Deposition of Elliot Cramer taken August 8 by APS attorney Ronald Merritt page 104-176. Q Tell me every outrageous lie that you have information about concerning Laura Walters. MR. NAKELL: Object to the form of the question in terms of that introductory statement. A Would you repeat it, please? Q Okay. Will you tell me each and every outrageous lie that you are aware of having been made by Laura Walters? A I will be happy to document that for you, but I can't tell you each and every one right now. But if we-- Q Can you tell us-- A If-- Q Can you tell us any? A I can, if we'll simply look at some of the statements--the public statements that we've made--she's made, and I'll be happy to go over them with you and point out lies. Q Today as we sit here-- A Yes, I can do that. Q --can you tell us any from your own mind? A Well, let me find some things here and-- Q Okay. A --we can talk about them. Q That's fine. A Okay. Let's see. I've got a quotation here in an article that I wrote after the HSUS report. Q No. Well, that's fine. A I've got quotations-- Q Go ahead. A --from-- Q Well, I asked you, though, that you were talking about in February of 2003. The HSUS report didn't exist in-- A Okay. You want earlier-- MR. NAKELL: Just a moment. Just a moment. THE WITNESS: Okay. MR. NAKELL: The question was can you tell me about, as you sit here, any outrageous lie-- MR. MERRITT: That's fine. MR. NAKELL: --that-- MR. MERRITT: That's fine. MR. NAKELL: --Laura Walters has said. MR. MERRITT: I stand corrected. MR. NAKELL: I believe he's entitled to answer that question. Q Go ahead. A Okay. Q Go ahead. A Okay. Chapel Hill Herald, June 28th, referring to the HSUS report, "It's something that is exactly what we wanted. We wanted an independent organization to kind of get us on the right track." Well, to say that this is exactly what we wanted, this devastating critique of everything that was going on at APS, is certainly an outrageous lie. Then Chapel Hill Herald, July 10th. Let's see. News & Observer--excuse me--July 28th she said that "HSUS required a policy that quickly euthanizes animals." That was an outrageous lie. Chapel Hill Herald, July 10th she said, "It's not in stone, and it never was in stone. If we have an animal that's perfectly adoptable and healthy and we have the space, we hold it as long as we can. That's what we've always done." That's the truth, but it contradicts what she said before. Chapel Hill News, July 13th, "They make it very clear that there should be a set number of days these animals can be held." That's an outrageous lie, because HSUS said, "The focus of the Humane Society's recommendation was on finding ways to shorten the amount of time animals spend in the shelter, not necessarily to kill them sooner. We did not recommend that animals be euthanized after a specific period of time." So that's one thing. Let's see. MR. MERRITT: Can I have that marked? I want to have that marked as an Exhibit-- MR. NAKELL: Okay. MR. MERRITT: --to the deposition, since he's referring to it. THE WITNESS: Uh-huh (affirmative). MR. MERRITT: We're going to mark what he just referred to, for the record, as Cramer Deposition Exhibit 4. (Whereupon, Deposition Exhibit No. 4 was marked for identification.) MR. MERRITT: I'll have copies made. MR. NAKELL: Okay. A Okay. Here's a letter, January 14th--well, it would be--it might be better to get the actual letter, but there--I just see a quotation from that, "Cramer had accessed or attempted to access areas clearly marked as off limits to the public." That's a lie. Let me--that's probably someplace else where it's better, but let me find some more things. Q And what is the date on that? Let me just have that marked as well. A Okay. This, February 13th. We may have--if you want to hold off on that, I'll find a better quotation, but-- Q No, I want to-- A Okay. That's fine. Q Whatever you pull out, sir, we're going to put in the record. A Fine. (Whereupon, Deposition Exhibit No. 5 was marked for identification.) (Witness reviews documents.) A Okay. Here we are. March 24th, Daily Tar Heel, "But Walters said Thursday that the veterinarians have never set foot in the Arkansas shelter." Oh, here. She's referring to Craig Smith and M.W. Singer. That was an outrageous lie. Q And what are you referring to now, sir? A This--the article where Laura Walters was quoted as saying the two veterinarians, Smith and Singer--yeah, I may have-- Q May I see it? A Oh, sure. MR. MERRITT: I'll mark this as Cramer Exhibit 6. (Whereupon, Deposition Exhibit No. 6 was marked for identification.) A If I can continue with that? Q Uh-huh (affirmative). A I think I'd like just to see if there's anything else there. Q Let me ask you about that quote since you just mentioned it. A Yes, uh-huh (affirmative). Q Does it mention--that's a partial sentence that was quoted there? A He is quoting Laura Walters. Q Well, the quoted portion that you just read is part of a sentence, is it not? It's not even a complete sentence? A Yes, that's right. Q Does it state when Laura Walters was referring to? A Well, it says "have never set foot in the Arkansas shelter." That's forever. Q And do you know whether she was referring to during the time that she was in charge of it or while they were on the board or after they were taken off the board? You don't have any information about that quote other than what you are reading in the newspaper; is that correct? MR. NAKELL: I object to the-- A Yeah. MR. NAKELL: --question as compound. MR. MERRITT: Okay. Q Do you have any information about the accuracy-- A I'm reading-- Q --of that quote? A No. Q But you deem that to be an outrageous lie? A Yes, I think that's an outrageous lie. Q What if it's a misquote? A If it's a misquote, then it's not an outrageous lie. Q But you don't know one way or the other? You just deem it to be? A Yes, I believe it is as stated, and I believe I'm taking this--just as you've taken things from the newspapers as being true, I take this to be true. And Laura Walters is right here. She can tell us whether she ever said it. Q Most people take what they read in the newspaper as being true, don't they? A No, I don't. Q Then why did you put it--why do you read the paper if you don't think what's in it is true? A I didn't say I don't-- MR. NAKELL: Objection. Objection to the question as a misstatement of his-- Q Well-- A I said I don't believe everything that's in the newspapers is true. I believe a lot of what's in the newspapers is true. Q I didn't ask you about everything. A Yeah. Q But I'll ask it again. A Yeah. Q Do you believe that the information you get from the newspaper is accurate? MR. NAKELL: Objection. It's irrelevant. Q Answer the question and I'll ask-- A I do not believe that all the information I get from the newspapers is accurate, but I believe that most of it is accurate. Q And do you believe and did you believe at the time you wrote the articles that you have written for the newspapers-- A Yes. Q --that people were going to believe what you wrote? A I hoped they would, since I have-- Q And so you intended for the people who read this article, Cramer's Deposition Exhibit 3, to believe that APS was a corrupt organization? A I believe that everything I have said in public about APS is the truth, and I would like others to learn about that. And I think I'm doing a public service by presenting this information. And so when I say that I believe that APS is a corrupt organization, it means indeed that I really do believe that APS is a corrupt organization. And I can tell you right now I believe that APS is a corrupt organization. Q And as a matter of fact, you didn't say, "I believe." What you said was, "They've got a corrupt organization"; isn't that true? A Obviously it is a statement of opinion, and so when I say, "They've got a corrupt organization," it's--I'm obviously stating my opinion. Q And-- A No one would believe otherwise. Q --"We want the members to know what's going on in this corrupt organization"? A Correct. Q Is that a statement of opinion? A It's a statement of what I want the members to know. Q That this is a corrupt organization? A No, that we want the members to know. That's the point of that statement. Q Is there any statement of opinion in the sentence, "We want the members to know what's going on in this corrupt organization"? A Is there any statement of opinion? Q Yeah. A That's a factual statement of what I want--what my purpose was. Q Okay. Go ahead. A Okay. So anyway, he said--he's quoting her as saying that they were not on the list, and certainly that is a lie. Where am I going here? Okay. I presume you just want to deal with Laura Walters, not her employees right now in terms of outrageous lies or-- Q You--we--you asked Laura--you said Laura Walters was an outrageous liar. A Right. Okay. Q And that made APS a corrupt organization. And I asked you to specify any outrageous-- A Okay. Right. Q --lies of which you were aware. A No--I just came across another outrageous lie, but it wasn't Laura Walters. So I won't say that. Q I will ask you again, of which you are aware, without reading in some other newspaper or some other article, outrageous lies of which you are personally aware as we sit here-- A Well, I-- MR. NAKELL: Wait, wait, wait. Hold on just a second. THE WITNESS: Okay. MR. NAKELL: I'm going to clarify that. Are you changing the question now? MR. MERRITT: No, no. I asked him before, "As we sit here today, are you aware of any outrageous lies?" And he said, "Well, I've got to go look, see what somebody else said." And he's not-- MR. NAKELL: Well, now wait. No. MR. MERRITT: --answering the question. MR. NAKELL: Hold on a second. MR. MERRITT: But I'll let him go on-- MR. NAKELL: You asked-- MR. MERRITT: --as long as he wants. But I'm-- MR. NAKELL: You asked-- MR. MERRITT: --going to keep asking him that question until he answers it. MR. NAKELL: I'm just trying to get clarification, because it appears to me that you might have changed it. But you asked him about whether he's aware of outrageous lies? MR. MERRITT: That's right. MR. NAKELL: All right. MR. MERRITT: Of him sitting here today. I used those words. MR. NAKELL: And whether he's aware of them? MR. MERRITT: Uh-huh (affirmative). MR. NAKELL: Okay. If that's the question, I have no objection. Go ahead and answer. A Okay. Let me continue. Q In the interest of saving time-- A Okay. Q In the interest of saving time, I'm going to ask you in a minute whether or not you were aware of any of these outrageous lies at the time you made this statement February 21 of 2003. So you may want to pay attention to that as you're reviewing your-- A Well, you've got the dates of all these things, and so obviously I couldn't be aware of any of the ones that happened before then. But you did ask about outrageous lies. So--and all the outrageous lies I knew about. So let me go through all the ones that I know about because I read all these articles and noted at the time. Okay. Here she says, "We're ready to take"--this is Sunday, June 29th. She is quoted in The Chapel Hill News as saying, "We are ready to take action." She said, "This is exactly what we were hoping to get. We know that we've been dealing with arcane policies for many years." I think that's an outrageous lie. Q Why do you think that's an outrageous lie? A Because I don't believe there were any arcane policies. And it's absurd to say that this is exactly what we wanted when it's an absolutely devastating report that criticizes virtually every aspect of what was going on. It's perfectly clear, I believe, that Laura Walters and Pat Beyle and their crew were expecting HSUS to come through with a glowing report. And I must confess that I was expecting the very same thing, and I said as much. I said that this was a waste of time, and I wrote a letter to HSUS because I thought it was going to be just a whitewash. Q Now let's go back to part of what you said. A Certainly. Q All right. You don't believe there were any arcane policies. All right. Did you not earlier testify that you were not aware of the operations of the APS before Laura Walters took over? MR. NAKELL: Object to the question. That mischaracterizes his testimony. MR. MERRITT: I'm asking him what he's testified to. Q Have you--you tell me what you testified to-- A Uh-huh (affirmative). Q --or you tell me what the truth is now. A Yes. Q Are you aware--did you study or investigate in any way the operations of APS and its management before Laura Walters took over? MR. NAKELL: Object to the question as compound and unclear. The question of whether he was aware is different than the question of whether he investigated it. MR. MERRITT: Okay. Q Either one. A Aware. Q Were you aware or did you investigate? A I didn't investigate, but certainly I'm aware of statements that people have made about things that went on. And so--and I have read the HSUS report, and I don't think the HSUS report has anything to do with arcane policies that were going on for many years. The HSUS report is dealing with things as they were then, and, as a matter of fact, they specifically said, "We do not investigate the past." So it was a--just a devastating critique of the way things were on the two days that they were there. And I, frankly, was astonished, because Laura Walters had three months to prepare for this. And I think I stated to people--probably to the Orange Board--that this was a waste of time, because obviously she's going to get the place cleaned up for these two days of the visit. But she didn't. They even found cockroaches on the floors, fans that weren't working even though workers there had reported and visitors had reported the smell. So I don't think this has anything to do with arcane practices. I think this-- Q All right. Let me ask-- A --has to do-- Q --you about specifics, since-- A Uh-huh (affirmative). Q --I can't get you to answer any of them. MR. NAKELL: Objection. Objection to the statement. A I'm answering. I'm going through here-- Q Mr. Cramer-- A --and answering your questions. Q --you mentioned fans? A Yes. Q Do you have any information whether or not those fans were operating while Pat Sanford was director at APS? MR. NAKELL: Objection. It is irrelevant. A Yes, I do. I asked her. Q All right. You asked Pat Sanford? A Yes. Q All right. And what did she say? A "Yes, of course." That when they did--she told me that if they ever had anything that wasn't operative--I also spoke to her former associate director. If they had anything that wasn't operative, they reported it to Public Works, and he said that even though they only had a few people, they came over promptly to fix anything that wasn't working. Also, he told me that they had a--well, no. I'm sorry. I called up the director of Public Works and asked him about their reports, and he told me that he went back for the last year and he didn't have a single request about the fans to--not working. He also told me that they had an exterminator contract with Clegg. So if there were roaches there or rat holes, all they had to do was make a call to them, and they would have had the exterminators out. Q Okay. Go ahead. A Okay. Do you want this? Q If you've referred to it. If you've mentioned anything. A I've forgotten. What did I mention? Yeah, I just said, "This is exactly what we--" Q The arcane policies. A "--were hoping to get. We know we've been dealing with many arcane policies." Q Okay. MR. MERRITT: We'll mark that as Cramer's Deposition Exhibit 7. (Whereupon, Deposition Exhibit No. 7 was marked for identification.) Q And let me make sure I understand. You're saying that the statement you just read by Laura Walters, you believe to be an outrageous lie? A I wonder--I've got another thing--well, you've already marked it. Okay. I've got another quotation here. Q Answer-- A Yeah, I believe that's an outrageous lie. Q Okay. All right. A Uh-huh (affirmative). Q Go ahead. A Here's another exact--let's see. What paper was that that I just read you from? Chapel Hill News. Well, here's the same quote from The Chapel Hill Herald. "It's something that is exactly what we wanted," she said. "We wanted an independent organization to give us constructive criticism and kind of get us on the right track because we're dealing with an archaic handbook that we knew needed updating." Walters--okay. "The bottom line is that the report was a long time in coming, and we've had some archaic procedures in here for years that needed to be changed." Q And you believe that to be a lie? A Yes. Q All of it? What part of that do you believe to be a lie? A The implication is that all the problems were due to the archaic handbook, and that is an outrageous lie. Q So you deem what you imply into a sentence-- A I believe the reasonable-- Q --to make it an outrageous lie? A I believe the statement is and the implication of the statement is an outrageous lie. Well, let's see. Okay. Here. "But APS Executive Director Walters says she believes the shelter's new policies are in line with the Humane Society's recommendation. 'In reading the recommendations, I think they make it very clear that there should be a set number of days these animals can be held, and unless we get these animals out through adoption or foster care, euthanasia is the only option.'" I think that's a lie. This was The Chapel Hill News, July 13th. (Whereupon, Deposition Exhibits Nos. 8 and 9 were marked for identification.) Q Do you think it's a lie that that's what she believed? Is that what you're saying? A No, that they make it very clear that they--there should be a set number of days, yeah. She--in reading-- Q Well-- A Yes, I think it's a lie that that's what she believes. No intelligent person could read that and believe it. Q Oh, okay. A And I do think she's intelligent. She's an outrageous liar, but an intelligent outrageous liar. Q Okay, sir. A Just a moment. Let me just see if there's anything else. Q All right. A I'm not going to be able to give you all because I've got a whole lot more material, and I only brought a selection of things that I thought would be relevant to what you're asking. But I'll give you enough to give you a flavor. Q While you're looking at that, can I ask you this question? A Certainly. Q Is it fair to say that whenever Laura Walters said something that you disagree with, you consider it a lie? A No, it is. No, there's-- Q All right. Okay. Go ahead. A Uh-huh (affirmative). (Witness reviews documents.) A Okay. I've just got a lot of quotations here that I've written down. This is from Indieweek.com, February 20th, 2002, "'The center which will open within a year will be a no-kill facility,' said APS interim Director, Laura Walters." Meaning animals that aren't being adopted at the Chapel Hill center will be sent there rather being euthanized. That's absolutely false. Q What's false about that statement? A Because that isn't what they are talking about doing. Q Is that not a statement of future-- MR. NAKELL: Let him finish-- A That's not-- MR. NAKELL: --his answer. A That's not what they're talking about doing. What they're talking about doing is an adoption center where animals are going to be kept for a few days before they're sent home. That's not a--that isn't a place where animals that aren't adopted at the shelter will be sent rather than being euthanized. Q Is that not a statement--are you finished with your answer now? A Yes, uh-huh (affirmative). Q All right. Is that not a statement of intention, or something that will be? A Well, a false statement. Yeah. Q So it's-- A False statement of intention. Q So it's your statement that Laura Walters didn't mean that? That's not what she intended and that's not what was being discussed at the time she made that statement? A No, I don't believe that was what was intended. Q Were you there? A No. Q Were you a party-- A But I have-- Q Were you-- A But I have read about-- Q Were you a party to that discussion? A No. Q Okay. Go ahead. (Witness reviews documents.) MR. MERRITT: Let me have the sheet you read from, sir. We'll need to mark that. (Whereupon, Deposition Exhibit No. 10 was marked for identification.) A Okay. Here's Laura Walters, a letter to David Jelly, September 30th, 2002, "The dogs were given their vaccines the morning after they came in, less than 24 hours later, which is protocol for every animal that comes in unless they are under age." I think that's a lie. "All animals are vaccinated within 24 hours." That's a lie. (Witness reviews documents.) A "This is your second warning. It is apparent through your own records that you have continued to accept birds on APS property despite my directive." That's a lie. MR. MERRITT: I'm marking this page as Cramer Deposition Exhibit 11. MR. NAKELL: For the record, this page is a document that Mr. Cramer was reading from when he made his last statements? MR. MERRITT: That's correct. (Whereupon, Deposition Exhibit No. 11 was marked for identification.) A Okay. Here's a statement Laura Walters to Virginia Ellington, APS board meeting, October 14th, "We had four animals returned in September." I believe that's a lie. Laura Walters to me on October 21st, "There is an average of three to four animals returned each month. This is down from the average of 12 each month in 2001." I believe that's a lie. Laura Walters, Shelter Committee, December 2002, "Question: Are there ever any adopted animals returned? Answer: No, there aren't any returns." That's a lie. Laura Walters to John Sauls, January 16th, "We are in the process of changing our system of monthly reports. We hope to have the process complete by the end of this month and expect that the monthly reports will be vastly improved from what it has been over the years." That's a lie. Q What about that statement is not true? A I don't think she hoped to have the process completed by the end of the month. This was back in January. There's no prospect of having it done. And that the monthly reports will be vastly improved from what it was over the years, I think in fact, the fact of the matter is the monthly reports have vastly--become vastly worse than over the years, based on the testimony of--a statement by Blankenship about what was done there. "The computer system crashed, and all data was lost," Laura Walters to John Sauls, January 21st, 2003. She's never documented that. I think it's a lie. Same letter, "The PetWhere software has been causing problems with the data in monthly reports for years." That's a lie. It had not. MR. MERRITT: We're going to mark the sheet he was just referring to as Cramer's Deposition Exhibit 12. (Whereupon, Deposition Exhibit No. 12 was marked for identification.) A Let me just see the bottom of that. Okay. Laura Walters's letter to John Sauls, March 7th, "We're saddened that Dr. Schopler decided to resign. It's not something we wanted, but we do anticipate continuing the Wildlife Center and will move on from here." That's a lie. Q What part of that statement is not true? A That she said that Dr. Schopler decided to resign and it's not something they wanted and that they anticipate continuing the Wildlife Center. I don't believe they ever planned to continue the Wildlife Center. Q Why do you think they did not want Bobby Schopler to continue to work there? A Because he wasn't willing to be subservient to Laura Walters. Q Well, you're telling me what he thought. I'm asking you-- A That is what I think. MR. NAKELL: I'm going to object to-- Q Why do you think--well, you said "they," referring to APS. Why do you think APS--anyone in APS management did not want Bobby Schopler to continue to work there? A Because he wasn't willing to be subservient to Laura Walters, and he wasn't willing to continue spaying and neutering public animals under the current contract. Q Okay. A Okay? Q Go ahead. A "We're"--same thing. "We're talking with other vets with a federal license." I believe that's a lie. (Witness reviews documents.) A Chapel Hill Herald, July 31st, 2002, "Walters has said that Schopler wanted only to be a wildlife veterinarian." That's a lie. Q How do you know? A Because I know that he was--based on my conversations with his mother, certainly--I'm not sure if I discussed it with him. But he was perfectly willing to continue spaying and neutering the animals that they had there. He never said he was--only wanted to be a wildlife veterinarian there. I know that wasn't his intention. Q Were you a party to any of the conversations and negotiations between Laura Walters-- A No. Q Let me finish my sentence--my question, please. Were you a party to any of the conversations or negotiations between Laura Walters and Bobby Schopler concerning his contract? A No. Q All right. Do you know how many different versions of the contract were offered to Bobby Schopler? A No. Q Have you ever seen a copy of any of those contracts? A I'm hoping to, but I haven't. Q Do you know whether or not he ever accepted any contract proposal that was made to him? A No, he did not. Q Okay. A Okay. MR. NAKELL: Would you like to mark this page for identification? MR. MERRITT: Uh-huh (affirmative). MR. NAKELL: Hold on. THE WITNESS: There--and there are other things on there I may want to get back to. So if you will keep all these things separate. (Whereupon, Deposition Exhibit No. 13 was marked for identification.) A Okay. Daily Tar Heel, March 24th, "Due to Cramer's repeated efforts at attempting to access areas of the animal shelter that are off limits to the public, along with his threatening behavior, shelter staff were forced to call the police and have Cramer removed from the property." That's a lie. Q You already mentioned that. A No, I didn't have that quote. That's a more complete quote. Q Okay. A And none of that happened. APS-- Q Well, let me ask you about that. Is it your testimony here today that you did not try to get into the front door of the APS after it was locked? A That's correct. Q Is it your testimony that you did not walk around to the side of the building and try to get into another door? A The side of the building? Q Uh-huh (affirmative). A No. Q Did you try to get into a second door in the front of the building? A I didn't try to. I walked in through an open door that was unmarked. Q And is it not true that the sign on the front door that you had just come from said that the facility was closed? A I don't know. Q What time was this? A It was a few minutes after 5 o'clock. Q And you did not notice whether or not the sign at the front door said the facility was closed? A I believe the facility was closed. Q Okay. A So I don't deny that. Q All right. Why did you try to enter the facility after it was closed to the public? A I had just delivered some nomination forms, and I forgot to ask for a receipt. It was a few minutes after 5:00. That door was unmarked. It wasn't marked closed. They do have a sign there now. I did walk in there. I asked--I believe asked Nicole Carper would she give me a receipt. She very cheerfully gave me a receipt. Nobody complained about my having walked in there. Q Did you go to any other parts of the building? A No. Q Have you ever been to any other parts of the building that were not open to the public? A Only once, and that was inadvertently, as I've described in the letter that I sent to Ms. Beyle. I went through a door that had no--I'm sorry. I went into a room which I know now to be the--something wing. I've forgotten what it's called now. It's where they, I think, quarantine animals or bring incoming animals. They, as I have learned since, typically keep a gate there. The gate was removed. The door was open. Only time I've ever been in the animal area of the shelter. I was looking around, making notes on the cage cards. Walked in there. There were two people who I presume now were APS employees in one cage, and one of them said to me, "This area isn't open to the public." I said something to the effect, "I'm sorry. I didn't know." And he said, "I forgot to put up the gate." And those two people were the only people that saw me in that area, and that was the basis for them issuing this trespass order. And it was a transparent attempt at intimidation because of what I have been doing since, and I never did any of the other things that they mentioned. And Pat Sanford has testified to Orange County that in fact they often had problems with people forgetting to put up that gate, and she confirmed that she went back there, I believe, and indeed it was unmarked. Q Did you--after leaving a board meeting--I'm talking about the board of directors at the APS-- A Uh-huh (affirmative). Q --and having the board go into executive session, did you sit outside the front door of the room that they were meeting in in your automobile for over an hour? A I may very well have. So what? It's university property leased by the county. Doesn't belong to APS. Q Why did you sit there for an hour? A I was waiting for Judith Reitman. It wasn't--I'm sorry. It was not an hour. Q How long did you sit there? A Probably 20 minutes. I was waiting for Judith Reitman, who I was expecting to come out. I had asked the officer there to tell her that I was waiting for her. Q Now, isn't it true, Mr. Cramer, that you only left the meeting when the meeting went into executive session? Is that not true? A Well, I'm--what date are you talking about? I'm not sure we're talking about the same thing. Q All right. Do you recall leaving a meeting of the board of directors at the animal shelter and sitting in your car directly outside the front door while the executive session took place? A I couldn't sit out--I couldn't sit in my car directly outside the front door. That's impossible. So-- Q At the closest parking place that there is there. A After they went into executive-- Q Yes, sir. A On what date? Q I don't recall the date. A No, I can't say that I do-- Q You don't recall doing that? A I don't recall that. I wouldn't say-- Q Do you think that some of the people in the meeting would have found that intimidating? A No, I don't think I'm an intimidating person. I'm 70 years old. I mean, I'm in pretty good physical condition. But whether or not they would find it intimidating, what's wrong with my sitting outside there? But I don't know that I--I certainly never sat outside there for an hour. It's conceivable I might have sat outside there going over--looking over some stuff or waiting for somebody. But you're saying when they went into executive session? Q Uh-huh (affirmative). A No, I can't say I have any recollection, but I certainly couldn't have been sitting outside there for an hour. Q Okay. Go ahead. A Uh-huh (affirmative). "It is believed that these solicitations would be directed at ruining APS and raising money for Cramer and Reitman's newly formed organization of the Piedmont Animal Welfare Society." Q Now, what-- A That's a lie. Q What are you reading now? A This is also from the Tar Heel, March 24th, the statement. Q By whom? A By Laura Walters. Q So you're saying that she didn't believe that? A How could she believe it? Because at the time I had asked for this information, PAWS had never been formed. PAWS wasn't formed until February. Q So she is clairvoyant? She knew about PAWS before-- A Apparently. Q --you did? A Apparently. She's quoted now on March 24th saying--that's exactly my point. She would have had to have been clairvoyant to know that. Q Well, let me--read it again, if you will. A "It is believed that these solicitations--" she's talking about my membership--my request for the membership list back in November. Q Do you know that's what she's talking about? That's not mentioned in that quote. A It says, "APS refused to turn over the membership list to Cramer and Reitman." I-- Q Did you not continue to seek the membership list? MR. NAKELL: Just a moment now. You're going to need to let him finish his answer. Q Did you not continue-- MR. NAKELL: Just a moment. Let him finish his-- Q Okay. Go ahead. MR. NAKELL: --answer before you ask the next question. Q Go ahead. A My request for the membership list was prior to the change in the bylaws. And she is saying that you refused to turn over the membership to Cramer and Reitman because it was necessary. Well, you never told me--no one--you never told me--you never answered my letters, in fact. But you certainly didn't tell me that that was the reason you wouldn't give it to me. You told Margie Huggins that you wouldn't give it because it would be used for improper purposes. But my requests were made before that. And I don't know that after I--after PAWS was founded, I think--I don't know that I asked for the membership list until recently. So you'll have to show me the letter. But in any event-- Q Now wait a minute. Are you finished with that answer? A Yes, uh-huh (affirmative). Q Okay. Didn't you go to the county commissioners and didn't you go to the newspapers and complain about not getting the membership list? A Certainly. Q And didn't you continue to do that even up unto and after forming PAWS? A I may have. Q And aren't you still to this day complaining about not getting the membership list? A Of course. Q All right. Is it not a fair interpretation of that statement that she was talking about the fact that you're still wanting the membership list? A That's--I don't think it's a fair interpretation at all. Q She doesn't mention your November request there. She just simply says your solicitation is for the membership list; is that correct? A It says, "APS refused to turn over the membership list." Well, the times you refused to turn over the membership list were back in November. I mean, the--all this time this stuff was in the newspaper, no one from APS ever talked to me about the membership list. So your refusal was earlier. I haven't gotten any refusals from you since January-- Q But your demands through the media and to the Orange County Commissioners have continued, have they not? A Yes, but that's nothing to do with your refusal. Your refusal was earlier. Q All right, sir. A Uh-huh (affirmative). Okay. Here. Same article, "Adoption rates have increased. The return rates have decreased, and employee and volunteer morale has soared." That's a lie. Adoption rates haven't increased, even though Pat Beyle claimed that they were ten points higher in an article with John Wise. They are not. MR. MERRITT: I'm going to mark this he just referred to as Cramer's Deposition Exhibit 14 for identification. (Whereupon, Deposition Exhibit No. 14 was marked for identification.) A May I ask to see that again? Q Sure. A Same article, same statement, "They have never approached the APS board or staff to try and resolve any issues, but instead went directly to the board of commissioners and newspapers." That's a lie. Judith Reitman wrote Pat Beyle, and, in point of fact, my very first--before I ever did anything, I went to the board and I offered--and you were there. I offered my cooperation. So that's a lie. Q And when you--do you feel like they didn't give you--didn't accept your cooperation? A They never said a word. Q In what way did you offer your cooperation? A I offered my cooperation in helping to run APS. I said I would like--I said we would like to be nominated to the board. I believe I suggested--well, I could--I think I've got my statement here which I could read you, but which you have. And I said we would be happy to cooperate with APS, and I think bring APS a bright future. I asked that you stop doing things in secret, stop going into executive session to hide things from the membership. You immediately went into executive session and discussed a change in the bylaws even though you told me you had no intention of doing that. That wasn't true. You did have an intention of doing it, because it was in the agenda for executive session, and that was something that should not have been covered in executive session. It should have been open to the membership. Q Go ahead. A Okay. (Witness reviews documents.) MR. NAKELL: Are you going to mark this as the next exhibit in order? MR. MERRITT: It's Exhibit 15. MR. NAKELL: This is the page that Mr. Cramer was just reading from? MR. MERRITT: That's correct. (Whereupon, Deposition Exhibit No. 15 was marked for identification.) A Okay. Here's something that I was told was jointly written by Laura Walters and John Sauls. Q And who told you that? A John Sauls. Q Okay. A "Animal Shelter FAQs." I first saw it in March of 2003. I believe it was written there, and he told me the two of them wrote it. "Total estimated costs for fiscal year 2001 to 2002 were $1,272,232." That's a lie. Q Are you saying that John Sauls is also an outrageous liar? A Yes, he is. Q Okay. Go ahead, sir. A Okay. And I questioned--I pointed out to John Sauls that this contradicted various budget statements, and he told me, "Laura Walters stands by it." And this was continued to be distributed, I believe, for a couple of months. Q Do you think that John Sauls is a corrupt public official? A Yes, I do. Q Okay. Go ahead. A And I have said so. MR. MERRITT: We'll mark this as--the page he just referred to and checked as Cramer's Deposition Exhibit 16. (Whereupon, Deposition Exhibit No. 16 was marked for identification.) MR. MERRITT: For the record, I want to say that Mr. Cramer has been placing a check mark beside the statements that he's referring to on these documents as he's referring to them. A Okay. This is Laura Walters, July 2nd, Channel 17 interview which I got from their web site. "The evaluation found that the building was too small and that the animals are kept there long." The first part, the evaluation did not find that the building was too small. "Laura Walters, the shelter director, told NBC 17 she and her staff are doing what they can to make the changes with the limited resources at their disposal." Well, there aren't limited--they've got $467,000 from Orange County, Carrboro and Chapel Hill. Q Are those--is that what you'd call unlimited? A Nope, but I think this-- Q Well, then it's not-- A --suggests--the suggestion of limited doesn't mean it's not infinite. The suggestion of limited, I believe, is there are relatively little resources, and I think four hundred and sixty-seven dollars [sic]--I think nobody would believe--would call those limited resources-- Q Again-- A --except Laura Walters. Q Again, do you have any information from any other animal shelter as to what the reasonable cost of running this size shelter is? A I believe that probably more money is spent per square foot on this shelter than any other shelter in this state. Q What do you base that belief upon? A On the report from the state which lists all the shelters in the state. I've looked through that, and I believe that is so. I could conceive--there might be others, but I believe that that is so. Q Okay. And is that more county money or more money total? A Huh? Q Are you referring to more government money or more money in total? A Probably either. Probably either. Q Well, do you know? A No, I--that's my belief. Q Okay. A APS press release June 30th, 2000, "The HSUS evaluation team pointed out the inoperable ventilation in the shelter as one of the causes for the spread of highly contagious diseases." They never said that at all, and it wasn't an inoperable ventilation system at all. It was just there were, I believe, nine fans that weren't working that Laura, in an air- conditioned office, never noticed and never bothered to report, and one fan that was turned off. And I believe that many people complained about the smell there, and Laura did nothing. All she had to do was call up the Public Works people, and they would have come over and fixed the fans. And they did come over and fix the fans, and Laura wrote a letter saying that "Everything had much improved, and we expect the disease rate to go down." Oh, continuing that--may I ask to just see that back for a moment? MR. MERRITT: I'm going to mark it first as-- THE WITNESS: Yeah. MR. MERRITT: --Deposition Exhibit 17. (Whereupon, Deposition Exhibit No. 17 was marked for identification.) THE WITNESS: Uh-huh (affirmative). A Yes, continuing the same statement, "The board acted immediately to get Orange County facilities staff to fix the system, which evidently had been turned off years ago." That's a lie. The system hadn't been turned off. There was one fan that was off. "This past year, the APS board and staff worked with the county staff to check reporting requirements." I don't believe they ever did any such thing. I've asked. I've been after them for months to do it and-- Q Reporting requirements concerning what? A I believe the monthly reports, the shelter reports, and I don't believe they--I've asked for all document--all correspondence with the county. And I never got anything relating to that. I specifically asked John Sauls what he had done, and he never did anything. Q Now, who made that statement you just mentioned? A This is the same quote. This is quotation. Q From whom? A Laura Walters. This is all Laura Walters. Press release. I'm continuing-- Q It's an APS press release? A Yeah. Q Do you know that Laura Walters wrote it? A Laura Walters, I believe, reviews all press releases. Q Do you know whether or not Laura Walters wrote that press release? A I believe that Laura Walters issues all press releases. That's my belief. Q Okay. A It may even have said it on there, but I'm--I don't have it handy. "Anticipating the preliminary report, review of policies and procedures regarding disease management and cleaning protocol were put on hold so that all HSUS recommendations could be fully reviewed and implemented as warranted." I believe that's a lie. Q Do you believe it's a lie that they put anything on hold, or do you believe-- A I believe-- Q What part of that do you think is a lie? A I don't believe that anything was put on hold for the purpose so that HSUS recommendations could be fully reviewed and implemented as warranted. Q So is--let me understand. A Yeah. Q Are you saying that you believe that APS never intended to implement the HSUS-- A No, I just don't believe that anything was put on hold because they were anticipating a preliminary report. I don't believe anybody anticipated a preliminary report. It was certainly a surprise to me, and I don't think anybody knew there was going to be a preliminary report. Q So you're accusing Laura Walters of lying when she says that she anticipated a preliminary report, because you didn't know about one? A That--no. I'm saying I don't believe that statement, that anticipating the preliminary report--I said I doubt that anybody knew about it. But what I am questioning here is I don't believe the statement that "Anticipating the preliminary report," the following, "review of policies and procedures regarding disease management and cleaning protocol were put on hold so that all HSUS recommendations could be fully reviewed and implemented as warranted." Now, if I'm wrong about that, I presume we will get the documents in discovery. But I believe that's false. "A list of proposed policy changes as attached based on HSUS preliminary report was unanimously approved and all changes will be implemented week of July 4, 2003." Well, elsewhere she said it was implemented that same day. Q Elsewhere where? A In the newspaper she was reported as saying--here. I've got the reference here, "Laura said it was done on July 1st, causing the euthanasia of 26 cats." Whereas Beyle said the board is still considering it. So I think that's false. It certainly contradicts what Laura was reported as saying, and it contradicts what Pat Beyle was reported as saying. MR. MERRITT: I'm marking that sheet as Exhibit 18 for the record. (Whereupon, Deposition Exhibit No. 18 was marked for identification.) A Okay. Laura Walters, Chapel Hill News, June 29, 2003, "In the past, vaccinations often were not given in a timely manner," contradicting what she had said before. "Measures have been enacted recently to rectify the problem." Quote, "In the past month, at least, I haven't found one that has been lacking." That's a lie. I found 19, and I-- Q But you're saying that--you're telling me that it's a lie that you found-- A It's a lie that-- Q Let me make sure I understand that. You're telling me that she lied when she said she hadn't found something; is that right? A That's right. She's responsible-- Q Do you know whether she looked? A The implication certainly was that she had looked. Q Again, the implication is a lie? A No, the statement. I believe the statement that she didn't find one. Either--the common sense interpretation of this is that she is on top of this. And the point was--the content of this article was the HSUS statement contradicting her statement that animals are vaccinated within 24 hours. They found that animals are not vaccinated within months, as I had repeatedly said both to APS and to Orange County. And so responding to this, now she admits that the vaccinations weren't given in a timely manner. But certainly the clear statement here is that now they are being given, and in June there was not one. In fact, I found a number. So, yes, I think that is a lie, and I think it's an outrageous lie, certainly. MR. MERRITT: Mark this sheet as Cramer's Deposition Exhibit 19. (Whereupon, Deposition Exhibit No. 19 was marked for identification.) A Here, from the animal shelter's FAQs which I previously mentioned, "Standard protocols as recommended by HSUS are adhered to," and the HSUS report confirms that they were not. "The APS veterinarian makes daily rounds through the animal shelter prescribing medications and assessing conditions." Laura Walters has made clear that now they are going to do that, but they didn't do it before. Q Where did she make that clear? When was the statement that you just read? A This was, I believe, in March, the FAQs which I believe was indicated in March, in the newspapers in response to the HSUS complaints I believe in the--it may be in the press release. She has said that she's now having the veterinarian come over daily, which the veterinarian never did before and didn't do before the current veterinarian either. He came over as needed, but this was certainly a false statement. "The shelter manager and her staff are responsible for ensuring that all disease control tools are in place and disease spread is at a minimum." Well, this contradicts what HSUS found. (Whereupon, Deposition Exhibit No. 20 was marked for identification.) A Okay. Laura Walters's letter to David Jelly, September 30th, "The dogs were given their vaccines the morning after they came in, less than 24 hours later, which is protocol for every animal that comes in--" Q You already mentioned that. A Oh, did I? Okay. Fine. (Witness reviews documents.) A Here's something that isn't signed by Laura Walters, but I believe that Laura Walters had a part in it. I think it's pretty clear. Q Why do you believe that? A Because of the information that was provided, which was a letter from you to Pat Sanford, which would have had to have come out of her files. And-- Q Well, let me see the document. Let's mark the document you're talking about. A Okay. Let's see. I've got this all stapled together. Is it possible for us to photocopy this, or can we stamp it and keep it together and then photocopy it or-- Q Stamp it and keep it together. A Okay. MR. NAKELL: Well, he means stamp it and just use this page as an exhibit. MR. MERRITT: That's fine. Unless he can identify what that is or he doesn't have it--well-- THE WITNESS: No, I mean can we-- Q Do you have any direct evidence that Laura Walters wrote that document? A No, I don't. Q Okay. A But it's my belief. Q But you're going to say that she's an outrageous liar because of what's in it? A I believe it's clear that she wrote this. Q Okay. That's fine. We'll mark it. A Okay. Q We'll copy it. A Okay. (Whereupon, Deposition Exhibit No. 21 was marked for identification.) A Let me see. "Under Pat's management, thousands of animals were unnecessarily killed because of her lack of understanding of animal behavior." Incidentally, this is signed, "Longtime current and former APS volunteers and staff." It was an anonymous statement that was made. Q Okay. A Okay. Let's see. Q And what part of that statement is an outrageous lie? A That thousands of animals were unnecessarily killed. Q Now, how do you know-- A I don't believe any--what? Q How do you know that's a lie? A Because there couldn't be thousands of animals that were unnecessarily killed, because the euthanasia rate--the adoption rates were the same the previous year as before. Unnecessarily means what? That is, there--the claim here is that certain types of dogs were euthanized. Q And do you know whether or not that was true? A It wouldn't make any difference. Because if they weren't euthanized, other dogs would have had to be euthanized in their place, because you've got 5,500 animals coming in. You've got a certain number of adoptions. I can quote you from the FAQ which she wrote, namely that the reason more animals aren't being adopted is because of the limited number of--or so many are being euthanized because of the limited number of adoptions. So what-- Q And of course you're assuming that the same--are you assuming that the same number of animals has come in for years? A Yes. Q Are you assuming--even though the population of Orange County is growing, you're assuming the same number of animals are-- A I'm not assuming it. I know it. Q For how many years--or how many years are referred to in that document? A Well, I can tell you with regard to your question that as far-- Q No. Answer this question. A What? It doesn't-- Q How many years are referred to in that document? A It doesn't say. Q So you don't know what years they're referring to, do you? A No. Q Okay. Go ahead. A Uh-huh (affirmative). Except that Laura Walters has only been there for a few years, and there are very few staff members who have been there for very many years at all. As a matter of fact, seven were, I believe-- I don't know. It's-- Q But since you don't know who wrote the document, how can you say that makes any difference? A Okay. Continue. "Pat further refused adoption to good people because they didn't fit her preconceived notion of what a proper family would be. Her prejudice against non-white races canceled out thousands of good homes for those unwanted animals. "When Pat finally left, she stole files and computers, forcing the new management to start over. The animals are finally cared for fairly." Yeah, I think those are lies, and I--actually, I've got a supporting letter from a former member of the board of directors who says so, too. Okay. Let's see what else I've got here. Q Let's have that document, sir. A Yes, right. I'm sorry. I do hope we will be able to find out who collaborated in the writing of that. The press release is signed--we referred to before is signed by Laura Walters. Q No, it's not. A Isn't it? It says, "Contact." No, you're right. It just says, "Contact: Laura Walters," uh- huh (affirmative). Q Let me have that, sir, since you referred to it. A Uh-huh (affirmative). MR. MERRITT: Mark this as Cramer Deposition Exhibit 22. (Whereupon, Deposition Exhibit No. 22 was marked for identification.) THE WITNESS: Can we photocopy that? MR. MERRITT: We're going to photocopy all of these-- THE WITNESS: Oh. MR. MERRITT: --sir, and give you copies of-- THE WITNESS: Okay. MR. MERRITT: --every one of them or your counsel. THE WITNESS: Yeah. Well, okay. A That probably is all I have here. Q Do you believe that telling a lie makes someone a corrupt person? A It's--somebody who persistently lies about things involving a government contract certainly indicates corruption to me. Q Have you ever looked up the word "corrupt" or "corruption"--the words "corrupt" or "corruption" in the dictionary? A I don't know. Not--certainly not in a number of years. Q Do you have any information that anyone at APS was giving or receiving bribes? A No. Q Do you have any information anyone at APS was involved in any under-the-table improper contracts or deals? A Yes. Q What was that? A Laura Walters. Q In what way? A Not while--you said, "anybody at APS." You mean while she was at APS? Q Yes. A No, not while she was-- Q This organization that you've called corrupt is APS-- A Yeah. Q --is that correct? A Yeah--no. I know, but we're talking about Laura Walters. And I thought-- Q What information-- A And so I-- Q What information do you have that Laura Walters has ever been involved in any real corruption? A There's a letter from an assistant who worked for her for six months. That's in the public record. Q Uh-huh (affirmative). And in what way did that assistant accuse her of corruption? A It appeared that--well, let's see. THE WITNESS: Barry, do you have that--can we get the letter? A I'm referring to this letter right here. Q Uh-huh (affirmative). In what way does that letter accuse Laura Walters of corruption? A Okay. Let's see. (Witness reviews document.) A "Laura Walters had"--you want me to read it? Q Uh-huh (affirmative). A Okay. "Laura Walters had telephoned me at home one morning saying the sheriff's deputy may call me to go to another town and pick up a few dogs on a playground that were displaying vicious behavior. She also informed me that I could go ahead and euthanize them. The sheriff's deputy never dispatched me. "Laura had informed me at a later time that there were a few more dogs that were going to be delivered to me, and upon arrival they were to be euthanized with the assistance of the gentlemen that were bringing them in. Laura had informed me that the official paperwork was not needed in this case. "There ended up being 16 dogs total, three of which were definitely mixed breed, that appeared to be litter mates and a little nervous. Twelve of the 16 were full grown blood beagles and one beagle puppy out of these. They all looked well cared for and friendly. "Laura was getting paid forty dollars per dog that came in from the county. When they came in around 3:00 p.m. that afternoon, it appeared that some of the beagles had been wearing collars just by looking at their marks on their necks. When I inquired about this to the gentlemen who brought them, they said, 'They don't anymore,' and laughed as they walked away. "At this point, I wasn't feeling comfortable with the conversations I had been having with Laura in regards to these particular dogs. I decided to load them into my truck and haul them to Dr. Smith's office to assist with the euthanizations, as he had always done for free. "We then euthanized the three mixed breeds, and I then took all the beagles back to the shelter. I then wrote up the appropriate paperwork on all the dogs and treated them like I did with any other dogs I received. "When Laura called me up at 5:00 p.m., I informed her what I had done. She then said the following: 'You did what? You didn't write up any paperwork, did you?' It seemed as if she didn't know what to say after that, and she was not comfortable that I had gone to Dr. Smith's office. She then came in and checked them over and said not to adopt the puppy out, that she had someone in mind to call. "Upon arrival the next morning, I found that the puppy was gone. When I asked her about this, she said that the puppy must have gotten out. The owners of the beagles did however contact me and stated that all of his dogs had on collars except the puppy, and that they were taken from his yard in the country. "I received one more load of dogs two weeks later, and I was informed by Laura to do the same thing as I was instructed before. I then decided to place them in kennels once again. "By this point, it was obvious to me that the mayor, who coincidentally was delivering the dogs, did not like the fact that I was placing them into the kennels and writing up the appropriate paperwork. I then informed Laura that I did not know what was going on and I did not feel comfortable taking in any more shipments of dogs from the mayor. "During this time, Laura had purchased a van from a board member prior to receiving an authorization from all board members. There were a few board members that knew of this purchase, one of whom being the one she'd purchased the van from. "They then held a board meeting and informed members they didn't need to be there, that it wasn't in regard to finances. They excluded two members, Ginger and Dr. Singer. "While she was planning the opening of the new facility, she had asked me to give rabies vaccinations at a low cost to adopted animals. She also wanted me to take in suspected rabies cases, i.e., skunks. I did inform Laura that my giving the rabies vaccinations was illegal. She then proceeded to speak at a local farmer's market informing the public about her plans at the shelter. "Laura frequently took calls from her home for the shelter and informed people that we had animals of specific breeds we did not. Some of these people would drive 30 miles and end up with what they thought was of full-blood origin. "On one of these calls, she informed a couple who had a skunk that was attacking the family dog and killing some of the puppies--she told them to kill the skunk and remove its head and bring it to Dr. Smith's for a rabies specimen, bucket and form, and to take it to Little Rock, Arkansas. "Dr. Smith refused to have anything to do with this. So they came to me. I gave them the bucket and form at this time"--oh, "At this time, I noticed the man's hand was severely scratched. I asked him if he had used gloves. I also informed him that he might need to check with his family doctor in regard to rabies exposure as soon as they returned. I never wanted any involvement. So I immediately started documenting dates, times, et cetera. "Laura called me the next day. She decided to scream profanities at me, asking me who the fuck do I think I am telling them to see their family doctor. I explained that he had scratches and abrasions on his hands. "She then said, 'If he was that stupid, then I don't care if it does kill him. He deserves it.' It was at this time I resigned from my position as animal control officer." Q And that's a letter from? A From Alia Thompson, which is in the public record. Q How did that letter-- A "My official title was animal control officer and kennel worker during the week, Monday through Friday. The weekends I was dispatched by the on-duty police officer. I was employed until the day the indoor kennel facilities were opened." Q How did that letter get in the public record? A I believe I put it there. Q And how did you do that? A I delivered it. Q To? A To the-- Q To whom did you deliver it? A I delivered it to the clerk, I believe. Q And is this-- A I may have faxed it. I either faxed it or delivered it. Q So is this typical of the way you have operated since you started investigating APS, take a document, put it in the public record, and then refer to it as being in the public record? A I'm sorry? What do you mean? Q Well, did you-- A No, I've only-- Q Have you not written-- A I think I have only put three things in the--three letters in the public record, and actually these were following a conversation that I had with you where you had criticized me for giving--it was actually that thick thing. You had criticized me at I think the second--I believe it was the November meeting of APS where I delivered that packet you note as presented to the APS board. I previously--yeah--no. It was given to the APS board. It was originally given in a statement to the Orange County Commissioners. And you came up to me after, at the end of the meeting, and berated me for giving a copy of this to a reporter who was present. And you asked me if it was--you thought it was--did I think it ethical to give this, referring to the Ann Clark statement, to the press. And I told you at that time that it was in the public record, and that furthermore, Pam Baine had given a copy to the APS board. And I believe you told me, "Just because a member has given it to the"--"given it"--"seen it, it doesn't mean it's presented to the APS board." And you asked me did I know the statement from Ann Clark was true, and I pointed out her qualifications. And I said that I believed it was true, but I was checking into confirmation about these things. And it was after that that I got this letter, the letter from Dr. Singer and Dr. Smith, and I did put those into the public record. And I believe I gave copies to APS. So it seemed to me this was a perfectly proper thing for me to do. MR. MERRITT: Let's mark this. This is Cramer Deposition Exhibit 22? THE WITNESS: Uh-huh (affirmative). (Whereupon, Deposition Exhibit No. 22 was marked for identification, and was later re-marked as Deposition Exhibit No. 24.) Q Mr. Cramer, did you request that this letter be written? A I asked her if she would write a statement about the situation in Greenwood involving Laura Walters, following what I had seen about the Ann Clark. Q So you called up Alia Thompson? A That's right. Q You contacted her? A Uh-huh (affirmative). Q What did you tell her your position was? A I told her about--that I had received this letter--I had seen this statement from Ann Clark and I was trying to get independent confirmation of it. Q Who did you tell her that you were, other than Elliot Cramer? Did you tell her that you represented APS? A No, of course not. Q Did you tell her that you were trying to get on the board at APS? A No. Q And why would she give an individual that had no connection with APS that letter? MR. NAKELL: Objection to the form of the question. It's asking-- Q If you know. MR. NAKELL: --about-- Q If you know. MR. NAKELL: --why another person--a third person acted, and it also misstates that he had no connection with APS. MR. MERRITT: Okay. Q Do you know why she agreed to give you that letter? A I think it's pretty obvious from this letter that she was pretty horrified by the actions of Laura Walters and wanted to document it to anyone who was interested.