason N. Zajia and Jesse L. Green of White & Case LLP, Miami; Ronald G. Meyer and Lynn Hearn of Meyer, Brooks, Demma & Blohm, P.A., Tallahassee; Daniel C. Brown of Carlton Fields, P.A., Tallahassee; David Healey, Tallahassee, for Respondents.

PER CURIAM.

DENIED.

VAN NORTWICK, WETHERELL, and MARSTILLER, JJ., CONCUR.

EXHIBIT B

EXHIBIT C 3 IN THE CIRCUIT COURT OF THE 1 A P P E A R A N C E S SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA 2 DAVID B. KING and THOMAS A. ZEHNDER, THE LEAGUE OF WOMEN VOTERS 3 Attorneys at Law, of the law offices of King, OF FLORIDA; THE NATIONAL COUNCIL OF LA RAZA; COMMON 4 Blackwell, Zehnder & Wermuth, PA, P.O. Box 1631, CAUSE; JOAN ERWIN; ROLAND SANCHEZ-MEDINA, JR.; 5 Orlando, Florida 32802-1631, (407)422-2472, J. STEELE OLMSTEAD; CHARLES PETERS; OLIVER D. 6 [email protected] and [email protected]; appeared on FINNIGAN; SERENA CATHERINA BALDACCHINO; and DUDLEY BATES, 7 behalf of the Plaintiff The League of Women Voters of Plaintiffs, vs. CASE NO. 2012-CA-2842 8 Florida. KENNETH W. DETZNER, in his official capacity as Florida 9 JOHN M. DEVANEY, Attorney at Law, of the law Secretary of State; THE FLORIDA STATE SENATE; THE 10 offices of Perkins Coie, LLP, 700 Thirteenth Street, FLORIDA HOUSE OF REPRESENTATIVES; 11 AND DEAN CANNON, in his official NW, Suite 700, Washington, D.C. 20005, (202)434-1624, capacity as Speaker of the Florida 12 [email protected]; appeared on behalf of the House of Representatives, 13 Plaintiff Romo. Defendants. ______/ 14 GEORGE N. MEROS, JR., Attorney at Law, of the VOLUME 1 DEPOSITION OF MARC REICHELDERFER 15 law offices of GrayRobinson, PA, Post Office Box 11189, MAY 16, 2013 REPORTED BY: 16 Tallahassee, Florida 32302, PEGGY OWENS REGISTERED PROFESSIONAL REPOTER 17 [email protected]; appeared on behalf of REGISTERED MERIT REPORTER 18 the Defendant Florida House of Representatives. 19 JASON N. ZAKIA, Attorney at Law, of the law 20 offices of White & Case, LLP, Southeast Financial 21 Center, Suite 4900, 200 South Biscayne Boulevard, 22 Miami, Florida 33131-2352, (305)925-4795; appeared on 23 behalf of the Defendant Florida Senate. 24 25 4 1 IN THE CIRCUIT COURT OF THE 1 APPEARANCES (CONTINUED) SECOND JUDICIAL CIRCUIT, IN 2 DANIEL C. BROWN, Attorney at Law, of the law 2 AND FOR LEON COUNTY, FLORIDA 3 offices of Carlton Fields, 215 S. Monroe Street, Suite 3 4 4 RENE ROMO, et al., 500, Tallahassee, Florida 32301-1866, (850)224-1585; 5 Plaintiffs, 5 appeared on behalf of the witness. 6 v. CASE NO. 2012-CA-00412 6 DAVID HEALEY, Attorney at Law, 2846 Remington 7 KEN DETZNER and PAM BONDI, 7 Green Circle, #B, Tallahassee, Florida 32308-3763, 8 Defendants. 8 [email protected]; appeared on behalf of the 9 ______/ 9 10 THE LEAGUE OF WOMEN VOTERS witness. OF FLORIDA, et al., 10 GEORGE T. LEVESQUE, General Counsel, The 11 11 Florida Senate, 404 South Monroe Street, Suite 409 The 12 Plaintiffs, 12 Capitol, Tallahassee, Florida 32399, (850)487-5237, 13 vs. 13 [email protected]; appeared telephonically 14 KEN DETZNER, et al., 14 15 Defendants. on behalf of The Florida Senate in Volume 1 of the 16 ______/ 15 deposition. 17 16 GERALD E. GREENBERG, Attorney at Law, of the 18 DEPOSITION OF: MARC REICHELDERFER 17 law offices of Gelber Schachter & Greenberg, PA, 1441 19 TAKEN AT THE INSTANCE OF: The Plaintiffs 18 Brickell Avenue, Suite 1420, Miami, Florida 33131, 20 DATE TAKEN: May 16, 2013 19 21 LOCATION: 131 N. Gadsden Street (305)728-0950, [email protected]; appeared Tallahassee, Florida 20 telephonically on behalf of the Plaintiffs in Volume 2 22 21 of the deposition. COMMENCING: 9:30 a.m. 22 23 23 CONCLUDING: 11:48 a.m. 24 24 25 25 1 (Pages 1 to 4) WWW.USLEGALSUPPORT.COM 954-463-2933 5 7 1 1 D E P O S I T I O N 2 I N D E X 2 THE VIDEOGRAPHER: Today is May 16, 2013. 3 WITNESS PAGE 3 The time is 9:30 a.m. We are located 131 N. 4 Marc Reichelderfer 4 Gadsden Street, Tallahassee, Florida, for the 5 Direct Examination by Mr. King 8 5 deposition Mark Reichelderfer. 6 6 My name is Krishna Singh. I'm the 7 7 videographer. The court reporter is Peggy Owens. 8 8 Will the counsel for the parties please 9 9 introduce themselves beginning with the petitioner 10 10 or plaintiff and the court reporter will swear in 11 11 the witness. 12 12 MR. KING: David King from King, Blackwell, 13 13 Zehnder & Wermuth in Orlando representing the 14 14 League of Women Voters. 15 15 MR. DEVANEY: John Devaney from Perkins Coie 16 16 representing the Romo plaintiffs. 17 17 MR. ZAKIA: Jason Zakia from White & Case 18 18 representing The Florida Senate. 19 19 MR. MEROS: George Meros, GrayRobinson, 20 20 representing The Florida House of Representatives. 21 21 MR. HEALEY: David Healey representing the 22 22 witness. 23 23 MR. BROWN: Daniel Brown representing the 24 24 witness. 25 25 DIRECT EXAMINATION 6 8 1 INDEX TO EXHIBITS 1 Whereupon, 2 NO. PAGE 2 MARC REICHELDERFER, 3 1 - Prosequence Client List 15 3 called as a witness; after having been first duly 4 2 - Reichelderfer - 14-19 64 4 sworn, was examined and testified as follows: 5 3 - List of Questions - Reichelderfer 213 78 5 DIRECT EXAMINATION 6 4 - E-mail - Reichelderfer 22 100 6 BY MR. KING: 7 5 - E-mail - Reichelderfer 28 101 7 Q Would you state your name please, sir. 8 6 - E-mail - Reichelderfer 36-38 103 8 A Marc Reichelderfer. 9 7 - E-mail - Reichelderfer 39-41 104 9 Q And what is your home address, 10 8 - E-mail - Reichelderfer 51-52 105 10 Mr. Reichelderfer? 11 9 - E-mail - Reichelderfer 53-54 106 11 A 3616 Mossy Creek Lane, Tallahassee, Florida, 12 10 - E-mail - Reichelderfer 55-58 109 12 32311. 13 13 Q And what is your business address? 14 14 A 115 East Park Avenue, Tallahassee, Florida, 15 15 32301. 16 16 Q And what business is located at that address, 17 17 sir? 18 18 A My Landmarc Strategies, Inc. 19 19 Q And is that your business? 20 20 A It would be a corporation that I own all the 21 21 shares of; yes, sir. 22 22 Q Okay, so you are the principal -- 23 23 A Yes, sir. 24 24 Q -- in that business. And what is your 25 25 occupation, sir? 2 (Pages 5 to 8) WWW.USLEGALSUPPORT.COM 954-463-2933 9 11 1 A I'm a political consultant, public affairs. 1 A I do not. I do not. From there I went to 2 Q Okay. And have you ever given a deposition 2 work on a campaign for Anna Cowan who was running for 3 before, sir? 3 an open state Senate seat. She won that seat in '96. 4 A Yes, sir. 4 Then I went on to serve as her aide for a year in the 5 Q Okay. What kind of cases were those, 5 Senate. 6 generally? 6 Q Okay. 7 A It was a, actually it was a deposition in the 7 A And then from there I left to go work on Rudy 8 Jim Greer criminal trial. 8 Giuliani's reelection staff in '97. Spent the last 9 Q Okay. Was that the only one you've done? 9 five months there working for Rudy Giuliani. I came 10 A I did one when I was in college for -- 10 back from New York to manage Katherine Harris's 11 against someone that stole my bicycle. 11 campaign for Secretary of State in 1998. 12 Q Oh, okay. Well, you understand to begin with 12 Q That was a successful campaign, wasn't it? 13 you are testifying under oath, right? 13 A Yes, it was. After that I went to work at a 14 A Yes, sir. 14 consulting firm in Orlando, Consensus Communications. 15 Q And as I ask you questions in this 15 Then in 2001 -- 16 deposition, I need you to answer audibly. Okay? 16 Q Who was the principal in Consensus? 17 A Okay. 17 A Tre' Evers and John Sowinski. Roy Reid is 18 Q And if I ask you something that you don't 18 also at that firm. 19 understand, will you tell me so I can rephrase it and 19 Q Uh-huh. Again, were you doing Republican 20 put it to you in a way that you do understand? 20 consulting? 21 A Yes, sir. 21 A I was doing some Republican consulting. I 22 Q And if you answer the question, I'm going to 22 was also doing some corporate work and worked on some 23 assume that you understand it; is that okay? 23 petition initiatives, different things like that. 24 A Yes, sir. 24 Q All right. And then what caused you to move 25 Q Now, would it be fair to say, sir, that you 25 to Tallahassee in 2001? 10 12 1 are a Republican campaign consultant? 1 A Consensus Communications wanted to open a 2 A Yes, sir. 2 Tallahassee office, and so -- 3 Q You do all your work for the Republicans or 3 Q You did that for them? 4 the Republican Party, right? 4 A They, they were very persuasive. And so I 5 A Yes, sir. 5 went, finally moved to Tallahassee, opened an office 6 Q And how long have you been doing that? 6 for them, and was here for about, about three years 7 A Since, in a variety of different capacities, 7 before we, before we amicably parted ways. And I 8 there is times I worked as an aide in the Senate, but 8 started my own firm in 2004. 9 that was on and off; but since 1995. 9 Q And so since that time you've been a 10 Q Okay. And you indicated that, I heard you 10 principal in your firm since 2004? 11 say before we got started that you lived in Orlando 11 A Yes, sir. 12 back in 1995; is that right? 12 Q And during that time, tell me some of the 13 A Yes, sir. 13 representative clients that you represented over that 14 Q So you lived there until 2001? 14 period, from 2004 to now. 15 A Yes, sir. 15 A On the campaign, on the election side or -- 16 Q And were you doing work for Republican 16 Q Well, let's talk about the election. How do 17 candidates during that period of time? 17 you divide your practice up? Is there an election side 18 A Yes, sir. 18 and then the rest of the time? 19 Q Who were some of the candidates you worked 19 A Landmarc Strategies is the corporation that 20 for or between '95 and 2001? 20 I'm a principal of. It has two LLCs that it owns that 21 A I was a staffer on Lamar Alexander's 21 are disregarded entities. So one of them is 22 presidential campaign starting in 1995. 22 Prosequence, LLC. The other one is Issue Management, 23 Q Tennessean. 23 LLC. So I kind of try to keep some of my different 24 A Yes, sir. 24 activities segregated. 25 Q Do you have any connections to Tennessee? 25 Q All right. So what type of work goes into, 3 (Pages 9 to 12) WWW.USLEGALSUPPORT.COM 954-463-2933 13 15 1 goes through Prosequence, LLC? 1 they? 2 A I do mostly candidate, candidate, directly 2 A Yes. 3 for candidates. The candidate work will go through 3 Q And does the money you make from them all 4 Prosequence. 4 come through Prosequence, from the Republican Party of 5 Q Prosequence? 5 Florida? 6 A Yes, sir. 6 A I believe so. 7 Q And what about through Issue Management? 7 Q Well, I've got some records that would 8 A Any committee work, if I'm doing some work 8 suggest that you made something like 600 -- almost 9 for an ECO or a political committee would go through 9 $600,000 from the Republican Party of Florida between 10 there. Then I also do some lobbying, which that would 10 2006 and 2012. Would you dispute that notion? 11 be through Landmarc Strategies, any of my lobbying 11 A That seems a little -- since 2007, that seems 12 work. 12 a little bit high. 13 Q So through Prosequence, could you tell us the 13 Q 2006. 14 names of some of your representative clients? 14 A That seems a little bit high. 15 A John Thrasher. Rob Bradley. Dorothy Hukill, 15 Q Lets look at it. I'm going to show you 16 Aaron Bean. Nancy Dieter. John Legg. 16 Exhibit 1 -- 17 Q Dean Cannon? 17 (Whereupon, the document was marked as 18 A Dean Cannon. I was going through senators 18 Deposition Exhibit No. 1.) 19 first. He is in the house. 19 BY MR. KING: 20 Q Right, okay. 20 Q And ask you if you recognize Exhibit 1 as 21 A In the House, Dean Cannon. Mike Fasano. 21 a -- 22 Danny Young. Matt Hudson. Travis Hutson. Travis 22 A Okay. This, so, actually you are asking me 23 Cummings. Those would be -- 23 if I've made it from not just the Republican Party of 24 Q A representative group? 24 Florida. You are saying from the Republican Party of 25 A That's a good representative group. I hope 25 Florida and candidates running for office. 14 16 1 I'm not forgetting any of my clients. 1 Q No, actually I was asking you about the 2 Q Right. Would the thing that all those folks 2 Republican Party. I was separating that out. Because 3 have in common is the fact that they are all 3 as you will see from Exhibit 1, it indicates that 4 Republicans? 4 Prosequence through the end of, or November of 2012, 5 A They are all Republicans, yes. 5 has received a total of a $1,125,925.13. Do you see 6 Q So you wouldn't do a Democrat, right? 6 that? 7 A Not in a race that was partisan, no. 7 A Yes, sir. 8 Q Because you are a Republican partisan, right? 8 Q Would you agree that is accurate? 9 A I'm a Republican consultant. 9 A That's probably accurate. 10 Q Right. And you are very partisan about 10 Q All right. And you see it lists -- I assume 11 supporting the Republican party, right? 11 you have to report everyone of these payments; is that 12 A Well, I think it is -- yes. 12 right? 13 Q I mean, obviously you philosophically believe 13 A Yes, sir. Yes, sir. Well, the candidates 14 the same things that Republicans do, right? 14 report them. 15 A Generally speaking, yes. 15 Q The candidates report. And this all gets -- 16 Q Right. And it is also very lucrative for you 16 A Correct. 17 because that's where you make your livelihood, right? 17 Q -- added together? 18 A I make a living, yes. 18 A It is all public record. 19 Q Right. And in addition to all those 19 Q Public record, all right. And so you will 20 Republican candidates, you also represent the or have 20 see there are a lot of candidates listed here, right? 21 done work, been paid by the Republican Party of 21 A Yes, sir. 22 Florida; right? 22 Q But there is also a large number of checks 23 A At times I have, yes. 23 coming directly from the Republican Party of Florida, 24 Q Well, actually they've been a pretty 24 right? 25 substantial client of yours from time to time, haven't 25 A Yes, sir. 4 (Pages 13 to 16) WWW.USLEGALSUPPORT.COM 954-463-2933 17 19 1 Q See back there right on the very first page, 1 A Those are your words, not mine. 2 right back there on, in 2006, 9/8/2006 you got 20,928. 2 Q Well, wouldn't you agree with me? 3 You got 10,928. You got 20,000. $50,000 coming from 3 A I'm a little more modest than that, but I try 4 the Republican Party, right? 4 to work hard. If other people think that, that's 5 A Yes, sir. 5 great. 6 Q Okay. So tell me what kind of work you do 6 Q That's kind of what your reputation is, isn't 7 for the Republican Party of Florida. 7 it, one of the very most prominent Republican campaign 8 A The majority of those payments for the 8 consultants? 9 Republican Party of Florida would be when a candidate 9 A I think that would be a question for other 10 is running for office and they get type -- I will have 10 people observing that work, not me. 11 a contract with an individual candidate running for 11 Q Right. Well, you've got quite an impressive 12 office. 12 client list, right? 13 When they win the primary, or get to the 13 A Well, thank you. 14 primary, or if there is no primary, the Republican 14 Q I mean, don't you think they are a pretty 15 Party of Florida can pick up the consulting fees for 15 impressive group of clients? 16 that candidate. And it is listed as a non-allegory 16 A I'm happy with my list of clients, so. 17 kind of expense. Those were in-kind contributions. 17 Q Right. And they represent a very substantial 18 So what they were doing, they were paying the 18 amount of power in the Florida State House, right? 19 fees that I had contracted with an individual candidate 19 MR. MEROS: Object to form. 20 on that candidate's behalf and listing that as an 20 MR. ZAKIA: Object to form. 21 in-kind contribution to the candidates, would be the 21 BY MR. KING: 22 majority of those. 22 Q You can go ahead and answer the question. 23 Q So some of those could be where your client 23 They are going to from time to time object. Since we 24 was Dean Cannon. And the Republican Party of Florida 24 don't have a judge here to rule on the objections, you 25 is picking up the bill for that? 25 go ahead and answer the question. 18 20 1 A Yes, sir. 1 A I mean, I don't know what your definition is 2 Q Okay. Did you do projects directly for the 2 of power. 3 Republican Party of Florida? 3 Q Well, lets go back to 2010. Wasn't Dean 4 A The only, during the period of -- to the best 4 Cannon the Speaker of the House? 5 of my recollection, the only direct consulting I did 5 A Yes, sir. 6 for the Republican Party of Florida was during the two 6 Q I mean, that's a pretty powerful position, 7 years that Dean Cannon was the Speaker Designate, which 7 isn't it? 8 he would then head House campaigns for the Republican 8 MR. MEROS: Objection to form. Leading. 9 Party of Florida. 9 BY MR. KING: 10 I was a consultant on House campaigns for 10 Q You can go ahead and answer the question. 11 Dean Cannon during that two-year period. 11 A I think it is fairly powerful position. 12 Q Okay. So let me make sure I understand. So 12 Q Right. And you had access to Dean Cannon 13 in this period of time, let's say by 2000, end of 2010, 13 pretty much as you needed him, right? 14 you have a good working relationship with a lot of 14 MR. MEROS: Object to form. Leading. 15 state senators and state representatives; is that 15 THE WITNESS: I don't know that as I needed 16 right? 16 it. No. 17 A Yes. 17 BY MR. KING: 18 Q I mean, you represent a whole bunch of them, 18 Q Did you have good access to Dean Cannon? 19 right? 19 A I have good access to Dean Cannon. 20 A A fair number, yes, sir. 20 Q Could you pick up the phone and call Dean 21 Q You have a very good working relationship 21 Cannon and get him on the telephone -- 22 with the Republican Party of Florida, right? 22 A Eventually. 23 A Yes, sir. 23 Q -- within a reasonable period of time? 24 Q You are considered to be one of the top 24 A Eventually, yes. 25 Republican campaign consultants; isn't that right? 25 Q Could you send him an e-mail and get a 5 (Pages 17 to 20) WWW.USLEGALSUPPORT.COM 954-463-2933 21 23 1 response from him within a reasonable period of time? 1 A Yes, sir. 2 A Sometimes it was reasonable. Sometimes it 2 Q And would it be correct that you wanted that 3 wasn't. 3 redistricting to result in districts that were 4 Q Okay. But you had the ability to do that, 4 favorable to Republicans? 5 right? 5 A Yes. 6 A Yes, sir. 6 MR. MEROS: Same objection. Go ahead. 7 Q And you had some pretty powerful clients in 7 MR. ZAKIA: Objection. 8 the Senate, didn't you? 8 THE WITNESS: Yes. 9 A Again, you know, that's subjective; but yes, 9 BY MR. KING: 10 I mean people that were -- 10 Q And you were -- wouldn't you say you were in 11 Q Well, wouldn't you say that John Thrasher had 11 a pretty unique position to be helpful in that process? 12 a reputation being a pretty powerful fellow in the 12 MR. ZAKIA: Object to form. 13 Florida Senate? 13 MR. MEROS: Object to form. 14 MR. ZAKIA: Object to form. 14 THE WITNESS: Not necessarily. 15 THE WITNESS: Sure. 15 BY MR. KING: 16 BY MR. KING: 16 Q Okay. Well, you were very familiar with the 17 Q All right. What was Mr. John Thrasher's 17 processes of the state House, right? 18 reputation in the Florida Senate? 18 A Yes, sir. 19 MR. MEROS: Object to form. 19 Q You've worked there, correct? 20 MR. ZAKIA: Object to form. 20 A Yes, sir. 21 THE WITNESS: He has a good reputation for 21 Q You knew a lot of the staffers, correct? 22 being an effective legislator. 22 A Yes, sir. 23 BY MR. KING: 23 Q A lot of the work in the state House is done 24 Q So in -- would it be correct that in 2011 and 24 by the staffers, isn't that right? 25 2012, it was your personal goal that as many Republican 25 A Yes, sir. 22 24 1 legislators could be elected -- strike that. Let me 1 Q A lot of the work in redistricting was done 2 start again. 2 by the staffers, correct? 3 Would it be your personal goal in 2011, 2012, 3 A Yes, sir. 4 to elect as many Republican legislators as possible? 4 Q And you knew those folks well, right? 5 A Yes. 5 MR. ZAKIA: Object to the form. 6 Q Would it be fair to say that in 2011 and 2012 6 THE WITNESS: Some of them. 7 you wanted the districts in the Senate and in the House 7 BY MR. KING: 8 and for the Congressional seats to perform as well for 8 Q And in your business you made it a point to 9 Republicans as you could get them to do? 9 know the ones that were important to know, right? 10 MR. ZAKIA: Object to form. 10 MR. MEROS: Object to form. 11 MR. MEROS: Object to form. Leading. 11 MR. ZAKIA: Object to form. 12 THE WITNESS: To the extent that we were also 12 THE WITNESS: It is not always that easy. 13 complying with the Florida Constitution, yes, sir. 13 BY MR. KING: 14 BY MR. KING: 14 Q Right. 15 Q So did you want the districts to be drawn in 15 A You have relationships with who you have 16 a way that they would perform well for Republicans? 16 relationships with. Some, I didn't know others. 17 MR. MEROS: Object to form. Leading. 17 Q Right, but you certainly knew some of the 18 MR. ZAKIA: Same objection. 18 folks that were involved in the redistricting effort; 19 MR. MEROS: And repetitive. 19 right? 20 BY MR. KING: 20 A Yes. 21 Q You can go ahead and answer the question, 21 Q Who was the main map drawer in the House, to 22 sir. 22 your knowledge? 23 A Can you ask that question again? 23 A I wasn't directly involved with that. I 24 Q Sure. In 2011 and 2012, you knew that there 24 could make some assumptions, but I wouldn't know for 25 was a redistricting going on; right? 25 certainty who was actually drawing the maps. 6 (Pages 21 to 24) WWW.USLEGALSUPPORT.COM 954-463-2933 25 27 1 Q Well, who was in charge of the process of 1 Q And why was that? 2 getting the maps drawn? 2 A That was at the advice of House counsel that 3 MR. ZAKIA: Object to form. 3 thought that political consultants should not be 4 THE WITNESS: That would be the chairman of 4 communicating with redistricting staff over the 5 the committee, Representative Will Weatherford. 5 redistricting process. 6 BY MR. KING: 6 Q What House counsel was that? 7 Q And who was the staffer directly under 7 A The House General Counsel. I mean, I think 8 Mr. Weatherford that was responsible for that? 8 -- 9 A Alex Kelly would have been the staff director 9 Q Who was that person? 10 of the House redistricting committee. 10 A I believe it was GrayRobinson who was 11 Q And Alex Kelly was a good friend of yours, 11 handling that. 12 wasn't he? 12 Q Mr. Meros? 13 A I know -- 13 A It may have been. It was at the direction of 14 MR. MEROS: Object to form. 14 the Speaker. 15 THE WITNESS: I know Alex Kelly. 15 Q Okay. 16 BY MR. KING: 16 A And the Speaker's chief of staff. 17 Q How would you characterize your relationship 17 Q Through the Speaker and the House counsel, 18 with Mr. Kelly? 18 you understood GrayRobinson was the House's counsel on 19 A I've been involved, I've known him through 19 that? 20 just business, through the years. 20 A Yes, yes. 21 Q For a long time? 21 Q All right. And they took the position and 22 A Probably since about 2000. 22 the Speaker took the position that political 23 Q Okay. He is not a fellow you could call up 23 consultants shouldn't have any contact with the people 24 on the phone and get him to take your call? 24 involved in the maps? 25 A Not during the redistricting process. 25 A I think that was advised; yes, sir. 26 28 1 Q Oh, he didn't have any communications with 1 Q Okay. And is that something you followed? 2 you during redistricting? 2 A I did; yes, sir. 3 A I do not recollect. Well, during the time 3 Q You thought it was important to stick to 4 period -- we will say after census data was pressed 4 that? 5 into the maps. 5 A That was the wishes of the Speaker, and I was 6 MR. MEROS: After census data what? 6 willing to carry those wishes out. 7 THE WITNESS: After the census data was 7 Q Okay. So the wishes of the Speaker and the 8 available and where you were capable of drawing 8 Speaker's lawyers were that you and other political 9 maps. 9 consultants should have absolutely nothing to do with 10 BY MR. KING: 10 the process of the map drawing and decisions about the 11 Q Okay. 11 districts in the redistricting process; is that right? 12 A My communication with Alex Kelly ceased. 12 MR. ZAKIA: Object to form. 13 Q Okay. 13 THE WITNESS: Specifically to the map 14 A To my recollection. To the greatest of my 14 drawing, yes. 15 recollection, our communication ceased. 15 BY MR. KING: 16 Q And when was that on a time basis? 16 Q Well, was there something, was this 17 A Summer-ish, 2011. 17 prohibition only limited just to having contact with 18 Q Summer-ish 2011 you think you stopped having 18 the person that was actually drawing the map? 19 communications with Alex Kelly? 19 A That was what the focus was; but, I mean, I 20 A About that time, yes, sir. 20 don't recall specifically how broad that was. 21 Q Okay. So from the summer of 2011, when was 21 Q Okay. And you also were in a position to 22 the next time you started having communications with 22 have contact and talk with Senator Thrasher about 23 Alex Kelly? 23 redistricting; isn't that correct, sir? 24 A Sometime after the legislator passed the 24 A I would have that ability, yes, sir. 25 maps. 25 Q Okay. Just as you had a relationship with 7 (Pages 25 to 28) WWW.USLEGALSUPPORT.COM 954-463-2933 29 31 1 Alex Kelly, did you also have a relationship with a 1 A Yes. 2 fellow named Johnny Guthrie? 2 Q Does that mean something to you when I say 3 A No, sir. 3 that? 4 Q Did you know who he was? 4 A Yes, sir. 5 A I know who he is, yes, sir. 5 Q What does that mean to you? 6 Q And what was his position? 6 A They are the reapportionment amendments that 7 A I think he had the equal position in the 7 provided the guidelines that we were then subject to 8 Senate as Alex Kelly. 8 through the redistricting process. 9 Q Okay. And what about a fellow named Clark? 9 Q And when you heard about those amendments, 10 Did you know a Senate staffer named Clark? 10 did you learn pretty quickly that the Republican 11 A Clark is the first name? 11 position was to oppose those amendments? 12 Q Last name, I think. 12 MR. MEROS: Object to form, leading. 13 A Oh, Chris Clark, yes, sir. 13 MR. ZAKIA: Objection. 14 Q Chris Clark? 14 THE WITNESS: Can you repeat the question? 15 A Yes, sir. 15 BY MR. KING: 16 Q Is that somebody you had a relationship with? 16 Q All right. Let me try again. Did you at 17 A Yes, sir. 17 some point learn before the vote occurred that the 18 Q Is that a fellow that was working on 18 Republican Party of Florida opposed the petition? 19 redistricting in 2011 and 2012? 19 A I don't know if the Republican Party took an 20 A I believe he was. 20 official position. Generally speaking, you know, I 21 Q For the Senate? 21 didn't think it was a particular good idea, and many of 22 A Yes, sir. 22 my clients didn't either. 23 Q Is he a fellow you could pick up the phone 23 Q So pretty much you and your clients were 24 and call and get on the line? 24 unified in your opposition to those petitions? 25 A I could pick up the phone and call him and 25 A Yes, sir. 30 32 1 get on the line. 1 Q And did you help raise money to oppose the 2 Q Okay. Is he another fellow you eschewed 2 petitions? 3 contact with during that period from the summer of 2011 3 A I did not, no. 4 until the maps were passed? 4 Q All right. Were your clients involved in 5 A I did not. 5 raising money to oppose the petitions? 6 Q You didn't have any contact? 6 A They may have been. I don't know 7 A No, no, no, I didn't eschew -- 7 specifically. 8 Q You actually did have contact with him -- 8 Q Okay. Was there litigation to try to keep 9 A I did have contact, yes, sir. 9 those petitions off the ballot? 10 Q -- during that period, okay. And so what 10 A Yes, sir. 11 kind of contacts did you have with Mr. Clark? 11 Q Were you in any way involved in that 12 A He was the legislative aide to Senator Don 12 litigation? 13 Gaetz. So in my capacity of representing a variety of 13 A Not directly, no, sir. 14 clients, I would often see him on issues unrelated to 14 Q Were some of your clients? 15 the redistricting. 15 A They may have been, yes. 16 Q And Gaetz was very much involved in 16 Q Did you know about it? 17 redistricting in the Senate, wasn't he? 17 A Yes, sir. 18 A Yes, sir. 18 Q They told you that they were opposing it? 19 Q Now, at some point you became aware that 19 A I mean, I think, I think Dean Cannon did the 20 there was a petition circulating to bring some 20 oral arguments before the Supreme Court on one of the 21 regulation into the way that the districts would be 21 legal issues. So I mean, yes, I would have been aware 22 reorganized by the legislature; is that right? 22 he was giving testimony before the Supreme Court. 23 A Yes, sir. 23 Q So you would have understood that the Speaker 24 Q And did you come to identify those as 24 was taking a pretty strong position about those 25 petitions five and six? 25 amendments, right? 8 (Pages 29 to 32) WWW.USLEGALSUPPORT.COM 954-463-2933 33 35 1 A Yes, sir. 1 here in Tallahassee, were you? 2 Q And that position was in opposition to those 2 That wasn't a very good question. Let me try 3 amendments, right? 3 it again. 4 A Yes, sir. 4 You know some other like-minded Republican 5 Q And so the litigation was not successful in 5 consultants here in Tallahassee that you worked with 6 keeping the petitions off the vote -- off the ballot? 6 from time to time, right? 7 A Correct. 7 A Yes. 8 Q Right? 8 Q And would one of those be Pat Bainter? 9 A Correct. 9 A Yes, sir. 10 FEMALE VOICE: George? 10 Q He is a very strong Republican consultant, 11 MR. MEROS: Was that someone on the phone? 11 right? 12 MR. KING: Hello? 12 A Sure. 13 MR. MEROS: Now it is on hold. 13 Q He has got lots of clients, right? 14 MR. ZAKIA: Someone may have disconnected it. 14 A Yes, sir. 15 MR. MEROS: Is anybody on the phone? 15 Q And makes lots of money from the Republicans 16 FEMALE VOICE: I was trying to conference in 16 that he represents, right? 17 George Levesque, but apparently it didn't work. I 17 A You would have to ask him what he makes. I 18 will have to try again. Thank you. 18 don't know specifically. 19 MR. ZAKIA: He must have gotten disconnected. 19 Q Well, you have seen the filings, haven't you? 20 BY MR. KING: 20 A Some. 21 Q All right. Let me recapitulate. I will try 21 Q You know your clients, some of your clients 22 to figure out where I was when we were interrupted 22 have paid him a bunch of money; right? 23 there. 23 A Yes. 24 So the Speaker was opposing the petition. 24 Q Okay. And there is another fellow that you 25 Litigation was filed. And it was unsuccessful. Is 25 work with very regularly called Rich Heffley, right? 34 36 1 that right? 1 A Yes, sir. 2 A That's my understanding. 2 Q And he is another senior Republican political 3 Q The petitions were on the ballot at the time 3 consultant here in Tallahassee, right? 4 of the election, right? 4 A Yes, sir. 5 A Yes, sir. 5 Q I mean, he has been at it for 20 years, would 6 Q And the petitions passed? 6 you say? 7 A Yes, sir. 7 A Yes, sir. 8 Q Right? 8 Q All right. And he represents a lot of 9 A Yes, sir. 9 prominent Republicans, right? 10 Q People of Florida spoke -- 10 A He doesn't do as many individual candidates. 11 A Yes, sir. 11 Q What does he mainly do, would you say? 12 Q -- right? 12 A He works for a variety of committees and then 13 A (Nodding head.) 13 does some work for the Republican Party of Florida. 14 Q They wanted the amendments to take effect and 14 Q Okay. And -- 15 to govern the actions of the legislature in this next 15 MR. MEROS: Can I stop you one minute. There 16 redistricting cycle. 16 was a beep. Did someone come on the phone? 17 MR. MEROS: Object to form. 17 MR. LEVESQUE: Yes, this is George Levesque. 18 MR. ZAKIA: Object to form. 18 I'm sorry, I got disconnected earlier. 19 BY MR. KING: 19 MR. MEROS: Anyone else on the phone? 20 Q Or at least the majority did. 20 (No response.) 21 MR. MEROS: Same objection. 21 MR. MEROS: Okay. 22 THE WITNESS: You can assume that, correct. 22 BY MR. KING: 23 BY MR. KING: 23 Q All right. So Mr. Heffley, you were telling 24 Q All right. You weren't the only Republican 24 me, he does stuff directly for the Republican Party 25 consultant involved in these issues with your clients 25 some? 9 (Pages 33 to 36) WWW.USLEGALSUPPORT.COM 954-463-2933 37 39 1 A That's my understanding. I don't know the 1 A Yes, but that was two years ago. So I don't 2 inner workings of his business. 2 know -- 3 Q And he was, he was, of course, also involved 3 Q I understand. Time flies. 4 in opposing the redistricting; is that right? 4 A -- if it was three months later or two days 5 A That was my understanding, yes. 5 later. I don't recall specifically. 6 Q Opposing the amendments? 6 Q Right. But you were very much involved in it 7 A Yes, sir. 7 at the time, right? 8 Q Felt very strongly anti-Amendment 5 and 6? 8 A In the lawsuits, no, sir. 9 MR. ZAKIA: Object to form. 9 Q Very much involved in following the 10 THE WITNESS: I mean, I don't know what you 10 redistricting situation? 11 mean by strongly or very strongly. I mean, I 11 A I was reading the newspaper clips, yes, sir. 12 think he was opposed to them. He was involved, I 12 Q Right. And you were really doing more than 13 believe in that effort, but -- 13 that, weren't you? I mean, you were discussing with 14 BY MR. KING: 14 Dean Cannon on a regular basis, right. 15 Q He was never shy about telling you he thought 15 MR. MEROS: Object to form. Leading. 16 that was a bad idea, right? 16 THE WITNESS: I think most of that was dealt 17 A No. 17 with -- I'm not a lawyer, and most of those 18 Q And there is another fellow named Terraferma; 18 communications were between the Speaker and the 19 is that right? 19 legal counsel. So I was not directly involved in 20 A Yes, sir. 20 those conversations. 21 Q What's his first name, Frank? 21 BY MR. KING: 22 A Frank, Frank Terraferma. 22 Q But I mean you went to meetings about it, 23 Q And he is another Republican consultant, 23 didn't you? 24 right? 24 A Not about the challenges, no, sir. 25 A Yes, sir. 25 Q Okay. Did you have anything to do with 38 40 1 Q All right. And so once the -- did you 1 dealing with Corrine Brown, getting her involved in 2 understand that sometimes they were referred to as the 2 bringing the action against -- 3 fair district amendments? 3 A No, sir. 4 A Yes, sir. 4 Q You don't have any close connections with 5 Q That has meaning to you? 5 her -- 6 A Yes, sir. 6 A I do not, no, sir. 7 Q All right. Once those fair districting 7 Q -- team? 8 amendments passed, were you involved in an effort to 8 A No, sir. 9 get them declared unconstitutional? 9 Q You knew that Mr. Heffley did, though, didn't 10 A Was I involved? 10 you? 11 Q Yes. 11 A I don't know that to be true. 12 A Not directly, no. 12 MR. MEROS: Object to form. 13 Q Well, your client Dean Cannon was involved; 13 BY MR. KING: 14 right? 14 Q Okay. You never talked about it with 15 A I believe he was involved in that, yes. 15 Heffley, with Rich Heffley? 16 Q And in fact, also, there was a lawsuit filed 16 A I mean, I'm sure we had conversations 17 by Corrine Brown and Mario Diaz-Balart; right? 17 generally about redistricting; but was I specifically 18 A Yes, sir. I remember hearing about that, 18 involved in advising or trying to be involved, the 19 yes, sir. 19 answer is no. 20 Q That was filed like the day after those 20 Q And then, of course, you understood that the 21 amendments passed, right? 21 House joined in the litigation and joined in a federal 22 A If you say so. I don't recall specifically 22 lawsuit down in Miami to try to get these two 23 when they were filed. 23 amendments declared unconstitutional; right? 24 Q You were following it pretty closely back at 24 MR. MEROS: Object to form. 25 the time, though, weren't you? 25 THE WITNESS: I was following it as anybody 10 (Pages 37 to 40) WWW.USLEGALSUPPORT.COM 954-463-2933 41 43 1 else might in the newspaper and through e-mails, 1 right. 2 yes, sir. 2 A Yes, sir. 3 BY MR. KING: 3 Q And of course, that included not favoring an 4 Q Okay. And that was unsuccessful, right? 4 incumbent or a political party, right? 5 A I believe so, yes, sir. 5 A As well as disfavoring an incumbent or 6 Q The district judge granted a summary judgment 6 political party. 7 in that case. And then it went up on appeal to the 7 Q But the incumbents were primarily Republican 8 11th Circuit. And they affirmed three-zip, right? 8 clients of yours that you wanted to protect; isn't that 9 A If you say so, sir. 9 right? 10 Q Weren't you following at the time? 10 MR. ZAKIA: Object to form. 11 A I mean, you are going in more detail than I 11 MR. MEROS: Object to form. 12 probably followed it. 12 BY MR. KING: 13 Q Okay. But you knew then that, or you heard 13 Q Many of the incumbents? 14 that the 11th Circuit Court of Appeals took the 14 A Yes. 15 position these amendments leveled the playing field in 15 Q And you understood that the way it was set up 16 Florida, right, in redistricting, right? 16 was that you had a, as far as the congressional 17 A I think you are -- I don't know that it was 17 districts were concerned, you had a few districts, six 18 11th Circuit. I mean, I wasn't following it close 18 or seven, that were packed with Democrats; and then you 19 enough to notice all the details. 19 had Republican majorities in the rest of them, right? 20 Q Okay, but you heard that concept, right? 20 MR. MEROS: Object to form. Leading. 21 A What I know is that the legal challenges 21 MR. ZAKIA: Object to form. 22 failed. 22 THE WITNESS: Can you ask that question 23 Q Right, the amendments -- 23 again? 24 A The specifics of it, I wouldn't know about. 24 BY MR. KING: 25 Q You understood the amendments were supposed 25 Q Sure. 42 44 1 to try to level the playing field in redistricting, 1 A I'm not sure I understood. 2 right? 2 Q Did you understand back at the time you were 3 MR. MEROS: Object to form. 3 getting involved in the redistricting that you had in 4 MR. ZAKIA: Same objection. 4 the baseline congressional districts, the ones before 5 BY MR. KING: 5 the redistricting, you had six or seven districts with 6 Q You can go ahead and answer. 6 a large population of Democrats. And the rest of the 7 A I think that was what the proponents of the 7 districts had a Republican majority. Isn't that 8 amendments were advocating, yes. 8 correct, sir? 9 Q But you really weren't interested in the 9 MR. MEROS: Objection. 10 playing field being leveled, were you, sir? 10 MR. ZAKIA: Same objection. 11 MR. MEROS: Object to form. 11 THE WITNESS: I wouldn't agree with your 12 MR. ZAKIA: Same objection. 12 exact analysis of the districts, sir. 13 THE WITNESS: My belief was that the playing 13 BY MR. KING: 14 field was level, and that these amendments would 14 Q That wasn't the way you saw it at the time? 15 make them unlevel. 15 A No, sir. I think there were some Democratic 16 It is not that, not that I was disinterested 16 districts with higher Democratic proportions for the 17 in them being -- so you are using words that I 17 purposes of electing minorities. But outside of that, 18 would not have chosen. 18 I mean, I don't know specifically. 19 BY MR. KING: 19 Q Well, is it my understanding then that you, 20 Q You were happy with the playing field as it 20 you thought that you were not supposed to be part of 21 was, is that right? 21 the redistricting effort as a political consultant? 22 A As it being level, yes, sir. 22 A That's not exactly what I said, no, sir. 23 Q And so you understood that the redistricting 23 Q Okay. Let me see where I went. In other 24 process was going to have to go ahead following the 24 words, I thought you were informed by Speaker, Cannon, 25 guidelines that were set out in those amendments; 25 and by his counsel that as a partisan political 11 (Pages 41 to 44) WWW.USLEGALSUPPORT.COM 954-463-2933 45 47 1 consultant you shouldn't be involved in the 1 MR. MEROS: Object to form. 2 redistricting process; is that right? 2 MR. ZAKIA: Object to form. 3 A I believe the specific question was, as it 3 BY MR. ZAKIA: 4 was worded before, was in the map drawing, which -- 4 Q People like Dean Cannon? 5 Q Okay. 5 A Yes, sir. 6 A -- the redistricting process in total is a 6 Q They didn't need your help to tell them how 7 larger picture than specifically just drawing maps. 7 to draw the districts, did they? 8 Q Well, but that larger picture results in the 8 MR. ZAKIA: Object to form. 9 drawing of the maps, doesn't it? 9 THE WITNESS: No, sir. 10 MR. MEROS: Object to form. 10 BY MR. KING: 11 THE WITNESS: Not necessarily, no, sir. 11 Q But when they got your help, they got help 12 MR. ZAKIA: Objection. 12 from a partisan Republican consultant; isn't that 13 BY MR. KING: 13 right? 14 Q I mean what's the part of the process that 14 A I don't know that I gave them any help. 15 you thought it was appropriate for you to be involved 15 Q Well, you certainly wanted to result in 16 in? 16 districts that would be favorable to your clients, 17 A I think there were early on, let's say prior 17 isn't that right? 18 to map drawing, there were decisions as to how to 18 MR. MEROS: Object to the form. 19 comply with 5 and 6. 19 MR. ZAKIA: Same objection. 20 And some of those, when you are drawing a 20 THE WITNESS: I think I was interested in the 21 line, is it better to use a VTD or is it better to use 21 process taking place in compliance with the 22 a river as a boundary. Is it better to use a city 22 constitution and being upheld by the courts. 23 boundary, is it best to use -- so it was really more 23 BY MR. KING: 24 determining, if you are drawing maps, what complies 24 Q But you and your political consultant friends 25 with five and six, and how you interpret five and six, 25 didn't think very much of those constitutional 46 48 1 which was mostly being done by the lawyers, but which 1 requirements, did you? 2 is conversations that I think is fair for me to have 2 MR. MEROS: Object to the form. 3 with other political consultants or people in the 3 MR. ZAKIA: Object to the form. 4 process. 4 THE WITNESS: But that doesn't matter. It is 5 Q Well, it is certainly fair for you to have 5 the constitution of the state. 6 those conversations with other political consultants 6 BY MR. KING: 7 like the Heffleys and the Bainters and the people like 7 Q Wasn't your intent to work around those 8 that; right? 8 constitutional requirements to get the very best 9 A Oh, absolutely. 9 districts for Republicans that you could get? 10 Q And you had those conversations on a regular 10 MR. MEROS: Object to form. 11 basis, right? 11 MR. ZAKIA: Object to form. 12 A Yes, sir. 12 THE WITNESS: Not to get around, no, sir. To 13 Q But you also considered it appropriate for 13 comply within, and do the best job possibly. 14 you to have those conversations with the staffers that 14 BY MR. KING: 15 were working in the redistricting area, right? 15 Q Would you agree that you had no business 16 MR. ZAKIA: Object to form. 16 being involved with the maps during the process while 17 MR. MEROS: Object to form. 17 the legislature was trying to decide what the districts 18 THE WITNESS: I did not have those 18 should be? 19 conversations, specifically. I don't believe I 19 MR. MEROS: Object to form. 20 had any conversations like that specifically with 20 THE WITNESS: No, I don't agree with that 21 staffers, no. 21 statement. 22 BY MR. KING: 22 BY MR. KING: 23 Q And you had those kind of conversations with 23 Q So it was okay for you to be giving your 24 your legislator friends; isn't that right? 24 advice to the people involved, the legislators, about 25 A Yes. 25 how the maps should look and be drawn and how they 12 (Pages 45 to 48) WWW.USLEGALSUPPORT.COM 954-463-2933 49 51 1 would perform? 1 A No, sir. 2 MR. BROWN: Objection to that question. It 2 MR. ZAKIA: Object to form. 3 is argumentative. Go ahead and answer. 3 MR. MEROS: I'm sorry, did you say "yes" or 4 BY MR. KING: 4 "no." 5 Q It could be multiple, as well. So let me, I 5 THE WITNESS: No, sir. 6 think your counsel made a good objection. Let me try 6 BY MR. KING: 7 again. 7 Q All right. Isn't it correct, sir, that you 8 For example, you were very interested in how 8 analyzed how the maps would perform politically? 9 the maps would perform, isn't that right, in the 9 MR. MEROS: Object to form. 10 various districts? 10 BY MR. KING: 11 A Yes. 11 Q The congressional maps. 12 Q In other words, you wanted to know whether 12 A I did analyze some of that analysis, yes, 13 these districts they were proposing would perform well 13 sir. 14 for Republicans or not, right? 14 Q All right. And you told staffers and 15 A Yes. 15 legislators about how those maps would perform, didn't 16 Q Okay. And so you provided that information 16 you, Mr. Reichelderfer? 17 about how they would perform politically to the 17 A I don't recall telling any of the staffers 18 legislators that you worked with; isn't that right? 18 about the congressional map performance, no, sir. 19 MR. ZAKIA: Object to form. 19 Q Did you tell Mr. Pepper about how the 20 THE WITNESS: Not necessarily, no, sir. 20 congressional map would perform? 21 BY MR. KING: 21 A I don't recall telling Mr. Pepper about how 22 Q But you did discuss performance with those 22 the congressional map performs, no, sir. 23 legislators; isn't that correct, sir? 23 Q Would you deny you did that? 24 MR. ZAKIA: Object to form. 24 A I don't recall doing that. 25 THE WITNESS: At, at the point at which they 25 Q Okay. Did you tell Mr. Pepper or any other 50 52 1 were made public, yes. I think timing is 1 legislator or staffer how the Senate maps would perform 2 important here. 2 politically? 3 BY MR. KING: 3 A Ask the question again. 4 Q At the point, you mean when they were first 4 Q Did you tell Mr. Pepper or any other staffer, 5 publicly announced? 5 or any of the legislators involved in the process, how 6 A Yes, sir. 6 the Senate maps would perform politically? 7 Q But after the first maps were publicly 7 MR. ZAKIA: Object to form. 8 announced, they went through a, another two months of 8 THE WITNESS: Yes. 9 process before they were finally, before a map was 9 BY MR. KING: 10 selected and enacted; right? 10 Q Who did you tell how the Senate maps would 11 A Correct. 11 perform politically, sir? 12 Q And so you provided to those Republican 12 A Well, considering I have clients in the 13 legislators information about how these maps would 13 legislature and in the Senate specifically, when a map 14 perform as they were deciding on which map to choose, 14 comes out, as their consultant, I would be the first 15 isn't that right, sir? 15 person they would call to ask what those, what does 16 MR. ZAKIA: Object to form. 16 this map do for them. So that would be the context in 17 THE WITNESS: Can you be more specific to 17 which I would answer those questions. 18 which maps we are discussing? 18 Q And who did you tell? Who did you discuss 19 BY MR. KING: 19 the political performance of the maps with? 20 Q We are talking about the congressional maps. 20 A I don't recall specifically, but I would be 21 Lets talk about the congressional maps first. 21 surprised if I didn't mention the performance to each 22 A Okay. 22 of the individual members about their individual 23 Q You provided information to the legislators 23 districts that are clients of mine. 24 about how those congressional maps would perform 24 Q Okay. So back in that first period at the 25 politically; isn't that correct sir? 25 start of the deposition, when you gave me the list of 13 (Pages 49 to 52) WWW.USLEGALSUPPORT.COM 954-463-2933 53 55 1 your clients in the Senate, those would have been the 1 A I occasionally got the maps a few hours 2 people that you would have discussed how their 2 before they were made public. 3 districts performed under the various maps that were 3 Q You got the maps a few hours before they 4 proposed; is that right? 4 became public? 5 MR. ZAKIA: Object to the form. 5 A Yes, sir. 6 THE WITNESS: Kind of, except some of those 6 Q How would that happen? 7 weren't in the legislature at that time. 7 A Through relationships in the legislature. 8 BY MR. KING: 8 Q You mean some of the staff members or 9 Q Okay, for the ones that were in the 9 legislators would send you the maps before they were 10 legislature at the time? 10 issued to the public? 11 A And the Senate. 11 A When they were becoming public. When they 12 Q And the Senate. And did you also discuss the 12 were becoming public. Sometimes they were made public 13 political performance of those maps with the House 13 and at that time -- I don't know, we are talking about 14 members that you represented, for the House maps? 14 minutes. 15 A For the House maps. 15 Q Minutes? 16 Q For the House maps. 16 A I don't know how quickly I got them versus 17 A Specifically. 17 they were posted online. 18 Q Yes, sir. 18 Q Could you have gotten the maps weeks before 19 A If a client called me and asked me, yes. I 19 they became public? 20 don't know that all of them did, but I'm sure I had 20 A No, sir. 21 those conversations. 21 Q You are sure about that? 22 Q And did you discuss how the maps performed 22 A I don't believe so. 23 politically with Mr. Kelly or Mr. Guthrie or Mr. Clark, 23 Q All right. And so who would send you the 24 the folks involved in the staff on the map drawers? 24 congressional maps before they became public? 25 A I don't believe so. 25 A Often at that time it would be Kirk Pepper. 54 56 1 MR. ZAKIA: Object to the form. 1 Q Kirk Pepper now. Kirk Pepper was the chief 2 BY MR. KING: 2 of staff for senator -- for Speaker of House Dean 3 Q Are you sure of that? 3 Cannon? 4 A I, I, I can't be certain, but I don't believe 4 A Yes. Yes, sir. 5 so. 5 MR. MEROS: Object to form. 6 Q Now -- 6 BY MR. KING: 7 A Now specifically, I -- never mind. That's 7 Q What was Kirk Pepper's job? 8 fine. 8 A He was chief of staff, deputy chief of staff. 9 Q If you have a concern, you want to clarify 9 Q Okay. 10 it, I will be happy to do that. 10 A To the Speaker. 11 A No, that's fine. 11 Q And so he was in a powerful position to know 12 Q Did you exchange e-mails with any of your 12 what was going on, right? 13 clients or the legislative staff members about how the 13 A I think he was, he knew what was going on 14 maps would perform? 14 most of the time. 15 A I don't recall. 15 Q Okay. And he was your friend? 16 Q Did you, did you get the maps when they 16 A Yes, he is a friend. 17 became public? Is that when you first saw the maps? 17 Q And his, his boss was your client, right? 18 MR. MEROS: Excuse me. Can you tell me, when 18 A Yes, sir. 19 you say the maps -- 19 Q And so you all were social friends? 20 MR. KING: Very good objection. I accept. 20 A Yes, sir. 21 BY MR. KING: 21 Q And business friends, right? 22 Q Let's start with the congressional maps. And 22 A Yes, sir. 23 when the congressional maps came out, when they became 23 Q And so why would Mr. Pepper want you to have 24 public, is that when you started analyzing them to see 24 these maps before the public got them? 25 how they would perform politically? 25 MR. ZAKIA: Object to form. 14 (Pages 53 to 56) WWW.USLEGALSUPPORT.COM 954-463-2933 57 59 1 BY MR. KING: 1 BY MR. KING: 2 Q Did he tell you? 2 Q Didn't they send out press releases that 3 A As a consultant with clients, it takes a 3 touted how open the process was? 4 significant amount of time to look at each individual 4 A Yes, sir. It was. 5 district. And my phone was going to ring as soon as my 5 Q And didn't one of the things they tout was 6 client saw the maps and ask me what they thought of 6 the fact they were doing this blind of the political 7 their districts. 7 performance of these districts? 8 It merely gave me time to be able to give 8 A I believe they were. 9 them a coherent answer. 9 Q Well, they weren't, they were until they got 10 Q And when the question was, what they thought 10 ahold of you and you told them about the political 11 of the districts, you interpreted that to mean how 11 performance; right? 12 would the districts perform from a voting standpoint; 12 MR. MEROS: Object to form. 13 is that right? 13 THE WITNESS: I think that there is a 14 A Not just that necessarily, no, sir. 14 difference between an individual member asking 15 Q Well, wouldn't that be the most important 15 about their own district versus asking about the 16 consideration on your client's mind? 16 performance of the map in total. 17 MR. MEROS: Object to the form. 17 BY MR. KING: 18 MR. ZAKIA: Object to the form. 18 Q Is that the way you read the constitution? 19 THE WITNESS: I can't read my client's mind, 19 MR. ZAKIA: Object to form. 20 but there are other issues that are important. 20 THE WITNESS: I'm just, I'm not, I'm just 21 BY MR. KING: 21 saying if someone called and asked -- I represent 22 Q Are there other issues more important than 22 them -- 23 getting them reelected? 23 BY MR. KING: 24 A Well, I mean there are other circumstances 24 Q Right. 25 where they could be drawn into another Republican -- 25 A -- on a campaign perspective. 58 60 1 them and another Republican senator being in the same 1 Q Right, and -- 2 district. So I mean that would be -- 2 A I think it is fair for them to ask me what 3 Q So that's another consideration? 3 does this mean to me. That -- 4 A Yes, that's what I'm saying. It is not 4 Q Right? 5 strictly performance. There are other issues. 5 A -- that doesn't mean that they necessarily 6 Q It is important to try to get them a district 6 are trying to change it. 7 where they don't have to run against another incumbent, 7 Q And you understood that other Republican 8 right? 8 clients were asking their political consultants the 9 MR. ZAKIA: Object to form. 9 same thing that they were asking you, right? 10 THE WITNESS: I don't know if "get them a 10 MR. MEROS: Object to the form. 11 district" is the right terminology. That's the 11 MR. ZAKIA: Object to the form. 12 word you are using. 12 THE WITNESS: I have no idea what they were 13 BY MR. KING: 13 discussing. 14 Q That's what's going on, isn't it? 14 BY MR. KING: 15 A The maps are being drawn by the legislature. 15 Q Because you and your other friends among the 16 Q Right. The maps are being drawn by some of 16 political consultants were sharing this performance 17 the same people that you represent, right? 17 data as these new maps were coming out, right? 18 MR. MEROS: Object to form. 18 MR. ZAKIA: Object to form. 19 THE WITNESS: Yes, sir. 19 THE WITNESS: In some cases. 20 BY MR. KING: 20 BY MR. KING: 21 Q And the legislature took a big position that 21 Q Right. I mean, as a map, as you first got a 22 this was like the most open process that had ever 22 glimpse of the map, the first thing you wanted to do 23 occurred in redistricting, didn't they? 23 was find out how is this map going to politically 24 MR. ZAKIA: Object to form. 24 perform; right? 25 THE WITNESS: I believe that it was. 25 A Not, not specifically in total; but I had 15 (Pages 57 to 60) WWW.USLEGALSUPPORT.COM 954-463-2933 61 63 1 clients that I represented that I needed to know how 1 the lead on the congressional districts, weren't they? 2 their individual districts were going to perform. 2 A I don't know that was the case. 3 Q So that is why you wanted the map as quickly 3 Q Okay. Anyway, they would he release a bunch 4 as you could get it, isn't that right? 4 of maps. You would get them and study them and 5 A So I could answer questions. 5 determine how they would perform, right? 6 Q Sure. In your business, knowledge is power; 6 A I studied maps, yes. 7 right? 7 Q Then you would provide information to 8 A I mean -- 8 Mr. Pepper. And then decisions would be made and a 9 Q Knowledge is fungible, right? It is 9 bunch of the maps, the congressional maps would be 10 saleable, right? 10 discarded and they would move forward with one of the 11 MR. ZAKIA: Object to form. 11 maps; right? 12 THE WITNESS: It is important to know. 12 MR. MEROS: Object to form. 13 BY MR. KING: 13 MR. BROWN: Objection, argumentative. Go 14 Q Right, okay. And so that is why it worked 14 ahead. 15 very well for you to get copies of these maps as 15 THE WITNESS: I don't recall what the whole 16 quickly as possible; right? 16 process was. I was not as involved in discussions 17 A Yes, sir. 17 about congressional maps. So I, I, I don't recall 18 Q Did you ask Mr. Pepper to send those maps to 18 how many maps were released. I don't recall what 19 you as soon as he could? 19 conversations and, I mean, I don't, that was, I 20 A Yeah, sure. 20 don't recall that. 21 Q You wanted to see them? 21 MR. BROWN: It has been about an hour. I 22 A When he could, when they were available. 22 think we need to take a break so the witness can 23 Q And you would tell Mr. Pepper how the maps 23 stretch his legs. 24 politically performed, isn't that right? 24 MR. KING: How long do the tapes last? 25 A No, sir, I don't believe that -- I don't 25 THE VIDEOGRAPHER: Two hours. 62 64 1 recall having those conversations with him. 1 MR. KING: Two hours? Okay. Well, if you 2 Q Isn't it, let me ask you again, sir, just so 2 want to take a break, sure. 3 we will be very clear on the record. 3 THE VIDEOGRAPHER: The time is 10:30 a.m. We 4 A All right. 4 are off the record. 5 Q Isn't it a fact, sir, that you and Kirk 5 (Brief recess.) 6 Pepper over and over again talked about how these maps 6 THE VIDEOGRAPHER: The time is 10:42 a.m. We 7 would politically perform? 7 are back on the record. 8 MR. MEROS: Object to form. 8 BY MR. KING: 9 THE WITNESS: I don't recall having specific 9 Q Okay, sir. I want to establish the context. 10 conversations about how the maps performed with 10 I want to ask you about some events early in December 11 Kirk Pepper, no. 11 of 2010. 12 BY MR. KING: 12 A Okay. 13 Q Well, if not oral conversations, e-mails? 13 Q You remember that the vote occurred in 14 Did you send e-mails back and forth discussing how the 14 November, right? 15 maps would perform? 15 A Yes, sir. 16 A I don't recall having e-mail back and forth 16 Q The amendments were passed, right? 17 about performance specifically. 17 A Yes, sir. 18 Q And you know, you knew that these maps were 18 Q Lawsuits were filed, right? 19 going through an iterative process, right? In other 19 A Yes, sir. 20 words, a bunch of maps would be released, congressional 20 Q Okay. And do you remember going to a 21 maps, let's say the congressional maps would be 21 redistricting meeting at the offices of the Republican 22 released, right, several of them? 22 Party of Florida? 23 A There were different, on the congressionals 23 A Yes, sir. 24 there were both House and Senate. 24 Q Okay. And let me show you Exhibit 2 -- 25 Q All right. But the House was sort of taking 25 (Whereupon, the document was marked as 16 (Pages 61 to 64) WWW.USLEGALSUPPORT.COM 954-463-2933 65 67 1 Deposition Exhibit No. 2.) 1 BY MR. KING: 2 BY MR. KING: 2 Q To talk about redistricting? 3 Q -- which is a composite group of e-mails that 3 MR. ZAKIA: Object to form. 4 you produced for us. Is that right? 4 THE WITNESS: You can ask Mr. Heffley that. 5 A Yes, sir. 5 BY MR. KING: 6 Q All right. These are Reichelderfer 14 6 Q Well, he did, didn't he? 7 through 19 on the Bates stamps, and Exhibit 2. Okay? 7 A Yes, sir. 8 A Yes, sir. 8 Q Is that a little unusual? To have a meeting 9 Q And you see that those e-mails pertain to a 9 at the Republican Party of Florida conference room, the 10 period of time, December 1 and December 2 of 2010, 10 chairman's conference room, with staffers from the 11 leading up to a meeting on December 3, 2010; right? 11 legislature to talk about redistricting? 12 A Yes, sir. 12 A I don't know. 13 Q Okay. Now, what was the purpose of that 13 Q But, of course, those staffers worked for 14 meeting, sir? 14 your client, or at least Mr. -- Mr. Kelly worked for 15 A The purpose of that meeting was to get 15 your client, Dean Cannon; right? 16 together and discuss what it means to the redistricting 16 A Yes, sir. 17 process now that Amendments 5 and 6 have passed. 17 Q And so if you all wanted Mr. Kelly to show 18 Q Well, now, it appears that Mr. Rich Heffley 18 up, I guess he showed up, right? 19 called that meeting; is that right? 19 MR. MEROS: Object to form. 20 A I believe so. That's who the e-mail is from, 20 MR. ZAKIA: Same objection. 21 so I guess that would be the case. 21 THE WITNESS: I don't know that specifically. 22 Q All right. And he said we are going to have 22 BY MR. KING: 23 the lawyers and the staff on to brain storm, right? 23 Q And so also among the political consultants, 24 A Yes, sir. 24 besides yourself and Mr. Heffley, were Frank 25 Q And then on the last page of that Exhibit 2, 25 Terraferma, right? 66 68 1 Reichelderfer 19, there is a list of who were going to 1 A Yes, sir. 2 attend the meeting. Right? 2 Q Another partisan Republican consultant, 3 A Yes, sir. 3 right? 4 Q And on this list is basically a who's who of 4 A He was, at that point I think had moved into 5 political consultants in Tallahassee, right? 5 actually work for the Republican Party of Florida. He 6 A Yes, sir. 6 was no longer an outside consultant. 7 Q Republican consultants. 7 Q Okay. So that would be the definition of a 8 MR. BROWN: Object to form. Settle down. 8 partisan, right? He was working for the Republican 9 BY MR. KING: 9 Party, right? 10 Q I mean, this is a who's who of Republican 10 A Those are your words, yes, sir. 11 political consultants, right? 11 Q Well, wouldn't you agree with me? 12 MR. MEROS: Object to form. 12 A I mean, I don't know that I agree with your 13 THE WITNESS: If you say so. 13 phraseology of the question. 14 BY MR. KING: 14 Q But he was certainly, just like you, 15 Q Well, wouldn't you agree with me? 15 committed to advancing the interests of the Republican 16 A They are Republican political consultants. 16 Party; right? 17 There is also some lawyers and staff, so I wouldn't say 17 A He was working for the Republican Party of 18 -- 18 Florida. 19 Q But lets identify the political consultants. 19 Q And just like you, he was interested in 20 We've got Mr. Heffley, who has called the meeting, 20 advancing the interests of Republican candidates for 21 right? 21 office in the legislature and in the Congress of the 22 A Yes, sir. 22 United States; right? 23 Q Now, he has the ability to summon staff 23 MR. MEROS: Object to form. Sorry. Go 24 members from the legislature to a meeting? 24 ahead. 25 MR. ZAKIA: Object to the form. 25 THE WITNESS: You would have to ask Frank 17 (Pages 65 to 68) WWW.USLEGALSUPPORT.COM 954-463-2933 69 71 1 Terraferma that question. 1 A The Senate campaign committee for the Senate. 2 BY MR. KING: 2 Q Is that, is he then a political consultant? 3 Q Do you have any reason to doubt he would be 3 Does he do it for money from the various campaigns? 4 as interested as you were in electing Republicans? 4 A No, he works for the party. 5 A I don't have a reason to doubt that, but I 5 Q He works for the party. He is paid by the 6 don't -- also am not a mind reader. 6 Republican Party of Florida. 7 Q Okay. And Pat Bainter, Pat Bainter was a 7 A He is the administrator over Senate campaigns 8 solid, loyal Republican political consultant; right? 8 at the party. 9 A To the best of my knowledge. 9 Q So at this meeting we had two employees of 10 Q All right. And he was part of the group 10 the Republican Party. That would be Joel Springer and 11 that, from that time on you shared information about 11 Frank Terraferma, right? 12 redistricting with, right? 12 A Andy Palmer may have still been an employee 13 A We communicated about redistricting, yes. 13 of the Republican Party. 14 Q Right. And from the time of this early 14 Q Right. I just saw that myself. So now we 15 meeting in December of 2010, you shared information 15 have three members of the Republican -- employees of 16 with Mr. Heffley and Mr. Terraferma about the 16 the Republican Party of Florida at this meeting; right? 17 redistricting process and the results; right? 17 A Well, I don't have a direct recollection of 18 A Yes, sir. 18 which one of these people actually attended the 19 Q And you and Mr. Heffley and Mr. Terraferma 19 meeting. This was expected participants. I don't know 20 and Mr. Bainter shared information about how these 20 that I can say for certainty each one of these members 21 proposed districts would perform politically; isn't 21 were there. 22 that right, sir? 22 Q Do you have any reason to believe that any of 23 A Certainly not at the time of this meeting. 23 them didn't show? 24 This meeting, this meeting -- 24 A I don't have any reason to believe they 25 Q Well, we didn't have any maps yet. 25 didn't show either, but I don't think it was a hundred 70 72 1 A Not only did we not have maps, there was no 1 percent participation. 2 census data or anything. So at the time of this 2 Q All right. And then you had Chris Clark and 3 meeting none of that was available -- 3 Alex Kelly, right? 4 Q But as you went forward -- 4 A Yes, sir. 5 MR. BROWN: Excuse me, let the witness answer 5 Q They were legislative employees of the State 6 the question. 6 of Florida, right? 7 BY MR. KING: 7 A I don't know at that particular exact time. 8 Q You are exactly right. My apologies. You 8 They ultimately were, but I don't know if they were -- 9 can go ahead and finish your answer if you have 9 for certain if they were or not at that point. 10 something else to say. 10 Q Well, why would you have them to the 11 A At the time of this meeting, it was well 11 meeting -- strike that. 12 before there were anything, no census data, no map 12 Weren't they already involved in 13 drawing software, nothing. 13 redistricting work for their employers? 14 Q But later there were maps and there was 14 A I don't know what time, I don't know on the 15 census data, you shared that information with these 15 timeline when they started that work, no, sir. They 16 other political consultants; isn't that right, sir? 16 may have been, they may not. I don't know. 17 A Yes, sir, I think I already answered that 17 Q Why do you suppose those two fellows were 18 question. 18 chosen to come to the meeting? 19 Q All right. Now, also present at this meeting 19 MR. ZAKIA: Object to form. 20 was Joel Springer. And how would you characterize his 20 THE WITNESS: I didn't call the meeting. You 21 involvement in the meeting? 21 would have to ask Rich Heffley. 22 A He was the head of Senate campaigns of the 22 BY MR. KING: 23 Republican Party of Florida. 23 Q Were you surprised to see Mr. Clark and 24 Q All right. Well, then he is another, you say 24 Mr. Kelly at the meeting? 25 he was the head of the Senate campaigns. 25 A Again, I don't, this is two years ago. I 18 (Pages 69 to 72) WWW.USLEGALSUPPORT.COM 954-463-2933 73 75 1 can't remember. I don't remember whether either of 1 Q And at this meeting who was Mr. Ginsberg 2 them or both of them were there or not. 2 representing? 3 Q Okay. Is it a normal thing for a House 3 A I don't recall whether or not -- Mr. Ginsberg 4 staffer like Mr. Kelly to come to a meeting with a 4 I know wasn't present. I don't know if he was on the 5 bunch of political consultants and lawyers at the 5 phone or not, but I don't think he was in the room. 6 Republican Party of Florida offices? 6 Q Okay. You think he might have been on the 7 MR. ZAKIA: Object to form. 7 phone? 8 THE WITNESS: Again, I already stated that I 8 A There was a conference call. And I think, 9 don't know that they were actually employed by the 9 as, if you, if you read the e-mail, it says 10 House at that particular moment in time. 10 specifically that people were going to join -- for 11 BY MR. KING: 11 those of you dialing in, so that's the other reason. I 12 Q Okay. So your thinking is that maybe 12 don't know who was there and who wasn't there because 13 Mr. Kelly and Mr. Clark weren't employed by the House 13 there was a phone like this. 14 and the Senate at that time? 14 Q Some people did phone in? 15 A I would say this. The meeting was two years 15 A I didn't know who was on the other end of the 16 ago. I don't recall if one or both of them were there 16 line or not. So I can't confirm who was or wasn't 17 or weren't there. And I don't know whether or not they 17 participating. 18 were specific -- who they were specifically employed by 18 Q Okay. And but my question back to you again 19 at that particular moment in time. So I mean, I don't 19 was, do you know who Mr. Ginsberg was representing in 20 know how else to answer the question. 20 that meeting? 21 Q Well, as it turned out, both of those fellows 21 A I don't know. I don't know. 22 were very involved in redistricting; right? 22 Q Who his client was? 23 A Ultimately, yes. 23 A I don't know. 24 Q And you think that was just a coincidence 24 Q All right. And then Mr. Meros and Mr. Bardos 25 that they were invited to the meeting back in December 25 were there, as well, or at least invited to 74 76 1 of 2010? 1 participate; is that right? 2 A I don't recall. 2 A That's the case, yes, sir. 3 Q And then also invited to the meeting 3 Q And do you think they came? 4 evidently was a fellow named Ben Ginsberg. Do you know 4 A I don't, again, I don't recall who may have 5 who that is? 5 been on the phone and who was in the room. 6 A Yes, sir. 6 Q Okay. Do you have any reason to believe 7 Q And he is a lawyer, right? 7 Mr. Meros and Mr. Bardos weren't there or weren't on 8 A Yes, sir. 8 the phone? 9 Q From Washington DC. 9 A I don't have any reason to believe that 10 A Yes, sir. 10 either. 11 Q Patton and Boggs, right? 11 Q Okay. And did you say one of the main 12 A Yes, sir. 12 reasons was to talk to the lawyers to try to figure out 13 Q And he is sort of the Republican 13 how to deal with these amendments? 14 redistricting national lawyer, isn't that right? 14 MR. BROWN: Object to the form of the 15 MR. ZAKIA: Object to form. 15 question. Go ahead. 16 THE WITNESS: I, I don't know enough about 16 THE WITNESS: Yeah, I would say that I don't 17 him to know specifically that is his role; but I 17 agree with the way you worded the question. 18 know he is at least knowledgeable on the subject. 18 BY MR. KING: 19 BY MR. KING: 19 Q Okay. Where did I go wrong? 20 Q Why was he there? 20 A You said deal with these amendments. I think 21 A Specifically, I think that the lawyers were 21 it was comply with the amendments. 22 involved to help determine how best to comply with 22 Q Comply with the amendments -- 23 Amendment 5 and Amendment 6, and to help lay out 23 A Would be -- 24 guidelines as to what, you know, the ground rules 24 Q Consider the amendments. 25 should be going forward. 25 MR. MEROS: Excuse me. You guys keep talking 19 (Pages 73 to 76) WWW.USLEGALSUPPORT.COM 954-463-2933 77 79 1 over each other. Please don't do that. 1 A I don't recall if I created all of this or 2 BY MR. KING: 2 not. Those were general questions early in the process 3 Q All right. We will try to do better. We 3 before we got any data. Probably may have been 4 will try to do better. 4 questions from a variety, that I probably wrote that. 5 Who to your understanding were Mr. Meros and 5 Q So you wrote Exhibit 3, in your opinion? 6 Mr. Bardos' client? 6 A I believe I did. 7 MR. MEROS: Object to form. 7 Q All right, good. But your testimony is, I 8 THE WITNESS: I mean, I don't, I think they 8 think, that you didn't have this document for this 9 were probably representing the House. I don't 9 meeting on December 3, 2010. You didn't have Exhibit 3 10 know that for certain, though. 10 for the meeting in December of 2010? 11 BY MR. KING: 11 A No, sir. These were questions that were 12 Q Tell me what you remember about that meeting. 12 probably spawned from that meeting. 13 A There was a specific conversation about going 13 Q Okay. All right. Well, then back to the 14 forward on the redistricting process on the issue of 14 meeting. The consultants were interested in finding 15 privilege, and what conversations would or would not be 15 out what conversations they could have about this 16 privileged, and how that would work. I think there was 16 amendment that would be privileged; is that right? 17 some discussion generally about that. 17 A Yes, sir. 18 And then there was going to be a follow-up on 18 Q Because they wanted to protect what they were 19 kind of, I think there were a list of questions. That 19 saying about this amendment to people? 20 is the one that sticks out. 20 A No, sir. I don't believe so. 21 Q What was your interest in determining what 21 Q Then why would you be interested in what 22 conversations would be privileged? What was that 22 conversations would be privileged? 23 about? 23 A I think there is a variety of conversations 24 A I think that the conversations, you know, on 24 in this process unrelated to drawing the maps that are 25 legal issues, whether or not we could discuss 25 legitimate considerations. 78 80 1 Amendments 5 and 6 and be involved in the process as 1 Q Were you trying to figure out how you could 2 consultants, from whatever capacity, was discussed. 2 have conversations with Mr. Kelly and Mr. Clark that 3 Q So you were looking to the lawyers for advice 3 would be privileged? 4 about that? 4 MR. MEROS: Object to form. 5 A I think there was a discussion about what 5 THE WITNESS: No, sir. I think more of the 6 conversations could be, privilege could be attached, 6 conversations with lawyers, not necessarily with 7 and what conversations couldn't. 7 them. 8 MR. KING: I show you, sir, Exhibit 3. 8 BY MR. KING: 9 (Whereupon, the document was marked as 9 Q Well -- 10 Deposition Exhibit No. 3.) 10 A Wouldn't have to be a conversation -- 11 BY MR. KING: 11 Q Well, why would this have been of interest to 12 Q And ask you if that was, which was produced 12 Mr. Kelly and Mr. Clark? How would they be involved in 13 by you, is that an agenda for the meeting we were just 13 conversations about what would be privileged regarding 14 discussing about, that occurred on December 3? 14 the redistricting process? 15 A No, sir. 15 MR. ZAKIA: Object to form. 16 Q What is that document that I've just put in 16 THE WITNESS: The question you asked me 17 front of you as Exhibit 3? 17 before was -- 18 A I think this was a later document for that. 18 BY MR. KING: 19 These were questions that, that I had at one point. 19 Q Right. 20 Q These were questions you had at one point? 20 A -- what was the one thing I remembered. 21 A These were questions that, you know, were 21 Q Sure. 22 circulated with the consultant class, I think I shared 22 A I think there were a variety of conversations 23 this with, with the other consultants. 23 that took place about Amendments 5 and 6. 24 Q Okay. Did you actually draft Exhibit 3? Is 24 Q Uh-huh. 25 that your document? 25 A That's the one that I, that sticks out in my 20 (Pages 77 to 80) WWW.USLEGALSUPPORT.COM 954-463-2933 81 83 1 mind. 1 standards. How do you go about complying with language 2 Q Uh-huh. 2 that we believe conflicted within itself. 3 A But you know, so there could be a variety of 3 So that was probably the overarching theme 4 other subjects that may have been more relevant. 4 from the lawyers, how would you actually go about 5 Q Was one of the subjects that was discussed at 5 complying with 5 and 6. 6 that meeting, was how we could get our, protect our 6 And that's, and you know, for example, you 7 Republican incumbents with the redistricting process? 7 could use some of these questions in this memo that I 8 MR. MEROS: Object to form. 8 have here. You know, measure of compliance, rank the 9 THE WITNESS: I don't recall specifically. 9 criteria. 10 BY MR. KING: 10 I mean, do you prevent retrogression in 11 Q Was there a discussion at that meeting about 11 minority districts, favor or disfavor party or 12 how you political consultants could work with Senate 12 incumbent. You know, retrogression in minority 13 staffers to provide them information about the 13 districts was a big issue that was discussed. 14 political performance in the redistricting process? 14 The constitution says where feasible you 15 MR. MEROS: Object to the form. Go ahead. 15 should use existing political and geographic 16 MR. ZAKIA: Join. 16 boundaries. What's the interpretation of that? Is it 17 THE WITNESS: I don't recall that 17 city or county boundary and why? How much importance 18 specifically, no. 18 should be placed on these two? Are they equal with 19 BY MR. KING: 19 roads and rivers? What about existing district 20 Q Do you deny that it occurred? 20 boundaries and other options? 21 A I don't deny that it occurred, but I don't 21 Those are the kind of conversations that, you 22 recall specifically either. 22 know, had to be answered in an amendment that didn't 23 Q Okay. Did you discuss how you might be -- 23 really clearly stipulate some of those technical 24 strike that. 24 issues. 25 Did you discuss at this meeting that the 25 Q But didn't the legislature take the position 82 84 1 position the party was going to take was that this 1 they were going to deal with all those issues without 2 effort by the legislature at redistricting was going to 2 dealing with political consultants to do it, though? 3 be done in an open way without any consideration of 3 MR. MEROS: Object to the form. 4 political performance? 4 MR. ZAKIA: Same objection. 5 A I'm sorry, can you repeat that question? 5 THE WITNESS: I don't know specifically. 6 Q Sure. Did you discuss in this meeting that 6 This was an early conversation -- 7 the redistricting effort was going to be presented as 7 BY MR. KING: 8 an effort that would not consider political 8 Q Right. 9 performance? 9 A -- with lawyers before that process. 10 A I'm sorry. One more time. 10 Q Right. 11 Q Sure. At the meeting did you talk about the 11 A Again. 12 way the House and the Senate was going to approach 12 Q Before that process began, it gave an 13 redistricting under the amendments? 13 opportunity for you political consultants to make your 14 A Yes. 14 views known about it to the staffers that ultimately 15 Q Okay. And what do you remember about that? 15 would be working on the redistricting, right? 16 A I would say the general premise, which was 16 A I don't believe that anybody thinks whether 17 the opposition to 5 and 6, we believed that the 17 or not you use a road or a county or a city boundary 18 language was drafted to be impossible to comply with, 18 would somehow favor, disfavor, or I mean it is kind of, 19 for the purposes of then putting it into the court's 19 it is kind of, I mean -- 20 hands to draw these maps. 20 Q Right. 21 So the various conflicting standards and 21 A -- it is kind of eight, seven months prior to 22 different things, that was that generally. At this 22 maps being drawn. 23 first meeting it was the first time after 5 and 6 where 23 Q But you all thought it was a good idea to 24 there was able to be an open conversation about can you 24 meet both with the political consultants and the 25 physically comply with 5 and 6, are these conflicting 25 lawyers with these two employees of the Senate -- of 21 (Pages 81 to 84) WWW.USLEGALSUPPORT.COM 954-463-2933 85 87 1 the legislature, light? 1 measured by how the seats are held, right? 2 A I think I previously said I can't confirm 2 MR. MEROS: Object to form. 3 whether or not at that time frame they were or were 3 MR. ZAKIA: Same objection. 4 not. In fact, I don't know. 4 THE WITNESS: I thought I just answered that 5 Q And of course, was one of the things you 5 question. 6 talked about, what was your opponent's likely legal 6 BY MR. KING: 7 challenges and how do we limit their chances for 7 Q Right. But what you and your other political 8 success? 8 consultant friends were all about was holding these 9 A Again, this document was created after that 9 seats in the legislature and the Congress for 10 meeting, not before it. So I think, I think complying 10 Republicans; weren't you, sir? 11 with the constitution is the best way to limit their 11 MR. MEROS: Object to form. 12 chances for success. I think that's what we attempted 12 MR. ZAKIA: Object to form. 13 to do. 13 THE WITNESS: I don't know that I would 14 Q Who were your opponents? Who did you view 14 exactly identify with your characterization. 15 your opponent as? 15 BY MR. KING: 16 A The plaintiffs sitting across the table. 16 Q Okay. And where did I go wrong? 17 Q Okay. The people that were the proponents of 17 A Repeat the question again. 18 the amendment? 18 Q Isn't it correct, sir, that your ultimate 19 MR. MEROS: Object to form. 19 goal in this process was to secure as many seats for 20 THE WITNESS: I suppose maybe the advocates 20 Republicans in the legislature and the Congress as you 21 to the -- I don't know. I don't know 21 could? 22 specifically. Whoever was going to bring forward 22 MR. MEROS: Object to form. 23 the legal challenge. It could be a variety of 23 MR. ZAKIA: Same. 24 groups or parties. 24 THE WITNESS: With compliance of the Florida 25 BY MR. KING: 25 Constitution. 86 88 1 Q Well, you considered -- 1 BY MR. KING: 2 A Ultimately, I think the Democrats were going 2 Q But, of course, you had already been told 3 to be behind that, but. 3 that it just really wasn't possible to comply with 4 Q Isn't it correct, sir, that you considered 4 these new amendments; right? 5 your opponents to be the proponents of these 5 MR. MEROS: Object to form. 6 amendments? 6 THE WITNESS: I think there were different 7 MR. MEROS: Object to form. 7 arguments about that, but -- 8 MR. BROWN: Argumentative and asked and 8 BY MR. KING: 9 answered. Go ahead. 9 Q And then another topic that you got here on 10 THE WITNESS: More so probably the Democratic 10 your list is communication with outside non-lawyers? 11 party than the proponents of the amendment. 11 How can we make that work? What do you mean by that, 12 BY MR. KING: 12 sir? 13 Q And the success you were talking about is 13 A That goes to the communication related to 14 ultimately the control of these seats and the 14 privilege that was brought up. 15 legislature and the Congress, right? 15 Q Okay. So you wanted to be able to tell 16 MR. MEROS: Object to form. 16 non-lawyers things that you didn't want people to know 17 MR. ZAKIA: Same. 17 about, right? 18 THE WITNESS: The success was fighting off 18 A No, not non-lawyers. Non-lawyers would be 19 legal challenges, not the success of the district. 19 the consultants that would be us not telling 20 Success would be of any challenges to the maps 20 non-lawyers things. 21 being defeated in a court of law because the 21 Q Okay. So the consultants wanted to be able 22 legislature properly complied with the 22 to communicate with the staff without people knowing 23 constitution. 23 about what you were saying, right? 24 BY MR. KING: 24 MR. MEROS: Object to form. 25 Q The ultimate success, of course, though is 25 MR. ZAKIA: Same objection. 22 (Pages 85 to 88) WWW.USLEGALSUPPORT.COM 954-463-2933 89 91 1 THE WITNESS: You know, not necessarily 1 A No, sir. 2 staff's specifically, but just communications 2 MR. MEROS: Object to the form. 3 about participating in the process. 3 THE WITNESS: No, sir, that's not what I 4 BY MR. KING: 4 said. 5 Q Right. You wanted to be able to participate 5 BY MR. KING: 6 in the process, you consultants, but you didn't want 6 Q Well, isn't that one of the reasons that you 7 anybody to know what you were saying or doing, right? 7 all discussed at that meeting that people should start 8 A I suppose that would be a fair 8 using their personal e-mail accounts? 9 representation. 9 A I never said that was discussed at the 10 Q Thank you, sir. And so, you were asking the 10 meeting. 11 lawyers how you could do that, right? 11 MR. MEROS: Object to the form. 12 MR. MEROS: Object to form. 12 BY MR. KING: 13 THE WITNESS: Right. 13 Q Well, wasn't it discussed at the meeting? 14 BY MR. KING: 14 A I don't recall it being discussed, no. 15 Q Right? 15 Q Didn't you all come up with the notion that's 16 A Correct. 16 one way we can communicate with staffers, if they use 17 Q And what did they tell you? 17 their personal e-mail accounts, rather than their 18 A There was some research done. And then there 18 Senate e-mail addresses or their House e-mail 19 was, it was determined it couldn't be done. 19 addresses? 20 Q It couldn't be done? 20 MR. MEROS: Excuse me. Object to the form. 21 A They determined there was no way to attach 21 You said you all. Could you tell me what you 22 privilege to those conversations. And it was at that 22 mean? 23 point that conversations about redistricting 23 BY MR. KING: 24 specifically ended. 24 Q Sure. The consultants that were involved 25 Q Let me make sure I get this straight. So the 25 that got this advice from the lawyers about how they 90 92 1 issue was raised, how can we talk to other people and 1 could keep their, or tried to get the advice about 2 not, people not know what we are saying or doing. And 2 whether they could keep what they said privileged and 3 so you wanted to try to attach privilege to that, 3 quiet. 4 right? 4 Those fellows, did you all discuss among 5 A Yes, sir. 5 yourselves and with the staffers that one way to maybe 6 Q But, and so the lawyers went off and actually 6 be able to communicate with the staff without anybody 7 did research to try to figure out how you political 7 knowing about it was to use personal e-mails. 8 consultants could talk to people involved in this 8 MR. BROWN: Object. Argumentative. Go 9 redistricting process and keep what you said secret and 9 ahead. 10 unknown, right? 10 THE WITNESS: No, sir, I don't recall the 11 A I don't know that they did research. I don't 11 conversation about private e-mails ever being 12 know what specific process they went through. I just 12 discussed. 13 know the answer came back and the answer was, couldn't 13 BY MR. KING: 14 do it. 14 Q Well, didn't you notice that people started 15 Q So you finally were told that whatever you 15 using their personal e-mails, hot mail and gmail and 16 say to people involved in the redistricting process, as 16 things like that, not their regular e-mail accounts? 17 political partisan political consultants, it is going 17 A I don't know -- 18 to come out and have to see the light of day; right? 18 MR. ZAKIA: Object to the form. 19 A Yes, sir. Which is why I'm sitting here 19 THE WITNESS: You use the question start, I 20 today. 20 don't know that wasn't the e-mail that was used 21 Q All right. And so the political consultants 21 prior to. And in some cases, you know, that's the 22 face the future under that restriction, right? 22 e-mail that was used because they have different 23 A Yes, sir. 23 jobs. And I've been using the same e-mail. 24 Q And you tried to figure out how you could 24 Whether or not they went to work here, went to 25 keep what you were doing unknown by the public, right? 25 work there, went to work there. Just the e-mails 23 (Pages 89 to 92) WWW.USLEGALSUPPORT.COM 954-463-2933 93 95 1 that they had. 1 the House map and vice versa. There were some 2 BY MR. KING: 2 discussions whether or not, in order to comply 3 Q So you weren't -- 3 with 5 and 6, whether it made more sense for both 4 A I don't know that there was, I don't recall 4 to draw each other's maps and their own maps or 5 any conversations specifically about, hey, do this to 5 not. 6 conceal things. That was just what was used before and 6 It was really just a question, do you do 7 what was used after. 7 that, or don't you, for the purposes of trying to 8 Q Okay. Well, of course, the conversation that 8 comply with the amendment. 9 you had with the lawyers was how you could conceal your 9 BY MR. KING: 10 conversations with folks, right? 10 Q Ultimately, did you discuss the issues on 11 MR. ZAKIA: Object to form. 11 this Exhibit 3 with Dean Cannon? 12 MR. MEROS: Object to form. 12 A I don't, I don't recall specifically. 13 THE WITNESS: I believe it was specifically 13 Q You don't recall whether you gave him advice 14 about attached privilege to any conversations. 14 about whether or not the House should do a Senate map 15 BY MR. KING: 15 or not? 16 Q Yeah, whether privilege would help you 16 A Oh, specifically on that issue? 17 conceal conversations you had, right? 17 Q Yes. 18 MR. MEROS: Objection. 18 A I may have had a conversation, but I don't, I 19 MR. ZAKIA: Same objection. 19 don't recall specifically. 20 THE WITNESS: I think I just answered that. 20 Q Do you remember advising Dean Cannon about 21 BY MR. KING: 21 whether there should be a central Florida Hispanic seat 22 Q Right, and they said it wouldn't work? 22 or not, pros and cons? 23 A They said there was no way to attach 23 A Again, I don't recall specifically. 24 privilege. 24 Q You wouldn't deny that you had that 25 Q Well, at this meeting were you all sitting 25 conversation with him, would you? 94 96 1 around talking about with the lawyers and the staffers 1 MR. ZAKIA: Object to form. 2 and the four or five political consultants, employees 2 THE WITNESS: I, I don't know that I would, 3 of the Republican Party, were you sitting around 3 no, I don't know that I would know one way or the 4 talking about whether you should have a central Florida 4 other. 5 Hispanic seat or not, pros and cons? 5 BY MR. KING: 6 A Again, this document was a later document, 6 Q And you, would you have talked about all 7 so, no. 7 these issues on this page with Kirk Pepper, his 8 Q That didn't come up at the meeting? 8 staffer? 9 A I don't believe we talked specifically about 9 MR. BROWN: Object to form. Would you or did 10 maps at that meeting. We didn't even have census data 10 you. 11 at that point. 11 BY MR. KING: 12 Q Okay. Well, did you talk about procedure 12 Q Okay. Did you talk to Kirk Pepper about 13 like should the Senate do a House map or vice versa? 13 these issues? 14 A Not at that particular point in time, no. 14 A I don't recall specifically whether I did or 15 Q That's something that came up later? 15 did not. 16 MR. ZAKIA: Object to form. 16 Q Do you remember anything else about this 17 THE WITNESS: I remember generally, and I 17 meeting of December 3rd, other than this privilege 18 don't remember whether or not, who I spoke with 18 issue specifically? 19 about -- there was the general discussion from a 19 MR. MEROS: Object to form. 20 procedure standpoint whether or not it made more 20 THE WITNESS: I think I've answered that, no, 21 sense legally for both the House and the Senate to 21 I don't remember specifically. 22 draw separate maps, both the House -- because 22 BY MR. KING: 23 traditionally prior to redistricting, only the 23 Q Did the meeting end with plans to meet again? 24 Senate drew a map and only the House drew a map. 24 A I don't recall. 25 And they then passed, the Senate would pass 25 Q Did this group continue to meet through the 24 (Pages 93 to 96) WWW.USLEGALSUPPORT.COM 954-463-2933 97 99 1 redistricting process? 1 A I don't recall. I don't know if there was a 2 MR. MEROS: Object to form. Can you tell me 2 conference call situation. I don't even remember if 3 what you mean by this group? 3 people joined by phone. But I think it was a smaller 4 BY MR. KING: 4 group. 5 Q The group of attendees at that meeting on 5 Q But you think you went? 6 December 3rd. 6 A I went. And it may have been just me being 7 A They did not. 7 delivered the news that, hey, look, you are not 8 Q Okay. That was the last meeting that 8 included. 9 occurred? 9 Q Was Mr. Kelly or Mr. Clark there? 10 A There, I recall one other meeting. 10 A I don't recall. 11 Q Okay. When did that happen? 11 Q And so from that time forward if they had 12 A Probably within, I don't recall specifically, 12 meetings, you weren't part of them? 13 but it was let's say within a month, maybe six weeks 13 MR. MEROS: Object to form. Can you tell me 14 after that meeting. Probably January or February time 14 who you mean by "they"? 15 frame. 15 BY MR. KING: 16 Q Okay. 16 Q I'm talking about the group you were with, 17 A That meeting was, I don't think all these 17 the people that emanated from this group, the 18 participants were there. I do remember that, that 18 GrayRobinson lawyers, the House staffers, the Senate 19 there were some lawyers from GrayRobinson there. 19 staffers? 20 That's when the news was delivered that there 20 A I was not involved in any meetings with the 21 is not going to be privilege attached. That's when 21 lawyers and House staff going forward at that point. 22 anybody of the, of the political class was no longer 22 Q Okay. Did you attend anymore redistricting 23 included in meetings. 23 meetings at the Republican Party of Florida before the 24 So there may have been meetings among staff 24 bill was passed? 25 and lawyers of the House, but I was no longer included 25 MR. BROWN: Which bill are we speaking of? 98 100 1 in those meetings from that point forward. 1 MR. KING: The initial passage of the 2 Q Okay. So, so the next meeting occurred, you 2 redistricting bill. 3 think in January maybe? January, February? 3 MR. MEROS: Which redistricting bill? 4 A January, February, somewhere like that. 4 BY MR. KING: 5 Q And it occurred at GrayRobinson? 5 Q The House, Senate and congressional 6 A Yes, sir. 6 redistricting bill. 7 Q And who was present there? 7 A I don't recall specifically a meeting where 8 A I don't recall specifically. I mean, I don't 8 we were all together. Did I go to the Republican Party 9 recall. I mean which, I know there were some lawyers 9 of Florida and sit with Rich Heffley and Frank 10 there. I don't recall specifically who was there and 10 Terraferma and talk about things? Yes. 11 who wasn't. 11 Was there a formal meeting where we were 12 Q Well, of your political consultant friends, 12 called together? No. 13 was Mr. Heffley there? 13 MR. KING: All right, sir, I show you Exhibit 14 A For some reason or another I don't believe he 14 4. 15 was there. 15 (Whereupon, the document was marked as 16 Q Was Mr. Terraferma? 16 Deposition Exhibit No. 4.) 17 A I don't recall Frank being there either. 17 BY MR. KING: 18 Q Mr. Springer? 18 Q I'm sorry, I gave you the wrong copy. There 19 A I couldn't say one way or the other. 19 you go. I show you Exhibit 4, which appears to be an 20 Q Was Mr. Gardner there? 20 e-mail of December 29, 2010, from Facebook to yourself. 21 A There were no -- 21 Do you recognize that? 22 Q I'm sorry, Mr. Palmer. I apologize. I 22 A Yes. Sure. 23 misspoke. 23 Q Now, J. Alex Kelly is the fellow that is 24 A I don't, I don't recall. 24 going to be involved in the redistricting for the 25 Q Mr. Bainter, was he there? 25 House, right? 25 (Pages 97 to 100) WWW.USLEGALSUPPORT.COM 954-463-2933 101 103 1 A Correct. 1 Q Okay. 2 Q And he is now sending you an e-mail through 2 (Whereupon, the next document was marked as 3 Facebook; is that right? 3 Deposition Exhibit No. 6.) 4 A It appears to be so. 4 BY MR. KING: 5 Q Is that the way you normally communicated 5 Q Okay. I show you Exhibit 6 and ask you if 6 with Mr. Kelly before? 6 you recognize that as an April 18, 2011 e-mail from 7 A No, sir. 7 [email protected] to you. 8 Q And he is sending you some information about 8 A Yes, sir. 9 redistricting; right? 9 Q Now, do you normally e-mail back and forth 10 A No. It looks like he is asking me to follow 10 with Kirk Pepper to his gmail address? 11 MyDistrictBuilder, which is the development of the 11 A Generally, probably. I've been e-mailing 12 software to draw maps that the House was doing. 12 with him going back farther than his time at the House. 13 Q Okay. And so did you accept that invitation? 13 Q Okay. So he normally wouldn't use his House 14 A I don't recall whether I did or didn't. More 14 e-mail address? 15 than likely, I did. 15 A I can't answer that for him, what he would 16 (Whereupon, the next document was marked as 16 normally use or not. 17 Deposition Exhibit No. 5.) 17 Q All right. At any rate, evidently his boss 18 BY MR. KING: 18 Dean Cannon issued the appointments to the House 19 Q Next, sir, I show you Exhibit 5, and ask you 19 redistricting committee and subcommittees at 7:17 on 20 if you recognize that as a March 17, 2011 e-mail from 20 April 18; correct? 21 Alex Kelly to yourself. 21 A That's what the e-mail says, yes, sir. 22 A March 17th, yes. 22 Q And it appears that four minutes later, 23 Q And that comes from, just like Exhibit 4, 23 Mr. Pepper sent them to you, right? 24 that comes from your files or your records and 24 A That appears so, yes, sir. 25 documents; is that right? 25 Q And again, he just wants you to know who is 102 104 1 A Yes, sir. 1 involved in the redistricting process, right? 2 Q And what is Mr. Kelly sending you there? 2 MR. ZAKIA: Object to form. 3 A I believe all that is, is census data. 3 THE WITNESS: I have some clients that, you 4 Q Okay. And why is Mr. Kelly sending that to 4 know, he was probably, that I probably would be 5 you, sir? 5 curious to know some of my clients were appointed 6 A He knew I was interested in it, and probably 6 to the committee. 7 sent it to me because I had an interest in census data. 7 BY MR. KING: 8 Q And the census data is part of the building 8 Q Did you have some clients on the committee? 9 blocks of the districts, right? 9 A Yes, sir. 10 A Yes, sir. I don't recall what this is 10 Q Who were your clients on the committee? 11 specifically. I think it may have been just plus or 11 A Horner. 12 minus for the district. 12 MR. MEROS: I'm sorry, you said Horner? 13 So you have got to get a general feel for who 13 THE WITNESS: Horner, Legg, Young. Legg 14 was over and who was under, what districts needed to 14 looks like he is listed twice. Hukill is a client 15 grow, which districts needed to shrink, I think is what 15 now, but was not at that point. 16 that probably was. 16 (Whereupon, the next document was marked as 17 Q Now, you had the -- did you have the election 17 Deposition Exhibit No. 7.) 18 data in your own data? 18 BY MR. KING: 19 A No, sir. 19 Q Okay. I show you, sir, Exhibit 7, which 20 Q Where did you get election data? 20 appears to be an e-mail from Rich Heffley, April 22, 21 MR. ZAKIA: Object to form. 21 2011, to a group of people including A. Palmer, Frank 22 THE WITNESS: Election data was in the 22 Terraferma, Joel Springer, Jim Rimes, Pat Bainter and 23 software MyDistrictBuilder. And I just, I just 23 yourself. 24 used MyDistrictBuilder when I was looking at maps. 24 A Yes, sir. 25 BY MR. KING: 25 Q Do you recognize that as a document coming 26 (Pages 101 to 104) WWW.USLEGALSUPPORT.COM 954-463-2933 105 107 1 from your -- 1 Is that a document from your files, sir? 2 A Yes, sir. 2 A Yes, sir. 3 Q -- files? And this is, this is the sort of 3 Q It actually starts with an e-mail from Pat 4 information that you all would pass around between 4 Bainter to John Thrasher down at the bottom of the page 5 yourselves? 5 on Monday. Do you see that? 6 A I don't normally. I don't know normally. It 6 A Yes, sir. 7 is kind of broad. This is certainly one thing that 7 Q And it says, quote, Speaker, would it make 8 came, yes. 8 sense for you and I and Marc to get together on Monday 9 Q Who is Jim Rimes? 9 in Tallahassee to discuss all things session, 10 A He is another consultant. 10 elections, redistricting, presidency. Do you see that? 11 Q A Republican consultant? 11 A Yes, sir. 12 A Yes, he is a Republican political consultant. 12 Q So did Pat Bainter tell you why he wanted to 13 (Whereupon, the next document was marked as 13 have this meeting with you and John Thrasher? 14 Deposition Exhibit No. 8.) 14 A We are both consultants to Pat -- to John 15 BY MR. KING: 15 Thrasher. I work closely with Pat on John Thrasher's 16 Q Next here I show you Exhibit 8, and ask you 16 races. It was probably just a meeting where we were 17 if you recognize that as a May 4, 2011 e-mail from Dean 17 discussing generally, you know, issues with him. Why 18 Cannon. Do you see that, sir? 18 redistricting. I don't recall specifically what about 19 A Yes, sir. 19 redistricting. 20 Q Do you remember receiving that e-mail? 20 Q You don't have any recollection of what you 21 A Not specifically, no, sir. 21 all talked about from a redistricting standpoint? 22 Q Dean Cannon says that he needs to discuss 22 A I don't. In fact, I'm pretty sure that we 23 this with you ASAP. 23 didn't even have data and maps on June 2nd, so. 24 A Yes, sir. 24 Q Okay. By that time were you, were you aware 25 Q Do you see that? 25 that Mr. Bainter was very frustrated about these 106 108 1 A Yes, sir. 1 amendments? 2 Q Do you remember that discussion? 2 MR. ZAKIA: Object to form. 3 A I don't, no, sir. 3 THE WITNESS: I, at this point I think that 4 Q Do you remember this article which raised an 4 was well past. I think the amendments were done. 5 issue about the cost of redistricting between the House 5 I don't know that Bainter was -- I can't speak for 6 and the Senate? 6 Pat Bainter. 7 A Vaguely. I vaguely remember the issue, but I 7 BY MR. KING: 8 don't recall specifically what the conversation was 8 Q Well, did he tell you how he felt about the 9 about the issue. 9 redistricting process under the amendments? 10 Q But when these kind of issues came up 10 A I mean, we've had a lot of conversations. I 11 involving redistricting, was it unusual for Dean Cannon 11 don't know that I would characterize that as 12 to contact you and say he needs to discuss something 12 frustrated. 13 with you immediately? 13 I think, I might have been frustrated that I 14 A I think I, as a consultant to Dean Cannon, I 14 was no longer able to participate in the process via 15 was consulted on his issues related to media relations. 15 the lawyers, but I mean -- 16 And so when there was a newspaper article of some sort, 16 Q Right. 17 he would very often call me to discuss how best to 17 A -- that was, that was what was determined and 18 handle the press inquiries. 18 that's how we moved forward. 19 (Whereupon, the next document was marked as 19 Q In the next nine months, though, from June 20 Deposition Exhibit No. 9.) 20 through March or April of 2012, isn't it a fact you did 21 BY MR. KING: 21 participate in the process? 22 Q Next here I show you Exhibit 9, which is an 22 MR. ZAKIA: Object to form. 23 e-mail, appears to be an e-mail from -- the last one 23 THE WITNESS: Yes, sir. Let me go back and 24 anyway in the chain -- is an e-mail from John Thrasher 24 clarify. In the map drawing, specifically. But 25 to yourself dated June 2, 2011. 25 in the process, you know, I'm like anybody else, 27 (Pages 105 to 108) WWW.USLEGALSUPPORT.COM 954-463-2933 109 111 1 I'm allowed to advocate positions on issues before 1 at it, that this was something that Greg Evers had 2 the legislature on a whole host of issues, which 2 either written up or somebody else had written up for 3 would not exclude redistricting. 3 him? 4 BY MR. KING: 4 A I don't know specifically. 5 Q And you did advocate positions with the 5 Q Well, it reads like he was saying it. 6 legislature about redistricting during the process, 6 A Right. 7 didn't you? 7 Q But it is signed at the bottom, Warmly, Greg. 8 A Yes. 8 A It looks like a newsletter that goes out, the 9 (Whereupon, the next document was marked as 9 newsletter that goes out to supporters, it looks like. 10 Deposition Exhibit No. 10.) 10 Q Okay. So evidently Lori, watching out for 11 BY MR. KING: 11 Greg, was maybe concerned that he might be saying too 12 Q I show you Exhibit 10, and ask you if you 12 much about redistricting? 13 recognize that as an e-mail chain ending on June 25, 13 MR. ZAKIA: Object to form. 14 2011. Last one being with an e-mail from Lori Weems to 14 THE WITNESS: I mean, it appears that, I mean 15 Marc Reichelderfer. Do you see that? 15 you can read her words. 16 A Yes, sir. 16 BY MR. KING: 17 Q And is that an e-mail you received back in 17 Q Well, she says she wants to run this, quote, 18 June of, June 25, 2011? 18 "Celina, I want to run this by Marc Reichelderfer --" 19 A Yes, sir, yes. 19 MR. MEROS: Reichelderfer. 20 Q Okay. Now, do you see in this e-mail that 20 BY MR. KING: 21 Lori Weems sent an e-mail to Celina Parker? Do you see 21 Q Reichelderfer, I apologize, "because of all 22 that? 22 that we have said about redistricting. We are getting 23 A Yes, sir. 23 into some pretty specific, and frankly, sensitive 24 Q And who is Celina Parker? 24 issues that I want to make sure he and the party are 25 A She works at Bascom Communications. 25 comfortable with. I have sent it to him and am 110 112 1 Q Okay. And Bascom Communications, were those 1 awaiting his response. It is written really well. 2 the people -- strike that. 2 There are just some sensitivities in the specifics of 3 Did she advise Greg Evers, as well as Lori -- 3 the issues raised that I want to make sure he is 4 strike that. Let me start over again. Is Lori Weems 4 comfortable with." 5 Greg Evers' wife? 5 You see that language, sir? 6 A That's my understanding, yes, sir. 6 A Yes, sir. 7 Q All right. And so Greg Evers is one of your 7 Q Now, she says she wants to make sure that he 8 clients, right? 8 and the party are comfortable with. So is that 9 A Yes, sir. I did some work with Greg Evers in 9 suggesting that you are aware what the party would be 10 the past. 10 comfortable with? 11 Q And he is a Republican representative or 11 MR. ZAKIA: Object to form. 12 senator? 12 THE WITNESS: I don't know what she would 13 A Senator, yes, sir. 13 assume that that meant. 14 Q Okay. And so evidently he was giving 14 BY MR. KING: 15 information out in some sort of a weekly update to his 15 Q And when we are talking about the party, I 16 voters or his members of his district -- 16 assume you think that means the Republican Party, 17 A Right. 17 right? 18 Q -- about the redistricting process; is that 18 A Yes, sir. 19 right? 19 Q Okay. And what did she, what did you 20 A Right. Yes. 20 understand was the sensitive part of this, of what was 21 Q And evidently, this is a proposed weekly 21 in this thing? 22 update on June 24, that is attached to these e-mails, 22 A I, I don't know specifically what she thought 23 right? 23 may or may not be sensitive. This is a campaign 24 A Yes. It appears to be, yes. 24 update. And when people do campaign communications, 25 Q And was it your understanding when you looked 25 I'm very often asked prior if it is okay to a campaign 28 (Pages 109 to 112) WWW.USLEGALSUPPORT.COM 954-463-2933 113 115 1 communication going out. 1 map drawers and the people involved about the way the 2 MR. MEROS: Can with we go off the record one 2 districts line up, right? 3 minute, please? 3 MR. MEROS: Object to form. 4 MR. KING: Sure. 4 MR. ZAKIA: Same objection. 5 THE VIDEOGRAPHER: The time is 11:43 a.m. We 5 THE WITNESS: Can you ask that question 6 are off the record. 6 again? 7 (Brief pause.) 7 BY MR. KING: 8 THE VIDEOGRAPHER: The time is 11:44 a.m. We 8 Q Sure. One way you abide by that statement 9 are back on the record. 9 that you agreed with, was that the political 10 MR. KING: Would you be the governor of that 10 consultants don't get involved in the process and 11 and tell me when the five minutes are up? 11 provide information, political information to the map 12 MR. MEROS: Okay. 12 makers and legislators, right? 13 BY MR. KING: 13 MR. MEROS: Object to form. 14 Q Did you think there was something sensitive 14 THE WITNESS: I don't know that I agree with 15 about Mr. Evers saying, quote, "Ensure that Amendments 15 your assessment. 16 5 and 6 are adhered to and that all party and political 16 BY MR. KING: 17 affiliations and factors are ignored when drawing the 17 Q So you think it is okay for the political 18 lines to delineate our new legislative and 18 consultants, the partisan political consultants, to 19 congressional districts?" 19 provide that information about political line ups in 20 A No, sir. 20 the districts to the map drawers and the legislators? 21 Q Is there anything sensitive about that to 21 MR. ZAKIA: Object to form. 22 your mind? 22 THE WITNESS: Yeah, I again don't agree with 23 A No, sir. 23 that assessment either. 24 Q Is that something that you thought was 24 BY MR. KING: 25 important to be adhered to? 25 Q So you don't agree with either side of that 114 116 1 A I think that's what most people are 1 statement, right? 2 attempting. 2 A Well, no, sir. I don't. 3 Q All right. So as a Republican political 3 Q Okay. 4 consultant, you felt that it was important in this 4 MR. MEROS: One more question if you can. 5 process that all party and political affiliations and 5 MR. KING: Okay. Got you. 6 factors are ignored when drawing the lines? 6 BY MR. KING: 7 A Me, personally? 7 Q So up there at the top, Lori says, "Marc, see 8 Q Yeah. 8 below. What are your thoughts about this? I think it 9 A No. I think when you specifically say 9 is getting into some pretty specific and sensitive 10 drawing the lines, yes. 10 issues that may not be good to be in writing." 11 Q All right. So you understood from that 11 Do you see that? 12 sample that you shouldn't draw districts and shed 12 A I do see that, yes, sir. 13 Democratic voters and add Republican voters to make it 13 Q What is it about the writing of this stuff 14 better for the Republican incumbent, right? 14 that is a problem? 15 A I think that's a general assessment of the 15 MR. ZAKIA: Object to form. 16 understanding, yes. 16 THE WITNESS: I have no idea. And you know, 17 Q That's an example of how the process was not 17 I would be curious. I would be surprised if this 18 supposed to work, right? 18 didn't go out as it was written here. 19 MR. ZAKIA: Object to the form. 19 BY MR. KING: 20 THE WITNESS: I mean, yes. I think 20 Q Did you have any further conversation with 21 generally. 21 Lori about this? 22 BY MR. KING: 22 A I don't recall. 23 Q Okay. And so one way, of course, the process 23 MR. MEROS: If you don't mind -- 24 works that way is if the political consultants don't 24 MR. KING: Lets, we can go off the record. 25 get involved and provide political information to the 25 THE VIDEOGRAPHER: The time is 11:48 a.m. We 29 (Pages 113 to 116) WWW.USLEGALSUPPORT.COM 954-463-2933 117 119 1 are off the record. 1 CERTIFICATE OF OATH 2 (Whereupon, the deposition was recessed at 2 3 11:48 for lunch. This concludes Volume 1 of the 3 STATE OF FLORIDA 4 deposition of Marc Reichelderfer taken May 16, 1973.) 4 COUNTY OF LEON 5 5 6 6 I, Peggy L. Owens, Registered Professional 7 7 Reporter, Notary Public, State of Florida, certify that 8 8 MARC REICHELDERFER personally appeared before me on the 9 9 16th day of May, 2013, and was duly sworn. 10 Signed this 22nd day of May, 2013. 10 11 11 12 12 13 ______13 14 PEGGY L. OWENS, RMR, RPR 14 15 Notary Public - State of Florida 15 My Commission No. EE 88005 16 16 Expires: 8-23-15 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 118 1 C E R T I F I C A T E 2 STATE OF FLORIDA 3 COUNTY OF LEON 4 5 I, PEGGY L. OWENS, Registered Professional 6 Reporter, at Tallahassee, Florida, do hereby certify as 7 follows: 8 That I correctly reported in shorthand the 9 foregoing proceedings at the time and place stated in 10 the caption hereof: 11 That I later reduced my shorthand notes by 12 computer-aided transcription, or under my supervision, 13 and that the foregoing pages 1 through 117 both 14 inclusive, contain a full, true, and correct transcript 15 of the proceedings on said occasion: 16 That I am neither of kin, nor of counsel, to any 17 parties involved, nor am I financially interested in 18 this action. 19 THIS the 22ND day of May, 2013. 20 ______21 PEGGY L. OWENS Registered Professional Reporter 22 Registered Merit Reporter 23 24 25 30 (Pages 117 to 119) WWW.USLEGALSUPPORT.COM 954-463-2933 Page 1

A ahold 59:10 APPEARANCES 4:1 B Aaron 13:16 aide 10:8 11:4 appeared 3:6,12,17 B 3:2 4:7 abide 115:8 30:12 3:22 4:5,8,13,19 back 10:12 11:10 ability 21:4 28:24 al 2:4,10,14 119:8 17:1,2 20:3 66:23 Alex 25:9,11,15 appears 65:18 38:24 44:2 52:24 able 57:8 82:24 26:12,19,23 29:1 100:19 101:4 62:14,16 64:7 88:15,21 89:5 29:8 72:3 100:23 103:22,24 104:20 73:25 75:18 92:6 108:14 101:21 106:23 110:24 79:13 90:13 absolutely 28:9 Alexander's 10:21 111:14 103:9,12 108:23 46:9 allowed 109:1 appointed 104:5 109:17 113:9 accept 54:20 amendment 74:23,23 appointments bad 37:16 101:13 79:16,19 83:22 103:18 Bainter 35:8 69:7 access 20:12,18,19 85:18 86:11 95:8 approach 82:12 69:7,20 98:25 accounts 91:8,17 amendments 31:6,9 appropriate 45:15 104:22 107:4,12 92:16 31:11 32:25 33:3 46:13 107:25 108:5,6 accurate 16:8,9 34:14 37:6 38:3 April 103:6,20 Bainters 46:7 action 40:2 118:18 38:8,21 40:23 104:20 108:20 BALDACCHINO 1:8 actions 34:15 41:15,23,25 42:8 area 46:15 ballot 32:9 33:6 activities 12:24 42:14,25 64:16 argumentative 49:3 34:3 add 114:13 65:17 76:13,20 63:13 86:8 92:8 Bardos 75:24 76:7 added 16:17 76:21,22,24 78:1 arguments 32:20 77:6 addition 14:19 80:23 82:13 86:6 88:7 Bascom 109:25 address 8:9,13,16 88:4 108:1,4,9 article 106:4,16 110:1 103:10,14 113:15 ASAP 105:23 baseline 44:4 addresses 91:18,19 amicably 12:7 asked 53:19 59:21 basically 66:4 adhered 113:16,25 amount 19:18 57:4 80:16 86:8 basis 26:16 39:14 administrator 71:7 analysis 44:12 112:25 46:11 advancing 68:15,20 51:12 asking 15:22 16:1 Bates 1:8 65:7 advice 27:2 48:24 analyze 51:12 59:14,15 60:8,9 Bean 13:16 78:3 91:25 92:1 analyzed 51:8 89:10 101:10 becoming 55:11,12 95:13 analyzing 54:24 assessment 114:15 beep 36:16 advise 110:3 Andy 71:12 115:15,23 began 84:12 advised 27:25 Anna 11:2 assume 9:23 16:10 beginning 7:9 advising 40:18 announced 50:5,8 34:22 112:13,16 behalf 3:7,12,17 95:20 answer 9:16,22 assumptions 24:24 3:23 4:5,8,14,20 advocate 109:1,5 19:22,25 20:10 attach 89:21 90:3 17:20 advocates 85:20 22:21 40:19 42:6 93:23 belief 42:13 advocating 42:8 49:3 52:17 57:9 attached 78:6 believe 14:13 15:6 affairs 9:1 61:5 70:5,9 93:14 97:21 27:10 29:20 affiliations 73:20 90:13,13 110:22 37:13 38:15 41:5 113:17 114:5 103:15 attempted 85:12 45:3 46:19 53:25 affirmed 41:8 answered 70:17 attempting 114:2 54:4 55:22 58:25 agenda 78:13 83:22 86:9 87:4 attend 66:2 99:22 59:8 61:25 65:20 ago 39:1 72:25 93:20 96:20 attended 71:18 71:22,24 76:6,9 73:16 anti-Amendment attendees 97:5 79:6,20 83:2 agree 16:8 19:2 37:8 Attorney 3:9,14,19 84:16 93:13 94:9 44:11 48:15,20 anybody 33:15 4:2,6,16 98:14 102:3 66:15 68:11,12 40:25 84:16 89:7 Attorneys 3:3 believed 82:17 76:17 115:14,22 92:6 97:22 audibly 9:16 Ben 74:4 115:25 108:25 available 26:8 best 18:4 45:23 agreed 115:9 anymore 99:22 61:22 70:3 48:8,13 69:9 ahead 19:22,25 anyway 63:3 106:24 Avenue 4:18 8:14 74:22 85:11 20:10 22:21 23:6 apologies 70:8 awaiting 112:1 106:17 42:6,24 49:3 apologize 98:22 aware 30:19 32:21 better 45:21,21,22 63:14 68:24 70:9 111:21 107:24 112:9 77:3,4 114:14 76:15 81:15 86:9 apparently 33:17 a.m 2:22,23 7:3 bicycle 9:11 92:9 appeal 41:7 64:3,6 113:5,8 big 58:21 83:13 Appeals 41:14 116:25

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WWW.USLEGALSUPPORT.COM 954-463-2933 120 122 IN THE CIRCUIT COURT OF THE 1 A P P E A R A N C E S SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA 2 DAVID B. KING and THOMAS A. ZEHNDER, THE LEAGUE OF WOMEN VOTERS 3 Attorneys at Law, of the law offices of King, OF FLORIDA; THE NATIONAL COUNCIL OF LA RAZA; COMMON 4 Blackwell, Zehnder & Wermuth, PA, P.O. Box 1631, CAUSE; JOAN ERWIN; ROLAND SANCHEZ-MEDINA, JR.; 5 Orlando, Florida 32802-1631, (407)422-2472, J. STEELE OLMSTEAD; CHARLES PETERS; OLIVER D. 6 [email protected] and [email protected]; appeared on FINNIGAN; SERENA CATHERINA BALDACCHINO; and DUDLEY BATES, 7 behalf of the Plaintiff The League of Women Voters of Plaintiffs, vs. CASE NO. 2012-CA-2842 8 Florida. KENNETH W. DETZNER, in his official capacity as Florida 9 JOHN M. DEVANEY, Attorney at Law, of the law Secretary of State; THE FLORIDA STATE SENATE; THE 10 offices of Perkins Coie, LLP, 700 Thirteenth Street, FLORIDA HOUSE OF REPRESENTATIVES; 11 AND DEAN CANNON, in his official NW, Suite 700, Washington, D.C. 20005, (202)434-1624, capacity as Speaker of the Florida 12 [email protected]; appeared on behalf of the House of Representatives, 13 Plaintiff Romo. Defendants. ______/ 14 GEORGE N. MEROS, JR., Attorney at Law, of the VOLUME 2 DEPOSITION OF MARC REICHELDERFER 15 law offices of GrayRobinson, PA, Post Office Box 11189, MAY 16, 2013 REPORTER BY: 16 Tallahassee, Florida 32302, PEGGY OWENS REGISTERED PROFESSIONAL REPORTER 17 [email protected]; appeared on behalf of REGISTERED MERIT REPORTER 18 the Defendant Florida House of Representatives. 19 JASON N. ZAKIA, Attorney at Law, of the law 20 offices of White & Case, LLP, Southeast Financial 21 Center, Suite 4900, 200 South Biscayne Boulevard, 22 Miami, Florida 33131-2352, (305)925-4795; appeared on 23 behalf of the Defendant Florida Senate. 24 25 121 123 1 IN THE CIRCUIT COURT OF THE 1 APPEARANCES (CONTINUED) SECOND JUDICIAL CIRCUIT, IN 2 DANIEL C. BROWN, Attorney at Law, of the law 2 AND FOR LEON COUNTY, FLORIDA 3 offices of Carlton Fields, 215 S. Monroe Street, Suite 3 4 4 RENE ROMO, et al., 500, Tallahassee, Florida 32301-1866, (850)224-1585; 5 Plaintiffs, 5 appeared on behalf of the witness. 6 v. CASE NO. 2012-CA-00412 6 DAVID HEALEY, Attorney at Law, 2846 Remington 7 KEN DETZNER and PAM BONDI, 7 Green Circle, #B, Tallahassee, Florida 32308-3763, 8 Defendants. 8 [email protected]; appeared on behalf of the 9 ______/ 9 10 THE LEAGUE OF WOMEN VOTERS witness. OF FLORIDA, et al., 10 GEORGE T. LEVESQUE, General Counsel, The 11 11 Florida Senate, 404 South Monroe Street, Suite 409 The 12 Plaintiffs, 12 Capitol, Tallahassee, Florida 32399, (850)487-5237, 13 vs. 13 [email protected]; appeared telephonically 14 KEN DETZNER, et al., 14 15 Defendants. on behalf of The Florida Senate only in Volume 1 of the 16 ______/ 15 deposition. Did not appear in Volume 2. 17 16 GERALD E. GREENBERG, Attorney at Law, of the 18 DEPOSITION OF: MARC REICHELDERFER 17 law offices of Gelber Schachter & Greenberg, PA, 1441 19 TAKEN AT THE INSTANCE OF: The Plaintiffs 18 Brickell Avenue, Suite 1420, Miami, Florida 33131, 20 DATE TAKEN: May 16, 2013 19 21 LOCATION: 131 N. Gadsden Street (305)728-0950, [email protected]; appeared Tallahassee, Florida 20 telephonically on behalf of the Plaintiffs only in 22 21 Volume 2 of the deposition. COMMENCING: 1:07 p.m. 22 23 23 CONCLUDING: 5:15 p.m. 24 24 25 25 1 (Pages 120 to 123) WWW.USLEGALSUPPORT.COM 954-463-2933 124 126 1 1 INDEX TO EXHIBITS CONTINUED 2 I N D E X 2 No. PAGE 3 WITNESS PAGE 3 34 - Reichelderfer 111-112 201 4 Marc Reichelderfer 4 35 - Reichelderfer 113-114 202 5 Continued Direct Examination by Mr. King 128 5 36 - Reichelderfer 115-116 203 6 Cross Examination by Mr. Devaney 260 6 37 - Reichelderfer 117-119 203 7 7 38 - Reichelderfer 120 & Attachments 204 8 8 39 - Reichelderfer 121 & Attachments 207 9 9 40 - Reichelderfer 122 210 10 10 41 - Reichelderfer 123 212 11 11 42 - Reichelderfer 124 214 12 12 43 - Reichelderfer 125-126 216 13 13 44 - Reichelderfer 127 218 14 14 45 - Reichelderfer 134-136 224 15 15 46 - Reichelderfer 137 230 16 16 47 - Reichelderfer 138 & Attachments 232 17 17 48 - Reichelderfer 139 & Attachments 233 18 18 49 - Reichelderfer 141-146 235 19 19 50 - Reichelderfer 147 & Attachments 236 20 20 51 - Reichelderfer 160 & Attachments 248 21 21 52 - Reichelderfer 161 250 22 22 53 - (Withdrawn - Not Attached 23 23 54 - Reichelderfer 164 & Attachments 255 24 24 55 - (Withdrawn - Not Attached) 25 25 56 - Reichelderfer 176 256 125 127 1 INDEX TO EXHIBITS 1 INDEX TO EXHIBITS CONTINUED 2 NO. PAGE 2 NO. PAGE 3 11 - Reichelderfer 59-60 136 3 57 - Reichelderfer 177 257 4 12 - Reichelderfer 62-63 139 4 58 - Reichelderfer 178 257 5 13 - Reichelderfer 65 140 5 59 - Reichelderfer 179 257 6 14 - Reichelderfer 66 & Map Attachment 144 6 60 - Reichelderfer 181 257 7 15 - Reichelderfer 76-77 149 7 61 - Reichelderfer 182 258 8 16 - Reichelderfer 83 & Attachments 149 8 62 - Reichelderfer 184 258 9 17 - Reichelderfer 86 & Attachments 153 9 10 18 - Reichelderfer 87 & Attachments 156 10 11 19 - Reichelderfer 88 & Attachments 159 11 12 20 - Reichelderfer 90 & Attachments 159 12 13 21 - Reichelderfer 91 & Attachments 160 13 14 22 - Reichelderfer 92 & Attachments 160 14 15 23 - Reichelderfer 93 & Attachments 161 15 16 24 - Reichelderfer 94 & Attachments 161 16 17 25 - Reichelderfer 95 & Attachments 161 17 18 26 - Reichelderfer 89 & Attachments 161 18 19 27 - Bill Status Report 163 19 20 28 - Reichelderfer 96-97 175 20 21 29 - Reichelderfer 98 182 21 22 30 - Reichelderfer 99-100 183 22 23 31 - Reichelderfer 101-102 183 23 24 32 - Reichelderfer 107-108 188 24 25 33 - Reichelderfer 109--110 191 25 2 (Pages 124 to 127) WWW.USLEGALSUPPORT.COM 954-463-2933 128 130 1 D E P O S I T I O N 1 somebody or something. 2 Whereupon, 2 So there was this argument, does the first 3 MARC REICHELDERFER, 3 map that comes out need to be exactly compliant. And 4 called as a witness; after having been previously duly 4 that's really what that was talking about. 5 sworn, was examined and testified as follows: 5 Q Who was the argument with? 6 THE VIDEOGRAPHER: The time is 1:07 p.m. We 6 A I don't think there was an argument. I think 7 are back on the record. 7 that this, these were things that we were discussing 8 BY MR. KING: 8 among the consultants, like Rich Heffley and myself. 9 Q Okay. Mr. Reichelderfer, we were talking 9 These were just a variety of questions that we thought, 10 before and we had gotten to about the summer of 2011. 10 you know, lawyers should try to answer. 11 Do you remember that, we were -- 11 I mean, there is timing, for example, when 12 A Yes, sir. 12 the maps were released, and how they were released and 13 Q -- talking about events that were occurring 13 all those kind of general questions. 14 in the summer. And by that time had the hearing 14 Q Were you trying to come up with a consensus 15 process started, the public hearings around the state? 15 among the consultants as to what direction to go here? 16 A I don't recall. I think probably around that 16 A We talked a lot about redistricting amongst 17 time. 17 ourselves. 18 Q Sometime late summer? 18 Q All right. 19 A Sometime in the summer. 19 A And had a variety of questions. Didn't know 20 Q Early fall? 20 answers to those questions and tried to come to a 21 A I think so. 21 consensus. 22 Q Okay. Now, we are going to begin looking 22 Q Then would it be correct that, this is really 23 again at Exhibit 3. Had you by mid summer, 2011, had 23 the kind of decision that's going to be made by the 24 you come up with these things that you were thinking 24 legislators, isn't it? 25 about and considering by the summer of 2011? 25 A The fact that we were discussing it doesn't 129 131 1 A I don't recall the exact time. 1 mean that -- 2 Q All right. But you were pretty clear that 2 Q Right. 3 you hadn't done it as of the time of December of 2010, 3 A You know. 4 right, when you had that meeting? 4 Q But you were putting yourself in a position 5 A Yes, sir. 5 to advise people like Dean Cannon about what you 6 Q And you think it occurred later on -- 6 political consultants thought they ought to do, right? 7 A Yes, sir. 7 MR. MEROS: Object to form. 8 Q -- right? Let me ask you about, that 8 THE WITNESS: Can you ask that question 9 question about the evolution of the point, the bullet 9 again? 10 point about evolution of maps. That's the fifth bullet 10 BY MR. KING: 11 point on there. 11 Q I said you were trying to reach a consensus 12 You say, "Evolution of maps. Should they 12 among the consultants so you would be in a position to 13 start less compliant and evolve through the process, or 13 advise Dean Cannon about what you thought the, what the 14 should the first map be as near as compliant as 14 consultants thought he ought to do; right? 15 possible and change very little? Or other 15 MR. MEROS: Same objection. Go ahead. 16 recommendations." 16 THE WITNESS: I don't believe so. I believe 17 Do you recall using that language? 17 there was more along the lines of us trying to 18 A Vaguely, yeah. 18 understand how the process was going to evolve. 19 Q What was on your mind there? 19 I think the lawyers are going to make that 20 A There was -- and again, if I recall 20 decision for the House and the Senate as to what 21 correctly, I think there was some legal debate that any 21 they think are best for the cases. 22 changes to the map after the first, there was one legal 22 We are just trying to know in advance what 23 argument that any changes to the map after it's first 23 the top process was going to be. 24 released, depending on who filed the amendment, maybe, 24 BY MR. KING: 25 every time you move a line it favors or disfavors 25 Q Well, in truth and in fact, unless you were 3 (Pages 128 to 131) WWW.USLEGALSUPPORT.COM 954-463-2933 132 134 1 advising your legislator clients, you wouldn't have any 1 statement. 2 role to play as to how compliant to make the maps, the 2 BY MR. KING: 3 first maps, right? 3 Q Okay. Well, did you come up with the rank of 4 A No, we wouldn't, no. 4 the criteria, a ranking of the criteria? 5 Q Unless maybe you were involved in giving 5 A I'm not a lawyer, so I didn't, I don't -- 6 advice about the maps, right? 6 that's not my judgment to rank the criteria. 7 MR. MEROS: Object to form. Go ahead. 7 Q Okay. So you didn't develop any opinion on 8 THE WITNESS: I would say that it was more 8 that yourself? 9 that we wanted to know how things were going to 9 A No, sir. 10 unfold in advance. More so than what we were 10 Q Did you discuss this with the lawyers that 11 trying to do was influence. 11 were involved? 12 In other words, because I have clients who 12 A I don't believe I did, no, sir. 13 have districts, and I am involved in the process 13 Q Did you discuss this list of concerns with 14 of running campaigns, I would like to know how 14 the lawyers that were involved? 15 this is going to be rolled out. I would like to 15 A I don't believe I did. 16 know, and that's -- 16 Q So you only discussed this list of concern 17 BY MR. KING: 17 with your fellow political consultants? 18 Q Were you actually considering with your 18 A Yes, sir. 19 consultant friends that maybe the legislature should 19 Q Did you discuss this list of concerns with 20 issue maps that weren't compliant? 20 any of the legislative staffers? 21 A I don't, I don't believe that was what was 21 A I don't recall. 22 being -- 22 Q Okay. And that means you could have 23 Q Well, less compliant would be not compliant, 23 discussed it with legislative staffers? 24 wouldn't it? 24 MR. ZAKIA: Object to the form. 25 MR. ZAKIA: Object to form. 25 MR. MEROS: Object to the form. 133 135 1 THE WITNESS: I don't remember exactly, but 1 THE WITNESS: I certainly could have asked 2 it goes back to the first point that I made, which 2 some of these questions. 3 was that if every time you moved a line it was 3 BY MR. KING: 4 favoring or disfavoring. 4 Q To some of those legislative staffers? 5 I think it was more along the lines of how do 5 A To those staffers. 6 you do that then. Obviously, there is going to be 6 MR. BROWN: Please let the witness answer his 7 people that the public input is going to affect 7 question, complete the answer before you ask the 8 things, different things, there would be changes 8 next question. 9 made. I think it was just an intellectual 9 BY MR. KING: 10 conversation about that issue. 10 Q Sure. Okay. Like Kirk Pepper, could you 11 BY MR. KING: 11 have talked to Kirk Pepper about this list? 12 Q And by the same token, ranking the criteria, 12 A I could have. 13 that's really none of your business unless the, unless 13 Q Okay. Could you have talked to Mr. J. Alex 14 you are advising the staff or the legislature about how 14 Kelly about this list? 15 to do that, is it? 15 A No, sir. 16 MR. ZAKIA: Object to form. 16 Q Could you have talked to Dean Cannon about 17 MR. MEROS: Object to form. 17 this list? 18 THE WITNESS: Repeat that question. 18 A Not in its entirety. 19 BY MR. KING: 19 Q Some of the issues you talked to Dean Cannon 20 Q You didn't have any opportunity, unless you 20 about? 21 were drawing maps, to deal with ranking the criteria, 21 A These are all various questions that we 22 did you? 22 compiled over time. Could I have asked him some of 23 MR. MEROS: Object to form. 23 these questions? I certainly could have. 24 MR. ZAKIA: Objection. 24 Q Did you discuss the pros and cons of the 25 THE WITNESS: I don't agree with that 25 central Florida Hispanic seat with Mr. Cannon? 4 (Pages 132 to 135) WWW.USLEGALSUPPORT.COM 954-463-2933 136 138 1 A I don't, I don't recall having that 1 Q Well, at any rate -- 2 conversation with him. 2 A Well -- 3 Q Did you discuss with him whether the House 3 Q Was it your understanding that the 4 should do a Senate map or vice versa? 4 legislature wanted to listen to the citizens first 5 A That's a conversation that could have taken 5 before producing the maps? 6 place. 6 A Yes. 7 Q Now, did you attend hearings that were going 7 Q And that was something they boldly proclaimed 8 on throughout the state on the redistricting? 8 in their press releases about the process, right? 9 A I did not attend any of the hearings that 9 MR. ZAKIA: Object to form. 10 were out of Tallahassee. 10 THE WITNESS: Those are your words. I don't 11 Q Did you attend hearings in Tallahassee? 11 know how boldly they proclaimed or didn't 12 A I think I probably sat through one, at least 12 proclaim. 13 one, maybe two, redistricting committee hearings. 13 BY MR. KING: 14 Q Did you speak at the hearings? 14 Q Okay. But they took that position, that was 15 A No, sir. 15 one of the benefits or advantages of the way they were 16 (Whereupon, the next document was marked as 16 going about -- 17 Deposition Exhibit No. 11.) 17 A I believe -- 18 BY MR. KING: 18 Q -- doing it? 19 Q I show you Exhibit 11, and ask if you 19 MR. BROWN: Let him finish his question. 20 recognize Exhibit 11 as a document that was in your 20 THE WITNESS: I believe that's the case. 21 file. 21 BY MR. KING: 22 A Yes, sir. 22 Q Do you recall why they, Mr. Terraferma 23 Q And this is an e-mail from Frank Terraferma 23 suggested that they not reference whether they were 24 dated July 5, 2011, to yourself, sir? 24 Republican or not when they were talking? 25 A Yes, sir. 25 A I do not. 137 139 1 Q And do you recall why Mr. Terraferma sent you 1 (Whereupon, the next document was marked as 2 these redistricting hearing pointers? 2 Deposition Exhibit No. 12.) 3 A I believe that it, that there were, in and 3 BY MR. KING: 4 around the state I think they were trying to generate 4 Q Next here I show you Exhibit 12. This is 5 some turn out. I think he sent this to maybe a variety 5 another document from your file. Do you recall that, 6 of different people. 6 sir, Bates stamp 62 through 64, dated November 8, 2012. 7 I have candidates running for office that 7 A Yes, sir. 8 maybe wanted to go testify that these were some things 8 Q And was that in your file because you are 9 that they could, some guidelines that they wanted to 9 quoted in the article? 10 testify -- 10 A I don't know why this is in my file. I guess 11 Q So these would be, these pointers were 11 I produced everything that I had, so. 12 directed toward Republicans that were going to appear 12 Q Okay. And you are, in fact, quoted in the 13 in front of these committees? 13 article; right? 14 A I believe so. 14 A Yes, sir. 15 Q Did you disseminate this to people? 15 Q It says, quote, "There's a likelihood the 16 A I don't recall whether I did or didn't. 16 numbers can drop, said Marc Reichelderfer, a 17 Q Do you remember why you were supposed to 17 Tallahassee lobbyist and Republican campaign 18 thank the legislature for listening to citizens first 18 consultant." 19 before producing maps? 19 Quote, "2010 was a great year, but can you 20 A No, sir. 20 keep everybody? I don't know," End quote. 21 Q Wasn't there an issue, an issue about whether 21 A Okay. 22 the legislature should give the people an idea of a map 22 Q Is that something you said? 23 that they were considering before the hearings or not? 23 A I believe so. 24 A I don't recall specifically; but if you say 24 Q Okay. And then the writer goes on to say, 25 so, yes. 25 but this once in a decade redrawing of political lines 5 (Pages 136 to 139) WWW.USLEGALSUPPORT.COM 954-463-2933 140 142 1 early next year also will prove key to whether the 1 Q This wasn't something you had gotten from the 2 Republicans retain their iron grip in Florida. 2 Senate? 3 Do you see that language? 3 A No, sir. 4 A Yes, sir. 4 Q You are certain of that? 5 Q And of course, your goal and desire was that 5 A I'm, on August 2011, yes, sir, I'm certain of 6 the Republicans retain their iron grip in Florida; 6 that. 7 right? 7 Q Okay. But that document, that attachment 8 A I don't know that is exactly what I said 8 would show us, wouldn't it? 9 there, but -- 9 A That -- 10 Q I'm not suggesting you said it. I'm saying 10 Q Whether you had produced it or the Senate had 11 the writer said it. 11 produced it? 12 A The writer said that. 12 A I don't know that it would or wouldn't. 13 Q But you agree with that concept, that you 13 Q Okay. Well, it wouldn't have been 14 wanted the Republicans to retain their iron grip in 14 appropriate or proper for you to have a Senate drawn 15 Florida, right? 15 map on August 11, 2011, would it, sir? 16 MR. ZAKIA: Object to form. 16 A That's why I told you that it wouldn't have 17 THE WITNESS: I would say that I wanted them 17 come from the Senate. 18 to retain their majority, yes. 18 Q Wouldn't have come from the Senate. The 19 (Whereupon, the next document was marked as 19 Senate, I mean, the legislature was still having these 20 Deposition Exhibit No. 13.) 20 open hearings around the state, right? 21 BY MR. KING: 21 A Yes -- 22 Q Now, next, sir, I show you Exhibit 13, and 22 Q They weren't supposed to have started drawing 23 ask if you recognize Exhibit 13 as an e-mail from you 23 maps yet, were they? 24 to Pat Bainter dated August 11, 2011. 24 A Correct. 25 A Yes, sir. 25 MR. BROWN: Let him finish his question. 141 143 1 Q And it appears that this attaches a Senate 1 BY MR. KING: 2 map, correct? 2 Q So your testimony is that you had actually 3 A Yes, sir. 3 drawn up a map of the Senate districts, yourself, 4 Q It says Senate6 working.doj, right? 4 without help from anybody else? 5 A Yes, sir. 5 A Correct. 6 Q Now, that attachment was not with your 6 Q And you diagrammed it out on a sheet like the 7 e-mail. Do you know what happened to that? 7 Senate did when they did their maps? 8 A I produced all my attachments as kmz files on 8 A I used -- 9 the zip file that we gave to you. 9 MR. MEROS: Excuse me. Could you tell me 10 Q Well, we got most all of them, I think, but 10 what you mean by "diagrammed out"? 11 -- 11 BY MR. KING: 12 A It should have been. 12 Q You had a visual presentation of your map, 13 Q -- I didn't see one for that one. Do you 13 did you? 14 know what could have happened to it? 14 A It is a software program, so you just, it is, 15 A No, sir. 15 anybody from the public can go on and design maps. 16 Q Okay. At any rate, let me ask you this 16 Q Okay. 17 question. How is it that you got a Senate map to pass 17 A On the House redistricting website. 18 to Pat Bainter on August 11, 2011? 18 Q Okay. And how does that look? Does it have 19 A Because we were drawing maps. 19 a House designation on it? 20 Q Is it your suggestion that this was a map 20 A It is just a website. 21 that you drew, that Mr. -- that you drew? 21 Q Just a website? 22 A Yes, sir. 22 A Anybody from the public can go in and draw 23 Q Okay. So this wasn't something produced by 23 maps. And it was encouraged that people draw maps from 24 the Senate? 24 the public and submit those maps. 25 A No, sir. 25 6 (Pages 140 to 143) WWW.USLEGALSUPPORT.COM 954-463-2933 144 146 1 (Whereupon, the next document was marked as 1 Q Did you submit it -- 2 Deposition Exhibit No. 14.) 2 A No, sir. 3 BY MR. KING: 3 Q -- to the, to any of the public hearings 4 Q And let me show you Exhibit 14 and ask you if 4 considering the redistricting? 5 you recognize Exhibit 14. 5 A No, sir. 6 A Yes, sir. 6 Q Did you submit it to the House or Senate for 7 Q Is Exhibit 14, which purports to be an e-mail 7 their consideration? 8 August 17, 2011, from you to Rich Heffley, is that an 8 A No, sir. 9 e-mail from your files and records, sir? 9 Q Did you give it to any staff members? 10 A I believe so. 10 A No, sir. 11 Q Now, it attaches the same attachment that was 11 Q Did you determine how this map would perform 12 on the Exhibit 13, right, that's referred to on Exhibit 12 politically for Republican candidates? 13 13? 13 A Not specifically, no, sir. 14 A It is the same file name. I would assume so. 14 Q Okay. Why was that? 15 Q So we do have a copy of the attachment here. 15 A If I recall correctly, the performance data 16 A Yes, sir. 16 was not included in the software until later in the 17 Q And you see that, right? 17 process. I think it was still being pressed into the 18 A Yes, sir. 18 program. 19 Q Now, is that a map you created? 19 Q And lets make sure we understand or I 20 A Yes, sir. 20 understand that. The performance data can be 21 Q Okay. You drew that using the House of 21 calculated once you have the census data and the 22 Representatives redistricting materials or -- my what 22 elections data; is that right, the precinct data? 23 did you say? 23 A Correct. 24 A Website. 24 Q So you have a bunch of census blocks within a 25 Q Their website. 25 precinct? 145 147 1 A MyDistrictFolder.com, yes. 1 A Right. 2 Q That had the software in it for you to design 2 Q And those, somehow in the world of software, 3 this Senate map, right? 3 get all merged together and then you can determine how 4 A Yes, sir. Anyone from the public can. 4 a district will perform or performed in prior 5 Q Why did you call it Senate6? 5 elections; correct? 6 A I don't recall. 6 A Correct. 7 Q And what did you do with this map, besides 7 Q So that would give you an idea how you -- 8 send it to Mr. Heffley? 8 strike that. 9 A That's it. And I can, I think Pat, at least 9 You could measure how the particular proposed 10 he was also on this e-mail. 10 district performed in the 2008 presidential election? 11 Q Right. You sent it to Bainter with Exhibit 11 A Correct. 12 13, and you sent it to Heffley with Exhibit 15; right? 12 Q You can measure how the particular district 13 A Appears to be so. 13 performed in the 2010 gubernatorial election, right? 14 Q Okay. 14 A Correct? 15 MR. ZAKIA: Did you get those numbers right? 15 Q And those would be bases that you would look 16 You said 15. 16 at to see, to make some calculation about how that 17 MR. KING: I'm sorry, Exhibit 14. You got 17 district might perform in the future; right? 18 me. 18 A Correct. 19 BY MR. KING: 19 Q And did the House or the Senate accomplish 20 Q You sent it to Mr. Heffley with Exhibit 14, 20 that merger of that information? 21 right? 21 A I don't know. 22 A I believe so. 22 Q Did one of the legislative bodies take the 23 Q Okay. Now, what did you do with it then? 23 position that they didn't want to even consider 24 A I mean, I sent it to them and we had probably 24 performance data? Or did both of them take that 25 discussions. 25 position? 7 (Pages 144 to 147) WWW.USLEGALSUPPORT.COM 954-463-2933 148 150 1 A I think, I don't know the answer to that 1 until November 28, 2011; were they, sir? 2 question. 2 A That's, that's correct. 3 Q So did you ever suggest this Senate map ought 3 Q So could you have obtained this map from some 4 to be used for any purpose, other than just discussion 4 staffer? 5 with Mr. Bainter and Mr. Heffley? 5 A No, sir. 6 A No, sir. 6 Q Or legislator? 7 (Whereupon, the next document was marked as 7 A No, sir. Unlikely. I don't recall. 8 Deposition Exhibit No. 15.) 8 Q Are you absolutely confident that this map 9 BY MR. KING: 9 was posted on the public website so that anybody could 10 Q I show you Exhibit 15, sir. And this is a 10 pull it off? 11 report from Senator Don Gaetz -- that's G-A-E-T-Z -- 11 A I am fairly confident that this map 12 from the Senate committee on reapportionment. 12 originated -- this wouldn't be exactly originated as a 13 And this is simply informing you that the 13 map that was posted publicly. You could download and 14 Senate has completed the statewide listening tour, and 14 enter your software and make edits to it. 15 they are ready for the next steps and the redrawing, 15 Q All right. And did you make any edits to it? 16 redistricting process, which will include starting to 16 A I believe I probably did. 17 consider maps; right? 17 Q Would there be some software trail, if you 18 A Yes, sir. 18 had drawn this map down from the Senate website? 19 Q Now, after that time did you submit any maps 19 MR. ZAKIA: Object to form. 20 to the, either the House or the Senate? 20 THE WITNESS: I don't know. 21 A I did not. 21 BY MR. KING: 22 (Whereupon, the next document was marked as 22 Q I mean, you can, let me just make sure I 23 Deposition Exhibit No. 16.) 23 understand. Sometimes not too good at computers. Can 24 BY MR. KING: 24 you just go on a computer and print this map off, off 25 Q All right, sir, next I show you Exhibit 16, 25 the Senate website, without any e-mail or trail or 149 151 1 and ask you if you recognize this e-mail of November 1, 1 anything like that? 2 2011, that you sent evidently to Mr. Terraferma; is 2 A Yes. 3 that right? 3 Q Okay. So this is what it would look like if 4 A Yes, sir. 4 you just went on the Senate website and printed this 5 Q And this involves a subject of a Senate map, 5 off? 6 right? 6 MR. MEROS: Object to form. Go ahead. 7 A Yes, sir. 7 THE WITNESS: Kind of. It is actually a data 8 Q And this one is entitled Senate concept 8 file that you download from the website. 9 working.kmz, right? 9 BY MR. KING: 10 A Yes, sir. 10 Q Okay. 11 Q Now, where did you get this map? 11 A That data file you can open in the website 12 A I don't recall. 12 that you are signed on to, and you can view the map in 13 Q Well, you didn't create this map, did you, 13 the software. 14 sir? 14 Q A map that corresponds visually to that data 15 A It is more likely a document that was one of 15 field? 16 the public documents that was downloaded and I probably 16 A Correct. 17 edited in some fashion. 17 Q Now, the material behind it, it says Senate 18 Q You think this is a public document? 18 123 revised 3 data.csv, Reichelderfer. What does that 19 A At this stage in the process -- and I don't 19 mean? 20 remember my dates exactly -- I think the maps were 20 MR. MEROS: Reichelderfer. 21 being posted publicly by this time in the time line. 21 BY MR. KING: 22 Anybody who posted a map publicly on the state's 22 Q Reichelderfer. What does that mean? 23 website was available to download. 23 A I don't know. 24 Q Okay. Well, would you agree with me that the 24 Q Is that a data field that you prepared? Or 25 Senate, Senate maps were not released to the public 25 did you get that off the Senate website? 8 (Pages 148 to 151) WWW.USLEGALSUPPORT.COM 954-463-2933 152 154 1 A I am not familiar with looking at a chart 1 current district is at 39.46 percent." Do you see 2 like this. I don't know. 2 that? 3 Q This chart was in your file, though, wasn't 3 A Yes, sir. 4 it? 4 Q Now, what does that mean? What were you 5 A What I believe is the case is that there is a 5 doing? 6 data file that gets uploaded into the computer. I gave 6 A It was an exercise in drawing maps to see if 7 on the zip drive the data file. That data file can be 7 we could actually physically do the maps and comply 8 looked at in a version of a map or even raw data. 8 with the federal voters rights act, which I think is 9 I usually viewed maps, not raw data like 9 somewhat interpreting at that point to prevent 10 this. So while that information may have been on there 10 retrogression of minority districts. 11 for the statistics, I visually am not familiar with 11 Q And so you actually took -- did you take the 12 that. 12 map that is in Exhibit 16, did you take that and change 13 Q Well, you printed it off, though, and passed 13 it to come up with 17? 14 it on to Mr. Terraferma, right? 14 A I don't recall specifically. 15 A I don't recall. 15 Q Exhibit 17? 16 Q I mean, you see the e-mail at the front? 16 A I don't recall specifically. 17 A What I'm saying is, this e-mail was an 17 Q Well, when you say, "I got the Blk VAP in 19 18 e-mail -- 18 to 39.47 percent," what are you saying? 19 Q Right. 19 A That would be the black voting age 20 A -- with an electronic data file attached to 20 population. And that would be a minority district. 21 it. 21 And one of the -- 22 Q Right. 22 Q Okay. 23 A You can open that electronic data file a 23 A -- things for the purposes of redistricting, 24 variety of different ways. 24 at least I always understood, was there should not be 25 Q Sure. 25 retrogression within the minority districts. 153 155 1 A Whoever prepared this document took this and 1 I would assume I was attempting to draw that 2 printed this data out. All I sent was an e-mail with 2 district. Have it come out at the right population and 3 an electronic file. 3 retain the current black voting age population in that 4 Q Okay. 4 district. 5 A I did not print this out and produce this 5 Q Why were you concerned about District 19? 6 specific document. 6 A I don't recall. 7 Q And you said, per our conversation. What was 7 Q Did you have a client involved in District 8 your conversation? 8 19? 9 A I don't recall. 9 A No, sir, I did not. 10 Q And this data file, do you understand the 10 Q So you were -- what this establishes is that 11 data file that's attached? 11 you were developing some facility with using this map 12 A I understand some of the lines, yes. I 12 drawing program? 13 understand what the data is, sure. 13 A I was learning the software, yes. 14 (Whereupon, the next document was marked as 14 Q All right. And why were you sharing the map 15 Deposition Exhibit No. 17.) 15 with Mr. Terraferma? 16 BY MR. KING: 16 A Because we were consultants that care 17 Q Okay. And then let me show you Exhibit 17. 17 about -- it is a lot like drawing jigsaw puzzles and we 18 And do you recognize Exhibit 17 as a November 4, 2011, 18 are junkies that like to do that, played around with 19 e-mail from yourself to Mr. Terraferma regarding Senate 19 the process. 20 123 revised 5.kmz? 20 Q But the process was not nearly as interesting 21 A Yes, sir. 21 as the outcome of the process to you, was it? 22 Q Now, that comes from your file, as well? 22 MR. MEROS: Object to form. 23 A I believe so. Yes, sir. 23 MR. ZAKIA: Same objection. 24 Q And you say, quote, "I think this is better. 24 THE WITNESS: I think they were equally. I 25 And I got the Blk VAP in 19 to 39.47 percent. The 25 mean -- repeat the question. 9 (Pages 152 to 155) WWW.USLEGALSUPPORT.COM 954-463-2933 156 158 1 BY MR. KING: 1 some maps from Mr. Terraferma? 2 Q I mean, the process of drawing these maps and 2 A I don't believe that I did, but I can't say 3 doing the jigsaw puzzle was not nearly as significant 3 with certainty. 4 to you as the outcome of the process, which would be 4 (Whereupon, the next document was marked as 5 what would these districts look like, right? 5 Deposition Exhibit No. 19.) 6 MR. MEROS: Same objection. 6 BY MR. KING: 7 MR. ZAKIA: Same objection. 7 Q I show you Exhibit 22 -- Exhibit 19, I'm 8 THE WITNESS: I wouldn't necessarily, I would 8 sorry, which is a November 11, 2011 e-mail from 9 not necessarily agree with that statement. 9 yourself to Rich Heffley Associates. And the subject 10 BY MR. KING: 10 there is a congressional plan. Do you see that? 11 Q Okay. So you really weren't concerned with 11 A Yes, sir. 12 how the districts were going to line up politically and 12 Q And it says, on the attachment, frank cong 13 who was going to have a good shot at getting elected? 13 plan revised4. 14 A I don't agree with that statement either. 14 A Yes, sir. 15 Q So you were? 15 Q And you say to Mr. Heffley that you meant to 16 A I didn't agree with the first statement. 16 send this to you last night, right? 17 (Whereupon, the next document was marked as 17 A Yes, sir. 18 Deposition Exhibit No. 18.) 18 Q And so, is this a plan you drew? 19 BY MR. KING: 19 A It says it is a plan Frank drew, I think, but 20 Q I show you Exhibit 18 and point out to you 20 -- 21 this is an e-mail dated November 4, 2011. Now it 21 Q So is that Frank Terraferma? 22 refers to Senate 123 revised 7.kmz. And this is an 22 A I believe so. 23 e-mail to Frank Terraferma again. Do you see that? 23 Q Okay. So this is a Frank plan. 24 A Yes, sir. 24 A Yes, sir. 25 Q Is that a document in your file? 25 Q All right. And did you make any changes to 157 159 1 A I believe so, yes, sir. 1 this? 2 Q So this is yet another version of the Senate 2 A I don't recall. 3 redistricting map that you worked on? 3 Q Now, I thought you indicated that you really 4 A I believe so. 4 weren't that interested in the congressional maps 5 Q And in this one, Mr. Terraferma suggests that 5 because you didn't have any congressional clients? 6 you, you thought -- he thought it was better because 6 A That's correct. I said as interested. 7 you followed the Peace River in Hardee, right? 7 Q But you were still interested? 8 A Yes, sir. That's what it says. 8 A I'm interested, sure. 9 Q Okay. And did he make contributions to the 9 Q All right. Because it was important for you 10 map drawing with you? Was he doing maps himself? 10 who ended up as congressman in United States House of 11 A I believe so. 11 Representatives, right? 12 Q Did he send you any of his maps? 12 A Generally. 13 A Probably. I don't recall. 13 Q Okay. And did you typically share these maps 14 Q Could there be some he sent you that didn't 14 with Mr. Heffley, as well? 15 get into this production? 15 A Yes. Sometimes. Sometimes Frank. Sometimes 16 A I don't believe so. 16 Pat. 17 Q Okay. So if they weren't in the production, 17 MR. KING: Okay. I apologize for the delay 18 you never got them from him? 18 in marking some of the exhibits, but we'll move 19 A I don't know the answer to that question. 19 along faster that way. 20 Q Well -- 20 (Whereupon, the next document was marked as 21 A I produced what was still in my -- 21 Deposition Exhibit No. 20.) 22 Q Sure. 22 BY MR. KING: 23 A Could I have lost files, prior to that? 23 Q Sir, let me show you Exhibit 20. Exhibit 20 24 Certainly likely. I would say unlikely, though. 24 purports to be an e-mail from Kirk Pepper at 25 Q Are you suggesting that you think you got 25 [email protected]? 10 (Pages 156 to 159) WWW.USLEGALSUPPORT.COM 954-463-2933 160 162 1 A Okay. 1 BY MR. KING: 2 Q On Wednesday, November 23, 2011, to you 2 Q And then lastly in this sequence, sir, I show 3 sharing Congressional 1.kmz with you using Dropbox. In 3 you Exhibit 26, and ask you if you recognize that as an 4 other words, giving you a link to the Dropbox. Do you 4 e-mail of November 23, 2011, from Kirk Pepper sharing 5 recognize that document, sir? 5 Congressional 7.kmz with you using Dropbox? 6 A Yes, sir. 6 A Yes, sir. 7 Q Is that a document from your file? 7 Q So having looked at each of these documents, 8 A Yes, sir. 8 you recognize those as coming out of your files and 9 (Whereupon, the next document was marked as 9 records, sir? 10 Deposition Exhibit No. 21.) 10 A Yes, sir. 11 BY MR. KING: 11 Q You produced them in this case, right? 12 Q All right. Next, sir, I show you Exhibit 21, 12 A Yes, sir. 13 and ask you if you recognize that as an e-mail of the 13 Q And these are seven congressional maps that 14 same date, November 23, 2011, to yourself from 14 were prepared by the House redistricting committee; 15 Mr. Pepper sharing Congressional 2.kmz with you using 15 isn't that correct, sir? 16 Dropbox. 16 A I don't know that for certain, but -- 17 A Yes, sir. 17 Q Well, it goes one through seven, doesn't it? 18 (Whereupon, the next document was marked as 18 A Yes, sir. 19 Deposition Exhibit No. 22.) 19 Q So that's seven congressional maps. 20 BY MR. KING: 20 A Yes, sir. 21 Q Next, sir, I show you Exhibit 22, and ask you 21 Q And Mr. Pepper is sending them to you, and 22 if you recognize that as an e-mail from Mr. Pepper to 22 they come from the House congressional redistricting 23 you sharing Congressional 3.kmz through Dropbox? 23 committee; don't they? 24 A Yes, sir. 24 A They may. 25 (Whereupon, the next document was marked as 25 Q All right. 161 163 1 Deposition Exhibit No. 23.) 1 A They may not. I mean, there is other 2 BY MR. KING: 2 options, but I don't recall specifically. 3 Q And next, sir, I show Exhibit 23 to you, and 3 Q And these weren't prepared by you, right? 4 ask you if you recognize that as an e-mail from Kirk 4 A These were not prepared by me, no, sir. 5 Pepper on November 23, 2011, sharing Congressional 5 Q Even though like in Exhibit 23, it has in the 6 4.kmz with you using Dropbox. 6 data sheet your name at the top, that wasn't prepared 7 A Yes, sir. 7 by you; right? 8 (Whereupon, the next document was marked as 8 A No, sir. 9 Deposition Exhibit No. 24.) 9 Q And, in fact, sir, these were maps that had 10 BY MR. KING: 10 not been released to the public at the time you 11 Q And next, sir, I show you Exhibit 24. And 11 received them on November 23, 2011; isn't that right, 12 ask you if you recognize that as an e-mail from Kirk 12 sir? 13 Pepper to yourself dated November 23, 2011, sharing 13 A I don't know that to be certain, but -- 14 Congressional 5.kmz with you using Dropbox? 14 Q Isn't it correct that these seven maps were 15 A Yes, sir. 15 not released to the public until December the 6th by 16 (Whereupon, the next document was marked as 16 the House, when the House released their maps? 17 Deposition Exhibit No. 25.) 17 A I don't know the exact dates. If you say 18 BY MR. KING: 18 that's the dates, then I certainly would agree with 19 Q And then next, sir, I show you Exhibit 25. 19 you. 20 And ask you if you recognize that as an e-mail dated 20 (Whereupon, the next document was marked as 21 November 23, 2011, from [email protected], sharing 21 Deposition Exhibit No. 27.) 22 Congressional 6.kmz with you using Dropbox. 22 BY MR. KING: 23 A Yes, sir. 23 Q I show you, sir, Exhibit 27, I pulled up off 24 (Whereupon, the document was marked as 24 the House redistricting committee website. And ask 25 Deposition Exhibit No. 26.) 25 you, sir, if you recognize that. 11 (Pages 160 to 163) WWW.USLEGALSUPPORT.COM 954-463-2933 164 166 1 A Yes, sir. 1 Q Isn't that a, doesn't that suggest that you 2 Q I mean, that's how you follow the progress of 2 and Mr. Pepper were trying to keep what you were doing 3 legislation -- 3 away from the eyes of the public? 4 A Yes, sir. 4 MR. MEROS: Object to the form. 5 Q -- through the committees and through the 5 MR. BROWN: Object. Argumentative. You can 6 House and Senate, right? 6 answer. 7 A Yes, sir. 7 THE WITNESS: I don't agree with that 8 Q And do you see, sir, that actually the House, 8 statement. 9 the congressional redistricting committee on the second 9 BY MR. KING: 10 page released seven congressional plans; right? 10 Q Well, would it be done like that then? 11 A I'm sorry, on which page? 11 A I don't know. 12 Q Second page under congressional redistricting 12 Q Mr. Pepper had an e-mail account where he 13 subcommittee? 13 could send you documents right out of his office, right 14 A Yes, sir. 14 to you, where it would be a permanent record of what 15 Q They released seven plans, right? 15 occurred; right? 16 A It appears so, yes, sir. 16 MR. ZAKIA: Object to form. 17 Q You see they released them on December 6, 17 THE WITNESS: Sometimes the files were 18 2011, publicly? 18 excessively large. And generally, when a Dropbox 19 A I think that's what it says there. I thought 19 was used was when the files were too long to 20 it was earlier than that, but if that's what the 20 e-mail. 21 document says. 21 BY MR. KING: 22 Q So your friend, Mr. Kirk Pepper, evidently 22 Q And you knew at the time you were not 23 sent you those seven maps something like two weeks 23 supposed to be receiving these congressional maps, 24 before the general public ever saw them, right? 24 didn't you? 25 MR. ZAKIA: Object to form. 25 MR. MEROS: Object to form. 165 167 1 THE WITNESS: According to these documents. 1 THE WITNESS: I don't agree with that. 2 BY MR. KING: 2 BY MR. KING: 3 Q Is that the way this process was supposed to 3 Q Well, you thought it was appropriate for 4 work, sir? 4 Mr. Pepper to send them to you? 5 A I can't opine on that. 5 A I don't necessarily agree with that statement 6 Q Well, that would seem to contradict the idea 6 either. 7 that the political consultants weren't supposed to be 7 Q Well, why was it inappropriate for him to be 8 involved in with these maps, wouldn't it? 8 sending it to you? 9 MR. MEROS: Object to form. 9 A I didn't think it was inappropriate. 10 THE WITNESS: I don't agree with your premise 10 Q As I understand, maybe I'm confused, but it 11 of the question. 11 seems to me like you said on the one hand it was 12 BY MR. KING: 12 appropriate that he sent it to you; on the other hand, 13 Q Well, did you ask Mr. Pepper to send these 13 it was inappropriate he sent it to you. 14 seven congressional maps to you two weeks before they 14 A I did not say either of those is what I'm 15 were released to the public? 15 trying to say. 16 A I don't recall. 16 Q Okay. Well, if it wasn't appropriate, wasn't 17 Q Did they just all of a sudden appear in your 17 it improper? 18 box on the 23rd? 18 A No, sir. 19 A I don't recall whether I asked or not. 19 Q Okay. So it is neither. It was neither 20 Q Okay. And the other question was, how do 20 appropriate or inappropriate? 21 those, how is it y'all are moving these maps around 21 A No, I believed it was appropriate. 22 through the Dropbox, through a Dropbox? 22 Q Now it is appropriate? 23 MR. ZAKIA: Object to form. 23 A I believe that there was nothing wrong with 24 THE WITNESS: I don't recall. 24 it. 25 BY MR. KING: 25 Q Nothing wrong with it. And so you got a two 12 (Pages 164 to 167) WWW.USLEGALSUPPORT.COM 954-463-2933 168 170 1 week jump on the general public and the opportunity to 1 BY MR. KING: 2 analyze these maps; right? 2 Q Do you deny that you did it, sir? 3 A I suppose that's one way to interpret it. 3 A No. 4 Q Is that another way of saying that's right, 4 MR. ZAKIA: Object to the form. 5 yes, sir, that's what happened? 5 THE WITNESS: I don't deny it, but I don't 6 MR. BROWN: Object. Argumentative. 6 recall. 7 THE WITNESS: I don't believe that is what 7 BY MR. KING: 8 happened, no, sir. 8 Q Isn't that something that you would remember? 9 BY MR. KING: 9 A Not necessarily, no. 10 Q Well, you know that's what happened, right? 10 Q I mean, that's, in the first place, you would 11 You got these maps two weeks before the general public 11 have known you were doing something you shouldn't have 12 got them. Right? 12 been doing, right? 13 A According to the documents, yes; but I don't 13 MR. MEROS: Object to form. 14 recall specifically. 14 THE WITNESS: I don't agree with the premise 15 Q And you got them for a reason, isn't that 15 of the question. 16 right? 16 BY MR. KING: 17 A I assume it was for a reason. 17 Q I mean -- okay. So you think it is okay for 18 Q Yeah. The reason was you wanted to send them 18 you to look at these maps, determine how they perform 19 around to your political consultant group, and you 19 politically, and then provide that information to Dean 20 could all then handle them, right? 20 Cannon, or Kirk Pepper, or anybody else? 21 MR. MEROS: Object to the form. 21 MR. MEROS: Object to form. 22 THE WITNESS: Not necessarily, no. 22 THE WITNESS: I'm not even sure I did any 23 BY MR. KING: 23 analysis on these maps. 24 Q Did you send them on to your group of 24 BY MR. KING: 25 Republican political consultants? 25 Q Well, the question was, did you think it was 169 171 1 A I don't recall, but if I did, it would be in 1 okay for you to do that, and then tell Cannon and 2 my production. 2 Pepper and the rest of those folks at the House, staff 3 Q I mean, this was kind of a, I mean, you were 3 or legislators about it? 4 kind of getting ahead of everybody by getting a chance 4 MR. MEROS: Object to form. 5 to look at these congressional maps before they were 5 MR. ZAKIA: Same. 6 even exposed publicly; right? 6 MR. BROWN: Foundation, object. 7 A Apparently, yes. 7 THE WITNESS: Ask that question again. 8 Q And so then you could take these maps and 8 BY MR. KING: 9 decide which ones performed best for your candidates, 9 Q Okay. See he gets me out of trouble here 10 right? 10 when he, when I have to ask the question again because 11 A I didn't have any congressional candidates. 11 it was a bad question. Let's try it again. 12 Q Well, you could determine how these maps 12 Are you saying you think it was okay for you 13 performed, right -- 13 to pass information about those maps after you got that 14 A I could. 14 preview of them to the people that sent them to you? 15 Q -- politically? 15 MR. MEROS: Object to form. Foundation. 16 A I could have done that, yes, sir. 16 MR. ZAKIA: Same objection. 17 Q And did you? 17 THE WITNESS: I don't know if it was okay or 18 A I don't recall. I think it is less likely 18 not okay. 19 that I did on the congressional maps. 19 BY MR. KING: 20 Q I mean, you, didn't you advise Mr. Pepper 20 Q Well, did you think you were involved in 21 which of these maps you thought would be best for the 21 something you shouldn't be involved in when you 22 Republican Party? 22 received those congressional maps? 23 MR. MEROS: Object to the form. 23 A No, sir. 24 MR. ZAKIA: Object to the form. 24 Q You thought that was fine? 25 THE WITNESS: I don't recall doing that. 25 A I answered the question, no, sir. 13 (Pages 168 to 171) WWW.USLEGALSUPPORT.COM 954-463-2933 172 174 1 Q Glad to get them when you got them? 1 the public did? 2 A I answered the question. No, sir. 2 A I don't recall. I don't recall seeing it. 3 Q No, I mean you were glad -- we are moving on. 3 Q Okay, you don't recall seeing it. Now, do 4 New question. You were glad to get the maps when you 4 you recall that shortly after you got these maps you 5 got them, right? 5 were involved in a lengthy e-mail discussion with Dean 6 MR. ZAKIA: Object to form. 6 Cannon and Kirk Pepper about a number of issues 7 THE WITNESS: I mean, I don't recall whether 7 involving redistricting? Do you remember that? 8 I was glad or not glad. 8 A Yes, sir. 9 BY MR. KING: 9 Q And that occurred the weekend of November 26 10 Q I mean, knowledge is power, right? 10 and November 27, right? 11 MR. MEROS: Object to form. 11 A I believe so. 12 THE WITNESS: I mean, I don't know how to 12 Q Right about three or four days after you got 13 answer that question. 13 these congressional maps, right? 14 BY MR. KING: 14 A Apparently. 15 Q As a political consultant, you've gotten 15 Q And this weekend was a period when neither 16 these things way ahead of the general public, so you 16 the House nor the Senate maps had been disclosed 17 are in a position to analyze them and advise about 17 publicly; isn't that correct, sir? 18 them, right? 18 A I believe so. 19 MR. MEROS: Object to form. 19 Q The Senate maps were disclosed on the 28th of 20 THE WITNESS: What I'm saying is I don't know 20 November, right? 21 that I even did any of that, so. I don't recall. 21 A I don't remember specific dates, but if you 22 BY MR. KING: 22 say -- 23 Q Isn't it correct, sir, that the Speaker of 23 Q I think we will run across that in these 24 the House, Dean Cannon, wanted your advice about these 24 e-mails that we are going to talk about. 25 congressional maps? 25 A That's fine, sure. 173 175 1 A I mean, I don't recall specifically. He may 1 Q And then the House maps were disclosed on the 2 have. I don't recall. 2 6th of December, as we've seen from that Exhibit 27, 3 Q All right. And I mean, Mr. Pepper would not 3 right? 4 have sent you these maps if Dean Cannon didn't want him 4 A Okay. 5 to do it, would he? 5 Q And isn't it a fact, sir, that Dean Cannon 6 MR. ZAKIA: Object to the form. 6 was very interested in your and Mr. Heffley's ideas 7 MR. MEROS: Object to the form. 7 about these maps? 8 THE WITNESS: You would have to ask Kirk 8 MR. MEROS: Object to form. 9 Pepper. I don't know. 9 THE WITNESS: I don't recall that 10 BY MR. KING: 10 specifically. 11 Q Well, would you expect Kirk Pepper typically 11 (Whereupon, the next document was marked as 12 would do -- follow the instructions of Dean Cannon? 12 Deposition Exhibit No. 28.) 13 A I can't answer a question for Kirk Pepper. 13 BY MR. KING: 14 Q Okay. You don't have any idea about that? 14 Q I show you, sir, Exhibit 28, and ask you if 15 A I don't have any idea. 15 you recognize that as a November 26, 2011, e-mail. Up 16 Q Okay. By the way, was there any public 16 at the top it is from Kirk Pepper to Marc 17 disclosure, to your knowledge, that you as a political, 17 Reichelderfer. And there is a series of e-mails that 18 Republican political consultant, was getting the maps 18 precede it, right? 19 two weeks ahead of the public? 19 A Yes. 20 A I don't, I don't know. 20 Q And this comes from your files and records, 21 Q Did you ever see any? 21 correct? 22 MR. MEROS: Ever see any? 22 A Yes, sir. 23 BY MR. KING: 23 Q These are e-mail exchanges that you engaged 24 Q Ever see any disclosure, public disclosure of 24 in with Kirk Pepper and Dean Cannon on November 25th 25 the fact that you received the maps two weeks before 25 and 26th of 2011; right? 14 (Pages 172 to 175) WWW.USLEGALSUPPORT.COM 954-463-2933 176 178 1 A Correct. 1 congressional plan, or a Senate plan or a House plan? 2 Q And it starts out evidently with Mr. Pepper 2 A It says CD on there, so I would -- 3 proposing that you fine gentlemen, referring to you and 3 Q So that makes it a congressional plan? 4 Dean Cannon, talk about getting together to talk on 4 A I would assume it was a congressional plan. 5 either Saturday or Sunday, either with your families 5 Q So you are being exposed to a discussion 6 and you -- you fellows would go off and sequester 6 about how the congressional plan is being formed, 7 yourselves in a room for an hour or so, or just meet 7 right? 8 without your families; right? 8 A Appears to be, yes, sir. 9 A Right. 9 Q But I thought that is something you weren't 10 Q And you indicated that you would be willing 10 supposed to be involved with. 11 to meet with the Speaker whatever his pleasure was, 11 A I don't know. This e-mail says that I am. 12 right? 12 Q Well, you are being exposed to this 13 A Yes, sir. 13 information, right? 14 Q So you assumed that this was a meeting being 14 A On this particular case, I was exposed to 15 called for by the Speaker, right? 15 information. 16 MR. ZAKIA: Object to the form. 16 Q Mr. Pepper is deliberately passing this 17 BY MR. KING: 17 information along to you, right? 18 Q Even though the message came from Kirk 18 A I believe there is information being passed 19 Pepper. 19 along to me, yes. 20 MR. MEROS: Object to form. 20 Q And when information is passed along to you 21 MR. ZAKIA: Object to form. 21 like that, it gives you the opportunity to pass 22 THE WITNESS: I don't know specifically. 22 information back to Mr. Pepper and Dean Cannon, doesn't 23 Possibly there is a longer version of this, there 23 it? 24 was stuff before that would give more context. 24 MR. MEROS: Object to form. 25 BY MR. KING: 25 THE WITNESS: I don't know that it makes that 177 179 1 Q Okay. And then up at the top of the page 1 assumption, no. 2 there is reference on Saturday to an e-mail from Alex, 2 BY MR. KING: 3 right? 3 Q Not making an assumption, I'm just saying you 4 A Yes, sir. 4 have the opportunity to do that, right? 5 Q Now, that is Alex Kelly? 5 A Opportunity to, I suppose. 6 A I don't know for certain, but -- 6 Q I mean they are involving you in the map 7 Q That's what you believe it to be? 7 drawing and making, isn't that right? 8 A Probably, yes, sir. 8 A I don't, I don't think that's the case here, 9 Q Okay. And Alex says, quote, I did a version 9 no. 10 that makes Hernando whole, makes 3,500 people worth of 10 Q Well, you are being provided information from 11 changes to Lake then Polk then Hillsborough then 11 the guy that is supposed to be doing it, right? 12 Pinellas, period. And I switched the Pinellas portion 12 A Yes. 13 of CD 24 to be the entirety of Tarpon Springs, rather 13 Q That's Alex Kelly, right? 14 than northeast Pinellas. To take CD 24 out of Pinellas 14 A Yes, sir. 15 completely, it requires a bigger discussion about 15 Q He is the House man on redistricting, right? 16 things the Speaker has said are important to him. End 16 A Yes, sir. 17 quote. 17 Q The plans were coming out of his office, 18 Do you see that language? 18 right? 19 A Yes, sir. 19 A Yes, sir. 20 Q Now, in the first place, Mr. Pepper is 20 Q Okay. And the plans haven't come out of his 21 exposing you to statements that a House staffer is 21 office at this point because we are still on November 22 making about how he is in the process of composing a 22 the 26th, right? 23 plan, right? 23 A I believe so. 24 A Appears to be, yes, sir. 24 Q So this is all going on outside the view of 25 Q Do you know whether this was a plan, a 25 the public, right? 15 (Pages 176 to 179) WWW.USLEGALSUPPORT.COM 954-463-2933 180 182 1 A I would believe that Alex's correspondence 1 know. 2 would be a public record. This was made on a public 2 MR. MEROS: Excuse me. You guys keep talking 3 records request. 3 over each other. You both jump in. Please stop 4 Q Through his gmail account? 4 that. 5 A Yeah. Or Alex's whatever, yes. 5 BY MR. KING: 6 Q Well, Alex somehow passed it to Kirk. Now 6 Q Did you, did you talk to other political 7 that's, that's okay, right? 7 consultants to see if they had the maps? 8 A Yes, sir. 8 MR. BROWN: Object to form. 9 Q Kirk is involved with Alex, they work for the 9 THE WITNESS: I don't recall. 10 same place, right? 10 (Whereupon, the next document was marked as 11 A Yes, sir. 11 Deposition Exhibit No. 29.) 12 Q But then Kirk provides it to you, right? 12 BY MR. KING: 13 A Our public records law would allow you to 13 Q I show you Exhibit 29 and ask you if you 14 make a public records request of the correspondence 14 recognize that as an e-mail from Kirk Pepper to you on 15 between Kirk Pepper and Alex Kelly. 15 November 27th, Sunday, November 27th at 1:17 p.m. 16 Q And so did you know what he was talking about 16 A Okay. Yes, sir. 17 when he said there is a bigger discussion about the 17 Q And that again comes from your records. 18 things the Speaker has said are important to him? 18 A Yes, sir. 19 A I don't recall. 19 Q So evidently, you all had chosen not to get 20 Q I mean you generally knew what was important 20 together on Sunday afternoon, right? 21 to the Speaker about issues that he was consulting with 21 A I don't recall specifically, but the e-mail 22 you about, isn't that right? 22 certainly seems to indicate that. 23 MR. MEROS: Object to form. 23 Q And so you are talking about maybe just try 24 THE WITNESS: Generally, yes, but I dealt 24 to get together on Monday, right? 25 with him on a lot of issues outside of 25 A I believe so. 181 183 1 redistricting. 1 Q And then it indicates there that you get the 2 BY MR. KING: 2 question, is it accurate the Senate is putting out the 3 Q Well, at this point, though, redistricting 3 Senate and congressional maps tomorrow midday. 4 was very much in the forefront, right? 4 Do you see that? 5 A As Speaker of the House, he was dealing with 5 A Yes, sir. 6 a lot of issues. It certainly wasn't the majority of 6 (Whereupon, the next document was marked as 7 what he was dealing with at that point. 7 Deposition Exhibit No. 30.) 8 Q I'm not talking about percentages. It was an 8 BY MR. KING: 9 important issue, isn't that right? 9 Q I show you, sir, Exhibit 30. Would it be 10 A Yes. 10 correct in Exhibit 30 on November 27, at 1:54 you 11 Q And it was an important issue that, to you, 11 answered the question that was pending in Exhibit 29, 12 personally, right? 12 which is, quote, "This is what I was told, the 28. Not 13 A Yes. 13 sure what time." Right? 14 Q And it was an important issue that you were 14 A Yes, sir. 15 being exposed information about that nobody else had 15 Q So evidently you knew then that the maps were 16 access to that didn't work for the House or the Senate, 16 coming out of the Senate on the 28th. 17 right? 17 A It appears that I did. 18 A I don't know that's the case either. 18 (Whereupon, the next document was marked as 19 Q Well, was it your thought that Mr. Pepper was 19 Deposition Exhibit No. 31.) 20 sending these seven congressional plans that hadn't 20 BY MR. KING: 21 been exposed to the public to other political 21 Q I show you Exhibit 31, which appears to be an 22 consultants for the Republican Party, as well? 22 e-mail from Dean Cannon at 1:58 on November 27th, 2011, 23 A I don't know that either. I mean I don't 23 to you with a copy to Kirk. 24 know who had the maps at this point. So I can't speak 24 Do you see that as a document out of your 25 to who had the maps and didn't have the maps. I don't 25 files and records? 16 (Pages 180 to 183) WWW.USLEGALSUPPORT.COM 954-463-2933 184 186 1 A Yes, sir. 1 is a way to avoid those controversies? 2 Q And he says, quote, "Why would they put out a 2 A I guess certainly something like that. 3 map until we are sure it is one that is acceptable? I 3 Q So it is kind of an end run around the 4 guess, Marc, I need you to find out from Rich why they 4 difficulties between the House and the Senate staff? 5 would put out a map without everyone being comfortable 5 A I wouldn't necessarily call it an end run, 6 with it, unless I'm missing something." 6 but getting -- certainly when there is hang up between 7 Is that what you got back from Dean Cannon at 7 House and Senate staff, yes. 8 1:58 on November 27, 2011, sir? 8 Q And does Rich Heffley have a good ability to 9 A Yes, sir, that's what that says. 9 get to the people that make the decisions in the 10 Q Okay. Now, in the first place, weren't the 10 Senate? 11 House and the Senate supposed to be working separately 11 MR. ZAKIA: Object to form. 12 on these maps? 12 THE WITNESS: I don't know for certain, but 13 MR. MEROS: Object to form. 13 certainly -- 14 BY MR. KING: 14 BY MR. KING: 15 Q Independently? 15 Q Well, I guess my question is -- 16 A I don't know one way or the other. I don't 16 MR. BROWN: Wait, he hasn't finished. 17 know. I don't believe so. 17 MR. KING: I'm sorry. I'm sorry. 18 Q Well, Mr. Cannon was suggesting that he was 18 THE WITNESS: I mean, I would believe so. 19 seemingly unhappy about the idea that they were putting 19 BY MR. KING: 20 one out before he had determined it was acceptable; 20 Q Okay. My question was, my new question is, 21 right? 21 if, if you could have done that, there would have been 22 MR. MEROS: Object to form. 22 no reason to get Heffley involved; right? 23 MR. ZAKIA: Object to form. 23 MR. ZAKIA: Object to form. 24 THE WITNESS: I mean, I don't know. That 24 THE WITNESS: I don't recall specifically, 25 certainly what is suggested by the e-mail. 25 but I mean, sure. 185 187 1 BY MR. KING: 1 BY MR. KING: 2 Q Right. And he tasked you with the project of 2 Q I mean, did Heffley have better access to the 3 finding out from Rich why they put out a map without 3 decision makers in the Senate than you did? 4 everybody being comfortable with it. Right? 4 A Yes. 5 A That's correct. 5 Q Okay. And so that is why it made sense to 6 Q And did you contact Rich? 6 get him involved to find out from the Senate side, 7 A I don't recall, but I certainly probably did. 7 right? 8 Q And that's Rich Heffley, right, one of your 8 A Yes. 9 fellow Republican political consultants? 9 MR. KING: Why don't we take just a little 10 A Yes, sir. 10 short break and we will fill out some exhibit 11 Q And did he explain to you why they were 11 slips for you. 12 putting out a map before they had run it by the House? 12 THE VIDEOGRAPHER: The time is 2:25 p.m. We 13 A I don't recall. 13 are off the record. 14 Q You just have no recollection of that? 14 (Brief recess.) 15 A I mean, I had lots of conversations. I don't 15 THE VIDEOGRAPHER: The time is 2:47 p.m. We 16 recall that specific conversation, you know, as to why 16 are back on the record. 17 they would or wouldn't be doing that. 17 MR. BROWN: Before you begin your 18 Q Well, do you know why Dean Cannon would use 18 questioning, I would just like to note for the 19 you and Rich Heffley to find out what was happening 19 record that Mr. Reichelderfer has been the last of 20 over in the Senate? 20 us to succumb to the heat in this room, and has 21 A Yes, sir. 21 taken his coat off for this portion of this 22 Q Why? 22 proceedings. 23 A Lets just say that the House and Senate staff 23 MR. KING: He is welcome to do that. 24 at times don't get along very well. 24 Hopefully it will be more comfortable for him. 25 Q Okay. And so using the political consultants 25 (Mr. Healey not present.) 17 (Pages 184 to 187) WWW.USLEGALSUPPORT.COM 954-463-2933 188 190 1 (Whereupon, the next document was marked as 1 Q Okay. But you had a good relationship with 2 Deposition Exhibit No. 32.) 2 Clark, his staffer, right? 3 BY MR. KING: 3 A Yes, sir. 4 Q Okay, sir. Continuing looking at that series 4 Q Okay. And so you were getting information 5 of e-mails that occurred on the 27th of November, I 5 from Gaetz about when they were putting the maps out, 6 show you, sir, Exhibit 32, and ask you if you recognize 6 right? 7 that as an exhibit from your files and records, an 7 A I believe so. 8 e-mail from you to Dean Cannon and a copy to Kirk 8 Q And did they tell you at the Senate that they 9 Pepper on November 27, 2011, at 2:14 p.m. 9 wanted to see a copy of what the House was working on 10 Is that one of your documents, sir? 10 to try to get their map as close to the House as is 11 A Yes, sir. 11 possible? 12 Q And so, and you authored the e-mail right 12 A I don't, I don't believe so, no. 13 there at the top, the three line e-mail back to Dean 13 Q Well, if they didn't tell you that, why did 14 Cannon; right? 14 you put that in the e-mail here? 15 A Yes, sir. It appears so. 15 A No, I mean I'm talking about, I'm talking 16 Q And you're answering his question about why 16 about they didn't ask me for copies of the House maps. 17 they put out, wouldn't, would put out a map until we 17 I'm saying, I'm sure that the House and 18 are sure that one is acceptable, right? 18 Senate staff were sharing maps with each other. I 19 A It appears to be that. Also, I guess based 19 don't think there was anything wrong with that. 20 on the previous question, did I reach out to Rich 20 Q Well, they told you they wanted to see a copy 21 Heffley, I suppose I did not reach out to Rich Heffley. 21 of what the House was working on last week, right? 22 Instead, I just responded to the Speaker. 22 A That, probably, yes. 23 Q And you say, quote, "The Senate had already 23 Q And the reason they wanted to see it was 24 announced that they were putting maps out on the 28th, 24 because they wanted to get their map as close as 25 and that is exactly what Gaetz told us last week. The 25 possible to the House's, right? 189 191 1 reason they wanted to see a copy of what the House was 1 A I believe that's probably the case. 2 working on last week was to try and get their maps as 2 Q But wasn't the public story being put out 3 close as to the House's as possible. That is why they 3 about this redistricting process, that the two 4 were a bit concerned over how the House map looked." 4 legislative bodies were agenting independently and 5 Is that what you said? 5 separately? 6 MR. MEROS: Excuse me one minute. It is 6 MR. MEROS: Object to form. 7 Senator Gaetz. 7 THE WITNESS: I don't know that that's the 8 BY MR. KING: 8 case. 9 Q Gaetz, okay. Gaetz. So, is that what you 9 BY MR. KING: 10 said, sir? 10 Q Well, it certainly wasn't the case evidently. 11 A I believe so. 11 Right? 12 Q Okay. So you had had some conversation with 12 MR. ZAKIA: Object to form. 13 Senator Gaetz the week before? 13 THE WITNESS: No, I don't know that was being 14 A I don't know if it was a conversation or 14 said publicly, that the House and Senate were 15 whether it was a, in the form of a meeting, or if it 15 going to work together. 16 was something in the press. I don't remember, 16 BY MR. KING: 17 specifically. 17 Q Well, had they gotten the House map? 18 Q Well, you say, "Gaetz told us last week." 18 A I don't remember specifically; but according 19 That doesn't sound like something you read in the 19 to this e-mail, it certainly appears that that 20 paper. 20 happened. 21 A No, it was probably something he said 21 (Whereupon, the next document was marked as 22 somewhere, yes. 22 Deposition Exhibit No. 33.) 23 Q Is he one of your, I've forgotten, was he 23 BY MR. KING: 24 your client? 24 Q Okay. Then I show you, sir, Exhibit 33 in 25 A No, sir. 25 the chain. And Dean Cannon responds back to what you 18 (Pages 188 to 191) WWW.USLEGALSUPPORT.COM 954-463-2933 192 194 1 wrote on November 27, 2011, to both you and to 1 ought to do. Isn't that right? 2 Mr. Pepper; right? 2 A Correct, yes, sir. 3 A Yes, sir. 3 Q You had advised him about what your and 4 Q And Mr. Reichelderfer, what he says is, 4 Rich's concerns about the maps were, isn't that right? 5 quote, "Well, as long as the Senate accommodates the 5 A That's what this e-mail says, yes, sir. 6 concerns that you and Rich identified in the map that 6 Q Right. But the map, or the e-mail doesn't 7 they put out tomorrow, then we are in fine shape. How 7 really mention what the concerns were -- 8 confident are you that they are going to do that?" 8 A No, sir. 9 Is that what he said, sir? 9 Q -- does it? 10 A Yes, sir. 10 A No, sir, it does not. 11 Q So evidently, you and Rich Heffley had 11 Q None of this chain of e-mails mentions what 12 identified in the maps that evidently the Senate was 12 your concerns about the maps were, do they? 13 going to put out on the 28th some concerns, right? 13 A No, sir. 14 A Apparently, yes, sir? 14 Q And these e-mails, when they provide you the 15 Q And what were those concerns? 15 congressional plans to look at and examine, the seven 16 A I don't recall specifically. 16 plans, they don't say anything about what they expect 17 Q Well, the reason you and Rich were looking at 17 you to do about them, do they? 18 them to see, was to see how they performed politically; 18 A No, sir. 19 isn't that right, sir? 19 Q And you do find concerns in the map. And you 20 MR. MEROS: Object to form. 20 identify concerns, and those were supposed to be being 21 MR. ZAKIA: Same objection. 21 fixed in the Senate when they put out the maps, right? 22 THE WITNESS: Not necessarily, no, sir. 22 A Apparently, yes, sir. 23 BY MR. KING: 23 Q And in fact, were they fixed in the maps that 24 Q I mean that was what you were primarily 24 were exposed on, by the Senate on the 28th of November? 25 interested in regarding those maps; wasn't it, sir? 25 MR. ZAKIA: Object to form. 193 195 1 A Not necessarily, no, sir. 1 THE WITNESS: I don't recall. 2 Q Whether it was putting incumbents up against 2 BY MR. KING: 3 each other, or whether it was going to perform 3 Q It appears that you and Rich were being used 4 appropriately for the Republican Party, right? 4 as the go-betweens between the House and the Senate, 5 MR. MEROS: Object to form. 5 right? 6 THE WITNESS: There are a variety of issues 6 MR. ZAKIA: Object to form. 7 above and beyond performance of those issues. 7 THE WITNESS: I don't know specifically as 8 BY MR. KING: 8 go-betweens, but occasionally when there were -- 9 Q And Dean Cannon was basically saying that if 9 BY MR. KING: 10 the Senate can deal with your and Rich's concerns, then 10 Q Well -- 11 we are okay. Right? 11 MR. BROWN: Let him finish his answer. 12 MR. MEROS: Object to form. Go ahead. 12 BY MR. KING: 13 THE WITNESS: I'm sorry, ask that question 13 Q I'm sorry. Excuse me. 14 again. 14 A Occasionally when there may have been some 15 BY MR. KING: 15 hostilities between the positions of the two different 16 Q I mean, Dean Cannon was saying that if the 16 bodies, we would be contacted. 17 Senate is okay with your concerns, your and Rich's 17 Q Let me make sure I understand the way this 18 concerns, then we are going to be in fine shape. 18 worked here. You got the maps. You and Rich got the 19 A That's what the Speaker says here. 19 maps and looked at them, right? These maps that are 20 Q And he was relying heavily on you and 20 referred to in this e-mail? 21 Mr. Heffley, Republican political consultants, to look 21 A Yes, sir. I don't know that they, I don't 22 over these maps carefully and advise him about what he 22 know that Rich got them. 23 ought to do. Isn't that right? 23 Q Well, it says you and Rich identified 24 A I don't know that I agree with that. 24 concerns in the map. So evidently you were both 25 Q Well, you had been advising him about what he 25 involved, weren't you? 19 (Pages 192 to 195) WWW.USLEGALSUPPORT.COM 954-463-2933 196 198 1 A "Well, as long as the Senate accommodates the 1 all, do you, sir? 2 concerns that you and Rich identified in the map that 2 A I don't, I do know that there were concerns 3 they put out tomorrow, then we are in fine shape." 3 at a global level that we discussed. So I do have a 4 I guess. I don't, I don't remember 4 knowledge of global concerns -- 5 specifically seeing the Senate map, but -- 5 Q Well, what global concerns had you discussed 6 Q Well, it says, but the Senate was putting out 6 about the maps? 7 both Senate and congressional maps, weren't they? 7 A I think that in order to comply with the 8 A Yes, sir. 8 federal voters rights act, that we thought it was 9 Q All right. So you and Rich had been provided 9 important that minority districts not retrogress. And 10 the maps to look at and found some concerns, right? 10 that minority districts that could be drawn at majority 11 MR. ZAKIA: Objection. Which map are you 11 minority districts, you would want to comply with that, 12 referring to? 12 as well. 13 MR. KING: The map he is referring to in this 13 Q That's your global concerns about the Senate 14 e-mail. 14 maps? 15 MR. ZAKIA: I'm just asking because you keep 15 A Those were things that we thought should be 16 switching between the singular and the plural. 16 accommodated in the plan. 17 MR. KING: You are right. The map. 17 Q Well, have you developed concerns that the 18 BY MR. KING: 18 Senate wasn't aware of the terms of the amendment and 19 Q Just so we are clear, I'm asking about the 19 wasn't dealing with minority districts? 20 map that you are referring to in this e-mail, the one 20 A I think there was a variety of debates from 21 you and Rich examined and found concerns in, right? Do 21 lawyers as to whether or not you had to have majority 22 you understand that? 22 minority in a district, or whether or not 23 A Yes, sir. 23 retrogression -- there was a debate as to whether or 24 Q Okay. We are on the same wave length. 24 not that violated the federal voters right act. 25 A But I would also read this as this could 25 Q Is it your testimony under oath here today, 197 199 1 potentially be read from the standpoint that our 1 sir, that when you said, when Mr. Cannon referred to 2 concerns were not specific to a specific map. They 2 the concerns you and Rich identified in the map, you 3 were specific to issues related to drawing a map. 3 are telling us now that it was minority issues? 4 And that is, that's totally different than 4 A I did not say that, sir. 5 actually commenting on a specific map. 5 Q Okay. So -- 6 Q Well, that's an interesting interpretation; 6 A I merely said that you were interpreting this 7 but, of course, the language in the e-mail said -- and 7 e-mail to read one way. I don't have a recollection of 8 this is Dean Cannon talking, a man that I assume picks 8 this specific e-mail. 9 his words carefully -- he says, the concerns you and 9 And I'm merely stating that there is another 10 Rich identified in the map. Right? 10 way to read this e-mail. And that could have been the 11 A It actually says as long as the Senate 11 case. I'm not saying it was or wasn't. 12 accommodates -- 12 Q But certainly one way to read the e-mail is 13 Q Right. 13 that you and Rich had seen some maps and identified 14 A -- the concerns that you and Rich identified 14 some concerns on them, right? 15 in the map they put out tomorrow. Not that we saw the 15 MR. BROWN: Objection. Argumentative. Asked 16 map they put out tomorrow. But if Rich and I had 16 and answered. 17 global concerns about certain things that should be 17 MR. ZAKIA: Object to the form. 18 included in a map, it reads, as long as the Senate 18 BY MR. KING: 19 accommodates the concerns that you and Rich 19 Q You can go ahead and answer. 20 identified -- from a global perspective, not from a 20 A I don't know that's the case. 21 specific perspective -- in the map they put out 21 Q That would be one way to read it though, 22 tomorrow. 22 wouldn't it? 23 Q But you don't remember that, you are just 23 MR. BROWN: Objection, argumentative, and 24 interpreting now this language. You don't have a 24 lack of foundation. 25 specific recollection of what those concerns were at 25 BY MR. KING: 20 (Pages 196 to 199) WWW.USLEGALSUPPORT.COM 954-463-2933 200 202 1 Q You may answer the question. 1 MR. KING: Sure. 2 MR. BROWN: You can answer the question. 2 (Brief pause.) 3 THE WITNESS: Yes. 3 MR. KING: Okay. Ready? 4 BY MR. KING: 4 MR. MEROS: Yes. 5 Q Thank you, sir. Now, this would also 5 BY MR. KING: 6 indicate, wouldn't it, sir, that you and Rich had seen 6 Q So do you see this e-mail and this -- 7 the Senate maps before they were released to the 7 A Yes. 8 public? 8 Q Is this the e-mail that comes from your files 9 MR. ZAKIA: Object to the form. And -- 9 and is that what you said, sir -- 10 MR. KING: Senate map, map. Excuse me. 10 A Yes, sir. 11 MR. ZAKIA: Thank you. 11 Q -- about the Senate map? 12 BY MR. KING: 12 A Yes, sir. 13 Q I will say it again. 13 (Whereupon, the next document was marked as 14 A I'm sorry. I -- 14 Deposition Exhibit No. 35.) 15 Q Yeah, let me do it again. He gets me every 15 BY MR. KING: 16 time on that one and he is right, which is painful. 16 Q And then, sir, I show you Exhibit 35 and ask 17 Wouldn't this indicate, this e-mail indicate, 17 you if you recognize that as a November 27, 2011, 18 that you and Rich had seen the Senate map before it was 18 e-mail in the same chain where Kirk Pepper says to you 19 released to the public? 19 and Dean Cannon, quote, "We already announced that we 20 MR. ZAKIA: Object to form. 20 were putting out House Senate and congressional maps 21 THE WITNESS: Not based on the previous 21 three weeks ago, but when they freaked out because it 22 interpretation of the wording of this e-mail. 22 wasn't exactly as they demanded, we changed course. 23 BY MR. KING: 23 Want to place a bet on whether they are willing to do 24 Q So it depends on how we interpret the e-mail, 24 the same." 25 right? 25 Do you see that language? 201 203 1 A It depends on what -- it depends on what the 1 A Yes, sir. 2 Speaker was writing here. 2 (Whereupon, the next document was marked as 3 Q Yeah. 3 Deposition Exhibit No. 36.) 4 A I don't recall seeing the Senate map before 4 BY MR. KING: 5 they put it out. 5 Q And then I show you Exhibit 36 and ask you if 6 Q But if the Speaker's words mean what they 6 you recognize another e-mail in the chain on 7 say, that would seem to suggest that you saw this 7 November 27, 2011, from Dean Cannon. And he says, 8 Senate map before it was put out didn't you? 8 quote, "And what does" -- no, from Kirk Pepper to Dean 9 MR. BROWN: Objection. Argumentative. 9 Cannon. 10 MR. ZAKIA: Objection, form. 10 He says, quote, "And what does their map look 11 THE WITNESS: I don't agree with that 11 like? We have shared everything they have asked, they 12 statement. 12 haven't showed us shit." 13 (Whereupon, the next document was marked as 13 Do you remember that e-mail in the chain? 14 Deposition Exhibit No. 34.) 14 A Yes, sir. 15 BY MR. KING: 15 Q So there is some little tense feelings 16 Q Okay. And then, sir, I show you Exhibit 34, 16 between the House and the Senate? 17 and ask you if you recognize that as another in this 17 A That was the acrimony I previously described. 18 series where on November 27, 2011, you say, in response 18 (Whereupon, the next document was marked as 19 to an e-mail from Mr. Pepper, isn't that what they 19 Deposition Exhibit No. 37.) 20 freaked out at us for. 20 BY MR. KING: 21 You say no, they were upset. The House was 21 Q Right. Then I show you Exhibit 37 and ask 22 releasing a Senate map. They did not care if the House 22 you if you recognize that e-mail from Dean Cannon back 23 rolled out a House and congressional map. 23 at 2:21 to Kirk Pepper, a copy to you, where he says, 24 MR. MEROS: Could you just stop there a 24 quote, "Everybody stop e-mailing and I will call you 25 minute and let us take a look at this? 25 shortly. Just calm down. I am with my son, and we are 21 (Pages 200 to 203) WWW.USLEGALSUPPORT.COM 954-463-2933 204 206 1 having fun, and I do not want to discuss this any 1 supposed to do with the other seven maps you got, 2 further until we talk." 2 right? 3 Do you see that? 3 A Yes, sir. 4 A Yes, sir. 4 Q The other seven congressional maps, from 5 Q Did he call you and did you talk? 5 Mr. Pepper, right? 6 A I don't recall specifically. That was a long 6 A Yes, sir. 7 time ago. 7 Q But of course, you knew what you were 8 Q You don't have any recollection of what he 8 supposed to do; isn't that right? 9 might have said? 9 A I don't know that to be the case, sir. 10 A I do not. 10 Q You knew that you were looking at those maps 11 Q But you and Kirk didn't stop e-mailing that 11 to determine how they performed and advise your client, 12 day, right? 12 and the Speaker of House, Dean Cannon, on what they 13 A If you say so. 13 should do with those maps, right? 14 (Whereupon, the next document was marked as 14 MR. MEROS: Object to form. 15 Deposition Exhibit No. 38.) 15 THE WITNESS: I don't know that for certain. 16 BY MR. KING: 16 BY MR. KING: 17 Q Well, let me show you Exhibit 38, which is an 17 Q Well, you say you don't know it for certain, 18 e-mail that comes at 2:50 on November 27, 2011. And 18 but can you think of another good reason why they would 19 ask you if you recognize that as a document from your 19 send you those maps before the public got them? 20 files and records? 20 MR. ZAKIA: Object to form. 21 A Yes, sir. 21 THE WITNESS: Yes, sir. 22 Q That is an e-mail you received from Kirk on 22 BY MR. KING: 23 November 27, 2011; right, sir? 23 Q What was that? 24 A Yes, sir. 24 A Again, looking at minority retrogression in 25 Q And he said, "Here's a link to Congressional 25 minority districts. 205 207 1 8.kmz in my Dropbox." 1 Q Did you have some specialty in minority 2 Do you see that? 2 retrogression or looking at minority districts? 3 A Yes, sir. 3 A No. I did spend some time working on a few 4 Q And so you went to that Dropbox and you 4 minority districts, only because it is an intellectual 5 pulled it down, right? 5 operation to do some of these, because it is like a 6 A Yes, sir. 6 jigsaw puzzle. It is sometimes difficult to accomplish 7 Q And that is yet another congressional map 7 those goals. 8 prepared by the House redistricting committee, right? 8 Q And then you got, Exhibit 39 later in the 9 MR. MEROS: Object to form. 9 day. 10 THE WITNESS: It would be an assumption on my 10 (Whereupon, the next document was marked as 11 part; but yes, I would assume so. 11 Deposition Exhibit No. 39.) 12 BY MR. KING: 12 BY MR. KING: 13 Q You thought it was a congressional map 13 Q You recognize that as a document you received 14 prepared by the House redistricting committee when you 14 from your, from Mr. Pepper? 15 received it back on November 27, 2011; didn't you? 15 A Yes, sir. 16 A I don't recall specifically, but I would 16 Q Did you advise Dean Cannon on which of these 17 guess so. 17 maps he ought to utilize in the House? 18 Q All right. And this was yet another 18 A I don't believe so. No. 19 congressional map evidently that you had received 19 Q Do you deny that you did that, sir? 20 before the public got any shot at it, right? 20 MR. ZAKIA: Object to the form. 21 A Yes, sir. 21 MR. BROWN: Object to the form. 22 Q And the -- now, they don't say in this e-mail 22 Argumentative. 23 what you are supposed to do with this map, do they? 23 THE WITNESS: I don't know for certain. 24 A No, sir. 24 BY MR. KING: 25 Q Just like they didn't say what you were 25 Q You don't know for certain whether you 22 (Pages 204 to 207) WWW.USLEGALSUPPORT.COM 954-463-2933 208 210 1 advised him or not? 1 (Whereupon, the next document was marked as 2 A No, sir. 2 Deposition Exhibit No. 40.) 3 Q So that would seem to suggest that you could 3 BY MR. KING: 4 have advised him, right? 4 Q I show you Exhibit 40, which comes a little 5 MR. ZAKIA: Object to form. 5 later. Now we are at 10:00 o'clock, 10:09 p.m. at, on 6 THE WITNESS: I don't know either way. 6 Sunday night. 7 BY MR. KING: 7 A Okay. 8 Q When I say advised him, I also include 8 Q And you are responding to the congressional 9 Mr. Pepper, because you gave Mr. Pepper advice about 9 map that has been sent to you by Dropbox. 10 these maps; didn't you? 10 A Yes, sir. 11 A I don't recall specifically. 11 Q And you say, quote, "It is workable. The 12 Q You understood that when you were advising 12 pieces are mostly in the right place, it is just a bit 13 Mr. Pepper, that's the same thing as advising 13 rough." Right? 14 Mr. Cannon; isn't it? 14 A Yes, sir, I did. 15 MR. MEROS: Object to form. 15 Q So you are giving him advice about the plans, 16 BY MR. KING: 16 aren't you? 17 Q His chief of staff? 17 A I would suppose that could be construed as 18 A Not necessarily. 18 advice, yes. 19 Q Well, I mean, if you were providing advice 19 Q And as a partisan political consultant, you 20 about the maps to Mr. Pepper, you would expect 20 are participating in providing information to the folks 21 Mr. Pepper to provide that information to Dean Cannon; 21 that are going to make the decisions about which of 22 wouldn't you? 22 these plans are going to be adopted; isn't that right? 23 MR. BROWN: Object to the form of the 23 A I don't know that this particular piece of 24 question. Go ahead and answer if you can. 24 advice is very specific in any way, shape, or form. 25 THE WITNESS: He may or may not. I would not 25 Q Well, it is very cryptic, isn't it? 209 211 1 know that for certain. 1 MR. ZAKIA: Object to form. 2 BY MR. KING: 2 THE WITNESS: I don't believe so. 3 Q But you knew in the past that on a regular 3 BY MR. KING: 4 basis Pepper had posed questions to you or asked 4 Q But you gave your advice to him not only in 5 information from you on behalf of his boss, Dean 5 e-mails, but in personal conversations, and telephone 6 Cannon; right? 6 conversations; isn't that right? 7 MR. BROWN: Object to the form of the 7 A I don't recall specifically. I don't recall. 8 question. 8 Q And this process is all going on before any 9 THE WITNESS: Could you ask that question 9 of these maps are exposed to the public, right? 10 again? 10 A I believe so. 11 BY MR. KING: 11 Q And nobody is telling anybody about your 12 Q Didn't you know in your past experience in 12 participation as a partisan political consultant in 13 dealing with your client, Dean Cannon, and his 13 this process; right? 14 employee, Mr. Pepper, that in the past Mr. Pepper had 14 A Not that I know of. 15 asked you for information that was being passed on to 15 Q And by this time you have done performance 16 Mr. Cannon? 16 analyses of these congressional maps, isn't that 17 A In some cases, yes. 17 correct, sir? 18 Q And you didn't think that these maps were 18 MR. ZAKIA: Object to the form. 19 being exposed to you for no purpose at all, right? 19 MR. MEROS: Object to the form. 20 A Probably not. 20 THE WITNESS: I don't know that that is the 21 Q And in each case when you got these 21 case. 22 congressional maps, you looked at them and you gave 22 BY MR. KING: 23 those fellows some advise about them; didn't you, sir? 23 Q Well, do you deny you have done it by now? 24 MR. BROWN: Objection, repetitive. 24 MR. ZAKIA: Same objection. 25 THE WITNESS: I don't recall. 25 BY MR. KING: 23 (Pages 208 to 211) WWW.USLEGALSUPPORT.COM 954-463-2933 212 214 1 Q You can go ahead. 1 (Whereupon, the next document was marked as 2 A No, sir. 2 Deposition Exhibit No. 42.) 3 Q So first you say it is workable, and the 3 BY MR. KING: 4 pieces are mostly in the right place, but it is just a 4 Q Well, I do. I show you Exhibit 42, and ask 5 little rough. Then do you recall seeing another e-mail 5 you if you recognize Exhibit 42, which is 10:13, a 6 a little later in the evening? 6 couple more minutes later in the evening. 7 A No, sir. 7 A I do. 8 (Whereupon, the next document was marked as 8 Q And so Mr. Pepper was interested in knowing 9 Deposition Exhibit No. 41.) 9 what you were talking about, about Kirk -- about 10 BY MR. KING: 10 Webster's district; right? 11 Q All right. Let me show you Exhibit 41 and 11 A Yes, sir. 12 ask you if you recognize that e-mail. 12 Q And so he asked you, "Performance or 13 A Yes, sir. 13 geography," right? 14 Q That is dated November 27, 2011, at 14 A Yes, sir. 15 10:11 p.m. Right? 15 Q And then there is no e-mail back, is there? 16 A Yes, sir. 16 A I don't know. You may produce something. 17 Q So two minutes after you send Exhibit 40, you 17 Q I don't have another one. I don't have a 18 look at the map a little more and you send Exhibit 41, 18 response. Do you know why you didn't respond to it? 19 right? 19 A I do not, sir. 20 A Yes, sir. 20 Q But, of course, those were the two categories 21 Q And here you say, "Actually, the Webster seat 21 that you were very up on, as far as these maps are 22 is a bit messed up." Right? 22 concerned, the political performance, and the geography 23 A Yes, sir. 23 of the maps; right? 24 Q Again, very cryptically, you don't tell him 24 A Certainly that appears to be this question, 25 why, how it is messed up in that e-mail, right? 25 yes. 213 215 1 MR. MEROS: Object to form. 1 Q And that is the area of your expertise, as 2 THE WITNESS: No. 2 far as these maps were concerned; right? 3 BY MR. KING: 3 A A little bit on the geography and 4 Q But you later talk to him and explain to him 4 performance, yes, sir. 5 why you thought it was messed up, didn't you? 5 Q Right. You had researched the performance 6 MR. MEROS: Object to form. 6 and you were aware of the geography, right? 7 THE WITNESS: I don't know that's the case. 7 A I don't know that I had at that particular 8 BY MR. KING: 8 moment in time. He is asking a question. 9 Q Well, do you deny that you talked to him and 9 Q He wants to know why they were messed up. 10 told him how it was messed up? 10 A Yes. 11 MR. ZAKIA: No. 11 Q Why was it messed up? 12 THE WITNESS: No. 12 A I don't recall. 13 BY MR. KING: 13 Q You just don't remember? 14 Q Because Kirk Pepper was interested in knowing 14 A This was two years ago. It was in a chain of 15 why you thought the Webster seat was messed up, right? 15 e-mails. Do I remember specifically why I thought this 16 MR. ZAKIA: Object to form. 16 was messed up? No. 17 THE WITNESS: I don't know that he was. He 17 Q All right. But you were able to give your 18 may have been. You would have to ask him. 18 opinions about what you thought was wrong with these 19 BY MR. KING: 19 maps when they weren't even being exposed to the 20 Q Well, he wanted to know why it was messed up, 20 public, right? 21 didn't he? 21 A Apparently yes. 22 MR. ZAKIA: Object to form. 22 Q Okay. And actually, you had more fulsome 23 THE WITNESS: I don't know. Maybe you have 23 discussions with Mr. Pepper and Mr. Cannon about what 24 some more documents that could refresh my memory. 24 was wrong with these maps, isn't that right, sir, than 25 25 is revealed in these little scraps of e-mails we have? 24 (Pages 212 to 215) WWW.USLEGALSUPPORT.COM 954-463-2933 216 218 1 MR. MEROS: Object to the form of the 1 A No. I don't know that I agree with all the 2 question. 2 statements you made in there, but I did not have a 3 THE WITNESS: Can you repeat the question. 3 conversation with Lenny Curry. 4 BY MR. KING: 4 Q Well, this release from Lenny Curry made you 5 Q Sure. You had more fulsome discussions with 5 uncomfortable, didn't it? 6 Mr. Pepper and Mr. Cannon about the problems with these 6 A No, sir. 7 maps from your viewpoint, other than what we get from 7 Q Okay. Well, Mr. Pepper sends this e-mail 8 these e-mails that we've received; right? 8 with just a question mark up there at the top, right? 9 MR. MEROS: Same objection. 9 A Yes, sir. 10 THE WITNESS: I think there were probably 10 Q So you thought this was a fine statement that 11 additional conversations, yes. 11 he made? 12 (Whereupon, the next document was marked as 12 A I think -- yes. 13 Deposition Exhibit No. 43.) 13 (Whereupon, the next document was marked as 14 BY MR. KING: 14 Deposition Exhibit No. 44.) 15 Q Now, I show you Exhibit 43, and ask you if 15 BY MR. KING: 16 you recognize that from your file, which is an e-mail 16 Q Okay. Well then I show you Exhibit 44, sir, 17 of November 28, the very next day from Kirk Pepper to 17 and ask you if you recognize that as the e-mail you 18 you. 18 responded to Mr. Pepper with. 19 A Yes. 19 A Yes, sir. 20 Q Late in the afternoon of the 28th, right? 20 Q And to Mr. Pepper, you say, "I have no idea. 21 A Yes, sir. 21 Seem to me he should not have said anything." 22 Q Now, this, he is transmitting to you a press 22 A Correct. 23 release. And this is a press release from Chairman 23 Q So at the time you read that statement, and 24 Lenny Curry on redistricting. Right? 24 thought, he shouldn't be saying this; isn't that right? 25 A Yes. 25 A No. It wasn't the content of the statement. 217 219 1 Q And Mr. Curry is the Chairman of the 1 The reason I thought he should not say anything was 2 Republican Party of Florida, right? 2 because I didn't think it made sense for the Republican 3 A Yes, sir. 3 Party of Florida to opine on the redistricting process, 4 Q And he says that the Florida legislature has 4 period. 5 been committed to making this the most open, 5 Q Well, and it certainly didn't make sense for 6 transparent and interactive redistricting process in 6 them to opine about stuff that really wasn't true, 7 Florida's history. Do you see that? 7 right? 8 A Yes, sir. 8 MR. ZAKIA: Object to the form. 9 Q Now, did he know about your involvement in 9 MR. MEROS: Object to form. 10 the process? 10 THE WITNESS: I don't agree with that 11 A I don't know. 11 statement. 12 Q Had you talked to him about your involvement 12 BY MR. KING: 13 in the process? 13 Q Okay. And of course, Mr. Pepper responded to 14 A No, sir. 14 what you said and said, "Completely agree. They need 15 Q You hadn't told him that you were reviewing 15 to understand when the time to just be quiet is." 16 these congressional plans before they were issued to 16 Right? 17 the public and giving opinions about them to Senator, 17 A Correct. 18 to Dean Cannon, the Speaker of the House, and his chief 18 Q So you were thinking the Republican Party 19 of staff, Mr. Pepper? 19 ought to stay out of the fray at this point, right? 20 A That was a long, multifaceted question. Can 20 A I think from a press standpoint that was a 21 you parcel those pieces out again for me? 21 true statement. 22 Q Did you tell Mr. Curry that you had been 22 Q Now, those congressional plans that 23 involved in looking at these congressional maps before 23 Mr. Pepper had sent to you, as of the 28th they are 24 they were released to the public, and giving opinions 24 still not going to be released until the 6th of 25 to Dean Cannon about them? 25 December, right? We established that earlier. 25 (Pages 216 to 219) WWW.USLEGALSUPPORT.COM 954-463-2933 220 222 1 A If that's, if those documents are correct, 1 House redistricting committee -- 2 yes. 2 MR. BROWN: Objection. Asked and answered. 3 Q Now, isn't it correct that you were looking 3 BY MR. KING: 4 at those plans to decide which one of those plans ought 4 Q -- to Speaker Cannon? 5 to be advanced forward, right? 5 MR. BROWN: Objection. Asked and answered. 6 MR. MEROS: Object to form. 6 You can answer. 7 THE WITNESS: I don't recall specifically. 7 THE WITNESS: No, I don't believe so. 8 BY MR. KING: 8 BY MR. KING: 9 Q Because in truth and in fact, only one of 9 Q Did you form opinions about certain 10 those seven plans was advanced forward; isn't that 10 congressional districts then, as opposed to the entire 11 right? 11 map? 12 MR. MEROS: Object to form. 12 MR. BROWN: Which map? 13 THE WITNESS: I don't recall specifically, 13 BY MR. KING: 14 no. 14 Q The congressional maps. 15 BY MR. KING: 15 A Opinions about individual districts, yes. 16 Q And do you deny that you recommended the plan 16 Q And did you provide the information about 17 that was advanced forward to be advanced forward by the 17 those individual districts to the client you 18 House redistricting committee? 18 represented in the House and the Senate? 19 MR. ZAKIA: Object to form. 19 A I don't understand that question. 20 THE WITNESS: I don't recall making a 20 Q Did you provide the information about those 21 specific recommendation of a map, and I certainly 21 specific districts to clients you represented in the 22 don't recall -- 22 House and Senate? 23 BY MR. KING: 23 MR. MEROS: You are talking about the 24 Q The map that was advanced -- 24 congressional map? 25 MR. BROWN: Would you wait for the witness to 25 BY MR. KING: 221 223 1 finish. 1 Q I'm talking about the congressional map. 2 MR. KING: I'm sorry, did he finish? 2 A It confuses, because I don't have, it wasn't 3 THE WITNESS: I think I did. 3 related to -- the answer is no. 4 BY MR. KING: 4 Q Okay. When we were talking about Webster's 5 Q The map that was advanced out of those seven 5 district -- maybe I asked this question. If I asked 6 maps was the one that performed the best for the 6 it, repeating, I apologize, but I don't remember what 7 Republican Party, isn't that right? 7 your answer was. 8 MR. MEROS: Object to form. 8 Did you ascertain what concern -- do you 9 BY MR. KING: 9 remember now what concerns you about Webster's 10 Q From a political standpoint? 10 district? 11 A I don't know that to be the case, no. 11 A I don't recall. 12 Q You are sure your performance analysis didn't 12 Q Was there some problem with the minority 13 reveal that to you? 13 situation in Webster's district? 14 A I don't know. 14 A I don't recall. 15 Q You wouldn't deny that you had figured that 15 Q You remember which district Webster had, 16 out, would you? 16 didn't you? 17 MR. ZAKIA: Object to form. 17 A This was two years ago. 18 THE WITNESS: I don't -- what I will say is I 18 Q Right. 19 never did a complete analysis of a map on the 19 A Going forward there were multiple iterations 20 individual districts to have some, hey, this is 20 of the districts. It came out publicly. 21 the best map. I never did an analysis that 21 Q Right. 22 detailed on the congressional map. 22 A I can't tell, remember one version from the 23 BY MR. KING: 23 next two years ago. 24 Q Didn't you recommend the map that ultimately 24 Q So you don't remember that Webster was 25 was approved and moved forward in the process by the 25 District 10? 26 (Pages 220 to 223) WWW.USLEGALSUPPORT.COM 954-463-2933 224 226 1 A I don't, I don't know what district number, 1 A This is about the state Senate, yes, sir. 2 no. And that also changed through the process, I 2 Q And it simply points out that the incumbents 3 think. I don't, I don't remember. 3 didn't have much problem with the new map because it 4 Q Now, you were looking at the Senate maps, as 4 seemed to favor incumbents, right? 5 well, after they came out, right? 5 A It appears to be so, yes. 6 A I believe so. 6 Q It points out that all the lawmakers still 7 Q And you were passing information back and 7 have a district where their party won the last 8 forth with your consultant friends about the Senate 8 gubernatorial and presidential election and virtually 9 map, as well, right? 9 all would still have the advantage approaching or 10 A Yes, sir. 10 topping double digits, right? 11 MR. BROWN: You are talking about the Senate 11 A Right. 12 district map or the Senate congressional map? 12 MR. ZAKIA: You are asking him to confirm 13 BY MR. KING: 13 that's what it says? 14 Q A good, good point. Senate congressional 14 MR. KING: Yes, that's right. That's what it 15 map. 15 says. 16 A Okay. No, I was answering for the Senate 16 BY MR. KING: 17 map, I'm sorry. So let's go back, because I was 17 Q And that was of interest to you, right? 18 answering the question about the Senate map -- 18 A I don't know, but it was of interest to me -- 19 Q It is a little confusing. I apologize for 19 Q Had you helped bring that -- 20 that. Let me make it clear. You all were passing 20 MR. BROWN: Let him finish his answer. 21 information about the Senate congressional map once it 21 BY MR. KING: 22 was issued? 22 Q Sure, sure. 23 A I, you know, I have no reason to believe that 23 A Ask the question again. 24 we weren't. 24 Q My question -- let me rephrase it another 25 (Whereupon, the next document was marked as 25 way. In your analysis of both congressional districts, 225 227 1 Deposition Exhibit No. 45.) 1 Senate districts, the House districts, did you attempt 2 BY MR. KING: 2 to ascertain where the incumbents lived? 3 Q I show you exhibit -- I'm sorry, what exhibit 3 A In some cases; but not the entire map, no. 4 was that? 4 Q But in specific districts you wanted to make 5 MR. ZEHNDER: It is 45. 5 sure you knew where the incumbents were? 6 BY MR. KING: 6 A I needed to know where my clients lived so I 7 Q I show you Exhibit 45, and ask you if you 7 knew when the map was drawn which direct they were in. 8 recognize that as an e-mail from Mr. Heffley -- 8 Q Right. Right. And so you could also advice 9 A Yes. 9 on the maps that you don't get some other incumbent in 10 Q -- on November 30, 2011, to Sarah Bascom and 10 with the same -- with your client, right? 11 her communications firm, to yourself, and to 11 MR. ZAKIA: Object to form. 12 Mr. Bainter. 12 THE WITNESS: I mean, I need to know the 13 A Yes, sir. 13 answer to that. I don't know that I had much 14 Q And he is talking about the Senate plan, 14 effect on it. 15 right? The Senate map proposals? 15 BY MR. KING: 16 A I don't know which congressional or -- I 16 Q And you wouldn't want that situation to 17 don't know. 17 occur, would you? 18 Q Well -- 18 A No, I would not. 19 A I would have to read it to remember. 19 Q You would not want another sitting member of 20 Q Well, the article attached to it is about a 20 the legislature somehow hooked into the same district 21 -- 21 as one of your clients as an incumbent, right? 22 A This is about the state Senate map. 22 A That would be less than desirable. 23 Q The Senate map, isn't it? 23 Q And that gave you, because as you looked at 24 A This is about the state Senate. 24 these maps, you had the opportunity to talk to Cannon 25 Q Right, the state Senate map. 25 and his office and the people in the Senate staff like 27 (Pages 224 to 227) WWW.USLEGALSUPPORT.COM 954-463-2933 228 230 1 Mr. Clark to try to keep that from occurring, right? 1 Right? 2 MR. ZAKIA: Object to form. 2 A I don't, I don't know. 3 THE WITNESS: Ask that question again. I'm 3 Q You see him saying that? 4 sorry. 4 A Yeah. 5 BY MR. KING: 5 Q So it sounds like he thinks the plan sucks 6 Q Sure. As this process was ongoing, you 6 because he doesn't get as many districts as he hoped he 7 ascertained the location of these incumbents and tried 7 would get; right? 8 to make sure that none of your incumbents had 8 A I don't, I can't, I can't interpret what he 9 opposition from an incumbent in the same district, 9 is saying here. 10 right? 10 Q Right, but you were pointing out to me how 11 MR. ZAKIA: Object to form. 11 they supported your position a minute ago, right? 12 THE WITNESS: Actually this e-mail just 12 A I think it still does. 13 disproves exactly what you are saying. In fact, 13 Q Well, I mean, the point is, he is saying that 14 this e-mail was Sarah Bascom forwarding this 14 the districts looked better and more compact and more 15 article saying she is going on a news panel to 15 sensible than the old ones did, doesn't he? 16 discuss redistricting and sends it to me, Pat 16 A Well, it doesn't make sense. 17 Bainter, Rich Heffley. 17 Q You mean Mr. Heffley doesn't make sense? 18 If, in fact, we had all that influence over 18 A No, I'm saying that second sentence doesn't 19 the Senate map, and Rich Heffley was appointed, 19 make sense. It looks like there is a typo in there 20 why would his e-mail say the plan sucks? You see 20 somehow. 21 my point is -- 21 Q Okay. We will ask Mr. Heffley about that. 22 BY MR. KING: 22 A Yeah. 23 Q Well, he is not saying the plan sucks because 23 (Whereupon, the next document was marked as 24 it exposes incumbents, does he? 24 Deposition Exhibit No. 46.) 25 A What I'm saying is, he didn't think, it is 25 MR. MEROS: Did you say what number that is? 229 231 1 what the Senate put out for a Senate plan and both 1 MR. ZAKIA: I think it is 46. 2 Rich -- 2 MR. KING: The last one was 45, so this is 3 Q I will talk to you about that e-mail in a 3 46. 4 second, but we were talking about incumbents. And of 4 BY MR. KING: 5 course, you used your position and your influence to 5 Q All right, sir. Next I show you Exhibit 46, 6 try to avoid any of your clients having to face 6 which is an e-mail on December 1, 2011, where 7 incumbents in their districts; isn't that right? 7 Mr. Pepper is sending you an e-mail and sharing yet 8 MR. ZAKIA: Object to form. 8 again congressional 6.kmz from his Dropbox, right? 9 THE WITNESS: I don't believe I was able to 9 A Yes, sir. 10 use my influence at all in the Senate map in that 10 Q Why is Mr. Pepper continuing to send you 11 regard. In fact, I think the Senate map was drawn 11 these congressional districts? 12 and there were no incumbents, maybe there were, I 12 A I don't recall specifically. 13 don't know. I don't know that any were put in the 13 Q You said before you weren't particularly 14 same district. 14 interested in the congressional districts because you 15 BY MR. KING: 15 didn't have clients in Congress. 16 Q So basically all the incumbents were 16 A I, I don't. 17 protected, right? 17 Q But over and over Mr. Pepper keeps sending 18 A I don't, I don't know. Republican or 18 you the congressional districts, the various iterations 19 Democrat, I don't know. 19 of them from his Dropbox, right? 20 Q And so Mr. Heffley responds to this situation 20 A Yes, sir. 21 by saying the plan sucks. Right? 21 Q Well, I'm sure you must have asked him why he 22 A Yeah. 22 is doing that, didn't you? 23 Q And he said if you look at any of the area of 23 A I'm sure I did. I'm sure there were 24 the state and compare the old versus the new districts, 24 conversations, but I don't recall them. 25 they look more compact and sensible than the old ones. 25 Q You just don't have any recollection at all 28 (Pages 228 to 231) WWW.USLEGALSUPPORT.COM 954-463-2933 232 234 1 as you sit here why on December 1 he is sending you 1 Q And do you know why he sent that? 2 again congressional maps that haven't been released to 2 A I don't recall specifically. I can make an 3 the public, right? 3 assumption based on the date and the name of the file. 4 A To the best of my knowledge, yes. 4 Q And it says, "Checking things out now." What 5 Q Yes, you don't know why he is doing that? 5 does that mean? 6 A No, I don't recall. 6 A I don't recall. 7 Q You don't recall why he is doing it? 7 Q Okay. And your assumption that you are going 8 A Yes, sir. 8 to make is that this is now a public document? 9 (Whereupon, the next document was marked as 9 A I would think so at this, I mean, I don't 10 Deposition Exhibit No. 47.) 10 know, but I can't be certain. 11 BY MR. KING: 11 Q So out of all these congressional maps you 12 Q I show you, sir, Exhibit 47, which is another 12 have gotten, this is the first one that you got at the 13 e-mail on December 1, 2011, from Mr. Pepper sending you 13 time that it has been released to the public. 14 a link to Congressional 9.kmz in the Dropbox. Do you 14 A I can't be certain. 15 see that? 15 Q Well -- 16 A Yes, sir. 16 A I mean there may have been -- 17 Q Do you know what congressional map nine was? 17 Q You don't have any reason to believe that any 18 A I don't recall. 18 of these others that we've identified here had been 19 Q Mr. Pepper continues to send you 19 released to the public when you got them; do you, sir? 20 congressional maps, right? 20 A I may have gotten other files that were 21 A Apparently, yes, sir. 21 already released to the public. 22 MR. MEROS: Just one second. Have you given 22 Q Other files? What do you mean? 23 us this one? 23 A I'm sorry, ask the question again. 24 MR. ZEHNDER: Yes. 24 Q The question is, simply, this is the first of 25 MR. BROWN: I think I may have handed you my 25 these congressional maps that you got from Mr. Pepper 233 235 1 copy back. 1 that at the time you got it, it had been released to 2 MR. ZEHNDER: That's why I have an extra. 2 the public; right? 3 MR. MEROS: Okay. 3 A Apparently, yes. 4 MR. KING: Everybody in order over there? 4 Q And again, you don't know what it means when 5 MR. MEROS: Yes, thanks. 5 he says, "Checking things out now." Right? 6 BY MR. KING: 6 A No, sir. 7 Q And there in your files and records there is 7 Q What is the Sirius plan? 8 simply no response to these e-mails from you back to 8 A I don't recall what that is. 9 Mr. Pepper, right? 9 Q You got some e-mails from Mr. Heffley 10 A Apparently not. No, sir. 10 providing stats about something called the Sirius plan. 11 (Whereupon, the next document was marked as 11 I just wondered what you could tell me about that. 12 Deposition Exhibit No. 48.) 12 A I don't recall what the Sirius plan is. 13 BY MR. KING: 13 (Whereupon, the next document was marked as 14 Q All right, next, sir, I show you 48. Yeah, 14 Deposition Exhibit No. 49.) 15 Exhibit 48. And that is an e-mail on December 6. 15 BY MR. KING: 16 Now, at this point on December 6, do you 16 Q Okay. I show you Exhibit 49, which appears 17 recognize this as an e-mail you got that day, sir, 17 to be an e-mail from Mr. Heffley to you on December 22, 18 Exhibit 48? 18 2011, about, "Here are the stats for the Sirius 19 A Yes, sir. That's what it says. 19 plan" -- and that's spelled S-I-R-I-U-S, Sirius plan -- 20 Q From Mr. Pepper? 20 "we discussed earlier." 21 A Yes, sir. 21 And they are stats which seem to correspond 22 Q And he provides H9017, right? 22 to congressional districts, right, 27 of them? 23 A Yes, sir. 23 A Yes, sir. 24 Q Yet another congressional plan, right? 24 Q And information, a series of pages of 25 A Yes, sir. 25 information about certain districts. Do you know what 29 (Pages 232 to 235) WWW.USLEGALSUPPORT.COM 954-463-2933 236 238 1 that is, sir? 1 (Brief recess.) 2 A No, sir. I mean know what the statistics 2 THE VIDEOGRAPHER: The time is 4:07 p.m. We 3 are, but I don't know, I don't remember them. As you 3 are back on the record. 4 can see, there were a large number of maps. For me to 4 BY MR. KING: 5 go back two years and remember which one is which, is 5 Q Tell me, sir, how did you go about preparing 6 tough to do. 6 for this deposition? Did you meet with anybody 7 Q Well, was this, would each of these sets of 7 preparatory to the deposition? 8 statistics support a map? 8 A My lawyers. 9 A It appears so. 9 Q Which lawyers? 10 (Whereupon, the next document was marked as 10 A Dan, Dan Brown and. 11 Deposition Exhibit No. 50.) 11 MR. BROWN: David Healey. 12 MR. MEROS: David, at a good breaking point I 12 THE WITNESS: David Healey. 13 would like to a break. 13 BY MR. KING: 14 MR. KING: I am just about there. I will 14 Q Okay, just those two? 15 stop with this exhibit. 15 A Yes. 16 BY MR. KING: 16 Q I don't understand. You had to look at your 17 Q I show you, sir, Exhibit 50, and ask you if 17 counsel for what reason? 18 that represents an e-mail on December 28th, 2011, when 18 A Well, I had -- a meeting in person, yes, and 19 once again Mr. Pepper sends you a map to your Dropbox. 19 then there was a subsequent conference call. 20 A Was there a question? 20 Q Okay. Just with Mr. Brown and Mr. Healey? 21 Q Yes. Is this a document that reflects that 21 A The subsequent conference call included Ben 22 Mr. Pepper sent you a House map to your Dropbox, 9027? 22 Ginsberg. 23 A Yes. 23 Q Ben Ginsberg? 24 Q And what did Mr. Pepper want you to do with 24 A Yes, sir. 25 that House map? 25 Q Is he your counsel? 237 239 1 A I don't recall. 1 MR. BROWN: We are going to assert the 2 MR. MEROS: I'm sorry, are you saying a House 2 attorney-client privilege as to Mr. Ginsberg's 3 of Representatives map? 3 conversations with this witness. 4 MR. KING: Well, it is H9027. 4 MR. KING: I appreciate that, but I get to at 5 MR. MEROS: You can ask the questions, but -- 5 least check the predicate and see if there is a 6 MR. KING: Sure. 6 basis for the assertion to that privilege, and 7 MR. MEROS: -- I think you misunderstand. 7 that's what I intend to do. 8 MR. KING: Maybe I did. That's probably 8 MR. BROWN: Absolutely. 9 likely. 9 BY MR. KING: 10 BY MR. KING: 10 Q So Mr. Ginsberg is the attorney from Patton 11 Q What do you understand H9027 to be? What 11 and Boggs in Washington? 12 kind of a map is that? 12 A Yes, sir. 13 A This looks like a state House map, state 13 Q Okay. And he was on the telephone with you? 14 House. 14 A Yes, sir. 15 Q Right. 15 Q All right. Does he represent you as your 16 A A House district, state representatives 16 attorney at this time, sir? 17 district. 17 A I have a team, I'm sorry, there was one 18 Q That's right. State representative districts 18 other, Richard Coates, also, who is my lawyer, also. 19 emanating from the House of representatives. 19 Q Richard Coates? 20 Redistricting committee, right? 20 A Yes, sir. 21 A It appears to be that way. 21 Q Who is Richard Coates? Where does he 22 MR. KING: Okay. All right, we will take a 22 practice? 23 break. 23 A Here in Tallahassee. He is my lawyer. 24 THE VIDEOGRAPHER: The time is 3:49. We are 24 Q So you have an attorney-client relationship 25 off the record. 25 with Mr. Coates? 30 (Pages 236 to 239) WWW.USLEGALSUPPORT.COM 954-463-2933 240 242 1 A Yes, sir. 1 mean, I assume that he does some work with the 2 Q All right. And you have an attorney-client 2 Republican Party. 3 relationship with Mr. Brown, right? 3 Q The Republican Party is not a party to this 4 A Yes, sir. 4 case, though, right? 5 Q And you have an attorney-client relationship 5 A I just follow the advice of my counsel. 6 with Mr. Healey. 6 Q Okay. And well, let me just make sure I've 7 A Yes, sir. 7 explored the predicate on the attorney-client 8 Q I mean, you have like engagement agreements 8 privilege. 9 with those folks that you have signed? 9 Have you ever seen any written engagement 10 A Yes. 10 agreement with Mr. Ginsberg? 11 Q Okay. Now, Mr. Ginsberg, do you have an 11 A No. 12 engagement agreement with Mr. Ginsberg? 12 Q Have you ever paid Mr. Ginsberg any money for 13 A According to my attorney, I do. 13 attorneys fees? 14 Q Had you ever signed it? 14 A No. 15 A No. 15 Q To your knowledge, has anybody on your behalf 16 Q Have you ever seen it? 16 paid Mr. Ginsberg any money for attorneys fees? 17 A No, sir. 17 A Possibly. I don't know. 18 Q When did you develop this attorney-client 18 Q You wouldn't know about it if it happened? 19 relationship with Mr. Ginsberg? 19 A I don't know. 20 A I believe that was the case, but on advice of 20 Q What? 21 counsel -- 21 A I, I, I don't know. 22 Q No, no. My question is when did you form an 22 Q And when was this phone call with 23 attorney-client relationship with Mr. Ginsberg? 23 Mr. Ginsberg? 24 A I don't know the answer to that question. 24 A Yesterday. 25 Q Have you formed an attorney-client 25 Q Yesterday. Prior to yesterday, had you ever 241 243 1 relationship with Mr. Ginsberg? 1 considered Mr. Ginsberg to be your lawyer? 2 A I believe so. 2 A I believe he was doing some work. I have not 3 Q How did you do that? 3 had a conversation with him, yes. 4 A I don't know. I'm not a lawyer. 4 Q You believe he was doing what kind of work 5 Q Did you call him up on the phone and ask him 5 for you? 6 to represent you? 6 A I believe in general he was -- 7 MR. BROWN: Don't answer any further 7 Q Don't tell me any conversations with 8 questions about this. The assertion is that 8 Mr. Ginsberg; but if he was doing some kind of work for 9 Mr. Ginsberg is covered by the privilege, at least 9 you, describe the work. 10 a common interest privilege, and we believe 10 A I believe there is a team of lawyers that 11 attorney-client privilege. 11 were, were representing a group of us being deposed. I 12 He is not going to answer any questions about 12 always believed him to be one of those lawyers along 13 his conversations with Mr. Ginsberg. 13 with David Healey, Dan, et cetera. I believe him to be 14 MR. KING: Okay. Now, that's a different 14 a part of that group of lawyers. 15 privilege than the attorney-client privilege. You 15 Q Okay. And what caused you to believe he was 16 are saying the common interest privilege. 16 a part of that group of lawyers, other than the fact 17 MR. BROWN: Both. 17 that he appeared on the telephone with you yesterday? 18 BY MR. KING: 18 A In conversations with my lawyers. 19 Q So you are saying that, is it your 19 MR. BROWN: He doesn't want you to go into 20 understanding Mr. Ginsberg represents the Republican 20 the substance of the conversations. 21 Party? 21 BY MR. KING: 22 A I don't know that he does or doesn't. 22 Q Right. So is it fair to say that you haven't 23 Q All right. What common interest is this 23 really engaged Mr. Ginsberg personally, yourself, as 24 with, the common interest -- 24 your attorney? 25 A It might be with the Republican Party. I 25 A It is my belief that he was one of the 31 (Pages 240 to 243) WWW.USLEGALSUPPORT.COM 954-463-2933 244 246 1 lawyers representing me. 1 THE WITNESS: Yes. 2 Q No, I understand that. But you, yourself, 2 MR. BROWN: That's all I've got. 3 personally, have not engaged Mr. Ginsberg as a lawyer 3 BY MR. KING: 4 in this case or any other case; have you, sir? 4 Q So how long were you on the phone yesterday 5 A I don't know that I understand the 5 with Mr. Ginsberg and the other fellows? 6 difference. 6 A Half hour, 45 minutes. 7 Q Well, you, you are an experienced fellow. 7 Q Okay. And you said you had an earlier 8 A Right. 8 meeting with Mr. Brown or Mr. Healey at some point? 9 Q You've engaged lawyers a bunch of times 9 A Yes, sir. 10 haven't you over the years? 10 Q And when was that? 11 A Not really, no. 11 A It was last Thursday, I believe. 12 Q Well, like Mr. Coates. 12 Q How long did that last? 13 A Yes. 13 A A couple hours. 14 Q You know how you engaged him, right? 14 Q And have you discussed your testimony in this 15 A Set up my companies and answers campaign 15 case with Mr. Bainter? 16 finance issues. 16 A No. 17 Q You went to him and asked him to represent 17 Q Have you discussed his testimony with you? 18 you, right? 18 A No. 19 A Yes, but it is -- 19 Q Have you seen his deposition transcript? 20 Q But you haven't done that with Mr. Ginsberg, 20 A I have not read his deposition transcript. 21 have you? 21 Q Have you had an opportunity to read it? 22 A No. 22 A No. 23 Q Okay. So for the record, I've got to ask 23 Q It wasn't provided to you? 24 you. What did you discuss with Mr. Ginsberg yesterday? 24 A No. 25 MR. BROWN: Do not answer that question. 25 Q Okay. Have you talked to Mr. Johnston about 245 247 1 MR. KING: So no matter how I phrase the 1 his deposition? 2 question, you are going to instruct him not to 2 A I did not. 3 answer it, as long as I'm asking about 3 Q Have you talked to Mr. Heffley about the 4 conversations that occurred with Mr. Ginsberg, 4 depositions that are occurring this week? 5 right? 5 A Have I talked to Mr. Heffley about the 6 MR. BROWN: That's correct. 6 depositions? 7 MR. KING: I mean, I understand I can't 7 Q Yes, right. 8 normally ask him questions about conversations 8 A Absolutely, I mean -- 9 with you and your clients -- I mean you and the 9 Q Okay. 10 other lawyer there. But if Mr. Ginsberg isn't his 10 A I would say that it is fair that I talked 11 lawyer, I have got a right to ask questions about 11 to -- we all talked about the fact we were getting 12 that. 12 deposed. I mean, and we talk on a regular basis on 13 MR. BROWN: I understand that. I need to ask 13 other business that we have together. It would be hard 14 one predicate question myself when you finish with 14 for it not to come up that it was taking place. 15 your questions. 15 Q Okay. So you, have you discussed any of the 16 MR. KING: Sure. 16 issues that you were concerned about with Mr. Heffley? 17 MR. BROWN: Are you done? 17 A No. 18 MR. KING: Sure, go ahead. 18 Q You didn't discuss any of what you 19 MR. BROWN: The conversation you had with 19 anticipated the substance of this testimony to be? 20 Mr. Ginsberg yesterday, was I present? 20 A No. 21 THE WITNESS: Were you present? 21 Q You didn't discuss with Mr. Heffley how you 22 MR. BROWN: On the phone. 22 were preparing for the deposition and how he ought to 23 THE WITNESS: Yes. 23 prepare for the deposition? 24 MR. BROWN: Were you talking to Mr. Ginsberg 24 A Not other than the fact that we were 25 with my direction and with my consent? 25 preparing for the deposition. 32 (Pages 244 to 247) WWW.USLEGALSUPPORT.COM 954-463-2933 248 250 1 Q Okay. And I neglected to ask you this 1 Q You don't deny that you gave him advice about 2 question. But in that conversation where Mr. Ginsberg 2 it, do you? 3 was on the line with your two other lawyers, were 3 MR. ZAKIA: Object to form. 4 Mr. Bainter or Mr. Heffley or any of those other 4 THE WITNESS: I don't recall whether or not I 5 fellows on the telephone at that time? 5 gave advice or not on this map. 6 A No. 6 (Whereupon, the next document was marked as 7 Q Do you intend to talk to Mr. Heffley about 7 Deposition Exhibit No. 52.) 8 this deposition today before your deposition -- before 8 BY MR. KING: 9 his deposition tomorrow? 9 Q Let me show you e-mail -- actually I have, 10 A No, sir. 10 this e-mail is two days earlier. This is on 11 (Whereupon, the next document was marked as 11 January 21st. Let me show you Exhibit 52, and ask you 12 Deposition Exhibit No. 51.) 12 if you recognize that as a January 21, 2002 e-mail from 13 BY MR. KING: 13 yourself to Mr. Terraferma and Mr. Heffley. 14 Q Okay. Let me show you, sir, Exhibit 51, and 14 A Okay. 15 ask you if you recognize this e-mail from Mr. Pepper on 15 Q And it also refers to an e-mail from 16 January 23, 2012, at 2:26 p.m. 16 Mr. Terraferma to you and Mr. Heffley of the same date? 17 A Okay. 17 A Yes, sir. 18 Q Now, is this the congressional map? 18 Q Okay. Do you remember that e-mail? 19 A Yes, sir. 19 A Vaguely. There are lots of e-mails here, but 20 Q And it appears to be 9047, right? 20 -- 21 A Yes, sir. 21 Q And you see that Mr. Terraferma sent an 22 Q Now, it refers to 24 cities, Hollywood, two 22 e-mail and was referring to a map? 23 counties. What does that mean, if you know? 23 A Yes, sir. 24 A I don't, I don't recall specifically. I 24 Q And he says, "Everything is balanced except 25 think there was, I think this refers to how many 25 southeast Florida," right? 249 251 1 counties are split versus how many cities are split, or 1 A Yes, sir. 2 something like that. 2 Q And then it says, "Highlights, used Marc's 3 One of the measurements for complying with 3 Corrine Brown." 4 Amendment 5 and 6 I think were, they used, were to 4 A Yes, sir. 5 split the fewest number of counties and the fewest 5 Q What does that mean? 6 number of cities. And one way of complying with 5 and 6 A I think this is part of a number of maps that 7 6 were to attempt to draw maps that split the fewest 7 the consultant class sent around to each other on a 8 number of cities and counties. 8 regular basis. 9 But that's the only thing I can think of 9 I specifically, in an intellectual exercise, 10 based on those numbers, but that's speculation. 10 when there was a debate over whether or not Corrine 11 Q Do you know why Mr. Pepper was continuing to 11 Brown's district could actually be drawn majority 12 send these maps to you in his Dropbox. 12 minority -- meaning 50 plus percent, black voting age 13 A That's the same answer as before. 13 population -- there early on, when the maps were drawn, 14 Q And of course, now we are close to the, to 14 they were under that number. 15 the decision by the, by the legislature about which 15 And there was some assertion that it wasn't 16 maps to enact; right? 16 actually physically able to do it. As an intellectual 17 A Yes, sir. 17 exercise, I then proceeded to attempt to see if it 18 Q You are like a few days before that time, 18 actually could be drawn. 19 right? 19 Q And you attempted to draw a map that would 20 A I would assume so, based on that date. 20 move more Democrats and black voters into Corrine 21 Q And did you advise Mr. Pepper and Dean Cannon 21 Brown's district? 22 about C9047? 22 A No, sir. I specifically went to see if it 23 A I don't recall. 23 could be drawn majority minority, because there was 24 Q How it would perform? 24 some debate that if you could draw it majority 25 A I don't recall. 25 minority, you should, under the federal voter rights 33 (Pages 248 to 251) WWW.USLEGALSUPPORT.COM 954-463-2933 252 254 1 act. 1 what Frank was referring to there. I guess it is 2 Q Well, the federal voters rights act didn't 2 Congress Mica and Congresswoman Sandy Adams. 3 require her district to be a majority minority 3 Q Right. 4 district, did it, sir? Did anybody ever tell you that? 4 A So. 5 MR. BROWN: Object to the form. Foundation. 5 Q And they ended up running against each other, 6 MR. MEROS: Object to the form and 6 didn't they? 7 foundation. 7 A Yes, sir, they did. 8 THE WITNESS: I have heard that, yes. 8 Q Is that something that you thought was a good 9 BY MR. KING: 9 idea? 10 Q Who told you that? 10 A I really was not involved in the conversation 11 A I don't recall. 11 about those specific districts. 12 Q You also -- strike that. You did draw maps 12 Q What does it mean, this last sentence, 13 during this time period where you moved more Democrats 13 "Billrakis will cry, but Hillsborough looks real nice. 14 into Corrine Brown's district and moved Republicans 14 Ross has 240K in Polk. No other county in his CD has 15 out, isn't that correct? 15 over 100. Webster, though, has 360 Polk and 209 Orange 16 MR. BROWN: Object to the form of the 16 plus Lake and Osceola. Thoughts? Feedback?" 17 question. What time period? 17 What did that mean to you? 18 BY MR. KING: 18 A It is an analysis of the district of the map 19 Q During the time period of January 21st, 2012. 19 that he drew here, that Frank drew. 20 A The exercise of the map I drew, was merely 20 Q And you are asking him for a doj or kmz file 21 moving African-American voters into a district to get 21 of this, right? 22 it over 50 percent. I was not actually looking at 22 A Yes, sir. 23 party registration. 23 Q Why did you want that? 24 Q When you moved people in, did you just move 24 A I couldn't -- the pdf he sent me, it wasn't 25 people in without moving people out? 25 very legible. It may have been a different format that 253 255 1 A You can not move people out when you move 1 I couldn't open. I don't recall. 2 people in. The number has to be 696,344 within one. 2 MR. KING: We are skipping 53 for the minute. 3 Q And was there movement of people in at the 3 I think you would rather me skip it, than talk 4 same time as there was moving the people out in that 4 about something we didn't need to talk about. 5 district? 5 MR. MEROS: Correct. 6 A Yes, sir. But -- 6 (Whereupon, the next document was marked as 7 Q And when the -- strike that. Did you advise 7 Deposition Exhibit No. 54.) 8 Dean Cannon and Kirk Pepper about the work you had done 8 BY MR. KING: 9 on Corrine Brown's district? 9 Q I show you Exhibit 54, and ask you if you 10 A Can you be more specific? 10 recognize that as an e-mail on January 23, 2012, from 11 Q Did you advise Dean Cannon and/or Kirk Pepper 11 Mr. Pepper. 12 about the work you had done drawing Corrine Brown's 12 A Yes, sir. 13 district? 13 Q Now, he is sending you C9047, and it says 27 14 A I don't recall that specifically. 14 cities, CD 5over50. What does that mean? 15 Q Did this map that Mr. Terraferma is referring 15 A I don't recall. 16 to, did that get to Mr. Cannon or Mr. Pepper or 16 Q But he continues over and over again to send 17 Mr. Kelly or Mr. Clark? 17 you these congressional maps, right? 18 A I did not provide that map to them, no. 18 A Yes, sir. 19 Q When it says, quote, "Could entice Mica to 19 Q He is not sending you House maps or Senate 20 run against Adams," what did that mean to you? 20 maps nearly as much as he is sending you congressional 21 A I don't know specifically. That's an e-mail 21 maps, right? 22 from Frank Terraferma. 22 A Correct. 23 Q But I mean this was the stuff y'all talked 23 Q And you don't know why that is? 24 about all the time, wasn't it? 24 A No, sir. 25 A Yeah. I don't recall specifically, you know, 25 MR. KING: Fifty-five is out. 34 (Pages 252 to 255) WWW.USLEGALSUPPORT.COM 954-463-2933 256 258 1 (Whereupon, the next document was marked as 1 Q And would that also be true for Exhibit 60? 2 Deposition Exhibit No. 56.) 2 A Yes, sir. 3 BY MR. KING: 3 (Whereupon, the next document was marked as 4 Q Okay. Sir, I show you Exhibit 56, and ask 4 Deposition Exhibit No. 61.) 5 you, sir, if you recognize that e-mail of March 15, 5 BY MR. KING: 6 2012. 6 Q And Exhibit 61? 7 A Yes, sir. 7 A Yes, sir. 8 Q What is that? Because we don't have an 8 Q So none of those are real maps? 9 attachment to this. 9 A No, sir. 10 A I may not have downloaded the attachment. 10 Q That's all just a joke? 11 Q Why is that? 11 A Yes, sir. 12 A I think this was a series of e-mails that 12 Q Fun? 13 there was, this would have been after the legislative 13 A It is maps drawing humor. 14 session, before the special session to redraw the 14 Q Okay. 15 Senate maps. 15 MR. BROWN: Which one is 60 and which one is 16 Q Right. 16 61? 17 A I think there was some conversation about 17 MR. ZEHNDER: What he just handed you is 60. 18 whether the House and the Senate were both going to 18 MR. ZAKIA: 60 is Bates number 181. 19 draw maps, or whether they were going to let the Senate 19 (Whereupon, the next document was marked as 20 just draw the maps. 20 Deposition Exhibit No. 62.) 21 There were a series of satirical maps that 21 BY MR. KING: 22 were drawn; that if the House was going to draw maps, I 22 Q Okay. And one more exhibit, sir. Exhibit 23 think this might be one of those. This would be one of 23 62. I show you Exhibit 62, which purports to be an 24 those, for all practical purposes, a practical joke. 24 e-mail from Kirk Pepper on March 17, 2012, to you. And 25 Q So this was not a real map? 25 you see this is an e-mail string that starts with 257 259 1 A No, sir. This would have been the House 1 Pepper to you. And he sends a map of some sort. Do 2 playing around with maps as if they were jokingly going 2 you see that? Down at the bottom? 3 to submit the Senate map. 3 A Yes, sir. 4 Q So Mr. Pepper was sharing some satirical map 4 Q Can you tell which map that is? 5 with you. 5 A That would be the Senate redraw. 6 A Yes, sir. 6 Q The Senate redraw? 7 Q And is that, is that what he did with Exhibit 7 A Redraw, yes, sir. It is based on the dates. 8 57? 8 Q And you say, "Got it. Thanks. It is better 9 A Yes, sir. 9 than I thought they would do, but still probably not 10 (Whereupon, the next documents were marked as 10 enough to clear courts." Is that right? 11 Deposition Exhibit No. 57 and No. 58.) 11 A Yes, it appears that's what I said, yes, sir. 12 BY MR. KING: 12 Q Why did you say that? 13 Q Is that what he did with Exhibit 58? 13 A I don't recall specifically. 14 Eighteen and barely legal? 14 Q Well, you thought something was wrong with 15 A Yes, sir. You can see why I remember the 15 the map, I assume; is that right? 16 names of these specific documents. 16 A I would not interpret that I thought 17 (Whereupon, the next document was marked as 17 something was wrong with the maps. I merely said that 18 Deposition Exhibit No. 59.) 18 I didn't know where the, what the courts would think. 19 BY MR. KING: 19 Q Well, in the kind of deal between the Senate 20 Q Right. And is that also true with Exhibit 20 and the House, because of your relationships, you kind 21 59, 30_15 to Yuma? 21 of lean to the House side; is that right? 22 A Yes, sir. Appears to be so. 22 A Yes, sir. 23 (Whereupon, the next document was marked as 23 Q And so you and your friends in the House were 24 Deposition Exhibit No.60.) 24 always a tad skeptical of the Senate? 25 BY MR. KING: 25 A I think that's -- 35 (Pages 256 to 259) WWW.USLEGALSUPPORT.COM 954-463-2933 260 262 1 MR. ZAKIA: Object to form. 1 today. Beginning with Kirk Pepper, how long have you 2 THE WITNESS: I think that's a, I think that 2 known Mr. Pepper? 3 the House staff would be skeptical. I would be 3 A I've known him since probably 2008, nine-ish. 4 less so because I have clients in both. 4 Q How did you first get to know Mr. Pepper? 5 BY MR. KING: 5 A He worked at the Republican Party of Florida. 6 Q Right. But still, you thought that what they 6 Q So was he a client of yours? 7 had done after all your study and efforts in 7 A No. 8 redistricting, you thought that what they had done was 8 Q No? How did you get to know him at the 9 still probably not enough to clear the courts; right? 9 Republican Party of Florida? 10 A You know, that's what I said there, but I 10 A I just had met him. I didn't work with him 11 don't know specifically why I thought that at the time. 11 real closely when he was there. I probably got to know 12 MR. KING: Okay. That completes my 12 him better when he was working on the staff of Bill 13 questions. 13 McCollum's gubernatorial campaign. 14 CROSS EXAMINATION 14 Q How did you get to know him in that capacity? 15 BY MR. DEVANEY: 15 A I was just involved in politics. 16 Q Good afternoon, Mr. Reichelderfer. John 16 Q You were working on a campaign together? 17 Devaney for the Romo plaintiffs. 17 A I was not, but I was in and around politics 18 In preparing for your deposition, did you 18 and got to know him a little bit through that. 19 meet or have any discussions with anybody from the 19 Q Uh-huh. Is your relationship with him 20 House or Senate? 20 business or is it also social? 21 A No. 21 A It is mostly business. 22 Q Did you have any conversations with counsel 22 Q Socialize with him sometimes? 23 for the House or Senate? 23 A Occasionally. 24 A No, sir. 24 Q How often? 25 Q And before in the discussion with 25 A Every, sometimes it could be every couple 261 263 1 Mr. Ginsberg, there was a discussion of a common 1 months, every six months, you know. 2 interest privilege. Do you have any sense of who the 2 Q Go out to dinner, go out to lunch or 3 common interest is with? What entity? 3 something like that? 4 A I think it would be our, the multiple 4 A Lunch every three or four months probably. 5 non-parties being deposed. 5 Q And similar question about Chris Clark. How 6 Q Are you alleging a common interest with any 6 long have you known Mr. Clark? 7 Republican Party entity? 7 A Probably since about, going back to probably 8 A I, I think that's, we all fall in that same 8 '99, 2000. 9 category, I would think, yes. 9 Q How did you get to know Mr. Clark? 10 MR. DEVANEY: Counsel, may I ask that 10 A He was a travel aide for Governor Jeb Bush. 11 question of you? Are you asserting a common 11 Q And what was your involvement with Jeb Bush 12 interest privilege with respect to any Republican 12 that caused you to get to know Mr. Clark? 13 entity or organization? 13 A We run in the same political circles and go 14 MR. BROWN: Yes. 14 to the same political events. 15 MR. DEVANEY: Which organization is that? 15 Q And have you worked together since 1999 with 16 MR. BROWN: The Republican Party of Florida. 16 Jeb Bush? 17 And the Republican -- well, the Republican 17 A I didn't work with Jeb Bush. That's when I 18 National Committee to the extent necessary. 18 first met him, that was the job he had. He has had a 19 BY MR. DEVANEY: 19 number of jobs since then. 20 Q Mr. Reichelderfer, I'm going to follow up on 20 Q Can you give me a sense of the extent of your 21 some questions that Mr. King asked. And I will be 21 interactions with him since 1999, both social and 22 jumping around a little bit, so bear with me in terms 22 business? 23 of organization. 23 A Sometimes in this business there are projects 24 But I want to go back and just ask you some 24 where you are working with someone, so you may have a 25 questions about some of the people we talked about 25 period of a legislative session or a campaign cycle 36 (Pages 260 to 263) WWW.USLEGALSUPPORT.COM 954-463-2933 264 266 1 where you communicate with somebody, you know, once a 1 we both got married and went our separate ways. He got 2 week or so. 2 elected to the Florida Legislature, but I was not his 3 And then there is other periods of time where 3 consultant when he first got elected. 4 we don't communicate much for several months. 4 His consultant passed. And then I became 5 Q And have you socialized with Mr. Kelly? 5 his, was hired to be his consultant after that. 6 A I'm sorry? 6 Q When did you become his consultant? 7 Q Have you socialized -- 7 A That would have been for the 2000 -- the 8 A I am sorry -- 8 first year I consulted with his campaign would have 9 Q With Mr. Clark, I'm sorry. 9 been -- his last election was in '10. So '8, 2006. 10 A Clark. You know, occasionally. Not, not 10 Q What are your responsibilities? By the way, 11 frequently. 11 are you still his consultant today? 12 Q Okay. And how long have you known Alex 12 A He is no longer a member of the legislature. 13 Kelly? 13 Q Okay. What are your, what were your 14 A Since about 2000. 14 responsibilities in your capacity as his consultant? 15 Q How did you get to know Mr. Kelly? 15 A I advised him on everything related to his 16 A He actually managed Anna Cowan's reelection 16 campaign. I helped put together campaign plans. I 17 campaign for the Senate in 2000. And I was a 17 helped develop campaign plans and produced television, 18 consultant on that race. 18 TV, mail. Also helped give advice on, you know, public 19 Q And describe for me the extent of your 19 relations and PR and press relations. 20 interactions with Mr. Kelly since you first met him in 20 Q So you had a close working relationship with 21 2000, up to the present. 21 him when he was Speaker? 22 A It would be similar to the answer I just gave 22 A Yes, sir. 23 on Mr. Clark. When we are working on, when we are 23 Q How often would you have contact with him? 24 working on a campaign together, I was a consultant and 24 A It was, it would be sporadic. Sometimes it 25 he was staff on that campaign. We interacted a lot. 25 would be, you know, once a week. Sometimes maybe twice 265 267 1 And we would go for long periods of time where we 1 a week. Sometimes it may go three or four weeks 2 didn't interact very much. 2 without, depending on the time of the year, also. 3 Q Dean Cannon, how long have you known 3 Q In response to one of Mr. King's questions 4 Mr. Cannon, Speaker Cannon? 4 earlier this morning, you said -- and I'm paraphrasing 5 A I've known him since probably 1991, '92. 5 here -- that you viewed it as appropriate to have 6 Q Tell me how you got to know him. 6 conversations with members of the legislature regarding 7 A We were both members of the Orange County 7 how to draw lines for redistricting maps. 8 Young Republicans. 8 You said Dean Cannon and other legislators. 9 Q And how much time did you spend with him back 9 Do you recall that? 10 in that time period when you were both members of the 10 A No, sir. I do not. Now -- 11 Young Republicans? 11 MR. MEROS: I am sorry, I didn't hear you. 12 A I mean that was a couple-year period, but you 12 THE WITNESS: I did not, I don't believe I 13 know, a fair amount then, a little bit socially. 13 said that. If I did it was, I misspoke. 14 Q What types of social interactions did you 14 BY MR. DEVANEY: 15 have with him? 15 Q Okay. Well, did you have conversations with 16 A Once again, Republican club events, like 16 Dean Cannon and other legislators concerning how to 17 that. 17 draw lines to comply with the fair district amendments? 18 Q Have you maintained your relationship with 18 A How to draw lines? 19 him from that period in the early '90s up to the 19 Q Yes. 20 present? 20 A No. 21 A Not, not, not continuously, no. 21 Q Or how to create a map to comply with fair 22 Q Describe for me the nature of your 22 district amendments? Did you have conversations with 23 relationship since your days in the Young Republicans 23 Speaker Cannon or other legislators about that? 24 and how much interaction have you had with -- 24 A I think I was asking the questions. 25 A We didn't have a lot of interaction after I, 25 Q Okay. But did you have conversations with 37 (Pages 264 to 267) WWW.USLEGALSUPPORT.COM 954-463-2933 268 270 1 people other than Speaker Cannon about map drawing and 1 THE WITNESS: I don't know whether I did or 2 the creation of the map? 2 didn't. 3 MR. BROWN: I will object to the form of the 3 BY MR. DEVANEY: 4 question. It assumes a lack of predicate, if I 4 Q You testified earlier in connection with 5 understand the question. It assumes he had 5 the -- strike that. 6 conversations with Cannon. 6 Do you recall the line of questioning from 7 BY MR. DEVANEY: 7 Mr. King about the series of maps that Mr. Pepper sent 8 Q You can answer. 8 to you from November 23rd to roughly December 6th of 9 A I'm confused. 9 2011? 10 MR. MEROS: Are we talking about other 10 A Yes, sir. 11 legislators or anyone? 11 Q And you testified, I think, that you 12 MR. DEVANEY: Other legislators. 12 evaluated performance, political performance under some 13 THE WITNESS: I'm confused because what you 13 of those maps. Did I understand you correctly? 14 said back is that I thought it was appropriate to 14 A I think at some point I probably looked at 15 tell them how, how to draw lines and 15 performance, yes. 16 specifically -- I didn't specifically say, hey, 16 Q Did you look at performance for each of the 17 draw lines here, draw lines there. 17 maps that Mr. Pepper sent you during that time period? 18 BY MR. DEVANEY: 18 A I don't believe so. 19 Q Yeah, my simple question is -- 19 Q Okay. How did you go about analyzing 20 A I'm confused. 20 performance? 21 Q You discussed, we established you discussed 21 A I mean, you look at past election results. 22 the creation of a congressional map, for example, with 22 Q Which elections did you look at? 23 Speaker Cannon; is that correct? 23 A I don't recall specifically; but my guess is 24 A You know, I said I couldn't recall whether I 24 I probably looked at the '08 presidential and probably 25 did or didn't. But the subject matter would be 25 looked at the gubernatorial race in '10. 269 271 1 something like retrogression. Those type of things had 1 Q And why did you focus on the '08 2 a global perspective. 2 presidential? 3 Q You don't dispute you discussed creation of a 3 MR. ZAKIA: Object to the form. 4 congressional map with Speaker Cannon, do you? 4 THE WITNESS: It was a recent -- generally 5 A No. 5 you are going to look at the most recent 6 Q And you testified earlier, I thought, that 6 presidential cycle and the most recent 7 you also had similar discussions with, quote, other 7 gubernatorial cycle. 8 legislators. 8 BY MR. DEVANEY: 9 And my question for you is, did you and who 9 Q When you did your analyses, did you keep the 10 were they? 10 results? 11 A I, I don't recall that I did. 11 A I, I don't, I don't believe so. I mean, it 12 Q Are you denying that you did or you don't 12 is, I don't know that I did any written analysis. I 13 recall? 13 mean, basically, I just looked at it and pulled it up 14 A I don't recall. 14 on the computer screen. 15 Q So is it possible you talked to other members 15 Q And did you convey your conclusions with 16 of the legislature about how to create a congressional 16 respect to political performance to anyone? 17 map, is that correct? 17 A I don't recall, specifically. Probably not. 18 A How to create -- I'm a little confused by the 18 Q Do you recall generally? 19 terminology on how to create. 19 A Generally, yes. I'm sure I discussed it with 20 Q Or the development of the congressional map? 20 Rich Heffley and Frank Terraferma. 21 A Look, I don't recall having any conversations 21 Q Now, my questions along these lines are 22 with other legislators. 22 referring to the maps that Mr. Pepper sent you between 23 Q But again, you are not denying that you did; 23 November 23 and December 6. 24 is that correct? 24 A I don't know that I did. 25 MR. MEROS: Object to form. Go ahead. 25 Q So help me understand. We see these e-mails, 38 (Pages 268 to 271) WWW.USLEGALSUPPORT.COM 954-463-2933 272 274 1 and I'm not going to go through the documents because 1 Q What do you recall telling Mr. Pepper about 2 it is late in the day, but I think you remember 2 political performance on those maps that he sent you 3 Mr. Pepper sent you a series of congressional maps. 3 from November 23rd to December 6? 4 What I would like to know is before he sent 4 A I don't recall telling him anything about 5 you each of those maps, did you have a conversation 5 political performance. You asked me if I recalled. I 6 with him about the map that he was about to send you? 6 don't recall. You said if it was possible. I said it 7 A I don't recall. I mean -- 7 was possible. 8 Q You probably did, didn't you? 8 Q Did you discuss political performance on 9 MR. ZAKIA: Object to form. 9 those maps with anyone other than Mr. Pepper? 10 MR. MEROS: Object to form. Go ahead. 10 A Of those maps, specifically, I don't recall. 11 THE WITNESS: I don't know one way or the 11 Q You testified earlier that you opined on 12 other. We may have, but -- 12 specific issues, specific districts in those maps that 13 BY MR. DEVANEY: 13 Mr. Pepper sent you. Do you recall testifying to that? 14 Q So you think he was just possibly sending you 14 A I think so, yes. 15 congressional maps out of the blue without any context? 15 Q Which districts did you opine on? 16 MR. ZAKIA: Object to form. 16 A When I said opine, I think I globally opined 17 THE WITNESS: He may have followed up with a 17 about whether districts retro -- whether the minority 18 phone call afterwards. It is two years ago. And 18 districts retrogressed, or whether or not they were, 19 as you can see, there is a large number of 19 could achieve the majority minority that I previously 20 e-mails. And these are only e-mails relating to 20 discussed about the federal voter rights act. 21 redistricting. Outside of redistricting, I have a 21 Q Did you also opine on seats that were 22 lot of other things I work on. So it is hard for 22 currently held by Republicans in Congress in your 23 me to recall. 23 discussions with Mr. Pepper relating to those maps? 24 BY MR. DEVANEY: 24 A I don't recall having those conversations. 25 Q So you said he may have followed up with a 25 Q Are you denying that you had them or you just 273 275 1 phone call. Isn't it true that each time he sent you 1 don't recall? 2 one of these maps, you guys would talk by phone about 2 A I don't recall. 3 the map he just sent you? 3 MR. BROWN: By the way, for a moment. It is 4 A We may or may not have. I don't know. 4 about five minutes to five. And this gentleman, 5 Q And you had conversations about everyone of 5 as we talked about this morning, needs to leave by 6 the maps that he sent you in that time period, didn't 6 five. Are you going to be finished by then? 7 you? 7 MR. DEVANEY: No, I will not be. 8 MR. MEROS: Object to form. Go ahead. 8 MR. BROWN: When do you anticipate you will 9 THE WITNESS: I don't know. 9 be finished? 10 BY MR. DEVANEY: 10 MR. DEVANEY: I probably have about 20 11 Q It is possible you did, isn't that right? 11 minutes. 12 A It is possible. 12 MR. MEROS: Why don't we stop now? It is 13 Q And in those conversations you conveyed to 13 four minutes to five. 14 him, didn't you, the political performance analysis 14 MR. DEVANEY: Sure. 15 that you conducted on these maps, correct? 15 MR. BROWN: Lets go off the record for a 16 MR. MEROS: Object to form. 16 second. 17 THE WITNESS: I don't know. 17 THE VIDEOGRAPHER: The time is 4:53 p.m. We 18 BY MR. DEVANEY: 18 are off the record. 19 Q It is possible you did, isn't it? 19 (Brief pause.) 20 A It is possible, I guess. 20 THE VIDEOGRAPHER: The time is 4:54 p.m. We 21 Q How would we find that out? 21 are back on the record. 22 A I don't know. 22 BY MR. DEVANEY: 23 Q Is there anyone other than you who can tell 23 Q In response to one of Mr. King's questions 24 us that? 24 earlier, you said you didn't recall specifically if you 25 A I don't know. 25 had recommended a particular map to Mr. Pepper or 39 (Pages 272 to 275) WWW.USLEGALSUPPORT.COM 954-463-2933 276 278 1 Speaker Cannon. Do you recall saying that? 1 map before it was passed? 2 A I guess so. 2 MR. MEROS: I'm sorry, which date was the 3 Q And your use of the word "specifically" 3 date? 4 caused me to suspect that perhaps generally you may 4 MR. DEVANEY: I believe it was January 23rd, 5 have some recollection of whether you recommended a 5 2012. 6 specific congressional map. 6 MR. MEROS: That's the first one? 7 Am I right, you have some general 7 MR. DEVANEY: The congressional map. 8 recollection of that? 8 MR. MEROS: Okay. Go ahead. 9 A I don't actually. 9 THE WITNESS: Which? 10 Q Is it possible you did, you just don't 10 BY MR. DEVANEY: 11 recall? Is that right? 11 Q The congressional map that was passed on 12 A Yeah, I don't recall. 12 January 23, 2012, did you perform a political 13 Q With respect to the maps that Mr. Pepper 13 performance analysis of that map? 14 provided to you during that time period in November 23 14 A I, I don't recall. 15 to December 6, do you know if others performed 15 Q There was a discussion earlier of the Webster 16 political performance analyses of those maps? 16 district, and it being I think messed up was the word. 17 A I'm sorry, ask that question again. 17 Just for the record, who is Webster? 18 Q With respect to the maps we've been 18 A Congressman Dan Webster. 19 discussing, the maps from November 23rd to December 6, 19 Q What is his party affiliation? 20 that were provided by Mr. Pepper -- 20 A Republican. 21 A Yes. 21 Q And why did you say it was messed up? 22 Q -- do you know if anyone other than yourself 22 A I don't recall. I can't answer that 23 performed political analysis, political performance 23 question. 24 analysis of the maps? 24 Q Do you recall whether your concern about that 25 A I don't know. Let met further state, I don't 25 district was addressed in the map that was ultimately 277 279 1 know that I did to everyone of those maps. 1 enacted, the congressional map? 2 I mean the question assumes that I did to all 2 A I don't, I don't recall. 3 those maps. I don't know that I did. 3 Q Do you have Exhibit 40 in front of you? 4 Q How many maps do you believe you performed 4 MR. KING: They are all in order. 5 performance analysis on? 5 THE WITNESS: Yes, sir. 6 A I have no idea. I don't recall. 6 BY MR. DEVANEY: 7 Q You can't give us an estimate? 7 Q So for the record, Exhibit 40 begins with an 8 A I, I looked at a lot of different maps. I 8 e-mail from Mr. Pepper to you, a Dropbox? 9 really honestly don't know. 9 A Yes, sir. 10 Q So I think there were about 12 or 13 maps 10 Q Conveyance of, quote, Florida Senate 11 that were provided during that time period. Are you 11 congressional map. Can you tell us what map this was 12 saying, can you tell us whether you performed analysis 12 that was conveyed to you? 13 on half of them? Or you don't even know? 13 A This appeared from the e-mail to be the, the 14 A I think there were probably on my computer 14 Senate's congressional map that was released at that 15 that I produced in the neighborhood of 40 maps of 15 point. 16 different kinds. I can't remember which and how many I 16 Q Had it been released at this point? 17 looked at performance data. 17 A I don't know. 18 In some cases, I was probably only looking at 18 Q In fact, it hadn't been released on 19 retrogression issues and minority, majority minority 19 November 27th, correct? 20 type districts, that a lot of times that's what I was 20 A I think it may be the one that was then being 21 looking at, not performance data. A lot of times, the 21 released on the 28th. 22 performance data was not the main issue I was looking 22 Q Right. This is another example of Mr. Pepper 23 for. 23 giving you a map that hadn't been publicly disclosed, 24 Q The map that was passed on January 23rd, 24 isn't that correct? 25 2012, did you perform a performance analysis of that 25 A Appears to be. 40 (Pages 276 to 279) WWW.USLEGALSUPPORT.COM 954-463-2933 280 282 1 Q And did you talk to them about why he was 1 BY MR. DEVANEY: 2 giving you this map that hadn't been publicly disclosed 2 Q Twenty-eight. 3 yet? 3 A Exhibit 28. Okay. Yes, sir. 4 A I don't recall specifically. I don't recall. 4 Q I don't think you discussed this with 5 Q You may have? 5 Mr. King. If you did, I apologize and I will move on. 6 A I may have. 6 But just for the record, this is an e-mail 7 Q But you don't recall? 7 from, at the top it is from Mr. Pepper to you. It is 8 A I may have. 8 dated November 6, 2011. 9 Q Did you have a conversation with him about 9 And it quotes from whom you identified as 10 this map after he sent it to you? 10 Alex Kelly earlier. 11 A I don't, I don't recall. 11 Now I will just read the last sentence of the 12 Q You state here in response to this -- 12 quote from Mr. Kelly. It says, "To take CD 24 out of 13 MR. DEVANEY: Let's go off the record. 13 Pinellas completely, it requires a bigger discussion 14 THE VIDEOGRAPHER: The time is 5:01 p.m. We 14 about things the Speaker has said are important to 15 are off the record. 15 him." 16 (Brief pause.) 16 My question for you is, what was your 17 THE VIDEOGRAPHER: The time is 5:01 p.m. We 17 understanding of the things that were important to the 18 are back on the record. 18 Speaker? 19 BY MR. DEVANEY: 19 A I don't know specifically. I don't know. 20 Q Mr. Reichelderfer, in Exhibit 40, you state 20 Q At this time the Speaker was your client. 21 in response to this Florida Senate congressional map, 21 A Yes. 22 it is workable. What did you mean by it is workable? 22 Q And did you make an inquiry of Mr. Kelly 23 A I can't go back and get in my head what I was 23 about what the Speaker said was important to him? 24 thinking two years ago. 24 A No, I didn't have a conversation with 25 Q By the way, you say two years ago. It really 25 Mr. Kelly at all. This was sent to me from Kirk 281 283 1 was a year and a half ago, wasn't it? 1 Pepper. 2 A A year and a half. 2 Q Is it your testimony you had no idea about 3 Q When you say it is workable, you were 3 the things that were important to the Speaker with 4 speaking of political performance, weren't you? 4 respect to the congressional map? 5 MR. ZAKIA: Object to form. 5 A I mean, the things that were important to the 6 THE WITNESS: I don't know that is the case. 6 Speaker, I mean, I don't, I mean, passing the legal, 7 BY MR. DEVANEY: 7 passing and being upheld by the courts was a priority 8 Q It may have been, though, right? 8 of the Speaker. That was the number one priority. 9 A I, no, I don't know that I could make that 9 So I mean, other than that, what other 10 assumption. 10 priorities -- 11 Q You don't know one way or the other? 11 Q And the Speaker also was concerned about 12 A No. 12 political performance, wasn't he? 13 Q And then you say the pieces are mostly in the 13 MR. MEROS: Object to form. 14 right place. What do you mean by the pieces? 14 MR. ZAKIA: Same objection. 15 A I think you are just looking at blocks of 15 THE WITNESS: I don't know that specifically. 16 trying to comply with Amendments 5 and 6. 16 BY MR. DEVANEY: 17 Again, now, I'm speculating on what that 17 Q Did you ever discuss with the Speaker the 18 meant. I looked at this document, I made some 18 importance of having a congressional map that would 19 comments, but I don't recall. 19 perform well for the Republicans? 20 Q Could you please pull out Exhibit 30. 20 A I don't recall specifically having that 21 A (Witness complying.) 21 conversation. 22 MR. ZAKIA: Bates 99. 22 Q Are you denying you had it? Or you just 23 MR. DEVANEY: Actually, Bates number 96. I 23 don't know? 24 think I misnumbered. 24 A I don't know. 25 MR. ZAKIA: Bates 96 is 28. 25 Q Could I ask you to take a look at Exhibit 41 (Pages 280 to 283) WWW.USLEGALSUPPORT.COM 954-463-2933 284 286 1 three, please? 1 I haven't gone to an iPhone yet. 2 A Yes, sir. 2 Q Just a couple more questions. At the meeting 3 Q Just for the record, remind us what Exhibit 3 3 on December 3rd, 2010, were you representing someone in 4 is. I think it is a document that you prepared. 4 particular when you attended that meeting? 5 A I think I was just trying -- these are 5 A Not necessarily. Not specifically. 6 personal notes that I made myself trying to come up 6 Q And why did you attend the meeting? 7 with questions that I think I didn't have an answer to 7 A We are a loose knit group of Republican 8 and I would be interested to know. 8 consultants. 9 Q And was this document used at any meeting 9 Q At whose behest did you attend? 10 that you ever attended? 10 A Rich Heffley invited me to attend. 11 A I don't believe so. No, it was not. 11 Q My final line of questions is, there was a 12 Q Your last bullet point states, "Communication 12 series of e-mails -- and I don't think we need to go 13 with outside non-lawyers, how can we make that work?" 13 through the documents -- but that occurred over 14 What was your, what did you mean by those 14 Thanksgiving weekend in 2011. Do you recall that? 15 words? 15 A Yes, sir. 16 A I believe it meant somehow being, some of the 16 Q And there was discussion among you and 17 consultants being involved in the process, which we 17 Mr. Pepper and Speaker Cannon about having a meeting. 18 were not included in that aspect. 18 Do you recall that? 19 Q And I know you had a discussion with Mr. King 19 A Yes, sir. 20 earlier about a discussion of involvement of political 20 Q To discuss redistricting issues, correct? 21 consultants in the redistricting process in a 21 A I think there were a number of issues on 22 December 3, 2010 meeting and another meeting, early 22 that, on that list, on that e-mail. 23 2011. Do you recall that? 23 Q But it included redistricting issues? 24 A Yes, sir. 24 A I think that was one thing on there, yes, 25 Q And my question for you is, did you 25 sir. 285 287 1 ultimately receive instructions about how to 1 Q And did that meeting ever take place that 2 communicate on redistricting issues? 2 weekend? 3 A I did not, no. 3 A I don't, according to the e-mails, I think it 4 Q So no one ever told you to communicate in a 4 said not, but I don't recall whether or not it took 5 certain way or through a certain mode of communication? 5 place after that. 6 A No, sir. 6 Q So you don't know whether that Monday or 7 Q Did you communicate with respect to 7 Tuesday after Thanksgiving weekend, whether you met 8 redistricting via texting at all? 8 with Speaker Cannon and Mr. Pepper to discuss the 9 A Not, not very frequently. I don't know that 9 congressional map? 10 I ever did, but -- 10 A I don't recall. Actually, I know I did not 11 Q You said not very frequently, that sure 11 meet with them to talk about the congressional map, 12 suggests that you did. Did you? 12 specifically. 13 A I don't text message very often. That's 13 Q Did you meet with them to discuss other 14 generally why I -- 14 maps -- 15 Q Did you text with respect to redistricting 15 A No. 16 issues? 16 Q -- after Thanksgiving weekend? 17 A I, I don't know. 17 A (No response.) 18 Q In responding to the document request that 18 Q You don't know? 19 was served upon you, did you check your text history to 19 A I don't know. 20 see if you had any redistricting texts? 20 Q I do have one more line of questions for you. 21 A My cell phone only goes back about 30 days, 21 You said that -- you never say I'm done with a line of 22 or my texting and e-mails. 22 questions. But you said that you had some clients on 23 Q Did you check to see if you had any? 23 the redistricting committee. 24 A Yeah, I mean, my, if I don't delete e-mails 24 And I think you identified Horner, Legg and 25 older than their two months, my BlackBerry freezes up. 25 Young. Did I get that right? 42 (Pages 284 to 287) WWW.USLEGALSUPPORT.COM 954-463-2933 288 290 1 A I think that's correct. 1 Q Is it possible you did? 2 Q Were there any others, any other clients who 2 A It is possible. 3 were on redistricting committees? 3 Q Were those communications you had with them 4 A I don't recall. That's only the House. I 4 private communications or were they publicly disclosed? 5 don't recall even who was on the Senate redistricting 5 MR. ZAKIA: Object to form. 6 committee. I could have had clients on that one; but I 6 THE WITNESS: I don't know if I understand. 7 was looking at the list and reading them off the list 7 BY MR. DEVANEY: 8 in that case. 8 Q Did you just have private conversations with 9 Q Did you have any conversations with the three 9 them about maps and how they would perform under 10 people I just named, Horne, Legg and Young about the 10 various maps? 11 redistricting process when they were on those 11 A That's not what I said I think the 12 committees? 12 conversation I had. 13 A Can you be more specific than that? 13 Q Whatever conversations you had, were they 14 Q I think the question speaks for itself. 14 just private between you and your client? 15 A It is likely that I had a conversation about, 15 A My conversations were private with my client, 16 generally about, you know, oh, you are going to 16 yes. 17 redistricting, where you are going to have the hearings 17 Q And I take it that you never disclosed to 18 and stuff like that, but nothing more specific than 18 anyone that you were having these conversations with 19 that. 19 people on the redistricting committee or committees 20 Q Did you ever discuss maps with your three 20 about how certain districts would perform, is that 21 clients who were on the redistricting committee? 21 correct? 22 A I don't recall. 22 MR. ZAKIA: Object to form. 23 Q It is possible that you did? 23 MR. MEROS: Object to form. Go ahead. 24 A It is possible that I did when they called me 24 THE WITNESS: I don't know that I had 25 to ask about districts that were made public, about 25 specific conversations with them or not. 289 291 1 their specific districts. 1 BY MR. DEVANEY: 2 Q Tell me what calls you recall -- 2 Q I thought you said that you did have 3 A I don't recall whether they did, but it 3 conversations with respect to how their districts would 4 wouldn't be unlikely if they called to say, hey, how is 4 perform? Am I wrong? 5 this district going to affect me. 5 MR. MEROS: Object, form. Go ahead. 6 Q Did they call, did you have discussions with 6 MR. BROWN: Go ahead. 7 them with respect to all three maps -- the House, the 7 THE WITNESS: I said it is possible 8 Senate, and the congressional maps? 8 conversations could have take place. I don't 9 A No. 9 recall. 10 Q Do you recall which maps you discussed with 10 MR. BROWN: It is now 5:16. It is time to 11 them? 11 conclude for him. 12 A The only conversation I would have had with 12 MR. DEVANEY: Okay, thank you. 13 them would have been them asking about their specific 13 THE VIDEOGRAPHER: The time is 5:15 p.m. We 14 districts. In which case, it would have been the state 14 are off the record. 15 House map. 15 MR. DEVANEY: I think we will say for the 16 Q Do you recall what you may have told them 16 record, the questioning of Mr. Reichelderfer has 17 about their specific districts? 17 not been completed, and that we will have to 18 A I don't recall. 18 resume at a mutually agreeable time. 19 Q And did they ask about political performance 19 (Whereupon, the taking of the deposition was 20 in their districts that were reflected in maps that 20 recessed at 5:15 p.m. Reading and signing were not 21 were being proposed? 21 waived.) 22 A That could have been a topic of conversation. 22 23 Q And did you provide performance analysis for 23 24 them? 24 25 A I don't recall. 25 43 (Pages 288 to 291) WWW.USLEGALSUPPORT.COM 954-463-2933 292 1 C E R T I F I C A T E 2 STATE OF FLORIDA 3 COUNTY OF LEON 4 5 I, PEGGY L. OWENS, Registered Professional 6 Reporter, at Tallahassee, Florida, do hereby certify as 7 follows: 8 That I correctly reported in shorthand the 9 foregoing proceedings at the time and place stated in 10 the caption hereof: 11 That I later reduced my shorthand notes by 12 computer-aided transcription, or under my supervision, 13 and that the foregoing pages 128 through 291 both 14 inclusive, contain a full, true, and correct transcript 15 of the proceedings on said occasion: 16 That I am neither of kin, nor of counsel, to any 17 parties involved, nor am I financially interested in 18 this action. 19 THIS the 22nd day of May, 2013. 20 ______21 PEGGY L. OWENS Registered Professional Reporter 22 Registered Merit Reporter 23 24 25 293 1 CERTIFICATE OF OATH 2 3 STATE OF FLORIDA 4 COUNTY OF LEON 5 6 I, Peggy L. Owens, Registered Professional 7 Reporter, Notary Public, State of Florida, certify that 8 MARC REICHELDERFER personally appeared before me on the 9 16th day of May, 2013, and was duly sworn. 10 Signed this 22nd day of May, 2013. 11 12 13 ______14 PEGGY L. OWENS, RMR, RPR 15 Notary Public - State of Florida My Commission No. EE 88005 16 Expires: 8-23-15 17 18 19 20 21 22 23 24 25 44 (Pages 292 to 293) WWW.USLEGALSUPPORT.COM 954-463-2933 Page 1

A age 154:19 155:3 answer 130:10 167:3,12,16,20 ability 186:8 251:12 135:6,7 148:1 167:21,22 267:5 able 215:17 229:9 agenting 191:4 157:19 166:6 268:14 251:16 ago 202:21 204:7 172:13 173:13 appropriately absolutely 150:8 215:14 223:17,23 195:11 199:19 193:4 239:8 247:8 230:11 272:18 200:1,2 208:24 approved 221:25 acceptable 184:3 280:24,25 281:1 222:6 223:3,7 area 215:1 229:23 184:20 188:18 agree 133:25 226:20 227:13 argument 129:23 access 181:16 140:13 149:24 240:24 241:7,12 130:2,5,6 187:2 156:9,14,16 244:25 245:3 argumentative accommodated 163:18 165:10 249:13 264:22 166:5 168:6 198:16 166:7 167:1,5 268:8 278:22 199:15,23 201:9 accommodates 192:5 170:14 193:24 284:7 207:22 196:1 197:12,19 201:11 218:1 answered 171:25 article 139:9,13 accomplish 147:19 219:10,14 172:2 183:11 225:20 228:15 207:6 agreeable 291:18 199:16 222:2,5 ascertain 223:8 account 166:12 agreement 240:12 answering 188:16 227:2 180:4 242:10 224:16,18 ascertained 228:7 accurate 183:2 agreements 240:8 answers 130:20 asked 135:1,22 achieve 274:19 ahead 131:15 132:7 244:15 165:19 199:15 acrimony 203:17 151:6 169:4 anticipate 275:8 203:11 209:4,15 act 154:8 198:8,24 172:16 173:19 anticipated 247:19 214:12 222:2,5 252:1,2 274:20 193:12 199:19 anybody 143:4,15 223:5,5 231:21 action 292:18 208:24 212:1 143:22 149:22 244:17 261:21 Adams 253:20 254:2 245:18 269:25 150:9 170:20 274:5 additional 216:11 272:10 273:8 211:11 238:6 asking 196:15,19 addressed 278:25 278:8 290:23 242:15 252:4 215:8 226:12 adopted 210:22 291:5,6 260:19 245:3 254:20 advance 131:22 aide 263:10 apologize 159:17 267:24 289:13 132:10 al 121:4,10,14 223:6 224:19 aspect 284:18 advanced 220:5,10 Alex 135:13 177:2 282:5 assert 239:1 220:17,17,24 177:5,9 179:13 Apparently 169:7 asserting 261:11 221:5 180:6,9,15 174:14 192:14 assertion 239:6 advantage 226:9 264:12 282:10 194:22 215:21 241:8 251:15 advantages 138:15 Alex's 180:1,5 232:21 233:10 Associates 158:9 advice 132:6 alleging 261:6 235:3 assume 144:14 172:24 208:9,19 allow 180:13 appear 123:15 155:1 168:17 210:15,18,24 amendment 129:24 137:12 165:17 178:4 197:8 211:4 227:8 198:18 249:4 APPEARANCES 123:1 205:11 242:1 240:20 242:5 amendments 267:17 appeared 122:6,12 249:20 259:15 250:1,5 266:18 267:22 281:16 122:17,22 123:5 assumed 176:14 advise 131:5,13 amount 265:13 123:8,13,19 assumes 268:4,5 169:20 172:17 analyses 211:16 243:17 279:13 277:2 193:22 206:11 271:9 276:16 293:8 assumption 179:1,3 207:16 209:23 analysis 170:23 appears 141:1 205:10 234:3,7 249:21 253:7,11 221:12,19,21 145:13 164:16 281:10 advised 194:3 226:25 254:18 177:24 178:8 attached 126:22,24 208:1,4,8 266:15 271:12 273:14 183:17,21 188:15 152:20 153:11 advising 132:1 276:23,24 277:5 188:19 191:19 225:20 133:14 193:25 277:12,25 278:13 195:3 214:24 attaches 141:1 208:12,13 289:23 226:5 235:16 144:11 affect 133:7 289:5 analyze 168:2 236:9 237:21 attachment 125:6 affiliation 278:19 172:17 248:20 257:22 141:6 142:7 African-American analyzing 270:19 259:11 279:25 144:11,15 158:12 252:21 and/or 253:11 appointed 228:19 256:9,10 afternoon 182:20 Anna 264:16 appreciate 239:4 attachments 125:8 216:20 260:16 announced 188:24 approaching 226:9 125:9,10,11,12 202:19 appropriate 142:14 125:13,14,15,16

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125:17,18 126:7 basically 193:9 bit 189:4 210:12 263:17 126:8,16,17,19 229:16 271:13 212:22 215:3 business 133:13 126:20,23 141:8 basis 209:4 239:6 261:22 262:18 247:13 262:20,21 attempt 227:1 247:12 251:8 265:13 263:22,23 249:7 251:17 Bates 120:8 139:6 black 154:19 155:3 attempted 251:19 258:18 281:22,23 251:12,20 C attempting 155:1 281:25 BlackBerry 285:25 C 122:1 123:2 attend 136:7,9,11 bear 261:22 Blackwell 122:4 292:1,1 286:6,9,10 Beginning 262:1 Blk 153:25 154:17 calculated 146:21 attended 284:10 begins 279:7 blocks 146:24 calculation 147:16 286:4 behalf 122:7,12,17 281:15 call 145:5 186:5 attorney 122:9,14 122:23 123:5,8 blue 272:15 203:24 204:5 122:19 123:2,6 123:14,20 209:5 bodies 147:22 238:19,21 241:5 123:16 239:10,16 242:15 191:4 195:16 242:22 272:18 240:13 243:24 behest 286:9 Boggs 239:11 273:1 289:6 attorneys 122:3 belief 243:25 boldly 138:7,11 called 128:4 242:13,16 believe 131:16,16 BONDI 121:7 176:15 235:10 attorney-client 132:21 134:12,15 boss 209:5 288:24 289:4 239:2,24 240:2,5 137:3,14 138:17 bottom 259:2 calls 289:2 240:18,23,25 138:20 139:23 Boulevard 122:21 calm 203:25 241:11,15 242:7 144:10 145:22 box 122:4,15 campaign 139:17 August 140:24 150:16 152:5 165:18 244:15 262:13,16 141:18 142:5,15 153:23 157:1,4 break 187:10 263:25 264:17,24 144:8 157:11,16 158:2 236:13 237:23 264:25 266:8,16 authored 188:12 158:22 167:23 breaking 236:12 266:16,17 available 149:23 168:7 174:11,18 Brickell 123:18 campaigns 132:14 Avenue 123:18 177:7 178:18 Brief 187:14 202:2 candidates 137:7 avoid 186:1 229:6 179:23 180:1 238:1 275:19 146:12 169:9,11 aware 198:18 215:6 182:25 184:17 280:16 Cannon 120:13 186:18 189:11 bring 226:19 131:5,13 135:16 B 190:7,12 191:1 Brown 123:2 135:6 135:19,25 170:20 B 122:2 123:7 207:18 211:2,10 138:19 142:25 171:1 172:24 back 128:7 133:2 222:7 224:6,23 166:5 168:6 173:4,12 174:6 178:22 184:7 229:9 234:17 171:6 182:8 175:5,24 176:4 187:16 188:13 240:20 241:2,10 186:16 187:17 178:22 183:22 191:25 203:22 243:2,4,6,10,13 195:11 199:15,23 184:7,18 185:18 205:15 214:15 243:15 246:11 200:2 201:9 188:8,14 191:25 224:7,17 233:1,8 267:12 270:18 207:21 208:23 193:9,16 197:8 236:5 238:3 271:11 277:4 209:7,24 220:25 199:1 202:19 261:24 263:7 278:4 284:11,16 222:2,5,12 203:7,9,22 265:9 268:14 believed 167:21 224:11 226:20 206:12 207:16 275:21 280:18,23 243:12 232:25 238:10,11 208:14,21 209:6 285:21 Ben 238:21,23 238:20 239:1,8 209:13,16 215:23 bad 171:11 benefits 138:15 240:3 241:7,17 216:6 217:18,25 Bainter 140:24 best 131:21 169:9 243:19 244:25 222:4 227:24 141:18 145:11 169:21 221:6,21 245:6,13,17,19 249:21 253:8,11 148:5 225:12 232:4 245:22,24 246:2 253:16 265:3,4,4 228:17 246:15 bet 202:23 246:8 251:3 267:8,16,23 248:4 better 153:24 252:5,16 258:15 268:1,6,23 269:4 balanced 250:24 157:6 187:2 261:14,16 268:3 276:1 286:17 BALDACCHINO 120:8 230:14 259:8 275:3,8,15 291:6 287:8 barely 257:14 262:12 291:10 capacity 120:11,14 Bascom 225:10 beyond 193:7 Brown's 251:11,21 262:14 266:14 228:14 bigger 177:15 252:14 253:9,12 Capitol 123:12 based 188:19 180:17 282:13 bullet 129:9,10 caption 292:10 200:21 234:3 Bill 125:19 262:12 284:12 care 155:16 201:22 249:10,20 259:7 Billrakis 254:13 bunch 146:24 244:9 carefully 193:22 bases 147:15 Biscayne 122:21 Bush 263:10,11,16 197:9

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WWW.USLEGALSUPPORT.COM 954-463-2933 Page 12 message 176:18 MyDistrictFold... 174:9,10,20 250:3 252:5,6,16 285:13 145:1 175:15,24 179:21 260:1 268:3 messed 212:22,25 182:15,15 183:10 269:25 271:3 213:5,10,15,20 N 183:22 184:8 272:9,10,16 215:9,11,16 N 121:21 122:1,14 188:5,9 192:1 273:8,16 281:5 278:16,21 122:19 124:2 194:24 201:18 283:13 290:5,22 met 262:10 263:18 128:1 202:17 203:7 290:23 291:5 264:20 276:25 name 144:14 163:6 204:18,23 205:15 objection 131:15 287:7 234:3 212:14 216:17 133:24 155:23 Miami 122:22 named 288:10 225:10 270:8 156:6,7 171:16 123:18 names 257:16 271:23 274:3 192:21 196:11 Mica 253:19 254:2 National 120:4 276:14,19 279:19 199:15,23 201:9 mid 128:23 261:18 282:8 201:10 209:24 midday 183:3 nature 265:22 No.60 257:24 211:24 216:9 mind 129:19 near 129:14 number 174:6 224:1 222:2,5 283:14 minority 154:10,20 nearly 155:20 230:25 236:4 obtained 150:3 154:25 198:9,10 156:3 255:20 249:5,6,8 251:6 Obviously 133:6 198:11,19,22 necessarily 156:8 251:14 253:2 occasion 292:15 199:3 206:24,25 156:9 167:5 258:18 263:19 occasionally 195:8 207:1,2,4 223:12 168:22 170:9 272:19 281:23 195:14 262:23 251:12,23,25 186:5 192:22 283:8 286:21 264:10 252:3 274:17,19 193:1 208:18 numbers 139:16 occur 227:17 277:19,19 286:5 145:15 249:10 occurred 129:6 minute 189:6 necessary 261:18 NW 122:11 166:15 174:9 201:25 230:11 need 130:3 184:4 188:5 245:4 255:2 219:14 227:12 O 286:13 minutes 212:17 245:13 255:4 O 128:1,1 occurring 128:13 214:6 246:6 286:12 oath 198:25 293:1 228:1 247:4 275:4,11,13 needed 227:6 object 131:7 132:7 office 122:15 misnumbered 281:24 needs 275:5 132:25 133:16,17 137:7 166:13 missing 184:6 neglected 248:1 133:23 134:24,25 179:17,21 227:25 misspoke 267:13 neighborhood 138:9 140:16 offices 122:3,10 misunderstand 277:15 150:19 151:6 122:15,20 123:3 237:7 neither 167:19,19 155:22 164:25 123:17 mode 285:5 174:15 292:16 165:9,23 166:4,5 official 120:11,13 moment 215:8 275:3 never 157:18 166:16,25 168:6 oh 288:16 Monday 182:24 221:19,21 287:21 168:21 169:23,24 okay 128:9,22 287:6 290:17 170:4,13,21 134:3,7,22 money 242:12,16 new 172:4 186:20 171:4,6,15 172:6 135:10,13 138:14 Monroe 123:3,11 226:3 229:24 172:11,19 173:6 139:12,21,24 months 263:1,1,4 news 228:15 173:7 175:8 141:16,23 142:7 264:4 285:25 nice 254:13 176:16,20,21 142:13 143:16,18 morning 267:4 night 158:16 210:6 178:24 180:23 144:21 145:14,23 275:5 nine 232:17 182:8 184:13,22 146:14 149:24 move 129:25 159:18 nine-ish 262:3 184:23 186:11,23 151:3,10 153:4 251:20 252:24 non-lawyers 284:13 191:6,12 192:20 153:17 154:22 253:1,1 282:5 non-parties 261:5 193:5,12 194:25 156:11 157:9,17 moved 133:3 221:25 normally 245:8 195:6 199:17 158:23 159:13,17 252:13,14,24 northeast 177:14 200:9,20 205:9 160:1 165:20 movement 253:3 Notary 293:7,15 206:14,20 207:20 167:16,19 170:17 moving 165:21 note 187:18 207:21 208:5,15 170:17 171:1,9 172:3 252:21,25 notes 284:6 292:11 208:23 209:7 171:12,17,18 253:4 November 139:6 211:1,18,19 173:14,16 174:3 multifaceted 149:1 150:1 213:1,6,16,22 175:4 177:1,9 217:20 153:18 156:21 216:1 219:8,9 179:20 180:7 multiple 223:19 158:8 160:2,14 220:6,12,19 182:16 184:10 261:4 161:5,13,21 221:8,17 227:11 185:25 186:20 mutually 291:18 162:4 163:11 228:2,11 229:8 187:5 188:4

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189:9,12 190:1,4 originated 150:12 178:21 270:17 271:22 191:24 193:11,17 150:12 passed 152:13 272:3 274:1,9,13 196:24 199:5 Orlando 122:5 178:18,20 180:6 274:23 275:25 201:16 202:3 Osceola 254:16 209:15 266:4 276:13,20 279:8 210:7 215:22 ought 131:6,14 277:24 278:1,11 279:22 282:7 218:7,16 219:13 148:3 193:23 passing 178:16 283:1 286:17 223:4 224:16 194:1 207:17 224:7,20 283:6,7 287:8 230:21 233:3 219:19 220:4 Pat 140:24 141:18 percent 153:25 234:7 235:16 247:22 145:9 159:16 154:1,18 251:12 237:22 238:14,20 outcome 155:21 228:16 252:22 239:13 240:11 156:4 Patton 239:10 percentages 181:8 241:14 242:6 outside 179:24 pause 202:2 275:19 perform 146:11 243:15 244:23 180:25 272:21 280:16 147:4,17 170:18 246:7,25 247:9 284:13 pdf 254:24 193:3 249:24 247:15 248:1,14 Owens 120:22 292:5 Peace 157:7 277:25 278:12 248:17 250:14,18 292:21 293:6,14 Peggy 120:22 292:5 283:19 290:9,20 256:4 258:14,22 o'clock 210:5 292:21 293:6,14 291:4 260:12 264:12 pending 183:11 performance 146:15 266:13 267:15,25 P people 131:5 133:7 146:20 147:24 270:19 278:8 P 122:1,1 128:1 137:6,15,22 193:7 211:15 282:3 291:12 PA 122:4,15 123:17 143:23 171:14 214:12,22 215:4 old 229:24,25 page 124:3 125:2 177:10 186:9 215:5 221:12 230:15 126:2 127:2 227:25 252:24,25 270:12,12,15,16 older 285:25 164:10,11,12 252:25 253:1,2,3 270:20 271:16 OLIVER 120:7 177:1 253:4 261:25 273:14 274:2,5,8 OLMSTEAD 120:6 pages 235:24 268:1 288:10 276:16,23 277:5 once 139:25 146:21 292:13 290:19 277:17,21,22,25 224:21 236:19 paid 242:12,16 Pepper 135:10,11 278:13 281:4 264:1 265:16 painful 200:16 159:24 160:15,22 283:12 289:19,23 266:25 PAM 121:7 161:5,13 162:4 performed 147:4,10 ones 169:9 229:25 panel 228:15 162:21 164:22 147:13 169:9,13 230:15 paper 189:20 165:13 166:2,12 192:18 206:11 ongoing 228:6 paraphrasing 267:4 167:4 169:20 221:6 276:15,23 open 142:20 151:11 parcel 217:21 170:20 171:2 277:4,12 152:23 217:5 part 205:11 243:14 173:3,9,11,13 period 174:15 255:1 243:16 251:6 174:6 175:16,24 177:12 219:4 operation 207:5 participating 176:2,19 177:20 252:13,17,19 opine 165:5 219:3 210:20 178:16,22 180:15 263:25 265:10,12 219:6 274:15,16 participation 181:19 182:14 265:19 270:17 274:21 211:12 188:9 192:2 273:6 276:14 opined 274:11,16 particular 147:9 201:19 202:18 277:11 opinion 134:7 147:12 178:14 203:8,23 206:5 periods 264:3 opinions 215:18 210:23 215:7 207:14 208:9,9 265:1 217:17,24 222:9 275:25 286:4 208:13,20,21 Perkins 122:10 222:15 particularly 209:4,14,14 permanent 166:14 opportunity 133:20 231:13 213:14 214:8 person 238:18 168:1 178:21 parties 292:17 215:23 216:6,17 personal 211:5 179:4,5 227:24 partisan 210:19 217:19 218:7,18 284:6 246:21 211:12 218:20 219:13,23 personally 181:12 opposed 222:10 party 169:22 231:7,10,17 243:23 244:3 opposition 228:9 181:22 193:4 232:13,19 233:9 293:8 options 163:2 217:2 219:3,18 233:20 234:25 perspective 197:20 Orange 254:15 221:7 226:7 236:19,22,24 197:21 269:2 265:7 241:21,25 242:2 248:15 249:11,21 PETERS 120:7 order 198:7 233:4 242:3,3 252:23 253:8,11,16 phone 241:5 242:22 279:4 261:7,16 262:5,9 255:11 257:4 245:22 246:4 organization 278:19 258:24 259:1 272:18 273:1,2 261:13,15,23 pass 141:17 171:13 262:1,2,4 270:7 285:21

WWW.USLEGALSUPPORT.COM 954-463-2933 Page 14 phrase 245:1 165:7 168:19,25 205:14 284:4 146:17 148:16 physically 154:7 172:15 173:17,18 preparing 238:5 149:19 155:19,20 251:16 181:21 182:6 247:22,25 260:18 155:21 156:2,4 picks 197:8 185:9,25 193:21 present 187:25 165:3 177:22 piece 210:23 210:19 211:12 245:20,21 264:21 191:3 211:8,13 pieces 210:12 214:22 221:10 265:20 217:6,10,13 212:4 217:21 263:13,14 270:12 presentation 219:3 221:25 281:13,14 271:16 273:14 143:12 224:2 228:6 Pinellas 177:12,12 274:2,5,8 276:16 presidential 284:17,21 288:11 177:14,14 282:13 276:23,23 278:12 147:10 226:8 proclaim 138:12 place 136:6 170:10 281:4 283:12 270:24 271:2,6 proclaimed 138:7 177:20 180:10 284:20 289:19 press 138:8 189:16 138:11 184:10 202:23 politically 146:12 216:22,23 219:20 produce 153:5 210:12 212:4 156:12 169:15 266:19 214:16 247:14 281:14 170:19 192:18 pressed 146:17 produced 139:11 287:1,5 291:8 politics 262:15,17 pretty 129:2 141:8,23 142:10 292:9 Polk 177:11 254:14 prevent 154:9 142:11 157:21 Plaintiff 122:7,13 254:15 preview 171:14 162:11 266:17 plaintiffs 120:9 population 154:20 previous 188:20 277:15 121:5,12,19 155:2,3 251:13 200:21 producing 137:19 123:20 260:17 portion 177:12 previously 128:4 138:5 plan 158:10,13,18 187:21 203:17 274:19 production 157:15 158:19,23 177:23 posed 209:4 primarily 192:24 157:17 169:2 177:25 178:1,1,1 position 131:4,12 print 150:24 153:5 Professional 178:3,4,6 198:16 138:14 147:23,25 printed 151:4 120:23 292:5,21 220:16 225:14 172:17 229:5 152:13 153:2 293:6 228:20,23 229:1 230:11 prior 147:4 157:23 program 143:14 229:21 230:5 positions 195:15 242:25 146:18 155:12 233:24 235:7,10 possible 129:15 priorities 283:10 progress 164:2 235:12,19,19 189:3 190:11,25 priority 283:7,8 project 185:2 plans 164:10,15 269:15 273:11,12 private 290:4,8,14 projects 263:23 179:17,20 181:20 273:19,20 274:6 290:15 proper 142:14 194:15,16 210:15 274:7 276:10 privilege 239:2,6 proposals 225:15 210:22 217:16 288:23,24 290:1 241:9,10,11,15 proposed 147:9 219:22 220:4,4 290:2 291:7 241:15,16 242:8 289:21 220:10 266:16,17 possibly 176:23 261:2,12 proposing 176:3 play 132:2 242:17 272:14 probably 128:16 pros 135:24 played 155:18 Post 122:15 136:12 145:24 protected 229:17 playing 257:2 posted 149:21,22 149:16 150:16 prove 140:1 please 135:6 182:3 150:9,13 157:13 177:8 provide 170:19 281:20 284:1 potentially 197:1 185:7 189:21 194:14 208:21 pleasure 176:11 power 172:10 190:22 191:1 222:16,20 253:18 plural 196:16 PR 266:19 209:20 216:10 289:23 plus 251:12 254:16 practical 256:24 237:8 259:9 provided 179:10 point 129:9,10,11 256:24 260:9 262:3,11 196:9 246:23 133:2 154:9 practice 239:22 263:4,7,7 265:5 276:14,20 277:11 156:20 179:21 precede 175:18 270:14,24,24 provides 180:12 181:3,7,24 precinct 146:22,25 271:17 272:8 233:22 219:19 224:14 predicate 239:5 275:10 277:14,18 providing 208:19 228:21 230:13 242:7 245:14 problem 223:12 210:20 235:10 233:16 236:12 268:4 226:3 public 128:15 246:8 270:14 premise 165:10 problems 216:6 133:7 143:15,22 279:15,16 284:12 170:14 proceeded 251:17 143:24 145:4 pointers 137:2,11 preparatory 238:7 proceedings 187:22 146:3 149:16,18 pointing 230:10 prepare 247:23 292:9,15 149:25 150:9 points 226:2,6 prepared 151:24 process 128:15 163:10,15 164:24 political 131:6 153:1 162:14 129:13 131:18,23 165:15 166:3 134:17 139:25 163:3,4,6 205:8 132:13 138:8 168:1,11 172:16

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173:16,19,24 172:2,4,13 282:11 274:24 275:1,2 174:1 179:25 173:13 183:2,11 reading 288:7 275:24 276:1,11 180:2,2,13,14 186:15,20,20 291:20 276:12 277:6 181:21 191:2 188:16,20 193:13 reads 197:18 278:14,22,24 200:8,19 205:20 200:1,2 208:24 ready 148:15 202:3 279:2 280:4,4,7 206:19 211:9 209:8,9 214:24 real 254:13 256:25 280:11 281:19 215:20 217:17,24 215:8 216:2,3 258:8 262:11 283:20 284:23 232:3 234:8,13 217:20 218:8 really 130:4,22 286:14,18 287:4 234:19,21 235:2 222:19 223:5 133:13 156:11 287:10 288:4,5 266:18 288:25 224:18 226:23,24 159:3 194:7 288:22 289:2,3 293:7,15 228:3 234:23,24 219:6 243:23 289:10,16,18,25 publicly 149:21,22 236:20 240:22,24 244:11 254:10 291:9 150:13 164:18 244:25 245:2,14 277:9 280:25 recalled 274:5 169:6 174:17 248:2 252:17 reapportionment receive 285:1 191:14 223:20 261:11 263:5 148:12 received 163:11 279:23 280:2 268:4,5,19 269:9 reason 168:15,17 171:22 173:25 290:4 276:17 277:2 168:18 186:22 204:22 205:15,19 pull 150:10 281:20 278:23 282:16 189:1 190:23 207:13 216:8 pulled 163:23 284:25 288:14 192:17 206:18 receiving 166:23 205:5 271:13 questioning 187:18 219:1 224:23 recess 187:14 purports 144:7 270:6 291:16 234:17 238:17 238:1 159:24 258:23 questions 130:9,13 recall 128:16 recessed 291:20 purpose 148:4 130:19,20 135:2 129:1,17,20 recognize 136:20 209:19 135:21,23 209:4 134:21 136:1 140:23 144:5 purposes 154:23 237:5 241:8,12 137:1,16,24 149:1 153:18 256:24 245:8,11,15 138:22 139:5 160:5,13,22 put 184:2,5 185:3 260:13 261:21,25 145:6 146:15 161:4,12,20 188:17,17 190:14 267:3,24 271:21 149:12 150:7 162:3,8 163:25 191:2 192:7,13 275:23 284:7 152:15 153:9 175:15 182:14 194:21 196:3 286:2,11 287:20 154:14,16 155:6 188:6 201:17 197:15,16,21 287:22 157:13 159:2 202:17 203:6,22 201:5,8 229:1,13 quiet 219:15 163:2 165:16,19 204:19 207:13 266:16 quote 139:15,19,20 165:24 168:14 212:12 214:5 putting 131:4 153:24 177:9,17 169:1,18,25 216:16 218:17 183:2 184:19 183:12 184:2 170:6 172:7,21 225:8 233:17 185:12 188:24 188:23 192:5 173:1,2 174:2,2 248:15 250:12 190:5 193:2 202:19 203:8,10 174:3,4 175:9 255:10 256:5 196:6 202:20 203:24 210:11 180:19 182:9,21 recollection puzzle 156:3 207:6 253:19 269:7 185:7,13,16 185:14 197:25 puzzles 155:17 279:10 282:12 186:24 192:16 199:7 204:8 p.m 121:22,23 quoted 139:9,12 195:1 201:4 231:25 276:5,8 128:6 182:15 quotes 282:9 204:6 205:16 recommend 221:24 187:12,15 188:9 208:11 209:25 recommendation 210:5 212:15 R 211:7,7 212:5 220:21 238:2 248:16 R 122:1 292:1 215:12 220:7,13 recommendations 275:17,20 280:14 race 264:18 270:25 220:20,22 223:11 129:16 280:17 291:13,20 rank 134:3,6 223:14 231:12,24 recommended 220:16 P.O 122:4 ranking 133:12,21 232:6,7,18 234:2 275:25 276:5 134:4 234:6 235:8,12 record 128:7 Q rate 138:1 141:16 237:1 248:24 166:14 180:2 question 129:9 raw 152:8,9 249:23,25 250:4 187:13,16,19 131:8 133:18 RAZA 120:5 252:11 253:14,25 237:25 238:3 135:7,8 138:19 reach 131:11 255:1,15 259:13 244:23 275:15,18 141:17 142:25 188:20,21 267:9 268:24 275:21 278:17 148:2 155:25 read 189:19 196:25 269:11,13,14,21 279:7 280:13,15 157:19 165:11,20 197:1 199:7,10 270:6,23 271:17 280:18 282:6 170:15,25 171:7 199:12,21 218:23 271:18 272:7,23 284:3 291:14,16 171:10,11,25 225:19 246:20,21 274:1,4,6,10,13 records 144:9

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WWW.USLEGALSUPPORT.COM 954-463-2933

EXHIBIT D 1 3

IN THE CIRCUIT COURT OF THE REPRESENTING FLORIDA HOUSE OF REPRESENTATIVES: SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA RENE ROMO, et al., GEORGE N. MEROS, JR., ESQUIRE Plaintiffs, [email protected] vs. CASE NO. 2012-CA-00412 GRAY ROBINSON KEN DETZNER and PAM BONDI, P.O. BOX 11189 Defendants. ______Tallahassee, FL 32302 850.222.7717 THE LEAGUE OF WOMEN VOTERS OF DANIEL E. NORDBY, ESQUIRE FLORIDA, et al., [email protected] Plaintiffs, vs. CASE NO. 2012-CA-00490 FLORIDA HOUSE OF REPRESENTATIVES KEN DETZNER, et al., 422 The Capitol Defendants. Tallahassee, FL 32399 ______

VOLUME REPRESENTING SECRETARY OF STATE: VIDEOTAPED (by telephone) DEPOSITION OF: FRANK TERRAFERMA ASHLEY DAVIS, ESQUIRE [email protected] TAKEN AT INSTANCE OF: The Defendants FLORIDA DEPARTMENT OF STATE DATE: June 11, 2013 500 S. Bronough Street Tallahassee, FL 32399 TIME: Commenced at 9:00 a.m. (by telephone) Concluded at 6:17 p.m. MICHAEL MAIDA, ESQUIRE LOCATION: 2894 Remington Green Lane [email protected] Tallahassee, Florida PO Box 12093 REPORTED BY: SANDRA L. NARGIZ Tallahassee, FL 32317 Certified Realtime Reporter 850.425.8124 Certificate of Merit Holder [email protected] (by telephone) VIDEOGRAPHER: DOUGLAS H. NARGIZ ELIZABETH FROST, ESQUIRE

2 4 APPEARANCES: 1 Third Renotice of Taking Video 14 REPRESENTING PLAINTIFF: Deposition Duces Tecum DAVID B. KING, ESQUIRE [email protected] 2 E-mail chain 35 THOMAS A. ZEHNDER, ESQUIRE [email protected] 3 7-11-11 Terraferma e-mail to Diez 78 KING BLACKWELL ZEHNDER WERMUTH 25 East Pine Street 4 7-11-11 Terraferma e-mail to Wild 80 Orlando, FL 32801 407.422.2472 5 7-11-11 Terraferma e-mail to Hofeller 81 REPRESENTING DEPONENT: DANIEL C. BROWN, ESQUIRE [email protected] 6 7-11-11 Terraferma e-mail to Diez 86 CARLTON FIELDS 215 S. Monroe Street 7 7-26-11 Terraferma e-mail to Heffley 89 Tallahassee, FL 32301 850.224.1585 8 7-27-11 Terraferma e-mail to Heffley 95 DAVID HEALEY, ESQUIRE 9 7-27-11 Terraferma e-mail to Heffley 98 [email protected] 2846B Remington Green Circle 10 Tallahassee, FL 32308 7-27-11 Terraferma e-mail to Heffley 105 850.222.5400 11 7-28-11 Heffley e-mail to Terraferma 108 REPRESENTING FLORIDA SENATE: 12 7-31-11 Terraferma e-mail to Heffley 119 RAOUL G. CANTERO, ESQUIRE [email protected] 13 E-mail chain 124 WHITE & CASE 200 S. Biscayne Blvd., #4900 14 E-mail chain 129 Miami, FL 33131 305.995.5290 CERTIFICATE OF OATH 132 CERTIFICATE OF REPORTER 133 ERRATA SHEET 134

1 (Pages 1 to 4) WWW.USLEGALSUPPORT.COM 954-463-2933 5 7 1 STIPULATIONS 1 sir? 2 The following VIDEOTAPED deposition of FRANK 2 A 420 East Jefferson Street, Tallahassee, 3 TERRAFERMA was taken on oral examination, pursuant to 3 Florida 32301. 4 notice, for purposes of discovery, and for use as 4 Q And what business is located there? 5 evidence, and for other uses and purposes as may be 5 A The Republican Party of Florida. 6 permitted by the applicable and governing rules. 6 Q By whom are you employed? 7 Reading and signing is not waived. 7 A By the Republican Party of Florida, yes. 8 * * * 8 Q What is your position? 9 9 A My position is director of House campaigns. 10 THE VIDEOGRAPHER: We are now on the record. 10 Q And how long have you been employed by the 11 This is the start of tape number 1. It is 11 Republican Party of Florida? 12 9:07 a.m. 12 A In this iteration, since January of 2011. 13 THE COURT REPORTER: This is the videotaped 13 Q So you have been employed by the Republican 14 deposition of Frank Terraferma taken in 14 Party of Florida continuously since January 2011? 15 Tallahassee, Florida on June 11, 2013 in the case 15 A Yes. 16 styled Rene Romo, et al., plaintiffs, versus Ken 16 Q And prior to that who did you work for? 17 Detzner and Pam Bondi, defendants, The League of 17 A Prior to that, I was a consultant, a 18 Women Voters of Florida, et al., plaintiffs, versus 18 self-employed consultant. 19 Ken Detzner, et al., defendants, filed in the 19 Q And how long were you a self-employed 20 Circuit Court, Second Judicial Circuit, Case 20 consultant, Mr. Terraferma? 21 Numbers 2012-CA-00412 and 2012-CA-00490. 21 A From, I think 2006 through December 2011. I 22 The court reporter is Sandi Nargiz; the 22 think it was like September 2006 through January or 23 videographer is Doug Nargiz. 23 December 2011. 24 Would you raise your right hand, please. 24 Q And before that, who did you work for? 25 Do you swear or affirm that the testimony you 25 A Before that I worked for the Florida House of 6 8 1 are about to give will be the truth, the whole 1 Representatives. 2 truth, and nothing but the truth? 2 Q In what capacity? 3 THE WITNESS: Yes. 3 A I was the director of the House Majority 4 THE COURT REPORTER: Would counsel please 4 Office. 5 identify yourselves. 5 Q And during what period of time did you hold 6 MR. KING: Bruce King and Tom Zehnder 6 that position? 7 representing the plaintiff, League of Women Voters. 7 A I held that position approximately from 8 MR. MEROS: George Meros, representing the 8 November 2004 through about September 2006. 9 Florida House of Representatives. 9 Q And the House Majority, was the Republicans 10 MR. CANTERO: Raoul Cantero representing the 10 the majority at that time? 11 Florida Senate. 11 A Yes, sir. 12 MR. BROWN: Daniel Brown representing the 12 Q And who did you specifically work for in that 13 witness, Mr. Terraferma. 13 position? 14 MR. HEALEY: David Healey representing the 14 A The Majority Leader. 15 witness as well. 15 Q Who was that? 16 Thereupon, 16 A Andy Gardner. 17 FRANK TERRAFERMA 17 Q And before you worked for the House of 18 was called as a witness, having been first duly sworn, 18 Representatives who did you work for? 19 was examined and testified as follows: 19 A Prior to that I worked for the Republican 20 20 Party of Florida. 21 DIRECT EXAMINATION 21 Q And what, during what period of time did you 22 BY MR. KING: 22 work for the Republican Party of Florida during that 23 Q Okay. Would you please state your name, sir. 23 time phase? 24 A Yes, my name is Frank Terraferma. 24 A I believe I -- let me see, that was out of 25 Q Okay. What is your business address, please, 25 college, so that would be -- I think it was January of 2 (Pages 5 to 8) WWW.USLEGALSUPPORT.COM 954-463-2933 9 11 1 1994, beginning, and then ending in November 2004. 1 been Mike Grissom the entire time? 2 Q So you worked for the Republican Party of 2 A I believe that it was on my -- I am not -- I 3 Florida for eight -- for ten years during that 3 believe so. No, actually it wasn't. I apologize. I 4 particular period? 4 think it started out with Andy Palmer. I think. Hold 5 A I think eleven. 5 on for a moment. Let me think. Yeah, I think it 6 Q Eleven years? 6 started out with Andy Palmer and then at some point Mike 7 A Uh-huh. 7 Grissom became executive director. 8 Q What positions did you hold then? 8 Q So that person, the executive director, would 9 A My position, first I was kind of like a 9 be your boss; is that right? 10 deputy -- you know, deputy political person. I think 10 A They're -- like I said previously, they are 11 they called it House liaison. And then I at some point 11 one of the people that I report to. 12 in that duration was the director of House campaigns. 12 Q Okay. So let's make sure, I just want to make 13 Q Who did you report to during the ten years you 13 sure I understand that line of reporting. On the one 14 worked for the Republican Party of Florida from '94 to 14 hand you've got Andy Palmer, later Mike Grissom, the 15 2004? 15 executive director, you work for them, right? 16 A During that period of time, that would change, 16 A Yes. 17 you know, during that period of time. There were 17 Q Does somebody else have the right to give you 18 different folks. 18 instructions and tell you what to do as well? 19 Q When you were director of the House campaigns 19 A I mean, the speaker-designate certainly is a 20 did your superior change during that time? 20 person that is involved with the party and I work for 21 A Yes. 21 them as well. 22 Q Can you tell me the names of some of the 22 Q And so the speaker-designate during this 23 people you reported to? 23 period of time from January 2011 to the present was Will 24 A Sure. Well, in my duty, you know, I am 24 Weatherford? 25 employed by the Republican party, so I would report to 25 A Yes. 10 12 1 the executive director, whoever that would be, at any 1 Q And did Will Weatherford also play a role in 2 time period. And then also the chairman of the party is 2 redistricting? 3 certainly the head of the entire Republican party whom I 3 A I believe he was the chairman of the 4 was employed by. And also as director of House 4 redistricting committee. 5 campaigns, I worked with speaker-designates of the 5 Q So I want to make sure I understand. So the 6 House. 6 two people during the period of time, January 2011 to 7 Q All right. And from January 2011 to the 7 the present, that you take orders from are Andy Palmer; 8 present, who have you reported to during that period of 8 Mike Grissom, the executive director; and Will 9 time? 9 Weatherford, the speaker-designate; is that right? 10 A In January of '11, it would have been, the 10 A That's correct. 11 executive director was Mike Grissom; the chairman was 11 Q Have you ever given a deposition before, 12 Dave Bittner, who deceased during this period, and then 12 Mr. Terraferma? 13 Lenny Curry became the chairman of the party. And then 13 A I believe that I have a long, long time ago. 14 Speaker-designate Will Weatherford. 14 Q How old are you? 15 Q Will Weatherford is chairman of the party now? 15 A I am -- 16 A No, sir. He was the speaker-designate during 16 Q The questions are going to get harder. 17 the period that you referenced in 2011. 17 A Yeah, I know. Sometimes when you get older 18 Q And did you report to him? 18 you start to forget. I think I am 42. 42. 19 A As I stated previously, that would be one of 19 Q And so you gave a deposition a long time ago, 20 the persons that I would report to. 20 you think? 21 Q Who did -- did you take instructions from all 21 A That's my recollection. 22 of those people? 22 Q What kind of a case was that? 23 A Yes. I mean to a lesser extent the chairman 23 A A candidate, I think, a Democrat candidate 24 of the party, but yes. 24 sued the Republican party. 25 Q Okay. So the executive director, has that 25 Q And is that the only time you have given a 3 (Pages 9 to 12) WWW.USLEGALSUPPORT.COM 954-463-2933 13 15 1 deposition before? 1 A Yes. I mean, I was preparing these documents 2 A I believe so. 2 as part of the first subpoena that I received myself. 3 Q Okay. As I ask these questions to you, if you 3 Q Okay. And did you pull together all the 4 don't understand a question I ask, will you tell me so I 4 documents, sir, that are called for here? 5 can rephrase it and put it to you in a way that you do 5 A I believe that I did. 6 understand it? 6 Q And do you recall how many pages of documents 7 A Yes. 7 that was? 8 Q And if you answer the question, I am going to 8 A No. 9 assume you understand it, is that fair? 9 Q Were they Bates stamped? Were the pages 10 A Yes. 10 numbered? 11 Q Also, it's important for us not to talk over 11 A The documents that I acquired or searched for 12 each other. You have been doing a good job of waiting 12 for this production, I gave them to my attorney. 13 until I finish my question to begin your answer. So 13 Q Were all of the documents produced to us prior 14 will you try to do that? Will you wait to let me get my 14 to the deposition? 15 question out before you start your answer? 15 A As far as I understand. 16 A Most definitely. 16 Q So your understanding is that all -- nothing 17 Q It helps the court reporter a lot because she 17 was withheld? 18 can't take us both down at once. It's also important 18 A It's my understanding that the documents that 19 for you to give audible answers, okay? 19 are covered in this subpoena have been produced. 20 A Okay. I have something I would like to 20 Q And so to your knowledge, no documents have 21 interject. 21 been withheld? 22 Q Sure. 22 A No. 23 A I have a very short attention span. So if 23 Q So all documents in your possession regarding 24 your questions tend to be long in nature, I probably 24 Congressional redistricting in Florida in 2012 have been 25 will have to ask you to repeat them multiple times. I 25 produced; is that correct? 14 16 1 just thought you would want to know that. 1 A My testimony is that the documents that I 2 Q I appreciate that. I will do my best to make 2 obtained as part of this subpoena, I presented them to 3 my questions pithy and sharp so you don't have a problem 3 my attorney whom I believe made the production on my 4 with that. 4 behalf. 5 A Very well. 5 Q Okay. And as far as paragraph 2 there, 6 (Exhibit No. 1 was marked for 6 Congressional redistricting maps, whole or partial, 7 identification.) 7 completed or draft, that were submitted or discussed 8 BY MR. KING: 8 with any legislator, legislative staff member, or any 9 Q I show you Exhibit 1, sir, which purports to 9 legislative committee, were all those produced, sir? 10 be the Third Renotice of Taking Video Deposition Duces 10 A That's my belief. 11 Tecum of one Frank Terraferma. 11 Q And Congressional redistricting maps that were 12 Do you remember seeing this document? 12 submitted to or discussed with any person with the 13 A No. 13 intent that that person would convey it to any 14 Q Okay. The reason I am going to ask you about 14 legislator, legislative staff member, or legislative 15 this document, Mr. Terraferma, is it also requires that 15 committee, submitted to or considered or passed by the 16 you produce certain documents for the deposition. And 16 Florida Legislature, were those all produced, sir? 17 look at page 7 to see the documents that are called on 17 A I produced every Congressional map that I 18 to be produced. You see that? 18 could find in my possession. 19 A Yes. 19 Q Okay. Do you remember how many that was? 20 Q Have you seen that part of the exhibit? 20 A I do not remember. 21 A I have not seen this document, this third 21 Q Was it multiple? 22 document that's presented in front of me. 22 A Several. 23 Q All right. Has anybody ever told you that you 23 Q More than ten? 24 needed to accumulate the documents that are listed on 24 A I am not sure of the exact number. You have 25 paragraph 7? I mean page 7. 25 them all. 4 (Pages 13 to 16) WWW.USLEGALSUPPORT.COM 954-463-2933 17 19 1 Q Okay. Any communication -- number 3: Any 1 Party of Florida. I am not really sure that I had a 2 communication with any person about the subjects 2 role. Maybe you have a more specific question. 3 described in 1 or 2 above. 3 Q Did you have any official duties related to 4 Did you produce all of those communications, 4 redistricting in the 2000 cycle from the Republican 5 sir? 5 Party of Florida? 6 A All the documents that I would produce in 6 A I don't recall having official duties for the 7 relationship to the subpoena I presented to my attorney 7 party. 8 and my attorney made the production for me. 8 Q Did you draw maps back in 2000 to 2002? 9 Q Okay. And number 4, any knowledge that you 9 A I am sure I did. 10 have about the method or process by which the 2012 10 Q Okay. And why did you draw maps then? 11 Florida redistricting maps were drawn, all documents 11 A Just out of interest. 12 that related to that knowledge were produced, to your 12 Q What do you mean out of interest? 13 knowledge? 13 A Out of personal interest, I drew maps back 14 A As I stated previously, the documents that I 14 then, that's what I meant. 15 was able to obtain that I searched for that I found, I 15 Q Did you submit those maps to anybody back in 16 presented them to my attorney and my attorney made the 16 the 2000-2002 time phase? 17 production on my behalf. 17 A I don't recall for sure. You know, I believe 18 Q Okay. And you produced all documents that you 18 that, you know, I did have contact with some legislators 19 have any knowledge about where the person who was 19 in the 2002 redistricting, but I don't recall if any 20 involved in any way in drafting the map or district that 20 maps that I drew were submitted or vice versa or 21 was submitted to any legislature, legislator or 21 whatever. 22 legislative staff member, or any legislative committee, 22 Q Did you learn how to draw maps back in 23 any document that had knowledge about that process, you 23 2000-2002? Was that the first time you had drawn 24 produced? 24 maps -- 25 A That's my belief, my belief is that I produced 25 A Yes. 18 20 1 that to my attorney. 1 Q -- for redistricting? 2 Q Did you search the documents yourself, sir? 2 A Yes. 3 A I did search them myself. 3 Q Did you use computer software back then? 4 Q And what did you search? 4 A Yes. 5 A I searched my e-mail and I searched my 5 Q Okay. Do you remember what computer software 6 computer, and I searched my home computer and my office. 6 you used then? 7 Q Okay. So you had a home computer, an office 7 A It's called Maptitude. 8 computer, and one or more e-mail addresses? 8 Q So you used Maptitude in 2000-2002 and again 9 A Yes. 9 during this latest redistricting cycle? 10 Q How many e-mail addresses? 10 A This recent redistricting cycle I also had 11 A I have two e-mail addresses. 11 Maptitude. 12 Q You have one e-mail address at work, the 12 Q And did you own the Maptitude license yourself 13 Republican Party of Florida? 13 personally? 14 A I have two at the Republican Party of Florida. 14 A No. 15 Q Two at the Republican. Then do you have one 15 Q Who owned the Maptitude license? 16 at home or a separate -- 16 A The Republican Party of Florida purchased that 17 A I have -- I am sorry, did you want to finish? 17 license, I believe. 18 Q Did you have a personal e-mail account as 18 Q Did they purchase that license for you back in 19 well? 19 2000-2002? 20 A Yes. 20 A Yes. 21 Q And you searched them all? 21 Q That's like a license that costs 5-, $10,000 a 22 A Yes. 22 user, isn't it? 23 Q Okay. What role did you play in redistricting 23 A I am not sure. 24 in 2002, Mr. Terraferma, or in the 2000-2002 cycle? 24 Q It's an expensive license, isn't it? 25 A I was in a -- I was working at the Republican 25 A I don't know how much it costs. 5 (Pages 17 to 20) WWW.USLEGALSUPPORT.COM 954-463-2933 21 23 1 Q Okay. Who would have made a decision to 1 A My job is to assist legislators and if that 2 provide you with Maptitude? 2 was one of the things they asked me about at that time, 3 A If I would have requested it, the party, if 3 then I would have tried to help them if I was able to. 4 they approved the request, would pay for it. 4 Q Right. And, of course, these would be 5 Q All right. So they approved a request so you 5 Republican legislators, right? 6 could do maps for your own personal interest? 6 A Yes. 7 A Yes. 7 Q You would be supplying information about the 8 Q Okay. So that's just one of the perqs of 8 maps to Republican legislators, right? 9 working for the Republican party, they supply you with 9 A If -- I don't have just -- I did multiple 10 Maptitude? 10 things. Specifically about maps, if they asked me about 11 A You are talking about -- 11 a map and I was able to help them, then I am sure I 12 Q In 2000-2002? 12 would have helped them in the way, the best that I could 13 A In 2000-2002? 13 have. 14 Q Right. 14 Q Okay. Now, in 2011, when you went back to 15 A Okay. So your question is? 15 work at the Republican Party of Florida, who hired you? 16 Q My question was: That was just a perq that 16 A Well, I was jointly hired by the executive 17 you were provided back in 2002, the right to use the 17 director or the chairman of the party upon the 18 license for Maptitude? 18 recommendation of speaker-designate Weatherford. 19 A As I stated previously, I not only drew for 19 Q So it was your understanding that Will 20 personal interest, but I stated that legislators had 20 Weatherford had recommended to the Republican Party of 21 asked me to draw things for them from time to time. 21 Florida that you be hired as a full-time permanent 22 Q Okay. So there was a business interest 22 employee? 23 involved back in 2000-2002 as you drew maps? 23 A That's my understanding. 24 A I am not -- that's your clarification, your 24 Q Okay. And did you talk to speaker-designate 25 classification. I don't know if I would necessarily 25 Will Weatherford about that? 22 24 1 call it that, but I mean those are your words. 1 A I am sure that we did. 2 Q Well, wasn't it part of your job to be able to 2 Q And had you worked for Will Weatherford during 3 supply information to the legislators about the maps 3 the time you were a self-employed consultant from 2006 4 back in 2000-2002? 4 to 2011? 5 A It wasn't anything in a written job 5 A Yes. 6 description that I have. 6 Q And what was your job for him during that 7 Q Do you have a written job description? 7 period of time? 8 A No. 8 A I helped him on his election and reelection 9 Q Okay. So then whether it was in a written job 9 campaigns. 10 description or not wouldn't make any difference, right? 10 Q How many campaigns did you work for him on? 11 MR. BROWN: Objection, argumentative. Go 11 A Well, let me see, it would have been the 2006 12 ahead and answer. 12 campaign, and the 2008 campaign, and I think he was 13 THE WITNESS: I am not sure what the question 13 unopposed in 2010. 14 is. 14 Q When you were working as a self-employed 15 BY MR. KING: 15 consultant, did you have an entity, a name of your 16 Q You just told me that responsibility to draw 16 business that you worked with, for? 17 maps wasn't in a written job description for you, right? 17 A Yes. 18 A That's what I stated, yes. 18 Q What was the name of that company? 19 Q But then you also told me you don't have a 19 A I had two companies that I did work under. 20 written job description, and you didn't back in 20 One of them was Terraferma Consulting Group. And the 21 2000-2002, right? 21 other one was Campaign Insights. 22 A That's correct. 22 Q And what was the -- what was your specialty 23 Q Okay. So would it be correct that your job 23 during that period of time from 2006 to 2011? What did 24 was to assist the legislators when they asked you 24 you hold yourself out as being specialized in doing? 25 questions about maps? 25 A I considered myself to be a general 6 (Pages 21 to 24) WWW.USLEGALSUPPORT.COM 954-463-2933 25 27 1 consultant. So I don't recollect that I advertised 1 (The requested portion was read.) 2 myself as having any specialty. 2 BY MR. KING: 3 Q All right. As a general consultant, how did 3 Q Let me rephrase it. 4 you describe what you did for folks? 4 You have, over the past two years, played a 5 A I helped them execute their campaign strategy. 5 role in the redistricting cycle, have you not? 6 Q Anything else? 6 MR. MEROS: Same objection, leading. Go 7 A Nothing else comes to mind. 7 ahead. 8 Q So really what you were doing was working for 8 THE WITNESS: I am sorry, now I need to have 9 potential candidates who were getting elected to the 9 the question repeated again. 10 House or the Senate or Congress, or what types of 10 BY MR. KING: 11 campaigns did you involve yourself with? 11 Q You played a role in redistricting in 2011 and 12 A I think almost exclusively State House. 12 2012; isn't that correct? 13 Q And you recall the names besides Will 13 MR. MEROS: Same objection. Go ahead. 14 Weatherford of some of your clients during that period 14 THE WITNESS: Can you rephrase the question or 15 of time that you worked on campaigns for? 15 ask it in a more specific way? 16 A Yes, I am sure I can recall some of them. 16 BY MR. KING: 17 Representative Steve Precourt would be one of 17 Q That doesn't help you, whether you played a 18 the persons that I assisted, Representative Will Snyder, 18 role in redistricting? That doesn't mean anything to 19 Representative Doug Holder. I am sure I am leaving out 19 you? 20 some. Representative Ben Albritton, Representative Liz 20 A It just seems like a broad question, but I 21 Porter, Representative Tom Goodson. I think that's all 21 mean, on behalf of the Republican party, I work to get 22 I could recall at this moment. 22 people to come to the hearings. I don't know how you 23 Q Where were your offices located? 23 would classify that as a role. That's why I struggled 24 A While I was an independent consultant? 24 with your question a bit. 25 Q Yes. 25 Q Well, Speaker-designate Weatherford played a 26 28 1 A I had, I think, several locations. Do you 1 role in redistricting, didn't he? 2 want to know the street address? 2 A The only role that I know that he played is he 3 Q Just give me the towns. 3 was chairman of the committee. I don't know if that's a 4 A All of it is in Tallahassee. 4 role. That's a position. 5 Q Now, when you were employed in 2011, in 5 Q Well, that's a pretty -- he had a pretty 6 January, what did you understand your responsibility was 6 significant responsibility regarding redistricting, 7 going to be? 7 didn't he? 8 A My responsibility would be to assist the 8 A Presumably so. 9 efforts of House Republicans to be -- to get reelected. 9 Q Yeah. And you, of course, were taking 10 Q And you were also aware that a redistricting 10 instructions from Speaker-designate Weatherford during 11 cycle was going to be carried out in 2011 and 2012, 11 the entire time from January 2011 to the present time, 12 right? 12 right? 13 A Yes. 13 A Yes. 14 Q And what role were you going to play in that? 14 Q And did he give you responsibilities regarding 15 A I didn't know if I would play a role. 15 redistricting? 16 Q Well, you have played a role, haven't you? 16 A No. 17 MR. MEROS: Object to the form, leading. 17 Q Okay. He never asked you to draw maps? 18 BY MR. KING: 18 A No. 19 Q You can go ahead and answer. From time to 19 Q Did you discuss the maps you drew with 20 time they may object during the deposition. Once they 20 Speaker-designate Weatherford? 21 finish objecting, since there is no judge here to rule 21 A I don't recall doing that. 22 on the objections, you need to go ahead and answer the 22 Q Wouldn't you recall it if you had done it? 23 question unless your lawyer tells you not to. Okay? 23 MR. MEROS: Object to the form, leading. 24 A What's your question, please? 24 THE WITNESS: The answer to your question 25 MR. KING: Would you read it back, please? 25 is -- I mean, as you have seen in my production, I 7 (Pages 25 to 28) WWW.USLEGALSUPPORT.COM 954-463-2933 29 31 1 did draw maps. But to answer your question, I 1 A I looked at some -- an alternative that they 2 don't recall ever discussing maps that I had drawn, 2 had asked me to look for. 3 that I had discussed that with Representative 3 Q Help me understand that. You say you looked 4 Weatherford. 4 at an alternative they asked you to look at? 5 BY MR. KING: 5 A Yes. 6 Q How about with Representative Weatherford's 6 Q Did they have an alternative map? 7 staff members, did you discuss maps you drew with them? 7 A No, they asked me if I would be able to find 8 A I don't believe so. 8 something for them that -- find something that was 9 Q Okay. Did you discuss maps you drew with any 9 better compliant with Amendment 5 than what was 10 legislators or staff members? 10 currently being or at the time being discussed. 11 A I believe that I -- I believe that I did have 11 Q So you did an alternative map? 12 some discussions with some legislators from time to time 12 A I drew an alternative map just in Duval 13 on the subject of redistricting. 13 County. 14 Q And which legislators did you talk to about 14 Q Just in that section of the state? 15 redistricting? 15 A Just Duval County alone. 16 A I am sure that -- I am sure I am going to 16 Q And did you provide it to him? 17 probably inevitably leave someone out, but I recollect 17 A I am not sure. 18 having a discussion with Representative Albritton about 18 Q Well, once you drew the map, did you just file 19 redistricting; I recollect that I had a discussion with 19 it away or did you talk to Mr. Lieffers again about it? 20 a member's aide about redistricting, that would be Gary 20 A Yes. To answer your question, I recall 21 Lieffers, who is an aide for Representative Charles 21 drawing the map, but I am not -- I don't recall if he 22 McBurney, I believe I recall discussing redistricting 22 got it, if I gave it to him. I don't know if they ever 23 with him. And I don't recall right at this moment 23 received it. 24 discussing redistricting with anyone else. 24 Q Did you produce that for us in your 25 Q All right. Representative McBurney, is 25 production? 30 32 1 that -- is he a representative in the House of 1 A I produced the e-mail, yes. 2 Representatives of Florida? 2 Q Okay. And the map? 3 A He is an incumbent, he is a House, current 3 A The map, it's an attachment. It's not -- I 4 House member. 4 don't have that map. 5 Q And Gary, how do you spell Lieffers? 5 Q When you say it's an attachment but you don't 6 A Lieffers? 6 have it, what do you mean? 7 Q Lieffers. 7 A We would have to -- well, since it's in a 8 A I am not sure. 8 matter that dealt exclusively with the State House, I 9 Q Okay. What's his position? 9 don't think that we produced it because it wasn't 10 A I think he's a legislative aide. 10 compliant with the subpoena. 11 Q Okay. And what did you and Mr. Lieffers talk 11 Q Okay. 12 about? 12 A However, I think there is an e-mail. 13 A My recollection is that Mr. Lieffers had asked 13 Q About it? 14 me to take a look at the configuration in Duval County. 14 A About it that is, it is in the production. 15 They felt like what was being proposed didn't comply 15 Q Okay. All right. And what was the 16 well with Amendment 5. 16 conversation you had with Representative Albritton? 17 Q And was this the House map? 17 A My recollection is that I had just informed 18 A The State House map, yes. 18 him about a map that -- a Senate amendment that had been 19 Q And about when did that occur? 19 filed, and I just was telling him about it because I 20 A I believe it occurred in January of 2012. 20 thought he would be interested in it. 21 Q Okay. And did you look at the State House map 21 Q Help me understand that. You told him you 22 proposed then? 22 thought he would be interested in what? 23 A Yes. 23 A I saw there was an amendment filed that 24 Q And what did you do, if anything, regarding 24 affects the county that he lives in, and I thought that 25 that request? 25 he would be interested in knowing about that. 8 (Pages 29 to 32) WWW.USLEGALSUPPORT.COM 954-463-2933 33 35 1 Q And was this another House map? 1 those petitions? 2 A No. 2 A No. 3 Q What is Representative Albritton? 3 Q After the -- either before or after the vote 4 A He is a State House member. 4 on those petitions, did you play any role in litigation 5 Q Okay. And what -- the amendment pertained to 5 opposed to those petitions? 6 what? 6 A No. 7 A To the State Senate. 7 Q Do you recall going to a meeting with some 8 Q Okay. And why did you think he would be 8 other political consultants and some lawyers and some 9 interested in the amendment that pertained to the Senate 9 staffers from the legislature in early December of 2010? 10 map? 10 A No. 11 A Because his -- it's -- it affected the county 11 (Exhibit No. 2 was marked for 12 that he resides in. 12 identification.) 13 Q And how did it affect the county he resided 13 BY MR. KING: 14 in? 14 Q Let me show you, sir, Exhibit 2 from 15 A It made a change. I don't recall the specific 15 Mr. Reichelderfer's deposition, which is a series of 16 nature of the change. 16 e-mails, it's a composite exhibit of e-mails between 17 Q Was he interested in running for the Senate? 17 December 1 and December 2, I believe, of 2010, and ask 18 A I don't believe so. 18 you if you recognize those e-mails to -- which purport 19 Q Did the change in the map affect his interest 19 to have been sent from various people to you. And, in 20 in running for the Senate? 20 fact, one of the e-mails appears to have been sent from 21 A I don't believe so. 21 you. Do you recognize those? 22 Q Okay. 22 A I recognize this e-mail on Reichelderfer 16, 23 A I don't know what his interests were, but I 23 which is labeled as page 77. 24 don't -- and he wasn't a Senate candidate, but -- so I 24 Q Right. And that's an e-mail that you sent on 25 don't know. 25 December 1, 2010, to Rich Heffley, Joel Springer, Pat 34 36 1 Q What was it about the amendment that caught 1 Bainter, [email protected], Andy Palmer, Marc 2 your attention that you thought you needed to talk to 2 Reichelderfer, right? 3 Mr. Albritton about? 3 A Yes. 4 A Since I know him well, I know that he is very 4 Q Now -- but you also received the -- let's say 5 passionate about his county, Hardy County; it's a very 5 the first page of Exhibit 2, you received that e-mail 6 small county, and I just thought he would be interested 6 from Mr. Heffley, didn't you? 7 to know how the amendment was changing things in that 7 MR. MEROS: Object to the form, leading. Go 8 area. 8 ahead. 9 Q And when was the conversation with him? 9 THE WITNESS: I don't recall receiving this 10 A I don't recall the specific date. 10 e-mail, but it was sent to me. 11 Q Was it in 2011 or 2012? 11 BY MR. KING: 12 A I believe it was in 2012. 12 Q Is that your e-mail address, 13 MR. KING: Do we need to go off the record? 13 [email protected], as of December 2010? 14 THE VIDEOGRAPHER: We are now going off the 14 A Yes. 15 record. It's 9:49. 15 Q Now, I think you told me you hadn't gone to 16 (A recess took place from 9:49 a.m. to 16 work at the Republican Party of Florida until January of 17 9:55 a.m.) 17 2011; is that right? 18 THE VIDEOGRAPHER: We are back on the record 18 A That's correct. 19 and it is 9:55. 19 Q But you had an e-mail address at the 20 BY MR. KING: 20 Republican Party of Florida in December? 21 Q Mr. Terraferma, were you aware that in 2010 21 A Yes. 22 the voters of Florida approved Amendments 5 and 6 to the 22 Q How is that? 23 Constitution -- petition 5 and 6 to the Constitution? 23 A As part of being an independent consultant, I 24 A Yes. 24 also did consulting work for the Republican party, so I 25 Q All right. Did you play any role in opposing 25 had that e-mail address. 9 (Pages 33 to 36) WWW.USLEGALSUPPORT.COM 954-463-2933 37 39 1 Q What kind of consulting work had you done for 1 Q Was he your attorney while you were a 2 the Republican party between 2006 and 2011? 2 consultant? 3 A Just general consulting for the House 3 A No. I consider him to be my attorney while I 4 campaigns division. 4 am employed by the Republican Party of Florida. 5 Q So Mr. Heffley called a redistricting meeting 5 Q Okay. So when you started your employment, 6 as of December 1, 2010, correct? 6 did they tell you he was going to be your attorney? 7 A It appears that he did do that. 7 A I know that we have -- our office, the 8 Q And he indicated that they were going to have 8 Republican party has an agreement with him as -- with 9 the lawyers and staff on to brainstorm, right? 9 his law firm and I understand him to be my attorney. 10 A That's what he wrote. 10 MR. CANTERO: Who is the "he" we are talking 11 Q And he invited a bunch of people to that 11 about? 12 meeting, right, including yourself? 12 MR. KING: Mr. Ginsberg, Ben Ginsberg. 13 A He invited, yes, several folks to that 13 BY MR. KING: 14 meeting, including me. 14 Q Do you also understand him to be a fellow with 15 Q And you indicated that you would come via 15 a good deal of expertise in the area of redistricting? 16 conference call? 16 A I believe that he has a good degree of 17 A What I wrote, it should work for me via 17 expertise in redistricting law. 18 conference call. 18 Q Okay. And did you know Mr. Meros, George 19 Q And did you attend via conference call? 19 Meros? 20 A I don't think -- I don't recall. I don't 20 A I know Mr. Meros, yes. 21 think so. I just don't recollect being on such a 21 Q And how do you know Mr. Meros? 22 conference call. 22 A I have known him just from living in 23 Q Okay. Now, you knew all the people that were 23 Tallahassee and from him being a lobbyist. 24 invited to this meeting? 24 Q Has he ever been your attorney? 25 A I know those people, yes. 25 A No. 38 40 1 Q On -- if you look at the very last e-mail, you 1 Q And why did you understand he was going to be 2 see that Mr. Heffley indicates that the meeting is going 2 present at this meeting? 3 to be held in the chairman's conference room at the 3 A I didn't -- I didn't understand that, why he 4 Republican Party of Florida, right? 4 would be there. I don't know about this meeting. 5 A That's what he wrote. 5 Q And you knew Alex Kelly? 6 Q And the meeting was going to be at 10:00 a.m. 6 A I know Alex Kelly. 7 on Friday, right? 7 Q He's on -- he is a staffer for the 8 A That's what it says. 8 legislature? 9 Q And you were on that e-mail as well, right? 9 A It's my understanding that he was the staff 10 A I am not on -- yes, I am on this last one. 10 director of the redistricting committee. 11 Yes, I am on there. 11 Q So he worked under Will Weatherford as well as 12 Q And he indicated the expected participants 12 you, right? 13 included Ben Ginsberg, right? 13 A In completely different capacities. 14 A Yes. 14 Q Right. So you knew Mr. Kelly well, didn't 15 Q Did you know who he was? 15 you? 16 A I know Mr. Ginsberg. 16 A I wouldn't say I know him well. 17 Q And who is he? 17 Q Have you gone to meetings with him in the 18 A He is an attorney for the Republican Party of 18 past? 19 Florida and my attorney. 19 A I don't think so. 20 Q Okay. 20 Q You never attended a meeting with Mr. Kelly? 21 A As well. 21 A I don't recall such a meeting. 22 Q All right. And how long has he been your 22 Q Have you ever called him on the telephone, 23 attorney? 23 talked to him? 24 A He's been my attorney for a long time. I 24 A I think I did one time. 25 can't remember how long that he has been. 25 Q Okay. One time you called Mr. Kelly? 10 (Pages 37 to 40) WWW.USLEGALSUPPORT.COM 954-463-2933 41 43 1 A Yes. 1 Q So did Senator Gaetz play a role in 2 Q Okay. 2 redistricting? 3 A That's my recollection. 3 A I presume that he did. He was the -- I think 4 Q Did you know Mr. Bardos? 4 he was the chairman of the committee. 5 A Not really, no. 5 Q Okay. And so Chris Clark happened to work for 6 Q Did you know who he was? 6 the chairman of the committee on redistricting in the 7 A I know who he is today. Back then, I don't 7 Senate, correct? 8 think I would have known of him. 8 A I am not -- I don't know Chris Clark well. I 9 Q How about Joel Springer? 9 mean, I once worked with him a long time ago. I didn't 10 A Yes, I know him. 10 know at this time what job he had or who he worked for. 11 Q He works with you? 11 Q Okay. And Andy Palmer, did you know him? 12 A Yes. 12 A I know Andy Palmer, yes. 13 Q At the Republican Party of Florida? 13 Q Who is Andy Palmer? 14 A Yes, he works at the Republican party. 14 A I believe he was the executive director of the 15 Q Was he a full-time employee of the Republican 15 Republican party at this time. 16 Party of Florida as of December 2, 2010? 16 Q And Mr. Reichelderfer, did you know him? 17 A I believe so. 17 A Yes, I know Marc Reichelderfer. 18 Q Has he continued to be up until the present 18 Q How did you know him? 19 time? 19 A He is a consultant here in Tallahassee. 20 A That's my -- yes. Yes. 20 Q A political consultant? 21 Q What is Mr. Springer's responsibility? 21 A Yes. 22 A He is the director of Senate campaigns. 22 Q A Republican political consultant? 23 Q So he was the director of Senate campaigns and 23 A Yes. 24 you were about to become the director of House 24 Q Okay. And had you worked with him before? 25 campaigns; is that right? 25 A Some. 42 44 1 A Yes. 1 Q In what way? 2 Q And Mr. Pat Bainter, did you know him? 2 A My recollection is that as the director of 3 A I know Pat Bainter. 3 House campaigns, he is a consultant, so some of his 4 Q And how did you know him? 4 clients were clients in the general election that we 5 A He is a political consultant. 5 worked, that the party assisted the client -- the 6 Q Had you worked with him before? 6 candidate, which in many -- in some instances were Marc 7 A Not too much. 7 Reichelderfer's clients. 8 Q That means you worked with him some? 8 Q One of Marc Reichelderfer's clients was Dean 9 A A little bit. 9 Cannon, right? 10 Q How did you work with him before? 10 A I believe so, yeah, I believe that he was. 11 A Just if he was working on a candidate's race, 11 Q That would be a pretty significant client for 12 we might have worked on the same race, but I can't even 12 Mr. Reichelderfer, wasn't it? 13 hardly think of times where we have worked on races 13 MR. MEROS: Object to the form, leading. 14 together; but I am sure there were a few instances. 14 THE WITNESS: What's your question? 15 Q And Chris Clark, who did you understand he 15 BY MR. KING: 16 was? 16 Q I said Dean Cannon was a significant client 17 A I know Chris Clark. 17 for Mr. Reichelderfer? 18 Q How do you know Chris Clark? 18 MR. MEROS: Reichelderfer, and object -- 19 A I have known him since he was employed at the 19 MR. KING: I appreciate that. Every once in a 20 Republican party many years ago. 20 while I slip a little bit, but I know that when I 21 Q Okay. And he played a role in redistricting 21 do, I know you will be there to correct me. So 22 in 2011-2012, didn't he? 22 that's a comforting thing to me. 23 A I am not aware of any role that he played. 23 BY MR. KING: 24 Q Didn't he work for Senator Gaetz? 24 Q So you understood that Mr. Reichelderfer was a 25 A I am not sure. 25 very well connected Republican political consultant at 11 (Pages 41 to 44) WWW.USLEGALSUPPORT.COM 954-463-2933 45 47 1 the time of this meeting, correct? 1 BY MR. KING: 2 A I know that Mr. Reichelderfer is a Republican 2 Q And you had had a long connection with 3 consultant. Those would be your words, to characterize 3 Mr. Heffley, correct? 4 him as, I think you said well connected or something. I 4 A I have been acquainted with him for a long 5 don't know. 5 time. 6 Q You wouldn't characterize him that way? 6 Q All right. And you had worked with him over 7 A That's not my characterization. 7 the period from '94 at various times until 2010? 8 Q What would be your characterization? 8 A I mean, I think he, when he worked for the 9 A That he is a Republican consultant. 9 State of Florida, I wasn't working with him at that 10 Q Okay. And Mr. Heffley, did you know 10 time. I mean, then I think it's points beyond when he 11 Mr. Heffley? 11 got back into political life in terms of campaigning, 12 A Yes, I know Mr. Heffley. 12 then I am sure we reconnected, if you will. 13 Q How did you know Mr. Heffley? 13 Q And so what did you understand the purpose of 14 A I have known Mr. Heffley since he employed me 14 this meeting was going to be regarding redistricting? 15 back in 1994. 15 A (Examining document.) It says that they are 16 Q So he was the fellow that employed you at the 16 going to brainstorm. 17 Republican party back in 1994? 17 Q Okay. And what did you understand they were 18 A Yes. 18 going to be brainstorming about? 19 Q Okay. And so you had worked for him. How 19 A Presumably that they are going to brainstorm 20 long did you work for him then? 20 about redistricting. 21 A Well, I think he left around 1996. Only like 21 THE VIDEOGRAPHER: This is the end of tape 22 two years maybe. 22 number 1. We are now going off the record. It is 23 Q But you worked for him directly for a couple 23 10:15 a.m. 24 of years? 24 (A recess took place from 10:15 a.m. to 25 A Actually -- no, I think, actually, I think he 25 10:17 a.m.) 46 48 1 actually left after just one year. 1 THE VIDEOGRAPHER: We are back on the record. 2 Q Okay. And -- but did you also know him to be 2 This is the start of tape number 2 and it's 3 a lobbyist and political operative in Tallahassee? 3 10:17 a.m. 4 A He is a lobbyist and a consultant. 4 BY MR. KING: 5 Q Okay. 5 Q Now, Mr. Terraferma, you, on receiving the 6 THE VIDEOGRAPHER: We have three minutes left 6 invitation to the meeting, said you would attempt to be 7 on this tape. 7 present, right, or attempt to appear by conference call? 8 BY MR. KING: 8 A Yes. The word I used was it should work for 9 Q Okay. Was Mr. Heffley the leader of one of 9 me. 10 the top GOP oriented firms in Tallahassee in 2010? 10 Q And is it your testimony, sir, that the only 11 A What kind of firm? 11 thing you knew about this meeting was there was going to 12 Q Consulting firm. 12 be brainstorming about redistricting? 13 A I am not sure if it's considered a top firm or 13 A I don't think I attended this meeting. I 14 not. 14 don't know anything about this meeting other than what's 15 Q Okay. Mr. Heffley would be disappointed to 15 in front of me on paper. 16 hear that, don't you think? 16 Q You knew that at the time the redistricting 17 MR. MEROS: Object to the form, argumentative. 17 was going to occur in 2011 and 2012, right? 18 BY MR. KING: 18 A Yes. 19 Q So, at any rate, you knew that Mr. Heffley was 19 Q And you knew that there was going to be new 20 a very well connected Republican political consultant, 20 requirements that were going to be have to be dealt with 21 correct? 21 in redistricting, right? 22 MR. MEROS: Object to the form, leading. 22 A Yes. 23 THE WITNESS: I know Mr. Heffley is a lobbyist 23 Q Because of the amendment adopted by the voters 24 and a consultant. 24 of the state of Florida, there were new rules that had 25 25 to be considered in redistricting, right? 12 (Pages 45 to 48) WWW.USLEGALSUPPORT.COM 954-463-2933 49 51 1 A Can you rephrase your question? 1 would be implemented as it relates to mapping. We 2 Q You understood that -- you understood as of 2 had discussions. 3 December 1, 2010, that there were new rules that were 3 BY MR. KING: 4 going to have to be considered in the next redistricting 4 Q And did you get a report? If you say you 5 process, correct? 5 didn't attend this meeting or participate, did you get a 6 A Yes. 6 report from any of the participants about what was 7 Q You knew that back in 2002 it was okay from a 7 discussed? 8 political standpoint to gerrymand in drawing districts; 8 A No, I have no recollection of this meeting. 9 isn't that correct, sir? 9 So I mean, no. I mean, no one told me -- I don't recall 10 MR. MEROS: Object to the form, leading, 10 this meeting, I don't recall this e-mail, so nobody 11 mischaracterization. Go ahead. 11 reported back to me about this meeting that I recall. 12 THE WITNESS: Back in 2002, there weren't the 12 Q I mean, at the time you worked pretty closely 13 same rules in -- that there were in 2012. 13 with Mr. Springer, didn't you? 14 BY MR. KING: 14 A Not at this time, no. 15 Q Right. And you understood in 2010 you were 15 Q Within a month you had gone to work full-time 16 going to be facing an election cycle -- I mean a 16 at the Republican Party of Florida? 17 redistricting cycle where the districts could not be 17 A This preceded me returning to working at the 18 drawn to favor a political party or an incumbent, right? 18 Republican party. 19 A Yes, they could not be drawn to favor or 19 Q Right. But I said within a month after that, 20 disfavor an incumbent or a party, among the various 20 you had gone to work at the Republican Party of Florida, 21 provisions. 21 right? 22 Q Right. And they were supposed to be compact 22 A Yes. 23 and contiguous, you were aware of that as well? 23 Q And you were working for Mr. Palmer? 24 A Yes. 24 A He was the executive director. 25 Q And be of equal number of people in each 25 Q Right, and working with Mr. Springer? 50 52 1 district, correct? 1 A We were coworkers; we don't share the same 2 A Yes. 2 work. 3 Q And there were some provisions that pertained 3 Q Right. But you had an equal interest in 4 to minority districts, right? 4 redistricting, didn't you, sir? 5 A Yes. 5 A We wanted to see the redistricting be 6 Q And so isn't it correct that you had been in 6 successful for the state of Florida. 7 discussions with your fellow political consultants about 7 Q You wanted to see it be successful for the 8 how the Republican party was going to deal with these 8 Republican Party of Florida, didn't you? 9 new strictures on redistricting; isn't that correct, 9 MR. CANTERO: Object to the form. 10 sir? 10 THE WITNESS: No. 11 A Like I mentioned to you before, I don't 11 BY MR. KING: 12 believe I was at this meeting, so I am not sure how to 12 Q That was not a goal of yours at the time you 13 answer your question because I don't know what was 13 went to work for the Republican Party of Florida, sir? 14 discussed at that meeting. 14 MR. MEROS: Object to the form, asked and 15 Q The question is not limited to the meeting. 15 answered. Go ahead. 16 The question is: As of this time frame, you had been 16 THE WITNESS: What's your question? 17 discussing with these fellow consultants, people like 17 BY MR. KING: 18 Mr. Heffley and Mr. Bainter and Mr. Reichelderfer, about 18 Q The question is: Wasn't it your goal for the 19 how you were going to be dealing with redistricting in 19 redistricting to be successful for the Republican Party 20 2011 and 12, correct? 20 of Florida? 21 MR. CANTERO: Object to the form. 21 MR. CANTERO: Object to the form. 22 MR. BROWN: You can answer him. 22 THE WITNESS: My personal hope was that the 23 THE WITNESS: I recall having discussions 23 redistrict -- that the legislature would pass a 24 about how Amendments 5 and 6 would work, how they 24 redistricting plan that would be legally 25 would be implemented, how they would -- how they 25 sufficient, that we could have orderly elections, 13 (Pages 49 to 52) WWW.USLEGALSUPPORT.COM 954-463-2933 53 55 1 and that that, you know, that things would move on 1 people all worked against Amendment 5 and 6. 2 from that. 2 Now, specific to your newest question, do I 3 BY MR. KING: 3 know or did I know Pat Bainter and Rich Heffley worked 4 Q Wasn't it your personal goal that the 4 on a campaign against Amendments 5 and 6? Yes, the 5 legislature would pass a redistricting plan that would 5 answer to your question to that question is yes, I knew 6 retain as many of the elements of the status quo as 6 that. 7 possible at that time? 7 Q Okay. And how about Mr. Springer and 8 A That was not my aspiration. 8 Mr. Gardner? 9 Q Wasn't it your goal that the new redistricting 9 A Mr. who? 10 plans adopted by the legislature perform in a way that 10 Q I am sorry, Mr. Springer and Mr. Palmer. 11 would perform well for Republican candidates? 11 A I am not aware of what those two gentlemen did 12 MR. MEROS: Object to the form, leading. Go 12 regarding the campaign against Amendments 5 and 6. 13 ahead. 13 Q Okay. You are aware that the House, the 14 THE WITNESS: My hope -- my goal -- my hope, 14 legislature, the House under Dean Cannon filed a lawsuit 15 if you will, was that the legislature would pass a 15 to declare the Fair District amendments 16 plan that was legally sufficient to pass the 16 unconstitutional, right? 17 Florida Supreme Court and pass the Federal Justice 17 A I am aware of that from reading it in the 18 Department. 18 newspaper. 19 BY MR. KING: 19 Q Okay. You had never talked to 20 Q And elect as many Republicans as possible, 20 Speaker-designate Will Weatherford about that? 21 right? 21 A I don't recollect us discussing that. 22 MR. MEROS: Object to the form. Asked and 22 Q And once you went to work at the Republican 23 answered. Leading. Go ahead. 23 Party of Florida, what did you understand your 24 MR. BROWN: Go ahead now. 24 relationship with Mr. Heffley was going to be regarding 25 THE WITNESS: I did not see that -- the need 25 redistricting? 54 56 1 for redistricting as a requirement that Republicans 1 A I didn't -- I wasn't aware that there was 2 needed redistricting done in a certain way to elect 2 going to be a, quote, relationship. 3 a Republican majority. 3 Q Did you have a relationship with Mr. Heffley 4 BY MR. KING: 4 on redistricting during the time -- in 2011 and the 5 Q You knew that every one present at that 5 first three months of 2012? 6 meeting that you were called to on December the 1st, had 6 A Can you explain what you mean by relationship? 7 been in opposition to the Fair District amendments; 7 Q Did you all work together very closely on 8 isn't that correct, sir? 8 these maps during that period of time? 9 A I didn't know that. 9 A I assisted him when he asked me to. 10 Q That was unknown to you? 10 Q All right. And why were you available to 11 MR. BROWN: That's what he just said. Move 11 assist Mr. Heffley? 12 on. 12 A Because I enjoyed doing that kind of work. 13 BY MR. KING: 13 Q It was just for fun? 14 Q You can go ahead and answer the question, sir. 14 A I was assisting him when he asked. 15 A I was going to ask you to -- I didn't fully 15 Q Were you just assisting him because it was 16 understand the question. If you could rephrase it. 16 just your own personal interest? 17 Q Okay. The question was: You didn't -- let's 17 A Yes. 18 break it down into bits. 18 Q Had nothing to do with business? 19 Is it your testimony that you didn't 19 A It had nothing to do with my business. 20 understand, for example, that Mr. Heffley and 20 Q As a full-time employee of the Republican 21 Mr. Bainter opposed the Fair District amendments? 21 Party of Florida? 22 A Okay. You previously mentioned asking me if I 22 A Yes. 23 knew all these people worked against Amendment 5 and 6. 23 Q Okay. Isn't it a fact, Mr. Terraferma, that 24 Q Right. 24 Mr. Heffley was employed by the Republican Party of 25 A And I do not know that for a fact that these 25 Florida starting in the summer of 2011 and paid $10,000 14 (Pages 53 to 56) WWW.USLEGALSUPPORT.COM 954-463-2933 57 59 1 a month to work on redistricting? 1 right, for him? 2 A I am not aware of that. 2 A That is correct. 3 Q You had no knowledge of that, sir? 3 Q Okay. Trying to answer his questions about 4 A I don't have knowledge that he was paid the 4 the maps, right? 5 amount that you just stated for the purpose that you 5 A Anyone who knows me knows I am a night owl, so 6 stated. 6 the fact that I am up at 2, 3, 4 o'clock in the morning 7 Q All right. Were you aware that he was a paid 7 is not unusual. I mean, you will notice that there's -- 8 consultant of the Republican Party of Florida working on 8 you're never going to see e-mails from me at 6, 7, 8, or 9 redistricting from 2011 to now? 9 9 o'clock in the morning because I am sleeping. I am a 10 A I was aware that Mr. Heffley was a consultant 10 night owl. 11 to the Republican party. I was not aware of the amount 11 Q You also -- did you work with Mr. Bainter as 12 of money he was paid or what the nature of his contract 12 well on redistricting? 13 was with the Republican Party of Florida. 13 A Not very much. 14 Q So you didn't -- as you were working with him 14 Q You knew Mr. Bainter was doing the same kind 15 on redistricting, you didn't understand that he had been 15 of work that you were doing on maps, didn't you? 16 employed as a consultant to lead -- to work in the area 16 A I knew that he was doing some stuff with -- 17 of redistricting for 24 months? 17 regarding redistricting, but I didn't know much of what 18 MR. MEROS: Object to the form. Asked and 18 he was doing or I hardly had any conversations or e-mail 19 answered. Go ahead. 19 with him. 20 THE WITNESS: That's not -- I did not -- I do 20 Q Now, when you came to work in 2011, at some 21 not know what you are telling me to be a fact. 21 time in the summer of 2011 did the party of Florida 22 BY MR. KING: 22 renew your Maptitude license? 23 Q Okay. So were you surprised by Mr. Heffley's 23 A I believe so. 24 interest in redistricting in 2011 and 2012? 24 Q Okay. And did anybody else there at the 25 A No. 25 Republican Party of Florida have a Maptitude license 58 60 1 Q And so, in point of fact, it was your job to 1 besides you? 2 assist Mr. Heffley as he was doing this work on 2 A I am not aware of anyone else. 3 redistricting; isn't that right? 3 Q Okay. Did Mr. Bainter have a Maptitude 4 MR. MEROS: Object to the form, leading, asked 4 license? 5 and answered. Go ahead. 5 A I don't know. 6 MR. CANTERO: Object to the form. 6 Q You didn't compare maps with Mr. Bainter? 7 THE WITNESS: That was not my job. 7 A I mean, we -- I am sure my recollection is 8 BY MR. KING: 8 that we discussed some maps at some point, but I don't 9 Q But you worked awfully hard at it, didn't you? 9 know how that relates to the Maptitude that you are 10 MR. MEROS: Object to the form, argumentative. 10 referencing. 11 Go ahead. 11 Q And when you started to work, you knew how to 12 THE WITNESS: I worked when he asked me to 12 operate the Maptitude? 13 help him. It was clear I did work when he asked me 13 A Somewhat. 14 and I was happy that I did it. Right. 14 Q That takes some skill, doesn't it? 15 BY MR. KING: 15 A It does. A little bit. I certainly don't 16 Q And you thought you were just doing it as a 16 feel like I was well versed in the software. 17 volunteer, separate and apart from your work 17 Q But it's not a simple thing to construct these 18 responsibilities for the Republican Party of Florida? 18 maps, is it, sir? 19 A I fully understood that at any moment I could 19 A It's not that hard, but it also, you know, 20 tell him I don't want to do it, I can't do it, it's not 20 there's also a lot of other features that are much more 21 my -- it was not -- we were not in any official capacity 21 technical. So I don't know that it's -- 22 where I felt like I had to do something for him that I 22 Q To your knowledge, did Mr. Heffley have a 23 did not personally want to do. 23 Maptitude license? 24 Q But some nights you worked as late as 24 A I think he did. 25 4 o'clock in the morning on those maps, isn't that 25 Q Okay. So he was able to construct maps as 15 (Pages 57 to 60) WWW.USLEGALSUPPORT.COM 954-463-2933 61 63 1 well? 1 A I am not -- I did not do that. 2 A I believe so. 2 Q Okay. To your knowledge, did Mr. Heffley do 3 Q All right. How about Mr. Reichelderfer, did 3 that? 4 he have a Maptitude license? 4 A I don't have that -- I am not aware. 5 A I am not sure. 5 Q So all this work on maps that you were doing 6 Q Did you work together with Mr. Reichelderfer? 6 was not to submit a map to the legislature as part of 7 A I had some conversations with him. 7 the public process, right? 8 Q On the mapping process? 8 A You know, the maps that I assisted with 9 A On mapping. 9 Mr. Heffley on were maps that he had asked for my 10 Q Alternative maps? 10 assistance on, and I am not sure what he intended for 11 A He, from time to time, he had shown me some 11 those maps. 12 maps and asked my opinion on it. 12 Q Okay. So -- 13 Q And did you ever submit a map to the 13 THE WITNESS: Can we take a bathroom break? 14 legislature during the public process up through 14 MR. KING: Sure, we'll take a break. 15 November 1st? 15 THE VIDEOGRAPHER: We are going off the 16 A I don't believe so. 16 record. It's 10:36. We are off the record. 17 Q Did you prepare a map for anyone else to 17 (A recess took place from 10:36 a.m. to 18 submit under their name? 18 10:49 a.m.) 19 MR. MEROS: Excuse me. Can you -- when you 19 THE VIDEOGRAPHER: We are back on the record. 20 say prepare a map, could you identify more 20 It is 10:49 a.m. 21 specifically House, Senate, Congressional? 21 BY MR. KING: 22 MR. KING: Sure -- 22 Q To put it in context, let's go back to where 23 MR. MEROS: Or if it's general, so indicate. 23 we were right before the break, and I was asking you 24 MR. KING: I think I may be asking general 24 about the maps that you did in 2011 and in 2012. And we 25 first. 25 centered on the period of time between July and November 62 64 1 BY MR. KING: 1 when the public maps were accepted by the legislature. 2 Q Did you prepare any map that was then provided 2 Do you remember that? 3 to somebody else to submit to the legislature, either 3 A Yes. 4 Congressional, Senate, or House? 4 Q And is it correct that you never, under your 5 A I think you said during -- the first time you 5 name or the name of the Republican Party of Florida, 6 asked me the question you had a time frame and then you 6 your employer, submitted any map to the legislature 7 changed the way. 7 under the public process? 8 Q I did. Let me make that clear. I appreciate 8 MR. MEROS: Object to the form, asked and 9 that. 9 answered. Go ahead. 10 You know that there was a period of time when 10 THE WITNESS: I don't believe that we -- that 11 the legislature solicited information or maps from the 11 me nor the Republican party submitted any maps 12 members of the public? 12 during that time that you referenced. 13 A Yes. 13 BY MR. KING: 14 Q And that time ended around November 1, 2011, 14 Q All right. Now, did you provide a map to 15 right? 15 anybody else to submit under their name during that 16 A That's my understanding. 16 time? 17 Q All right. Now, during that period of time 17 MR. MEROS: Same objection, go ahead. 18 that maps were solicited from the public, did you 18 THE WITNESS: I do not believe I did that. 19 prepare a map yourself that was submitted to the 19 BY MR. KING: 20 legislature under your name or under the name of the 20 Q Okay. To your knowledge, did any of your 21 Republican Party of Florida? 21 fellow consultants -- strike that. 22 A No. 22 Did any of the consultants like Mr. Heffley or 23 Q Did you prepare a map that you provided to 23 Mr. Bainter or Mr. Reichelderfer, to your knowledge, 24 some other person to submit to the legislature, either a 24 provide any maps to the Florida Legislature during the 25 House, Congressional, or Senate map? 25 public process? 16 (Pages 61 to 64) WWW.USLEGALSUPPORT.COM 954-463-2933 65 67 1 A I do not have that knowledge. 1 from prior to about July of 2011, I don't have very many 2 Q And so to your knowledge, were any of the maps 2 e-mails prior to July of 2011. 3 that you prepared provided to the legislature after 3 Q And why was that? 4 November 1 by either yourself or someone else? 4 A Because about a year ago, probably to free up 5 A I don't believe so. 5 space, I deleted e-mails that were in the first part of 6 Q Do you know that for a fact? 6 2011 and prior. 7 A No. 7 Q So in June of 2012, you deleted e-mails for 8 Q In fact, all the maps that you prepared, were 8 the first half of 2011? 9 those turned over to Mr. Heffley? 9 A No. I believe around the end of '11, the end 10 A Maps that -- there was a two-way flow of maps. 10 of '11 or the beginning of '12 I deleted e-mails from 11 Sometimes I had maps that I sent; sometimes he had maps 11 the beginning of 2011. 12 that he sent me. 12 Q Okay. 13 Q Okay. But all -- would it be correct that the 13 A Most. Probably not all, but most. 14 maps that you did were provided to Mr. Heffley? 14 Q How would you delete most but not all? What 15 A I don't believe I provided him every single 15 would you save? 16 map that I ever drew. I don't believe that to be the 16 A Right. There were -- if some things were in a 17 case. 17 subfolder that I didn't open. But the majority -- what 18 Q The ones you liked the best, did you provide 18 I recall doing is the e-mails that I deleted during this 19 those to Mr. Heffley? 19 time period were ones in the deleted items box or sent 20 A I don't recollect what criteria may have been 20 items box. But there may have been some subfolders that 21 used to give him maps. 21 only had a few e-mails that I would not have probably -- 22 Q But you transmitted a significant number of 22 I would have probably looked over them because they were 23 your maps to Mr. Heffley; is that right? 23 small subfolders. 24 A Clearly, yes. 24 Q I show you Heffley Exhibit 5 which purports to 25 Q And did you transmit some of your maps to 25 be an e-mail from Mr. Heffley to you and Joel Springer 66 68 1 Mr. Reichelderfer? 1 dated February 2, 2011 and ask you if you recall 2 A I don't recall me transmitting maps that I had 2 receiving that e-mail? 3 drawn to Mr. Reichelderfer. 3 A I don't recall this e-mail in particular. 4 Q Did you transmit any maps, either 4 Q Do you deny you received it? 5 Congressional, State, or House, to Mr. Bainter or any of 5 A I don't recall ever receiving this. 6 his associates at Data Targeting? 6 Q The question was do you deny receiving it? 7 A I believe that I might have sent Mr. Bainter 7 A Yes -- no, I don't deny it. It says it was 8 one or two maps, I believe so. 8 sent to me, but I don't recall receiving it. 9 Q Mr. Terraferma, I didn't find Reichelderfer 9 Q Okay. Did you assist Mr. Heffley in the 10 Exhibit 2, which is in front of you, in your files and 10 February of 2011 period in ascertaining or updating his 11 records that you produced. Do you know why that would 11 stats for redistricting? 12 be? 12 A I might have, but I don't recall specifically. 13 A Which one are you asking me about? 13 Q Why were you concerned about performance 14 Q I am asking you about Reichelderfer Exhibit 2. 14 information regarding redistricting? 15 That's the composite exhibit of -- each of these e-mails 15 A I believe we looked at performance as an 16 appear to have come to you, correct? 16 analysis after -- as an analysis after districts were 17 A Yes. 17 passed as part of our duty to win races, we looked at 18 Q Or were emanated from your computer, right? 18 performance data. 19 A I am not following you. 19 Q And you looked at that performance data as you 20 Q Well, one of them, Reichelderfer 16, Bates 20 were going through the redistricting process and 21 stamp 16, actually you sent that e-mail out, right? 21 anticipating what districts would look like and how they 22 A Yes. 22 would perform; isn't that correct, sir? 23 Q All right. How is it that those weren't in 23 MR. MEROS: Object to the form, leading. Go 24 your production? 24 ahead. 25 A I believe that I don't have a lot of e-mails 25 THE WITNESS: Can you restate the question, 17 (Pages 65 to 68) WWW.USLEGALSUPPORT.COM 954-463-2933 69 71 1 please? 1 have a sense of how those districts might perform, 2 BY MR. KING: 2 right? 3 Q Isn't it correct, as you went through this 3 A I didn't establish any districts, I don't 4 redistricting process, you would evaluate the 4 believe. That's what you said. 5 performance of the proposed districts that were being 5 Q I understand you are not a lawmaker, but as 6 considered? 6 you did maps, you were establishing districts on your 7 A I am sure that I evaluated districts that 7 maps, right? 8 were, you know -- that -- that I evaluated districts, 8 A Yes, I had statistics for the various maps 9 yes. 9 that I drew. 10 Q And you wanted to know how they would perform 10 Q And you determined how those maps performed, 11 as far as electing Republicans; isn't that correct, sir? 11 isn't that right, as you drew them? 12 A Yeah, I would say to evaluating the districts 12 A No, not necessarily while we were drawing 13 on how the districts performed politically. Right. 13 them; perhaps afterwards. 14 Q Your job was to elect Republicans, right? 14 Q Okay. After you drew a map, you would analyze 15 A Yes, that's my job. 15 it and see how it performed, right? 16 Q All right. 16 A Not always, but possibly. 17 A Part of my job. 17 Q And you and Mr. Heffley would discuss that 18 Q And redistricting was part of that job 18 information; isn't that right? 19 performance; isn't that correct, sir? 19 A I think we had a couple of discussions about 20 A No. 20 some things of that nature. 21 Q I mean, how those districts would perform in 21 Q You just had a couple of discussions, sir? 22 the future was going to determine whether you would be 22 MR. MEROS: Object to the form, argumentative. 23 able to elect Republicans in the House or Senate or 23 BY MR. KING: 24 Congress, right? 24 Q Is that all? 25 MR. MEROS: Object to the form, leading. Go 25 A That's -- my recollection is that we discussed 70 72 1 ahead. 1 some of these maps. I don't recall specific 2 THE WITNESS: I disagree with that premise. 2 discussions. I am sure in the -- my production there 3 BY MR. KING: 3 are some references to what you are asking about. But I 4 Q That how the districts would perform would 4 mean, the only way I can recall some of that information 5 play a role in the electability of Republican 5 is actually seeing those e-mails. I don't have specific 6 candidates? 6 recollections of specific conversations. 7 A I would agree with that. 7 Q Did you attempt to master the issues involved 8 Q Okay. You would agree that how the districts 8 in the redistricting process, Mr. Terraferma, as best 9 performed in the past in other significant elections 9 you could? 10 would affect how they might perform in the future, 10 MR. MEROS: Object to the form, vague. Go 11 right? 11 ahead. 12 A I would say the political data is -- could be 12 THE WITNESS: Could you please rephrase the 13 an indicator of how a district would the elect -- would 13 question or explain it better because I don't 14 vote in a general election. 14 really understand the question. 15 Q Right. You accumulated a lot of political 15 BY MR. KING: 16 data about how Floridians had voted in past elections; 16 Q Let me show you Exhibit 6 from Mr. Heffley's 17 isn't that correct, sir? 17 deposition which appears to be an e-mail from Mr. Tom 18 A I wouldn't say it's a lot of data, but, yes, 18 Hofeller -- 19 we had data. 19 MR. MEROS: Hofeller. 20 Q Right. And you analyzed a bunch of prior 20 BY MR. KING: 21 elections, right? 21 Q -- Hofeller to Mr. Heffley and Mr. Terraferma 22 A Going back a couple of cycles, yes. 22 dated February 10, 2011, and ask you if you recognize 23 Q Right. And then you categorized that 23 that, sir? 24 information so as you established new districts, both in 24 A I don't really recognize this. 25 the House and the Senate and the Congress, you would 25 Q Did you receive it? 18 (Pages 69 to 72) WWW.USLEGALSUPPORT.COM 954-463-2933 73 75 1 A My name is on here, but I don't recollect 1 that, on this presentation. But if he would have asked, 2 receiving this e-mail. 2 I probably would have helped him. 3 Q Who is Mr. Hofeller? 3 Q Were you aware that Mr. Heffley was making 4 A Hofeller is -- he is the -- he works at the 4 presentations like that on redistricting? 5 Republican National Committee. 5 A Yes. I mean, not -- I didn't know he did one 6 Q And why would he be sending this to you? 6 to the RPF board, but I know he did a presentation to 7 A Because he knows us and knew that we were 7 other groups. 8 following the redistricting process, and I am sure he 8 Q All right, sir. I show you Exhibit 2 in this 9 thought this information would be useful. But actually, 9 deposition and ask you if you recognize that as an 10 now I am speculating, which I probably shouldn't do, so, 10 e-mail from your yourself to George Meros at 11 I mean -- but I did just speculate and that's how I 11 GrayRobinson.com? 12 speculated. 12 A Yes, I see my name on there. 13 Q So he knew that you and Mr. Heffley were 13 Q And do you recall why you sent this to 14 following the redistricting process, right? 14 Mr. Meros? 15 A I believe he did know that, yes. 15 A I sent this to him, I believe just to -- I 16 Q And had you discussed it with him? 16 think I thought he would be interested to see that. 17 A Yes, I mean I discussed redistricting with 17 Q Why did you think he would be interested to 18 him. I don't remember at this time if we had -- what we 18 see that? 19 had discussed. 19 A Just because it's about redistricting and I 20 Q Why were you discussing redistricting with 20 think it's about the public hearings. 21 Mr. Hofeller? 21 Q Did you regularly communicate with Mr. Meros? 22 A He follows redistricting issues at the RNC. 22 A No. 23 Q In Washington? 23 Q And what was it about this communication from 24 A Yes. 24 Scott Arceneaux of the Florida Democratic party that 25 Q And you and Mr. Heffley were already working 25 made you think, wow, that's something I need to send to 74 76 1 together by February 10 of 2011 on redistricting? 1 Mr. Meros? 2 A What do you mean by working on redistricting? 2 A I don't recall. 3 Q Well, you were sharing e-mails, discussing 3 Q Was he your attorney at that time? 4 redistricting together by then? 4 A No, he's never been my attorney. 5 A Sharing e-mails. It appears that way. 5 Q I show you Exhibit 11 in Mr. Reichelderfer's 6 Q I show you Heffley Exhibit 14 which purports 6 deposition which is a document entitled Redistricting 7 to be a redistricting briefing provided to the 7 Hearing Pointers, and it's an e-mail from you to 8 Republican Party of Florida May 14, 2011 at a Republican 8 Mr. Reichelderfer on July 5, 2011, and ask you if you 9 Party of Florida board meeting and ask you if you 9 recognize that? 10 recognize that document? 10 A I recognize this. 11 A I have never seen this document in my life. 11 Q This is another document that wasn't produced 12 Q Did you attend Republican Party of Florida 12 to us in this case. Is that one you deleted as well? 13 board meetings? 13 A Well, no. I mean, well, the answer to your 14 A No. 14 question is that I believe that the -- my attorneys, 15 Q Did you assist Mr. Heffley in preparing this 15 pursuant to their recent -- since I am not a lawyer, I 16 presentation before he made it to the board? 16 am afraid of saying it the wrong way, but pursuant to 17 A No. 17 the recent motion, produced the documents that they felt 18 Q You had absolutely nothing to do with it? 18 were the most respondent, responsive to the subpoena. 19 A I just testified that I've never seen this 19 Q So you think this is a document that was 20 document ever. 20 withheld? 21 Q Okay. And Mr. Heffley never suggested to you 21 A It might be. 22 that he needed to get prepared for a briefing that he 22 Q Were there other documents that you produced 23 was going to make to the board and needed your 23 that were withheld? 24 assistance on it? 24 A It's possible. 25 A I don't recall him ever asking for my help on 25 MR. KING: Counsel, are there other documents 19 (Pages 73 to 76) WWW.USLEGALSUPPORT.COM 954-463-2933 77 79 1 that haven't been produced? 1 Q You believe you had consulted with him prior 2 MR. BROWN: Yes, indeed there are. As you 2 to this? 3 will see, we filed a motion for protective order 3 A It's possible that we might have consulted 4 with the Court last week and we've withheld certain 4 with him prior to this. I don't recall. 5 documents pending ruling on that motion. 5 Q And he was -- he is formerly a member of the 6 MR. KING: Do you have any -- I am just trying 6 Republican National Committee? 7 to figure out what's the volume that you've 7 A I don't have that knowledge. I am not aware 8 withheld? 8 of that. 9 MR. BROWN: I don't know specific page count. 9 Q You understood that he was a Republican map 10 I would guess it's probably an inch thick or so 10 drawer? 11 maybe. 11 A I understood that he is a -- he is a company 12 MR. KING: And the basis that they have been 12 that provides technical assistance that does political 13 withheld is? 13 consulting. That's what I understand about his company. 14 MR. BROWN: Basis is stated in the motion. 14 Q And Mr. Rimes is the former executive director 15 MR. KING: And that's all the identification 15 of the Republican Party of Florida? 16 we are going to get of those documents? 16 A He is. 17 MR. BROWN: At this time, yes. 17 Q Why were you sending it to him? 18 BY MR. KING: 18 A I don't recall. 19 Q Well, my question to you, sir, is: Did you 19 Q And so you were starting your work with 20 prepare these redistricting hearing pointers? 20 Maptitude, right? 21 A I believe I did. 21 A It's possible. I believe so. 22 Q And did you discuss them with Mr. Heffley 22 Q All right. Well, it's not possible. You 23 before you sent them out to Mr. Reichelderfer? 23 believe that's what you were doing, right? 24 A I don't recall. 24 A It seems that way. 25 Q Why did you say not -- that the person should 25 Q And as you started drawing districts, 78 80 1 not identify themselves orally or in writing as a part 1 Congressional districts, you wanted to make sure what 2 of Republican party? 2 the population was supposed to be for each district, 3 A Because they are not authorized to speak for 3 right? 4 the Republican party. 4 A Yes, this e-mail I was trying to get 5 Q Did you disseminate this to others besides 5 clarification on since Congressional seats have to be 6 Mr. Reichelderfer? 6 drawn at what's called zero deviation, trying to find 7 A I believe that it was disseminated, yes, to 7 out what that would look like since there is going to be 8 others. 8 an odd number of -- odd number of residents, so some 9 (Exhibit No. 3 was marked for 9 districts would have a few more population than others. 10 identification.) 10 (Exhibit No. 4 was marked for 11 BY MR. KING: 11 identification.) 12 Q I show you, sir, Exhibit 3, and ask you if you 12 BY MR. KING: 13 recognize that as an e-mail from yourself to a fellow 13 Q I show you Exhibit 4 and ask you if you 14 named John Dietz [sic] -- 14 recognize that as an e-mail -- at least the top one is 15 A Diez. 15 an e-mail from you to Mike Wild of July 11, 2011. Do 16 Q Diez. All right. And a copy to Mr. Heffley 16 you recognize that as an e-mail you sent? 17 and Mr. Jim Rimes, an e-mail sent July 11, 2011. Is 17 A It looks familiar. 18 that a document you sent, sir? 18 Q You are still working on a problem of the 19 A It certainly appears that way. 19 population of various Congressional districts, right? 20 Q Now, Mr. Diez is with Magellan Strategies in 20 A Seems like that I was asking the same question 21 Louisiana? 21 of two different people on the same day at virtually the 22 A Yes. 22 same time. 23 Q Why were you consulting with him? 23 Q All right. And Mike Wild, he is the deputy 24 A I believe that we had consulted with him for 24 director for strategic analysis at the Republican 25 technical assistance. 25 National Committee? 20 (Pages 77 to 80) WWW.USLEGALSUPPORT.COM 954-463-2933 81 83 1 A I know he works at RNC. I wasn't sure of his 1 Maybe. 2 title. 2 Q Where did you have a meeting with him? 3 Q Why did you choose to ask him the questions? 3 A We visited in my office. 4 A Because I thought he might know the answer. 4 MR. CANTERO: I am sorry. I just want to 5 Q How did you know he might know the answer? 5 clarify, when you say September, 2011? 6 A Just from the fact that I am acquainted with 6 THE WITNESS: That's my recollection. 7 him and was acquainted with kind of the job that he 7 BY MR. KING: 8 does, which is the title that you just stated. 8 Q And was anybody with him when he visited your 9 Q Had you been working with him on redistricting 9 office? 10 in Florida up to that time? 10 A I think there was another gentleman that 11 A No, I wouldn't classify that I had been 11 traveled with him, Dale, Dale Oldham. 12 working with him on redistricting. I wouldn't 12 Q Is Dale Oldham, is he the fellow from South 13 characterize that. 13 Carolina? 14 Q Had you had meetings with him about 14 A I am not sure. 15 redistricting in Florida? 15 Q Is he a lawyer? 16 A No. 16 A I believe so. 17 Q Telephone calls? 17 Q Okay. And did Mr. Heffley join you? 18 A It's possible, but I don't recollect the 18 A I believe Mr. Heffley also was present at 19 specific call. 19 various points in time. 20 Q But he is one of the people that you might 20 Q What do you mean present at various points of 21 call to ask questions about redistricting? 21 time? 22 A Yes. 22 A I am not sure -- what I am saying is I don't 23 (Exhibit No. 5 was marked for 23 know if Mr. Heffley was there, if we all met together 24 identification.) 24 all for the exact same amount of time or there were 25 25 times where I was present and he wasn't, or vice versa. 82 84 1 BY MR. KING: 1 That's what I am saying. 2 Q I show you next Exhibit 5 and ask you if you 2 Q So Mr. Heffley might have stepped away from 3 recognize Exhibit 5 as an e-mail of July 11, 2011 that 3 the meeting at some point? 4 you authored to Mr. Hofeller? 4 A And I might have as well. 5 A I -- you know, this appears to be an e-mail 5 Q What was the purpose of the meeting for? 6 that I sent. 6 A They wanted to come down and just talk about 7 Q Okay. And why did you write Mr. Hofeller? 7 redistricting. 8 A Well, I think -- well, in examining this 8 Q And what did they have to discuss with you 9 document, it looks like Mr. Wild is the one that looped 9 about redistricting? 10 Mr. Hofeller into this e-mail, kind of verifying what he 10 A I don't remember the specifics of what they 11 had surmised and was getting Tom's opinion on it. I 11 had to say. 12 didn't e-mail Tom. I mean, I only e-mailed him after 12 Q Did they give you some specific advice about 13 Mr. Wild had opined, had brought him into the 13 how you ought to handle the redistricting issues you 14 conversation. 14 were dealing with? 15 Q Who did you understand Hofeller to be? 15 A Like I just stated, I don't remember any 16 A Tom Hofeller works at the RNC, I believe that 16 specific conversations that were had at that time. 17 his title was redistricting director or something like 17 Q So your memory is just a complete blank as to 18 that. 18 that discussion with those fellows from Washington? 19 Q Did you have meetings with Mr. Hofeller on 19 A Yes. 20 redistricting in 2011 and 2012? 20 Q Were they trying to get hired as consultants? 21 A I believe that I did have a meeting with him. 21 A I don't believe so. 22 Q Where did you have a meeting with him? 22 Q That wasn't discussed? 23 A I think he came to Tallahassee. 23 A That was not discussed. 24 Q When did he come to Tallahassee? 24 Q So you remember at least that that wasn't 25 A I think it was around September, I think. 25 discussed? 21 (Pages 81 to 84) WWW.USLEGALSUPPORT.COM 954-463-2933 85 87 1 A Well, what I am saying I guess is that they 1 BY MR. KING: 2 have a job. They didn't -- I don't recall them coming 2 Q I show you Exhibit 6 which purports to be an 3 here for a job, so when I answered your question, was 3 e-mail from you on July 11, 2011, again to Mr. Diez at 4 you asked me if they came seeking a job and I said, no, 4 Magellan and ask you if you recognize that chain as 5 that doesn't mean that I recollected what we discussed. 5 e-mails you sent? 6 It's just so implausible. They have a job; they didn't 6 A It certainly looks like e-mails that I have 7 come seeking a job. 7 sent. 8 Q Were they there coming to see you as part of 8 Q So you indicate that by this time, you have 9 their job for redistricting nationwide? 9 got the population of the districts all squared away; is 10 A I am not sure if they went to other states or 10 that right? 11 what their job duties are. 11 A That's correct. 12 Q Well, you brought up their job as far as being 12 Q His -- 13 one involving redistricting, right? 13 THE VIDEOGRAPHER: We have four minutes left 14 A That's the title of Mr. Hofeller. He is the 14 on the tape. 15 director of redistricting. I thought we established 15 MR. KING: I can handle about two of those 16 that. 16 right now. 17 Q Were any maps shown to Mr. Hofeller while he 17 BY MR. KING: 18 was here? 18 Q I show you Heffley Exhibit 17, sir, which 19 A I don't recall. 19 purports to be an e-mail of yours on August 9, 2011, 20 Q By that time you had some maps, didn't you? 20 another one that you didn't produce, and ask you if you 21 A We might have. 21 recognize that as an e-mail you sent out to Mr. Heffley, 22 Q Did they reveal to you what their interest was 22 Kathy Mears, Joel Springer, and Christina? 23 in Florida redistricting? 23 A I mean, it certainly appears that this is an 24 A I don't think -- like I said, I don't remember 24 e-mail that I received and an e-mail that I sent. 25 anything specifically that they stated, so I don't 25 Q Okay. And who is Kathy Mears? 86 88 1 recall any revelations that they made. 1 A Kathy Mears -- you are talking about at the 2 Q Did they schedule the meeting with you in 2 time of this e-mail? 3 advance? They just didn't appear in your office one 3 Q Yes. 4 day? 4 A At the time of this e-mail she was a, I guess 5 A I am sure they did not just show up one day. 5 she was a consultant for the Republican party. 6 Q Did you take any notes at that meeting? 6 Q Okay. And Springer was your fellow employee 7 A I don't think so. 7 at that time? 8 Q Do you ever take notes in any of these 8 A Yes. 9 meetings you had about redistricting? 9 Q And who is Christina? 10 A We have only talked -- you only mentioned one 10 A Christina Johnson was also a consultant. Yes, 11 meeting that I told you I didn't probably attend. 11 a consultant as well. 12 Q I was just asking at any time, 2011 and '12, 12 Q All right. And you referred to the League of 13 any meetings pertaining to redistricting, did you ever 13 Women Vipers website? 14 take any notes? 14 A Yes, that's what I wrote. 15 A I don't recall taking any notes. 15 Q Is that what you called the League of Women 16 Q Do you recall producing any notes? 16 Voters? 17 A I am not even sure what you mean by that. 17 A Regretfully I used that language and I do 18 Q Handwritten notes? 18 regret that, but I was referring to the League of Women 19 A Producing notes? 19 Voters. 20 Q I mean, for this production, for this 20 Q And you called them the League of Vipers? 21 deposition; when you got your documents together, did 21 A That's what I wrote. 22 you find any notes? 22 Q Is that the way you felt at the time? 23 A No. 23 A I don't recall how I felt at that time. 24 (Exhibit No. 6 was marked for 24 MR. KING: Go ahead and change the tape now. 25 identification.) 25 THE VIDEOGRAPHER: This is the end of tape 22 (Pages 85 to 88) WWW.USLEGALSUPPORT.COM 954-463-2933 89 91 1 number 2. Now we are going off the record. It's 1 plan from me to Rich. 2 11:29 a.m. 2 Q Somehow that's a way to do it? 3 (A recess took place from 11:29 a.m. to 3 A I think there could be other ways, but I don't 4 11:36 a.m.) 4 really fully recollect how I gave him this plan. As you 5 THE VIDEOGRAPHER: We are back on the record. 5 noticed, I use the word question mark because I wasn't 6 This is the start of tape number 3 and it's 6 sure myself. I was not certainly a technical expert in 7 11:36 a.m. 7 this software. 8 (Exhibit No. 7 was marked for 8 Q Okay. Were these your first Congressional and 9 identification.) 9 State Senate plans? 10 BY MR. KING: 10 A I don't recall. 11 Q Next I show you Exhibit 7 and ask if you 11 Q Who worked with you on the plans other than 12 recognize that as an e-mail of July 26, 2011, from you 12 yourself? 13 to Mr. Heffley? 13 A Presumably I did it by myself. But I don't 14 A I believe this is an e-mail that I wrote. 14 recall anybody else working with me, so I presume -- I 15 Q And at this point, you evidently have created 15 don't really -- when I was drawing things, I don't 16 Congressional and State Senate plans; is that correct, 16 recall anyone being with me, so I am having to assume 17 sir? 17 that I was by myself regarding this, regarding these 18 A It seems that way. 18 plans, this e-mail. 19 Q And this is prior to the public process 19 Q Why were you sending them to Mr. Heffley? 20 starting; isn't that correct, sir? 20 A I presume he asked for them, but I don't know. 21 A I don't remember when that first hearing was 21 I am not really sure. 22 held. I thought it was -- I thought it might be before 22 Q Could it be because he was the Republican 23 this date, but I am not sure. I don't know. 23 consultant in charge of redistricting for the Republican 24 Q All right. And you were sending -- is it 24 Party of Florida? 25 correct that you were going to send these plans to 25 A As I previously told you, I didn't know that 90 92 1 Mr. Heffley? 1 -- I don't know to this day and I only have to be going 2 A I wrote that I would be sending them to him, 2 off your word that that was his title or his official 3 yes. 3 role at the Republican party. So I don't -- certainly I 4 Q All right. How do you -- how did you provide 4 know he was interested in redistricting, but I don't 5 those to him? 5 know more than that. 6 A I don't recall. 6 Q Is Mr. Heffley a secretive fellow? 7 Q What would be the method by which you would 7 A I don't know. I am not sure what you mean by 8 transmit the Congressional and State Senate plan to 8 that. 9 Mr. Heffley? 9 Q I mean, is -- can you imagine some reason why 10 A I believe that in other e-mails that I 10 he would not reveal to you that he had been employed by 11 produced say that I was giving him a disk, but I don't 11 the Republican Party of Florida to consult on 12 specifically recall how I transmitted this plan or other 12 redistricting at the price of $10,000 a month? 13 plans for that matter to him. 13 MR. MEROS: Object to the form. 14 Q Why would you give it to him on a disk? 14 Argumentative. Foundation. 15 A I think it's possible that sometimes 15 THE WITNESS: Can you restate the question, 16 transmitting these types of plans, if it's too big to be 16 please? 17 sent by e-mail, that it would have to be done in another 17 BY MR. KING: 18 way. But I don't recall for sure. 18 Q Sure. Can you think of some reason that 19 Q What does it mean when it says, "export plans 19 Mr. Heffley wouldn't have told you that he had been 20 at blocks as dbf, correct"? 20 employed by the Republican Party of Florida as a 21 A I think that my production shows I struggled a 21 consultant on redistricting? 22 lot with a lot of the technical issues of this software. 22 MR. MEROS: Same objection. 23 But I mean, I think that this is a way, exporting plans 23 THE WITNESS: I don't think he needs to go 24 as blocks as dbf would be, I think means database 24 around bragging to me that he's been hired by the 25 format, but I think that's somehow a way of giving this 25 party. He never told me that. Like I said, I 23 (Pages 89 to 92) WWW.USLEGALSUPPORT.COM 954-463-2933 93 95 1 don't -- frankly I have serious doubts that that 1 Congressional plans that I had, so I am not sure which 2 is -- was his title or that's what he was paid for. 2 plans these are specifically referencing, it doesn't 3 You are telling that to me, but I don't know that 3 say. 4 for a fact. 4 Q Did you have a way of identifying the plans? 5 BY MR. KING: 5 A Unfortunately, I was not the most organized in 6 Q Okay. And I take it you haven't read his 6 that regard. So -- so I mean, I am not sure which plans 7 sworn testimony under oath in this case. 7 those are. 8 A No. 8 Q I understand that, but did you identify plans 9 Q Okay. By the way, how did you prepare for 9 in some way? 10 this deposition, sir? 10 A Yeah. I mean, they had names. 11 A I searched my e-mails, I -- we also had a 11 Q You gave them a name? 12 computer expert come to retrieve e-mails and I searched 12 A That's my -- they are labeled in my production 13 my computer, and I searched my office. 13 with a name. 14 Q Well, that's how you accumulated the e-mails, 14 Q What are some of the names you gave the plans? 15 right, or the documents? 15 A I think Sputnik is a name that comes to mind. 16 A Oh, I see. I think I misunderstood your 16 I think some of them might be named Heffley. But I 17 question. 17 would have to look at the production to tell you the 18 Q My question was: How did you prepare for this 18 rest of the names. Those are a couple of things that 19 deposition to testify here today? Did you meet with 19 come to mind. 20 anybody about your testimony? 20 (Exhibit No. 8 was marked for 21 A I met with my attorneys. 21 identification.) 22 Q Okay. And those were who? 22 BY MR. KING: 23 A Mr. Healey, Mr. Brown, and Mr. Ginsberg. 23 Q I show you Exhibit 8 and ask you if this is an 24 Q Okay. Was Mr. Ginsberg present? 24 e-mail you recognize dated July 27, 2011, that you sent 25 A Was he present? 25 to Mr. Heffley with the subject State Senate? 94 96 1 Q Yes. 1 A Certainly this appears to be my e-mail. I 2 A Yes. 2 don't recall specifically sending this, but it's 3 Q Okay. He was here when you met with him? 3 definitely my e-mail. 4 A Yes. 4 Q Now, is this a plan, is this the State Senate 5 Q Okay. When was that? 5 plan that you were referring to in Exhibit 7? 6 A Several days ago. A week ago or so. About a 6 A This is a State Senate plan, I believe. 7 week. 7 Q Now, this shows the -- some description, a 8 Q How long did you meet with the three of those 8 visual description of the plan. Was the data 9 fellows? 9 transmitted behind the plan at the same time you sent it 10 A I don't remember. Several hours. Over -- 10 to Mr. Hofeller? 11 several hours over a couple of days. Not that 11 A I don't recall. 12 Mr. Ginsberg was there the entirety. 12 Q What does it mean when it says, "scan from 13 Q Did you talk to anybody else about your 13 RPOF xerox 001.pdf"? 14 testimony here today? 14 A I think I had scanned the document, scanned 15 A No. 15 it, that it originated as a scan from a scanner. 16 Q Okay. You didn't have any meetings with 16 Q Okay. And that's a Republican Party of 17 Mr. Heffley or Mr. Bainter about your testimony? 17 Florida scanner? 18 A No. 18 A Yes. 19 Q What happened to these Congressional and State 19 Q Okay. And would it be fair to say, sir, that 20 Senate plans that you sent to Mr. Heffley on July 26, 20 you developed this State Senate plan as part of your 21 2011? 21 duties at work for the Republican Party of Florida? 22 A What do you mean by what happened to them? 22 A I believe I've answered that question before, 23 Q I mean, were they in your files and records 23 that that is not part of my duties, official duties, 24 when you produced them to us here for this deposition? 24 especially you see it says Senate on it as well. 25 A I produced to you all the Senate and 25 Q So this is not part of your additional duties 24 (Pages 93 to 96) WWW.USLEGALSUPPORT.COM 954-463-2933 97 99 1 to do this State Senate plan that you did? 1 like to voir dire on this document and ask him a 2 A That's correct. 2 couple of questions if I could, on Exhibit 9. 3 Q How much -- how many hours did you have to 3 THE WITNESS: Can I interject? I think -- I 4 work on that before you produced this version of the 4 am not sure, did you mean to transmit these other 5 State Senate plan? 5 pages? 6 A I don't recall. 6 MR. KING: No. Normally I wouldn't think that 7 MR. MEROS: Let me object to form and just say 7 was a good idea but if you want to ask just a 8 I am not sure you're characterizing this document 8 couple of questions. 9 correctly. 9 VOIR DIRE EXAMINATION 10 MR. KING: Okay. I certainly want to try to 10 BY MR. MEROS: 11 get it right. 11 Q Mr. Terraferma, look at the first page after 12 BY MR. KING: 12 the -- 13 Q So how would you characterize this document, 13 A We are still on 8 or are we on 9? 14 Mr. Terraferma, that's attached? 14 Q We are on 8. Go back to 8. 15 A I am not sure, I don't know what you mean. I 15 A Okay. 16 am not sure that I followed the sequence of events that 16 Q At the top there is a map depiction in a block 17 just occurred. 17 there in a square, correct? 18 Q Well, is this a visual depiction of the State 18 A Yes, that's correct. 19 Senate plan that you sent to Mr. Heffley on July 27, 19 Q Does that say, "HJR 1987 (2002 Senate) 20 2011? 20 District 1"? 21 A It appears that this is copies of portions of 21 A Yes. 22 a State Senate plan that I sent to Mr. Heffley. 22 Q Does that mean that this -- that depiction is 23 Q Okay. Does it appear to be not totally 23 from the 2002 Senate? 24 complete to you? 24 A Looking at that block that you referenced, 25 A I have no reason to believe that this is not 25 that appears to me to be the State Senate lines that 98 100 1 the entirety of the scan. 1 were effected by the State of Florida between 2002 to 2 Q Okay. And did you provide any other 2 2012. 3 information to Mr. Heffley at the time you sent him this 3 Q So that is the -- the top portion here were 4 visual depiction? 4 the existing districts? 5 A I don't recall. 5 A That's -- certainly that's what it appears as. 6 Q And is it fair to say that these districts 6 Q And below that is what you drew? 7 that are depicted here are districts that you put -- 7 A That -- presuming that I drew this, which I 8 that you defined the lines for? 8 stated I don't recollect this specifically, but 9 A You are asking me if I drew the lines? 9 presuming that that is the case, that what I have 10 Q Yes, sir. 10 beneath that would be the -- would be, looks to me like 11 A Presumably I did. But I am not sure because I 11 I was showing what I drew and how that compared to what 12 don't really recollect this time. This is almost two 12 was existing at the time. 13 years ago. 13 Q Okay. And then the next page, am I correct in 14 Q Well, do you know who else would have drawn it 14 saying that the top block again was the existing Senate 15 if you hadn't drawn it? 15 map from 2002 to 2012? 16 A Like I stated, sir, I presume that this is my 16 A Yes. 17 work. I don't know who else did it, could have done it, 17 Q And then the second half of that is 18 would have done it. I presume it's mine, but I don't 18 purportedly what you drew? 19 recollect this map or this e-mail that was sent nearly 19 A Yes. 20 two years ago. 20 Q Is that the same thing on page 3? 21 (Exhibit No. 9 was marked for 21 A Yes. 22 identification.) 22 Q Okay. And go to page 4. Is that a depiction 23 BY MR. KING: 23 exclusively of portions of the existing Senate map from 24 Q And next, sir, I show you Exhibit 9 -- 24 2002 to 2012? 25 MR. MEROS: Let me ask you. May I -- I would 25 A I am sorry, can you restate your question 25 (Pages 97 to 100) WWW.USLEGALSUPPORT.COM 954-463-2933 101 103 1 again. 1 at the top and then your new map section below; is that 2 Q Page 4, it looks like it says, "HJR 1987 (2002 2 correct? 3 Senate) District 29." Do you see that? 3 A That appears to be the correct -- 4 A Yes. 4 Q Now, how have you changed in that section the 5 Q Does that appear to be the enacted map, the 5 existing Congressional map? 6 2002 enacted Senate map as opposed to something you 6 MR. MEROS: I am sorry, are you referring to a 7 might have drawn? 7 particular page? 8 A That is correct. That is my understanding in 8 MR. KING: That's the first page of the 9 reviewing this, that is the plan that existed for the 9 attachment. 10 decade of 2000. 10 MR. BROWN: Would that be Terra -- FT00025. 11 Q And the next two, the last two pages of 11 MR. KING: That would be. Exactly. 12 Exhibit 8, do these, in fact, show enacted districts of 12 THE WITNESS: You are asking me to verbally 13 the 2002 Senate plan? 13 tell you the difference? 14 A Yes. That's my -- that's what it appears, 14 BY MR. MEROS: 15 yes. 15 Q Do you see any significant changes in the 16 MR. MEROS: Okay. 16 two maps? 17 MR. KING: Okay. 17 A I mean, there are lots of changes. 18 CONTINUED DIRECT EXAMINATION 18 Q What are the more significant changes that you 19 BY MR. KING: 19 note? 20 Q All right, sir. So you have some of your plan 20 A Well, if you look at like the Volusia/Flagler/ 21 is depicted here in comparison to other districts and 21 St. Johns area in the top part and you look at it in the 22 evidently some of your plan is not depicted here; is 22 bottom part, they are substantially different there. 23 that right? 23 The third district by Corrine Brown in the bottom part 24 A What's depicted here is -- yes, what's 24 below has -- goes down into the Ocala area. That's 25 depicted. This is not -- what I probably drew is not -- 25 different than the top part. 102 104 1 the whole state plan is not on these sheets of paper. 1 The District 4, that -- at the top part, as 2 Q Okay. Did you have the rest of the plan that 2 represented by Andrew Crenshaw, has like Duval and 3 you didn't provide to Mr. Heffley? You just provided a 3 Nassau County in the upper part and then in this part he 4 selected part of it? 4 has St. Johns, Duval, and Nassau and no longer these 5 A Like I stated previously, I don't recall 5 other rural counties. 6 specifically sending this or why I chose certain parts 6 So those are some of the changes I can 7 to send, but I don't know if I sent more of this to 7 visually see. 8 Mr. Heffley or what. I don't recall. 8 Q My copy is not very good but does District 3, 9 Q Okay. Now let me show you -- I had already 9 does that run from Jacksonville to Orlando in your 10 given you Exhibit 9? 10 version of the map? 11 A Yes. 11 A It did with the population in Gainesville and 12 Q All right. Look at Exhibit 9. Do you 12 Ocala as well. 13 recognize that as an e-mail you sent to Mr. Heffley also 13 Q Then you do the same thing on the second page 14 on July 27, at about the same time as Exhibit 8? 14 of the attachment that's FT 26, you compare an area of 15 A It's the same time, yes. 15 the state from the original map and your proposal, 16 Q Right. And there the plan pertains to the 16 correct? 17 Congress, right? 17 A That's correct. 18 A It appears that way, yes. 18 Q That's the Tampa area? 19 Q So you were drawing -- even though your 19 A Yes, that is that. 20 assignment was the House, you were drawing maps for the 20 Q And you continue to do that through the 21 Senate and the Congress as well, correct? 21 exhibit you put in your Congressional map. Does it 22 A I drew Senate and Congressional maps as well, 22 contain all the Congressional map? 23 yes. 23 A This e-mail doesn't -- hang on. Let me look 24 Q And evidently the first page attached is the 24 at the whole document before I answer your question. 25 same thing we saw in Exhibit 8. You have the 2002 map 25 This depiction of maps does not show every district in 26 (Pages 101 to 104) WWW.USLEGALSUPPORT.COM 954-463-2933 105 107 1 the state in its entirety. 1 BY MR. KING: 2 Q Okay. Did Mr. Heffley have any reaction to 2 Q So it refers to, on the Senate it says, 3 what you had done? 3 "finish map, can have Hispanics in section 5 counties." 4 A As I have stated previously, this is almost 4 Do you see that language? 5 two years ago. I don't recall if he had any reaction at 5 A Yes. 6 all. I don't recall having a conversation with him 6 Q Is that Mr. Heffley -- is that Mr. Heffley's 7 about this. 7 suggestion to you? 8 (Exhibit No. 10 was marked for 8 A That's what he is writing to me, it appears. 9 identification.) 9 Q Well, you are writing it to him, aren't you? 10 BY MR. KING: 10 A Oh, yes. Right. I was incorrect. I 11 Q Next I show you Exhibit 10 which appears to be 11 misstated what the e-mail purports to show. 12 a July 27, 2011 e-mail from you to Mr. -- to Mr. Heffley 12 I wrote to Mr. Heffley and then I wrote in, 13 later in the same day as Exhibits 8 and 9 where 13 Senate finished map can have Hispanics in section 5 14 evidently you are discussing your maps, right? 14 counties. I don't really know -- I don't recall what I 15 A What's your question, I am sorry, sir? 15 wrote, what I meant. It's two years later now. I don't 16 Q My question is: This is an e-mail later in 16 really remember. 17 the same day that you sent the Senate and the 17 Q And it refers to "Tampa Bay Senate - cut out 18 Congressional maps to Mr. Heffley, right? 18 Sarasota," right? 19 A That is the same day that he -- that I sent 19 A That's what it says. 20 those. 20 Q Was that your idea or Mr. Heffley's? 21 Q All right. And this e-mail that you are 21 A I don't recall. 22 writing, you describe it as a follow-up from earlier 22 Q And then it says, "Congress fixed Tampa Bay," 23 today, correct? 23 what does that mean? 24 A That's what it says. 24 A I don't recall this e-mail. 25 Q You start out by saying, "tell me if I missed 25 Q Are you making a list of things you've got to 106 108 1 something." What are you referring to? 1 do? 2 A I am not sure. 2 A It seems that it could be that, but I simply 3 Q Aren't you referring to the maps? 3 don't remember. This is two years ago and I just don't 4 A Perhaps probably. But I'm not -- it's not 4 recall. 5 definitive. 5 MR. KING: Okay. We'll stop and take our 6 Q What do you understand has been redacted from 6 lunch break now. 7 this? 7 THE VIDEOGRAPHER: We are now going off the 8 MR. BROWN: Don't answer that question. 8 record. It is 12:03. 9 If it's been redacted, it's been redacted 9 (Lunch recess took place from 12:03 p.m. 10 because he's not going to talk about it. 10 to 1:09 p.m.) 11 MR. KING: Well, can you give me -- since I 11 THE VIDEOGRAPHER: We are back on the record. 12 don't have a clue as to what the basis of the 12 And it is 1:09 p.m. 13 redaction is, can you tell me what that is? 13 (Exhibit No. 11 was marked for 14 MR. BROWN: I don't remember off the top of my 14 identification.) 15 head either without a log of some type. 15 BY MR. KING: 16 MR. KING: Well, there is nothing here that 16 Q Next I show you Exhibit 11 and ask you if you 17 suggests this is an attorney/client document. So I 17 recognize this as an e-mail from Mr. Heffley to you and 18 am just curious as to the basis of the redaction. 18 Mr. Ginsberg? 19 MR. BROWN: Mr. Healey may have more specific 19 A It certainly appears that this was sent to me. 20 knowledge than I about that. 20 MR. KING: Do we know what this redaction is? 21 MR. KING: Thank you, Mr. Healey. 21 MR. HEALEY: This will be attorney/client. 22 MR. HEALEY: The information that was redacted 22 BY MR. KING: 23 dealt exclusively with House maps or issues. 23 Q Was Mr. Heffley and you both represented by 24 MR. KING: That is all you needed to tell me. 24 Mr. Ginsberg back then? 25 I just didn't have a clue. 25 A You are asking me? 27 (Pages 105 to 108) WWW.USLEGALSUPPORT.COM 954-463-2933 109 111 1 Q Yes. 1 Q Right. And it might have an impact on the 2 A I presume that Mr. Heffley has an attorney/ 2 Republicans' majorities in the House and the Senate and 3 client privilege relationship with Mr. Ginsberg. I 3 in the Congress, right? 4 think my attorneys might be better able to answer that 4 A What's the question? 5 question. 5 Q I said how these candidates run may also 6 Q Okay. I show you Exhibit 16 from 6 affect the majority position the Republican party had 7 Mr. Heffley's deposition which appears to be the same 7 both in the House and the Senate and the Congress, 8 July 28, 2011 e-mail and ask you if you recognize that 8 right? 9 as the e-mail you received on July 28, 2011? 9 A I think you meant how the districts were 10 A They appear to be the same e-mail. 10 drawn, although you said how the candidates run, so I am 11 Q Okay. And really what's discussed is 11 a little confused -- 12 Mr. Heffley is talking about that he's attached a copy 12 Q I am sorry. 13 of a proposed central Florida Hispanic district that he 13 A -- by the question. 14 is suggesting or that he's provided to you and 14 Q Let me try again. We'll see if I can get it 15 suggesting that you drop that baby into our map, right? 15 right. 16 A That's what he wrote. 16 A Okay. 17 Q Is that what you did? 17 Q How the districts were drawn would have an 18 A I don't recall. 18 impact on how successful your candidates would 19 Q So now again, is this something you are just 19 ultimately be, correct? 20 doing for fun? 20 A I don't agree with the full premise of your 21 A Yes. 21 question. I mean, about -- I agree how the districts 22 Q So this doesn't have anything to do with your 22 are drawn impacts the races that candidates run. 23 responsibilities at work? 23 Q Right. It impacts whether incumbents have to 24 A No. 24 run against each other or not, right? 25 Q And Mr. Ginsberg, he is just in on the fun, 25 A Yes. 110 112 1 too? 1 Q It relates to whether incumbents' districts 2 A Mr. Heffley sent that to Mr. Ginsberg. 2 include most of the prior people that voted for them in 3 Q Right. And you. 3 the past, right? 4 A Right. But you just asked me about Ben 4 A That's one of the things that comes out of a 5 Ginsberg, so I don't want to speak for him. I didn't 5 redistricting process. 6 send the e-mail. 6 Q Right. And how the various proposed districts 7 Q But it was your understanding that you and 7 may perform and did perform in prior elections was very 8 Mr. Heffley were doing this map process and Mr. Ginsberg 8 interesting to you; isn't that correct? 9 was watching what you were doing and seeing it, and this 9 A Yeah, it was interesting to us. 10 was just everybody was just doing it for pleasure? 10 Q Because you all -- 11 A I think one of the things that, besides 11 A To me, let me just speak for myself. 12 self -- not self-interest, personal interest, in doing 12 Q Well, it was interesting to you and 13 this map is also we were looking at various ways the 13 Mr. Heffley, both, right? 14 maps could look on how the legislature passed and how 14 A It seems that he has an interest. But I only 15 that would affect our jobs in terms of me running State 15 can speak for myself. So, yes, it was interesting to 16 House; Rich running -- being involved, if not -- I don't 16 me. 17 want to use the running because Joel runs State Senate, 17 Q And so, you continued to use a lot of the 18 but involved with running State Senate campaigns and 18 resources of the Republican party while you were doing 19 that's why we had played around with a lot of maps. 19 this mapping work, right? 20 Q Because how those maps performed would 20 A That I was -- you said -- you asked me if I 21 determine the success of your candidates in the future, 21 was using the resources of the Republican party? 22 right? 22 Q Yeah. Right. 23 A How the districts are drawn has an impact on 23 A I mean, I guess, it was their computer. 24 where the candidates run and might have an impact on 24 Q Right. Their license program, Maptitude? 25 their electoral chances. 25 A They purchased it, yes. 28 (Pages 109 to 112) WWW.USLEGALSUPPORT.COM 954-463-2933 113 115 1 Q Right. Their time, you were doing this some 1 Q You had an employer that would allow you to 2 at the office; isn't that right? 2 spend time drawing the maps, right? Correct? 3 A Yes. 3 A You are finished? 4 Q Right. Using their attorney, Mr. Ginsberg? 4 Q Yes, that's the end of the question. 5 A Yes. 5 A I think the State had very good software that 6 Q You weren't paying Mr. Ginsberg's fees, were 6 was available to every Floridian. So whether I had one 7 you? 7 kind of software and the State provided another one for 8 A No -- I did not pay him personally. 8 free, I think anybody could participate in the process. 9 Q You understood that he was a lawyer in 9 Q All right. The question was: Your employer 10 Washington at Patton and Boggs? 10 allowed you to spend time drawing maps; isn't that 11 A Yes. 11 right? 12 Q You ever figure out what kind of fees you have 12 A Yes. 13 to pay a lawyer like that? 13 Q Your employer also allowed you to utilize the 14 A No. 14 services of experts around the country in a Republican 15 Q You never paid him any fees, have you? 15 party that had worked in redistricting before, correct? 16 A I have not personally paid him any fees, no. 16 A We utilized experts, yes. 17 Q Okay. But you continue to suggest that this 17 Q So you were able to bring all those things to 18 was just your personal adventure to do these maps; is 18 bear in the maps that you were drawing, right? 19 that right? 19 A I am not sure that I agree with that. 20 A I don't think you heard everything I stated a 20 Q You were able to trade your maps around with 21 few moments ago. 21 Mr. Heffley and Mr. Reichelderfer and Mr. Bainter, all 22 Q Okay. Tell me again. 22 very experienced political operatives in Florida, right? 23 A What I stated was two things. 23 A Those folks are known experienced political 24 One was I stated that it was of immense 24 consultants. 25 personal interest to me; and secondarily, though, what I 25 Q All right. And the four of you had 114 116 1 also stated was that we were interested in looking at 1 connections and relationships with all the leadership in 2 how the districts could possibly come out with 2 both the House and the Senate of the legislature; isn't 3 Amendments 5 and 6 and, you know, getting an idea where 3 that correct? 4 potentially we would need to recruit candidates, where 4 A I can only speak for myself, that I worked for 5 potentially there would be open seats, where potentially 5 members of the legislature. 6 incumbents would run against each other. So I said 6 Q Right. You had a very close relationship with 7 there were two things. 7 Will Weatherford, right? 8 Q Right. But wasn't there a third thing? Also 8 A I was his employee. 9 you had the ability to potentially affect the way the 9 Q Yeah. And you knew that Heffley had his 10 maps were drawn by the legislature, didn't you? 10 relationships in the Senate and the House, right? 11 MR. MEROS: Object to the form leading. Go 11 A I am not aware of what particular 12 ahead. 12 relationships he has. 13 THE WITNESS: I think any citizen could 13 Q So all the time you and Mr. Heffley spent 14 participate in the process. I don't think that -- 14 together, he never discussed with you who -- which 15 I just disagree with the premise of the question. 15 legislators he was close to? 16 BY MR. KING: 16 MR. MEROS: Object to the form, leading, 17 Q You had a lot more advantages than any 17 argumentative. Go ahead. 18 citizen, right? 18 THE WITNESS: That's correct. 19 MR. MEROS: Object to the form. Leading. Go 19 BY MR. KING: 20 ahead. 20 Q Okay. And you knew that Mr. Reichelderfer had 21 THE WITNESS: I don't know. 21 relationships; isn't that correct? 22 BY MR. KING: 22 MR. MEROS: Object to the form, leading. Go 23 Q Well, you had the mapping programs and the 23 ahead. 24 data. 24 THE WITNESS: I knew that -- knew and know 25 A Okay. 25 that Michael Reichelderfer had clients that he 29 (Pages 113 to 116) WWW.USLEGALSUPPORT.COM 954-463-2933 117 119 1 worked for. What -- how -- what the nature of the 1 performed or Republican candidates performed was of no 2 relationship is, I am not -- I can't speak to that. 2 consequence to you; is that right? 3 BY MR. KING: 3 A It was something that certainly we considered 4 Q Well, you knew that he was very close to Dean 4 and looked at, but the State of Florida has an 5 Cannon; isn't that right? 5 obligation to pass legally compliant maps under 6 MR. MEROS: Object to the form, leading. Go 6 Amendments 5 and 6. That was my -- what I hoped that 7 ahead. 7 the legislature would do. 8 THE WITNESS: I know that he's done -- worked 8 Q But your goal was to try to make sure that 9 on Dean's reelection campaign. 9 those maps performed as well as possible for your 10 BY MR. KING: 10 clients; isn't that right? 11 Q And so you all, you and your fellow 11 A No. 12 consultants working in the redistricting area had 12 MR. MEROS: Object to the form, leading, 13 information about these maps as they evolved; isn't that 13 argumentative, asked and answered. Go ahead. 14 right? 14 THE WITNESS: I answered no. 15 A Can you restate the question? 15 (Exhibit No. 12 was marked for 16 Q In other words, as the maps were being 16 identification.) 17 supplied and considered by the legislature, you and 17 BY MR. KING: 18 Mr. Heffley would run your analyses of those maps and 18 Q Let me show you Exhibit 12 here, sir, and ask 19 determine the political performance under those maps; 19 you if you recognize that document, sir, as an e-mail 20 isn't that correct? 20 that you sent to Mr. Heffley on July 31st, 2011? 21 MR. MEROS: Object to the form. Leading. 21 A It certainly is an e-mail that appears that I 22 Can you -- again, can you explain, when you 22 sent to Mr. Heffley. 23 say maps, what you are talking about? 23 Q And -- 24 MR. KING: I am talking about the 24 MR. CANTERO: I'm sorry, you said July 11? 25 Congressional, Senate maps and the House maps. 25 MR. KING: I am sorry, July 31, 2011. That's 118 120 1 MR. MEROS: But I am asking -- I am asking for 1 my mistake. 2 clarification of maps drawn by him? Maps drawn by 2 BY MR. KING: 3 someone else? 3 Q You see that, sir? 4 BY MR. KING: 4 A Yes, I see this -- 5 Q As the legislature was involved in the map 5 Q Is that an e-mail -- 6 drawing process, you and Mr. Heffley, and perhaps 6 MR. BROWN: Let him finish his answer, please. 7 others, would quickly attempt to ascertain how those 7 MR. KING: Sure. 8 maps would perform politically as soon as you can get a 8 THE WITNESS: No, I think I was finished. 9 hold of them; isn't that right, sir? 9 BY MR. KING: 10 A There are instances where we did do political 10 Q Is that an e-mail you authored, sir? 11 analyses. I can't say that every time a map came out 11 A I e-mailed -- I authored -- it appears I 12 that it was analyzed by me or by Rich. I know that 12 authored the top part. 13 there are instances where I did a political analysis of 13 Q Okay. Now, in the bottom part, you wrote a 14 a map that was given to me or, you know, I know my 14 number of or you referred to what you called lies 1 15 e-mails show that. 15 through 5; is that right? 16 Q Isn't it correct, sir, that your only interest 16 A It appears that I wrote that. 17 in these maps was how they would politically perform? 17 Q And what was the purpose of that? 18 MR. MEROS: Object to the form, leading, 18 A I don't recall. 19 argumentative. Go ahead. 19 Q I mean, it appeared to be in response to 20 THE WITNESS: My interest was, is that the 20 something from the State Democratic party chair, Ryan 21 State of Florida would pass maps that would be 21 Smith, right, or something about that? 22 compliant with Amendments 5 and 6 so that we would 22 A It seems that way. 23 have an orderly elections process. 23 Q Now, do you know what happened to the 24 BY MR. KING: 24 originating e-mail on this chain? You see down at the 25 Q Okay. And so how the Republican party 25 bottom it's clear we don't have the entire chain? 30 (Pages 117 to 120) WWW.USLEGALSUPPORT.COM 954-463-2933 121 123 1 A One second, sir. I am studying this. 1 MR. MEROS: For the record, that's Larcenia. 2 (Examining document.) 2 MR. KING: Larcenia. Thank you, sir. 3 It appears Rich had e-mailed three, four other 3 THE WITNESS: I think I was talking about 4 people. 4 those two districts are districts that would give 5 MR. KING: All right. I just call on you, if 5 the opportunity of African Americans to elect the 6 you could, to check and see if there is a part of 6 candidate of their choice and both would have over 7 the string there that got left out somehow 7 50 percent African American population, I believe. 8 accidentally. 8 BY MR. KING: 9 MR. HEALEY: Do you have FT43? 9 Q And then what do you mean when you are saying 10 MR. KING: We do and it doesn't have anything 10 "having Ellyn," E-l-l-y-n, "problems, though, and that 11 to do with it. It will be the next exhibit, you 11 Negron is at PB county line and need 100,000"? 12 will see it. 12 A I mean, I indicated that I was having a 13 MR. BROWN: We'll check. I am going to tell 13 problem in drawing the map. I don't remember now, this 14 you, we have been through the documents pretty 14 is even kind of vague to me, but so I don't remember the 15 carefully, but we'll check. 15 specifics of this, of this problem that I referenced. 16 MR. KING: Okay. 16 Q Was Negron a Republican senator? 17 BY MR. KING: 17 A He is a Republican senator. 18 Q Now, you were sort of taking partisan 18 Q And who is Ellyn? 19 positions in this e-mail that you wrote evidently to 19 A I believe that's a reference to Ellyn 20 Mr. Heffley on July 31st, at 11:01 p.m.; isn't that 20 Bogdanoff. 21 right? 21 Q And what did you mean when you were saying you 22 A The things that I wrote seem to be statements 22 were having Ellyn problems? 23 that debunk some of the stuff that was being said 23 A Let me reread this carefully and try to see if 24 about -- by the proponents of Amendments 5 and 6. 24 I can remember. (Examining document.) 25 Q Right. Because you and Mr. Heffley were still 25 One thing about this is oftentimes political 122 124 1 involved in an effort to make as few changes pursuant to 1 people, including myself, will refer to a district by 2 these new amendments as you possibly could in these 2 the name of the person who represents the area. But I 3 maps; isn't that right? 3 think that this is really more of a geographic problem 4 MR. MEROS: Object to the form, leading, 4 as opposed to talking about specific incumbents, is that 5 compound, lack of foundation. Go ahead. 5 I was drawing districts in the Palm Beach County area 6 THE WITNESS: No. 6 and I was short a hundred thousand people. 7 BY MR. KING: 7 Q You say you "can't seem to find a way to 8 Q Well, look up at the first -- at the e-mail at 8 weasel out of this one"? 9 the top at 11:24 p.m., you write Mr. Heffley, right? 9 A That's what I wrote, yes. 10 A Yes. 10 (Exhibit No. 13 was marked for 11 Q And you say you were drawing the Senate that 11 identification.) 12 night. 12 BY MR. KING: 13 A Yes. 13 Q Next, sir, I show you Exhibit 13 and ask you 14 Q And you have four performing Hispanic seats in 14 if you recognize that document as a series of e-mails 15 south Florida utilizing Monroe, Collier, Hendry, and 15 that you exchanged with William Weatherford? 16 Broward, right? 16 A This appears to be e-mails that I have sent to 17 A That's what I wrote. 17 him. 18 Q When does it mean when you say you have four 18 Q All right. Now starting down at the bottom, 19 performing Hispanic seats? 19 you send an e-mail on August 1, 2011, to William 20 A I think what I wrote indicates that I think 20 Weatherford, a copy to Seth Weightman. Who is Seth 21 there would be four Senate seats that would elect a 21 Weightman? 22 Hispanic candidate in south Florida. 22 A Seth was a Republican Party of Florida 23 Q And you say you have both Larcenia and the 23 employee. 24 other seat both over 50 percent with just Dade and South 24 Q Worked alongside of you at the headquarters? 25 Broward. What are you talking about 50 percent? 25 A He worked for me. 31 (Pages 121 to 124) WWW.USLEGALSUPPORT.COM 954-463-2933 125 127 1 Q He worked for you. What did he do for you? 1 first paragraph of what he sends you and then he says, 2 A I am the head of House campaigns. 2 "I will try to call Meros today. I don't know if we 3 Q And he worked under you? 3 want to hand anything out at the meeting or not. It may 4 A Yes. 4 be better and safer to do it all verbally." 5 MR. KING: And so there is a redaction in 5 You see that? 6 that. You all know what that pertains to? 6 A I do. 7 MR. HEALEY: It was one of two things. It was 7 Q And so, is that what you decided to do? 8 either dealing exclusively with House district 8 A No. 9 issues or more likely was dealing with internal 9 Q Okay. So it was printed up? 10 Republican party matters not dealing with 10 A I believe that we printed out things that were 11 redistricting. 11 on the House website. 12 BY MR. KING: 12 Q Well, in your response, you say you agree on 13 Q All right. Number 2, you say there, "Don't 13 redistricting not to do handouts unless it's something 14 forget to ask Meros to prepare something for you for 14 already posted to on the House website. 15 8/9. I don't think we would want that included with our 15 Correct? 16 materials to be handed out. Correct?" 16 A That's what I appear to have written. 17 What does that refer to? 17 Q So you didn't want Mr. Meros -- or you and 18 A This refers to a meeting that we had on 18 Mr. Weatherford did not want Mr. Meros to do anything in 19 August 9th. 19 writing on redistricting that had not already been 20 Q What kind of a meeting? 20 posted on the House website, right? 21 A It was a meeting of Republican legislators. 21 A That seems to be correct. 22 Q Okay. And where was that meeting held? 22 Q Did you attend the August 9 meeting in 23 A I think it was held in Orlando. 23 Orlando? 24 Q Was that a public meeting? 24 A I believe I was there. 25 A It was a party meeting. 25 Q So even though you are not a legislator, you 126 128 1 Q So it was a private meeting? 1 can attend that meeting? 2 A I believe under the laws of the State of 2 A I helped put it together. 3 Florida, it would be considered a private meeting. 3 Q You were on the staff sort of that ran the 4 Q Okay. And what did you suggest to 4 meeting? 5 Mr. Weatherford that he needed Mr. Meros to prepare for 5 A That's my recollection. 6 him for that meeting? 6 Q Okay. Was Mr. Meros there? 7 A I believe that we were going to have a handout 7 A I believe he came. 8 from Mr. Meros explaining Amendment 5. 8 Q Did he make some sort of an oral presentation 9 Q Okay. That's what you understood it was going 9 about redistricting to the Republican legislators? 10 to be, a memo explaining Amendment 5? 10 A My recollection is that he spoke for about 11 A Yes. 11 ten minutes explaining Amendment 5. 12 Q Why did you say you didn't think you would 12 Q Okay. And how long did this meeting last? 13 want that included in the materials to be handed out? 13 A It probably lasted, I think part of an 14 A Well, I think I wrote that because our 14 afternoon. 15 materials were materials that the party was going to 15 Q Was Mr. Heffley there? 16 reproduce. And that material, if it came from 16 A I don't recall him being there, but I can't -- 17 Mr. Meros, I thought that maybe it would have to be 17 I certainly can't see why he would be invited. He 18 produced from another -- you know, maybe Mr. Meros would 18 didn't work for House campaigns. 19 produce it as opposed to us producing or reproducing it, 19 Q So you didn't see him, you don't know that he 20 rather. 20 was there? 21 Q Then Mr. Weatherford refers -- responds to you 21 A I don't believe he was there. 22 on August 2, 2011, correct? 22 Q Was Mr. Bainter there? 23 A It appears that he wrote to me at that time on 23 A Who? 24 that day. 24 Q Pat Bainter? 25 Q All right. Something is redacted from the 25 A Pat Bainter? I don't believe so. 32 (Pages 125 to 128) WWW.USLEGALSUPPORT.COM 954-463-2933 129 131 1 Q Was Mr. Reichelderfer there? 1 A I get to pretty much set my own hours. 2 A No, I don't believe he was. 2 Q Right. And do you remember what maps you were 3 Q So no consultants were invited? 3 working on until 4 o'clock in the morning? 4 A That's my recollection. 4 A Nope. 5 Q So it was just the people that worked for the 5 Q And your response to Mr. Johnson's draw them 6 Republican party and the Republican legislators? 6 up good, what was that? It's redacted. 7 A It would have just been only the Republican 7 MR. KING: Is there some explanation as to why 8 employees in my department, which is House campaigns 8 that's redacted? 9 would probably have been there, which is a small number 9 MR. HEALEY: It would have been something that 10 of folks. 10 did not deal with the drawing of maps, which is why 11 Q And it was only the House Republicans that 11 it was redacted. It's not being responsive to the 12 were there? 12 subpoena. 13 A That's who the invitees were there. 13 MR. KING: Okay. 14 Q Senators weren't invited? 14 THE VIDEOGRAPHER: We have three minutes left 15 A No. 15 on the tape. 16 Q And did Will Weatherford run the meeting? 16 MR. KING: Why don't you go ahead and change? 17 A I think so. 17 THE VIDEOGRAPHER: This is the end of tape 18 Q Is that something the speaker-designate would 18 number 3. We are now going off the record. It is 19 run as opposed to the speaker at the time? 19 1:41. 20 A Yes, that's correct. 20 (A recess took place from 1:41 p.m. to 21 (Exhibit No. 14 was marked for 21 1:46 p.m.) 22 identification.) 22 23 BY MR. KING: 23 24 Q I show you Exhibit 14 and ask you if you 24 25 recognize that as an e-mail string that ends up with an 25 130 132 1 e-mail on August the 2nd between you and Mr. David 1 CERTIFICATE OF OATH 2 Johnson? 2 3 A That's what it appears to be. 3 STATE OF FLORIDA ) 4 Q Who is David Johnson? 4 COUNTY OF LEON ) 5 5 A David Johnson is a political consultant in 6 6 Tallahassee. 7 7 Q Okay. And so was he involved in drawing maps 8 I, the undersigned authority, certify that 8 as well, sir? 9 the above-named witness personally appeared before me 9 A I am not aware of that. 10 and was duly sworn. 10 Q Okay. And so in your e-mail exchange with 11 11 him, you pointed out that you had been up until 12 WITNESS my hand and official seal this 12 4:00 a.m. drawing maps, just got to work at 10 -- at 13 16th day of June, 2013. 13 12:10 in the morning, right, on Tuesday? 14 NOTARY DD947789 EXPIRES: 4-18-14 14 A That's what I wrote. 15 /s/ Sandra L. Nargiz 15 Q Okay. And Mr. Johnson said draw them up good, 16 SANDRA L. NARGIZ, RMR, CRR 16 right? 1-800-934-9090 17 A That's what he wrote. 17 850-878-2221 18 Q Yeah. And, of course, his loyalties are the [email protected] 19 same as yours, right, Republican? 18 20 A He is a Republican consultant. 19 21 Q Right. And your employer was okay with you 20 21 22 coming in at 12:10 on Tuesday, right? 22 23 A Yes. 23 24 Q Because you had been up late drawing maps, 24 25 right? 25 33 (Pages 129 to 132) WWW.USLEGALSUPPORT.COM 954-463-2933 133 1 2 CERTIFICATE OF REPORTER 3 STATE OF FLORIDA ) 4 COUNTY OF LEON ) 5 I, SANDRA L. NARGIZ, Registered Professional 6 Reporter, certify that the foregoing proceedings were 7 taken before me at the time and place therein 8 designated; that my shorthand notes were thereafter 9 translated under my supervision; and the foregoing pages 10 numbered 1 through 133 are a true and correct record of 11 the aforesaid proceedings. 12 I further certify that I am not a relative, 13 employee, attorney or counsel of any of the parties, nor 14 am I a relative or employee of any of the parties' 15 attorney or counsel connected with the action, nor am I 16 financially interested in the action. 17 DATED this 16th day of June, 2013. 18 19 20 21 /S/ Sandra L. Nargiz 22 SANDRA L. NARGIZ, RMR, CRR Notary Public 23 1-800-934-9090 850-878-2221 24 [email protected] 25 1

ERRATA SHEET I have read the transcript of my deposition, pages through 133 and hereby subscribe to same, including any corrections and/or amendments listed below. DATE:______

PAGE/LINE CORRECTION or AMENDMENT REASON FOR CHANGE ______DATE OF DEPOSITION: 6-11-13 REPORTER: Sandi Nargiz

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WWW.USLEGALSUPPORT.COM 954-463-2933 137

IN THE CIRCUIT COURT OF THE REPRESENTING FLORIDA HOUSE OF REPRESENTATIVES: SECOND JUDICIAL CIRCUIT, IN AND FOR LEON COUNTY, FLORIDA RENE ROMO, et al., GEORGE N. MEROS, JR., ESQUIRE Plaintiffs, [email protected] vs. CASE NO. 2012-CA-00412 GRAY ROBINSON KEN DETZNER and PAM BONDI, P.O. BOX 11189 Defendants. ______Tallahassee, FL 32302 850.222.7717 THE LEAGUE OF WOMEN VOTERS OF DANIEL E. NORDBY, ESQUIRE FLORIDA, et al., [email protected] Plaintiffs, vs. CASE NO. 2012-CA-00490 FLORIDA HOUSE OF REPRESENTATIVES KEN DETZNER, et al, 422 The Capitol Defendants. Tallahassee, FL 32399 ______

VOLUME 2 REPRESENTING SECRETARY OF STATE: VIDEOTAPED (by telephone) DEPOSITION OF: FRANK TERRAFERMA ASHLEY DAVIS, ESQUIRE [email protected] TAKEN AT INSTANCE OF: The Defendants FLORIDA DEPARTMENT OF STATE DATE: June 11, 2013 500 S. Bronough Street Tallahassee, FL 32399 TIME: Commenced at 9:00 a.m. (by telephone) Concluded at 6:17 p.m. MICHAEL MAIDA, ESQUIRE LOCATION: 2894 Remington Green Lane [email protected] Tallahassee, Florida PO Box 12093 REPORTED BY: SANDRA L. NARGIZ Tallahassee, FL 32317 Certified Realtime Reporter 850.425.8124 Certificate of Merit Holder [email protected] (by telephone) VIDEOGRAPHER: DOUGLAS H. NARGIZ ELIZABETH FROST, ESQUIRE

136 138 APPEARANCES: 15 E-mail chain 140 16 E-mail chain 146 REPRESENTING PLAINTIFF: 17 8-3-11 Terraferma e-mail to Heffley 147 DAVID B. KING, ESQUIRE 18 8-5-11 e-mail with attachment 148 [email protected] 19 E-mail chain 154 THOMAS A. ZEHNDER, ESQUIRE [email protected] 20 E-mail chain 156 KING BLACKWELL ZEHNDER WERMUTH 21 8-8-11 Terraferma e-mail to 157 25 East Pine Street Heffley/Ginsberg Orlando, FL 32801 22 8-9-11 e-mail chain 159 407.422.2472 REPRESENTING DEPONENT: 23 8-10-11 e-mail chain 161 DANIEL C. BROWN, ESQUIRE 24 E-mail chain 163 [email protected] 25 10-11-11 e-mail chain 171 CARLTON FIELDS 26 215 S. Monroe Street 10-21-11 E-mail chain 178 Tallahassee, FL 32301 27 10-21-11 Heffley e-mail to Terraferma 188 850.224.1585 28 10-21-11 Terraferma e-mail to Heffley 189 29 E-mail chain 191 DAVID HEALEY, ESQUIRE [email protected] 30 10-25-11 E-mail chain 192 2846B Remington Green Circle 31 E-mail chain 196 Tallahassee, FL 32308 32 E-mail chain 201 850.222.5400 33 10-27-11 Heffley e-mail to Terraferma 204 REPRESENTING FLORIDA SENATE: 34 Terraferma e-mail to Ginsberg 205 35 E-mail chain 208 RAOUL G. CANTERO, ESQUIRE 36 10-28-11 E-mail chain 212 [email protected] WHITE & CASE 38 E-mail chain 217 200 S. Biscayne Blvd., #4900 39 10-29-11 E-mail chain 219 Miami, FL 33131 40 11-1-11 E-mail chain 220 305.995.5290 41 11-1-11 Terraferma e-mail to Heffley 222 42 11-1-11 E-mail chain 223 43 11-2-11 Terraferma e-mail to 229 Heffley/Reichelderfer Heffley/Reichelderfer 1 (Pages 135 to 138) WWW.USLEGALSUPPORT.COM 954-463-2933 139 140 44 11-2-11 E-mail chain 230 1 THE VIDEOGRAPHER: We are back on the record. 2 This is the start of tape number 4 and it is 1:46. 45 E-mail chain 233 3 (Exhibit No. 15 was marked for 46 11-2-11 Terraferma e-mail to Heffley 237 4 identification.) 5 CONTINUED DIRECT EXAMINATION 47 E-mail chain 238 6 BY MR. KING: 48 11-2-11 Terraferma e-mail 239 7 Q I show you, sir, Exhibit 15, and ask you if 8 you recognize that as an e-mail chain between you and to Reichelderfer 9 Mr. Heffley? 49 E-mail chain 241 10 A It appears to be an e-mail, that chain between 11 50 11-4-11 E-mail chain 242 Rich Heffley and I. 12 Q Now, you start down there with an e-mail that 51 11-10-11 E-mail chain 244 13 you sent to Mr. Heffley on August 2nd, right? 52 11-15-11 E-mail chain 245 14 A Yes. 15 Q And it says, "Subject: I checked with 53 11-20-11 E-mail chain 248 16 GoToMeeting and the forward thing should work up to ten 54 11-21-11 E-mail chain 248 17 people, so Ben's problem was not that." 18 What does that mean, sir? 55 11-21-11 Terraferma e-mail to Heffley 255 19 A I am not a 100 percent sure. 56 11-28-11 E-mail chain 256 20 Q What was the GoToMeeting? 21 A It looks like there was -- it looks like there 57 11-28-11 Terraferma e-mail to Rimes 257 22 was a meeting -- there was a meeting and it appears like 58 11-28-11 Terraferma e-mail to Heffley 258 23 there was a problem. 24 Q Were you trying to accept a video conferencing 59 E-mail chain 258 25 kind of a meeting with a bunch of people? 140 141 61 E-mail chain 261 1 A I said -- I don't recall doing that. 63 E-mail chain 263 2 Q And do you have any recollection of what Ben's 64 11-30-11 Terraferma e-mail to 264 3 problem was? Heffley/Reichelderfer 4 A I do not know, recall what his problem was. 5 Q Okay. And Mr. Heffley responds to you and 65 E-mail chain 266 6 says, "Strange. When are you sending -- send out new 66 12-21-11 Terraferma e-mail to Heffley 268 7 data and maps and are you sending me the block 70 1-20-12 Terraferma e-mail to 271 8 assignment files." Heffley/Reichelderfer 9 Do you see that? 71 E-mail chain 275 10 A Yes. 72 E-mail chain 276 11 Q Mr. Heffley was wanting to know when he was 73 1-21-12 E-mail chain 277 12 going to get more data and maps, right? 74 E-mail chain 279 13 A It could be surmised from what he wrote that 75 1-23-12 E-mail chain 280 14 that was what he wanted. 76 3-14-12 E-mail chain 281 15 Q All right. And could it also be surmised from 16 77 12-2-11 E-mail chain 284 that that you were basically supporting Mr. Heffley in 17 his efforts with mapping? 78 12-2-11 email 286 18 A I think that's an accurate statement. 79 E-mail chain 286 19 Q Okay. And when Mr. Heffley asked you about 20 the block assignment files, what do you understand the 21 block assignment files to be? CERTIFICATE OF OATH 290 22 A I believe that that's a way of me giving him a CERTIFICATE OF REPORTER 291 23 map. ERRATA SHEET 292 24 Q Okay. In what form does that take? 25 A I'm not sure. I mean, maybe dbf, but I am not 2 (Pages 139 to 141) WWW.USLEGALSUPPORT.COM 954-463-2933 142 144 1 sure. 1 MR. MEROS: Joe Negron. I object to form, 2 Q Well, you respond to him by saying, "We'll 2 leading. 3 definitely" -- I assume the d-e-f means definitely -- 3 THE WITNESS: No. 4 "we'll def send you block assignment files." Right? 4 MR. MEROS: Negron. 5 A That's what it appears that I have written. 5 MR. KING: I understand that. Is there 6 Q So you evidently knew what he was talking 6 something wrong with the way I said it? 7 about then, right? 7 MR. MEROS: Yeah, you keep saying Negron. 8 A I mean, I stated previously I think that this 8 MR. KING: Okay. Do you need to correct me 9 is a way, one way of giving him a map, is that I would 9 every time I mess up? Nobody else seems to, but 10 send him these block assignment files. But as I stated 10 you seem to be doing a wonderful job of it, George, 11 and I think that you all have seen in my e-mails, I had 11 and I appreciate that, but I am getting a little -- 12 a lot of technical issues, I had a lot of trouble with 12 if I get it wrong, just let me get it wrong, okay? 13 this software. So it appears I was attempting to give 13 You can correct me after we are through. Make a 14 him the maps that are referenced in this e-mail. 14 list. 15 Q So you were sending him one that night for the 15 MR. MEROS: This is also videotaped and -- 16 State Senate, right? 16 MR. KING: I understand. Right. I have been 17 A It says that "I can send that to you tonight." 17 very quiet about it through three depositions now. 18 Q Did you? 18 But at some point we've just got to let me blunder 19 A I don't recollect. 19 along as best I can. 20 Q And you indicated that you had just about 20 MR. BROWN: Did you answer that question? 21 finished one plan that you were going to name bikini, 21 THE WITNESS: Yeah, I was -- weren't we on an 22 right? 22 objection and maybe Mr. -- the attorney, if you 23 A Yes. 23 don't mind restating the question. 24 Q And you say "that's because of scant minority 24 MR. KING: Sure. Let's see what it looks like 25 coverage being provided to Collier and Hendry." 25 over here. 143 145 1 A That's what I wrote. 1 (The requested portion was read back.) 2 Q And why did you say that there was going to be 2 MR. MEROS: Object to form, leading. Go 3 scant minority coverage for Collier and Hendry? 3 ahead. 4 A That's a real good question. The Collier and 4 THE WITNESS: The answer is no. 5 Hendry being section 5 counties, based on the 2002 5 BY MR. KING: 6 redistricting, that those areas, once they are enjoined 6 Q You were very cognizant as to the effect of 7 in a minority district, that you really can't un-enjoin 7 what you were doing on both he and Ellyn Bognavich -- 8 them. But those areas also have large populations of 8 right? 9 white voters as opposed -- as well as smaller 9 A Bogdanoff. 10 populations of minority voters. 10 Q Bogdanoff, great. 11 So what I recollect that I was trying to do in 11 A Of course, when you are drawing districts, I 12 this map was to just have the more minority populations 12 mean, they all have an effect on one another. So I 13 in Collier and Hendry be in minority majority districts 13 mean, am I cognizant of the fact that you take 14 and having more white areas in those two counties not be 14 population from one and it affects another, absolutely, 15 in minority majority districts. 15 I would be cognizant of that. 16 Q Why are you talking about what Negron would 16 Q And you indicate that it's -- I won't use your 17 need from North Palm Beach County? 17 adjective, but you indicate the State Senate in 18 A I think this is kind of -- similar to what we 18 southeast Florida is really hard, huh? 19 just saw in one of the previous e-mails, that I still 19 A That's what I wrote, yes. 20 must have been having trouble drawing the districts, the 20 Q But again, you are just doing this for your 21 reference of missing or needing a hundred thousand 21 own pleasure, right? 22 people for Ellyn and Negron. I think that's a reference 22 MR. MEROS: Object to the form. 23 to that problem still ongoing. 23 Argumentative. 24 Q Isn't it correct that you are trying to draw a 24 THE WITNESS: I told you reasons why I draw 25 district that will protect Negron as an incumbent? 25 maps today. Would you like me to restate those? 3 (Pages 142 to 145) WWW.USLEGALSUPPORT.COM 954-463-2933 146 148 1 BY MR. KING: 1 August the 3rd, right? 2 Q That's okay. 2 A Yes. 3 A Okay. 3 Q I presume you are at work, right? 4 (Exhibit No. 16 was marked for 4 A Presumably so. 5 identification.) 5 (Exhibit No. 18 was marked for 6 BY MR. KING: 6 identification.) 7 Q Let me show you Exhibit 16 and you see where 7 BY MR. KING: 8 you have an e-mail exchange on August 3rd with Pat 8 Q Okay. Next, sir, I show you Exhibit 18 and 9 Bainter, right? 9 ask if you recognize that as an e-mail with attachment 10 A Yes, that looks like an exchange between he 10 that you received on August 5, 2011? 11 and I. 11 A That looks like an e-mail I received on that 12 Q And Pat asked you whether you have drawn 12 date, yes. 13 anything on CDs, right? 13 Q Now this comes from Xerox Alerts at RPOF.org. 14 A That's what he wrote. 14 What's that? 15 Q And you understand that to be the 15 A That's the scanner. 16 Congressional districts? 16 Q So your scanner to Republican Party of Florida 17 A According to reading this e-mail, I eventually 17 has sent you an e-mail. Did you cause it to do that? 18 understood that, but I didn't understand it at first. 18 A I don't recall specifically doing that, but in 19 Q Okay. You asked for clarification? 19 all likelihood I would have done that. 20 A That's what I wrote. 20 Q And why did you do it like that? I'm just -- 21 Q And what was his response? 21 A Probably so I would have them, these 22 A He responded "CONG DIST." 22 attachments in my e-mail stream. 23 Q And then that helped you understand what he 23 Q Okay. And can I see your exhibit just a 24 was talking about? 24 second? I just want to make sure. 25 A I wrote at the top that I first thought he was 25 A (Tendering.) 147 149 1 talking about CD-ROMs, but then I -- apparently reading 1 Q What do we have attached here, sir? 2 the e-mail, I came to understood it appears that he 2 A You are asking me what this is? 3 meant was really meaning Congressional district. 3 Q Yes, sir. 4 Q And was this exchange between you and 4 A 2338. 5 Mr. Bainter, was that an unusual exchange? 5 Q No, the question is, what is it? I understand 6 A I would say so, yeah. 6 the page number, but what is -- what are on these pages 7 Q You didn't hear from him very often? 7 that you sent to -- 8 A No. 8 A Right. I mean, all the pages or the first 9 Q Did you ever send him any of your maps? 9 page? 10 A I think that I did. 10 Q Well, maybe you can give me an overview for 11 Q And for what purpose? 11 all of them and then we can talk about an individual 12 A I don't recollect. If you have an e-mail, 12 page or two? 13 perhaps I would be able to recollect based on that. 13 A I am going to look at all of them first. 14 (Exhibit No. 17 was marked for 14 Q Sure, you do that. 15 identification.) 15 A (Examining document.) Okay. 16 BY MR. KING: 16 Q What do you think that is that you sent 17 Q I show you Exhibit 17 and ask you if you 17 yourself? 18 recognize that as an August 3, 2011 e-mail from you to 18 A It looks like a Congressional map. Well, 19 Mr. Heffley? 19 maps, plural. 20 A Yes, it appears that I was sending an e-mail 20 Q Okay. And whose handwriting is that on the 21 or that I sent this e-mail to Rich Heffley. 21 side of the maps? 22 Q And evidently you're letting him know that you 22 A That appears to be my handwriting. 23 are about to send him some State Senate plans, right? 23 Q Okay. So all of those things that are written 24 A That's in the subject line. 24 on these pages were written by you? 25 Q That's 1:30 in the afternoon on Wednesday, 25 A Presumably so. I don't recall doing that. 4 (Pages 146 to 149) WWW.USLEGALSUPPORT.COM 954-463-2933 150 152 1 But I mean, that appears to be my handwriting. 1 percentage in B. What is that? 2 Q Okay. And are those several versions of the 2 A I think it says "56 percent B." 3 same area? 3 Q Okay. That means 56 percent black? 4 MR. MEROS: You are talking about -- 4 A Probably so. 5 MR. KING: Of the same geographical area. 5 Q Okay. And then when you say on the side "too 6 MR. MEROS: You are talking about one page. 6 skinny," what are you referring to? 7 MR. KING: I am talking about the first 7 A It looks like a geographic connection. 8 two pages anyway. 8 Q Okay. Do you know what that is? 9 BY MR. KING: 9 A What do you mean? 10 Q Are those several versions of the same area? 10 Q I mean, do you know what geographic connection 11 A The first page is the Congressional districts 11 you are referring to there? 12 that were drawn in the Tampa area by the legislature in 12 A No. 13 the year enacted in 2002. 13 Q Okay. And then on page 4, what do you see? 14 Q Okay. And you know that just because you know 14 A Page 4 is kind of the southern part of Florida 15 it or is there something on the page that lets you know 15 peninsular. 16 that? 16 Q And the top part is the current map or was the 17 A I know it because I recognize it and I have no 17 current map at that time? 18 doubt whatsoever that that is the plan. 18 A Yes. 19 Q And then what -- on page 2, what are those? 19 Q And then the bottom half is a proposed map? 20 A Those appear to be Congressional maps in the 20 A The bottom half is -- yeah, is a map that's 21 same area, in the Tampa Bay area. 21 different than the current one. 22 Q Okay. Two different? 22 Q All right. And you drew that? 23 A They appear to be different. 23 A I think I did. Yeah. I believe so. 24 Q Two different views of the same area? 24 Q Okay. All right. Then what is the next page, 25 A That seems to be what it shows. 25 another e-mail to yourself that comes two minutes later? 151 153 1 Q Okay. And those were drawn by you? 1 A Yes. 2 A I believe they were. 2 Q And then does it have some more areas 3 Q Okay. And then if you turn to page 3, what 3 attached? 4 area is depicted there? 4 A Yes, there's more things attached. 5 A Page 3, the top is the greater south Florida 5 Q And then the page 1 behind that e-mail is -- 6 area as enacted by the legislature in 2002. 6 is that the current map or the current map at that time? 7 Q Okay. And you are centering there on the 7 A Just to be sure, what -- what do you call the 8 current Congressional District 23, right? 8 legal page numbers? 9 A That's one of the ones that's clearly in view. 9 Q 2330 is the one I am asking. 10 Q All right. And you've indicated that on the 10 A Okay. What's your question? 11 side of the page in your handwriting, right? 11 Q The question is that -- was that, at that 12 A Oh, yes, I did that. 12 time, the current map for that area for the Senate? 13 Q And then the second half of the page is the 13 A I think it is. Yeah, it looks -- it appears 14 same, is a proposed 23? 14 to be that it is. 15 A The second, the bottom of this page, page 3, 15 Q All right. So the first e-mail pertained to 16 is different districts in the area including 16 the Congress. Does the second e-mail pertain to the 17 District 23. 17 Senate? 18 Q Okay. 18 A It appears that way. 19 A But not exclusively District 23. 19 Q And again, where it refers to proposed 20 Q Right, but it says there proposed CD 23 in the 20 portions of the map, that's something you drew yourself, 21 side, right? 21 right? 22 A That is written there, yes. 22 A What -- are you referring to a specific page? 23 Q Okay. And does it indicate, I am trying to 23 Q When I see a page where it says proposed, like 24 see what you say under proposed CD 23, three counties, 24 on 2333? 25 and then under that, what is that, some number, 25 A Uh-huh. 5 (Pages 150 to 153) WWW.USLEGALSUPPORT.COM 954-463-2933 154 156 1 Q When it says proposed, is that something you 1 efforts, right? 2 have drawn? 2 A That's what he writes. 3 A I think I did. I don't recollect drawing it, 3 Q Okay. And you respond to him, his question 4 but I think it's possible that I did. 4 whether these are new maps, and you are saying you are 5 (Exhibit No. 19 was marked for 5 not sure, you think some are new, right? 6 identification.) 6 A Right. I wrote, "Not sure frankly." 7 BY MR. KING: 7 Q Then you wrote, "I think some new," right? 8 Q Okay. I show you Exhibit 19, and ask you if 8 A Right, that's what I wrote. 9 you recognize that as a chain of e-mails back and forth 9 MR. BROWN: I think you didn't mean to hand 10 between you and Mr. Heffley, again on August 8th? 10 this to the witness. I think that's yours. 11 A It appears to be an e-mail between Mr. Heffley 11 MR. KING: Cheat sheet. I was looking for it 12 and I. 12 right then. I appreciate you handing it back. If 13 Q All right. And did you author the e-mails 13 you stuck it under the table, I would have been in 14 that come from you there? 14 trouble. 15 A I don't recollect doing that, but I certainly 15 (Exhibit No. 20 was marked for 16 presume that I did send it, but I don't recollect that I 16 identification.) 17 did that. 17 BY MR. KING: 18 Q All right. So you indicate on August 8 to 18 Q Okay. I next show you, sir, Exhibit 20, and 19 Mr. Heffley that you are including, and it refers to 19 ask if you recognize that as a series of e-mails ending 20 State Senate, you are including a few current maps of 20 on August 9, 2011, between you and Mr. Hofeller? 21 south Florida, right? 21 A It appears to be between August 8 and 9th. 22 A That's what is written on this paper. 22 Q And actually down at the bottom of the page, 23 Q And you point -- and you say, "I figured it 23 those are the ones that we looked at on Exhibit 19, 24 was important for you to discuss the present situation 24 right? 25 soon before looking at new ideas. Hitting the road 25 A It appears that way. 155 157 1 soon. Catch you at 4 EST." Right? 1 Q And then on August 9, you let Mr. Heffley know 2 A That's what is written there. 2 that you sent him all the Senate dbfs so far, right? 3 Q All right. Why were you saying that you 3 A That appears to be what I wrote. 4 thought it was important for Heffley to discuss the 4 Q And you describe them as dbfs, why? 5 present situation soon? 5 A I think -- I don't know. I think dbf means 6 A Can you restate your question, please? 6 database format. 7 Q Why did you think it was important for Heffley 7 Q Okay. 8 to discuss the present situation soon? 8 (Exhibit No. 21 was marked for 9 A I don't recall sending this e-mail, so I am 9 identification.) 10 having trouble recollecting, you know, the meaning 10 BY MR. KING: 11 behind the words because this is, you know, pretty old. 11 Q I show you Exhibit 21 and ask if you recognize 12 Q Mr. Heffley responds by saying, "Are the maps 12 that as an e-mail of August 8, 2011 from yourself and 13 the same as I have or are there new ones? Thanks, 13 Mr. Heffley and Mr. Ginsberg? 14 Frank, for all your efforts, good stuff." 14 MR. BROWN: Hold on. This is marked as 15 You see that? 15 Exhibit 20, is that what you meant? 16 A Yes, I see that. 16 MR. ZEHNDER: 21. 17 Q So at that -- by that point, you had been 17 MR. BROWN: My mistake. 18 working on these maps at least from July through the 8th 18 BY MR. KING: 19 of August, right? 19 Q You see Exhibit 21 there, sir? 20 A I presume I had been drawing maps at that 20 A Yes, I have Exhibit 21. 21 time. It seems that way. 21 Q Okay. And that's something as you sent to 22 Q All right. And do you know how many maps you 22 Mr. Heffley and Mr. Ginsberg a scan of Congressional 23 had turned out by that time? 23 maps? 24 A No. 24 A It appears that I did do that. 25 Q Okay. But Mr. Heffley was pleased with your 25 Q All right. And so you are sending 6 (Pages 154 to 157) WWW.USLEGALSUPPORT.COM 954-463-2933 158 160 1 Mr. Ginsberg and Mr. Heffley the current -- page 1 of 1 if you recognize that as an August 9 e-mail chain with 2 that is the current Congress map for Tampa Bay, right? 2 Mr. Heffley? 3 A It appears that way. I don't recall doing 3 A It appears to be an e-mail from me to Rich 4 that, but it certainly seems that way. 4 Heffley. 5 Q And then page 2 are two possible 5 Q And he asked you on August 9, "Can you please 6 configurations for the same area in Tampa Bay; is that 6 send me the Congressional plan with the minority 7 right? 7 district for Castor. I can't find it. Thanks." 8 A It seems to indicate that. 8 Do you see that, sir? 9 Q Okay. And then on page 3 there is a current 9 A Yes, I see that. 10 Congressional District 23, right, at the top of the 10 Q And so you concluded that you hadn't sent it, 11 page? 11 but you sent it on to him when he asked for it, right? 12 A That's what it says at the top of the page. 12 A I say -- what I wrote here, and I don't 13 Q And on the bottom of the page, there is a 13 remember this e-mail, but what I wrote is that I, at the 14 proposed Congressional District 23, right? 14 moment said, "I will send now." 15 A It says proposed Congressional District 23. 15 Q Okay. And you did send it to him? 16 Q And actually we have seen that "too skinny" 16 A I don't recollect. 17 there before, right? 17 Q Okay. But you would want to help him and 18 A I believe that was in a previous exhibit that 18 support him, right? 19 we looked at. 19 A As I stated previously, I was helping him with 20 Q Okay. And then page 4 is the current Congress 20 a lot of his efforts. So if he asked me to do it, I 21 for the tip of -- the southern tip of Florida and then a 21 mean I certainly felt like -- my recollection of my 22 proposed Congress for that area, right? 22 interactions with him is I felt I could not do it if I 23 A It says that. What you stated is what is 23 chose not to, but my recollection was I was okay with 24 written. 24 helping him. 25 Q And for the proposed areas, those were areas 25 Q From time to time did he give you advice as to 159 161 1 that you drew, correct? 1 how he would like you to draw the maps? 2 A I believe I drew this. I don't recollect with 2 A I don't recollect anything specific that he 3 a 100 percent certainty that I did, but I suspect that I 3 may have told me. In the e-mails there may be some 4 did. 4 where he has some specific things in mind, but I don't 5 Q If you weren't drawing this as part of your 5 recollect off the top of my head that he gave me 6 job for the Republican Party of Florida, why would you 6 specific things that he wanted to do. I mean in terms 7 be sending these scans to Mr. Ginsberg? 7 of drawing. 8 A As I stated previously, I found this to be 8 (Exhibit No. 23 was marked for 9 immensely interesting, and I oftentimes found myself 9 identification.) 10 helping out Rich Heffley, so I believe that I was 10 BY MR. KING: 11 helping out Rich Heffley. 11 Q Let me show you Exhibit 23 and ask you if you 12 Q By sending it to Mr. Ginsberg? 12 recognize that as an e-mail chain between you and Will 13 A Well, the e-mail is sent to both persons. 13 Weatherford on August 10, 2011? 14 Q Right. 14 A This e-mail appears to be between me and Will 15 A Right. 15 Weatherford. I don't remember specifically sending it, 16 Q Okay. And you thought that was something Rich 16 but it does certainly appear to be an exchange between 17 wanted you to do? 17 us. 18 A I don't recollect him asking me to do that, 18 Q Now, you sent Mr. Weatherford a newspaper 19 but I suspect that he wanted me to do that. But I don't 19 article about a letter that had been sent to legislative 20 recollect that for sure. 20 leaders asking them to adopt a redistricting timeline 21 Q Okay. 21 that would result in votes on the new maps no later than 22 (Exhibit No. 22 was marked for 22 January 13, 2012, right? 23 identification.) 23 A That's what the article says that the timeline 24 BY MR. KING: 24 suggested by the groups, sets an October 3 deadline for 25 Q Next, sir, I show you Exhibit 22 and ask you 25 all potential redistricting plans to be submitted. 7 (Pages 158 to 161) WWW.USLEGALSUPPORT.COM 954-463-2933 162 164 1 Q And you sent that to Mr. Weatherford, right? 1 files is the way the Florida House wants public 2 A As I previously stated, it appears that I did 2 submissions, correct? 3 do that. 3 A That appears to be one of the things contained 4 Q And let's see Mr. Weatherford's chief of 4 in this e-mail. 5 staff, is that Kathy Mears? 5 Q And so your concern is how to convert a 6 A That's his current chief of staff now. 6 Maptitude plan into KMZ format, right? 7 Q All right. And then later, right after you 7 A That's what I wrote. 8 sent it, you sent another e-mail saying, "Yesterday 8 Q Because you have done all your plans on 9 Feeney was suggesting we set a deadline so when they 9 Maptitude, right? 10 don't submit anything, we call them on it." 10 A Yeah, they are, that's not necessarily related 11 Do you see that? 11 to this, but I drew plans in Maptitude. 12 A I see that. 12 Q And then you indicate that the reason you are 13 Q You sent that to Mr. Weatherford? 13 asking about this and how you can convert is because the 14 A It appears that I did. 14 Florida House and the House redistricting system wants 15 Q All right. And Feeney, who is Feeney, sir? 15 plans submitted as KMZ files, so that's why I am asking. 16 A I presume that's Tom Feeney, the former 16 Do you see that? 17 Speaker of the House. 17 A That appears to be what I wrote. 18 Q Okay. And you had a conversation with him? 18 Q And so you were trying to figure out how to 19 A I don't recollect having a conversation with 19 convert your Maptitude plans into KMZ, right? 20 him, but it appears that I did. 20 A I didn't write that. And it's not stated 21 Q In 2011, was he up here in Tallahassee working 21 here. 22 as a consultant or something? 22 Q Well, he is suggesting to you that you can buy 23 A I don't know. 23 Google Earth program and use it to do that, right? 24 Q But he was a former Republican Speaker of the 24 A He wrote that. 25 House? 25 Q And you said over here on the first page that 163 165 1 A Yes. 1 you haven't bought it yet, it's going to cost you $300, 2 Q And a former Republican Congressman? 2 but you will do it tomorrow, right? 3 A Yes. 3 A That's what I wrote. 4 Q Okay. And you sent his suggestion on to Will 4 Q So you were trying to get in shape where you 5 Weatherford and he says that would be a good idea, 5 could convert your programs, your Maptitude programs to 6 right? 6 KMZ programs, right? 7 A That appears to be what he wrote. 7 A I didn't write that here, and I don't recall 8 Q Okay. Did they set a deadline? 8 this e-mail, but I didn't -- I don't see anywhere here 9 A I believe the legislature had the deadline for 9 where it says that I want my map, anything I have in 10 submitting maps. 10 Maptitude into KMZ. 11 Q And wasn't that around November 1st? 11 Q Why would you guy this Google Earth program 12 A That's my recollection. 12 for $300 if it wasn't so that you could change your 13 (Exhibit No. 24 was marked for 13 Maptitude maps into KMZ files? 14 identification.) 14 A I don't recollect writing this e-mail, so it's 15 BY MR. KING: 15 hard for me to remember much more about other than 16 Q Next, sir, I show you Exhibit 24 and ask if 16 what's written here. 17 you recognize this e-mail about KMZ files that is dated 17 Q Well, what's written says that you are going 18 at the top August 27, 2011. 18 tomorrow, on August 25, to buy this program so you can 19 A I see this e-mail. 19 convert to KMZ files; isn't that right? Look at the 20 Q And did you author a number of the parts of 20 third e-mail from the bottom. 21 this e-mail chain? 21 A Right. I mean, yes, I see the third e-mail 22 A It appears that I did. 22 from the bottom. 23 Q And you are talking about, at the start of 23 Q That says, "I didn't buy yet. It's like $300. 24 this e-mail chain back on August 24, you talk to 24 Will do tomorrow." Right? 25 Mr. Diez at Magellan in Louisiana, that evidently KMZ 25 A That's what I wrote. 8 (Pages 162 to 165) WWW.USLEGALSUPPORT.COM 954-463-2933 166 168 1 Q So you had already been out pricing, 1 offer a plan, an alternative map under the name of Frank 2 evidently, the program, right? 2 Terraferma or the Republican Party of Florida, right? 3 A I don't really know why I knew that it was 3 MR. MEROS: Same objection. Go ahead. 4 $300, but that's what I wrote. 4 THE WITNESS: I don't know if we considered 5 Q Well, a plausible suggestion would be because 5 doing that or not. I don't recollect. 6 you checked to find out how much it would cost, right? 6 BY MR. KING: 7 A I might have done that. 7 Q All right. But what you did consider as 8 Q Yeah. And you say you are going to buy it 8 evidenced by that e-mail that you wrote was that you 9 tomorrow, right? 9 were making plans to get the Maptitude alternative maps 10 A It says that I will do tomorrow. 10 that you had done into form so that you could provide it 11 Q And you said, "I didn't do yet. Will buy 11 to the legislature, right? 12 tomorrow." Wouldn't you agree a plausible 12 A That's not written here. 13 interpretation of that is that you intended to buy it 13 Q So when you say that you are going to do 14 the next day? 14 ongoing conversions, that's moving them into KMZ, right? 15 A I don't remember writing this e-mail, so I 15 A I don't recollect why specifically, you know, 16 mean certainly someone could say that about this e-mail. 16 I never -- it's not stated in here that I wanted to 17 But -- but I don't recollect writing this. 17 submit anything to the legislature. Mark Reichelderfer 18 Q But then you say, after Mr. Diez says, "I 18 used the House software that required KMZ, so I think 19 don't remember paying that much, is there a free trial?" 19 maybe I wrote this because if I wanted to give a plan to 20 Then you say, "There is a free trial but we'll probably 20 Marc to look at, he -- only he didn't have Maptitude, is 21 need to do ongoing conversion, so I thought it was best 21 my recollection. He only used the House software and I 22 to just pay now." 22 think maybe Pat Bainter was only using the House 23 Do you see that? 23 software and the little bit I spoke with him and they 24 A I see that I wrote -- that is written here. 24 would need KMZ, is what I take from this. 25 Q So you had already checked the program out 25 Q Right. But when you look at the e-mail on the 167 169 1 enough to know that there was a free trial, right? 1 first page, what you said was that the reason you were 2 A I don't recall doing that. 2 talking about this, because the Florida House and the 3 Q Well, but obviously you did because you wrote 3 House redistricting systems wants plans submitted as KMZ 4 it down, right? 4 files; isn't that right, sir? 5 A Presumably you could deduce that, one could 5 A While it says that there, I don't recollect 6 deduce that. But I just don't recollect doing those 6 writing this e-mail. 7 things. 7 Q You don't say anywhere in this e-mail that you 8 Q And you planned to do it or try to get them 8 need to convert to KMZ files so you can provide them to 9 into KMZ files because you were planning on ongoing 9 Marc Reichelderfer, do you? 10 conversions, right? 10 A As I stated previously, I don't recall writing 11 A Yeah, it says ongoing conversions in the third 11 this e-mail and I don't recall the things that are on 12 block. 12 here. 13 Q Right. Because you were turning out all these 13 Q And, in fact, you ultimately got your 14 plans and you wanted to get them into KMZ files so you 14 Maptitude alternative maps into KMZ files; isn't that 15 could give them to the legislature when they needed 15 correct? 16 them, right? 16 A I don't think that is correct. 17 A No. 17 Q And why do you think that's not correct? 18 Q Well, you weren't going to offer them publicly 18 A I think there's other e-mails that indicate 19 and say that Frank Terraferma was proposing a plan, were 19 that I was never able to do that in my production, 20 you? 20 that -- I don't believe I ever was able to do that. 21 MR. MEROS: Object to the form, leading, 21 Q Let me show you Exhibit 20 and ask you if 22 argumentative. Go ahead. 22 you -- 23 THE WITNESS: Can you restate your question? 23 MR. MEROS: 20? 24 BY MR. KING: 24 MR. KING: Yes. Oh, I am sorry, this is 25 Q I said, you had no intentions at that time to 25 Heffley Exhibit 20. I apologize. 9 (Pages 166 to 169) WWW.USLEGALSUPPORT.COM 954-463-2933 170 172 1 BY MR. KING: 1 don't recollect writing it. 2 Q I am showing you Heffley Exhibit 20. This is 2 Q You see evidently on October 11, you say to an 3 another e-mail that wasn't in your production to us. Do 3 e-mail to Mr. Weatherford, "Did they give you heads up?" 4 you have any understanding why August 31, 2011 wouldn't 4 Do you know what you are talking about? 5 have been produced? Was that deleted? 5 A I think I was asking about the subject of that 6 A I have no idea why this e-mail would not have 6 e-mail. 7 been produced. 7 Q All right. The subject that Browning/SEC are 8 Q Okay. 8 attacking SEC of the VRA in court? 9 A I don't believe I deleted the e-mail after the 9 A Yes. 10 subpoena. I mean, I have no idea -- 10 Q What did you understand that subject matter to 11 MR. MEROS: Excuse me, you said August 31? 11 mean? 12 MR. KING: August 31, 2011. 12 A I think I recollected that the Secretary of 13 MR. MEROS: Am I looking at the wrong thing? 13 State had filed some sort of -- I remember reading in 14 MR. CANTERO: You've got 22. This is 22. 14 the newspaper that the Secretary of State had filed some 15 MR. KING: I am sorry, can you find 15 sort of a brief with the courts challenging the validity 16 Exhibit 20. Our bad. 16 of section 5 of the Voting Rights Act. 17 MR. CANTERO: You said that's August 22. 17 Q Okay. And Will Weatherford says, "Maybe Dean 18 MR. ZEHNDER: Maybe 22 has 20 in it. No, it 18 knew." 19 has 22 also. 19 A It appears that's what he wrote. 20 MR. KING: Let me pass it over to you and you 20 Q You know who Dean is, right? 21 all can look at it. 21 A Presumably it's the Speaker, the then Speaker 22 MR. MEROS: I guess I would like to have a 22 of the House. 23 copy of this sometime. 23 Q Dean Cannon? 24 MR. KING: Sure. Pass it down to them, too. 24 A Yeah. 25 25 Q Okay. Then you write back to Mr. Weatherford, 171 173 1 BY MR. KING: 1 that "Kirk P. was here meeting with Rich. They were 2 Q All right, sir. I have put in front of you 2 huddled on a computer. Congressional redistricting if I 3 Mr. Heffley's Exhibit 20 which appears to be an e-mail 3 had to guess." 4 from you to Mr. Heffley on August 31st, 2011; is that 4 You see that language? 5 right? 5 A I do. 6 A That appears -- this appears to be an e-mail 6 Q And would it be correct that Kirk Pepper is 7 that I wrote to Mr. Heffley. 7 who you were referring to as Kirk P.? 8 Q And you say, "Some friends with deep pockets 8 A I mean, presumably, yes. 9 want to help on redistricting, need to discuss more with 9 Q And you knew Kirk Pepper? 10 you." Do you see that? 10 A Not well. 11 A I do. 11 Q But you knew that he worked directly for Dean 12 Q What are you talking about? 12 Cannon, right, the Speaker of the House? 13 A I don't recollect that e-mail, that statement. 13 A My recollection is that he was the deputy of 14 Q Just don't have any recollection at all as you 14 chief of staff of the Florida House. 15 sit here about that? 15 Q Okay. And was he involved in redistricting? 16 A No. 16 A I am not a 100 percent sure. 17 (Exhibit No. 25 was marked for 17 Q Evidently he was on October 11, 2011, right? 18 identification.) 18 MR. CANTERO: Object to the form. 19 BY MR. KING: 19 THE WITNESS: If you read the e-mail, I was 20 Q All right, sir. I show you Exhibit 25 and ask 20 only speculating, and I would be speculating now, 21 you if you recognize that October 11, 2011 e-mail string 21 and I really don't recall this very well. 22 between you and Will Weatherford? 22 BY MR. KING: 23 A You are asking me if I recognize this? 23 Q Did you meet with Kirk Pepper on other 24 Q Yes. 24 occasions or see him in your offices on other occasions 25 A It appears to be something that I wrote, but I 25 where you thought he was working on redistricting? 10 (Pages 170 to 173) WWW.USLEGALSUPPORT.COM 954-463-2933 174 176 1 A I have a problem with your question, but -- I 1 Q What did he ask you about? 2 find it to be a compound question. Can you restate your 2 A My recollection is that he, on a couple of 3 question? 3 instances, had sent me some plans. I recollect that I 4 Q Sure. Did you have any other opportunities to 4 commented back to him on the plans and I don't recollect 5 see Mr. Pepper where you thought he was working on 5 what the specific comments were about the plans. But I 6 Congressional redistricting? 6 recollect speaking with him about some plans. 7 A I don't recall seeing him working -- I mean, I 7 Q All right. And do you remember what comments 8 don't recall seeing him during the duration of the whole 8 he asked you for on the plans that he sent you, the 9 legislative period. 9 Congressional plans? 10 Q Well, this was during the duration of the 10 A I think -- well, first of all, I am not sure 11 legislative period, right? 11 the plans he sent me, if it was Congressional. I know 12 A Other than this time, I don't recall seeing 12 he sent me for sure Senate, because I remember -- 13 him. 13 recollect e-mailing him about that. I have seen the 14 Q Okay. Did you know he had a close 14 e-mails, so that helped me to recollect the comments. 15 relationship with Marc Reichelderfer? 15 But -- so I don't recollect specifically if the plans 16 A No. I mean, I believe they are friends, but I 16 that he sent me were exclusively Senate, if maybe some 17 don't know the depth of their relationship. 17 were Congress. I think -- in fact, I think a couple, at 18 Q Did you see any of the Congressional plans 18 least one I can recollect him being about Congress. But 19 produced by the House redistricting committee before 19 I don't know where he got them from, or who the author 20 they were released to the public on December 6, 2011? 20 of those plans were. 21 A I don't think so. 21 Q Okay. And he didn't tell you where he got 22 Q Why do you say you don't think so? 22 them from or who the author was? 23 A Any plan that I saw, I don't know that it came 23 A Not that I recollect. 24 from the Florida House of Representatives. I mean -- so 24 Q And what kind of comments did he solicit from 25 that is why I am not sure. 25 you about the plans? 175 177 1 Q So you may have seen some Congressional plans 1 A He just asked me things like, well, what do 2 prior to December 6, but you didn't get them from the 2 you think of this or how does that look? 3 House of Representatives? 3 Q Okay. And how would you answer that or 4 A Well, the Senate released their plan, 4 respond to it? 5 Congressional plan, the week before, I recollect. 5 A I mean, I can't -- since I don't remember the 6 Q Senate released their plan on November 28th, 6 specific conversations, I just think I looked at it and 7 2011, correct? 7 looked to see if the county configurations looked -- if 8 A Yes. 8 they were breaking up too many counties, I might have 9 Q Had you already seen some House plans at that 9 said, oh, those counties are cut up too much. But other 10 point? 10 than that, I didn't spend much time with that at all. 11 A I don't recall seeing any plans that the 11 Q Did you look to see how his maps would perform 12 legislature -- that they released, I don't recall seeing 12 politically? 13 the legislature's plans before they were released on the 13 A I don't think so. 14 website. 14 Q Do you know? 15 Q Do you recall seeing any proposed 15 A Excuse me? 16 Congressional plans released by the House, that 16 Q Do you know for sure? 17 Mr. Reichelderfer had obtained before December 6, 2011? 17 A No. 18 A I recollect that Marc Reichelderfer on a few 18 Q Would it be correct to say that by October of 19 instances had sent me some plans and asked me about 19 2011, you had done the analysis on the prior elections 20 them. But I don't know who the author of those plans 20 so as new districts were proposed, you could, with 21 were. 21 Maptitude, determine how those districts had performed 22 Q I understand. He sent you Congressional 22 in prior elections? 23 plans, though, and asked you about how those plans would 23 A We had -- within the software I had the 24 perform, didn't he? 24 capability of doing -- looking at electoral results for 25 A No, that's not what my recollection is. 25 prior elections. 11 (Pages 174 to 177) WWW.USLEGALSUPPORT.COM 954-463-2933 178 180 1 MR. BROWN: You want to break? 1 were there? 2 THE VIDEOGRAPHER: We have three minutes. 2 A I don't recollect who all we met with. 3 MR. KING: How much? 3 Q Well, you don't remember anybody else besides 4 THE VIDEOGRAPHER: Three. 4 Mr. Ginsberg that you met with in Washington? 5 MR. KING: All right. Rather than starting a 5 A I mean, there may have been other people, but 6 new exhibit, let's just go ahead and take our break 6 I remember myself and Rich and Ben and Ben's wife 7 right now. 7 actually. 8 THE VIDEOGRAPHER: This is the end of tape 8 Q When did you leave Tallahassee? 9 number 4. We are now going off the record and it 9 A I don't recall. 10 is 2:43. 10 Q Did you leave on Friday? 11 (A recess took place from 2:43 p.m. to 11 A I stated I didn't recall. 12 2:58 p.m.) 12 Q Did you fly to Washington? 13 THE VIDEOGRAPHER: We are back on the record. 13 A I don't believe that I drove. Presumably, I 14 This is the start of tape number 5 and it's 2:58. 14 am sure that I flew. 15 (Exhibit No. 26 was marked for 15 Q All right. And did you carry some maps with 16 identification.) 16 you when you flew up there? 17 BY MR. KING: 17 A I don't recall. 18 Q I show you, sir, Exhibit 26 and ask you if you 18 Q Didn't you take maps with you when you went to 19 recognize that as an e-mail chain back and forth between 19 Washington with Rich Heffley? 20 you and Mr. Heffley on October 21, 2011? 20 MR. MEROS: Object to the form. Leading. 21 A It appears to be. 21 THE WITNESS: I stated I don't recall what I 22 MR. CANTERO: I am sorry, which one are you 22 had in my possession. 23 showing? 23 BY MR. KING: 24 MR. KING: Exhibit 26, e-mail exchange on 24 Q Wasn't the purpose to go and show the maps and 25 October 21, 2011. 25 discuss redistricting with Mr. Ginsberg? 179 181 1 BY MR. KING: 1 MR. MEROS: Object to the form. Leading. Go 2 Q Is that what you've got there, Mr. Terraferma? 2 ahead. 3 A I do, sir. 3 THE WITNESS: We might have spoken about 4 Q Okay. And it seems to start with an e-mail 4 redistricting. We probably did. I just simply 5 that you sent to Mr. Heffley on October 21, 2011 and the 5 don't recall the specifics of the meeting. 6 subject is "suit and tie Monday." What does that refer 6 BY MR. KING: 7 to? 7 Q Wasn't that the purpose of the trip, sir? 8 A I am not sure. 8 A Like I just stated, sir, I went to Washington, 9 Q Well, the text of the first message you write 9 we might have discussed redistricting. We probably did. 10 says, "Okay, around what time are you planning to get to 10 I just don't recall the specifics of the meeting. 11 Ben's house? And I will plan on getting there around 11 Q Did you have any other purpose to go to 12 the same time as you. The plan is to stay at his place 12 Washington other than redistricting? 13 on Sunday. Correct?" 13 A Like I said, I don't recall the specifics of 14 You see that? 14 the trip. Presumably it was about redistricting, but I 15 A Yeah. I mean, okay, now I see that and 15 am not a 100 percent sure. 16 presume that that means on Monday if I needed a suit and 16 Q Okay. But as you sit here today under oath, 17 tie, I think is what that means. 17 you can't think of another reason why you would have 18 Q Well, where were you going? 18 gone to Washington other than redistricting with 19 A I recollect that he and I went to Washington. 19 Mr. Heffley, right? 20 Q You and Mr. Heffley? 20 A I don't recall the specifics of the trip is 21 A Yes. 21 what I testified to. 22 Q Okay. And you went to Washington to go have a 22 Q How many times in 2011 did you go to 23 meeting with Ben Ginsberg? 23 Washington? 24 A That's -- I believe so. 24 A I think that was the only time, I believe. 25 Q Did you meet with some other people while you 25 Q Do you travel a lot in your work out of state? 12 (Pages 178 to 181) WWW.USLEGALSUPPORT.COM 954-463-2933 182 184 1 A Some. 1 recollection is that it was just -- I was just in 2 Q In 2011, did you? 2 Washington for one day. 3 A I don't -- I don't recall that trip that you 3 Q Okay. And one night? 4 are referencing. Or -- I mean, I can't recall other 4 A My recollection is that I was there just on 5 trips that I have taken for work. I travel a lot for 5 Sunday and Monday. 6 personal vacation and stuff. 6 Q Okay. 7 Q But you don't remember any other trips that 7 A I believe on Tuesday I did a presentation to a 8 you took for work out of state in 2011 other than this 8 trade group in Tampa, so that was the next day, is now 9 trip to Washington? 9 what I recollect, so I couldn't have been there more 10 A Well, I don't recall my itinerary throughout 10 than one day. 11 2011. I am just not sure. 11 Q Okay. And so did you and Mr. Heffley spend 12 Q So the only trip you can recall as you sit 12 the night, Sunday night, at Mr. Ginsberg's house? 13 here that you took in 2011 out of state for business was 13 A I believe that I just stated that I think that 14 this trip to Washington, right? 14 we did. 15 A That is the only trip I am recalling at this 15 Q Okay. And did the Republican party pay for 16 moment. 16 your plane transport to Washington and back? 17 Q But you are telling me that you just really 17 A I mean, I would presume that they did, but I 18 can't recall anything about the purpose of the trip 18 don't know for a fact. 19 other than it might have been for redistricting? 19 Q Well, I mean, you would know if you had to pay 20 A That is my testimony. 20 for it yourself, wouldn't you? 21 Q Had you ever been to Ben Ginsberg's house 21 A I mean, I believe that oftentimes, if I have 22 before? 22 an expense, a business expense, they will reimburse me. 23 A I don't think so. 23 I don't specifically recall being reimbursed by them. 24 Q Did you go by the headquarters of the 24 Q So you think you went up to Washington to meet 25 Republican National Party while you were in Washington? 25 with Heffley and Ginsberg on your own dime? 183 185 1 A I don't recollect. I don't think so, but I am 1 A Like I just stated, sir, I believe that I was 2 not sure. 2 reimbursed for this. 3 Q Wouldn't you remember it if you had been to 3 Q Okay. 4 the headquarters of the Republican party on the one trip 4 A I don't specifically recall the reimbursement. 5 you went out of town in 2011 for business? 5 I don't recall how much the reimbursement may have been 6 A I have been to the RNC on previous occasions, 6 for. I simply don't recall. 7 but I don't recall this trip if I visited the RNC. 7 Q But this was a business trip, correct? 8 Q Did you and Mr. Heffley go up together to 8 A Like I stated to you previously, I believe 9 Washington? 9 that I went to Washington, D.C., I believe I traveled by 10 A I don't recollect traveling with him. 10 myself, and that I told you I believed that we stayed at 11 Q Okay. But it sort of suggests that you didn't 11 Ben Ginsberg's house. I don't recall the specifics of 12 from this e-mail because you are asking when he is going 12 the meeting, is what I testified to. I mean presumably, 13 to get to Ben's house, right? 13 it probably -- we probably did discuss redistricting. 14 A I mean, you know, it could. I just -- I don't 14 Q You can't think of anything else you discussed 15 recall traveling with him. So I don't know that I could 15 with Mr. Ginsberg, right? 16 comment on that more than I just don't recollect 16 A It's presumable that we might have talked 17 traveling with him. 17 about campaign finance and stuff. I think that my 18 Q Right. And you say you will plan on getting 18 recollection is that there were some campaign finance 19 there around the same time as you, right? 19 issues going on at that time. 20 A That's apparently what I wrote. 20 Q Now, Mr. Heffley writes back to you on Friday, 21 Q Did you spend the night at Mr. Ginsberg's 21 October 21st, and says, "yes and yes, I double double 22 house? 22 checked." 23 A I believe that I did. 23 And did that refer to staying at 24 Q Okay. More than one night? 24 Mr. Ginsberg's house? 25 A No, I think it was just -- I think -- my 25 A I don't know. 13 (Pages 182 to 185) WWW.USLEGALSUPPORT.COM 954-463-2933 186 188 1 Q Okay. Then he says, "Look at the plans I sent 1 A That's what I wrote there. 2 you. Do you have anything new?" 2 Q All right. And a Senate 4 Hispanic that send 3 What's that referring to? 3 Garcia up through Broward, what does that mean? 4 A I would invite you to ask him. I am not sure. 4 A I presume that this would draw -- that this 5 Q Well, you got the e-mail and received it. You 5 indicates to me that there would be four Hispanic 6 knew what he was talking about, didn't you? 6 majority seats in Miami, in south Florida, Miami-Dade 7 A This e-mail is a year and a half ago. I 7 County area, that the district that would be represented 8 simply don't recall the specifics of this e-mail. It's 8 by -- Senator Renee Garcia would be Broward and have 9 quite a long time ago. I just don't recall. 9 section 5 areas. That's what this indicates to me. 10 Q Of course, you were talking about alternative 10 Q And while you were in Washington, did you get 11 plans for redistricting in Florida; isn't that correct, 11 any alternative plans approved by the Republican party? 12 sir? 12 A Like I stated previously, I don't really 13 A I don't see anywhere here where it says 13 recall much about that meeting. I think I testified as 14 alternative plans. 14 well that I don't think that I visited the Republican 15 Q Well, look at the next, the e-mail you write 15 party while I was in Washington. 16 back to him. You say on October 21st, "I was just 16 (Exhibit No. 27 was marked for 17 really going to play with shifting that Orlando seat a 17 identification.) 18 bit and we have the various plans that we've shown them 18 BY MR. KING: 19 too." 19 Q I show you Exhibit 27 which is also an e-mail 20 Isn't that what you said, sir? 20 from Mr. Heffley to you on that same day of October 21, 21 A That appears to be what I wrote. 21 2011, before you all went to Washington, and ask you if 22 Q Well, shifting the Orlando seat around, you 22 you recognize that as Mr. Heffley's e-mail to you? 23 are talking about alternative maps, aren't you, sir? 23 A It looks like an e-mail that Rich Heffley sent 24 A Alternative to what? I am not sure what you 24 to me. 25 are referring to. 25 Q And he says, "Could you please e-mail me the 187 189 1 Q Alternative to the current, the 2002 map. 1 file for that Senate plan. I want to play with the 2 Right? 2 non-VRA districts. Thanks." 3 A I am not sure that I -- I mean, that I agree 3 Do you see that? 4 with your use of the word alternative. 4 A I see that. 5 Q Well, proposed, would that work better for 5 Q Did you send it to him? 6 you, proposed map? 6 A I don't know. I don't recall. 7 A Clearly this is indicating that we are talking 7 Q What did you understand he meant when he said 8 about maps that I was probably helping Rich Heffley 8 he wanted to play with the non-VRA districts? 9 with. This is what this to me indicates. 9 A To me, VRA seems like the abbreviation for 10 Q Thank you, sir. And you refer to the fact 10 Voting Rights Act districts. 11 that "we have the various plans that we have shown them 11 Q So he wanted to make some changes to some of 12 to." 12 the ones that weren't VRA districts? 13 Now them is who, sir? Who have you shown 13 A That, you would have to ask him that. I don't 14 these various plans to? 14 know what his intentions were. 15 A I don't recall who we mean by it with them. 15 (Exhibit No. 28 was marked for 16 Q Then Mr. Heffley responds, "I want to try 16 identification.) 17 Senate 4 Hispanic that send Garcia up through Broward 17 BY MR. KING: 18 and gets the section 5 areas. Have you tried that?" 18 Q Now, next, sir, I show you Exhibit 28, and ask 19 You see that? 19 if you if recognize that as yet another e-mail that you 20 A I see that. 20 and Mr. Heffley exchanged on that Friday, October 21st, 21 Q And you indicate that you have tried that, 21 before your trip to Washington? 22 right? 22 A I presume I sent this e-mail to Rich. I don't 23 A It says here that I wrote to Rich Heffley, 23 recall specifically doing that, but it certainly looks 24 "Yes, we have." 24 like that I did send him this e-mail. 25 Q And that you can print it for him, right? 25 Q And you say as the subject matter, "Here is a 14 (Pages 186 to 189) WWW.USLEGALSUPPORT.COM 954-463-2933 190 192 1 .pdf of a south Florida map I started trying to take 1 A It looks that way. 2 Chris Smith to Collier/Hendry." 2 Q And then evidently on October 21st, that same 3 Do you see that? 3 Friday afternoon before your trip to Washington, 4 A Yes. 4 Mr. Heffley sent that to you, right? 5 Q And you say, "Never developed it much, but 5 A It appears that he did send me an e-mail, 6 thought I would share." Right? 6 presumably the attachment is still in that. But we 7 A That's what I wrote. 7 don't know that for a fact. 8 Q All right. And tell me who Chris Smith is. 8 Q Well, we know it, don't we, because it's in 9 A Chris Smith is a senator from Fort Lauderdale. 9 your documents. You produced it. You see? 10 Q Okay. And so does that mean that -- is he a 10 A It's part of -- okay. Well, as part of 11 Republican senator? 11 January 25th, it's indicated there is an attachment. 12 A No. 12 Q And you wouldn't have had it to pass on on 13 Q He is a democratic senator? 13 January 25 if you hadn't got it on October 21st, would 14 A Yes. 14 you? 15 Q And so you are going to try to move him into 15 A I mean, it's theoretically possible that -- 16 Collier/Hendry? 16 it's theoretically possible that it was not part of the 17 A I wrote that I was trying that, taking him to 17 October 21 e-mail, but presumably it was. I am not a 18 Collier/Hendry, and having him represent part of Collier 18 100 percent sure. 19 and Hendry County, yes. 19 (Exhibit No. 30 was marked for 20 Q Okay. And what did you think you could 20 identification.) 21 achieve by doing that? 21 BY MR. KING: 22 A My recollection is that the reason why I would 22 Q Next, sir, I show you Exhibit 30 and ask you 23 have been -- that I thought it might be necessary to try 23 if you recognize that as an e-mail chain between you and 24 that is those areas are voting -- section 5 of the 24 Mr. Bainter on October 25, 2011? 25 Voting Rights Act, that they had -- some of those areas 25 A It appears that this is an e-mail to which I 191 193 1 had minority representation and presumably whatever -- 1 was a receiver. 2 any plan that's passed would continue to have minority 2 Q Now, this evidently came on Monday, 3 representation. 3 October 24th, the day that you and Mr. Heffley are in 4 Q What district did Chris Smith represent at 4 Washington with Mr. Ginsberg, right? 5 that time in October of 2011? 5 A I don't even remember the date of that. 6 A I don't know what number he has or anything 6 Q We established that you were having e-mails 7 like that. 7 with Mr. Heffley on Friday afternoon, the 21st, and that 8 (Exhibit No. 29 was marked for 8 you were going to be in Washington on Sunday and Monday, 9 identification.) 9 right? 10 BY MR. KING: 10 A I will take your word for it. I don't 11 Q Next, sir, I show you Exhibit 29, and ask you 11 remember that. 12 if you recognize that document which has an attachment 12 Q So Mr. Bainter is suggesting that you all need 13 that includes the State Senate's members and 13 to meet, right? 14 residencies, resident addresses. 14 A He says, "Meet this week?" 15 A It looks like -- this looks like an e-mail in 15 Q Right. And you write back and say, 16 which I am part of the e-mail exchange. 16 "Wednesday-Friday is good for me." Right? 17 Q All right. And evidently down at the bottom 17 A That appears to be what I wrote. 18 on October 4, there was an e-mail from Mr. Bainter to 18 Q And then Rich -- then Bainter says that "Rich 19 Mike Sheehan asking him to do an .xls of the Senate 19 says he can do Thursday, which works for me. Who else 20 members' home addresses along with a Maptitude file for 20 should we bring in?" 21 overlay, right? 21 And you say, "Depends what agenda is. Not 22 A That's what is written. 22 trying to be smart but info here is a little vague." 23 Q All right. And then evidently on October 4, 23 Right? 24 Mr. Sheehan passed that information on to Mr. Bainter 24 A Yes. 25 and Mr. Ostrander, O-s-t-r-a-n-d-e-r, right? 25 Q Isn't it correct that when Bainter and Heffley 15 (Pages 190 to 193) WWW.USLEGALSUPPORT.COM 954-463-2933 194 196 1 were dealing with you about redistricting, everybody was 1 Q That would have been the 27th of October. 2 a bit cryptic in the e-mails that they were sending 2 A I just stated I don't recollect. 3 around about that? 3 Q Okay. So you just don't remember anything 4 MR. MEROS: Object to the form, leading, 4 about a meeting that Mr. Bainter and Mr. Heffley would 5 without foundation. Go ahead. 5 have wanted to have with you about redistricting 6 THE WITNESS: I wouldn't agree with that. 6 three days, three or four days after you got back from 7 BY MR. KING: 7 your Washington trip? 8 Q Okay. Well, this was so cryptic you were 8 A That's correct, I don't recall having a 9 saying you weren't clear about what he wanted to talk 9 meeting with Mr. Bainter. 10 about, right? 10 Q You don't remember anything about your 11 MR. MEROS: Object to the form, leading. Go 11 Washington trip, you don't remember when you got back, 12 ahead. 12 anything about your meeting with Bainter and Heffley, 13 THE WITNESS: I was unclear about what he 13 right? 14 wanted to meet about, yes. It's clear, I said I 14 MR. MEROS: Object to the form, argumentative. 15 didn't -- it's clear that I didn't recognize what 15 Go ahead. 16 he wanted to meet about. 16 THE WITNESS: I said I don't recall. I am not 17 BY MR. KING: 17 sure that I -- that there was such a meeting. It's 18 Q All right. And then he writes back and says, 18 all a possibility. We are looking together at this 19 "What we talked about on the phone. All getting 19 e-mail and I just don't recall if we had such a 20 together on a single idea so we can try to make things a 20 meeting. I had trouble recollecting this 21 bit smoother." 21 information then contemporaneously, and now it's a 22 I mean, that's -- he is trying to clue you in 22 year and a half later. 23 on what he is talking about, right? 23 (Exhibit No. 31 was marked for 24 MR. MEROS: Object to the form, leading, 24 identification.) 25 without foundation. Go ahead. 25 195 197 1 THE WITNESS: I mean, I was still not sure 1 BY MR. KING: 2 what he was talking about. I mean, I have a 2 Q Next, sir, I show you Exhibit 31, and ask you 3 question mark there above, I don't remember this 3 if you recognize this e-mail chain with Mr. -- between 4 e-mail now. I didn't even understand what it was 4 Mr. Terraferma -- you and Mr. Heffley? 5 then, let alone now. 5 A It appears to be an e-mail that Rich Heffley 6 BY MR. KING: 6 and I wrote between each other. 7 Q And, of course, then you finally figured out 7 Q Okay. And initially you wrote out, Siplin, 8 what he was talking about and you say redistricting, 8 Sanford-Orlando, VAP 40 percent black and 20 percent 9 right? 9 Hispanic. All on westside of Orange and Seminole. 10 A I wrote -- I can't remember. 10 These Hispanics -- is that don't? 11 Q Question mark? 11 A I believe it's a typo. 12 A I wrote, "I can't remember the phone call." 12 Q Don't effect the other seat? Is that what you 13 Q "LOL." 13 mean to say? 14 A Right. 14 A Yeah, don't. 15 Q Okay. And then, of course, he agrees that 15 Q Don't. Don't affect the other seat. 16 what he wants to talk about is redistricting, right? 16 And what are you talking about the other seat? 17 A He wrote, yes, I am not sure to what he was 17 Aren't you referring to -- strike that. 18 writing yes to. 18 What other seat are you referring to? 19 Q And did Mr. Bainter chide you about actually 19 A I am not sure what map we are talking about. 20 putting redistricting in the e-mail to him? 20 But I mean, presumably looking at this e-mail, that 21 A I don't remember him ever, quote, chiding me. 21 there's another Hispanic seat that these Hispanics don't 22 I don't recollect such a conversation. 22 affect. 23 Q Did you have your meeting on Thursday of that 23 Q Then Mr. Heffley says, "Great, I wonder if we 24 week? 24 ought to float the other one, too." 25 A I don't recollect. 25 Did you understand what that meant? 16 (Pages 194 to 197) WWW.USLEGALSUPPORT.COM 954-463-2933 198 200 1 A I don't know if I understood what it meant at 1 Q Right. You traveled with him to Washington -- 2 the time. 2 I mean, you met him in Washington, right? 3 Q Well, now, when it says float the other one, I 3 A That's my testimony, that we traveled to 4 mean, is that -- again, that's just something you and 4 Washington. 5 Mr. -- that's some kind of a code you and Mr. Heffley 5 Q All right. And did you ever ask him what are 6 have? 6 you doing with these maps I am producing for you? 7 MR. MEROS: Object to the form, leading, 7 A He never told me and I never asked him. 8 argumentative. Go ahead. 8 Q And so you just would continue to produce 9 THE WITNESS: I think you should best address 9 these maps for Mr. Heffley, but just had no idea what 10 that question to Mr. Heffley. I am not sure what 10 was going to happen to them? 11 he was writing there. 11 A That's what I just stated, that he didn't tell 12 BY MR. KING: 12 me and -- I never asked him and he didn't tell me. 13 Q And then you say, "Really wish they would go 13 Q Is he kind of a need-to-know kind of a guy, he 14 with JAX-Gville & Orlando/Daytona." Right? 14 just doesn't talk a lot about what he is doing? 15 A That's what I wrote or appear to have written. 15 A I am not even familiar with that term. I find 16 Q And what do you mean by that? 16 it confusing. 17 A I am not -- I am not sure. Looks like it's 17 Q Need to know? 18 talking about a district or districts. 18 A Yes. 19 Q Okay. And then Mr. Heffley says he thinks we 19 Q Okay. Well, does he keep information very 20 put that map out, too, right? 20 secure? 21 A That's what he apparently wrote. 21 A I don't know. I am not sure. 22 Q When you put the map out, where did you put it 22 Q Is he not a fellow -- 23 out to? 23 MR. BROWN: Let the witness finish answering 24 A I think, as you can see, I didn't respond to 24 the question. 25 that question because I am not sure what he meant then 25 MR. KING: Sure. 199 201 1 and I don't know what he means now. 1 BY MR. KING: 2 Q Well, you just said you just arranged to have 2 Q Go ahead. 3 you get together with him then, right? 3 A I think I was done. I am just not -- I don't 4 A I didn't respond to his statement about 4 feel like I could -- I don't feel like I -- those 5 putting -- quote, putting that map out, too. 5 descriptives are applicable here. I just don't know. 6 Q Right. So were you surprised when he talked 6 Q So, as you spent all this time with 7 about putting the map out, what that meant? 7 Mr. Heffley, lunches, trips, e-mails, telephone calls, 8 A I don't recall the e-mail now so I can't 8 Mr. Heffley always kept to himself what he was going to 9 really comment on whether or not I was surprised because 9 do with these maps that you were giving him? 10 I don't recall this. 10 A This is the third time you are asking me the 11 Q So you don't understand what he meant when he 11 same question and I will give you the same answer for 12 is talking about putting the map out? 12 the third time. 13 A That's -- I think that Mr. Heffley could best 13 He did not tell me what he was doing and I 14 answer his own -- speak for his own words. 14 just never asked him. So I just simply don't know. 15 Q Well, during this period of time, you are 15 (Exhibit No. 32 was marked for 16 continuing to support Mr. Heffley, right? 16 identification.) 17 A I assisted him. 17 BY MR. KING: 18 Q Yeah. And you are doing these maps for him. 18 Q Next, sir, I show you Exhibit 32, and ask you 19 Right? 19 if you recognize that as two e-mails between you and 20 A I mean, I assisted him, is what I just 20 Mr. Heffley? Do you see that? 21 testified to. 21 A Yes, I see that there's e-mails between Rich 22 Q Right. You assisted him by really working 22 Heffley and I. 23 hard at times on these maps, these proposed maps, right? 23 Q And the first one, the subject line on 24 A I assisted him, I worked -- I worked, whether 24 October 26 is "Here's a completed Congressional plan 25 you want to say I worked hard. I assisted him. 25 through Tampa, is far from perfect." Right? 17 (Pages 198 to 201) WWW.USLEGALSUPPORT.COM 954-463-2933 202 204 1 MR. MEROS: It says though, not through. 1 Q Okay. And you were also sending a copy of the 2 THE WITNESS: Yes. 2 map to Jim Rimes at the Republican Party of Florida? 3 MR. KING: Good point. 3 A It appears that I did do that. 4 BY MR. KING: 4 Q Why did you do that? 5 Q Let me read it again. "Here is a completed 5 A I don't recall. 6 Congressional plan, though Tampa is far from perfect." 6 Q And then the e-mail above refers to Jim's 7 Right? 7 e-mail, and then it has [email protected]. Is 8 A That's what it states, that's what it says. 8 that the same Jim that's in the copy line that you sent 9 Q So you sent Mr. Heffley yet another plan, 9 it to a different e-mail address? 10 right? 10 A I believe that Rich is indicating that there 11 A I am not sure if it's something different, or 11 is a different Jim e-mail. 12 maybe it's completely different, somewhat different. I 12 Q Okay. That you had the wrong, like the wrong 13 mean, I don't know -- a year and a half later I am not 13 e-mail? 14 sure what this is -- what this is getting specifically 14 A Presumably so, but I don't -- like I said, I 15 at. 15 don't recollect this. But I mean... 16 Q All right. You say, "Castor is Hill's 16 (Exhibit No. 33 was marked for 17 only" -- and put -- is that a smiley face? 17 identification.) 18 A No. 18 BY MR. KING: 19 Q What is that little round circle then? 19 Q All right. Then next, sir, I show you an 20 A It's -- 20 October 27 e-mail, which is Exhibit 33, and ask you if 21 Q Unhappy face? 21 you recognize this e-mail from you to Mr. -- from 22 A It's a frown face. 22 Mr. Heffley to you? 23 Q A frown face. I am sorry. I apologize. 23 A The e-mail, it looks like he sent me an 24 So why do you put a frown face by Castor is 24 e-mail. 25 Hill's only? 25 Q Right. And would it be correct that evidently 203 205 1 A Because -- I don't have a good recollection of 1 first Mr. Bainter had sent Mr. Heffley a Senate map and 2 this, but I think that I might have put a frown face 2 performance data, and Mr. Heffley has sent it on to you? 3 there because I think that that probably would be 3 A That appears to be the case. 4 against Amendment 6. 4 Q Okay. And attached to this is a visual copy 5 Q Okay. And then you say, "Another coming." 5 of the map and some performance data? 6 So you were working on yet another map? 6 A That appears to be -- that appears to be the 7 A Presumably so. I mean, I am not -- I don't 7 case. 8 recall this specific e-mail or map or whatever, but I 8 Q What, if anything, did you do with that 9 mean -- you know -- 9 information? 10 Q Now, were you -- as of October 26, were you 10 A I don't recollect even seeing this, so I don't 11 doing these maps because Mr. Heffley asked you to do 11 recollect doing anything with this. 12 them or were you doing them just for fun? 12 (Exhibit No. 34 was marked for 13 A Probably -- 13 identification.) 14 MR. MEROS: Object to the form. Leading, 14 BY MR. KING: 15 mischaracterizes his testimony. Go ahead. 15 Q Okay. Then I next show you, sir, Exhibit 34, 16 THE WITNESS: What's your question, please? 16 and ask you if you recognize that as an e-mail from 17 BY MR. KING: 17 yourself to Mr. Ginsberg with a copy to Mr. Heffley and 18 Q Were you doing the maps that you are referring 18 Mr. Bainter? 19 to here in the e-mail because Mr. Heffley asked you to 19 A It looks like it's an e-mail that I sent from 20 do that or -- and you were supporting him? That's the 20 me to Rich and to Pat Bainter -- I am sorry, to Rich -- 21 first question. 21 from me to Ben Ginsberg. 22 A The answer to the question is since I don't 22 Q Why are you sending the maps and performance 23 recall the e-mail, I don't recall the purpose. At this 23 data to Mr. Ginsberg? 24 point I could only speculate as to why I might have been 24 A I am not -- I am not sure. I would only be 25 helping him. 25 speculating if I gave you an answer. 18 (Pages 202 to 205) WWW.USLEGALSUPPORT.COM 954-463-2933 206 208 1 Q You mean you have no recollection as to why a 1 have to say a lesser amount of time on Congressional and 2 week after you -- or actually four days after you left 2 that I did this, as multiple e-mails indicate, I did 3 Mr. Ginsberg's house up in Washington, you don't have 3 this to help Rich Heffley out. 4 any recollection as to why you would be sending him this 4 Q Right, because Mr. Heffley was working on both 5 information on the statewide Senate plan? 5 the Senate and Congressional maps; isn't that right? 6 A I just stated I don't recollect why I sent 6 A You know, like I previously testified, he 7 this to him. 7 didn't tell me what he was doing with it and if he asked 8 Q Okay. So it attaches something called the 8 for my help, I just did it. 9 Schmedlov plan stats. S-c-h-m-e-d-l-o-v plan stats. Do 9 (Exhibit No. 35 was marked for 10 you know what that is? 10 identification.) 11 A That's apparently the name of this statistics. 11 BY MR. KING: 12 Q Did you name that? 12 Q Next I show you Exhibit 35 and ask you, sir, 13 A I don't remember. 13 if you recognize that as an e-mail chain that at least 14 Q Is that the name of a plan -- 14 has your name on two of the e-mails at the top of the 15 A I don't think that it's a name -- I don't 15 page? 16 know. I am not sure. I don't think it's the name of a 16 A My name, I think, only appears at the top of 17 plan that I have, but I don't recollect. 17 the page. 18 Q Did you prepare this plan? 18 Q Right. 19 A I am not sure. I can't really tell. 19 A Not two times. 20 Q Do you know -- and you don't know why you 20 Q Well, it actually appears twice, doesn't it? 21 would be sending it to Mr. Ginsberg? 21 A Okay. Yes. You are right. 22 MR. BROWN: Asked and answered. 22 Q Now, at the bottom of the page, Mr. Heffley 23 MR. KING: I think you are right. I won't 23 evidently on October 28 sends an e-mail to 24 even ask him to answer that. 24 MSheehan@Datatargeting and says, "Draft SO1 is the plan. 25 25 Thanks." 207 209 1 BY MR. KING: 1 Do you see that? 2 Q Did you prepare these statistics? 2 A That's apparently what he sent to Rich 3 A I might have. 3 Heffley. 4 Q Even though your job was the House, you spent 4 Q No, that's what Mr. Heffley sent to Sheehan, 5 a significant amount of time dealing with both Senate 5 right? 6 and Congressional maps, correct? 6 A Actually, yes, I was incorrect. 7 A I am not sure about the first part of your 7 Q Okay. Okay. And evidently there is an 8 question. Didn't seem like it was applicable to the 8 attachment that reveals that map, right? 9 second part of your question. But you asked me if I 9 A Appears that way. 10 spent time on Congress and Senate maps. It's a question 10 Q And then Mr. Sheehan sends Mr. Heffley an 11 you have asked multiple times today, and the answer to 11 e-mail saying, "Here are the resulting Maptitude files, 12 your question is, is that it does appear that I spent 12 unzip and open in Maptitude." 13 some time doing -- assisting Mr. Heffley with Senate, 13 Do you see that? 14 and to much less extent, some Congressional maps. 14 A Yes. 15 Q Well, your nominal job that you described 15 Q Then Mr. Heffley sends that to you, right, on 16 early on at the Republican Party of Florida was House 16 October 28? 17 campaigns, wasn't it? 17 A He appears to have done that. 18 A That's my job title. 18 Q And then you turn around and send it to Mike 19 Q Right. 19 Wild, right? 20 A Right. 20 A I appear to have done that. 21 Q So despite the fact that that's your job 21 Q Why did you do that? 22 title, you spent a lot of time on both Congressional and 22 A I don't fully recall, but I presume that we 23 Senate maps, right? 23 were trying to -- I was trying to help Rich do the unzip 24 A I just testified to the fact that I did, 24 and open. 25 indeed, spend some time on Senate and I think I would 25 Q Why would you send this map to Mike Wild, the 19 (Pages 206 to 209) WWW.USLEGALSUPPORT.COM 954-463-2933 210 212 1 deputy director for strategic analysis at the Republican 1 in mind, which was to help unzip and open this because I 2 National Committee? 2 don't believe -- and I know for a fact that I was very, 3 A Because as I testified previously, I don't 3 very good with this software, that I would be able to do 4 think I was that functional with the Maptitude software 4 this myself. And I believe that I was seeking technical 5 and I probably was seeking technical assistance. 5 assistance. 6 Q Do you say anything about seeking technical 6 (Exhibit No. 36 was marked for 7 assistance in your e-mail to Mr. Wild? 7 identification.) 8 A It doesn't say that. But -- 8 BY MR. KING: 9 Q All you did in the e-mail, anyway, was just 9 Q Next, sir, I'm going to show you Exhibit 36, 10 send out a map that Mr. Heffley had said is the plan to 10 and ask you if you recognize this e-mail which is a 11 Mr. Wild in Washington who's involved in redistricting 11 couple of e-mails back and forth between you and 12 for the Republican party nationwide, right? 12 Benjamin Ginsberg on October 28, right? 13 A My -- I don't recollect much about this, but I 13 A That looks to me like it's an e-mail between 14 believe I sent this to him in order to help accomplish 14 Ben Ginsberg and I. 15 what Pat had asked Rich who asked me to be able to open 15 Q So first, you send Mr. Ginsberg with copies to 16 it. And I don't believe I was capable of doing that. 16 Heffley and Bainter, the statewide Senate plan, right? 17 Q So Mr. Wild, the deputy director of strategic 17 A Well, you say "the" statewide Senate plan? 18 analysis, was going to help you open a map? 18 This just says statewide Senate plan. 19 A I believe if I asked him to help me with 19 Q Well, you all have agreed there on the 28th 20 something, that he would. 20 that you have got the plan, right? A draft that is the 21 Q Could just as plausible an explanation be that 21 plan, that's what Exhibit 35 says, doesn't it? Look 22 you sent it up there to him to so that he could approve 22 down at the bottom of Exhibit 35 where Mr. Heffley says 23 it? 23 draft S1 -- S01 is the plan, right? 24 MR. MEROS: Object to the form, leading. Go 24 A He wrote that to Mr. Sheehan. 25 ahead. 25 Q Right. And so, you all are sending that plan 211 213 1 THE WITNESS: I don't believe that. I don't 1 around that afternoon, aren't you? 2 believe that. 2 A It appears to be the same day. 3 BY MR. KING: 3 Q Right. So now you are sending the plan to 4 Q Because that would raise some questions that 4 Mr. Ginsberg, right? 5 you don't want to get into, wouldn't it? 5 A I apparently e-mailed it to Mr. Ginsberg. 6 MR. MEROS: Object to the form, leading, 6 Q Right. For his review, right? 7 argumentative. 7 A I am not sure why I sent it to him. 8 MR. CANTERO: Object to the form. 8 Q Again, you just can't remember why you would 9 THE WITNESS: I don't believe the RNC -- this 9 have sent it to Mr. Ginsberg? 10 is a State Senate map. I really don't think that 10 A I don't recall. It's over a year and a half 11 they care about the Florida State Senate. I don't 11 ago. I just don't remember why. 12 have any indication that -- I've never known them 12 Q Right. And is this plan, the plan that was 13 to be one -- want to know anything about the 13 the plan according to Mr. Heffley, is that the Schmedlov 14 legislative map. So I don't believe that was the 14 plan, is that the name of the plan? 15 reason why I sent that. 15 A I'm not -- you are asking me if this 16 BY MR. KING: 16 attachment is the same thing as this one right in the 17 Q You think they're only concerned in the 17 previous exhibit? 18 Congressional map? 18 Q All I am asking is, is the plan that you were 19 A As part of a national party, I believe that 19 sending out on the 28th, Exhibit 36, is that the 20 the national party tends to focus on national issues, 20 Schmedlov plan? 21 national races. 21 A Presumably -- I am not sure. I presume the 22 Q Why did you send a Senate map to Mr. Wild? 22 statistics here match the geographic display here as 23 A This would be the third time I've just 23 well. 24 answered your question. 24 Q This is the way it was produced from your 25 I believe I sent this to him with one purpose 25 file, do you see? 20 (Pages 210 to 213) WWW.USLEGALSUPPORT.COM 954-463-2933 214 216 1 A Do I see what? 1 saw? 2 Q Look at the numbers from your file, 123 2 A I am not sure. I thought in some of the 3 through 134. 3 production it said that he is sending me a map, but I am 4 A 123 through 134. 4 not 100 percent sure. 5 Q Right. 5 Q Did you ever see him -- or strike that. 6 A Right. 6 Did he ever indicate to you that he had the 7 Q We found it in your file. 7 skill with Maptitude to draw a map? 8 A This is in my production. 8 A I don't recall. I am not sure. 9 Q Yes, sir. 9 Q Did Mr. Bainter indicate that he had the skill 10 A Right. So I am not sure I understand what 10 to draw maps with Maptitude? 11 your question is. 11 A I hardly ever spoke with Mr. Bainter. I am 12 Q The question is: The e-mail, the visual 12 not sure what software he might have used. 13 depiction of the map, and the stats all go together, 13 Q Did Mr. Reichelderfer have the ability to draw 14 don't they? 14 maps on Maptitude or any other computer program? 15 A I presume that they do. 15 A I believe that, as I've testified previously, 16 Q Okay. And that's what you sent to 16 Mr. Reichelderfer, I believe, had drawn some stuff using 17 Mr. Ginsberg, right? 17 the State's software and I don't recollect him ever 18 A I believe that that's what I sent him. 18 telling me that he had purchased or knew how to use 19 Q And Mr. Ginsberg sent you something back about 19 Maptitude. 20 it, right? 20 Q Did you see any maps drawn on Maptitude by any 21 A Umm -- 21 of those fellows other than yourself? 22 Q Don't tell me, because it's redacted. But 22 A I am not sure, I don't recall if I saw other 23 there was something there, right? 23 maps. When I got -- if someone gave me a map, I 24 A Well, I needed to flip the page to look. 24 wouldn't inherently necessarily know what program it was 25 Q Sure. 25 drawn on. You've got to understand. 215 217 1 A There is something there and it is redacted. 1 MR. KING: Just so you know, I am skipping 37. 2 Q Okay. 2 Let's just move along. 3 MR. KING: And is that redacted because of 3 (Exhibit No. 38 was marked for 4 attorney/client privilege? 4 identification.) 5 MR. HEALEY: Sure. 5 BY MR. KING: 6 BY MR. KING: 6 Q I am showing you Exhibit 38, sir, and ask you 7 Q Did you draw the plan that is attached to 7 if you recognize that e-mail from Mr. Bainter to you at 8 Exhibit 36, sir? 8 the top dated October 31, 2011? 9 A I don't recollect for sure. It's possible, 9 A It appears to be an e-mail between Mr. Bainter 10 but I am not a 100 percent sure. 10 and I. 11 Q If you didn't draw it, did Mr. Bainter draw 11 Q All right. And you see on October 31st, down 12 it? 12 the page, Mr. Bainter responds to a redacted e-mail that 13 A Like I just stated, I am not sure if I drew 13 you wrote by saying -- sending an e-mail saying 14 it. I said that it's possible that I drew it. 14 regarding the statewide Senate plan, that he just needs 15 Q Among your group, who were the map drawers 15 to overlay the home addresses on this to make sure. You 16 among this association, loose association of political 16 see that? 17 consultants and the Republican party? Who could draw 17 A He e-mailed that to me and copied Rich 18 maps with Maptitude? 18 Heffley. 19 A Well, I am not sure I even agree with the 19 Q Right. And so then above that, again, you are 20 beginning premise of your question. I mean, I don't -- 20 asking Mr. Bainter to make it clear what he's asking 21 when you label a group, I mean, I certainly -- 21 you, right? 22 Q Okay. Let's don't even worry about that. Let 22 A Right. I was unsure what he was asking. 23 me just ask it more directly. 23 Q So you say, "Are you asking us to do something 24 A Okay. 24 specific? Just trying to be clear." Right? 25 Q Did Mr. Heffley ever draft any maps that you 25 A That's what I wrote. 21 (Pages 214 to 217) WWW.USLEGALSUPPORT.COM 954-463-2933 218 220 1 THE VIDEOGRAPHER: Three minutes left. 1 see? 2 BY MR. KING: 2 A Yes, that's what he wrote to me. 3 Q And then he says, "Yeah, was hoping you would 3 Q And you say for him to call your cell? 4 resend .pdf showing those incumbent homes." 4 A Yes. 5 You see that? 5 Q Did you tell him how to do it? 6 A I see that he wrote that. 6 A I don't believe so. 7 Q So about this statewide Senate plan that you 7 Q Did you tell him you couldn't do it? 8 all were getting approved there on the end of October, 8 A I didn't know how then and I don't know how 9 Mr. Bainter was wanting to see where the incumbent homes 9 today, so I don't believe that I would have been capable 10 resided on that map; isn't that correct? 10 of doing that. 11 MR. MEROS: Object to the form, leading, move 11 Q So your testimony is you told him that you 12 to strike the question. 12 could not do that? 13 MR. KING: You can go ahead and answer. 13 A My testimony is that I don't recollect 14 THE WITNESS: Can you restate the question, 14 speaking with him on the phone as the e-mail indicates, 15 please? 15 but I certainly don't believe that would be possible. 16 BY MR. KING: 16 (Exhibit No. 40 was marked for 17 Q Isn't it correct that Mr. Bainter was trying 17 identification.) 18 to find out where the incumbent homes would be on that 18 BY MR. KING: 19 statewide Senate plan? 19 Q I show you Exhibit 40 and ask you if you 20 A Since I don't recall the e-mail, all I can do 20 recognize that as an e-mail between you and Mr. Heffley 21 is indicate what he wrote. He says that he wanted 21 and Mr. Springer on November 1, 2011? 22 essentially a .pdf showing those incumbent homes. 22 A It appears to be an e-mail between myself, 23 Q Now, did you include the incumbent homes as 23 Rich Heffley, and Joel Springer. 24 you designed the statewide Senate map? 24 Q All right. And you say, "Took our map that we 25 A I don't recollect doing that. 25 are liking and cleaned up south Florida to just have the 219 221 1 THE VIDEOGRAPHER: We need to break. 1 Chris seat Smith. It is -- Chris Smith seat. It is 2 MR. KING: We'll take a break. 2 50/50 Broward/Palm." 3 THE VIDEOGRAPHER: This is the end of tape 3 Right? 4 number 5 and it is 3:00 p.m. 4 A That's what it says. 5 (A short recess took place from 3:00 p.m. 5 Q And so this map is a -- that you are talking 6 to 4:13 p.m.) 6 about is a Senate map? 7 THE VIDEOGRAPHER: We are back on the record. 7 A Based on the information present, I would 8 This is the start of tape number 6 and it is 4:13. 8 presume that it is. 9 MR. BROWN: Before the questioning begins, I 9 Q All right. And when you say "cleaned up south 10 would like to note for the record that 10 Florida to just have the Chris Smith seat," what does 11 Mr. Terraferma as finally succumbed to the heat 11 that mean? 12 long after, I would note, every lawyer in the room, 12 A I don't know. 13 except for one, who has taken their coats off long 13 Q And you say you have been playing with Orlando 14 ago. 14 and Daytona. You see that? 15 MR. KING: It's an appropriate decision. 15 A That's what I wrote. 16 (Exhibit No. 39 was marked for 16 Q Do you remember what you were trying to 17 identification.) 17 accomplish there? 18 BY MR. KING: 18 A I don't. 19 Q Okay. Sir, I show you Exhibit 39 and ask if 19 Q And then you ask them, you say, "Need to ask 20 you recognize that as an e-mail chain between you and 20 you some questions about what you want to see in terms 21 Jim Rimes of Enwright Consulting Group? 21 of other areas." 22 A It appears to be an e-mail between Jim Rimes 22 Do you see that? 23 and I. 23 A Yes. 24 Q And on October 29, 2011, Jim Rimes is now 24 Q So you want some more direction from 25 saying, "How do you make a KMZ in Maptitude?" Do you 25 Mr. Heffley and Mr. Springer about what they would like 22 (Pages 218 to 221) WWW.USLEGALSUPPORT.COM 954-463-2933 222 224 1 to see in the rest of the state, right? 1 one from you to Mr. Bainter and then the top one from 2 A I don't even recall this e-mail. Based on the 2 Mr. Bainter to Mr. Heffley with a copy to you on 3 line that you just read, one could surmise what you 3 November 1, 2011? 4 stated would be correct, but I don't recall the 4 A That appears to be correct, what you just 5 specifics of your e-mail, of this e-mail. 5 stated. 6 (Exhibit No. 41 was marked for 6 Q Okay. And in the first of those e-mails at 7 identification.) 7 the bottom, you say to Mr. Bainter, "It bounced back and 8 BY MR. KING: 8 I just saw it. The difference here between this one and 9 Q I show you Exhibit 41 which is an e-mail from 9 the previous (4:15/Sputnik2) is the way the black JAX 10 you to Mr. Heffley on November 1, 2011, and ask you if 10 seat is configured." 11 you recognize that? 11 You see that language? 12 A It appears to be an e-mail from me to Rich 12 A I do. 13 Heffley. 13 Q What are you talking about? 14 Q And you tell him as the subject line on 14 A It appears that this appears to be explaining 15 November 1, 2011, "Here are the stats," right? 15 the difference between this e-mail and a previous 16 A That's what it says. 16 e-mail. And -- 17 Q And you give him the stats for Schmedlov3.xls, 17 Q Is it the difference in a previous e-mail or a 18 the current Senate map, right? 18 previous map? 19 A The attachments are -- one of them has, it 19 A It's a good point. I am not sure. 20 appears, the statistics for this plan called 20 Q Isn't that -- Sputnik, isn't that a map? 21 Schmedlov 3, and the other attachment, part of it, the 21 A I believe that it is a map. 22 other attachment which is attached here indicates that 22 Q Okay. So the difference between this one, 23 this is the statistics of the current state of the 23 this one refers to a map, doesn't it, and the previous 24 current Senate seats. 24 Sputnik. Are we talking about two maps there? 25 Q Help me understand that then. So you have 25 A It appears that there -- that they are talking 223 225 1 both the Schmedlov stats and the current stats attached 1 about the difference between two maps, it appears that 2 here; is that right? 2 way. 3 A That's what it looks like. 3 Q All right. And who is the author of the 4 Q All right. And back in the back, it says at 4 Sputnik map? 5 the top, current Senate, and then in the front of the 5 A I am not entirely sure. It's possible that 6 attachment, it says Schmedlov 3, right? Schmedlov 3? 6 it's something that I worked on or drafted, but I am 7 A It says -- where -- 7 not -- I am just not sure at this moment. 8 Q Let me make it a little better. Page -- of 8 Q Did you attempt to file a map with the 9 the attachment, page 1 through 5 of the attachment, 9 legislature that day on November 1st? 10 first five pages are Schmedlov and then the second 10 A No. 11 five pages, pages 1 through 5, are the current Senate 11 Q When it says "it bounced back and I just saw 12 stats, right? 12 it," are you referring to somebody else's efforts to try 13 A That's correct. 13 to file a map? 14 Q And that's for the 40 Senate districts, right? 14 A If you see, look at the e-mail, I was 15 A These statistics have 40 seats in each 15 e-mailing Pat Bainter, and I e-mailed and it says that 16 statistics package. 16 this one didn't go through earlier. I believe that 17 Q Right. And again, is the Schmedlov 3 17 that's an e-mail to Pat Bainter. 18 statistics, is that for a map that you drew? 18 Q Right. What does it mean when it says, "This 19 A It might be. I just don't recall. 19 one didn't go through earlier, darn"? 20 (Exhibit No. 42 was marked for 20 A That -- I believe I was e-mailing Pat. 21 identification.) 21 Q You were. It shows you sent an e-mail to Pat 22 BY MR. KING: 22 with a copy to Rich. Right? 23 Q Next, sir, I show you Exhibit 42 which appears 23 A Yes. 24 to be an e-mail of November 1, 2011, and ask you if you 24 Q At 5:59 in the afternoon on November 1st. 25 recognize these as e-mails that went -- well, the bottom 25 Right? 23 (Pages 222 to 225) WWW.USLEGALSUPPORT.COM 954-463-2933 226 228 1 A Yes. 1 recognize that e-mail on November 1, 2011 from 2 Q And when it says this one didn't go through 2 Mr. Reichelderfer to you? 3 earlier, what are you talking about? 3 A It appears to be an e-mail from Marc 4 A I -- 4 Reichelderfer to me. 5 Q Is that the e-mail or something else? 5 Q And he is sending you a Senate map, right? 6 A I believe that the previous one that it 6 A That's what it appears to be. 7 references, it didn't go through was an e-mail to Pat. 7 Q Is that one he prepared? 8 Q Okay. Well, then what does it mean when Rich 8 A I mean, I believe so. I don't recollect this 9 says, "Should we try to get this submitted now"? 9 map or this e-mail, but it appears that he is sending me 10 A Rich says "may as well submit, the worst they 10 a map. 11 can do is not take it." 11 Q All right. And you indicated before that he 12 Q What does that mean? 12 was doing it on the Senate -- I mean, on the 13 A To me it appears that Rich was interested in 13 legislature's mapping program? 14 submitting something. 14 A That's my belief. 15 Q To who? 15 Q And that's why it looks like it's -- it has 16 A I would suggest that you would need to best 16 the House of Representatives redistricting committee 17 address that question to him. 17 language here on the map; is that right? 18 Q Well, you knew what was going on on 18 A Since I've never used that software, I can 19 November 1st, right? 19 tell you that maps that are drawn in that software would 20 A When you say what was going on -- 20 be printed out this way. I can't -- I just don't have 21 Q What these e-mails are about. 21 that knowledge. 22 A Right. Right. And I stated that it bounced. 22 Q Okay. And then you see the statistics that go 23 Q But what's being submitted and to whom is it 23 with this map, with Reichelderfer's name above them, 24 being submitted? 24 right? 25 A I don't recall what was being submitted and to 25 A I see the statistics attached. 227 229 1 whom. 1 Q So did that cause you to think that 2 Q Well -- 2 Mr. Reichelderfer had prepared this map? 3 A My recollection of this e-mail is that 3 A It appears to me that he did, but I simply 4 something that we, me, probably had sent to Pat, had 4 don't have knowledge of that. I just simply don't know. 5 been returned. 5 Q You had evidently talked about it with him, 6 Q Okay. So you are not -- you don't think this 6 right? 7 has anything to do with the submission of maps through 7 A I mean, because it says "per our 8 the public process to the legislature on November 1, 8 conversation"? 9 2011? 9 Q Right. 10 A I am not -- I don't have firsthand knowledge 10 A I mean, that's what it says, but I don't 11 of that. It's certainly possible and it certainly 11 recall this conversation. 12 appears that way, but I don't have that firsthand 12 Q What did you do with this map that he sent 13 knowledge. 13 you? 14 Q Because I think we previously discussed, to 14 A You are back on Exhibit -- 15 your knowledge, none of your -- the maps you drew were 15 Q 16. 16 ever submitted in the public process to the legislature, 16 A -- 16? 17 right? 17 Q From Reichelderfer's deposition. 18 A I testified that I did not submit a map as -- 18 A I am not sure. 19 to the -- as we stated, to the legislature, right. 19 (Exhibit No. 43 was marked for 20 Q And you are not aware of Mr. Bainter 20 identification.) 21 submitting a map or Data Targeting submitting a map, are 21 BY MR. KING: 22 you, sir? 22 Q Next I show you Exhibit 43 and ask you if you 23 A I don't have knowledge that they did that. 23 recognize that as an e-mail you sent on November 2, 24 Q Next, sir, I show you Exhibit 16 to 24 2011, to Rich Heffley and Marc Reichelderfer. 25 Mr. Reichelderfer's deposition and ask you if you 25 A It appears to be an e-mail from me to Rich and 24 (Pages 226 to 229) WWW.USLEGALSUPPORT.COM 954-463-2933 230 232 1 Marc. 1 mean redecoupling?" 2 Q And you say as the subject, "Its variation to 2 A That's what I wrote. 3 Sputnik2. 3 Q Well, what do you mean? 4 A That's what is stated there. 4 A I didn't know. I don't know. It's very vague 5 Q And there is a one-page attachment, right? 5 language. I am not sure what he meant. 6 A It appears that way. 6 Q Are you all talking in some sort of code here? 7 Q That's pretty difficult to make anything out 7 MR. MEROS: Object to the form, leading, 8 of, right? 8 argumentative. 9 A It's not easy to discern what this is. 9 THE WITNESS: Not a code that -- there is no 10 Q Right. But it says here, "Changes in 10 code that I know of. I don't speak in code. 11 northeast Florida; all else same. Thoughts." 11 BY MR. KING: 12 Was that something you did? 12 Q What did you understand decoupling to mean? 13 A I presume that it is, but I just don't 13 A Well, as you can see, I put a question mark by 14 remember. 14 the word decoupling because I don't know what he meant. 15 Q When it says variation to Sputnik2, does that 15 Q And then he says in response to your question, 16 refresh your recollection that you did Sputnik2? 16 "Correct. WW asked him to change." 17 A It does not do anything for my recollection. 17 What does that mean? 18 (Exhibit No. 44 was marked for 18 A I am not sure. 19 identification.) 19 Q Well, WW would be Will Weatherford, wouldn't 20 BY MR. KING: 20 it? 21 Q Next, sir, I show you Exhibit 44 and ask you 21 A It certainly is an indication that could be 22 if you recognize that as an e-mail chain between you and 22 referencing him. 23 Mr. Heffley on November 2nd? 23 Q And ask him. Who is him, do you know? 24 A It appears that way. 24 A It says "WW asked him to change." I don't 25 Q And do you see a reference that you make to 25 know who him is. 231 233 1 Mr. Heffley down at the bottom on November 2, "Noticed 1 Q And when he says asked him to change, is that 2 there is a new dropdown on Senate website indicating 2 to change the new dropdown on the Senate website? 3 received before/after deadline." 3 A Sir, I don't know. This e-mail was cryptic to 4 Do you see that? 4 me. It was unintelligible to me then and it's 5 A Yes. 5 unintelligible to me now. 6 Q What were you talking about there? 6 (Exhibit No. 45 was marked for 7 A It appears to me that I noticed on the Florida 7 identification.) 8 Senate's website that there was some sort of a 8 BY MR. KING: 9 notification on the website about indicating if a plan 9 Q Next, sir, I show you Exhibit 45 and ask you 10 was received before or after the deadline. This is what 10 if you recognize that as some more e-mails between you 11 reading this e-mail means to me. 11 and Mr. Heffley on November 2nd, 2011? 12 Q Okay. Then Mr. Heffley responds to this by 12 A It appears to be e-mails between Rich Heffley 13 saying, "Yes, I am still tying to kill it." 13 and I. 14 What does that mean? 14 Q All right. And actually this is in reference 15 A As you can tell in the line above, I was 15 to this earlier e-mail that you exchanged with 16 rather perplexed. I didn't know then and I don't know 16 Mr. Heffley, Exhibit 43, right? Because Exhibit 43 17 now. 17 repeats -- is repeated at the bottom of Exhibit 45, 18 Q First, Mr. Heffley says, "Yes, I am still 18 right? 19 trying to kill it," and then, "We are not decoupling 19 A It certainly appears that way. 20 today." 20 Q All right. And then Mr. Heffley responds to 21 Do you see that? 21 your e-mail asking him for his thoughts and he says, "I 22 A I do. 22 want to do a perfect fix of the 4H plan, too. We need 23 Q Do you know what he meant by decoupling? 23 to do a little rebalancing for performance." 24 A I didn't and I don't. 24 Do you understand what that means? 25 Q And then you say in response, "Congress? You 25 A If you look at the next line it was clear that 25 (Pages 230 to 233) WWW.USLEGALSUPPORT.COM 954-463-2933 234 236 1 I didn't understand what he meant. I asked him a 1 those areas of the plan, right? 2 question because it was unclear to me what he meant. 2 A He seems to indicate that that's what he wants 3 Q When he talks about fixing the 4H plan, what 3 to have done. 4 was the 4H plan? 4 Q All right. And you say you will discuss it 5 A I am not 100 percent sure. 5 when he gets there, huh? 6 Q Are we talking about Congressional plans or 6 A Yes, that's what I wrote to him. 7 Senate plans or House plans? 7 Q And did you all rebalance the plans when he 8 A It's my belief that it would probably be a 8 got there? 9 Senate plan, but I am not sure. 9 A Unfortunately, I don't remember even writing 10 Q So do we have a Senate plan that was called 10 this e-mail. I certainly don't remember meeting with 11 the 4H plan? 11 Rich specific to anything referenced in this e-mail. 12 A I am not sure. 12 Q You don't have any reason to believe that you 13 Q And Mr. Heffley is saying we need to do a 13 didn't meet with Rich about the matters listed in the 14 little rebalancing for performance. You know what that 14 e-mail, do you? 15 means, don't you? 15 A It's certainly possible that we did not meet. 16 A That's what he wrote. 16 Q But it's also probable you did meet, right? 17 Q Right. You know what that means, don't you? 17 A I wouldn't say probable. 18 A I didn't know what it meant, so I asked him a 18 Q So you are saying the last e-mail you write 19 question. 19 is, "Okay, let's discuss when you get here." And so now 20 Q Rebalancing for performance would be to change 20 you are going to suggest to us that the meeting never 21 lands to improve performance, wouldn't it? 21 occurred? 22 A It could be interpreted that way. 22 A What I am going to suggest is oftentimes we 23 Q So you say you would like all four to equal 23 say let's meet with different -- not only with Rich, it 24 the McCain/Scott kind of thing, right? 24 could be with anyone, let's meet and then it just 25 A That's what I -- that's what it appeared to 25 doesn't work out; someone gets delayed, someone gets on 235 237 1 have written to him. 1 a phone call. You know, there's just various reasons 2 Q McCain/Scott, that's a reference to two 2 why these types of ad hoc meetings may or may not occur. 3 separate elections, right? 3 So I am not sure if we met at that date, later that day. 4 A Presumably. 4 (Exhibit No. 46 was marked for 5 Q That's a reference to the way the vote 5 identification.) 6 performed in those two elections, right? 6 BY MR. KING: 7 A Can you restate your question? 7 Q I am going to show you Exhibit 46 which is 8 Q I mean, that's a reference to the way the 8 another document from the same day and ask you if you 9 voting performance was in those two elections, right? 9 recognize that as an e-mail passing between you and 10 A It could be interpreted that way. 10 Mr. Heffley that same afternoon on November 2nd? 11 Q That's the way you meant it, wasn't it? 11 A It appears to be an e-mail from me to Rich 12 A I don't recall writing this e-mail, but what 12 Heffley. 13 you stated certainly is a plausible explanation. But 13 Q Now, this says -- this refers to Sputnik3.jpg, 14 again, I don't recall writing this e-mail at this time. 14 right? 15 Q And you are asking him that if he would like 15 A That's what it says in the attachment. 16 all four -- are you referring to four separate plans? 16 Q Is that yet another plan you had done? 17 A My interpretation of 4H might be four 17 A I am not sure. 18 Hispanic, but I am not a 100 percent sure. 18 Q You don't remember anything about this one 19 Q You are asking him you would like those four 19 either? 20 to equal the McCain/Scott kind of thing, right? 20 A It could simply be a variation of something 21 A That's what I wrote to him. 21 else, but I don't have a good recollection of this. 22 Q He says back, "Not necessarily equal, but not 22 Q Now, this would appear to be a Congressional 23 losing as much strength for Garcia and Flores," right? 23 plan, wouldn't it, or would it? 24 A That's what he wrote. 24 A It appears to me that this is a State Senate 25 Q So, he's wanting you to change performance in 25 plan. 26 (Pages 234 to 237) WWW.USLEGALSUPPORT.COM 954-463-2933 238 240 1 Q Okay. Senate plan. 1 Exhibit 48 and ask you if you recognize that as an 2 A Yeah. 2 e-mail from you to Mr. Reichelderfer that afternoon 3 Q And you say, "This has Marion into three 3 regarding any three variations? Do you see that? 4 instead of four." 4 A I see the e-mail that you have. 5 A That's what it says. 5 Q Okay. And why are you sending that to 6 Q And is that something you had been asked to do 6 Mr. Reichelderfer? 7 by Mr. Heffley? 7 A I don't recall. 8 A I don't recall. 8 Q Now you refer to among these Sputnik3; is that 9 (Exhibit No. 47 was marked for 9 yet another alternative map in addition to Sputnik1 and 10 identification.) 10 Sputnik2? 11 BY MR. KING: 11 A Well, I am not sure of your characterization 12 Q I show you Exhibit 47 and ask you if you 12 of alternate, but it's -- it's an attachment that has 13 recognize that? 13 some maps attached to it. I am not sure what else to 14 A I see this is an e-mail exchange between Rich 14 say. 15 and I. 15 Q I mean, during this time you appeared to be 16 Q Let me just see your exhibit one, second. 16 churning maps out at a rapid rate, didn't you? 17 A (Tendering.) 17 A I don't remember it. It does seem like there 18 Q All right, sir. Do you see down at the bottom 18 are a lot of maps with my name attached to it, but I 19 Mr. -- the second from the bottom Mr. Heffley asked you, 19 mean, you know, that's then. This is now. 20 "Did you do Sputnik1 data, et cetera, I didn't get it, 20 I mean, I don't -- just because there's some 21 thanks." 21 every couple of days doesn't mean that there's this 22 Do you understand what that means? 22 tremendous number of maps or something, I mean. And 23 A Reading this, he is saying that he didn't get 23 because one map may be sent to the same person on the 24 something that he thought he was supposed to get 24 same day, it may make it look like there is more than 25 apparently, it seems like. 25 there are. I just don't really recall. 239 241 1 Q Your response is, "This is the one with the 1 Q By early November, 2011, isn't it correct that 2 stringy south Clay, JAX-Gville connector," right? 2 this redistricting work that you were doing was pretty 3 A Yes, I was unclear apparently, as I was 3 much the major thing you were spending your time on for 4 reading this made me believe I was unclear there as I am 4 the Republican party, right? 5 unclear now about this. 5 A I don't recollect that. These e-mails are 6 Q Now it refers to Sputnik1 data and the subject 6 just a small window, I think, into other things that I 7 line refers to maps, data, and dbf of Sputnik2. Is that 7 had to do as part of my job. 8 two separate plans? 8 (Exhibit No. 49 was marked for 9 A I don't recall. I'm not even sure -- can you 9 identification.) 10 restate the question? I am sorry. 10 BY MR. KING: 11 Q It refers to Sputnik1 and in the subject line 11 Q I show you Exhibit 49 and ask you if you 12 it refers to Sputnik2. Is that two separate plans? 12 recognize this e-mail string between you and 13 A Where does it say Sputnik1? I am sorry, I 13 Mr. Heffley? 14 don't see that. 14 A I see it's an e-mail potentially between Rich 15 Q Mr. Heffley's question to you, d-u-d, you do 15 Heffley and I. 16 Sputnik1 data, et cetera? 16 Q And do you see that it refers to something 17 A Okay. I see that. 17 called 143 Coastal? 18 Q Is that two separate maps? 18 A Yes, I see that. 19 A It might be, I am not sure. 19 Q Is that a map you prepared? 20 Q Did you do both of them; did you draw both? 20 A Mr. Johnston is the originator and sent it to 21 A I am not sure. 21 Rich Heffley and Pat Bainter. I don't believe that I 22 (Exhibit No. 48 was marked for 22 created this map, but I mean, I don't really recall. 23 identification.) 23 Q You think Mr. Johnston created it? 24 BY MR. KING: 24 A I would be -- I mean, I am just not sure who 25 Q Next, sir, again on November 2, I show you 25 created it. I don't think I did. 27 (Pages 238 to 241) WWW.USLEGALSUPPORT.COM 954-463-2933 242 244 1 Q Okay. 1 things just to critique for him. 2 (Exhibit No. 50 was marked for 2 Q And that's what you did? 3 identification.) 3 A On a couple of instances, I did look at 4 BY MR. KING: 4 something he sent me and I gave him my thoughts and 5 Q Next, sir, I show you Exhibit 50 and ask if 5 opinion. 6 you recognize that document? 6 Q Did you know what he was going to do with it? 7 A I see this document is a document of an e-mail 7 A No. 8 between Marc Reichelderfer and myself. 8 (Exhibit No. 51 was marked for 9 Q On November 4, 2011, right? 9 identification.) 10 A Yes. 10 BY MR. KING: 11 Q And Mr. Reichelderfer has asked you to look at 11 Q I show you Exhibit 51 and ask you if you 12 a map, right? 12 recognize that exhibit as some November 10 e-mails 13 A He wrote "look at this one." 13 between you and Mr. Reichelderfer? 14 Q And you respond by saying, "Looks good other 14 A It appears that way. 15 than shafting Polk. I suspect JD and Paula would 15 Q And you sent Mr. Reichelderfer something at 16 object. Also do you think Galvano would want to be in 16 the bottom and say, "Let me know if this works." 17 the open Jones seat?" 17 Do you see that? 18 Do you see that? 18 A It seems to be the original thing in this 19 A I do. 19 e-mail. 20 Q Who is Galvano? 20 Q Right. And then Reichelderfer responds by 21 A Galvano is a -- at this time was a former 21 saying, "Look at this." Right? 22 House member. 22 A That's what he appears to have written. 23 Q Former Republican office holder? 23 Q And he must be attaching something to this, 24 A Former Republican State House membership, 24 right, these e-mails? 25 former at the time of this e-mail. 25 A I am not sure. 243 245 1 Q And the open Jones seat would be what? Is 1 Q You are looking at something, aren't you? 2 that a House seat or Senate seat? 2 A I mean, presumably so, but I don't think there 3 A I believe that's an open Senate seat. 3 is an attachment here. 4 Q Okay. And why were you speculating about 4 Q And then you say, "It definitely looks better, 5 whether he would want to be in that seat? 5 I don't like the fact that Clay was lost to rural 6 A I think my recollection of this is that Marc 6 counties." Right? 7 had from time to time, I think in this instance had 7 A That's apparently what I wrote. 8 asked me to look at something he was sending me and just 8 Q And then Marc's response to that is, "It still 9 asking me about it. 9 performs very well," right? 10 Q All right, sir, I show you next a November 4, 10 A That's what he wrote. 11 2011 e-mail that's been marked as Exhibit 17 in 11 Q And you knew what that meant, right? 12 Mr. Reichelderfer's deposition and ask if you recognize 12 A No, I am not sure what that means. I don't 13 that? 13 know what it is. 14 A I don't. It appears to be an e-mail between 14 Q Didn't you think that that meant that the map 15 Marc Reichelderfer and I, but -- 15 performs well for Republicans? 16 Q Now, he evidently has revised the map that he 16 A I am not -- I mean it is a very -- it's a 17 had sent you before, right? 17 pronoun and it's very nondescriptive. 18 A I mean, it says "I think this is better." I 18 (Exhibit No. 52 was marked for 19 don't recall what he is comparing it with. But it 19 identification.) 20 certainly could be interpreted as a comparison, but I am 20 BY MR. KING: 21 not sure. 21 Q I show you, sir, Exhibit 52, and ask if you 22 Q And do you know why he was sending that to 22 recognize that document as a November 15, 2011 e-mail 23 you? 23 exchange between you and Mr. Heffley? 24 A Like I stated in the last exhibit, from time 24 A It appears to be an e-mail exchange between 25 to time it's my recollection that he had sent me some 25 us. 28 (Pages 242 to 245) WWW.USLEGALSUPPORT.COM 954-463-2933 246 248 1 Q And then you say there that, here's the info, 1 from Collier, Hendry? 2 and you provide a HefNonRetro.zip. What is that? 2 A If the goal was to give a Hispanic candidate 3 A A zip file perhaps. 3 or Hispanic voters the ability to elect a candidate of 4 Q Okay. And that shows what you were attempting 4 their choice, I think that that would have been 5 to convey to him about a map? 5 something to have been considered in terms of what Rich 6 A The zip file presumably contains the map, the 6 and I were doing. And I am saying this based on this 7 attachment in this case. 7 e-mail. 8 Q Okay. And you say, "The HISP seats are 32, 8 Q Okay. 9 34, 38, and 40. All 50 or over for Scott and McCain." 9 (Exhibit No. 53 was marked for 10 Is that right? 10 identification.) 11 A That's what I appear to have written. 11 BY MR. KING: 12 Q You had analyzed those proposed seats and then 12 Q All right, sir. I show you Exhibit 53 and ask 13 checked the performance data on them, right? 13 you if you recognize that as an e-mail chain you had 14 A I mean, I don't remember, you know, the 14 with Rich Heffley on November 20, 2011? 15 specifics of this e-mail or of this map. 15 A It appears to be. 16 Q Well, you wouldn't have just made that up, 16 Q And down at the bottom, Mr. Heffley sends you 17 would you? 17 an e-mail on November 20, 2011 and says, "Did you look 18 A I mean, I believe it's just a statement of 18 at those maps." Right? 19 fact that I was telling Rich about. 19 A That's what he wrote. 20 Q Right. But I mean, you had to go and look at 20 Q Do you know what he was talking about? 21 your data to be able to make that statement of fact, 21 A I do not. 22 didn't you? 22 Q Did Mr. Heffley call you? 23 A Certainly I would have to look at something to 23 A I don't recall if he did or not. 24 get that information. 24 (Exhibit No. 54 was marked for 25 Q And evidently you did that and made that 25 identification.) 247 249 1 statement of fact, right? 1 BY MR. KING: 2 A That's what it appears to be. 2 Q Next I show you Exhibit 54 and ask if you 3 Q Then you say, "Section 34, which has the three 3 recognize that as an e-mail chain, two e-mails between 4 section 5 counties, has a plurality of white registered 4 you and Mr. Heffley on November 21? 5 voters though HISPs are a close second." Right? 5 A It appears to be an e-mail between Rich 6 A That's what I wrote. 6 Heffley and I. 7 Q And you checked that out, right? 7 Q Now, on this e-mail, November 21, 2011 at 8 A I presume that I looked at the statistics and 8 3:52 a.m. you send Mr. Heffley an e-mail and you say, 9 saw that that number 34 has three section 5 counties. 9 "CDs are on your chair." Right? 10 And it was a plurality of white voters, registered 10 A That's what is written there. 11 voters. 11 Q When you say CDs are on your chair, are you 12 Q And then you said, "I think it is best to 12 saying a CD that you had to put in a machine that would 13 separate Monroe from Collier/Hendry to avoid that." 13 have information on it was in his chair, or are you 14 Right? 14 saying that the Congressional districts were on his 15 A That's what I wrote. 15 chair? 16 Q And what were you avoiding? 16 A I believe that this is referring to a CD, like 17 A I think, looking at this e-mail today, I 17 a CD-ROM. I am just surmising that from reading this 18 suspect that it was to be able to have four districts 18 right now. 19 with a majority of Hispanic registered voters presumably 19 Q All right. And you say, "One of them, 20 with Monroe, Collier, and Hendry being a vast majority 20 number 8, has a problem and can't be uploaded." Right? 21 of white registered voters, by having all those counties 21 A That's what I wrote. 22 in one district, that it would lessen the Hispanic 22 Q "The other one, number 4, I downloaded the 23 percentage in the districts that they were connected 23 political data and called it as such along with 24 with. 24 everything on the CDs." 25 Q So you thought it was best to separate Monroe 25 You see that? 29 (Pages 246 to 249) WWW.USLEGALSUPPORT.COM 954-463-2933 250 252 1 A That's what I wrote. 1 A That is correct. I don't know these specific 2 Q All right. And then you say, "Maybe we should 2 CDs, so I mean, I am not familiar with them. But the 3 all it the Lazarus seat instead." You mean call it? 3 ones that I put on his chair, I mean I am not even sure 4 A I believe that's the word. The letter C is 4 which ones they were. But I don't have -- I put them on 5 omitted. 5 his chair. 6 Q "Otherwise, looking good. Except why the 6 Q Why did all of a sudden you download political 7 Margolis seat is still there is beyond me. That seat 7 data and put it on a CD-ROM and take it by hand over to 8 should have been abolished ten years ago! TTY 8 Mr. Heffley's office and leave it in his seat? 9 tomorrow." Right? 9 A I believe that he -- it's my recollection that 10 A That's what I wrote. 10 I think he asked me to download something to look at it, 11 Q Now, did you keep copies of those CD-ROM? 11 and I gave it back to him, is looking at this is what I 12 A The e-mail here says that the CDs are on 12 think happened here. 13 Rich's chair. 13 Q I mean, you transferred information back and 14 Q Right. 14 forth by e-mail to Mr. Heffley for months without ever 15 A So I don't have that. 15 putting anything on a CD-ROM, right? 16 Q You didn't keep copies? 16 A I don't know that that's been an established 17 A No. 17 fact. I think there were references... 18 Q So you left him with Rich Heffley? 18 Q Had you provided him CD-ROMs before? 19 A Yes. 19 A I am not sure. I mean, you previously stated 20 Q Do you know what he did with them? 20 that that did or didn't happen. I simply don't recall. 21 A I have no idea. 21 Q The only time you can recall leaving the 22 Q And what was on them? 22 CD-ROMs or giving him information by CD-ROM was on 23 A I think reading this e-mail, it says one of 23 November 21st? 24 them is a number 8 and then there is a number 4 24 A At this moment, that would be correct. Maybe 25 according to the e-mail. 25 there are other e-mails that indicate that I had done 251 253 1 Q So you think there were two CD-ROMs? 1 something with a CD with Rich prior. I am not sure if 2 A I don't really recall. 2 we -- we may have already gone through an e-mail that 3 Q Well, you refer one of them, number 8 has a 3 mentioned a CD. I don't really recall from this long -- 4 problem; the other, number 4. Are you suggesting there 4 this period, this long ago. 5 are two of them there? 5 BY MR. KING: 6 A I don't remember this e-mail. Everything we 6 Q I show you Exhibit 55 -- 7 discussed about this so far is just from me reading 7 MR. CANTERO: Before you get there, it's 5:04. 8 this. 8 MR. KING: Okay. Can I get about -- a couple 9 Q And evidently you had downloaded political 9 more exhibits? 10 data and put it on the CDs? 10 MR. CANTERO: Yeah, no. I am just letting you 11 A Reading that first line, I downloaded the 11 know. 12 political data. It says what it says. I don't recall 12 MR. BROWN: Let's go off the record for a 13 this e-mail or this, doing this stuff. 13 second. 14 Q Have you ever seen those e-mails since you 14 THE VIDEOGRAPHER: Hang on. 15 left them on -- strike that. 15 (Discussion off the record.) 16 Have you ever seen those CDs since you left 16 (A recess took place from 5:07 p.m. to 17 them on Mr. Heffley's chair? 17 5:25 p.m.) 18 A I don't believe so. 18 THE VIDEOGRAPHER: We are back on the record. 19 Q Maybe I just assumed you left them on his 19 This is the start of tape number 7 and it is 5:25. 20 chair. I don't know. Did you actually leave them on 20 BY MR. KING: 21 his chair? 21 Q All right, sir. I want to show you, 22 A It says here, "CDs are on your chair." So I 22 Mr. Terraferma, Exhibit 33 to the deposition of Marc 23 mean, unless I didn't know what I was writing on 23 Reichelderfer. And I realize you are not listed on 24 November 21st, I presume that I left them on his chair. 24 this. I just want to ask you a question about the last 25 Q And you've never seen them since? 25 statement that is made which is an e-mail from Dean 30 (Pages 250 to 253) WWW.USLEGALSUPPORT.COM 954-463-2933 254 256 1 Cannon to Marc Reichelderfer with a copy to Kirk Pepper. 1 question is, sir: Do you recognize that e-mail from 2 And it says, "Well, as long as the Senate accommodates 2 Mr. Heffley on November 21, 2011? 3 the concerns that you and Rich identified in the maps 3 A This e-mail before me is from me. 4 that they put out tomorrow, then we are in fine shape. 4 Q I mean from you to Mr. Heffley. 5 How confident are you that they are going to do that?" 5 A It appears to be an e-mail from me to Rich 6 Did you ever discuss with Rich the map that 6 Heffley. 7 the Senate was putting out that -- before they put it 7 Q And now you are referring to something called 8 out publicly? 8 "Heffley8PolyData." What is that? 9 A I am not -- I don't have any recollection of 9 A I mean, I would only -- I am not really sure. 10 this e-mail. I am not even sure what map is being 10 I mean it looks like data both political and geographic 11 referred to. 11 or statistical data. 12 Q You remember that the Senate released their 12 Q Is that the data behind yet another map? 13 maps on November 28, right? 13 A It might be. I really don't know off the -- 14 A I believe that I know that as a fact. I don't 14 just looking at this e-mail, I am not sure. 15 recall that specifically, but -- 15 Q Did you draw that map, sir? 16 Q Okay. 16 A I don't know. 17 MR. CANTERO: Just for clarification, the 17 Q Mr. Heffley's name is on the map. Did he tell 18 Senate released their Senate map or their -- 18 you what to draw for that map? 19 MR. KING: Their maps. 19 A I don't recall. 20 MR. CANTERO: Both? 20 Q That's a Senate map, right? 21 MR. KING: Yes, both Congressional and Senate, 21 A The fact that there's 40 districts would 22 I think. I am just asking him. 22 indicate that it's a Senate map. 23 BY MR. KING: 23 (Discussion off the record.) 24 Q And -- 24 (Exhibit No. 56 was marked for 25 MR. MEROS: Okay, I am not sure you're correct 25 identification.) 255 257 1 on that. But go ahead. 1 BY MR. KING: 2 BY MR. KING: 2 Q Okay. Sir, now I show you Exhibit 56 and ask 3 Q Okay. 3 you if that e-mail string on November 28, 2011, confirms 4 A It's my recollection that maps were released 4 that those Senate maps were released on November 28? 5 by the Senate on the 28th. I am not sure which kind, 5 A It indicates to me that, it indicates to me 6 but that definitely seems to be. 6 that this is a reference to the Senate plan being 7 Q At any rate, the question is: Did you and 7 released, they are up. 8 Rich have the opportunity to review those maps before 8 Q And you are indicating that you are having a 9 they were issued publicly? 9 slight problem with the Senate plans, but you are also 10 A I am not aware that I reviewed maps, the ones 10 trying the Congress plans, right? 11 you are referring to that came out on the 28th. 11 A My recollection of this is that I was trying 12 Q Okay. You don't have any recollection of 12 to download them. 13 reviewing them before they came out? 13 Q Right. And so evidently they released both 14 A I am not even sure which maps came out on the 14 the Senate plan and a Congress plan on November 28, from 15 28th. 15 the Florida Senate, right? 16 Q Okay. But to your knowledge, you reviewed no 16 A I mean, I am not a 100 percent sure. I think 17 maps that -- before they came out publicly? 17 they might have. I mean, I don't really recall for sure 18 A I don't recollect reviewing maps before they 18 what plans were released on the 28th. 19 were publicly -- as you said, before they publicly came 19 Q Okay. 20 out. 20 (Exhibit No. 57 was marked for 21 (Exhibit No. 55 was marked for 21 identification.) 22 identification.) 22 BY MR. KING: 23 BY MR. KING: 23 Q I show you Exhibit 57, and you have asked 24 Q I think we -- I had Exhibit 55 in front of 24 Mr. Rimes on November 28, whether -- whether the 25 you, but I don't think we talked about it. And the 25 Congress plan went fine, right? 31 (Pages 254 to 257) WWW.USLEGALSUPPORT.COM 954-463-2933 258 260 1 A That's what was written here. 1 A The RSLC stands for Republican State 2 Q And Mr. Rimes says yes, right? 2 Leadership Committee. 3 A That's what he wrote. 3 Q Okay. And so then you provide Mr. Jankowski 4 Q He was satisfied with the Congress plan? 4 some comments about the Florida, the Senate's Florida 5 A I think he was trying to download the same 5 map, right? 6 thing I was. And I think he was successful in it. I 6 A That's correct. I wrote some comments there. 7 think that's what that e-mail indicates, that the 7 Q And you say this is -- it's the Senate's base 8 downloading went fine. 8 map, House will release their map next week, right? 9 (Exhibit No. 58 was marked for 9 A That's what I wrote. 10 identification.) 10 Q And you say the plan is pretty much status quo 11 BY MR. KING: 11 map, good for Rs, right? 12 Q All right. Next, sir, I show you Exhibit 58 12 A That was my opinion of it, yes. 13 and ask you if you recognize that November 28, 2011 13 Q Right. And as we discussed earlier, a status 14 e-mail at 4:04 p.m.? 14 quo map would be good for Republicans, right? 15 A I am looking at this e-mail and it appears to 15 A I guess that could be in the eye of the 16 be an e-mail from me to Rich Heffley. 16 beholder. I mean... 17 Q And so, you have analyzed what the Senate 17 Q Well, you were the beholder and it was good in 18 released as their proposed Congressional plan and also 18 your eye, right? 19 given Mr. Heffley the data on the current Senate plan, 19 A I wrote that I thought it was good for Rs; 20 right? 20 that it didn't change a bunch of stuff. 21 A That's what it appears to be. 21 Q When you say Rs, you mean Republicans, right? 22 Q And you were able to accomplish that by 4:04 22 A Yes. 23 in the afternoon on the 28th, right? 23 Q And you indicate one of the new seats is a 24 A It appears that it was done by 4:04. 24 HISP oriented seat in Orlando, right? 25 (Exhibit No. 59 was marked for 25 A Yes. 259 261 1 identification.) 1 Q And you also indicate that Cliff Stearns's 2 BY MR. KING: 2 seat is kind of divided, depending where he runs, that 3 Q Next, sir, I show you Exhibit 59 and ask if 3 kind of determines where the other new seat is; is that 4 you recognize that e-mail chain? 4 correct? 5 A Okay. 5 A That's what I wrote. 6 Q Which starts on November 28, with an e-mail 6 Q And then Mr. Jankowski asked you, he says, "So 7 from Aaron Blake to Chris Jankowski, Aaron Blake being 7 the Senate, this is it?" 8 evidently some sort of a journalist, right? 8 A That's what he wrote. 9 A It says he is with the Washington Post. 9 Q And then you return, you respond by saying, 10 Q Right. And he wants to know whether the 10 "It has to go through committee into Florida, but this 11 proposal released by the Senate is the proposal, right? 11 is what they will work off of , not a trial balloon." 12 A That's what Mr. Jankowski wrote. 12 Right? 13 Q And Jankowski then writes you on November 28 13 A That's what I wrote. 14 and asks if you have any off-the-record comments, right? 14 Q And that was what your understanding was, 15 A That's what he wrote. 15 correct? 16 Q Now, Mr. Jankowski is the RSLC president, 16 A Well, the Senate -- since it was the Senate 17 right? 17 map, the committee's map, I presumed that it was, I 18 A That's correct. 18 mean, a map that they will work off of. 19 Q And he is in Washington? 19 MR. KING: I am going to pull 60. I am not 20 A Yes. 20 going to use 60. 21 Q What is the RSLC, what is that? 21 (Exhibit No. 61 was marked for 22 A Well, let me back up. I am not sure if they 22 identification.) 23 are in Washington or they might be in Virginia. But 23 BY MR. KING: 24 anyways -- 24 Q Next, sir, I show you Exhibit 61 and ask if 25 Q Okay. What is the RSLC? 25 you if you recognize this series of e-mails with Tom 32 (Pages 258 to 261) WWW.USLEGALSUPPORT.COM 954-463-2933 262 264 1 Hofeller? 1 Q That's the district of Mario Diaz-Balart? 2 A I see that I e-mailed with Tom Hofeller on 2 A I don't think so. 3 this day, this e-mail. 3 Q You don't? 4 Q So he has given you an idea about evidently 4 A No. Maybe. I am not sure. 5 his review of the Congressional map? 5 Q Then you say, but -- Mr. Heffley says, "The 6 A The first -- the lowest part of the chain, I 6 House needs to fix a few of these." 7 interpret that as a critique, his critique of this map 7 A That's what he wrote. 8 that had just come out. 8 Q And you agree, yes, right? 9 Q All right. And he indicates that the first 9 A That's what I wrote. 10 problem is District 3 is not a majority African-American 10 Q And the House did fix Congressional District 11 district, right? 11 25; isn't that right? 12 A That's what he wrote. 12 MR. MEROS: Object to the form, leading. Go 13 Q He says it needs to be over 50 percent in 13 ahead. 14 order to justify its departure from the neutral state 14 THE WITNESS: You know, I didn't follow the 15 criteria safely. 15 Congressional process close enough to know what 16 A That's what he wrote. 16 was -- how the final map was composed. I think 17 Q Then he points out this could be easily 17 that there were ideas taken from the House and from 18 remedied? 18 the Senate, so I am not sure that I would agree 19 A That's what he wrote. 19 with your question. 20 Q Then you indicated in response that you agreed 20 (Exhibit No. 64 was marked for 21 it could be easily fixed, right? 21 identification.) 22 A That's what I wrote. 22 BY MR. KING: 23 Q And you say, "One thing is that the way the 23 Q Next I show you Exhibit 64, sir, and ask if 24 lawyers interpret Florida amendments is that it doesn't 24 you recognize that as a November 30, 2011 e-mail from 25 have to be over 50 percent, but they do believe 25 yourself to Mr. Heffley and Mr. Reichelderfer? 263 265 1 50 percent is a safer harbor." Is that right? 1 A Yes. 2 A That's what I wrote. 2 Q What do you mean when you say, "Miami-Dade 3 Q What lawyers told you that? 3 Congressional based on Senate map. Virtually no change 4 A I don't recall. 4 made to other districts"? 5 Q You have no recollection of which lawyers you 5 A I believe that I had the Senate map, and part 6 are referring to? 6 of our hypothetical exercises that we did is I believe I 7 A It might have been Ben Ginsberg. I just don't 7 took the Miami Congressional map that the Senate had 8 recall. 8 proposed and I made some changes and didn't change -- 9 Q And then Hofeller says certainly that's not 9 just changes in Miami-Dade and didn't change districts 10 worth the risk for such a little fix, right? 10 elsewhere. 11 A That's what he wrote. 11 Q Are you referring to a map you drew here or 12 MR. KING: I am going to pull 62 also. 12 are you referring to the Senate's map? 13 (Exhibit No. 63 was marked for 13 A I believe that I am referring to the Senate's 14 identification.) 14 Congressional map. 15 BY MR. KING: 15 Q Okay. And you are saying that Miami-Dade was 16 Q Next, sir, I show you Exhibit 63 and ask if 16 based on what? 17 you recognize that as an e-mail chain between you and 17 A What I am saying is reading this e-mail, I 18 Mr. Heffley? 18 believed that I was taking the Senate's Congressional 19 A I recognize that as a chain, as an e-mail. 19 map, changing some things around in Miami-Dade, actually 20 Q And you first write Heffley and say, "That 20 making some major changes in Miami-Dade apparently and 21 CD 25 is pretty weak." Right? 21 that I changed nothing else. 22 A That's what I wrote. 22 Q On a proposed map? 23 Q And you are referring to Congressional 23 A As part of just playing around on the maps. 24 District 25? 24 Q Right. And that's on a map called SFL 25 A Presumably so. 25 Triplets? 33 (Pages 262 to 265) WWW.USLEGALSUPPORT.COM 954-463-2933 266 268 1 A That's what I named the attachment. 1 Q All right. And you didn't mean which map is 2 Q All right. 2 more relevant than the others? 3 (Exhibit No. 65 was marked for 3 A I don't understand what I wrote here. 4 identification.) 4 Q What did you understand when he wrote back to 5 BY MR. KING: 5 you and said I think it is 9-11, 9011? 6 Q Next, sir, I show you Exhibit 65 and ask you 6 A I am not sure what 9011 is. 7 if you recognize that as an e-mail exchange between you 7 Q Aren't you aware that's a bill number? 8 and Marc Reichelderfer? 8 A No, I am not aware of that. 9 A I do recognize that. 9 Q Did you write him back and say I don't 10 Q And you asked -- now this is after the House 10 understand what you are talking about? 11 Congressional maps have been released, right, on 11 A It doesn't appear that I have -- did. 12 December 9? 12 (Exhibit No. 66 was marked for 13 A Yes, I believe the House maps had already been 13 identification.) 14 released. 14 BY MR. KING: 15 Q And you knew that the House released seven 15 Q I show you Exhibit 66, sir, and ask if you 16 Congressional maps, right -- 16 recognize that as an e-mail that you sent to Mr. Heffley 17 A No. 17 on December 21, 2011? 18 Q -- on December 6? 18 A It appears that I e-mailed him on this date. 19 A I wasn't -- I am not aware of how many they 19 Q And what is the Sirius plan? 20 released. 20 A I think it's Sirius. 21 Q Were you aware they released multiple 21 Q Sirius plan, okay. 22 Congressional maps? 22 A And it appears to be a Congressional plan. 23 A I believe that I know that there were several 23 Q All right. And who devised it? 24 maps released. 24 A I'm not a 100 percent sure. 25 Q Because your question is, is there one 25 Q So you don't know who invented the Sirius 267 269 1 Congressional district map number that is relevant than 1 plan? 2 the others, right? 2 A I don't know that. 3 A That's what I wrote. 3 Q All right. You indicated to Mr. Heffley, "The 4 Q All right. What you were really saying is 4 map and CD are on your desk." Is that another CD-ROM? 5 there's one map that's more relevant than the others; is 5 A I presume that it is. 6 that right? 6 Q Okay. Why are you again delivering it in 7 A I mean the more is not there, but I mean I am 7 CD-ROM to Mr. Heffley? 8 not really sure. 8 A I am not sure. I mean, possibly because it 9 Q It's not really grammatically correct the way 9 would be too big to e-mail. I am not sure. 10 it reads; you just left more out, didn't you? 10 Q I show you Exhibit 49 to Mr. Reichelderfer's 11 A Well, there is probably a verb missing then, 11 deposition and ask if you are aware that Mr. Heffley 12 too, in your hypothesis. 12 sent the stats for the Sirius plan that you had sent to 13 Q Well, you wanted to know which of the maps 13 him to Mr. Reichelderfer? 14 Mr. Reichelderfer felt was the most relevant, right? 14 A I was not aware that he did that. 15 A I was asking him -- 15 Q I show you Exhibit 67, sir, and ask you if you 16 MR. MEROS: Object to the form, 16 recognize that as an e-mail that you sent to Seth 17 mischaracterization. But go ahead. 17 Weightman? 18 THE WITNESS: I am not -- this is -- this 18 MR. MEROS: You said 67? 19 e-mail is not clear to me what I was asking him. 19 MR. KING: This is 67. 20 BY MR. KING: 20 MR. MEROS: I am sorry, I thought this was 67. 21 Q So you just can't figure out from what you 21 MR. ZEHNDER: That's the Reichelderfer 49. 22 wrote there what you were trying to convey to 22 BY MR. KING: 23 Mr. Reichelderfer? 23 Q Show you Exhibit 67, sir, and ask you if you 24 A I just stated what I wrote to him is not clear 24 recognize that as an e-mail you sent to Mr. Weightman at 25 to me at this time exactly what is meant. 25 Will Weatherford's office? 34 (Pages 266 to 269) WWW.USLEGALSUPPORT.COM 954-463-2933 270 272 1 A Well, I mean his name is Seth Weightman. 1 Q And the legislature is still trying to decide 2 Q Seth Weightman. 2 what Congressional map they are going to enact as of 3 A He does not work at Will Weatherford's office. 3 January 21st, 2012, right? 4 He worked for the Republican of Florida. 4 A I mean, I don't think they had enacted a plan 5 Q Why is the e-mail address 5 yet, a final plan. 6 [email protected]? 6 Q So Frankenstein, you described what the 7 A That's just the domain he worked from. 7 highlights were, right? 8 Q Had he worked for Will Weatherford? 8 A Yes. 9 A He worked for the party but -- worked during 9 Q And you say, "Everything balanced except 10 this period for the party, but he kind of was a driver 10 southeast Florida." What does that mean? 11 who drove Will Weatherford, so -- not for State events, 11 A I believe it means that that wasn't drawn at 12 for political events that the political party 12 zero deviation. 13 speaker-designate had. 13 Q Okay. And so the highlights of that plan you 14 Q Why are you sending these links? 14 describe, right? 15 A My recollection of this e-mail is that at this 15 A Those are some of the pointers there. 16 point in time, based on a newspaper article that I read, 16 Q And you say, "It used Marc's Corrine Brown," 17 there were a lot of people in Pasco County that were 17 right? 18 upset with the way the Senate map had drawn the Pasco 18 A Correct. 19 County districts. There are two districts in Pasco. A 19 Q So that's Marc Reichelderfer's Corrine Brown 20 lot of people were upset, and I think we were -- it 20 district? 21 helped telling Seth, if people contacted him, that the 21 A I would believe -- that's what I would 22 way they could complain or send comments about 22 recollect -- or that's what I would believe. I mean, 23 redistricting issues would be that they -- specifically 23 but I don't know what that specifically means. 24 about this Pasco issue, that these would be three e-mail 24 Q As you used that, did that change 25 addresses that people could contact and complain about 25 significantly from the status quo, the prior plan? 271 273 1 the Senate seat. 1 A The plan that was in place -- 2 MR. KING: Okay. I am going to pull 68 and 2 Q Yes. 3 69, so you won't have numbers for them. 3 A -- in the last decade? 4 (Exhibit No. 70 was marked for 4 Q Yes. 5 identification.) 5 A I think -- I think that it's somewhat similar 6 BY MR. KING: 6 to what was in place in the last decade. 7 Q Next I show you Exhibit 70 and ask if you 7 Q Did you add more Democrats to that Corrine 8 recognize this January 20, 2012 e-mail from yourself to 8 Brown district by using Marc's plan? 9 Mr. Heffley and Mr. Reichelderfer? 9 A I don't recall what was added to the district 10 A I recognize this e-mail as between myself and 10 other than the fact that if it was underpopulated, I am 11 Rich Heffley and Marc Reichelderfer, presumably, yes. 11 sure that I tried to make it the right deviation. 12 Q And there is an attachment and it's described 12 Q And you say "Pasco plus Hernando," that's a 13 as Frankenstein.jpg. Do you see that? 13 highlight? 14 A Yes. 14 A That's what it says. 15 Q What is that? 15 Q They were joined together in a Congressional 16 A That is a plan that I think that I drew. 16 district? 17 Q So you remember drawing that, huh? 17 A In this attachment? 18 A I believe I do remember drawing this. 18 Q Yes. 19 Q And did you draw it right there around 19 A It seems that they are. 20 January 21st? 20 Q And "Brevard plus Indian River." Joined 21 A I believe that Rich and Marc had contacted me 21 together in a district? 22 and asked me to draw up some ideas for them. 22 A It seems that it is. 23 Q Okay. Is this for -- this is a Congressional 23 Q And you say "could entice Mica to run against 24 map, right? 24 Adams." 25 A That appears to be a Congressional map, yes. 25 A That's what's written. 35 (Pages 270 to 273) WWW.USLEGALSUPPORT.COM 954-463-2933 274 276 1 Q That was the way you drew the district? 1 Congressman. 2 A I think -- no, under Amendment 6, the fact 2 Q Okay. Is that a Republican Congressman? 3 that the districts have to be compact and both 3 A He is a Republican Congressman. 4 incumbents lived near each other, that it would be 4 Q All right. And you say you could have Vern 5 inevitable that incumbents would run against each other 5 with virtually all of Manatee, minus the sliver lost to 6 because they both are from -- their residences are 6 Hillsborough, and almost all of Sarasota with all of 7 extremely close to each other. 7 Charlotte going to Ross. Right? 8 Q Okay. And the next sentence, read that for 8 A That's what I wrote. 9 me. 9 Q And so, you are still fine tuning your plan as 10 A It says, "Bilirakis will cry but Hillsborough 10 of January 22, 2012, right? 11 looks nice. Ross has 240,000 in Polk. No other county 11 A This is, like I stated previously, this was a 12 his CD has over. Webster, though, has 360 Polk and 209 12 plan that Rich and Marc had asked me to work on for 13 Orange, plus Lake and Osceola." 13 them, so I am not sure that the word fine tuning -- in 14 Q When you say no other county in his CD over a 14 fact, I think this -- fine tuning is not even a correct 15 hundred, a hundred, what do you mean a hundred? A 15 word because I think they had asked me to do something 16 hundred what? 16 from scratch. 17 A I would presume that means a hundred thousand. 17 Q But this was the Frankenstein plan, right? 18 Q A hundred thousand people? 18 A This is referring to the plan that is called 19 A Probably. 19 Frankenstein. 20 Q So what you are saying is he's got 240,000 in 20 (Exhibit No. 72 was marked for 21 Polk and no other county in his Congressional district 21 identification.) 22 has over a hundred thousand people in his district? 22 BY MR. KING: 23 A Ross has 240 in Polk. 23 Q Next, sir, I show you Exhibit 72, and in this 24 Q Right. 24 one, do you recognize that as a continued part of those 25 A Okay. And then, okay, I see it says "no other 25 chains on January 21, 2012? 275 277 1 county in his CD has over a hundred." 1 A It appears that it is a continuation. 2 Q Okay. And so that means he's got several more 2 Q All right. And Mr. Heffley says, could Posey 3 counties in his district, right, to get to 696,000? 3 eat the Volusia and give the Orange to Adams to reduce 4 A It looks like there are several other 4 Orange splits. Right? 5 counties. 5 A That's what he wrote. 6 Q And then you say "Webster, though, has 360,000 6 Q And you say, "Yes, Posey could go north to 7 in Polk and 209,000 in Orange plus Lake and Osceola." 7 Volusia instead of Orange. Posey doesn't have that much 8 A That's what it says. 8 on" -- what does that mean? Posey doesn't have that 9 (Exhibit No. 71 was marked for 9 much on Orange? 10 identification.) 10 A Presumably it means of, but I am not a good 11 BY MR. KING: 11 typist. 12 Q Next, sir, I show you Exhibit 71 and ask you 12 Q All right. Then you say, "It's no biggy 13 if you recognize that as an e-mail that continues the 13 move," right? 14 chain that you were talking about where you gave the 14 A That's what I wrote. 15 highlights of the plan, of the map? 15 (Exhibit No. 73 was marked for 16 A Right. I recognize this e-mail as being 16 identification.) 17 between Rich, me, and Marc Reichelderfer. 17 BY MR. KING: 18 Q And Rich writes back and says, "Is there a -- 18 Q And then, sir, I show you Exhibit 73 and ask 19 is there a better wise to do Vern." Right? 19 if you recall that e-mail? And I am going to ask you 20 A That's what he wrote. 20 about the one at the top, January 21, 2012, where you 21 Q And did you understand that to mean better way 21 respond to Mr. Heffley. Do you see it? 22 to do Vern? 22 A Yes. 23 A Way or ways, yes. 23 Q And you say also another option is to give 24 Q And Vern is who? 24 Ross more or all of Manatee and push Vern south into all 25 A Presumably that's Vern Buchanan, the 25 of Charlotte and even take Ross's Lee finger too. You 36 (Pages 274 to 277) WWW.USLEGALSUPPORT.COM 954-463-2933 278 280 1 see that? 1 did not work, not sure what to do at this point." 2 A I see that I wrote that, that's in this 2 What is he talking about? 3 e-mail. 3 A Apparently seems like I was sending him a 4 Q Isn't it correct that that's exactly what 4 file, but he was not able to open it. 5 happened with Ross's Lee finger; it was removed from his 5 Q Okay. 6 district? 6 (Exhibit No. 75 was marked for 7 A Hold on. Let me read the e-mail in its 7 identification.) 8 entirety here. (Examining document.) 8 BY MR. KING: 9 I am not sure. I don't know -- I thought -- I 9 Q And next, sir, I show you Exhibit 75. And ask 10 don't think Vern or Ross are in Charlotte or Lee County. 10 you if you recognize that as an e-mail exchange with 11 So I am not really sure, I am not aware that they are. 11 Mr. Heffley on January 23, 2012? 12 I thought that Charlotte is in the new Congressional 12 A I recognize this e-mail as with my name and 13 district that Tom Rooney ended up running for. 13 e-mail to Rich Heffley. 14 Q Dennis Ross is in District 15, right? 14 Q Right. It says, "Close to final as we 15 A I am not sure of the district number that he 15 discussed." Right? 16 represents today. 16 A What is it -- oh, on the subject line it says 17 Q Vern Buchanan is in District 16, right? 17 that. 18 A I am not sure of the district number that he 18 Q What does that mean, sir? 19 has today. 19 A I think this is something that I had been 20 Q Okay. And you don't know whether the Ross's 20 playing with, it looks like. 21 Lee finger was taken away? 21 Q It refers to an attachment, HeffleySE.jpg and 22 A I am not familiar with the initial plans that 22 HeffleySW.jpg, right? 23 the House or the Senate put out, so I don't know what 23 A Yes. 24 that is really referring to, the Ross/Lee finger. 24 Q And you say that "the Senate or the Houses of 25 Q What did you do with the Frankenstein plan 25 Miami-Dade could be slapped in there pretty easily," 279 281 1 after you did it for Mr. Heffley? 1 right? 2 A As you can see here, I -- they had asked me to 2 A That's what I wrote. 3 do this. They were highly critical of it and I don't 3 Q And you say, "Broward and Palm districts still 4 recall doing anything with it. I think -- I don't 4 need a small amount of work." Right? 5 recall that I even gave it to them other than the .pdfs 5 A That's what I wrote. 6 that -- I mean, I am not -- I don't recall what was done 6 Q Why did you say that? 7 with it. 7 A Because it must have needed a small amount of 8 (Exhibit No. 74 was marked for 8 work. I don't remember what that work is, but 9 identification.) 9 presumably it needed work. 10 BY MR. KING: 10 Q Now you are referring to the Senate map, 11 Q I show you Exhibit 74, sir, and ask you if you 11 right? 12 recognize that as an e-mail exchange between you and 12 A No, I think I am referring to the attachment. 13 Mr. Reichelderfer? 13 Q Isn't the attachment the Senate map or is it 14 A It is an exchange between us, yes. 14 the Congressional map? 15 Q All right. And he reports to you, "Changing 15 A No, this is a Congressional map. 16 the extension did not work, not sure what to do at this 16 Q I am sorry. All right. Okay. And what was 17 point." 17 wrong with the Palm district? 18 Do you know what he is referring to? 18 A It needed a small amount of work, is what the 19 A This e-mail makes me think that I might have 19 e-mail says. 20 sent it to Marc Reichelderfer, but I am not a 20 Q What kind of work? 21 100 percent sure. 21 A I think I just answered that question, that I 22 Q Well, the first in the chain is an e-mail from 22 mean I would only be guessing and I am just not sure. 23 you to Reichelderfer saying here's the file, right? 23 (Exhibit No. 76 was marked for 24 A That's what I wrote. 24 identification.) 25 Q And then he responds, "Changing the extension 25 37 (Pages 278 to 281) WWW.USLEGALSUPPORT.COM 954-463-2933 282 284 1 BY MR. KING: 1 wrote is Wise and remainder of Duval go together. 2 Q Next, sir, I show you Exhibit 76, and ask you 2 Q Okay. And then Thrasher all of St. Johns and 3 if you recognize this e-mail string that is March 14, 3 Flagler and Putnam? 4 2012? 4 A That's what he wrote. 5 A I see that it's an e-mail between me and Rich 5 Q Okay. And did you draw such a map? 6 Heffley. 6 A I don't think I did. I am not a 100 percent 7 Q Right. And timewise do you recognize this as 7 sure. 8 the period of time after the Senate map has been 8 Q Why not? 9 rejected by the Supreme Court? 9 A I am not sure. I just may not have had time. 10 A It appears that it was in that period of time 10 Q Did you not support Mr. Heffley at this point 11 after the rejection. 11 on the map drawing? 12 Q All right. And so Mr. Heffley is e-mailing 12 A There were, as you know, clearly as we have 13 you from the Capitol, right? 13 seen in these e-mails, there are times where I did help 14 A He says he is at the Capitol. 14 him. I don't specifically recall doing that. 15 Q Right. And he is telling you how he wants you 15 Q Okay. 16 to draw a map, right? 16 (Discussion off the record.) 17 A He is telling me -- he is saying if I wanted 17 (Exhibit No. 77 was marked for 18 to do something, if I wanted to start something, that he 18 identification.) 19 would give me some things to begin with. 19 BY MR. KING: 20 Q And he is telling you to "nest your three 20 Q All right. Sir, I show you Exhibit 77 and ask 21 Panhandle together for Evers and remainder for Gaetz." 21 you if that reflects that on December 2, 2011, you 22 Right? 22 provided a map to David Rivera? 23 A That's what he quote. 23 A That appears that way, yes. 24 Q Evers? Who is Evers? 24 Q Who is David Rivera? 25 A Evers is a State senator. 25 A David Rivera is a former Congressman from 283 285 1 Q Is he a Republican? 1 Miami-Dade County. 2 A Yes. 2 Q Was he a former Republican Representative in 3 Q And Senator Gaetz is a Republican as well, 3 the United States House of Representatives at that time, 4 right? 4 sir? 5 A Yes. 5 A At that time he was an incumbent Congressman. 6 Q Then it says, "In JAX, draw lwv Gibson." What 6 Q He was an incumbent Congressman. So he was 7 does that mean? 7 actually in Congress, right? 8 A I think that's L, your client. 8 A At that time. 9 Q Okay. League of Women Voters? 9 Q What happened to him? 10 A Presumably so. 10 A He was defeated for reelection. 11 Q And what does it mean, and Gibson? 11 Q Okay. And why were you sending a map to him? 12 A I think that he is probably saying to look at 12 A My recollection is he asked me to play around 13 your client's proposal for Jacksonville. 13 and see if there were some alternatives under 14 Q Gibson means Jacksonville? 14 Amendment 6 that were different than what he -- than 15 A Senator Gibson is a Democrat senator from 15 what had been floating out there so far. 16 Jacksonville. 16 Q And that would help him? 17 Q Okay. And then it says, "Wise all of Nassau," 17 A No. In fact, my recollection is he 18 what does that mean? 18 specifically said I am not looking to have my House 19 A That the seat that would be represented by 19 placed in a district. He just wanted to see if there 20 Steve Wise, I presume that he is saying to give that or 20 were other alternatives that could be drawn under 21 to put that in the Nassau County, in that seat that 21 Amendment 6 that, you know, that could be looked at. 22 Senator Wise represents. 22 Q Well, was he asking you to give him a district 23 Q And the remainder of Duval to Thrasher? 23 that would perform worse than what he already had? 24 A No. I think -- reading this, these are his 24 A I don't recall that he discussed performance. 25 words. He is saying that Wise -- the way I read what he 25 The one thing I recall in the conversation is that he 38 (Pages 282 to 285) WWW.USLEGALSUPPORT.COM 954-463-2933 286 288 1 asked me to come up with some ideas that comply with 1 Q Well, David Rivera then was contacting Dean 2 Amendment 6 but that specifically did not try to place 2 Cannon over the weekend before the House maps were 3 his House in a particular district. 3 released; is that right? 4 (Exhibit No. 78 was marked for 4 A That's what -- what Javier is saying that. So 5 identification.) 5 I don't know that that -- I don't know that to be a 6 BY MR. KING: 6 fact. 7 Q I show you Exhibit 78 and ask you to compare 7 Q And what is CLC? 8 it to Exhibit 77. 8 A Presumably CLC is a House member, Carlos Lopez 9 A Okay. 9 Cantera. 10 Q Are those two different maps you drew for 10 Q Was Cantera on the redistricting committee in 11 Rivera? 11 the House? 12 A They are two different ones, yes. 12 A I don't think so, but I am not sure. 13 Q So you sent him two examples of alternative 13 MR. KING: Okay. I am done. 14 changes? 14 MR. MEROS: We need -- can we have a 15 A These are two -- well, I think this is only in 15 one-minute break. 16 Dade County to start with, but they are similar, very 16 THE VIDEOGRAPHER: We are going off the 17 similar, but it looks like there are some slight 17 record. We are off the record. 18 differences here. 18 (A recess took place from 6:13 p.m. to 19 Q Were either of those plans adopted in the 19 6:17 p.m.) 20 plan, in the ultimate map? 20 THE VIDEOGRAPHER: We are back on the record. 21 A I don't believe so. 21 MR. MEROS: The House does not have any 22 Q Adopted by the legislature? 22 questions. 23 A I don't believe they were adopted by the 23 MR. CANTERO: Senate has no questions. 24 legislature. 24 MR. BROWN: We are concluded. We'll read and 25 (Exhibit No. 79 was marked for 25 he will sign. 287 289 1 identification.) 1 THE VIDEOGRAPHER: We are now going off the 2 BY MR. KING: 2 record. It is 6:17. We are off the record. 3 Q I show you, sir, Exhibit 79 and ask you if you 3 (Proceedings concluded at 6:17 p.m.) 4 recognize that e-mail exchange with Jan -- how do you 4 5 pronounce her name? 5 6 A That's a man. 6 7 Q Javier? 7 8 A Javier. 8 9 Q Javier, what? 9 10 A Correoso. 10 11 Q Correoso. Okay. Do you know who that was? 11 12 A I believe Mr. Correoso worked for Congressman 12 13 Rivera. 13 14 Q Right. And he was writing you to find out 14 15 when the House maps were going to come out? 15 16 A That's what he wrote. 16 17 Q And that was on December 6? 17 18 A That's correct. 18 19 Q And you are telling him they are going to come 19 20 out around noontime on December 6, right? 20 21 A Yes, that's what I wrote. 21 22 Q Okay. And it says there, "I know David 22 23 touched based with Dean and CLC over the weekend." 23 24 Is that right? 24 25 A That's what he wrote. 25 39 (Pages 286 to 289) WWW.USLEGALSUPPORT.COM 954-463-2933 290 1 1 CERTIFICATE OF OATH ERRATA SHEET 2 I have read the transcript of my deposition, pages 3 STATE OF FLORIDA ) through 291 and hereby subscribe to same, including any 4 COUNTY OF LEON ) corrections and/or amendments listed below. 5 DATE:______6

7 PAGE/LINE CORRECTION or AMENDMENT REASON FOR CHANGE 8 I, the undersigned authority, certify that ______9 the above-named witness personally appeared before me ______10 and was duly sworn. 11 ______12 WITNESS my hand and official seal this ______13 16th day of June, 2013. ______14 NOTARY DD947789 ______EXPIRES: 4-18-14 ______15 /s/ Sandra L. Nargiz ______16 SANDRA L. NARGIZ, RMR, CRR ______1-800-934-9090 ______17 850-878-2221 [email protected] ______18 ______19 ______20 ______21 ______22 23 DATE OF DEPOSITION: 6-11-13 REPORTER: Sandi Nargiz 24 25 291 1 2 CERTIFICATE OF REPORTER 3 STATE OF FLORIDA ) 4 COUNTY OF LEON ) 5 I, SANDRA L. NARGIZ, Registered Professional 6 Reporter, certify that the foregoing proceedings were 7 taken before me at the time and place therein 8 designated; that my shorthand notes were thereafter 9 translated under my supervision; and the foregoing pages 10 numbered 1 through 290 are a true and correct record of 11 the aforesaid proceedings. 12 I further certify that I am not a relative, 13 employee, attorney or counsel of any of the parties, nor 14 am I a relative or employee of any of the parties' 15 attorney or counsel connected with the action, nor am I 16 financially interested in the action. 17 DATED this 16th day of June, 2013. 18 19 20 /s/ Sandra L. Nargiz 21 SANDRA L. NARGIZ, RMR, CRR Notary Public 22 1-800-934-9090 850-878-2221 23 [email protected] 24 25 40 (Pages 290 to 1) WWW.USLEGALSUPPORT.COM 954-463-2933 Page 1

A ahead 145:3 167:22 240:15 290:9 article 161:19,23 Aaron 259:7,7 168:3 178:6 appears 140:10,22 270:16 abbreviation 189:9 181:2 194:5,12 142:5,13 147:2 ASHLEY 137:11 ability 216:13 194:25 196:15 147:20 149:22 ashley.davis@d... 248:3 198:8 201:2 150:1 153:13,18 137:11 able 147:13 169:19 203:15 210:25 154:11 156:21,25 asked 141:19 169:20 210:15 218:13 255:1 157:3,24 158:3 146:12,19 160:5 212:3 246:21 264:13 267:17 160:3 161:14 160:11,20 175:19 247:18 258:22 al 135:3,7,8 162:2,14,20 175:23 176:8 280:4 Alerts 148:13 163:7,22 164:3 177:1 200:7,12 abolished 250:8 alternate 240:12 164:17 171:3,6,6 201:14 203:11,19 above-named 290:9 alternative 168:1 171:25 172:19 206:22 207:9,11 absolutely 145:14 168:9 169:14 178:21 186:21 208:7 210:15,15 accept 140:24 186:10,14,23,24 192:5,25 193:17 210:19 232:16,24 accommodates 254:2 187:1,4 188:11 197:5 204:3 233:1 234:1,18 accomplish 210:14 240:9 286:13 205:3,6,6 208:16 238:6,19 242:11 221:17 258:22 alternatives 208:20 209:9,17 243:8 252:10 accurate 141:18 285:13,20 213:2 217:9 257:23 261:6 achieve 190:21 Amendment 203:4 219:22 220:22 266:10 271:22 Act 172:16 189:10 274:2 285:14,21 222:12,20 223:23 276:12,15 279:2 190:25 286:2 1:6 224:4,14,14,25 285:12 286:1 action 291:15,16 amendments 262:24 225:1 226:13 asking 149:2 153:9 ad 237:2 1:3 227:12 228:3,6,9 159:18 161:20 Adams 273:24 277:3 amount 207:5 208:1 229:3,25 230:6 164:13,15 171:23 add 273:7 281:4,7,18 230:24 231:7 172:5 183:12 added 273:9 analysis 177:19 233:12,19 237:11 191:19 201:10 addition 240:9 210:1,18 237:24 243:14 213:15,18 217:20 address 198:9 analyzed 246:12 244:14,22 245:24 217:20,22,23 204:9 226:17 258:17 247:2 248:15 233:21 235:15,19 270:5 and/or 1:3 249:5 256:5 243:9 254:22 addresses 191:14 answer 144:20 258:15,21,24 267:15,19 285:22 191:20 217:15 145:4 177:3 268:18,22 271:25 asks 259:14 270:25 199:14 201:11 277:1 282:10 assignment 141:8 adjective 145:17 203:22 205:25 284:23 141:20,21 142:4 adopt 161:20 206:24 207:11 applicable 201:5 142:10 adopted 286:19,22 218:13 207:8 assistance 210:5,7 286:23 answered 206:22 appreciate 144:11 212:5 advice 160:25 211:24 281:21 156:12 assisted 199:17,20 affect 197:15,22 answering 200:23 appropriate 219:15 199:22,24,25 aforesaid 291:11 anybody 180:3 approve 210:22 assisting 207:13 African-American anyway 150:8 210:9 approved 188:11 association 215:16 262:10 anyways 259:24 218:8 215:16 afternoon 147:25 apologize 169:25 area 150:3,5,10,12 assume 142:3 192:3 193:7 202:23 150:21,21,24 assumed 251:19 213:1 225:24 apparently 147:1 151:4,6,16 attached 149:1 237:10 240:2 183:20 198:21 153:12 158:6,22 153:3,4 205:4 258:23 206:11 209:2 188:7 215:7 222:22 agenda 193:21 213:5 238:25 areas 143:6,8,14 223:1 228:25 ago 186:7,9 213:11 239:3 245:7 153:2 158:25,25 240:13,18 219:14 250:8 265:20 280:3 187:18 188:9 attaches 206:8 253:4 appear 150:20,23 190:24,25 221:21 attaching 244:23 agree 166:12 187:3 161:16 198:15 236:1 attachment 138:18 194:6 215:19 207:12 209:20 argumentative 148:9 191:12 264:8,18 237:22 246:11 145:23 167:22 192:6,11 209:8 agreed 212:19 268:11 196:14 198:8 213:16 222:21,22 262:20 APPEARANCES 136:1 211:7 232:8 223:6,9,9 230:5 agrees 195:15 appeared 234:25 arranged 199:2 237:15 240:12

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245:3 246:7 196:12 205:1,18 Ben's 140:17 141:2 Browning/SEC 172:7 266:1 271:12 205:20 212:16 179:11 180:6 Buchanan 275:25 273:17 280:21 215:11 216:9,11 183:13 278:17 281:12,13 217:7,9,12,20 best 144:19 166:21 bunch 140:25 attachments 148:22 218:9,17 224:1,2 198:9 199:13 260:20 222:19 224:7 225:15,17 226:16 247:12,25 business 182:13 attacking 172:8 227:20 241:21 better 187:5 223:8 183:5 184:22 attempt 225:8 balanced 272:9 243:18 245:4 185:7 attempting 142:13 balloon 261:11 275:19,21 buy 164:22 165:18 246:4 base 260:7 beyond 250:7 165:23 166:8,11 attorney 144:22 based 143:5 147:13 big 269:9 166:13 291:13,15 221:7 222:2 biggy 277:12 attorney/client 248:6 265:3,16 bikini 142:21 C 215:4 270:16 287:23 Bilirakis 274:10 C 136:9 250:4 August 140:13 basically 141:16 bill 268:7 call 153:7 162:10 146:8 147:18 Bay 150:21 158:2,6 Biscayne 136:18 195:12 220:3 148:1,10 154:10 Beach 143:17 bit 168:23 186:18 237:1 248:22 154:18 155:19 before/after 231:3 194:2,21 250:3 156:20,21 157:1 beginning 215:20 black 152:3 197:8 called 206:8 157:12 160:1,5 begins 219:9 224:9 222:20 234:10 161:13 163:18,24 beholder 260:16,17 BLACKWELL 136:5 241:17 249:23 165:18 170:4,11 belief 228:14 Blake 259:7,7 256:7 265:24 170:12,17 171:4 234:8 block 141:7,20,21 276:18 author 154:13 believe 141:22 142:4,10 167:12 calls 201:7 163:20 175:20 151:2 152:23 blunder 144:18 campaign 185:17,18 176:19,22 225:3 158:18 159:2,10 Blvd 136:18 campaigns 207:17 authority 290:8 163:9 169:20 Bogdanoff 145:9,10 candidate 248:2,3 avoid 247:13 170:9 174:16 Bognavich 145:7 Cannon 172:23 avoiding 247:16 179:24 180:13 BONDI 135:4 173:12 254:1 aware 227:20 181:24 183:23 bottom 151:15 288:2 255:10 266:19,21 184:7,13,21 152:19,20 156:22 Cantera 288:9,10 268:7,8 269:11 185:1,8,9 197:11 158:13 165:20,22 CANTERO 136:16 269:14 278:11 204:10 210:14,16 191:17 208:22 170:14,17 173:18 a.m 135:17 249:8 210:19 211:1,2,9 212:22 223:25 178:22 211:8 211:14,19,25 224:7 231:1 253:7,10 254:17 B 212:2,4 214:18 233:17 238:18,19 254:20 288:23 B 136:3 152:1,2 216:15,16 220:6 244:16 248:16 capability 177:24 back 140:1 145:1 220:9,15 224:21 bought 165:1 capable 210:16 154:9 156:12 225:16,20 226:6 bounced 224:7 220:9 163:24 172:25 228:8 236:12 225:11 226:22 Capitol 137:7 176:4 178:13,19 239:4 241:21 Box 137:4,15 282:13,14 184:16 185:20 243:3 246:18 break 178:1,6 care 211:11 186:16 193:15 249:16 250:4 219:1,2 288:15 Carlos 288:8 194:18 196:6,11 251:18 252:9 breaking 177:8 CARLTON 136:10 212:11 214:19 254:14 262:25 Brevard 273:20 carry 180:15 219:7 223:4,4 265:5,6,13 brief 172:15 case 135:4,8 224:7 225:11 266:13,23 271:18 bring 193:20 136:17 205:3,7 229:14 235:22 271:21 272:11,21 Bronough 137:12 246:7 252:11,13 253:18 272:22 286:21,23 Broward 187:17 Castor 160:7 259:22 268:4,9 287:12 188:3,8 281:3 202:16,24 275:18 288:20 believed 185:10 Broward/Palm 221:2 Catch 155:1 bad 170:16 265:18 Brown 136:9 144:20 cause 148:17 229:1 Bainter 146:9 Ben 179:23 180:6 156:9 157:14,17 CD 151:20,24 147:5 168:22 182:21 185:11 178:1 200:23 249:12,16 253:1 191:18,24 192:24 205:21 212:14 206:22 219:9 253:3 263:21 193:12,18,25 263:7 253:12 272:16,19 269:4 274:12,14 195:19 196:4,9 Benjamin 212:12 273:8 288:24 275:1

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CDs 146:13 249:9 233:2 234:20 190:18 247:20 146:16 147:3 249:11,24 250:12 235:25 260:20 248:1 149:18 150:11,20 251:10,16,22 265:3,8,9 272:24 Collier/Hendry 151:8 157:22 252:2 1:6 190:2,16,18 158:10,14,15 CD-ROM 249:17 changed 265:21 247:13 160:6 173:2 250:11 252:7,15 changes 189:11 come 154:14 262:8 174:6,18 175:1,5 252:22 269:4,7 230:10 265:8,9 286:1 287:15,19 175:16,22 176:9 CD-ROMs 147:1 265:20 286:14 comes 148:13 176:11 201:24 251:1 252:18,22 changing 265:19 152:25 202:6 207:6,14 cell 220:3 279:15,25 coming 203:5 207:22 208:1,5 centering 151:7 characterization Commenced 135:17 211:18 234:6 certainly 154:15 240:11 comment 183:16 237:22 249:14 158:4 160:21 Charlotte 276:7 199:9 254:21 258:18 161:16 166:16 277:25 278:10,12 commented 176:4 262:5 263:23 189:23 215:21 Cheat 156:11 comments 176:5,7 264:10,15 265:3 220:15 227:11,11 checked 140:15 176:14,24 259:14 265:7,14,18 232:21 233:19 166:6,25 185:22 260:4,6 270:22 266:11,16,22 235:13 236:10,15 246:13 247:7 committee 174:19 267:1 268:22 243:20 246:23 chide 195:19 210:2 228:16 271:23,25 272:2 263:9 chiding 195:21 260:2 261:10 273:15 274:21 certainty 159:3 chief 162:4,6 288:10 278:12 281:14,15 Certificate 135:21 173:14 committee's 261:17 Congressman 163:2 140:20,21 290:1 choice 248:4 compact 274:3 276:1,2,3 284:25 291:2 chose 160:23 compare 286:7 285:5,6 287:12 Certified 135:20 Chris 190:2,8,9 comparing 243:19 connected 247:23 certify 290:8 191:4 221:1,1,10 comparison 243:20 291:15 291:6,12 259:7 complain 270:22,25 connection 152:7 cetera 238:20 churning 240:16 completed 201:24 152:10 239:16 circle 136:13 202:5 connector 239:2 chain 138:15,16,19 202:19 completely 202:12 consider 168:7 138:20,22,23,24 CIRCUIT 135:1,1 comply 286:1 considered 168:4 138:25,26,29,30 clarification composed 264:16 248:5 138:31,32,35,36 146:19 254:17 compound 174:2 consultant 162:22 138:38,39,40,42 Clay 239:2 245:5 computer 173:2 consultants 215:17 139:44,45,47,49 CLC 287:23 288:7,8 216:14 Consulting 219:21 139:50,51,52,53 cleaned 220:25 concern 164:5 contact 270:25 139:54,56,59 221:9 concerned 211:17 contacted 270:21 140:1,2,5,9,10 clear 194:9,14,15 concerns 254:3 271:21 140:11,12,13,14 217:20,24 233:25 concluded 135:17 contacting 288:1 140:15,17 140:8 267:19,24 160:10 288:24 contained 164:3 140:10 154:9 clearly 151:9 289:3 contains 246:6 160:1 161:12 187:7 284:12 conferencing contemporaneously 163:21,24 178:19 client 283:8 140:24 196:21 192:23 197:3 client's 283:13 confident 254:5 continuation 277:1 208:13 219:20 Cliff 261:1 configurations continue 191:2 230:22 248:13 close 174:14 247:5 158:6 177:7 200:8 249:3 259:4 264:15 274:7 configured 224:10 continued 140:5 262:6 263:17,19 280:14 confirms 257:3 276:24 275:14 279:22 clue 194:22 confusing 200:16 continues 275:13 chains 276:25 Coastal 241:17 CONG 146:22 continuing 199:16 chair 249:9,11,13 coats 219:13 Congress 153:16 conversation 249:15 250:13 code 198:5 232:6,9 158:2,20,22 162:18,19 195:22 251:17,20,21,22 232:10,10 176:17,18 207:10 229:8,11 285:25 251:24 252:3,5 cognizant 145:6,13 231:25 257:10,14 conversations challenging 172:15 145:15 257:25 258:4 177:6 change 165:12 Collier 142:25 285:7 conversion 166:21 232:16,24 233:1 143:3,4,13 Congressional conversions 167:10

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167:11 168:14 courts 172:15 dbrown@carlton... desk 269:4 convert 164:5,13 coverage 142:25 136:9 despite 207:21 164:19 165:5,19 143:3 DD947789 290:14 determine 177:21 169:8 created 241:22,23 deadline 161:24 determines 261:3 convey 246:5 241:25 162:9 163:8,9 DETZNER 135:4,8 267:22 criteria 262:15 231:3,10 developed 190:5 copied 217:17 critical 279:3 dealing 194:1 deviation 272:12 copies 212:15 critique 244:1 207:5 273:11 250:11,16 262:7,7 Dean 172:17,20,23 devised 268:23 copy 170:23 204:1 CRR 290:16 291:21 173:11 253:25 dhealy@davidhe... 204:8 205:4,17 cry 274:10 287:23 288:1 136:13 224:2 225:22 cryptic 194:2,8 decade 273:3,6 Diaz-Balart 264:1 254:1 233:3 December 174:20 Diez 163:25 166:18 correct 143:24 current 151:8 175:2,17 266:12 difference 224:8 144:8,13 159:1 152:16,17,21 266:18 268:17 224:15,17,22 164:2 169:15,16 153:6,6,12 284:21 287:17,20 225:1 169:17 173:6 154:20 158:1,2,9 decide 272:1 differences 286:18 175:7 177:18 158:20 162:6 decision 219:15 different 150:22 179:13 185:7 187:1 222:18,23 decoupling 231:19 150:23,24 151:16 186:11 193:25 222:24 223:1,5 231:23 232:12,14 152:21 202:11,12 196:8 204:25 223:11 258:19 deduce 167:5,6 202:12 204:9,11 207:6 218:10,17 cut 177:9 deep 171:8 236:23 285:14 222:4 223:13 def 142:4 286:10,12 224:4 232:16 D defeated 285:10 difficult 230:7 241:1 252:1,24 Dade 286:16 Defendants 135:5,9 dime 184:25 254:25 259:18 DANIEL 136:9 137:6 135:14 DIRECT 140:5 260:6 261:4,15 darn 225:19 definitely 142:3,3 direction 221:24 267:9 272:18 data 141:7,12 245:4 255:6 directly 173:11 276:14 278:4 205:2,5,23 delayed 236:25 215:23 287:18 291:10 227:21 238:20 deleted 170:5,9 director 210:1,17 CORRECTION 1:6 239:6,7,16 delivering 269:6 discern 230:9 corrections 1:3 246:13,21 249:23 Democrat 283:15 discuss 154:24 Correoso 287:10,11 251:10,12 252:7 democratic 190:13 155:4,8 171:9 287:12 256:10,11,12 Democrats 273:7 180:25 185:13 Corrine 272:16,19 258:19 Dennis 278:14 236:4,19 254:6 273:7 database 157:6 DEPARTMENT 137:12 discussed 181:9 cost 165:1 166:6 date 135:15 148:12 departure 262:14 185:14 227:14 counsel 291:13,15 193:5 237:3 depending 261:2 251:7 260:13 counties 143:5,14 268:18 1:4,23 Depends 193:21 280:15 285:24 151:24 177:8,9 dated 163:17 217:8 depicted 151:4 Discussion 253:15 245:6 247:4,9,21 291:17 depiction 214:13 256:23 284:16 275:3,5 David 136:3,12 DEPONENT 136:8 display 213:22 county 135:2 284:22,24,25 deposition 135:12 DIST 146:22 143:17 177:7 287:22 288:1 227:25 229:17 district 143:7,25 188:7 190:19 DAVIS 137:11 243:12 253:22 147:3 151:8,17 270:17,19 274:11 day 166:14 184:2,8 269:11 1:2,23 151:19 158:10,14 274:14,21 275:1 184:10 188:20 depositions 144:17 158:15 160:7 278:10 283:21 193:3 213:2 depth 174:17 188:7 191:4 285:1 286:16 225:9 237:3,8 deputy 173:13 198:18 247:22 290:4 291:4 240:24 262:3 210:1,17 262:10,11 263:24 couple 176:2,17 290:13 291:17 describe 157:4 264:1,10 267:1 212:11 240:21 days 196:6,6 206:2 272:14 272:20 273:8,9 244:3 253:8 240:21 described 207:15 273:16,21 274:1 course 145:11 Daytona 221:14 271:12 272:6 274:21,22 275:3 186:10 195:7,15 dbf 141:25 157:5 descriptives 201:5 278:6,13,14,15 court 135:1 172:8 239:7 designated 291:8 278:17,18 281:17 282:9 dbfs 157:2,4 designed 218:24 285:19,22 286:3

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WWW.USLEGALSUPPORT.COM 954-463-2933 Page 15 regarding 217:14 236:9,10 237:18 responded 146:22 148:1,3 149:8 240:3 240:17 246:14 responds 141:5 151:8,10,11,20 registered 247:4 251:6 254:12 155:12 187:16 151:21 152:22,24 247:10,19,21 271:17,18 281:8 217:12 231:12 153:15,21 154:13 291:5 Remington 135:18 233:20 244:20 154:18,21 155:1 Reichelderfer 136:13 279:25 155:3,19,22 139:48 168:17 removed 278:5 response 146:21 156:1,5,6,7,8,12 169:9 174:15 RENE 135:3 231:25 232:15 156:24 157:2,25 175:17,18 216:13 Renee 188:8 239:1 245:8 158:2,7,10,14,17 216:16 228:2,4 repeated 233:17 262:20 158:22 159:14,15 229:2,24 240:2,6 repeats 233:17 rest 222:1 160:11,18 161:22 242:8,11 243:15 REPORTED 135:20 restate 145:25 162:1,7,7,15 244:13,15,20 Reporter 135:20 155:6 167:23 163:6 164:6,9,19 253:23 254:1 140:21 291:2,6 174:2 218:14 164:23 165:2,6 264:25 266:8 1:23 235:7 239:10 165:19,21,24 267:14,23 269:13 reports 279:15 restating 144:23 166:2,6,9 167:1 269:21 271:9,11 represent 190:18 result 161:21 167:4,10,13,16 275:17 279:13,20 191:4 resulting 209:11 168:2,7,11,14,25 279:23 representation results 177:24 169:4 171:2,5,20 Reichelderfer's 191:1,3 return 261:9 172:7,20 173:12 227:25 228:23 Representative returned 227:5 173:17 174:11 229:17 243:12 285:2 reveals 209:8 176:7 178:5,7 269:10 272:19 Representatives review 213:6 255:8 180:15 181:19 reimburse 184:22 137:1,7 174:24 262:5 182:14 183:13,18 reimbursed 184:23 175:3 228:16 reviewed 255:10,16 183:19 185:15 185:2 285:3 reviewing 255:13 187:2,22,25 reimbursement represented 188:7 255:18 188:2 190:6,8 185:4,5 283:19 revised 243:16 191:17,21,23,25 rejected 282:9 REPRESENTING 136:2 Rich 140:11 147:21 192:4 193:4,9,13 rejection 282:11 136:8,15 137:1,9 159:10,11,16 193:15,16,23 related 164:10 represents 278:16 160:3 173:1 194:10,18,23 relationship 283:22 180:6,19 187:8 195:9,14,16 174:15,17 Republican 148:16 187:23 188:23 196:13 198:14,20 relative 291:12,14 159:6 162:24 189:22 193:18,18 199:3,6,16,19,22 release 260:8 163:2 168:2 197:5 201:21 199:23 200:1,2,5 released 174:20 182:25 183:4 204:10 205:20,20 201:25 202:7,10 175:4,6,12,13,16 184:15 188:11,14 208:3 209:2,23 202:16 204:19,25 254:12,18 255:4 190:11 204:2 210:15 217:17 206:23 207:19,20 257:4,7,13,18 207:16 210:1,12 220:23 222:12 207:23 208:4,5 258:18 259:11 215:17 241:4 225:22 226:8,10 208:18,21 209:5 266:11,14,15,20 242:23,24 260:1 226:13 229:24,25 209:8,15,19 266:21,24 288:3 270:4 276:2,3 233:12 236:11,13 210:12 212:12,16 relevant 267:1,5 283:1,3 285:2 236:23 237:11 212:20,23,25 267:14 268:2 Republicans 245:15 238:14 241:14,21 213:3,4,6,6,12 remainder 282:21 260:14,21 246:19 248:5,14 213:16 214:5,6 283:23 284:1 requested 145:1 249:5 250:18 214:10,17,20,23 remedied 262:18 required 168:18 253:1 254:3,6 217:11,19,21,22 remember 160:13 resend 218:4 255:8 256:5 217:24 220:24 161:15 165:15 resided 218:10 258:16 271:11,21 221:3,9 222:1,15 166:15,19 172:13 residences 274:6 275:17,18 276:12 222:18 223:2,4,6 176:7,12 177:5 residencies 191:14 280:13 282:5 223:12,14,17 180:3,6 182:7 resident 191:14 Rich's 250:13 225:3,18,22,25 183:3 193:5,11 respond 142:2 right 140:13 226:19,22,22 195:3,10,12,21 156:3 177:4 141:12,15 142:4 227:17,19 228:5 196:3,10,11 198:24 199:4 142:7,16,22 228:11,17,24 206:13 213:8,11 242:14 261:9 144:16 145:8,21 229:6,9 230:5,8 221:16 230:14 277:21 146:9,13 147:23 230:10 233:14,16

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