Following are excerpts from the recent deposition of Joyce Moss-Clay: Attorney Kelly Greenwood Prather asked

Moss-Clay about her consulting work for the construction company RHJ-JOC and her arrangement with HISD trustee Larry Marshall. Q. Okay. Did you ever give any money to Mr. Marshall out of what RHJ paid you? A. Yes. Q. And is there a percentage amount or a dollar amount you can tell me? A. A percentage. Q. What percentage is that? A. What started out as a fourth worked up to three-fourths sometimes. Q. So Mr. Marshall would get 25 percent to 75 percent of what RHJ or Ms. Jackson’s firm paid you? A. Yes. (---) Q. Why did you pay Mr. Marshall money from your RHJ fee? A. I paid Mr. Marshall primarily of any of the work that we collaborated on, so I wouldn’t just single her out. But he was important in my attempt to build -- not really build, but to establish a vehicle for assisting persons who were in need, or wanted, or desired to participate in some of the markets that had been limited to, let’s say, male-dominated areas, marketplaces. And so he and I felt that we had skill sets that would -- we could share with others to help them do the business

development, or to do strategic plans that could be incorporated into the way they operated. (---) Q. Why did you give up such a high percentage of your earnings to Mr. Marshall? A. I felt obligated to, primarily because much of my development over the years, professional development associated with the personal experience I brought to the job, was the reason why I advanced through HISD. And it was all as a result of his coaching and mentoring me and joining me in projects, you know, for a number of years. So I was -- I had no problem with giving that to him. None. (---) Attorney Greenwood Prather asked Moss-Clay about her consulting for the company Fort Bend Mechanical, which does air-conditioning and construction work for HISD. Q. And did Mr. Marshall share in the proceeds of your consulting fee that you received from Fort Bend Mechanical? A. Yes, he did. Q. Okay. And why did he share in the proceeds? A. Because he, again, servicing as my mentor, facilitated my design of a program, even though I did it, but our arrangement was to share as I saw fit with the income. Q. And in regard to Mr. Marshall's sharing the income on your consulting fees with RHJ and Fort Bend Mechanical, did he also agree to vote to approve contracts for them?

A. I don't know what he agreed to, but not with me or not with, as far as I know, not with Pete (Medford, the owner of Fort Bend Mechanical). I can't make that call for you. (---) Attorney Greenwood Prather asked Moss-Clay about her consulting for Linebarger Goggan, the law firm that HISD has hired to collect delinquent taxes. Q. Okay. Do you have any way of looking up how many hours you spent earning your money for Linebarger? A. No, because I was considered 24/7. They could always call me and say, "Can you go do this?" Q. But sitting here today, can you give me a ballpark, "I spent ten hours a year, 2,000 hours a year doing services for Linebarger"? A. No. Q. And tell me what Mr. Marshall contributed for his 75 percent of the Linebarger payment? A. Again, strategizing more than anything else. Suppose if I were to -- let me give you an assumption. Suppose I wanted to move to the southwest side of town to try to convince a community that we ought to do a – we ought to do a forum out there. Well, he has a better knowledge maybe of southwest persons to contact and how to go about selling the program without infuriating residents out there. So that's kind of the support that he can give me. And he's always been my first -- first post of contact in terms of doing projects, getting involved, going into communities, giving insert -- giving input to clients and saying, "This is what I think you ought to do." Q. Okay. So for Mr. Marshall's $1,125 a month payment, y'all would have a conversation and you would say, "Where's

the best place in Southwest Houston to put on a forum for Linebarger to communicate with the residents?"

A. Or somebody call Linebarger and they want them to do something in their community, you know, do you think it's -"Do you think it will fly? Do you think you can get community support? Is there anyone in the community that would be more receptive to what we want to do and what we want to say, the information we want to give out?" We don't want to be going out there and being attacked, you know. It's just their function, they have to collect taxes. Q. And so Mr. Marshall for his $1,125 a month would give you his two cents on that. A. Absolutely.

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