298 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Okay.

And what's been your involvement in a consulting

basis? A I've basically worked with Holly Miller on that. And when

it first began after the affiliation, she and I talked about how we were going to proceed. Q A Q Okay. And how did you decide to proceed?

Essentially by writing them a check each month. You write a check for the integration team for what

purpose? A No. We -- CNA/NNOC writes a check to NUHW and then they That's essentially the work of the integration team

pay bills. is -Q

And is that -- is that spelled out here?

The amount of

the check that you would write to them? A Q The amount of the check is not spelled out. Okay. How is that defined, the amount of the check, if Well, you would know I guess from what you said.

you know? A

Well, that was -- that was defined by a set of expenses

that were approved for -- under that -- under that payment agreement -- or process, I should say. Q Is there a document -- or are there documents that

memorialize the payment process that you've just described? A The payment process? I don't know if there's a document

that memorializes the payment process. Q How about the amount of the payment?

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299 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A There is -- there is certainly a -- there is a record of

the payment, yes. Q A Okay. And what does the record consist of? And there is some specificity obviously as to

The amount.

what the payment is going toward. Q And is there a document that describes or defines the

specificity -- that constitutes the amount of money that is -the check is written for? A There is -- I can't say that there's a monthly document,

but there certainly was an initial budget for those payments. Q Has the budget been revised in the meantime, do you know,

since the initial budget? A The type of expenses are essentially the same. The amount

of the monthly payment has varied slightly. Q Do you know why it has varied?

But it's --

What accounts for any

variance? A I might -- it -- just the amount of expenses, of

personnel, those kinds of things. Q Okay. From what you know about that budget and about the

record of the payments that have been made since January 1st of 2013, what is the agreement on the amount of money that is to be paid to the NUHW on a monthly basis? A I'm not sure. You mean what is the amount itself or --

I'm not sure I understand the question. Q What is the amount itself? Is it $5,000? Is it $100,000?

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300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q It's between 1 million and 1.2 million per month. Okay. And what is it that defines what constitutes the 1

million to the 1.2 million on a monthly basis? A Q A Q A It's based upon expenses. NUHW expenses? Based on NUHW expenses. Is there -- are those expenses audited by the CNA? They're certainly reviewed. We're very -- yes. And we're

very aware of what they are related to, which is, you know, ongoing work that our folks are aware of. Q So if I understand your testimony, there's 1 million to

1.2 million dollars a month that is being -- a check that is being written to the NUHW. Prior to the affiliation that 1 million to 1.2 million dollars would have been available for -- as a resource, an asset for California Nurses Association members; is that correct? MS. MCNEIL: JUDGE LAWS: THE WITNESS: Objection. Overruled. Well, it depends on how you want to consider I mean, it -- certainly we have Compound.

the source of that money.

reserve accounts and we have other things. The payment for -- these payments to NUHW are a direct reflection of the organization's commitment to acting on behalf of our members. And primarily the -- well, these expenses go

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