Officer X5 - Deposition Transcript (Federal) - Redacted

J er emy Fr eeman , Mar ch 14, 2014
Paul Mur phy v. What comCount y

3206 Wet mor e, Sui t e 12, Ever et t , WA 98201
BMA Cour t Repor t er s 425- 252- 7277
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UNI TED STATES OF DI STRI CT COURT
WESTERN DI STRI CT OF WASHI NGTON AT SEATTLE
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PAUL MURPHY, t oget her wi t h hi s )
mar i t al communi t y, )
Pl ai nt i f f s, )
)
vs. ) NO. 2: 13- CV- 00727
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WHATCOM COUNTY, WASHI NGTON, a )
gover nment ent i t y; WHATCOM COUNTY )
SHERI FF' S DEPARTMENT; WI LLI AM J . )
ELFO, t oget her wi t h hi s mar i t al )
communi t y, )
Def endant s. )
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DEPOSI TI ON UPON ORAL EXAMI NATI ON
OF
J EREMY FREEMAN
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3: 40PM - 4: 15PM
Mar ch 14, 2014
What comCount y Cour t house
311 Gr and Avenue
Bel l i ngham, Washi ngt on 98225
Repor t ed by Kr i st en M. Uhl i g
Cer t i f i ed Cour t Repor t er , CCR, CSR
Page 2
1 A P P E A R A N C E S
2
3 FOR THE PLAI NTI FFS:
Emi l y Beschen
4 Law Of f i ces of Rober t But l er
103 East Hol l y St r eet Sui t e 512
5 Bel l i ngham, Washi ngt on 98225
360. 734. 3448
6
7 FOR THE DEFENDANTS WHATCOM COUNTY & SHERI FF' S DEPARTMENT & ELFO
Dal e Kamer r er
8 Law Lyman Dani el Kamer r er Bogdanovi ch
2674 RWJ ohnson Bl vd SW
9 Tumwat er , Washi ngt on 98512
360. 754. 3480
10
11 FOR WHATCOM COUNTY:
El i zabet h Gal l er y
12 What comCount y Pr osecut or ' s Of f i ce
311 Gr and Avenue
13 Bel l i ngham, Washi ngt on 98225
14
ALSO PRESENT:
15 Wi l l i amEl f o
Tar a Adr i an- St avi k
16
17 I N D E X
18 EXAMI NATI ON: PAGE
19 BY MS. BESCHEN. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
20 BY MR. KAMERRER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
21
22 EXHI BI T DESCRI PTI ON PAGE
23 62. . . . What comCount y Sher i f f ' s Memor andumr e: Deput i es. . . . . . 21
24
25
Page 3
1 J EREMY FREEMAN,
2 havi ng been f i r st dul y swor n, was cal l ed as a wi t ness her ei n and
3 was exami ned and t est i f i ed as f ol l ows:
4
5 DI RECT EXAMI NATI ON
6
7 BY MS. BESCHEN:
8 Q Can you please state your full name for the record?
9 A Jeremiah James Freeman.
10 Q Mr. Freeman, where are you currently employed?
11 A Lynden Police Department.
12 Q Prior to the Lynden Police Department, where were you employed?
13 A The Whatcom County Sheriff's Office.
14 Q What was your position at the Whatcom County Sheriff's Office?
15 A As a deputy sheriff.
16 Q And what years were you with Whatcom County for?
17 A 2001 to 2013.
18 Q During your time at the Whatcom County Sheriff's Office, did
19 you hold any special assignments?
20 A I did.
21 Q What special assignment did you have?
22 A I was in the K9 unit. I was assigned SRT, Special Response
23 Team. I was a first aid instructor and assigned to the Honor
24 Guard.
25 Q Okay. During your time at the Whatcom County Sheriff's Office,
Page 4
1 did you ever have any part in any internal investigations?
2 A Yes.
3 Q How many times?
4 A I don't know. I was there for 12 years, a lot of internals got
5 done.
6 Q Were you ever involved in any internal investigations into
7 Kevin Mede?
8 A I don't know what they called -- right before I left, they did
9 an administrative inquiry. I don't know if they're calling
10 that an internal or an admin inquiry.
11 Q Sure. Fair enough. Were you interviewed in connection with
12 that internal or administrative whatever type of investigation
13 that that was labeled as?
14 A I was.
15 Q Do you know how many times you were interviewed?
16 A Once.
17 Q Who interviewed you?
18 A I think that it was Chief Chadwick and Lieutenant Rossmiller.
19 Q Do you recall whether that interview was recorded?
20 A I don't believe so.
21 Q During that interview, do you recall what the topics they were
22 asking you about included?
23 A I think that they asked me if I had any information on whether
24 or not Kevin Mede had done anything to -- I think they asked if
25 it was Brady material, anything that I had any knowledge of
Page 5
1 that he had done.
2 Q Do you recall what your response was?
3 A I -- I don't recall my exact response. I didn't write it down
4 or keep a recording of it. I don't think that I knew of
5 anything that was Brady material on Kevin Mede at that point in
6 time, no.
7 Q What does Brady material mean to you?
8 A Information where you have been -- well, what it means to me?
9 Well, there have been a time or two when I've had
10 attorneys in criminal cases -- Mr. Butler was one of them. I
11 believe that he brought it up that I had been Brady'ed in a
12 suppression hearing where he was trying to get some evidence
13 suppressed.
14 So my understanding of that is that they think that
15 you're a liar and they don't want anything that you have to say
16 to be admissible. You can no longer be a police officer
17 because you're not trusted to testify in court.
18 Q Prior to that situation with Mr. Butler, did you have a
19 different understanding of Brady material?
20 A No. That's about it.
21 Q Okay. So going back to the investigation of whatever type of
22 investigation it was into Kevin Mede, did you give any
23 information to Chadwick and Rossmiller that you knew about
24 Kevin Mede's activities?
25 A I think that they asked me if I had any knowledge of whether or
Page 6
1 not he had lied and I brought up that, you know, we were
2 involved in guild activities together. And it had -- it was
3 guild related material that had nothing to do with actual
4 police work, and that he had been untruthful with me.
5 Q Okay. So my next question, which I think that you just in part
6 answered: Has Kevin Mede ever lied to you?
7 MR. KAMERRER: I obj ect t o t he f or mof t he quest i on.
8 I t ' s ar gument at i ve, cal l s f or specul at i on, and cal l s f or
9 hear say. Go ahead.
10 Q (By Ms. Beschen) So throughout the deposition -- I didn't go
11 through all of the rules -- he may object and you still can
12 answer the question afterwards. He's just making a record for
13 the transcript.
14 A Okay. Can you ask the question again?
15 Q Yes. Has Kevin Mede ever lied to you?
16 MR. KAMERRER: Same obj ect i on, but go ahead.
17 THE WI TNESS: I bel i eve he has, yes.
18 Q (By Ms. Beschen) Okay. Can you tell me about that time that
19 you believe that he has lied to you?
20 A It's -- I don't know if I can disclose it because it has to do
21 with guild activities from other employees. I -- it's been two
22 or three years now, so I don't recall all of the detail of it.
23 But, yes, I believe that he's lied to me.
24 Q Okay. We've -- I think your deposition No. 25 or 26 throughout
25 this week. So we have heard from other people that he had made
Page 7
1 statements trying to pass a social media policy through the
2 guild. Is that what you're referring to or is this a different
3 instance?
4 A That would be the one.
5 Q Okay. Now, having me said that, does that help refresh your
6 memory at all into what the situation was with Kevin Mede and
7 the social media policy in the guild activities?
8 A It does.
9 Q Okay. Can you tell me what you recall about that social media
10 policy?
11 A I don't remember much detail of it.
12 Q Do you recall what Kevin Mede said to you that makes you
13 believe that he lied?
14 A Just that he -- at that point in time, I believe that he was
15 the guild president. I believe that he came to us as the guild
16 executive board and said that the -- that the staff was trying
17 to push the social media policy through. And that he went to
18 them and he told them no -- but...
19 Q When he said that the staff was trying to push the social media
20 policy through, who did you understand the staff to include?
21 A I believe that it was Undersheriff Parks was the only one that
22 was brought up.
23 Q Can you give me as much background as you're aware of, of how
24 does a policy like that go through the guild? What's the
25 guild's responsibility in policies?
Page 8
1 A Basically, if the staff develops a new policy for the office,
2 they generally will before it's enacted, they'll notify the
3 guild, hey, we're coming up with the new schedule policy or
4 whatever it may be. And then they send it to the guild to see
5 if they have any issue with it. And then if there's no
6 objection or even if there is -- I mean, my understanding is
7 that they can still enact a policy and, you know, the guild can
8 object and fight it later on.
9 Q Okay. So when a policy comes to the guild, do all of the
10 members vote or are there a certain number of members who vote
11 or how does that work?
12 A I think that it depends on what it's -- what's being voted on
13 or what -- there are things where you need the general
14 membership of the guild to vote on and there are things that
15 the executive board can vote on and make a decision.
16 Q Okay. At that time, do you recall whether Kevin Mede was the
17 guild president or not?
18 A I don't. I think that he might have been, but I don't recall.
19 Q Any other statements that you recall telling Chadwick and
20 Rossmiller in the investigation into Mede about lies that he
21 told to you, yourself?
22 A I don't recall off the top of my head.
23 Q Have you heard rumors or talked to anybody else who has worked
24 in the Whatcom County Sheriff's Department, either now or in
25 the past, who has been told a lie by Kevin Mede?
Page 9
1 MR. KAMERRER: Obj ect . Cal l s f or specul at i on, cal l s
2 f or hear say. You can answer .
3 THE WI TNESS: Yeah. I mean, we - - i t ' s a cl ose gr oup
4 of peopl e and you t al k t o t hemand - - yeah. I ' ve t al ked t o
5 many peopl e. I ' ve hear d gossi p and al l of t hat st uf f . But do
6 I r ecal l speci f i c det ai l s of what peopl e have sai d? No, I
7 don' t .
8 Q (By Ms. Beschen) Okay. Do you believe that you have worked
9 enough with Sergeant Mede in order to form an opinion as to his
10 reputation for truthfulness? Does that question make sense?
11 A Ask it again?
12 Q Okay. Do you have an opinion as to Kevin Mede's reputation for
13 truthfulness?
14 A I do.
15 Q What is your opinion of his truthfulness?
16 A My opinion is that he is a liar and a coward.
17 Q Other than the situation that we just talked about with the
18 guild and the social media policy, are there -- what other
19 circumstances or situations have there been that have caused
20 you to form that opinion about Kevin Mede?
21 MR. KAMERRER: Obj ect i on, asked and answer ed.
22 THE WI TNESS: I t ' s - - I have known Kevi n f or , 10 t o 15
23 year s. I mean, we' ve been f r i ends. We have wor ked t oget her .
24 I don' t r ecal l speci f i c det ai l s of al l of t he conver sat i ons
25 t hat we have had over t he year s.
Page 10
1 Q (By Ms. Beschen) At any point during your time at the Whatcom
2 County Sheriff's Office, were you ever -- I guess, do you guys
3 have partners at any point? Do you work on cases together?
4 A It differs everyday.
5 Q Okay.
6 A I mean, you go to calls with different deputies all of the
7 time.
8 Q Okay. Has there been a point during the time that you were at
9 the Whatcom County Sheriff's Office where you knew Kevin Mede
10 to lie in a police report?
11 A No.
12 Q Was there ever a point where Kevin Mede directed or encouraged
13 you to lie in a police report?
14 A No.
15 Q Was Kevin Mede your supervisor when you were at the Whatcom
16 County Sheriff's Office?
17 A It would depend. My direct supervisor was the K9 supervisor
18 until I left, but I would work -- I worked split between a
19 swing shift and a graveyard, so I would work for four different
20 supervisors at different times throughout my work week.
21 Q Okay. Who was the K9 supervisor?
22 A Larry Flynn.
23 Q And did you believe Flynn to be credible?
24 A Yes.
25 Q Did you ever work under Sean Crisp?
Page 11
1 A Yes.
2 Q Did you believe Sean Crisp to be truthful and credible?
3 A Yes.
4 Q What about Beth Larson? Did you ever work with Beth Larson?
5 A I did.
6 Q Were you able to form a reputation as to Beth Larson's
7 truthfulness?
8 A Yes.
9 Q What is your opinion about Beth Larson's truthfulness?
10 A I believe that she's a liar and a coward.
11 Q Can you recall any circumstances where Sergeant Larson has lied
12 to you?
13 A Lied to me? No.
14 Q Any circumstances where you have observed her lie to others?
15 A Yes.
16 Q Can you explain those circumstances to me?
17 A I had a log entry that she wrote about me that was about
18 two-and-a-half pages that I would say about 90 percent of it
19 was a complete and total lie.
20 Q Do you recall approximately what year that occurred?
21 A 2011 or 2012.
22 Q And what was the log entry regarding?
23 A She sent me an e-mail. It was about -- she called me out for
24 violating several policies in the e-mail and it was CC'ed to
25 the K9 supervisor Flynn.
Page 12
1 So I went to her and I asked her why she sent me an
2 e-mail as opposed to coming and talking to me. She wouldn't
3 look me in the eye at that point in time. When I asked her
4 questions, I was told that I needed to mind my own business.
5 I mean, we had a brief conversation that -- it was at
6 one of the substations. I got called in the next night and I
7 believe that it was her and Kevin Mede that were in there. I
8 got confronted and they tried baiting me into going off.
9 And then the next thing that I know, about a year later
10 when I was getting my employee evaluation, I see in the
11 evaluation that I'm being rated substandard on certain
12 categories. And this log entry that she wrote is being
13 referenced, but it was not attached to the evaluation. So I
14 had to ask for it.
15 And when it was given to me, I read it. Like I said,
16 about 90 percent of it, the things that she put in there, were
17 false.
18 Q Can you recall specifically any of the statements that she made
19 in that log entry which were false?
20 A I guess the part that was shocking to me is that I was
21 described in that log entry as one would describe a suspect
22 that's about ready to attack an officer and that did not
23 happen. I believe that she made some comment about
24 insubordination or something like that and that -- the comments
25 that she made about that were not true.
Page 13
1 Q Among the co-workers that you had at Whatcom County Sheriff's
2 Office, roughly how many of them do you think would share your
3 opinion that Beth Larson is not credible and truthful?
4 MR. KAMERRER: I j ust want t o i nser t an obj ect i on t hat
5 t hat cal l s f or specul at i on and hear say. Go ahead.
6 THE WI TNESS: I don' t know how many peopl e woul d shar e
7 t hat one.
8 Q (By Ms. Beschen) Do you know how long Beth Larson has been a
9 sergeant for?
10 A Since maybe 2010 or 2011, somewhere around there.
11 Q What about Kevin Mede? Do you know how long he's been a
12 sergeant for?
13 A I don't, maybe five or six years. I don't know.
14 Q Okay. Do you have any knowledge as to whether or not Beth
15 Larson supported Sheriff Elfo in the election?
16 A I believe that she did.
17 Q Do you have any knowledge as to whether Kevin Mede supported
18 Bill Elfo in the election?
19 A I don't.
20 Q Are you aware of any internal or administrative or any level of
21 investigations into Beth Larson's credibility at the Whatcom
22 County Sheriff's Office?
23 A Not that I'm aware of.
24 Q Are you aware of whether anybody has ever made complaints about
25 Beth Larson being untruthful to the Whatcom County Sheriff's
Page 14
1 Office?
2 A Can you ask the question again, please?
3 Q Are you aware of any complaints that have been made to the
4 Whatcom County Sheriff's Office about Beth Larson's
5 truthfulness? And by complaint, I mean, broad -- not some sort
6 of written formal complaint.
7 A Yes.
8 Q What complaints are you aware of?
9 A I made a, you know, I went and spoke to supervisors in
10 reference to the log entry and then I talked to another deputy
11 who shared a similar experience.
12 Q Who was that deputy that shared a similar experience?
13 A Oaks.
14 Q Did you ever speak with Sheriff Elfo about it?
15 A About Deputy --
16 Q Deputy Larson?
17 A Oaks?
18 Q About Beth Larson. Sorry.
19 A Yes, I did.
20 Q Do you recall when that was?
21 A It was right before I left the sheriff's office.
22 Q Did you provide Sheriff Elfo any information about Beth
23 Larson's credibility or truthfulness during that meeting?
24 A I told him about my log entry and he said that he would look
25 into it.
Page 15
1 Q Do you know whether he ever looked into it or not?
2 A I don't. I wasn't -- it wasn't a -- I think it was right
3 before I left the sheriff's office, so I didn't check to see if
4 he checked into it.
5 Q Okay. Did you resign from the sheriff's office?
6 A I quit to go work somewhere else.
7 Q Okay. Was that due to issues that you had with Larson or Mede?
8 A Yes.
9 Q Do you know if you or others thought that Larson and/or Mede
10 were protected by Sheriff Elfo?
11 A I don't know that.
12 Q Has the sheriff's office ever done any sort of internal
13 investigation into you for telling a lie?
14 A Mm-hm.
15 Q Do you recall when that was?
16 A I think that it was after 2009. I had been sued. The Justice
17 Department did a -- came and did a big investigation on me and
18 the prosecutor's office was involved and the sheriff's office
19 supplied them with information. I think that they checked all
20 my computers and I was not found to have been untruthful.
21 Q Okay. At any point during your career at the Whatcom County
22 Sheriff's Office, were you ever directed by anybody from the
23 prosecuting attorney's office to lie?
24 A No.
25 Q During your time at Whatcom County Sheriff's Office, were you
Page 16
1 ever directed by anybody within the sheriff's department to
2 lie?
3 A No.
4 Q Were you ever encouraged to lie?
5 A No.
6 Q Did you ever enter into any sort of stipulation at the
7 direction or encouragement of Deputy Watts and -- Deputy
8 Prosecuting Attorney Watts, I think.
9 MR. KAMERRER: I ' l l i nser t an obj ect i on t hat i t cal l s
10 f or a l egal concl usi on.
11 Q (By Ms. Beschen) Do you know what a stipulation is?
12 A Yes. But can you ask the question again?
13 Q Were you ever asked to enter into any sort of stipulation with
14 Randy Watts or by Randy Watts?
15 A By Randy Watts.
16 MR. KAMERRER: Same obj ect i on.
17 Q (By Ms. Beschen) And what stipulation did Randy Watts ask you
18 to enter into?
19 A He -- I don't believe that we entered into a stipulation. He
20 -- it was in reference to a lost boot with Brian Wiederspohn
21 over the stairs versus ramp. He told the other deputy and I
22 that we were going to lose the case and that nobody believed us
23 that there was stairs there.
24 I was not willing to concede that there was not stairs
25 there because that's what I saw that day that we were there
Page 17
1 and, yeah. On the stand, I did not -- I did not concede that
2 there was a ramp there.
3 My testimony and what I truly believe to this day was
4 that we were standing on stairs. But the fact that I didn't
5 have photographs of those stairs and the fact that they had
6 about 50,000 photos of stairs and apparently everybody coming
7 out of the woodworks testifying to it.
8 I said, hey, you guys have proven in your case -- you
9 have shown proof. We don't have any proof other than our word.
10 So that was my testimony on that and that was what I recall of
11 that.
12 Q With regards to the testimony that you're speaking about right
13 now, was that in the criminal case or the civil case?
14 A The civil case.
15 Q Before you testified in the civil case, did Randy Watts direct
16 you as to what your testimony needed to be?
17 A No. I had not discussed it with him prior to the civil case.
18 Q Okay. Did you ever discuss your testimony with Sheriff Elfo?
19 A About the civil case?
20 Q Yes.
21 A Yes.
22 Q Did he give you any advice or direction as to what your
23 testimony needed to be?
24 A No. This was after the civil case was done that I spoke to
25 Sheriff Elfo.
Page 18
1 Q Okay. After the civil case was done and you spoke with Sheriff
2 Elfo, what about the case did the two of you discuss?
3 A I discussed with him that if I was a liability or if it was
4 ever a point in time where I was -- if he felt that I was
5 dragging the sheriff's office down, that he would just have to
6 say the word and I would step down.
7 Q Did he ask you to step down?
8 A No.
9 Q Did you at any point believe that Sheriff Elfo wanted you to
10 step down?
11 A No.
12 Q Did you believe that Beth Larson did not want you to be working
13 at the Whatcom County Sheriff's Office?
14 A I don't know that.
15 Q Who did you support in the 2011 election?
16 A That's my political preference.
17 Q Did you openly support anybody for sheriff in the 2011
18 election?
19 A You mean standing on a street corner?
20 Q No. Did you tell other people who you would be voting for
21 within the Whatcom County Sheriff's Office?
22 A Some close friends and maybe some family. I didn't -- I am not
23 a very political person. I did not get involved in any of the
24 political stuff in the department.
25 Q Okay. Did you endorse any candidate?
Page 19
1 A What do you mean endorse?
2 Q Apparently, there's some formal endorsements that people can
3 fill out and --
4 A I did not fill out any formal endorsements.
5 Q Did you donate money to any of the candidates?
6 A I don't know if my wife made a donation, but I know the sheriff
7 has different, what is it, I believe it's Pass The Hat that the
8 sheriff is involved in. My wife contributes money to that.
9 Q Who of the people that we have talked about have you -- is
10 there anybody currently working at the Whatcom County Sheriff's
11 Department whose credibility is in question to you?
12 MR. KAMERRER: Obj ect i on. Vague and over br oad, cal l s
13 f or specul at i on.
14 Q (By Ms. Beschen) Does that question make sense?
15 A Yes.
16 Q Do you want me to re-ask it?
17 A No. Other than -- other than Beth and Kevin, I'm not concerned
18 about anybody else's credibility.
19 Q Did you ever work with Paul Murphy?
20 A I did.
21 Q Did you work with him enough to form an opinion as to his
22 credibility?
23 A I did.
24 Q Do you believe him to be a credible officer?
25 A I do. Your previous question about the endorsements. I had a
Page 20
1 sign in my front yard for a candidate.
2 Q Okay. Who was the sign for?
3 A Bill Elfo.
4 Q Okay. While you were still at the Whatcom County Sheriff's
5 Office, were you aware that Sheriff Elfo was himself, or other
6 people that he had directed, monitoring Paul Murphy's Facebook
7 page?
8 A I was not aware.
9 Q Were you aware that Paul Murphy had a Facebook page that
10 related to un-electing Bill Elfo?
11 A I was not. I saw a picture of -- I saw a picture of the
12 sheriff sitting on a unicorn that somebody showed me.
13 Q Do you recall who showed it to you?
14 A I don't. I think several people showed it to me. Sorry.
15 Q Are there any other internal investigations that occurred while
16 you were at the Whatcom County Sheriff's Office that you recall
17 that we haven't already talked about?
18 A Yes.
19 Q Which other internal investigations can you recall that we
20 haven't discussed?
21 A I have been investigated for several allegations.
22 Q Anything that didn't involve you as the subject of the
23 investigation?
24 A I believe they did an internal on Andy Koch, a former deputy,
25 but that was probably maybe eight or ten years ago.
Page 21
1 Q Do you know what he was investigated for?
2 A I don't recall.
3 MS. BESCHEN: Okay. Let ' s go of f t he r ecor d and t ake
4 j ust a f i ve mi nut e br eak. I t hi nk I ' mal most done. I j ust
5 want t o r un t hr ough my not es r eal l y qui ck.
6 ( Br i ef Pause I n Pr oceedi ngs)
7 ( Deposi t i on Resumed)
8 ( Mar ked Deposi t i on Exhi bi t No. 62)
9 Q (By Ms. Beschen) The court reporter has just handed you what's
10 been marked as Exhibit No. 62. If you turn, it looks like the
11 pages are not numbered, but if you would turn midway through
12 the part where it says, "Deputy Freeman" towards the bottom of
13 the exhibit. Did you find it?
14 A Mm-hm.
15 Q Okay. So looking down to the third paragraph where it says,
16 "Deputy Freeman. On February 26th, Lieutenant Rossmiller and I
17 spoke with Deputy Freeman at the Laurel Fire Hall."
18 Go ahead and read that paragraph through to the next
19 page. And then after that, I'm going to ask you if that is
20 what you recall about that conversation and if you recall
21 anything else that didn't get reported in here.
22 MR. KAMERRER: Let me get t hat page, j ust so t hat I - -
23 MS. BESCHEN: I t doesn' t have a page number , but t hi s
24 i s i t .
25 MR. KAMERRER: Okay.
Page 22
1 MS. BESCHEN: I t ' s about mi dway t hr ough.
2 THE WI TNESS: I ' mdone r eadi ng.
3 Q (By Ms. Beschen) Okay. Does that match your exact
4 recollection of what occurred during that interview with -- was
5 it Chadwick or Rossmiller?
6 A I believe both of them were there.
7 Q Okay.
8 A I don't have an exact recollection of our conversation that we
9 had. I mean, with changes of words like saying not accurate as
10 opposed to a bold faced lie, which was the wording that I used,
11 I don't see any. And then we spoke a majority of the time
12 about Sergeant Larson and I don't think that any of that is in
13 here. It's mostly on Kevin Mede.
14 Q Anything else that you recall discussing that you don't see in
15 that paragraph?
16 A Other than that, no.
17 Q Okay.
18 MS. BESCHEN: I have no f ur t her quest i ons. He may
19 have some t hough.
20 MR. KAMERRER: I ' ve got a coupl e of quest i ons.
21
22 EXAMI NATI ON OF J EREMY FREEMAN MR. KAMERRER
23
24 BY MR. KAMERRER:
25 Q You mentioned a Pass The Hat donation, was that for a charity?
Page 23
1 A I believe it is. I don't know. My wife told me about it and I
2 know that -- I don't believe that Sheriff Elfo runs it, but
3 it's a -- I believe that it is a charity, yes.
4 Q Is it something that is a solicitation within the sheriff's
5 office?
6 A No. Not that I'm aware of, no.
7 Q Okay. So it's a community charity or solicitation?
8 A I don't even know that it was a solicitation. I think that it
9 was something that my wife saw on Facebook or something like
10 that. I don't do Facebook, so I couldn't tell you much about
11 it.
12 Q Do you have any knowledge that Sheriff Elfo asked employees of
13 the Whatcom County Sheriff's Office for political donations?
14 A No.
15 Q Were you ever asked for a donation to Sheriff Elfo's political
16 campaign?
17 A No.
18 Q The photograph of Bill Elfo on a unicorn, was that something
19 that you understood to be from an Un-Elect Bill Elfo page
20 maintained online by Paul Murphy?
21 A I don't know. I -- the photo that I saw was printed off and
22 stuck on the wall in an office.
23 MR. KAMERRER: Al l r i ght . That ' s al l of t he quest i ons
24 t hat I have.
25 MS. BESCHEN: Okay. Thank you. You' r e done.
Page 24
1 ( Si gnat ur e Reser ved)
2 ( Deposi t i on Adj our ned)
3
4
5
6
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11
12
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15
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Page 25
1 C E R T I F I C A T E
2 STATE OF WASHI NGTON )
) ss.
3 COUNTY OF I SLAND )
4 I , Kr i st en M. Uhl i g, t he under si gned CCR i n and f or t he St at e
of Washi ngt on, do her eby cer t i f y:
5
That t he annexed and f or egoi ng deposi t i on of t he wi t ness
6 named her ei n was t aken st enogr aphi cal l y bef or e me and t r anscr i bed
by me;
7
I f ur t her cer t i f y t hat t he wi t ness exami ned, r ead, and si gned
8 t he deposi t i on af t er t he same was t r anscr i bed, unl ess i ndi cat ed i n
t he r ecor d t hat t he par t i es and t he wi t ness wai ve t he si gnat ur e;
9
I f ur t her cer t i f y t hat al l of t he obj ect i ons made at t he t i me
10 of sai d exami nat i on t o my qual i f i cat i ons or t he manner of t aki ng
t he deposi t i on, or t o t he conduct of any par t y, have been not ed by
11 me upon sai d deposi t i on;
12 I f ur t her cer t i f y t hat I amnot a r el at i ve or empl oyee or
at t or ney or counsel of any of t he par t i es t o sai d act i on or
13 counsel , and t hat I amnot f i nanci al l y i nt er est ed i n t he sai d
act i on or t he out come t her eof ;
14
I f ur t her cer t i f y t hat t he deposi t i on, as t r anscr i bed, i s a
15 f ul l , t r ue, and accur at e t r anscr i pt of t he t est i mony, i ncl udi ng al l
quest i ons and answer s, and al l obj ect i ons, mot i ons and except i ons
16 of counsel made and t aken at t he t i me of t he f or egoi ng exami nat i on;
17 I f ur t her cer t i f y t hat I amseal i ng t he deposi t i on i n an
envel ope wi t h t he t i t l e t o t he above cause t her eon and mar ked
18 " Deposi t i on Upon Or al Exami nat i on" of sai d wi t ness and pr ompt l y
causi ng t he same t o be del i ver ed or f or war ded t o Counsel f or t he
19 Opposi ng Par t y;
20 I N WI TNESS THEREOF, I have her eunt o set my hand and af f i xed
my of f i ci al seal t hi s ___ day of ____________, 2014.
21
22
__________________________
23 Kr i st en M. Uhl i g, #1934
Cer t i f i ed Cour t Repor t er ,
24 Resi di ng i n Cl i nt on, Washi ngt on.
25

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Paul Mur phy v. What comCount y

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