Chris Jackson Testimony

Joseph Hall - Redirect
Wednesday/January 27, 2010/Volume 3
85
later point asked for reconsideration of the vote.
has been no further -- there was no further testimony
regarding the disposition of the motion for reconsideration,
the request for reconsideration.
There
Secondly, Mr. St. John testified that when
Mr. Riddle's request for the $25,000 was voiced and
Mr. St. John said no, Mr. Riddle showed no reaction.
8
9
10
Third, the last witness, Mr. Hall, never worked in

any of the -- never performed in any of the clubs.
Thank you.
11
Let's go ahead.
12
MR. GARDEY:
13
as a witness.
14
15
The United States calls Chris Jackson
THE COURT:
In front of me, sir.
Raise your right
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.
25
That's good.
Mr. Jackson, if you could pull the microphone down.
09-20025-04; U.S.A. v. Samuel Riddle
Christopher Jackson - Direct

86
Please state your full name for the record and
spell your last name.
A.
Christopher Troy Jackson, J-a-c-k-s-o-n.
MR. GARDEY:
Your Honor, at this time the
government would move Exhibits 22A through E and Exhibit 23
into evidence.
Those are the Deja Vu exhibits.
THE COURT:
MR. GARDEY:
THE COURT:
10
MR. GARDEY:
11
THE COURT:
Hold on.
22?
22A through E.
Admitted.
And Exhibit 23.
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.
17
Consulting Group, L.L.C.
18
Valley Partners.
19
and I am also a partner in Detroit Credit Card ATM
20
Processing, L.L.C.
21
One is Jackson
I am also a partner in Paradise
I am a partner in Queen Lillian, L.L.C.,
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?

A.
Detroit, Michigan.
Q.
Were you born and raised here?
A.
Yes, I was.
Q.
What's your educational background?
A.
Went to grade school here in Detroit, St. Phillips
Lutheran School.
from Cass Tech High School.
received a degree there.
attended the University of Detroit Law School, did not
87
Went to Cass Tech High School, graduated

Went to Howard University,
Upon graduating I actually
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.
14
Councilman Gil Hill.
15
graduating from Howard University.
16
Q.
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.
24
legislative affairs.
25
Q.
I was working in the employ of Detroit City

I started working there upon
What year did you start working for Councilman
At that time I was an administrative assistant handling
How long did you work for Councilman Hill?

88
A.
Approximately about eight years, seven years.
Q.
What year did you leave Councilman Hill's?
A.
Somewhere around 1997.
Q.
Did you hold any other positions with Councilman Hill?
A.
Upon my last two years I was his chief of staff.
Q.
What did you do after you left Councilman Hill?
A.
When I left Councilman Hill, I started Jackson
Consulting Group.
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.
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.
24
did Jackson Consulting do?
25
A.
I also served in a consulting capacity
So did you leave Councilman Hill and start Jackson
How about back in the fall of 2006, what kind of work
2006 or 2007?

89
Q.
In 2006.
A.
Well, I did not have Jackson Consulting while I was
still in the employ of --
Q.
I'm sorry, in 2006, not 1996.
A.
I'm sorry, I'm sorry, I thought you said 1996.
Jackson Consulting was again focusing on clients in the
financial arena.
believe that Jackson Consulting had that was outside of the
finance arena that was in the sort of public schools or in
In 2006
At that time there was one client I
10
the schools markets, but for the most part most of
11
Jackson Consulting's clients were in the finance arena.
12
Q.
13
the finance arena, what type of work did you do for your
14
finance clients?
15
A.
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
And when you say Jackson Consulting's clients were in
Most of my clients were asset management firms, hedge

90
invested into those hedge funds or private equity funds.
Q.
of the Detroit Credit Card Processing Company?
A.
Yes, sir.
Q.
And how long have you owned that company?
A.
Detroit Credit Card/ATM Processing roughly I believe
was started back in 2000/2001.
Q.
And that business was active in 2006?
A.
Yes.
10
Q.
What kind of work does that company do, Detroit Credit
11
Card/ATM Processing?
12
A.
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.
17
purposes of your credit card processing business?
18
A.
19
Card/ATM Processing's partner was First Independence Bank.
20
Q.
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
Now, you mentioned earlier that you are also the owner
Detroit Credit Card/ATM Processing owns ATM machines,
In 2006 did you have a relationship with a bank for
Yes.
My partner -- or I should say Detroit Credit
And was it First Independence Bank's job to process

91
business.
A.
would use an ATM machine we charge a transaction fee.
the credit card processing there is a small transaction fee.
When a person uses a credit card at a point of sale, a place
of business, there is a small transaction fee that is
charged to that company that is actually using the
processing services.
Q.
The ATM business, for every transaction that a customer

For
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.
19
tell the truth.
20
it relates to telling the truth, I will perjure myself.
21
roughly it's to tell the truth.
22
Q.
23
government can use what you say in your testimony today
24
against you at a later criminal proceeding?
25
A.
My understanding of the terms of that agreement is to

If in fact I violate any of those terms as
So
And what is your understanding as to whether or not the
It's my understanding that they cannot.

92
Q.
And what happens if you lie during your testimony
today?
today against you in a later criminal proceeding?
A.
Yes.
Q.
Now, Mr. Jackson, let me direct your attention back to
the fall of 2006.
Deja Vu Consulting?
A.
Yes, I did.
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.
17
actually was back in September of '96.
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.
22
asked to look at consulting in that regard, that was not
23
necessarily my forte, if you will.
24
practice was more so in the finance arena, but I did agree
25
to look into some due diligence, initial due diligence into
Would the government be able to use your testimony
At that time did you do some work for
I was asked to consider representing Deja Vu.
It
I was approached by
I actually, when I
I informed her that my

93
the matter.
Q.
2006?
A.
2006.
Q.
And that was in September 2006?
A.
Yes.
Q.
And you say you were proposed by a Ms. Pipis?
A.
Yes.
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.
12
represented some downriver communities.
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.
18
turn, contacted me.
You said, you testified 1996.
19
Did you mean to say
I'm sorry, sir.
It's my understanding she

She had brought to
Ms. Pipis, in
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.
25
meetings with people from Deja Vu?
Now, after you were contacted by Ms. Pipis did you have

94
A.
Yes, I did.
Q.
Who did you meet with from Deja Vu?
A.
I believe it was Gary Koloszar, Mr. Hall and
Mr. St. John.
Q.
Is that Jim St. John and Joseph Hall?
A.
Yes.
Q.
And what was the purpose of your meeting with Mr. Hall,
Mr. St. John, and Mr. Koloszar?
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.
14
at Deja Vu concerning your working for them?
15
A.
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.
Did you come to any kind of agreement with the people
We actually had come to a verbal agreement of sorts.
And would that have been a significant investment or

95
was that of significant worth to you in your credit card
processing company if you had been able to get that from
Deja Vu?
A.
Yes.
Q.
Did they also offer you an opportunity to buy an
option, an ownership interest in the Deja Vu facility in
Detroit?
A.
those gentlemen as it relates to an ownership interest in
Yes.
Later on there were discussions with myself and
10
the Deja Vu Detroit property.
11
Q.
12
Deja Vu?
13
A.
14
interest in being in the strip club business.
15
focused on the credit cart processing business and the ATM
16
business.
17
Q.
18
strip club business?
19
A.
20
great idea, but it was just not something that I truly had
21
a lot of experience in.
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.
25
just, really more so focused on growing my ATM and credit
Were you interested in getting an ownership interest in
That was not really my interest.
I really had no
I was more so
Why weren't you interested in being a part owner of a
Well, I don't think my wife would have thought it was a
I had been in the entertainment
And so I was really

96
card processing business.
Q.
that with 400 Monroe Partnership?
A.
Partners had a 50 percent ownership interest in Greektown
Casino.
Q.
Greektown Casino?
A.
And you mentioned you had an interest in gaming.
Was
Yes 400 Monroe later became Monroe Partners, and Monroe
But at the time in 2006 you had sold your interest in
Yes.
I actually had made provisions to sell my
10
interest, yes.
11
Q.
12
what was your understanding of what you were supposed to do
13
for Deja Vu?
14
A.
15
make contact with the City, in particular the City's Law
16
Department.
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.
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.
25
to find out in fact if the City felt that it was from a
Based on your meetings with Mr. Hall and Mr. St. John,
My understanding was to, one, the first step was to
I did contact John Johnson at the time, who was
The gentleman had
So the first step was to talk with John Johnson

97
legal perspective prudent to effectuate the transfer.
Next was to --
Q.
Well, first let me ask a couple of questions about
that.
A.
Sure.
Q.
So in September of 2006 it was your understanding that
there was ongoing litigation between Deja Vu and the City of
Detroit about Deja Vu opening a club in Greektown in the
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.
18
meeting scheduled.
19
meeting.
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.
25
have any understanding as to whether Deja Vu had met with
Yeah, I actually contacted Mr. Johnson.
We had a
Something came up the day of the
We did talk by phone and had some conversation
Now, before Deja Vu started working with you did you

98
any of the members of the City Council?
A.
council prior to that.
Q.
Council in order to convince them to approve the license for
Deja Vu?
A.
Yes, I arranged a number of meetings.
Q.
What meetings did you arrange?
A.
I believe the first meeting we had was with Barbara,
10
I had not.
I don't think I knew they had met with
Did you arrange any meetings with members of City
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.
14
Alberta Tinsley-Talabi.
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.
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.
We met with Cockrel, Reeves, Councilwoman

I had spoken with a staff member of
So did you reach out to Councilwoman Monica Conyers to
I believe Joe Hall was at all of the

99
meetings.
I believe Mr. St. John was at all or at most of
the meetings as well.
Q.
these members of the City Council to approve the transfer of
the license so that they could open their club?
A.
Yes.
Q.
And the members of the City Council you met with, were
they receptive to your request?
A.
And were you trying to work with Deja Vu to convince
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.
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.
21
could face damages from the litigation if they went forward
22
with the litigation?
23
A.
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
And many of them, many of them maybe
Did you also discuss the possibility that the City
We shared with them in those meetings that these very

100
country with other major cities and those cities had lost in
these type of transfer cases and there were significant
damages and that in this case what we tried to prevail on
them is that it was better to move forward or allow the
transfer versus putting the City in harm's way.
Q.
meet with you or who you believed were against the transfer
of the license?
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.
14
does that leave?
15
Were there some members of City Council who would not
I'm trying to think who
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.
18
Councilwoman Jones, we were not able to arrange a meeting
19
with Councilwoman Jones.
20
Q.
21
Monica Conyers?
22
A.
23
would have gone through with the other council members.
24
Q.
25
the people from Deja Vu?
And I am sorry,
Why did you want to meet with Councilwoman
To be able to go through the same issues with her as we
Did you actually set up meetings with Ms. Conyers and

101
A.
Yes, we did have a meeting scheduled.
Q.
Did you meet with her?
A.
No, I did not meet with her.
Q.
Why is that?
A.
I either ran into her or either received a phone call,
I cannot recall exactly how it came about, but I did talk
with her and she had shared with me that she was not able to
make the appointment, that I was still supposed to, should
still come to her office and that I would be meeting with
10
somewhere there at her office.
11
Q.
12
Mrs. Conyers or her husband?
13
A.
14
a consultant, being in city hall, being involved in city
15
government.
16
Q.
17
cancelled the meeting.
18
A.
19
instructed.
20
office with Mr. Sam Riddle to discuss.
21
that he was there to receive me to discuss the issues
22
relative to Deja Vu.
23
Q.
24
with Sam Riddle?
25
A.
Had you had any prior contact, relationship with
I had had contact with her just in my regards of being
Now, you said you ran into Ms. Conyers and she had
What happened next?
Well, the meeting -- or I still went to her office as

When I got to her office, I met in her actual
It was understood
Did Ms. Conyers tell you why she wanted you to meet
That he was her representative.

102
Q.
And at that time what was your understanding of the
relationship between Sam Riddle and Monica Conyers?
A.
rumors sort of out in the consulting community, you know,
out throughout Detroit that, you know, that there was a
relationship between Ms. Conyers and Mr. Riddle.
one time --
At that time it was a little unclear.
MR. WISHNOW:
THE COURT:
I had heard some
I know at
I'll object to this, Your Honor.
Well, he's answered the question.
10
Let's wait for the next question.
11
BY MR. GARDEY:
12
Q.
13
whether Mr. Riddle held any position within Ms. Conyers'
14
office?
15
A.
16
time he had been her campaign manager.
17
sure if that was -- I would assume that was the capacity
18
that he was in on that day.
19
Q.
20
Mr. Riddle --
Mr. Jackson, did you have any understanding as to
I know at one time he was her chief of staff.
At one
I was not exactly
Now, the day you met with Mr. Riddle -- is
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

he's wearing?
A.
103
He has on an argyle sweater and a blazer.
MR. GARDEY:
Let the record reflect that the
witness has identified the defendant, Mr. Riddle.
BY MR. GARDEY:
Q.
her personal office?
A.
Yes.
Q.
Now, each member of the City Council has offices in the
Now, you said you met with Mr. Riddle in Ms. Conyers',
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
Mrs. Conyers' husband?
A.
Yes.
Q.
And when was that?
A.
Back in the spring of '87 roughly through about '99.
Maybe spring of '99.
Q.
Is that spring of '87 to '89?
A.
I'm sorry, '89, '89, yes.
Q.
Is that when you were in college?
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.
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.
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.
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
Because we were not meeting with what I considered the
And if you had met, when you had scheduled a meeting
I, I actually was, you know, a little curious about

105
quote, but, you know, that they couldn't necessarily always
get along.
said that, you know, he was her chief of staff but that they
had to have a different relationship.
Q.
office with Mr. Riddle?
A.
started out the meeting.
me to read.
I think he might have used the word crazy.
He
What happened during your meeting in Mrs. Conyers'
Well, we talked about a number of things.
I believe he
He suggested a couple of books for
I'm not sure how we got on that subject.
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.
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.
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
I guess he or Mrs. Conyers was
Mr. Riddle asked you about a Greg Robinson who you knew

106
applying for work with Mrs. Conyers' office?
A.
Yes.
Q.
And after talking about books and the reference for
Mr. Robinson, did you talk about the Deja Vu issue?
A.
Yes, we did.
Q.
What did Mr. Riddle say about that?
A.
It seems to me that he understood the legal issues that
were at hand.
having been to law school, he seemed to understand the legal
Mr. Riddle, you know, being an attorney or
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.
15
Mrs. Conyers' office to discuss it further?
16
A.
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 he say why he wanted to meet with you outside of
I got the impression that because he had a Meridian
Did you arrange to have a second meeting with

107
Mr. Riddle after that first meeting at Mrs. Conyers' office?
A.
Yes.
Q.
Where did that meeting, the second meeting take place?
A.
That meeting took place at the Click Restaurant.
Q.
Where is the Click Restaurant?
A.
Click is on East Jefferson just east of I-75 freeway on
the south side of Jefferson.
Q.
Mrs. Conyers' office, was that in October of 2006?
Now, this first meeting with Mr. Riddle in
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?
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.
21
Meridian Management.
22
commercial, if you will, of the accomplishments of Meridian
23
Management or himself.
24
successes there in Colorado after that tragedy in assisting
25
I believe families there.
What kind of meeting was it?
At the meeting at the Click there was more focus on

Sam went into sort of a, what I call a
He talked about Columbine and his
He talked about some of the work

108
he had done with Meridian and that -- the value that he
could add, that if in fact if Meridian was brought into this
that Meridian could help, help us secure support from
Councilwoman Conyers.
Q.
hire Meridian Management in order to get Mrs. Conyers' vote?
A.
Yes.
Q.
What did he say?
A.
He laid out a couple of scenarios, one being that
Did Mr. Riddle say whether or not Deja Vu would have to
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.
18
hire Meridian Management?
19
A.
Did Mr. Riddle say what would happen if Deja Vu did not
Well, I got the impression that --
20
MR. WISHNOW:
21
THE COURT:
22
MR. WISHNOW:
23
24
25
Objection, Your Honor.
Wait a minute.
I'm sorry, he's talking about his
impression.
THE COURT:
The question was:
Did Mr. Riddle say
what would happen if Deja Vu did not hire Meridian?
Did he

say something?
Not your impression.
THE WITNESS:
THE COURT:
THE WITNESS:
109
Did he say something?
Yes.
What did he say?

We wouldn't get Monica Conyers'
support.
THE COURT:
Go ahead.
BY MR. GARDEY:
Q.
And what would happen if Deja Vu did not hire Meridian?
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.
14
what Monica Conyers would do to act actively against the
15
Deja Vu project if Meridian wasn't hired?
16
A.
17
our conversation.
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
Did Mr. Riddle describe at this meeting at the Click
Well, that could happen in a couple of ways based on

One, if in fact Deja Vu and I guess our

110
probably could be a need and you want to be preventive in
that regard from any of that occurring.
Q.
Did you take that as a threat?
A.
Yes.
Q.
Why is that?
A.
I took it as a threat because council president pro tem
I believe at that time having influence that there are many
gray areas as it relates to those type of establishments and
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.
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.
So Mr. Riddle had offered -- first he wanted Deja Vu to
$25,000.

111
Q.
staff to Gil Hill did you ever act as a consultant on a
matter that was pending before the City Council?
A.
No.
Q.
Why not?
A.
You cannot wear two hats at the same time.
have -- you can't be advising --
MR. WISHNOW:
Now, when, back in the '90's when you were the chief of
I'll object to the basis for this
witness' opinion as to that without a proper foundation.
10
THE COURT:
11
MR. WISHNOW:
12
area.
13
one.
What foundation do you want laid?

Whatever expertise he has in this
I believe when you talk about gray areas that may be

He's giving his opinion.
14
THE COURT:
15
BY MR. GARDEY:
16
Q.
The objection is overruled.
Go ahead.
Mr. Jackson --
17
18
You can't
MR. GARDEY:
I don't know if he had already
answered the question.
19
THE COURT:
No.
Start over.
20
BY MR. GARDEY:
21
Q.
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
Mr. Jackson, back in the '90's you were the chief of

112
consulting work or other work pending before the City
Council?
A.
No.
Q.
And why didn't you do that at that time?
A.
It was a conflict of interest.
office of an elected official advising that person as
relates to decisions that they make and at the same time
represent individuals who are doing business or who are
asking or looking for support or guidance as relates to
You cannot work in the
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.
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.
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?
That is why I left when I left the
Now, you testified that Mr. Riddle had said that he

113
A.
Adolph Mongo.
Q.
And who is Adolph Mongo?
A.
Adolph Mongo is a government relations marketing
consultant here in Detroit.
Q.
Deja Vu work in the fall of 2006?
A.
$1,500.
Q.
Did Mr. Mongo have any experience in connection to
strip clubs and their business before the City Council in
And what did you pay Mr. Mongo to assist you with the
10
Detroit?
11
A.
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.
15
been successful in his endeavor to do that.
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.
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.
Actually he did.
It came to my attention that
He had
This was more
And Mr. Riddle, based on what Mr. Riddle told you and
No.

114
Q.
Based on Mr. Riddle, what Mr. Riddle told you, did you
leave that meeting at the Click with any certainty as to
whether you would get Mrs. Conyers' vote if you hired
Mr. Riddle as a consultant?
A.
support, yes.
Q.
did you set up a meeting between Mr. Riddle and the people
at Deja Vu?
I felt confident that if he was hired we would have her
After your second meeting with Mr. Riddle at the Click,
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.
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.
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.
And was that because you believed that it was important
It took place in Andiamo's in Dearborn I believe on
Not very long after.

115
Q.
Just a few days?
A.
Yes.
Q.
Now, did you go to the meeting in Dearborn with
Mr. Riddle or separately?
A.
I believe we were separate.
Q.
And what happened at the meeting?
A.
I believe Mr. Riddle may have come in a little late.
He came into the meeting.
Q.
How was he dressed at the meeting?
10
A.
From what I recall, he had maybe University of Michigan
11
paraphernalia on.
12
way to the Michigan-Ohio State football game in Columbus, if
13
I'm not mistaken.
14
He --
I believe he had -- he said he was on his
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.
21
secure Mrs. Conyers' vote?
22
A.
23
secured.
24
Q.
And how much did he ask for getting her vote?
25
A.
$25,000.
What did Mr. Riddle say as to whether or not he could
He told us that by hiring him that her vote could be

116
Q.
Did Mr. Riddle talk at all as to whether the vote was
going to be close or not close?
A.
way the council had lined up that, you know, without her
vote they would probably not prevail.
Q.
Mr. Riddle say anything about what Mrs. Conyers would do if
Deja Vu did not hire Mr. Riddle?
A.
He made it clear that she was a swing vote, that the
Now, at the meeting at Andiamo's with Deja Vu did
Well, that we would not get her support and that in
10
fact she could work against us.
11
Q.
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.
23
the case, but we didn't get into a lot of detail.
24
25
Did you, based on what Mr. Riddle said, did you take
There may have been just some general discussion about
THE COURT:
Bring the mike a little closer.
are letting your voice drop slightly, please.
You
Thank you.

117
BY MR. GARDEY:
Q.
Ms. Conyers' vote, what was the reaction or what happened at
the meeting?
A.
were surprised, taken off guard.
that that was, one, excessive, just buying -- they looked at
it as if it was buying a vote.
After Mr. Riddle quoted the price of $25,000 for
The gentlemen, they were -- I guess the best word, they
MR. WISHNOW:
10
THE COURT:
They, I guess they felt
Objection, Your Honor.
No, you can't say what they looked at.
11
The question -- what was your question?
12
BY MR. GARDEY:
13
Q.
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?
20
A.
Pretty abruptly.
21
Sam.
22
dialogue.
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.
What was the reaction of the people at Deja Vu to
How did the meeting end?

They were not supportive of hiring
They didn't want to really continue on with any more

Sam had his football game to get to and pretty

118
Q.
Did Mr. Riddle leave at that point?
A.
Yes.
Q.
Did you have further discussions with Deja Vu at the
Andiamo's Restaurant after Mr. Riddle left?
A.
Yes.
Q.
Did you make any proposal to the Deja Vu people
regarding Mr. Riddle?
A.
I proposed that Jackson Consulting could hire
Well, I saw their discomfort in contracting Sam and so
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?
24
A.
25
pay the $25,000 in order to get the vote of Councilwoman
What do you understand that to mean?
I was being pressured to have to in one way or another

119
Conyers.
Q.
the Deja Vu people, did the license transfer issue come up
for a vote in the Detroit City Council?
A.
Yes.
Q.
And did that take place on November 15, 2006?
A.
Yes.
Q.
And what was the vote?
A.
The transfer was not approved.
Now, after the meeting at Andiamo's with Mr. Riddle and
It was denied.
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?
15
A.
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.
24
voting down of the license, what impact did that have on
25
your business for credit card processing?
How did you feel?
Somewhat dejected, if you will.
I had put in a lot of
And what impact did the loss of the license or the

120
A.
Well, I could have spent a lot of time going after
business in other areas.
on the value of potentially securing this as a customer.
Q.
a share of the credit card processing at Deja Vu, would that
have been significant financially for you?
A.
Very lucrative, yes.
Q.
After the vote of 5-4 at the City Council, did you have
further contact with Sam Riddle?
I had put, had sort of put a lot
And if the license had gone through and you had gotten
10
A.
Yes.
11
Q.
What happened?
12
A.
Mr. Riddle and I, we met.
13
upon myself.
14
hiring him directly.
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.
18
I met with Sam Riddle and had agreed to contract
19
Meridian Management, for Jackson Consulting to contract
20
21
Q.
22
additional meeting with Mr. Riddle about Jackson Consulting
23
hiring Mr. Riddle and Meridian Management?
24
A.
25
still a way that there could be a reconsideration.
At that point I had taken it
I knew that the Deja Vu group did not support

I felt that as far as if they would --
So
Now, how was it that after the vote you had this
Well, I talked to Mr. Riddle.
He felt that there was
There is

121
a certain period of time after a vote that a councilperson
could reconsider.
the clerk's office for reconsideration and that if in fact
that could be a sign, if you will, of certainly his
effectiveness in that he could get her to reconsider.
Q.
And that's what Mr. Riddle offered to do for you?
A.
Yes.
Q.
And what price was he asking?
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.
16
would pay him a success fee.
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.
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
They could actually put in a letter to
I told Sam that I would pay him a retainer and I

And so we had decided that I
When you say we decided to do a retainer, who is the

122
Mr. Riddle agreed to?
A.
15,000.
Q.
with the $10,000?
A.
The reconsideration.
Q.
And how about for the 15,000?
A.
The successful vote as it relates to the transfer of
the license.
The retainer was $10,000.
The success fee would be
And so what was your understanding what you were buying
10
Q.
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
16
Did you meet with Mr. Riddle and deliver him those
THE COURT:
Excuse me.
You gave him two checks at
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.
24
evidence as Government's Exhibit 22B.
25
Mr. Jackson, I'm handing you what's been entered into
THE COURT:
B?

MR. GARDEY:
123
22B as in boy and 22D as in Delta.
BY MR. GARDEY:
Q.
identify what they are.
A.
Meridian Management Systems dated 11-16, 2006 for $10,000.
The memo section says consulting services retainer.
Q.
And is this the retainer amount that you said was meant to
Would you please take a look at those two documents and

First 22B.
22B is a check from Jackson Consulting Group, L.L.C. to
That's down in the lower left-hand corner of the check.
10
pay for Mrs. Conyers' reconsideration vote?
11
A.
12
Yes.
MR. GARDEY:
Okay.
Could you enlarge the back of
13
the check.
14
BY MR. GARDEY:
15
Q.
16
of the $10,000 check, what's the stamp on the right side of
17
the back of the check?
18
A.
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.
24
the memo section it says, "Consulting."
25
Q.
And what's the, on the back of the check, Mr. Jackson,
It says, "Pay to the order of Comerica Bank, Detroit,
So the $10,000 was for Mrs. Conyers to file for
In

124
reconsideration, and the $15,000 was a success fee if the
license transfer actually was voted successfully in the City
Council; is that correct?
A.
Yes.
Q.
Did you ask Mr. Riddle anything about the second check
for $15,000?
A.
At that time?
Q.
Yes.
anything?
Yes.
Did you ask him to do anything with it or not do
10
A.
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.
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.
Now, before you proposed the idea of two separate
I believe later on that day there was a letter that

125
went into the city clerk's office from Councilwoman Conyers
for the reconsideration of the transfer.
understanding to get it back onto the docket for Council to
vote.
Q.
Would you please take a look at that and state what it is.
A.
Council President Pro Tem Monica Conyers, date November 17,
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.
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.
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
So that's my
Mr. Jackson, I'm handing you Government's Exhibit 23.
"Memorandum to Janice M. Winfrey, City Clerk, from
Mr. Jackson is this the reconsideration that you spoke
My understanding was that a reconsideration could only

126
to reconsider in writing.
Q.
necessarily a declaration that the person is going to change
their vote, just that they are going to reconsider; is that
correct?
A.
Yes.
Q.
Did Mr. Riddle say anything to you about the
reconsideration filed by Mrs. Conyers?
A.
And the, this notice of reconsideration, it's not
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.
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.
During your discussions with Mr. Riddle right after the
Can you clarify as far as what may have occurred?
I'm

127
sorry.
Q.
were there other meetings of the City Council or were there
other presentations?
A.
No.
Q.
After she filed the notice of reconsideration was there
another meeting of the Detroit City Council?
A.
No.
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.
20
reconsideration and to have a new vote.
21
Q.
22
Mrs. Conyers filed for reconsideration?
23
A.
24
I'm not sure of the exact date.
25
Q.
Was there any -- before she filed for reconsideration
The purpose of that meeting was to take up the
And did that meeting take place the day after
I'm not sure if it was the day after or two days after.
Soon thereafter?

128
A.
Yes, sir.
Q.
Now, you said that pastors and other people appeared
before the City Council.
A.
to give testimony as relates to their disapproval of any
reconsideration.
denied previously, and they wanted that vote to stand.
had moral objections to a cabaret D license, and they
pressed those objections at that meeting.
What happened?
They were allowed to testify and speak at the Council,
They were happy that the transfer had been

They
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.
15
not willing to or did not interact very much with the
16
ministers.
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.
21
end of that meeting?
22
A.
23
another councilperson, I believe it was her, asked that the
24
matter be tabled.
25
Q.
She was
She didn't say very much at that meeting.
She
And at the -- what happened with Mrs. Conyers at the

What happened?
At the end of the meeting either it was Mrs. Conyers or
And what does that mean?

Tabled.
129
A.
They were -- I believe it was the last meeting
before council was to recess for the year, and tabled means
that the matter is no longer -- will not be taken up, that
the vote will not be taken and it was tabled until next year
or until the following year.
Q.
Council that meant that there would be no actual revote on
the issue of the license transfer for Deja Vu until January
of 2007; is that correct?
And so because the matter was tabled in the City
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.
15
but to pursue or move forward with the litigation.
16
Q.
17
second City Council meeting?
18
A.
19
the vote of the councilperson who had reconsidered,
20
Monica Conyers.
21
that he later was not even in town.
22
Flint or somewhere.
23
and so I felt that I did not get the value of the money that
24
I spent.
25
Q.
That meant that it was dead, that they had no option
How did you react about what happened at this
Well, I had hired a consultant to assist in securing
He was not there at the meeting.
Found out
He was in Saginaw or
That was the explanation given to me,
You didn't get your vote?

130
A.
No.
Q.
After that did you take any action in connection to the
success fee, the $15,000 check?
A.
Yes.
Q.
What did you do?
A.
And I should say I got the value of my $10,000, but I
didn't get the value or did not warrant the $15,000 success
fee because there was no success.
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:
19
The government has one brief matter to bring up at
20
Just one moment, Your Honor.
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.
25
letter of agreement for professional services.
It's a

MR. WISHNOW:
MR. GARDEY:
131
I'm sorry.
And this is a document we have never
seen before and had not been produced by the defense and we
had asked them to produce any documents that they intended
to use as exhibits.
THE COURT:
Do you propose to use this?
MR. WISHNOW:
Actually we are not sure.
to see how the cross develops.
THE COURT:
I'm going
We may not.
Oh, no, you can't use this.
10
an obligation to deliver this in advance.
11
that.
You had
We talked about
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.
17
think this record will reflect both formally and informally
18
the Court telling you to produce your exhibits.
19
of fact, the last conference we had shortly before, I don't
20
know that it's reflected, but you knew this.
21
22
You are not allowed that much, Mr. Wishnow.
MR. WISHNOW:
The objection is noted.
As a matter
We'll move
forward.
23
THE COURT:
What?
24
MR. WISHNOW:
25
THE COURT:
We'll move forward.
I haven't read it.
I don't know what

its significance is.
MR. WISHNOW:
THE COURT:
You don't have to.
All right.
(End of discussion at side bar.)
MR. GARDEY:
THE COURT:
MR. WISHNOW:
THE COURT:
Never mind.
10
132
No further questions, Your Honor.

Cross-examine.
Thank you.
Can I see you back here one moment?

Go ahead.
I changed my mind.
The
judge always has that privilege, except at home.
11
Go ahead.
12
MR. WISHNOW:
13
Thank you.
-
14
CROSS-EXAMINATION
15
BY MR. WISHNOW:
16
Q.
17
I'm one of Sam Riddle's attorneys.
18
A.
Good morning.
19
Q.
Edward Wishnow.
20
A.
Wishnow.
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?
Good morning, Mr. Jackson.
My name is Edward Wishnow.

How are you?
I'm sorry, what's your name sir?
Good morning.
Christopher Jackson - Cross

133
A.
Yes.
Q.
In fact, you were involved in putting together the
Greektown Casino deal?
A.
Yes.
Q.
And your group, I think it's called Monroe Partners?
A.
Yes.
Q.
Became a significant -- had a significant ownership
interest in that casino, correct?
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
Q.
But it most likely did require some up front fee,
correct?
A.
Yes.
Q.
Pardon?
A.
Possibly.
Q.
You don't remember the amount of the retainer involved,
correct?
A.
No.
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.
15
or some credit card processing business.
16
Q.
17
interested in giving you a piece of the ATM pie; isn't that
18
correct?
19
A.
That's correct.
20
Q.
Because that was a very significant revenue stream for
21
them?
22
A.
23
relationship with some other entity.
24
Q.
25
get involved in the credit card processing business?
There would be a retainer involved.
As well as sharing in or having access to ATM machine
Well, at some point they told you they weren't
They had already contracted with or already had a
And there was some interest possibly in allowing you to

135
A.
Yes.
Q.
And you already had such a business, did you not?
A.
Yes.
Q.
You indicated that at one point you did meet with
Sam Riddle and your first meeting directly with him was at
the Click Restaurant on East Jefferson?
A.
That would have been the second meeting.
Q.
After the meeting in chambers, I'm sorry.
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
24
believe there was something emailed to me or either given to
25
me.
I don't actually have it, but I

136
Q.
And that, unlike the contract you attempted to have
with HDV/Deja Vu, that contract was not signed, was it?
A.
No.
Q.
That contract that was sent to you from Sam Riddle had
a no conflicts provision in it?
A.
the contract.
Q.
recall now?
I don't recall.
L I don't recall.
I don't remember
You didn't give it much thought or you just don't
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.
17
was.
18
people in general.
19
Q.
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.
I knew of him.
I didn't know exactly what his vocation
I knew of him through the media and through other
And did you know that he was involved in
And at your meeting with him he gave you information

137
about himself and Meridian, did he not?
A.
Yes.
Q.
Somewhat touting all the good things that he had done
during his career as a consultant?
A.
Yes.
Q.
And some of those were incidents that you were well
aware of, such as Columbine, correct?
A.
Yes.
Q.
And you knew those, you believe those to be true, that
10
he was involved with those instances?
11
A.
12
involved.
13
idea who was representing the family members and that kind
14
of thing.
15
Q.
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.
24
Q.
You could have?
25
A.
Yeah.
Oh, I had no idea if he actually, he himself was

He shared with me that he was.
I had, I had no
And as we sit here today you have no reason to
I'm not sure.

138
Q.
And would the terms of his engagement with you have
been discussed at that time?
A.
Possibly.
Q.
And would he -- do you -- well, when you met with him
at the Click Restaurant did he discuss with you that he was
there acting as a consultant pursuant to
Meridian Management?
A.
Yes.
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.
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
Okay.
Did you tell either Mr. St. John or Mr. Hall

139
Deja Vu, correct?
Well, let me put that in context, excuse me.
Before you gave your $10,000 check to Sam Riddle,
by that time you had expended significant time and energy
into trying to help out Deja Vu Consulting, correct?
A.
Yes.
Q.
And up until then you had not received any
reimbursement, I mean you hadn't received any compensation
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.
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
Consulting retainer, correct.

140
you, did he not, why a consultant would be important in
dealing with a strip club that was trying to locate in
downtown Detroit?
A.
Yes.
Q.
And you accepted those reasons and they were valid,
were they not?
A.
I accepted the reasons that a consultant was needed.
Q.
And I think you have touched upon some of those; that's
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.
21
of Meridian Management could do, yes.
22
Q.
23
consulting services was being offered, that is, the context
24
of a strip club being located downtown?
25
A.
That's what was being sold to me in what the services
But you understood the context within which this
I was hiring Meridian Management to assist in getting

141
Monica Conyers' vote for the transfer.
Q.
his consulting services could help with other areas involved
with a strip club in downtown Detroit?
A.
transfer that Meridian Management services would also be
needed for other governmental type things because, because
of the gray areas, because of the potential for getting
tickets and other types of --
Sam Riddle though discussed with you, did he not, that
After a vote would be taken if they were to get a
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.
23
I don't look at that business as tawdry or anything.
24
just not an area that I focused on.
25
Q.
Well, as a correction, I never pass any disparaging --
Okay.
It was
I focused on financing.
But Mr. Riddle explained to you that this was an

142
area that he could work in and would feel comfortable in
working, correct?
A.
Yes.
Q.
And before you went to Andiamo's, before the meeting at
Andiamo's did you explain to Mr. St. John and Mr. Hall that
Mr. Riddle could be a valuable consultant in these so-called
gray areas with government as far as a strip club in
downtown Detroit?
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.
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?
21
A.
That's correct.
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
Knowing that, they came to this meeting in

either, did they?
2
3
THE COURT:
I think those are argumentative
questions.
4
5
143
MR. WISHNOW:
Thank you, Your Honor.
I'll move
on.
THE COURT:
MR. WISHNOW:
BY MR. WISHNOW:
Q.
They have to be reformulated.

Thank you.
They did not want to pay you up front money either, did
10
they?
11
A.
12
did not reach an agreement on any of this.
13
Q.
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.
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?
I don't recall them saying actually they did not.
We
Well, you had asked for up-front money as part of your
The vote came up for --

144
A.
Yes.
Q.
And Monica Conyers, you believe, tabled that vote?
A.
I'm not sure if it was her or one of her colleagues.
Q.
But you were at that meeting?
A.
The vote was tabled.
Q.
You were at that meeting?
A.
Yes.
there.
Q.
I was in and out of the room, but yes, I was
Okay.
And you did not see Monica Conyers vocally favor
10
a vote in favor of Deja Vu, did you?
11
A.
No.
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?
They didn't vote.
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:
23
MR. WISHNOW:
24
If I could have one moment.
25
THE COURT:
I said the question is argumentative.

Thank you, Your Honor.
You may.

145
BY MR. WISHNOW:
Q.
councilman and a council president, were you a full-time
employee?
A.
Yes.
Q.
And did that cover -- did you have fringe benefits on
that job?
Sir, when you worked with Gil Hill, who was a
MR. GARDEY:
THE COURT:
10
Objection, Your Honor, relevance.

What is the arguable relevance of what
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.
14
15
THE COURT:
No, no, no, no.
MR. WISHNOW:
17
THE COURT:
Your Honor, we have evidence that --
I said I have sustained the objection,
but he can answer.
19
MR. WISHNOW:
20
THE COURT:
21
I'm sustaining the
objection.
16
18
We have evidence in --
Thank you.
Did you get fringe benefits when you
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
BY MR. WISHNOW:
Q.
normal work year?
A.
You said 2,000 hours --
Q.
Hours.
A.
-- a week?
Q.
No.
normal work year, about 2,000 hours if you had two weeks off
or thereabouts?
10
A.
Did you work for close to 2,000 hours a week like a
Did you have an arrangement where you worked a
Yes.
11
MR. WISHNOW:
Okay.
Thank you.
12
MR. GARDEY:
13
THE COURT:
14
Do you want to start with another witness or wait

The witness is excused.
15
until Friday morning?
16
MR. GARDEY:
17
short testimony about Deja Vu.
18
THE COURT:
19
THE WITNESS:
20
THE COURT:
21
Go ahead.
22
MR. GARDEY:
23
24
We have Agent Lubisco just to have
Would you wait in back a few minutes.

Yes.
Thank you.
The United States calls Special Agent
Mike Lubisco.
-
25
Michael Lubisco - Direct

147
DIRECT EXAMINATION
BY MR. GARDEY:
Q.
you gather bank records concerning the Deja Vu scheme?
A.
Yes, I did.
Q.
Did those bank records include the records for Meridian
Management, an account at Comerica controlled by Sam Riddle?
A.
Yes, they did.
Q.
Agent Lubisco, I'm handing you what's been marked and
Agent Lubisco, in the course of the investigation did
10
entered into evidence as Government's Exhibit 22C and 22E.
11
Would you please identify those.
12
A.
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.
19
amount of $15,000.
20
Q.
21
slip?
22
A.
23
24
Q.
25
Government's Exhibit 22A.
First 22C.
22C is a deposit into the Meridian Management account
It's on November 27th, 2006, and it is for the
And is the name of Sam L. Riddle also on the deposit
Yes, it is.
Samuel L. Riddle, Jr.,
Agent Lubisco, I am handing you what's been marked

Would you please state for the

148
record what that is.
A.
Meridian Management Systems.
November 30, 2006.
Q.
please, and under the deposits.
A.
November 17th for $10,000, one on November 27th for $15,000.
Q.
It's a copy of a statement from Comerica Bank for

It's for November 1st, 2006 to
Would you turn to the second page of Exhibit 22A,
The bank account shows two deposits, one on
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.
15
$15,000 was taken out of the account.
16
Q.
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.
22
November 9th for $4,000; the second on November 20th for
23
2500; and then on November 27 also for 2500.
That on Page 3 is a returned item chargeback, meaning
Any understanding as to why 15,000 would be charged
There are three withdrawals:
The first one on
24
MR. GARDEY:
Just one moment, Your Honor.
25

THE COURT:
MR. WISHNOW:
149
Cross.
Oh, I'm sorry.
No questions,
Your Honor.
THE COURT:
MR. GARDEY:
Thank you.
The witness is excused.
Your Honor, our next witness was
going to be Agent Lubisco concerning a different scheme,
and --
8
9
THE COURT:
I think we should start Friday
morning.
10
MR. GARDEY:
11
THE COURT:
Thank you.
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.
17
18
19
20
21
You don't
have to haul it in and out.

(Jury out at 12:40 p.m.)
THE COURT:
You can sit down.
We'll just wait
until the jury clears the floor.

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

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Joseph Hall - Redirect

Wednesday/January 27, 2010/Volume 3

later point asked for reconsideration of the vote.

has been no further -- there was no further testimony

regarding the disposition of the motion for reconsideration,

the request for reconsideration.

Secondly, Mr. St. John testified that when

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

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

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

The United States calls Chris Jackson

In front of me, sir.

Raise your right

being first duly sworn by the Court to tell

the truth, was examined and testified upon his

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

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

Christopher Jackson - Direct

Please state your full name for the record and

spell your last name.

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

Your Honor, at this time the

government would move Exhibits 22A through E and Exhibit 23

Those are the Deja Vu exhibits.

Mr. Jackson, how are you employed?

What is your business?

I own a couple of businesses.

Consulting Group, L.L.C.

and I am also a partner in Detroit Credit Card ATM

I am also a partner in Paradise

I am a partner in Queen Lillian, L.L.C.,

Pull the mike a little closer to you.

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

Where are you from originally?

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

Christopher Jackson - Direct

Were you born and raised here?

What's your educational background?

Went to grade school here in Detroit, St. Phillips

from Cass Tech High School.

received a degree there.

attended the University of Detroit Law School, did not

Went to Cass Tech High School, graduated

Upon graduating I actually

graduate, did three years there.

Now, after, what do you do after you left law school?

While I was in law school, I was actually in law school

Councilman Gil Hill.

graduating from Howard University.

I believe it was 1991.

Was that Detroit City Council?

When you started with Councilman Hill's office, what

was your position?

I was working in the employ of Detroit City

What year did you start working for Councilman

At that time I was an administrative assistant handling

How long did you work for Councilman Hill?

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

Christopher Jackson - Direct

Approximately about eight years, seven years.

What year did you leave Councilman Hill's?

Somewhere around 1997.

Did you hold any other positions with Councilman Hill?

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