Deposition of Councilman Matt Dees and His Self Admitted Memory Problems, August 2016 (190 Pages)

Page 1
1 IN THE COURT OF COMMON PLEAS

OF NORTHAMPTON COUNTY, PENNSYLVANIA
2 CIVIL DIVISION
3
4 TRICIA MEZZACAPPA, : NO. C-48-CV-2011-11066
Plaintiff : NO. 1527 CD 2012
5 :
vs. : NO. C-48-CV-2013-12530
6 : NO. 1278 CD 2014
BOROUGH OF WEST EASTON, :
7 Defendant :
8
9 DEPOSITION OF MATTHEW A. DEES
10
11 Taken in the law offices of Steven
12 Goudsouzian & Associates, 2925 William Penn Highway,
13 Suite 301, Easton, Pennsylvania, on Thursday, August
14 18, 2016, commencing at 9:48 a.m. before Christine L.
15 Pelanne, Registered Professional Reporter.
16
17
APPEARANCES:
18
19 TRICIA MEZZACAPPA
817 Ridge Street
20 West Easton, PA 18042
-- Pro Se
21
22
* * *
23 VERITEXT LEGAL SOLUTIONS
Mid-Atlantic Region
24 4949 Liberty Lane, Suite 200
Allentown, PA 18106
25 (610) 434-8588
Veritext Legal Solutions

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1 APPEARANCES (Continued):
2
GOUDSOUZIAN & ASSOCIATES
3 By: STEVEN N. GOUDSOUZIAN, ESQ.
2925 William Penn Highway, Suite 301
4 Easton, PA 18042
610-253-9171
5 SteveSNGLAW@Gmail.com
-- For the Defendant
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1 INDEX TO WITNESSES
2
WITNESS PAGE
3
4 MATTHEW A. DEES
5
As of Cross-Examination
6 By Ms. Mezzacappa 5
7 Direct Examination
By Mr. Goudsouzian 184
8
9
10 INDEX TO EXHIBITS
11 PAGE
EXHIBIT DESCRIPTION MARKED
12
13 Exhibit-1 Petition for Contempt
No. C-48-CV-2011-11066 5
14
15 Exhibit-2 Petition for Contempt
No. C-48-CV-2013-12530 5
16
17 Exhibit-3 Undated Letter 8
18
Exhibit-4 OOR Final Determinations
19 Search Results 14
20
Exhibit-5 June 6, 2016 E-Mails 19
21
22 Exhibit-6 June 6, 2016 E-Mails 19
23
Exhibit-7 April 8 & June 6, 2016 E-Mails 19
24
25 Exhibit-8 June 23, 2016 E-Mail 19

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1 INDEX TO EXHIBITS (Continued)

2 PAGE
EXHIBIT DESCRIPTION MARKED
3
4 Exhibit-9 Final Determination
Docket No. AP 2013-1877 29
5
6 Exhibit-10 Final Determination
Docket No. AP 2013-2078 54
7
8 Exhibit-11 Section 1305 67
9
Exhibit-12 April 15, 2016 Letter
10 With Attachment 72
11
Exhibit-13 2012 E-Mails 80
12
13 Exhibit-14 Settlement Offer 121
14
Exhibit-15 May 24, 2016 Blog 145
15
16 Exhibit-16 April 11, 2016 Letter
With Attachments 148
17
18 Exhibit-17 May 24, 2016 Blog 170
19
Exhibit-18 August 17, 2014 Blog 172
20
21 Exhibit-19 June 9, 2014 Blog 178
22
23
24
25

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1 * * *
2 MATTHEW A. DEES, having been duly
3 sworn, was examined and testified as follows:
4 AS OF CROSS-EXAMINATION
5 BY MS. MEZZACAPPA:
6 Q. Okay. Shall we begin? Do you understand
7 why you're here today?
8 A. No.
9 Q. You do not understand. Do you understand
10 that I filed two petitions making allegations that
11 West Easton Borough is in disobedience of a court
12 order? I'm going to show you those two documents.
13 Have you seen those two documents before?
14 A. I did not see the document ending in 11066.
15 And I did not see the document ending in 12530.
16 MS. MEZZACAPPA: Can we stop and mark
17 those into evidence.
18 (Deposition Exhibit Numbers 1 and 2
19 were marked for identification.)
20 Q. Do you understand that we are here today
21 because I have to prepare a factual record to support
22 the allegations I made against West Easton Borough?
23 MR. GOUDSOUZIAN: Objection as to
24 what he would know about why you're doing this. You
25 can answer.

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1 MS. MEZZACAPPA: Would you like me to

2 rephrase it?
3 MR. GOUDSOUZIAN: Please.
4 Q. Are you aware of the fact that Juge Zito
5 ordered that a factual record be established so that
6 he can decide whether or not West Easton Borough is in
7 disobedience of a court order?
8 A. I'm aware that Judge Zito ordered
9 depositions to be taken.
10 Q. Okay. Do you understand that when you
11 answer questions in a deposition they have to be
12 clear, concise, and truthful, answering yes or no, and
13 not using body language, such as shaking your head yes
14 or no, or saying uh-huh, umm, that they have to be
15 words?
16 A. Yes, I understand that.
17 Q. Okay. Can you state your name, address and
18 date of birth?
19 A. Matthew A. Dees, 407 Second Street, West
20 Easton, Pennsylvania. 2/25/59 date of birth.
21 Q. Can you state the number of years at your
22 current address?
23 A. June of 2012 would be four years.
24 Q. Can you state the dates and terms of
25 elected office in the Borough of West Easton?

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1 A. I just started January 4th, 2016 I took

2 office.
3 Q. Can you state the position and title on
4 Borough Council from January 2016 to present in
5 relation to any committees that you did chair or are
6 the chairperson of?
7 A. I serve as councilman pro tem. I was on
8 the newsletter computer committee. I'm now on
9 properties -- the properties committee, and also --
10 it's old age.
11 Q. Did you ever serve on the legal committee?
12 A. That was part of the newsletter, yes.
13 Q. And what dates were you the chairperson of
14 the legal committee?
15 A. January to, my best guess, I would think it
16 was probably May or June.
17 Q. Were you chairperson of the legal committee
18 when I brought certain concerns to council about not
19 -- about the Borough not cooperating with court
20 orders?
22 certain concerns. How is he supposed to know what
23 certain concerns are?
24 MS. MEZZACAPPA: Okay. Let me get
25 the -- all right.

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1 Q. Were you the chairperson of the legal

2 committee when I furnished upon West Easton Borough
3 this letter?
4 A. I did not see this letter. I saw portions
5 of it. You had handwritten a letter I saw, but I did
6 not see this letter she presents me.
7 MS. MEZZACAPPA: I'd like to mark
8 this into evidence. Okay. This will be marked as
9 Exhibit 3.
10 (Deposition Exhibit Number 3 was
11 marked for identification.)
12 Q. So your answer then is that you never were
13 furnished a copy of this letter that was addressed to
14 Dear Council?
15 A. Not that I recall.
16 Q. Was this letter with its attachments ever
17 before the legal committee?
19 Q. Not that you recall?
20 A. I don't recall seeing that letter. I
21 recall seeing something you had handwritten with some
22 of those requests that are in that letter.
23 Q. Okay. Do you acknowledge that in -- in
24 this letter that I showed you, I drew attention to the
25 fact that the Commonwealth Court Order in favor of

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1 Mezzacappa has been blown off -- a third Commonwealth

2 Court Order involving the treasurer's report in my
3 favor from 2013 was also blown off, but I never
4 pursued action on that matter?
5 MR. GOUDSOUZIAN: Are you asking --
6 MS. MEZZACAPPA: I'm asking --
7 MR. GOUDSOUZIAN: He said he didn't
8 see the letter, so what are you asking him?
9 Q. Do you acknowledge that when I submitted
10 this letter to West Easton Borough Council, that I
11 positively brought up the fact that West Easton
12 Borough was not in compliance with certain
13 Commonwealth Court Orders?
14 A. I can't acknowledge that because I don't
15 recall seeing that letter.
16 Q. Okay. Who -- who at West Easton Borough
17 Hall was in charge of distributing correspondence that
18 was directed to council members?
19 A. What's the date on the letter? I might
20 give you a guess.
21 Q. Well, there is no date on the letter.
22 A. Well, I couldn't tell you who was in charge
23 because for a while we didn't have a Borough manager.
24 If there's no date --
25 Q. Was Mr. --

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1 A. If there's no date on the letter, I don't

2 even know when it was submitted.
3 Q. Okay. Do you remember me speaking at a
4 February -- about a February 22nd, 2016 meeting about
5 monies owed to me and that there were problems with
6 contempts of court with prior Court Orders, I
7 courtesied the floor, and that I was going to put it
8 in writing? Do you remember me standing up at
9 courtesy of the floor and announcing that at any time?
10 A. I recall you saying everything you just
11 said except the part about putting it in writing.
12 Q. Okay. To the best of your knowledge and
13 belief, did anyone else on Council receive a copy of
14 this letter that's marked in as Exhibit 3?
15 A. Not to my knowledge. You would have to ask
16 them if they received it.
17 Q. Are you aware of extensive litigation
18 involving the Right-To-Know Law that occurred between
19 myself and West Easton from about 2011 to 2015?
20 A. I'm aware from about 2012 when I first
21 moved to town.
22 Q. As a councilman, was it your responsibility
23 as the head of the legal committee to make sure that
24 West Easton Borough was in compliance with prior court
25 orders?

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1 A. I don't believe so. That would be our

2 attorney's responsibilities.
3 Q. So it's not the responsibility of anyone on
4 Borough Council to be in compliance with court orders?
5 A. It would be --
6 MR. GOUDSOUZIAN: Objection, he just
7 answered that.
8 A. Yeah.
9 Q. Do you feel that you have a responsibility
10 as a councilman to make sure that West Easton Borough
11 complies with court orders?
12 A. Under the advice of an attorney, if he
13 agrees, yes.
14 Q. Okay. What did you do -- what action did
15 you take since you've been a council person to make
16 sure that West Easton Borough became compliant with
17 the court orders at issue?
18 A. And those court orders are?
19 Q. Marked in as Exhibits 1 and 2.
20 A. I would just discuss the matter with an
21 attorney during executive session.
22 Q. Okay. So you admit then that all
23 discussions about this matter took place in executive
24 session?
25 MR. GOUDSOUZIAN: Objection, that's

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1 not what he said. He didn't say all discussions.

2 Q. Okay. Let me -- let me go back.
3 What action did you take as a Borough
4 Council member to make sure that West Easton Borough
5 was in compliance with the court orders that are the
6 subject of this instant matter?
7 A. Discussions took place during executive
8 session.
9 Q. The question is, what action did you take
10 as a Borough Council member to make sure that West
11 Easton Borough was in compliance with the existing
12 court orders? And that action could be encouraging
13 compliance, it could be asking to see the Orders, it
14 could be asking to see the history behind the Orders.
15 I'll let you answer what you did, what actions you
16 took.
17 A. I, along with other council members, pushed
18 to have a more open -- or less stringent Right-To-Know
19 policy. As for myself, I voted to award you monies
20 that were due you with the exception of those that the
21 Judge had imposed upon you, the fines that the Judge
22 imposed upon you. Everything else that you requested
23 I was for you getting as far as monies due.
24 Q. Okay. When you say you voted, on what date
25 and time did you vote? And I'll finish the -- on what

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1 date and time did you vote?

2 A. I don't recall the date, but it's -- it was
3 after executive session, we came out and we voted to
4 -- actually, we voted to -- let me correct that. We
5 voted to have our attorney, Mr. Goudsouzian, approach
6 you with that amount of money with the exception of
7 the fines imposed by the courts.
8 Q. At any time during that executive session
9 was this letter discussed that was marked in as
10 Exhibit 3?
12 what took place in executive session. It's an
13 executive session.
14 MS. MEZZACAPPA: All right.
15 Q. Let me go back to, are you aware of
16 excessive Right-To-Know litigation between myself and
17 West Easton Borough?
18 MR. GOUDSOUZIAN: What was the term
19 you used?
20 MS. MEZZACAPPA: Excessive
21 Right-To-Know litigation between myself and West
22 Easton Borough.
23 MR. GOUDSOUZIAN: You can answer that
24 if you can.
25 A. Excessive is matter of opinion, but I'm

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1 aware of Right-To-Know litigation that you've had with

2 the Borough.
3 MS. MEZZACAPPA: I'd like to
4 introduce a new exhibit.
7 Q. Marked in as Exhibit 4, Final
8 Determinations Search on the Office of Open Records.
9 Do you recognize what this document is?
10 A. Well, I can read that it's a Final
11 Determinations Search Results from the Office of Open
12 Records, but --
13 Q. Approximately --
14 A. -- I don't know what you're asking me. Do
15 I recognize it?
16 Q. Approximately how many --
17 MR. GOUDSOUZIAN: Wait. Are you
18 finished with your answer? Finish your answer.
19 A. No, I don't understand what -- what you
20 want by recognize. I recognize it being a Final
21 Determinations Search Results.
22 Q. Is it a listing of Right-To-Know litigation
23 between myself and West Easton Borough?
24 MR. GOUDSOUZIAN: If you can answer
25 that, you can answer it if you know what it is.

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1 A. Repeat your question, please?

2 Q. Is the document that I showed you a
3 comprehensive list of Right-To-Know litigation between
4 myself and West Easton Borough?
5 A. It appears to be.
6 Q. To the best of your knowledge, on
7 inspection of that document, is it true and correct
8 that there have been over 35 cases between myself and
9 West Easton Borough in the Office of the Open Records?
10 MR. GOUDSOUZIAN: You're asking him
11 what this document shows, not his knowledge, correct?
12 MS. MEZZACAPPA: Right, what the
13 document shows is correct.
14 A. What's the number you gave, 35?
15 Q. Correct.
16 A. It appears there are 35 at least.
17 Q. Going back to the question then, would that
18 satisfy your determination that there was excessive
19 Right-To-Know litigation between myself and West
20 Easton Borough?
21 A. May I see the documents again so I can see
22 the time span? Over three years, yes, I think you
23 were excessive.
24 Q. When you stated do you think I was
25 excessive or do you think West Easton Borough was

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1 excessive, can you explain that?

2 A. I think that both the Council at the time,
3 and this is just my opinion, because I wasn't serving
4 on Council, and you, were excessively filing
5 Right-To-Know requests and appeals and all that stuff.
6 That's my opinion.
7 Q. I'm going to follow up on that. I'll come
8 back to that. Let's move to the instant matters of
9 the petitions that are the subject of today's matter.
10 Okay.
11 Do you remember me showing you the
12 two petitions that I filed?
13 A. I remember you showing me two petitions.
14 Q. Okay. Are you aware that the decisions
15 were affirmed by the Commonwealth Court?
16 A. I'm not aware those decisions were
17 affirmed. I know something was affirmed, I don't know
18 what it was, there's so much out there.
19 Q. Did you ever read the orders attached to
20 these two petitions from the Commonwealth Court at any
21 time?
23 Q. Why didn't you read them?
24 A. I just told you I didn't see those earlier.
25 Q. Did you ask?

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1 A. I'm supposed to ask for something I don't

2 know about?
3 Q. As head of the legal committee, wouldn't
4 you be responsible for pending litigation?
5 A. I don't know what pending litigation is out
6 there.
7 Q. You don't know that there was litigation
8 filed by me against this Borough in April?
9 A. You -- you just said you filed 35 -- more
10 than 35 already with the Right-To-Know. I don't know
11 what you've got --
12 Q. Is it -- is it your answer -- is it --
13 MR. GOUDSOUZIAN: Hang on, I'd ask
14 you to allow him to finish his answer.
15 MS. MEZZACAPPA: Okay.
16 MR. GOUDSOUZIAN: And Mr. --
17 A. I don't know how many you have out there
18 and I can't -- I can't request something, is there
19 something that I haven't seen from Tricia Mezzacappa.
20 Q. Okay. When you became aware that I had
21 filed allegations against West Easton Borough for
22 disobedience of court orders, did you at any time from
23 the date you were aware until today, ask to read
24 copies of those court orders?
25 A. No.

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1 Q. Did you ask to read copies of the

2 underlying Office of Open Records' determinations that
3 were in my favor?
4 A. No.
5 Q. Did you ask to read copies of the
6 underlying Court of Common Pleas' decisions that were
7 in my favor?
8 A. No.
9 Q. Why not? Why didn't you ask?
10 A. Why -- why do I have to ask? Because it --
11 because you were pursuing the matter legally, until I
12 saw it come in front of me, I don't know if you're
13 going to drop that legal matter or keep pursuing it.
14 Q. Do you feel that it's important for West
15 Easton Borough to be in compliance with Commonwealth
16 Court Orders?
17 A. I do.
18 Q. Are you aware that to this day West Easton
19 Borough is still not in compliance with the subject to
20 two of these petitions being the Commonwealth Court
21 Orders?
22 A. I'm only aware that we tried to settle with
23 you on one matter that I'm aware of, that was the
24 money due you. Now, I'm aware that we're -- that you
25 claim we're not in compliance because I'm sitting here

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1 today.
2 Q. Do you think that West Easton should be in
3 compliance with -- with two existing Commonwealth
4 Court Orders?
5 A. Do I believe we should be in compliance
6 with two existing court orders? Yes.
7 Q. Okay. Then what reason is there for West
8 Easton to be out of compliance with the current
10 MR. GOUDSOUZIAN: Objection, that
11 assumes that West Easton is out of compliance.
12 Q. As alleged, and I'm alleging that West
13 Easton is out of compliance with the Commonwealth
14 Court Orders, what reason is there for West Easton not
15 to abide by the Commonwealth Court Orders?
16 MR. GOUDSOUZIAN: Objection. He
17 can't answer that. You -- in fact, to this day we've
18 asked you on repeated occasions tell us what's -- what
19 we're not in compliance with, and you haven't provided
20 an answer.
21 MS. MEZZACAPPA: Okay. Let me now
22 back up to an e-mail. Okay. One, two, three, four.
23 I'd like to mark in these as four different exhibits.
24 (Deposition Exhibit Numbers 5, 6, 7
25 and 8 were marked for identification.)

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1 Q. Marking in Exhibit 5, Exhibit 6, Exhibit 7

2 and Exhibit 8. Okay. I'm giving to you for your
3 inspection Exhibits 5 through 8, can you please tell
4 me what they are?
5 A. Appears to be e-mails between you and Mr.
6 Goudsouzian's office or Mr. Goudsouzian for the most
7 part about this whole -- all this litigation.
8 Q. Do the e-mails inform Mr. Goudsouzian of
9 why I believe that West Easton Borough is out of
10 compliance with the court orders and what is due to
11 me? Am I discussing and explaining that in that -- in
12 those exhibits that I handed you?
13 A. It appears to have your opinions in it,
14 yes.
15 Q. Are the opinions supported by final
16 determinations of the Office of Open Records in those
17 e-mails?
18 A. I couldn't tell you. I -- I'm not a legal
19 expert.
20 Q. Can you -- can I reintroduce --
21 MR. GOUDSOUZIAN: Hang on a one
22 second.
24 MR. GOUDSOUZIAN: You didn't make
25 copies, so I'm going to take a look at them.

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2 Q. Referring back to Exhibit 7 and Exhibit 8,
3 do these e-mails direct Solicitor Goudsouzian to the
4 links of the Office of Open Records' final
5 determinations in this matter?
6 A. Honestly, I don't know where these links
7 would lead to.
8 Q. You're not sure?
9 A. I don't know. It's just a printed link. I
10 can't click it. I don't know where it goes to.
11 Q. Do you acknowledge that the link says
12 dced.state.pa.us/open-records/final-determinations?
13 A. I can see what it reads. I don't know
14 where the link leads to. You asked me if that leads
15 to that site. I don't know that.
16 Q. Do you -- do you think that I was sending
17 Mr. Goudsouzian links to sites that were not final
18 determinations in this matter?
19 MR. GOUDSOUZIAN: Objection.
20 A. You got --
21 MR. GOUDSOUZIAN: Pardon me.
22 Objection. How would he know what you did or you
23 didn't do? You asked him you saw -- you showed him an
24 e-mail, which he identified. You can't ask him why
25 you're doing something or what was in your mind while

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1 you did it. How would he know?

2 MS. MEZZACAPPA: Okay. I'll rephrase
3 it.
4 Q. Do you believe that the e-mails made it
5 very clear that I was providing Mr. Goudsouzian with
6 the underlying decisions that led to the Commonwealth
7 Court decisions in these e-mails?
8 MR. GOUDSOUZIAN: Same objections.
9 Again, how would he know?
10 Q. Let's go back -- let's go back to Exhibit 7
11 and 8. Could you please reread Exhibits 7 and 8?
12 A. Okay. I read it.
13 Q. Okay. What did I discuss in Exhibit 7 and
14 8?
15 A. The monies that you paid out to West Easton
16 for fees.
17 Q. Did I describe in the e-mail that the final
18 determinations of the Office of Open Records were in
19 my favor?
20 MR. GOUDSOUZIAN: Are you asking him
21 is that what you said in the e-mail, that you're
22 asking him to read what it says?
23 MS. MEZZACAPPA: Let me back up.
25 Q. Is the e-mail -- the two e-mails that

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1 you're holding in your hand, are they e-mails

2 explaining to Solicitor Goudsouzian what the final
3 determinations were and what documents I am still owed
4 as of that date of that e-mail?
5 A. I don't honestly know if it explains
6 anything. It's -- it rambles. I -- I have a
7 difficult time trying to figure out what --
8 Q. Okay. Let -- let --
9 MR. GOUDSOUZIAN: Let him finish his
10 answer.
11 A. I have a difficult time trying to figure
12 out what you're trying to say in the order you put it
13 in. It looks like you're trying to give your
14 explanation of something of monies due, but I have a
15 difficult time following it.
16 Q. Okay. Let's -- let me see the exhibit.
17 I'd like you to read into evidence the date of the
18 e-mail from myself to Solicitor Goudsouzian, and I'd
19 like you to read the paragraph beginning here, Steve,
20 and ending here with the word case. I'd like you to
21 read it slowly and concisely into evidence.
22 A. Steve, I set up an auto reply that I will
23 be away until 8/15. I'm actually leaving tomorrow, so
24 I do not know if you got the auto reply.
25 At any rate, let me explain why West

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1 Easton owes $141.75. The below final determination of

2 the OOR spells out what actually made up their $100 --
3 their $141.75. See their statement of facts which
4 begins on page 3. I don't have page 3 here.
5 See their statement of facts, which
6 begins on page 3, and then look to page 7 through 9,
7 which I also don't have, where they disallow these
8 fees. The $141.75 is the total of $100 improperly
9 assessed, redaction cost, parentheses, down payment,
10 for the 2013 invoices. $12.50 for improper redaction
11 of bank statements, and $29.25 due for a previous
12 Commonwealth Court Order, parentheses, this contempt
13 was the action I dropped earlier this year in
14 CV-2012-7973, end parentheses.
15 After the OOR decided these fees were
16 assessed in error, West Easton appealed this decision
17 and another by rolling two OOR decisions into one
18 trial court docket number, parentheses, CV-2013-12530,
19 end parentheses.
20 You will also see a detailed footnote
21 on page 4, which I don't see here. In that footnote I
22 did not contest a payment I already made for $13.50
23 and another payment of $19, but did contest the
24 $12.50, $29.25, and $100.
25 It is important to point out the

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1 worth of the -- use this pen for a second. It is

2 important to point out that the worth of statement of
3 financial interest for Tom Nodoline and Kelly Gross
4 that I won at three levels of litigation in a year to
5 date expenditure report -- I'm sorry, and a
6 year-to-date expenditure report that I won at -- can I
7 start over again at that sentence?
8 Q. Uh-huh.
9 A. And a year-to-date expenditure -- instead
10 of providing the year-to-date expenditure report,
11 which was only about 15 pages, they printed out the
12 entire general leader record --
13 MR. GOUDSOUZIAN: Is it ledger maybe?
14 Q. Ledger.
15 A. All right. I'm reading as it shows here,
16 leader. General leader report is what it reads, over
17 100 pages. When I told them they printed the wrong
18 report, they kept the money and charged me extra for
19 the correct report.
20 It is also noted that I stopped
21 litigating the 2013-7973 contempt, because in that
22 petition I only sought the records, not fines, and
23 because West Easton already destroyed most of them, I
24 thought an effort in futility to continue the case.
25 Q. I'll take this back. Now that you've read

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1 into the record what I e-mailed to Solicitor

2 Goudsouzian, would you say that I have given him very
3 clear instructions, and I've made myself extremely
4 clear in why I am still owed this $141.75?
5 MR. GOUDSOUZIAN: Objection. Again,
6 as to the characterization of what you've done in your
7 mind.
8 Q. I am going to rephrase it for you. Based
9 upon what you just read into evidence, is it a fact
10 that I did, in fact, inform Solicitor Goudsouzian of
11 what parts of these Commonwealth Court Orders have not
12 been adhered to?
13 A. In -- in my opinion you're asking --
14 Q. No.
15 A. -- or is -- you're saying it's a fact
16 you've done.
17 Q. Let me start again.
18 A. I don't know if that's a fact.
19 Q. Do you acknowledge that part of the
20 noncompliance of the Court Order was the $141.75 fee
21 that I paid, that I alleged is due back to me?
23 you're asking him to acknowledge that there's some
24 sort of violation, and you asked him to read an e-mail
25 that you sent. But he indicated he hadn't seen the

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1 underlying agreements -- or the underlying decision,

2 so how would he know?
3 Q. Okay. Let's go back to exhibit -- let's go
4 back to Exhibit 2. Can you acknowledge what I wrote
5 in Exhibit 2, which is Petition For Contempt For
6 Disobedience Of A Court Order Requiring The Release Of
7 Specified Open Public Records, and this was caption
8 number 2013-12530. Can you read into evidence
9 paragraph number 3 of my allegation?
10 A. The parties were engaged in a Right-To-Know
11 records dispute that was fully litigated through the
12 Office of Open Records, this trial court and the
13 Commonwealth Court of PA beginning in 2012 and ending
14 in 2014. Plaintiff successfully won the right to
15 these records at all levels of litigation.
16 Additionally, fees charged improperly are due to be
17 refunded.
18 Q. Do you agree with the allegations in that
19 paragraph as to be true?
20 MR. GOUDSOUZIAN: You're asking him
21 if he agrees that your allegations are true, is that
22 what your asking him?
23 MS. MEZZACAPPA: Yes.
24 MR. GOUDSOUZIAN: How would he know?
25 Or you can answer it to the best you know, but ...

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1 Q. Did I bring --
2 A. No, because I didn't --
3 Q. Did I --
4 MR. GOUDSOUZIAN: Wait, hold on. Let
5 him answer.
6 Q. Okay.
7 A. Because I did not see that document that
8 you're referring me to verify your e-mail with.
9 Q. Okay. Let me back up again. Did I win the
10 right to certain records at all three levels of
11 litigation that started at the Office of Open Records
12 and went all the way to the Commonwealth Court where
13 determinations were made in my favor and against the
14 Borough of West Easton?
15 MR. GOUDSOUZIAN: If you're aware of
16 any of this.
17 A. Not this specifically. I'm aware that you
18 had won a couple of cases. I don't know it was
19 specifically these pieces of litigation you're showing
20 me here, because I hadn't seen those documents.
21 Q. So is it --
22 A. I'm aware that you were awarded -- let me
23 -- I'm going to expand on this. I'm aware that you
24 were awarded, I think it was $141.75, that's what I'm
25 aware of.

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1 Q. Okay. Good. Let's stop there. Okay. Now

2 that you're aware that I was awarded $141.75, do you
3 acknowledge that I was asked, and that I did explain
4 in an e-mail, Exhibit Number 8, what made up the
5 $141.75?
6 A. No, because I can't make sense of that
7 e-mail.
8 Q. The e-mail that you just read into --
9 A. The one I just read that rambles on about
10 check this page 7, that I'm not looking at, page 9,
11 and everything else that went into it, that -- that
12 just doesn't tell me you were awarded $141.75 without
13 the support of other things I hadn't seen. It's your
14 -- I agree that your opinion is that you were due
15 $141.75.
16 Q. Okay. Let's go back to Exhibit 8 that you
17 read in. And I'm going to ask you once again to read
18 -- all right.
19 MS. MEZZACAPPA: Okay. I'd like to
20 mark as evidence Exhibit 9. This is Final
21 Determination in the matter of Mezzacappa versus
22 Borough of West Easton, Docket Number AP 2013-1877.
25 Q. Okay. Do you recall reading that I was

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1 describing the final determination of fees that were

2 charged to me which -- that made up $141.75, and I was
3 referencing the OOR decision in my favor, and
4 specifically I said see the footnote on page 4? Can
5 you read the footnote on page 4 to yourself.
6 A. Okay.
7 Q. Okay. Can you also read -- here, let me
8 see this again. Just reread this one sentence where
9 -- see their statement of facts -- see their statement
10 of facts beginning with this --
11 A. Okay.
12 Q. -- sentence in the e-mail, this is Exhibit
13 8.
14 A. All right.
15 Q. The e-mail that I sent to Solicitor
16 Goudsouzian on June 23rd at 4:32 p.m., just read the
17 one sentence.
18 A. See their statement of facts which begins
19 on page 3, and then look to page 7 through 9 where
20 they disallow these fees.
21 Q. Does Exhibit 9 contain the statement of
22 facts in the sentence that you just referenced on page
23 3 and then continuing on page 7 to 9?
24 A. Tricia, what am I looking --
25 Q. I'm trying --

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1 A. -- for page 9 here?

2 Q. Right. Page 7 to 9 was part of the
3 decisions that disallowed the fees they charged. That
4 was the part of the decision where those fees were
5 ruled improper that I paid, pages 7 to 9.
6 A. Okay. I see some rulings 7 through 9 for
7 some fees, yes.
8 Q. Okay. Were those fees that you're reading
9 right now in the Final Determination which is marked
10 as Exhibit 9, were those the same fees that I
11 discussed in the e-mail that you've been reading aloud
12 that is marked as Exhibit 8?
13 A. I can't say for certain because I'm seeing
14 fees exceeding $100 is all it says.
15 Q. Okay. Can you -- okay. Can you go back to
16 the e-mail where I discuss the $100 fee? It was the
17 $100 fee and reread where I'm discussing that the $100
18 fee was ruled improper. Do you acknowledge that the
19 $100 fee West Easton charged me was ruled improper?
20 A. It appears it was ruled improper, yes.
21 Q. Did I explain to Solicitor Goudsouzian in
22 the e-mail that largely of the $141, part of it was
23 the $100 that was ruled improper?
24 A. It appears your explanation -- or your
25 opinion is it was ruled improper, yes, in that

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1 e-mail --
2 Q. Right.
3 A. -- your e-mail, yes.
4 Q. So it is correct and factual that, in fact,
5 that $100 is due back to me?
6 MR. GOUDSOUZIAN: Objection. If you
7 can answer that, and for that matter, if it hasn't
8 already been paid.
9 A. That was part of the $141 I thought.
10 Q. Are you stating that West Easton Borough
11 has paid me -- has paid me the $141.75 that was due
12 back to me?
13 A. It is my belief that you were offered a
14 settlement that included the $141.75 when I saw a
15 written request for your belief of what monies were
16 owed you, yes. I believe we --
17 Q. And are -- you realize to this day, that
18 $141.75 has not been paid, and that the Borough is
19 still not in compliance with that Court Order, which
20 this final determination which became part of the
21 Commonwealth Court Order?
22 A. $141.75 is -- no, I'm not aware of that.
23 Q. You're unaware that it's still outstanding?
24 A. Yes.
25 Q. Should West Easton come into compliance and

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1 pay that amount due back to me?

2 MR. GOUDSOUZIAN: Objection, if he
3 knows whether they're in compliance or not.
4 MS. MEZZACAPPA: I'm not asking that
5 question. I'm asking should West Easton pay the
6 $141.75.
7 MR. GOUDSOUZIAN: That assumes it
8 hasn't been paid yet.
9 Q. Has West Easton paid the $141.75?
10 A. I believe we had paid you, yes.
11 Q. Why do you believe that I was paid 100 --
12 did you --
13 A. Because I thought it was part of that total
14 list of demands that you had regarding amount of
15 monies that was owed you. I thought that -- I thought
16 this $141.75 was part of that.
17 Q. Okay. Let's -- let's go back to the issue
18 at hand here. Okay. Do you acknowledge that Exhibit
19 8, I wrote extensively in the e-mail to Solicitor
20 Goudsouzian why I believe I was owed $141.75? Does
21 Exhibit 8 accurately reflect what I just said?
22 A. I can't say if it reflects it accurately.
23 Q. Did I explain --
24 A. I mean --
25 MR. GOUDSOUZIAN: Pardon me, let him

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1 answer.
2 Q. Okay.
3 A. Your explanation, as I said, is totally
4 confusing to me. When you break out a line, I can see
5 that you're claiming some money was owed, you're
6 referencing an Office of Open Records' decision. But
7 if this money is actually still owed you, that I don't
8 know for sure.
9 Q. Well, if -- hypothetically if the money
10 were to be owed back to me --
11 A. I don't answer -- do I have to answer
12 hypotheticals?
13 MR. GOUDSOUZIAN: You do not.
14 Q. Okay. Let me -- let me go back to -- let
15 me have these exhibits.
16 A. I want to make sure I got them separated
17 for you.
18 Q. What -- what reason is there for West
19 Easton not -- not to pay the $141.75? Is there -- is
20 there a reason?
21 MR. GOUDSOUZIAN: That assumes it's
22 due, that assumes it hasn't been paid already, that
23 assumes it's been identified.
24 Q. All right. Is the $141.75 due back to me
25 through -- through the order that you just read and

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1 the exhibit that you just read, that also became part
2 of one of my petitions that included the Commonwealth
3 Court Order. Is the $141.75 at issue in that final
4 determination and in this petition?
5 A. At this point, I don't know.
6 Q. You still don't know?
7 A. I still don't know because I know we paid
8 you some money -- or we tried to pay you money. We
9 authorized payment of money, and I believe that was
10 part of it. So at this point, I don't know what
11 you've gotten and what you haven't gotten.
12 Q. Are you referring to the payment of money
13 that became part of the magistrate docket? Are you --
14 are you aware that I filed separately at the end of
15 June a magistrate docket with Magistrate Yetter that
16 requested reimbursement of fees related to code
17 inspections and other fees, but was completely
18 independent of this matter?
19 A. I believe your code fees was part of your
20 list of what you felt you were to be reimbursed for.
21 And as I said, I thought -- I thought part of the --
22 that demand you made in that handwritten note that I
23 read from you was -- I thought part of that was the
24 $141.75 that we agreed to pay you.
25 Q. What handwritten note are you referring to?

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1 A. It's a letter you gave to our secretary,

2 Joan, you had a list of -- of money you felt was due,
3 I think there was some over -- late charges for sewer
4 on it. You wanted to be reimbursed for harassment
5 charges, fines you received, and --
6 Q. And you're alleging that that note that I
7 gave to Joan was handwritten?
8 A. I saw one -- yes, the one I saw was in your
9 handwriting, and there was a couple checkmarks next to
10 it of, I think, an item or two that you said you
11 didn't expect to get paid for this, but you'd like to.
12 Q. But you never saw the typed letter?
13 A. I never saw that.
14 Q. Well, then where was the handwriting?
15 A. To my -- to my recollection, I don't recall
16 seeing that typed letter.
17 Q. Then where was the handwriting? Are you
18 saying that I wrote out on a piece of paper my --
19 A. I believe -- I believed it was from you.
20 It was handwritten with a list of everything you felt
21 was due -- due to you.
22 Q. Was -- was that my handwriting that was in
23 the magistrate docket number, in the magistrate filing
24 when I filed in June and had to handwrite a complaint?
25 A. As I said, it was -- it was handwritten. I

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1 don't know if it was your handwriting, but I believed

2 -- I believed at the time it was your handwriting and
3 you submitted the request.
4 Q. Okay. Are you aware that West Easton
5 Borough reimbursed me for the inspection fees paid
6 that were never performed, the improperly assessed
7 late fees to my sewer and garbage bill, and
8 approximately $200 in Right-To-Know fees that were
9 charged for routine copies with checklists and minutes
10 and bank statements from 2012 to present that could
11 have easily been faxed or e-mailed, and those were --
12 do you acknowledge that that's what I was reimbursed
13 for because I had to file it on a magistrate
14 complaint?
15 A. Are you asking me if you -- that's a number
16 of questions in there.
17 Q. All right. Let me -- let me make it more
18 clear. Are you aware of what I asked for in the
19 complaint I filed with the district magistrate in
20 June?
21 MR. GOUDSOUZIAN: If you know, that's
22 her question.
23 A. No, I didn't know what you filed with the
24 magistrate.
25 Q. Did anybody tell you what I filed with the

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1 magistrate?
3 MR. GOUDSOUZIAN: Other than me, and
4 now you can't talk about what I told you.
5 A. I'll make this easy for you, Trish. I'm
6 aware that you received a payment -- because you asked
7 me multiple questions there. I'm aware that you
8 received a payment. I wasn't aware that you had to go
9 and get that payment through the magistrate.
10 Q. Are you aware that because West Easton met
11 my request with silence on this letter and didn't pay
12 any of it, and didn't even come into compliance with
13 the Court Order, was the reason that I filed the two
14 instant petitions and then later the magistrate
15 action?
17 that, but it -- perhaps clarity help. Is your claim
18 that West Easton didn't come into compliance because
19 they didn't pay the $141?
20 MS. MEZZACAPPA: No, my claim is that
21 West Easton is still not in compliance of the
22 Commonwealth Court Orders.
23 MR. GOUDSOUZIAN: Because they didn't
24 pay $141?
25 MS. MEZZACAPPA: And records. Even,

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1 though, Steve, we have to stop this because that's for

2 you to depose me.
3 MR. GOUDSOUZIAN: Well, he can't
4 figure it out either. None of us can figure it out,
5 that's part of the problem.
7 Q. Okay. I'm trying to establish a factual
8 record of why we're here today.
9 A. I'd like to establish why I'm here today.
10 Q. Okay. Do you realize that the reason why
11 we are here today is because I have alleged that West
12 Easton Borough is out of compliance with two existing
14 A. I'm aware that, yes.
15 Q. Okay. Do you also understand that we are
16 here today because the lack of compliance with the
17 Court Orders also includes some monies in the amount
18 of $141.75 that I believe are due back to me?
20 if that's what you think is due?
21 Q. Is part of the reason why we're here today
22 a combination of records that are due to me and monies
23 that are due to me?
24 MR. GOUDSOUZIAN: And there's an
25 objection, how would he know that? That's the

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1 question that we've been trying to -- the Borough of

2 West Easton has been asking over and over again is
3 what do you allege is actually due. So if you're
4 asking him --
5 MS. MEZZACAPPA: All right. Let's go
6 back and --
7 MR. GOUDSOUZIAN: Is that what you're
8 telling him --
10 Q. Then let's go -- let's go back again.
11 We'll go back again to Exhibit 8 and Exhibit 7 and
12 Exhibit 6 and Exhibit 5. Let's go back to these
13 exhibits. Can you tell me if I am explaining why I
14 have filed the allegations against West Easton Borough
15 in these e-mails?
16 A. I already answered that, I can't tell what
17 you're doing in these e-mails because it's rambling.
18 I have trouble deciphering it. You're telling me now
19 that we still you owe $141.75, that's what I'm getting
20 from this.
21 I thought we were here because you
22 didn't get documents you felt you were -- I didn't --
23 I wasn't aware of any money. Okay. Does that answer
24 your question? I thought your money was paid up. If
25 you're claiming money is due, I had no knowledge of

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1 that.
2 Q. Okay.
3 A. And I'm still not sure it is due.
4 Q. Okay. How about are you aware of any
5 records that are still due?
6 A. I'm aware that you're claiming you're
7 looking for -- I'm aware that you're claiming we --
8 West Easton didn't provide you records. I'm not aware
9 of any records that we have that you didn't receive.
10 MR. GOUDSOUZIAN: Why don't you
11 identify what it is that you're looking for that you
12 claim West Easton didn't provide, then he can answer
13 it. Then at least West Easton will know what the
14 claim is.
15 MS. MEZZACAPPA: I'll ask the
16 questions, Steve. I'll ask the questions.
17 MR. GOUDSOUZIAN: Well, we can go
18 around and around for hours, or you can just simply
19 tell him what you want, and at least we can respond to
20 it.
21 MS. MEZZACAPPA: I'm trying to
22 establish a fact pattern of why West Easton is
23 continually bumping heads with the Right-To-Know Law
24 and myself. So I have to establish the fact pattern
25 with questions that can be answered.

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1 MR. GOUDSOUZIAN: Why don't you

2 actually specifically ask him what it is you're
3 looking for, and then he can say whether he knows we
4 provided it or not.
5 MS. MEZZACAPPA: Okay. Let's just
6 stop. Can we take a break here, Steve? Can we take a
7 break?
8 MR. GOUDSOUZIAN: You're -- feel free
9 to take a break.
10 (Brief recess was taken.)
12 Q. Exhibit 6 and 7 here, I'm going to show you
13 -- do you acknowledge that you read the e-mail from
14 Exhibit 8 --
15 A. Yes.
16 Q. -- from what I wrote?
17 Can you acknowledge the date of that
18 e-mail from myself to Steve Goudsouzian on Exhibit 8?
19 A. June 23rd --
20 Q. Okay.
21 A. -- 2016.
22 Q. Now, I'm handing you Exhibit 6 and 7, which
23 were also e-mails. Can you confirm the dates on these
24 e-mails, on 6 and 7?
25 A. Both of them are June 6th, 2016.

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1 Q. And is there an e-mail chain in those

2 e-mails that had another date of April?
3 A. Yes, on -- on Exhibit 7 shows April.
4 Q. Okay. Now, let -- let me see those --
5 these exhibits again now. Okay.
6 So on June 6th, 2016, Exhibit 6, I
7 sent an e-mail to Sue Ackerman, which -- who works at
8 this law office. Can you read the two paragraphs that
9 I wrote?
10 A. The missing information would be the
11 treasurer reports from May 2010 through September of
12 2011. Kelly Gross granted the entire request, then
13 refused to provide the reports based on a $30.25 fee.
14 It appears she knew why I was requesting them, during
15 my campaign in 2011 to alert the taxpayers that West
16 Easton does not balance its book. They appealed the
17 ORR decision and lost at all levels of litigation to
18 make sure I never had the info for the 2011 campaign
19 for Borough Council.
20 My calls to the Borough to obtain the
21 info were ignored, as were my e-mails and letters. I
22 never paid the fee and the fee was determined
23 improper. I petitioned for costs through the
24 Commonwealth Court, won and received them from the
25 Borough. It is all able to be seen on the public

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1 docket.
2 The other docket number 12530, also
3 has not been satisfied. I am owed $141 and several
4 documents, unreacted invoices for all of 2013, in
5 parentheses. And some of the DI -- some of the DUI
6 center accounting records from 2012 to 2013.
7 Joan ran a list of the impact fee
8 payments from 2012 to 2016 and gave it to me. She
9 also showed me the accounting records, in parentheses,
10 deposit slips, accounting from jail for inmate census,
11 and the copy of the check from West Easton Development
12 for the 2015 impact fees. Therefore, I only need to
13 see the same records for the period of 2012 to 2013
14 that was part of the request, parentheses, deposit
15 slips, jail census report, copies of checks from West
16 Easton Development.
17 I will be out of the area for
18 anticipated -- oh, you just said the first two
19 paragraphs.
20 Q. Okay. Based on what you just read into
21 evidence, is that an e-mail of me explaining some of
22 the underlying issues in this -- in this petition in
23 this matter about the fees owed and records owed?
24 A. It appears to be, yes.
25 Q. Okay. Going to now Exhibit 7, there are

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1 two e-mail chains on this exhibit, it is June 6th and

2 April 8th. Can you acknowledge those two e-mail
3 chains?
4 A. Yes.
5 Q. Can you read those into evidence of what I
6 wrote on the June 6th e-mail first?
7 A. Steve, here are the OOR decisions that
8 resulted in 2013-12530. Notice West Easton rolled two
9 decisions into one docket number to make it that much
10 more labor intensive for me to litigate. I will also
11 note that Abe Atiyeh also repugnantly refused to show
12 me any records of payment at all, thereby forcing me
13 to go through the great wall of West Easton to get the
14 DUI center revenues.
15 Curiously, other than an initial
16 e-mail during the OOR level of litigation, they,
17 parentheses, West Easton Development, did not
18 intervene in either of the court cases. Strange,
19 isn't it? Should be pretty easy for Abe to produce an
20 accounting of monstrous impact fees that West Easton
21 forced upon them in exchange for spot zoning of the
22 DUI center, parentheses, accomplished by via
23 ordinance. Really, really disturbing that no one has
24 any record of these impact fees coming or going. Lots
25 of money here.

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1 Q. Okay. So would you agree that's an

2 explanation of the underlying OOR decisions that
3 became part of these Court Orders?
5 whether it's an explanation. You asked him to read it
6 and he did, but he doesn't have the factual background
7 as to what it is and what it isn't.
8 Q. Okay. Then to the best of your belief,
9 what you just -- can you just summarize what I was
10 attempting to accomplish in the e-mail to Solicitor
11 Goudsouzian?
12 MR. GOUDSOUZIAN: Objection. How
13 would he be able to summarize what you are attempting
14 to accomplish?
15 MS. MEZZACAPPA: Because I had him
16 read the e-mails, and I'm just asking him for whether
17 he believes or not that I am trying to inform the
18 solicitor of what the OOR decision said, and what I am
19 owed.
20 Q. Do you believe that I tried to do that in
21 the e-mail that you just read?
22 MR. GOUDSOUZIAN: And objection. How
23 can he put himself into your mind as to what you're
24 doing and why you're doing it and how you're doing it
25 and whether you're doing it and what your motivations

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1 are?
2 MS. MEZZACAPPA: I'm not asking him
3 to put himself in my mind. I'm asking him to
4 acknowledge that I was explaining in these e-mails
5 what is due back to me with the Court Orders.
6 MR. GOUDSOUZIAN: That's an entirely
7 separate question. That's not what you asked him the
8 first three times.
10 Q. Do you acknowledge that I am -- that I am
11 attempting in this e-mail to inform West Easton what
12 it is that I am disputing in these petitions?
13 MR. GOUDSOUZIAN: Same objection.
14 MS. MEZZACAPPA: Why is it an
15 objection?
16 MR. GOUDSOUZIAN: Because you're
17 asking him to say is this what you are trying to do.
18 You keep asking him the same thing over and over
19 again.
20 MS. MEZZACAPPA: No, I asked --
21 MR. GOUDSOUZIAN: Pardon me. You
22 asked and I'm answering. You can't ask him -- it is
23 an objectionable question to ask him to speculate as
24 why you did something. He can only testify as to what
25 he knows and what he sees. He can't testify as to why

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1 you have done something.

2 MS. MEZZACAPPA: Let me try to
3 rephrase it.
5 Q. Did I write these e-mails that explained
6 what I needed from West Easton Borough on --
8 to the best you can.
9 A. You wrote the e-mails.
10 Q. Are you -- all right. Let's go back. Are
11 you aware that West Easton Borough has continually
12 asked me more than once, more than twice, and more
13 than three times to be absolutely specific about what
14 it is in the Court Orders that I believe have not been
15 followed?
16 A. Yes.
17 Q. Okay. Have I tried to, through the series
18 of e-mails in Exhibits 6, 7, 8 and 9, did I put in
19 writing what it was that I believed West Easton
20 Borough needed to do to come in compliance with the
21 Court Orders?
22 MR. GOUDSOUZIAN: Same objection,
23 it's what you believe. You keep asking what him, is
24 this what I did? Is this what Tricia Mezzacappa
25 believed? And he can't answer that.

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1 Q. Okay. In Exhibits 6, 7, 8 and 9 -- wait a

2 minute. Nope.
3 In Exhibits 6, 7 and 8, would you
4 agree that these are e-mails that I sent to Solicitor
5 Goudsouzian that discussed the underlying Court Orders
6 and the underlying ORR orders?
7 A. Yes.
8 Q. Okay. Was I reasonably specific in regard
9 to what I was seeking?
11 reasonably specific. Your e-mail reads what it says.
12 You identified it, you had him read it, it is what it
13 is.
14 Q. I'm not asking for an opinion. I'm asking
15 whether or not the e-mails were specific and described
16 what I was disputing in the Court Orders?
17 MR. GOUDSOUZIAN: Well, that is an
18 opinion, and he already responded to it, that it was
19 rambling, he couldn't figure it out, it didn't make
20 any sense.
21 Q. All right. Should we go back and have him
22 read again into evidence what I wrote so he can state
23 factually what is rambling and what is not understood?
24 MR. GOUDSOUZIAN: You've already
25 asked him that, plus your exhibits are made -- become

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1 part of the record. And you've also, for reasons I

2 don't understand, made him read the exhibits.
3 Q. All right. Maybe -- maybe I need to back
4 up here. The reason why I'm asking these questions is
5 because West Easton is continually saying, we don't
6 know what we owe her. I am continually saying, yes,
7 you do know what I owe you.
8 In between here we have communication
9 that I wrote, that you read of me attempting to
10 explain over and over again in e-mail chains what I am
11 owed. Do we have an agreement on that?
13 that somehow.
14 A. I can only give an opinion that you're
15 trying to convey what you believe you're owed.
16 Q. And do the e-mails discuss in detail what I
17 believe I am owed?
18 A. In detail, no, because -- we still don't
19 know what you think you're owed. What specific
20 documents do you want specifically?
21 Q. Okay. So it's not specific enough for me
22 to write a paragraph about how $141 was -- was
23 assessed wrong, and it's not enough for me to write
24 two detailed paragraphs about the records that I owed
25 quoting and linking the Office of Open Records'

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1 decisions, and that's not enough detail, is that what

2 you're saying, that I haven't provided enough detail?
3 A. Your opinions you've provided enough
4 detail --
5 Q. Have I provided enough --
6 MR. GOUDSOUZIAN: Pardon me. Let him
7 answer.
8 Q. Go ahead.
9 A. Your opinion is you've provided enough
10 detail. I don't know if that's enough to satisfy what
11 you're looking for.
12 Q. Okay. Let's move on.
13 A. How hard is it to write down a list of
14 exact documents, exact documents you want that we
15 haven't provided you already?
16 Q. Okay. Let's go back to Exhibit 6. Doesn't
17 that exactly state what you just said, exactly what is
18 due back to me? Can you read paragraph 2?
19 A. Okay. I read it.
20 Q. Does that explain adequately what is due to
21 me under these Court Orders?
22 A. It does not.
23 Q. Why not?
24 A. Well, for one thing, you've got in here I
25 am owed $141. Now, it's 141. And several documents,

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1 unreacted invoices for all of 2013 and some of the DUI

2 center accounting records. What are the some of the
3 records?
4 Q. Okay. Then let's go back to another
5 e-mail. This one discussed the fee. Do you
6 acknowledge that I wrote -- as you read, that I wrote
7 in this Exhibit 6, e-mail of June 6th to the
8 solicitor, Joan ran a list of the impact fee
9 statements from 2012 to 2016 and gave it to me. She
10 also showed me the accounting records, deposit slips,
11 accounting from jail for inmate census, and the copy
12 of the check from West Easton Development for the 2015
13 impact fees; therefore, I only need to see these same
14 records for the period of 2012 to 2013 that was part
15 of the request, the deposit slips, the jail census
16 report, copies of checks from West Easton Development.
17 Is that specific of exactly what is due to me?
18 MR. GOUDSOUZIAN: Objection. It's a
19 characterization. You can answer it the best you can.
20 Q. Have I identified what is due back to me in
21 what I just read?
22 A. In that document, you're --
23 Q. This is Exhibit 6 --
24 MR. GOUDSOUZIAN: Well, let him
25 answer the question.

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1 A. In that document you're giving your opinion

2 of what you're owed. The other document --
3 Q. It's my opinion --
4 MR. GOUDSOUZIAN: Pardon me. Let him
5 answer the question.
6 Q. All right.
7 A. Yes, that's what you wrote. I don't know
8 what you're owed.
9 Q. Okay. So it's your testimony today that
10 you still at this point in the game, at this point in
11 the litigation, you still have no idea of what the
12 problem is --
13 A. Of exactly what you're looking for?
14 Q. You still have --
15 A. No, I still --
16 Q. Okay.
17 A. -- don't because you still have not
18 provided anybody --
19 Q. Okay.
20 A. -- a list with exactly what you want.
21 Q. Okay. So then this --
22 A. We are supposed -- we are supposed to
23 decipher multiple e-mails back and forth where you
24 reference one to the other, and we're supposed to
25 figure out from all of that what you want, instead of

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1 you providing us a firm one, two, three, four item

2 list of exactly what you want. We're supposed to
3 decipher your ramblings in e-mails to figure out what
4 to get you.
7 Q. Okay. Let's move to Exhibit Number 10.
8 Exhibit Number 10 is Final Determination, AP
9 2013-2078. Final Determination exhibit marked Exhibit
10 10 was one of the two Final Determinations that became
11 part of the Commonwealth Court decision in 1278 CD
12 2014.
13 MR. GOUDSOUZIAN: Are you testifying
14 or asking him a question?
15 MS. MEZZACAPPA: I'm just -- I'm just
16 reading what the exhibit is. I'm marking it into
17 evidence.
18 Q. Can you understand that document is a final
19 determination?
20 A. It reads as final determination, yes.
21 Q. Okay.
22 A. Granted in part and denied in part.
23 Q. Can you page to the back, the last page
24 where it says conclusion?
25 A. Okay.

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1 Q. Are you aware that West Easton Borough

2 appealed that final determination?
3 A. I was not aware.
4 Q. Okay. Are you aware that when they did
5 appeal that final determination, it went into the same
6 docket number as the final determination in Exhibit 9?
7 A. No.
8 Q. Which -- okay. You weren't aware?
9 A. No.
10 Q. Okay.
11 A. This was 2013?
12 Q. Right.
13 A. Yeah, I wasn't even on council then.
14 Q. So you -- okay. So then you were not aware
15 that both of these final determinations were appealed
16 and rolled into one docket number, and West Easton
17 lost that docket number at the trial court level and
18 again at the Commonwealth Court level?
19 A. I was not aware of that.
20 Q. You were not aware of it?
21 And that those docket numbers are
22 substantially the issues that I am having with this
23 Borough today and continually since April? Do you
24 realize that these were the determinations, these were
25 the court cases, and that West Easton lost at all

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1 three levels of litigation, and that that is what --

2 that is why we are here today?
3 A. How many -- how many ands do we have in
4 there?
5 MR. GOUDSOUZIAN: Right, that's --
6 objection, that's a compound question you've asked --
8 MR. GOUDSOUZIAN: Hang on.
9 MS. MEZZACAPPA: All right.
10 MR. GOUDSOUZIAN: One moment, please.
11 You asked him seven questions of which he's already
12 answered most, if not all of them, over and over
13 again. You're asking him as to what he knows before
14 he became a council member. And I think he's
15 testified he was not aware of these things before he
16 was a council member. And they are of a time period
17 before he became a council member.
18 Q. Okay. I have to ask -- I have to -- just
19 bear with me. Can you just read into evidence this
20 part of the conclusion that -- that begins with for
21 the foregoing reasons and read the full sentence?
22 A. For the foregoing reasons, requester's
23 appeal is granted in part and denied in part and the
24 Borough is required to allow the requester to inspect
25 all minutes and checklists, all funds, approved at the

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1 Borough Council September 9th, 2013 meeting, the

2 requested unredacted bank statements without payment
3 of redaction or related copying costs and census
4 reports and bank statements for the period from June
5 1st, 2013 through September 15, 2013, upon the
6 requester's payment of the outstanding $19 fee if it
7 has not already been paid.
8 Q. Now, from what you just read, do you
9 understand that I sent e-mails in Exhibit 6, 7, 8 that
10 you also read, that describe these exact records that
11 were granted?
12 A. You're asking me if I understand those
13 relate to that?
14 Q. Right. That -- that because I won this
15 final determination and, again, at the trial court
16 level and, again, at the Commonwealth Court level,
17 that I wrote these e-mails to explain what I want, and
18 what did you just read? Did you read the records that
19 I just won? Did you read from the determination the
20 records that were granted to me?
21 A. After a $19 fee.
22 Q. Correct.
23 A. Yes.
24 Q. Right. Did you realize, also, I did pay
25 that $19 fee?

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1 A. I did not know that.

2 Q. Okay. Let's move --
3 A. You're talking three years before -- two
4 before I took council.
5 Q. Right. Is it -- is it a fact that I have
6 invested a significant amount of time embroiled in
7 this Right-To-Know matter alone to get the
8 Commonwealth Court Order that I did receive?
9 MR. GOUDSOUZIAN: Objection. How can
10 he know what time you spent? I mean, are you -- you
11 can --
12 A. I don't -- I was just going to say the same
13 thing. I don't know --
14 Q. You don't?
15 A. -- if you spent an inordinate amount of
16 time.
17 Q. Okay. It's not clear from the exhibits
18 from the three levels of litigation the amount of
19 time? It is not clear to you or you don't understand,
20 I'm not --
21 A. It's not clear to me. You could have given
22 it to your sister to do. I don't know. How much time
23 did you put in? I have no clue.
24 Q. You believe that I gave all of this to my
25 sister?

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1 MR. GOUDSOUZIAN: He doesn't --

2 A. I don't know if you gave it to your sister,
3 the next-door neighbor, or did it all yourself in the
4 middle of the night.
5 Q. Okay. Let's just say hypothetically, if I
6 did do it all of myself -- all by myself --
7 A. I don't answer hypotheticals.
9 Objection. He can't answer a hypothetical question.
10 And you're -- even if he could answer the hypothetical
11 question, it's relating to what you did of which he
12 has no knowledge.
13 Q. Is it a fact that this matter alone was a
14 waste of resources and time?
15 MR. GOUDSOUZIAN: Objection. You can
16 answer that if you can. I don't know how he would be
17 able to, but go ahead.
18 A. Is it a waste to defend yourself? I don't
19 think so.
20 Q. Okay.
21 A. But to expand on that, I believe you could
22 solve this easily without what we're going through
23 today.
24 Q. I'll get back to that. All right. As a
25 reasonable person and a member of Borough Council --

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1 MS. MEZZACAPPA: Is this okay, Steve,

2 you're rolling your eyes?
3 MR. GOUDSOUZIAN: Go ahead and finish
4 your question.
6 Q. As a reasonable person and a member of
7 Borough Council, if you had gone through three levels
8 of litigation over what were standard business public
9 records, and won at all three levels of litigation,
10 would you expect the Borough to comply with the Court
11 Order?
12 MR. GOUDSOUZIAN: Now you're -- now
13 I'm going to object, you're asking him a compound
14 question, and it's all hypothetical.
15 Q. Okay. Do I have a right to expect that
16 West Easton Borough will comply with the orders of the
17 Court?
19 Now, you're talking about your expectation. How can
20 he testify as to what your expectation is?
21 Q. All right. Let's go to --
22 MR. GOUDSOUZIAN: Why don't you ask
23 him what he knows, that's the purpose of the
24 deposition.
25 Q. Okay. What -- what do you know?

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1 A. Regarding what?
2 Q. Why --
3 A. What do I know? I --
4 Q. Let's go back to why we're here today.
5 A. When the sun is going to rise tomorrow.
6 Q. Why we are here today.
7 A. Why we're here? You're -- you're angry at
8 West Easton. You're looking for something that you
9 think is going to be satisfied through some kind of
10 judgment. You're looking for vindication. You're not
11 looking for these records that you're missing or the
12 $141 that you claim you have. You're looking for some
13 type of vengeance upon a Council that existed two
14 years ago or last year. And you're trying to prove a
15 point by tying up everyone's time and energy into
16 this. That's what we're doing here.
17 Q. Okay. So you don't think that -- you don't
18 think that I have any right at all to the records that
19 were ordered to be due under the Court Orders, is that
20 what you're saying?
21 MR. GOUDSOUZIAN: That is --
22 A. That is not what I said.
23 MR. GOUDSOUZIAN: Pardon me. Excuse
24 me for one minute. Objection. Assuming that they
25 haven't already been provided. But go ahead, you can

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1 answer to the best you can.

2 A. Yeah, that's not what I said.
3 Q. So to restate what you said, no --
4 A. I don't know -- that's not what I said. I
5 said I don't know what you've been provided yet.
6 That's what I gave was my opinion of why we're really
7 here. I don't think these records that you're missing
8 are that important to you. You're trying to prove
9 some kind of point. You want to be vindicated and
10 victorious in this hunt, and I think it's a leftover
11 residual hatred of a previous Council.
12 We are trying -- this new Council,
13 Tricia, is trying to change what happened in the past
14 towards you and towards myself even, who had to put in
15 Right-To-Know requests. This is a new Council. No
16 one is trying to suppress any information from you or
17 cheat you out of anything. If you would tell us what
18 you want in a list, we could satisfy this today
19 probably.
20 Q. Okay. Why isn't West Easton Borough coming
21 into compliance with the Court Orders then as of
22 today?
23 A. I think we're trying --
24 Q. Why is West Easton Borough still out of
25 compliance?

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1 A. -- we're -- we're still waiting for an

2 exact list of documents that you want.
3 Q. Okay. So the list of documents that were
4 previously entered into evidence as Exhibits 6, 7, 8
5 are not sufficient, is that your testimony today?
6 A. My testimony is, I still don't know what
7 you're looking for.
8 Q. Okay. So --
9 A. You haven't given me an exact list of
10 documents. You say some documents, oh, now, check
11 this e-mail, and I mentioned some documents in here,
12 and this e-mail references something else.
13 Q. Okay. Let me go back.
14 A. How hard is it to make up a list, Trish,
15 and give it to us?
16 Q. Okay. Let me go back and ask. The
17 documents that were marked into evidence as Exhibits
18 6, 7, 8, 9, were all e-mails that you read into
19 evidence, correct?
20 A. Yes.
21 Q. Okay. And is it your testimony today that
22 the e-mails that you read into evidence are not
23 sufficient enough for West Easton to determine what --
24 what I still need?
25 MR. GOUDSOUZIAN: Objection, I think

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1 he said that five times.

2 Q. I don't think I have it.
3 MR. GOUDSOUZIAN: Okay. Go ahead.
4 You can answer it.
5 Q. Is that this is not sufficient enough, is
6 that your testimony, the Exhibits 6, 7 and 8?
7 A. I don't know if it's sufficient enough.
8 Q. Now you're saying you don't know. You
9 previously --
10 A. I don't know. Previously I said what?
11 Previously I said you rambled on --
12 Q. That I have to give you --
13 A. -- in the e-mails --
15 A. -- that I couldn't understand.
16 Q. Did you say that I have to provide West
17 Easton a specific point-by-point list of what is due
18 back to me?
19 A. Documents, give -- yes, please give us --
20 Q. Okay.
21 A. -- a list of documents that you feel you
22 didn't get already.
23 Q. Why is Exhibit 6, 7 and 8 not enough
24 explanation and listing and detail to satisfy what --
25 what you want?

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1 A. I can't answer -- I can't answer why -- are

2 you asking me why it's not enough for me, or why it's
3 not enough for West Easton? I can't answer for the
4 rest of the Council. I can't answer for Mr.
5 Goudsouzian.
6 Q. I'm asking why the e-mails aren't
7 sufficient enough. You said I had to list it out.
8 Aren't the e-mails --
9 A. Isn't sufficient enough for who?
10 Q. For the Borough to come into appliance for
11 the Court Orders.
12 A. I can't answer for the rest of the
13 councilmen, I can't answer for Mr. Goudsouzian --
14 Q. Can you answer for yourself?
15 A. -- and I can't answer that we haven't come
16 into compliance. I don't know what -- what you
17 haven't received because you haven't given us a
18 specific list.
19 Q. Okay. So --
20 A. And you're talking about stuff -- and
21 you're talking about stuff that you requested how many
22 years ago?
23 Q. Okay. You said I have not given a specific
24 list?
25 A. I'm asking you to provide a specific list

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1 of documents.
2 Q. Okay. Here we go again, one last time.
3 Exhibits 6, 7, 8, e-mails dated June 6th, June 26th,
4 April the 8th, e-mails and e-mail chains that you
5 already read into evidence, is this not specific
6 enough, yes or no?
7 A. For me, no.
8 Q. No. Okay. Let's move on.
9 MR. GOUDSOUZIAN: Can I see 6 through
10 9, please?
11 MS. MEZZACAPPA: Sure. 6 through?
12 MR. GOUDSOUZIAN: Through 9, all the
13 e-mails.
14 MS. MEZZACAPPA: 6, 7 and 8 I have,
15 and 5.
16 MR. GOUDSOUZIAN: I'll take 5. Is it
17 5, 6, 7 and 8?
18 (Discussion held off the record.)
19 MR. GOUDSOUZIAN: And I want the
20 record to be clear that Ms. Mezzacappa has not
21 provided copies of any of the exhibits. I've asked
22 her to provide Exhibits 5 through 8, which I made
23 copies of for my own sake.
24 It is my specific request that the
25 stenographer, since this is a trial deposition, the

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1 stenographer take the exhibits, make them part of the

2 file record. It is the appropriate way to have a
3 clear and concise record before the Court where
4 there's no issue with regard to copying or anything
5 else.
6 If copies were made in advance,
7 various accommodations could be made. But this is for
8 trial purposes, it is not for deposition purposes,
9 therefore, I want the record to be clear, and I want
10 the stenographer to keep the original exhibits and
11 make the appropriate copies when she provides a
12 transcript. Thank you.
14 Q. Let's move on to the next question. Are
15 you aware of a section of the Right-To-Know Law
16 entitled Section 1305 civil penalty?
17 A. No.
18 MS. MEZZACAPPA: Okay. Let's mark
19 into evidence Exhibit Number 11.
22 Q. Can you please read into evidence Section
23 1305 Civil Penalty?
24 A. (A), denial of access, a Court may impose a
25 civil penalty of not more than $1,500 if an agency

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1 denied access to a public record in bad faith.

2 (B), failure to comply with Court
3 Order, an agency or public official who does not
4 comply -- who does not promptly comply with a Court
5 Order under this act is subject to a civil penalty of
6 not more than $500 per day until the public records
7 are provided.
8 Q. Okay. Do you agree that West Easton
9 Borough is subject to that law?
10 MR. GOUDSOUZIAN: Objection, unless
11 you know.
12 A. Yeah, I don't know.
13 Q. Okay. Are you aware that this provision in
14 the Right-To-Know Law took effect in -- on January
15 1st, 2009?
16 A. No.
17 Q. Would you read into evidence where it says
18 in the law that the -- this provision -- right here at
19 the bottom, okay, the following, can you read into
20 evidence when they took effect?
21 A. The following provisions shall take effect
22 immediately, (i) -- I'm sorry, yeah (i), Sections 101,
23 102 and 1310. (ii), this section. (2), Chapters 15
24 and 17 and Sections 3102(1)(i) and 3102(2)(2),
25 Chapters -- oh, 3102(2)(i) shall take effect July 1st,

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1 2008. (3), the remainder of this act shall take

2 effect January 1st, 2009.
3 Q. Okay. Is it your understanding from what
4 you just read that this -- for purposes of
5 Right-To-Know Law, that Section 1305, which discussed
6 the penalties went into effect in 2009?
8 he knows. He said he doesn't know the statute. You
9 asked him to read what the -- you asked him to read
10 what the documents says. You handed him a document,
11 you asked him to read it, which he did. Now you're
12 asking for as to what effect it has over a law that he
13 doesn't know anything about.
14 Q. Is West Easton Borough subject to 1305
15 penalty?
16 A. I don't know.
17 Q. You don't know?
18 A. What is that -- what is that from?
19 Q. Okay. This is actually from the
20 legislative history. I actually printed it out from
21 when the Right-To-Know Law was created from the
22 internet from the PA Legislature to answer your
23 question.
24 Was the Right-To-Know Law created,
25 Section 1305 specifically, a civil penalty, to deter

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1 an agency from blowing off Court Orders without

2 penalty?
3 MR. GOUDSOUZIAN: Objection. You're
4 now asking him why the law was passed, over a law
5 which he doesn't know anything about. How would he
6 know these things? You can answer it if you can,
7 but --
8 A. I don't -- I don't know. I mean, as far --
9 my opinion of the Right-To-Know Law is -- is to make
10 it less stringent to get public knowledge. I'm all
11 for somebody wants minutes to a meeting, give them the
12 dam minutes, they don't have --
13 Q. So is this --
14 A. -- to put in a Right-To-Know request. I'm
15 not familiar with every section of the Right-To-Know
16 Law. I mean, if -- if you're saying that's what it
17 says, I'm reading it, that's what I read.
18 Q. So the civil -- the civil penalties were
19 part of the Right-To-Know Law, are you acknowledging
20 that there are civil penalties available under Section
21 1305 of the Right-To-Know Law?
23 that.
24 A. I'm aware of what I heard in Court and your
25 requests for monies that you believe you're due under

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1 this litigation.
2 Q. Okay. But did you just read Section 1305
3 of the Right-To-Know Law into -- into evidence of what
4 it says?
5 A. You gave me an unmarked paper with
6 something written on it that I read, but it doesn't
7 say where it came from, so if -- if --
8 Q. Okay. Let's go back. I'm trying to
9 reintroduce this again. Does this setting say --
10 heading say Section 1305 Act of February 14th, 2008,
11 with certain numbers and letters after it,
12 Right-To-Know Law enactment, is that what this --
13 A. It's printed off of your -- off of your
14 computer, yes. Do I have the actual book in front of
15 me, no.
16 Q. Okay. Does it discuss what the remedy is
17 for people who fail to abide by Court Orders in
18 Section 1305?
19 A. Your printed copy mentions civil penalties,
20 yes.
21 Q. Okay. Are they $1,500 per -- what does it
22 say what the remedies are?
23 A. Why are you asking me to read something and
24 asking me if it says it?
25 Q. I'm asking you what the remedies are?

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1 MR. GOUDSOUZIAN: That's an entirely

2 separate question. You've asked him to read a
3 document, which he has done. You also marked the
4 document. But then you were asking him what the legal
5 ramifications are of a law that he's not familiar
6 with.
7 Q. Does it state that it's $500 a day penalty
8 for each day that the agency is out of compliance with
9 the Court Order?
10 A. Your paper here says not more than $500 per
11 day until the public records are provided.
12 Q. Okay. Now, have you seen this letter that
13 I'm marking into evidence as Exhibit 12?
16 Q. Have you seen this letter from myself to
17 Attorney Goudsouzian dated April 15th, 2016?
18 A. I don't -- I don't recall seeing this, no.
19 Q. Okay. Is attached to the letter a
20 spreadsheet that shows the $500 a day fine
21 extrapolated over the number of days that West Easton
22 is late for a total of 600 and I believe -- $675,500
23 in fines?
24 A. Yes, attached is the spreadsheet.
25 Q. Okay. Are you acknowledging that West

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1 Easton's exposure in this would be under the letter of

2 that law a $500 a day fine coming up to $675,000?
4 A. No.
6 you're asking him the same type of question. You're
7 asking him to interpret a law that he's not familiar
8 with, but go ahead and answer it.
9 A. No.
10 MS. MEZZACAPPA: No, I'm not. I'm
11 not. I'm asking him to interpret what I've put on my
12 spreadsheet.
13 A. If you want me to repeat the number you put
14 on your spreadsheet, is that your question --
15 Q. Did I --
16 A. -- what number did you put down? The
17 number you put down was $675,000.
18 Q. Okay. Let's move on.
19 Are you aware that in my petition I
20 kept each petition at $25,000 each instead of the full
21 $675,000?
22 A. I'm aware of that through of that Court
23 hearing I attended, yes.
24 Q. Okay. All right. Are you aware that when
25 the Commonwealth Court affirmed the trial court, West

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1 Easton -- on both matters, West Easton failed to

2 exhaust their appeal to the Supreme Court?
3 A. No.
4 Q. Did they appeal to the Supreme Court?
5 A. I don't know.
6 Q. Okay. Would you agree that if West Easton
7 disagreed with the Commonwealth Court that they could
8 have appealed up to the Supreme Court?
9 A. No, because I don't know what the appeals
10 process is.
11 Q. Are you aware that they did not appeal to
12 the Supreme Court in either of these two cases?
13 A. I already answered that, no, I'm not aware
14 of that.
15 Q. Okay. That's it anyway. On what day is
16 Solicitor Layman or Christy Schlottman convey the
17 court orders to Borough Council?
18 A. I have no idea.
19 Q. To the best of your knowledge and
20 recollection, on what date did West Easton cooperate
21 or attempt to cooperate with the court orders?
22 A. The orders we've been discussing here?
23 Q. Correct.
24 A. Probably after the reorganization meeting,
25 trying to find out what exactly you wanted, that would

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1 be around February -- beginning of February, I would

2 guess.
3 Q. That's a guess?
4 A. That's a guess. Because there was a lot
5 going on. It was a busy first couple months.
6 Q. Okay. Let's get -- let's stop here and go
7 right to those busy couple of months. And I'm going
8 to come back to this.
9 Now, that we are at the beginning of
10 the year, did you take office January 4th, 2016?
11 A. Yes.
12 Q. What was the overall condition of the
13 Borough office at the time you became a councilman?
14 A. Disarray.
15 Q. Can you describe what you meant by
16 disarray?
17 A. We were lacking office staff. We had to
18 get our clerk back. We were anticipating getting a
19 new attorney. We had -- so we only had one staff
20 member. And then we had to locate files for meetings,
21 get the recorders going -- or try to get the recorders
22 going, try to get into computers. The computer -- we
23 were locked out of the computer.
24 Q. Were you aware of any missing computers or
25 any missing documents?

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1 A. At -- when I took office? When we first

2 took office? No.
3 Q. Well, not as you took office, but as -- as
4 you became a councilman, were you -- were you aware of
5 missing computers and missing documents and missing
6 files?
7 A. I was aware of missing computers. I was
8 not aware of missing paper files. Computers. The
9 computers, I don't remember. I think it was the --
10 might have been the reorganization meeting, it might
11 have been the meeting after, I'm not certain. We
12 discovered that old computers were missing and in its
13 place was a new computer.
14 Q. Are you aware of a security video that was
15 taken on December the 30th, 2015?
16 A. Yes.
17 Q. What did the security video show?
18 A. It showed a man entering the building that
19 we later determined to be a computer technician for
20 the previous Council entering the building, and then
21 at the end of the -- at the end of the time, which I
22 think was about two hours, that gentleman and Tom
23 Nodoline were walking out with what appeared to be a
24 computer, and it was placed in the back of the
25 technician's car, and they drove off.

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1 Q. Did they have permission to do that from

2 Council to remove Borough property?
3 A. Not the new Council, no.
4 Q. Were any of those computers ever recovered,
5 to the best of your knowledge and belief?
6 A. Yeah, we got the one that ended up in the
7 back of the tech's car, he returned it after we
8 contacted him. We got that back, yeah.
9 Q. Okay. But the other two were never
10 recovered, is that the correct way to --
11 A. I think there was one other and --
12 Q. That was never recovered?
13 A. Well, it was -- it was brought back, but it
14 had to -- if I remember correctly, I think there was a
15 problem with the hard drive, it was corrupt.
16 Q. Okay. Were there -- was there something
17 else in the office where files had been wiped clean?
18 Was it a server or another computer where files like
19 e-mail or other files had been wiped off?
20 A. Yeah, there was a computer in the main
21 office, which would be the main computer in the
22 Borough manager's office. When we finally got into
23 that, it appeared -- it appeared the files were
24 missing.
25 Q. Okay. Were any complaints filed with

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1 anybody -- with any agency, or were any complaints

2 made to hold responsible the persons that interfered
3 with the property and spoiled the records?
4 MR. GOUDSOUZIAN: I'm going to object
5 and then caution you, and then you can answer it. I'm
6 going to object because it's part of a pending
7 investigation --
9 MR. GOUDSOUZIAN: -- and, therefore,
10 I would caution you to not respond --
11 THE WITNESS: Okay.
12 MR. GOUDSOUZIAN: -- in that sense.
13 However, it is appropriate, and I want you to respond
14 that it was referred to an entity for investigation.
15 I mean, you do what you want, but, I mean, you can go
16 that far.
17 A. Well, I was going to answer that we
18 authorized our solicitor to pursue it.
19 Q. Okay. I'm not going to keep asking
20 questions about that. I'm moving on to the next
21 question.
22 Is it a fact that most of my several
23 e-mails to West Easton Borough over many years were
24 not available anymore because of the deleting of
25 e-mail files on the server?

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2 to the extent that how is he supposed to know what is
3 not on the server?
4 MS. MEZZACAPPA: I understand. Okay.
5 Q. Were e-mails deleted from the server -- to
6 the best of your knowledge and belief, were e-mails
7 deleted from the server?
8 A. To my belief, I believe that e-mails were
9 deleted. We could not find past e-mails.
10 Q. Okay. Was there a forensic investigation
11 into how many files were deleted and how many e-mails
12 were deleted?
13 A. No, not forensic.
14 Q. Okay. Is it a possibility that many of my
15 communications through e-mail over the years are no
16 longer available or retained?
18 to the best you can answer.
19 A. I would say it's possible, sure.
20 MS. MEZZACAPPA: Okay. I'd like to
21 switch over to some of those e-mails. And now, this
22 exhibit, Steve, do you want to look at it? It is --
23 I'm going to mark it in as Exhibit 13. Remember in
24 Court when you said I sent all these e-mails to you
25 one at a time, I cut and paste them into this

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1 document. Okay.
4 MS. MEZZACAPPA: So I'm marking in
5 Exhibit 13, which I'm going to show to Steve first.
6 They're a collection of e-mails from 2012 that went
7 back and forth between myself, Kelly, the Borough, and
8 the police chief. And I'm going to run to the
9 bathroom while you look at it. When you're done, can
10 you pass it to your client to read?
11 MR. GOUDSOUZIAN: I'll be happy to.
14 Q. Have you read this exhibit?
15 A. No, I have not.
16 Q. Okay.
17 A. I haven't read all of them.
18 Q. Can you take your time and read through?
19 A. Every one? I mean --
20 Q. Yes, please.
21 A. Okay. Tricia, my memory is not as good as
22 it used to be. By the time I get to the last one, I'm
23 going to forget what the first one said. If you have
24 questions, can we, like, go to the e-mail you want me
25 to read? Honestly, if I read all of this, by the time

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1 I get to the last one, I won't remember what the first

2 one said. And you're going to ask me questions on the
3 first one, and I'll have to read it again.
4 Q. Okay. So you want me to go one by one
5 through every single e-mail in the pack? I want you
6 -- I want to -- the purpose -- I'm trying to ask you
7 to read the e-mails so you can understand the
8 obstacles that I was facing continually with
9 Right-To-Know -- picking up Right-To-Know requests.
10 A. All right. You want me to get a general
11 feel of the e-mail.
12 Q. I want you to get a general feel of --
13 A. I thought I was going to have -- I thought
14 I was going to have to retain something in --
15 Q. Okay. I will get specific with a couple.
16 A. Okay.
17 Q. But it's the scheduling of the
18 appointments, not being scheduled in the morning when
19 I could.
20 A. I'll take a --
21 Q. Okay.
22 A. I'll breeze through them. Okay. I think I
23 got the gist of it.
24 Q. And to the best of your knowledge and
25 belief now that you've read a significant number of

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1 those e-mails that went back and forth between myself

2 and Kelly, Peter Layman and the police chief, what is
3 the overall gist of that -- of those e-mails? What do
4 you think?
5 MR. GOUDSOUZIAN: Pardon me. Before
6 you -- before you answer that question. I just want
7 to clarify for the record that -- I'm sorry, look at
8 the number, Exhibit 13 as indicated by you, Ms.
9 Mezzacappa, is a compilation of various e-mails that
10 you have cut and pasted and that you have compiled to
11 produce as one exhibit before Mr. Dees, is that right?
12 MS. MEZZACAPPA: Correct.
13 MR. GOUDSOUZIAN: Okay. Then you can
14 answer it the best you can answer it.
15 A. What was the question? What -- my gist of
16 it?
17 Q. Like what I'll -- were significant hurdles
18 being put in my place to collect Right-To-Know
19 records?
20 MR. GOUDSOUZIAN: That's a separate
21 question. That -- you can answer that to the best --
22 Q. Based upon what he's read, based upon what
23 you've read in Exhibit 13, can you testify that it was
24 very obvious West Easton Borough was obstructing
25 access to public records by using the Right-To-Know

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1 Law?
2 MR. GOUDSOUZIAN: That's an
3 objection. You're asking him to draw a legal
4 conclusion. You're asking him to assume that
5 everything in these documents are accurate. You're
6 assuming that he knew what was happening during those
7 time periods. You're assume that he had the context
8 of these e-mails. But you can answer if you can, but,
9 I mean -- and he wasn't a member at that point.
10 A. Yeah, I wasn't a member of Council. My
11 personal -- my personal belief is Right-To-Know should
12 not be so difficult. But I am aware that during this
13 time there was some altercations between you and Ms.
14 Gross at Borough Hall that resulted in the requirement
15 of police presence while you came to the Council.
16 There does seem to be some problems in arranging the
17 times that -- that you could be down there to inspect
18 records, because the times offered weren't good for
19 you.
20 Q. Can I cut you off just for a second?
21 A. Sure.
22 Q. Was it obvious from the e-mails that you
23 read that I habitually asked to have these
24 appointments in the morning because my afternoons were
25 busy with work, and they were habitually never

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1 schedule -- allowing me to inspect the records in the

2 morning, and that was the bulk of the e-mails, that
3 was the bulk of the e-mail correspondence?
4 A. I don't know if it was the bulk. There was
5 a few that, like I said, you couldn't agree on a time
6 you wanted. I think you wanted mornings?
7 Q. Correct.
8 A. And she wanted afternoons.
9 Q. Did I explain a number of times in the
10 e-mails, to the best of your knowledge, that
11 afternoons didn't work out for me due to my work
12 requirements?
13 A. Yeah, I believe you made that statement.
14 Q. Okay. Are you aware of yet another
15 Right-To-Know case, not the subject of today, but
16 another battle that went to the OOR that was decided
17 in my favor that said, agency records must be
18 available during regular business hours? Were you
19 aware of that battle that I won?
20 A. I'm not aware of yours --
21 Q. Okay.
22 A. -- specifically, but I would think I was
23 aware of that in general.
24 Q. Okay. And are you aware that West Easton
25 did not appeal that?

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1 A. No, I'm not aware.

2 Q. Okay. And are you aware that they just
3 decided to discard that --
4 A. No.
5 Q. -- by what was in the e-mail?
6 A. Wasn't aware of that.
7 Q. Okay. Does it appear to you that they were
8 making the records available during normal business
9 hours, or were they more or less jerking me around?
10 MR. GOUDSOUZIAN: Objection. How can
11 he answer that?
12 Q. Okay. Last question on these. Were they
13 making it more difficult than it had to be?
15 would he know? He wasn't there.
16 Q. Let me have the exhibit back. Are you --
17 I'm going to ask you to read one in particular. Okay.
18 There's one here that is dated March 10, 2012, from
19 myself to Peter Layman, Kelly Gross, Borough clerk and
20 Larry Otter. Do you need to see this e-mail?
21 A. Oh, yeah.
22 Q. Okay.
23 A. If you're going to ask me a question about
24 it.
25 Q. Okay. This e-mail right here that says, I

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1 really don't want --

2 A. I really don't --
3 Q. -- go ahead and read that. Can you read it
4 out loud, please?
5 A. Okay. This is from you to MLJ epix -- oh,
6 copy Kelly Gross, Borough clerk, Larry Otter. I
7 really don't want to appeal the appointment issue.
8 Can we please come to an agreement that even one
9 morning per week will be available for inspection?
10 West Easton can pick the day. Afternoons don't work
11 for me at this time. I'm locked into an on-call
12 schedule. The records for Monday were not part of the
13 30-day delay. Tricia.
14 Q. Is that unreasonable?
16 asking him to, again, provide a conclusion without
17 having any context.
18 Q. Is this -- is this an e-mail of somebody
19 who is having to jump through hurdles just to get --
20 just to be able to inspect public records, is that --
22 You're asking -- again, you're asking him to make
23 conclusions in the context that he's not familiar with
24 where he wasn't involved, he's not one of the parties,
25 he wasn't having any discussions.

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1 Q. Do you agree that I'm complaining that they

2 -- that they're refusing to schedule appointments for
3 me at the times that I'm available?
4 A. I would agree that you're complaining.
5 Q. Okay. How about this e-mail, also to Peter
6 Layman, Kelly Gross, Larry Otter. This one on March
7 22nd, 2012. Is this, again, the same issue of not
8 being able to get appointments scheduled when I'm
9 available?
10 A. This is you, yes, but you're -- you're
11 claiming that you can't get appointments during --
12 Q. Okay.
13 A. Right.
14 Q. Okay. Also, in this same exhibit, this one
15 is dated March 26, 2012, from myself to Kelly Gross,
16 Peter Layman and Larry Otter. Can you read this one
17 out loud? I put a star next to it.
18 A. You both have sunk to an all-time low.
19 Photographs of my car doesn't mean I'm here, doesn't
20 mean that I am not working from my house, and doesn't
21 mean that I walked or carpooled with a coworker to a
22 job. Wow, did you photograph the inside of the car,
23 too?
24 Q. What do you make of that e-mail?
25 MR. GOUDSOUZIAN: You can answer to

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1 the best you can. I mean, to the extent you know any
2 of it, the context or anything else.
3 A. That somebody took a photo of your car and
4 you didn't like it.
5 Q. Correct. Is that -- is that going to the
6 extreme over appointments and e-mails and scheduling
7 and mornings versus afternoons and everything that
8 you've read about, is it going to an extreme then for
9 a Borough to go and actually photograph somebody's
10 car, as like -- as if that is some kind of a reason
11 that appointments can only be scheduled at a certain
12 time? Is that -- do you understand my question?
13 MR. GOUDSOUZIAN: I'm objecting.
15 MR. GOUDSOUZIAN: It's a compound
16 question. You keep asking to put himself in a context
17 where he has no bearing. He's not there. He wasn't
18 there. And you show him an isolated line from an
19 e-mail that you have sent to someone.
20 Q. Okay. How would you feel as a person
21 taxpayer if a Borough was refusing to accommodate
22 appointment requests by purposely photographing your
23 car and scheduling appointments for you when you had
24 work duty?
25 MR. GOUDSOUZIAN: Objection, you're

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1 asking him a hypothetical question. You're asking him

2 to put himself in the shoes of somebody else.
3 Q. Is it appropriate for a Borough entity to
4 photograph anyone's car without some type of order
5 from police or a district attorney?
7 to the best you can. You can answer that one if you
8 know.
9 A. Sure.
10 Q. When is it appropriate for a Borough
11 official to photograph a residence car?
12 A. If they're illegally parked, if they're
13 parked on the lawn, they might want evidence of
14 something.
15 Q. Okay. But how about to go around and
16 photograph someone as they're parked, such as myself,
17 for the heck of it, just for the heck of it to --
18 A. Well, legally, and I'm not a lawyer, but I
19 would say legally, yeah, it's -- outside is public
20 domain. You can photograph a person. You can
21 photograph a house. There's no law against taking
22 photos.
23 Q. Do you feel that this -- that this is
24 proper then, that Kelly Gross photographing my car to
25 try to prove that --

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1 A. Well, that's what you're telling me.

3 Q. -- that I was home?
5 Objection, again. Now, that's different because now
6 you're asking him in the context of a photograph,
7 which may or may not have taken place, in a discussion
8 which he wasn't involved in, and you're asking him
9 whether it's improper or not, and you're asking him to
10 speculate. He can't answer those things. It's an
11 improper question for, like, six different reasons.
12 Q. Okay. Let me try to back up. With all of
13 the records that you've read in this -- in this
14 21-page file, okay, is it a fact that Kelly Gross was
15 putting substantial hurdles in my place in regards to
16 the Right-To-Know Law?
18 How would he know?
19 Q. I've asked him to read the documents, and
20 I'm asking him to read if it is -- was it your
21 conclusion that there were hurdles, substantial
22 hurdles at every turn every time I tried to collect a
23 public record?
25 You keep asking him questions about a time period

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1 where he was not a party, where he has no personal

2 knowledge. You've shown him cut and paste of e-mails,
3 which he doesn't know if they're accurate or not, and
4 he doesn't know the context of them.
5 Q. He read them. Did you read them?
6 A. I read them.
7 Q. What was your understanding of them?
8 A. That you and Kelly were having a pissing
9 contest, that's my understanding. I think you guys
10 were butting heads for a long time.
11 Q. Do you feel that somebody who is -- who is
12 looking for public records should be put through
13 anything even close to this as what came across in
14 these e-mails?
16 it's the same thing, he doesn't have the context.
17 Q. I'm going to keep rephrasing it until I get
18 an answer, Steve. I have a pile of e-mails here that
19 show a back and forth of e-mails between the police,
20 between myself, between Kelly Gross and the solicitor
21 trying to schedule appointments to get records,
22 objecting to the fact that no one in Borough Hall will
23 help me because people in Borough Hall were being told
24 they were not allowed to help me, having to e-mail
25 appointment requests, not receiving any responses,

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1 being told that I can only schedule appointments when

2 it doesn't work out with my work schedule. Would you
3 -- would you agree that that is the context of what I
4 just described? Is that the context of all of these
5 e-mails from 2012?
7 You can ask him as many times as you like, but I will
8 continue to object. You keep --
9 MS. MEZZACAPPA: Then we're going to
10 be here all day.
11 MR. GOUDSOUZIAN: That's fine. And
12 we can --
13 MS. MEZZACAPPA: We -- then we'll be
14 here all day until I get it on record what -- what
15 these e-mails represented.
16 Q. Did they represent or not a stubborn
17 Borough who butted heads with the Right-To-Know Law,
18 and used the Right-To-Know Law as a weapon?
19 MR. GOUDSOUZIAN: And that's an
20 improper question, and he's not the witness -- I don't
21 know if there is a witness to answer this, but he is
22 not that witness. You can only ask him what this man
23 knows.
24 Q. I am asking him based upon what he read in
25 the e-mails. Is it -- is it your conclusion -- now, I

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1 have to remember what I just said. Is it your

2 conclusion that there were substantial and
3 unnecessary, continual hurdles that were being put in
4 front of me to get my hands on Right-To-Know records?
5 MR. GOUDSOUZIAN: And I'm going to
6 object again. And I will continue, and I will
7 instruct him not to answer a conclusionary statement
8 on a set of e-mails that you have compiled of which he
9 was not a party, that he did not become involved in,
10 that he has no firsthand knowledge of.
11 MS. MEZZACAPPA: I'm asking it based
12 upon what he's read.
13 MR. GOUDSOUZIAN: But that's --
14 Q. Based upon what the e-mails say. I'm not
15 asking for something he doesn't know about. I'm
16 asking for this document, which have about 25
17 different e-mails from 2012, and in each of the
18 e-mails there is one hurdle after another -- after a
19 problem and another problem with access. And I am
20 asking -- I'm asking you if that is reflected in these
21 e-mails that I had a problem with access to
22 documents --
23 MR. GOUDSOUZIAN: Again --
24 Q. -- related --
25 MR. GOUDSOUZIAN: -- same objection.

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1 He's already told -- you asked him to draw -- the one

2 proper question you asked him is what -- essentially
3 what do you see out of this and so on, which he
4 responded. You were in a piss -- he said, if I'm to
5 guess, you're in a pissing contest with West Easton at
6 this point.
7 Q. Okay. We'll leave it that. Would a person
8 normally be frustrated with this kind of activity?
9 Would a reasonable person be frustrated, a taxpayer --
11 But to move this forward, you can answer it if you
12 can. I'll preserve the objection.
13 MS. MEZZACAPPA: You're not letting
14 me build a record, Steve.
15 MR. GOUDSOUZIAN: You're not asking
16 proper questions.
17 MS. MEZZACAPPA: I am asking. You're
18 not -- you're stopping me from building a record, a
19 pattern of abuse, a pattern of taxpayer abuse.
20 Q. Do you feel that this establishes at least
21 somewhat in your information and belief a pattern of
22 taxpayer abuse with regard to the Right-To-Know Law?
23 MR. GOUDSOUZIAN: Same objection. He
24 can't answer that.
25 MS. MEZZACAPPA: Why can't he answer

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1 it?
2 MR. GOUDSOUZIAN: Same reasons as
3 before that I've stated on the record and I will state
4 again, you're asking him to provide an opinion over a
5 series of documents that he's never seen before, that
6 you have compiled, that he has no context of, that he
7 was not firsthand party of. You're essentially
8 showing him some documents which he does -- never
9 seen, that he doesn't know anything about and asking
10 him to draw conclusions on it. He's a fact witness.
11 He can only testify to what he knows.
12 Q. All right. Can I -- do I have to break it
13 down into, like, 100 different questions? Do these
14 look like e-mail exchanges?
15 A. Yes.
16 Q. Do these look like e-mails exchange -- do
17 they look like e-mails exchanges between myself, Kelly
18 Gross and the Borough clerk and its solicitor and the
19 police chief?
20 A. They look to be, yes.
21 Q. Are they discussing problems with getting
22 records from -- from Borough Hall?
23 A. Yes.
24 Q. Do they have -- discuss problems with
25 appointment times?

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1 A. Yes.
2 Q. Do they discuss problems and me complaining
3 of three police officers coming here riot ready while
4 I'm standing at the door? Was there a complaint about
5 that?
6 A. You made a complaint, yes.
7 Q. Did you read the e-mail where the police
8 chief responded?
10 Q. Okay. Would you like to read his response?
11 A. If you're going to ask me a question about
12 it, sure.
13 Q. The response is that we'll send as many as
14 we need because it's political, but I'll let you read
15 it.
16 A. Okay.
17 Q. Okay. So it even rose to the level of the
18 police -- the police chief e-mailing me and the police
19 sending -- sending troops when I'm knocking on the
20 door to get a Right-To-Know request?
22 a question?
23 MS. MEZZACAPPA: Yes, I am.
24 MR. GOUDSOUZIAN: What's your
25 question?

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1 Q. That even in this exhibit, of all of these

2 e-mails, that had all kinds of problems with me
3 getting records, that it even rose to the level of
4 significant police presence at Borough Hall?
5 MR. GOUDSOUZIAN: Okay. Same
6 objection. He doesn't know whether the police came or
7 didn't come.
8 Q. Well, based upon Carl Scalzo's answer --
9 e-mail, if you believe that to be genuine, are you
10 acknowledging that that -- it was regular and
11 recurring that I had police presence -- police coming
12 to West Easton Borough Hall because I was at the
13 door --
15 that --
16 Q. -- gathering records, seeking records,
17 asking for records.
19 any of that from that e-mail -- if you can answer that
20 question from that e-mail, go ahead and do it.
21 A. Per this e-mail, not -- not because of you
22 in particular. He mentions to protect you, our
23 officers and the citizens of the Borough from any
24 potential physical conflict.
25 Q. Okay. Okay.

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1 MR. GOUDSOUZIAN: Well, let him

2 finish his answer.
3 Q. Go ahead. Are you aware of any other
4 Borough --
5 MR. GOUDSOUZIAN: Wait, pardon me,
6 are you done with your answer?
7 A. Yes.
8 Q. Are you aware of any other Borough who does
9 this?
10 MR. GOUDSOUZIAN: Does what?
11 A. Am I aware that has police at the door? I
12 think --
13 Q. All right. Let -- let me rephrase --
14 A. -- I think Bethlehem has --
15 MR. GOUDSOUZIAN: Let him answer the
16 question.
17 A. Yeah, I think there's other Boroughs that
18 have police at the council meetings, too, and we don't
19 have any.
20 Q. No, that's not what I'm asking.
21 A. Oh, you were asking about police presence.
22 Q. When -- no. When police are called
23 habitually to Borough Hall for one person trying to
24 get their hands on Right-To-Know records, are you
25 aware of another Borough that does that to its

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1 citizens trying to get anything basic, any right to

2 minutes, a checklist, any -- any kind of routine
3 record where appointments had to be established and
4 then police had to be routinely called? Are you aware
5 of any other Borough that treated any other taxpayer
6 in that manner? It's just yes or no.
7 A. Well, actually, yes. This was 25 years ago
8 or 30 years ago in Watchung similar --
9 Q. Okay. Well --
11 question.
12 A. In Watchung, New Jersey. You asked me.
13 Similar instance. It was a political year, there was
14 a fight broke out in Borough Hall. And after that,
15 both parties who were involved in the fight had to
16 have a police escort when they went to Borough Hall.
17 Q. Okay. Do you believe it is a good use of
18 the police force, who was then the Easton Police
19 force, to be summoned down to Borough Hall every time
20 I was there?
21 A. At that time, yes.
22 Q. You do believe that?
23 A. I did then, yeah.
24 Q. Because -- why did you think that was a
25 proper use of -- let me back up.

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1 Are you aware that I was requesting

2 habitually minutes, checklists, bank statements and
3 other routine records be faxed or e-mailed to my home,
4 were you aware of that?
5 A. Back then?
6 Q. Or continually from maybe 2011 up to
7 present, that I was continually asking for records to
8 be e-mailed to avoid going down to Borough Hall and
9 facing the embarrassment of police, were you aware --
10 A. I had -- I had read one of your blogs that
11 mentioned that.
12 Q. Okay. Are you aware that also West Easton
13 habitually refused to use fax or e-mail to give me
14 documents?
15 A. I became aware of that only --
16 Q. Okay.
17 A. -- after the fact.
18 Q. So is it a correct statement that I was
19 trying to avoid going down to Borough Hall in person
20 to pick up records because the police had to be
21 called, and that I was habitually trying to encourage
22 them to fax and e-mail records to me?
23 A. Okay. You got -- you got multiple --
24 Q. Were you -- were you aware --
25 A. -- you got multiple questions in there.

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1 Q. Okay. Were you aware that because there

2 was a police presence required and requested by Kelly
3 Gross and her clerk, every single time I went to
4 Borough Hall, that I asked that the records that I was
5 requesting here and there be faxed or e-mailed, were
6 aware of that?
7 A. I wasn't aware of that was your reason
8 because of police presence, and that's the question
9 you asked. I wasn't aware of why you asked them to be
10 e-mailed.
11 Q. Well, weren't you --
12 A. I don't know why you asked --
13 MR. GOUDSOUZIAN: Let him finish --
14 please him let finish his answer.
15 A. I don't know why you asked them to be
16 e-mailed.
17 Q. You don't think that it would be
18 embarrassing to have to go to a Borough Hall and be
19 confronted with two, three, four and sometimes five
20 police officers?
21 MR. GOUDSOUZIAN: Objection,
22 speculation as to what he would be embarrassed by or
23 what you would be embarrassed by.
24 MS. MEZZACAPPA: Okay. Let me go
25 back. This is -- I'm going to continue with this

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1 until I get through. Okay. You're going to object,

2 I'm trying to present a record, Steve.
3 Q. I'm trying to get a record of how absurd is
4 it -- how absurd is it for a Borough to call a police
5 to respond with one, two, three, sometimes four and
6 even five police officers over open public records
7 requests when they can easily be faxed or e-mailed?
8 How absurd is that?
9 MR. GOUDSOUZIAN: Objection. That is
10 an objectionable question.
11 MS. MEZZACAPPA: Why is it
12 objectionable?
13 MR. GOUDSOUZIAN: It's objectionable
14 because, again, you're asking him to provide an
15 opinion in a context that he is not familiar with, in
16 a context where he was not there, where he does not
17 know the circumstances, where he doesn't have any of
18 the background as to what was happening at that
19 particular time.
20 MS. MEZZACAPPA: I disagree.
21 MR. GOUDSOUZIAN: And I think what
22 you're missing is, there's a difference between types
23 of witnesses. And this is a witness who has --
24 MS. MEZZACAPPA: Then I'll back up
25 and start again.

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2 Q. Are you aware that I -- I was begging West
3 Easton Borough to e-mail and fax my records?
4 A. No.
5 Q. You weren't aware of that?
6 A. Not that you were begging them, no.
7 Q. And were you aware that instead of faxing
8 and e-mailing records, they preferred and made me come
9 down there in person, and then called the police every
10 time I was there, were you aware of that?
11 A. I'm aware -- I'm aware that they required
12 police presence when you showed up at the door.
13 Q. Is this a good use of resources when
14 someone who they are afraid of, doesn't want to be
15 there, and wants to instead stay home and accept the
16 records via fax, is it a good use of resources to
17 instead force that person that they're afraid of into
18 their faces and then call the police when they get
19 there --
21 Q. -- is that a good use of resources?
22 MR. GOUDSOUZIAN: Now, you're asking
23 an objectionable question as to whether it's a good
24 use of resources where he does not have the context of
25 what was happening at that time.

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1 Q. Okay. I'll rephrase it. Does that make

2 any sense to you? Does it make any sense to you why a
3 Borough would refuse to use technology, and then force
4 a citizen that they claim to be afraid of, right down
5 into Borough Hall?
6 A. I don't know that you were being forced. I
7 don't know that you've been forced.
8 Q. Okay. Are you aware that I filed an appeal
9 with the Office of Open Records, and I'm going to
10 reintroduce this exhibit -- okay. This exhibit which
11 is Exhibit 4, you looked at it before, with the list
12 of final determinations?
13 A. Uh-huh.
14 Q. That I even appealed that -- okay. This
15 was decided 9/29/2014, 2014-1072 was the exact docket
16 number. I lost the appeal, Borough is not required to
17 provide the requested records by facsimile. Do you
18 acknowledge that there was an appeal there?
19 MR. GOUDSOUZIAN: Are you -- the
20 question is, you're acknowledging whether he knows of
21 an appeal?
22 Q. Are you acknowledging that I even was so
23 disturbed by them not using technology and
24 embarrassing me with the police, that I appealed the
25 issue to the Office of Open Records?

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1 MR. GOUDSOUZIAN: Again, you're

2 asking him what --
3 MS. MEZZACAPPA: I'm asking him if --
4 MR. GOUDSOUZIAN: Pardon me -- pardon
5 me for a minute. I always let you finish. I'd ask
6 that you give me the same courtesy. You've asked him
7 how you feel. Now, number one, how would he know what
8 you felt. Number two, you're asking him as to what a
9 -- what the appeal was about. You showed him a
10 document which he said he had not seen before, he can
11 read what the document says, but that's as far as he
12 knows with his knowledge.
14 Q. Okay. I'll ask it again. Does the
15 document indicate that there was an appeal taken
16 regarding faxing of documents?
17 A. Yes.
18 Q. And that I lost that presumably -- I know
19 you don't have the exact final determination, but it
20 does say Borough does not have to fax?
21 A. Says Borough is not required to e-mail the
22 minutes.
23 Q. Okay. Is that another one?
24 A. It's right there.
25 Q. Where?

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1 A. You sit down too long, you fall over.

2 Borough -- Borough is not required to e-mail the
3 minutes.
4 Q. Oh, that's another one even. Oh, okay.
5 Thank you for pointing it out.
6 A. I thought I was reading at the wrong one.
7 Q. There were two. There were two.
8 A. Which the Borough wasn't required to do
9 that for either one.
10 Q. Okay. So Borough is not required to
11 e-mail. So is it clear to you that I had an issue
12 with the Borough refusing to e-mail and fax documents?
14 whether he knew that you had an issue. He can tell
15 you what this document that you've presented to him
16 said. That's all --
17 Q. So did I file an appeal because West Easton
18 was refusing to either fax or e-mail the minutes?
19 A. Yes.
20 Q. Okay. Do you -- do you agree that if a
21 Borough is too frightened of a resident and has to use
22 police when they come, it is perhaps a better use of
23 resources to fax or e-mail those minutes?
24 MR. GOUDSOUZIAN: Objection. Same
25 objection. You're asking him questions he can't

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1 answer.
2 MS. MEZZACAPPA: I'm asking him a
3 question about what is a proper use of resources.
4 MR. GOUDSOUZIAN: Correct. And he's
5 a fact witness.
6 MS. MEZZACAPPA: Well, can't that be
7 a fact?
8 MR. GOUDSOUZIAN: No.
9 MS. MEZZACAPPA: Why not?
10 MR. GOUDSOUZIAN: It's an opinion.
11 You're asking him to draw a conclusion of which he
12 does not have knowledge.
14 Q. Is it a fact that it is -- it is a waste of
15 resources to utilize services of a police force to
16 intimidate someone at Borough Hall rather than just
17 fax or e-mail minutes?
18 MR. GOUDSOUZIAN: Again, same
19 objection. You're asking him the same thing. You
20 still keep asking him questions about whether it's a
21 good idea or a bad idea or what his opinion is or what
22 his conclusion is in the context where he was not
23 present.
24 Q. Okay. What --
25 A. Can I ask for a break?

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1 MR. GOUDSOUZIAN: Yeah. Sure.

2 MS. MEZZACAPPA: Why don't we just
3 break for lunch then. Can we break for lunch?
6 Q. Okay. We're back on the record, it's 1:05
7 p.m. on Thursday, August 18th. Let's pick up where we
8 left off with this packet of e-mails from 2012.
9 Do you agree that most of these
10 e-mails were from a time where you were not living in
11 West Easton Borough?
13 you can have him read the dates, but he can't testify
14 to the veracity, the truthfulness, the accuracy of any
15 of these things. But if you want to ask him are the
16 dates when he was not -- you know, if you want to ask
17 him do the dates that appear on this correspondence
18 coincide with before he was a Borough Council member,
19 you can do that.
20 Q. All right. Do you agree that each and
21 every one of these e-mails was from 2012?
22 A. I'll have to look at them again.
23 Q. Okay.
24 A. I really didn't pay attention to it.
25 Q. January, March -- and I'll let you look at

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1 it again. January, March, March 12, March 21, March

2 21, March 26, March 27, March 29th, March 31st, March
3 30th, 4/20 -- 4/2/12, April 1st, 2012. Would you like
4 to check the dates and see --
5 A. No, if you're reading -- and these are from
6 2012?
7 Q. Right.
8 A. The dates you read?
9 Q. Were these all exchanges between myself,
10 the Borough and the police chief and Kelly Gross prior
11 to when you moved into West Easton?
12 A. Yes.
13 Q. Would you agree then based upon the
14 information and your belief that my problems and
15 debacles with the Right-To-Know Law and the Borough
16 existed even before you moved here?
17 MR. GOUDSOUZIAN: Objection to the
18 question, but you can answer to the best you can.
19 A. Per the e-mails you have --
20 Q. That it --
21 A. -- there was a conflict, yes --
22 Q. Even before --
23 A. -- before I moved in.
24 Q. Okay. So would you agree that it's been
25 long-term and ongoing?

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1 A. If those are accurate, it's a subjective

2 term, but I -- it goes back apparently four years.
3 Q. Okay. Let's talk about the appropriateness
4 of the police presence at Borough Hall with me being
5 involuntarily forced to submit to doing things in
6 person. Let's get to --
7 MR. GOUDSOUZIAN: I'm going to
8 object. You can ask each question, but I'm just
9 telling you I'm going to object to each one when you
10 talk about the appropriateness of the police when he's
11 not there, when he's not a Borough Council member
12 where he has no personal knowledge. You can't ask him
13 those questions.
14 Q. All right. Do you understand, though, from
15 this document, Exhibit 13, that the Borough felt it
16 was appropriate to bring police with every instance of
17 me coming to Borough Hall?
18 MR. GOUDSOUZIAN: Objection, you're
19 asking him now whether -- whether it was appropriate
20 for the Borough when he was not a Council member.
21 Q. How about forget -- why don't we just leave
22 out the word appropriate. That the Borough did, in
23 fact, summon the police time after time, instant after
24 instant of me being at Borough Hall trying to get
25 Right-To-Know records, that they did --

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1 MR. GOUDSOUZIAN: Ms. Mezzacappa, I'm

2 just --
3 Q. -- that they did or they didn't? It's a
4 yes or no question.
5 MR. GOUDSOUZIAN: Is your question to
6 him, and if it is -- this might help. If your
7 question to him, does he know, does he have firsthand
8 knowledge whether the police were summoned, he can
9 tell you that with his own eyes. If that's the
10 question, that I will not object, I just don't know
11 what you're asking him.
12 Q. Well, then that's the question.
13 A. Am I aware they were summoned when you
14 showed up? Yes.
15 Q. Habitually?
16 A. Oh, I don't know habitually, but I'm aware
17 of occasions where they were there, yes.
18 Q. Okay. Why aren't there police here today?
20 one to the best you can.
21 A. I don't feel I need police around you.
22 Q. All right. So is it correct to say that
23 you don't feel in fear for your safety having to sit
24 in a room with me and converse in a deposition, that
25 you feel comfortable without having the police present

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1 today?
2 A. In a deposition with other people here, I
3 feel comfortable.
4 Q. Okay. Maybe we can move on to something
5 else now.
6 Are you aware that I was banned from
7 Borough Hall from 2012 until recently?
8 A. No.
9 Q. You --
10 A. Banned, no.
11 Q. Banned meaning I -- I was not allowed in or
12 about Borough Hall without police escorts, that's what
13 I mean by banned. Are you aware?
14 A. Yes.
15 Q. You are aware?
16 A. Without escort, yes.
17 Q. Okay. Is it reasonable that I would be
18 frustrated with that treatment?
19 MR. GOUDSOUZIAN: Objection. Now
20 you're asking him whether you would -- it's reasonable
21 whether you would be frustrated.
22 Q. Is it reasonable that any taxpayer should
23 be subjected to that type of treatment?
25 You're asking him to put himself in the mind of

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1 somebody else.
2 Q. As a current sitting Council member, would
3 you enforce a policy upon anybody who happened to make
4 Right-To-Know requests that police presence is
5 mandatory for that one particular person?
6 A. If there was no --
7 Q. That blanket police protection is
8 constantly needed for one specific person, would you
9 support that policy as a sitting Council member?
10 MR. GOUDSOUZIAN: Are you asking as a
11 general rule or specifics?
12 Q. As a general rule.
13 A. If there was no prior history of violence,
14 no, I wouldn't -- I wouldn't see that there was police
15 presence there.
16 Q. Okay. Are you aware that I was never
17 charged with or accused of any violent crime related
18 to my incidences at Borough Hall?
19 A. I'm aware that you were convicted of
20 harassment, threatening to drown someone.
21 Q. Okay. Do you have a transcript of that
22 record?
23 A. No, I only have --
24 Q. Okay.
25 A. -- what was reported in the papers.

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1 Q. Right. Are you aware that I sued the

2 newspaper over that exact statement?
3 A. And I'm aware you lost.
4 Q. Are you aware of the outcome?
5 A. Yes, you lost.
6 Q. Are you aware of the agreement?
7 A. No.
8 Q. Okay. Did you look at the docket number
9 and the docket history of that case?
10 A. No.
11 Q. Okay. When I said banned, do you
12 understand that to mean I was not allowed in or around
13 Borough Hall without the police when I used the word
14 banned? I'm using the word banned again.
15 MR. GOUDSOUZIAN: What -- sorry --
16 Q. Do you --
17 MR. GOUDSOUZIAN: -- what are you
18 doing?
19 MS. MEZZACAPPA: Another question
20 about myself being banned.
21 MR. GOUDSOUZIAN: I thought his
22 testimony was you were not banned.
23 MS. MEZZACAPPA: No, that I was
24 banned, and he did answer, yes, that he understood
25 that I was not allowed around Borough Hall without the

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1 presence of police at all.

2 A. Yeah, I didn't answer that you were banned
3 totally. I was -- I answered that you were only
4 allowed with police presence.
5 Q. Well, what -- okay. What would be the
6 appropriate word if banned --
7 A. Escorted.
8 Q. Escorted. Okay. Who was the person most
9 responsible for that required escort?
10 A. I had -- I don't know who was most
11 responsible.
12 Q. Do you think it was Kelly Gross?
14 he knows. You're asking him, again, a time period
15 where he was not on Council. So if you have personal
16 knowledge, Mr. Dees, you should answer. But if you
17 don't, you don't.
18 A. Not personal knowledge, it would just be an
19 opinion.
20 Q. Are you aware upon information that you
21 have and belief that you have now that Kelly Gross was
22 the sole person at Borough Hall who ran everything
23 from beginning to end herself for a number of years,
24 and that she was the only decision maker in Borough
25 Hall at the time of her being Council president?

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1 A. That's a two-part question. I'd have to

2 answer differently for each part. Ask me the first
3 question without the and with.
4 Q. Was Kelly Gross the Borough Council
5 president from approximately 2010 to 2015?
6 A. Yes.
7 Q. Okay. In her role as Borough Council
8 president, did she assume all authority within Borough
9 Hall regarding all decisions related to the office, to
10 the best of your knowledge and belief?
11 A. She ran --
12 MR. GOUDSOUZIAN: Well, pardon me,
13 you can answer that the best that you can in your
14 own --
15 A. I'm aware that she acted as Borough manager
16 and secretary, I believe.
17 Q. Is it a reasonable conclusion that it was
18 she who was making sure I had police escorts at all
19 times?
20 MR. GOUDSOUZIAN: Was the question is
21 it a reasonable conclusion or just does he know?
22 Q. Is it a reasonable conclusion that the
23 reason why I had to have perpetual police escorts was
24 because of Kelly Gross?
25 MR. GOUDSOUZIAN: Objection unless --

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1 again, you're asking him to draw a conclusion now.

2 MS. MEZZACAPPA: We're going to be
3 here all day.
4 MR. GOUDSOUZIAN: That's fine.
5 Q. Do you believe that if Kelly Gross was not
6 part of West Easton Borough Council and Council
7 president during that time, that I would have been
8 remanded to constant and perpetual police escorts?
9 MR. GOUDSOUZIAN: Objection, how
10 would he know? He wasn't a member of Council. And
11 you're asking him what would happen if something else
12 didn't happen.
13 Q. Do you have knowledge of the way Kelly
14 Gross ran Borough Hall while she was Borough
15 president?
17 one.
18 A. In some -- some areas, yes, but not -- not
19 all of it.
20 Q. To the best of your knowledge and belief,
21 did she have full control over everything that
22 happened in the office?
23 A. To my belief, yes.
24 Q. That she dictated all policies, that she
25 controlled --

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1 A. No.
2 Q. -- all mail, that she controlled who
3 accessed to the computers, that she controlled what
4 information was given out?
5 A. From what I was told, that would be the
6 conjecture -- conjecture.
7 Q. Okay. Was -- are you aware that Kelly
8 Gross, while she was Borough Council president,
9 specifically directed the office staff, who was at the
10 time Molly and Jill Garcia and even Dane, that no one
11 was allowed to give any information to anybody
12 regarding the Right-To-Know Law? And what I mean by
13 that was she prohibited the other employees from
14 scheduling appointments, from giving information, from
15 supplying records that were due to me under various
16 determinations?
17 A. I don't have firsthand knowledge of that.
18 Q. You don't. Okay.
19 A. No, not firsthand.
20 Q. Okay. Who -- who -- prior to 2016, who was
21 the person most responsible in West Easton Borough for
22 complying with the Court Orders?
23 MR. GOUDSOUZIAN: If you know that.
24 You can answer that if you know.
25 A. I would say the Council president, Kelly

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1 Gross.
2 Q. Okay. Do you believe that she had any
3 intention or did comply with the Orders of the Court?
4 MR. GOUDSOUZIAN: Objection. Now,
5 you're asking him to put -- to give an opinion as to
6 what was in Kelly Gross' mind.
7 MS. MEZZACAPPA: Steve, I don't know
8 how else you want me to get this?
9 MR. GOUDSOUZIAN: You can't get it
10 in. You can't ask a witness what somebody else was
11 thinking.
12 Q. Okay. Do you have any evidence in your
13 possession or in the Borough's possession, meaning you
14 as a Council person, that Kelly Gross actually did
15 comply with these Court Orders?
16 A. I can only --
17 Q. Such as -- such as I'm just going to make
18 --
19 A. In my possession, no.
20 Q. How --
21 A. What the Borough has, I couldn't say.
22 Q. Okay. Do you have any -- is the Borough or
23 yourself as Council, do you have knowledge or evidence
24 from January of 2016 to present of the Borough
25 complying with the Court Orders?

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1 A. Again, I'm trying to remember, these are

2 the two litigations that we have here. Yeah, we
3 approached -- or we directed the solicitor to provide
4 you with all the information you requested that we had
5 available and that he could find, we could find.
6 Q. It is possible that due to the fact that
7 computers were stolen and thrown away and documents
8 and e-mails were wiped clean from the servers, that
9 it's possible some of those records are unable to be
10 produced at this current time?
12 the best that you can.
13 A. I'm aware of e-mails that were probably
14 wiped.
15 Q. Okay.
16 A. Specific document files, we don't know
17 because we don't know what was on there.
18 Q. Okay. But that there were a significant
19 number missing?
20 MR. GOUDSOUZIAN: Objection. I mean,
21 you can answer it to the extent you can, but --
22 A. I don't know if it was significant, but we
23 think some things were missing, e-mails specifically.
24 Q. Okay. Are you aware that I attempted to
25 settle this whole matter early on without any of this

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1 going on if West Easton Borough would have adopted the

2 following resolution that I provided to them? Were
3 you aware of this, of my settlement offer? All right.
4 Let's mark -- let's mark it in. Let's mark it in as
5 Exhibit -- I guess we're up to 14.
8 A. I wasn't aware that this was a settlement
9 offer. I became aware of this document through
10 another Council member that you had given it to, but
11 it was never mentioned this was a settlement document.
12 Q. Which Councilman showed it to you?
13 A. That was Dan DePaul.
14 Q. Okay. Was it discussed as a possible way
15 to resolve this issue?
17 Q. It was never discussed in any meeting?
19 to the extent that it should be with regard to any
20 non-privileged meeting, meaning any meeting that I was
21 with, I was present, we talked about it, that you
22 should not testify about. But if the question is to
23 give Ms. Mezzacappa the benefit of the doubt, if the
24 question is, it's a meeting with you and Mr. DePaul,
25 you can testify about that.

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1 A. No, not for settlement purposes.

2 Q. Is it -- was it something that West Easton
3 Borough was considering doing to end the entire
4 matter?
5 A. No, because we didn't know that this was --
6 this was part of this matter -- or I didn't know that
7 this was part of this matter.
8 Q. Okay. Did you realize that just a few
9 weeks ago, I think it was in the beginning of July,
10 that I resubmitted that resolution as a way to settle
11 the matter?
12 A. You submitted this to Council?
13 Q. That I submitted it to -- I believe through
14 e-mail to the Borough clerk?
15 A. I did not see this.
16 Q. And it went to Joan?
17 A. Through -- through them, through Joan or
18 anyone else that -- other than Dan when you first
19 presented it a couple months ago or something.
20 Q. Is it -- is it more prudent to continue
21 litigating this matter than it is to settle it with a
22 resolution such as that?
24 asking him now what's more prudent from the Borough's
25 standpoint.

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1 MS. MEZZACAPPA: Well, how about from

2 his own standpoint?
3 MR. GOUDSOUZIAN: And you're also
4 asking him -- although it's your questions that you're
5 opening the door for, you're asking him questions
6 about settlement negotiations, which is also improper.
7 Q. Okay. Let's have that back then. All
8 right.
9 Are you aware that no effort was made
10 to comply with the Court Orders prior to the filing of
11 this matter, and I filed it in early April?
12 A. No.
13 Q. What reason does West Easton have to be out
14 of compliance with the Court Orders?
15 MR. GOUDSOUZIAN: Objection, that
16 assumes they are out of compliance.
17 MS. MEZZACAPPA: Okay. Can I
18 rephrase it then?
19 MR. GOUDSOUZIAN: Sure.
20 Q. That if West Easton is out of compliance
21 with the Court Orders, what reason is there for them
22 to have to be continually out of compliance with the
23 Court Orders?
25 the best you can.

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1 A. I don't have an answer for that. I -- if

2 they're out of compliance what reasons would West
3 Easton have? My stance is I don't believe -- I didn't
4 believe we were out of compliance. I think we went
5 over this. I thought we had settled this other than
6 the documents.
7 Q. Does there exist a reason -- if the Borough
8 is still not in compliance with the Court Orders, does
9 there exist a reason why not?
10 A. If there were a reason, it's because you
11 didn't specifically ask what exact documents you
12 wanted. You never gave us a list, you gave us a bunch
13 of e-mails. We couldn't figure it out.
14 Q. So is it your testimony that West Easton
15 has made every effort possible to become compliant
16 with the Court Order?
17 A. I think we've tried to do that as soon as
18 we -- as soon as the new Council came in. I know -- I
19 can only speak for the new Council.
20 Q. You think or you know?
21 A. I can only speak for the new Council. I
22 think. I believe. I feel --
23 Q. Okay. You but don't know --
24 A. -- that we did -- that we did the best we
25 could to -- to mitigate your complaints and get you

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1 what you sought.

2 Q. So if -- at this time if West Easton, if
3 they are still out of compliance with the Court Order,
4 do you believe that West Easton should be coming into
5 compliance with the Court Order?
6 A. I believe that we should get you the
7 documents that --
8 Q. Okay.
9 A. -- you requested if they're available.
10 Q. Okay. Is it a fact that the prior
11 noncompliance with the Court Orders from the prior
12 Council was deliberate and willful?
14 would he know?
15 Q. Do you think that Kelly Gross embraced the
16 Right-To-Know Law?
18 You can't ask him what Kelly Gross -- what was in
19 Kelly Gross's head or why she did something or didn't
20 do something.
21 Q. Well, he has knowledge of Kelly Gross, and
22 he has knowledge of her obstructing the Right-To-Know
23 Law constantly, do you not?
24 A. No, I don't have her --
25 Q. Did Kelly gross --

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1 A. -- obstructing it, no.

2 Q. I'm sorry?
3 A. I don't have knowledge of her obstructing
4 the Right-To-Know Law.
5 Q. You don't?
6 A. No, I -- what I have knowledge --
7 Q. You did --
9 question.
10 A. What I have knowledge of is her using the
11 Right-To-Know Law as law was written. My belief, my
12 feeling, my opinion, as a Councilman is that certain
13 Right-To-Know requests can be omitted. If somebody
14 wants minutes, legally, you can request a
15 Right-To-Know request -- you can have them put in the
16 Right-To-Know request. Legally, you can make them
17 wait 30 days.
18 My feeling as a Councilman that wants
19 more transparency in government, is if the minutes are
20 printed up, they're available that day the person
21 walks in, give them a copy.
22 Q. Okay. I think you did testify before --
23 going back to the letter that I submitted, Exhibit 3,
24 in February of this year, that you -- it was your
25 testimony that you never physically saw this letter?

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1 A. Not that printed letter. I believe I -- I

2 saw a written -- handwritten letter, which I assumed
3 was from you with that -- much of what was on that
4 list.
5 Q. Do you know of anybody else who received a
6 copy of my letter addressed to Council?
7 A. No. The only one I saw was the one that
8 Joan had I believe, Joan the secretary. I believe it
9 was -- it was her that had -- that had the handwritten
10 copy, which is why later when I said you wrote it, it
11 could have been Joan that wrote it. I don't recognize
12 either one of your handwritings, but I assumed it was
13 from you.
14 Q. As of today has West Easton furnished all
15 of the records that were ordered to be -- that were
16 ordered to be released?
17 MR. GOUDSOUZIAN: Objection. You've
18 asked him this many times. He's answered it.
19 MS. MEZZACAPPA: I don't think I got
20 it.
21 MR. GOUDSOUZIAN: He's told you that
22 we've provided -- what we've had. But go ahead. If
23 you want to ask it, go ahead. I want to keep this
24 moving, so answer the best you can.
25 A. Well, my -- my knowledge is that we gave

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1 you all we had. And other than what you're still

2 looking for that I've said we still don't know exactly
3 what that is.
4 Q. Is it -- is it a fact that I've been
5 waiting for three years on one petition, and now an
6 entire year on the second petition to get the records?
7 Is that a fact that if you're correct that you gave me
8 all of the records at some point this year, okay, if
9 you are correct that you did give -- that West Easton
10 did give them all to me, which I dispute, but if that
11 is a fact, is it a fact that I have waited an entire
12 three-year period from the date of this one Order and
13 an entire one-year period from the date of the second
14 Order?
15 A. Okay. What you're asking me is if you just
16 got them, have you been waiting all this time to get
17 them?
18 Q. Right. Correct.
19 A. If you just got them. If you didn't get
20 them before, and you've been waiting since it was
21 supposed to get them, yes, it would be three years.
22 Q. Okay. Is that proper?
24 whether it's proper or not.
25 Q. Do you think that the Right-To-Know Law was

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1 crafted so that somebody with a Court Order would be

2 waiting three years to get the records?
3 MR. GOUDSOUZIAN: Objection. You
4 can't ask him why -- you can ask him, but I'm going to
5 object as to why he thinks the Right-To-Know Law was
6 created or not created.
7 Q. Well, going back to Section 1305 that was
8 an exhibit, do you recall the exhibit of the civil
9 penalty?
10 A. That was with the fines or something --
11 Q. Right. Do you think that it is appropriate
12 for somebody to wait an entire three years, given the
13 Section 1305 fines, to wait an entire three years past
14 the Court Order to get the records?
15 A. You're asking me for my opinion?
16 Q. Well, it's --
17 A. Personally I would have -- I would have
18 gotten you what we had as soon as possible. If you
19 said, hey, you owe me this, I would have made sure you
20 got it, what we had.
21 MS. MEZZACAPPA: Okay. Now, I'm
22 hoping you're not going to object and object and
23 object to this, which you probably will, but I'm going
24 to try to get it in.
25 Q. What more could I have done, given the

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1 circumstances with the police, with the harassment

2 charges --
3 A. I don't --
4 Q. -- what more could I have done --
5 A. I can't -- I can't -- I know where you're
6 going. I don't know what more you could have done,
7 I'm not you.
8 Q. Do you believe based upon what you know
9 today and in the past that I've -- that I've put forth
10 every effort I could physically and financially and
11 emotionally put forth to get the records?
13 would he know? He cannot testify as to what you could
14 have done, or what you should have done, or what you
15 did do, or whether it was the most that you could have
16 done.
17 Q. Okay. I'll rephrase it. Did I present
18 enough evidence today to establish a pattern that
19 there was constant head banging with the Right-To-Know
20 Law between me and former Council -- former Council
21 and that I did have to jump through every hurdle
22 possible to get records?
24 Q. Have you seen enough evidence presented
25 today to draw any conclusion about the willingness of

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1 former Council to comply with the Court Orders?

2 MR. GOUDSOUZIAN: Objection. You --
3 you've not presented -- well, objection. I'm
4 instructing him to not answer that question.
5 Q. Based upon the evidence that I have
6 presented you with today, and the questions asked and
7 answered, is it reasonable to conclude that I did
8 everything I could possibly do to get the Borough to
9 comply with the Court Orders prior to 2016?
11 MS. MEZZACAPPA: Steve, why are you
12 -- it's a factual question. It's yes or no.
13 MR. GOUDSOUZIAN: It is not, and I am
14 not going to continually educate you on the law. You
15 keep asking inappropriate questions. That is not an
16 appropriate question.
17 MS. MEZZACAPPA: That is there enough
18 evidence for him to conclude what I asked him? It's a
19 yes or no question.
20 MR. GOUDSOUZIAN: It is horribly
21 inappropriate.
22 MS. MEZZACAPPA: I don't understand
23 why --
24 MR. GOUDSOUZIAN: That's -- I don't
25 mean to be rude, that -- that's not my issue. It's

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1 you're asking him a series of questions which make --

2 which he cannot answer. You're asking him to draw
3 conclusions which are inappropriate.
5 Q. Let me -- let me try to word it a different
6 way. Based upon the evidence that you've seen today,
7 do you think that there was something else I could
8 have or should have done prior to 2016 to get West
9 Easton to cooperate?
11 MS. MEZZACAPPA: Steve, that's a fair
12 question.
13 MR. GOUDSOUZIAN: It is not.
14 MS. MEZZACAPPA: Why?
15 MR. GOUDSOUZIAN: Again, you are
16 asking him to figure out what you did, which he does
17 not know. Then you're asking him whether there could
18 have been more for him to do -- that you should have
19 done more, or you should have done less, all of
20 which --
21 MS. MEZZACAPPA: I'm just asking him
22 based upon what he's seen.
23 MR. GOUDSOUZIAN: And you keep
24 talking -- and you keep talking about you have
25 produced evidence, which is clearly a misunderstanding

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1 or a misstatement of what today is.

2 MS. MEZZACAPPA: Well, how many --
3 how many exhibits have I -- do you want me to word it,
4 like, exactly exhibit by exhibit by exhibit, and we'll
5 go -- we'll be sitting here until 8 o'clock tonight,
6 or can I say based upon the evidence that I presented
7 today, can you draw a conclusion that I did everything
8 I possibly could?
9 MR. GOUDSOUZIAN: He cannot draw a
10 conclusion. I'm going to object yet again.
11 THE WITNESS: And to save you time, I
12 would say I don't know.
14 Q. Well, then to the best of your knowledge,
15 what else could I have done?
17 How does he know what you did, what you could have
18 done, what you should have done? You're asking him to
19 put himself in your head.
20 Q. Okay. So if you're charged with summary
21 harassment crimes for trying to access records at
22 Borough Hall, if you were, and if you were subjected
23 to perpetual and repeated police escorts in and out of
24 your Borough Hall building when trying to get records
25 related to Right-To-Know requests, would -- would you

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1 continue to put yourself in the same situation that

2 got you criminally charged?
3 MR. GOUDSOUZIAN: Now you're asking
4 him a hypothetical question, and I'm going to object
5 to that. Plus, you're asking him to answer a question
6 which has no context, for that reason I'm also going
7 to object.
8 MS. MEZZACAPPA: Okay. I'll rephrase
9 it again.
10 Q. Based upon the evidence that I have
11 produced today, and that you've read today, and that
12 you've testified to today of your knowledge of police
13 presence and police charges all related to
14 Right-To-Know records, I'm asking you what else it is
15 that I could have done given the circumstances as they
16 exist?
18 MS. MEZZACAPPA: Well, I don't
19 understand why. I'm trying to get in -- Steve, what
20 else -- what else could -- we're sitting here today
21 because nobody has complied with the Orders of the
22 Court. That's why we're sitting here. And I have to
23 establish a factual record, even though the law
24 actually doesn't say that, have to jump through hoops.
25 It just -- it just states what disobedience is and

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1 what the penalty is.

2 Okay. But Judge Zito wants me to
3 establish a record to back up my allegations. And I
4 have produced now a number of exhibits, a number of
5 e-mails, a number of communications that describe
6 events from 2012 up until now of a litigant Borough
7 and a Borough that is constantly using the police --
8 THE WITNESS: Now she's testifying.
9 MS. MEZZACAPPA: -- to keep me -- to
10 keep me -- and I don't understand why it is that I
11 can't ask questions about what he is concluding from
12 everything that he's been asked today. I'm asking for
13 a conclusionary statement based upon what I've
14 presented to him today.
15 MR. GOUDSOUZIAN: And you cannot ask
16 for a conclusionary statement for the umpteenth time.
17 MS. MEZZACAPPA: Well, am I allowed
18 to ask for a factual statement?
19 MR. GOUDSOUZIAN: He can say what he
20 knows. He can testify. It's not my job to educate
21 you on the law, but I'm doing it anyway. He can
22 testify as to what he knows, that's it.
24 Q. What more could I have done?
25 MR. GOUDSOUZIAN: Objection. It's

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1 the same thing.

2 MS. MEZZACAPPA: Well, I'm going to
3 have to keep rephrasing it. I'm going to have to --
4 we're just going to have to continue until -- until I
5 get on record.
6 MR. GOUDSOUZIAN: You can ask --
7 Q. Do you -- do you believe --
8 MR. GOUDSOUZIAN: Pardon me, I'd like
9 to make this clear for the record. You can -- no one
10 is telling you to stop asking questions. This is your
11 deposition. But every single question that you ask
12 where you ask him, in essence, what could have been
13 done or what should I have been done, meaning Tricia
14 Mezzacappa should have done, is an inappropriate
15 question, and is going to be objected to.
16 Q. Okay. Have I established a pattern of
17 malfeasance with West Easton cooperating with the
18 Right-To-Know Law?
19 MR. GOUDSOUZIAN: Objection. Now
20 you're asking a legal conclusion.
21 Q. No, I'm asking him if -- whether or not I
22 have established today a pattern of malfeasance that
23 existed between myself and the Borough based on
24 everything that's been introduced and questioned
25 today. I'm asking --

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2 Q. -- him if I've -- if he believes that West
3 Easton -- do you believe that West Easton Borough
4 engaged in a pattern of malfeasance for a number of
5 years, namely, from 2012 up until the end of 2015?
6 MR. GOUDSOUZIAN: Now you're --
7 objection, again. Plus, this is a time where he's not
8 a Council member. Plus, you're asking him to draw a
9 legal conclusion.
10 MS. MEZZACAPPA: Okay. Well, then
11 we're going to have to go his own words which were in
12 his blogs. Okay.
13 Q. But before we go to that, does this letter
14 -- you claimed that you didn't see it. Does this
15 letter state -- you claim that you never saw it before
16 today, but is there a statement in this letter that
17 says West Easton was not in compliance with the
19 A. It looks to be one sentence in here where
20 you say, West Easton refused to pay me back,
21 disregarding the Commonwealth Court Order in its
22 entirety. And also refused to produce records that
23 they were directed to release.
24 Q. Okay. Is there another statement in there
25 they also blew off another Commonwealth Court Order

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1 that was decided earlier?

2 A. In your letter you say a third Commonwealth
3 Court Order involving the treasurer's report in my
4 favor from 2013, was also blown off --
5 Q. Okay.
6 A. -- but I never pursued action on that
7 matter.
8 Q. Okay. So do you agree that I put West
9 Easton -- at least for purposes of when you were on
10 present -- president on Council, that I put West
11 Easton Borough on notice when I gave them this letter?
12 A. On notice of what?
13 Q. That I was complaining that the Court --
14 that they were not in compliance with Court Orders?
15 A. You made a statement that --
16 Q. Right, I complained about it.
17 A. -- you believed they weren't compliant.
18 Q. Okay. Now, getting to the treasurer
19 report, are you aware that one of the petitions is the
20 Commonwealth Court Order that addressed that -- that
21 request? The treasurer report issue was -- are you --
22 do you understand that that was addressed in this
23 petition, which was Exhibit 1?
24 A. I am now.
25 Q. Okay.

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1 A. I thought you had received the treasurer's

2 reports.
3 Q. All right. Are you aware that I have
4 received certain treasurer reports, but not including
5 most of 2010 and 2011 that those --
6 A. Most.
7 Q. Well, I have another exhibit that says
8 where exactly -- hold on. Back to e-mail.
9 Do you agree that in Exhibit 6, in
10 this e-mail of June 6, 2016, I said in it, the missing
11 information would be the treasurer's reports from May
12 2010 through September 2011?
13 A. Yeah, I agree that --
14 Q. Okay.
15 A. -- in it you said that, yeah.
16 Q. Right. Now, did you attend a number of
17 Council meetings and record those meetings before you
18 were elected Council person?
19 A. Yes.
20 Q. All right. Do you remember one specific
21 meeting where everybody was fighting and screaming --
22 A. That was typical.
23 Q. Right. -- over treasurer reports not being
24 done?
25 A. Yeah, I do recall discussions about

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1 treasurer reports, yeah.

2 Q. All right. So do we also know for a fact
3 that there were no treasurer reports from at that
4 point in 2010 to 2011?
6 does -- is he aware -- or does he know whether or not
7 there were treasurer's reports for a time period, is
8 that what --
9 A. I'm 2010-2011 --
10 MR. GOUDSOUZIAN: I need clarify -- I
11 want to ask him --
12 MS. MEZZACAPPA: You're going to
13 object -- you're going to object to this.
14 Q. Okay. I -- I wrote that I didn't receive
15 the treasurer's reports from May 2010 to September
16 2011. To the best of your knowledge and belief, is
17 that because those treasurer reports were never
18 prepared?
19 A. No, I don't have any knowledge of those.
20 My best guess with -- they didn't exist.
21 Q. Correct. That's my best guess, too. So we
22 agree that for the purposes of this petition, do we --
23 and agree on record that I've collected everything
24 that I can on that petition, and that one alone, that
25 dealt with the treasurer reports?

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1 A. I don't know. I don't know if you've --

2 I'm not sure exactly everything that you're looking
3 for in that petition --
4 Q. Okay.
5 A. -- and I don't have --
6 Q. This petition --
7 A. -- knowledge of everything that's in
8 Borough Hall.
9 Q. Well, you're more than welcome to read it.
10 A. Actually, I don't have to read it --
11 Q. Okay.
12 A. -- because I can tell you I don't know
13 every document that's in Borough Hall. I don't know
14 what you've gotten or haven't gotten.
15 Q. Okay. But is it true that after probably
16 five years of having no treasurer's reports approved,
17 West Easton now has recently hired a treasurer and
18 there have been in 2016 at least four to five monthly
19 treasurer reports approved at Council meetings?
20 A. Per Council meeting or all total? All
21 total since we --
22 Q. Since -- yes.
23 A. -- since we appointed a treasurer, we're
24 getting what we feel are better treasurer reports.
25 Q. Okay. And do you -- do you agree that they

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1 were nonexistent in 2015, in 2014, in 2013 and 2012,

2 that there were no treasurer reports during those
3 years?
4 MR. GOUDSOUZIAN: If you know.
5 A. I can't -- I don't know.
6 Q. Okay. But you do remember certain Council
7 members arguing in a Council meeting that there hasn't
8 been a treasurer's report in some time?
9 A. I do remember a couple of occasions where
10 there was -- there was arguments about the type of
11 treasurer report, that it was more of a bank statement
12 than an actual treasurer's report that you're seeing
13 now in West Easton.
14 Q. And were you also at a meeting where they
15 had to argue over an appointment of who was going to
16 be the treasurer, whether it was going to be the
17 auditor or Carl Pearson?
18 A. I do remember discussion about two people
19 that were up, yeah.
20 Q. And was that because that West Easton did
21 not even have a treasurer with any regularity for a
22 number of years?
23 A. Going to the Council meetings at that time,
24 I wasn't on Council, I got the impression that there
25 was, yeah, no -- no appointed treasurer.

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1 Q. Okay. All right. I think I'm concluding

2 on the record speaking about the Court Orders. But I
3 would like to also ask you certain questions about
4 certain things you've written about me in the past and
5 in the present.
6 All right. Do you have a blog
7 entitled westeastonpa.com?
8 A. Yes.
9 Q. Do you own and maintain that blog even as a
10 Council member?
11 A. Yes.
12 Q. When did you start that blog?
13 A. I'm thinking 2013.
14 Q. Okay. Do you recall writing several
15 negative blogs about me since you've created your
16 blog?
17 A. Yes.
18 Q. About how many would you say you have
19 written about me prior to being a Councilman, about
20 maybe 10 to 20? Is that the correct number of
21 negative blogs that you've written about me?
22 A. I would say eight to ten.
23 Q. Negative blogs that you've written, only
24 eight to ten prior to being a Councilman?
25 A. Yeah. You got to understand what you see

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1 as negative --
2 Q. Okay.
3 A. -- you're not including --
5 question, please.
6 A. -- you're not including what might have
7 been said positive in what you consider negative.
8 Q. Do you remember writing any -- any blog
9 that was positive about me?
10 A. Yes.
11 Q. Which blog, can you recall?
12 A. Just a recent one where you came up with a
13 good -- I mean, the blog wasn't entitled Mezzacappa
14 anything. But I gave you kudos for a good suggestion
15 about parking during the wintertime. Your suggestion
16 was to clear off -- once Keystone was done, I gave you
17 kudos for that. I've given you -- I've given you a
18 few mentions when it was appropriate.
19 Q. Okay. Did you also threaten to retaliate
20 against my job as a constable because I have pending
21 litigation against the Borough?
22 A. Did I threaten to retaliate? No, I don't
23 recall that.
24 Q. No. Okay. Let's introduce this blog, and
25 I'm going to ask you to read into evidence exactly

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1 what you wrote. Okay. I have to find it, give me a

2 minute.
3 (Deposition Exhibit Number 15 was marked
4 for identification.)
5 Q. Okay. This blog entitled -- dated May
6 24th, 2016, Mezzacappa seeking Borough work as
7 constable. I'd like you to read the entire blog in
8 your own words -- did you write this?
9 A. Yeah, I'm sure I wrote it.
10 Q. Okay. I'd like you to just read the blog
11 into the evidence.
12 MR. GOUDSOUZIAN: You don't have to
13 read -- you can introduce --
14 A. It's going to be a long -- it's going to be
15 a long one --
17 MS. MEZZACAPPA: I forgot to
18 introduce -- I'm sorry --
19 MR. GOUDSOUZIAN: Just have it
20 marked. And if he admits that it's his, then it's
21 part of the record.
22 MS. MEZZACAPPA: Okay. Okay. But
23 since I've already questioned him about it, and he
24 denied retaliation, I'd like him to read his own words
25 into the record if you wouldn't mind.

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1 Q. Can you please read what you wrote?

2 MR. GOUDSOUZIAN: Let's do it this
3 way. Do you acknowledge -- Mr. Dees, do you
4 acknowledge Exhibit 15 is what you wrote? Take a look
5 first.
6 THE WITNESS: Yes. Yes.
7 MR. GOUDSOUZIAN: We're willing to
8 stipulate, he wrote it, it's part of the record.
9 MS. MEZZACAPPA: Well, yeah, but I
10 have to develop what was in it. I need him to read
11 into the record what it says.
12 MR. GOUDSOUZIAN: You do not, but --
13 you do not, but that's okay. I don't want to --
15 Q. How about one excerpt, I'll pick one?
16 A. Sure, because there's nothing retaliatory
17 in there.
18 Q. Okay. Did you write, at the May 23rd
19 Council meeting she offered Council to hear from an
20 individual from an organization of constables. The
21 unnamed person will inform West Easton Council of what
22 duties the constable can perform for the Borough.
23 Mezzacappa mentioned parking issue and car removal
24 during snow emergencies, that sounds more like code
25 enforcement duties, and I'm not inclined to approve

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1 Ms. Mezzacappa that type of authority over the

2 citizens of West Easton that might allow her the
3 ability to issue parking tickets or have vehicles
4 towed, especially so, considering West Easton is once
5 again defending itself against her in new litigation
6 she has brought against it.
7 A. Is that retaliation?
8 Q. Does that --
9 A. That doesn't fall under retaliation to me.
10 Q. That you are going to block any possible
11 future constable work because I have litigation --
12 A. That wasn't the reason was --
13 Q. -- especially so?
14 A. -- because of that. Especially so, yes.
15 Q. Okay.
16 A. But I wouldn't -- I wouldn't provide any
17 constable with that type of authority.
18 Q. Well, they actually don't have that type of
19 authority. I just got done with my two-week training,
20 so it's a dead issue.
21 A. Well, you're the one that brought it up.
22 Q. It's a dead issue now. I didn't have the
23 training then.
24 Are you aware --
25 MS. MEZZACAPPA: Let's mark this

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1 exhibit into evidence.

2 MR. GOUDSOUZIAN: We're on 16?
5 Q. Okay. Are you aware that I objected to you
6 being on the legal committee?
7 A. Yes.
8 Q. Okay. Are you aware of this letter dated
9 April 11th from me addressed to Council members?
10 A. Yes.
11 Q. Are there two blogs attached to it that you
12 authored?
13 A. Yes.
14 Q. Okay. Let me have the exhibit back. Are
15 you aware that I accused you in this letter of being
16 bigoted, that I am disturbed by ethnic biased when he
17 used the words Italian Mezzarella, that I was
18 concerned because I was compared to a barefoot
19 African-American woman sitting with her hand out
20 begging in the street, and that I was concerned
21 because you suggested that because I support the
22 Second Amendment I should be disqualified from
23 receiving in forma pauperis status? Are you aware
24 that that was what I complained about?
25 A. Yes, I'm aware of your mostly false

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1 allegations.
2 Q. Why -- why are they false? I'd like you
3 to --
4 A. I said mostly false.
5 Q. Okay. And are you also aware that in this
6 letter I took offense to a blog you wrote about pork
7 and scrambled eggs?
8 A. Yes.
9 Q. Okay. Because -- were you aware that my
10 pot-belly pig had recently died?
11 A. At that time, no.
12 Q. Were you aware that my house at that time
13 was also vandalized with eggs?
14 A. Yes.
15 Q. Okay. Are you sure you weren't aware that
16 my pot-belly pig had recently died?
17 MR. GOUDSOUZIAN: Objection, he
18 already answered that.
19 A. I don't recall being aware then. I became
20 aware afterwards, my recollection.
21 Q. Right. Okay. I'd like you to read into
22 evidence what you wrote in this blog, and I'd like you
23 to read the ingredients, the cooking directions, the
24 serving suggestions, and specifically words that used
25 pot-belly pig, do not use massage oil?

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1 A. Would you read it or are you asking me to

2 read it?
3 Q. I'm going to ask -- I'm going to ask you to
4 read it. Were you aware that I once had a massage
5 business?
6 A. No, I was aware that you were trying to
7 start a massage business.
8 Q. Okay. All right. Because at one time I
9 was a masseuse, is that correct?
10 Okay. I'd like you to read into
11 evidence what you wrote?
12 A. I just cooked up something for breakfast
13 that I had -- that I last had while stationed in Guam.
14 I can't be sure what reminded me of the dish, but
15 there's no denying it could have been tailor made for
16 West Easton.
17 While the Chamorro people of Guam
18 used goat cheese with the dish, I found the crazy
19 ingredients of this breakfast are better suited to a
20 cheese that is baked such as the Italian Mezzarella.
21 I'm pleased to share the recipe.
22 Ingredients, 6 ounces of cooked
23 pulled pork, Chamorro people use pot-bellied pigs,
24 just saying; six large eggs; salt and pepper; one
25 tablespoon of olive oil, do not use massage oil; half

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1 small red bell pepper cored and cut into quarter-inch

2 dice; half small green bell pepper cored and cut into
3 quarter-inch dice; two small onion cut into
4 quarter-inch dice; one cup Mezzarella cheese,
5 preferably shredded.
6 Cooking directions, in a large bowl
7 lightly beat the eggs, unless you have eggs already
8 scrambled on your house, if so, simply scrape off into
9 large bowl. Season with salt and pepper and set
10 aside.
11 In a large skillet over medium heat
12 warm the oil, add the pork, stir occasionally until
13 hot, about one minute. Transfer to a plate or bowl,
14 cover loosely to keep warm, set aside.
15 Return the skillet to medium heat.
16 Add the bell peppers and cook, stirring occasionally
17 for one minute, add the onion and cook, stirring
18 occasionally until vegetables are tender, about five
19 minutes. Add the eggs and cook -- add the eggs and
20 cook, stirring occasionally until the eggs are softly
21 set, about two minutes. Stir in about half the pork,
22 cook, stirring occasionally until the eggs are set,
23 about one minute. Scatter the cheese and remaining
24 pork on top in the manner a crazy person has scattered
25 thoughts and serve.

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1 Makes four servings, one for you, and

2 three for your paranormal animal friends. Serving
3 suggestions, this hearty scrambled can be multiplied
4 if you're cooking for a crowd or just trying to feed
5 all your multiple personalities.
6 If you are having your best and only
7 friend for dinner, use a small skillet and reduce the
8 prep portions accordingly. Place the uneaten portion
9 of your pig friend in fridge. To give it more of an
10 Italian spin, top it with chopped fresh basil. For a
11 less crazy Latin spin use cheddar or jack and serve
12 hot sauce and tortillas on the side.
13 You'll find this breakfast has plenty
14 of protein that will help those with histrionics get
15 started on the day filled with court appearances,
16 conspiracy theories and doses of needed medications.
17 Q. I'll take it back. Now, what was your
18 point in writing that blog?
19 A. Oh, it was probably in retaliation for
20 maybe at the time you calling up my employer and
21 accusing me of being a pedophile. It could have been
22 because you have a history of histrionics --
23 histrionics, and you have a problem with anybody that
24 tells you you're wrong about something.
25 Q. Okay. So we're acknowledging that you do

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1 retaliate --
2 A. No.
3 Q. -- as you just said in your own words, that
4 it was for retaliation for what you believed I did?
5 MR. GOUDSOUZIAN: Answer the
6 question. Go ahead.
7 Q. Okay. Did you just --
8 MR. GOUDSOUZIAN: Wait, are you
9 asking him a question --
10 MS. MEZZACAPPA: Yes --
11 MR. GOUDSOUZIAN: -- or are you
12 pulling back your question?
13 MS. MEZZACAPPA: -- I have a
14 question. That's a question.
15 MR. GOUDSOUZIAN: Then stop making
16 statements. It's one or the other.
17 MS. MEZZACAPPA: I'm asking a
18 question.
19 MR. GOUDSOUZIAN: Are you withdrawing
20 your earlier question then?
21 MS. MEZZACAPPA: No.
22 MR. GOUDSOUZIAN: Then let him answer
23 that question.
24 Q. Go ahead.
25 A. No, not so much retaliation as poking a

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1 little fun at you and trying to show you what it --

2 what it feels like to be harassed.
3 Q. Okay. My second question, did you bring
4 harassment charges against me in 2014?
5 A. Yes, I did.
6 Q. Was it heard before District Magistrate
7 Yetter?
8 A. Yes.
9 Q. Was I found not guilty?
10 A. Yes.
11 Q. Okay.
12 A. Because I filed the wrong charges against
13 you.
14 Q. Okay. If you were unhappy with the
15 outcome, could you have appealed that decision?
16 A. No.
17 Q. No?
18 A. I would -- I should have filed the right
19 charges against you.
20 Q. Okay. Then why didn't you?
21 A. Because I thought we would come to some
22 kind of agreement, truce. I thought you had had
23 enough and learned your lesson.
24 Q. Do you recall that after I was found not
25 guilty, I spoke to you in the court that day and said,

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1 why don't we come to a global agreement never to

2 mention each other's names on the internet again?
3 A. No, I don't recall that.
4 Q. You don't. Okay. Going back to this
5 letter, there was another blog that I complained about
6 in this letter, and that blog -- I didn't like that
7 blog because I felt it was bigoted because you
8 included a photo of a barefooted African-American
9 woman sitting barefoot in the street, begging in the
10 street and suggested that because I support the Second
11 Amendment I should be disqualified from receiving IFP
12 status.
13 Do you recall writing this blog,
14 Tricia Mezzacappa wants to appeal harassment
15 conviction on taxpayers' dime, dated March 31st, 2014?
16 A. Yes.
17 Q. Okay. I'd like you to read into evidence
18 what you wrote in that blog. It begins on the page --
19 the first page right there.
20 THE WITNESS: Am I required to read
21 this out loud? It's already in evidence because I'm
22 getting a little tired of reading.
23 MR. GOUDSOUZIAN: Well, do you want a
24 break?
25 THE WITNESS: Yeah.

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1 MR. GOUDSOUZIAN: All right.

2 MS. MEZZACAPPA: We can come back and
3 read it on the record when you're done. I'd like it
4 read into the record.
5 THE WITNESS: I guess, if you want me
6 to read it.
7 MR. GOUDSOUZIAN: Well, while we're
8 still on the record, again, these are documents that
9 if he admits to writing these things, we admit it's
10 part of the record, which will be part of the
11 deposition. It doesn't make any sense to have him
12 read it, other than to just waste time. If you want
13 to ask him excerpts --
14 MS. MEZZACAPPA: I prefer that he
15 read it into the record, so that he has a recollection
16 because I'm going to have some questions. I want him
17 reading it. It was written two years ago. I feel
18 it's necessary to have him read it into the record.
19 MR. GOUDSOUZIAN: Why don't you just
20 ask him, did he read it, does he remember it, and then
21 you can ask him, and then that way we can speed this
22 along.
23 MS. MEZZACAPPA: Okay. I'll
24 accommodate your request. I'm just going to ask about
25 certain excerpts, is that okay with you?

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1 MR. GOUDSOUZIAN: That's fine. That

2 would make a lot of sense.
4 MR. GOUDSOUZIAN: You still need a
5 break?
6 THE WITNESS: Yeah, because I need to
7 ask you something.
8 MR. GOUDSOUZIAN: Well, you can't ask
9 me anything of what's going on in the deposition.
10 THE WITNESS: Oh, no. Okay.
11 MS. MEZZACAPPA: Well, you can't
12 depose me.
13 THE WITNESS: She's making false
14 statements here --
15 MR. GOUDSOUZIAN: Wait. Wait. Stop.
16 Stop. You need a break?
17 THE WITNESS: Yeah.
18 MR. GOUDSOUZIAN: Okay. Five
19 minutes? Ten minutes?
20 THE WITNESS: Five.
23 Q. We were at Exhibit 16, and the blog that
24 was entitled Tricia Mezzacappa wants to appeal
25 harassment conviction on taxpayers' dime.

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1 A. You wanted me to read it when we left.

2 Q. Well, why don't I just read excerpts and --
3 A. That would be helpful.
4 Q. -- and you can either confirm or deny that
5 you wrote them. Can we do that?
6 A. I already -- I already conceded the fact
7 that I wrote that entire blog.
8 Q. Okay. You started the blog by saying, West
9 Easton resident, Tricia Mezzacappa, is appealing her
10 harassment conviction handed down by Judge Yetter and
11 upheld by Judge Dally.
12 She has every right to do so, but why
13 should all of us pay for it if we shouldn't have to.
14 That's what we could be doing if her petition to
15 proceed In Forma Pauperis she submitted on February
16 26th is granted without confirming the information.
17 Okay. Do you remember if that
18 application was granted?
19 A. I believe it was denied.
20 Q. You believe it was denied?
21 A. Well, the application, yeah --
22 Q. For the harassment action?
23 A. You didn't -- you didn't get --
25 question, please.

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1 A. -- you didn't get that status, in that

2 sense the application was denied I'm saying.
3 Q. Okay. I did get that status, just for the
4 record.
5 MR. GOUDSOUZIAN: You can't testify,
6 ma'am.
7 MS. MEZZACAPPA: Should I bring in --
8 schedule another deposition and bring in the exhibits
9 where it was approved, that Judge Dally signed it?
10 MR. GOUDSOUZIAN: You can do whatever
11 you want --
13 MR. GOUDSOUZIAN: -- but you can't
14 testify today.
17 Q. Okay. In this blog there is a photograph
18 of a minority elderly woman barefoot in the street
19 with her hand out?
20 A. The one you call black.
21 Q. Black, African-America, Latin, what -- be
22 it as it may, is it photograph of a minority woman
23 with her hand out and dressed poorly, barefoot in the
24 street begging?
25 A. The woman you referred to --

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1 Q. This one?
2 A. -- as African-American, the Indonesian
3 picture.
4 Q. The woman that I'm pointing to.
5 A. The woman -- the woman who's an Indonesian
6 that you referred to after --
7 Q. The --
8 A. That you -- that you referred to as
9 African-America, yes, that picture is in the blog.
10 Q. Okay. All right. Did you write,
11 Mezzacappa is telling the Court she is so poor that
12 she can't afford the filing fees and other costs
13 associated with her appeals, I call bullshit?
14 A. Yes.
15 Q. Do you realize that if I filed a false
16 application for in forma pauperis status that is
17 considered a crime?
18 A. No, I didn't realize that.
19 Q. You didn't. So then you didn't realize
20 that you were inadvertently accusing me of a crime?
21 A. No.
22 Q. Okay. Are you -- do you realize that when
23 you filed that application it is filed under penalties
24 of perjury subject to --
25 A. No, I am not.

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1 Q. Okay. Did you write, normally I wouldn't

2 argue with someone in financial straits, but
3 Mezzacappa's petition to the Court doesn't match up
4 with her financial disclosure report she submitted for
5 the position of NorCo GOP vice-chair in 2013?
6 A. Yes.
7 Q. Okay. So again, you're -- you're accusing
8 me of filing a false affidavit with the Court, is that
9 correct?
10 A. I think I said it doesn't match up with
11 your financial records, is that --
12 Q. Right, said that I lied.
13 MR. GOUDSOUZIAN: Ma'am, please let
14 him finish.
15 Q. So the insinuation is that I falsified the
16 application to the Court?
17 A. I'm saying the two pieces of information I
18 had didn't match.
19 Q. Okay. You went on to explain -- you wrote,
20 on her financial disclosure statement used for the
21 election, she listed the following as direct or
22 indirect sources of income, RN, Mezzacappa Massage,
23 Sands Casino, Estate of Joseph Mezzacappa. Okay.
24 So what -- what was your problem with
25 what I listed?

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1 A. It didn't match your petition.

2 Q. Did you realize that the statement of
3 financial interest included income from the prior
4 year?
5 A. No.
6 Q. Okay. If she is listing the estate of her
7 father as income, can we assume that she was left an
8 inheritance or possibly a trust fund? Since he passed
9 away a decade ago, one can speculate that listing his
10 estate as income in 2013 would make the income likely
11 a trust fund. Did you write that?
12 A. Yes.
13 Q. Did you ask me what --
14 A. No.
15 Q. -- what it was in my --
16 A. No.
17 Q. -- in the estate? You didn't ask?
18 A. Didn't ask.
19 Q. So you just wrote what -- what you thought?
20 A. I wrote it was speculation and an
21 assumption.
22 Q. Did you realize what the income was from
23 the Estate of Joseph Mezzacappa?
24 A. No.
25 Q. Do you recall maybe a blog that I posted

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1 explaining what that income was?

2 A. No.
3 Q. Okay. And then you wrote, the problem with
4 these two sources of income is that they were not
5 disclosed to the Court when she filed for fees to be
6 waived because she claims to be a pauper. Did you
7 write that?
8 A. Yes.
9 Q. So then again, you're insinuating I
10 falsified a Court document?
11 A. I'm insinuating -- I'm not insinuating
12 anything. I'm opinionating the fact that your two
13 financial statements didn't match up to the
14 information I had.
15 Q. Right. And again, did you realize that
16 they were on two separate reporting years?
17 A. No.
18 Q. Okay.
19 A. Again, no.
20 Q. Then you wrote somehow, though, with so
21 little income and money at her disposable she paid off
22 her home mortgage in February of this year and her
23 2008 vehicle that cost $17,500 is also paid for. Did
24 you write that?
25 A. Yes.

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1 Q. Well, what evidence did you have that I

2 paid off my mortgage and that my vehicle cost $17,500
3 and that it was paid for?
4 A. I believe you stated that your mortgage was
5 paid off.
6 Q. When did I state that?
7 A. It was in -- I believe it was in one of
8 Brady O'Hare's blogs.
9 Q. Oh --
10 A. And it was part of --
11 MR. GOUDSOUZIAN: Wait a minute. Let
12 him finish.
13 A. -- it was part of a record that you gave
14 Court.
15 Q. Okay. So then you believe everything that
16 Bernie O'Hare writes on his blog?
17 A. No, I believe what --
18 Q. Okay.
19 A. -- what makes sense to me.
20 Q. But do you have any evidence that I paid
21 off my home mortgage, and that my 2008 vehicle cost
22 $17,500, that was also paid for? Is it speculation or
23 do you have actual evidence of that?
24 A. I would call it speculation.
25 Q. Okay. Did you write, and let's not forget

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1 that new gun she boasts about and all that expensive
2 ammunition she uses when she pays the Heritage Guild
3 to practice. If she has money for those luxuries, she
4 has money to pay her own way. Did you write that?
5 A. Absolutely.
6 Q. Okay. So do you believe that somebody who
7 supports the Second Amendment and possesses a firearm
8 should be banned from in forma pauperis status?
9 A. Nothing has anything to do with Second
10 Amendment and what I wrote. I believe that somebody
11 has the money to go for shooting practice and buy a
12 brand new gun and all the ammunition that goes with
13 it, can pay her own Court cost.
14 Q. Okay. Did you have the records of the gun
15 I bought and when I bought it?
16 A. No, I had your statement of what you owned.
17 Q. What statement?
18 A. The ones you write about in your blog. Or
19 the one -- or the gun you walk around town with on
20 your hip.
21 Q. Okay. But you don't know when I bought the
22 gun?
23 A. I know you had that gun before I wrote
24 that.
25 Q. Do you have the records that show when I

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1 purchased the gun?

2 A. No, I don't.
3 Q. Okay. So then you can't state --
4 A. I only have my eyes that sees what you
5 wore.
6 Q. So today then you cannot --
7 MR. GOUDSOUZIAN: Although this is
8 the delightful for everybody else involved, one at a
9 time.
10 Q. So then you --
11 MR. GOUDSOUZIAN: And then, you know,
12 it's a deposition, and I understand that, but what
13 does this have to do with anything?
14 MS. MEZZACAPPA: Well, I'm
15 establishing a pattern of malcontent is what I'm
16 establishing. Let me -- can I finish?
17 MR. GOUDSOUZIAN: You can ask.
18 Q. And let's -- okay. Did you write, somebody
19 doesn't sound like a pauper and the Court needs to get
20 all the facts before they grant her the relief she
21 seeks?
22 A. Absolutely.
23 Q. Do you believe that the Judge did his due
24 diligence when he reviewed my petition?

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1 would he know what the Judge did or didn't do?

2 Q. Okay. Are you suggesting that a judge just
3 signed it without checking?
5 would he know?
6 Q. Okay. Update, April 1st, 2014, this
7 morning I woke up to find a message on my cell phone
8 left by Ms. Mezzacappa. I'm told that if I do not
9 remove this article that questions her submission for
10 in forma pauperis, she will sue me for libel. A
11 comment by her on her blog also states she has
12 provided a copy of this article to the state police.
13 Did you write that?
14 A. Yes.
15 Q. So was it clear to you that I was objecting
16 to what you were writing about me?
17 A. It was clear to me you were trying to
18 intimidate me.
19 Q. Okay. Did you just testify that you didn't
20 actually contact me for comment or have any evidence
21 to write what you wrote, but you just wrote --
22 A. No, I did not testify to that.
23 Q. Okay.
24 A. I testified evidence is what I see with my
25 eyes and what appears on your own blog that you had at

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1 the time, which is now taken down.

2 Q. Okay. Then did you write, should you, as a
3 taxpayer, wish to contact the Court and ask that her
4 requested status be reviewed more closely, you can
5 contact them by e-mail or phone. And you listed an
6 e-mail link to Court Administration, 669 Washington
7 Street, Easton, PA, 18042, (610) 559-6700.
8 A. Yes.
9 Q. Did you write that? Why did you write
10 that?
11 A. Well, for one thing it's freedom of speech,
12 both -- both -- and all these articles you're going to
13 bring up are freedom of speech issues, something that
14 you promote yourself. You're running for public
15 office at the time. You're a public -- you are out
16 there for the public to see. You need to be looked at
17 as closely as I do serving the public office. So I
18 have a right to write it. I use my best judgment and
19 what I knew to be true at the time about you, and the
20 people can judge for themselves. And I'm providing
21 public information and providing the court address and
22 phone number.
23 Q. Okay. So after you did that, are you aware
24 that, in fact, I did receive the status, it wasn't
25 revoked, and there was no problem with it, and I

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1 appealed it to Superior Court unsuccessfully, but

2 didn't pay the fee because I was granted IFP status?
3 Do you realize that to be true?
4 MR. GOUDSOUZIAN: If you know, you
5 can answer.
6 A. I don't know. That's what you're telling
7 me.
8 Q. Okay.
9 A. And I would also point out, at no point,
10 and there was an open invitation for you to -- which
11 you have done previously, put something on my blog if
12 you wish to rebut something. You could have done
13 that.
14 Q. Have you ever contacted me for comment
15 before you've written negative things about me?
16 A. Not to my knowledge.
17 Q. Okay.
18 A. But the invitation for you to respond was
19 always there.
20 Q. Is it still there?
21 A. Absolutely.
22 Q. Okay. Now, that we've addressed the second
23 blog, do you agree that I complained to Council about
24 the blog that we just went over, about the IFP status,
25 and the breakfast in West Easton pork and scrambled

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1 eggs, that's what I submitted to the Borough?

2 A. That's what you submitted to the Borough.
3 Q. Okay. And did you respond to that by
4 actually reposting the article that I complained
5 about, which was the Mezzacappa wants to appeal
6 harassment conviction on taxpayer dime?
7 A. No.
8 Q. You didn't repost it?
9 A. No, I didn't repost it.
10 Q. Okay. Let me refresh your memory with
11 another exhibit. Okay. You didn't republish the link
12 to that article. On May 24th, 2016, you published,
13 West Easton Council Meeting 5/23/16. I'd like to mark
14 this into evidence.
17 Q. Do you recognize this as something that you
18 published on May 24th, 2016?
19 A. Yes.
20 Q. Okay. Can I have it back, please. And did
21 you write, finally resident Tricia Mezzacappa tries to
22 make hay. Offended by an image I used for myself,
23 Alfred Newman, the cartoon, of What Me Worry fame and
24 often used for self-depreciation?
25 A. Deprivation.

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1 Q. Okay. President Obama referenced his own

2 ears to those of Newman, says it puts Borough in bad
3 light. This is from the woman who wrote a letter to
4 the editor of The Express Times supporting Ross
5 Township murderer Rockne Newell. Offended by
6 westeastonpa.com articles about her, throws out words
7 racist and bigoted. This is from the woman who
8 reportedly used the N word toward a neighbor during a
9 dispute over a honking taxi. She also misidentifies
10 the beggar woman pictured in the article, and this is
11 a link, as black.
12 Do you agree that then by including
13 the link to the article you have republished it?
14 A. No. There's a difference between republish
15 and reposting and providing --
16 Q. Okay.
17 A. -- a link to something that's already
18 existing.
19 Q. Okay. But is it correct that after I
20 complained about that article, you came back on your
21 blog on May 24th of 2016, and put a link to that
22 article?
23 A. Yes.
24 Q. Okay. Let's go back to the harassment
25 complaint that you filed against me in 2013. As I

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1 understood, you did -- I was found not guilty and you

2 did not appeal it, is that correct?
3 A. That's correct.
4 Q. Okay. So for all practical purposes then,
5 do you agree that the decision of the Judge stood?
6 A. Yes.
7 Q. Okay. On August 17th, 2014, did you write
8 an article, Express Times editorial addresses
9 transparency problems in West Easton?
10 And I'll mark this in as Exhibit 18.
13 Q. Okay. Did you write this article?
14 A. I did.
15 Q. Okay. Did you write as most -- did you
16 write this? As most are aware -- were these your own
17 words that you wrote? It'll be yes or no. As most
18 are aware, my disdain for Mezzacappa is no secret.
19 Her accusations about me and others has no boundaries.
20 They are made for no legitimate purpose and without a
21 foundation of fact as a means of harassment.
22 Did you write this after I was found
23 not guilty of harassment?
24 A. I didn't look at the date. I couldn't tell
25 you.

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1 Q. Okay. I'll refresh your memory. What date

2 approximately was I found not guilty of harassment
3 when you filed the charge against me?
4 A. Remind me. I said I don't remember the
5 date.
6 Q. Was it in mid-2013 in the election season?
7 A. It could have been.
8 Q. Okay. But it was definitely in 2013?
9 A. I can't even say -- yeah, I would guess --
10 Q. Okay.
11 A. -- either late 2012 or 2013.
12 Q. Okay. And this was published on August
13 17th, 2014, correct?
14 A. Okay.
15 Q. So after I was found not guilty, you are
16 coming on the blog and accusing me of harassment by
17 your own words, is that correct?
18 A. Not criminal harassment, harassment, yeah.
19 There's a difference between --
20 Q. Well, isn't it --
21 A. -- harassment and criminal harassment.
22 Q. What's the difference?
23 A. Criminal harassment is when you go in front
24 of a Judge and have to defend yourself because the DA
25 found credence to it. Regular harassment is just

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1 calling somebody's employer and telling them they're a

2 pedophile.
3 Q. Wasn't that what you included in your -- in
4 your harassment complaint against me? Isn't that what
5 you went to court for, that I called you a pedophile
6 and called your employer? Didn't you sue me for
7 harassment based upon that?
8 A. That was some of it.
9 Q. Okay. But was I found not guilty of that?
10 A. We already -- I already said, yes.
11 Q. Okay. So is it a pattern --
12 A. Because the wrong charges were filed
13 against you.
14 Q. Okay. So is it a pattern of yours that
15 when you disagree with a Judge, you go about your own
16 business and accuse people of crimes anyway?
17 MR. GOUDSOUZIAN: Objection. But you
18 can answer it the best you can.
19 A. I didn't -- I accused you of harassing
20 people, not criminal harassment. Try to get the two
21 straight.
22 Q. Okay. But according to your own words in
23 this blog, you described your disdain for me because
24 you've said I've harassed you?
25 A. Yes.

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1 Q. And you've already admitted that it was

2 vetted by a Court and found not guilty?
3 A. Criminal harassment you were found not
4 guilty of.
5 Q. Are you aware that I was not charged with a
6 misdemeanor harassment by you?
7 MR. GOUDSOUZIAN: You can answer if
8 you can answer it.
9 A. Yes.
10 MR. GOUDSOUZIAN: Hopefully we'll
11 move on at some point.
12 Q. Did you charge me a summary harassment?
13 A. I charged you with criminal harassment.
14 Q. So you charged me with a misdemeanor?
15 A. It would turn out -- yeah, criminal
16 harassment in that level is a misdemeanor.
17 MR. GOUDSOUZIAN: Misdemeanor or
18 summary, just to get --
19 A. Summary. Sorry.
20 Q. A summary?
21 A. Summary.
22 Q. So what you're saying is in this blog that
23 I have harassed you, even after the Court determined I
24 didn't harass you?
25 A. Sure, you did it a month ago.

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1 Q. Okay. So in your -- to the best of your

2 knowledge and belief, it's okay for you to accuse me
3 of a crime after I was vindicated of the crime?
4 MR. GOUDSOUZIAN: Objection, asked
5 and answered, but you can answer it the best you can.
6 A. Different levels of harassment, Tricia.
7 Q. Okay.
8 A. Criminal harassment and regular harassment.
9 When you come to my front yard or my front drive of
10 the street, and when I'm working on a car, and have
11 somebody lean out your car window and tell me I'm
12 doing something against the law and going to call the
13 cops, and then you tell me in your own words, look at
14 me and say, you're fucked, that's harassment. May not
15 be criminal as it turns out, but that's still
16 harassment.
17 Q. Okay. I'm talking about what you wrote on
18 August 17th, 2014 --
19 A. I'm telling you -- trying to explain to you
20 the --
21 Q. -- two years ago --
22 A. -- differences -- I'm trying to explain to
23 the differences -- differences in harassment. I
24 didn't say criminal harassment in that -- in that
25 blog, I just said harassment. Simple harassment.

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1 Q. Okay.
2 A. Calling somebody on the phone and yelling
3 at them.
4 Q. Okay. Two years -- let me go back to this
5 because I need this on. Two years ago, on August
6 17th, 2014, two years to the day, you came on your
7 blog and accused me of harassing you, correct?
8 A. Yes. Well, read it -- read it, please. I
9 don't know -- think it was just me.
10 Q. As most are -- as most are aware -- I'm
11 quoting for the record what he wrote. As most are
12 aware, my disdain for Mezzacappa is no secret. Her
13 accusations about me and others has no boundaries.
14 They are made for no legitimate purpose and without a
15 foundation of fact as a means of harassment. She has
16 made the most vial of charges and innuendo, even going
17 so far as to call my employer in attempt to have me
18 fired.
19 Wasn't that the basis of your
20 harassment claim against me in 2013?
21 A. That was only part of it.
22 Q. It's yes or no.
23 A. It can't be answered yes or no because it's
24 only part of it. And that harassment talks about
25 simple harassment, Tricia, not criminal harassment.

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1 So nothing continued on after the Judge found you

2 innocent. I was ready to walk away. You're the one
3 that continued it.
4 Q. And you've said on record that you have
5 continually written negative blogs about me --
6 A. Not continually, I didn't say that.
7 Q. Did you quantify it as between eight and
8 ten or ten and twenty?
9 A. I think I said eight to ten.
10 Q. Okay. Based --
11 MS. MEZZACAPPA: Oh, and one more.
12 This will be the last blog that's introduced, and the
13 last piece of evidence, I think, or maybe one more.
14 Let's introduce Exhibit 19.
17 Q. Okay. This blog from you was published on
18 June 9th, 2014, called The Sociopath Next Door. Did
19 you write that blog?
20 A. Yes, this is about the book, The Sociopath
21 Next Door.
22 Q. Was that meant to infer that I am a
23 sociopath?
24 A. If -- I don't know, Trish, if you think it
25 infers you then, I'm not going -- I'm not going to go

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1 there.
2 Q. Does it or doesn't it infer that it's me?
3 A. Not particularly.
4 Q. Not particularly or not at all?
5 A. Oh, I couldn't say not at all. I don't --
6 I can't get in your head.
7 Q. Well, I'm not asking you to. I'm asking
8 you if you if you were referring, not mentioning my
9 name?
10 A. It's just a book review.
11 Q. It's just a book review?
12 A. Yeah.
13 Q. Did you incorporate some of your own facts
14 and opinions in this?
15 A. Probably.
16 Q. Okay. Let's read what they were.
17 A. Sure.
18 Q. Did you write, dealing with people during
19 my life, I've run into some crazy individuals here and
20 there. Here, at this point in time, is West Easton.
21 Did you write that?
22 A. I said I wrote it.
23 Q. Okay. Do I live in West Easton?
24 A. Yeah.
25 Q. Okay. Is it reasonable to believe that

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1 maybe you meant that this article was about me, The
2 Sociopath Next Door?
3 A. From that, no.
4 Q. Okay.
5 MR. GOUDSOUZIAN: And objection as to
6 whether somebody else would find it reasonable.
7 Q. Okay. I'm not going to spend much time on
8 this, it speaks for itself.
9 Did you write in here, they feel more
10 emotion towards a pet than they do another human
11 being. They are often childless, never married, and
12 never had an intimate relationship that lasted more
13 than two years?
14 A. I think I quoted the book there.
15 Q. Okay. Is it reasonable that that could be
16 directed at me?
17 A. I don't know what's reasonable.
18 Q. Are you aware that I love pets, I'm
19 childless and never married?
20 A. I thought you were married.
21 Q. Okay. As you went on quoting the facts
22 about sociopaths and what causes sociopathy, did you
23 write here, sociopaths just seem to crop up, though
24 they occasionally have their uses, they can make
25 excellent soldiers in times of war. People who can

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1 kill on the battlefield without feeling guilt after

2 the fact are probably good to have on your side, not
3 so good if there is no war, but they still carry a gun
4 in public. Did you write that?
5 A. Yes.
6 Q. And you're still sure, absolutely certain
7 that this is not about me?
8 A. Wasn't intended to be about you.
9 Q. All right. It speaks for itself.
10 Now, based upon the blogs that were
11 introduced, and the testimony about your failed
12 harassment complaint, is it appropriate that you
13 continue to be in executive sessions and be allowed to
14 deliberate for matters concerning my litigation?
15 A. Oh, absolutely.
16 Q. Do you recall that I suggested perhaps you
17 recuse yourself from executive session?
18 A. I do recall that was a complaint of yours
19 that you wanted me to recuse myself.
20 Q. Okay. Did you ever recuse yourself?
21 A. No.
22 Q. No. So is it your testimony -- to be fair,
23 is it your testimony that given all of the blogs and
24 things that you've said and done, that you are
25 absolutely, unequivocally unbiased?

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1 A. When it comes to you and decisions I make

2 on Council, absolutely unbiased.
3 Q. Sure. Okay.
4 A. I'm sorry, are you answering the question
5 for me or are --
6 Q. No, I'm listening to your --
7 A. Oh, okay.
8 Q. That you -- that it is your testimony that
9 despite everything --
10 MR. GOUDSOUZIAN: Excuse me, for a
11 minute.
12 (Discussion held off the record.)
13 Q. That despite everything that was introduced
14 in regard to what you've written about me, and in
15 regard to the harassment complaint, and in regard to
16 you stating in your own words, it's no secret that I
17 have a disdain towards Mezzacappa, yet you maintain
18 today and you are truthfully stating that, in fact,
19 you have no bias toward me?
20 A. When it comes to serving on Council,
21 Tricia, I have to put my personal differences with you
22 aside and decide on what's best for the town.
23 Right-To-Know requests, even if they come from you,
24 honored as much as my next-door neighbor who I like --
25 particularly like.

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1 I don't like you as a person, but

2 that doesn't mean I will make a decision against you.
3 Because of that, call it a bias against you, a dislike
4 for you. But when it comes to Council decisions,
5 because I serve you as a taxpayer, I can be fair to
6 you and I am fair to you when it comes to Council
7 decisions. We don't have to like each other
8 personally, but I would never abuse you in a position
9 of Council.
10 Q. And none of this constitutes abuse --
11 abusive conduct on your behalf toward me, none of this
12 that we just testified to?
13 A. I think -- I -- to be fair, probably the
14 worst thing I did was the little pork story with the
15 pigs. I didn't realize your pig had died -- or I
16 don't recall it being dead at the time I wrote it.
17 I'm not a pig person. Hate me for it. I think pigs
18 deserve to be made into bacon. I don't like pet
19 snakes. I'm into dogs and cats. You know, those are
20 pets to me. I didn't have much empathy for your pig,
21 I apologize for that, but that's probably the worst
22 thing in that whole pile.
23 Q. So do you realize that what you write
24 leaves a scar -- what you write on the internet leaves
25 an indelible scar about your ability to be neutral?

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1 MR. GOUDSOUZIAN: Objection. It's

2 not what he said. That's the exact opposite of what
3 he said. And how would he know about an indelible
4 scar?
5 MS. MEZZACAPPA: Okay. Let -- let me
6 rephrase it.
7 Q. Based upon what you've said about me in
8 your blogs, and on record with harassment complaints,
9 and what you've testified to today, is it reasonable
10 for me to request that you resign from the legal
11 committee, and that you recuse yourself from matters
12 concerning this litigation?
14 whether it's reasonable or not.
15 MS. MEZZACAPPA: Okay. Why don't we
16 conclude the deposition then.
17 MR. GOUDSOUZIAN: Okay. All right.
18 Very good. Wait. Wait. Hang on. I've got a couple
19 questions.
20 * * *
21 DIRECT EXAMINATION
22 BY MR. GOUDSOUZIAN:
23 Q. Mr. Dees, you became on Council in 2016,
24 correct?
25 A. Correct.

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1 Q. Prior to 2016 you were not on Council?

2 A. Yes.
3 Q. You had no official position at the Borough
4 of West Easton?
5 A. Correct.
6 Q. You were aware of some interaction between
7 Ms. Mezzacappa and the Borough, though, correct?
8 A. Yes.
9 Q. You were aware there was some litigation --
10 A. Yes.
11 Q. -- at times?
12 A. At times.
13 Q. Ms. Mezzacappa --
14 MS. MEZZACAPPA: Can I -- can I
15 object for one minute? I'm not sure that this is
16 appropriate because you're deposing him in my
17 deposition. Are you --
18 MR. GOUDSOUZIAN: Of course it is.
19 MS. MEZZACAPPA: Is that allowed?
20 MR. GOUDSOUZIAN: Of course it is.
21 BY MR. GOUDSOUZIAN:
22 Q. Come 2016, Ms. Mezzacappa appeared before
23 the Borough of West Easton at official meetings,
24 correct?
25 A. Yes.

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1 Q. She appeared on more than one occasion?

2 A. Yes.
3 Q. When she initially appeared there was a
4 tone of reconciliation for Ms. Mezzacappa?
5 A. Yes.
6 Q. She withdrew a whole host of legal actions,
7 and they settled a whole host of legal actions with
8 West Easton?
9 A. Yes.
10 Q. And that was authorized by my -- by Council
11 for me to do those things?
12 A. Yes.
13 Q. And she signed off on them?
14 A. I believe so.
15 Q. She also came before Council and indicated
16 at least initially she was owed some money, correct?
17 A. Yes.
18 Q. And she was asked by Council through my
19 office at an open meeting to prepare documentation to
20 that effect, correct?
21 A. Yes.
22 Q. The first time or two that she came before
23 Council she did not have documentation?
24 A. No.
25 Q. She merely said, I'm owed something?

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1 A. Yes.
2 Q. Eventually West Easton received the
3 correspondence that has been marked into evidence at
4 some point -- or strike that.
5 West Easton was aware that Ms.
6 Mezzacappa had come up with some number that she felt
7 she was owed, correct?
8 A. Yes.
9 Q. And Borough Council authorized my office to
10 pay not the entire amount, but almost the entire
11 amount, correct?
12 A. Yes.
13 Q. And that was done after a public meeting --
14 or during a public meeting rather?
15 A. Yes.
16 Q. At that point in time, there was no request
17 for why we're here today, specifically these open
18 records?
19 A. Correct.
20 Q. Negotiations with regard to what amount to
21 pay Ms. Mezzacappa didn't work, correct?
22 A. To my understanding, yes.
23 Q. Subsequently there was this petition filed,
24 correct?
25 A. Yes.

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1 Q. Since the petition was filed, has Borough

2 Council, and one of them being you, authorized staff
3 to provide her with the documents?
4 A. Yes.
5 Q. And to the best of your knowledge, has
6 staff, meaning the Borough of West Easton staff as
7 well as my office, tried to do that?
8 A. Yes.
9 Q. Has there been an indication from staff
10 that everything that we have, meaning everything that
11 West Easton has, has been provided?
12 A. Yes.
13 Q. And has there been an indication that
14 they're -- we, being West Easton, are not clear what
15 else Ms. Mezzacappa wants?
16 A. Yes.
17 Q. To the best of your knowledge, are you
18 aware that requests have been made to Ms. Mezzacappa
19 to outline exactly what she wants?
20 A. Yes.
21 Q. Sitting here today, after going through the
22 deposition testimony, the questions that she has
23 asked, were you still confused as to what she wants?
24 A. Very much so.
25 Q. Are you willing to provide her what she

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1 wants if she's entitled to them pursuant to the open

2 records?
3 A. Absolutely.
4 Q. If you knew what it was that she wanted,
5 would you -- or strike that.
6 Sitting here today you don't know
7 what she wants?
8 A. No.
9 MS. MEZZACAPPA: I'd like to object
10 because that contradicts his prior testimony.
11 MR. GOUDSOUZIAN: That's fine. You
12 can do that.
13 Q. But with the testimony that Ms. Mezzacappa
14 asked you today with regard to the e-mails, you
15 indicated you couldn't figure out what she wants?
16 A. Not all of it. Let me correct myself.
17 When I said, no, not a flat-out no, not all of what --
18 I understand there's $141.75 or something.
19 Q. And if that is actually rightfully owed,
20 you're ready to pay it?
21 A. Absolutely.
22 Q. In fact, West Easton paid various other
23 claims made at a district justice level, correct?
24 A. Yes.
25 Q. Paid it in full?

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1 A. Yes, to my -- to my knowledge.
2 Q. To the best of your knowledge. And to the
3 best of your knowledge, although you might not know
4 the details, various documents have been provided to
5 Ms. Mezzacappa?
6 A. Yes.
7 Q. And all that happened post-2016?
8 A. Yes.
9 Q. And has happened more -- when I say
10 recently, in the last several months?
11 A. Yes.
12 Q. To the best of your knowledge, were
13 attempts to be -- were there -- were there attempts by
14 West Easton to promptly provide the documents to Ms.
15 Mezzacappa once it was determined what she wanted?
16 A. As quickly as possible.
17 MR. GOUDSOUZIAN: That's it. I don't
18 have anything else.
19 MS. MEZZACAPPA: All right. Then we
20 can go.
21 (Deposition concluded at 2:49 p.m.)
22
23
24
25

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1 C E R T I F I C A T E
2
I do hereby certify that I am a
3 Notary Public in good standing, that the aforesaid
testimony was taken before me, pursuant to notice, at
4 the time and place indicated; that said deponent was
by me duly sworn to tell the truth, the whole truth,
5 and nothing but the truth; that the testimony of said
deponent was correctly recorded in machine shorthand
6 by me and thereafter transcribed under my supervision
with computer-aided transcription; that the deposition
7 is a true and correct record of the testimony given by
the witness; and that I am neither of counsel nor kin
8 to any party in said action, nor interested in the
outcome thereof.
9
WITNESS my hand and official seal
10 this 7th day of September, 2016.
11
12
<%signature%>
13 ______________________
Notary Public
14
15
16
17
18
19
20
21
22
23
24
25

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1,500 67:25 71:21 141.75. 24:1,3 177:6 178:18
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2008 69:1 71:10
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100 24:2,8,24 148 4:16 52:12 76:15 116:5
2009 68:15 69:2,6
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2010 43:11 116:5
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2010-2011 140:9
101 68:22 146:4 4:18 7:1,4 10:4
2011 10:19 43:12
102 68:23 1527 1:4 42:21,25 43:6
43:15,18 100:6
11 4:8,16 67:19,20 15th 72:17 44:8 52:9 72:17
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rambles 23:6 29:9
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156:20 158:1,2 10:10 13:2 16:22 156:10,15,18
49:19,23
177:8,8 179:16 29:25 36:15 38:2 159:4 164:13
ramblings 54:3
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29:25 31:8,11 129:8 139:25 182:12 184:8
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115:22 116:11
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61:11,18 62:7 reflected 93:20 137:23 reports 43:11,13
68:6 72:11 78:3 reflects 33:22 released 127:16 57:4 139:2,4,11,23
82:19,25 83:18 refresh 170:10 relief 166:20 140:1,3,7,15,17,25
84:1,17 85:8 173:1 remainder 69:1 141:16,19,24
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weeks 122:9 124:2,14 125:2,4 woman 148:19 writing 10:8,11
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Deposition of Councilman Matt Dees and His Self Admitted Memory Problems, August 2016 (190 Pages)

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Deposition of Councilman Matt Dees and His Self Admitted Memory Problems, August 2016 (190 Pages)

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Page 1

1 IN THE COURT OF COMMON PLEAS

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1 INDEX TO EXHIBITS (Continued)

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1 MS. MEZZACAPPA: Would you like me to

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1 A. I just started January 4th, 2016 I took

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1 Q. Were you the chairperson of the legal

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1 Mezzacappa has been blown off -- a third Commonwealth

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1 A. If there's no date on the letter, I don't

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1 A. I don't believe so. That would be our

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1 not what he said. He didn't say all discussions.

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1 date and time did you vote?

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1 aware of Right-To-Know litigation that you've had with

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1 A. Repeat your question, please?

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1 excessive, can you explain that?

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1 A. I'm supposed to ask for something I don't

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1 Q. Did you ask to read copies of the

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1 Q. Marking in Exhibit 5, Exhibit 6, Exhibit 7

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1 you did it. How would he know?

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1 you're holding in your hand, are they e-mails

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1 Easton owes $141.75. The below final determination of

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1 worth of the -- use this pen for a second. It is

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1 into the record what I e-mailed to Solicitor

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1 underlying agreements -- or the underlying decision,

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1 Q. Okay. Good. Let's stop there. Okay. Now

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1 describing the final determination of fees that were

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1 A. -- for page 9 here?

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1 pay that amount due back to me?

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1 A. It's a letter you gave to our secretary,