allgood, david | testimony transcript
TRANSCRIPT
Transcript of the Testimony of David Allgood
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:
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 1
IN RE: JOPLIN CRITICAL INVESTIGATION
SWORN STATEMENT OF
DAVID ALLGOOD
Taken on Thursday, November 14, 2013, from 2:33 p.m. to 2:58
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.
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 2
APPEARANCES
MR. THOMAS E. LORAINE
Loraine & Associates, LLC
4075 Osage Beach Pkwy., Suite 300
Osage Beach, MO 65065
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 3
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.
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 4
I N D E X
Page/Line
DIRECT EXAMINATION BY MR. LORAINE . . . 5-4
E X H I B I T S
Exhibit #A. . . . . . . . 5-6
Advice of Rights
Exhibit #20 . . . . . . . 13-5
1/27/13 letter
Exhibit #21, #22, #24 . . . . . 13-5
Employee Performance Measurement
Exhibit #23 . . . . . . . 17-23
11/8/13 memo
Note: Exhibits in separate binder
(sic) - typed as spoken
(ph.) - phonetic
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 5
1 DAVID ALLGOOD
2 Having been first duly sworn and examined,
3 testified as follows:
4 DIRECT EXAMINATION BY MR. LORAINE:
5 Q. Mr. Allgood, we've had a chance to meet in
6 the hall here. This is Exhibit #A. Have you
7 had a chance to read this form yet?
8 A. Not yet.
9 Q. All right. Let me let you read that and then
10 I'll read it to you because it says I need to
11 do that.
12 A. Okay.
13 Q. Have you had an opportunity to read what's
14 been marked as Exhibit #A?
15 A. Yes.
16 Q. And I will now read it and you can peruse it
17 again, if you want. "I wish to advise you
18 that you are being questioned as part of an
19 official investigation by the City of Joplin.
20 You will be asked questions related and
21 specifically directed to the performance of
22 your official duties of fitness for office.
23 You are entitled to all of the rights and
24 privileges guaranteed by the laws of the
25 Constitution of the State and the
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 6
1 Constitution of the United States, including
2 the right not to be compelled to incriminate
3 yourself. I further wish to advise you that
4 if you refuse to testify or answer questions
5 relating to the performance of your official
6 duties, you will be subject to departmental
7 charges, which could result in your dismissal
8 from your official duties. If you do answer
9 these statements may be used against you in
10 relation to subsequent department charges,
11 but not in any subsequent criminal
12 proceedings. I have read and fully under the
13 Advice of Rights as it appears above, and
14 this information has also been read to me
15 prior to answering any questions." Sir, do
16 you understand what we've talked about?
17 A. Yes.
18 Q. All right. Would you sign that and date it?
19 A. Okay. Right here (indicating), sir?
20 Q. Yes, print your name above that, if you can
21 there.
22 A. (Witness complies)
23 Q. Thank you, sir. Mr. Allgood, I'm witnessing
24 your signature and your date of 11/14 of this
25 Exhibit #A, is that correct, sir?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 7
1 A. Yes, sir.
2 Q. And how long have you been employed by the
3 City?
4 A. Approximately six months.
5 Q. Six months? That's all?
6 A. Yes, sir.
7 Q. Okay. Good to have you. Have you ever been
8 involved in a Garrity before?
9 A. No.
10 Q. Never heard of it, okay. What division do
11 you work under?
12 A. I work under the Human Resources, Risk
13 Management Department.
14 Q. That is your department?
15 A. Yes, sir, it is. I report directly to the
16 City Manager.
17 Q. So Mr. Rohr is your supervisor?
18 A. Yes.
19 Q. Now, Mr. Allgood, you're under oath here
20 today and do you understand that?
21 A. Yes, sir.
22 Q. You understand that this is an investigation
23 that's been authorized by the City?
24 A. Yes, sir.
25 Q. Did you know about this investigation prior
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 8
1 to today?
2 A. Yes, sir.
3 Q. How did you learn about it?
4 A. Only through the Council and the meetings in
5 the Council.
6 Q. So you knew somebody was going to be hired to
7 do some kind of investigation?
8 A. Yes, sir, I did.
9 Q. And you knew that a couple of weeks ago?
10 A. Yes, probably. I don't remember exactly when
11 it was, I didn't know it was, or when that
12 person was going to be hired.
13 Q. And do you know what I'm doing here today?
14 Do you have an idea what I'm doing?
15 A. Other than I'm assuming you're the person
16 they hired to do the investigation, sir.
17 Q. I am, in fact, sir.
18 A. I'd never heard your name before until I was
19 told to come over here.
20 Q. Today?
21 A. Yesterday whenever he gave me the time and
22 date to come over.
23 Q. He being?
24 A. Brian.
25 Q. Brian Head?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 9
1 A. Brian Head, yes, sir.
2 Q. He's the City Attorney?
3 A. Yes, sir.
4 Q. Now have you discussed this meeting with me
5 today with anybody?
6 A. My City Manager Assistant, City Manager Sam
7 Anslem, he's the one I go through in most of
8 my dealings with the City Manager.
9 Q. Sam?
10 A. Sam Anslem. I'm not sure, A-N-S-L-E-M, I
11 believe. The Assistant City Manager.
12 Q. You talked to Sam about me and this
13 investigation?
14 A. We didn't talk about you other than the fact
15 that I was coming over here to talk to you.
16 Q. Okay. What did he ask you?
17 A. He only said okay. We didn't really get into
18 any discussion, I just told him I was coming
19 over. Brian had told me the day he talked to
20 me that you would probably want to talk to me
21 to confirm everything some time this week,
22 and I told Sam that I would be out this
23 afternoon coming over to talk to you.
24 Q. And he said okay?
25 A. Yes, sir.
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 10
1 Q. Any other discussions with Sam?
2 A. No, sir.
3 Q. How about yesterday, any discussions with Sam
4 yesterday?
5 A. No, I talked to Sam on Monday.
6 Q. Okay. What about?
7 A. Just the information that Brian had
8 requested.
9 Q. Why did you do so?
10 A. Because being new to the City I wanted to
11 make sure I followed proper procedure. I
12 talked to Sam - I think Brian asked me for
13 the information on Thursday, I'm not sure
14 what that date was, around 4:30 p.m., wanted
15 a copy of Mr. Cotten's trial. I asked him
16 why. He said, well, the investigator was
17 wanting the information for his investigation
18 into Council members, which I couldn't tell
19 you who that - I mean I know who they are,
20 but I don't know what the information is.
21 And I said, well, I would like to have a
22 written request. He said on the way out I'll
23 get it to you tomorrow, I don't have it with
24 me now, and I said, well, I don't normally
25 like to give out information since I'm
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 11
1 responsible for all of the files and he said,
2 well, I'll give it to you tomorrow. So in
3 good faith I gave it to him. And even though
4 he's not on the approved list of people that
5 can look at files I didn't want to do
6 anything that would impede the investigation,
7 I guess.
8 Q. Who created that list?
9 A. The list of rules and regulations of the City
10 of Joplin, I don't know when it was created,
11 sir.
12 Q. There's certain people that can see your
13 files according to that list?
14 A. It is.
15 Q. Who are they?
16 A. There's six of them, I believe. The City
17 Manager, the H.R. Director, Assistant H.R.
18 Director, department supervisor, and the
19 department head, I believe, sir.
20 Q. Department head?
21 A. For the employees.
22 Q. You don't know who created that list?
23 A. No, sir.
24 Q. Has general counsel told you that he should
25 be on that list?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 12
1 A. He didn't tell me he should, no. He sent me
2 a letter back saying that as City Council he
3 has the right to see any of it, which, okay,
4 I'm not going to argue with him.
5 Q. And he wouldn't be telling you that unless he
6 --
7 A. I wouldn't think so.
8 Q. So you probably ought to add him to your
9 list?
10 A. I probably should, but I have to go through a
11 process. I can't just add that to my list.
12 I'm not in charge of that.
13 Q. Who is in charge of that?
14 A. I would assume the City Council would be the
15 one that actually would be in charge of the
16 rules and regulations.
17 Q. All right. Let's talk a little bit about
18 what goes on in here or what we talk about is
19 supposed to be confidential. Do you
20 understand that?
21 A. Yes, sir.
22 Q. Who told you that?
23 A. He did.
24 Q. Did anybody else ever tell you that?
25 A. No, sir, I've not talked to anybody else
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 13
1 about that.
2 Q. I'm going to show you what's been marked -
3 I'd like that marked separately, please. I'm
4 going to show you what's been marked as
5 Exhibit #21, #22, and there's two other pages
6 that I guess are part of #21. Let's hand you
7 #21 and ask you, have you seen those three
8 pages before?
9 A. I have seen these on the day that Brian asked
10 for them.
11 Q. And there's three pages.
12 A. I've seen two pages here. Hold on, there it
13 is, there's three pages.
14 Q. All right. So Exhibit #21 is three pages.
15 Is that the full document?
16 A. No, sir, I think there's more. Here's 5A so
17 there's got to be something in front of it.
18 Maybe 1, 1A. The complete would be all of
19 what you've got here in front of me.
20 Q. All of these documents?
21 A. Yes, sir, this would be the Employee
22 Performance document as I understand it.
23 Q. Page 1, 2, and 3 you have?
24 A. Yes, sir.
25 Q. I have two page 1's in my hand.
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 14
1 A. That's possible, sir. I mean I didn't
2 develop this form, I'm just learning it
3 myself.
4 Q. I'm going to hand you now what's been marked
5 as #22, page 1 of #22. Have you seen that
6 before today?
7 A. Other than the day I gave it to Brian and I
8 just did a quick scan on it and saw what it
9 was, sir.
10 Q. All right. I'm handing you what's been
11 marked as #24.
12 A. And that would be the final page of the
13 evaluation. I saw it also on the day that
14 Brian came in and I scanned it as well, sir.
15 Q. These are the five pages that you handed Mr.
16 Head?
17 A. Yes, sir, it is. That would be the
18 Performance Management document review.
19 Q. Now as far as you understand it what person
20 is this file part of?
21 A. This is Mr. Christopher Cotten, sir.
22 Q. Mr. Head asked you to provide Mr. Cotten's
23 personnel file?
24 A. Yes, sir.
25 Q. What else is contained in that personnel
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 15
1 file?
2 A. Application, any reference checks, things of
3 that nature, if there's been reprimands or
4 counseling sessions, I think more than
5 anything like that would be in there, too.
6 Q. Did you see any other counseling sessions or
7 any other forms other than these pages?
8 A. There were these documents, sir, and I laid
9 it out and showed it to Brian. He asked for
10 this document and then he also asked for the
11 counseling session from Mr. Rohr to Chris,
12 which I don't know the date on it, but I know
13 both of these preceded my date of employment
14 so I wasn't part of it so there's one other
15 document I don't see here.
16 Q. I'm going to hand you what's now been marked
17 Exhibit #20 and ask you if that's the
18 additional page?
19 A. Yes, sir, this appears to be the document.
20 Q. Suffice it to say that we've got them
21 numbered strange, it seems to me, but in any
22 case you've got 1, 2, 3, 4, 5, 6 pieces of
23 paper and that was the entire file that you
24 provided to Mr. Head?
25 A. That was the document that Mr. Head
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 16
1 requested. There was more information in the
2 file, but he didn't request any of it, sir.
3 Q. Thank you. I would like to direct your
4 attention specifically to Exhibit #20. This
5 is signed by Chris Cotten and Mark Rohr. Do
6 you see those signatures?
7 A. I see those signatures, sir.
8 Q. Do you recognize either signature?
9 A. I recognize Mr. Rohr's because I deal with
10 him. Chris Cotten, I would have to compare
11 that against something in the file and I
12 haven't done that, sir.
13 Q. But in any case this came from the Chris
14 Cotten file?
15 A. Yes, sir, it did.
16 Q. Do you believe this to all be legitimately
17 part of your record on Chris Cotten?
18 A. Yes, sir, I do. I have no reason to believe
19 otherwise.
20 Q. All right, sir. I appreciate that. Now
21 you've only been here six months as I
22 understand?
23 A. Yes, sir.
24 Q. You don't have any idea why this file is here
25 as I understand it?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 17
1 A. No, sir, I don't.
2 Q. Okay. You don't know Mr. Cotten probably, do
3 you?
4 A. I know Mr. Cotten, sir, he is a department
5 head so we meet not personally, but we meet
6 as a group of department heads twice a month
7 and I see him then and I'll see him in the
8 hallway.
9 Q. You haven't talked about this matter?
10 A. No, sir.
11 Q. And I assume you will not?
12 A. No, sir, I will not.
13 Q. I assume you will not talk about what we've
14 talked about to the City Manager Assist and
15 the City Manager?
16 A. No, sir, I will not.
17 Q. Because I've instructed you not to?
18 A. You've instructed me not to and I understand
19 now better why.
20 Q. One other item I'd like to show you. There
21 is something that has been marked as - I hope
22 we don't have this numbered yet - yes, Number
23 #23. Do you recognize that document?
24 A. Yes, sir, it's a memorandum that Brian sent
25 to me and my request authorizing him, me to
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 18
1 give this information to him after the fact.
2 Q. Why was this memorandum written, if you know?
3 A. Beg your pardon, sir?
4 Q. Why was this memorandum written, if you know?
5 A. Well, I would assume because I asked for it,
6 sir.
7 Q. You asked for something in writing from Mr.
8 Head?
9 A. Yes, sir, I am the keeper of the files so I
10 wanted to have a paper trail. I thought that
11 was good for me to have so if somebody would
12 ask down the road why did you give this
13 information, the City Attorney asked for it.
14 Q. And there's three documents attached together
15 here. What is the last page there?
16 A. That is an email that I sent to Brian
17 requesting that information, sir.
18 Q. And the response to that was the two blue
19 pages?
20 A. The two pages, that's correct.
21 Q. All right. Did Assistant City Manager talk
22 anymore about what you were doing here as of
23 the date that all this went on or a
24 subsequent date other than what you've
25 related to me?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 19
1 A. I talked to the City Manager, Assistant City
2 Manager on the day of course that Brian was
3 there because I told him I wasn't sure if I
4 thought it was proper protocol, which Brian
5 wasn't on the approved list, and he said no
6 problem, thanks for telling me. Then on
7 Monday when I got this from Brian I confirmed
8 that I had gotten the written documentation
9 and of course I think Brian had also copied
10 him anyway so he had already seen it.
11 Q. That's Mr. --
12 A. Mr. Sam.
13 Q. -- Anslem?
14 A. Yes.
15 Q. And you also copied Mr. Rohr?
16 A. Yes, I have not talked to Mr. Rohr at all
17 about any of this, sir.
18 Q. Fine. If you talk to anyone else, if any of
19 your supervisors want to talk to you I am
20 instructing you now that you must call me.
21 A. Yes, sir, I will.
22 Q. And that is by authority of the City Council.
23 A. Yes, sir, I understand that perfectly.
24 Q. Thank you, sir. Appreciate it very much.
25 Now just a couple of follow-up questions. Do
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 20
1 you normally deal with Mark Rohr or do you
2 normally deal with the Assistant?
3 A. Primarily the Assistant. I deal with Mark
4 occasionally. Probably 80, 90 percent of the
5 time it's with Sam.
6 Q. And what is your relationship with Sam?
7 A. I see him as my supervisor.
8 Q. Instead of Mark?
9 A. Mark is my supervisor, but I guess the
10 authority sort of goes through him. If I
11 have issues or questions about the procedures
12 with City business or City policies - I guess
13 municipalities since I've been on the private
14 side for thirty years the government side
15 operates differently, sir, so I go to Sam a
16 lot of times and say is this appropriate or
17 what would you suggest.
18 Q. If there's a legal matter you wouldn't
19 normally go to the general counsel then?
20 That's not in your normal chain of command as
21 you see it?
22 A. I don't report to him, but if it's to deal
23 with a legal claim that falls under Risk
24 Management I deal with Brian.
25 Q. Direct?
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 21
1 A. Yes.
2 Q. So when there is a matter that is with Brian
3 you deal directly with Brian?
4 A. Like on an automobile claim, a liability
5 claim, a work comp claim or something that
6 has the potential to become legal like on an
7 employee or something I will go get Brian
8 involved.
9 Q. For example, a retaliation charge or
10 something of that nature, would you deal
11 directly with Brian or would you deal with
12 Mark Rohr?
13 A. I would go to legal counsel.
14 Q. And that is your understanding essentially of
15 the role, is that right?
16 A. Yes, sir, to deal with the daily business of
17 the City I would deal with Mr. Rohr, you
18 know. And assuming, once again, sir, I'm not
19 familiar with the City work the way it
20 operates a lot of times, a lot of times on a
21 legal matter if it's not directly with the
22 City Manager I would assume the City Manager
23 would be informed probably by Brian.
24 Q. Let me suggest to you that for your future it
25 would appear to me that you need to find out
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 22
1 what role the general counsel has for you.
2 If any. When I deal with a city and it's a
3 legal matter I deal with the lawyer. That
4 would seem like --
5 A. Yeah.
6 Q. But it does not appear from the sequence of
7 events and documents that we've just talked
8 about that you're aware of that resource so I
9 would think you would want to straighten that
10 out a little bit.
11 A. I appreciate that very much. Because there
12 does appear to be some gray in there for me.
13 Q. It does, and I think you have now a City
14 opinion signed by Head that I think you may
15 rely on, it appears to me, and if there is
16 more need for clarification that perhaps you
17 should --
18 A. Yes, sir.
19 Q. Fair enough.
20 A. I wouldn't want to do anything that impedes
21 the investigation, which is why I went out on
22 the trust of what Brian was telling me and
23 providing him with the information without
24 any documentation, which is what normally
25 would have been my requirement because again
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 23
1 I go back to the policy of the rules and
2 regs. I would think the City Attorney could
3 see what he wants to see when he wants to see
4 it.
5 Q. I think so. And the reason I guess I have
6 talked about these issues and I see that Mr.
7 Head also has consulted with you about this,
8 is that if I wanted to talk with Mr. Anslem I
9 would have done that. And I will now.
10 A. Okay.
11 Q. But my point is did you impede it? I don't
12 know. I don't know. But I would suggest to
13 you that because of areas that are gray in
14 your mind that you might want to get that
15 totally lined out because from my standpoint
16 as an outsider it seems to be a little bit
17 foggy to you and I think it should not be.
18 If there's something wrong with the lawyer's
19 abilities or something that should be
20 reported to the Council, I would think, but
21 in any case otherwise I would think that
22 general counsel would be one of the main
23 resources you would have. And if I would be
24 here on retaliation or hostile work
25 environment I'd be dealing with the lawyer
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 24
1 unless he was part of the hostile work
2 environment.
3 A. Yeah, I just wanted to be sure I followed
4 proper procedure and Sam is usually my person
5 I go to so that's why I did that.
6 Q. I will want to talk to counsel about that
7 because I --
8 A. Maybe I didn't understand what Brian was
9 asking or needed. There wasn't a lot of
10 explanation going on. I didn't know you had
11 been hired, I didn't know you had been
12 approved by Council, I didn't know your name,
13 and I sort of felt like I went out on good
14 faith with Brian to provide him the
15 information.
16 Q. I appreciate that.
17 A. And maybe I - I don't know, I just felt like
18 that was necessary for me to get
19 clarification that I'd acted appropriately.
20 Q. And I still think you need to get that
21 clarified.
22 A. I agree and I will do that.
23 Q. I appreciate that. One other thing I want to
24 talk about a little bit is what observations
25 have you made with Manager Rohr's style of
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 25
1 operations?
2 A. I think he does a fine job.
3 Q. What about the Assistant?
4 A. I think they do a fine job.
5 Q. What about the lawyer?
6 A. I think he does good. And I've very few
7 dealings with the lawyer. When I have it's
8 always been good.
9 Q. The same thing would be true of your
10 observations on Mr. Rohr?
11 A. Yes, sir.
12 Q. The same thing on the Assistant?
13 A. Yes, sir, I've had no issues at all since
14 I've been here.
15 Q. And you're the new guy?
16 A. I'm the new guy.
17 Q. Well, it's a rough way to get in on this.
18 A. Yeah, it definitely is.
19 Q. And you have a couple of issues bouncing
20 around on the Council, I guess you're vaguely
21 aware of those issues?
22 A. Vaguely. I try to avoid it, sir. It's none
23 of my business what went on with him or how
24 it went on or anything to do with the
25 Council. Even the Council and the City
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 26
1 Manager I try to avoid. Not my business.
2 I'm hired to be H.R. and I'm trying to do
3 that.
4 Q. Sometimes you're stuck in the middle.
5 A. That is an understatement.
6 Q. I appreciate you coming in here today, Mr.
7 Allgood, and you have identified these
8 records for me and I needed the records
9 identified and I appreciate you coming in,
10 and once again I'm admonishing you that until
11 this investigation is over I would not
12 discuss this with anybody, and if anybody
13 attempts to discuss it with you I want to
14 know about it.
15 A. Okay.
16 Q. Do you promise me that?
17 A. I promise you, sir, I won't say anything to
18 anybody, and as far as I'm concerned --
19 Q. Right now I'm your boss for awhile just for a
20 very short period of time.
21 A. Okay. This thing is going to continue
22 forward now and you're going to continue your
23 investigation and I'm going to stay out of
24 it.
25 Q. I hope you do. It's my hope that you do.
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 27
1 Okay?
2 A. Okay.
3 Q. Thank you, sir, for coming in here. I
4 appreciate it very much. I am going to give
5 you one of my cards, and the reason I'm
6 giving you my card is if anybody wants to
7 know what we talked about or anything else
8 then I want you to tell them please just tell
9 them that's the guy that you'd like to have
10 them talk to and then we can invite them over
11 here, okay?
12 A. Okay.
13 Q. Thank you very much for coming in.
14
15 (SWORN STATEMENT CONCLUDED)
16
17
18
David Allgood In Re: Joplin Critical Investigation
417-358-4078
Holliday Reporting Service, Inc.
Page 28
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