Chris Jackson Testimony

Joseph Hall - RedirectWednesday/January 27, 2010/Volume 3

85

1 later point asked for reconsideration of the vote. There

2 has been no further -- there was no further testimony

3 regarding the disposition of the motion for reconsideration,

4 the request for reconsideration.

5 Secondly, Mr. St. John testified that when

6 Mr. Riddle's request for the $25,000 was voiced and

7 Mr. St. John said no, Mr. Riddle showed no reaction.

8 Third, the last witness, Mr. Hall, never worked in

9 any of the -- never performed in any of the clubs.

10 Thank you.

11 Let's go ahead.

12 MR. GARDEY: The United States calls Chris Jackson

13 as a witness.

14 THE COURT: In front of me, sir. Raise your right

15 hand.

16 - - -

17 CHRISTOPHER JACKSON,

18 being first duly sworn by the Court to tell

19 the truth, was examined and testified upon his

20 oath as follows:

21 - - -

22 DIRECT EXAMINATION

23 BY MR. GARDEY:

24 Q. Mr. Jackson, if you could pull the microphone down.

25 That's good.

09-20025-04; U.S.A. v. Samuel Riddle

Christopher Jackson - DirectWednesday/January 27, 2010/Volume 3

86

1 Please state your full name for the record and

2 spell your last name.

3 A. Christopher Troy Jackson, J-a-c-k-s-o-n.

4 MR. GARDEY: Your Honor, at this time the

5 government would move Exhibits 22A through E and Exhibit 23

6 into evidence. Those are the Deja Vu exhibits.

7 THE COURT: Hold on. 22?

8 MR. GARDEY: 22A through E.

9 THE COURT: Admitted.

10 MR. GARDEY: And Exhibit 23.

11 THE COURT: Admitted.

12 BY MR. GARDEY:

13 Q. Mr. Jackson, how are you employed?

14 A. I am self-employed.

15 Q. What is your business?

16 A. I own a couple of businesses. One is Jackson

17 Consulting Group, L.L.C. I am also a partner in Paradise

18 Valley Partners. I am a partner in Queen Lillian, L.L.C.,

19 and I am also a partner in Detroit Credit Card ATM

20 Processing, L.L.C.

21 THE COURT: Pull the mike a little closer to you.

22 The chair doesn't move so we have to move the mike or the

23 body.

24 BY MR. GARDEY:

25 Q. Where are you from originally?



87

1 A. Detroit, Michigan.

2 Q. Were you born and raised here?

3 A. Yes, I was.

4 Q. What's your educational background?

5 A. Went to grade school here in Detroit, St. Phillips

6 Lutheran School. Went to Cass Tech High School, graduated

7 from Cass Tech High School. Went to Howard University,

8 received a degree there. Upon graduating I actually

9 attended the University of Detroit Law School, did not

10 graduate, did three years there.

11 Q. Now, after, what do you do after you left law school?

12 A. While I was in law school, I was actually in law school

13 part time. I was working in the employ of Detroit City

14 Councilman Gil Hill. I started working there upon

15 graduating from Howard University.

16 Q. What year did you start working for Councilman

17 Gil Hill?

18 A. I believe it was 1991.

19 Q. Was that Detroit City Council?

20 A. Yes.

21 Q. When you started with Councilman Hill's office, what

22 was your position?

23 A. At that time I was an administrative assistant handling

24 legislative affairs.

25 Q. How long did you work for Councilman Hill?



88

1 A. Approximately about eight years, seven years.

2 Q. What year did you leave Councilman Hill's?

3 A. Somewhere around 1997.

4 Q. Did you hold any other positions with Councilman Hill?

5 A. Upon my last two years I was his chief of staff.

6 Q. What did you do after you left Councilman Hill?

7 A. When I left Councilman Hill, I started Jackson

8 Consulting Group. I also served in a consulting capacity

9 and then later as a partner in Monroe Partners, 400 Monroe

10 Associates and then later Monroe Partners, which then later

11 on became one of the 50 percent owners of Greektown Casino,

12 and I was a partner in that company.

13 Q. So did you leave Councilman Hill and start Jackson

14 Consulting approximately in 1987?

15 A. Yes.

16 Q. And so you have been working partly as Jackson

17 Consulting from 1997 to the present?

18 A. Yes.

19 Q. What kind of work does Jackson consulting do?

20 A. Jackson Consulting is a government relations consulting

21 firm primarily focusing on assisting clients in the

22 financial sector.

23 Q. How about back in the fall of 2006, what kind of work

24 did Jackson Consulting do?

25 A. 2006 or 2007?



89

1 Q. In 2006.

2 A. Well, I did not have Jackson Consulting while I was

3 still in the employ of --

4 Q. I'm sorry, in 2006, not 1996.

5 A. I'm sorry, I'm sorry, I thought you said 1996. In 2006

6 Jackson Consulting was again focusing on clients in the

7 financial arena. At that time there was one client I

8 believe that Jackson Consulting had that was outside of the

9 finance arena that was in the sort of public schools or in

10 the schools markets, but for the most part most of

11 Jackson Consulting's clients were in the finance arena.

12 Q. And when you say Jackson Consulting's clients were in

13 the finance arena, what type of work did you do for your

14 finance clients?

15 A. Most of my clients were asset management firms, hedge

16 funds, money management firms, real estate management firms.

17 We primarily do business with Detroit's pension funds, Wayne

18 County's pension fund, as well as other pension funds around

19 the country.

20 Q. And what kind of work did you do for these clients?

21 A. I would assist my clients, the asset management clients

22 in actually obtaining asset allocations from pension funds

23 to manage the pension fund's dollars or in the case of hedge

24 funds or private equity funds Jackson Consulting would

25 assist those clients in obtaining dollars that would be



90

1 invested into those hedge funds or private equity funds.

2 Q. Now, you mentioned earlier that you are also the owner

3 of the Detroit Credit Card Processing Company?

4 A. Yes, sir.

5 Q. And how long have you owned that company?

6 A. Detroit Credit Card/ATM Processing roughly I believe

7 was started back in 2000/2001.

8 Q. And that business was active in 2006?

9 A. Yes.

10 Q. What kind of work does that company do, Detroit Credit

11 Card/ATM Processing?

12 A. Detroit Credit Card/ATM Processing owns ATM machines,

13 has an interest in securing clients, if you will, for credit

14 card processing from businesses, restaurants, entertainment

15 venues and the like.

16 Q. In 2006 did you have a relationship with a bank for

17 purposes of your credit card processing business?

18 A. Yes. My partner -- or I should say Detroit Credit

19 Card/ATM Processing's partner was First Independence Bank.

20 Q. And was it First Independence Bank's job to process

21 credit card transactions that you were handling with either

22 MasterCard or Visa or other banks around the country?

23 A. Yes.

24 Q. And how is it you would make money off of your

25 business, the Detroit Credit Card Processing and ATM



91

1 business.

2 A. The ATM business, for every transaction that a customer

3 would use an ATM machine we charge a transaction fee. For

4 the credit card processing there is a small transaction fee.

5 When a person uses a credit card at a point of sale, a place

6 of business, there is a small transaction fee that is

7 charged to that company that is actually using the

8 processing services.

9 Q. Now, today, Mr. Jackson, do you have any agreements

10 with the United States Government in connection with your

11 testimony today?

12 A. Yes, I have an immunity agreement.

13 Q. Do you have a use immunity agreement with the

14 United States?

15 A. Yes.

16 Q. What is your understanding of the terms of that

17 agreement?

18 A. My understanding of the terms of that agreement is to

19 tell the truth. If in fact I violate any of those terms as

20 it relates to telling the truth, I will perjure myself. So

21 roughly it's to tell the truth.

22 Q. And what is your understanding as to whether or not the

23 government can use what you say in your testimony today

24 against you at a later criminal proceeding?

25 A. It's my understanding that they cannot.



92

1 Q. And what happens if you lie during your testimony

2 today? Would the government be able to use your testimony

3 today against you in a later criminal proceeding?

4 A. Yes.

5 Q. Now, Mr. Jackson, let me direct your attention back to

6 the fall of 2006. At that time did you do some work for

7 Deja Vu Consulting?

8 A. Yes, I did.

9 Q. And what kind of business is Deja Vu Consulting in?

10 A. My understanding is that Deja Vu is in the business of

11 adult entertainment.

12 Q. Is that strip clubs?

13 A. Yes.

14 Q. What was the purpose of your work for Deja Vu

15 Consulting?

16 A. I was asked to consider representing Deja Vu. It

17 actually was back in September of '96. I was approached by

18 a Renee Pipis, who was another government relations

19 consultant, who asked me to look into working with this

20 group as it relates to transferring a license, an existing

21 license from one owner to a new owner. I actually, when I

22 asked to look at consulting in that regard, that was not

23 necessarily my forte, if you will. I informed her that my

24 practice was more so in the finance arena, but I did agree

25 to look into some due diligence, initial due diligence into



93

1 the matter.

2 Q. You said, you testified 1996. Did you mean to say

3 2006?

4 A. 2006. I'm sorry, sir.

5 Q. And that was in September 2006?

6 A. Yes.

7 Q. And you say you were proposed by a Ms. Pipis?

8 A. Yes.

9 Q. What was your understanding who she was working with?

10 A. She actually had been consulted or contacted by State

11 Representative Barb Ferrer. It's my understanding she

12 represented some downriver communities. She had brought to

13 her attention the issue of the Deja Vu, and they had

14 previously been turned down as it relates to the transfer of

15 the license maybe back in 2003, and I believe Representative

16 Ferrer contacted Ms. Pipis and asked if this was something

17 that she could assist in, could she help. Ms. Pipis, in

18 turn, contacted me.

19 From there I was given a series of some white

20 papers and other historical documentation relative to the

21 whole license transfer of the ownership from Ms. Pipis as

22 well as some things even faxed to me from Barb Ferrer's

23 office.

24 Q. Now, after you were contacted by Ms. Pipis did you have

25 meetings with people from Deja Vu?



94

1 A. Yes, I did.

2 Q. Who did you meet with from Deja Vu?

3 A. I believe it was Gary Koloszar, Mr. Hall and

4 Mr. St. John.

5 Q. Is that Jim St. John and Joseph Hall?

6 A. Yes.

7 Q. And what was the purpose of your meeting with Mr. Hall,

8 Mr. St. John, and Mr. Koloszar?

9 A. To get background information on this particular case

10 as part of my due diligence. I wasn't sure at that time if

11 I would even consider representing them as a consultant, but

12 to get all the information possible.

13 Q. Did you come to any kind of agreement with the people

14 at Deja Vu concerning your working for them?

15 A. We actually had come to a verbal agreement of sorts. I

16 had actually proposed, because this was something sort of

17 outside of my general consulting practice, that my interest

18 was to -- versus a basic consulting arrangement, I was

19 looking for being able to grow my credit card/ATM processing

20 business and so I had proposed to them that sort of in lieu

21 of consulting fees being able to do business, if I assisted

22 them, to be able to do business either having ATM machines

23 in their various facilities around the country as well as

24 credit card processing business.

25 Q. And would that have been a significant investment or



95

1 was that of significant worth to you in your credit card

2 processing company if you had been able to get that from

3 Deja Vu?

4 A. Yes.

5 Q. Did they also offer you an opportunity to buy an

6 option, an ownership interest in the Deja Vu facility in

7 Detroit?

8 A. Yes. Later on there were discussions with myself and

9 those gentlemen as it relates to an ownership interest in

10 the Deja Vu Detroit property.

11 Q. Were you interested in getting an ownership interest in

12 Deja Vu?

13 A. That was not really my interest. I really had no

14 interest in being in the strip club business. I was more so

15 focused on the credit cart processing business and the ATM

16 business.

17 Q. Why weren't you interested in being a part owner of a

18 strip club business?

19 A. Well, I don't think my wife would have thought it was a

20 great idea, but it was just not something that I truly had

21 a lot of experience in. I had been in the entertainment

22 business, if you will, in the gaming business, and I had

23 just actually transitioned out of that business and had sold

24 my interest not long prior to this. And so I was really

25 just, really more so focused on growing my ATM and credit



96

1 card processing business.

2 Q. And you mentioned you had an interest in gaming. Was

3 that with 400 Monroe Partnership?

4 A. Yes 400 Monroe later became Monroe Partners, and Monroe

5 Partners had a 50 percent ownership interest in Greektown

6 Casino.

7 Q. But at the time in 2006 you had sold your interest in

8 Greektown Casino?

9 A. Yes. I actually had made provisions to sell my

10 interest, yes.

11 Q. Based on your meetings with Mr. Hall and Mr. St. John,

12 what was your understanding of what you were supposed to do

13 for Deja Vu?

14 A. My understanding was to, one, the first step was to

15 make contact with the City, in particular the City's Law

16 Department. I did contact John Johnson at the time, who was

17 the counsel for the City of Detroit, to do some initial due

18 diligence as to what was the City's legal position as

19 relates to the transfer of the license. The gentleman had

20 shared with me that if in fact the license was not

21 transferred they were going to continue on with their

22 litigation against the City of Detroit in federal court on

23 some constitutional grounds as relates to the denial of the

24 transfer. So the first step was to talk with John Johnson

25 to find out in fact if the City felt that it was from a



97

1 legal perspective prudent to effectuate the transfer.

2 Next was to --

3 Q. Well, first let me ask a couple of questions about

4 that.

5 A. Sure.

6 Q. So in September of 2006 it was your understanding that

7 there was ongoing litigation between Deja Vu and the City of

8 Detroit about Deja Vu opening a club in Greektown in the

9 City of Detroit?

10 A. Yes.

11 Q. And you were to try to convince the City Council and

12 the City to grant the license instead of proceeding with the

13 litigation; is that correct?

14 A. Yes.

15 Q. Now, you said you met with Mr. Johnson from the City of

16 Detroit Law Department?

17 A. Yeah, I actually contacted Mr. Johnson. We had a

18 meeting scheduled. Something came up the day of the

19 meeting. We did talk by phone and had some conversation

20 relative to the issue, and it appeared to me that he did

21 understand some of the legal issues and potential

22 culpability that the City may have if in fact there were --

23 if Deja Vu prevailed on the litigation.

24 Q. Now, before Deja Vu started working with you did you

25 have any understanding as to whether Deja Vu had met with



98

1 any of the members of the City Council?

2 A. I had not. I don't think I knew they had met with

3 council prior to that.

4 Q. Did you arrange any meetings with members of City

5 Council in order to convince them to approve the license for

6 Deja Vu?

7 A. Yes, I arranged a number of meetings.

8 Q. What meetings did you arrange?

9 A. I believe the first meeting we had was with Barbara,

10 Councilwoman Barbara Rose Collins.

11 I don't know the exact order, but I know we met

12 with Councilwoman Sheila Cockrel. We met with Councilwoman

13 Martha Reeves. We met with Cockrel, Reeves, Councilwoman

14 Alberta Tinsley-Talabi. I had spoken with a staff member of

15 Councilman Cockrel, but we did not, could not get a meeting

16 scheduled, and I had also spoken with Councilwoman

17 Monica Conyers and had a meeting scheduled.

18 Q. So did you reach out to Councilwoman Monica Conyers to

19 try to set up a meeting with Deja Vu?

20 A. Yes.

21 Q. Now, these meetings that you talked about with these

22 other councilpeople, who was at those meetings?

23 A. From a staff standpoint or from?

24 Q. From Deja Vu.

25 A. Deja Vu. I believe Joe Hall was at all of the



99

1 meetings. I believe Mr. St. John was at all or at most of

2 the meetings as well.

3 Q. And were you trying to work with Deja Vu to convince

4 these members of the City Council to approve the transfer of

5 the license so that they could open their club?

6 A. Yes.

7 Q. And the members of the City Council you met with, were

8 they receptive to your request?

9 A. In most cases they were able to separate the emotional

10 component of a strip club and the entertainment side of it

11 from the legal issue, which was that the license, the

12 cabaret D license already existed at that particular

13 location and this was just a matter of a transfer of

14 ownership and so that they could not stop that location from

15 having a license. And many of them, many of them maybe

16 initially did not fully understand that, but it seemed like

17 after our meetings that that became clear and that this was

18 really not a morality issue, but it was really more of a

19 legal issue.

20 Q. Did you also discuss the possibility that the City

21 could face damages from the litigation if they went forward

22 with the litigation?

23 A. We shared with them in those meetings that these very

24 same type of cases have occurred and that I believe Deja Vu

25 had even been involved in litigation in other parts of the



100

1 country with other major cities and those cities had lost in

2 these type of transfer cases and there were significant

3 damages and that in this case what we tried to prevail on

4 them is that it was better to move forward or allow the

5 transfer versus putting the City in harm's way.

6 Q. Were there some members of City Council who would not

7 meet with you or who you believed were against the transfer

8 of the license?

9 A. Yes.

10 Q. And who were those?

11 A. We were not able to arrange a meeting with Ken Cockrel.

12 We were not able to arrange a meeting with Councilman

13 Kenyatta or Councilwoman Watson. I'm trying to think who

14 does that leave?

15 All of the people we met with we were -- were the

16 ones we felt were receptive. I think those were three that

17 we were not able to arrange a meeting with. And I am sorry,

18 Councilwoman Jones, we were not able to arrange a meeting

19 with Councilwoman Jones.

20 Q. Why did you want to meet with Councilwoman

21 Monica Conyers?

22 A. To be able to go through the same issues with her as we

23 would have gone through with the other council members.

24 Q. Did you actually set up meetings with Ms. Conyers and

25 the people from Deja Vu?



101

1 A. Yes, we did have a meeting scheduled.

2 Q. Did you meet with her?

3 A. No, I did not meet with her.

4 Q. Why is that?

5 A. I either ran into her or either received a phone call,

6 I cannot recall exactly how it came about, but I did talk

7 with her and she had shared with me that she was not able to

8 make the appointment, that I was still supposed to, should

9 still come to her office and that I would be meeting with

10 somewhere there at her office.

11 Q. Had you had any prior contact, relationship with

12 Mrs. Conyers or her husband?

13 A. I had had contact with her just in my regards of being

14 a consultant, being in city hall, being involved in city

15 government.

16 Q. Now, you said you ran into Ms. Conyers and she had

17 cancelled the meeting. What happened next?

18 A. Well, the meeting -- or I still went to her office as

19 instructed. When I got to her office, I met in her actual

20 office with Mr. Sam Riddle to discuss. It was understood

21 that he was there to receive me to discuss the issues

22 relative to Deja Vu.

23 Q. Did Ms. Conyers tell you why she wanted you to meet

24 with Sam Riddle?

25 A. That he was her representative.



102

1 Q. And at that time what was your understanding of the

2 relationship between Sam Riddle and Monica Conyers?

3 A. At that time it was a little unclear. I had heard some

4 rumors sort of out in the consulting community, you know,

5 out throughout Detroit that, you know, that there was a

6 relationship between Ms. Conyers and Mr. Riddle. I know at

7 one time --

8 MR. WISHNOW: I'll object to this, Your Honor.

9 THE COURT: Well, he's answered the question.

10 Let's wait for the next question.

11 BY MR. GARDEY:

12 Q. Mr. Jackson, did you have any understanding as to

13 whether Mr. Riddle held any position within Ms. Conyers'

14 office?

15 A. I know at one time he was her chief of staff. At one

16 time he had been her campaign manager. I was not exactly

17 sure if that was -- I would assume that was the capacity

18 that he was in on that day.

19 Q. Now, the day you met with Mr. Riddle -- is

20 Mr. Riddle --

21 Do you know Mr. Riddle?

22 A. Yes.

23 Q. Is he here in the courtroom?

24 A. Yes.

25 Q. Could you please point him out and describe something



103

1 he's wearing?

2 A. He has on an argyle sweater and a blazer.

3 MR. GARDEY: Let the record reflect that the

4 witness has identified the defendant, Mr. Riddle.

5 BY MR. GARDEY:

6 Q. Now, you said you met with Mr. Riddle in Ms. Conyers',

7 her personal office?

8 A. Yes.

9 Q. Now, each member of the City Council has offices in the

10 City/County Building; is that correct?

11 A. That is correct.

12 Q. And within those offices there is an office for,

13 personal office for the City Council members; is that

14 correct?

15 A. Yes.

16 Q. And you met with Mr. Riddle in her actual office?

17 A. Yes.

18 Q. And Ms. Conyers was not present?

19 A. No.

20 Q. Where did you sit within the office?

21 A. There is a small round conference table in her office.

22 We both sat at the conference table.

23 Q. Was anybody else present beside you and Mr. Riddle?

24 A. No.

25 Q. And some time ago you had been an intern for



104

1 Mrs. Conyers' husband?

2 A. Yes.

3 Q. And when was that?

4 A. Back in the spring of '87 roughly through about '99.

5 Maybe spring of '99.

6 Q. Is that spring of '87 to '89?

7 A. I'm sorry, '89, '89, yes.

8 Q. Is that when you were in college?

9 A. Yes, when I was at Howard University.

10 Q. Why did you go to the meeting with Mr. Riddle without

11 anyone from Deja Vu?

12 A. Because we were not meeting with what I considered the

13 principal and we were meeting with a staff person, a little

14 bit not sure exactly what direction that meeting was going

15 and I thought it was best that I meet with him myself.

16 Q. And if you had met, when you had scheduled a meeting

17 with Ms. Conyers, had you planned to have someone from

18 Deja Vu with you at that meeting?

19 A. Yes.

20 Q. Now, at that meeting in Mrs. Conyers' office did

21 Mr. Riddle tell you or say anything about what his current

22 relationship was with Mrs. Conyers?

23 A. I, I actually was, you know, a little curious about

24 that myself because of the rumors I have heard out there.

25 He shared with me, you know, that, it may not be an exact



105

1 quote, but, you know, that they couldn't necessarily always

2 get along. I think he might have used the word crazy. He

3 said that, you know, he was her chief of staff but that they

4 had to have a different relationship.

5 Q. What happened during your meeting in Mrs. Conyers'

6 office with Mr. Riddle?

7 A. Well, we talked about a number of things. I believe he

8 started out the meeting. He suggested a couple of books for

9 me to read. I'm not sure how we got on that subject. I

10 know one was A State of Denial and the other one was -- I

11 can't recall what the second book was off the top of my

12 head.

13 We talked about a gentleman who actually worked in

14 Councilman Gil Hill's office, Greg Robinson. He asked me

15 about his work ethic. I guess he or Mrs. Conyers was

16 considering hiring him or either he had been hired, I am not

17 sure if he was in her employ at that time, but wanting to

18 know sort of as a reference or referral what did I think of

19 them hiring him.

20 Q. Mr. Riddle asked you about a Greg Robinson who you knew

21 from Gil Hill's office when you worked for Gil Hill; is that

22 correct?

23 A. Yes.

24 Q. And Mr. Riddle was asking you basically as a reference.

25 What is your understanding as to whether Mr. Robinson was



106

1 applying for work with Mrs. Conyers' office?

2 A. Yes.

3 Q. And after talking about books and the reference for

4 Mr. Robinson, did you talk about the Deja Vu issue?

5 A. Yes, we did.

6 Q. What did Mr. Riddle say about that?

7 A. It seems to me that he understood the legal issues that

8 were at hand. Mr. Riddle, you know, being an attorney or

9 having been to law school, he seemed to understand the legal

10 issues. He thought that it was something that possibly

11 could be something that she may be able to support, and we

12 had agreed that we would get together outside of the office

13 to discuss it further.

14 Q. Did he say why he wanted to meet with you outside of

15 Mrs. Conyers' office to discuss it further?

16 A. I got the impression that because he had a Meridian

17 Management business that we were sort of switching into more

18 a discussion as a consultant that it would probably be more

19 prudent to discuss that somewhere else.

20 Q. What did Mr. Riddle say about Meridian Management?

21 A. Meridian Management was a consulting firm that he had,

22 and Meridian Management was an entity that, you know, might

23 be able to -- that he suggested that could help in this

24 regard.

25 Q. Did you arrange to have a second meeting with



107

1 Mr. Riddle after that first meeting at Mrs. Conyers' office?

2 A. Yes.

3 Q. Where did that meeting, the second meeting take place?

4 A. That meeting took place at the Click Restaurant.

5 Q. Where is the Click Restaurant?

6 A. Click is on East Jefferson just east of I-75 freeway on

7 the south side of Jefferson.

8 Q. Now, this first meeting with Mr. Riddle in

9 Mrs. Conyers' office, was that in October of 2006?

10 A. I believe that sounds right, yes.

11 Q. Now, how soon after your first meeting did you have a

12 second meeting with Mr. Riddle at the Click?

13 A. I don't believe it was too long, days.

14 Q. Was it breakfast, lunch? What kind of meeting was it?

15 A. It was a breakfast meeting.

16 Q. And who was there at that second meeting?

17 A. At that meeting it was just myself and Mr. Riddle.

18 Q. Now, what did you discuss with Mr. Riddle at the

19 meeting at Click?

20 A. At the meeting at the Click there was more focus on

21 Meridian Management. Sam went into sort of a, what I call a

22 commercial, if you will, of the accomplishments of Meridian

23 Management or himself. He talked about Columbine and his

24 successes there in Colorado after that tragedy in assisting

25 I believe families there. He talked about some of the work



108

1 he had done with Meridian and that -- the value that he

2 could add, that if in fact if Meridian was brought into this

3 that Meridian could help, help us secure support from

4 Councilwoman Conyers.

5 Q. Did Mr. Riddle say whether or not Deja Vu would have to

6 hire Meridian Management in order to get Mrs. Conyers' vote?

7 A. Yes.

8 Q. What did he say?

9 A. He laid out a couple of scenarios, one being that

10 Meridian -- if in fact we didn't have Meridian, and clearly

11 I think he had done some due diligence and saw that, took

12 the temperature where the council was and where sort of the

13 splits were and where the various councilpeople were going

14 to be voting one way or another and that her vote was sort

15 of a key vote and Meridian would be necessary in order to

16 secure her vote which probably could be the key swing vote.

17 Q. Did Mr. Riddle say what would happen if Deja Vu did not

18 hire Meridian Management?

19 A. Well, I got the impression that --

20 MR. WISHNOW: Objection, Your Honor.

21 THE COURT: Wait a minute.

22 MR. WISHNOW: I'm sorry, he's talking about his

23 impression.

24 THE COURT: The question was: Did Mr. Riddle say

25 what would happen if Deja Vu did not hire Meridian? Did he



109

1 say something? Not your impression. Did he say something?

2 THE WITNESS: Yes.

3 THE COURT: What did he say?

4 THE WITNESS: We wouldn't get Monica Conyers'

5 support.

6 THE COURT: Go ahead.

7 BY MR. GARDEY:

8 Q. And what would happen if Deja Vu did not hire Meridian?

9 A. We would not get the councilwoman's support. In

10 addition to that, she could actively work against us getting

11 support even from other people, that she would work actively

12 against Deja Vu.

13 Q. Did Mr. Riddle describe at this meeting at the Click

14 what Monica Conyers would do to act actively against the

15 Deja Vu project if Meridian wasn't hired?

16 A. Well, that could happen in a couple of ways based on

17 our conversation. One, if in fact Deja Vu and I guess our

18 discussion also went into a maintenance contract, if you

19 will, and that was an ongoing relationship with Meridian

20 Management, that if in fact the transfer did occur there was

21 going to be a need for ongoing consultation because

22 establishments of that type could also run into problems

23 with zoning and licensing and the actual employees of those

24 facilities could be ticketed or the facility itself could be

25 ticketed and there would be a need or should be, there



110

1 probably could be a need and you want to be preventive in

2 that regard from any of that occurring.

3 Q. Did you take that as a threat?

4 A. Yes.

5 Q. Why is that?

6 A. I took it as a threat because council president pro tem

7 I believe at that time having influence that there are many

8 gray areas as it relates to those type of establishments and

9 that if, using her influence, be it with City officials,

10 police department, that kind of thing, that if an elected

11 official really has an issue with a place that operates what

12 I call sort of in the gray there is a possibility that

13 places could be ticketed and there could be retribution.

14 Q. So Mr. Riddle had offered -- first he wanted Deja Vu to

15 hire Meridian Consulting to get the vote, get the vote of

16 Mrs. Conyers at the City Council's vote on the transfer of

17 the license; is that correct?

18 A. Yes.

19 Q. And then, secondly, he also wanted Deja Vu to hire

20 Meridian on a continuing basis going forward at the time to

21 protect Deja Vu from Mrs. Conyers?

22 A. Yes.

23 Q. Did Mr. Riddle give you a price for what he wanted from

24 Deja Vu?

25 A. $25,000.



111

1 Q. Now, when, back in the '90's when you were the chief of

2 staff to Gil Hill did you ever act as a consultant on a

3 matter that was pending before the City Council?

4 A. No.

5 Q. Why not?

6 A. You cannot wear two hats at the same time. You can't

7 have -- you can't be advising --

8 MR. WISHNOW: I'll object to the basis for this

9 witness' opinion as to that without a proper foundation.

10 THE COURT: What foundation do you want laid?

11 MR. WISHNOW: Whatever expertise he has in this

12 area. I believe when you talk about gray areas that may be

13 one. He's giving his opinion.

14 THE COURT: The objection is overruled. Go ahead.

15 BY MR. GARDEY:

16 Q. Mr. Jackson --

17 MR. GARDEY: I don't know if he had already

18 answered the question.

19 THE COURT: No. Start over.

20 BY MR. GARDEY:

21 Q. Mr. Jackson, back in the '90's you were the chief of

22 staff for Gil Hill, a member of Detroit City Council; is

23 that correct?

24 A. Yes.

25 Q. And while you served for Mr. Hill did you ever take on



112

1 consulting work or other work pending before the City

2 Council?

3 A. No.

4 Q. And why didn't you do that at that time?

5 A. It was a conflict of interest. You cannot work in the

6 office of an elected official advising that person as

7 relates to decisions that they make and at the same time

8 represent individuals who are doing business or who are

9 asking or looking for support or guidance as relates to

10 those decisions and so I understood that there was a line

11 there that either you work in the public sector or you are

12 in the private sector. That is why I left when I left the

13 councilman's office and I started a consulting firm and did

14 use my, you know, background in government affairs outside

15 of government.

16 Q. Now, you testified that Mr. Riddle had said that he

17 wanted $25,000 at the Click Restaurant, and based on your

18 experience as the chief of staff for a City Councilman and

19 later as a consultant, what was your opinion as to the price

20 of $25,000?

21 A. I thought it was excessive.

22 Q. In fact, did you hire anyone else to assist your work

23 for Deja Vu in the fall of 2006?

24 A. Yes.

25 Q. Who was that?



113

1 A. Adolph Mongo.

2 Q. And who is Adolph Mongo?

3 A. Adolph Mongo is a government relations marketing

4 consultant here in Detroit.

5 Q. And what did you pay Mr. Mongo to assist you with the

6 Deja Vu work in the fall of 2006?

7 A. $1,500.

8 Q. Did Mr. Mongo have any experience in connection to

9 strip clubs and their business before the City Council in

10 Detroit?

11 A. Actually he did. It came to my attention that

12 Mr. Mongo had previously represented one, if not maybe

13 two other clubs, if you will, relative to the same issue of

14 a transfer of a license from one owner to another. He had

15 been successful in his endeavor to do that. This was more

16 so after the fact I learned this later on and so I thought

17 it could be prudent as a subcontractor to hire Mr. Mongo to

18 assist me since he had previously talked to councilpeople

19 and had been able to lay out that case, make a forthright

20 case as it relates to the transfer, the legal issues of law.

21 Q. And Mr. Riddle, based on what Mr. Riddle told you and

22 your knowledge of Mr. Riddle, did Mr. Riddle have any

23 experience with adult entertainment licenses and the

24 transfer of such licenses?

25 A. No.



114

1 Q. Based on Mr. Riddle, what Mr. Riddle told you, did you

2 leave that meeting at the Click with any certainty as to

3 whether you would get Mrs. Conyers' vote if you hired

4 Mr. Riddle as a consultant?

5 A. I felt confident that if he was hired we would have her

6 support, yes.

7 Q. After your second meeting with Mr. Riddle at the Click,

8 did you set up a meeting between Mr. Riddle and the people

9 at Deja Vu?

10 A. Yes. I told Mr. Riddle that I needed to consult with

11 the gentlemen who I consulted for and that it would be best

12 for him to meet them as it relates to that request.

13 Q. And was that because you believed that it was important

14 to get Mrs. Conyers' vote if you were going to win before

15 the City Council?

16 A. Yes.

17 Q. And who -- where was that meeting to take place between

18 Deja Vu and Mr. Riddle?

19 A. It took place in Andiamo's in Dearborn I believe on

20 Michigan Avenue.

21 Q. And who was present for that meeting?

22 A. Mr. St. John, Joe Hall and Gary Koloszar.

23 Q. And how soon after the Click meeting did the meeting at

24 Andiamo's take place?

25 A. Not very long after.



115

1 Q. Just a few days?

2 A. Yes.

3 Q. Now, did you go to the meeting in Dearborn with

4 Mr. Riddle or separately?

5 A. I believe we were separate.

6 Q. And what happened at the meeting?

7 A. I believe Mr. Riddle may have come in a little late.

8 He came into the meeting. He --

9 Q. How was he dressed at the meeting?

10 A. From what I recall, he had maybe University of Michigan

11 paraphernalia on. I believe he had -- he said he was on his

12 way to the Michigan-Ohio State football game in Columbus, if

13 I'm not mistaken.

14 Mr. Riddle came, he talked about, again, the value

15 of hiring Meridian Management. Meridian Management, again,

16 sort of the accolades of his company and their

17 accomplishments and what he had done in Colorado and in this

18 case what he can do in order to secure Councilwoman Conyers'

19 support or her vote.

20 Q. What did Mr. Riddle say as to whether or not he could

21 secure Mrs. Conyers' vote?

22 A. He told us that by hiring him that her vote could be

23 secured.

24 Q. And how much did he ask for getting her vote?

25 A. $25,000.



116

1 Q. Did Mr. Riddle talk at all as to whether the vote was

2 going to be close or not close?

3 A. He made it clear that she was a swing vote, that the

4 way the council had lined up that, you know, without her

5 vote they would probably not prevail.

6 Q. Now, at the meeting at Andiamo's with Deja Vu did

7 Mr. Riddle say anything about what Mrs. Conyers would do if

8 Deja Vu did not hire Mr. Riddle?

9 A. Well, that we would not get her support and that in

10 fact she could work against us.

11 Q. Did you, based on what Mr. Riddle said, did you take

12 that as a threat?

13 A. Yes.

14 Q. During the meeting at Andiamo's did Mr. Riddle ask

15 about the merits of the transfer of the license from

16 Deja Vu?

17 A. Could you just clarify what you mean by the merits?

18 Q. Did Mr. Riddle ask any questions about what the project

19 would mean or if the club opened in Detroit what would

20 happen or what the benefits of having the transfer of the

21 license would be?

22 A. There may have been just some general discussion about

23 the case, but we didn't get into a lot of detail.

24 THE COURT: Bring the mike a little closer. You

25 are letting your voice drop slightly, please. Thank you.



117

1 BY MR. GARDEY:

2 Q. After Mr. Riddle quoted the price of $25,000 for

3 Ms. Conyers' vote, what was the reaction or what happened at

4 the meeting?

5 A. The gentlemen, they were -- I guess the best word, they

6 were surprised, taken off guard. They, I guess they felt

7 that that was, one, excessive, just buying -- they looked at

8 it as if it was buying a vote.

9 MR. WISHNOW: Objection, Your Honor.

10 THE COURT: No, you can't say what they looked at.

11 The question -- what was your question?

12 BY MR. GARDEY:

13 Q. What was the reaction of the people at Deja Vu to

14 Mr. Riddle's request?

15 A. They were surprised.

16 Q. During the meeting did they agree to hire him or not

17 hire him?

18 A. No, they did not want to hire him.

19 Q. What happened? How did the meeting end?

20 A. Pretty abruptly. They were not supportive of hiring

21 Sam. They didn't want to really continue on with any more

22 dialogue. Sam had his football game to get to and pretty

23 much left out, well, you know, it's, basically, you know,

24 this is it, you know, this is the deal and you take it or

25 leave it.



118

1 Q. Did Mr. Riddle leave at that point?

2 A. Yes.

3 Q. Did you have further discussions with Deja Vu at the

4 Andiamo's Restaurant after Mr. Riddle left?

5 A. Yes.

6 Q. Did you make any proposal to the Deja Vu people

7 regarding Mr. Riddle?

8 A. Well, I saw their discomfort in contracting Sam and so

9 I proposed that Jackson Consulting could hire

10 Meridian Management as a subcontractor, and that would sort

11 of keep their hands clean, if you will, and they would not

12 have any direct involvement with him but that I at that

13 point felt that without hiring Meridian we would not secure

14 Councilwoman Conyers' vote and their transfer would not

15 happen.

16 Q. What did Deja Vu say to your proposal?

17 A. They did not support it.

18 Q. Based on what Mr. Riddle said to you at the meeting at

19 Andiamo's, did you feel that you were being shaken down by

20 Mr. Riddle?

21 A. Yes.

22 Q. And what do you understand, when I say shake down, what

23 do you mean? What do you understand that to mean?

24 A. I was being pressured to have to in one way or another

25 pay the $25,000 in order to get the vote of Councilwoman



119

1 Conyers.

2 Q. Now, after the meeting at Andiamo's with Mr. Riddle and

3 the Deja Vu people, did the license transfer issue come up

4 for a vote in the Detroit City Council?

5 A. Yes.

6 Q. And did that take place on November 15, 2006?

7 A. Yes.

8 Q. And what was the vote?

9 A. The transfer was not approved. It was denied. I

10 believe it was 5 to 4.

11 Q. And how did Mrs. Conyers vote?

12 A. She voted against the transfer.

13 Q. And after the request to transfer the license was

14 defeated, what was your reaction? How did you feel?

15 A. Somewhat dejected, if you will. I had put in a lot of

16 time and effort since September to meet with various council

17 people, meet with the representatives of the Law Department

18 or at least talk to them to lay out the repercussions of not

19 transferring and what in fact was the City's liability.

20 Personally I had invested a lot of time and energy into it,

21 had no retainer from the Deja Vu group or HDV, and so at

22 that point felt that that was a lot of work down the drain.

23 Q. And what impact did the loss of the license or the

24 voting down of the license, what impact did that have on

25 your business for credit card processing?



120

1 A. Well, I could have spent a lot of time going after

2 business in other areas. I had put, had sort of put a lot

3 on the value of potentially securing this as a customer.

4 Q. And if the license had gone through and you had gotten

5 a share of the credit card processing at Deja Vu, would that

6 have been significant financially for you?

7 A. Very lucrative, yes.

8 Q. After the vote of 5-4 at the City Council, did you have

9 further contact with Sam Riddle?

10 A. Yes.

11 Q. What happened?

12 A. Mr. Riddle and I, we met. At that point I had taken it

13 upon myself. I knew that the Deja Vu group did not support

14 hiring him directly. I felt that as far as if they would --

15 if they got the transfer and they didn't have to know all of

16 the details on how it came about and if I hired him as a

17 subcontractor that, you know, everybody would be happy. So

18 I met with Sam Riddle and had agreed to contract

19 Meridian Management, for Jackson Consulting to contract

20 Meridian Management.

21 Q. Now, how was it that after the vote you had this

22 additional meeting with Mr. Riddle about Jackson Consulting

23 hiring Mr. Riddle and Meridian Management?

24 A. Well, I talked to Mr. Riddle. He felt that there was

25 still a way that there could be a reconsideration. There is



121

1 a certain period of time after a vote that a councilperson

2 could reconsider. They could actually put in a letter to

3 the clerk's office for reconsideration and that if in fact

4 that could be a sign, if you will, of certainly his

5 effectiveness in that he could get her to reconsider.

6 Q. And that's what Mr. Riddle offered to do for you?

7 A. Yes.

8 Q. And what price was he asking?

9 A. It was $25,000.

10 Q. And was this soon after the vote in the City Council?

11 A. Yes.

12 Q. Where the license went down?

13 A. Yes.

14 Q. So you agreed to -- did you agree to pay the 25,000?

15 A. No. I told Sam that I would pay him a retainer and I

16 would pay him a success fee. And so we had decided that I

17 would give him the retainer and that if upon -- because the

18 reconsideration was just one piece of it, bringing it back

19 to the table, then once it came back to the table there

20 would be another City Council vote in order to do the

21 transfer.

22 Q. When you say we decided to do a retainer, who is the

23 "we" we are talking about?

24 A. Well, me and Sam, but that was my proposal.

25 Q. And what was the amount of the retainer that you and



122

1 Mr. Riddle agreed to?

2 A. The retainer was $10,000. The success fee would be

3 15,000.

4 Q. And so what was your understanding what you were buying

5 with the $10,000?

6 A. The reconsideration.

7 Q. And how about for the 15,000?

8 A. The successful vote as it relates to the transfer of

9 the license.

10 Q. Did you meet with Mr. Riddle and deliver him those

11 two checks?

12 A. Yes.

13 Q. Where was it that you met him?

14 A. I believe we met at the Click again.

15 THE COURT: Excuse me. You gave him two checks at

16 the same time?

17 THE WITNESS: Yes. One -- I'm not sure if it was

18 post dated, but I told him one was, one actually I put in

19 the memo section was for a retainer, and the other was

20 supposed to be cashed upon the successful vote.

21 THE COURT: Thank you.

22 BY MR. GARDEY:

23 Q. Mr. Jackson, I'm handing you what's been entered into

24 evidence as Government's Exhibit 22B.

25 THE COURT: B?



123

1 MR. GARDEY: 22B as in boy and 22D as in Delta.

2 BY MR. GARDEY:

3 Q. Would you please take a look at those two documents and

4 identify what they are. First 22B.

5 A. 22B is a check from Jackson Consulting Group, L.L.C. to

6 Meridian Management Systems dated 11-16, 2006 for $10,000.

7 The memo section says consulting services retainer.

8 Q. That's down in the lower left-hand corner of the check.

9 And is this the retainer amount that you said was meant to

10 pay for Mrs. Conyers' reconsideration vote?

11 A. Yes.

12 MR. GARDEY: Okay. Could you enlarge the back of

13 the check.

14 BY MR. GARDEY:

15 Q. And what's the, on the back of the check, Mr. Jackson,

16 of the $10,000 check, what's the stamp on the right side of

17 the back of the check?

18 A. It says, "Pay to the order of Comerica Bank, Detroit,

19 Michigan 48207," there is an account number, "For Deposit

20 Only, Meridian Management Systems."

21 Q. And would you please look at 22D as in Delta.

22 A. A check from Jackson Consulting Group, L.L.C. to

23 Meridian Management Systems dated 11-16-06 for $15,000. In

24 the memo section it says, "Consulting."

25 Q. So the $10,000 was for Mrs. Conyers to file for



124

1 reconsideration, and the $15,000 was a success fee if the

2 license transfer actually was voted successfully in the City

3 Council; is that correct?

4 A. Yes.

5 Q. Did you ask Mr. Riddle anything about the second check

6 for $15,000?

7 A. At that time?

8 Q. Yes. Did you ask him to do anything with it or not do

9 anything?

10 A. Yes. I told him that that should be deposited later,

11 anticipating that once the vote had occurred and the

12 councilwoman had supported the transfer then that check

13 would be deposited as a success fee.

14 Q. Now, before you proposed the idea of two separate

15 checks had Mr. Riddle made any -- what did Mr. Riddle want

16 in connection with the 25,000?

17 A. Well, he wanted the whole $25,000.

18 Q. He wanted all 25,000 up front?

19 A. Yes, yes.

20 Q. And before you paid those two checks over to Mr. Riddle

21 did you get approval from Deja Vu in any way?

22 A. No.

23 Q. What happened after you gave Mr. Riddle those

24 two checks?

25 A. I believe later on that day there was a letter that



125

1 went into the city clerk's office from Councilwoman Conyers

2 for the reconsideration of the transfer. So that's my

3 understanding to get it back onto the docket for Council to

4 vote.

5 Q. Mr. Jackson, I'm handing you Government's Exhibit 23.

6 Would you please take a look at that and state what it is.

7 A. "Memorandum to Janice M. Winfrey, City Clerk, from

8 Council President Pro Tem Monica Conyers, date November 17,

9 2006, regarding reconsideration of vote on resolutions A and

10 B on the petition of HDV-Greektown, L.L.C. (Petition Number

11 1392) to transfer ownership with dance entertainment and

12 topless activity permit from K & P, Inc. at 414 E.

13 Congress."

14 Q. Mr. Jackson is this the reconsideration that you spoke

15 about?

16 A. Yes.

17 Q. And based on your experience as a chief of staff for

18 City Council, what was your understanding of how

19 reconsideration would work and who could bring such a

20 request?

21 A. My understanding was that a reconsideration could only

22 take place by someone on the prevailing, the winning side.

23 So if you wanted to reconsider within the period of time

24 that is allowed for reconsideration that you would notify

25 the City Clerk in writing of your intention or your intent



126

1 to reconsider in writing.

2 Q. And the, this notice of reconsideration, it's not

3 necessarily a declaration that the person is going to change

4 their vote, just that they are going to reconsider; is that

5 correct?

6 A. Yes.

7 Q. Did Mr. Riddle say anything to you about the

8 reconsideration filed by Mrs. Conyers?

9 A. He told me that, that that certainly would show some

10 good will as relates to the consulting fee, and it also

11 showed that Meridian Management could follow through on what

12 it promised.

13 Q. During your discussions with Mr. Riddle right after the

14 vote when you were giving him the checks, did Mr. Riddle

15 ever suggest that he was ever going to try to get other City

16 Council members besides Mrs. Conyers to change their vote?

17 A. No.

18 Q. Was there any doubt in your mind, Mr. Jackson, you were

19 paying Mr. Riddle for Monica Conyers' vote?

20 A. No.

21 Q. Other than your payment of the two checks, $10,000 and

22 $15,000, was there anything else that occurred in connection

23 to Deja Vu and the issue before the City Council before

24 Mrs. Conyers filed her notice of reconsideration?

25 A. Can you clarify as far as what may have occurred? I'm



127

1 sorry.

2 Q. Was there any -- before she filed for reconsideration

3 were there other meetings of the City Council or were there

4 other presentations?

5 A. No.

6 Q. After she filed the notice of reconsideration was there

7 another meeting of the Detroit City Council?

8 A. No.

9 Q. After the reconsideration?

10 A. Yes.

11 Q. And what happened at that meeting?

12 A. At that meeting there were a number of people from the

13 community, a number of very prominent ministers, members of

14 their congregation.

15 Q. Were you present for that meeting?

16 A. Yes.

17 Q. And what was the purpose of that meeting in the City

18 Council?

19 A. The purpose of that meeting was to take up the

20 reconsideration and to have a new vote.

21 Q. And did that meeting take place the day after

22 Mrs. Conyers filed for reconsideration?

23 A. I'm not sure if it was the day after or two days after.

24 I'm not sure of the exact date.

25 Q. Soon thereafter?



128

1 A. Yes, sir.

2 Q. Now, you said that pastors and other people appeared

3 before the City Council. What happened?

4 A. They were allowed to testify and speak at the Council,

5 to give testimony as relates to their disapproval of any

6 reconsideration. They were happy that the transfer had been

7 denied previously, and they wanted that vote to stand. They

8 had moral objections to a cabaret D license, and they

9 pressed those objections at that meeting.

10 Q. Is it fair to say there was political opposition to

11 providing a license to Deja Vu?

12 A. Yes.

13 Q. And during the meeting how did Mrs. Conyers react?

14 A. Mrs. Conyers appeared to be very intimidated. She was

15 not willing to or did not interact very much with the

16 ministers. She didn't say very much at that meeting. She

17 didn't -- of course, a lot of the testimony was directed at

18 her because she was the councilperson who had actually asked

19 for the reconsideration.

20 Q. And at the -- what happened with Mrs. Conyers at the

21 end of that meeting? What happened?

22 A. At the end of the meeting either it was Mrs. Conyers or

23 another councilperson, I believe it was her, asked that the

24 matter be tabled.

25 Q. And what does that mean?



129

1 A. Tabled. They were -- I believe it was the last meeting

2 before council was to recess for the year, and tabled means

3 that the matter is no longer -- will not be taken up, that

4 the vote will not be taken and it was tabled until next year

5 or until the following year.

6 Q. And so because the matter was tabled in the City

7 Council that meant that there would be no actual revote on

8 the issue of the license transfer for Deja Vu until January

9 of 2007; is that correct?

10 A. That's correct.

11 Q. And for your purposes what did that mean, what impact

12 did that have on the Deja Vu project and the effort to

13 transfer the license by a method other than litigation?

14 A. That meant that it was dead, that they had no option

15 but to pursue or move forward with the litigation.

16 Q. How did you react about what happened at this

17 second City Council meeting?

18 A. Well, I had hired a consultant to assist in securing

19 the vote of the councilperson who had reconsidered,

20 Monica Conyers. He was not there at the meeting. Found out

21 that he later was not even in town. He was in Saginaw or

22 Flint or somewhere. That was the explanation given to me,

23 and so I felt that I did not get the value of the money that

24 I spent.

25 Q. You didn't get your vote?



130

1 A. No.

2 Q. After that did you take any action in connection to the

3 success fee, the $15,000 check?

4 A. Yes.

5 Q. What did you do?

6 A. And I should say I got the value of my $10,000, but I

7 didn't get the value or did not warrant the $15,000 success

8 fee because there was no success.

9 Q. What did you do in connection with the $15,000 check?

10 A. I put a stop payment.

11 Q. You put a stop payment on it with your bank?

12 A. Yes.

13 Q. And you didn't, you didn't do that with the $10,000

14 check because -- did you do that -- you didn't do that with

15 the $10,000 check because you felt you got your vote for

16 reconsideration from Mrs. Conyers?

17 A. Yes.

18 MR. GARDEY: Just one moment, Your Honor.

19 The government has one brief matter to bring up at

20 side bar.

21 (At side bar on the record out of the hearing of

22 the jury, as follows:)

23 MR. GARDEY: Judge, moments before Mr. Jackson

24 took the stand Mr. Wishnow gave me this document. It's a

25 letter of agreement for professional services.



131

1 MR. WISHNOW: I'm sorry.

2 MR. GARDEY: And this is a document we have never

3 seen before and had not been produced by the defense and we

4 had asked them to produce any documents that they intended

5 to use as exhibits.

6 THE COURT: Do you propose to use this?

7 MR. WISHNOW: Actually we are not sure. I'm going

8 to see how the cross develops. We may not.

9 THE COURT: Oh, no, you can't use this. You had

10 an obligation to deliver this in advance. We talked about

11 that. You can't sandbag him that way.

12 MR. WISHNOW: Well, Judge, this is a criminal

13 trial. It's not a civil trial where the discovery is

14 required, and we are allowed some leeway in providing --

15 THE COURT: You are not allowed that much leeway,

16 Mr. Wishnow. You are not allowed that much, Mr. Wishnow. I

17 think this record will reflect both formally and informally

18 the Court telling you to produce your exhibits. As a matter

19 of fact, the last conference we had shortly before, I don't

20 know that it's reflected, but you knew this.

21 MR. WISHNOW: The objection is noted. We'll move

22 forward.

23 THE COURT: What?

24 MR. WISHNOW: We'll move forward.

25 THE COURT: I haven't read it. I don't know what



132

1 its significance is.

2 MR. WISHNOW: You don't have to.

3 THE COURT: All right.

4 (End of discussion at side bar.)

5 MR. GARDEY: No further questions, Your Honor.

6 THE COURT: Cross-examine.

7 MR. WISHNOW: Thank you.

8 THE COURT: Can I see you back here one moment?

9 Never mind. Go ahead. I changed my mind. The

10 judge always has that privilege, except at home.

11 Go ahead.


13 - - -

14 CROSS-EXAMINATION

15 BY MR. WISHNOW:

16 Q. Good morning, Mr. Jackson. My name is Edward Wishnow.

17 I'm one of Sam Riddle's attorneys. How are you?

18 A. Good morning. I'm sorry, what's your name sir?

19 Q. Edward Wishnow.

20 A. Wishnow. Good morning.

21 Q. Sir, after leaving common council, you started many

22 businesses, including Jackson Consulting, correct?

23 A. Yes.

24 Q. And you have indicated that your primary area of

25 interest and expertise was in the finance sector?


Christopher Jackson - CrossWednesday/January 27, 2010/Volume 3

133

1 A. Yes.

2 Q. In fact, you were involved in putting together the

3 Greektown Casino deal?

4 A. Yes.

5 Q. And your group, I think it's called Monroe Partners?

6 A. Yes.

7 Q. Became a significant -- had a significant ownership

8 interest in that casino, correct?

9 A. Yes.

10 Q. Anything you've done in the financial sector with

11 clients or prospective investors usually involves some type

12 of, well, not usually, always involves some type of written

13 contract, does it not?

14 A. Yes.

15 Q. In this particular situation when you were approached

16 by Deja Vu representatives you did not have a written

17 contract with them, did you?

18 A. I presented one to them.

19 Q. You presented a contract to them?

20 A. Yes.

21 Q. And they refused to sign it?

22 A. It was being negotiated, never was signed.

23 Q. And did that contract ask that you would receive some

24 type of up front fee?

25 A. I can't recall the exact details of the contract.



134

1 Q. But it most likely did require some up front fee,

2 correct?

3 A. Yes.

4 Q. Pardon?

5 A. Possibly. There would be a retainer involved.

6 Q. You don't remember the amount of the retainer involved,

7 correct?

8 A. No.

9 Q. But they didn't want to pay that, correct?

10 A. They gave me a counter to my contract.

11 Q. And their counter was instead of some up front money

12 some possible reward for you later on by buying into their

13 business?

14 A. As well as sharing in or having access to ATM machine

15 or some credit card processing business.

16 Q. Well, at some point they told you they weren't

17 interested in giving you a piece of the ATM pie; isn't that

18 correct?


20 Q. Because that was a very significant revenue stream for

21 them?

22 A. They had already contracted with or already had a

23 relationship with some other entity.

24 Q. And there was some interest possibly in allowing you to

25 get involved in the credit card processing business?



135

1 A. Yes.

2 Q. And you already had such a business, did you not?

3 A. Yes.

4 Q. You indicated that at one point you did meet with

5 Sam Riddle and your first meeting directly with him was at

6 the Click Restaurant on East Jefferson?

7 A. That would have been the second meeting.

8 Q. After the meeting in chambers, I'm sorry.

9 A. Yes.

10 Q. And that, you understood, was held outside the office

11 because he was there in his role as a consultant with

12 Meridian Management?

13 A. The second meeting was held outside the office.

14 Q. Yes.

15 A. Yes.

16 Q. And he was there, as you understood it and as he

17 explain to you, as a consultant with Meridian Management?

18 A. At the second meeting, yes.

19 Q. Correct, at the second meeting at Click?

20 A. Yes.

21 Q. At some point was a contract submitted to you?

22 A. I recall that there was a contract, something from

23 Meridian Management. I don't actually have it, but I

24 believe there was something emailed to me or either given to

25 me.



136

1 Q. And that, unlike the contract you attempted to have

2 with HDV/Deja Vu, that contract was not signed, was it?

3 A. No.

4 Q. That contract that was sent to you from Sam Riddle had

5 a no conflicts provision in it?

6 A. I don't recall. L I don't recall. I don't remember

7 the contract.

8 Q. You didn't give it much thought or you just don't

9 recall now?

10 A. I just don't recall.

11 Q. You did not know Sam Riddle very well before your

12 meeting with him, correct?

13 A. No, I did not.

14 Q. But you certainly knew of him and that he is a,

15 certainly was a well-known media consultant, a PR person?

16 A. I knew of him. I didn't know exactly what his vocation

17 was. I knew of him through the media and through other

18 people in general.

19 Q. And did you know that he was involved in

20 Monica Conyers' campaign?

21 A. Yes.

22 Q. That he was involved in the campaigns of others?

23 A. I was more familiar with his campaign with

24 Monica Conyers.

25 Q. And at your meeting with him he gave you information



137

1 about himself and Meridian, did he not?

2 A. Yes.

3 Q. Somewhat touting all the good things that he had done

4 during his career as a consultant?

5 A. Yes.

6 Q. And some of those were incidents that you were well

7 aware of, such as Columbine, correct?

8 A. Yes.

9 Q. And you knew those, you believe those to be true, that

10 he was involved with those instances?

11 A. Oh, I had no idea if he actually, he himself was

12 involved. He shared with me that he was. I had, I had no

13 idea who was representing the family members and that kind

14 of thing.

15 Q. And as we sit here today you have no reason to

16 disbelieve that, do you?

17 A. No.

18 Q. Before you met with Mr. -- Meridian and Mr. St. John

19 and Mr. Hall at the Andiamo in Dearborn did you have a

20 second meeting with him at your office?

21 A. With who?

22 Q. Just Sam Riddle and yourself at your office.

23 A. I could have. I'm not sure.

24 Q. You could have?

25 A. Yeah.



138

1 Q. And would the terms of his engagement with you have

2 been discussed at that time?

3 A. Possibly.

4 Q. And would he -- do you -- well, when you met with him

5 at the Click Restaurant did he discuss with you that he was

6 there acting as a consultant pursuant to

7 Meridian Management?

8 A. Yes.

9 Q. Did you, yourself, tell Mr. Riddle to come to the

10 meeting at the Andiamo's Restaurant?

11 A. I can't recall exactly how the invitation took place.

12 Q. Did you tell him who would be there?

13 A. Oh, I told him the representatives of Deja Vu would be

14 there, yes.

15 Q. Okay. Did you tell either Mr. St. John or Mr. Hall

16 that Sam Riddle would be coming to the meeting at the

17 Andiamo's Restaurant?

18 A. Yes.

19 Q. So they expected that he would be there?

20 A. Yes.

21 Q. And did you explain to them that he was a consultant

22 and had a company called Meridian Management?

23 A. Yes.

24 Q. At some point you became rather upset because you had

25 expended some monies and had not gotten anything out of



139

1 Deja Vu, correct?

2 Well, let me put that in context, excuse me.

3 Before you gave your $10,000 check to Sam Riddle,

4 by that time you had expended significant time and energy

5 into trying to help out Deja Vu Consulting, correct?

6 A. Yes.

7 Q. And up until then you had not received any

8 reimbursement, I mean you hadn't received any compensation

9 for your services, correct?

10 A. Yes.

11 Q. And that concerned you, did it not?

12 A. Yes.

13 Q. I mean you are a businessman, your time is valuable,

14 correct?

15 A. Yes.

16 Q. You, on your own, decided that you would pay $10,000 to

17 Mr. Riddle, correct?

18 A. Yes.

19 Q. And that check was made out to Meridian Management, and

20 on the memo line it stated "consulting," correct?

21 A. Retainer. Consulting retainer, correct.

22 Q. And a second check the same day for $15,000 also made

23 out to Meridian?

24 A. Yes.

25 Q. During your meetings with Mr. Riddle he explained to



140

1 you, did he not, why a consultant would be important in

2 dealing with a strip club that was trying to locate in

3 downtown Detroit?

4 A. Yes.

5 Q. And you accepted those reasons and they were valid,

6 were they not?

7 A. I accepted the reasons that a consultant was needed.

8 Q. And I think you have touched upon some of those; that's

9 not a popular business, there are a lot of what you

10 characterized as gray areas, and government intervention

11 could be of help?

12 A. You say government intervention could be of help?

13 Q. Yes.

14 A. That is not something that I was -- I was getting the

15 services of a nongovernmental entity, Meridian Management.

16 Q. No, but your -- excuse me. Let me be more precise.

17 A consultant of yours could intervene with

18 governmental bureaus and departments in this type of

19 context, correct?

20 A. That's what was being sold to me in what the services

21 of Meridian Management could do, yes.

22 Q. But you understood the context within which this

23 consulting services was being offered, that is, the context

24 of a strip club being located downtown?

25 A. I was hiring Meridian Management to assist in getting



141

1 Monica Conyers' vote for the transfer.

2 Q. Sam Riddle though discussed with you, did he not, that

3 his consulting services could help with other areas involved

4 with a strip club in downtown Detroit?

5 A. After a vote would be taken if they were to get a

6 transfer that Meridian Management services would also be

7 needed for other governmental type things because, because

8 of the gray areas, because of the potential for getting

9 tickets and other types of --

10 Q. Issues such as liquor licenses, police involvement,

11 zoning issues, correct?

12 A. Yes.

13 Q. And you are familiar in your term of government with

14 the City Council that those type of issues come up with any

15 type of bar establishment, let alone a cabaret or topless

16 entertainment facility, correct?

17 A. Yes.

18 Q. And you, because of your role in the financial sector,

19 you had little interest in getting involved in that type of

20 what apparently you believe are somewhat tawdry sectors of

21 business?

22 A. Well, as a correction, I never pass any disparaging --

23 I don't look at that business as tawdry or anything. It was

24 just not an area that I focused on. I focused on financing.

25 Q. Okay. But Mr. Riddle explained to you that this was an



142

1 area that he could work in and would feel comfortable in

2 working, correct?

3 A. Yes.

4 Q. And before you went to Andiamo's, before the meeting at

5 Andiamo's did you explain to Mr. St. John and Mr. Hall that

6 Mr. Riddle could be a valuable consultant in these so-called

7 gray areas with government as far as a strip club in

8 downtown Detroit?

9 A. I don't recall having that conversation with them.

10 Q. You may have had that discussion with them, correct?

11 A. My conversation focused more on the transfer of the

12 license, securing the support and the vote to transfer the

13 license.

14 Q. So that's what you told St. John and Hall, correct?

15 A. That was the focus, yes.

16 Q. Okay. Knowing that, they came to this meeting in

17 Dearborn, correct?

18 A. Yes.

19 Q. And then when it came to money, that is, for them to

20 pay Mr. Riddle, they balked at that, they wouldn't do that?


22 Q. In the same manner that they didn't want to pay you any

23 money, correct?

24 A. No, they did not balk at it in the same manner, no.

25 Q. But they didn't want to pay you any money up front



143

1 either, did they?

2 THE COURT: I think those are argumentative

3 questions.

4 MR. WISHNOW: Thank you, Your Honor. I'll move

5 on.

6 THE COURT: They have to be reformulated.


8 BY MR. WISHNOW:

9 Q. They did not want to pay you up front money either, did

10 they?

11 A. I don't recall them saying actually they did not. We

12 did not reach an agreement on any of this.

13 Q. Well, you had asked for up-front money as part of your

14 initial contract proposal to them for you, for

15 Jackson Consulting?

16 A. I believe there was a retainer made, yes.

17 Q. Ultimately you said that when the vote came up for

18 reconsideration there was community opposition, correct?

19 After November 17?

20 A. After the reconsideration?

21 Q. Yeah. The vote came up for --

22 A. Yes.

23 Q. When the vote came up again after the letter for

24 reconsideration was submitted that there was community

25 opposition?



144

1 A. Yes.

2 Q. And Monica Conyers, you believe, tabled that vote?

3 A. I'm not sure if it was her or one of her colleagues.

4 Q. But you were at that meeting?

5 A. The vote was tabled.

6 Q. You were at that meeting?

7 A. Yes. I was in and out of the room, but yes, I was

8 there.

9 Q. Okay. And you did not see Monica Conyers vocally favor

10 a vote in favor of Deja Vu, did you?

11 A. No. They didn't vote.

12 Q. And she took no strong position in favor of Deja Vu,

13 did she?

14 A. No.

15 Q. And that action on her part would have been detrimental

16 to her financial situation if she was going to get part of

17 the $15,000; isn't that correct?

18 THE COURT: That question is argumentative.

19 THE WITNESS: I don't know.

20 MR. WISHNOW: I can ask the opinion of this

21 witness, Your Honor.

22 THE COURT: I said the question is argumentative.

23 MR. WISHNOW: Thank you, Your Honor.

24 If I could have one moment.

25 THE COURT: You may.



145

1 BY MR. WISHNOW:

2 Q. Sir, when you worked with Gil Hill, who was a

3 councilman and a council president, were you a full-time

4 employee?

5 A. Yes.

6 Q. And did that cover -- did you have fringe benefits on

7 that job?

8 MR. GARDEY: Objection, Your Honor, relevance.

9 THE COURT: What is the arguable relevance of what

10 his remuneration was in the 1990's when he was working?

11 MR. WISHNOW: Because he gave an opinion earlier

12 as to what he thought was a conflict of interest of someone

13 working for the City government. We have evidence in --

14 THE COURT: No, no, no, no. I'm sustaining the

15 objection.

16 MR. WISHNOW: Your Honor, we have evidence that --

17 THE COURT: I said I have sustained the objection,

18 but he can answer.


20 THE COURT: Did you get fringe benefits when you

21 worked for Hill?

22 THE WITNESS: I had different arrangements over

23 the course of the seven years, so it depends on what period

24 of time.

25 THE COURT: Okay.



146

1 BY MR. WISHNOW:

2 Q. Did you work for close to 2,000 hours a week like a

3 normal work year?

4 A. You said 2,000 hours --

5 Q. Hours.

6 A. -- a week?

7 Q. No. Did you have an arrangement where you worked a

8 normal work year, about 2,000 hours if you had two weeks off

9 or thereabouts?

10 A. Yes.

11 MR. WISHNOW: Okay. Thank you.

12 MR. GARDEY: No further questions, Your Honor.

13 THE COURT: The witness is excused.

14 Do you want to start with another witness or wait

15 until Friday morning?

16 MR. GARDEY: We have Agent Lubisco just to have

17 short testimony about Deja Vu.

18 THE COURT: Would you wait in back a few minutes.

19 THE WITNESS: Yes.

20 THE COURT: Thank you.

21 Go ahead.

22 MR. GARDEY: The United States calls Special Agent

23 Mike Lubisco.

24 - - -

25


Michael Lubisco - DirectWednesday/January 27, 2010/Volume 3

147

1 DIRECT EXAMINATION

2 BY MR. GARDEY:

3 Q. Agent Lubisco, in the course of the investigation did

4 you gather bank records concerning the Deja Vu scheme?

5 A. Yes, I did.

6 Q. Did those bank records include the records for Meridian

7 Management, an account at Comerica controlled by Sam Riddle?

8 A. Yes, they did.

9 Q. Agent Lubisco, I'm handing you what's been marked and

10 entered into evidence as Government's Exhibit 22C and 22E.

11 Would you please identify those. First 22C.

12 A. 22C is a deposit into the Meridian Management account

13 on 11-16-06, and it is for $10,000.

14 Q. What's the date on 22C of the deposit?

15 A. 2C is -- it's 11-17-06.

16 Q. And what was 22E?

17 A. 22E is also a deposit into the Meridian Management

18 account. It's on November 27th, 2006, and it is for the

19 amount of $15,000.

20 Q. And is the name of Sam L. Riddle also on the deposit

21 slip?

22 A. Yes, it is. Samuel L. Riddle, Jr.,

23 Meridian Management.

24 Q. Agent Lubisco, I am handing you what's been marked

25 Government's Exhibit 22A. Would you please state for the



148

1 record what that is.

2 A. It's a copy of a statement from Comerica Bank for

3 Meridian Management Systems. It's for November 1st, 2006 to

4 November 30, 2006.

5 Q. Would you turn to the second page of Exhibit 22A,

6 please, and under the deposits.

7 A. The bank account shows two deposits, one on

8 November 17th for $10,000, one on November 27th for $15,000.

9 Q. And were there also earlier deposits for $10,000 on

10 November 8 and 400 on November 1st?

11 A. Yes, there is.

12 Q. Was there anything else reflected on this statement

13 concerning the November 27 $15,000 deposit?

14 A. That on Page 3 is a returned item chargeback, meaning

15 $15,000 was taken out of the account.

16 Q. Any understanding as to why 15,000 would be charged

17 back on this account?

18 A. Because there was a stop payment placed on the check.

19 Q. Are there any cash withdrawals reflected on

20 Mr. Riddle's bank statement for November of 2006?

21 A. There are three withdrawals: The first one on

22 November 9th for $4,000; the second on November 20th for

23 2500; and then on November 27 also for 2500.

24 MR. GARDEY: Just one moment, Your Honor.

25 No further questions, Your Honor.



149

1 THE COURT: Cross.

2 MR. WISHNOW: Oh, I'm sorry. No questions,

3 Your Honor.

4 THE COURT: Thank you. The witness is excused.

5 MR. GARDEY: Your Honor, our next witness was

6 going to be Agent Lubisco concerning a different scheme,

7 and --

8 THE COURT: I think we should start Friday

9 morning.

10 MR. GARDEY: Thank you.

11 THE COURT: Between now and then keep your eyes

12 open, your ears closed, your mouths shut. Don't talk to

13 anyone about it, don't let anyone talk to you about it.

14 I'll see you Friday morning at 9:00. Also, don't Google.

15 Everyone will sit down, please, back there.

16 Just leave your stuff on your chair. You don't

17 have to haul it in and out.

18 (Jury out at 12:40 p.m.)

19 THE COURT: You can sit down. We'll just wait

20 until the jury clears the floor.

21 We'll meet tomorrow morning at 10:00, and it would

22 be helpful if you had a draft in the jury instructions, I

23 don't care where you are in your negotiations, but a draft

24 and the verdict form.

25 Ms. Altman has a memo, a copy, on 5401 if you want


Chris Jackson Testimony

Documents

Transcript of Chris Jackson Testimony