IN THE SUPERIOR

COURT OF THE STATE OF ARIZONA

IN AND FOR THE COUNTY OF PINAL MARTIN MCDONALD, a married man, Plaintiff, vs. CITY OF MARICOPAj KOLMAN, and ROGER Defendants.
)
) )

)

) No. CV2010-00775
)

)
)

)
) )

DEPOSITION

OF CORRINE WILCOX-CORNN

Phoenix, Arizona September 24, 2010 1:30 p.m.

PREPARED FOR: MS. CLAIR W. LANE ATTORNEY AT LAW

Ottma«

& A~eY,

IVlD.

2800 N. Central, Ste. 150 Phoenix, Arizona 85004 (602) 485-1488 l-866-485-1444

(COpy) Reported by: Robin Jasper, RPR CCR No. 50286

Corrine wilcox-Cornn
Page 2
1

9/24/2010
Page 4 CORRINE WILCOX-CORNN,

2

DEPOSITION

OF CORRINE WILCOX-CORNN, commencing

taken on

1

2 September 24,2010,

at 1:37 p.rn., at the law

2 a witness herein, having been first duly sworn by the 3 Certified Reporter to speak the truth and nothing but the
4

3 offices of THE DOYLE FIRM, P.C., 1313 East Osborn Road, 4 Suite 100, Phoenix, Arizona, before ROBIN JASPER, a 5 Certified Reporter in the State of Arizona. 6 7 COUNSEL 8 9 10 11 12 13

truth, was examined and testified as follows: EXAMINATION Q. Can you give me your full name and address, A. My full name is Corrine Elisa Wilcox-Cornu, and

5 6

APPEARING:

7 BY MR. DOYLE: 8

TIIE DOYLE FIRM, P.C. BY: Mr. William H. DOXie 1313 East Osborn Road, Suite 100 Phoenix, Arizona 85014 Attorneys for Defendants BY: Mr. Clair William Lane One West Elliot, Suite 106 Tempe, Arizona 85284 Attorneys for Plaintiff

9 please. 10

11 my address is at 44028 West Maricopa Avenue, Maricopa, 12 Arizona,85138. 13 14 15 16 17 18

Q. Have you ever been deposed before? A. A. A. A long time ago, yes. It was a sexual harassment suit. Brought by a lady named Gena McVicers and it was Incorporated. Q. In regards to what? Q. Brought by whom?

14 ALSO PRESENT: 15 16 17 18 19 20 21 22 23 24 25

Mr. Martin McDonald

19 against Native American Air Ambulance, 20 21

Q. And how were you deposed in that case? A. Somewhere here in town, I can't remember, I want

22 to say 3200 South Central and I was put in an office and 23 they asked a bunch of questions. 24 25

Q. How were you involved? A. Ijust witnessed the behavior that occurred and Page 5

Page 3
1 2 WI1NESS 3 CORRINE WILCOX-CORNN 4 5 6 7
8

INDEX PAGE BY MR. DOYLE BY MR. LANE 4 48

1 things that were going on at the office. 2
3

Q. and -A. Q. A. A. Q. A. Q.

SO you recall that you need to answer out loud Yes. -- preferably with a yes or no? Yes. Yes. I will tell you, if you don't understand one of Okay. Okay? I will do whatever I can to make sure you it. But if you don't, I don't want you to

EXAMINATION EXAMINATION

4 5 6 7
8

Q. And let me finish my questions.

9 10 EXHIBITS 11 No.1 12 No.2 13 14 15 16 17 18 19 20 21 22 23 24 25

EXHIBITS DESCRIPTION MARKED 52 Release Questionnaire Memo to Corrine Wilcox-Cornn from Martin 1. McDonald, dated 1-10-08, Re: Colliigiate Pacific Purchase Order; Pure ase Requisition; Invoice Invoice from Midwest Premiums & Promotions, dated 8-29-07

9

10 my questions, I want you to tell me. 11

66

12

13 do understand

No.3

70

14 answer it. 15 16

A.

Okay. what my

Q. But if you go ahead and answer without saying

17 anything, I'm going to assume you understood 18 question was. Fair enough? 19

A. That's fair enough.

Can I -- I have to confess a I have problems with I have

20 little challenge in that

I'm hearing impaired. So you are
because I have lost the low end

21 going to have to speak very clearly. 22 men's voices particularly,

23 of the spectrum, as far as hearing is concerned.

24 lost 75 percent of my hearing, so I will sit here and do 25 this so I can hear you. I did put in my hearing aid. So

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 6
1 just so you know. 2 3 4

9/24/2010
Page 8 in the town that I was living in at that time.

3

1 companies

Q. Q.

I'll try. Lucky you. If you don't hear me, just say Okay? I don't have a typically low voice, so

2 Let's see. I think that kind of -- Lots of bookkeeping 3 jobs.

A. The thing I hear really good is the fan.

I did a lot of audit work. I worked as a staff for a CPA firm in Fillmore, California, which And I did that for a few Then moved to Arizona and

4 accountant

5 something.

S is right next to Santa Paula. 6 years, those kinds of jobs.

6 maybe it won't be as much of a problem. 7 8 9 10 11 12

How old are you? A. I am 52. And are you a life-long Valley resident? Where were you born and raised? I was born in San Jose, California, and I was You completed high school? I completed high school, yes.

7 went to work here for a CPA firm. 8 9 10

Q.
A.

Let me stop you for a second. Sure. Recall for me as best you can who you actually Okay. Let's see. It's been a while. I worked I had my own

Q. Q.
A.

A. No.

Q.
A.

11 worked for before you relocated to Arizona. 12

13 raised in Santa Paula, California. 14 15 16 17 18 19 20 21

13 for Sambo's, I worked for Vicovick Ranches, Incorporated, 14 I worked for Cowell & Barrow, CPA's.

Q.
A.

15 business for probably about five years doing accounting. 16 That was just a Schedule C business. 17 Alpenlite.

Q. From where? A. I -- actually, from Santa Paula Union High.

I worked for I worked

I can't remember the parent company.

Q. Q.
A.

And do you have education after high school? What education do you have? I have an associate's of arts degree from Ventura College. That's Ventura, California. I also of science degree from Ventura I have subsequently Page 7

18 for an equipment

company, and I can't remember the name of or something like that. I California was so long ago.

A. Yes.

19 it. It's like Power Equipment, 20 can't remember their name. 21 22 23 24

Q.
A.

When did you move to Arizona?

22 Community

In '86.
Were you still married at the time? I was married at the time, yes, when I moved to Page 9

23 have an associate's 24 Community

Q.
A.

College in accounting.

2S acquired a bachelor of science degree and it has a minor

25 Arizona.

1 in accounting.
2

I also have a master's degree in business and I'm currently working on my doctorate

1 2 3 4 5 6 7 8 9 10 11 12

Q.
A.

How many times have you been married? I have been married three times. And your first husband's name was? Steven. Oris? And where does he live? He lives in Chandler. I was married to Mr. Phelps for 16 years.

administration,

3 in business administration.
4

Q.
A.

Q.

Where did you get your B.A. degree from? of Phoenix.

s
7 8 9 10
11

A. My B.A. and my M.B.A. and my doctorate are all

Q. Q.
A. A. A.

6 from the University

A. Yeah, he's still alive. Steven R. Phelps.

Q. Q.
A.

When do you expect you will be done with your -Yes. In 2014. And what is the topic of your doctorate, or My thesis is actually in sustainable governments. When did you -- Well, give me the progression of college, what you did

A. Doctorate?

Q. And how long were you married to Mr. Phelps? Q. And where did the marriage take place?

Q.
A.

12 field? 13 14

In Ojai, California.
And the divorce took place in Maricopa County? In Maricopa County. And then who were you married to the second time? When did that marriage take place? It took place in '94. In Maricopa County? And how long were you married to Mr. Wilcox? I got divorced in '97. Again, in Maricopa County? In Maricopa County. And you are currently married?

13 14 15 16 17 18 19 20 21

Q.
A.

Q.

15 after you graduated from community 16 and what your work history was. 17

Q. Q.
A.

A- I was married to David Wilcox.

A. I have worked for a wide variety of companies in I started out as actually a payroll clerk at a it. I worked It

18 Ventura County, and even in L.A. County in accounting 19 positions.

Q. Q.
A.

20 company called Sambo's, if you guys remember

A. No, that's not right. '93. In Maricopa County.

21 there for a while, then I worked for several farming type 22 operations,

doing accounting, full-charge bookkeeping. After that I did some retail stuff. I

22 23 24 25

23 included payrolL

Q.
A.

24 started having babies.

So I did accounting services where

25 I did some audit work, as well as worked for different

Q.

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page ]0
1 2 3 4

9/24/2010

4
Page 12

A. No.

1 2 3

asking questions. He was at the newest city, and being their city was similar to our city in that they were experiencing very high levels of growth at that time. And just to get some insight of how they were handling certain things. They were at a much higher speed than we were growing, but they had some of the same revenue issues that we did. So I talked to him several times about how they dealt with those kind of things, planning and budgets, and dealing with those kinds of things at that time. So I only knew him on the telephone. I had never met him in person. Q. Were you living in Maricopa? A. I was living in Queen Creek at the time, in the Johnson Ranch area. Q. When did you move to Maricopa?
A. I moved to Maricopa in 2006.

Q. You married Mr. Cornn? A. I married Mr. Cornu in '99. Q. Again, in Maricopa County? A. Actually, I married him in Las Vegas, so. Q. And when did you divorce Mr. Cornu? A. Mr. Cornu, I divorced him in 2006. Q. In Maricopa County? A. In Pinal County. Q. SOyou moved to the Valley in 1986 to do what or why? A. We just wanted to get out of California. It was going to -- my girls were getting ready to start school, and we felt that Arizona would be a better place than the trend that California was taking at that particular time. Q. And where did you originally live? A. In Chandler. Q. And work? A. I worked for a CPA firm, Spero, Hougham & Mazza, and they were in Phoenix. Q. How long did you work for the CPA firm?
A. I'm going to say like 18 months.

4 5 6
7 8 9

5 6
7 8

9 10
11

10 11 12 13 14 15 16 17 18 19 20
21 22 23

12 13 14 15 16 17 18 19 20
21

Q. Why? A. Because it was a very long drive from Queen Creek to Maricopa. And I was in a divorce situation, so it was just easier to move there. I had to move anyway, so. Q. How many times would you, do you believe that you had spoken to Roger Kolman before the conversation in which he suggested that you apply for ajob with the City of Maricopa?
A. Maybe two or three times.

22
23

Q. And then where did you work? A. I worked for -- Good grief. Q. It's not a test. If you don't remember, just say Page 11 you don't remember. A. I don't remember. I think I want to say that I worked for Walt's Jewelers for a couple years. Q. And then run me the progression. A. Then I worked for about six and a half years for a company called Elite Fashions International. And they were a chain of retail stores that did high-end Italian shoes. Q. How did you make your way to Maricopa?
A. I had just finished a job and had been working

24 25

24 25

Page 13
1 2 3 4 5

1 2

Q. It was purely a professional relationship?
A. Purely.

3 4
5

Q. What job was opening up at Maricopa?
A.

Senior accountant.

Q. Did you understand that you would be working for Mr. Kolman? A. Yes, I did. Q. Had he explained the job to you Orgiven you any detail of it prior to your application? A. He told me that the job was open and he thought I might be good at it and that I should probably apply and stuff. And that's all I did. And more than that, he told me where to check the web site, that kind of stuff. He didn't give me any more information than that. Q. Did he participate in your interview? A. Yes, he did. Q. Who else was at your interview? Do you recall?
A. Rick Buss was there, and I'm trying to -- I

6 7
8 9

6 7
8

9 10
11

10 11
12 13

for the City of Queen Creek for a year as a budget analyst, and the opening became available -- I actually knew Roger from talking to him on the phone a few times. And he told me the job was open and he asked me to apply for it, and I did, and I got the job. Q. SOat some point you worked for the City of Queen Creek?
A. Yes.

12
13

14 15 16 17 18 19 20 21 22 23 24 25

14 15 16 17 18 19 20
21 22 23

Q. How long did you work for them? A. I worked for them for about a year. Q. As a budget analyst?
A. As a budget analyst.

remember it was a female, and I'm going to say it was Debra. I don't know why I can't remember her name. She handled the permitting desk. I can't think of her name right now. Anyway, so somebody from permits. Q. And only one interview?
A. Just one interview.

Q. How did you know Roger Kolman?
A. He was the budget -- excuse me, he was the

24 25

finance director from Maricopa. And I only knew him from

Q. Then you were offered the job?

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 14
1

9/24/2010
Page 16

5

A. A.

Then I was offered the job. I worked for the City of Maricopa from 2005 until

1

Q. What injury did you suffer? A. I had a stroke, and that's how I lost my hearing. Q. SO you quit shooting, I take it? A. Yeah. That's one of the things they told me not

2
3

Q. How long did you work for the City of Maricopa?

2
3

4 2009. 5
6 7

4

Q. And why did you leave? A. I was laid off. Q. Because ofthe slowdown in growth? A. Yeah, because of the slowdown in growth. Q. Was Roger Kolman your supervisor the entire four A. No. The last year, Kevin Evans was my supervisor the last year. Q. Did your position remain senior accountant? A. No. I was a senior accountant and then I became budget analyst, and then I became senior to the budget manager, and I The budget -- no, I went from the budget

5 do to. I can't go to concerts, I can't go race car 6 driving and I can't shoot again -- shouldn't shoot again.
7

It's very bad for me. Q. I would kill myself. A. You know what, I'm very careful. I have actually I had to try out my new gun.

8
9

a
9

10 years?
11 12

10 gone one time already.
11

Q. How did you first meet Mr. McDonald? A. He was on staff when I got to Maricopa. Q. What was his position when you arrived? A. His position, he handled PRL. I didn't know his

12
13

13
14

14

15 senior accountant 16 accountant.

15 formal title until later . And that's all I knew at the 16 time. 17 18 19
20

17 analyst and senior accountant
18

Q. What did you understand PRL? A. A. Q. Oh, the Parks, Recreation & --- Library. Thank you. Q. And Library? SO you met him because you went to work for the

ended up budget manager.

19
20 21

Q. And that would have put you under Mr. Evans'
supervision? A. A. Yes. One year.

21

22
23

Q. How long was Mr. Evans your supervisor? Q. And Roger was your supervisor the previous three? A. Yes.
Page 15 Q. Did you receive annual reviews? A. I don't think it was as formal the first probably Just

22 City of Maricopa?
23

A. Right. Q. You had never met Mr. McDonald before that? A. Right. Page 17 Q. Did you work particularly closely with him? A. No more than any of the other managers, about the Q. Or department heads? heads, yes.

24 25

24 25

1 2

1 2

3 couple of years as it was the last couple of years.

3 same. 4
5

4 new city, a lot of other things to deal with, and so -5 6 7

and we didn't have an HR person, either. I did get annual raises, but I did not get a formal review.

A. Department

6 7
8

Q. Tell me the level that that would involve. A. When I first got there, I was -- we basically divided up duties. It was Roger and myself were the when I first got there. There was the

Q.

Did you get what you thought you were appropriate

a raises?
9 10
11

A. Yes, for where we were at, yes. Q. A. And did you -- Any review or comment on your work Not really. Roger and I worked very well Did you become friends with Roger? Just work friends. that you view as critical? together.

9 finance department

10 two of us. And basically, I handled all the purchasing.
11 12 13 14

It was just the easier one for Roger to divorce himself of. And it was a good separation of duties. He wrote the checks and paid for the vendors, and then I basically did the purchasing part and made sure all the authorizations So if needed to purchase something, he had to go

12
13

14 15 16
17

Q.
A.

15 and bidding and all that kind of stuff happened. 16 Mr. McDonald

Q. You didn't socialize with him outside of the workplace? A. I think I went to a home -- when he first moved He had a house warming, went to to town, he had a home -- I can't think what that's called. A house warming.

17 through my office to do that. 18 19
2a

18
19 2a

Q. How often would you have contact with him? A. Probably several times a week. I'm thinking maybe even as often as daily, depending on where he was starting. So ifhe was like in baseball season, it would So it kind of went

21 that. He invited several people from work to go to that.
22 23 24 25

21 with his different levels of courses and things that were
22 23

And I made tamales with his wife one year. And that's all. He did go shooting with us once. He liked to do that. And I was big time into that before I had my injury.

be real busy before that. But once it got started, it kind of slowed down, the purchasing. in shifts, depending on what season was opening.

24
25

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 18
1

9/24/2010
Page 20 And were you, then, the person responsible for the records as it relates to vendor payments?

6

Q.

Did you ever have any difficulty with

1

Q.

2 Mr. McDonald? 3
4

2 maintaining 3 4 5

A. Again, no more than any other director or manager.

A. No.

Q.

Who was responsible for that? So that AP clerk, her job

5

Q.
A.

I mean, other than the day-to-day issues that have. there, and I actually don't have those kind of issues. It And like I said, it was no more

A. We had hired an accounts payable clerk probably

6 normal co-employees 7

6 eight months after I was hired.

7 was to do the actual processing ofthe purchases and 8 basically the data entry part of it, make sure that they 9 get in the system.

8 was just things like getting the paperwork 9 those kind of things.

She would do the matching of the the purchase orders

10 than any of the other managers were having. 11

10 bills, any receiving type documents,

Q.

And did you ever have any issues with Roger

11 were all matched together and made sure that they got 12 inside the computer, and then Roger would actually make 13 the payments. 14 15 16 17 18

12 Kolman? 13

A. Not directly. We had some personality clashes at

14 first, and that was really about all. I'm a very

Q.
A.

What was that person's name? Her name was Elena Mangru. Mangrute? And you think she started eight or nine months She started, yeah, almost the whole year was Your best recollection is that she started eight

IS different person than Roger, but it's a really good
16 balance for us. He's not so much a people person and I'm 17 more of a people person. 18

Q. Q.
A.

A. Mangru, M-A-N-G-R-U.

Q.

And that was the nature of the personality

19 conflict? 20 21

19 after you started -20

A. I think so.

Q.

At some point, Ms. Cornn -- or is it

21 done. 22

22 Wilcox-Cornn? 23 24 25

Q.

A. Wilcox-Cornn.

23 or nine months after your start in July of'05?

Q.

Wilcox-Cornn.

At some point in late 2005 -Page 19

24 25

A. Yes.

When did you start in '05? A. I started June 13,2005.

Q.

SO sometime -Page 21

1

1 2 3 4

A. No, June of '05. I started in June of '05.

2

Q.

At some point after that date, as I understand

Q.
A.

SO sometime in the spring of '06? Yes, I believe so. And she would have been responsible for for example, the Federal Express payable

3 it, someone from Federal Express contacted the City of 4 Maricopa about an overdue bill. 5 6

Q.

Do you have any recollection of that? A.

5 maintaining, 6 fIle? 7
8

In 2005, no, I have no recollection of that. In 2005.
Did you have any dealings with Federal Express or relating to Federal Express

7 fact, I don't know anything about any bill in
8

A. Yes.

Q.

Q. Q.

Who did she report to? Did you have any supervisory role over her? got to her, ifthere was any weird stuff on the that kind of interaction with her. And I was

9 Roger Kolman or Mr. McDonald 10 in 2005 and early 2006?
11

9 10 11

A. She reported directly to Roger. A. Except for the, making sure that the purchase

A. No. It was not part of my, anything that I was We had very little business that we did with FedEx Most of our stuff was when we had to send and that was really about it, low volume. for vendor payables?

12 doing.

12 documents 13 purchase,

13 in general. 14 something, 15

14 over her, but I did not actually supervise her work. 15 16

Q.
A.

In your position in the finance department, would The actual payments of the bills, no. Getting Approving the payments? Approving the payments -- at a point it became

Q.

Did you ever have a conversation -- strike that. Later, sometime in late '07, I believe,

16 you have been responsible 17

17 perhaps early '08, there was an inquiry from Federal 18 Express about an overdue bill, correct? 19 20 21 22 23

18 the packets ready to be paid, yes. 19 20

Q.
A.

A.

Yes. You recall that? Yes, I do. Do you recall when that occurred? time was the interim City Manager, and so any or situations that came up in the department,

Q.
A.

21 part of what I did, was to make sure that the, all the 22 documents that were together became very, like 100 percent 23 everything that was purchased had to have a purchase 24 order. And so once that happened, of course, I was 25 involved in that part of it.

Q.

A. You know, in remember correctly, Roger at that

24 particular 25 problems

OTTMAR

& ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 22
1

9/24/2010
Page 24

7

they would be brought to my attention.

Technically, I was So

1

Roger. Roger got a briefing -- ifnot daily, Roger got a without his knowledge. Q. So the AP clerk, whose name I have now
>-

2 kind of like the gatekeeper

because Roger was not there,

2 briefing weekly, so there was no decisions that occurred
3 4

3 frequently gone, and -- just to do business and stuff.
4

it basically had gone to our AP clerk, of she had gotten a I called them back and then had them send me a big

5 call from them originally and then she brought it to my 6 attention.
7 8 9

5 forgotten 6
7

A. Vanessa. Q. -- Vanessa, gets a call from Federal Express,

out the bills. They sent them to me electronically, that was probably sometime in December.

fax I think is what we ended up getting. I want to say

8 says we have an overdue bill on the City account, in 9 essence, correct? 10 11 12 13 14
15 16

10
11

Q. Of?
A. Of '07. And at that time Elena was already gone,

A. Uh-huh,

Q. That's what she reported to you?
A. That's what she reported to me, yes. Q. How long did Vanessa remain employed at the City? A. Vanessa is still employed at the City. Q. When she gets this call, she comes to you? A. Right. Q. And says what? A. These don't look like anything that we have, and it's none of our particular invoices, because they were larger. Usually we had a FedEx of $15, $20, and then for a whole month we might have 100 bucks. They were asking for a lot larger and several of them. So I became involved, because she knew it wasn't ours and, you know, I Page 25

12 and we had not replaced her at that time. So it was just
13

the AP clerk -- we by then had a payroll clerk as well, purchasing guy. And the purchasing person was new.

14 So we had the two clerks and myself and then we had a
15

16 17
18 19

Q. Who was the AP clerk in December of '07?
A. December of '07 it would have been Vanessa Bellen. And Elena had been basically her supervisor. Q. And Elena had left the City's employ? A. Elena had left the City's employ in 2005. I want like that.

17
18 19 2a

20

21 to say like August or something 22
23 24 25

21 maybe it might be -- if we had done three that week, and 22
23

Q. SO who was the AP clerk's supervisor in December
of'07? A. Roger. Page 23

In December of '07 it would have been directly

24

25 said, "Fine, I will take care of it." And then I

1 2 3

Q. Were you the accounting finance manager?
A. I was just handling some of Roger's duty. I was not officially anything, except if they had a question, Q. Although you may not have been officially finance manager, on a practical level

1 2

contacted them directly, because she just didn't have the time to be messing with a lot of that. Hers was just the bills. Q. A She's a data entry clerk in effect? Basically, yes.

3 simply processing 4 5

4 they were to go to me because Roger was not available.
5

6 appointed accounting

6
7 B

Q. But she was keen enough to recognize that what they were calling about didn't appear on the surface to be City issues, right? A. A. Yes. I called them and asked -- they told me, well,

7 in December of'07 is that the function you were 8 performing? 9 10
11

A. That is the function I was performing, yes. Q. And unless it was something outside your purview of knowledge or something special, you wouldn't go to Roger; you would simply make the decision and proceed forward? A. Yeah. And most of it, we are talking just little clerical kinds of issues. It would have been, we got this
Ill--

9 10
11

Q. So what did you do?

12 necessarily
13

12 these are this, this is this, and they basically gave me
13 14 15 16 17 18

some general information on what they were reading on their account and, hey, these are past due. And I said, well, we don't have anything, any knowledge of these, you need to send us copies ofthose bills, which was just a standard SOP to get the information in front of us. So like a few days later we actually had copies And at that time we determined these aren't ours. And I saw Martin's name was on there and I this is, and I don't know why we have it, but these look like something Martin is doing, and it doesn't look like it's City business at all." Q. And when you say "Martin," you mean Mr. McDonald?

14
15 16

17 18 19
20

Q. My question is -A. I'm sorry. I'm just explaining. Q. My question is: Is it accurate that in December of '07, unless it were outside of the purview of your and experience or some special issue, you would

19 of the invoices. 20

21 knowledge

21 just took the whole thing to Roger, "1 don't know what 22
23

22 just make the decision and proceed with the activity as
23 24

opposed to going to Roger? A. No. I would make a preliminary decision on the

24
25

25 issue. Ifit was something that -- I always briefed

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 26
1 2 3 4 5 6

9/24/2010
Page 28

8

A. A.

Yes, Mr. McDonald. Roger took a look at them, he said, well, call

1 2 3

Roger Kolman, went and physically pulled the paper file to, for example, look at the address on the invoices from Fed Ex in the past? A. No. Q. Or to see whether the City had paid any invoice home in the past? A. No. Q. Did you instruct Vanessa to do that? A. No. Q. Did you instruct anyone to do that? A. No.

Q. What did Roger say?
back, because their address was an address that was not a City address. The actual billing address was Martin's home address, so we were able to figure that out. And it the city name on it and stuff. So we asked some and then they said, no, we still Well, that's not possible. And then show two accounts basically under the City, is what we were told by FedEx.

4 5

6 that was addressed to Mr. McDonald's
7 8

7 was like, well, this doesn't make sense, because it had
8

9 additional questions,
10 11

9 10 11 12
13

12 the other one was addressed to Martin's home address and
13

Q. Did the thought even cross your mind to do that?
A. No.

one was addressed to Ours and had our activity on it. So

14 at that time it would appear that Martin had an account 15 using the City account, or something under the name of the
16 17 1B 19 20

14

Q. To look in the paper file and see what might be
A. No. Q. So you told Roger this is what FedEx has sent us, I've looked through it, here's my impression, as you have A. Roger looked at them as well and he said, you And at that particular point in time

15 there?
16 17 18

City, to do business under. And that's kind of where we were. Q. Let me stop you for a second. When you looked at all the documentation A. that FedEx gave you, was that the impression you reached? That was the impression I reached. Q. That Mr. McDonald had a personal account that was identified as the City account? A. Right. Page 27 Q. Yes? A. Yes. Q. And did you explain that impression to Roger Kolman? A. Yes. And I let him review the documents. There I want to say there were probably So a lot of

19 described to me, and what did Roger say? 20

21
22 23

21 know what, this looks pretty serious and we probably need 22 to talk to Kevin.
23

Kevin had already been appointed and was going to be starting relatively soon.

24
25

24
25

Q. SO Kevin had the job, but he wasn't physically in
Page 29 Maricopa? A. Q. That's true. He was still in Texas. SO Roger suggested that you call Kevin?

1 2 3

1

2
3

4

4
5 6 7 B

A. No, Roger suggested that next time he calls Kevin that I speak with him and tell him what information I had. And within a few days, in one ofthe evenings, he called Kevin, so we had that conversation at that time. yes.

5 was a lot of documents.

6 50 pieces of paper that we got from them.
7 8 9 10 11

detailed information that we got of all this. And I want to say they were looking for a payment of like, just under $5,000. So it was -- I can understand why they were wanting it and I can understand why we weren't going to pay for it, either. It wasn't like a boo-boo or anything

Q.
A. A.

And did you talk to Kevin? I talked to Kevin on speakerphone,

9
10 11

Q. What did you tell Mr. Evans? Basically what Ijust told you. This is what

12 like that. 13
14

12 they said, this is this, this is this. We did check with
13

Q. Did you go back and look at the FedEx payables
account to see what had been paid in the past? A. I looked inside the computer. the payables account. I did not look at All the payable file would have had

FedEx and they had given that account discounts, the same discounts that we got, so we knew that at that time. Q. SO after you talked to Roger the first time, you went back and checked with FedEx and learned that personal account had been given government discounts? A. Yes. Because they saw it as a City of Maricopa That's all they saw. Q. Did you relay that information to Mr. Kolman? A. Yes.

14 government
15 16 17

15
16

17 were paid bills.
18

And I was oriented to look at all my

information in the computer system. I have the same And I looked on our side and I could see that we had very hadn't at that point even crossed may be $1100, $1200 worth of activity the whole time we had had the FedEx account. Q. And I appreciate that. What I'm trying to find out is if you at any time, before or after you spoke to

18 Mr. McDonald's
19

19 thing. All it would do is give me the paper documents.
20

20

21 small invoices, sporadic and, you know, three years we 22
23

2 1 second account. 22
23

24
25

24
25

Q. SO you told him FedEx confirmed that Mr. McDonald
had been getting government discounts on his personal

OTTMAR

& ASSOCIATES

602-485-1488

Corrine wilcox-Cornn
Page 30
1 2 3

9/24/2010
Page 32

9

account? A. On that account. Q. Right. It was his personal account, right? A. As far as I knew, yes. Q. Did you tell Mr. Evans that in the phone conversation? A. Yes, I did. Q. What did Roger say during the phone conversation? A. He just introduced me to Mr. Evans and he let me go. And then he dismissed me afterwards and he talked probably another 30, 40 minutes with Mr. Evans. Q. You don't know what he spoke to him about? A. I don't know. I just know they were talking for a long time. Q. When did Mr. Evans say to you during the A. He said to both Roger and myself that we needed Q. That would be Pat Melvin? A. Pat Melvin. Q. A. Chief of police? Chief of police.

1 2 3 4 5 6 7 8 9 10 11 12

everything." Q. Well, what other problems were you having with Mr. McDonald? A. You know, it was procedural issues, and Roger and Martin had had a number of years of butting heads, is the way I will say it. And this was just, Roger wanted me to make sure that he knew that Martin wasn't the easiest follow-all-the-procedures type employee that we had. And that was Roger's opinion of Martin. Q. Was that your opinion as well? A. Not really. Again, I will go back to my first statement, he was no more difficult than any of our other Q. Did Mr. McDonald on occasion not follow the procedure for purchasing items? A. Once we actually had some type of procedures in

4
5 6 7 8 9 10 11 12

13
14

13 managers or directors, as far as doing their own thing.
14

15

15 appropriate
16 17

16 conversation?
17

place, it was not so. Before we had procedures in place,

18 to contact Pat and start an investigation. 19 20 21 22 23 24 25

18 no body really knew how or what the proper way to do 19 certain things were. 20 21
22 23 24

Q. That wasn't my question. A. Okay. Q. My question was: Did Mr. McDonald not always follow the proper procedures as it related to purchasing items for PRL? A. In what time frame? Page 33 Q. During the time you worked for Maricopa. A. When we had procedures, Martin followed them. When we didn't have procedures, anything. Q. Did you have any involvement A. No. Q. Do you have any information about that? A. I knew during the purchasing functions that Martin had occasionally some things he would start to more cost effective to buy it using their funds and saving mind. A lot of the time he would start to order something it was going to cost more than what he had budgeted. lot of time the PRL, the Friends of the Library monies So a in Mr. McDonald utilizing the library fund to purchase items? obviously nobody followed

Q. Did Mr. Evans say anything else? A. No. Q. What did Roger say in response to that? Page 31 A. He told me, thank you, don't say anything to anybody about this, it's confidential, blah-blah-blah, Q. A. of

25

1 2

1 2 3 4

3 that spiel.
4

SO what happens next in relation to these FedEx Basically, I put everything in the file and just

5 issues? 6
7 8 9 10 11 12

5
6 7 8 9 10

kind ofleft it in my office. And that was it until a couple -- some time passed, what time frame, I'm not certain. Then I met with a detective from Phoenix. And Roger had told me that this guy was going to come. He told me like the night before the guy actually came. And he told me to go ahead and make sure that I tell him all sure that he has a clean picture of what's going on with Q. This was Detective Quaas? A. A. Q. Okay. If that's his name. That sounds like right. SO Mr. Kolman told you to be forthcoming with Q. You don't remember his name?

11 purchase using City funds, and then because it was either
12

13 the problems that we are having with Martin and to make
14

13 those funds for something else, he may have changed his
14

15 Martin and how he behaves at work. 16
17

15 and he would find that they couldn't get it in time and/or
16 17

18 19 20

18 would come into play, and then he would either cancel 19 something or buy less of that and have the PRL -- the 20 library people cover some of those things.
21 22 23 24

21 Detective Quaas as it related to what was going on with
22 23

Q. Did you ever have any involvement in auditing the use of the library fund money? A. Q. A. Of auditing it, no. Of tracking it or monitoring it in any respect? My understanding is that was a not-for-profit

Mr. McDonald? A. He told me to let him know -- I'm using his Don't spare anything. Just let him know words, "Let him know all the problems that we are having

24

25 with Martin.

25

OTTMAR & ASSOCIATES

602-485-1488

Corrine wilcox-Cornn
Page 34
1

9/24/2010

10
Page 36

organization that had its own board and had its own we would not have done any of those things. Q. Did you ever have any conversations with anyone

1 2 3

Like I say, I was focused on getting information out of our computer. That's where I always looked for stuff. Q. I'm sorry, ma'am. A. I'm sorry. Ask again. I didn't understand it. Q. I don't think I asked it very well. Did you make available to Detective Quaas the City's files? A. No. Q. If he wanted to look at any file, could he have? A. I believe he actually got those from Roger, because he already had files. Q. What files did he have? A. I believe he had actually gotten ahold of the Q. Well, they were in your department?

2 totally separate situation going on than the City. So no,
3

4

4 5
6 7

5 at the library fund about the use of their money for
6 7 8

purchasing items that Mr. McDonald wanted? A. No. Q. Did you ever have any conversation with A. Mr. Kolman didn't like the fact that the library would fund things that he would otherwise tell Martin he couldn't do. I'm trying to think of a nice, easy way to say it. Martin may have had $1500 and the item he wanted to purchase was $2,000, and Martin still ended up purchasing it because he would use the library funds. It things. And he had a way to facilitate that and it bothered him immensely. Q. After he had been told no by Mr. Kolman? A. After he had been told no by Mr. Kolman. Q. SO Detective Quaas comes? A. Yes. Q. Did you answer all his questions? A. Yes, I did. Page 35 Q. Did Mr. Kolman tell you to hide any information from Detective Quaas? A. No. Q. Did he tell you to mislead Detective Quaas? A. No. Q. Did he tell you to skew the information about in any respect to Detective Quaas?

8
9

9 Mr. Kolman about that? 10
11 12 13 14 15

10
11 12 13

14 FedEx stuff. I did not have those files.
15

16 really initated Roger that he could still get those
17 18

16
17 18 19 20 21

A. They were in the finance department. Q. Well, that's where you worked, right? A. That's where I worked, yeah. Actually, the file cabinets were right outside the door. They were there where anybody could get into them. Q. And you had been charged by your supervisor, Roger Kolman, to be the contact with Detective Quaas? A. Yes. Q. And to make available to Detective Quaas whatever information was requested? Page 37 A. Yes. Q. Yes? A. He only requested -Q. Excuse me, ma'am. My question is: Mr. Kolman A. Correct.

19 20
21

22 23 24
25

22
23 24 25

1 2

1 2

3
4

3
4

5

5 told you to make available to Quaas whatever he wanted?
6 7

6 Mr. McDonald
7

A. His desire was for me to paint Mr. McDonald in knowledge, that he had committed a criminal act in the and that's what I did, based on what Roger had told me to do. Q. Based on your review of the documents and your of what you were looking at and your did you think there was a possibility that

Q. Right?
A. Yes. Q. And so Detective Quaas did have access to and A. I don't know. Q. WeL!-A. All I gave him and all he requested from me was copies of the invoices in question. any past files or anything like that. Q. I'm not asking you what he asked for yet. What I want to confirm is that they were available to him. If he A. Yes, as far as I know, yes. He never asked me for

8 the worst light possible, that he felt, and, to my
9

8
9

10 only part that I knew of, which were these documents,
11

10 made available to him the FedEx paper files of the City?
11

12

12
13 14 15

13 understanding 14 impression,

IS some criminal conduct had taken place? 16
17 18

A. That was that possibility, yes. Q. Did you make the City's files, as it relates to FedEx, available to Detective Quaas? A. Actually, no, because I didn't keep the payables

16
17

18 had asked, he could have had them? 19 20

19

20 files. They were open files, and those were something 21 that AP filed. They were just plain old, you know, here's
22 23

Q. No one in the City management told you not to A. That's correct. Q. All Quaas asked for was the invoices relating to this issue that arose in December of '07? A. Yes.

21 give him something? 22
23 24 25

where the documents ended up. I saw them before and Roger saw them once they were completed before he actually wrote the checks. And they went through several reviews before a whole lot of stuff happened. Some looking at that --

24
25

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 38
1 2 3

9/24/2010
So you meet with Quaas?

11
Page 40

Q. Do you know whether Quaas ever talked to Mr. Kolman? A Yes. Q. How do you know that? A. Because when he came in, that was the first thing he said, that he had already been briefed from Pat and had with me.
50

1

Q.

2
3 4

A. Uh-huh. Q. You meet with him again about a week later? A. Approximately. with him? a phone call I'm not sure on the time frame. Q. And then much, much later you have one telephone A. He may have called. I'm remembering

4 5
6

5

6 conversation
7

7 spoken to Roger and he started his conversation
8

And he actually had a lot of leading questions, Q. What essentially did Quaas tell you? A.

he knew

8 when I was in -- No, that was that call. I'm sorry. Yes, 9 that one bizarro call afterwards. 10 11 12
13 14

9 10 11

a considerable amount of what had happened already.
That he had been briefed by Pat and that he had

Q. A. A.

SO my chronology

is correct?

Approximately, Right.

yes.

12 spoken to Roger and that he was going to ask some specific 13 questions of me, and then he started asking questions.
14

Q. And you spoke to Roger before you met with Quaas? Q. Did you ever speak with Roger Kolman about the again? A. Yes. Actually, he wanted a debriefing of what I And so we were talking in Elena's

Tell me about the phone call, when who called you from And I said I don't remember the name. So we just

15 FedEx.

15 FedEx issue and Mr. McDonald 16
17 18

16 kind of went through all the different dates and times and
17

stuff like that. And just how everything had occurred. Q. Did you ever have any further conversations with A. No, I didn't. After the first initial couple of I want to say probably I talked to them a Like at one point somebody total of four or five times, getting copies, getting additional questions answered. asked, well, when was that account originally made and when was ours made, and all that kind of stuff. So probably had three or four different times that

had told the detective.

18

old office, we were looking for something, and I explained went over the synopsis of what I had spoken of. He was This is it. We will get

19 FedEx about this issue? 20

19 to him that we had talked about this and this and kind of 20

21 informational-22
23 24 25

21 really excited and he said, "Oh, this is going to get 22 Martin in all kinds of trouble.
23 24 25

rid of Martin this way." And he told me at that time, "I had talked to Martin about this and he had to get our name off that account before." I turned to him and I asked Page 41

r
Page 39

1 2

r called

1 2

him, "What are you talking about?" I actually stopped what I was looking for and turned to him and asked him, And he looked like deer in the headlight look, and then he stopped, "Oh, nothing, and then he actually left the room. He stopped And he quickly stopped the conversation that He never, he kind of made himself scarce And I totally forgot about it about all this

them from the initial time about when -- just different Q. After you first met with Detective Quaas, from directly with FedEx? A. No. Q. Did you have any further communication Detective Quaas? A. He came back a week or so later, asked -- pulled on the Internet, and asked with

3 questions that had come up, Roger had asked, you know.
4

3 "What are you talking about?"
4

5 that point forward did you have any communication
6 7

5 nothing,"

6 doing what he was doing and he said he had to go
7

somewhere.

8
9 10

8 we were having.

9 for the next couple weeks.

1 0 until I actually read in the newspaper 11 stuff. 12
13

11 up something on the computer,

12 me to identify ifI knew any of these people that were in 13 a picture, and that was it. 14

Q. You never mentioned that to Mr. Kolman again? A. No. Q. Did you ever mention that to Detective Quaas? A. No. Q. How about to Mr. Evans? A. No. Q. After Mr. McDonald was indicted, did you raise that issue with anyone? A. Yes, I did. Q. Who? A. I actually had wrote an affidavit to state what I had known and let the -- r want to say the County Attorney people is who ended up with the actual affidavit. But Roger knew ahead of time. And then later, of course, I

He also called me way later. I thought of2008 and he asked some very strange

14
15

15 everything had been done and stuff. He called me in 16 December
17

16
17

off-the-wall question about Martin. And I told him that It was something But

18 as far as I knew -- I want to say he either asked if he 19 used drugs or if he was an alcoholic. 20

18
19

very strange like that. And, of course, I told him as far it was just really strange. "Well, I'm getting ready to

20 21 22
23 24 25

21 as I know, no, and how would I know ifhe was anyway.
22 23 24 25

close out the file, so this is it." So at that time that was the only other time, and, of course, I couldn't add to anything that he had to say.

OTTMAR & ASSOCIATES

602-485-1488

Corrine wilcox-Cornn
Page 42
1 2 3

9/24/2010

12
Page 44

find out there's all this other correspondence but at that time I did not know. Q. Who drafted the affidavit for you? A. I drafted the affidavit for me. Q. At whose suggestion?

about that,

1 2

A. No.

Q. Q.
A.

Did you talk to Mr. McDonald? You submitted an affidavit originally when was indicted, correct? For the FedEx thing, yes. And what was the second affidavit for? The --

3 4

A. No.

4 5 6
7

5 Mr. McDonald 6
7 8

A. I had called Clair Lane's office, because I knew half of the stuff that was in the media report was wrong, that Rick had been involved in

Q. Q.

8 and that Roger had known about the FedEx account prior to 9 the 2005 FedEx information

A. About the stuff with the PRL misappropriation. A. With the library, Friends of the Library Q. The most recent indictment? A. The most recent indictment. Q. Did you, again, do that affidavit voluntarily? A. Yes. Q. You weren't asked to do it by Mr. Lane or Mr. McDonald? A. No. Q. SO after Mr. McDonald was indicted, did you have with Mr. Kolman? any further conversation terminated.

9 10

10 and stuff, and he had let it slip to me, in that weird
11 12 13 14

conversation, Q. A.

that he knew.

11 misappropriation.
12 13

SO you called Mr. Lane's office and volunteered I called and said that, "If Martin is going to

that information?

14
15

15 end up going to jail, then I would really like you to call 16 me as a witness, because I think that Mr. Kolman kind of
17 18

16
17 18 19 20 21

set him up to get in trouble."

And at that time he said,

"You know what, you need to write your stuff down and you Q. After Mr. McDonald was terminated from the City but before the indictment, did you have any conversation with him? A. Nothing more than on Spacebook -- Facebook, encouraging him and stuff. It was hard for a lot of us who lost our jobs. I was real sick at the time, but I Page 43

1 9 can present it to -- in a way that we can use it." 20
21 22 23 24 25

A. I have not spoken to Roger since before I was

22 23
24 25

Q.

Why?

A. Because he was just somebody I worked with. Many people at work I have never spoken to again. Page 45 Q. You knew that Mr. McDonald had been indicted, right? A. Vh-huh. Q. And you believed that Mr. Kolman had some that was relevant to that issue? A. Vh-huh.

1 2

just encouraged him. Q. After the indictment but before the indictment did you have any conversations with Mr. McDonald? A. No.

1 2

3 was dismissed,
4

3
4

5 6
7 8

5 information 6
7 8

Q.

Have you had any recently?

A. Outside of encouraging him, no. That's about it. We exchanged things like recipes and stufflike that on and that's really about it. Not a whole lot of

Q. Correct?
A. Yes.

9 Facebook,

9 10 11
12 13 14 15

Q. But you never spoke to Mr. Kolman about it?
A. No. Q. And your reason is that there's lots of employees, co-employees intentionally. you don't talk to? A. No. I think, actually, Roger did that I think he pointed me towards the as I possibly can, and all the time knowing detective, told me to paint as bad a picture of that he had actually dealt with the situation before and that what Martin was doing was, you know, they obviously had an error going and hadn't fixed it at FedEx. He already knew the account was out there. Q. Why do you say -- what facts do you base your conclusion that -A. Because-Q. Excuse me.
--

10 anything more than that. 11
12 13 14 15

Q. Q.
A.

Are you working now? Where? I work for Central Arizona Association of

A. Yes, actually, I am working now.

Governments.

16
17 18

Q. How long have you had that job?
A. A. I have had that job since April. I'm the finance director there. What did you do to prepare for your deposition? A. What did I do? I looked over my notes on the two affidavits I had submitted. Q. Did you talk to Mr. Lane?

16 Mr. McDonald
17 18 19 20 21

Q. Doing what? Q. And when was the -- strike that.

19
20 21 22 23 24 25

22
23 24 25

that they hadn't fixed it at FedEx?

OTTMAR & ASSOCIATES

602-485-1.488

Corrine Wilcox-Cornn
Page 46
1 2 3 4 5

9/24/2010
MR. LANE: MR. DOYLE: Let's take a quick break. Sure.

13
Page 48

A. Because when I talked to Quaas in December of 2008, I subsequently got off the phone with him and walked into the City Manager's office. And I told him that, just got a call from a detective in Phoenix. Now I thought that they weren't proceeding with that, I thought nothing me that they weren't going to because the only person who lost money, and he said something like $14,000, was FedEx,

1
2 3 4

(The deposition was at recess.) EXAMINATION

5 6 BY
7 8

6 was going to be happening with that. And Kevin Evans told
7 8

MR. LANE:

Q. IfI have this right, it was not you that got the initial phone call from FedEx; it was one of your other A. It was the clerk. Q. And then she reported that to you? A. Yes, she reported it to me. Q. And then you took and contacted FedEx, or did they call you again? A. No, I took and contacted FedEx. In fact, I might the

9 and they weren't willing to prosecute because it was an 10 error on their part. The City hadn't lost anything and
11

9 employees?
10

they knew that it was an error that had happened and So I said, "Well, Ijust wanted you to know I got

11 12 13
14

12 nothing should be happening. 13

14 a call from a Phoenix detective and he's asking some weird 15 questions, and Ijust thought it was kind of strange. " 16 And he said,

15

"I assure you, nothing is going to happen,

16 have had Vanessa call them and then she transferred

17 the City is not pursuing this, nobody is going to be 18 pursuing this." And for it to come up in the newspaper
19 20

17 phone call in to me, I think is actually what transpired. 18

Q.

I take it you noticed that there was a difference

after, you know, a few months later, it didn't make sense. Q. You are talking about the conversation with Quaas

19 between the account number they were referring to -20

A. Yes. Q. -- and the City's account number? A. Q. That is correct. Thank you. And you also noticed that at some

21 about drugs or alcohol?
22 23 24 25

21
22 23 24 25

A. Yeah, that phone call. I turned around and told
Mr. Evans about the phone call. Q. Do you know whether or not the City agreed to be the victim for the prosecution in the indictment with Page 47 Mr. McDonald? A. I was not involved in any ofthat, no. Q. My question is: Do you know whether they did or A. A. I don't know. That's what --- and asked not to participate

point they sent you all the invoices in question? A. Yes. Page 49 Q. And did you also notice that the address on that account, the second account, was Martin's horne address? A. Yes, I did. Q. To clarify, you said the City didn't use a lot of A. FedEx, it's not customary, most people come into

1 2 3

1 2 3 4

4 not?
5

5 FedEx services for the prior year at that time. 6
7 8

6
7 B

Q. If the City was not a victim-Q. Excuse me. in the then what Mr. Evans told you would be

the City to do different things. The only time we actually used FedEx is when we had to send a plan or some to use -- So we had a low volume. It was not something We usually used UPS.

9

9 papers, contracts usually into town, and we weren't going
10

10 prosecution, 11 accurate? 12 13

11 that we had a high volume on. And we certainly didn't use 12 FedEx too much for purchasing. 13
14

A.

Yes.

Q. Do you know whether Mr. Evans had any control

Q. The City maintained its own separate file with respect to its own FedEx account number? A. Yes. Q. And would it be fair to say that that file was A. A. That's true. Yes.

14 over FedEx and whether they wanted Mr. McDonald 15 prosecuted? 16

15 16

A.

Basically, they told him that they weren't going

17 to do it, that they accepted the fact that they had made 18 an error, there was an error on their part, and that's 19 what he told me.
20

17 not voluminous? 18
19 20

Q. And it was available and it was there? Q. Did someone ever go into the City computer and confirm whether or not any City funds were used to pay any of these invoices that you received from FedEx with Martin's horne address on them? A. We verified that the ones that were in our

Q. You never talked to anybody at F edEx about that?

21
22 23 24 25

A. No.
MR. DOYLE: you. MR. MCDONALD: break? Can we take a five-minute That's all I have, ma'am. Thank

21
22 23 24 25

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 50
1

9/24/2010
(Deposition Exhibit No.1 was marked for

14
Page 52

possession were actually ours. The thing about it is, in FedEx bills, so we knew that they were something that was supposed to be occurring. Because that's kind of the way

1 2

2 general is that we had purchase orders attached to the
3 4

identification.) Q. Let me show you Exhibit 1. It's called a Release Questionnaire. You will notice on page two of the document, there's a statement that Detective Quaas makes Have you ever seen that statement before? A. No. Q. If you will look in the statement, it I attributes -- go ahead and review it. It attributes several statements attributed to you in this statement. would like you to read that statement and tell me if there's any things in there that are attributed, as coming from you, that you didn't say. As you read it down, if you find one, would you stop and repeat it and tell us what it is, please. A. Well, if he's referring to me as the finance

3 BY ·MR. LANE: 4
5 6

5 we did it. It wasn't like -- I knew that if a purchase
6 7

order was issued and a FedEx bill was attached to that, there was a certain procedural thing that occurred. then that would make it questionable. So it Any time that there wasn't any, And as far as I

7 about the case. Would you read that briefly for me.
9 9 10 11 12 13 14 15 16 17 18

8 was a valid purchase.
9 10 11

could see in the computer, everything had validity and was okay. So in looked at the paper file, I would have seen

12 the physical documents that said the same thing. 13
14 15 16 17 18 19

Q.

Do you believe that you were the City employee

that was in effect in charge of the investigation with Detective Quaas? A. No. Q. When Detective Quaas first came to your office, who was he accompanied by? A. I'm sorry. Say it again. Q. When he first came to your office-I assume he came into the finance area? A. Yes, he did. Q. Did you stay in your office, go to a conference room, what did you do? A. No, we stayed in my office and closed the door. Page 51 Q. And who was he accompanied with at the time?

19 manager, I wasn't the finance manager. 20 21 22
23 24

20 21 22
23 24

Q. And who was the finance manager? A. Technically, Roger was the finance manager. Was that during the time Q. You say "technically." he was wearing both hats? A. He was wearing both hats at the time any of this Roger was the finance director, that Page 53 would have occurred.

25

25

1 2

1 2 3 4

was his title. He was acting interim City Manager. Q. And what title did you have? A. I was the budget analyst and the senior accountant at the time. Q. Keep going. And if you find a statement that you believe is attributed to you that you didn't make, please stop and read it for us. A. Q. A. Well, this whole statement. Read the statement that you are concerned about.

A. Roger brought him over to my office. Q. You said it appeared that he had been, quote, and A. That's actually his words. He said that he was briefed. He had been briefed by Roger and by Pat. And

3

4 I will use your phrase, briefed? 5
6

5
6 7 B 9 10

7 when he used "Pat" rather than using "Chief Melvin," I 8 knew he knew Pat and stuff, so I found that kind of 9 strange.
10 11 12

But there was a familiarity from the way he

talked about "Pat." Because nobody, except for close friends, ever call Chief -- because I only called him "Chief." Nobody called him "Pat," unless you were very And I always assumed anybody who would use, call Chief "Pat," actually they were very close friends. Q. Did you know that Chief Melvin was a former City of Phoenix police officer? A. Yes, I did.

It says: It was also learned that this FedEx
City of Maricopa account which

11 account was an unauthorized
12 13 14 15 16 17 18

was verified by the City of Maricopa finance director as being an unauthorized FedEx account and the finance manager was unaware of such account. Q. Is that attributed to you? A.

13 close friends.
14 15 16 17 18

It says "finance manager."

I'm assuming that's

Roger, and I would think that that would be less than truthful. Q. Why would you say that's less than truthful? A. Because Roger intimated to me that he knew that he had spoken to Martin about getting his name off ofthis account, getting the City's name off of this account, and he hadn't done that yet. Q. A. On a prior occasion? On a prior occasion.

19 20 21
22 23

Q.

Did you assume therefore that --

19 20
21 22 23 24

A. Yes. Q. Let me finish my question.
--

therefore, since Detective Quaas was

Phoenix police, that maybe he and Chief Melvin had a prior knowledge of each other and relationship? A. Yes.

24 25

25

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 54
1 2

9/24/2010

15
Page 56

Q. Keep going. A. Well, this thing down here about the City I know Kevin had told me that they I'm

1 2 3 4

Chief Melvin, you've testified that Chief Melvin must have been the source of that information, not you? A. I would guess, but I'm fairly certain that he had spoken to Roger. He had been in Roger's office before he Q. That's what you are basing that on? A. Yeah. Q. Did he appear to have a, what I'm going to call a working knowledge of what the facts were before he came A. Q. Yes, he did. He was very familiar with the case. I want to go back. You said that at some point to you that this was a prior incident with

3 desiring to prosecute.
4

weren't going to do that. Q. Okay. I'm going to read you a statement. number 2008 80256700. looking at Detective Quaas's original report, page six, DR The third paragraph says this: Lead Martin running a

5
6 7

5 came into my office.
6 7 8 9

8 "Corrine observed Investigative
9

'Fantasy Football' personal business through his PRL with 'Fantasy Football' logo merchandise inside these

10 director office by receiving FedEx shipments and packages
11

10 into your office?
11

12 packages." 13 14 Quaas? 15 16

12
l3

Did you make that statement to Detective A. No, I did not. Q. Did you ever talk to Detective Quaas about Martin A He asked what I thought the shipments were for,

in December '08 -- or January '08, when it first started, FedEx. Can you clarify where you were standing and A. We were in Elena's office, because we were And I want to say it was a bill or

14 Roger mentioned
15

16

17 running a football operation? 18

17 what was going on when that statement was made? 18

19 and I told him that I thought it was for his Fantasy 20

19 looking for something.
20 21

Football stuff he did on the side. And I explained to him promo type merchandise, and I explained different kinds of promo stuff, and that was the Q. There's another statement in this report, and I will quote it: "Martin receives these FedEx packages Page 55 addressed to him being delivered to his office." Did you make that statement to Detective A. No, I did not. Q. This is another statement, same page, same report: "Martin was told not to conduct his personal business while working for the City of Maricopa and to stop sending and receiving personal packages to his work." Did you make that statement? A. No, I did not. But Roger did say that. Q. The next statement: "Corrine believes Martin is

something of that nature. And so we were in there looking. Actually, I know what it was. We were looking We had just recently taken over through fire documents.

21 it was just merchandise,
22

22
23 24 25

23 essence of what I knew about the Fantasy Football stuff. 24
25

the fire and we were trying to prepare documents for the audit. So we were looking for some invoices and some correspondence in there. Page 57

1 2

1 2

And so he was going through one big box, because we had basically used that room, her office as a storage Roger was going

3 Quaas? 4 5
6 7 8 9

3 area. So we were looking through that

4 through a box and I was going through a box. And at the
5

time I was debriefing him as to what had happened with the with Detective Quaas. And so

6 conversations
7 8

r was just

going through the different

points that I had made with him. And he was all excited. And then he

9 He said, "This is going to get Martin fired, and, finally, 10 you know, we will get rid of Martin."
11

10
11

continues on. He's just really excited and very, very

12 utilizing City of Maricopa vendors to obtain discounts on 13 shirts and printing for personal use by promising the City 14 vendors City of Maricopa business." 15 16

12 happy about this whole issue. And he says, "I told him a 13 long time ago to get the City's name off of that account." 14 And I stopped what I was doing, and I looked up and I 15 asked him, "What are you talking about," in just about 16 that type tone. And he says, "Uh, uh, nothing, nothing. 17 You know what, I just remembered IB

Did you make that statement? A. He asked about what kinds of things Martin on his credit card that he got reimbursements would purchase different things and the

17 purchased

--" he looked at his

18 for. And I told him at that time that he purchased, 19 occasionally
20

watch real quick, "I just remembered I have got to get out And it was after hours, so it was probably like 6:00. "I have got to take care of the baby tonight," so he was like out and stuff. And I didn't see him for several days at all. Q. Was that unusual that you didn't see him for several days? A. Because he was in meetings and doing all kinds of

19 of here."
20 21 22

vendors -- he asked about which vendors those were, who the extent ofthat conversation, conversation. Q. Assuming that Detective Quaas has testified that or that part of the

21 would take a credit card, that kind of stuff. And that's
22 23

23
24

24

25 the only people he talked with at the City were you and

25

OTTMAR & ASSOCIATES

602-485-1488

Corrine wilcox-Cornn
Page 58
1 2 3 4

9/24/2010

16
Page 60

business for the City. Q. My question was: Was it unusual you didn't see him? A. No, it wasn't unusual that I didn't see him. Q. That itself wasn't unusual? A. No. It was just kind of weird because he wasn't around to do the debrief that we were -- He kind of stayed

1 2 3 4 5 6

Q. Did you get the impression that there had been written documentation to support Martin's claim that he thought he had taken care of the problem? A. 1 got the feeling from Kevin that there was evidence and documentation that he had made an effort with Rick -- Rick was involved at that time, Rick Buss was brought it to his attention. And Rick was involved and And then that

5
6 7

7 involved -- in separating the accounts, because Roger had
8 9 10 11

8 away from me for about, I want to say about 10 days, 9 before we actually had a chance to say more than a couple
10 11

basically, hey, get these things separated.

little things in passing. Q. I would like to go with the conversation you say You said he

Martin had done it and Martin had sent e-mails back and forth and those kinds of things, and that's kind of in Q. So Kevin used the name Rick Buss as part of that

12 you had with Kevin Evans in January of'08.

12 essence what Kevin told me about. 13
14

13 told you FedEx admitted it was their fault or they were in 14 error? 15

conversation-A. Yes. Q. -- referring to a prior incident of some kind? A. Yes. Q. But you weren't aware of what that incident was? A. Well, at that time I wasn't aware of what that incident was. And it brought back that thing that Roger but I didn't know what it was, what the

A. It was in December '08, after I had the with Quaas. I went in and told him, because I found it kind of unusual that after all these months of

15 16
17

16 conversation
17

18 nothing, and he basically said, hey, they are closing out 19 the file. So I went and told him, and I also told him
20

IB
19
20

about the bizarro question.

I got a call from the

21 detective, told him about that. And then 1 told Kevin -22 I asked him, "I thought this was all done, since they are
23

21 had mentioned,

22 particular facts were. He said that FedEx was dropping
23

not doing anything about it." And he subsequently told me, he said, "Well, you know, they figured out that it was about $14,000 worth of discounts that Martin received over Page 59

it. And that was all my concern, because I was concerned that -- you know, at this point in time everybody was playing nice, so like we don't want anybody to get in Page 61

24
25

24
25

1 the years, and FedEx admitted it was their error and --"
2 3 4

1 trouble.
2 3 4

Q. Did he use the word "error"? A. He used, Kevin used the word "error." And he said that FedEx admitted that they had accordingly, whatever, in the computer, and it continued to give him a discount, and it shouldn't have been. They did get the correspondence and stuff that were given from the City before, and from Martin before, telling them to basically separate the two accounts. And that was his understanding, that that had

Q. I believe you made a statement that, with respect to this situation, it looked as if Roger was setting Martin up. What are you talking about? A. Roger and Martin had always had, from probably since the time that I was there, when I first noticed it, it was usually at counsel meetings, Roger was a little towards Martin and kind of in a teasing manner to how Roger did things, he would put him down. And as time went on and I had been there and got more accustomed

5 made an error and had not switched off his account
6 7 8 9 10

5
6 7 8

9 derogatory
10 11

11

12 happened and they just messed up and didn't get it sorted 13 out correctly.

12 really had a great deal of animosity towards Martin. 13 Martin had a flashy, really cool job and everyone was
14

And so FedEx didn't want to do anything to

14 Martin because it really wasn't his fault. And the City 15 didn't lose anything. 16
17

excited that this or that was going on and we were doing

15 the park and all the things that were, you know, positive 16 stuff that was going on. 17

He might have had -- Martin had made a good faith effort in getting the name off, they just never took care He thought it hadn't gone through and

And Roger had this big responsibility

basically

18 of it, and getting the account separated. 19 was separated, and apparently
20

18 where he had to tell people no a lot and we can't do this. 19 And Roger was not a people person and Martin was, and 1 20

didn't appropriately

get disengaged from getting the

think there was a professional disrespectful.

amount of discord that

21 discounts and stuff.
22 23

21 happened to him. He treated him very badly, very
22 23

But that was the conversation with Kevin. He just went on and on about it. "We are not going to do anything." in trouble." And, "It's okay." And "Nobody is going to get

And I say that because the relationship

was -- to me, Roger would have this exchange with Martin and then he would go into his office and he would be so pissed off. And he was just outside with Martin and kind

24
25

24
25

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 62
1 2 3 4 5

9/24/2010

17
Page 64

oflaughing

and being jovial, then he gets in his office He said he said this, what do you know,

1 2 3

or no?
A. Yes.

and he is pissed.

and he would just go on like a little kid, all brooding.

Q. And where did that statement take place? I'm
A. A. I believe it was in Roger's office. About this same time frame that we are talking

Q. Did he require Martin as a department head or
director to go through different procedures than other heads? A. Yes. Frequently he would have Martin jump through hoops that he didn't require other departments to

4 going to break this up. Tell me where that took place. 5 6
7 8 9

6 department
7 8

Q. When? about, 2007, 2008. Q. And what was the subject matter you were Do you remember anything about a check being made to Midwest Premiums & Promotions? A. Oh, yes. Do you remember a transaction involving a check & Promotions for Founders Day

9 do. The other problem that he also did that was, I don't 10 want to say unfair, but he would delay purchases and
11

10 discussing?
11

stuff, stuff would sit on his desk, knowing -- and I put a

12 big note, Martin needs this order by this date so that he 13 can get it in time, and, you know, to be timely and stuff 14 like that, and he would just sit on it. He would not sign 15 the documents.

12 13

Q.

14 from Midwest Premiums 15 merchandise? 16 17 18 19
20

And, of course, I couldn't order the stuff So he put

16 until he actually did sign the documents.

A. Right. Q. When was that transaction discussed? A. I want to say that's in 2007 as well. Q. Tell me what you know about the Midwest Premiums & Promotions transaction. A. Basically, Martin needed to purchase some merchandise for the Founders Day, and he brought in a That was my authorization, I signed Page 65 purchase order. It always starts with me. It's like do you have the money? And then it would go into,

17 things -- to make his life really hard any time he tried 18 to do things the correct way. 19 20

Q. You said at one point that in the early days of
the City there were no real procedures of how things were correct? A. Correct. set up that were to be followed? Page 63

21 supposed to be done, vis-a-vis finances where you worked,
22 23 24

21
22 23 24

Q. At some point in time there were in fact

25 procedures

25 it, yes, you have the money.

1 2 3 4 5

A. A.

Correct. Yes.

1 2 3 4 5

you know, being ordered and get prices and all that kind of stuff. Then it would get ordered. Martin had given that to me in the morning, here's the PRo I had signed it and then he subsequently brought it back probably just within -- I don't want to the day, and he was cancelling that because he needed to some problems with the actual getting it here on time kind Q. Do you remember seeing Martin hand a check to A. Yes. Q. What was the facts surrounding him giving a Was it his personal check? Do you remember? He gave him a personal check because he ended up A.

Q. Did Martin follow those established procedures?

Q. Are you aware of any other situations involving
Martin and Roger where you believe he tried to set Martin

6 up? Yes or no?
7 8 9

6 say within hours -- later on that day, towards the end of
7

A. Yes.

Q.

What other -- Is there one or more incidents?

8 buy more and he needed it here sooner and he was baving
9

A. You know, the thing is that a lot of the time we would tell Martin to do something a certain way and then

10 would have different issues that would come up, and he
11

10 of issue and stuff. 11

12 he would turn right around and, you know, "Oh, he's doing 13 it this way, that's not the way we are supposed to do 14 this," and kind of get him in trouble and those kinds of 15 things. 16

12 Roger being payable to Midwest Premiums & Promotions?
13

14

15 check? 16

He required Martin to do all kinds of, I don't

1 7 want to say delay things, but you need to do this, you 18 need to get three of these, where there wasn't anything 19 really said about it, and, for everything
20

17 buying that using the funds from the Friends of the 18 Library, which happened frequently when something like in 19 this particular
20

and stuff. And

case didn't work out. You know, he go to an alternate method so he could get and

some people could just go out and do all kinds of stuff had been in place. And there was a lot of really weird stuff that would go on similarly. Q. Was there ever a transaction where you heard Yes

couldn't get it here timely, so then he had to get it at the cost associated with it.

21 that were contra to any written policy or anything that
22 23 24

21 subsequently
22 23 24

Q.
A.

Do you know whether or not Roger was aware of Yes.

this separate Friends of the Library account?

25 Roger Kolman say he wanted to teach Marty a lesson?

25

OTTMAR & ASSOCIATES

602-485-1488

Corrine wilcox-Cornn
Page 66
1 2
3

9/24/2010

18
Page 68

Q.

How do you know that?

1 the signatures were in place. 2

A. He was aware of that and he was upset that he couldn't get his hands on that and control that money, and he could always go to the

Q.

Would it be fair to say that the documents are,

3 they have a purchase request, a PR, then a PO, then an 4 invoice? 5 6

4 that it was always an out for Martin, and when Martin 5 really needed to get something,

A. Right.

6 Friends of the Library and get monies to be able to do 7 that, whatever it was. 8 9

Q.

Is there a procedure whereby the department heads

So no didn't mean no, necessarily.

7 and other people approve the invoice before the check is 8 written? 9 10 11

MR. LANE: Would you mark this next. (Deposition Exhibit No.2 was marked for

A. Yes.

10 identification.) 11 BY MR. LANE: 12

Q.
A.

What is that procedure? She actually puts a stamp on the invoice, that They sign off,

Q.

In the City of Maricopa, assume that a department head. Is that the same as a

12 way that they have actually seen the invoice before the 13 money gets charged into their account.

13 head -- I'm saying department 14 director? 15 16

14 yes, this is it, I did get it. That kind of verifies the 15 getting of the goods. 16 department 17 department 18

A. Yes.

And then it goes back to the

Q.

If they wanted to buy something, what starts the What's the very first thing they do to request

to actually issue the check, the finance to issue the check.

17 process?

18 the City buy something, whether it's soccer balls, pencils 19 or other stuff that they need bought? 20 21 22

Q.

Let me show you what we have marked for your Have you ever seen that document before?

19 deposition Exhibit No.3. 20 21 22 23 24 25

A. They would have to do a purchase request.

Q.

And what is that called? A purchase request? We refer to it as a PR, but a

A. Yes.

A. Purchase request.

Q.
A.

When did you see that document? On January 10. What was that document? Page 69

23 purchase request, yeah. 24 25

Q.

Now is that a PO? Page 67

Q.

A. No.

A. This document is a memo, and it had attached to of the purchase request. And it was

1

Q.

SO a department head submits to somebody in the finance, a purchase request?

1 it the cancellation

2 department, 3 4 5

2 sent to me so that I would release these funds, and that 3 he's basically cancelling this purchase order and this PO. 4

A. Right.

Q.
A.

What's the very next step that occurs? The very next step that occurs is that the PR is And department. They would

Q.

And had you already issued a PO on that order

5 yet? Do you know one way or the other? 6
7

6 signed by me, saying that there's money available. 7 then it would go to the purchasing

A. It would have been issued, the number would have been issued, but only the number would have been issued. that kind of stuff. But it would have been issued because

8 actually contact the vendor and get pricing and do that
9

8 Martin did a lot of his own ordering, calling the vendors,
9

kind of stuff, and then it would get ordered.

10 11 12 13 14 15 16

Q. Q.
A.

And I assume the vendor gets a purchase order --- and then fills the order? Right. Then an invoice comes in? Right. When the invoice is received, what steps are then Prior to issuing the check, basically, invoice and if there's no receiving documents, usually and And it would go to the were put together Then it would come back

10 the number is here. 11

A. Order.

Q.
A.

SO he issues a request, a purchase order number That's correct. Does the purchase order go out that day or is a couple days between them?

12 is assigned; is that fair? 13 14

Q.
A.

Q.

15 there sometimes 16

Q.
A.

A. You know, the purchase order is just the number.

17 taken prior to issuing the check? 18

17 The number is assigned and, hey, we are going to get it 18 from this vendor and it's going to be this amount. 19 That's, technically 20 made. 21

19 comes in, the invoice is usually matched up with receiving 20 documents,

the electronic file is what was being

21 the AP clerk would check with them, the department, 22 find out did we get these things.

Q.

Did you forward this -- Now this appears to

22 cancel the purchase request? 23 24 25

23 department head once all those documents 24 so they would okay the payment. 25 to the department

A. Yes.

Q.

Did you put that in the City system?

to actually issue the check, after all

A. Actually, I would not, because I would have

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 70
1 2

9/24/2010

19
Page 72

gotten a copy of this so that I released the funds, so that he could actually end up spending these monies. would have canceled it. Q.
SO

1

head didn't want to do that, and they wanted you to check, say, with -- find a vendor, go get this, then I would make contract people first to find out if we had any vendors available. Q. Are quotes generally received prior to a purchase request being submitted? A. Yes, so they can have a general idea of how much

And

2

3 a copy would have gone to the AP person and that person
4 5

3 those phone calls. Usually I would check with the state
4

it's the accounts payable person that would

5 and then I would try to use locals after that, who was
6 7 8 9

6 then cancel it?
7 8 9

A. Yes.

Q. Were you ever made aware that this purchase order
was in fact paid? A. No, I was never made aware it hadn't been paid. As far as I'm concerned, it was dead on arrival with this MR. LANE: Mark this as Exhibit 3. (Deposition Exhibit No.3 was marked for

10
11

10 stuff is going to cost and have general point of reference
11

if they can afford something. Q. Can you think of any reason someone would send a

12 information. 13 14 15

12

13 quote for items for which a purchase request has already
14

been submitted? A. No.

identification.)
Q. Let me show you what we have marked as Exhibit 3, & Okay? Forget there's some other handwriting.

15 16
17

16 BY MR. LANE:
17

Q.

Because if! understand it, the purchase request

is the item, the amount, tax, shipping, the whole ball of A. Yes. Q. It's your job to make sure that there's City A. Yes, because that's what I'm certifying. There's

18 which appears to be an invoice from Midwest Premiums 19 Promotions.
20

18 wax? 19
20

I want you to notice -- you mentioned a stamp. What kind of stamp is put on an incoming invoice? A. On an incoming invoice, there's one that actually has a signature area that basically gives the okay from the finance department and the actual department doing the Page 71

21
22 23 24 25

21 funding available to purchase that item?
22 23 24 25

actually a place on there that I actually would sign that I certified that there was actual funding available. Q. Who was in charge from the City of Maricopa side Page 73 of the FedEx investigation? A. Roger Kolman.

1 2 3

order and the purchasing department.

1 2

Q.

And if that is not on there, would it indicate

the department head did not approve that yet? A. This is true, the department would not have on it. And usually

3
4

Q. Not Chief Melvin?
A. Not Chief Melvin. Q. Were you yourself ever interviewed personally by Chief Melvin? A. No. Q. Any other Maricopa police officers? A. No. Q. Were you ever interviewed by Kolman? A. Initially, yes, when I gave him the information. Q. Have you ever been the finance director of the City of Maricopa? A. No. MR. LANE: I have nothing further. MR. DOYLE: MR. DOYLE: Do you want to read and sign? Pardon? You have the right and read and THE WITNESS:

4

5 approved that. Although it's got the "Paid" thing on 6 here, it doesn't have the department
7 S 9

5
6 7 B

it goes on the invoice.

Q. And if it's not on there, does it get sent back
to be correct to have it put on there? A. Yes. We can't do it without that. And it doesn't have a PO number either. This invoice is missing Q. And who would have the authority to pay it without that information? A. Well, the only person who actually issued checks director. Q. And who was that? A. That would have been Roger Kolman at this time. Q. Do you know the procedure that the City uses when Were you involved in that area at all, or is that pretty much up to the A.
>-

9
10 11

10
11

12 a few things. 13
14

12
13

14 15 16
17

15

16 in the City for the whole time I was there was the finance
17

18 19
20

18

19 sign your deposition to make sure that you heard the
20

questions, gave the answers you intended to and make sure correctly. You can waive that. It's up to you. MR. LANE: That just allows you to read what she's taken down, in case she's made a mistake, you can correct it. It's your choice. A lot of people waive

21 a department head requests a quote from a vendor?
22 23 24 25

21 it's been transcribed
22 23 24 25

Originally I was involved in that. A lot of the

time, if we were just getting quotes and the department

OTTMAR & ASSOCIATES

602-485-1488

Corrine Wilcox-Cornn
Page 74
1

9/24/2010

20

their signature. THE WITNESS: (3:10 p.m.) I'm going to waive it.

2
3 4

5 6
7

(Waived.) CORRINE WILCOX-CORNN

8 9 10
11

12
13

14 15 16 17 18 19 20 21 22
23

24 25

OTTMAR & ASSOCIATES

602-485-1488

Corrine wilcox-Cornn

9/24/2010

75

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
20

STATE OF ARIZONA ss. COUNTY OF MARICOPA BE IT KNOWN that the foregoing transcript was taken in the

before me, ROBIN JASPER, a Certified Court Reporter State of Arizona;

that the witness before testifying was

duly sworn by me to testify to the whole truth; that the questions witness propounded to the witness and the answers of the

thereto were taken down by me in shorthand and reduced to print under my direction; that the

thereafter

witness waived the right to read and sign the transcript; that the foregoing pages are a true and correct transcript of all proceedings, ability. I further certify that I am in no way related to any of the parties hereto nor am I in any way interested in the outcome hereof. Dated at Phoenix, Arizona, 2010. this 8th day of October, all done to the best of my skill and

21 22 23 24
25

ROBIN JASPER - Digital Signature AZ Certified Court Reporter No. 50286

OTTMAR & ASSOCIATES

602-485-1488

Sign up to vote on this title
UsefulNot useful