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

LISA SCHWAGER May 29, 2013

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

Min-U-Script with Word Index

LISA SCHWAGER - May 29, 2013

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

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

DEPOSITION OF:

LISA SCHWAGER

May 29, 2013, at 3:05 p.m. 401 West Cedar Avenue, Gladwin, Michigan

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

LISA SCHWAGER - May 29, 2013

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

----------------------------------------------------------------EXHIBIT INDEX ----------------------------------------------------------------PAGE Schwager Exhibits: 1 - Board of Education Minutes 17

LISA SCHWAGER, having been first duly sworn, testified on her oath as follows:

LISA SCHWAGER - May 29, 2013

3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q A Q BY MR. HANSEN: Q A Would you state your name and address, please. Lisa Schwager, 410 South Antler Street, Gladwin, Michigan, 48624. And you're a member of the Gladwin School Board? Correct. And how long have you been a member? Since May of 2010, I believe. You know Mr. Caffrey here? Um-hum. Have you ever met him before? Before I was on the Board? Before today. Yes. We went to the same church, Sacred Heart Church. EXAMINATION

Have you had any conversations with him in the past two years? If it was like seeing him on the street or seeing him somewhere, maybe hi, how are you. than that. Have you had any conversations concerning school business or anything else of that nature? No. Do you have any fear of him? No.
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Probably nothing more

LISA SCHWAGER - May 29, 2013

4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A A Q A Q Q A Q A Q A A Q A Q Q Were you aware that a motion for protective order was being filed in this matter? Was I aware? Yes. I don't recall that, no. Now, on December 24th there was a special meeting of the Board of Education? Yes. Do you remember that meeting? I remember there being one, yes. The morning of, yes.

And what was the purpose of that meeting? If I recall correctly, it was to approve some documents that we had to have in a time -- certain time frame. Okay. case? I believe so. And you went into closed session, is that right? Right. And the minutes indicate that you seconded the resolution to go into closed session. Do you recall doing that? And that had to do with some legal filings in this

I don't recall, but I'm pretty confident if the minutes said so, then -- then I more than likely did. But you don't have a specific memory of doing that. No. Who took the minutes that day, do you know?
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LISA SCHWAGER - May 29, 2013

5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q Q A Q A Q A Q A Q A I don't recall. Mr. Withrow? Mr. Withrow. And he takes the notes, is that right? Yes. Do you know what he does with those notes afterwards? No -- I mean, I -- I could say I assume what he -- I -- he does but I don't know for sure. Usually they go right to -Usually it's our secretary.

to Julie and then she types them up. She types them up, right? That's what I recall it as. Now, part of the minutes indicate that you resolved to authorize Mr. Wallace to represent you and to pursue certain counterclaims, is that right? I don't recall. What does it say -It's down there towards

Here, I'll show you the minutes. the bottom. Um-hum. Okay.

So, by that resolution, you were authorizing Mr. Wallace to file a counterclaim on your behalf against Mr. Caffrey, is that right? Against these case numbers, correct. Right. Um-hum. And prior to the meeting did you read the counterclaim?
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LISA SCHWAGER - May 29, 2013

6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A session. Q A A Q A Q I don't recall. After the meeting did you do so? I don't recall. Prior to voting do you recall ever having read the counterclaim? We -- we usually do read them when we come to the meeting. We have a certain time frame where we can read over, um-hum. And did that happen in this meeting, do you recall? MR. WALLACE: I'm going to object. There's no

discussion about what happened in the closed session. Don't answer that question. MR. HANSEN: Attorney/client privilege.

I'm not asking about the closed

I'm asking whether or not she had a time period to

read it before the closed session. I don't recall. Usually that's what we do, but I don't

specifically recall. Okay. Now, there's some language in there towards the end

that says "in any other matters" or something to that effect. there. "And any others as applicable", yes. What does that refer to? Any other matters concerning these two case numbers. Okay. that.
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Do you see that?

It's at the end of the resolution

It's not some other lawsuits or anything else like

LISA SCHWAGER - May 29, 2013

7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q A Q A Q A Q A Q A Q Q A Some other lawsuit? No; it should be right to those two,

"and any others as applicable". Now, when the first lawsuit was filed in this matter, that concerned the FOIA requests for phone bills and details and that type of thing, do you recall that? I do recall something about them, yes. The Board never met concerning that, did it? I don't recall. Okay. Do you recall having any deliberations whatsoever

concerning that lawsuit? As a Board? Yes. I don't recall. Did you have any conversations with any Board members or Mr. Seebeck concerning that case? I don't recall. Did the Board ever authorize Mr. Seebeck to notify the insurance company? Concerning? Defending that action, that first case. Did we ever -- repeat your question again. Did the Board ever vote to authorize Mr. Seebeck to contact the insurance company to provide a defense in that case? I don't recall. So you don't remember any conversations concerning that case
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LISA SCHWAGER - May 29, 2013

8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q Q A A Q Q A Q A Q whatsoever one way or another? Correct. Do you think it would be likely that there would have been discussions about that case? MR. WALLACE: Form and foundation and you're The question has been

asking the witness to speculate. asked and answered. You can answer. Repeat the question again, please. Well, you're being sued, okay? sued, okay?

The school system's being

You've already indicated that, in other

matters, you normally would read pleadings or something, you know, there would be a time for doing that. Um-hum. Do you think it would be likely in this case that you would have had conversations about this lawsuit? MR. WALLACE: Form and foundation. The question

has been asked and answered. You can answer. It would be likely that we did because we usually have that time frame. Okay. No. Now, in the counterclaim that you filed against Mr. Caffrey, you claim that he libeled you and slandered you.
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But you don't have any specific memory of it.

LISA SCHWAGER - May 29, 2013

9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A A Q A Q Q A Q A Q A Me personally? Yes. Well, I know that he has -- well, family members of his have. Yes. No. Did he make any false statements, oral statements, to any third parties that you are aware of? I don't recall. And did he make any written statements that were false statements about you to anybody? I don't recall that. You've also sued him for intentional infliction of mental distress, okay? And you claim that his conduct towards you He directly to me?

was extreme and outrageous and atrocious. What were you referring to? Well, I would believe that would be referring to all the FOIA requests, and, for instance, the one where I had to print any e-mails that I had between Mr. Seebeck and myself, which -- and I tend to keep everything, and it took me quite a few hours to print everything for a certain time frame that he wanted. or something. I believe it was like October to December But it

I'm not even sure of the exact dates.

took a lot of personal time. Okay. And people have a right to make FOIA requests?
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LISA SCHWAGER - May 29, 2013

10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q A Q A Q A Q A Q A Q A Q A Q Absolutely. Okay. So do you find that to be extreme and outrageous and

atrocious conduct, to ask for certain things? The number of FOIA requests is a bit extreme but -The one that I'm referring to -MR. WALLACE: I'm referring to -Well --- the one that you're talking about. It was a bit extreme, I felt, yes. And why was that extreme? MR. WALLACE: It wasn't a FOIA request, counsel. Please let her answer.

Please don't confuse the record. MR. HANSEN: I thought that's what she said. She

said that she was requested to turn over her e-mails. MR. WALLACE: It was a discovery request.

It was a discovery request? I was asked to turn over certain e-mails from a certain time frame, is what I'm referring to. By whom? It was a FOIA request that Mr. Seebeck had asked all of us Board members if we kept e-mails, any e-mails between the School, himself, which I do. Okay. So those are the ones that took me quite a number of hours
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I keep all my e-mails.

LISA SCHWAGER - May 29, 2013

11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A Q Q A Q to print and turn them in. But under the law he's entitled to those, correct? Correct. You just didn't like the fact that you had to put them all together, right? Well, it took a lot of time. I mean, that's why you were upset about it, the amount of time you had to spend, right? Correct. You've also accused him of willful and wanton misconduct. What are you referring to there? I don't recall. You've also accused him of abusing process in this case. What are you referring to there? MR. WALLACE: Form and foundation. That's a legal

term of art that you know relates to improperly filing multiple lawsuits. Do you know what you're referring to? MR. WALLACE: Go ahead and answer if you can, if

you understand the question. I don't understand your question. Well, you've sued him for abuse of process; you understand that. Um-hum. Yes?
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LISA SCHWAGER - May 29, 2013

12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q A Q Q Q A A A Q Yes. You have to answer yes so she can record it. And you've made certain allegations there, you know. What do you base these allegations on? I believe we're basing them on, just from the very beginning, all the number of FOIA requests and all the information that they're asking for, and then coming to the Board meetings and recording them, which I know is absolutely fine, they can do that, but that just seemed automatically to start, well, recently, the past few months. It's like why didn't they come a year ago and record, come to the Board meetings before all this even started? did. Sharman never did. Nobody

And so you don't -And that's what I don't understand. If they're interested

in coming now and recording, they should have been interested two years ago and recording. Well, there has to be a starting point sometime, doesn't there? (No response.) I mean, why not five years ago or ten years ago? Exactly, um-hum. Do you find that offensive, to have them recording the -No, no. Not at all.

On the 24th did you consider any legal written opinion?

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LISA SCHWAGER - May 29, 2013

13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A Q Q A Q A Q A A Q A Q A Q A Q I don't recall. And was Mr. Wallace there? It does not say he was there, no. Was any other attorney there? No. One of the things that's part of this lawsuit is FOIA requests and also Open Meetings Act requests concerning proposed minutes. Um-hum. Were you aware that there's a difference between proposed minutes and approved minutes? Yes. We get minutes; we have to approve them at the Board Do you understand that?

meeting, -Right. And for --

-- and they're draft until -I'm sorry? They're draft until we approve them. Okay. okay? Okay. And I'll refer to it as "draft", okay? Okay. Are you aware that the Open Meetings Act requires that draft minutes have to be provided eight working days after the meeting?
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Let's call "proposed" and "draft" the same things,

LISA SCHWAGER - May 29, 2013

14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q A A Q Q A Q A Q A Q No, I was not aware. You understand that's what this lawsuit is all about, is the failure to turn over these minutes according to the law. Correct. Do you find any problem with that? No. We've heard a lot of testimony about how the Board has never talked about that first lawsuit, never deliberated that first lawsuit or anything else. Is that actually true, that nobody ever talked about that lawsuit with each other or anything else? MR. WALLACE: multiple questions. Is it really true that nobody ever talked about that lawsuit? I don't recall if we did or not. Are there a lot of lawsuits against the school so this is one of so many that you're not aware of the contents of it? No; we may have a few lawsuits, but it's not something we spend day in and day out conversing amongst ourselves about. Well, would it be unreasonable for the Board to discuss the merits of the claim to decide how to resolve it? MR. WALLACE: Form and foundation. Form and foundation. You've asked

You can answer if you can. Okay, I -- I don't recall if we ever spent a lot of time
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LISA SCHWAGER - May 29, 2013

15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A A Q A Q A Q Q A Q A Q Q discussing this amongst ourselves. You could have discussed it; you just don't have specific recollection? Correct. I'm going to show you Seebeck Exhibit 2 and ask you to read Definitions B(1). Okay. Now, from your reading of that, the definition of "member" is the School District or the School Board, is that fair? MR. WALLACE: I'm going to object. The document Just read it to yourself.

speaks for itself and is as written. Is that your understanding? MR. WALLACE: Form and foundation.

Answer if you can, please. "Member means the School District" is what it says. Now, if you agreed -- on the next page or two pages from there, I believe it is, I guess it's three, there at the bottom of the Page 3 and then on the next page, I believe -is that 3 or 2, please? 3(a). Yes. Okay. So it's the member then that is supposed to notify the insurance company, is that right? "Written notice to the pool", what is "the pool" referring
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LISA SCHWAGER - May 29, 2013

16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 authority?
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to? Q A Q That's probably the insurance pool but -So what was your question again? The question is: It's the member that's supposed to do the

notifying, correct? MR. WALLACE: speaks for itself. A Q A Um-hum. That's a yes? Yes. "The member shall give immediate written notice to the Same objection, and the contract

pool of any claim made against a member." Q A Q And that would be the School District, right? Correct, I believe. Did the Board ever authorize Mr. Seebeck to notify the insurance company? A We had given him our okay years ago to -- to do what he felt was necessary, yes. Q A Q A Necessary on what? On behalf of the School concerning lawsuits. Do you recall when that was? No, I do not recall when. MR. WALLACE: that document. MR. HANSEN: The document that -- of the I don't have the document.

Also, I'd indicate that you have

LISA SCHWAGER - May 29, 2013

17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Q Q Q A A Q Q it. MR. HANSEN: Would you mark this. MR. WALLACE: MR. HANSEN: (indicating)? MR. WALLACE: I don't know. I just know you have Yes, sir. Is this the one you're referring to

(Schwager Exhibit 1 was marked by the reporter.) I'm showing you what's been marked as Schwager 1, which are the Board minutes of June 23rd of 2008. Drawing your attention to, I believe it's Page 3 of that document under Action Item J.2(c), is that what you're referring to? I'd have to read it. Sure. Sure. Have you had a chance to read that? Um-hum. It says that they approved SET SEG for the carrier I was not --

in the amount of 55,000. Okay. That's the document that was supplied to us by your

counsel -MR. WALLACE: There's other documents, counsel.

That's not the only document. Well, that particular provision, all that does is, it authorizes SET SEG to be your insurance company, correct? Yes, that's what that paragraph says. It doesn't authorize Mr. Seebeck to act on your behalf, does
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LISA SCHWAGER - May 29, 2013

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it? A Q This paragraph, no. Okay. Are you aware of any statements about Rick that have

been made by Mr. Caffrey to any other Board members? A I'm not aware. MR. HANSEN: That's all I have.

(Deposition concluded at or about 3:35 p.m.)

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

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

Caffrey vs. Gladwin Community Schools, et al.

LISA SCHWAGER May 29, 2013 definition (1) 15:8 Definitions (1) 15:6 deliberated (1) 14:8 deliberations (1) 7:9 Deposition (1) 18:7 details (1) 7:4 difference (1) 13:10 directly (1) 9:4 discovery (2) 10:16,17 discuss (1) 14:21 discussed (1) 15:2 discussing (1) 15:1 discussion (1) 6:10 discussions (1) 8:4 distress (1) 9:14 District (3) 15:9,15;16:12 document (7) 15:10;16:21,23,24; 17:11,18,21 documents (2) 4:12;17:20 down (1) 5:16 draft (5) 13:15,17,18,21,23 Drawing (1) 17:10 exact (1) 9:23 Exactly (1) 12:22 EXAMINATION (1) 3:1 Exhibit (2) 15:5;17:7 extreme (5) 9:15;10:2,4,10,11

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Absolutely (2) 10:1;12:9 abuse (1) 11:22 abusing (1) 11:13 according (1) 14:3 accused (2) 11:10,13 Act (3) 13:7,23;17:25 action (2) 7:20;17:11 actually (1) 14:10 address (1) 3:3 afterwards (1) 5:6 again (3) 7:21;8:9;16:3 against (5) 5:20,22;8:24; 14:17;16:11 ago (5) 12:11,17,21,21; 16:16 agreed (1) 15:16 ahead (1) 11:19 allegations (2) 12:3,4 amongst (2) 14:20;15:1 amount (2) 11:7;17:17 answered (2) 8:7,18 Antler (1) 3:4 applicable (2) 6:21;7:2 approve (3) 4:12;13:12,17 approved (2) 13:11;17:16 art (1) 11:16 assume (1) 5:7 atrocious (2) 9:15;10:3 attention (1) 17:10 attorney (1) 13:4 Attorney/client (1) 6:11 Min-U-Script

authority (1) 16:25 authorize (5) 5:13;7:17,22; 16:14;17:25 authorizes (1) 17:23 authorizing (1) 5:19 automatically (1) 12:10 aware (9) 4:1,3;9:8;13:10,23; 14:1,18;18:3,5

Church (2) 3:15,15 claim (4) 8:25;9:14;14:22; 16:11 closed (5) 4:17,20;6:10,12,14 coming (2) 12:7,16 company (5) 7:18,23;15:24; 16:15;17:23 concerned (1) 7:4 concerning (9) B 3:21;6:23;7:7,10, 15,19,25;13:7;16:19 concluded (1) B1 (1) 18:7 15:6 conduct (2) base (1) 9:14;10:3 12:4 confident (1) basing (1) 4:21 12:5 confuse (1) beginning (1) 10:13 12:6 consider (1) behalf (3) 12:25 5:20;16:19;17:25 contact (1) bills (1) 7:22 7:4 contents (1) bit (2) 14:18 10:4,10 contract (1) Board (18) 16:6 3:6,13;4:7;7:7,11, 14,17,22;10:22;12:8, conversations (5) 3:16,21;7:14,25; 12;13:12;14:7,21; 8:16 15:9;16:14;17:9;18:4 conversing (1) bottom (2) 14:20 5:17;15:18 correctly (1) business (1) 4:12 3:21 counsel (3) 10:12;17:19,20 C counterclaim (4) 5:20,25;6:5;8:24 Caffrey (4) counterclaims (1) 3:10;5:20;8:24; 5:14 18:4 call (1) D 13:18 can (9) dates (1) 6:7;8:8,19;11:19; 9:23 12:2,9;14:24,24; day (3) 15:14 4:25;14:20,20 carrier (1) days (1) 17:16 13:24 case (10) December (2) 4:15;5:22;6:23; 4:6;9:22 7:15,20,23,25;8:4,15; decide (1) 11:13 14:22 certain (8) Defending (1) 4:13;5:13;6:7; 7:20 9:21;10:3,18,18;12:3 defense (1) chance (1) 7:23 17:15

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fact (1) 11:4 failure (1) 14:3 fair (1) 15:9 false (2) 9:7,10 family (1) 9:3 fear (1) 3:24 felt (2) 10:10;16:16 few (3) 9:21;12:10;14:19 file (1) 5:20 filed (3) 4:2;7:3;8:24 filing (1) 11:16 filings (1) 4:14 find (3) 10:2;12:23;14:5 fine (1) 12:9 first (4) 7:3,20;14:8,9 five (1) 12:21 FOIA (8) 7:4;9:18,25;10:4, 12,21;12:6;13:6 Form (6) 8:5,17;11:15; 14:12,23;15:13 foundation (6) 8:5,17;11:15; 14:12,23;15:13 frame (5) 4:13;6:7;8:21; 9:21;10:19

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Education (1) 4:7 effect (1) 6:19 eight (1) 13:24 else (4) 3:22;6:24;14:9,11 e-mails (6) 9:19;10:15,18,22, 22,23 end (2) 6:17,19 entitled (1) 11:2 even (2) 9:23;12:12

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given (1) 16:16 Gladwin (2) (1) Absolutely - Gladwin

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Caffrey vs. Gladwin Community Schools, et al. 3:4,6 guess (1) 15:17

LISA SCHWAGER May 29, 2013 7:14;9:3;10:22; 18:4 memory (2) 4:23;8:22 mental (1) 9:13 merits (1) 14:22 met (2) 3:12;7:7 Michigan (1) 3:4 minutes (12) 4:19,21,25;5:12, 16;13:8,11,11,12,24; 14:3;17:9 misconduct (1) 11:10 months (1) 12:10 more (2) 3:19;4:22 morning (1) 4:10 motion (1) 4:1 multiple (2) 11:17;14:13 myself (1) 9:19 16:6 October (1) 9:22 offensive (1) 12:23 one (8) 4:10;8:1;9:18;10:5, 9;13:6;14:18;17:2 ones (1) 10:25 only (1) 17:21 Open (2) 13:7,23 opinion (1) 12:25 oral (1) 9:7 order (1) 4:1 others (2) 6:21;7:2 ourselves (2) 14:20;15:1 out (1) 14:20 outrageous (2) 9:15;10:2 over (4) 6:7;10:15,18;14:3 18:7 point (1) 12:18 pool (4) 15:25,25;16:2,11 pretty (1) 4:21 print (3) 9:19,21;11:1 prior (2) 5:25;6:4 privilege (1) 6:11 Probably (2) 3:19;16:2 problem (1) 14:5 process (2) 11:13,22 proposed (3) 13:8,10,18 protective (1) 4:1 provide (1) 7:23 provided (1) 13:24 provision (1) 17:22 purpose (1) 4:11 pursue (1) 5:13 put (1) 11:4

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keep (2) 9:20;10:23 kept (1) 10:22

HANSEN (7) 3:2;6:12;10:14; 16:24;17:2,6;18:6 happen (1) 6:8 happened (1) 6:10 heard (1) 14:7 Heart (1) 3:15 hi (1) 3:19 himself (1) 10:23 hours (2) 9:21;10:25

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language (1) 6:17 law (2) 11:2;14:3 lawsuit (10) 7:1,3,10;8:16;13:6; 14:2,8,9,11,15 lawsuits (5) 6:24;11:17;14:17, 19;16:19 legal (3) 4:14;11:15;12:25 libeled (1) 8:25 likely (4) 4:22;8:3,15,20 Lisa (1) 3:4 long (1) 3:8 lot (5) 9:24;11:6;14:7,17, 25

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immediate (1) 16:10 improperly (1) 11:16 indicate (3) 4:19;5:12;16:22 indicated (1) 8:11 indicating (1) 17:3 infliction (1) 9:13 information (1) 12:7 instance (1) 9:18 insurance (6) 7:18,23;15:24; 16:2,15;17:23 intentional (1) 9:13 interested (2) 12:15,17 into (2) 4:17,20 Item (1) 17:11

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name (1) 3:3 nature (1) 3:22 necessary (2) 16:17,18 next (2) 15:16,18 Nobody (3) 12:12;14:10,14 normally (1) 8:12 notes (2) 5:4,6 notice (2) 15:25;16:10 notify (3) 7:17;15:23;16:14 notifying (1) 16:5 number (3) 10:4,25;12:6 numbers (2) 5:22;6:23

P
page (4) 15:16,18,18;17:10 pages (1) 15:16 paragraph (2) 17:24;18:2 part (2) 5:12;13:6 particular (1) 17:22 parties (1) 9:8 past (2) 3:16;12:10 people (1) 9:25 period (1) 6:13 personal (1) 9:24 personally (1) 9:1 phone (1) 7:4 pleadings (1) 8:12 please (6) 3:3;8:9;10:6,13; 15:14,19 pm (1)

M
many (1) 14:18 mark (1) 17:6 marked (2) 17:7,8 matter (2) 4:2;7:3 matters (3) 6:18,23;8:12 May (2) 3:9;14:19 maybe (1) 3:19 mean (3) 5:7;11:7;12:21 means (1) 15:15 meeting (9) 4:6,9,11;5:25;6:2, 6,8;13:13,25 meetings (4) 12:8,12;13:7,23 member (8) 3:6,8;15:8,15,23; 16:4,10,11 members (4)

Q
quite (2) 9:20;10:25

R
read (10) 5:25;6:4,6,7,14; 8:12;15:5,6;17:13,15 reading (1) 15:8 really (1) 14:14 recall (28) 4:5,12,20,21;5:1, 11,15;6:1,3,4,8,15, 16;7:5,6,8,9,13,16, 24;9:9,12;11:12; 13:1;14:16,25;16:20, 21 recently (1) 12:10 recollection (1) 15:3 record (3) 10:13;12:2,11 (2) guess - record

J
J2c (1) 17:11 Julie (1) 5:9 June (1) 17:9

O
object (2) 6:9;15:10 objection (1)

Min-U-Script

Mid-Michigan Reporting LLC (989)835-9171

Caffrey vs. Gladwin Community Schools, et al. recording (4) 12:8,16,17,23 refer (2) 6:22;13:21 referring (11) 9:16,17;10:5,7,19; 11:11,14,18;15:25; 17:2,12 relates (1) 11:16 remember (3) 4:9,10;7:25 repeat (2) 7:21;8:9 reporter (1) 17:7 represent (1) 5:13 request (4) 10:12,16,17,21 requested (1) 10:15 requests (7) 7:4;9:18,25;10:4; 12:6;13:7,7 requires (1) 13:23 resolution (3) 4:19;5:19;6:19 resolve (1) 14:22 resolved (1) 5:12 response (1) 12:20 Rick (1) 18:3 right (15) 4:17,18;5:4,8,10, 14,21,23;7:1;9:25; 11:5,8;13:14;15:24; 16:12 seeing (2) 3:18,18 seemed (1) 12:9 SEG (2) 17:16,23 session (5) 4:17,20;6:10,13,14 SET (2) 17:16,23 shall (1) 16:10 Sharman (1) 12:13 show (2) 5:16;15:5 showing (1) 17:8 slandered (1) 8:25 sometime (1) 12:18 somewhere (1) 3:19 sorry (1) 13:16 South (1) 3:4 speaks (2) 15:11;16:7 special (1) 4:6 specific (3) 4:23;8:22;15:2 specifically (1) 6:16 speculate (1) 8:6 spend (2) 11:8;14:20 spent (1) 14:25 start (1) 12:10 started (1) 12:12 starting (1) 12:18 state (1) 3:3 statements (5) 9:7,7,10,11;18:3 Street (2) 3:4,18 sued (4) 8:10,11;9:13;11:22 supplied (1) 17:18 supposed (2) 15:23;16:4 sure (4) 5:8;9:23;17:14,14 system's (1) 8:10 7:22 voting (1) 6:4

LISA SCHWAGER May 29, 2013 3a (1) 15:20

T
talked (3) 14:8,10,14 talking (1) 10:9 ten (1) 12:21 tend (1) 9:20 term (1) 11:16 testimony (1) 14:7 third (1) 9:8 thought (1) 10:14 three (1) 15:17 today (1) 3:14 together (1) 11:5 took (5) 4:25;9:20,24; 10:25;11:6 towards (3) 5:16;6:17;9:14 true (2) 14:10,14 turn (4) 10:15,18;11:1;14:3 two (5) 3:16;6:23;7:1; 12:17;15:16 type (1) 7:5 types (2) 5:9,10

4 W
410 (1) 3:4 Wallace (20) 48624 (1) 5:13,19;6:9;8:5,17; 3:5 10:6,12,16;11:15,19; 13:2;14:12,23;15:10, 5 13;16:6,22;17:1,4,20 wanton (1) 11:10 55,000 (1) way (1) 17:17 8:1 what's (1) 17:8 whatsoever (2) 7:9;8:1 willful (1) 11:10 Withrow (2) 5:2,3 witness (1) 8:6 working (1) 13:24 written (5) 9:10;12:25;15:11, 25;16:10

Y
year (1) 12:11 years (5) 3:17;12:17,21,21; 16:16

1
1 (2) 17:7,8

S
Sacred (1) 3:15 same (3) 3:15;13:18;16:6 School (10) 3:6,21;8:10;10:23; 14:17;15:9,9,15; 16:12,19 Schwager (3) 3:4;17:7,8 seconded (1) 4:19 secretary (1) 5:1 Seebeck (8) 7:15,17,22;9:19; 10:21;15:5;16:14; 17:25 Min-U-Script

U 2
Um-hum (10) 3:11;5:18,24;6:7; 8:14;11:24;12:22; 13:9;16:8;17:16 under (2) 11:2;17:11 unreasonable (1) 14:21 up (2) 5:9,10 upset (1) 11:7 Usually (5) 5:1,8;6:6,15;8:20 2 (2) 15:5,19 2008 (1) 17:9 2010 (1) 3:9 23rd (1) 17:9 24th (2) 4:6;12:25

3
3 (3) 15:18,19;17:10 3:35 (1) 18:7 (3) recording - 55,000

V
vote (1)

Mid-Michigan Reporting LLC (989)835-9171