Onstot, Lynn | Testimony transcript

Transcript of the Testimony of Lynn Onstot

Date: December 17, 2013Volume: I

Case: In Re: Joplin Critical Investigation

Printed On: December 27, 2013

Holliday Reporting Service, Inc.Phone: 417-358-4078

Fax: 417-451-1114Email:[email protected]

Internet:

Lynn Onstot In Re: Joplin Critical Investigation

417-358-4078

Holliday Reporting Service, Inc.

Page 1

IN RE: JOPLIN CRITICAL INVESTIGATION

SWORN STATEMENT OF

LYNN ONSTOT

Taken on Tuesday, December 17, 2013, from 3:07 p.m. to 3:41

p.m., at the law offices of Juddson H. McPherson, LLC, 626

S. Byers, in the City of Joplin, County of Jasper, State of

Missouri, before

SHARON K. ROGERS, C.C.R.650,

a Certified Court Reporter and a Notary Public within and

for the County of Jasper, and State of Missouri.


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APPEARANCES

MR. THOMAS E. LORAINE

Loraine & Associates, LLC

4075 Osage Beach Pkwy., Suite 300

Osage Beach, MO 65065

[email protected]


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S T I P U L A T I O N

IT IS HEREBY STIPULATED AND AGREED that this Sworn

Statement may be taken by steno-mask type recording by

SHARON K. ROGERS, a Certified Court Reporter, and

afterwards reduced into typewriting.

It is further stipulated that the signature of the

witness is hereby waived, and that said Sworn Statement of

said witness shall be of the same force and effect as

though said witness had read and signed Sworn Statement.


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I N D E X

Page/Line

DIRECT EXAMINATION BY MR. LORAINE . . . 6-19

E X H I B I T S

Exhibit #A. . . . . . . . 6-8

Advice of Rights

Note: Exhibits in separate binder

(sic) - typed as spoken

(ph.) - phonetic


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1 BY MR. LORAINE:

2 Q. Ms. Onstot, I'm going to read the Advice of

3 Rights. I know you've already read it, but

4 it says in here I need to read it to you so

5 I'm going to read it to you. "I wish to

6 advise you that you are being questioned as

7 part of an official investigation by the City

8 of Joplin. You will be asked questions

9 related and specifically directed to the

10 performance of your official duties or

11 fitness for office. You are entitled to all

12 the rights and privileges guaranteed by the

13 laws and the Constitution of the State and

14 the Constitution of the United States,

15 including the right not to be compelled to

16 incriminate yourself. I further wish to

17 advise you that if you refuse to testify or

18 to answer questions relating to the

19 performance of your official duties, you will

20 be subject to departmental charges, which

21 could result in your dismissal from your

22 official duties. If you do answer, these

23 statements may be used against you in

24 relation to subsequent departmental charges,

25 but not in any subsequent criminal


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1 proceedings. I have read and fully

2 understand the Advice of Rights as it appears

3 above. This information has also been read

4 to me prior to answering any questions." Did

5 you understand that?

6 A. I did. Thank you.

7 Q. And you did, in fact, now execute your name

8 to this document, Exhibit #A?

9 A. Yes, I did.

10 Q. And you did print your name next to your

11 signature?

12 A. Yes.

13 Q. And I'm witnessing it with your permission.

14 A. Yes.

15 Q. Did you swear her in yet?

16 LYNN ONSTOT

17 Having been first duly sworn and examined,

18 testified as follows:

19 DIRECT EXAMINATION BY MR. LORAINE:

20 Q. All right. You've been sworn in to tell the

21 truth. You're under advice for the

22 investigation. This is not about you and

23 it's not concerning you, and it's the same

24 procedure we've followed with every person I

25 have talked with with the City, it's just


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1 part of the procedure, okay?

2 A. Okay.

3 Q. I have no interest in having anything about

4 you, I just want information from you.

5 A. Okay.

6 Q. What is your name and position for the

7 record?

8 A. My name is Lynn Onstot and my position is

9 Public Information Officer for the City of

10 Joplin.

11 Q. How long have you been a Public Information

12 Officer?

13 A. I started in '03 so ten years, almost eleven.

14 Q. And what does a Public Information Officer

15 do?

16 A. I'm responsible for communications to general

17 audiences such as the public, news media, as

18 well as coordinating news media interviews

19 and external communications such as that.

20 Q. I notice that you said newspaper. Would it

21 be if the City had information to be placed

22 in the newspaper that you would be the person

23 to do that?

24 A. Well, I don't take care of advertisements or

25 those things, I don't do that. Mine is the


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1 general information news releases, things of

2 that nature. Corresponding to them, working

3 with as far as the written word, yes. Now I

4 also coordinate with the newspaper to set up

5 interviews for other people to speak directly

6 with them.

7 Q. So would it be fair to say that all official

8 contacts from the City really should be as

9 far as information on behalf of the City

10 regardless of who it is should be run through

11 your office when it comes to a newspaper?

12 A. That was the policy, yes.

13 Q. And that remains the policy, isn't it?

14 A. As I understand it, yes.

15 Q. Have you had exceptions to that policy?

16 A. Yes, it seems after the disaster, obviously

17 in 2011 in May as you know we suffered a

18 tornado, there was a lot of news media in

19 town and contacting us with all sorts of

20 aspects and they were able to coordinate or

21 contact rather directly with some

22 individuals.

23 Q. Who would be those individuals?

24 A. It wasn't necessarily an allowance, it was

25 just who they got to. Ideally we were trying


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1 to coordinate any critical information such

2 as the death count and things of that nature

3 through my office. Of course in that

4 situation you also want to clear it through

5 the City Manager's office as well as the

6 attorney's office.

7 Q. You've mentioned at least three offices,

8 yourself, the City Attorney, and City

9 Manager?

10 A. In the disaster stage, yes. In regular

11 stages typically when I release information

12 it goes through the City Manager's office for

13 approval.

14 Q. And are you part of the City Manager's

15 overall supervisory --

16 A. Yes, I'm part of his staff.

17 Q. Okay. So you are part of the staff. So the

18 City Manager when he has communications to

19 release should he go through you?

20 A. He has worked with me, yes. We typically

21 have them working directly to send

22 information. There are times where he is

23 directly contacted and he responds directly

24 to them and I am not involved.

25 Q. Are those only under emergency conditions or


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1 does he just not follow the policy?

2 A. I believe he has contacted them directly,

3 yes.

4 Q. Do you have any reason to explain why he

5 would do that in contradiction to the policy

6 of the City?

7 A. Other than a matter of convenience and

8 timeliness, that would be the reasons I

9 believe it would be done, but I don't know

10 why, you know, he would have to answer that

11 question.

12 Q. There has been discussion in the City Council

13 about certain information allegedly

14 concerning Councilman Scearce that was

15 communications directly between the City

16 Manager and the newspaper editor.

17 A. Uh-huh.

18 Q. Do you have any knowledge about that or why

19 that came about directly without involving

20 your office?

21 A. No, I do not.

22 Q. In fact, it should have involved your office,

23 don't you believe?

24 A. It was not a news inquiry made into my office

25 so I was not aware of the situation at that


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1 time.

2 Q. You would likely be or should be made aware

3 of a situation that would be critical like

4 that I mean because here I am and the whole

5 thing has now resulted in probably tens of

6 thousands, and maybe hundreds of thousands of

7 dollars over this matter and I'm just

8 wondering why normal procedures would not

9 have been followed. Do you have any excuse

10 for that?

11 A. No, I do not. I did not know about it until

12 Bill Scearce called the press conference.

13 Q. So do you have any personal information about

14 the alleged note that Bill Scearce was given

15 or how he acquired it?

16 A. I was told it was found on the floor.

17 Q. Who told you that?

18 A. Brian Head.

19 Q. Did Brian Head tell you who had found the

20 note?

21 A. He said he found it.

22 Q. He found it?

23 A. Uh-huh.

24 Q. Okay. So as far as you know there was no

25 official communication through the


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1 appropriate source as to contact with the

2 newspaper editor for any matters involving

3 that incident?

4 A. No.

5 Q. Are you aware of when Mr. Steve Cope, his

6 office was accused of some wrongdoings?

7 A. I was brought in when there were going to be

8 some staff changes, yes, and we had to

9 address that in the public's eye.

10 Q. Wasn't there already a leak to the newspaper

11 prior to that?

12 A. I can't recall the order of activities, but

13 that is not unusual for the media to have

14 information sometimes before my office does.

15 Q. And the only place that information would

16 come from would be the City Manager, isn't

17 that true?

18 A. It depends on who all knows it. It just

19 depends. I'm not really sure how that

20 information could get there. There's a

21 variety of different - again in each

22 circumstance it depends on which party is

23 involved, what parties are involved, and what

24 the relationship is with the news media.

25 Q. Well, I understand the information that was


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1 released was that Mr. Cope and several other

2 engineers above him were actually accused of

3 stealing from the City hundreds of thousands

4 of dollars. Is that generally your

5 knowledge?

6 A. Well, I don't know if the accusation of theft

7 was made at that time. Wrongdoing and

8 clerical errors and a lack of supervision of

9 his own staff and deposits and things like

10 that was what I understood to be done since

11 there was a police investigation I know

12 because of those errors.

13 Q. Now the police investigation, would that have

14 occurred prior to your receiving information

15 from outside sources back?

16 A. Sometimes there would be, you know, on

17 internal matters sometimes the police may get

18 involved before any information is released

19 to the public. In this case we did release

20 information to the public and then after that

21 a police investigation was discussed.

22 Q. Who released the information that money was

23 missing from the City?

24 A. It came through a news release from my

25 office.


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1 Q. And who was responsible for the contents of

2 that?

3 A. I was working with Assistant City Manager Sam

4 Anselm and City Manager Mark Rohr.

5 Q. So the information about whether there was

6 money missing or whether or not there had

7 just been improper billing or whether or not

8 there was clerical errors you didn't have any

9 inside information on that at all, did you,

10 personally?

11 A. No.

12 Q. So whatever information was released came

13 from either the City Manager or the Assistant

14 City Manager?

15 A. Yes, they provided me with the information

16 and asked me to craft a news release in

17 relationship to that.

18 Q. And they gave you specific directions on what

19 to say?

20 A. Yes.

21 Q. Is that normal procedure that the City

22 Manager or the Assistant City Manager

23 actually tell you what to release, or are you

24 normally at liberty to develop the form of

25 the press release?


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1 A. In general matters such as parks and

2 activities, parks openings, activities,

3 things of that nature that are general

4 knowledge I usually work with the department

5 heads. In this matter since it was a City

6 Manager issue, so to speak, he was handling

7 it, it came directly from him working as the

8 department head, per se.

9 Q. And as a result of that one of the engineers

10 was demoted, wasn't he?

11 A. Yes, he was.

12 Q. And who was that?

13 A. That was David Hertzberg.

14 Q. And did you ever talk with Mr. Hertzberg

15 about his knowledge of why all this happened?

16 A. I'm trying to recall.

17 Q. I mean prior to issuing any statements.

18 A. Oh, prior to? No.

19 Q. What about Mr. Cope?

20 A. I know Mr. Cope was on our floor quite a bit

21 and he was very frustrated, but I did not

22 know to the nature of what it was.

23 Q. So would it be fair to say that there was no

24 input from any other City employee other than

25 the City Manager or the Assistant City


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1 Manager directly you what to say about that?

2 A. No. Yeah, there was no other involved.

3 Q. No other involved?

4 A. Uh-huh.

5 Q. So no chance for exchange of information

6 between any of the other parties?

7 A. No.

8 Q. It seems like sensationalism to me, but I

9 mean I would normally think that a gatherer

10 of facts would gather the facts.

11 A. Right. Let me back up a little bit. Brian

12 Head I believe during that time was on

13 vacation or was out of the office, I'm not

14 sure what the nature of his absence was, but

15 Peter Edwards, our Assistant City Attorney

16 was also in the room a couple of times we

17 discussed the press release.

18 Q. Did he contribute anything?

19 A. He worked very closely in the wording, to be

20 careful of how we worded it, yes.

21 Q. In the wording it actually pretty well - I

22 mean I don't have that in front of me right

23 now, but I have read it. It's pretty

24 accusatory as I read it. Do you agree with

25 that?


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1 A. Yes, it was pretty strong.

2 Q. Let me ask you this question. Have you ever

3 seen the note between the City Manager that

4 was allegedly taken from some information

5 over the phone?

6 A. No.

7 Q. Do you know he was talking with when he took

8 that information?

9 A. No, I just heard what was on the note, but I

10 don't know.

11 Q. What did you hear?

12 A. I heard the name Carol Stark I believe was on

13 the note, I believe her phone number, and I

14 can't remember what else. It related, yeah,

15 to the investigation of the incident so I

16 can't remember if there was a gentleman's

17 name that had rented from Bill Scearce or

18 there was some sort of connection there with

19 the FBI, the investigation that had taken

20 place in Bill Scearce's rental matters.

21 Q. And once again you never subsequently were

22 involved in any press releases about that,

23 the City Manger dealt with that directly?

24 A. Yes.

25 Q. Okay. Did you ever make any effort to put


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1 any information in from Bill Scearce if he

2 had additional information or corrective

3 information?

4 A. No, Bill Scearce issued a statement at a

5 press conference I believe the second week in

6 August and that was my first knowledge of it.

7 Q. So he went around you, also?

8 A. Yes.

9 Q. Well, it must be a little bit insulting for

10 you to have your career like that and have

11 people go around you, I would think. You

12 would like the procedure to be such that you

13 would be involved I would think in any

14 release, wouldn't you?

15 A. It would sure help when I get calls from the

16 media, yes.

17 Q. And you would normally receive the calls

18 back?

19 A. Yes, and that's actually how I learned about

20 the press conference of Bill Scearce, or Bill

21 Scearce had called one of the news media

22 sources that had called about Bill Scearce's

23 press conference.

24 Q. Okay. I guess an elected official, the City

25 Manager or in different positions, I suppose,


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1 but it seems to me the City Manager should

2 follow his own procedures. Would you agree

3 with that as far as information released?

4 A. Yes.

5 Q. Can you tell me have you had occasion to work

6 with the City Manager closely at any time

7 during your career?

8 A. Yes.

9 Q. Can you tell me what observations you have

10 made as being someone that works under his

11 supervision and within his department? How

12 is his managerial style exhibited?

13 A. He lets you do the work, he supervises when

14 the matter is close to his office, so to

15 speak, when it's involving City wide efforts

16 that obviously the Council and his office

17 would be interested in. I do try to keep him

18 apprised of anything that would relate to

19 that before we go to the public.

20 Q. Have you had any experiences with so-called

21 the wrath of the City Manager? I've had

22 people discuss his style with me and I

23 wondered if you had made any observations

24 about that?

25 A. Yes, I have seen that.


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1 Q. And what observations can you make so I can

2 record that?

3 A. There is frustration on his part, I believe,

4 when a situation is not out of control, but

5 there's something that is very difficult to

6 control and possibly will make the City look

7 bad as a whole.

8 Q. And what kind of reaction does he exhibit?

9 A. He's loud.

10 Q. Is it threatening gestures, slamming doors?

11 A. Slamming doors, loud. At one matter there

12 was a threatening gesture, I can't exactly

13 remember what it was, we were across the

14 desk. I was at my desk and he was in a chair

15 and he stood up and bellowed for a moment,

16 but then I just --

17 Q. But you were put aback by that?

18 A. I thought I would lose my job at that time,

19 yes.

20 Q. Not conducive to good management in the

21 public sector, I wouldn't think, is it?

22 A. It was a difficult situation because of the

23 disaster, but it's somewhat intimidating and

24 very disrespectful.

25 Q. Have you experienced that on other occasions


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1 with the City Manager?

2 A. He does get frustrated when there is some

3 disagreement with maybe an opinion or a

4 decision to move forward on some matters and

5 he will dismiss you, you know, or dismiss any

6 opinion or other comments you might have.

7 Q. Publicly?

8 A. Publicly he just doesn't acknowledge you.

9 Q. Which is probably just as bad?

10 A. It can be. You know, it's interesting on how

11 he aligns co-workers.

12 Q. When you say co-workers or aligned, I mean I

13 guess you've seen it with other co-workers,

14 also, with the City Manager exhibiting these

15 tendencies?

16 A. Yes.

17 Q. How many different people have you seen that

18 with?

19 A. Probably --

20 Q. I mean lots?

21 A. No, usually the department head level, yeah.

22 Maybe occasionally as staff I will hear about

23 it, but our offices sit on the same floor. I

24 sometimes hear door slamming. Sometimes a

25 loud voice, but not knowing what the words


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1 are.

2 Q. As working under him would you be critical of

3 yourself if you performed like the City

4 Manager does to your employees?

5 A. Would I be critical of myself if I behaved

6 that way?

7 Q. Yes.

8 A. Yes, I would.

9 Q. You don't think it has a place in the City

10 government?

11 A. No.

12 Q. I mean I've talked with other people. This

13 is not the first time I've heard this. Is

14 this such that has this been continuous

15 throughout his period of reign in this

16 community? I mean it seems to me that this

17 has been a longstanding problem?

18 A. There's a divide and conquer mentality. Not

19 too many sit at a table in a meeting on a

20 project, but that's the way he chooses is to

21 work one-on-one with people on a lot of

22 different projects.

23 Q. So he doesn't work with the consensus of his

24 employees?

25 A. Not what I've seen, no.


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1 Q. Have you ever worked under another City

2 Manager?

3 A. Yes, I have.

4 Q. Who was that?

5 A. I worked under Steve Lewis originally for

6 approximately eleven months, and then Harold

7 McCoy was interim for about a year.

8 Q. And Harold has done it more than once?

9 A. Yes, yes, but I had it on his last stint

10 after Steve left before Mark came.

11 Q. Was there a marked difference between those

12 styles and this individual's style, Mark?

13 A. Yes, considerably.

14 Q. To the worse, I assume?

15 A. Yes. Well, as far as in the Public

16 Information Office position typically Mr.

17 Lewis, it was a new position and would bring

18 me in originally to talk about the perception

19 and how we were going to discuss different

20 matters and felt it was a value of opinion

21 there in discussions.

22 Q. Well, at least you were able to express your

23 concern and he took it into consideration?

24 A. Correct.

25 Q. You're not able to do that with Manager Rohr?


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1 A. No, not unless asked, but that's infrequent.

2 Q. And I guess the same thing would be true of

3 Harold?

4 A. Harold, yes, Harold had a different style as

5 well, but never to the temper level.

6 Q. You actually work under his supervision as a

7 department head?

8 A. Well, I'm not officially a department head, I

9 don't supervise anyone, but I do go to all

10 the meetings and such. It's because I

11 believe it's the communications person. I do

12 now work with Sam Anselm, the Assistant City

13 Manager. He kind of serves as what I call a

14 buffer between Mark and I.

15 Q. And you appreciate that buffer, I assume?

16 A. I do. Yes, I feel much more relaxed in my

17 job.

18 Q. Would it actually be true that Mark Rohr does

19 not have a conducive atmosphere for good

20 working conditions under his supervision with

21 the higher ups?

22 A. Yes, I would say that's true.

23 Q. I mean if anything that has gotten worse, it

24 certainly hasn't diminished any?

25 A. No, it has not diminished.


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1 Q. Do you believe the City Council is aware of

2 this? I mean if you know. You may not know

3 how many of the City Council members know.

4 Have you ever discussed with any City Council

5 members Mark's conduct?

6 A. Not specifics, no.

7 Q. That would be kind of like putting your chin

8 out of line, wouldn't it?

9 A. Yes.

10 Q. And Mark has changed a lot of faces since

11 he's been here in all the department heads,

12 hasn't he?

13 A. Yes, he has.

14 Q. I've heard that the City Clerk has expressed

15 concern about working under his supervision.

16 Have you heard that?

17 A. Yes, there was a discussion of that under the

18 Charter review that is currently taking

19 place. That was a question brought to the

20 Charter Review Commission to consider. Since

21 then they have decided that's not a

22 recommendation they're going to put forward

23 to the Council. We have our final report

24 meeting tonight, but that's what I understand

25 they're going to report is not to recommend


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1 that.

2 Q. And that's because Barb won't work under that

3 condition?

4 A. I'm not sure exactly the reason, just that

5 discussion.

6 Q. If you had your choice would you like to be

7 in a different department with someone else

8 buffering between you and Mark Rohr?

9 A. I would like to continue doing

10 communications, yes, and it would be

11 beneficial, I think, for the City to have

12 better communications for my position with

13 the supervisor, yes.

14 Q. And that's expressed - I mean what is your

15 background in your position with public

16 information?

17 A. I have a Bachelor's of Arts Degree in

18 Communications if that's what you're asking,

19 Public Communications. Have worked 15 years

20 prior to coming to the City in communications

21 and media relations, special event planning

22 and marketing and some paid advertisement

23 positions, but feel pretty well versed in

24 dealing with media relations and the public

25 and customer service, yes.


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1 Q. I mean it's an expertise?

2 A. Media relations is something that, yes, it

3 can be taught, but you really need to do it

4 to learn it and you have to know your market.

5 Q. Does the City Manager have any background in

6 that that you know of?

7 A. No, I don't believe he does.

8 Q. So would it be a fair statement that he

9 really doesn't know how to use your

10 expertise?

11 A. Yes.

12 Q. Do you have any statements about Mr. Head

13 that are of significance or anything the

14 Council should know?

15 A. Brian is a hard worker. It's unfortunate

16 that we call it, you know, the City Manager's

17 office and the Attorney's office is always at

18 odds and it creates a large divide in any

19 kind of project development.

20 Q. So there's internal politics that disturb the

21 performance of the employees because of the

22 divide between those two?

23 A. Yes.

24 Q. Let me ask you, I was hired to discuss two

25 problems, one with Bill Scearce's alleged


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1 activity in some kind of a gambling ring. Do

2 you have any knowledge of that of your own

3 self?

4 A. Of the gambling ring?

5 Q. Yes.

6 A. I knew that there were bookies in town, but I

7 had no idea about Bill Scearce renting

8 property to them. I knew nothing about that,

9 but I knew there was, you know, what I

10 consider amateur bookie operations.

11 Q. And you don't know if Bill was ever involved

12 in that personally, do you?

13 A. No.

14 Q. There's an allegation that Mr. Woolston is a

15 Councilman that engages in matters with real

16 estate that causes frequent conflicts of

17 interest. Do you know of any information

18 about that that I should know about?

19 A. No.

20 Q. And would you have an opinion that the

21 divisiveness between the City Manager and the

22 City Attorney is negative to the City's

23 involvement in public matters?

24 A. I believe there are often conflicts or

25 discussions that aren't brought forward until


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1 the very last minute making it difficult for

2 the Council to make a decision, difficult for

3 the City Attorney and the Finance Director to

4 read contracts and make sure it's to the

5 benefit of the City because things aren't

6 discussed soon enough.

7 Q. And that would be at the discretion of the

8 City Manager of not getting that information

9 out sooner?

10 A. I believe so, yes.

11 Q. Would that divisiveness that exists there, do

12 you believe that the City Manager has any

13 role in divisive nature between the present

14 Council members that sit on the City Council?

15 Does he play a role in that divisiveness

16 also in your opinion? If you know?

17 A. I don't know any specifics, but obviously

18 there's two different factions on the

19 Council.

20 Q. Does he have favorites?

21 A. I don't know. I mean I don't know his

22 specific favorites necessarily, but he's

23 obviously aware of those who are not in favor

24 of it.

25 Q. And that would be because of public votes, I


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1 would assume?

2 A. I would assume so and probably discussions in

3 his office and just the general questioning

4 of projects and things of that nature.

5 Q. So there certainly is a divisiveness that

6 exists on the Council as well as in City

7 government?

8 A. Can you define the word divisiveness in this

9 case?

10 Q. Well, I mean we know there seems to be two

11 major sides?

12 A. Uh-huh.

13 Q. I mean one seems to favor the City Manager

14 and one seems to favor the City Attorney in

15 the City management issue, and then also on

16 the Council I see a reflection there. I

17 wondered if you did?

18 A. I don't know if it's necessarily specifically

19 related to the people or to the positions.

20 Again I think it goes back to not having

21 enough time to go over the information.

22 Q. And who gets the information early?

23 A. Right.

24 Q. And who does not?

25 A. Yes, but I understood, and again I'm not sure


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1 how this is done, but I understood when one

2 Council member gets it they all get it. That

3 is what I understand should be happening.

4 Whether it does or does not I do not know.

5 Q. Okay. You don't know whether or not he

6 brings certain people in at certain times or

7 whether he discloses this information to them

8 all at the same time?

9 A. Right.

10 Q. Okay. Thank you for your time. Is there

11 anything that I should have asked you or

12 should have inquired about that we have not

13 had an opportunity to do that?

14 A. No, not that I can think of.

15 Q. I'm not giving the specific transcripts to

16 the City, but I'm excerpting things so that

17 no one will have these transcripts.

18 A. Will my name be used at all?

19 Q. I don't know. I mean as a practical matter

20 your name will be used from the standpoint of

21 how many people have I talked with. I don't

22 know if the court reporter has a better idea,

23 but I think there's at least 30. I haven't

24 counted them yet, but there's a lot of people

25 I've talked with.


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1 A. Well, with this type of questioning I would

2 say it sounds like you may have talked to all

3 departments and I'm not sure exactly where

4 you're going, but I'm sure you have talked to

5 quite a few.

6 Q. That's right. So thank you very much for

7 your time.

8 A. Thank you. Appreciate it.

9 Q. And your efforts?

10 A. This would be more my position question. Is

11 there a time line when you'll be releasing

12 this information in the process or is that

13 something Brian will know?

14 Q. Yeah, Brian will know. I'll make a report of

15 sorts, a written report concerning my

16 recommendations to the City Council in

17 chambers and then who knows what they're

18 going to do with my report, probably publish

19 it the next day, I don't know.

20 A. Is that a closed meeting where you make your

21 report into the investigative matters?

22 Q. Yes, it will be, but I'm certain the next

23 minute they go into open meeting they'll

24 probably throw my report on the table so

25 that's probably the way it goes. And you


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1 would hope that you would have that a little

2 bit ahead of time?

3 A. Again for my job so I would know.

4 Q. I would suggest that you talk with Mr. Head

5 because I will be running my information at

6 some point to him. Not ahead of the

7 information to the Council, but he will know

8 more specifically my deadlines so I would

9 think, I would hope that between the time the

10 City Council gets it you'd have an

11 opportunity to brief yourself but I can't

12 promise that. That's way out of my control.

13 A. Right. Brian and I will discuss it.

14 Q. You and City Attorney Head should talk.

15 A. On how he wants it handled. Like will you be

16 doing this prior to the new year or will this

17 be in January?

18 Q. No, it will be probably in February.

19 A. Just holidays are always hard.

20 Q. Yes, they're already hard enough.

21 A. Right. Just timing. So that's just part of

22 my job.

23 Q. I understand.

24 A. Thank you.

25 Q. Thank you.


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1

2 (SWORN STATEMENT CONCLUDED)

3

4

5


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REPORTER'S CERTIFICATE

STATE OF MISSOURI

ss.

COUNTY OF JASPER

I, SHARON K. ROGERS, Certified Court Reporter in the

State of Missouri, do certify that pursuant to the

foregoing Stipulation the witness came before me on the

17th day of December, 2013, was duly sworn by me, and was

examined. That examination was then taken by me by

steno-mask recording and afterwards transcribed; said Sworn

Statement is subscribed by the witness as hereinbefore set

out on the day in that behalf aforesaid and is herewith

returned.

I further certify that I am not counsel, attorney, or

relative of either party, or clerk, or stenographer of

either party or of the attorney of either party, or

otherwise interested in the event of this suit.

_________________________

SHARON K. ROGERS, CCR-650

Onstot, Lynn | Testimony transcript

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Transcript of Onstot, Lynn | Testimony transcript