Affidavit Stating Facts on Information and Belief

STATE OF ___OHIO___
COUNTY OF ______LUCAS___

PERSONALLY appeared before me, the undersigned authority in and for said county and
state, __Heidi Buck____, who, having been being first duty sworn by the undersigned Notary
Public, deposes and says:

Affiant is informed and believes, and on such information and belief, and in good faith,
states the following:

1. I was offered an opportunity to be treasurer with the board of Toledo Streets Newspaper in January
2015. Shortly after I was informed by Amanda Zuehkle and Karin Coble that one whom I would be
working closely with was Ken Leslie (referred to from now on- him/he/his). I was told he had left the
board in December 2014 to focus on other commitments, however, was an asset to navigate through
how to obtain funding for Toledo Streets Newspaper. The person that was currently in charge of fund
raising, Rachel Richardson, was leaving after the event in March. She failed at raising money and decided
to focus on her artwork, is what I was told is why she left. A few weeks later I went to his office with the
editor of the paper (Amanda Zuehkle). She reiterated how important he was to funding for the
newspaper. The meeting was brief and professional, with a promise of a check to help coming in the next
few weeks.

2. Over the next few months, I had many interactions with him that were cordial, friendly, and
professional. I felt at ease around him. Early June I was told a check was ready and I could pick it up at his
office. When I arrived to pick up the check, we went into his office and had small talk about the
newspaper for about 5 minutes. He handed me the check, then I went to leave the office. He followed
me out and as I turned to hug him, as was custom for me to do to everyone I worked with at the time, he
leaned over to kiss me on the mouth. I was stunned and left quickly, taking no time in convincing myself
it was nothing but a fluke. I mentioned it to the board president (Karin Coble) at the time, and she
brushed it off as him being friendly.

3. About a week or so after that encounter, he sent me a message via social media asking if my husband
and I would like to come to his cabin for the 4th of July holiday. I found that very odd, since I barely knew
him, and had only brief encounters with him the last few months and declined.

4.The second or third week in July (2015), I was attending a Saturday Morning Picnic with the employees
of Toledo Streets Newspaper, Courtney Billion and Lilian Briggs, making sure the Vendors had
newspapers to sell. He was there, like every other Saturday. When he walked by me, he reached his
hand out and rubbed my stomach while moving around me brushing his crotch against my hip. I froze,
looked around in fear, making eye contact with Courtney Billion. She and I moved toward each other;
she asked me if I was ok when we met up. I told her what happened, and she said she saw in my eyes
something was wrong. We found Lilian, filling her in, and we all left.

5. A few days later I met with the President of the Board, Karin Coble, and told her what happened. She
once again blew it off as a misunderstanding, his age, how he has always been, handsy friendly. I told her
I was not comfortable working with him anymore. She agreed to be the one to work with him.

6. I avoided him as much as possible after that. On rare occasions I would be in the same room with him.
July 2017 was the Savage Golf Outing. His organization, Veterans Matter, was a recipient of their charity
along with Toledo Streets Newspaper. I was there to represent the paper. He chose to sit at my table, and
being in a public setting, I greeted him, “hello Mr. Leslie”. He replied, “hello Heidi girl”. It made my skin
crawl, and I could not wait to be finished to leave. I had a panic attack on the way home, so focused on
getting away from him I accidently took the big prop check Savage gives for photo ops.

7. In late August 2017, it became clear that the attempts to keep Toledo Streets Newspaper properly
funded was coming to an end. We decided to have one more fundraiser to hopefully get us through the
end of the year. If not, we had to close the door at the end of October. Karin Coble informed me that the
only way to have a fundraiser was to work with him again. He was going to fund the venue, she claimed.
We had no choice, she said. I told her she needed to handle it because I could not work with him. The
afternoon of the event, October 17th, 2017, I was in the ER thinking I was having a heart attack. It was a
panic attack. I did not attend the event. Shortly after I left Toledo Streets Newspaper, and it was
reabsorbed into One Matters, headed by him.

8. January 2021, while commenting on a post from Rachel Richardson, I found out that he was asked to
leave the board of Toledo Streets Newspaper due to sexual harassment. I was never told that.

___________________________________

SWORN to and subscribed before me, this the ____ day of _____________, 20____.

_____________________________
NOTARY PUBLIC

My Commission Expires:
 Affidavit Stating Facts on Information and Belief

STATE OF _____OHIO____
COUNTY OF ________LUCAS____

PERSONALLY appeared before me, the undersigned authority in and for said county and
state, ___Rachel Richardson______________, who, having been being first duty sworn by the
undersigned Notary Public, deposes and says:

Affiant is informed and believes, and on such information and belief, and in good faith,
states the following:

1. In 2012, I applied for a data entry job with 1Matters.org. I was invited for an interview at
1 Matters headquarters in Ken Leslie’s office. As I recall, I met Ken at Tent City that year
where I performed a set of music. We struck up a friendly rapport at the event and he
mentioned the job was available. During the interview, Ken took me for ice cream. I did
not feel comfortable getting in a car with him and going for ice cream but felt like I should
go along with it because I needed a job. I was on the verge of being homeless and told
him that. I was honest during the interview and expressed that I wasn’t enthusiastic
about the idea of a data entry job but that I had a college degree and was capable of
doing the job in order to get back on my feet financially. Another organization I worked
for had lost funding. At the end of the interview, Ken expressed that I would not be a
good fit for the organization because I lacked enthusiasm for the position. I repeated to
him that I was on the verge of being homeless and that I really needed a job. He took
out his wallet, gave me $60 dollars cash, and walked me out of the office while
pantomiming zipping up his pants and making groaning and grunting sounds to imply I
had just performed oral sex on him.
2. In 2014, I was hired as the Development Director for Toledo Streets Newspaper. Ken
Leslie was on the Board of Directors for the organization and 1Matters was the fiscal
sponsor. When I was hired, I told the Board President (Karin Coble ) and my co-worker
(Christy Grob) that I had had a very uncomfortable encounter with Ken and was not
looking forward to working with him in any capacity. Nevertheless, I was required to go
to Ken’s office to pick up checks and to accompany him, alone, to fundraising meetings.
During those times when we met for any reason, I did not show a sense of humor for his
jokes and was not interested in extensive conversations. He would tell me I was
aggressive, arrogant, and combative whenever I didn’t go along with his jokes.
3. My co-worker (Christy Grob) at Toledo Streets came to our office one day and told me
that something happened she knew I would be bothered by. She told me that Ken, the
previous evening, called her on the phone and told her he had been looking at pictures
of her on Facebook and that those pictures had given him an erection. I told her I had
no choice but to go to the Board President (Karin Coble) and put a stop to the sexual
harassment we were being subjected to as staff of Toledo Streets Newspaper with him
on the Board.
 4. I went to the Board President (Karin Coble) and was told she would put a “firewall” in
place and enforce a rule that Ken would have no contact with me and I would not have
to see him or be alone with him. I was not satisfied with that and wanted him removed
from the Board. She and Ken came up with an arrangement that if I raised a certain
amount of money for the organization, he would resign from the Board.
5. In October of 2014, I organized a fundraising event at Gathered Glass Blowing Studio.
At the event, I was stationed at the door taking tickets and welcoming guests. Ken
attended the event and when he arrived he walked directly to me and forced me to hug
him. He sat at my table for most of the night and tried to talk to me. I did my best to
ignore him. My boyfriend (now husband) sat with me. Ken forced another hug on me
before he left.
6. I documented all of this and submitted it to the Board President (Karin Coble) over dinner
at her home with her husband. I reiterated my request for him to be removed from the
Board. I raised the funding amount we agreed to. Ken Leslie resigned from the Board.
I did not keep a copy of the documentation and when asked, the former Board President
could not find the documentation. An email mentioning the failed “firewall” is attached.

___________________________________

SWORN to and subscribed before me, this the ____ day of _____________, 20____.

_____________________________
NOTARY PUBLIC

My Commission Expires:
 GENERAL AFFIDAVIT

STATE OF OHIO
COUNTY OF LUCAS

PERSONALLY came and appeared before me, the undersigned Notary, the within named
CAMILLA (‘CAMI’) ROTH SZIROTNYAK, who is a resident of LUCAS County, State of
OHIO, and makes this her statement and General Affidavit upon oath and affirmation of belief and
personal knowledge that the following matters, facts, and things set forth are true and correct to
the best of her knowledge:

1. As of the date of this affidavit, I work at the Mental Health & Recovery Services Board
of Lucas County (‘MHRSB’), where I have been the Director of Planning and Quality
since January 2018. In this role, I oversee strategic planning, contract development and
compliance, outcomes performance for contracted agencies, HIPAA Privacy, and 42 CFR
Part 2 compliance.

2. In 2019, the Executive Director of the MHRSB, Mr. Scott Sylak, and the Advocate in
Chief of 1Matters, Mr. Ken Leslie, were both part of the Housing First Core Team
meeting (later renamed the No Barriers Housing Committee), a community committee
comprised of local policymakers and service providers whose clients intersect with Lucas
County’s homelessness system of care. I was invited by Mr. Sylak to attend the Housing
First Core Team meetings as an audience member, given my role at the MHRSB.

3. Within the Housing First Core Team, a committee was formed to research solutions to a
perennial issue regarding coordination of care and intersystem data exchange. This
committee was titled the Open Homeless Management Information System (‘HMIS’)
Committee, and Mr. Leslie was to lead it. At that time, I had a fairly extensive knowledge
base of behavioral health privacy and confidentiality regulations; I had also been on, and
served as Co-Chair for, the Toledo-Lucas County Homelessness Board’s Quality and
Performance Subcommittee in which we discussed HMIS data and policy regularly, so I
had a good working knowledge of its outputs and limitations. In fact, at that time, I was
so passionate about the intersection of behavioral health and homelessness policies, that I
was recognized in 2017 by receiving the 20 Under 40 award, in part due to my
community work around homelessness issues, public health, and quality improvement.
of the Thomas M. Wernert Center), I have maintained as much distance from him as
possible. I’ve literally attempted to hide behind people, objects, or structures so he does
not see me. As a young female professional in executive leadership, it is incredibly
demeaning to have to hide myself because of Mr. Leslie’s sexual harassment toward me.

DATED this the ____ day of _______________, 20____.

__________________________________
Signature of Affiant

SWORN to and subscribed before me, this the ____ day of _______________, 20____.

____________________________________
NOTARY PUBLIC

My Commission Expires: ____________________