Transcript of the Testimony of Leslie Haase
Date: November 19, 2013Volume: I
Case: In Re: Joplin Critical Investigation
Printed On: December 1, 2013
Holliday Reporting Service, Inc.Phone: 417-358-4078
Fax: 417-451-1114Email:[email protected]
Internet:
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
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IN RE: JOPLIN CRITICAL INVESTIGATION
SWORN STATEMENT OF
LESLIE HAASE
Taken on Tuesday, November 19, 2013, from 1:26 p.m. to 1:55
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
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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 . . . 5-2
E X H I B I T S
(sic) - typed as spoken
(ph.) - phonetic
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1 LESLIE HAASE
2 DIRECT EXAMINATION BY MR. LORAINE:
3 Q. Ms. Haase, we talked last week. Do you
4 recall that?
5 A. I do.
6 Q. And I asked you to swear under oath and you
7 signed a Garrity warning. Do you remember
8 that?
9 A. I do.
10 Q. I'd like to remind you that you're still
11 under oath and we're revisiting a little bit
12 today in reference to a couple of issues,
13 okay?
14 A. Okay.
15 Q. And the first thing I want to ask you is did
16 you have to talk to anyone concerning what
17 you and I talked about in this meeting last
18 week?
19 A. No.
20 Q. Nobody asked you what you were doing here?
21 A. Nobody.
22 Q. Okay. And that includes Mr. Rohr?
23 A. Right. I don't even know if he knew I was
24 here.
25 Q. And I want to go ahead and continue that same
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1 understanding. Is that okay with you?
2 A. Yes.
3 Q. I would like to talk about several issues
4 today, and I'll just number them some odd
5 number 1, 2, 3, and maybe there's a fourth,
6 but the first issue that I'd like to talk
7 about is Lane Roberts is your Police Chief?
8 A. Yes.
9 Q. He's been here a long time. I don't recall.
10 A. Four or five years.
11 Q. When he came here he was set up to receive a
12 salary and then he was to receive some
13 benefits including a pension?
14 A. Yes.
15 Q. What oddity occurred for the certain period
16 of time when he came that you're aware of in
17 the term of his pension benefits? Can you
18 explain that?
19 A. I can, and I apologize, I've lost of track of
20 time a little bit with the tornado, my years
21 have gotten away from me, but it had to have
22 been before the tornado he called me and said
23 I think there's a problem, and I said okay.
24 He said I don't think that anything is being
25 deducted from my paycheck for the pension,
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1 and I said, oh, okay, hang on, let me look.
2 And I looked and sure enough it wasn't and
3 never had been since he started working
4 there. And he told me, he said, you know, I
5 never even realized it. He said the only
6 reason I realized it now is my wife and I
7 were starting to do some retirement planning
8 and he said I wanted to look and see, you
9 know, how much money I had, and he said I
10 started looking at my check and nothing was
11 being deducted. So I looked back to see what
12 had happened. In fact, it was an issue in my
13 office. We do the payroll and at the time
14 that Lane started I was going in between - I
15 had a new hire doing my payroll for me for
16 the City. But also the H.R. Department had a
17 new hire doing the payroll on their side.
18 They enter the information and then we do the
19 payroll. Anyway it was a bad circumstance in
20 the fact that both departments had new people
21 and when Lane came that deduction never got
22 attached to him.
23 Q. How long did this condition of not
24 withdrawing any payroll deduction from his
25 salary, how long did that last?
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1 A. It would have been from the time he was hired
2 until he called me.
3 Q. Well, give me a period of time.
4 A. That's what I'm saying I lose track of time.
5 It was before the tornado when he called me.
6 How much before the tornado I don't know. We
7 have all the records over there.
8 Q. Okay. What record would this be?
9 A. Once we discovered it - and this is not the
10 first case of errors in payroll, both on the
11 employee and the employer side. But when
12 that happens and people have to pay things
13 back - and in this case this particular
14 deduction is very odd because when the
15 employee retires or they terminate they get
16 all that money back so it is not - it goes
17 into a plan, but it comes right back out of
18 the plan when they leave. So I met with
19 Lane. Of course I informed Brian Head and I
20 informed the City Manager. But what our
21 normal practice is when we find an error, and
22 we find them from time to time, is we sit
23 down with the employee and we make
24 arrangements to rectify the situation. And
25 if we've overpaid somebody we always get the
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1 money back. In this case we drew up, I'm
2 pretty sure we drew up an agreement with him
3 on how it would be repaid. And obviously it
4 was a large sum of money he could not pay.
5 Nobody could have paid that out of their
6 pocket and he could not, and so we did the
7 normal standard thing that we always do, we
8 kind of look at how long a period it was done
9 and we look to see what he could afford out
10 of his paycheck and we made an arrangement
11 for him to repay it over a set amount of
12 time. And we did an agreement and we kept
13 track of it on payroll and then he actually
14 repaid it early. He wound up - we were
15 deducting the extra amount from his payroll
16 for whatever time period and then he wound up
17 writing us a check when it got near -
18 somewhere near the end he wrote a check for
19 the balance.
20 Q. So you're telling me it was repaid in full?
21 A. Yes, and we showed receivable on the books.
22 We did everything we were supposed to. The
23 auditors looked at it. I mean nothing
24 secret.
25 Q. Provide me the agreement, if you will.
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1 A. Yes.
2 Q. Now did City Manager Rohr have any role in
3 this episode that we've talked about?
4 A. No, it was me. Now I made the City Manager
5 aware of it and I made Brian aware of it and
6 told them what we were going to do, but to my
7 recollection it was all me. That's our
8 standard practice.
9 Q. And you think it was in excess of
10 $100,000.00?
11 A. I think so.
12 Q. I'd like to now go to the issue with Mr.
13 Steve Cope.
14 A. Okay.
15 Q. I think that's the Engineering Department?
16 A. Building Department which is --
17 Q. That's under the Engineering Division?
18 A. Yes.
19 Q. Can you tell me, there was an episode of over
20 $100,000.00 reported in the newspaper that
21 had not been collected in that department.
22 A. Right.
23 Q. Tell me about that.
24 A. Sure. What happened is our I.S. Director,
25 the Building Department evidently they wanted
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1 to get some little computers in the field to
2 do field recording, which our computer
3 doesn't accommodate. But also --
4 Q. Who was the I.S. Director?
5 A. Our I.S. Director is Mark Morris. And so he
6 knew that they weren't necessarily using the
7 computer system to its full capability so he
8 decided to bring Sunguard (ph.) HTE, that's
9 our computer company software, that's where
10 we get our software from, he decided rather
11 than before he spent money on hardware or
12 software he wanted to bring them in to do an
13 assessment. And when they came in to do the
14 assessment they ran a report that is open
15 building permit fees and open code
16 enforcement cases, and the open building -
17 and they wrote a report so there's a report
18 that gives all of this information which I
19 have.
20 Q. Would you provide that report to me?
21 A. Yes. So the report said, okay, you've got
22 open building permits of over $200,000.00 and
23 you've got open code enforcement cases of -
24 well, it said $200,000.00 and some, also. So
25 Mark once they put that in writing he brought
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1 it --
2 Q. Mark Morris?
3 A. Mark Morris, the I.S. Director. Once they
4 put that in writing he brought it to me
5 because it had to do with finances and we
6 reported it to the City Manager. And the
7 City Manager directed us, me, to look further
8 into it because it was just a report and I
9 could flip through it and see that, for
10 instance, for the school district we will
11 issue building permits but we do not collect
12 the fee, and I could see some on there for
13 them. So he directed me to look into it
14 further, so I did, and in doing that it turns
15 out that the $200,000.00 in open building
16 permits there were about $40,000.00 from that
17 report that I could tell we should have
18 collected but we did not collect. Now they
19 had voided ones, they had ones for the City
20 of Joplin and ones for the schools that
21 shouldn't have been collected. They had ones
22 that were mistyped like where they typed in
23 the address instead of the building permit
24 amount so it showed like a $40,000.00
25 building permit when that was really the
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1 street address, you know, just some errors.
2 But in the end on that report there was
3 $40,000.00 we should have collected that we
4 didn't collect. And then the code
5 enforcement report, what it actually did was
6 show a total and then it showed the amount
7 billed, and the way code enforcement bills
8 is, and code enforcement is mainly where the
9 City goes out and mows somebody's property
10 and then the fourth floor, which would be
11 Public Works, has to hit a button and send it
12 down to my office to send out the bill.
13 Well, on many of them they didn't hit the
14 button to send it down to us to bill so there
15 was $110,000.00 that just simply never got
16 billed in code enforcement. So that's where
17 the $150,000.00 comes from. Now since then
18 after Mr. Cope was let go we cleaned out his
19 office and found a stack of checks this big
20 (indicating) that he just sat on and never
21 deposited to the tune of over $10,000.00
22 worth of checks that he just - I have no
23 idea. He just never sent them through to be
24 deposited.
25 Q. And this would be of the $40,000.00 some?
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1 A. No, it would be on top of the $40,000.00.
2 And, you know, I had had trouble with Mr.
3 Cope for a long time. I could see that he was
4 not billing sign permits that he was supposed
5 to be billing and every year I would say
6 something. I honestly believe what happened
7 on the code enforcement is what would happen
8 our fiscal year end is the end of October and
9 it would get almost to fiscal year end and I
10 would look at the revenue in that lien and
11 say, okay, there's no revenue, you guys
12 haven't done your billings all year long, and
13 then they would try to catch up their mow
14 billings. And invariably I'm guessing they
15 missed some because they were trying to
16 backtrack and that's how they missed billing
17 a bunch of them. So he simply was not doing
18 his job and he was sitting on checks and you
19 cannot do that.
20 Q. Do you say that you have given him warnings
21 over a number of years?
22 A. Not me. He didn't work for me. But I talked
23 to the Public Works Director time and time
24 again.
25 Q. Who was the Public Works Director?
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1 A. It was David Hertzberg.
2 Q. Did you do any of that in writing?
3 A. No, and then I told the City Manager. None
4 of that was in writing. But I had other
5 witnesses, I mean. It was usually in budget
6 meetings.
7 Q. Now Mr. Hertzberg was relieved of his duties?
8 A. He was demoted.
9 Q. Was that because of this in your opinion?
10 A. It was because of this.
11 Q. And who did that, you?
12 A. No, the City Manager. He doesn't work for
13 me.
14 Q. Do you know if the City Manager had other
15 reasons? I mean if you know.
16 A. Well, in this particular case at the time
17 period that many of these issues happened the
18 City Manager had made his sole job duties
19 code enforcement and building, and so I think
20 that - I mean after the tornado he had given
21 many of the duties to Jack Schaller and he
22 assigned David solely to the Building
23 Department, and many of these things were
24 going on when David was solely responsible
25 for making sure that the Building Department
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1 was working like it was working. And you can
2 - I
3 mean --
4 Q. Did you make a recommendation to the City
5 Manager?
6 A. About Steve Cope. I said, yeah, I said he
7 has to go. We can't have an employee sitting
8 on checks. And I would do that again.
9 Q. Okay. Did you make a recommendation to the
10 City Manager about Mr. Hertzberg?
11 A. I don't know if recommendation is the right
12 word. I know that he talked about it with
13 several of us, Brian Head, me, the Assistant
14 City Manager, Sam Anslem, Lane Roberts may
15 have been in there at that point. I know we
16 all talked about it and nobody - I can't say
17 that I made a recommendation, but I did not
18 disagree.
19 Q. With Hertzberg?
20 A. That something had to change.
21 Q. Okay. But that decision was made by the City
22 Manager?
23 A. Yeah.
24 Q. Okay. What was the reason Mr. Schaller was
25 let go, if you know?
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1 A. He wasn't let go. He quit.
2 Q. Do you know why?
3 A. Well, Jack, himself, told me and of course I
4 have the payroll records, so Jack was
5 disciplined and he told us in the budget
6 meeting, me and our financial analyst that
7 goes to the budget meeting, he told us why he
8 was disciplined, which was when they were
9 hiring the Public Works Operations Manager he
10 said that the City Manager said that he -
11 whoever the number one pick was we had hired
12 him, he was getting ready to start, and he
13 came in before his start date and met with
14 Jack and Jack evidently according to what he
15 said, that he said bad things about the City
16 and then the guy called the City Manager and
17 backed out of taking the job so he got in
18 trouble. Now Jack told us that he didn't do
19 that, you know. I don't know what happened.
20 I mean I don't know. I only know what Jack
21 said.
22 Q. But Jack denies that he said --
23 A. He denies it and he told everybody what
24 happened.
25 Q. But did Jack say that he was screamed at or
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1 hollered at by the City Manager?
2 A. Not to me.
3 Q. Had you ever heard that, that he was?
4 A. That Jack was screamed at?
5 A. Yes.
6 Q. No.
7 Q. We talked about the City Manager's actions
8 along those lines before. Did you hear
9 anything more about the City Manager's
10 arguments or pushing episodes with his wife
11 at the office?
12 A. No.
13 Q. All right. We talked about one issue
14 concerning the tire matter where the City
15 Manager directed the tire company not to be -
16 I think it was Goodyear.
17 A. Goodyear.
18 Q. Not to be used anymore because they had
19 angered the City Manager. Do you have
20 records that indicate that they were, in
21 fact, not used any longer?
22 A. Yes.
23 Q. And what would those records be?
24 A. That would be --
25 Q. Is there a memo or something from the City
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1 Manager?
2 A. No, at the same time - the other piece of
3 this Building Department issue it was the
4 garage investigation and my staff looked into
5 - we already were going to look into the
6 garage for a different reason. We were going
7 to basically assess whether it's better to do
8 that operation in house or farm it all out,
9 and that's just an exercise that we do once
10 in awhile. We were going to do that prior to
11 the tornado and then our efforts got, you
12 know, redirected. But at the same time this
13 came out we were looking at the garage and a
14 piece of that was that came to light that we
15 stopped doing business with Goodyear and we
16 were buying our fleet tires from Firestone.
17 And my employee that was looking into that
18 called to ask the Police Department - because
19 remember she was looking in the garage and
20 there were issues in the garage. So she just
21 asked the Police Department why is the garage
22 getting tires from Firestone and not
23 Goodyear, and their answer was because the
24 City Manager said not to use Goodyear
25 anymore. And then he confirmed it.
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1 Q. To you?
2 A. To me.
3 Q. Okay. And did he tell you why?
4 A. Yes. Well, he told me why right after the
5 tornado.
6 Q. And the reason was they didn't give him
7 preferential treatment?
8 A. They didn't fix his car.
9 Q. Preferential treatment? Is that right?
10 A. Well, what he said to me they wouldn't fix my
11 car right away.
12 Q. Let me ask you a question. What document can
13 I see to show me that the purchase was no
14 longer at Goodyear?
15 A. I can get you that report, I think, that will
16 show you.
17 Q. Give me a report on that?
18 A. Uh-huh.
19 Q. All right. So I'm looking for at least two
20 reports.
21 A. I've got three things.
22 Q. What was the third one? I'm sorry.
23 A. The Lane Roberts information, the Sunguard
24 (ph.) report on this, and now Goodyear.
25 Q. Yeah. I'd like to go to the fourth area,
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1 that would be Fire Station No. 2, the
2 rebuilding of Fire Station No. 2.
3 A. Okay.
4 Q. I have been told that there was an issue
5 concerning a culvert, and let me expand that,
6 and equipment such as cranes and things of
7 that nature that had to be hired or rented to
8 handle the culvert and other materials of
9 that nature.
10 A. Okay.
11 Q. Can you explain the issue of the culvert as
12 you understand it to be?
13 A. There are two issues that I know about and
14 I'll tell you everything I know which is -
15 and I don't know which station is which, but
16 I think we had an issue at both stations.
17 Q. The culvert is at Station 2 so let's talk
18 about that one first.
19 A. Is Station 2 the one on 13th and
20 Schifferdecker?
21 Q. Yes.
22 A. Okay. I'm with you now. Okay, so that would
23 be the storm water issue.
24 Q. Yes.
25 A. So here's what I can tell you. After we
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1 purchased the property the Fire Chief came to
2 me and said, somewhere along the way he said,
3 we've got a storm water issue. He said, you
4 know, that was an issue with that property,
5 but Jack Schaller said it would not be an
6 issue. But here's the situation. We're
7 rebuilding these stations, both of these
8 stations with FEMA money, but FEMA only pays
9 you to put something back just like it was.
10 Well, we relocated both of these stations and
11 we're building them bigger than they were so
12 the City also has some costs in it so it's
13 part FEMA and part City on both fire
14 stations. We have a very tight budget.
15 Basically we can't go over budget, what we
16 budgeted for to rebuild the stations. I'm
17 holding everybody on all the FEMA work, I'm
18 trying to hold them to everything as best
19 that I can. And he came to me about the
20 storm water issue.
21 Q. This is the Fire Chief?
22 A. Yes, and he said Jack knew about it, Jack
23 said he would take care of it, you know, what
24 are we going to do. And I think I probably
25 talked to Jack at some point, I really can't
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1 remember, you know, that's what I do all day
2 long is talk to people about money. So what
3 I said, and this is also normal for us, we
4 have maintenance - we have a ten year parks
5 storm water sales tax and they asked me,
6 well, what can we do to make sure we stay in
7 budget.
8 Q. Who asked you that?
9 A. Mitch. I think Mitch and I can't remember if
10 Jack was there. It was different discussions
11 over a period of time, but it was all only
12 either me and Mitch or me, Mitch and Jack,
13 maybe David Hertzberg. Anyway I said, well,
14 the only thing that we can do is use storm
15 water and it's a storm water issue, we need
16 to fix it with the storm water money and we
17 can do it with our maintenance money and it's
18 not a problem. So as far as I know that's
19 what they've done. I have not double
20 checked. I haven't had time to go back and
21 see if that's what they've done. The issue
22 on the other station was something about the
23 street, and I only found out about this in
24 the last few weeks, something about the
25 street and as the fire trucks pull out
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1 there's a dip or something, and so there was
2 some concern from our Engineer Dan Johnson
3 that we needed to fix the street in order for
4 the fire trucks to pull out and it was going
5 to cost X amount of money, which I cannot
6 remember, but a fair amount of money. And I
7 think that's when I found out about that and
8 I started asking some questions about I'm
9 like, you know, what is this, what's going
10 on, because he was actually holding up
11 anymore work at the fire station until we
12 figured this out. And then I talked to
13 Mitch, our Fire Chief, on the phone, because
14 Dan was explaining it to me and I'm like Dan
15 was thinking, okay, we only have one ladder
16 truck which is a great big truck, it's our
17 biggest truck that we have, and he was
18 thinking that we were going to have a ladder
19 truck out there. The ladder trucks sit lower
20 than the other trucks and he was trying to
21 build it for clearance on the ladder truck.
22 And I said there isn't going to be a ladder
23 truck out there. The ladder truck is only at
24 Station 1. It doesn't go to any other
25 station. So I'm like you need to talk to
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1 Mitch because that's not right. You need to
2 see what fire trucks are really going to be
3 out there and see if they're going to work or
4 not before you do any extra work. So he did
5 and, in fact, the last I heard is that
6 they've determined that they don't have to do
7 anything to the street extra because of the
8 types of fire trucks that are going to be out
9 there. So as far as I know we're not
10 spending any extra money. And that's
11 everything I know about both fire stations.
12 I have not been very involved with either of
13 them.
14 Q. All right. Were you directed to use the
15 storm water money by Mark Rohr?
16 A. No, I think that was me that said that. I
17 don't even remember having a conversation
18 with Mark about it. And that's not out of
19 the norm. That's how we do stuff.
20 Q. Is the storm money, does that require an
21 authorization from the City Council?
22 A. No, because we always budget - it is
23 authorized because we always budget
24 maintenance for storm water and that was a
25 small enough project, from my understanding
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1 that was a small enough project to be some of
2 the maintenance money that we had.
3 Q. Well, that would be under $100,000.00?
4 A. Yeah.
5 Q. If, in fact, it was more than $100,000.00
6 that would be an improper use of the money?
7 A. Yes, if it's over $100,000.00 they should
8 have gotten Council approval.
9 Q. And Mark approved this project to be done at
10 some point?
11 A. Yeah.
12 Q. Okay. The culvert issue?
13 A. Oh, that I don't know. Because I never, ever
14 talked to Mark Rohr about this.
15 Q. Okay. Can you check on that to see if, in
16 fact, there was ever Council approval because
17 I'm under the impression that it was
18 somewhere around $99,000.00 or $95,000.00 for
19 the culvert and then there would be equipment
20 to use that culvert and done in house by the
21 City engineers and street workers.
22 A. Okay, if that's how they did it they would
23 not have to get Council approval. You only
24 have to get Council approval if they're
25 buying something or awarding a contract
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1 that's over, in and of itself is over
2 $100,000.00.
3 Q. The expenditure of more than $125,000.00 does
4 not count in --
5 A. Not in that way. Not if it was our own
6 labor.
7 Q. Well, not counting the labor, I'm talking the
8 rental of items like the cranes and things of
9 this nature.
10 A. Uh-huh, we see that as two - we always treat
11 that as two separate things.
12 Q. Well, how would anybody know what that
13 firehouse cost if you didn't assign it from
14 the firehouse budget?
15 A. Well, we would have it in storm water.
16 Q. Well, I mean what if there's another storm
17 water project?
18 A. We still have plenty of money left in storm
19 water.
20 Q. Did you ever hear the concept of paying the
21 money back to the storm water?
22 A. No.
23 Q. You don't know anything of that?
24 A. No, nothing.
25 Q. I'd appreciate it if you could check on that
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 28
1 information.
2 A. Sure.
3 Q. And give me whatever you have on that.
4 A. I will, sure.
5 Q. So that will be the fourth item I'm expecting
6 from you.
7 A. Sure.
8 Q. Okay. I think that covers everything that I
9 wanted to talk about. Once again I'm going
10 to admonish you to try to not use anything
11 that we said in here in discussions outside.
12 If anybody does want to talk to you about
13 what you're doing over here then I want you
14 to please call me, okay?
15 A. Okay.
16 Q. Thank you, ma'am, for coming back to talk to
17 me.
18 A. Sure.
19 (SWORN STATEMENT CONCLUDED)
20
Leslie Haase In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 29
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
19th day of November, 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
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