In legal proceedings, attorneys systematically present and authenticate various types of evidence including text messages, emails, meeting notes, and personnel files to establish facts and support their case, with witnesses providing testimony about the content and context of these documents.
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Uh, Wes, uh, can you hear me? Okay, >> I can hear you fine. Can you hear me?
>> Uh, I'm fine. Did you see the email from Carrie Morgan's, um, attorney?
>> No, I did not.
>> She emailed you and I asking for a status. What time did you tell her she was? It's, uh, the time is 11:16.
She said she couldn't go until the afternoon. I gave her from noon to 5 range.
>> Okay. Um, just housekeeping only. I assume we are going to take a lunch after Mr. Benhack is done. Is that your intent, Judge?
>> Well, I was nodding to the extent that you're assuming we're going to take a lunch. As to when we take it, I there's a fair amount of uh latitude that I'll grant you. you're the ones that are con have a better idea of uh who you're going to call and how long they're going to take. Uh is that a logical breaking point, do you think? Uh >> both.
>> I I think that could be a logical breaking point. Yeah. Um >> or I could squeeze in one witness beforehand who's a former Yeah. Yeah.
Probably we'll probably take a break.
Never mind.
>> Um Wes, just FYI, I I will respond to her. I'll copy you in just so they're not sitting there waiting that it's going to be at least an hour if not more. I mean, it's courtesy to these folks that are >> Absolutely. I appreciate you catching that email. My My >> notifications are all off when I'm talking. Thank you so much.
>> Very helpful.
>> I I just was during the brief break, I just because I didn't wasn't sure when we were going to have lunch and I I nibbled a little bit on one of those protein bars. They always look like they're going to taste a lot better than they actually taste.
Would everybody agree with that?
>> Yeah, absolutely.
>> Okay.
>> Okay.
>> The other the other thing before we go, and I know we got to get going, but I I'm assuming that I've seen that background that attorney Lubinsky has just for transparency, that's not her actual abode. Uh but uh um I the the chair in the back >> the chair in the background is like sort of a knockoff of a very famous mid-century modern chair called the Chieftain chair and it was uh it was designed by Finn Ule I believe in 1949.
Uh but it's kind of a bastardization of his creation. Uh so anyway uh if there's anything useful useful anybody and all the viewers get out of this hearing I think that probably will be be it.
>> Um so okay uh let's go back on the record then the recording has been going so that'll all be on the recording. Um we are continuing with Mr. Ben Hack's uh the examination Mr. Ben Hack by attorney Hasslam. Um I think we are on C72 as far as exhibits go.
>> C7 >> whatever the next the next one is.
>> The next one will be C72. That's correct.
My screen right now.
>> And uh the next exhibit I'm pulling up here is my um C152 and it's going to be page 39.
And uh Mr. Mr. Binhack. Um, and this is a short hand is text Fashi Binhack.
>> Yes.
>> So, Mr. Benhack, these are texts between Amanda Felashi and yourself.
>> Yes.
>> And it's on April 4th, 2023.
>> Correct.
>> And when she says, "Oh, Art, five flipping votes." Uh, she's talking about your your your narrow loss, right?
>> Correct.
>> Okay. And uh then below that she says, "I'm stuck with Amy." Is she talking about Amy Helvick there?
>> I assume so.
>> Okay. And uh you say, "Oh, she's a conservative, right?"
>> Yes.
>> And then she kind of laughs about that a little bit, it looks like. Right.
>> Yes.
>> Okay. But then you go down and you say, "But we have the majority now or we have the majority 3 to2 and we need to elect one of our three the president of the school board." They set the agenda. I nominate Gwen. Is that correct?
>> Yes.
>> And Amanda Felashi responds to you, "Good idea, right?"
>> Yes.
>> And do you know the three that you're referring to there?
Uh Gwen, um Amy or Amanda and uh Audrey, I would imagine.
>> Okay. Gwen, Keller, Audrey Costage, and Amanda Felashi. Right.
>> I believe so. Yes.
>> Okay. So, I'd like to go ahead and move in C152, page 39 into evidence, please, as exhibit C72.
>> No objection.
>> And just before we uh Well, oh, okay, let me admit it. So yes, exhibit C72 um bait C152 is admitted. Um how do you spell I can't see it on the screen. Uh >> F A L A S.
>> Okay, hold on. You you anticipated whose name I want to spell, but let me get positioned here. F A L >> um F A L. Uh, >> at F A L A S C H I. Thank you. Sorry about that.
>> Okay. So, that exhibit is admitted.
>> Okay. And now I'm going to go to my 156 and we're going to go to pages 3,97.
And um this is going to run through 3,914.
So 3,97 to 3,914.
Okay. And uh Mr. Binhack up here I have um is this a a date uh January 2nd, 2023?
>> I believe so.
>> Okay. And is it a >> council? Before you continue, can you just give me a shorthand description for this exhibit?
>> Uh, yes. We'll say notes of a school board meeting.
>> Notes of what was it? Schoolboard meeting.
>> Notes of schoolboard meeting. Yep.
>> And so, um, here are these notes you took of a I'm going to actually make these a little bit larger.
I think that's about as large as I could appropriately make it. So these notes of a school board meeting that that that you were at or that >> Yes, I believe this is this is the u the special meeting for the Raymond search firm. Yes.
>> Okay.
>> And this is this is enumerated uh page one right here, right?
>> Yes.
>> Okay. And um seems like right here you're talking about the superintendent search. Is that right?
>> Yes. Yeah. this I believe that that's what this is about.
>> Great. And then if I go down to um page two, these is a continuation of the same notes, right?
>> I believe so.
>> Page three is the same notes, correct?
>> Yep.
>> Now, up here though, it says uh Gwen.
I'm g highlight it for you. Says Gwen.
What? What? Do you know why you wrote that there?
>> No, I really don't. I >> Okay. Um, now on um page uh 310 here, does the board at at some point here go into a closed uh session?
>> I I believe so. I think so. Yes.
>> Okay. Um but your notes keep going, right?
>> Well, I wouldn't have notes of the closed session. I wasn't in the closed session.
>> Okay. If I scroll down to uh another backwards one.
Now if I scroll down here, it says right here close session discuss performance.
Right.
>> Right.
>> And then there's something about I don't know 10K and then two surveys.
Right.
>> Yes. Yeah.
>> Okay. And if I go down to uh three, well actually right here at the bottom of uh page uh 3910, it says, do you know what this says here?
>> Something about the firm search.
Okay. Does it say Joanne right here?
>> You know, according to my writing, it would look more like Judith, but I don't >> Okay.
>> Who the >> That's That's fine. That's fine. And then when I go down here, um on page, uh 3911.
>> Sure.
Uh what the first one I have highlighted next to what does that say?
>> There's been turnover in the board.
>> Okay. And the next one down >> like and I think what they were referring to is historically over you know the last you know number of boards you know um over the last maybe 10 years or so something like that.
>> Okay. And the next one down it says Mr. Peterson interim very woke, right?
>> I don't know that that says woke. I don't really know what that says.
It does it say short?
>> I don't think he's that short.
>> I don't believe this is woke. I'm >> about remembering exactly what it says.
>> Okay. But it says something about Mr. Peterson interim very something that we can't make out, right?
>> Yes. Yeah.
>> Okay. And then if I go down to page 3912 here, um does it say here different principle comes to super part-time something like that.
>> Or is that to support like a shortand for support part-time?
I don't know.
>> I'm not remembering exactly my note.
>> Okay. And then if we go down here, does it say uh uh Jeff has a good handle on the principal job? Is that right?
>> Yes. Yeah.
>> Okay. So, that's something that's something somebody was saying at the school board, right?
>> Yes. during that the open portion of the meeting. Yeah.
>> Okay. And um are you able to here it says high emotions right on this uh >> about right here. Okay.
>> Yeah.
>> And does this say uh what does this say right here? What does that part say?
Well, not long ago. August. Not long ago.
>> It says believe August. Not long ago, right?
>> I don't know if that's believe or not.
>> Okay.
>> I'm not remembering exactly what that >> All right. So, I'm going to um pull up uh an exhibit that's previously been entered in and is marked as uh exhibit C29 here.
>> And >> okay, the previous discussion was all concerning C73, correct? Should we move that?
>> Yeah, let's move that into evidence, please. Thank you.
>> No objection. So C73 Bates one C156 uh the pages were 3907 through 3914 I believe is admitted.
>> Okay. And actually I opened up uh the wrong one. So let me go back and it's going to be exhibit 29 but it's my 09. Well this this is the this what I'm opening up now is the exhibit previously admitted as C29.
>> Okay.
And Mr. Binhack, are these the notes of the um >> You mean minutes?
>> The minutes. Thank you, Lori. Are these the minutes of the uh board meeting that you were at?
>> I believe so. Yes.
>> These are the ones you took note notes on.
>> Yes.
>> And so it looks like there was a time for community comment when you uh expressed support for the board to save money and end the search. Correct.
>> Yes.
And uh that was something you had talked about at the retreat you said, right?
>> Uh no, >> it wasn't.
>> No, we really didn't talk about that at the retreat.
>> Okay.
>> And then there was >> I don't remember talking about that at the retreat uh you know the the search or um other candidates or anything like that.
>> Okay. So you um did you stay for the entire schoolboard meeting?
>> I'm sorry. Which one? The one of for the minutes or the s or the retreat?
>> Yes. Thank you. The the one that the minutes are up for right now. This entire this entire schoolboard meeting right here.
>> Well, I don't recall exactly. I would I would think so. Although if they go into close session sometimes I leave, you know, I just I don't recall.
So nothing in your notes there were things that were discussed in closed session. Is that right?
>> Correct. Yeah, I wasn't in the closed session. Okay.
>> Did you ever get any recordings of closed sessions?
>> No.
No, I don't believe I ever got recordings of closed sessions.
>> Um I'm going to go to uh my exhibit C.
Uh 150.
>> This will be a new one, Wes.
>> This will be a new one. Page 94.
>> C1 150. Page 94.
>> And I think it's large enough if we all agree. Now, um, >> give me a short description for this >> description. This is notes between Keller and Vinhack on January 5th, 2023.
Okay. Thanks.
>> All right. Uh, Mr. Benac, do you see the top line of this? It says Gwen Keller 15203.
>> Yes.
>> Are these notes you took of a conversation you had with her on that day?
>> Yes.
>> So, >> um, now it says here uh on the right.
Well, actually, um, does this this first this first part here, does this say, uh, >> user forum?
>> User forum, superintendent search.
>> Yes. Yeah. January 26th to the 27th focus group.
>> Has focus groups, right? And you have uh underneath it a few like like teachers, right?
And you it says two groups. Is that correct?
>> I believe so.
>> Then underneath that it says staff.
It says community survey.
And then underneath underneath that, do you see this part right here?
>> Yes.
>> Does that say Garvey list of 8 to 10?
>> It seems to. Yeah.
>> Okay. And are these rec these are these names those eight to 10 names?
>> You know I don't really recall.
>> Can you make out any of can you make out any of these names?
Harry, Joe, Rose, Keith.
Yeah, that's about >> So, did you have a discussion with Gwen Keller on the phone where you talked about how to choose focus groups for the um HYA superintendent search? I'm going >> object to the form of that question.
What can you be more What don't you like about it?
>> Because it assumes that they were choosing focus groups, which they persons for focus groups, which they weren't.
>> Well, um, >> you want do you want to just break it down maybe uh into several questions?
>> I I could do that. Is this a conversation you had about focus groups?
Uh well, I believe that it was um uh Gwen telling me about it rather than, you know, us making a decision. I I certainly wasn't making a decision, you know, about the uh the superintendent search and all that. She was just telling me what's going on.
>> So, she was calling you and she was giving you a list of names.
Well, I think this is in her mind. She's, you know, planning it out. Um, but I don't remember, uh, you know, making decisions with her or anything like that. I mean, uh, I remember her just, you know, telling me what's going on.
Yeah. Um, >> I'd like to move uh exhibit uh C150, page 94 into the record, please.
>> No objection.
>> Okay. C74, Bates 150 is received in evidence. Okay.
>> Thank you, your honor. And um now I'd like to move on to uh my C156 pages 3,82 through 3,888.
And this will be Art Binhack emails with Carrie Morgan with records received.
Mr. Bin Mr. Binhack, is this um an email where uh the school was providing you with the records that you had received from Mr. Binhack or from uh that you requested? Sorry.
>> Yes. Yeah. One of two.
>> Yep. And this is done back on October 18th of 2023, right?
>> Correct.
>> Okay. And then in March of 2024, you had gotten another batch of files, right? We were talking about earlier, right?
>> If that's the right date. Yes. Yeah.
>> Okay. Okay. And um now, so there's one of two. And it says um and then you do you go on to forward this to Carrie Morgan?
>> Yes, I believe so.
>> And you blind copied yourself on it >> the next day.
>> Yep. and it's uh you forwarded the next day on October 19th, 2023.
And um he's told her there are two PDFs.
Now, here's what I really want to get at here. Underneath this is Jeff's personnel file, right?
You agree to that?
>> Well, I'm going to object to the form. I think he can agree to what he received.
I don't think he can authenticate the document as >> Pearson's personnel file, but you can fix it by I'm going to withdraw. Is this what you received from Patty Hoppus as Peterson's personnel file?
>> Yes.
>> Okay. And I'm just going to keep scrolling. I'm going to keep scrolling through it.
And this still looks like Peterson's personnel file, right?
Again, I won't object if you ask him if these are the documents he received.
Again, I don't think he can testify.
This is Peterson's personnel file.
>> Yes, >> which was your question.
>> These are the documents you received from the school when you requested Peterson's personnel file. Correct.
>> These are the documents I received.
Yeah.
>> Okay. And so I'm just going to go >> I mean it was up to the it was up to the school to provide me you know with uh you know uh non >> that's and that's an explanation that that's I see think superfluous. He's just interested in what was sent to you.
>> Okay. Okay. Thank you judge. I'm sorry.
>> That's all right. And so I'm going to keep going through and like you know some things are of course blotted out like a social security redacted and we're just going to keep going through and so this goes all the way on.
We're still his personnel file. Correct.
>> Again I'm sorry. I'm gonna fix that before you say anything. Lori, this is still what you received when you requested his personnel file, right?
This is what I received.
>> Yep.
>> And this is the end of part one, right?
So, this is the end of part one. And that's page 3,888.
Um, and we'll just say that the size of this personnel file is about 85 to 86 pages.
Agreed? Because this runs from PDF 382 to 388. And there's also the email first page in there. Is that right?
>> Again, Wes, you want to revise that question to be what he received?
>> Yes. Yes, we agree that what you received was about >> Mhm. Yeah. This is what I received. I did not, you know, count the pages or anything.
>> Okay. And then I'm going to go to um well, first I'm going to move to have uh this admitted as exhibit number C75, please.
>> No objection.
>> C75, page C156 is admitted.
>> Okay. And now I'm going to go to 3,694 through 3,81.
There's the next page grouping of C156.
And is this a part two of the of of the response that the school sent you when you requested Mr. Peterson's personnel file?
>> It appears to be.
>> And you forward that to Carrie Morgan on the same day, correct? Well, you forwarded it the day after you got it, but the same day as you forwarded the other one, right?
>> Yes, it appears to be. Yeah.
>> What's the What do you want to call this as a shorthand description, council?
We'll call it uh Peterson personnel file part two of two or no we we'll call it we I mean it's just shortand but we can call it we can call it binhack o r receipt part two of two if that's now um again we're going to do the same thing we did last time so bear with me here. So again, here's what they refer to as part two of his of his personnel file and they sent you uh correct and the records you received, right? and we're going to go down and you just tell me if at any point you have any reason to disagree with that.
And I see there's a lot of like nice little notes about Jeff and some positive comments and pictures with students.
>> Is that correct?
Is that you remember receiving that?
Yeah. A lot of nice stuff.
>> Um we'll keep going down. There's a few letters from uh parents in here that are um saying Jeff was doing a good job. Do you remember that? Remember seeing those?
>> Uh yes. Yeah.
>> Okay. Yeah.
>> I didn't uh read the file in detail. I was pretty much, you know, thumbming through through it. So, >> but you remember seeing those things, right?
>> Yeah.
>> What they sent?
>> Yes. Yeah. Yeah.
>> A lot of a lot of positive things in here.
>> Yes.
>> Um and there was uh let's see some articles about him that were positive.
There were some emails from other school districts that were positive about stuff you did with them. Right. Is that correct?
>> Yes.
>> And I'm just going to keep going through again. Some more positive nice notes here, right?
>> Yes.
>> Okay.
And background check.
Again, as I'm going through this, all you have to do is if you see something that seems like it's not the personnel file, all you got to do is is is let me know.
Okay.
Yeah, I I don't really know uh if I know this um what I received from the school that well to be to tell you what >> no >> that it wasn't part of it in there. I mean I I don't think I studied it that in that detail to >> I understand the only reason I want to put this um I'm going through this arduous task with you is because I I I want to just kind of get this into the record. And so can we agree that those pages I showed you were were what you received from the school when you requested Peterson's personnel file both one and two.
>> They seem to be >> okay. I would like to to move to have um that admitted into evidence as uh C76 please.
>> No objection.
C76 Bates C156 is admitted and then um I'm going to go to uh my C154 and this is going to be page 39 to 42. Okay.
And are these texts between you and Carrie Morgan?
It it appears to be so.
>> And um and is this her uh saying that um this you telling her that you got the foyer request and you forward them to her, >> right?
>> Yes, it appears to be that.
>> Yes.
>> And you tell her the >> And it appears that I did count them. So I stand corrected.
>> Okay. Great. Great. Great. So you counted the pages.
>> I guess you count.
>> I mean there's numbers there. I I I don't remember counting them, but >> Okay. Well, we don't have to worry about that right now. What I'm worried about just is what is what is on the screen and whether you can confirm that you sent this text. Okay.
>> Sure.
>> So, this is a text you sent to Carrie Morgan and uh it says uh that the first part of the the first PDF is 86 pages and the second is 107 pages long. Does that sound about right?
>> Yep.
>> Sure. Feels like that's how many times I clicked.
And now she says to you back, she says, "Okay, thanks. I'll take a look and let you know what I find." Did you share with anyone else? And you say, "No, I have not." Is that correct?
>> Correct.
>> Okay.
So then on the next page here, um, excuse me one second.
We're going to keep We're going to get We're going to get on two pages actually.
Okay. Yes. I'm sorry. We're going to go to the final page of this one. And do you see here this Carrie Morgan texting you?
And this is she states uh I was able to pull all pages related to discipline and lack to do his job and attach them in a sheet in front with bullet points for all 36 pages. Do you see that?
>> Yes.
>> And do you see it says uh I'm going to put it on a thumb drive and hand it to a few people to send out?
>> Yes.
>> And she says I'll email it to you.
>> Yes.
>> Okay. And um I would like to have uh this admitted into as exhibit number 077 or sorry C77 please.
>> No objection.
>> And um I want to make sure that this was uh >> I think you said pages 39 to 42.
>> That's what he said.
>> Is that what you showed him with?
>> Um yeah I did show him 42. I but I think I actually need to do a 39 to 42. Yep.
>> That's That's what >> Oh, sorry. I need >> I need to go.
Ah, >> sorry. There are two more pages I didn't >> Hey, >> include. So, I'm what I'm going to do.
I'm going to go through these with you and I'm going to make sure that you you can attest that these are all my faults.
My numbering was a little messed up. So, we started up here on page uh 39 of the PDF. All right. Text between you and Carrie Morgan, right?
>> Yep.
>> Text between you and Carrie Morgan, right?
>> Yes.
>> Text between you and Carrie Morgan, right?
>> Yes.
>> Text between you and Carrie Morgan, right?
>> Yes.
>> Text between you and Carrie Morgan, right?
>> Yes.
>> Text between you and Carrie Morgan, right?
>> Yes.
text between you and Carrie Morgan.
Right.
>> Correct.
>> Okay. And I think we actually got the other one down on here. So, I think we're good. So, I'd like to have that be uh 39 to 45, please, entered in as exhibit number 077 >> or 77.
>> C77. Bates C154, pages 39 through 45.
Any objections, council?
>> No objection.
>> Okay. So, that exhibit C77, as I just described it, is admitted.
>> All right. And now I'm going to bring in my um C155 pages 1 through 8.
Now, uh Mr. Binhack, if you look at the top here, actually, let me go ahead and make it a little bit larger for us here.
>> Thank you. Give me a short hand description council for that.
>> Yes. Yes, your honor. This would be um a conversation between Art Binhack and Joanne Keknney.
>> Okay. Uh and can you >> K O E N E C K E?
>> I know I've seen that, but I it's helpful to have somebody spell it out for me. Thank you.
>> Absolutely. And Mr. Mr. MC, can you confirm that this is a Joanne Keen and a conversation with No, strike that been saying a lot. Can you please confirm that that these are notes of a conversation you had with Joan Keen?
>> Yes. Yes.
>> Okay. And um now >> that that first dot it is more of a general statement she made to me as I remember >> uh specifically with uh Raymond school or anything.
>> Okay. And what does that statement say?
>> I'm the one to get the info uh to the media.
>> Okay. And >> and Okay. And it says, it says foyer, right?
>> No, I don't.
>> Oh, sorry. Over here on the >> says mom's for liberty.
>> Yep. Okay. Um, right here though. Do you see where it says fo ya?
>> Right.
>> Yeah. And I think I think I've I've seen you spell foy freedom of information act fa a few times. Remember?
>> Yes. Exactly. Yeah. Sorry. But I mean um I don't well I don't remember her. Well, yeah.
Okay.
>> Okay. And um now what is uh what does this part say right here? Does this say zip drive right here?
I'm going to make that one a little bit larger for you.
>> Maybe. So, yeah, maybe it does say zip drive.
>> Do you think so? I mean, it looks like it's me. Can you confirm that?
>> Something like that. Yeah, >> that would be my >> my guess. Yeah. Okay. Okay. And um I'm then make it a little smaller now so we can keep moving through. Um now on a page now I'm going to go down and these this is a page two a continuation of your notes with Joanne, right?
>> Yes.
>> Okay. And um page three, this is a continuation of your notes with Joanne. Is that right?
Or no, I'm sorry. This is a it says VM >> voicemail.
>> Ah voicemail.
uh October 29th, 2023.
And uh it says, what's the first line that there reads here? Can you just read that to me?
>> New message today, 10 o'clock 10:01.
>> Anyone name?
>> Wayne Keller.
>> Wayne Keller. Okay. And we're going to keep going down a little bit.
And um now, >> what does it say? Save.
you cut out, sir.
>> Oh, I said, what does this say right here under the four? The first line here on four. There's two dots in here. I'm going to take out so you don't get confused there. I just put those for me to be able to go through them more quickly. It looks like I wrote saw Wednesday, October 25th at uh 10:56 a.m.
So I I attended a meeting of the Mom's for uh Liberty. Um I don't know if that was the date though or anything. So okay.
>> And now does this next one say open records request?
>> Yes. And it has a phone number underneath it, right?
>> Yes.
>> You can confirm this phone number is 2623323462.
>> Yes. Yeah. Yeah. It looks like that.
>> And this part here was does it say wanted info about it to be sure about it?
>> It looks like it says that. Yes.
>> And actually, we'll start two lines up from that. It says open records request and has a phone number and it said wanted info about it to be sure about it. Is that right?
>> I believe so. Yes.
>> Okay. And do you know if um you were talking about a reporter named uh Jason Calvie who was trying to confirm some records he had received.
>> The name doesn't ring a bell.
>> No. Do you remember uh who who it was that wanted more info about it?
>> No, I don't I don't recall.
>> Um and now down here, does this uh say Missy Moms for Liberty?
>> Yes.
>> Okay.
And this is dated now November 1st, 2023, right? Page one.
>> Yes.
>> Okay. And um right here, the next one I've highlighted, does it say Peterson's boyfriend?
>> Yes.
>> Okay.
Um and then the next one down, does it say Google guy's name in Peterson's file?
I believe it does.
>> Then down below it says Peter and it cut short. Are you still talking about Jeff Peterson here, you think?
>> You know, I don't know. I don't know. I don't remember um googling anybody um the guy's name in Mr. Peterson's file.
>> Maybe it was something that was being discussed where you were, right?
I mean, that's what it says, right? We agree. It says Google guy's name in Peterson's file, right?
>> Yeah. Okay. It does. Yeah.
>> Okay. So, it was a conversation you were having with somebody, right?
>> Yes. Yeah.
>> And Joanne Kickin is up here too, as well as Gwen Keller's name in this file, right? So, do you know which one of them you're talking to? If if there >> if you scroll up or scroll down, I would uh I think you went too far, sir.
>> You meant scroll up.
>> Scroll up.
>> Scroll up. Okay.
>> Yeah, I I think that that is uh when I was talking with uh Joanne.
>> Okay. And then we go down here though and we see um uh Oh, say sorry. It says Peter and you said you're not sure if you're talking about Peterson or not, right?
>> Correct. Yeah.
>> But then below that it says EOC and then something. Oh, >> and then complaint. Do you see that?
>> Yes.
>> Okay. And then does it say uh send the complaint to Joanne?
Oh, sorry.
It's right here. This part >> it does.
>> Okay. All right. And we're going to go down to page five here.
And now up here, right here, does this say Amanda?
>> I believe so.
>> Do you think this is a conversation you're having with Amanda Felashi or about Amanda Felashi?
>> No.
If you scroll up to the top, >> the top of this page, you still think this under a conversation with Joanne then, right?
>> I believe it looks that way to me.
>> Okay. Okay. Yeah. Great. No, I appreciate the clarity. So, Joanne Kekney uh November 1st, 2023, page one, and then we have page two, right?
And then, um down on page five, um it says Amanda Joe Felashi, right?
>> Okay. Yeah.
>> And then it says then there's a hyphen between Joe Falashi and group, right?
Yes.
>> Then Facebook.
Sorry. Sorry about the clicking. I'm trying not to highlight everything. Um and uh now do you know about a Facebook page called The Raven?
>> You know what? No, I don't.
>> Do you know if uh this is a discussion about Joe Feli starting a Facebook page?
No, I don't believe No, I I don't remember. I really don't remember talking to Joanne about um Joe Flashy and uh Facebook page.
>> All right. And this dot right here, uh I'm just gonna Does this say Soros money backing Peterson group or something like that?
>> That's what it says. Yeah.
>> Okay. Did someone tell you that?
>> You know, I don't know. I don't remember.
>> Okay.
And um >> who would who would that be? Soros money.
Would Soros be?
>> I'm assuming that's George Soros.
Okay.
And um then right down here where I just removed the highlight, I believe that says uh well actually tell me what this says here.
I'll take off the highlight.
Peterson. Uh CCAP relies on something municipality >> city >> city of Kosha maybe I don't know >> okay but we can agree it says Peterson CCAP relies on municipality right >> I believe so yeah >> okay now there's also um up here in the top right it's also talks about Peterson a little bit. I'm going to take off that highlight. So, in this little in this little area you have triangled off, it says Peterson and then uh down below it says personnel file, right?
>> Yes. Yeah.
>> And it says Louie. Do you know what Louie stands for?
>> No.
>> You ever heard that referred to as a as an a shortand for Luden lascivious uh citation?
>> No.
>> Okay. And then below that it says attempted theft in 1997. Do you see that?
>> Yes. Yeah.
>> Were you discussing like the negative things you could find in Jeff Peterson's personnel file?
>> It appears that way, but I don't really remember that.
I think I think part of it was that was a long time ago, 1997.
You know, people change. You know, >> people are different when they're younger.
>> Yeah. But that I mean that wasn't a a charge that he had. Do you remember? I mean you read his you read his personal file. You read his rap sheet. That wasn't a charge he had. Right. That wasn't something he was convicted of rather.
>> You know I don't remember. I >> that that was multiple questions in fairness to the witness. Can you ask him one question?
>> Sure. Sure. Do you know if that was something that he was convicted of actually?
>> No, I don't.
>> Okay. Okay. Okay.
Um, and then we're going to wrap up pretty soon here. So, we're going to go down to page uh to the final page of this one. And this again is Joanne uh Kickin, right?
You see that?
>> Yeah.
>> And uh we see uh we see a date here, November 15, 2023, right?
>> Yes.
>> Okay. And it has a quite a bit we talk about here. And um but down here, this part that I've highlighted off in this section, does this part here say Gwen at the top?
>> Yes.
>> Does it say Mom's for Liberty underneath it?
>> Yes.
>> Does it say COS underneath that?
>> Yes.
>> Is that Convention of States?
>> I would I would imagine so.
>> And does it say underneath that watch what she can say don't talk to? And I can make that big for you.
You see that right there?
>> Yes.
>> Does that say watch what she can say, don't talk to?
>> It appears to say that. Yeah.
>> Okay. Uh, was Gwen also asking to to be kept in the background of certain conversations?
>> No, I don't I don't ever remember anything like that.
>> Did Joanne tell you to keep Gwen in the background?
No, I don't remember.
>> I don't remember really other than Carrie that appearing, but I I really don't remember any discussions that way.
Uh >> do you I'll change it. Do you remember why you wrote uh Gwen, watch what she could say, don't talk to?
>> No, I don't.
>> All right. I'm going to move to enter that in as an exhibit uh number 78. And again that's uh C5 page 1 through8.
>> No objection.
>> Okay. C exhibit C78 page C 155 is receive the record.
>> Okay. And um now I'm going to move on to uh C54.
Oopsie.
B154. And we got page 4,000 and 68 to 4,069.
Now, is this a uh email from Carrie Morgan to yourself?
>> Yes, it appears to be.
>> Does she say share with whomever you deem appropriate receive from a parent group today?
>> That's what's that's what's typed there.
Yeah.
>> Okay. And the next page, is this uh the attachment that was in there?
>> It appears to be.
>> Okay. And is this uh about address to all Raymond residents. Again, >> that's what it says.
>> And is this is this similar to any of the other documents that I uh showed you before that you recall?
I'll tell you what'll make this easy.
Strate that question.
So this this document here well first let's move this into be being entered in. This is a C54 pages 468 to 469.
The short title of it is a is Morgan email to Binhack parent group.
And then what I would like to do is go back to an exhibit that I've previously introduced as exhibit 63.
>> Are we moving C79 in?
>> Oh, yes. Yes. Yes. I I didn't get a chance for objection. I'm sorry, guys.
>> Okay. I I just want to make sure I understand what you've just done, which is fine. 4 468 to 469 is the email we see up on our screen as well as the attachment or the I'm sorry the document that is after that you showed the witness >> correct >> okay is that only one page Wes that meaning the attachment or is it two >> Yeah the the attachment's only one page >> okay >> only one page >> could I just ask the witness is Art is that the document that was attached to the email that he showed you from the first page.
>> Um, it appears to be >> okay. I don't object to the introduction of exhibit C79.
>> C79 dates C154 is admitted.
>> And and and now, Mr. Binhack, you remember that when I um after you gave me all this discovery, I asked you for specific files with metadata on them, right? And this was one of them, right?
>> Okay. So, so you're you're pretty familiar with this particular documents because I've asked you for it in two different versions, right?
Strike that question. Strike that question.
>> I wouldn't >> strike that question. That's pointless.
Um, so what I want to do is I want to pull up um an exhibit now uh we got that entered in, right?
>> Yes.
>> Okay. I want to pull up now an exhibit uh that we have previously answered is 63. And just to make things easier, this is still within C154 and it's PDF page 63.
Now I'm confused. Are you saying >> PDF page 126?
>> Are you saying this was a previously introduced exhibit?
>> Yes. And it's in the same PDF.
>> Ju just what what com what exhibit hearing exhibit number?
>> You said C60. Are you referring to to your Bates to the Bates number or to the hearing exhibit number? Because uh >> this is hearing exhibit number 63.
>> Thank you.
hearing exhibit number wait I didn't hear the number I'm sorry >> 63 >> so complaintant 63 >> correct >> let me just check my I want to see if I have that logged in if I don't have it up I'm not going to pause this very long but I thought the email between Morgan and Benhack 92623 page 126.
>> That is correct.
>> Okay, proceed.
>> Mr. Binhack, we talked about this email before. This was sent on September 26, 2023 at 3:55 p.m., right?
>> Yes.
>> And this is addressed uh to you from Carrie Morgan.
>> I I believe that I received a 355. I don't know when it was sent.
>> Okay.
>> Probably shortly before that.
>> Okay. And then is this is the attachment to that, right?
It appears to be >> and it's the same letter but it's uh two pages long so maybe it's a little bit different but it's also to taxpayers and do you agree it looks nearly identical to the one we just saw?
>> Uh there are similarities.
>> Okay. And then when I go uh now I'm going to go back to the exhibit we entered in as 79 C79.
And here's uh the first email. The second this this email came after, right? This email came at 6:55 p.m. The one we just said came at around, you know, sometime between 3 and 4 p.m. Right.
>> Yes.
>> And it's the same attachment, right?
roughly except this one's a page long.
The other one's two pages long. There may be some small differences, right?
>> It's got a different name for the file.
>> Different name. And in this one though, this is the second one she sent you, but she says she received it from a parent group today, >> right?
>> That's what it says. Yes.
>> And that's in a PDF form. And when she sent it to you in the Word form, did you make any changes to it? send it back to her.
>> No, I don't I don't remember doing anything like that.
>> Okay, Mr. Bennack, you've been here for a long time today. You've been really helpful. You've given me thousands of pages of notes to go through and I really needed to make sense of some of them. So, I appreciate your time and effort and I will um end my my my questioning.
>> Okay.
Uh let's just talk about where we are right now and the rest just planning the rest of the day. Um is this a time where you'd like to take lunch or do you want to postpone lunch for a while yet?
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