Q: Well, let me ask you this. Do you recall saying, "I believe that APS is guilty of fraud in submitting these blatantly false reports"? A: Yes, I certainly said that. Q: All right. What did you mean by the word "fraud"? A: I mean I felt that they had either knowingly or in reckless disregard submitted false reports. Q: Why did you-- A: In reckless disregard for their accuracy. Q: Why did you believe that they had knowingly submitted false reports? MR. NAKELL:Objection. I don't think he testified that they had knowingly submitted them. Q: Well, why did you believe that they had knowingly or in reckless disregard? A: I believe that looking at--when I first looked at them I found gross errors, misaccounting of hundreds of animals, and I told John Sauls about this and asked--told him I thought he ought to look into it. And I believe I asked the Orange County Commissioners to look into that, and then I never heard any more. And then sometime later--I'm not sure--it was surely--maybe it might have been a couple of months later, I was informed by John Sauls that a new set of records had been turned in I believe for January through August. Maybe January through September. And I went over and looked at those, and the first thing I noticed was that the counts of animals in the shelter at the beginning--or the end of each month had been changed. There is no way you can go back after the fact and recount the animals that had been there months before. I think--I'm not sure whether it's here or not. I referred to the fact--oh, let's see. Is it in here? Oh, yes. "I've given"--"here given to you the original and corrected September reports. The number of animals in these two versions differ by 85. Both figures are reportedly based on physical account of animals. I can only suppose that Laura Walters obtained the assistance of the Parapsychology Institute in performing this new count that she has done now of actual animals." Now, is APS lying now? Was APS lying a month ago? Does APS habitually lie about their statistics? I have heard Laura Walters glibly tell the APS board there were only four adopted animals returned to APS in September, and so forth. Yes. There is no way you can go back and recount the animals that were in the shelter at each month. In the reports it says it was based on an actual count of animals. I believe this is transparent fraud. Q: Let me ask you about that. A: Yes. Q: In the first set of records-- A: Uh-huh (affirmative). Q: --do you have any information or have you seen any indication that those records, the first set, were intentionally incorrect? A: I have no way of knowing whether they were intentionally incorrect. Q: And you don't have any information that would lead you to believe those records were intentionally incorrect? A: No, I do not. I think-- Q: Your-- MR. NAKELL:Let him finish his answer. Q: Okay. Go ahead. A: I think that in that case it was mere incompetence. Q: And when--after you complained to John Sauls and an effort was made to correct the records, is it fair to say that your complaint is that there's no way that effort could be properly carried out? A: I don't accept your supposition. Q: Well, tell me what is your complaint about the second set of records? A: Well, would you repeat what you said? Q: Well, disregard that question and answer this one, please. A: Okay. Q: What is your problem with the second set of records? A: They're blatantly--they're transparently fraudulent. Q: Do you have any information that would lead you to believe that those records were intentionally incorrect? A: I don't see how it could be otherwise. Q: Do you have any information that the original reports were submitted with any intent to deceive the county? A: No. Q: Have you spoken to anyone at the county or do you have any information from anyone that they were in fact deceived by the numbers in those records? A: Of course they were deceived. The numbers are wrong. They were deceived. Q: Have you spoken to anyone at the county who said they paid any attention to the numbers in those records? A: No. Q: How were they deceived? A: They were given false information. They are required to report to the county about the disposition of animals, and they were given false information. Therefore, they were deceived. Q: But you haven't spoken to anyone at the county to see whether or not they ever read those reports; is that correct? A: Well, certainly John Sauls should have read those reports. Q: That's not my question. Please answer-- A: And whether or not-- Q: --my question. A: --he did, I do not know. But certainly it was his job and he was responsible to and he should have. Q: At the time you made this statement to the county commissioners-- A: Uh-huh (affirmative). Q: --were you aware or had you been told by anyone at the county that they had read those reports? A: No. Q: At the time you made this statement to the county commissioners, did you have any information showing that APS had gained anything by the errors in these reports? A: I would certainly believe they'd gained something, since they are soliciting funds from the public based on their adoption records, and this is related to their adoption records. So certainly they have a great deal to gain by portraying a very good adoption record. Q: These reports were not given to the public, were they? A: No. Q: They were given to the county? A: That's right. Q: All right. My question is do you have any information that these reports given to the county that you call fraudulent-- A: Uh-huh (affirmative). Q: --were any gain for APS? A: Yes. Q: What was that? A: I just told you. Q: Well, you just said that they had solicited funds from the public-- A: That's right. Q: --talking about-- A: Based on-- Q: --adoption records. A: Based on their adoption records. And their adoption records are from these. Q: Do you have any information to show that the adoption rates that APS has given to the public--not to the county, but to the public--were false? A: If these data are false, the adoption rates are false. The adoption rates are based on this. Q: Do you know what adoption rate is given to the public? A: Yes. Q: What? A: Forty percent. Q: Do you have any information that could prove that the adoption rate is not 40 percent? A: If the data on which the adoption rates are false, then there is no reason to believe the adoption rate is accurate. So-- Q: Could it be 42 percent? A: It could be anything. Q: So it could be that the adoption rate is even higher-- A: I think-- Q: --than what AP--let me finish my question. A: Uh-huh (affirmative). Q: It could be, so far as you know, that the adoption rate is even higher than what APS has advertised to the public? A: I-- MR. NAKELL:Objection to the form. A: I find that very unlikely. Q: Why? A: Because I've looked at more recent records which show the adoption rates are only 35 percent. Q: And where did those records come from? A: Laura Walters. Q: Are those records accurate? A: I don't know. Laura Walters has removed the information that would be necessary to check--that I used to check these other ones. Q: Do you have any information that Orange County was damaged in any way by the errors in the original records that you found at John Sauls's office? A: What do you mean, damaged? Q: Damaged. Did Orange County lose anything? A: They might lose credibility. Q: Now, isn't it true that at the request of Judith Reitman, you delivered the statement of Ann Clark to the clerk of the Orange County Board of Commissioners? A: Yes, it is. Q: And let me ask you why, in this statement, Deposition Exhibit 1, you said that you did not--that you didn't put it in the record? A: Because I didn't. I didn't put it in the record. Q: You delivered it to the clerk of the-- A: That's right. Q: --Orange County Commissioners? A: That's not putting it in the record. Judith Reitman put it in the record. Q: You were aware that once it gets to the clerk of the Orange County Board of Commissioners, that it is public record; is that correct? A: Certainly. Q: And you physically delivered it there? A: Certainly. Q: And you did it at the request of Judith Reitman? A: Yes. Q: So that's why you're saying she put in the record? A: That's right. Q: Have you delivered other things at the request of Ms. Reitman to the county commissioners? A: I may have. I'm not sure. Q: And has she delivered information from you to the Orange County Commissioners? A: I don't believe she ever has. Q: And you hand-delivered that to the clerk in Hillsborough before you pursued any independent verification of it; isn't that true? A: Yes. Q: When did you first meet Judith Reitman? A: What do you mean by "meet"? Q: Meet. Do you recall when you first met Judith Reitman? A: Saw her? I first saw her in October. Q: When were you first introduced to her? A: Probably--I don't think I ever was introduced to her, as a matter of fact. I think later in the month I called her. Q: Tell us about that conversation. A: I had heard that she had some monthly reports that APS had submitted, and, based on my looking at something that had been in the commissioners' packet, I think I had some skepticism about some statistics. And I always have an interest in statistics and the misuse of statistics. And so when somebody told me that Judith Reitman had monthly reports, I was interested in pursuing that, and so I believe I asked some people who was this woman. Maybe I remembered her saying that--I wasn't really paying much attention to what she said. But in any event, I found out who she was, and I called her and asked her if she had some statistical reports that APS had submitted to the county. CLICK ON 'BACK' TO RETURN