Stephen Cassidy Deposition FDNY / UFA, NY POST Defamation Lawsuit

GARY SUSON VS. NYP HOLDINGS, INC.

STEPHEN J. CASSIDY - 9/13/2007

GARY SUSON BSA XMAX(1/51) VS. NYP HOLDINGS, INC.STEPHEN J. CASSIDY - 9/13/2007

Page 1 (1) CIVIL COURT OF THE CITY OF NEW YORK

(2) COUNTY OF NEW YORK --------------------------------------x

(3) GARY SUSON,

(4) Plaintiff,

(5) -against-

(6) NYP HOLDINGS, INC., NEWS AMERICA INCORPORATED, CYNTHIA R. FAGAN, MURRAY WEISS, STEPHANIE

(7) GASKELL, and JOHN DOES 1 AND 2,

(8) Defendants,

(9) INDEX NO.: 3000605 TSN 2006 --------------------------------------x(10)

(11) 875 Third Avenue New York, New York(12) September 13, 2007

(13) 9:05 a.m.(14) (15)

(16) Deposition of STEPHEN J. CASSIDY,

(17) pursuant to Subpoena, before Sophie Nolan, a

(18) Notary Public of the State of New York.(19) (20) (21) (22)

(23) ELLEN GRAUER COURT REPORTING CO. LLC 126 East 56th Street, Fifth Floor

(24) New York, New York 10022 212-750-6434

(25) Ref: 85199

Page 2 (1) A P P E A R A N C E S:

(2)

(3) JARED M. LEFKOWITZ, ESQ.

(4) Attorney for Plaintiff

(5) 48 Wall Street, 11th Floor

(6) New York, New York 10005

(7) BY: JARED M. LEFKOWITZ, ESQ.

(8) PHONE 917-887-3920

(9)

(10) HOGAN & HARTSON

(11) Attorneys for Defendants

(12) 875 Third Avenue

(13) New York, New York 10022

(14) BY: JASON P. CONTI, ESQ.

(15) PHONE 212-918-3000

(16) FAX 212-918-3643

(17) E-MAIL [email protected]

(18)

(19) ALSO PRESENT:

(20) GARY SUSON

(21)

(22)

(23)

(24)

(25)

Page 3 (1) ------------------ I N D E X ------------------

(2) WITNESS: STEPHEN J. CASSIDY

(3) EXAMINATION BY PAGE

(4) MR. CONTI 4

(5) MR. LEFKOWITZ 105

(6)

(7) --- DOCUMENTS AND/OR INFORMATION REQUESTED ----

(8) DESCRIPTION PAGE

(9) Minutes of board meetings 59

(10) Last name of Bruce 102

(11) Copy of charges 117

(12)

(13) --------------- E X H I B I T S ---------------

(14) EXHIBIT DESCRIPTION FOR I.D.

(15) 182 Subpoena 6

(16)

(17) (EXHIBITS RETAINED BY MR. CONTI)

(18)

(19)

(20)

(21)

(22)

(23)

(24)

(25)

Page 4 (1) S T E P H E N J. C A S S I D Y, called as a

(2) witness, having been first duly sworn,

(3) was examined and testified as follows:

(4)

(5) EXAMINATION BY

(6) MR. CONTI:

(7) Q. Good morning, Mr. Cassidy.

(8) A. Good morning.

(9) Q. My name is Jay Conti. I'm an

(10) attorney here at Hogan & Hartson. We are the

(11) attorneys for the Defendants, the New York Post

(12) and three of its reporters. We've been sued in

(13) this case brought by Gary Suson who is the

(14) Plaintiff.

(15) Could you please state your full

(16) name and address for me for the record?

(17) A. Stephen J. Cassidy, 71 Tanners Neck

(18) Lane, Westhampton, New York.

(19) Q. Could you tell me your current

(20) occupation?

(21) A. I'm a New York City firefighters.

(22) I'm also the president of the Uniformed

(23) Firefighters Association.

(24) Q. Have you ever had your deposition

(25) taken before?

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(2) A. I think the answer to that is yes. (3) I can't remember when, but I think I've been (4) deposed before. (5) Q. Do you remember around the time? (6) A. I think I was definitely deposed (7) for some kind of a lawsuit at one point in (8) time. I don't remember when. A long time ago. (9) Q. I'm going to go through a couple of(10) groundrules to familiarize you with how this(11) will work. The purpose here is for us to ask(12) some questions and get some answers regarding(13) this particular lawsuit.(14) We ask that you listen to the(15) question and wait to respond until we're(16) finished with the question. If you don't hear(17) anything or you don't understand anything,(18) please just ask me to repeat the question.(19) I'll be happy to do that. If you answer the(20) question, I'm going to assume that you(21) understood. It does that make sense?(22) A. Yes.(23) Q. The court reporter is here to take(24) down your testimony she needs audible responses(25) so please don't shake your head or nod. There

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(2) has to be an audible response. (3) There may be an objection by Mr. (4) Suson's counsel Mr. Lefkowitz. You are still (5) required to answer the question even if an (6) objection has been made. (7) If you want to take a break, just (8) let me know and we'll be happy to take a break (9) any time you need one. All answers here are(10) given under oath. You understand that because(11) they're under oath your answers must be(12) truthful. Do you understand that?(13) A. Yes, I do.(14) Q. In general do you understand these(15) instructions?(16) A. Yes.(17) Q. One final obligatory question, are(18) you taking any drugs or medications that would(19) prevent you from being able to give truthful(20) answers here today?(21) A. No.(22) Q. Great. I'm going to show you a(23) document, here. I'm going to mark this as -- I(24) think we're up to 182.(25) (Exhibit 182, subpoena, marked for

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(2) identification.) (3) Q. Just leaf through that for a (4) minute. (5) A. (Reviewing.) (6) Q. Have you seen that document before? (7) A. Yes. (8) Q. I'm going to ask you to look at the (9) page marked four at the bottom. Do you see it(10) says "Document Requests"?(11) A. Yes.(12) Q. Have you seen that before?(13) A. I have, but not for some time.(14) Q. Do you recall whether or not you(15) searched for any documents that were responsive(16) to the requests made?(17) A. I had my attorney, Michael Block(18) who is the attorney for the Uniformed(19) Firefighters Association ask my secretary for(20) any document as it relates to this. To my(21) knowledge, that was done. I don't know what he(22) found or what he submitted, but that's what we(23) asked.(24) Q. Do you have any additional(25) documents?

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(2) A. No. (3) Q. So anything that was submitted to (4) Mr. Block would be what you have in your (5) records? (6) A. Yes. (7) Q. Let's go a little bit into your (8) background. Did you attend high school? (9) A. Yes.(10) Q. What high school was that?(11) A. Nazareth High School in Brooklyn,(12) New York.(13) Q. Did you graduate from high school?(14) A. Yes.(15) Q. What year was that, do you recall?(16) A. 1974.(17) Q. Did you attend college?(18) A. Yes.(19) Q. What college was that?(20) A. I attended St. John Fisher in(21) Rochester New York and St. Francis College in(22) Brooklyn.(23) Q. Did you receive a degree?(24) A. No, I did not.(25) Q. Have you received -- you said

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(2) you're a firefighter. Have you received any (3) training that's offered by the fire department? (4) A. Yes, I have. (5) Q. Was that the standard probationary (6) training or did you receive any additional (7) training? (8) A. Firefighters receive training (9) throughout their career. So I received(10) training for -- I now have 19 years on the job.(11) Certainly for the first 14 and a half years(12) when I was active in the firehouse before I was(13) elected the president, I received ongoing(14) training.(15) Q. You said your current position is(16) president of the Uniformed Firefighters(17) Association; is that correct?(18) A. Yes.(19) Q. Where is that union located?(20) A. Our offices are at 204 East 23rd(21) Street in New York.(22) Q. And when were you first elected to(23) that position?(24) A. In August of '02.(25) Q. In general, if you could just

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(2) describe the duties and responsibilities of the (3) president of the UFA? (4) A. They're pretty expansive, negotiate (5) contracts, protect workers rights, do media as (6) it relates to issues concerning firefighters (7) and a host of other things, grievances. (8) Q. You mentioned doing media. Do you (9) have frequent contact with, let's say,(10) reporters?(11) A. I do.(12) Q. How often would you say you speak(13) with reporters?(14) A. I would say on a -- depending on(15) the circumstances, it can be very often, but I(16) would say on a -- certainly on a weekly basis(17) we're dealing with the media on one topic or(18) another.(19) Q. And you directly speak with the(20) media in those instances?(21) A. Yes, and if you watched the(22) telecast last night or read the papers this(23) morning the UFA was involved in a -- we(24) actually had a media briefing yesterday as it(25) relates to an issue with the fire department.

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(2) We were on most of the major (3) channels last night and the Daily News and the (4) Post and many other papers today. (5) Q. Do you have conversations with (6) reporters that aren't in the context of a press (7) conference, one-on-one? (8) A. One-on-ones as it relates to issues (9) that concern firefighters?(10) Q. Yes.(11) A. Yes.(12) Q. You said you were elected in August(13) of 2002 to the UFA. Prior to that time period,(14) what position did you hold?(15) A. New York City firefighter as I am(16) now.(17) Q. Certain class?(18) A. First grade.(19) Q. What engine and firehouses?(20) A. Engine 236 in East New York in(21) Brooklyn.(22) Q. And when did you start at that(23) particular firehouse?(24) A. I was appointed in February of(25) 1988. I was assigned there in April of 1988.

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(2) Q. So, you stayed there during your (3) entire career as a firefighter prior to being a (4) elected to the UFA? (5) A. Absolutely, and I still am assigned (6) to that firehouse. (7) Q. And as on September 11th you were (8) assigned to that firehouse as well? (9) A. Yes.(10) MR. LEFKOWITZ: When you say(11) September 11th, I assume you're talking(12) about 2001?(13) MR. CONTI: 2001, yes.(14) Q. So, you have not ever been a fire(15) officer; is that correct?(16) A. That's correct.(17) Q. Could you do me a favor and please(18) go over the ranks in the fire department?(19) A. Above firefighter is lieutenant,(20) then captain, then battalion chief, then deputy(21) chief, then staff chiefs. When you get to the(22) rank of staff chiefs, those are appointed. All(23) the other ranks are by a promotional exam.(24) Q. Prior to 1988, did you hold any(25) other positions relating to firefighting?




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(2) A. No. (3) Q. Could you just briefly tell me who (4) comprises the membership of the union, is it (5) every firefighters in the city of New York? (6) A. Every firefighter of the City of (7) New York is a member of the Uniformed (8) Firefighters Association which is the union. (9) The elected officials of the union are really(10) 11 members, five borough trustees elected by(11) the members of each borough, so i.e. Brooklyn(12) elects the Brooklyn trustee. There are five(13) citywide officials; president, vice president,(14) treasurer, recording secretary and sergeant at(15) arms.(16) And there is a fire marshal(17) representative, the 11th, which represents only(18) fire marshals which are also part of my union.(19) Q. When you say you have been(20) president since 2002, do you remember the exact(21) date that you were elected?(22) A. I took office effective August 1,(23) 2002. I was elected sometime in July.(24) Q. How long are those terms?(25) A. Three year terms.

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(2) Q. So, then did you run again in 2005? (3) A. I did and I was reelected. (4) Q. Sworn in again on August 1, 2005? (5) A. Yes. (6) Q. I take it there's another election (7) scheduled in July of 2008? (8) A. There's another election scheduled (9) next year, yes.(10) Q. Will that be in July?(11) A. It actually may be moved up because(12) the consultation has some mandates about(13) contracts, but it will be sometime next year.(14) Q. Who was the president of the UFA(15) prior to you taking office in 2002?(16) A. Kevin Gallagher.(17) Q. Did you run against Mr. Gallagher(18) in 2002?(19) A. No.(20) Q. Did you run against another(21) candidates?(22) A. I ran against several candidates.(23) Kevin Gallagher was stepping down after serving(24) two terms. He was not running for reelection.(25) Q. Was there a UFA executive board?

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(2) A. Yes. (3) Q. And how many people are on that (4) executive board? (5) A. That's the 11 people that I (6) mentioned earlier. (7) Q. It would be the five borough (8) trustees, the president, vice president, (9) recording secretary, treasurer, health and(10) safety/sergeant at arms and the marshal(11) representative; is that correct?(12) A. Yes.(13) Q. As best you can recall, do you(14) remember who held those positions when you(15) first started as UFA president in August of(16) 2002?(17) A. Yes. When I first took office in(18) August 2002, I was the president, Jim Slevin(19) was the vice president as he currently is.(20) Phil McArdle was the sergeant at arms, Kevin(21) McAdams was the treasurer. And Joe Miccio was(22) the recording secretary. The borough trustees(23) were Bob Straub, Bronx trustee; John Kelly,(24) Brooklyn trustee; Rudy Sanfilippo, Manhattan(25) trustee; Tom DePalma, Queens trustee; and Don

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(2) Ruland, Staten Island trustee. The fire (3) marshal rep was Ed Burke. (4) Q. In August of 2005, I'd like a (5) rundown of the folks who held those same 11 (6) positions. (7) A. I was the president, reelected (8) president, Jim Slevin, vice president; Bob (9) Straub, treasurer; Bill Romaka, health and(10) safety/sergeant at arms; Joe Miccio, recording(11) secretary; Lester Layne, fire marshal rep;(12) trustees, John Kelly, Brooklyn; Don Ruland,(13) Staten Island, Steve Humenesky, Queens; Ed(14) Brown, the Bronx; and Dan Murphy, Manhattan.(15) Q. Of all those individuals you just(16) listed, are they all still currently in office?(17) A. Yes.(18) Q. And have been since August of 2005?(19) A. Yes.(20) Q. As president, are you responsible(21) to the board?(22) A. Yes, I am.(23) Q. How do you interact with the board,(24) are you head of the board, are you a voting(25) member of the board?


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(2) A. As president I have, as designated (3) by the UFA constitution, certain rights and (4) responsibilities. We hold regular board (5) meetings to discuss issues relating to the (6) board and to the firefighters in the field. (7) That is an opportunity for individual board (8) members to raise issues of concern in any (9) manner, shape or form. They can call for votes(10) on topics that may need a vote for the board to(11) decide on actions, but the board acts as a(12) unit.(13) I don't independently act. As the(14) president I'll have my say in what I believe we(15) should do, but in the end, the board votes on(16) certain kinds of actions.(17) Q. Is there a way to determine what(18) kinds of actions require a board vote and what(19) kinds of actions you might be able to make on(20) your own?(21) A. I would say that that is probably(22) outlined -- I don't have a copy of the(23) Constitution with me, but that is clearly(24) outlined in the UFA constitution and if there(25) are any questions about those actions, we refer

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(2) them to our attorney, Michael Block, who is the (3) general counsel and attends all board meetings. (4) So, if there is a dispute or a (5) concern about how we should be acting as it (6) applies to the constitution, our attorney will (7) advise us. (8) Q. You mentioned regular board (9) meetings, how frequently are those meetings?(10) A. Usually twice a month, sometimes(11) more often.(12) Q. Can any member call a meeting or is(13) it a set schedule?(14) A. The president can call a meeting at(15) any time, any board member can call a meeting(16) as outlined in the constitution. I think they(17) need to have a majority of the board agree that(18) a meeting should be held or an emergency(19) meeting. It would be described as an emergency(20) meeting.(21) Q. You mentioned a trustee position.(22) Is that a full-time position?(23) A. All of these 11 positions are(24) full-time positions. Each member of the union(25) is granted full release time as part of our

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(2) contract with the city, which means they are (3) not working in a firehouse or the fire marshal (4) is not working as a fire marshal rep. They are (5) full-time positions. (6) Q. Generally speaking, could you just (7) describe duties and responsibilities in the (8) trustee position? (9) A. The borough trustees?(10) Q. The borough trustee, yeah.(11) A. The borough trustee is responsible(12) for anything involving the members of his(13) particular borough, which can go from dealing(14) with disputes between firefighters and(15) management and/or officers. It can be dealing(16) with arrests, disciplinary actions.(17) MR. LEFKOWITZ: I'm sorry, you said(18) "arrests"?(19) A. Arrests and/or disciplinary(20) actions. Also there are other duties as(21) assigned by the constitution and any(22) assignments granted to them or given to them by(23) the president.(24) Q. So you will at times ask the(25) borough president to take certain actions?

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(2) A. Absolutely. (3) Q. Does the borough trustee have (4) certain authority to act on behalf of the (5) union? (6) A. Could you be more specific? (7) Q. Does the trustee have authority to (8) act on behalf of the union in a matter that (9) involves more than, say, just something in a(10) particular borough?(11) A. No.(12) Q. Do you know who Thomas Butler is?(13) A. Thomas Butler is the public(14) relations person employed by the Uniformed(15) Firefighters Association.(16) Q. Do you know where he works?(17) A. His office is in our building on(18) the third floor of 204 East 23rd Street.(19) Q. Does he have his own separate firm?(20) A. He does, Butler Associates.(21) Q. And he does the press relations for(22) the union?(23) A. He does.(24) Q. Does he -- how long -- do you know(25) how long he's worked for the union?




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(2) A. He's worked there significantly (3) longer than I've been the president which is, (4) you know, over five years. (5) Q. He's been there for the entirety of (6) your tenure as president? (7) A. Absolutely, yes. (8) Q. Does he have authority to comment (9) on behalf of the union on certain matters that(10) are pertinent to the union? I mean by(11) "comment" to the press?(12) A. He does. Usually he will not do(13) that unless he's coordinated those statements(14) with me, but he does have the authority to(15) comment.(16) Q. So, is it fair to say he would come(17) to you for an issue that he had never spoken to(18) the press about before?(19) A. Yes.(20) Q. If there was an issue he had(21) already discussed with the press, in those(22) instances would he have authority then to speak(23) with the press about that particular topic?(24) A. Yes, he has latitude to comment(25) with the media on topics that he's already

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(2) discussed with me, yes. (3) Q. How frequently would you say you (4) speak with Mr. Butler? (5) A. Virtually every day and sometimes (6) that's seven days a week. (7) Q. Usually in terms of Mr. Butler's (8) involvement, how does he get involved? Does (9) the press go directly to him or does the UFA(10) forward all calls to him if they initiate(11) there?(12) A. The media knows that he is our(13) public relations man and, as I said, he's done(14) this for a long time. So they -- if they want(15) to speak to me or they want a comment from the(16) UFA on a particular topic or they want an(17) interview with me, they will contact Tom.(18) Q. They pretty much always go through(19) Tom Butler if they want to get to you?(20) A. Absolutely.(21) Q. And if Mr. Butler is not available,(22) are there any people on staff at the UFA that(23) handle press calls or alternative people?(24) A. He has his own staff. I also have(25) a chief of staff, his name is Jim Spollen, who

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(2) is a liaison between me and Tom on issues when (3) Tom can't get ahold of me or when there are (4) many things going on at once. (5) Q. You mentioned Jim Spollen, his (6) title is chief of staff? (7) A. I'm not sure what his title is. He (8) is my chief of staff and that's what I call (9) him. I don't know if he's got an official(10) title. He's a retired firefighter. He's(11) worked for me for several years in that(12) capacity.(13) Q. When did he start working for you,(14) if you recall?(15) A. 2004. Either late 2003 or early(16) 2004 is my recollection.(17) Q. Generally, what kind of duties and(18) responsibilities does Mr. Spollen have?(19) A. He is an intermediary between me(20) and the board on a whole range of topics. It's(21) impossible for me to be available to talk to(22) all 11 board members at any given time.(23) If they have issues that they don't(24) want to bother me with, but they want to raise(25) they'll bring them up to Jim. He's also

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(2) actively involved in our public relations. He (3) sits with me and Mr. Butler. (4) His role is pretty expansive and (5) the main function is to make it easier for me (6) to get through the day and get all the things (7) that we need to do done. (8) Q. Does he at times, Mr. Spollen, (9) speak with the press?(10) A. Not -- no.(11) Q. You mentioned Michael Block. You(12) said he is the general counsel for the UFA?(13) A. Yes.(14) Q. Do you know how long he's been the(15) UFA's general counsel?(16) A. I believe it's over 20 years.(17) Q. Does Mr. Block speak with the press(18) on behalf of the UFA to your knowledge?(19) A. He may on rare occasions. It is(20) only as it relates to legal issues.(21) Q. And as it relates to legal issues(22) does he have authority to speak with the press(23) on behalf of the UFA?(24) A. He does. As a general rule he will(25) always speak with me, but he certainly has my


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(2) authority to do that if he believes it's (3) appropriate. (4) Q. Do you collaborate much with the (5) Uniformed Fire Officers Association? (6) A. We certainly do on some topics. I (7) don't know how to describe it in terms of how (8) often we do, but we have clearly a working (9) relationship. Many of the issues that are(10) important to us are important to them,(11) squabbles that we may have with the fire(12) department usually relate to firefighters and(13) fire officers.(14) So, in general, I would say the(15) answer is yes. I don't know how frequently we(16) do, but the answer is probably yes.(17) Q. Do you make joint announcements at(18) times?(19) A. Yes, we do.(20) Q. Joint press releases?(21) A. Occasionally.(22) Q. In general, did you have a good(23) working relationship with Peter Gorman, the(24) former president?(25) A. Yes.

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(2) Q. Who is the current president of the (3) UFOA? (4) A. Jack McDonald. (5) Q. Do you work with him at this point? (6) A. Yes. (7) Q. Would you describe your working (8) relationship as amicable? (9) A. I would say it's very good.(10) Q. Do you know what the term Ground(11) Zero refers to?(12) A. Sure.(13) Q. Could you describe that for me?(14) A. Ground Zero is a term that's used(15) to refer to the site where the World Trade(16) Center once stood in the aftermath of its(17) destruction. A lot of people refer to that(18) site as Ground Zero.(19) Q. Have you ever been to Ground Zero?(20) A. Yes.(21) Q. Do you recall your first visit to(22) Ground Zero, was it on 9/11/01?(23) A. It was on late 9/11.(24) Q. Would you briefly describe the(25) nature of your work on 9/11 --

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(2) A. I was off duty. I came in from (3) home. I did what most firefighters did, went (4) to the fire house, grabbed their gear and then (5) made our way into Manhattan. (6) Q. And on that day, did you (7) participate in the rescue efforts going on? (8) A. Yes. Like everybody else, I was (9) involved in trying to make -- make some impact.(10) Q. Were you working -- what area(11) generally were you working in on 9/11, if you(12) recall?(13) A. You know what, I'm not really sure.(14) I'm trying to remember 9/11 versus 9/12 versus(15) 9/14 and 9/15 and, to be honest, it's kind of(16) hazy as to where I was on that first day.(17) Q. Generally speaking, say the week(18) after 9/11, were you at Ground Zero?(19) A. I was there very often for the(20) first two months.(21) Q. Would you say you went every day?(22) A. No. I would say up until November(23) 10th, I was there at least every other day.(24) Q. And generally what kind of duties(25) and responsibilities were you undertaking at

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(2) that time? (3) A. Well, prior to 9/11 I had been (4) assigned light duty at headquarters due to an (5) injury, two injuries that I suffered when I (6) fell through a floor at a fire. I was working (7) for the public information office so I was (8) working at Ground Zero for public information, (9) trying to coordinate in the first week(10) communications between headquarters and staff(11) chiefs.(12) In the first few days, there was no(13) cell phones that were working. It was very(14) much like the Pony Express.(15) And in the weeks that followed, as(16) communications got better, I was there dealing(17) with the media in some kind of backup role.(18) Q. Were you working at that point with(19) Frank Gribbon?(20) A. Yes. He was the -- I'm trying to(21) think what his title is, but he's in charge of(22) public information for the city. I think he's(23) assistant commissioner for public information.(24) I was working for his office.(25) Q. In addition to helping with




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(2) communications, did you participate at all in (3) the rescue and then later recovery efforts that (4) were taking place at Ground Zero? (5) A. I did. Some on 9/11 and 9/12 and (6) then on some of my off time. (7) Q. Did you participate in any of the (8) digging through rubble at Ground Zero, breaking (9) through rubble?(10) A. As I said in the first few days,(11) yes, but then later on on some of my off days,(12) yes.(13) Q. Do you know of any rules or(14) procedures that were in place during the(15) recovery efforts at Ground Zero in terms of how(16) the recovery was supposed to proceed?(17) A. Are you talking about --(18) Q. The logistics in terms of sifting(19) through material and where items were supposed(20) to go and what you were looking for?(21) A. In the beginning it was merely a(22) bucket brigade. When we believed we still had(23) an opportunity to rescue people who may have(24) been trapped, you know, the actions were, I(25) think, entirely different and more haphazard

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(2) than later on when it was deemed that it was (3) too late and it was a recovery effort, which (4) was more structured. (5) Q. During that recovery effort which (6) was more structured, can you describe how (7) material was moved through Ground Zero and (8) eventually removed from Ground Zero? (9) A. Firefighters were working in(10) conjunction with iron workers and other(11) construction workers to ensure that material(12) was removed -- we searched for remains and when(13) we were clear there were no remains, then it(14) was removed from the site.(15) Q. Do I know if there are any rules or(16) procedures regarding the people who were(17) working there removing any items from Ground(18) Zero?(19) A. Well, everyone was told that(20) anything that was found was to be put aside,(21) any remains or any items or any personal(22) effects were to be put aside and would be, you(23) know, viewed by the fire marshals and the(24) police department. They wanted them.(25) Q. Do you know what the transfer

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(2) station is? (3) A. The transfer station? (4) Q. Yeah, it's a term called transfer (5) station in reference to Ground Zero? (6) A. I don't know what you mean by that. (7) Q. Okay. Do you know where everything (8) at Ground Zero was taken after it was taken off (9) site?(10) A. No, I don't know.(11) Q. Have you ever heard of Fresh Kills?(12) A. Oh, Fresh Kim's landfill. I do(13) know that much, I don't know if all, of the(14) material after it had been sifted through was(15) taken to Fresh Kills.(16) Q. During your time working at Ground(17) Zero, generally how long were the shifts?(18) A. In the -- in the first -- I would(19) say in the first few weeks the shifts were 24(20) hours on, 24 hours off.(21) Let me back up. In the first week(22) to ten days there were 24 hours on, 24 hours(23) off. Then I think the department shifted to(24) maybe twelve-hour shifts. You know, to be(25) honest, I can't remember. They did change

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(2) their chart. In the first few weeks it was -- (3) definitely guys were there for extended periods (4) of time. (5) Q. And when you're doing the (6) communications work, were you set up at some (7) kind of a command post near Ground Zero or (8) where in general were you working? (9) A. It wasn't that structured, to be(10) honest. You know, when we had -- I want to say(11) maybe day four or five, when we had cell phones(12) that were working, you would just go wherever(13) they needed you to go and it may have been(14) simply to find a particular chief and get an(15) update on a report that came in.(16) There were many, many rumors(17) circulating about people being found, items(18) being recovered and. So, the public(19) information office needed to be able to respond(20) to the media and one of the ways they needed to(21) do that was to verify whether or not(22) information that they were hearing from(23) reporters was true. One of the things that(24) they had asked me and others to do is find a(25) particular chief or track down a particular


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(2) story and find out whether any of this was, in (3) fact, true. (4) Q. After the first couple of weeks (5) when the rumors started to subside just a (6) little bit, what types of duties did you (7) perform in terms of communications at the site? (8) A. I was not the lead guy there, but (9) the role was to set up interviews with(10) reporters and either commanders that would give(11) them an update on where we were in terms of(12) progress. That was -- that was mainly what we(13) did and also one of the things we did was try(14) to keep media out of the site, people who(15) continued to find a way to sneak in. If we(16) found them, we had to throw them out.(17) Q. Were there other people in addition(18) to media who tried to get into the site?(19) A. Yes.(20) Q. Were you involved in removing those(21) individuals as well?(22) A. I wasn't involved in removing those(23) individuals, but we pointed them out to people(24) and if they were not New York City firefighters(25) or police officers and they weren't supposed to

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(2) be in there, they were to be pointed out and (3) asked to be removed. (4) Q. So, you were on site noticing these (5) people and that's how you participated? (6) A. Absolutely. (7) Q. After, I think you said it was (8) November 10, 2001, did you return to Ground (9) Zero at any point?(10) A. No. I -- I think it was around(11) November 10th that I had surgery on my hand. I(12) was out of work for probably six weeks and(13) never went back in any substantial way. I went(14) down a few times on my own, but never went down(15) in any substantial way.(16) Q. Are you familiar with what a crime(17) scene is?(18) A. Yes.(19) Q. Would you just describe generally(20) what a crime scene is?(21) A. I don't know what the technical(22) definition is, but I would say a crime scene is(23) an area where a crime has been committed and is(24) cordoned off or deemed to be cordoned off while(25) evidence is gathered.

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(2) Q. As a firefighter, did you encounter (3) these crime scenes? (4) A. Absolutely. (5) Q. Are you allowed to disturb a crime (6) scene? (7) A. No, you're not. (8) MR. LEFKOWITZ: Object to the form. (9) Q. Are you allowed to take any items(10) from a crime scene?(11) MR. LEFKOWITZ: Object to the form.(12) A. No.(13) Q. Do you know whether or not Ground(14) Zero was considered a crime scene?(15) MR. LEFKOWITZ: Objection.(16) A. Yes, it was.(17) Q. Do you know whether or not an(18) agency ever designated it a crime scene?(19) A. If an agency ever designated Ground(20) Zero as a crime scene? Yes, the police(21) department did.(22) Q. Do you know what the term artifact(23) means in reference to Ground Zero?(24) A. No.(25) Q. How about remnant, the term

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(2) remnant? (3) A. Remnant, I'm not sure what you mean (4) by that. (5) Q. How about victims' personal (6) belonging? (7) A. I know what you mean by that, yes. (8) Q. What would you describe that as? (9) A. Anything that was being carried by(10) any one of the victims who was killed in the(11) terrorist attack, i.e., clothing, wallet,(12) pictures, money, watches, jewelry, any of those(13) things.(14) Q. Do you know whether or not there(15) are any policies in place for workers at Ground(16) Zero as to removing items from Ground Zero,(17) meaning for their own personal use as opposed(18) to going for the landfill?(19) A. Yeah, absolutely, prohibited.(20) Q. Were private citizens who were(21) involved in some way in the efforts at Ground(22) Zero allowed to or have the authority to remove(23) any of these items from Ground Zero?(24) A. No.(25) Q. Did they have the authority to




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(2) remove anything from Ground Zero that was not (3) their own personal property? (4) A. No. (5) Q. Do you know whether or not any FDNY (6) employee or official had any authority to allow (7) an individual to remove any item from Ground (8) Zero? (9) A. I do know, and the answer is no,(10) they weren't allowed to. They didn't have the(11) right to give that authority.(12) Q. Do you know the name Brian(13) Bonsignore?(14) A. No.(15) Q. Just to be clear, would an FDNY(16) lieutenant working at Ground Zero have the(17) authority to allow another individual at the(18) site to remove any item from Ground Zero?(19) A. Absolutely not.(20) Q. Have you ever heard the name Samuel(21) Brandon?(22) A. No.(23) Q. Have you ever heard the name Gary(24) Suson?(25) A. Yes.

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(2) Q. Do you recall when you first heard (3) the name Gary Suson? (4) A. Not specifically. I would say (5) sometime in late 2002 or early 2003. (6) Q. It was sometime after you became (7) UFA president? (8) A. Yes. (9) Q. Do you have any recollection as to(10) who first mentioned Mr. Suson to you?(11) A. Yes, the Manhattan trustee at the(12) time Rudy Sanfilippo.(13) Q. Do you recall what Mr. Sanfilippo(14) said to you?(15) A. His name came up -- I don't(16) remember the specifics, but he came up in a(17) board meeting where he had recounted his(18) relationship with Mr. Suson and said that he(19) was a friend, someone that had been down there(20) taking photographs, and was -- how do I(21) describe it -- was working on behalf of(22) firefighters to tell the story of 9/11 and the(23) recovery efforts.(24) Q. When you say "down there," do you(25) mean Ground Zero?

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(2) A. Yes. (3) Q. Do you recall when this board (4) meeting took place? (5) A. No. (6) Q. Do you recall the year, generally? (7) A. It could have been late 2002, but (8) it was probably sometime in 2003. (9) Q. Do you recall why Mr. Sanfilippo(10) had brought this issue to the attention the(11) board?(12) A. The first time that I heard his(13) name, I don't know if that's when he raised(14) this topic, but he subsequently, if he didn't(15) do it at that point in time, raised it to say(16) that the UFA had granted Mr. Suson the mantle(17) of official photographer of the Uniformed(18) Firefighters Association.(19) Q. You don't recall whether or not he(20) said that at that board meeting?(21) A. He said it at a board meeting. I(22) don't know if he said it at the first board(23) meeting that I remember him mentioning this.(24) Q. The first time that he mentioned(25) this at a board meeting, do you recall why he

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(2) brought up Mr. Suson's name at all? (3) A. No. (4) Q. Do you recall if he asked the board (5) to take any kind of action? (6) A. At some point in time, he was -- he (7) was looking for us to grant Mr. Suson that -- (8) that mantle, you know, give him something in (9) writing saying that he was the official(10) photographer of the Uniformed Firefighters(11) Association.(12) It was discussed at a board(13) meeting. Nobody knew who Mr. Suson was. Our(14) decision was to not grant him that simply(15) because it was too broad. It implied that(16) anything that he did was okay with the(17) Uniformed Firefighters Association. We(18) generally don't give endorsements or(19) recommendations like that and so the board(20) decided not to do that.(21) Q. And, again, the title or mantle(22) that he was asking for was what?(23) A. My recollection is official(24) photographer of the Uniformed Firefighters(25) Association.


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(2) Q. Do you recall any other individuals (3) speaking during any of these board meetings (4) where Mr. Suson was discussed? (5) A. Well, there was a discussion among (6) many of the board members about whether or not (7) this was a good thing or not a good thing. Our (8) general counsel, Mike Block, weighed in and in (9) the end after a free-flowing discussion we(10) decided in a vote that we would not grant that(11) title as official photographer of the Uniformed(12) Firefighters Association to Mr. Suson.(13) Q. And again that was sometime --(14) actually, for this particular vote, do you have(15) any recollection as to when that took place?(16) A. I don't. I mean, I don't want to(17) guess, so I'm going to say I'm not sure(18) exactly.(19) Q. Any idea as to the year, perhaps?(20) A. I would say -- you know, sometime(21) in 2003, but I guess it's possible it was 2004,(22) but I'm not sure. I'm not sure when this(23) controversy really erupted.(24) Q. Do you recall if anyone other than(25) Mr. Sanfilippo was in favor of granting this

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(2) designation? (3) A. I don't believe anybody else was. (4) Q. Again, that's the 11 member board; (5) is that correct? (6) A. Let me clarify one thing. On the (7) 11 member board, the fire marshal rep doesn't (8) get to vote. It's a ten member board. The (9) president only votes to break ties.(10) Q. You didn't vote?(11) A. I would only vote to break a tie(12) and it was not necessary for me to vote.(13) Q. Before today, have you ever met(14) Mr. Suson in person?(15) A. I don't believe so.(16) Q. Do you recall if you've ever spoken(17) with him on the telephone?(18) A. I think that's possible that I have(19) spoken to him, but I don't recall any(20) specifics.(21) Q. Do you recall whether or not he(22) might have called you and left any voicemails(23) or anything like that?(24) A. I don't recall any specifics about(25) that, but it's possible.

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(2) Q. Have you ever received any (3) communications of any kind from Mr. Suson in (4) written form? (5) A. Yes. (6) Q. Do you recall generally what those (7) were? (8) A. Well, I can't give you specifics, (9) but the general theme was we got letters -- I(10) received letters from him, you know, protesting(11) that we didn't grant him this title and that he(12) had already been granted this by a previous(13) board and implying that I must have had(14) something against him when nothing could be(15) further from the truth.(16) Q. Do you have any knowledge whether(17) or not the previous board had discussed(18) Mr. Suson at all?(19) A. Well, what I was told by the(20) previous president, Kevin Gallagher, was there(21) apparently was a letter that had his signature(22) on it. He said he did not sign it. It was a(23) stamped signature and that he, nor the UFA, had(24) ever granted this quote unquote title, official(25) photographer, to the UFA to Mr. Suson.

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(2) Q. Do you know if Mr. Suson had access (3) to Ground Zero during the recovery period? (4) A. I never saw him there, but based on (5) photographs that apparently he has taken, he (6) obviously did have access. (7) Q. Do you have any idea how he was (8) allowed access to Ground Zero? (9) A. I only know what I was told. I was(10) told that Mr. Sanfilippo helped to facilitate(11) that for him.(12) Q. Who told you that?(13) A. Mr. Sanfilippo told me that.(14) Q. I'm going to ask you to look at(15) certain exhibits that are in these binders(16) here. The first one is going to be on that(17) top -- and by the way, if you need a break at(18) any time, we've been going for an hour, just(19) let me know.(20) A. I'm okay.(21) Q. You'll see on the right there are(22) numbers, pages in between are numbered. Those(23) are sequential exhibits. I'm looking for(24) Exhibit 11.(25) A. (Reviewing.)




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(2) Yes, I've read it. (3) Q. Have you ever seen this letter (4) before? (5) A. Yes, I have. (6) Q. Do you recall when the first time (7) was that you saw the letter? (8) A. Not specifically, but back during (9) this -- the first time Mr. Suson's name came(10) up, this letter was shown to me as -- I believe(11) by Mr. Sanfilippo that he had already been(12) granted this access, quote unquote this title(13) that he was looking for.(14) Actually, the letter doesn't grant(15) him a title. It's just a de facto endorsement(16) of some kind.(17) Q. Do you recall whether or not(18) Mr. Sanfilippo asserted that the letter did(19) grant him the title?(20) A. He -- he wanted us to grant him(21) that title as the official photographer of UFA.(22) Q. "He" being Mr. Sanfilippo?(23) A. Mr. Sanfilippo. He pointed to this(24) letter as the reason we should do that. One of(25) the first things I did was call Mr. Gallagher

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(2) and Mr. Gorman. Mr. Gallagher said that -- (3) after reviewing it, said that that's a stamp. (4) It's not his signature. He never stamped that (5) letter or authorized that it be stamped. (6) When I spoke to Mr. Gorman, he said (7) Rudy Sanfilippo showed up at his office with (8) this letter with Kevin Gallagher's name on this (9) side. The letter already drawn up and asked(10) Pete to sign it. He said -- Pete told me that(11) he signed it because he thought that if it was(12) okay with Kevin, it was okay with him.(13) Q. Did you ever discuss with Mr.(14) Sanfilippo whether or not he knew how it came(15) to be that Mr. Gallagher's signature or stamp(16) ended up on the letter?(17) A. No.(18) Q. Do you know, other than bringing(19) the letter to Mr. Gorman, what role(20) Mr. Sanfilippo played in either writing or(21) procuring the letter?(22) A. I don't. I know that the(23) secretary -- the presidential secretary for the(24) UFA who is Fern Iodice, who was Kevin's(25) secretary. She's been the secretary for the

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(2) president of the UFA for some 20 years. She (3) told me she didn't draft this letter and she (4) did not put Kevin's stamp on that letter. (5) So no one connected with the office (6) of the president knew of this letter or either (7) stamped it or signed that letter. And, as I (8) said, Mr. Gorman told me point blank the reason (9) he signed it was because Rudy brought it to(10) him, showed it to him and said Kevin is okay(11) with this.(12) Q. Do you know whether or not there(13) was any effort to search to see if the UFA had(14) a copy of this letter in its files?(15) A. I think we did make a search and(16) didn't have a copy.(17) Q. Do you recall Mr. Gorman mentioning(18) anything else about the letter when you asked(19) him about it other than the fact of the(20) circumstances under which he signed it?(21) A. Well, what he said to me was(22) that -- in April of 2002 we were still in the(23) midst of a catastrophe. There was much work to(24) be done for the families of 343 firefighters.(25) This didn't seem like an important fact. He

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(2) wasn't going to pick up the phone and call (3) Kevin and have a discussion. He saw Kevin's (4) signature on it. He read the letter. He (5) didn't think it was a big deal. He signed it. (6) Q. Did he mention whether or not he (7) had heard the name Gary Suson? (8) A. I don't recall him ever saying he (9) knew or did not know Mr. Suson.(10) Q. How about Kevin Gallagher, do you(11) recall whether or not he said he knew the name(12) Gary Suson when you asked him about the letter?(13) A. To be honest, I don't know what(14) Kevin said about that. I don't know if he ever(15) raised that topic. He just was very clear that(16) he absolutely did not sign this letter. It's a(17) stamp and he did not authorizes it to be(18) stamped.(19) Q. Did you send the letter to(20) Mr. Gallagher at some point so he could review(21) it?(22) A. Absolutely.(23) Q. When he reviewed it, did he tell(24) you whether or not he had ever seen it before?(25) A. He said he had never seen it before


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(2) and he made clear it wasn't his signature. It (3) was a stamp and he did not authorize it to be (4) stamped and, again, as I said earlier, that's (5) when we discussed it with his secretary, who is (6) not my secretary and she said absolutely she (7) did not stamp it. (8) Q. In the context of when you made (9) these efforts to investigate the letter, was it(10) because Mr. Sanfilippo brought it to your(11) attention or some other reason?(12) A. Yeah, it was because Mr. Sanfilippo(13) brought it to our attention. He was trying to(14) secure from the UFA some endorsement for(15) Mr. Suson as the official photographer of the(16) UFA.(17) He used this as his argument that(18) we had already, you know, agreed to support(19) Mr. Suson in some way down at Ground Zero. So(20) with a little research we found out that the(21) former president said it's not true. And that(22) Pete Gorman, the president of the Fire(23) Officers, said he only signed it is because(24) Rudy brought it to him and it had Kevin's(25) signature on it.

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(2) Q. And it was Mr. Sanfilippo who gave (3) you a copy of the letter the first time? (4) A. Yes. (5) Q. Do you have any idea who generated (6) the letter, actually wrote the letter? (7) A. No. (8) Q. Would a letter with a joint (9) announcement by the two unions be typical,(10) something that's done with frequency?(11) A. We have letterhead that says this,(12) Uniformed Fire Officers and the Uniformed Fire(13) Firefighters. We have joint stationery so that(14) if we are going to put out an announcement that(15) the UFOA is going to join us in, we can do that(16) without having to send it down to them and back(17) and forth.(18) They have the same joint stationery(19) so if they're going to put out an announcement(20) that we're going to support them in and we(21) agree that it's a joint thing, they can print(22) it up and send it out themselves.(23) Q. In those instances, you don't have(24) a stamp of the signature of the president from(25) the UFOA, do you?

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(2) A. You know, to be honest, I'm not (3) sure of the answer. It's possible we do, but (4) I'm not sure. (5) Q. Do you have a stamp of your (6) signature that's been made? (7) A. There is a stamp of my signature. (8) I don't have it. My secretary has it. (9) Q. Do you know if there's one stamp or(10) more than one stamp?(11) A. I don't know the answer to that.(12) Q. Generally, who would be authorized(13) to use the stamp that your secretary has?(14) A. Only she would. There is a stamp(15) of my signature that is used by the treasurer's(16) office for checks that require my signature and(17) there is a procedure in the UFA that there are(18) three signatures required for checks over(19) $5,000 and in some cases a stamp can be used.(20) The three signatures are the president, the(21) treasurer and the chairman of the board of(22) trustees.(23) So some -- there is a stamp for(24) each one of those people. I think that stamp(25) is different from the one that my secretary

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(2) has. (3) Q. Generally, do you know whether or (4) not they ever stamp your name without your (5) knowledge; "they" being the secretary or the (6) treasurer? (7) A. I think the answer to that is (8) probably they do on occasion. (9) Q. You mentioned Rudy Sanfilippo. You(10) worked together at the UFA, right? He was the(11) Manhattan trustee?(12) A. Yes.(13) Q. Did you have a good working(14) relationship?(15) A. I would say no.(16) Q. And why is that?(17) A. It just wasn't. It was adversarial(18) from the beginning. I can't really give you(19) any details as to why it was that way. It just(20) was.(21) Q. Is there any incident that took(22) place to cause that initially?(23) A. Well, when I ran for president the(24) first time he campaign pain and supported the(25) person that I beat in the election.




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(2) Q. So, the first time you ran, just to (3) be clear, was in July of 2002? (4) A. Yes. (5) Q. Do you remember what was the name (6) of the opponent? (7) A. Bill Mirro. (8) Q. Did anything else happen between (9) you and Mr. Sanfilippo to cause any kind of(10) problems?(11) A. After I was elected president, he(12) wanted to be the chairman of the board, which(13) is a position -- the chairman of the board is(14) elected by the five borough trustees. That(15) particular person represents them as a group(16) and sits on the fire department pension board,(17) which involves both investments and disability(18) issues.(19) He wanted that position. He did(20) not win that election internally and I think he(21) blamed me.(22) Q. Did he believe you were opposed to(23) him getting it?(24) A. Well, I didn't want him to get the(25) position, but I didn't have any votes, so --

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(2) Q. Did Mr. Sanfilippo at any point (3) ever file formal charges against you? (4) A. He did. He tried to have me (5) impeached. (6) Q. Do you recall when that was? (7) A. I would say shortly before my (8) election in 2005. So it could have been early (9) 2005 or late 2004.(10) Q. What generally was the nature of(11) his complaint against you?(12) A. He had three or four charges. I(13) can't remember the specifics. They were(14) frivolous. They were all dismissed.(15) Q. And by formal charges, is there a(16) procedure to deal with that at the UFA?(17) A. There is. There is a procedure to(18) file impeachment charges that is written in the(19) constitution. I will say that he never brought(20) any of his concerns ever to a board meeting(21) where the elected members of the board could(22) have debated whether or not there was any merit(23) to that.(24) What he did was file charges and(25) raise it at a union meeting, having not raised

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(2) it at an executive board meeting with the (3) people that he works with every day. (4) Q. In order to initiate formal charges (5) does he just -- how does that procedure work? (6) A. You know, I'd have to look at the (7) constitution to refresh my recollection. But (8) he had to notify me. He had to put them in (9) writing. He had to announce it at a union(10) meeting. There are some protocols for it, but(11) as I said what he didn't do was he never(12) discussed it with anybody on the executive(13) board before he did it.(14) Q. And then is there a body that looks(15) into it and investigates it?(16) A. Well, the answer is that the(17) membership would vote on the charges.(18) Q. And did that take place in this(19) instance?(20) A. It did. He withdrew either one or(21) more than one of the charges and whatever ones(22) that were remaining were voted down.(23) Q. Do you recall generally what kind(24) of a vote was it? Was it --(25) A. It was virtually unanimous.

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(2) Q. Do you have any recollection as to (3) whether or not this procedure was before or (4) after Mr. Sanfilippo approached you with (5) Exhibit 11? (6) A. It's after. (7) Q. After? (8) A. Absolutely. (9) Q. After the filing of these charges,(10) did you have much interaction with(11) Mr. Sanfilippo?(12) A. Not really, not much.(13) Q. Again, you believe it was pretty(14) close to the next election in 2005?(15) A. It was. It was leading into that,(16) for sure.(17) Q. In addition, you have testified(18) that you spoke to Mr. Gorman and Mr. Gallagher(19) and you spoke to the secretary Fern and that(20) somebody made a search for the letter.(21) Do you recall whether or not you(22) took any other steps in terms of verifying or(23) researching this letter?(24) A. Well, other than reporting to the(25) executive board what I had found and what I was


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(2) told by both Mr. Gallagher and Mr. Gorman. (3) Q. And when you reported to the (4) executive board was it at the meeting where (5) Mr. Sanfilippo was trying to get Mr. Suson to (6) be appointed? (7) A. It was either that meeting or the (8) subsequent meeting where the topic was still on (9) the agenda. This may not have been resolved in(10) one meeting. As a matter of fact, the more I(11) think about it, I'm sure it dragged on for a(12) period of time while both Mr. Gallagher and(13) Mr. Gorman were spoken to, a search for the(14) document was done, my secretary was(15) interviewed. So I'm sure it was at least over(16) two meetings.(17) Q. When you say your secretary was(18) interviewed, was that by you?(19) A. By me and I believe also by Mike(20) Block, my attorney.(21) Q. After the investigation was done,(22) is that when the vote was taken?(23) A. Yes.(24) MR. CONTI: If you don't mind,(25) let's just take a short break at this

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(2) time. (3) (Recess taken.) (4) Q. Mr. Cassidy, earlier you testified (5) that the board, the UFA board, discussed (6) Mr. Suson on a couple of occasions? (7) A. Yes. (8) Q. Are there minutes of those (9) meetings?(10) A. There should be and one of the(11) things I said earlier I wanted to clarify. I(12) said there was a vote. There certainly was a(13) discussion of the topic. I can't be certain it(14) was a vote because it may have been that(15) Mr. Sanfilippo couldn't even get a second to(16) have a vote, so there may not have technically(17) been a vote not to do this.(18) It's my belief that there was a(19) vote and we voted not to do it, but certainly(20) the action was the board had decided not to(21) grant Mr. Suson the title of official(22) photographer for the UFA, which Mr. Sanfilippo(23) was trying to secure for him.(24) Q. And, again, minutes are kept as a(25) regular course of business for these meetings;

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(2) is that correct? (3) A. Yes. (4) Q. Do you know whether or not there (5) are minutes that reflect any discussions (6) regarding Mr. Suson? (7) A. I haven't looked at the minutes (8) from, you know, back then, but there should be (9) minutes.(10) MR. LEFKOWITZ: Are you moving on(11) to another topic now?(12) MR. CONTI: Yeah.(13) + MR. LEFKOWITZ: Before we do(14) that, I want to put on the record, please(15) look for minutes of these board meetings.(16) THE WITNESS: I absolutely will.(17) It never even crossed my mind to do so.(18) Q. So, you've testified that it came(19) up before the board. Was Suson ever the(20) official photograph at Ground Zero for the UFA?(21) A. No.(22) Q. Has the UFA ever had an official(23) photographer at Ground Zero?(24) A. No.(25) Q. Has the UFA ever had an official

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(2) photographer in general? (3) A. No. (4) Q. I'd like you to turn to Exhibit 24 (5) which is going to be in that same binder there. (6) A. Yes. (7) Q. If you could take a look at that. (8) A. Okay. (Reviewing.) (9) Okay.(10) Q. Have you ever seen this document(11) before?(12) A. I don't recall ever seeing it(13) before.(14) Q. Are you familiar at all with the(15) dispute that's described in this letter?(16) A. Mr. Butler has told me that it's(17) his belief that Mr. Suson is talking about(18) somebody else, has him mistaken for somebody(19) else.(20) Q. Does Mr. Butler know who that other(21) person is?(22) A. No.(23) Q. Do you know whether or not Tom(24) Butler spoke with the Associated Press on(25) August 28, 2005 as is asserted in the first




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(2) sentence of this letter? (3) A. I don't know. I know that there (4) was things going back and forth as it relates (5) to this museum workshop or something that (6) Mr. Suson was doing where we were called for (7) comments and Mr. Butler may have commented. (8) Q. Do you recall whether or not you (9) ever spoke with Tom Butler in August of 2005(10) about Gary Suson?(11) A. Mr. Butler was, in the scheme of(12) things, briefed as to what the board had(13) decided about this topic. He had discussions(14) with me and with other board members and(15) certainly with Michael Block, our counsel, as(16) to what the UFA board's decision was, about(17) what research we had done into the previous(18) letter that has Mr. Gallagher's stamp and(19) Mr. Gorman's signature.(20) So, Tom was aware of what had(21) transpired and what the UFA had decided in(22) relationship to whether or not we were going to(23) grant Mr. Suson the title of official(24) photographer for the UFA and, so, he was(25) clearly up-to-date on all of that.

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(2) Q. As of August 2005 had the board (3) already made a determination? (4) A. Yes. (5) Q. Do you recall how much earlier it (6) had been? Was it a year? (7) A. You know, I'd be guessing. I think (8) it's a year earlier, but to be honest, I can't (9) recall exactly.(10) Q. Do you recall whether or not(11) Mr. Butler was briefed on this at the time it(12) happened or in reference to any of inquiries(13) that might have come in in August of 2005?(14) A. No, he was certainly briefed on it(15) as it happened.(16) Q. Do you recall one way or the other(17) whether or not Mr. Butler had contacted you in(18) August of 2005 saying that there had been press(19) inquiries related to Mr. Suson?(20) A. I don't remember him specifically(21) doing it, but I'm sure he did.(22) Q. In the first line of the last(23) paragraph Mr. Suson states, "I was the official(24) photographer at Ground Zero for the UFA."(25) A. I see that.

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(2) Q. Do you see that? (3) A. Yes. (4) Q. Is that accurate? (5) A. No. (6) Q. If you could turn to Exhibit 25. (7) A. Okay. (8) Q. It's a one-page document. It (9) should say "Fax to James Spollen."(10) A. Yup.(11) Q. If you would just review that.(12) A. (Reviewing.)(13) Yes.(14) Q. Do you recall if you've ever seen(15) that document before?(16) A. No. I don't recall ever seeing(17) that letter.(18) Q. Read the first sentence, "If(19) Mr. Butler has any concerns over the legitimacy(20) or the purpose of anything that I am doing, I(21) would ask that he contact me directly as(22) opposed to calling major media to give what can(23) only be deemed as 'misinformation.' It is(24) humiliating and counterproductive for all(25) parties involved."

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(2) Do you know what Mr. Suson is (3) referring to in that statement? (4) A. No. (5) Q. Do you know as of August of 2005 if (6) the UFA had any concerns over the legitimacy of (7) Mr. Suson's museum or his assertion that he was (8) the official photographer for the UFA? (9) A. My recollection is that we received(10) inquiries concerning the museum. I believe(11) that is because he was displaying artifacts(12) that he either directly or indirectly got from(13) Ground Zero and when questioned about that, it(14) was noted that Mr. Suson was saying he was the(15) official photographer of the UFA.(16) It's my recollection that(17) Mr. Butler refuted that and maybe that's what(18) this letter is in reference to.(19) Q. Do you have any recollection as to(20) who brought Mr. Suson and his museum to the(21) attention of the UFA?(22) A. I think it was the media.(23) Q. What agency or news agency?(24) A. I think there was more than one but(25) I know for certain that the New York Post


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(2) brought it to our attention. Let me say this, (3) the New York Post certainly asked us to comment (4) on it. I think there were others, also. (5) Q. Prior to any New York Post inquiry, (6) do you know if any other New York media (7) entities had asked the UFA to comment? (8) A. Not specifically. (9) Q. Do you have any knowledge of(10) whether the Associated Press had asked the UFA(11) to comment?(12) A. I don't recall specifically, but I(13) wouldn't be surprised if it did.(14) Q. Do you have any knowledge whether(15) or not Mr. Butler sought out the media to(16) discuss Mr. Suson?(17) A. I don't believe he did.(18) Q. Do you ever speak with Mr. Spollen(19) about this document marked as Exhibit 25?(20) A. I remember -- I don't remember(21) speaking to him about this document, but I do(22) remember him commenting to me that Mr. Suson(23) had contacted him or sent him something. I(24) assume it's in reference to this.(25) Q. Do you recall the nature of any

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(2) conversation with Mr. Spollen about Mr. Suson? (3) A. What Mr. Spollen had told me is the (4) same thing that Mr. Butler had told me, that (5) Mr. Suson had continued to refer to Mr. Butler (6) as having met down at Ground Zero and that both (7) of them believe that he's mistaken; that he (8) must have been talking about somebody else. (9) Tom Butler had said to me point(10) blank, "I never met the man before in my life.(11) I don't know what he's talking about."(12) Q. Do you recall who first heard that(13) Mr. Suson was opening a museum and brought it(14) to the UFA's attention?(15) A. I'm not sure.(16) Q. Do you recall having any(17) discussions with Mr. Butler in August of 2005(18) about Mr. Suson?(19) A. I'm sure we did, now that I'm(20) looking at these documents. I do recall that(21) our fire marshal representative, Lester Layne,(22) had said that the fire marshals were(23) considering going to arrest Mr. Suson for(24) having artifacts from Ground Zero.(25) I don't recall if that ever

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(2) happened, but I remember him saying that they (3) were talking about doing that. (4) Q. Do you believe that came from (5) Mr. Butler? (6) A. No, that came from Lester Layne who (7) is the fire marshal rep. (8) Q. Do you know if any action was (9) ultimately taken?(10) A. I don't know. I don't recall.(11) Q. Do you know if Mr. Spollen(12) conducted any research or investigation once it(13) was brought to the UFA's attention that(14) Mr. Suson had opened a museum?(15) A. Say that again.(16) Q. Do you know if Mr. Spollen had(17) taken any actions in researching Mr. Suson or(18) the past issue, when the fact that Mr. Suson(19) was opening a museum came to the UFA's(20) attention?(21) A. I don't know the answer to that.(22) Q. Do you know if Mr. Butler conducted(23) any kind of investigation as to the details?(24) A. If you mean by "investigation" did(25) they discuss with either me or Mike Block as to

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(2) what was happening on this issue? (3) Q. Yes. (4) A. Or a rehash of what had previously (5) happened in terms of our decisions, the answer (6) to that is yes. (7) Q. But you don't recall the (8) conversations with either Mr. Butler or Spollen (9) in August of 2005 about Gary Suson?(10) A. Well, in this timeframe I remember(11) that this became -- this topic popped up again(12) when we were notified that Mr. Suson was(13) opening up this "museum." And it was, you(14) know, again, the same topic; his claim that he(15) was the official photographer for the UFA at(16) Ground Zero, which was not true.(17) So, other than the rehash of what(18) had gone on prior to that, whether a year(19) before or whenever, I don't know of any other(20) research into that.(21) Q. I'm going to have you quickly take(22) a look at Exhibit 152, which would be in that(23) second binder in front of you.(24) A. This one?(25) Q. Yeah.




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(2) A. Okay. (3) Q. Quickly just review this one-page (4) document. (5) A. (Reviewing.) (6) Okay. (7) Q. Have you ever seen this document (8) before? (9) A. I haven't seen it, but -- not(10) before.(11) Q. It's a one-page document e-mail(12) from Mr. Suson to Jim Spollen and in the first(13) paragraph, "If you would be so kind as to ask(14) Mr. Cassidy to call me as soon as possible(15) regarding erroneous and slanderous remarks made(16) yesterday to the Associated Press from Tom(17) Butler, Re: Ground Zero museum workshop and(18) myself."(19) Do you recall whether or not(20) Mr. Spollen ever discussed this document with(21) you or this request from Mr. Suson that you(22) call him?(23) A. I do remember that he did speak to(24) me about being contacted by Mr. Suson now that(25) I read this e-mail. I don't believe I've read

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(2) it before, but I do remember having a (3) conversation with Jim Spollen about this. (4) Q. Do you recall what the nature of (5) the details of the conversation were? (6) A. Just him updating me that Mr. Suson (7) had e-mailed him and, you know, was a rehash of (8) what we had already decided. He continued to (9) say that he had been granted, you know, the(10) title of official photograph of the UFA, even(11) though we know that not to be the case and we(12) made that clear to him not to go forward with(13) saying that. It was just an update that, you(14) know, this topic was, again, on the -- in the(15) media.(16) Q. Right. Do you know whether or not(17) Mr. Butler spoke with the Associated Press as(18) Mr. Suson asserts?(19) A. I don't know that.(20) Q. And did you ever contact Mr. Suson(21) as he had requested?(22) A. No, I don't believe I did.(23) Q. Why is that?(24) A. This is an item that we had already(25) discussed as a board, had decided that he was

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(2) not going to have the title of official (3) photograph. It was past business. It was (4) done. The fact that it was back in the media (5) did not change our opinion or my opinion about (6) what we had already decided. (7) Q. I'm going to have you look at (8) Exhibit 26. You don't have to have read the (9) whole thing through, but if you could quickly(10) glance at it.(11) A. (Reviewing.)(12) Who is this to? Who is James,(13) James Spollen?(14) Q. It's a one-page document. At the(15) top it's a forwarded e-mail from Mr. Suson to(16) Mr. Butler but right underneath there's an(17) e-mail that shows it's from Ground Zero museum(18) to J. Spollen. It appears to be Mr. Spollen(19) and T. Farinela?(20) A. I got you. Let me just take a(21) quick look. (Reviewing.)(22) Okay.(23) Q. Is your e-mail address(24) [email protected]?(25) A. Yes, it is.

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(2) Q. Do you recall whether you ever (3) received this document? (4) A. I don't recall ever receiving it. (5) Q. And you don't recall reading it (6) then, I suppose? (7) A. I definitely do not recall reading (8) it. (9) Q. Do you recall whether or not you(10) discussed the e-mail at all with anyone?(11) A. Again, I remember the topic being(12) discussed at this point in time that Mr. Suson(13) continued to say that he was the official(14) photographer of the UFA and that we, the UFA,(15) were saying that was absolutely not true, which(16) seemed to be causing much of this back and(17) forth in the media. That's my recollection.(18) Q. Right, I quote from the second(19) sentence, "I thought we had a very positive and(20) productive phone call yesterday and yet today I(21) heard shocking news from the New York Post.(22) The UFA stated to the New York Post, who is(23) making a routing" it should be "routine" "phone(24) call on fact checking that 'Gary Suson was not(25) the official photographer on behalf of the


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(2) Uniformed Firefighters Association at Ground (3) Zero. In addition we are sending a cease and (4) desist letter to him." (5) Do you have any idea what Mr. Suson (6) is referring to in terms of a "very positive (7) and productive phone call yesterday"? (8) A. No, I don't. (9) Q. Do you know if Mr. Suson had spoken(10) to anyone at the UFA at the end of August 2005?(11) A. Well, I think it's -- it seems that(12) he had a conversation with Mr. Spollen.(13) Q. Do you know whether or not he did?(14) Do you know any details of any kind of(15) interaction?(16) A. I believe he did have a(17) conversation with Mr. Spollen because it was(18) clear to me that he wanted to speak to me.(19) From the previous exhibit he wanted to speak to(20) me, and Mr. Spollen, one of his jobs is to act(21) as an intermediary. I did not speak to him. I(22) guess he's referencing a phone call that he had(23) with Jim Spollen.(24) Q. Do you know any knowledge as to why(25) it might have been perceived as positive and

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(2) productive by Mr. Suson. (3) A. No, I don't. (4) Q. In the fourth paragraph down, (5) there's a sentence, "I will always be the (6) official photographer of record at Ground Zero (7) on behalf of the UFA/UFOA and nothing will (8) change that." (9) Is that an accurate statement?(10) A. No, it's absolutely not an accurate(11) statement.(12) Q. Could I have you go to Exhibit 27?(13) A. Yeah.(14) Q. Just review that letter.(15) A. (Reviewing.)(16) Okay.(17) Q. Do you remember ever seeing this(18) document before?(19) A. Yes.(20) Q. At the end of the document there's(21) a cc line to Mr. Steven J. Cassidy. Do you(22) know if it was sent to you?(23) A. I believe it was.(24) Q. Pull it out of the sleeve.(25) A. Yes, okay.

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(2) Q. Do you recall receiving the letter? (3) A. Yes. (4) Q. Did you know that this letter was (5) being sent by Mr. Block before it went out? (6) A. Yes, I did. (7) Q. Do you know who made the decision (8) to make this -- to send this letter? (9) A. I did in conjunction with my(10) executive board.(11) Q. Do you know whether or not it was(12) discussed in a board meeting?(13) A. I don't remember if it was(14) specifically discussed at a board meeting, but(15) it was discussed with certain board members for(16) sure and I, as the president, certainly had the(17) authority to ask our attorney to send a letter(18) like this.(19) Q. So, the letter was sent under your(20) authority?(21) A. Absolutely.(22) Q. Why was this letter sent, what(23) motivated the letter?(24) A. Because this topic continued to(25) come up, that Mr. Suson was continuing to claim

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(2) that he was the official photographer for the (3) Uniformed Firefighters Association so we got to (4) a point in time where just having said -- (5) having thought that we resolved this issue (6) earlier by making clear at a board meeting that (7) he was not and allowing Mr. Sanfilippo to (8) communicate that to him, that we needed to do (9) it in a more formal way and Mr. Block drafted(10) this letter and sent it to him.(11) Q. Do you know when the decision was(12) made to send this kind of a letter?(13) A. When?(14) Q. Yes.(15) A. It was probably made the day before(16) or that day. I'm sure Mr. Block did it(17) immediately when asked to do so.(18) Q. Did you have any discussions with(19) Mr. Suson about this letter at any point?(20) A. I don't believe I did.(21) Q. Do you know if anyone associated(22) with the UFA ever had any discussions regarding(23) this letter?(24) A. I'm not aware of any specific(25) discussions. It wouldn't surprise me if either




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(2) Mr. Spollen or Mr. Block or Mr. Butler spoke to (3) him about this. (4) Q. Was this letter motivated in any (5) way by a desire to get back at or lash out at (6) Rudy Sanfilippo? (7) A. Absolutely not. (8) Q. Look at the last paragraph on the (9) second page?(10) A. Okay.(11) Q. "Please consider this letter a(12) demand on behalf of the Uniformed Firefighters(13) Association that you immediately cease and(14) desist from referring to yourself or(15) representing yourself as the 'official(16) photographer' for the Uniformed Firefighters(17) Association in any context."(18) Does this statement accurately(19) reflect the position of the board as to(20) Mr. Suson?(21) A. Yes, it does.(22) Q. If you could then look at Exhibit(23) 28. This also has a few pages if you want to(24) take it out.(25) A. (Reviewing.)

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(2) Okay, yes. (3) Q. Have you ever seen this document (4) before? (5) A. Yes. (6) Q. Did you know about this letter (7) before it was sent to Mr. Suson? (8) A. Yes. (9) Q. Did you authorizes this letter to(10) be sent?(11) A. Yes.(12) Q. What was the reason that this(13) letter was sent?(14) A. Again, to clarify for -- again, to(15) clarify this particular issue with Mr. Suson(16) claiming that he was the official photographer(17) for the UFA. He had now apparently sent us(18) some checks to the UFA Widows and Childrens(19) Fund and this letter clarified that although we(20) appreciated it, we could not accept it as he(21) was continuing to say he was the official(22) photographer for the UFA.(23) Q. So in November of 2006, more than a(24) year after the initial cease and desist letter,(25) Mr. Suson was still claiming he was the

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(2) official photographer? (3) A. Yes. (4) Q. And the board continued to take the (5) position that that was inaccurate? (6) A. Absolutely. (7) Q. If you could take a look at Exhibit (8) 164, which is going to be in that other binder (9) which you have open there still.(10) A. Okay.(11) Q. If you want to take a quick look at(12) this from below the "Good morning Linda" line,(13) just that next e-mail portion.(14) A. (Reviewing.)(15) Okay.(16) Q. Have you seen this document before?(17) A. Yes.(18) Q. Did you read this document?(19) A. I did.(20) Q. It's an e-mail from Mr. Gallagher(21) and you in addition to other folks who have(22) been CC'd. Do you know if you replied to(23) Mr. Gallagher?(24) A. I don't know if I replied in the(25) form of an e-mail but I did speak to him about

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(2) the topic. (3) Q. Do you remember the details of the (4) conversation with Mr. Gallagher? (5) A. Just a rehash of what we had (6) previously discussed, that he had never (7) authorized his stamp to be on such a letter, (8) that he never signed that letter and that he (9) didn't know anything about this guy and that(10) the UFA, prior to me being the president, did(11) not grant Mr. Suson the title of official(12) photographer in the UFA.(13) Q. Did you speak with anyone else when(14) you got this e-mail?(15) A. Pardon me?(16) Q. Did you speak with anyone else(17) about Mr. Suson when you got the e-mail?(18) A. I'm sure I spoke to my attorney,(19) Mike Block, but I don't remember any specifics.(20) Q. Did you do anything else as a(21) result of the e-mail, contact Mr. Suson, for(22) example?(23) A. I don't believe so.(24) Q. Did Mr. Sanfilippo ever state that(25) he had appointed Mr. Suson the official


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(2) photographer at Ground Zero for the UFA? (3) A. I don't recall him ever saying (4) that. (5) Q. As the Manhattan trustee for the (6) UFA, would he have been authorized to have (7) appointed Mr. Suson under the constitution and (8) the general procedures of the UFA, Mr. Suson as (9) the official photographer?(10) A. Absolutely not.(11) Q. So, to your knowledge, there's(12) nothing in Mr. Sanfilippo's job duties at the(13) time, meaning the trustee position, that would(14) have authorized him or allowed him to have(15) appointed Mr. Suson as the official(16) photographer?(17) A. He absolutely would not have been(18) allowed to do so.(19) Q. If you could take a look at Exhibit(20) 108.(21) A. (Reviewing.)(22) Okay.(23) Q. Have you ever seen this document(24) before, marked as Exhibit 108?(25) A. I do believe that it was shown to

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(2) me, yes. (3) Q. Do you remember when it was shown (4) to you? (5) A. Sometime after it was written. (6) Q. Reading from the second paragraph, (7) "In my capacity as an elected representative (8) for New York City firefighters, I interviewed (9) Gary and reviewed some photos he had taken in(10) the first days following 9/11/01. After some(11) lengthy discussions, we outlined the guidelines(12) for this work and agreed to introduce him to(13) certain members and chiefs at the site so that(14) he could record a truthful as well as sensitive(15) photo account."(16) Do you know anything about any(17) guidelines that Mr. Sanfilippo discussed with(18) Mr. Suson?(19) A. I don't, and it's interesting to me(20) that he says, "I interviewed Gary and reviewed(21) some photos he had taken in the first days(22) following 9/11" and then it says "after some(23) lengthy discussions, we outlined the guidelines(24) for his work." I have no idea who "we" is.(25) Q. Would "we" refer to anyone at the

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(2) UFA, to your knowledge, other than (3) Mr. Sanfilippo? (4) A. My knowledge no one at the UFA, (5) other than Mr. Sanfilippo, had anything to do (6) with Mr. Suson gaining access to Ground Zero (7) and there was no one on the board who wanted (8) him to have the official title of photographer (9) of the UFA, official photographer of the UFA.(10) Q. Do you know anything about the(11) guidelines that are referred to in this letter?(12) A. I have no idea what he's talking(13) about.(14) Q. Towards the end of the document it(15) says in quotes, "In closing, may I state simply(16) Gary Suson was the official photograph for the(17) UFA at Ground Zero."(18) Is that an accurate statement?(19) A. That's absolutely not true.(20) Q. Was Mr. Sanfilippo authorized to(21) make such an assertion on behalf of the UFA?(22) A. Absolutely not.(23) Q. Do you ever recall discussing this(24) letter with Mr. Sanfilippo at any point?(25) A. No.

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(2) Q. Take a look at Exhibit 107. Take a (3) quick glance at that. (4) A. (Reviewing.) (5) Okay, I'm good. (6) Q. Have you ever seen this document (7) before? (8) A. I don't recall seeing this (9) document.(10) Q. I'm going to read from the first(11) paragraph. It's a sentence, "It is sad that I(12) am in the middle of nothing more than a(13) vendetta between one insecure union official(14) and another former union member."(15) Do you have any idea what that(16) references from Mr. Suson's statement in that(17) letter?(18) A. It's -- I don't know what it(19) references and it's not a true statement. Our(20) actions as the UFA executive board were simply(21) to make clear that a claim that Mr. Suson had(22) been making for some years was not accurate.(23) It had nothing to do with Rudy Sanfilippo.(24) Rudy Sanfilippo may have been the(25) conduit for Mr. Suson to think he was the




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(2) official photographer for the UFA, but our (3) actions had nothing to do with Rudy Sanfilippo. (4) It had to do with simply with (5) whether or not the UFA thought it was prudent (6) to grant that title to anyone. We didn't and (7) we voted on that or decided on that as a board (8) and that's all it was about. It's not about (9) any vendetta.(10) Q. Reading from the last paragraph,(11) "It is only now since Mr. Sanfilippo's(12) departure that they all of a sudden 'didn't(13) know I was official' as was told to me(14) yesterday James Spollen, Mr. Cassidy's(15) assistant."(16) Is that an accurate statement?(17) A. No.(18) Q. Had the UFA board determined prior(19) to August of 2005 that Mr. Suson was not the(20) official photographer?(21) A. Absolutely.(22) Q. Again, that had nothing to do with(23) the departure of Mr. Sanfilippo?(24) A. Absolutely not. It was decided(25) long before that while Mr. Sanfilippo was on

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(2) the board. He's the one who raised it. He (3) wanted a letter saying that he was the official (4) photographer and at that point in time this (5) whole discussion began, the research started. (6) I spoke to Kevin Gallagher. Pete Gorman found (7) out what they said about this topic. (8) It was discussed by the board and (9) the board decided not to grant him that status.(10) Q. The next sentence in the last(11) paragraph, "He also claimed he 'didn't know'(12) there was an official letter signed by a former(13) UFA president, Kevin Gallagher," and he is(14) referring to Mr. Spollen.(15) Do you know whether or not there is(16) an official letter signed by former UFA(17) president, Kevin Gallagher?(18) A. I think that references the former(19) document that has Mr. Gallagher's stamp on it.(20) Q. That would be Exhibit 11, the April(21) 2002?(22) A. Absolutely, but that document(23) doesn't say he's the official photograph of the(24) UFA as is outlined in the letter from Mr. Block(25) to Mr. Suson asking him to cease and desist.

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(2) Q. One other question. In the first (3) paragraph Mr. Suson asserts, "Just yesterday (4) UFA conveyed to me that this would be the end (5) of this issue and now here today their lawyer (6) states that a cease and desist letter is going (7) out and I am not the official photog." (8) Do you know what Mr. Suson is (9) referring to when he refers to the UFA(10) conveying the issue?(11) A. I have no idea what he's talking(12) about.(13) Q. Have you ever -- well, well, other(14) than Mr. Block, Mr. Gorman, Mr. Butler, and(15) Mr. Gallagher, do you recall whether or not you(16) discussed Mr. Suson with anyone else?(17) A. Well, it was discussed at a board(18) meeting, so, the members of the executive board(19) certainly new. I think you didn't mention Jim(20) Spollen, my executive, certainly he knew about(21) it, but I don't think it was a major topic of(22) discussion.(23) I mean, in the end, this is a small(24) thing, a blip on our radar screen that had to(25) be resolved. It's certainly not something we

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(2) tried to spend a lot of time on. (3) Q. Do you recall whether or not you (4) had any discussions with Frank Gribbon about (5) Mr. Suson? (6) A. I don't recall a specific (7) conversation with Frank Gribbon, but it is (8) certainly possible that the UFA reached out to (9) him to get their take on whether or not they(10) had granted Mr. Suson any status that we(11) weren't aware of.(12) Q. Do you know whether Mr. Gribbon had(13) asked you to meet with Mr. Suson?(14) A. Not to my recollection.(15) Q. For the record, again, you have(16) never met with Mr. Suson?(17) A. No, I don't believe I've ever seen(18) him before.(19) Q. Do you know what the Widows and(20) Childrens Fund is?(21) A. Yes. It's a 5013-C charitable(22) organization for the UFA.(23) Q. Generally what are its purposes and(24) goals?(25) A. We have raised significant amounts


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(2) of money for the widows and children of New (3) York City firefighters and fire officers killed (4) in the line of duty. (5) Q. So, following September 11th, that (6) charity raised a fair amount of money for the (7) families of the fallen firefighters? (8) A. It certainly did. (9) Q. Is the fund still in operation(10) today?(11) A. Yes, it is.(12) Q. Are you involved in this charity as(13) president of the UFA?(14) A. Yes, I am. I sit on the board.(15) Q. There's a separate board for the(16) charity?(17) A. Yes.(18) Q. Do you oversee the board or do you(19) act as its head?(20) A. I am one of several board members.(21) Q. Do you know if Mr. Suson has made(22) any donations to the UFA Widows and Childrens(23) Fund?(24) A. Other than those checks that were(25) part of one exhibit that we were returning, I'm

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(2) not aware of any contributions that he had (3) made. (4) Q. Do you have any idea approximately (5) how much money it might have been that was (6) donated by Mr. Suson? (7) A. I think it was just a few hundred (8) dollars that we had returned. I'm not aware of (9) anything else.(10) Q. Do you know whether or not the fund(11) received anything from a website called(12) september11.net?(13) A. I don't recall.(14) Q. Did Mr. Suson have any authority to(15) associate himself with the UFA Widows and(16) Childrens Fund?(17) A. Associate himself with the Widows(18) and Childrens Fund?(19) MR. LEFKOWITZ: Objection to form.(20) A. What do you mean by that?(21) Q. If you could turn to Exhibit 6. I(22) don't need you to read this document. I'm just(23) going to represent to you that it's a document(24) in a case captioned Van Wagner Kiosk(25) Advertising versus Gary Suson and that this

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(2) document is a document that is labeled as the (3) answer and it was signed by -- it has the (4) signature under the name Gary Suson. (5) If you go to the second page of the (6) document at the very top it states, "Gary (7) Suson, owner of Headshots.com Photography and (8) September11.net memorial website on behalf of (9) the Unformed Firefighters Association, Widows(10) and Childrens Fund, FDNY, acting on his own(11) behalf does respond to the allegations filed by(12) Van Wagner as follows."(13) Did Mr. Suson have the authority --(14) again, this document is from 2003, to associate(15) himself in the manner that I just read?(16) A. Absolutely not.(17) Q. Did Mr. Suson have any connection,(18) to your knowledge, to the UFA Widows and(19) Childrens Fund in 2003?(20) A. Absolutely not.(21) Q. I'm going to go a few pages from(22) there. It's the eighth page of the document --(23) actually the seventh page, I think. It's the(24) third from the back. And there's a letter O(25) there sort of in the middle of the page. "Gary

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(2) Suson regularly raises money for the UFA Widows (3) and Childrens Fund and also the Brian E. (4) Sweeney Memorial Fund through sales of his (5) books." (6) Do you know if that's accurate as (7) to the UFA Widows and Childrens Fund? (8) A. I'm not aware of him raising any (9) substantial amount of money for the Widows and(10) Childrens Fund. I wouldn't know if he made any(11) contributions on his own, but I'm not aware of(12) him making any significant contributions.(13) Q. Do you know if Mr. Suson ever had a(14) book published of his photographs?(15) A. I believe he did, but I'm not --(16) I've never seen it.(17) Q. Do you know whether or not the UFA(18) Widows and Childrens Fund ever received any(19) money as a result of the book sales or book(20) advance?(21) A. I don't know the answer to that.(22) Q. Do you know whether or not at some(23) point Mr. Suson made a request through your(24) lawyer, Michael Block, to meet with you at some(25) point or to meet with the board, actually?




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(2) A. I don't recall that specifically. (3) Q. Would it be typical to have (4) somebody come in and meet with the board? (5) Would you do that, have outside people come in (6) and meet? (7) A. Occasionally it happens. (8) Q. Do you know whether or not it was (9) discussed with the board as to whether or not(10) they'd like to have Mr. Suson come in and(11) discuss issues?(12) A. No, I don't believe it was ever(13) discussed or considered that we would bring him(14) in.(15) (Recess taken.)(16) Q. Mr. Cassidy do you recall whether(17) or not you were ever asked to comment on any(18) articles in the New York Post regarding Gary(19) Suson?(20) A. I don't recall.(21) Q. Have you ever spoken with Murray(22) Weiss?(23) A. I have spoken to Murray Weiss,(24) sure.(25) Q. Do you recall if you ever spoke

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(2) with him about Gary Suson? (3) A. I don't recall, to be honest. (4) Q. Have you ever spoken with Cynthia (5) Fagan? (6) A. I have. (7) Q. Do you know if you spoke with her (8) about Gary Suson? (9) A. I don't.(10) Q. Have you ever spoken with Stephanie(11) Gaskell?(12) A. Yes, I have.(13) Q. Have you ever spoken with her about(14) Gary Suson?(15) A. I don't recall if I ever spoke to(16) any of them about Gary Suson. I may have. I(17) just don't remember.(18) Q. Do you know if anyone at the UFA or(19) associated with the UFA spoke with a reporter(20) at the Post regarding Mr. Suson in August of(21) 2005 or September of 2005?(22) A. You know, I don't know the answer(23) to that.(24) Q. Let me show you Exhibit 100.(25) A. I got it.

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(2) Q. Just take a look at that article (3) and I'm referring to the article "9/11 Cam (4) Scam," the article that appears below. (5) A. Got you. (Reviewing.) (6) Okay. (7) Q. Do you recognize this article at (8) all? (9) A. I recall it.(10) Q. Do you know whether or not you(11) reviewed it before today?(12) A. I remember reading it when it came(13) out, absolutely.(14) Q. Do you remember whether or not you(15) had provided any information that's contained(16) in the article?(17) A. Directly, I don't remember(18) providing any information to this.(19) Q. I'm going to read a quote from the(20) first paragraph, "A Manhattan photographer is(21) improperly billing himself as the 'official'(22) photographer for the firefighters union and may(23) have illegally taken artifacts from Ground Zero(24) for his new 9/11 exhibition, the Post has(25) learned."

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(2) Was Mr. Suson at that time (3) improperly billing himself as the UFA (4) photographer at Ground Zero? (5) A. Yes, he was. (6) Q. Is that an accurate statement? (7) A. Yes, it is. (8) Q. Further on in the last column (9) there's a statement, "The photographer said a(10) fire chief - whose name he could not provide -(11) gave him permission to rummage through the(12) dumpster."(13) Do you know whether or not it was(14) appropriate for a fire chief to give permission(15) for someone working at Ground Zero to take(16) items out of a dumpster at Ground Zero for(17) their personal possession?(18) A. A fire chief didn't have the right(19) to do that and it seems improbable.(20) Q. The next paragraph states,(21) "Meanwhile, FDNY union officials are preparing(22) to send a letter to Suson demanding he stop(23) claiming he worked as their official(24) photographer."(25) As of August 31, 2005 do you know


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(2) that that statement was accurate? (3) A. That was accurate. (4) Q. A little bit further down, "Suson (5) says a 2002 joint 'letter of introduction' from (6) the UFA and the Uniformed Fire Officers (7) Association allows him to use the title (8) 'official' although the word appears nowhere in (9) the letter. Current union officials and the(10) FDNY said there was no such title but one(11) ex-union official told the Post that Suson was(12) given it."(13) Do you know the statement in those(14) paragraphs, as to whether or not there was no(15) such title are accurate?(16) MR. LEFKOWITZ: Objection to the(17) form.(18) A. Well, he was absolutely not given(19) the title of official photographer so as far as(20) it is outlined here, that's true. He was not(21) given that title.(22) Q. The next paragraph states, "Current(23) union officials in the FDNY also charge Suson(24) has not honored his pledge to donate thousands(25) of dollars in proceeds from his 9/11 artwork."

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(2) Do you know anything about that (3) assertion? (4) A. I don't know that he made an (5) assertion that he was going to donate (6) significant amounts of money. I do know that (7) we did not receive any significant amounts of (8) money, but that's all I know about that. (9) Q. Had Mr. Suson made an agreement to(10) donate money, is it your contention then that(11) he would not have satisfied that agreement(12) based on your --(13) A. I'm not aware --(14) MR. LEFKOWITZ: Objection.(15) A. I'm not aware of any agreement, but(16) if there was an agreement, he certainly didn't(17) send us any significant amounts of money.(18) Q. If you could turn to Exhibit 103.(19) A. Yup.(20) Q. If you could read the article in(21) the middle that says "9/11 Curr-ator."(22) A. (Reviewing.)(23) Okay.(24) Q. Do you recall whether or not you've(25) ever seen this article?

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(2) A. I remember when it came out, yes. (3) Q. Do you remember reviewing it at the (4) time it came out? (5) A. Yes. (6) Q. Do you know whether or not you (7) provided any information for the article (8) itself? (9) A. I don't recall providing any(10) information for this article.(11) Q. If you go to the second column(12) midway down, "Suson could not be reached for(13) comment. He previously said that he had(14) permission from an unnamed FDNY official to(15) take the items," referring to items at Ground(16) Zero.(17) Do you know whether or not any FDNY(18) official would have had permission to give(19) Mr. Suson that authority?(20) A. Absolutely. They would absolutely(21) not have the authority to give him permission(22) to take items from Ground Zero.(23) Q. The next column, "He," meaning(24) Mr. Suson, "claims that he was the 'official'(25) FDNY union photographer during the clean up

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(2) effort. FDNY officials dispute that claim, (3) however, saying Suson was never given any (4) official duties." (5) Do you know that statement to be (6) accurate? (7) A. It is accurate. (8) Q. "Suson has said that previous (9) officials at the Uniformed Firefighters(10) Association gave him the 'official title' and(11) one ex-union bigwig has confirmed that to the(12) Post."(13) Do you know if that statement is(14) accurate?(15) A. It's accurate insofar as no(16) executive board of the UFA or no one in(17) authority at the UFA ever granted him the(18) authority to use the title "official" as it(19) relates to the UFA in any manner, shape or(20) form.(21) Q. If you could please look at Exhibit(22) 106. Take a look at the article in the lower(23) right-hand corner entitled "9/11 Charity Big(24) Busted."(25) A. Okay (Reviewing.)




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(2) Okay. (3) Q. Do you recognize this article at (4) all? (5) A. I remember when it came out. (6) Q. Do you remember reading it when it (7) came out? (8) A. Yes. (9) Q. Do you know anything about its(10) subject, one of the subjects, Michael Bellone?(11) A. No.(12) Q. Had you ever heard the name before?(13) A. I don't recall ever hearing that(14) name before.(15) Q. The last sentence of this article(16) states, "Leaders of the union say Suson is not(17) its photographer." Is that an accurate(18) statement?(19) A. Yes.(20) Q. Have you ever read any other(21) articles, newspaper articles of any kind, about(22) Mr. Suson other than those in the New York Post(23) that you recall?(24) A. It's possible if there was articles(25) in other papers relating to him, I probably

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(2) read them. (3) Q. Do you regularly read the articles (4) in relation to the UFA or the fire department? (5) A. I do, every day. (6) Q. Does anyone prepare a collection of (7) articles for you to review? (8) A. On a daily basis we have articles (9) relating to the UFA, articles relating to(10) firefighting in New York City and some other(11) topics, e-mailed to me and the other board(12) members on a daily basis.(13) Q. Who generally puts that together,(14) who e-mails you?(15) A. It's somebody that we employ to do(16) that. I'm trying to think of his last name.(17) His first name is Bruce.(18) Q. We can leave a blank. If you think(19) of it, fill it in later.(20) + TO BE FURNISHED: ___________________________(21) Q. If any articles that you read in(22) reference to the UFA are inaccurate, do you(23) ever take any action to notify the media(24) entities?(25) A. Yes, we do.

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(2) Q. Do you recall if you ever took any (3) action to notify the Post that any of the (4) articles that you just reviewed were (5) inaccurate? (6) A. We did not take any action. (7) Q. Take a look at Exhibit 158. Just (8) quickly review. You don't have to review the (9) whole e-mail.(10) A. Okay. This is an e-mail from --(11) Q. 158. It says Block, Michael at the(12) top. September 6, 2005. And then there's a(13) forwarded message underneath of September 2 of(14) 2005.(15) A. Okay.(16) Q. Do you remember if you've ever seen(17) this forwarded e-mail here from September 2 of(18) 2005 which seems to be from the Ground Zero(19) museum to Jim Cassidy and Jim Spollen?(20) A. I don't recall ever seeing this(21) before.(22) Q. In the second paragraph, Mr. Suson(23) states, "You have orchestrated a defaming(24) attack on me and I ask you to stop. I will not(25) get caught in the middle a vendetta between you

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(2) and former union members. For four years I (3) have been loyal to the UFA, whether this (4) interests you or not, and what you have done to (5) me through your New York Post connection is (6) horrible, just horrible." (7) Do you have any idea what Mr. Suson (8) is referencing in terms of your New York Post (9) connection?(10) A. I have no idea what he's talking(11) about.(12) Q. Do you have a New York Post(13) connection?(14) A. If he means do I have a(15) relationship with people that work for the New(16) York Post, I have a relationship with people(17) that work for every media outlet in the City of(18) New York.(19) Q. Did you approach the Post to do an(20) article about Mr. Suson?(21) A. Absolutely not.(22) Q. Finally, I don't know that I've(23) asked you, we discussed the fact that(24) Mr. Sanfilippo did not have the authority to(25) appoint Mr. Suson the official photographer.


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(2) Do you recall that testimony? (3) A. Yes. (4) Q. If the UFA had wanted to appoint (5) someone an official photographer at Ground (6) Zero, would that be someone that the board (7) would have to approve? (8) A. Absolutely. (9) Q. Would you have been able on your(10) own to appoint someone the official(11) photographer for Ground Zero or for the UFA for(12) that matter on your own?(13) A. No, no.(14) Q. Mr. Cassidy, I greatly appreciate(15) your time today. I don't have any further(16) questions. Thanks very much.(17) A. Thank you.(18) MR. LEFKOWITZ: I do have a few(19) follow-up questions for you.(20) EXAMINATION BY(21) MR. LEFKOWITZ:(22) Q. Did you do anything to prepare for(23) today's deposition?(24) A. No.(25) Q. Did you speak with anybody to

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(2) prepare for today's deposition? (3) A. No. (4) Q. Without telling me the contents of (5) your conversations, did you speak with your (6) attorney, Mr. Block, before coming to this (7) deposition? (8) A. No. (9) Q. Did you review any documents before(10) preparing for today's deposition?(11) A. No.(12) Q. Did you look at any of the(13) documents that were provided to -- to us by(14) Mr. Block in response to the subpoena?(15) A. I did not.(16) Q. Okay. Prior to today, have you(17) ever spoken with counsel, Jay Conti?(18) A. Only when I met him in the hallway.(19) Q. I'm just talking about prior to(20) today.(21) A. No.(22) Q. What about another attorney in his(23) office, Slade Metcalfe?(24) A. No.(25) Q. Have you ever met any other

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(2) attorney or employee of the law firm of Hogan & (3) Hartson before today? (4) A. No. (5) Q. When was the last time that you (6) spoke with anybody who works for the New York (7) Post? (8) A. Yesterday. (9) Q. And who was that?(10) A. I don't know who the Post had at(11) our press conference, but we had a press(12) conference there and they wrote a story about(13) our topic yesterday so I'm sure I spoke to(14) somebody from the New York Post yesterday. I(15) don't know who it was.(16) Q. I'll cut through it because I know(17) you're pressed for time and I have no interest(18) in keeping you unnecessarily.(19) Did that press conference have(20) anything to do with Gary Suson or 9/11?(21) A. It had something to do with 9/11.(22) It had nothing to do with Gary Suson.(23) Q. I realized, based on the date, as I(24) asked the question that it might have something(25) to do with 9/11. Did it have anything to do

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(2) with Gary Suson? (3) A. No. (4) Q. When is the last time you spoke (5) with a person employed by the New York Post (6) having anything to do with Gary Suson? (7) A. I don't recall ever speaking with (8) anybody at the New York Post about Gary Suson. (9) I'm not saying that I haven't, but I don't(10) recall ever doing it.(11) Q. Okay.(12) A. If you go back a couple of years,(13) it is possible that I spoke to somebody at the(14) Post when they asked me a question about it.(15) Yes, it's possible but certainly I don't recall(16) doing it.(17) Q. What are the duties of the(18) Manhattan borough trustee?(19) A. To administer to the needs of(20) firefighters in that particular borough as it(21) relates to grievances, discipline, to represent(22) them in discipline issues at headquarters, to(23) take phone calls from delegates and/or members,(24) to man the office one day a week, to take phone(25) calls from anyone in the city, to do any




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(2) projects designated by the president or the (3) board, among other things. (4) Q. And this is a full-time job? (5) A. Full-time job. (6) Q. I think you said that they were (7) excused by the city according to the union (8) contract in order to perform this full-time (9) job?(10) A. That's correct.(11) Q. Okay. Are all of these duties(12) outlined in the union constitution?(13) A. I may have outlined in more detail(14) than the constitution says.(15) Q. Well, isn't it true that in the(16) constitution, pretty much the only duty of the(17) Manhattan trustee is to review the finances of(18) the union?(19) A. No, that's not true. That may be(20) what -- I don't have the constitution in front(21) of me, so I can't quote it, but each trustee is(22) responsible for any responsibilities that are(23) assigned by the president. That's certainly(24) outlined in the constitution also.(25) Q. Would that be a full-time job? Do

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(2) you regularly assign additional duties to the (3) trustees of the boroughs? (4) A. Well, as I just -- what I just (5) outlined is what is expected of the individual (6) trustee and insofar as that's expected by the (7) membership and by me, I guess you could say (8) that those are the responsibilities that I (9) expect the trustee to handle, not just the(10) Manhattan trustee, each and every trustee.(11) Q. Did you personally tell each(12) trustee after the 2002 election that part of(13) their job was to do all of these things you(14) outlined?(15) A. I certainly had a discussion with(16) everybody on the board about what I expected(17) them to do, yes.(18) Q. You instructed them about dealing(19) with problems or disputes involving union(20) members?(21) A. Absolutely.(22) Q. They didn't know this already?(23) A. Oh, I think they did, but you asked(24) me if I outlined to them what I expected as the(25) president.

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(2) Q. So there were a number of duties of (3) the trustee that everybody knew but aren't (4) necessarily explained or outlined in the (5) constitution; is that right? (6) A. I would say that's accurate, yes. (7) Q. Okay. Did you ever remove any (8) items from Ground Zero? (9) A. Me, personally?(10) Q. Yes.(11) A. No.(12) Q. Are you aware that there were items(13) which had been removed from Ground Zero by(14) various individuals?(15) A. I don't have any firsthand(16) knowledge of that.(17) Q. Are you aware that firefighters had(18) removed items from Ground Zero?(19) A. I'm not aware of any firefighters(20) removing anything from Ground Zero.(21) Q. You're not aware of steel crosses(22) being made and removed from Ground Zero?(23) A. No, I'm not aware of steel crosses(24) being removed from Ground Zero, no.(25) Q. Are you aware of them being made

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(2) using the steel from the rubble? (3) A. I would say the answer to that is (4) yeah. (5) Q. Are you aware that there was a (6) steel FDNY emblem that was made using the (7) rubble from Ground Zero? (8) A. Yes. (9) Q. Who authorized that?(10) A. I have no idea.(11) Q. Was it authorized?(12) A. I don't know.(13) Q. Well, was that steel evidence?(14) A. That's not something that I could(15) answer for you.(16) Q. Why not?(17) A. I don't know the answer to that. I(18) don't know if the police department or any(19) other investigatory body deemed a piece of(20) steel as evidence. I don't know the answer to(21) that.(22) Q. And that would be the same for any(23) other item, would it?(24) A. I would have to disagree with you.(25) Q. Have you ever seen the steel FDNY


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(2) emblem? (3) A. I'm trying to think of the answer. (4) I don't recall that I have seen it. I'm not (5) sure where it is. (6) Q. Have you ever seen any of the (7) crosses that were made of Ground Zero steel? (8) A. I haven't personally, but I think (9) I've seen pictures of the FDNY cross that(10) you're referring to initially.(11) Q. Where is it?(12) A. I don't know. I've seen a picture(13) of it. I don't remember where it is.(14) Q. You don't remember from the context(15) where it was?(16) A. I don't remember.(17) Q. Mr. Conti talked to you a little(18) bit about the Fresh Kills landfill. Do you(19) know what that is?(20) A. Sure.(21) Q. What is it?(22) A. That's where the rubble from Ground(23) Zero was dumped, much of it.(24) Q. When you say "dumped," are you(25) talking about garbage?

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(2) A. I'm talking about -- well, let me (3) clarify. I've never been to the Fresh Kills (4) landfill. I've never seen stuff being dumped (5) at the Fresh Kills landfill so what I know (6) about it is what I've read about it or have (7) been told, but my understanding is that much of (8) the rubble and debris from the collapsed towers (9) when it was removed was removed to the Fresh(10) Kills landfill. That's all I know about it.(11) Q. How would this rubble and debris(12) include possible evidence or is this garbage to(13) be disposed of?(14) A. I think the answer to that is that(15) the city had police officers and detectives and(16) possibly fire marshals sifting through that(17) debris looking for evidence.(18) Q. At Fresh Kills?(19) A. That's my understanding.(20) Q. Okay. Now, you are aware that(21) immediately after 9/11/2001 Gary Suson spent(22) much time at Ground Zero taking photographs?(23) A. I'm not aware of that.(24) Q. Have you ever seen any of his(25) photographs?

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(2) A. I don't believe I have, unless (3) they've been in the newspapers. If they've (4) been in the newspapers, it's possible that I've (5) seen them. I don't recall seeing any of them. (6) Q. You testified a moment ago when (7) Mr. Conti asked you the question about you (8) employ a person by the name of Bruce to prepare (9) materials for you which are articles about the(10) union or the FDNY?(11) A. Yes.(12) Q. How often does he do that?(13) A. It's done every day.(14) Q. And so every day you'd walk in the(15) office in the morning, I guess, and there would(16) be a stack of documents or -- not to(17) characterize how many, but whatever documents(18) were in the news that day?(19) A. Yes.(20) Q. And he does that every day?(21) A. Every day.(22) Q. For how long has he been doing(23) that?(24) A. At least three years, maybe more,(25) four years. Maybe longer.

Page 116(1)

(2) Q. What about things about the union (3) or the FDNY which are not in print, for (4) instance something that would be on TV or the (5) internet or something like that? (6) A. His main function is to provide (7) articles that are in the media, mostly in the (8) newspapers. I won't say he doesn't do anything (9) off the internet, but mostly in the newspapers(10) relating to UFA, relating to the fire(11) department, relating to labor issues and/or(12) politics.(13) Q. Have you found that Bruce does a(14) good job?(15) A. Yes, he does.(16) Q. And have you ever found his(17) coverage of the articles deficient meaning that(18) he missed something here or there, or you think(19) he's pretty thorough?(20) A. I think he's pretty thorough, but I(21) think he's missed things on occasion.(22) Q. As we all do.(23) A. Absolutely.(24) Q. Is Bruce employed by the union or(25) by an outside entity?




Page 117(1)

(2) A. By the union. (3) Q. He's a salaried employee? (4) A. Yes. (5) Q. You talked about charges that Rudy (6) Sanfilippo brought against you and I know you (7) said that some were withdrawn and others were (8) dismissed or voted down. (9) Would you please tell me what those(10) charges were.(11) A. I don't recall specifically. I(12) don't have them in front of me.(13) Q. What was the nature of the charges?(14) A. As I said, they were -- I might(15) have them.(16) Q. You have some file in your(17) Blackberry there?(18) A. I might, I might.(19) MR. LEFKOWITZ: For the record, the(20) witness is looking through his(21) Blackberry, because he suspects there may(22) be something.(23) A. I don't have them on my Blackberry.(24) Q. + Well, I would ask you if you have(25) it back at the office to produce a copy of it.

Page 118(1)

(2) A. We certainly can do that for you. (3) Q. Thank you very much. (4) Now, what are the job of fire (5) marshals? (6) A. To investigate fires for cause and (7) origin, to arrest people related to arsons and (8) I guess to carry out the duties as asked by the (9) fire commissioner.(10) Q. Would fire marshals have the duty(11) or responsibility to investigate people who(12) removed items from Ground Zero?(13) A. It's very possible, yes.(14) Q. Well, I think you mentioned in your(15) testimony with Mr. Conti that fire marshals(16) were considering arresting Mr. Suson?(17) A. What I was told by Lester Layne,(18) the fire marshal rep who represents the fire(19) marshals, is that they were considering(20) arresting him, yes.(21) Q. And what led them to consider(22) arresting him?(23) A. I think the articles in the paper(24) that highlighted that he took items from Ground(25) Zero.

Page 119(1)

(2) Q. Well, are you aware that fire (3) marshals did visit the museum? (4) A. I'm not aware of it. (5) Q. Are you aware that fire marshals (6) did examine the items in the museum? (7) A. I'm not aware. (8) Q. Well, if fire marshals did go to (9) the museum and see the items that were on(10) display there, is there any doubt in your mind(11) that they would arrest Gary Suson if there were(12) anything illegal?(13) A. That's -- you're asking me to(14) speculate. I don't know that they did. I(15) don't know what they saw if they did go.(16) Q. Just so you know, I'm entitled to(17) ask you to speculate in a deposition. So based(18) upon the premise that I've given you that fire(19) marshals are there, they're in the museum and(20) they see items that had been illegally removed(21) from Ground Zero, is there any doubt in your(22) mind that they would have arrested him?(23) MR. CONTI: Objection. He just(24) testified he can't answer that.(25) A. I guess it to would come down to

Page 120(1)

(2) could they prove that he illegally took them. (3) I don't know. I mean, I just don't know the (4) answer to that. (5) Q. If they saw items illegally (6) removed, would they take steps to investigate (7) how he got them? (8) A. Well, I'm not a fire marshal. I've (9) never been a fire marshal and so I couldn't(10) really detail for you what they should or(11) shouldn't do. And so I couldn't give you a(12) specific answer as to what they would do(13) because I really don't know what their role is(14) other than investigating fires for arson. I'm(15) not trying to avoid the question. That's(16) really the best I can do for you. I'm sorry.(17) Q. You don't need to apologize. You(18) just give me your best answers and that's fine.(19) A. I'm trying.(20) Q. Now, I believe you testified that(21) Rudy Sanfilippo first brought up Gary Suson, I(22) think you said it was late 2002 or early 2003?(23) A. He's the first one to bring it up(24) and the timing I'm unclear about, but that's my(25) best guess that it was late 2002 or sometime


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Page 121(1)

(2) 2003. (3) Q. And you talked about board meetings (4) where Gary Suson was discussed. (5) A. My recollection is that (6) Mr. Sanfilippo brought the topic up because he (7) wanted to secure for Mr. Suson something from (8) us that said he was the official photographer (9) for the UFA.(10) Q. And how long after Mr. Sanfilippo(11) first brought up Gary Suson did you have the(12) board meetings?(13) A. Well, he may have brought it up --(14) I believe he brought it up at a board meeting.(15) Q. And did you discuss it right then(16) and there?(17) A. I think it was discussed to some(18) degree, but as I testified earlier, I believe(19) that it took a period of time to resolve(20) because Kevin Gallagher had to be called. Pete(21) Gorman had to be called. We had to do some(22) research into what the previous board had done.(23) If they had made an agreement with(24) Mr. Suson, then we might have been in a(25) position where we wanted to -- even if we

Page 122(1)

(2) disagreed, allow that position to continue. (3) When they told us that they had not (4) given or granted Mr. Suson the right to say (5) official photographer, then it was easy for us (6) to decide we weren't going to give him that (7) title. (8) Q. How long did it take you to make (9) those phone calls and conduct this(10) investigation?(11) A. To be honest, I don't recall how(12) long it took. I don't know how long. A couple(13) of weeks, a month. I don't know.(14) Q. So, I guess in the next board(15) meeting or two it would have been resolved?(16) A. I think in a relatively short(17) period of time, within a month or so certainly.(18) Q. Okay.(19) A. And, again, that's just my best(20) recollection.(21) Q. I may be finished, but if you give(22) me a moment to step out with my client, I will(23) let you know.(24) A. Go right ahead.(25) (Recess taken.)

Page 123(1)

(2) Q. If you would just take a look at (3) Exhibit 18 for me. What is this? (4) A. This looks like a photocopy of a (5) placard that we give to New York City (6) firefighters so that they can display in the (7) window of their vehicles when they park outside (8) firehouses throughout the city. (9) Many firehouses do not have parking(10) for New York City firefighters. This placard(11) we hope will alert traffic enforcement and(12) police officers that this is an active(13) firefighter who's working in the hopes that(14) they will not get a ticket if they're parked(15) near their firehouse, but illegally.(16) Q. You hope for a little courtesy from(17) the police department?(18) A. That is true.(19) Q. Is this given to anybody other than(20) active duty firefighters?(21) A. Is it given to anybody? The answer(22) to that is it shouldn't be, but the answer to(23) that is probably yes.(24) Q. Well, why do you say that it should(25) be?

Page 124(1)

(2) A. Well, we give two to every New York (3) City firefighter. Once they're given out, we (4) have no control over where they go. (5) Q. I see. So what you're saying is (6) it's possible that a New York City firefighter (7) will give one to his friend or family or (8) something like that? (9) A. It's certainly possible.(10) Q. Well, other than that use of the(11) second placard, is the placard issued initially(12) to anybody other than an active duty(13) firefighter?(14) A. I don't think we have any official(15) list of people they're given to. Some may be(16) given as a courtesy to a small group of people(17) that do something -- that do something on(18) behalf of us, if that's the point you're(19) getting to, it's possible that that happened.(20) Q. What do you mean by "a small group(21) of people that do something on behalf of us"?(22) A. Well, what I mean is that the(23) individual trustees who give out the placards(24) to their members, is it possible that they give(25) them to somebody else who's not a firefighter,




Page 125(1)

(2) it's possible. We're talking about 9,000 (3) firefighters, 18,000 placards. Yes, it's (4) possible. (5) Q. Who is in charge of giving out the (6) placards? (7) A. The recording secretary usually is (8) responsible for that. (9) Q. In 2004 who was the recording(10) secretary?(11) A. Joe Miccio.(12) Q. What about the sergeant at arms,(13) who was the suggest at arms in 2004?(14) A. Phil McArdle.(15) Q. Would Mr. McArdle be authorized or(16) entitled to give out a parking placard, this(17) kind of placard, to somebody that he deemed(18) appropriate?(19) A. Well, he certainly would have had(20) access to placards. I don't know if he gave(21) them to anyone outside of firefighters. Our(22) position, the union's official position is that(23) they shouldn't be given to anyone besides(24) active New York City firefighters. And we went(25) so far as to print up a placard for retired

Page 126(1)

(2) firefighters. We have one for active, one for (3) retired, but if you're saying did Mr. McArdle (4) have access to placards, I'm sure the answer to (5) that is yes. (6) Q. I understand access. Would he be (7) authorized to make a decision on his own to (8) give somebody a placard who was not an FDNY (9) firefighter?(10) A. No, the official position of the(11) union is to not give placards to anyone that is(12) not an active firefighters.(13) Q. If somebody did that, for instance(14) if Mr. McArdle in 2004 give Gary Suson this(15) parking placard, you're saying that he was not(16) authorized to do that?(17) A. I'm saying that the official(18) position of the union was not to give placards(19) to anyone other than active New York City(20) firefighters.(21) Q. What about honorary battalion(22) chiefs, would they be considered an active duty(23) firefighter under what you just said?(24) A. No. An honorary battalion chief(25) should go to the UFOA for a placard. UFOA is

Page 127(1)

(2) the Uniformed Fire Officers Association. (3) Q. I see. What is an honorary (4) battalion chief, by the way? (5) A. I'm not sure there really is such a (6) thing. I think it's just a title that is (7) bestowed by the department or maybe the (8) Uniformed Fire Officers Association saying that (9) this particular person is being recognized and(10) given this title.(11) MR. LEFKOWITZ: I have no further(12) questions.(13) MR. CONTI: Just for the record,(14) thanks again, Mr. Cassidy, and we're(15) going to send you the original(16) transcript. Do you want us to send it to(17) your attorney, Mr. Block, or to you.(18) THE WITNESS: To my attorney,(19) Mr. Block.(20) (Time noted: 12:02 p.m.)(21)

(22)

(23)

(24)

(25)

Page 128 (1) A C K N O W L E D G M E N T (2)

(3) STATE OF ) (4) :ss (5) COUNTY OF ) (6)

(7) I, STEPHEN J. CASSIDY, hereby (8) certify that I have read the transcript (9) of my testimony taken under oath in my(10) deposition; that the transcript is a(11) true, complete and correct record of my(12) testimony, and that the answers on the(13) record as given by me are true and(14) correct.(15)

(16) ___________________________ STEPHEN J. CASSIDY(17)

(18)

(19) Signed and Subscribed to(20) before me, this day(21) of , 2007.(22) ________________________________(23) Notary Public, State of New York(24)

(25)


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Page 129 (1) C E R T I F I C A T E (2)

(3) STATE OF ) (4) :ss (5) COUNTY OF ) (6)

(7) I, SOPHIE NOLAN, a Shorthand Reporter and (8) Notary Public within and for the State of New (9) York, do hereby certify:(10) That STEPHEN J. CASSIDY, the witness(11) whose examination is hereinbefore set forth,(12) was duly sworn by me and that such deposition(13) is a true record of the testimony given by such(14) witness.(15) I further certify that I am not related(16) to any of the parties to this action by blood(17) or marriage; and that I am in no way interested(18) in the outcome of this matter.(19) IN WITNESS WHEREOF, I have hereunto set(20) my hand this 18th day of September, 2007.(21)

(22) ________________________(23) SOPHIE NOLAN(24)

(25)

Page 130 (1) *** ERRATA SHEET *** (2) ELLEN GRAUER COURT REPORTING CO, LLC 126 East 56th Street, Fifth Floor (3) New York, New York 10022 212-750-6434 (4) NAME OF CASE: Suson v. NYP Holdings, et al (5) DATE OF DEPOSITION: September 13, 2007 NAME OF WITNESS: STEPHEN J. CASSIDY (6) PAGE LINE FROM TO REASON (7) ____|____|________|_________|__________________ (8) ____|____|________|_________|__________________ (9) ____|____|________|_________|__________________(10) ____|____|________|_________|__________________(11) ____|____|________|_________|__________________(12) ____|____|________|_________|__________________(13) ____|____|________|_________|__________________(14) ____|____|________|_________|__________________(15) ____|____|________|_________|__________________(16) ____|____|________|_________|__________________(17) ____|____|________|_________|__________________(18) ____|____|________|_________|__________________(19) ____|____|________|_________|__________________(20) (21) _______________________(22) Subscribed and sworn before me(23) this_____day of ____, 2007(24) __________________ _______________________ (Notary Public) My Commission Expires:(25)




Concordance Report- - -

Unique Words: 1,488Total Occurrences: 6,390Noise Words: 382Total Words In File: 19,460

- - -Single File Concordance

- - -Case Insensitive

- - -Noise Word List(s): NOISE.NOI

- - -Cover Pages = 0

- - -Includes ALL Text Occurrences

- - -Dates ON

- - -Includes Pure Numbers

- - -Possessive Forms ON

* * DATES * *9/11/01 [2] 26:22; 82:10 9/11/2001 [1] 114:21

* * $ * *$5,000 [1] 51:19

* * 0 * *02 [1] 9:24

* * 1 * *1 [3] 1:7; 13:22; 14:4 10 [1] 34:8 100 [1] 94:24 10005 [1] 2:6 10022 [3] 1:24; 2:13; 130:3 102 [1] 3:10 103 [1] 98:18 105 [1] 3:5 106 [1] 100:22 107 [1] 84:2 108 [2] 81:20, 24 10th [2]

27:23; 34:11 11 [10] 13:10; 15:5; 16:5; 18:23; 23:22; 42:4, 7; 44:24; 56:5; 86:20117 [1] 3:11 11th [5] 2:5; 12:7, 11; 13:17; 89:5 126 [2] 1:23; 130:2 12:02 [1] 127:20 13 [2] 1:12; 130:5 14 [1] 9:11 152 [1] 68:22 158 [2] 103:7, 11 164 [1] 79:8 18 [1] 123:3 18,000 [1] 125:3 182 [3] 3:15; 6:24, 25 18th [1] 129:20 19 [1] 9:10 1974 [1] 8:16 1988 [3] 11:25; 12:24

* * 2 * *2 [3] 1:7; 103:13, 17 20 [2] 24:16; 47:2 2001 [3] 12:12, 13; 34:8 2002 [16] 11:13; 13:20, 23; 14:15, 18; 15:16, 18; 38:5; 39:7; 47:22; 53:3; 86:21; 97:5; 110:12; 120:22, 252003 [8] 23:15; 38:5; 39:8; 41:21; 91:14, 19; 120:22; 121:22004 [7] 23:15, 16; 41:21; 54:9; 125:9, 13; 126:142005 [23] 14:2, 4; 16:4, 18; 54:8, 9; 56:14; 60:25; 61:9; 62:2, 13, 18; 64:5; 66:17; 68:9; 73:10; 85:19; 94:21; 96:25;

103:12, 14, 182006 [2] 1:9; 78:23 2007 [5] 1:12; 128:21; 129:20; 130:5, 232008 [1] 14:7 204 [2] 9:20; 20:18 212-750-6434 [2] 1:24; 130:3 212-918-3000 [1] 2:15 212-918-3643 [1] 2:16 236 [1] 11:20 23rd [2] 9:20; 20:18 24 [5] 31:19, 20, 22; 60:4 25 [2] 63:6; 65:19 26 [1] 71:8 27 [1] 74:12 28 [2] 60:25; 77:23

* * 3 * *3000605 [1] 1:9 31 [1] 96:25 343 [1] 47:24

* * 4 * *4 [1] 3:4 48 [1] 2:5

* * 5 * *5013-c [1] 88:21 56th [2] 1:23; 130:2 59 [1] 3:9

* * 6 * *6 [3] 3:15; 90:21; 103:12

* * 7 * *71 [1] 4:17

* * 8 * *85199 [1] 1:25 875 [2] 1:11; 2:12

* * 9 * *9,000 [1] 125:2 9/11 [17] 26:23, 25; 27:11, 14, 18; 28:3; 29:5; 38:22; 82:22; 95:3, 24; 97:25; 98:21; 100:23; 107:20, 21, 259/11/01 [2] 26:22; 82:10 9/11/2001 [1] 114:21 9/12 [2] 27:14; 29:5 9/14 [1] 27:15 9/15 [1] 27:15 917-887-3920 [1] 2:8 9:05 [1] 1:13

* * A * *a.m. [1] 1:13 able [4] 6:19; 17:19; 32:19; 105:9 absolutely [35] 12:5; 20:2; 21:7; 22:20; 34:6; 35:4; 36:19; 37:19; 48:16, 22; 49:6; 56:8; 59:16; 72:15; 74:10; 75:21; 77:7; 79:6; 81:10, 17;83:19, 22; 85:21, 24; 86:22; 91:16, 20; 95:13; 97:18; 99:20; 104:21; 105:8; 110:21; 116:23accept [1] 78:20 access [8] 44:2, 6, 8; 45:12; 83:6; 125:20; 126:4, 6according [1] 109:7 account [1] 82:15 accurate [17]

63:4; 74:9, 10; 83:18; 84:22; 85:16; 92:6; 96:6; 97:2, 3, 15; 100:6, 7, 14, 15; 101:17; 111:6accurately [1] 77:18 act [5] 17:13; 20:4, 8; 73:20; 89:19acting [2] 18:5; 91:10 action [7] 40:5; 58:20; 67:8; 102:23; 103:3, 6; 129:16actions [12] 17:11, 16, 18, 19, 25; 19:16, 20, 25; 29:24; 67:17; 84:20; 85:3active [9] 9:12; 123:12, 20; 124:12; 125:24; 126:2, 12, 19, 22actively [1] 24:2 acts [1] 17:11 addition [5] 28:25; 33:17; 56:17; 73:3; 79:21additional [3] 7:24; 9:6; 110:2 address [2] 4:16; 71:23 administer [1] 108:19 advance [1] 92:20 adversarial [1] 52:17 advertising [1] 90:25 advise [1] 18:7 aftermath [1] 26:16 against-nyp [1] 1:5 agency [4] 35:18, 19; 64:23 agenda [1] 57:9 agree [2] 18:17; 50:21 agreed [2] 49:18; 82:12 agreement [5] 98:9, 11, 15, 16; 121:23 ahold [1] 23:3 al [1] 130:4 alert [1] 123:11


From 9/11/01 to alertwww.ellengrauer.com


allegations [1] 91:11 allow [3] 37:6, 17; 122:2 allowed [7] 35:5, 9; 36:22; 37:10; 44:8; 81:14, 18allowing [1] 76:7 allows [1] 97:7 alternative [1] 22:23 america [1] 1:6 amicable [1] 26:8 amount [2] 89:6; 92:9 amounts [4] 88:25; 98:6, 7, 17 announce [1] 55:9 announcement [3] 50:9, 14, 19 announcements [1] 25:17 answer [27] 5:2, 19; 6:5; 25:15, 16; 37:9; 51:3, 11; 52:7; 55:16; 67:21; 68:5; 91:3; 92:21; 94:22; 112:3, 15, 17, 20; 113:3; 114:14; 119:24; 120:4, 12; 123:21, 22; 126:4answers [6] 5:12; 6:9, 11, 20; 120:18; 128:12anybody [8] 42:3; 55:12; 105:25; 107:6; 108:8; 123:19, 21; 124:12apologize [1] 120:17 apparently [3] 43:21; 44:5; 78:17 appears [3] 71:18; 95:4; 97:8 applies [1] 18:6 appoint [3] 104:25; 105:4, 10 appointed [6] 11:24; 12:22; 57:6; 80:25; 81:7, 15appreciate [1] 105:14 appreciated [1] 78:20 approach [1] 104:19 approached [1]

56:4 appropriate [3] 25:3; 96:14; 125:18 approve [1] 105:7 approximately [1] 90:4 april [3] 11:25; 47:22; 86:20 area [2] 27:10; 34:23 aren't [2] 11:6; 111:3 argument [1] 49:17 arms [6] 13:15; 15:10, 20; 16:10; 125:12, 13arrest [3] 66:23; 118:7; 119:11 arrested [1] 119:22 arresting [3] 118:16, 20, 22 arrests [3] 19:16, 18, 19 arson [1] 120:14 arsons [1] 118:7 article [13] 95:2, 3, 4, 7, 16; 98:20, 25; 99:7, 10; 100:22; 101:3, 15; 104:20articles [14] 93:18; 101:21, 24; 102:3, 7, 8, 9, 21; 103:4; 115:9; 116:7, 17; 118:23artifact [1] 35:22 artifacts [3] 64:11; 66:24; 95:23 artwork [1] 97:25 aside [2] 30:20, 22 asking [3] 40:22; 86:25; 119:13 asserted [2] 45:18; 60:25 assertion [4] 64:7; 83:21; 98:3, 5 asserts [2] 70:18; 87:3 assign [1] 110:2 assigned [6] 11:25; 12:5, 8; 19:21; 28:4; 109:23assignments [1] 19:22

assistant [2] 28:23; 85:15 associate [3] 90:15, 17; 91:14 associated [6] 60:24; 65:10; 69:16; 70:17; 76:21; 94:19associates [1] 20:20 association [20] 4:23; 7:19; 9:17; 13:8; 20:15; 25:5; 39:18; 40:11, 17, 25; 41:12; 73:2; 76:3; 77:13, 17; 91:9; 97:7; 100:10; 127:2, 8assume [3] 5:20; 12:11; 65:24 attack [2] 36:11; 103:24 attend [2] 8:8, 17 attended [1] 8:20 attends [1] 18:3 attention [8] 39:10; 49:11, 13; 64:21; 65:2; 66:14; 67:13, 20attorney [14] 2:4; 4:10; 7:17, 18; 18:2, 6; 57:20; 75:17; 80:18; 106:6, 22; 107:2; 127:17, 18attorneys [2] 2:11; 4:11 audible [2] 5:24; 6:2 august [20] 9:24; 11:12; 13:22; 14:4; 15:15, 18; 16:4, 18; 60:25; 61:9; 62:2, 13, 18; 64:5; 66:17; 68:9; 73:10; 85:19; 94:20; 96:25authority [21] 20:4, 7; 21:8, 14, 22; 24:22; 25:2; 36:22, 25; 37:6, 11, 17; 75:17, 20; 90:14; 91:13; 99:19, 21; 100:17, 18; 104:24authorize [1] 49:3 authorized [11] 46:5; 51:12; 80:7; 81:6, 14; 83:20; 112:9, 11; 125:15; 126:7, 16authorizes [2] 48:17; 78:9 available [2] 22:21; 23:21 avenue [2] 1:11; 2:12 avoid [1]

120:15 aware [22] 61:20; 76:24; 88:11; 90:2, 8; 92:8, 11; 98:13, 15; 111:12, 17, 19, 21, 23, 25; 112:5; 114:20, 23; 119:2, 4, 5, 7

* * B * *background [1] 8:8 backup [1] 28:17 based [4] 44:4; 98:12; 107:23; 119:17basis [3] 10:16; 102:8, 12 battalion [4] 12:20; 126:21, 24; 127:4 beat [1] 52:25 behalf [14] 20:4, 8; 21:9; 24:18, 23; 38:21; 72:25; 74:7; 77:12; 83:21; 91:8, 11; 124:18, 21belief [2] 58:18; 60:17 believe [26] 17:14; 24:16; 42:3, 15; 45:10; 53:22; 56:13; 57:19; 64:10; 65:17; 66:7; 67:4; 69:25; 70:22; 73:16; 74:23; 76:20; 80:23; 81:25; 88:17; 92:15; 93:12; 115:2; 120:20; 121:14, 18believed [1] 29:22 believes [1] 25:2 bellone [1] 101:10 belonging [1] 36:6 besides [1] 125:23 best [5] 15:13; 120:16, 18, 25; 122:19bestowed [1] 127:7 bigwig [1] 100:11 bill [2] 16:9; 53:7 billing [2] 95:21; 96:3 binder [3] 60:5; 68:23; 79:8 binders [1] 44:15 bit [4]

8:7; 33:6; 97:4; 113:18 blackberry [3] 117:17, 21, 23 blamed [1] 53:21 blank [3] 47:8; 66:10; 102:18 blip [1] 87:24 block [22] 7:17; 8:4; 18:2; 24:11, 17; 41:8; 57:20; 61:15; 67:25; 75:5; 76:9, 16; 77:2; 80:19; 86:24; 87:14; 92:24; 103:11; 106:6, 14; 127:17, 19blood [1] 129:16 board [89] 3:9; 14:25; 15:4; 16:21, 23, 24, 25; 17:4, 6, 7, 10, 11, 15, 18; 18:3, 8, 15, 17; 23:20, 22; 38:17; 39:3, 11, 20, 21, 22, 25; 40:4, 12, 19; 41:3, 6; 42:4, 7, 8; 43:13, 17; 51:21; 53:12, 13, 16; 54:20, 21; 55:2, 13; 56:25; 57:4; 58:5, 20; 59:15, 19;61:12, 14; 62:2; 70:25; 75:10, 12, 14, 15; 76:6; 77:19; 79:4; 83:7; 84:20; 85:7, 18; 86:2, 8, 9; 87:17, 18; 89:14, 15, 18, 20;92:25; 93:4, 9; 100:16; 102:11; 105:6; 109:3; 110:16; 121:3, 12, 14, 22; 122:14board's [1] 61:16 bob [2] 15:23; 16:8 body [2] 55:14; 112:19 bonsignore [1] 37:13 book [3] 92:14, 19 books [1] 92:5 borough [14] 13:10, 11; 15:7, 22; 19:9, 10, 11, 13, 25; 20:3, 10; 53:14; 108:18, 20boroughs [1] 110:3 bother [1] 23:24 brandon [1] 37:21 break [6] 6:7, 8; 42:9, 11; 44:17;

From allegations to break Ellen Grauer Court Reporting(212) 750-6434

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57:25breaking [1] 29:8 brian [2] 37:12; 92:3 briefed [3] 61:12; 62:11, 14 briefing [1] 10:24 briefly [2] 13:3; 26:24 brigade [1] 29:22 bringing [1] 46:18 broad [1] 40:15 bronx [2] 15:23; 16:14 brooklyn [7] 8:11, 22; 11:21; 13:11, 12; 15:24; 16:12brown [1] 16:14 bruce [5] 3:10; 102:17; 115:8; 116:13, 24bucket [1] 29:22 building [1] 20:17 burke [1] 16:3 business [2] 58:25; 71:3 busted [1] 100:24 butler [30] 20:12, 13, 20; 22:4, 19, 21; 24:3; 60:16, 20, 24; 61:7, 9, 11; 62:11, 17; 63:19; 64:17; 65:15; 66:4, 5, 9, 17; 67:5, 22; 68:8; 69:17; 70:17; 71:16; 77:2; 87:14butler's [1] 22:7

* * C * *call [13] 17:9; 18:12, 14, 15; 23:8; 45:25; 48:2; 69:14, 22; 72:20, 24; 73:7, 22calling [1] 63:22 calls [5] 22:10, 23; 108:23, 25; 122:9cam [1] 95:3 campaign [1] 52:24 candidates [2]

14:21, 22 capacity [2] 23:12; 82:7 captain [1] 12:20 captioned [1] 90:24 career [2] 9:9; 12:3 carried [1] 36:9 carry [1] 118:8 case [4] 4:13; 70:11; 90:24; 130:4 cases [1] 51:19 cassidy [15] 1:16; 3:2; 4:7, 17; 58:4; 69:14; 74:21; 93:16; 103:19; 105:14; 127:14; 128:7, 16; 129:10; 130:5cassidy's [1] 85:14 catastrophe [1] 47:23 caught [1] 103:25 cc [1] 74:21 cc'd [1] 79:22 cease [5] 73:3; 77:13; 78:24; 86:25; 87:6cell [2] 28:13; 32:11 center [1] 26:16 certify [3] 128:8; 129:9, 15 chairman [3] 51:21; 53:12, 13 change [3] 31:25; 71:5; 74:8 channels [1] 11:3 characterize [1] 115:17 charge [3] 28:21; 97:23; 125:5 charges [13] 3:11; 54:3, 12, 15, 18, 24; 55:4, 17, 21; 56:9; 117:5, 10, 13charitable [1] 88:21 charity [4] 89:6, 12, 16; 100:23 chart [1] 32:2

checking [1] 72:24 checks [4] 51:16, 18; 78:18; 89:24 chief [12] 12:20, 21; 22:25; 23:6, 8; 32:14, 25; 96:10, 14, 18; 126:24; 127:4chiefs [5] 12:21, 22; 28:11; 82:13; 126:22children [1] 89:2 childrens [11] 78:18; 88:20; 89:22; 90:16, 18; 91:10, 19; 92:3, 7, 10, 18circulating [1] 32:17 circumstances [2] 10:15; 47:20 citizens [1] 36:20 city [22] 1:1; 4:21; 11:15; 13:5, 6; 19:2; 28:22; 33:24; 82:8; 89:3; 102:10; 104:17; 108:25; 109:7; 114:15; 123:5, 8, 10; 124:3, 6;125:24; 126:19 citywide [1] 13:13 civil [1] 1:1 claim [4] 68:14; 75:25; 84:21; 100:2 claimed [1] 86:11 claiming [3] 78:16, 25; 96:23 claims [1] 99:24 clarified [1] 78:19 clarify [5] 42:6; 58:11; 78:14, 15; 114:3class [1] 11:17 clean [1] 99:25 clear [9] 30:13; 37:15; 48:15; 49:2; 53:3; 70:12; 73:18; 76:6; 84:21client [1] 122:22 closing [1] 83:15 clothing [1] 36:11

co [2] 1:23; 130:2 collaborate [1] 25:4 collapsed [1] 114:8 collection [1] 102:6 college [3] 8:17, 19, 21 column [3] 96:8; 99:11, 23 coming [1] 106:6 command [1] 32:7 commanders [1] 33:10 comment [10] 21:8, 11, 15, 24; 22:15; 65:3, 7, 11; 93:17; 99:13commented [1] 61:7 commenting [1] 65:22 comments [1] 61:7 commission [1] 130:24 commissioner [2] 28:23; 118:9 committed [1] 34:23 communicate [1] 76:8 communications [6] 28:10, 16; 29:2; 32:6; 33:7; 43:3complaint [1] 54:11 complete [1] 128:11 comprises [1] 13:4 concern [3] 11:9; 17:8; 18:5 concerning [2] 10:6; 64:10 concerns [3] 54:20; 63:19; 64:6 conduct [1] 122:9 conducted [2] 67:12, 22 conduit [1] 84:25 conference [4] 11:7; 107:11, 12, 19 confirmed [1] 100:11 conjunction [2]

30:10; 75:9 connected [1] 47:5 connection [4] 91:17; 104:5, 9, 13 consider [2] 77:11; 118:21 considered [3] 35:14; 93:13; 126:22 considering [3] 66:23; 118:16, 19 constitution [15] 17:3, 23, 24; 18:6, 16; 19:21; 54:19; 55:7; 81:7; 109:12, 14, 16, 20, 24; 111:5construction [1] 30:11 consultation [1] 14:12 contact [5] 10:9; 22:17; 63:21; 70:20; 80:21contacted [3] 62:17; 65:23; 69:24 contained [1] 95:15 contention [1] 98:10 contents [1] 106:4 context [4] 11:6; 49:8; 77:17; 113:14 conti [14] 2:14; 3:4, 17; 4:6, 9; 12:13; 57:24; 59:12; 106:17; 113:17; 115:7; 118:15; 119:23; 127:13continue [1] 122:2 continued [6] 33:15; 66:5; 70:8; 72:13; 75:24; 79:4continuing [2] 75:25; 78:21 contract [2] 19:2; 109:8 contracts [2] 10:5; 14:13 contributions [3] 90:2; 92:11, 12 control [1] 124:4 controversy [1] 41:23 conversation [7] 66:2; 70:3, 5; 73:12, 17; 80:4; 88:7conversations [3] 11:5; 68:8; 106:5 conveyed [1]


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87:4 conveying [1] 87:10 coordinate [1] 28:9 coordinated [1] 21:13 copy [6] 3:11; 17:22; 47:14, 16; 50:3; 117:25cordoned [2] 34:24 corner [1] 100:23 counsel [7] 6:4; 18:3; 24:12, 15; 41:8; 61:15; 106:17counterproductive [1] 63:24 county [3] 1:2; 128:5; 129:5 couple [5] 5:9; 33:4; 58:6; 108:12; 122:12course [1] 58:25 court [4] 1:1, 23; 5:23; 130:2 courtesy [2] 123:16; 124:16 coverage [1] 116:17 crime [10] 34:16, 20, 22, 23; 35:3, 5, 10, 14, 18, 20cross [1] 113:9 crossed [1] 59:17 crosses [3] 111:21, 23; 113:7 curr-ator [1] 98:21 current [5] 4:19; 9:15; 26:2; 97:9, 22 currently [2] 15:19; 16:16 cut [1] 107:16 cynthia [2] 1:6; 94:4

* * D * *daily [3] 11:3; 102:8, 12 dan [1] 16:14 date [3] 13:21; 107:23; 130:5 day [20] 22:5; 24:6; 27:6, 16, 21, 23;

32:11; 55:3; 76:15, 16; 102:5; 108:24; 115:13, 14, 18, 20, 21; 128:20; 129:20; 130:23days [7] 22:6; 28:12; 29:10, 11; 31:22; 82:10, 21de [1] 45:15 deal [2] 48:5; 54:16 dealing [5] 10:17; 19:13, 15; 28:16; 110:18debated [1] 54:22 debris [3] 114:8, 11, 17 decide [2] 17:11; 122:6 decided [11] 40:20; 41:10; 58:20; 61:13, 21; 70:8, 25; 71:6; 85:7, 24; 86:9decision [5] 40:14; 61:16; 75:7; 76:11; 126:7decisions [1] 68:5 deemed [5] 30:2; 34:24; 63:23; 112:19; 125:17defaming [1] 103:23 defendants [3] 1:8; 2:11; 4:11 deficient [1] 116:17 definitely [3] 5:6; 32:3; 72:7 definition [1] 34:22 degree [2] 8:23; 121:18 delegates [1] 108:23 demand [1] 77:12 demanding [1] 96:22 depalma [1] 15:25 department [13] 9:3; 10:25; 12:18; 25:12; 30:24; 31:23; 35:21; 53:16; 102:4; 112:18; 116:11; 123:17; 127:7departure [2] 85:12, 23 depending [1] 10:14

deposed [2] 5:4, 6 deposition [10] 1:16; 4:24; 105:23; 106:2, 7, 10; 119:17; 128:10; 129:12; 130:5deputy [1] 12:20 describe [10] 10:2; 19:7; 25:7; 26:7, 13, 24; 30:6; 34:19; 36:8; 38:21described [2] 18:19; 60:15 description [2] 3:8, 14 designated [4] 17:2; 35:18, 19; 109:2 designation [1] 42:2 desire [1] 77:5 desist [5] 73:4; 77:14; 78:24; 86:25; 87:6destruction [1] 26:17 detail [2] 109:13; 120:10 details [5] 52:19; 67:23; 70:5; 73:14; 80:3detectives [1] 114:15 determination [1] 62:3 determine [1] 17:17 determined [1] 85:18 digging [1] 29:8 disability [1] 53:17 disagree [1] 112:24 disagreed [1] 122:2 disciplinary [2] 19:16, 19 discipline [2] 108:21, 22 discuss [6] 17:5; 46:13; 65:16; 67:25; 93:11; 121:15discussed [25] 21:21; 22:2; 40:12; 41:4; 43:17; 49:5; 55:12; 58:5; 69:20; 70:25; 72:10, 12; 75:12, 14, 15; 80:6; 82:17; 86:8; 87:16, 17; 93:9, 13; 104:23; 121:4, 17

discussing [1] 83:23 discussion [7] 41:5, 9; 48:3; 58:13; 86:5; 87:22; 110:15discussions [9] 59:5; 61:13; 66:17; 76:18, 22, 25; 82:11, 23; 88:4dismissed [2] 54:14; 117:8 display [2] 119:10; 123:6 displaying [1] 64:11 disposed [1] 114:13 dispute [3] 18:4; 60:15; 100:2 disputes [2] 19:14; 110:19 disturb [1] 35:5 document [34] 6:23; 7:6, 10, 20; 57:14; 60:10; 63:8, 15; 65:19, 21; 69:4, 7, 11, 20; 71:14; 72:3; 74:18, 20; 78:3; 79:16, 18; 81:23; 83:14; 84:6, 9; 86:19, 22; 90:22, 23; 91:2, 6, 14, 22documents [8] 3:7; 7:15, 25; 66:20; 106:9, 13; 115:16, 17doesn't [4] 42:7; 45:14; 86:23; 116:8 dollars [2] 90:8; 97:25 don [2] 15:25; 16:12 donate [3] 97:24; 98:5, 10 donated [1] 90:6 donations [1] 89:22 doubt [2] 119:10, 21 draft [1] 47:3 drafted [1] 76:9 dragged [1] 57:11 drawn [1] 46:9 drugs [1] 6:18 due [1] 28:4 duly [2] 4:2; 129:12

dumped [3] 113:23, 24; 114:4 dumpster [2] 96:12, 16 duties [13] 10:2; 19:7, 20; 23:17; 27:24; 33:6; 81:12; 100:4; 108:17; 109:11; 110:2; 111:2; 118:8duty [8] 27:2; 28:4; 89:4; 109:16; 118:10; 123:20; 124:12; 126:22

* * E * *e-mail [16] 2:17; 69:11, 25; 71:15, 17, 23; 72:10; 79:13, 20, 25; 80:14, 17, 21; 103:9, 10, 17e-mailed [2] 70:7; 102:11 e-mails [1] 102:14 early [4] 23:15; 38:5; 54:8; 120:22 easier [1] 24:5 east [5] 1:23; 9:20; 11:20; 20:18; 130:2easy [1] 122:5 ed [2] 16:3, 13 effective [1] 13:22 effects [1] 30:22 effort [4] 30:3, 5; 47:13; 100:2 efforts [6] 27:7; 29:3, 15; 36:21; 38:23; 49:9eighth [1] 91:22 elected [12] 9:13, 22; 11:12; 12:4; 13:9, 10, 21, 23; 53:11, 14; 54:21; 82:7election [7] 14:6, 8; 52:25; 53:20; 54:8; 56:14; 110:12elects [1] 13:12 ellen [2] 1:23; 130:2 emblem [2] 112:6; 113:2 emergency [2] 18:18, 19 employ [2]

From conveying to employ Ellen Grauer Court Reporting(212) 750-6434

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102:15; 115:8 employed [3] 20:14; 108:5; 116:24 employee [3] 37:6; 107:2; 117:3 encounter [1] 35:2 end [7] 17:15; 41:9; 73:10; 74:20; 83:14; 87:4, 23ended [1] 46:16 endorsement [2] 45:15; 49:14 endorsements [1] 40:18 enforcement [1] 123:11 engine [2] 11:19, 20 ensure [1] 30:11 entirety [1] 21:5 entities [2] 65:7; 102:24 entitled [3] 100:23; 119:16; 125:16 entity [1] 116:25 errata [1] 130:1 erroneous [1] 69:15 erupted [1] 41:23 esq [3] 2:3, 7, 14 et [1] 130:4 eventually [1] 30:8 everybody [3] 27:8; 110:16; 111:3 evidence [5] 34:25; 112:13, 20; 114:12, 17ex-union [2] 97:11; 100:11 exact [1] 13:20 exactly [2] 41:18; 62:9 exam [1] 12:23 examination [4] 3:3; 4:5; 105:20; 129:11 examine [1] 119:6 examined [1] 4:3

example [1] 80:22 excused [1] 109:7 executive [11] 14:25; 15:4; 55:2, 12; 56:25; 57:4; 75:10; 84:20; 87:18, 20; 100:16exhibit [24] 3:14; 6:25; 44:24; 56:5; 60:4; 63:6; 65:19; 68:22; 71:8; 73:19; 74:12; 77:22; 79:7; 81:19, 24; 84:2; 86:20; 89:25; 90:21; 94:24; 98:18; 100:21; 103:7; 123:3exhibition [1] 95:24 exhibits [3] 3:17; 44:15, 23 expansive [2] 10:4; 24:4 expect [1] 110:9 expected [4] 110:5, 6, 16, 24 expires [1] 130:24 explained [1] 111:4 express [1] 28:14 extended [1] 32:3

* * F * *facilitate [1] 44:10 fact [8] 33:3; 47:19, 25; 57:10; 67:18; 71:4; 72:24; 104:23facto [1] 45:15 fagan [2] 1:6; 94:5 fair [2] 21:16; 89:6 fallen [1] 89:7 familiar [2] 34:16; 60:14 familiarize [1] 5:10 families [2] 47:24; 89:7 family [1] 124:7 farinela [1] 71:19 favor [2] 12:17; 41:25 fax [2]

2:16; 63:9 fdny [16] 37:5, 15; 91:10; 96:21; 97:10, 23; 99:14, 17, 25; 100:2; 112:6, 25; 113:9; 115:10; 116:3; 126:8february [1] 11:24 fell [1] 28:6 fern [2] 46:24; 56:19 field [1] 17:6 fifth [2] 1:23; 130:2 file [4] 54:3, 18, 24; 117:16 filed [1] 91:11 files [1] 47:14 filing [1] 56:9 fill [1] 102:19 final [1] 6:17 finances [1] 109:17 find [4] 32:14, 24; 33:2, 15 fine [1] 120:18 finished [2] 5:16; 122:21 fire [46] 9:3; 10:25; 12:14, 18; 13:16, 18; 16:2, 11; 19:3, 4; 25:5, 11, 13; 27:4; 28:6; 30:23; 42:7; 49:22; 50:12; 53:16; 66:21, 22; 67:7; 89:3; 96:10, 14, 18; 97:6; 102:4; 114:16; 116:10; 118:4, 9, 10, 15, 18; 119:2, 5, 8, 18; 120:8, 9; 127:2, 8firefighter [14] 9:2; 11:15; 12:3, 19; 13:6; 23:10; 35:2; 123:13; 124:3, 6, 13, 25; 126:9, 23firefighters [46] 4:21, 23; 7:19; 9:8, 16; 10:6; 11:9; 13:5, 8; 17:6; 19:14; 20:15; 25:12; 27:3; 30:9; 33:24; 38:22; 39:18; 40:10, 17, 24; 41:12; 47:24; 50:13; 73:2; 76:3; 77:12, 16; 82:8; 89:3, 7; 91:9; 95:22; 100:9; 108:20; 111:17, 19; 123:6, 10, 20; 125:3, 21, 24; 126:2, 12, 20

firefighting [2] 12:25; 102:10 firehouse [6] 9:12; 11:23; 12:6, 8; 19:3; 123:15firehouses [3] 11:19; 123:8, 9 fires [2] 118:6; 120:14 firm [2] 20:19; 107:2 first [43] 4:2; 9:11, 22; 11:18; 15:15, 17; 26:21; 27:16, 20; 28:9, 12; 29:10; 31:18, 19, 21; 32:2; 33:4; 38:2, 10; 39:12, 22, 24; 44:16; 45:6, 9, 25; 50:3; 52:24; 53:2; 60:25; 62:22; 63:18; 66:12; 69:12; 82:10, 21; 84:10; 87:2; 95:20; 102:17; 120:21, 23; 121:11firsthand [1] 111:15 fisher [1] 8:20 five [6] 13:10, 12; 15:7; 21:4; 32:11; 53:14floor [5] 1:23; 2:5; 20:18; 28:6; 130:2folks [2] 16:5; 79:21 follow-up [1] 105:19 followed [1] 28:15 following [3] 82:10, 22; 89:5 follows [2] 4:3; 91:12 form [8] 17:9; 35:8, 11; 43:4; 79:25; 90:19; 97:17; 100:20formal [4] 54:3, 15; 55:4; 76:9 former [7] 25:24; 49:21; 84:14; 86:12, 16, 18; 104:2forth [4] 50:17; 61:4; 72:17; 129:11 forward [2] 22:10; 70:12 forwarded [3] 71:15; 103:13, 17 found [9] 7:22; 30:20; 32:17; 33:16; 49:20; 56:25; 86:6; 116:13, 16four [5]

7:9; 32:11; 54:12; 104:2; 115:25fourth [1] 74:4 francis [1] 8:21 frank [3] 28:19; 88:4, 7 free-flowing [1] 41:9 frequency [1] 50:10 frequent [1] 10:9 frequently [3] 18:9; 22:3; 25:15 fresh [8] 31:11, 12, 15; 113:18; 114:3, 5, 9, 18friend [2] 38:19; 124:7 frivolous [1] 54:14 front [3] 68:23; 109:20; 117:12 full [2] 4:15; 18:25 full-time [7] 18:22, 24; 19:5; 109:4, 5, 8, 25function [2] 24:5; 116:6 fund [14] 78:19; 88:20; 89:9, 23; 90:10, 16, 18; 91:10, 19; 92:3, 4, 7, 10, 18furnished [1] 102:20

* * G * *gaining [1] 83:6 gallagher [19] 14:16, 17, 23; 43:20; 45:25; 46:2; 48:10, 20; 56:18; 57:2, 12; 79:20, 23; 80:4; 86:6, 13, 17; 87:15; 121:20gallagher's [4] 46:8, 15; 61:18; 86:19 garbage [2] 113:25; 114:12 gary [33] 1:3; 2:20; 4:13; 37:23; 38:3; 48:7, 12; 61:10; 68:9; 72:24; 82:9, 20; 83:16; 90:25; 91:4, 6, 25; 93:18; 94:2, 8, 14, 16; 107:20, 22; 108:2, 6, 8; 114:21; 119:11; 120:21; 121:4, 11; 126:14gaskell [2] 1:7; 94:11


From employed to gaskellwww.ellengrauer.com


gathered [1] 34:25 gave [4] 50:2; 96:11; 100:10; 125:20gear [1] 27:4 generated [1] 50:5 give [25] 6:19; 33:10; 37:11; 40:8, 18; 43:8; 52:18; 63:22; 96:14; 99:18, 21; 120:11, 18; 122:6, 21; 123:5; 124:2, 7, 23, 24; 125:16; 126:8, 11, 14, 18given [18] 6:10; 19:22; 23:22; 97:12, 18, 21; 100:3; 119:18; 122:4; 123:19, 21; 124:3, 15, 16; 125:23; 127:10; 128:13; 129:13giving [1] 125:5 glance [2] 71:10; 84:3 goals [1] 88:24 gorman [13] 25:23; 46:2, 6, 19; 47:8, 17; 49:22; 56:18; 57:2, 13; 86:6; 87:14; 121:21gorman's [1] 61:19 grabbed [1] 27:4 grade [1] 11:18 graduate [1] 8:13 grant [12] 40:7, 14; 41:10; 43:11; 45:14, 19, 20; 58:21; 61:23; 80:11; 85:6; 86:9granted [10] 18:25; 19:22; 39:16; 43:12, 24; 45:12; 70:9; 88:10; 100:17; 122:4granting [1] 41:25 grauer [2] 1:23; 130:2 great [1] 6:22 greatly [1] 105:14 gribbon [4] 28:19; 88:4, 7, 12 grievances [2] 10:7; 108:21 ground [69] 26:10, 14, 18, 19, 22;

27:18; 28:8; 29:4, 8, 15; 30:7, 8, 17; 31:5, 8, 16; 32:7; 34:8; 35:13, 19, 23; 36:15, 16, 21, 23; 37:2, 7, 16, 18; 38:25; 44:3, 8; 49:19; 59:20, 23; 62:24; 64:13; 66:6, 24; 68:16; 69:17; 71:17; 73:2; 74:6; 81:2; 83:6, 17; 95:23; 96:4, 15, 16; 99:15, 22; 103:18; 105:5, 11; 111:8, 13, 18, 20, 22, 24; 112:7; 113:7, 22; 114:22; 118:12, 24; 119:21groundrules [1] 5:10 group [3] 53:15; 124:16, 20 guess [9] 41:17, 21; 73:22; 110:7; 115:15; 118:8; 119:25; 120:25; 122:14guessing [1] 62:7 guidelines [4] 82:11, 17, 23; 83:11 guy [2] 33:8; 80:9 guys [1] 32:3

* * H * *half [1] 9:11 hallway [1] 106:18 hand [2] 34:11; 129:20 handle [2] 22:23; 110:9 haphazard [1] 29:25 happening [1] 68:2 happens [1] 93:7 happy [2] 5:19; 6:8 hartson [3] 2:10; 4:10; 107:3 haven't [4] 59:7; 69:9; 108:9; 113:8 hazy [1] 27:16 he's [26] 20:25; 21:2, 5, 13, 25; 22:13; 23:9, 10, 25; 24:14; 28:21, 22; 66:7, 11; 73:22; 83:12; 86:2, 23; 87:11; 104:10; 116:19, 20, 21;117:3; 120:23

head [3] 5:25; 16:24; 89:19 headquarters [3] 28:4, 10; 108:22 headshots.com [1] 91:7 health [2] 15:9; 16:9 hear [1] 5:16 heard [9] 31:11; 37:20, 23; 38:2; 39:12; 48:7; 66:12; 72:21; 101:12hearing [2] 32:22; 101:13 held [3] 15:14; 16:5; 18:18 helped [1] 44:10 helping [1] 28:25 hereby [2] 128:7; 129:9 hereinbefore [1] 129:11 hereunto [1] 129:19 hhlaw.com [1] 2:17 high [4] 8:8, 10, 11, 13 highlighted [1] 118:24 hogan [3] 2:10; 4:10; 107:2 hold [3] 11:14; 12:24; 17:4 holdings [2] 1:6; 130:4 home [1] 27:3 honest [8] 27:15; 31:25; 32:10; 48:13; 51:2; 62:8; 94:3; 122:11honorary [3] 126:21, 24; 127:3 honored [1] 97:24 hope [2] 123:11, 16 hopes [1] 123:13 horrible [2] 104:6 host [1] 10:7 hour [1] 44:18 hours [4] 31:20, 22

house [1] 27:4 humenesky [1] 16:13 humiliating [1] 63:24 hundred [1] 90:7

* * I * *i'd [4] 16:4; 55:6; 60:4; 62:7 i've [15] 5:3; 21:3; 45:2; 69:25; 88:17; 92:16; 104:22; 113:9, 12; 114:3, 4, 6; 115:4; 119:18; 120:8i.d. [1] 3:14 i.e. [2] 13:11; 36:11 idea [12] 41:19; 44:7; 50:5; 73:5; 82:24; 83:12; 84:15; 87:11; 90:4; 104:7, 10; 112:10identification [1] 7:2 illegal [1] 119:12 illegally [5] 95:23; 119:20; 120:2, 5; 123:15immediately [3] 76:17; 77:13; 114:21 impact [1] 27:9 impeached [1] 54:5 impeachment [1] 54:18 implied [1] 40:15 implying [1] 43:13 important [3] 25:10; 47:25 impossible [1] 23:21 improbable [1] 96:19 improperly [2] 95:21; 96:3 inaccurate [3] 79:5; 102:22; 103:5 inc [1] 1:6 incident [1] 52:21 include [1] 114:12 incorporated [1]

1:6 independently [1] 17:13 index [1] 1:9 indirectly [1] 64:12 individual [5] 17:7; 37:7, 17; 110:5; 124:23individuals [5] 16:15; 33:21, 23; 41:2; 111:14information [11] 3:7; 28:7, 8, 22, 23; 32:19, 22; 95:15, 18; 99:7, 10initial [1] 78:24 initially [3] 52:22; 113:10; 124:11 initiate [2] 22:10; 55:4 injuries [1] 28:5 injury [1] 28:5 inquiries [3] 62:12, 19; 64:10 inquiry [1] 65:5 insecure [1] 84:13 insofar [2] 100:15; 110:6 instance [3] 55:19; 116:4; 126:13 instances [3] 10:20; 21:22; 50:23 instructed [1] 110:18 instructions [1] 6:15 interact [1] 16:23 interaction [2] 56:10; 73:15 interest [1] 107:17 interested [1] 129:17 interesting [1] 82:19 interests [1] 104:4 intermediary [2] 23:19; 73:21 internally [1] 53:20 internet [2] 116:5, 9 interview [1]

From gathered to interview Ellen Grauer Court Reporting(212) 750-6434

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22:17 interviewed [4] 57:15, 18; 82:8, 20 interviews [1] 33:9 introduce [1] 82:12 introduction [1] 97:5 investigate [4] 49:9; 118:6, 11; 120:6 investigates [1] 55:15 investigating [1] 120:14 investigation [5] 57:21; 67:12, 23, 24; 122:10investigatory [1] 112:19 investments [1] 53:17 involved [9] 10:23; 22:8; 24:2; 27:9; 33:20, 22; 36:21; 63:25; 89:12involvement [1] 22:8 involves [2] 20:9; 53:17 involving [2] 19:12; 110:19 iodice [1] 46:24 iron [1] 30:10 island [2] 16:2, 13 issue [10] 10:25; 21:17, 20; 39:10; 67:18; 68:2; 76:5; 78:15; 87:5, 10issued [1] 124:11 issues [13] 10:6; 11:8; 17:5, 8; 23:2, 23; 24:20, 21; 25:9; 53:18; 93:11; 108:22; 116:11item [4] 37:7, 18; 70:24; 112:23 items [20] 29:19; 30:17, 21; 32:17; 35:9; 36:16, 23; 96:16; 99:15, 22; 111:8, 12, 18; 118:12, 24; 119:6, 9, 20; 120:5

* * J * *jack [1] 26:4 james [4]

63:9; 71:12, 13; 85:14 jared [2] 2:3, 7 jason [1] 2:14 jay [2] 4:9; 106:17 jewelry [1] 36:12 jim [11] 15:18; 16:8; 22:25; 23:5, 25; 69:12; 70:3; 73:23; 87:19; 103:19job [9] 9:10; 81:12; 109:4, 5, 9, 25; 110:13; 116:14; 118:4jobs [1] 73:20 joe [3] 15:21; 16:10; 125:11 john [4] 1:7; 8:20; 15:23; 16:12 join [1] 50:15 joint [7] 25:17, 20; 50:8, 13, 18, 21; 97:5jpconti [1] 2:17 july [4] 13:23; 14:7, 10; 53:3

* * K * *keep [1] 33:14 keeping [1] 107:18 kelly [2] 15:23; 16:12 kept [1] 58:24 kevin [14] 14:16, 23; 15:20; 43:20; 46:8, 12; 47:10; 48:3, 10, 14; 86:6, 13, 17; 121:20kevin's [4] 46:24; 47:4; 48:3; 49:24 killed [2] 36:10; 89:3 kills [7] 31:11, 15; 113:18; 114:3, 5, 10, 18kim's [1] 31:12 kinds [3] 17:16, 18, 19 kiosk [1] 90:24 knowledge [12] 7:21; 24:18; 43:16; 52:5; 65:9, 14; 73:24; 81:11;

83:2, 4; 91:18; 111:16

* * L * *labeled [1] 91:2 labor [1] 116:11 landfill [6] 31:12; 36:18; 113:18; 114:4, 5, 10lane [1] 4:18 lash [1] 77:5 last [12] 3:10; 10:22; 11:3; 62:22; 77:8; 85:10; 86:10; 96:8; 101:15; 102:16; 107:5; 108:4late [8] 23:15; 26:23; 30:3; 38:5; 39:7; 54:9; 120:22, 25latitude [1] 21:24 law [1] 107:2 lawsuit [2] 5:7, 13 lawyer [2] 87:5; 92:24 layne [4] 16:11; 66:21; 67:6; 118:17 lead [1] 33:8 leaders [1] 101:16 leading [1] 56:15 leaf [1] 7:3 learned [1] 95:25 leave [1] 102:18 lefkowitz [18] 2:3, 7; 3:5; 6:4; 12:10; 19:17; 35:8, 11, 15; 59:10, 13; 90:19; 97:16; 98:14; 105:18, 21; 117:19; 127:11legal [2] 24:20, 21 legitimacy [2] 63:19; 64:6 lengthy [2] 82:11, 23 lester [4] 16:11; 66:21; 67:6; 118:17 let's [3] 8:7; 10:9; 57:25 letter [69] 43:21; 45:3, 7, 10, 14, 18,

24; 46:5, 8, 9, 16, 19, 21; 47:3, 4, 6, 7, 14, 18; 48:4, 12, 16, 19; 49:9; 50:3, 6, 8; 56:20, 23; 60:15; 61:2, 18; 63:17; 64:18; 73:4; 74:14; 75:2, 4, 8, 17, 19, 22, 23; 76:10, 12, 19, 23; 77:4, 11; 78:6, 9, 13, 19, 24; 80:7, 8; 83:11, 24; 84:17; 86:3, 12, 16, 24; 87:6; 91:24; 96:22; 97:5, 9letterhead [1] 50:11 letters [2] 43:9, 10 liaison [1] 23:2 lieutenant [2] 12:19; 37:16 life [1] 66:10 light [1] 28:4 linda [1] 79:12 line [5] 62:22; 74:21; 79:12; 89:4; 130:6list [1] 124:15 listed [1] 16:16 listen [1] 5:14 llc [2] 1:23; 130:2 located [1] 9:19 logistics [1] 29:18 looks [2] 55:14; 123:4 lot [2] 26:17; 88:2 lower [1] 100:22 loyal [1] 104:3

* * M * *main [2] 24:5; 116:6 mainly [1] 33:12 major [3] 11:2; 63:22; 87:21 majority [1] 18:17 man [3] 22:13; 66:10; 108:24 management [1]

19:15 mandates [1] 14:12 manhattan [10] 15:24; 16:14; 27:5; 38:11; 52:11; 81:5; 95:20; 108:18; 109:17; 110:10manner [3] 17:9; 91:15; 100:19 mantle [3] 39:16; 40:8, 21 mark [1] 6:23 marked [4] 6:25; 7:9; 65:19; 81:24 marriage [1] 129:17 marshal [12] 13:16; 15:10; 16:3, 11; 19:3, 4; 42:7; 66:21; 67:7; 118:18; 120:8, 9marshals [12] 13:18; 30:23; 66:22; 114:16; 118:5, 10, 15, 19; 119:3, 5, 8, 19material [4] 29:19; 30:7, 11; 31:14 materials [1] 115:9 matter [4] 20:8; 57:10; 105:12; 129:18matters [1] 21:9 mcadams [1] 15:21 mcardle [5] 15:20; 125:14, 15; 126:3, 14mcdonald [1] 26:4 mean [12] 21:10; 31:6; 36:3, 7; 38:25; 41:16; 67:24; 87:23; 90:20; 120:3; 124:20, 22meaning [4] 36:17; 81:13; 99:23; 116:17means [3] 19:2; 35:23; 104:14 meanwhile [1] 96:21 media [21] 10:5, 8, 17, 20, 24; 21:25; 22:12; 28:17; 32:20; 33:14, 18; 63:22; 64:22; 65:6, 15; 70:15; 71:4; 72:17; 102:23; 104:17; 116:7medications [1] 6:18 meet [5] 88:13; 92:24, 25; 93:4, 6 meeting [27]


From interviewed to meetingwww.ellengrauer.com


18:12, 14, 15, 18, 19, 20; 38:17; 39:4, 20, 21, 23, 25; 40:13; 54:20, 25; 55:2, 10; 57:4, 7, 8, 10; 75:12, 14; 76:6; 87:18; 121:14; 122:15meetings [12] 3:9; 17:5; 18:3, 9; 41:3; 57:16; 58:9, 25; 59:15; 121:3, 12member [9] 13:7; 16:25; 18:12, 15, 24; 42:4, 7, 8; 84:14members [17] 13:10, 11; 17:8; 19:12; 23:22; 41:6; 54:21; 61:14; 75:15; 82:13; 87:18; 89:20; 102:12; 104:2; 108:23; 110:20; 124:24membership [3] 13:4; 55:17; 110:7 memorial [2] 91:8; 92:4 mention [2] 48:6; 87:19 mentioned [10] 10:8; 15:6; 18:8, 21; 23:5; 24:11; 38:10; 39:24; 52:9; 118:14mentioning [2] 39:23; 47:17 merit [1] 54:22 message [1] 103:13 metcalfe [1] 106:23 miccio [3] 15:21; 16:10; 125:11 michael [7] 7:17; 18:2; 24:11; 61:15; 92:24; 101:10; 103:11middle [4] 84:12; 91:25; 98:21; 103:25midst [1] 47:23 midway [1] 99:12 mike [4] 41:8; 57:19; 67:25; 80:19 mind [4] 57:24; 59:17; 119:10, 22 minute [1] 7:4 minutes [7] 3:9; 58:8, 24; 59:5, 7, 9, 15 mirro [1] 53:7 misinformation [1] 63:23 missed [2] 116:18, 21

mistaken [2] 60:18; 66:7 moment [2] 115:6; 122:22 money [11] 36:12; 89:2, 6; 90:5; 92:2, 9, 19; 98:6, 8, 10, 17month [3] 18:10; 122:13, 17 months [1] 27:20 morning [5] 4:7, 8; 10:23; 79:12; 115:15mostly [2] 116:7, 9 motivated [2] 75:23; 77:4 moved [2] 14:11; 30:7 moving [1] 59:10 mr [249] 3:4, 5, 17; 4:6, 7; 6:3, 4; 8:4; 12:10, 13; 14:17; 19:17; 22:4, 7, 21; 23:18; 24:3, 8, 17; 35:8, 11, 15; 38:10, 13, 18; 39:9, 16; 40:2, 7, 13; 41:4, 12, 25; 42:14; 43:3, 18, 25; 44:2, 10, 13; 45:9, 11, 18, 22, 23, 25; 46:2, 6, 13, 15, 19, 20; 47:8, 17; 48:9, 20; 49:10, 12, 15, 19; 50:2; 53:9; 54:2; 56:4, 11, 18; 57:2, 5, 12, 13, 24; 58:4, 6, 15, 21, 22; 59:6, 10, 12, 13; 60:16, 17, 20; 61:6, 7, 11, 18, 19, 23; 62:11, 17, 19, 23; 63:19; 64:2, 7, 14, 17, 20; 65:15, 16, 18, 22; 66:2, 3, 4, 5, 13, 17, 18, 23; 67:5, 11, 14, 16, 17, 18, 22; 68:8, 12; 69:12, 14, 20, 21, 24; 70:6, 17, 18, 20; 71:15, 16, 18; 72:12; 73:5, 9, 12, 17, 20;74:2, 21; 75:5, 25; 76:7, 9, 16, 19; 77:2, 20; 78:7, 15, 25; 79:20, 23; 80:4, 11, 17, 21, 24, 25; 81:7, 8, 12, 15; 82:17, 18; 83:3, 5, 6, 20, 24; 84:16, 21, 25; 85:11, 14, 19, 23, 25; 86:14, 19, 24, 25; 87:3, 8, 14, 15, 16; 88:5, 10, 12, 13, 16; 89:21;90:6, 14, 19; 91:13, 17; 92:13, 23; 93:10, 16; 94:20; 96:2; 97:16; 98:9, 14; 99:19, 24; 101:22; 103:22; 104:7, 20, 24, 25; 105:14, 18, 21; 106:6, 14; 113:17; 115:7; 117:19; 118:15, 16;

119:23; 121:6, 7, 10, 24; 122:4; 125:15; 126:3, 14; 127:11, 13, 14, 17, 19 murphy [1] 16:14 murray [3] 1:6; 93:21, 23 museum [15] 61:5; 64:7, 10, 20; 66:13; 67:14, 19; 68:13; 69:17; 71:17; 103:19; 119:3, 6, 9, 19myself [1] 69:18

* * N * *name [26] 3:10; 4:9, 16; 22:25; 37:12, 20, 23; 38:3, 15; 39:13; 40:2; 45:9; 46:8; 48:7, 11; 52:4; 53:5; 91:4; 96:10; 101:12, 14; 102:16, 17; 115:8; 130:4, 5nature [5] 26:25; 54:10; 65:25; 70:4; 117:13nazareth [1] 8:11 neck [1] 4:17 needs [2] 5:24; 108:19 negotiate [1] 10:4 news [5] 1:6; 11:3; 64:23; 72:21; 115:18newspaper [1] 101:21 newspapers [4] 115:3, 4; 116:8, 9 night [2] 10:22; 11:3 nobody [1] 40:13 nod [1] 5:25 nolan [3] 1:17; 129:7, 23 notary [4] 1:18; 128:23; 129:8; 130:24noted [2] 64:14; 127:20 noticing [1] 34:4 notified [1] 68:12 notify [3] 55:8; 102:23; 103:3 november [4] 27:22; 34:8, 11; 78:23

nowhere [1] 97:8 number [1] 111:2 numbered [1] 44:22 numbers [1] 44:22 nyp [1] 130:4

* * O * *oath [3] 6:10, 11; 128:9 object [2] 35:8, 11 objection [7] 6:3, 6; 35:15; 90:19; 97:16; 98:14; 119:23obligatory [1] 6:17 obviously [1] 44:6 occasion [2] 52:8; 116:21 occasionally [2] 25:21; 93:7 occasions [2] 24:19; 58:6 occupation [1] 4:20 offered [1] 9:3 office [15] 13:22; 14:15; 15:17; 16:16; 20:17; 28:7, 24; 32:19; 46:7; 47:5; 51:16; 106:23; 108:24; 115:15; 117:25officer [1] 12:15 officers [12] 19:15; 25:5, 13; 33:25; 49:23; 50:12; 89:3; 97:6; 114:15; 123:12; 127:2, 8offices [1] 9:20 official [64] 23:9; 37:6; 39:17; 40:9, 23; 41:11; 43:24; 45:21; 49:15; 58:21; 59:20, 22, 25; 61:23; 62:23; 64:8, 15; 68:15; 70:10; 71:2; 72:13, 25; 74:6; 76:2; 77:15; 78:16, 21; 79:2; 80:11, 25; 81:9, 15; 83:8, 9, 16; 84:13; 85:2, 13, 20; 86:3, 12, 16, 23; 87:7; 95:21; 96:23; 97:8, 11, 19; 99:14, 18, 24; 100:4, 10, 18; 104:25; 105:5, 10; 121:8; 122:5; 124:14; 125:22; 126:10, 17

officials [7] 13:9, 13; 96:21; 97:9, 23; 100:2, 9oh [2] 31:12; 110:23 okay [32] 31:7; 40:16; 44:20; 46:12; 47:10; 60:8, 9; 63:7; 69:2, 6; 71:22; 74:16, 25; 77:10; 78:2; 79:10, 15; 81:22; 84:5; 95:6; 98:23; 100:25; 101:2; 103:10, 15; 106:16; 108:11; 109:11; 111:7; 114:20; 122:18one-on-one [1] 11:7 one-on-ones [1] 11:8 one-page [4] 63:8; 69:3, 11; 71:14 ones [1] 55:21 ongoing [1] 9:13 open [1] 79:9 opened [1] 67:14 opening [3] 66:13; 67:19; 68:13 operation [1] 89:9 opinion [2] 71:5 opponent [1] 53:6 opportunity [2] 17:7; 29:23 opposed [3] 36:17; 53:22; 63:22 orchestrated [1] 103:23 order [2] 55:4; 109:8 organization [1] 88:22 origin [1] 118:7 original [1] 127:15 outcome [1] 129:18 outlet [1] 104:17 outlined [14] 17:22, 24; 18:16; 82:11, 23; 86:24; 97:20; 109:12, 13, 24; 110:5, 14, 24; 111:4outside [4] 93:5; 116:25; 123:7; 125:21oversee [1]

From meetings to oversee Ellen Grauer Court Reporting(212) 750-6434

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89:18 owner [1] 91:7

* * P * *p.m. [1] 127:20 page [9] 3:3, 8; 7:9; 77:9; 91:5, 22, 23, 25; 130:6pages [3] 44:22; 77:23; 91:21 pain [1] 52:24 paper [1] 118:23 papers [3] 10:22; 11:4; 101:25 paragraph [13] 62:23; 69:13; 74:4; 77:8; 82:6; 84:11; 85:10; 86:11; 87:3; 95:20; 96:20; 97:22; 103:22paragraphs [1] 97:14 pardon [1] 80:15 park [1] 123:7 parked [1] 123:14 parking [3] 123:9; 125:16; 126:15 part [4] 13:18; 18:25; 89:25; 110:12participate [3] 27:7; 29:2, 7 participated [1] 34:5 parties [2] 63:25; 129:16 pension [1] 53:16 people [22] 15:3, 5; 22:22, 23; 26:17; 29:23; 30:16; 32:17; 33:14, 17, 23; 34:5; 51:24; 55:3; 93:5; 104:15, 16; 118:7, 11; 124:15, 16, 21perceived [1] 73:25 perform [2] 33:7; 109:8 period [5] 11:13; 44:3; 57:12; 121:19; 122:17periods [1] 32:3 permission [5] 96:11, 14; 99:14, 18, 21 person [8]

20:14; 42:14; 52:25; 53:15; 60:21; 108:5; 115:8; 127:9personal [5] 30:21; 36:5, 17; 37:3; 96:17personally [3] 110:11; 111:9; 113:8 pertinent [1] 21:10 pete [5] 46:10; 49:22; 86:6; 121:20 peter [1] 25:23 phil [2] 15:20; 125:14 phone [10] 2:8, 15; 48:2; 72:20, 23; 73:7, 22; 108:23, 24; 122:9phones [2] 28:13; 32:11 photo [1] 82:15 photocopy [1] 123:4 photog [1] 87:7 photograph [5] 59:20; 70:10; 71:3; 83:16; 86:23photographer [45] 39:17; 40:10, 24; 41:11; 43:25; 45:21; 49:15; 58:22; 59:23; 60:2; 61:24; 62:24; 64:8, 15; 68:15; 72:14, 25; 74:6; 76:2; 77:16; 78:16, 22; 79:2; 80:12; 81:2, 9, 16; 83:8, 9; 85:2, 20; 86:4; 95:20, 22; 96:4, 9, 24; 97:19; 99:25; 101:17; 104:25; 105:5, 11; 121:8; 122:5photographs [5] 38:20; 44:5; 92:14; 114:22, 25photography [1] 91:7 photos [2] 82:9, 21 pick [1] 48:2 picture [1] 113:12 pictures [2] 36:12; 113:9 piece [1] 112:19 placard [10] 123:5, 10; 124:11; 125:16, 17, 25; 126:8, 15, 25placards [7] 124:23; 125:3, 6, 20; 126:4, 11, 18

place [7] 29:4, 14; 36:15; 39:4; 41:15; 52:22; 55:18plaintiff [3] 1:4; 2:4; 4:14 played [1] 46:20 please [8] 4:15; 5:18, 25; 12:17; 59:14; 77:11; 100:21; 117:9pledge [1] 97:24 point [18] 5:7; 26:5; 28:18; 34:9; 39:15; 40:6; 47:8; 48:20; 54:2; 66:9; 72:12; 76:4, 19; 83:24; 86:4; 92:23, 25; 124:18pointed [3] 33:23; 34:2; 45:23 police [7] 30:24; 33:25; 35:20; 112:18; 114:15; 123:12, 17policies [1] 36:15 politics [1] 116:12 pony [1] 28:14 popped [1] 68:11 portion [1] 79:13 position [18] 9:15, 23; 11:14; 18:21, 22; 19:8; 53:13, 19, 25; 77:19; 79:5; 81:13; 121:25; 122:2; 125:22; 126:10, 18positions [6] 12:25; 15:14; 16:6; 18:23, 24; 19:5positive [3] 72:19; 73:6, 25 possession [1] 96:17 post [26] 4:11; 11:4; 32:7; 64:25; 65:3, 5; 72:21, 22; 93:18; 94:20; 95:24; 97:11; 100:12; 101:22; 103:3; 104:5, 8, 12, 16, 19; 107:7,10, 14; 108:5, 8, 14 premise [1] 119:18 prepare [4] 102:6; 105:22; 106:2; 115:8preparing [2] 96:21; 106:10 present [1] 2:19 president [45]

4:22; 9:13, 16; 10:3; 13:13, 20; 14:14; 15:8, 15, 18, 19; 16:7, 8, 20; 17:2, 14; 18:14; 19:23, 25; 21:3, 6; 25:24; 26:2; 38:7; 42:9; 43:20; 47:2, 6; 49:21, 22; 50:24; 51:20; 52:23; 53:11; 75:16; 80:10; 86:13, 17; 89:13; 109:2, 23; 110:25presidential [1] 46:23 press [20] 11:6; 20:21; 21:11, 18, 21, 23; 22:9, 23; 24:9, 17, 22; 25:20; 60:24; 62:18; 65:10; 69:16; 70:17; 107:11, 19pressed [1] 107:17 pretty [7] 10:4; 22:18; 24:4; 56:13; 109:16; 116:19, 20prevent [1] 6:19 previous [7] 43:12, 17, 20; 61:17; 73:19; 100:8; 121:22previously [3] 68:4; 80:6; 99:13 print [3] 50:21; 116:3; 125:25 prior [11] 11:13; 12:3, 24; 14:15; 28:3; 65:5; 68:18; 80:10; 85:18; 106:16, 19private [1] 36:20 probationary [1] 9:5 problems [2] 53:10; 110:19 procedure [5] 51:17; 54:16, 17; 55:5; 56:3procedures [3] 29:14; 30:16; 81:8 proceed [1] 29:16 proceeds [1] 97:25 procuring [1] 46:21 produce [1] 117:25 productive [3] 72:20; 73:7; 74:2 progress [1] 33:12 prohibited [1] 36:19 projects [1] 109:2 promotional [1]

12:23 property [1] 37:3 protect [1] 10:5 protesting [1] 43:10 protocols [1] 55:10 prove [1] 120:2 provide [2] 96:10; 116:6 provided [3] 95:15; 99:7; 106:13 providing [2] 95:18; 99:9 prudent [1] 85:5 public [12] 1:18; 20:13; 22:13; 24:2; 28:7, 8, 22, 23; 32:18; 128:23; 129:8; 130:24published [1] 92:14 pull [1] 74:24 purpose [2] 5:11; 63:20 purposes [1] 88:23 pursuant [1] 1:17 puts [1] 102:13

* * Q * *queens [2] 15:25; 16:13 question [11] 5:15, 16, 18, 20; 6:5, 17; 87:2; 107:24; 108:14; 115:7; 120:15questioned [1] 64:13 questions [5] 5:12; 17:25; 105:16, 19; 127:12quick [3] 71:21; 79:11; 84:3 quickly [4] 68:21; 69:3; 71:9; 103:8 quote [5] 43:24; 45:12; 72:18; 95:19; 109:21quotes [1] 83:15

* * R * *radar [1]


From owner to radarwww.ellengrauer.com


87:24 raise [3] 17:8; 23:24; 54:25 raised [7] 39:13, 15; 48:15; 54:25; 86:2; 88:25; 89:6raises [1] 92:2 raising [1] 92:8 ran [3] 14:22; 52:23; 53:2 range [1] 23:20 rank [1] 12:22 ranks [2] 12:18, 23 rare [1] 24:19 re [1] 69:17 read [19] 10:22; 45:2; 48:4; 63:18; 69:25; 71:8; 79:18; 84:10; 90:22; 91:15; 95:19; 98:20; 101:20; 102:2, 3, 21; 114:6; 128:8reading [6] 72:5, 7; 82:6; 85:10; 95:12; 101:6realized [1] 107:23 reason [5] 45:24; 47:8; 49:11; 78:12; 130:6recall [81] 7:14; 8:15; 15:13; 23:14; 26:21; 27:12; 38:2, 13; 39:3, 6, 9, 19, 25; 40:4; 41:2, 24; 42:16, 19, 21, 24; 43:6; 45:6, 17; 47:17; 48:8, 11; 54:6; 55:23; 56:21; 60:12; 61:8; 62:5, 9, 10, 16; 63:14, 16; 65:12, 25; 66:12, 16, 20, 25; 67:10; 68:7; 69:19; 70:4; 72:2, 4, 5, 7, 9; 75:2; 81:3; 83:23; 84:8; 87:15; 88:3, 6; 90:13; 93:2, 16, 20, 25; 94:3, 15; 95:9; 98:24; 99:9; 101:13, 23;103:2, 20; 105:2; 108:7, 10, 15; 113:4; 115:5; 117:11; 122:11receive [4] 8:23; 9:6, 8; 98:7 received [10] 8:25; 9:2, 9, 13; 43:2, 10; 64:9; 72:3; 90:11; 92:18receiving [2] 72:4; 75:2

recess [3] 58:3; 93:15; 122:25 recognize [2] 95:7; 101:3 recognized [1] 127:9 recollection [13] 23:16; 38:9; 40:23; 41:15; 55:7; 56:2; 64:9, 16, 19; 72:17; 88:14; 121:5; 122:20recommendations [1] 40:19 record [10] 4:16; 59:14; 74:6; 82:14; 88:15; 117:19; 127:13; 128:11, 13; 129:13recording [6] 13:14; 15:9, 22; 16:10; 125:7, 9records [1] 8:5 recounted [1] 38:17 recovered [1] 32:18 recovery [7] 29:3, 15, 16; 30:3, 5; 38:23; 44:3reelected [2] 14:3; 16:7 reelection [1] 14:24 ref [1] 1:25 refer [5] 17:25; 26:15, 17; 66:5; 82:25reference [6] 31:5; 35:23; 62:12; 64:18; 65:24; 102:22references [3] 84:16, 19; 86:18 referencing [2] 73:22; 104:8 referred [1] 83:11 referring [8] 64:3; 73:6; 77:14; 86:14; 87:9; 95:3; 99:15; 113:10refers [2] 26:11; 87:9 reflect [2] 59:5; 77:19 refresh [1] 55:7 refuted [1] 64:17 regarding [7] 5:12; 30:16; 59:6; 69:15; 76:22; 93:18; 94:20regular [3]

17:4; 18:8; 58:25 regularly [3] 92:2; 102:3; 110:2 rehash [4] 68:4, 17; 70:7; 80:5 relate [1] 25:12 related [3] 62:19; 118:7; 129:15 relates [9] 7:20; 10:6, 25; 11:8; 24:20, 21; 61:4; 100:19; 108:21relating [8] 12:25; 17:5; 101:25; 102:9; 116:10, 11relation [1] 102:4 relations [4] 20:14, 21; 22:13; 24:2 relationship [8] 25:9, 23; 26:8; 38:18; 52:14; 61:22; 104:15, 16relatively [1] 122:16 release [1] 18:25 releases [1] 25:20 remaining [1] 55:22 remains [3] 30:12, 13, 21 remarks [1] 69:15 remember [37] 5:3, 5, 8; 13:20; 15:14; 27:14; 31:25; 38:16; 39:23; 53:5; 54:13; 62:20; 65:20, 22; 67:2; 68:10; 69:23; 70:2; 72:11; 74:17; 75:13; 80:3, 19; 82:3; 94:17; 95:12, 14, 17; 99:2, 3; 101:5, 6; 103:16; 113:13, 14, 16remnant [3] 35:25; 36:2, 3 remove [5] 36:22; 37:2, 7, 18; 111:7 removed [13] 30:8, 12, 14; 34:3; 111:13, 18, 22, 24; 114:9; 118:12; 119:20; 120:6removing [5] 30:17; 33:20, 22; 36:16; 111:20rep [6] 16:3, 11; 19:4; 42:7; 67:7; 118:18repeat [1] 5:18 replied [2]

79:22, 24 report [1] 32:15 reported [1] 57:3 reporter [3] 5:23; 94:19; 129:7 reporters [6] 4:12; 10:10, 13; 11:6; 32:23; 33:10reporting [3] 1:23; 56:24; 130:2 represent [2] 90:23; 108:21 representative [4] 13:17; 15:11; 66:21; 82:7 representing [1] 77:15 represents [3] 13:17; 53:15; 118:18 request [2] 69:21; 92:23 requested [2] 3:7; 70:21 requests [2] 7:10, 16 require [2] 17:18; 51:16 required [2] 6:5; 51:18 rescue [3] 27:7; 29:3, 23 research [6] 49:20; 61:17; 67:12; 68:20; 86:5; 121:22researching [2] 56:23; 67:17 resolve [1] 121:19 resolved [4] 57:9; 76:5; 87:25; 122:15 respond [3] 5:15; 32:19; 91:11 response [2] 6:2; 106:14 responses [1] 5:24 responsibilities [7] 10:2; 17:4; 19:7; 23:18; 27:25; 109:22; 110:8responsibility [1] 118:11 responsible [4] 16:20; 19:11; 109:22; 125:8responsive [1] 7:15 result [2] 80:21; 92:19 retained [1] 3:17 retired [3]

23:10; 125:25; 126:3 return [1] 34:8 returned [1] 90:8 returning [1] 89:25 review [9] 48:20; 63:11; 69:3; 74:14; 102:7; 103:8; 106:9; 109:17reviewed [5] 48:23; 82:9, 20; 95:11; 103:4reviewing [17] 7:5; 44:25; 46:3; 60:8; 63:12; 69:5; 71:11, 21; 74:15; 77:25; 79:14; 81:21; 84:4; 95:5; 98:22; 99:3; 100:25right [11] 37:11; 44:21; 52:10; 70:16; 71:16; 72:18; 96:18; 111:5; 121:15; 122:4, 24right-hand [1] 100:23 rights [2] 10:5; 17:3 rochester [1] 8:21 role [5] 24:4; 28:17; 33:9; 46:19; 120:13romaka [1] 16:9 routine [1] 72:23 routing [1] 72:23 rubble [7] 29:8, 9; 112:2, 7; 113:22; 114:8, 11rudy [12] 15:24; 38:12; 46:7; 47:9; 49:24; 52:9; 77:6; 84:23, 24; 85:3; 117:5; 120:21ruland [2] 16:2, 12 rule [1] 24:24 rules [2] 29:13; 30:15 rummage [1] 96:11 rumors [2] 32:16; 33:5 run [3] 14:2, 17, 20 rundown [1] 16:5 running [1] 14:24

From raise to running Ellen Grauer Court Reporting(212) 750-6434

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* * S * *sad [1] 84:11 safety [2] 15:10; 16:10 salaried [1] 117:3 sales [2] 92:4, 19 samuel [1] 37:20 sanfilippo [43] 15:24; 38:12, 13; 39:9; 41:25; 44:10, 13; 45:11, 18, 22, 23; 46:7, 14, 20; 49:10, 12; 50:2; 52:9; 53:9; 54:2; 56:4, 11; 57:5; 58:15, 22; 76:7; 77:6; 80:24; 82:17; 83:3, 5, 20, 24; 84:23, 24; 85:3, 23, 25; 104:24; 117:6; 120:21; 121:6, 10sanfilippo's [2] 81:12; 85:11 satisfied [1] 98:11 saying [16] 40:9; 48:8; 62:18; 64:14; 67:2; 70:13; 72:15; 81:3; 86:3; 100:3; 108:9; 124:5; 126:3, 15, 17; 127:8scam [1] 95:4 scassidy [1] 71:24 scene [8] 34:17, 20, 22; 35:6, 10, 14, 18, 20scenes [1] 35:3 schedule [1] 18:13 scheduled [2] 14:7, 8 scheme [1] 61:11 school [4] 8:8, 10, 11, 13 screen [1] 87:24 search [4] 47:13, 15; 56:20; 57:13 searched [2] 7:15; 30:12 second [9] 58:15; 68:23; 72:18; 77:9; 82:6; 91:5; 99:11; 103:22; 124:11secretary [20] 7:19; 13:14; 15:9, 22; 16:11; 46:23, 25; 49:5, 6;

51:8, 13, 25; 52:5; 56:19; 57:14, 17; 125:7, 10secure [3] 49:14; 58:23; 121:7 send [10] 48:19; 50:16, 22; 75:8, 17; 76:12; 96:22; 98:17; 127:15, 16sending [1] 73:3 sense [1] 5:21 sensitive [1] 82:14 sentence [7] 61:2; 63:18; 72:19; 74:5; 84:11; 86:10; 101:15separate [2] 20:19; 89:15 september [10] 1:12; 12:7, 11; 89:5; 94:21; 103:12, 13, 17; 129:20; 130:5september11.net [2] 90:12; 91:8 sequential [1] 44:23 sergeant [5] 13:14; 15:10, 20; 16:10; 125:12serving [1] 14:23 seven [1] 22:6 seventh [1] 91:23 shake [1] 5:25 shape [2] 17:9; 100:19 she's [1] 46:25 sheet [1] 130:1 shifted [1] 31:23 shifts [3] 31:17, 19, 24 shocking [1] 72:21 shorthand [1] 129:7 show [2] 6:22; 94:24 shows [1] 71:17 sifted [1] 31:14 sifting [2] 29:18; 114:16 sign [3]

43:22; 46:10; 48:16 signature [14] 43:21, 23; 46:4, 15; 48:4; 49:2, 25; 50:24; 51:6, 7, 15, 16; 61:19; 91:4signatures [2] 51:18, 20 signed [11] 46:11; 47:7, 9, 20; 48:5; 49:23; 80:8; 86:12, 16; 91:3; 128:19significant [5] 88:25; 92:12; 98:6, 7, 17 significantly [1] 21:2 sit [1] 89:14 site [10] 26:15, 18; 30:14; 31:9; 33:7, 14, 18; 34:4; 37:18; 82:13sits [2] 24:3; 53:16 six [1] 34:12 slade [1] 106:23 slanderous [1] 69:15 sleeve [1] 74:24 slevin [2] 15:18; 16:8 sneak [1] 33:15 somebody [12] 56:20; 60:18; 66:8; 93:4; 102:15; 107:14; 108:13; 124:25; 125:17; 126:8, 13someone [5] 38:19; 96:15; 105:5, 6, 10 sophie [3] 1:17; 129:7, 23 sorry [2] 19:17; 120:16 sort [1] 91:25 sought [1] 65:15 speak [19] 10:12, 19; 21:22; 22:4, 15; 24:9, 17, 22, 25; 65:18; 69:23; 73:18, 19, 21; 79:25; 80:13, 16; 105:25; 106:5speaking [5] 19:6; 27:17; 41:3; 65:21; 108:7specific [4] 20:6; 76:24; 88:6; 120:12 specifically [8] 38:4; 45:8; 62:20; 65:8, 12;

75:14; 93:2; 117:11specifics [6] 38:16; 42:20, 24; 43:8; 54:13; 80:19speculate [2] 119:14, 17 spend [1] 88:2 spent [1] 114:21 spoke [17] 46:6; 56:18, 19; 60:24; 61:9; 70:17; 77:2; 80:18; 86:6; 93:25; 94:7, 15, 19; 107:6, 13; 108:4, 13spoken [11] 21:17; 42:16, 19; 57:13; 73:9; 93:21, 23; 94:4, 10, 13; 106:17spollen [26] 22:25; 23:5, 18; 24:8; 63:9; 65:18; 66:2, 3; 67:11, 16; 68:8; 69:12, 20; 70:3; 71:13, 18; 73:12, 17, 20, 23; 77:2; 85:14; 86:14; 87:20; 103:19squabbles [1] 25:11 ss [2] 128:4; 129:4 st [2] 8:20, 21 stack [1] 115:16 staff [8] 12:21, 22; 22:22, 24, 25; 23:6, 8; 28:10stamp [20] 46:3, 15; 47:4; 48:17; 49:3, 7; 50:24; 51:5, 7, 9, 10, 13, 14, 19, 23, 24; 52:4; 61:18; 80:7; 86:19stamped [6] 43:23; 46:4, 5; 47:7; 48:18; 49:4standard [1] 9:5 start [2] 11:22; 23:13 started [3] 15:15; 33:5; 86:5 state [8] 1:18; 4:15; 80:24; 83:15; 128:3, 23; 129:3, 8stated [1] 72:22 statement [15] 64:3; 74:9, 11; 77:18; 83:18; 84:16, 19; 85:16; 96:6, 9; 97:2, 13; 100:5, 13; 101:18

statements [1] 21:13 staten [2] 16:2, 13 states [7] 62:23; 87:6; 91:6; 96:20; 97:22; 101:16; 103:23station [3] 31:2, 3, 5 stationery [2] 50:13, 18 status [2] 86:9; 88:10 stayed [1] 12:2 steel [8] 111:21, 23; 112:2, 6, 13, 20, 25; 113:7step [1] 122:22 stephanie [2] 1:6; 94:10 stephen [7] 1:16; 3:2; 4:17; 128:7, 16; 129:10; 130:5stepping [1] 14:23 steps [2] 56:22; 120:6 steve [1] 16:13 steven [1] 74:21 stop [2] 96:22; 103:24 story [3] 33:2; 38:22; 107:12 straub [2] 15:23; 16:9 street [5] 1:23; 2:5; 9:21; 20:18; 130:2structured [3] 30:4, 6; 32:9 stuff [1] 114:4 subject [1] 101:10 subjects [1] 101:10 submitted [2] 7:22; 8:3 subpoena [4] 1:17; 3:15; 6:25; 106:14 subscribed [2] 128:19; 130:22 subsequent [1] 57:8 subsequently [1] 39:14 subside [1]


From sad to subsidewww.ellengrauer.com


33:5 substantial [3] 34:13, 15; 92:9 sudden [1] 85:12 sued [1] 4:12 suffered [1] 28:5 suggest [1] 125:13 support [2] 49:18; 50:20 supported [1] 52:24 suppose [1] 72:6 supposed [3] 29:16, 19; 33:25 surgery [1] 34:11 surprise [1] 76:25 surprised [1] 65:13 suson [138] 1:3; 2:20; 4:13; 37:24; 38:3, 10, 18; 39:16; 40:7, 13; 41:4, 12; 42:14; 43:3, 18, 25; 44:2; 48:7, 9, 12; 49:15, 19; 57:5; 58:6, 21; 59:6, 19; 60:17; 61:6, 10, 23; 62:19, 23; 64:2, 14, 20; 65:16, 22; 66:2, 5, 13, 18, 23; 67:14, 17, 18; 68:9, 12; 69:12, 21,24; 70:6, 18, 20; 71:15; 72:12, 24; 73:5, 9; 74:2; 75:25; 76:19; 77:20; 78:7, 15, 25; 80:11, 17, 21, 25; 81:7, 8, 15; 82:18; 83:6, 16; 84:21, 25; 85:19; 86:25; 87:3, 8, 16; 88:5, 10, 13, 16; 89:21; 90:6, 14, 25; 91:4, 7, 13, 17; 92:2, 13, 23; 93:10, 19; 94:2, 8, 14, 16, 20; 96:2, 22; 97:4, 11, 23; 98:9; 99:12, 19, 24; 100:3, 8; 101:16, 22; 103:22; 104:7, 20, 25; 107:20, 22; 108:2, 6, 8; 114:21; 118:16; 119:11; 120:21; 121:4, 7, 11, 24; 122:4; 126:14; 130:4suson's [5] 6:4; 40:2; 45:9; 64:7; 84:16 suspects [1] 117:21 sweeney [1] 92:4 sworn [4] 4:2; 14:4; 129:12; 130:22

* * T * *talk [1] 23:21 talked [3] 113:17; 117:5; 121:3 talking [13] 12:11; 29:17; 60:17; 66:8, 11; 67:3; 83:12; 87:11; 104:10; 106:19; 113:25; 114:2; 125:2tanners [1] 4:17 technical [1] 34:21 technically [1] 58:16 telecast [1] 10:22 telephone [1] 42:17 telling [1] 106:4 ten [2] 31:22; 42:8 tenure [1] 21:6 term [5] 26:10, 14; 31:4; 35:22, 25 terms [13] 13:24, 25; 14:24; 22:7; 25:7; 29:15, 18; 33:7, 11; 56:22; 68:5; 73:6; 104:8terrorist [1] 36:11 testified [8] 4:3; 56:17; 58:4; 59:18; 115:6; 119:24; 120:20; 121:18testimony [6] 5:24; 105:2; 118:15; 128:9, 12; 129:13thank [2] 105:17; 118:3 thanks [2] 105:16; 127:14 theme [1] 43:9 there's [11] 14:6, 8; 51:9; 71:16; 74:5, 20; 81:11; 89:15; 91:24; 96:9; 103:12they'd [1] 93:10 they'll [1] 23:25 they're [7] 6:11; 10:4; 50:19; 119:19; 123:14; 124:3, 15they've [2] 115:3

third [4] 1:11; 2:12; 20:18; 91:24 thomas [2] 20:12, 13 thorough [2] 116:19, 20 thousands [1] 97:24 three [6] 4:12; 13:25; 51:18, 20; 54:12; 115:24throw [1] 33:16 ticket [1] 123:14 tie [1] 42:11 ties [1] 42:9 timeframe [1] 68:10 times [4] 19:24; 24:8; 25:18; 34:14 timing [1] 120:24 title [29] 23:6, 7, 10; 28:21; 40:21; 41:11; 43:11, 24; 45:12, 15, 19, 21; 58:21; 61:23; 70:10; 71:2; 80:11; 83:8; 85:6; 97:7, 10, 15, 19, 21; 100:10, 18; 122:7; 127:6, 10today's [3] 105:23; 106:2, 10 tom [10] 15:25; 22:17, 19; 23:2, 3; 60:23; 61:9, 20; 66:9; 69:16top [4] 44:17; 71:15; 91:6; 103:12 topic [19] 10:17; 21:23; 22:16; 39:14; 48:15; 57:8; 58:13; 59:11; 61:13; 68:11, 14; 70:14; 72:11; 75:24; 80:2; 86:7; 87:21; 107:13; 121:6topics [5] 17:10; 21:25; 23:20; 25:6; 102:11towards [1] 83:14 towers [1] 114:8 track [1] 32:25 trade [1] 26:15 traffic [1] 123:11 training [6] 9:3, 6, 7, 8, 10, 14

transcript [3] 127:16; 128:8, 10 transfer [3] 30:25; 31:3, 4 transpired [1] 61:21 trapped [1] 29:24 treasurer [6] 13:14; 15:9, 21; 16:9; 51:21; 52:6treasurer's [1] 51:15 true [14] 32:23; 33:3; 49:21; 68:16; 72:15; 83:19; 84:19; 97:20; 109:15, 19; 123:18; 128:11, 13; 129:13trustee [25] 13:12; 15:23, 24, 25; 16:2; 18:21; 19:8, 10, 11; 20:3, 7; 38:11; 52:11; 81:5, 13; 108:18; 109:17, 21; 110:6, 9, 10, 12; 111:3trustees [9] 13:10; 15:8, 22; 16:12; 19:9; 51:22; 53:14; 110:3; 124:23truth [1] 43:15 truthful [3] 6:12, 19; 82:14 tsn [1] 1:9 tv [1] 116:4 twelve-hour [1] 31:24 twice [1] 18:10 types [1] 33:6 typical [2] 50:9; 93:3

* * U * *ufa [98] 10:3, 23; 11:13; 12:4; 14:14, 25; 15:15; 17:3, 24; 22:9, 16, 22; 24:12, 18, 23; 38:7; 39:16; 43:23, 25; 45:21; 46:24; 47:2, 13;49:14, 16; 51:17; 52:10; 54:16; 58:5, 22; 59:20, 22, 25; 61:16, 21, 24; 62:24; 64:6, 8, 15, 21; 65:7, 10; 68:15; 70:10; 72:14, 22; 73:10; 74:7; 76:22; 78:17, 18, 22; 80:10, 12; 81:2, 6, 8; 83:2, 4, 9, 17, 21; 84:20; 85:2, 5, 18; 86:13, 16, 24;

87:4, 9; 88:8, 22; 89:13, 22; 90:15; 91:18; 92:2, 7, 17; 94:18, 19; 96:3; 97:6; 100:16, 17, 19; 102:4, 9, 22; 104:3; 105:4, 11; 116:10; 121:9 ufa's [4] 24:15; 66:14; 67:13, 19 ufanyc.org [1] 71:24 ufoa [6] 26:3; 50:15, 25; 74:7; 126:25ultimately [1] 67:9 unanimous [1] 55:25 unclear [1] 120:24 underneath [2] 71:16; 103:13 understand [5] 5:17; 6:10, 12, 14; 126:6 understanding [2] 114:7, 19 understood [1] 5:21 undertaking [1] 27:25 unformed [1] 91:9 uniformed [21] 4:22; 7:18; 9:16; 13:7; 20:14; 25:5; 39:17; 40:10, 17, 24; 41:11; 50:12; 73:2; 76:3; 77:12, 16; 97:6; 100:9; 127:2, 8union [33] 9:19; 13:4, 8, 9, 18; 18:24; 20:5, 8, 22, 25; 21:9, 10; 54:25; 55:9; 84:13, 14; 95:22; 96:21; 97:9, 23; 99:25; 101:16; 104:2;109:7, 12, 18; 110:19; 115:10; 116:2, 24; 117:2; 126:11, 18union's [1] 125:22 unions [1] 50:9 unit [1] 17:12 unnamed [1] 99:14 unnecessarily [1] 107:18 unquote [2] 43:24; 45:12 up-to-date [1] 61:25 update [3]

From substantial to update Ellen Grauer Court Reporting(212) 750-6434

www.ellengrauer.com


32:15; 33:11; 70:13 updating [1] 70:6

* * V * *van [2] 90:24; 91:12 vehicles [1] 123:7 vendetta [3] 84:13; 85:9; 103:25 verify [1] 32:21 verifying [1] 56:22 versus [3] 27:14; 90:25 vice [4] 13:13; 15:8, 19; 16:8 victims [2] 36:5, 10 viewed [1] 30:23 virtually [2] 22:5; 55:25 visit [2] 26:21; 119:3 voicemails [1] 42:22 vote [16] 17:10, 18; 41:10, 14; 42:8, 10, 11, 12; 55:17, 24; 57:22; 58:12, 14, 16, 17, 19voted [4] 55:22; 58:19; 85:7; 117:8 votes [4] 17:9, 15; 42:9; 53:25 voting [1] 16:24

* * W * *wagner [2] 90:24; 91:12 wait [1] 5:15 walk [1] 115:14 wall [1] 2:5 wallet [1] 36:11 wanted [12] 30:24; 45:20; 53:12, 19; 58:11; 73:18, 19; 83:7; 86:3; 105:4; 121:7, 25watched [1] 10:21 watches [1] 36:12 ways [1]

32:20 we'll [1] 6:8 we're [6] 5:15; 6:24; 10:17; 50:20; 125:2; 127:14we've [2] 4:12; 44:18 website [2] 90:11; 91:8 week [5] 22:6; 27:17; 28:9; 31:21; 108:24weekly [1] 10:16 weeks [6] 28:15; 31:19; 32:2; 33:4; 34:12; 122:13weighed [1] 41:8 weiss [3] 1:6; 93:22, 23 weren't [4] 33:25; 37:10; 88:11; 122:6 westhampton [1] 4:18 whenever [1] 68:19 whereof [1] 129:19 wherever [1] 32:12 who's [2] 123:13; 124:25 widows [12] 78:18; 88:19; 89:2, 22; 90:15, 17; 91:9, 18; 92:2, 7, 9, 18win [1] 53:20 window [1] 123:7 withdrawn [1] 117:7 withdrew [1] 55:20 witness [9] 3:2; 4:2; 59:16; 117:20; 127:18; 129:10, 14, 19; 130:5won't [1] 116:8 word [1] 97:8 work [11] 5:11; 26:5, 25; 32:6; 34:12; 47:23; 55:5; 82:12, 24; 104:15, 17worked [5] 20:25; 21:2; 23:11; 52:10; 96:23

workers [4] 10:5; 30:10, 11; 36:15 working [23] 19:3, 4; 23:13; 25:8, 23; 26:7; 27:10, 11; 28:6, 8, 13, 18, 24; 30:9, 17; 31:16; 32:8, 12; 37:16; 38:21; 52:13; 96:15; 123:13works [3] 20:16; 55:3; 107:6 workshop [2] 61:5; 69:17 world [1] 26:15 wouldn't [3] 65:13; 76:25; 92:10 writing [3] 40:9; 46:20; 55:9 written [3] 43:4; 54:18; 82:5 wrote [2] 50:6; 107:12

* * Y * *yeah [8] 19:10; 31:4; 36:19; 49:12; 59:12; 68:25; 74:13; 112:4year [10] 8:15; 13:25; 14:9, 13; 39:6; 41:19; 62:6, 8; 68:18; 78:24years [11] 9:10, 11; 21:4; 23:11; 24:16; 47:2; 84:22; 104:2; 108:12; 115:24, 25yesterday [9] 10:24; 69:16; 72:20; 73:7; 85:14; 87:3; 107:8, 13, 14york [52] 1:1, 2, 11, 18, 24; 2:6, 13; 4:11, 18, 21; 8:12, 21; 9:21; 11:15, 20; 13:5, 7; 33:24; 64:25; 65:3, 5, 6; 72:21, 22; 82:8; 89:3; 93:18; 101:22; 102:10; 104:5, 8, 12, 16, 18; 107:6, 14; 108:5, 8; 123:5, 10; 124:2, 6; 125:24; 126:19; 128:23; 129:9; 130:3you'd [1] 115:14 you'll [1] 44:21 you've [5] 42:16; 59:18; 63:14; 98:24; 103:16yourself [2] 77:14, 15 yup [2] 63:10; 98:19

* * Z * *zero [69] 26:11, 14, 18, 19, 22; 27:18; 28:8; 29:4, 8, 15; 30:7, 8, 18; 31:5, 8, 17; 32:7; 34:9; 35:14, 20, 23; 36:16, 22, 23; 37:2, 8, 16, 18; 38:25; 44:3, 8; 49:19; 59:20, 23; 62:24; 64:13; 66:6, 24; 68:16; 69:17; 71:17; 73:3; 74:6; 81:2; 83:6, 17; 95:23; 96:4, 15, 16; 99:16, 22; 103:18; 105:6, 11; 111:8, 13, 18, 20, 22, 24; 112:7; 113:7, 23; 114:22; 118:12, 25; 119:21


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Stephen Cassidy Deposition FDNY / UFA, NY POST Defamation Lawsuit

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