Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 1 of 141

I(ELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017

l_ fN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA 2 ATLANTA DIVISION

3 ORIGINAL KELVIN .J . COCHRAN, 4 Plaintiff, 5 CIVÏL ACTION FÏLE vs. 6 NO. l- : 15 -cv- OO47 7 -LMM CÏTY OF ATLANTA, GEORGIA; 7 and. MAYOR KASIM REED, IN HÏS ÏNDIVÏDUAL CAPACITY, I Defendants - 9

10

11

a2 VIDEOTAPED DEPOSÏTÏON OF MELÏSSA J. MULLÏNAX 13 FEBRUARY 23, )ñ1'7 L4 9:38 A-M

15 BAKER DONELSON BEARMAN CALDWELL 6. BERKOWITZ, P. C MONARCH PLAZA , SUI TE 1- 6 O O L6 341,4 PEACHTREE ROAD, N.E. ATLANTA, GEORGTA L7

l_8

L9

20

2a

22

23

24 Reported by Suzanne Beasl"y, RPR CCR-B -1484 25

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on02l23l20l7 Page2

1 INDEX TO EXAMINATÏON

2

3 Examination Page No.

4

5 By Ms. Holcomb 6

6

7 I

9 INDEX TO EXHIBITS

10

11 Exhibit. No. Page No

L2 Exhibit 85 35 1_3 H-maaÌ dated 12/4/1,4 from Ms. Shatrar to Ms. Rose and Ms. Mullinax L4 Exhibit 86 44 1_5 E-mail- dated 1,/2/1,5 from Ms. Mullinax to Ms. Mullinax, Subj ecL : Cochran L6 Exhibit 87 46 1,7 .Ei -mar_ l_ dated 1,/5/1,5 f rom Ms. MulLinax to Ms- Mullinax, Subj ecL : Cochran 1-8 Exhibit 88 53 T9 E-mail dated 1,/5/1,5 from Ms. Mullinax to Ms. Mul-l-inax, Subj ecL : Coch 20 Exhibit 89 5'7 2L E-mail dated l/6/L5 from Ms. Mul-linax to Ms. Ward with attached official 22 statement from Mayor Reed

23 Exhibit 90 58 E-mail dated 1-/1-2/1"5 from Ms. Mul-l-inax 24 to Ms. Mull-inax, SubjecL: Faith and Freedom Coalitíon 25 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 3 of 141

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) 1 INDEX TO EXHIBÏTS

2 Exhibit No. Page No

3 Exhibit 91- 58 4 Document headed Faith & Freedom Coalition, Bates stamped 5 COA-EMAIL OO4O24 t.hroughO04043

6 Exhibit 92 61 E-mai1 dated 1,/1,3 /1,5 f rom Ms . Mullínax 7 to Ms. Torres, Ms. Byrd, Ms. Taylor and Ms. Garl-and, Subj ect : Support on 8 Cochran Issue

9 Exhibit 93 62 E-mail dat.ed t/1-3/1-5 f rom Ms. Mul-l-inax 1-0 to Mr. Binns, Subject : Fwd: Messages for Social- Media 11 Exhibit 94 65 a2 E-mail- dat.ed 1,/L3/1,5 from Ms Mul-linax to Ms. Driebe, Subject: Fwd: Messages l_3 for Social- Media 1"4 Exhibit 9s 68 E-mail dated l/]-3/15 from Ms. Mul-linax l_5 to Ms. Zellner and Ms. Craighill, Subject: Fwd: Messages for Social Media L6 Exhibit 96 68 t'7 E -maí I dated 1, / 1,3 / 1,5 f rom Lillian Govus to Ms. Mu11inax, Subject: Fwd: Messages 1_8 for Social Medi-a t9 Exhibit 97 69 E-mail dated 1/a3/15 from Ms. Mullinax 20 to Ms. Torres, Ms. Garland and Ms . Shatrar, Sub j ecL : Pres s release 2L r/:-3/ts

22 Exhibit 98 69 Press Release 23 24 (Al-so discussed were previously marked Plaintif f rs Exhibits 13 and 49.) 25

\

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1 APPEARÄ.NCES OF COUNSEL:

2 On bekralf of tkre Pl-aintif f :

3 KEVIN H. THERIOT, ESQ. KENNETH LT . CONNELLY, Esq . 4 All-iance Defending Freedom l-51-00 N. 90th Street 5 Scottsdale, Arizona 85260 (480) 444- OO2O 6 ktheroit@adf 1egal . org kconnel ly@adf 1ega1 . org 7 CHRïSTïANA HOLCOMB, Esq. I Al-l-iance Defending Freedom 44O First Street, N.W. 9 suite 6oo Washington, D. C. 20001- 10 (zoz) ¡g:-8690 chol-comb@adf 1ega1 . org 11 On beLral-f of the Defendants: 1-2 KATHRYN J. HINTON, Esq. 13 Baker Donelson Bearman Cal-dwel-l- 6¿ Berkowitz, P.C. L4 341-4 Peachtree Road, N. E. Monarch Plaza, Suite 1-600 l-5 Atlanta, Georgia 30326 (qoq) zzL-65L2 l-6 khinton@bakerdone I son . com

L'7 Al-so Present: Kelwin J. Cochran l-8 L9 Videographer: Brandon Brantley 20

2L

22

23

24

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) 1 THE VIDEOGRAPHER: This is the

2 beginníng of Media Number 1- in the

3 deposition of Mel-issa Mullinax in the

4 matter of Kelvin Cochran versus City of

5 Atl-anta, êt âf . , Case Number 1: l-5-cv- 00477 .

6 Today's date is February 23rd, 2017.

7 The time on the monitor is 9:38 a.m. My I name is Brandon Brantley. Irm the

9 videographer. The court reporter is

1_0 Suzanne Beasley. We are here with Huseby

l- 1- Global Litigation.

T2 Counsel-, please ínt,roduce yourselves,

1_3 after which the court reporter wíl-l swear ) I4 in t.he witness. 15 MS. HOLCOMB: Christiana Holcomb, T6 Ken Connelly and Kevin Theriot for the t7 Plaintiff Kelvin Cochran.

18 MS . HINTON: Kathryn Hinton for the t9 Defendants. 20 (The signature of t,he wit,ness Lo the

2T deposition was reserved. ) 22 MELISSA .] . MULLINAX, 23 having been duly sworn, was examined and testified 24 as follows: 25 )

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1 EXAMINATÏON

2 BY MS. HOLCOMB:

3 O. Good morning, Ms . Mull-inax.

4 A. How are you?

5 O. I'm well-, thank you. How are you?

6 A. Good.

7 O. ï'm Christiana Holcomb. Ttm one of the I attorneys representing the plaintiff Kelvin Cochran

9 in this case.

10 Ir,loul-d you please state and spell your full

11 legaI name? t2 A. Sure. It's Melissa June Mullinax.

13 M-e-1-i-s-s-a,.Tune, Mullinax, M-ü-1-1-i-n-a-x. L4 O. I'l-1 be taking your deposition loday. 15 Have you ever been deposed before?

1"6 A. Yes. L7 O. And in what situation? 18 A. In a case involving an Indian tribe in

T9 Mississippi. 20 O. Vüell, I'd like to go ahead and go over a 2T few introductory mat.ters, just so that wetre on the

22 same page regarding the deposiLlon and tô make sure

23 you understand the procedure.

24 The courL reporter and the videographer

25 will be recording both my questions and your answers. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 7 of 141

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) 1_ As a resul-t, it ' s really important that neither one 2 of us talk over the other and that v\¡e t,hat, you

3 respond with verbal- responses. She canrt very well

4 record head shakes and nonverbal- cues.

5 Also I'11 try to wait, unt,il- you f inish

6 responding before I ask you the next question and I

7 ask t,hat you do t,he same for me, wait until I've I completed my question before providing your ans\^/er.

9 And if I ask a question that's unclear to 10 you, please just ask me to clarify it. I'l-l- be happy

1-1 to do so. And if at any point later in the T2 deposition you recal-l- something that you would like

13 to add to your answer, please go ahead and l-et me

1,4 know, and we'l-l- make sure you're able to do that at. 15 that, üime. !6 You've got water. We have coffee t7 availabl-e. If any point you need a break, please 18 just l-et. me know. I'l-1 go ahead and finish that l-ine t9 of questioning and then we can definitely take a 20 break. And Irll probably want one at some point, as 27 wel]. 22 A. Okay. 23 O. Now I'm going to ask you a couple of 24 questions related just to your condit,ion t,oday. How 25 are you feeling?

I

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1 A. F'1ne.

2 o. Are you under a doctor's care for any

3 illness?

4 A. No.

5 0. Are you t,aking any medication or drugs

6 t,hat. might impair your ability to respond accurately

7 t,oday? I A. No.

9 O. Have you ever been a party to a l-awsuit 10 before?

11 A. No. I2 a. You said you had been deposed before?

13 A. (Witness nods head af f irmatively. ) t4 O. Have you ever Lest,if ied in court.? 15 A. No.

1,6 0. And do you underst,and that you're under t7 oath today, and so the testimony that you provide is 18 of t.he same import as if you \^/ere testifying in a

1,9 court of law?

20 A. I do. 2L a. Did you review any documents in 22 prepa-r.dLiun for youl deposiIion Loday?

23 A. r did. 24 O. And what were they? 25 A. E-mails that I had sent and the ordinance. www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 9 of 141

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) 1 That's it.

2 O. Did you bring any documents with you

3 today?

4 A. In my briefcase, in my bag.

5 O. Do you have documents in your briefcase

6 related to the matter?

7 A. No. I O. Did you speak with anyone about your

9 deposition other than counsel? 10 A. No. 11 O. Now we're just going to move into some t2 general questions about your background. Illhat is 13 your address? Just city and state is fine. ) T4 A. Atl-anta, Georgia.

1_5 O. And how long have you lived in Atlanta? t6 A. My whole life. L7 O. Are you married?

1_8 A. No. !9 O. Do you profess any religious fait,h? 20 2t O. What's the highest level- of schooling that 22 yourve complet,ed?

23 A. A bachelor's. 24 a. And where did you go to college? 25 A. Agnes Scot.t College. )

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1 O. And what was your major?

2 A. Political science and rel-igious studies.

3 O. Did you pursue any post,-bachelor studies?

4 A. I started law school, but didn't f inish.

5 0. Tell me about your employment, history.

6 ,-Tust a brief overview is f ine.

7 A. I started my own firm almost right ouL of I college and ran that until 2009, when I sold it to a

9 firm in D.C. called The Edison Group. And then I 10 worked for this Indian t.ribe ín Mississippi until

1_1 20!I, and then I came to work for the mayor in 2012. t2 O. V'lhat type of firm? 13 A. It was a public affairs firm. T4 0. So you began working f or t,he Cít,y in 2012? 15 A. Uh-huh. T6 0. In what position? t7 A. I came on as the womenrs policy advisor

18 and then moved into communications in the mayorts

79 office for two years. And Lhen in August, of 2014

20 moved over t,o become his senior advisor. 2I 0. Describe a litt,le bit about your position

22 cis Llie womenI s pol icy advisor , please . 23 A. At the tíme the mayor wanted to launch a

24 womenrs incubator, entrepreneurship incubat,or, and so

25 I came on to essentially put that program toget.her, www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 11 of 141

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1 t,he structure of that program. And I did that and

2 then moved into communications, so t.here was a hold

3 there.

4 O. And what were your responsíbilitíes in the

5 communications department?

6 A. I handled I was the sort of

7 amorphous because of just the nature of the office, I but, the operational- departments. Any major policy

9 initiatives or any complicat,ed press requests would 10 come to me for the operational departments. I was a

11- planner and st.rat,egist. and writer for the chief I2 operating officer. 13 0. All right. And so in August of 201,4 you T4 indicated you became senior advisor 15 A. Yes. T6 a. to Mayor Reed. Pl-ease describe your

1,7 job duties in that position. 18 A. Al-so somewhat amorphous, but. I managed his t9 external- rel-at,ionshíps in certain communities, 20 certain constit,uencies, I guess, 1rou'd say. I work 2t with him on all the appointment.s to boards and 22 commissions that he makes. I project manage projects 23 t.hat are important to him that are not going well or 24 need a boost,. 25 0. So in talkíng about managing his external- www.huseby.com Husebyn Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 12 of 141

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1 relationships, lou mentioned cert,ain communities and

2 constit,uencies. Could you expound upon that?

3 A. Sure. The womenrs community, the LGBT

4 community, t,he faíth community. It.'s rea11y as needs

5 arise. Neighborhood, neighborhood groups, for

6 example, around Turner Field. 'Just it ' s 7 really it's not, set. TL,'s not, defined. Tt.'s just I t,here are some relationships t.hat he manages directly

9 and doesnrt need outside support, and others where I

10 come in and others come in. 11 O. And what, rel-at.ionships might, he coul-d

T2 you provide some examples of relatíonships that he

13 wouLd direct,ly manage? I4 A. All of his national political 15 rel-at,ionships. So when I say "external, " I don't 16 mean the DNC and those kinds of things. That's what t7 I'm saying. 18 O. How frequently do you interact with t,he 19 mayor?

20 A. Pretty of ten. 2I O. Illoul-d that be on a daily basis, a weekly 22 basis?

23 A. Certainly weekly, you know, when he's in

24 the office. 25 a. What would be your primary met,hod of www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 13 of 141

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) 1 communication with him?

2 A. Talking \,vit,h him in the hallway or in his

3 office.

4 O. Do you use e-mail very much

5 A. I do.

6 O. when communicat,ing with the mayor?

7 A. I don't. I O. What, about communications with his senior

9 executive t,eam? 10 A. I talk with them al-l t,he time. I'm part 1L of that senior executi-ve team. I'm not sure which

1,2 group you're talking about exactly. 13 O. All right. Do you have any City-issued t4 equipment for use in your job? 15 A. I do. l6 O. And what. t,ypes of equipment? t7 A. I have a celI phone. That's it. I don't

l_8 have a laptop, L9 O. Do you have a deskt.op? 20 A. I do. 2t a. Do you have a City e-mail accounL? 22 A. I do. 23 O. And what about a tabl-et, or iPad? 24 A. I don't. 25 O. Okay. Have you ever used your City-issued )

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1 equípment for personal- use?

2 A. Irm sure.

3 O. Okay. And what type what examples

4 could you provide of t,hat,?

5 A. My children call on my Cit,y cell phone, so

6 I hear from them.

7 0. So calls f rom f amily members on your Cit,y I cell phone. Have you ever sent personal e-mails from

9 your City of Atlanta account, e-mail account?

10 A. ïtm sure.

11_ 0. Do you have a Facebook account? L2 A. I do. 13 O. Have you ever checked your Facebook t4 account from your City desktop? 15 A. Probably. t6 O. Or potentially paid a bill online using L7 your City computer?

18 A. No. I never do that. I don't pay bills. I9 O. Are you aware of any City employee ever 20 being disciplined for incídental- use of City-issued 2I equipment?

22 A. Could you repeat that question? 23 O. Are you aware of any City employee being 24 disciplined for personal use of Cit,y equipment?

25 A. Irm not. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 15 of 141

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) 1 a. How long have you known Chief Cochran?

2 A. Since I came onL,o t,he City, not I was

3 hired in March of 2012, so not right a\^ray, but, very

4 soon after that.

5 O. Tell me about your rel-ationship with him,

6 interact,íons with him.

7 A. Professional- and cordial . I O. How often would you interact with him in

9 your official capacit,y?

1_0 A. I woul-d see Chief every Monday at, cabinet,

t- 1- and during my time in communications, whenever there t2 u¡as a, you know, bigger issue beyond what hís

l_3 information offícer could or shoul-d handl-e, wê would t4 talk. 15 a. ülhat. do you know about his reputat,ion in t6 the community prior to November of 2014? T7 MS. HINTON: Object to form. 18 You can ansl^/er.

T9 THE WITNESS: I don't. Not much.

20 BY MS. HOLCOMB: 2t O. Reputation within t,he City of Atlanta? 22 MS. HINTON: Object to form. 23 THE WITNESS: I don't know.

24 BY MS. HOLCOMB: 25 O. .fust based on your personal perception. ) www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 16 of 141

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l- A. Of his representation within the cityt

2 O. Uh-huh.

3 A. Prof essional- .

4 O. Vühen did you first become aware t.hat the

5 chief had writt.en a book?

6 A. I don't, know t,he exact d"y, but it \^ias the

7 day that, Yvonne Yancy in late November brought, it to I my attention.

9 O. And how did she brinq that to r/our 10 at t ention?

11 A. I don't remember exactly. L2 O. Do you know what the title of the book is? 13 A. Vüho Told You That You I¡lere Naked? L4 0. Do you know when the mayor might have

1-5 become ah¡are aware when Chief Cochran scratch

L6 t,hat. t7 Do you know when the mayor became aware

18 that Chief Cochran had writt,en a book? t9 A. I don't other t,han when we all discussed 20 ir. 21" O. And when woul-d y'aIl have discussed it? 22 A. Aft,er Yvonne brought it to my attenLíon

23 and to others. Late November. 24 0. Talk to me about that, meeting. 25 A. Which meeting? www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 17 of 141

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) 1 O. The meeting which y'all discussed the

2 book.

3 A. There was an inf ormal- gathering in t,he

4 mayor's office where Yvonne laid out what she had

5 read and discovered. People I remember there \,vere

6 a number of phone calls from Council-man Wan was

7 mentioned. And there was, 1rou know, sort of a I typical round-robin conversation about what. do you

9 think?

1-0 O. How was the meet,ing scheduled? How did it 11 come about.?

T2 A. It tvas not formally scheduled. It was, l-3 Yvonne and Cathy came down there. They're on

T4 different floors than the mayorts executive suite. T 15 am a few doors down from the mayor. His deputy chief L6 of staff , Kat,rina Parks, is next to me. And so it l7 \^Ias the mayor is availabl-e Lo speak no\^r, let's have 18 this conversation. So it was kind of a gat,hering.

1_9 O. Who was present. at t,he meeting? 20 A. I don't remember everybody because I'm not

21- sure that Mike GeisLer, who was the COO who was on 22 our fl-oor, \^/as there. I donrt think that he \^ras. I 23 was there. I think Katrina Taylor-Parks was t.here, 24 and Yvonne was there, the mayor was there. I believe 25 Cathy and Candace were there. l

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1 O. Vühat. did Yvonne say during the course of

2 that meeting?

3 A. I don't remember exactly what she said,

4 but she laid out what she had covered in the book.

5 O. And what was that,?

6 A. Vüell, t.hat the book existed. That the

7 concerns about the content,, the concerns about the I process. I don't, remember exactly what she said.

9 O. Sure. Just generally, do you recal-l what

1_0 she mentíoned about the book's content?

11 A. That it was offensive t.o a wide array of

T2 consLit,uencies. 13 O. Did she provide examples?

T4 A. From ühe book? 15 0. Provide examples, excuse me, of t,he

1,6 constituencies that might find it offensive? t7 A. Yeah, I think she mentioned l,vomen. She 18 mentioned, 1roll know, the gay community. She I9 mentioned what I remember from the discussion was

20 women, the gay community, .lewish community. 21, O. What, about Ms . Taylor? Tllhat, did 22 Ms. Taylor say during the course of the conversatíon?

23 A. I don't remember. There was a lot of back

24 and forth. 25 O. Back and forth related to? www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washingtono I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 19 of 141

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1 A. You know, kind of shock that you know,

2 everyone/ I think, felt like blind-sided by this. So

3 t,here was a lot of conversation about, 1rou know, 4 where t,his came f rom, who knew abouL this, did Mike

5 Geisl-er know about this? So it. was it wasn't, a

6 structured conversat,ion. It was, you know.

7 O. Let, me back up to Ms. Yancy. Did she I indicat.e who had provided her a copy of the book?

9 A. I don't remember. 10 O. What about, t,he mayor? What did he say 11 during the course of the conversation? t2 A. Not much. You know, he's very 13 deliberative. So and what he typically does when !4 we come together like this on l-ots of issues, he 15 wants to hear what, all of his folks think. I L6 remember when I said ühat I was surprised by this and L7 lhat I felt like we needed to go sl-ow and not react

1_8 in a knee-jerk fashion. t9 Because my experience with Chief Cochran, 20 particularly around gay pride events, was that he'd 2L always been very supportive and that, you know, 22 didn't real-Iy know how to place all this, but that I 23 knew that, in our interactions around things that he'd 24 been supportive of gay firefighters and others 25 invol-ved in pride, had always you know, all the www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 20 of 141

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1_ resources of the fire department were available.

2 And I do remember t,he mayor nodding. I

3 felt like he heard that and agreed with that

4 assessment so

5 O. Were there other voices in the room that

6 shared your perspective?

7 A. Yeah, Lhere \^iere lots of folks ín the I room. Certainly Katrina want,ed t.o go slow. I mean,

9 I dontt remember a l-oL of what, Candace said, but.

10 yeah.

11 O. I¡,lhat. about Ms . Hampton? What did she say? 12 MS. HINTON: I want to just provide

13 some dírection since she is the city 74 attorney. If Ms. Hampton was providing any

15 1ega1 advice to anyone in that, room, then t6 don't, touch that. If she's just speaking I7 about the facts

18 THE V\TITNESS : I don' t remember. I t9 don't remember what Cat,hy had t,o say.

20 BY MS. HOLCOMB: 27 O. And Candace Byrd? 22 A. I don't remember specifically. 23 a. Did Yvonne Yancy bring excerpts from the 24 book Lo t,hat meeting?

25 A. I don't remember that. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - WashÍngton, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 21 of 141

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) 1 O. Do you recal-l seeing excerpt,s in t.hat, Lime

2 frame?

3 A. I remember yês, at some point in t,he

4 days surrounding it, T saw excerpt.s .

5 O. Was anything said at t,he meeting about

6 whet.her or not Chief Cochran had gotten approval- from

7 the et,hics board? I A. Yeah.

9 O. What hras t,hat,? 10 A. I¡fell, L.here were questions about whet,her

11_ that had been had happened. I don't remember if, L2 at that meeting, there had been a discussion wíth 13 Nina and if we knew anything. It was really kínd of

T4 the point of my comment, which is ühat \^¡e don' t know 15 a lot, right, now, this is out of the blue and let,'s L6 see what 77 O. lrlas anyt,hing said about whether t,he book L8 \^ras for sal-e? I9 A. I don't. remember. 20 a. Tiùas anyt,hing said about whether the book 2I had been given to employees? 22 A. I don't remember that either. 23 O. T¡üere any documents given out during that 24 meet,ing?

25 A. No, not that, I can recaLL.

)

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1 O. What ü/as t,he consensus at, t,he meeting? z A. To be deliberat,e and to investigate.

3 O. Were any specific actíon ítems discussed?

4 A. Not, that. I can remember.

5 O. Vlhen you say the consensus was to

6 investigate, what, was t,he plan to go about that?

7 A. I don't. know what. the plan was other than I t.he law depart.ment wou1d t,ry t.o uncover the, you

9 know, the timing of how this had happened. 10 O. So the law department v/as tasked with 11 following up on the matter?

L2 A. I woul-dn't say they were t.asked, but, t.hat.

13 was my understanding of what next steps were. There 74 !üere no next steps f or me. The next steps \^rere f or 15 the law department, âs far as I recal-l. t6 O. Did you take any notes at the meeting? \7 A. No. 18 a. Did you observe anyone else taking notes? 19 A. Huh-uh. I don' t think so. 20 O. And anyt,hing else you remember about the 2T meet.ing?

22 A. No. 23 O. Were you ever given a copy of 24 Chief Cochran's book? 25 A. I don't. think so. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 23 of 141

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1 a. Did you ever purchase a copy?

2 A. I did noL.

3 O. Vühen did you first become ah/are that it

4 was publicly available for sale?

5 A. Probably Lhe day that Yvonne told me about.

6 it, that it was available.

7 O. Did you ever read the book? I A. I did noL.

9 0. And you indicat,ed t.hat you had seen 10 excerpts from it?

11 A. Uh-huh.

1"2 O. Do you recalL who provided those excerpts 13 t,o you?

1"4 A. I think it was Robin Shahar. 15 O. And do you recalI what those excerpts were t6 about?

L7 A. They were about the I don't remember

18 exactly what it said, but it was secLíons around L9 LGBT. I guess the sinfulness of that, and I remember

20 something about beastiality. And I don't remember

2L much. 22 O. How did you respond t,o t,he excerpts that 23 you read?

24 MS. HINTON: Object, to form. 25 THE hIITNESS: How did I respond to www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 24 of 141

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1- them? You know, somewhat, shocked, but

2 not just somewhat shocked.

3 BY MS. HOLCOMB:

4 O. Iirlere you aware during the course of your

5 professional relat.ionship with Chief Cochran that he

6 was a Christian, professed to be a Christian?

7 A. I don't think so. I a. So going back to that meeting, that

9 initial meeting with Yvonne Yancy and others related 10 to t.he book, did you later discuss those meetings

11 wit.h anyone el-se?

T2 A. Not that. I remember. You mean anyone el-se

13 besides who was in the room? T4 o. Yes. 15 A. No. 16 O. Did you ever have any additional t7 conversations with the mayor about Chief Cochrants

18 book?

19 A. Probably, but there wasnrt another meeting 20 that I was in with him. 2L O. Vühat. do you recollect, the mayor t,elling 22 you during Ehose conversaLions? 23 A. I don't recol-l-ect. I mean, it's likely 24 that we had conversations, but I don't remember for 25 sure and I don't remember content. rvww.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 25 of 141

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) t_ 0. Did you have any additional conversat,ions 2 with ot,her employees about Chief Cochran' s book?

3 A. V{ell, certainly Katrina and Robin and I

4 talked. I know I spoke \^rith Yvonne. I spoke with

5 Anne Torres. As t,hings unf olded, we had work to do

6 around it.

7 O. Describe your conversations with Kat,rina, I pl-ease.

9 A. Well, there \^/ere lot.s of them.

1_0 O. Start with the f irst one you recoll-ect. .

t_1 A. We had conversations about you know, my t2 job as the senior advisor woul-d be to manage the

1_3 exL,ernal reaction to this, so \^/e lalked about t.hat.

1"4 f remember that she was you knohr, we both wanted 15 t,his to go to go sl-ow and didn' t want t.he chief to L6 be terminat,ed immediately. t7 There was you know, there was a lot to 18 be invest,igated here to understand how t,his was going L9 to had impacted the department, and woul-d impact, 20 going forward, so we had those conversations. 2L a. Were some advocating t,hat t,he chief be 22 terminated immediat,ely? 23 A. I dontt remember anyone advocating 24 directly for that, but. Lhat's, you know, certainly 25 always a possibility in chaot,ic sit,uations. So

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1 0. Vühat do you recol-lect about your

2 conversations with Robin Shahar rel-ated to

3 Chief Cochran's book?

4 A. Well, Robin \,vas very very offended, and

5 was here as she in addition to being in the law

6 department, she was the mayorrs advisor on LGBT

'7 issues, so she was hearing directly from I constituencies and trying t,o manage those. So we

9 talked about how to do that and try to keep things 10 from becoming too inflamed. 11 O. Can you describe wít.h any more specificity T2 when you talked about, how to do that, how t.o manage

13 those relationships? Vühat did those conversations

T4 l-ook like?

15 A. It.'s three years ago. I mean, I remember

t6 her having a discussion about Councilman Tiùan and t7 t.hat. you know, to make sure he understood t,hat 18 t,here needed to be a full underst.anding of what.

19 happened and had approval been asked for and

20 received, how this impacted the department. 2t So it was like, basically, just like let.

22 eve-ryone ktrow th¿t you kuow, at tiris pc'ir:t there

23 had been I guess the decision was made for t,he

24 suspension and Lhe investigation. And so essentially 25 there \,vas a process here and we weren't going to jump www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 27 of 141

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) 1 to any concl-usions and t,o but, she was hearing.

2 She was gett,ing a lot, of phone calls directly.

3 O. What about your conversations with

4 Ms. Yancy?

5 A. Those were you kno\^r, I have l-ess memory

6 of those because I sit next. t.o Katrina and Robin came

7 to see me a lot. Yvonne I woul-d talk to kind I of not, in t,he hallway, but more like more

9 like so where we would any new information 10 t,oday kind of things. I don't really remember. 11 O. And Ms. Torres? I2 A. f started talking with Anne about. this

13 because I had just moved over, 1rou know, some months t4 earlier from communications so I was stí]] on the 15 ATL Media e-mail. So I was sLill get.ting I woul-d 16 see the communicat,ions t,hat, went around through that, T7 department. And I still did a bunch of the writing 18 for the mayor for press conferences and those kinds I9 of things, so I was talking with her about t,hat. 20 And then once the general assembly started 2t in ,fanuary after t,he termination, then I talked with 22 her quite a bit about t.he press conferences that were 23 happening across t,he st,reet at the state capitol, 24 both pro and con around the religious freedom bilI, 25 not not our stuff directly, but state legislation

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1 t.hat. was getting woven in to what lvas happening at

2 t,he Cít,y.

3 O. Do you know of any other Cit,y employees 4 who have written books?

5 A. I don't.

6 O. li'lhen was the decision made to suspend

7 Chief Cochran? I MS. HINTON: Object to form.

9 THE WITNESS: I don't, know.

10 BY MS. HOLCOMB: 11 O. Do you know who made that decision? I2 A. To suspend him?

1_3 O. Uh-huh. t4 A. I'd have to speculate. 15 O. Vühen did you learn that Chief Cochran had T6 been suspended?

T7 A. I donrt recal] . I don't. recal-l-. I assume 18 it, was the same day. I did know I knew that 79 Candace was meeting with him or with Bob Godfrey, and 20 t.hat they were having a díscussion with Chief 2t Cochran. 22 O. Ii'lhen you say that ttsame dry, t' in rel-ation 23 to 24 A. The same day that he was suspended. I'm

25 sure there wasn' t a lag in t,ime . I \^ras www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 29 of 141

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) 1 O. So you were not involved in any of the

2 meetings rel-ated to the decision to suspend him? Let

3 me rephrase t,hat.

4 You were not involved in the meeting

5 deciding to suspend him?

6 A. Right.

7 O. Were you involved in any of t.he meetings I about communicating about the suspension?

9 A. I had yes, I was invol-ved in several-

1_0 meetings with Anne and with the law department about

1_1 how to communicat.e it. t2 O. Tell me about, those meetings, please.

1_3 MS. HINTON: And just to insert I4 another instruction, to t,he ext.ent yourre 15 getting advice from the legal depart,ment, ín

T6 those meetings, don't speak to what that I7 advice is.

t-8 THE WITNESS: Irm sorry. Ask me the

1-9 quest,ion again.

20 BY MS. HOLCOMB: 2T O. So please talk Lo me about the meetings 22 you mentioned relating to communicating about t,he 23 suspension. 24 A. I real-ly just remember what I looked at in 25 my e-mail-s yesterday, but it was, you know, i

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1 essentially t.hat we were going to issue a statement.

2 I'm sure I edited the sLatemenL. And I remember

3 sayíng that, lou know, wê need to essentially try to 4 deescalate and let. t.his invest.igatíon play out.

5 O. Do you l

6 A. I don't.

7 O. But, you probably edit,ed ita

I A. (Witness nods head af f irmatively. )

9 a. Let's take a look, please hand the 10 wítness Exhibit 49 . I'l-1 give you a minute to l-ook 11 over that. L2 A. Okay. 13 O. Do you recognize this e-mail- chain? T4 A. I do. 15 O. Do you have any reason to doubt its t6 authent,icityt I7 A. No. 18 O. When was the meeting discussed in this L9 e-mail- chain held?

20 A. I don't know exactly. My memory is that

2L ít was t,hat dry, the 24Lh, that Monday, in the

22 af tert:r¡ot:. 23 a. Do you recoll-ect who attended t,he meetíng? 24 A. I can t,eIl you that Michael Geisl-er didn't 25 attend the meeting. Ot,her than that, I assume www.huseby.com Husebyr lnc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 31 of 141

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) 1 everyone el-se was there, but I don't remember.

2 O. So here approximately in the middle of the

3 page, Robin Shahar cautions against saying anything

4 rel-ated t,o disciplinary action or ensuring t,hat it

5 doesn'L, happen again.

6 Do you see what I'm referencing?

7 A. Uh-huh. I O. Did you share her view?

9 A. f don't I don't. real-ly remember my 10 reaction to that.

1_ 1_ O. Do you recal-l- what was said during t,his

1,2 meeting?

13 A. No. What, I remember about early days was ) 1,4 t.here was a l-ot of uncert,ainty. Anne had a certain 15 set of point.s. Yvonne said that was not accurate. 76 There was a lot of back and forth. And in t.he seat t7 that I sit in, I just didn't want to deal- in 18 uncertainty and I wanted to know I wanted t.o be

1,9 able to speak with what we knew to be true, and if we 20 didntt, I didn't want to say anything at aIl. Again, 2t try not, Lo inflame the external constituencies and 22 relationships t,hat we had. 23 O. When you say Yvonne had certain point,s, 24 what do you mean by that? 25 A. Well, Yvonne said you know, )

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1 contradicted Anne, that. what. Anne's points here

2 were not accurate t.hat it had been dist,ributed in

3 command staff meeting. I remember that KaLrina and I

4 \^rere both concerned that we didn't know.

5 There were a lot of lot of statements

6 floating around that we just, didn't, know how they all

7 fit together. I O. And when you say "here, " were you

9 referring to page 2 of Exhibit 49? 10 A. Yes. 11 O. Do you recal-l whether anyt.hing was said 72 about t,he cont,ent, of the book at this meeting?

1-3 A. I don't. L4 O. Do you recal-l whether anything was said

1_5 about. whether or not Chief Cochran had received L6 ethics board approval at this meeting? r'7 A. That was something very early on in the 18 early discussions that was really central . I t.hink,

T9 t.o me, âs I said, because I -- in terms of the 20 content, ffiy experience with Chief Cochran didn't

2L support what I had read. He never in my

22 rel-ationship with him and in my experiences wc:r'king

23 with him, I didn't see what he described in the book.

24 It, didn't manifest in my professional- experience wit,h 25 him. And so I was less concerned abouL Lhe content www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 33 of 141

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) 1 and more abouL this process.

2 And al-so didn't, want Lo, again, exaggeraLe

3 with the notion t,hat what h¡e hrere hearing external-l-y

4 was t.hat discrimination is rampant. in t,he cit,y, you

5 know. That's why l-ater in my e-mail-s you'11 see that

6 we had a campaign to push back against. that.

7 O. Were any documents given out, or discussed

8 at the meeting?

9 A. Not t.hat. I remember. 10 O. Do you recal-l- what the consensus of t.his

1_ 1- meeLíng was?

I2 A. I don't . 13 a. Any act.ion items come out of this meeting? ) T4 A. Not t.hat, I remember. 15 a. All right. Do you know anyt.hing about. an L6 investigat.ion that was done while Chief Cochran was

L7 suspended?

1-8 A. Yes. I9 a. What do you know? 20 A. I know that there was one. I believe that 2t law and HR did it joint,ly. 22 O. Uh-huh. 23 A. And to determine, again, the process 24 around approval for the book and the et.hics board and 25 discussions with employees. ) www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 34 of 141

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1 O. Were you involved in the investigalion at.

2 all?

3 A. I was not.

4 O. Did anyone discuss the investigation with

5 you?

6 A. Not until afterwards when I saw the final

1 report,. I O. Please hand the witness Exhibit 13. It's

9 already been introduced. Take a moment to l-ook

10 through that. 11 A. Uh-huh. T2 O. This is the investigative report prepared 13 by the city law department. Is this what, you t4 received?

15 A. Yes. t6 O. When did you first see a copy? L1 A. I can't I can't remember for sure. It

18 was T don't. know. I9 O. V'lould it, have been aft,er it was publicly 20 released? 27 A. No. I think I saw a draft a couple of 22 days bef ore. 23 O. Do you recall- who you received that draft, 24 from?

25 A. I don't . www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 35 of 141

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) l- O. Tiüas that, received via e-mail-, hard copy?

2 A. I think it was a hard copy.

3 (Exhibit 85 \^/as marked for

4 ident,if ication. )

5 BY MS. HOLCOMB:

6 O. Do you recall- receiving the e-mail?

7 A. I do.

8 O. And were you a\^rare that Robín Shahar would

9 be sending the e-mail-?

10 A. Uh-huh. I \,\Ias .

l_ 1_ O. What's this e-mail- about? L2 A. This e-mail- is abouL I said earlier 13 t.hat, Robin was getting lot,s of call-s, unhappy calls ) 1,4 f rom constituents. She thought, it woul-d be a good 15 ídea to reach out t,o ADL for t,heir not analysis,

76 but f or their opinion of this. And that, !\re t7 ant,icipated there ü/as a pretty hot religious 18 freedom bill from the general- assembly from the

t9 previous session that, we knew was gearing up and we

20 expected this would be swept up into that, and we

2L were trying Lo get, ahead of that wit,h external folks. 22 O. Who is ADL? 23 A. Itts t,he Antidefamation League. 24 O. Can you tell me about them? 25 A. It's a nonprofit whose mission is to fight

)

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1 discriminat ion.

2 O. And why did you think ADL's input vüould be

3 helpful in t.his sit,uat,ion?

4 A. It[hy did I? v{e]l, they are an ally who we

5 had been hearing from and knew and had been

6 they are an ally in the sense of the work that we'd

7 been fighting on religious freedom and the positions I there on the religious freedom bil]s at t.he general

9 assembly.

10 And also Robin was hearing t,hat. they

11 wanted to meet with the mayor, so \,\re wanted them to !2 have the information before they came to meet with

13 him so it woul-d be productive, not speculative. I4 O. Yourve ment,ioned. a couple of times

1-5 religious f reedom biIl. Can you t,ell me a little bit

L6 about that? I7 A. Iiüell, it's a series of bills introduced 18 around state houses around the country and in Georgia

l_9 specifically that would it.'s called religious

20 freedom, but the idea behind them is that pastors 2L don't have Lo marry gay couples if they don't want 22 Lo. Tirere's loLs of Ehings Eira[ ¿re invo]-ved in

23 that. The legislation changes from year to year. 24 O. And what, \^ras your involvement in t.hese 25 bilIs? www.huseby.com Husebyr lnc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - Ncw York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 37 of 141

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) L A. It, was the general-l-y the Cit.y doesn't

2 have a position and we don't, invol-ve ourselves in

3 those. Personally, I'm opposed to them. But this

4 year, in t.he 20:'5 legislative session, which start,s

5 in ,January, we knew leading up to t,hat, in November,

6 December Oct,ober, November, December, we knew that

7 it was coming and that it was going to be I controversial.

9 And then with this decision here, Ralph 10 Reed and other I guess it \^/as Frankl-in Graham and 11 ot,her evangelicals were picking up this cause, and we t2 real- ized that \^re \^rere going to get swept up into this 13 and be part of the conversation at the state, which t4 we wanted to avoid, buL t.hat didnrt happen. 15 a. Okay. The first paragraph here on L6 Exhibit 85, it indicates, "The request. was not coming

1"7 from the mayor himself, but from Mel-issa Mullinax and

1_8 I, " being Robin Shahar, 'rrequest.ing this issue be I9 l-ooked at further by ot,her faith-based l-eaders and

20 organization. " 2L By t'this issue, t' what. \^Iere you referring 22 to?

23 A. The issue that the decision to suspend 24 the chief to investigate this was getting people 25 u¡ere rushing to judgment about on both sides about

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1 discriminat,ion or nondiscriminat,ion and that we \^rere

2 gett,ing swept up into the relígious freedom

3 legislative package at, the state capitol. 4 a. Vfhy was it importanL Lo clarify t.hat the

5 request was not coming from the mayor himself?

6 A. Because I remember saying to Robin t.hat. I

7 hadn't asked him about t.his and thal I want,ed her to

I be clear that this was hre hrere doing what ü/e

9 thought. was the right thing to get us ahead of what,

10 was coming in January at the state capitol, but that

11 I had not talked to him about. t.his. t2 , O. What did you hope to accomplish by 13 reaching out to ADL? t4 A. I don't. remember exact.ly at the time, but

15 what we wanted was for the groups t.hat. we work with:

T6 ADL, Faith in Public Life, the I think there's a

L7 group of ministers that we regularly work with, t.hat

1-8 we were looking into this. And that, loLr know, oh t9 the one hand we had folks who were saying that werve 20 allowed discrimination against City employees by 2L having the chief as t,he f ire chief ; and on the other 22 Ir.and, w€ had people wir.o were saying that hre were 23 violating the chief 's First Amendment right,s. 24 And so \^re really just want,ed we wanted 25 our folks to know that we were working through this. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 39 of 141

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I L There's a process and

2 O. Picking up on what you just said. In any

3 of the meetings that you participated in rel-ated to

4 Chief Cochran, did any of them did anyone raise

5 the quesLion of whether or not they might, violat,e the

6 chief 's religious rights?

7 A. I don't remember that. I O. Going back to this ADL l-et,ter, why did it

9 matter what outside organizaL.ions thought of this

1-0 employment issue? 11 A. It didn't matter what. t.hey thought of the 72 employment issue. It mat.ters what they think of the

1-3 administration, and thatts, you know, my role to

1"4 manage those.

1-5 a. And who came up with the idea to have t6 other faíth-based l-eaders and organizat.ions l-ook at L7 the issue? 18 A. Robin and I both talked about, it, but,

1-9 there what was happening at the time is that 20 Reverend Barber from Lhe Moral Monday Movement in 2t Nort,h Caro1ina was coming down Lo Georgia. Peop1e 22 were it, wasnrt people were already lookíng at 23 this and so we want,ed to essentially engage t,hem in 24 the conversation and sâ1rr again, wê have a process. 25 You know, I -- at this point in December,

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1 I thought we were I didn't expect the chief to be

2 terminated, so I knew that. we were going to have to

3 manage an entire group of people who of

4 constituencies who were going to be unhappy that. he

5 wagnr t, .

6 And so hre were trying early on, I am, to,

7 you know, basically let, them know that werre noL I sweeping this under the rug. This is important to

9 us. So 10 O. What other faith-based leaders and 11 organizations did you cont.act to look at the issue?

L2 A. So t,here's a group called Faith in Public

13 Life that I understood was putting t,oget,her a press L4 conf erence f or early ,January, that t.he Cit,y didn't 15 part.ícipate in and typically, you know, wouldn't L6 part,icipate in, but I talked with some of t.hose I7 pastors, a Rabbi Josh Lesser, who had been an al1y. 18 a. Can you tell me a little bit more about L9 Faith in Public Life, that organízation? 20 A. It's a DC-based nonprofit and they work a 2t lot with Reverend Barber and the Moral- Monday

22 Moveurent. They were at that tinre looking to üpen a

23 Georgia office. I don't know if that actually 24 happened, but that's, you know, sort, of a group of 25 progressive churches and pasLors. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 41 of 141

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1 O. When you say trprogressiverr --

2 THE VIDEOGRAPHER: Itm sorry. Could

3 you move your microphone up higher for me?

4 THE WITNESS: Yes.

5 THE VIDEOGRAPHER: Thank you.

6 BY MS. HOLCOMB:

7 O. When you say t'progressive, " how do you I identify them as such?

9 A. They support. a womanrs right to chose, so 10 their faith is I donrt know how to describe 11 progressive religious folks. That. t.hey support, t2 marriage equalit.y Fait.h in Public Life supports 13 marriage equality, but, they support immigration t4 ríghts, a \^romanrs right to choose, all of those 15 things st,ill within their their faith framework.

1"6 O. So these other faith-based leaders and T7 organizat,íons t,hat you contacted, what types of L8 responses did you receive from Lhem, letters,

T9 e-mail-s? 20 A. No, no letters other than the letter that 2t came from ADL. What we what. I remember is that 22 t,hey wanted us to come over to t,heir press 23 conference. I ended up going, but no one else from 24 t,he Cit,y went,. And that they you know, t,hey 25 wanted they wanted to their their their www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washingtono DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 42 of 141

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1 point and their focus was to defeat the I guess it

2 was Senator McKoon's bill at, the time, the religious

3 f reedom bill, and that was really t.heir f ocus .

4 And they also were concerned that this

5 employment, issue was get.ting wrapped up in a cause

6 celeb for the for the other side in their mind.

7 O. Did you try to get different community I perspectives on t,he issue?

9 A. We were get,ting different, community 10 perspectives on the issue. 11 O. So you received both l-etters, e-mails in

T2 supporL of t.he chief and against the chief?

13 A. I didn't exactly get letters, I personally

1,4 didn't., but. I certainly heard f rom l-ots of people at 15 city council- meetings, ât commit,tee meetings.

L6 Uh-huh.

T7 O. But as far as the City intent.ionally 18 reaching out to t,he f aith community, you werenrt t9 intentionally seeking diverse perspectives? 20 A. I wasn'L reaching out t.o there \^¡as a

2T group of pastors that came up to the City, came to

22 city hall. Primarily I guess it hras primarily

23 black pastors, and I didntt talk with t,hem but that

24 wasntt that wasntt the community that I typically 25 worked with. So I know that they had a different www.huseby.com Husebyo Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 43 of 141

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) 1 perspect,ive than ADL and Faith in Public Life, some

2 of Lhem.

3 O. So if I understand you correctl-y, you were 4 primarily reaching out to your contacts. Those

5 organizations

6 A. Yes.

7 O. that, you primarily \,vorked witht I A. Yes.

9 a. And woul-d it be a fair characterization

1-0 that those organizat,ions would be supportive of

11 same-sex marriage?

L2 A. Yes. 13 O. And you did not reach out to faith leaders L4 that might hold t,he traditional beliefs about 15 marriage is the union of a man and a woman?

T6 A. I did not. L7 O. What happened next after t.his l-etter was 18 sent. to t,he ADL? I9 A. After t,his e-mail- was sent? 20 O. Irm sorry, yes. Thank you. 2T A. I remember that they asked for a meeting 22 with the mayor, and I passed that request, along to

23 the mayorrs scheduler. 24 O. Did you participate in that meeting? 25 A. No. )

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1 (Exhibit 86 was marked for

2 identífícation. )

3 BY MS. HOLCOMB:

4 a. The court reporter has handed you what has 5 been marked as Flaint,if f 's Exhibit 86.

6 A. Uh-huh.

7 O. PLease f eel f ree to t.ake a moment Lo look I that over.

9 A. Uh-huh. 10 O. Does this e-mail- l-ook accurate to you?

1-1 A. Yeah. L2 0. And do you reca1l sending it? 13 A. I remember being up into t,he wee hours of

T4 t.he morning. 15 O. You are referring to the 4:23 a.m. time t6 stamp?

1,7 A. Yes. This was I did a bunch of

18 research leading up to the generaL assembly in I9 January. Thatrs what this was about. I don't

20 remember exactly which cardinal this was about,

2L but 22 O. So Lhese a-r.'e yuu-r.' rroLes? 23 A. Uh-huh. 24 O. And you saíd they related t.o t.he upcoming 25 general assembly? www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 45 of 141

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) 1 A. Uh-huh.

2 O. What anti-LGBT l-awmakers and extremists

3 were you referring to?

4 A. This is f 'm not even I'm not sure

5 that this f irst sentence is somet,hing that I wrote.

6 I t,hink this might be a copy and paste.

7 O. okay.

8 A. But it was it was speaking nationally

9 because these bílls were t,hey introduced like 10 t,he Nort,h Carol-ina one that came a year l-at,er around 11 HB2 and the bathrooms. Yeah, I didn't include the t2 source here, but, 13 O. So your recollection is this was a copy ) I4 and past,e?

15 A. Yes.

1"6 a. And when yourre referring to bills in the 77 Georgia legislaLure, were you specifically referring

1-8 to the religious freedom bill t.hat you spoke of I9 earl-ier? 20 A. Uh-huh. 2t a. And why did you put Cochran in the subject 22 line?

23 A. For an easy search for myself because I 24 expected to do I was I think I did a bunch of 25 these. And as I said, t,he chief was being pulled in )

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1 as the example for t,he groups that were supporting

2 the religíous freedom bi1ls.

3 O. Did you take any action with respect t,o

4 t,his content aft.er you sent it to yourself?

5 A. Probably ínformed some of the documents

6 that I - - that I wrot,e in preparing to engage the

7 public and the faith leaders around the bills at the I general assembly.

9 a. Okay. Next, one.

1-0 (Exhíbit 87 r^ras marked for

11 identification. )

I2 BY MS. HOLCOMB: 13 0. The court reporter has handed you what, has

t4 been marked as Pl-aintif f 's Exhibit 87 . 15 A. Uh-huh. t6 O. Does this e-mail look accurate to you? l1 A. It does. 18 O. And do you recaIl sending íta t9 A. I don't, but 20 O. But no reason to doubt its authenticity? 2T A. Right. 22 O. IL l-ooks like, agaitr, all e-mail frout 23 yourself to yoursel-f . V'lhat \^/as the purpose of this

24 e -mail ?

25 A. More research and a reminder to l-ook at www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 47 of 141

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I 1 the evidently the Times Union art.icle, though I

2 don't, remember that one, and t,his Pope Francis note.

3 a. So t,he Pope Francis note related to 4 Exhibit 86?

5 A. (Witness nods head af f irmat,ively. )

6 O. And you don't recall what Times Union

7 article I A. I don't.

9 O. you hrere talking about? 10 And, again, why were these items relevant

11- to Cochran? t2 A. Because the well, I was putt,ing

13 together, from what I remember, a message around our I4 belief that t.he Cochran decision hras an employment

15 íssue and not. you know, that he that he was t6 not going that he shoul-d not be seen or viewed in t7 this inst.ance as the, you know, the reason why these 18 religious freedom bills are required. L9 O. When did you first become aware that 20 Chief Cochran was goíng to be termínated?

2T A. Vüell-, I don't remember except that from 22 the e-maíls t,hat, f saw, I think I knew on Monday. 23 O. Bef ore his t.ermination on? 24 A. Tuesday. Because we were I was I 25 was getting ready for the press conference.

I

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1 0. Do you recall who informed you?

2 A. I don't.

3 O. Were any reasons given to you for the

4 termínation?

5 A. Ccrt,ainly. Thc convcrsatíon was that

6 the the violation of the process; that t,hat, his

7 book had not been approved by the ethics office; that I the mayor was not aware and had not, given approval;

9 that during hís suspension, he spoke to the press,

t_0 whích is really a cardinal- rule for all cabinet

11 members that you don't do that. Really, kind of the

T2 degrading of the rel-ationship between the chief and 13 the administration. T4 O. And who provided you with this 15 information? I6 A. I don't. remember exact,ly, but it L7 was that was the discussion. 18 O. Do you recall being in any meetings where 19 t,his inf ormat ion woul-d have been communicated to the

20 executive team?

2T A. I don't. remember. 22 0. Have y'Ju ever discussed Chief Cochrau' s 23 termination with anyone? 24 A. ï rm sure. 25 O. Do you recall who those conversat.ions www.huseby.com Huseby, Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 49 of 141

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1 might have been directed to?

2 A. You mean beyond our internal team?

3 O. Sure. 4 A. I t,alked about, ít with the I mean, f

5 described the terminat,íon as an employment decision,

6 not an attack on his religious beliefs with l-ot,s of

7 folks. The community you know, communíty l-eaders I who called, people who came to council meetings.

9 V'lhen I attended the press conference that 10 Faith in Public Life had, they came up there. I

l_L talked with the leaders of the press conference who

T2 were there about that. The message after the 13 termination was why why he was t.erminated and that.

1,4 it wasn't about the content of the book, but about 15 the process that had unfolded. t6 O. You mentioned phone cal-ls. lVho was T7 cal-l-ing or what types of phone cal-ls did you receive? 18 A. I mean, lou know, phone calls from I t9 mean, they would have been from the Faith in Public 20 Life folks at the press conference. I don't remember

2T all of who cal-Ied. A lot of what, a lot of my 22 interaction was with people in person at city council 23 and at commit,t.ee meet.ings. 24 a. With city council members themselves or 25 t,he public? www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 50 of 141

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1 A. No, the public.

2 MS. HOLCOMB: Take a break. Vrle've

3 been going for about an hour and

4 15 minutes. Let's go ahead and take a

5 break.

6 THE VIDEOGRAPHER: The time is now

I 7 I0 :41 a. m. I¡rTe re of f the record.

I (A recess was taken. )

9 THE VIDEOGRAPHER: The time is now

10 10:49 a.m. We are back on the record.

11 BY MS. HOLCOMB: I2 O. Werre back. So you mentioned thaL 13 Robin Shahar had received a number of phone cal-ls I4 from constituent.s expressing out,rage or concern. Do

15 you know who t.hose phone call-s were coming from? t6 A. I don't. T7 O. Did they communicate what types of

l-8 organi zat ions ?

L9 A. No. 20 O. 'Just that they've expressed 2t A. Right. 22 O. displeasure? 23 A. Yes. 24 a. You al-so testified about. a meet.ing that 25 t,he mayor had with some representatives. B1ack www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 51 of 141

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T pastors, I think you had mentioned?

2 A. I didn't say the mayor met. with t,hem.

3 O. I apologize. 4 A. I t.hínk they came to city hall. There was

5 a march, prot,est, march into city hall.

6 O. Do you recall whether they met with anyone

7 while they h¡ere at city hall? I A. f don't remember.

9 O. Do you remember approximately when that 10 was?

1_ 1- A. I believe it was in January. L2 O. Do you recall anything related to a

1-3 meeting that the mayor might have had with

L4 representatives from Elizabeth Baptist Church?

15 A. I don't. I think I remember that it

t6 happened I think that's is that 'Jasper Ïrüilliams t7 church? 18 O. I don't know. T9 A. I think I remember that it happened. 20 O. And then you talked a fair amount about

21" this religious freedom bilI. First, of all-, could you 22 explain it with a little more detail why you oppose

23 the bill? 24 A. Wel-l, f oppose the bill because I dontt, 25 think I think that, religious freedom is already rvww.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 52 of 141

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1 enshríned in the constitution and the Bill of Right,s,

2 and additional legislation is not necessary. And

3 it's really just, an at,t,empt to give Lo make legal

4 for folks to discriminate agaínst, people whose

5 beliefs they dontt share.

6 O. Did you ever express those beliefs in your

7 official capacity during your work at city hal1?

8 A. I don't think so.

9 O. So you received no pushback wit.hin the

1_0 City for your perspect.ive on that bill? 11 A. I didn't we didn't I wouldn't have I2 discussed the bilI, how I felt, abouL the bill or the 13 bills because it hias kind of a you know, it.'s a

T4 broader movement except for t.he fact, in t.he 201-5

15 session, that what hias happening aL city hall \,vas t6 being used as an example of why the bills were

L7 needed. So

1_8 O. And so would that have been, then, t9 discussed among t,he mayorts executive team?

20 MS. HINTON: Object to form. 2t THE II{ITNESS: Yeah. I mean, I don't.

22 remember that. I mean, I discussed with

23 Anne, Lhat I remember from the e-maiIs,

24 that we knew that t,his was happening and 25 want,ed to pushback against that. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 53 of 141

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) 1_ (Exhibit 88 was marked for

2 identification. )

3 BY MS. HOLCOMB:

4 O. The court reporLer has handed you \t¡hat ' s

5 been marked as Exhibit, 88.

6 A. Uh-huh.

7 O. Do you recal-l t,his e-mail? I A. I do.

9 a. Irm noticing in the to l-ine that, your name

1_0 is there twice. Do you recal-l- what e-mail accounts 11 you sent this e-mail- to? t2 A. I don't. I think I mean, I only have 13 two. I have my personal- and then I have my City, but

1,4 I don't know that t.hat, was to my personal . Oh, it 15 must. have because iL says one ís Melissa Mullinax and I6 one is Mullinax Melissa, so t7 O. Vühat is this e-mail? 18 A. This is these are my notes about, t,he

T9 press conference t,hat, was going to happen on Tuesday. 20 And the second sentence here reminds me that I

21" guess when f was told to begin to get a press 22 conference together or that one was coming, that. t,he 23 chief woul-d be given the option to resign. So that's

24 why t,hat ' s in there. 25 And up Eop, t.he support,ers is who I was

)

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1 suggesting would be standing there with the mayor.

2 O. Are these notes from a meeting?

3 A. No. These are my planning at. home at

4 night by myself.

5 0. Vüho communicated to you that, a press

6 conference was going to be necessary the fo1lowíng

7 day? I A. I don't remember. It might have been I

9 mean, it woul-d have been Yvonne or Candace or Cat,hy,

1_0 you know. As I said, werre all Candace and I are

11 in the same hallway with Katrina and Mike Geisl-er, so t2 it coul-d have been any one of them. 13 O. So no official meeting informing T4 A. No, not that f remember. 15 O. Directing your attention to t.he subject

1_6 line. What does COCH stand for?

T7 A. That's my I guess I got lazy and didn't

18 puL Cochran. t'supporL,ersrt 1-9 O. And what does in the body of 20 the message reference? 2L A. These are our constit.uency allies who I

22 LhoughL woulcl be imporLant t.o i:ave there with him. 23 O. Why did you think it would be imporLant to 24 have these particular individual-s?

25 A. Because \^re were because the publíc was www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 55 of 141

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1 very split on this. We were making a decision t,o

2 terminate t,hat \,vas around the you know, t,he

3 process issues, but there was such a drumbeat that

4 the City was had a lot of discriminat,ion and, you

5 know, they are just, all regardless of whether the

6 facts agree, the administration just has detract,ors.

7 And so they were using this as another way I to attack the mayor. He wasn't progressive enough.

9 He wasnrt, left, enough. He let, t,his go on for years. 10 He should have known about this, whatever, whatever.

11_ And so we want.ed our supporters there to kind of help t2 cal-m that and send the message out. 13 O. lrÏho is CT Vivian? L4 A. He is a SORS leader, pastor. 15 O. Vrlho is ühe rabbi you reference? L6 A. I didn't have anyone in particul-ar in !7 mind. I mean, it could have been ,fosh Lesser. It.

1-8 might have been the rabbi from the Temple. These are L9 just profiles other t.han CT Vivian. 20 O. And t,he whit,e f emaLe minister?

21" A. It could have been one of five or six, 22 but, you know. 23 a. And LGBT? 24 A. The same. I mean, ,Jeff Graham is the head 25 of Georgia Equality. That's probably who I had in www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 56 of 141

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1 mind. Someone that \^re v\¡ork wíth quite a bit, .

2 O. And how did you know t.hat, Lhese

3 individuals were supporters?

4 A. Wel-I, I didn't know that they \^Iere

5 supporters on this part,icular issue. They're our

6 natural allies on the mayorrs you know, his past

7 campaigns. I O. Are t,hey your natural alLíes on a

9 particular issue for the mayor?

10 A. Huh-uh, fo. In fact, wê you know, it

11_ comes and goes. T2 O. As you already mentioned, the second 1ine, 13 "Chief Cochran has resigned or been separated from

I4 t,he City today. " 15 Did the City have two plans ready to go, 16 one for terminat,ion, one for resignation?

1,7 A. I don't know. I was putting t,his

18 together, âs I said, talking points for Lhe mayorrs 19 speech writer. 20 a. And then the final paragraph, rrÏ want, to 2t make my and the City of At.lanta's position clear. 22 The city's noricliscrirnilial-ic-xr ¡rolicy is 23 nonnegotiabl-e, " and so on. 24 You see t,hat in the third paragraph? V{hat 25 \^ras your role in draf ting the Cit,y or the mayorrs www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washingtono DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 57 of 141

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) t_ statement for the press conference?

2 A. Tllell, I wrot,e that and then it h¡as

3 incorporated into the mayor I s sLatemenL or t,he quote

4 in t,he press rel-ease.

5 O. Did you writ,e the full quote in the press

6 rel-ease?

7 A. I was not responsible for t,he typo. I O. Fair enough.

9 lrlho reviewed the mayor's stat.ement for the

1-0 press conference?

11 A. Like1y I l-ooked aL it, but Anne Torres. L2 O. And who would have ul-timately been

1_3 responsible for approving that? L4 A. The mayor would have been responsible for 15 approving it. I6 (Exhibit 89 was marked for

t7 identification. )

18 BY MS. HOLCOMB: I9 O. Is this the press statemenL you were 20 referring to a moment ago? 2T A. Uh-huh. 22 O. Does the e-mail- look accurate to you?

23 A. It, does . 24 O. Why did you forward the Cochran press 25 reLease on to ,Janet, Ward? )

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1 A. Because Janet was the public ínformation

2 officer for the fire department, and she üias getting

3 calls asking for it from reporters.

4 O. And I apologize if you already answered

5 this. Did you draf t the ent.irety of this statement,i'

6 A. I did not.

7 O. Could you identify what, port,ions you I drafted?

9 A. WelI, I woul-d have sent this or given t.his 10 to Anne and so I think she took my sentence here

11 about the díscrimination and incorporated it into t2 this document. 13 O. So the remainder would have been drafted 14 by anot,her individual?

1-5 A. Uh-huh. t6 (uxhibíts 90 and 9I were marked for

T7 identificat ion. )

18 BY MS. HOLCOMB: t9 O. The court reporter has handed you two 20 exhibits that have been marked 90 and 9L. 2t A. Uh-huh. 22 a. Do you recognize Exhibit 90? 23 A. I do. 24 O. Does that, look accurate to you?

25 A. It, does . www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washingtono DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 59 of 141

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) 1- O. And is Exhibit 9L the exhibit or excuse

2 me the attachment for Exhibít 90?

3 A. Yes. 4 a. okay. So the t,it,le of Exhibit 90, "Faith 5 and Freedom Coalition, " what, is this document?

6 A. This is a document that I put together. I

7 mentioned earl-ier that. the Georgia Baptist Convention

8 and others were organizíng a big rally at the capitol

9 around the religious freedom bill, and they were

10 going Lo, you know, use Chief Cochran's terminat.ion

11 as kind of their rallying cry for the bill. But I2 then, ult.imately and what I was concerned about

13 was against the mayor and the administ,ration. t4 And so I put this together Lo recruit. 15 folks at, t,he capitol who would kind of give a

T6 different perspective on this. L7 O. When you say "give a different

1_8 perspective " ? t9 A. Essentially get our message out.. This top 20 part is our what I wanted people to say. 2T O. Did you draft, the first two pages? 22 A. I wrote the top, the draft statement for 23 the MKR supporter. The supporting facts are this 24 is, you know, research that I pulled toget,her from 25 varíous places.

)

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1 0. fVhat does MKR supporter stand for on the

2 very first, page?

3 A. Mayor Kasim Reed.

4 O. Who was it specifically drafted for?

5 A. Nobody specifically, but the folks I was

6 t,alking t,o in t,he Fait,h in Public Life Coalit,ion,

7 slate legislat.ors who I know supported t.he mayor. I O. Was t.his sLaLement. sent. t,o anyone else in

9 addit,ion Lo the t.wo you mentioned? 10 A. Over here in my not,es you mean? 11 a. Irm sorry. Was this document sent to

1,2 anyone? rtThis document'r being Exhibit 91.

1_3 A. I didn't e-maíl, I don't think, to

T4 anybody. And I üook I took copies over to the 15 capitol. I6 O. The notation in facing at the t7 right-hand margin.

18 A. Uh-huh. 19 O. Are these your notes? 20 A. They are. 2I O. Who is Reverend .Toanna Adams? 22 A. ,Joarrna Atlarns is Lhe rrrinisLer aL TriniLy

23 PresbyLerian. Shets a white woman. And ADL is

24 Anti -Defamation League . 25 O. And why did you write those two terms in www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 61 of 141

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) 1 the margin?

2 A. There were question marks because I was

3 t,hinkíng about, whet.her I wanted to get, t,his

4 specif ica1ly to those folks or to other peopl-e.

5 O. And asked them potentially to make those

6 st,atement s

7 A. Right, . I O. to the Georgia legislature?

9 A. Uh-huh.

1_0 (Exhibit, 92 was marked for

l- l- identification. )

L2 BY MS. HOLCOMB: L3 0. The court reporter has handed you what, has T4 been marked Plaintiff's Exhibit 92. 15 A. Uh-huh. T6 O. Does t,his e-mail look accuraLe to you? t7 A. It does. 18 O. Do you recall sending ita

1"9 A. I do. 20 O. Vrlhat is this e-mail- about? 2I A. I'm letting the senior team and the 22 communicat,ions folks know about t,he work around the 23 religious freedom bill and our attempts to get our 24 message out. and push back. 25 O. How did you know that ADL would be l

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*.,1^1 .,i^1., .:È^ ì^rr^-ô 1 I,,t,rrJ_LrU_Ly -^l^^^-.i--J-CrEcrÞrrrY rLÞ JEr-L-Er :

2 A. I must have heard it from Robin because I

3 didn't talk to Shelly myself. 4 O. In the second bull-et. point. there, /ou

5 mention a ,Jeff Graham, Georgia Equality t-lp-lld'¡

6 A. Uh-huh.

7 O. Did you solicit Georgia Equalíty to write I that piece?

9 A. r don't remember if I did or if Robin did. 10 O. But your guess is one of the two of you?

11_ A. Uh-huh. T2 O. And same thing with the Faith in Public 13 Life op-Ed? L4 A. I talked t,o t,hem. 15 a. And several times you've mentioned the 16 Faith in Public Life press conference. What was the

L7 topic or the purpose of that press conference? 18 A. The t,opic was to show that, there \^/ere 19 pastors in the around the state who, you know,

20 also hrere guided by their faith who opposed the bill, 2I and that there wasn'L a you know, monopoly or a

22 unif ied f aith corrununil-y ilr su¡l¡lorL of McKot-rrr' s bill

23 at t,he time.

24 (Exhibit 93 was marked for

25 ident,if ication. ) www.huseby.com Husebyr lnc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 63 of 141

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) 1 BY MS. HOLCOMB:

2 0. The court reporter has handed you what's

3 been marked Exhibit 93. Do you recognize this e-mail-

4 Lhread?

5 A. I do.

6 O. Does it look accurate to you?

1 A. It does. I 0. And you recal-l- sending itr

9 A. I do. 10 O. ,Jumping down about halfway down the page,

1- l- Anne Torres says, "Please forward to all of our L2 support,ers and organizations. rt

1-3 V'lho is she referencing? l4 A. Well, supporters would be I mean, she's 15 talking about, lou know, campaign supporters, al-lies I6 who have public you know, who have a social- media

T7 profile that can be helpful. Organizations woul-d be 18 the ones Irve ment.ioned earl-ier and any others, so

1,9 O. Can you 20 A. There's no list anywhere of you know,

2L the mayor has a campaign list, 1zou know, campaign 22 e-mail list, but we didn't, access t,hat. 23 0. So can you provide names of some of the 24 organizations other than t,he ones werve already 25 ment.ioned such as Faith in Public Life?

)

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1 A. No. And I actually didn't end up sending

2 out t.o any organizations. I didn't need to because

3 once t,he mayor started tweeting and the Cit,y started

4 tweeting, the organizat,ions who, you know, do t.his

5 kind of thing picked it up. I sent it out to

6 índivídual-s. ttdo 7 O. When you say to thís kind of thing, " I what are you talking about?

9 A. I mean who weígh in on social media, lou

1-0 know. 11 O. What are t.hese e-mail-s about? Vühat, are I2 you trying to accomplish? 13 A. V{e11, wê are t.rying to what we were t4 trying t,o do here, again, is tease out that. t.he

1_5 decision t,o terminate the chief uras not about content

T6 and it was not. an at.tempt to violate his religious

77 rights, but that and as I saíd, 1rou know, not all 18 t,his is speaking some of this ís speaking to the t9 pro gay groups who were still attacking us for not 20 having fired him immediately and for having had him

2t on as fíre chief, 1ron know, for any amount of t.ime. 22 So it was kind of a l-ot,s of nressages

23 for various audiences. And people across the country

24 were att.acking the mayor and saying that he had 25 viol-ated the chief 's civil rights, and so this I www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 65 of 141

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) 1- stand with Kasim was essentially a you know, a way

2 to bolster the mayor publícly in a situation where

3 there is getting it was getting national, negative

4 attent.ion.

5 O. Did you help craf t, these social- media

6 messages?

7 A. I didn't. I O. Do you know who drafted them?

9 A. I don't. I'm going to guess it was Anne,

1-0 but I don't. know.

11 t2

13 t4

15 (Exhibit 94 was marked for

T6 identification. )

I7 BY MS. HOLCOMB: 18 O. Do you recognize t,his e-mail-?

1_9 A. I do. 20 O. It looks very similar to the prior 2L exhibit. 22 A. Yeah. 23 O. Who is Norma Driebe?

24 A. Driebe . N'J, Norma ,Jack, that ' s my aunt, 25 who is an act.ivist with PFLAG and Parents and Friends )

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T r¡r^'l 'l T ¡^F r {- l--^.., ,.,L^{- .ì r ç^- 1 \Jl-^ç lJcÞu_Lo.rrÞ.^^l^.i ^*^ Ì/ìtg_Lr, r L,I\JIr L. t\Lrvw wllctL _LL Þuo.rrLrÞ^r ^*l ^ !\J! .

2 O. What do you mean by your first sentence,

3 rrThe mayor is getting hit pretty hard by the

4 religious right "?

5 A. Vrlhat, I said earlier, that, nat.ionally folks

6 were saying that the mayor had violat.ed the chief 's

7 civil rights and pretty ugly things were being said I about him on Twitter and on Facebook, and we wanted

9 to counter t,hat.. 10 O. Looking at the Twitter messages, the fírst

11_ one listed, "I stand with Kasim because all employees I2 have a right to a boss who does not speak of t.hem as

1-3 second-cl-ass cit.izens . " t4 Is it your understanding that, the 15 implicat.ion was that Chief Cochran spoke of those

76 underneat.h him as second class citizens? I7 A. Is that my understanding of what happened 18 or what this message is saying? I9 0. Is that your underst,anding of what thís 20 message is communicating? 27 A. No. Really so much of in mid-January 22 our work Ìracl really sirifl-ecl frorn Lire wiral- acLually

23 had happened to what was being said nationally and 24 pushíng back on t,hat,. And so t,hat.'s really what I 25 \^ras doing with the Faith in Public Life press www.huseby.com lluseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 67 of 141

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1_ conf erence . Again, I said earl ier, \^¡e woul-dn ' t

2 normally get invol-ved in t.hat. It,ts not, someLhing

3 the Cit,y needs to have a position on and the mayor

4 specifically didntt want t,o take a posit.ion on it.

5 And he had been approached in the early fall about

6 weighing in on this as a democratic l-eader. He chose

7 not t.o t,hen. I We only got, invol-ved because he was beíng

9 attacked and t,he City was being dragged into, 1rou

1-0 know, as t.he problem and the reason for these bills. 11 So my memory of this is t,hat, so much of this was I2 about responding to articles and things that they

1-3 \^/ere saying that, the mayor had that the City was I4 not, you know, a good place to work, that the mayor 15 wasn't. a good mayor, so L6 And, you know, the other piece t,oo is that L7 what t,he public can say in a Twitter message when 18 t.hey're spreading the New York Times art,icl-e, Lhe t9 public doesn't know the ins and outs of the 20 investigat.ion or the employment issues. And so they 2I can speak to what's out t.here publicly and that's 22 what, was out there publicly. 23 O. As you read t,hese t,weets, t,he first one, 24 for exampfe, does it imply that Chief Cochran did 25 speak to those beneath him as second-cl-ass citizens? www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 68 of 141

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1_ MS. HINTON: Object. to form. Asked

2 and answered.

3 You can still- answer.

4 THE WITNESS: Oh, okay. I don't,

5 think so.

6 BY MS. HOLCOMB:

7 O. And t,he second t,weet, in your I underst,anding, does that imply that discrimination

9 had been taking place in the workplace?

1_0 A. I don't think so. 11 (Exhibít 95 \^ras marked for

I2 identificat ion. )

13 BY MS. HOLCOMB: I4 O. Exhibit 95, same song, different verse? 15 A. Uh-huh. t6 O. V'lho is Natalie Zel-lner? I7 A. A friend of mine. And Cecily Craighill as

1-8 weIl. 19 O. Where do they work? 20 A. They boLh at the time worked at Emory. 21 (Exhibit 96 was marked for

22 identification. )

23 BY MS. HOLCOMB: 24 O. Do you recognize this e-mail? 25 A. I do. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 69 of 141

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) 1 O. Who is Lillian Govus? 2 A. She worked for a st,at,e senator,

3 Nan Orrock. She was her chief of staff, I guess.

4 (Exhibit.s 97 and 98 were marked for

5 ident,if ication. )

6 BY MS . HOLCOMB: 7 O. All right. Do you recognize Exhibit 97, I t,he e-mail?

9 A. I do. 10 a. Do you recall sending it? l-1 A. No, but, I don't doubt that I did. t2 O. And looking at Exhibit 98, is this the 13 press release tha! woul-d have been attached to that ) 1,4 ,Ianuary l-3th e-mail? 15 A. Yes. 76 O. Whose press rel-ease is this? I7 A. I guess I wrote t.his. l-8 a. For the City of Atlant,a?

1,9 A. For the City of Atlanta? 20 O. Uh-huh. 2t A. Yes. 22 O. And why did you send a copy of this Lo 23 Torres and Garland? 24 A. Well, because they woul-d have had to 25 be they wouLd have been the official folks to

)

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1 release it and to run it by the mayor.

2 O. Even given the time sLamp being 7 240 p.m.

3 on the 1-3th?

4 A. Right.. I go home and end up working a lot

5 more at home. So this is clearly a draf t t.hat, I

6 would have writ,t,en at home. I don't, know that t,his

7 actually ever was released. If it was, iL would be I on t.he Cit,y, you know, website and would be on City

9 let.terhead, but it looks like I wrote this.

10 O. Okay. Well, I ' l-l represent to you that

1_1 there is this press release on the website but it was L2 posted at l-east publicly around 2:30 p.m. 13 A. This one was? On the 13th? 74 O. I believe so. I have not compared it 15 identically. So I was just. curious if this \,\ras the L6 already rel-eased press release that you \Àrere then t7 disseminating or if it was 18 A. No. This is a different, press release t9 t,han the mayor's statement t,hat you gave me earl-ier. 20 O. So this would be a subsequenL one to be 27 released potentially on the 14th? 22 A. Uh-huh. Oh, right. 'l'hís one went ouL on 23 January 6Lh, so about the terminat.ion. This woul-d 24 have been something that, would go out officially with 25 the report. when we were releasing a report. www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 71 of 141

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) 1 MS. HOLCOMBE: All right. Let,'s take

2 a couple-minute break, and then I think we

3 are about, ready to wrap up.

4 THE VIDEOGRAPHER: The time ís

5 ]-]-:21 a.m. Werre off the record.

6 (A recess was t,aken.)

7 THE VIDEOGRAPHER: The time is now

I 11- : 31 a. m. Vüe ' re back on the record.

9 BY MS. HOLCOMB:

1_0 O. Ms. Mullinax, you previously t.estified 11 that there were some groups that had wanted L2 Chief Cochran to be t,erminated immediately. Do you

L3 recal-l- which groups t.hose were?

1"4 A. Not. with cerLaint.y, but. Georgia Equality

1_5 comes to mind. The Georgia Voice, which is a T6 newspaper but functions as an advocacy paper in my I7 mind. 18 O. Advocacy paper for what partícular issue? t9 A. Oh, yeah. IL's a gay paper. 20 O. Any other organizat.ions come to mind? 2T A. No. 22 MS. HOLCOMB: No further questions. 23 MS. HINTON: No questions.

24 MS . HOLCOMB: Thank you. 25 THE VIDEOGRAPHER: This concl-udes )

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1 Media Number 1- in the video deposition of

2 Mel-issa Mullinax. Werre of f the record at

3 ]-L:33 a.m.

4 (Deposition concl-uded at 1-l-:33 a.m.)

5

6

7 I

9

10

l- 1_

L2

1-3

L4

15 t6 t7 18

19

20 21 22

23 24 25 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 73 of 141

I(ELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on02123/2017 Page 73

) 1_ ERRATA SHEET a Pursuant. t.o Rule 30(e) of the Federal Rules of Civil Procedure a:nd/oy the Official Code of Georgia 3 "Annotat.ed 9-11*30 (e) any changes in form or substance which you desíre to make to your deposition test,imony 4 shall be entered upon the deposition with a statement of the reasons given for making them. 5 To assist you in maki-ng any such corrections, 6 please use Lhe form below. If supplemental or addit.ional pages are necessary, please furnish same and attach them to this errata sheet.

B

o T., t.þre undersigned, MELTSSA MULLIN.A.X, do hereby certify that I have read the foregoing deposit.ion and 10 that to the best of my knowledge said deposition is true and accurate (with the exception of the 11 following corrections listed below) .

a2

13 Page_ Line should read ) l4 Reason for change:

15

L6 Page Lr,ne should read: 17 Reason for change:

1B L9 Page_ Line should read: 20 Reason for change

2A 22 Page_ Line_should read: 23 Reason for change:

24

25 )

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ì 1 Page_ Line_should read: 1 Reason for change:

3

4 Page_ Line_should read

5 Reason for change:

6

7 Page_ Line_should read

tt Reason for change:

9 10 Page_ Line_should read: 11 Reason for change:

1"2 13 Page_ Line_should read: 1-4 Reason for change:

15 1-6 Page_ Line_should read A7 Reason for change:

1B Signat.ure 19 Sworn to and Subscribed before me 20 Knr(^ Jortr\Son , Norary pubric 23- rlnj-s 4O+tl day of -7/VLa,nC-h-1 aL+ My Commission Expires: 3-lvl4 ESB ¿¿

23

24

25

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1 CERTTF]CATE

2

3 G E O R G I A:

4 FULTON COUNTY:

5

6 I hereby certify that the

7 foregoing deposition hras reported, as I stated in the capt.ion, and t,he questions

9 and answers thereto were reduced to the 10 written page under my direction; that the

11_ foregoing pages L through 72 represent a I2 t,rue and correct transcript of the evidence 13 given. I further certify that I am not in 74 any r,r/ay financially interested in the

1_5 result of said case.

1"6 Pursuant. t.o Rules and Regulations

1"7 of the Board of Court Reporting of the

1_8 ,ludicial Council- of Georgia, I make the 79 following disclosure: 20 I am a Georgia Certified Court 2t Reporter. I am here as an independent 22 contractor for Huseby, Inc. 23 24 25 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 78 of 141

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1 T \^ras contacted by the offices

2 of Huseby, Inc. to provide court reporting

3 serwices for this deposj-tion. I witl not

4 be t.aking this deposition under any

5 contract that is prohibited by O .c.G.A.

6 L5-1,4-37 (a) or (b) .

7 I krawe no written contract to I prowide reporting services with any party

9 to t.he case, âDy counsel in the case, oT

10 any reporter or reporting agency from whrom 11 a referral- mj-ght have been made to cover t2 t.his deposit.i-on. I will charge my usual 13 and customary rates to all- parties in the 14 case.

t_5 This, tkre 7t.h day of Marckr, 201-7.

L6

L7

18 SUZANNE BEASLEY, B-1,TA4 L9 My commission expires on thre 24Lh day of August , 2OL8. 20 2I

22

23

24

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: l..account

) MuIlinar

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET ÄL. Melissa J. Mullinax on 0212312017 Index: accounts..Atlanta accounfs administration ally 36 :4 , 6 approached 53 :10 39:13 40:!7 67 :5 accurate 48:1-3 55:6 Amendment approval 31:15 32:2 59 : l-3 38:23 2t:6 26 :L9 44:70 advice 20:15 amorphous 32:16 46 z16 2921-5,!7 33 224 48:8 17 :'7 , I8 57 :22 advisor approved 58 224 amount 51" :20 1,0 : L7 ,20 , 48 z'7 6l:16 63:6 64 z2I 22 ]-1, z 14 analysis approving accurately 25zL2 26:6 57 z]-3, 15 8:6 35:15 advocacy approximatel-y action 22:3 71" :1"6 , !8 Anne 25:5 27:12 3L:2 5l- : 9 3t:4 33:13 advocating 46 z3 29:L0 arise t2:5 25221-,23 3l:74 32:L array 1- 8 : 1- 1 activist affaírs 52 :23 65:25 10:13 57:II article Adams 60:2I, 58: l-0 47 :1, ,'7 affirmatively 67 ztB 22 8:13 30:8 63:11- 65:9 add 7 :I3 47 z5 Anners 32zl articles 67 zL2 addition afternoon answers 6:25 26:5 60:9 30:22 assembly Antí- 27 220 additional- Agnes 9 225 defamation 35 : l-8 36:9 24:16 25zI 60 224 agree 55:6 44 : L8 ,25 52 :2 anti-Igbt agreed 20:3 46 :8 address 9:13 45:2 ahead 6:20 asÉessment ADL 35:15, 7:13,18 antícipated 2O :4 35: l-7 22 38:13, 35:2L 38:9 assume 28 zL7 !6 39:8 50:4 Antídefamation 30 225 4L :21 35 223 43:!,!3 aLlíes 54 227 ATL 27 z].5 apologize 6O:23 56:6 ,8 Atlanta 5:5 51:3 58:4 6l:25 63 : l-5 9:1-4,L5 appointments ADL' S 36:2 all-owed L4:9 15 z2I 38:20 11,:2L 69 :tB ,19

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KELVIN J. COCHRAN vs. CITY OF ATLA,NTA., ET AL. Melissa J. Mullinax on 0212312017 lndex: Atlanta's..boss Atlanta's 30:16 Beasley 5 : 1-0 67:L0 56:2L 46 220 beastíaIity bir L0 z2L attached avoid 37:I4 23:20 27 :22 69:I3 36: l-5 aware 1"4 z 79 , began 10:1-4 40:18 56: l- attachment 23 \624, begin 53:2L 59 z2 t5,r7 23:3 black 42:23 24:4 35:8 beginning 50 225 attack 49 z6 5:2 55:8 47:L9 48:8 blind-sided bel-ief 47:L4 attacked 19 :2 B 67 :9 beliefs blue 2t:t5 bachelor's 43 zt4 49 :6 attackíng 52:5 ,6 board 2L:7 64:19 ,24 9:23 32:!6 back ]-8:23, beneath 33:24 attempt 52:3 67 :25 64:16 25 t9:7 boards Ltz2I 24:8 3l- : 16 Bens 65: l-l- at,tempts Bob 28 : L9 33:6 39:8 big 59:8 6L :23 50:10,12 body 54:L9 bÍgger t5:12 attend 30 225 67:24 bolster 65:2 attended 66:24 7I:8 bill L4:16 book 1,6 :5 30:23 49:9 27 :24 , background 12 , 18 1,7 :2 9:72 35:18 attentÍon 36:1-5 l8:4,6,14 20:24 16:8,1-0,22 bag 9 z4 42:2 ,3 19:8 54:I5 65 z 4 BaptÍst 45:1-8 2tzI'1 ,20 22 224 23:7 attorney 5l-: l-4 59 z7 5t:2t ,23 , 24:L0, l-8 20 zt4 Barber 39:20 24 52:I, ro ,72 25:2 26 :3 attorneys 4Q:2I 32:L2,23 6:8 59 :9 ,1,I based L5 225 6I :23 33:24 48:7 49:L4 audÍences basically 62 220 ,22 64:23 26:21 40 :7 bil-l-s 14:18 book's 18 :10 Àugust 10:19 basÍs t2:21, 36:8,1-7,25 books 28:4 l-L:1-3 22 45z9,L6 boost L1,:24 aunt 65:24 46 :2 ,7 bathrooms 47 :18 boss 66 2]-2 authenticity 45:LL 52:1"3 , L6 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 82 of 141

KELVIN J. COCHRAN vs. CITY OF A.TLANTA, ET AL. Melissa J. Mullinax on0212312017 Index: Brandon..city Brandon 5:8 35 : 1-3 cautions 48:12,22 Brantley 5:8 49:76,L7 , 31:3 53:23 18 50:13, Cecily 68:17 56:13 break 7:17 , 15 58 :3 59:10 20 50 :2 ,5 celeb 42:6 calm 55:L2 64:15 ,2L 7t:2 cel1 L3 z1-7 66:L5 briefcase carnpaign 14:5,8 67 :24 69:3 9:4,5 33 :6 71,: L2 63 :15 , 27 central bring 9:2 32:L8 chief's campaigns 1,6 :9 2O :23 38223 3926 56:7 certainty broader 7I:14 64:25 66 z 6 Candace 52 :74 chain 30:1-3, chíIdren l7:25 L4zS brought 20 :9 ,27 t9 76 z7 ,22 28zL9 chaotic choose 4]-2]-4 bul-l-et 62:4 54z9,L0 25 :25 chose 4L:9 bunch 27:I7 capacity characterizati 67 :6 44:77 1-5: 9 52:'l on 43 z9 Chrístian 45:24 capitol checked 24:6 Byrd 20 227 27 223 1-42L3 Chrístiana 38:3,1-0 chief 11:11 5: l-5 6:7 c 59:8, 1-5 15 :1, 10 church 60:15 l-6:5,15,18 51-:14,1'7 cabinet L1 21,5 cardínal- churches l-5:10 AA.1A 1 . ã. av LJ.L¿A¿.V0.1 0 t1 48:1-0 ==. 40:25 48: l-0 22 :24 caII L4:5 24:5,17 citizens care I z2 25:2,L5,27 66 :1-3 , !6 called l-0 : 9 Carolina 67 :25 36:79 26:3 28:7 , 39:21 L5 4Q 2].2 ,20 city 524 45:10 32 :15 49 :8 ,21 ,2Q 9:13 1"0 ztL casê 5:5 33:1-6 1-3 :21, calling 6 :9 ,18 37 :24 1425,7,9, 49 z17 38 z2L 39 :4 Cathy L7:1-3, 1"4 ,1"7 , L9 , 422t2 calle t4:7 25 20:19 40:l- 23 ,24 45:25 17 z6 27 z2 5429 1-5:2,2I 47 z2Q www.huseby.com lluseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washingtono I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 83 of 141

KELVINJ. COCHRANvs. CITY OFATLANTA, ET AL. MelissaJ.Mullinaxon02l23l20lT Index:city's..constituents 16:1 20:13 19:I9 2t:6 communicating concerng ) 28:2 ,3 24:5 28:7, 13 :6 29:8, ]-8:7 33 :4 34 2L3 75 ,21 22 66:20 concl-uded 37:L 38:20 32 :1,5 , 20 communícation 72:4 40 274 33:16 39:4 13 :1 4l:24 45 :27 concl-udes communications 71, :25 42:L5 ,17 , 47 :Lt,t4, 2t ,22 20 54: l-8 10:18 conclusions 49:22 ,24 56 : l-3 IL:2,5 27 zL 13:8 l-5:l-l- 5L:4 ,5 ,7 57:24 condition 52:7,10,15 66: l-5 27 :14 ,16 7 224 53 : l-3 55:4 67:24 6L :22 56 z14 ,75 , 7I :42 communities conference 40:L4 2r ,25 64:3 Cochran's 11:19 72:7 67 z3 4]-223 ,9 ,13 22 224 community 69:LB , L9 47 225 24 21"7 25 2 2 12:3 ,4 70:8 4929,L7,20 26:3 48:22 L5:1-6 53:l-9,22 cÍty's 56:22 59: l-0 l-8: l-8,20 54:6 5'7 :! , City- íssued coffee 7:L6 42:7 ,9 , LB , 10 62:l.6, 24 49:7 -ã i3 :1,3 ,25 college rt otir a4 z2O 62:22 9:24 ,25 conferenceg compared cívil 64:25 10:8 2'7 : I8 ,22 7O:14 66:7 command 32:3 Connel-ly '7 compl-eted cI-arify :70 comment 5 :1-6 38 :4 7:8 9:22 21-: L4 conE errE us class 66:L6 complicated 222I,5 commíssione 11:9 clear 38:8 LL:22 33:10 computer 56:2L committee constituencies t4 z 1,7 12:2 Coal-ition 42 z 1,5 7I:20 59:5 60:6 49:23 con 27 :24 tB : 12 ,1"6 concern 26 z B 31,22]- cocH 54:16 communícate 40 :4 50 : 1-4 Cochran 5:4, 29 z ]-1" 50: l-7 concerned constituency 17 6:8 5422]- l-5: l- communicated 32 :4 ,25 l-6:15, 18 48:t9 54:5 4224 592]-2 constituents

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. MelissaJ.Mullinaxon02123l20lT Index:constitution..deposed 35:1-4 27 :3 48:25 46:1"3 53 :4 decision 50:14 58:19 26 223 coo 1,7 :2L 6l- : 1-3 63 z2 2826,17 constitution copies 60:14 52:l covered 18 :4 2922 37:9, copy 19:8 23 47 :1"4 contact 22:23 23:l craft 65:5 4925 55:l- 40:tt 34:t6 CraighilL 64:t5 contacted 35:L,2 68 zt7 deescal-ate 4]-277 45:6 , 13 cry 59:11 3O :4 69:22 contacts CT 55:13,1,9 defeat 42:t 4324 cordial 15 z7 cues 7:4 Defendants content correctly 5:19 18:7,10 43:3 curr-ou€t 70 : l-5 defined 12:7 24:25 councíI 32272,20, degrading 42 z 1,5 46:4 D 48 :12 25 49 :8 ,22 ,24 49:L4 Councilman D.C. 10:9 deliberate 64:L5 22 :2 t'7 :6 26 : L6 daily 72:21 contradicted deIíberatÍve 32:I counsel 5:12 date 5:6 9:9 l-9:1-3 controversíal day 1626,7 democratíc counter 66:9 23 z5 37:8 6'7 z6 country 28:L8,22, Conventíon department 59:7 36:1-8 24 30:2I tr4.'7 11:5 20:l 64:23 Ja. I conversation 2228,10,15 days 2!:4 L7 :8 ,1,8 couple 7:23 25 zt9 t8 :22 34:21 31:13 2626,20 19:3,6,7I 36 zL4 34 222 27 zL7 37 z]-3 couple-minute DC.BASED 29:1-0, 15 39:24 48:5 7Lz2 40:20 34:I3 58 z2 convcrsatíong couplcs deal 31, : t7 dcpartmento 24:I7 ,22 , 36:2L December 11:8, 10 24 252L,7, court 5 :9, 13 37:6 39:25 deposed 6 : l-5 l.1, ,20 6:24 8:I4, 8 :12 2622,L3 decíding t9 4424 29 :5

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. MelissaJ.Mullinaxon02l23l20lT Index:deposition..earlier deposition discovered 42 zL9 duly 5:23 :5 5:3,2L t7 DNc 1,2:16 duties 11": L7 6 2L4 ,22 díscriminate '7 :1,2 8:22 doctor's 8:2 52:4 E 9 :9 72:7. , 4 document díscrimination 58 :72 deputy 1-7:1-5 33:4 36:1 e-maiI 1-3:4, 59:5,6 27 I4:9 describe 38 :1, ,20 60:l-L,t2 27 :t5 I0 :2L 55:4 58:l-1- lL:L6 25:7 68:8 documents 30:13,19 26:LL 8227 9:2,5 35:l-,6,9, dÍscuss 1"1 4l- : 10 21, :23 33 :7 ,1,2 242]-0 34:4 4625 43 zL9 desktop dÍscussed 44:IO 13:19 domestic L6 z 1,9 ,2I 46:16 ,22 , 74:14 65 zL2 L7:L 22:3 24 53:7 , detail 5t:22 30: l-8 33:7 doors t7 :1,5 l-0, l_1,1,7 48 :22 doubt 30:15 57 :22 determine 60:13 33 :23 52:12 , !9 , 46:20 22 69:II 67:76 ,20 detractors 63 :3 ,22 d,iscussion 55:6

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: early..Facebook early 31:13 entirety 5:23 existed 1-8 : 6 32 :1"7 I8 58:5 , examples expect 40 :1, 14 40:6 , L2 L4 3 entrepreneursh 2L2 expecEecl 67 zS ip L0 224 18:13,15 35:20 easy 45:23 equality excerpts 45:24 4Iz12,73 Edíson 10:9 20:23 experience 55 :25 edíted 30:2, 2L:1,4 L9 :19 62:5 ,7 23 :1,0 7 ,7-2 , 32:20 ,24 7I21,4 75 ,22 Elizabeth experiences equipment 57274 excuse 18:1-5 32 :22 L3:L4,16 59: l- Emory 68:20 t4:7,27,24 explain executíve 5L :22 employee essentially !3 :9 ,1,I t42L9,23 I0 :25 L7 :L4 expound 72:2 employees 26224 48:20 expreEs 52:6 30:1,3 52:19 2L:21" 25:2 expressed 28:3 33 225 39:23 exhibit 59:19 65:1 50:20 38:20 3229 30:10 expressíng 66 :]-3. et aI 5:5 34 35:3 :8 50:1-4 employment ethics 2L:7 37:16 l-0:5 32:16 4421-,5 extent 29 zL4 39:10,L2 33 224 48:7 46 : LO ,7.4 external 42:5 47 zL4 47 :4 53:1, evangelicals l-1:l-9,25 49:5 67 :20 5 57 :1-6 L2:L5 37:11- 58:22 end 64zL 25 :13 events 19 220 7O:4 59:1,2,4 3Lz2L evídently 60 zt2 35 :21 ended 4]-223 47:l 6l-:1-0,L4 62224 63:3 exLernally engage 39 223 exact t6:6 33 :3 46:6 65 : l-5 ,2! exaggerate 68:11-,1-4, extremists enshrined 33:2 2L 69z7,1-2 45 z2 52 21, EXA}ÍINATION exhibits ensuring 6zL 58:16,20 F 3724 69 examíned :4 Facebook entire 40 z3

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET ÄL. Melissa J. Mullinax on 0212312017 fndex: facing..general L4 z11, 13 feeling 7:25 20:7 35:21 67223 ) 66zB felt a9:.2, 38:l-9,25 frequentLy facíng 60: l-6 L7 20:3 4IzaI 12:L8 52zL2 49 :7 ,2Q fact 52:L4 5224 59:15 f ríend 68 z 1-7 56:1-0 femaLe 55:20 60:5 6L:4, Friends facts 20:1-7 Field L2z6 22 66:5 65:25 55:6 59:23 fight 35:25 69:25 full 6:10 fair 43:9 fighting form 15 zI7 , 26:LB 57:5 5I:20 57 z I 36:7 22 23:24 functions 28 :8 52:20 faíth 9:19 7 I :1"6 final 34:6 68: l- L2:4 38:1-6 56 :20 4O:12 ,19 formally G fínd l-8:1-6 4l:IO ,1-2 , t7 :L2 15 42:18 fine 8:l- forward Garland 43:I,73 9:13 l-0:6 25:20 69:23 46 z7 fínish 7:5, 57 :24 gathering 49:I0,19 18 70:4 63:1-1- 17:3,L8 59:4 60:6 62:i2,i6, fire 20:! frame 2L:2 gave 7O:19 20 ,22 38:2I 58 z2 framework gay 18:18, 63:25 64:27 4L :1"5 20 19 z2O , 66 225 f íred 64 220 Francís 24 36:21 faíth-based 47 :2 64:19 firefighters ,3 7I:t9 37:19 19 224 Frankl-in 39 z16 37:10 gearíng 40:10 fÍrm I0:7 , 35:19 9,L2,13 free 44:7 4t:16 Geisler f ir 32:7 f all- 67 :5 freedom I7 :21 19:5 floating 27 :24 3Q:24 f amíIy L4 z 7 32:6 35:18 54:LL fashion 36:7,8,L5, floor 17:22 general 9 :1"2 1-9: l-8 20 38:2 27 220 floors 17:14 42 z3 45 : l-8 February 5:6 35:l-8 36:8 focus 42:I,3 46 z2 47 :tB feel 44:7 5122I,25 44:1,8 ,25 folks l-9:15 59:5,9 46 :8

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KELVIN J. COCIIRAN vs. CITY OF ATLANTA, ET AL. MelissaJ.Mullinaxon02l23l20lT Index:generally..Huh-uh generally 37:1-0 43:17 hired 15:3 18:9 37:I 42:1,22 51:16,79 history 10:5 53 :2L 66 z L'7 ,23 Georgía 9:14 hít 66:3 36:18 54:!7 happening 39:2L 622]-0 65:9 27 :23 28:L Holcomb 5:15 4O:23 69 z3 ,17 39:19 6:2 ,7 45 zI7 guíded 62:20 522L5,24 15 :20 , 24 55:25 59 z7 20:20 24:3 happy 7:70 28:10 6l-:8 62:5, H 7 7t:74 ,15 hard 35:7,2 29:20 35:5 hal-fway 66:3 4I:6 44:3 give 30:1-0 46:12 52:3 63:10 HB2 45:tt 50 :2 ,II haIl 42:22 '7 59:l-5,]-'7 head :4 53 :3 57 :78 Global 5:11 512 4 ,5 ,7 8: l-3 30:8 58:18 52:7 , t5 47:5 55:24 Godfrey 6I: t2 63 : l- 28:L9 hallway 1-3:2 hear L4:6 65:L7 27 :8 54:II 19: l-5 68:6 ,L3,23 good 6:3 ,6 Hampton heard 20:3 69:6 7L:9, 35:l-4 22 ,24 67:L4,L5 20 :1-1" ,14 42:L4 62:2 hand 30:9 hearing 26:'7 HOLCOIIBE Govus 69:L 7I:1- 34:8 27 :L 33:3 Graham 37:t0 38:19,22 36:5,10 hol-d ]-]-:2 55 224 62:5 handed 44:4 hetd 30:l-9 43:14 group l-0:9 46:73 53:4 aa I home 54:3 L3 :12 58:19 ¡rerpfur Jo : J 7024,5,6 63 zI7 38:l-7 61:13 63:2 hope 38:1"2 40 z3 ,12 ,24 hígher 4I:3 handl-e 15 :13 42 :2I hot 35: l-7 highest 9 z2L groups 12:5 handled l-l-:6 hour 50:3 Hinton 5:1-8 38:15 46:L happen 31:5 l-5 : l-7 ,22 hours 44:13 64:L9 37 :74 20 :12 53: l-9 houses 36: l-8 77 z1-1, 13 23:24 28:8 guess 1"L:20 happened 29:13 HR 33 z2l 23 :1-9 2L: LI 22 :9 52:20 68:l- IIuh-uh 22 : L9 26:23 262L9 7L:23 56:10 40:24 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 89 of 141

KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on O2/2312017 Index: husband..issue husband ímpair 8:6 36:12 introductory 65 :12 implication 48 :15 ,19 6 227 58 :1- Huseby 5:10 66 21,5 investigate informed imply 67 224 22:2,6 I 68:8 46:5 48:I 37 224 informing investigated 35: l-5 import 8: l-8 idea 542]-3 25:1-B 36:20 important 24:9 ínvestigation 39:15 7 :! AI 223 initíal 3824 40:8 ínitiatives 26:24 30:4 ídenticall-y 33:16 70:1-5 54 :22 , 23 1l- :9 34 zI,4 identifícation incidental input 36:2 67:20 !4 z20 35:4 44:2 íne 67:L9 ínvestigative 46:II 53:2 incl-ude insert 29:13 34zL2 57:17 45z]-]- 58:1-7 instance involve 3'7 :2 incorporated 6l-:11- 47:L7 invol-ved 57 z3 58: l-1- 62 225 instruction ]-9:25 65:16 incubator 29:14 29:1 ,4 ,7 , 9 68:L2,22 tU :24 intentionally 34:7 36:22 69 :5 Indian 6: l-8 67:2,8 42 217 ,19 identify 10:10 invoLvement 41":8 58:7 interact indivíduaL 12:LB 15:8 36:24 illness 8:3 58:14 ínteraction involving 6: l-8 immediately individuals 49:22 25:16,22 54:24 56:3 ipad 1-3:23 64:20 64:6 interactione 15:6 19 223 issue L5 zL2 7L:L2 inflame ínternal 30:l- inrnigration 3Lz2L 37:L8,21, 49 z2 41,:13 inflamed 23 39:10, introduce impact 25 :1,9 26 :10 12 ,17 5z12 40:11 ímpacted ínformal introduced 42:5,8,10 25 :1"9 L7:3 47 z 1,5 26:20 34:9 36:L7 information 4529 56:5,9 15: l-3 27 z9 wrwv.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - \ilashington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 90 of 141

KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: issues..letters 7L:18 552]-7 l-9:18 40: l-0 issues L9:L4 judgrment knew 1924, 4L: L6 26:7 55:3 37 :25 23 2IzI3 43 : 13 46 :'7 49 :7 ,Il 67 220 jump 26 225 28: l-8 it,ems 22:3 31-:19 1-eading 37 z 5 ilumpíng 35: l-9 36:5 44:L8 33 : 1-3 63:10 41 :L0 37:5,6 League 35223 .Iune 6 2L2, 40:2 47 222 60:24 13 52:24 iI l-earn 28:15

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KELVINJ. COCHRANvS. CITY OFATLANTA, ET AL. MelissaJ.Mullinaxon02l23l20lT Index:letting..medication 42 : Il-, 13 32:5 4O:21 manages L2:8 L2 :1"9 i-3 : 6 ) letting 49:21 55:4 managing L6:14,L7 '70:4 61,:2I 1L :25 1,7:I5,1-7, l-ots ]-9:14 24 19:10 l-evel- 9 :27 manifest 20 z2 20:'7 2529 32:24 LGBT L2:3 35:13 24 : 17 ,2t 23:19 2626 36 222 march 15:3 27:18 55:23 42:t4 49:6 51:5 36:11 37 38:5 life 9:16 64 :22 margin 60:L7 :17 43:22 48:8 38: l-6 61:1 50:25 40:]-3,1,9 M marked 35:3 4L2L2 43:I 5L:2 ,13 44:I,5 54:I 55:8 49 : lO ,20 M-e-I-i-s-s-a 46 :1,0 , 14 56 :9 5'7 : L4 60 :6 6: l-3 53:1,5 59:13 62: L3 16 , M-u-1-t-i-n-a- 57:16 6023,7 63 :25 x 6zL3 58: l-6,20 66:25 63:21 made 26:23 6L:1-O,14 64:3 ,24 Lil-lian 69 :1" 28:6,Lt 62:24 63:3 65:2 66 :3 , 65:15 l-ist 63:20 , major 10:1 6 67:3,]-3, 2L ,22 11:8 68 : ii,2i L4,L5 702L 69 :4 listed 66 :1,I make 6:22 mayor I s marks 6L:2 7 :14 26:I7 10:1-8 Litigatíon 17z4,14 5:11 5223 56:2L marriage 6Iz5 4I:L2,13 2626 43223 l-ived 9:15 43:L1, l-5 52:19 makes 1,1, :22 56 :6 , I8 ,25 long 9:15 married 9 2L7 making 55: l- 57:3,9 15: l- 14 65:13 , '7 man 43 : l-5 O :L9 l-ooked 29 :24 marry 36:21 37 :1,9 manage 1-7:22 Mckoon'g 57 zL]- t2zt3 matter 5 z4 42 z2 62 222 9:6 22 ztL 25 :72 media 5 z2 lot t8:23 39 :9 ,1,I 19:3 20:9 26 :8 ,1,2 27 :15 2t:1,5 3921-4 40:3 matters 6:2L 63 :L6 64:9 39 :42 25 :17 managed 65:5 72:1, 27 :2 ,7 1-1-: l-8 mayor 10:11, medication 3]-2L4,t6 23 l-l-:16 8:5 ) www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, I)C - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 92 of 141

KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: meet..needed meet 36:L1-, mention 62:5 19 :4 54 : ]-1, morning 6 z3 12 mentioned mind 4226 44 z1-4 meeting 72:I 17:7 55 2L7 56:1 move 9 :1,I 16:24 ,25 18:10,I7 , 7L:L5 , t7 , 4l z3 17 :I ,lO ,19 18 ,19 20 moved 10:18, 18 z2 20:24 29 :22 mine 68:17 20 tt:2 21,:5 ,12 ,24 36:14 27 273 22 :1 , L6 ,21" 49 z16 mínister 24:8 ,9 , 19 50:72 5l-:1 55:20 movement 60:22 39:20 28:t9 29 z 4 56:12 59:7 30:18,23, 60:9 62:15 ministere 40:22 25 3I: L2 63 : L8 ,25 38 :17 52:t4 32:3 16 ,72 , message minute 30:10 MuIlínax 33:8 ,1-7,13 523,22 47 :1,3 mínutes 50:4 43 :2L,24 49 :12 6:3,L2,!3 5Q:24 54:20 missíon 37 :17 51:13 55 :1,2 35:25 53:15,76 54:2,!3 72 z2 59 :1"9 Missíssippi 7l-:1-0 meetings 6L:24 6:I9 10:10 24:IO 66 : tB N ,20 MKR 59 223 29 :2 ,7 ,IO , 67:I7 60:1 Naked 1-6 :13 12 , 16 ,21 messages moment 3429 39 z3 42:I5 64:22 6526 names 63 223 44 :7 57 :20 48:18 66:10 Nan 69:3 4928,23 Monday â. 15:10 .i ¡t¡g9JL.hrv*aF tr1 .t ÀÎa{.r1 a Mel-issa 5:3, 30:2I 68:1-6 22 6:1-2 method 12:25 39 220 37 zL7 Michael 40:21 national 53:15,1,6 30 224 47 222 t2:1,4 65:3 72:2 mÍcrophone monitor 527 nationally 45:8 66:5, members ]-427 4L z3 rnonopoly 23 48 211 mid- j anuary 62 :27 49:24 natural 66:21 months 27:13 56:6 ,8 memory 27 z5 middle 3Lz2 30:20 Moral 39:20 nature ]-L:7 Mike L7 z 21- 4Q:2ï 67 :7I needed ]-9:17 www.huseby.com Huseby,Inc. Regional Centers 800-333-2082 Charlotte - Atlanta - Washington, DC - New York - Houston - San Francisco Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 93 of 141

KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. MelissaJ.Mullinaxon02l23l20lT Index:negative..participate 26:!8 18 44:22 15 : l-3 58 z2 63:t2,I7, 53 : 52:L7 18 54:2 f Ícial 24 64:2 ,4 60: l-0, 19 ,of 7l:20 negative l-5 : 9 52:'7 65:3 notícing 54 : l-3 organizing neíghborhood 53:9 69:25 59:8 t2 :5 notíon 33 :3 of f icial-3-y Orrock 69:3 newsPaPer November 70224 outrage 7I:L6 L5:16 onl-íne 14 z16 50:14 night 54 z4 t6:7 ,23 Op-ed 62:5, outs 67:19 3'7:5,6 13 Nina 21, z 13 overvíew nr¡mber 522,5 open 40:22 l-0:6 NiI 65:24 L7:6 50:l-3 nodding 20:2 72:t operating LL:L2 P node I : l-3 30:8 47:5 o operational p.m. '70:2, 11:8,10 L2 nondiscrimínat oath I :1,7 ion 38:1 opínion package 38:3 56:22 Obj ect 35:16 rJ.rttzz1t= - 1-' -l-) pages 59 z2I oppose nonnegotiabLe 23:24 28:8 paid L4 :1,6 56:23 5L :22 , 24 52:20 68:l- paper 7I:L6, opposed 37 z3 nonprofit observe 18, 19 35:25 62 220 22zLB paragraph 40:20 optÍon 53:23 October 37:6 37: L5 nonverbal ordínance offended 56 :20 ,24 7 z4 8 225 2624 Parents Norma 65 :23 , offensive organízation 65:25 24 37 z2Q l-8 : 1I,16 Parks 1,7 : 16 North 39 z2t 40: L9 of fíce l-0:19 part 1-3 : 1- 0 45:10 organizations 77 :'7 72 :24 37:13 39 :9 notation l-3:3 17:4 ,1,6 59:20 60:1-6 40: l-1 40 223 48 z7 4t:L7 particípate note 47:2,3 offícer 43 :5, 10 40 2]-5 , 1-6 notes 22 z16, l.1: t2 50: l-8 43:24

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KELVINJ. COCHRANvs. CITY OFATLANTA, ET AL. Melissa J. Mullinax on02123l20l7 Index: participated..primarily participated perspective play 30:4 preparation 43 8 39:3 20 :6 :7 point 7 :L1,, :22 partner 52 :1"0 17,20 prepared 59:16,1-8 65:12 2I:3 , 14 34 zt2 party 8:9 perspectives 26 222 preparing 42:8 ,70 , 19 39 :25 42:t 46 :6 passed 43 222 62:4 PFLAG 65:25 Presbyterian past 56:6 points phone t3:17 60 223 paste 45:6, 14:5,8 31 : 15 ,23 t4 32:I 56: l-8 present L7 z6 27:2 L7 :L9 pastor 55 : l-4 49:L6,!7 , po1-icy press :-.t:9 pastore 1-8 50:13, 10:17 ,22 15 l-l-:8 56:22 2'7 2L8,22 36:20 40:1-3 40:17 ,25 pícked 64 z5 political 41 222 4222I,23 picking LO:2 12:L4 47 :25 48:9 51:1 6221,9 37 zII 39:2 Pope 47:2,3 4929,17,20 pay !4 z tB píece 62:8 portions 53:l-9,2! people t7:5 67:a6 58:7 54:5 57 :7, 4,5,r0,19, 37 224 place t9:22 position 24 62 zL6 , 38 222 67 zI4 68:9 l-0:l-6,21 39:21,22 L7 66z25 !t:17 37:2 69:13 L6 40:3 422L4 places 59:25 , 56:27 70:1-7-,7-6, 49 :8 ,22 plaintíff 6'7 :3 ,4 1-8 52:4 59 z2O 5z17 6:8 positions 6l:4 64 223 pretty 72:20 Pl-aintif f 's 36:7 perception 4425 46:I4 35:17 possibility 66:3 ,7 L5 :25 61" z L4 25 :25 previous person 49:22 plan 22:6,7 post-bachel-or 35:19 personaJ- pl-anner l-0:3 prevíousl-y t4:t ,8 ,24 1-1.: l-l- posted 70:72 7l-:1-0 15 :25 planning potential-ly pride 1-9:20, 53:l-3,14 54 z3 L42L6 6l-:5 25 personally plans 56:15 37 :3 42:L3 7O:2L prímaríIy

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: primary..realized 42 :22 40 :25 70:L2 6 225 7 :24 43 :4 ,7 4t:L,7,71 pulled 45:25 9:12 2L:IO prímary 55: 8 59:24 71,:22 ,23 L2 225 project purchase quote 5'723,5 LL :22 prior 15:16 23 :1, R 65:20 projects purpose pro 27:24 L]-:22 46:23 rabbi 40:t7 64 z]-9 protest 5l- : 5 62:I7 55:15, i-8 problem provide 8:77 pursue 1-0:3 raise 39:4 67 :tO t2 z L2 L4:4 push 33:6 ral-l-y 59:8 procedure l-8:13,15 6!:24 rallying 6 223 20zt2 63 223 pushback 59: l-1- procesÉr l-8 : I 52:9 ,25 provided Ralph 37:9 26 :25 pushing 33:1,23 l-9:8 23:!2 rampant 33:4 48:L4 66:24 39:I,24 ran 10:8 4826 492L5 províding put 1-O:25 55:3 7zB 20274 45 :2I reach 35:15 54: i8 43: i3 productive publ-ic 10:13 59:6,L4 36:13 38:16 reaching putting 38: l-3 40 z L2 profess 9 21,9 ,1"9 4L:L2 43zI 40:13 42:18 ,20 professed 4627 47 :12 43 :4 24:6 49:1-0,19, 56:77 react L9:.1,7 professíonaI 25 50:1 reaction 1,5 :7 16 :3 54:25 58:l- a 25:L3 24 :5 32 :24 60:6 question 31:10 profile 62212,a6 '7:6,8,9 63:16,25 read t7:5 63:17 14222 66 :25 23 :7 ,23 29 z1-9 39:5 profiles 67:17 ,19 32:21" 55: l-9 61 :2 67:23 publ-icIy questioning program 23 :4 34 :1,9 ready 47:25 IQ:25 l-1: 1 62:t 65:2 7:1,9 56:15 71,:3 progressive 67 z 21, ,22 questíons realized

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KELVIN J. COCHRAN vs. CITY OF ATLANTA, ET AL. Melissa J. Mullinax on 0212312017 Index: strategist..Theriot ') straÈegist l-5 team 1-3:9, T 1l-:1-1- supporting 1l- 48:20 49:2 52:19 street 27 223 46zI 59:23 tablet 73 :23 6l z2I structure supportive taking 6 :14 tease 64 zL4 11:1 L9 :2I , 24 8:5 22:18 structured 43 :10 68:9 t,elling 24:21 L9z6 supports talk '7 :2 studíes 472]-2 13 :10 Temp1e 55: l-8 t0 :2 ,3 surprised L5 :14 terminate L6 224 27 :7 stuff 27:25 L9:16 5522 642L5 29 :2I surrounding terminated subj ect 42 223 62 z3 45 :21 2Iz4 25:76 ,22 talked 25:4, 47 54: l-5 suspend 40:2 :20 1-3 26 :9 , L2 49:1"3 subsequent 28:6,L2 29:2,5 27 :21, 7L:L2 7O:20 38: l-1 37 :23 termination suggesting 39:18 27:2! suspended 40 z16 54:L 47:23 2.8 21 6 ,2.4 4924,lL suiÈe t7:L4 33:1-7 5t:20 48 :4 ,23 support L2:9 62:t4 49:5,L3 suspension 56:L6 32:21 26 :24 talking 59: l-0 4L:9 , LI ,1,3 29 :8 ,23 7! :25 7 O:23 42:L2 4829 1-3:2,12 terms 32:I9 62 :22 27 :12 L9 Suzanne 5:1-0 , 60:25 supported 47 z9 56:1-8 60:7 swear 5: l-3 60:6 63 :15 testified 5 223 supporter sweeping 64 :8 8:I4 50 224 59:23 60:1 40:8 taEked 7!21,0 supporters swept 35 220 22 :70 , 72 53:25 37 21,2 38 z2 Taylor testifying 8:18 54 2L9 sworn 5 223 1822L,22 testimony 55:11 Taylor-parks 8:17 56:3,5 t7 :23 63:A2,14, TherÍot 5 : l-6 i

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From: Shahar, Robin Sent: Thursday, December 04,201,4 2:49 PM To: [email protected] Cc: Mullinax, Melissa Subject: FW: Scanned from a Xerox Multifunction Device Attachments: Scanned from a Xerox Multifunction Device,pdf

HiShelley,

Attached are portions of the book we spoke about. A link to a Washington Post article about it is also below. To be clear, this request is not coming from the Mayor himself. Melissa Mullinax, the Mayor's Special Advísor, and I are requesting that this issue be looked at by other faith-based leaders and organizations.

According to the media coverage, it appears that Chief Cochran's suspension occurred on November 24th (This info is from the Washington Times on November 25,201.4).

Atlanta Fire Chief Kelvin Cochran has been suspended without pay for one month and must undergo sensitivity training for authoring a Christian book in 20L3 that described homosexuality as a "sexual perversion."

Mayor Kasim Reed's spokeswoman Anne Torres said the administration didn't know about book, titled "Who Told You That You Are Naked?" until employees came forward with complaints last week, the Atlanta Journal- Constitution reported.

The book identifies Mr. Cochran as Atlanta's fire chief and says it's his first priority as chief is to run the department "to cultivate its culture to the glory of God," a local ABC affiliate reported.

The mayor's office has opened an investigation to determine whether the chief's actions violated city policies or discri minated agai nst em ployees.

The Washington Post Link

http://www.washingtonpost.com/news/post-nation/wp/ZOta/n/26/allanta-fire-chief-suspended-after-distributing-his-

rel igious-boo k-to-em p I oyees/

I am available to answer any questions. Thanks for your time and consideration.

Robin

NOTE: My office address and phone number has changed.

Robin Joy Shahar Mayor's Advisor on LGBT lssues 55 Trinity Ave, Suite 5000 Atlanta, Georgia 30303 rshahar@atla ntaga.gov Office: (404') 546-4t7 t Fax: (404) 546-8580

1 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 104 of 141

From: Mullinax, Melissa Sent: Friday, January A2,2OL5 4:23 AM To: Mullinax, Melissa Subject: Cochran

How ironic it is to find the demoted cardinal is from the United States. What does that say about America - that even the Catholic Church and a pope are ahead of so many anti-LGBT lawmakers and extremists in this country.

W'eeks after taking office in2013, Pope Francis asked, 'Who am I to judge?' speaking of the LGBT community. Since then, he has had great support for his progressive views, and of course, great opposition. Raymond Burke is one of the pope's strongest opponents. The 66 year-old Burke believes homosexuality is,'always and everywhere wrong [and] evil,' and continuously questioned the authority of Pope Francis, now 77. Burke told Buzzfeeó in October:

Sent from my iPhone

coA-EMAtLA04112 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 105 of 141

From: Mullinax, Melissa Sent: Monday, January 05, 2015 L:23 PM To: Mullinax, Melissa Subject: Cochran

Times Union article Religious freedom bill Pope Francis

Sent from my iPhone

coA-EMAtL003998 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 106 of 141

From: Mullinax, Melissa Sent: Monday, January 05, 2015 8:21 PM To: Mullinax, Melissa; Melissa Mullinax Subject: Coch

Supporters - City Council members including Alex Wan, high profile community leaders (CT Vivian, rabbi, white female minister, lgbt)

Chief Cochran has resigned or been separated from the City today.

I've called this press conference because I want to make my and the City of Atlanta's position clear. - the city's non-discrimination policy is non-negotiable -neither race, nor gender, nor religion, nor creed, nor sexual orientation, nor physical ability, nor gender identity

Sent from my iPhone

coA-EMAtL004188 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 107 of 141

From: Mullinax, Melissa Sent: Tuesday, January 06,2015 9:35 PM To: Ward, Janet L. Cc: atlmedia Subject: FW: Statement on Chief Cochran

Janet - Our official statement is below, Thanks, MM

From: Torres, Anne Sent: Tuesday, January 06, 2015 4:26PM To: Fa usset, Richa rd (richa rd,fa usset@ nyti mes. com) Cc: atlmedia Subject: Statement on Chief Cochran

Hi Richard-

Here's the official statement

Statement from Mayor Kasim Reed on the Termination of Atlanta Fire Chief

ATLANTA- Mayor Kasim Reed issued the following statement today, announcing the termination of Atlanta Fire and Rescue Chief Kelvin Cochran:

"l have made a decìsion to separate from Atlanta Fire and Rescue Chief Kelvin Cochran, effective immediately. I want to make my position and the City of Atlanta's position clear. The City's non-discrimination policy is non-negotiable. Neither race, nor gender, no religion, nor creed, nor sexual orientation, nor physical ability, nor gender identity will be used to discriminate against any City of Atlanta employee. lappreciate Chief Cochran's seryice as Fire Chief. Chief Cochran's personal religious beliefs are not the issue. The City and my Administration stand firmly in support of the right to religious freedom, freedom of speech, and the right to freely observe one's faith.

I take no pleasure in this decision, but as the Commanding Officer of 750 employees within the Fire and Rescue Department, his judgment and management skills were the subject of the inquiry and my decision to terminate his employment with the City of Atlanta.

I am person of deep faith, and we are a city of laws. Chief Cochran's book, "Who Told You You Were Naked," was published in violation of the city's Standards of Conduct, which required prior approval from the Board of Ethics. Despite my respect for Chief Cochran's service, I believe his actions and decision-making undermine his ability to effectively manage a large, diverse workforce. Every single employee under the Fire Chief's command deserves the certa¡nty that he or she is a valued member of the team and that fairness and respect guide employment decisions. His actions and his statements during the investigation and his suspension have eroded my confidence in his ability to convey that message.

Chief Cochran also failed to notify me, as Mayor and Chief Executive of the City of Atlanta and his employer, of his plans to publish the book and its inflammatory content. This demonstrates an irreconcilable lapse in judgment. Chief Joel Baker will serve as the lnterim Fire Chief and will be able to compete for the permanent job. Going forward, the Fire and Rescue Department Command Staff and all members of my Cabinet will participate in a sensitivity training

coA-EMAtL004014 + I Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 108 of 141 '' pffered by the well-respected Basic Diversity firm in January. This same training will be rolled out to all managers this year

Any Fire and Rescue Department employees with additionalsuggestions for moving forward are invited to share those ideas with me. I am all ears and will do everything I can to support the healing that needs to take place within the Fire and Rescue Department and for all City employees."

Anne Torres Director of Communications Office of Mayor Kasim Reed {a) 404.330.6423 (q 4a4.904.2678 (F) 404.s46.2983 www.atlantaÊa.gov @AnneMTorres

Stay conneded on Twitter: @CityofAtlanta and @KasimReed

coA-EMAtL004015 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 109 of 141

From: Mullinax, Melissa To: 'Melissa Mullina/ Sent: 1l'12/2015 1l:08:33 PM Subject: faith and freedom coalition Attachments: Faith Freedom Coalition. pdf

Melissa Mullinax I Senior Advisor to the Mayor I City of Atlanta I Office of Mayor Kasim Reed | 55 Trinity Ave. SE, Suite 2500 Atlanta, 30303 ph: 404.330.6756 cell: r,rnnnnr.atlantaga.gov | GA | | 404.825.2ßA I I mjmullinax@atlantaga. gov

Stay connected on Twitter: @MJMullinax, @CityofAtlanta and @KasimReed

coA-EMAtL004023 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 110 of 141

FAITH & FREEDOM COALITION Ralph Reed, Founder & Chairman National Endorserc: Sarah Palin, Sean Hanníty, James Dobson, Newt Gingrich

DRAFT STATJMENT FOF MKR SUPPORTER tN RESPONSE TO GA BAPT|ST "DEFETUD RELIGT9US LtBLFTy" RAU-Y ATGA STATF CAPTTOL The Religious Right never lets the truth get in the way of a good story. They specialize in distorting the facts to create martyrs, not to support the individuals, but to advance their { national right-wing agenda. v ..ì

ln the case of Chief Cochran, there has been NO attack on his religious liberty. He was dismissed because he violated city code, ignored the city's Ethics Office, showed terrible judgment and flagrantly disrespected the chain of command that required him to seek and 'l receive approval from his boss before publishÍng a book. ¡¡6\"t-

The GA Baptist Convention and the Faith & Freedom Coafition are ignorfng the facts and dishonestly presentíng his dismissal as an attack on religious liberty.

Ralph Reed and his people have a history of this díshonest manufacturing of martyrs. The ways in which these folks are mis-characterizing Mayor Kaiim Reed are absurd and a who knows the Mayor knows better than to believe thls junk.

SUPPORTING FACTS ln 2012, when Retired GeneralJerry Boykin was disinvited from speaking at a National Day of Prayer event at West Point, Ralph Reed and his allies tried to lift Boykin up as a martyr - sayihg he was denied the riþht to speak because of his Christian beliefs.

The truth about Boykin is that, in 200O when Boykin was still on active duty, he generatêd criticism for public commenþ given while he was in uníform, indicating that he saw U.S, military engagement in religlous terms, as "our God" (Christian) vs. Satan or the "idol" God he said was worshípped by Muslims. lt was widely feared that such comments could endanger U.S. troops. Boykin was criticized publicly by then-Presldent George W. Bush and in a 2004 report by the Pentagon's inspector general; critics worried that his remarks could put servlcemembers' lives in jeopardy by suggesting that the American rnilitary saw rejlonal conflicts in retìgious terms.

coA-EMAlLOO4024 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 111 of 141

Boykin has repeatedly said that President Obama is creating a Hitler-like cadre of Brownshirts to force Marxism down Americans'throats.

Vigorous opposition to Boykin's invitation to keynote the West Point prayer breakfast was led by veterans utilizing research from Right Wing Watch, as well as West Point cadets and faculty, military chaplains, and religious and civil rights organizations. Said a faculty member wr¡t¡ng on behalf of his colleagues: iuffice ff fo say thot the horríble consequences of the prejudiced messoge sent 'round-the-world by thÍs offtciølWest Paint invitation to Boykin is øll but incqlculuble. The true príce to be exacted, by grantíng this high profile speokíng engøgement to the bigot Boykín, will shamefully be paíd in blood, and the blood of innocents.

VoteVets argued that Boykin's views were incompatible with Arrny values, inconsistent with Army doctrine, and disrespectful of the service of Muslim-Americans serving in the Armed Forces. Votevets leaders Jon Soltz and Richard Allen Smith saíd the kind of anti-Muslim remarks Gen. Boykin has made "threaten our relationships with Muslims around the world, and thereby, our troops serving in harm's way."

Members of the Forum on the Military Chaplaincy also opposed Boykin's invitation. "Chaplains are sworn to serve allin the military," said retired Chaplain (Colonel) Paul Dodd, co-chair of the Forum. "lt sends a poisonous message to have chaplains sponsor someone so strongly associated with speech that condemns one particular religious group."

Although West Point officials initially defended the plan to have Boykin speak at the "pluralistic" breaHast, saying cadets were "purposefully exposed to different perspectives and cultures," the retired general withdrew a few days before the breakfast, reportedly after speaking with West Point officials.

ln 2013, David and Jason Benham - whose plans for a reality TV show on HGW were scrapped by the network after Right Wing Watch reported on the brothers' anti-gay, anti- choice, anti-lslam activism - were featured speakers at Ralph Reed's 20L4 Road to Majority conference, sponsored by the taith and Freedom Coalition.

coA-EMAlL004025 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 112 of 141 Kelvin Cochmn Petition Page I ol'5

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d¡sc¡imìnctiron irj lh'* ,\,lorkplûcr , lJor.v l: the tirnc lor cil B rbt,.-believrrig Ëtlr¡:.t,on! tû 5hËw the¡r surjpûrt fo¡. Chief Cscirran's courüÊÉ.r¡nd for ou¡ Fir:t ,Amendment right-: c; Americçn ciãÊzÊns: j¡¡th Cûme sttnd fer your and ogoinst onti-Chr¡stron üigctry rv¡th Ch,ef Keiv¡n Coch¡c¡i* pûsiorb, clrr¡relh leç¡jc-rc l:nd Chlrçticnt. trr¡Ê .r;iil Ëonct1 Jdr- orrr time together by wolk,ng tel ûiiy l-!cl! for s lrme of prnyer,

Whct; Stonding foi Our Fsitl': ,qoily When' li¡esrjçy, .tüFuûry 13, i;i.0-?:30 p.m. Where: Gecrgic Copitsl Eotunds 'fdt¡ol Public lnvited Srgoni:ed by Concenred Püstüri,i Go¡lun

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Sign the Petition:

Th{: Ge*rgic: #rrilt¡st ücnven!rcn {GB(¡ rs calling on the Ct¡r.stian Ëûrnmunrty ìo ''stoild ¡,¡: fer brf:lcol pr;nc,,pÈef *nd feifow bf.¡rar¡erç r¿'hú cre punished or mcrginclrzed for thc:¡ fclth.'.

in res¡lcnsr tn $,iluntø Frre ihrei Kelvin Cochron's orlginci suspensii:rn, ond nc¡w teiminr¡ti*n Þy tvloyor Ki:sirn Êeec!, the G3c's Pui:!¡c Affairs {ommiÌtee is conti;ru nç thc pctitron storted ÌÇst nïûnífï. The comm:rieu ht¡s ¡s.ued lt! Gwn stcteme¡lt dcl*ndinç the Fire Chi*f r.¡nd ;* caiiing on Reed ts.

r Éckno.-vleCçc Chrel Çcrchr¡:n's F¡rst Amendme¡rt Êrghts. r lvloke u Fuhhc opoiogy for the terrninnfion anci grief it hcr coured rhe Chict r:nd hrs famrly, Ë H+sÊere l*hiet Cr:chren's p*sition ffrìd rcp$tÊt¡frn qs sn hc¡r¡er#llle Í:¡re Chief. (,hrislir:nç Gãt ri requestrng crnd pe+pi* fl,i iaith srrrl:s the r¡ct¡ûfl ri) rign the reisied petrtron {1ght} rcl¡nt uf¡on Mayi:r Recd ic reve rse hjs dcc sroír û5 outllned in the rhree ar*a¡ li:led obove.

Flea-.e enliçt i-rs rr:nny churchËs ûfid heli*r'ers us possrble lû expÍåss tl"¡ess concerns ro I..4ayr.rr ftceci:

f*Toyor Kcsim Reed 4{r4-33Ë-61r:û 55 Triniþ Âve. Sr¡ite ã50& Åt!cnr¡:, $A 3t3û3 mkreed@otlontogo.ûov

Additionol Resources:

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FeËiti*n to frllayor Kasinn Reed

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STÂTE l PRTVI¡JTË

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How to Contoct GBC:

Addres*¡ Georgio Boptist Convention Missions & Mínistry Center 6405 Strgorloof Porkwcy Duluth, GA 30097-409I

Phone: 7704ñç0404 Toll Free: 8g0;746*442?

Contoct Form

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A Pnorlr Þ's*T$Ëå" Published on People For the American tllay (http://www"pfaw.org)

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The Mythical Martyrdom of Jerry Boykin -lrø --*iiú'LJ oü 'rt¡' MG}IT WING TJITAT-CFI i!.1

The Mythical Martyrdom of Jerry Boykin

A Case Study in Religious Right Propaganda Techniques

Table of Contents: ' lnkoduction ' F¿qfs,Fj_rs-ti,.8-o iÊ.in ief ' Bovkin at the-B-each I Bsvkin at West Point

Pr-pEÐArdaT,echnic¡qe?:Misçh.{actçriæ,thçgobositioJ1 PropaqandATechnique 3: Whitewash Historv Prosaoanda Technique 4: Blame Obama Þropao The Truth lntroduction

Ever since retired Lt. Gen. Jerry Boykin withdrew as the scheduled keynote speaker at the February I National Prayer Breakfast at West Point military academy, Religious Ri$ht leaders have fied to turn the controversy over his planned appearance into a cautionary tale of political conectness trumping religious liberty. ln reality, the episode provides a case

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study_ of Religious Right propaganda techniques in action - and of right-wing leaders' unwilllngness to let the truth get in the way of a good story. Facts First: Boykin in Brief

Retired General Wlliam*Jerry" Boykin had a tong military career, much of it spent in charge of special forces units. So why would his selectlon as a ipeaker at West point be controversial? Almost ten years ago, when Boykin was still on active duty, he generated criticism for public comments, given while he was in uniform, indicating th'at helaw U.S. military engagement in rellgious terms, as "our God" (Christian) vs, Satan or the'idol" God he said was worshipped by Muslims. lt was widely hared that such comments could endanger U.S, troops. Boykin was criticized publicly by then-President George W Bush and in a2O04 report by the Pentagon's inspector gdneial; critics worried that his remarks could put servicememFrs' lives in jeopardy by suggesting that the American military saw regional conflicts in religious terms. Since he retired, BoykÍn became an ordained minister and has been a regular speaker at Religious Right and right-wing events, where he has not only demonized Muslims, but also claimed that slnce lslam is noi a religion but a "totalitarian ryay of life," and since Muslims are under an "obligation to destroy our Constitution," American Muslims are not protected under the Firbt Amendment'ê guarantees of religious llberty. More explicitly, he said there should be no mosques atlowed in Amerlca. eoy:t

ln January, People For the American Way's Right \Mng Watch blog noticed that Boykin was scheduled to be the keynote speaker at the "Mayor's Prayer Breakiast" in Ocean City, Maryland. PFAW President Michael B. Keegan wrote to the mayor and city council members details gfieri¡q {oyJ Çoykin's promotion of religious bigotry aná h¡s advoóacy for retigious discrimination. PFAWs letter argued that city officials Jtroúlo not give Boykin s extremism an implied endorsement. Other organizations, including the Council on American lslamic Relations, the Aubum Semlnary, and Standing on the Side of Love, asked that Boykin be disinvited; at least 2,000 people contacted city officials to express their opposition. The Baltimare sun weighed in with a strong editorial, which concluded:

Make no mistake: This is not an issue of freedom of speech or of any of the constitution's protections for religious expression that Mr. Boykln-Boykin seems so eager to deny to those wtro don't share his own thristian faith. Mr. has every right to say whatever outrageously offensive and hateful things âbout Muslimi pop into his head, and the private organizers of an Ocean Cifu prayer breakfast have the right to invite him to speak. Likewise, Ocean City Mãyor Rick Meehan and the town councll can attend the breakfast if they so choose. \rVl'rat they cannot do, however, is pretend that their presence there won't reflect badly on them and the resort town they lead. They need to make clear whether they agree with Mr. Boykin's views, they need to do it immediately and they need to Ob ¡[ publicly.

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In the end, Boykin addressed the breakñast, focusíng on his experiences as a military commander and hís belief that God had repeatedly intervened to save him and his men. Boykin concluded with the equivalent of an altar call, asking participants to join him in a prayer recognizing Jesus Ghrist as lord and savior. Boykin at West Point

As the controversy over Boykin's invitation to lead the Ocean City Mayor's Prayer Breakfast picked up steam, it was revealed that Boykin was also scheduled to be the featured speaker at the National Prayer Breakfast at West Point military academy - a rnuch higher-level platform that would directly suggest approval by the nation's military leadership of Boykin's extremism, religious bigotry, and calls for discrirnination. Vigorous opposition to Boykin's invitation to keynote the lrlþst Point prayer breakfast was led by veterans uülizing research from Right \Mng Watch, as well as West Point cadets and faculty, military chaplains, and religious and civil rights organizations. Said a faculty member writing on behalf of his colleagues:

Suffice it to say that the honible consequences of the prejudiced message sent 'round-the-world by this official West Polnt invitation to Boykin is all but incalculable. The fue price to be exacted, by granting this high profile speaking engagement to the bigot Boykin, will shamefully be paid in blood, and the blood of innocents.

VoteVets argued that Boykin's views were incompatible with Army values, inconsistent with Army doctrine, and disrespectful of the service of Muslim-Americans serving in the Armed Forces, VoteVets leaders Jon Soltz and Rlchard Allen Smith said the kind of anti-Muslim remarks Gen. Boykin has made "threaten our relaüonships with Muslims around the world, and thereby, our troops serving in harm's way."

Members of the Forum on the Military Chaplaincy also opposed Boykin's invitation. "Ohaplains are swom to serve all in the military," said retired Chaplain (Colonel) Paul Dodd, co-chair of the Forum. "lt sends a poisonous message to have chaplains sponsor someCIne so strongly associated with speech that condemns one particular religious group.'

Although West Point officials initially defended the plan to have Boykin speak at the 'pluralistic' breakfast, saying cadets were "purposefully exposed to different perspectives and cultures," the retired generalwithdrew a few days before the breakfast, reportedly after speaking with West Point otficials. Cranking Up the "Christian Persecution" Propaganda Machine

Right-wing leaders and pundits lost no tirne in trylng to turn a defeat into victory by portraying Boykin as a martyr for free speech and religious libefi. This is one of the Religious Right's go-to strategies: to dishonestly porfay policy disagreements - or in this case, an effort to hold officials accountable for promoting irresponsible behavior - as attacks on roligious liberty. Saíd the Family Research Gouncil's Tony Perkins, "He has done so much to defend the ideals and the freedom that America stands for. Yet his own freedoms - that he fought to protect for others - have been taken from hirn."

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Propaganda Technique 1: Distort the lssue as a question of Religious Freedom and Free Speech

Boykin supporters immediately began porhaying opposition to his appeârance as an attack on Boykin's Christian faith and his freedom of speech. Ken Blackwell and Ken Klukowski of the Family Research Council declared that Boykin was kept from speaking at West point "because of his Christian beliefs." Frank Gaffney, himself a font of antiMuslim bigotry, railed in The Washington Times against "the suppression of Gen. Boykin's right to expiess-himself - and, for that matter, to enjoy freedorn of religion." The Family Research Council sent an action alert to members blaming Boykin's withdrawal on "the Obama Adminlstration's continuing track-record of hostility toward Christianity." FRC's Tony Perkins urged activists to "Sign our petÍtion urging Congress and the Obama administratión to take aclion to end the purging of Christianig from the military."

Diana West one of Boykin's co-authors on the "Team B ll" report, argued that the issue was about freedom of inquiry: 'Boykirt's opinion about a legitimate topic oi discusslon is cause for ejecting him ftom West Point, The effect is to marginalize further the quest for open debate about lslam and its threat to liberty - and to marginalize further those who seek it." Boykin hirnself pushed thls line of attack, saying 'The message is that people of faith and conservative Americans are losing our voice to a very well-organized and very well-funded group of very passionate people -those being the atheists and the Muslims. They want to change the nature of our culture - and they are succeeding."

On a radio show with Religious Right leaders Tony Perkins and Tm lÂ/ildmon, Boykin said:

This is golng tq Set worse unless the American people - and particularly people for faith, Christians - rise up and say that we're going to draw a line in tire sand .,. They contact their congressman, they let their congressman know that this is not their vatues, that they believe in the First Amendment, not only free speech, but the freedorn of religion. And I think they have to get the leadeiship involved in this and I think that the Administration needs to hear through the Congress that there are a lot of Americans who do not endorse this sort of tning. \Mlère's it going to stop?

Propaganda Technigue 2: Mischaracterize the Opposition

Gaffney's Washington Tmes op-ed pushed a silencing-of ChristÍans interpretation of the controversy by focusing only on opposition tc Boykin by the Council forAmerican-lslamic (CAIR), Relations which he described as "the organization demanding that [Boykin] be silenced." Todd Stearns of Fox News & Cornmentary headlined an article "Muslims, Atheists Pressure Military to Remove Christian Speaker."

The Family Research Council told ¡ts activists, "The Academy moved Boykin to pull out of the event when a handful of atheist and Muslims cadets comþhineO aboi¡t Boykin's belieË. The message to this elite, three-star wanísr was obvious: You and your faith aren't welcome." These claims ignore the vÍgorous and well-articulated opposition to Boykin's

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appearance from VoteVets, the Forum on the Mllitary Chaplaincy, and a group of 27 West Point faculty and 74 cadets working with the Military Religious Freedom Èoundaüon, the vast majorig of them selÊidentified as Christians.

Boykin has even blamed the media, claiming that the nation's leaders are aftaid to take on radical lslamists 'because of the liberal media. The media is going to support the enemy. That's the bottom line - the mainstream media is." Propaganda Technigue 3: Whitewash History

After his Ocean City speech, Boykin told a reporter, 'The Muslim people are a precious people and I respect them and their right to worship, so long as they don't fall into the category of a radical who wants to destroy the Constitution." \Mlenasked by Fox News anchor Megyn Kelly about his past statements, including his view that Muslims should be barred from immigrating to, and building mosques in America, Boykin claimed he had misspoken and that he had merely been opposing the so-called "Ground Zero Mosque." He complained to the Christian Broadcasting Network that his vlernæ "have been grossly misrepresented." Unfortunately for Boykin, whitewashing history is a little harder ¡nine YouTube era; People For the American Way's Right Wing Watch has full documentation of Boykin's statements.

Propaganda Technique 4: Blame Obama

Since the primary goal of the Religious Right political movement today is the defeat of President Obama, and Religious Right leaders routinely and falsely characterize the administration as anti-religious and anti-ChristÍan, it is not surprising that Religious Right officials have tried to blame the controversy on the presidenL Tony Perkins said, "There seems to be pressure coming from within the administration to sweep Christianity off the face of military bases," Ken Blaclcwell echoed the charge: "This sad episode is y-et another example of the Obama administration's ongoing hostility to people of faith, especially Christians," The Family Research Council's Tony Perkins wrote, 'The ObamaAdministration is advancing an environment of religious disarmament among the military - and it must be stopped quickly for the sake of our solders' spiritual lives." Boykin himsstf has joined in, Tying that the adminishation has "shown favor to lslam at the same time that fhey have denigrated both Christianity and Judaism." Perkins saÍd that even if the -The order did not some from Obama's desk, President has created an environment that has become hostile to Christianity in thls country."

There has been no indlcation that administration officials were involved in conversation about the prayer breakfast. lndeed, West Point officíals initially defended he invitation to Boykin; he himself said he withdrew after a conversation with West Point's chaplaln about the pressure that had been put on the school's leadership. Propaganda Technique 5: Shout'nsharia!,,

Boykin is part of a brigade of right-wing activists who claim that the U.S. is under dire threat o{.h_a.ving the Constitution supplanted by Sharia law. As noted earlier, Boykin is a co-author of "Sharia, the Threat to America," popularly known as the Team B ll repórt. American

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Family Association spokssman Bryan Fischer made the nonsensical claim that criticism of Boykin's invitation to address West Point was sonehow a sign that.sharia law ls gaining a prefened place ln the United States rnilitary. The Truth

No one has challenged retlred Gen. Boykin's freedom of religion or freedom of speech, He is like all Americans free to speak, preach, and prosetytize. He is free to contînue to travel around the country promoting religious bigotry and calling for legalized discrìmination against some Americans based on heir religious beließ, He ls free to make his case in the medfa, as he has continued to do since withdrawing from the West Point prayer breakfast. And he ís even ftee to claim that critici¡ing his outrageous statements is the equivalent of an attack on his personalfreedom.

But General Boykin has no "nghl" to be free from criticism. And he has no "righf'to have his 'inesponsible positibns promoted by public officials. lndeed, Arnericans who value free speech and religious liberty have good reasons to challenge Boykin's assertions, and to hold accountable publlc officials who glve hls extremisrn øedibiiity it Ooes not deserve.

A new Right l/V9ng Watch ln Focus report from People For the Arnerican Way about Lt. Gen. Jerry Boykin (Ret.) provides a case study in the Rel¡gious Right's propaganda techniques.

Download tlur report a¡ a PDF. ¡¡ A Story lmage:

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Source URL: túb/fir¡rç.pfaw.on/'v¡rfi-in:focrrslms¡l¡!¡çfr¡aÉ,v4pnçigrrs"brìlkin Llnlts: [1 J http:l/site.pfaw.org/pdf/Boykin-Report.pdf

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From: Mullinax, Melissa Sent: Tuesday, January 13, 2015 1-2:1-5 PM To: Torres, Anne; Byrd, Candace; Taylor, Katrina; Garland, Jenna Subject: Support on Cochran Issue

Team-

This NYT editorial should be widely distr¡buted! lt was posted online this morning. http://mobile.nytimes.co m/2Of5/OU 13/opinion/god-gays-and-the-atlanta-fire-department. html

- ADL will publicly release letter today. - jeff graham/ga equality is writing long piece for ajc op ed page- will support firing decision in detail- will run Thursday - Faith in Public Life will run ajc oped Friday. - I will be at the FIPL press conference this morning at the Capitol at l.Oam.

Thanks, MM

Sent from my iPhone

coA-EMAtL004089 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 131 of 141

From: Mullinax, Melissa Sent: Tuesday, January L3,2015 6:06 PM To: Joe Binns Subject: Fwd: Messages for Social Media

Joe: See below. Help how you can

Thanks

Sent from my iPhone

Begin forwa rded message:

From: "Torres, Anne" Date: January t3,2OI5 at 11:56:20 AM EST

To: "Mul li nax, Mel issa" Subject: Messages for Social Media

MM-

Please forward to all of our supporters and organizations. These are ready to go. We want #lStandWithKasim trendi ng.

Tw¡tter Messages #lStandWithKasim because all employees have a right to a boss who does not speak of them as 2nd class citizens. http://nyti.ms/IKFECYc

#lStandWithKasim because there is no place for discriminat¡on in the workplace

http : //nvt i. ms/1 KFECYc

Religious freedom have been violated? An assertion that is as wrong as it was predicta ble. http ://nvti. ms/LKFECYc #l Sta ndWith Kasim

Atlanta is a welcoming city for all - let's keep it that way #lStandwithKasim http://nvti. ms/IKFECYc g Pl¡[mFF',S iå QfilBF Ça oà -----.É.ì- fr:/r.\t7.1^ Facebook Messages

Finally! Someone gets it right. There is no place for discrimination in the workforce. I support Mayor Kasim Reed's decision to terminate the Fire Chief. http:/lnvti.ms/IKFECYc

Religious freedoms have been violated? An assertion that is as wrong as it was predictable Read today's New York Times Editorial here: http://nvti.ms/]-KFECYc

coA-EMAtL004172 t , Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 132 of 141 a

#lStandwithKasim because he has it right: everyone, no matter who they love, should come to work without fear of discrimination. Read it here: http://nyti.ms/IKFECYc

Anne Torres Director of Com munications Office of Mayor Kasim Reed (o)404.330.6423 (c) 404.904.2618 (F) 404.s46.2983 www.atlantaga.Aov @AnneMTorres

Stoy connected onTwitter: @CityofAtlanta and @KasimReed

coA-EMAtL004173 ù Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 133 of 141 f

From: Mullinax, Melissa Sent: Tuesday, January 13, 2015 6:08 PM To: Norma Driebe Subject: Fwd: Messages for Social Media

NJ- The Mayor is getting hit pretty hard bythe religious right. Willyou help us by posting on your Facebook page?

See suggested messages below.

Than ks !

Sent from my iPhone

Begin forwarded message:

From: "Torres, Anne" Date: January 13,2O15 at LL:56:20 AM EST

To: "Mu I li nax, Melissa" Subject: Messages for Social Media

MM.

Please forward to all of our supporters and organizations. These are ready to go. We want #lStandWith Kasim trending.

Tw¡tter Messages #lStandWithKasim because all employees have a right to a boss who does not speak of them as 2nd class citizens. htto://nvti ms/IKFECYc

#lStandWithKasim because there is no place for discrimination in the workplace. http:l/nvti. ms/IKFECYc

Religious freedom have been violated? An assertion that is as wrong as it was

predicta b le. http :/lnyti. ms/IKFECYc #lSta ndWith Kasi m

Atlanta is a welcoming city for all - let's keep it that way #lStandwithKasim g T http://nvti. ms/IKFECYc Ë å ô c'z Èu 7 Facebook Messages

Finally! Someone gets it right. There is no place for discrimination in the workforce. I support Mayor Kasim Reed's decision to terminate the Fire Chief. http://nyti.ms/1KFECYc

1

coA-EMAtLOO4275 t Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 134 of 141

Religious freedoms have been violated? An assertion that is as wrong as it was predictable Read today's New York Times Editorial here: http://nvti.ms/LKFECYc

#lStandwithKasim because he has it right: everyone, no matterwho they love, should come to work without fear of discriminat¡on. Read it here: htto://nvti ms/IKFECYc

Anne Torres Director of Communications Office of Mayor Kasim Reed (o)404.330.6423 (c) 404.e04.2618 (F) 404.s46.2983 www.atlantaga.gov @AnneMTorres

Stay connected onTwitter: @CityofAtlanta and @KasimReed

2

coA-EMAtL004276 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 135 of 141

From: Mullinax, Melissa Sent: Tuesday, January L3,20L5 6:09 PM To: Natalie Zellner; Cecily Craighill Subject: Fwd: Messages for Social Media

NZ, CC: See below. lf you guys can help by posting on FB or twitter, that'd be great.

Tha n ks.

Sent from my iPhone

Begin forwarded message:

From: "Torres, Anne" Date: January 13,2OtS at Ll":56:20 AM EST To: "Mul li nax, Melissa" Subject: Messages for Social Media

MM.

Please forward to all of our supporters and organizations. These are ready to go. We want #lStandWithKasim trendi ng.

Twitter Messages #lStandWithKasim because all employees have a r¡ght to a boss who does not speak of them as 2nd class citizens. http://nvti.ms/IKFECYc

#lStandWithKasim because there is no place for discriminat¡on in the workplace http ://nyti. ms/LKFECYc

Religious freedom have been violated? An assertion that is as wrong as it was

predicta b le. http ://nyti. msll-KFECYc #lSta ndWith Kasim

Atlanta is a welcoming city for all - let's keep it that way #lStandwithKasim $ E EXHIBIT http ://nvti. ms/IKFECYc å q, + ,5

Facebook Messages

Finallyl Someone gets it right. There is no place for discrimination in the workforce. I support Mayor Kasim Reed's decision to terminate the Fire Chief. http:l/nyti.ms/]-KFECYc

Religious freedoms have been violated? An assertion that is as wrong as it was predictable Read today's New York Times Editorial here: http://nvti.ms/IKFECYc

coA-EMAtL004064 I Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 136 of 141 f

#lStandwithKasim because he has it right: everyone, no matter who they love, should come to work without fear of discrimination. Read it here: http://nvti.ms/IKFECYc

Anne Torres Director of Comm unications Office of Mayor Kasim Reed (o)404.330.6423 lc) 4o4.9a4.2678 (F) 404.s46.2e83 www.atlantaAa.gov @AnneMTorres

Stay conneded on Twitter: @CityofAtlanta and @KasimReed

2

coA-EMAtL004065 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 137 of 141

From: lillian govus Sent: Tuesday, January L3,2015 6:39 PM To: Mullinax, Melissa Subject: Re: Messages for Social Media

You got it!

On Tue, Jan 13, 2015 at 1:06 PM, Mullinax, Melissa

Thanks.

Sent from my iPhone

Begin forwarded message

From: "Torres, Anne" > Date: January 73,2015 at 77:56:20 AM EST To: "Mullinax, Melissa" > Subject: Messages for Social Media

MM-

Please forward to all of our supporters and organizations. These are ready to go. We want #IStandWithKasim trending.

Twitter Messages #IStandWithKasim because all employees have a right to a boss who does not speak of them as2nd class citizens http ://n)¡ti. rns/ I KFECYc #IStandWithKa I because there is no place for discrimination in the workplace. http://ri)¡ti.ms/l KFECYc Religious freedom have been violated? An assertion that is as wrong as it was predictable. http.//nyti.ms/IKFECYc

#IStandWithKasim Atlanta is a welcoming city for all - let's keep it that way #IStandwithKasim http://nyti.ms/IKFECYc

Facebook Messages Finally! Someone gets it right. There is no place for discrimination in the workforce. I support Mayor Kasim Reed's decision to terminate the Fire Chief. http://nyti.ms/IKFECYc Religious freedoms have been violated? An assertion that is as wrong as it was predictable. Read today's New York Times Editorial here: http ://n)¡ti. ms/ I KFECYc #IStandwithKasim because he has it right: everyone, no matter who they love, should come to work without fear of discrimination. Read it here: http ://nyti. ms/1 KFECYo

Anne Torres Director of Communications Office of Mayor Kasim Reed (o) 404.330.6423

coA-EMAtL003966 , Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 138 of 141 , (c\404.904.2618 (F) 404.s46.2983 www. atlantaga. gov @AnneMTorres

Stay connected on Twítter: @CityofAtlanta and @KasimReed

¡

coA-EMAtL003967 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 139 of 141

From: Mullinax, Melissa Sent: Tuesday, January 13,20L5 7:40 PM To: Torres, Anne; Garland, Jenna Cc: Shahar, Robin Subject: press release- 1-1.3-20L5 Attachments: press release- 1-13-2015.doc

coA-EMAtLA04208 Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 140 of 141

PRBSS RBLEASE

City of Atlanta Releases the Larv Department's Investigative Report of Kelvin Cochran

ATLANTA- The City of Atlanta Law Department performed a thirty-day investigation into the publication of the book Who Told You That Yozt Were Naked by former Fil'e Chief Kelvin Cochran. The Law Department issued its findings in an Investigative Report released on January 9,2015.

The lnvestigative Report shows that Mr. Cochran did not have authority to publish the book as requiled by the Atlanta Code of Ordinances and that he distributed the book to at least nine subordinates at wolk. It also describes a general consensus among the interviewed Atlanta Fire Rescue Department employees that Mr. Cochran's book publication, in his capacity of Fire Chie{ undermined his ability to provide leadership to the Department in the future.

The findings demonstrate the inaccuracy of the relentless assertions, by a vocal minority, that the Mayor terminated Mr'. Cochran for his religious beliefs.

"Mr. Cochlan and I are both men of faith," said Mayor Kasim Reed. "My decision has nothing to do with his religion and everything to do with his judgment and conduct as the leader of the Atlanta Fire Rescue Department and a member of my Cabinet. Ml. Cochran ignored the City's Ethics Code which establish a clear protocol which musl be followed before a Commissioner may engage in private activity for pay. Mr. Cochran made numerous judgment decisions regarding the book that are unacceptable for a leader in City of Atlanta government: he sold the Book withoul the requisite approval; he authored the book identifying himself as the Atlanta Fire Chief; he distributed the book at work, despite the fact that is content expressed opinions which are contrary to tlie City's and my personal commitment to nondiscrimination; he exposed the City to potential litigation frorn employees; and he published the book without ever mentioning it to me. Mr. Cochlan's decisions as a City official, not his religion, resulted in his termination."

Authoritv

Atlanta's Ethics Code estabüshes the required applovai process for Departrnent heads who wish to engage in outside activities "for remuneration". Commissioners - . . may engage in private employment or render services for private interest only upon obtaining prior written approval fi'om the board of ethics in accordance with this paragraph. The board of ethics shall review each request individually and provide written approval or disapproval of the notification within thirty days. (Atlanta Code of Ordinances, Section 2-820 (d).

o 2et ÈU 7

coA-EMArL004209 I Case 1:15-cv-00477-LMM Document 124 Filed 05/01/17 Page 141 of 141

The independent report found that "no such approval was sought or rendered in the publication of the book that is available on Amazon.com for purchase". (Investigative Report, p. l).

Distribution of Book in Worknlace

The Investigative Report determined that Mr. Cocluan distributed his book in the worþlace to at least nine individuals. Three of them stated that the book was given to them without a request on their part. (Investigative Report, p. 2)

Most notably, Mr. Cochran provided the book to a Battalion Chief during a professional counseling one-one-one session. The Battalion Chief did not request a copy of the book. The purpose of the session was to discuss what the Battalion Chief needed to do to prepale himself for appointment to the position of Assistant Chief. The Assistant Chief position rs the only s\Morn position that a Fire Chief may appoint using his sole discretion; all other sworn positions are filled through a pre-determined selection process- (Investigative Report, p. 2)

Discinlinarv Decision s

The Investigative Report found no indication that Mr. Cochran allowed his religious beliefs to compromise his disciplinary decisions. (Investigative Report, p. 3)

None of the witnesses interviewed for the Investigative Report were able to identifo a specific instance of unfair treatment by Mr. Cochran based on his religious beliefs. One of the witnesses, a lesbian who is a retired Battalion Chiei stated that during her employment, she suspected Mr. Cochran's religious beliefs and consequently took a voluntary demotion. (Investigative Report, p. 4)

Judgment as Department Head

The Investigative Report evinces that Mr. Cochran's actions undermined his ability to lead the Atlanta Fire Rescue Department. "There was a consistent sentiment among the witnesses that firefighters throughout the organization are appalled by the sentiments expressed in the book. There is also a general agreement the contents of the book have eroded trust and have compromised the ability of the chief to provide leadership in the future. . . . [Union president Borders] echoed the sentiment of distrust and disgust created by the contents of the book with the representation in the book that Chief Cochran is speaking in his capacity as AFRD Chief," (Investigative Report, pp. 3-4)

2

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