2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 1 of 15 Pg ID 174

Exhibit 2
2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 2 of 15 Pg ID 175

CRAWFORD, ET AL. v. MCCABE, ET AL.

JAN CRAWFORD

March 29, 2017

Preparedfor you by

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Ann Arbor Detroit Flint Jackson Lansing Mt. Clemens Saginaw Troy
2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 3 of 15 Pg ID 176

JAN CRAWFORD
March 29, 2017

Page 1 Page 3

1 UNITED STATES DISTRICT COURT 1 TABLE OF CONTENTS

2 EASTERN DISTRICT OF MICHIGAN 2
3 SOUTHERN DIVISION 3 WITNESS PAGE
4 4 JAN CRAWFORD
5 JAN CRAWFORD and 5
6 MICHELLE JAEGER, 6 EXAMINATION
7 Plaintiffs, 7 BY MR. VINSON: 5
8 vs. Case No. 16-13263 8
9 Hon. Robert H. Cleland 9 EXHIBITS
10 RYAN McCABE AND JOHN 10
11 DOE OFFICERS 1-3, in their 11 EXHIBIT PAGE
12 individual capacities, 12 (Exhibits not offered.)
13 Defendants. 13
14 / 14
15 15
16 16
17 The Deposition of JAN CRAWFORD, 17
18 Taken at 28588 Northwestern Highway, Suite 100, 18
19 Southfield, Michigan, 19
20 Commencing at 10:10 a.m., 20
21 Wednesday, March 29, 2017, 21
22 Before Alan Stalburg, CER-9106. 22
23 23
24 24
25 25

Page 2 Page 4
1 APPEARANCES: i Southfield, Michigan
2 2 Wednesday, March 29, 2017
3 ROBERT M. GIROUX, JR. 3 10:10 a.m.
4 Giroux Ratton, P.C. A

5 28588 Northwestern Highway 5 JAN CRAWFORD,

6 Suite 100 6 was thereupon called as a witness herein, and after
7 Southfield, Michigan 48034 7 having first been duly sworn to testify to the truth,
8 (248) 531-8665 8 the whole truth and nothing but the truth, was
9 [email protected] 9 examined and testified as follows:
10 Appearing on behalf of the Plaintiffs. 10 MR. VINSON: Let the record reflect this is
11 11 the deposition of Jan Crawfordconducted pursuant to
12 ETHAN VINSON 12 notice and to be used for all purposes allowed by the
13 Cummings, McClorey, Davis 8: Acho, P.L.C. 13 Federal Rules of Civil Procedure.
14 33900 Schoolcraft Road 14 Ms. Crawford, I introduced myself to you
15 Livonia, Michigan 48150 15 earlier.
16 (734) 261-2400 16 THE WITNESS: You did.
17 [email protected] 17 MR. VINSON: I'm Ethan Vinson. I represent
18 Appearing on behalf of the Defendant, Ryan McCabe. 18 Officer Ryan McCabe in this lawsuit that you and Ms.
19 19 Jaeger have filed, and to that extent my purpose here
20 ALSO PRESENT: 20 today is to ask you questions about the incident that
21 Michelle Jaeger 21 led to the lawsuit. Have you ever given a deposition
22 22 before?
23 23 THE WITNESS: No.
24 24 MR. VINSON: Okay. I will be asking you a
25 25 series of questions, you have to give a verbal

Pages 1 to 4

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2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 4 of 15 Pg ID 177

JAN CRAWFORD
March 29, 2017

Page 5 Page 7

1 response. We have a court reporter who's taking down Yep. Kimberly Steadman, Kimberly K. Steadman. She
2 everything thafs being said, thafs why ifs was bom in '75, July 16th, 1975.
3 important to give a verbal response. 15th or 16th?

4 THE WITNESS: Okay. July 16th.

5 MR. VINSON: And if at any time you do not 1975?

6 understand a question, just say so, I'll either Yes. Then Sally Anne Steadman, she's June 13th,
7 rephrase it or repeat it. That's important because 1970 - no, June 14th, sorry, 1977. Yeah, 1977,
8 once you answer it's assumed you understood the correct

9 question. Is that fair enough? 9 Q- And where do you currently reside?

10 THE WITNESS: Fair enough. 10 A. At 1530 Dorothea, D-o-r-o-t-h-e-a, Berkley, Michigan
11 MR. VINSON: If you need to take a break at 11 48072.

12 any time, hopefully we won't be here that long, just 12 Q Okay. Is that a single-family home?
13 say so and we can do that. 13 A. It is.

14 THE WITNESS: Okay. 14 Q And who do you live there with?

15 EXAMINATION 15 A. My mother, my children.
16 BY MR. VINSON: i6 Q Your mother is Eileen, correct?
17 Q. Would you state your full name once again for the 17 A Eileen, children, my boyfriend.
18 record? 18 Q Okay. May I have the -
19 A. Jan Linette Crawford. 19 A. And a family a little family that I'm taking a
20 Q. Spell Linette? 20 homeless family that we are taking care of, and it's a
21 A. L-i-n-e-t-t-e. 21 28-year-old woman and her five children, her babies.
22 Q. And your date of birth? 22 Q It must be a big house?
23 A. October 1st, 1969. 23 A. It's not. It's a busy life. They're all special
24 Q. And where were you bom? 24 needs so it's a crazy life.
25 A. Beaumont Hospital, Royal Oak, Michigan. Wow, that's very commendable.

Page 6 Page 8
Q. The name of your parents? You wouldn't say no, nobody would.
A. My father's name is Basil, B-a-s-i-l, Ernest Perrich, May I have the names and ages of your children?
3 P-e-r-r-i-c-h. My mother's name is Eileen, Yeah. My oldest one is at college. She's at Western.
4 E-i-l-e-e-n, Helen maiden name or married name? Her name is Falyn Johnson.
5 Q. What name does she use now? Western Michigan?
6 A. Steadman, her married name. Yep.
7 Q. Steadman? That's where I -
8 A. S-t-e-a-d-m-a-n. Full ride.
9 Q. So I take it your mother and father are not married? 9 Thafs where I graduatedfromyears ago.
10 A. They were, then she was remarried and then -- they 10 My mom too and my sister. F-a-l-y-n.
11 were divorced, and he's deceased. My father, Basil, 11 Falyn?
12 has passed. 12 Uh-huh.
13 Q. Do you have any siblings? 13 All right.
14 A. I do. 14 KayJohnson, K-a-y,and her date of birth is February
Q. And their names and ages? 15 21st, 1998.
16 A. Shannon Elise McLaughlin, M-c-L-a-u-g-h-l-i-n. Want a 16 Okay.
17 date of birth? 17 Then Tristan, T-r-i-s-t-a-n, Christopher Crawford.
18 Q. And how old is she? 18 Spell Tristan again?
19- A. She's two years younger than me, she's June 26,1967. 19 T-r-i-s-t-a-n.
20 MR. GIROUX: Two years younger than you or 20 A-n?
21 two years older? Yeah. Christopher Crawford. Thafs his middle name,
THEWrTNESS: Sorry, older than me. Sorry, Christopher, last name Crawford. He's August 11th,
23 two years older than me, yeah. 23 2002.
24 BY MR. VINSON: 24 Okay.
25 Q. And any other siblings? 25 Then Merrin, M-e-r-r-i-n, Elise Crawford, so E is the

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2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 5 of 15 Pg ID 178

JAN CRAWFORD
March 29, 2017

Page 9 Page 11
1 middle initial, Crawford. Elise is E-l-i-s-e, 1 Q. And did you say your boyfriend lives with you?
2 Crawford. -
A. Yeah, he just moved in with us. He's Enthe basement
3 Q. E-l-i-s-e, Elise? 3 with me.
4 A. Crawford, yep. Her birthday is October wait, 4 Q. And his name?
5 October 11th, yeah, 2003. 5 A. Christopher Matrjce.
6 Q. Okay. 6 Q. Mattice?
7 A. Then comes Rowen, R-o-w-e-n, Skye, S-k-y-e, Crawford, 7 A. MatrJce, M-a-t-t-i-c-e.
8 and she was born on December 15th, 2004. 8 Q. Oh, he was the passenger in the car --
9 Q. Is that it on the children? 9 A. Absolutely.
10 A. Yeah, that's it for mine. I have a stepdaughter, she 10 Q- - that night?
11 does not reside with me. 11 A. Yep.
12 Q. Are you married? 12 Q- And speaking of him, you said he just moved in?
13 A. I am married but I've been separated for five or six *-2 A. Uh-huh.

14 years, he lives in Florida. His name is Jeffery 14 Q. What happened to the criminal case against him?
15 Robert Crawford. April 29th, 1973. 15 A. He went to jail.
16 Q. What part of Florida does he live in? 16 Q. Did he?
17 A. Cape Coral. 17 A. Yep.
18 Q. Cape Coral? 18 Q- And he's out now?
19 A. Yep, Cape Coral. 19 A. Yep, served his time and he's out
20 Q. And where is that at? 20 Q. Oh, that's right, this happened a long time ago,
21 A. Right by Fort Myers. 21 didnt it?

22 Q. And where's Fort Myers? 22 A. Yeah.

23 A. Oh, in southwest Florida. 23 Q. Allright. I'm thinking it just happened in --

24 Q. Southwest, okay. 24 A. Served his time, went to the rehab, he's doing
n c
25 A. Ifs nice and warm. amazing.

Page 10 Page 12
1 Q. And then you indicated you have a - i Q. All right, Christopher. Then you said there's a
2 A. A stepdaughter. -
homeless family?
3 Q. But she doesn't live with you but - 3 A. Yeah, that was Meaghan. Her name was Meaghan, that
4 A. Oh, oh, oh, my new roommate, yes 4 was the name I gave you.
5 Q. The roommate. 5 Q. Oh, thafs Meaghan?
6 A. - our little family that we're taking care of? 6 A. Yes.
7 Yes, Meaghan lives with me, and her last 7 Q- Oh, and thafs the five children?
8 name is Ried, R-i-e-d, Meaghan Claire Ried. 8 A. Yeah, and the five children.
9 Q. R-e-e-d? 9 Q. Gotcha, all right. Who owns the house?
10 A. R-i-e-d. 10 A. My mother.
11 Q. R-i-e-d? 11 Q- Your mother, okay.
12 A. Uh-ftuh. She's 28. I'm sorry. 12 A. It was her campaign manager's daughter, so it's her.
13 Q. And you said 13 Ifs not my thing. Oh, I'm sorry.
14 A. And her children, yep, she has five children, and 14
Q- Allright And you said your mother's campaign
i 5
they're all under seven. 15 manager's?
16 Q. How many bedrooms is that house? 16 A. Yeah, she knew her 20 years ago and so she just took
17 A. Well, I take up the basement and my children take up 17 care of her daughter.
18 the upstairs and she and her kids have bedrooms on the 18 Q. What - did your mother hold a political office?
19 main floor, and my mom and them are on the main floor. 19 A. Yeah.
20 It's not a big house, ifs a 15 square foot --1,500 20 Q. And what office is that?
21 square foot bungalow. 21 A. City coundlwoman in Berkley.
Q- And how long has she held that position?
o~<
22 Q. Wow.
23 A. It just has to have it's major structure, I mean, I 23 A. 19 years, or 18, I'm not exactly sure.
24 have to have everything on a time schedule. We get up 24 Q. Your mother is Eileen Steadman, correct?
25 at 5:30. 25 A. Uh-huh.

Pages 9 to 12
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2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 6 of 15 Pg ID 179

JAN CRAWFORD
March 29, 2017

Page 13 Page 15
1 Q- Okay. Are you employed? l Q. And then you retired?
1 2 A. Yep. I was given an offer to retirement buyout and
A. No.
3
3 Q- Have you ever been employed? then I--

4 A. Yes. 4 Q. An early buyout?

5 Q. Let me back up. Where did you go to high school? 5 A. Uh-huh.

6 A. Berkley High School. 6 Q. Oh, you have to say yes.

7
Q. When - did you graduate? 7 A. Yes.

e A. 1987. Did you say when or did? Oh, sorry. 8 Q. So what is your source of income now, if any?
9 1987. And what did you do after graduating? 9 A. Yeah, right now with the kids food stamps and my mom,
Q.
10 A. I went to college. 10 and I just got done getting, what do you call ft,
11 Q. Where did you go? 11 child support Ifs in force but they're having a
12 A. O.C.C. 12 hard time with that getting it to me from him.
13 Q. How long did you go there? 13 Q. From --
14 A. It took me a bit I did my L.P.N. first and then I 14 A. Their father.

15 finished my R.N. in 1995. 15 Q. - the husband - former husband down in Florida?

16 MR. GIROUX: He~ 16 A. Yeah, right uh-huh.
17 A. Oh, sorry, how long did I go there? About six years. 17 Q. You were married here in Michigan; is -
16 Six, yeah, off and on. ie A. I was.

19 BY MR. VINSON: 19 Q. - that correct?

20 Q- Okay. But you obtained an R.N.? 20 Okay. Any other marriages or is that it?
21 A. Uh-huh. 21 A. No.

22 Q. And are you currently - what's the correct term -- 22 Q. Have you ever been known by any other name?
23 certified or practicing, or what? 23 A. Yes.
24 A. I am not I am not. I'm a stay-at-home mom. 24 Q. And whafs that?
25 Q. Okay. Did you work as an R.N.? 25 A. Jan, J-a-n, Linette Perrich, P-e-r-r-i-c-h. Then I

Page 14 Page 16
1 A. Yes. 1 had a legal name change and I became Jan Steadman.
o
Q. For how long and where? -
Q. Okay. Perrich was your father's name?
3 A. My first job was at Beaumont and I worked there 3 A. Right so my birth name was Perrich then when I was
4 from - till 2010 from 19,1 think 96 - 1986 to 2010. 4 about I'd probably say six, somewhere in the range of
5 Q. Okay. So you were working there as a -- 5 five or six, my parents, my mother and stepdaughter ~
6 A. I retired from there. 6 I mean stepfather, changed my name to Steadman,
7
7
Q- When you started working there -- S-t-e-a-d-m-a-n. And then my married name.
8 A. I was En high school, a senior. 8 Q. Beaumont Hospital, is that the only job you ever had?
9 Q. And in what capacity - 9 A. No, then I moved to Florida. I also have let me
10 A. I was a co-op. 10 backtrack. I also worked agency and so I would
11 Q. Oh, a co-op? 11 moonlight at other hospitals during my career at
12 A. Nursing assistant and co-op, uh-huh. 12 Beaumont so I worked at ~ through the DMCs, some St
13 Q. Then I think you said you got your L.P.N.? 13 John's, I worked at numerous hospitals.
14 A. Yep. 14 Q. What agency was that?
15 Q. And you continued working there? 15 A. ProCare One.

16 A. Uh-huh. Never worked in that capacity. I'm sorry. 16 Q. Where is that located?
17 Q- Oh, you didn't? 17 A. I don't I'm not certain if it is even there
16 A. I mean, yeah. I mean, I didn't use it because I went ie anymore, but it was in Southfield.
19 into the R.N. program. It was a bridge. 19 Q. Okay. And other empbyment? We got Beaumont?
20 Q. And you obtained your R.N. in 1995? 20 A. Yeah.
21 A. Uh-huh. 21 Q. ProCare One?
">?
Q. And worked there as an R.N.? 22 A. ProCare One, and then I moved to Florida and I worked
23 A. Yeah. 23 for Gulf Coast Medical Center, thafs another hospital
24 Q. From '95 until when? 24 in Florida.
25 A. 2010. 25 Q. Where in Florida?

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2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 7 of 15 Pg ID 180

JAN CRAWFORD
March 29, 2017

Page 17 Page 19

1 A. Fort Myers. 1 Q. Sunday night, early Monday morning7

2 Q. What years were you there? -

A. Uh-huh.

3 A. 2010 to 2012,1 believe. 3 Q. And tell me about -- what had you been doing that
4
Q. Were you still with your husband then' 4 Sunday afternoon?

5 A. Sort of, it was like the beginning of his end. 5 A. We were at a barbecue at my boyfriend's brother's

6 Q. Okay. That's Gulf Care Hospital? 6 house.

7 A. Gulf Coast. 7 Q. And that's Christopher Mattice's brother7

-

Q. Gulf Coast? -
A. Uh-huh.

9 A. Yeah. 9 Q. What's his name?

10 Q. Hospital? :: A. Matthew.

.: A. Yeah. Well, they call it Medical Center, but it is a Q. And where does he live?
12 hospital, Gulf Coast Medical Center. 12 A. I have no idea anymore, I mean, I don't currently know

Q. And that was 2010 - 2010 to 2012? 13 right now, but at the time he was living in Detroit.
A. Yep. :; Q. Do you know where in Detroit?
:: Q. And then after 2012 you came back to Michigan? 15 A. On a street called Greenley. I do not recall the
16 A. Uh-huh. 1 address.

17 Q- And did you work anywhere after - : Q. A street called what7

18 A. No. 18 A. Greenley.
19 Q. upon your return? : Q. Greenley or Greeley, G-r-e-e-l-y (sic)7
20 A. No. :;. A. It could be Greeley or it could be Greenley. I just
21 Q. When you were in Florida you had all your children :: always thought it was Greenley. At first I thought it
22 with you down there too? 22 was Green Leaf, so I can never remember the name of
23 A. Yeah. 23 it, but I think it was Greenley or Greeley.
24 Q. Have you ever been convicted of any crime? :; Q. And what time did you go over to -- his name is Matt7
25 A. Yeah, I got a DUI, a misdemeanor I think that is, or 25 A. Matt.

Page 18 Page 20
1 whatever it was. 1 Q. What time did you go over there?
2 Q. When was that? 2 A. Early afternoon.
3 A. 1999. 3 Q. How'd you get there?
4 Q. And where was that7 4 A. My friend Michelle picked us up and we drove in her
0 A. In Royal Oak, Michigan. z> Tahoe, in her car.
6 Q. Anything else? 6 Q. And you said she picked you up, who is we?
7 A. (Shaking head negatively.) 7 A. My boyfriend and I.
8 Q. Ever been involved in any other litigations, lawsuits? Q. And where did she pick you up from7
9 A. No. 9 A. From his house at the time.

10 Q. Ever filed a workers' comp claim? 10 Q. And where was he living7

11 A. No. Oh, yes. Yes, I did in at Beaumont Hospital 11 A. In Warren.

12 in it was somewhere around in the late '90s. It :: Q. Okay. So you were in Warren7
12 was --1 can tell you where I was living at the time. 13 A. Uh-huh.

1'-. I was off work for three weeks for a back injury. 14 Q. And Michelle picked you up?
Q- Just three weeks and then back to work? 15 A. Yep.
16 A. Yeah, but they paid me for that time. 16 Q. Around what time7
17
Q. This incident occurred on June the 6th, 20 -- oh, it 17 A. I don't remember exactly. It was sometime in the
1" was this year, 2016, last year. Is that about right? 18 afternoon, in the ea rly afternoon, maybe around 12:00.
19 MR. GIROUX: Where's the report? 19 Maybe earlier, I don't remember the exact time.
20 A. On or about that time. 20 Q. And you went down to Matt's --
MR. GIROUX: The report says 6/6/2016. . : A. Yep.
2-2 MR. VINSON: Okay. 22 Q. -- house?
23 BY MR, VINSON: 23 A. Uh-huh.
24 Q. What day of the week was that, if you recall? 24 Q. For a cookout, a barbecue7
A. A Sunday night. 25 A. Yeah, a cookout.

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2:16-cv-13263-RHC-DRG Doc # 17-3 Filed 05/24/17 Pg 8 of 15 Pg ID 181

JAN CRAWFORD
March 29, 2017

Page 21 Page 23
1 Q. What did he cook? Q. No idea where it came from?
2 A. What did we cook? We had hamburgers and then we had A. I can surmise, I mean, but I don't know exactly. I'm
3 hot dogs. We had a whole bunch of stuff, it was a 3 assuming that maybe Chris set it down. We were
4 bunch of people there. 4 walking out and I thinkhe forgot that he had it, but
5 Q. Oh, how many people approximately7 5 I don't know, he didn't - never said anything to me
6 A. Maybe ten. about it, it just ended up being there.
7 Q. Ten people7 7 Q. Allright. Tell me about when you left there, what
6 A. Yeah. r happened?
9 Q. And how long were you there? 9 A. Well, we left there and we started traveling down
10 A. Throughout all the afternoon and then evening. There 10 Eight Mile and Officer McCabe started following us
was people there when we got there and then it just 11 right after we pulled off and we got on to the ~ like
12 ended up being the four of us. 2? as soon as we came across like Eight Mile, because it

Q. And I think you indicated - 13 was on the other side, like we came that way, then he

: ; A. We just sat there watching TV and playing cards. 14 started following us. He followed us for quite a

. Q. You don't know where Matt lives now? 15 ways.

16 A. No, uh-uh. I mean, I heard he moved, but I don't have 16 Q. All right. Let me go through this. When you left his
any idea where he moved to. 17 house on Greeley -- and you don't know the address7
Q. Do you know any of the other people who attended7 18 A. No, I don't remember it.

A. No, I didn't know any of them. They weren't my 19 Q. Do you know what streets it would have been between7

20 friends or anything, I didn't --1 don't you know, 20 A. Not exactly.

:: they were just friends of Mart's that happened to be Q. It would have been off of State Fair7
22 over, neighbors and stuff. He's really social. A. It was further.

23 Q. How long were you there7 23 Q. Further north?

24 A. Let me see. Probably from then until I would say 24 A. No yeah, further east.
25 around 12:30, 1:00 in the eve -- in the night. 25 Q. Toward Eight Mile?

Page 22 Page 2 4
1 Q. Were you d rinking? 1 A. No, it was more towards Seven Mile, Six, Seven Mile.
A. Earlier in the afternoon I had three beers, two or Q. More towards Seven Mile7
three. I don't recall exactly. It was two or three 3 A. Yeah.

4 maybe. 4 Q. Okay. But anyway, when you left there I assume you
5 Q. And you sa d you were there until around 12:30 or 1:00 5 took Greeley down to Eight Mile?
6 a.m. 6 A. No, I think we yeah, maybe. I don't remember
7 A. Yep. 7 exactly. I wasn't driving, I was busy talking.
8 Q. And you left at that point? 8 Q. Okay.
9 A. Uh-huh. 9 A. So I don't remember exactly but I know that we ended
:: Q. That's a yes? 10 up down on Eight Mile and she took a side street.
A. That's a yes, yeah. 11 Q. Going west on Eight Mile?
Q. And who was driving? 12 A. We were driving west on Eight Mile when -- as soon as
: : A. Michelle. 13 we like he came around there, like turned on like
14 Q. And where were you in the vehicle? 14 the you know, you do like a Michigan left onto it,
15 A. In the back seat. 15 we noticed he started following us.
16 Q. All right. And did you have a beer in the back seat? 16 Q. You saw the officer following you?
17 A. I did not. 17 A. Absolutely, yes.

Q. You did not? 18 Q. All right. And what happened then?
19 A. I was not that was not I did not. ::- A. He followed us and continued following us all the way
20 Q. Pardon me? down Eight Mile until we got on the service drive and
21 A. It was there but it was not mine, I mean, I did not 21 then he continued following us down the service drive.
22 have it. It was found there but I did not have it and 22 Q. From Greeley to the service drive is not that far,
23 I did not put it there. 23 correct7

Q. Had you seen it there? 24 A. It was from well, Greeley goes this way
.

A. No. Q. North7
"

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JAN CRAWFORD
March 29, 2017

Page 25 Page 27
A. -- and the service drive goes this way, they're Q. He took that --

parallel to each other, so it was the distance from A. Yep.

maybe Dequindre to 75,so it's that - it was maybe a Q. -- and then he left the vehicle7

mile or two all the way down Eight Mile. A. Right, and then he came back while the information was
5 Q. About a mile that he followed you? being run by the other guy, the tall, dark-haired guy

A. Maybe closer to two, and that's because it was from 6 with a

where he lived, which is more towards Dequindre, I Q. So at that point another car --
believe, and all the way down the service all the A. No, they were two of them were in the one car
way down Eight Mile and then down the service drive. together and then there was two more in the second
Q. So when you got to the service drive a right turn was car. There was always four of them.
11 made. 11 Q. Officer McCabe was in the car with another person7
A. Uh-huh. A. Yes.

1 Q. And then what happened7 Q. And did you get the name of that person7
14 A. We went down the service drive for a little bit and 14 A. No, I didn't ask.
then he turned his lights on as we were coming Q. So your testimony then is Officer McCabe gave the
16 getting onto 75. He pulled us over and we pulled off 16 driver's licenses to the other person?
17 onto the shoulder. 1" A. Uh-huh.

Q. All right. What happened then7 18 Q. And that person--that's a yes?

19 A. Then he came up tothe car and he asked for our A. And then he came to my window and started talking to
driver's licenses and hetook all of ours, and then he me, not initially to Christopher at all, to me first
started asking us questions. Q. And what did he say to you7
Q. When he approached the vehicle did he do it on the A. Well, he asked for the identification too and while he
driver's side or the passenger's side? was asking I was like I'm not trying to be rude, I was
A. Initially on the driver's side. like is this going to take long because I have an
25 Q. And what did he say or do7 appointment in the morning, and then he said what is

Page 26 Page 28
A. He asked, you know, what we were doing and, you know, it for, and I said my daughter has a brain tumor and
where you know, and he asked us if he could see our we have to go to Children's in the morning and then he
driver's licenses, some identification, and she got told started to proceed to tell me about his
hers and he said all of you. She got out hers and he brother and the struggles with his brain tumor.
said all of you, and I was like in the back seat, but Q. And then what happened7
okay, so we all gave our driver's licenses. And then A. Michelle at one point had asked can ~ she asked a
he went and started looking at that looking at the couple times actually, why can somebody tell me why
information. We sat there quietly. I'm being pulled over, and he didn't he wouldn't
Q. Did he talk to Michelle? answer the question, he refused to answer the
10 A. No.
question. And then he got what almost seemed like
:: Q. Did he talk to Christopher7 overly friendly with me, just like - we kind of had
12 A. Through the window initially, yeah. 12 an identifying moment because we had -- you know, his
13 Q. And where was he at that point then, on the driver's :: brother, he was telling me how his brother now has a
14 side - :; job, you know, he's an adult and he's fending for
IS A. He was on the 15 himself and he told me, you know, just, you know, the
:: Q. -- or the passenger's side? : struggles that he has, and so we were talking for a
17 A. -- driver's side and then later he came over and 17 little bit, and then Chris at one point was like umm,
:- talked to us on the passenger side while his partner : Michelle had asked why were we pulled over and he's
19 was running the information. :c- like does anybody want to tell her why we're being
2 D Q. So he pulled you over' 20 pulled over? And at that point he was like I
:: A. Uh-huh. :; didn't wasn't talking to you to him, and like that
22 Q. Came up to the driver's side window? 22 was about it.
. 3 A. Right. :.: Q. That was the extent of the conversation?
.:; Q. Asked for l.D. from everyone? A. Yeah.
25 A. Yep. Q. At some point -

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A. It wasn't much of it. It was kind of a long A. I didn't see that but I saw them taking his shoes off.
conversation about his brother and Merrin because my 1 Q. You learned later that he had cocaine on him?
daughter had her craniotomy this summer, so I was A. In his shoe, in his sock apparently. They made him
about I told him we were about to be having the take his socks off.

brain tumor removed. It was kind of a lengthy 5 Q. Did you know that he had cocaine on him7
conversation because it was the entire time that A. No, I did not.
MR. GIROUX: Jan, wait for another Q. Had he been using cocaine at his brother's house7
8 question. A. Not to my knowledge.
A. Oh, I'm son-y. 9 Q. Did he obtain the cocaine from his brother7
BY MR. VINSON: 10 A. I do not believe so.

Q. At some point he asked Christopher to step out of the 11 Q. Do you know whether or not his brother sells cocaine7
12 car? I'- A. He does not.

A. Uh-huh, after they came back with our-after the 13 Q. Was anyone using cocaine there --
other officer came back and talked to him and then he A. No, we were not.
asked Christopher to step out of the car. Q. - at the brother -- pardon me7
-i Q. And did you see what happened at that point7 A. No, we were not.
A. Yep. Well, I mean, as much as I could because I was Q. Do you use cocaine7
looking over my thing. They walked him over to the ".B A. No, I do not.
car and they started asking him questions. 19 Q. Have you ever used7
Q. To the police car7 20 A. Yes, I have.
A. Uh-huh. 21 Q. And when was that?
22 Q. Now, you were-- 22 A. It was a few years ago. I'm going to say let me
23 A. And they were talking to I guess, I mean see. I want to say it was a couple
MR.GIROUX: Jan, wait for questions and -4 MR. GIROUX: If you don't recall --
you can't talk over Mr. Vinson because the gentleman 25 A. I don't remember. I don't recall.

Page 30 Page 32
to your left can't take everybody down in the right MR. GIROUX: Then you can give him a range.
order. Slow down, it's okay. A. Yeah.
A. Okay. MR. GIROUX: Was it several years ago?
BY MR. VINSON:
THEWITNESS: No, it was about a year or
Q. All right. You were pulled over down on 1-75; is that two when we tried it.
correct? BY MR. VINSON:
A. Like at the end of the service drive. Q. By the way, how long have you been dating Christopher7
Q. And the police vehicle was immediately behind the car A. Three years.
you were in, correct7 Q. Three years.
:: A. Probably about six - a couple car lengths back maybe. 1C A. Well, no, that's not correct. Two and a half.
n There was a little space there. 11 Q. So it was during the time you were using cocaine you
:: Q. And when Christopherstepped out of the car you were :: were dating Christopher7
13 in where did they take him, did they put him in the 13 MR. GIROUX: I think she said she tried it.
14 car immediately or just behind the - 14 A. I tried it, I wasn't using.
15 A. No, they took him to in the lights in front of the 15 BY MR. VINSON:
16 car.
Q. Oh, okay. Was Christopher using cocaineduring that
:~ Q. In the lights in front of the car, and did they period.
18 conduct a search of him? :;- A. No, not to my knowledge. Well, he wasn't, to my
19 A. Yes. 19 knowledge.
Q. Did you hear them ask if they could search him7 2D Q. All right. So the officers conduct a search of
A. I couldn't hear anything. Christopher, find something. Did you see them place
Q. Okay, you couldn't. Did you watch them search him? him in the police car?
: A. Yes. A. Yes.
24 Q. And did you see them when they found a little packet Q. All right. Then what happened7
25 of a white powdery substance? 25 A. Then they took me out of the car.

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<3>IENENSTOCK U]jpport
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JAN CRAWFORD
March 29, 2017

Page 33 Page 33

Q. And took you where7 and he said no, all the way up.

A. To in front of the lights, in front of the hood of the 2 Q. Let me stop you right there. What were you wearing,

car. what type of top were you wearing?

Q. And who was it, was it Officer McCabe7 A. I don't even remember. I cannot

A. It was Officer McCabe. - Q. I mean, was it a T-shirt, a blouse?

6 Q. Tell me what happened7 A. Yeah, the shirt was probably it was a very hot
7 A. Officer McCabe walked me to the back of the car. At summer day and it was probably a tank top or a T-shirt
- this point in time somebody the other partner that like not a tank top, like a T-shirt, probably like
9 was in the car with him was putting Chris into the a V-neck usually. I don't remember what I was wearing
1C back seat of the car and the other car had pulled up that day but I'm pretty sure it was a T-shirt.
:: and they were had gotten out of the car and they -- Q. And would you have been wearing shorts or pants or
12 were standing so if this is the car and it's facing 12 what?
north, I was facing the car, McCabe was to my left. 13 A. Probably shorts.
14 Chris and his partner were at the back door and they Q. Okay. You just don't remember --
were shutting the door, like, you know, that he shut A. I don't remember.
16 the door, and the other officers had pulled up right 16 Q. - specifically7
1" behind him and walked up alongside the driver's side A. Uh-uh.
: - of the car and were standing ~ 18 Q. All right. Go ahead.
19 Q. The driver's side of which car, the police car? -9 A. Okay. So I pulled my shirt up and then he said I need
:: A. Of Officer McCabe's car. you to now I need you to pull your bra up with it
21 Q. Okay. too, and I said okay. So I kind of pulled it out and
A. And they were standing like to the on the driver's he goes no, all the way up. So I took it all the way
side of the vehicle, so to my right because I was 23 up like this, and I
24 facing the car. 1 ; Q. Chest high?
25 Q. So your recollection is at that point there were four A. About to here, right about to my sternum, and then he

Page 34 Page 36
officers present? said

A. Yes, uh-huh. MR. GIROUX: For the record, she's at the

Q. And what happened7 bottom of her throat at the top of her chest.
A. He said we found we just -- are you aware that we A. Like that, and I was leaning trying to do it all at
just found - are you aware that Chris Mattice was in the same time and I was nervous so I felt shaken. I
the possession of crack cocaine, that's what he called was like okay, is that enough? He goes no, I need you
it. And he said --1 was in shock and I was like to shake your breasts in case there's anything in
what, and I said no, I was not, I had no idea. And he there, so I did. And he said not side to side, up and
said do you have crack cocaine and I said no, I do 9 down, so I shook them up and down. At this point I
not, that's ridiculous. And he said okay, well, I :: heard Chris yell because the window was still -- like
have to strip I have to search you now, I have to the door was still partially open and he was doing
pat you down and search you now, and I said okay. :: something with him. He goes oh, hell, no, because he
So he said I need you to place both your :: was inside of the car. And he went to get up and his
palms hands palm down on the hood of the car, and I 14 partner shoved him -- his head back into the car. He
15 said okay. And he said go ahead, and I did. He goes 15 said sit down, and then so - and he goes shake your
16 now spread your legs, so I did. He said spread them : breasts, ma'am, so I did again.
:~ further, and I did. Andthen he said now I need you 17 And at that point I looked over and I could
18 to like lean forward, he goes now stick out your ass, 1- see that the one guy on the right-hand had his
19 and I did. He said stick it out further, so I did. ;
cellphone camera on me, and he said all right one
20 And I'm like okay, and he's like well, 20 of them said all right, like it was enough, and he
:: ma'am, I have to make sure that, you know, you're not said well, I just need to make sure there's nothing in
22 concealing anything, and I'm like oh, okay. And then there because if not Irn going to have to take you to
23 he said I need you to take your right hand, lift it up the off to the station and have a female officer
24 and pull your shirt up, and then I said okay. So I'm conduct a full strip search. And then at that point,
like -- so I kind of pulled it up like a little bit you know -- oh, he also told me to shake them harder.

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JAN CRAWFORD
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Page 37 ?aq< 3

1 Sorry, I forgot, and so I did. first place, the license numbers or driver's licenses.
Then that happened and then I stood back up Q. Didyou see them conduct a search of Michelle7
and he said okay, I need you to stand up over here and A. Yes.

he was like do we need to strip search you, and at Q. And what happened there7
this point I had started to cry and I was like no. I A. She was standing. It was similar to mine. They
go and he's like do you know what happens when we didn't have her pull her shirt all the way up. They

strip search you with an officer? I go what do you had her like lift it out and shake her breasts like

want me to do, you want me to stop you know, cough 8 that and

and squat, what is it that you want me to do? And :' Q. Lift -- pull it out?
10 then- A. I don't I don't remember exactly because at that
'-'- BY MR. VINSON: : - point in time I was crying, my eyes were pretty blurry
Q. Who's talking, who are you referring to. 12 but I was watching her do something almost exactly the
13 A. I said that to Officer McCabe, and I was shaking and 33 same but not bent over. She was doing it from a
crying. I said I don't know what you want, what do 14 standing position.
you want me to do? You know, like there's nothing on 15 Q. And after that they - strike that.
16 me, you just saw my breasts, there's nothing else. Did another officer come -

And he was like do I need you to take -- he goes all A. Yeah.

right, can you tell me that you're telling me the :'- Q. -- on the scene7
entire truth, and I said yes, I'm telling you the 19 A. Yeah, and I'm not sure if which one searched her.
entire truth. And you have no knowledge of, you know, 2C I think it was one of the other officers but I don't
him having anything on him, and I said I had no remember. It could have been the partner at this
22 knowledge. point, I don't know, because at this point I was just
And then he said do I need to take you -- absolutely floored.
-4 if i take you right now and have you strip searched by 24 Q. So there were four officers there. Didany other
a female and patted down by a female officer, will you officers arrive7

Page 38 Page 40
have anything on you now, and I was like no, I said A. No, just the four.
no. I said I pulled my shirt up, I don't know what Q. And all four were there during the duration of the
more you want. And then he said okay and then he incident7

started searching Michelle. And then the other guy A. Yes, and one had a cellphone out with a camera going,
who was standing with Michelle started you know, he like the bright light of a flash and the camera, like
said hold on a moment and then he started searching you could see that in the dark it was on me.
her. Q. I'm sorry, say that again?
Q. Where was Michelleduring all of this7 A. The camera was on me when I was being searched over
A. Michelle was in her car and then during the time that the hood.

I was being shooken down, or whatever we call it, he Q. All right. Doyou know what type of camera, was it -
got the officer got her out of the car and walked A. It was a cellphone.
:: her alongside 75, and so she was to my right because I Q. Oh, it was a cellphone?
13 was facing the car. A. Yeah.
:-. Q. And after this interchange what did he say or do7 Q. Anything else happen7
1: A. He said okay, what we're going to we're going to A. Not that I remember.
16 let you girls go after and then he said but you Q. How long were you detained there at the side of the
1" need to get out of here right now, and they were like road?
18 go, get out of here, run, and so we did, and then we A. I'm not exactly sure. I'm not exactly certain. It
19 got in the car and Michelle said wait a minute, we 19 seemed like an eternity. It could have been only a
:: don't even have our driver's licenses, so then we 2C half hour, 45 minutes. It wasn't that long, I don't
:: waited and then eventually somebody brought it over to think. I don't know how long.
us because it was very intimidating. Q. The officers then told you to get out of here.
Q. Was it Officer McCabe that brought it to you7 What's --
24 A. No, it was the other short-haired guy, I believe. 24 A. Yeah, go, just go.
25 Yes, the other one that ran the license plates in the 25 Q. Did--

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March 29, 2017

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: A. We're gonna like it wa s we're gonna let you go now. skills, relaxation.

2 Q- Did the officers search the vehicle? Q. Were you seeing her prior to the incident?

3 A. Yes. A. No.

4 Q- Did he find the open can of beer7 Q. And how did you find her7

5 A. Apparently. A. My children were going there and my mom noted that I

6 Q. And did he say anything to you about that7 was having a hard time, I had come unglued on one of
7 A. Not at all. the people that work for her, one of the police
8 Q. Did they confiscate the beer or just leave it in the officers, on a routine traffic stop that she was in

9 car7 the car for and I completely lost it on him because I

:: A. I don't know, I didn't see it. thought he was going to search me for just a traffic
:: Q- So after you left what did you do, where did you go7 :: stop, and she --
ii A. Home to my house. To my mom. 12 Q. And where was this, in what -
13 Q. In Berkley? 13 A. It was in Berkley in front of this in front of
14 A. Yep. 14 Anderson, my daughter's middle school. They were
15 Q. As a result of this incident have you treated with any 1: just they were just trying to tell people how they
16 medical provider7 wanted the flow to go but I lost it and I started
n A. Yeah. screaming at him, you know, what are you going to do.
18 Q Who? I got out of the car, I was like -- my mom like ran
j ^ A. Her name is Cindy. I can't think of her last name and ushered the kids in the school and then he calmed
right now because I norm ally only call her Cindy, but me down and he talked with me and he's like I'm sorry,
she's Oakland Family Services. That's who yeah, and then he said to me -- my mom said she's having a
OFS in Berkley. hard time because so mething bad happened to her with
23 What street7 23 some police officers recently, and he was like okay,
Twelve Mile. 24 and then he was rea lly calm and really calm
And what is she, is she a doctor, psychologist, soothing, but he then told my mom you might want to

Page 4 2 Page 44
therapist, counselor7 get her some help for that, and that's when I -- my
A. Just I think a therapist. mom was like you need to call and make a counseling
Q. She's a therapist, so a -- appointment.
A. It's a mental Q. When was this incident7
Q. -- mental-health therapist? A. It was the first day of school for my children.

A. ~ health therapist. Q. So that would have been sometime --
7 Q. Pardon me7 A. September
r A. Mental-health therapist. Q. -- September or August7
9 Q. And what does the therapy consist of7 A. -6th or 7th.
10 A. Weekly sessions where I sit there and talk with her 10 Sometime in early September after Memorial
:: for an hour. ;: Day (sic). I could look at the Berkley calendar and
:: Q. And how long have you been seeing her7 :: tell you. He's still there every day because that's
A. A few months.
his job. Now he just waves and smiles.
Q. Pardon me7 14 Q. And you sought out Cindybecause your children were
A. Probably, I don't know, off and on for mostly for a 15 seeing her?
few - a few months, I would say. Sometimes she can't 16 A. No, they weren't seeing her. They were going to
17
make a one-week appointment and we'll go hit like 17 Oakland FamilyServices and it's the only place my
:- early one week and late the next week. I'd say - I :- insurance goes to. I have Medicaid and it's close to
:; don't remember exactly when I started but it's been a the house and I don't have a lot of time in my
2C few months now, seven months probably. schedule for anywhere long drives.
:: Q. Has she given youany sortof diagnosis or anything7 2] Q. And what do yourchildren go to Oakland Family
A. No, it's - I just don't believe it is her job to do __

Services for?
23 so. She's a therapist, she's not a doctor, but she A. They each have very serious health conditions, so they
z~. said she has told me that she you know, that it 24 can wrap their head around it.
25 is consistent with PTSD and we've talked on coping 25 Q. So is that like therapy for them also7

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JAN CRAWFORD
March 29, 2017

Page 45 Page 47

A. Yeah, its a - I'm probably going to die therapy. My extent of it?

one has a brain tumor, the other one just got a lupus A. Yeah, pretty much. I mean, I have an OB/GYN that I
diagnosis and the other one has periodic fever see, a gynecologist that I just started going to. I
syndrome. hadn't seen one prior to that in six years. I just
Q. What's that, periodic? saw her last week for the first time, or two weeks ago
A. Periodic fever syndrome, it's an autoimmune disease. for the first time. Oh, I had hand surgery. I forgot
But they were having a really hard time coping so I about that, but that wasn't an overnight stay.
entered them in that put them in that like a year Q. You said hand?
9 before I started. A. Yep. I broke my hand in my garage, a box came down,
10 Q. At some point then you decided to institute the and I had to have my fingers pinned.
11 lawsuit? Q. And when was that?
A. Yes. A. That was like a I want to say last no, not last
Q. And when did you make that decision? Memorial Day but a year ago it will be two years
A. I don't remember exactly when it it was I mean, ago Memorial Day. That weekend. It was not - it
it was shortly after it because I didn't want anyone wasn't on Memorial Day, it was like the weekend of
16 else to go through feeing sexually harassed or police Memorial Day when I injured it and it wasn't actually
17 misconduct. I mean, I've got a 19-year-old daughter fixed for two months after that because, you know, I
that is out there driving. had to wait for an appointment
19 Q. Now, other than Oakland Family Services, are you Q. You indicated the therapist is Gndy. You dont know
treating with anyone else or seeing anyone else? her last name?
A. No. A. No, I can't think of it offhand.
Q. Are you taking any medications? Q. She said you have PTSD?
23 A. No. 23 A. Uh-huh.
24 Q. Do you have any other medical condition likehigh 24 Q. Has she referred you to any psychiatrists or someone
blood pressure, diabetes? who can -

Page 4 6 Page 48
Endometriosis. A. No, because I'm not interested in taking medication.
Pardon me? Q. That was my next question.
3 I have endometriosis, that's it A. I have narcolepsyand anything that I take reallyputs
4 What -
me to sleep a whole lot When I was in Havenwyck they
Ifs a uterine thing. 5 tried, you know, like some anxiety stuff and I just -
6 Oh, that's whyI don't know about it. Have youbeen 6 I can't even physically wake up. I'm like, shooo,
7 hospitalized forany reason in the last ten years 7 gone, sleeping.
8 other than childbirth? 6 Q. So you're not taking any medication?
9 Yeah, kidney infections. Let me see. Accidents and 9 A. No. I work out, that's my coping mechanism.
10 like falls, things like that, nothing major. 10 Q. Where do you work out?
11 Allright. And what- 11 A. Planet Fitness.
12 Never any - nothing like that was - the longest stay 12 Q. Which one?
13 was a kidney infection a couple years ago, I think it 13 A. Oak Park. I also run, not in the snow though.
14 was in 2013. I was really sick. 14 Q. Do youmean you're a marathon runner or just--
15 AH right. Was that at Beaumont? 15 A. No, I run the streets with my chihuahuathrough
16 Uh-huh. 16 Berkley.
17
So any hospitalization would have been at Beaumont? 17
Q. Now, how long haveyoubeendating Christopher?
18 Yes. Oh, I was also- you know, for mental-health ie A. About two and a half years.
19 issues I was - shortly after I came home from Florida 19 Q. Where did you meet him?
20 I was in during the separation and my divorce I was 20 A. Through friends.
21 in Havenwyck for a little while. 21 Q. Was it a blinddate or you -
22 And where's Havenwyck? A. Oh,no, it was just I was out with a friend one day
23 On Rochester. 23 and he was helping her move a refrigerator.
24 So other than beingtreated at Havenwyck, Beaumont 24 Q. Then things kind of clicked?
Hospitaland Oakland FamilyServices, that's the A. And then he saw me on Facebook and sent me a friend

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1
request and I talked to him about six months after 1 theater you've probably been in, hospitals, all over,
-
that I didn't like htm, he wasn't cute enough. 2 floors everywhere.
3 Q. Now, at the time of this incident he was living in 3 Q. Well, for the time he served, did he do it at the
4 Warren? 4 county jail?
5 A. Yep. 5 A. Yeah, Oakland County.
6 Q. And he was arrested, and you said he did some jail 6 MR. VINSON: Okay. All right. I have no
7 time? 7 further questions. Thank you.
8 A. Uh-huh. 8 MR. GIROUX: I don't have any questions.
9 Q. How much did he do? 9 (The deposition was concluded at 11:07 a.m.
10 A. He got sentenced to I think 80 days or whatever and he 10 Signature of the witness was not requested by
11 ended up serving 70. He did a no-tolerance release ii counsel for the respective parties hereto.)
12 program, but he was also he put himself in 12

13 outpatient therapy and treatment and started going to 13

14 A.A. as soon as the incident happened because he 14

15 didn't want to lose me obviously. 15

16 Q. Outpatient therapy for what, alcohol or drugs or both? 16

17 A. For drugs. 17

18 Q. All right Is he in therapy still? 18

19 A. To this day. Church ever Sunday. You know, he is 19

20 he wants to stay with me. 20

21 Q. All right. And he attends N.A.? 21

22 A. Yep. No, A.A. and N.A. Well, whatever meeting he can 22

23 get to, he does both, just because sometimes some are 23

24 more accessible than others, but he mostly goes to 24

25 A.A. because it's but they ordered him treatment 25

Page 50 Page 52
1 for the drugs, although he believes he's had problems 1 CERTIFICATE OF NOTARY
2 with drugs and alcohol most of his life since his 2 STATE OF MICHIGAN )
3 mother died at 17, so it's been good for him, I 3 )SS
4 believe. 4 COUNTY OF OAKLAND )
5 Q. Just give me a second. 5
6 A. Oh, take your time. 6 I, ALAN STALBURG, certify that this
7 Q. Let me see if there's anything. 7 deposition was taken before me on the date
8 A. Oh, and that was you sa id how long he's - that was 8 hereinbefore set forth; that the foregoing questions
9 how much time after, he got after. Initially he was 9 and answers were recorded electronically and
10 in jail for a month and then until the case came 10 transcribed by me; that this is a true, full and
11 up, then he started the remaining time, so there was 11 correct transcript of my recording so taken; and that
12 some other time. The next 70 days was after the month 12 I am not related to, nor of counsel to, either party
13 that he originally served. 13 nor interested in the event of this cause.
14 Q. Well, when he was initially arrested - 14

15 A. I didn't have the $1,000 cash to get him out so he sat 15

16 there for a while. 16

17 Q. But then you were able to - 17 ^_

18

19
A. And then his boss wanted him back and coughed up the
money.
18

19
'i^SS*
"fL^jk
20 Q. Who? 20
''- "^B&
21 A. His boss. 21

22 Q. His boss? 22 ALAN STALBURG, CER-9106

23 A. Uh-huh. 23 Notary Public,
24 Q. Where does he work? 24 Oakland County, Michigan
25 A. At tile, Paul Tile. He lays custom tile. Every movie 25 My Commission expires: October 6, 2022

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