Sie sind auf Seite 1von 60

Kevin Mede, March 10, 2014 Paul Murphy v.

Whatcom County

1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Reported by Kristen M. Uhlig Certified Court Reporter, CCR, CSR Washington CCR #1934 UNITED STATES OF DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE --------------------------------------------------------------PAUL MURPHY, together with his marital community, Plaintiffs, ) ) ) ) vs. ) NO. 2:13-CV-00727 ) WHATCOM COUNTY, WASHINGTON, a ) government entity; WHATCOM COUNTY ) SHERIFF'S DEPARTMENT; WILLIAM J. ) ELFO, together with his marital ) community, ) Defendants. ) --------------------------------------------------------------DEPOSITION UPON ORAL EXAMINATION OF KEVIN MEDE --------------------------------------------------------------11:00AM - 12:20PM March 10th, 2014 Whatcom County Courthouse 311 Grand Avenue Bellingham, Washington 98225

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

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

2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: William Elfo Tara Adrian-Stavik FOR WHATCOM COUNTY: Elizabeth Gallery Whatcom County Prosecutor's Office 311 Grand Avenue Bellingham, Washington 98225 FOR THE DEFENDANTS WHATCOM COUNTY & SHERIFF'S DEPARTMENT & ELFO Dale Kamerrer Law Lyman Daniel Kamerrer Bogdanovich 2674 RW Johnson Blvd SW Tumwater, Washington 98512 360.754.3480 FOR THE PLAINTIFFS: Robert Butler & Emily Beschen Law Offices of Robert Butler 103 East Holly Street Suite 512 Bellingham, Washington 98225 360.734.3448 A P P E A R A N C E S

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

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

3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 EXHIBIT DESCRIPTION PAGE EXAMINATION: PAGE I N D E X

BY MR. BUTLER.................................................3 BY MR. KAMERRER..............................................35 BY MR. BUTLER................................................47

1....E-mail Dated 12/8/2010 - 2011 Election Issue............15 2....E-mail Dated 10/19/2011 - RE: Murphy Website...........19

3....E-mail Dated 3/21/2012 - Memo as requested..............24 4....E-mail Dated 10/19/2011 - Murphy Public Disclosure......30 5....E-mail Dated 12/16/2011 - RE: Update...................32

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

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

4
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

KEVIN MEDE, having been first duly sworn, was called as a witness herein and was examined and testified as follows:

DIRECT EXAMINATION

BY MR. BUTLER: Q A Q A Q A Q Good morning. Would you please state your name for the record?

Kevin Mede, M-E-D-E. And where are you employed? Whatcom County Sheriff's Office. How long have you been so employed? This summer will be 15 years, so since August of '99. Okay. It's 11:00 on March 10th. You're here for a discovery You

deposition in the matter of Murphy versus Whatcom County. have counsel present; correct? A Correct. MR. KAMERRER: THE WITNESS: MR. BUTLER: Q (By Mr. Butler) I am not his attorney. Ah, I do not know. Okay.

And that was Mr. Kamerrer who indicated that

he's not your attorney; correct? THE WITNESS: MR. KAMERRER: THE WITNESS: Is your name Mr. Kamerrer? Yes. Yes.

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

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

5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q A Q Q (By Mr. Butler) Do you know Liz? I do. Do you know her to be your attorney? I don't believe that I am represented by anybody. Okay. And next to her is Sheriff Elfo. All right. And next to him is Liz Gallery.

Correct. Do you know him? Yes, I do. And around the corner is Tara, the paralegal for the prosecutor's office. I -- yes. And then next to me is Emily Beschen, an associate of my firm, and myself and the court reporter. that you're aware of? Not that I'm aware of, no. Any reason that we should be aware of today that your sense of perception would be compromised or your ability to hear and answer questions truthfully, would be somehow better on another day? No. Under the influence of any alcohol, drugs, prescriptions or otherwise? No. What's your understanding of a discovery deposition? Why Anybody else in the room Do you know her?

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

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

6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A Q A Q A Q A Q A you're here? To obtain as much information from named witnesses before going to trial to see if they're useful or the information is relevant, I suppose. Okay. I do. How do you know Paul? He was an employee of the sheriff's office. Okay. Was he in your 15 years of employment, was he ever under And in this matter -- do you know Paul Murphy?

your supervision? Yes, he was. And when was that? In November of 2007 until he left the sheriff's office -- not contiguously, I'm a shift supervisor, so it would be for periods of time. Okay. When you started in '99, what did you hire in at? What

was your position? Deputy sheriff. And have you had any promotions? Yes. What promotions have you had? Rank promotion, a first line supervisor sergeant in November of 2007. Any other promotions? No.

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

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

7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q Q Q A Q A Q Of rank? No. So it would be appropriate to refer to you as Sergeant Mede? Sure. Okay. With regards to the sheriff's department, are you aware

of anybody in the sheriff's department that has credibility problems? MR. KAMERRER: Object, calls for speculation. In a

deposition even though I stated an objection, you'll still answer the question, so I'm just making that for the record. So if you understand the question, you can answer it. THE WITNESS: (By Mr. Butler) of Deputy Flynn? Not sustained.

What's your personal view of the credibility I'm going to use deputy all the way across

these names as opposed to the rank that I may get wrong. MR. KAMERRER: I'll insert another speculation -Go ahead.

calls for speculation objection. THE WITNESS: (By Mr. Butler) Flynn.

You're asking my personal opinion?

Your personal opinion of the credibility of

Can you define how you're using credibility? Do you think that he tells the truth? Yes. So have you had any question of his telling of the truth? No.

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

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

8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q A Q A Q A Q A Q A Q Q Q How about Nyhus? MR. KAMERRER: (By Mr. Butler) telling? No. That was a long pause. Yes, it was. Can you explain, since we're just getting this in written form, why you took quite a while to answer that? I was being sure of my answer, being thoughtful. Are you sure of your answer that he is credible and truthful? Yes. How about Taddonio? Yes. And Roff? Yes. VanderVeen? No. Can you explain your concerns with regards to Deputy VanderVeen? It would have to do with his personal life and keeping commitments and being honest with those in his most inner circle. Any regard to his on-the-job sheriff's officer capacity for truthfulness? Same objection.

Have you had any questions with his truth

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

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

9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q Q A A Q A Q Q A Q A No -- check that. Perhaps. I am skeptical of his incident

that brought him to federal court. Okay. The Wiederspohn matter?

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

investigation in your capacity as a deputy -- as an employee of the sheriff's department into the Wiederspohn, Freeman and VanderVeen matter? No. Moving on. Harris? Phrase the question again?

Again, I want to answer correctly.

Your personal opinion as to his truthfulness and truth telling? MR. KAMERRER: I just want to insert the same

speculation -- calls for speculation -- objection. THE WITNESS: (By Mr. Butler) Okay. Yes. I have doubts with Harris.

What is that based on?

Differing answers about mostly guild related activity and public disclosures, things like that. Anything else of concern or any specifics that you can identify, as you did with VanderVeen, with regard to Harris' credibility? Not at this time. Would there be documents that you could review that would refresh your recollection, do you think? Or when you say, not

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

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

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

10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A A A Q Q MR. KAMERRER: THE WITNESS: Objection, that's argumentative. Perhaps if I sat and thought about that

question for a long period of time, I could come up with better examples. But on the face of it, I don't trust his

credibility, most recently stemming from a public disclosure request that he completed and reportedly gave false information about when confronted. (By Mr. Butler) And what are you referring to there, just so A public disclosure request that

that we're on the same page? he made of the county? Correct.

So your concern is that he made a request of the county for documents? Under the guise of being the guild president after I refused to release them to him. you to be spiteful. Okay. When was that? It was the last And then he, of course, provided them to

You could answer that better than I could. several months, maybe three months. Okay. No. Credibility? No. Moving on. Cooley? Truthfulness?

You don't think that he's truthful and credible? I do think. I don't have cause to question it.

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

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

11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A Q A Parks? No question about him. Jeremy Freeman? The same questions that I have regarding the Wiederspohn incident. Anything else with regard to Freeman? I don't know if it's truth telling. issue. Can you explain that? He was upset and angry over a disputed, I believe, log event or a counseling session that Sergeant Larson wrote. Where he is It's more of a perception

adamant that he never displayed the behaviors that were written in the counseling, where I myself witnessed them. So, again, I don't know if it's more a perception issue on his end or if it was an honesty issue. it's more of a perception issue. Okay. When did that take place? I would have to look at My gut feeling is

This is, I am guessing, 2009 or 2010. the logs specifically. Okay. But it was years ago. Okay.

What's your relationship with the guild?

I'm a guild member. Have you held any office with the guild? I did.

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

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

12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A Q A A Q A Q A Q What office did you hold? President. When were you president? All of 2012 and up 'til March of 2013. Who became the president of the guild in March of '13? replaced you? It wasn't until a couple of months later, but Steve Harris is now the president. And who was the guild president that you replaced? Steve Harris. Okay. What's the role of the guild to your knowledge? Who

The guild is to protect the bargaining rights and to, you know, negotiate a contract for the represented group. Laymen's term, it's a union -Yes. -- for the deputies? Correct. Does the guild have internal officers? Yes. Are those elected? Yes. What are some of the functions that the guild officers perform? There's the treasurer. Okay. That does the traditional treasurer role of bookkeeping and

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

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

13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q Q A what not. There's the secretary that keeps track of meeting There's the first and second vice president

minutes and notes.

that will -- the first vice president is in charge of -- no. Check that. The second vice president is in charge of the The first vice president, I think, just

grievance committee.

helps the president and the president oversees the board. Okay. The grievance committee, what is that?

The grievance committee is a group of volunteers that when a member believes that they have a grievance, a violation of the contract that they believe is wrong, they'll bring it to the grievance committee who reviews the matter and decides to present it to the executive board for whether or not they want to push forward and file a grievance or try to resolve it with the administration et cetera. Is everybody in the sheriff's department in the guild? No. Where is the line? Sergeants and deputies are in the guild. Is the grievance committee elected or do they self-appoint themselves? They volunteer and are accepted or not based on the second vice president. Okay. So if the grievance committee reviews something, What's the next

generally, what happens with that review? step?

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

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

14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q Q A Q A If -- depending on their decision. Sure. If they decide that it is a righteous grievance, they would present to the executive board who says, yes, we should make the decision to formally grieve this matter or not. It's based If they --

on a number of factors, tactical decision making, cost, whether or not the matter is significant enough to forward to a grievance, given those factors. If the grievance committee

votes not to grieve it, then the member can elect to do that on their own. And the executive board, is that the president, vice president, first assistant, treasurer, secretary, that normal functioning? Yes. Normal hierarchy? I'm sorry. Okay.

Is there communication between the guild and management with regards to the grievance committee's work? There is supposed to be, yes. Okay. Is that conveyed through the president or does that go

directly -- committee to the sheriff or the management? It depends. When I was the president, I had the second vice

president, Jason Nyhus handle that. Okay. MR. BUTLER: I wasn't at the last deposition, Counsel.

Where did we leave off on numbering? MR. KAMERRER: I don't know. I think that we should

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

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

15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q with it. (By Mr. Butler) Okay. A Q A Q A Q Q start over. I think that we should start over. Oh, we can start over and go for

MR. BUTLER:

plaintiff's deposition exhibits one through -- that's fine with me. MR. KAMERRER: Why don't we just have one package of

depositions for this week and number them one through whatever. MR. BUTLER: Yeah. Okay.

(Marked Deposition Exhibit No. 1) (By Mr. Butler) Showing you what's been marked as Exhibit 1 --

I would represent to you that the reason my name is on the top is because it's printed off of my computer. Mm-hm. Do you recognize this as an e-mail that you sent in December of 2010 regarding the two-thousand and -- 2011 election issue? Let me take a minute and look at it. Sure. Yes. I recognize the e-mail.

Looking back at your dates, did Harris step down as a result of this? MR. KAMERRER: THE WITNESS: Objection, vague. I think that this had something to do

I can explain it if you would like. Well, let me keep asking questions. It may be that I'll just

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

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

16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A Q A Q A Q A Q say, would you explain it, in a minute. So that I'm clear with relationships, you supported Elfo in the election; correct? Ultimately, yes. You did an ad for him; correct? Yes. Okay. And Harris was running against Elfo?

Correct. And Taylor ran also? Yes, he did. The fourth paragraph, it says, "A few of the reasons." see that paragraph? Mm-hm. I see that. Do you

The second sentence you write there is that the relationship between the sheriff and the guild has soured over the last few years. Do you see that sentence?

I see it. What are you referring to there? The relationship between the guild and the sheriff. Yeah. sour? I used the word sour because that was my best analogy for picturing the relationship as far as being collaborative and unified. We're all in the same team type of thing. That that Why was it sour? What was -- why did you use the word

had become adversarial it seems.

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

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

17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A Q When you started in '99 -Mm-hm. -- so roughly 10 years preceding this, had it been not sour? During those 10 years, yes. What do you attribute the souring to? If it was good and as of

December of 2010 it was sour, what do you attribute the cause for the sour? Oh, I think that there's -- it would be pure speculation on my point, but my opinion would be as a number of factors, I am sure. But with regard to my labeling it this way with regard

to this e-mail, it would be Steve Harris' personality and approach to the administration. Labeling them as evil and everything that they do has an ulterior motive. And we have to -- we as a guild have to That, you know, anything that is

grieve every single thing.

suggested by the staff needs to be fought against, whether it is shift schedule changes which the deputies would enjoy or propose themselves -- if it was proposed by the staff, we need to fight against it. Things like that. But in your

So in your opinion, lots of reasons for sour. opinion, Harris was the reason that it soured? One of the reasons, yup. Okay. Is he alone in that in the guild?

Was he a lone wolf

that thought that management should be challenged? MR. KAMERRER: Objection, calls for speculation.

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

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

18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q Q A Q A Q A Q A Q A Q THE WITNESS: I wouldn't say a lone wolf, but he was

the -- clearly the biggest advocate of that. (By Mr. Butler) Okay. How is the guild president -- are they

elected by the guild? Correct. What's the term? Two years. A two year term? Correct. How long had Steve been the guild president? I don't recall. time. Multiple elections? I think two. And you were the interloper and then he's back; is that correct? Yup. Okay. Yes. Does the vote become known to the guild? Does the -- does it A period of time. A significant period of How long are you elected for?

get published that it's 37 to 24 or Steve won or is it just Steve won? It gets published, the numbers, not the actual individuals. Right. Correct. But the numbers do get --

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

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

19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A Q A Q Q Okay. Are you aware of what the -- what his support is? I

mean did he win by one vote? This last round? Yes. He went unopposed. Okay.

Did he win by a lot of votes?

I don't think that anyone else wants that job. Okay. So is it your understanding that the reason that Mr.

Kamerrer and Ms. Gallery and probably Dan Gibson aren't your attorney is because of the guild relationship? represent the county and the guild is separate? My understanding of it is that I'm not on trial. I'm here as a That they

witness and they're representing the interests of Whatcom County. Okay. But do you believe that Liz Gallery or Dan Gibson is

your attorney in your capacity as a sheriff? MR. KAMERRER: I'll insert an objection. It's irrelevant. It's vague

and calls for speculation. THE WITNESS:

Go ahead.

I suppose if I am on trial for

something, they would be my -- well, they would be the county's defense. MR. BUTLER: Okay. All right.

(Marked Deposition Exhibit No. 2) (By Mr. Butler) Showing you what has been marked as Exhibit 2, So let's start with the --

this is a multiple page document.

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

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

20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q Q A A Q some identifiers. On Page 1, halfway down, do you see an

e-mail from you to Chief Cooley referencing, Attached is a copy and paste version of what is on Murphy's website, Campaign to Un-Elect Elfo? I do see that. Do you recall sending an e-mail to Chief Cooley in October of 2011 regarding the Un-Elect Elfo website? I don't independently recall that, but I am sure that this is correct. Okay. We're going to look at a variety of exhibits with You're aware that when you print out an e-mail, the

e-mails.

first e-mail is typically at the bottom and the response is on top? Yes. Okay. Looking at the first page, do you recognize that the top That's how the thread typically goes?

of it is Steve Cooley's response to you thanking you regarding Facebook? Yes. Okay. That's what it looks like. Looking at Page 2 is the clean, if you will, version of

what is the bottom half of Page 1. Yes. Okay. That's what it looks like to me, yes. This one indicates that you sent it to Doug Chadwick and Why would you have included Doug Chadwick?

Steve Cooley.

I believe that at that time, he was my lieutenant, my supervisor.

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

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

21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q We by virtue of being your supervisor, you CC'ed him on whatever you sent to Cooley? Yes. I believe that this stems -- there's a reason for that.

That it stems from the -- well, if I'm thinking of it correctly that this is stemming from the meeting that Deputy Murphy and I had regarding his vague -- I've got something big going on. They're going to see, just you wait, type of thing. He --

everyone in the deputy ranks knew that he was operating the website. So my assumption was that that's what he was

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

bottom half or Page 2, the clean version of it, do you recall why you sent this? As in, were you directed, hey, get me this Or did you self-initiate it?

and you're complying? No.

I self-initiated it based on -- my best recollection is

based on that I've got something really big coming, real big going on, per our conversation about the trails issue. Okay. Was there anything in the campaign to Un-Elect Elfo,

which is the third through probably about the tenth page -- let me count them. This is just a print out of the page; correct? I was reading. The following pages,

I'm sorry, can you say that again? Okay.

That was a really bad question.

which I think is about 10 pages is just a printout that you printed out from the Campaign to Un-Elect Elfo; is that correct?

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

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

22 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q Q Q A A A Q I believe so, yeah. Is there anything in that printout, these 10 pages, that related to what you referred to as the trails and something coming? No. If I can re-address my answer now -- now looking at the

timing and flipping the page and looking at the posts that specifically were printed out, it would not be the trails issue. It would be another issue, I guess.

The issue being his campaign to Un-elect Elfo? The issue would be him claiming that I was on duty and misusing my authority, appearing in a commercial while I was in uniform or things like that. Okay. That's -- when we go to the page, the printout that you

have provided here, there's posts that appear to be your name associated. On the first page of it, it says, "No, Deputy Paul Do you see that?

Murphy, that video wasn't illegal." I do see that. Do you recall writing that? Mm-hm. Okay. Yes. All right. The second page.

Is that you?

It says, "Lastly, I am not Sorry to correct all of When is the election?

the Guild President until January 1st. your untruths, but enough is enough." Which election? MR. KAMERRER: (By Mr. Butler)

Objection, vague.

The election -- you said that you're not the

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

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

23 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q A Q A Q Q A Q A guild president until January 1st. guild president? I don't recall. Sometime -- sometime after Steve Harris When were you elected to be

stepped down, I would assume, in December. Was there a gap? Wait a minute. Was there a gap in time where the guild didn't have a president? I am sure a small gap. When you say small gap, what do you mean? I -Are we talking days or are we talking six months? Probably weeks is my best recollection. You said that everybody was aware that Murphy had the website, Un-Elect Elfo. How did you first become aware?

I don't recall if it was just in roadside conversations or, I believe, that it was banter amongst the deputies of, oh, have you seen the latest, oh, oh, type of thing. This appears to just be a two-day print out, the Saturday Sunday snap of this. Would you agree with that?

You have reviewed it more than I have so -- sure. Do you recall, was this -- I mean, it says, Attached is a copy and paste version of what is on website that is Tuesday the 18th. Would it be your testimony that this is probably the

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

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

24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q Q Q A Saturday, Sunday of, like, the 16th and the 15th? and Sunday before you sent this e-mail? MR. KAMERRER: THE WITNESS: Calls for speculation. Yeah. I don't recall. It is -- Mr. It is The Saturday

Murphy would post so much information on the internet. hard to ascertain which -- without a date on it. (By Mr. Butler) Okay. And did you follow it?

Only when I received information from deputies that he was talking about me. (Marked Deposition Exhibit No. 3) (By Mr. Butler) Showing you what has been marked as Exhibit 3,

it appears to be an e-mail from you to Steve Cooley on March 21st. Yes. And the first page is, "Attached is the memo regarding the evening of 3/2/12. Let me know if there's anything else." Do you recognize that?

Do you see that? I see that. The second, third and fourth page of the exhibit appear to me to be a memo written by you dated the 20th. that? I do. It's just a really weird memo system that the county has. has the memo header on each of the pages. that how it works? It Do you recognize

Is that what -- is

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

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

25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A A Q Yes. Okay. It was driving me crazy at my office. Okay. Do you

recall why you -- what direction you received to write this memo? I don't recall exactly who it was, whether it was Chief Chadwick or Inspector Cooley, but I was directed to write my observations of that evening in a memo and forward them to Inspector Cooley. What did they know about that evening that they would say, write a memo? Because Chief Chadwick and Lieutenant Rossmiller were there. Okay. You were there as guild or you were there as the patrol? Chief

I was working -- I was the scheduled patrol sergeant.

Chadwick told me that I needed to meet at the evidence building to talk to him, so I did. The night shift sergeant was not working that night, I don't recall if they were sick or vacation or whatever. So

there was an acting sergeant, which was a deputy, that is the acting supervisor. time. So Chief Chadwick asked that I send Mr. Murphy a message on the computer saying that he needs to come to the evidence building and meet, and then stand by so that I could make staffing arrangements because Mr. Murphy was going to be sent home. So it's the same rank as Mr. Murphy at the

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

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

26 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A A Q A Q Q A Q Okay. Why didn't you write it on the second or the third, if

that's when it happened? I don't know -- or believe that I was directed to until a little while later. Did you take notes on the second from which you relied to write the memo on the 20th? No. So is it fair to say that on the 20th, you were going off of memory and conversation? Most likely, yes -- well, yes. Okay. Just touching on some terms real quick from you. It

says in the second paragraph that you sent him a CAD message. What is that? A computer aided dispatch that means using our MTDs, the mobile data terminal in the car. You send a message like an instant

message or a text message or the computer. Okay. To your knowledge, are CAD messages retained?

I believe so. Okay. Mm-hm. Is that different than a laptop? No. Okay. They're used interchangeably. In the second page, Mr. Murphy, it says, you recall And the MDT?

asking you if you were there as his guild witness, and you told him that you were not. You were there as a shift sergeant and

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

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

27 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 leading. A Q A A Q A Q it would be inappropriate for you to be his guild witness for a number of reasons. Which? The third to the bottom. asks. Yes. I do see that. What would be the It starts with Deputy Murphy then Do you see that?

I'm curious as to the number of reasons.

number of reasons that it would be inappropriate for you to be his guild witness at that? That I was on duty, requested to be there as the patrol sergeant. That it wouldn't be appropriate for me to personally

represent him, given all of his animosity and false accusations against me. And in your opinion, the animosity between the two of you disqualified you from being objective and being his witness type of thing? No. MR. KAMERRER: Go ahead. THE WITNESS: objective. No. It didn't disqualify me from being Objection, calls for speculation. It's

I was the subject of much scrutiny and false It would only, my belief, lead me

accusations from Mr. Murphy.

into a no win position with Mr. Murphy to try to be his representative. Because he already had claimed that I was --

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

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

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

28 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A Q A Q A Q Q and I was in cahoots with Sheriff Elfo and his staff, et cetera. witness. (By Mr. Butler) Any other reasons come to mind as to why it So I arranged for someone else to be his guild

would have been inappropriate for you to have been his guild witness? Nothing else comes to mind. And if I'm reading it correctly, you allowed him to call Deputy Collins and Deputy Collins came out to the site? I contacted Deputy Collins and handed Mr. Murphy the phone. And then Collins came out? Yes. There was disagreement at that meeting regarding the gun and duty belt? Correct. But everything else, Murphy handed over; correct? Yes. And then Chadwick gave him a ride home and agreed, we'll sort out the gun thing another day? Correct. Were you aware on the second that that was going to happen on the second? Not until Chief Chadwick called me at about, I believe, that it was 7:00 at night. It was before nightshift came in. Yeah.

1900 hours, that's when I became aware.

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

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

29 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q A Q A Q Q A Q A Q Were you aware that there was investigation ongoing into Murphy and that -Yes. And what were you aware of that? That there was an investigation into the -- his use of equipment, hard drive, swapping or cloning a hard drive of a computer. That's -- I intentionally distanced myself from it,

putting first vice president Steve Roff kind of in charge of that aspect because of the conflict of interest between Mr. Murphy and I. Okay. You were aware of deputies modifying county property;

correct? No. You'll have to explain that.

Well, deputies personalize their weapon? Within policy, yeah. Okay. They do things to personalize their vehicle in a variety

of ways; correct? No. You're not aware of any of that? Not of their vehicles, no. Okay. Maybe minor decor. Okay. Going back to the gun thing for a second. Modifying the

gun within policy, what are you referring to? Lights, grips or sights.

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

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

30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q Q Q A A Q Q And your -- your understanding is that the policy allows them to modify lights, grips or sights? Correct. Are you aware of any other modifications being done to weapons other than lights, grips and sights by deputies since 1999 when you started? The only other modification that I can think of is a -- is a suppresser authorized by Chief Chadwick for a member of the SRT, that he has a federal tac stand for it. Okay. (Marked Deposition Exhibit No. 4) (By Mr. Butler) 4. Showing you what's been marked as Exhibit No.

It appears to be an e-mail from you to Steve Cooley on Do you see that?

October 19th, 2011. I see it.

And it indicates that there's a -- that there's three attachments. It says, would you agree that, Attached are the (As

e-mails and other documents that I have per the request. Read). I agree that's what it says. Do you recall the request? I can only assume that it was a public disclosure request because that's the subject line. Okay.

"Murphy Public Disclosure."

Was it your understanding that Steve Cooley was in

charge of public disclosures?

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

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

31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q Q A A Q A Q A Q A Q A A Q Yes. As of October 19th, this was all that you had or why did you get -- do you know why you gave these three items? I -- my assumption again is that it was a -- he had to do a computer search that, typically with a public disclosure request, we'll be told to do a search of documents containing certain words in the parameters that were provided. And then

you save them to an identified folder and then you would forward them onto whomever you were instructed to do. Okay. So is that your understanding of what we have here?

That's my best guess, yes, educated guess. Okay. Do you know if Whatcom County Sheriff's department

maintains a Facebook account? Yes. And have you ever been an administrator on that account? No. Do you know who is? I am guessing that it is Steve Gatterman, but that's just a guess. Have you ever posted anything on the Facebook account? I don't believe that I have. the little like button. Okay. I don't recall ever posting anything on there. Going back to Exhibit 3, just for purposes of reference. How I've -- I've liked things, pushed

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

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

32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q Q A many of those type of meetings have you attended where you have been asked to show up for the suspension of a deputy where they are told to surrender their stuff? That's the only one. (Marked Deposition Exhibit No. 5) (By Mr. Butler) Showing you what's been marked as Exhibit 5,

this appears to me to be an e-mail from Elfo to you that got an auto reply from you. December of 2011? Yes. Okay. The attached is a memo to the personnel file from Elfo Do you Do you recall being out injured in

describing a meeting that you had had on the 15th. recall receiving this? Yes.

Do you recall what specific concerns that Elfo was referring to in getting this to you? Yes. What specific concerns? I was deputy -- Mr. Murphy's supervisor at the time and we were attempting to correct some compliance issues with regard to policy and what's the field operations, guidelines or expectations. Specifically with completion of paperwork, use

of time, communication with supervisors. And the more -- Mr. Murphy became very -- I'm trying to think of the best way to describe it -- difficult and at times

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

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

33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q bizarre with his behavior. The more that we tried to help him

understand that, oh, all that I'm asking is for you to do your job, that's all I ask of you to do. everyone else. No more no less. That's what I expect of

He would reply with -- he would intentionally -- and he admitted that he was making things very very difficult because he felt that he was being micromanaged. At one point, he

pointed to his back and said, there's no saddle on me, you're not going to ride me -- or I don't like being ridden. So it's

my belief that those were the types of concerns that were probably being addressed. That paragraph ends with performance and credibility. I've

heard you talk about paperwork and time and stuff like that. What's -- that would be in the performance category. you working with with regards to credibility? The things that he would say, it would take him, you know, a long time to do the reports or I have got these reports to do. Okay. Well, what are they? Oh, just reports. You need to be What were

specific.

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

then would turn in a report that was very short and very quick to complete. This would not be congruent with all of the

follow-up that he indicated that he needed to do, et cetera. Anything else? Nothing comes to mind any way. What were you aware of with regards to his time with Dr. Ekemo?

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

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

34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q Q A A Q A Q Q A Q A I would need to review the memo. I'm not sure.

Were you aware that he saw Dr. Ekemo? I am -- Mr. Murphy referred to it as a back door psych eval when he was talking to me one day, that he was sent for a back door psych eval. That's my assumption, that Dr. Ekemo or Ekema (Sic) He does the

is our person who does that.

What's your understanding of what Dr. Ekemo does? psych evals? He does the psych evals for the department, yeah. Fit for duties? I did not know that he did that, but yes.

What's your understanding of what a psych eval is if it's not fit for duty? Well, it's your initial hiring psych eval, yeah. is a good way to put it. see if you pass the test. When Murphy went to see Ekemo, were you appraised of the outcome of that at the time? No. Prior to receiving this memo on the 15th or 16th of December, do you recall the last time you had heard about Murphy and Ekemo? No. Did you ever review Ekemo's report? No. It is -- that To

To see if you are fit for duty.

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

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

35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. KAMERRER: EXAMINATION OF KEVIN MEDE BY MR. KAMERRER A A Q Q A Q A Q A Q Q Were you aware of other people in the department that didn't support Elfo in the election in the fall of 2011? Yes. Are you aware of anybody else's credibility that didn't support Elfo being questioned? MR. KAMERRER: THE WITNESS: Objection, vague. Am I aware of anyone who didn't support

Sheriff Elfo, and their credibility being questioned? (By Mr. Butler) Yes.

Is that the question? Yes. No. In your role as guild president, did you hear complaints about Elfo favoritism in the department? Yes. Did you hear complaints of Elfo favoritism in your capacity as guild president from people that you knew not to have supported Elfo in the election? Yes. MR. BUTLER: MR. KAMERRER: I don't have anything further. I have a few questions, sergeant.

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

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

36 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q A Q Q Exhibit 1 is sent to a number of people who are named on the first page. Are those all of the members of the deputy

sheriff's guild at that time? Yes. Okay. The guild ended up voting to endorse a candidate for

sheriff in 2011; is that right? Yes. Who did they endorse? Bill Elfo. And what was the breakdown of the vote percentage wise? I don't recall. Do you recall 75 percent of the deputies voted to endorse? It was a large majority supporting Sheriff Elfo. Okay. No. You're familiar with police officers in other departments in the vicinity, aren't you? Yes. Would you say that it's fairly common for police officers at the deputy or officer rank to have complaints about the administration of their department? Yes. Did you ever believe that the complaints that you heard from people in the Whatcom County deputy sheriff's guild were in any way overwhelmingly negative towards Sheriff Elfo? Have you worked for any other police departments?

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

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

37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A A Q A Q A Q A Q Can you say that again? If --

Well, did you ever have the feeling that the number or the strength of the complaints about the Sheriff Elfo administration among the Whatcom County deputy sheriffs was in some way overwhelming? Only from one person. And who is that? Steve Harris. Okay. Yes. Do you recall what the breakdown on the vote was among the electorates in Whatcom County between Sheriff Elfo and Steve Harris? I believe that it was also overwhelming. that was 76 percent. A landslide? Yes. The e-mail from you to Inspector Cooley and -- was it Lieutenant Chadwick? I believe so. Exhibit 2. Exhibits 2. Is that something you voluntarily initiated to them? Yes. I was irritated that in my professional capacity, he was Is this exhibit -I want to say that Steve Harris is the fellow who ran against Sheriff Elfo?

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

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

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

38 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q Q A Q Q A Q conduct or unethical violations. Were you his supervisor at that time? Yes. So you were concerned that the criticisms that he was making of you could have violated department policy? MR. BUTLER: (By Mr. Kamerrer) Correct. You weren't sending that e-mail to Cooley and Chadwick as a political statement, were you? No. Regarding gun ownership, were you familiar with the sheriff's office or the county's buyback of deputies' duty firearms that was negotiated by the guild some time in the past? Yes. Did that afford deputies the opportunity to be repaid for the duty firearm that they had originally chosen and paid for themselves? Yes. Did you take advantage of that? I did not. Okay. Do you know -- do you have any idea what percentage of Object to the form.

Is that right?

deputies did take advantage of that? No. Okay. When you were with Rossmiller and Murphy was told to

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

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

39 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Q A A Q A Q A A Q A Q A Q turn over his duty firearm on March 2, 2012, did you hear that conversation? Yes. Did you accurately report that conversation in the exhibit that is Exhibit 3 -- or it's part of Exhibit 3? Yes. Okay. Did you see the receipt that Rossmiller showed Murphy to

explain why he needed to turn in his firearm? I did not. Okay. So you didn't recognize it as the typical form that a

deputy would fill out if he or she wanted to have his gun bought back? I did see that it was an evidence and equipment issue receipt, but I did not read the writing on it. Okay. Did you see Murphy's signature on it? I didn't examine it closely.

I saw a signature on it. Okay.

What did Mr. Murphy say, if anything, about the

authenticity or correctness of that receipt? I recall -- I need to -- without looking at my memo, I recall him saying that is my signature, but I don't recall signing it or filling it out. Yeah. Yeah. Feel free. Maybe I didn't put that in. I don't see that in my I can refer to my --

memo, but I independently recall that. Okay. I want to have you turn to Exhibit 4, and this is kind

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

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

40 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A A Q of a housekeeping matter. But on the third page in, I'm going

to direct your attention to a particular sentence that actually is a particular word that I just want to clarify. This memo

that was prepared by you and directed to Deputy Murphy, was that done as the result of an investigation that Murphy apparently had done, but not reported? Yes. Okay. I want to draw your attention to the third paragraph of It's the second to the last sentence where -- and "It was then discovered that no report

Exhibit 4.

I'll quote it.

documenting our activities had been filed." Should that our be your? Either or our representing the sheriff's office -- his representing the sheriff's office or your, it could be. I

believe that I had meant it as our because the BP security staff was upset that the sheriff's office was doing nothing. Okay. And the sheriff's office being Deputy Murphy in his capacity. Was it Murphy who had undertaken that investigation? Yes. Had you been aware of it being conducted near in time to when it was occurring? At the end of the night, he called me and said something to the effect of, I found some trails, talked to security, and briefed me on it. I said okay, great. The assumption being that he

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

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

41 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Q A Q Q would actually document it like most, would be expected. So you anticipated that after your verbal conversation with him about the investigation, he would follow up with a report? Yes. Did he follow-up with a report? No. That's why this memo was prepared documenting the counseling with him about that? Yes. Okay. Did you ever learn or determine that the -- BP officials

were upset about what Deputy Murphy had done relative to that investigation? Yes. And explain that, please? I received a call. at the time. I don't recall if it was Lieutenant Cooley

I received a call from the staff asking about

this investigation on the refinery, because apparently the BP staff had called either the sheriff or undersheriff and asked what was going on. They received word from their security people that the sheriff's office was conducting an investigation on suspicious activity, but they never notified. And when our senior staff

went to look for the report, it wasn't located, so that's how I got it. Exhibit 5, I'm going to draw your attention to the last

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

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

42 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A A Q A Q A Q paragraph on the first page. you a question about it. I'll read that and then I'll ask It

This memo is from Sheriff Elfo.

says, "I further reminded Deputy Murphy that I had arranged a training session with Dr. Ekemo following my receipt of the concerns from the Guild President about his previous bizarre statements and that Dr. Ekemo had cautioned him about damaging his reputation and the reputation of the Sheriff's Office by making such statements." Were you the guild president who had expressed concerns about Murphy's previous bizarre statements? No. Did you know about that expression of concern by the guild president back in 2008? Yes, I was. Who was the guild president at that time? Steve Harris. During the time that you worked with Deputy Murphy, including the time when you were a supervisor of his, did you develop concerns about his mental stability? Yes, I did. What were those concerns based on? Based on his bizarre behavior and his eccentric views on nominal occurrences. Please do. Mr. Murphy was dispatched to a found bicycle in Birch Bay, I can give you an example.

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

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

43 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q long. something we go to quite often. it was during the summertime. I don't recall the date, but I lost track of time. I looked

at the screen and he had been up there for a significant period of time, almost an hour, which is a -- quite a long period of time to retrieve a bicycle. I called Mr. Murphy and asked him what was taking so He said that he was surveilling the bicycle because it I asked him what that meant and he said,

was red and white.

clearly, it was a sign for the Hells Angels for a drop spot or a pick-up point, and that he was going to sit on it a little bit longer to see if any Hells Angels showed up. I instructed him to retrieve the bicycle and immediately take it into the shop to be booked into evidence because that was not a good use of our resources. Is the use of red and white bicycles a known marker of some sort for the Hells Angels? Not that I have ever heard of, no. Did Mr. Murphy ever explain why he thought that that was true? Because he -- he did. He would profer opinions about the Hells

Angels and their proliferation within Whatcom County numerous, numerous times. And that they would use -- if there was a red and white truck -- anything red and white -- a red and white mailbox, that that was a sign that those individuals supported the Hells Angels and that we needed to watch out for them, pay attention.

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

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

44 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q A Q A Q Q A Q Is that something that is known among law enforcement officers, that those colors are significant to the Hells Angels? Those red and white colors are the colors used by the Hells Angels, but not used to mark suspicious or clandestine devices. You've given one example. Are you aware of other examples of

conduct or expressions by Mr. Murphy that caused you to question his mental stability? Yes. Are you aware that he has said that there were black helicopters following him? Yes. Are you aware that he believed that people were trying to tamper with his computer? No. Do you have other examples of situations that he described that you thought were evidence of mental instability? Yes. Can you explain those? When the sheriff's office initiated the Special Response Team in 2005, a sniper class was put on and members from the Quebec federal -- what would be their federal police. I think that

it's -- I'll pronounce it wrong -- but Surete du Quebec attended. t-shirt. When Mr. Murphy saw that, he saw that name, Surete du As a gesture, they gave some of our members a hat or

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

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

45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q Q Quebec, and he was very concerned because members of that agency -- he described a shootout that occurred with Native Americans years ago, and that members of the agency swore to eradicate the planet of that tribe. And that those members They were here to

certainly weren't here for a sniper class.

check on Mr. Murphy and his status of -- as a tribal member. Okay. Did you have any evidence -- were you aware of any

evidence that indicated that Mr. Murphy's suspicions were true? No. Were you aware that he had feelings that there was a volunteer in the sheriff's office who was somehow aligned with the Israeli intelligence organization called Mossad? Yes. Did you hear about that from Murphy himself? No. How about a receptionist or another staff person in the sheriff's office who Mr. Murphy believed was associated with Outlaw motorcycle gangs? Yes. Penny -- I can't remember her last name. He believed

that she was providing information to the Outlaw motorcycle gangs, which is why they were so difficult to catch. He also

told me personally that members of the prosecuting attorney's office were in cahoots with Outlaw motorcycle gangs, which is why cases often don't get prosecuted because of deals happening behind closed doors.

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

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

46 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q Q Mr. Murphy, also as another example, also told me that the reason that no one was stealing the bait car that we had as a bait car program was because -- NICB -- I believe that those are the acronyms -- was also in cahoots with organized theft rings and would identify for these organized theft rings which cars were bait cars and that's why they wouldn't get stolen. Based on those last three incidents, the employee Penny, the prosecutor and Outlaw motorcycle gangs and the bait car, did you ever discover or learn of any factual evidence indicating that those theories of Mr. Murphy were correct? No. Did you ever hear him indicate that he suspected county officers of purchasing property on Lake Whatcom so that drug drops could be arranged there? Yes. South Lake Whatcom.

And what did you hear about that? He would be very vague often in his theories, but he would refer -- he would just say -- he would refer to it as the county. The county, you know, there's big business, there's That's why the county will

big money in these type of things. look to purchase this.

I mean, it's a remote area for drug That type of thing. He would

drops and they all know that.

often not name a specific person. Did you ever learn of any factual information indicating that that theory of Murphy's was true?

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

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

47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q Q A A Q BY MR. BUTLER: Q A The bike in Birch Bay was when? Years ago. It was probably -- I was a supervisor, so it was EXAMINATION OF KEVIN MEDE BY MR. BUTLER have. A Q No. Okay. MR. KAMERRER: Thank you. MR. BUTLER: Let me just follow-up on a couple. That's all of the questions that I

probably 2008 or nine. Are you aware that he was tribal member of the -- I don't know how to pronounce it either -- from the Quebec police shootout? I believe that he said that. then. Okay. I knew that he was part Native American, but I didn't know what tribe or anything like that. Okay. Prior to the deposition, did you do anything to prepare I wasn't aware of that before

for today's dep? (Witness Indicating). Did you do anything to prepare for the deposition? I -Review documents, meet with people, have discussions?

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

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

48 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q Q Q A Q A No. I had the meeting with Prosecutor Gallery two weeks ago, a

week ago. Any other meetings or conversations? No. Anything that I didn't ask you that you expected, based on your preparation that you would be asked to discuss today? MR. KAMERRER: speculation. the question. THE WITNESS: (By Mr. Butler) No. I'll insert an objection. It calls for

It's argumentive.

Nevertheless, you can answer

With regard to Penny Goodman, you were aware

that he was assigned to do that investigation; right? No. You weren't aware of that? No. Okay. I was not. Would it change your opinion if he was assigned and

actually conducted an investigation as to whether or not it was a bizarre theory of his? MR. KAMERRER: calls for speculation. MR. BUTLER: MR. KAMERRER: I don't think it calls for speculation. It's extremely vague. You haven't even I want to insert an objection. It

identified the subject of that investigation. (By Mr. Butler) Did you understand I was talking about the

Penny Goodman investigation?

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

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

49 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q Q A Q A or no. (By Mr. Butler) I can answer it. Go ahead. If Mr. Murphy offered up information that he believed to be true and presented it and the staff said, whoa, we should look into this, go ahead and run with it, then I would say yes. That it's bizarre still. But if it was something that came Okay. A Q Yes. Okay. Would it change your opinion that it was bizarre if you

learned that it was assigned and he was doing what he was assigned to do? MR. KAMERRER: THE WITNESS: Objection, argumentative. It's a more complicated answer than yes

down from somebody who, I believe, had more of a credible foundation, then it wouldn't be. Yup. Okay. Penny Goodman still work for the sheriff's department? I don't know. Not for the headquarters, I mean. Does that make sense?

She was a receptionist -- is she still a receptionist down there? Not here, no. I don't know if she went to alternative

corrections or anything like that. MR. BUTLER: Okay.

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

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

50 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Signature Reserved) (Deposition Adjourned)

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

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

51 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 __________________________ Kristen M. Uhlig, #1934 Certified Court Reporter, Residing in Clinton, Washington. I further certify that the deposition, as transcribed, is a full, true, and accurate transcript of the testimony, including all questions and answers, and all objections, motions and exceptions of counsel made and taken at the time of the foregoing examination; I further certify that I am sealing the deposition in an envelope with the title to the above cause thereon and marked "Deposition Upon Oral Examination" of said witness and promptly causing the same to be delivered or forwarded to Counsel for the Opposing Party; IN WITNESS THEREOF, I have hereunto set my hand and affixed my official seal this ___ day of____________, 2014. I further certify that all of the objections made at the time of said examination to my qualifications or the manner of taking the deposition, or to the conduct of any party, have been noted by me upon said deposition; I further certify that I am not a relative or employee or attorney or counsel of any of the parties to said action or counsel, and that I am not financially interested in the said action or the outcome thereof; I further certify that the witness examined, read, and signed the deposition after the same was transcribed, unless indicated in the record that the parties and the witness waive the signature; That the annexed and foregoing deposition of the witness named herein was taken stenographically before me and transcribed by me; STATE OF WASHINGTON ) ) COUNTY OF ISLAND ) ss. C E R T I F I C A T E

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

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

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

Page 52
A ability 5:18 accepted 13:21 account 31:13,15 31:20 accurate 51:15 accurately 39:4 accusations 27:12 27:22 accusing 37:25,25 acronyms 46:4 acting 25:18,19 action 51:12,13 activities 40:11 activity 9:17 41:22 actual 18:23 ad 16:5 adamant 11:12 addressed 33:11 Adjourned 50:2 administration 13:14 17:12 36:21 37:4 administrator 31:15 admitted 33:6 Adrian-Stavik 2:15 advantage 38:20,23 adversarial 16:25 advocate 18:2 affixed 51:20 afford 38:16 agency 45:2,3 ago 11:21 45:3 47:11 48:1,2 agree 23:20 30:17 30:20 agreed 28:18 Ah 4:19 ahead 7:17 19:18 27:19 49:10,13 aided 26:14 alcohol 5:22 aligned 45:11 allowed 28:8 allows 30:1 alternative 49:23 American 47:18 Americans 45:3 analogy 16:22 Angels 43:9,11,16 43:20,25 44:2,4 angry 11:10 animosity 27:12,14 annexed 51:5 answer 5:19 7:10 7:11 8:9,10,11 9:11,25 10:18 22:5 48:8 49:6,9 answers 9:17 51:15 anticipated 41:2 anybody 5:5,14 7:6 35:4 apparently 40:6 41:17 appear 22:14 24:19 appearing 22:11 appears 23:19 24:12 30:13 32:7 appraised 34:17 approach 17:12 appropriate 7:3 27:11 area 46:21 argumentative 10:1 49:5 argumentive 48:8 arranged 28:2 42:3 46:14 arrangements 25:24 ascertain 24:6 asked 25:21 32:2 41:18 43:6,8 48:6 asking 7:18 15:25 26:24 33:2 41:16 asks 27:5 aspect 29:9 assigned 48:12,16 49:3,4 assistant 14:12 associate 5:13 associated 22:15 45:17 assume 23:4 30:22 assumption 21:9 31:4 34:5 40:25 attached 20:2 23:22 24:15 30:17 32:11 attachments 30:17 attempting 32:20 attended 32:1 44:23 attention 40:2,8 41:25 43:25 attorney 4:18,22 5:4 19:10,16 51:12 attorney's 45:22 attribute 17:5,6 August 4:13 authenticity 39:18 authority 22:11 authorized 30:8 auto 32:8 Avenue 1:21 2:12 aware 5:15,16,17 7:5 19:1 20:11 23:14,15 28:21,25 29:1,4,11,19 30:4 33:25 34:2 35:1,4 35:7 40:21 44:5,9 44:12 45:7,10 47:13,15 48:11,14 B back 15:18 18:15 29:23 31:25 33:8 34:3,4 39:12 42:13 bad 21:22 bait 46:2,3,6,8 banter 23:17 bargaining 12:12 based 9:16 13:21 14:5 21:15,16 42:21,22 46:7 48:5 Bay 42:25 47:10 behavior 33:1 42:22 behaviors 11:12 belief 27:22 33:10 believe 5:5 11:10 13:10 19:15 20:24 21:3 22:1 23:17 26:3,18 28:23 31:21 36:23 37:14 37:20 40:15 46:3 47:15 49:15 believed 44:12 45:17,19 49:11 believes 13:9 Bellingham 1:22 2:5,13 belt 28:14 Beschen 2:3 5:13 best 16:22 21:15 23:13 31:11 32:25 better 5:19 10:3,18 bicycle 42:25 43:5 43:7,12 bicycles 43:15 big 21:6,16,16 46:19,20 biggest 18:2 bike 47:10 Bill 36:9 Birch 42:25 47:10 bit 43:11 bizarre 33:1 42:5 42:10,22 48:18 49:2,14 black 44:9 Blvd 2:8 board 13:6,12 14:4 14:11 Bogdanovich 2:8 booked 43:13 bookkeeping 12:25 bottom 20:12,20 21:12 27:4 bought 39:12 BP 40:15 41:10,17 breakdown 36:10 37:11 briefed 40:24 bring 13:10 brought 9:2 bucking 27:25 building 25:14,23 business 46:19 Butler 2:3,4 3:4,6 4:7,20,21 5:1 7:13 7:19 8:3 9:16 10:8 14:23 15:2,7,9,23 18:3 19:22,24 22:25 24:7,11 28:4 30:12 32:6 35:9,20 38:6 47:5 47:7,9 48:11,21 48:24 49:8,25 button 31:22 buyback 38:13 C C 2:1 51:1,1 CAD 26:12,17 cahoots 28:1 45:23 46:4 call 28:8 41:15,16 called 4:2 28:23 40:23 41:18 43:6 45:12 calls 7:8,17 9:14 17:25 19:18 24:3 27:18 48:7,20,21 campaign 20:3 21:18,24 22:9 candidate 36:5 capacity 8:24 9:6 19:16 35:16 37:24 40:18 car 26:15 46:2,3,8

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

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

Page 53
cars 46:6,6 cases 45:24 catch 45:21 category 33:14 cause 10:25 17:6 51:17 caused 44:6 causing 51:18 cautioned 42:6 CC'ed 21:1 CCR 1:24,24 51:4 certain 31:7 certainly 45:5 Certified 1:24 51:23 certify 51:4,7,9,12 51:14,17 cetera 13:14 28:2 33:22 Chadwick 20:22,23 25:6,11,14,21 28:18,23 30:8 37:19 38:9 challenged 17:24 change 9:25 48:16 49:2 changes 17:17 charge 13:3,4 29:8 30:25 check 9:1 13:4 45:6 Chief 20:2,6 25:5 25:11,13,21 28:23 30:8 chosen 38:17 circle 8:23 claimed 27:24,25 claiming 22:10 clandestine 44:4 clarify 40:3 class 44:20 45:5 clean 20:19 21:12 clear 16:2 clearly 18:2 43:9 Clinton 51:24 cloning 29:6 closed 45:25 closely 39:16 collaborative 16:23 Collins 28:9,9,10 28:11 colors 44:2,3,3 come 10:3 25:22 28:4 comes 28:7 33:24 coming 21:16 22:4 commercial 22:11 commitments 8:22 committee 13:5,7,8 13:11,19,23 14:8 14:19 committee's 14:16 common 36:19 communication 14:15 32:23 community 1:10,15 complaints 35:13 35:16 36:20,23 37:3 complete 33:21 completed 10:6 completion 32:22 compliance 32:20 complicated 49:6 complying 21:14 compromised 5:18 computer 15:11 25:22 26:14,16 29:7 31:5 44:13 concern 9:19 10:12 42:12 concerned 38:4 45:1 concerns 8:19 32:15,18 33:10 42:5,9,19,21 conduct 38:1 44:6 51:10 conducted 40:21 48:17 conducting 41:21 conflict 29:9 confronted 10:7 congruent 33:21 contacted 28:10 containing 31:6 contiguously 6:14 contract 12:13 13:10 conversation 21:17 26:9 39:2,4 41:2 conversations 23:16 48:3 conveyed 14:18 Cooley 10:20 20:2 20:6,23 21:2 24:12 25:6,8 30:13,24 37:18 38:9 41:15 Cooley's 20:16 copy 20:2 23:22 corner 5:10 correct 4:16,17,22 5:7 9:4 10:11 12:17 16:3,5,8 18:5,9,16,25 20:9 21:20,25 22:21 28:15,16,20 29:12 29:17 30:3 32:20 38:8 46:10 corrections 49:24 correctly 9:11 21:4 28:8 correctness 39:18 cost 14:6 counsel 4:16 14:23 51:12,13,16,18 counseling 11:11 11:13 41:7 count 21:20 county 1:13,13,21 2:7,11,12 4:11,15 10:10,12 19:11,14 24:23 29:11 31:12 36:24 37:4,12 43:20 46:12,19,19 46:20 51:3 county's 19:20 38:13 couple 12:7 47:5 course 10:15 court 1:7,24 5:14 9:2 51:23 Courthouse 1:21 crazy 25:2 credibility 7:6,13 7:19,21 9:21 10:5 10:22 33:12,15 35:4,8 credible 8:11 10:24 49:15 criticisms 38:4 CSR 1:24 curious 27:7 delivered 51:18 dep 47:21 department 1:14 2:7 7:5,6 9:7 13:15 31:12 34:9 35:1,14 36:21 38:5 49:19 departments 36:14 36:16 depending 14:1 depends 14:20 deposition 1:17 4:15 5:25 7:9 14:23 15:3,8 19:23 24:10 30:11 32:5 47:20,23 50:2 51:5,8,10,11 51:14,17,18 depositions 15:6 D deputies 12:16 D 3:1 13:18 17:17 23:17 Dale 2:7 24:8 29:11,14 damaging 42:6 30:5 36:12 38:16 Dan 19:9,15 38:23 Daniel 2:8 deputies' 38:13 data 26:15 deputy 6:18 7:14 date 24:6 43:1 7:14 8:19 9:6 21:5 dated 3:10,11,12,13 21:8 22:15 25:18 3:14 24:20 27:4 28:8,9,10 dates 15:18 32:2,19 36:2,20 day 5:20 28:19 34:4 36:24 37:4 39:11 51:20 40:4,18 41:11 days 23:12 42:3,17 deals 45:24 describe 32:25 December 15:13 described 44:15 17:6 23:4 32:9 45:2 34:20 describing 32:12 decide 14:3 DESCRIPTION decides 13:11 3:9 decision 14:1,5,6 determine 41:10 decor 29:22 develop 42:18 Defendants 1:15 devices 44:4 2:7 different 26:21 defense 19:21 Differing 9:17 define 7:21 difficult 32:25 33:6

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

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

Page 54
45:21 direct 4:5 40:2 directed 21:13 25:6 26:3 40:4 direction 25:3 directly 14:19 disagreement 28:13 disclosure 3:13 10:5,9 30:22,23 31:5 disclosures 9:18 30:25 discover 46:9 discovered 40:10 discovery 4:14 5:25 discuss 48:6 discussions 47:25 dispatch 26:14 dispatched 42:25 displayed 11:12 disputed 11:10 disqualified 27:15 disqualify 27:20 distanced 29:7 DISTRICT 1:7,8 document 19:25 41:1 documenting 40:11 41:7 documents 9:23 10:13 30:18 31:6 47:25 doing 40:16 49:3 door 34:3,5 doors 45:25 doubts 9:15 Doug 20:22,23 Dr 33:25 34:2,5,7 42:4,6 draw 40:8 41:25 drive 29:6,6 driving 25:2 drop 43:9 drops 46:14,22 drug 46:13,21 drugs 5:22 du 44:22,25 duly 4:2 duties 34:10 duty 22:10 27:10 28:14 34:13,15 38:13,17 39:1 Elizabeth 2:11 else's 35:4 Emily 2:3 5:13 employed 4:10,12 employee 6:8 9:6 46:7 51:12 employment 6:9 ended 36:5 endorse 36:5,8,12 E ends 33:12 E 2:1,1 3:1 51:1,1 enforcement 44:1 e-mail 3:10,11,12 enjoy 17:17 3:13,14 15:13,17 entity 1:13 17:11 20:2,6,11 envelope 51:17 20:12 24:2,12 equipment 29:6 30:13 32:7 37:18 39:13 38:9 eradicate 45:4 e-mails 20:11 30:18 et 13:14 28:1 33:22 East 2:4 eval 34:3,5,12,14 eccentric 42:22 evals 34:8,9 educated 31:11 evening 24:16 25:7 effect 40:24 25:9 either 40:13 41:18 event 11:10 47:14 everybody 13:15 Ekema 34:5 23:14 Ekemo 33:25 34:2 evidence 25:14,22 34:5,7,17,22 42:4 39:13 43:13 44:16 42:6 45:7,8 46:9 Ekemo's 34:24 evil 17:13 elect 14:9 exactly 25:5 elected 12:20 13:19 examination 1:17 18:4,6 23:1 3:3 4:5 35:23 47:7 election 3:10 15:14 51:10,16,18 16:3 22:22,23,25 examine 39:16 35:2,18 examined 4:3 51:7 elections 18:13 example 42:23 44:5 electorates 37:12 46:1 Elfo 1:14 2:7,15 5:6 examples 10:4 44:5 16:2,7 20:4,7 44:15 21:18,24 22:9 exceptions 51:15 23:15 28:1 32:7 executive 13:12 32:11,15 35:2,5,8 14:4,11 35:14,16,18 36:9 exhibit 3:9 15:8,9 36:13,25 37:3,9 19:23,24 24:10,11 37:12 42:2 24:19 30:11,12 31:25 32:5,6 36:1 37:20,21 39:4,5,5 39:25 40:9 41:25 exhibits 15:3 20:10 37:22 expect 33:3 expectations 32:22 expected 41:1 48:5 explain 8:8,19 11:9 15:24 16:1 29:13 39:8 41:14 43:18 44:18 expressed 42:9 expression 42:12 expressions 44:6 extremely 48:22 financially 51:13 fine 15:3 firearm 38:17 39:1 39:8 firearms 38:13 firm 5:13 first 4:2 6:22 13:2,3 13:5 14:12 20:12 20:15 22:15 23:15 24:15 29:8 36:2 42:1 fit 34:10,13,15 flipping 22:6 Flynn 7:14,20 folder 31:8 follow 24:7 41:3 follow-up 33:19,22 F 41:5 47:5 F 51:1 following 21:22 face 10:4 42:4 44:10 Facebook 20:17 follows 4:3 31:13,20 foregoing 51:5,16 factors 14:6,8 17:9 form 8:8 38:6 39:10 factual 46:9,24 formally 14:5 fair 26:8 forward 13:13 14:7 fairly 36:19 25:7 31:9 fall 35:2 forwarded 51:18 false 10:6 27:12,21 fought 17:16 familiar 36:16 found 40:24 42:25 38:12 foundation 49:16 far 16:23 fourth 16:11 24:19 favoritism 35:14,16 free 39:22 federal 9:2 30:9 Freeman 9:7 11:3,6 44:21,21 full 51:15 Feel 39:22 functioning 14:12 feeling 11:15 37:2 functions 12:22 feelings 45:10 further 35:20 42:3 fellow 37:9 51:7,9,12,14,17 felt 33:7 G field 32:21 fight 17:19 Gallery 2:11 5:1 file 13:13 32:11 19:9,15 48:1 filed 40:11 gangs 45:18,21,23 fill 39:11 46:8 filling 39:21 gap 23:5,7,9,10

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

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

Page 55
Gatterman 31:18 generally 13:24 gesture 44:23 getting 8:8 32:16 Gibson 19:9,15 give 42:23 given 14:8 27:12 44:5 go 7:17 14:18 15:2 19:18 22:13 27:19 43:1 49:10,13 goes 20:13 going 6:2 7:14 9:5 20:10 21:6,7,17 25:24 26:8 28:21 29:23 31:25 33:9 40:1 41:19,25 43:10 good 4:8 17:5 34:15 43:14 Goodman 48:11,25 49:19 government 1:13 Grand 1:21 2:12 great 40:25 grievance 13:5,7,8 13:9,11,13,19,23 14:3,8,8,16 grieve 14:5,9 17:15 grips 29:25 30:2,5 group 12:13 13:8 guess 22:8 31:11,11 31:19 guessing 11:18 31:18 guidelines 32:21 guild 9:17 10:14 11:22,23,24 12:5 12:9,11,12,18,22 13:15,18 14:15 16:15,19 17:14,23 18:3,4,10,20 19:10,11 22:21 23:1,2,7 25:12 26:24 27:1,9 28:2 28:5 35:13,17 36:3,5,24 38:14 42:5,9,12,15 guise 10:14 gun 28:13,19 29:23 29:24 38:12 39:11 gut 11:15 Inspector 25:6,8 37:18 instability 44:16 instant 26:15 instructed 31:9 43:12 intelligence 45:12 intentionally 29:7 H I 33:5 half 20:20 21:12 idea 38:22 interchangeably halfway 20:1 identified 31:8 26:22 hand 51:20 48:23 interest 29:9 handed 28:10,16 identifiers 20:1 interested 51:13 handle 14:21 identify 9:20 46:5 interests 19:13 happen 28:21 illegal 22:16 interloper 18:15 happened 26:2 immediately 43:12 internal 12:18 happening 45:24 inappropriate 27:1 internet 24:5 happens 13:24 27:8 28:5 37:25 investigation 9:6 hard 24:6 29:6,6 incident 9:1 11:5 29:1,5 40:5,19 Harris 9:10,15 12:7 incidents 46:7 41:3,12,17,21 12:10 15:18 16:7 included 20:23 48:12,17,23,25 17:21 23:3 37:8,9 including 42:17 irrelevant 19:18 37:13 42:16 51:15 irritated 37:24 Harris' 9:20 17:11 independently 20:8 ISLAND 51:3 hat 44:23 39:24 Israeli 45:12 header 24:24 indicate 46:12 issue 3:10 11:8,14 headquarters indicated 4:21 11:15,16 15:14 49:20 33:22 45:8 51:8 21:17 22:8,8,9,10 hear 5:18 35:13,16 indicates 20:22 39:13 39:1 45:14 46:12 30:16 issues 32:20 46:16 indicating 46:9,24 items 31:3 heard 33:13 34:21 47:22 J 36:23 43:17 individuals 18:23 held 11:24 43:24 J 1:14 helicopters 44:10 influence 5:22 January 22:21 23:1 Hells 43:9,11,16,19 information 6:2,3 Jason 14:21 43:24 44:2,3 10:6 24:5,8 45:20 Jeremy 11:3 help 33:1 46:24 49:11 job 19:7 33:3 helps 13:6 initial 34:14 Johnson 2:8 hereunto 51:20 initiated 37:23 K hey 21:13 44:19 Kamerrer 2:7,8 3:5 hierarchy 14:14 injured 32:8 4:18,21,23,24 7:8 hire 6:16 inner 8:22 7:16 8:2 9:13 10:1 hiring 34:14 insert 7:16 9:13 14:25 15:5,20 hold 12:1 19:17 48:7,19 17:25 19:9,17
BMA Court Reporters, (425) 252.7277 3206 Wetmore Avenue, Suite 12 - Everett, Washington 98201

Holly 2:4 home 25:25 28:18 honest 8:22 honesty 11:15 hour 43:4 hours 28:25 housekeeping 40:1

22:24 24:3 27:18 35:6,21,23,25 38:7 47:3 48:7,19 48:22 49:5 keep 15:25 keeping 8:21 keeps 13:1 Kevin 1:18 4:1,9 35:23 47:7 kind 29:8 39:25 knew 21:8 35:17 47:18 know 4:19 5:2,4,8 5:11 6:5,7 11:7,14 12:12 14:25 17:15 24:16 25:9 26:3 31:3,12,17 33:16 34:11 38:22 42:12 46:19,22 47:13,18 49:20,23 knowledge 12:11 26:17 known 18:20 43:15 44:1 Kristen 1:23 51:4 51:23 L labeling 17:10,13 Lake 46:13,15 landslide 37:16 laptop 26:21 large 36:13 Larson 11:11 Lastly 22:20 latest 23:18 law 2:4,8 44:1 Laymen's 12:14 lead 27:22 leading 27:19 learn 41:10 46:9,24 learned 49:3 leave 14:24 left 6:13 let's 19:25

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

Page 56
mark 44:4 marked 15:8,9 19:23,24 24:10,11 30:11,12 32:5,6 51:17 marker 43:15 matter 4:15 6:5 9:3 9:8 13:11 14:5,7 40:1 MDT 26:19 mean 19:2 23:10,22 46:21 49:20 means 26:14 meant 40:15 43:8 Mede 1:18 4:1,9 7:3 35:23 47:7 meet 25:14,23 47:25 meeting 13:1 21:5 28:13 32:12 48:1 meetings 32:1 48:3 member 11:23 13:9 14:9 30:8 45:6 47:13 members 36:2 44:20,23 45:1,3,4 45:22 memo 3:12 24:15 24:20,23,24 25:4 25:7,10 26:6 32:11 34:1,20 M 39:19,24 40:3 M 1:23 51:4,23 41:7 42:2 M-E-D-E 4:9 memory 26:9 mailbox 43:23 mental 42:19 44:7 maintains 31:13 44:16 majority 36:13 message 25:21 making 7:10 14:6 26:12,15,16,16 33:6 38:4 42:8 messages 26:17 management 14:15 micromanaged 14:19 17:24 33:7 manner 51:10 mind 28:4,7 33:24 March 1:20 4:14 minor 29:22 12:4,5 24:13 39:1 minute 15:15 16:1 marital 1:10,14 23:6 lieutenant 20:24 25:11 37:19 41:15 life 8:21 lights 29:25 30:2,5 liked 31:21 line 6:22 13:17 30:23 little 26:4 31:22 43:10 Liz 5:1,2 19:15 located 41:23 log 11:10 logs 11:19 lone 17:23 18:1 long 4:12 8:6 10:3 18:6,10 33:17 43:4,7 longer 43:11 look 11:18 15:15 20:10 21:11 41:23 46:21 49:12 looked 43:2 looking 15:18 20:15,19 22:5,6 39:19 looks 20:18,21 lost 43:2 lot 19:2 lots 17:20 33:19 Lyman 2:8 observations 25:7 obtain 6:2 occurred 45:2 occurrences 42:23 occurring 40:22 October 20:6 30:14 31:2 offered 49:11 office 2:12 4:11 5:11 6:8,13 11:24 12:1 25:2 38:13 40:13,14,16,18 41:21 42:7 44:19 45:11,17,23 officer 8:24 36:20 officers 12:18,22 36:16,19 44:1 46:13 Offices 2:4 official 51:20 officials 41:10 oh 15:2 17:8 23:17 23:18,18 33:2,18 okay 4:14,20 5:6 6:5,9,16 7:5 9:3 9:16 10:17,20 11:17,20,22 12:11 12:24 13:7,23 14:14,18,22 15:7 15:23 16:7 17:23 18:3,18 19:1,6,8 19:15,22 20:10,15 20:19,22 21:11,18 21:22 22:13,20 24:7 25:2,2,12 26:1,11,17,19,23 O 29:11,16,21,23 Object 7:8 38:6 30:10,24 31:10,12 objection 7:9,17 31:23 32:11 33:18 8:2 9:14 10:1 36:5,14 37:9 15:20 17:25 19:17 38:22,25 39:7,10 N 22:24 27:18 35:6 39:15,17,25 40:8 N 2:1 3:1 48:7,19 49:5 40:17,25 41:10 name 4:8,23 15:10 objections 51:9,15 45:7 47:2,17,20 22:14 44:25 45:19 objective 27:15,21 48:16 49:2,8,18 minutes 13:2 misusing 22:10 Mm-hm 15:12 16:13 17:2 22:19 26:20 mobile 26:14 modification 30:7 modifications 30:4 modify 30:2 modifying 29:11,23 money 46:20 months 10:19,19 12:7 23:12 morning 4:8 Mossad 45:12 motions 51:15 motive 17:14 motorcycle 45:18 45:20,23 46:8 Moving 9:10 10:20 MTDs 26:14 multiple 18:13 19:25 Murphy 1:10 3:11 3:13 4:15 6:5 21:5 22:16 23:14 24:5 25:19,21,24 26:23 27:4,22,23 28:10 28:16 29:1,10 30:23 32:24 34:3 34:17,21 37:25 38:25 39:7,17 40:4,5,18,19 41:11 42:3,17,25 43:6,18 44:6,25 45:6,14,17 46:1 46:10 49:11 Murphy's 20:3 32:19 39:15 42:10 45:8 46:25 46:23 named 6:2 36:1 51:6 names 7:15 Native 45:2 47:18 near 40:21 need 17:18 33:18 34:1 39:19 needed 25:14 33:22 39:8 43:25 needs 17:16 25:22 negative 36:25 negotiate 12:13 negotiated 38:14 never 11:12 41:22 Nevertheless 48:8 NICB 46:3 night 25:16,16 28:24 40:23 nightshift 28:24 nine 47:12 nominal 42:23 normal 14:12,14 noted 51:10 notes 13:2 26:5 notified 41:22 November 6:13,22 number 14:6 15:6 17:9 27:2,7,8 36:1 37:2 numbering 14:24 numbers 18:23,24 numerous 27:25 43:20,21 Nyhus 8:1 14:21

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

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

Page 57
49:25 on-the-job 8:24 ongoing 29:1 operating 21:8 operations 32:21 opinion 7:18,19 9:12 17:9,20,21 27:14 48:16 49:2 opinions 43:19 opportunity 38:16 opposed 7:15 Opposing 51:19 Oral 1:17 51:18 organization 45:12 organized 46:4,5 originally 38:17 outcome 34:18 51:13 Outlaw 45:18,20,23 46:8 oversees 13:6 overwhelming 37:5 37:14 overwhelmingly 36:25 ownership 38:12 paralegal 5:10 parameters 31:7 Parks 11:1 part 39:5 47:18 particular 40:2,3 parties 51:8,12 party 51:10,19 pass 34:16 paste 20:3 23:23 patrol 25:12,13 27:10 Paul 1:10 6:5,7 22:15 pause 8:6 pay 43:25 Penny 45:19 46:7 48:11,25 49:19 people 35:1,17 36:1 36:24 41:20 44:12 47:25 percent 36:12 37:15 percentage 36:10 38:22 perception 5:18 11:7,14,16 perform 12:22 P performance 33:12 P 2:1,1 33:14 package 15:5 period 10:3 18:11 page 3:3,9 10:9 18:11 43:3,4 19:25 20:1,15,19 periods 6:15 20:20 21:11,12,19 person 34:6 37:6 21:20 22:6,13,15 45:16 46:23 22:20 24:15,19 personal 7:13,18,19 26:23 36:2 40:1 8:21 9:12 42:1 personality 17:11 pages 21:22,23 22:2 personalize 29:14 24:24 29:16 paid 38:17 personally 27:11 paperwork 32:22 45:22 33:13 personnel 32:11 paragraph 16:11 phone 28:10 16:12 26:12 33:12 Phrase 9:11 40:8 42:1 pick-up 43:10 picturing 16:23 place 11:17 plaintiff's 15:3 Plaintiffs 1:11 2:3 planet 45:4 please 4:8 41:14 42:24 point 17:9 33:7 43:10 pointed 33:8 police 36:14,16,19 44:21 47:14 policy 29:15,24 30:1 32:21 38:5 political 38:10 position 6:17 27:23 post 24:5 posted 31:20 posting 31:24 posts 22:6,14 preceding 17:3 preparation 48:6 prepare 47:20,23 prepared 40:4 41:7 prescriptions 5:22 present 2:14 4:16 13:12 14:4 presented 49:12 president 10:14 12:2,3,5,8,9 13:2 13:3,4,5,6,6,22 14:11,11,18,20,21 18:3,10 22:21 23:1,2,8 29:8 35:13,17 42:5,9 42:13,15 previous 42:5,10 print 20:11 21:20 23:19 printed 15:11 21:24 22:7 printout 21:23 22:2 22:13 Prior 34:20 47:20 probably 19:9 21:19 23:13,25 33:11 47:11,12 problems 7:7 profer 43:19 professional 37:24 program 46:3 proliferation 43:20 promotion 6:22 27:25 promotions 6:19,21 6:24 promptly 51:18 pronounce 44:22 47:14 property 29:11 46:13 propose 17:18 proposed 17:18 prosecuted 45:24 prosecuting 45:22 prosecutor 46:8 48:1 prosecutor's 2:12 5:11 protect 12:12 provided 10:15 22:14 31:7 providing 45:20 psych 34:3,5,8,9,12 34:14 public 3:13 9:18 10:5,9 30:22,23 30:25 31:5 published 18:21,23 purchase 46:21 purchasing 46:13 pure 17:8 purposes 31:25 push 13:13 pushed 31:21 put 34:15 39:23 44:20 putting 29:8 Q qualifications 51:10 Quebec 44:20,22 45:1 47:14 question 7:10,11,24 9:11 10:3,25 11:2 21:22 35:10 42:2 44:7 48:9 questioned 35:5,8 questions 5:19 8:3 11:4 15:25 35:21 47:3 51:15 quick 26:11 33:20 quite 8:9 43:1,4 quote 40:10 R R 2:1 51:1 ran 16:9 37:9 rank 6:22 7:1,15 25:19 36:20 ranks 21:8 re-address 22:5 read 30:19 39:14 42:1 51:7 reading 21:21 28:8 real 21:16 26:11 really 21:16,22 24:23 reason 5:17 15:10 17:21 19:8 21:3 46:2 reasons 16:11 17:20,22 27:2,7,8 28:4 recall 18:11 20:6,8 21:12 22:18 23:3 23:16,22 24:4 25:3,5,17 26:23 30:21 31:24 32:8 32:13,15 34:21 36:11,12 37:11 39:19,19,20,24 41:15 43:1 receipt 39:7,13,18

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

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

Page 58
42:4 received 24:8 25:3 41:15,16,20 receiving 32:13 34:20 receptionist 45:16 49:21,21 recognize 15:13,17 20:15 24:13,20 39:10 recollection 9:24 21:15 23:13 record 4:8 7:10 51:8 red 43:8,15,22,23 43:23 44:3 refer 7:3 39:21 46:18,18 reference 31:25 referencing 20:2 referred 22:3 34:3 referring 10:8 16:18 21:10 29:24 32:15 refinery 41:17 refresh 9:24 refused 10:14 regard 8:24 9:20 11:6 17:10,10 32:20 48:11 regarding 11:4 15:14 20:7,16 21:6 24:15 28:13 38:12 regards 7:5 8:19 14:16 21:11 33:15 33:25 related 9:17 22:3 relationship 11:22 16:14,19,23 19:10 relationships 16:2 relative 41:11 51:12 release 10:15 relevant 6:4 relied 26:5 remember 45:19 reminded 42:3 remote 46:21 repaid 38:16 replaced 12:6,9 reply 32:8 33:5 report 33:20 34:24 39:4 40:10 41:3,5 41:23 reported 1:23 40:6 reportedly 10:6 reporter 1:24 5:14 51:23 reports 33:17,17,18 represent 15:10 19:11 27:12 representative 27:24 represented 5:5 12:13 representing 19:13 40:13,14 reputation 42:7,7 request 10:6,9,12 30:18,21,22 31:6 requested 3:12 27:10 Reserved 50:1 Residing 51:24 resolve 13:13 resources 43:14 response 20:12,16 44:19 result 15:18 40:5 retained 26:17 retrieve 43:5,12 review 9:23 13:24 34:1,24 47:25 reviewed 23:21 reviews 13:11,23 ridden 33:9 ride 28:18 33:9 right 5:1 18:24 19:22 22:20 36:6 38:7 48:12 righteous 14:3 rights 12:12 rings 46:5,5 roadside 23:16 Robert 2:3,4 Roff 8:15 29:8 role 12:11,25 35:13 room 5:14 Rossmiller 25:11 38:25 39:7 roughly 17:3 round 19:3 run 49:13 running 16:7 RW 2:8 14:12 security 40:15,24 41:20 see 6:3 16:12,13,16 16:17 20:1,5 21:7 22:16,17 24:17,18 27:2,6 30:14,15 34:15,16,17 39:7 39:13,15,23 43:11 seen 23:18 self-appoint 13:19 self-initiate 21:14 self-initiated 21:15 send 25:21 26:15 sending 20:6 38:9 senior 41:22 sense 5:17 49:16 S sent 15:13 20:22 S 2:1 21:2,13 24:2 saddle 33:8 25:24 26:12 34:4 sat 10:2 36:1 Saturday 23:19 sentence 16:14,16 24:1,1 40:2,9 save 31:8 separate 19:11 saw 34:2 39:16 sergeant 6:22 7:3 44:25,25 11:11 25:13,16,18 saying 25:22 39:20 26:25 27:11 35:21 says 14:4 16:11 Sergeants 13:18 22:15,20 23:22 session 11:11 42:4 26:12,23 30:17,20 set 51:20 42:3 sheriff 5:6 6:18 schedule 17:17 14:19 16:15,19 scheduled 25:13 19:16 28:1 35:8 screen 43:3 36:6,13,25 37:3,9 scrutiny 27:21 37:12 41:18 42:2 seal 51:20 sheriff's 1:14 2:7 sealing 51:17 4:11 6:8,13 7:5,6 search 31:5,6 8:24 9:7 13:15 SEATTLE 1:8 31:12 36:3,24 second 13:2,4,21 38:12 40:13,14,16 14:20 16:14 22:20 40:18 41:21 42:7 24:19 26:1,5,12 44:19 45:11,17 26:23 28:21,22 49:19 29:23 40:9 sheriffs 37:4 secretary 13:1 shift 6:14 17:17 25:16 26:25 shootout 45:2 47:14 shop 43:13 short 33:20 show 32:2 showed 39:7 43:11 Showing 15:9 19:24 24:11 30:12 32:6 Sic 34:6 sick 25:17 sights 29:25 30:2,5 sign 43:9,24 signature 39:15,16 39:20 50:1 51:8 signed 51:7 significant 14:7 18:11 43:3 44:2 signing 39:20 single 17:15 sit 43:10 site 28:9 situations 44:15 six 23:12 skeptical 9:1 small 23:9,10 snap 23:20 sniper 44:20 45:5 somebody 49:15 sorry 14:14 21:21 22:21 sort 28:18 43:16 sour 16:20,21,22 17:3,6,7,20 soured 16:15 17:21 souring 17:5 South 46:15 Special 44:19 specific 32:15,18 33:19 46:23 specifically 11:19 22:7 32:22 specifics 9:19 speculation 7:8,16

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

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

Page 59
7:17 9:14,14 17:8 17:25 19:18 24:3 27:18 48:8,20,21 spiteful 10:16 spot 43:9 SRT 30:9 ss 51:2 stability 42:19 44:7 staff 17:16,18 28:1 40:16 41:16,18,22 45:16 49:12 staffing 25:24 stand 25:23 30:9 start 15:1,1,2 19:25 started 6:16 17:1 30:6 starts 27:4 state 4:8 51:2,4 stated 7:9 statement 38:10 statements 42:6,8 42:10 STATES 1:7 status 45:6 stealing 46:2 stemming 10:5 21:5 stems 21:3,4 stenographically 51:6 step 13:25 15:18 stepped 23:4 Steve 12:7,10 17:11 18:10,21,22 20:16 20:23 23:3 24:12 29:8 30:13,24 31:18 37:8,9,12 42:16 stolen 46:6 Street 2:4 strength 37:3 stuff 32:3 33:13 subject 27:21 30:23 48:23 suggested 17:16 Suite 2:4 summer 4:13 summertime 43:2 Sunday 23:20 24:1 24:2 supervision 6:10 supervisor 6:14,22 20:25 21:1 25:19 32:19 38:2 42:18 47:11 supervisors 32:23 support 19:1 35:2,4 35:7 supported 16:2 35:17 43:24 supporting 36:13 suppose 6:4 19:19 supposed 14:17 suppresser 30:8 sure 7:4 8:10,11 14:2 15:16 17:10 20:8 23:9,21 34:1 Surete 44:22,25 surrender 32:3 surveilling 43:7 suspected 46:12 suspension 32:2 suspicions 45:8 suspicious 41:21 44:4 sustained 7:12 SW 2:8 swapping 29:6 swore 45:3 sworn 4:2 system 24:23 T T 51:1,1 t-shirt 44:24 tac 30:9 tactical 14:6 Taddonio 8:13 take 9:5 11:17 15:15 26:5 33:16 38:20,23 43:13 taken 51:6,16 talk 25:15 33:13 talked 40:24 talking 23:12,12 24:9 34:4 48:24 tamper 44:13 Tara 2:15 5:10 Taylor 16:9 team 16:24 44:19 telling 7:24 8:4 9:12 11:7 tells 7:22 tenth 21:19 term 12:14 18:6,8 terminal 26:15 terms 26:11 test 34:16 testified 4:3 testimony 23:25 51:15 text 26:16 Thank 47:4 thanking 20:16 theft 46:4,5 theories 46:10,17 theory 46:25 48:18 thereof 51:13,20 thereon 51:17 thing 16:24 17:15 21:7 23:18 27:16 28:19 29:23 46:22 things 9:18 17:19 22:12 27:25 29:16 31:21 33:6,16 46:20 think 7:22 9:24 10:24,25 13:5 14:25 15:1,21 17:8 18:14 19:7 21:23 30:7 32:25 44:21 48:21 thinking 21:4 third 21:19 24:19 26:1 27:4 40:1,8 thought 10:2 17:24 43:18 44:16 thoughtful 8:10 thread 20:13 three 10:19 30:16 31:3 46:7 time 6:15 9:5,22,25 9:25 10:3 18:11 18:12 20:24 23:7 25:20 32:19,23 33:13,17,25 34:18 34:21 36:3 38:2 38:14 40:21 41:16 42:15,17,18 43:2 43:4,5 51:9,16 times 32:25 43:21 timing 22:6 title 51:17 today 5:17 48:6 today's 47:21 told 25:14 26:24 31:6 32:3 38:25 45:22 46:1 top 15:10 20:13,15 touching 26:11 track 13:1 43:2 traditional 12:25 trails 21:17 22:3,7 40:24 training 42:4 transcribed 51:6,8 51:14 transcript 51:15 treasurer 12:23,25 14:12 trial 6:3 19:12,19 tribal 45:6 47:13 tribe 45:4 47:19 tried 33:1 truck 43:23 true 43:18 45:8 46:25 49:12 51:15 trust 10:4 truth 7:22,24 8:3 9:12 11:7 truthful 8:11 10:24 truthfully 5:19 truthfulness 8:25 9:12 10:20 try 13:13 27:23 trying 32:24 44:12 Tuesday 23:23 Tumwater 2:9 turn 33:20 39:1,8 39:25 two 18:7,8,14 27:14 48:1 two-day 23:19 two-thousand 15:14 type 16:24 21:7 23:18 27:16 32:1 46:20,22 types 33:10 typical 39:10 typically 20:12,13 31:5 U Uhlig 1:23 51:4,23 ulterior 17:14 Ultimately 16:4 Un-Elect 20:4,7 21:18,24 22:9 23:15 undersheriff 41:18 undersigned 51:4 understand 7:11 33:2 48:24 understanding 5:25 19:8,12 30:1 30:24 31:10 34:7 34:12 undertaken 40:19 unethical 38:1 unified 16:24 uniform 22:11 union 12:14 UNITED 1:7 unopposed 19:5

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

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

Page 60
untruths 22:22 Update 3:14 upset 11:10 40:16 41:11 use 7:14 16:20 29:5 32:22 43:14,15,22 useful 6:3 want 9:11,13 13:12 37:14 39:25 40:3 40:8 48:19 wanted 39:11 wants 19:7 Washington 1:8,13 1:22,24 2:5,9,13 51:2,4,24 V wasn't 12:7 14:23 vacation 25:17 22:16 41:23 47:15 vague 15:20 19:17 watch 43:25 21:6 22:24 35:6 way 7:14 17:10 46:17 48:22 32:25 33:24 34:15 VanderVeen 8:17 36:25 37:5 8:20 9:8,20 ways 29:17 variety 20:10 29:16 we'll 28:18 31:6 vehicle 29:16 we're 8:8 10:9 vehicles 29:20 16:24 20:10 verbal 41:2 weapon 29:14 version 20:3,19 weapons 30:4 21:12 23:23 website 3:11 20:3,7 versus 4:15 21:9 23:14,23 vice 13:2,3,4,5,21 week 15:6 48:2 14:11,20 29:8 weeks 23:13 48:1 vicinity 36:17 weird 24:23 video 22:16 went 19:5 34:17 view 7:13 41:23 49:23 views 42:22 weren't 38:9 45:5 violated 38:5 48:14 violation 13:9 WESTERN 1:8 violations 38:1 Whatcom 1:13,13 virtue 21:1 1:21 2:7,11,12 voluntarily 37:23 4:11,15 19:13 volunteer 13:21 31:12 36:24 37:4 45:10 37:12 43:20 46:13 volunteers 13:8 46:15 vote 18:20 19:2 white 43:8,15,22,23 36:10 37:11 43:23 44:3 voted 36:12 whoa 49:12 votes 14:9 19:2 Wiederspohn 9:3,7 voting 36:5 11:4 vs 1:12 William 1:14 2:15 win 19:2,2 27:23 W wise 36:10 wait 21:7 23:6 witness 4:2,19,23 waive 51:8 4:25 7:12,18 9:15 10:2 15:21 18:1 19:13,19 24:4 26:24 27:1,9,15 27:20 28:3,6 35:7 47:22 48:10 49:6 51:5,7,8,18,20 witnessed 11:13 witnesses 6:2 wolf 17:23 18:1 won 18:21,22 word 16:20,22 40:3 41:20 words 31:7 work 14:16 49:19 worked 36:14 42:17 working 25:13,16 33:15 works 24:25 wouldn't 18:1 27:11 46:6 49:16 write 16:14 25:3,6 25:10 26:1,5 writing 22:18 39:14 written 8:8 11:12 24:20 wrong 7:15 13:10 44:22 wrote 11:11 X X 3:1 Y yeah 15:7 16:20 22:1 24:4 28:24 29:15 34:9,14 39:22,23 year 18:8 years 4:13 6:9 11:21 16:16 17:3 17:4 18:7 45:3 47:11 yup 17:22 18:17 49:17 Z 0 1 1 3:10 15:8,9 20:1 20:20 21:11 36:1 10 17:3,4 21:23 22:2 10/19/2011 3:11,13 103 2:4 10th 1:20 4:14 11:00 4:14 11:00AM 1:20 12/16/2011 3:14 12/8/2010 3:10 12:20PM 1:20 13 12:5 15 3:10 4:13 6:9 15th 24:1 32:12 34:20 16th 24:1 34:20 18th 23:24 19 3:11 1900 28:25 1934 1:24 51:23 1999 30:5 19th 30:14 31:2 1st 22:21 23:1 2 2 3:11 19:23,24 20:19 21:12 37:21 37:22 39:1 2:13-CV-00727 1:12 2005 44:20 2007 6:13,23 2008 42:13 47:12 2009 11:18 2010 11:18 15:14 17:6 2011 3:10 15:14 20:7 30:14 32:9 35:2 36:6 2012 12:4 39:1 2013 12:4 2014 1:20 51:20 20th 24:20 26:6,8 21st 24:13 24 3:12 18:21 2674 2:8 3 3 3:4,12 24:10,11 31:25 39:5,5 3/2/12 24:16 3/21/2012 3:12 30 3:13 311 1:21 2:12 32 3:14 35 3:5 360.734.3448 2:5 360.754.3480 2:9 37 18:21 4 4 3:13 30:11,13 39:25 40:9 47 3:6 5 5 3:14 32:5,6 41:25 512 2:4 6 7 7:00 28:24 75 36:12 76 37:15 8 9 98225 1:22 2:5,13 98512 2:9 99 4:13 6:16 17:1

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