M_ Rebecca Downing v York Co_ D_A. H.

Stanley Rebert Randy Rizzu'Co

Page 35 Page 37
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1 Q And when you did that were you I 1 were in the D.A.'s office?
2 worbng on the clock, so to speak? 2 A No, I don't recall.
3 A Yes. 3 Q Do you recall any point in time when
4 Q And how many occasions did this 4 Bob Leichliter may have removed the signs from
5 occur? 5 the office?
6 A Three or four times. I meaI'", it was 6 A Yes.
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7 very infrequent 7 Q Do you remember the circumsTanCeS in t
Q And whose county vehicle were you which that occurred?
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9 using?
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9 A No, other than they were taken out II~
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~ v p~ It vias Stan's vehicle. ilO the back door.
Q And where were you going? Was it to Q Do you recal1 --
11 : 11
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12 an airport, a train station? 112 A I think they were going to have a --

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A Train station in Lancaster.

Q P.uT].G hovv far approxim:1tely did you
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114
rmsorry.
Q t~o, go ~head.
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have to travel? !
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1 t:; .LA. I think they "\"X/ere going to have a I;'
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A About 30 miles. I don't know how l16 get-together later that evening; they meaning a I,~
far. j "7 group of people that were going to put the signs
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n'< Each'l.;ay? !
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out. But I don't know who they were ot.l.er that" 1;1
A
Yes. It would be an hour.
Q i~'ilid you
didn't put in for vacation
119
120 ;::~~~~t~O:B:~~cl:;=~~!~~' of
time or anything like that? ,i2l Q So the purpose then was to assemble
22 A No. 122 for something that would occur after work?
23 Q Did Miss Downing -- Or did you ever 123 A Yes, um-hm.
24 ask Miss Downing if she would travel in your 124
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Q In regard to the personal favors, do
place to the Lancaster train station to -- 1
25 you recal1lYIiss Downing ever telling Stan that I~
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A I don't think so.
Q Do you know if any other employees of i 2
I1 this is not a good practice, a proper practice
for the D.A.'s office?
3 the D.A.'s office performed the transportation I 3 A Several times.
4 for family members of Mr. Rebert? !4 Q And what was Stan's reaction?
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AQ Not that I'm aware of.
How about Mr. Ingle?
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A I don't know.
Q You don't --
7 A Well, yeah, he had. I mean -- Ij 7 A I wasn't there. I just -- You know,
8 Q How often? I, 8 Becky would say, he wants me to do this and I'm
9 A I don't know. . 9 not doing it. I'm like, okay.
10 Q Vlere you ever asked by Ivlr. Rebert to 110 Q I guess--
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11 go to his residence during business hours to 1 11 A I don't know ifhe ever -- I don't
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12 perform any types of errands, pick up food, or 112 think he ever pressured her into doing anything.
13 anything of that nature? 113 I mean, it was --
14 A No. 114 Q But she told him the practice should
Q I believe we previously discussed N1r. i 15
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15 stop?
16 Rebert's re-election c a m p a i g n . ! 16 A Yes.
17 A Um-hm. 117 Q Did the practice stop?
18 Q Mere were those signs, the 11
8 A Yes.
19 campaign -- the yard signs that we discussed -- ! 19 Q At what point, because you said
20 A Right 120 several times? So it took several times before
21 Q -- where were those located within i21 the process stopped?
22 the D.A.'S office? 122 A Well, you know, it would depend. You
23 A In his office. I
23 know, like doing the election stuff was one of
24 Q Okay. Do you recall Sheriff Hose ! 24 them. I don't really recall specifics because I
25 making a complaint about the fact that the signs 25 I just don't recall.

Key Reporters 717.764.7801 keyreporters@suscorn.net

Pages 35 to 38
 M. Rebecca Downing v York Co. D.A. H. Stanley Rebert Randy Rizzuto

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Page 39! Page 41
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1 Q Okay. But do you recall Miss Downing I 1 your counsel is finished, I'm going to ask you
2 saying, you should not be doing your re-election I 2 if you can identify the document that you're
3 activities in the office, or something -- I 3 looking at?
4 A Yeah. I 4 A Um-hm, yes.
5
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Q -- to that effect?
A Yes, um-hm. I
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Q And what is that document?
A I guess it's a --
7 Q j·\.gain \ve're steppiL"l.g on each ot.~er. 7 Q If you know.
8 As far as the personal errands, at 8 A Yeab. Obviously, Mike Barley talked
9 some point you remember Miss Downing telling 9 I to Stan and Stan probably asked him to fax it in
10 Stan, hey, people should not be doiIlg personal 110 with the information. And t.~en I remember Stan
I 11 errands for you duriTJ.g the normal business 11 ! asking Bec10j to check it out, and she said no.
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12 hours? Do you recall something to that effect? 112
A No. i 13
Q And what was the reason why she said
no, if you recall?
/14 Q But just sometbiTJ.g t..hat t..he personal 114 J.A~ \A/ell, I don't recall vvhy she said she
115 errands should stop? 15 ! couldn't do it. I know the reason why it wasn't
/1 6 A Right. I 16 done. Because if it's not an investigation, you
I17 Q Do you recall if Miss Downing ever !17 know, then we're not supposed to do that.
11 8 told Stan that, hey, count"j vehicles shouldn't 118 Q P..u.'1d ho\v did you lmovv that?
' 19 be used to transport family members? 119 A Because -- About what?
/20 A No, I don't know that. i20 Q That if it's not an investigation,
I21 Q Do you recall receiving a fax from 21 I this type of information should not be --
22 Mike Barley in regard to Jennifer Ceurran, ! 22 A Because Tammy told me several times,
23 C-E-U-R-R-A-N? 123 you know, I mean, this is -- That's what I was
24 A I remember seeing it. 24 ! told. That it's illegal to get any information
25 Q Was that a fax that you would have 25 ! from CLEAr,]" or NCIC unless it's an investigation.
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Q Okay. And Tammy told you this. Do
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1 received?
2 A I didn't know -- I don't know if it you remember when Tammy told you this?
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3 was faxed or if Stan brought the paper in. I A No. It's probably, you know, just
4 don't recall -- I thought it was on a piece of 4 when I first came on board and, you know, just
5 paper. I don't know if it was faxed. 5 certain things.
6 Q Okay. So you don't know if this came 6 Q So it was early on in your career

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7 in on the D.A's office fax, correct? with the D.A.'s office?
8 A No. A Yeah.
9 Q When I say this, I apologize. I'm 9 Q And approximately when did you start
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10 looking at -- You don't lr.now if the fa'\. from 1 ~
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with the D.A.'s office?
11 Barley came in on the district attorney's office ill A September 2nd, 1998.
12 fa>:; is that correct? 112 Q So from around sometime in '98, you
13 A I don't know if that piece of paper 113 knew that it would be improper, or as you say --
14 came in faxed. That's what I mean. 114 A Yes.
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15 Q I'm going to show your counsel, it's lIS Q -- illegal to obtain this type of --
16 been redacted in regard to a date of birth and 116 A Yes.
17 Social Security number. But I'm going to show 117
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Q Let me finish. -- to obtain this
18 you what's already made a part of the record, so 118
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type of information unless it was tied to a
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19 it doesn't need to -- 1.1.:1 criminal investigation?
20 A Um-hm. \20 A Yes.
21 Q -- be an exhibit here. I2 1
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Q Do you know if Stan ever knew that?
22 A Oh, okay, so it was faxed. l 22 A Well, I would think so.
23 Q Let me just, so I can make it clear I 23 Q You said that you believe that Stan
24 on the record. It's Exhibit A to both the ! 24 spoke to 1vlr. Barley. Do you have firsthand
25 Complaint and the Amended Complaint. And once I 25 knowledge of that?

Key Reporters 717.764.7801 keyreporters@suscorn.net

Pages 39 to 42