Carly Cortright, 2-4-2016

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IN THE MATTER OF SPOKANE POLICE DEPARTMENT RESIGNATION OF CHIEF FRANK STRAUB INTERVIEW OF CARLY CORTRIGHT FINAL HELD ON THURSDAY, FEBRUARY 4, 2016 9:55 A.M. SPOKANE COUNTY COURTHOUSE 1116 WEST BROADWAY AVENUE SPOKANE, WASHINGTON 99260

Transcript of Carly Cortright, 2-4-2016

Page 1: Carly Cortright, 2-4-2016

IN THE MATTER OF SPOKANE POLICE DEPARTMENT RESIGNATION OF CHIEF FRANK STRAUB

INTERVIEW OF

CARLY CORTRIGHT

FINAL

HELD ON THURSDAY, FEBRUARY 4, 2016 9:55 A.M.

SPOKANE COUNTY COURTHOUSE 1116 WEST BROADWAY AVENUE SPOKANE, WASHINGTON 99260

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1 INTERVIEW CONDUCTED BY

2 KRIS CAPPEL, ESQUIRE

3 The Seabold Group

4 4039 21st Avenue West, Suite 100

5 Seattle, Washington 98199

6 (206) 522-1152

7 (206) 522-1692 (Fax)

8 [email protected]

9

10 Also present:

11 MICHAEL CHURCH, ESQUIRE

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1 INTERVIEW OF

2 CARLY CORTRIGHT

3 FINAL

4 HELD ON

5 THURSDAY, FEBRUARY 4, 2016

6 9:55 A.M.

7

8 THE REPORTER: We are on the record.

9 BY MS. CAPPEL:

10 Q. My name is Kris Cappel. I'm with the Seabold

11 Group. And the City of Spokane has retained my firm to do

12 an outside investigation largely involving Former Chief

13 Straub. And the work that I am doing is being overseen by a

14 joint committee which is comprised of some private

15 attorneys, a city council member, and Rick Romero, who is

16 the director of your utilities department. And so those are

17 the folks that I -- that's my chain of communication.

18 And my role in this investigation is as a fact

19 finder. I am an attorney, but I don't do this work as an

20 attorney, so I won't be giving legal advice of any kind.

21 One of the areas that I have been asked to make

22 recommendations on, if warranted, are the City's practices

23 and policies of responding to harassment and discrimination

24 complaints. But aside from that, I won't be making any

25 recommendations on what the City should do with the

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1 information that I collect as part of this investigation.

2 Do you have any questions about my role or the

3 process?

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

5 Q. Okay. Because there is a fair amount of public

6 interest in this work, and because there is now litigation

7 that's has been filed, it's very clear that my work product

8 and your statements will be requested, either as a public

9 records request or in subsequent litigation. So I want to

10 make sure everyone understands that your statements will

11 become public.

12 A. That's why I brought Mike along.

13 Q. Okay. And so -- so that we're aware of that.

14 Before we get started, I'm going to have you state

15 your name and spell it for the reporter, and I'll have you

16 do the same.

17 MR. CHURCH: Sure.

18 Q. So go ahead.

19 A. So Carly Cortright. C-a-r-l-y, Cortright is C-o-

20 r-t-r-i-g-h-t.

21 MS. CAPPEL: And also present is?

22 MR. CHURCH: Michael Church. I'm with the law

23 firm of Stamper Rubens, PS.

24 MS. CAPPEL: Okay. And you represent Carly?

25 MR. CHURCH: That is correct.

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1 MS. CAPPEL: Okay. Terrific.

2 BY MS. CAPPEL:

3 Q. As we go through this process, I want to make sure

4 that we're communicating, so I invite you to stop me and ask

5 questions if I'm not being clear. If at any time you need a

6 break, please let me know, and I'll accommodate that. So

7 let's get started.

8 Will you tell me your current position with the

9 City, and then take me through the progression of all the

10 positions that you've held in the City.

11 A. Okay.

12 Q. Let's get that background information.

13 A. Right now, I am the Customer Service Director for

14 the City of Spokane. I have been in that role formally for

15 just over a year now. I'm going to go back in time and how

16 I got there. I started at the City in 2003 as a crime

17 analyst. I was in that role for about three years before I

18 became a police planner.

19 And I was in that role for about six years.

20 Towards the end, even though it was classified as a police

21 planner, I was doing a lot of what we called strategic

22 analysis work, so I was reporting directly to the assistant

23 chief. When he retired and Scott Stephens became the

24 interim chief, continued to become part of the leadership

25 team at SPD. When Chief Straub came in, in October of 2012,

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1 after about a month of him being there, he approached me and

2 asked me to serve as his Business Services Director.

3 He was going to reorganize the department and kind

4 of create a new Business Services Division that would be in

5 charge of pretty much all the civilian support functions in

6 the department, so that would include our Records Unit,

7 which was a joint unit between police and sheriff, our

8 property evidence facility, which was also a joint unit, our

9 personnel department, which was one employee, but handled

10 all the personnel records; police planning, which I had just

11 come from, and our fleet, which was two employees that

12 pretty much were responsible for making sure all of our

13 fleet equipment was in operating condition and getting it

14 over to city fleet, where they would work on it as

15 necessary.

16 I was also, kind of, our liaison with the

17 accounting department. The City of Spokane has a

18 centralized accounting function, so the accountant reported

19 up through Gavin Cooley, but was assigned to work on PD. I

20 had been working with Angela for several years on grant

21 projects and all that, so sort of a natural nexus to help,

22 you know, work with her to get the police spending, kind of,

23 in line or advise on what to do.

24 So I accepted that position, and we made that an

25 out-of-grade position starting in January of 2013. It was

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1 about --

2 Q. January?

3 A. Yeah, January.

4 Q. And you said it was -- I'm sorry to interrupt.

5 A. That's okay.

6 Q. Out of -- out of grade?

7 A. Out of grade. And the reason for that is, it was

8 about that time that the City had decided to change their

9 approach. Traditionally, they have followed a each

10 department gets two exempt employees that are at will,

11 everyone else is civil service. Based on the size of both

12 the fire department and the police department, they felt

13 that that was restrictive; that a chief should be allowed to

14 pick people that directly report to him rather than just

15 one. So they had to go through a series of ordinance

16 changes to make that happen.

17 So during that time, myself, Joe Walker, and Brad

18 Arleth and Craig Meidl were all paid out of grade. I take

19 that back. Craig Meidl, actually, I think became a -- no.

20 He wasn't. He was still -- because Scott Stephens was still

21 on the books. So we were all paid out of grade during that

22 time while they worked on changing that ordinance.

23 At that same time, Monique Cotton was brought on

24 board as our communications person. She was paid as a temp

25 seasonal until we could permanently hire her. That whole, I

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1 guess, work with the ordinance and then the necessary budget

2 paperwork that had to go through to do that, took several

3 months. So those positions didn't become permanent until

4 May of 2013.

5 Q. So your position as the business services director

6 became --

7 A. Permanent.

8 Q. -- permanent in May of 2013.

9 A. Correct.

10 Q. And when you say you were paid out of class, out

11 of grade --

12 A. Out of grade.

13 Q. -- does that mean you were paid more?

14 A. Yes.

15 Q. Okay.

16 A. So basically, we had developed a job description

17 and the estimated pay range, but they couldn't put me into

18 it until it became an official created position, so... So in

19 essence, I was paid and was acting as the Business Service

20 Manager; it just didn't become a permanent position until

21 May.

22 So I was in that role until October of 2013, which

23 is when I officially transferred to City Hall in what was

24 supposed to be a temporary reassignment to work on the

25 City's 311 project. And that changed in about a matter of

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1 two weeks, which we can get into.

2 Q. Okay.

3 A. And so it became quickly obvious that my position

4 at SPD was being eliminated, and I had no home to go back

5 to. So over the course between October of 2013 and December

6 of 2014, I was paid by the Spokane Police Department, but I

7 was working on the 311 project for the City of Spokane.

8 Q. And so I'm sorry, during what period paid by the

9 police?

10 A. October 2013 through December 2014.

11 Q. And what is the 311 project?

12 A. 311 is a -- I call it One Call for City Hall. It

13 was developed at the same time the 911 frequency was back in

14 the '60s, and it's been used by a lot of larger cities for

15 nonemergency law enforcement. We have CrimeCheck here, so

16 we've never utilized 311 in that function. In many cities

17 now, 311 has become a general phone number to get

18 governmental services. So the City has been planning to

19 embark on this one number. So as a citizen, instead of

20 trying to figure out who you need to call, you would call

21 311, and a 311 staff member would answer your question or

22 get you to the right place.

23 Q. Is that the nature of the project you were working

24 on --

25 A. Yes.

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1 Q. -- you were making that transition from a

2 nonemergency law enforcement number to a general city

3 number?

4 A. That was the reasoning behind lending me from City

5 Hall, at least that's what I was told; that we were unhappy

6 with the service that we were getting from CrimeCheck, which

7 is run by a different board, and so we don't have we're

8 contracting with them as the city. And they felt that, you

9 know, we need to re-look at that.

10 And then the other portion of just a centralized

11 customer service function, which is what we're doing today.

12 So it was thought that by bringing me over, I could help --

13 it was explained to me that I have good project management

14 skills; that they needed someone to help develop this and

15 get it up and going, and because I had that experience with

16 the law enforcement piece, we could potentially work on the

17 CrimeCheck function.

18 Q. Did you keep your title of Business Services

19 Director when you went to City Hall on this temporary?

20 A. Because literally, in the space of two weeks from

21 when I moved till it became clear that I was gone, I pretty

22 much had to change my title, because I wasn't at PD at all

23 anymore. They had completely cut my access from the system.

24 So I adopted the title of 311 Project Director, which is

25 what I referred to myself for the -- I guess that's 15

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1 months that I was in limbo of having a permanent position at

2 City Hall.

3 Q. And were you being paid as the Business Services

4 Director?

5 A. Yes.

6 Q. And then when that project concluded, what

7 happened?

8 A. Well, the -- from what was explained to me by my

9 boss at City Hall, Jonathan Mallahan, it was, in fact,

10 supposed to be temporary. So he was as surprised as I was

11 when it became obvious that my position at PD was,

12 essentially, eliminated by Former Chief Straub, and was very

13 supportive about keeping me on board, wanted me in that

14 role, so worked to create a permanent position for me. His

15 department is general funded, as is the police department,

16 so it was a general fund position.

17 He didn't have money in his budget to pay for me,

18 because this was an unplanned, permanent transfer. City

19 Hall's budget is submitted to council for review usually by

20 September or October, so there was no chance to find money,

21 essentially, because by the time this all happened, the

22 budget had already been presented to council.

23 So in theory, Straub should have given the money

24 that was funding me over, there should have been a transfer

25 to say, you don't want Carly anymore, we're taking that

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1 funding, and we're going to use it general fund to general

2 fund to fund her. Straub wouldn't give up the money. He

3 wanted to keep it and use for a different position as part

4 of his many reorgs.

5 And so I was, sort of, left in limbo until the

6 very end of the year when they finally -- and I, quite

7 honestly, heard through the grapevine that Straub had

8 finally released the funds to pay for me. I don't know if

9 that's an accurate statement or not. Somehow they found

10 money and created a permanent position for me.

11 Q. And what -- is that the current position you're

12 holding?

13 A. Yes.

14 Q. The Customer Service Director?

15 A. Yes.

16 Q. In which department?

17 A. My name on my department is MySpokane. It's under

18 the Community Services Division, and it's still an exempt,

19 at-will position.

20 Q. And Jonathan -- I'm sorry, I didn't catch his last

21 name.

22 A. Mallahan.

23 Q. Can you spell that for me?

24 A. Yes. M-a-l-l-a-h-a-n.

25 Q. And he is -- what's his position?

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1 A. He is the Community Services Division Director, so

2 he's a member of the Mayor's cabinet.

3 Q. Okay. Let's go back.

4 Have you ever been a commissioned officer or

5 always civilian?

6 A. No, always civilian.

7 Q. Okay. And as a crime analyst, were you civil

8 service?

9 A. Yes.

10 Q. And then as a police planner --

11 A. Civil service.

12 Q. -- civil service? And once you became a permanent

13 Business Services Director, that's when you became exempt,

14 at will?

15 A. Yes, correct.

16 Q. And so when you refer in your letter that you were

17 protected and became unprotected, is that what you're

18 talking about?

19 A. Yes.

20 Q. Okay. So I'm going to go back to the period where

21 Chief Straub was appointed the police chief.

22 A. Okay.

23 Q. You mentioned your position -- remind me of what

24 your position was. You were a strategic analyst?

25 A. Yeah. I was officially a police planner, but we

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1 referred to me as a strategic analyst.

2 Q. Who did you report to before Straub was hired?

3 A. Scott Stephens.

4 Q. And what was his position?

5 A. He was interim chief.

6 Q. How long did he hold that position?

7 A. Eight months. So he was appointed that in January

8 of 2012, and so when -- Straub was hired October. So nine

9 months.

10 Q. Is he still with the department?

11 A. No.

12 Q. And about when did he leave?

13 A. Officially in December of 2012. He was promised

14 the Assistant Chief position when they hired the new chief,

15 and when Straub came in, he decided to give that position to

16 Craig Meidl, M-e-i-d-l, and Scott was going to be demoted to

17 captain. He did not take that well, was put out on an admin

18 leave, subsequent to an investigation, was eventually laid

19 off.

20 Q. Okay.

21 A. Which I don't remember the exact date when he was

22 laid off, but he left the department in December of 2012.

23 Q. Okay. And then very generally, what were your

24 duties as police planner?

25 A. As police planner, I was responsible for the

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1 Department's grant writing, our resource allocation, so

2 examining how can we deliver business services better in

3 terms of where do we need to put officers, you know, looking

4 at annexation projects and how much would that be to put on

5 Meidl.

6 At that point, like, 2009, the City was suffering

7 some pretty bad budget problems, and so we were looking at

8 pretty substantial budget cuts, and so that's why I started

9 getting involved with the budget and what do we do with

10 less. So what officers do we cut without impacting

11 services. And so it kind of and very much an advisory

12 research analyst role for the department.

13 Q. And other than reporting to Scott, who did you

14 work most closely with?

15 A. Through most -- during that time was former

16 Assistant Chief Jim Nicks, N-i-c-k-s.

17 Q. Okay. So he's gone from the department also?

18 A. Yes. He retired in October, November of 2011.

19 Q. And how about any other staff that you would

20 regularly work with, besides the two assistant chiefs?

21 A. It would vary, but it was usually the -- early as

22 a police planner, it was the senior staff, which is the

23 lieutenants and captains of the department. As -- by the

24 time I was working with Nicks, at that point, we had majors,

25 so at that time, Scott Stephens was a major, so I worked

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1 closely with him. Major Meidl. He was a major at the time.

2 Q. Okay. What was your work schedule?

3 A. At the time, I worked for four tens, Monday

4 through Thursday.

5 Q. Normal business hours?

6 A. Yeah, normal business hours.

7 Q. Is that -- is that an 8:00 to 5:00?

8 A. Yeah. With the four tens, I think I worked 7:00

9 to 5:00.

10 Q. Okay.

11 A. Yeah.

12 Q. And where was your office? Did you have an

13 office?

14 A. I did have an office. By the time this was

15 occurring, it was in the Public Safety Building. When --

16 when I was in the strategic analysis role, I was in an

17 office down the hall. When I promoted to Business Services

18 Manager, I was on Mahogany Row, which is the executive suite

19 of offices. So I was three doors down from the chief.

20 Q. Okay. And I'm sorry, I'm catching up with the

21 dates. He came in in October of 2012, and you mentioned

22 within a short time, maybe a month, he approached you about

23 promoting you.

24 A. Yes.

25 Q. Did you physically move to that space?

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1 A. Not until January.

2 Q. Of 2013?

3 A. Right.

4 Q. So where were you from October '12 to January '13?

5 A. I was still down in the -- it was sort of the

6 police planner and the patrol lieutenants. We all had a

7 space at the end of the hall. So...

8 Q. So when Chief Straub came in, what were your early

9 impressions?

10 A. My early impressions, quite honestly, I never

11 quite trusted the man. He had a -- a way of not looking at

12 you when he talked to you. He would look down, just very

13 awkward body language that didn't sit right with me. But he

14 came in with a lot of passionate ideas. And we have been a

15 department that was struggling. I'm sure you've probably

16 been briefed with the AutoZone incident. A lot of, I don't

17 know, morale issues in the department.

18 The prior chief before Interim Chief Stephens,

19 Anne Kirkpatrick, had, kind of, came in strong, left weak,

20 and had created a lot of, I don't know, bad feelings in the

21 department. And so I think we were looking for a strong

22 leader, and -- and he had some really great ideas. I mean,

23 the man is brilliant, but...

24 So when he approached me on, kind of, changing my

25 role, I remember at the time thinking they don't quite trust

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1 you, but have you -- I loved the Spokane Police Department.

2 It was -- I was passionate about the work I was doing,

3 making our community safer, working on ways to, you know,

4 save money and be smarter, you know, and I have worked hard.

5 And so I felt like I wanted this promotion. I was

6 ready for it. And so it's like do you say no just because

7 you don't like the guy? You know. And I decided that no, I

8 was willing to --

9 Q. Had you really formed the opinion that you didn't

10 like him at that time?

11 A. Not at that point. Like I said, it was cautious,

12 I don't know how I feel about you. It wasn't an immediate I

13 like you, and then it changed. It was always a I don't know

14 how I feel about you.

15 Q. How did he explain the new position?

16 A. It was essentially he wanted to reorganize the

17 department, and he had been advised that we had been working

18 on, actually, officially making me a strategic analyst, and

19 that I had been pretty much blocked by Chief Kirkpatrick on

20 ever making that happen. And Scott Stephens had been, sort

21 of, I don't want to create a position for you if a new chief

22 is going to come in and change that. So I had been, kind

23 of, in a holding pattern of promised we're going to get you

24 reclassified and not having it happen.

25 So at the time, I told him that I was, you know,

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1 like I'm -- would like to move forward, but at the same

2 time, I have been lied to in the past. And so I distinctly

3 remember him coming in. I think he sent me an e-mail,

4 actually, that said, you know, I've decided to go ahead and

5 move forward with creating this position by passable

6 service. Are you okay with that? And I wrote back, "Yes, I

7 am." And his response was, "Great, I look forward to

8 working with you."

9 Q. What were the advantages, as far as you understood

10 them, of -- of taking on the new position?

11 A. The -- I liked the initial reorg because for a

12 long time, civilians in the department, which are mostly

13 female, are, kind of, I wouldn't say marginalized, but not

14 viewed as important as real police work, which, to a certain

15 extent, is understood. I mean, they are the ones out there

16 doing the real work. But I think the Records Department,

17 without police records, you don't have that information on

18 file. You know, they are the ones that are issuing

19 concealed pistol licenses.

20 They have -- they have to enter missing people

21 within a certain amount of time. I mean, they have real

22 responsibilities. The same thing with our property evidence

23 facility. I mean, you lose a piece of evidence or you

24 categorize it wrong, there are major repercussions. And

25 they were always, kind of, treated as an after thought. So

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1 I feel like the reorganization made a lot of sense, because

2 you could put someone, like myself, that had passion about

3 it, in -- in charge of it and would give it the attention

4 that it needed.

5 One of the things I'm most proud about was our

6 Records Department had continually suffered a very long

7 backlog in filling public records requests. That was

8 largely due to having to pull records that were on

9 microfiche that we didn't legally need to keep anymore. They

10 were past the retention period. No previous administrator

11 had granted our Records Department the authority to destroy

12 those. So I said, "Let's destroy them."

13 Q. Uh-huh.

14 A. So we got that done. And by the time I left, we

15 were almost caught up on our backlog.

16 Q. So in terms of the benefits to you, you became a

17 director, so you had a title change.

18 A. A title change. A -- you know, a significant pay

19 increase.

20 Q. And did you -- were you supervising staff before?

21 A. I had one staff person.

22 Q. And what changed when you became a director?

23 A. I had six direct reports.

24 Q. Okay.

25 A. I think I had -- my division had 50 people in it

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1 overall.

2 Q. And then you took on a broader array of process

3 and function.

4 A. Right. Served on committees, was briefing City

5 Council on, probably, a monthly basis on different contracts

6 and items that needed to be approved.

7 Q. Okay.

8 A. So much more responsibility.

9 Q. And as a director, who did you report to?

10 A. Technically, the Assistant Chief Meidl.

11 Q. Okay.

12 A. But that is part of the problem is, if you briefed

13 him, it's not clear if he wasn't briefing Straub, but then

14 you would get in trouble for not having told Straub. So

15 then I started reporting to Straub, and then Craig would get

16 upset that I was telling him. It was very unclear who,

17 technically, I was supposed to be reporting to.

18 Q. So did you adjust your -- your approach at some

19 point?

20 A. Yes.

21 Q. From what to what?

22 A. It went -- I would say the first couple of months

23 were busy. I mean, I was working 50-, 60-hour weeks. Pretty

24 positive our -- that the core people that I described

25 earlier that were on the out-of-grade position, we met daily

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1 at 7:30 in the morning. We had executive team meetings and

2 briefed projects, what we were doing, and it was a nice,

3 cohesive group, and we were fulfilling Straub's vision of

4 things to do. I mean, we hit the ground running, and I

5 think we really did make some really good progress. I would

6 say around --

7 Q. Can you tell me -- I'm sorry. Who was on

8 executive team?

9 A. That would be Meidl, who was Assistant Chief. Our

10 two commanders, which were Joe Walker and Brad Arleth, A-r-

11 l-e-t-h, Monique Cotton, and myself.

12 Q. And then the chief.

13 A. And the chief.

14 Q. And this would have been as of January 2013 --

15 A. Correct.

16 Q. -- this group is meeting on a daily basis.

17 A. Yep.

18 Q. And -- okay. So Monique was on the executive team

19 as the Communications --

20 A. Communications.

21 Q. -- Director?

22 A. Right.

23 Q. Okay. So you started to say that it -- it was

24 going well.

25 A. It was going well. I distinctly remember, besides

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1 all of us working -- I mean, and we were. We were working

2 hard. Like I said, I -- my recollection, the first two

3 months were good.

4 Around March, the chief started to become

5 impatient. Some things weren't changing quickly enough for

6 him, which I was always found very ironic, because as a

7 person has a Ph.D, he should realize that you need time to

8 have things in place before you can measure here was the

9 baseline, here's where we're at right now, two months isn't

10 enough time to see significant change. His major number one

11 mandate is, we need to bring down crime. You know, nothing

12 else matters. We have to bring down the crime numbers.

13 Q. All or just --

14 A. All.

15 Q. Okay. Auto theft and --

16 A. Auto theft we had. He had started CompStat at

17 that point in time, which measures the -- all eight part one

18 crimes by the UCR. So homicide, forcible rape, robbery,

19 aggravated assaults, and then burglary, larceny, auto theft,

20 and technically arson, which is --

21 Q. Okay.

22 A. -- because we don't investigate arson as a police

23 department here.

24 So we were meeting weekly on that. We also had

25 weekly CompStat meetings. And so we were measuring the

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1 numbers, and they weren't coming down fast enough in his

2 opinion. Some of the different strategies that we tried to

3 utilize to, you know, hot spot policing, like put the cops

4 here, getting information on the crime analysis. We were

5 making changes. I really truly believed things were going

6 for the good, but then he would get upset and decide that we

7 were going to switch course and do something else.

8 And so we would do that, but it's like, but now we

9 don't know which system is working because you've overlapped

10 them. You don't know what you're measuring. I think -- and

11 that was largely left up to Walker and Arleth to -- they

12 were in charge of investigations and patrol, and it was up

13 to them to, kind of, direct that work. And I think, you

14 know, they were trying to tell him, we are doing these

15 things, but you need to be patient.

16 At that point, I think, I don't know, from all of

17 us working so hard, we started to fracture a little bit as a

18 group. All of us have talked about it now, after the fact,

19 and Straub was telling all of us different things about each

20 other. So he was telling Craig that he needed to, you know,

21 stand up to Joe and Brad; that they were, you know, going

22 around them, and be forceful. And then he would tell Joe

23 and Brad that Craig was weak and that they should report

24 directly to him because Craig couldn't handle it.

25 He, in my opinion, tried to drive a wedge between

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1 me and Monique. Monique was new to the City. She had never

2 worked there before. He gave her a lot of new

3 responsibilities, including managing people, which I'm not

4 sure she had really done before, and she had a budget to

5 manage. And so I was trying to, kind of, instruct her on,

6 you can't spend money on this, while the chief would turn

7 around and tell her yes, you can, don't listen to Carly, and

8 then would get mad at me because she felt that I was

9 purposely lying to her, which wasn't true. But I think he

10 did a lot of head games to purposely keep people in check.

11 Q. Okay. So you mentioned it started out fine,

12 working well together, and then by March --

13 A. March is where I really feel --

14 Q. -- 2015 you said --

15 A. Right.

16 Q. -- since this fissure and --

17 A. Yeah, we're -- we're turning on each other. I

18 mean, there's -- and like I said, I don't know if it was

19 some of it just because we were working so hard, and, you

20 know, the weekly, daily meetings, and we're trying -- I

21 mean, it just -- they started to become lectures. I mean,

22 Straub would, "You're not doing this. We need to work

23 faster. We need to, you know, stay ahead of everybody else.

24 You know, we've got to keep council off beat. You know, we

25 have to --"

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1 He was quite upset, during a budget presentation,

2 that people didn't have the answers, and so he was basically

3 caught off foot by the council, and we got chewed out the

4 next day, that we needed to know all that, that we always

5 needed to know them -- know the answers so they couldn't

6 catch us that way again.

7 Q. So the honeymoon was over. These meetings that

8 you're describing, where they went from collaboration to

9 lectures, did his demeanor change in terms of

10 professionalism and language and --

11 A. Yeah. That's when a lot of the, right, bad things

12 started happening. One of his favorite -- and he would do

13 this -- I mean, numerous times. We've all seen it -- where

14 he would make references to, "Let's us take out and

15 measure," and then he'd slam his forearm down on the table

16 in an apparent reference to measuring penis size.

17 Q. Uh-huh.

18 A. And it was always a competition with him on who

19 was better. The -- I worked at the --

20 Q. Can we go through that again?

21 A. Sure.

22 Q. I'm having a hard time visualizing it.

23 A. Yeah. We would just flop his arm out, so we'd

24 take them out and measure.

25 Q. And in the context of measuring progress on crime

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1 statistics or --

2 A. No. On, you know, who was better at what; who

3 was, you know -- you know, he hated the sheriff. So any

4 time we were working with the sheriff, and the sheriff would

5 push back on like a joint task force --

6 Q. Uh-huh.

7 A. -- you know, he would be, "We're -- we're better

8 than them." You know, if Joe and Brad were arguing with

9 each other on wanting to do something, you know, he'd make

10 reference to that. Like, I mean, it was just, again --

11 Q. And he'd throw his arm out.

12 A. Right.

13 Q. And your impression of that was --

14 A. Oh, he'd say, "Let's take them out and measure." I

15 mean, it was -- and then flop it down like he was

16 graphically trying to display slapping his penis down on the

17 table.

18 Q. Okay. Did that ever come out more directly, where

19 he said that's what he was doing, or someone called him out

20 on it or --

21 A. No. I think we all knew.

22 Q. Did you talk about it as a group how you were

23 interpreting this --

24 A. No.

25 Q. -- throwing out the forearm?

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1 A. For a police department, I think we all knew. I

2 mean...

3 Q. Okay.

4 A. I think that was another -- I worked there ten

5 years. It's well known. In fact, it used to be a joke that

6 I couldn't ever leave working at the police department

7 because of my potty mouth. I tend to talk like a trucker.

8 And we always used to joke about that.

9 I believe I know when to be professional and when

10 not to be. I felt in that core team of meetings, I would be

11 allowed to swear, and Straub actually counseled me once that

12 that wasn't appropriate. But he would swear all the time.

13 It was perfectly fine for him to drop the F bomb, any type

14 of language he wanted to, but apparently, it wasn't

15 appropriate for me to do so.

16 Another one of his favorite expressions was a

17 circle jerk, which clearly referred to sitting around and

18 jerking each other off. And he would usually say that in

19 reference to, like, the cabinet meetings, where he'd come

20 back from them and say, "Everyone just sat around and

21 laughed at jokes, and it was like a giant circle jerk."

22 Q. Uh-huh.

23 A. He just used a lot of colorful language like that

24 that, like I said, in my opinion, it's the police

25 department. It's a type of culture that we use that kind of

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1 language. I don't think any of us necessarily found it

2 offensive. It definitely wasn't very professional for a

3 police chief to do. Scott Stephens never would have done

4 that. Jim Nicks never would have done that. It was -- I

5 had never seen it from someone who was the chief.

6 Q. So some of these colorful phrases that he started

7 to use, how long into his tenure did he start to -- to use

8 those?

9 A. Almost right away. Like I said, I would say the -

10 - I think with anybody, the more you become comfortable with

11 them. So I couldn't tell you if it was around February. If

12 it was March. But I would say within six to eight weeks, it

13 went from the occasional swear word to fairly often using

14 colorful language.

15 Q. Okay. Can you think of any other common phrases

16 that he would use?

17 A. Those are the two. The two circle jerk sticks out

18 in my mind a lot.

19 Q. And the -- and the let's measure?

20 A. Yeah, let's measure. I remember -- it's the only

21 time I can ever say that I was -- that it was so

22 inappropriate -- he and I had a meeting together. It was

23 very early in his tenure. It was probably that January that

24 we had to meet at City Hall for something.

25 Q. January of 2013?

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1 A. Yeah, '13. And I don't -- I don't remember the

2 context. It, obviously, probably had to do something with

3 budget, which is why I was brought along. So we rode from

4 the Public Safety Building here at City Hall, which isn't

5 that far. I rode in the car with him. After the meeting

6 was over and we got back and drove off, we were crossing the

7 Post Street Bridge, and he made a comment to me along the

8 lines of, "Well, that was just like we went and masturbated

9 each other." And I just remember sitting there like, this

10 is so weird. I don't know you well enough to have you make

11 that kind of comment.

12 And I still remember that after all this time,

13 because I joke about it with one of my friends. I'm like, I

14 felt like asking, "Do you need a tissue?" I mean, I just --

15 I didn't know how to respond, it was so weird. And he

16 clearly meant it as a joke, I'm trying to be friendly with

17 you. But again, it was that same -- that's just really

18 inappropriate from a boss, and I've known you three months.

19 I mean, it's weird.

20 Q. Just this just the two of you in the car?

21 A. Yeah, just the two of us in the car.

22 Q. Do you remember who you had just met with?

23 A. I am fairly confident it was Theresa Sanders and

24 potentially the Mayor. But I feel like it was probably just

25 Theresa and maybe Gavin. Like I said, it was likely budget

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1 related. It was so early on, I didn't document it, didn't

2 really think anything of it and just disregarded it, because

3 we were getting along at that point. And the only reason I

4 remember is, because like I said, I've made the joke to my

5 friend about it. And for a long time after, we would

6 reference that when I was talking about how much I disliked

7 him. So...

8 Q. So but at the time, you felt like you were getting

9 along okay with him.

10 A. Yeah. At that point in time, things were okay.

11 Q. And that changed, obviously.

12 A. Yeah. It started, like I said, around March. I,

13 in my previous role, anytime a boss, you know, Assistant

14 Chief Nicks or Scott Stephens had asked me to send something

15 to City Hall, either the current mayor or the former mayor

16 staff, they would say, "Carly, please send this to so and

17 so." And I would send them the information and copy my

18 boss. I did this in something that Straub had sent to me,

19 so I sent it to directly to Theresa Sanders. That made him

20 very mad. He sent me an e-mail. Never counseled you in

21 person.

22 It was usually always by e-mail, if he gave you

23 any direct feedback at all, and said, "Send to me next

24 time." And so from there on out, anytime that type of

25 request would come in, I would send to him. And every now

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1 and then, he'd copied me on it, and he would send the exact

2 same e-mail. It's like he didn't even change anything, it

3 just had to come from him and not from me, which is fine,

4 but it was one of those, you know --

5 Q. Uh-huh.

6 A. -- I felt like he overreacted in his negativity

7 towards it, in terms he'd never told me not to do that.

8 Q. So you said he got really mad. Was that apparent

9 in his e-mail or did he confront you personally?

10 A. In the e-mail it said, "Please don't do it again."

11 I don't recall him -- it's just from the tone of the e-mail,

12 and it's e-mail, so interpret what you will. But his

13 demeanor towards me changed. I mean, I could tell that it

14 made him mad. I mean, there's no other way to describe that

15 except, you know, that was one -- first noticed -- where I

16 started to notice that he started to be cooler towards me.

17 Q. Had anything else happened before that that you

18 can recall?

19 A. What had happened -- and this is where Straub and

20 I -- I know why he ended up disliking me and wanted me gone.

21 Being in charge of our budget, I was constantly the person

22 that had to tell him that we didn't have the money to do

23 that or he couldn't spend the money the way he wanted to.

24 We -- like I said, this was 2013. We're still in a little

25 bit of a budget crunch at the department, and he has now

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1 reorganized and created a lot more higher- paying positions.

2 We had quite a few vacancies on the books. So we cut some

3 positions and we tried to make it work.

4 In the space of from January 2013 to the time

5 right after I left in October, we had seven different org

6 charts. We reorganized seven different times. Now, a few

7 of those were a little bit minor. We added a certain

8 position and did different things. But we were constantly

9 adding new positions and changing things up. And --

10 Q. Can I ask you: Was this just an exercise in

11 figuring out which one works, or is this actually placing

12 people in the positions and then changing your mind and

13 putting them in different positions?

14 A. I think a little bit of both. I mean, some of it

15 was like this was his, this isn't happening fast enough for

16 me, so we're going to change some things up. And so I think

17 right away, within three months, he wanted to add two

18 lieutenants' positions. And part of that was, he wanted

19 more of the law enforcement presence out at the dispatch

20 center, because he felt like that wasn't happening. Okay.

21 That maybe makes organizational sense, but a

22 lieutenant is almost the cost of a police officer and a

23 half. And so we would then have to convert police officer

24 positions, and I'd have to be the one to tell him you're

25 running out of positions, we're not going to have enough,

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1 you know. And then he'd get mad at me for it, like it was

2 my fault that I couldn't make money grow on trees.

3 At one point in time, we had a grant through the

4 state for auto theft prevention, and it was a joint task

5 force with WSP and the sheriff's office, and the grant came

6 through the sheriff's office, and in order for us to

7 participate, they wanted the detective that we had on that

8 task force to actually co-locate with them on the task force

9 instead of work out our office.

10 We decided that as a team, that we didn't like

11 that approach, so we weren't going to participate anymore.

12 So I explained, okay, that's fine, but their funding a

13 detective, so if we lose that money, then we have to roll

14 back a detective, and we lose the space on the bottom. And

15 he was like, "No, we don't have to do that." I'm like,

16 "Yes, we do. That's -- we don't have any more money." And

17 then, again, just would direct his anger towards me on it,

18 that I was telling him, "No, you -- you can't do that."

19 Q. So when he would get angry at you, what would he

20 do?

21 A. He would -- he only lost his temper on me once. By

22 angry, stern expression, slightly elevated voice, and, you

23 know, more of, "What do you mean, we can't do that? Yes, we

24 can." "No, sir, we can't. We don't have the money. You

25 know, we can't do that." "Well, that's a stupid thing.

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1 That doesn't make sense."

2 Q. Okay.

3 A. "I don't know what to tell you. That's how it

4 is." I mean, so just stern expression, angered tone, but

5 not yelling.

6 Q. And was that -- if there was a usual, was that in

7 the executive team meetings or is that one on one?

8 A. Usually executive team meetings, because usually

9 we're doing this work as a group. He and I had very little

10 one-on-one interaction. And that was part of my -- by the

11 time April rolls around, it's become very clear to me that

12 he's happy with me, but he's never given me any direct

13 feedback of what I'm doing wrong.

14 We started to have a couple of one on ones about

15 that time, and his expression to me was, he would tell me

16 that I couldn't get out of my own way, and that -- and I

17 would, kind of, always like, "Well, what do you mean by

18 that?"

19 Q. Uh-huh.

20 A. And that basically, I was too stuck in the past

21 and couldn't, you know, get out of my old way of thinking,

22 and, you know, move forward. So I was my own worst enemy,

23 couldn't get out of my own way. And I think it's in

24 reference to -- and we have civil service rules. Almost

25 everybody in the department is civil service, so with all

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1 the moves that he wanted to do, I -- I always felt like I

2 was trying to counsel him, here's where you are. This is

3 what you want to do. These are the road barriers to doing

4 that, and would try to help him get to the answer he wanted,

5 but he didn't like all the red tape that was associated with

6 doing those things. And he blamed me personally for not

7 being able to do those.

8 Q. Could you tell whether he was familiar with civil

9 service rules as a general matter, like, from his prior

10 positions?

11 A. You would think he would. To me, I honestly felt

12 it was always that east coast-west coast difference, that in

13 the east coast, they're used to doing, I don't know,

14 bartering deals or whatever, or you don't follow the rules.

15 The rules are more like guidelines.

16 Q. Okay.

17 A. He would make reference to that every now and

18 then, that we move so slow out here in the west coast, that

19 things just that happen like that on the east coast. And so

20 to say that he didn't understand the rules, yeah, that's

21 possible, but I would explain them to him, so he should have

22 known them.

23 Q. So you mentioned that he only lost his -- really

24 lost his temper with you once. Tell me about that.

25 A. That was in July, the very end of July of 2013,

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1 and we were at a CompStat meeting, and I had walked over --

2 our CompStat meetings were in the Gardner Building, which is

3 a different building across campus, and so we had to walk

4 from the Public Safety Building there.

5 And I walked over with Brad Arleth, and we had

6 been discussing the burglary series that had been going on,

7 that happened to be occurring in my neighborhood. And he

8 was like, "Oh, yeah, I just talked to Crime Analysis. The MO

9 for how they're getting in is through unlocked sliders."

10 And I laughed, and I said, "You know, what's really funny

11 is," I said, "I went to, you know, let the dogs out this

12 morning and realized I had left my slider unlocked." Ha,

13 ha, ha, isn't that funny.

14 So we're at the meeting, and that comes up. So

15 they're discussing the MO, and we're sitting across the room

16 from each other. So he's sitting up by the chief and I'm

17 sitting at the other end of the room. And we exchange.

18 We're friends. We make a face at each other, like, you

19 idiot. And I'm like --

20 Q. You and Brad or you and the chief?

21 A. Yeah, me and Brad. So I'm like, "Hmm, hmm, yeah,

22 I know. I'm a moron." The chief saw it. Him and Brad were

23 friendly at the time. I mean, they were socializing with

24 wives after work. I don't know why it bothered him so much,

25 but after the meeting, he said, "I want all of us --" and

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1 it's this little empty room, office, that no one was in, and

2 he's like, "Come here." So --

3 Q. Who did he ask to join him?

4 A. So that was Monique, Brad, and myself. I believe

5 both Craig and Joe were on vacation. But he specifically

6 said, "Executive staff, I want you to meet now." So we step

7 into the room. He closes the door and yells. I mean, turns

8 bright red. And I'll never forget it because I've never had

9 a boss speak to me in such a horrible manner. I mean, it

10 was just -- and he yelled at us and said, "If either one of

11 you ever disrespect another member of this command staff

12 ever again, I will fire you --" and he pointed at me -- and

13 then "I'll demote you," pointed at Brad, and then said, "If

14 you don't believe me, call Indianapolis, because I'm a real

15 cocksucker," and then stormed out of the office.

16 And from that moment on, I was -- I'm like, he's

17 going to fire me. I mean, it's pretty evident that he hates

18 me; that, you know, I came in for -- ironically, it didn't

19 last very long -- for about the next week just pretty sure

20 that I was going to get fired at any moment.

21 Q. So what you just described, his demeanor and the

22 volume and tone, had you experienced that before --

23 A. No.

24 Q. -- July? So this was the first --

25 A. This was the first time that he -- the actual

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1 voice was raised, red-faced. I mean, he was angry.

2 Q. And did that happen again after that?

3 A. Not while I was there. It did not happen to me.

4 Q. Okay. So we're now into July of 2013. How does

5 the relationship -- I'm going to assume it continued to

6 deteriorate.

7 A. It didn't -- no. It was very quick after that. If

8 I can go back up.

9 Q. Sure.

10 A. By April -- and it's become very clear he's

11 unhappy with, like I said, just in general -- we had, like,

12 another situation, because the program that's actually, up

13 and going, and it's pretty well respected in town, was this

14 youth program. It's called YPI, that he had done, I think

15 both Indianapolis and White Plains.

16 Q. What does it stand for?

17 A. Youth something. I don't really remember what the

18 P and the I stand for. But it's a youth prevention. It's a

19 youth --

20 Q. That he -- that he introduced?

21 A. Right.

22 Q. Okay.

23 A. So he wanted to bring it here to Spokane. So we

24 had gotten got a proposal from the company that does it, and

25 I want to say it was around $75,000. With city budget

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1 rules, anything over $50,000 needs to go to council for

2 approval, and really, anything over -- I can't remember the

3 limits now -- 15,000, 10,000 -- are supposed to go out for

4 RFPs. A good steward, so the city's money.

5 So we canceled source contracts, but you have to

6 justify why. So he wanted that done. I had to come up with

7 funding for it. He really wanted to use -- and we didn't

8 have a lot of extra money. I mean, our general fund money

9 almost all goes to paying for cops. We have some grant

10 money, and then the rest of our money comes from seizure and

11 forfeiture. The seizure and forfeiture money has a lot of

12 strict regulation on it, that it can only be used towards

13 drug enforcement.

14 Q. And that's right, yeah.

15 A. Right. So and that was -- we had some pretty

16 significant cases at that point time, that that was our

17 fairly large -- and I don't remember the exact amount, but

18 we had a hundred thousand or so in there. I mean, it was

19 pretty substantial. And we've always used it traditionally

20 to fund our SWAT team for new equipment, and there's an

21 nexus there to drug enforcement or anything for the gang and

22 drug units.

23 Q. Uh-huh.

24 A. So he really wanted to spend the money on that

25 with this YPI program, with, you know, it's keeping kids out

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1 of gangs, so it's going to keep them out of drugs. Like,

2 okay. I mean, there's kind of a link there, but -- so

3 that's what we were going to do. Accounting was like, no,

4 we don't feel comfortable doing that. We're going to get

5 audited, and we can't show that clear link. And then our

6 purchasing department said, no, you can't do a sole source.

7 You need to put this out for an RFP, which, of course, takes

8 time. So I came back and told him that.

9 Q. And these are departments in the city.

10 A. Yes. So I would come back and relay that

11 information. Like, okay, I'll get going on RFP so we can do

12 this. We'll have to find some other way to fund it. And

13 then, again, we'd get the lecture of, what do you mean,

14 that's stupid, just go do a sole source. I can't do a sole

15 source. They won't let me. I mean, it was just this

16 constant, like, really? I really believed that he thought I

17 was purposely just saying no because I wanted to.

18 We did end up putting it out to RFP. I think we

19 ended up talking to our legal advisor, who decided that the

20 link there was close enough that we'd be able to justify

21 using the seizure money. So that, kind of, full process

22 happened.

23 Q. Can I ask you: Who was the legal advisor for the

24 police department?

25 A. Mary Murmatsu, which --

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1 Q. Mary?

2 A. -- if you ask me to spell her last name. M-a-r.

3 Q. We're getting there.

4 A. Yeah. Murmatsu.

5 Q. Murmatsu.

6 A. Yeah.

7 Q. I'll just do it phonetically. And is she still

8 the legal --

9 A. Yeah.

10 Q. -- advisor for the department? Okay. Sorry, I

11 interrupted. So you got --

12 A. That's okay.

13 Q. You talked to her and she thought there was enough

14 --

15 A. So we decided that there was enough of an nexus

16 there that we could make that work. So, like I said, this

17 was around April. And why it's relevant is, by the time May

18 has come around, I am feeling completely beaten down and

19 just, in general, the chief doesn't like me. I'm not doing

20 anything right. You know, like I said, still working at

21 that point not quite 60, but at least 50, 55 hours a week.

22 I mean, I would spend -- every Sunday around 3:00

23 p.m., I would get on my laptop and just start cleaning up

24 all the e-mails that I hadn't gotten to the week before, so

25 at least I could come in Monday morning knowing that I had

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1 kind of taken care of everything.

2 It's important because May is when they finally

3 finalized our positions and we could become permanent

4 employees. And part of that process is meeting with the

5 mayor to get your offer letter, and the mayor likes to have

6 a one on one with all the exempts he hires. So we had our

7 sit down. And I remember at the time thinking why is he

8 offering me this job when he clearly thinks I can't do it.

9 It just didn't make sense to me.

10 Q. When you met with the mayor, was it with Chief

11 Straub present?

12 A. Yes.

13 Q. So it's the three of you?

14 A. The three of us. The, you know, Mayor, kind of,

15 he asked some standard boilerplate questions on, you know,

16 what do you want to work for this job, you know.

17 Q. Uh-huh.

18 A. What are you, I think, most critical of and which

19 -- yeah. And the -- there was like one other question. And

20 the Mayor is very friendly, and, you know, he usually fills

21 up a lot of the time talking, so you don't have a lot to

22 say.

23 Q. Uh-huh.

24 A. But I thought it went -- I mean, it was okay,

25 great, thanks, Mayor, happy. And as we left, the chief --

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1 or I think because I went before the chief commanders did.

2 So the next day, when we were at exec staff meeting talking

3 about how it went, because they were that day, the chief

4 kind of laughed. He's like, "Yeah, Carly did better than I

5 thought she would." I mean, it was just like this little

6 jab of right, we're back to, I don't know why you're hiring

7 me to do this job --

8 Q. Uh-huh.

9 A. -- when you clearly don't -- I mean, it was -- it

10 was very negative. That was at the very end of May. He

11 sent three of us to Boston for three weeks for leadership

12 training. So --

13 Q. Three weeks?

14 A. Yeah. Which, again, I think it was $8,000 a

15 person. And I remember saying that, you know, I'm like he's

16 -- he's going to get rid of me. And my family, my friends

17 were all, "He's spending $8,000 on you for leadership

18 training. He can't quite possibly dislike you as much as

19 you think he does."

20 Q. Who went?

21 A. Craig Meidl, Brad Arleth, and myself.

22 Q. Okay. And I'm sorry, when was the training?

23 A. This was from June 1st through June 21st of 2013.

24 Q. Okay.

25 A. So a great experience. He had told the three of

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1 us, "Don't do work back here. I really want you to focus on

2 your leadership." So I think for the most part, we were all

3 pretty hands off of not -- you know, there were a couple

4 things I had to take care of, but for the most part, we're

5 able to focus on that. It was great training. I came back,

6 kind of, rejuvenated and ready to, you know, let's fix these

7 problems that are still going on in the department.

8 In July, he sends me and three other women to a

9 female leadership training in Seattle, and it was during

10 that time that I got an e-mail from our HR director -- or

11 from accounting, actually, wanting advice on what we were

12 supposed to do to hire this new position that the chief is

13 bringing to the council on Monday.

14 Q. Who did the e-mail come from?

15 A. Angela Golden, who was our accountant.

16 Q. Okay. She's a city accountant?

17 A. She was, yeah. She has since left.

18 Q. And she is e-mailing you for information on how to

19 hire --

20 A. Right. She -- right. She sent me the e-mails on

21 the lines of, "Please call me. We need to talk about this."

22 And so I'm reading -- so she brought me the whole chain, and

23 now I can see the chain, which was from the chief e-mailing

24 city council on the reason for this position and why it was

25 needed and what they were going to do, and then an e-mail

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1 from HR saying, okay, he wants this taken care of now.

2 Where's the funding coming from and who is going to present

3 this to council.

4 Q. Uh-huh.

5 A. So it was another one of these, "Thanks, Chief.

6 This is what -- you know, I'm the one that has to do this,

7 and this is the first I'm hearing about it. I knew that he

8 wanted to hire this person, but I didn't realize it was

9 happening, you know, that soon. So I'm trying to care of

10 this by cell phone in Seattle and trying to figure out,

11 okay, where are we going to find the money, you know, move

12 it from here, do this.

13 Q. Uh-huh.

14 A. You know, we've got this vacant position so we can

15 fund it. And, you know, can someone please fill out the --

16 the, like, the council briefing sheet that we need to do.

17 At that time is when I found out the salary range for this

18 new position, which was titled Deputy Director of Strategic

19 Initiatives, which was to be in charge of the department's

20 seizure, so civil assets, and he was hiring a gentleman from

21 the federal defender's office who had experience with fraud

22 and seizures.

23 Q. So he had already made up his mind who he was

24 hiring?

25 A. Yep. He knew who he was hiring. His name is Tim

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1 Schwering, S-c-h-w-e-r-i-n-g.

2 Q. And did he have to create a new position?

3 A. Yep.

4 Q. So this deputy director --

5 A. So this another exempt position, so HR had come up

6 with a job spec for it, as well as the salary range. The

7 salary range was the same as my position as Director of

8 Business Services. The deputy director -- like I said, it

9 was going to be charge of civil forfeiture, asset, you know,

10 investigations. Basically, how can we get more money into

11 the department, with no direct reports, as I recall. And,

12 of course, HR is working closely with all division heads on

13 developing new job specs. So Straub --

14 Q. Who in HR was doing that?

15 A. It would have been Heather Lowe.

16 Q. Okay.

17 A. So, again, it was sort of a slap in the face, at

18 that point in time, that here we are hiring this new man who

19 is going to make the same amount of pay as I am with less

20 responsibility. He was given a take-home car, because, in

21 theory, he'd be out doing I don't know what. You know, I --

22 I wouldn't have taken a take-home car. I mean, I'm single.

23 It would have been a pain in the butt to try to juggle two

24 cars. But it was never offered to me. It was never

25 suggested that I needed a take-home car. I was down at City

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1 Hall weekly for meetings driving my own car.

2 Q. But I think you mentioned that this new position

3 would be more out in the community, or you don't think so?

4 A. I don't think so. I mean, it was -- because he

5 was supposed to be doing, I think, marijuana, because

6 marijuana had been legalized at that point, so how is that

7 going to be regulated. The -- I mean, if you read the job

8 description, like I said, on civil asset forfeiture. So

9 kind of working on those investigations, like, so -- and he

10 reporting to the investigative commander. So he reported to

11 Joe Walker. So it was branched in the investigations

12 department. And all of the investigators had take-home

13 cars. So, I mean, it wasn't, I suppose, out of the realm

14 that he would get one.

15 Q. Uh-huh.

16 A. Every member of executive staff had a take-home

17 car except for me. I mean, it -- you know, but it was,

18 again, one of those Carly, get Tim on the budget, get him

19 paid, and get him a car. Well, we were so short of cars at

20 that point in time. And that was another reason I was

21 constantly getting -- for whatever reason, the city

22 purchases the -- the police department fleet once a year. So

23 we make one purchase for about 20 cars, and then rotate them

24 through as needed. Because it was about the same time that

25 the Crown Vic stopped being made and we moved to the new

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1 Interceptors, there had been a lag in buying time, so

2 nobody's fault, but we just kind of had come into a crunch.

3 It's also the same time that we're putting the new

4 emergency communications systems, the 800 megahertz radio

5 system. So those are taking longer to install. So it's

6 just a perfect storm of bad timing. And so we're not

7 turning them over as quick as we can. Again, City Fleets,

8 that does all that work, doesn't report to me. I just have

9 the two guys that do flat tire changes and that sort of

10 thing. But --

11 Q. So can I go back to the -- you're -- you're

12 learning, for the first while you're in Seattle attending

13 this leadership training, that the chief has made a decision

14 --

15 A. Right.

16 Q. -- to create a new position, which is a deputy

17 director, and he's already made up his mind who he's hiring.

18 And the process of creating the new position, doing the job

19 spec, as you call it, has already been done by HR.

20 A. Right.

21 Q. Is that the same process that you went through

22 when they created your position?

23 A. Yeah.

24 Q. Are you aware of any differences in how it was

25 handled procedurally?

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1 A. No. The only difference would be the rush on when

2 it was done. We had met Tim before we went to Boston. I

3 mean, he had met him somewhere, and he thought Tim was,

4 quite frankly, the bee's knees. And so he was interested in

5 bringing him on board. I think what's different -- and

6 maybe not different. I think, again, it was another one of

7 these we're going to create a job description to fit the

8 person we want to hire instead of what I believe is the

9 correct method of, I'm going to create a job description,

10 then go find the right person.

11 I'm not going to pretend that I didn't benefit

12 from that as well in both cases. They clearly designed a

13 job description, knowing already that I was going to get it.

14 I still think that that's the wrong way to go about doing

15 things.

16 Q. And so the -- but the other thing that came to

17 your attention that you thought was a slap was the fact that

18 he was going to be paid at the same --

19 A. Yeah.

20 Q. -- the same salary range --

21 A. The same salary range when he's got a deputy

22 director title versus director, doesn't have the same chain

23 of report. It just --

24 Q. Uh-huh.

25 A. Like I said, to me, it reeked of gender

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1 discrimination.

2 Q. And do you know what he was eventually offered

3 within that range?

4 A. I'm pretty sure he started out at the lower level,

5 the entry level, which is what I was at, because, again, we

6 had to find the money to do it. So I'm -- I'm fairly

7 positive it was the same entry level. That was in late July

8 of 2013.

9 Q. Were you still being paid at the lowest level of

10 the range?

11 A. In October of 2013, after I was moved out and they

12 reorganized, he developed a new position for Tim, which

13 basically took over all of the functions I previously had,

14 plus the Internal Affairs department, and that new position

15 afforded him an $18,000 raise.

16 Q. So let me make sure I understand that. When you

17 went to City Hall to work on what you thought was a

18 temporary project, the mayor -- the mayor -- the police

19 chief reorganized again.

20 A. Uh-huh.

21 Q. And created a new position, like with a new title?

22 A. Yep.

23 Q. And what -- is that --

24 A. It was -- he went to Director of Strategic

25 Initiatives.

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1 Q. And do you know if he went through HR to do a job

2 spec and a --

3 A. Yes.

4 Q. -- salary, the whole process?

5 A. I'm sure he would have. At that point, I was out,

6 so it would have been the same process again.

7 Q. And the outcome, as far as you understand it, is

8 that he took on your responsibilities? Were they made a

9 formal part of that job description?

10 A. I believe so, yeah.

11 Q. Okay. And then also, he was asked to take on

12 oversight of Internal Affairs?

13 A. Correct.

14 Q. And then resulted in an $18,000 range. Did it

15 move him into a different classification?

16 A. Yes. A new classification, a new salary range.

17 Like I said, it was -- the bottom of that salary range was

18 $18,000 higher than the bottom range of the classification

19 that he had been in before. So where they moved him on

20 that, I don't even know, but the -- the bottom line

21 difference was $18,000. So in the space of three months,

22 he's promoted to a higher-paying job, that was essentially

23 everything I had been doing before, plus Internal Affairs.

24 Q. And you had already gone to City Hall when you

25 learned about this?

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1 A. How I learned that my temporary move wasn't so

2 temporary was, as part of the chief cutting corners, if you

3 will -- and we had two police planners in the department.

4 One of them I worked very closely with and was very good at

5 his job. We had another one that, for whatever reason, just

6 wasn't performing to where he should be. The decision was

7 made, because he had been my former supervisor quite

8 sometime ago, that he shouldn't report to me, that he should

9 report directly to the assistant chief.

10 And so Craig Meidl was unhappy with his

11 performance as well. And so the chief, rather than do the

12 correct, you know, what you should do, which is put someone

13 on a performance improvement plan to give them a chance to

14 improve, his choice was to, we're just going to eliminate

15 planners, and then we'll offer Jason an exempt position. So

16 we'll get rid of the poor performer and we'll offer Jason an

17 exempt position. I argued against that.

18 Q. So you're still in --

19 A. Yeah.

20 Q. -- the department --

21 A. This was still -- yeah. This was also around that

22 July time frame. You know, it was, sort of, don't do that.

23 That's the -- again, the wrong way to do things. Do it the

24 right way. We can do this the correct way, and then we can

25 hire a real police planner. You know, if we can't improve

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1 the other one's performance, then, you know, we can get

2 someone on board. And I was overruled. And so we were

3 forced to make Deputy Business Services Director position to

4 report to me, and we hired Jason into that role, like, two

5 weeks before I left the department for the temporary job.

6 And so how I found about the reorg was, I moved to

7 City Hall, like, October 2nd of 2013, which is, like, a

8 Wednesday. The very next Tuesday, I believe, Jason asked

9 for my help on an org chart, because he was trying to

10 arrange what they wanted them to do, and, you know, needed

11 some feedback. At least that's what he told me.

12 I think Jason was actually trying to get me to see

13 it. And I'm looking at the org chart, and I'm -- I'm

14 staring at it, and I'm like, "I'm not on here." And Jason

15 said, "Yeah, you are. You're right here," and he pointed to

16 a position. I'm like, "No, that's Tim." I mean, it didn't

17 have names on it, but it had positions. I'm like --

18 Q. Like actual titles?

19 A. Yeah. And I was like, "Jason, that's --" because

20 I had been in enough conversation to know that they were,

21 you know, going into a little bit of a reorg, but, I mean,

22 this was a lot more dramatic than what I have been privy to

23 the week before. And I'm like, "I'm out of here. He's

24 completely cut my job out."

25 And it was one of those things that when I moved

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1 to City Hall, I always had an inkling in the back of my

2 mind, that this wasn't a temporary move. I remember packing

3 up my office here and crying. And, you know, Brad walked

4 by, and he's like, "What's going on?" He's like, "It's just

5 six months." I'm like -- I don't know. I just -- I guess

6 in my heart of hearts, the timing of when I was asked to

7 move to City Hall was a week after Straub blew up at me and

8 said he was going to fire me.

9 So the very next week, I am told, "Hey, Theresa

10 Sanders wants to talk to you about coming down to do this

11 temporary project, and I think it would be a really great

12 idea." I don't believe in those type of coincidences.

13 So I guess in the back of my mind, I always, kind

14 of, knew, but I had to get away from him, and so I was

15 willing to take the temporary job. When I saw the new org

16 chart, it was pretty clear what was going on, that I was

17 definitely out. And so I -- I left on my terms.

18 I think the next day, I had a meeting with the

19 chief regarding a project he was working on with Washington

20 State University, and afterwards, you know, had kind of told

21 him, I'm like, "So it looks like you're reorging, you know,

22 me out of the department." And he said, "Well, yes, you're

23 going to be gone for a while. I need to keep doing business

24 as usual." And I said, "Okay. You know, I understand

25 that." I said, "I guess we should probably just plan on me

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1 not coming back. I think that would be easier for

2 everybody." And then --

3 Q. Did you say that?

4 A. Yes. I wanted to leave on my terms. At that

5 point, he had jerked me around enough that -- I don't know,

6 I felt like I had to -- I was tired of being played like the

7 pawn, and so I was going to take matters into my own hands.

8 And so I said, you know, "Let's do that." The very next

9 day, I got a call from our IT department at the police

10 department, that they had cut off my security access to the

11 building, and had cut off my access to our shared drives at

12 the department.

13 I still had a police department laptop. I mean, I

14 had taken it to work with me on City Hall, because it was

15 supposed to be a temporary, just completely no -- no goodbye

16 or no, we're not having a party. I wish Carly

17 congratulations on her new job. It was just she's out the

18 door, out of mind, I get to move forward. And so it's after

19 that fact that I find out that Tim has now been granted --

20 you know, they officially make that org chart that I saw and

21 that he's got these new departments.

22 Q. Okay. So I want to go back.

23 We've been going for a bit. Do you want to a

24 break?

25 MR. CHURCH: Yeah.

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1 MS. CAPPEL: A five-minute break?

2 MR. CHURCH: Five minutes.

3 MS. CAPPEL: Okay.

4 THE REPORTER: Off the record.

5 (WHEREUPON, a recess was taken from 11:04 a.m. to

6 11:15 a.m.)

7 MS. CAPPEL: So we're back on the record, and it's

8 about 11:15.

9 BY MS. CAPPEL:

10 Q. Carly, when we broke, we were talking about some

11 conversations you had with the chief right before you, well,

12 transitioned to City Hall for this temporary project. So

13 let me back up a little bit.

14 Who first approached you about taking on the

15 temporary?

16 A. Right. It was told to me through Chief Straub.

17 Like I said, I -- we'd have an exec team meeting that

18 morning. And as everyone got up to leave, he said, Carly,

19 can you stay behind." And as I said -- I went, "Well, this

20 is it. I'm finally going to get fired," was my first

21 thought. And, you know, he very calmly said, "You know, I

22 met with Theresa Sanders last week, and the city is

23 embarking working on this 311 project, and she has asked if

24 we will lend you to go work on this project." And then he

25 said, "I think it would be good for you to experience

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1 something outside of the police department," that by working

2 at City Hall, I will be exposed to different types of

3 people.

4 Q. Uh-huh.

5 A. And that it would be good for the department

6 because of the nexus to the nonemergency law enforcement;

7 that it could provide a way for us to take back those

8 CrimeCheck calls. He said, "So, go ahead, if you're

9 interested, set up a meeting with Theresa, and, you know, go

10 from there." It was completely, you know, set up as it's my

11 decision. You know, he did say if it turns out to be one of

12 those City Hall projects that isn't going to go anywhere,

13 you know, let me know. So I set up a meeting with Theresa.

14 Q. Can I ask you: Did he say how long he estimated

15 the project would be in that first conversation?

16 A. I don't remember if it him or Theresa, to be

17 honest. There was an estimate of 12 months. Six to 12

18 months was the initial assessment of how long I would be on

19 loan.

20 Q. And you don't know if that came from --

21 A. I do not remember --

22 Q. -- to Straub or --

23 A. -- if it came from Straub or from Theresa.

24 Q. Okay. When he first proposed this idea to you,

25 did he suggest in any way that he would not bring you back

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1 to the police department?

2 A. No.

3 Q. Did that come up at all?

4 A. Never.

5 Q. Did you have any -- did you think about whether

6 that was an issue?

7 A. Like I said, there was, in my heart, I felt that

8 there are no such things as coincidences. It was just too

9 much that he had threatened to fire me the week before, and

10 now I'm being magically offered this temporary job away. It

11 smelled funny.

12 Q. And you recall feeling that way --

13 A. Yes.

14 Q. -- this time, this first conversation?

15 A. Yes. I mean, right away. Just sort of -- it was

16 twofold. It was relief that I wasn't getting fired, and

17 then, two, a -- while I think this is a trick, I also need

18 to get away from you. You are making me sick. I am -- you

19 know, I'm trying to lead my people, and the same time, not

20 show that I'm crying at the office. I mean, it's -- it had

21 become very stressful to be working there, and so -- I'll be

22 honest.

23 I went and met with Theresa to learn more about

24 the project, and Theresa was very -- I don't know if

25 flattering was the word -- of we would really like you to

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1 come on and do this. You have a great skill set for it, you

2 know. And then she was like, you know, and it's -- it's up

3 to you if you want to. We'd be -- it would be great.

4 Temporary. And then she said -- and that's why I know it

5 temporary -- "If you want to create a job for yourself at

6 the end of this, please feel free to do so."

7 Q. What did that mean?

8 A. That with the design of 311, if I wanted to design

9 a job that would fit in that umbrella, that I guess, to me,

10 I took it as a you can create a new job for yourself and

11 come work here if you want to.

12 Q. Okay.

13 A. I said, "Thanks, but I'm happy at the police

14 department, but based on this conversation, I really would

15 like the opportunity to come work on it, on a temporary

16 basis."

17 Q. You told her that?

18 A. Yes.

19 Q. And did she tell you who you would be reporting

20 to?

21 A. Yes.

22 Q. And that was?

23 A. Would be Jonathan Mallahan. And, in fact, that

24 was -- how we left that meeting was, she suggested I follow

25 up with Jonathan, schedule a meeting and start working out

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1 how we were going to do that.

2 I met -- and this was August, at this point, of

3 2013. I met with -- I had vacation that week, so I feel

4 like I met with Jonathan after I got back, so mid August I

5 met with Jonathan and discussed the project, and, you know,

6 what he was looking for. And basically, it was, you know,

7 how are we going to take these services that these other

8 departments do and move them underneath the 311 team and the

9 technology pieces. So pretty much designing what would 311

10 look like, how would we do it, get the framework ready.

11 Q. And as you're talking to Jonathan, did you believe

12 this was a legitimate project or --

13 A. Yes.

14 Q. -- this was made up?

15 A. Nope. They had documents already. They had

16 already started in theory, kind of, the -- the framework of

17 the project that -- we had a staff. I guess the

18 department's name is MySpokane. They had already, sort of,

19 centralized customer service function the year before. And

20 so that the current manager over that department, I think

21 that was part of the reason that they brought me in, is that

22 she didn't have the skill sets to do this whole big piece of

23 it; that she had been able to pull together the initial

24 team.

25 Q. Uh-huh.

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1 A. But the broader, this is a whole new thing that

2 we're bringing with whole new technology, she was struggling

3 with. And so --

4 Q. Okay. Did Theresa mention whether she would need

5 to get anyone else's permission or authorization to move

6 forward?

7 A. No.

8 Q. Was there any suggestion that she needed to talk

9 to the Mayor or HR?

10 A. Nope.

11 Q. How about get council approval?

12 A. Nope.

13 Q. It was just going to physically move you across to

14 City Hall?

15 A. Right, that I'd be on loan from the police

16 department.

17 Q. Did you have to fill out any documentation?

18 A. No.

19 Q. Did you ever meet with HR to discuss this?

20 A. No.

21 Q. Do you know if that's consistent with city

22 practices and policies, this on-loan arrangement?

23 A. We've done it before at PD. The under performing

24 planner I had discussed?

25 Q. Uh-huh.

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1 A. We had loaned to the mayor's office the year

2 before because they needed somebody to work on projects.

3 Q. Okay.

4 A. In my experience, that's the only on loan that I'm

5 aware of.

6 Q. So you didn't have to fill out any forms.

7 A. Nuh-uh.

8 Q. No, like, personnel change form that you're aware

9 of?

10 A. No.

11 Q. And did they explain how your compensation, what

12 it would be?

13 A. It would stay the same, because I'm on loan.

14 Q. Okay. So what's the next move? You meet with

15 Jonathan.

16 A. So I meet with Jonathan. Jonathan and I come up

17 with a, sort of, transition plan. So I had -- was taking a

18 long weekend at the end of September to go on a trip to

19 Florida, and with just various projects that I was working

20 on, we decided that October I would move down. But during

21 the month of September, I would start attending his

22 leadership meetings and starting to get to meet the people

23 and kind of start working on those projects.

24 So -- so I had started -- you know, I probably put

25 ten hours total in the month of September, kind of, meeting

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1 the players and that sort of thing at City Hall.

2 Meanwhile, back at the police department, I'm --

3 like I said, that was about the time that we're hiring Jason

4 to be my deputy director, and I'm giving him the -- you

5 know, this is what I do, this is what you're going to be

6 responsible for; meeting with all of my direct reports to

7 explain the change, and, you know, this is what I expect of

8 you.

9 This is a key point. I sent out an e-mail,

10 approximately a week before the move, so it was before I

11 went on vacation, to all of the executive staff, which

12 included the chief, as well as, like, a couple of other

13 captains that we had had promoted -- so, you know, our --

14 our leadership team -- that specifically stated I'm going to

15 be down at City Hall.

16 This is who you need to contact for these things.

17 And then said I plan to spend ten hours a week still up here

18 at PD to work on accounting things, because it was the only

19 thing that I really couldn't transition to anybody. And so

20 I'll be here on Monday mornings for exec staff, and I'll

21 stick around Mondays. And I had already cleared that with

22 Jonathan.

23 He knew that I was going to be doing that, because

24 in my mind, after those initial meetings in September, it

25 was pretty clear to me that the 311 project, at least

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1 initially, wasn't going to be a full-time job; that I know

2 my skill set and what I can do, and it was a 20- to 30-hour

3 a week job. So me being able to spend ten hours a week up

4 at PD seemed very feasible. And, of course, I was already

5 working more hours than that, anyway.

6 So I sent that out very clearly, it's clear to me

7 that this is temporary. I'm still going to be, you know, in

8 charge of these things, but your day-to-day contact will be,

9 basically, my direct reports. No one ever came to

10 contradict me on that e-mail to say, "Hmm, Carly, you have a

11 different understanding of how things are going to happen

12 then."

13 Q. Do you still have access to this e-mail?

14 A. I do. I fact, I brought it.

15 Q. Do I get it?

16 MS. CORTRIGHT: Does she get it?

17 MR. CHURCH: Uh-huh. Sure.

18 BY MS. CAPPEL:

19 Q. At what point did you inform Straub that you were

20 going to accept the offer?

21 A. I think after I met with Theresa. So I believe I

22 came back the -- that same -- I feel like I met with her on

23 a Thursday. I could go back and look at my calendar. I

24 believe it was August 8th.

25 Q. The meeting with Theresa?

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1 A. Yeah. And like I said, I was on vacation the

2 following week. So -- and I had -- I was working four tens

3 at the time, so I would have Friday off. So it's possible I

4 didn't -- I feel like I would have told him before I went on

5 vacation. I mean, that just -- in my mind, I don't think I

6 would have left him hanging for a week. So I'm pretty sure

7 I probably told him that afternoon that, yeah, it seemed

8 like a legitimate project, and I was going to follow up with

9 Jonathan.

10 Q. Do you remember if that was face to face or e-mail

11 or --

12 A. I feel like it was face to face. I don't

13 remember, to be sure.

14 Q. Any recollection of his reaction or anything more

15 he said about it?

16 A. He was positive. I mean, at that point,

17 everything with him changed. He was exceptionally nice to

18 me for the next six weeks that I worked there.

19 Q. Okay. And no response to this e-mail, which is --

20 A. No.

21 Q. -- what I'm looking at is an e-mail from Carly

22 dated Monday, September 9th, 2013, to SPD Command Staff. Is

23 that the executive leadership team?

24 A. Yeah.

25 Q. And then you cc'd these other folks who are --

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1 A. Right.

2 Q. -- on here? Okay.

3 A. So yeah, the SPD Command Staff would have included

4 the Chief, Craig Meidl, Joe Walker, Brad Arleth, Monique

5 Cotton, and myself.

6 Q. Okay.

7 A. So no one -- no one contradicted the statements in

8 that e-mail to say, like I said, "Hmm, no, Carly, you don't

9 understand what's happening."

10 The -- I went to Orlando, Florida at the end of

11 month, came back. I think I had that Monday off. I came in

12 -- I think I actually had Tuesday off, because I got in very

13 late Monday night. But there was a meeting planned on

14 Tuesday to talk about the reorgs that they were planning. I

15 knew there was a reorg going on. I didn't see the org chart

16 until after I left. But so we were, you know, moving things

17 around. And one of the -- I came in on my day off in the

18 afternoon to attend the meeting, and the chief welcome my

19 contributions at that meeting.

20 We discussed -- and we were drawings things on the

21 board, and decided that we were going to move forward, and

22 so we were now making another captain, and that was going to

23 be Rick Dobrow, who is currently the interim chief. At the

24 time, he was a lieutenant, but we were going to pay him out

25 of grade as a captain. Pretty much everything we did at the

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1 department, contrary to what things have been in the past,

2 was to do out of grade, because we didn't have the positions

3 yet. So he was constantly adding new positions.

4 So until we could get all of the red tape to catch

5 up with it, we would pay people in an out-of-grade status.

6 So he needed someone to write the memo to HR, because

7 basically you end up saying we want to promote -- or put

8 this person in an out-of-grade status in this salary range

9 starting this date to this date.

10 Q. Uh-huh.

11 A. So that was one of the last things I did. It's

12 like, you know, "Carly, go do this." "Okay. I'll get it

13 done. I'll get it taken care of," you know, I think trying

14 to prove I'm still committed to being here and -- you know,

15 he'd been nicer to me and things were going better, and I

16 wanted to be helpful. So I went and did that. Packed up

17 some of my things, and, you know, moved to my new office at

18 City Hall. That was a Wednesday. And like I said, it was

19 the following -- it was either Monday afternoon or Tuesday

20 of that following week. I just -- I don't remember

21 specifically. I do remember it was one of those days

22 because the Wednesday was the meeting with WSU on -- the

23 account at Washington State University, and so, I mean, that

24 was when I --

25 Q. Uh-huh.

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1 A. -- made up my mind that, okay, we're not going to

2 play this game. But Jason showed me the org chart, and like

3 I said, I could look at it and I could see -- because that's

4 why Jason thought it was mine. It was all of my divisions,

5 all of my units were on this org chart, plus Internal

6 Affairs. And that's how -- I mean, Jason thought it was me.

7 I'm like, there's no way they'd put me in charge of Internal

8 Affairs. I mean, that -- that doesn't make any sense. I --

9 I know that that's not --

10 Q. Is Jason still at the department?

11 A. Jason is. Jason, after I left, when it became

12 clear what was going on, took a voluntary demotion to go

13 work in our property evidence facility as an evidence tech.

14 Q. And that's what he's doing currently?

15 A. Yes, and he's still there.

16 Q. Where is his office located?

17 A. He is out at the evidence facility, which is, I

18 think, 4100 East Alki, A-l -- you're from Seattle.

19 Q. Did he talk to you about why he took a demotion?

20 A. Yeah.

21 Q. What did he say?

22 A. Jason and I had been planners together, and we got

23 hired within a week of each other. Jason was my closest

24 colleague at the department, so he knew the strife of

25 working for Straub and what that was like. I had told him

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1 about, you know, we're eliminating the planners. You're

2 going to get offered this deputy director position that

3 makes you exempt. And he's like, "I don't think I really

4 want that, Carly." And I'm like, "I understand. You won't

5 have a job if you don't." I mean --

6 Q. Uh-huh.

7 A. -- we're literally putting people in a rock and a

8 hard place. We're -- we're trying to get rid of one

9 employee, so we're going to screw the other one over to make

10 it happen. So Jason reluctantly accepted the promotion to

11 the deputy director when it was clear that I wasn't going to

12 be his boss anymore and wasn't going to be there. The

13 property people -- he had helped design the whole new

14 facility, and we used to be in this really horrible building

15 over here. So he had worked with property for a long time.

16 They liked him. They'd been trying to get him to come out

17 there forever. It was a demotion. It was a pay cut. So he

18 wasn't previously open to their offer, but they still had

19 the open position.

20 Q. Uh-huh.

21 A. And he knew, "I don't want to work for Straub.

22 This is a bad environment, and with you gone, especially,

23 I'm not going to do it."

24 Q. And that's something he said to you --

25 A. Yes.

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1 Q. -- about the reason he took the demotion.

2 A. Yes.

3 Q. And had Tim already been hired by the time he took

4 the demotion?

5 A. Tim, as the deputy director, so Tim was there as

6 the -- so Tim didn't -- you know, the timing at that point,

7 Tim probably was the director, so Jason probably reported to

8 him for a brief amount of time.

9 Q. Do you have this org chart that you're referring

10 to? Do you have a copy of it?

11 A. I don't think so. I've got all the old ones up

12 until that point. I could probably get that one.

13 Q. How would you go about doing that if you were to

14 do it? I'm not going to ask you to do it, but I want to

15 know how.

16 A. Right. Joe Walker, who was the commander at the

17 time, who also during this same time, takes a voluntary

18 demotion back down to captain, because he's expressed that

19 he doesn't work for the chief any longer in that role,

20 mostly because of the hours and the time commitment was, you

21 know, what he expressed at that time. But I -- I have -- I

22 have an e-mail from Joe, he wanted all the previous org

23 charts. So I had sent them to him. And so I'm fairly

24 positive he has a file of org charts from the departments,

25 because this was part of the -- after I left, Joe had met

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1 with HR several times. He was president or vice president

2 of the Lieutenants and Captains Association, and was trying

3 to demonstrate that Straub keeps changing things up, like,

4 every two months.

5 Q. So do you think he'll have copies of everything

6 that you have kept, or do you think you have something he

7 doesn't have?

8 A. I don't know. I couldn't tell you. Like I said,

9 I know I still have the e-mail of what I sent him of the org

10 charts that I had up until that date. That cut off my

11 access to the computers.

12 Q. But you still currently have that e-mail?

13 A. Uh-huh.

14 Q. Can you provide that to me?

15 A. Yeah, I could provide it to you.

16 Q. You have my business card.

17 A. Yeah, I do. Yeah.

18 Q. And while we're on the subject of e-mail, if there

19 are any other e-mails you think are relevant to -- to what

20 we're talking about --

21 A. Okay.

22 Q. -- to your concerns, if you're okay with providing

23 them, maybe send them to you first and you can decide?

24 MR. CHURCH: Yeah. Why -- why don't you show them

25 to me, and then I can forward them.

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1 MS. CORTRIGHT: Okay.

2 BY MS. CAPPEL:

3 Q. Okay. And that's true with any other notes or

4 documents you're aware of --

5 A. Okay.

6 Q. -- that you're willing to share with me. Okay.

7 So you see the org chart that looks like you have

8 been eliminated from the department. How do we then get to

9 the conversation with the chief when you say we should just

10 part ways and --

11 A. Because we had a meeting where he brought Tim

12 Schwering along, and we met with Washington State. We had

13 been funding some of their researchers to work on the CIT

14 program, Crisis Intervention Team, and I wanted to, kind of,

15 here are my ideas on how to fund that. So after that

16 meeting, like I said, I'd been kicked by this man enough at

17 this point. He'd been dishonest to me. Actually, there's

18 an important piece of in between on that.

19 After Jason had showed me the org charts, and it

20 was clear that I wasn't on there, then Jason became very

21 worried that he was now going to get in trouble; that --

22 that he had shown me something that he shouldn't have. And I

23 was like, "Jason, you thought you reported to me. You didn't

24 do anything wrong, and I will tell them that."

25 And so he went and told Craig Meidl, who was the

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1 assistant chief, who now, in theory, Jason would be

2 reporting to with me gone, and Craig, apparently, did get a

3 little upset with him for sharing.

4 Q. Jason told Craig that he had shared the org chart?

5 A. Right. And I guess Craig did get a little upset

6 with him about that, and -- and so, and so Jason told me

7 that, you know, Craig did get upset. And I said, "Jason,

8 that's not right." So I believe I texted Craig -- I don't

9 think I e-mailed him. I'm pretty positive it was text --

10 and basically said, "Don't be mad at Jason. He thought that

11 he was reporting to me. This isn't his fault." And Craig

12 said something to the effect of, "Well, you should have

13 known that he didn't report to you."

14 And I said, "Craig, that's not my understanding.

15 I thought that --" I mean, the e-mail I sent out, I thought

16 it was still pretty clear that I was at least somewhat in

17 the door. I did not know that this was happening. He said,

18 "Well, the chief said that he made it very clear to you."

19 And my final reply back was, "Well, that's not true."

20 Q. Made what very clear to you?

21 A. That I was no longer in the department.

22 Q. And this is all through texts?

23 A. Yes.

24 Q. Do you still have those?

25 A. I don't, no. That was on my department cell

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1 phone, and I gave that back when I left.

2 Q. Do you know what happened to that phone once you

3 turned it back in?

4 A. Erica Wade has it. Well, she has the phone

5 number. I don't know if the phone is still with her or not.

6 Q. Okay. Did you ever talk to Craig outside this

7 text exchange?

8 A. No. By that point, I was furious with him. I

9 felt that he was -- had betrayed me as well.

10 Q. Craig?

11 A. Yeah. He'd -- in recent weeks, he and I had been,

12 kind of, at each other's throats. One of my direct reports,

13 the records manager, had a duty. She was our TAC

14 coordinator, which stands for Technical Advisor, and it was

15 regarding the access to the criminal history system

16 monitored through WSP. Theresa had inherited the records

17 manager by somebody years before when she was hired. It's

18 really not a records function. It's -- you have to do a

19 criminal background check on employees every three years,

20 and you have to audit why are they accessing the system, are

21 they using it the way they're supposed to.

22 Q. Uh-huh.

23 A. And in my opinion, that's an Internal Affairs

24 function. Discussed it with our legal advisor, Mary

25 Murmatsu. She actually thought it belonged at the academy,

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1 but was in the agreement it should be a commissioned officer

2 position, you're investigating --

3 Q. Uh-huh.

4 A. -- essentially, mostly commissioned officers. This

5 shouldn't belong in records.

6 Q. Is that something you crossed hairs with Craig

7 over?

8 A. Yeah. And I can find you e-mails on that. So I

9 was pretty insistent that we needed to have a conversation

10 about it and talk about moving it. Craig, for whatever

11 reason, did not like Theresa, and so, I think, was very

12 myopic about having that conversation. Essentially, there's

13 too much other things going on. It's a records function.

14 It needs to stay with Theresa. And I said, but no, even

15 legal is saying this needs to move.

16 Q. Okay.

17 A. We really need to talk about this.

18 Q. So you knew all of these things before you have

19 this conversation with --

20 A. Right. So at that point --

21 Q. -- Chief Straub.

22 A. -- I -- and it was over a weekend. I -- like I

23 said, it had been a very stressful nine months. I had

24 worked at the department for ten years at that point, had,

25 you know, blood, sweat, and tears. I, unfortunately, was

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1 one of those people that my career and my job were my

2 identity. It was everything. It bothers me now.

3 And I was -- I hated him so much for being

4 dishonest with me, for the way he had treated me, and to,

5 basically, right behind my back, temporarily send me off

6 underneath that expectation, and -- and to basically tell

7 Craig that no, I told Carly. She should know. And now he's

8 a liar on top of it.

9 From my -- I don't know -- just self-powerment, I

10 felt that I needed to tell him -- you know, I did it in my

11 best professional, very friendly way of I'm -- clearly, you

12 need to go on without me, but let's just work under the

13 assumption I'm not coming back. And, I mean, we hugged. It

14 was a very nice, you know, congratulations, you know. I

15 think he even said, "I would like to get together and have

16 coffee with you to talk about your career," which never

17 happened.

18 Q. Okay.

19 A. It was -- I just had to do it. For -- for me, it

20 was clear that I had been lied to and misled. And I think

21 what further goes to that, and something I only found out

22 about in November of last year.

23 Q. 2015?

24 A. Yeah. After I left, the Chief had told Joe Walker

25 and Brad Arleth that part of the reason, you know, they were

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1 questioning about why is Carly gone, why did this happen,

2 and he said that Carly had to go because of her cunt-ish

3 behavior. And it was something that they didn't tell me

4 about at the time. I, at the time, had considered seeking

5 legal. You know, I mean, I really felt like I had been

6 treated wrongly, but again, the discrimination, the

7 retaliation for telling him no, you can't do these things.

8 And at the end of the day, it was sort of like, I

9 have a job. I'm away from him. I -- I don't -- no one is

10 going to believe me. I mean, which I think the crux of this

11 whole investigation is, it's the chief. He's the hand-

12 picked chief by the Mayor, and me going and saying that he

13 treated me this way and said these things, nothing is going

14 to happen. And I have a job. It's paying the same. I'm

15 going to -- I'm going to let it go.

16 Q. This is what you were thinking last November?

17 A. No. This is what I was thinking when I first

18 left, so October of '13. Brad and Joe didn't tell me about

19 the cunt comment until November of 2015. I wish they had

20 told me earlier, because I feel like I may have -- and

21 that's a horrible thing to say to anybody, and to say it to

22 my peers after I left is...

23 Q. Did both Joe and Brad tell you that that's what

24 they mayor had said?

25 A. The chief had said.

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1 Q. I'm sorry. The chief had said. And let me clear

2 that up. Did -- did Joe tell you that that's what the chief

3 had said?

4 A. Brad is the one that had told it to me. He said

5 he said that to him and Joe. And since that time, Joe and I

6 have talked about it, and Joe said that he heard it as well.

7 So they both told me separately, but Brad was the first one

8 I heard it from.

9 Q. Okay. And did they give you any further details

10 about the context of that conversation?

11 A. No. It just --

12 Q. It was along the lines they were asking why you

13 left the department?

14 A. Yeah. Right.

15 Q. And his comment was what you described?

16 A. Right.

17 Q. Okay. And the other thing you mentioned is that

18 when you made the transition in October of 2013, you thought

19 -- you contemplated getting legal counsel at that time, but

20 decided against it for the reasons you have explained.

21 A. Yeah. I mean, it's he said, she said environment.

22 He's the chief of police. And -- and I feel -- I mean, the

23 comments I've made in the paper. I think how this

24 administration has handled the situation, kind of, shows

25 that I was correct; that if I had brought my complaint

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1 forward, it -- it would have been me thrown under the bus

2 instead of him being held accountable for his actions. It's

3 something I regret. I look at everything that has happened

4 since then, how every -- so many other employees at that

5 department were treated, and I wish that I had had the

6 courage to come forward then. I don't think anything would

7 have changed, but at least I wouldn't feel like I could have

8 done something.

9 Q. Okay. So on that front, did you ever report your

10 concerns about how you were being treated to anyone in the

11 police department, either the command staff, a legal

12 advisor, or an HR representative?

13 A. No. They all observed it, I mean, at the exec

14 staff level. I mean, Joe, Brad, and Monique. I mean, I've

15 talked to her since. I mean, they observed his nitpicking

16 constant, kind of, negative behavior. I mean, there was --

17 Brad and Monique were both there the day that he yelled at

18 me and threatened to fire me.

19 Q. Uh-huh.

20 A. I mean, so there -- there were a lot of

21 observations on that. Erica Wade, who I referred to, she

22 had been an accountant at the department, had transferred to

23 City Hall for a promotion, and then actually was brought

24 back as part of that reorg when I left. But at the time,

25 she was a confidant, and, you know, I told her how I was

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1 being treated. But no one in an official capacity. I had

2 coffee with Mary Murmatsu after I left, because there was a

3 lot of, I guess, surprise. I mean, a lot of people were

4 very surprised that I was suddenly gone.

5 And -- and Mary expressed to me, while we were

6 having coffee, that she was alarmed at how the chief is

7 treating female employees at the department. And I don't --

8 I didn't give Mary the detail of, you know, some of the

9 things that have occurred. But, you know, basically had

10 said that I -- you know, that he was very difficult to work

11 for, and I -- I took the transfer because, you know, I

12 needed to get away from it, and that --

13 Q. What's the earliest time that you had that

14 conversation with Mary?

15 A. It was after I moved. I mean, so it would have

16 been late October, early November of 2013.

17 Q. And this, you mentioned, was just having a cup of

18 coffee?

19 A. Yeah.

20 Q. Did she provide any details about the women that

21 she thought the chief was not treating well?

22 A. No. I'm trying to remember. At that point, he

23 had moved Judy Carl, who was a captain at the time, she was

24 our highest-ranking female officer, had kind of changed her

25 job twice, I believe, in that time period. The -- at that

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1 point --

2 Q. What was her rank?

3 A. She was captain.

4 Q. Did she lose that rank?

5 A. No, she stayed as a captain, but they kept moving

6 her into different roles. Shortly after I left, the records

7 manager I referred to, that Mary was also working with, that

8 we were like this role needs to come off of her, and so

9 maybe Mary needs something --

10 Q. Her names is Teresa?

11 A. Yeah, Theresa Giannetto, which is G-i-a-n-n-e-t-t-

12 o. And I found this out later from Theresa, but Mary might

13 have known, just based on the timing, that they had tried to

14 discipline Theresa for not doing her job, which ended up not

15 going anywhere, because all of the things that they tried to

16 discipline her on weren't things that she was responsible

17 for. So it, kind of, didn't go anywhere. And that would

18 have been about November of 2013.

19 They eliminated her position in January of 2014

20 and said that a records manager was no longer needed, and

21 basically laid her off, which, in my opinion, based on my

22 experience, is because they didn't like her, and so rather

23 than doing it the right way of trying to discipline her,

24 which takes too long, they just eliminated the position.

25 Q. So Theresa is no longer with the --

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1 A. Correct.

2 Q. -- the police department. Is she with the city?

3 A. Nope. She retired.

4 Q. Other than -- did -- what details did you provide

5 Mary about your experience working for Straub? For

6 instance, did you tell her about the comments he would make

7 in the leadership team meetings?

8 A. Nope. Just the general -- I guess, you know, the

9 -- my biggest complaint with Straub was always the negative

10 you're not -- you know, you're not doing what I want you to

11 do without providing the this is what I want you to do

12 instead.

13 Q. Okay.

14 A. So it was just critical without this is how you

15 can correct the behavior. He would be critical of people in

16 CompStat meetings, which Mary would go to. So she had

17 witnessed that. I mean, so I think Mary observed a lot of

18 things on her own.

19 The other female employee, now that I think about

20 it, because it happened at the exact same time, was Angela

21 Golden, who was our primary accountant. The -- shortly

22 after I left, he requested a meeting with Gavin Cooley, the

23 CFO, to have Angela removed as his accountant. Unbeknownst

24 to him, Angela had accepted a promotion with the City that

25 same day, so she was moving anyway. But --

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1 Q. She was the accountant in the police department?

2 A. She was assigned to the police department, so she

3 worked for accountings. We had a centralized accounting

4 function, but she was assigned as the police department's

5 main --

6 Q. Do you know what basis he gave to Cavin for --

7 Cavin -- Gavin for removing Angela?

8 A. I'm sure what he gave was just poor communication

9 or wasn't getting the information he needed, would be my

10 guess on the excuse.

11 Q. Is it a guess or do you have any reason to know

12 what he said?

13 A. I don't know what he said. I -- I do know he

14 wanted to remove Angela earlier in the year.

15 Q. Did he tell you that?

16 A. Yes.

17 Q. And what excuse did he give you?

18 A. The excuse on that was there was a report -- the

19 city monitors what websites you go to, so they send out a

20 report, and Angela was spending a lot of time on Facebook,

21 and so to him, she wasn't working. I know from working with

22 Angela that she took her computer home every night and on

23 the weekend, and I'm sure she probably was on Facebook, but

24 it was also when she was not working. It was her primary

25 laptop. Angela and I -- you could look at all of our e-

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1 mails. We would e-mail each other on the weekend at night.

2 I mean, we were constantly in contact. I probably

3 had more contact with Angela than I did most other people in

4 that department. Because we had $52 million budget, there

5 was a lot of things that needed to go on, and it wasn't

6 enough to cover what we were doing. We were in contact a

7 lot. Yeah. So he had -- he said he didn't. And him and

8 Angela didn't communicate well. She would try to explain

9 things to him, and you could see that he wasn't getting it,

10 and I think he thought that she was being difficult on

11 purpose.

12 And I could tell it was just because he wasn't

13 understanding her. But I -- and Craig Meidl liked Angela as

14 well. So I think between the two of us saying no, Angela is

15 the best accountant the city has, you really want to keep

16 her, we managed to keep her. But I guess that -- it's

17 pretty obvious to me that the chief wanted both of us gone

18 because we were impeding what he wanted to spend money on.

19 Q. Because you were pushing back.

20 A. Yeah. That we kept saying, "You can't spend money

21 on that," or, "You don't have the money to do that," and he

22 doesn't like being told no.

23 Q. And so one of the things you mentioned is Mary was

24 at these CompStat meetings, and she likely observed some of

25 his critical comments. Was he only critical about certain

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1 genders?

2 A. No. He's pretty equal opportunity.

3 Q. And this notion that he doesn't like to hear no,

4 do you have information that that was true with male

5 employees who may have pushed back or tried to tell him no?

6 A. I believe so, in terms of his interaction with Joe

7 Walker and what Joe has confided to me. He -- he was really

8 horrible to Joe, after Joe said, "I don't want to be

9 commander anymore. It's too much time commitment, and

10 basically, you keep changing things, and you're not giving

11 me enough time to really work on it. And I'm -- I'm not

12 well suited for this position." He was very upset at Joe

13 for that, and I think retaliated against Joe quite a bit for

14 that. So --

15 Q. Okay. So I'm looking at the letter that went to

16 the Human Resources Department, and this is dated December

17 21st, 2015. And my question is: Before the date of this

18 letter, had you ever gone to HR to report concerns of gender

19 discrimination, sexual harassment, or retaliation?

20 A. No.

21 Q. And had you ever gone to anyone in the police

22 department with complaints of --

23 A. No.

24 Q. -- harassment, discrimination, or retaliation?

25 A. No.

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1 Q. Had you ever had a conversation with Theresa

2 Sanders where you expressed concerns that you thought the

3 chief had engaged in gender discrimination, retaliation, or

4 harassment?

5 A. No.

6 Q. How about the mayor?

7 A. No.

8 Q. Heather Lowe?

9 A. Not officially.

10 Q. So what about unofficially?

11 A. Heather Lowe was part of a group of friends that

12 we would go out socially drinking and eating a couple times

13 a month. And Heather didn't attend all the time, but she

14 was there. So we were never friends outside of that group.

15 We didn't do anything else together socially, but, I mean, I

16 would consider myself friendly with Heather. Heather aware

17 of some of the treatment.

18 Q. What kinds of things did you share with her?

19 A. Again, the -- the belittling. The, yeah, getting

20 upset with me about when I would tell him no. I don't think

21 I ever referred to the gender discrimination because she was

22 part of that. I mean, she's the one that designs the job

23 specs. You know, I mean, she's complicit to that extent.

24 And that's her job as the HR director, to make the

25 department heads happy. They want this job spec, I'll go

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1 make it for you.

2 Q. What about some of these comments that he made,

3 circle jerk or --

4 A. Yeah. We -- it actually became an ongoing thing

5 with our group of people, because the guys were really good

6 about slamming their arm down and making a lot of noise.

7 And we would all laugh, because none of us girls can do it.

8 We'd be like, it hurts our hands and we would laugh. I

9 mean, it -- it was a joke to us, because it was -- he did it

10 -- he, apparently, did it in another meeting that one of the

11 group was at and witnessed it. So we talked about it and

12 laughed about it, and like, see, he does it all the time,

13 like it's appropriate, but he doesn't understand that it's -

14 - you don't do that. So...

15 Q. So that came up more than once with Heather, that

16 that was something the chief did?

17 A. Right.

18 Q. And was it explicitly discussed that he's using

19 that as a way to suggest let's measure our penises?

20 A. I think we all knew it because, I mean --

21 Q. But did it come up as a --

22 A. No.

23 Q. -- an explicit --

24 A. No.

25 Q. -- point of the conversation with Heather? As the

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1 HR director --

2 A. No, not as the HR director.

3 Q. Okay. Did she give you any advice or make any

4 suggestions on --

5 A. No.

6 Q. -- how to handle the chief? No?

7 A. No.

8 Q. Did she share any other concerns that had been

9 raised by anyone else about the chief?

10 A. No. Like I said, I -- I specifically didn't hang

11 out with this group of people while I worked at the

12 department, so we didn't start doing this until I left. So I

13 want to be clear on that.

14 Q. Okay.

15 A. So there wasn't -- and that's -- like I said, I

16 didn't make any complaint afterwards or while it was going

17 on. After I left, a lot of these conversations came up.

18 Yeah. There -- we always tried not to talk about work for

19 that reason. I mean, I think it was just an understanding,

20 like, we don't want to compromise each other. I get that

21 you're in that role. So I, maybe, would be aware that she

22 met with, like, Joe, but, I mean, it would be of a, oh, I

23 had coffee with Joe this week. We didn't talk specifically

24 about what went on. So I would have to say no, I didn't --

25 wasn't aware.

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1 Q. Did -- did Heather ever say to you, in this

2 setting where you're outside of work, that she was aware

3 that anyone had made sexual harassment complaints against

4 Chief Straub?

5 A. That's a no.

6 Q. How about any kind of gender discrimination

7 complaints?

8 A. No.

9 Q. Retaliation complaints?

10 A. Yes.

11 Q. What did she say?

12 A. Well, in the letter that I referred to the

13 complaints, there was a comment in there that I had a

14 colleague whose husband worked at the department who

15 referred to, if you tell the chief no, you get Carlied. That

16 colleague was Heather Lowe, and it was her husband.

17 And she has since explained to me, when we did the

18 interview following up on that, that she had talked to her

19 husband about it, and said that he didn't use the term

20 Carlied; that he had said that if you say no to the chief,

21 they make you disappear. So that was the comment going

22 around. And so when she had relayed that comment to me

23 while we were out at one of these functions, she had turned

24 it into Carlied, or, you know, I guess maybe that's I heard.

25 Either way, it was clear that, you know, it was an

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1 ongoing joke that she knew from her husband out at the

2 academy that people were talking, that if you say no to the

3 chief, you get disappeared. So, to me, that's retaliation,

4 and therefore, she would have had that information being

5 reported to her by her husband from others that worked at

6 the department.

7 Q. Do you know when her husband was hired?

8 A. It was after I left the department. So --

9 Q. What's his name?

10 A. Jeff.

11 Q. Jeff Lowe?

12 A. Yep.

13 Q. Is a police officer now?

14 A. No.

15 Q. What was he hired as?

16 A. As a police officer. He was injured during his

17 training after he finished the academy, the basic academy,

18 and so he was stationed, like, on light duty out at the

19 academy for quite a while, and then he started his

20 probationary status and didn't pass that. So early 2014, I

21 believe, was when he was hired, and sometime in early 2015.

22 I want to say he just was on the department for about a

23 year, but I don't have the exact date.

24 Q. So I want to make sure I'm clear about this

25 conversation with Heather on being Carlied. When did you

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1 first have the conversation with Heather where she said she

2 learned that if you push back, you get Carlied?

3 A. It would have been sometime in 2014. Our --

4 Heather was -- sometime in 2015, she's adjunct at Eastern

5 Washington, so she was teaching class, and so we hadn't seen

6 her as much in the group in the year 2015. So it would have

7 been in 2014 at some point, I guess. And we would get

8 together twice a month. It had to be further enough along

9 into 2014 that we felt like we could joke about it. As my -

10 -

11 Q. How did it come up?

12 A. I think we were bashing on the chief. The --

13 another part of this group is the city's labor attorney.

14 Q. Who is that?

15 A. Aaron Jacobson. And again, while we didn't ever

16 talk specifics, we would, you know, oh, yeah, we had a

17 meeting at the chief's this week. And he'd be like, "Oh,

18 God, I'm sorry." And so it was always very generic in terms

19 of, you know, what the event was. But that was the point of

20 getting together, was to vent and let things out. So I think

21 that was probably how it came up is, at some point, there

22 was some -- I don't know. I could have broughten it up.

23 One of them could have broughten it up. But it was

24 definitely a somehow the chief came up in conversation, and

25 -- and that's when -- and, again, I mean, Heather was able

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1 to laugh about it, and, you know, that it was, you know,

2 they just know that if you say no, get you Carlied. And,

3 you know, like I remember rolling my eyes.

4 And so it had to be late enough in 2014 that I was

5 largely over it, and was like, I'm -- I'm glad to be away

6 from there, because at that point in time, enough of my

7 friends at PD had shared that this behavior is still going

8 on, that he's still getting angry and berating people and

9 lecturing them.

10 I'm like, I'm so glad I don't have to do anymore.

11 I -- I have a very good boss now, that I feel supported and

12 good things are going on and I don't have to deal with this

13 BS anymore. So...

14 Q. So on this -- this particular occasion, you

15 mentioned that you guys would try and meet twice a month.

16 A. Yeah.

17 Q. And the group was -- was you, Heather, Aaron. Were

18 there others?

19 A. Yeah, a few people from the fire department.

20 Q. All women?

21 A. One woman. And I guess it was a hit and miss

22 group, so three or four gentlemen from Fire.

23 Q. Okay. Anyone else that was a regular that you

24 would consider?

25 A. No. Occasionally, I mean, very occasionally, a

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1 couple of the other females from HR --

2 Q. And who are they?

3 A. -- would join us. Chris Cavanaugh attended a

4 couple times. And then -- because we've pretty much

5 disbanded.

6 Q. When did you disband?

7 A. We don't get together anymore. We haven't met,

8 honestly, since probably September.

9 Q. 2015?

10 A. Yeah.

11 Q. Who was -- do you remember the name of the other

12 HR?

13 A. Yeah. Meghann Steinolfson, which I can't spell.

14 She's newer. She's only been, say, for about a year, but --

15 so she had attended a couple over the summer. So...

16 Q. Did Chris or Meghann express any concerns about

17 the chief or --

18 A. No.

19 Q. -- typical interactions?

20 A. Yeah, because -- I mean, it's not like we would

21 talk about him every time.

22 Q. Okay.

23 A. So they -- it definitely wouldn't have come up.

24 Q. But when Heather brought up the fact that she

25 learned from her husband --

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1 A. Right. And Jeff had joined us a couple times. I

2 mean, Jeff had -- I think probably the time that he was an

3 officer, because of the hours and being at training, he

4 didn't join us, but prior to him being hired, he had

5 attended a couple of them. So --

6 Q. So did he ever --

7 A. So Jeff knew us, and so he met me, and I think

8 that's why he relayed the comment to her in that sort of way

9 of --

10 Q. Did he relay it in your presence?

11 A. No.

12 Q. So he told Heather. Heather told you.

13 A. Yes.

14 Q. That's a yes. And Heather -- can you describe

15 best recollection of how she described what Jeff told her?

16 A. My recollection was that -- exactly. That however

17 the context it came up, that Jeff was having lunch with Dave

18 Overhoff, who is a sergeant out there, who is -- I would

19 consider a friend of mine. I used to do ride- alongs with

20 Dave. That Dave had told Jeff that, you know, you -- he

21 basically had warned him. You don't want to tell the chief

22 no or he will Carly you was how Jeff -- or how Heather

23 explained it to me.

24 And like I said, I remember being kind of like,

25 right. And again, it's the ongoing joke that everybody

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1 knows that you don't say no to the chief. I mean, it brings

2 back that whole no one will say anything because they're

3 afraid for their jobs. And so that's --

4 Q. Okay.

5 A. -- how it would --

6 Q. Other than Heather, has anyone else told you that

7 they're aware if you say no to the chief, that he will Carly

8 you?

9 A. No.

10 Q. That's just through Heather?

11 A. Just through Heather.

12 Q. And then she said that to you in one of these

13 outings --

14 A. Right.

15 Q. -- and then she, apparently, corrected herself?

16 A. She did. After she received my complaint and read

17 through it, and I didn't name her specifically in the

18 complaint. I'm --

19 Q. Okay.

20 A. -- trying hard not to throw anyone under the bus

21 for anything, and I didn't want to specifically call her out

22 on it. But, again, it was known. So when we did the

23 initial interview to go over the complaint, she, you know,

24 said, "This is clearly me you're referring to." And I said

25 yes. And she said, "Okay. It's like I -- I want you to

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1 know that because I had the ability to interview the person,

2 because it's my husband, I asked him what his recollection

3 of it was," because she says, "I don't remember telling you

4 this."

5 And I said, "But I asked Jeff, and Jeff said that

6 yes, that there was -- it was well known that if you say no

7 to the chief, he will make you disappear." So it wasn't

8 that you were Carlied; that you will disappear is how

9 Heather expressed, and then apologized for saying if she had

10 said Carlied, she apologized for it, and I accepted her

11 apology.

12 Q. Okay. Let me go to this -- the -- how this rolled

13 out. You -- it's dated the 21st, but in -- it being the

14 letter to HR. But I have some notes where Heather says she

15 didn't see it until the 29th. How was it delivered to HR?

16 A. I mailed it to them. And dated the letter, signed

17 it. I was on vacation that week. It was a significant snow

18 event, and my staff was answering the snow lines. There was

19 a lot of stuff going on. I didn't -- I didn't get it to the

20 mail in a timely manner. So I --

21 Q. So it wasn't mailed on the 21st?

22 A. It was not mailed on the 21st. I am positive I

23 mailed it on either the 23rd or the 24th.

24 Q. Okay.

25 A. I am positive I mailed it before Christmas, before

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1 I remember thinking it won't get there until after

2 Christmas, so... and I believe Heather was also on vacation.

3 Q. Okay. And then how were you first contacted about

4 this letter?

5 A. Heather called me. I believe it was New Year's

6 Eve, the day before New Year's. I could check my e-mail

7 because I e-mailed Mike.

8 Q. Were you at work?

9 A. I was at work. She called me to say that she was

10 in receipt of my complaint, and that she'd be scheduling a

11 meeting to go over it, and that it would be with a fairly

12 innocuous title on our calendars to not raise flags. But

13 that's what the intent of the meeting was. I didn't get the

14 meeting invite for several more days.

15 Q. Were you okay with meeting with --

16 A. Uh-huh.

17 Q. -- Heather on the letter? And was it just the two

18 of you?

19 A. No. The M&P Union President, David Lewis, was

20 also there.

21 Q. On your behalf?

22 A. Yes, on my behalf. Heather invited him.

23 Q. Okay. And how did that meeting go?

24 A. Well, we went over, kind of -- we were going to go

25 over the contents of the letter, and then we kind of

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1 backtracked, and instead, Heather asked me, kind of, what

2 resolution did I want; that she really couldn't conduct an

3 investigation, as Straub was no longer an employee, and

4 therefore, what do I really, you know, expect to happen, and

5 then, kind of, went over what those options are. And then

6 brought up, you know, at this point, it was an independent

7 investigator.

8 I believe you had been hired at that point, and

9 so, you know, she wanted to know does it make -- a lot of

10 these things seem to fall underneath that, would that make

11 sense to you. And I agreed. And then she really wanted to

12 know more about my concerns of retaliation. And at that

13 point, I still am very concerned about retaliation. I

14 believe that speaking out and telling the truth, you

15 disappear. It's --

16 Q. Retaliation by whom?

17 A. At this point, I am fearful of retaliation from

18 city administration.

19 Q. Anyone in particular?

20 A. The city administrator, Theresa Sanders, who, I'm

21 assured, thinks highly of me. But, you know, Brad Arleth

22 has been put out on the admin leave while they investigate a

23 case of administration -- or insubordination, which believe

24 it looks like it's come from Theresa.

25 And I believe it's retaliation for him speaking

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1 out about the move to the downtown precinct, because he and

2 I had been in communication that he had been vocal in a

3 public meeting that he didn't think it was a good idea. And

4 he is the only legitimate internal candidate for chief, and

5 I think they purposely did this to eliminate him from

6 contention, and I'm fearful they're going to do the same

7 thing to me.

8 Q. Okay. So was there any decision between you and

9 Heather about how this would move forward?

10 A. What we decided --

11 Q. And "this" being the September 21st letter.

12 A. Right. What we decided -- so she gave me some

13 options -- was, you know, to speak with you and see if these

14 coincided. And then she also suggested that to protect

15 myself, she brought me the whistleblower paperwork; that

16 there are only certain, you know, parameters that you can

17 file a whistleblower complaint on, but since, you know, I

18 believed that part of the reason I was removed was because I

19 was telling Frank no on spending, that -- that I believed

20 that there was problematic spending going on, and that was

21 something that would fall underneath whistleblower, and that

22 if I wanted to file a whistleblower complaint, that would

23 protect me from retaliation.

24 She -- just like I said, I believe it was a

25 Thursday, and said why don't you take the weekend to think

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1 about it and get back to me. But overall, you know, I felt

2 it was a good meeting, and I -- I appreciated the suggestion

3 that you take over the investigation, because quite frankly,

4 I don't trust that HR would do a very good job of it.

5 Q. And why do you say that?

6 A. Because, like I said -- and Heather is aware of

7 Straub's behavior. I have never made an official complaint,

8 and it puts her in a weird position because we're friendly,

9 and I don't necessarily expect her to do it on my behalf,

10 but seeing what he's done to other employees, especially

11 with everything that's come out since.

12 Q. Uh-huh.

13 A. With the notes on how Monique Cotton's situation

14 was handled, you know. And not so much as even Monique.

15 Mark Griffiths was also treated horribly in that meeting,

16 and he was a victim of a hostile work environment. And no

17 one should be treated that way. And to have nothing really

18 happen. And I know, you know, Heather recused herself at

19 the time because her husband was employed. But it still,

20 like --

21 Q. Were you aware that she had recused herself at the

22 time or did you learn that --

23 A. I learned that after.

24 Q. Okay.

25 A. Right.

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1 Q. Did -- did she mention at any time, when you guys

2 were in these social settings, that she had recused herself

3 from HR responsibilities --

4 A. No.

5 Q. -- over the police department?

6 A. It never came up.

7 MS. CAPPEL: I see you looking at your watch. Do

8 you need to close out? I have just few more things.

9 MR. CHURCH: I'm -- I'm late for a meeting, but

10 it's not something that --

11 MS. CORTRIGHT: It's 12:15.

12 MS. CAPPEL: I think I got about 15 more minutes.

13 Can you hang with us?

14 MR. CHURCH: Yeah. Absolutely.

15 MS. CAPPEL: Okay.

16 MR. CHURCH: Yeah.

17 BY MS. CAPPEL:

18 Q. Are you aware of any employees who have gone to

19 Heather to complain as a formal matter about their treatment

20 by Straub?

21 A. In my opinion, Joe Walker was making formal

22 complaints, that by requesting meetings with HR to discuss

23 his behavior. I mean, I don't know what's formal. Do you

24 have to write it down? I mean, what's -- when you're

25 requesting meetings with HR to discuss your concerns --

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1 Q. What about besides Joe; anyone else?

2 A. Not that I'm aware of. I know Dan Torok, who is a

3 captain at the department, was meeting with Nancy Iserliss

4 on a regular basis. I had seen them at the Starbucks

5 together.

6 Q. Do you know how long that's been going on?

7 A. I don't. And again, that's all secondhand,

8 thirdhand information, so I have not spoken to Dan directly

9 about it. But my understanding was Dan was meeting with

10 Nancy to discuss the issues that they were having with

11 Straub.

12 Q. Straub? Okay. So let me turn to Monique.

13 A. Okay.

14 Q. Did you ever observe any inappropriate behavior on

15 Straub's part towards Monique?

16 A. No.

17 Q. Anything at all that you think --

18 A. I did not.

19 Q. -- crossed --

20 A. No.

21 Q. -- professional boundaries?

22 A. Not at all.

23 Q. Did she ever confide in you that was having

24 difficulties with Straub?

25 A. No. We have since discussed it, but at the time

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1 that I worked there, she -- I never saw anything

2 inappropriate. I always believed that she just really

3 idolized him; that she thought he was -- because he was. He

4 was a very smart man and had some really great ideas, and he

5 definitely favored her. They were the two new kids. I

6 mean, the rest of us -- and I -- I can understand that.

7 We've all been there a while.

8 We're all friends. They're the two new ones. So

9 they kind of had a bond together. To me, it never appeared

10 to be anything more than a professional mentor-mentee-type

11 relationship. When I left, they still appeared to be very

12 friendly. But I never saw anything inappropriate.

13 Q. Do you know whether they socialized outside or

14 work?

15 A. I do not know, and I don't think they did, but I

16 don't know.

17 Q. Okay. Did you ever receive text messages from

18 Straub that you thought were inappropriate?

19 A. No. I barely received any. I probably received

20 three text messages ever from Straub.

21 Q. Okay. Was he the kind of supervisor to tell his

22 command staff that he loved them?

23 A. No.

24 Q. Have you -- had you ever heard him --

25 A. No.

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Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 105

1 Q. -- even in jest where he's saying --

2 A. No.

3 Q. -- I love you. You guys are great partners.

4 A. No. He -- he was not effusive with praise at all.

5 We would occasionally get a good job, team, and that was

6 usually in an e-mail format,

7 Q. Was he physically demonstrative with staff,

8 anything like that where he puts his arms around people's

9 shoulders?

10 A. Nope.

11 Q. Did -- was he different with Monique?

12 A. No. I guess I -- there were always rumors that

13 the two of them had an extracurricular relationship. I

14 never believed it because when you read body language, you

15 can usually tell when two people have an intimacy. I never

16 saw that. So if they did have something going on, they

17 masked it very well, in my opinion. Like I said, she was

18 always very effusive of her praise of Straub. I mean, it

19 was clear she thought that he walked on water.

20 Q. Okay.

21 A. And he was always very pro -- Monique's doing good

22 things, I like Monique, but it was never anything more than

23 that.

24 Q. Okay. You mentioned that you've had conversations

25 with Monique -- I guess, since this all became --

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Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 106

1 A. Yeah.

2 Q. -- public. Has she given you any detail about any

3 of the acts that she thought were harassment?

4 A. What Monique has shared with me is that for a long

5 time, the chief was very abusive towards her; that he would

6 yell at her behind closed doors. She said it got to a point

7 where she refused to have closed-door meetings with him,

8 that she was actually afraid that he was going to hurt her;

9 that it got to a point where she hated him, and everyone

10 thought that they were a thing, when she's like a -- you

11 know, I'm sure she must have been feigning professionalism,

12 and she's like, "They didn't know how much I hated him."

13 She said that she observed behaviors that made her think

14 that he had something inappropriate with Tracy Meidl.

15 Q. Craig's wife?

16 A. Yes, who is a lieutenant in the department.

17 Q. Did she give any detail, or is this just her

18 speculating?

19 A. Just her speculating.

20 Q. Did she -- but she denied that she had had an

21 affair with --

22 A. That she -- right.

23 Q. That she --

24 A. I never asked her directly. What I told her was,

25 Monique, for what it's worth, I never believed that you guys

Page 107: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 107

1 were an item, and I told her, in fact, I said, I always

2 thought that you were hooking up with Mark Griffiths, which

3 later turned out they were. I mean, they were the ones that

4 were all flirty and cutie-cute together. So --

5 Q. Okay.

6 A. So I shared that with her, and she laughed and

7 said, you know, okay, thank you. But so didn't say anything

8 other than that, and I didn't ask her directly. So she

9 didn't offer it.

10 Q. Are you aware of the allegations she has asserted

11 against Straub which include --

12 A. Right.

13 Q. -- efforts -- or attempts to kiss her and slap her

14 on the --

15 A. We've never talked about it, but I've read it.

16 Q. So she's never discussed --

17 A. No.

18 Q. -- any details about those accusations?

19 A. No.

20 Q. I'm just going to check your letter to see if

21 there's anything else I want to --

22 A. Okay.

23 Q. -- address. And as I'm doing that, if I have

24 follow-up questions, may I contact you again?

25 A. Yes.

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Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 108

1 Q. And the way I would do it is probably by telephone

2 and just conference you in to follow up rather than schedule

3 a separate -- unless I'm in town.

4 Would that be okay with you?

5 MR. CHURCH: That would work just fine.

6 MS. CAPPEL: Okay.

7 BY MS. CAPPEL:

8 Q. I do know -- I have a question of whether -- did

9 HR ever get involved in establishing this new position for

10 you once the --

11 A. Yeah.

12 Q. -- 311 project ended?

13 A. Yeah.

14 Q. What was their role?

15 A. They developed a new job spec, and came up the job

16 duties and descriptions, shared it with both me and

17 Jonathan, and it had left my salary range exactly the same,

18 which I talked to Jonathan about, because his other two

19 direct reports were actually classified two ranges higher,

20 and I kind of called foul on that.

21 Q. Uh-huh.

22 A. I mean, at this point, I'm tired of being jerked

23 around by the city and I'm kind of like I just -- I want a

24 fair look at it, but if your other two direct reports are

25 making this much, it seems like your third one should, too.

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Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 109

1 So --

2 Q. Did they make that accommodation?

3 A. Yep.

4 Q. Were you satisfied with that?

5 A. Yeah.

6 Q. Did, as far as you know, your transfer into that

7 position require approval beyond HR?

8 A. What we ended up doing, they created the new

9 position with exempt positions. If you are a department

10 head, it requires council approval. If you are put into a,

11 sort of, like an assistant or -- so it's not a department

12 head. So, technically, I'm Jonathan's assistant. So it

13 didn't require council approval.

14 Q. Okay.

15 A. It does require -- I had to have another job offer

16 letter from the mayor, so the mayor has to approve the

17 appointment.

18 Q. Okay.

19 A. But, yeah, basically, HR develops the spec and the

20 mayor signs off on it.

21 Q. So in terms of the resolution that you are

22 seeking, what I take from this is, you do want a full

23 investigation of the claims you're making in this letter and

24 the information you have provided me today. Is that right?

25 A. Yes.

Page 110: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 110

1 Q. Okay. All right. Do you have any questions of me

2 before we part ways, knowing that I've kept you late?

3 MR. CHURCH: How long do you expect your

4 investigation to run?

5 MS. CAPPEL: It's impossible for me to tell right

6 now. When we started down this road, we gave an estimate to

7 the joint committee based on very little information. And so

8 we've said we'd try and finish it up by mid April. If I'm

9 able to meet that deadline, I'll be very happy, but it could

10 go longer.

11 And I will tell you also that the parameters of

12 what you, Carly, have raised was not originally within the

13 scope of the work that was approved by the joint committee.

14 MS. CORTRIGHT: Right.

15 MS. CAPPEL: So I'm meeting with those folks on

16 Friday to get some direction on whether they want to include

17 it. I mean, certainly, there was a part of your experience

18 it was within the scope, and I don't know if you've actually

19 seen the scope document.

20 It's a public record. But it's basically the

21 facts and circumstances surrounding your transfer out of PD

22 into your current position. But at the time, there was no

23 indication that you believed you were the victim of gender

24 discrimination or retaliation. So that's new to the mix.

25 And that's the conversation I'll have with the joint

Page 111: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 111

1 committee.

2 MS. CORTRIGHT: I think the -- for me, the

3 retaliation largely comes from -- I believe I was retaliated

4 by Straub for saying no, and I think that's pretty clear

5 from his lawsuit that he filed yesterday. If you read it,

6 he says that they only approved the transfer of one

7 disruptive employee.

8 MS. CAPPEL: And you think that refers to you?

9 MS. CORTRIGHT: Yes. I'm fairly positive. So I'm

10 disruptive, apparently, for saying no. And I, to me,

11 believe that Theresa Sanders had to know that.

12 MS. CAPPEL: Know -- know what?

13 MS. CORTRIGHT: Know that he wanted me gone, and

14 that's why she offered me the job.

15 MS. CAPPEL: Had he ever accused you being of

16 disruptive before you saw the lawsuit?

17 MS. CORTRIGHT: No.

18 MS. CAPPEL: Okay. All right. I haven't quite

19 made it all the way through that lawsuit, but I'm getting

20 there. Okay. Thank you very much. We're done.

21 (WHEREUPON, the interview of Carly Cortright was

22 concluded at 12:26 p.m.)

23

24

25

Page 112: Carly Cortright, 2-4-2016

CERTIFICATE

Marilyn Broyles

I, Marilyn Broyles, do hereby certify that I

reported all proceedings adduced in the foregoing matter

and that the foregoing transcript pages constitutes a

full, true and accurate record of said proceedings to the

best of my ability.

I further certify that I am neither related

to counsel or any party to the proceedings nor have any

interest in the outcome of the proceedings.

IN WITNESS HEREOF, I have hereunto set my

hand this 16th day of February, 2016.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

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Page 113: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 113

1 CORRECTION SHEET

2 Transcript of: Carly Cortright Date: 02/04/16

3 Regarding: Frank Straub Resignation Interview

4 Transcriber: Broyles

5 ____________________________________________________

6 Please make all corrections, changes or clarifications

7 to your testimony on this sheet, showing page and line

8 number. If there are no changes, write "none" across

9 the page. Sign this sheet on the line provided.

10 Page Line Reason for Change

11 _____ _____ ________________________________________

12 _____ _____ ________________________________________

13 _____ _____ ________________________________________

14 _____ _____ ________________________________________

15 _____ _____ ________________________________________

16 _____ _____ ________________________________________

17 _____ _____ ________________________________________

18 _____ _____ ________________________________________

19 _____ _____ ________________________________________

20 _____ _____ ________________________________________

21 _____ _____ ________________________________________

22 Print Name ___________________________

23

24 Signature ___________________________

25

Page 114: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 114

1 DECLARATION

2 Transcript of: Carly Cortright Date: 02/04/16

3 Regarding: Frank Straub Resignation Interview

4 Transcriber: Broyles

5 ____________________________________________________

6

7 I declare under penalty of perjury the following to

8 be true:

9

10 I have read my deposition and the same is true and

11 accurate save and except for any corrections as made

12 by me on the Correction Page herein.

13

14 Signed at ____________________________, ____________

15 on the ______________ day of ________________, 2016.

16

17

18

19

20

21

22 Print Name ___________________________

23

24 Signature ___________________________

25

Page 115: Carly Cortright, 2-4-2016

Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 115

$

$18,000 51:15

52:14 52:1852:21

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14:814:13 14:2216:21

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77:23 78:1986:17 91:2192:4 92:694:9

2016 3:5

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24th 97:23

29th 97:15

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3

3:00 42:22

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5:6

accommodation

109:2

account 68:23

accountable

80:2

accountant

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6:1845:15 45:1680:22 83:2183:2384:1 85:15

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across 37:3

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acting 8:19

actions 80:2

acts 106:3

actual

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99:22

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n 79:24

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advisor 41:19

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afterwards

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79:20 86:1390:3 107:11

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agreement

76:1

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19:425:23 58:8

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alarmed 81:6

Alki 69:18

allegations

107:10

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15:1

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7:13 28:11

alongs 95:19

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34:2239:1 93:8

Anne 17:19

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15:4

answer 9:21

36:4

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97:18

answers

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26:2 26:5

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64:19 78:21

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attended 94:3

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attorney 3:19

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61:4 65:24

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awkward 17:13

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background

5:12 75:19

backlog

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60:14 82:1382:21 110:7

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basic 91:17

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80:16 83:1593:7101:7102:23103:14

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belong 76:5

belonged

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benefit 50:11

benefits

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berating 93:8

besides 15:20

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betrayed 75:9

better 15:2

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blew 55:7

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blocked 18:19

blood 76:25

board 7:24

10:711:1350:5 54:267:21

body 17:13

105:14

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43:15

bomb 28:13

bond 104:9

books 7:21

33:2

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Boston

44:11 50:2

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37:24

bothers 77:2

bottom

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briefed 17:16

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brings 96:1

broader

21:2 62:1

broke 57:10

brought

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broughten

92:22 92:23

BS 93:13

budget 8:1

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building

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bus 80:1

96:20

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busy 21:23

butt 47:23

buying 49:1

C

cabinet

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calendar

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calendars

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calmly 57:21

campus 37:3

canceled 40:5

candidate

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Cappel 3:9

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captains

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car 30:5

30:20 30:21

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47:20 47:2247:2548:148:17 48:19

card 72:16

care 43:1

45:4 46:146:9 68:13

career 77:1

77:16

Carl 81:23

Carlied 90:15

90:20 90:2491:2592:2 93:297:8 97:10

Carly 4:19

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26:6 68:4

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categorize

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caught

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cautious

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Cavanaugh

94:3

Cavin 84:6

84:7

cc'd 66:25

cell 46:10

74:25

center 33:20

centralized

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certain 19:14

19:2133:785:25100:16

certainly

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chain 3:17

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change 7:8

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17:2423:5 33:933:1272:3 86:10

charge 6:5

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city's 3:22

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cleaning

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closest 69:23

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coast 36:12

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coast-west

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cocksucker

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coffee

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cohesive 22:3

coincided

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coincidences

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collaboration

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colleague

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collect 4:1

co-locate

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colorful

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comes 37:14

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comfortable

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coming 19:3

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command 38:11

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commander

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commissioned

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community

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company 39:24

compensation

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competition

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complain

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complaint

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complaints

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completely

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complicit

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comprised

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compromise

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CompStat

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computer

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computers

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concealed

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concerned

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concerns

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constant

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constantly

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contemplated

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contention

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context 26:25

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continually

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continued

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contracting

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contracts

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contradicted

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contrary 68:1

contributions

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conversation

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conversations

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Cooley 6:19

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course 9:5

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cover 85:6

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creating 19:5

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crime 5:16

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CrimeCheck

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crimes 23:18

criminal

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critical

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crossed

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crossing 30:6

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crux 78:10

crying 55:3

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culture 28:25

cunt 78:19

cunt-ish 78:2

cup 81:17

current 5:8

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currently

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customer 5:13

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cutting 53:2

D

daily 21:25

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Dan 103:2

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date 14:21

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dated 66:22

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dates 16:21

Dave 95:17

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David 98:19

day 26:4 44:2

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days 68:21

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day-to-day

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deadline

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deal 93:12

deals 36:14

December

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decide 24:6

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decided 7:8

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decision

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defender's

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definitely

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deliver 15:2

delivered

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demeanor 26:9

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demonstrate

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demonstrative

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demote 38:13

demoted 14:16

demotion

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department

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departments

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department's

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deputy

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describe

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described

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describing

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description

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descriptions

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design 60:8

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designed

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designing

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designs 87:22

destroy 20:11

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detail 81:8

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details

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detective

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deteriorate

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develop 10:14

developed

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developing

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develops

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difference

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differences

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different

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difficult

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directly 5:22

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dishonest

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dispatch

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display 27:16

disregarded

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disrespect

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disruptive

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distinctly

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division

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divisions

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document 31:1

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documentation

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documents

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done 20:14

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doors 16:19

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dramatic

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drawings

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drinking

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drive 24:25

drives 56:11

driving 48:1

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drove 30:6

drug 40:13

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drugs 41:1

due 20:8

during 7:17

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earliest

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effusive

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either 4:8

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e-mails 42:24

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embark 9:19

embarking

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emergency

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employee

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employees

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enemy 35:22

enforcement

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engaged 87:3

enter 19:20

entry 51:5

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environment

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equipment

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Erica 75:4

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especially

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essentially

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establishing

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estimate

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estimated

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Eve 98:6

event 92:19

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eventually

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everybody

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everyone 4:10

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everything

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evidence

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evident 38:17

exact 14:21

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exactly 95:16

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examining

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except

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exceptionally

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exchange

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excuse

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exec 44:2

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exempt 7:10

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exempts 43:6

exercise

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expect 64:7

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expectation

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experience

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explain 18:15

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explained

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explicit

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explicitly

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exposed 58:2

express 94:16

expressed

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expression

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expressions

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extent

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extra 40:8

extracurricul

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eyes 93:3

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Facebook

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facility

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fact 3:18

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facts 110:21

fair 4:5

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fairly

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fall 99:10

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familiar 36:8

family 44:16

fast 24:1

33:15

faster 25:23

fault 34:2

49:2 74:11

favored 104:5

favorite

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fearful 99:17

100:6

feasible 65:4

February

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federal 46:21

feedback

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feel 18:12

18:1420:125:13 30:2441:4 60:661:365:2266:466:12 78:2079:2280:7 93:11

feeling 42:18

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feelings

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feigning

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felt 7:12

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female

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females 94:1

figure 9:20

46:10

figuring

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file 19:18

71:24100:17100:22

filed 4:7

111:5

fill 46:15

62:17 63:6

filling 20:7

fills 43:20

final 3:3

74:19

finalized

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finally

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finder 3:19

fine 25:11

28:1332:334:12 108:5

finish 110:8

finished

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fire 7:12

38:12 38:1755:8 59:980:18 93:19

93:22

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first 21:22

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fissure 25:16

fit 50:7 60:9

Five 57:2

five-minute

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fix 45:6

flags 98:12

flat 49:9

flattering

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fleet 6:11

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flirty 107:4

flop 26:23

27:15

Florida 63:19

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folks 3:17

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follow-up

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foot 26:3

force 27:5

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forced 54:3

forceful

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forcible

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forearm 26:15

27:25

forever 70:17

forfeiture

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forget 38:8

form 63:8

formal 52:9

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formally 5:14

format 105:6

formed 18:9

former 3:12

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forms 63:6

forward

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foul 108:20

fracture

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frame 53:22

framework

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Frank 100:19

frankly

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fraud 46:21

free 60:6

frequency

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Friday 66:3

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friend 31:5

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friendly

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friends 30:13

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front 80:9

fulfilling

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full 41:21

109:22

full-time

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function 6:18

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functions 6:5

51:13 90:23

fund 11:16

12:1 12:212:2 40:840:20 41:1246:15 73:15

funded 11:15

funding 11:24

12:134:1240:7 46:273:13

funds 12:8

funny 37:10

37:13 59:11

furious 75:8

G

game 69:2

games 25:10

gang 40:21

gangs 41:1

Gardner 37:2

Gavin 6:19

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gender

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genders 86:1

general

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generally

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generic 92:18

gentleman

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gentlemen

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getting

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G-i-a-n-n-e-

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Giannetto

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giant 28:21

girls 88:7

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giving 3:20

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glad 93:5

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God 92:18

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gone 10:21

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goodbye 56:15

gotten

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governmental

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grade 7:6 7:7

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grant 6:20

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granted 20:11

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grapevine

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graphically

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great 17:22

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Griffiths

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ground 22:4

group 3:11

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grow 34:2

guess 8:1

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guidelines

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guy 18:7

guys 49:9

88:5

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H

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37:13 37:13

hairs 76:6

half 33:23

hall 8:23

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Hall's 11:19

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hated 27:3

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hates 38:17

haven't

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having 11:1

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head 25:10

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hearing 46:7

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Heather 47:15

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he'd 26:15

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held 3:4 5:10

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10:12 10:1436:4 54:9

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herself 96:15

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Hey 55:9

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higher-paying

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highest-

ranking

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highly 99:21

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holding 12:12

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home 9:4

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honestly 12:7

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hours 16:5

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hugged 77:13

Human 86:16

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hurts 88:8

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I

I'd 33:24

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I'll 4:15 5:6

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53:25

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include 6:6

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included

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including

25:3

increase

20:19

independent

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Indianapolis

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indication

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inform 65:19

information

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initially

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Initiatives

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35:10 86:6

interactions

94:19

Interceptors

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internal

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interpreting

27:23

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Intervention

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intimacy

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39:20

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23:22 99:22

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38:18

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jab 44:6

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January

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Jeff 91:10

91:1195:1 95:295:795:15 95:1795:20 95:2297:5 97:5

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Jonathan 11:9

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Jonathan's

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July 36:25

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June 44:23

44:23

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40:6 41:20

K

key 64:9

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104:5

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labor 92:13

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late 51:7

67:13 81:1693:4102:9 110:2

later 82:12

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laugh 88:7

88:8 93:1

laughed 28:21

37:1044:488:12 107:6

law 4:22 9:15

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leader 17:22

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48:6

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61:1266:8 100:4

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Lewis 98:19

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19:19

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33:22 67:24106:16

lieutenants

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lost 34:21

36:23 36:24

lot 5:21 9:14

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love 105:3

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Lowe 47:15

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magically

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a-n 12:24

man 17:11

17:23 47:1873:16 104:4

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management

10:13

manager

8:2016:18 61:2075:13 75:1782:7 82:20

managing 25:3

mandate 23:11

manner 38:9

97:20

M-a-r 42:2

March 23:4

25:12 25:1329:12 31:12

marginalized

19:13

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48:5 48:6

Mark 101:15

107:2

Mary 41:25

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meant 30:16

Meanwhile

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meetings 22:1

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Monday 16:3

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Mondays 64:21

money 11:17

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Monique's

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monthly 21:5

months 8:3

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morning

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moron 37:22

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19:12 71:2076:4

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N

Nancy 103:3

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40:21 42:1558:6

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N-i-c-k-s

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84:22 85:1

nine 14:8

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nobody's 49:2

noise 88:6

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Nope 61:15

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normal 16:5

16:6

notes 73:3

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nothing 23:11

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notice 32:16

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notion 86:3

November

15:18 77:2278:16 78:1981:16 82:18

Nuh-uh 63:7

numerous

26:13

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obvious 9:3

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obviously

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occasional

29:13

occasionally

93:25 93:25105:5

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5:25 8:229:5 9:1011:2014:815:18 16:2117:4 33:551:1154:763:20 78:1879:18 81:16

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old 35:21

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ones 19:15

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one's 54:1

ongoing

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on-loan 62:22

open 70:18

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opinion

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60:15 86:2

options

99:5 100:13

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outings 96:13

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3:12 58:175:687:1490:2 104:13

overall

21:1 101:1

Overhoff

95:18

overlapped

24:9

overreacted

32:6

overruled

54:2

overseen 3:13

oversight

52:12

P

p.m 42:23

111:22

Packed 68:16

packing 55:2

paid 7:18

7:21 7:24

8:10 8:138:19 9:69:8 11:348:19 50:1851:9

pain 47:23

paper 79:23

paperwork 8:2

100:15

parameters

100:16110:11

participate

34:7 34:11

particular

93:14 99:19

partners

105:3

party 56:16

pass 91:20

passable 19:5

passion 20:2

passionate

17:14 18:2

past 19:2

20:10 35:2068:1

patient 24:15

patrol 17:6

24:12

pattern 18:23

pawn 56:7

pay 8:17

11:1712:820:18 47:19

67:2468:5 70:17

paying 33:1

40:9 78:14

PD 6:19 10:22

11:11 62:2364:1865:4 93:7110:21

peers 78:22

penis 26:16

27:16

penises 88:19

people 7:14

19:20 20:2521:2425:325:1026:233:1258:359:19 63:2268:5 70:770:1377:1 81:383:1585:3 88:589:1191:2 93:893:19105:15

people's

105:8

perfect 49:6

perfectly

28:13

performance

53:11 53:1354:1

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Interview of Carly Cortright FINAL February 4, 2016 NDT Assgn # 21084-1 Page 141

performer

53:16

performing

53:6 62:23

period 9:8

13:20 20:1081:25

permanent 8:3

8:7 8:88:20 11:111:14 11:1812:10 13:1243:3

permanently

7:25

permission

62:5

person 7:24

20:2123:731:21 32:2144:1546:8 50:850:1068:8 97:1

personally

32:9 36:6

personnel 6:9

6:10 63:8

Ph.D 23:7

phone 9:17

46:1075:1 75:275:4 75:5

phonetically

42:7

phrases

29:6 29:15

physically

16:25 62:13105:7

pick 7:14

picked 78:12

piece 10:16

19:23 61:2273:18

pieces 61:9

pistol 19:19

placing 33:11

Plains 39:15

plan 53:13

55:25 63:1764:17

planned 67:13

planner

5:18 5:2113:10 13:2514:24 14:2515:2217:653:25 62:24

planners 53:3

53:15 69:2270:1

planning 6:10

9:18 67:14

play 69:2

played 56:6

players 64:1

please 5:6

31:16 32:1045:21 46:1560:6

plus 51:14

52:23 69:5

point 15:6

15:24 18:1121:19 23:1724:1631:331:1034:340:16 42:2147:1848:648:2052:5 56:561:2 64:965:19 66:1671:671:12 73:1775:876:20 76:2481:2282:188:2592:792:19 92:2193:6 99:699:899:13 99:17106:6 106:9108:22

pointed 38:12

38:13 54:15

police 5:18

5:20 6:76:10 6:227:12 9:69:9 11:1513:10 13:2113:25 14:2414:25 15:2217:6 18:119:14 19:1723:22

28:1 28:628:2429:333:22 33:2341:24 48:2251:1853:353:2556:956:1358:1 59:160:13 62:1564:279:22 80:1183:2 84:184:2 84:486:21 91:1391:16 102:5

policies 3:23

62:22

policing 24:3

poor 53:16

84:8

portion 10:10

position

5:8 6:246:25 8:58:18 8:209:3 11:111:11 11:1411:1612:312:10 12:1112:19 12:2513:23 13:2414:4 14:614:14 14:1518:15 18:2119:519:10 21:2533:8

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45:12 45:2446:14 46:1847:2 47:547:7 48:249:16 49:1849:22 51:1251:14 51:2153:15 53:1754:354:1670:270:1976:282:19 82:2486:12 101:8108:9 109:7109:9110:22

positions

5:10 8:333:1 33:333:933:12 33:1333:18 33:2433:25 36:1043:354:1768:2 68:3109:9

positive

21:2451:766:16 71:2474:997:22 97:25111:9

possible

36:21 66:3

possibly

44:18

Post 30:7

potentially

10:16 30:24

potty 28:7

practices

3:22 62:22

praise

105:4105:18

precinct

100:1

presence

33:19 95:10

present

4:2143:11 46:2

presentation

26:1

presented

11:22

president

72:1 72:198:19

pretend 50:11

pretty 6:5

6:1210:2115:7 15:818:19 21:2338:17 38:1939:13 40:1540:1945:3 51:455:1661:964:2566:667:2574:9 74:16

76:985:1786:2 94:4111:4

prevention

34:4 39:18

previous

20:10 31:1371:22

previously

51:13 70:18

primary 83:21

84:24

prior 17:18

36:9 95:4

private 3:14

privy 54:22

pro 105:21

probably

17:1521:529:2330:230:24 55:2563:2466:7 71:771:771:12 84:2385:292:2194:8 95:2104:19108:1

probationary

91:20

problem 21:12

problematic

100:20

problems 15:7

45:7

procedurally

49:25

process 4:3

5:3 21:241:2143:449:18 49:2152:4 52:6

product 4:7

professional

28:9 29:277:11103:21104:10

professionali

sm 26:10

106:11

program 39:12

39:14 40:2573:14

progress 22:5

26:25

progression

5:9

project

8:25 9:79:11 9:2310:13 10:2411:651:18 55:1155:19 57:1257:23 57:2458:15 59:2461:561:12 61:1764:2566:8 108:12

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projects 6:21

15:4 22:258:1263:263:19 63:23

promised

14:13 18:23

promote 68:7

promoted

16:17 52:2264:13

promoting

16:23

promotion

18:570:10 80:2383:24

property

6:8 19:2269:13 70:1370:15

proposal

39:24

proposed

58:24

protect

100:14100:23

protected

13:17

proud 20:5

prove 68:14

provide

58:772:14 72:1581:20 83:4

provided

109:24

providing

72:22 83:11

PS 4:23

public 4:5

4:8 4:1116:1520:7 30:437:4100:3 106:2110:20

pull 20:8

61:23

purchase

48:23

purchases

48:22

purchasing

41:6

purpose 85:11

purposely

25:925:10 41:17100:5

push 27:5

92:2

pushed 86:5

pushing 85:19

puts 101:8

105:8

putting 33:13

41:1849:3 70:7

Q

question 9:21

43:19 86:17

108:8

questioning

78:1

questions 4:2

5:5 43:15107:24110:1

quick 39:7

49:7

quickly 9:3

23:5

quite 12:6

17:10 17:1117:2526:1 33:242:21 44:1850:4 53:786:13 91:19101:3111:18

R

radio 49:4

raise 51:15

98:12

raised 39:1

89:9 110:12

range 8:17

46:1747:6 47:750:20 50:2151:351:10 52:1452:16 52:1752:1868:8 108:17

ranges 108:19

rank 82:2

82:4

rape 23:18

rather 7:14

53:11 82:22108:2

reaction

66:14

reading 45:22

ready 18:6

45:6 61:10

real 19:14

19:16 19:2138:14 53:25

realize

23:7 46:8

realized

37:12

really

17:2218:9 22:522:5 24:525:425:13 30:1731:2 32:836:23 37:1039:1740:2 40:740:24 41:1641:1645:155:11 59:2560:14 64:1970:370:14 75:1876:1778:585:1586:786:1188:5 99:299:4

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99:11101:17104:2 104:4

realm 48:13

reason 7:7

31:345:24 48:2048:2153:561:2171:176:11 77:2584:11 89:19100:18

reasoning

10:4

reasons 79:20

reassignment

8:24

recall

32:11 32:1847:11 59:12

receipt 98:10

receive

104:17

received

96:16104:19104:19

recent 75:11

recess 57:5

reclassified

18:24

recollection

23:266:14 95:1595:16 97:2

recommendatio

ns 3:22

3:25

record 3:8

57:4 57:7110:20

records 4:9

6:6 6:1019:16 19:1720:6 20:720:820:11 75:1375:16 75:1876:576:1382:6 82:20

recused

101:18101:21102:2

red 36:5 38:8

68:4

red-faced

39:1

reeked 50:25

refer 13:16

reference

26:16 27:1028:1931:635:24 36:17

references

26:14

referred

10:2514:128:17 80:2182:787:21 90:1290:15

referring

71:9 96:24

refers 111:8

refused 106:7

regarding

55:19 75:15

regret 80:3

regular 93:23

103:4

regularly

15:20

regulated

48:7

regulation

40:12

rejuvenated

45:6

related 31:1

relationship

39:5 104:11105:13

relay 41:10

95:10

relayed 90:22

95:8

released 12:8

relevant

42:17 72:19

relief 59:16

re-look 10:9

reluctantly

70:10

remember

14:21 17:2519:322:25 29:20

30:1 30:930:12 30:2231:439:1740:240:1743:744:1555:258:16 58:2166:10 66:1368:20 68:2181:2293:394:11 95:2497:3 98:1

remind 13:23

remove 84:14

removed 83:23

100:18

removing 84:7

reorg 19:11

54:654:21 67:1580:24

reorganizatio

n 20:1

reorganize

6:3 18:16

reorganized

33:1 33:651:12 51:19

reorging

55:21

reorgs 12:4

67:14

repercussions

19:24

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reply 74:19

report 7:14

14:2 21:924:2349:850:2353:8 53:954:474:1380:984:18 84:2086:18

reported 6:18

48:1071:773:23 91:5

reporter

3:8 4:1557:4

reporting

5:2215:13 21:1521:17 48:1060:1974:2 74:11

reports 20:23

47:1164:6 65:975:12108:19108:24

represent

4:24

representativ

e 80:12

request 4:9

31:25

requested 4:8

83:22

requesting

102:22102:25

requests 20:7

require 109:7

109:13109:15

requires

109:10

research

15:12

researchers

73:13

resolution

99:2 109:21

resource 15:1

Resources

86:16

respected

39:13

respond 30:15

responding

3:23

response 19:7

66:19

responsibilit

ies 19:22

25:3 52:8102:3

responsibilit

y 21:8

47:20

responsible

6:1214:2564:6 82:16

rest 40:10

104:6

restrictive

7:13

resulted

52:14

retained 3:11

retaliated

86:13 111:3

retaliation

78:786:19 86:2487:3 90:991:399:12 99:1399:16 99:1799:25100:23110:24111:3

retention

20:10

retired

5:2315:18 83:3

review 11:19

RFP 41:7

41:11 41:18

RFPs 40:4

Rick 3:15

67:23

rid 44:16

53:16 70:8

ride 95:19

road 36:3

110:6

robbery 23:18

rock 70:7

rode 30:3

30:5

role 3:18 4:2

5:14 5:175:19 8:2211:14 15:1216:16 17:2531:1354:471:1982:889:21108:14

roles 82:6

roll 34:13

rolled 97:12

rolling 93:3

rolls 35:11

Romero 3:15

room 37:15

37:1738:1 38:7

rotate 48:23

Row 16:18

r-t-r-i-g-h-t

4:20

Rubens 4:23

rules 35:24

36:936:14 36:1536:20 40:1

rumors 105:12

run 10:7

110:4

running

22:4 33:25

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rush 50:1

S

safer 18:3

Safety

16:1530:4 37:4

salary

46:1747:6 47:750:20 50:2152:452:16 52:1768:8 108:17

Sanders 30:23

31:19 55:1057:2287:299:20111:11

sat 28:20

satisfied

109:4

save 18:4

saw 37:22

55:15 56:20104:1104:12105:16111:16

schedule 16:2

60:25 108:2

scheduling

98:10

Schwering

47:1 73:12

S-c-h-w-e-r-

i-n-g 47:1

scope

110:13110:18110:19

Scott 5:23

7:20 14:314:16 15:1315:25 18:2029:3 31:14

screw 70:9

Seabold 3:10

seasonal 7:25

Seattle

45:946:10 49:1269:18

secondhand

103:7

security

56:10

seeing 101:10

seeking

78:4 109:22

seem 99:10

seemed 65:4

66:7

seems 108:25

seen 26:13

29:5 92:5103:4110:19

seizure 40:10

40:11 41:2146:20

seizures

46:22

self-

powerment

77:9

send 31:14

31:16 31:1731:23 31:2532:172:2377:5 84:19

sends 45:8

senior 15:22

sense 20:1

33:2135:1 43:969:8 99:11

sent 19:3

31:18 31:1931:20 44:1145:2064:9 65:671:2372:9 74:15

separate

108:3

separately

79:7

September

11:20 63:1863:21 63:2564:24 66:2294:8 100:11

sergeant

95:18

series 7:15

37:6

serve 6:2

Served 21:4

service

5:13 7:11

8:19 10:610:11 12:1413:813:11 13:1219:635:24 35:2536:9 61:19

services

6:2 6:4 8:59:1810:1811:312:1813:113:1315:215:11 16:1747:8 54:361:7

sets 61:22

setting 90:2

settings

102:2

seven 33:5

33:6

several

6:20 8:272:1 98:14

sexual

86:19 90:3

share 73:6

87:18 89:8

shared

56:1174:4 93:7106:4 107:6108:16

sharing 74:3

she'd 98:10

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sheet 46:16

sheriff 6:7

27:3 27:427:4

sheriff's

34:5 34:6

she's 45:16

56:17 87:2287:2392:494:14 94:14106:10106:12107:16

short 16:22

48:19

shortly

82:6 83:21

shoulders

105:9

showed 69:2

73:19

shown 73:22

shows 79:24

sick 59:18

signed 97:16

significant

20:18 23:1040:16 97:17

signs 109:20

single 47:22

sir 34:24

sit 17:13

43:7

sitting 28:17

30:937:15 37:16

37:17

situation

39:12 79:24101:13

six 5:19

20:23 29:1255:558:17 66:18

size 7:11

26:16

skill 60:1

61:22 65:2

skills 10:14

slam 26:15

slamming 88:6

slap 47:17

50:17107:13

slapping

27:16

slider 37:12

sliders 37:9

slightly

34:22

slow 36:18

smart 104:4

smarter 18:4

smelled 59:11

snow 97:17

97:18

social 102:2

socialized

104:13

socializing

37:23

socially

87:12 87:15

sole 41:6

41:14 41:14

somebody 63:2

75:17

somehow

12:9 92:24

someone 10:14

20:227:1929:546:15 53:1254:2 68:6

sometime 53:8

91:2192:3 92:4

somewhat

74:16

somewhere

50:3

sorry 7:4 9:8

12:20 16:2022:742:10 44:2279:1 92:18

sort 6:21

12:5 17:518:20 47:1749:953:22 59:1561:18 63:1764:1 78:895:8 109:11

source 40:5

41:641:14 41:15

space 10:20

16:25

17:7 33:434:14 52:21

SPD 5:25

9:4 66:2267:3

speak 38:9

100:13

speaking

99:14 99:25

spec 47:6

49:1952:287:25108:15109:19

specifically

38:564:14 68:2189:10 89:2396:17 96:21

specifics

92:16

specs 47:13

87:23

speculating

106:18106:19

spell 4:15

12:2342:2 94:13

spend 25:6

32:23 40:2442:22 64:1765:385:18 85:20

spending 6:22

44:17 84:20100:19100:20

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Spokane

3:11 5:146:17 9:69:7 18:139:23

spoken 103:8

spot 24:3

staff 9:21

15:19 15:2220:20 20:2131:1638:638:1144:248:16 61:1764:11 64:2066:2267:380:11 80:1497:18104:22105:7

Stamper 4:23

stand 24:21

39:16 39:18

standard

43:15

stands 75:14

Starbucks

103:4

staring 54:14

start 29:7

42:23 60:2563:21 63:2389:12

started

4:14 5:75:16 15:821:15 22:23

23:423:16 24:1725:11 25:2126:1229:631:12 32:1632:16 35:1451:461:16 63:2491:19 110:6

starting 6:25

63:22 68:9

state 4:14

34:455:20 68:2373:12

stated 64:14

statement

12:9

statements

4:8 4:1067:7

stationed

91:18

statistics

27:1

status 68:5

68:8 91:20

stay 25:23

57:19 63:1376:14

stayed 82:5

Steinolfson

94:13

step 38:6

Stephens 5:23

7:20 14:315:25 17:18

18:2029:3 31:14

stern 34:22

35:4

steward 40:4

stick 64:21

sticks 29:17

stop 5:4

stopped 48:25

storm 49:6

stormed 38:15

strategic

5:2113:2414:116:16 18:1846:18 51:24

strategies

24:2

Straub 3:13

5:2511:12 11:2312:2 12:713:2114:2 14:814:1517:821:13 21:1421:15 24:1925:22 28:1131:18 32:1943:11 47:1355:757:16 58:2258:23 65:1969:25 70:2172:376:2183:5 83:9

90:4 99:3102:20103:11103:12103:24104:18104:20105:18107:11111:4

Straub's 22:3

101:7103:15

Street 30:7

stressful

59:21 76:23

strict 40:12

strife 69:24

strong

17:19 17:21

struggling

17:15 62:2

stuck 35:20

stuff 97:19

stupid

34:25 41:14

subject 72:18

submitted

11:19

subsequent

4:9 14:18

substantial

15:8 40:19

suddenly 81:4

suffered 20:6

suffering

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15:6

suggest 58:25

88:19

suggested

47:25 60:24100:14

suggestion

62:8 101:2

suggestions

89:4

suite 16:18

suited 86:12

summer 94:15

Sunday 42:22

supervising

20:20

supervisor

53:7 104:21

support 6:5

supported

93:11

supportive

11:13

suppose 48:13

supposed 8:24

11:10 21:1740:345:1248:556:15 75:21

sure 4:10

4:17 5:36:1217:1525:426:21 38:1939:9 51:4

51:1652:565:1766:666:1384:884:23 91:24106:11

surprise 81:3

surprised

11:10 81:4

surrounding

110:21

SWAT 40:20

swear 28:11

28:12 29:13

sweat 76:25

switch 24:7

system

10:2324:9 49:575:15 75:20

systems 49:4

T

table 26:15

27:17

TAC 75:13

take-home

47:20 47:2247:25 48:1248:16

taking

11:25 19:1049:557:14 63:17

talk 27:22

28:7

45:21 55:1062:867:14 69:1975:676:10 76:1777:16 89:1889:23 92:1694:21

talked

17:12 24:1837:842:1379:680:15 88:1190:18107:15108:18

talking 13:18

31:641:19 43:2144:257:10 61:1172:20 91:2

tape 36:5

68:4

task 27:5

34:4 34:834:8

teaching 92:5

team 5:25

22:1 22:822:18 28:1034:1035:7 35:840:20 57:1761:861:24 64:1466:23 73:1483:7 105:5

tears 76:25

tech 69:13

Technical

75:14

technically

21:10 21:1723:20109:12

technology

61:9 62:2

telephone

108:1

temp 7:24

temper

34:21 36:24

temporarily

77:5

temporary

8:2410:19 11:1051:1853:1 53:254:5 55:255:11 55:1556:15 57:1257:15 59:1060:4 60:560:15 65:7

ten 28:4

63:25 64:1765:3 76:24

tend 28:7

tens 16:3

16:8 66:2

tenure 29:7

29:23

Teresa 82:10

term 90:19

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terms 15:3

20:1626:9 32:755:1756:4 86:692:18109:21

Terrific 5:1

text 74:9

75:7 104:17104:20

texted 74:8

texts 74:22

thank 107:7

111:20

thanks

43:2546:5 60:13

theft 23:15

23:16 23:1934:4

theory

11:23 47:2161:16 74:1

therefore

91:4 99:4

there's 25:18

32:14 40:2041:2 69:773:17 76:12107:21

Theresa 30:23

30:25 31:1955:957:2258:958:13 58:1658:23 59:2359:24

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third 108:25

thirdhand

103:8

thousand

40:18

threatened

59:9 80:18

throats 75:12

throw 27:11

96:20

throwing

27:25

thrown 80:1

Thursday

3:5 16:465:23100:25

till 10:21

Tim 46:25

48:1850:2 50:351:12 54:16

56:1971:3 71:571:5 71:671:7 73:11

timely 97:20

tire 49:9

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108:22

tissue 30:14

title 10:18

10:22 10:2420:17 20:1850:22 51:2198:12

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today 10:11

109:24

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total 63:25

towards

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108:3

Tracy 106:14

traditionally

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training

44:12 44:1844:22

45:5 45:949:13 91:1795:3

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57:12

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77:4 78:678:1380:580:1081:1 101:15101:17

treating 81:7

81:21

treatment

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trees 34:2

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tried 24:2

24:2533:382:13 82:1586:5 89:18

trip 63:18

trouble 21:14

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trucker 28:7

true 25:9

73:374:19 86:4

truly 24:5

trust 17:25

101:4

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truth 99:14

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83:23

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61:8 77:699:10100:21

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understanding

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10:539:11 53:10

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unit 6:6

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University

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87:10

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13:17

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V

vacancies

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vacation 38:5

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various 63:19

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vent 92:20

versus 50:22

Vic 48:25

vice 72:1

victim 101:16

110:23

viewed 19:14

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vision 22:3

visualizing

26:22

vocal 100:2

voice 34:22

39:1

volume 38:22

voluntary

69:12 71:17

W

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84:19

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100:15100:17100:21100:22

White 39:15

whole 7:25

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whom 99:16

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wife 106:15

willing

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wish 56:16

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witnessed

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wives 37:24

woman 93:21

women 45:8

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104:14108:5110:13

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worst 35:22

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write 68:6

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WSP 34:5

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WSU 68:22

Y

Year's 98:5

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yell 106:6

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38:10 80:17

yelling 35:5

yells 38:7

Yep 22:17

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yesterday

111:5

yet 68:3

yourself 60:5

60:10

youth 39:14

39:17 39:1839:19

you've 5:10

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24:9 105:24110:18

YPI 39:14

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