In The Matter Of: Caffrey vs. Gladwin Community Schools, et al.

KELLY GOWER May 29, 2013

Mid-Michigan Reporting LLC 1606 W Carpenter St Midland MI 48640 (989)835-9171

Min-U-Script with Word Index

KELLY GOWER - May 29, 2013

1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Reported by: 24 25
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STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF GLADWIN

PHILIP CAFFREY, Plaintiff/Counter-Defendant, vs. GLADWIN COMMUNITY SCHOOLS, GLADWIN COMMUNITY SCHOOLS BOARD OF EDUCATION, SALLY HIGHTOWER, KELLY GOWER, GREG ALWARD, TREVOR GRAVELLE, BRAD WITHROW, LISA SCHWAGER, LINDA WINARSKI, RICK SEEBECK, JULIE A. SHEARER, jointly and severally, Defendants/Counter-Plaintiffs. ______________________________________/ File No. 12-6665-CZ

DEPOSITION OF:

KELLY GOWER

May 29, 2013, at 1:20 p.m. 401 West Cedar Avenue, Gladwin, Michigan

APPEARANCES: For Plaintiff/ Counter-Defendant: For Defendants/ Counter-Plaintiffs: ALSO PRESENT: CLINE CLOSE DYER BY: KURT N. HANSEN (P14622) O'NEILL WALLACE & DOYLE BY: DAVID A. WALLACE (P24149) PHILIP CAFFREY DIANE KRAYNAK, RPR, CRR, CM, SCC Certified Shorthand Reporter 2122 (989)835-9171 Fax: (989)835-6064

KELLY GOWER - May 29, 2013

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----------------------------------------------------------------EXAMINATION INDEX ----------------------------------------------------------------PAGE Examination By Mr. Hansen 3

----------------------------------------------------------------EXHIBIT INDEX -----------------------------------------------------------------

(No exhibits marked.)

KELLY GOWER, having been first duly sworn, testified on her oath as follows:

KELLY GOWER - May 29, 2013

3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q BY MR. HANSEN: Q A Q A Q A Q A Q A Q A Q Would you state your name for the record, please. Kelly Gower. And your address? 1425 North Spring Street, Apartment 7-B, like baby. And how old are you? 47. Okay. You're a member of the School Board? EXAMINATION

Yes, sir. Gladwin School Board. Yes. And how long have you been a member? Since '07. Okay. 2007. I'm in my second term.

You're familiar with the lawsuit that we're here for

today, is that correct? Yes, sir. This case was filed back in May of this year. find out about the lawsuit? Paperwork was handed to me at a meeting for the suit. This occurred back in May, do you believe? I believe so. And you believe that this was at a meeting? Yes, sir. Would that have been included in your packet at that time?
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How did you

KELLY GOWER - May 29, 2013

4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A A Q A Q I don't get packets. Okay. filed? It was an attorney or somebody official. Okay. This had to do with certain FOIA requests by Mr. Do you recall who handed you the lawsuit that was

Caffrey concerning some phone records, you recall that? Okay. I never read the material but...

Did you have anybody read it to you? No. MR. WALLACE: I'm going to object to form and

foundation because the lawsuit we're here about today has nothing to do with phone records, so I'm -- I think you're intentionally trying to confuse the issues. MR. HANSEN: Well, it certainly has to do with how

counsel was retained and how the paperwork was filed in defense of these actions. Do you recall how Mr. Wallace was retained or hired to defend the School District? Yes, sir. Okay. Can you tell us about that.

He's with SET SEG, and SET SEG represents School Board members. He came and spoke to us at a meeting.

Do you recall what meeting that was? I don't recall a date or a time, no. But it's your memory that Mr. Wallace actually came to a
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KELLY GOWER - May 29, 2013

5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q Q A Q A Q A Q Q A Q A A meeting and spoke about the case? I don't know that he spoke in detail about the case at a public meeting, no. But he came and talked to you at some point in time? Yes. I'm trying to figure out, was this at a meeting or was it -Well, it would have been that we would have closed the meeting and done it privately, you know, in accordance with legal issues. Okay. in May. I don't know if it was in May or April or March. remember when it was. Okay. But it wasn't in the fall of the year. I don't And it's your memory that that's what happened back

Last year? Yes. I don't recall that, either. Okay. Do you know how it came about that the insurance

company SET SEG was notified? No. The Board never discussed that at all? I don't recall. Did the Board ever deliberate or discuss whether or not the case should be turned over to the insurance company? I don't recall.
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KELLY GOWER - May 29, 2013

6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q A Q A Q A Q A Q A Q Q No decision was ever made by the Board to do that, is that a fair statement? I don't recall ever making a vote like that. Did you discuss the lawsuit with any other members of the Board? Of the Board? Yes. No. Did you ever discuss the lawsuit with Mr. Seebeck or Julie Shearer? The lawsuit? I --

The lawsuit I'm referring to is the FOIA request over phone bills and records. MR. WALLACE: and foundation. We can discuss whatever we want. Well, I'm asking if you did do that. I don't recall. You could've but you don't -- you don't have a specific memory? I'm fully aware of what's going on here, what the Caffreys are trying to do, and, you know, I voted my conscience, if that's what you're worried about. Well, what are the Caffreys trying to do? They're after Rick Seebeck for whatever reason, and now
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Again I'm going to object to form

KELLY GOWER - May 29, 2013

7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A A Q A Q Q A Q A Q they're dragging us into it. Well, Mr. Seebeck works for the Board, right? Right. So if we're making allegations of how he's performing his duties, then it would involve you, correct? Yes. We are totally happy with Mr. Seebeck's performance as

superintendent. Okay. Do you think that it's important that Mr. Seebeck

complies with the law? Of course. Do you know what the Freedom of Information Act is? Yes, sir. Do you think it's important that items get turned over that are supposed to be turned over under the Freedom of Information Act? Assuming that the Caffreys have a right to that information, it's been turned over. That's what you've been told. MR. WALLACE: I'm going to object to form and You're mischaracterizing

foundation, what she's been told. her testimony. Is that what you've been told? What?

That everything has been turned over? Yes.

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KELLY GOWER - May 29, 2013

8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A A Q A Q Q Q A Q A And who told you that? Mr. Seebeck. Did anybody do anything to verify that? What do we need to do to verify it? That's his job to

comply with that kind of stuff, and he does. Okay. Are you aware of an incident where Sharman Caffrey

made a Freedom of Information Act request and he himself denied it, saying that she -It wasn't any of her --- wasn't entitled -Right. -- that she wasn't entitled to it because she was a party to a civil lawsuit with the School Board? I don't recall that. I recall her coming to the Board on

numerous occasions requesting the same information that had already been determined was none of her right. fall under FOIA for her to have it. It's not her business to know all the legal -- you know, legal records of people that we deal with. right to that information. What are you referring to? We tried to hire -- or we looked into -- we entertained a request for someone to volunteer at the schools that had a record. We -- we checked into it, looked over it. We, you Criminal She has no It didn't

know, did the -- we do a -- what do you call that?

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KELLY GOWER - May 29, 2013

9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q Q A Q A Q background check. And she has no right to that information. She isn't

anybody that needs to know the private criminal background of anybody. Was a criminal background check actually done by somebody? Of course. Who did it? I don't know. Were you at the most recent meeting where Mr. Seebeck was asked about that and he said that -- he was asked whether or not he had done the background check and he said that he could answer that but he wasn't going to because every time he answered something, it came back to bite him? Yeah. Okay. So he wouldn't answer the question as to whether the We always do that when we look at volunteers.

background check was even conducted, right? MR. WALLACE: I'm going to object. This has no

relevance to this case whatsoever. THE WITNESS: MR. HANSEN: MR. WALLACE: Yeah. Well, it may lead to it. Well --

It doesn't -- every time she comes, she goes into this major long -- she started last October. She asked for the May, she asked for

information, you know, blah blah blah. the -- and she still hasn't received it.

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KELLY GOWER - May 29, 2013

10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A Q A Q A Q Well, there was -- you know, we checked with our attorney; she's not entitled to it. Rick just said he's not going to -- you know, we're not going to go that far into answering questions when she can turn around and say, he didn't give it to me. Well, do you believe that she's entitled to make FOIA requests? Within reason, but just to catch one of us in something so that you can nail Rick to the wall doesn't -- isn't nice. And, no, you don't -- you don't get FOIA requests for that purpose. Well, you have sued Mr. Caffrey here, correct? Yeah. I think, as a School Board, we have.

Well, you did it individually, too, didn't you? No. Well, that's what you voted for, wasn't it, on the 24th? MR. WALLACE: I'm going to object to the extent

that you're invading the attorney/client privilege and you're asking this lady legal questions that are inappropriate. Court. Well, the counterclaim has been filed in this and you're one of the counter-complaint plaintiffs, aren't you? Well, he was nickel-and -- I won't say nickel-and-diming but he was nitpicking lawsuits at us for no purpose other than
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That's a decision that can be made by a

KELLY GOWER - May 29, 2013

11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A answer. I'm sorry, go ahead. We just decided, let's shut him off. You know, we don't Q to set Mr. Seebeck off. Who told you that? MR. WALLACE: Wait a minute. Let her finish her And --

need all these penny-ante little dipsticky lawsuits coming at us all the time. getting an education. How many lawsuits has he filed? Numerous. Numerous lawsuits. Yes -- well, with the FOI stuff and everything. lawsuits, but still... So he's filed two lawsuits, right? Okay, but countless FOIs. Okay. Do citizens have a right to do that? They're not We're trying to make sure kids are

Within reason. Well, who determines whether or not it's within reason? Whoever is being requested it, you know, whoever he's requesting them of. So you can refuse it because you feel it's not reasonable? After a certain point, when, you know, he's nitpicking every single detail just to set Rick and the Board off, yeah. Well, isn't that what the judge determined, too?
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KELLY GOWER - May 29, 2013

12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q A Q A Q They're frivolous harassments. Who told you that it was a frivolous harassment? Nobody did. That's just what you concluded? Right. Did you ever discuss with any Board members a protective order? Protective order against whom? Mr. Caffrey. I haven't discussed it with anybody. So you didn't discuss that with Mr. Seebeck. No, sir -- well, I would've suggested it but really haven't discussed anything. Okay. No. And when was the last time that you remember that you talked to Mr. Caffrey about anything? I try not to. Well, when was the last time that you ever did? He was sending me stupid-ass mailings for auto insurance. I called his office once and told him that that was totally stupid. So you got some flyers from him about doing auto insurance with him? Yeah. I did constantly until we got through that one
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Never talked to anybody about it.

KELLY GOWER - May 29, 2013

13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A Q Q A Q A decision on that -- when we filed against him. any now and I'm happy. Have you ever had a conversation with him personally? No -- well, he tried to call me one time on the telephone. I told him I didn't want any insurance and I didn't need to talk to him about anything else. So he called you about insurance? No; he called me to rag on me about Rick, did I know this and did I know that. And how long ago was that? Oh, it's been a couple of months. Months? Yeah. Before Christmas. I don't get

How about before that? No, I haven't discussed anything with him. And your memory is that you talked to him and you told him you didn't want to talk to him, and you've never heard from him since. Right. You claim that he's made some false statements about you, some slanderous and some libelous statements. Are you aware of any writings that he's done that were false that were made about you? Who said he said anything about me? Your lawsuit says that.
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KELLY GOWER - May 29, 2013

14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q Q A Q A Just the crap that I've gotten in the mail from him. And that's all insurance stuff. Yeah. If that isn't the dumbest thing. You know, I don't

need to be reminded that I don't drive a car because I'm a blind kid. That's the stupidest thing in the world, and he

did it just to irritate me. Were there any statements that he's made to third parties that have been untrue about you? I don't know what he's said to anybody. So you're not aware of who he would have said anything to or anything else like that. No. As you're sitting here now, you're not aware of any writings or any oral statements that he's made about you that were false, is that correct? I'm not aware of any, no. You say in your lawsuit against him that he abused the process by his conduct against you. What is all that about? MR. WALLACE: foundation. I'm going to object, form and

It's a legal term of art and it's a legal

decision that will be made by the Court. Do you know what that's about? I don't know anything about it. Okay. You've claimed that he has intentionally inflicted
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KELLY GOWER - May 29, 2013

15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q A A Q A Q A A Q A Q A Q mental distress upon you. Getting all those mailings about the insurance is stressful. That was all? To my knowledge. You've alleged that he was guilty of willful and wanton misconduct towards you. I have no idea. Now, there was a meeting on Christmas Eve, December 24th, and you were at that meeting, right? Yes, sir. How did you learn of the meeting? I'm sure Mr. Seebeck or somebody from his office called me. And what did they tell you the purpose of the meeting was? I don't remember all of the meetings that we've had and the issues that we've discussed at them. I know I was peeved What's that about?

because it was Christmas Eve, but there were timeline issues and so I attended. Who told you that there was timeline issues? I don't know. Maybe it came out in the meeting. Why else

would you have a Christmas Eve meeting if there wasn't a timeline issue? Well, that's a very good question. Did you discuss anything about the meeting before going there? I told you, I don't recall even what the meeting was about.
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KELLY GOWER - May 29, 2013

16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A Q A Q Q Well, this is unusual that it would be on a Christmas Eve, right? (No response.) I can understand why you wouldn't remember every meeting, but one on Christmas Eve, you don't remember what that was about? No. And you don't remember what happened at the meeting? No. You don't remember that you authorized Mr. Wallace to pursue counterclaims on your behalf? MR. WALLACE: Don't answer that.

To the extent that it was a closed session, under -MR. HANSEN: I'm not asking about that. I'm

asking about the resolution that was filed. MR. WALLACE: themselves. Well, are you aware of that? I don't recall anything. Who was the person that was talking to Mr. Wallace about these lawsuits? It wasn't me. Do you know who it was? No. Did the Board ever authorize any one person to do all the
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The minutes of the meeting speak for

KELLY GOWER - May 29, 2013

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talking? A Q Not that I recall. Did Mr. Seebeck -- well, were you ever present when Mr. Caffrey allegedly made statements about Mr. Seebeck to any Board members? A I don't recall if I was -- if I attended anything like that at all. Q Okay. So you're not aware of any statements that he made

about Rick to any Board members. A I don't have a clear recollection. MR. HANSEN: That's all I have.

(Deposition concluded at or about 1:45 p.m.)

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STATE OF MICHIGAN COUNTY OF MIDLAND I, Diane Kraynak, Notary Public in and for Midland County, State of Michigan, acting in Gladwin County, State of Michigan, do hereby certify that I stenographically recorded the deposition of KELLY GOWER, the deponent in the foregoing deposition; that prior to the taking of said deposition the said deponent was duly sworn to tell the truth, the whole truth, and nothing but the truth, and that the foregoing deposition is a true and correct transcript of the testimony of said deponent, to the best of my ability. I further certify that I am not a relative, employee, attorney or counsel of any of the parties, a relative or employee of such attorney or counsel, or am financially interested in the transaction. I further certify that no request was made that the foregoing deposition be submitted to the said deponent for examination and correction by her or that she sign the same.

_________________________________________ Diane Kraynak, CSR-2122 Certified Shorthand Reporter Registered Professional Reporter Notary Public, Midland County, Michigan My Commission Expires: 11-1-13

Caffrey vs. Gladwin Community Schools, et al.

KELLY GOWER May 29, 2013 claimed (1) 14:25 clear (1) 17:10 closed (2) 5:7;16:13 coming (2) 8:14;11:7 company (2) 5:19,24 complies (1) 7:9 comply (1) 8:5 concerning (1) 4:6 concluded (2) 12:4;17:12 conduct (1) 14:18 conducted (1) 9:16 confuse (1) 4:13 conscience (1) 6:22 constantly (1) 12:25 conversation (1) 13:3 counsel (1) 4:15 counterclaim (1) 10:22 counterclaims (1) 16:11 counter-complaint (1) 10:23 countless (1) 11:16 couple (1) 13:11 course (2) 7:10;9:6 Court (2) 10:21;14:22 crap (1) 14:1 Criminal (3) 8:25;9:3,5 14:22 defend (1) 4:18 defense (1) 4:16 deliberate (1) 5:23 denied (1) 8:8 Deposition (1) 17:12 detail (2) 5:2;11:24 determined (2) 8:16;11:25 determines (1) 11:19 dipsticky (1) 11:7 discuss (7) 5:23;6:4,9,16;12:6, 11;15:23 discussed (5) 5:21;12:10,13; 13:15;15:15 distress (1) 15:1 District (1) 4:18 done (4) 5:8;9:5,11;13:22 dragging (1) 7:1 drive (1) 14:4 dumbest (1) 14:3 duties (1) 7:5 fair (1) 6:2 fall (2) 5:14;8:17 false (3) 13:20,23;14:15 familiar (1) 3:15 far (1) 10:4 feel (1) 11:22 figure (1) 5:6 filed (8) 3:18;4:3,15;10:22; 11:10,15;13:1;16:15 find (1) 3:19 finish (1) 11:3 flyers (1) 12:23 FOI (1) 11:13 FOIA (5) 4:5;6:12;8:17;10:6, 10 FOIs (1) 11:16 form (4) 4:10;6:14;7:19; 14:20 foundation (4) 4:11;6:15;7:20; 14:21 Freedom (3) 7:11,14;8:7 frivolous (2) 12:1,2 fully (1) 6:21

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abused (1) 14:17 accordance (1) 5:8 Act (3) 7:11,15;8:7 actions (1) 4:16 actually (2) 4:25;9:5 address (1) 3:5 Again (1) 6:14 against (4) 12:8;13:1;14:17,18 ago (1) 13:10 ahead (1) 11:5 allegations (1) 7:4 alleged (1) 15:5 allegedly (1) 17:4 always (1) 9:6 answered (1) 9:13 Apartment (1) 3:6 April (1) 5:12 around (1) 10:5 art (1) 14:21 Assuming (1) 7:16 attended (2) 15:17;17:6 attorney (2) 4:4;10:2 attorney/client (1) 10:18 authorize (1) 16:25 authorized (1) 16:10 auto (2) 12:20,23 aware (8) 6:21;8:6;13:22; 14:10,13,16;16:18; 17:8

3:6 back (4) 3:18,21;5:10;9:13 background (5) 9:1,3,5,11,16 behalf (1) 16:11 bills (1) 6:13 bite (1) 9:13 blah (3) 9:24,24,24 blind (1) 14:5 Board (17) 3:9,11;4:21;5:21, 23;6:1,5,6;7:2;8:13, 14;10:13;11:24;12:6; 16:25;17:5,9 business (1) 8:18

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Caffrey (6) 4:6;8:6;10:12;12:9, 17;17:4 Caffreys (3) 6:21,24;7:16 call (2) 8:25;13:4 called (4) 12:21;13:7,8;15:12 came (6) 4:22,25;5:4,18; 9:13;15:19 Can (7) 4:20;6:16;10:4,9, 20;11:22;16:4 car (1) 14:4 case (5) 3:18;5:1,2,24;9:18 catch (1) 10:8 certain (2) 4:5;11:23 certainly (1) 4:14 check (4) 9:1,5,11,16 checked (2) 8:24;10:1 Christmas (6) 13:13;15:8,16,20; 16:1,5 citizens (1) 11:17 civil (1) 8:13 claim (1) 13:20

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education (1) 11:9 either (1) 5:17 else (3) 13:6;14:11;15:19 entertained (1) 8:22 entitled (4) 8:10,12;10:2,6 Eve (5) 15:8,16,20;16:1,5 even (2) 9:16;15:25 EXAMINATION (1) 3:1 extent (2) 10:17;16:13

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Gladwin (1) 3:11 goes (1) 9:22 good (1) 15:22 Gower (1) 3:4 guilty (1) 15:5

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date (1) 4:24 deal (1) 8:19 December (1) 15:8 decided (1) 11:6 decision (4) 6:1;10:20;13:1;

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handed (2) 3:20;4:2 HANSEN (5) 3:2;4:14;9:20; 16:14;17:11 (1) abused - HANSEN

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baby (1) Min-U-Script

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Caffrey vs. Gladwin Community Schools, et al. happened (2) 5:10;16:8 happy (2) 7:6;13:2 harassment (1) 12:2 harassments (1) 12:1 heard (1) 13:17 himself (1) 8:7 hire (1) 8:22 hired (1) 4:17 11:25 Julie (1) 6:9 5:12 material (1) 4:7 May (6) 3:18,21;5:11,12; 9:20,24 Maybe (1) 15:19 meeting (20) 3:20,23;4:22,23; 5:1,3,6,8;9:9;15:8,9, 11,13,19,20,23,25; 16:4,8,16 meetings (1) 15:14 member (2) 3:9,13 members (5) 4:22;6:4;12:6;17:5, 9 memory (4) 4:25;5:10;6:20; 13:16 mental (1) 15:1 minute (1) 11:3 minutes (1) 16:16 mischaracterizing (1) 7:20 misconduct (1) 15:6 months (2) 13:11,12 most (1) 9:9 5:19 numerous (3) 8:15;11:11,12

KELLY GOWER May 29, 2013 13:3 phone (3) 4:6,12;6:12 plaintiffs (1) 10:23 please (1) 3:3 pm (1) 17:12 point (2) 5:4;11:23 present (1) 17:3 private (1) 9:3 privately (1) 5:8 privilege (1) 10:18 process (1) 14:18 protective (2) 12:6,8 public (1) 5:3 purpose (3) 10:11,25;15:13 pursue (1) 16:10

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Kelly (1) 3:4 kid (1) 14:5 kids (1) 11:8 kind (1) 8:5 knowledge (1) 15:4

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object (6) 4:10;6:14;7:19; 9:17;10:17;14:20 occasions (1) 8:15 occurred (1) 3:21 October (1) 9:23 off (3) 11:1,6,24 office (2) 12:21;15:12 official (1) 4:4 old (1) 3:7 once (1) 12:21 one (6) 10:8,22;12:25; 13:4;16:5,25 oral (1) 14:14 order (2) 12:7,8 out (3) 3:19;5:6;15:19 over (7) 5:24;6:12;7:13,14, 17,24;8:24

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idea (1) 15:7 important (2) 7:8,13 inappropriate (1) 10:20 incident (1) 8:6 included (1) 3:25 individually (1) 10:14 inflicted (1) 14:25 Information (8) 7:11,15,16;8:7,15, 20;9:2,24 insurance (8) 5:18,24;12:20,23; 13:5,7;14:2;15:2 intentionally (2) 4:13;14:25 into (5) 7:1;8:22,24;9:22; 10:4 invading (1) 10:18 involve (1) 7:5 irritate (1) 14:6 issue (1) 15:21 issues (5) 4:13;5:9;15:15,16, 18 items (1) 7:13

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lady (1) 10:19 Last (4) 5:15;9:23;12:16,19 law (1) 7:9 lawsuit (11) 3:15,19;4:2,11;6:4, 9,11,12;8:13;13:25; 14:17 lawsuits (7) 10:25;11:7,10,12, 14,15;16:21 lead (1) 9:20 learn (1) 15:11 legal (6) 5:9;8:18,19;10:19; 14:21,21 libelous (1) 13:21 little (1) 11:7 long (3) 3:13;9:23;13:10 look (1) 9:6 looked (2) 8:22,24

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rag (1) 13:8 read (2) 4:7,8 really (1) 12:12 reason (4) 6:25;10:8;11:18,19 reasonable (1) 11:22 recall (16) 4:2,6,17,23,24; 5:17,22,25;6:3,18; 8:14,14;15:25;16:19; 17:2,6 received (1) 9:25 recent (1) 9:9 recollection (1) 17:10 record (2) 3:3;8:24 records (4) 4:6,12;6:13;8:19 referring (2) 6:12;8:21 refuse (1) 11:22 relevance (1) 9:18 (2) happened - relevance

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nail (1) 10:9 name (1) 3:3 need (4) 8:4;11:7;13:5;14:4 needs (1) 9:3 nice (1) 10:9 nickel-and (1) 10:24 nickel-and-diming (1) 10:24 nitpicking (2) 10:25;11:23 Nobody (1) 12:3 none (1) 8:16 North (1) 3:6 notified (1)

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packet (1) 3:25 packets (1) 4:1 Paperwork (2) 3:20;4:15 parties (1) 14:7 party (1) 8:12 peeved (1) 15:15 penny-ante (1) 11:7 people (1) 8:19 performance (1) 7:6 performing (1) 7:4 person (2) 16:20,25 personally (1)

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mail (1) 14:1 mailings (2) 12:20;15:2 major (1) 9:22 making (2) 6:3;7:4 many (1) 11:10 March (1)

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job (1) 8:4 judge (1) Min-U-Script

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Caffrey vs. Gladwin Community Schools, et al. remember (7) 5:13;12:16;15:14; 16:4,5,8,10 reminded (1) 14:4 represents (1) 4:21 request (3) 6:12;8:7,23 requested (1) 11:20 requesting (2) 8:15;11:21 requests (3) 4:5;10:7,10 resolution (1) 16:15 response (1) 16:3 retained (2) 4:15,17 Rick (6) 6:25;10:3,9;11:24; 13:8;17:9 right (14) 7:2,3,16;8:11,16, 20;9:2,16;11:15,17; 12:5;13:19;15:9;16:2 single (1) 11:24 sitting (1) 14:13 slanderous (1) 13:21 somebody (3) 4:4;9:5;15:12 someone (1) 8:23 sorry (1) 11:5 speak (1) 16:16 specific (1) 6:19 spoke (3) 4:22;5:1,2 Spring (1) 3:6 started (1) 9:23 state (1) 3:3 statement (1) 6:2 statements (6) 13:20,21;14:7,14; 17:4,8 still (2) 9:25;11:14 Street (1) 3:6 stressful (1) 15:2 stuff (3) 8:5;11:13;14:2 stupid (1) 12:22 stupid-ass (1) 12:20 stupidest (1) 14:5 sued (1) 10:12 suggested (1) 12:12 suit (1) 3:20 superintendent (1) 7:7 supposed (1) 7:14 sure (2) 11:8;15:12 16:20;17:1 telephone (1) 13:4 term (2) 3:14;14:21 testimony (1) 7:21 third (1) 14:7 timeline (3) 15:16,18,21 today (2) 3:16;4:11 told (11) 7:18,20,22;8:1; 11:2;12:2,21;13:5, 16;15:18,25 totally (2) 7:6;12:22 towards (1) 15:6 tried (2) 8:22;13:4 try (1) 12:18 trying (5) 4:13;5:6;6:22,24; 11:8 turn (1) 10:5 turned (5) 5:24;7:13,14,17,24 two (1) 11:15 wall (1) 10:9 WALLACE (14) 4:10,17,25;6:14; 7:19;9:17,21;10:17; 11:3;14:20;16:10,12, 16,20 wanton (1) 15:5 what's (2) 6:21;15:6 whatsoever (1) 9:18 willful (1) 15:5 Within (3) 10:8;11:18,19 WITNESS (1) 9:19 works (1) 7:2 world (1) 14:5 worried (1) 6:23 writings (2) 13:22;14:13

KELLY GOWER May 29, 2013

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year (3) 3:18;5:14,15

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same (1) 8:15 saying (1) 8:8 School (6) 3:9,11;4:18,21; 8:13;10:13 schools (1) 8:23 second (1) 3:14 Seebeck (11) 6:9,25;7:2,8;8:2; 9:9;11:1;12:11; 15:12;17:3,4 Seebeck's (1) 7:6 SEG (3) 4:21,21;5:19 sending (1) 12:20 session (1) 16:13 SET (5) 4:21,21;5:19;11:1, 24 Sharman (1) 8:6 Shearer (1) 6:10 shut (1) 11:6 Min-U-Script

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07 (1) 3:14

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under (3) 7:14;8:17;16:13 untrue (1) 14:8 unusual (1) 16:1 upon (1) 15:1

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2007 (1) 3:14 24th (2) 10:16;15:8

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47 (1) 3:8

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talk (2) 13:6,17 talked (4) 5:4;12:14,16;13:16 talking (2)

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7-B (1) 3:6

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Wait (1) 11:3

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(3) remember - 7-B