chris jackson testimony
TRANSCRIPT
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1 later point asked for reconsideration of the vote. There
2 has been no further -- there was no further testimony
3 regarding the disposition of the motion for reconsideration,
4 the request for reconsideration.
5 Secondly, Mr. St. John testified that when
6 Mr. Riddle's request for the $25,000 was voiced and
7 Mr. St. John said no, Mr. Riddle showed no reaction.
8 Third, the last witness, Mr. Hall, never worked in
9 any of the -- never performed in any of the clubs.
10 Thank you.
11 Let's go ahead.
12 MR. GARDEY: The United States calls Chris Jackson
13 as a witness.
14 THE COURT: In front of me, sir. Raise your right
15 hand.
16 - - -
17 CHRISTOPHER JACKSON,
18 being first duly sworn by the Court to tell
19 the truth, was examined and testified upon his
20 oath as follows:
21 - - -
22 DIRECT EXAMINATION
23 BY MR. GARDEY:
24 Q. Mr. Jackson, if you could pull the microphone down.
25 That's good.
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1 Please state your full name for the record and
2 spell your last name.
3 A. Christopher Troy Jackson, J-a-c-k-s-o-n.
4 MR. GARDEY: Your Honor, at this time the
5 government would move Exhibits 22A through E and Exhibit 23
6 into evidence. Those are the Deja Vu exhibits.
7 THE COURT: Hold on. 22?
8 MR. GARDEY: 22A through E.
9 THE COURT: Admitted.
10 MR. GARDEY: And Exhibit 23.
11 THE COURT: Admitted.
12 BY MR. GARDEY:
13 Q. Mr. Jackson, how are you employed?
14 A. I am self-employed.
15 Q. What is your business?
16 A. I own a couple of businesses. One is Jackson
17 Consulting Group, L.L.C. I am also a partner in Paradise
18 Valley Partners. I am a partner in Queen Lillian, L.L.C.,
19 and I am also a partner in Detroit Credit Card ATM
20 Processing, L.L.C.
21 THE COURT: Pull the mike a little closer to you.
22 The chair doesn't move so we have to move the mike or the
23 body.
24 BY MR. GARDEY:
25 Q. Where are you from originally?
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1 A. Detroit, Michigan.
2 Q. Were you born and raised here?
3 A. Yes, I was.
4 Q. What's your educational background?
5 A. Went to grade school here in Detroit, St. Phillips
6 Lutheran School. Went to Cass Tech High School, graduated
7 from Cass Tech High School. Went to Howard University,
8 received a degree there. Upon graduating I actually
9 attended the University of Detroit Law School, did not
10 graduate, did three years there.
11 Q. Now, after, what do you do after you left law school?
12 A. While I was in law school, I was actually in law school
13 part time. I was working in the employ of Detroit City
14 Councilman Gil Hill. I started working there upon
15 graduating from Howard University.
16 Q. What year did you start working for Councilman
17 Gil Hill?
18 A. I believe it was 1991.
19 Q. Was that Detroit City Council?
20 A. Yes.
21 Q. When you started with Councilman Hill's office, what
22 was your position?
23 A. At that time I was an administrative assistant handling
24 legislative affairs.
25 Q. How long did you work for Councilman Hill?
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1 A. Approximately about eight years, seven years.
2 Q. What year did you leave Councilman Hill's?
3 A. Somewhere around 1997.
4 Q. Did you hold any other positions with Councilman Hill?
5 A. Upon my last two years I was his chief of staff.
6 Q. What did you do after you left Councilman Hill?
7 A. When I left Councilman Hill, I started Jackson
8 Consulting Group. I also served in a consulting capacity
9 and then later as a partner in Monroe Partners, 400 Monroe
10 Associates and then later Monroe Partners, which then later
11 on became one of the 50 percent owners of Greektown Casino,
12 and I was a partner in that company.
13 Q. So did you leave Councilman Hill and start Jackson
14 Consulting approximately in 1987?
15 A. Yes.
16 Q. And so you have been working partly as Jackson
17 Consulting from 1997 to the present?
18 A. Yes.
19 Q. What kind of work does Jackson consulting do?
20 A. Jackson Consulting is a government relations consulting
21 firm primarily focusing on assisting clients in the
22 financial sector.
23 Q. How about back in the fall of 2006, what kind of work
24 did Jackson Consulting do?
25 A. 2006 or 2007?
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1 Q. In 2006.
2 A. Well, I did not have Jackson Consulting while I was
3 still in the employ of --
4 Q. I'm sorry, in 2006, not 1996.
5 A. I'm sorry, I'm sorry, I thought you said 1996. In 2006
6 Jackson Consulting was again focusing on clients in the
7 financial arena. At that time there was one client I
8 believe that Jackson Consulting had that was outside of the
9 finance arena that was in the sort of public schools or in
10 the schools markets, but for the most part most of
11 Jackson Consulting's clients were in the finance arena.
12 Q. And when you say Jackson Consulting's clients were in
13 the finance arena, what type of work did you do for your
14 finance clients?
15 A. Most of my clients were asset management firms, hedge
16 funds, money management firms, real estate management firms.
17 We primarily do business with Detroit's pension funds, Wayne
18 County's pension fund, as well as other pension funds around
19 the country.
20 Q. And what kind of work did you do for these clients?
21 A. I would assist my clients, the asset management clients
22 in actually obtaining asset allocations from pension funds
23 to manage the pension fund's dollars or in the case of hedge
24 funds or private equity funds Jackson Consulting would
25 assist those clients in obtaining dollars that would be
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1 invested into those hedge funds or private equity funds.
2 Q. Now, you mentioned earlier that you are also the owner
3 of the Detroit Credit Card Processing Company?
4 A. Yes, sir.
5 Q. And how long have you owned that company?
6 A. Detroit Credit Card/ATM Processing roughly I believe
7 was started back in 2000/2001.
8 Q. And that business was active in 2006?
9 A. Yes.
10 Q. What kind of work does that company do, Detroit Credit
11 Card/ATM Processing?
12 A. Detroit Credit Card/ATM Processing owns ATM machines,
13 has an interest in securing clients, if you will, for credit
14 card processing from businesses, restaurants, entertainment
15 venues and the like.
16 Q. In 2006 did you have a relationship with a bank for
17 purposes of your credit card processing business?
18 A. Yes. My partner -- or I should say Detroit Credit
19 Card/ATM Processing's partner was First Independence Bank.
20 Q. And was it First Independence Bank's job to process
21 credit card transactions that you were handling with either
22 MasterCard or Visa or other banks around the country?
23 A. Yes.
24 Q. And how is it you would make money off of your
25 business, the Detroit Credit Card Processing and ATM
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1 business.
2 A. The ATM business, for every transaction that a customer
3 would use an ATM machine we charge a transaction fee. For
4 the credit card processing there is a small transaction fee.
5 When a person uses a credit card at a point of sale, a place
6 of business, there is a small transaction fee that is
7 charged to that company that is actually using the
8 processing services.
9 Q. Now, today, Mr. Jackson, do you have any agreements
10 with the United States Government in connection with your
11 testimony today?
12 A. Yes, I have an immunity agreement.
13 Q. Do you have a use immunity agreement with the
14 United States?
15 A. Yes.
16 Q. What is your understanding of the terms of that
17 agreement?
18 A. My understanding of the terms of that agreement is to
19 tell the truth. If in fact I violate any of those terms as
20 it relates to telling the truth, I will perjure myself. So
21 roughly it's to tell the truth.
22 Q. And what is your understanding as to whether or not the
23 government can use what you say in your testimony today
24 against you at a later criminal proceeding?
25 A. It's my understanding that they cannot.
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1 Q. And what happens if you lie during your testimony
2 today? Would the government be able to use your testimony
3 today against you in a later criminal proceeding?
4 A. Yes.
5 Q. Now, Mr. Jackson, let me direct your attention back to
6 the fall of 2006. At that time did you do some work for
7 Deja Vu Consulting?
8 A. Yes, I did.
9 Q. And what kind of business is Deja Vu Consulting in?
10 A. My understanding is that Deja Vu is in the business of
11 adult entertainment.
12 Q. Is that strip clubs?
13 A. Yes.
14 Q. What was the purpose of your work for Deja Vu
15 Consulting?
16 A. I was asked to consider representing Deja Vu. It
17 actually was back in September of '96. I was approached by
18 a Renee Pipis, who was another government relations
19 consultant, who asked me to look into working with this
20 group as it relates to transferring a license, an existing
21 license from one owner to a new owner. I actually, when I
22 asked to look at consulting in that regard, that was not
23 necessarily my forte, if you will. I informed her that my
24 practice was more so in the finance arena, but I did agree
25 to look into some due diligence, initial due diligence into
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1 the matter.
2 Q. You said, you testified 1996. Did you mean to say
3 2006?
4 A. 2006. I'm sorry, sir.
5 Q. And that was in September 2006?
6 A. Yes.
7 Q. And you say you were proposed by a Ms. Pipis?
8 A. Yes.
9 Q. What was your understanding who she was working with?
10 A. She actually had been consulted or contacted by State
11 Representative Barb Ferrer. It's my understanding she
12 represented some downriver communities. She had brought to
13 her attention the issue of the Deja Vu, and they had
14 previously been turned down as it relates to the transfer of
15 the license maybe back in 2003, and I believe Representative
16 Ferrer contacted Ms. Pipis and asked if this was something
17 that she could assist in, could she help. Ms. Pipis, in
18 turn, contacted me.
19 From there I was given a series of some white
20 papers and other historical documentation relative to the
21 whole license transfer of the ownership from Ms. Pipis as
22 well as some things even faxed to me from Barb Ferrer's
23 office.
24 Q. Now, after you were contacted by Ms. Pipis did you have
25 meetings with people from Deja Vu?
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1 A. Yes, I did.
2 Q. Who did you meet with from Deja Vu?
3 A. I believe it was Gary Koloszar, Mr. Hall and
4 Mr. St. John.
5 Q. Is that Jim St. John and Joseph Hall?
6 A. Yes.
7 Q. And what was the purpose of your meeting with Mr. Hall,
8 Mr. St. John, and Mr. Koloszar?
9 A. To get background information on this particular case
10 as part of my due diligence. I wasn't sure at that time if
11 I would even consider representing them as a consultant, but
12 to get all the information possible.
13 Q. Did you come to any kind of agreement with the people
14 at Deja Vu concerning your working for them?
15 A. We actually had come to a verbal agreement of sorts. I
16 had actually proposed, because this was something sort of
17 outside of my general consulting practice, that my interest
18 was to -- versus a basic consulting arrangement, I was
19 looking for being able to grow my credit card/ATM processing
20 business and so I had proposed to them that sort of in lieu
21 of consulting fees being able to do business, if I assisted
22 them, to be able to do business either having ATM machines
23 in their various facilities around the country as well as
24 credit card processing business.
25 Q. And would that have been a significant investment or
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1 was that of significant worth to you in your credit card
2 processing company if you had been able to get that from
3 Deja Vu?
4 A. Yes.
5 Q. Did they also offer you an opportunity to buy an
6 option, an ownership interest in the Deja Vu facility in
7 Detroit?
8 A. Yes. Later on there were discussions with myself and
9 those gentlemen as it relates to an ownership interest in
10 the Deja Vu Detroit property.
11 Q. Were you interested in getting an ownership interest in
12 Deja Vu?
13 A. That was not really my interest. I really had no
14 interest in being in the strip club business. I was more so
15 focused on the credit cart processing business and the ATM
16 business.
17 Q. Why weren't you interested in being a part owner of a
18 strip club business?
19 A. Well, I don't think my wife would have thought it was a
20 great idea, but it was just not something that I truly had
21 a lot of experience in. I had been in the entertainment
22 business, if you will, in the gaming business, and I had
23 just actually transitioned out of that business and had sold
24 my interest not long prior to this. And so I was really
25 just, really more so focused on growing my ATM and credit
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1 card processing business.
2 Q. And you mentioned you had an interest in gaming. Was
3 that with 400 Monroe Partnership?
4 A. Yes 400 Monroe later became Monroe Partners, and Monroe
5 Partners had a 50 percent ownership interest in Greektown
6 Casino.
7 Q. But at the time in 2006 you had sold your interest in
8 Greektown Casino?
9 A. Yes. I actually had made provisions to sell my
10 interest, yes.
11 Q. Based on your meetings with Mr. Hall and Mr. St. John,
12 what was your understanding of what you were supposed to do
13 for Deja Vu?
14 A. My understanding was to, one, the first step was to
15 make contact with the City, in particular the City's Law
16 Department. I did contact John Johnson at the time, who was
17 the counsel for the City of Detroit, to do some initial due
18 diligence as to what was the City's legal position as
19 relates to the transfer of the license. The gentleman had
20 shared with me that if in fact the license was not
21 transferred they were going to continue on with their
22 litigation against the City of Detroit in federal court on
23 some constitutional grounds as relates to the denial of the
24 transfer. So the first step was to talk with John Johnson
25 to find out in fact if the City felt that it was from a
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1 legal perspective prudent to effectuate the transfer.
2 Next was to --
3 Q. Well, first let me ask a couple of questions about
4 that.
5 A. Sure.
6 Q. So in September of 2006 it was your understanding that
7 there was ongoing litigation between Deja Vu and the City of
8 Detroit about Deja Vu opening a club in Greektown in the
9 City of Detroit?
10 A. Yes.
11 Q. And you were to try to convince the City Council and
12 the City to grant the license instead of proceeding with the
13 litigation; is that correct?
14 A. Yes.
15 Q. Now, you said you met with Mr. Johnson from the City of
16 Detroit Law Department?
17 A. Yeah, I actually contacted Mr. Johnson. We had a
18 meeting scheduled. Something came up the day of the
19 meeting. We did talk by phone and had some conversation
20 relative to the issue, and it appeared to me that he did
21 understand some of the legal issues and potential
22 culpability that the City may have if in fact there were --
23 if Deja Vu prevailed on the litigation.
24 Q. Now, before Deja Vu started working with you did you
25 have any understanding as to whether Deja Vu had met with
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1 any of the members of the City Council?
2 A. I had not. I don't think I knew they had met with
3 council prior to that.
4 Q. Did you arrange any meetings with members of City
5 Council in order to convince them to approve the license for
6 Deja Vu?
7 A. Yes, I arranged a number of meetings.
8 Q. What meetings did you arrange?
9 A. I believe the first meeting we had was with Barbara,
10 Councilwoman Barbara Rose Collins.
11 I don't know the exact order, but I know we met
12 with Councilwoman Sheila Cockrel. We met with Councilwoman
13 Martha Reeves. We met with Cockrel, Reeves, Councilwoman
14 Alberta Tinsley-Talabi. I had spoken with a staff member of
15 Councilman Cockrel, but we did not, could not get a meeting
16 scheduled, and I had also spoken with Councilwoman
17 Monica Conyers and had a meeting scheduled.
18 Q. So did you reach out to Councilwoman Monica Conyers to
19 try to set up a meeting with Deja Vu?
20 A. Yes.
21 Q. Now, these meetings that you talked about with these
22 other councilpeople, who was at those meetings?
23 A. From a staff standpoint or from?
24 Q. From Deja Vu.
25 A. Deja Vu. I believe Joe Hall was at all of the
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1 meetings. I believe Mr. St. John was at all or at most of
2 the meetings as well.
3 Q. And were you trying to work with Deja Vu to convince
4 these members of the City Council to approve the transfer of
5 the license so that they could open their club?
6 A. Yes.
7 Q. And the members of the City Council you met with, were
8 they receptive to your request?
9 A. In most cases they were able to separate the emotional
10 component of a strip club and the entertainment side of it
11 from the legal issue, which was that the license, the
12 cabaret D license already existed at that particular
13 location and this was just a matter of a transfer of
14 ownership and so that they could not stop that location from
15 having a license. And many of them, many of them maybe
16 initially did not fully understand that, but it seemed like
17 after our meetings that that became clear and that this was
18 really not a morality issue, but it was really more of a
19 legal issue.
20 Q. Did you also discuss the possibility that the City
21 could face damages from the litigation if they went forward
22 with the litigation?
23 A. We shared with them in those meetings that these very
24 same type of cases have occurred and that I believe Deja Vu
25 had even been involved in litigation in other parts of the
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1 country with other major cities and those cities had lost in
2 these type of transfer cases and there were significant
3 damages and that in this case what we tried to prevail on
4 them is that it was better to move forward or allow the
5 transfer versus putting the City in harm's way.
6 Q. Were there some members of City Council who would not
7 meet with you or who you believed were against the transfer
8 of the license?
9 A. Yes.
10 Q. And who were those?
11 A. We were not able to arrange a meeting with Ken Cockrel.
12 We were not able to arrange a meeting with Councilman
13 Kenyatta or Councilwoman Watson. I'm trying to think who
14 does that leave?
15 All of the people we met with we were -- were the
16 ones we felt were receptive. I think those were three that
17 we were not able to arrange a meeting with. And I am sorry,
18 Councilwoman Jones, we were not able to arrange a meeting
19 with Councilwoman Jones.
20 Q. Why did you want to meet with Councilwoman
21 Monica Conyers?
22 A. To be able to go through the same issues with her as we
23 would have gone through with the other council members.
24 Q. Did you actually set up meetings with Ms. Conyers and
25 the people from Deja Vu?
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1 A. Yes, we did have a meeting scheduled.
2 Q. Did you meet with her?
3 A. No, I did not meet with her.
4 Q. Why is that?
5 A. I either ran into her or either received a phone call,
6 I cannot recall exactly how it came about, but I did talk
7 with her and she had shared with me that she was not able to
8 make the appointment, that I was still supposed to, should
9 still come to her office and that I would be meeting with
10 somewhere there at her office.
11 Q. Had you had any prior contact, relationship with
12 Mrs. Conyers or her husband?
13 A. I had had contact with her just in my regards of being
14 a consultant, being in city hall, being involved in city
15 government.
16 Q. Now, you said you ran into Ms. Conyers and she had
17 cancelled the meeting. What happened next?
18 A. Well, the meeting -- or I still went to her office as
19 instructed. When I got to her office, I met in her actual
20 office with Mr. Sam Riddle to discuss. It was understood
21 that he was there to receive me to discuss the issues
22 relative to Deja Vu.
23 Q. Did Ms. Conyers tell you why she wanted you to meet
24 with Sam Riddle?
25 A. That he was her representative.
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1 Q. And at that time what was your understanding of the
2 relationship between Sam Riddle and Monica Conyers?
3 A. At that time it was a little unclear. I had heard some
4 rumors sort of out in the consulting community, you know,
5 out throughout Detroit that, you know, that there was a
6 relationship between Ms. Conyers and Mr. Riddle. I know at
7 one time --
8 MR. WISHNOW: I'll object to this, Your Honor.
9 THE COURT: Well, he's answered the question.
10 Let's wait for the next question.
11 BY MR. GARDEY:
12 Q. Mr. Jackson, did you have any understanding as to
13 whether Mr. Riddle held any position within Ms. Conyers'
14 office?
15 A. I know at one time he was her chief of staff. At one
16 time he had been her campaign manager. I was not exactly
17 sure if that was -- I would assume that was the capacity
18 that he was in on that day.
19 Q. Now, the day you met with Mr. Riddle -- is
20 Mr. Riddle --
21 Do you know Mr. Riddle?
22 A. Yes.
23 Q. Is he here in the courtroom?
24 A. Yes.
25 Q. Could you please point him out and describe something
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1 he's wearing?
2 A. He has on an argyle sweater and a blazer.
3 MR. GARDEY: Let the record reflect that the
4 witness has identified the defendant, Mr. Riddle.
5 BY MR. GARDEY:
6 Q. Now, you said you met with Mr. Riddle in Ms. Conyers',
7 her personal office?
8 A. Yes.
9 Q. Now, each member of the City Council has offices in the
10 City/County Building; is that correct?
11 A. That is correct.
12 Q. And within those offices there is an office for,
13 personal office for the City Council members; is that
14 correct?
15 A. Yes.
16 Q. And you met with Mr. Riddle in her actual office?
17 A. Yes.
18 Q. And Ms. Conyers was not present?
19 A. No.
20 Q. Where did you sit within the office?
21 A. There is a small round conference table in her office.
22 We both sat at the conference table.
23 Q. Was anybody else present beside you and Mr. Riddle?
24 A. No.
25 Q. And some time ago you had been an intern for
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1 Mrs. Conyers' husband?
2 A. Yes.
3 Q. And when was that?
4 A. Back in the spring of '87 roughly through about '99.
5 Maybe spring of '99.
6 Q. Is that spring of '87 to '89?
7 A. I'm sorry, '89, '89, yes.
8 Q. Is that when you were in college?
9 A. Yes, when I was at Howard University.
10 Q. Why did you go to the meeting with Mr. Riddle without
11 anyone from Deja Vu?
12 A. Because we were not meeting with what I considered the
13 principal and we were meeting with a staff person, a little
14 bit not sure exactly what direction that meeting was going
15 and I thought it was best that I meet with him myself.
16 Q. And if you had met, when you had scheduled a meeting
17 with Ms. Conyers, had you planned to have someone from
18 Deja Vu with you at that meeting?
19 A. Yes.
20 Q. Now, at that meeting in Mrs. Conyers' office did
21 Mr. Riddle tell you or say anything about what his current
22 relationship was with Mrs. Conyers?
23 A. I, I actually was, you know, a little curious about
24 that myself because of the rumors I have heard out there.
25 He shared with me, you know, that, it may not be an exact
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1 quote, but, you know, that they couldn't necessarily always
2 get along. I think he might have used the word crazy. He
3 said that, you know, he was her chief of staff but that they
4 had to have a different relationship.
5 Q. What happened during your meeting in Mrs. Conyers'
6 office with Mr. Riddle?
7 A. Well, we talked about a number of things. I believe he
8 started out the meeting. He suggested a couple of books for
9 me to read. I'm not sure how we got on that subject. I
10 know one was A State of Denial and the other one was -- I
11 can't recall what the second book was off the top of my
12 head.
13 We talked about a gentleman who actually worked in
14 Councilman Gil Hill's office, Greg Robinson. He asked me
15 about his work ethic. I guess he or Mrs. Conyers was
16 considering hiring him or either he had been hired, I am not
17 sure if he was in her employ at that time, but wanting to
18 know sort of as a reference or referral what did I think of
19 them hiring him.
20 Q. Mr. Riddle asked you about a Greg Robinson who you knew
21 from Gil Hill's office when you worked for Gil Hill; is that
22 correct?
23 A. Yes.
24 Q. And Mr. Riddle was asking you basically as a reference.
25 What is your understanding as to whether Mr. Robinson was
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1 applying for work with Mrs. Conyers' office?
2 A. Yes.
3 Q. And after talking about books and the reference for
4 Mr. Robinson, did you talk about the Deja Vu issue?
5 A. Yes, we did.
6 Q. What did Mr. Riddle say about that?
7 A. It seems to me that he understood the legal issues that
8 were at hand. Mr. Riddle, you know, being an attorney or
9 having been to law school, he seemed to understand the legal
10 issues. He thought that it was something that possibly
11 could be something that she may be able to support, and we
12 had agreed that we would get together outside of the office
13 to discuss it further.
14 Q. Did he say why he wanted to meet with you outside of
15 Mrs. Conyers' office to discuss it further?
16 A. I got the impression that because he had a Meridian
17 Management business that we were sort of switching into more
18 a discussion as a consultant that it would probably be more
19 prudent to discuss that somewhere else.
20 Q. What did Mr. Riddle say about Meridian Management?
21 A. Meridian Management was a consulting firm that he had,
22 and Meridian Management was an entity that, you know, might
23 be able to -- that he suggested that could help in this
24 regard.
25 Q. Did you arrange to have a second meeting with
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1 Mr. Riddle after that first meeting at Mrs. Conyers' office?
2 A. Yes.
3 Q. Where did that meeting, the second meeting take place?
4 A. That meeting took place at the Click Restaurant.
5 Q. Where is the Click Restaurant?
6 A. Click is on East Jefferson just east of I-75 freeway on
7 the south side of Jefferson.
8 Q. Now, this first meeting with Mr. Riddle in
9 Mrs. Conyers' office, was that in October of 2006?
10 A. I believe that sounds right, yes.
11 Q. Now, how soon after your first meeting did you have a
12 second meeting with Mr. Riddle at the Click?
13 A. I don't believe it was too long, days.
14 Q. Was it breakfast, lunch? What kind of meeting was it?
15 A. It was a breakfast meeting.
16 Q. And who was there at that second meeting?
17 A. At that meeting it was just myself and Mr. Riddle.
18 Q. Now, what did you discuss with Mr. Riddle at the
19 meeting at Click?
20 A. At the meeting at the Click there was more focus on
21 Meridian Management. Sam went into sort of a, what I call a
22 commercial, if you will, of the accomplishments of Meridian
23 Management or himself. He talked about Columbine and his
24 successes there in Colorado after that tragedy in assisting
25 I believe families there. He talked about some of the work
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1 he had done with Meridian and that -- the value that he
2 could add, that if in fact if Meridian was brought into this
3 that Meridian could help, help us secure support from
4 Councilwoman Conyers.
5 Q. Did Mr. Riddle say whether or not Deja Vu would have to
6 hire Meridian Management in order to get Mrs. Conyers' vote?
7 A. Yes.
8 Q. What did he say?
9 A. He laid out a couple of scenarios, one being that
10 Meridian -- if in fact we didn't have Meridian, and clearly
11 I think he had done some due diligence and saw that, took
12 the temperature where the council was and where sort of the
13 splits were and where the various councilpeople were going
14 to be voting one way or another and that her vote was sort
15 of a key vote and Meridian would be necessary in order to
16 secure her vote which probably could be the key swing vote.
17 Q. Did Mr. Riddle say what would happen if Deja Vu did not
18 hire Meridian Management?
19 A. Well, I got the impression that --
20 MR. WISHNOW: Objection, Your Honor.
21 THE COURT: Wait a minute.
22 MR. WISHNOW: I'm sorry, he's talking about his
23 impression.
24 THE COURT: The question was: Did Mr. Riddle say
25 what would happen if Deja Vu did not hire Meridian? Did he
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1 say something? Not your impression. Did he say something?
2 THE WITNESS: Yes.
3 THE COURT: What did he say?
4 THE WITNESS: We wouldn't get Monica Conyers'
5 support.
6 THE COURT: Go ahead.
7 BY MR. GARDEY:
8 Q. And what would happen if Deja Vu did not hire Meridian?
9 A. We would not get the councilwoman's support. In
10 addition to that, she could actively work against us getting
11 support even from other people, that she would work actively
12 against Deja Vu.
13 Q. Did Mr. Riddle describe at this meeting at the Click
14 what Monica Conyers would do to act actively against the
15 Deja Vu project if Meridian wasn't hired?
16 A. Well, that could happen in a couple of ways based on
17 our conversation. One, if in fact Deja Vu and I guess our
18 discussion also went into a maintenance contract, if you
19 will, and that was an ongoing relationship with Meridian
20 Management, that if in fact the transfer did occur there was
21 going to be a need for ongoing consultation because
22 establishments of that type could also run into problems
23 with zoning and licensing and the actual employees of those
24 facilities could be ticketed or the facility itself could be
25 ticketed and there would be a need or should be, there
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1 probably could be a need and you want to be preventive in
2 that regard from any of that occurring.
3 Q. Did you take that as a threat?
4 A. Yes.
5 Q. Why is that?
6 A. I took it as a threat because council president pro tem
7 I believe at that time having influence that there are many
8 gray areas as it relates to those type of establishments and
9 that if, using her influence, be it with City officials,
10 police department, that kind of thing, that if an elected
11 official really has an issue with a place that operates what
12 I call sort of in the gray there is a possibility that
13 places could be ticketed and there could be retribution.
14 Q. So Mr. Riddle had offered -- first he wanted Deja Vu to
15 hire Meridian Consulting to get the vote, get the vote of
16 Mrs. Conyers at the City Council's vote on the transfer of
17 the license; is that correct?
18 A. Yes.
19 Q. And then, secondly, he also wanted Deja Vu to hire
20 Meridian on a continuing basis going forward at the time to
21 protect Deja Vu from Mrs. Conyers?
22 A. Yes.
23 Q. Did Mr. Riddle give you a price for what he wanted from
24 Deja Vu?
25 A. $25,000.
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1 Q. Now, when, back in the '90's when you were the chief of
2 staff to Gil Hill did you ever act as a consultant on a
3 matter that was pending before the City Council?
4 A. No.
5 Q. Why not?
6 A. You cannot wear two hats at the same time. You can't
7 have -- you can't be advising --
8 MR. WISHNOW: I'll object to the basis for this
9 witness' opinion as to that without a proper foundation.
10 THE COURT: What foundation do you want laid?
11 MR. WISHNOW: Whatever expertise he has in this
12 area. I believe when you talk about gray areas that may be
13 one. He's giving his opinion.
14 THE COURT: The objection is overruled. Go ahead.
15 BY MR. GARDEY:
16 Q. Mr. Jackson --
17 MR. GARDEY: I don't know if he had already
18 answered the question.
19 THE COURT: No. Start over.
20 BY MR. GARDEY:
21 Q. Mr. Jackson, back in the '90's you were the chief of
22 staff for Gil Hill, a member of Detroit City Council; is
23 that correct?
24 A. Yes.
25 Q. And while you served for Mr. Hill did you ever take on
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1 consulting work or other work pending before the City
2 Council?
3 A. No.
4 Q. And why didn't you do that at that time?
5 A. It was a conflict of interest. You cannot work in the
6 office of an elected official advising that person as
7 relates to decisions that they make and at the same time
8 represent individuals who are doing business or who are
9 asking or looking for support or guidance as relates to
10 those decisions and so I understood that there was a line
11 there that either you work in the public sector or you are
12 in the private sector. That is why I left when I left the
13 councilman's office and I started a consulting firm and did
14 use my, you know, background in government affairs outside
15 of government.
16 Q. Now, you testified that Mr. Riddle had said that he
17 wanted $25,000 at the Click Restaurant, and based on your
18 experience as the chief of staff for a City Councilman and
19 later as a consultant, what was your opinion as to the price
20 of $25,000?
21 A. I thought it was excessive.
22 Q. In fact, did you hire anyone else to assist your work
23 for Deja Vu in the fall of 2006?
24 A. Yes.
25 Q. Who was that?
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1 A. Adolph Mongo.
2 Q. And who is Adolph Mongo?
3 A. Adolph Mongo is a government relations marketing
4 consultant here in Detroit.
5 Q. And what did you pay Mr. Mongo to assist you with the
6 Deja Vu work in the fall of 2006?
7 A. $1,500.
8 Q. Did Mr. Mongo have any experience in connection to
9 strip clubs and their business before the City Council in
10 Detroit?
11 A. Actually he did. It came to my attention that
12 Mr. Mongo had previously represented one, if not maybe
13 two other clubs, if you will, relative to the same issue of
14 a transfer of a license from one owner to another. He had
15 been successful in his endeavor to do that. This was more
16 so after the fact I learned this later on and so I thought
17 it could be prudent as a subcontractor to hire Mr. Mongo to
18 assist me since he had previously talked to councilpeople
19 and had been able to lay out that case, make a forthright
20 case as it relates to the transfer, the legal issues of law.
21 Q. And Mr. Riddle, based on what Mr. Riddle told you and
22 your knowledge of Mr. Riddle, did Mr. Riddle have any
23 experience with adult entertainment licenses and the
24 transfer of such licenses?
25 A. No.
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1 Q. Based on Mr. Riddle, what Mr. Riddle told you, did you
2 leave that meeting at the Click with any certainty as to
3 whether you would get Mrs. Conyers' vote if you hired
4 Mr. Riddle as a consultant?
5 A. I felt confident that if he was hired we would have her
6 support, yes.
7 Q. After your second meeting with Mr. Riddle at the Click,
8 did you set up a meeting between Mr. Riddle and the people
9 at Deja Vu?
10 A. Yes. I told Mr. Riddle that I needed to consult with
11 the gentlemen who I consulted for and that it would be best
12 for him to meet them as it relates to that request.
13 Q. And was that because you believed that it was important
14 to get Mrs. Conyers' vote if you were going to win before
15 the City Council?
16 A. Yes.
17 Q. And who -- where was that meeting to take place between
18 Deja Vu and Mr. Riddle?
19 A. It took place in Andiamo's in Dearborn I believe on
20 Michigan Avenue.
21 Q. And who was present for that meeting?
22 A. Mr. St. John, Joe Hall and Gary Koloszar.
23 Q. And how soon after the Click meeting did the meeting at
24 Andiamo's take place?
25 A. Not very long after.
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1 Q. Just a few days?
2 A. Yes.
3 Q. Now, did you go to the meeting in Dearborn with
4 Mr. Riddle or separately?
5 A. I believe we were separate.
6 Q. And what happened at the meeting?
7 A. I believe Mr. Riddle may have come in a little late.
8 He came into the meeting. He --
9 Q. How was he dressed at the meeting?
10 A. From what I recall, he had maybe University of Michigan
11 paraphernalia on. I believe he had -- he said he was on his
12 way to the Michigan-Ohio State football game in Columbus, if
13 I'm not mistaken.
14 Mr. Riddle came, he talked about, again, the value
15 of hiring Meridian Management. Meridian Management, again,
16 sort of the accolades of his company and their
17 accomplishments and what he had done in Colorado and in this
18 case what he can do in order to secure Councilwoman Conyers'
19 support or her vote.
20 Q. What did Mr. Riddle say as to whether or not he could
21 secure Mrs. Conyers' vote?
22 A. He told us that by hiring him that her vote could be
23 secured.
24 Q. And how much did he ask for getting her vote?
25 A. $25,000.
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1 Q. Did Mr. Riddle talk at all as to whether the vote was
2 going to be close or not close?
3 A. He made it clear that she was a swing vote, that the
4 way the council had lined up that, you know, without her
5 vote they would probably not prevail.
6 Q. Now, at the meeting at Andiamo's with Deja Vu did
7 Mr. Riddle say anything about what Mrs. Conyers would do if
8 Deja Vu did not hire Mr. Riddle?
9 A. Well, that we would not get her support and that in
10 fact she could work against us.
11 Q. Did you, based on what Mr. Riddle said, did you take
12 that as a threat?
13 A. Yes.
14 Q. During the meeting at Andiamo's did Mr. Riddle ask
15 about the merits of the transfer of the license from
16 Deja Vu?
17 A. Could you just clarify what you mean by the merits?
18 Q. Did Mr. Riddle ask any questions about what the project
19 would mean or if the club opened in Detroit what would
20 happen or what the benefits of having the transfer of the
21 license would be?
22 A. There may have been just some general discussion about
23 the case, but we didn't get into a lot of detail.
24 THE COURT: Bring the mike a little closer. You
25 are letting your voice drop slightly, please. Thank you.
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1 BY MR. GARDEY:
2 Q. After Mr. Riddle quoted the price of $25,000 for
3 Ms. Conyers' vote, what was the reaction or what happened at
4 the meeting?
5 A. The gentlemen, they were -- I guess the best word, they
6 were surprised, taken off guard. They, I guess they felt
7 that that was, one, excessive, just buying -- they looked at
8 it as if it was buying a vote.
9 MR. WISHNOW: Objection, Your Honor.
10 THE COURT: No, you can't say what they looked at.
11 The question -- what was your question?
12 BY MR. GARDEY:
13 Q. What was the reaction of the people at Deja Vu to
14 Mr. Riddle's request?
15 A. They were surprised.
16 Q. During the meeting did they agree to hire him or not
17 hire him?
18 A. No, they did not want to hire him.
19 Q. What happened? How did the meeting end?
20 A. Pretty abruptly. They were not supportive of hiring
21 Sam. They didn't want to really continue on with any more
22 dialogue. Sam had his football game to get to and pretty
23 much left out, well, you know, it's, basically, you know,
24 this is it, you know, this is the deal and you take it or
25 leave it.
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1 Q. Did Mr. Riddle leave at that point?
2 A. Yes.
3 Q. Did you have further discussions with Deja Vu at the
4 Andiamo's Restaurant after Mr. Riddle left?
5 A. Yes.
6 Q. Did you make any proposal to the Deja Vu people
7 regarding Mr. Riddle?
8 A. Well, I saw their discomfort in contracting Sam and so
9 I proposed that Jackson Consulting could hire
10 Meridian Management as a subcontractor, and that would sort
11 of keep their hands clean, if you will, and they would not
12 have any direct involvement with him but that I at that
13 point felt that without hiring Meridian we would not secure
14 Councilwoman Conyers' vote and their transfer would not
15 happen.
16 Q. What did Deja Vu say to your proposal?
17 A. They did not support it.
18 Q. Based on what Mr. Riddle said to you at the meeting at
19 Andiamo's, did you feel that you were being shaken down by
20 Mr. Riddle?
21 A. Yes.
22 Q. And what do you understand, when I say shake down, what
23 do you mean? What do you understand that to mean?
24 A. I was being pressured to have to in one way or another
25 pay the $25,000 in order to get the vote of Councilwoman
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1 Conyers.
2 Q. Now, after the meeting at Andiamo's with Mr. Riddle and
3 the Deja Vu people, did the license transfer issue come up
4 for a vote in the Detroit City Council?
5 A. Yes.
6 Q. And did that take place on November 15, 2006?
7 A. Yes.
8 Q. And what was the vote?
9 A. The transfer was not approved. It was denied. I
10 believe it was 5 to 4.
11 Q. And how did Mrs. Conyers vote?
12 A. She voted against the transfer.
13 Q. And after the request to transfer the license was
14 defeated, what was your reaction? How did you feel?
15 A. Somewhat dejected, if you will. I had put in a lot of
16 time and effort since September to meet with various council
17 people, meet with the representatives of the Law Department
18 or at least talk to them to lay out the repercussions of not
19 transferring and what in fact was the City's liability.
20 Personally I had invested a lot of time and energy into it,
21 had no retainer from the Deja Vu group or HDV, and so at
22 that point felt that that was a lot of work down the drain.
23 Q. And what impact did the loss of the license or the
24 voting down of the license, what impact did that have on
25 your business for credit card processing?
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1 A. Well, I could have spent a lot of time going after
2 business in other areas. I had put, had sort of put a lot
3 on the value of potentially securing this as a customer.
4 Q. And if the license had gone through and you had gotten
5 a share of the credit card processing at Deja Vu, would that
6 have been significant financially for you?
7 A. Very lucrative, yes.
8 Q. After the vote of 5-4 at the City Council, did you have
9 further contact with Sam Riddle?
10 A. Yes.
11 Q. What happened?
12 A. Mr. Riddle and I, we met. At that point I had taken it
13 upon myself. I knew that the Deja Vu group did not support
14 hiring him directly. I felt that as far as if they would --
15 if they got the transfer and they didn't have to know all of
16 the details on how it came about and if I hired him as a
17 subcontractor that, you know, everybody would be happy. So
18 I met with Sam Riddle and had agreed to contract
19 Meridian Management, for Jackson Consulting to contract
20 Meridian Management.
21 Q. Now, how was it that after the vote you had this
22 additional meeting with Mr. Riddle about Jackson Consulting
23 hiring Mr. Riddle and Meridian Management?
24 A. Well, I talked to Mr. Riddle. He felt that there was
25 still a way that there could be a reconsideration. There is
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1 a certain period of time after a vote that a councilperson
2 could reconsider. They could actually put in a letter to
3 the clerk's office for reconsideration and that if in fact
4 that could be a sign, if you will, of certainly his
5 effectiveness in that he could get her to reconsider.
6 Q. And that's what Mr. Riddle offered to do for you?
7 A. Yes.
8 Q. And what price was he asking?
9 A. It was $25,000.
10 Q. And was this soon after the vote in the City Council?
11 A. Yes.
12 Q. Where the license went down?
13 A. Yes.
14 Q. So you agreed to -- did you agree to pay the 25,000?
15 A. No. I told Sam that I would pay him a retainer and I
16 would pay him a success fee. And so we had decided that I
17 would give him the retainer and that if upon -- because the
18 reconsideration was just one piece of it, bringing it back
19 to the table, then once it came back to the table there
20 would be another City Council vote in order to do the
21 transfer.
22 Q. When you say we decided to do a retainer, who is the
23 "we" we are talking about?
24 A. Well, me and Sam, but that was my proposal.
25 Q. And what was the amount of the retainer that you and
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1 Mr. Riddle agreed to?
2 A. The retainer was $10,000. The success fee would be
3 15,000.
4 Q. And so what was your understanding what you were buying
5 with the $10,000?
6 A. The reconsideration.
7 Q. And how about for the 15,000?
8 A. The successful vote as it relates to the transfer of
9 the license.
10 Q. Did you meet with Mr. Riddle and deliver him those
11 two checks?
12 A. Yes.
13 Q. Where was it that you met him?
14 A. I believe we met at the Click again.
15 THE COURT: Excuse me. You gave him two checks at
16 the same time?
17 THE WITNESS: Yes. One -- I'm not sure if it was
18 post dated, but I told him one was, one actually I put in
19 the memo section was for a retainer, and the other was
20 supposed to be cashed upon the successful vote.
21 THE COURT: Thank you.
22 BY MR. GARDEY:
23 Q. Mr. Jackson, I'm handing you what's been entered into
24 evidence as Government's Exhibit 22B.
25 THE COURT: B?
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1 MR. GARDEY: 22B as in boy and 22D as in Delta.
2 BY MR. GARDEY:
3 Q. Would you please take a look at those two documents and
4 identify what they are. First 22B.
5 A. 22B is a check from Jackson Consulting Group, L.L.C. to
6 Meridian Management Systems dated 11-16, 2006 for $10,000.
7 The memo section says consulting services retainer.
8 Q. That's down in the lower left-hand corner of the check.
9 And is this the retainer amount that you said was meant to
10 pay for Mrs. Conyers' reconsideration vote?
11 A. Yes.
12 MR. GARDEY: Okay. Could you enlarge the back of
13 the check.
14 BY MR. GARDEY:
15 Q. And what's the, on the back of the check, Mr. Jackson,
16 of the $10,000 check, what's the stamp on the right side of
17 the back of the check?
18 A. It says, "Pay to the order of Comerica Bank, Detroit,
19 Michigan 48207," there is an account number, "For Deposit
20 Only, Meridian Management Systems."
21 Q. And would you please look at 22D as in Delta.
22 A. A check from Jackson Consulting Group, L.L.C. to
23 Meridian Management Systems dated 11-16-06 for $15,000. In
24 the memo section it says, "Consulting."
25 Q. So the $10,000 was for Mrs. Conyers to file for
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1 reconsideration, and the $15,000 was a success fee if the
2 license transfer actually was voted successfully in the City
3 Council; is that correct?
4 A. Yes.
5 Q. Did you ask Mr. Riddle anything about the second check
6 for $15,000?
7 A. At that time?
8 Q. Yes. Did you ask him to do anything with it or not do
9 anything?
10 A. Yes. I told him that that should be deposited later,
11 anticipating that once the vote had occurred and the
12 councilwoman had supported the transfer then that check
13 would be deposited as a success fee.
14 Q. Now, before you proposed the idea of two separate
15 checks had Mr. Riddle made any -- what did Mr. Riddle want
16 in connection with the 25,000?
17 A. Well, he wanted the whole $25,000.
18 Q. He wanted all 25,000 up front?
19 A. Yes, yes.
20 Q. And before you paid those two checks over to Mr. Riddle
21 did you get approval from Deja Vu in any way?
22 A. No.
23 Q. What happened after you gave Mr. Riddle those
24 two checks?
25 A. I believe later on that day there was a letter that
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1 went into the city clerk's office from Councilwoman Conyers
2 for the reconsideration of the transfer. So that's my
3 understanding to get it back onto the docket for Council to
4 vote.
5 Q. Mr. Jackson, I'm handing you Government's Exhibit 23.
6 Would you please take a look at that and state what it is.
7 A. "Memorandum to Janice M. Winfrey, City Clerk, from
8 Council President Pro Tem Monica Conyers, date November 17,
9 2006, regarding reconsideration of vote on resolutions A and
10 B on the petition of HDV-Greektown, L.L.C. (Petition Number
11 1392) to transfer ownership with dance entertainment and
12 topless activity permit from K & P, Inc. at 414 E.
13 Congress."
14 Q. Mr. Jackson is this the reconsideration that you spoke
15 about?
16 A. Yes.
17 Q. And based on your experience as a chief of staff for
18 City Council, what was your understanding of how
19 reconsideration would work and who could bring such a
20 request?
21 A. My understanding was that a reconsideration could only
22 take place by someone on the prevailing, the winning side.
23 So if you wanted to reconsider within the period of time
24 that is allowed for reconsideration that you would notify
25 the City Clerk in writing of your intention or your intent
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1 to reconsider in writing.
2 Q. And the, this notice of reconsideration, it's not
3 necessarily a declaration that the person is going to change
4 their vote, just that they are going to reconsider; is that
5 correct?
6 A. Yes.
7 Q. Did Mr. Riddle say anything to you about the
8 reconsideration filed by Mrs. Conyers?
9 A. He told me that, that that certainly would show some
10 good will as relates to the consulting fee, and it also
11 showed that Meridian Management could follow through on what
12 it promised.
13 Q. During your discussions with Mr. Riddle right after the
14 vote when you were giving him the checks, did Mr. Riddle
15 ever suggest that he was ever going to try to get other City
16 Council members besides Mrs. Conyers to change their vote?
17 A. No.
18 Q. Was there any doubt in your mind, Mr. Jackson, you were
19 paying Mr. Riddle for Monica Conyers' vote?
20 A. No.
21 Q. Other than your payment of the two checks, $10,000 and
22 $15,000, was there anything else that occurred in connection
23 to Deja Vu and the issue before the City Council before
24 Mrs. Conyers filed her notice of reconsideration?
25 A. Can you clarify as far as what may have occurred? I'm
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1 sorry.
2 Q. Was there any -- before she filed for reconsideration
3 were there other meetings of the City Council or were there
4 other presentations?
5 A. No.
6 Q. After she filed the notice of reconsideration was there
7 another meeting of the Detroit City Council?
8 A. No.
9 Q. After the reconsideration?
10 A. Yes.
11 Q. And what happened at that meeting?
12 A. At that meeting there were a number of people from the
13 community, a number of very prominent ministers, members of
14 their congregation.
15 Q. Were you present for that meeting?
16 A. Yes.
17 Q. And what was the purpose of that meeting in the City
18 Council?
19 A. The purpose of that meeting was to take up the
20 reconsideration and to have a new vote.
21 Q. And did that meeting take place the day after
22 Mrs. Conyers filed for reconsideration?
23 A. I'm not sure if it was the day after or two days after.
24 I'm not sure of the exact date.
25 Q. Soon thereafter?
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1 A. Yes, sir.
2 Q. Now, you said that pastors and other people appeared
3 before the City Council. What happened?
4 A. They were allowed to testify and speak at the Council,
5 to give testimony as relates to their disapproval of any
6 reconsideration. They were happy that the transfer had been
7 denied previously, and they wanted that vote to stand. They
8 had moral objections to a cabaret D license, and they
9 pressed those objections at that meeting.
10 Q. Is it fair to say there was political opposition to
11 providing a license to Deja Vu?
12 A. Yes.
13 Q. And during the meeting how did Mrs. Conyers react?
14 A. Mrs. Conyers appeared to be very intimidated. She was
15 not willing to or did not interact very much with the
16 ministers. She didn't say very much at that meeting. She
17 didn't -- of course, a lot of the testimony was directed at
18 her because she was the councilperson who had actually asked
19 for the reconsideration.
20 Q. And at the -- what happened with Mrs. Conyers at the
21 end of that meeting? What happened?
22 A. At the end of the meeting either it was Mrs. Conyers or
23 another councilperson, I believe it was her, asked that the
24 matter be tabled.
25 Q. And what does that mean?
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1 A. Tabled. They were -- I believe it was the last meeting
2 before council was to recess for the year, and tabled means
3 that the matter is no longer -- will not be taken up, that
4 the vote will not be taken and it was tabled until next year
5 or until the following year.
6 Q. And so because the matter was tabled in the City
7 Council that meant that there would be no actual revote on
8 the issue of the license transfer for Deja Vu until January
9 of 2007; is that correct?
10 A. That's correct.
11 Q. And for your purposes what did that mean, what impact
12 did that have on the Deja Vu project and the effort to
13 transfer the license by a method other than litigation?
14 A. That meant that it was dead, that they had no option
15 but to pursue or move forward with the litigation.
16 Q. How did you react about what happened at this
17 second City Council meeting?
18 A. Well, I had hired a consultant to assist in securing
19 the vote of the councilperson who had reconsidered,
20 Monica Conyers. He was not there at the meeting. Found out
21 that he later was not even in town. He was in Saginaw or
22 Flint or somewhere. That was the explanation given to me,
23 and so I felt that I did not get the value of the money that
24 I spent.
25 Q. You didn't get your vote?
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1 A. No.
2 Q. After that did you take any action in connection to the
3 success fee, the $15,000 check?
4 A. Yes.
5 Q. What did you do?
6 A. And I should say I got the value of my $10,000, but I
7 didn't get the value or did not warrant the $15,000 success
8 fee because there was no success.
9 Q. What did you do in connection with the $15,000 check?
10 A. I put a stop payment.
11 Q. You put a stop payment on it with your bank?
12 A. Yes.
13 Q. And you didn't, you didn't do that with the $10,000
14 check because -- did you do that -- you didn't do that with
15 the $10,000 check because you felt you got your vote for
16 reconsideration from Mrs. Conyers?
17 A. Yes.
18 MR. GARDEY: Just one moment, Your Honor.
19 The government has one brief matter to bring up at
20 side bar.
21 (At side bar on the record out of the hearing of
22 the jury, as follows:)
23 MR. GARDEY: Judge, moments before Mr. Jackson
24 took the stand Mr. Wishnow gave me this document. It's a
25 letter of agreement for professional services.
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1 MR. WISHNOW: I'm sorry.
2 MR. GARDEY: And this is a document we have never
3 seen before and had not been produced by the defense and we
4 had asked them to produce any documents that they intended
5 to use as exhibits.
6 THE COURT: Do you propose to use this?
7 MR. WISHNOW: Actually we are not sure. I'm going
8 to see how the cross develops. We may not.
9 THE COURT: Oh, no, you can't use this. You had
10 an obligation to deliver this in advance. We talked about
11 that. You can't sandbag him that way.
12 MR. WISHNOW: Well, Judge, this is a criminal
13 trial. It's not a civil trial where the discovery is
14 required, and we are allowed some leeway in providing --
15 THE COURT: You are not allowed that much leeway,
16 Mr. Wishnow. You are not allowed that much, Mr. Wishnow. I
17 think this record will reflect both formally and informally
18 the Court telling you to produce your exhibits. As a matter
19 of fact, the last conference we had shortly before, I don't
20 know that it's reflected, but you knew this.
21 MR. WISHNOW: The objection is noted. We'll move
22 forward.
23 THE COURT: What?
24 MR. WISHNOW: We'll move forward.
25 THE COURT: I haven't read it. I don't know what
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1 its significance is.
2 MR. WISHNOW: You don't have to.
3 THE COURT: All right.
4 (End of discussion at side bar.)
5 MR. GARDEY: No further questions, Your Honor.
6 THE COURT: Cross-examine.
7 MR. WISHNOW: Thank you.
8 THE COURT: Can I see you back here one moment?
9 Never mind. Go ahead. I changed my mind. The
10 judge always has that privilege, except at home.
11 Go ahead.
12 MR. WISHNOW: Thank you.
13 - - -
14 CROSS-EXAMINATION
15 BY MR. WISHNOW:
16 Q. Good morning, Mr. Jackson. My name is Edward Wishnow.
17 I'm one of Sam Riddle's attorneys. How are you?
18 A. Good morning. I'm sorry, what's your name sir?
19 Q. Edward Wishnow.
20 A. Wishnow. Good morning.
21 Q. Sir, after leaving common council, you started many
22 businesses, including Jackson Consulting, correct?
23 A. Yes.
24 Q. And you have indicated that your primary area of
25 interest and expertise was in the finance sector?
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1 A. Yes.
2 Q. In fact, you were involved in putting together the
3 Greektown Casino deal?
4 A. Yes.
5 Q. And your group, I think it's called Monroe Partners?
6 A. Yes.
7 Q. Became a significant -- had a significant ownership
8 interest in that casino, correct?
9 A. Yes.
10 Q. Anything you've done in the financial sector with
11 clients or prospective investors usually involves some type
12 of, well, not usually, always involves some type of written
13 contract, does it not?
14 A. Yes.
15 Q. In this particular situation when you were approached
16 by Deja Vu representatives you did not have a written
17 contract with them, did you?
18 A. I presented one to them.
19 Q. You presented a contract to them?
20 A. Yes.
21 Q. And they refused to sign it?
22 A. It was being negotiated, never was signed.
23 Q. And did that contract ask that you would receive some
24 type of up front fee?
25 A. I can't recall the exact details of the contract.
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1 Q. But it most likely did require some up front fee,
2 correct?
3 A. Yes.
4 Q. Pardon?
5 A. Possibly. There would be a retainer involved.
6 Q. You don't remember the amount of the retainer involved,
7 correct?
8 A. No.
9 Q. But they didn't want to pay that, correct?
10 A. They gave me a counter to my contract.
11 Q. And their counter was instead of some up front money
12 some possible reward for you later on by buying into their
13 business?
14 A. As well as sharing in or having access to ATM machine
15 or some credit card processing business.
16 Q. Well, at some point they told you they weren't
17 interested in giving you a piece of the ATM pie; isn't that
18 correct?
19 A. That's correct.
20 Q. Because that was a very significant revenue stream for
21 them?
22 A. They had already contracted with or already had a
23 relationship with some other entity.
24 Q. And there was some interest possibly in allowing you to
25 get involved in the credit card processing business?
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1 A. Yes.
2 Q. And you already had such a business, did you not?
3 A. Yes.
4 Q. You indicated that at one point you did meet with
5 Sam Riddle and your first meeting directly with him was at
6 the Click Restaurant on East Jefferson?
7 A. That would have been the second meeting.
8 Q. After the meeting in chambers, I'm sorry.
9 A. Yes.
10 Q. And that, you understood, was held outside the office
11 because he was there in his role as a consultant with
12 Meridian Management?
13 A. The second meeting was held outside the office.
14 Q. Yes.
15 A. Yes.
16 Q. And he was there, as you understood it and as he
17 explain to you, as a consultant with Meridian Management?
18 A. At the second meeting, yes.
19 Q. Correct, at the second meeting at Click?
20 A. Yes.
21 Q. At some point was a contract submitted to you?
22 A. I recall that there was a contract, something from
23 Meridian Management. I don't actually have it, but I
24 believe there was something emailed to me or either given to
25 me.
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1 Q. And that, unlike the contract you attempted to have
2 with HDV/Deja Vu, that contract was not signed, was it?
3 A. No.
4 Q. That contract that was sent to you from Sam Riddle had
5 a no conflicts provision in it?
6 A. I don't recall. L I don't recall. I don't remember
7 the contract.
8 Q. You didn't give it much thought or you just don't
9 recall now?
10 A. I just don't recall.
11 Q. You did not know Sam Riddle very well before your
12 meeting with him, correct?
13 A. No, I did not.
14 Q. But you certainly knew of him and that he is a,
15 certainly was a well-known media consultant, a PR person?
16 A. I knew of him. I didn't know exactly what his vocation
17 was. I knew of him through the media and through other
18 people in general.
19 Q. And did you know that he was involved in
20 Monica Conyers' campaign?
21 A. Yes.
22 Q. That he was involved in the campaigns of others?
23 A. I was more familiar with his campaign with
24 Monica Conyers.
25 Q. And at your meeting with him he gave you information
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1 about himself and Meridian, did he not?
2 A. Yes.
3 Q. Somewhat touting all the good things that he had done
4 during his career as a consultant?
5 A. Yes.
6 Q. And some of those were incidents that you were well
7 aware of, such as Columbine, correct?
8 A. Yes.
9 Q. And you knew those, you believe those to be true, that
10 he was involved with those instances?
11 A. Oh, I had no idea if he actually, he himself was
12 involved. He shared with me that he was. I had, I had no
13 idea who was representing the family members and that kind
14 of thing.
15 Q. And as we sit here today you have no reason to
16 disbelieve that, do you?
17 A. No.
18 Q. Before you met with Mr. -- Meridian and Mr. St. John
19 and Mr. Hall at the Andiamo in Dearborn did you have a
20 second meeting with him at your office?
21 A. With who?
22 Q. Just Sam Riddle and yourself at your office.
23 A. I could have. I'm not sure.
24 Q. You could have?
25 A. Yeah.
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1 Q. And would the terms of his engagement with you have
2 been discussed at that time?
3 A. Possibly.
4 Q. And would he -- do you -- well, when you met with him
5 at the Click Restaurant did he discuss with you that he was
6 there acting as a consultant pursuant to
7 Meridian Management?
8 A. Yes.
9 Q. Did you, yourself, tell Mr. Riddle to come to the
10 meeting at the Andiamo's Restaurant?
11 A. I can't recall exactly how the invitation took place.
12 Q. Did you tell him who would be there?
13 A. Oh, I told him the representatives of Deja Vu would be
14 there, yes.
15 Q. Okay. Did you tell either Mr. St. John or Mr. Hall
16 that Sam Riddle would be coming to the meeting at the
17 Andiamo's Restaurant?
18 A. Yes.
19 Q. So they expected that he would be there?
20 A. Yes.
21 Q. And did you explain to them that he was a consultant
22 and had a company called Meridian Management?
23 A. Yes.
24 Q. At some point you became rather upset because you had
25 expended some monies and had not gotten anything out of
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1 Deja Vu, correct?
2 Well, let me put that in context, excuse me.
3 Before you gave your $10,000 check to Sam Riddle,
4 by that time you had expended significant time and energy
5 into trying to help out Deja Vu Consulting, correct?
6 A. Yes.
7 Q. And up until then you had not received any
8 reimbursement, I mean you hadn't received any compensation
9 for your services, correct?
10 A. Yes.
11 Q. And that concerned you, did it not?
12 A. Yes.
13 Q. I mean you are a businessman, your time is valuable,
14 correct?
15 A. Yes.
16 Q. You, on your own, decided that you would pay $10,000 to
17 Mr. Riddle, correct?
18 A. Yes.
19 Q. And that check was made out to Meridian Management, and
20 on the memo line it stated "consulting," correct?
21 A. Retainer. Consulting retainer, correct.
22 Q. And a second check the same day for $15,000 also made
23 out to Meridian?
24 A. Yes.
25 Q. During your meetings with Mr. Riddle he explained to
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1 you, did he not, why a consultant would be important in
2 dealing with a strip club that was trying to locate in
3 downtown Detroit?
4 A. Yes.
5 Q. And you accepted those reasons and they were valid,
6 were they not?
7 A. I accepted the reasons that a consultant was needed.
8 Q. And I think you have touched upon some of those; that's
9 not a popular business, there are a lot of what you
10 characterized as gray areas, and government intervention
11 could be of help?
12 A. You say government intervention could be of help?
13 Q. Yes.
14 A. That is not something that I was -- I was getting the
15 services of a nongovernmental entity, Meridian Management.
16 Q. No, but your -- excuse me. Let me be more precise.
17 A consultant of yours could intervene with
18 governmental bureaus and departments in this type of
19 context, correct?
20 A. That's what was being sold to me in what the services
21 of Meridian Management could do, yes.
22 Q. But you understood the context within which this
23 consulting services was being offered, that is, the context
24 of a strip club being located downtown?
25 A. I was hiring Meridian Management to assist in getting
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1 Monica Conyers' vote for the transfer.
2 Q. Sam Riddle though discussed with you, did he not, that
3 his consulting services could help with other areas involved
4 with a strip club in downtown Detroit?
5 A. After a vote would be taken if they were to get a
6 transfer that Meridian Management services would also be
7 needed for other governmental type things because, because
8 of the gray areas, because of the potential for getting
9 tickets and other types of --
10 Q. Issues such as liquor licenses, police involvement,
11 zoning issues, correct?
12 A. Yes.
13 Q. And you are familiar in your term of government with
14 the City Council that those type of issues come up with any
15 type of bar establishment, let alone a cabaret or topless
16 entertainment facility, correct?
17 A. Yes.
18 Q. And you, because of your role in the financial sector,
19 you had little interest in getting involved in that type of
20 what apparently you believe are somewhat tawdry sectors of
21 business?
22 A. Well, as a correction, I never pass any disparaging --
23 I don't look at that business as tawdry or anything. It was
24 just not an area that I focused on. I focused on financing.
25 Q. Okay. But Mr. Riddle explained to you that this was an
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1 area that he could work in and would feel comfortable in
2 working, correct?
3 A. Yes.
4 Q. And before you went to Andiamo's, before the meeting at
5 Andiamo's did you explain to Mr. St. John and Mr. Hall that
6 Mr. Riddle could be a valuable consultant in these so-called
7 gray areas with government as far as a strip club in
8 downtown Detroit?
9 A. I don't recall having that conversation with them.
10 Q. You may have had that discussion with them, correct?
11 A. My conversation focused more on the transfer of the
12 license, securing the support and the vote to transfer the
13 license.
14 Q. So that's what you told St. John and Hall, correct?
15 A. That was the focus, yes.
16 Q. Okay. Knowing that, they came to this meeting in
17 Dearborn, correct?
18 A. Yes.
19 Q. And then when it came to money, that is, for them to
20 pay Mr. Riddle, they balked at that, they wouldn't do that?
21 A. That's correct.
22 Q. In the same manner that they didn't want to pay you any
23 money, correct?
24 A. No, they did not balk at it in the same manner, no.
25 Q. But they didn't want to pay you any money up front
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1 either, did they?
2 THE COURT: I think those are argumentative
3 questions.
4 MR. WISHNOW: Thank you, Your Honor. I'll move
5 on.
6 THE COURT: They have to be reformulated.
7 MR. WISHNOW: Thank you.
8 BY MR. WISHNOW:
9 Q. They did not want to pay you up front money either, did
10 they?
11 A. I don't recall them saying actually they did not. We
12 did not reach an agreement on any of this.
13 Q. Well, you had asked for up-front money as part of your
14 initial contract proposal to them for you, for
15 Jackson Consulting?
16 A. I believe there was a retainer made, yes.
17 Q. Ultimately you said that when the vote came up for
18 reconsideration there was community opposition, correct?
19 After November 17?
20 A. After the reconsideration?
21 Q. Yeah. The vote came up for --
22 A. Yes.
23 Q. When the vote came up again after the letter for
24 reconsideration was submitted that there was community
25 opposition?
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1 A. Yes.
2 Q. And Monica Conyers, you believe, tabled that vote?
3 A. I'm not sure if it was her or one of her colleagues.
4 Q. But you were at that meeting?
5 A. The vote was tabled.
6 Q. You were at that meeting?
7 A. Yes. I was in and out of the room, but yes, I was
8 there.
9 Q. Okay. And you did not see Monica Conyers vocally favor
10 a vote in favor of Deja Vu, did you?
11 A. No. They didn't vote.
12 Q. And she took no strong position in favor of Deja Vu,
13 did she?
14 A. No.
15 Q. And that action on her part would have been detrimental
16 to her financial situation if she was going to get part of
17 the $15,000; isn't that correct?
18 THE COURT: That question is argumentative.
19 THE WITNESS: I don't know.
20 MR. WISHNOW: I can ask the opinion of this
21 witness, Your Honor.
22 THE COURT: I said the question is argumentative.
23 MR. WISHNOW: Thank you, Your Honor.
24 If I could have one moment.
25 THE COURT: You may.
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1 BY MR. WISHNOW:
2 Q. Sir, when you worked with Gil Hill, who was a
3 councilman and a council president, were you a full-time
4 employee?
5 A. Yes.
6 Q. And did that cover -- did you have fringe benefits on
7 that job?
8 MR. GARDEY: Objection, Your Honor, relevance.
9 THE COURT: What is the arguable relevance of what
10 his remuneration was in the 1990's when he was working?
11 MR. WISHNOW: Because he gave an opinion earlier
12 as to what he thought was a conflict of interest of someone
13 working for the City government. We have evidence in --
14 THE COURT: No, no, no, no. I'm sustaining the
15 objection.
16 MR. WISHNOW: Your Honor, we have evidence that --
17 THE COURT: I said I have sustained the objection,
18 but he can answer.
19 MR. WISHNOW: Thank you.
20 THE COURT: Did you get fringe benefits when you
21 worked for Hill?
22 THE WITNESS: I had different arrangements over
23 the course of the seven years, so it depends on what period
24 of time.
25 THE COURT: Okay.
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1 BY MR. WISHNOW:
2 Q. Did you work for close to 2,000 hours a week like a
3 normal work year?
4 A. You said 2,000 hours --
5 Q. Hours.
6 A. -- a week?
7 Q. No. Did you have an arrangement where you worked a
8 normal work year, about 2,000 hours if you had two weeks off
9 or thereabouts?
10 A. Yes.
11 MR. WISHNOW: Okay. Thank you.
12 MR. GARDEY: No further questions, Your Honor.
13 THE COURT: The witness is excused.
14 Do you want to start with another witness or wait
15 until Friday morning?
16 MR. GARDEY: We have Agent Lubisco just to have
17 short testimony about Deja Vu.
18 THE COURT: Would you wait in back a few minutes.
19 THE WITNESS: Yes.
20 THE COURT: Thank you.
21 Go ahead.
22 MR. GARDEY: The United States calls Special Agent
23 Mike Lubisco.
24 - - -
25
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1 DIRECT EXAMINATION
2 BY MR. GARDEY:
3 Q. Agent Lubisco, in the course of the investigation did
4 you gather bank records concerning the Deja Vu scheme?
5 A. Yes, I did.
6 Q. Did those bank records include the records for Meridian
7 Management, an account at Comerica controlled by Sam Riddle?
8 A. Yes, they did.
9 Q. Agent Lubisco, I'm handing you what's been marked and
10 entered into evidence as Government's Exhibit 22C and 22E.
11 Would you please identify those. First 22C.
12 A. 22C is a deposit into the Meridian Management account
13 on 11-16-06, and it is for $10,000.
14 Q. What's the date on 22C of the deposit?
15 A. 2C is -- it's 11-17-06.
16 Q. And what was 22E?
17 A. 22E is also a deposit into the Meridian Management
18 account. It's on November 27th, 2006, and it is for the
19 amount of $15,000.
20 Q. And is the name of Sam L. Riddle also on the deposit
21 slip?
22 A. Yes, it is. Samuel L. Riddle, Jr.,
23 Meridian Management.
24 Q. Agent Lubisco, I am handing you what's been marked
25 Government's Exhibit 22A. Would you please state for the
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1 record what that is.
2 A. It's a copy of a statement from Comerica Bank for
3 Meridian Management Systems. It's for November 1st, 2006 to
4 November 30, 2006.
5 Q. Would you turn to the second page of Exhibit 22A,
6 please, and under the deposits.
7 A. The bank account shows two deposits, one on
8 November 17th for $10,000, one on November 27th for $15,000.
9 Q. And were there also earlier deposits for $10,000 on
10 November 8 and 400 on November 1st?
11 A. Yes, there is.
12 Q. Was there anything else reflected on this statement
13 concerning the November 27 $15,000 deposit?
14 A. That on Page 3 is a returned item chargeback, meaning
15 $15,000 was taken out of the account.
16 Q. Any understanding as to why 15,000 would be charged
17 back on this account?
18 A. Because there was a stop payment placed on the check.
19 Q. Are there any cash withdrawals reflected on
20 Mr. Riddle's bank statement for November of 2006?
21 A. There are three withdrawals: The first one on
22 November 9th for $4,000; the second on November 20th for
23 2500; and then on November 27 also for 2500.
24 MR. GARDEY: Just one moment, Your Honor.
25 No further questions, Your Honor.
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1 THE COURT: Cross.
2 MR. WISHNOW: Oh, I'm sorry. No questions,
3 Your Honor.
4 THE COURT: Thank you. The witness is excused.
5 MR. GARDEY: Your Honor, our next witness was
6 going to be Agent Lubisco concerning a different scheme,
7 and --
8 THE COURT: I think we should start Friday
9 morning.
10 MR. GARDEY: Thank you.
11 THE COURT: Between now and then keep your eyes
12 open, your ears closed, your mouths shut. Don't talk to
13 anyone about it, don't let anyone talk to you about it.
14 I'll see you Friday morning at 9:00. Also, don't Google.
15 Everyone will sit down, please, back there.
16 Just leave your stuff on your chair. You don't
17 have to haul it in and out.
18 (Jury out at 12:40 p.m.)
19 THE COURT: You can sit down. We'll just wait
20 until the jury clears the floor.
21 We'll meet tomorrow morning at 10:00, and it would
22 be helpful if you had a draft in the jury instructions, I
23 don't care where you are in your negotiations, but a draft
24 and the verdict form.
25 Ms. Altman has a memo, a copy, on 5401 if you want
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