Robert Telles Tells Jury Jeff German was Assassinated — Cross-Examination

[00:00:00] Speaker 1: Okay, how about this? If Compass Realty wants to kill you, why don't they encourage Metro like we'd really like you to put the murder weapon in there? Why didn't they do something like that? I don't know. That seems really odd that the most significant thing is not in your house, correct? I think what's odd is that [00:00:16] Speaker 2: five days after the murder that supposedly there was a shoe and also a [00:00:21] Speaker 1: hat in my house. So the answer to my question, the most significant piece of evidence, the murder weapon, is not in your house despite your theory you've been framed? That's correct, sir. Let's talk about this. We've seen the picture of the killer. What's the most notable thing, by far the most notable [00:00:39] Speaker 2: thing, on the killer's person? It's either the hat or the shirt. It's the shirt, [00:00:44] Speaker 1: right? And that shirt is not in your house, is it? No. If Metro or Compass or Rita or [00:00:52] Speaker 3: Cliff all wanted to frame you, why didn't they put the bright orange coat in your house? I couldn't speak to that. All I can tell you is... Doesn't that sound not very [00:01:03] Speaker 1: professional if they're trying to set you up? I don't know. Maybe for plausibility's sake, they'd put half the stuff in their... Oh, they want to dial it back? I don't know. Okay. Here's another thing. Why don't they cover your car in Garriman's DNA? Why didn't they do that? Because they didn't have access to the car until the day that Mr. Mogg took photos. But they have... I mean, they control everything. They take it to their CSI garage and rub it full of DNA. Why didn't they... why is there no DNA of Garriman in your car? I mean, if they want to frame you, why isn't it there? Do you have an answer for that? Sir, I don't know. Okay. But one of the things that we do know is that prior to your arrest, you do in fact wash that car. Correct? The exterior only. You still wash it. Correct? Oh, yes. And your testimony to this jury was, after Rita told me about the tweets about the car that I found so strikingly similar, I went out and washed my car. You told them that on direct. Isn't that correct? No, sir. Do you mean Roberta? I meant Roberta. After Roberta told you, "Gosh, that looks just like your car." You read John Hunter Custer's tweet. You went out and that prompted you to start washing the Yukon. No. That's not your testimony. No. I said... [00:02:17] Speaker 2: No. I said that I washed all three vehicles. Right. Including your Yukon. [00:02:22] Speaker 1: Yes. Right. Because you'd agree if you only wash one of them, that might look a little suspicious. Right? I don't know that I was planning things to be suspicious or not suspicious, sir. Okay. But let's just be clear. You would agree with me washing things can make evidence go away. Isn't that right? [00:02:45] Speaker 2: I would think DNA evidence would be inside of a vehicle, not on the outside, sir. Okay. Sir, you'd be surprised. Okay. But that's not the point. I guess I would be surprised then. [00:02:54] Speaker 1: My question is this. Washing things can make evidence go away. Correct? Could it possibly? Yes. Thank you. So, let's continue down the path of what's in your phone. [00:03:12] Speaker ?: I'm going to be... I hope I didn't ruin this. I'm going to be... Let's see if this pulls up. We're going to be publishing Exhibit 354. Sure. Let's close out of this. [00:03:25] Speaker 1: Let's close out of this. Okay. Okay. [00:03:28] Speaker ?: Okay. Let's close out of this. [00:03:30] Speaker 1: Okay. Okay. Okay. Okay. Let's see if this pulls up. We're going to be publishing Exhibit 354. Sure. Okay. Okay. Let's close out of this. [00:03:40] Speaker ?: Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay. Okay. Let's close out of this. Okay. [00:03:51] Speaker 1: Let's look at... All right. Let's look at this. [00:03:54] Speaker ?: Let's do it. We'll do it this way. We're going to... If we could just cue over for a second to the overhead. [00:04:00] Speaker 1: Let's look at this. Let's do it. We'll do it this way. We're going to -- if we could just cue over for a second to the overhead. This is this extraction report that has a lot of images regarding Google Maps in your phone. Do you remember hearing testimony about this? [00:04:27] Speaker 2: That's what I heard. [00:04:28] Speaker 1: Okay. And the date on this is August 12th of 2022. Isn't that correct? That's when these files appear. Isn't that right? [00:04:35] Speaker 2: That's when it purports to have appeared. [00:04:38] Speaker 1: Okay. Sir, you would agree with me. You don't actually have to go to Bronze Circle to get Google Maps to generate these images, correct? All you have to do is go to the website. Isn't that right? [00:04:51] Speaker 2: For any location? Sure. Yes. [00:04:53] Speaker 1: And this is, what, about two to three weeks before Mr. Derriman is killed? [00:05:03] Speaker 2: If we can trust the date, yes. [00:05:06] Speaker 1: All right. All right. So, sir, let's -- I'm opening the folder that says Bronze Circle. If we could cue over, please. [00:05:23] Speaker ?: Okay. [00:05:24] Speaker 1: That's Jeff Derriman's house, correct? [00:05:33] Speaker 2: I have come to learn that it is his house. [00:05:36] Speaker 1: That's a great point. You've come to learn that. Because prior to this all happening, you had never been over at a house, correct? Correct. You have no reason to be over at that house, correct? [00:05:46] Speaker 2: That is absolutely correct. [00:05:47] Speaker 1: You don't even know where he lives, because I'm sure Mr. Derriman didn't give you his personal address. That is absolutely correct. And yet, the weird thing is, when we go through these images, when we start getting to, like, the Google Maps data, like, that's his house, right? [00:06:05] Speaker 2: It looks like that is the house. [00:06:11] Speaker 1: Yeah. [00:06:14] Speaker ?: Same thing. [00:06:18] Speaker 1: That's his house, right? [00:06:20] Speaker 2: It appears to be. [00:06:22] Speaker 1: Like, if we look over here in the back, that's literally the very spot where Mr. Derriman breathes his last breath. Isn't that right? [00:06:35] Speaker 3: That's the very last spot that we see Mr. Derriman from that body cam, right? He's lying right over there. [00:06:45] Speaker 2: It looks like a similar area. Similar. [00:06:48] Speaker 1: It's the area, isn't it? [00:06:50] Speaker 2: If you say so, sure. [00:06:52] Speaker 1: So you don't believe that's the spot? [00:06:55] Speaker 2: It looks like the house, so I would think... How about there? [00:06:58] Speaker 1: Isn't that where Mr. Derriman was found by the police? [00:07:01] Speaker 2: I would think likely so. [00:07:04] Speaker 1: And the very spot that his body is lying is inside your phone. [00:07:11] Speaker 2: That is very strange. I mean, how does someone plan to have a victim in a particular area at their home? That's, again... [00:07:24] Speaker 1: So you would agree with me that if you were planning to kill someone at their house, it might be a good idea to get a lay of the land, right? [00:07:33] Speaker 2: I've never plotted to kill anyone. Oh, I didn't say you. [00:07:37] Speaker 1: I'm just talking hypothetically. You would agree with me that if you were planning to kill someone, it might be a good idea to get a lay of the land. Correct. I have a hypothetical question. He's not an expert, right? I don't know. I don't know what the circumstances are. I don't know what you're talking about as far as where you want to, you know, do this deed or whatever. Mr. Tellis, if you wanted... Let's do it. Let's do it. You don't want to answer the question. We'll do it another way. Again, I had objection to characterization. Mr. Tellis, if you're planning on doing something, you want to prepare for it, correct? [00:08:01] Speaker 2: It depends on what you're planning to do, sir. Okay. How about your work as a public administrator? Did you prepare every day to go to work to be competent? I don't know. [00:08:08] Speaker 1: I don't know. I don't know. I don't know. I don't know what the circumstances are. I don't know what you're talking about as far as where you want to, you know, do this deed or whatever. Mr. Tellis, if you wanted... Let's do it. You don't want to answer the question. We'll do it another way. Again, I had objection to characterization. Mr. Tellis, if you're planning on doing something, you want to prepare for it, correct? [00:08:24] Speaker 2: It depends on what you're planning to do, sir. [00:08:26] Speaker 1: Okay. How about your work as a public administrator? Did you prepare every day to go to work to be competent at what you're doing? Mr. Yes. Did you do that because it's important to do the job correctly? Mr. Yes, sir. And if the stakes are really big, you want to make sure you're super prepared? Mr. Yes, sir. Okay. There's over a hundred images of Bronze Circle neighborhood in your house, correct? In your phone. Isn't that right? [00:08:47] Speaker 2: Mr. I don't know that they are, sir. Okay. [00:08:49] Speaker 1: Well, then let's start clicking. [00:08:54] Speaker 2: Mr. Plus two. Again, I wouldn't use my card. [00:08:58] Speaker 1: Mr. It's not my question. My question is this is contained in your phone, right, sir? [00:09:05] Speaker 2: Mr. I don't believe so. Mr. Okay. You don't believe so? Mr. If it is in there, I didn't put it there, sir. [00:09:10] Speaker 1: Mr. Okay. So the answer is it's there, but you didn't put it there, correct? [00:09:14] Speaker 2: Mr. Again, I do not know that it's there, and I certainly did not put it there. [00:09:17] Speaker 1: Mr. Okay. Mr. Okay, sir. Mr. You're asking me to testify something that I can't tell you is true. [00:09:25] Speaker 2: Mr. Right. [00:09:26] Speaker 1: But you did hear the testimony of someone coming and said I looked in his phone and that stuff is there, correct? [00:09:31] Speaker 2: Mr. That's what they've said. [00:09:33] Speaker 1: Mr. It's the same phone that your expert looked at, correct? To extract Celebrite data from, right? It's the exact same phone, correct? Mr. Sure. Mr. Did you ever hear Mr. Aguaro ever say that your phone was compromised in any way? Did you ever hear that from him? [00:09:48] Speaker 2: Mr. We never asked him that question. Mr. Okay. [00:09:50] Speaker 1: But he didn't say it, did he? [00:09:51] Speaker 2: Mr. The question was never asked. Mr. Right. [00:09:53] Speaker 1: He looked at your data, he prepared a report and alerted no one to any problems with your phone, correct? [00:09:59] Speaker 2: Mr. I don't know. [00:10:00] Speaker 3: Mr. I object to, he was not called upon to review the phone. He reviewed the Celebrite extraction from the phone, so I object to just finding questions. [00:10:09] Speaker 1: Mr. We can move on. You heard from Matt Hobanix from the DFL department. He testified that there weren't any issues with this phone, correct? When he looked at data that came from it, correct? [00:10:22] Speaker 2: Mr. He said that, you know, I guess they try not to modify contents of things, but he didn't say that it was impossible. [00:10:29] Speaker 1: Mr. Okay. Here, we can do this too. You got up on direct examination and you went through message by message by message and you didn't complain about any of the messages that were on September 2nd, correct? [00:10:41] Speaker 2: Mr. I dispute. [00:10:42] Speaker 1: Mr. I objected to complain. [00:10:43] Speaker 4: Mr. Sure. [00:10:45] Speaker 1: You offered testimony to this jury about the timeline, correct? Mr. Yes. You went text by text and phone call by phone call and you explained things, right? Mr. Right. Mr. At no point did you say, oh, there's a problem here, correct? Mr. Correct. Mr. You had no problem with that information, did you? Mr. Right. Mr. Okay. Mr. Sir, do you find it a little bit strange that when you find information that's helpful to you in your phone, you don't think there's a problem with it, but when there's damaging evidence in your phone, you believe maybe it's been hacked or compromised? [00:11:19] Speaker 2: Mr. I do think that if someone was trying to frame me that obviously they would leave the content that I made on the phone as well as whatever they decided to put on there. Yes. [00:11:28] Speaker 1: Mr. Okay. Mr. And as we see here, like there's one, two, three, four, five, six, seven, seven different houses are being photographed, correct? [00:11:41] Speaker 2: Mr. If that is truly what was on my phone, then supposedly sure. [00:11:45] Speaker 1: Mr. Okay. Here's a good example. In this image, there's a security camera being focused on in the image, correct? [00:11:55] Speaker 2: Mr. That's what it appears to be, which -- Mr. You -- Mr. -- brings up a question that I would have. [00:12:00] Speaker 1: Mr. There's no question pending, and you're going to get a chance on redirect. You'll be able to say whatever you need to say. But let's be clear, there's an image that isolates on a security camera for the next door neighbor, Mr. Gehrman, and it's right there, isn't it? [00:12:17] Speaker 2: Mr. Yeah, it is. There's one right there. [00:12:22] Speaker 1: Mr. And here is something I remember you told me about. Mr. When you started out, what was your first job again? [00:12:28] Speaker 2: Mr. Um, IT. [00:12:30] Speaker 1: Mr. IT. Mr. Hmm? Mr. You've got a technical background, correct? Mr. Right. Mr. I believe even on direct examination, you described yourself as a techie, correct? [00:12:38] Speaker 2: Mr. Absolutely, yes. [00:12:39] Speaker 1: Mr. So you know your way around a computer, right? Mr. Right. Mr. Fair to say you know your way around different software, correct? [00:12:45] Speaker 2: Mr. Right. [00:12:46] Speaker 1: Mr. Fair to say you know your way around a cell phone, right? Mr. Right. Mr. You certainly know how to use Google Maps, right? Mr. I think a lot of people do. [00:12:52] Speaker 2: Mr. Right. [00:12:53] Speaker 1: Mr. Anyone could use that, correct? Mr. Right. Mr. And you would consider yourself a fairly thorough person in your work as a public administrator, right? [00:13:00] Speaker 2: Mr. More thorough than to do something like this, sure. [00:13:03] Speaker 1: Mr. You consider yourself detail-oriented? [00:13:05] Speaker 2: Mr. I do. [00:13:06] Speaker 1: Mr. Okay. Mr. Can we cue over for one second to the overhead? Mr. There's over 132 images in your phone focusing on that. Mr. Would you say that's a lot of detail? [00:13:24] Speaker 2: Mr. If that was on my phone, I guess I would say yes. [00:13:28] Speaker 1: Mr. Okay. Mr. And then let's talk about the Popeyes thing, Publishing 364. Mr. Do you remember these images? Mr. Yes. [00:13:51] Speaker 2: Mr. Okay. Mr. I remember them being presented as being allegedly on my phone. Mr. Right. [00:13:58] Speaker ?: Mr. Right. [00:13:59] Speaker 1: Mr. The testimony was it was on your phone. Mr. You just don't believe you had anything to do with it, correct? [00:14:04] Speaker 2: Mr. Again, I don't know that they were ever on my phone. Mr. I know that I did not take those photos. [00:14:08] Speaker 1: Mr. Okay. Mr. So you're just denying what you heard? [00:14:10] Speaker 2: Mr. I am saying that whatever the testimony is that it could have been placed on my phone or who knows? [00:14:16] Speaker 1: Mr. The testimony was it was found on your phone, correct? [00:14:20] Speaker 2: Mr. It was allegedly found on an image of my phone. Mr. Okay. [00:14:23] Speaker 1: Mr. Okay. Mr. If we could cue over to the over head or the computer. Mr. We talked about being detailed oriented. Mr. You would agree this is numerous images from the same spot, correct? [00:14:53] Speaker 2: Mr. It appears so. [00:14:55] Speaker 1: Mr. And if we kind of look and I just can't see because of the monitor. I mean we're looking at that's a sedan, correct? [00:15:01] Speaker 2: Mr. Yes. [00:15:02] Speaker 1: Mr. Sedan, correct. Well, it's like a minivan but it's gray in color, right? [00:15:05] Speaker 2: Mr. It's like a crossover. Mr. And that's gray in color, right? [00:15:07] Speaker 1: Mr. Sure. Mr. And that's a truck that's kind of a whitish gray, right? [00:15:09] Speaker 2: Mr. Mm-hmm. [00:15:10] Speaker 1: Mr. Another gray car, correct? Mr. Sure. Mr. Another gray sedan, correct? Mr. Mm-hmm. Mr. This one's a Honda, right? Mr. Sure. [00:15:16] Speaker 2: Mr. Or maybe that's not a Honda. [00:15:17] Speaker 1: I don't want to misspeak. That might be a Kia. Mr. It looks like a Honda. Mr. Okay. [00:15:21] Speaker 2: Mr. It's a Honda. [00:15:22] Speaker 1: Mr. I think. Mr. Unless it's a Hyundai. Mr. Or a Hyundai. Mr. I'm not sure. [00:15:26] Speaker 2: It kind of looks like an H. [00:15:27] Speaker 1: We've got an SUV here but there's a lot of images here, correct? Mr. Yes. [00:15:29] Speaker 2: Mr. Okay. [00:15:30] Speaker 1: Mr. Okay. And according to this report, if we could cue over, we've got 101, correct? [00:15:50] Speaker 2: Mr. That's what it alleges. [00:15:53] Speaker 1: Mr. That's fairly -- that's a lot of photos, correct? Mr. It would be. Mr. It looks like surveillance, doesn't it? [00:16:00] Speaker 2: Mr. It looks like a stupid way to do surveillance. Mr. Right. [00:16:04] Speaker 1: It looks kind of amateurish, doesn't it? [00:16:05] Speaker 2: Mr. Right. [00:16:06] Speaker ?: Mr. Not professional. [00:16:07] Speaker 1: Mr. Right. [00:16:08] Speaker 2: I wouldn't think -- I wouldn't see how that makes sense. [00:16:14] Speaker 1: Mr. And then, sir, another thing located in your phone were these. [00:16:27] Speaker ?: Mr. Can we cue over to the overhead? [00:16:28] Speaker 1: Mr. Sir, what are we looking at here? Mr. It looks like it's identification of a vehicle that is owned by Mr. Gurman. [00:16:46] Speaker 2: Mr. It's a Honda, right? Mr. Yes, sir. [00:16:48] Speaker 1: Mr. And we know from the photographs earlier, his Honda is gray, correct? [00:16:58] Speaker 2: Mr. I don't remember -- I wasn't paying attention to the color with the earlier testimony. Sorry. [00:17:05] Speaker 1: Mr. You have no reason to dispute me if I told you that the color of the car was gray, correct? Mr. I don't, sir. [00:17:09] Speaker 2: Mr. Okay. [00:17:10] Speaker 1: Mr. And we saw in those images lots of gray cars were getting snapped, correct? [00:17:15] Speaker 2: Mr. Yeah. Mr. I saw a black one and a white one. Mr. Yes? [00:17:19] Speaker 1: Mr. And you know what that program that's pulling up that information is, don't you, Mr. [00:17:25] Speaker 2: Mr. No? Mr. That I do, yes. [00:17:27] Speaker 1: Mr. That's IDICOR, correct? Mr. Right. Mr. That is proprietary software that is, in fact, used by the public administration's office, correct? Mr. Yes, sir, it is. Mr. It gives the person at the public administration's office the ability to look up personally identifying information about people, correct? [00:17:42] Speaker 2: Mr. Yes. [00:17:43] Speaker 1: Mr. Okay. Mr. And we can see here that Jeffrey Guerin is being looked up on IDICOR, correct? [00:17:49] Speaker 2: Mr. What I remember correctly looking at this was it was looked up by address. [00:17:55] Speaker 1: Mr. Well, that's just one report, sir. Mr. Let's look at this result. Mr. What's the search term? Mr. There's no question pending, sir. Mr. Okay. Mr. Take a look at registrants. Mr. What's the registrant? [00:18:12] Speaker 2: Mr. Again, it's Jeffrey M. Gurman. [00:18:14] Speaker 1: Mr. Right. Mr. And if we look down, what's the first address associated with this? Mr. P.O. Box. [00:18:20] Speaker 2: Mr. Okay. [00:18:21] Speaker 1: Mr. And then we go to the next entry, what's the address associated with Mr. Gurman? [00:18:25] Speaker 2: Mr. 7216, it's the second one related to Mr. Gurman. Mr. Gurman. There's a first one related to Mr. Gurman. That's the P.O. Box, which is current. The second one is 7216 Bronze Circle, Las Vegas, Nevada. Mr. Right. [00:18:40] Speaker 1: Mr. Tell us, that's where Mr. Gurman lived, correct? Mr. Yes, sir. Mr. That's where he was murdered, correct? Mr. Yes, sir. Mr. And this image of his personal information and his home address is located inside your phone. [00:18:55] Speaker 2: Mr. Again, I don't know that it is. [00:18:58] Speaker 1: Mr. Okay. So we're just, again, we don't have to do the dance, but you're just not accepting the testimony that it was located on your phone? Mr. That is correct. [00:19:04] Speaker 2: Mr. Okay. [00:19:05] Speaker 1: All right. But you'd agree with me that from just that bottom there, that looks like a desktop monitor, a Dell desktop monitor, correct? Mr. Correct. [00:19:13] Speaker 2: Mr. And again, this has more information about Mr. Gurman's cars, correct? [00:19:18] Speaker 1: Mr. Yes, sir. Mr. This is IDI core, correct? Mr. Right. Mr. Software that is in your office, correct? [00:19:22] Speaker ?: Mr. In the office that Mr. Jappe visited, yes. [00:19:23] Speaker 2: Mr. Okay. Mr. This is more, this is again, this is more IDI core images, correct? [00:19:25] Speaker 1: Mr. Right. Mr. It appears so, yes, sir. Mr. Let me just come out and ask you, this is your desk, isn't it? Mr. Okay. Mr. Yes, sir. [00:19:30] Speaker 2: Mr. It probably is. Mr. Yeah. Mr. Okay. [00:19:33] Speaker 1: Mr. Yes. Mr. Okay. Mr. Okay. Mr. Okay. Mr. Okay. Mr. Okay. Mr. This is more, this is again, this is more IDI core images, correct? [00:19:42] Speaker 2: Mr. It appears so, yes, sir. [00:19:43] Speaker 1: Mr. Let me just come out and ask you, this is your desk, isn't it? [00:19:48] Speaker 2: Mr. It probably is. [00:19:50] Speaker ?: Mr. Yeah. Mr. Okay. Mr. Okay. [00:19:53] Speaker 1: Mr. Let me ask you this, during your official duties as the public administrator, I mean, you didn't have like a case with Mr. Gehrman at all, right? Mr. No, sir, I didn't. [00:20:13] Speaker 2: Mr. Okay. Mr. Okay. Mr. What was the search term to find that? [00:20:21] Speaker 1: Mr. Well, one of the search terms was 7216 bronze circle, correct? [00:20:26] Speaker 2: Mr. Can you show that to me? [00:20:28] Speaker 1: Mr. Sure. Mr. 7216 bronze. Mr. We can cue over to the overhead. [00:20:40] Speaker ?: Mr. All right. [00:20:45] Speaker 2: Mr. Can everybody see that? [00:20:48] Speaker 1: Oh, it's much better over here. It was terrible. So you can see that, right? Mr. Yes, sir, I can. Mr. And the date, the created time is 8:23, 2022 at 6:05 PM, correct? Mr. Yes. [00:21:01] Speaker 2: That's what it reports to be. [00:21:02] Speaker 1: Mr. Okay. And that was a weekday, wasn't it? [00:21:08] Speaker 2: Mr. I'm sure it was, because, you know. [00:21:12] Speaker 1: Mr. And there's one more thing. Mr. Okay. This wasn't converted into UTC time. So if we subtract 7 hours, that's at 11:05 AM in the morning on 8:23, correct? [00:21:24] Speaker 2: Mr. Again, I don't know if this document has been modified by a PDF viewer or not, but it purports to be of that day. [00:21:32] Speaker 1: Mr. Do you recall the testimony -- well, no. Mr. You recall the testimony of Matt Havanich, which said this was not converted, and when you convert it, this search was conducted at 11:00 in the morning, correct? Mr. Do you recall him saying -- I'm not asking if you agree with it, but do you recall it being said? [00:21:48] Speaker 2: Mr. I know that I didn't do the search, so I couldn't tell you definitively. [00:21:51] Speaker 1: Mr. So I'd like you to focus on my question. Do you recall Mr. Havanich saying that here in court? [00:21:57] Speaker 2: Mr. That's what he said. [00:21:59] Speaker 1: Mr. Okay. And just to be clear, Publishing 351 -- there it is. That's a weekday. That's a Tuesday, correct? Mr. Yes, sir. Mr. Did you typically have random people coming into your office using your desktop software? [00:22:17] Speaker 2: Mr. Again, that could have been modified many -- in a number of ways. Mr. In a number of ways, sir. [00:22:23] Speaker 1: Mr. That's not my question. My question is, as the public administrator, did you allow people to go back to the office? Mr. In the middle of the day and manipulate and use your computer? [00:22:33] Speaker 2: Mr. I didn't allow, but that's not to say that it didn't happen, sir. [00:22:37] Speaker 1: Mr. So the answer is, you had an edict that said you're not allowed to do this, correct? [00:22:41] Speaker 2: Mr. But if I wasn't around or whatever, I don't know. Mr. Okay. [00:22:46] Speaker 1: I mean, you would hope as the head of the department, they would have at least not used your computer, right? [00:22:51] Speaker 2: Mr. I would have hoped, but you'd be surprised what happened in that office. Mr. Okay. [00:22:54] Speaker 1: Mr. Okay. Mr. Right, because of the conspiracy? Mr. Right. Mr. Okay. Mr. Isn't it true? Mr. I think we've heard from both your expert and Detective Jappy that there was no outgoing messages from your phone between 8:48 a.m. and 2:05 p.m., correct? Mr. Correct. Mr. Okay. Mr. You mentioned or at least we've kind of heard this comment about maybe I was hacked. Just to be clear, you never reported to anyone that your phone was hacked prior to September 2nd, correct? [00:23:48] Speaker 2: Mr. I wouldn't have known about it because there didn't seem to be anything wrong with the phone [00:23:52] Speaker 1: this time. Mr. So the answer is you've never reported any situation that you've been hacked, correct? [00:23:57] Speaker 2: Mr. I didn't have knowledge of whether it had been or not. [00:24:00] Speaker 1: Mr. You've never reported that your phone was stolen, correct, prior to 9:02? [00:24:03] Speaker 2: Mr. That definitely did not happen. [00:24:05] Speaker 1: Mr. Okay. Mr. You never reported that your house was broken into prior to 9:02, correct? Mr. I did not. [00:24:10] Speaker ?: Mr. Nope. [00:24:11] Speaker 1: Mr. And there aren't any text messages on your phone complaining about being hacked, right? [00:24:16] Speaker 2: Mr. Again, if I was hacked, I might not have known it. [00:24:19] Speaker 1: Mr. Well, and sometimes when we notice we've been hacked, some people will send out emails to people like, "Oh, ignore this email. I've been hacked," things like that, right? [00:24:26] Speaker 2: Mr. There are various types of hacks, sir. [00:24:28] Speaker 1: Mr. Right, right. But there's nothing like that on your phone either, correct? [00:24:31] Speaker 2: Mr. No, and again, that doesn't necessarily mean it wasn't hacked or that somebody didn't create a false image later or add files to that image later. [00:24:39] Speaker 1: Mr. Okay. So, sir, I want to now talk to you about this conspiracy a little bit. Is Rita Reed in the conspiracy? [00:24:45] Speaker 2: Mr. Well, she certainly took money from Compass Realty and Adam Fenn. [00:24:48] Speaker 1: Mr. So the answer is she conspired to murder Jeff Gehrman? [00:24:52] Speaker 2: Mr. I don't know to what extent she had knowledge of anything other than to make sure that I got taken down. [00:24:57] Speaker 1: Mr. Taken down. So she conspired to have you framed for the murder of Jeff Gehrman? [00:25:01] Speaker 2: Mr. I don't know that she was privy to that particular part of -- [00:25:04] Speaker 1: Mr. So she's not part of the conspiracy? Mr. I can't say either way, sir. Mr. Okay. So you're not tying her to this? [00:25:10] Speaker 2: Mr. I don't have any evidence to tie her to this. Mr. Can we rule her out? [00:25:13] Speaker 1: Mr. Sir, go ahead, please finish. [00:25:18] Speaker 2: Mr. What was the question at this point? [00:25:22] Speaker 1: Mr. Okay, I'll ask the question again. Mr. Can we rule Rita Reed out of your conspiracy to murder Jeff Gehrman? [00:25:28] Speaker 2: Mr. I think it's weird that you're -- I mean, maybe it's not weird. Obviously, you've got to try to minimize the concern that I have with this and try to make me seem like I'm crazy for it. Mr. But there's the evidence to back up what has been occurring. So that is what it is, sir. [00:25:42] Speaker 1: Mr. Okay, so let's focus on my question. Can we rule out -- Mr. I don't know that we can either way, sir. [00:25:48] Speaker 2: Mr. Okay. [00:25:49] Speaker 1: So it's possible she's part of it? [00:25:51] Speaker 2: Mr. I would be surprised, but I couldn't rule it out. Mr. Okay. So it's possible? [00:25:56] Speaker 1: Mr. Anything is possible. Mr. Okay. Mr. Alicia Goodwin, is she part of this conspiracy? [00:26:01] Speaker 2: Mr. Again, part of the conspiracy, sure. [00:26:05] Speaker 1: Mr. Let me specify, is she part of the conspiracy to murder Jeff Gehrman? [00:26:11] Speaker 2: Mr. I would think it's unlikely. Mr. Okay. [00:26:14] Speaker 1: So we can rule her out? [00:26:15] Speaker 2: Mr. I mean, again, I couldn't rule anything out, but certainly I think it's unlikely. [00:26:19] Speaker 1: Mr. So it's possible? [00:26:20] Speaker 2: Mr. Again, anything is possible. [00:26:22] Speaker 1: Mr. Okay. So we can't rule her out because anything is possible. [00:26:25] Speaker 2: Mr. That's what I said. I said unlikely, but, you know -- Mr. Okay. [00:26:29] Speaker 1: Mr. Understood. How about Mr. Cahill? Mr. Cahill, is he part of the conspiracy to kill Jeff Gehrman? Mr. Again, highly unlikely, but I -- [00:26:39] Speaker 2: Mr. You're not ruling it out? Mr. Without further evidence, I cannot rule it out, sir. Mr. Okay. [00:26:45] Speaker 1: So it's possible? [00:26:46] Speaker 2: Mr. Again, anything is possible, sir. [00:26:48] Speaker 1: Mr. Is Thomas Monroe, who's part of Compass Realty, I believe? Mr. Is he part of this conspiracy to murder Jeff Gehrman? Mr. Thomas Moore? [00:26:56] Speaker 2: Mr. Thomas -- I apologize. [00:26:57] Speaker 1: Mr. Thomas Moore, is he part of this? Mr. I would think that would be likely, yes. [00:27:00] Speaker 2: Mr. Okay, likely. Mr. Okay. [00:27:02] Speaker 1: And Compass Realty as a business as a whole is part of this as well, to kill Mr. Gehrman, correct? [00:27:08] Speaker 2: Mr. Again, if you recall, the best way to take me down would be to frame me for Mr. Gehrman's murder. And so, you know, yes, I do believe that. [00:27:20] Speaker 1: Mr. And I want to write that down. Mr. You said the best way to take me out is to frame you for killing Gehrman, right? Mr. Yes, sir. Mr. I'm paraphrasing. But essentially, that's it. Mr. Absolutely. Mr. Okay. You would agree, and I think you told this jury extensively on direct examination. What a thorn you were in the side of Compass Realty, correct? Mr. It was, yes. Mr. You fought them at every turn, correct? Mr. Absolutely. Mr. You thought what they were doing was improper, correct? [00:27:51] Speaker 2: Mr. I think I proved that. [00:27:53] Speaker 1: Mr. Okay. You thought that so much of their wrongdoing that you actually went to the police about it, correct? [00:27:59] Speaker 2: Mr. Yes, sir. [00:28:00] Speaker 1: Mr. And you were, until the moment that you were stopped working in that office, you fought against Compass Realty, correct? [00:28:05] Speaker 2: Mr. I believe when that order was entered on August 30th, that shows that, absolutely. [00:28:10] Speaker 1: Mr. And the issue for Compass Realty is because you were the public administrator, correct? Mr. Right. Mr. You stood in their way from doing the things that they wanted to do in terms of independent administrators. Is that right? [00:28:25] Speaker 2: Mr. Yes, sir. Mr. And in fact, again, that order was going to allow me to dig into them and actually prove, without a doubt, that Detective Jaffe was just ignoring criminal conduct, sir. Mr. Yes. [00:28:35] Speaker 1: Mr. So here's the thing, though. Mr. You said that they did something else. They also donated somebody. Who did they donate to? [00:28:44] Speaker 2: Mr. That's Reed Reed. [00:28:45] Speaker 1: Mr. How much money did they donate? Mr. $10,000. Mr. So they thought -- and let me get this straight. In your opinion, the things that they were doing cost in the millions. Is that right? [00:28:56] Speaker 2: Mr. Absolutely. [00:28:57] Speaker 1: Mr. This is a million-dollar scheme that they're running, correct? Mr. Mm-hmm. Mr. And all they could muster to fund an opponent was $10,000? Mr. No. [00:29:05] Speaker 2: Mr. Oh, campaign laws prohibit anything over $10,000. [00:29:08] Speaker 1: Mr. Aha. Mr. So did any other independent employees of Compass Realty shell out money for Rita? [00:29:14] Speaker 2: Mr. So there's, again, Adam Fenn and also -- Mr. How much? Mr. Compass Realty. Mr. How much? Mr. Five grand each. And so, you know, that's all that they needed in order to -- [00:29:22] Speaker 1: Mr. So if I'm hearing you correctly, you have described yourself as the sole impediment Mr. For their multimillion-dollar scheme and the only thing that they could come up with financially to stop you is just $10,000? Mr. No, sir. Mr. Okay. Mr. That's -- your C&Es that you submitted, that's all we have, right? It's like 10 grand. [00:29:43] Speaker 2: Mr. That's 10 grand on our campaign contribution report. Mr. Right. Mr. That is not all the money that they've given to anybody to, again, to engage in this activity. [00:29:51] Speaker 1: Mr. Are you speculating at this point? Mr. I'm going to ask if you're allowed to answer the question. Mr. Okay. Mr. Please finish the question. [00:29:57] Speaker 2: Mr. So, again, without being able to firsthand investigate because Mr. German was murdered and I had been arrested and been sitting in jail for two years, you know, yeah, perhaps I'm speculating, but if I'd had that authority like I intended, you know, I would have uncovered the various different ways that they actually tried to, you know, thwart me, all the attorney's fees that they paid in order to pay these attorneys who would -- again, this was an escalating situation that started -- Mr. Right. Mr. Go on. [00:30:27] Speaker 1: Mr. I mean, I think we're a little far afield of my question at this point. Mr. Sure. Mr. I don't know if that was as responsive to my question. So, let me direct you back to it. You would agree like $10,000 is really not that much money. In the world of county-wide races, 10 grand, not that much, correct? [00:30:43] Speaker 2: Mr. In the world of county races, it's the maximum contributions for these two guys or these two entities but -- [00:30:49] Speaker 1: Mr. Those two guys, but listen, if we're talking about -- look, you know how politics works. If there are businesses or special interests, they pool their money together behind a candidate, right? Mr. You don't know that, but you were -- Mr. It depends on the situation. It depends on the situation. Mr. Sir, are you going to sit here and tell this jury you've run for political office twice, and you don't know that businesses or special interests pool their money together to back a candidate they really want? Are you really telling them that? [00:31:22] Speaker 2: Mr. Again, I don't have first-hand knowledge of that because I don't -- I've never had that happen for me. Mr. Right. Mr. Now, if you're talking about political action committees, I don't know, what do you -- [00:31:32] Speaker 1: Mr. Look, the bottom line is, all they donated was 10 grand, correct? [00:31:36] Speaker 2: Mr. I think that's a mischaracterization of what they've done. Mr. Fine. [00:31:40] Speaker 1: Mr. Let's move on. Mr. And then here's the crazy part: they won, right? [00:31:45] Speaker 2: Mr. And I still kept fighting them, yes. [00:31:47] Speaker 1: Mr. No, no. Mr. Sir, you were a lame duck as of September 2, 2022. Isn't that right? [00:31:54] Speaker 2: Mr. But I still continue to fight Compass Realty. [00:31:56] Speaker 1: Mr. That's not my question. You're out of a job in that -- you're not an impediment as of January 1st. Isn't that right? [00:32:03] Speaker 2: Mr. As of January 1st, but I was right then. [00:32:05] Speaker 1: Mr. So you're trying to tell us that Compass Realty was so upset with you, that they backed a candidate -- a candidate who wins, but then they just can't wait any longer, so they murder a reporter? They can't wait but three months? [00:32:19] Speaker 2: Mr. I would recommend that the jury watch the video and, again, see the time at which the order was filed. And I think you might agree that, yes, that is absolutely the case, sir. [00:32:28] Speaker 1: Mr. So the answer to my question is, yes. Mr. That -- Mr. Compass Realty, even though they successfully backed a candidate that defeated you in a primary, they couldn't wait another three months for you to leave office, correct? [00:32:42] Speaker 2: Mr. Because I've got the authority to really crack things open right then. Mr. So you're -- [00:32:47] Speaker 3: Mr. He's answering the question. [00:32:48] Speaker 1: These are fairly complex questions. Mr. I'm not sure that each of you lets the answer -- Mr. Sir, are you finished? Mr. No, sir. [00:32:52] Speaker 3: Mr. Okay. Mr. So then my next question is this. [00:32:54] Speaker 1: If they hated you so much -- [00:32:55] Speaker 2: Mr. I don't think they knew me to hate me, but sure. Mr. Well, I mean, they're willing to kill people over you, right? [00:32:57] Speaker 1: Mr. I guess they would have hated me, yeah. Mr. Right. And if they hated you so much, why didn't they just kill you? Mr. That's a really good question. And I would like to answer it. [00:33:02] Speaker 2: Mr. My belief as to why they didn't -- Mr. Please tell me why they didn't just bother killing you. Mr. So -- [00:33:05] Speaker 1: Mr. Because if they had killed me, would that have stopped you? Mr. Please tell me why they didn't just bother killing you. Mr. Because if they had killed me, would that have stopped you? I guess they would have hated me, yeah. Right. And if they hated you so much, why didn't they just kill you? [00:33:13] Speaker 2: That's a really good question and I would like to answer it. My belief as to why they didn't. Please tell me why they didn't just bother killing you. Because if they'd killed me, would that have stopped the Nevada State Division from investigating them? No. If they killed me, would anybody have felt the duty to continue my work because I was actually doing this? I think so. So murdering me would have not discredited me. It would not have put me in a position where all the work that I was doing just got left by the wayside. It would make no sense to kill me. [00:33:42] Speaker 1: So your theory is that Jeff Gehrman is collateral damage? [00:33:47] Speaker 2: You know, when you've taken into account the fact that months earlier we had this public feud, it's a pretty convenient way to do this. [00:33:53] Speaker 1: So the guy who writes the articles that ends your career, they reward him by killing him? [00:34:00] Speaker 2: Well, again, like I said, it was a pretty good way to do this. [00:34:04] Speaker 1: And let's not get it twisted. Rita and Alicia are part of the conspiracy that loop in Jeff Gehrman. And they're in cahoots with Compass. So they're like, you know what? Thanks, Jeff. But you got to go? That's what you're suggesting? [00:34:16] Speaker 2: And like I said, I don't know that they knew about that particular aspect of the conspiracy, sir. Okay. I mean, I would certainly think that they wouldn't. Because you're right. I can't imagine that they would know and be okay with that, sir. [00:34:30] Speaker 1: Isn't it also true that Roberta testified that once you lost, Rita Reed was actually reversing the things that you did in the office, right? That would be her prerogative at that point. Okay. So changes were even afoot before you had even left office, correct? Sure. And you even told us that once Rita took over, nothing came of the things that you wanted to do, like none of the things that you want to investigate were ever done, right? [00:35:02] Speaker 2: I was talking about the fact that I had this investigative authority against Compass Realty that I had just gotten just a few days before Mr. Grimm was murdered, and she never picked up that torch and ran with it. And it's clear why she didn't, because Compass Realty gave her that money, despite the fact that as you saw, sir, you know, these homes, millions of dollars in theft, sir. [00:35:24] Speaker 1: So the answer to my question is, yes, Rita Reed never followed through with the things that you, the authority that you had, correct? [00:35:32] Speaker 2: Regarding Compass Realty, yes, sir. [00:35:34] Speaker 1: Thank you. And just to be clear, she was going to have full authority as of January, right? Yes, sir. And the authority could have gotten Thomas in trouble, but that risk was eliminated once they put Rita in, according to your theory, right? [00:35:50] Speaker 2: Once, no, again, once she actually became the public administrator, that would be the case. But while I was still, as you call it, a lame duck, I was still coming after them, sir. [00:35:59] Speaker 1: Okay. So your suggestion is, your thought is murder was the only right. [00:36:04] Speaker 2: There might have been other ways, but it was a, again, if they didn't do it, they sure had a windfall for it that they didn't expect. [00:36:11] Speaker 1: So how did Compass break into your home to plant this evidence? [00:36:16] Speaker 2: Again, like I said before, I don't know how it got in there, but I did not put it there, sir. [00:36:20] Speaker 1: How did they plant the hat? [00:36:21] Speaker 2: Again, I don't know how it got there, but I didn't put it there. [00:36:24] Speaker 1: How did they plant the shoes? [00:36:26] Speaker 2: I don't know how it got under the couch, but I did not put it there. [00:36:29] Speaker 1: How did they get your DNA in there? [00:36:31] Speaker 2: Again, I don't know when and where that DNA was allegedly obtained, so I couldn't say, sir. [00:36:37] Speaker 1: How did they put the images in your phone? [00:36:39] Speaker 2: Again, I don't know if that was in my phone or on a corrupt image or what have you. Again, you cannot say when or where any of this occurred, really. [00:36:51] Speaker 1: And again, when they executed this warrant, the police, they did that also in the presence of your wife, correct? [00:36:59] Speaker 2: Not exactly, sir. If I may. [00:37:02] Speaker 1: So the answer to my question is no? [00:37:04] Speaker 2: Not all of them did. Okay. [00:37:07] Speaker 1: No question pending. I appreciate it. You'll have a chance on redirect. Okay. So let's start focusing on May of 2012 or May of 2022. Sorry about that. Fair to say that the dynamics in the office aren't great at that point. [00:37:37] Speaker 2: That's correct, sir. [00:37:39] Speaker 1: Rita and the old guard are unhappy with you and the new guard. Would that be correct? [00:37:44] Speaker 2: Yeah. Yeah. [00:37:46] Speaker 1: Sure. And the members of the new guard included you, Roberta and Nicole. Would that be accurate? [00:37:51] Speaker 2: That was just some of us. [00:37:53] Speaker 1: Okay. There were a couple others? [00:37:55] Speaker 2: I believe there were actually 10 folks. And after Jay retired, it was just four old guards, as has been stated. So six of us who are -- that didn't include me either. So I guess it would be seven of us versus the four people who had gotten there before I did. Okay. [00:38:17] Speaker 1: So you agreed to do a sit-down interview on May 11th of 2022 with Jeff Gehrman, correct? [00:38:26] Speaker 2: Yes, sir. [00:38:27] Speaker 1: Why did you agree to do this interview? [00:38:29] Speaker 2: Because I wanted to dispel the notion that, you know, there was any concern. [00:38:34] Speaker 1: You were being accused of a series of things, including creating emotional stress on your employees, correct? Right. Bullying? [00:38:43] Speaker 2: Right. [00:38:44] Speaker 1: And engaging in an inappropriate relationship, correct? [00:38:46] Speaker 2: Right. [00:38:47] Speaker 1: Okay. When you sat down to do this interview, did you want to get the truth out? [00:38:52] Speaker 2: To a certain extent, yes, but when it came to the office issues, yes, sir. [00:38:58] Speaker 1: Okay. When you sat down, when you spoke with him, were you truthful in your interview? [00:39:04] Speaker 2: Not entirely, no. [00:39:05] Speaker 1: Okay. What were you untruthful about? [00:39:07] Speaker 2: About the extent of the relationship with me and Roberta Lee Kennett. Okay. [00:39:11] Speaker 1: What was different? What did you say versus the truth? [00:39:14] Speaker 2: I said that, you know, she and I had no affair but, you know, regrettably we did have, you know, when I say regrettably I think we both regret the mistake but we both had a romantic affair with each other. [00:39:30] Speaker 1: Okay. So you did lie to him, correct, on that topic? [00:39:34] Speaker 2: I didn't think that that was the public's business. [00:39:37] Speaker 1: That's not my question. My question is -- [00:39:39] Speaker 2: I did lie regarding that particular issue, yes. [00:39:42] Speaker ?: Okay. [00:39:43] Speaker 1: Okay. Now, you would agree with me, at the moment you sat down for that interview, you were in the throngs of a reelection campaign, correct? Yes, sir. It would be -- you would agree with me that the public administration job was something very important to you. [00:40:00] Speaker 2: I mean, sure, yes. You know, obviously, again, you know, it was important at the time, yes. [00:40:06] Speaker 1: I mean, well, listen, you know, you told us a little bit about your story, I mean, right? I mean, you put yourself through law school, you opened up a law firm, you were elected to this job. I mean, you were proud of the work you were doing at the PA's office, correct? I absolutely was. Okay. And you wanted to remain in that job, correct? I certainly did. [00:40:25] Speaker 2: Okay. [00:40:26] Speaker 1: Okay. And you would agree with me that if you had been entirely truthful, that may not have developed your election prospects. Would that be correct? [00:40:37] Speaker 2: That was certainly not the sole motivation for lying. [00:40:40] Speaker 1: And I understand that. But that is a factor, correct? [00:40:44] Speaker 2: I don't know. Again, I don't know that I necessarily considered that to be the primary factor or honestly consider it to be a factor at all. My main concern was having any embarrassment or any, you know, for both of our families, you know, that kind of thing. [00:40:59] Speaker 1: And listen, that's totally fair, right? You're concerned about your family. Maybe you're concerned about Roberta's family. Understood. And that for you is the main reason why you're not being truthful about that. Right. Okay. So, you sit down. Did you feel after speaking with him that you thought Gehrman would give you a fair shake? [00:41:20] Speaker 2: I did. I thought we had a pretty good conversation. I walked outside with him. I told them more about a lot of the issues that had occurred at the office before I got there and about the way that, well, the strange things that had happened. I won't get into it. But yes, I thought by the time we were done that, you know, that he understood what was really going on at the office. [00:41:43] Speaker 1: Okay. And then, when he - sorry, excuse me, one second - when that was published, you were very upset, correct? Yeah. [00:41:58] Speaker 2: I was shocked at, you know, what ended up coming out versus what we had discussed. Yes, sir. Were you devastated? I don't know if I - I'm not sure, you know. That I've ever, you know, considered myself devastated on anything. I was certainly upset. I was, you know, hurt for, you know, that this came out. But that was that day. That was that day. Sure. [00:42:29] Speaker 1: And on that day - and let's just be clear, because not only does it potentially jeopardize your work, but it poses - jeopardizes potentially the family stability. Fair? [00:42:39] Speaker 2: In a sense, yes, my wife did forgive me. But, you know, it certainly - it wasn't good optically for, you know, obviously my children and, you know, have them teased by other kids or what have you. So, from that respect, it was a little hard on them. [00:42:57] Speaker 1: And here's the thing. He didn't have to write it the way he did, but he chose to do so, correct? [00:43:05] Speaker 2: Certainly, yes. [00:43:08] Speaker 1: And you told him - you talked to him about how upset you were when you saw - I'm assuming an advanced copy of it, or at least before. [00:43:17] Speaker 2: No, I believe it was actually after it was released. I think people have been misstating the date of the article, because I think my text was after. I don't know if it got republished and the date changed or what have you. [00:43:27] Speaker 1: Yeah. So, like, if we publish 355 - sorry, 353A, we can see here - the date on this is May 16th, correct? Okay. I would agree sometimes what happens is, like, the RJ will throw up an article online at night, and so maybe it's the night before, and then maybe in a publication it's for the next day, something along this line. Right, right. Okay. So, because your text messages with Mr. Gehrman reacting to this actually happened on the 15th. Isn't that right? Right, sir. Okay. So, I want to talk about that if we could. If we could cue over. Now, on direct, you said it was a bummer, right? Or was that the election loss? I can't remember. I don't - which was the bummer? [00:44:12] Speaker 2: I think the - I mean, and maybe - I can't remember what was a bummer, per se. The articles certainly were not - I wasn't happy about them. But, yeah. [00:44:25] Speaker 1: Well, let's turn - let's turn to this message. It's on page four. Mm-hmm. And you state, "I don't know what to say. I told you about how much this has all impacted me. You heard from employees who were being harassed by these people. Provided you proof." I'm assuming that's proof, correct? It says prove. It's a typo. [00:44:47] Speaker 2: It might have auto-corrected and - yeah. [00:44:49] Speaker 1: Understood. Provided you proof that I was doing my best to actually smooth things over after I had to make hard decisions. Still, you wrote an article that makes me sound like I'm the guilty one. That was not fair or balanced, correct? Yes, sir. I wrote that. You were very, very upset when you wrote that. [00:45:03] Speaker 2: Yeah. And I guess it says I'm very distraught right now. Clearly there are typos in my message. [00:45:07] Speaker 1: And you held him responsible because he was the one who chose to write the words, correct? Again, at the time I was upset. So the answer to my question is yes. You held Mr. Gehrman responsible because he chose to write this article in this particular way. [00:45:22] Speaker 2: If I had to hold anyone responsible in any sense, I guess the context that you're saying, I mean certainly not enough to murder him. [00:45:32] Speaker 1: That wasn't my question. [00:45:33] Speaker 2: Okay. I guess I'm trying to get a sense of what the wordplay is here. [00:45:38] Speaker 1: Well, it's not wordplay. You held him responsible. He chose to write it that particular way, right? [00:45:44] Speaker 2: On that day, I felt that, again, he would totally misconstrue things. So I was upset with him and I told him I was upset with him. Okay. [00:45:54] Speaker 1: So that's how you were feeling on May 15th, correct? Correct. Mm-hmm. And you even say I've done so much for that office. I told you I've been followed and that I caught Rita following me. You decided to take it on her word that she wasn't, however clearly she was. It seems to me you valued sensationalism or the value of a potential takedown than actually telling the truth. Thank you for helping him drop more pressure on my life. Yeah. [00:46:19] Speaker 2: And I think that was a typo with the him. It was probably a them instead. [00:46:23] Speaker 1: Understood. Yeah. So, I mean, you described this probably as a hit piece. Would that be correct? [00:46:30] Speaker 2: Honestly, yes. [00:46:32] Speaker 1: Character assassination, correct? Yes. And he's the one who chose it to write it that way, correct? Correct. [00:46:38] Speaker 2: Correct. [00:46:39] Speaker 1: And then what happens is about nine days go by and he reaches out to you again, correct? [00:47:03] Speaker 2: Yes, sir. [00:47:04] Speaker 1: Now, the primary election was held on June 14th, correct? [00:47:07] Speaker 2: I don't recall, but you're probably right. [00:47:11] Speaker 1: Okay. So, we have one article that gets into not just the inner organs of the office, but it's hitting you on personal stuff. And now he's reaching out to try to do another article. Right? Right, sir. Fair to say you've got to be upset. [00:47:27] Speaker 2: It wasn't -- I don't know if at this point I was still upset. I couldn't remember. I know that I had to, at a certain point, like, start to try to, like, basically combat this with my own narrative to try to, again, win the race. [00:47:45] Speaker 1: Right. You're so concerned about Jeff Garren's articles that you start literally creating websites to try to fight against it, correct? I wanted the truth to come out, yeah. [00:47:54] Speaker 2: Right. [00:47:55] Speaker 1: That's how significant the article was to you. [00:47:58] Speaker 2: In the sense that I wanted to win the race and I needed to dispel what was in the articles, yes, sir. [00:48:05] Speaker 1: You must have felt that this guy is just personally out to get you at this point. [00:48:10] Speaker 2: Not personally out to get me. I thought he was a friend of John Cahill's. Okay. Later I found out that Alicia Goodwin's father was a friend of his. [00:48:21] Speaker 1: That must have been infuriating. [00:48:23] Speaker 2: I mean, it is what it is. You know, like I said, by the time, about a month later, I think you see my tweets. I'm more just trying to... [00:48:32] Speaker 1: We'll talk about different things over time that we see from you. But moving on, you end up providing a written statement, correct? Yes, sir. I imagine you're hopeful that you're going to get more of a balanced article from him, correct? No, sir. [00:48:48] Speaker 2: Okay. [00:48:49] Speaker 1: You're just hoping he'll just publish something, correct? [00:48:51] Speaker 2: I'm just hoping that it wouldn't be too bad because I had already figured by this point, it's like, well, you know what? He's going to do what he's going to do. [00:48:56] Speaker 1: But it was pretty bad, wasn't it? [00:48:58] Speaker 2: Again, that's... It's the same stuff, right? He's trashing you, correct? [00:49:01] Speaker 1: But there's a certain point in which you kind of get desensitized to things. [00:49:06] Speaker 2: Sure. Right? So by the time the fourth article came out, I was like, oh, whatever. Right? I will say that when it comes... Sir, only objection. [00:49:14] Speaker 1: He's answering the question. [00:49:15] Speaker 2: He's answering the question. I know, but sir, the witness is not responsive to the question. He's answering the question that's posed and it's a complex question. [00:49:23] Speaker 4: I'm asking him to ask the question again. Okay. [00:49:26] Speaker 1: You're upset because he's trashing you, correct? [00:49:31] Speaker 2: I couldn't say at that time that I was still upset or just trying to fight to win the race. Okay. [00:49:37] Speaker 1: This was not helping your election, was it? [00:49:40] Speaker 2: No, that it certainly wasn't. [00:49:53] Speaker 1: So then we have... Let's do this. Let me back out. [00:50:00] Speaker 2: And... Hold on a second. [00:50:02] Speaker 1: I'd like to now turn to some items that pop up in your phone kind of around this time. So there is this image from May 20th. Mm-hmm. I'm going to publish that. This was found in your phone, correct? Yes, it was, sir. You're not denying that this was something actually in your phone. No, and I can tell you why I did. I'm not asking that question, but the title of this is how to push down negative search results. Correct? [00:50:32] Speaker ?: Correct? Yes, sir. Okay. [00:50:35] Speaker 1: We have these kind of inflammatory tweets that you're tracking where they're talking about [00:50:49] Speaker 2: you, correct? I was not tracking these. These were given to me by Roberta Lee Kennett. [00:50:53] Speaker 1: Okay. So people are sending them to you, right? [00:50:56] Speaker 2: Yes. [00:50:57] Speaker 1: And then you have this message here to Mr. Kinsley. Mm-hmm. And just to be clear, that is a message that is being kind of issued out on the 15th, which would have been like that day that that article came out, right? According -- is that correct? Sure. Because the article is dated -- the original one is dated 5:16, and we had that conversation about it released earlier, right? Right. Right, right. Okay. So let's look and see what you say here. Isn't it true you tell Mr. Kingsley, I'm working to bring the full truth to light. I guess I want to focus on, you know, you're kind of maintaining the same posture that you had with Gehrman, right, about these things -- you know, some things are true, none of this stuff is true, right? [00:51:42] Speaker 2: Well, and again, like I said, I'll point out that I did lie in this message because I did not want to publicly embarrass my family further. Right. [00:51:50] Speaker 1: Right. And to be fair, it's understandable, but so this is something that you -- it is -- the potential impact on your family is so significant, you're even telling people in this context like it's not true because that's an important thing to protect. Fair? [00:52:03] Speaker 2: I don't think that they would have -- my wife would have left me, you know, but certainly I didn't want them to have to go through any embarrassment or any pain. [00:52:15] Speaker 1: Sure. And I want to focus down here at the very bottom because I know you said, oh, I was kind of over it and things like that. Isn't it true you state here you have no idea how hard it's been? You say that, correct? [00:52:27] Speaker 2: That was that same day and that was referring to the troubles that I had with the ladies in the office that no matter what I was doing to try to actually make peace with them, giving them raises, whatever things that -- still, again, I had to be a cheerleader for the other employees while trying to minimize the damage they were doing. [00:52:49] Speaker 1: Okay. You say I'm truly devastated, correct? [00:52:52] Speaker 2: And that it was again on the same day that I texted Mr. German. [00:52:55] Speaker 1: So the answer is yes. Yes. Yep. Isn't it true you also try to reach out to county officials to see if there's anything that they can do to help rein in reader reads behavior? [00:53:16] Speaker ?: That I don't recall. [00:53:17] Speaker 2: I mean if you've got something to show that as long as you know -- Okay. I don't know. All right. So let's -- I did talk to HR about how to best handle disciplinary issues and got their advice and did things appropriately. Okay. [00:53:34] Speaker 1: If that's what you're referring to. I'm just asking. Okay. And so now that brings us to the primary, which is June 14th of 2022. You would agree with me. When that day began, you were hopeful that you were going to win, correct? [00:53:47] Speaker 2: You're always hopeful when you're running for an election. You had gone out. [00:53:50] Speaker 1: You had canvassed neighborhoods, correct? [00:53:52] Speaker 2: Yes, sir. [00:53:53] Speaker 1: And you were expressing to your friends and family that, you know, yeah, I think we're going to pull this out, correct? [00:53:59] Speaker 2: Obviously, you know, you always want to have an optimistic face no matter what. But I wasn't 100% sure that I was going to win or not. [00:54:06] Speaker 1: Okay. But ultimately, you lose. Is that correct? That is correct. And you don't -- you don't place second. You end up placing third. Is that right? [00:54:17] Speaker 2: All three of us were pretty tight, though. [00:54:19] Speaker 1: But yes. Right. And I'm going to approach with what's been marked as states proposed 377. Does that appear to be kind of the accurate outcome of the election? Yes, sir. Okay. And that's a fair and accurate depiction of those results? I think so. [00:54:33] Speaker 2: Like I said, it was pretty close. [00:54:34] Speaker 1: At this time, we're asking the state commission to admit states 377. Sure. Sorry about that. No objection. [00:54:41] Speaker ?: Publishing 377. [00:54:42] Speaker 1: We can cue over. So when we look at this, you don't lose by much, do you? No. I mean, a little more than 2,000 votes, correct? Right. Right. Right. Jeff Gariman didn't write any articles about Carolyn Escobar in a negative fashion. [00:55:03] Speaker ?: Did he? I wouldn't think so. [00:55:03] Speaker 2: I mean, leading up to this election, he didn't do that, correct? [00:55:04] Speaker 1: Correct. [00:55:05] Speaker ?: He didn't do that about Rita. [00:55:05] Speaker 1: No. Fair to say, in your opinion, if Jeff Gariman hadn't written these articles, you'd probably [00:55:07] Speaker ?: end up winning that primary. [00:55:07] Speaker 1: Probably, yes. Probably, yes. [00:55:09] Speaker 2: Yes. [00:55:10] Speaker ?: That's correct. Right. Okay. Thank you very much. [00:55:13] Speaker 1: Thank you. Jeff Gariman didn't write any articles about Carolyn Escobar in a negative fashion. Did he? [00:55:18] Speaker 2: I wouldn't think so. [00:55:19] Speaker 1: I mean, leading up to this election, he didn't do that, correct? Correct. He didn't do that about Rita? [00:55:25] Speaker 2: No. [00:55:26] Speaker 1: Fair to say, in your opinion, if Jeff Gariman hadn't written these articles, you'd probably end up winning that primary. [00:55:35] Speaker 2: Probably, yes. It had to be crushing, correct? [00:55:37] Speaker ?: No. [00:55:38] Speaker 2: It was disappointing, but again, I knew that my chances were 50-50, so I was prepared for a loss. And I think my conciliation post on Facebook was pretty clear that, hey, you know what, we tried really hard, we gave it our go, but, you know, I'm gonna go serve families as a probate attorney again. I'm ready to go back to work, and, you know, and I got a lot of support when I made that post. [00:56:15] Speaker 1: Okay. But everything that you work for is gone because of a couple of articles that say things that you don't think are really true, correct? Especially about the work stuff, right? [00:56:25] Speaker 2: It wasn't the articles per se. It was obviously Rita and Alicia. [00:56:32] Speaker 1: Who got Jeff Gariman into the fold to publicly tear you down. [00:56:38] Speaker 2: They did, yes. [00:56:41] Speaker 1: And he agreed to do it. So now, I want to focus on just two days later. Two days later, oh, can we cue over, sorry. Two days later, Jeff Gariman writes to you, correct? Mm-hmm. At this point, you are kind of right on teetering on the verge of, like, conceding, correct? [00:57:14] Speaker 2: I think it took a long time for the count to occur. It was like almost a week. So we were -- and this is a while back, so if I remember correctly, we were still waiting for the final outcome, and, yeah, so this was -- [00:57:31] Speaker 1: So you're down as of May 16th. You're losing in the race, correct? [00:57:36] Speaker 2: It was kind of, like, similar to what you saw on that report in the sense that things kept going up and down, but, you know, it was some -- I think, if I'm not mistaken, it was somewhere around those, you know, 1,000, 2,000 between the three of us, you know? But Rita would go up, then Caroline would go up, and so it was more of a tug of war between them, and that was pretty much in third place at all times. [00:57:59] Speaker 1: So it's very close, right? It was really close, yeah. You don't know how this -- at this point, as of June 16th, you still don't officially know how this one's going to shake out, correct? [00:58:08] Speaker 2: You know, based on the fact that I never came out of third place during the whole thing, I was pretty sure that it was done. [00:58:15] Speaker 1: Okay. But nevertheless, Jeff Gehrman comes calling again, correct? [00:58:19] Speaker ?: Mm-hmm. [00:58:20] Speaker 2: And it's about that truth website that I created. [00:58:24] Speaker 1: Right. Right. And you just say it's fine at this point. They won. Do what you like. Mm-hmm. Fair to say you felt resigned at this point? [00:58:32] Speaker 2: Yeah. Like, just, you know what? What's it going to do at this point? Whatever, you know? [00:58:36] Speaker 1: Well, you wrote another one, correct? Mm-hmm. [00:58:39] Speaker 2: That is, yes. [00:58:40] Speaker 1: Fair to say you weren't happy with that coverage. It wasn't positive, was it? [00:58:44] Speaker 2: Again, I don't remember if I cared or not. I know I started to poke fun at him on Twitter, but, you know, it came to a point where it was just me trying to, I think, see if I couldn't get him to put more light on my website. [00:59:02] Speaker 1: Okay. And so then on June 18th, he publishes this article number three, correct? Mm-hmm. [00:59:09] Speaker 2: Excuse me. [00:59:10] Speaker ?: I'm sorry, Your Honor. [00:59:11] Speaker 2: Yes. Thank you. [00:59:13] Speaker 1: And then just six days later on June 22nd, he publishes a fourth article about you officially losing, but pointing out that you remain combative, correct? [00:59:24] Speaker 2: Yeah. Which, again, was inaccurate, but sure, yes. [00:59:27] Speaker 1: So, again, it's inaccurate reporting about you, the fourth one. [00:59:33] Speaker 2: Right. Right. Like I said, by this point, I, you know, I was just having fun with it. [00:59:39] Speaker 1: Well, let's, let's be, Mr. Tejas, you didn't like Jeff Gehrman by this point, did you? [00:59:47] Speaker 2: I mean, sure. I did not like him. [00:59:51] Speaker 1: You hated him. Isn't that correct? [00:59:53] Speaker 2: I mean, I don't know if hate, I mean, there might have been various points throughout that where I might have felt like that, but I don't know that I ever, he was not a central figure in my life. I'll put it that way. [01:00:05] Speaker 1: He is the figure that ends up causing you to leave your job as public administrator for Clark County. Correct? [01:00:14] Speaker 2: Again, I don't blame him, per se. I blame Rita and I blame Alicia. [01:00:18] Speaker 1: Sir, you just told this jury that if those articles weren't written, hold on, I'm not finished. You just told this jury, like, five minutes ago, that if Mr. Gehrman hadn't written these four articles, you believe you would have won the race. [01:00:34] Speaker 2: Correct. But again, if Rita and Alicia hadn't gone to Alicia's dad to ask for this favor, those articles wouldn't have happened. [01:00:42] Speaker 1: So the answer to my question is yes. [01:00:45] Speaker 2: Who I would hold most responsible is not Mr. Gehrman. [01:00:50] Speaker 1: Sir, that's not my question. Okay. My question is, do you believe if Mr. Gehrman had not written these four articles, you would have won the race, correct? [01:01:00] Speaker 2: I do believe that, yes. [01:01:02] Speaker 1: You hated him by this point in time, isn't that right? [01:01:07] Speaker 2: I could not say whether I hated him by this point in time. And if I, you know, how long am I to hate him? You know. [01:01:16] Speaker 1: Roberta said you hated him. [01:01:17] Speaker 2: Roberta hasn't had her own opinion. I don't know that I ever said I hated him. [01:01:23] Speaker 1: Okay. So now we're in July. Fair to say working in that office had to have been hard in July. [01:01:40] Speaker 2: So after the election loss, I ended up, so I guess just back up a little bit. When Mike Murphy came into the office, it was not a directive from Clark County. It was a request. Jeff Wells said, hey, you know, you've got this situation. I know I think, you know, maybe if we bring in Mr. Murphy, he could help you kind of be an independent, you know, arbiter of sorts. And he said that, you know, you don't have to say yes. This is not, you know, we have no right to force this on you. It's entirely up to you. And I said, you know what? Sounds like a great idea. Let's do it. Okay. So we brought him in. But then again, that got misconstrued, which it is what it is at this point. But so once I lost the election, he and Rita had taken over the duties primarily. And I did, you know, most of my work from home coming in a couple of days a week just to, you know, do things here and there. [01:02:48] Speaker 1: Okay. So to go back to my question, was July hard? [01:02:51] Speaker 2: Yes or no? Sorry. My answer would be not as -- I didn't have to deal with the first, you know, the day to day frustrations I used to deal with when I was in the office 50 hours a week. [01:03:03] Speaker 1: So you came in less, correct? Yes, sir. Mm-hmm. Rita assumed more of a responsibility. Right, sir. Even though you were still the acting duly elected public administrator. [01:03:15] Speaker 2: Right. Right. We decided, you know, just -- [01:03:19] Speaker 1: Okay. I'm going to publish Exhibit 340. We could queue over to the Elmo. On June 13th -- I mean, I don't know if you are aware of this back in the day, but an email is sent out -- I'm sorry? July. July. Sorry about that. July 13th of 2022, Jeff Gehrman is making a public records request, correct? Yes, sir. Now, in July, you have already lost your race, correct? Right. So the election isn't at stake. Is that correct? Correct. You will be gone in a matter of six months, right? Right. And now, Jeff Gehrman is asking for all emails between public administrator Robert Tellis and the state porter Roberta Lee Kennett from January 1st to the date that this is fulfilled, correct? [01:04:16] Speaker 2: Correct. [01:04:17] Speaker 1: He also wanted all of your communications, including messages, between you and Roberta, correct? Right. From your personal cell phones, correct? Yes. He did, but he was not allowed to have them, but yes. Understood. But I mean, that's how far this is going. And additionally, and I didn't read that in the middle, it included a request for Microsoft Teams messages as well. Isn't that right? Right. Okay. Now, sir, you are familiar with the county's policy. Well, let's do it this way. You testified to this jury that, oh, you know, before the records requests went out for the team's messages, you had reviewed them and you didn't have any issues with them, correct? [01:05:04] Speaker 2: And I'd love to elaborate on that if I could. So -- [01:05:07] Speaker 1: I want -- I need you to focus on my question. Yes or no? Sir? Sir? Yes, I did have an opportunity to review them before. Judge, it's a two-way street on this one. Okay. [01:05:17] Speaker 4: If you can answer the question, yes or no -- I haven't finished the question yet. [01:05:20] Speaker 1: Oh, I -- [01:05:21] Speaker 4: but I can ask Mr. Amner if you want you to answer the question. [01:05:24] Speaker 1: I -- I need you to list -- I need to finish the question. Oh, I thought you were done. [01:05:27] Speaker 2: Sorry. [01:05:28] Speaker 1: Well, yes or no, you testified on direct examination that you reviewed Teams messages and you did not have an issue with them, correct? [01:05:40] Speaker 2: The production that I was going to -- that I understood was going to send -- be sent to Mr. German, yes. [01:05:46] Speaker 1: Right. And just to be clear, you were familiar with the county's policy about what gets produced in a public records request, correct? Yes, sir. And so, isn't it true that under this county policy, personal messages would not be produced under a public records request? That is correct. Okay. So, any personal communications between you and her wouldn't go out to Mr. German, correct? That is absolutely correct. And that is why -- and so, you're like, I don't have any issue with that other stuff going out, correct? Correct. Okay. [01:06:26] Speaker ?: Okay. [01:06:27] Speaker 1: But let's be clear about something. The election is over, right? [01:06:31] Speaker 2: Mm-hmm. [01:06:32] Speaker 1: And Jeff German -- [01:06:33] Speaker 2: Yes, I'm sorry, Your Honor. [01:06:34] Speaker 1: And Jeff German seems to still be digging about you and Roberto, isn't that right? [01:06:39] Speaker 2: Yes. But there's nothing to dig, provided, obviously, that I -- you know, if he was going to receive what I saw, then there was nothing for him to dig. [01:06:49] Speaker 1: I mean, you would agree. I mean, reporters typically don't ask for records requests unless they're planning on doing a story, [01:06:55] Speaker 2: correct? Sometimes I think they're just fishing to see if there is a story. [01:06:58] Speaker 1: And what -- and according to this records request, he's fishing about one thing. It's you and Roberto, right? Right. Okay. Which you told us back in May, when you sat down with your interview with Jeff German, the number one priority was to, you know, protect your family and not really dig into that, correct? Not really dig into that. Or at least disclose that, correct? I'm sorry. You told us when you met with German on May 11th, you had said, you know, I was truthful about some things, but I wasn't truthful at everything. The one thing I didn't want to talk about was the indiscretions. And you said that the reason for that was, I was really concerned about my family, correct? Correct. Okay. [01:07:35] Speaker ?: The election's over. [01:07:36] Speaker 1: You're on your way out. And now this guy is wanting to ask more questions about you and Roberto, right? Yep. It's not about you and Rita, right? There's a request. [01:07:43] Speaker 2: Oh, I know that there was a later request for those other emails that got appended to this, but I don't know if you remember that with Mike Murphy and Rita. [01:08:01] Speaker 1: Just in this specific request, he's not asking for communications between you and Rita, right? Correct. It's just about you and Roberto. Right. He's not leaving it alone, is he? I think he's still fishing. That had to have been frustrating. Mr. Tell us. No, it was not because I knew he wasn't going to have anything based on what I reviewed from the production. Okay. I think he's still fishing. That had to have been frustrating, Mr. Talos. [01:08:20] Speaker 2: No, it was not because I knew he wasn't going to have anything based on what I reviewed from the production. [01:08:25] Speaker 1: Okay. So it's your testimony that the possibility of a fifth article didn't concern you at all when the potential source of the request is just about your communications between you and Roberta. You're telling us that's not a concern at this point in time. [01:08:42] Speaker 2: Again, so I can explain to you how things... [01:08:45] Speaker 1: Yes or no? Is it a concern or is it not? [01:08:48] Speaker 2: Not at the time that I reviewed those documents, no. [01:08:52] Speaker 1: Okay. So, now, let's now jump forward to August 8th of 2022. On that day, Dan Coolin emails you and starts to tell you about the production request, that it's going to start to happen, correct? Yes, sir. Okay. That's on August 8th, right? August 8th, four days later, in your phone, the Google Maps and Bronze Circle start popping up, correct? [01:09:35] Speaker ?: No, sir. [01:09:35] Speaker 1: Read this out to me. What does that say? That says August 12th, 2022. Great. Publishing 364, this is the street surveillance. Please read out to me what the date is on that. August 15th, 2022. [01:09:52] Speaker 2: August 15th, 2022. Okay. You would agree that August 12th is just four days after August 8th, correct? [01:09:55] Speaker 1: I would. You would agree with me that August 15th is just seven days after August 8th, correct? I would. You would agree with me that August 15th is just seven days after August 8th, correct? [01:10:14] Speaker ?: I would. [01:10:14] Speaker 1: And if we go back to the overhead 354, I want you to read the date on entry number one on that. [01:10:35] Speaker 2: The modified date? Yeah. The modified date? Yeah. 8/23. Okay. [01:10:44] Speaker ?: 2022. [01:10:45] Speaker 1: I wish I could do the math on that one. I feel like that's, like, about two weeks after August 8th, correct? [01:10:50] Speaker 2: That's somewhere on there. [01:10:53] Speaker 1: We also heard from Nicole Lofton, correct? Yes, sir. Nicole Lofton, correct? [01:11:08] Speaker 2: Yes, sir. [01:11:09] Speaker 1: Nicole Lofton was employee of the public administrator's office, correct? Yes, sir. A member, as you describe it, of the New Guard, correct? Yes. She was on team TELUS, fair? Sure. Yes. Okay. You had text messages between you and Nicole Lofton through the course of your time as a public administrator, correct? [01:11:31] Speaker 2: If you've got them, then sure. I don't recall. [01:11:34] Speaker 1: Okay. Well, I'm going to approach her a second. So I'm going to show opposing counsel what's been marked as 376. It's just an excerpt of some things, but take a look. These are just excerpts. [01:11:42] Speaker ?: They're not the entire. It's not the full. [01:11:42] Speaker 1: It's not the full thing. There's a lot of messages there. [01:11:44] Speaker ?: I just wanted to kind of narrow down. I just wanted to kind of narrow down. I'm going to approach in a minute. But I need to get an understanding. Um. It's not the full. It's not the full thing. There's a lot of messages there. I just wanted to kind of narrow down. I'm going to approach in a minute. But I need to get an understanding. Um. By August. Beginning of August. August 8th. By August 8th. By August 8th. How are you feeling about Jeff Gehrman's next upcoming article? Okay. It's not the full thing. But I need to get an understanding. Um. [01:12:07] Speaker 2: By August. Beginning of August. [01:12:09] Speaker 1: August 8th. By August 8th. How are you feeling about Jeff Gehrman's next upcoming article? I don't recall. Okay. Okay. Are you concerned at all? I don't recall. Okay. Well. [01:12:22] Speaker ?: Let me show you. [01:12:23] Speaker 1: What's been marked as Exhibit 376. Proposed Exhibit 376. Why don't you just take a minute and flip through those and let me know, um, if you recognize the census of the census of the census. Essentially what you're looking at there. [01:12:31] Speaker ?: Okay. [01:12:31] Speaker 2: Okay. Okay. [01:12:33] Speaker 1: Okay. [01:12:34] Speaker 2: Okay. [01:12:35] Speaker 1: So, I'm going to go ahead and see what's been marked as Exhibit 376. I'm going to go ahead and see what's been marked as Exhibit 376. Proposed Exhibit 376. Why don't you just take a minute and flip through those and let me know, um, if you recognize essentially what you're looking at there. [01:12:47] Speaker ?: I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. Okay. Okay. Okay. [01:13:33] Speaker 1: Okay. I'm going to go ahead and see what you're looking at. [01:14:03] Speaker ?: I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. [01:14:06] Speaker 1: I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. [01:14:10] Speaker ?: I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. [01:14:11] Speaker 4: I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. I'm going to go ahead and see what you're looking at. [01:14:44] Speaker 3: I'm going to go ahead and see what you're looking at. Thank you.