________________________________________________________________________

In the matter of:

Deborah Kuether
vs.
Keith P. Posley, et al.

Case No.: 2:23-CV-948

Witness: Keith Posley

Date: April 28, 2025

Court Reporter: Alicia Pabich, CSR

_______________________________________________________________________

790 North Milwaukee Street, Suite 100-C

Milwaukee, WI 53202
414.585.8128
www.creamcityreporting.com
 Keith Posley 4/28/2025 1 (1)

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF WISCONSIN
MILWAUKEE DIVISION
-----------------------------------------------------
DEBORAH KUETHER,

Plaintiff,

-vs- Case No. 2:23-CV-948

KEITH P. POSLEY, et al.,

Defendants.
-----------------------------------------------------

Videotaped examination of KEITH POSLEY,

taken at the instance of the Plaintiff, under and
pursuant to Section 804.05 and 805.07 of the
Wisconsin Statutes, before ALICIA PABICH, a Certified
Shorthand Reporter and Notary Public in and for the
State of Wisconsin, at Radtke Law Office, LLC, 15850
West Bluemound Road, Suite 300, Brookfield,
Wisconsin, on April 28, 2025, commencing at 9:08 a.m.
and concluding at 4:58 p.m.

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1 A P P E A R A N C E S
2 CROSS LAW FIRM, S.C., by
MR. BEN HITCHCOCK,
3 MS. ELLA UYLAKI,
845 North 11th Street,
4 Milwaukee, Wisconsin 53233,
appeared on behalf of the Plaintiff.
5
von BRIESEN & ROPER, S.C., by
6 MS. LAURIE MCLEROY,
MS. HANNA KOLBERG,
7 411 East Wisconsin Avenue, Suite 1000,
Milwaukee, Wisconsin 53202,
8 appeared on behalf of the Defendants.
9 A L S O P R E S E N T
10 MS. DEBORAH KUETHER,
Plaintiff.
11
MR. MIKE DEGUELLE,
12 Videographer.
13 * * * * *
14

15

16

17

18

19

20

21

22

23

24

25

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1 I N D E X
2 Examination: Page
3 By Mr. Hitchcock................................ 7
4

5 Exhibits Identified: Page

6 Exhibit 1 -Recommended Appointments........... 51
Exhibit 2 -Letter, Dated 12/7/2021............ 61
7 Exhibit 3 -Memorandum, Dated 10/13/2021....... 62
Exhibit 4 -Letter, Dated 1/7/2020............. 98
8 Exhibit 5 -Board Governance Policy 3.08....... 156
Exhibit 6 -Memorandum, Dated 11/5/2020........ 173
9 Exhibit 7 -E-Mail, Dated 8/6/2020............. 179
Exhibit 8 -Letter, Dated 10/16/2020........... 184
10 Exhibit 9 -E-Mail, Dated 7/21/2021............ 224
Exhibit 10 -
Letter, Dated 5/20/2021............ 239
11 Exhibit 11 -
Video Entitled, "Holiday Explains
to Police How the Door is Usually
12 Open".............................. 296
Exhibit 12 - Audio File Entitled, "HR Chief
13 Advises for Employees to Defy
Subpoenas"......................... 301
14 Exhibit 13 - Video of Portion of Trial of Dr.
Holiday............................ 308
15 Exhibit 14 - Video Entitled, "She Filed a
Complaint Against Me".............. 311
16
Disposition Of Original Exhibit/s:
17
Attached To Original Transcript
18
Line Page
19 Question Certified ........................ 13 312
20

21

22

23

24

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1 TRANSCRIPT OF PROCEEDINGS 1 for the record, then the court reporter will
2 2 swear in the witness.
3 THE VIDEOGRAPHER: We are going on 3 MR. HITCHCOCK: With and on behalf of
4 the record. The time is 9:08. Today's date is 4 the plaintiff, Ben Hitchcock Cross of Cross Law
5 April 28th, 2025. My name is Mike Deguelle. 5 Firm. Also appearing with me from my law firm
6 My notary ID is 25886. I hold the commission 6 is Ella Uylaki. She is not an attorney, she is
7 at the Notary Public within Wisconsin with full 7 a clerk.
8 authority to perform all powers and duties of 8 MS. MCLEROY: Are you going to note
9 that office in accordance with Chapter 140 of 9 the plaintiff is also here?
10 the Wisconsin Statutes, to hold together office 10 MR. HITCHCOCK: I said "with," but
11 with all rights and privileges for the term of 11 yes --
12 four years, beginning May 24th, 2024 and 12 MS. MCLEROY: Oh, okay.
13 expiring May 23rd, 2028. 13 MR. HITCHCOCK: -- and I'm also
14 This is media unit number one of the 14 appearing with the plaintiff as well.
15 video-recorded deposition of Keith P. Posley. 15 MS. MCLEROY: Laurie McLeRoy
16 This is taken in the matter of Kuether versus 16 appearing on behalf of the defendants.
17 Posley, et al. This case is filed in the 17 MS. KOLBERG: And Hannah Kolberg also
18 United States District Court Eastern District 18 appearing on behalf of the defendants.
19 of Wisconsin, Case Number 23-CV-948. The 19 MS. MCLEROY: And before we go
20 deposition is being held at Radtke Law Office, 20 further, I just want to note for the record
21 15850 West Bluemound Road, Suite 300, 21 that we're actually not in the office of
22 Brookfield, Wisconsin 53005. 22 Attorney Radtke, but we're in her office
23 I'm the video recorder for today's 23 building in a conference room on the lower
24 deposition. At this time, I will ask counsel 24 level.
25 to state their name, appearance, affiliation 25 Can I confirm, also, that there are
Page 6 Page 7
1 no other recordings going on other than the 1 the video transcripts and how one can order the
2 videographer and what the stenographer is 2 video from you?
3 doing? 3 THE VIDEOGRAPHER: Yes, I can. You
4 MR. HITCHCOCK: And the last time we 4 want that at this time?
5 did this, which was at Dr. Kuether's 5 MS. MCLEROY: Sure.
6 deposition, I believe we all went around the 6 THE VIDEOGRAPHER: I'm prepared to
7 room and certified that we weren't recording. 7 follow up with you after.
8 Is that what you'd like to do here? 8 MS. MCLEROY: Okay. The clients let
9 MS. MCLEROY: That would be greet. 9 us know on the record, but okay. Go ahead.
10 MR. HITCHCOCK: Okay. I will start 10 MR. HITCHCOCK: Is that -- that's
11 then. My name is Ben Hitchcock Cross. I am 11 all?
12 not recording this deposition. 12 MS. MCLEROY: That's it.
13 MS. KUETHER: Deborah Kuether. I am 13 MR. HITCHCOCK: Great. Thank you.
14 not recording this deposition. 14 KEITH POSLEY, called as a witness
15 THE VIDEOGRAPHER: Mike Deguelle. I 15 herein, having been first duly sworn on oath,
16 am not recording beyond the camera I am 16 was examined and testified as follows:
17 operating in front of you. 17 EXAMINATION
18 MS. KOLBERG: Hannah Kolberg. I am 18 BY MR. HITCHCOCK:
19 not recording. 19 Q Good morning, Mr. -- Dr. Posley. Are you ready
20 MS. MCLEROY: Laurie McLeRoy. I am 20 to proceed?
21 not recording. 21 A Yes.
22 MS. UYLAKI: Ella Uylaki. I am not 22 Q Okay. And are you -- you are able to proceed
23 recording. 23 here today?
24 MS. MCLEROY: And, also, 24 A Yes.
25 Mr. Deguelle, can you let us know how you store 25 Q Okay. Now, I believe that you worked at MPS at

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1 some point; is that true? 1 I think they changed the name to administrative
2 A Yes. 2 specialist, and after which, regional
3 Q Okay. Now, were you ever a teacher? 3 superintendent because the name got changed
4 A Yes. 4 again.
5 Q When did that happen? 5 Q Can I just pause you there. When did you
6 A In 1990 through '95. 6 become a regional superintendent?
7 Q Okay. And then I understand you were a 7 A I would have to look back at documentations. I
8 principal at Benjamin Carver; is that right? 8 just don't have them.
9 A No. 9 Q Fair enough.
10 Q Where were you at after that? 10 A It's a long -- I've had a long career with
11 A Clark Street -- 11 Milwaukee Public Schools, and the exact year I
12 Q Clark Street. 12 would need to just verify, but yes.
13 A -- School. 13 Q Okay. And excuse me for interrupting, but what
14 Q Okay. And you've held other positions as 14 was the position you had after that?
15 principal; is that true? 15 A After?
16 A Summer school principal, yes. 16 Q Regional superintendent.
17 Q Okay. But I also understand that you were an 17 A After regional superintendent, I became the
18 administrator at MPS after that; is that 18 chief of school administration.
19 accurate? 19 Q Okay. And then how about after that position?
20 A Yes. 20 A Interim superintendent and superintendent.
21 Q Okay. When -- what was your next position 21 Q Okay. Now, when you were a principal, did you
22 after principal? 22 have a contract?
23 A After principal, principal coach, and after 23 A Yes.
24 principal coach, leadership -- leadership -- 24 Q Okay. And how about when you were regional
25 administrative leadership specialist, and then 25 superintendent, were you working under a
Page 10 Page 11
1 contract? 1 Dr. Gregory Thornton, William Andrekopoulos.
2 A Yes. 2 Q Do you know Dr. Kuether?
3 Q Okay. And interim superintendent also a 3 A Yes.
4 contract? 4 Q Did you work with her?
5 A Yes. 5 A Yes.
6 Q And superintendent as well? 6 Q Okay. What was the first position that you
7 A Yes. 7 held that you can recall working with
8 Q Okay. Do you know about when you became a 8 Dr. Kuether?
9 superintendent? 9 A I would -- I would say assistant principal.
10 A It was '19. Wait, hold on. Let me count. So, 10 Q Okay. You were assistant principal?
11 like, it was in 2018 when I started work, yeah. 11 A I was assistant principal before I was
12 Q Okay. 12 principal.
13 A It was into the role. 13 Q Okay. And what was she doing at that time?
14 Q And there was some period where you were 14 A I can't verify the exact job, but I knew it was
15 interim -- 15 something in literacy, reading.
16 A Right. 16 Q Okay. Was she at the central office then?
17 Q -- and then you became -- 17 A Not 100 percent sure.
18 A I started out as interim, and then it rolled in 18 Q Okay. But you were familiar with her work at
19 after that. 19 that time?
20 Q Who was -- 20 A Yes.
21 A The exact dates I don't have in the back of my 21 Q How was her work?
22 mind like that. 22 A I've never had any encounters -- no more than
23 Q I understand. Who is -- who was your 23 back and forth with PD and that kind of stuff.
24 predecessor in that superintendent position? 24 That's all I have.
25 A I had several. Dr. Darienne Driver, 25 Q Okay. Was that -- not enough to make a

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1 judgment or something else? 1 A The manager and the chief, that would have been
2 A I can't make a judgment on her work or anything 2 a couple direct -- there has been a director
3 of that nature. 3 of -- director of C&I, and then it would have
4 Q I got it. Okay. What was the next position 4 been a director of -- a senior director, and
5 that you had when you worked with her? 5 then upper.
6 A As principal of Clark Street School, and then 6 Q Okay. And I thank you for that. So
7 as administrative specialist, and then 7 Dr. Kuether worked at curriculum and
8 leadership specialist, and regional 8 instruction. Is that your under --
9 superintendent and chief of schools. 9 A In that department, that area, but the name
10 Q Okay. So let's just focus on chief of schools 10 convention changed over the years, so I don't
11 for a second. What work was she doing at that 11 know which -- which one year may have been
12 time? 12 known as C&I or whatever the situation may be,
13 A She was in the reading department, I want -- 13 but just that area -- in that area.
14 and literacy, actually, and I want to say she 14 Q And then the work is pretty much the same
15 was the manager at that time. 15 throughout that time?
16 Q Okay. And as a manager, would there have been 16 A I would think so. You know, various -- there
17 a supervisor between you as the chief of 17 was various chiefs, as well as senior directors
18 academics and Dr. Kuether? 18 and directors in that department, so their work
19 A Yes. 19 requirements may have been different.
20 Q Okay. What position would that have been? 20 Q I understand. So no matter what the area is
21 A The different positions that would have been -- 21 called, my question to you is, at what time did
22 Q Who -- sorry, excuse me. Who would have 22 you become above Dr. Kuether's work at -- over
23 been -- what position in the hierarchy would 23 curriculum?
24 have been between the manager and the chief of 24 MS. MCLEROY: I'm going to object,
25 academics at that time? 25 vague.
Page 14 Page 15
1 Go ahead. 1 and stuff.
2 THE WITNESS: Yeah. It's really the 2 Q Okay. I understand. So --
3 idea -- I was on the leadership side of this, 3 A Actually, I -- actually, I left the district,
4 and then it was the C&I side of this. So, 4 separated from the district on June --
5 therefore, I was not directly supervising or 5 June 30th, the end of -- the end started
6 directly over her work at all because at that 6 June 30th of 2024.
7 particular time, they had the Department of 7 Q Got it. Okay. Let me ask you -- and so you no
8 Accountability and the Department of Support. 8 longer work for the district now?
9 And I was on the accountability side, and C&I 9 A No.
10 was on the support side. 10 Q You don't have any or other relationship with
11 BY MR. HITCHCOCK: 11 the district now?
12 Q Okay. So then I want to move you forward in 12 A Not at all.
13 time from that to when you were the 13 Q I understand. Okay. So when you were the
14 superintendent. 14 superintendent, what was your -- what was the
15 A Uh-huh. 15 duties of that position at that time?
16 Q Okay. And about how long were you the 16 A The duties and responsibilities overall
17 superintendent? 17 day-to-day operations of the school district,
18 A Six years. 18 the school budget, the school's functioning,
19 Q Six years, okay. And you are no longer the 19 the school -- everything that in and around
20 superintendent? 20 policy, and help to bring forward policy and
21 A That's correct. 21 procedure to the board to make decisions on
22 Q When did that happen? 22 that. So all of those kinds of things. I do
23 A I think I left June 4th of 2024. We just need 23 not have a list right before me that I can just
24 to probably check the date to be exactly 24 roll down through and tell all of the things
25 because I don't have dates just rolling around 25 that I was responsible for.

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1 Q Fair enough. How did you -- when you were 1 along with that. Schooling and that, as far as
2 superintendent, how did you know what your job 2 licensure as superintendent, there's a whole
3 duties were? 3 process that goes through that particular piece
4 A There was a role and responsibilities of the 4 as well.
5 superintendent as a part of the contract. 5 Q Okay. So then we will back up there for a
6 Q Okay. So your contract is what told you? 6 second. What schooling -- what degrees do you
7 A Along with being on the job, knowing what's 7 have?
8 going on in the job, as well as being a part of 8 A What degrees do I have? I have a bachelor's
9 the district and serving with several other 9 degree, I have a master's degree, I have a
10 superintendents. 10 certificate of advanced studies, and a
11 Q Got it. Okay. So fair to say contract and 11 doctorate in education.
12 on-the-job experience? 12 Q Okay. And even though it may sound evident,
13 MS. MCLEROY: I'm going to object as 13 I'm guessing, but please tell me, are any of
14 not a complete restatement. 14 those degrees in education?
15 Go ahead. 15 A All.
16 THE WITNESS: Could you restate it 16 Q Okay. What is your doctorate from?
17 for me then? 17 A National Louis University.
18 BY MR. HITCHCOCK: 18 Q When did you get it?
19 Q Sure. I'm trying to understand how you learned 19 A 2012.
20 what your job duties as superintendent were. 20 Q Is it publish -- is -- your doctorate thesis,
21 And I'm trying to make sure that I understood 21 is that published at all?
22 you correctly, and when you said that it was 22 A With National Louis University, they have a --
23 the contract informed you, and what I am 23 a place where they publish all of them, where
24 paraphrasing is on-the-job experience. 24 they have them. As far as being published with
25 A But there is a number of other things that go 25 academic literature, I am not sure what they
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1 have there as far as -- but they do have a 1 Go ahead.
2 depository that they are placed in. 2 THE WITNESS: I don't quite
3 Q And what's your thesis? What was your thesis? 3 understand where you are going there, but the
4 A I did a phenomenology of study of African 4 idea there is a plethora of different things
5 American leadership. 5 that inform the day-to-day work and role of the
6 Q Okay. Do you -- is there a race that you 6 superintendent.
7 identify with? 7 BY MR. HITCHCOCK:
8 A Yes. 8 Q I understand. Okay. So let's focus then on
9 Q What is that? 9 the school board. What is the relationship
10 A African American. 10 between the superintendent and the school board
11 Q I will try to use African American going 11 while you were the superintendent?
12 forward. Is that the word you want to use? 12 A I report to the school board. And the
13 A It's fine. 13 school -- the school board is my direct
14 MS. MCLEROY: I'm going to object, 14 supervisor -- was my direct supervisor.
15 vague as to context. 15 Q So -- well, is it the case -- is there any
16 BY MR. HITCHCOCK: 16 other employees of the school district that the
17 Q I understand. Okay. So -- and so far, just to 17 board of directors super -- also supervises?
18 go back to where I think we were, we have got 18 A Yes.
19 the -- on the subject of what informed your job 19 MS. MCLEROY: Object, vague as to
20 duties as superintendent, we've got the 20 time.
21 contract, we've got on-the-job experience and 21 BY MR. HITCHCOCK:
22 we've got schooling. Is there anything else we 22 Q Fair enough. While you were superintendent.
23 should add to that list? 23 A Yes.
24 MS. MCLEROY: Again, misstates his 24 Q Okay. Who else is that?
25 prior testimony. 25 A The board clerk, which was Dr. Mann at the

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1 time. And accountability and efficiency, which 1 Go ahead and answer if you know.
2 is Matt Chason. 2 THE WITNESS: No, I don't know.
3 Q And then I understand there's an office -- the 3 BY MR. HITCHCOCK:
4 board has an office as well. Does that office 4 Q Okay. Was there any complaints against
5 also have employees? 5 Dr. Mann when she left the district --
6 A Yes. 6 MS. MCLEROY: I'm going to object --
7 Q Okay. Now, Dr. Mann is no longer the board 7 BY MR. HITCHCOCK:
8 clerk; true? 8 Q -- if you are aware?
9 A Yes. 9 MS. MCLEROY: -- foundation.
10 Q Okay. And she stopped being the board clerk 10 Go ahead.
11 while you were the supervisor; true? 11 THE WITNESS: I'm not aware. I don't
12 A I never supervised Dr. Mann. 12 know.
13 Q Superintendent. 13 BY MR. HITCHCOCK:
14 A Yes. 14 Q Okay. And to be clear, it's -- is it fair to
15 Q While you were the -- 15 say you don't have any awareness of why
16 A Yes. Yes. 16 Dr. Mann left the district?
17 Q Sorry. And just so we have a clean record, 17 MS. MCLEROY: Asked and answered.
18 Dr. Mann stopped being the board clerk while 18 Go ahead.
19 you were the superintendent? 19 THE WITNESS: No, I'm not aware.
20 A That's correct. 20 BY MR. HITCHCOCK:
21 Q Okay. Thank you. Based on your role as 21 Q I understand. Okay. Now, you said earlier
22 superintendent, did you learn why Dr. Mann left 22 that you reported to the school board as the
23 the district? 23 superintendent. Did I understand that right?
24 MS. MCLEROY: I'm going to object, 24 A That's correct.
25 relevance. 25 Q What does "report to the school board" mean to
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1 you? 1 Well, let me explain. It's not -- the idea is
2 A What does it mean to me? 2 there's a process that takes place. Like human
3 Q Yes. 3 recourse sources do all of those kinds of
4 A That they are -- they are my direct 4 things. I can make a recommendation.
5 supervisors, and actually, that's who I report 5 BY MR. HITCHCOCK:
6 to. There is a number of different things that 6 Q Okay. So that's -- when you say
7 have to be reported and then spelled out, and 7 "recommendation," that's also something that
8 that's -- as far as things that we have to do 8 you would need approval for; right?
9 -- that I have to do as the building super -- 9 A For the recommendation? The recommendation
10 the school superintendent at that particular 10 would have to be approved.
11 time had to go before the board for approval. 11 Q I understand. Okay. Now, what about would you
12 Q Okay. So there's some things that you -- that 12 have to -- or could you only recommend the
13 the superintendent needs approval from the 13 termination of a administrator?
14 board? 14 A Could I only recommend?
15 A That's correct. 15 Q Yeah. Sorry. Do you -- I will put it in the
16 Q Okay. And there's other things I assume then 16 positive. Did you have the power of
17 that the superintendent doesn't need approval 17 superintendent to terminate an administrator?
18 from the board? 18 A Again, I don't do terminations.
19 A That's correct. 19 Q Okay.
20 Q Okay. While you were the superintendent, could 20 A I can make a recommendation after all processes
21 the superintendent terminate a teacher? 21 have been followed.
22 MS. MCLEROY: Objection, vague, 22 Q Okay. Who would you make that recommendation
23 overbroad. 23 to for an administrator?
24 Go ahead. 24 A For an administrator, I would make that
25 THE WITNESS: The superintendent, no. 25 recommendation to the Milwaukee Board of School

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1 Directors. 1 you recommended while you were the
2 Q Okay. While you were the superintendent, did 2 superintendent?
3 you ever recommend that the Milwaukee Board of 3 A I can't think back to all -- on a daily basis,
4 School Directors terminate any administrator? 4 the number of different things that I deal
5 A I would have to go back and -- while I've been 5 with, the people that I deal with, I can't
6 employed as superintendent or as a -- 6 think of all the individuals that were
7 Q Sorry. And I do just mean to focus on 7 terminated.
8 superintendent here. And I will clean that up 8 Q Okay. And would you think it happened more
9 again. Thank you. While you were 9 than, say, ten times while you were
10 superintendent, did you ever recommend the 10 superintendent?
11 board terminate any administrators? 11 A It's possible, yes. Because anything that
12 A I would have to go back and take a look at it, 12 happens with -- anything that happens within
13 but I would say the answer would be yes, 13 the district if it was something that was
14 because there was a number of different 14 malicious or whatever the situation may be, all
15 situations that came before us that -- that may 15 of those -- a lot of those things led to
16 have led to termination. 16 termination, so --
17 Q Okay. Do you know Dan Chanin? 17 Q Okay. And while you were superintendent, did
18 A Dan Chanin, yes. 18 the school district ever terminate any
19 Q Did you work with him at MPS? 19 administrator's employment without the approval
20 A Yes. 20 of the board?
21 Q Okay. Did you ever recommend his termination? 21 A Not --
22 A No. 22 MS. MCLEROY: Can I have that
23 Q Okay. And I guess to put this another way, you 23 question read back?
24 are not able to, sitting here today, tell us 24 (Record read.)
25 the name of any administrator whose termination 25 MS. MCLEROY: Okay. Go ahead.
Page 26 Page 27
1 THE WITNESS: Not that I'm aware of. 1 A Because --
2 BY MR. HITCHCOCK: 2 Q Sorry, because I think you are saying did
3 Q Okay. Now, while you were the superintendent, 3 somebody bring their contract to you to take a
4 were all the administrators working under 4 look at. What I'm asking you is while you were
5 contract? 5 superintendent, did you ever see any
6 A That is something I think that everyone was 6 administrator contracts?
7 under contract. 7 MS. MCLEROY: Other than his own?
8 Q Okay. 8 BY MR. HITCHCOCK:
9 A And let me make it clear here, that's an HR 9 Q Other than your own.
10 function. That is not at my level. I do not 10 A Other than my own.
11 do -- I do not do contracts for anyone, so, 11 Q Fair enough. Thank you.
12 therefore, that's an HR function. 12 A I would have to say no, I don't think so. No
13 Q Okay. But while you were superintendent, did 13 one has -- I have never -- that is not -- that
14 you ever see any contracts for any 14 is not a place that I spent time looking at
15 administrators? 15 contracts.
16 A Did I ever see any? 16 Q Okay. How about non-renewal, did you ever
17 Q Yeah. 17 non-renew any administrators while you were a
18 A I've seen them in the past, but no one ever 18 superintendent?
19 brought me the contract and sent me their 19 A Yes, there were non-renewals.
20 contract and, you know, to say take a peek at 20 Q Okay. Do you know about how many?
21 this, no. 21 A It -- it will be speculation and guessing.
22 Q Okay. During the entire time you were 22 Q Okay.
23 superintendent, to be clear? 23 A I'm not -- I can't sit here and tell you an
24 A To me, to take a look at their contract? 24 exact number.
25 Q And -- 25 Q But more than ten?

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1 MS. MCLEROY: I'm sorry, are we still 1 Q Okay. And do you know Calvin Fermin?
2 talking about administrators? 2 A Yes.
3 MR. HITCHCOCK: Yes, only 3 Q Did you work with Calvin Fermin?
4 administrators. 4 A Yes.
5 THE WITNESS: Only administrators 5 Q What was his job while you were at MPS?
6 would be -- would have been more than ten in 6 MS. MCLEROY: The entire time?
7 my -- 7 MR. HITCHCOCK: I think we are okay
8 BY MR. HITCHCOCK: 8 with that question.
9 Q Six years. 9 MS. MCLEROY: Object, overbroad.
10 A -- six years as the superintendent. I'm not 10 Go ahead.
11 sure. I don't want to give you a number that 11 THE WITNESS: From the time from --
12 -- that I'm not looking at. I can't say over 12 at one time Calvin Fermin was the city
13 six years -- this is talking about six years of 13 attorney, and then he was also the deputy
14 how many people, and I do -- I can say that 14 superintendent on the finance side.
15 there were people that were non-renewed. 15 BY MR. HITCHCOCK:
16 Q Okay. And could you name any of those people 16 Q Okay.
17 here today? 17 A Go ahead.
18 A No. 18 Q But he -- when he was with the city attorney,
19 Q Okay. Now, do you know Dr. Holiday? 19 he worked for the -- he didn't work for MPS.
20 A Yes. 20 Is that your understanding?
21 Q Did you ever work with Dr. Holiday? 21 A That's correct.
22 A Yes. 22 Q Okay. So the only position he ever held --
23 Q Okay. I'm assuming from your previous answer 23 A He worked -- he worked -- he worked for the
24 that you worked with Dr. Mann, the clerk? 24 city attorney's office, but he did work -- he
25 A Yes. 25 was -- he worked on some of the MPS cases and
Page 30 Page 31
1 things as well. 1 know if there was an -- it was -- I don't know
2 Q Did you work with him while you were at MPS 2 if it was an issue with her contract or it was
3 while he was at the city attorney's office? 3 an issue with her with the school board. I
4 MS. MCLEROY: I'm going to object, 4 don't know. I really don't have all of those
5 vague. 5 details.
6 But go ahead. 6 Q I understand. Did you work with Calvin Fermin
7 THE WITNESS: I am just trying to 7 with your contract?
8 think of -- I think there was -- there was a -- 8 A Did I work with Calvin Fermin in my contract?
9 I would say yes, on one case I remember. 9 MS. MCLEROY: I'm going to object,
10 BY MR. HITCHCOCK: 10 vague.
11 Q Okay. Now, when you became the superintendent, 11 Go ahead.
12 as I understand it, Darienne Driver was the 12 THE WITNESS: No. Calvin was not the
13 previous superintendent; is that true? 13 person that did our contract -- did my
14 A Yes, he was the previous superintendent. 14 contract.
15 Q And her contract -- there was an issue with her 15 BY MR. HITCHCOCK:
16 contract; is that true? 16 Q Okay. And this was --
17 MS. MCLEROY: I'm going to object, 17 A It was a young -- it was a lady. I'm just
18 foundation. 18 trying -- she's no longer with the city
19 Go ahead. 19 attorney's office that did my contract.
20 THE WITNESS: There was an issue with 20 Q And this is your 2018 contract that you are
21 it? What do you mean? Like at the end when 21 talking about now?
22 she was leaving or -- 22 A 2018, yes.
23 BY MR. HITCHCOCK: 23 Q Okay. Then it was -- how was it extended from
24 Q Yeah. 24 time to time, if at all?
25 A Was there an issue with her contract? I don't 25 A It was extended at -- I want to say I know two

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1 times because it was two-year contracts, and to 1 A Why was it?
2 get to six -- I know it was two or three times 2 Q Yeah.
3 that it was extended. 3 A Because I had to have a deputy superintendent
4 Q Okay. So when did Calvin Fermin become the 4 for the financial side of the house.
5 deputy superintendent? 5 Q Okay. So I'm assuming then you know
6 A I would have to look to see on record the exact 6 Mr. Fermin's credentials. Is that fair?
7 year and date. I don't have that date and 7 A From what I've seen on the resume.
8 year. 8 Q Okay. And what did you see on the resume that
9 Q Okay. Do you know how -- how he became the 9 led you to believe that Calvin Fermin knew
10 deputy superintendent? 10 about the financial side of the house, to be
11 A Do I know how? 11 fair to you?
12 Q Uh-huh. 12 A To be fair to me --
13 A I recommended his name for promotion. 13 Q Yeah.
14 Q Who did you recommend it to? 14 A -- the idea around it wasn't just a financial,
15 A To the Milwaukee Board of School Directors. 15 it was all operations, such as contracts, such
16 Q Okay. Why did you come up with that name to 16 as a number of different things on the
17 recommend? 17 facilities side of the house. So it was all of
18 A Why? 18 the facilities, all of the contracts, as well
19 Q That's correct. 19 as bus transportation, as well as
20 A Because I was looking for a candidate that 20 transportation and food services.
21 could take care of the financial side of the 21 Q Okay. What experience did Mr. Fermin have in
22 house to make sure that -- I had an educational 22 food services?
23 side of the house, financial and operational 23 A Oh, I don't know if he had -- and I can't speak
24 side of the house, and he rose to the top. 24 to what experiences that Fermin has in all of
25 Q Oh, okay. Why was that? 25 those areas. I don't -- it would unfair. I
Page 34 Page 35
1 don't have his resume before me to look at it. 1 an excellent job in the interview and a
2 But when I looked at his resume and when I 2 background that supported.
3 interviewed him, he -- and his records checked 3 Q Great. And that's -- what were the credentials
4 out as well. 4 that he had that matched?
5 Q Sure. What about his records -- and, well, 5 A Again, I cannot -- I cannot give you those
6 let's say -- you also said there was bus 6 credentials without looking -- you know, this
7 transportation; right? 7 has been a number of years ago, and having
8 A Yeah. 8 resumes I see on the daily, I cannot recall
9 Q What about his resume, if you recall, led you 9 back to someone's resume and go around their
10 to believe that Mr. Fermin knew about bus 10 resume and say what they -- what matched up.
11 transportation? 11 Q Regional superintendent is -- or, sorry, deputy
12 A Because his bus contracts. And -- 12 superintendent is a pretty important job;
13 Q What does that "bus contracts" mean? 13 right?
14 A Bus contracts is all -- a lot of legal jargon 14 A That's correct.
15 about what services will be provided and who 15 MS. MCLEROY: Objection, vague.
16 will provide those services and those things. 16 Go ahead.
17 And that's all contractural standpoint after 17 BY MR. HITCHCOCK:
18 going through procurement and those kinds of 18 Q Okay. And how many other regional -- sorry,
19 things. 19 deputy superintendents did you recommend for --
20 Q And he knew the jargon? Mr. Fermin knew the 20 while you were superintendent?
21 jargon? 21 A Rosana Mateo, Calvin Fermin and Christopher
22 A I can't speak for what honestly -- I can't sit 22 Hauser. But Christopher Hauser was interim.
23 here and say that Calvin Fermin knew the jargon 23 Q And did Calvin Fermin -- what job did Calvin
24 or whatever the situation may be. I just knew 24 Fermin have before he came to the -- to your
25 that he had credentials to match. And he did 25 school district?

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1 A He's with the -- he came to us from the city 1 that be helpful?
2 attorney's office. 2 MS. MCLEROY: Same objection.
3 Q Okay. And you knew he was an attorney; right? 3 THE WITNESS: Yes.
4 A Yes. 4 BY MR. HITCHCOCK:
5 Q Okay. Was that one of the credentials that he 5 Q And how about legal jargon, would that be
6 had? 6 helpful with that, too?
7 A Was it a -- a credential that he had when he 7 MS. MCLEROY: Same objection.
8 came in? 8 THE WITNESS: Yes.
9 Q Right. 9 BY MR. HITCHCOCK:
10 A Yeah. He had -- he's an attorney. 10 Q Okay. Who -- did you interview anybody other
11 Q Okay. And you knew that; right? 11 than Calvin Fermin when you recommended his
12 A Yes, I knew he was an attorney. 12 promotion?
13 Q Okay. And being an attorney would be helpful 13 A Yes.
14 with, for example, contracts; right? 14 Q Who would -- who else did you interview?
15 MS. MCLEROY: I'm going to object, 15 A I would have to go back and take a look, but I
16 vague, to the extent you are calling for a 16 do know right off that I can think of Debra
17 legal conclusion in that job. 17 Rash.
18 BY MR. HITCHCOCK: 18 Q Okay. And what position did she hold prior?
19 Q Just based on your knowledge and understanding 19 A Debra Rash was a principal at a school at that
20 as superintendent, would having a legal degree 20 time. Prior to that, she worked in C&I, I
21 be helpful with contracts? 21 think.
22 MS. MCLEROY: Same objection. 22 Q And do you believe that Calvin Fermin had any
23 THE WITNESS: Yes. 23 credentials to be a -- education credentials
24 BY MR. HITCHCOCK: 24 when you recommended his -- I'm using the term
25 Q Okay. And how about with bus contracts, would 25 "promotion" to deputy superintendent?
Page 38 Page 39
1 MS. MCLEROY: I'm go to object, 1 Q Okay. So you read the resume after you
2 vague, irrelevant, misstates his prior 2 interviewed her. Is that fair to say?
3 testimony. 3 A No. I seen her resume during the interview.
4 Go ahead. 4 Q No, I understand. Okay. Okay. Have you ever
5 THE WITNESS: It was the -- it was 5 been intimidated by Dr. Kuether?
6 the business side of the house as for -- it was 6 MS. MCLEROY: Object, vague,
7 not the academic side of the house. There was 7 overbroad.
8 an academic side and a business side. He was 8 THE WITNESS: What do you mean --
9 on the business side with the areas that I 9 MS. MCLEROY: If you understand, go
10 previously talked about, so yes. 10 ahead.
11 BY MR. HITCHCOCK: 11 THE WITNESS: What do you mean
12 Q I understand. Do you know if Ms. Rash is an 12 "intimidated"? What intimidated by?
13 attorney? 13 BY MR. HITCHCOCK:
14 A Do I know if she's an attorney? 14 Q Just the ordinary sense of the word
15 Q That's my question to you, yes. 15 "intimidated."
16 A I don't know if she's a practicing attorney. I 16 MS. MCLEROY: Same objection.
17 do know on her resume that she had gone to law 17 Go ahead.
18 school before. I don't know -- I don't know 18 BY MR. HITCHCOCK:
19 details or any of those kinds of things, 19 Q And, sorry, let me -- and I will back up and
20 whether she's a practicing attorney or anything 20 ask it a different way. Have you ever been
21 of that nature. But I do know -- 21 physically intimidated by Dr. Kuether, if that
22 Q Sorry. When you interviewed her, did you know 22 helps?
23 that she had gone to law school? 23 MS. MCLEROY: Same objection.
24 A No. I seen it on the -- on her -- on her 24 Go ahead.
25 resume. 25 THE WITNESS: I fear no one. So I,

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1 you know -- but I could -- I could say that -- 1 holding these signs?
2 this is on a different level, my wife when she 2 A She came to several board meetings.
3 was banging on my door at my house was 3 Q Okay. You were the superintendent at those
4 intimidated. 4 board meetings?
5 BY MR. HITCHCOCK: 5 A Correct.
6 Q Okay. And similar question, have you ever been 6 Q Okay. And while she was at those board
7 afraid of Dr. Kuether? 7 meetings, she was holding up signs?
8 A No. 8 A Yeah, a lot of people were. But yes, she did.
9 MS. MCLEROY: Same objection. 9 Q Okay. And you -- when she was holding up those
10 BY MR. HITCHCOCK: 10 signs, you recognized that it was her. Fair?
11 Q Have you ever learned of Dr. Kuether making any 11 A Yeah. She was sitting right next to me in the
12 negative public statements about you? 12 row -- the row right beside my chair.
13 A Have I ever learned of that? 13 Q And just maybe if I can paint the picture. As
14 Q Yeah. 14 I can recall, the school board meetings are
15 MS. MCLEROY: I going to object, 15 held in something like an auditorium where
16 assumes facts not in evidence. 16 there's a raised section, and then there's a
17 Go ahead. 17 seating area where the seats go up on an
18 THE WITNESS: No. I can only speak 18 incline. Is that fair?
19 of, you know, things that I have seen on her 19 A That's correct.
20 sign or whatever. But other than that, I 20 Q Okay. And then you would have been sitting on
21 haven't had any contact with Dr. Kuether, you 21 the raised section; is that right?
22 know, so -- 22 A Correct.
23 BY MR. HITCHCOCK: 23 Q And then Dr. Kuether would have been close to
24 Q Okay. So we'll -- let's take that -- just back 24 you, but on the seating area. Is that what we
25 that up a second. When did you see Dr. Kuether 25 are talking about?
Page 42 Page 43
1 A Yes. 1 THE WITNESS: I cannot sit here today
2 Q And, sorry, is that what you meant when you 2 and tell you that verbatim what was on her
3 said right next to you? 3 signs because, frankly, I tuned it out. And
4 A Yeah. She -- yeah. 4 I -- you know, whatever Dr. Kuether was doing,
5 Q I understand. Okay. And then so based on that 5 she was doing. And so as far as me being able
6 vantage point, was it easy for you to see what 6 to quote what was there, no.
7 was on the sign? 7 BY MR. HITCHCOCK:
8 A Yes. 8 Q I understand. And I'm not -- what I'm asking
9 Q Okay. 9 you -- and I didn't say the word did you quote,
10 A If I would look at it. 10 I'm just asking were you aware of what was on
11 Q And did you look at it? 11 the signs? Did you have a general
12 A I glimpsed every now and then, but most likely 12 understanding?
13 never. 13 MS. MCLEROY: Objection, vague.
14 Q Okay. So based on those glimpses, did you get 14 Go ahead.
15 a sense of what was on those signs? 15 THE WITNESS: The general
16 A Not really. 16 understanding came because I'm assuming that
17 Q Not really, okay. Now, at those board meetings 17 what she testified about was what she had on
18 -- and I guess I want to be clear. When you 18 her signs or whatever. I am not 100 percent
19 say "not really," is it your testimony here 19 sure.
20 that you don't have any understanding of what 20 BY MR. HITCHCOCK:
21 was on Dr. Kuether's signs during those board 21 Q I understand.
22 meetings? 22 A So --
23 MS. MCLEROY: I'm going to object, 23 Q And you never discussed those signs with
24 vague. 24 anybody?
25 Go ahead. 25 A No.

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1 Q Okay. I understand. Now -- 1 curriculum items, it was about, I want to say,
2 A What do you mean? Hold it. Hold it. 2 one time something to do with discipline --
3 Discussed as far as -- I can say that things 3 student discipline, something with -- something
4 had gotten so out of control that -- you know, 4 to do with students. And I want to say it was
5 with -- with signs and protests and things of 5 the -- that restraining piece that we have that
6 that nature, so I can't say that, you know, as 6 we have to report to the state, I think there
7 far as from a safety standpoint -- 7 was a comment about that one time. Those are
8 Q Right. Okay. And I appreciate that. 8 vaguely some of them I remember, but to report
9 A -- you know that. Yeah. 9 them all, I don't know.
10 Q And I will give you the -- we'll -- we are 10 Q Okay. And do you believe the comments that she
11 going to talk about that soon, but if you have 11 was making was generally supportive of your
12 more to say on that subject -- 12 agenda?
13 A No. 13 MS. MCLEROY: I'm going to object,
14 Q -- by all means. 14 vague.
15 A No. 15 THE WITNESS: My agenda was children,
16 Q Okay. So at those board meetings, did 16 and if she was making something that was in
17 Dr. Kuether ever make any public statements? 17 support of students or whatever the situation,
18 A Yes. 18 yeah.
19 Q Okay. And you witnessed those public 19 BY MR. HITCHCOCK:
20 statements? 20 Q Well, so is that yes, she wasn't supportive of
21 A Yes. 21 your agenda or no --
22 Q Okay. Did you -- what was -- what's your 22 A She was supportive of my agenda if it was about
23 awareness of what the thrust of those 23 students. But for me to say everything that
24 statements were? 24 came out of her mouth, I would have to hear it
25 A It was about budgetary items, it was about 25 again to say whether it was student, whether it
Page 46 Page 47
1 was about -- you know, whether it was against 1 what's going on, you'll agree with me that
2 my program or whatever. It wasn't my program, 2 some -- while you were the superintendent, you
3 it was a student program. 3 proposed action to the board. Fair?
4 Q Okay. And at the board meetings, it's 4 MS. MCLEROY: Asked and answered.
5 sometimes the case where the administration is 5 Go ahead.
6 presenting proposals to the board and the board 6 THE WITNESS: Yes.
7 votes. Is that fair? 7 BY MR. HITCHCOCK:
8 A Yes, sometimes. And sometimes it's just for 8 Q Okay. And then you also proposed -- or gave
9 information. 9 the board informal items at those meetings,
10 Q Okay. And was there ever a time -- and, sorry, 10 too; is that true?
11 as superintendent, you were putting forth 11 A Yes.
12 proposals to the board for their vote; true? 12 Q Okay. Now, while you -- is there ever an
13 MS. MCLEROY: Objection, overbroad, 13 opportunity for people to make public comments
14 vague. 14 after the administration proposes action to the
15 Go ahead. 15 board?
16 THE WITNESS: Okay. It is, but 16 A Yes, at some board meetings. At all the
17 there's -- yet you would have to give me the -- 17 committee meetings, but not the full board,
18 the exact item because sometimes it's just for 18 unless the rules were relaxed.
19 information only. 19 Q I understand. Have you ever been at one of
20 BY MR. HITCHCOCK: 20 those meetings in which Dr. Kuether responded
21 Q I understand. 21 to a proposed action by your administration?
22 A And sometimes there is something that we need a 22 A Yes.
23 vote on. 23 Q Okay. Was she opposed to that proposed action
24 Q I understand. But just so we have a basis -- 24 at that time or something else?
25 to make sure that you've got a basis to know 25 MS. MCLEROY: I am going to object,

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1 vague, overbroad. 1 BY MR. HITCHCOCK:
2 THE WITNESS: I would have to -- then 2 Q Okay. And I get that. That's why I'm backing
3 I would have to know the exact topic or 3 up and trying to ask you, because it's my
4 whatever the situation, but I was there. 4 understanding that you are saying you don't
5 BY MR. HITCHCOCK: 5 recall all of the proposals that Dr. Kuether
6 Q Okay. Well, do you think she was opposed to 6 made public comments and response to. Is that
7 your proposals or not? 7 your answer?
8 MS. MCLEROY: Again, object, 8 A I don't -- yes. I don't remember all of that.
9 overbroad, asked and answered. 9 I know she made several.
10 THE WITNESS: I would say at some -- 10 Q Okay. But it's also your answer that she
11 yes, sometimes and no sometimes. 11 opposed some of those proposals. Fair?
12 BY MR. HITCHCOCK: 12 A Yes.
13 Q I understand. Okay. And so on the sometimes 13 Q Okay. And so then we can infer then, and let
14 of the -- or yes, she was opposed sometimes, is 14 me know if I'm wrong, that you don't recall
15 it fair that you just don't remember which 15 which proposals that she opposed; is that true?
16 sometimes we are talking she was opposed. Is 16 MS. MCLEROY: Well, I'm going to
17 that fair? 17 object to "infer" or speculation. He's
18 MS. MCLEROY: Objection, vague, 18 supposed to testify about his personal
19 overbroad, calls for speculation. 19 knowledge, so calls for speculation.
20 Go ahead. 20 Go ahead if you can. Do you need the
21 THE WITNESS: I'm really a little 21 question read back?
22 unclear of where we are going here with this 22 THE WITNESS: Yes.
23 one because I would have to -- you know, for me 23 (Record read.)
24 to just give an answer, a blanket statement is 24 THE WITNESS: That's true.
25 very difficult. 25 BY MR. HITCHCOCK:
Page 50 Page 51
1 Q Okay. Did Dr. Kuether ever testify about 1 that she made testimony.
2 discrimination? 2 Q Okay. I'm going to hand you this document
3 A Yes. 3 here. I'm going to hand a copy to my
4 Q Okay. And did she ever testify about Marla -- 4 colleague. If you can mark that one, please.
5 and I'm going to get the last name wrong, but 5 The clerk -- or the reporter, sir, is going to
6 it's Bronaugh. Did she ever testify about her 6 put a sticker on that document.
7 at all? 7 MS. MCLEROY: Wait. Is that
8 A I can say that I've heard her -- have her name 8 highlighted?
9 in one of her statements, yes. 9 MS. KUETHER: Yeah, that's the one
10 Q Okay. But that was also when Ms. Bronaugh was 10 that's highlighted.
11 up for a position; true? 11 MR. HITCHCOCK: Sorry.
12 A No. I think it was when she was being demoted. 12 (Exhibit No. 1 was marked.)
13 Q Okay. She was trying -- she is now -- she 13 MS. KUETHER: MPS doesn't put dates
14 became the -- sorry, Dr. Marla Bronaugh became 14 on this stuff, but (inaudible) --
15 the remote work director after that meeting; 15 BY MR. HITCHCOCK:
16 right? 16 Q Do you see this document?
17 MS. MCLEROY: I'm going to object, 17 A Yes.
18 vague. Do you have a time frame? I mean, 18 Q Okay. This is the document that you have now
19 we're talking generalities. And which meeting 19 as Exhibit 1. Is that what it says at the
20 are we talking about? 20 bottom there?
21 BY MR. HITCHCOCK: 21 A Yes.
22 Q Do you know what meeting we're talking about? 22 Q Can you identify what this document is?
23 A I can't -- I can't pinpoint the meeting, but I 23 A Yes.
24 do know when -- when Bronaugh was being demoted 24 Q What is it?
25 and reassigned to a position. I want to say 25 A It's a list of recommendations for promotions

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1 or reclassifications. 1 A That's correct.
2 Q I understand. 2 Q Okay. And then I just see there is a date that
3 A It's appointments, promotions, reassignments 3 says base salary will be adjusted effective
4 and reclassifications, salary increases and 4 July 1st, 2023.
5 decreases, and limited-term employment, LTE, 5 A Uh-huh.
6 contracts. 6 Q Is that accurate?
7 Q And it also says this item is initiated by the 7 A That's correct.
8 superintendent at the top? 8 Q Okay. My question to you now is why did you
9 A That's correct. 9 make that recommendation at that time?
10 Q Okay. And that would have been you at that 10 A Because --
11 time? 11 Go ahead.
12 A Yes. Depending on which year it is, I don't 12 MS. MCLEROY: I'm going to object
13 know -- I do recognize these names. 13 that it's irrelevant to this lawsuit, it's
14 Q Okay. And I'm going to direct you to the 14 after all the time frame at issue in this case,
15 second page. 15 and it does -- it isn't related whatsoever.
16 A Yeah. 16 But I will let it go ahead at this point in a
17 Q And to "Recommended Reclassifications." Do you 17 limited fashion before we shut it down.
18 see that there? 18 MR. HITCHCOCK: Oh, okay.
19 A Uh-huh. 19 MS. MCLEROY: Unless you tell me what
20 Q And this is -- do you see the names there? 20 cause of action this is related to.
21 A Yes. 21 BY MR. HITCHCOCK:
22 Q Is this the Marla Bronaugh -- is this the 22 Q It's all -- I mean, it's related to all of the
23 reclassification of remote work that you were 23 causes of action. It's certainly the Title 7.
24 describing as a demotion? Is that what we were 24 Are you prepared to answer the
25 talking about? 25 question, sir?
Page 54 Page 55
1 A I could -- what do you want to know about where 1 a director?
2 I could answer? 2 A A chief and a director, there's the -- there is
3 Q Why did you make this recommendation at this 3 a senior director that's between there. The
4 time? 4 regional superintendent's job is hire as well.
5 A The recommendation -- why I would make this 5 And so it's the chief, the senior director,
6 recommendation? I was demoting Marla at that 6 regional superintendent, and then director.
7 particular time? 7 Q Okay. And do you know how she got promoted
8 Q Yes, sir. 8 at -- to that chief position?
9 A And the process of when you remote -- when you 9 A Yes.
10 demote someone, if they had a position, they go 10 Q Did you recommend that promotion?
11 back to that position level that they had. She 11 A Yes.
12 was chief, and she was being demoted, and she 12 Q Why did you do that?
13 went back to director. And HR takes care of 13 A Because she was the person that was over --
14 all of that. I don't. The other thing is that 14 took care of contracted schools as well as
15 when it looks at the salary, you see there's a 15 communication.
16 bullet by the salary, and if the person is 16 Q Okay. Now, as I understand it, a chief is
17 demoted during that particular year, that 17 directly below the deputy superintendent?
18 person's salary stays the same until the start 18 A That's correct.
19 of the -- until the start of the school year. 19 Q Okay. Did -- while Ms. Bronaugh was chief, did
20 Q Okay. So there's a couple of things. And you 20 she report to the deputy superintendent?
21 are clear that this move is a demotion, for 21 A Did she report?
22 lack of a better word? 22 Q Right.
23 A Yes. 23 A No, she did not.
24 Q Okay. And generally speaking, how many 24 Q Who did she report to?
25 promotional steps are there between a chief and 25 A She was a direct report to me.

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1 Q Okay. When did that happen? 1 A Who?
2 A That happened when she took the job. It was 2 Q Calvin Fermin's.
3 her -- that person was a direct report, and a 3 A I am not sure. I don't -- I don't -- honestly,
4 director of communication was a direct report. 4 I don't know. I don't know what I --
5 So everybody -- the two senior people in 5 MS. MCLEROY: Calls for
6 communication direct reported to me. 6 speculation --
7 Q Now, what about -- or sorry. Just going back 7 THE WITNESS: You know what -- yeah,
8 to the demotion as you described it. Why -- 8 because I don't --
9 what was your reasoning behind that action? 9 MS. MCLEROY: -- what he maybe he
10 Why did you do it? 10 identifies as.
11 A I had received comp -- one complaint that made 11 Can you say how he identifies?
12 a decision for me to make that decision. 12 THE WITNESS: I would -- male, I
13 Q Okay. And I want to be sure that we're talking 13 would think, yeah.
14 about the same document here. Who was the 14 BY MR. HITCHCOCK:
15 person that made the complaint? 15 Q Okay. And do you know what race he identifies
16 MS. MCLEROY: I'm going to, again, 16 as?
17 object as this being overbroad, irrelevant as 17 A No, I don't know.
18 it's far after the relevant time frames in this 18 Q Okay. That never came up at the interview?
19 case for the Title 7 claims, and I don't see 19 A No.
20 how this is related to any of the other causes 20 MS. MCLEROY: Who?
21 of action. 21 BY MR. HITCHCOCK:
22 BY MR. HITCHCOCK: 22 Q How about Sue -- do you know who Sue Salter is?
23 Q Okay. Can you answer the question? 23 MS. KUETHER: Saller.
24 A Yes. Calvin Fermin. 24 THE WITNESS: Saller, yes.
25 Q Okay. What was that person's sex, if you know? 25 BY MR. HITCHCOCK:
Page 58 Page 59
1 Q Who was that? 1 Q Okay. Then I also understand he's filed a
2 A She was the -- I want to say manager of 2 complaint as a separate document. Is that your
3 superintendent initiatives. 3 understanding?
4 Q Okay. Did she ever make a complaint against 4 MS. MCLEROY: I'm going to object,
5 Ms. Bronaugh? 5 vague.
6 A Did she ever make a complaint? 6 THE WITNESS: I'm not 100 percent
7 Q That's right. 7 sure. And when you say "filed a complaint," I
8 A No. 8 don't know what you are referring to when you
9 Q Okay. Now, Mr. Fermin, I understand made 9 talk about complaint. If -- I would have
10 two -- he left the district at some point; is 10 to hear what you are talking about. I don't
11 that true? 11 know what you are referring to.
12 A Yes. 12 BY MR. HITCHCOCK:
13 Q Do you know why he left the district? 13 Q Great. Let's back up a second. When did you
14 A Not sure. No more than what -- what I 14 learn of Mr. Fermin's complaint against
15 received. You know, I didn't -- I didn't even 15 Ms. Bronaugh?
16 receive his resignation papers or anything of 16 A That was before he left he gave it to me, gave
17 that nature. He did not submit those to me. 17 me a copy.
18 Q Okay. So when you're saying "resignation 18 Q Okay. So -- so, sir, I'm going to direct you
19 papers," I understand that he submitted an exit 19 to the second page of this document -- or third
20 interview. Do you understand that to be the 20 page of the document.
21 case? 21 And, again, for the record, this is
22 A I'm not sure. I don't see the exit interviews. 22 Exhibit 2?
23 Q Okay. And you've never looked at Mr. Fermin's 23 MS. MCLEROY: Can we identify for the
24 exit interview. Is that fair? 24 record what Exhibit 2 is? There seems to be a
25 A That's fair. 25 couple cover pages, and then a letter.

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1 MR. HITCHCOCK: I hope that's what 1 work?
2 I'm doing, but we'll find out. 2 MS. KOLBERG: Just so we are clear.
3 MS. MCLEROY: Okay. 3 MS. MCLEROY: Why don't we just
4 BY MR. HITCHCOCK: 4 substitute it as 2.
5 Q Starting on page 3, are you able to identify 5 MR. HITCHCOCK: 2. I'm happy to
6 this document? 6 follow that. 2. 2.
7 A Page 3? 7 (Exhibit No. 2 was marked.)
8 Q I -- 8 BY MR. HITCHCOCK:
9 A Am I able to identify -- 9 Q All right. And now, again --
10 MS. MCLEROY: Oh, there's an 10 MS. MCLEROY: You have it, yes.
11 Exhibit 2 already on the top of that page 11 BY MR. HITCHCOCK:
12 that's not on ours. 12 Q Take your time, sir, but I'm directing you to
13 MR. HITCHCOCK: Okay. 13 page 3. And I'm trying to -- I'm asking you
14 MS. KUETHER: This is part of the 14 here if you can identify this exhibit for us?
15 record -- 15 A I've never seen this. This was not given to
16 MR. HITCHCOCK: Don't -- 16 me.
17 MS. KOLBERG: The copies are 17 Q And you've never subsequently seen this?
18 different. 18 A No.
19 BY MR. HITCHCOCK: 19 Q Okay. Now -- and I want to be clear because I
20 Q I may have given you the wrong copy. Hold on. 20 believe there's two documents here. Mr. Fermin
21 Just to be clear, I'm taking back Exhibit 2. 21 gave what document to you as you understood it
22 We have to remark it. 22 when he left?
23 MS. KOLBERG: Just for the record, 23 A He gave --
24 sir, that will still be Exhibit 2 or -- 24 MS. MCLEROY: Objection, misstates
25 MR. HITCHCOCK: Maybe 2A. Will that 25 his testimony.
Page 62 Page 63
1 Go ahead. 1 Q Okay. But you --
2 THE WITNESS: He gave me a document 2 A I do know he gave me a document of this nature,
3 of a complaint that he had against Bronaugh. 3 but I just -- let me just read through some of
4 BY MR. HITCHCOCK: 4 the bullets here, and I can see if it's the
5 Q I got it. Okay. 5 same stuff that I remember. Yeah. This --
6 A And that's all I received from Calvin. 6 some of the body that I'm reading and what I've
7 Q I got it. Okay. 7 read now rings a bell of what was given to me,
8 MS. MCLEROY: Are you going to 8 but the "Whistleblower Complaint" piece I don't
9 identify now Exhibit 2 what the first two pages 9 know anything about that. He just -- I just
10 are? 10 remember it being a complaint.
11 BY MR. HITCHCOCK: 11 Q Okay. And I want to be clear on that. And the
12 Q I'm going to wait on that one. I am going to 12 document that I'm reading has a date of
13 move on to 3, and then I will go back to 2 as 13 October 15th -- 13th, 2021. Does that sound
14 needed, but I appreciate your assistance. 14 about the same time that you would have
15 This should be 3, excuse me. But do 15 received the potential other document from
16 you want to check it? 16 Mr. Fermin?
17 MS. MCLEROY: Yeah. Okay. 17 A Honestly, I -- that's been so long ago, I can't
18 (Exhibit No. 3 was marked.) 18 tell you. I really don't. My memory -- I
19 BY MR. HITCHCOCK: 19 really don't remember the dates.
20 Q So I'm asking you to look on the first page of 20 Q I understand. But you also -- you will agree
21 Exhibit 3 there. And are you able to identify 21 with me, won't you, that at the top of the
22 this document? 22 document it says that it's to you?
23 A This -- this document -- the document that 23 A Correct.
24 Calvin gave me I don't recall having 24 Q Okay. And you're stating now under oath that
25 "Whistleblower Complaint" on it. 25 you didn't receive this document. Fair?

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1 A I can't -- 1 Q And when you left MPS, did you take anything
2 MS. MCLEROY: I'm going to object, 2 with you?
3 misstates his testimony. Also object that this 3 A No.
4 document is far after the relevant time frame 4 Q Okay. You don't have any documents of any kind
5 here and irrelevant. 5 from MPS?
6 But go ahead and answer. 6 A No.
7 THE WITNESS: Just like I shared with 7 Q Okay. How did you communicate when you were
8 you earlier, he gave me a complaint, but I do 8 working at MPS?
9 not remember it being a "Whistleblower 9 A When I wasn't working?
10 Complaint." It may have very -- just like I 10 Q Was working. Just the superintendent. For the
11 say, it's been a number of years, and after I 11 six years of superintendent, how did you
12 read through here, it rings a bell again in my 12 communicate?
13 head of some of the things that I -- that I 13 MS. MCLEROY: Object, overbroad,
14 remember being there. 14 vague.
15 BY MR. HITCHCOCK: 15 Go ahead.
16 Q Okay. So do you -- do you think that there is 16 THE WITNESS: What do you mean? How
17 a potential -- another documents that's not -- 17 did I --
18 that's different than this document that you 18 BY MR. HITCHCOCK:
19 received? 19 Q We will narrow it down. Did you ever use text
20 A I don't know. 20 messages to communicate MPS business?
21 Q Okay. I understand. Do you -- the document 21 A I would say every now and then. Maybe as
22 that you received, where is that document 22 school closed, canceled or whatever the
23 located now, if you know? 23 situation, but most definitely, no, not
24 A It will be at 52nd -- at the central 24 really --
25 administration building. 25 Q Okay. Where --
Page 66 Page 67
1 A Ever used text. 1 MS. MCLEROY: I'm going to have --
2 Q Excuse me, are you finished? 2 can I have a continuing objection that this is
3 A Yeah. 3 post the complaints and this issue? You
4 Q Okay. Where is the phone that you used to text 4 haven't identified cause of action it's related
5 MPS business? 5 to, and I think irrelevant based on that.
6 A I turned it back in. 6 MR. HITCHCOCK: Totally. No problem
7 Q Okay. And when did you do that? 7 with that.
8 A I -- sometime in June. 8 MS. MCLEROY: Okay.
9 Q Okay. Of 2024? 9 MR. HITCHCOCK: Can I just be clear,
10 A Yeah. 10 though, when you are saying "after the
11 Q Thank you. Okay. Now, if I can just direct 11 complaint," are we talking about after the move
12 your attention back to this. And I -- because 12 to Washington High School? Are we talking
13 I think I -- we will go through some of the 13 about something else?
14 allegations in here. Okay? 14 MS. MCLEROY: For Title 7 complaint
15 A Uh-huh. 15 is the move to Washington High School, which
16 Q And I want to be clear, you told us that you 16 occurred at the end of 2020, early 2021, and
17 demoted Ms. Bronaugh based on a complaint from 17 are the Title 7 claims.
18 Mr. Fermin. Was that accurate? 18 MR. HITCHCOCK: Got it.
19 A That would be corr -- based on the complaint 19 MS. MCLEROY: Those are the only
20 from Mr. Fermin and all other things that were 20 things that you related this to, so go ahead.
21 entailed, yes. 21 MR. HITCHCOCK: Good. I think we are
22 Q Well, okay. So we'll get -- after you got -- 22 on the same page.
23 whatever form that you received the complaint 23 Is there a question that's
24 from Mr. Fermin, what did you do, if anything, 24 outstanding?
25 to investigate his allegations? 25 (Record read.)

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1 THE WITNESS: I worked with HR, and 1 other law firm?
2 had a law firm to -- to do -- to conduct an 2 A No, no. I just can't think of the attorney's
3 interview and do an investigation. 3 name right now.
4 BY MR. HITCHCOCK: 4 Q Okay. Was it the von Briesen law firm?
5 Q And the law firm interviewed Ms. Bronaugh. Is 5 A No.
6 that fair? 6 Q Okay. Was it the city attorney's office?
7 A Right. 7 A No.
8 Q Okay. What law firm is that? 8 Q How did you acquire this attorney?
9 A I am not 100 percent sure the name of it. 9 A I asked the HR chief to see who they had
10 Q Okay. What attorney were you working with? 10 available to -- to investigate it.
11 A Oh, what was the guy's name? I can't even 11 Q Okay. And who was the HR chief at that time?
12 think of his name right now. 12 A I want to say it was Adria Maddaleni.
13 Q James Carrol? 13 Q Okay. She's an attorney; isn't that true?
14 A James Carrol? 14 MS. MCLEROY: I'm going object to the
15 Q That's a question. 15 extent, vague. By education are you asking or
16 A There was two attorneys that I -- I only talked 16 by practice?
17 to. James Carrol was not the name of the 17 BY MR. HITCHCOCK:
18 person that -- it was another guy that I -- I'm 18 Q Sure. That's fair enough.
19 trying -- 19 Is she a J.D. as far as you
20 Q Mr. Grenell? 20 understand?
21 A Who? 21 A On her resume --
22 Q Saveon? 22 MS. MCLEROY: Same objection.
23 A No. 23 THE WITNESS: -- yeah, I think --
24 Q Just to back up then since we're playing guess 24 yeah, she is -- she has a J.D.
25 the law firm. Was it Buelow Vetter or some 25 BY MR. HITCHCOCK:
Page 70 Page 71
1 Q Okay. Has she ever given you legal advice? 1 name? Miriam Hortzwit -- Hor --
2 A No, they are not allowed to. 2 Q Horwitz.
3 Q Same with Mr. Fermin? 3 A Horwitz.
4 A Mr. Fermin has never given me legal advice, no 4 Q And to be clear, the attorney -- the second
5 more than the one case we worked on way back in 5 attorney was Miriam Horwitz?
6 the day. 6 A That's correct.
7 Q Got it. Okay. So what did you learn -- 7 Q Okay. And was she working at Crivello Carlson
8 A The attorney's name was Emery. Emery -- 8 at that time, if you know?
9 Q McBride. 9 A I'm not sure what law firm.
10 A McBride, no. No. 10 Q Fair enough. Okay. So who came -- whose
11 Q Harlan? 11 suggestion was it that the -- Mr. Harlan's law
12 A Emery what? 12 firm wasn't a good one?
13 Q Harlan. 13 A The school board.
14 A Harlan, yeah, that's it. 14 Q Okay. Do you know who -- the entire school
15 Q Okay. Do you know how -- oh, HR. Okay. Did 15 board made that vote?
16 you get a written report from the attorney on 16 A I don't know exactly. I don't even know if
17 the investigation? 17 they voted on it or -- or whatever. And this
18 A No. 18 firm had completed -- almost completed their
19 Q How did you learn of the facts that were 19 investigation, and then Miriam started it all
20 revealed in the investigation? 20 over -- worked with them, and started it from
21 A I had -- I asked those individuals to meet with 21 there.
22 Calvin Fermin, to talk to him. And then at the 22 Q Okay. Do you know if Mr. Harlan's law firm
23 end, there was a concern that that was not good 23 talked to Mr. Fermin?
24 law firm, and so the board asked that we get 24 A I would think yes, because I directed them --
25 another law firm. And we got -- what was her 25 that day that he came and talked to me, I

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1 directed him to Fermin to talk with him. 1 you do that. Whatever the situation might be.
2 Q Okay. Do you know if Mr. Harlan's law firm 2 BY MR. HITCHCOCK:
3 talked to Ms. Bronaugh? 3 Q Okay. And when a single board member called
4 MS. MCLEROY: I'm going to -- 4 you and asked you to do something, have you
5 THE WITNESS: That -- 5 ever done it?
6 MS. MCLEROY: -- object, foundation, 6 MS. MCLEROY: I'm going object,
7 calls for speculation. 7 vague, overbroad. When asked to do something
8 Go ahead and answer if you know. 8 direct -- we are pretty general speaking here.
9 THE WITNESS: That I don't -- I do 9 Do you understand his questions?
10 not know. Or who else, you know, that was 10 THE WITNESS: You are asking me have
11 interviewed. I don't know. 11 I -- have a board member ever asked me to do
12 BY MR. HITCHCOCK: 12 something and I've done it?
13 Q Was there -- other than the fact that -- the 13 BY MR. HITCHCOCK:
14 name of the law firm, was there any basis that 14 Q Right.
15 the board gave you for rejecting that law firm? 15 MS. MCLEROY: And my objection is, is
16 A No. 16 this a board decision or is this a phone call?
17 Q Okay. So how does the board communicate its 17 This is pretty overbroad.
18 wishes to you? 18 BY MR. HITCHCOCK:
19 MS. MCLEROY: I'm going to object, 19 Q Okay. I will ask a different question, but we
20 vague, overbroad. 20 are getting a little bit close to interfering
21 Go ahead. 21 here.
22 THE WITNESS: Well, in a number of 22 Let's --
23 ways. They -- they are in meetings. As far as 23 MS. MCLEROY: I object to that
24 one-on-ones because all of them call and -- you 24 comment.
25 know, and you ask for can you do this or can 25 BY MR. HITCHCOCK:
Page 74 Page 75
1 Q Okay. I understood you to say that different 1 board has -- a single board member has come to
2 board members would call you up from time to 2 you while you were the superintendent and asked
3 time and ask you to do things. Is that -- I'm 3 you to use your superintendent powers?
4 paraphrasing maybe, but is that what your 4 A They have asked me to do it?
5 answer was? 5 Q That's right.
6 A I don't know what you mean "to do things." 6 A Yes, people have asked. But there's been a
7 Like for instance, there may be a tree that's 7 mixed bag. Sometimes it was a no, and
8 on the playground at X, Y school, and I've got 8 sometimes, you know, if it was something that
9 board members that call me and said, "Posley, 9 -- that was -- that supported schools and
10 we've got a tree on the parking lot" -- "a 10 children to get something accomplished, yes.
11 parking lot at X, Y, Z school, and can you make 11 But is it for -- if it's something that's
12 sure that someone remove it?" That kind of 12 personal or anything of that nature, the answer
13 stuff has happened before. 13 is no. It's a process that we go through.
14 Q Okay. And -- but I assume other things as 14 Q Okay. So -- and what was the process, as you
15 well; right? 15 know it?
16 MS. MCLEROY: Objection, calls for 16 A It depended on what -- what you are talking
17 speculation. 17 about. If it's about promotion or anything of
18 THE WITNESS: It depends on what you 18 that nature, there's an interview process and
19 are talking about, though. 19 those kinds of things that it works its
20 BY MR. HITCHCOCK: 20 channels through. It's three levels and it
21 Q Okay. So -- and that's -- that's -- I guess 21 gets itself through.
22 you've given us a specific example of a tree 22 Q How about let's go to Washington High School
23 removal. 23 and look at the administrator's office. How
24 A Yeah. 24 does that happen?
25 Q But has there ever been any other times where a 25 A How does it happen?

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1 MS. MCLEROY: I'm going to object, 1 directly to the secretary, and asked the
2 vague. 2 secretary to show us where Dr. Kuether's office
3 Go ahead. 3 was located, and carried us down, and we got
4 THE WITNESS: I got a call from the 4 the engineer to let us in. And I got a chance
5 director -- at that time he was school board 5 to see this is the office that she was given.
6 president -- Larry Miller. And it was nothing 6 And then afterward, she took us to
7 abnormal for him to give me a call in the 7 another office that she was -- she was given
8 morning of and ask questions about various 8 two different offices. And the office that she
9 things. And he called me one morning, and he 9 was given when I went there was clean, and the
10 said, "Keith, I" -- "I understand" -- "I got a 10 office that -- the second office that she had
11 complaint that you placed Deb Kuether in a room 11 was clean. President Miller apologized
12 that was not an assistant principal's office 12 profusiously to me for calling me about that,
13 and it was dirty." And I was like, "What?" 13 and said, "I'm sorry for calling you to ask you
14 And I was like, "What are you talking about?" 14 about this." As well as he had an opportunity
15 He said that this is -- this is what 15 to talk with the young lady that meet -- that I
16 he had been told. And I said, "I don't know 16 met and greeted Dr. Kuether when she showed up,
17 anything about that." And I said, "You know 17 as well as the support that was surrounded that
18 what? I'm in my car." He said, "Where are 18 was given to her, as well as the principal.
19 you?" And he says that, "I'm over close to the 19 BY MR. HITCHCOCK:
20 district office." And I was headed from home, 20 Q Okay. And why did you -- why did you go to
21 and I said, "Hey, why don't you meet me there." 21 that high school at that time?
22 And so he and I meet at the school. 22 A I went to the high school because he called me
23 He stayed at the school until I got there. He 23 and made the allegations that he had received
24 arrived before me because he was closer. He 24 allegation that -- what had happened, and I
25 waited for me. We walk in together, went 25 wanted to verify myself. So I took it upon
Page 78 Page 79
1 myself when he asked that question, like, hey, 1 sure. I would have to look at the roster. But
2 let's go there, you know, we don't have 2 she had some central office at steering. I
3 anything to hide, and let's go see. And I will 3 remember encountering her for the first time
4 tell you that we found a very presentable 4 there.
5 office in both places, and very cordial people 5 Q Now, at some point you recommended Dr. Holiday
6 that meeted and greeted us as well. 6 for the position of chief academic officer;
7 Q Was Dr. Kuether there? 7 right?
8 A No. 8 A Yes.
9 Q Do you know why not? 9 Q Okay. Why did you do that?
10 A At that particular time, I don't think any 10 A Because of his work and his performance.
11 administrator was there because it was before 11 Q Okay. What about his work and his performance?
12 the start of the school day. And when -- the 12 A His work and performance were at par. And
13 principal even came in after we were there. 13 first of all, I recommended Tonya Adair to the
14 Q And that's Angela Terry? 14 role of chief academic officer. And Tonya
15 A Yes. Yes, sir. 15 Adair took the job with Dr. Driver in Detroit.
16 Q Okay. Do you know Angela Terry? 16 And after Tonya Adair left, Jeremiah Holiday
17 A Do I know who she is? 17 was filling in as the acting senior director of
18 Q Yeah. 18 C&I. And he was pulled up because she wasn't
19 A I know who she is. 19 there and pulled into the cabinet, did some
20 Q Okay. Do you have -- did you have any other 20 amazing work, and that was the reason I
21 connection to Angela Terry? 21 submitted his name for recommendation.
22 A No. She was one of the -- she was one of the 22 Q Okay. And when he was at C&I, he was the
23 principals. And I think she may have worked 23 supervisor of Dr. Kuether; right?
24 in -- one of the early childhood programs 24 A I would think, yes.
25 awhile back, I think. I'm not 100 percent 25 Q Okay. Did you ever learn of any complaints

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1 against Dr. Holiday while you were 1 me -- didn't give them to me. Had to have
2 superintendent? 2 given me the feedback that they had -- first of
3 A The only complaint that I've heard of 3 all, let's back up here. They told me that
4 Dr. Holiday was when I was promoting 4 they had some concerns with individuals on the
5 Dr. Holiday. I carried his name for 5 list. They didn't bring out exactly who those
6 recommendation for a promotion. And there was 6 individuals were. They gave me some examples
7 a closed session, and in that closed session, 7 of two individuals that were on the list.
8 there was -- it was shared with me that you 8 Q Got it.
9 have some names on your promotion list that 9 A And so, therefore, they did not share with me.
10 we -- that has some concerns with, and I said, 10 They had paper in the hand, but they did not
11 "What are the concerns?" 11 share any -- any of those items with me at all.
12 Q And this is a board member who told you this? 12 Q Okay. Based on that paper, what did you think
13 A This is board members in the -- in the -- in 13 they had?
14 the board -- in the executive session, yes. 14 A That -- just basically that he is not the right
15 Q Okay. So this is -- you're learning of these 15 person for the job.
16 concerns, as they put it, from the board? 16 Q Got it. Who else was at that meeting?
17 A From the board. 17 A Who else?
18 Q Okay. And you never heard of any concerns 18 Q Uh-huh.
19 against Dr. Holiday prior to that? 19 A All of the other board members were there. I
20 A No. 20 want to say Matt Chason may have been in there,
21 Q Okay. How about after that? 21 and Dr. Mann, I would think was in there.
22 A After the -- 22 Q How about Calvin Fermin?
23 Q The board members told you that they had all 23 A I don't think so. Calvin Fermin was in one
24 these people that presented them with concerns? 24 closed session with me.
25 A After the board -- after the board had gave 25 Q Okay. Would that have been the 20 -- the
Page 82 Page 83
1 January 21st closed session? 1 name. I pulled -- I said that I was not going
2 A I don't know the exact date, honestly, but I 2 to have anyone embarrassed by taking the names
3 did know he was in one. Various chiefs and 3 off. And if the board wanted to single out
4 deputies went in with me. It's just whoever 4 individuals to take their names off, do it and
5 had an item of whatever the item was about. 5 we can do that, or either we could -- I could
6 And I would think -- and Calvin probably was 6 take the whole list back, and I removed the
7 there because of the -- could have been because 7 whole list.
8 of the finance piece. 8 Q The whole list was Leah Scoptur and Holiday --
9 Q Okay. Well -- 9 A Leah was on that list.
10 A I don't even know if Calvin was working for me 10 Q And who else?
11 then. I'm not 100 percent sure. I don't know 11 A I don't know who all was on that list. Truly,
12 if he was even with the district at the time. 12 I don't. I would have to see the list. I
13 Q Okay. How many closed -- - 13 don't know. I can't say who was on what list
14 A May have been before then. 14 out of all the various promotions and names and
15 Q -- board session meetings did you have where 15 recommendations that I set forward. I don't
16 you discussed Holiday? 16 know. If I would see the list, I could, you
17 A That one. And then there was another one that 17 know --
18 we didn't discuss, Holiday's name came up. 18 Q Okay. Well -- but so other than Holiday, who
19 Q Was this January 21st, 2021 or something? 19 else did the board name by name?
20 A I honestly -- Honestly, Ben, I don't know which 20 A They named by name -- they didn't name by name.
21 date that was. And for me to sit here and tell 21 They called -- there was a board member that
22 you that I know the exact day -- 22 took issue with Leah's name.
23 Q And you recall taking Mr. Holiday's name off 23 Q Okay. Who was that board member?
24 reconsideration; right? 24 A Director Taylor.
25 A I pulled the whole list. I didn't pull his 25 Q Okay. Got it. Now, at some point, Mr. --

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1 Dr. Holiday is up for the full position of 1 Q Okay. Why did you demote him?
2 chief academic officer; right? 2 A I demoted him because the fact that his name
3 A Uh-huh. 3 was not going to go forward.
4 Q And then you pulled his name from 4 Q Okay.
5 consideration? 5 A And -- and it was not fair to the district, not
6 A Uh-huh. 6 fair to the students in the district, and
7 Q And -- sorry. And it's also true that at that 7 needed to move forward. And I shared that with
8 time he was the interim chief academic officer; 8 him.
9 true? 9 Q Okay. But after you knew his name was going to
10 A Interim. Yes, he was interim already. 10 go forward, he continued to perform that work;
11 Q Okay. 11 right?
12 A Yeah. 12 A At that particular time, yes.
13 Q And then what happened after you pulled his 13 Q Okay. For how long did he continue to perform
14 name? 14 that work?
15 A After I pulled his name for consideration, he 15 A I would have to see the time between this time
16 remained as the interim chief. 16 that his name went forward until the time that
17 Q Okay. And then what happened? 17 he was demoted to the -- back to director of --
18 A And it continued to work and continued to move 18 Q Okay. At the time that --
19 forward. 19 A -- school support.
20 Q Okay. And then did he go to some other 20 Q Excuse me. At the time that you demoted him,
21 position after he was no longer interim chief? 21 was there any complaint against Dr. Holiday
22 A Yes, he did. 22 that you knew of?
23 Q What was that position? 23 A I knew of no more complaints of Dr. Holiday as
24 A I demoted him to, I think, director of school 24 far as any of those kinds of things. You know,
25 support. 25 when the pandemic hit, you know, I didn't have
Page 86 Page 87
1 complaints or anybody -- no one -- nobody give 1 he wasn't going to go through; is that true?
2 me -- gave me written complaints or any of 2 A On that particular night?
3 those kinds of things. Whether they talked 3 Q Uh-huh.
4 to -- whether they talked to the deputy 4 A That particular night of the board, it was just
5 superintendent about it, I don't know. 5 the idea, yes. And that is something that I
6 Q Okay. And when you say "deputy 6 never received.
7 superintendent," you mean Calvin Fermin; right? 7 Q Okay. Well, what other infor -- what I'm
8 A Calvin Fermin. Could have been Calvin Fermin, 8 trying to understand is you made the decision
9 could have been Christopher Hauser, and could 9 to demote Mr. Holiday; right?
10 have been Rosana Mateo. 10 A I made the decision later --
11 Q Got it. Did Calvin Fermin ever tell you orally 11 Q Great.
12 about any complaints that anybody had made 12 A -- to de -- demote him, yes.
13 against Jeremiah Holiday? 13 Q Okay. What other information did you have
14 A Not that my memory -- I don't remember. Not 14 other than that single closed session board
15 that my memory serves me correct. 15 meeting?
16 Q Is it possible? 16 A The single closed session, day-to-day
17 MS. MCLEROY: I am going to object, 17 operations at work, I met with him every
18 vague. 18 Tuesday, I met with other individuals in his --
19 Go ahead. 19 that worked with him, you know. And I could
20 THE WITNESS: Anything is possible. 20 see his work, I could see what was going on,
21 BY MR. HITCHCOCK: 21 and those kinds of things.
22 Q Right. Okay. So the only information that you 22 Q And what about his --
23 had to influence your decision on the demotion 23 A He did an excellent job of managing his work,
24 of Calvin -- Jeremiah Holiday was simply the 24 and things did not really -- did not bubble up
25 statements from the board members saying that 25 to me at all.

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1 Q Oh, okay. So you never learned about, for 1 A Sometime after that, yeah. It was shortly
2 example, any failure of Dr. Holiday who 2 after that. I first worked with him through
3 approved a Flash Player program necessary for 3 that process, and then after which that's when
4 curriculum? 4 he was out of the position and back in the
5 A I know nothing about Dr. Holiday and a Flash 5 other position. And then I think the complaint
6 Player. He never brought -- said to me, 6 came.
7 "Posley, I need to approve for a Flash Player." 7 Q I understand. How -- how did you receive the
8 Q Okay. And did you directly supervise 8 complaint?
9 Mr. Holiday? 9 A Just like any other complaint. Any time when
10 A Yes, I did. Well, actually, not directly 10 you do your job, some people are not going to
11 because he was under the deputies. And so the 11 like it, and some people have concerns about
12 deputies directly supervise him, but I did -- 12 it. And every time I have done my job of
13 like I said, on Tuesdays -- I had a one-on-one 13 demoting someone, I always -- that's when I get
14 with him every Tuesday. 14 a complaint.
15 Q Okay. Now, did Dr. Holiday ever file a 15 Q I understand. How did you physically receive
16 complaint against you? 16 the document?
17 A Yes. 17 A I want to say HR made me aware that they had a
18 Q Okay. How did that happen? 18 form that there's some questions that -- that
19 A That happened when I shared with Dr. Holiday 19 -- and I didn't see the form. They had given
20 that he was -- that I was going to be moving in 20 it to Miriam Harlan [sic] and she was going to
21 another direction, and -- and that I was unable 21 do the investigation. And they just shared
22 to get his name -- get his name -- get him 22 with me to -- if I get a call from her to --
23 promoted through the board. 23 that's what it was about and to talk to her
24 Q Okay. And so then he filed a complaint against 24 about it.
25 you? 25 Q Did you talk to her?
Page 90 Page 91
1 A Yes, I did. 1 Q Okay. With DPI?
2 Q And this is the same Miriam Horowitz that 2 A With DPI or anywhere else.
3 investigated the Calvin Fermin accusations 3 Q Okay. I understand.
4 against Marla Bronaugh; right? 4 MS. MCLEROY: Is now a good time for
5 A That's correct. 5 a break?
6 Q Okay. And do you know if the MPS responded to 6 MR. HITCHCOCK: Sure, if you want
7 Mr. Holiday's complaint at any time? 7 one.
8 A I would think yes, because they -- she 8 MS. MCLEROY: Let's take a break.
9 interviewed me. 9 THE VIDEOGRAPHER: Standby. We are
10 Q And based on what you learned about the 10 going off the record. The time is 10:41. This
11 complaint, did you think it was valid? 11 is the end of media unit one.
12 MS. MCLEROY: I'm going to object, 12 (Recess.)
13 vague, irrelevant. 13 THE VIDEOGRAPHER: The time is 10:54.
14 Go ahead and answer. 14 This is beginning of media unit two.
15 THE WITNESS: I don't -- you know, I 15 BY MR. HITCHCOCK:
16 can't speak to what was valid in his mind, you 16 Q You ready to continue?
17 know, but I can just say that I did my job and 17 A I'm ready, yeah.
18 chips fall where they may. 18 MR. HITCHCOCK: Okay. Can you just
19 BY MR. HITCHCOCK: 19 read out the last question, please?
20 Q Okay. One of the allegations that Dr. Holiday 20 (Record read.)
21 made was that you were using his connection 21 BY MR. HITCHCOCK:
22 with his wife for DPI. Do you recall that? 22 Q So other than talking with Miriam Horwitz, did
23 A I don't remember that. It may be there, but I 23 you have any other input in the response to
24 don't remember. But I've never used his wife 24 Dr. Holiday's discrimination complaint?
25 or any other connection. 25 A No. She -- she conducted the whole piece and

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1 interviewed me as one of the people. 1 A Absolutely not.
2 Q Okay. Dr. Holiday stated that he believes that 2 Q Okay. Dr. Holiday also stated that he was
3 Keith Posley's attacks were fueled by 3 repeatedly told by you that Dr. Holiday would
4 discriminatory behavior due to my marital 4 be put through to the board for confirmation in
5 status in retaliation for my wife's position 5 official appointment. Is that a true
6 and the involvement in the administration of 6 statement?
7 current state superintendent, Carolyn Stanford 7 MS. MCLEROY: I'm going to object to
8 Taylor. How did you respond to that? 8 the extent this examination is apparently
9 MS. MCLEROY: I'm going to object, 9 reading a document that has not been put in the
10 misstates his testimony. 10 record, and it's vague as to whether you are
11 Go ahead. 11 asking. I mean, he said he didn't respond, he
12 THE WITNESS: I do not have copies of 12 was interviewed by Miriam Horwitz, so I'm not
13 what I said. Don't remember. 13 sure what you're asking. What he said to
14 BY MR. HITCHCOCK: 14 Miriam Horowitz, are you saying if he remembers
15 Q Okay. Dr. Holiday also said, I was targeted, 15 or what he's saying today?
16 treated unfairly and bullied consistently for 16 BY MR. HITCHCOCK:
17 over two years by Keith Posley simply because I 17 Q What you're saying today. But right now what
18 was a black man and he felt threatened by me. 18 I'm asking you is -- and to be clear, I'm not
19 Do you recall being notified of that complaint? 19 asking you and I hope I didn't or come off that
20 A That was something that she questioned about, 20 I was saying what did you say to Attorney
21 yes. 21 Horwitz. What I'm asking you is, how do you
22 Q Okay. How did you respond to that accusation? 22 respond to these accusations today?
23 A I truly don't remember. 23 MS. MCLEROY: I'm going to add the
24 Q Sitting here today, how do you respond to that 24 objection, it's irrelevant.
25 accusation by Mr. -- Dr. Holiday? 25 Go ahead.
Page 94 Page 95
1 BY MR. HITCHCOCK: 1 A No.
2 Q Okay. So do you deny that you put -- told 2 Q Okay. Dr. Holiday also says that you used him
3 Dr. Holiday that you would put through his 3 as a punching target at meetings; is that true?
4 confirmation -- his appointment to the board 4 MS. MCLEROY: Same objections.
5 for confirmation? 5 THE WITNESS: No.
6 MS. MCLEROY: Same objections. 6 BY MR. HITCHCOCK:
7 Go ahead. 7 Q Okay. He also says that you ignored mistakes
8 THE WITNESS: Yes. I have told 8 by other chiefs; is that true?
9 Dr. Holiday one other time that I was taking 9 MS. MCLEROY: Same objections.
10 his name back. They -- you know, that one time 10 THE WITNESS: No.
11 was the night that -- that I pulled the list. 11 BY MR. HITCHCOCK:
12 I explained to him that particular night that, 12 Q Okay. Dr. Holiday describes his working
13 you know, I was going to continue to monitor 13 conditions as toxic. Do you believe that's a
14 his work, and at some point I would push his 14 true statement?
15 name back through. 15 MS. MCLEROY: Same objections, also
16 BY MR. HITCHCOCK: 16 vague.
17 Q Okay. Dr. Holiday also says that no one on the 17 THE WITNESS: No.
18 senior team receives mistreatment from Keith 18 BY MR. HITCHCOCK:
19 Posley but me. Is that a true statement? 19 Q Okay. Quoting again from Dr. Holiday, he says,
20 MS. MCLEROY: Same objections. 20 this hostility and Keith Posley's behavior
21 Go ahead. 21 toward me has caused me significant and
22 THE WITNESS: No. 22 continued emotional distress and unwarranted
23 BY MR. HITCHCOCK: 23 stress on my family. Is that a true statement?
24 Q Okay. Do you believe that you mistreat anybody 24 MS. MCLEROY: I'm going to object,
25 on the senior team? 25 same objections, also calls for speculation.

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1 Go ahead. 1 THE WITNESS: About what, though? I
2 THE WITNESS: No. 2 don't know what you are talking about.
3 BY MR. HITCHCOCK: 3 BY MR. HITCHCOCK:
4 Q Okay. Are you aware of whether or not 4 Q Okay. Great.
5 Dr. Holiday has sought medical attention in 5 THE VIDEOGRAPHER: Laurie, just to be
6 relation to what he describes as a hostile 6 clear, when you lean forward, you are being
7 working condition? 7 captured, just to let you know.
8 MS. MCLEROY: I'm going object, 8 MS. MCLEROY: Thank you very much.
9 assumes facts not in evidence. 9 MR. HITCHCOCK: I don't think so.
10 Go ahead. 10 Are you sure that's not the same thing?
11 THE WITNESS: No, I'm not aware. 11 I will show you these two. These are
12 BY MR. HITCHCOCK: 12 your copy and we will use that as an exhibit
13 Q Okay. Is it accurate that Dr. Holiday was 13 copy.
14 demoted down two levels? 14 MS. MCLEROY: Here. Turn pages with
15 A Yeah. Can you -- he was chief, the next level 15 me.
16 would have been a senior director, and then -- 16 MS. KOLBERG: Did you skip this page?
17 yeah, then director. Yes. 17 MS. MCLEROY: Is there a page
18 Q Okay. Are you aware of what's sometimes called 18 missing?
19 a Peterson Report? 19 MS. KOLBERG: There's a page missing.
20 A What is that? Explain that. 20 Page 8 from this packet. It's the signature
21 Q Sure. Were you aware of an investigation 21 page.
22 conducted by City Attorney Robin Pederson? 22 MS. MCLEROY: Sorry. It's four pages
23 MS. MCLEROY: I'm going to object, 23 down.
24 vague. 24 MS. KUETHER: Okay. Thank you.
25 Go ahead. 25 MS. KOLBERG: Then Exhibit 4,
Page 98 Page 99
1 Exhibit 5, Exhibit 6. Then there's multiple 1 true?
2 more exhibits. 2 A I am aware that it happened, yes.
3 MS. MCLEROY: Oh, here's a duplicate 3 MS. MCLEROY: Objection, that was
4 set. 4 compound. A complaint or a lawsuit?
5 (Exhibit No. 3 was marked.) 5 BY MR. HITCHCOCK:
6 BY MR. HITCHCOCK: 6 Q Fair enough.
7 Q Now -- 7 You are aware -- I think we were on
8 Sorry, Laurie. Let me know if you 8 lawsuit, but I will be happy to clean that up.
9 are not ready. 9 Are you aware that a lawsuit -- that she sued?
10 Okay. Dr. Posley, do you know who 10 A I was made aware of when it was a lawsuit.
11 Deb Bowling is? 11 Q Okay. How were you made aware of that?
12 A Yes. 12 A Through a closed session.
13 Q How do you know Deb Bowling? 13 Q Okay. And who told you this?
14 A I worked with Deb Bowling as a -- actually, she 14 A The attorney in the closed session.
15 was in one of my university classes and I was 15 Q Got it. Okay. When -- so did you learn about
16 her instructor there. She was a principal. 16 these complaints while they were happening?
17 Q And she filed a complaint against Dr. Holiday, 17 A No.
18 didn't she? 18 Q Okay. Do you know who did learn about these
19 A To my understanding, yes. 19 complaints while they were happening?
20 Q Okay. And she also sued the district based on 20 A No, I do not.
21 Holiday's behavior; right? 21 Q Okay. What steps have you taken to determine
22 A I don't know the details of the case or 22 who knew of these complaints while they were
23 anything of this nature. That's not something 23 happening?
24 that I handled at all. 24 MS. MCLEROY: Objection, calls for
25 Q Okay. But you are aware that it happened; 25 speculation, implies --

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1 Go ahead. 1 something that I've read.
2 THE WITNESS: This is not something 2 Q Okay. Are you unaware of whether or not
3 that a superintendent -- I covered. This is an 3 Dr. Holiday was ordered to undergo coaching at
4 HR piece, and HR handles that from start to 4 any time?
5 finish. 5 A I'm aware that he had to go to coaching, yes.
6 BY MR. HITCHCOCK: 6 Q Okay. Now, is -- the complaint from Deborah
7 Q Okay. So you didn't have anything to do with 7 Bowling, is that before or after you demoted
8 Deb Bowling's transfer. Is that fair to say? 8 Holiday?
9 A Correct. 9 A That was after.
10 Q Okay. Got it. So what as you understand were 10 Q Okay. That's --
11 the allegations against Dr. Holiday made by Deb 11 A It's the date -- the dates are -- yeah, it was
12 Bowling at this time? 12 after. It was -- all of this was after. I
13 A All I remember was the idea of something with 13 just have to check the dates. You know, just
14 an interview and there was a lawsuit. 14 ask me was something before or after, and I
15 Q Okay. And now looking at this document in 15 don't know which date you were talking about.
16 front of me, it's dated January 7th of 2020. 16 I understand you are saying after -- this was
17 Do you see that? 17 after -- yes, I can say it was after
18 A Uh-huh. 18 January 7th of 2020.
19 Q Have you seen this document before? 19 Q That you demoted him?
20 A No. Like I said, I was only -- I was only 20 A It was after that time, yes.
21 shared with in closed session. Nothing in 21 Q Right. Okay. Got it. Okay. And are you ever
22 closed session comes out. They don't give it 22 aware -- have you ever become aware of whether
23 to you. 23 or not the district settled with Ms. Bowling at
24 Q What does that mean? 24 any time?
25 A It's not something that I was given. It is not 25 A I'm not 100 percent sure, but they did talk
Page 102 Page 103
1 about that. 1 testimony.
2 Q Okay. When did they talk about that? 2 Do you -- do you want the question
3 A During the closed session. 3 back?
4 Q Okay. Was that before or after you recommended 4 THE WITNESS: Yeah, read it back
5 the demotion of Dr. Holiday? 5 because I'm --
6 A Demotion? After. 6 (Record read.)
7 Q So -- 7 THE WITNESS: When I made the
8 A This happened before -- 8 decision?
9 Q Right. 9 BY MR. HITCHCOCK:
10 A -- the demotion. 10 Q Uh-huh.
11 Q Both things happened before the demotion? Both 11 A Those -- I would this. I -- those -- these
12 the investigation into Dr. Bowling's 12 things to my understanding that happened
13 accusations on January 7th of 2020 and the 13 before, because his demotion was in, like --
14 settle -- settlement of the lawsuit -- 14 don't even know what year his demotion was in.
15 A As far as -- 15 I just know this was before.
16 Q -- happened before? 16 Q Okay.
17 A Yeah. As far as my memory serves me correctly. 17 MS. MCLEROY: And "this"?
18 Q Okay. And you were aware of both of those 18 THE WITNESS: The January 7th of
19 things when you made the decision to demote 19 2020 -- of '20 is before.
20 Dr. Holiday; correct? 20 BY MR. HITCHCOCK:
21 MS. MCLEROY: I'm going to object, 21 Q Okay. And you -- after this January 7th of
22 vague, irrelevant. 22 2020, you continued to push Dr. Holiday's
23 MS. KOLBERG: And misstates the 23 promotion; right?
24 (inaudible) -- 24 A I never took Dr. Holiday's name back for
25 MS. MCLEROY: Oh, and misstates his 25 promotion after that. After I carried

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1 Dr. Holiday's name that one time, I did not 1 Q Right.
2 carry his name back. 2 A I don't know anything about who else he filed
3 Q I understand. 3 against. The board has not talked to me about
4 A The next time I carried his name back, it was 4 that. I only -- and like I said, the one that
5 to be demoted. 5 he filed against me, they didn't give it to me.
6 Q Okay. Did you have any discussions with any 6 They just said this person is investigating
7 board members about the demotion of 7 it --
8 Dr. Holiday? 8 Q Got it.
9 MS. MCLEROY: Objection, vague. 9 A -- and I answered the questions.
10 Go ahead. 10 Q Okay. Now, were you ever aware of a complaint
11 THE WITNESS: I don't remember. 11 that Dr. Kuether made against Dr. Holiday?
12 BY MR. HITCHCOCK: 12 A No.
13 Q Okay. Did you have any discussions with any 13 Q So to this day, you have no knowledge of
14 board members about Dr. Holiday's complaint? 14 Dr. Kuether ever making any complaints against
15 MS. MCLEROY: Same objection. 15 Dr. Holiday?
16 THE WITNESS: About his -- which 16 A No. I don't get -- I don't get those
17 complaint? This complaint? 17 complaints. I don't know who she made the
18 BY MR. HITCHCOCK: 18 complaint with that she did. I don't get them.
19 Q The -- you understand that Dr. Holiday filed an 19 But there's three places that you can go to for
20 equal rights discrimination complaint alleging 20 complaints. You can go to the administration,
21 that the Board of School Directors 21 you can go to Office of Accountability &
22 discriminated against him; right? 22 Efficiency, and you can go to the board office
23 A I don't know anything about that one. I just 23 with Dr. Mann. And Dr. Mann and Matt Chason do
24 know that -- that he filed something against 24 not share their information with me at all.
25 me. 25 Q Okay. Well, except at closed session board
Page 106 Page 107
1 meetings; right? 1 of Dr. Kuether.
2 A Not even -- 2 Q Oh, okay. Hold on. Okay. Okay. So let's
3 MS. MCLEROY: Objection, vague, calls 3 just go from your recollection. Do you recall
4 for speculation. 4 being in a meeting with various board members
5 THE WITNESS: Not even then. I have 5 and Calvin Fermin and Matt Chason in which Matt
6 not heard Dr. Kuether's name in reference to 6 Chason presented to the board?
7 any filing of any complaint, you know. So 7 A What?
8 that -- that is -- that is not something that 8 Q Whistleblower complaints against Dr. Holiday.
9 they have shared with me. 9 A Matt Chason never -- against Dr. who?
10 BY MR. HITCHCOCK: 10 Q Holiday.
11 Q Okay. January 1st, 2021, were you in a closed 11 A Not that I'm aware of. I do remember
12 session meeting with -- among other people, 12 Dr. Holiday's -- some information on
13 Calvin Fermin and Matt Chason? 13 Dr. Holiday in a closed session, but I don't
14 MS. MCLEROY: January 1st? 14 remember did it have to do with whistleblowers
15 MR. HITCHCOCK: The 1st? 15 because whistleblowers are handled different.
16 MS. MCLEROY: Or sorry -- 16 And a lot of times I'm not even in a closed
17 MR. HITCHCOCK: The 21st. 17 session when Matt meets with the board about
18 MS. MCLEROY: I thought you said 18 whistleblowers because I don't get any of the
19 "1st." 19 names. You know, I will find out if there was
20 BY MR. HITCHCOCK: 20 -- some of my staff was involved doing
21 Q I understood I said 21st. So I will restate 21 something that they maybe assumed they
22 it. 21st. Were you in such a meeting? 22 shouldn't have been doing, but --
23 A I have been in closed sessions with him, but I 23 Q I got it. Do you recall whether or not
24 don't know if it was -- I don't -- we have not 24 Dr. Kuether was ever involuntarily transferred
25 gone into closed session about -- at the time 25 to Washington High School?

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1 A Do I recall her ever -- ever -- restate the 1 particular time.
2 question. 2 Q Okay. So what was the brief conversation that
3 Q Did you recall whether or not Dr. Kuether was 3 you had with Katrice?
4 ever involuntarily transferred to Washington 4 A I shared with Katrice -- the brief conversation
5 High School? 5 I had was after a meeting with -- with
6 MS. MCLEROY: Objection, vague. 6 Dr. Saffold where Dr. Saffold's responsibility
7 Go ahead. 7 was to bring documentation to me about what we
8 THE WITNESS: Yes, she was 8 were doing around instruction for students.
9 transferred. 9 And students were out, not receiving
10 BY MR. HITCHCOCK: 10 instruction, and it was the idea of -- and I've
11 Q How do you know that? 11 been working along with -- well, they was
12 A How do I know that? 12 bringing me reports of where they were in order
13 Q That's right. 13 to be able to get to a point where we have
14 A Because number one, I received a call from 14 computerized instruction at home for all of our
15 President Miller about Dr. Kuether and being 15 children.
16 placed in an office that was not appropriate, 16 This was a time where the children
17 you know, so -- and that's how I know that. 17 were not receiving instructions. We were
18 Q Oh, okay. Do you know anything about how 18 passing out instruction packages, and had to
19 Dr. Kuether got to Washington High School? 19 get them to the houses. And we wanted to make
20 A No more than -- you know, the conversation that 20 sure that they had computers at home that they
21 I -- when I mentioned to Katrice. And I 21 could do work with their teacher and
22 remember having a brief conversation or 22 asynchronous and synchronous work with their
23 whatever with Calvin. 23 teachers and trying to get that done.
24 Q Who is Katrice? 24 I had a conversation with Director
25 A Dr. Cotton was the chief of schools at that 25 Saffold at that particular time. And the
Page 110 Page 111
1 reason I was meeting with Saffold other than 1 teacher-student instruction to moving into a --
2 Dr. Holiday, Dr. Holiday was out. It was 2 you know, a computer-based programming piece to
3 during the COVID time, and apparently I think 3 educate children. And it was a long, drawn out
4 he may have had COVID or ever what. He was 4 process. I first -- you know, it was -- my
5 out, and I had met, like, three times that week 5 first full understanding was through
6 with report -- reporting, and it was shared 6 Dr. Saffold. Dr. Saffold had been working and
7 with me that -- in a dramatic fashion that the 7 couldn't -- could not get things delivered
8 work could not get done because Dr. Kuether 8 because of -- of Dr. Kuether's not allowing it
9 would not allow any work to be done, and not 9 to happen within the meetings.
10 allow people that were in her sphere of 10 Q Okay. So what things could Dr. Saffold not get
11 influence to be asked to do anything. 11 delivered?
12 And for the betterment of children 12 A There was a -- we wanted a platform to be -- a
13 and to move all of our children in this -- that 13 reading platform to -- read and literacy
14 district at that particular time forward, they 14 platform to be put together and to lay -- and
15 needed instruction, did not have instruction. 15 rolled out. And, also, a schedule put together
16 And for the sake of children, I asked that 16 of scheduling teachers with their time within a
17 Dr. Kuether be reassigned because we had to get 17 school. And then looking at other different
18 work done and we had to move forward. 18 incentive activities that they could use after
19 Q Okay. So who did you learn that there was this 19 school with various platforms for staying in
20 alleged issue with Dr. Kuether preventing work 20 touch with their reading and their skills.
21 from getting done? 21 Q How long had the curriculum and instruction
22 A Like I said, that I had learned this 22 department been working on those tasks?
23 information -- it was the idea -- this was a 23 A I don't know at that particular time exactly
24 long, drawn out process because we had to go 24 how long. It wouldn't be fair for me to guess
25 from regular instruction in front of -- 25 and say it was this length of time, but things

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1 was happening -- happening. This was just like 1 would be working. So I would have to go back.
2 drinking from a fire -- fire hydrant because, 2 I'd have to refer to that document.
3 you know, it was a COVID-19 crisis, everything 3 Q Okay. But you'll agree with me that it would
4 had to be redone -- retooled and redone 4 be helpful for you to understand what work was
5 differently. 5 being prevented from getting done to know what
6 Q Oh, okay. 6 work it was; right?
7 A And then there were not people at work, so 7 MS. MCLEROY: I'm going to object,
8 there was a lot of individuals that were -- you 8 vague.
9 know, everybody was home. It was just 9 Go ahead.
10 basically the administrative staff that was 10 THE WITNESS: Yeah. I'm really not
11 there and team of administrators that was 11 clear of the question you want me to answer on
12 working to try to get all of this turnaround 12 this one.
13 and turn back to the schools. 13 BY MR. HITCHCOCK:
14 Q Well, Dr. Kuether was working in the -- in the 14 Q Sure. You're trying -- let me understand this
15 schools, wasn't she? 15 if I have it right. You're saying that you had
16 A Yes. She was working at that particular time. 16 to move Dr. Kuether because there was an
17 She was working at central or wherever she was 17 emergency crisis. Fair?
18 working. 18 A That's correct.
19 Q She was not working remotely; right? 19 Q Okay. And then what I'm trying to understand
20 A I -- I can't tell you whether she was working 20 is what is the crisis?
21 remotely or not because that was a number of 21 A Children receiving quality instruction at home.
22 levels down. And I could not tell you exactly. 22 Q Okay. And what was Dr. Kuether doing
23 I would have to look. There was a statement 23 alledgedly to prevent that work?
24 that Leah Scoptur put out of all individuals of 24 A All of the C&I people that were doing reading
25 where they would be working at, how long they 25 and literacy, they reported to her. And there
Page 114 Page 115
1 was issues with -- she did not want -- she did 1 A The -- getting the platform set up, and all of
2 not want anyone talking -- or directing them to 2 the different reading materials for children.
3 do anything, or talking to them, or asking them 3 Q Okay. And do you know what -- other than, I
4 questions, or giving them assignments of things 4 guess, not -- the allegation that Dr. Kuether
5 to do. 5 didn't allow others to talk to her
6 Q Okay. And how did you know that? 6 subordinates, do you know what else she was
7 A I was informed of that by Dr. Saffold. 7 alledgedly doing to prevent others -- prevent
8 Q Got it. Okay. Okay. Now, I understand that 8 this platform from being set up?
9 you normally don't get involved in these kinds 9 A To my understanding, shutting down meetings.
10 of things. Is that fair? 10 When there was a meeting, you know, to move
11 MS. MCLEROY: Objection, vague. 11 forward with work, she shut it down and got
12 Go ahead. 12 into screaming matches with the leader of the
13 THE WITNESS: It depends on what it 13 meeting. And they would have to shut it down
14 is. If it's a crisis situation, it's all hands 14 and no one could get any work done.
15 on deck. And when children are not receiving 15 Q Okay. So it's her getting -- the allegation
16 quality education, children are not receiving 16 now was she was getting into screaming matches
17 instruction, and the world is on my back to get 17 during meetings. Is that fair?
18 instructions in the hands of children. 18 MS. MCLEROY: Objection, vague,
19 BY MR. HITCHCOCK: 19 harassing the way the allegation is now.
20 Q Great. What specifically did you think -- or, 20 Go ahead and answer.
21 I guess, let me be clear. What specifically 21 THE WITNESS: That was not the only
22 did you think was going to happen -- sorry. 22 thing. There was a number of different things.
23 What specific work did you think was not 23 So that was one of them that we just talked
24 happening that was going to cause a crisis for 24 about.
25 the children? 25 BY MR. HITCHCOCK:

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1 Q Got it. Okay. Now, did you ever identify any 1 his testimony.
2 work rules that Dr. Kuether was alleged to have 2 Go ahead.
3 violated at that time? 3 THE WITNESS: No.
4 A That is not my responsibility. That's the 4 BY MR. HITCHCOCK:
5 Department of Human Resources who is tapped to 5 Q Okay. Now, what did you do to investigate
6 do that type of work. That is not -- and to my 6 these allegations against Dr. Kuether?
7 understanding, that they have worked through 7 A What did I do?
8 the Department of Human Resources with 8 Q That's right.
9 Dr. Kuether on behalf of that. That's when 9 A I -- the thing that I did was the idea that I
10 they did misconduct or whatever the situation 10 ask -- I said to Dr. Saffold, I said that you
11 may be. 11 need to work with the Department of Human
12 Q Well, how do you know that that happened? 12 Resources. And she also shared with me at that
13 A How do I know that was happening -- 13 time that she had done so.
14 Q Yeah. 14 Q Okay. What --
15 A -- was happening? 15 A And I -- what's that? Go ahead.
16 Because when Dr. Saffold -- when 16 Q What did she do? What did she share with you
17 Dr. Saffold had a meltdown about it, basically 17 that she had done?
18 that was one of the things that came out that 18 A She -- she shared with me that she had had
19 she said at that time. 19 misconducts, and that she had -- and I even
20 Q Okay. I got it. So -- and to be fair, your 20 asked about what about mediation, have ya'll
21 knowledge of what's happening, it sounds like 21 tried to sit down to try to get on the same
22 it's only coming from Dr. Saffold's meltdown. 22 page, and that was attempted as well.
23 Is that fair? 23 Q Okay. Now, what misconducts did she identify?
24 A No. 24 A She did not go into details. No misconduct.
25 MS. MCLEROY: Objection, misstates 25 Q Now, you -- how long was Dr. Saffold employed
Page 118 Page 119
1 in that position at that time? 1 candidates that were considered; is that also
2 A Truly, I don't know. I would have to look at 2 true?
3 when she was hired, and then go from there. I 3 A Yes.
4 don't know. I don't remember. 4 Q Okay. Now, I'm going to talk about the first
5 Q Okay. Who made the decision to hire Saffold? 5 round. Okay?
6 A The decision is a mutual decision. There is 6 A Okay.
7 three rounds of interviews. There is a -- this 7 Q And was Dr. Kuether involved in that first
8 was a -- this was a situation where it was a 8 round? Do you know?
9 district level position. So the district 9 A I don't have a clue. I don't know who's on --
10 office do conduct a round of interviews. It 10 I don't get any information from the central
11 might be 15 candidates, they cut it down to 11 office interviews or the second round of
12 three candidates. And then the second round of 12 interviews. Everything to me is -- all I have
13 interviews is with the chief of -- of 13 is the interview and that -- and I don't even
14 academics, and whoever that person has a -- on 14 know how they scored them or anything. So that
15 their interview team, and then they get it down 15 interview comes to me cold turkey, and all I
16 to two people. And then two people come to me 16 operate off is basically their resume.
17 for the final round of interviews. 17 Q Great. So during the first round of resumes
18 Q Okay. What happened with Dr. Saffold? 18 that you got, Dr. Saffold was not on the list;
19 A Dr. Saffold, what do you mean what happened? 19 right?
20 Q Well, was there anybody -- it's my 20 A The first round?
21 understanding that there was several rounds of 21 Q Right.
22 hiring for Dr. Saffold's position; is that 22 A The first round, Dr. Saffold was not one of the
23 true? 23 people because I think, like, two or three
24 A Yes. 24 times they brought names to me --
25 Q Okay. There's also several rounds of 25 Q Right.

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1 A -- for that position. 1 the interview, the answers that was given to
2 Q Right. 2 me. As well as my follow-up calls to
3 A But she was not apart of that first group. 3 individuals within the school district, and,
4 Q Okay. Now, it's my understanding that on that 4 you know -- and so, therefore, I also called
5 first group, there were people who were -- do 5 their superintendent of their school district.
6 you know what the races were of the people in 6 You know, I go with what is there, you know,
7 the first group? 7 any references that they have, and I -- and at
8 A They do not give that as well. I don't know 8 that level, I call the superintendent of the
9 their races or anything of that nature. I've 9 school.
10 seen -- I've seen the people because they were 10 Q Okay. And so did you pick any of those
11 on Skype, you know, but -- or Zoom or whatever. 11 applicants?
12 I don't know what it was at that time, a Skype 12 A Did I pick them? No.
13 or Zoom, whatever the situation. 13 Q Okay. Did you believe that any of those
14 Q Okay. And did you get a general concept as to 14 applicants were black?
15 what their race was when you interviewed them 15 A It would be hard to say. But one -- one I
16 on Zoom? 16 think was a -- it's all speculation because I
17 A I could possibly look at them and, you know -- 17 don't know for sure because was it not only --
18 at this day and time, I don't know people race 18 I believe that one was a white male.
19 or how they identify or whatever the situation 19 MS. MCLEROY: I am just going to say
20 may be. 20 we aren't here to speculate.
21 Q Okay. And then the first time, you rejected 21 THE WITNESS: Yeah. So --
22 the two applicants; right? 22 BY MR. HITCHCOCK:
23 A Yes. 23 Q Okay. How about was Brenda Martinez one of the
24 Q Okay. Why did you do that? 24 other people?
25 A Because of the interview -- after going through 25 MS. KUETHER: Nancy.
Page 122 Page 123
1 BY MR. HITCHCOCK: 1 had another round of interviews or maybe two
2 Q Nancy Martinez. 2 rounds, two other different times, but it
3 A Nancy Martinez. Nancy Martinez was the former 3 was -- it was back and forth on interviews.
4 principal of School of Languages, or was it 4 Q Okay. So the two people from the first round
5 Nancy -- I don't remember the name. I remember 5 that were suggested to you, you rejected them;
6 interviewing Nancy, but I don't know exactly 6 right?
7 which job was it for because she wanted to come 7 A That's correct.
8 back. There was a young lady from Boston that 8 Q Okay. And then you had another round -- you
9 I remember interviewing for the C&I job. And I 9 initiated a subsequent hiring process; is that
10 don't know exactly -- I remember interviewing 10 true?
11 Nancy, but I don't know if I interviewed Nancy 11 A They went through the same process all over
12 for the CAL, the curriculum job, I think. That 12 again. They reopened the position and did the
13 was -- 13 same thing all over again. Individuals
14 Q And was that curriculum job, was that essential 14 applied, and then they brought back names.
15 at that point? 15 Q Whose -- under whose initiative was the
16 A That what? 16 position reopened?
17 Q Was the job essential? 17 A That would have to be Dr. Holiday. You know,
18 A Essential to the work at the district? 18 bottom line if I don't accept either one of the
19 Q For children. 19 candidates.
20 A Absolutely. 20 Q Right.
21 Q Okay. But it didn't get filled at that point; 21 A And I just -- and I'm not the only individual
22 right? 22 that made that decision of which candidate that
23 A No. 23 goes. It's whoever -- like the chief for that
24 Q When did it get filled? 24 area that that person is going to be supervised
25 A It got filled after that. I want to say they 25 by or the deputy, along with myself. I'm not

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1 the only decisionmaker, so -- 1 Dr. Holiday for race-based discrimination?
2 Q So Dr. Holiday was involved in the decision, 2 MS. MCLEROY: I believe this was
3 too? 3 asked and answered.
4 MS. MCLEROY: Were you done with your 4 Go ahead.
5 answer? 5 THE WITNESS: Yes. That is the
6 You've been interrupting him. 6 question you asked about earlier, and I shared
7 THE WITNESS: Yes. 7 with you that I had -- in that closed session,
8 BY MR. HITCHCOCK: 8 I had been informed, I knew the name of the
9 Q Sorry. My question is, Dr. Holiday was 9 person and I knew who the individuals were, but
10 involved in the decision-making; right? 10 I did not know all of the details that you
11 A In the decision-making of whom? 11 shared with me in the document today.
12 Q Of who to hire for this position. 12 BY MR. HITCHCOCK:
13 A Dr. Holiday had influence in the hiring 13 Q I got it. Okay. But you were aware that it
14 process. The final decision with anyone from 14 was a race-based complaint. Is that fair?
15 director and hire is after I take all of the 15 A I was aware that it was something to do with an
16 feedback and we do all of the reference checks 16 interview. I did not have the details.
17 and I take a name forward. But I make sure 17 Q I got it.
18 that the chief and the deputy can live with the 18 A Yeah.
19 decision that is rendered. 19 Q Okay. And what about that interview?
20 Q And when did that happen? 20 A That's all I know. It had something to do with
21 A When -- I would have to see paperwork. I 21 an interview. What he said to somebody or
22 cannot tell you what happened and when and what 22 whatever. That's all I know.
23 day in six years. 23 Q I understand. And what steps did you take to
24 Q I understand. In six years, were you ever 24 find out what was said about the -- what was
25 aware of anybody making any complaints against 25 the gravamen of the accusation?
Page 126 Page 127
1 A There -- when there is HR complaints, I do not 1 sat in on the interview. And he sat in on the
2 dig into HR -- well, when it's HR situations 2 first round of interviews, to my understanding.
3 like whistleblowers or whatever the situation, 3 But like I said, they have influence. The
4 I don't dig into those things. That was not my 4 final decision comes to me.
5 information. That was not information for me 5 Q Right. And after -- my point or question to
6 to know. 6 you and so we are clear for the record, is that
7 Q I understand. 7 my -- you were aware that there was a
8 A They only give me information that I need to 8 race-based allegation against Dr. Holiday with
9 know. That was not information that I needed 9 the hiring process; true?
10 to know. 10 A I would have --
11 Q Okay. And after that point that you didn't -- 11 MS. MCLEROY: I object --
12 you didn't investigate; right? That's fair to 12 THE WITNESS: -- to look at the
13 say you didn't investigate the -- 13 dates.
14 A It was already investigated. They just told me 14 MS. MCLEROY: -- misstates his
15 the outcome of whatever -- not for me to go 15 testimony.
16 back and to -- that's double jeopardy. I can't 16 BY MR. HITCHCOCK:
17 come back and now interview individuals, and 17 Q Okay. Can you answer my question, though?
18 then try to do some type of discipline. So it 18 A I have to look back at the dates. I have to
19 was -- when I heard about it, it was -- it was 19 see the dates and to see when this interview
20 a complaint, it had been investigated and done 20 was. I can't -- I don't -- I truly don't
21 and over, and they were making a decision. 21 remember.
22 Q Okay. And you continued to allow Dr. Holiday 22 Q Okay. I understand with your question on the
23 to have input on hiring decisions; right? 23 dates. My -- or answer on the dates. That's
24 A Did I continue to have him? No. That was the 24 not my question, though. My question is
25 only position that he -- that he sat in on. He 25 confirming, please, to me now that you were

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1 aware that there was a -- at least one 1 A I don't understand.
2 race-based complaint against Dr. Holiday's 2 Q Okay. Well, if the one thing happened before
3 involvement in the hiring process? 3 the other thing and you would have known about
4 MS. MCLEROY: Asked and answered. 4 the complaint before the hiring, and you didn't
5 Go ahead. 5 take any steps to investigate, then it would be
6 THE WITNESS: Yeah. I have -- I have 6 the case, wouldn't it, that you were aware of
7 given you what I have. I would have to look at 7 the allegation and you continued to allow him
8 the times that that took place, and to look at 8 to have input?
9 when this -- I -- honestly, I can't sit here -- 9 MS. MCLEROY: I'm going to -- once
10 I'm not going to sit here and tell you a lie 10 again, a lot of these have been asked and
11 because I truly don't know. 11 answered, it misstates his testimony, it's
12 BY MR. HITCHCOCK: 12 irrelevant, and it's vague.
13 Q Okay. So you will agree with me then that if 13 Go ahead.
14 Deb -- if you were aware of this Deb Bowling 14 THE WITNESS: I don't -- I don't
15 complaint before the hiring of Felicia Saffold, 15 understand what you are asking me.
16 that you would have continued to allow 16 BY MR. HITCHCOCK:
17 Dr. Holiday to have an input into hiring 17 Q Okay. When -- in terms of time, right. You
18 decisions with this race-based allegation 18 will accept with me that when one thing happens
19 against him; true? 19 before another. We can assume that the thing
20 A I don't understand what -- where you're going 20 that happened after the first thing, that the
21 with this. 21 people would have been aware of the things that
22 MS. MCLEROY: Object that it 22 happened first; right?
23 misstates the testimony. He's answered, but -- 23 MS. MCLEROY: Well, objection, calls
24 BY MR. HITCHCOCK: 24 for speculation, overbroad.
25 Q Sorry, what's your answer? 25 Go ahead.
Page 130 Page 131
1 THE WITNESS: But the other side of 1 cabinet. I talked to Marla Bronaugh. When I
2 this, another date that has to come in there is 2 moved her, she was apart of my cabinet. No one
3 when the closed session was held, because the 3 else I talked to. That ain't -- I don't go
4 closed session is when I found out about that 4 down that many levels, because otherwise I'd
5 situation. I don't -- I don't even remember 5 never get anything accomplished. There was a
6 when the closed session was. 6 number of individuals that are at those levels.
7 BY MR. HITCHCOCK: 7 Q What race is Marla Bronaugh? Do you know?
8 Q And I get that you don't remember, but I'm 8 A I don't know. I don't know how -- I don't know
9 saying if the one thing happened before the 9 what she has down as race.
10 other, then you will accept what I'm saying is 10 Q Okay. So what work was Dr. Kuether to do at
11 true; right? 11 Washington High School?
12 A I don't feel comfortable accepting anything 12 A That is -- that is a situation that you will
13 when it comes to that. I'm just -- I would 13 have to talk to individuals that are
14 just have to look at dates. 14 responsible for that. I was not responsible
15 Q Got it. Did you ever talk to Dr. Kuether about 15 for it, the workload or what they need to do,
16 the proposal to move her to Washington High 16 and those kinds of things. That was not my --
17 School? 17 that was not my scope.
18 A Did I ever talk to her? 18 Q Okay. What was your scope?
19 Q That's right. 19 A My scope was the senior cabinet piece of it. I
20 A No. 20 did not troubleshoot out in schools and things
21 Q Why not? 21 of that nature.
22 A If anyone is moved, I haven't talked to them, 22 Q Well, you made the decision for her to be
23 unless that they were apart of my cabinet. And 23 moved; correct?
24 the people that I moved -- I talked to Holiday 24 A That's correct.
25 when I moved him because he was apart of my 25 Q Okay. And when you made that decision, did you

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1 have a job that she was supposed to do? 1 A Therese Freiberg is -- at that particular time,
2 A Did I have -- did she have a job? 2 she was over labor relations -- employee
3 Q Right. 3 relations at that particular time.
4 A No. I just asked that she be reassigned. And 4 Q Okay. Did you consult with her on your
5 that means that she was going to be reassigned 5 decision to move -- involuntarily transfer
6 somewhere. 6 Dr. Kuether?
7 Q Okay. And when you -- you didn't have -- it 7 A No.
8 could have been anywhere. Fair? 8 Q Oh, okay. What was Dr. Kuether's rate of pay
9 A Yes. But it wouldn't have been -- it could 9 to be when she was moved?
10 have been anywhere, but the idea of -- I don't 10 A I have no clue. I do not get into who gets
11 think it was in the central administration in 11 paid what and how much.
12 that -- in that particular area. 12 Q Okay. So it's fair to say that you weren't
13 Q Right. Because people came to you with other 13 aware of any discussions with the city
14 options for Dr. -- for things to do with 14 attorney's office regarding the rate of pay for
15 Dr. Kuether, didn't they? 15 Dr. Kuether?
16 A No. 16 A No.
17 Q Calvin Fermin never presented with you options 17 Q Okay. Did the term "adverse employment action"
18 -- other options where to send Dr. Kuether? 18 ever come up in your discussions about
19 A All I remember -- if my memory serves me 19 Dr. Kuether?
20 correctly, all I remember is sharing with 20 MS. MCLEROY: Object, overbroad,
21 Calvin to work with Dr. Cotton and to do the 21 vague.
22 round of reassignment. Other than that, no. 22 Go ahead.
23 Q Oh, okay. Do you know who Therese Freiberg is? 23 THE WITNESS: No, not that I'm aware
24 A Yes. 24 of.
25 Q Who is Therese Freiberg? 25 BY MR. HITCHCOCK:
Page 134 Page 135
1 Q Okay. So to be clear, you talked to Calvin 1 the other, and, you know, as far as with
2 Fermin? 2 assignments, with work, with the projects that
3 A Yes. 3 they were working on to get the platform up and
4 Q And Katrice Cotton? 4 running. But I gave -- you know, they just
5 A Yes. 5 made notice or commented, but no conversation
6 Q And nobody else? 6 about -- Dr. Kuether's name was never
7 A As far as about? 7 mentioned.
8 Q The removal of -- 8 BY MR. HITCHCOCK:
9 A The -- 9 Q Okay. Did you feel that Dr. Kuether needed to
10 Q -- involuntary -- 10 reset her behavior at any time?
11 A There were only two individuals that I talked 11 A Did I feel that?
12 to at that particular time. 12 Q Yeah.
13 Q Okay. Did you communicate in any other way 13 MS. MCLEROY: I'm going to object,
14 with anybody? 14 vague.
15 A Not that I'm aware of. 15 Go ahead.
16 Q Okay. How about any other time other than that 16 THE WITNESS: I shared with you
17 did you talk to anybody else about the 17 earlier what I felt. I felt that it was a
18 involuntary transfer of Dr. Kuether? 18 crisis situation, and that we had to get
19 MS. MCLEROY: I'm going object, 19 instructions out to children, whether it was
20 overbroad, vague. 20 Dr. Kuether, Dr. Saffold or Dr. Holiday or a
21 THE WITNESS: Those are the only two 21 firm or anyone else. It was nothing pointing
22 individuals. And then, you know, there is the 22 at anyone, but we've got to move forward.
23 whole thing with -- like, for instance, Holiday 23 BY MR. HITCHCOCK:
24 and Dr. Saffold, you know, have asked questions 24 Q Where were you when you made the decision to
25 of me about what should I do with this, that or 25 involuntarily transfer Dr. Kuether?

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1 A Where was I at? 1 vague.
2 Q That's right. 2 THE WITNESS: The answer is yes.
3 MS. MCLEROY: Just going to object, 3 BY MR. HITCHCOCK:
4 vague as to the terminology. 4 Q Okay. Where did you get that belief?
5 Go ahead. 5 A That has been part of the -- it's part of my --
6 THE WITNESS: I would say that I was 6 my responsibilities to make -- to make
7 in the superintendent's suite, and I walked -- 7 recommendations, to assign administrators and
8 I want to say I walked in to Calvin Fermin and 8 things of this nature, and that's what I did.
9 shared with him, and I went to -- I want to say 9 Q Okay. So it's your position that you could
10 I went to Katrice Cotton's office. 10 have reassigned Dr. Kuether to any position at
11 BY MR. HITCHCOCK: 11 any time. Is that fair?
12 Q Okay. And what did you share with Katrice 12 MS. MCLEROY: I'm going to object,
13 Cotton? 13 vague, overbroad.
14 A That -- actually, shared with Katrice Cotton 14 Go ahead.
15 that -- that we need to reassign Dr. Kuether. 15 THE WITNESS: I wouldn't say any.
16 She needs to be reassigned. 16 BY MR. HITCHCOCK:
17 Q And -- okay. Did you tell her why at that 17 Q Okay. What positions couldn't you have --
18 time? 18 A I wouldn't have reassigned her to the business
19 A Did I tell her why? 19 side of the house, as far as -- I wouldn't
20 Q Yeah. 20 reassign her to facilities and maintenance or
21 A I don't remember. 21 any of those kinds of things.
22 Q Okay. Do you feel at this time that you had 22 Q Okay. How about as a classroom teacher?
23 the authority as superintendent to involuntary 23 A No. It would have to go through a demotion
24 transfer administrators? 24 process in order to reassign her to classroom
25 MS. MCLEROY: I'm going to object, 25 teacher.
Page 138 Page 139
1 Q Okay. How about to a position -- did 1 Fermin for information?
2 Dr. Kuether have a license at this point, if 2 MS. MCLEROY: I'm going to object,
3 you are aware? 3 calls for speculation.
4 MS. MCLEROY: Objection, vague. 4 Go ahead.
5 THE WITNESS: That is it not -- just 5 THE WITNESS: I would say yes. I
6 like I said, I shared this with the other two 6 would think so.
7 leaders, that's the work that they perform and, 7 BY MR. HITCHCOCK:
8 you know, do all of the things that they need 8 Q Okay. And would you think that Mr. Fermin
9 to do. But that is something that happens 9 would be responding truthfully to Calvin -- or
10 within the Milwaukee Public Schools all the 10 to Matt Chason?
11 time, special assignment of administrators. 11 MS. MCLEROY: Again, objection, calls
12 BY MR. HITCHCOCK: 12 for speculation.
13 Q So the special assignment of administrators. 13 THE WITNESS: It is true it's
14 And were you also clear with Dr. Cotton and 14 speculation. I don't know what he would say.
15 Mr. Fermin that Dr. Kuether could not -- no 15 I can't speak for him.
16 longer work at the central office? 16 BY MR. HITCHCOCK:
17 A I don't remember. 17 Q Have you ever known him to lie? Mr. Fermin,
18 Q Okay. Now, did Matt Chason -- are you aware 18 that is.
19 whether or not Matt Chason investigated the 19 MS. MCLEROY: Same objection, lacks
20 reassignment of Dr. Kuether? 20 foundation.
21 A I have no clue. 21 THE WITNESS: I can't answer that
22 Q Oh, okay. 22 question. I don't know whether he lied or not.
23 A I don't know who all Matt investigates. 23 BY MR. HITCHCOCK:
24 Q I got it. Do you believe that Matt had the 24 Q Okay. Well, you worked with him for some time;
25 authority to go ask Katrice Cotton and Calvin 25 right?

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1 A Yes. 1 the question that you asked.
2 Q And based on that knowledge and experience, do 2 BY MR. HITCHCOCK:
3 you have any reason to believe that Mr. Fermin 3 Q Yeah. Are you aware of whether or not
4 wouldn't tell the truth? 4 Dr. Saffold -- is it true that Dr. Saffold
5 MS. MCLEROY: I'm going to object, 5 expressed her concerns about Dr. Kuether
6 calls for speculation, lacks foundation. 6 directly to you on a few questions?
7 Go ahead. 7 MS. MCLEROY: Asked and answered.
8 THE WITNESS: It would be 8 Go ahead.
9 speculation. I don't know whether -- what -- 9 THE WITNESS: Yeah, that's true.
10 you know, I don't know what people would do. 10 Yes.
11 BY MR. HITCHCOCK: 11 BY MR. HITCHCOCK:
12 Q Okay. Okay. So I'm going to read to you what 12 Q Okay. Is it also true that you were very
13 I'm purporting is a statement from Mr. Fermin 13 concerned with Dr. Kuether's behavior?
14 to Mr. Chason, and you can tell me if it's 14 MS. MCLEROY: I'm going to object,
15 factually accurate or not. It says, 15 vague.
16 Dr. Saffold expressed a concern directly to 16 Go ahead.
17 Dr. Posley on a few occasions. I assume this 17 THE WITNESS: Yes.
18 is about Dr. Kuether; is that true? 18 BY MR. HITCHCOCK:
19 MS. MCLEROY: Well, once again, we 19 Q Okay. Is it also true that you indicated that
20 don't have the benefit of even knowing what you 20 the work of the department is too important and
21 are reading from, whether there's a foundation 21 it needed to go forward?
22 or accuracy to any of it, so I would object. 22 A Yes. Probably not in those exact words, but
23 To the extent you are not 23 yes.
24 speculating, go ahead and answer. 24 Q Okay. Dr. Posley indicated that a reassignment
25 THE WITNESS: And who -- now, restate 25 would allow Dr. Kuether to reset; is that true?
Page 142 Page 143
1 MS. MCLEROY: I'm going to object, 1 Q Okay. He then asked Dr. Cotton and Calvin
2 once again, lacks foundation, we don't know 2 Fermin to speak to Dr. Kuether about the
3 what you are reading from, calls for 3 reassignment; is that true?
4 speculation. 4 MS. MCLEROY: Same objections.
5 To the extent you recall your 5 Go ahead.
6 language, go ahead. 6 THE WITNESS: Yes.
7 THE WITNESS: I do not recall my 7 BY MR. HITCHCOCK:
8 language at that particular time. 8 Q Okay. Now, when you had asked Dr. Cotton to
9 BY MR. HITCHCOCK: 9 speak with Dr. Kuether -- or Dr. Cotton and --
10 Q Okay. So you don't know whether or not you 10 or scratch that. Let me start that over again.
11 told Calvin Fermin that the reassignment would 11 When you asked Calvin Fermin and
12 allow Dr. Kuether to reset; true? 12 Katrice Cotton to speak to Dr. Kuether, you had
13 MS. MCLEROY: Asked and answered. 13 already made the decision to reassign
14 Go ahead. 14 Dr. Kuether; true?
15 THE WITNESS: Yeah, I don't -- the 15 A That is the correct answer. However, those
16 word "reset" is what I'm -- I don't even know 16 individuals could have came back to me and said
17 if -- I don't remember saying -- the word 17 Posley, no way, I think this has worked out, or
18 "reset" is what's foggy to me. 18 whatever the situation by may be. You know,
19 BY MR. HITCHCOCK: 19 that was still -- that was still an option that
20 Q Okay. Dr. Posley spoke with Dr. Cotton about 20 was out there, but they did not come back to me
21 placement opportunities. Is that a true or 21 with that.
22 false statement? 22 Q Right. You were the boss then; right?
23 A That would be true. 23 A Right.
24 MS. MCLEROY: Same objection. 24 MS. MCLEROY: Objection, vague,
25 BY MR. HITCHCOCK: 25 assumes facts not in evidence as it relates to

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1 these questions. 1 superintendent, did the school district ever
2 Go ahead. 2 promulgate any work rules for administrators?
3 THE WITNESS: I may have been the 3 A What does that mean? Explain that.
4 supervisor at that particular time, but I don't 4 Q Sure. Did they -- why not. A work rule, from
5 have all the answers. 5 my understanding, is a predetermined set of
6 BY MR. HITCHCOCK: 6 behavioral criteria that management propounds
7 Q Got it. 7 to employees, and if they don't adhere to those
8 A And I do listen to others. 8 standards, then management says, hey, you
9 Q Did you direct them to investigate at all? 9 violated this rule or that rule.
10 A No. 10 A Yes, we have work rules.
11 MS. MCLEROY: Objection, vague. 11 Q Okay. Now I understand. And how does an
12 BY MR. HITCHCOCK: 12 administrator know what the work rules are?
13 Q No. Okay. And you chose not to direct Calvin 13 A The work rules are provided to them upon hiring
14 Fermin and Dr. Cotton to investigate the 14 during orientation. Every year they -- they
15 allegations by Dr. Saffold; right? 15 are refreshed, and there's a handbook.
16 A I chose not to. What do you mean? 16 Q I got it. Okay. So what work rules did
17 Q Right. Well, you could have done it, but you 17 Dr. Saffold alert you that Dr. Kuether was
18 didn't do it. 18 violating?
19 A But -- but the thing about it is that Calvin 19 MS. MCLEROY: Objection, vague,
20 Fermin and Dr. -- Calvin Fermin in particular 20 assumes facts not in evidence.
21 had already been in the rooms with Dr. Saffold 21 Go ahead.
22 and knew everything about what was happening 22 THE WITNESS: The bottom line is just
23 with the progress of the work in the curriculum 23 like anything else. That's the Department of
24 department. 24 Human Resources that there are work rule
25 Q Got it. Okay. Now, when you were the 25 violations and those kinds of things.
Page 146 Page 147
1 BY MR. HITCHCOCK: 1 another source of evidence for the allegations
2 Q Well, what rule -- 2 that Dr. Saffold made?
3 A And that was the reason I asked, you know -- 3 MS. MCLEROY: I'm just going to
4 you know, about going to see human resources, 4 object, asked and answered.
5 going down to human resources. 5 THE WITNESS: I shared with you all
6 Q I got it. 6 of the -- all of the -- what took place. And
7 A I asked about mediation. All of those -- those 7 that was rendered on what took place and the
8 are work rule requirements. 8 urgency for students.
9 Q Did you ever learn from HR what work rule 9 BY MR. HITCHCOCK:
10 violations Dr. Kuether was alleged to have 10 Q Okay. Does that mean that you didn't have
11 violated -- committed? 11 another source of evidence or something else?
12 A No. I did not go back to HR and ask what 12 A It doesn't mean that.
13 rules. Just like I said, I did not have 13 Q Okay. Can -- well, then can you kindly answer
14 conversations about the situation with anyone 14 my question?
15 else. 15 A I did.
16 Q Okay. So other than the allegations made by 16 MS. MCLEROY: Asked and answered.
17 Dr. Saffold, did you have any evidence that 17 BY MR. HITCHCOCK:
18 Dr. Kuether was violating any work rules? 18 Q Well, okay. What other sources of evidence did
19 A Did I have any evidence? 19 you have other than Dr. Saffold's allegations?
20 Q For example. 20 MS. MCLEROY: Asked and answered,
21 A For example of was there misconducts, or for 21 objection.
22 example, were there meetings that were shut 22 THE WITNESS: I just shared with you,
23 down? Is that what you are referring to? 23 and I will do it one more time.
24 Q I'm asking you other than Dr. Saffold -- I 24 BY MR. HITCHCOCK:
25 believe it's Dr. Saffold -- did you have 25 Q Please, because maybe I'm not understanding.

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1 A Yeah. The idea of what was shared with me in 1 right?
2 that particular time in that meeting, and that 2 MS. MCLEROY: Objection, vague.
3 was ongoing information about whatever, and 3 THE WITNESS: I was not -- I was not
4 I -- and that was -- that was what I made the 4 at the meeting. And no, I was not there at
5 decision on. 5 all.
6 Q Okay. And the ongoing information about 6 BY MR. HITCHCOCK:
7 whatever, what was that -- the source of that 7 Q Okay. So it's -- so the answer to my question
8 ongoing information? 8 would be no, you -- I didn't personally witness
9 A I just shared with you the shutdown of 9 Dr. Kuether stop the work for the children;
10 meetings, and being outright in meetings people 10 true?
11 could not -- her folks could not work or do 11 MS. MCLEROY: Objection, vague, calls
12 anything or couldn't -- nobody could call them 12 for speculation to what may have happened
13 or talk to them, or any of those kinds of 13 beyond the meeting. It's limited. He's
14 things. These are the kinds of things that I'm 14 already -- he's already testified about all of
15 talking and the misconducts. 15 this.
16 Q And these -- these are the allegations -- 16 Go ahead.
17 A The allegations, yeah. 17 THE WITNESS: Speculation. I don't
18 Q From Saffold? 18 know.
19 A From who? Yeah. 19 BY MR. HITCHCOCK:
20 Q Okay. Right. So, like, you didn't -- you are 20 Q Okay. But we're clear that you're the only
21 not seeing -- and you didn't personally witness 21 person who made the decision?
22 Dr. Kuether interrupt a meeting, for example? 22 MS. MCLEROY: Objection, misstates
23 A I was not at the meeting. 23 his testimony.
24 Q Okay. And you didn't personally witness 24 BY MR. HITCHCOCK:
25 Dr. Kuether stopping the work for the children; 25 Q Well, who else made the decision to forcibly
Page 150 Page 151
1 transfer Dr. Kuether? 1 how long?
2 MS. MCLEROY: That's been asked and 2 MS. MCLEROY: I would like to plow
3 answered. It's in the transcript. 3 through and let's just get this done. We can
4 MR. HITCHCOCK: Can you please stop 4 take breaks for sure.
5 interrupting? 5 MR. HITCHCOCK: Okay. Then let's
6 MS. MCLEROY: I have the ability to 6 take a --
7 put my objection on the record -- 7 MS. MCLEROY: You said you had a
8 MR. HITCHCOCK: Yes. 8 court thing, too.
9 MS. MCLEROY: -- which is what I'm 9 MR. HITCHCOCK: I do. And I'm
10 doing. 10 perfectly fine with that, but I want to
11 MR. HITCHCOCK: I don't know that 11 accommodate people if people want lunch. Can I
12 that's accurate. It seems like you are also 12 ask another person who is working here today if
13 making extraneous comments, which are both 13 they have any preference for eating?
14 influencing witness testimony and distracting 14 MS. MCLEROY: I think he's talking to
15 and interrupting my deposition, and I'm asking 15 Madam Court Reporter.
16 you to stop doing that. 16 THE REPORTER: Yes. A shorter break,
17 MS. MCLEROY: Well, I -- I'm 17 though.
18 objecting to that. You are trying to pinhole 18 MR. HITCHCOCK: Okay. Let's do this
19 excerpts of his testimony without taking it as 19 at this time then. So let's say 15 minutes.
20 a whole. That is my concern, and I will 20 Does that work for everybody --
21 continue to object. I will not influence the 21 MS. MCLEROY: Sure.
22 witness. 22 MR. HITCHCOCK: -- approximately?
23 MR. HITCHCOCK: Okay. I don't know 23 MS. MCLEROY: Is that good for you?
24 what time it is. It is almost noon. Is there 24 THE REPORTER: Yes.
25 any preference for taking a break? And if so, 25 MS. MCLEROY: Okay. Yes.

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1 MR. HITCHCOCK: Thank you. 1 A Yes.
2 THE VIDEOGRAPHER: Standby. We are 2 Q Okay. And did you do any checking to determine
3 going off the record. The time is 11:56. This 3 whether or not Dr. Kuether was on FMLA before
4 is the end of media unit two. 4 you directed her to be forcibly transferred?
5 (Recess.) 5 A No. I shared with you all the things. I
6 THE VIDEOGRAPHER: We are going back 6 didn't --
7 on the record. This is the beginning of 7 Q Okay. Now, at some point after you directed
8 media -- media unit three. The time is 8 Dr. Kuether to be forcibly transferred, you met
9 12:24 p.m. 9 with the school board on that subject; is that
10 BY MR. HITCHCOCK: 10 true?
11 Q Now, Dr. Posley, are you aware of what FMLA is? 11 MS. MCLEROY: I'm going to object,
12 A Yes. 12 vague, terminology.
13 Q Were you aware -- do you believe that while 13 Go ahead.
14 somebody is on FMLA that they can be 14 THE WITNESS: I can't tell you
15 disciplined? 15 exactly when or the date or any of those kinds
16 MS. MCLEROY: I'm going to object, 16 of things.
17 vague, overbroad, calls for a legal conclusion. 17 BY MR. HITCHCOCK:
18 Go ahead. 18 Q But it would have been after?
19 THE WITNESS: I don't know what it -- 19 MS. MCLEROY: Same objection.
20 pending -- you know, you got all kinds of 20 THE WITNESS: I would think so, yes.
21 things that happen when people are out, you 21 BY MR. HITCHCOCK:
22 know, so that may impede some kind of action. 22 Q Okay. And is this the meeting that -- or do
23 BY MR. HITCHCOCK: 23 you recall if Calvin Fermin was at this
24 Q Okay. And have you received any training of 24 meeting?
25 being an administrator? 25 A I cannot recall.
Page 154 Page 155
1 Q Okay. How about Matt Chason? 1 some other thing, do you recall discussing
2 A It's a possibility Matt Chason would have been 2 the -- let's say, Matt Chason's reports on
3 there. 3 whistleblowers at any time?
4 Q Okay. What do you recall happening at this 4 A Like I said --
5 meeting? 5 MS. MCLEROY: I'm going to object,
6 A In regards -- in regards to just having a 6 overbroad.
7 meeting set for Deb Kuether, I don't ever 7 Go ahead.
8 remember having a meeting just set aside -- a 8 THE WITNESS: Matt Chason does not
9 closed session notice or any kind of meeting 9 give me his reports, he does not explain his
10 set aside for Deb Kuether. 10 reports to me, or any of those kinds of things.
11 Q Do you recall discussing Deb Kuether at a 11 BY MR. HITCHCOCK:
12 closed session meeting? 12 Q Right. But, no, he reads them out verbatim,
13 A As my memory -- I don't -- I think that I have 13 doesn't he, from notes that he's got in front
14 -- I don't remember a meeting where the reason 14 of him, doesn't he?
15 we were going into closed session was about Deb 15 MS. MCLEROY: Well, objection --
16 Kuether, no. 16 THE WITNESS: Verbatim?
17 Q Okay. I got that. 17 MS. MCLEROY: -- calls for
18 A But there was things that -- you know, no. 18 speculation, lacks foundation.
19 Q Was there any closed session meetings that you 19 THE WITNESS: About a whistleblower?
20 didn't go to -- 20 BY MR. HITCHCOCK:
21 A Yes. 21 Q It's Matt Chason's practice to read out his
22 Q -- while you were superintendent? 22 statements to the board in closed sessions
23 A Yes, several of them. 23 verbatim from notes that he has in front of
24 Q Okay. So whether or not the meeting was about 24 him; isn't that correct?
25 -- or scheduled or noticed about Deb Kuether or 25 MS. MCLEROY: Objection, calls for

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1 speculation, lacks foundation. 1 this read out to you?
2 Go ahead. 2 MS. MCLEROY: Asked and answered.
3 THE WITNESS: I don't recall Matt 3 THE WITNESS: And I was supposed to
4 delivered all of his reports -- whether he was 4 be in the room when this was read out?
5 reading them, whether he spoke, I don't know. 5 BY MR. HITCHCOCK:
6 BY MR. HITCHCOCK: 6 Q That's what I'm asking you, sir. Did that
7 Q This should be his -- 7 happen or no?
8 I'm sorry, what number are we on? 5. 8 A This was not read to me. I would have known if
9 Okay. 9 somebody read all of this to me. This was not
10 (Exhibit No. 5 was marked.) 10 read to me.
11 BY MR. HITCHCOCK: 11 Q Okay. Do you know whether or not the Office of
12 Q Do you know -- have you seen this document 12 Accountability & Efficiency received multiple
13 before? 13 concerns under whistleblower protections
14 A What is this? No. No. 14 regarding the conduct of Jeremiah Holiday?
15 Q And do you believe that you've ever had 15 MS. MCLEROY: Asked and answered.
16 somebody read out what's on this page to you 16 Go ahead.
17 before? 17 THE WITNESS: Will you restate that
18 A This whole document read to me? 18 question for me, please, because I was just
19 Q Uh-huh. 19 looking at something and I wasn't --
20 A Nobody ever read this whole document to me. 20 BY MR. HITCHCOCK:
21 Q Okay. And I will submit to you that Matt 21 Q Of course. And to be clear, we are focused in
22 Chason produced this document in response to my 22 on the Office of Accountability & Efficiency.
23 request for his notes for the January 21st, 23 Are you aware of whether or not they -- that
24 2021 meeting, closed session meeting. And 24 office had received multiple concerns about
25 you're stating that this -- you've never had 25 Jeremiah Holiday?
Page 158 Page 159
1 A I don't know. I truly don't know what Matt has 1 Dr. Holiday. The things that we just talked
2 received. 2 about earlier.
3 Q Okay. And were you aware of any complaints 3 Q Okay. The anonymous letters?
4 against Dr. Holiday for mismanagement? 4 A Right. Yeah. Which I didn't ever get my hands
5 A Mismanagement of -- mismanagement how? What? 5 on them. They just told me that they had them,
6 Funds? Mismanagement of people? 6 and they had something in their hands. So I
7 Q I would say mismanagement of people. Let's 7 don't -- I did not get those physically.
8 start with that. 8 Q Okay. But you -- you were aware those were
9 A And state the question again. 9 complaints of mismanagement?
10 Q Are you aware of any complaints against 10 A Complaints about -- this was more of complaints
11 Dr. Holiday for mismanagement? 11 about people not liking him.
12 A No more than what the -- the letters that -- 12 Q Okay. Bad management complaints. Is that
13 you know, that we -- that we just talked about, 13 fair?
14 the things that we just talked about. 14 MS. MCLEROY: Well, objection,
15 BY MR. HITCHCOCK: 15 misstates his testimony.
16 Q Okay. So just excluding the letters -- and 16 BY MR. HITCHCOCK:
17 what letters are we talking about? Excluding 17 Q Oh, okay. And this is about people not liking
18 the letters. And, I guess, sorry, for the 18 him?
19 record, excluding the letters, are you 19 A Yes.
20 otherwise aware of any complaints of 20 Q Okay. Did you ever learn of any complaints
21 mismanagement? 21 about harassing and bullying behaviors that
22 A Not that I'm -- not that no one has made to me. 22 created an environment of hostility and
23 Q Okay. And maybe I missed it, but what letters 23 toxicity?
24 are we talking about? 24 A And this is still on?
25 A What you asked me about earlier about 25 Q Mr. Holiday -- Dr. Holiday.

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1 A No. No more than the whole thing with the 1 academic officer.
2 closed session piece that I told you about -- 2 Okay. With that in mind, my question
3 that you told me about and I answered. The two 3 to you, was this the first meeting that you
4 closed sessions. The one with the -- well, the 4 were talking about with regards to getting the
5 one with the letters, they really didn't say 5 notification about concerns for Dr. Holiday?
6 anything off those, but the ones with the -- 6 MS. MCLEROY: I'm going to object,
7 the lawsuit one is where -- the one that I'm 7 lacks foundation to this witness, calls for
8 referring to. 8 speculation, vague.
9 Q Okay. Mr. Chason goes on to say, in the course 9 Go ahead and answer if you can.
10 of our investigation, a number of 10 THE WITNESS: Yeah. I'm not
11 substantiating documents and corroborating 11 100 percent sure here, but that was the only
12 evidence was provided by multiple 12 time that I carried his name forward.
13 whistleblowers who either reached out 13 BY MR. HITCHCOCK:
14 themselves to this office or participated in 14 Q Got it.
15 good faith with the understanding that they, 15 A Now, I don't know if this 19th is the time that
16 too, would be protected by the whistleblower 16 he -- I carried his name for interim, and then
17 policy. I will present these facts in a 17 I carried his name for a full position. So I
18 chronological order, and then conclude by 18 don't know -- have to see which ones we're
19 sharing my perspectives on the evidence 19 talking about here.
20 presented. 20 Q Okay. But are we clear that you were at this
21 He goes on to say, on November 21st 21 November 21st, 2019 meeting?
22 of 2019, the board having retired to executive 22 A If I carried his name for it, I would say yes.
23 session, discussed concerns surrounding the 23 Q Okay. It says, "The Board" -- because, again,
24 administrator's recommended appointment of 24 it's talking about the administration's
25 Dr. Jeremiah Holiday to the position of chief 25 recommendation -- recommended appointment of
Page 162 Page 163
1 Dr. Jeremiah Holiday's position of chief 1 aware that Dr. Holiday was at that time, the
2 academic officer. Is that what you were just 2 subject of an external investigation by the
3 referring to? 3 city attorney's office." Is that true based on
4 MS. MCLEROY: I'm going to object, 4 your understanding?
5 vague, foundation as to this document you are 5 A I don't remember.
6 reading from. 6 MS. MCLEROY: Objection, calls for
7 Go ahead. 7 speculation, lacks foundation to this witness.
8 THE WITNESS: Like I shared, there 8 Go ahead.
9 was two times that his name went forward. One 9 BY MR. HITCHCOCK:
10 for interim chief, and then another time I 10 Q Okay. It was -- he also goes on to say, It was
11 carried his name for full appointment. 11 shared that this -- this internal investigation
12 BY MR. HITCHCOCK: 12 was initiated at the request of the office of
13 Q Okay. I got it. Well, what about regional 13 human resources in responses to concerns raised
14 superintendent, did you have to recommend his 14 in their office surrounding Dr. Holiday. Do
15 promotion to the board for that? 15 you believe that to be a true statement?
16 A He was not regional superintendent. 16 MS. MCLEROY: First of all, I'm going
17 Q Thank you. All right. "It was disclosed to 17 to object, it was misread, and lacks foundation
18 the Board in that" -- 18 to this witness, and calls for speculation.
19 A He -- he worked in the second position in that 19 THE WITNESS: Honestly, I don't know.
20 office. It used to be directives of school -- 20 Just like I say, this -- I'm not privy of this
21 director of school support, and now he's 21 information. This information has never been
22 director of instruction. 22 shared with me. It wasn't shared with me. So
23 Q Okay. "It was discussed to the Board in that 23 whether HR -- on any HR case, they don't come
24 executive session that the OAE had always been" 24 and tell me when there's -- we have a case with
25 -- "had been" -- excuse me, "had been made 25 a staff member or whatever the situation may

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1 be. 1 Dr. Kuether from HR; true?
2 BY MR. HITCHCOCK: 2 A From HR, no.
3 Q Right. Well, okay. So -- but is it the 3 Q Okay. "Subsequent Board action that
4 case -- so it's the case that HR never brings 4 evening resulted in Dr. Holiday remaining in
5 any complaints to you. Is that fair? 5 the position of Interim Chief Academic
6 MS. MCLEROY: Objection, overbroad, 6 Officer." And that's true; right?
7 vague. 7 MS. MCLEROY: Objection, vague as to
8 Go ahead. 8 time to this witness.
9 THE WITNESS: I can't say they will 9 THE WITNESS: Like I say --
10 never bring any. They didn't bring this one. 10 MS. MCLEROY: Go ahead.
11 BY MR. HITCHCOCK: 11 THE WITNESS: I -- if this is the
12 Q Okay. And they didn't bring the Dr. Kuether 12 interim piece, I guess the answer would be yes.
13 complaint either, did they? 13 And, again, I clearly state I've never seen
14 A No. 14 this, don't know where it came from, how it was
15 Q No. Okay. That came specially to you from 15 comprised. So I am going with I shared with
16 Dr. Saffold; right? 16 you that I did take his name on an interim
17 MS. MCLEROY: Objection, misstates 17 basis. When I took his name, there was --
18 the testimony. 18 there was no complaint during the interim time,
19 Go ahead. 19 if my memory serves me correctly. The
20 THE WITNESS: And you are saying that 20 complaints were when I tried to promote him
21 there was not a -- what do you mean? A concern 21 full-time in the position.
22 or complaint? What are you -- I'm confused 22 BY MR. HITCHCOCK:
23 here. 23 Q I got it. And you are telling us that you
24 BY MR. HITCHCOCK: 24 never learned of the conclusion by the city
25 Q You never got any complaints regarding 25 attorney's office that Dr. Holiday made a
Page 166 Page 167
1 race-based hiring decision in violation of the 1 it was never discussed with me.
2 law and district policy. Is that fair? 2 BY MR. HITCHCOCK:
3 MS. MCLEROY: I'm going object, 3 Q Okay. Could this have been the closed session
4 vague, foundation to this witness. 4 discussion that you were referring to in your
5 Go ahead. 5 previous testimony?
6 THE WITNESS: Are we talking about 6 MS. MCLEROY: Objection, calls for
7 Dr. Kuether here or are we talking about -- 7 speculation, lacks foundation.
8 BY MR. HITCHCOCK: 8 THE WITNESS: I don't remember.
9 Q Dr. Holiday. 9 BY MR. HITCHCOCK:
10 A So restate the question again. 10 Q Oh, okay. Did Dr. Holiday ever express concern
11 Q Yes. Are you telling us that you were not 11 to you about this finding that he had made a
12 aware of any conclusion by the city attorney's 12 race-based decision?
13 office that Dr. Holiday made a race-based 13 MS. MCLEROY: Object, hypothetical,
14 hiring decision in violation of the law? 14 improper.
15 A I shared -- 15 Go ahead.
16 MS. MCLEROY: That's vague, 16 THE WITNESS: Okay. The only time
17 objection. 17 that I once -- what happened with this piece
18 THE WITNESS: I shared with you 18 after all of this was done, I had no knowledge
19 earlier when I found that out in a closed 19 of what the -- what the directives of him were
20 session. I did not -- I don't know details 20 to do or any of those kinds of things, right.
21 now. I didn't get the details then. I just 21 And Calvin Fermin came to me one day and says
22 know it was about an interview, something to do 22 that -- that they had worked out something for
23 with an interview, and that was it. And I knew 23 counseling or something in this nature or some
24 it was something to do with the lawsuit. But 24 form that was going to be doing some counseling
25 outside of what the details, I don't have it, 25 with Holiday.

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1 And I questioned what -- what is this 1 Go ahead.
2 all about, and then he said this was one of the 2 THE WITNESS: I don't even know if he
3 requirements that -- that stem out from the 3 was present at the meeting. Which meeting are
4 document. So -- and they got that squared 4 you talking about? The meeting -- the closed
5 away. Who did it, I have no clue. I don't 5 session meeting?
6 know or any of that. 6 BY MR. HITCHCOCK:
7 BY MR. HITCHCOCK: 7 Q No. The meeting in which you -- that you had
8 Q So you didn't give -- you didn't give Calvin 8 Cotton and Fermin tell Dr. Kuether that she was
9 Fermin any instruction on that -- 9 going to be involuntarily transferred.
10 A That was Calvin Fermin's job. I don't -- I 10 A Oh, because he was acting in both places. He
11 didn't stand over him and say go do this, that 11 was helping out in both places at that time.
12 and the other, no, I did not. 12 Q Okay. And you asked him to do that; right?
13 Q Got it. Because Calvin Fermin was on the 13 A Yeah.
14 finance side; right? 14 MS. MCLEROY: Objection.
15 A He was on the finance side, and he worked with 15 THE WITNESS: Yes.
16 Steve -- Chris Hauser on the academic side. 16 BY MR. HITCHCOCK:
17 And there was times where he was pulled into 17 Q Okay. Do you know if Calvin Fermin had any
18 various meetings and various things if someone 18 background in HR?
19 was not there, or there was some help needed, 19 A From what I remember from the resume, yes.
20 or if the person asked for him to be there. 20 Q Okay. Do you recall Matt Chason ever telling
21 Q Is that why he was at the meeting in which 21 you that he had spoken with a wide range of
22 Dr. Kuether was notified of her involuntary 22 employees of the district of different races,
23 transfer? 23 of different sexes, of different jobs and
24 MS. MCLEROY: Object, speculation, 24 levels within the organization, some retired
25 lacks foundation. 25 and some still employed, and I acknowledge that
Page 170 Page 171
1 these witnesses are self-selecting, and that 1 honestly, out of six years, I don't know what
2 they are also Dr. Holiday's critics, and thus 2 happened on which date.
3 are likely to provide negative information 3 BY MR. HITCHCOCK:
4 about him? Do you recall that? 4 Q How about Deb Bowling?
5 MS. MCLEROY: Objection, lacks 5 A Like I said, I was in a closed session that Deb
6 foundation as to this document, calls for 6 Bowling was discussed and --
7 speculation. 7 Q How about the mediation for Deb Bowling?
8 Go ahead and answer. 8 A The mediation? Can't say I remember anything
9 THE WITNESS: I don't remember. 9 about mediation. I do know they -- they had
10 BY MR. HITCHCOCK: 10 some options, they weighed some options. I
11 Q Okay. Do you recall Mr. Chason telling you 11 just don't remember what the options were.
12 that he -- do you have any awareness of whether 12 Q Are you aware of whether or not on
13 or not on July 8th of 2020, the administration 13 September 2nd of 2020 Calvin Fermin discussed
14 with representation from the city attorney's 14 the investigative findings with Dr. Holiday and
15 office attempted to reach a settlement through 15 assigned him to coaching given the concerns
16 mediation to resolve a complaint raised by an 16 raised about Dr. Holiday?
17 employee working under Dr. Holiday? 17 MS. MCLEROY: Objection, lacks
18 MS. MCLEROY: Same objection, bearing 18 foundation, calls for speculation.
19 the foundation of this document and dates with 19 Go ahead and answer.
20 respect to this witness, calls for speculation. 20 THE WITNESS: I wasn't there. And
21 Go ahead. 21 just like I shared with you earlier, I do know
22 THE WITNESS: I can't answer if I 22 that Calvin Fermin and Dr. Holiday worked out
23 don't know the name, you know, or -- because I 23 what they needed to do.
24 would have to hear the name. And then I cannot 24 BY MR. HITCHCOCK:
25 answer on the exact date because I don't -- 25 Q Okay. Why did they need to get that worked

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1 out? 1 wrote about Dr. Holiday at any time?
2 MS. MCLEROY: Objection, calls for 2 MS. MCLEROY: Objection, overbroad,
3 speculation, lacks foundation. 3 vague.
4 Go ahead. 4 THE WITNESS: Based on what? What
5 THE WITNESS: To my understanding, as 5 was it? What -- what are you referring to?
6 far as my memory serves me here, it had to do 6 (Exhibit No. 6 was marked.)
7 with, I want to say, the Deb Bowling situation. 7 BY MR. HITCHCOCK:
8 But I was not present, don't really know. 8 Q No problem. Have you seen this document
9 BY MR. HITCHCOCK: 9 before?
10 Q Okay. But you did discuss it with Mr. Fermin 10 A No.
11 at least once; right? 11 Q Are you aware of this -- what the document is?
12 MS. MCLEROY: Objection, misstates 12 A From what I'm reading here.
13 his testimony. 13 Q Okay. Now, does this look like the kind of
14 Go ahead. 14 document that's created by MPS in the normal
15 THE WITNESS: I shared with you 15 course of business?
16 earlier that -- that after all of this was 16 MS. MCLEROY: I'm going to object,
17 done, I was -- I was told that this is what had 17 foundation.
18 happened. 18 Go ahead.
19 BY MR. HITCHCOCK: 19 THE WITNESS: As far as it's on the
20 Q Okay. Are you aware of whether or not Calvin 20 letterhead, and it's from within the inner
21 Fermin met with any whistleblowers in October 21 office letterhead.
22 of 2020 regarding Jeremiah Holiday? 22 BY MR. HITCHCOCK:
23 A I am not sure. I don't know. He never told 23 Q And it's an initialed by call Calvin Fermin;
24 me. 24 right?
25 Q Okay. Did you actually read what Calvin Fermin 25 MS. MCLEROY: Objection, calls for
Page 174 Page 175
1 speculation. 1 BY MR. HITCHCOCK:
2 Go ahead. 2 Q Can I have your answer, please, sir?
3 THE WITNESS: I see F there. I would 3 A Reread what you read. I don't know what you --
4 just -- I guess. I'm not sure. I don't know. 4 Q The racial discrimination allegation stems from
5 Initials are initiated. You said initiated? 5 a disagreement between you and Ms. Bowling
6 BY MR. HITCHCOCK: 6 regarding which candidates was the most
7 Q I said initials. 7 qualified.
8 A Initials, yeah. 8 MS. MCLEROY: Again, same objection,
9 Q And it also describes race discrim -- 9 document speaks for itself, foundation.
10 discrimination allegations; right? 10 THE WITNESS: That is -- that is what
11 A That's one of the topics I'm reading right 11 is written right here, yes.
12 here, yeah. 12 BY MR. HITCHCOCK:
13 Q Okay. And it -- it reads, the racial 13 Q And you told us that you were aware of an
14 discrimination allegations stem from a 14 allegation against Calvin Fermin for making a
15 disagreement between you and Ms. Bowling; 15 race-based hiring decision in connection with
16 right? 16 Deb Bowling; true?
17 A Uh-huh. 17 MS. MCLEROY: Objection, misstates
18 MS. MCLEROY: Objection, the document 18 all testimony to this case.
19 speaks for itself, speculation as to this 19 THE WITNESS: With Calvin Fermin.
20 witness. 20 MS. MCLEROY: Yeah.
21 BY MR. HITCHCOCK: 21 BY MR. HITCHCOCK:
22 Q Well, does the document say what it says, or is 22 Q Mr. Holiday. You're aware --
23 it something -- does the document say what I 23 MS. MCLEROY: Your question was a
24 just read or something else? 24 raced-based discrimination against Fermin.
25 MS. MCLEROY: Asked and answered. 25 MR. HITCHCOCK: Okay.

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1 THE WITNESS: Right. 1 THE WITNESS: Yeah.
2 MR. HITCHCOCK: Great. I get it. An 2 (Record read.)
3 easy thing to do was just point that out. 3 MS. MCLEROY: Same objection.
4 So -- 4 THE WITNESS: No. It was Holiday
5 MS. MCLEROY: That's what I just did. 5 that you were talking about.
6 BY MR. HITCHCOCK: 6 BY MR. HITCHCOCK:
7 Q Okay. So same question, sir, against 7 Q Okay. Are you aware of any time that
8 Dr. Holiday. 8 Dr. Holiday was directed to go to training by
9 MS. MCLEROY: Can you read back the 9 Chris Hauser?
10 question with Dr. Holiday? 10 A Am I aware of it?
11 (Record read.) 11 Q That's right.
12 MS. MCLEROY: Same objection, vague, 12 A Yes. I don't know who it was by, but I -- I'm
13 calls for speculation. 13 aware he was supposed to go to counseling.
14 THE WITNESS: Yes. 14 Q How did you become aware of that?
15 BY MR. HITCHCOCK: 15 A Like I shared with you, Calvin Fermin.
16 Q Okay. 16 Q Okay. And then did you learn whether or not
17 A No, no -- 17 Dr. Holiday had gone to counseling?
18 MS. MCLEROY: Your answer -- 18 A No. I don't know what the situation -- I knew
19 THE WITNESS: -- no. 19 it was set up. I don't know -- know details
20 MS. MCLEROY: Do you understand the 20 back to me, you know, what happened, how it
21 question? You need to -- 21 went or any of those kinds of things.
22 THE WITNESS: What -- read it back to 22 Q Nobody reported to you anything about the
23 me again. 23 status of Calvin Fermin going to the coaching.
24 MS. MCLEROY: -- understand the 24 Is that fair?
25 question before you answer. 25 MS. MCLEROY: Objection --
Page 178 Page 179
1 BY MR. HITCHCOCK: 1 MS. MCLEROY: Oh, okay. Are these
2 Q Sorry. Holiday going to the coaching. 2 separately being marked?
3 A I know that he was directed to go. I don't 3 MR. HITCHCOCK: No. Let's mark them
4 know who the coaching agency was. I'm not -- 4 as one document.
5 any of those kinds, I have no details of that. 5 (Exhibit No. 7 was marked.)
6 Q Great. Do you know -- I appreciate that. But 6 BY MR. HITCHCOCK:
7 can you focus on the question that I'm asking 7 Q Can you identify this document?
8 you, which is do you know if he went? 8 MS. MCLEROY: Object, lacks
9 A No, I do not know if he went. I know that he 9 foundation.
10 was required to do so. 10 Go ahead.
11 Q Okay. Was that something that you ever 11 MS. MCLEROY: Did you hear his
12 followed up on as a supervisor of Calvin -- or 12 question?
13 Holiday at any time? 13 THE WITNESS: What was the question?
14 A That is -- 14 BY MR. HITCHCOCK:
15 MS. MCLEROY: Objection, vague. 15 Q Can you identify the document?
16 Go ahead. 16 MS. MCLEROY: Same objection, lacks
17 THE WITNESS: That is something that 17 foundation.
18 the deputy superintendent and deputy 18 Go ahead.
19 superintendents would have followed up. 19 THE WITNESS: I can't identify the
20 MR. HITCHCOCK: Okay. It looks like 20 document. I've never seen either of the two.
21 I have only one copy of this. It's fairly 21 BY MR. HITCHCOCK:
22 short. 22 Q Okay. And what does this document appear to
23 MS. MCLEROY: These are two different 23 be?
24 things? 24 A A letter from Therese Freiberg to Calvin Fermin
25 MR. HITCHCOCK: Yes. 25 talking, basically, about that Holiday had

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1 contacted her in regards of something around 1 BY MR. HITCHCOCK:
2 coaching and he had some concerns with it. And 2 Q Great.
3 that he would -- that he would like to state 3 A And what's on the paper is what's there.
4 that he would like to speak to HR and a deputy 4 Q And I understand that. But I'm asking you to
5 superintendent. 5 identify this document for the record here. So
6 Q About what? 6 what is the subject of this document, if you
7 MS. MCLEROY: I'm just going to 7 know?
8 object that the document speaks for itself. 8 MS. MCLEROY: Well, objection,
9 This witness has no foundation. 9 foundation of this -- this witness cannot
10 Go ahead. 10 authenticate this document, lacks foundation,
11 THE WITNESS: About what he's talking 11 speculation as to what it is, the document
12 to Therese Freiberg about. 12 speaks for itself.
13 BY MR. HITCHCOCK: 13 BY MR. HITCHCOCK:
14 Q Right. And it's Calvin Fermin refusing to do 14 Q I understand that. Can you please answer the
15 the coaching; right? 15 question?
16 MS. MCLEROY: Well, again, objection, 16 A All I can see is the subject is "Investigation
17 the document speaks for itself, this witness 17 Outcome Follow Up" is what it's talking about,
18 has no foundation as to its contents. 18 and the -- the request for coaching services.
19 Go ahead. 19 Q And now that you've had time to review that
20 BY MR. HITCHCOCK: 20 document, is your testimony that you never
21 Q Is that accurate? 21 received any of the information that's in that
22 MS. MCLEROY: Same objection. 22 document?
23 THE WITNESS: I can't say that's 23 A I've never received either one. You see I'm
24 accurate. I can just go by what's here on the 24 not on this.
25 paper. 25 Q My question to you wasn't whether you received
Page 182 Page 183
1 the e-mail. My question is whether you 1 with me.
2 received any of the information that's 2 BY MR. HITCHCOCK:
3 contained in that document? 3 Q Got it. And you met once a week with Calvin
4 A Whether I received any of the information? 4 Fermin and Dr. Holiday; right?
5 MS. MCLEROY: Objection, asked and 5 A No. Cal -- I met with Calvin Fermin alone,
6 answered. 6 Dr. Holiday alone. Everybody is one-on-one.
7 Yes, go ahead. 7 It was just by me and the individual.
8 THE WITNESS: I shared with you 8 Q Okay. And nobody ever mentioned that during
9 earlier what I know about the whole situation 9 any of those times?
10 around coaching, all I know, and all I can do 10 MS. MCLEROY: Object, asked and
11 is I can read what's here. 11 answered, getting argumentative.
12 BY MR. HITCHCOCK: 12 Go ahead.
13 Q Okay. And after you -- and it seemed like you 13 THE WITNESS: I shared with you all
14 had a chance to do that. Have you had a chance 14 that I have on that topic.
15 to read what was there? 15 MR. HITCHCOCK: Okay. This is a
16 A Yeah, I skimmed through it. 16 series of a couple letters.
17 Q Okay. And based on that skimming, are you able 17 MS. KOLBERG: Okay. And then is this
18 to tell us whether or not anybody had alerted 18 a different letter at the end? No. That's not
19 you to any of the statements that are in that 19 right because this is 2021.
20 communication? 20 MS. KUETHER: Yeah, check the dates.
21 MS. MCLEROY: Objection, asked and 21 MS. KOLBERG: So this is the same
22 answered. 22 last page as this page. So let's check it on
23 Go ahead. 23 what we've got. So this is page 2. Then
24 THE WITNESS: Again, I shared with 24 page 3.
25 you what I was -- what Calvin Fermin shared 25 MS. MCLEROY: Yeah.

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1 MS. KOLBERG: Okay. Okay. So now I 1 A Uh-huh.
2 don't know what that page is. 2 Q And it also says that, "MPS's failure to meet
3 (Exhibit No. 8 was marked.) 3 these requirements under state and federal
4 BY MR. HITCHCOCK: 4 special education law may result in the
5 Q So I'm showing you now Exhibit 8, which is a 5 withholding of payments." Do you see that
6 series of letters from the Department of Public 6 there?
7 Instruction to you; is that accurate? 7 A Uh-huh.
8 MS. MCLEROY: Take your time to look 8 Q Okay. Did the MPS ever -- did the federal
9 through all of it. 9 government ever withhold funding from MPS that
10 BY MR. HITCHCOCK: 10 you are aware of?
11 Q And so we are clear, the only question so far 11 A The answer here in this situation --
12 is can you identify these documents? 12 Q Sure.
13 A Yes. 13 A -- is no because we set up, like, three
14 Q Okay. And do you believe that you received all 14 different locations that children could
15 of these documents? 15 provide -- be provided with in-service --
16 A I would say yes. Except for the one on the -- 16 in-person services academically if they needed,
17 yeah. Yes. 17 children with special needs.
18 Q Was there an exception or no? 18 Q Okay. Did you move any staff around for this?
19 A I said yes to all of them. I received them. 19 A Did we move any staff around? Yes.
20 Q Okay. Got it. Okay. Now, did you take any 20 Q Okay. And I'll also point you to the second
21 action on these communications from DPI? 21 page of the March 3rd, 2021 letter. That also
22 A Yes. 22 says that, "MPS's failure to meet these
23 Q And I'm just going to point you to the third 23 requirements under state and federal law may
24 page there. And it shows that Dr. Holiday was 24 result in the withholding of payments"; right?
25 copied on this as well as Jennifer Mims Howell? 25 A Correct. Just for the record, no money was
Page 186 Page 187
1 withheld. 1 reports to the Office of School Administration,
2 Q Okay. How about after you were the 2 and Dr. Mann or whomever in that office direct
3 superintendent, was any of that money withheld? 3 their work.
4 MS. MCLEROY: I'm going to object, 4 Q Okay. But you ultimately supervised the Office
5 foundation to this witness, irrelevant. 5 of School Administration while you were the
6 THE WITNESS: After -- after -- some 6 superintendent; true?
7 bug is buzzing around here. 7 A Yes.
8 MS. MCLEROY: Yeah, I see it. 8 Q Okay. Did you ever direct the Office of School
9 THE WITNESS: Go ahead. Ask the 9 Administration to change any of its practices
10 question again. 10 for any of the school board meetings?
11 (Record read.) 11 MS. MCLEROY: I'm going object,
12 THE WITNESS: With special ed 12 vague, overbroad.
13 services? 13 Go ahead.
14 BY MR. HITCHCOCK: 14 THE WITNESS: No. It was an idea of
15 Q Yes, please. 15 board member concern about safety.
16 MS. MCLEROY: Again, objection. 16 BY MR. HITCHCOCK:
17 THE WITNESS: No, we received the 17 Q Okay. Let -- let's talk about that. So were
18 dollars. 18 there any changes made to board policies
19 BY MR. HITCHCOCK: 19 regarding attendance at public meetings?
20 Q Now, let's go back to board meetings. Who is 20 MS. MCLEROY: Object, vague as to
21 in control of the security at board meetings? 21 time, overbroad.
22 A Who is in control of the security at board 22 Go ahead.
23 meetings? Would be -- it's a hybrid. It's a 23 THE WITNESS: As far as over the --
24 bifurcation. It's the clerk, as well as the 24 the span of time that I was there?
25 Office of School Administration. The safety 25 BY MR. HITCHCOCK:

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1 Q Just while you were superintendent. 1 guidelines that you can't have to be seated,
2 A Was nothing made with the policy, or it was 2 you can't be standing up with your sign or
3 just the idea of -- of -- yes, the doors were 3 holding your sign up blocking the view of the
4 locked until the meeting got started, and it 4 person that's sitting directly behind you. So
5 was due to the fact that people were on stage. 5 there were protocol to have people to make sure
6 And we don't know, you know -- the -- the team 6 they lower their signs at certain times so that
7 of individuals didn't know what was going on 7 others behind them could see. And not to be
8 because people were on stage and, you know, 8 standing in front of others so that they could
9 they get there early, and there's no reason to 9 not see what was going on.
10 be on the stage. And so there was some safety 10 BY MR. HITCHCOCK:
11 concerns around that. 11 Q Okay. Anything else?
12 Q Okay. So that's the -- other than people being 12 A That is where -- and, also, the idea of around
13 on the stage, was there any other reasons for 13 the location, like that first row, they made
14 any other changes? Sorry, let me back all of 14 the first row accessible for media, and the
15 those questions up. Other than locking the 15 first -- there may have been the first sets of
16 doors, was there any other changes that you are 16 two rows there. Media was set on both sides of
17 aware of to the policies for security at board 17 that. Safety has always been there, but then
18 meetings? 18 safety were seated on the stage due to
19 MS. MCLEROY: Objection, misstates 19 individuals up on the stage or coming up on the
20 his testimony. 20 stage. So those kinds of things were set into
21 But go ahead. 21 place, yes.
22 THE WITNESS: Well, with policies, 22 Q Okay. How about the number of security
23 that's one thing. But protocol was going on, 23 officers, did that ever increase any time?
24 we need more protocol. As the idea around 24 A There were times when there was additional
25 making sure people can see. They have 25 safeties called in, yeah.
Page 190 Page 191
1 Q How about police, Milwaukee police officers, 1 Schools?
2 were they ever called in? 2 MS. MCLEROY: Objection, overbroad,
3 A And there was a time that the Milwaukee police 3 vague.
4 were called in as well. 4 THE WITNESS: Can't say all because
5 Q Okay. How do you know that? 5 all is -- I don't direct the work of OAE and I
6 A I saw them there. 6 don't supervise them. I don't dir -- direct or
7 Q Okay. How many times? Just once? 7 supervise the work of the Office of Board
8 A I don't know exactly how many times the police 8 Governance.
9 was there. 9 BY MR. HITCHCOCK:
10 Q Okay. Do you know who called the police? 10 Q Got it. Okay. So --
11 A I don't know if it was Dr. Mann or was it the 11 A Just the administration.
12 safety director. I'm not 100 percent sure. 12 Q So other than Mann and Chason in their
13 Because the board meetings don't belong to me, 13 respective offices, you supervise every other
14 so I'm not -- I'm just -- my staff worked the 14 employee. Is that fair?
15 board meetings, but the board meetings belongs 15 A It's a quasi piece with the division of
16 to the board clerk. 16 recreation as well, because the city ran that.
17 Q I understand. The -- although, you are the 17 They got people that I don't supervise there.
18 supervisor of the security director; true? 18 Q Okay. So are you testifying that you
19 A Yes. Well, I am not. I'm not the direct -- I 19 weren't -- excuse me?
20 wasn't the direct supervisor. The direct 20 A Did not supervise. It's past tense.
21 supervisor was -- the direct supervisor was 21 Q Pardon me. Did you -- were you aware of any of
22 Cotton, I think, Dr. Cotton. 22 these changes to the security practices before
23 Q Okay. While you were the superintendent, did 23 they went into effect?
24 you supervise whether directly or indirectly 24 A Was I aware?
25 all of the employees of Milwaukee Public 25 Q That's right.

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1 A Yes, I was made aware. 1 Q Okay. Who did that?
2 Q Okay. Were you ever consulted on any of these 2 A A number of individuals that was there that did
3 security practices before they went into 3 that. Or if you are asking me did Deb Kuether
4 effect? 4 do it? Yes.
5 A I wouldn't say "consulted." I would say that 5 Q Okay. And many of the board meetings at which
6 OA -- the office -- the Board Governance 6 Dr. Kuether was in, there were no more than
7 Office, at that particular time, Dr. Mann set 7 five or six other people in attendance; isn't
8 all that, and she informed us of what was going 8 that true?
9 to take place and those kinds of things. 9 MS. MCLEROY: I'm going to object,
10 Q Now I got it. Okay. And did you ever object 10 vague, calls for a hypothetical.
11 to any of the policies that she put into place? 11 THE WITNESS: I can't totally say
12 A Did I object? 12 every single meeting was packed or whatever.
13 Q Uh-huh. 13 There were times, yes, that I saw Dr. Kuether
14 A She didn't ask me whether I agreed or disagreed 14 and a few others, yes.
15 with what they were -- how they was going to go 15 BY MR. HITCHCOCK:
16 forward with doing it. 16 Q Okay. And can you identify what times you saw
17 Q Whether or not she asked you, did you object 17 her blocking anybody with a sign?
18 to any of the -- and I want to be fair to you 18 A I can't identify all of the times that -- you
19 -- practices that were in place before they 19 know, every time that I saw Dr. Kuether with a
20 were put into place? 20 sign or blocking or whatever the situation, no.
21 A No. 21 Q Okay. Did you ever see a security guard
22 Q Okay. Based on your experience at the public 22 interacting with Dr. Kuether while you were at
23 meetings, did you ever witness anybody blocking 23 the public board meetings?
24 another person's view with their sign? 24 A I truly don't remember. I've seen her talking
25 A Yes. 25 in the direction the night of the camera
Page 194 Page 195
1 episode. 1 BY MR. HITCHCOCK:
2 Q What is the camera episode? 2 Q Okay. So you didn't observe it happen. Is
3 A When this gentleman here was on the floor. And 3 that fair?
4 I -- you know, with that particular piece, I 4 A Right. All I know is I heard screaming, and I
5 witnessed those kinds of things. But other 5 looked over and he was down.
6 than that -- 6 Q Okay. And as superintendent, did you take any
7 Q What did you witness then? 7 steps to investigate what happened there?
8 MS. MCLEROY: Well, for the record, 8 (Video interruption.)
9 when you said "this gentleman," you are 9 MS. MCLEROY: Excuse me.
10 pointing to the videographer here, Mike 10 MS. KUETHER: I'm sorry.
11 Deguelle? 11 MR. HITCHCOCK: Okay. Can you repeat
12 THE WITNESS: Yeah. 12 the question?
13 MS. MCLEROY: Okay. Go ahead. 13 (Record read.)
14 BY MR. HITCHCOCK: 14 MS. MCLEROY: Objection, calls for
15 Q What did you witness? 15 speculation, implies that he had to do.
16 A I just witnessed that somebody yelled out "he's 16 Go ahead.
17 down" or something of this nature, and I looked 17 THE WITNESS: It was not my
18 and he was on the -- he was lying on the floor. 18 responsibility, it was not my meeting. The
19 Q Okay. Was there an allegation of who had put 19 Milwaukee Police Department, I think, was there
20 him on the floor? 20 and those kinds of things. I know there was
21 MS. MCLEROY: I'm going to object, 21 some yelling back and forth about some safety
22 vague. 22 or something was involved, or whatever the
23 THE WITNESS: I have no clue of who 23 situation. In those situations, I do not
24 put him on the floor, or how he got there, if 24 investigate every single allegation that
25 he put himself. I don't know. 25 happens in the Milwaukee Public Schools that --

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1 they have people to do that, the safety 1 Q When you said "they said," who are you talking
2 director. I would have to check to see what 2 about?
3 happened there. But I have no information on 3 A They -- they drafted the information and sent
4 that. 4 it over to us.
5 BY MR. HITCHCOCK: 5 Q Who is "they"?
6 Q Okay. And you didn't take any steps to learn 6 A Dr. Mann. Dr. Mann's office drafted the
7 any information either; right? 7 information and sent it over.
8 A No. I did not go over to find out what was the 8 Q And why do you believe Dr. Mann had input from
9 end result of that. That is -- that was under 9 any school board members?
10 board governance, and that's board governance 10 A Because President Peterson's name was on it.
11 domain, and they have cameras there. 11 Q And what do you mean when you say "it"? Is
12 Q Okay. Is it your understanding that Jackie 12 this a letter? What kind of communication is
13 Mann was the sole person responsible for 13 this?
14 changing the practices regarding the security 14 A I remember a statement that this is the new
15 at the board meetings? 15 protocol of what will happen.
16 MS. MCLEROY: Objection, lacks 16 Q Okay. And how did you receive that?
17 foundation. 17 A I just remember reading it. I don't know if it
18 Go ahead. 18 was something walked over and delivered by
19 THE WITNESS: I don't know. 19 them, I don't know if they e-mailed it. I
20 Jackie -- Dr. Mann worked with board members, 20 don't know. I just -- it was in my folder of
21 to my understanding with that, because they are 21 things to look at and that's what I got in my
22 the ones that drafted of what it's going to be. 22 folder.
23 And they said to the administration, this is 23 Q Okay. From Bob Peterson. The instructions
24 what we are going to be doing. 24 were from him or were they from Mann?
25 BY MR. HITCHCOCK: 25 A I can't remember who they were from, but I know
Page 198 Page 199
1 both were -- both prepared it, I guess. 1 MS. MCLEROY: A pastor?
2 Q Okay. Did you ever witness a security officer 2 MR. HITCHCOCK: Yes.
3 advancing on Dr. Kuether, for lack of a better 3 MS. MCLEROY: Like at a church?
4 word? 4 MR. HITCHCOCK: That's right.
5 MS. MCLEROY: Objection, vague. 5 MS. MCLEROY: Okay. Objection,
6 THE WITNESS: What do you mean by 6 highly irrelevant.
7 "advancing"? 7 You can answer.
8 BY MR. HITCHCOCK: 8 THE WITNESS: Yes, I have a pastor.
9 Q Well, threatening her with his body. 9 BY MR. HITCHCOCK:
10 MS. MCLEROY: Objection -- 10 Q Okay. And did he -- I understand there were
11 THE WITNESS: I -- 11 some public board meetings surrounding the
12 MS. MCLEROY: -- vague. 12 possibility of you exiting the district, for
13 THE WITNESS: Like I said, I was in a 13 lack of a better word?
14 board meeting, and I don't know what was -- 14 MS. MCLEROY: Object -- okay.
15 what all was going on in the audience or the 15 BY MR. HITCHCOCK:
16 auditorium. 16 Q Do you believe that your pastor was at any of
17 BY MR. HITCHCOCK: 17 those board meetings?
18 Q I understand. Why did you leave the -- your 18 MS. MCLEROY: I'm going to object as
19 employment at Milwaukee Public Schools? 19 irrelevant, not reasonably calculated to lead
20 A It had nothing to do with the -- Dr. Kuether or 20 to anything discoverable in this case
21 this matter at all. 21 whatsoever.
22 Q Oh, okay. And do you have a pastor? 22 Answer if you wish.
23 MS. MCLEROY: Excuse me? 23 THE WITNESS: Do I need to -- I won't
24 MR. HITCHCOCK: I asked him if he had 24 answer it.
25 a pastor. 25 BY MR. HITCHCOCK:

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1 Q You are refusing to answer that question? 1 MS. MCLEROY: Objection, harassment.
2 A Yes, I have a pastor. I shared that with you. 2 BY MR. HITCHCOCK:
3 Q I understand that. Did he speak on your behalf 3 Q I will withdraw the question.
4 at any board meetings? 4 Okay. Now, are you aware of whether
5 MS. MCLEROY: Same objection. 5 or not Dr. Kuether attempted to serve
6 THE WITNESS: My pastor spoke at a 6 Dr. Jeremiah Holiday at any time?
7 board meeting, yes, he did. 7 A Am I aware?
8 BY MR. HITCHCOCK: 8 Q That's right.
9 Q Okay. And did he at that board meeting raise 9 MS. MCLEROY: Objection, vague.
10 the issue of your being forced out because of 10 Serve with process?
11 white women? 11 BY MR. HITCHCOCK:
12 A I have -- 12 Q That's right.
13 MS. MCLEROY: Object. 13 A I am aware. Yes, I've -- I've -- I was made
14 THE WITNESS: I have no clue what his 14 aware.
15 statements were. 15 Q Okay. And do you know what case that was for?
16 BY MR. HITCHCOCK: 16 A What case?
17 Q Okay. But you were at the board meeting? 17 Q Yeah.
18 A Yes. 18 A I have no clue.
19 Q And you were aware that he spoke at one? 19 Q Oh, okay. Do you know who Jose Garcia Joven
20 A Yes. 20 is?
21 Q But you have no clue -- 21 A I've met him before, yes.
22 A And I did not hear anything he said about white 22 Q Okay. And are you aware of whether or not he
23 women at all. 23 had ever filed any complaints against MPS?
24 Q And you don't know him to be -- to lie about 24 A I -- was I aware?
25 anything, do you? 25 Q That's right.
Page 202 Page 203
1 A I do know that he -- yes. I don't know how I 1 A No.
2 was made aware, but someone -- yeah, I was told 2 Q Okay. What's your relationship with the MTEA?
3 that he filed a complaint. 3 A They are the Milwaukee Teacher's Education
4 Q Okay. And that's about raced-base 4 Association. I worked with them from a
5 decision-making in the Curriculum & Instruction 5 professional standpoint.
6 Department? 6 Q Okay. Did you ever discuss any action by the
7 A I have no clue what his case was about. 7 board with the MTEA before the board took any
8 Q Do you know Angela Ford? 8 action?
9 A Yes, I know Angela Ford. 9 MS. MCLEROY: Objection, overbroad,
10 Q Okay. Are you aware of whether she has a 10 hypothetical, calls for speculation.
11 complaint filed against Milwaukee Public 11 THE WITNESS: Before they -- give me
12 Schools? 12 an example.
13 A I know nothing. 13 BY MR. HITCHCOCK:
14 Q Okay. Did you ever talk to Angela Ford about 14 Q Well, like a pay raise, for example. Did you
15 Dr. Holiday at any time? 15 ever discuss a pay raise for anybody at MPS
16 A No. 16 with the MTEA before the board actually took a
17 Q Okay. Did you ever talk to Angela Ford about 17 vote on it?
18 any complaints you made at any time? 18 A The MTEA has --
19 A Any complaints that I made? 19 MS. MCLEROY: Same objection.
20 Q That -- sorry. Angela Ford -- did you talk to 20 THE WITNESS: The MTEA has a meeting
21 Angela Ford about any complaints that Angela 21 confirmed. My people would talk to the MTEA
22 Ford made at any time? 22 about salaries and wages and that type -- well,
23 A No. 23 they only meet with them for -- about salaries
24 Q Did you talk to -- sorry -- Ms. Ford about any 24 or whatever the situation. They had back and
25 -- about Dr. Kuether at all? 25 forth with that. And the human resource chief

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1 would share with me what was said, and they 1 MS. MCLEROY: Objection, calls for
2 would also put it in writing and send it over. 2 speculation.
3 BY MR. HITCHCOCK: 3 THE WITNESS: Would a contract
4 Q Okay. Do you know how contracts were 4 result?
5 negotiated with employees while you were the 5 BY MR. HITCHCOCK:
6 superintendent? 6 Q Would MPS create a contract based on that
7 A With employees? 7 salary negotiation?
8 Q Right. 8 MS. MCLEROY: Same objection, calls
9 A I was not into whose contract and negotiating 9 for speculation, incomplete hypothetical.
10 contracts, but I have a general knowledge of 10 Go ahead.
11 how they are. 11 THE WITNESS: Yes. Just like I
12 Q Okay. How are they negotiated? 12 shared with you, that's how they came up with
13 A As far as? 13 the scope of what the salary would be.
14 Q Administrators. 14 BY MR. HITCHCOCK:
15 A As administrators, basically what they did was, 15 Q And once the contracts were prepared, did you
16 like, if an administrator came from outside the 16 sign them?
17 district, they had a lattice of where that 17 MS. MCLEROY: Same objections.
18 person falls, with the years of experience, and 18 THE WITNESS: I have a designee sign
19 at the time on the job, and what their salary 19 those contracts.
20 were at that particular time. And they would 20 BY MR. HITCHCOCK:
21 bring that -- they have to submit that to HR, 21 Q Okay. Who was that?
22 and HR would make a decision around a salary 22 A That was Adria Maddaleni at that time.
23 and give them a salary quote. 23 Q Okay. Now, do you know whether or not
24 Q Got it. And then would a contract result after 24 Dr. Holiday went to the hearing that he was
25 that salary quote? 25 subpoenaed for by Dr. Kuether?
Page 206 Page 207
1 A I know nothing about that. 1 MS. MCLEROY: -- of questioning as
2 Q Okay. Well, then let's stick with that 2 irrelevant so I don't interrupt. Okay?
3 incident. Did you talk to Dr. Pos -- 3 MR. HITCHCOCK: Great.
4 Dr. Holiday about the service of the subpoena 4 THE WITNESS: I don't even remember.
5 on him? 5 BY MR. HITCHCOCK:
6 MS. MCLEROY: I'm going to, first of 6 Q You don't remember how you heard?
7 all, object that's it's completely irrelevant, 7 A I don't remember how I heard.
8 but I would note that the record now states 8 Q Did you talk to Dr. Holiday about the service
9 that subpoena was served -- was issued by the 9 of the subpoena at any time?
10 plaintiff here. 10 A No.
11 Go ahead. 11 Q Did you talk to Adria Maddaleni about the
12 THE WITNESS: Can you re-ask the 12 services at any time?
13 question? 13 A Not that I'm aware of.
14 BY MR. HITCHCOCK: 14 Q Okay. Do you know what case that was for?
15 Q Sure. So we're clear that there was a subpoena 15 A No.
16 served on Dr. Holiday; right? 16 Q Okay. Have you ever -- other than your
17 A I'm not 100 percent clear, but I -- I heard 17 deposition here today, have you ever been asked
18 that it was once served. 18 to appear for a deposition?
19 Q How did you hear it? 19 MS. MCLEROY: Object, irrelevant.
20 MS. MCLEROY: I'm going to object -- 20 THE WITNESS: I think there was one
21 THE WITNESS: I don't even 21 time that I was -- that I was told that I
22 remember -- 22 needed to be deposed by you, but other than
23 MS. MCLEROY: -- to this whole 23 that.
24 line -- 24 BY MR. HITCHCOCK:
25 THE WITNESS: -- who told me. 25 Q And when was that?

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1 A I have no clue. It's been in the past. I 1 people to give him some days that the calendar
2 just -- I don't know. 2 was clear.
3 Q While you were superintendent or something 3 Q Have you ever seen a notice of deposition other
4 else? 4 than the one that you are here today, which you
5 A It was while I was superintendent. 5 may or may not have seen?
6 Q Okay. Was it this attorney here or a different 6 A This is the first time that has been put in my
7 attorney? 7 hand.
8 MS. MCLEROY: Are you pointing at me 8 Q Okay. So other than today, you've never seen a
9 for the record? 9 notice of deposition?
10 BY MR. HITCHCOCK: 10 A A deposition for what?
11 Q I am. Laurie McLeRoy for the record. 11 Q For Dr. Kuether. Any of her cases.
12 Was it this attorney here, Laurie 12 MS. MCLEROY: I'm just going to
13 McLeRoy or someone else? 13 object as irrelevance.
14 A It was someone else. It was the other 14 Go ahead.
15 gentleman in the office. 15 THE WITNESS: In the past, Chris did
16 Q Perhaps Mr. Riordan? 16 not give me a document. He just told me that,
17 A Yes, Chris Riordan. 17 basically, I was going to be deposed, clear my
18 Q And were you available at that time? 18 calendar.
19 A Huh? 19 BY MR. HITCHCOCK:
20 Q Were you available to be -- 20 Q And he didn't tell you you were going to be
21 A Yeah. 21 deposed on a specific day; is that true?
22 Q -- deposed? 22 A He gave me -- he told -- he said he was going
23 A Because he didn't tell me that I was -- the day 23 to work with my administrative assistant to get
24 I was being deposed. He just called and said 24 a number of days that -- that would work for my
25 make some -- clear your calendar, and ask my 25 calendar.
Page 210 Page 211
1 Q And you never told them I couldn't be available 1 Q Oh, okay. What's the -- why is gathering
2 on a certain day. Is that fair? 2 evidence important, if at all?
3 A That was -- 3 MS. MCLEROY: I'm going to object,
4 Go ahead. 4 calls for a hypothetical, incomplete, calls for
5 MS. MCLEROY: That's -- well, yeah, 5 speculation, vague.
6 that's -- any -- any conversation you had with 6 THE WITNESS: Could you ask the
7 Chris Riordan is attorney-client privilege as 7 question again?
8 it relates to this. 8 BY MR. HITCHCOCK:
9 BY MR. HITCHCOCK: 9 Q Sure. Why is gathering evidence important for
10 Q Okay. Got it. I appreciate that. Do you know 10 misconduct investigations, if at all?
11 if MPS keeps personal records on 11 A Because the idea that you want to know what --
12 administrators -- personnel records, to be 12 because it's the idea around when it's -- when
13 clear? 13 -- if there's administering discipline, it
14 A Yes, they have personnel records. 14 makes a difference whether this is the first
15 Q Have you ever seen any of those personnel 15 time something happened or if it's the 15th
16 records before? 16 time it happened, and what types of steps have
17 A Have I ever seen -- as superintendent, no, but 17 gone -- we've gone through.
18 as regional superintendent, yes, I've seen, 18 Q Because MPS practices progressive discipline
19 because any time you are doing a misconduct, 19 while you were the superintendent; right?
20 you have to check to see if there's other 20 A That's correct.
21 misconducts and those kinds of things, yeah. 21 Q Okay. And part of progressive discipline is
22 Q Where did you learn that? 22 notice and opportunity for the employee to be
23 A Where did I learn that? 23 heard; right?
24 Q Uh-huh. 24 MS. MCLEROY: I'm going to object,
25 A As a part of gathering evidence. 25 incomplete hypothetical, assumes facts not in

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1 evidence. 1 information. I don't want to just go off the
2 Go ahead. 2 top of my head around that.
3 THE WITNESS: And you are asking if 3 BY MR. HITCHCOCK:
4 it's -- it's our responsibility so that the 4 Q Okay. And how long were you a regional
5 person being accused have an opportunity to 5 superintendent? I missed it.
6 speak for themselves and to have -- have 6 A The regional superintendent, the administrative
7 someone to take an objective look at it, yes. 7 specialist and the leadership specialist are
8 BY MR. HITCHCOCK: 8 basically the same job. And in those jobs, I
9 Q So where did you gain knowledge of how the 9 think I was there probably close to 14 years.
10 misconduct process at MPS works? 10 Q Okay. And you participated in disciplines?
11 A That is -- MPS has a number of misconduct 11 A A lot of them.
12 trainings that they provide per year. 12 Q Okay. And did you do any investigation in the
13 Q And you participated in at least one of those; 13 disciplines that you took part of?
14 right? 14 A Absolutely.
15 A Several of them. Every year that I was -- 15 Q Okay. And did you learn what the point of
16 probably for the last 22 years I've 16 those investigations were during those
17 participated in. 17 14 years?
18 Q Okay. And what did you learn in those 18 A Yes.
19 trainings about the opportunity for an employee 19 Q Okay. What was the point of those
20 to defend themselves? 20 investigations?
21 MS. MCLEROY: I'm going to object, 21 A To make --
22 vague, incomplete hypothetical. 22 MS. MCLEROY: Objection, vague
23 Go ahead and answer. 23 incomplete hypothetical.
24 THE WITNESS: I would have to take a 24 Go ahead.
25 look at the manual and all of the training 25 THE WITNESS: Number one and fore --
Page 214 Page 215
1 foremost is to make sure students are safe, and 1 discipline an employee you have to investigate;
2 make sure that no work rules and guidelines of 2 true?
3 being -- that they are being followed. And to 3 MS. MCLEROY: Asked and answered.
4 make sure that we are not falsely accusing a -- 4 THE WITNESS: Define what you mean.
5 someone for something that they did not do as 5 I don't know -- are you speaking hypothetical?
6 well to gain an understanding of what's -- what 6 But, you know, if you're speaking -- I am just
7 occurred. It was a misconduct of a moment in 7 trying to figure out where you are going with
8 time. 8 it.
9 BY MR. HITCHCOCK: 9 BY MR. HITCHCOCK:
10 Q And is there also a role in a misconduct 10 Q Okay. What I'm trying to do is understand,
11 evaluation for the accused person to tell what 11 based on your 24 years of experience whether or
12 their side of the story is? 12 not you believed that an investigation was an
13 A Yes. 13 important part of misconduct -- misconduct, the
14 Q What is the reason for that? 14 word I think you used?
15 A Because they have to have due process. 15 MS. MCLEROY: Asked and answered,
16 Q Okay. And when did you learn about due 16 overbroad.
17 process? 17 Go ahead.
18 A I shared with you that's probably in the 18 THE WITNESS: Yes.
19 last -- it's probably been 24 years of it. 19 BY MR. HITCHCOCK:
20 24 years of it. 20 Q Yes. Okay. And -- okay. And what we were
21 Q Okay. So for at least 24 years, you knew that 21 just describing, which was an allegation, an
22 before you disciplined an employee, you've got 22 investigation, a determination, and an
23 to hear their side of the story; true? 23 opportunity for the accused person to present
24 A Absolutely. 24 their side of the story, are those what you
25 Q Okay. For 24 years, you knew that before you 25 would consider basic elements of a disciplinary

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1 investigation? 1 BY MR. HITCHCOCK:
2 A Yes. 2 Q Uh-huh.
3 Q Okay. Now, do you believe that an 3 MS. MCLEROY: -- vague. Process at
4 administrator has a right to be heard by the 4 MPS?
5 board before non-renewal? 5 BY MR. HITCHCOCK:
6 MS. MCLEROY: Object, calls for 6 Q Sure. At MPS while you were a superintendent.
7 speculation, incomplete hypothetical. 7 A Is there a process?
8 Go ahead. 8 Q Right.
9 THE WITNESS: They contract, they 9 A What kind of complaint are you referring to?
10 have guidelines and policies and procedures 10 Q Let's just focus on complaint made -- complaint
11 around who get heard by the board and who 11 made against Jeremiah Holiday. Is there a
12 doesn't. 12 process for the superintendent to be notified
13 BY MR. HITCHCOCK: 13 of complaints against Jeremiah Holiday?
14 Q There's also state law, too; right? 14 A It's on an at-need-to-know basis. If it's a
15 MS. MCLEROY: Again, calls for 15 whistleblower that comes through -- come
16 speculation, incomplete hypothetical. 16 through board governance, I won't know. If it
17 Go ahead. 17 comes through -- if it comes through OAE, I
18 THE WITNESS: There are -- state law 18 won't know. And even it can come through HR
19 governs around how individuals are demoted. 19 and I won't know.
20 BY MR. HITCHCOCK: 20 Q Okay. And that's -- my understanding is that
21 Q Okay. Is there a process for the 21 there are several kinds of complaint
22 superintendent to learn about employee 22 processes --
23 complaints? 23 A Right.
24 A Is there a process? 24 Q -- at MPS; that's true? Right? And there's --
25 MS. MCLEROY: Objection -- 25 the board has a special whistleblower complaint
Page 218 Page 219
1 process; right? 1 to the board, and three to administration; is
2 A Correct. 2 that accurate?
3 Q Okay. And the part of the purpose of that, at 3 A And administration could mean that they could
4 least as I understand it, is to circumvent the 4 make it directly to the superintendent's office
5 superintendent's office; right? 5 or they may make it to assistant principal out
6 A That I -- 6 at a school or -- or whomever.
7 MS. MCLEROY: Objection, calls for 7 Q I got that. But once -- and there's certain --
8 speculation. 8 certain people from each of those categories
9 BY MR. HITCHCOCK: 9 which must take a whistleblower complaint; is
10 Q Oh, okay. And you -- so you don't know why 10 that also true?
11 Matt Chason's office is not under the 11 A Out of that category, yes.
12 supervision of the superintendent? 12 Q Okay. And the superintendent is also someone
13 MS. MCLEROY: Objection, lacks 13 who must take a whistleblower complaint; true?
14 foundation. 14 A Right.
15 Go ahead. 15 Q Okay. And -- but it's also true that you are
16 THE WITNESS: That office was that 16 not -- you are not getting the complaints?
17 way before I came there. 17 Isn't that also the case?
18 BY MR. HITCHCOCK: 18 MS. MCLEROY: Objection, vague.
19 Q Okay. Do you know why or something else? 19 THE WITNESS: Are you referring to
20 A I have no clue why they decided to go that 20 from OAE and --
21 route. 21 BY MR. HITCHCOCK:
22 Q I got it. Okay. So as I understand it, 22 Q No. I'm talking about from the administration.
23 there's at least three places, and this is from 23 A I don't get every complaint that is levied
24 Matt Chason that a person can make a 24 against the district when I was the
25 whistleblower complaint, one to his office, two 25 superintendent.

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1 Q Have you ever received a whistleblower 1 A Like I said, I only get notified of -- they
2 complaint while you were superintendent? 2 don't give me complaints that happens in
3 A Yes, the one from Calvin Fermin. 3 schools, complaints -- people complain about
4 Q Got it. 4 Milwaukee Public Schools all the time. I don't
5 A I don't know who wasn't -- I just don't 5 get those complaints. There's places that
6 remember the word "whistleblower" being on it, 6 those complaints go. And some of them I would
7 but I received that document from him. 7 never have knowledge that it happened.
8 Q Okay. Thank you for that. So then there are 8 Q Did any board members ever complain to you
9 also, to my knowledge, complaints that are of 9 about Jeremiah Holiday?
10 the non-whistleblower type, that those go to 10 A Yes.
11 HR; isn't that accurate? 11 Q Who?
12 A I would say it could be HR, it could be the 12 A Dr. Baez.
13 local school, it could be principals or 13 Q Anybody else?
14 assistant principals, or somebody at the school 14 A That was the only one that just complained
15 level. I don't know. 15 about him. You know, there's others that have
16 Q Right. And there -- and there could be 16 asked me questions about various things or, you
17 employee relations; right? 17 know, what's going on with this or what's going
18 A Right. It can go there. 18 on with that. I've had individuals ask that.
19 Q And it could be employee rights, too? 19 Q How about Bob Peterson?
20 A Employee rights, yeah. 20 A Bob Peterson has asked me questions.
21 Q Right. So there's all sorts of places that 21 Q What has he asked you about Jeremiah Holiday?
22 somebody can be can make a complaint; true? 22 A The only thing that I remember him asking me
23 A Right. 23 about something to do with the math science
24 Q Which of those complaints, if any, are you 24 department or something to do with math
25 going to get notified of? 25 science.
Page 222 Page 223
1 Q Dr. Garcia Joven's department? 1 it was Rochelle Zanden.
2 A No. It was -- this was another young lady that 2 Q Okay. Do you know how MPS will handle an FMLA
3 was there. I can't think of her name right 3 request?
4 now. I think she -- actually, it was science, 4 MS. MCLEROY: I'm going to object,
5 I believe it was. I can't think of the young 5 vague, incomplete hypothetical.
6 lady's right now. 6 Go ahead.
7 Q And was it -- 7 THE WITNESS: That is something that
8 A She was a -- like a curriculum specialist. 8 -- that I'm not -- that's an HR function.
9 Q Okay. Was it a positive interaction that 9 BY MR. HITCHCOCK:
10 Mr. Peterson was bringing to your attention 10 Q I got it. Based on your knowledge and
11 that Mr. Holiday had engaged in? 11 experience at MPS, do you believe if somebody's
12 A It was -- he just was seeking knowledge around 12 time sheets indicate that they are on FMLA
13 -- I think one time it was about something with 13 leave that they are on FMLA leave?
14 the curriculum and textbook or something of 14 MS. MCLEROY: Objection, incomplete
15 that nature. So it was just a number of little 15 hypothetical.
16 things like that. He asked a number of 16 THE WITNESS: If they -- the sheet?
17 questions. He's very -- he was very in tune to 17 What do you mean? Like depend on where the
18 the academic piece. And, you know, I think he 18 sheet come from. If it's something that
19 asked a question in the past about history, 19 somebody had written up or is it something that
20 social studies books, things of that nature. 20 come from HR.
21 And so just that kind of stuff. 21 BY MR. HITCHCOCK:
22 Q Okay. And is the specialist we are talking 22 Q Got it. Okay.
23 about Tamera Coleman or somebody else? 23 Here's the one. And we will mark
24 A Tamera Coleman, no. It might Sandy. Is it 24 that. I'm going with 6.
25 Sandy? Sandy? I don't -- Rochelle -- I think 25 THE REPORTER: 9.

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1 (Exhibit No. 9 was marked.) 1 A Yes.
2 BY MR. HITCHCOCK: 2 Q Can you tell me what -- if you've seen entries
3 Q Do you see this document here? 3 in this format before during your course of
4 A Yes. 4 employment as a superintendent?
5 Q Okay. It's my understanding that this is an 5 MS. MCLEROY: I'm going to object,
6 e-mail from Mr. Gorton, and on the first page 6 lacks foundation as to this witness.
7 it's dated July 21st, 2021. Do you see that 7 Go ahead and answer.
8 there? 8 THE WITNESS: The answer is no, I
9 A Yes. 9 don't get this document. I don't know anything
10 Q Okay. And then I'm going to direct your 10 about this document. This is between HR and
11 attention to at least the third -- I guess the 11 the employee.
12 second page, the bottom of the second page. 12 BY MR. HITCHCOCK:
13 MS. MCLEROY: I'm going to object to 13 Q Okay. And do you know who James Gorton is?
14 this exhibit as not authentic, and lacks 14 A Yes.
15 foundation as to this witness. 15 Q Okay. Who is James Gorton?
16 Go ahead. 16 A James Gorton worked in the HR.
17 BY MR. HITCHCOCK: 17 Q Okay. Do you know if he's an attorney? At
18 Q I understand. I'm pointing you to the section 18 least went to law school?
19 that says above, "Full MPS Absences Entries 19 A That I do not know.
20 covering FMLA period." Do you see that there? 20 Q Okay. I understand.
21 I might have read that -- 21 A I never interviewed Gorton, so I haven't seen
22 A Yes, yes, yes, yes, yes. 22 his resume.
23 Q Okay. And then there's three entries, and then 23 Q Okay. And I'm just looking there on the
24 there's several pages of entries after that. 24 bottom. And for the record, it says page 133
25 Do you see that there? 25 at the bottom and then 134. Do you see that?
Page 226 Page 227
1 MS. MCLEROY: No. 1 MR. HITCHCOCK: I got it. And it
2 BY MR. HITCHCOCK: 2 sounds to me, just so we're -- because I'm
3 Q 120 -- I know I see 134. Do you not have that? 3 speaking out loudly, there's maybe
4 Do you object to this one being an 4 authentication issues with this particular
5 exhibit, other than the objections you've 5 document. But I would like to ask him
6 already stated? 6 questions at least on this, and we will see
7 MS. KUETHER: It's right there. 7 what happens. Okay?
8 MS. MCLEROY: I can't even tell if 8 MS. MCLEROY: Absolutely. Go ahead.
9 they are the same thing, to be honest. 9 BY MR. HITCHCOCK:
10 MS. KOLBERG: They are different 10 Q Great. So I -- with my false start there, I
11 because there's a page number on one and 11 indicated that there was 134 at the bottom, but
12 there's highlighting on one. 12 I will just also indicate for the record, it
13 MS. MCLEROY: Also, the spacing is 13 says, "Sedgwick FMLA Usage Calendar," and then
14 off, so I can't tell if they are the same, to 14 it's got Mr. Gorton's position and credentials
15 be honest. I would say do it separately. I 15 information after that. Do you see that there?
16 don't know what that is. 16 A Uh-huh.
17 MR. HITCHCOCK: But -- and so you 17 Q Okay. So then I'm just going to direct you to
18 have -- it looks like you have a page similar 18 these one, two, three, four five, six dates up
19 to this, but it doesn't have a 134 at the 19 from the bottom of this document. Do you see
20 bottom. Is that fair? 20 the dates on those days?
21 MS. MCLEROY: Correct. And I also 21 A 12/28/2020?
22 held it up to the light and it didn't match up 22 Q Yeah. And then just so for completeness, I
23 exactly either. So the spacing or something is 23 also see 12/23, 12/22, 12/14, 12/7 and 12/4; is
24 different, and I didn't take the time to see 24 that right?
25 what else is different. 25 A Yes.

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1 Q And then for the -- for 12/28, 12/23 and 12/22, 1 building principal, because they would get --
2 oh, and also 12/14, it -- what I see here is 2 we would get a list, basically if somebody was
3 that the date is noted FMLA Sick Take/Personal 3 on FMLA. But I have not seen the new piece
4 Leave FMLA. Do I see right? 4 with Sedgwick --
5 MS. MCLEROY: I am going to object 5 Q Got it.
6 again, no authentication as to this document, 6 A -- you know, because that was after -- that
7 no foundation for this witness, no -- no 7 came off I was a principal.
8 information for this witness to speculate as to 8 Q Do you know what ambitious instruction is?
9 when those entries were made or FMLA was 9 A Absolutely.
10 approved, whether before or after. So the 10 Q What is it?
11 document speaks for itself. 11 A Ambitious instruction is one the five the
12 MR. HITCHCOCK: Got it. Okay. 12 priorities that I had for the school district.
13 MS. MCLEROY: Okay. With that, go 13 Q And it had a literacy piece; is that right?
14 ahead and answer. 14 A Uh-huh.
15 THE WITNESS: And you're asking do I 15 Q Okay. And was Dr. Kuether working on that, to
16 see FMLA sick take and personal and sick FM -- 16 your knowledge?
17 FMLA? 17 A I can just say that everybody in the C&I
18 BY MR. HITCHCOCK: 18 Department and the school district should have
19 Q That's right. 19 been working on it.
20 A Yeah, I see that. 20 Q Okay. Now -- and I'm going to use the term
21 Q Okay. And, again, is this -- have you seen 21 "supervisor," but to be clear, you supervised
22 this on a form during -- not just as 22 Jeremiah Holiday with the deputy
23 superintendent, but during your entire time at 23 superintendent; true?
24 MPS? 24 A Yeah, the deputy superintendent supervised him.
25 A I would say I would have seen this as a 25 Q Okay. But you were the ultimate person
Page 230 Page 231
1 responsible for supervising Dr. Holiday; true? 1 Calvin Fermin.
2 A The only one that was responsible for 2 BY MR. HITCHCOCK:
3 Dr. Holiday -- depending on what year you are 3 Q Got it. What deputy superintendent supervised
4 talking about. The deputy superintendent when 4 an allegation of race-based hiring?
5 I had the deputy superintendents. And then 5 MS. MCLEROY: Objection, vague,
6 when I did not have a deputy superintendent, it 6 overbroad, calls for speculation.
7 was me. 7 THE WITNESS: I -- I would think it
8 Q Got it. So -- 8 would have to have been Chris Hauser.
9 A And I don't even know if he was around at time 9 BY MR. HITCHCOCK:
10 when I didn't have a deputy superintendent. So 10 Q Okay. Why?
11 it was always a deputy superintendent when I 11 A Because Chris Hauser was the deputy
12 had Dr. Holiday. 12 superintendent at that time.
13 Q Okay. So you're -- do I understand it 13 Q Okay. And so how do you know that he would
14 correctly that while Calvin Fermin was a deputy 14 have been in charge as opposed to -- or
15 superintendent, he was the supervisor of 15 supervised --
16 Jeremiah Holiday? 16 A I'm just --
17 MS. MCLEROY: Objection, misstates 17 Q -- as opposed to --
18 his prior testimony, assumes facts not in 18 A I'm just --
19 evidence. 19 Q -- Rosana Mateo?
20 THE WITNESS: They had -- we had it 20 A That is truly speculation, because I do not see
21 split up, academic side and the business side. 21 it on paper. I see -- I don't know the name
22 And there was a deputy superintendent on the 22 which you are talking about, so I'm just -- and
23 academic side, which the two deputies that I 23 I have to see was he there at that particular
24 had was Rosana Mateo and Christopher Hauser. 24 or had he retired.
25 And then on the financial side was -- was 25 Q Okay. So how long was it between the period

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1 when there were complaints against Dr. Holiday 1 A Because if they -- we want to make sure that
2 until the time that you ultimately did not put 2 the district is moving -- moving forward in the
3 it -- or demoted him? 3 right direction.
4 MS. MCLEROY: I am going to object to 4 Q Got it. Have you ever been discriminated
5 the extent it misstates his prior testimony. 5 against?
6 Go ahead and answer. 6 MS. MCLEROY: I'm going to object as
7 THE WITNESS: I don't know. I guess 7 irrelevant.
8 that the thing about it is I would have to look 8 Go ahead and answer.
9 at when he was -- when I carried his name 9 THE WITNESS: As far as?
10 forward until when I demoted him. 10 BY MR. HITCHCOCK:
11 BY MR. HITCHCOCK: 11 Q We will start with race.
12 Q Okay. Now, if Calvin Fermin while he was 12 A Race?
13 deputy superintendent had received a numerous 13 Q Yeah.
14 anonymous complaints against Dr. Holiday, would 14 A Not that I'm aware of. Not that someone just
15 you have expected Calvin Fermin to give you 15 said, hey, I'm discriminating against you. You
16 those complaints? 16 have to be a person that looks for those kinds
17 MS. MCLEROY: Objection, calls for 17 of things. I don't look for that. People are
18 speculation. 18 going to treat you the way they treat you and
19 Go ahead. 19 that's their business.
20 THE WITNESS: I would hope that he 20 Q Okay. What do you mean "you have to be a
21 would have. 21 person that looks for those things"?
22 BY MR. HITCHCOCK: 22 A I -- I mean, that I would have to be a person
23 Q Okay. Why? 23 that's looking to say you did this to me
24 A Why? 24 because I'm African American or whatever the
25 Q Why? 25 situation. I don't do that. I don't make
Page 234 Page 235
1 excuses. 1 Q Okay. Were you aware that Calvin Fermin
2 Q Did Dr. Holiday make excuses? 2 received anonymous complaints about Jeremiah
3 A I have -- 3 Holiday alleging that Jeremiah Holiday speaks
4 MS. MCLEROY: Objection -- 4 very poorly about his female directors?
5 THE WITNESS: -- no clue. 5 A No.
6 MS. MCLEROY: -- calls for 6 Q Okay. Were you aware that Calvin Fermin
7 speculation. 7 received a complaint about Dr. Holiday asking
8 BY MR. HITCHCOCK: 8 why someone with pending legal action would be
9 Q Okay. Well, you know he files an ERD -- a 9 appointed?
10 discrimination complaint; right? 10 MS. MCLEROY: Objection, vague.
11 MS. MCLEROY: Asked and answered. 11 THE WITNESS: Who are you referring
12 THE WITNESS: The one you are talking 12 to? I don't -- no. No.
13 about referred to me? 13 BY MR. HITCHCOCK:
14 BY MR. HITCHCOCK: 14 Q I'm referring to Calvin Fermin had pending
15 Q Right. 15 legal action against -- or, sorry, Jeremiah
16 A Yes. 16 Holiday had pending legal action against him;
17 Q Okay. When Dr. Holiday became chief -- interim 17 right?
18 chief of academics, did he interview with 18 MS. MCLEROY: I'm going to object,
19 anybody? 19 vague.
20 A Yes. 20 THE WITNESS: Against who? Against
21 Q Who? 21 him? He had -- they had it against him.
22 A Me. 22 BY MR. HITCHCOCK:
23 Q Anybody -- did you interview anybody else for 23 Q Uh-huh. Deb Bowling filed a complaint against
24 that position at that time? 24 Dr. Holiday, and you still put up Dr. Holiday
25 A Yes. 25 for promotion; true?

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1 A Like I -- 1 Dr. Holiday told them if we have something to
2 MS. MCLEROY: Objection, misstates 2 say to say it directly to Dr. Holiday, and to
3 the evidence, calls for speculation. 3 not sneak around Dr. Holiday until Dr. Posley.
4 Go ahead. 4 Are you aware of that?
5 THE WITNESS: Like I shared with you, 5 MS. MCLEROY: Objection, lack of
6 you would have to take a look at the date that 6 foundation.
7 I was made aware of that one particular case 7 THE WITNESS: Not aware of that at
8 that you keep referring to. 8 all.
9 BY MR. HITCHCOCK: 9 BY MR. HITCHCOCK:
10 Q Got it. Did Calvin Fermin ever make you aware 10 Q Okay. Do you think as superintendent that
11 that he received anonymous complaints -- he 11 those -- these are the kind of complaints that
12 read and received anonymous complaints against 12 you should have been made aware of?
13 Jeremiah Holiday stating that Jeremiah Holiday 13 MS. MCLEROY: I'm going to object,
14 had stated with some regularity that there are 14 assumes facts not in evidence, calls for
15 too many white people in the office of 15 speculation.
16 academics? 16 THE WITNESS: And this is total
17 A No. 17 speculation if someone was saying or doing
18 MS. MCLEROY: Objection, asked and 18 those kinds of things, yeah, that's something I
19 answered. 19 should have been made aware.
20 THE WITNESS: No. 20 BY MR. HITCHCOCK:
21 BY MR. HITCHCOCK: 21 Q Okay. And you would agree with me that if
22 Q No, he never did that. Okay. Did Calvin 22 Dr. Holiday says that he feels that there are
23 Fermin ever share with you the allegation 23 too many white people in the office of
24 against Jeremiah Holiday that he read in which 24 academics, that that's something as
25 subordinates of Dr. Holiday say that 25 superintendent that you should be
Page 238 Page 239
1 investigating; right? 1 changed Dr. Holiday's -- wrote a letter stating
2 MS. MCLEROY: I'm going to object, it 2 that he didn't believe Dr. Holiday engaged in
3 assumes facts not in evidence, calls for 3 race discrimination; right?
4 speculation, no foundation. 4 MS. MCLEROY: Objection, asked and
5 Go ahead. 5 answered, vague.
6 THE WITNESS: Not just Holiday. 6 THE WITNESS: Who wrote the -- that
7 Anyone that would make any type of racist type 7 Calvin wrote a letter to whom?
8 of statement as such I would ask that they be 8 BY MR. HITCHCOCK:
9 investigated. 9 Q Wrote a letter absolving Jeremiah Holiday of
10 BY MR. HITCHCOCK: 10 race discrimination in the hiring of Deb
11 Q Okay. And other than the city attorney's 11 Bowling?
12 office investigation into Dr. Holiday and the 12 A Hiring -- I don't know anything about that.
13 Miriam Horwitz investigation into Dr. Holiday 13 Q Okay.
14 and the James Carrol investigation into 14 MS. KOLBERG: This is different.
15 Dr. Holiday, are you aware of any other 15 This has a different mark on it. It says
16 investigations -- oh, and, sorry, the Calvin 16 "scanned with CamScanner" on this one.
17 Fermin investigation into Dr. Holiday, are you 17 MS. MCLEROY: The content is the
18 aware of any other investigations into 18 same, but the print is not -- there's some
19 Dr. Holiday? 19 additional footers.
20 MS. MCLEROY: I am going to object 20 MR. HITCHCOCK: Okay. He's got the
21 that it misstates his prior testimony. You've 21 clean copy?
22 added things that he hasn't -- he had no 22 MS. MCLEROY: Yes.
23 foundation. 23 MR. HITCHCOCK: Great.
24 BY MR. HITCHCOCK: 24 (Exhibit No. 10 was marked.)
25 Q Oh. Well, you are aware that Calvin Fermin 25 BY MR. HITCHCOCK:

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1 Q Have you ever seen this document before? 1 Q Okay. Are you saying that Mr. Gorton never
2 A No. 2 discussed -- sought your permission to contact
3 Q Okay. And do you recognize the letterhead of 3 the city attorney's office to investigate
4 this document? 4 Dr. Holiday?
5 A Do I know the letterhead? Yes. 5 A They don't seek my permission to call on
6 Q What is it? 6 misconducts and things of that nature. You
7 A It's from the city of Milwaukee city attorney's 7 realize how large Milwaukee Public Schools is
8 office. 8 and all the things that happen on a daily basis
9 Q Okay. And who is it addressed to? 9 that they don't call me for.
10 A It's Jim Gorton. 10 Q I appreciate that. Just with regards to this
11 Q And what position did he hold at this time? 11 and Mr. Gorton, did Mr. Gorton do that or not?
12 A Employee Rights Division, Employee Relations 12 A Did he call me?
13 Department, Office of Human Resources. 13 Q Did he contact you in any way? Communicate
14 Q Okay. Are you -- and you are telling us that 14 with you regarding this?
15 you are not aware of the fact that Jim Gorton's 15 A No, I haven't talked to him.
16 office engaged the office of the city attorney 16 Q Okay. And Calvin Fermin didn't either?
17 to conduct investigation of two Bowling 17 A About Deb Kuether? Nothing about Deb Kuether.
18 harassment discrimination complaints, internal 18 Q Okay. Katrice Cotton didn't contact you about
19 complaints filed by Deborah Kuether; true? 19 Deb Kuether; true?
20 MS. MCLEROY: I'm going to object, 20 A For what reasons?
21 vague. 21 Q Well, to alert you to the fact that they had --
22 THE WITNESS: Like I shared with you 22 had to speak with the city attorney?
23 earlier, I do not have -- I don't have any 23 A No.
24 knowledge of those things at all. 24 Q Okay. Felicia Saffold didn't tell that she had
25 BY MR. HITCHCOCK: 25 to --
Page 242 Page 243
1 A No. 1 morning and was questioning me -- not President
2 Q -- was being interviewed by the city attorney's 2 Peterson, president -- president -- former
3 office? 3 president Miller, Bob Miller.
4 A No. I never even talked to Felicia Saffold. 4 MR. HITCHCOCK: I just want the
5 Q Okay. And Jeremiah Holiday also didn't tell 5 record to reflect --
6 you that? 6 MS. MCLEROY: Larry Miller.
7 A No. None of these individuals. And I don't 7 THE WITNESS: Larry Miller. Larry
8 know whether -- did they tell them to share it 8 Miller. Larry Miller.
9 with me? 9 MR. HITCHCOCK: -- the attornies were
10 Q Okay. And you'll look on page 2, section 2 Key 10 whispering to each other, and based on those
11 Individuals, the second bullet point has got 11 whispers, the deponent changed his response.
12 your name; right? 12 MS. MCLEROY: Well, I'd like to --
13 A Yeah. 13 THE WITNESS: Larry.
14 Q It says, "Posley did not directly supervise 14 MS. MCLEROY: We did not communicate
15 Kuether during the time frame relevant to her 15 with the witness. And the record would show
16 complaints, but he did make the decision to 16 that he's repeatedly testified from questions
17 reassign her from Central Office position to 17 from you about his conversations with Larry
18 Washington High School"; true? 18 Miller and visit to Washington High School.
19 A Not to Washington High School. I did not tell 19 MR. HITCHCOCK: Right. And I noticed
20 anybody where she was going. So Washington 20 that, too, but I also refrained from
21 High School is -- right here is incorrect. 21 communicating with the witness. Okay.
22 Q Okay. When did you find out where Dr. Kuether 22 MS. MCLEROY: As did I.
23 was sent to? 23 BY MR. HITCHCOCK:
24 A Honestly, I found out where Dr. Kuether was 24 Q Are you friends with Angela Terry?
25 sent to when President Peterson called me that 25 A I shared with you that earlier. I knew her, I

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1 am not friends with her. 1 witness.
2 Q Got it. Okay. Are you in the same fraternity 2 Go ahead.
3 or any -- I guess because she would obviously 3 THE WITNESS: Like I shared with you,
4 not be in a fraternity, but she was in a 4 every time there was a closed session, I was
5 related organization? 5 not present, so I don't know, and I can't
6 MS. MCLEROY: I am going to object, 6 remember whether I was in the full meeting or a
7 irrelevant. 7 portion of the meeting or whatever on that
8 THE WITNESS: What related 8 particular day.
9 organization? 9 BY MR. HITCHCOCK:
10 BY MR. HITCHCOCK: 10 Q Okay. I'm going to read from -- further from
11 Q I will withdraw the question. 11 this James Carrol report, "Posley instructed
12 Were you aware of any complaints 12 Fermin and Cotton to meet with Kuether on
13 about Jeremiah Holiday misusing FMLA with the 13 December 29th, 2020." Is that part true?
14 instruction of coaches? 14 MS. MCLEROY: Can I -- can you direct
15 MS. MCLEROY: I am going to object, 15 us where you are reading from?
16 irrelevant, vague, lacks foundation. 16 MR. HITCHCOCK: No.
17 Go ahead. 17 MS. MCLEROY: On Exhibit 10?
18 THE WITNESS: No. 18 THE WITNESS: Exhibit 10.
19 BY MR. HITCHCOCK: 19 MR. HITCHCOCK: It's a bullet point.
20 Q Okay. Now, at the -- we will move back in time 20 BY MR. HITCHCOCK:
21 here. The January 21st, 2021 board meeting, 21 Q Okay. Can you answer my question? Is that
22 did any -- I understand that Mr. Chason made 22 accurate that you asked them to meet with
23 some comments. Did any board members respond? 23 Dr. Kuether on the 29th of December, 2020?
24 MS. MCLEROY: I'm going to object, 24 A I can share with you that I asked them to meet
25 calls for speculation, foundation of this 25 with her, but I cannot tell you sitting here
Page 246 Page 247
1 today exactly what date it was. 1 BY MR. HITCHCOCK:
2 Q Got it. 2 Q I just -- I'm just -- my question is just is
3 A Not sure on the -- 3 that a true statement?
4 Q And that doesn't -- that doesn't refresh your 4 MS. MCLEROY: Again, are you refusing
5 recollection at all? Fair enough. 5 to let him know from where you are reading?
6 A You know, honestly, as far as dates, I do not 6 You are reading from something.
7 know the exact date. 7 BY MR. HITCHCOCK:
8 Q Okay. And if the letter -- if the report says 8 Q I am reading from something. I'm reading from
9 that you directed Cotton and Fermin to reassign 9 page 10. The first bullet point on page 10.
10 Kuether to Washington High School, you dispute 10 It's about halfway down there.
11 that; right? 11 A Posley. Okay. Go ahead.
12 A I said to Washington High School, I did not say 12 Q "According to Posley, this decision was made
13 that. 13 only after Kuether's problematic behavior
14 Q Okay. Got it. 14 persisted." Is that part true?
15 A I said "reassign." 15 A This decision was made only -- the decision was
16 Q Okay. Then it says, "According to Posley, this 16 made because it was a crisis situation,
17 decision was made only after Kuether's 17 children were not receiving instruction. I
18 problematic behavior persisted following 18 wanted to make sure children were receiving
19 Saffold's counseling of Kuether on 19 quality instruction on a daily basis at home.
20 December 2nd, 2020." Now, let's skip past the 20 That's why the decision was made.
21 "according to Posley part." Is this part true, 21 Q Got it.
22 "this decision was made only after Kuether's 22 A The decision to reassign has -- is based on a
23 problematic behavior persisted"? 23 need for the district. If there's a need for
24 MS. MCLEROY: Can you let the witness 24 someone to go -- we do all the time. We
25 know from where you are reading? 25 reassign all the time. Every school year,

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1 people are reassigned for months at a time to 1 MS. MCLEROY: I'm going to object,
2 get school up and running. There was times 2 vague.
3 where we didn't have teachers, they were 3 If you can answer.
4 reassigned. Reassignment is not a negative 4 THE WITNESS: I didn't forcibly
5 thing. There was a thing -- there's a need, 5 remove her. I --
6 and this was a situation where there was a 6 BY MR. HITCHCOCK:
7 crisis and we had to move forward. 7 Q Okay. I appreciate that. So we're clear it's
8 Q Okay. And how many people have you reassigned 8 an involuntary transfer; right?
9 approximately after a month after they made a 9 A An involuntary transfer? Involunt --
10 complaint against Dr. Holiday? 10 transfer -- transfers -- not involuntary
11 MS. MCLEROY: I am going to object, 11 transfer, it was a reassignment.
12 vague. 12 Q Okay. Was it voluntary or something else?
13 THE WITNESS: I can't answer that 13 A It was a -- it was called special assignment.
14 question. I don't even -- I don't even know 14 She was reassigned on special assignment.
15 who made complaints against Dr. Holiday, except 15 Q Okay. Did that special assignment have any job
16 for the ones that are privy to today, and the 16 duties?
17 ones that, you know, have come to me through 17 A Yes.
18 investigation. 18 Q What were those job duties?
19 BY MR. HITCHCOCK: 19 A You would have to -- I would have to get those
20 Q Okay. Now, how long after you had direct -- 20 job duties. I don't have those duties on the
21 you forcibly -- involuntarily removed 21 back of my mind of what those duties were.
22 Dr. Kuether was the problem that Dr. Saffold 22 Q Well, did you --
23 brought to your attention resolved? 23 A She had the duties of the assistant principal,
24 MS. MCLEROY: Can you read that back? 24 and all the assistant principal job duties and
25 (Record read.) 25 responsibilities are similar and the same,
Page 250 Page 251
1 whether there's an instructional person, 1 particular assignment. It's called
2 whether it's a person that does programming, 2 administrator on special assignment.
3 and whether it's a person that -- sometime they 3 Q Okay. And what are the job duties for the
4 even have it as far as whoever does the 4 administrator on special assignment?
5 discipline of -- climate of the school. 5 A The job duties for an administrator on special
6 Q Was there ever a time that you had 6 assignment is the same duties of the job that
7 Dr. Kuether's job duties on special assignment 7 they are on assignment to do the assistant
8 written down? 8 principal's of the job, whether it was the
9 A No. 9 academic portion of it, whether it was the
10 Q Okay. And so how -- 10 programming portion of it, whether it was just
11 A That I had them written down for me? 11 overall day-to-day operations of a school.
12 Q Right. 12 Q So Dr. Kuether was specially assigned to be the
13 A No. 13 assistant principal at Hamilton High School.
14 Q Did you have them write them down for anybody 14 Is that fair?
15 else? 15 MS. MCLEROY: Objection, misstates
16 A I don't have it written down for any assistant 16 his testimony.
17 principal within the district or anyone or 17 THE WITNESS: She was not assigned to
18 principal or anyone else. 18 be assistant principal at Hamilton High School,
19 Q When you say "assistant principal," are you 19 so the answer is no.
20 talking about special assignment? 20 BY MR. HITCHCOCK:
21 A Yes. 21 Q Okay. Now I got it. How about Washington High
22 Q How is special assignment and assistant 22 School?
23 principal the same? 23 A At Washington High School -- she was on special
24 A The -- basically, if someone is moved, they go 24 assignment at Washington High School.
25 to an assignment, and they serve in that 25 Q Okay. But not to be -- she wasn't specially

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1 assigned to be the assistant principal; true? 1 resources that they would -- may need to confer
2 MS. MCLEROY: I'm going to object, 2 with.
3 lacks foundation. 3 Q Now, was that Calvin Fermin?
4 Go ahead. 4 A Could have been Calvin Fermin because he --
5 THE WITNESS: She was assigned as 5 because I talked to him as well.
6 administrator on special assignment. 6 Q Okay. But not --
7 BY MR. HITCHCOCK: 7 A On the front end.
8 Q Great. Did Dr. Kueth -- did you ever 8 Q But not --
9 communicate to Dr. Kuether what her job duties 9 A I talked to him at the beginning.
10 were? 10 Q It wasn't Ms. Freiberg; true?
11 A I never talked to Dr. Kuether. 11 A Right.
12 Q Okay. So that's a no? It's not possible? 12 Q And it wasn't the city attorney's office; true?
13 A You asked did I do it? 13 A About her duties and what she was supposed to
14 Q Right. 14 do, no, I didn't call them and say let's have a
15 A I never talked to Dr. Kuether. 15 conversation about what she should be doing.
16 Q Did you talk to anybody about Dr. Kuether's job 16 There's a job description for the assignment.
17 duties whenever she went? 17 Q Continuing on, it says, "From Posley's
18 A That is not in my responsibility, that is not 18 perspective, Kuether had been a difficult
19 in my wheelhouse to do. That is not what I do. 19 employee for some time." Is that a true
20 I have a team to take care of that. 20 statement?
21 Q Got it. Okay. And -- I got it. Okay. And 21 A That she's been a difficult -- I haven't talked
22 who -- when you say your team, who are we 22 to anybody about her being a difficult
23 talking about? 23 employee. I shared with you what -- the
24 A That's Dr. Cotton's department, which was 24 information that I shared earlier of what I
25 school administration, and anyone in human 25 learned from Saffold and, you know --
Page 254 Page 255
1 Q Okay. Did you share with Katrice Cotton that 1 with co-workers?
2 Dr. Kuether had been a difficult employee? 2 A No.
3 A No. 3 Q Okay. Did you tell anybody that you believe
4 Q Okay. How about Calvin Fermin? 4 that Kuether's insistence on doing things her
5 A No. I shared -- I shared with you earlier what 5 way and her refusal to credit other
6 I shared with them. 6 perspectives delayed the implementation of
7 Q Okay. Did you share with anybody your belief 7 important projects and initiatives?
8 that Debbie Kuether had been a difficult 8 A No.
9 employee? 9 Q Okay. And we're clear that you did tell us
10 A How would I make that statement when I have not 10 this -- basically, these exact same allegations
11 supervised her? 11 earlier today; right?
12 Q I understand. Do you have -- can you account 12 A I shared with --
13 for any way on how this statement got into the 13 MS. MCLEROY: I'm going to object,
14 James Carrol report stating, "From Posley's 14 misstates his testimony.
15 perspective, Kuether had been a difficult 15 Go ahead.
16 employee for some time"? 16 THE WITNESS: I shared with you who I
17 MS. MCLEROY: Objection, calls for 17 discussed Kuether with.
18 speculation, lack of foundation. 18 BY MR. HITCHCOCK:
19 Go ahead. 19 Q Right.
20 THE WITNESS: Can't speculate. I 20 A And those are the only individuals that I've
21 have no clue. 21 talked to.
22 BY MR. HITCHCOCK: 22 Q Okay. And of those individuals, you didn't
23 Q You have no idea. Okay. And did you ever tell 23 tell them that -- what I just had read out?
24 anybody that Dr. Kuether had demonstrated 24 A No.
25 aggressive and confrontational interactions 25 Q Okay. I understand that. So that's -- what

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1 I'm trying to understand then is -- I guess we 1 MS. MCLEROY: Same objection.
2 will leave it. It also says, Posley notes that 2 BY MR. HITCHCOCK:
3 he had made the decision to reassign Kuether 3 Q That you made the decision to reassign Kuether
4 when her behavior and attitude did not improve 4 when Kuether's behavior and attitude did not
5 following the September 2nd meeting with 5 improve following the December 2nd meeting with
6 Saffold. Is that a true statement? 6 Saffold?
7 MS. MCLEROY: I'm sorry, where are 7 A Are we going back and forth with meetings with
8 you reading that? 8 which meeting she had with Saffold? I --
9 MR. HITCHCOCK: Bottom of that 9 Saffold wasn't there to tell me about this
10 paragraph there. 10 meeting and then the next meeting. None of
11 THE WITNESS: This page here? 11 that stuff happened.
12 BY MR. HITCHCOCK: 12 Q Got it. And so -- I mean, you would say this
13 Q Uh-huh. 13 is a false attribution to you; right?
14 MS. MCLEROY: Paragraph at the 14 MS. MCLEROY: I'm going to object,
15 bottom. 15 lacks foundation, calls for speculation,
16 I will just put on the record an 16 misstates his prior testimony.
17 objection to foundation as to commenting on 17 THE WITNESS: I've testified earlier
18 someone else's report. 18 that my beliefs are what I've said around this.
19 THE WITNESS: I go back to my 19 BY MR. HITCHCOCK:
20 original statement. 20 Q Okay. And it's possible that I may be missing
21 BY MR. HITCHCOCK: 21 it, so I'm going to try to ask it this way.
22 Q You never told anybody that this -- first of 22 Between the dates -- I guess, let's put it this
23 all, let's be clear. Is this something that 23 way. There was only one day, and that is
24 you believe to be true, that sentence there? 24 towards the end of November where you learned
25 A Read the sentence. 25 of the issues that Dr. Kuether was alledgedly
Page 258 Page 259
1 preventing work from getting done, and that's 1 A No. She didn't tell me they had gone to
2 when he made the decision? 2 mediation. She just said that we have tried
3 MS. MCLEROY: I'm going to object, 3 all of the things that I have suggested.
4 misstates prior testimony. 4 Q Okay. Now --
5 Go ahead. 5 A She didn't say they went to mediation.
6 THE WITNESS: I had learned earlier 6 Q When Saffold started, it's my understanding
7 that -- that they couldn't get meetings going 7 that she got a raise pretty quickly after
8 forward and things of this nature. But that 8 starting; is that true?
9 was something that was shared at the table by 9 MS. MCLEROY: I'm going to object to
10 Dr. Saffold at another time. But this is the 10 the relevance.
11 time when I was -- that particular day in 11 Go ahead.
12 question is when all of the different things 12 THE WITNESS: I would say to you that
13 when I questioned about have you worked with 13 I am aware that she received an increase
14 HR, have you approached the mediation, have 14 because of compression issues within the
15 ya'll sat down together, those kinds of things, 15 department.
16 when I troubleshooted through that. 16 BY MR. HITCHCOCK:
17 BY MR. HITCHCOCK: 17 Q What does "compression issues" mean?
18 Q Okay. Now I got it. And what was the results 18 A That means that we got individuals that had a
19 of your troubleshooting? 19 situation with salary compression. When people
20 A What was the results? 20 who come from the outside versus individuals
21 Q Right. You said they -- 21 who have been there. If they was on the
22 A She said -- she just said that none of this has 22 outside and they had much a higher salary, they
23 worked. 23 got -- they came in at a higher level versus
24 Q Got it. Well, but did she tell you that they 24 somebody that had been in the district and
25 had gone to mediation? 25 worked their way up. Or if there's somebody

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1 that can work a different way because if 1 Q Okay. And they won't happen unless you
2 somebody came from the outside of the district 2 recommend them; right?
3 and had a much lower salary, they are below all 3 A That's correct.
4 of the people that they supervise. 4 MS. MCLEROY: Objection, vague.
5 So any time there is a compression 5 BY MR. HITCHCOCK:
6 issue with salary, it is they -- they work it 6 Q Now, during your history with working with
7 through human resources, and they brought it to 7 Dr. Kuether, had you ever known her to be
8 me, and I carried it forward to the Milwaukee 8 aggressive?
9 board of supervisors. 9 MS. MCLEROY: Objection, vague.
10 Q Who brought it to you? 10 THE WITNESS: Not towards me, I have
11 A HR. 11 not, so I can't speak for anyone -- anyone
12 Q And not Saffold? 12 else.
13 A No. Saffold -- HR is the one who presented it 13 BY MR. HITCHCOCK:
14 to me. 14 Q Well, how about confrontational?
15 Q Okay. Did you ever discuss the compression 15 MS. MCLEROY: Same objection.
16 issue with Saffold? 16 THE WITNESS: She had never been
17 A Not that I'm aware. Not that I remember. 17 confrontational towards me.
18 Because I don't do anything with salaries. 18 BY MR. HITCHCOCK:
19 That's something that is worked out through HR. 19 Q Okay. And, in fact, you knew Dr. Kuether's
20 And any salary has to be approved by the 20 work was excellent; right?
21 Milwaukee Board of School Directors. I can't 21 MS. MCLEROY: Objection, asked and
22 just go around giving out salary increases. 22 answered.
23 Q Okay. But you can go around recommending 23 THE WITNESS: I shared with you
24 salary increases; right? 24 earlier that I can't supervise and did not
25 A I can recommend. 25 supervise Dr. Kuether's work at any time during
Page 262 Page 263
1 my tenure of knowing her. 1 Q And on -- from that basis, did you form an
2 BY MR. HITCHCOCK: 2 opinion?
3 Q I understand that. Did you not ever form a 3 MS. MCLEROY: Same objection.
4 basis on her work product at any time? 4 THE WITNESS: That she was
5 A Did I ever form a basis? 5 responsible for what -- as far as what the
6 Q Uh-huh. A basis of understanding. 6 curriculum part of whatever she had to deliver
7 A It just depend on who was superintendent at 7 at that particular time, she delivered it.
8 that particular time. We had a number of 8 BY MR. HITCHCOCK:
9 iterations of curriculum design, departments, 9 Q Oh, okay. And that meant your work -- your
10 and we had worked in a number of different 10 expectations?
11 ways. So there was times that we presented to 11 A I didn't have an issue with it, but she was
12 principals and we had a C&I person on the team 12 supervised by someone else.
13 and -- so it just varies. 13 Q I got it. Did you work with Dr. Kuether in the
14 Q Okay. So sitting here under oath, you are 14 Washington cluster?
15 telling us that you -- over at least 28 years 15 A Washington cluster? Washington cluster? For
16 of working with Dr. Kuether that you didn't 16 this -- the high schools? I can't --
17 form an opinion on her work product. Is that 17 Washington cluster. Back in the day -- I have
18 fair? 18 to -- I need to have a little more relevance of
19 MS. MCLEROY: Objection, misstates 19 what you are referring to. Who was
20 his prior testimony, asked an answered, also 20 superintendent at the time? Is this
21 speculation. 21 Andrekopoulos? I don't know. I'm just -- I
22 THE WITNESS: Like I said, I've never 22 can't -- I am not saying I didn't, but like I
23 supervised Dr. Kuether, but I have worked with 23 said, I worked with Dr. Kuether. I just don't
24 Dr. Kuether over the years. 24 know what year, when it was and all of those
25 BY MR. HITCHCOCK: 25 kinds of things.

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1 Q How would the year help you identify whether or 1 Q Okay. So from what that perspective -- from
2 not you worked with Dr. Kuether in the 2 your perspective, the allegations that Saffold
3 Washington cluster? 3 made were unusual. Fair?
4 A Well, whoever it was that was superintendent 4 MS. MCLEROY: Objection, calls for
5 would help me. 5 speculation, lacks foundation.
6 Q And why? 6 THE WITNESS: I wouldn't say it was
7 A Because I would know kind of what we did and 7 unusual. I've heard all kinds of things before
8 kind of -- have some kind of overall 8 around staff and what happens.
9 understanding of what we had to do. 9 BY MR. HITCHCOCK:
10 Q Okay. Did you feel that Saffold's allegations 10 Q And did you investigate those all kinds of
11 with Dr. Kuether were commensurate with your 11 things or something else?
12 existing understanding of Dr. Kuether? 12 A I don't -- it depend on what it was. It would
13 MS. MCLEROY: I am going to object, 13 depend on was it for me to investigate, was I
14 vague, calls for speculation. 14 the immediate supervisor. If I was the
15 THE WITNESS: Did I feel that what 15 immediate supervisor, yes.
16 she had to say was -- the Dr. Kuether that I 16 Q Did it depend on the race of the person being
17 knew? 17 investigated?
18 BY MR. HITCHCOCK: 18 A Absolutely not.
19 Q For example, I used the word "commensurate," 19 Q Okay. And -- but you don't dispute that you
20 but, yeah, that will work. 20 didn't benefit from any investigation into the
21 A You know, honestly, at that particular time, 21 allegations of Dr. Kuether; right?
22 I -- from when I worked with Dr. Kuether over 22 A I don't benefit? How would I benefit?
23 the years, she had never -- she had never did 23 Q Well, you didn't read them, for example.
24 that to me. So I can speak from that 24 A You asked me did I read all --
25 perspective. 25 Q Any investigation into any allegation --
Page 266 Page 267
1 A I have not read any investigations of 1 A Never.
2 Dr. Kuether. 2 Q Okay. The phone number (XXX) XXX-XXXX, do you
3 Q Got it. 3 recognize that number?
4 A Everything you are showing me is new 4 A Not off -- I think it sounds like Holiday's
5 information. 5 number. An old number.
6 MS. MCLEROY: Are you still doing 6 MS. MCLEROY: To the extent it's
7 good? Do you need a break? 7 personally identifying any information, I'd
8 THE WITNESS: I'm good. 8 rather it not be in the transcript. Can we --
9 MR. HITCHCOCK: Do you want a break? 9 MR. HITCHCOCK: I don't have any
10 MS. KOLBERG: We're good. 10 objection to that.
11 MS. MCLEROY: No, I'm fine. I was 11 MS. MCLEROY: Okay. Thank you.
12 just checking. 12 MR. HITCHCOCK: Just to go off the
13 BY MR. HITCHCOCK: 13 record here for a second.
14 Q Did ever tell any board members that you were a 14 (Discussion off the record.)
15 soldier for the board? 15 MS. KOLBERG: Standby. We are going
16 A No. 16 off the record. The time is 2:32. This is the
17 Q Okay. If Tony Baez said that you did, would 17 end of media unit number three.
18 that be incorrect? 18 (Recess.)
19 A That is incorrect. 19 THE VIDEOGRAPHER: The time is
20 Q Did you have any direct communications with 20 2:47 p.m. This is the beginning of media unit
21 Dr. Kuether at all? 21 four.
22 A Me? 22 BY MR. HITCHCOCK:
23 Q You. 23 Q Dr. Posley, at some point when you were
24 A No. 24 superintendent, Dr. Holiday was charged with
25 Q You never text message -- text her? 25 assault and battery on Dr. Kuether; is that

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1 true? 1 Q Okay. Did you ever discuss the matter with
2 MS. MCLEROY: I'm sorry, can you read 2 him?
3 that question again? 3 A No.
4 (Record read.) 4 Q Okay. How about -- well, do you know what
5 MS. MCLEROY: I'm going to object as 5 happened on that day?
6 irrelevant and charging is admissible to 6 A The only thing that I -- it's all speculation
7 nothing. 7 and hearsay. That Dr. Kuether was in his
8 If you know, go ahead. 8 office for some various reason. Why, I don't
9 THE WITNESS: I don't know about 9 know. And he asked that the police be called.
10 charges. I know the police was involved. 10 Q Okay. Did you -- I guess I want to be clear.
11 BY MR. HITCHCOCK: 11 Did you discuss this -- we will just call it an
12 Q Okay. Do you know -- how do you know that the 12 incident -- with Dr. Holiday at any time?
13 police were involved? 13 A Not that I remember.
14 A How do I know that? 14 Q Okay. Did you give any direction to
15 Q That's right. 15 Dr. Holiday regarding how to move forward after
16 A Is because the secretary said the police out on 16 that at any time?
17 the floor and the police was over in the -- 17 MS. MCLEROY: Objection, vague.
18 that area. 18 Go ahead.
19 Q Okay. Did you -- any other way that you 19 THE WITNESS: Move forward with
20 learned about any allegations against 20 Dr. Kuether?
21 Dr. Holiday? 21 BY MR. HITCHCOCK:
22 A That is pretty much it. 22 Q Uh-huh.
23 Q Okay. Did you learn whether or not he had a 23 A Not that I remember. He never come and talked
24 trial of any kind? 24 to me about anything like that.
25 A I -- that I don't know. 25 Q I got it. Did you direct Dr. Holiday or
Page 270 Page 271
1 anybody else to make any changes to the way 1 A There's like an A hold [sic], and the
2 that public access -- or, sorry. I'm going to 2 superintendent's conference room is like this,
3 start that question over. Did you direct any 3 this office of suites is here, the office you
4 MPS employees to change the way that access to 4 are talking about is back here.
5 the C&I program is open to the public? 5 Q Okay. Was there ever a security guard that sat
6 A C&I? 6 outside your office while you were the
7 Q Uh-huh. Curriculum instruction. Did they -- 7 superintendent?
8 is there an area where C&I works from? 8 A Yes.
9 A There's a department down on the other end of 9 Q Was that the entire time that you were
10 the building, yes. 10 superintendent?
11 Q Okay. How about 214? Do you know where room 11 A Not the entire time. I'm just trying to figure
12 214 is? 12 out -- I can't recall was that person there
13 A 214 is the suite where the office of the school 13 before I got there, or did that person come
14 administration is on the end of the -- the last 14 afterwards, but that was a person out there.
15 door. 15 Q Okay. Was there a time that there wasn't a
16 Q On the east side of the building? 16 security guard out there?
17 A Yeah. 17 A Yes.
18 Q Okay. And you are on the north side of that 18 Q When was that?
19 building when you were the superintendent; 19 A That was I know under -- few years back.
20 right? 20 Q Okay. Was this before or after Dr. Kuether
21 A I'm directionally challenged. 21 started making publics complaints about MPS?
22 Q Fair enough. 22 A Just like a said, I don't know when she
23 A But I'm right beside that -- the superintendent 23 started.
24 conference room is right beside that. 24 Q Okay. Did you -- you have a communications
25 Q Okay. And there's -- 25 officer; is that true?

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1 A Yes. 1 Dr. Kuether had been in the news at any time?
2 Q And you created that position; right? 2 A No. As my memory serves me correctly, no.
3 A That's correct. 3 Q Okay. So they didn't -- they never told you
4 Q Okay. What is the -- are the duties of the 4 about any of the -- let's see. Did they ever
5 communications officer? 5 tell you when Dr. Kuether was on TV news at any
6 A Communication officer's responsibility was the 6 time?
7 charter schools. All of the charter schools, 7 A No, not that I remember. The only thing that I
8 and then also the external communications, 8 remember was you all's talk show. Someone
9 notices to families, and upkeeping the webpage, 9 brought that to me one time, but I've never
10 the home page, and those kinds of things. 10 seen it.
11 Q How about media? Does that person have any -- 11 Q Okay. Who brought that -- the talk show to
12 A That person helps with me. There's a -- 12 you?
13 there's a director over that department. 13 A One -- I want to say, it had to be -- I'm
14 Q Okay. And what does a director do? 14 trying to think of her name. She just -- my
15 A That director does all of that particular work, 15 last director that I just had. I would have to
16 and that director is the person that produces 16 check whoever the last director was of
17 the work. 17 communications is the person that --
18 Q Okay. Did they alert you of new stories about 18 Q Okay. And was -- she brought this to your
19 MPS? 19 attention while you were the superintendent?
20 A Yes. If it's something that is going to be on 20 A Yes.
21 the news, that's the reason they both was 21 Q Okay. And you were working as the
22 direct reports. 22 superintendent at that time?
23 Q To you? 23 A Working as the superintendent. I shared at
24 A Yes. 24 that time with her I don't care, don't want to
25 Q Okay. Did they tell you of whether or not 25 see it, don't want to know anything about it.
Page 274 Page 275
1 They can do whatever they like. 1 Q Now, you kept Dr. Holiday in his position
2 Q Oh, okay. 2 despite the charges against him; right?
3 A Yeah. 3 MS. MCLEROY: I'm going to object,
4 Q And what were they -- what did -- what was it 4 vague, irrelevant. And you are talking
5 that we like to do? 5 November 8th of 2022 as opposed to the prior?
6 A No. I'm just saying the idea that apparently 6 I guess I'm not sure "charges."
7 you all had something on your show about me 7 BY MR. HITCHCOCK:
8 sending a letter or having my attorney to send 8 Q Okay. Are you -- you are telling me -- I
9 a letter to someone, or whatever the situation 9 guess, let's be clear. Were you aware of the
10 was. I told her that time that I don't -- I 10 fact that there was charges against
11 did not care, don't inform me any further about 11 Dr. Holiday? I thought the answer was yes?
12 anything that they are doing, that you all were 12 A What do you mean "charges"? Charges on what I
13 doing, it didn't bother me, they can continue 13 shared with you earlier, what I was aware of
14 to do whatever they like. 14 that on the night that I asked for a promotion
15 Q Got it. So were you ever made aware by the 15 of Dr. Holiday, board members said that they
16 media specialist -- 16 had received information. I never got the
17 A Nicole is her name. 17 information.
18 Q Nicole. 18 Q Right. No. What I'm talking about is that you
19 A Nicole. 19 explained to us, as I understood it, that your
20 Q And I belive it's Armendariz? 20 secretary told you that there were police in
21 A Armendariz, yeah, correct. 21 the building.
22 Q Okay. So did you make -- did she ever make you 22 A Oh, you are talking about -- now we're talking
23 aware of any of the newspaper articles that 23 about the situation with -- what case are you
24 Dr. Kuether was featured in? 24 talking about? You are talking about which
25 A No. 25 case here?

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1 Q Well, so -- okay. Dr. Kuether comes to serve 1 Q Okay. And was Dr. Kuether an employee of MPS
2 Dr. Holiday, and serves Dr. Holiday. Are you 2 at that time?
3 aware of that fact? 3 A As far as I know. I don't know what her status
4 A I didn't know what a purpose was there for. I 4 was at that time. I don't know.
5 just know that apparently she was down in his 5 Q So she would have had access to presumably room
6 office. Don't know why she was there or 6 215 at that time. Is that fair? 214.
7 whatever the situation, and the police had been 7 MS. MCLEROY: Objection, lacks
8 called. The reason the police was there. 8 foundation, incomplete hypothetical, vague.
9 Q And what was the reason that the police were 9 Go ahead.
10 there? 10 THE WITNESS: It would be totally
11 A That Dr. Holiday asked for the police to be 11 speculation. I -- I don't have the details
12 called because apparently Dr. Kuether had came 12 there to tell you that.
13 to his office or entered his office or 13 BY MR. HITCHCOCK:
14 something. 14 Q Okay. And then do you know if Dr. Kuether was
15 Q Okay. And what's wrong with Dr. Kuether 15 banned from central office after that?
16 entering Dr. Holiday's office? 16 A Banned. I never heard that before.
17 MS. MCLEROY: I'm going to object as 17 Q Okay.
18 incomplete hypothetical. 18 A Because she was at meetings.
19 Go ahead. 19 Q Okay. How about the second floor? Was she
20 THE WITNESS: I have no clue, unless 20 ever banned from the second floor, if you know?
21 she was invited. You know, people just don't 21 A I don't know anything about her being banned
22 go and come into your office, unless somebody 22 from the second floor.
23 asks you to come up to your -- their office or 23 Q Fine. Let me ask you this. Are you aware of
24 whatever the situation may be. 24 any changes in the practices of the Milwaukee
25 BY MR. HITCHCOCK: 25 Public Schools after Dr. Kuether served
Page 278 Page 279
1 Jeremiah Holiday? 1 THE WITNESS: I would just say I --
2 MS. MCLEROY: Objection, vague, 2 as far as just like -- just like I shared with
3 assumes facts not in evidence. 3 you, if he did, I don't remember it, right.
4 Go ahead. 4 BY MR. HITCHCOCK:
5 THE WITNESS: The only thing I know, 5 Q So have you seen the trial testimony of
6 that they directed them to come through one 6 Dr. Holiday?
7 door. 7 A Trial testimony, no, I have not.
8 BY MR. HITCHCOCK: 8 Q Okay. Did you talk to him about the trial
9 Q Okay. And who is "they"? 9 after it happened?
10 A The -- that whole side. I guess it was someone 10 A After it happened? No. I don't know when it
11 on that side. It would have to be possibly 11 happened. You have to -- that's a hypothetical
12 Dr. Cotton or whatever the situation was or 12 because I don't know when the trial happened or
13 whomever. I don't know. I just know that you 13 any of those kinds of things. So don't know.
14 cannot come through multiple doors and just go 14 Q But it's your testimony that nobody told you at
15 -- you have to come through the main door and, 15 MPS and that you -- that Dr. -- the city of
16 yeah, get buzzed in the main door. 16 Milwaukee had charged Dr. Holiday with assault
17 Q And you didn't make that decision; right? 17 and battery based on his interaction with
18 A No, I didn't make that decision. 18 Dr. Kuether; is that true?
19 Q Got it. If Dr. Holiday testified under oath 19 MS. MCLEROY: I'm going to object to
20 that he discussed the incident with you, would 20 vague, foundation.
21 he be lying or something else? 21 Go ahead.
22 MS. MCLEROY: I'm going to object, 22 THE WITNESS: There was a city
23 assumes facts not in evidence, lacks 23 attorney that -- and that I do know that --
24 foundation, calls for speculation. 24 Is that privileged information with
25 Go ahead. 25 the city attorney?

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1 MS. MCLEROY: Oh, yeah. 1 THE WITNESS: Read the question
2 Conversations with the city attorney would be 2 again. Excuse me.
3 attorney-client privilege. 3 (Record read.)
4 BY MR. HITCHCOCK: 4 THE WITNESS: No one from MPS? You
5 Q Well, let's wait on what happened. I don't 5 said no one from MPS?
6 need to know what the person said. 6 BY MR. HITCHCOCK:
7 Woah, woah, woah. Excuse me. 7 Q That's right, MPS.
8 I don't know -- need to know what was 8 A My information came from the city attorney's
9 said, but I do need to know who this person 9 office.
10 was? 10 Q Okay. Who at the city attorney gave you this
11 MS. MCLEROY: I'm sorry, for what 11 information?
12 purpose? 12 A I don't remember, but it was someone of the --
13 MR. HITCHCOCK: Because I asked the 13 whoever that was in charge at that particular
14 question. 14 time that was covering the school district.
15 MS. MCLEROY: Can I have the question 15 Q Where were you when you got this information?
16 back? 16 A It was in my office.
17 (Record read.) 17 Q Okay. Did they tell you other -- anything
18 MS. MCLEROY: I don't think we need 18 other than he had been charged?
19 to know who the city -- the conversations. You 19 MS. MCLEROY: That is attorney-client
20 want to know somebody at the city attorney's 20 privilege. We are not going to discuss the
21 office? 21 conversation.
22 BY MR. HITCHCOCK: 22 BY MR. HITCHCOCK:
23 Q Well, first, can we get the answer to the 23 Q I'm not asking for the conversation. I'm just
24 question I posed? So let's start with that for 24 asking, was there anything else that was spoken
25 the record. 25 -- communicated about other than the fact that
Page 282 Page 283
1 he was charged? 1 Q Okay. About when did this conversation take
2 A That's all I remember. 2 place?
3 Q Okay. Was there anybody else at this meeting? 3 A When? I'm not sure. I -- I don't remember.
4 A No. 4 Q Okay. And so just so I have what I understand
5 Q Who initiated the meeting? 5 correctly, a city attorney called you and told
6 MS. MCLEROY: I'm going to object to 6 you that Dr. Holiday had been charged, and
7 the extent "meeting." There's no foundation to 7 nothing else. Fair?
8 that, vague. 8 A It wasn't the idea that he was -- I thought
9 Go ahead. 9 that the -- I don't remember exactly what -- I
10 THE WITNESS: There wasn't -- there 10 don't -- I don't --
11 was a phone call. 11 MS. MCLEROY: The content of the
12 BY MR. HITCHCOCK: 12 communication from the city attorney is
13 Q Who initiated the phone call? 13 attorney-client privilege.
14 A They called me. They called me. 14 THE WITNESS: Okay.
15 Q Why did you take the call? 15 MS. MCLEROY: The fact that he
16 MS. MCLEROY: Objection, calls for 16 called, he's already giving you that
17 speculation, irrelevant. 17 information, or he or she.
18 BY MR. HITCHCOCK: 18 BY MR. HITCHCOCK:
19 Q Do you know why you took the call? 19 Q Okay. And -- but I will just read out there --
20 A I took the call -- any time the city attorney's 20 recall what I remember of the conversation or
21 office called me, I would take the call. 21 the question that's in front of you, and I
22 Q Okay. So then that's not speculation; right? 22 believe it's simply this. A city attorney
23 MS. MCLEROY: Harassment at this 23 contacted you, you took the phone call, the
24 point. 24 city attorney told you that Dr. Holiday had
25 BY MR. HITCHCOCK: 25 been charged with a crime against Dr. Kuether,

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1 and nothing else. Is that fair? 1 MS. MCLEROY: Asked and answered.
2 MS. MCLEROY: I'm going to object, 2 THE WITNESS: No.
3 misstates the testimony. 3 BY MR. HITCHCOCK:
4 But go ahead on that limited basis. 4 Q Okay. I'm going to read to you from page 9 of
5 THE WITNESS: I don't -- I think what 5 Jeremiah Holiday's rebuttal to his -- to the
6 I was told that he was being called in and 6 position statement of the ERD complaint.
7 about a citation or something of that nature, 7 MS. MCLEROY: What exhibit is this?
8 so I don't -- that's the gist of what I have. 8 BY MR. HITCHCOCK:
9 BY MR. HITCHCOCK: 9 Q I don't know that it's an exhibit. It says,
10 Q Got it. Okay. And you didn't -- it's also -- 10 the white woman complained about the leadership
11 did you ever start a formal investigation into 11 of a black man because they don't want to be
12 the allegations of Jeremiah Holiday into race 12 asked to do their job and don't want to be held
13 discrimination? 13 accountable for their performance in the worst
14 MS. MCLEROY: Can I have that back? 14 district in the state and arguably the nation.
15 (Record read.) 15 Now, did you ever discuss complaints from white
16 MS. MCLEROY: Asked and answered. 16 women about the leadership of a black man with
17 Go ahead. 17 Jeremiah Holiday?
18 THE WITNESS: Yeah. I've already 18 MS. MCLEROY: Objection, reading from
19 answered that one, and I shared with you that 19 a document without any authenticity or
20 this was done and complete when it came to me. 20 foundation for this witness, out of context, is
21 The investigation had already been conducted. 21 a complete hypothetical -- an incomplete
22 BY MR. HITCHCOCK: 22 hypothetical, calls for speculation, and an
23 Q And so then I think I'm expounding on that. 23 improper foundation to a question.
24 And I'm trying to find out if you had initiated 24 Do you understand the question? Are
25 any further investigation? 25 you able to answer it?
Page 286 Page 287
1 THE WITNESS: It calls for all 1 THE REPORTER: Do you want --
2 speculation, and I'm not able to answer it 2 MR. HITCHCOCK: Sure. It seems to be
3 because I shared with you earlier all of the -- 3 not my deposition.
4 what I received. 4 (Record read.)
5 BY MR. HITCHCOCK: 5 THE WITNESS: I have shared with you
6 Q Okay. So -- and I don't know that I asked you 6 earlier, and I'll do it again, that I did not
7 this straight out. But you never learned that 7 receive this document. It was not shared with
8 Jeremiah Holiday has alleged that white women 8 me.
9 complained about the leadership of a black man 9 BY MR. HITCHCOCK:
10 because they don't want to be asked to do their 10 Q I understand that. My question and more
11 job. Is that a true statement? 11 broadly is that whether or not you received
12 MS. MCLEROY: Again, object to the 12 this document and whether or not it was shared
13 reading from an unauthenticated, lack of 13 with you. Have you ever learned that Jeremiah
14 foundation to this witness document that is 14 Holiday had complained that white women -- or
15 completely unfounded for him to provide an 15 that he had alleged that white women were
16 answer, calls for speculation. 16 complaining about the leadership of a black
17 Go ahead and answer to the extent you 17 man?
18 can. 18 MS. MCLEROY: Same objection, assumes
19 THE WITNESS: And could you re-ask 19 facts not in evidence.
20 the question? 20 THE WITNESS: And I can say that
21 BY MR. HITCHCOCK: 21 Jeremiah Holiday, Dr. Holiday has never
22 Q Sure. 22 complained to me about such.
23 MS. MCLEROY: Do you want it read 23 BY MR. HITCHCOCK:
24 back? 24 Q Okay. I also see that Dr. Holiday says, the
25 THE WITNESS: Yeah. 25 actions of Keith Posley and the Milwaukee Board

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1 of School Directors was not based on 1 A No.
2 performance, but was purely rooted in racism 2 MR. HITCHCOCK: Okay. Can you play
3 and discrimination fueled by resentment towards 3 the video?
4 me from MTEA of subordinate individuals 4 MS. KUETHER: Yeah.
5 unwilling to be held accountable for their 5 MR. HITCHCOCK: So what I propose to
6 work. Did Dr. Holiday raise any complaints to 6 do is this. We have some videos of board
7 you about people at MTEA? 7 meetings here that are publicly available --
8 MS. MCLEROY: Objection to the lack 8 oh, I think we are going to do the trial first.
9 of authenticity of the document from which you 9 So my proposal is to not have the reporter take
10 are reading, and you are not showing in context 10 any down -- any -- anything --
11 to the witness, lack foundation as to this 11 MS. MCLEROY: I'm not comfortable
12 witness, calls for speculation, assumes facts 12 with that.
13 not in evidence, calls for speculation. 13 MR. HITCHCOCK: Okay. Do you have an
14 Answer to the extent you can. 14 alternative proposal?
15 THE WITNESS: I can share with you 15 MS. MCLEROY: Well, this -- how is
16 that just like all of my chiefs had situations 16 this going to be a record? I mean, how were
17 where they had to work with the MTEA. And 17 you planning on having this produced as a
18 Dr. Holiday, just like anyone else, you know, 18 record?
19 the MTEA had shared with me that I didn't get 19 MR. HITCHCOCK: Well, so, first of
20 this or I didn't get that. And that's for all 20 all, we got the trial, and so that's an exhibit
21 of my chiefs. 21 that we have and that we've been produced to us
22 BY MR. HITCHCOCK: 22 by the city of Milwaukee. And the second
23 Q Okay. Did Calvin Fermin ever share with you 23 things are all public board meetings, excuse
24 that he had assisted Jeremiah Holiday in 24 me, that have been produced and directed to us
25 drafting his ERD complaint against you? 25 -- when we asked for the originals or whatever
Page 290 Page 291
1 else, we were instructed by your colleague to 1 MR. HITCHCOCK: Well, I guess the
2 go look at the ones online. So that's what we 2 alternative of that would be to --
3 are talking about now. 3 MS. MCLEROY: I mean, I don't -- I
4 MS. KOLBERG: The question -- the 4 don't know what you are playing. I don't know
5 question here is when we need to reference what 5 if you are playing 20 minutes of something, I
6 exactly got played at what time, from what 6 don't know if you are playing, you know,
7 location, where, and have an original copy of 7 something out of context, a minute or two here
8 it, where is that going to be? Where is that 8 or there. It needs to somehow make it into
9 contained in the record? Like where is the 9 this record is what I'm saying.
10 file actually going to be? 10 MR. HITCHCOCK: Okay. I understand.
11 MR. HITCHCOCK: Right. Well, so we 11 If that's how you want to proceed, then let's
12 asked you for that actual record, and instead 12 proceed that way. I can't think of an -- I
13 of producing that, you produced links and said 13 mean, we have the document.
14 that the document speaks for themselves. 14 Can you not start that yet?
15 MS. KOLBERG: Yeah. Now you have the 15 MS. KUETHER: I have not.
16 files, so it's your responsibility to get them 16 MR. HITCHCOCK: We have the document
17 into the record somehow. We have to replicate 17 -- or the video there online. That's where you
18 what happened here today somehow. 18 directed us to it. I do understand that online
19 MS. MCLEROY: We need -- yes. Is 19 videos are not static, and the issue that I
20 this being marked as an exhibit? 20 think you are referring to is the need to have
21 MR. HITCHCOCK: No, I don't think so. 21 a static video. And I don't necessarily
22 I think I am just going to show it to him. 22 dispute that, I was -- I am trying to work
23 MS. KOLBERG: Well, then we need a 23 around that for ease of everybody involved, but
24 transcript of what goes down. 24 if that's what we need to do, then that's what
25 MS. MCLEROY: Yeah. 25 we need to do.

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1 MS. MCLEROY: Well, one of the things 1 by the city or going to be produced the city
2 you could do is -- have you downloaded it so 2 attorney -- city. They did then produce that,
3 it's not that it's static? I mean, I don't 3 and that's the copy that we have. So hopefully
4 know -- 4 that will be -- they also, I understand,
5 MR. HITCHCOCK: Yes, I have a 5 provided an identical copy to you. So that is
6 discrete copy of this document. 6 the exhibit that I'm talking about.
7 MS. MCLEROY: So you have your own 7 This next exhibit that we're talking
8 copy? 8 about --
9 MR. HITCHCOCK: That's right. 9 MS. MCLEROY: Well, let me first
10 MS. MCLEROY: So that copy can be 10 respond to the first. Your recitation of the
11 made apart of the record as an exhibit, and you 11 facts are not entirely accurate, but that's
12 put down what time frame to what time frame you 12 fine, we will mark it. I would -- I will make
13 are doing, and we get provided with the same 13 an objection at the time to his ability to
14 thing. 14 watch someone else's trial. And I want the
15 MR. HITCHCOCK: Fantastic. The first 15 record to reflect what part, from what minute
16 document that we're talking about is the -- 16 to what minute is being shown.
17 MS. MCLEROY: Well, you can lay a 17 MR. HITCHCOCK: Okay. And but to be
18 foundation when we get -- when you do it. 18 clear, Michael Sherer, your colleague, filed a
19 MR. HITCHCOCK: Thanks, but kindly 19 motion stating that we couldn't get this
20 don't interrupt me. The first document that we 20 document, and then filed another letter with
21 are going to put out there is the trial of 21 the court saying that he was never aware
22 Jeremiah Holiday. Now, we have extensive 22 that -- that this was going to be made public.
23 litigation over that, and I believe that you 23 But unfortunately, the day before he filed that
24 guys opposed the production of that, but 24 with the court, Mr. Peter Block from the city
25 ultimately, even knowing that it was produced 25 attorney's office had made him aware because he
Page 294 Page 295
1 had copied them on that document. So let's -- 1 here.
2 I think that should be cleared up now. 2 MS. MCLEROY: He was going to go to
3 MS. MCLEROY: Well -- well -- and 3 the next number here. I don't know. Are you
4 let's -- if you want to go back, you served a 4 going one by one or are you telling us the
5 subpoena without copying the other side. We 5 whole --
6 learned about in subpoena, so we are coming -- 6 MR. HITCHCOCK: We are going to start
7 trying to come up to the fact. We were not 7 with the Holiday --
8 identified as to when this was going to be 8 MS. MCLEROY: Okay.
9 produced, weren't sure at what point. There 9 MR. HITCHCOCK: -- and we'll go from
10 was a lot of moving -- moving wheels at that 10 there.
11 point. So it started with your serving a 11 MS. MCLEROY: For the record, on the
12 subpoena without copying opposing counsel as is 12 Holiday, there was apparently a municipal trial
13 required under the rules. 13 on a citation given to Jeremiah Holiday of
14 MR. HITCHCOCK: I don't know that 14 which there was a municipal trial of which
15 that would, you know, change anything that I -- 15 there was a finding of not guilty. To the -- I
16 MS. MCLEROY: Well. 16 would say that there is -- you need a witness
17 MR. HITCHCOCK: -- a duty that one 17 to authenticate it should we get to trial, and
18 would have to make appropriate representations 18 there's no foundation as to this.
19 and accurate representations from the court, 19 THE REPORTER: Clarification. You
20 but maybe it does. Are we ready to ready to 20 don't want me to take down the video because
21 proceed along the lines that we've discussed? 21 it's marked as an exhibit now?
22 MS. KOLBERG: Well, just objections 22 MS. MCLEROY: Not if it's marked as
23 to the relevance -- 23 an exhibit and he identifies what minute to
24 MS. MCLEROY: Well, yeah. 24 what minute.
25 MS. KOLBERG: -- and the reality 25 MS. KOLBERG: So this will be Exhibit

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1 Number 11. 1 disc?
2 MR. HITCHCOCK: Thank you. 2 MS. KUETHER: It is, but we're not --
3 (Exhibit No. 11 was marked.) 3 I'm not giving that away. I will let them make
4 MS. KUETHER: It's part of what they 4 a copy of that. This is the authentication
5 produced. 5 right here.
6 MS. MCLEROY: Can you see? 6 MR. HITCHCOCK: Got it. Do we have a
7 MR. HITCHCOCK: Okay. So this here 7 copy of this?
8 is a discrete document. It is entitled here, 8 MS. KUETHER: Yes. I have all the
9 it says, Holiday explains to the police how the 9 e-mails and the subpoenas.
10 door is usually open. And I'm starting it here 10 MR. HITCHCOCK: Well -- okay. So I
11 at -- it's 18 seconds long, and I'm starting it 11 want to continue with this. If you need to
12 here at 0. 12 make an objection, go ahead and make the
13 MS. MCLEROY: Excuse me. Hold on. 13 objection. I think we can work on
14 MR. HITCHCOCK: Uh-huh. 14 authentication after the fact here.
15 MS. MCLEROY: Is this the trial? You 15 MS. MCLEROY: Well, this is not
16 said this was the trial. 16 authentication, obviously, with this witness.
17 MR. HITCHCOCK: This was produced, as 17 But I -- I don't -- what is this? This is an
18 I understand it, in the exhibits from the 18 exhibit that was shown at the trial?
19 trial. 19 MR. HITCHCOCK: Yes.
20 MS. KOLBERG: So this is a body cam 20 MS. MCLEROY: Okay. Well, what --
21 video? 21 identify the trial and identify what exhibit it
22 MR. HITCHCOCK: That's right. 22 was, if you would.
23 MS. MCLEROY: We need a better 23 MR. HITCHCOCK: Okay. And I don't
24 description of what this is from the trial. 24 have the exhibit number, and I understand the
25 MR. HITCHCOCK: Okay. Is it on this 25 request, and I will try to accommodate this as
Page 298 Page 299
1 best as I can. But I understand that this 1 recognize the voice on that recording?
2 document was produced to us on July 10th of 2 A Yes.
3 2024 by the city of Milwaukee via the police 3 Q Who is that?
4 department. The case, I believe, is 06 -- oh, 4 A Dr. Holiday.
5 it's the city of Milwaukee case 068ITKWX7, I 5 Q Okay. And did he speak about you giving him
6 believe the city of Milwaukee municipal number 6 some instructions?
7 is 223120585, and that there also appears a 7 A He said that the super -- and I'd have to
8 number on this disc that says 2413274. 8 listen to it again, but he said something that
9 MS. MCLEROY: Thank you. 9 the superintendent wanted doors closed.
10 MR. HITCHCOCK: Of course. 10 Q Okay. Would you like to listen to it again?
11 MS. MCLEROY: And do you -- do you 11 A Yes, please.
12 have the ability to tell us what exhibit it was 12 (Whereupon Exhibit 11 was played.)
13 in that trial? 13 BY MR. HITCHCOCK:
14 MR. HITCHCOCK: I don't have the 14 Q Okay. And so, again, that's 1 -- 0 minutes to
15 ability to tell that from this disc right now, 15 18 seconds there. And I heard him say that the
16 no, but I will be happy to clarify that going 16 door is usually open. Did you hear him say
17 forward. 17 that?
18 MS. MCLEROY: And you don't know if 18 MS. MCLEROY: I'm going to object,
19 it's the prosecutor or the defense? 19 the video speaks for itself, calls for
20 MR. HITCHCOCK: I believe it was -- I 20 speculation on this witness.
21 don't know. I don't know. 21 THE WITNESS: Yeah. I understand,
22 (Whereupon Exhibit 11 was played.) 22 yeah.
23 BY MR. HITCHCOCK: 23 BY MR. HITCHCOCK:
24 Q Okay. So do you -- there was a voice -- at 24 Q Okay. And then he also says, from what I
25 least one voice on that recording. Did you 25 understood, that the superintendent gave him

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1 some direction about the door. Did you hear 1 MS. KUETHER: It's audio only.
2 that part? 2 MS. MCLEROY: Okay. And this is
3 A Yes. 3 Exhibit 12, I think?
4 Q Okay. Is that an accurate statement? 4 MR. HITCHCOCK: I think it's 13 is
5 MS. MCLEROY: I'm going to object as 5 the number that I --
6 foundation to this witness knowing Holiday's 6 MS. MCLEROY: Well, I had 11 for the
7 comment, and lack of foundation on the whole 7 trial. It's 12.
8 thing to this witness. 8 MR. HITCHCOCK: 12.
9 Go ahead. 9 (Exhibit No. 12 was marked.)
10 THE WITNESS: Just like I shared with 10 MS. MCLEROY: And what is the audio
11 you earlier about those doors on that side, 11 description?
12 that is not my office. The superintendent 12 MR. HITCHCOCK: It says, "HR chief
13 office doors are closed. 13 advises for employees to defy subpoenas."
14 BY MR. HITCHCOCK: 14 MS. MCLEROY: And is this from the
15 Q Okay. So -- 15 trial as well?
16 A And there's a door that goes right there from 16 MR. HITCHCOCK: Yes.
17 the superintendent's office onto their office, 17 MS. MCLEROY: And it was an exhibit
18 it's closed. So I don't know if he was 18 at the trial as well?
19 referring to that door or what was he referring 19 MR. HITCHCOCK: That's my
20 to. 20 understanding. And to be fair, the description
21 Q I got it. 21 that I just gave is obviously our description,
22 A But I never had a conversation with him about 22 not the one necessarily that was presented at
23 closing doors. 23 trial.
24 Q Okay. I have another clip. It's 11 seconds 24 MS. MCLEROY: Is this your
25 long here. 25 description from your YouTube?
Page 302 Page 303
1 MR. HITCHCOCK: I don't believe so. 1 A I don't know who she was serving for. I have
2 Okay. 2 no clue.
3 MS. MCLEROY: And it's 11 seconds? 3 Q Okay. What I want to clue you in on, though,
4 MR. HITCHCOCK: Yes. 4 is this Dr. Holiday statement about Adria
5 (Whereupon Exhibit 12 was played.) 5 Maddaleni. Do you have any independent -- to
6 BY MR. HITCHCOCK: 6 verify -- can you independently verify his
7 Q Do you want to hear that again, sir? 7 statement about Adria Maddaleni?
8 A By Director -- Dr. Garcia. Uh-huh. 8 MS. MCLEROY: I'm going to object,
9 (Whereupon Exhibit 12 was played.) 9 foundation to this witness, calls for
10 BY MR. HITCHCOCK: 10 speculation.
11 Q Okay. So I just -- did you understand what 11 Go ahead.
12 Dr. Holiday was saying there? 12 THE WITNESS: I know nothing about
13 MS. MCLEROY: I'm going to object 13 Dr. Garcia and -- and his case or whatever. I
14 again to this playing for a witness who was not 14 know nothing about that.
15 there, lacks foundation, lacks authenticity, 15 BY MR. HITCHCOCK:
16 and the entire context is unknown to this 16 Q Okay. Were you ever served yourself in the
17 witness, calls for speculation. 17 Garcia Joven case?
18 Go ahead. 18 A Served --
19 THE WITNESS: Does this have to do 19 MS. MCLEROY: I'm going to object as
20 with Dr. Kuether? This was -- because I heard 20 irrelevant. To this matter, it doesn't affect
21 him say Dr. Garcia. 21 any of the causes of action in this case
22 BY MR. HITCHCOCK: 22 whatsoever.
23 Q Right. Well, so it's my understanding that 23 Go ahead and answer to the extent you
24 Dr. Kuether was serving process for Dr. Garcia 24 can.
25 Joven. Is that your understanding? 25 THE WITNESS: Served by Dr. Garcia

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1 for what? 1 correctly, it was given to someone in HR. I
2 BY MR. HITCHCOCK: 2 never even had hands on it.
3 Q Were you ever served with papers for the 3 BY MR. HITCHCOCK:
4 Dr. Garcia Joven hearing against MPS? 4 Q Was it Adria Maddaleni or somebody else?
5 A To do what? To show up in court? 5 MS. MCLEROY: Same objection.
6 Q For example. 6 THE WITNESS: I truly don't remember.
7 A I have not been asked to come in court for 7 I know it went to somebody down there. Never
8 Dr. Garcia. 8 even seen what was in the inside because I
9 Q Okay. Did your wife ever accept any service on 9 didn't know what she was delivering to our
10 your behalf? 10 house.
11 A The -- 11 BY MR. HITCHCOCK:
12 MS. MCLEROY: Same objection. 12 Q Okay. Is it fair to say that you -- after
13 THE WITNESS: The stuff that she got 13 receiving this document that you did not appear
14 when Dr. Kuether banged on the door and 14 at the Garcia Joven hearing?
15 speaking all through the door, and those kinds 15 MS. MCLEROY: Well, objection, calls
16 of things. She left an envelope, and we did 16 for speculation, foundation as to what document
17 not even open the envelope. That was -- that 17 it was.
18 envelope was carried back to the district 18 But go ahead.
19 office. 19 THE WITNESS: I have not been into
20 BY MR. HITCHCOCK: 20 any hearing with Dr. -- Dr. Garcia.
21 Q Okay. Was it given to anybody at that time? 21 BY MR. HITCHCOCK:
22 MS. MCLEROY: I'm going to object, 22 Q Okay. And did anybody advise you not to go to
23 relevance. 23 that hearing?
24 Go ahead. 24 MS. MCLEROY: Same objection.
25 THE WITNESS: If my memory serves me 25 THE WITNESS: Truly, I don't
Page 306 Page 307
1 remember. 1 individuals who can call the city attorney's
2 BY MR. HITCHCOCK: 2 office.
3 Q Oh, okay. Okay. And if Adria Maddaleni hadn't 3 BY MR. HITCHCOCK:
4 told Dr. Holiday not to appear at a hearing, 4 Q Can -- I guess, contact the city attorney's
5 would that be -- would you think that that 5 office. Can -- it sounded like you were
6 would be outside of her job description or 6 explaining to me that Adria Maddaleni and the
7 something else? 7 city attorney's office were making decisions
8 MS. MCLEROY: I'm going to object, it 8 together. Did I understand that right?
9 calls for speculation, incomplete hypothetical. 9 A No, I did not say that. I just said that the
10 Go ahead. 10 city attorney -- the chief of school adminis --
11 THE WITNESS: As the chief of human 11 the chief of human resources has autonomy to
12 resources and her working directly with the 12 make decisions.
13 city attorney's office, they make decisions. 13 Q Okay. So if a -- if what Dr. Holiday said on
14 BY MR. HITCHCOCK: 14 this recording is -- to the police is accurate
15 Q Okay. Does -- okay. I appreciate that. And 15 and Adria Maddeleni advised him not to show up
16 maybe you've assisted us here. What authority 16 to the hearing, that would have come from the
17 did you give Adria Maddeleni to communicate 17 city attorney's office. Is that what you are
18 with the city attorney's office? 18 saying?
19 MS. MCLEROY: I'm going to object, 19 MS. MCLEROY: Objection, calls for
20 vague, incomplete hypothetical. 20 speculation, this witness lacks foundation,
21 THE WITNESS: And I would -- and my 21 assumes facts not in evidence, incomplete
22 answer would be all chiefs and senior directors 22 hypothetical.
23 have the autonomy to call the city attorney's 23 Go ahead and answer, if you can.
24 office on anything that's a need. And there 24 THE WITNESS: I really don't have
25 are some directors as well. There's a list of 25 enough details to answer that question about

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1 what they did. 1 -- a represented party, so --
2 MR. HITCHCOCK: Okay. I'm sorry, so 2 MS. MCLEROY: Who is talking on the
3 this is a -- Exhibit -- 3 record.
4 MS. MCLEROY: 13. 4 MR. HITCHCOCK: I understand that. I
5 MR. HITCHCOCK: 13. Thank you. 5 still -- my objection still remains. So I --
6 (Exhibit No. 13 was marked.) 6 again, I will do what you're asking, which is
7 MR. HITCHCOCK: And it is 7 to get you all the proper citations for this so
8 approximately 32 seconds long. This is a 8 that it's not floating out there. I'm asking
9 portion of the trial in which Dr. Holiday is 9 for efficiency sake that we postpone that
10 testifying. 10 objection until -- unless -- and until we can
11 MS. MCLEROY: Okay. So this is not 11 correct that so that we can get out of here at
12 an exhibit, this is actually form the trial? 12 an appropriate time. I understand exactly what
13 MR. HITCHCOCK: That's right. 13 you're saying, and I don't disagree with it.
14 MS. MCLEROY: And from what time to 14 MS. MCLEROY: Okay. Well -- and we
15 what time portion excerpt? 15 are doing it this way so we can expedite this
16 MR. HITCHCOCK: I don't have the 16 and get out of here. That's what -- that's
17 entire, but -- 17 where we started. So let's do that, but we
18 MS. KUETHER: It's all in discovery. 18 need to have that specificity for the record.
19 MR. HITCHCOCK: -- but I will -- 19 MR. HITCHCOCK: Right. And I've been
20 MS. MCLEROY: Thank you, Dr. Kuether, 20 taking notes of --
21 but for the record, we need to make sure if you 21 MS. MCLEROY: Okay.
22 are going to be admitting evidence, we have 22 MR. HITCHCOCK: -- all of the ones we
23 specifics and not just out-of-context excerpts. 23 got in there. So this is 0 to 32.
24 MR. HITCHCOCK: I don't disagree with 24 MS. MCLEROY: Can you tell me -- this
25 you. What I do disagree with is talking to the 25 is Dr. Holiday's testimony?
Page 310 Page 311
1 MR. HITCHCOCK: This is Dr. Holiday 1 entitled, "She filed a complaint against me."
2 testifying here, is my understanding. 2 It's 1 minute and 13 seconds long. And I think
3 MS. MCLEROY: Okay. And do -- who is 3 we are on 14 now.
4 asking the questions, prosecution or defense? 4 (Exhibit No. 14 was marked.)
5 MR. HITCHCOCK: I believe that this 5 MS. MCLEROY: And, again, is this in
6 is prosecution. 6 the trial?
7 (Where upon Exhibit 13 was played.) 7 MR. HITCHCOCK: Yes.
8 BY MR. HITCHCOCK: 8 (Whereupon Exhibit 14 was played.)
9 Q Now, is that -- we heard an extra 2 seconds of 9 BY MR. HITCHCOCK:
10 that. But is that -- is this the first time 10 Q Now, would you be -- complaints filed against
11 today that you've heard this recitation of 11 Dr. Holiday with the MPS Department of Labor,
12 these events from Dr. Holiday? 12 would you be made aware of those complaints?
13 MS. MCLEROY: I'm going to object to 13 MS. MCLEROY: Once again, I'm going
14 the use of this video. I don't know if that 14 to object as to the showing -- well, actually,
15 was a video or just audio, frankly. Lacks 15 I don't know if that was a video or audio. You
16 foundation as to this witness, it's out of 16 have the computer facing toward you. It's
17 context, incomplete, calls for speculation for 17 improper to question this witness as to another
18 any comment on testimony of Dr. Holiday, which 18 witness's testimony, calls for speculation, and
19 is improper. 19 is totally irrelevant to the causes of action
20 Go ahead. 20 remaining in this case.
21 THE WITNESS: This is -- it will be 21 Go ahead.
22 truly speculation. This is my first time 22 THE WITNESS: It's all speculation.
23 seeing this. 23 I don't want to get into speculation.
24 BY MR. HITCHCOCK: 24 BY MR. HITCHCOCK:
25 Q Okay. I'm playing another clip. It's 25 Q Okay. And -- but this -- this incident

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1 happened when Dr. Holiday was at work; right? 1 case.
2 MS. MCLEROY: I'm going to object, 2 MR. HITCHCOCK: Okay. And, I mean, I
3 foundation. 3 want to be clear, you're not claiming that
4 Go ahead. 4 there's a privilege, you are just refusing to
5 THE WITNESS: I would think, yes. 5 answer it because there's another case that's
6 BY MR. HITCHCOCK: 6 filed; is that true?
7 Q Okay. Do you know who Floyd Williams is? 7 MS. MCLEROY: I'm telling --
8 A Yes. 8 privilege? What privilege are you talking?
9 Q Okay. How do you know Floyd Williams? 9 But it's -- it's -- I don't even know when the
10 A He was the principal school district, teacher 10 -- strike that.
11 in the school district, assistant principal in 11 When were the time frames for Floyd
12 the school district. 12 Williams?
13 Q Did you ever refuse to hire Floyd Williams? 13 MR. HITCHCOCK: What about it?
14 MS. MCLEROY: Woah, woah. Objection, 14 MS. MCLEROY: It -- it has nothing to
15 you have another lawsuit against Floyd Williams 15 do with the causes of action in this case, it's
16 that has nothing to do with this case, with 16 not relevant to the Title 7 claims, it has
17 this witness, and we're not going you cross 17 nothing to with any of the causes of action,
18 discovery on other cases, so we're not going to 18 and you are trying to do cross discovery
19 discuss that here today. 19 against another action that still hasn't even
20 MR. HITCHCOCK: You're refusing to 20 been answered. So we're not going to have
21 answer the question. 21 Dr. Posley sit here and talk about somebody
22 MS. MCLEROY: Yes. This -- that case 22 else and somebody else's case as it relates to
23 is based on a refusal to hire that you just 23 Dr. Kuether.
24 filed representing Floyd Williams. It has 24 MR. HITCHCOCK: Okay. Should we
25 nothing do with the causes of action in this 25 certify the question?
Page 314 Page 315
1 MS. MCLEROY: Sure. Go ahead. 1 I am instructing you not to answer,
2 Certify the question. 2 but you can let him know that.
3 BY MR. HITCHCOCK: 3 THE WITNESS: I've been instructed
4 Q Okay. The next -- and I want to be clear, sir, 4 not to answer by my legal counsel, and I won't
5 because I'm going to ask you directly. I 5 be answering that question.
6 understand that we just -- are you refusing to 6 BY MR. HITCHCOCK:
7 answer my question here today? 7 Q I appreciate that. I'm not making these
8 MS. MCLEROY: I'm instructing you not 8 formalities for no reason, sir, but I do
9 to answer. 9 appreciate it. Okay. The last question on
10 BY MR. HITCHCOCK: 10 that subject is are you aware of any
11 Q And, sorry, for the record, I just need to -- 11 allegations against Floyd Williams?
12 MS. MCLEROY: You can answer that I'm 12 MS. MCLEROY: Once again, same
13 instructing you not to answer. 13 objection, same instruction.
14 THE WITNESS: My attorney is 14 THE WITNESS: And I will not be
15 instructing me not to answer and I won't be 15 answering that question due to the guidance of
16 answering. 16 attorney.
17 BY MR. HITCHCOCK: 17 BY MR. HITCHCOCK:
18 Q I appreciate that. Thank you. Okay. So I 18 Q Thank you. Okay. Are you aware of any
19 have another question about Floyd Williams, 19 settlement between Milwaukee Public Schools and
20 which is, I guess, for foundational purposes. 20 Patrick Chapman?
21 Are you aware of him ever applying for any 21 A Settlement, no. What do you mean? The
22 positions at MPS? 22 financial settlement?
23 MS. MCLEROY: Once again, I am 23 Q For example, yeah.
24 instructing the witness not to answer. It has 24 A Not that I'm aware of.
25 nothing to do with this case. 25 Q How about another kind of settlement?

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1 MS. MCLEROY: I'm going to object to 1 answer.
2 the relevance, foundation for this witness. 2 THE WITNESS: I can't remember that.
3 Go ahead and answer if you can. 3 I -- I don't know. I can't say she has or she
4 THE WITNESS: Not that I know 4 has not. I don't.
5 anything about. 5 BY MR. HITCHCOCK:
6 BY MR. HITCHCOCK: 6 Q What's she authorized to negotiate on behalf of
7 Q Okay. How about Lorena Gueny, are you aware of 7 MPS at any time?
8 any settlements for her? 8 MS. MCLEROY: Same objection,
9 MS. MCLEROY: Same objection. 9 overbroad, vague, calls for speculation.
10 Go ahead. 10 Go ahead.
11 THE WITNESS: Yes. 11 THE WITNESS: What I can say there's
12 BY MR. HITCHCOCK: 12 a dollar amount, a threshold dollar amount.
13 Q How did you achieve that awareness? 13 And I think that threshold dollar amount is,
14 A Because of a closed session. 14 like, under $5,000 that -- but still have to
15 Q Okay. And was there an attorney there? 15 have board approval. That not necessarily her,
16 A Was there an attorney? Yes. 16 but Jim Gorton and various individuals that
17 Q Are you aware of whether or not Adria Maddaleni 17 were in that department.
18 has made any settlement offers on behalf of 18 BY MR. HITCHCOCK:
19 MPS? 19 Q Is Adria Maddaleni empowered to reject a
20 MS. MCLEROY: Can I have that 20 settlement offer?
21 question back? 21 MS. MCLEROY: Same objection.
22 (Record read.) 22 Go ahead.
23 MS. MCLEROY: I'm going to object to 23 THE WITNESS: You know, like I
24 relevance, foundation. 24 would think of anything else, if you can say
25 To the extent you know, go ahead and 25 yes to something, you can say no to it. But,
Page 318 Page 319
1 you know, if it's a need board approval, she 1 MS. MCLEROY: Objection, asked and
2 can't just make it on her own. 2 answered, lacks foundation, misstates his prior
3 BY MR. HITCHCOCK: 3 testimony.
4 Q Okay. I want to direct your attention back to 4 Go ahead.
5 the Calvin Fermin. I think we are calling it 5 THE WITNESS: Like I testified
6 the exit survey, but may also be the 6 earlier, I shared with you that I did read this
7 whistleblower complaint against Marla -- yeah. 7 document and passed it on to the attorneys.
8 Are we clear on what document we are talking 8 BY MR. HITCHCOCK:
9 about? 9 Q Got it. Did you discuss the document with the
10 MS. MCLEROY: Was it a marked 10 board at any time?
11 exhibit? 11 A This document?
12 BY MR. HITCHCOCK: 12 Q Uh-huh.
13 Q Yes. I believe it's 2. It might be 3. 13 MS. MCLEROY: Same objection.
14 The only reason I'm asking you that, 14 Go ahead.
15 just for clarity, is because I know there was 15 THE WITNESS: This document after
16 two documents, and I am not sure which one 16 everything was -- everything was complete, then
17 exactly we were referring to. 17 it was discussed with the board.
18 MS. MCLEROY: Is it this one? 18 BY MR. HITCHCOCK:
19 Exhibit 3. 19 Q Okay. And what was the nature of those
20 MR. HITCHCOCK: I believe so, yeah. 20 discussions?
21 Thank you. 3. 21 A And with the board?
22 THE WITNESS: That's it. Okay. 22 Q Right.
23 BY MR. HITCHCOCK: 23 THE WITNESS: There was a -- an
24 Q Okay. Now, did you review your -- did you 24 attorney there at that particular time. Do
25 review these allegations at any time? 25 I --

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1 MS. MCLEROY: Oh, yeah. I'm going to 1 No, that's fine. The answer is
2 object also as to relevance and the time frame. 2 fine.
3 You can't say anything that the attorney 3 -- to the extent what was told to you
4 discussed with you or the board. 4 to do was instructed by the attorney.
5 THE WITNESS: And what -- and you 5 Okay. Go ahead.
6 want -- and could you restate the question? 6 MR. HITCHCOCK: Can you read out what
7 BY MR. HITCHCOCK: 7 she just said?
8 Q Sure. Well -- and to be clear, my question was 8 (Record read.)
9 did you discuss this with the board? 9 BY MR. HITCHCOCK:
10 A Yes. 10 Q Was there -- were you told to do anything by
11 Q Okay. Did any individual board members tell 11 the attorney?
12 you -- give you any instructions at that point? 12 A Yes.
13 A Yes. 13 Q Okay. And who was that attorney?
14 Q Okay. Was there a vote on what to do at that 14 A There was a -- I can't remember what city
15 point? 15 attorney was there, but Miriam was there as
16 A A vote of what to do at that point? No. I was 16 well.
17 just directed of what to do at that point. 17 Q Okay. And did the city attorney tell you to do
18 Q Okay. And there couldn't have been a vote 18 the same thing that the board told you to do?
19 because it was a closed session; right? 19 MS. MCLEROY: I'm going to object to
20 A That's correct. 20 the extent I don't want you discussing what the
21 Q And when they told you what to do in the closed 21 attorney told you to do. You can talk about
22 session, did you do what they told to you do? 22 what the board instructed you to do.
23 A Yes. 23 BY MR. HITCHCOCK:
24 MS. MCLEROY: I'm going object to the 24 Q Right. And I didn't ask you what the attorney
25 extent it -- 25 told you, I just asked if they were the same
Page 322 Page 323
1 thing. 1 relevant.
2 MS. MCLEROY: Well, and that is 2 THE WITNESS: At my house, no.
3 objectionable and attorney-client privilege. 3 BY MR. HITCHCOCK:
4 You can ask him what the board told him to do. 4 Q Okay. And when we're -- I'm saying service at
5 BY MR. HITCHCOCK: 5 your house, you described to us an event where
6 Q I have asked you what the board told you to do; 6 Dr. Kuether went to your house and knocked on
7 right, sir? 7 your door; right?
8 MS. MCLEROY: Actually, no. 8 A Yes. And you are asking me did I tell
9 BY MR. HITCHCOCK: 9 Dr. Holiday about her knocking at my door?
10 Q Oh, good. Okay. 10 Q Right.
11 A So the question is? 11 A I don't know if I -- I don't remember if I
12 Q Yeah. Did any board members tell you what to 12 directly said anything to Dr. Holiday, but
13 do with -- what did the board members tell you 13 everybody in the office knew.
14 to do? 14 Q Okay. How did they know?
15 A They asked that -- 15 A Because my wife called, and I -- in panic. And
16 MS. MCLEROY: I was going to say 16 I shared with -- because she even talked to
17 objection, irrelevant. 17 whoever the person was that she talked to who
18 But go ahead. 18 answered the phone. And so, therefore, she was
19 THE WITNESS: That I find another 19 made aware, the person that answered the phone
20 assignment for reassigning that person. 20 call. And I know that I told someone in human
21 BY MR. HITCHCOCK: 21 resources, and I -- and also called the city
22 Q Did you talk to Dr. Holiday about the service 22 attorney's office to find out what needs to
23 from Dr. Kuether at your house? 23 happen. And I was told to -- whatever package
24 A The service? 24 that she had left, don't open it, to bring
25 MS. MCLEROY: I'm going to object, 25 it and turn it in to human resources.

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1 Q Okay. And is it -- based on that, is it clear 1 discrimination -- or Equal Rights Division
2 to you that Jeremiah Holiday was aware of the 2 complaint?
3 service at your house? 3 MS. MCLEROY: I'm going to object,
4 MS. MCLEROY: Object, calls for 4 lacks foundation, calls for speculation.
5 speculation. 5 THE WITNESS: When you say "the
6 Go ahead. 6 district," I don't know who you are referring
7 THE WITNESS: It's speculation. I 7 to. I don't know what they did with that. I'm
8 don't know if he was made aware or was he aware 8 not privy to that information.
9 or not. 9 BY MR. HITCHCOCK:
10 BY MR. HITCHCOCK: 10 Q Do you know what it means to be redlined?
11 Q I understand. I heard you testify just moments 11 MS. MCLEROY: I'm going to object,
12 ago that everybody in the office knew. 12 context, calls for speculation.
13 A Yeah. 13 Go ahead.
14 Q Okay. And did that include Jeremiah Holiday? 14 THE WITNESS: Redlined?
15 A Jeremiah Holiday is not in my -- 15 BY MR. HITCHCOCK:
16 MS. MCLEROY: Objection, calls for 16 Q Uh-huh.
17 speculation. 17 A Do I -- I know that term from insurance.
18 Go ahead. 18 Q Okay. How about MPS?
19 THE WITNESS: Jeremiah Holiday is not 19 A MPS, that means when a person is on special
20 in my office. 20 assignment or reassigned or whatever the
21 BY MR. HITCHCOCK: 21 situation may be, their salary is -- their
22 Q Okay. Did you learn whether or not the 22 salary is redlined. Like, for instance, when
23 district had used Dr. Holiday's -- 23 Dr. Holiday was demoted, his salary was
24 Dr. Kuether's complaint against Holiday to 24 redlined until the start of that particular
25 respond to Dr. Holiday's equal rights 25 year because the demotion happened within the
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1 year. 1 practice. So am I to infer from that is the
2 Q Okay. Was Dr. Kuether redlined? 2 practice because you said it's the practice or
3 A That I -- that I do not know, but -- 3 something else?
4 Q And you -- sitting here today, are you able to 4 MS. MCLEROY: I'm going to object,
5 tell us whether or not you directed anybody to 5 argumentative, assumes -- it's an incomplete
6 keep her pay the same? 6 hypothetical.
7 A Just like I shared with you earlier, the human 7 Go ahead and answer to the best you
8 resources takes care of pay. And any time 8 can.
9 someone is put on special assignment, that pay 9 THE WITNESS: I just shared with you
10 doesn't change. 10 the practice in the district when a person is
11 Q How do you know that? 11 redlined, their salaries do not change.
12 A Well, that is -- that's the practice. It 12 BY MR. HITCHCOCK:
13 doesn't change. 13 Q And I'm asking you, is it written down
14 Q How do you know that? 14 anywhere?
15 A I'm just telling you that's the practice. 15 MS. MCLEROY: I'm just going to
16 Q And I'm just asking you how do you know that 16 object, assumes facts not in evidence that
17 that's the practice? 17 something like that exists.
18 A I just told you that was the practice. 18 Go ahead and answer.
19 Q How does that answer my question? 19 THE WITNESS: As far as the written
20 MS. MCLEROY: I'm going to object, 20 down document of it would have to be in the
21 this has become argumentative. 21 handbook.
22 BY MR. HITCHCOCK: 22 BY MR. HITCHCOCK:
23 Q So my question to you was how do you know that 23 Q Did you ever learn -- how did you learn that
24 that's the practice, and I understood you to 24 this was the practice?
25 say to me that I just told you it was the 25 A This has been the practice -- how did I learn

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1 is because, just like I shared with you, I was 1 assigned to a job as principal on special
2 in the Office of School Administration, and we 2 assignment or assistant principal on special
3 had a number of reassignments to special 3 assignment. They assumed those duties of the
4 assignment. 4 job that they were assigned to.
5 Q I got it. Okay. And do those people have job 5 BY MR. HITCHCOCK:
6 duties? 6 Q Okay. And maybe I missed it, but did you tell
7 MS. MCLEROY: I'm going to object, 7 us what special -- what assignment that
8 overbroad, vague. 8 Dr. Kuether was specially put on?
9 Go ahead. 9 MS. MCLEROY: Objection, asked and
10 THE WITNESS: Yes. Everyone has a 10 answered.
11 job duty and responsibilities. 11 THE WITNESS: I shared with you that
12 BY MR. HITCHCOCK: 12 Dr. Kuether was assigned as administrator on
13 Q All the people who were -- to be clear, all the 13 special assignment in the assistant principal's
14 people who were reassigned on -- 14 room.
15 A Reassigned -- 15 BY MR. HITCHCOCK:
16 Q -- special -- if they had job duties? 16 Q Got it.
17 MS. MCLEROY: Object, asked and 17 A And I shared with you also on record, it could
18 answered a couple hours ago. 18 have been the -- there's an academic -- it
19 BY MR. HITCHCOCK: 19 could be academic assistant principal that just
20 Q Great. And how did you know that those other 20 does the academic component of it. It could be
21 people had job duties? 21 an assistant principal in the middle or high
22 MS. MCLEROY: Objection, asked and 22 school that does the program, the scheduling of
23 answered. 23 everything. And then there could be someone
24 Go ahead. 24 that does the day-to-day operations of students
25 THE WITNESS: Because they was 25 and student discipline.
Page 330 Page 331
1 Q I got it. How did Dr. Kuether know what work 1 MS. MCLEROY: Objection, asked and
2 she was supposed to be doing? 2 answered.
3 MS. MCLEROY: Objection, lacks 3 Go ahead.
4 foundation, calls for speculation. 4 THE WITNESS: Yes. That she was the
5 Go ahead. 5 new assistant principal, reassigned as
6 THE WITNESS: And I shared with you 6 assistant principal over to the school in a
7 earlier that when they are assigned, the Office 7 dirty office.
8 of School Administration does the assignment, 8 BY MR. HITCHCOCK:
9 and the role is assigned as far as what their 9 Q Now I understand. Okay. And so do you know if
10 job duties and responsibilities are. And the 10 Dr. Kuether had any computer to do any work on?
11 job duties and responsibilities are the 11 A I am -- like I said, that is a school
12 assistant principal, and I had just given those 12 operations thing. That is the principal of
13 to you. 13 that particular school. And at that particular
14 BY MR. HITCHCOCK: 14 time when we got there, the -- this office
15 Q I got it. Okay. And did you learn that 15 staff -- when we made it back to the office --
16 Dr. Kuether had been assigned to the assistant 16 because when we first got there, the principal
17 principal position when you went to Washington 17 was not there. And when we made it back, the
18 High School? 18 office -- the principal called, a young lady
19 A That was my first time hearing exactly where 19 that's apart of the staff and as well as the
20 she was assigned in her role was when former 20 secretary, and they talked about all of the
21 President Larry Miller called me that morning 21 wonderful things that they had done to welcome
22 and said, hey, you know, X, Y and Z. 22 Dr. Kuether, balloons, all of these wonderful
23 Q Okay. And did Larry Miller -- Miller tell you 23 things for her when she came in.
24 what the job that she was assigned as assistant 24 And that she had said, oh -- she had
25 principal? 25 gone to the office and came back and said she

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1 didn't want that office, and they gave her 1 remember going in the lower level, and I went
2 another office and asked her anything she 2 up on one of the second floors, maybe even the
3 needed, to let them know. So if she needed a 3 third floor. We saw three -- we saw three
4 computer, she would let them know, but all the 4 locations, and all three locations are used by
5 assistant principals offices, to my 5 high school principals. And high schools are
6 understanding, had computers in them, unless -- 6 huge, and we have assistant principals on the
7 Q Did they show the assistant principal's office 7 floors where children are.
8 at that time? 8 BY MR. HITCHCOCK:
9 A Yes. They showed me -- they showed me the 9 Q And did -- Angela Terry, did she know what
10 assistant principal's office that she went 10 Dr. Kuether's job duties were?
11 into, they showed me the new office that she 11 A Like I shared with you earlier, I have not
12 was assigned to, and then they showed me 12 talked to Angela Terry. And I will say to you
13 another assistant principal's office. 13 any time I've done the work before any time
14 Q Were any of those offices in the basement? 14 that a person is reassigned, there is a
15 A I don't know if you call it basement or garden 15 thorough conversation that takes place on what
16 level or whatever the situation may be, but 16 needs to happen with that person moving
17 there are students classrooms there. 17 forward.
18 Q Okay. Were the offices in the -- in the 18 Q Well, sitting here today, can you tell us what
19 basement as well? 19 happened with Dr. Kuether?
20 A I would have -- 20 MS. MCLEROY: I'm going to object,
21 MS. MCLEROY: Asked and answered. 21 foundation.
22 Go ahead. 22 Go ahead.
23 THE WITNESS: I would have to -- just 23 THE WITNESS: Sitting here today, I
24 like I said, I would have to go back to take a 24 can just share with you that what I shared with
25 closer look at that, but I just -- I do 25 Dr. Cotton and Calvin Fermin to reassign
Page 334 Page 335
1 Dr. Kuether, and I can only share with you 1 morning.
2 those things. The rest of that work is their 2 Q Who was not an employee of MPS?
3 work to do. 3 A He was at that particular time president of the
4 BY MR. HITCHCOCK: 4 Milwaukee Board of School Directors.
5 Q Got it. And correct me if I'm wrong, but the 5 Q And, therefore, not an employee; right?
6 only person I've heard that you learned that 6 MS. MCLEROY: Objection,
7 Dr. Kuether was to be assigned as an assistant 7 argumentative.
8 principal was Larry Miller. Did I 8 Go ahead.
9 misunderstand that? 9 THE WITNESS: I would -- whatever it
10 MS. MCLEROY: Objection, misstates 10 is when they hire, they identify when it's a
11 testimony. 11 board member.
12 Go ahead. 12 BY MR. HITCHCOCK:
13 THE WITNESS: I shared with you that 13 Q Okay. How -- do you know how Larry Miller
14 was the first person. 14 learned that she was to be an assistant
15 BY MR. HITCHCOCK: 15 principal?
16 Q Oh, okay. Who was the second person? 16 MS. MCLEROY: Objection, foundation.
17 A The second person, what do you mean? 17 Go ahead.
18 Q Who was the second person with you -- that 18 THE WITNESS: He said he had received
19 shared with you that you learned of 19 a call.
20 Dr. Kuether's new job position? 20 BY MR. HITCHCOCK:
21 A I can't remember who the second person was that 21 Q Okay. Do you know from who?
22 I learned from that perspect -- I asked the 22 A He did not tell me from who.
23 first person, that's how I found it out. 23 Q Got it. Okay. So after you and Larry Miller
24 Q Which is from Larry Miller? 24 left Washington High School, what did you
25 A From Larry Miller when he called me that 25 understand Dr. Kuether's situation to be?

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1 A That she had been reassigned another office. 1 -- what I said that he said. What I'm asking
2 That she didn't want the one that she had, she 2 you is is that statement accurate?
3 was reassigned another office. 3 MS. MCLEROY: Same objection.
4 Q Did you learn whether or not Dr. Kuether left 4 THE WITNESS: No. Calvin was not my
5 MPS on medical leave after that? 5 personal attorney.
6 A I have no clue. 6 BY MR. HITCHCOCK:
7 Q Can -- is that a no or something else? 7 Q Okay. Did you ever conduct the safety analysis
8 MS. MCLEROY: Objection, asked and 8 at the district?
9 answered. 9 MS. MCLEROY: Object, vague.
10 THE WITNESS: That was a no. 10 Go ahead.
11 BY MR. HITCHCOCK: 11 THE WITNESS: The district -- yes.
12 Q Okay. If Tony Baez said that Posley used 12 There was a safety analysis conducted with the
13 Fermin as his personal attorney while Posley 13 entire district.
14 was superintendent, is that an accurate 14 BY MR. HITCHCOCK:
15 statement? 15 Q Okay. Is there ever -- ever times that you did
16 MS. MCLEROY: I'm going object, 16 not use the e-mail system and purposely used
17 asking this witness to comment on another 17 some other system?
18 hearsay comment of another witness is highly 18 MS. MCLEROY: Objection, vague.
19 improper, calls for speculation. 19 Go ahead.
20 Go ahead and answer. 20 THE WITNESS: The answer is no.
21 THE WITNESS: That is spec -- totally 21 BY MR. HITCHCOCK:
22 speculation, and I don't know what Tony Baez 22 Q Okay. Did you ever learn of any accusations
23 would say. 23 that Aisha Carr had planted listening devices
24 BY MR. HITCHCOCK: 24 in your office?
25 Q Well, okay. I posed a positive to you what he 25 MS. MCLEROY: I'm going to object as
Page 338 Page 339
1 irrelevant, lacks foundation, calls for 1 THE WITNESS: Right. I don't have a
2 speculation. 2 clue.
3 Go ahead and answer. 3 BY MR. HITCHCOCK:
4 THE WITNESS: Yes, I did hear that. 4 Q Okay. Was it from -- was it on YouTube at the
5 BY MR. HITCHCOCK: 5 time?
6 Q Who did you hear it from? 6 MS. MCLEROY: Same objection.
7 A It was a video recording. 7 THE WITNESS: I have no clue.
8 Q Okay. And how did you obtain this video 8 BY MR. HITCHCOCK:
9 recording? 9 Q Okay. And so in what context did this media
10 MS. MCLEROY: Same objection. 10 person bring this to your attention?
11 THE WITNESS: I want to say it was 11 MS. MCLEROY: Same objection.
12 through the Department of Communications. 12 Go ahead.
13 BY MR. HITCHCOCK: 13 THE WITNESS: At that -- that was
14 Q Okay. And where did they get the recording, if 14 some allegations that there was listening
15 you know? 15 devices planted throughout the -- my office.
16 MS. MCLEROY: I'm going to object, 16 BY MR. HITCHCOCK:
17 same objections, also calls for speculation, 17 Q Okay. Did you ever investigate that?
18 lacks foundation. 18 A Yes.
19 Go ahead. 19 Q Okay. Did you find out that was true or false?
20 THE WITNESS: I have no clue where 20 A I found out that at -- the company that
21 they got it from. 21 investigated it, they didn't find anything at
22 BY MR. HITCHCOCK: 22 the time.
23 Q Was it on our talk show? 23 Q Okay. And you had a private company
24 MS. MCLEROY: I'm going to -- same 24 investigate it?
25 objection. 25 A It's a company that they came up with with

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1 board governance, basically, as far as my 1 needed to be discussed, and two-by-two, and
2 memory serves me. 2 it's all publicly noticed.
3 Q Did you ever meet with Aisha Carr when she was 3 MR. HITCHCOCK: Okay. I need to take
4 a board member? 4 a break here. I do not expect this to take
5 MS. MCLEROY: I'm going to object, 5 more than 15 minutes, but I will be back.
6 vague, overbroad. 6 MS. MCLEROY: You're not done?
7 Go ahead. 7 MR. HITCHCOCK: I'm not done.
8 THE WITNESS: Yes. 8 MS. KOLBERG: Standby. We are going
9 BY MR. HITCHCOCK: 9 off the record. The time is 4:05 p.m. This is
10 Q Did you ever meet with Aisha Carr and Jackie 10 the end of media unit four.
11 Mann together? 11 (Recess.)
12 MS. MCLEROY: Same objection. 12 THE VIDEOGRAPHER: We are going back
13 Go ahead. 13 on the record. The time is 4:17 p.m. This is
14 THE WITNESS: Along with other 14 the beginning of media unit five.
15 people, yes. 15 BY MR. HITCHCOCK:
16 BY MR. HITCHCOCK: 16 Q Okay. Dr. Posley, was Dr. Kuether's special
17 Q Okay. Any other board members? 17 assignment meant to be punitive?
18 MS. MCLEROY: Same objection. 18 MS. MCLEROY: I'm going to object,
19 THE WITNESS: Yes. 19 asked and answered, I believe.
20 BY MR. HITCHCOCK: 20 Go ahead.
21 Q What was that meeting about? 21 THE WITNESS: Special assignment, the
22 A Two-by-twos on a lot of different things to 22 answer is -- to be punitive, the answer is no.
23 discuss -- we discussed the safety plan, 23 The answer was to get -- to make sure that we
24 different things that needed to take place. It 24 could get the work done that we needed to get
25 was just a plethora of different things that 25 done and move forward. People are assigned
Page 342 Page 343
1 special assignment all the time for various 1 lacks foundation, calls for speculation.
2 needs at the district. 2 THE WITNESS: I have clue what --
3 BY MR. HITCHCOCK: 3 MS. MCLEROY: Go ahead and answer it.
4 Q Okay. And is there any evidence that the work 4 THE WITNESS: Truly, I have no clue
5 got done after Dr. Kuether was removed? 5 of what they -- of their conversation.
6 A The answer is yes, the work was produced. 6 BY MR. HITCHCOCK:
7 Q Okay. And what work is that? 7 Q Okay. So you wouldn't know, for example, if
8 A The -- to build a platform for instruction, as 8 Dr. Holiday -- if there would be many e-mails
9 well as all of the sources that could be used 9 between Dr. Holiday and Dr. Kuether in which
10 at home for students. All of that work is 10 Dr. Holiday simply doesn't respond on these
11 done. 11 issues. Is that fair?
12 Q The curriculum work? 12 MS. MCLEROY: I'm going to object,
13 A The curriculum was done. 13 lacks foundation, assumes facts not in
14 Q Okay. And did MPS purchase any materials in 14 evidence.
15 order to complete that work? 15 Go ahead.
16 A As my memory serves me correctly, I think, yes, 16 THE WITNESS: I'm not 100 percent
17 we -- there were some things that we did not 17 sure. I have -- you know, I don't know if they
18 have licensure to -- for the whole entire 18 communicated between each other by e-mail or
19 school district. And they wanted to add some 19 not.
20 more license, so we had to purchase some more 20 BY MR. HITCHCOCK:
21 things. 21 Q At the time that -- of the reassignment of
22 Q Okay. And do you believe that Dr. Kuether 22 Dr. Kuether, Dr. Holiday was a chief. Is that
23 asked Dr. Holiday for those licenses at any 23 fair?
24 time? 24 A Interim.
25 MS. MCLEROY: I'm going to object, 25 Q Interim chief. Okay. And if Dr. Holiday had

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1 gone to Dr. Cotton and Dr. -- scratch that. If 1 Q Okay. Do you believe it was more than $5,000?
2 Dr. Kuether had gone to Dr. Cotton about 2 A I would think, yes.
3 complaints about Holiday, could Dr. Cotton have 3 Q Okay. Why?
4 done anything about Dr. Holiday's behavior? 4 A Because licensure add-ons was high. And then
5 MS. MCLEROY: Objection, incomplete 5 at that particular time everyone was -- the
6 hypothetical, assumes facts not in evidence. 6 supply and demand was up, so there was some
7 Go ahead. 7 changes there.
8 THE WITNESS: Dr. Cotton did not 8 Q Okay. Did you recommend to the board to take
9 supervise. They was equals. 9 any action with regard to the curriculum
10 BY MR. HITCHCOCK: 10 materials?
11 Q Got it. 11 A I would have to go back and take a look. I
12 A Didn't supervise Dr. Holiday. 12 can't sit here today and say yes or no. But if
13 Q Do you know why MPS didn't purchase the 13 there was a need, that the answer would have
14 curriculum materials prior to the forcible 14 been yes.
15 reassignment of Dr. Kuether? 15 Q Got it. Could Dr. Kuether have approved the
16 MS. MCLEROY: Objection, vague. 16 purchase of the curriculum materials?
17 THE WITNESS: I have no clue. 17 MS. MCLEROY: Objection, vague.
18 BY MR. HITCHCOCK: 18 Go ahead.
19 Q Okay. Do you know what needed to happen to 19 THE WITNESS: Which -- what one?
20 purchase the -- the materials? 20 Which one?
21 A That was not something that I walked step by 21 BY MR. HITCHCOCK:
22 step through. 22 Q Well, so far have you identified any curriculum
23 Q Okay. Did the board need to approve it? 23 materials?
24 A The board would have to approve it if it was a 24 MS. MCLEROY: I'm going to object,
25 certain dollar of value. 25 vague. We haven't identified any.
Page 346 Page 347
1 BY MR. HITCHCOCK: 1 for you to understand what it is that
2 Q Well, that's not really accurate, is it, sir. 2 Dr. Saffold was accusing Dr. Kuether of holding
3 We have just now been talking about curriculum 3 up?
4 materials and licensure. What licensure were 4 MS. MCLEROY: I'm going to object,
5 you talking about in your answers just now? 5 argumentative.
6 A I was just talking about the various platforms. 6 Go ahead.
7 Like, for instance, if it was mental math or 7 THE WITNESS: Ask -- re-ask the
8 reading A to Z or something of this nature, it 8 question.
9 did not go to 12th grade. If they had license 9 BY MR. HITCHCOCK:
10 to use it from kindergarten through 8th grade, 10 Q Well, sure. If it was vague, wasn't it also
11 we would have to add the extra grades on, and 11 vague for you to understand what -- exactly
12 that's what I was referring to. And so we had 12 what the allegations made against Dr. Kuether
13 to do that in some cases. 13 by Dr. Saffold?
14 Q And this is -- again, this is approval here is 14 A If that's what you call it.
15 the work that Dr. Saffold alleged that 15 Q Okay. So is that a yes?
16 Dr. Kuether was holding up; true? 16 MS. MCLEROY: I'm going to object,
17 MS. MCLEROY: I'm going to object, 17 that's argumentative, the question was vague,
18 vague. 18 calls for speculation.
19 Go ahead. 19 Go ahead.
20 THE WITNESS: You know, she -- I 20 BY MR. HITCHCOCK:
21 can't say that she pinpointed each curriculum 21 Q So the question that I've asked you, was your
22 item that was held up, so I -- you know, so 22 last answer yes or something else?
23 kind of vague on that one. 23 A It was vague and speculation, so I don't --
24 BY MR. HITCHCOCK: 24 Q So you didn't answer the question. Is that
25 Q Well, if it was kind of vague, wasn't it vague 25 fair?

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1 A It's vague and it was speculation. 1 that's what you called it.
2 Q I understand. Despite the fact that it's vague 2 MR. HITCHCOCK: Okay.
3 and that it's speculation, what is the answer 3 MS. MCLEROY: I have objection to it
4 to that question? 4 being vague, argumentative, and calls for
5 MS. MCLEROY: Okay. We've gotten 5 speculation thereafter.
6 argumentative, this has been asked and 6 So go ahead.
7 answered. 7 THE WITNESS: And my statement that
8 Go ahead. 8 it was vague and it was speculation.
9 THE WITNESS: It's vague. 9 BY MR. HITCHCOCK:
10 MR. HITCHCOCK: Can you read out the 10 Q So you are not able to answer that question.
11 answer, please? 11 Is that fair?
12 THE REPORTER: To the question? 12 MS. MCLEROY: Same objections.
13 MR. HITCHCOCK: To my question, yes. 13 THE WITNESS: Uh-huh.
14 THE REPORTER: Sorry, do you want me 14 BY MR. HITCHCOCK:
15 to answer -- or read the question and the 15 Q It's true? Is that what you are saying? I
16 answer? 16 need a -- I need a response here.
17 MR. HITCHCOCK: Please. 17 A I just shared with you that it was vague as
18 (Record read.) 18 well as speculation. That's my answer.
19 BY MR. HITCHCOCK: 19 Q Okay. So same -- or similar question here.
20 Q Okay. And then I understood your answer to be 20 With that vague understanding of the
21 if that's what you're saying, then -- and then 21 allegations against Dr. Kuether, how was it
22 I don't know that you answered the question. 22 that you were able to determine that
23 So that's what I'm still trying to get clear on 23 Dr. Kuether was staying -- standing in the way
24 is what is your answer to that question, sir? 24 of the children's work being done?
25 MS. MCLEROY: He actually said if 25 MS. MCLEROY: I'm going to object,
Page 350 Page 351
1 asked and answered. 1 communication from you earlier today that the
2 THE WITNESS: As I shared with you 2 allegation from Saffold among -- was that she
3 earlier and I will share again, the urgency of 3 was difficult in meetings, and that she was
4 making sure that children had instruction 4 preventing her subordinates from doing certain
5 material in front of them at home with a 5 things. Is that the sum total of the
6 platform to do their work and to work with 6 allegations against her?
7 their teachers on a daily basis was a number 7 A That was something like that. And shutting
8 one priority. 8 down meetings and would not allow meetings to
9 BY MR. HITCHCOCK: 9 go forward.
10 Q Got it. What actions did Dr. Kuether take to 10 Q Okay. So what about her not allowing meetings
11 prevent that work from getting done? 11 to go forward was stopping the board from
12 MS. MCLEROY: Objection, asked and 12 approving the curriculum?
13 answered. 13 A If she could not --
14 Go ahead. 14 MS. MCLEROY: Let me just object,
15 THE WITNESS: I have answered that 15 asked and answered, discussed at length, calls
16 question as well. And I will go back to what 16 for speculation as to meetings he wasn't
17 I've shared with you over and over and over 17 present at.
18 again, around the idea of the urgency of 18 Go ahead.
19 children having quality instructions in front 19 THE WITNESS: If she was shutting
20 of them on a daily basis and a platform to go 20 down -- if she was shutting down meetings, that
21 along with it, along with various reading and 21 means -- that means the work could not get
22 literacy and math material. 22 done. And then if her people were not working
23 BY MR. HITCHCOCK: 23 with the staff, we couldn't have got --
24 Q I get that. But my -- what I'm trying to 24 couldn't have got it done.
25 understand is I thought we had some 25 BY MR. HITCHCOCK:

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1 Q Well, how do you know those meetings were about 1 working for children.
2 the curriculum? 2 BY MR. HITCHCOCK:
3 A How do I know those meetings were about the 3 Q Okay. And are you able to identify anybody
4 curriculum? 4 else who you've relocated because you allege
5 Q That's right. 5 that they were not working in the best interest
6 A Because the curriculum is what's -- what we 6 of children?
7 were working on. That was the -- that was what 7 MS. MCLEROY: I'm going to object,
8 was on the table, the urgency of children. 8 incomplete hypothetical, vague.
9 Q Okay. Is there any time -- is there ever a 9 Go ahead.
10 time when you are not working on the urgency of 10 THE WITNESS: That would have to be
11 children? 11 if I could look at a list of names of
12 MS. MCLEROY: I'm going to object, 12 individuals, I could tell you yes.
13 vague, calls for speculation, incomplete 13 BY MR. HITCHCOCK:
14 hypothetical. 14 Q Okay. But -- so sitting here today, you can't
15 Go ahead. 15 identify --
16 THE WITNESS: Hypothetical like when? 16 A I don't have on the back of my mind all the
17 There's tons of things to work on within the 17 people that have been reassigned and the
18 district. 18 reasons why they were reassigned.
19 BY MR. HITCHCOCK: 19 Q Okay. How long was Dr. Kuether supposed to be
20 Q I understand. My question to you is, is there 20 at Washington High School?
21 ever a time that when you at the district are 21 A That was not -- I don't know if there was a
22 not working for the betterment of children? 22 time given to her of how long she was to be
23 MS. MCLEROY: Same objection. 23 there. Once I shared with you what I did, the
24 THE WITNESS: No. There's never a 24 two people that I talked to, that was worked
25 time that we're not -- all the time we were 25 out, and that would be worked out with those
Page 354 Page 355
1 offices. 1 A Did he have the ability?
2 Q Okay. And how do you know that it was worked 2 Q Uh-huh.
3 out when Dr. Kuether was to be off of special 3 A Yes. He has the ability to involve -- to put
4 assignment? 4 her on special assignment.
5 A To be off? 5 Q Got it. How about Katrice Cotton?
6 Q Uh-huh. 6 A Yes, they would have had the autonomy.
7 A I have never asked a question about when 7 Q Okay. Is there a code for being on special
8 Dr. Kuether would be off. 8 assignment?
9 Q So as far as you were concerned, she was 9 MS. MCLEROY: Object, vague.
10 permanently on special assignment; true? 10 THE WITNESS: What kind of -- not
11 A I don't know anyone that was permanently on 11 that I'm aware of.
12 special assignment. 12 BY MR. HITCHCOCK:
13 Q Well, how was Dr. Kuether to get off of special 13 Q What instructions do you have to give to HR for
14 assignment? 14 somebody who's -- so that they can adequately
15 MS. MCLEROY: Object, calls for 15 account for somebody being on special
16 speculation, lacks foundation. 16 assignment?
17 Go ahead. 17 A Administrator on special assignment, that
18 THE WITNESS: I would just say that 18 administrator with their title. So the
19 is totally speculation. I don't know how that 19 administrator as well as their current title
20 I would -- you know, each case is different, 20 stays at same.
21 but special -- like I said, special assignment 21 Q Got it. During your experience at MPS, did you
22 is for a period of time. 22 believe that being on special assignment was a
23 BY MR. HITCHCOCK: 23 positive thing for an employee?
24 Q Okay. Did Dr. -- or did Calvin Fermin have the 24 A Being on special -- yes. There is special
25 ability to involuntarily transfer Dr. Kuether? 25 assignments for various reasons, just like I

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1 shared earlier. There are shortages in the 1 Q Okay. What else don't they vote on?
2 district. The start of the school year, 2 MS. MCLEROY: I'm going to object --
3 everybody is out there months -- couple months 3 THE WITNESS: They vote on -- they
4 at a time. So there's all -- special 4 don't vote on --
5 assignment has a very -- don't always looked at 5 MS. MCLEROY: Objection, foundation,
6 as being negative. 6 calls for speculation, vague, overbroad.
7 Q Okay. Got it. Was Marla put on special 7 Go ahead.
8 assignment? 8 THE WITNESS: Let me clarify. As far
9 A Was Marla put on special assignment? 9 as when people are out or reassigned a place
10 MS. MCLEROY: I'm going to object, 10 like that, they don't -- they don't vote on
11 relevant. 11 that.
12 Go ahead. 12 BY MR. HITCHCOCK:
13 THE WITNESS: Marla was placed out on 13 Q Okay. They just told you to do it?
14 a leave, and then after coming back from her 14 A I was directed to place her on leave.
15 leave, she was demoted into a position. 15 Q By whom?
16 BY MR. HITCHCOCK: 16 A I just shared with you.
17 Q Who put her on leave? 17 MS. MCLEROY: Asked and answered.
18 A I was told to place her on leave. 18 BY MR. HITCHCOCK:
19 Q By who? 19 Q Well, this is the problem, Dr. Posley. How do
20 A By the board. 20 you know that the board did it if there wasn't
21 Q Was there a vote? 21 a vote?
22 A Was there a vote? 22 MS. MCLEROY: Well, objection,
23 Q That's right. 23 argumentative, calls for speculation.
24 A To go on -- to go on leave? They don't vote on 24 Go ahead.
25 leaves. 25 THE WITNESS: How do I know the board
Page 358 Page 359
1 did it if it wasn't a vote? 1 MS. MCLEROY: Object, vague, asked
2 BY MR. HITCHCOCK: 2 and answered --
3 Q Sure. You -- 3 THE WITNESS: I have shared --
4 A Placing -- 4 MS. MCLEROY: -- argumentative.
5 Q Just a second. You are explaining to me that 5 THE WITNESS: I have shared with you
6 the board directed you to put Marla on leave; 6 that attorney was there, and I was directed to
7 right? 7 place her on leave.
8 A Yes. 8 BY MR. HITCHCOCK:
9 Q Okay. And that you were also clear that there 9 Q Okay. How do you know that you were directed?
10 was no vote; right? 10 A I was told. They told me.
11 A Placing individuals on leave is my -- in my 11 Q All -- all of the members of the board told
12 responsibilities of doing so. 12 you?
13 Q Can you answer my question? Was there a vote? 13 A No.
14 A Was there a vote? 14 Q Okay. Do you know if anybody opposed that
15 MS. MCLEROY: Asked and answered. 15 decision?
16 BY MR. HITCHCOCK: 16 MS. MCLEROY: I'm going to object,
17 Q Right. 17 lacks foundation, calls for speculation,
18 A To place her on leave? 18 argumentive.
19 Q Right. 19 Go ahead and answer if you can.
20 A I just shared with you there was no vote to 20 THE WITNESS: I don't -- I don't
21 place her on leave. 21 remember the exact person that -- that said to
22 Q I got it. And then so my -- then my question 22 place on her leave, but that's what I was
23 is without a vote, how do you know what the 23 directed to do.
24 will of the board was as opposed to just some 24 BY MR. HITCHCOCK:
25 board members? 25 Q Did you ever learn in your training to be a

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1 superintendent whether or not the board could 1 MS. MCLEROY: Objection, vague,
2 take some action without a vote? 2 argumentative.
3 MS. MCLEROY: I'm going to object, 3 Go ahead.
4 vague, overbroad, incomplete hypothetical, 4 THE WITNESS: The answer is no.
5 calls for speculation. 5 BY MR. HITCHCOCK:
6 Go ahead. 6 Q How about Dr. Holiday?
7 THE WITNESS: And could you ask the 7 MS. MCLEROY: Same objection.
8 question again? 8 THE WITNESS: The only thing I
9 BY MR. HITCHCOCK: 9 received from the board is what I testified to
10 Q Sure. Did you ever learn that the board could 10 you earlier about there was concern about his
11 take an action without a vote? 11 promotion.
12 MS. MCLEROY: Same objection. 12 BY MR. HITCHCOCK:
13 THE WITNESS: The board cannot take 13 Q Okay. And we wouldn't know if what you are
14 an action without a vote. 14 saying is true or not because there would have
15 BY MR. HITCHCOCK: 15 been no public vote; right?
16 Q Okay. And how do you know that? 16 MS. MCLEROY: Objection,
17 MS. MCLEROY: Same objection. 17 argumentative.
18 THE WITNESS: Because there has to be 18 Go ahead.
19 an action in order to take -- there has to be 19 THE WITNESS: There was not given a
20 an item in order to take action on. 20 -- not been a vote on what?
21 BY MR. HITCHCOCK: 21 BY MR. HITCHCOCK:
22 Q Okay. Have you ever received instructions from 22 Q On any commun -- direction to you regarding
23 the board without a vote -- or I should say to 23 Holiday?
24 be fair to you, direction from the board 24 MS. MCLEROY: Same objection.
25 without a vote regarding Dr. Kuether? 25 THE WITNESS: I just shared with you
Page 362 Page 363
1 early on and just a few minutes ago the process 1 Q Okay. Well, so if you learned at a closed
2 what happened with Holiday. 2 session meeting that the board wouldn't promote
3 BY MR. HITCHCOCK: 3 Dr. Holiday and then you removed him from
4 Q Okay. And when -- and when the board members 4 consideration, do you consider that to be a
5 -- when you learned that Dr. Holiday wasn't 5 directive from the board or something else?
6 going to pass, was that direction from the 6 A I -- I seen that as a directive that they were
7 board or something else? 7 not going to pass the list as it was printing.
8 MS. MCLEROY: Asked and answered. 8 I did not want to embarrass anyone by saying
9 Go ahead. 9 I'm going to take your name off. And I said to
10 THE WITNESS: It was the idea that 10 the board, you know, if you all want to take
11 they were not ready to move those names 11 the names off, you can do that or we can move
12 forward. 12 it forward, or the option is I pull the whole
13 BY MR. HITCHCOCK: 13 list and I will bring the list back, you know,
14 Q Okay. Was it a majority of the board wasn't 14 so -- and they agreed. Well, basically, it was
15 ready to move the names forward? Who wasn't 15 the sentiment to just take the list and not
16 ready to move those names forward? 16 embarrass anyone.
17 MS. MCLEROY: Objection, calls for 17 Q What did Bob Peterson say at that time --
18 speculation. 18 A I don't know.
19 Go ahead. 19 Q -- if anything?
20 THE WITNESS: I'm just sharing with 20 A I truly don't remember.
21 you and I will share with you again the same 21 Q How about Marva Hermann?
22 thing I shared earlier of the -- what was said, 22 A I truly -- I truly do not remember.
23 and that's all I can tell you. That's all I 23 Q Okay. Has Marva Hermann ever said that any
24 have to tell you. 24 accusations against you are attempts to take
25 BY MR. HITCHCOCK: 25 down a black man?

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1 MS. MCLEROY: I'm going to object, 1 A And plus, it's not my employee. I do not
2 calls for speculation, incomplete hypothetical, 2 supervise that person.
3 in context of improper to have him speculate on 3 Q Okay. Do you believe that Rosana Mateo was
4 what another witness says. 4 actually at Hamilton High School 156 times?
5 Go ahead. 5 MS. MCLEROY: I am going to object to
6 THE WITNESS: I -- I don't know what 6 the relevance of this claim, it has nothing to
7 Director Hermann said. 7 do with the causes of action herein, vague,
8 BY MR. HITCHCOCK: 8 overbroad, assumes facts not in evidence.
9 Q Got it. Do you know why Jackie Mann left the 9 Go ahead.
10 district? 10 THE WITNESS: Do I believe Rosana
11 A I shared you with you earlier, I do not know 11 Mateo was there 156 times you are asking me?
12 the details of why Dr. Mann left the district. 12 BY MR. HITCHCOCK:
13 I was not in that closed session. 13 Q Right.
14 Q Okay. Do you have any other information other 14 A Do I believe that?
15 than that closed session as to why Dr. Mann 15 Q Right.
16 left the district? 16 A That is not -- I did not provide that she was
17 A I do not. 17 there 156 times.
18 Q Okay. Were you not invited to that closed 18 Q I understand that. Did you believe that that's
19 session meeting? 19 an accurate -- that those allegations were
20 A I am not in closed sessions when it's the 20 accurate?
21 Office of Board Governance or OAE, unless it is 21 A I --
22 something that they want to share with me, and 22 MS. MCLEROY: Same objections.
23 that was not something that they wanted to 23 THE WITNESS: I don't know.
24 share with me. 24 BY MR. HITCHCOCK:
25 Q Got it. 25 Q Well, do you think they are credible?
Page 366 Page 367
1 MS. MCLEROY: Same objections, calls 1 MS. MCLEROY: Object --
2 for speculation. 2 THE WITNESS: I'm the implementer of
3 THE WITNESS: Going by the cameras 3 her retaliation.
4 and the swipes, you know. 4 BY MR. HITCHCOCK:
5 BY MR. HITCHCOCK: 5 Q That's right.
6 Q Right. Does that -- that -- I understand that 6 MS. MCLEROY: I'm going to object as
7 that information was presented to -- and that 7 completely irrelevant to this matter,
8 you had that information of Rosana Mateo; 8 incomplete hypothetical, and improper to
9 right? The question was, did you think at that 9 comment by this witness on another witness's
10 time that it was credible? 10 testimony.
11 MS. MCLEROY: Same objections, 11 But go ahead.
12 completely irrelevant to this action. 12 THE WITNESS: I don't remember having
13 THE WITNESS: It's not my 13 such conversation with Tony Baez.
14 responsibility to audit -- audit reports or 14 BY MR. HITCHCOCK:
15 audit investigation. I don't do second 15 Q Okay. I'm going to read a statement that Tony
16 investigations after the information has been 16 Baez attributes to you and you can tell me if
17 provided. 17 this is accurate. He says that -- I assume
18 BY MR. HITCHCOCK: 18 he's paraphrasing, but he says, when Driver was
19 Q Okay. Got it. Did you ever have a 19 the superintendent and I was this main [sic],
20 conversation with Tony Baez in which he alleged 20 he used Obama. And he says, remember Obama,
21 that you were the implementer of all Darienne 21 remember his chief for deportation with
22 Driver's retaliation? 22 immigration, he says, when I was with Driver, I
23 MS. MCLEROY: I'm sorry. I need to 23 was without a doubt the chief implementer of
24 have that read. I missed -- 24 retaliation, but I was her soldier, but now I
25 (Record read.) 25 am your soldier. Is that -- did you say

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1 statements like that to Tony Baez at any time? 1 THE WITNESS: Just like I've told you
2 MS. MCLEROY: Same objection. 2 over and over, and I gave you an example of a
3 Go ahead. 3 tree early on, and I just told you, it depends
4 THE WITNESS: No. I will never stoop 4 on what am I directed to do and does it have
5 myself to that level. 5 validity of being done.
6 BY MR. HITCHCOCK: 6 BY MR. HITCHCOCK:
7 Q Okay. And going on Tony Baez says, and because 7 Q Right. And you also gave us examples of when
8 I am your soldier, okay, if you decide that you 8 the board told -- without a vote told you to
9 don't want to do this, I won't do this. Is 9 put Marla Bronaugh on leave; right?
10 that -- did you say something like that to Tony 10 MS. MCLEROY: Objection, misstates
11 Baez? 11 the testimony, argumentative.
12 MS. MCLEROY: Same objections. 12 Go ahead.
13 THE WITNESS: I don't remember that 13 THE WITNESS: I've shared with you
14 at all. At any time I met with Tony Baez, 14 the statements that I shared with you earlier
15 somebody was always with me because I did not 15 in regards of Marla.
16 trust the conversation. 16 BY MR. HITCHCOCK:
17 BY MR. HITCHCOCK: 17 Q Okay. And you also did it; right? You did
18 Q Got it. But it is true that if the board tells 18 what they told you to do from Marla; right?
19 you to do something, you do it even if there -- 19 MS. MCLEROY: Objection, misstates
20 regardless of whether or not there's a vote; 20 the evidence, asked and answered, incomplete
21 true? 21 hypothetical.
22 MS. MCLEROY: Objection, asked and 22 Go ahead.
23 answered, incomplete hypothetical, calls for 23 THE WITNESS: Yes. I reassigned --
24 speculation, overbroad and vague. 24 not reassigned. I placed Marla on leave.
25 Go ahead. 25 BY MR. HITCHCOCK:
Page 370 Page 371
1 Q Okay. And you also took the names off of -- 1 shouldn't be demoted?
2 Holiday's name off of reconsideration just like 2 MS. MCLEROY: Objection, irrelevant.
3 the board asked you to do; right? 3 Go ahead.
4 MS. MCLEROY: Objection, misstates 4 THE WITNESS: When she was demoted?
5 the testimony, asked and answered at length 5 BY MR. HITCHCOCK:
6 numerous times. 6 Q Uh-huh.
7 Go ahead. 7 A That information was handled through HR.
8 THE WITNESS: I shared with you about 8 Q Okay. But who made the decision?
9 the Holiday situation and -- and what was there 9 A I made the decision.
10 with that particular situation that went 10 Q Okay. So before you made the decision to take
11 around. They were not comfortable with moving 11 this action, did you give her the opportunity
12 his name forward. 12 to explain to you why you shouldn't take that
13 BY MR. HITCHCOCK: 13 action?
14 Q I got it. Okay. Before you placed -- and I 14 MS. MCLEROY: Same objection.
15 guess to be clear, I may not have asked this 15 THE WITNESS: The answer is no.
16 question, Marla Bronaugh, you believe she's 16 BY MR. HITCHCOCK:
17 female or something else? 17 Q Okay. Why not?
18 A Just like I shared with you in earlier times, I 18 A Why?
19 have no clue. 19 MS. MCLEROY: Same objection.
20 Q Got it. Okay. Then before you placed her on 20 BY MR. HITCHCOCK:
21 leave, did you give Marla the opportunity to 21 Q Right. Why didn't you give her any due
22 explain why she shouldn't be placed on leave? 22 process, for example?
23 A No. 23 A The bottom line is that she had gone through --
24 Q Okay. How about before you demoted her, did 24 there's a different due process for chiefs than
25 you give her the opportunity to explain why she 25 it is -- for anybody from director down,

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1 there's a due -- different due process versus 1 Q So how did you know she was at-will?
2 senior director up. 2 MS. MCLEROY: I'm going to object --
3 Q Okay. So based on that, Dr. Kuether was 3 THE WITNESS: I --
4 entitled to more due process than Marla 4 MS. MCLEROY: -- it's argumentative.
5 Bronaugh in that situation; true? 5 THE WITNESS: I have a list of
6 MS. MCLEROY: Objection, misstates 6 individuals that are at-will employees.
7 the testimony. 7 BY MR. HITCHCOCK:
8 THE WITNESS: You would have to take 8 Q How did that information come to be compiled?
9 a closer look at the guidelines around 9 A It's compiled as a board document. You can go
10 individuals that are -- that have a board 10 and look at it yourself.
11 hearing and those kinds of things versus those 11 Q Got it. And so at least we can be sure that
12 individuals that are at-will employees. 12 Dr. Kuether wasn't on that list; right?
13 BY MR. HITCHCOCK: 13 A On which list?
14 Q Okay. Who -- 14 Q The at-will list.
15 A And the chief is an at-will employee. 15 A Dr. Kuether in her role was not an at-will
16 Q Okay. How do you know that? 16 employee.
17 A Because it's on my list of individuals that 17 Q Okay. And, therefore, entitled to more due
18 were at-will. 18 process protections than chief; true?
19 Q Did you review the contract at any time? 19 MS. MCLEROY: I'm going to object --
20 A Did I review what -- 20 THE WITNESS: I would say different.
21 Q Did Ms. Bronaugh have a contract? 21 BY MR. HITCHCOCK:
22 A Everybody in the district I shared with you had 22 Q Different. Okay. Are they different and
23 a contract. And, no, I did not review her 23 additional or different and something else?
24 contract. I don't look at individual 24 MS. MCLEROY: Same objection.
25 contracts. 25 THE WITNESS: Different.
Page 374 Page 375
1 BY MR. HITCHCOCK: 1 asked and answered, calls for speculation.
2 Q Okay. Do you know if Saffold ever disciplined 2 THE WITNESS: I've shared with you
3 Kuether? 3 several times today that I had no privy to
4 A Like I shared with you earlier is what I know. 4 Dr. Kuether's personnel file to know any of
5 And as far as details about her discipline and 5 those things. It's not even in my office.
6 that kind of stuff, not sure. 6 BY MR. HITCHCOCK:
7 Q Well, what other steps did you consider other 7 Q Okay. But if you had known those things, would
8 than forcibly transferring Dr. Kuether to that 8 that have helped you craft progressive
9 high school? 9 discipline for Dr. Kuether?
10 A Just like I shared with you earlier, I did not 10 A And I --
11 transfer Dr. Kuether to a high school. I asked 11 MS. MCLEROY: I am going to object,
12 that Dr. Kuether be reassigned. 12 assumes facts not in evidence, calls for
13 Q Great. What other than re -- than asking for 13 speculation.
14 her to be reassigned, what else did you 14 Go ahead.
15 consider, if anything else, less than 15 THE WITNESS: I've shared with you
16 reassignment? 16 over and over, and I will continue to share as
17 A I considered have a mediation and those kinds 17 long as I sit here and you asking me the same
18 of things, I asked to have that done, tried to 18 question, that this was a urgency matter.
19 work together, tried to get on the same page. 19 Children at that particular time,
20 That -- that is what I asked of Dr. Saffold. 20 70-plus-thousand children in that district
21 Q Okay. And -- but you didn't know before you 21 needed quality instruction on a daily basis in
22 reassigned her, Dr. Kuether, whether or not she 22 their homes via services that we needed to
23 had been -- Dr. Kuether had been subject to any 23 provide, and I had to make sure that those
24 progressive discipline; right? 24 services was provided.
25 MS. MCLEROY: I'm going to object, 25 BY MR. HITCHCOCK:

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1 Q Okay. Ultimately, what the district did to 1 evidence.
2 make sure that those services were provided was 2 THE WITNESS: Would you like to
3 the board to approve a contract; true? 3 restate the question?
4 MS. MCLEROY: Objection, incomplete 4 BY MR. HITCHCOCK:
5 hypothetical. 5 Q No. Did you not understand it?
6 Go ahead. 6 A No, I didn't understand it.
7 THE WITNESS: We -- no. We had to 7 Q I appreciate that. Do you -- do you know what
8 redesign the whole entire district what we do 8 a bad actor is? And I'm not trying to be
9 with children face-to-face. We have to do that 9 flippant with you, I'm just --
10 when the teachers were now working at -- from 10 A Well, apparently you're asking me that
11 home. So, therefore, you know, we had to do 11 question.
12 the curriculum, had to redo that whole piece, 12 Q Right. Okay. So what I'm asking you is, do
13 what that looked like, what services that 13 you believe that it's public knowledge that you
14 needed to be provided, how do we coincide the 14 were a bad actor in the employment context in
15 courses that they are doing there with their 15 this case?
16 regular courses because we had to be able to 16 MS. MCLEROY: Okay. I'm going to
17 provide grades. There was a number of 17 object, vague, assumes facts not in evidence,
18 different things that we had to do. 18 complete harassment, and lacks foundation as to
19 BY MR. HITCHCOCK: 19 what the public thinks.
20 Q Got it. If Dr. Kuether's -- how -- let's put 20 To the extent you can answer at the
21 it like this. Do you think it's common 21 insult to you, go ahead.
22 knowledge that you are a bad actor in this 22 THE WITNESS: It's all speculation,
23 case? 23 and one is entitled to believe whatever they
24 MS. MCLEROY: Objection, totally 24 desire.
25 harassment, vague, assumes facts not in 25 MR. HITCHCOCK: I appreciate that. I
Page 378 Page 379
1 really do. 1 what the first two pages are for the record.
2 Okay. Just give me 30 seconds, and 2 MR. HITCHCOCK: Okay. Would you
3 we will make -- we may be done. 3 object to us removing the first two pages?
4 MS. KOLBERG: Standby. We are going 4 MS. MCLEROY: I think that would be
5 off the record. This is -- the time is 5 appropriate.
6 4:54 p.m. This is the end of media unit five. 6 MR. HITCHCOCK: Okay.
7 (Recess.) 7 MS. MCLEROY: I will take that one.
8 MS. KOLBERG: We are going back on 8 That's our copy.
9 the record. The time is 4:56 p.m. This is the 9 MR. HITCHCOCK: No problem. So just
10 beginning of media unit six. 10 to be clear for the record, I am going to -- I
11 BY MR. HITCHCOCK: 11 don't know how best to do this, but there's an
12 Q I just have one question. Do you know what 12 exhibit sticker on page 1. I'm going to remove
13 happened to the letter that Dr. Kuether 13 page 1 and 2. There would not be an exhibit
14 delivered to your house after you gave it to 14 sticker on number -- on that first page there,
15 HR? 15 and we will clean that up.
16 MS. MCLEROY: Objection, foundation, 16 MS. MCLEROY: We will have the court
17 calls for speculation. 17 reporter just substitute in the March -- or the
18 Go ahead. 18 December 7, 2021 letter as the entirety of
19 THE WITNESS: No, I do not. 19 Exhibit 2. Thank you.
20 MR. HITCHCOCK: Okay. Thank you for 20 Okay. No questions from us.
21 your time here today. 21 MR. HITCHCOCK: Not one?
22 MS. MCLEROY: Can you finish up what 22 MS. MCLEROY: No.
23 you were going to do with Exhibit 2? You said 23 MR. HITCHCOCK: It's always nice to
24 you would get back to it, but you only talked 24 see you guys.
25 about the letter on page 3, and I don't know 25 THE VIDEOGRAPHER: The time is

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1 4:58 p.m. We are going off the record. This 1 STATE OF WISCONSIN )
) SS:
2 concludes today's video-recorded testimony. 2 COUNTY OF MILWAUKEE )
3 There are six media units total for this 3
4 deposition. 4
5 THE REPORTER: Would you like to 5 I, ALICIA PABICH, a Certified Shorthand
6 order the original? 6 Reporter and Notary Public in and for the State of
7 MR. HITCHCOCK: Yes, please. 7 Wisconsin, do hereby certify that the above
8 THE REPORTER: And would you guys 8 videotaped deposition of KEITH POSLEY was recorded
9 like a copy? 9 by me on April 28, 2025, and reduced to writing
10 MS. MCLEROY: Yes, please. 10 under my personal direction.
11 (Proceedings concluded at 4:58 p.m.) 11 I further certify that I am not a
12 12 relative or employee or attorney or counsel of any
13 13 of the parties, or a relative or employee of such
14 14 attorney or counsel, or financially interested
15 15 directly or indirectly in this action.
16 16 In witness whereof I have hereunder set
17 17 my hand and affixed my seal of office at Milwaukee,
18 18 Wisconsin, this 7th day of May, 2025.
19 19
20 20
21 21
22 22 Notary Public
In and for the State of Wisconsin
23 23
24 24
25 25

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WORD INDEX 13 3:14, 19 301:4 2024 4:12 14:23 4:17 341:13

308:4, 5, 6 310:7 15:6 66:9 298:3 4:54 378:6
<$> 311:2 2025 1:1 4:5 381:9, 4:56 378:9
$5,000 317:14 345:1 133 225:24 18 4:58 1:1 380:1, 11
134 225:25 226:3, 19 2028 4:13 411 2:7
<0> 227:11 214 270:11, 12, 13 4th 14:23
0 296:12 299:14 13th 63:13 277:6
309:23 14 3:15 213:9, 17 215 277:6 <5>
06 298:4 311:3, 4, 8 21st 82:1, 19 106:17, 5 3:8 98:1 156:8, 10
068ITKWX7 298:5 140 4:9 21, 22 156:23 160:21 5/20/2021 3:10
15 118:11 151:19 161:21 224:7 244:21 51 3:6
<1> 341:5 22 212:16 52nd 64:24
1 3:6 51:12, 19 156 3:8 365:4, 11, 17 223120585 298:7 53005 4:22
299:14 311:2 379:12, 15850 1:1 4:21 224 3:10 53202 2:7
13 15th 63:13 211:15 239 3:10 53233 2:4
1/7/2020 3:7 173 3:8 23-CV-948 4:19
10 3:10 239:24 179 3:9 23rd 4:13 <6>
245:17, 18 247:9 18 296:11 299:15 24 214:19, 20, 21, 25 6 3:8 98:1 173:6
10/13/2021 3:7 184 3:9 215:11 223:24
10/16/2020 3:9 19 10:10 2413274 298:8 61 3:6
10:41 91:10 1990 8:6 24th 4:12 62 3:7
10:54 91:13 19th 161:15 25886 4:6
100 11:17 43:18 1st 53:4 106:11, 14, 28 1:1 262:15 381:9 <7>
59:6 68:9 78:25 15, 19 28th 4:5 7 3:3, 9 53:23 56:19
82:11 101:25 161:11 296 3:12 67:14, 17 179:5
190:12 206:17 <2> 29th 245:13, 23 313:16 379:18
343:16 2 3:6 59:22, 24 2A 60:25 7/21/2021 3:10
1000 2:7 60:11, 21, 24 61:4, 5, 2nd 171:13 246:20 70-plus-thousand
10th 298:2 6, 7 62:9, 13 183:23 256:5 257:5 375:20
11 3:11 296:1, 3 242:10 310:9 318:13 7th 100:16 101:18
298:22 299:12 378:23 379:13, 19 <3> 102:13 103:18, 21
300:24 301:6 302:3 2:23-CV-948 1:1 3 3:7 60:5, 7 61:13 381:18
11/5/2020 3:8 2:32 267:16 62:13, 15, 18, 21 98:5
11:56 152:3 2:47 267:20 183:24 318:13, 19, 21 <8>
11th 2:3 20 81:25 103:19 378:25 8 3:9 97:20 184:3, 5
12 3:12 301:3, 7, 8, 9 291:5 3.08 3:8 8/6/2020 3:9
302:5, 9 2012 17:19 30 378:2 804.05 1:1
12/14 227:23 228:2 2018 10:11 31:20, 22 300 1:1 4:21 805.07 1:1
12/22 227:23 228:1 2019 160:22 161:21 301 3:13 845 2:3
12/23 227:23 228:1 2020 67:16 100:16 308 3:14 8th 170:13 275:5
12/28 228:1 101:18 102:13 30th 15:5, 6 346:10
12/28/2020 227:21 103:19, 22 170:13 311 3:15
12/4 227:23 171:13 172:22 312 3:19 <9>
12/7 227:23 245:13, 23 246:20 32 308:8 309:23 9 3:10 223:25 224:1
12/7/2021 3:6 2021 63:13 67:16 3rd 185:21 285:4
12:24 152:9 82:19 106:11 156:24 9:08 1:1 4:4
120 226:3 183:19 185:21 224:7 <4> 95 8:6
12th 346:9 244:21 379:18 4 3:7 97:25 98 3:7
2022 275:5 4:05 341:9
2023 53:4

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<A> 294:19 300:4 307:14 219:1, 3, 22 252:25 agree 47:1 63:20

a.m 1:1 336:14 337:2 346:2 270:14 328:2 330:8 113:3 128:13 237:21
ability 150:6 293:13 365:19, 20 367:17 administration's agreed 192:14
298:12, 15 354:25 accusation 92:22, 25 161:24 363:14
355:1, 3 125:25 administrative 8:25 ahead 7:9 14:1
able 7:22 24:24 accusations 90:3 9:1 12:7 112:10 16:15 19:1 21:1, 10,
43:5 60:5, 9 62:21 93:22 102:13 337:22 209:23 213:6 18 22:24 25:25
109:13 182:17 363:24 administrator 8:18 29:10, 17 30:6, 19
285:25 286:2 326:4 accused 212:5 23:13, 17, 23, 24 24:4, 31:11 35:16 38:4
349:10, 22 353:3 214:11 215:23 25 27:6 78:11 39:10, 17, 24 40:17
376:16 accusing 214:4 347:2 145:12 152:25 42:25 43:14 46:15
abnormal 76:7 achieve 316:13 204:16 216:4 251:2, 47:5 48:20 49:20
Absences 224:19 acknowledge 169:25 4, 5 252:6 329:12 53:11, 16 62:1 64:6
Absolutely 93:1 acquire 69:8 355:17, 18, 19 65:15 67:20 72:8, 21
122:20 213:14 acting 79:17 169:10 administrators 24:11 76:3 86:19 90:14
214:24 227:8 229:9 action 47:3, 14, 21, 23 26:4, 15 27:17 28:2, 92:11 93:25 94:7, 21
265:18 53:20, 23 56:9, 21 4, 5 112:11 136:24 96:1, 10, 25 100:1
absolving 239:9 67:4 133:17 152:22 137:7 138:11, 13 104:10 108:7 113:9
academic 17:25 38:7, 165:3 184:21 203:6, 145:2 204:14, 15 114:12 115:20 117:2,
8 79:6, 14 84:2, 8 8 235:8, 15, 16 210:12 15 125:4 128:5
161:1 162:2 165:5 303:21 311:19 administrator's 25:19 129:13, 25 133:22
168:16 222:18 312:25 313:15, 17, 19 75:23 160:24 135:15 136:5 137:14
230:21, 23 251:9 345:9 360:2, 11, 14, admissible 268:6 139:4 140:7, 24
329:18, 19, 20 19, 20 365:7 366:12 admitting 308:22 141:8, 16 142:6, 14
academically 185:16 371:11, 13 381:15 Adria 69:12 205:22 143:5 144:2 145:21
academics 12:18, 25 actions 287:25 207:11 303:4, 7 149:16 152:18
118:14 234:18 350:10 305:4 306:3, 17 153:13 155:7 156:2
236:16 237:24 activities 111:18 307:6, 15 316:17 157:16 161:9 162:7
accept 123:18 actor 376:22 377:8, 317:19 163:8 164:8, 19
129:18 130:10 304:9 14 advanced 17:10 165:10 166:5 167:15
accepting 130:12 actual 290:12 advancing 198:3, 7 169:1 170:8, 21
access 270:2, 4 277:5 Adair 79:13, 15, 16 adverse 133:17 171:19 172:4, 14
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accommodate 151:11 342:19 346:11 advise 305:22 179:10, 18 180:10, 19
297:25 added 238:22 advised 307:15 182:7, 23 183:12
accomplished 75:10 additional 189:24 Advises 3:13 301:13 186:9 187:13, 22
131:5 239:19 373:23 affect 303:20 188:21 194:13
account 254:12 add-ons 345:4 affiliation 4:25 195:16 196:18
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9 20:1 105:21 adhere 145:7 African 18:4, 10, 11 23 213:24 215:17
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184:7 219:2 220:11 5, 9 191:11 196:23 ago 35:7 63:17 268:8 269:18 276:19
245:22 293:11 324:12 328:18 362:1 277:9 278:4, 25

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 3

279:21 282:9 284:4, 268:20 284:12 280:23 285:25 286:2, apart 120:3 130:23,
17 286:17 297:12 315:11 318:25 16, 17 288:14 303:23 25 131:2 292:11
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310:20 311:21 312:4 alleged 110:20 116:2 4 316:3 317:1 321:1 110:3 274:6 276:5,
314:1 316:3, 10, 25 146:10 286:8 287:15 326:19 327:7, 18 12 295:12 377:10
317:10, 22 319:4, 14 346:15 366:20 336:20 337:20 338:3 appear 179:22
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18 325:13 327:7, 18 allow 110:9, 10 343:3 345:13 347:22, appearance 4:25
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331:3 332:22 333:22 129:7 141:25 142:12 20, 24 349:10, 18 appearing 5:5, 14, 16,
334:12 335:8, 17 351:8 358:13 359:19 361:4 18
336:20 337:10, 19 allowed 70:2 371:15 377:20 appears 298:7
338:3, 19 339:12 allowing 111:8 answered 21:17 47:4 applicants 120:22
340:7, 13 341:20 351:10 48:9 105:9 125:3 121:11, 14
343:3, 15 344:7 all's 273:8 128:4, 23 129:11 applied 123:14
345:18 346:19 347:6, alternative 289:14 141:7 142:13 147:4, applying 314:21
19 348:8 349:6 291:2 16, 20 150:3 157:2, appointed 235:9
350:14 351:18 amazing 79:20 15 160:3 174:25 appointment 93:5
352:15 353:9 354:17 ambitious 229:8, 11 182:6, 22 183:11 94:4 160:24 161:25
356:12 357:7, 24 American 18:5, 10, 215:3, 15 234:11 162:11
359:19 360:6 361:3, 11 233:24 236:19 239:5 261:22 Appointments 3:6
18 362:9, 19 364:5 amount 317:12, 13 262:20 284:16, 19 52:3
365:9 367:11 368:3, analysis 337:7, 12 285:1 313:20 319:2 appreciate 44:8
25 369:12, 22 370:7 Andrekopoulos 11:1 323:18, 19 328:18, 23 62:14 178:6 210:10
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377:21 378:18 Angela 78:14, 16, 21 336:9 341:19 348:7, 314:18 315:7, 9
ain't 131:3 202:8, 9, 14, 17, 20, 21 22 350:1, 13, 15 377:7, 25
Aisha 337:23 340:3, 243:24 333:9, 12 351:15 357:17 approached 258:14
10 anonymous 159:3 358:15 359:2 362:8 appropriate 108:16
al 1:1 4:17 232:14 235:2 236:11, 368:23 369:20 370:5 294:18 309:12 379:5
alert 145:17 241:21 12 375:1 approval 22:11, 13,
272:18 answer 21:1 24:13 answering 314:16 17 23:8 25:19
alerted 182:18 28:23 48:24 49:7, 10 315:5, 15 317:15 318:1 346:14
ALICIA 1:1 381:5 53:24 54:2 56:23 answers 121:1 144:5 approve 88:7 344:23,
alledgedly 113:23 64:6 72:8 74:5 346:5 24 376:3
115:7 257:25 75:12 90:14 113:11 anybody 37:10 approved 23:10 88:3
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115:4, 15, 19 127:8 23 128:25 137:2 118:20 124:25 345:15
128:18 129:7 175:4, 139:21 140:24 134:14, 17 182:18 approving 351:12
14 194:19 195:24 143:15 147:13 149:7 192:23 193:17 approximately
215:21 231:4 236:23 161:9 165:12 170:8, 203:15 221:13 151:22 248:9 308:8
265:25 351:2 22, 25 171:19 175:2 234:19, 23 242:20 April 1:1 4:5 381:9
allegations 66:14, 25 176:18, 25 181:14 250:14 252:16 area 13:9, 13, 20
77:23 90:20 100:11 185:11 199:7, 22, 24 253:22 254:7, 24 41:17, 24 123:24
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147:1, 19 148:16, 17 8 228:14 232:6 282:3 304:21 305:22 areas 33:25 38:9
174:10, 14 255:10 233:8 245:21 248:13 326:5 353:3 359:14 arguably 285:14
264:10 265:2, 21 249:3 251:19 275:11 371:25

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 4

argumentative 178:7 181:4 193:3 211:25 230:18 241:3 242:2 253:12

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359:4 361:2, 17 318:14 323:8 326:16 343:13 344:6 365:8 attornies 243:9
369:11 373:4 327:13 336:17 337:1 375:12 376:25 attributes 367:16
argumentive 359:18 365:11 374:13 377:17 attribution 257:13
Armendariz 274:20, 375:17 377:10, 12 assuming 28:23 33:5 at-will 372:12, 15, 18
21 asks 276:23 43:16 373:1, 6, 14, 15
arrived 76:24 assault 267:25 asynchronous 109:22 audience 198:15
articles 274:23 279:16 at-need-to-know Audio 3:12 301:1,
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48:9 69:9 70:21, 24 251:12, 17 252:1, 5 attacks 92:3 auditorium 41:15
73:4, 7, 11 75:2, 4, 6 329:1, 4, 12 330:7, 9, attempted 117:22 198:16
77:1 78:1 110:11, 16 16, 20, 24 332:12 170:15 201:5 authentic 224:14
117:20 125:3, 6 334:7 341:25 attempts 363:24 authenticate 181:10
128:4 129:10 132:4 assignment 138:11, attendance 187:19 295:17
134:24 141:1, 7 13 249:13, 14, 15 193:7 authentication 227:4
142:13 143:1, 8, 11 250:7, 20, 22, 25 attention 66:12 96:5 228:6 297:4, 14, 16
146:3, 7 147:4, 16, 20 251:1, 2, 4, 6, 7, 24 222:10 224:11 authenticity 285:19
150:2 157:2, 15 252:6 253:16 322:20 248:23 273:19 318:4 288:9 302:15
158:25 168:20 325:20 326:9 328:4 339:10 authority 4:8 136:23
169:12 174:25 182:5, 329:2, 3, 7, 13 330:8 attitude 256:4 257:4 138:25 306:16
21 183:10 192:17 341:17, 21 342:1 attorney 5:6, 22 authorized 317:6
198:24 207:17 215:3, 354:4, 10, 12, 14, 21 29:13, 18 36:3, 10, 12, autonomy 306:23
15 221:16, 20, 21 355:4, 8, 16, 17, 22 13 38:13, 14, 16, 20 307:11 355:6
222:16, 19 234:11 356:5, 8, 9 68:10 69:8, 13 70:16 available 69:10
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24 252:13 261:21 135:2 355:25 99:14 208:6, 7, 12 289:7
262:20 265:24 269:9 assistance 62:14 225:17 240:16 Avenue 2:7
275:14 276:11 assistant 11:9, 10, 11 241:22 274:8 279:23, aware 21:8, 11, 19
280:13 284:16 285:1, 76:12 209:23 219:5 25 280:2 281:10 26:1 43:10 89:17
12 286:6, 10 289:25 220:14 249:23, 24 283:5, 12, 22, 24 96:4, 11, 18, 21 98:25
290:12 304:7 319:1 250:16, 19, 22 251:7, 293:2 307:10 314:14 99:2, 7, 9, 10, 11
321:25 322:6, 15 13, 18 252:1 312:11 315:16 316:15, 16 101:5, 22 102:18
328:17, 22 329:9 329:2, 13, 19, 21 319:24 320:3 321:4, 105:10 107:11
331:1 332:2, 21 330:12, 16, 24 331:5, 11, 13, 15, 17, 21, 24 124:25 125:13, 15
334:22 336:8 341:19 6 332:5, 7, 10, 13 336:13 337:5 359:6 127:7 128:1, 14
342:23 347:21 348:6 333:6 334:7 335:14 381:12, 14 129:6, 21 133:13, 23
350:1, 12 351:15 assisted 288:24 attorney-client 210:7 134:15 138:3, 18
354:7 357:17 358:15 306:16 280:3 281:19 283:13 141:3 152:11, 13
359:1 362:8 368:22 Association 203:4 322:3 157:23 158:3, 10, 20
369:20 370:3, 5, 15 assume 22:16 74:14 attorneys 68:16 159:8 163:1 166:12
374:11, 18, 20 375:1 129:19 140:17 319:7 171:12 172:20
asking 27:4 43:8, 10 367:17 attorney's 29:24 173:11 175:13, 22
61:13 62:20 69:15 assumed 107:21 30:3 31:19 36:2 177:7, 10, 13, 14
73:10 93:11, 13, 18, 329:3 69:2, 6 70:8 133:14 185:10 188:17
19, 21 114:3 129:15 assumes 40:16 96:9 163:3 165:25 166:12 191:21, 24 192:1
146:24 150:15 157:6 143:25 145:20 170:14 238:11 240:7 200:19 201:4, 7, 13,

Cream City Reporting, LLC

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14, 22, 24 202:2, 10 Bad 159:12 376:22 256:4 257:4 344:4 Board 3:8 15:21
207:13 233:14 235:1, 377:8, 14 behavioral 145:6 19:9, 10, 12, 13, 17, 25
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12, 19 238:15, 18, 25 336:12, 22 366:20 belief 137:4 254:7 25 22:11, 14, 18
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274:15, 23 275:9, 13 bag 75:7 33:9 34:10 37:22 14 42:17, 21 44:16
276:3 277:23 293:21, balloons 331:22 45:10 61:20 94:24 46:4, 6, 12 47:3, 9, 15,
25 311:12 314:21 banged 304:14 95:13 121:13, 18 16, 17 70:24 71:13,
315:10, 18, 24 316:7, banging 40:3 125:2 138:24 140:3 15 72:15, 17 73:3, 11,
17 323:19 324:2, 8 banned 277:15, 16, 146:25 152:13 16 74:2, 9 75:1 76:5
355:11 20, 21 156:15 163:15 80:12, 13, 14, 16, 17,
awareness 21:15 base 53:3 184:14 197:8 199:16 23, 25 81:19 82:15
44:23 170:12 316:13 Based 20:21 36:19 216:3 222:5 223:11 83:3, 19, 21, 23 86:25
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67:5 81:12 90:10 283:22 292:23 298:4, 94:4 104:7, 14, 21
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bachelor's 17:8 173:4 182:17 192:22 318:13, 20 341:19 17 153:9 155:22
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11:23 17:5 18:18 243:10 247:22 365:3, 10, 14, 18 162:15, 18, 23 165:3
24:5, 12 25:3, 23 279:17 288:1 312:23 370:16 377:13, 23 186:20, 21, 22 187:10,
35:9 37:15 39:19 324:1 372:3 believed 215:12 15, 18 188:17 190:13,
40:24 49:21 54:11, basement 332:14, 15, believes 92:2 15, 16 191:7 192:6
13 56:7 59:13 60:21 19 belive 274:20 193:5, 23 196:10, 15,
62:13 66:6, 12 68:24 basic 215:25 bell 63:7 64:12 20 197:9 198:14
70:5 78:25 81:3 basically 81:14 belong 190:13 199:11, 17 200:4, 7, 9,
83:6 85:17 89:4 112:10 116:17 belongs 190:15 17 203:7, 16 216:5,
94:10, 15 103:3, 4, 24 119:16 179:25 BEN 2:2 5:4 6:11 11 217:16, 25 219:1
104:2, 4 112:13 204:15 209:17 213:8 82:20 221:8 244:21, 23
113:1 114:17 122:8 229:2 250:24 255:10 benefit 140:20 260:9, 21 266:14, 15
123:3, 14 126:16, 17 340:1 363:14 265:20, 22 275:15 287:25 289:6,
127:18 143:16, 20 basis 25:3 46:24, 25 Benjamin 8:8 23 317:15 318:1
146:12 152:6 176:9, 72:14 165:17 217:14 best 298:1 327:7 319:10, 17, 21 320:4,
22 177:20 186:20 241:8 247:19 262:4, 353:5 379:11 9, 11 321:18, 22
188:14 195:21 5, 6 263:1 284:4 better 54:22 198:3 322:4, 6, 12, 13 335:4,
203:24 244:20 350:7, 20 375:21 199:13 296:23 11 340:1, 4, 17
248:24 249:21 battery 267:25 betterment 110:12 344:23, 24 345:8
256:19 257:7 263:17 279:17 352:22 351:11 356:20
271:4, 19 280:16 bearing 170:18 beyond 6:16 149:13 357:20, 25 358:6, 24,
284:14 286:24 294:4 beginning 4:12 bifurcation 186:24 25 359:11 360:1, 10,
304:18 316:21 318:4 91:14 152:7 253:9 bit 73:20 13, 23, 24 361:9
331:15, 17, 25 332:24 267:20 341:14 black 92:18 121:14 362:4, 7, 14 363:2, 5,
341:5, 12 345:11 378:10 285:11, 16 286:9 10 364:21 368:18
350:16 353:16 behalf 2:4, 8 5:3, 16, 287:16 363:25 369:8 370:3 372:10
356:14 363:13 378:8, 18 116:9 200:3 blanket 48:24 373:9 376:3
24 304:10 316:18 317:6 Block 293:24 Bob 197:23 221:19,
background 35:2 behavior 92:4 95:20 blocking 189:3 20 243:3 363:17
169:18 98:21 135:10 141:13 192:23 193:17, 20 body 63:6 198:9
backing 49:2 246:18, 23 247:13 Bluemound 1:1 4:21 296:20

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 6

books 222:20 building 5:23 22:9 calls 48:19 49:19 232:12, 15 235:1, 6,
boss 143:22 64:25 229:1 270:10, 57:5 72:7 74:16 14 236:10, 22 238:16,
Boston 122:8 16, 19 275:21 95:25 99:24 106:3 25 239:7 241:16
bother 274:13 bullet 54:16 242:11 121:2 129:23 139:3, 253:3, 4 254:4
bottom 51:20 123:18 245:19 247:9 11 140:6 142:3 288:23 318:5 333:25
145:22 224:12 bullets 63:4 149:11 152:17 337:4 354:24
225:24, 25 226:20 bullied 92:16 155:17, 25 161:7 cam 296:20
227:11, 19 256:9, 15 bullying 159:21 163:6, 18 167:6 camera 6:16 193:25
371:23 bus 33:19 34:6, 10, 170:6, 20 171:18 194:2
Bowling 98:11, 13, 14 12, 13, 14 36:25 172:2 173:25 176:13 cameras 196:11
100:12 101:7, 23 business 38:6, 8, 9 193:10 195:14 366:3
128:14 171:4, 6, 7 65:20 66:5 137:18 203:10 205:1, 8 CamScanner 239:16
172:7 174:15 175:5, 173:15 230:21 211:4 216:6, 15 canceled 65:22
16 235:23 239:11 233:19 218:7 231:6 232:17 candidate 32:20
240:17 buzzed 278:16 234:6 236:3 237:14 123:22
Bowling's 100:8 buzzing 186:7 238:3 244:25 254:17 candidates 118:11, 12
102:12 257:15 264:14 265:4 119:1 123:19 175:6
break 91:5, 8 150:25 <C> 278:24 282:16 captured 97:7
151:16 266:7, 9 C&I 13:3, 12 14:4, 9 285:22 286:1, 16 car 76:18
341:4 37:20 79:18, 22 288:12, 13 299:19 care 32:21 54:13
breaks 151:4 113:24 122:9 229:17 302:17 303:9 305:15 55:14 252:20 273:24
Brenda 121:23 262:12 270:5, 6, 8 306:9 307:19 310:17 274:11 326:8
brief 108:22 109:2, 4 cabinet 79:19 311:18 317:9 324:4, career 9:10
BRIESEN 2:4 69:4 130:23 131:1, 2, 19 16 325:4, 12 330:4 Carlson 71:7
bring 15:20 27:3 CAL 122:12 183:5 336:19 338:1, 17 Carolyn 92:7
81:5 109:7 164:10, calculated 199:19 343:1 347:18 349:4 Carr 337:23 340:3,
12 204:21 323:24 calendar 208:25 351:15 352:13 10
339:10 363:13 209:1, 18, 25 227:13 354:15 357:6, 23 carried 77:3 80:5
bringing 109:12 call 72:24 73:16 359:17 360:5 362:17 103:25 104:4 161:12,
222:10 74:2, 9 76:4, 7 89:22 364:2 366:1 368:23 16, 17, 22 162:11
brings 164:4 108:14 121:8 148:12 375:1, 12 378:17 232:9 260:8 304:18
broadly 287:11 173:23 241:5, 9, 12 Calvin 29:1, 3, 12 Carrol 68:13, 14, 17
Bronaugh 50:6, 10, 253:14 269:11 31:6, 8, 12 32:4 33:9 238:14 245:11
14, 24 52:22 55:19 282:11, 13, 15, 19, 20, 34:23 35:21, 23 254:14
58:5 59:15 62:3 21 283:23 306:23 37:11, 22 56:24 57:2 carry 104:2
66:17 68:5 72:3 307:1 323:20 332:15 62:6, 24 70:22 81:22, Carver 8:8
90:4 131:1, 7 369:9 335:19 347:14 23 82:6, 10 86:7, 8, Case 1:1 4:17, 19
370:16 372:5, 21 called 7:14 13:21 11, 24 90:3 106:13 19:15 30:9 46:5
Brookfield 1:1 4:22 73:3 76:9 77:22 107:5 108:23 132:17, 53:14 56:19 58:21
brought 26:19 88:6 83:21 96:18 121:4 21 134:1 136:8 70:5 98:22 129:6
119:24 123:14 189:25 190:2, 4, 10 138:25 139:9 142:11 163:23, 24 164:4
248:23 260:7, 10 208:24 242:25 143:1, 11 144:13, 19, 175:18 199:20
273:9, 11, 18 249:13 251:1 269:9 20 153:23 167:21 201:15, 16 202:7
bubble 87:24 276:8, 12 282:14, 21 168:8, 10, 13 169:17 207:14 219:17 236:7
budget 15:18 283:5, 16 284:6 171:13, 22 172:20, 25 275:23, 25 298:4, 5
budgetary 44:25 323:15, 21 330:21 173:23 175:14, 19 303:13, 17, 21 311:20
Buelow 68:25 331:18 334:25 349:1 177:15, 23 178:12 312:16, 22 313:1, 5,
bug 186:7 calling 36:16 77:12, 179:24 180:14 15, 22 314:25 354:20
build 342:8 13 318:5 182:25 183:3, 5 376:23 377:15
220:3 230:14 231:1

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 7

cases 29:25 209:11 Chason 20:2 81:20 Christopher 35:21, 328:13 348:23 358:9
312:18 346:13 105:23 106:13 107:5, 22 86:9 230:24 370:15 379:10
categories 219:8 6, 9 138:18, 19 chronological 160:18 cleared 294:2
category 219:11 139:10 140:14 154:1, church 199:3 clearly 165:13
cause 53:20 67:4 2 155:8 156:22 circumvent 218:4 clerk 5:7 19:25
114:24 160:9 169:20 170:11 citation 284:7 295:13 20:8, 10, 18 28:24
caused 95:21 191:12 218:24 citations 309:7 51:5 186:24 190:16
causes 53:23 56:20 244:22 city 29:12, 18, 24 clients 7:8
303:21 311:19 Chason's 155:2, 21 30:3 31:18 36:1 climate 250:5
312:25 313:15, 17 218:11 69:6 96:22 133:13 clip 300:24 310:25
365:7 check 14:24 62:16 163:3 165:24 166:12 close 41:23 73:20
central 11:16 64:24 101:13 183:20, 22 170:14 191:16 76:19 213:9
79:2 112:17 119:10 196:2 210:20 273:16 238:11 240:7, 16 closed 65:22 80:7
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242:17 277:15 checking 153:2 253:12 279:15, 22, 25 16 99:12, 14 100:21,
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351:4 Chief 3:12 9:18 22, 24 289:22 293:1, 16 125:7 130:3, 4, 6
certainly 53:23 12:9, 10, 17, 24 13:1 2, 24 298:3, 5, 6 154:9, 12, 15, 19
certificate 17:10 54:12, 25 55:2, 5, 8, 306:13, 18, 23 307:1, 155:22 156:24 160:2,
Certified 1:1 3:19 16, 19 69:9, 11 79:6, 4, 7, 10, 17 321:14, 17 4 166:19 167:3
6:7 381:5 14 84:2, 8, 16, 21 323:21 169:4 171:5 245:4
certify 313:25 314:2 96:15 108:25 118:13 claim 365:6 299:9 300:13, 18
381:7, 11 123:23 124:18 claiming 313:3 316:14 320:19, 21
chair 41:12 160:25 162:1, 10 claims 56:19 67:17 363:1 364:13, 15, 18,
challenged 270:21 165:5 203:25 234:17, 313:16 20
chance 77:4 182:14 18 301:12 306:11 Clarification 295:19 closer 76:24 332:25
change 187:9 270:4 307:10, 11 343:22, 25 clarify 298:16 357:8 372:9
294:15 326:10, 13 367:21, 23 372:15 clarity 318:15 closing 300:23
327:11 373:18 Clark 8:11, 12 12:6 clue 119:9 133:10
changed 9:1, 3 13:10 chiefs 13:17 82:3 classes 98:15 138:21 168:5 194:23
239:1 243:11 95:8 288:16, 21 classroom 137:22, 24 200:14, 21 201:18
changes 187:18 306:22 371:24 classrooms 332:17 202:7 208:1 218:20
188:14, 16 191:22 childhood 78:24 clean 20:17 24:8 234:5 254:21 276:20
270:1 277:24 345:7 children 45:15 75:10 77:9, 11 99:8 239:21 303:2, 3 336:6
changing 196:14 109:15, 16 110:12, 13, 379:15 338:20 339:2, 7
Chanin 24:17, 18 16 111:3 113:21 clear 21:14 26:9, 23 343:2, 4 344:17
channels 75:20 114:15, 16, 18, 25 42:18 54:21 60:21 370:19
Chapman 315:20 115:2 122:19 135:19 61:2, 19 63:11 66:16 cluster 263:14, 15, 17
Chapter 4:9 148:25 149:9 185:14, 67:9 71:4 93:18 264:3
charge 231:14 17 247:17, 18 333:7 97:6 113:11 114:21 coach 8:23, 24
281:13 350:4, 19 352:8, 11, 127:6 134:1 138:14 coaches 244:14
charged 267:24 22 353:1, 6 375:19, 149:20 157:21 coaching 101:3, 5
279:16 281:18 282:1 20 376:9 161:20 184:11 171:15 177:23 178:2,
283:6, 25 children's 349:24 206:15, 17 208:25 4 180:2, 15 181:18
charges 268:10 chips 90:18 209:2, 17 210:13 182:10
275:2, 6, 10, 12 chose 144:13, 16 229:21 249:7 255:9 code 355:7
charging 268:6 Chris 168:16 177:9 256:23 269:10 275:9 coincide 376:14
charter 272:7 208:17 209:15 210:7 293:18 313:3 314:4 cold 119:15
231:8, 11 318:8 320:8 324:1 Coleman 222:23, 24

Cream City Reporting, LLC

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colleague 51:4 290:1 271:24 272:5, 8 319:16 342:15 confrontational

293:18 273:17 338:12 377:18 254:25 261:14, 17
come 32:16 75:1 comp 56:11 completed 71:18 confused 164:22
93:19 118:16 122:7 company 339:20, 23, completely 206:7 connection 78:21
126:17 130:2 133:18 25 286:15 366:12 367:7 90:21, 25 175:15
143:20 163:23 compiled 373:8, 9 completeness 227:22 consider 215:25
217:15, 18 223:18, 20 complain 221:3, 8 component 329:20 363:4 374:7, 15
248:17 259:20 complained 221:14 compound 99:4 consideration 84:5,
269:23 271:13 285:10 286:9 287:14, compression 259:14, 15 363:4
276:22, 23 278:6, 14, 22 17, 19 260:5, 15 considered 119:1
15 294:7 304:7 complaining 287:16 comprised 165:15 374:17
307:16 373:8 Complaint 3:15 computer 311:16 consistently 92:16
comes 100:22 119:15 56:11, 15 58:4, 6 331:10 332:4 consult 133:4
127:4 130:13 217:15, 59:2, 7, 9, 14 62:3, 25 computer-based 111:2 consulted 192:2, 5
17 276:1 63:8, 10 64:8, 10 computerized 109:14 contact 40:21 241:2,
comfortable 130:12 66:17, 19, 23 67:11, computers 109:20 13, 18 307:4
289:11 370:11 14 76:11 80:3 85:21 332:6 contacted 180:1
coming 116:22 88:16, 24 89:5, 8, 9, concept 120:14 283:23
189:19 294:6 356:14 14 90:7, 11 91:24 concern 70:23 contained 182:3
commencing 1:1 92:19 98:17 99:4 140:16 150:20 290:9
commensurate 101:6 104:14, 17, 20 164:21 167:10 content 239:17
264:11, 19 105:10, 18 106:7 187:15 361:10 283:11
comment 45:7 73:24 125:14 126:20 128:2, concerned 141:13 contents 180:18
300:7 310:18 336:17, 15 129:4 164:13, 22 354:9 context 18:15 285:20
18 367:9 165:18 170:16 202:3, concerns 80:10, 11, 288:10 291:7 302:16
commented 135:5 11 217:9, 10, 21, 25 16, 18, 24 81:4 89:11 310:17 325:12 339:9
commenting 256:17 218:25 219:9, 13, 23 141:5 157:13, 24 364:3 377:14
comments 45:10 220:2, 22 234:10 160:23 161:5 163:13 continue 85:13
47:13 49:6 150:13 235:7, 23 248:10 171:15 180:2 188:11 91:16 94:13 126:24
244:23 285:6 288:25 311:1 conclude 160:18 150:21 274:13
commission 4:6 318:7 324:24 325:2 concluded 380:11 297:11 375:16
committed 146:11 complaints 21:4 concludes 380:2 continued 84:18
committee 47:17 67:3 79:25 85:23 concluding 1:1 85:10 95:22 103:22
common 376:21 86:1, 2, 12 99:16, 19, conclusion 36:17 126:22 128:16 129:7
commun 361:22 22 105:14, 17, 20 152:17 165:24 continuing 67:2
communicate 65:7, 107:8 124:25 126:1 166:12 253:17
12, 20 72:17 134:13 158:3, 10, 20 159:9, condition 96:7 contract 9:22 10:1, 4
241:13 243:14 252:9 10, 12, 20 164:5, 25 conditions 95:13 16:5, 6, 11, 23 18:21
306:17 165:20 201:23 conduct 68:2 118:10 26:5, 7, 19, 20, 24
communicated 202:18, 19, 21 216:23 157:14 240:17 337:7 27:3 30:15, 16, 25
281:25 343:18 217:13 219:16 220:9, conducted 91:25 31:2, 7, 8, 13, 14, 19,
communicating 24 221:2, 3, 5, 6 96:22 284:21 337:12 20 204:9, 24 205:3, 6
243:21 232:1, 14, 16 235:2 confer 253:1 216:9 372:19, 21, 23,
communication 55:15 236:11, 12 237:11 conference 5:23 24 376:3
56:4, 6 182:20 240:18, 19 242:16 270:24 271:2 contracted 55:14
197:12 272:6 283:12 244:12 248:15 confirm 5:25 contracts 26:11, 14
351:1 271:21 285:15 288:6 confirmation 93:4 27:6, 15 32:1 33:15,
communications 311:10, 12 344:3 94:4, 5 18 34:12, 13, 14
184:21 266:20 complete 16:14 confirmed 203:21 36:14, 21, 25 52:6
284:20 285:21 confirming 127:25

Cream City Reporting, LLC

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204:4, 10 205:15, 19 Cotton's 136:10 262:9 263:6 270:7 DEBORAH 1:1 2:10
372:25 252:24 342:12, 13 344:14 6:13 101:6 240:19
contractural 34:17 counsel 4:24 294:12 345:9, 16, 22 346:3, Debra 37:16, 19
control 44:4 186:21, 315:4 381:12, 14 21 351:12 352:2, 4, 6 December 245:13, 23
22 counseling 167:23, 24 376:12 246:20 257:5 379:18
convention 13:10 177:13, 17 246:19 cut 118:11 decide 368:8
conversation 108:20, count 10:10 decided 218:20
22 109:2, 4, 24 135:5 COUNTY 381:2 <D> decision 56:12 73:16
210:6 253:15 281:21, couple 13:2 54:20 daily 25:3 35:8 86:23 87:8, 10
23 283:1, 20 300:22 59:25 183:16 328:18 241:8 247:19 350:7, 102:19 103:8 118:5,
333:15 343:5 366:20 356:3 20 375:21 6 123:22 124:2, 14,
367:13 368:16 course 157:21 160:9 Dan 24:17, 18 19 126:21 127:4
conversations 146:14 173:15 225:3 298:10 Darienne 10:25 131:22, 25 133:5
243:17 280:2, 19 courses 376:15, 16 30:12 366:21 135:24 143:13 148:5
copied 184:25 294:1 COURT 1:1 4:18 date 4:4 14:24 32:7 149:21, 25 166:1, 14
copies 60:17 92:12 5:1 151:8, 15 293:21, 53:2 63:12 82:2, 21 167:12 175:15
copy 51:3 59:17 24 294:19 304:5, 7 101:11, 15 130:2 204:22 242:16
60:20 97:12, 13 379:16 153:15 170:25 171:2 246:17, 22 247:12, 15,
178:21 239:21 290:7 cover 59:25 228:3 236:6 246:1, 7 20, 22 256:3 257:3
292:6, 8, 10 293:3, 5 covered 100:3 Dated 3:6, 7, 8, 9, 10 258:2 278:17, 18
297:4, 7 379:8 380:9 covering 224:20 100:16 224:7 359:15 371:8, 9, 10
copying 294:5, 12 281:14 dates 10:21 14:25 decisionmaker 124:1
cordial 78:5 COVID 110:3, 4 51:13 63:19 101:11, decision-making
corr 66:19 COVID-19 112:3 13 127:13, 18, 19, 23 124:10, 11 202:5
correct 14:21 20:20 co-workers 255:1 130:14 170:19 decisions 15:21
21:24 22:15, 19 craft 375:8 183:20 227:18, 20 126:23 128:18
29:21 32:19 35:14 create 205:6 246:6 257:22 306:13 307:7, 12
41:5, 19, 22 52:9 created 159:22 day 70:6 71:25 deck 114:15
53:1, 7 55:18 63:23 173:14 272:2 78:12 82:22 105:13 decreases 52:5
71:6 86:15 90:5 credential 36:7 120:18 124:23 defend 212:20
100:9 102:20 113:18 credentials 33:6 167:21 208:23 Defendants 1:1 2:8
123:7 131:23, 24 34:25 35:3, 6 36:5 209:21 210:2 245:8 5:16, 18
143:15 155:24 37:23 227:14 257:23 258:11 defense 298:19 310:4
185:25 211:20 218:2 credible 365:25 263:17 269:5 293:23 Define 215:4
226:21 261:3 272:3 366:10 381:18 definitely 65:23
274:21 309:11 credit 255:5 days 209:1, 24 Defy 3:13 301:13
320:20 334:5 crime 283:25 227:20 degree 17:9 36:20
correctly 16:22 crisis 112:3 113:17, day-to-day 15:17 degrees 17:6, 8, 14
102:17 132:20 20 114:14, 24 135:18 19:5 87:16 251:11 DEGUELLE 2:10
165:19 230:14 273:2 247:16 248:7 329:24 4:5 6:15, 25 194:11
283:5 305:1 342:16 criteria 145:6 de 87:12 delayed 255:6
corroborating 160:11 critics 170:2 deal 25:4, 5 deliver 263:6
Cotton 108:25 Crivello 71:7 Deb 76:11 98:11, 13, delivered 111:7, 11
132:21 134:4 136:13, CROSS 2:2 5:4 14 100:8, 11 128:14 156:4 197:18 263:7
14 138:14, 25 142:20 6:11 312:17 313:18 154:7, 10, 11, 15, 25 378:14
143:1, 8, 9, 12 144:14 current 92:7 355:19 171:4, 5, 7 172:7 delivering 305:9
169:8 190:22 241:18 curriculum 13:7, 23 175:16 193:3 235:23 demand 345:6
245:12 246:9 254:1 45:1 88:4 111:21 239:10 241:17, 19 demonstrated 254:24
278:12 333:25 344:1, 122:12, 14 144:23 Debbie 254:8 demote 54:10 85:1
2, 3, 8 355:5 202:5 222:8, 14 87:9, 12 102:19

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 10

demoted 50:12, 24 14, 22 231:3, 11 66:11 73:8 144:9, 13 disc 297:1 298:8, 15
54:12, 17 66:17 232:13 187:2, 8 190:19, 20, disciplinary 215:25
84:24 85:2, 17, 20 described 56:8 323:5 21 191:5, 6 224:10 discipline 45:2, 3
96:14 101:7, 19 describes 95:12 96:6 227:17 245:14 126:18 211:13, 18, 21
104:5 216:19 232:3, 174:9 248:20 266:20 215:1 250:5 329:25
10 325:23 356:15 describing 52:24 269:25 270:3 272:22 374:5, 24 375:9
370:24 371:1, 4 215:21 318:4 disciplined 152:15
demoting 54:6 89:13 description 253:16 directed 71:24 72:1 214:22 374:2
demotion 52:24 296:24 301:11, 20, 21, 153:4, 7 177:8 178:3 disciplines 213:10, 13
54:21 56:8 86:23 25 306:6 246:9 278:6 289:24 disclosed 162:17
102:5, 6, 10, 11 design 262:9 291:18 320:17 326:5 discoverable 199:20
103:13, 14 104:7 designee 205:18 357:14 358:6 359:6, discovery 308:18
137:23 325:25 desire 377:24 9, 23 369:4 312:18 313:18
deny 94:2 despite 275:2 348:2 directing 61:12 114:2 discrete 292:6 296:8
department 12:13 details 31:5 38:19 direction 88:21 discrim 174:9
13:9, 18 14:7, 8 98:22 117:24 125:10, 193:25 233:3 269:14 discriminated 104:22
111:22 116:5, 8 16 166:20, 21, 25 300:1 360:24 361:22 233:4
117:11 141:20 177:19 178:5 277:11 362:6 381:10 discriminating 233:15
144:24 145:23 184:6 307:25 364:12 374:5 directionally 270:21 discrimination 50:2
195:19 202:6 221:24 determination 215:22 directive 363:5, 6 91:24 104:20 125:1
222:1 229:18 240:13 determine 99:21 directives 162:20 174:10, 14 175:4, 24
252:24 259:15 270:9 153:2 349:22 167:19 234:10 239:3, 10
272:13 298:4 311:11 Detroit 79:15 directly 14:5, 6 240:18 284:13 288:3
317:17 338:12 devices 337:23 55:17 77:1 88:8, 10, 325:1
departments 262:9 339:15 12 140:16 141:6 discriminatory 92:4
depend 223:17 difference 211:14 189:4 190:24 219:4 discuss 82:18 172:10
262:7 265:12, 13, 16 different 12:21 237:2 242:14 306:12 203:6, 15 260:15
depended 75:16 13:19 19:4 22:6 314:5 323:12 381:15 269:1, 11 281:20
Depending 52:12 24:14 25:4 33:16 director 13:2, 3, 4 285:15 312:19 319:9
230:3 39:20 40:2 60:18 50:15 54:13 55:1, 2, 320:9 340:23
depends 74:18 64:18 73:19 74:1 3, 5, 6 56:4 76:5 discussed 43:23 44:3
114:13 369:3 77:8 107:15 111:17 79:17 83:24 84:24 82:16 160:23 162:23
deponent 243:11 115:2, 22 123:2 85:17 96:16, 17 167:1 171:6, 13
deportation 367:21 169:22, 23 178:23 109:24 124:15 241:2 255:17 278:20
deposed 207:22 183:18 185:14 208:6 162:21, 22 190:12, 18 294:21 319:17 320:4
208:22, 24 209:17, 21 226:10, 24, 25 239:14, 196:2 272:13, 14, 15, 340:23 341:1 351:15
deposition 4:15, 20, 15 258:12 260:1 16 273:15, 16 302:8 discussing 154:11
24 6:6, 12, 14 150:15 262:10 340:22, 24, 25 364:7 371:25 372:2 155:1 321:20
207:17, 18 209:3, 9, 354:20 371:24 372:1 directors 13:17, 18 discussion 167:4
10 287:3 380:4 373:20, 22, 23, 25 19:17 24:1, 4 32:15 267:14
381:8 376:18 104:21 235:4 260:21 discussions 104:6, 13
depository 18:2 differently 112:5 288:1 306:22, 25 133:13, 18 319:20
deputies 82:4 88:11, difficult 48:25 335:4 Disposition 3:15
12 230:23 253:18, 21, 22 254:2, dirty 76:13 331:7 dispute 246:10
deputy 29:13 32:5, 8, 15 351:3 disagree 308:24, 25 265:19 291:22
10 33:3 35:11, 19 dig 126:2, 4 309:13 distracting 150:14
37:25 55:17, 20 86:4, dir 191:6 disagreed 192:14 distress 95:22
6 123:25 124:18 direct 13:2 19:13, 14 disagreement 174:15 DISTRICT 1:1 4:18
178:18 180:4 229:22, 22:4 52:14 55:25 175:5 15:3, 4, 8, 11, 17 16:9
24 230:4, 5, 6, 10, 11, 56:3, 4, 6 59:18 19:16 20:23 21:5, 16

Cream City Reporting, LLC

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25:13, 18 35:25 doing 6:3 11:13 25 109:6 110:2, 8, 17, 23, 24 263:13, 23
58:10, 13 76:20 12:11 43:4, 5 60:2 20 111:6, 8, 10 264:2, 11, 12, 16, 22
82:12 85:5, 6 98:20 107:20, 22 109:8 112:14 113:16, 22 265:21 266:2, 21
101:23 110:14 118:9 113:22, 24 115:7 114:7 115:4 116:2, 9, 267:23, 24, 25 268:21
121:3, 5 122:18 150:10, 16 167:24 16, 17, 22 117:6, 10, 269:7, 12, 15, 20, 25
145:1 166:2 169:22 192:16 196:24 25 118:18, 19, 22 271:20 273:1, 5
199:12 204:17 210:19 237:17 119:7, 18, 22 123:17 274:24 275:1, 11, 15
219:24 229:12, 18 253:15 255:4 266:6 124:2, 9, 13 125:1 276:1, 2, 11, 12, 15, 16
233:2 247:23 250:17 274:12, 13 292:13 126:22 127:8 128:2, 277:1, 14, 25 278:12,
259:24 260:2 281:14 309:15 330:2 351:4 17 130:15 131:10 19 279:6, 15, 16, 18
285:14 304:18 358:12 376:15 132:14, 15, 18, 21 283:6, 24, 25 287:21,
312:10, 11, 12 324:23 dollar 317:12, 13 133:6, 8, 15, 19 24 288:6, 18 299:4
325:6 327:10 337:8, 344:25 134:18, 24 135:6, 9, 302:8, 12, 20, 21, 24
11, 13 342:2, 19 dollars 186:18 20, 25 136:15 137:10 303:4, 13, 25 304:4, 8,
352:18, 21 356:2 domain 196:11 138:2, 14, 15, 20 14 305:20 306:4
364:10, 12, 16 372:22 Door 3:11 40:3 140:16, 17, 18 141:4, 307:13 308:9, 20
375:20 376:1, 8 270:15 278:7, 15, 16 5, 13, 24, 25 142:12, 309:25 310:1, 12, 18
DIVISION 1:1 296:10 299:16 300:1, 20 143:1, 2, 8, 9, 12, 311:11 312:1 313:21,
191:15 240:12 325:1 16, 19 304:14, 15 14 144:14, 15, 20, 21 23 322:22, 23 323:6,
doctorate 17:11, 16, 323:7, 9 145:17 146:10, 17, 18, 9, 12 324:23, 24, 25
20 doors 188:3, 16 24, 25 147:2, 19 325:23 326:2 329:8,
document 51:2, 6, 16, 278:14 299:9 300:11, 148:22, 25 149:9 12 330:1, 16 331:10,
18, 22 56:14 59:2, 19, 13, 23 150:1 152:11 153:3, 22 333:10, 19, 25
20 60:6 61:21 62:2, double 126:16 8 158:4, 11 159:1, 25 334:1, 7, 20 335:25
22, 23 63:2, 12, 15, 22, doubt 367:23 160:25 161:5 162:1 336:4 341:16 342:5,
25 64:4, 18, 21, 22 downloaded 292:2 163:1, 14 164:12, 16 22, 23 343:8, 9, 10, 22,
89:16 93:9 100:15, DPI 90:22 91:1, 2 165:1, 4, 25 166:7, 9, 25 344:1, 2, 3, 4, 8, 12,
19 113:2 125:11 184:21 13 167:10 168:22 15 345:15 346:15, 16
156:12, 18, 20, 22 Dr 3:14 6:5 7:19 169:8 170:2, 17 347:2, 12, 13 349:21,
162:5 168:4 170:6, 10:25 11:1, 2, 8 171:14, 16, 22 173:1 23 350:10 353:19
19 173:8, 11, 14 12:18 13:7, 22 19:25 176:8, 10 177:8, 17 354:3, 8, 13, 24, 25
174:18, 22, 23 175:9 20:7, 12, 18, 22 21:5, 183:4, 6 184:24 357:19 360:25 361:6
179:4, 7, 15, 20, 22 16 28:19, 21, 24 39:5, 187:2 190:11, 22 362:5 363:3 364:12,
180:8, 17 181:5, 6, 10, 21 40:7, 11, 21, 25 192:7 193:6, 13, 19, 15 372:3 373:12, 15
11, 20, 22 182:3 41:23 42:21 43:4 22 196:20 197:6, 8 374:8, 11, 12, 20, 22,
209:16 220:7 224:3 44:17 47:20 49:5 198:3, 20 201:5, 6 23 375:4, 9 376:20
225:9, 10 227:5, 19 50:1, 14 77:2, 16 202:15, 25 205:24, 25 378:13
228:6, 11 240:1, 4 78:7 79:5, 15, 23 206:3, 4, 16 207:8 drafted 196:22
285:19 286:14 287:7, 80:1, 4, 5, 19 81:21 209:11 221:12 222:1 197:3, 6
12 288:9 290:14 84:1 85:21, 23 88:2, 229:15 230:1, 3, 12 drafting 288:25
291:13, 16 292:6, 16, 5, 15, 19 90:20 91:24 232:1, 14 234:2, 17 dramatic 110:7
20 293:20 294:1 92:2, 15, 25 93:2, 3 235:7, 24 236:25 drawn 110:24 111:3
296:8 298:2 305:13, 94:3, 9, 17 95:2, 12, 237:1, 2, 3, 22 238:12, drinking 112:2
16 318:8 319:7, 9, 11, 19 96:5, 13 98:10, 17 13, 15, 17, 19 239:1, 2 Driver 10:25 30:12
15 327:20 373:9 100:11 101:3 102:5, 241:4 242:22, 24 79:15 367:18, 22
documentation 109:7 12, 20 103:22, 24 245:23 248:10, 15, 22 Driver's 366:22
documentations 9:7 104:1, 8, 14, 19 250:7 251:12 252:8, due 92:4 188:5
documents 61:20 105:11, 14, 15, 23 9, 11, 15, 16, 24 254:2, 189:18 214:15, 16
64:17 65:4 160:11 106:6 107:1, 8, 9, 12, 24 257:25 258:10 315:15 371:21, 24
184:12, 15 318:16 13, 24 108:3, 15, 19, 261:7, 19, 25 262:16,

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 12

372:1, 4 373:17 elements 215:25 Entitled 3:11, 12, 15 318:17 330:19

duly 7:15 ELLA 2:3 5:6 6:22 296:8 311:1 372:4 347:11
duplicate 98:3 else's 256:18 293:14 373:17 377:23 examination 1:1 3:2
duties 4:8 15:15, 16 313:22 Entries 224:19, 23, 24 7:17 93:8
16:3, 20 18:20 E-Mail 3:9, 10 182:1 225:2 228:9 examined 7:16
249:16, 18, 20, 21, 23, 224:6 337:16 343:18 envelope 304:16, 17, example 36:14 74:22
24 250:7 251:3, 5, 6 e-mailed 197:19 18 88:2 146:20, 21, 22
252:9, 17 253:13 e-mails 297:9 343:8 environment 159:22 148:22 203:12, 14
272:4 328:6, 16, 21 embarrass 363:8, 16 episode 194:1, 2 264:19 265:23 304:6
329:3 330:10, 11 embarrassed 83:2 equal 104:20 324:25 315:23 343:7 369:2
333:10 emergency 113:17 325:1 371:22
duty 294:17 328:11 Emery 70:8, 12 equals 344:9 examples 81:6 369:7
emotional 95:22 ERD 234:9 285:6 excellent 35:1 87:23
<E> employed 24:6 288:25 261:20
earlier 21:21 64:8 117:25 169:25 essential 122:14, 17, exception 184:18
125:6 135:17 158:25 employee 133:2 18 excerpt 308:15
159:2 166:19 171:21 170:17 191:14 et 1:1 4:17 excerpts 150:19
172:16 182:9 240:23 211:22 212:19 evaluation 214:11 308:23
243:25 253:24 254:5 214:22 215:1 216:22 evening 165:4 excluding 158:16, 17,
255:11 257:17 258:6 220:17, 19, 20 225:11 event 323:5 19
261:24 275:13 286:3 240:12 253:19, 23 events 310:12 excuse 9:13 12:22
287:6 300:11 319:6 254:2, 9, 16 277:1 everybody 56:5 62:15 66:2 85:20
326:7 330:7 333:11 335:2, 5 355:23 112:9 151:20 183:6 162:25 191:19 195:9
350:3 351:1 356:1 365:1 372:15 373:16 229:17 291:23 198:23 280:7 281:2
361:10 362:22 381:12, 13 323:13 324:12 356:3 289:23 296:13
364:11 369:14 Employees 3:13 372:22 excuses 234:1, 2
370:18 374:4, 10 19:16 20:5 145:7 evidence 40:16 96:9 executive 80:14
early 67:16 78:24 169:22 190:25 204:5, 143:25 145:20 160:22 162:24
188:9 362:1 369:3 7 270:4 301:13 146:17, 19 147:1, 11, Exhibit 3:6, 7, 8, 9,
ease 291:23 372:12 373:6 18 160:12, 19 210:25 10, 11, 12, 14, 15
East 2:7 270:16 employment 25:19 211:2, 9 212:1 51:12, 19 59:22, 24
EASTERN 1:1 4:18 52:5 133:17 198:19 230:19 236:3 237:14 60:11, 21, 24 61:7, 14
easy 42:6 176:3 225:4 377:14 238:3 278:3, 23 62:9, 18, 21 97:12, 25
eating 151:13 empowered 317:19 287:19 288:13 98:1, 5 156:10 173:6
ed 186:12 encountering 79:3 307:21 308:22 179:5 184:3, 5 224:1,
educate 111:3 encounters 11:22 327:16 342:4 343:14 14 226:5 239:24
education 17:11, 14 engaged 222:11 344:6 365:8 369:20 245:17, 18 285:7, 9
37:23 69:15 114:16 239:2 240:16 375:12 377:1, 17 289:20 290:20
185:4 203:3 engineer 77:4 evident 17:12 292:11 293:6, 7
educational 32:22 entailed 66:21 exact 9:11 10:21 295:21, 23, 25 296:3
effect 191:23 192:4 entered 276:13 11:14 27:24 32:6 297:18, 21, 24 298:12,
effective 53:3 entering 276:16 46:18 48:3 82:2, 22 22 299:12 301:3, 9,
efficiency 20:1 entire 26:22 29:6 141:22 170:25 246:7 17 302:5, 9 308:3, 6,
105:22 157:12, 22 71:14 228:23 271:9, 255:10 359:21 12 310:7 311:4, 8
309:9 11 302:16 308:17 exactly 14:24 71:16 318:11, 19 378:23
either 83:5 123:18 337:13 342:18 376:8 81:5 111:23 112:22 379:12, 13, 19
160:13 164:13 entirely 293:11 122:6, 10 153:15 Exhibit/s 3:15
179:20 181:23 196:7 entirety 379:18 190:8 226:23 246:1 Exhibits 3:5 98:2
226:23 241:16 283:9 290:6 309:12 296:18

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 13

existing 264:12 281:25 283:15 294:7 17 134:7 135:1 File 3:12 88:15
exists 327:17 297:14 348:2 137:19 172:6 173:19 290:10 375:4
exit 58:19, 22, 24 facts 40:16 70:19 184:11 187:23 Filed 3:15 4:17
318:6 96:9 143:25 145:20 204:13 233:9 246:6 59:1, 7 88:24 98:17
exiting 199:12 160:17 211:25 250:4 263:5 277:3 104:19, 24 105:2, 5
expect 341:4 230:18 237:14 238:3 279:2 327:19 330:9 201:23 202:3, 11
expectations 263:10 278:3, 23 287:19 340:1 345:22 354:9 235:23 240:19
expected 232:15 288:12 293:11 357:8 374:5 293:18, 20, 23 311:1,
expedite 309:15 307:21 327:16 fashion 53:17 110:7 10 312:24 313:6
experience 16:12, 24 343:13 344:6 365:8 fear 39:25 files 234:9 290:16
18:21 33:21 140:2 375:12 376:25 featured 274:24 filing 106:7
192:22 204:18 377:17 federal 185:3, 8, 23 filled 122:21, 24, 25
215:11 223:11 factually 140:15 feedback 81:2 124:16 filling 79:17
355:21 failure 88:2 185:2, 22 feel 130:12 135:9, 11 final 118:17 124:14
experiences 33:24 Fair 9:9 16:1, 11 136:22 264:10, 15 127:4
expiring 4:13 19:22 21:14 27:11 feels 237:22 finance 29:14 82:8
explain 23:1 96:20 33:6, 11, 12 39:2 Felicia 128:15 168:14, 15
145:3 155:9 370:22, 41:10, 18 46:7 47:3 241:24 242:4 financial 32:21, 23
25 371:12 48:15, 17 49:11 felt 92:18 135:17 33:4, 10, 14 230:25
explained 94:12 58:24, 25 63:25 68:6 female 235:4 370:17 315:22
275:19 69:18 71:10 85:5, 6 Fermin 29:1, 3, 12 financially 381:14
explaining 307:6 99:6 100:8 111:24 31:6, 8 32:4 33:9, 21, find 60:2 107:19
358:5 113:17 114:10 24 34:10, 20, 23 125:24 196:8 242:22
Explains 3:11 296:9 115:17 116:20, 23 35:21, 23, 24 37:11, 284:24 322:19
expounding 284:23 125:14 126:12 132:8 22 56:24 58:9 61:20 323:22 339:19, 21
express 167:10 133:12 137:11 63:16 66:18, 20, 24 finding 167:11
expressed 140:16 159:13 164:5 166:2 70:3, 4, 22 71:23 295:15
141:5 177:24 191:14 72:1 81:22, 23 86:7, findings 171:14
extended 31:23, 25 192:18 195:3 210:2 8, 11 90:3 106:13 fine 18:13 151:10
32:3 226:20 246:5 251:14 107:5 132:17 134:2 266:11 277:23
extensive 292:22 262:18 265:3 270:22 136:8 138:15 139:1, 293:12 321:1, 2
extent 36:16 69:15 277:6 283:7 284:1 8, 17 140:3, 13 finish 100:5 378:22
93:8 140:23 142:5 301:20 305:12 142:11 143:2, 11 finished 66:2
232:5 267:6 282:7 343:11, 23 347:25 144:14, 20 153:23 fire 112:2
286:17 288:14 349:11 360:24 167:21 168:9, 13 FIRM 2:2 5:5 68:2,
303:23 316:25 fairly 178:21 169:8, 17 171:13, 22 5, 8, 25 69:1, 4 70:24,
320:25 321:3, 20 faith 160:15 172:10, 21, 25 173:23 25 71:9, 12, 18, 22
377:20 fall 90:18 175:14, 19, 24 177:15, 72:2, 14, 15 135:21
external 163:2 272:8 falls 204:18 23 179:24 180:14 first 7:15 11:6 62:9,
extra 310:9 346:11 false 142:22 227:10 182:25 183:4, 5 20 79:3, 13 81:2
extraneous 150:13 257:13 339:19 220:3 230:14 231:1 89:2 111:4, 5 119:4,
falsely 214:4 232:12, 15 235:1, 6, 7, 17, 20, 22 120:3, 5,
<F> familiar 11:18 14 236:10, 23 238:17, 7, 21 123:4 127:2
face-to-face 376:9 families 272:9 25 241:16 245:12 129:20, 22 161:3
facilities 33:17, 18 family 95:23 246:9 253:3, 4 254:4 163:16 189:13, 14, 15
137:20 Fantastic 292:15 288:23 318:5 333:25 206:6 209:6 211:14
facing 311:16 far 17:1, 24 18:1, 17 336:13 354:24 224:6 247:9 256:22
fact 72:13 85:2 22:8 43:5 44:3, 7 Fermin's 33:6 57:2 280:23 289:8, 19
188:5 240:15 241:21 56:18 64:4 69:19 58:23 59:14 168:10 292:15, 20 293:9, 10
261:19 275:10 276:3 72:23 85:24 102:15, figure 215:7 271:11 310:10, 22 330:19

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 14

331:16 334:14, 23 formalities 315:8 378:16 getting 73:20 110:21

379:1, 3, 14 format 225:3 foundational 314:20 113:5 115:1, 15, 16
five 193:7 227:18 former 122:3 243:2 four 4:12 97:22 161:4 183:11 219:16
229:11 341:14 378:6 330:20 227:18 267:21 258:1 350:11
Flash 88:3, 5, 7 forth 11:23 46:11 341:10 gist 284:8
flippant 377:9 123:3 195:21 203:25 frame 50:18 53:14 give 28:11 35:5
floating 309:8 257:7 64:4 242:15 292:12 44:10 46:17 48:24
floor 194:3, 18, 20, 24 forward 14:12 15:20 320:2 76:7 81:1 86:1
268:17 277:19, 20, 22 18:12 83:15 84:19 frames 56:18 313:11 100:22 105:5 120:8
333:3 85:3, 7, 10, 16 97:6 frankly 43:3 310:15 126:8 155:9 168:8
floors 333:2, 7 110:14, 18 115:11 fraternity 244:2, 4 203:11 204:23 209:1,
Floyd 312:7, 9, 13, 15, 124:17 135:22 Freiberg 132:23, 25 16 221:2 232:15
24 313:11 314:19 141:21 161:12 162:9 133:1 179:24 180:12 269:14 306:17
315:11 192:16 232:10 233:2 253:10 320:12 355:13
FM 228:16 248:7 258:8 260:8 friends 243:24 244:1 370:21, 25 371:11, 21
FMLA 152:11, 14 269:15, 19 298:17 front 6:17 100:16 378:2
153:3 223:2, 12, 13 333:17 341:25 351:9, 110:25 155:13, 23 given 60:20 61:15
224:20 227:13 228:3, 11 362:12, 15, 16 189:8 253:7 283:21 63:7 70:1, 4 74:22
4, 9, 16, 17 229:3 363:12 370:12 350:5, 19 77:5, 7, 9, 18 81:2
244:13 found 78:4 130:4 fueled 92:3 288:3 89:19 100:25 121:1
focus 12:10 19:8 166:19 242:24 full 4:7 47:17 84:1 128:7 171:15 295:13
24:7 178:7 217:10 334:23 339:20 111:5 161:17 162:11 304:21 305:1 330:12
focused 157:21 foundation 21:9 224:19 245:6 353:22 361:19
foggy 142:18 30:18 72:6 139:20 full-time 165:21 giving 114:4 260:22
folder 197:20, 22 140:6, 21 142:2 function 26:10, 12 283:16 297:3 299:5
folks 148:11 155:18 156:1 161:7 223:8 glimpsed 42:12
follow 7:7 61:6 162:5 163:7, 17 functioning 15:18 glimpses 42:14
181:17 166:4 167:7 168:25 funding 185:9 go 5:19 7:9 14:1
followed 23:21 170:6, 19 171:18 Funds 158:6 16:15, 25 18:18 19:1
178:12, 19 214:3 172:3 173:17 175:9 further 5:20 245:10 21:1, 10, 18 22:11, 24
following 246:18 179:9, 17 180:9, 18 274:11 284:25 24:5, 12 25:25 29:10,
256:5 257:5 181:9, 10 186:5 381:11 17 30:6, 19 31:11
follows 7:16 196:17 218:14 35:9, 16 37:15 38:1,
follow-up 121:2 224:15 225:6 228:7 <G> 4 39:9, 17, 24 40:17
food 33:20, 22 237:6 238:4, 23 gain 212:9 214:6 41:17 42:25 43:14
footers 239:19 244:16, 25 252:3 Garcia 201:19 222:1 46:15 47:5 48:20
forced 200:10 254:18 256:17 302:8, 21, 24 303:13, 49:20 53:11, 16
forcible 344:14 257:15 265:5 277:8 17, 25 304:4, 8 54:10 62:1, 13 64:6
forcibly 149:25 278:24 279:20 282:7 305:14, 20 65:15 66:13 67:20
153:4, 8 248:21 285:20, 23 286:14 garden 332:15 72:8, 21 75:13, 22
249:4 374:8 288:11 292:18 gathering 210:25 76:3 77:20 78:2, 3
Ford 202:8, 9, 14, 17, 295:18 300:6, 7 211:1, 9 84:20 85:3, 10 86:19
20, 21, 22, 24 302:15 303:9 305:16 general 43:11, 15 87:1 90:14 92:11
fore 213:25 307:20 310:16 312:3 73:8 120:14 204:10 93:25 94:7, 21 96:1,
foremost 214:1 316:2, 24 319:2 generalities 50:19 10, 25 100:1 101:5
form 66:23 89:18, 19 325:4 330:4 333:21 generally 45:11 104:10 105:19, 20, 21,
167:24 228:22 262:3, 335:16 338:1, 18 54:24 22 107:3 108:7
5, 17 263:1 308:12 343:1, 13 354:16 gentleman 194:3, 9 110:24 113:1, 9
formal 284:11 357:5 359:17 377:18 208:15 114:12 115:20 117:2,
15, 24 118:3 121:6

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 15

125:4 126:15 128:5 328:9, 24 330:5 167:24 169:9 173:16 8, 23 379:10, 12

129:13, 25 131:3 331:3 332:22, 24 177:23 178:2 180:7 380:1
133:22 135:15 136:5 333:22 334:12 335:8, 184:23 186:4 187:11 Good 7:19 67:21
137:14, 23 138:25 17 336:20 337:10, 19 188:7, 23 189:9 70:23 71:12 91:4
139:4 140:7, 24 338:3, 19 339:12 192:8, 15 193:9 151:23 160:15 266:7,
141:8, 16, 21 142:6, 340:7, 13 341:20 194:21 196:22, 24 8, 10 322:10
14 143:5 144:2 343:3, 15 344:7 198:15 199:18 206:6, Gorton 224:6
145:21 146:12 345:11, 18 346:9, 19 20 209:12, 17, 20, 22 225:13, 15, 16, 21
149:16 152:18 347:6, 19 348:8 211:3, 24 212:21 240:10 241:1, 11
153:13 154:20 155:7 349:6 350:14, 16, 20 215:7 220:25 221:17 317:16
156:2 157:16 161:9 351:9, 11, 18 352:15 223:4, 24 224:10, 13 Gorton's 227:14
162:7 163:8 164:8, 353:9 354:17 356:12, 225:5 227:17 228:5 240:15
19 165:10 166:5 24 357:7, 24 359:19 229:20 232:4 233:6, gotten 44:4 348:5
167:15 168:11 169:1 360:6 361:3, 18 18 235:18 237:13 Governance 3:8
170:8, 21 171:19 362:9, 19 364:5 238:2, 20 240:20 191:8 192:6 196:10
172:4, 14 173:18 365:9 367:11 368:3, 242:20 244:6, 15, 24 217:16 340:1 364:21
174:2 177:8, 13 25 369:12, 22 370:7 245:10 248:11 249:1 government 185:9
178:3, 16 179:10, 18 371:3 373:9 375:14 252:2 255:13 257:7, governs 216:19
180:10, 19, 24 182:7, 376:6 377:21 378:18 14, 21 258:3, 7 259:9 grade 346:9, 10
23 183:12 186:9, 20 goes 17:3 123:23 264:13 267:15 268:5 grades 346:11 376:17
187:13, 22 188:21 160:9, 21 163:10 270:2 272:20 275:3 gravamen 125:25
192:15 194:13 290:24 300:16 276:17 278:22 Great 7:13 35:3
195:16 196:8, 18 going 4:3 5:8 6:1 279:19 281:20 282:6 59:13 87:11 97:4
205:10 206:11 13:24 16:8, 13 18:11, 284:2 285:4 289:8, 114:20 119:17 176:2
209:14 210:4 212:2, 14 19:3 20:24 21:6 16 290:8, 10, 22 178:6 181:2 207:3
23 213:1, 24 215:17 30:4, 17 31:9 34:18 292:21 293:1, 22 227:10 239:23 252:8
216:8, 17 218:15, 20 36:15 40:15 42:23 294:8 295:2, 4, 6 328:20 374:13
220:10, 18 221:6 44:11 45:13 47:1, 25 298:16 299:18 300:5 greet 6:9
223:6 224:16 225:7 48:22 49:16 50:5, 17 302:13 303:8, 19 greeted 77:16 78:6
227:8 228:13 232:6, 51:2, 3, 5 52:14 304:22 306:8, 19 Gregory 11:1
19 233:8 236:4 53:12 56:7, 16 59:4, 308:22 310:13 Grenell 68:20
238:5 244:17 245:2 18 62:8, 12 64:2 311:13 312:2, 17, 18 group 120:3, 5, 7
247:11, 24 250:24 67:1 69:14 72:4, 19 313:20 314:5 316:1, guard 193:21 271:5,
252:4 254:19 255:15 73:6 76:1 83:1 85:3, 23 320:1, 24 321:19 16
256:19 258:5 259:11 9 86:17 87:1, 20 322:16, 25 325:3, 11 Gueny 316:7
260:22, 23 267:12 88:20 89:10, 20 326:20 327:4, 15 guess 24:23 42:18
268:8 269:18 276:19, 90:12 91:10 92:9 328:7 333:1, 20 68:24 74:21 111:24
22 277:9 278:4, 14, 93:7, 23 94:13 95:24 336:16 337:25 114:21 115:4 158:18
25 279:21 282:9 96:8, 23 102:21 338:16, 24 340:5 165:12 174:4 198:1
284:4, 17 286:17 113:7 114:22, 24 341:8, 12, 18 342:25 224:11 232:7 244:3
290:2 294:4 295:2, 9 119:4 120:25 121:19 343:12 345:24 256:1 257:22 269:10
297:12 300:9 302:18 123:24 128:10, 20 346:17 347:4, 16 275:6, 9 278:10
303:11, 23 304:24 129:9 132:5 134:19 349:25 352:12 353:7 291:1 307:4 314:20
305:18, 22 306:10 135:13 136:3, 25 356:10 357:2 359:16 370:15
307:23 310:20 137:12 139:2 140:5, 360:3 362:6 363:7, 9 guessing 17:13 27:21
311:21 312:4 314:1 12 141:14 142:1 364:1 365:5 366:3 guidance 315:15
316:3, 10, 25 317:10, 146:4, 5 147:3 152:3, 367:6, 15 368:7 guidelines 189:1
22 319:4, 14 321:5 6, 16 153:11 154:15 373:2, 19 374:25 214:2 216:10 372:9
322:18 324:6, 18 155:5 161:6 162:4 375:11 377:16 378:4, guilty 295:15
325:13 327:7, 18 163:16 165:15 166:3 guy 68:18

Cream City Reporting, LLC

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guys 292:24 379:24 harassing 115:19 High 67:12, 15 94:1, 16, 23 95:6, 11,
380:8 159:21 75:22 77:21, 22 18 96:3, 12 97:3, 9
guy's 68:11 harassment 201:1 107:25 108:5, 19 98:6 99:5 100:6
240:18 282:23 130:16 131:11 103:9, 20 104:12, 18
<H> 376:25 377:18 242:18, 19, 21 243:18 106:10, 15, 17, 20
halfway 247:10 hard 121:15 246:10, 12 251:13, 18, 108:10 113:13
Hamilton 251:13, 18 Harlan 70:11, 13, 14 21, 23, 24 263:16 114:19 115:25 117:4
365:4 89:20 329:21 330:18 333:5 121:22 122:1 124:8
hand 51:2, 3 81:10 Harlan's 71:11, 22 335:24 345:4 353:20 125:12 127:16
209:7 381:17 72:2 365:4 374:9, 11 128:12, 24 129:16
handbook 145:15 Hauser 35:22 86:9 higher 259:22, 23 130:7 133:25 135:8,
327:21 168:16 177:9 230:24 highlighted 51:8, 10 23 136:11 137:3, 16
handle 223:2 231:8, 11 highlighting 226:12 138:12 139:7, 16, 23
handled 98:24 head 64:13 213:2 highly 199:6 336:18 140:11 141:2, 11, 18
107:15 371:7 headed 76:20 hire 55:4 118:5 142:9, 19, 25 143:7
handles 100:4 hear 45:24 59:10 124:12, 15 312:13, 23 144:6, 12 146:1
hands 114:14, 18 170:24 179:11 335:10 147:9, 17, 24 149:6,
159:4, 6 305:2 200:22 206:19 hired 118:3 19, 24 150:4, 8, 11, 23
HANNA 2:6 214:23 299:16 300:1 hiring 118:22 123:9 151:5, 9, 18, 22 152:1,
Hannah 5:17 6:18 302:7 338:4, 6 124:13 126:23 127:9 10, 23 153:17, 21
happen 8:5 14:22 heard 50:8 80:3, 18 128:3, 15, 17 129:4 155:11, 20 156:6, 11
56:1 75:24, 25 88:18 106:6 126:19 195:4 145:13 166:1, 14 157:5, 20 158:15
111:9 114:22 124:20 206:17 207:6, 7 175:15 231:4 239:10, 159:16 161:13
152:21 157:7 195:2 211:23 216:4, 11 12 162:12 163:9 164:2,
197:15 241:8 261:1 265:7 277:16 299:15 history 222:19 261:6 11, 24 165:22 166:8
323:23 333:16 302:20 310:9, 11 hit 85:25 167:2, 9 168:7 169:6,
344:19 324:11 334:6 HITCHCOCK 2:2 16 170:10 171:3, 24
happened 25:8 56:2 hearing 205:24 3:3 5:3, 4, 10, 13 6:4, 172:9, 19 173:7, 22
74:13 77:24 84:13, 304:4 305:14, 20, 23 10, 11 7:10, 13, 18 174:6, 21 175:1, 12,
17 88:19 98:25 99:2 306:4 307:16 330:19 14:11 16:18 18:16 21, 25 176:2, 6, 15
102:8, 11, 16 103:12 372:11 19:7, 21 21:3, 7, 13, 177:6 178:1, 20, 25
116:12 118:18, 19 hearsay 269:7 336:18 20 23:5 26:2 27:8 179:3, 6, 14, 21
124:22 129:2, 20, 22 held 4:20 8:14 11:7 28:3, 8 29:7, 15 180:13, 20 181:1, 13
130:9 149:12 167:17 29:22 41:15 130:3 30:10, 23 31:15 182:12 183:2, 15
171:2 172:18 177:20 226:22 285:12 288:5 35:17 36:18, 24 37:4, 184:4, 10 186:14, 19
195:7 196:3 211:15, 346:22 9 38:11 39:13, 18 187:16, 25 189:10
16 221:7 257:11 help 15:20 168:19 40:5, 10, 23 43:7, 20 191:9 193:15 194:14
269:5 279:9, 10, 11, 264:1, 5 45:19 46:20 47:7 195:1, 11 196:5, 25
12 280:5 290:18 helped 375:8 48:5, 12 49:1, 25 198:8, 17, 24 199:2, 4,
312:1 325:25 333:19 helpful 36:13, 21 50:21 51:11, 15 9, 15, 25 200:8, 16
362:2 378:13 37:1, 6 113:4 53:18, 21 56:22 201:2, 11 203:13
happening 99:16, 19, helping 169:11 57:14, 21, 25 59:12 204:3 205:5, 14, 20
23 112:1 114:24 helps 39:22 272:12 60:1, 4, 13, 16, 19, 25 206:14 207:3, 5, 24
116:13, 15, 21 144:22 hereunder 381:16 61:5, 8, 11 62:4, 11, 208:10 209:19 210:9
154:4 Hermann 363:21, 23 19 64:15 65:18 67:6, 211:8 212:8 213:3
happens 25:12 364:7 9, 18, 21 68:4 69:17, 214:9 215:9, 19
129:18 138:9 195:25 Hey 76:21 78:1 25 72:12 73:2, 13, 18, 216:13, 20 217:1, 5
221:2 227:7 265:8 145:8 233:15 330:22 25 74:20 77:19 218:9, 18 219:21
happy 61:5 99:8 hide 78:3 86:21 90:19 91:6, 15, 223:9, 21 224:2, 17
298:16 hierarchy 12:23 18, 21 92:14 93:16 225:12 226:2, 17

Cream City Reporting, LLC

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227:1, 9 228:12, 18 331:8 333:8 334:4, 160:25 161:5 163:1, honestly 34:22 57:3
231:2, 9 232:11, 22 15 335:12, 20 336:11, 14 165:4, 25 166:9, 63:17 82:2, 20 128:9
233:10 234:8, 14 24 337:6, 14, 21 13 167:10, 25 170:17 163:19 171:1 242:24
235:13, 22 236:9, 21 338:5, 13, 22 339:3, 8, 171:14, 16, 22 172:22 246:6 264:21
237:9, 20 238:10, 24 16 340:9, 16, 20 173:1 175:22 176:8, hope 60:1 93:19
239:8, 20, 23, 25 341:3, 7, 15 342:3 10 177:4, 8, 17 178:2, 232:20
240:25 243:4, 9, 19, 343:6, 20 344:10, 18 13 179:25 183:4, 6 hopefully 293:3
23 244:10, 19 245:9, 345:21 346:1, 24 184:24 201:6 202:15 Hor 71:1
16, 19, 20 247:1, 7 347:9, 20 348:10, 13, 205:24 206:4, 16 Horowitz 90:2 93:14
248:19 249:6 251:20 17, 19 349:2, 9, 14 207:8 217:11, 13 Hortzwit 71:1
252:7 254:22 255:18 350:9, 23 351:25 221:9, 21 222:11 Horwitz 71:2, 3, 5
256:9, 12, 21 257:2, 352:19 353:2, 13 229:22 230:1, 3, 12, 91:22 93:12, 21
19 258:17 259:16 354:23 355:12 16 232:1, 14 234:2, 238:13
261:5, 13, 18 262:2, 356:16 357:12, 18 17 235:3, 7, 16, 24 hostile 96:6
25 263:8 264:18 358:2, 16 359:8, 24 236:13, 24, 25 237:1, hostility 95:20
265:9 266:9, 13 360:9, 15, 21 361:5, 2, 3, 22 238:6, 12, 13, 159:22
267:9, 12, 22 268:11 12, 21 362:3, 13, 25 15, 17, 19 239:2, 9 hours 328:18
269:21 275:7 276:25 364:8 365:12, 24 241:4 242:5 244:13 house 32:22, 23, 24
277:13 278:8 279:4 366:5, 18 367:4, 14 248:10, 15 267:24 33:4, 10, 17 38:6, 7
280:4, 13, 22 281:6, 368:6, 17 369:6, 16, 268:21 269:12, 15, 25 40:3 137:19 305:10
22 282:12, 18, 25 25 370:13 371:5, 16, 275:1, 11, 15 276:2, 322:23 323:2, 5, 6
283:18 284:9, 22 20 372:13 373:7, 21 11 278:1, 19 279:6, 324:3 378:14
285:3, 8 286:5, 21 374:1 375:6, 25 16 283:6, 24 284:12 houses 109:19
287:2, 9, 23 288:22 376:19 377:4, 25 285:17 286:8 287:14, Howell 184:25
289:2, 5, 13, 19 378:11, 20 379:2, 6, 9, 21, 24 288:6, 18, 24 HR 3:12 26:9, 12
290:11, 21 291:1, 10, 21, 23 380:7 292:22 295:7, 12, 13 54:13 68:1 69:9, 11
16 292:5, 9, 15, 19 hold 4:6, 10 10:10 296:9 299:4 302:12 70:15 89:17 100:4
293:17 294:14, 17 37:18 44:2 60:20 303:4 306:4 307:13 126:1, 2 146:9, 12
295:6, 9 296:2, 7, 14, 107:2 240:11 271:1 308:9 310:1, 12, 18 163:23 164:4 165:1,
17, 22, 25 297:6, 10, 296:13 311:11 312:1 322:22 2 169:18 180:4
19, 23 298:10, 14, 20, holding 41:1, 7, 9 323:9, 12 324:2, 14, 204:21, 22 217:18
23 299:13, 23 300:14 189:3 346:16 347:2 15, 19, 24 325:23 220:11, 12 223:8, 20
301:4, 8, 12, 16, 19 Holiday 3:11, 14 342:23 343:8, 9, 10, 225:10, 16 258:14
302:1, 4, 6, 10, 22 28:19, 21 79:5, 16 22, 25 344:3, 12 260:11, 13, 19 301:12
303:15 304:2, 20 80:1, 4, 5, 19 82:16 361:6, 23 362:2, 5 305:1 355:13 371:7
305:3, 11, 21 306:2, 83:8, 18 84:1 85:21, 363:3 370:9 378:15
14 307:3 308:2, 5, 7, 23 86:13, 24 87:9 Holiday's 82:18, 23 huge 333:6
13, 16, 19, 24 309:4, 88:2, 5, 9, 15, 19 90:7 91:24 98:21 Huh 208:19
19, 22 310:1, 5, 8, 24 90:20 92:2, 15, 25 103:22, 24 104:1, 14 human 23:2 116:5, 8
311:7, 9, 24 312:6, 20 93:2, 3 94:3, 9, 17 107:12 128:2 162:1 117:11 145:24 146:4,
313:2, 13, 24 314:3, 95:2, 12, 19 96:5, 13 170:2 239:1 267:4 5 163:13 203:25
10, 17 315:6, 17 98:17 100:11 101:3, 276:16 285:5 300:6 240:13 252:25 260:7
316:6, 12 317:5, 18 8 102:5, 20 104:8, 19 309:25 324:23, 25 306:11 307:11
318:3, 12, 20, 23 105:11, 15 107:8, 10, 344:4 370:2 323:20, 25 326:7
319:8, 18 320:7 13 110:2 123:17 home 76:20 109:14, hybrid 186:23
321:6, 9, 23 322:5, 9, 124:2, 9, 13 125:1 20 112:9 113:21 hydrant 112:2
21 323:3 324:10, 21 126:22 127:8 128:17 247:19 272:10 hypothetical 167:13
325:9, 15 326:22 130:24 134:23 342:10 350:5 376:11 193:10 203:10 205:9
327:12, 22 328:12, 19 135:20 157:14, 25 homes 375:22 211:4, 25 212:22
329:5, 15 330:14 158:4, 11 159:1, 25 honest 226:9, 15 213:23 215:5 216:7,

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 18

16 223:5, 15 276:18 102:24 150:21 270:7 315:13 342:8

277:8 279:11 285:21, incentive 111:18 influencing 150:14 350:4 375:21
22 306:9, 20 307:22 incident 206:3 infor 87:7 instructional 250:1
327:6 344:6 352:14, 269:12 278:20 inform 19:5 274:11 instructions 109:17
16 353:8 360:4 311:25 informal 47:9 114:18 135:19
364:2 367:8 368:23 incline 41:18 information 46:9, 19 197:23 299:6 320:12
369:21 376:5 include 324:14 86:22 87:13 105:24 350:19 355:13
incomplete 205:9 107:12 110:23 360:22
<I> 211:4, 25 212:22 119:10 126:5, 8, 9 instructor 98:16
ID 4:6 213:23 216:7, 16 139:1 148:3, 6, 8 insult 377:21
idea 14:3 19:4 23:1 223:5, 14 276:18 163:21 170:3 181:21 insurance 325:17
33:14 87:5 100:13 277:8 285:21 306:9, 182:2, 4 196:3, 7 interacting 193:22
109:10 110:23 117:9 20 307:21 310:17 197:3, 7 213:1 interaction 222:9
132:10 148:1 187:14 327:5 344:5 352:13 227:15 228:8 253:24 279:17
188:3, 24 189:12 353:8 360:4 364:2 266:5 267:7 275:16, interactions 254:25
211:11, 12 254:23 367:8 368:23 369:20 17 279:24 281:8, 11, interest 353:5
274:6 283:8 350:18 376:4 15 283:17 325:8 interested 381:14
362:10 incorrect 242:21 364:14 366:7, 8, 16 interfering 73:20
identical 293:5 266:18, 19 371:7 373:8 Interim 9:20 10:3,
Identified 3:5 67:4 increase 189:23 informed 16:23 15, 18 35:22 84:8, 10,
294:8 345:22, 25 259:13 18:19 114:7 125:8 16, 21 161:16 162:10
identifies 57:10, 11, increases 52:4 192:8 165:5, 12, 16, 18
15 295:23 260:22, 24 initialed 173:23 234:17 343:24, 25
identify 18:7 51:22 independent 303:5 Initials 174:5, 7, 8 internal 163:11
59:23 60:5, 9 61:14 independently 303:6 initiated 52:7 123:9 240:18
62:9, 21 116:1 indicate 223:12 163:12 174:5 282:5, interrupt 148:22
117:23 120:19 179:7, 227:12 13 284:24 207:2 292:20
15, 19 181:5 184:12 indicated 141:19, 24 initiative 123:15 interrupting 9:13
193:16, 18 264:1 227:11 initiatives 58:3 255:7 124:6 150:5, 15
297:21 335:10 353:3, indirectly 190:24 inner 173:20 interruption 195:8
15 381:15 in-person 185:16 interview 35:1 37:10,
identifying 267:7 individual 123:21 input 91:23 126:23 14 39:3 57:18 58:20,
ignored 95:7 183:7 320:11 372:24 128:17 129:8 197:8 24 68:3 75:18
immediate 265:14, 15 individuals 25:6 in-service 185:15 100:14 118:15
immigration 367:22 70:21 81:4, 6, 7 83:4 inside 305:8 119:13, 15 120:25
impede 152:22 87:18 112:8, 24 insistence 255:4 121:1 125:16, 19, 21
implementation 255:6 121:3 123:13 125:9 instance 1:1 74:7 126:17 127:1, 19
implementer 366:21 126:17 131:6, 13 134:23 325:22 346:7 166:22, 23 234:18, 23
367:2, 23 134:11, 22 143:16 instructed 245:11 interviewed 34:3
implies 99:25 195:15 188:7 189:19 193:2 290:1 315:3 321:4, 38:22 39:2 68:5
important 35:12 216:19 221:18 242:7, 22 72:11 90:9 92:1
141:20 211:2, 9 11 255:20, 22 259:18, instructing 314:8, 13, 93:12 120:15 122:11
215:13 255:7 20 288:4 307:1 15, 24 315:1 225:21 242:2
improper 167:14 317:16 353:12 instruction 13:8 interviewing 122:6, 9,
285:23 310:19 358:11 372:10, 12, 17 109:8, 10, 14, 18 10
311:17 336:19 364:3 373:6 110:15, 25 111:1, 21 interviews 58:22
367:8 infer 49:13, 17 327:1 113:21 114:17 118:7, 10, 13, 17
improve 256:4 257:5 influence 86:23 162:22 168:9 184:7 119:11, 12 123:1, 3
inaudible 51:14 110:11 124:13 127:3 202:5 229:8, 11 127:2
244:14 247:17, 19

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 19

intimidated 39:5, 12, 207:2, 19 233:7 295:13 324:2, 14, 15, 346:23, 25 355:10
15, 21 40:4 244:7, 16 268:6 19 374:6
investigate 66:25 275:4 282:17 303:20 Jim 240:10, 15 kindergarten 346:10
69:10 117:5 126:12, 311:19 322:17 338:1 317:16 kindly 147:13 292:19
13 129:5 144:9, 14 366:12 367:7 371:2 job 11:14 16:2, 7, 8, kinds 15:22 23:3
195:7, 24 215:1 issue 30:15, 20, 25 20 18:19 29:5 35:1, 34:18 38:19 75:19
241:3 265:10, 13 31:2, 3 53:14 67:3 12, 23 36:17 55:4 85:24 86:3 87:21
339:17, 24 83:22 110:20 200:10 56:2 79:15 81:15 114:9 131:16 137:21
investigated 90:3 260:6, 16 263:11 87:23 89:10, 12 145:25 148:13, 14
126:14, 20 138:19 291:19 90:17 122:7, 9, 12, 14, 152:20 153:15
238:9 265:17 339:21 issued 206:9 17 132:1, 2 168:10 155:10 167:20
investigates 138:23 issues 114:1 227:4 204:19 213:8 249:15, 177:21 178:5 189:20
investigating 105:6 257:25 259:14, 17 18, 20, 24 250:7 192:9 194:5 195:20
238:1 343:11 251:3, 5, 6, 8 252:9, 210:21 217:21
investigation 68:3 item 46:18 52:7 16 253:16 285:12 233:16 237:18
70:17, 20 71:19 82:5 346:22 360:20 286:11 306:6 328:5, 258:15 263:25 265:7,
89:21 96:21 102:12 items 44:25 45:1 11, 16, 21 329:1, 4 10 272:10 279:13
160:10 163:2, 11 47:9 81:11 330:10, 11, 24 333:10 304:15 372:11
181:16 213:12 iterations 262:9 334:20 374:17
215:12, 22 216:1 its 72:17 75:19 jobs 169:23 213:8 knew 11:14 33:9
238:12, 13, 14, 17 180:18 187:9 Jose 201:19 34:10, 20, 23, 24 36:3,
240:17 248:18 Joven 201:19 302:25 11, 12 85:9, 22, 23
265:20, 25 284:11, 21, <J> 303:17 304:4 305:14 99:22 125:8, 9
25 366:15 J.D 69:19, 24 Joven's 222:1 144:22 166:23
investigations 211:10 Jackie 196:12, 20 judgment 12:1, 2 177:18 214:21, 25
213:16, 20 238:16, 18 340:10 364:9 July 53:4 170:13 243:25 261:19
266:1 366:16 James 68:13, 14, 17 224:7 298:2 264:17 323:13
investigative 171:14 225:13, 15, 16 238:14 June 14:23 15:4, 5, 6 324:12
invited 276:21 245:11 254:14 66:8 knocked 323:6
364:18 January 82:1, 19 knocking 323:9
Involunt 249:9 100:16 101:18 <K> know 6:25 7:9 10:8
involuntarily 107:24 102:13 103:18, 21 Katrice 108:21, 24 11:2 13:11, 16 16:2
108:4 133:5 135:25 106:11, 14 156:23 109:3, 4 134:4 21:1, 2, 12 24:17
169:9 248:21 354:25 244:21 136:10, 12, 14 138:25 26:20 27:20 28:19
involuntary 134:10, jargon 34:14, 20, 21, 143:12 241:18 254:1 29:1 31:1, 4, 25 32:2,
18 136:23 168:22 23 37:5 355:5 9, 11 33:5, 23 35:6
249:8, 9, 10 Jennifer 184:25 keep 236:8 326:6 37:16 38:12, 14, 16,
involve 355:3 jeopardy 126:16 keeps 210:11 17, 18, 21, 22 40:1, 19,
involved 107:20 Jeremiah 79:16 KEITH 1:1 4:15 22 43:4 44:4, 6, 9
114:9 119:7 124:2, 86:13, 24 157:14, 25 7:14 76:10 92:3, 17 45:9 46:1, 25 48:3,
10 195:22 268:10, 13 160:25 162:1 172:22 94:18 95:20 287:25 23 49:9, 14 50:22, 24
291:23 201:6 217:11, 13 381:8 52:13 54:1 55:7
involvement 92:6 221:9, 21 229:22 kept 275:1 56:25 57:4, 7, 15, 17,
128:3 230:16 235:2, 3, 15 Key 242:10 22 58:13, 15 59:8, 11
irrelevance 209:13 236:13, 24 239:9 kind 11:23 65:4 63:2, 9 64:20, 23
irrelevant 38:2 242:5 244:13 278:1 74:12 152:22 154:9 70:15 71:8, 14, 16, 22
53:13 56:17 64:5 284:12 285:5, 17 173:13 197:12 217:9 72:2, 8, 10, 11, 25
67:5 90:13 93:24 286:8 287:13, 21 222:21 237:11 264:7, 74:6 75:8, 15 76:16,
102:22 129:12 186:5 288:24 292:22 8 268:24 315:25 17 78:2, 9, 16, 17, 19
199:6, 19 206:7 82:2, 3, 10, 11, 20, 22

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 20

83:11, 13, 16, 17 232:7 234:9 239:12 known 13:12 129:3 262:16, 23, 24 263:13,
85:24, 25 86:5 87:19 240:5 242:8 245:5 139:17 157:8 261:7 23 264:2, 11, 12, 16,
88:5 90:6, 15, 17 246:6, 7, 25 247:5 375:7 22 265:21 266:2, 21
94:10, 13 97:2, 7 248:14, 17 253:25 KOLBERG 2:6 5:17 267:25 269:7, 20
98:8, 10, 13, 22 99:18 263:21, 24 264:7, 21 6:18 60:17, 23 61:2 271:20 273:1, 5
101:13, 15 103:14, 15 268:8, 9, 10, 12, 14, 25 97:16, 19, 25 102:23 274:24 276:1, 12, 15
104:23, 24 105:2, 17 269:4, 9 270:11 183:17, 21 184:1 277:1, 14, 25 279:18
106:7, 24 107:19 271:19, 22 273:25 226:10 239:14 283:25 289:4 291:15
108:11, 12, 17, 18, 20 276:4, 5, 6, 21 277:3, 266:10 267:15 290:4, 296:4 297:2, 8 301:1
111:2, 4, 23 112:3, 9 4, 14, 20, 21 278:5, 13 15, 23 294:22, 25 302:20, 24 304:14
113:5 114:6 115:3, 6, 279:10, 12, 13, 23 295:25 296:20 341:8 308:18, 20 313:23
10 116:12, 13 118:2, 280:6, 8, 9, 19, 20 378:4, 8 322:23 323:6 326:2
4 119:8, 9, 14 120:6, 282:19 285:9 286:6 Kueth 252:8 329:8, 12 330:1, 16
8, 11, 12, 17, 18 121:4, 288:18 291:4, 6 KUETHER 1:1 2:10 331:10, 22 333:19
6, 17 122:6, 10, 11 292:4 294:14, 15 4:16 6:13 11:2, 8 334:1, 7 336:4 342:5,
123:17 125:10, 20, 22 295:3 298:18, 21 12:18 13:7 39:5, 21 22 343:9, 22 344:2,
126:6, 9, 10 128:11 300:18 303:1, 12, 14 40:7, 11, 21, 25 41:23 15 345:15 346:16
131:7, 8 132:23 305:7, 9 310:14 43:4 44:17 47:20 347:2, 12 349:21, 23
134:22, 24 135:1, 4 311:15 312:7, 9 49:5 50:1 51:9, 13 350:10 353:19 354:3,
138:8, 23 139:14, 22 313:9 315:2 316:4, 57:23 60:14 76:11 8, 13, 25 360:25
140:9, 10 142:2, 10, 25 317:3, 23 318:1, 77:16 78:7 79:23 372:3 373:12, 15
16 143:18 145:12 15 323:11, 14, 20 97:24 105:11, 14 374:3, 8, 11, 12, 22, 23
146:3, 4 149:18 324:8 325:6, 7, 10, 17 107:1, 24 108:3, 15, 375:9 378:13
150:11, 23 152:19, 20, 326:3, 11, 14, 16, 23 19 110:8, 17, 20 Kuether's 6:5 13:22
22 154:18 156:5, 12 328:20 330:1, 22 112:14 113:16, 22 42:21 77:2 106:6
157:11 158:1, 13 331:9 332:3, 4, 15 115:4 116:2, 9 117:6 111:8 133:8 135:6
161:15, 18 163:19 333:9 335:13, 21 119:7 121:25 130:15 141:13 246:17, 22
165:14 166:20, 22 336:22 338:15 343:7, 131:10 132:15, 18 247:13 250:7 252:16
168:6 169:2, 17 17 344:13, 19 346:20, 133:6, 15, 19 134:18 255:4 257:4 261:19,
170:23 171:1, 9, 21 22 348:22 352:1, 3 135:9, 20, 25 136:15 25 324:24 333:10
172:8, 23 174:4 353:21 354:2, 11, 19, 137:10 138:2, 15, 20 334:20 335:25
175:3 177:12, 18, 19, 20 357:20, 25 358:23 140:18 141:5, 25 341:16 375:4 376:20
20 178:3, 4, 6, 8, 9 359:9, 14 360:16 142:12 143:2, 9, 12,
181:7 182:9, 10 361:13 363:10, 13, 18 14 145:17 146:10, 18 <L>
184:2 188:6, 7, 8 364:6, 9, 11 365:23 148:22, 25 149:9 labor 133:2 311:11
190:5, 8, 10, 11 366:4 372:16 373:1 150:1 153:3, 8 154:7, lack 54:22 198:3
193:19 194:4, 25 374:2, 4, 21 375:4 10, 11, 16, 25 164:12 199:13 237:5 254:18
195:4, 20 196:19 376:11 377:7 378:12, 165:1 166:7 168:22 286:13 288:8, 11
197:17, 19, 20, 25 25 379:11 169:8 183:20 193:3, 300:7
198:14 200:24 knowing 16:7 6, 13, 19, 22 195:10 lacks 139:19 140:6
201:15, 19 202:1, 8, 9, 140:20 262:1 292:25 198:3, 20 201:5 142:2 155:18 156:1
13 204:4 205:23 300:6 202:25 205:25 161:7 163:7, 17
206:1 207:14 208:2 knowledge 36:19 209:11 226:7 229:15 167:7 168:25 170:5
210:10 211:11 215:5, 49:19 105:13 116:21 240:19 241:17, 19 171:17 172:3 179:8,
6 217:16, 18, 19 140:2 167:18 204:10 242:15, 22, 24 245:12, 16 181:10 196:16
218:10, 19 220:5, 15 212:9 220:9 221:7 23 246:10, 19 248:22 218:13 224:14 225:6
221:15, 17 222:18 222:12 223:10 251:12 252:9, 11, 15 244:16 252:3 257:15
223:2 225:9, 13, 17, 229:16 240:24 253:18 254:2, 8, 15, 265:5 277:7 278:23
19 226:3, 16 229:6, 8 376:22 377:13 24 255:17 256:3 302:15 307:20
230:9 231:13, 21 257:3, 25 261:7 310:15 319:2 325:4

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 21

330:3 338:1, 18 110:22 165:24 licensure 17:2 311:2 353:19, 22

343:1, 13 354:16 253:25 257:24 258:6 342:18 345:4 346:4 375:17
359:17 377:18 268:20 286:7 287:13 lie 128:10 139:17 longer 14:19 15:8
lady 31:17 77:15 294:6 334:6, 19, 22 200:24 20:7 31:18 84:21
122:8 222:2 331:18 335:14 362:5 363:1 lied 139:22 138:16
lady's 222:6 learning 80:15 light 226:22 look 9:7 24:12
language 142:6, 8 leave 198:18 223:13 liking 159:11, 17 26:24 27:4 32:6
Languages 122:4 228:4 256:2 336:5 limited 53:17 149:13 34:1 37:15 42:10, 11
large 241:7 356:14, 15, 17, 18, 24 284:4 62:20 75:23 79:1
Larry 76:6 243:6, 7, 357:14 358:6, 11, 18, limited-term 52:5 112:23 118:2 120:17
8, 13, 17 330:21, 23 21 359:7, 22 369:9, Line 3:15 123:18 127:12, 18 128:7, 8
334:8, 24, 25 335:13, 24 370:21, 22 145:22 206:24 130:14 173:13 184:8
23 leaves 356:25 371:23 197:21 212:7, 25
lattice 204:17 leaving 30:22 lines 294:21 232:8 233:17 236:6
LAURIE 2:6 5:15 led 24:16 25:15 links 290:13 242:10 290:2 332:25
6:20 97:5 98:8 33:9 34:9 list 15:23 18:23 345:11 353:11 372:9,
208:11, 12 left 14:23 15:3 51:25 80:9 81:5, 7 24 373:10
Law 1:1 2:2 4:20 20:22 21:5, 16 58:10, 82:25 83:6, 7, 8, 9, 11, looked 34:2 58:23
5:4, 5 38:17, 23 68:2, 13 59:16 61:22 65:1 12, 13, 16 94:11 194:17 195:5 356:5
5, 8, 25 69:1, 4 70:24, 79:16 304:16 323:24 119:18 229:2 306:25 376:13
25 71:9, 11, 22 72:2, 335:24 336:4 364:9, 353:11 363:7, 13, 15 looking 27:14 28:12
14, 15 166:2, 14 12, 16 372:17 373:5, 12, 13, 32:20 35:6 100:15
185:4, 23 216:14, 18 legal 34:14 36:17, 20 14 111:17 157:19
225:18 37:5 70:1, 4 152:17 listen 144:8 299:8, 10 225:23 233:23
lawsuit 53:13 99:4, 8, 235:8, 15, 16 315:4 listening 337:23 looks 54:15 178:20
9, 10 100:14 102:14 length 111:25 339:14 226:18 233:16, 21
160:7 166:24 312:15 351:15 370:5 literacy 11:15 12:14 Lorena 316:7
lay 111:14 292:17 Letter 3:6, 7, 9, 10 111:13 113:25 lot 25:15 34:14
lead 199:19 59:25 179:24 183:18 229:13 350:22 41:8 74:10, 11
leader 115:12 185:21 197:12 239:1, literature 17:25 107:16 112:8 129:10
leaders 138:7 7, 9 246:8 274:8, 9 litigation 292:23 213:11 294:10
leadership 8:24, 25 293:20 378:13, 25 little 48:21 73:20 340:22
12:8 14:3 18:5 379:18 222:15 263:18 loudly 227:3
213:7 285:10, 16 letterhead 173:20, 21 live 124:18 Louis 17:17, 22
286:9 287:16 240:3, 5 LLC 1:1 lower 5:23 189:6
Leah 83:8, 9 112:24 letters 158:12, 16, 17, local 220:13 260:3 333:1
Leah's 83:22 18, 19, 23 159:3 located 64:23 77:3 LTE 52:5
lean 97:6 160:5 183:16 184:6 location 189:13 lunch 151:11
learn 20:22 59:14 level 5:24 26:10 290:7 lying 194:18 278:21
70:7, 19 79:25 99:15, 40:2 54:11 96:15 locations 185:14
18 110:19 146:9 118:9 121:8 220:15 333:4 <M>
159:20 177:16 196:6 259:23 332:16 333:1 locked 188:4 Madam 151:15
210:22, 23 212:18 368:5 locking 188:15 Maddaleni 69:12
213:15 214:16 levels 75:20 96:14 long 9:10 14:16 205:22 207:11 303:5,
216:22 268:23 112:22 131:4, 6 63:17 85:13 110:24 7 305:4 306:3 307:6
324:22 327:23, 25 169:24 111:3, 21, 24 112:25 316:17 317:19
330:15 336:4 337:22 levied 219:23 117:25 151:1 213:4 Maddeleni 306:17
359:25 360:10 license 138:2 342:20 231:25 248:20 307:15
learned 16:19 40:11, 346:9 296:11 300:25 308:8 main 278:15, 16
13 88:1 90:10 licenses 342:23

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 22

367:19 Marva 363:21, 23 102:21, 25 103:17 232:4, 17 233:6

maintenance 137:20 master's 17:9 104:9, 15 106:3, 14, 234:4, 6, 11 235:10,
majority 362:14 match 34:25 226:22 16, 18 108:6 113:7 18 236:2, 18 237:5,
making 40:11 45:11, matched 35:4, 10 114:11 115:18 13 238:2, 20 239:4,
16 105:14 124:25 matches 115:12, 16 116:25 121:19 124:4 17, 22 240:20 243:6,
126:21 150:13 Mateo 35:21 86:10 125:2 127:11, 14 12, 14, 22 244:6, 15,
175:14 188:25 230:24 231:19 365:3, 128:4, 22 129:9, 23 24 245:14, 17 246:24
271:21 307:7 315:7 11 366:8 133:20 134:19 247:4 248:11, 24
350:4 material 350:5, 22 135:13 136:3, 25 249:1 251:15 252:2
male 57:12 121:18 materials 115:2 137:12 138:4 139:2, 254:17 255:13 256:7,
malicious 25:14 342:14 344:14, 20 11, 19 140:5, 19 14 257:1, 14 258:3
man 92:18 285:11, 345:10, 16, 23 346:4 141:7, 14 142:1, 13, 259:9 261:4, 9, 15, 21
16 286:9 287:17 math 221:23, 24 24 143:4, 24 144:11 262:19 263:3 264:13
363:25 346:7 350:22 145:19 147:3, 16, 20 265:4 266:6, 11
management 145:6, 8 Matt 20:2 81:20 149:2, 11, 22 150:2, 6, 267:6, 11 268:2, 5
159:12 105:23 106:13 107:5, 9, 17 151:2, 7, 14, 21, 269:17 275:3 276:17
manager 12:15, 16, 9, 17 138:18, 19, 23, 23, 25 152:16 153:11, 277:7 278:2, 22
24 13:1 58:2 24 139:10 154:1, 2 19 155:5, 15, 17, 25 279:19 280:1, 11, 15,
managing 87:23 155:2, 8, 21 156:3, 21 157:2, 15 159:14 18 281:19 282:6, 16,
Mann 19:25 20:7, 12, 158:1 169:20 218:11, 161:6 162:4 163:6, 23 283:11, 15 284:2,
18, 22 21:5, 16 28:24 24 16 164:6, 17 165:7, 14, 16 285:1, 7, 18
81:21 105:23 187:2 matter 4:16 13:20 10 166:3, 16 167:6, 286:12, 23 287:18
190:11 191:12 192:7 198:21 269:1 303:20 13 168:24 169:14 288:8 289:11, 15
196:13, 20 197:6, 8, 367:7 375:18 170:5, 18 171:17 290:19, 25 291:3
24 340:11 364:9, 12, McBride 70:9, 10 172:2, 12 173:2, 16, 292:1, 7, 10, 17 293:9
15 MCLEROY 2:6 5:8, 25 174:18, 25 175:8, 294:3, 16, 24 295:2, 8,
Mann's 197:6 12, 15, 19 6:9, 20, 24 17, 20, 23 176:5, 9, 12, 11, 22 296:6, 13, 15,
manual 212:25 7:5, 8, 12 13:24 18, 20, 24 177:3, 25 23 297:15, 20 298:9,
March 185:21 16:13 18:14, 24 178:15, 23 179:1, 8, 11, 18 299:18 300:5
379:17 19:19 20:24 21:6, 9, 11, 16 180:7, 16, 22 301:2, 6, 10, 14, 17, 24
marital 92:4 17 22:22 25:22, 25 181:8 182:5, 21 302:3, 13 303:8, 19
mark 51:4 179:3 27:7 28:1 29:6, 9 183:10, 25 184:8 304:12, 22 305:5, 15,
223:23 239:15 30:4, 17 31:9 35:15 186:4, 8, 16 187:11, 24 306:8, 19 307:19
293:12 36:15, 22 37:2, 7 20 188:19 191:2 308:4, 11, 14, 20
marked 51:12 61:7 38:1 39:6, 9, 16, 23 193:9 194:8, 13, 21 309:2, 14, 21, 24
62:18 98:5 156:10 40:9, 15 42:23 43:13 195:9, 14 196:16 310:3, 13 311:5, 13
173:6 179:2, 5 184:3 45:13 46:13 47:4, 25 198:5, 10, 12, 23 312:2, 14, 22 313:7,
224:1 239:24 290:20 48:8, 18 49:16 50:17 199:1, 3, 5, 14, 18 14 314:1, 8, 12, 23
295:21, 22 296:3 51:7 53:12, 19 56:16 200:5, 13 201:1, 9 315:12 316:1, 9, 20,
301:9 308:6 311:4 57:5, 9, 20 59:4, 23 203:9, 19 205:1, 8, 17 23 317:8, 21 318:10,
318:10 60:3, 10 61:3, 10, 24 206:6, 20, 23 207:1, 18 319:1, 13 320:1,
Marla 50:4, 14 62:8, 17 64:2 65:13 19 208:8, 11, 13 24 321:19 322:2, 8,
52:22 54:6 90:4 67:1, 8, 14, 19 69:14, 209:12 210:5 211:3, 16, 25 324:4, 16
131:1, 7 318:7 356:7, 22 72:4, 6, 19 73:6, 24 212:21 213:22 325:3, 11 326:20
9, 13 358:6 369:9, 15, 15, 23 74:16 76:1 215:3, 15 216:6, 15, 327:4, 15 328:7, 17,
18, 24 370:16, 21 86:17 90:12 91:4, 8 25 217:3 218:7, 13 22 329:9 330:3
372:4 92:9 93:7, 23 94:6, 219:18 223:4, 14 331:1 332:21 333:20
Martinez 121:23 20 95:4, 9, 15, 24 224:13 225:5 226:1, 334:10 335:6, 16
122:2, 3 96:8, 23 97:8, 14, 17, 8, 13, 21 227:8 228:5, 336:8, 16 337:3, 9, 18,
22 98:3 99:3, 24 13 230:17 231:5 25 338:10, 16, 24

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 23

339:6, 11 340:5, 12, meet 70:21 76:21, 22 memory 63:18 86:14, misconducts 117:19,
18 341:6, 18 342:25 77:15 185:2, 22 15 102:17 132:19 23 146:21 148:15
343:3, 12 344:5, 16 203:23 245:12, 22, 24 154:13 165:19 172:6 210:21 241:6
345:17, 24 346:17 340:3, 10 273:2 304:25 340:2 mismanagement
347:4, 16 348:5, 25 meeted 78:6 342:16 158:4, 5, 6, 7, 11, 21
349:3, 12, 25 350:12 meeting 50:15, 19, 22, mental 346:7 159:9
351:14 352:12, 23 23 81:16 87:15 mentioned 108:21 misread 163:17
353:7 354:15 355:9 106:12, 22 107:4 135:7 183:8 missed 158:23 213:5
356:10 357:2, 5, 17, 109:5 110:1 115:10, message 266:25 329:6 366:24
22 358:15 359:1, 4, 13 148:2, 22, 23 messages 65:20 missing 97:18, 19
16 360:3, 12, 17 149:4, 13 153:22, 24 met 77:16 87:17, 18 257:20
361:1, 7, 16, 24 362:8, 154:5, 7, 8, 9, 12, 14, 110:5 153:8 172:21 misstates 18:24 38:2
17 364:1 365:5, 22 24 156:24 161:3, 21 183:3, 5 201:21 61:24 64:3 92:10
366:1, 11, 23 367:1, 6 168:21 169:3, 4, 5, 7 368:14 102:23, 25 116:25
368:2, 12, 22 369:10, 188:4 193:12 195:18 Michael 293:18 127:14 128:23
19 370:4 371:2, 14, 198:14 200:7, 9, 17 middle 329:21 129:11 149:22
19 372:6 373:2, 4, 19, 203:20 244:21 245:6, MIKE 2:10 4:5 159:15 164:17
24 374:25 375:11 7 256:5 257:5, 8, 10 6:15 194:10 172:12 175:17
376:4, 24 377:16 282:3, 5, 7 340:21 Miller 76:6 77:11 188:19 230:17 232:5
378:16, 22 379:4, 7, 363:2 364:19 108:15 243:3, 6, 7, 8, 236:2 238:21 251:15
16, 22 380:10 meetings 41:2, 4, 7, 18 330:21, 23 334:8, 255:14 257:16 258:4
mean 21:25 22:2 14 42:17, 22 44:16 24, 25 335:13, 23 262:19 284:3 319:2
24:7 30:21 34:13 46:4 47:9, 16, 17, 20 MILWAUKEE 1:1 334:10 369:10, 19
39:8, 11 44:2 50:18 72:23 82:15 95:3 2:4, 7 9:11 23:25 370:4 372:6
53:22 65:16 74:6 106:1 111:9 115:9, 24:3 32:15 138:10 mistakes 95:7
86:7 93:11 100:24 17 146:22 148:10 190:1, 3, 25 195:19, mistreat 94:24
118:19 144:16 145:3 154:19 168:18 25 198:19 202:11 mistreatment 94:18
147:10, 12 164:21 186:20, 21, 23 187:10, 203:3 221:4 240:7 misunderstand 334:9
197:11 198:6 215:4 19 188:18 190:13, 15 241:7 260:8, 21 misusing 244:13
219:3 223:17 233:20, 192:23 193:5, 23 277:24 279:16 mixed 75:7
22 257:12 259:17 196:15 199:11, 17 287:25 289:22 298:3, moment 214:7
275:12 289:16 291:3, 200:4 257:7 258:7 5, 6 315:19 335:4 moments 324:11
13 292:3 313:2 277:18 289:7, 23 381:2, 17 money 185:25 186:3
315:21 334:17 351:3, 8, 10, 16, 20 Mims 184:25 monitor 94:13
means 44:14 132:5 352:1, 3 mind 10:22 90:16 month 248:9
259:18 325:10, 19 meets 107:17 161:2 249:21 353:16 months 248:1 356:3
351:21 meltdown 116:17, 22 minute 291:7 293:15, morning 7:19 76:8,
meant 42:2 263:9 member 73:3, 11 16 295:23, 24 311:2 9 243:1 330:21
341:17 75:1 80:12 83:21, 23 minutes 151:19 335:1
media 4:14 91:11, 163:25 187:15 291:5 299:14 341:5 motion 293:19
14 152:4, 8 189:14, 335:11 340:4 362:1 mouth 45:24
16 267:17, 20 272:11 members 74:2, 9 Miriam 71:1, 5, 19 move 14:12 54:21
274:16 339:9 341:10, 80:13, 23 81:19 89:20 90:2 91:22 62:13 67:11, 15
14 378:6, 10 380:3 86:25 104:7, 14 93:12, 14 238:13 84:18 85:7 110:13,
mediation 117:20 107:4 196:20 197:9 321:15 18 113:16 115:10
146:7 170:16 171:7, 221:8 244:23 266:14 misconduct 116:10 130:16 133:5 135:22
8, 9 258:14, 25 259:2, 275:15 320:11 117:24 210:19 185:18, 19 244:20
5 374:17 322:12, 13 340:17 211:10 212:10, 11 248:7 269:15, 19
medical 96:5 336:5 358:25 359:11 362:4 214:7, 10 215:13 341:25 362:11, 15, 16
Memorandum 3:7, 8 363:11

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 24

moved 130:22, 24, 25 274:17 363:9 370:2, negative 40:12 170:3 note 5:8, 20 206:8
131:2, 23 133:9 12 248:4 356:6 noted 228:3
250:24 named 83:20 negotiate 317:6 notes 155:13, 23
moving 88:20 111:1 names 52:13, 20 negotiated 204:5, 12 156:23 256:2 309:20
233:2 294:10 333:16 80:9 83:2, 4, 14 negotiating 204:9 notice 135:5 154:9
370:11 107:19 119:24 negotiation 205:7 209:3, 9 211:22
MPS 7:25 8:18 123:14 353:11 never 11:22 20:12 noticed 154:25
24:19 29:5, 19, 25 362:11, 15, 16 363:11 27:13 42:13 43:23 243:19 341:2
30:2 51:13 65:1, 5, 8, 370:1 57:18 58:23 61:15, notices 272:9
20 66:5 90:6 173:14 Nancy 121:25 122:2, 17 70:4 80:18 87:6 notification 161:5
185:8, 9 201:23 3, 5, 6, 11 88:1, 6 90:24 103:24 notified 92:19
203:15 205:6 210:11 narrow 65:19 107:9 131:5 132:17 168:22 217:12
211:18 212:10, 11 nation 285:14 135:6 156:25 163:21 220:25 221:1
217:4, 6, 24 223:2, 11 National 17:17, 22 164:4, 10, 25 165:13, November 160:21
224:19 228:24 270:4 nature 12:3 38:21 24 167:1 172:23 161:21 257:24 275:5
271:21 272:19 277:1 44:6 58:17 63:2 179:20 181:20, 23 number 4:14, 19
279:15 281:4, 5, 7 75:12, 18 98:23 209:8 210:1 221:7 16:25 22:6 24:14
304:4 311:11 314:22 120:9 131:21 137:8 225:21 236:22 241:1 25:4 27:24 28:11
316:19 317:7 325:18, 167:23 194:17 242:4 252:11, 15 33:16 35:7 64:11
19 335:2 336:5 222:15, 20 241:6 256:22 261:16 72:22 108:14 112:21
342:14 344:13 258:8 284:7 319:19 262:22 264:23 115:22 131:6 156:8
355:21 346:8 266:25 267:1 269:23 160:10 189:22 193:2
MPS's 185:2, 22 necessarily 291:21 273:3, 9 275:16 209:24 212:11
MTEA 203:2, 7, 16, 301:22 317:15 277:16 286:7 287:21 213:25 222:15, 16
18, 20, 21 288:4, 7, 17, necessary 88:3 293:21 300:22 305:2, 226:11 262:8, 10
19 need 9:12 14:23 7 352:24 354:7 267:2, 3, 5, 17 295:3
multiple 98:1 157:12, 22:17 23:8 46:22 368:4 296:1 297:24 298:6,
24 160:12 278:14 49:20 88:7 117:11 new 197:14 229:3 8 301:5 328:3 350:7
municipal 295:12, 14 126:8 131:15 136:15 266:4 272:18 331:5 376:17 379:14
298:6 138:8 171:25 176:21 332:11 334:20 numerous 232:13
mutual 118:6 188:24 199:23 news 272:21 273:1, 5 370:6
247:23 248:5 253:1 newspaper 274:23
<N> 263:18 266:7 280:6, nice 379:23 <O>
name 4:5, 25 6:11 8, 9, 18 290:5, 19, 23 Nicole 274:17, 18, 19 OA 192:6
9:1, 3 13:9 24:25 291:20, 24, 25 295:16 night 87:2, 4 94:11, OAE 162:24 191:5
28:16 32:13, 16 50:5, 296:23 297:11 12 193:25 275:14 217:17 219:20
8 68:9, 11, 12, 17 306:24 308:21 non-renew 27:17 364:21
69:3 70:8 71:1 309:18 314:11 318:1 non-renewal 27:16 oath 7:15 63:24
72:14 79:21 80:5 341:3 344:23 345:13 216:5 262:14 278:19
82:18, 23 83:1, 19, 20, 349:16 366:23 non-renewals 27:19 Obama 367:20
22 84:4, 14, 15 85:2, needed 62:14 85:7 non-renewed 28:15 object 13:24 16:13
9, 16 88:22 94:10, 15 110:15 126:9 135:9 non-whistleblower 18:14 19:19 20:24
103:24 104:1, 2, 4 141:21 168:19 220:10 21:6 29:9 30:4, 17
106:6 122:5 124:17 171:23 185:16 noon 150:24 31:9 36:15 38:1
125:8 135:6 161:12, 207:22 332:3 340:24 normal 173:14 39:6 40:15 42:23
16, 17, 22 162:9, 11 341:1, 24 344:19 normally 114:9 45:13 47:25 48:8
165:16, 17 170:23, 24 375:21, 22 376:14 North 2:3 270:18 49:17 50:17 53:12
197:10 222:3 231:21 needs 22:13 136:16 Notary 1:1 4:6, 7 56:17 59:4 64:2, 3
232:9 242:12 273:14 185:17 291:8 323:22 381:6, 22 65:13 69:14 72:6, 19
333:16 342:2 73:6, 23 76:1 86:17

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 25

90:12 92:9 93:7 Objection 22:22 344:5, 16 345:17 16 282:21 293:25

95:24 96:8, 23 35:15 36:22 37:2, 7 349:3 350:12 352:23 300:12, 13, 17 304:19
102:21 113:7 127:11 39:16, 23 40:9 43:13 357:5, 22 360:12, 17 306:13, 18, 24 307:2,
128:22 133:20 46:13 48:18 61:24 361:1, 7, 16, 24 5, 7, 17 323:13, 22
134:19 135:13 136:3, 67:2 69:22 73:15 362:17 368:2, 22 324:12, 20 328:2
25 137:12 139:2 74:16 93:24 99:3, 24 369:10, 19 370:4 330:7 331:7, 14, 15,
140:5, 22 141:14 104:9, 15 106:3 371:2, 14, 19 372:6 18, 25 332:1, 2, 7, 10,
142:1 147:4 150:21 108:6 114:11 115:18 373:24 376:4, 24 11, 13 336:1, 3
152:16 153:11 155:5 116:25 129:23 138:4 378:16 337:24 339:15
161:6 162:4 163:17 139:11, 19 142:24 objectionable 322:3 364:21 375:5 381:17
166:3 167:13 168:24 143:24 144:11 objections 94:6, 20 officer 79:6, 14 84:2,
173:16 179:8 180:8 145:19 147:21 149:2, 95:4, 9, 15, 25 143:4 8 161:1 162:2 165:6
183:10 186:4 187:11, 11, 22 150:7 153:19 205:17 226:5 294:22 198:2 271:25 272:5
20 192:10, 12, 17 155:15, 25 159:14 338:17 349:12 officers 189:23 190:1
193:9 194:21 199:14, 163:6 164:6, 17 365:22 366:1, 11 officer's 272:6
18 200:13 206:7, 20 165:7 166:17 167:6 368:12 offices 77:8 191:13
207:19 209:13 211:3, 169:14 170:5, 18 objective 212:7 332:5, 14, 18 354:1
24 212:21 216:6 171:17 172:2, 12 observe 195:2 official 93:5
223:4 224:13 225:5 173:2, 25 174:18 obtain 338:8 Oh 5:12 32:25
226:4 228:5 232:4 175:8, 17 176:12 obviously 244:3 33:23 53:18 60:10
233:6 235:18 237:13 177:3, 25 178:15 297:16 301:21 68:11 70:15 88:1
238:2, 20 240:20 179:16 180:16, 22 occasions 140:17 98:3 102:25 107:2
244:6, 15, 24 248:11 181:8 182:5, 21 occurred 67:16 214:7 108:18 112:6 132:23
249:1 252:2 255:13 186:16 188:19 191:2 October 63:13 133:8 138:22 159:17
257:14 258:3 259:9 195:14 196:16 198:5, 172:21 167:10 169:10 179:1
264:13 268:5 275:3 10 199:5 200:5 offer 317:20 198:22 201:19 211:1
276:17 278:22 201:1, 9 203:9, 19 offers 316:18 218:10 228:2 238:16,
279:19 282:6 284:2 205:1, 8 213:22 Office 1:1 4:9, 10, 20 25 263:9 274:2
286:12 299:18 300:5 216:25 218:7, 13 5:21, 22 11:16 20:3, 275:22 280:1 289:8
302:13 303:8, 19 219:18 223:14 4 29:24 30:3 31:19 298:4 306:3 320:1
304:22 306:8, 19 230:17 231:5 232:17 36:2 69:6 75:23 322:10 331:24
310:13 311:14 312:2 234:4 235:10 236:2, 76:12, 20 77:2, 5, 7, 8, 334:16
316:1, 23 320:2, 24 18 237:5 239:4 10 78:5 79:2 105:21, okay 5:12 6:10 7:8,
321:19 322:25 324:4 251:15 254:17 22 108:16 118:10 9, 22, 25 8:3, 7, 14, 17,
325:3, 11 326:20 256:17 257:1 261:4, 119:11 133:14 21 9:13, 19, 21, 24
327:4, 16 328:7, 17 9, 15, 21 262:19 136:10 138:16 10:3, 8, 12 11:6, 10,
333:20 336:16 337:9, 263:3 265:4 267:10 157:11, 22, 24 160:14 13, 16, 18, 25 12:4, 10,
25 338:16 340:5 269:17 277:7 278:2 162:20 163:3, 12, 14 16, 20 13:6 14:12, 16,
341:18 342:25 282:16 285:18 165:25 166:13 19 15:2, 7, 13 16:6,
343:12 345:24 287:18 288:8 293:13 170:15 173:21 11 17:5, 12, 16 18:6,
346:17 347:4, 16 297:12, 13 304:12 186:25 187:1, 2, 4, 8 17 19:8, 24 20:7, 10,
349:25 351:14 305:5, 15, 24 307:19 191:7 192:6, 7 197:6 21 21:4, 14, 21 22:12,
352:12 353:7 354:15 309:5, 10 312:14 208:15 218:5, 11, 16, 16, 20 23:6, 11, 19, 22
355:9 356:10 357:2 315:13 316:9 317:8, 25 219:4 236:15 24:2, 17, 21, 23 25:8,
359:1, 16 360:3 21 319:1, 13 322:17 237:23 238:12 240:8, 17, 25 26:3, 8, 13, 22
364:1 365:5 367:1, 6 324:16 328:22 329:9 13, 16 241:3 242:3, 27:16, 20, 22 28:16,
373:2, 19 374:25 330:3 331:1 334:10 17 253:12 269:8 19, 23 29:1, 7, 16, 22
375:11 377:17 379:3 335:6, 16 336:8 270:13 271:3, 6 30:11 31:16, 23 32:4,
objecting 150:18 337:3, 18 338:10, 25 276:6, 13, 16, 22, 23 9, 16, 25 33:5, 8, 21
339:6, 11 340:12, 18 277:15 280:21 281:9, 35:18 36:3, 5, 11, 13,

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 26

25 37:10, 18 39:1, 4 134:1, 13, 16 135:9 230:13 231:10, 13, 25 335:13, 21, 23 336:12,
40:6, 24 41:3, 6, 9, 20 136:12, 17, 22 137:4, 232:12, 23 233:20 25 337:7, 15, 22
42:5, 9, 14, 17 44:1, 8, 9, 17, 22 138:1, 18, 22 234:9, 17 235:1, 6 338:8, 14 339:4, 9, 17,
16, 19, 22 45:10 46:4, 139:8, 24 140:12 236:22 237:10, 21 19, 23 340:17 341:3,
10, 16 47:8, 12, 23 141:12, 19, 24 142:10, 238:11 239:13, 20 16 342:4, 7, 14, 22
48:6, 13 49:2, 10, 13 20 143:1, 8 144:13, 240:3, 9, 14 241:1, 16, 343:7, 25 344:19, 23
50:1, 4, 10, 13 51:2, 25 145:11, 16 146:16 18, 24 242:5, 10, 22 345:1, 3, 8 347:15
18 52:10, 14 53:2, 8, 147:10, 13, 18 148:6, 243:21 244:2, 20 348:5, 20 349:2, 19
18 54:20, 24 55:7, 16, 20, 24 149:7, 20 245:10, 21 246:8, 14, 351:10 352:9 353:3,
19 56:1, 13, 23, 25 150:23 151:5, 18, 25 16 247:11 248:8, 20 14, 19 354:2, 24
57:15, 18 58:4, 9, 18, 152:24 153:2, 7, 22 249:7, 12, 15 250:10 355:7 356:7 357:1,
23 59:1, 18 60:3, 13 154:1, 4, 17, 24 156:9, 251:3, 21, 25 252:12, 13 358:9 359:9, 14
61:19 62:5, 7, 17 21 157:11 158:3, 16, 21 253:6 254:1, 4, 7, 360:16, 22 361:13
63:1, 11, 24 64:16, 21 23 159:3, 8, 12, 17, 20 23 255:3, 9, 22, 25 362:4, 14 363:1, 23
65:4, 7, 25 66:4, 7, 9, 160:9 161:2, 20, 23 257:20 258:18 259:4 364:14, 18 365:3
11, 14, 22 67:8 68:8, 162:13, 23 163:10 260:15, 23 261:1, 19 366:19 367:15 368:7,
10 69:4, 6, 11, 13 164:3, 12, 15 165:3 262:14 263:9 264:10 8 369:17 370:1, 14,
70:1, 7, 15 71:7, 10, 167:3, 10, 16 169:12, 265:1, 19 266:17 20, 24 371:8, 10, 17
14, 22 72:2, 17 73:3, 17, 20 170:11 171:25 267:2, 11 268:12, 19, 372:3, 14, 16 373:17,
19 74:1, 14, 21 75:14 172:10, 20, 25 173:13 23 269:1, 4, 10, 14 22 374:2, 21 375:7
77:20 78:16, 20 79:9, 174:13 175:25 176:7, 270:11, 18, 25 271:5, 376:1 377:12, 16
11, 22, 25 80:15, 18, 16 177:7, 16 178:11, 15, 20, 24 272:4, 14, 378:2, 20 379:2, 6, 20
21 81:12, 25 82:9, 13 20 179:1, 22 182:13, 18, 25 273:3, 11, 18, old 267:5
83:18, 23, 25 84:11, 17 183:8, 15, 17 21 274:2, 22 275:8 once 129:9 140:19
17, 20 85:1, 4, 9, 13, 184:1, 14, 20 185:8, 276:1, 15 277:1, 14, 142:2 167:17 172:11
18 86:6, 22 87:7, 13 18, 20 186:2 187:4, 8, 17, 19 278:9 279:8 183:3 190:7 205:15
88:1, 8, 15, 18, 24 17 188:12 189:11, 22 281:10, 17 282:3, 22 206:18 219:7 311:13
90:6, 20 91:1, 3, 18 190:5, 7, 10, 23 283:1, 4, 14, 19 314:23 315:12
92:2, 15, 22 93:2 191:10, 18 192:2, 10, 284:10 285:4 286:6 353:23
94:2, 17, 24 95:2, 7, 22 193:1, 5, 16, 21 287:24 288:23 289:2, one-on-one 88:13
12, 19 96:4, 13, 18 194:13, 19 195:2, 6, 13 291:10 293:17 183:6
97:4, 24 98:10, 20, 25 11 196:6, 12 197:16, 295:8 296:7, 25 one-on-ones 72:24
99:11, 13, 15, 18, 21 23 198:2, 22 199:5, 297:10, 20, 23 298:24 ones 160:6 161:18
100:7, 10, 15 101:2, 6, 10, 14 200:9, 17 299:5, 10, 14, 24 196:22 248:16, 17
10, 21 102:2, 4, 18 201:4, 15, 19, 22 300:4, 15, 24 301:2 290:2 309:22
103:16, 21 104:6, 13 202:4, 10, 14, 17 302:2, 11 303:3, 16 ongoing 148:3, 6, 8
105:10, 25 106:11 203:2, 6 204:4, 12 304:9, 21 305:12, 22 online 290:2 291:17,
107:2 108:18 109:2 205:21, 23 206:2 306:3, 15 307:13 18
110:19 111:10 112:6 207:2, 14, 16 208:6 308:2, 11 309:14, 21 on-the-job 16:12, 24
113:3, 19, 22 114:6, 8 209:8 210:10 211:1, 310:3, 25 311:25 18:21
115:3, 15 116:1, 20 21 212:18 213:4, 10, 312:7, 9 313:2, 24 Open 3:12 270:5
117:5, 14, 23 118:5, 12, 15, 19 214:16, 21, 314:4, 18 315:9, 18 296:10 299:16
18, 25 119:4, 5, 6 25 215:10, 20 216:3, 316:7, 15 318:4, 22, 304:17 323:24
120:4, 14, 21, 24 21 217:20 218:3, 10, 24 319:19 320:11, 14, operate 119:16
121:10, 13, 23 122:21 19, 22 219:12, 15 18 321:5, 13, 17 operating 6:17
123:4, 8 125:13, 19 220:8 222:9, 22 322:10 323:4, 14 operational 32:23
126:11, 22 127:17, 22 223:2, 22 224:5, 10, 324:1, 14, 22 325:18 operations 15:17
128:13 129:2, 17 23 225:13, 15, 17, 20, 326:2 328:5 329:6 33:15 87:17 251:11
131:10, 18, 25 132:7, 23 227:7, 17 228:12, 330:15, 23 331:9 329:24 331:12
23 133:4, 8, 12, 17 13, 21 229:15, 20, 25 332:18 334:16

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 27

opinion 262:17 263:2 365:8 368:24 85:12 87:2, 4 94:12 21 340:15 341:25
opportunities 142:21 109:1, 25 110:14 351:22 353:17, 24
opportunity 47:13 <P> 111:23 112:16 357:9
77:14 211:22 212:5, p.m 1:1 152:9 132:12 133:1, 3 percent 11:17 43:18
19 215:23 370:21, 25 267:20 341:9, 13 134:12 142:8 144:4, 59:6 68:9 78:25
371:11 378:6, 9 380:1, 11 20 148:2 192:7 82:11 101:25 161:11
opposed 47:23 48:6, PABICH 1:1 381:5 194:4 204:20 227:4 190:12 206:17
14, 16 49:11, 15 package 323:23 231:23 236:7 245:8 343:16
231:14, 17 275:5 packages 109:18 251:1 258:11 262:8 perfectly 151:10
292:24 358:24 packed 193:12 263:7 264:21 272:15 perform 4:8 85:10,
359:14 packet 97:20 281:13 319:24 13 138:7
opposing 294:12 Page 3:2, 5, 15 52:15 325:24 331:13 335:3 performance 79:10,
option 143:19 363:12 59:19, 20 60:5, 7, 11 345:5 370:10 375:19 11, 12 285:13 288:2
options 132:14, 17, 18 61:13 62:20 67:22 parties 381:13 period 10:14 224:20
171:10, 11 97:16, 17, 19, 20, 21 party 309:1 231:25 354:22
orally 86:11 117:22 156:16 pass 362:6 363:7 permanently 354:10,
order 7:1 109:12 183:22, 23, 24 184:2, passed 319:7 11
137:24 160:18 24 185:21 224:6, 12 passing 109:18 permission 241:2, 5
342:15 360:19, 20 225:24 226:11, 18 pastor 198:22, 25 persisted 246:18, 23
380:6 242:10 247:9 256:11 199:1, 8, 16 200:2, 6 247:14
ordered 101:3 272:10 285:4 374:19 Patrick 315:20 person 31:13 54:16
ordinary 39:14 378:25 379:12, 13, 14 pause 9:5 55:13 56:3, 15 68:18
organization 169:24 pages 59:25 62:9 pay 133:8, 14 203:14, 81:15 105:6 118:14
244:5, 9 97:14, 22 224:24 15 326:6, 8, 9 123:24 125:9 149:21
orientation 145:14 379:1, 3 payments 185:5, 24 151:12 168:20 189:4
Original 3:15 paid 133:11 PD 11:23 196:13 204:18 212:5
256:20 290:7 380:6 paint 41:13 Pederson 96:22 214:11 215:23
originals 289:25 pandemic 85:25 peek 26:20 218:24 229:25
outcome 126:15 panic 323:15 pending 152:20 233:16, 21, 22 250:1,
181:17 paper 81:10, 12 235:8, 14, 16 2, 3 262:12 265:16
out-of-context 308:23 180:25 181:3 231:21 people 25:5 28:14, 271:12, 13, 14 272:11,
outright 148:10 papers 58:16, 19 15, 16 41:8 47:13 12, 16 273:17 280:6,
outside 166:25 304:3 56:5 75:6 78:5 9 322:20 323:17, 19
204:16 259:20, 22 paperwork 124:21 80:24 89:10, 11 92:1 325:19 327:10
260:2 271:6 306:6 par 79:12 106:12 110:10 112:7 333:14, 16 334:6, 14,
outstanding 67:24 paragraph 256:10, 14 113:24 118:16 16, 17, 18, 21, 23
overall 15:16 251:11 paraphrasing 16:24 119:23 120:5, 6, 10, 339:10 359:21 365:2
264:8 74:4 367:18 18 121:24 123:4 personal 49:18
overbroad 22:23 Pardon 191:21 129:21 130:24 75:12 210:11 228:16
29:9 39:7 46:13 parking 74:10, 11 132:13 140:10 336:13 337:5 381:10
48:1, 9, 19 56:17 part 16:5, 8 60:14 148:10 151:11 personally 148:21, 24
65:13 72:20 73:7, 17 137:5 210:25 211:21 152:21 158:6, 7 149:8 267:7
129:24 133:20 213:13 215:13 218:3 159:11, 17 188:5, 8, personnel 210:12, 14,
134:20 137:13 245:13 246:21 12, 25 189:5 191:17 15 375:4
152:17 155:6 164:6 247:14 263:6 293:15 193:7 196:1 203:21 person's 54:18 56:25
173:2 187:12, 21 296:4 300:2 209:1 219:8 221:3 192:24
191:2 203:9 215:16 participated 160:14 233:17 236:15 perspect 334:22
231:6 317:9 328:8 212:13, 17 213:10 237:23 248:1, 8 perspective 253:18
340:6 357:6 360:4 particular 14:7 17:3 259:19 260:4 276:21 254:15 264:25 265:1,
22:10 54:7, 17 78:10 288:7 328:5, 13, 14, 2

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 28

perspectives 160:19 platforms 111:19 54:10, 11 55:8 79:6 predecessor 10:24

255:6 346:6 84:1, 21, 23 89:4, 5 predetermined 145:5
Peter 293:24 play 289:2 92:5 118:1, 9, 22 preference 150:25
Peterson 96:19 played 290:6 298:22 120:1 123:12, 16 151:13
197:23 221:19, 20 299:12 302:5, 9 124:12 126:25 137:9, prepared 7:6 53:24
222:10 242:25 243:2 310:7 311:8 10 138:1 160:25 198:1 205:15
363:17 Player 88:3, 6, 7 161:17 162:1, 19 present 160:17
Peterson's 197:10 playground 74:8 165:5, 21 227:14 169:3 172:8 215:23
phenomenology 18:4 playing 68:24 291:4, 234:24 240:11 245:5 351:17
phone 66:4 73:16 5, 6 302:14 310:25 242:17 272:2 275:1 presentable 78:4
267:2 282:11, 13 please 17:13 51:4 285:6 330:17 334:20 presented 80:24
283:23 323:18, 19 91:19 127:25 147:25 356:15 107:6 132:17 160:20
physically 39:21 150:4 157:18 175:2 positions 8:14 12:21 260:13 262:11
89:15 159:7 181:14 186:15 137:17 314:22 301:22 366:7
pick 121:10, 12 299:11 348:11, 17 positive 23:16 222:9 presenting 46:6
picture 41:13 380:7, 10 336:25 355:23 president 76:6 77:11
piece 17:3 45:5 plethora 19:4 340:25 POSLEY 1:1 4:15, 108:15 197:10
63:8 82:8 91:25 plow 151:2 17 7:14, 19 74:9 242:25 243:1, 2, 3
100:4 111:2 131:19 plus 365:1 88:7 92:17 94:19 330:21 335:3
160:2 165:12 167:17 point 8:1 42:6 98:10 140:17 141:24 presumably 277:5
191:15 194:4 222:18 53:16 58:10 79:5 142:20 143:17 pretty 13:14 35:12
229:3, 13 376:12 83:25 94:14 109:13 152:11 237:3 242:14 73:8, 17 259:7
pinhole 150:18 122:15, 21 126:11 245:11 246:16, 21 268:22
pinpoint 50:23 127:5 138:2 153:7 247:11, 12 256:2 prevent 113:23
pinpointed 346:21 176:3 184:23 185:20 267:23 287:25 115:7 350:11
place 17:23 23:2 213:15, 19 242:11 313:21 336:12, 13 prevented 113:5
27:14 128:8 147:6, 7 245:19 247:9 267:23 341:16 357:19 381:8 preventing 110:20
189:21 192:9, 11, 19, 282:24 294:9, 11 Posley's 92:3 95:20 258:1 351:4
20 283:2 333:15 320:12, 15, 16, 17 253:17 254:14 previous 28:23
340:24 356:18 357:9, pointing 135:21 possibility 154:2 30:13, 14 167:5
14 358:18, 21 359:7, 194:10 208:8 224:18 199:12 previously 38:10
22 Police 3:11 190:1, 3, possible 25:11 86:16, principal 8:8, 15, 16,
placed 18:2 76:11 8, 10 195:19 268:10, 20 252:12 257:20 22, 23, 24 9:21 11:9,
108:16 356:13 13, 16, 17 269:9 possibly 120:17 10, 11, 12 12:6 37:19
369:24 370:14, 20, 22 275:20 276:7, 8, 9, 11 278:11 77:18 78:13 98:16
placement 142:21 296:9 298:3 307:14 post 67:3 122:4 219:5 229:1, 7
places 78:5 105:19 policies 187:18 postpone 309:9 249:23, 24 250:17, 18,
169:10, 11 218:23 188:17, 22 192:11 potential 63:15 64:17 19, 23 251:13, 18
220:21 221:5 216:10 power 23:16 252:1 312:10, 11
Placing 358:4, 11 Policy 3:8 15:20 powers 4:8 75:3 329:1, 2, 19, 21
Plaintiff 1:1 2:4, 10 160:17 166:2 188:2 practice 69:16 330:12, 17, 25 331:5,
5:4, 9, 14 206:10 poorly 235:4 155:21 326:12, 15, 17, 6, 12, 16, 18 334:8
plan 340:23 Portion 3:14 245:7 18, 24 327:1, 2, 10, 24, 335:15
planning 289:17 251:9, 10 308:9, 15 25 principals 78:23
planted 337:23 Pos 206:3 practices 187:9 220:13, 14 262:12
339:15 posed 280:24 336:25 191:22 192:3, 19 332:5 333:5, 6
platform 111:12, 13, position 8:21 9:14, 196:14 211:18 principal's 76:12
14 115:1, 8 135:3 19 10:24 11:6 12:4, 277:24 251:8 329:13 332:7,
342:8 350:6, 20 20, 23 15:15 29:22 practicing 38:16, 20 10, 13
37:18 50:11, 25

Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 29

print 239:18 produces 272:16 provided 34:15

printing 363:7 producing 290:13 145:13 160:12 <Q>
prior 18:25 37:18, product 262:4, 17 185:15 292:13 293:5 qualified 175:7
20 38:2 80:19 production 292:24 366:17 375:24 376:2, quality 113:21
230:18 232:5 238:21 professional 203:5 14 114:16 247:19
257:16 258:4 262:20 profusiously 77:12 Public 1:1 4:7 9:11 350:19 375:21
275:5 319:2 344:14 program 46:2, 3 40:12 44:17, 19 quasi 191:15
priorities 229:12 88:3 270:5 329:22 47:13 49:6 138:10 Question 3:19 13:21
priority 350:8 programming 111:2 184:6 187:19 190:25 25:23 29:8 38:15
private 339:23 250:2 251:10 192:22 193:23 40:6 49:21 53:8, 25
privilege 210:7 programs 78:24 195:25 198:19 56:23 67:23 68:15
280:3 281:20 283:13 progress 144:23 199:11 202:11 221:4 73:19 78:1 91:19
313:4, 8 322:3 progressive 211:18, 241:7 270:2, 5 103:2 108:2 113:11
privileged 279:24 21 374:24 375:8 277:25 289:23 124:9 125:6 127:5,
privileges 4:11 projects 135:2 255:7 293:22 315:19 17, 22, 24 139:22
privy 163:20 248:16 promote 165:20 361:15 377:13, 19 141:1 147:14 149:7
325:8 375:3 363:2 381:6, 22 157:18 158:9 161:2
probably 14:24 82:6 promoted 55:7 88:23 publicly 289:7 341:2 166:10 175:23 176:7,
141:22 212:16 213:9 promoting 80:4 publics 271:21 10, 21, 25 178:7
214:18, 19 promotion 32:13 publish 17:20, 23 179:12, 13 181:15, 25
problem 67:6 173:8 37:12, 25 55:10 published 17:21, 24 182:1 184:11 186:10
248:22 357:19 379:9 75:17 80:6, 9 103:23, pull 82:25 363:12 195:12 200:1 201:3
problematic 246:18, 25 162:15 235:25 pulled 79:18, 19 206:13 211:7 222:19
23 247:13 275:14 361:11 82:25 83:1 84:4, 13, 244:11 245:21 247:2
procedure 15:21 promotional 54:25 15 94:11 168:17 248:14 258:12 268:3
procedures 216:10 promotions 51:25 punching 95:3 270:3 280:14, 15, 24
proceed 7:20, 22 52:3 83:14 punitive 341:17, 22 281:1 283:21 285:23,
291:11, 12 294:21 promulgate 145:2 purchase 342:14, 20 24 286:20 287:10
PROCEEDINGS 4:1 proper 309:7 344:13, 20 345:16 290:4, 5 307:25
380:11 proposal 130:16 purely 288:2 311:17 312:21
process 17:3 23:2 289:9, 14 purporting 140:13 313:25 314:2, 7, 19
54:9 75:13, 14, 18 proposals 46:6, 12 purpose 218:3 276:4 315:5, 9, 15 316:21
89:3 110:24 111:4 48:7 49:5, 11, 15 280:12 320:6, 8 322:11
123:9, 11 124:14 propose 289:5 purposely 337:16 326:19, 23 347:8, 17,
127:9 128:3 137:24 proposed 47:3, 8, 21, purposes 314:20 21, 24 348:4, 12, 13,
201:10 212:10 23 pursuant 1:1 15, 22, 24 349:10, 19
214:15, 17 216:21, 24 proposes 47:14 push 94:14 103:22 350:16 352:20 354:7
217:3, 7, 12 218:1 propounds 145:6 put 23:15 24:23 358:13, 22 360:8
302:24 362:1 371:22, prosecution 310:4, 6 51:6, 13 80:16 93:4, 366:9 370:16 375:18
24 372:1, 4 373:18 prosecutor 298:19 9 94:2, 3 111:14, 15 377:3, 11 378:12
processes 23:20 protected 160:16 112:24 150:7 192:11, questioned 92:20
217:22 protections 157:13 20 194:19, 24, 25 168:1 258:13
procurement 34:18 373:18 204:2 209:6 232:2 questioning 207:1
produce 293:2 protests 44:5 235:24 256:16 243:1
produced 156:22 protocol 188:23, 24 257:22 292:12, 21 questions 73:9 76:8
289:17, 21, 24 290:13 189:5 197:15 326:9 329:8 355:3 89:18 105:9 114:4
292:25 293:1 294:9 provide 34:16 170:3 356:7, 9, 17 358:6 134:24 141:6 144:1
296:5, 17 298:2 185:15 212:12 369:9 376:20 188:15 221:16, 20
342:6 286:15 365:16 putting 46:11 222:17 227:6 243:16
375:23 376:17

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 30

310:4 379:20 266:1 268:2, 4 331:5 333:14 336:1, 240:3 267:3 299:1
quickly 259:7 280:17 281:1, 3 3 353:17, 18 357:9 recognized 41:10
quite 19:2 283:19 284:15 285:4 369:23, 24 374:12, 14, recollection 107:3
quote 43:6, 9 204:23, 286:23 287:4 316:22 22 246:5
25 319:6 321:6, 8 reassigning 322:20 recommend 23:12, 14
Quoting 95:19 348:10, 15, 18 366:24, reassignment 132:22 24:3, 10, 21 32:14, 17
25 367:15 138:20 141:24 35:19 55:10 162:14
<R> reading 11:15 12:13 142:11 143:3 248:4 260:25 261:2 345:8
race 18:6 57:15 63:6, 12 93:9 111:13, 249:11 343:21 recommendation
120:15, 18 131:7, 9 20 113:24 115:2 344:15 374:16 23:4, 7, 9, 20, 22, 25
174:9 233:11, 12 140:21 142:3 156:5 reassignments 52:3 53:9 54:3, 5, 6 79:21
239:3, 10 265:16 162:6 173:12 174:11 328:3 80:6 161:25
284:12 197:17 245:15 rebuttal 285:5 recommendations
race-based 125:1, 14 246:25 247:5, 6, 8 recall 11:7 34:9 51:25 83:15 137:7
127:8 128:2, 18 256:8 285:18 286:13 35:8 41:14 49:5, 14 Recommended 3:6
166:1, 13 167:12 288:10 346:8 350:21 62:24 82:23 90:22 25:1 32:13 37:11, 24
175:15 231:4 reads 155:12 174:13 92:19 107:3, 23 52:17 79:5, 13 102:4
raced-base 202:4 ready 7:19 91:16, 17 108:1, 3 142:5, 7 160:24 161:25
raced-based 175:24 98:9 294:20 362:11, 153:23, 25 154:4, 11 recommending 260:23
races 120:6, 9 169:22 15, 16 155:1 156:3 169:20 reconsideration
racial 174:13 175:4 reality 294:25 170:4, 11 271:12 82:24 370:2
racism 288:2 realize 241:7 283:20 record 4:4 5:1, 20
racist 238:7 really 14:2 31:4 receive 58:16 63:25 7:9 20:17 25:24
Radtke 1:1 4:20 42:16, 17, 19 48:21 89:7, 15 197:16 32:6 49:23 59:21, 24
5:22 63:18, 19 65:24 287:7 60:15, 23 67:25
raise 200:9 203:14, 87:24 113:10 160:5 received 56:11 58:15 91:10, 20 93:10
15 259:7 288:6 172:8 307:24 346:2 62:6 63:15 64:19, 22 103:6 127:6 150:7
raised 41:16, 21 378:1 66:23 77:23 87:6 152:3, 7 158:19
163:13 170:16 re-ask 206:12 108:14 152:24 176:11 177:2 181:5
171:16 286:19 347:7 157:12, 24 158:2 185:25 186:11 194:8
ran 191:16 reason 79:20 110:1 181:21, 23, 25 182:2, 195:13 206:8 208:9,
range 169:21 140:3 146:3 154:14 4 184:14, 19 186:17 11 225:24 227:12
Rash 37:17, 19 38:12 188:9 214:14 269:8 220:1, 7 232:13 243:5, 15 248:25
rate 133:8, 14 272:21 276:8, 9 235:2, 7 236:11, 12 256:16 267:13, 14, 16
reach 170:15 315:8 318:14 259:13 275:16 286:4 268:4 280:17, 25
reached 160:13 reasonably 199:19 287:11 335:18 281:3 284:15 287:4
read 25:23, 24 39:1 reasoning 56:9 360:22 361:9 289:16, 18 290:9, 12,
49:21, 23 63:3, 7 reasons 188:13 receives 94:18 17 291:9 292:11
64:12 67:25 91:19, 241:20 353:18 receiving 109:9, 17 293:15 295:11
20 101:1 103:4, 6 355:25 113:21 114:15, 16 308:21 309:3, 18
111:13 140:12 reassign 136:15 247:17, 18 305:13 314:11 316:22 321:8
155:21 156:16, 18, 20 137:20, 24 143:13 Recess 91:12 152:5 329:17 341:9, 13
157:1, 4, 8, 9, 10 242:17 246:9, 15 267:18 341:11 378:7 348:18 366:25 378:5,
172:25 174:24 175:3 247:22, 25 256:3 recitation 293:10 9 379:1, 10 380:1
176:9, 11, 22 177:2 257:3 333:25 310:11 recorded 381:8
182:11, 15 186:11 reassigned 50:25 reclassification 52:23 recorder 4:23
195:13 224:21 110:17 132:4, 5 reclassifications 52:1, recording 6:7, 12, 14,
236:12, 24 245:10 136:16 137:10, 18 4, 17 16, 19, 21, 23 298:25
248:24, 25 255:23 248:1, 4, 8 249:14 recognize 52:13 299:1 307:14 338:7,
256:25 265:23, 24 325:20 328:14, 15

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 31

9, 14 regularity 236:14 333:1 334:21 359:21 requirements 13:19

recordings 6:1 reject 317:19 363:20, 22 367:12, 20, 146:8 168:3 185:3,
records 34:3, 5 rejected 120:21 21 368:13 23
210:11, 12, 14, 16 123:5 remembers 93:14 Reread 175:3
recourse 23:3 rejecting 72:15 remote 50:15 52:23 resentment 288:3
recreation 191:16 related 53:15, 20, 22 54:9 reset 135:10 141:25
redesign 376:8 56:20 67:4, 20 244:5, remotely 112:19, 21 142:12, 16, 18
redlined 325:10, 14, 8 removal 74:23 134:8 resignation 58:16, 18
22, 24 326:2 327:11 relates 143:25 210:8 remove 74:12 249:5 resolve 170:16
redo 376:12 313:22 379:12 resolved 248:23
redone 112:4 relation 96:6 removed 83:6 resource 203:25
reduced 381:9 relations 133:2, 3 248:21 342:5 363:3 Resources 116:5, 8
refer 113:2 220:17 240:12 removing 379:3 117:12 145:24 146:4,
reference 106:6 relationship 15:10 rendered 124:19 5 163:13 240:13
124:16 290:5 19:9 203:2 147:7 253:1 260:7 306:12
references 121:7 relative 381:12, 13 reopened 123:12, 16 307:11 323:21, 25
referred 234:13 relaxed 47:18 repeat 195:11 326:8
referring 59:8, 11 relevance 20:25 repeatedly 93:3 respect 170:20
146:23 160:8 162:3 259:10 263:18 243:16 respective 191:13
167:4 173:5 217:9 294:23 304:23 316:2, replicate 290:17 respond 92:8, 22, 24
219:19 235:11, 14 24 320:2 365:6 report 19:12 21:25 93:11, 22 244:23
236:8 263:19 291:20 relevant 56:18 64:4 22:5 45:6, 8 55:20, 293:10 324:25
300:19 318:17 325:6 242:15 313:16 323:1 21, 24, 25 56:3, 4 343:10
346:12 356:11 70:16 96:19 110:6 responded 47:20
reflect 243:5 293:15 relocated 353:4 245:11 246:8 254:14 90:6
refrained 243:20 remained 84:16 256:18 responding 139:9
refresh 246:4 remaining 165:4 reported 21:22 22:7 response 49:6 91:23
refreshed 145:15 311:20 56:6 113:25 177:22 156:22 243:11
refusal 255:5 312:23 remains 309:5 Reporter 1:1 5:1 349:16
refuse 312:13 remark 60:22 51:5 151:15, 16, 24 responses 163:13
refusing 180:14 remember 30:9 45:8 223:25 287:1 289:9 responsibilities 15:16
200:1 247:4 312:20 48:15 49:8 63:5, 10, 295:19 348:12, 14 16:4 137:6 249:25
313:4 314:6 19 64:9, 14 79:3 379:17 380:5, 8 328:11 330:10, 11
regard 345:9 86:14 90:23, 24 381:6 358:12
regarding 133:14 92:13, 23 100:13 reporting 110:6 responsibility 109:6
157:14 164:25 104:11 107:11, 14 reports 109:12 155:2, 116:4 195:18 212:4
172:22 175:6 187:19 108:22 118:4 122:5, 9, 10 156:4 187:1 252:18 272:6 290:16
196:14 241:14 9, 10 127:21 130:5, 8 272:22 366:14 366:14
269:15 360:25 132:19, 20 136:21 representation 170:14 responsible 15:25
361:22 138:17 142:17 154:8, representations 131:14 196:13 230:1,
regardless 368:20 14 163:5 167:8 294:18, 19 2 263:5
regards 154:6 161:4 169:19 170:9 171:8, represented 309:1 rest 334:2
180:1 241:10 369:15 11 193:24 197:14, 17, representing 312:24 restate 16:16 106:21
regional 9:2, 6, 16, 17, 25 206:22 207:4, 6, 7 request 156:23 108:1 140:25 157:17
24 12:8 35:11, 18 220:6 221:22 245:6 163:12 181:18 223:3 166:10 320:6 377:3
55:4, 6 162:13, 16 260:17 269:13, 23 297:25 restatement 16:14
210:18 213:4, 6 273:7, 8 279:3 required 178:10 restraining 45:5
regular 110:25 281:12 282:2 283:3, 294:13 result 185:4, 24
376:16 9, 20 305:6 306:1 196:9 204:24 205:4
317:2 321:14 323:11

Cream City Reporting, LLC

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 Keith Posley 4/28/2025 32

resulted 165:4 216:4, 14 217:8, 23, 24 271:2 277:5 265:2 346:15 347:2,
results 258:18, 20 24 218:1, 5 219:14 329:14 13 351:2 374:2, 20
resume 33:7, 8 34:1, 220:16, 17, 18, 21, 23 rooms 144:21 Saffold's 109:6
2, 9 35:9, 10 38:17, 222:3, 6 226:7 rooted 288:2 116:22 118:22
25 39:1, 3 69:21 227:24 228:4, 19 ROPER 2:4 147:19 246:19
119:16 169:19 229:13 233:3 234:10, Rosana 35:21 86:10 264:10
225:22 15 235:17 238:1 230:24 231:19 365:3, sake 110:16 309:9
resumes 35:8 119:17 239:3 242:12, 21 10 366:8 salaries 203:22, 23
retaliation 92:5 243:19 246:11 249:8 rose 32:24 260:18 327:11
366:22 367:3, 24 250:12 252:14 roster 79:1 salary 52:4 53:3
retired 160:22 253:11 255:11, 19 round 118:10, 12, 17 54:15, 16, 18 204:19,
169:24 231:24 257:13 258:21 119:5, 8, 11, 17, 20, 22 22, 23, 25 205:7, 13
retooled 112:4 260:24 261:2, 20 123:1, 4, 8 127:2 259:19, 22 260:3, 6,
revealed 70:20 265:21 268:15 132:22 20, 22, 24 325:21, 22,
review 181:19 270:20, 23, 24 272:2 rounds 118:7, 21, 25 23
318:24, 25 372:19, 20, 275:2, 18 278:17 123:2 Saller 57:23, 24
23 279:3 281:7 282:22 route 218:21 Salter 57:22
right 8:8 10:16 290:11 292:9 296:22 row 41:12 189:13, 14 Sandy 222:24, 25
15:23 21:23 23:8 297:5 298:15 300:16 rows 189:16 sat 126:25 127:1
34:7 35:13 36:3, 9, 302:23 307:8 308:13 rule 145:4, 9, 24 258:15 271:5
11, 14 37:16 41:11, 309:19 312:1 319:22 146:2, 8, 9 Saveon 68:22
12, 21 42:3 44:8 320:19 321:24 322:7 rules 47:18 116:2 saw 190:6 193:13,
50:16 55:22 58:7 323:7, 10 335:5 145:2, 10, 12, 13, 16 16, 19 333:3
61:9 68:7, 12 69:3 339:1 352:5 356:23 146:13, 18 214:2 saying 27:2 49:4
73:14 74:15 75:5 358:7, 10, 17, 19 294:13 58:18 67:10 86:25
79:7, 23 81:14 82:24 361:15 365:13, 15 running 135:4 248:2 93:14, 15, 17, 20
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12, 25 204:8 206:16 76:11 157:4 270:11, 259:6 260:12, 13, 16 scheduled 154:25
211:19, 23 212:14

Cream City Reporting, LLC

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scheduling 111:16 Scoptur 83:8 112:24 227:6, 15, 19, 23 services 33:20, 22
329:22 scored 119:14 228:2, 4, 16, 20 34:15, 16 181:18
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225:25 226:3, 24 323:4 324:3 153:5 162:8 163:11,

Cream City Reporting, LLC

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22 165:15 166:15, 18 side 14:3, 4, 9, 10 276:7, 24 278:12 sound 17:12 63:13

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Cream City Reporting, LLC

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129:24 139:3, 12, 14 stand 168:11 status 92:5 177:23 submitted 58:19
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204:21 188:1 190:23 195:6

Cream City Reporting, LLC

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Cream City Reporting, LLC

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term 4:11 37:24 379:19 think 9:1 13:16 29:6, 11, 12 31:24
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23:17 24:4, 11 25:18 thesis 17:20 18:3 48:6 50:12 57:13 56:18 61:12 63:14
terminated 25:7 thing 54:14 97:10 64:16 66:13 67:5, 21 64:4 69:11 71:8
termination 23:13 115:22 117:9 123:13 68:12 69:2, 23 71:24 74:2, 3 76:5 77:21
24:16, 21, 25 25:16 129:2, 3, 18, 19, 20 78:10, 23, 25 79:24 78:10 79:3 82:12
terminations 23:18 130:9 134:23 144:19 81:12, 21, 23 82:6 84:8 85:12, 15, 16, 18,
terminology 136:4 151:8 155:1 160:1 84:24 89:5 90:8, 11 20 89:9, 12 90:7
153:12 176:3 188:23 221:22 97:9 99:7 110:3 91:4, 10, 13 94:9, 10
terms 129:17 226:9 232:8 248:5 114:20, 22, 23 119:23 100:12 101:4, 20, 24
Terry 78:14, 16, 21 269:6 273:7 278:5 121:16 122:12 104:1, 4 106:25
243:24 333:9, 12 292:14 300:8 321:18 132:11 139:6, 8 109:1, 16, 25 110:3,
testified 7:16 43:17 322:1 331:12 355:23 143:17 151:14 14 111:16, 23, 25
149:14 243:16 361:8 362:22 153:20 154:13 112:16 116:3, 19
257:17 278:19 319:5 things 15:22, 24 190:22 195:19 117:13 118:1 120:12,
361:9 16:25 19:4 22:6, 8, 207:20 213:9 215:14 18, 21 129:17 133:1,
testify 49:18 50:1, 4, 12, 16 23:4 25:4, 15 222:3, 4, 5, 13, 18, 25 3 134:12, 16 135:10
6 324:11 30:1 33:16 34:16, 19 231:7 237:10 267:4 136:18, 22 137:11
testifying 191:18 38:19 40:19 44:3, 5 273:14 280:18 284:5, 138:11 139:24 142:8
308:10 310:2 54:20 64:13 66:20 23 289:8 290:21, 22 144:4 147:23 148:2
testimony 18:25 67:20 74:3, 6, 14 291:12, 20 294:2 150:24 151:19 152:3,
38:3 42:19 51:1 75:19 76:9 85:24 297:13 301:3, 4 8 155:3 161:12, 15
61:25 64:3 92:10 86:3 87:21, 24 306:5 311:2 312:5 162:10 163:1 165:8,
103:1 117:1 127:15 102:11, 19 103:12 317:13, 24 318:5 18 167:16 169:11
128:23 129:11 111:7, 10, 25 114:4, 342:16 345:2 365:25 173:1 177:7 178:13
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Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 38

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Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 39

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Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 40

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Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 41

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Cream City Reporting, LLC

414.585.8128
 Keith Posley 4/28/2025 42

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