brigance, alisha and dustin | testimony transcript

Transcript of the Testimony of Alisha and Dustin Brigance

Date: November 14, 2013Volume: I

Case: In Re: Joplin Critical Investigation

Printed On: November 27, 2013

Holliday Reporting Service, Inc.Phone: 417-358-4078

Fax: 417-451-1114Email:[email protected]

Internet:

Alisha and Dustin Brigance In Re: Joplin Critical Investigation

417-358-4078

Holliday Reporting Service, Inc.

Page 1

IN RE: JOPLIN CRITICAL INVESTIGATION

SWORN STATEMENT OF

ALISHA BRIGANCE and DUSTIN BRIGANCE

Taken on Thursday, November 14, 2013, from 3:46 p.m. to 4:43

p.m., at the law offices of Juddson H. McPherson, LLC, 626

S. Byers, in the City of Joplin, County of Jasper, State of

Missouri, before

SHARON K. ROGERS, C.C.R.650,

a Certified Court Reporter and a Notary Public within and

for the County of Jasper, and State of Missouri.


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APPEARANCES

MR. THOMAS E. LORAINE

Loraine & Associates, LLC

4075 Osage Beach Pkwy., Suite 300

Osage Beach, MO 65065

[email protected]


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S T I P U L A T I O N

IT IS HEREBY STIPULATED AND AGREED that this Sworn

Statement may be taken by steno-mask type recording by

SHARON K. ROGERS, a Certified Court Reporter, and

afterwards reduced into typewriting.

It is further stipulated that the signature of the

witness is hereby waived, and that said Sworn Statement of

said witness shall be of the same force and effect as

though said witness had read and signed Sworn Statement.


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I N D E X

Page/Line

DIRECT EXAMINATION BY MR. LORAINE . . . 5-22

E X H I B I T S

Exhibit #26 . . . . . . . 58-4

Contract

Note: Exhibits in separate binder

(sic) - typed as spoken

(ph.) - phonetic


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1 ALISHA BRIGANCE and DUSTIN BRIGANCE

2 Having been first duly sworn and examined,

3 testified as follows:

4 BY MR. LORAINE: Let's swear Dustin

5 in, also, while we're doing it. Now I'm

6 going to try to take the statement from

7 Alisha first, and only one of us can talk

8 because the court reporter has to listen to

9 one of us and then the other one responding

10 and they can't understand head shakes so

11 you've got to say yes, no, or whatever. And

12 if we can if you, Dustin, have something to

13 say just say I've got something to add to

14 that and then I'll stop and I'll go to you

15 and she'll be able to distinguish the voices

16 and of course it would be so on the record.

17 You knew that we were taking statements under

18 oath, is that true?

19 BY MR. BRIGANCE: Yes.

20 BY MR. LORAINE: And we want all the

21 truth so here we are.

22 DIRECT EXAMINATION BY MR. LORAINE:

23 Q. Alisha, can you tell me let's go through this

24 again, it's my understanding that neither you

25 nor your husband work for the City?


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1 A. That is correct.

2 Q. And you knew that I was doing an

3 investigation on some matters involving the

4 City from your mother-in-law?

5 A. I knew you were doing an investigation of the

6 City because we live here and we were

7 involved already. She is the one that knows

8 enough people that called and got the - Bill

9 Scearce and, what is the other one's name,

10 Rosenberg, both of them called my mother

11 because when all this came down she got

12 really pissed and voiced her opinion and

13 called them. So when you got involved they

14 called her and she called me to call the City

15 Attorney and I called him a week ago and left

16 my name and number and he called me back and

17 we scheduled this to come talk to you through

18 my mother.

19 Q. And what's your mother's name?

20 A. Cheryl Dandridge.

21 Q. And she's an ex-Mayor of the City of Joplin?

22 A. Yes.

23 Q. And she's been retired now for a few years

24 off that Mayor job?

25 A. She's been retired since 1992.


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1 Q. And she's not on the Council now?

2 A. No.

3 Q. And hasn't been since '92?

4 A. No, she hasn't even lived in the City since

5 1992.

6 Q. So tell me what you're here to tell me about.

7 A. Our dealings with Mike Woolston and Four

8 State Homes in the sale of our home, our

9 house.

10 Q. Four State Homes is the company he was

11 working for?

12 A. No, Four State Homes is the person that

13 purchased our house - well, this is going to

14 get confusing. Okay, Mike Woolston at the

15 time worked for Pro 100. He was working for

16 Four State Homes to purchase an extremely

17 large amount of property in our area.

18 Q. Who did he work for, Four State Homes?

19 A. That's who his client was was Four State

20 Homes. In July of 2002 we received a letter

21 - sorry, 2012. July 2012 we received a

22 letter from Woolston saying that somebody was

23 interested in the purchasing of our property.

24 About that same time were the rumors of the

25 movie theater and library going in at 20th


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1 and Connecticut. Our house was at 1812

2 Delaware which our yard, I don't know how to

3 explain this - Connecticut was here and

4 Delaware was here (indicating) so there was

5 no alley so the yards would connect in a way.

6 Q. You were one block away from Delaware?

7 A. No, we were on Delaware. We were a block

8 away from Connecticut.

9 Q. From Connecticut. And Connecticut was

10 essentially where the --

11 A. At the time was where the rumors were going

12 that the --

13 Q. The art center or whatever it is?

14 A. Yes, the library, theater, all that stuff.

15 At the time we got the letter that was what

16 the rumor was. I called my mom and told her

17 about it. She told me to call Gary Shaw and

18 I called Gary and he said, oh, it's nothing,

19 it's just rumors, we don't know what it's

20 about, you know, don't know why someone would

21 want to purchase the property. We were like,

22 okay, so we didn't do anything about it at

23 the time. Our neighborhood is an extremely

24 close knit neighborhood so we knew that we

25 weren't the only ones that got - we knew that


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1 everybody got a letter from 18th and Delaware

2 all the way to 20th Street and then down 19th

3 Street to New Jersey. It's a really weird -

4 it's a very L-shaped area. So we knew and

5 then --

6 Q. You knew that everybody in that L-shaped area

7 was receiving letters from Woolston?

8 A. Yes, and it didn't say who was purchasing,

9 who was interested, just that he had someone

10 that was interested in purchasing the

11 property. And then September or October

12 there was the announcement - it was one of

13 the CART meetings that Wallace-Bajjali made

14 the announcement that it really was going

15 there, the library when we went to that

16 meeting at City Hall.

17 BY MR. BRIGANCE: Before that we had

18 the neighborhood meeting and Woolston was

19 there.

20 BY MRS. BRIGANCE: Did we have the

21 neighborhood meeting first?

22 BY MR. BRIGANCE: Yeah, it was when

23 Scearce had the CART meeting at City Hall at

24 that meeting after we already knew. He said

25 we had a neighbor in the meeting - a neighbor


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1 just off 16th Street when everybody got

2 together and exchanged phone numbers, kind of

3 set up a neighborhood watch and started kind

4 of implements to that program and wanting to

5 also establish - someone invited a City

6 Council representative was invited, two of

7 them were invited.

8 BY MR. LORAINE: Who were invited?

9 BY MR. BRIGANCE: Benji Rosenberg.

10 BY MRS. BRIGANCE: And he is our

11 section zone person.

12 BY MR. BRIGANCE: Then you have Mike

13 Woolston was invited. As things were

14 progressing everybody was talking expressing

15 concerns, well, we have this house,

16 demolition is going there, everybody was kind

17 of taking notes, okay, this one we need to

18 call the City on demolition, or just trying

19 to make the neighborhood safer, like that,

20 trying to take hold of our neighborhood from

21 there.

22 BY MR. LORAINE: That was after the

23 tornado?

24 BY MR. BRIGANCE: This was after the

25 tornado.


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1 BY MRS. BRIGANCE: Yes, this would

2 have been September of 2012.

3 BY MR. BRIGANCE: So as we were

4 talking and everything and turned around to

5 where we asked - Woolston asked what was

6 going on and he said nothing is going in the

7 neighborhood, he's not at liberty to say. We

8 asked a grocery store or what, he said he's

9 not at liberty to say on behalf of his

10 client. So secretive about everything. Mr.

11 Rosenberg was also, he was caught off guard,

12 was unaware of everything going on based off

13 of his reaction and the - what I'm saying

14 what was going on I wasn't particularly

15 talking to him, I was trying to listen to

16 Mike Woolston's conversation as my wife was

17 talking to Mr. Rosenberg and his wife.

18 BY MR. LORAINE: Mr. Rosenberg was

19 not aware that Woolston was contacting people

20 in this area?

21 BY MRS. BRIGANCE: Correct.

22 BY MR. BRIGANCE: Correct. That was

23 my assumption.

24 BY MR. LORAINE: That's what you

25 learned?


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1 BY MR. BRIGANCE: Correct.

2 A. I have something to add to that.

3 Q. (By Mr. Loraine) All right. Go ahead.

4 A. Dr. Rosenberg and I was talking to him

5 because he asked - he said - he asked me

6 where we lived and I told him our address and

7 he asked are you one that Woolston is trying

8 to - and I said yes. I said Woolston has

9 contacted all of this grouping of people

10 about purchasing their land, and he was

11 caught off guard. He had no idea that --

12 Q. That Woolston was doing that?

13 A. That Woolston was doing that.

14 Q. All right. So what then did Woolston say?

15 BY MR. BRIGANCE: He assured us that

16 he still had somebody interested in it, could

17 not divulge anything one way or the other as

18 to who and what interests were. He

19 reiterated basic stories that were running in

20 the paper being the library, the complex,

21 just the scuttlebutt. He said that's a

22 possibility. He's never said definitive as

23 to this is or is not going in place. For

24 privacy of his client he wouldn't jeopardize

25 that, which is justifiable. And then that


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1 was in September and then we had a

2 neighborhood meeting - sorry, the City

3 Council meeting. Well, CART where they come

4 through and said this is what we have

5 proposed and puts it like that.

6 A. Yeah, Wallace-Bajjali made the big

7 announcement that - because it was City Hall

8 and Wallace-Bajjali was there and they were

9 wanting to get some ideas, other ideas, but

10 they were also making a big announcement

11 that, yes, the library and whatever was going

12 at 20th and Connecticut. And we went to that

13 and talked to David Box there because he was

14 the one that was going to discuss that.

15 Q. (By Mr. Loraine) He works for

16 Wallace-Bajjali?

17 A. He works for Wallace-Bajjali. So after the

18 big announcement they let everybody kind of

19 sit out and talk to varying different groups

20 of I guess Wallace-Bajjali people that were

21 representing certain things and all of us

22 went to go to talk to - our entire

23 neighborhood, most of our neighborhood was at

24 this meeting - went to talk to David Box

25 about it. And in this time period we had


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1 contacted Bonnie, which is Bonnie Wright who

2 works for Pro 100 was our realtor for us. We

3 had contacted her to contact Woolston.

4 BY MR. BRIGANCE: We wanted to get a

5 buffer in there and we were trying to get

6 some things on our side to figure out what

7 was going on because we don't want to get

8 blindsided in trying to get some --

9 Q. (By Mr. Loraine) So you got a realtor?

10 A. We got a realtor.

11 Q. And what was your realtor's name?

12 A. Bonnie Wright.

13 Q. How do I get hold of her?

14 A. And she actually worked for Pro 100. I mean

15 she was a personal friend of ours.

16 BY MR. BRIGANCE: She'd actually been

17 with us whenever we --

18 A. She's the one that sold us the original

19 property.

20 Q. (By Mr. Loraine) How do I get hold of her?

21 A. 417 - is that her work, the 649? No, it's

22 not.

23 Q. I don't need her work, just whatever number

24 you've got for her.

25 A. 437-2726.


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1 Q. 2726. Now does she know anymore than you do

2 about any of the things with Woolston? Would

3 she talk with him?

4 A. She would be the one to talk to him. She was

5 who would talk to him in the negotiations and

6 everything else.

7 Q. So would you call her and tell her I'd like

8 to speak with her down here and see if she'd

9 come?

10 A. Uh-huh.

11 Q. And I'd like to know what conversations she

12 had. Now does she still work for Woolston or

13 with Woolston at Pro 100?

14 A. No, he actually no longer works for Pro 100.

15 Q. Okay. So she would not have any hesitancy to

16 talk to me?

17 A. I don't think so. I don't know.

18 Q. You paid her a commission, didn't you?

19 A. Yes.

20 Q. Well, see if she will.

21 A. Okay.

22 Q. And if she will I'll be here tomorrow about

23 1:00 or 1:30 and at 2:00, something like

24 that. See if she'll come in and talk with

25 me. Would you do that?


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1 A. Yes, I'd do that.

2 Q. I appreciate that. Maybe she'll come and

3 talk to me. Now let's talk some more. So

4 what else?

5 A. So we contacted her kind of just to see - we

6 hadn't officially decided. It was a more of

7 how serious is this? Can you kind of just --

8 BY MR. BRIGANCE: We wanted a buffer,

9 kind of get somebody else's input, are we

10 jumping the gun too early, should we just

11 hang loose, what do we need to do on our end

12 as well as prior to this CART meeting that

13 went on here at City Hall. And at City Hall

14 then at the meeting we talked to Mr. Box and

15 everything like that and our neighborhood was

16 altogether that's when everything started to

17 come out that --

18 A. When he knew we were selling.

19 Q. (By Mr. Loraine) Who knew?

20 A. David Box knew that we had contacted a

21 realtor. We hadn't told anybody other than

22 our realtor.

23 Q. But David Box had some conversation with your

24 realtor apparently?

25 A. No, David Box had contacted Woolston.


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1 Because we had talked to Bonnie and said just

2 talk to him, see what - I guess kind of just

3 put feelers, see what's going on, and she's

4 like, yeah, sure, I can just kind of see, you

5 know, see if she could get a little more

6 information than what we --

7 Q. Had you already signed a contract with

8 Bonnie?

9 A. Huh-uh.

10 Q. So she was a friend?

11 A. Yeah, she was a friend. So at the night of

12 that meeting and we were talking to Box he

13 told every one of us if you live south of

14 18th Street they want your property. Or that

15 Wallace-Bajjali wanted their property.

16 Q. Did you live south of 18th Street?

17 A. (Nodding head)

18 Q. That's a yes?

19 A. That's a yes. Sorry. Yes, I live south of

20 18th Street. And I said so you're basically

21 telling me that I shouldn't have built back

22 and he asked me where I lived and I said --

23 Q. You should what?

24 A. That I should not have rebuilt my house. And

25 he asked me where I lived and I said - I gave


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1 him my address and he said, well, I thought

2 you were already selling. And I said, no. I

3 said we are not selling. And the look on his

4 face was like I just kicked him. He was

5 shocked that I answered that way. So I knew

6 at that point that Woolston had talked to him

7 and told him that we were interested in

8 selling our property.

9 Q. When had you built your house back?

10 A. We had moved in Christmas Eve of 2012.

11 BY MR. BRIGANCE: 2011.

12 A. 2011. Sorry.

13 Q. (By Mr. Loraine) So how many months before

14 this?

15 A. Six months.

16 Q. So you had already built a house back. Your

17 house was totally destroyed?

18 A. Our house was totally destroyed.

19 Q. How did you build back?

20 A. Insurance money. Insurance money and we had

21 a mortgage loan. We had a contractor's loan

22 that turned into a mortgage loan.

23 Q. And there was sufficient money in the

24 insurance to build your home again?

25 A. Yes.


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1 Q. So you were not intending on moving then?

2 A. No, we had absolutely no intention of moving

3 at all.

4 Q. Are you now in that house?

5 A. No, we sold it. It sold.

6 Q. You sold it because they were going to what?

7 A. We sold it because Four State Homes bought

8 every bit of property around our house and

9 sold it to the City.

10 Q. So there was no neighbors anymore?

11 A. We have no neighbors. We had no neighbors.

12 Well, --

13 BY MR. BRIGANCE: As we were going

14 through the hoops - after all this we

15 contacted Bonnie and we did contracts, okay,

16 let's go ahead since this is going this way

17 and they went from 18th Street south we're

18 stuck, we've got to get out no matter what so

19 let's get out when we can, cut our losses and

20 just get away because I don't want to live in

21 a neighborhood with commercial things like

22 that. That's why we built back. So we

23 secured ours with Bonnie, things to cover

24 Bonnie Wright to cover it that way, and then

25 we started going through various requests by


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1 Mike Woolston on behalf of his client, which

2 at this time we still didn't - we had

3 suspicion it was Four State Homes, but I mean

4 we weren't completely sure.

5 A. We knew who it was because we knew - the

6 property to the south of us was originally

7 owned by a gentleman by the name of Jason

8 Bass and he's a good friend of ours. He

9 actually sold his property first and we knew

10 who he sold his property to so that's why we

11 had a feeling we knew who was buying.

12 Q. And it was Four State Homes?

13 A. And it was Four State Homes.

14 Q. Now who is that name, Jason who?

15 A. Jason Bass, B-A-S-S. He was the original -

16 he was the first to sell all of them, or sell

17 out of all of them.

18 Q. Now had he rebuilt his home?

19 A. No, we were the only ones to rebuild.

20 Everybody else was land.

21 Q. So I'm going to have to ask you some personal

22 questions.

23 A. That's fine.

24 Q. Did you have enough money from the insurance

25 company to cover your entire building back?


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1 A. Yes. Well, --

2 BY MR. BRIGANCE: Before we had to do

3 a contractor's loan and then after the

4 contractor's loan that rolled into a mortgage

5 so we went back to having a mortgage.

6 Q. (By Mr. Loraine) So you didn't have a

7 mortgage before the tornado?

8 A. Yes, we did. We had a mortgage. Okay, we

9 had enough insurance money to pay off our

10 existing mortgage, then we got a contractor's

11 loan which rolled over into a mortgage once

12 our house was built.

13 Q. Who fixed you up with that contractor?

14 A. Arvest Bank.

15 Q. Who?

16 A. Arvest Bank.

17 BY MR. BRIGANCE: Fixed us up with

18 the contractor or the loan?

19 A. It wasn't a contract, it was a construction

20 loan, sorry. It was called a construction

21 loan, and once the construction of the house

22 was completed it automatically rolled over

23 into a mortgage loan.

24 Q. (By Mr. Loraine) And who is involved at

25 Arvest Bank?


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1 A. Who did our loan? Casey Cowger was our loan

2 --

3 Q. Did they inquire as to whether or not the

4 rest of the neighborhood was selling or

5 anything?

6 A. Huh-uh, we owned the land before. All of us

7 - when our house was completely built

8 everybody still owned their original lots.

9 Q. But they were all in various stages of

10 dilapidation?

11 A. Yes.

12 Q. They were affected by the tornado?

13 A. Correct.

14 Q. Was there anybody still really living in any

15 of those homes?

16 A. No, our entire neighborhood was completely

17 wiped out.

18 BY MR. BRIGANCE: From 18th Street

19 south along Delaware we were the only house

20 that was there.

21 Q. (By Mr. Loraine) And that's the new house,

22 correct?

23 A. That's the new house, yes.

24 Q. Now let's talk about so now you don't want to

25 be in a commercial neighborhood so you


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1 contact Bonnie Wright and she contacts who?

2 A. She contacts Mike Woolston and says, okay,

3 they're deciding to go ahead and sell, let's

4 negotiate. And we knew he was in

5 negotiations not only with us, but everybody

6 else in the neighborhood. And we started

7 talks in the end of October and we did not

8 even come

9 to --

10 Q. What year?

11 A. October of 2012.

12 Q. When did you finalize your negotiations?

13 A. February 28th of 2013 is when we officially

14 signed the documents that this is what we

15 agreed to sell.

16 Q. And who did you sign that with? Was that

17 Woolston?

18 A. We signed with - well, Woolston had Charlie

19 Kuehn sign the paperwork and he was the owner

20 of Four State Homes, he gave the papers to

21 Bonnie and Bonnie brought them to us and we

22 signed them.

23 Q. Now do you know if Woolston received a

24 commission?

25 A. According to the papers - according to these


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1 papers it says that we will pay for Bonnie's

2 commission and Four State Homes would pay for

3 Mike Woolston's commission.

4 Q. Let me see what papers you've got.

5 A. That's the original contract we signed. But

6 there's much more other jacked up stuff. Oh,

7 it's right here. Right there.

8 Q. You're talking about special agreements,

9 number 22 on page 607?

10 A. Yes.

11 Q. And it says, "Seller will pay commission for

12 listing agent and buyer will pay commission

13 for selling agent. Sale and closing

14 contingent on -" so it says the buyer is

15 going to pay for one and the seller is going

16 to pay for the other?

17 A. Uh-huh.

18 Q. Did you pay for somebody?

19 A. We paid for Bonnie. We paid Bonnie's

20 commission. In these negotiations we had -

21 our house is custom built, or was custom

22 built. Custom cabinets, hardwood floors,

23 granite countertops, tile floors. It was a

24 1,900 square foot home. Our original asking

25 price was $210,000.00.


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1 Q. Now you're talking about your rebuilt home?

2 A. Our rebuilt home.

3 Q. Okay. It was $210,000.00?

4 A. Was the offer that we told Bonnie to give to

5 Woolston to give to Four State Homes.

6 Q. And how much profit would that have made you

7 on what you owed?

8 A. On what we owed?

9 Q. Yes.

10 A. After commission we ended up with --

11 Q. No, I'm saying --

12 BY MR. BRIGANCE: That would have

13 brought us $50,000.00.

14 Q. (By Mr. Loraine) You would have made

15 $50,000.00 on that you're saying based over

16 above what you paid for the house?

17 A. Yes.

18 Q. And that would have helped you on your

19 mortgage?

20 A. Yes.

21 Q. How much was your mortgage?

22 A. Our mortgage was $110,000.00.

23 BY MR. BRIGANCE: As we were talking

24 with him the issue of if we were going to

25 move the house, have somebody come out and


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1 walk through the house, my client might walk

2 through the house to see about moving it if

3 it's feasible to move it.

4 A. And I kept telling him it wasn't feasible to

5 move because there was a solid poured

6 concrete safe room in the dead center of the

7 house and they did not believe me it was not

8 feasible to move. So Bonnie and I met Mike

9 Woolston, someone from Four State Homes, and

10 then two people from Wallace-Bajjali showed

11 up at our house to look at our house and they

12 never looked at the possibility of moving it.

13 They never once crawled underneath the

14 house. They looked at the house like they

15 were wanting to purchase it. And the first

16 offer that they came back to us was for

17 $150,000.00.

18 Q. (By Mr. Loraine) $150,000.00 as opposed to

19 the $210,000.00 that you had listed?

20 A. Correct.

21 Q. So what then happened?

22 A. Bonnie basically told them no and don't come

23 back unless you actually have a real offer

24 for us. They wanted to know basically what

25 we paid to purchase the house, or sorry, to


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1 build the house.

2 Q. The new house?

3 A. The new house, yes. They wanted to know -

4 they wanted the --

5 BY MR. BRIGANCE: They wanted to know

6 everything about investment, about how much

7 we invested out-of-pocket, how much was

8 insurance invested, they wanted to know the

9 whole details of everything.

10 BY MR. LORAINE: Who is they?

11 BY MR. BRIGANCE: Mike Woolston's

12 client.

13 A. Four State Homes.

14 Q. (By Mr. Loraine) And did you talk directly

15 to Mike Woolston or Four States?

16 A. Bonnie talked to Woolston.

17 Q. So what did Bonnie tell? Did you tell Bonnie

18 what you had in it?

19 A. Correct.

20 Q. What was that number?

21 A. They wanted documentation of everything.

22 Q. What was that number?

23 A. $170,000.00.

24 Q. What you had into it?

25 A. Yes.


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1 Q. So you were looking to make a $25,000.00,

2 there abouts, profit?

3 A. Right.

4 BY MR. BRIGANCE: Which is also a

5 fair amount of money. We were not being

6 excessive, we were being fair market value of

7 the house.

8 Q. (By Mr. Loraine) Did anybody appraise your

9 house?

10 A. Yes, the bank appraised the house at the time

11 that it was complete.

12 Q. And who appraised it?

13 A. Arvest Bank's appraiser. I don't know the

14 gentleman's name.

15 Q. Did you have a copy of that appraisal?

16 A. Yes, I did.

17 Q. Do you have it now?

18 A. Yes, I do.

19 Q. Do you have it with you?

20 A. No, I don't. I can get it to you.

21 Q. Can you get it to me?

22 A. Uh-huh.

23 Q. And that appraisal would have said

24 $200,000.00?

25 A. Actually, no, the appraisal said $173,000.00


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1 I think is what the appraisal said.

2 Q. And you asked for $200,000.00?

3 A. We asked for $210,000.00.

4 Q. So what now then happened?

5 A. They continued - we at first thought we had

6 an agreement of the $190,000.00 and in the

7 last minute they backed out and said no and

8 we had to start negotiations over again.

9 Q. That was Woolston?

10 A. Yes, Woolston and Bonnie thought they had

11 everything worked out. Woolston took it to I

12 guess Charlie and Charlie said no.

13 Q. Charlie Kuehn?

14 A. Charlie Kuehn, yes. And then he wanted us to

15 jump through some more hoops. They were

16 still wanting to see if it was possible to

17 move the house. They actually didn't want to

18 - they didn't want to purchase the house.

19 What they wanted to do was they wanted us to

20 be able to still live in the house and they

21 were going to move the house to another

22 location for us and they just wanted the

23 land.

24 Q. I understand. And you didn't really want

25 that?


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1 A. No, because --

2 BY MR. BRIGANCE: Where they proposed

3 moving the house was in the same

4 neighborhood, once we were back there the

5 same boat of, okay, we're putting a

6 development through this, you know, we'd be

7 pushed back out again. As well as we built a

8 house to be in that location I don't want to

9 deal with the house moving or moving

10 somewhere else and take the actual money we

11 get and we'll start from scratch again and go

12 from there.

13 A. I said that I didn't trust the integrity of

14 the house with it being moved because it had

15 a concrete room in the middle of the room.

16 Q. (By Mr. Loraine) So you were worried about

17 the condition of the house?

18 A. Yeah, I was more worried about the condition

19 of the house once we got it moved. I was

20 like, no.

21 Q. So did they ultimately tear your house down?

22 A. No, they ultimately have someone living in my

23 house.

24 Q. Right now?

25 A. Yes.


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1 Q. And nothing else is there?

2 A. No.

3 Q. So really you were forced from your home

4 under the concept that other things would be

5 built there?

6 A. Correct.

7 Q. And yet they haven't?

8 A. Correct. And two other things happened. And

9 once we signed the contracts they also wanted

10 - they originally wanted us to have 120 days.

11 It was 120 days - how was it worded?

12 BY MR. BRIGANCE: It was 120 days

13 within --

14 A. 120 days they could back out and another 60

15 days after that they would close, and we were

16 like no. And we put it down to 45 days they

17 could change their mind and then 30 days

18 after that we close.

19 Q. (By Mr. Loraine) And what was the price?

20 A. $190,000.00 is what we finally agreed on.

21 Q. And that's what you got?

22 A. And that's what we got. Well, no, that's not

23 what we got. We got a little more. So our

24 real estate --

25 Q. Let's find out, what did you get?


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1 A. Well, let me explain why I say it's a little

2 more than that. May 15th was our close date.

3 Q. Just give me the number and we'll go back.

4 A. $190,000.00 plus 7, 7, and 7.

5 BY MR. BRIGANCE: Another $2,100.00,

6 plus then the last was $1,000.00 so 7 and 7

7 is $1,400.00 plus $1,000.00 would be

8 $2,400.00.

9 Q. (By Mr. Loraine) $2,400.00 in addition to

10 the $91,000.00 (sic.)?

11 A. $190,000.00, yes.

12 Q. $190,000.00. $191,000.00?

13 A. $190,000.00.

14 BY MR. BRIGANCE: They had agreed on

15 May 15th they were going to take possession

16 of our house so we moved everything, vacated

17 our house at that time, that way they could

18 have possession of the house at that time.

19 Then they came and said we need 30 more days.

20 We can't finalize the house.

21 A. They came and told us this a week before our

22 close date, that sorry, can we extend this

23 for another 30 days.

24 Q. (By Mr. Loraine) And you've already moved

25 your furniture?


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1 A. We've already moved everything out of the

2 house.

3 Q. Do you have another house?

4 A. Yes.

5 Q. At that time did you have another house?

6 A. My family has a farm that we moved into after

7 the tornado and we just moved back out there.

8 BY MR. BRIGANCE: So we penalized

9 them since they tried to postpone we

10 penalized them with a month's mortgage is how

11 we came up with $700.00. Another month comes

12 up, actually I think it was four or five days

13 prior.

14 A. Yeah, it was the month - we were supposed to

15 close on a Friday. They called us that

16 Monday and said we have to extend it another

17 30 days. I'm like, okay.

18 Q. (By Mr. Loraine) Who called you?

19 A. Woolston called Bonnie, Bonnie called us, and

20 they said they needed to extend it another 30

21 days. And they needed to change who was

22 going to purchase the house. It was going to

23 come out of - it was no longer going to be

24 Four State Homes, LLC purchasing it, it was

25 switching to Charlie Kuehn and his wife


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1 personally. And so they said the second one

2 - is it the second one? Yeah, it would have

3 been July. So we said fine, another $700.00.

4 And they originally wanted the money that

5 they were giving us for our mortgage to come

6 off the total asking price and we said, no,

7 you have put us out, we're not doing that.

8 So, fine. And we even moved it back another

9 week because it was July 24th. So one week

10 before our closing again we get another call

11 that says they need to push it back again.

12 So now we're closing in August.

13 Q. August of?

14 A. 2013.

15 Q. So basically they strung you along for eight

16 months?

17 A. Correct.

18 Q. Now they being Woolston and dealing with your

19 realtor?

20 A. Yes, Four States. And in this time period

21 Woolston is also no longer working for - some

22 time in this grouping Woolston no longer

23 works for Pro 100. And I don't know who he

24 goes to work for.

25 BY MR. BRIGANCE: And at the same


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1 time,

2 too --

3 Q. (By Mr. Loraine) He stayed on your deal,

4 though?

5 A. Yes, he stayed on our deal.

6 BY MR. BRIGANCE: North of our house

7 is a corner lot. He had already secured that

8 one and paid for that one.

9 BY MR. LORAINE: Woolston?

10 BY MR. BRIGANCE: Correct. Everybody

11 completely down our street was completely

12 secured.

13 A. It was us, it was us at 1812 Delaware and I

14 don't know Gale's, but Gale's was at 19th and

15 New Jersey. Those are the only two

16 properties that are still - that they hadn't

17 purchased. And actually --

18 Q. (By Mr. Loraine) As of August?

19 A. As of August. Everyone else is closed, and

20 as a matter of fact everyone down 18th

21 Street, everyone between 18th and 19th and

22 Delaware and actually the property directly

23 across from us has also been sold to the

24 City.

25 Q. Now have any of the homes been ripped down by


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1 that point?

2 A. No, there was no homes to rip down.

3 Q. They were already gone?

4 A. They were already gone.

5 Q. Were they were cleaned up, though?

6 A. Yes.

7 BY MR. BRIGANCE: While all this

8 we're going through we're stuck, we can't

9 back out because we're trapped because you

10 already have everybody else around us boxed

11 in. It was one of those no reason to sit

12 there and fight with it.

13 BY MRS. BRIGANCE: We're basically

14 stuck.

15 BY MR. BRIGANCE: Now do you want

16 hearsay?

17 BY MR. LORAINE: Absolutely.

18 BY MR. BRIGANCE: Okay, Alisha works

19 with Gale, which what is his last name?

20 A. Okay. I work with a gentleman by the name of

21 Gale Wade. He is the last hold out that was

22 on 19th and New Jersey.

23 Q. (By Mr. Loraine) How do you spell his last

24 name?

25 A. W-A-D-E.


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1 Q. Do you have a phone number for Mr. Wade?

2 A. I can get one for you. I see him every day.

3 Q. I would like you to make contact with Mr.

4 Wade and possibly send him down here tomorrow

5 if at all possible.

6 A. Okay.

7 Q. Probably about 3:00, yeah, about 3:00.

8 A. Okay, Gale, at this time - well, in this

9 whole crazy negotiations that we're having

10 Woolston is also - actually Woolston didn't

11 even know how to get ahold of him, didn't

12 have a phone number. He showed up at the new

13 house knocking on his door.

14 Q. At Wade's house?

15 A. At Wade's house interested in selling,

16 because he wasn't going to sell either. But

17 they were in kind of the same thing,

18 negotiations and everything, and Gale wanted

19 $45,000.00 for his property because he had a

20 75x200 lot and he knew it was going to go

21 commercial and he didn't want to pay - he

22 didn't want to be

23 paid --

24 Q. Residential?

25 A. -- residential when he knows it's going to go


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1 commercial. Because he has already had a

2 previous experience where he sold something

3 residential, they turned around and redid it

4 as commercial, so he was not doing it again.

5 Q. Was this still zoned?

6 A. It was all still zoned residential.

7 Q. So Mr. Wade, what else can you tell me about

8 Mr. Wade?

9 A. Wade ran into Gary Box at the Elks Lodge one

10 night and Box asked Wade have you come to an

11 agreement and he says, no, we're at a

12 $5,000.00 difference. I want $45,000.00,

13 they want $40,000.00. He says don't worry

14 about it, I'll get it taken care of. This

15 was a Saturday night. The very next day Wade

16 got a call from Woolston and told him he'd

17 been ordered to give him what he had been

18 asking for.

19 BY MR. BRIGANCE: Which we thought

20 was odd because he doesn't work for that guy,

21 he works for Four State Homes. How do you

22 know what - just didn't make sense to us.

23 Q. (By Mr. Loraine) Who was Box working for?

24 A. Gary Box works for Wallace-Bajjali.

25 Q. So Bajjali basically ordered Woolston to get


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1 the extra five grand?

2 BY MR. BRIGANCE: But on behalf of

3 Four State Homes. Four State Homes is the

4 one that secured the property, but why are

5 they --

6 Q. (By Mr. Loraine) So it was finally sold to

7 Four State Homes?

8 A. They closed - we closed - we got a call - all

9 the TIF money and everything was sold and

10 basically the City got the influx of all

11 their money and we got a phone call and said

12 can you do this, can you close on your house

13 the 9th or the 11th.

14 Q. Of when?

15 A. Sorry, the 9th or the 12th of August, which

16 do you want, and Dustin said let's do the

17 9th, so 8:00 a.m. August 9th, 2013 we walked

18 in and signed our papers and sold our house.

19 Q. And you got your money?

20 A. And got our money.

21 Q. And the same thing happened to Wade?

22 A. No, Wade, when he originally signed his

23 papers he had - he signed them I think May is

24 when he finally signed his agreement and he

25 wasn't even going to close until September


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1 and he ended up closing in September. He had

2 like a long drawn out --

3 Q. 2013?

4 A. 2013, yes.

5 BY MR. BRIGANCE: And he was content

6 with that because it was just land.

7 A. It was just land.

8 Q. (By Mr. Loraine) So your contention is that

9 Woolston was still a City Councilman?

10 A. Correct.

11 Q. And he was negotiating on behalf originally

12 of Pro 100 for some mystic client?

13 A. Correct.

14 Q. And then he talked about selling your

15 property to Kuehn personally?

16 A. Yes.

17 Q. And that didn't happen and eventually the

18 property was sold to?

19 A. Well, --

20 Q. Who did you sign it over to?

21 A. We signed it over to Charlie Kuehn is who

22 originally bought it, but they own Four State

23 Homes.

24 BY MR. BRIGANCE: But CART specified

25 them directly, not Four State Homes.


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1 Q. (By Mr. Loraine) And obviously Bajjali

2 ordered Kuehn to pay you an extra $5,000.00?

3 A. For Wade's property, yes. And we also

4 thought it was really weird when Kuehn came

5 to look at the house to possibly move it that

6 two people from Wallace-Bajjali showed up

7 with him.

8 Q. Do you know who they were?

9 A. It's a lady, and I think her last name is

10 Love, and the other gentleman from Joplin who

11 is not David Box. I could not tell you what

12 his name is.

13 BY MR. BRIGANCE: Bonnie might be

14 able to.

15 A. Bonnie might be able to remember who they

16 were because that's the first - when we saw

17 them walk in we're like what are they doing

18 here and why are they involved?

19 Q. (By Mr. Loraine) So Wallace-Bajjali

20 basically wound up with all the property?

21 A. Our house is still - as far as I know our

22 house is still being owned by Charlie Kuehn,

23 but every bit of the property around it is

24 owned by the City.

25 Q. Okay. So what else? Did Woolston ever


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1 suggest to you that you would be condemned?

2 Did that word ever come up?

3 A. No, he never said anything about condemned.

4 Q. He said you would be in a commercial area?

5 BY MR. BRIGANCE: He said across the

6 street from us could look into become a

7 grocery store. He never flat said our house

8 would be this or that. Now in CART meetings

9 that we had, though, when talking to Gary Box

10 he said that 18th Street to the south is

11 going to be bought up and this is proposed

12 laid out, our house is gone and it's shopping

13 center and parking lots and things like that.

14 Q. (By Mr. Loraine) So you're saying Woolston

15 didn't tell you the truth?

16 A. Correct.

17 Q. He didn't disclose everything to you?

18 A. No.

19 Q. Any other complaints about Woolston?

20 BY MR. BRIGANCE: The only thing that

21 I feel is that throughout this whole series,

22 and I'm limited to what we know because we're

23 not following around with him and knowing

24 everything, he has to make money at this, I

25 understand that.


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1 BY MR. LORAINE: You mean Woolston?


3 BY MR. LORAINE: Why does he have to

4 make money?

5 BY MR. BRIGANCE: His job is a

6 realtor therefore his job is to sell houses

7 and sell property and things like that so I

8 understand that in that regard.

9 BY MR. LORAINE: But you knew he was

10 also on the City Council at the same time,

11 didn't you?

12 BY MRS. BRIGANCE: Yes, that's kind

13 of what pissed us off.

14 BY MR. BRIGANCE: That was the

15 initial, but we had nobody else express

16 interest in our property, we don't want to

17 still get stuck behind the eight ball and

18 we've got to sell and we've got to get out of

19 our property.

20 BY MR. LORAINE: So that did impress

21 you with the fact that he was going to be a

22 buyer somehow or he was going to make it

23 happen?


25 Q. (By Mr. Loraine) That impressed you. And


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1 when I say impressed you, you were left to

2 believe that he would take care of this

3 problem, get it resolved, and you would not

4 be stuck in a commercial area? I mean you

5 knew that at some point because he had told

6 you?

7 A. We knew that basically if we did not sell now

8 we would be stuck living with the library,

9 all the commercial, everything else if we

10 didn't sell. We were basically be living in

11 a construction zone for however long it takes

12 to build the property and then we'd be stuck

13 with the commercial stuff to do with it, yes.

14 Q. You thought it was inappropriate for a City

15 alderman to be acting in this fashion on your

16 purchase?

17 A. Yes, because he had prior knowledge to the

18 fact that the library and other stuff was

19 going there so he is involved with all the

20 property around it. He basically is

21 monopolizing all the property around it by

22 selling it to this one person or being the

23 broker for this one person, and he's been

24 using almost his prior knowledge.

25 Q. And he's controlling the prices?


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1 A. Correct, he's also controlling the prices.

2 Q. Do you believe that if you would have held

3 out you now would be able to sell your

4 property for more?

5 A. No.

6 BY MR. BRIGANCE: As far as to him or

7 to somebody else?

8 BY MR. LORAINE: To anybody.

9 BY MRS. BRIGANCE: No.

10 BY MR. BRIGANCE: I do not believe

11 anybody else would have come in and bought it

12 because --

13 BY MR. LORAINE: That the City would

14 have, the City would have been forced to buy

15 it.


17 BY MR. LORAINE: Then it's a

18 condemnation matter.


20 BY MR. LORAINE: You're aware of that

21 word condemnation, aren't you?


23 BY MRS. BRIGANCE: Yes.

24 BY MR. LORAINE: And you were aware

25 with them?


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1 BY MRS. BRIGANCE: Yes, that's kind

2 of why we felt stuck that basically if we

3 didn't sell now we weren't going to get what

4 we wanted later.

5 BY MR. BRIGANCE: You kind of take

6 the crumbs and you run or you try to get a

7 little piece of the pie and run that way.

8 BY MRS. BRIGANCE: Because like I

9 said by the time we signed our papers the

10 City owned every bit of the property around

11 us.

12 BY MR. BRIGANCE: But I was with the

13 understanding Woolston is going to make money

14 we sit back and everything we get secondhand

15 as far as to my knowledge. So reading the

16 paper we know that - that was being sold.

17 BY MR. LORAINE: The what?

18 BY MR. BRIGANCE: Coca Cola, used to

19 be on 8th Street down by the flea market

20 area, we knew that property was being sold,

21 okay, and it's funny how - it was a strange

22 coincidence how the next thing you see a

23 little later on in the paper was Four State

24 Homes purchased property right next --

25 BY MRS. BRIGANCE: Dr. Joseph.


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1 BY MR. BRIGANCE: Dr. Joseph which

2 owns Four State Homes has his hand in it.

3 BY MRS. BRIGANCE: He and Four State

4 Homes.

5 Q. (By Mr. Loraine) Who is Dr. Joseph?

6 A. You're going to learn a lot. What's that

7 building, the Griffon Building, he owns that

8 building and I think he owns the majority of

9 the buildings from on down to flea market,

10 all of that. The Coca Cola was going to be

11 sold so I think Joseph ended up buying all

12 that property and somehow Wallace-Bajjali is

13 involved because that's the property that

14 they want to put the post office.

15 BY MR. BRIGANCE: That got released

16 that was to be for the post office, but it's

17 already conveniently owned by --

18 BY MRS. BRIGANCE: Somebody else.

19 BY MR. LORAINE: Dr. Joseph?

20 BY MR. BRIGANCE: Correct, which also

21 is Four State Homes.

22 BY MRS. BRIGANCE: Has his hand in

23 Four State Homes.

24 BY MR. LORAINE: Okay. Anything else

25 you know?


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1 BY MR. BRIGANCE: And just as a

2 citizen driving down the tornado's path from

3 32nd Street east/west, 20th Street, 26th

4 Street --

5 BY MRS. BRIGANCE: Four State Homes.

6 BY MR. BRIGANCE: Four State Homes is

7 buying up property galore down there and

8 that's conveniently where - that whole

9 corridor is also all Wallace-Bajjali is

10 looking at changing, I mean asking the City

11 for one thing or another and it's all popping

12 up with Four State Homes, Four State Homes.

13 BY MR. LORAINE: What does Dr. --

14 BY MRS. BRIGANCE: He had a hand in

15 it. I don't know, he's almost I guess like

16 an investor.

17 Q. (By Mr. Loraine) Well, you know that Charlie

18 owns Four States?

19 A. Yes, Charlie owns Four State Homes.

20 Q. That's Charlie Kuehn?

21 A. Yes.

22 Q. So we now think that they're holding property

23 for Wallace-Bajjali to buy?

24 A. Yes.

25 Q. Okay. So they're accumulating property?


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1 A. They're accumulating property that eventually

2 is sold to the City or somehow --

3 BY MR. BRIGANCE: But how do they

4 know which - but as you drive from 20th

5 Street in that tornado path Four State Homes

6 signs went up and there were Wallace-Bajjali

7 and you don't see hardly any Four State Homes

8 signs. Now the other maybe you can is

9 there's more available there because

10 everybody is trying to sell off and get out

11 while they can or like that, so you have that

12 argument, but other things, too, there was

13 real estate, I mean land, purchased land and

14 stuff, but why are they all Four State Homes?

15 That was kind of weird. And then we know on

16 our side who represents Four State Homes what

17 else is there going on in this area or that

18 area where you see a Four State Homes sign

19 that is the pipeline that somebody is trying

20 to buy it beforehand.

21 Q. (By Mr. Loraine) What was the doctor's last

22 name?

23 A. Joseph.

24 Q. Dr. Joseph, okay.

25 A. And there's about eight of them so just to


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1 let you know.

2 Q. You don't know who the rest of them are?

3 A. It should be Michael, I think is who it is is

4 Michael Joseph, then there's also Richard

5 Joseph.

6 Q. Who?

7 A. Richard, Sr. and Jr.

8 Q. Okay, who else?

9 A. Those are the only ones that I know. Those

10 are the only three men.

11 Q. So we've got four, but we think there's eight

12 though, huh? How do you know that?

13 A. I've grown up in this entire town. My father

14 was a well known doctor.

15 Q. Your dad is a doctor?

16 A. Yes.

17 Q. What's your dad's name?

18 A. Dr. Dandridge.

19 Q. Is he still alive?

20 A. Yes, he is.

21 Q. So somehow you know that there's eight

22 members?

23 A. Well, no, I'm not for sure. I just know that

24 there are - there's a lot of Josephs.

25 Q. But you know that there's more than one owner


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1 to --

2 A. Four State Homes. No, I don't know.

3 Q. So we know Joseph at least?

4 A. I just know that any time you see a Four

5 State Homes property there is a Joseph

6 somehow.

7 Q. And Charlie?

8 A. Yes, Charlie is the one that I know owns Four

9 State Homes.

10 BY MR. BRIGANCE: With this whole

11 thing we figured out Four State Homes buyer.

12 We found out through Mr. Bass that Four State

13 Homes bought his property. This is odd.

14 Here and there and then find out that -

15 assuming they're going to be ones that got

16 our property until we find out later on that,

17 yes, we were, in fact, correct, but just the

18 whole whenever you wash your hands of all

19 this stuff it was like - and we asked them

20 how do you vote in the neighborhood meeting

21 we had, how can you be a realtor and purchase

22 property inside of Springfield when you might

23 know what's going on, but he says I abstained

24 the votes that affects zoning and stuff like

25 that. But I understand his part on that, but


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1 he's going in, buying the property, putting

2 money in his pocket. And I understand he has

3 to make money, I am not disputing that in the

4 slightest, but that's why you buy somewhere

5 away from it just to make sure your hands

6 stay clean or - and if he hasn't done

7 anything unethical. To me he's an unethical

8 person just because you know too much was

9 going back.

10 Q. (By Mr. Loraine) You don't know if it's

11 illegal?

12 A. Yes.

13 Q. But you don't know how much he's getting on

14 the side or if he is?

15 A. Correct.

16 BY MR. BRIGANCE: Correct. But as a

17 City Councilman I would assume he had a

18 little window, snippets here or snippets

19 there or what's going on and what's not going

20 on, and it just looks - and whenever we heard

21 the investigation being focused on Dr.

22 Rosenberg we were like, good, somebody else

23 has raised enough concerns to where it's not

24 just us that feels this way.

25 BY MR. LORAINE: And I assume there


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1 are people in your community, your old

2 neighbors that feel this way?

3 BY MR. BRIGANCE: From 18th Street to

4 the south has all been purchased, okay? Now

5 from house it goes back 200 feet, 175 feet,

6 back behind those, those houses were

7 approached, some of those were. One of those

8 neighbors directly behind us, his last name

9 is Burton, he was never approached.

10 BY MRS. BRIGANCE: Those two were

11 never approached.

12 BY MR. BRIGANCE: But Cupp --

13 BY MRS. BRIGANCE: No, you have

14 Palmer and then Cupp. And Cupp has been

15 approached I think directly from

16 Wallace-Bajjali because she has property from

17 18th almost all the way to 20th. She is the

18 one property that stands in the way from the

19 City owning --

20 BY MR. LORAINE: And what's her name?

21 BY MRS. BRIGANCE: Her last name is -

22 her name is Katie Cupp and she's almost 90

23 years old.

24 BY MR. BRIGANCE: So to say that as

25 far as anybody else down on 18th Street as


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1 far as to the best of our knowledge none of

2 them have received any letters.

3 Q. (By Mr. Loraine) Who is Bryant? Have you

4 ever heard the name Bryant, B-R-Y-A-N-T?

5 A. Bryant? Huh-uh.

6 Q. Last name.

7 BY MR. BRIGANCE: It clips in there,

8 but I don't know where for sure.

9 Q. (By Mr. Loraine) Is there anything else you

10 want to tell me?

11 A. I don't know because I know his name Irish

12 (inaudible).

13 BY MR. BRIGANCE: And I don't know if

14 it's kind of weird, too, on the corner of

15 Murphy and 20th Street where they kind of

16 make like it a little triangle ledge and the

17 doctor that had purchased that was going to

18 put --

19 BY MRS. BRIGANCE: Going to put up

20 her practice there.

21 BY MR. BRIGANCE: She was going to

22 put up her practice there. And that

23 property, I don't think he had a for sale

24 sign on it.

25 BY MRS. BRIGANCE: It never had a for


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1 sale sign, but --

2 BY MR. BRIGANCE: And she purchased

3 it and shortly after she purchased it

4 everything I got from Box was nothing was

5 going on further on that side, that corner

6 there, just like the little park and

7 everything like that.

8 BY MRS. BRIGANCE: But it did go to

9 get rezoned and it did get that, but past

10 that nothing has happened.

11 Q. (By Mr. Loraine) Rezoned residential?

12 A. Commercial.

13 Q. And that would have come before the City?

14 A. The City.

15 Q. And what is her name?

16 A. I couldn't tell you what her name is, I'm

17 sorry.

18 Q. It's a doctor and does she have an office

19 there now?

20 A. No, there's nothing there.

21 Q. But it is zoned commercial?

22 A. As far as I know it is zoned commercial. And

23 there's a few other bits along 20th Street

24 that have been put up to rezone.

25 Q. And all of those votes, you wonder about how


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1 Mr. Woolston would have voted?

2 BY MR. BRIGANCE: Correct, because as

3 of now the way we understand it from the -

4 there's a church there on 20th Street and

5 that church all the way west towards

6 Connecticut is all City property now.

7 BY MRS. BRIGANCE: Well, it is either

8 between City property and Four State Homes

9 property, somewhere in between all that.

10 BY MR. LORAINE: Or Wallace-Bajjali?

11 BY MRS. BRIGANCE: Or

12 Wallace-Bajjali, yes.

13 BY MR. LORAINE: Okay. Anything

14 else?

15 BY MRS. BRIGANCE: Not that I can

16 think of.

17 BY MR. BRIGANCE: We'll get a phone

18 number for you for --

19 BY MRS. BRIGANCE: I need Gale's

20 number. He's on vacation. I think he went

21 on vacation today. I can still get you the

22 number, though.

23 BY MR. LORAINE: Gale Bass?

24 BY MRS. BRIGANCE: No, Gale Wade.

25 He's the 19th and Jersey.


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1 BY MR. LORAINE: The other name was?

2 BY MR. BRIGANCE: Bonnie Wright.

3 BY MR. LORAINE: And you'll call both

4 of those for me, give them my number?


6 Q. (By Mr. Loraine) Let me give you a card. I

7 would particularly be interested to talk to

8 Bonnie, if she will, because she'll have some

9 insight, but I don't know whether she will or

10 she won't. Here are a couple of my business

11 cards and if you can call me at that number

12 or I can give you my cell number if you'll

13 take that down. Is that on there, the cell

14 number?

15 A. No.

16 Q. I probably shouldn't be giving that. If you

17 can just call that number, you know, that

18 would be fine. The 573 number there,

19 348-8909.

20 A. Yes, that's on here.

21 Q. There is a number - we knew that, didn't we?

22 There's a City number, but I don't know the

23 number of it yet.

24 A. I only know the City Attorney's number.

25 Q. Yes, that will work. Okay, thank you for


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1 coming in.

2 A. You're welcome.

3 Q. I'm going to hand you back Exhibit #26. This

4 is the Contract for Sale on the residential

5 property we've talked about earlier and it

6 appears to be 7 pages long. Do you agree with

7 that?

8 A. Yes.

9 Q. Marked #26?

10 A. Yes.

11 Q. This concludes this. I appreciate you coming

12 by.

13 (SWORN STATEMENT CONCLUDED)

14

15

16


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REPORTER'S CERTIFICATE

STATE OF MISSOURI

ss.

COUNTY OF JASPER

I, SHARON K. ROGERS, Certified Court Reporter in the

State of Missouri, do certify that pursuant to the

foregoing Stipulation the witness came before me on the

14th day of November, 2013, was duly sworn by me, and was

examined. That examination was then taken by me by

steno-mask recording and afterwards transcribed; said Sworn

Statement is subscribed by the witness as hereinbefore set

out on the day in that behalf aforesaid and is herewith

returned.

I further certify that I am not counsel, attorney, or

relative of either party, or clerk, or stenographer of

either party or of the attorney of either party, or

otherwise interested in the event of this suit.

_________________________

SHARON K. ROGERS, CCR-650

brigance, alisha and dustin | testimony transcript

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