sgt. kevin mede, wcso - deposition (federal) - full transcript

Kevin Mede, March 10, 2014Paul Murphy v. Whatcom County

3206 Wetmore Avenue, Suite 12 - Everett, Washington 98201BMA Court Reporters, (425) 252.7277

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7 UNITED STATES OF DISTRICT COURT

8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE

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10 PAUL MURPHY, together with his ) marital community, )

11 Plaintiffs, ) )

12 vs. ) NO. 2:13-CV-00727 )

13 WHATCOM COUNTY, WASHINGTON, a ) government entity; WHATCOM COUNTY )

14 SHERIFF'S DEPARTMENT; WILLIAM J. ) ELFO, together with his marital )

15 community, ) Defendants. )

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17 DEPOSITION UPON ORAL EXAMINATION OF

18 KEVIN MEDE

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20 11:00AM - 12:20PM March 10th, 2014

21 Whatcom County Courthouse 311 Grand Avenue

22 Bellingham, Washington 98225

23 Reported by Kristen M. Uhlig

24 Certified Court Reporter, CCR, CSR Washington CCR #1934

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1 A P P E A R A N C E S

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3 FOR THE PLAINTIFFS:Robert Butler & Emily Beschen

4 Law Offices of Robert Butler103 East Holly Street Suite 512

5 Bellingham, Washington 98225360.734.3448

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7 FOR THE DEFENDANTS WHATCOM COUNTY & SHERIFF'S DEPARTMENT & ELFODale Kamerrer

8 Law Lyman Daniel Kamerrer Bogdanovich2674 RW Johnson Blvd SW

9 Tumwater, Washington 98512360.754.3480

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11 FOR WHATCOM COUNTY:Elizabeth Gallery

12 Whatcom County Prosecutor's Office311 Grand Avenue

13 Bellingham, Washington 98225

14ALSO PRESENT:

15 William ElfoTara Adrian-Stavik

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1 I N D E X

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3 EXAMINATION: PAGE

4 BY MR. BUTLER.................................................3

5 BY MR. KAMERRER..............................................35

6 BY MR. BUTLER................................................47

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9 EXHIBIT DESCRIPTION PAGE

10 1....E-mail Dated 12/8/2010 - 2011 Election Issue............15

11 2....E-mail Dated 10/19/2011 - RE: Murphy Website...........19

12 3....E-mail Dated 3/21/2012 - Memo as requested..............24

13 4....E-mail Dated 10/19/2011 - Murphy Public Disclosure......30

14 5....E-mail Dated 12/16/2011 - RE: Update...................32

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1 KEVIN MEDE,

2 having been first duly sworn, was called as a witness herein and

3 was examined and testified as follows:

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5 DIRECT EXAMINATION

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7 BY MR. BUTLER:

8 Q Good morning. Would you please state your name for the record?

9 A Kevin Mede, M-E-D-E.

10 Q And where are you employed?

11 A Whatcom County Sheriff's Office.

12 Q How long have you been so employed?

13 A This summer will be 15 years, so since August of '99.

14 Q Okay. It's 11:00 on March 10th. You're here for a discovery

15 deposition in the matter of Murphy versus Whatcom County. You

16 have counsel present; correct?

17 A Correct.

18 MR. KAMERRER: I am not his attorney.

19 THE WITNESS: Ah, I do not know.

20 MR. BUTLER: Okay.

21 Q (By Mr. Butler) And that was Mr. Kamerrer who indicated that

22 he's not your attorney; correct?

23 THE WITNESS: Is your name Mr. Kamerrer?

24 MR. KAMERRER: Yes.

25 THE WITNESS: Yes.



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1 Q (By Mr. Butler) All right. And next to him is Liz Gallery.

2 Do you know Liz?

3 A I do.

4 Q Do you know her to be your attorney?

5 A I don't believe that I am represented by anybody.

6 Q Okay. And next to her is Sheriff Elfo.

7 A Correct.

8 Q Do you know him?

9 A Yes, I do.

10 Q And around the corner is Tara, the paralegal for the

11 prosecutor's office. Do you know her?

12 A I -- yes.

13 Q And then next to me is Emily Beschen, an associate of my firm,

14 and myself and the court reporter. Anybody else in the room

15 that you're aware of?

16 A Not that I'm aware of, no.

17 Q Any reason that we should be aware of today that your sense of

18 perception would be compromised or your ability to hear and

19 answer questions truthfully, would be somehow better on another

20 day?

21 A No.

22 Q Under the influence of any alcohol, drugs, prescriptions or

23 otherwise?

24 A No.

25 Q What's your understanding of a discovery deposition? Why



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1 you're here?

2 A To obtain as much information from named witnesses before going

3 to trial to see if they're useful or the information is

4 relevant, I suppose.

5 Q Okay. And in this matter -- do you know Paul Murphy?

6 A I do.

7 Q How do you know Paul?

8 A He was an employee of the sheriff's office.

9 Q Okay. Was he in your 15 years of employment, was he ever under

10 your supervision?

11 A Yes, he was.

12 Q And when was that?

13 A In November of 2007 until he left the sheriff's office -- not

14 contiguously, I'm a shift supervisor, so it would be for

15 periods of time.

16 Q Okay. When you started in '99, what did you hire in at? What

17 was your position?

18 A Deputy sheriff.

19 Q And have you had any promotions?

20 A Yes.

21 Q What promotions have you had?

22 A Rank promotion, a first line supervisor sergeant in November of

23 2007.

24 Q Any other promotions?

25 A No.



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1 Q Of rank?

2 A No.

3 Q So it would be appropriate to refer to you as Sergeant Mede?

4 A Sure.

5 Q Okay. With regards to the sheriff's department, are you aware

6 of anybody in the sheriff's department that has credibility

7 problems?

8 MR. KAMERRER: Object, calls for speculation. In a

9 deposition even though I stated an objection, you'll still

10 answer the question, so I'm just making that for the record.

11 So if you understand the question, you can answer it.

12 THE WITNESS: Not sustained.

13 Q (By Mr. Butler) What's your personal view of the credibility

14 of Deputy Flynn? I'm going to use deputy all the way across

15 these names as opposed to the rank that I may get wrong.

16 MR. KAMERRER: I'll insert another speculation --

17 calls for speculation objection. Go ahead.

18 THE WITNESS: You're asking my personal opinion?

19 Q (By Mr. Butler) Your personal opinion of the credibility of

20 Flynn.

21 A Can you define how you're using credibility?

22 Q Do you think that he tells the truth?

23 A Yes.

24 Q So have you had any question of his telling of the truth?

25 A No.



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1 Q How about Nyhus?

2 MR. KAMERRER: Same objection.

3 Q (By Mr. Butler) Have you had any questions with his truth

4 telling?

5 A No.

6 Q That was a long pause.

7 A Yes, it was.

8 Q Can you explain, since we're just getting this in written form,

9 why you took quite a while to answer that?

10 A I was being sure of my answer, being thoughtful.

11 Q Are you sure of your answer that he is credible and truthful?

12 A Yes.

13 Q How about Taddonio?

14 A Yes.

15 Q And Roff?

16 A Yes.

17 Q VanderVeen?

18 A No.

19 Q Can you explain your concerns with regards to Deputy

20 VanderVeen?

21 A It would have to do with his personal life and keeping

22 commitments and being honest with those in his most inner

23 circle.

24 Q Any regard to his on-the-job sheriff's officer capacity for

25 truthfulness?



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1 A No -- check that. Perhaps. I am skeptical of his incident

2 that brought him to federal court.

3 Q Okay. The Wiederspohn matter?

4 A Correct.

5 Q I'm not going to take time on that. Did you do any

6 investigation in your capacity as a deputy -- as an employee of

7 the sheriff's department into the Wiederspohn, Freeman and

8 VanderVeen matter?

9 A No.

10 Q Moving on. Harris?

11 A Again, I want to answer correctly. Phrase the question again?

12 Q Your personal opinion as to his truthfulness and truth telling?

13 MR. KAMERRER: I just want to insert the same

14 speculation -- calls for speculation -- objection.

15 THE WITNESS: Yes. I have doubts with Harris.

16 Q (By Mr. Butler) Okay. What is that based on?

17 A Differing answers about mostly guild related activity and

18 public disclosures, things like that.

19 Q Anything else of concern or any specifics that you can

20 identify, as you did with VanderVeen, with regard to Harris'

21 credibility?

22 A Not at this time.

23 Q Would there be documents that you could review that would

24 refresh your recollection, do you think? Or when you say, not

25 at this time, would your answer change at another time?



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1 MR. KAMERRER: Objection, that's argumentative.

2 THE WITNESS: Perhaps if I sat and thought about that

3 question for a long period of time, I could come up with better

4 examples. But on the face of it, I don't trust his

5 credibility, most recently stemming from a public disclosure

6 request that he completed and reportedly gave false information

7 about when confronted.

8 Q (By Mr. Butler) And what are you referring to there, just so

9 that we're on the same page? A public disclosure request that

10 he made of the county?

11 A Correct.

12 Q So your concern is that he made a request of the county for

13 documents?

14 A Under the guise of being the guild president after I refused to

15 release them to him. And then he, of course, provided them to

16 you to be spiteful.

17 Q Okay. When was that?

18 A You could answer that better than I could. It was the last

19 several months, maybe three months.

20 Q Okay. Moving on. Cooley? Truthfulness?

21 A No.

22 Q Credibility?

23 A No.

24 Q You don't think that he's truthful and credible?

25 A I do think. I don't have cause to question it.



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1 Q Parks?

2 A No question about him.

3 Q Jeremy Freeman?

4 A The same questions that I have regarding the Wiederspohn

5 incident.

6 Q Anything else with regard to Freeman?

7 A I don't know if it's truth telling. It's more of a perception

8 issue.

9 Q Can you explain that?

10 A He was upset and angry over a disputed, I believe, log event or

11 a counseling session that Sergeant Larson wrote. Where he is

12 adamant that he never displayed the behaviors that were written

13 in the counseling, where I myself witnessed them.

14 So, again, I don't know if it's more a perception issue

15 on his end or if it was an honesty issue. My gut feeling is

16 it's more of a perception issue.

17 Q Okay. When did that take place?

18 A This is, I am guessing, 2009 or 2010. I would have to look at

19 the logs specifically.

20 Q Okay.

21 A But it was years ago.

22 Q Okay. What's your relationship with the guild?

23 A I'm a guild member.

24 Q Have you held any office with the guild?

25 A I did.



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1 Q What office did you hold?

2 A President.

3 Q When were you president?

4 A All of 2012 and up 'til March of 2013.

5 Q Who became the president of the guild in March of '13? Who

6 replaced you?

7 A It wasn't until a couple of months later, but Steve Harris is

8 now the president.

9 Q And who was the guild president that you replaced?

10 A Steve Harris.

11 Q Okay. What's the role of the guild to your knowledge?

12 A The guild is to protect the bargaining rights and to, you know,

13 negotiate a contract for the represented group.

14 Q Laymen's term, it's a union --

15 A Yes.

16 Q -- for the deputies?

17 A Correct.

18 Q Does the guild have internal officers?

19 A Yes.

20 Q Are those elected?

21 A Yes.

22 Q What are some of the functions that the guild officers perform?

23 A There's the treasurer.

24 Q Okay.

25 A That does the traditional treasurer role of bookkeeping and



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1 what not. There's the secretary that keeps track of meeting

2 minutes and notes. There's the first and second vice president

3 that will -- the first vice president is in charge of -- no.

4 Check that. The second vice president is in charge of the

5 grievance committee. The first vice president, I think, just

6 helps the president and the president oversees the board.

7 Q Okay. The grievance committee, what is that?

8 A The grievance committee is a group of volunteers that when a

9 member believes that they have a grievance, a violation of the

10 contract that they believe is wrong, they'll bring it to the

11 grievance committee who reviews the matter and decides to

12 present it to the executive board for whether or not they want

13 to push forward and file a grievance or try to resolve it with

14 the administration et cetera.

15 Q Is everybody in the sheriff's department in the guild?

16 A No.

17 Q Where is the line?

18 A Sergeants and deputies are in the guild.

19 Q Is the grievance committee elected or do they self-appoint

20 themselves?

21 A They volunteer and are accepted or not based on the second vice

22 president.

23 Q Okay. So if the grievance committee reviews something,

24 generally, what happens with that review? What's the next

25 step?



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1 A If -- depending on their decision. If they --

2 Q Sure.

3 A If they decide that it is a righteous grievance, they would

4 present to the executive board who says, yes, we should make

5 the decision to formally grieve this matter or not. It's based

6 on a number of factors, tactical decision making, cost, whether

7 or not the matter is significant enough to forward to a

8 grievance, given those factors. If the grievance committee

9 votes not to grieve it, then the member can elect to do that on

10 their own.

11 Q And the executive board, is that the president, vice president,

12 first assistant, treasurer, secretary, that normal functioning?

13 A Yes.

14 Q Normal hierarchy? I'm sorry. Okay.

15 Is there communication between the guild and management

16 with regards to the grievance committee's work?

17 A There is supposed to be, yes.

18 Q Okay. Is that conveyed through the president or does that go

19 directly -- committee to the sheriff or the management?

20 A It depends. When I was the president, I had the second vice

21 president, Jason Nyhus handle that.

22 Q Okay.

23 MR. BUTLER: I wasn't at the last deposition, Counsel.

24 Where did we leave off on numbering?

25 MR. KAMERRER: I don't know. I think that we should



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1 start over. I think that we should start over.

2 MR. BUTLER: Oh, we can start over and go for

3 plaintiff's deposition exhibits one through -- that's fine with

4 me.

5 MR. KAMERRER: Why don't we just have one package of

6 depositions for this week and number them one through whatever.

7 MR. BUTLER: Yeah. Okay.

8 (Marked Deposition Exhibit No. 1)

9 Q (By Mr. Butler) Showing you what's been marked as Exhibit 1 --

10 I would represent to you that the reason my name is on the top

11 is because it's printed off of my computer.

12 A Mm-hm.

13 Q Do you recognize this as an e-mail that you sent in December of

14 2010 regarding the two-thousand and -- 2011 election issue?

15 A Let me take a minute and look at it.

16 Q Sure.

17 A Yes. I recognize the e-mail.

18 Q Looking back at your dates, did Harris step down as a result of

19 this?

20 MR. KAMERRER: Objection, vague.

21 THE WITNESS: I think that this had something to do

22 with it.

23 Q (By Mr. Butler) Okay.

24 A I can explain it if you would like.

25 Q Well, let me keep asking questions. It may be that I'll just



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1 say, would you explain it, in a minute.

2 So that I'm clear with relationships, you supported Elfo

3 in the election; correct?

4 A Ultimately, yes.

5 Q You did an ad for him; correct?

6 A Yes.

7 Q Okay. And Harris was running against Elfo?

8 A Correct.

9 Q And Taylor ran also?

10 A Yes, he did.

11 Q The fourth paragraph, it says, "A few of the reasons." Do you

12 see that paragraph?

13 A Mm-hm. I see that.

14 Q The second sentence you write there is that the relationship

15 between the sheriff and the guild has soured over the last few

16 years. Do you see that sentence?

17 A I see it.

18 Q What are you referring to there?

19 A The relationship between the guild and the sheriff.

20 Q Yeah. Why was it sour? What was -- why did you use the word

21 sour?

22 A I used the word sour because that was my best analogy for

23 picturing the relationship as far as being collaborative and

24 unified. We're all in the same team type of thing. That that

25 had become adversarial it seems.



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1 Q When you started in '99 --

2 A Mm-hm.

3 Q -- so roughly 10 years preceding this, had it been not sour?

4 A During those 10 years, yes.

5 Q What do you attribute the souring to? If it was good and as of

6 December of 2010 it was sour, what do you attribute the cause

7 for the sour?

8 A Oh, I think that there's -- it would be pure speculation on my

9 point, but my opinion would be as a number of factors, I am

10 sure. But with regard to my labeling it this way with regard

11 to this e-mail, it would be Steve Harris' personality and

12 approach to the administration.

13 Labeling them as evil and everything that they do has an

14 ulterior motive. And we have to -- we as a guild have to

15 grieve every single thing. That, you know, anything that is

16 suggested by the staff needs to be fought against, whether it

17 is shift schedule changes which the deputies would enjoy or

18 propose themselves -- if it was proposed by the staff, we need

19 to fight against it. Things like that.

20 Q So in your opinion, lots of reasons for sour. But in your

21 opinion, Harris was the reason that it soured?

22 A One of the reasons, yup.

23 Q Okay. Is he alone in that in the guild? Was he a lone wolf

24 that thought that management should be challenged?

25 MR. KAMERRER: Objection, calls for speculation.



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1 THE WITNESS: I wouldn't say a lone wolf, but he was

2 the -- clearly the biggest advocate of that.

3 Q (By Mr. Butler) Okay. How is the guild president -- are they

4 elected by the guild?

5 A Correct.

6 Q What's the term? How long are you elected for?

7 A Two years.

8 Q A two year term?

9 A Correct.

10 Q How long had Steve been the guild president?

11 A I don't recall. A period of time. A significant period of

12 time.

13 Q Multiple elections?

14 A I think two.

15 Q And you were the interloper and then he's back; is that

16 correct?

17 A Yup.

18 Q Okay.

19 A Yes.

20 Q Does the vote become known to the guild? Does the -- does it

21 get published that it's 37 to 24 or Steve won or is it just

22 Steve won?

23 A It gets published, the numbers, not the actual individuals.

24 Q Right. But the numbers do get --

25 A Correct.



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1 Q Okay. Are you aware of what the -- what his support is? I

2 mean did he win by one vote? Did he win by a lot of votes?

3 A This last round?

4 Q Yes.

5 A He went unopposed.

6 Q Okay.

7 A I don't think that anyone else wants that job.

8 Q Okay. So is it your understanding that the reason that Mr.

9 Kamerrer and Ms. Gallery and probably Dan Gibson aren't your

10 attorney is because of the guild relationship? That they

11 represent the county and the guild is separate?

12 A My understanding of it is that I'm not on trial. I'm here as a

13 witness and they're representing the interests of Whatcom

14 County.

15 Q Okay. But do you believe that Liz Gallery or Dan Gibson is

16 your attorney in your capacity as a sheriff?

17 MR. KAMERRER: I'll insert an objection. It's vague

18 and calls for speculation. It's irrelevant. Go ahead.

19 THE WITNESS: I suppose if I am on trial for

20 something, they would be my -- well, they would be the county's

21 defense.

22 MR. BUTLER: Okay. All right.


24 Q (By Mr. Butler) Showing you what has been marked as Exhibit 2,

25 this is a multiple page document. So let's start with the --



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1 some identifiers. On Page 1, halfway down, do you see an

2 e-mail from you to Chief Cooley referencing, Attached is a copy

3 and paste version of what is on Murphy's website, Campaign to

4 Un-Elect Elfo?

5 A I do see that.

6 Q Do you recall sending an e-mail to Chief Cooley in October of

7 2011 regarding the Un-Elect Elfo website?

8 A I don't independently recall that, but I am sure that this is

9 correct.

10 Q Okay. We're going to look at a variety of exhibits with

11 e-mails. You're aware that when you print out an e-mail, the

12 first e-mail is typically at the bottom and the response is on

13 top? That's how the thread typically goes?

14 A Yes.

15 Q Okay. Looking at the first page, do you recognize that the top

16 of it is Steve Cooley's response to you thanking you regarding

17 Facebook?

18 A Yes. That's what it looks like.

19 Q Okay. Looking at Page 2 is the clean, if you will, version of

20 what is the bottom half of Page 1.

21 A Yes. That's what it looks like to me, yes.

22 Q Okay. This one indicates that you sent it to Doug Chadwick and

23 Steve Cooley. Why would you have included Doug Chadwick?

24 A I believe that at that time, he was my lieutenant, my

25 supervisor.



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1 Q We by virtue of being your supervisor, you CC'ed him on

2 whatever you sent to Cooley?

3 A Yes. I believe that this stems -- there's a reason for that.

4 That it stems from the -- well, if I'm thinking of it correctly

5 that this is stemming from the meeting that Deputy Murphy and I

6 had regarding his vague -- I've got something big going on.

7 They're going to see, just you wait, type of thing. He --

8 everyone in the deputy ranks knew that he was operating the

9 website. So my assumption was that that's what he was

10 referring to.

11 Q Okay. So with regards to the -- when you look at Page 1, the

12 bottom half or Page 2, the clean version of it, do you recall

13 why you sent this? As in, were you directed, hey, get me this

14 and you're complying? Or did you self-initiate it?

15 A No. I self-initiated it based on -- my best recollection is

16 based on that I've got something really big coming, real big

17 going on, per our conversation about the trails issue.

18 Q Okay. Was there anything in the campaign to Un-Elect Elfo,

19 which is the third through probably about the tenth page -- let

20 me count them. This is just a print out of the page; correct?

21 A I'm sorry, can you say that again? I was reading.

22 Q Okay. That was a really bad question. The following pages,

23 which I think is about 10 pages is just a printout that you

24 printed out from the Campaign to Un-Elect Elfo; is that

25 correct?



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1 A I believe so, yeah.

2 Q Is there anything in that printout, these 10 pages, that

3 related to what you referred to as the trails and something

4 coming?

5 A No. If I can re-address my answer now -- now looking at the

6 timing and flipping the page and looking at the posts that

7 specifically were printed out, it would not be the trails

8 issue. It would be another issue, I guess.

9 Q The issue being his campaign to Un-elect Elfo?

10 A The issue would be him claiming that I was on duty and misusing

11 my authority, appearing in a commercial while I was in uniform

12 or things like that.

13 Q Okay. That's -- when we go to the page, the printout that you

14 have provided here, there's posts that appear to be your name

15 associated. On the first page of it, it says, "No, Deputy Paul

16 Murphy, that video wasn't illegal." Do you see that?

17 A I do see that.

18 Q Do you recall writing that? Is that you?

19 A Mm-hm. Yes.

20 Q Okay. All right. The second page. It says, "Lastly, I am not

21 the Guild President until January 1st. Sorry to correct all of

22 your untruths, but enough is enough." When is the election?

23 A Which election?


25 Q (By Mr. Butler) The election -- you said that you're not the



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1 guild president until January 1st. When were you elected to be

2 guild president?

3 A I don't recall. Sometime -- sometime after Steve Harris

4 stepped down, I would assume, in December.

5 Q Was there a gap?

6 A Wait a minute.

7 Q Was there a gap in time where the guild didn't have a

8 president?

9 A I am sure a small gap.

10 Q When you say small gap, what do you mean?

11 A I --

12 Q Are we talking days or are we talking six months?

13 A Probably weeks is my best recollection.

14 Q You said that everybody was aware that Murphy had the website,

15 Un-Elect Elfo. How did you first become aware?

16 A I don't recall if it was just in roadside conversations or, I

17 believe, that it was banter amongst the deputies of, oh, have

18 you seen the latest, oh, oh, type of thing.

19 Q This appears to just be a two-day print out, the Saturday

20 Sunday snap of this. Would you agree with that?

21 A You have reviewed it more than I have so -- sure.

22 Q Do you recall, was this -- I mean, it says, Attached is a copy

23 and paste version of what is on website that is Tuesday the

24 18th.

25 Would it be your testimony that this is probably the



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1 Saturday, Sunday of, like, the 16th and the 15th? The Saturday

2 and Sunday before you sent this e-mail?

3 MR. KAMERRER: Calls for speculation.

4 THE WITNESS: Yeah. I don't recall. It is -- Mr.

5 Murphy would post so much information on the internet. It is

6 hard to ascertain which -- without a date on it.

7 Q (By Mr. Butler) Okay. And did you follow it?

8 A Only when I received information from deputies that he was

9 talking about me.


11 Q (By Mr. Butler) Showing you what has been marked as Exhibit 3,

12 it appears to be an e-mail from you to Steve Cooley on

13 March 21st. Do you recognize that?

14 A Yes.

15 Q And the first page is, "Attached is the memo regarding the

16 evening of 3/2/12. Let me know if there's anything else."

17 Do you see that?

18 A I see that.

19 Q The second, third and fourth page of the exhibit appear to me

20 to be a memo written by you dated the 20th. Do you recognize

21 that?

22 A I do.

23 Q It's just a really weird memo system that the county has. It

24 has the memo header on each of the pages. Is that what -- is

25 that how it works?



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1 A Yes.

2 Q Okay. It was driving me crazy at my office. Okay. Do you

3 recall why you -- what direction you received to write this

4 memo?

5 A I don't recall exactly who it was, whether it was Chief

6 Chadwick or Inspector Cooley, but I was directed to write my

7 observations of that evening in a memo and forward them to

8 Inspector Cooley.

9 Q What did they know about that evening that they would say,

10 write a memo?

11 A Because Chief Chadwick and Lieutenant Rossmiller were there.

12 Q Okay. You were there as guild or you were there as the patrol?

13 A I was working -- I was the scheduled patrol sergeant. Chief

14 Chadwick told me that I needed to meet at the evidence building

15 to talk to him, so I did.

16 The night shift sergeant was not working that night, I

17 don't recall if they were sick or vacation or whatever. So

18 there was an acting sergeant, which was a deputy, that is the

19 acting supervisor. So it's the same rank as Mr. Murphy at the

20 time.

21 So Chief Chadwick asked that I send Mr. Murphy a message

22 on the computer saying that he needs to come to the evidence

23 building and meet, and then stand by so that I could make

24 staffing arrangements because Mr. Murphy was going to be sent

25 home.



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1 Q Okay. Why didn't you write it on the second or the third, if

2 that's when it happened?

3 A I don't know -- or believe that I was directed to until a

4 little while later.

5 Q Did you take notes on the second from which you relied to write

6 the memo on the 20th?

7 A No.

8 Q So is it fair to say that on the 20th, you were going off of

9 memory and conversation?

10 A Most likely, yes -- well, yes.

11 Q Okay. Just touching on some terms real quick from you. It

12 says in the second paragraph that you sent him a CAD message.

13 What is that?

14 A A computer aided dispatch that means using our MTDs, the mobile

15 data terminal in the car. You send a message like an instant

16 message or a text message or the computer.

17 Q Okay. To your knowledge, are CAD messages retained?

18 A I believe so.

19 Q Okay. And the MDT?

20 A Mm-hm.

21 Q Is that different than a laptop?

22 A No. They're used interchangeably.

23 Q Okay. In the second page, Mr. Murphy, it says, you recall

24 asking you if you were there as his guild witness, and you told

25 him that you were not. You were there as a shift sergeant and



27

1 it would be inappropriate for you to be his guild witness for a

2 number of reasons. Do you see that?

3 A Which?

4 Q The third to the bottom. It starts with Deputy Murphy then

5 asks.

6 A Yes. I do see that.

7 Q I'm curious as to the number of reasons. What would be the

8 number of reasons that it would be inappropriate for you to be

9 his guild witness at that?

10 A That I was on duty, requested to be there as the patrol

11 sergeant. That it wouldn't be appropriate for me to personally

12 represent him, given all of his animosity and false accusations

13 against me.

14 Q And in your opinion, the animosity between the two of you

15 disqualified you from being objective and being his witness

16 type of thing?

17 A No.

18 MR. KAMERRER: Objection, calls for speculation. It's

19 leading. Go ahead.

20 THE WITNESS: No. It didn't disqualify me from being

21 objective. I was the subject of much scrutiny and false

22 accusations from Mr. Murphy. It would only, my belief, lead me

23 into a no win position with Mr. Murphy to try to be his

24 representative. Because he already had claimed that I was --

25 claimed numerous things, but that I was bucking for a promotion



28

1 and I was in cahoots with Sheriff Elfo and his staff, et

2 cetera. So I arranged for someone else to be his guild

3 witness.

4 Q (By Mr. Butler) Any other reasons come to mind as to why it

5 would have been inappropriate for you to have been his guild

6 witness?

7 A Nothing else comes to mind.

8 Q And if I'm reading it correctly, you allowed him to call Deputy

9 Collins and Deputy Collins came out to the site?

10 A I contacted Deputy Collins and handed Mr. Murphy the phone.

11 Q And then Collins came out?

12 A Yes.

13 Q There was disagreement at that meeting regarding the gun and

14 duty belt?

15 A Correct.

16 Q But everything else, Murphy handed over; correct?

17 A Yes.

18 Q And then Chadwick gave him a ride home and agreed, we'll sort

19 out the gun thing another day?

20 A Correct.

21 Q Were you aware on the second that that was going to happen on

22 the second?

23 A Not until Chief Chadwick called me at about, I believe, that it

24 was 7:00 at night. It was before nightshift came in. Yeah.

25 1900 hours, that's when I became aware.



29

1 Q Were you aware that there was investigation ongoing into Murphy

2 and that --

3 A Yes.

4 Q And what were you aware of that?

5 A That there was an investigation into the -- his use of

6 equipment, hard drive, swapping or cloning a hard drive of a

7 computer. That's -- I intentionally distanced myself from it,

8 putting first vice president Steve Roff kind of in charge of

9 that aspect because of the conflict of interest between Mr.

10 Murphy and I.

11 Q Okay. You were aware of deputies modifying county property;

12 correct?

13 A No. You'll have to explain that.

14 Q Well, deputies personalize their weapon?

15 A Within policy, yeah.

16 Q Okay. They do things to personalize their vehicle in a variety

17 of ways; correct?

18 A No.

19 Q You're not aware of any of that?

20 A Not of their vehicles, no.

21 Q Okay.

22 A Maybe minor decor.

23 Q Okay. Going back to the gun thing for a second. Modifying the

24 gun within policy, what are you referring to?

25 A Lights, grips or sights.



30

1 Q And your -- your understanding is that the policy allows them

2 to modify lights, grips or sights?

3 A Correct.

4 Q Are you aware of any other modifications being done to weapons

5 other than lights, grips and sights by deputies since 1999 when

6 you started?

7 A The only other modification that I can think of is a -- is a

8 suppresser authorized by Chief Chadwick for a member of the

9 SRT, that he has a federal tac stand for it.

10 Q Okay.


12 Q (By Mr. Butler) Showing you what's been marked as Exhibit No.

13 4. It appears to be an e-mail from you to Steve Cooley on

14 October 19th, 2011. Do you see that?

15 A I see it.

16 Q And it indicates that there's a -- that there's three

17 attachments. It says, would you agree that, Attached are the

18 e-mails and other documents that I have per the request. (As

19 Read).

20 A I agree that's what it says.

21 Q Do you recall the request?

22 A I can only assume that it was a public disclosure request

23 because that's the subject line. "Murphy Public Disclosure."

24 Q Okay. Was it your understanding that Steve Cooley was in

25 charge of public disclosures?



31

1 A Yes.

2 Q As of October 19th, this was all that you had or why did you

3 get -- do you know why you gave these three items?

4 A I -- my assumption again is that it was a -- he had to do a

5 computer search that, typically with a public disclosure

6 request, we'll be told to do a search of documents containing

7 certain words in the parameters that were provided. And then

8 you save them to an identified folder and then you would

9 forward them onto whomever you were instructed to do.

10 Q Okay. So is that your understanding of what we have here?

11 A That's my best guess, yes, educated guess.

12 Q Okay. Do you know if Whatcom County Sheriff's department

13 maintains a Facebook account?

14 A Yes.

15 Q And have you ever been an administrator on that account?

16 A No.

17 Q Do you know who is?

18 A I am guessing that it is Steve Gatterman, but that's just a

19 guess.

20 Q Have you ever posted anything on the Facebook account?

21 A I don't believe that I have. I've -- I've liked things, pushed

22 the little like button.

23 Q Okay.

24 A I don't recall ever posting anything on there.

25 Q Going back to Exhibit 3, just for purposes of reference. How



32

1 many of those type of meetings have you attended where you have

2 been asked to show up for the suspension of a deputy where they

3 are told to surrender their stuff?

4 A That's the only one.


6 Q (By Mr. Butler) Showing you what's been marked as Exhibit 5,

7 this appears to me to be an e-mail from Elfo to you that got an

8 auto reply from you. Do you recall being out injured in

9 December of 2011?

10 A Yes.

11 Q Okay. The attached is a memo to the personnel file from Elfo

12 describing a meeting that you had had on the 15th. Do you

13 recall receiving this?

14 A Yes.

15 Q Do you recall what specific concerns that Elfo was referring to

16 in getting this to you?

17 A Yes.

18 Q What specific concerns?

19 A I was deputy -- Mr. Murphy's supervisor at the time and we were

20 attempting to correct some compliance issues with regard to

21 policy and what's the field operations, guidelines or

22 expectations. Specifically with completion of paperwork, use

23 of time, communication with supervisors.

24 And the more -- Mr. Murphy became very -- I'm trying to

25 think of the best way to describe it -- difficult and at times



33

1 bizarre with his behavior. The more that we tried to help him

2 understand that, oh, all that I'm asking is for you to do your

3 job, that's all I ask of you to do. That's what I expect of

4 everyone else. No more no less.

5 He would reply with -- he would intentionally -- and he

6 admitted that he was making things very very difficult because

7 he felt that he was being micromanaged. At one point, he

8 pointed to his back and said, there's no saddle on me, you're

9 not going to ride me -- or I don't like being ridden. So it's

10 my belief that those were the types of concerns that were

11 probably being addressed.

12 Q That paragraph ends with performance and credibility. I've

13 heard you talk about paperwork and time and stuff like that.

14 What's -- that would be in the performance category. What were

15 you working with with regards to credibility?

16 A The things that he would say, it would take him, you know, a

17 long time to do the reports or I have got these reports to do.

18 Okay. Well, what are they? Oh, just reports. You need to be

19 specific. Or he would say that he's got lots of follow-up, but

20 then would turn in a report that was very short and very quick

21 to complete. This would not be congruent with all of the

22 follow-up that he indicated that he needed to do, et cetera.

23 Q Anything else?

24 A Nothing comes to mind any way.

25 Q What were you aware of with regards to his time with Dr. Ekemo?



34

1 A I would need to review the memo. I'm not sure.

2 Q Were you aware that he saw Dr. Ekemo?

3 A I am -- Mr. Murphy referred to it as a back door psych eval

4 when he was talking to me one day, that he was sent for a back

5 door psych eval. That's my assumption, that Dr. Ekemo or Ekema

6 is our person who does that. (Sic)

7 Q What's your understanding of what Dr. Ekemo does? He does the

8 psych evals?

9 A He does the psych evals for the department, yeah.

10 Q Fit for duties?

11 A I did not know that he did that, but yes.

12 Q What's your understanding of what a psych eval is if it's not

13 fit for duty?

14 A Well, it's your initial hiring psych eval, yeah. It is -- that

15 is a good way to put it. To see if you are fit for duty. To

16 see if you pass the test.

17 Q When Murphy went to see Ekemo, were you appraised of the

18 outcome of that at the time?

19 A No.

20 Q Prior to receiving this memo on the 15th or 16th of December,

21 do you recall the last time you had heard about Murphy and

22 Ekemo?

23 A No.

24 Q Did you ever review Ekemo's report?

25 A No.



35

1 Q Were you aware of other people in the department that didn't

2 support Elfo in the election in the fall of 2011?

3 A Yes.

4 Q Are you aware of anybody else's credibility that didn't support

5 Elfo being questioned?


7 THE WITNESS: Am I aware of anyone who didn't support

8 Sheriff Elfo, and their credibility being questioned?

9 Q (By Mr. Butler) Yes.

10 A Is that the question?

11 Q Yes.

12 A No.

13 Q In your role as guild president, did you hear complaints about

14 Elfo favoritism in the department?

15 A Yes.

16 Q Did you hear complaints of Elfo favoritism in your capacity as

17 guild president from people that you knew not to have supported

18 Elfo in the election?

19 A Yes.

20 MR. BUTLER: I don't have anything further.

21 MR. KAMERRER: I have a few questions, sergeant.

22

23 EXAMINATION OF KEVIN MEDE BY MR. KAMERRER

24

25 BY MR. KAMERRER:



36

1 Q Exhibit 1 is sent to a number of people who are named on the

2 first page. Are those all of the members of the deputy

3 sheriff's guild at that time?

4 A Yes.

5 Q Okay. The guild ended up voting to endorse a candidate for

6 sheriff in 2011; is that right?

7 A Yes.

8 Q Who did they endorse?

9 A Bill Elfo.

10 Q And what was the breakdown of the vote percentage wise?

11 A I don't recall.

12 Q Do you recall 75 percent of the deputies voted to endorse?

13 A It was a large majority supporting Sheriff Elfo.

14 Q Okay. Have you worked for any other police departments?

15 A No.

16 Q You're familiar with police officers in other departments in

17 the vicinity, aren't you?

18 A Yes.

19 Q Would you say that it's fairly common for police officers at

20 the deputy or officer rank to have complaints about the

21 administration of their department?

22 A Yes.

23 Q Did you ever believe that the complaints that you heard from

24 people in the Whatcom County deputy sheriff's guild were in any

25 way overwhelmingly negative towards Sheriff Elfo?



37

1 A Can you say that again? If --

2 Q Well, did you ever have the feeling that the number or the

3 strength of the complaints about the Sheriff Elfo

4 administration among the Whatcom County deputy sheriffs was in

5 some way overwhelming?

6 A Only from one person.

7 Q And who is that?

8 A Steve Harris.

9 Q Okay. Steve Harris is the fellow who ran against Sheriff Elfo?

10 A Yes.

11 Q Do you recall what the breakdown on the vote was among the

12 electorates in Whatcom County between Sheriff Elfo and Steve

13 Harris?

14 A I believe that it was also overwhelming. I want to say that

15 that was 76 percent.

16 Q A landslide?

17 A Yes.

18 Q The e-mail from you to Inspector Cooley and -- was it

19 Lieutenant Chadwick?

20 A I believe so. Is this exhibit --

21 Q Exhibit 2.

22 A Exhibits 2.

23 Q Is that something you voluntarily initiated to them?

24 A Yes. I was irritated that in my professional capacity, he was

25 accusing me of -- Mr. Murphy was accusing me of inappropriate



38

1 conduct or unethical violations.

2 Q Were you his supervisor at that time?

3 A Yes.

4 Q So you were concerned that the criticisms that he was making of

5 you could have violated department policy?

6 MR. BUTLER: Object to the form.

7 Q (By Mr. Kamerrer) Is that right?

8 A Correct.

9 Q You weren't sending that e-mail to Cooley and Chadwick as a

10 political statement, were you?

11 A No.

12 Q Regarding gun ownership, were you familiar with the sheriff's

13 office or the county's buyback of deputies' duty firearms that

14 was negotiated by the guild some time in the past?

15 A Yes.

16 Q Did that afford deputies the opportunity to be repaid for the

17 duty firearm that they had originally chosen and paid for

18 themselves?

19 A Yes.

20 Q Did you take advantage of that?

21 A I did not.

22 Q Okay. Do you know -- do you have any idea what percentage of

23 deputies did take advantage of that?

24 A No.

25 Q Okay. When you were with Rossmiller and Murphy was told to



39

1 turn over his duty firearm on March 2, 2012, did you hear that

2 conversation?

3 A Yes.

4 Q Did you accurately report that conversation in the exhibit that

5 is Exhibit 3 -- or it's part of Exhibit 3?

6 A Yes.

7 Q Okay. Did you see the receipt that Rossmiller showed Murphy to

8 explain why he needed to turn in his firearm?

9 A I did not.

10 Q Okay. So you didn't recognize it as the typical form that a

11 deputy would fill out if he or she wanted to have his gun

12 bought back?

13 A I did see that it was an evidence and equipment issue receipt,

14 but I did not read the writing on it.

15 Q Okay. Did you see Murphy's signature on it?

16 A I saw a signature on it. I didn't examine it closely.

17 Q Okay. What did Mr. Murphy say, if anything, about the

18 authenticity or correctness of that receipt?

19 A I recall -- I need to -- without looking at my memo, I recall

20 him saying that is my signature, but I don't recall signing it

21 or filling it out. I can refer to my --

22 Q Yeah. Feel free.

23 A Yeah. Maybe I didn't put that in. I don't see that in my

24 memo, but I independently recall that.

25 Q Okay. I want to have you turn to Exhibit 4, and this is kind



40

1 of a housekeeping matter. But on the third page in, I'm going

2 to direct your attention to a particular sentence that actually

3 is a particular word that I just want to clarify. This memo

4 that was prepared by you and directed to Deputy Murphy, was

5 that done as the result of an investigation that Murphy

6 apparently had done, but not reported?

7 A Yes.

8 Q Okay. I want to draw your attention to the third paragraph of

9 Exhibit 4. It's the second to the last sentence where -- and

10 I'll quote it. "It was then discovered that no report

11 documenting our activities had been filed."

12 Should that our be your?

13 A Either or our representing the sheriff's office -- his

14 representing the sheriff's office or your, it could be. I

15 believe that I had meant it as our because the BP security

16 staff was upset that the sheriff's office was doing nothing.

17 Q Okay.

18 A And the sheriff's office being Deputy Murphy in his capacity.

19 Q Was it Murphy who had undertaken that investigation?

20 A Yes.

21 Q Had you been aware of it being conducted near in time to when

22 it was occurring?

23 A At the end of the night, he called me and said something to the

24 effect of, I found some trails, talked to security, and briefed

25 me on it. I said okay, great. The assumption being that he



41

1 would actually document it like most, would be expected.

2 Q So you anticipated that after your verbal conversation with him

3 about the investigation, he would follow up with a report?

4 A Yes.

5 Q Did he follow-up with a report?

6 A No.

7 Q That's why this memo was prepared documenting the counseling

8 with him about that?

9 A Yes.

10 Q Okay. Did you ever learn or determine that the -- BP officials

11 were upset about what Deputy Murphy had done relative to that

12 investigation?

13 A Yes.

14 Q And explain that, please?

15 A I received a call. I don't recall if it was Lieutenant Cooley

16 at the time. I received a call from the staff asking about

17 this investigation on the refinery, because apparently the BP

18 staff had called either the sheriff or undersheriff and asked

19 what was going on.

20 They received word from their security people that the

21 sheriff's office was conducting an investigation on suspicious

22 activity, but they never notified. And when our senior staff

23 went to look for the report, it wasn't located, so that's how I

24 got it.

25 Q Exhibit 5, I'm going to draw your attention to the last



42

1 paragraph on the first page. I'll read that and then I'll ask

2 you a question about it. This memo is from Sheriff Elfo. It

3 says, "I further reminded Deputy Murphy that I had arranged a

4 training session with Dr. Ekemo following my receipt of the

5 concerns from the Guild President about his previous bizarre

6 statements and that Dr. Ekemo had cautioned him about damaging

7 his reputation and the reputation of the Sheriff's Office by

8 making such statements."

9 Were you the guild president who had expressed concerns

10 about Murphy's previous bizarre statements?

11 A No.

12 Q Did you know about that expression of concern by the guild

13 president back in 2008?

14 A Yes, I was.

15 Q Who was the guild president at that time?

16 A Steve Harris.

17 Q During the time that you worked with Deputy Murphy, including

18 the time when you were a supervisor of his, did you develop

19 concerns about his mental stability?

20 A Yes, I did.

21 Q What were those concerns based on?

22 A Based on his bizarre behavior and his eccentric views on

23 nominal occurrences. I can give you an example.

24 Q Please do.

25 A Mr. Murphy was dispatched to a found bicycle in Birch Bay,



43

1 something we go to quite often. I don't recall the date, but

2 it was during the summertime. I lost track of time. I looked

3 at the screen and he had been up there for a significant period

4 of time, almost an hour, which is a -- quite a long period of

5 time to retrieve a bicycle.

6 I called Mr. Murphy and asked him what was taking so

7 long. He said that he was surveilling the bicycle because it

8 was red and white. I asked him what that meant and he said,

9 clearly, it was a sign for the Hells Angels for a drop spot or

10 a pick-up point, and that he was going to sit on it a little

11 bit longer to see if any Hells Angels showed up.

12 I instructed him to retrieve the bicycle and immediately

13 take it into the shop to be booked into evidence because that

14 was not a good use of our resources.

15 Q Is the use of red and white bicycles a known marker of some

16 sort for the Hells Angels?

17 A Not that I have ever heard of, no.

18 Q Did Mr. Murphy ever explain why he thought that that was true?

19 A Because he -- he did. He would profer opinions about the Hells

20 Angels and their proliferation within Whatcom County numerous,

21 numerous times.

22 And that they would use -- if there was a red and white

23 truck -- anything red and white -- a red and white mailbox,

24 that that was a sign that those individuals supported the Hells

25 Angels and that we needed to watch out for them, pay attention.



44

1 Q Is that something that is known among law enforcement officers,

2 that those colors are significant to the Hells Angels?

3 A Those red and white colors are the colors used by the Hells

4 Angels, but not used to mark suspicious or clandestine devices.

5 Q You've given one example. Are you aware of other examples of

6 conduct or expressions by Mr. Murphy that caused you to

7 question his mental stability?

8 A Yes.

9 Q Are you aware that he has said that there were black

10 helicopters following him?

11 A Yes.

12 Q Are you aware that he believed that people were trying to

13 tamper with his computer?

14 A No.

15 Q Do you have other examples of situations that he described that

16 you thought were evidence of mental instability?

17 A Yes.

18 Q Can you explain those?

19 A When the sheriff's office initiated the Special Response Team

20 in 2005, a sniper class was put on and members from the Quebec

21 federal -- what would be their federal police. I think that

22 it's -- I'll pronounce it wrong -- but Surete du Quebec

23 attended. As a gesture, they gave some of our members a hat or

24 t-shirt.

25 When Mr. Murphy saw that, he saw that name, Surete du



45

1 Quebec, and he was very concerned because members of that

2 agency -- he described a shootout that occurred with Native

3 Americans years ago, and that members of the agency swore to

4 eradicate the planet of that tribe. And that those members

5 certainly weren't here for a sniper class. They were here to

6 check on Mr. Murphy and his status of -- as a tribal member.

7 Q Okay. Did you have any evidence -- were you aware of any

8 evidence that indicated that Mr. Murphy's suspicions were true?

9 A No.

10 Q Were you aware that he had feelings that there was a volunteer

11 in the sheriff's office who was somehow aligned with the

12 Israeli intelligence organization called Mossad?

13 A Yes.

14 Q Did you hear about that from Murphy himself?

15 A No.

16 Q How about a receptionist or another staff person in the

17 sheriff's office who Mr. Murphy believed was associated with

18 Outlaw motorcycle gangs?

19 A Yes. Penny -- I can't remember her last name. He believed

20 that she was providing information to the Outlaw motorcycle

21 gangs, which is why they were so difficult to catch. He also

22 told me personally that members of the prosecuting attorney's

23 office were in cahoots with Outlaw motorcycle gangs, which is

24 why cases often don't get prosecuted because of deals happening

25 behind closed doors.



46

1 Mr. Murphy, also as another example, also told me that

2 the reason that no one was stealing the bait car that we had as

3 a bait car program was because -- NICB -- I believe that those

4 are the acronyms -- was also in cahoots with organized theft

5 rings and would identify for these organized theft rings which

6 cars were bait cars and that's why they wouldn't get stolen.

7 Q Based on those last three incidents, the employee Penny, the

8 prosecutor and Outlaw motorcycle gangs and the bait car, did

9 you ever discover or learn of any factual evidence indicating

10 that those theories of Mr. Murphy were correct?

11 A No.

12 Q Did you ever hear him indicate that he suspected county

13 officers of purchasing property on Lake Whatcom so that drug

14 drops could be arranged there?

15 A Yes. South Lake Whatcom.

16 Q And what did you hear about that?

17 A He would be very vague often in his theories, but he would

18 refer -- he would just say -- he would refer to it as the

19 county. The county, you know, there's big business, there's

20 big money in these type of things. That's why the county will

21 look to purchase this. I mean, it's a remote area for drug

22 drops and they all know that. That type of thing. He would

23 often not name a specific person.

24 Q Did you ever learn of any factual information indicating that

25 that theory of Murphy's was true?



47

1 A No.

2 Q Okay.

3 MR. KAMERRER: That's all of the questions that I

4 have. Thank you.

5 MR. BUTLER: Let me just follow-up on a couple.

6

7 EXAMINATION OF KEVIN MEDE BY MR. BUTLER

8

9 BY MR. BUTLER:

10 Q The bike in Birch Bay was when?

11 A Years ago. It was probably -- I was a supervisor, so it was

12 probably 2008 or nine.

13 Q Are you aware that he was tribal member of the -- I don't know

14 how to pronounce it either -- from the Quebec police shootout?

15 A I believe that he said that. I wasn't aware of that before

16 then.

17 Q Okay.

18 A I knew that he was part Native American, but I didn't know what

19 tribe or anything like that.

20 Q Okay. Prior to the deposition, did you do anything to prepare

21 for today's dep?

22 A (Witness Indicating).

23 Q Did you do anything to prepare for the deposition?

24 A I --

25 Q Review documents, meet with people, have discussions?



48

1 A No. I had the meeting with Prosecutor Gallery two weeks ago, a

2 week ago.

3 Q Any other meetings or conversations?

4 A No.

5 Q Anything that I didn't ask you that you expected, based on your

6 preparation that you would be asked to discuss today?

7 MR. KAMERRER: I'll insert an objection. It calls for

8 speculation. It's argumentive. Nevertheless, you can answer

9 the question.

10 THE WITNESS: No.

11 Q (By Mr. Butler) With regard to Penny Goodman, you were aware

12 that he was assigned to do that investigation; right?

13 A No.

14 Q You weren't aware of that?

15 A No. I was not.

16 Q Okay. Would it change your opinion if he was assigned and

17 actually conducted an investigation as to whether or not it was

18 a bizarre theory of his?

19 MR. KAMERRER: I want to insert an objection. It

20 calls for speculation.

21 MR. BUTLER: I don't think it calls for speculation.

22 MR. KAMERRER: It's extremely vague. You haven't even

23 identified the subject of that investigation.

24 Q (By Mr. Butler) Did you understand I was talking about the

25 Penny Goodman investigation?



49

1 A Yes.

2 Q Okay. Would it change your opinion that it was bizarre if you

3 learned that it was assigned and he was doing what he was

4 assigned to do?

5 MR. KAMERRER: Objection, argumentative.

6 THE WITNESS: It's a more complicated answer than yes

7 or no.

8 Q (By Mr. Butler) Okay.

9 A I can answer it.

10 Q Go ahead.

11 A If Mr. Murphy offered up information that he believed to be

12 true and presented it and the staff said, whoa, we should look

13 into this, go ahead and run with it, then I would say yes.

14 That it's bizarre still. But if it was something that came

15 down from somebody who, I believe, had more of a credible

16 foundation, then it wouldn't be. Does that make sense?

17 Q Yup.

18 A Okay.

19 Q Penny Goodman still work for the sheriff's department?

20 A I don't know. Not for the headquarters, I mean.

21 Q She was a receptionist -- is she still a receptionist down

22 there?

23 A Not here, no. I don't know if she went to alternative

24 corrections or anything like that.

25 MR. BUTLER: Okay.



50

1 (Signature Reserved)

2 (Deposition Adjourned)

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51

1 C E R T I F I C A T E

2 STATE OF WASHINGTON ) ) ss.

3 COUNTY OF ISLAND )

4 I, Kristen M. Uhlig, the undersigned CCR in and for the Stateof Washington, do hereby certify:

5 That the annexed and foregoing deposition of the witness

6 named herein was taken stenographically before me and transcribedby me;

7 I further certify that the witness examined, read, and signed

8 the deposition after the same was transcribed, unless indicated inthe record that the parties and the witness waive the signature;

9 I further certify that all of the objections made at the time

10 of said examination to my qualifications or the manner of takingthe deposition, or to the conduct of any party, have been noted by

11 me upon said deposition;

12 I further certify that I am not a relative or employee orattorney or counsel of any of the parties to said action or

13 counsel, and that I am not financially interested in the saidaction or the outcome thereof;

14 I further certify that the deposition, as transcribed, is a

15 full, true, and accurate transcript of the testimony, including allquestions and answers, and all objections, motions and exceptions

16 of counsel made and taken at the time of the foregoing examination;

17 I further certify that I am sealing the deposition in anenvelope with the title to the above cause thereon and marked

18 "Deposition Upon Oral Examination" of said witness and promptlycausing the same to be delivered or forwarded to Counsel for the

19 Opposing Party;

20 IN WITNESS THEREOF, I have hereunto set my hand and affixedmy official seal this ___ day of____________, 2014.

21

22 __________________________

23 Kristen M. Uhlig, #1934 Certified Court Reporter,

24 Residing in Clinton, Washington.

25





Aability 5:18accepted 13:21account 31:13,15

31:20accurate 51:15accurately 39:4accusations 27:12

27:22accusing 37:25,25acronyms 46:4acting 25:18,19action 51:12,13activities 40:11activity 9:17 41:22actual 18:23ad 16:5adamant 11:12addressed 33:11Adjourned 50:2administration

13:14 17:12 36:2137:4

administrator31:15

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19:23,24 24:10,1130:11,12 32:5,651:17

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memory 26:9mental 42:19 44:7

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16:13 17:2 22:1926:20

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12:7 23:12morning 4:8Mossad 45:12motions 51:15motive 17:14motorcycle 45:18

45:20,23 46:8Moving 9:10 10:20MTDs 26:14multiple 18:13

19:25Murphy 1:10 3:11

3:13 4:15 6:5 21:522:16 23:14 24:525:19,21,24 26:2327:4,22,23 28:1028:16 29:1,1030:23 32:24 34:334:17,21 37:2538:25 39:7,1740:4,5,18,1941:11 42:3,17,2543:6,18 44:6,2545:6,14,17 46:146:10 49:11

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22:14 44:25 45:19

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observations 25:7obtain 6:2occurred 45:2occurrences 42:23occurring 40:22October 20:6 30:14

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5:11 6:8,13 11:2412:1 25:2 38:1340:13,14,16,1841:21 42:7 44:1945:11,17,23

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23:18,18 33:2,18okay 4:14,20 5:6

6:5,9,16 7:5 9:39:16 10:17,2011:17,20,22 12:1112:24 13:7,2314:14,18,22 15:715:23 16:7 17:2318:3,18 19:1,6,819:15,22 20:10,1520:19,22 21:11,1821:22 22:13,2024:7 25:2,2,1226:1,11,17,19,2329:11,16,21,2330:10,24 31:10,1231:23 32:11 33:1836:5,14 37:938:22,25 39:7,1039:15,17,25 40:840:17,25 41:1045:7 47:2,17,2048:16 49:2,8,18



49:25on-the-job 8:24ongoing 29:1operating 21:8operations 32:21opinion 7:18,19

9:12 17:9,20,2127:14 48:16 49:2

opinions 43:19opportunity 38:16opposed 7:15Opposing 51:19Oral 1:17 51:18organization 45:12organized 46:4,5originally 38:17outcome 34:18

51:13Outlaw 45:18,20,23

46:8oversees 13:6overwhelming 37:5

37:14overwhelmingly

36:25ownership 38:12

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pages 21:22,23 22:224:24

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sgt. kevin mede, wcso - deposition (federal) - full transcript

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