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ORIGINAL

SUPERIOR COURT -OF N LAW DIVISION - HUDSON COUNTY DOCKET NO. HUD-L-3172-07

CHRISTOPHER CAMPOS, Petitioner,

-vs-

HONORABLE MARY JANE DESMOND,

ACTING HUDSON COUNTY CLERK;

HUDSON COUNT BOARD OF ELECTIONS

AND BOARD OF CANVASSERS; MARIE

BORACE, HUDSON COUNTY

SUPERINTENDENT OF ELECTIONS;

JAMES FARINA, MUNICIPAL CLERK

OF THE CITY OF HOBOKEN and DAWN

ZIMMER, Respondents.

DEPOSITION OF: DAWN ZIMMER

Tuesday, August 14, 2007

ROSENBERG & ASSOCIATES, INC.

Certified Shorthand Reporters & Videographers

425 Eagle Rock Avenue - Suite 201

Roseland, New Jersey 07068

(973) 228 - 9100 www.rosenbergandassociates.com

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Deposition of DAWN ZIMMER, taken in

the above entitled matter before SUZANNE BALDINI,

a Certified Shorthand Reporter (License No. XI01269) and Notary Public of the State of New Jersey, taken at the law offices of McMANIMON &

SCOTLAND, One Riverfront Plaza, Newark, New

J e r s e y, 0 n T u e s day, Aug u s t 1 4, 2 0 0 7, comme n c i n gat

1:43 p.m.

A P PEA RAN C E S:

BROWNSTEIN BOOTH & ASSOCIATES

BY: KRAIG MC GRATH DOWD, ESQ. 512 42nd Street

Union City, New Jersey 07087

Counsel for the Petitioner

McMANIMON & SCOTLAND, LLC

BY: WILLIAM W. NORTHGRAVE, ESQ. One Riverfront Plaza

Fourth Floor

Newark, New Jersey 07102

Counsel for the Respondents

ROSENBERG & ASSOCIATES, INC. (973) 2289100 www.rosenbergandassociates.com

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I N D E X

WITNESS EXAMINATION BY PAGE

DAWN ZIMMER

MR. DOWD 4

E X H I BIT S

NUMBER DESCRIPTION PAGE

P 7 Dawn Zimmer for Council Campaign

20-day Post Election Report 20 P 8 Amended Answer and Counter Petition 66

(Exhibits retained by counsel.)


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59 Madison Street, Apartment 2, Hoboken, New

Jersey 07030, having been duly sworn, testifies as

follows:

EXAMINATION

BY MR. DOWD:

Q. Good afternoon, Dawn. My name is Kraig Dowd. Could you state your name and address

for the record, please.

A. Dawn Zimmer, 59 Madison Street,

Apartment Number 2, Hoboken, New Jersey 07030.

Q. Dawn, my name is Kraig Dowd, and I'm with Brownstein, Booth & Associates, a law firm.

I represent Christopher Campos in the election

contest that brings us all here today.

Have you ever had a deposition taken

of yourself before?

A. No.

Q. Have you ever participated ln a deposition in any way?

A. No.

Q. This deposition is a formal court proceeding, even though we're in a somewhat

informal setting.

Everything you say is going to be


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tak~n down by the court reporter. Anything~that

anyone says here today will be taken down by the

court reporter, unless, for some reason, we go off

the record. Because of that, all responses by you

and all questions by me have to be verbalized, so

a nod of the head or an unh-unh or an urn, things

like that, won't necessarily reflect what you're

trying to convey.

A. All right.

Q. And, so if you will, try to verbalize every response; and I will try to do

the same thing when I'm asking you questions.

A. Okay.

Q. The other tricky thing about a deposition is that the court reporter, as

wonderful as she is, can't take down testimony

when we are both talking at the same time. So, if

for some reason you're responding to a question,

I'm going to do everything I can not to jump in and ask you another one. And I would just ask the same courtesy of you

A. Okay.

Q. when I'm asking you a question, just wait until I'm finished.

A. Okay.


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Q. Even though you may know, many times today, you are going to know exactly what

I'm going to ask you, just wait until I complete the question, so that the record is clear what

you're answering.

A. Okay.

Q. Again, this is a formal court proceeding. We are on opposite sides of the

litigation here today. I'm representing Chris.

I'm not here to trick you. If for some reason I

ask you a question, and you don't understand the

question, just ask me to rephrase it or repeat it. I'm happy to do the best I can to try to help you

understand what I'm asking.

A. Okay.

Q. By the same token, if I ask you a question and you feel the need to estimate or give

something other than a specific response, let me

know if you're estimating or - I don't want you

to guess at any responses, but let us know if

you're estimating, let us know that's what you're

doing, so that you're not improperly held to some

statement when, in fact, you were just estimating. A.

Q. Okay.

There may be times today, and I


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~xpect there"Verywell will be, when your attorney

feels it proper to object to one of the questions that I ask. If that is the case, you'll be asked

to stop responding until he has placed his

objection on the record; and then you'll receive further instruction after that. Okay?

A. Okay.

Q. Dawn, you were a candidate in the

fourth ward council race for Hoboken this past

year. Correct?

A. Yes.

Q. In that capacity, did you have a

specific name for your campaign committee?

A. You know, we probably did. I I m not

even sure. What it was. I think it was the Dawn

Zimmer For Council Campaign Committee. Il m not

sure.

Q. And as part of that campaign, did you have any staff?

A. I did not have any paid, urn - well,

most of my, quote, unquote, staff was volunteer

basis.

Q. Did your campaign have some kind of

structure, like hierarchy of responsibility?

A. I wouldn't say we had an official

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hierarchy 0 responsibility.

Q. Did you have titles for some of your staff, as you and I both referred to it?

A. Right. On a volunteer basis, Doug

Snyder was my campaign manager. That was the only

official title.

Q. As campaign manager, what were Doug Snyder's responsibilities?

A. He was helping to, you know, work

with the people that - to sort of build the team

of people that would help us during the campaign.

He helped with figuring out the message. I mean,

he played a lot of different roles.

Q. You filed election law enforcement commission reports demonstrating the expenditures

and the contributions from the campaign?

A. Yes.

Q. Do you know who prepare those reports?

A. Drew Moss. And he was our

treasurer.

Q. Can you spell that name, please. A. He was a volunteer, and he was our

treasurer. His name is Drew Moss, D-r-e-w

M o-s-s.


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Q. He was the campaign treasurer? A. Yes, and that was done on a

volunteer basis.

Q. Doug Snyder was also a volunteer? A. Yes.

Q. And were both -- was Doug Snyder your campaign manager in both the May election

and

A. No.

Q. - and the June runoff election? A. Well

Q. This is May 2007 and June 2007? A. He came in about two weeks before

the May 8th election. So that, he was only

that's when he started working with me.

Q. He continued A. My former campaign manager quit.

Q. What was the name of your former campaign manager?

A. Sarah Stojkovic. Q. Could you spell that last name? A. S-t 0 - I'm not even sure how you

spell it S-t-o-j-o-v--i-c. Q. Do you know why she quit? A. Personal reasons.


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Q. Db you knuw what they were? A. I think she had some family issues

going on.

Q. Were there any other campaign staff that quit your campaign?

A. No.

Q. Did you bring on any new campaign staff between the May 8th election - let me

rephrase the question.

You had a certain campaign staff at

the time of the May 8th election and a certain

campaign staff at the time of the June 12

election. Were there any new campaign staff that

weren't there at the May election?

A. Probably the most important person

that came back on to help me was Susan Chait. She

helped with graphic design.

Q. How do you spell her last name? A. C-h-a-i-t.

Q. She came on for the June election? A. Well, she was.

Q. She came A. It's kind of confusing. She was

involved. And then, you know, for various

reasons, stopped working, and then came back on.


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los e was kind of ln and out with the May 8th

2 election, and then! fully back for June 11th.

3 Q. Can you name some of the other 4 volunteer campaign staff members of yours?

A. Rachel Goldberg. Urn, Susan Chait. 6 Urn, Andrew Amato. Andrew may have been paid for

7 some of the work that he did. I'm not really

8 sure.

9 MR. NORTHGRAVE: Just so the record

is clear, you are talking about Andrew Amato.

11 THE WITNESS: Yes.

12 Q. What was Rachel Goldberg's, what 13 were her responsibilities as part of your campaign

14 staff?

A. Helping to get us organized.

16 Q. What do you mean? 17 A. Well, just get our headquarters in 18 order, so we could function.

19 Q. Did she participate in "get out the vote" efforts?

21 A. Yes.

22 Q. And how did she participate in those 23 efforts?

24 A. Urn, I mean, everyone was involved in

the, like, you know - like, calling. I mean, I


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don't ktib0wh~ther she 'was involved, personally,

in calling people.

Q. I'm only asking what you are aware of, what you do have knowledge of. I don't want

to you guess. So to the extent that Rachel was

involved in any "get out the vote" efforts, do you

have any specific knowledge?

A. I think that she was more on the

organizational side and helping to coordinate

volunteers.

MR. NORTHGRAVE: Off the record for

a minute.

(Whereupon, a discussion is held off the record.) Q. Had you finished your response?

A. Yes.

Q. I want to get back to Susan Chait

for the minute. You said there was a break

between the times she was working for you. Do you

know what she did during that break?

A. She has a full time job. She's a professional graphic designer, so she did her job.

Q. Do you know if she was doing any

another election work at the time?

A. No.


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~Q . No,~ you don't know?

A. She was not. She was not.

Q. Any other volunteer staff? A. Let's see. As I said, Susan,

Rachel, Drew, Doug. Those are kind of the key

people.

Q. When you say Drew, you're referring to Andrew Amato?

A. No, Drew Moss.

Q. You mentioned Andrew Amato? A. And my husband was involved in the

campaign.

Q. Your husband's name? A. Stan Grossbard.

Q. What was Andrew Amato's, what were his responsibilities in your campaign?

A. He was sitting out on the street

every day, talking me up to people, you know,

talking to people, and -

Q. And he was a volunteer, or did you not that I recall?

A. He was a volunteer. He was a senior

and doing it on a volunteer basis.

Q. How did Andrew Amato come to be a volunteer for your campaign?


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A. I went I was told he was a person

to talk to, and I went and befriended him.

Q. Do you recall who told you that? A. I think it was Michael Lenz.

Q. You thought Andrew Amato could help your campaign?

A. Yes. I mean, he's a former -- yes,

I did.

Q. Why? A. He's the former fourth ward

councilman. He ran for mayor. He's well known in

Hoboken.

Q. And Michael Lenz, was he a volunteer staff member, also?

A. He did help, yes.

Q. What were his responsibilities? A. He didn't have direct

responsibilities.

Q. What did he do? A. Sometimes he would, you know, I

would bounce ideas off of him.

Q. When was the last time you spoke to Michael Lenz?

A. I don't know. A couple weeks ago.

Q. Have you spoken to him about this


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Ii gation?

A. No. I haven't really discussed -- I

mean, I well, I may have discussed it with him,

yeah.

Q. Do you recall what you discussed? A. I haven't discussed it in detail

with him. I don't recall exactly what I've

discussed with him.

Q. Who have you discussed this litigation with aside from your counsel?

A. My husband.

Q. Anyone else? A. Urn, Rachel Goldberg, Doug Snyder.

Q. Just keep going until you can't remember.

A. That's, you know, who I can think of

right now.

Q. Have you spoken to Florence Amato in the last week?

A. Yes, I have seen her.

Q. When did you see her? A. Last Sunday.

Q. Where? A. In the hospital.

Q. Did you speak with her?


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A. Yes.

Q. What did you talk about? A. Her husband.

Q. Did you talk about the election at all with Florence that day?

A. I don't remember that we really

talked. It was a big group setting.

Q. Who was there? A. Her daughter, her grandson, Angel

Rivera, another senior that I don't know, Andrew

Amato.

Q. You say last Sunday. You're talking about a week ago from this past Sunday?

A. Yes.

Q. So, roughly, the 5th of August? A. Yeah, I guess so. Yeah.

Q. Did you speak with anyone that day when you were in the hospital and you saw Florence

Amato, did you speak to anyone else -- strike

that.

Did you speak to Angel Rivera about

the election that day?

A. Well, I saw him at the parade and

talked to him.

Q. When was that?


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.---.~--..-- ---------------------------.

A. That same day.

Q. And you spoke to him about the election?

A. I think we might have discussed it.

Q. Do you recall any specifics about that discussion.

A. Urn, I don't really recall any, like,

specifics, just frustration about this situation. Q. Did he advise you that he had

received a subpoena for his deposition?

A. Yes, he did. I'm quite sure he did.

Q. Do you know Belinda Mc Donald? A. Yes, I did.

Q. Who was Belinda Mc Donald? A. She was one of our captains in the

housing authority.

Q. What's a captain? A. Well, it's someone who was in charge

of, you know, coordinating a group of workers in

the housing authority.

Q. And what would that mean, coordinating a group of workers?

A. Well, what we tried to do is, each

person set up a team, you know, and they were

supposed to hire certain - this was my


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erstanding. I wasn't actually part of making

all the decisions and coordinating the workers so.

Q. You delegated that? A. Yes, I delegated that.

Q. Who did you delegate that to? A. Doug.

Q. What's your understanding - you started to explain it to me a second ago, and I

cut you off a little bit. I apologize for that.

What's your understanding as to how workers came

to be workers?

A. You know, the, basically, the

captains made the decisions as far as who would be

who would be hired and who would not be.

Q. Do you know what those decisions were based upon?

A. Based - no, I don't. I mean, I

would

Q. I don't want to you guess. A. Yeah, I'm not going to guess. I

mean, I don't know.

Q. When you say workers as opposed to

staff, there is a difference?

A. I'm not sure what you mean by the

question.


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1 Q. I will rephrase it.

2 Earlier we talked about volunteer

3 staff that you had

4 A. Right.

Q. -- for you're campalgn.

6 A. Yes.

7 Q. And then, in my questioning of you 8 regarding Belinda Mc Donald, you indicated that

9 she was a captain in charge of certain workers.

Were those workers paid or not paid?

11 A. They were paid.

12 Q. Explain to me your understanding as 13 to how they get paid?

14 A. Urn, what do you mean as far as how

they get paid? By -- by check.

16 Q. Fair enough. Who made the decision 17 whether or not to pay those workers?

18 A. Now, I'm not really sure.

19 Q. Would Doug Snyder make the decision whether to pay workers that were under the

21 responsibility of a captain?

22 A. Yes, I think he would have been

23 involved in that.

24 Q. Do you know whether there was any protocol that would govern the determination to


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pay a worker or not to pay a worker?

A. Yes, I believe there was.

Q. Do you know what the protocol was? A. I don't know exactly.

Q. Who would know? A. Doug could probably speak to that.

And also, Vonda McKeithan was

involved in making the decisions.

Q. Can you, please, spell that name for me.

A. Vonda, V 0 n-d-a. I think it's

M c K e-i-t-h-a-n.

Q. Do you know, do you have any understanding as to why some workers might get

paid one amount, and other workers, a different

amount?

MR. NORTHGRAVE: Objection. Your question assumes, A, that that happened. And I

don't know if you want to refer to the reports.

The reports indicate that, in fact, that happened;

and, B, that Ms. Zimmer is aware of that.

MR. DOWD: Mark this P-7.

(Whereupon, Exhibit P-7 is marked for identification.)

Q. Ms. Zimmer, I'm going to show you

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~h~t has been marked P-7.

A. Okay.

Q. It's an exhibit. I'm going to represent to you that it's the 20 day post

election report filed by your campaign, Dawn

Zimmer for Council.

I believe you have a copy in front

of you.

A. Yes.

Q. And with your counsel's permission, I'll refer to the exhibit, but we'll both look at

the copies simultaneously?

MR. NORTHGRAVE: Yes.

Q. If you want to take a look at that, if you haven't seen it.for a while?

A. Okay.

Q. And just let me know when you're done.

Are you finished?

A. Yes, it's fine.

Q. Can you look at the last page of this report, please. Towards the middle of that

last page -- the top of the page says Statement of

Campaign Depository and campaign treasurer?

A. Yes.


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1 Q. And then, in the middle, it says 2 Certification?

3 A. Certification?

4 Q. In the middle of the page. A.

6 Q. Beneath certification, there is a 7 name and a signature. Is that your name and your

8 signature, Dawn?

9 A. Yes.

Q. What's the date of that? 11 A. 6/28/07.

12 Q. Can you read that certification to 13 yourself?

14 A. "I certify that the statements on

this document are true, and that the contribution

16 amounts received conform with the limitations

17 designated by law. I'm aware that if any of the

18 statements are willfully false, I may be subject 19 to punishment."

Q. So, by signing that, you, basically, 21 attest to the validity of the information

22 contained in this document?

23 A. Yes.

24 Q. And you are satisfied that the information in this document is true and


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accurate 1 y cJepi ct s the campai gn con t r ibu t ions -an-d

expenses that are listed in the report?

A. Unless further amendments -- I mean

this was our 20 day, there may have been some

amendments that were needed to be made. I'm not

sure.

Q. As of that date, though, the 28th, you were satisfied that the information here was

correct?

MR. NORTHGRAVE: Objection. The certification says that it was not willfully

false, the information is not willfully false.

Q. Just going back to the certification on the back page, it says that I certify that the

statements on this document are true. Is that

correct?

MR. NORTHGRAVE: Right.

A. Yes.

Q. And you stand by that certification? A. Well, like I said, unless there were

some - I believe there were some amendments that

were made, but I don't have everything in front of

me.

Q. Fair enough. Is there anything in here that, sitting here right now, having reviewed


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it - and I knovl you Liidn J t rev i e~v eve ry pag. A. Absolutely.

Q. Is there anything, sitting here right now, that you would want to point out to me

that is in correct?

A. I don't really know. I would have

to go through it very carefully to officially

answer that.

Q. I would like to direct your attention to what's listed as Schedule I-D?

A. Okay.

Q. And if you go to the second page of that schedule.

A. It starts with check number 236?

Q. Correct. And if you go down to check number 243.

A. Yes.

Q . Who is that made out to? A. Glen Butler.

Q. Do you know who Glen Butler is? A. Yes.

Q . Who is he? A. He, I'm pretty sure I know who he

is. He has his own company, specializing in

helping out with elections.


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25 1 Q. Do you know the name of that

2 company?

3 A. I don I t, actually.

4 Q. Is that company called Rob Horowitz 5 Associates, Inc.?

6 A. No.

7 Q. What does his company do?

8 A. Urn, he, I believe, brings together a

9 group of, you know, people who help getting out

10 the vote in elections.

11 Q. How did you find out about Glen 12 Butler's company?

13 A. Through Carol Marsh.

Q. A.

Q. 17 A. No, she was not a part of it.

18 Q. Did she assist in this election in 19 any way?

20 A. Yes, she assisted she assisted, but

21 she was not a formal part of the campaign.

22 Q. How did she assist? 23 A. She helped out with some fund

24 raising.

25 Q. It indicates here that this check,


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number 243, that Glen Butler was paidi by that-

check, the amount of $125. A. You know what, this may be a

different you know what, 11m going to say I'm

not totally sure who Glen Butler is. There's

I'm not totally sure who Glen Butler is.

Q. Is there someone else with a similar name that had a company?

A. Well, there was someone else that

was hired as part of the team, and I'm not sure if

this is the owner of the company, or if this is

one of the workers.

Q. Who is that someone else you were talking about who was hired by the campaign?

A. I'm not sure of his name. I thought

his name was Glen too. There might be two Glens.

I'm not sure.

Q. Were there any other employees? A. Do you know what I mean? Like Glen

the owner and Glen the worker.

Q. Were there any workers of that company that worked on your campaign?

A. There was Jenny Davis and Vonda

McKeithan, and the owner, and this guy named Ryan.

And I believe that was it.


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Q. R Y anY a co fp h) ? A. I'm not sure of his last name.

Q. Do you know whether he was from New Jersey or not?

A. No.

Q. Would you turn to the next page in that Schedule 1 D on Exhibit P 7. I ask you to

look at the first name, the first check listed.

A. Yes.

Q. Alex Melendez?

A. Yes.

Q. Do you know who Alex Melendez is? A. Yes, I do.

Q. Who is he? A. He's a person who lives in the

housing authority.

Q. What did he do for your campaign, if anything.

A. I know there were some issues with

Alex, so I'm not sure; but he worked in the May

8th election. And I don't believe - I'm not

sure, so I'm not going to

Q. Can you tell me the date that he was paid, according to Schedule 1 D?

A. According to the Schedule 1 D, he


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waS paid on August 15th, what? 06/15?

Q. June 15th? A. I don't know. It looks like -- it's

hard to tell. It looks like a six.

Q. You don't have an independent recollection of what day he got paid. Your

recollection is based on when you see here in the

report?

A. Right.

Q. And how much did he get paid? A. $75. Q. And the purpose, as stated in P-7,

the purpose for which he got paid was voter

participation promotion.

A. Uh-huh.

Q . What is that? A. It just refers to helping to get out

the vote.

Q. Is it your understanding that Alex Melendez helped you get out the vote in one of

these. two elections that took place?

A. I believe he helped in the May 8th,

and I don't think he helped on June 12th.

Q. Can you explain why he would have been paid on June 15, 2007 for working the May 8th


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election?

A. There was a mix up with his check.

Q. What was the mix-up? A. I don't really know exactly, but

Q. Has he been asked to give that money back to the campaign?

A. No, he hasn't been asked to give it

back.

Q . Is it your understanding that he didn't earn the $75?

A. I should say, I haven't asked him to

give it back.

Q . Is it your understanding that he didn't earn the $75 for doing work in your campaign in the June election?

A. I don't know.

Q. Do you know if he got paid for work that you believe he performed in the May 8th

election?

A. I know - I'm quite sure that he got

paid late.

Q. Do you believe this is the payment for the May 8th election?

A. I believe it is.

Q. Looking on that same page the next


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voter listed below lex Melendez' name, check

number 248, do you know that person?

A. 248, Florence?

Q. Correct. A. Yes.

Q. How do you know Florence? A. She is that Andrew Amato's wife.

Q. So this is Florence Amato? A. Uh-huh.

Q. And the indication here is that Florence Amato was paid for voter participation

promotion?

A. Yes.

Q. And what does that mean, voter participation promotion?

A. Like I said, it means helping to get

out the vote.

Q. Do you know what Florence Amato did to help get out the vote?

A. I don't know exactly.

Q. Did she do anything? A. She was always talking to people.

She went around and campaigned with me.

But I was not part of paying, you

know.


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Q . You weren't handing out checks?

A. Right.

Q. Did you pay anyone yourself? Did you hand out checks to any workers with respect

the June election?

A. To the June election? I don't

believe I did.

Q. How about the May election? A. Urn, I believe I gave Alex Melendez

his check from the May election, which is why I

know it was so late.

Q. And you believe you gave him that check on June 15th?

A. I don't know the exact date, but I

know it was late.

Q. Do you believe the check was In the amount of $75?

A. Yes, I believe it was.

Q. Do you know why Alex Melendez was paid more than Florence Amato for voter

participation promotion?

A. So - we - I believe it would have

been because we paid our workers a different

amount in the first election than in the second

election. We set up a different structure.

to


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Q. Well, looking dOvln at the next person on that list, Allen Grossman, who received

check number 249 in the amount of why $110, do you know why received more than Florence Amato for

voter participation promotion?

A. No, I don't. Like I said, I was not

part of the setting up of the structure.

Q. So you don't know what the criteria was for determining why one person got X-amount

and a one person got Y-amount?

A. I know that people were asked to

distribute flyers, you know; and if they did more

work before the election, they got paid more. But

I don't know exactly what the breakdown was and

how that worked.

Q. Aside from Alex Melendez, did you, personally, hand anyone else a check for working

on the campaign, whether it be the Mayor the June

campaign?

A. I believe I gave, possibly, one,

maybe two, other checks.

Q. Do you recall to whom? A. I don't remember the names.

Q. Did you pay anyone with cash for work they did in the election?


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I don't think I did that.

Q. Do you know if anyone did that as part of your campaign?

A. I don't believe so.

Q. Did you pay anyone with a personal check for work that they did on the campaign?

A. I don't believe I did. I don't believe so. Not to the best of my recollection.

Q. You were talking earlier about some workers who worked for someone you believe his

name is Glen?

A. Uh-huh.

Q. Can you tell me, Jenny Davis, can you describe Jenny Davis for me?

A. What do you mean, describe her?

Q. What she looks like. A. She's short, has short hair, curly

hair.

Q. What race or ethnicity lS she? A. She's white.

Q. And what did she do for the campaign?

A. She helped me get organized.

Q. What do you mean, she helped you get organized? Did she do the same things that Rachel


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Goldberg did?

A. Yes, she was working with Rachel.

Q. Did you have a campaign headquarters?

A. Yes, I did.

Q. Where vJas that? A. That was on First Street.

Q. Is that referred to as "the club" ever?

A. The club? Well, you know, not by

me. But I think, possibly, the seniors referred

to it that way.

Q. Did Jenny Davis do work for you at your headquarters?

A. Yes, she came into the headquarters.

Q. The work that she did in helping you organize, did that entail doing anything outside

of headquarters?

A. Urn, I don't -- I don't remember

exactly.

Q. How often were you at headquarters during the campaign?

A. I was in and out of headquarters.

Q. On a daily basis? A. Yes.


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Q. Vonda lVicKeithan also workedfor this person you referred to earlier as Glen?

A. Yes.

Q. And she performed work for your campaign?

A. I believe she did, yes.

Q. And do you recall whether she was a volunteer worker or a paid worker?

A. I believe she was a paid wor r.

Q. And you believe she was paid by your campaign?

A. You know, I'm not sure exactly how

she was paid.

Q . How else could she have been paid,

other than by your campaign for the work she did

for your campaign?

A. She could have been paid, may have

been paid, by in-kind contribution. I'm not sure.

Q. Are you aware of those types of payments to people who worked on your campaign?

A. What do you mean?

Q . Let me ask you this. What do you

mean when you say she may have been paid by an

in-kind contribution?

A. Exactly what I said. She may


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have- - - I' m not sur e how, e x act 1 y - - I' In not sur e

how she was paid. Like I said, I wasn't involved

in all the finances of

Q. Are you saying that some other A. Is she on here? I mean, I'm not

sure.

Q. Are you saying that someone other than the Dawn Zimmer far Council campaign may have

paid her for the work that she did for your

campaign?

A. Yes.

Q. Do you know of anyone else who did work for your campaign and was paid, but was not

paid by Dawn Zimmer for Council Campaign

Comm itt e e ?

A. So that group of people whose -- the

owner I believe is Glen, like, that group of

people, may have been covered by an in-kind

contribution.

MR. NORTHGRAVE: I need to object at this point, just to clarify the record.

Counsel, you're assuming. She's

saying "may have been" and you're saying "were".

I just want the record to be clear she never said they were. She's just saying that may have


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occurred.

Q. Are you aware of anyone else, of anyone, being paid for work that they did on your

campaign but who were not paid by your campaign

committee for that work?

A. No, I'm not aware of anyone else.

Q. The company that you talked about that, this Glen person

A. Yeah.

Q. -- owns? A. Right.

Q. Did your campaign committee pay that company?

A. I'm not sure.

Q. Did your campaign pay the owner of that company?

A. I'm not sure.

Q. What work did Vonda McKeithan do for your campaign?

A. I believe she was involved with

working with the people in the housing authority.

Q. And was she a captain? A. I don't think she was called a

captain. I don't know.

Q. Did she work with the captain?


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A. Yes, I believe she did.

Q. Did she work with Belinda Mc Donald? A. I believe she did.

Q. Do you know any other captains that were working in the housing authority?

A. Sandra Smith. Vivian Watts, urn, I

believe Kim Torres. That's who I can think of at

the moment.

Q. They were captains? A. Yes, I believe so.

Q. And did they hire workers for your voter participation promotion?

A. I don't know exactly how it worked,

so they were part of the process.

Q. As captains, would there be workers that were somehow assigned to them?

A. I don't think that's the way the

process worked.

Q. What's your understanding of how the process worked, if you know?

A. They -

Q. In terms of people that you described as workers and people that you described

as captains.

A. I believe that the captains were


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pa~t of choosing the teams, but I'm not sure

exactly how it worked.

Q. And you said Vonda McKeithan worked in the housing authority. Can you recall,

specifically, what work she was doing?

A. I think she was working with the

captains.

Q. To do what? A. To help manage the process.

Q. Are you aware as to whether or not Vonda McKeithan was encouraging people to vote by

way of absentee ballot?

A. I'm not aware of whether or not she

-- I mean, I believe she was.

Q. What do you base that belief on? A. Everyone in my campaign was

encouraging people, you know, if they aren't going

to be able to get to the poles, to vote by mail.

Q. Did they encourage people to vote by way of absentee ballot for any other reason?

A. What do you mean?

Q. Other than because they couldn't get to the poles.

A. I don't -- not to my knowledge.

Q. The workers, you mentioned earlier


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that there were captains and there were workers-at

the housing authority. The workers, as far as you know, work on election day?

A. Everyone that was hired to work

should have been working on election day.

Q. Did hear aboutyou complaintsany Vonda McKeithan during the campaign?

A. Urn, I do recall hearing - no,

actually, no, it wasn't about Vonda. No, I didn't hear any complaints about Vonda.

Q. Who did you hear complaints about? A. I canlt remember the person's name.

Q. What was the complaint? A. I don't remember exactly what the

situation was.

Q. Well, what was the nature of the complaint? Did it have anything to do with

absentee ballots?

A. No, it didn't.

Q. Did it have anything to do with harassment?

A. No.

Q. You indicated that people that worked for you encouraged others to vote by

absentee ballot.


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lV1R. NORTHGRAVE: Objection. That's not what she said. She said people in her

campaign encouraged people to vote by absentee

ballot if they weren't going otherwise going to

be able to get to the polls. Based on your

complaint, that's a critical distinction.

Q. The people who were encouraged to vote by absentee ballot by workers in your

campaign.

A. Yes.

Q. How were they encouraged? A. I don't how the - I don't know

exactly how that would have happened.

Q. Did you encourage anyone to vote by absentee ballot?

I'm sorry, you didn't finish

responding. I interrupted you. Go ahead.

A. That's all was going to say.

Q. Did you encourage anyone to vote by absentee ballot?

A. When I went around campaigning, I

explained to people that the law has changed. You

no longer have to have a reason, you don't have to

be sick or anything; anyone can vote by mail if

they're not going to be able to get the polls and


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the y don't -wan t tog e t to the poll s , the yea n v 0 t e

by absentee ballot.

Q. Did you explain the process to them? A. Yes, I did explain the process.

Q. What is your understanding of the process?

A. That you can fill out an application

and send it in, and then you're - sometimes I

joked with people. Then the ballot comes to your house and then you fill out the ballot and you

mail it in.

Q. In those instances where you encouraged people to vote by absentee ballot and

explained this new process to them, did you, at

the time, did you have any absentee ballot

literature with you?

A. Um, yes, I believe I had

applications with me.

Q. Did you provide applications to voters?

A. Yes.

Q. Absentee ballot applications? A. Yes.

Q. During this process, did you take

notes as to which people you thought might be


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favorable to your c~mpaign?

A. Urn.

MR. NORTHGRAVE: During the process

of going door to door or during the process of giving people absentee applications? The question

is not clear.

MR. DOW D: It seemed to me that the

testimony was that that was part of one process

door-to-door campaigning and explaining the

absentee ballot process.

A. Well, sometimes.

MR. DOWD: Wait until your

attorney directs you.

MR. NORTHGRAVE: If you understand

the question, go ahead, answer. The question to

me, is I think you may be answering a question

he didn't ask. But if you think you understand

it, go ahead.

A. Can you rephrase it, please.

Q. Sure. When you were going door to door, during your campaign.

A. Yes, uh huh.

Q. Did you have a list of voters with you?

A. Sometimes I did.


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Q. And when you were going door to door, at the times when you did have a list with

you, did you ever take notes as to whether a

particular voter might be a supporter of yours?

A. I tried to, but I wasn't very good

at it. It was hard to keep track of everything.

Q. Did you do this door-to door effort by yourself?

A. Urn. No. I didn't go by myself.

Q. Were there any other people who were going door to door with you who were taking notes

as to whether or not a voter was supportive of

your candidacy?

A. I was trying to do it, but there

weren't -- I don't think there were other people

taking notes.

Q. In the times that you provided absentee ballot applications to potential voters,

did you make any note as to which voters you

provided an application to?

A. Well, what when I - I didn't always

bring absentee ballot applications. I mean, that

was sometimes that I did that. And generally, I

tried, we tried, to get them to fill out the

a lication and give it back to us.

ROSENBERG &ASSOCIATES, INC. (973) 2289100 www.rosenbergandassociates.com

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Q. Can you tell me who the people were that were with you these various

times? Could you list, to the best of your

knowledge, the people that were accompanying you

going door to door?

A. It's hard to - I fell like the two

campaigns have merged into one.

Q. Well, for purposes of this question, limit it to the June runoff election, if that

helps.

A. Yeah. And I'm spacing on it. There

were two volunteers that helped me. I can't

believe it. I'm spacing on their names.

Q. Did Vonda McKeithan ever accompany you?

A. No, she did not.

Q. Florence Amato? A. I never handed out -- yes, I mean,

Florence did, yes.

Q. How about Vivian Watts? A. No, she did not.

Q. Belinda Mc Donald? A. I don't think so.

Q. Did Rachel ever accompany you when you were going door to door?


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A. I don't think Rachel and I ever went

together.

Q. Did the applications that you provided to people, did they ever hand those back

to you or to the person that was with you when you

were going door to door?

A. I believe so, for the June 12th, I

believe so.

Q. And what was done with those applications?

A. They were brought back to

headquarters, and then taken to the board of

elections.

Q. They were brought back to a headquarters. Did you, personally, take absentee

ballot applications back to headquarters?

A. Um, I don't remember whether I was

the one. I think, I think I may have taken some

of them back.

Q. Who else did take some back, to the

best of your recollection, other than you.

A. I just -- I can't remember whether Lorraine Herman may have, but I can't

remember whether she really only worked on the May

8th or was still involved in the June 12th. Its


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kind 6f all merging together.

Q. What happened to those absentee ballot applications after they were brought back

to headquarters?

A. Lorraine Herman helped with bringing

them to the board of elections.

Q. Was that for the JUne? A. I'm quite sure that she was the one.

Q. Did she bring them back the same day that they were brought into the headquarters?

A. No, she was not going every day. I

mean, they

Q. Where were the applications physically placed at headquarters when they were

brought back to headquarters?

A. They were on a shelf.

Q . These were completed applications?

A. Yes.

Q. Did anyone other than Lorraine Herman bring back applications from headquarters

to the clerk's office?

A. I believe Doug Snyder brought some

applications.

Q. Was this during the June election? A. I'm quite sure, I'm quite sure he


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did during the June election.

Q. Anyone else? A. Not that I can think of.

Q. Did you incur any expenses in your campaign that were paid for by someone other than

your campaign committee?

A. I'm not sure.

Q. You're not sure of the question. Or not sure whether that happened?

A. Rephrase the question.

Q. Were there any campaign expenses incurred by your campaign that were paid for by

someone else, someone other than your ca aign?

A. Not to my knowledge, but I'm - you

know, I'm not sure.

Q. Do you know if Beth Mason paid for any of your campaign's expenses?

A. Urn. We did -- there was a -- I

can't remember if it was from May 8th or June

12th. There was a training for the challengers,

but I don't - I don't think that she paid for it,

unless it was something that - I'm not sure.

Q. Did you say that she conducted the

training for the challengers?

A. No, someone that she had hired


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1 con d u c ted the t r a i n i n g; and 0 u r c hall eng e r s j -0 i ned 2 that training, but I can't remember if it was from

3 May 8th or June 12th.

4 Q. Are you aware of the organization called Vote Hoboken, Inc.?

6 A. Yes, I am.

7 Q. What is that organization, to your

8 knowledge?

9 A. It's an organization that's -- you

know, I wouldn't really know how to describe it.

11 I think they -- it's a -- I guess you would

12 describe it as a political organization.

13 Q. Did they support you in the June 14 election?

A. Urn, I wouldn't really say so.

16 Q. Did you receive any contributions 17 from Vote Hoboken, Inc.?

18 A. Not to my knowledge.

19 Q. Do you know who runs that organization?

21 A. Urn, well, could you rephrase the

22 question.

23 Q. Do you know anyone who is in charge 24 of that organization?

A. Who, urn -- I don't know his name.


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1 Like, I don't know 'the chairman's name. I knovJ,

2 you know, Kim Cardinal is involved, Lane Bigardi

3 (ph) is involved. 4 Q. Who is Kim Cardinal?

A. She is a Hoboken resident.

6 Q. Does she live in the fourth ward?

7 A. No, she lives in the first ward.

8 Q. Do you know if Beth Mason is a

9 member of Vote Hoboken, Inc.?

A. I'm not sure where she stands on

11 that. I mean, she was I'm not quite sure where

12 she stands on that.

13 Q. Does Vote Hoboken, Inc. have some 14 kind of agenda that's recognizable that could help

describe what that organization is?

16 A. I don't know.

17 Q. Do you know whether they're a formal 18 political organization?

19 A. I don't know exactly. Like,

technically, what they are. I'm not sure.

21 Q. Do you know if they performed any 22 work on behalf of your campaign for the June

23 election?

24 A. I don't believe that they did.

Q. How about the May election?


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~ A. Well, the May election, we had

well, they didn't, but we had some of their they

people that they hired working for us for a short

time.

Q. Who? A. Michael Aleva (ph). Q. Anyone else that you can recall? A. 1'm spacing on his name. There's

one other person. I can't believe I'm spacing on

his name Musa Moore (ph). Q. Did they do any work for your

campaign, your June election campaign?

A. No, I don't think so.

Q. Are you aware of allegations that individuals associated with Chris Campos have

been harassing voters since this litigation was

instituted?

A. Urn, yes, I have, I have heard about

that.

Q. Who did you hear that from? A. Urn, I believe I heard it from I

believe I heard from - I think it was from Sandra

Smith.

Q. Sandra Smith, did she complain that

she was harassed by people associated with the


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Chris Campos ~ampaign?'

A. I believe she did.

Q. Did she describe it in any way? A. She didn't really go into detail.

Q. What did she say? A. No, I don't really remember, because

I didn't totally understand what she was saying

and I was so I can't really speak to it.

Q. Are you aware of, other than whatever Sandra Smith told you, are you aware of

any claims of harassment by individuals associated

with the Chris Campos campaign?

A. Yes, there are two other people.

Q. Who? A. I believe it's Frank Ladson and

Vivian Watts.

Q. And what was the nature? A. They -- I mine, I see them quite a

bit.

Q. Did they speak to you about their claims of being harassed.

A. They didn't speak to me directly

about what they said their claims were, what they

put in the claim.

Q. Did they make a formal claim of


--..... ....--~~

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harassment?

A. My my understanding is that they

did.

Q. Okay. What do you mean by that? What kind of formal claim is that?

A. Well, I was told that they went to

the police.

Q. Who told you that? A. I think it was Frank Ladson. Maybe

it was Vivian Watts. I'm not sure.

Q. But they didn't tell you what their specific complaint was?

A. I knew that no, they didn't tell

me, specifically, what they put in the complaint.

Q. Did they claim that they were being subjected to, like, racial harassment?

A. I don't know exactly what was in the

claim.

Q. Were you present when a call was made to the "Hoboken Reporter" about harassment of

Vivian Watts and Frank Ladson?

A. Yes, I was.

Q. And who made that phone call? A. I was that -- I made the phone call

to Michael Mullins.


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Q. Why? A. Why did I make the phone call?

Q. Yes. A. Because Vivian Watts does not have a

phone.

Q. And why were you calling the "Hoboken Reporter" for Vivian?

A. Urn, because I felt like, if he

wanted to know more about the story, he should

talk to people directly.

Q. Were you present when she was speaking to him?

A. I gave her the phone, so, yes, I was

there.

Q. She was standing next to you? A. Yes.

Q. What did she till the reporter? A. I think that was when she told him

about -- she thought that Gerry McCann had called,

she heard Gerry McCann call Frank Ladson an

arrogant nigger.

Q. Did Frank Ladson speak to the

reporter?

A. He came later; and then, yes, he

not in that same phone call.


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55 1 Q. Where were you at the time this

2 initial phone call by Vivian Watts was made?

3 A. I went down to the housing

4 authority, so I was there.

Q. What prompted you to go there?

6 A. Urn, because I

- I went there

7 because Michael Mullins said he wanted to speak

8 with her.

9 Q. So Michael Mullins contacted you? A. Yes. I don't remember who made the

11 phone call, though.

12 Q. And Frank Ladson, were you present 13 when - did Frank Ladson speak with the reporter

14 also by phone?

A. I believe he did.

16 Q. Did he use your phone, also? 17 A. I can't remember if he -- he has a

18 phone, so

19 Q. Were you present when he spoke to the reporter?

21 A. I wasn't right next to him when he

22 spoke.

23 Q. Did Mike Mullins ever make you aware 24 of how he became aware of these harassment

allegations?


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A. -Urn, I mean, I'm not I think it

was actually me that told him about it.

Q. Did you encourage Frank Ladson to speak to Mike Mullins?

A. I asked Michael Mullins if he wanted

to speak directly and find out the story.

Q. Did you encourage Vivian Watts to speak with Michael Mullins?

A. I wasn't encouraging them to speak

with him.

MR. NORTHGRAVE: At this point, what

does that possibly have to do with the petition or

the counter petition? I understand it's pretty

broad here, but candidly, this is a political

case. This is a counter spin a bad story for the

petitioner here. I'm trying to give you some

leeway here, counselor; but if this goes too much

farther, I'm just going to direct the witness not to answer.

Q. If I'm not mistaken, both Vivian Watts and Frank Ladson are voters whose votes have

been challenged in this litigation; and the

participation of your client, based on the

testimony that she's given, I think, is important

to determine -- it's going to go towards the


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--~.-----------.----------~--.-.-~.---

credlbiliti of th~e witnesses; it's going to go towards whatever defenses are raised with respect

to these witnesses' ballot casting.

I think there's plenty of reason to

go down this route. I can tell you I'm not going

to go much further right now.

MR. NORTHGRAVE: And, counselor, I'm

sure you're doing this in good faith. I'm not

questioning that. It's just, we have a very limited period of time to do this discovery. And

if it goes too much farther, then I'm going to

direct the witness not to answer. But I'm not

directing the witness not to answer at this point.

MR. DOWD: Could you read the last

response of the witness back.

(The requested portion of the record is read by the Reporter.)

Q. Did you recommend to Vivian Watts she consider filing a police report?

A. I don't believe I did.

Q. Did you recommend to Frank Ladson that he consider filing a police report?

A. I don't believe I did.

Q. Are you aware of anyone else who was present when Vivian Watts was allegedly harassed?


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Urn, I believe there were other

people there, but I don't know them personally.

Q. Did the alleged harassment of Vivian and Frank Ladson take place at the same time?

A. I don't know.

Q. To your knowledge? A. I don't know.

Q. Do you know anyone else who they spoke to about these claims of harassment?

A. I don't know.

Q. Did you hear what Frank Ladson stated to the reporter?

A. No, I didn't listen to it.

Q. In your campaign, did you mail literature?

A. Did we mail literature?

Q. Yes. A. Yes, we mailed literature.

Q. Was there a single person responsible for coordinating that effort?

A. Urn, who was responsible for that?

Urn, no, don't think there was a single person.

Q. Are you aware of the allegations in Mr. Campos' complaint that voters in the fourth

ward received campaign literature in envelopes


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accompaniea-b9 lottery tickets?

A. Yes.

Q. Are you aware of that allegation? A. Yes.

Q. Do you believe that allegation to be true?

A. That I

Q. Do you have any knowledge that voters received campaign literature of yours that

was accompanied by a lottery ticket?

A. I believe what was in the envelope

was just the lottery ticket. Q. What is that belief based on? A. Based on the fact that I took them

around.

Q. You took? A. I took some of them, yeah.

Q. What did you take around? A. I distributed some of the envelopes

to people.

Q. What was on the envelopes? A. I had my my urn, my -- I believe,

my, urn, sticker, you know, Dawn for Council

sticker was on there. And then there was a

sticker that said: Don't gamble with your future.


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Vote Dawn Zimmer 18 was on there?

Q. And what was inside the envelopes? A. I think we just had the lottery

ticket. But I'm not sure. I don't remember what

was

Q. Were these mailed? A. No, they were not mailed.

Q. They were hand-delivered? A. They were placed, either -- you

know, some people you know, I knocked on the

door; and then I ran out of time, so I put them

under people's doors.

Q. So some people, you knocked on their door; and if they were horne, what would happen?

A. Then I gave it to them.

Q. Do you recall approximately how many of these envelopes you distributed?

A. Urn, I don't remember exactly.

Maybe - I don't remember exactly.

Q. More than ten? A. Probably more than ten, yes.

Q. More than 50? A. Not more than 50. Not more than 50.

Q. More than 20? A. Probably more than 20.


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More than 40?

A. That I don't know.

Q. So now we have a range somewhere between perhaps 20 to 40.

A. That sounds fair, yes.

Q. And overall, did other people distribute these envelopes with a lottery ticket

in them?

A. Yes, I believe they went to 400

First, 220 Adams, and 221 ckson.

Q. Where did you distribute them? A. 221 Jackson.

Q. And who distributed them? Did anyone else distribute them at 221 Jackson?

A. Forde Prigot.

Q. What's his name? A. Forde Prigot, P-r-i-g-o-t; F-o-r-d-e

is the first name.

Q. How do you know Forde Prigot? A. He's a volunteer.

Q. Is 221 Jackson a senior building? A. Yes, it is.

Q. Who distributed tickets at 220 Adams, the envelopes with lottery tickets inside?

A. I'm not sure who did it in that


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building.

Q. Do you know who delivered the envelopes with lottery tickets at 400 First

Street?

A. I'm not sure who did it.

Q. Is 400 First Street a senior building?

A. Yes.

Q. Is 220 Adams a senior building? A. Yes.

Q. Do you know whether Belinda Mc Donald distributed any of these envelopes with

lottery tickets in them?

A. I don't know.

Q. So, aside from you and Forde Prigot, were there other people that distributed these

envelopes?

A. I believe there were other people.

Q. But sitting here today, you can't

recall who?

A. No, I don't recall; I don't know who

did it.

Q. Do you know how many envelopes Forde Prigot distributed?

A. The same range. He was with me the


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whole time.

Q. So the 20 to 40 you distributed, in that range, would be the same for him, or did he

distribute additional envelopes?

A. You know what, he -- I take that

back. He may have stayed and done the rest of

them. I don't remember how many envelopes we had.

Q. This was for the June election. Correct?

A. Yes.

Q. Aside from the envelopes that you and Forde Prigot distributed a 221 Jackson?

A. Right.

Q. Aside from those, do you know approximately how many other envelopes with

lottery tickets were distributed?

A. I don't know exactly.

Q. Who purchased the lottery tickets? A. I don't know.

Q. Do you know how many lottery tickets were purchased?

A. I don't know.

Q. Do you know who paid for the lottery tickets?

A. I don't know.


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64 r-------------------------~.-----~---~

1 Q. How did your campaign determine who 2 was gOlng to get an envelope with a lottery ticket

3 ln it?

4 A. I don't know how that - I mean, I

just know they were put together and given to me 6 to distribute. I don't know exactly how -

7 Q. Who gave them to you? 8 A. Jenny gave them to me.

9 Q. Do you know who put them together? A. I believe Jenny Davis was involved

11 in that.

12 Q. Do you know if any of these 13 envelopes with a lottery ticket in them were

14 distributed to people other than senior citizens?

A. I don't believe they were, but I

16 don't know.

17 Q. What do you based that belief upon? 18 A. I think that that I think we were

19 just giving them to the seniors. Q. Did you talk about this with people

21 in your campaign?

22 A. Urn, I think we talked about - I

23 think Jenny and I talked about, you know, reaching

24 the seniors, reaching out to the seniors.

Q. This was part of a campaign


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strategy?

A. Ye s.

Q. Were there any other strategies that you and Jenny talked about for reaching out the

seniors?

A. Not that -- I don't remember

exactly. I mean, we talked about going around to

the seniors, but

Q. Did Florence Amato receive an envelope with a lottery ticket?

A. I don't know.

Q. Did you give lottery tickets to every senior at 221 Jackson?

A. I don't know if we gave them I'm

not sure if we gave them to everyone. Urn

Q. Do you know who you did give them to?

A. No.

Q. When you were handing them out, did you have, at the time, did you have a list of

names that you were going by?

A. No, the names were already on the

envelopes.

Q. And is it your belief that Jenny Davis put those names on the envelopes?


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A. ~ believe Ghe did.

Q. Did you and Jenny Davis talk about which names to put on the envelopes?

A. No, we did not.

MR. DOWD: Mark this as P-8, please.

(Whereupon, Exhibit P-8 is marked for identification.)

(Whereupon, a discussion is held off the record.)

Q. Did you have any workers for the campaign that did not reside within the fourth

ward, other than the people you've already talked

about?

A. Yes, I believe we did.

Q. Do you know how your workers were recruited?

A. Urn, I'm not sure how that came

about.

Q. Did you have any assistance from the Hudson County Democratic Organization in

recruiting workers?

A. No, it was more -- it was from

the -- I believe it was Ryan from that special

company that recruited the workers.

Q. If I represented to you that there


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orkers that lived in Jergey City ~b0~workerl.

for your campaign, would you have any idea how

such workers would have been recruited to work for

your campaign?

MR. NORTHGRAVE: Objection. That's what she just answered.

Q. Did the company that you talked about Ryan -- you used the name Ryan?

A. Yes.

Q. Did they recruit workers from Jersey City?

A. I believe they might have recruited.

Q. Do you know if the company that this person Ryan worked for or owned, do you know

whether they were hired by Hudson County

Democratic Organization?

A. Yes, they were hired June 5th.

Q. They were hired on June 5th? A. Yes, they were hired for the June

5th election, they were hired by them.

Q. Do you mean the June 5th primary election, or the June

A. The June 5th primary election.

Q. But they did work for you on your

June 12th runoff election?


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Q. How do you know that they were hired by the Hudson County Democratic Organization?

A. Urn, I'm not sure how I know it. I

think, through Carol Marsh.

Q. Did you hear any complaints about workers who were supposed to work for your

campaign but didn't work for your campaign, but

got paid anyway?

A. Can you restate the question.

Q . Are you aware of any complaints made to your campaign about workers that were paid by

your campaign, but the person complaining claims

they didn't actually work for you, didn't actually

do any work for you?

MR. NORTHGRAVE: Other than the

petition filed in this matter; or -

Q. Other than allegations that have been made in this litigation.

So -- I'm still sorry, I'm stillA.

confused by the question.

You talked about mix up up with AlexQ.

Melendez' payment earlier.

A. Right.

Were there any other mix-ups whereQ.


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d by campaig!l. .pu.pn

didn't work?

MR. NORTHGRAVE: Objection. MR. DOvJD: Let me rephrase that

question.

MR. NORTHGRAVE: Because I don't think that was her testimony.

MR. DO"Y'JD: I know. I didn't mean to insinuate there was such a situation.

Q. Were you aware of any complaints made to your campaign complaining that someone got

paid by your campaign even though they didn't

work?

A. I was not aware of that.

MR. NORTHGRAVE: And just so we're clear, other than what may be in the petition

filed in this matter.

MR. DOWD: Yes.

Q. Do you know Patrick Edy? A. Yes.

Q. Who is Patrick Edy? A. He is a friend of Rachel Goldberg.

Q. Did Patrick do any work for your campaign?

A. Very briefly.


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Q. .Wha t o Nork did he dn?

A. He helped, just before the election, with messengering ballots.

Q. How do you know this? A. From Rachel.

Q. What did Rachel say? A. And Patrick.

Q. {!>Jha t did Patrick say? Patrick told you that he messengered ballots for the election?

A. I knew that it was arranged.

Q. How did you know that it was arranged?

A. From, I believe it was from Rachel,

and possibly Jenny Davis.

Q. What was arranged? A. We -- that he was asked if he would

messenger ballots.

Q. Do you know who asked him? A. No, I do not know.

Q. When you say messenger ballots, you're talking about the actual envelopes

containing ballots, as opposed to ballot

applications?

A. Yes.

Q. What is your understanding what that


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dns, mes-seng 119 ballots?

A. That means he -- that means, when

ballots are messengered, the person signs in front

of the voter and then delivers it to the board of

elections and signs it in the board of elections.

Q. Do you know how many ballots were, if any, were messengered by Patrick Edy?

A. I don't know the exact number.

Q. More than ten? A. I don't know the exact number.

Q. Was Patrick Edy paid by your campaign?

A. I -- no, I don't think so.

Q. Do you know if he received any compensation from any source for the work he did

in messengering ballots?

A. I don't believe he did.

Q. Did you witness Patrick Edy

messengering any ballots?

A. No, I did not.

Q. Do you know if anyone else was

present when he messengered ballots?

I believe Jenny Davis was with him.A.

Q. When you say she was with him, do

you mean from the moment he picked up a ballot


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original

Documents

deposition of dawn zimmer

page dawn zimmer

state of new jersey

kraig dowd

new j e r s e y

n t u e s day

court reporter

brownstein booth associates