BEFORE THE STATE OF ALASKA LEGISLATURE

2
IN THE MATTER OF: )
3 )
4
SARAH PALIN, GOVERNOR )
)
5

6
AFFIDAVIT OF RANDY RUARO

7 STATE OF ALASKA j ss.

8 FIRST JUDICIAL DISTRICT

9
I, Randy Ruaro, hereby state that I am voluntarily responding to the
10
Interrogatories submitted to me by Senator Hollis French, Chairman of the
11
Senate Judiciary Committee on Monday, October 6, 2008 at 4:20 p.m. The
12
Interrogatories seek information "into the events and circumstances
13
surrounding the tennination of former Public Safety Commissioner Walt
14
Monegan." In response to these Interrogatories and to the subpoena previously
15
issued, through my attorneys I yesterday sent via DHL to Mr. Branchflower 3
16
volumes containing documents numbered 1 through 1554. With this affidavit I
17
am sending documents numbered 1555 through 2292. Having first been duly
18 sworn, I hereby state the following:
19

20
QUESTION NO.1: What positions have you held in the Palin

21
administration? Describe the date your employment began and the dates of

22
each position.
RESPONSE: I am currently the Deputy Chief-of-Staff for
23
Governor Sarah Palin. I was appointed to that position on September 1, 2008.
24
Prior to this appointment, I was employed as a Special Assistant to the
25

26 Affidavit of Randy Ruaro

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 Governor. I am currently performing the job duties of both positions. My
employment as a Special Assistant to the Governor started on or about the 6th
2
of September, 2007, when I replaced the previous Special Assistant, Russell
3
Kelly. Prior to 2007, my State service consisted of working as the House
4
Finance Committee aide overseeing legislation for the Co-Chairman, the
5
Legislative Liaison for the Department of Law, and the Deputy Legislative
6
Director.
7
QUESTION NO.2: What communications have you had with
8
Governor Sarah Palin regarding Walt Monegan?
9
RESPONSE: I am sure I have had conversations with the
10
Governor regarding the ordinary business activities of the Department of
II
Public Safety, but I recall only two conversations that relate specifically to the
12
subject of this investigation. The first conversation occurred on May 5, 2008,
13
in Anchorage at the Governor's office. Mike Nizich and Anna Kim were
14
present. I was asked to provide an assessment of current issues relating to the
15
departments in my portfolio, including DPS. As part of my response, I gave
16
an assessment of Walt Monegan to the Governor, as I was becoming more and
17 more frustrated in my dealings with Walt Monegan. In substance, I told the
18 Governor the following: I told her I found Walt Monegan difficult to work
19 with and that in my opinion he had not taken an aggressive approach to
20 addressing alcohol and drug issues, especially in the more rural areas. I told
21 the Governor I thought Walt Monegan often took labor's side on issues rather
22 than supporting management. While I am not sure, I believe I told her about a
23 conversation I had with Annette Kreitzer in which Annette relayed her
24 concerns about Walt Monegan advocating for the State to pay Rob Cox, the
25 PSEA union president for his time spent on union issues. I believe I also

26 Affidavit of Randy Ruaro

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 relayed Annette's statement that she was not comfortable with Walt
Monegan's attempts to intervene in the union negotiations. I told her trying to
2
work with him on issues almost felt like negotiating with a union. I told the
3
Governor I thought his approach to reducing sexual assaults would be largely
4
ineffective, and would likely cost between $10 million and $30 million once
5
its cost was fully determined. I told her that Walt Monegan disagreed with
6
my suggestions and was unwilling to agree that the approach I recommended
7
that focused on increasing education, treatment, and prevention of alcohol and
8
drug abuse, increased interdiction efforts and education, treatment, and
9
prevention of sexual assaults by partnering with communities, tribes, and the
10
federal Indian Health Service facilities was the better approach. I also told the
11
Governor it would be highly unlikely for the legislature to fund Walt
12
Monegan's plan because there were a significant number of vacancies in
13
trooper positions that were not being filled now. It is my recollection that
14
Mike Nizich confirmed my statements. My memory is that the Governor
15
mostly listened to my report. She indicated agreement that these were
16
concerns and specifically stated a concern about pursuing Walt Monegan's
17 sexual assault plan without accurate cost estimates and a source of funding.
18 In this conversation I conveyed my sense of frustration in trying to work
19 with Walt Monegan, which is documented in the e-mails referenced below. It
20 was also relevant to my evaluation of Commissioner Monegan for the
21 Governor on May 5, 2008, and to my sense of frustration that I view the role
22 and relationship of the Governor to a commissioner as that set out in the
23 Alaska Constitution. In my view, it is the Governor who is vested with the
24 executive power of the State. It is the Governor who is the ultimate supervisor

25 of each department and it is the Governor who has the constitutional authority

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 to detennine agency budgets through her initial budget bills and her veto
authority. It appeared to me that Walt Monegan did not want to recognize the
2
constitutional authority of the Governor and instead wanted to work around
3
that authority.
4
The only other conversation with Governor Palin I recall relating to
5
Walt Monegan occurred in the later part of July of 2008, after Walt Monegan
6
was removed. This conversation took place in the Governor's office in
7
Anchorage. Sharon Leighow was present and I believe Kris Perry was present
8
at times. Governor Palin said the allegation in news reports that Walt
9
Monegan's removal was somehow connected to Trooper Wooten and other
10
allegations were untrue. She asked me to work with Sharon Leighow to
II
provide a response. She mentioned her concern that he was not a team player,
12
that he had not been effective in recruitment or in filling vacancies and his
13
lack of leadership on alcohol and drug related issues.
14
I have had communications with Governor Palin regarding Walt
15 Monegan through e-mail. I asked my secretary to print all e-mails to or from
16 the Governor regarding DPS. Copies of e-mails she printed are submitted
17 herewith and are numbered 2147 to 2237. The content, context, date and time
18 of each e-mail communication and persons included on each e-mail is apparent
19 from the face of the e-mail.
20 For the purposes of further explanation of e-mails, I can provide the
21 following information:
22 a. On July 1, 2008, I sent the Governor an e-mail regarding "DPS

23 management". Submitted herewith are documents numbered 2147 to 2148.

24 This e-mail was sent in response to the Governor's e-mail stating that there

25 needed to further review of suggestions that DPS does not have the resources

26 Affidavit of Randy Ruaro

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 to do its job. My e-mail referencewasmainlydirectedatWaltMonegan.In
the e-mail I told the Governor it was my opinion that "DPS management
2
needed to lead and do the best job they can with the resources they have just
3
like every other agency." I was expressing my frustration with Walt Monegan
4
and pessimistic comments made by him to the effect that DPS could not
5
protect the public's safety adequately and that morale in the department was
6
low. It seemed to me that if Walt Monegan put as much energy into finding
7
ways to lead and motivate DPS personnel to adequately protect public safety
8
as he did complaining, DPS personnel might become more highly motivated
9
and morale would be better.
10
b. On July 13, 2008, the Governor sent me an e-mail regarding the
II
removal of Walt Monegan as commissioner of DPS and the offer of a position
12
to him as Director of the ABC Board. Submitted herewith is document
13
number 2178. The e-mail stated that: "We're replacing Walt with Chuck Kopp
14
from Kenai. It's all good. Except we asked Walt to move to the ABC Board
15
so he could utilize his talents and connections with Rural AK and help address
16 the bootlegging problem (leading to horrendous other problems) In our
17 villages ... he said no to that offer. Chuck starts on Monday."
18 c. On July 14, 2008, I sent the Governor an e-mail regarding a press
19 release. Submitted herewith is document number 2174. The e-mail noted that
20 "actually solving the problem of alcohol and crime I sexual assaults in rural
21 Alaska was one of Walt's weakest points. He talked about it a lot and may
22 have flown around Alaska a lot, but the only solution he pursued hard was
23 hiring a bunch of retired troopers to ease the workload of existing troopers and
24 make a few more arrests. . .. Any significant long lasting progress has to
25 combine education, prevention, treatment, law enforcement, cracking down on

26 Affidavit of Randy Ruaro

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~ .NC.;; ,Ie .•&.b.P.ft, & \

 bootlegging and having buy-in from the tribes and tribal members." This
sentence illustrates an issue Walt Monegan and I disagreed on for months,
2
how best to get some lasting changes to the problem of sexual assault rates in
3
rural Alaska. His proposal was for a vertically integrated statewide sexual
4
assault law enforcement team at a cost of millions to perform one function,
5
making a few more arrests. I preferred an approach that involved more of a
6
public health approach and included education, prevention, and treatment and
7
partnering with tribes in rural Alaska and possibly, federal Indian Health
8
Services. My goal was to try to do something that would bring communities
9
together against the problem and bring about lasting improvements.
10
c. On July 17, 2008, I sent the Governor an e-mail regarding a trip
II
of mine to Anchorage to work with former Commissioner Chuck Kopp, who
12
was appointed to replace Walt Monegan. Submitted herewith is this e-mail as
13
document number 2179. I stated in the e-mail that: "I'll be in Anchorage
14 today and tomorrow meeting with Chuck Kopp to discuss steps we can take on
J5 crime in rural Alaska and improving recruiting, etc. There are several things
16 Walt didn't really seem to work hard on or want to do, like recruiting from
17 returning National Guard and military or finding ways to improve our local
18 option laws and cracking down on bootlegging that could be helpful." I
19 mentioned the recruiting issue because the Governor had asked me in February
20 to ask DPS to recruit new troopers from a group of 180 or so returning
21 National Guardsmen in Bethel. I do not believe this was done. I had also
22 asked Walt Monegan for statistics on alcohol related sexual assaults in rural

23 Alaska that DPS had gathered. He never provided those to me and mentioned

24 that it was a sensitive topic we needed to be careful of. I disagreed. I thought

25 if the statistics were as bad as I suspected and were shown in studies like the

26 Affidavit of Randy Ruaro

In the Matter ofSarah Palin, Governor
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 Bernard Segal study, the statistics should be used to educate the public and the
legislature on the scope of the problem so they would support changes to laws
2
and help communities to come together against drug and alcohol abuse and
3
sexual assaults.
4
d. On July 18, 2008, I sent the Governor an e-mail regarding a
5
meeting I had with former Commissioner Chuck Kopp in Anchorage.
6
Submitted herewith is document number 2292. I stated in the e-mail that I
7
had met with Chuck Kopp for a few hours and felt like we had made more
8
progress on public safety issues in a few hours than we had with Walt
9
Monegan in months. During my brief meeting with Mr. Kopp he talked about
10
strategies for getting more troopers on the front line and the problem of
II
alcohol and drug related crime in rural Alaska.
12
Other e-mails responsive to this request are produced herewith and are
13
self explanatory.
14
QUESTION NO.3: What communications have you had with
15 Governor Sarah Palin regarding Mike Wooten?
16 RESPONSE: To my memory, I had no communications with
17 Governor Palin regarding Mike Wooten before Walt Monegan was removed.
18 I did have communications with Governor Palin regarding Mike Wooten after
19 Walt Monegan was removed and after public allegations were made against
20 the Governor relating to Mike Wooten. One of the oral communications is
21 summarized in response to my answer to Question 2 above. I also had a
22 discussion with the Governor in her Juneau office sometime in August before
23 she was named as a vice-presidential nominee. No one else was present. The

24 Governor told me one of Mr. Wooten's ex-wives had called the Governor to

25 let her know Mr. Wooten and his current girlfriend or wife had called and

26 Affidavit of Randy Ruaro

In the Matter ofSarah Palin, Governor
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 offered child custody and/or child support benefits to the former wife if she
would come out publicly against the Governor and her family. I do not recall
2
any other conversations with the Governor regarding Mike Wooten.
3
I asked my secretary to print all e-mails to and from the Governor
4
regarding Mike Wooten. Copies of e-mails she printed are submitted herewith
5
as documents 2183 to 2184. These e-mails are self explanatory.
6
One relevant e-mail was sent by Governor Palin to me on July 18, 2008.
7
Submitted herewith is document 2183. This e-mail states in pertinent part:
8
"On Sunday, Wooten refused to follow a court order to hand the kids over to
9
Molly after his visitation. One of Wooten's sergeants had to call him and tell
10
him he must obey the court order. He handed over the kids and promised
11
Molly, "Get ready for a show, I'm going to bring you and your family down".
12
QUESTION NO.4 AND NO.5: What communications have you had
13
with Todd Palin regarding Walt Monegan or Mike Wooten?
14
RESPONSE: I do not believe I have had communications with
15
Todd Palin regarding just Walt Monegan or just Mike Wooten so I am
16 combining my answers. To my memory, there was a phone call in February,
17 2008, where Todd Palin talked about Mike Wooten and a threat by Mike
18 Wooten against his family and other misconduct. I recall Todd Plain
19 mentioning a concern of the risk to other motorists if Mike Wooten drove
20 while consuming alcoholic beverages. I believe he also talked about another
21 trooper who he thought had gotten away with misconduct. I told him of a
22 trooper in Ketchikan who had gotten very aggressive inside the home of an
23 elderly friend of the family.
24 Sometime later, on a trip to Anchorage, Todd Palin showed me a picture

25 of a person he said was Mike Wooten standing next to a snowmobile. He told

26 Affidavit of Randy Ruaro

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 me Mike Wooten was on disability or workers compensation benefits at the
time and that the photo had been taken some 100 miles out. I believe he said
2
he gave the photo to Walt Monegan, but never heard back from him.
3
I believe there was another conversation after Walt Monegan had been
4
removed, during which I told Todd Palin I had done some research and found
5
that the situation with troopers being investigated by other troopers in
6
Connecticut had gotten so bad that the commissioner there resigned and the
7
state of Connecticut called in the New York State Troopers to investigate and
8
issue a report on the problems and improvements that needed to be made.
9
At no point during these conversations did Todd Palin ask me to take
10
any action against Mike Wooten or Walt Monegan.
11
The electronic communications I have received from Todd Palin are
12
submitted herewith as documents numbered 2289 to 2291.
13
QUESTION NO.5: What communications have you had with Mike
14
Tibbles regarding Walt Monegan?
15
RESPONSE: I have had numerous oral communications with
16 Mike Tibbles regarding Walt Monegan. Shortly after my employment as
17 Special Assistant to the Governor, I met with Walt Monegan in Anchorage at
18 DPS headquarters. In mid September of 2007 I spoke with then Chief-of-Staff
19 Mike Tibbles about this meeting. I told Mike Tibbles that Walt Monegan had
20 advised me he was going to produce a "strategic plan" for the Alaska State
21 Troopers and provided me with a copy of the draft. I told Mike Tibbles the
22 draft strategic plan struck me as unusual in several ways:
23 a. I read the plan as proposing to take away the Governor's
24 constitutional authority to review and assess the State's fiscal situation each

25

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,,!?,"¥.. • 4 ill. ."... .3., i .• 4 a '

 year and fund agencies and priorities on an annual basis in any manner she
wished.
2
b. Instead, annual budget authority would essentially be
3
transferred to Walt Monegan and DPS.
4
c. A key component of the strategic plan proposed a "staffing
5
study" that would be performed by DPS. The staffing study would review and
6
recommend changes to retention and recruiting methods and I assumed,
7
significant increases in staffing.
8
d. The staffing study was open ended in the sense that it had
9
not been performed yet, but whatever the outcome determined by DPS, the
10
recommendations would become part of the strategic plan.
11
e. The staffing study would be done without the involvement,
12
oversight, or approval of OrYIB, the agency in charge of position increases and
13
budget issues for all state agencies.
14 f. The plan proposed that the Governor and Lt. Governor sign
15 it as if it was a binding contract. I was concerned that this could be spun
16 politically later to prohibit or discourage the Governor from freely exercising
17 her discretion and making adjustments or changes depending on the State's
18 fiscal situation or the Governor's own priorities.
19 h. I read the forward or introduction letter accompanying the
20 plan from Walt Monegan as trying to reverse the normal approach to
21 budgeting: "[r]ather than plan to a budget, we want to budget to a plan".
22 I believe Mike Tibbles agreed with my assessment and was concerned
23 enough to contact Walt Monegan. In response, I believe Walt Monegan sent a

24 September 13, 2007, memo to Mike Tibbles explaining that the strategic plan

25

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[n the Matter a/Sarah Palin, Governor
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"1(
 was intended to allow the public and the legislature to make decisions on the
budget for DPS.
2
Between September 13, 2007 and October 25, 2007, I had several more
3
conversations with Mike Tibbles regarding the strategic plan. The gist of
4
these conversations was that the strategic plan could intrude on the Governor's
5
budget authority and discretion. Because I was unable to resolve the issue, I
6
asked Mike Tibbles if I could arrange a meeting between OMB, the COS, and
7
DPS personnel. On October 25, 2007, a meeting occurred at which, to my
8
memory Mike Tibbles explained the Governor makes policy and budget
9
decisions for the agencies and agencies usually support those decisions, not
10
vice-versa. Present at this meeting were Karen Rehfeldt, Audie Holloway and
II
me. I believe Walt Monegan was present telephonically. Another meeting
12
occurred in December 2007 or January 2008 with Mike Tibbles, Mike Nizich,
13
Karen Rehfeldt, Commissioner Schmidt, Ric Svobodney, Walt Monegan and
14
possibly others. In my mind, the main purpose of this meeting was to
15
encourage Walt Monegan to support the Governor's DPS budget at the crime
16 summit scheduled for January 2008.
17 Between October 25, 2007, and the end of Mike Tibbles' employment
18 In early May of 2008, I had ongoing conversations with Mike Tibbles
19 regarding Walt Monegan and the problems I was experiencing with him. I
20 cannot separate one conversation from another, but the topics were generally
21 the same and reflected the increasing frustration I was experiencing in trying
22 to work with Walt Monegan, as I have described above.
23 QUESTION NO.6: What communications have you had with Mike
24 Tibbles regarding Mike Wooten?

25

26 Affidavit of Randy Ruaro

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 RESPONSE: I do not recall any conversations with Mike Tibbles
regarding Mike Wooten while Mike Tibbles was employed as Chief-of-Staff.
2
The only conversation I can remember with Mike Tibbles regarding Mike
3
Wooten was in the Anchorage airport. I do not believe anyone else was in the
4
immediate area. I believe it occurred in mid to late July or August, 2008. The
5
gist of the conversation was that reporters or Jon Bitney had called or were
6
likely to call Mike Tibbles regarding press coverage related to Walt Monegan
7
and Mike Wooten.
8
QUESTION NO.7: What communications have you had with
9
Annette Kreitzer regarding Walt Monegan?
10
RESPONSE: On at least 2 or more occasions, I have spoken with
II
Annette Kreitzer regarding Walt Monegan. I believe the first occasion was in
12
the spring of 2008, when I happened to be at the Department of
13
Administration for another issue, which I believe was union negotiations with
14
AMHS employees. We started discussing union negotiations with public
15 safety officers. To my memory, she stated she felt Walt Monegan was trying
16 to improperly insert himself into the negotiations on the side of the union and
17 she had to tell him to back off. Annette also told me that Walt Monegan had
18 been way off base in suggesting that PSEA union president Rob Cox be paid
19 by the State for his time spent working on union issues. I do not recall anyone
20 else being present when this conversation occurred. There were other similar
21 conversations after this. In one of these conversations, Annette Kreitzer
22 mentioned getting a very nasty note from Walt Monegan that upset her. She
23 said she tore the note up and threw it away. I also believe I spoke to Annette

24 Kreitzer about ETS issues such as changing over DPS to a new phone system

25 and push back from DPS to Annette Kreitzer that she felt would cost the State

26 Affidavit of Randy Ruaro

In the Matter o/Sarah Palin, Governor
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 a significant amount of money if the switch over to the new phone system was
not made. She said that WaIt Monegan was unwilling to help her with the
2
difficulty she was having with the DPS employee. I understood Annette was
3
frustrated because the DPS employee handling this matter resisted her efforts
4
as Commissioner of Administration and that Walt Monegan had not
5
intervened. Matters such as phone service and technology for State agencies
6
are under the authority of the Department of Administration.
7
I have had communications with Annette Kreitzer regarding general
8
DPS issues. I asked my secretary to print all e-mails to Annette Kreitzer and
9
have separated out those related to DPS. Copies of e-mails she printed are
10
submitted as documents 2276 to 2288. The content, context, date and time of
II
each e-mail communication and persons included on each e-mail is apparent
12
from the face of the e-mail.
13
QUESTION NO.8: What communications have you had with
14
Annette Kreitzer regarding Mike Wooten?
\5 RESPONSE: I don't recall any conversations specifically relating
16 to Mike Wooten. I did see Annette at the Juneau airport while on my way to
17 Anchorage sometime after the removal of Walt Monegan. In a general
\8 conversation Annette said proper discipline should be handed out to State
19 employees when it is warranted.
20 QUESTION NO.9: What communications have you had with
2\ Brad Thompson regarding Walt Monegan?
22 RESPONSE: None that I can remember.
23 QUESTION NO. 10: What communications have you had with

24 Brad Thompson regarding Mike Wooten?

25 RESPONSE: None that I can remember.

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 QUESTION NO. 11: What communications have you had with
Nlike Nizich regarding Walt Monegan?
2
RESPONSE: I have had many verbal communications with Mike
3
Nizich regarding Walt Monegan and agency budget issues, operations of DPS,
4
Walt Monegan's ability or lack of ability to lead DPS, whether he could
5
possibly provide some benefit as ABC Board Executive Director, his
6
statements and action in the news, our responses, and legal issues related to
7
the legislative investigation and related court cases. It is difficult for me to
8
separate one conversation from the other, but I have above described some of
9
the meetings I recall Mike Nizich being present at. One such meeting I
10
specifically recall is a December 2007 or January 2008 meeting with agency
II
personnel and commissioners. Mike Nizich offered to sit in at this meeting to
12
help make the point that Walt Monegan needed to be supportive of the
13
Governor's budget process. I later passed Mike Nizich a note that Mike
14
Tibbles told me he had addressed this issue with Walt Monegan.
15
Unfortunately, I saw no improvement or change during my subsequent
16 dealings with Walt Monegan. Just a short time later Walt Monegan testified
17 that he expected the criminal justice working group to possibly make
18 recommendations for increases in the operating budget for DPS. I also
19 discussed with Mike Nizich the lack of leadership I perceived was being
20 shown by Walt Monegan. Approximately a week before Walt Monegan was
21 removed, I believe Mike Nizich told me the Governor was thinking about
22 making this change because she was approaching the halfway point of her
23 term and there were things she still wanted to accomplish that she had a better
24 chance of accomplishing if a change was made. Mike asked me whether I

25 thought Walt Monegan would be a good fit for the ABC Director. I told him I

26 Affidavi~ of Randy Ruaro

In the Maller a/Sarah Palin, Governor
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 thought Walt Monegan would be a much better fit in this role as his
involvement in budget issues would be minimal, he would be taking direction
2
from a board, and he would not be involved in union issues. I also told him I
3
thought Walt Monegan had some positives, such as existing relationships in
4
rural Alaska, which could be put to good use in this position. I am sure I had
5
other conversations with Mike Nizich which relate to Walt Monegan, but they
6
would either have addressed the same ongoing issues outlined above or events
7
occurring in the ordinary business of DPS.
8
After Walt Monegan was removed, I remember receiving a telephone
9
call from Mike Nizich telling me he had been removed as commissioner and
10
that he had not accepted the offer of the ABC Directorship. I have also had
II
conversations with Mike Nizich and Sharon Leighow regarding a July 13,
12
2008 video interview between a KTUU employee and Walt Monegan and
13
news story. 1 discussed the following statement of Walt Monegan that
14
appeared in the news story: "I respect her-I still do. She has a lot on her
15
plate. She's a hell of a lady. If she found someone better to do a better job,
16
that's her authority to find them and 1 will gladly step aside." I mentioned that
17 this statement seemed inconsistent with Walt Monegan's current statements.
18 1 also have had conversations with Mike Nizich regarding legal issues
19 which arose In the course of this investigation, but 1 consider these
20 conversations to be protected by the attorney client and work product
21 privileges.
22 1 have also had communications with Mike Nizich regarding Walt
23 Monegan through e-mail. 1 asked my secretary to print all e-mails to Mike
24 Nizich and have separated out those related to DPS. Copies of e-mails she

25 printed are attached documents numbered 1792 to 1809. The content, context,

26 Affidavit of Randy Ruaro

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 date and time of each e-mail communication and persons included on each e-
mail is apparent from the face of the e-mail.
2
QUESTION NO. 12: What communications have you had with
3
Mike Nizich regarding Mike Wooten?
4
RESPONSE: I do not believe I had any conversations with Mike
5
Nizich regarding Mike Wooten before Walt Monegan was removed. After
6
Walt Monegan was removed and after Mike Wooten went public with his
7
allegations against the Governor, I had numerous conversations with Mike
8
Nizich regarding who Mike Wooten is, his conduct and alleged conduct, his
9
statements in the press, responses from the Governor's office, Walt
10
Monegan's actions or inactions regarding Wooten, and whether actions by
II
troopers like Wooten are adequately investigated and prosecuted under the
12
existing system. Most of these conversations were between Mike Nizich and
13
I. It is possible that Sharon Leighow and/or Kris Perry were present during
14
some of these conversations, but I do not have a clear recall of this.
15 QUESTION NO. 13: What communications have you had with Ivy
16 Frye regarding Walt Monegan?
17 RESPONSE: No direct communications that I can remember. She
18 may have been copied on an e-mail that I was also copied on.
19 QUESTION NO. 14: What communications have you had with Ivy
20 Frye regarding Mike Wooten?
21 RESPONSE: No direct communications that I can remember. She
22 may have been copied on an e-mail that I was also copied on, or been copied
23 on an e-mail I sent to someone else.
24 QUESTION NO. 15: What communications have you had with
25 Frank Bailey regarding Walt Monegan?

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 RESPONSE: No direct communications that I can remember
before Walt Monegan was removed. He may have copied me on an e-mail
2
sent to someone else. While I do not recall any mention of Walt Monegan or
3
Mike Wooten, I believe I had a short phone conversation with Frank Bailey in
4
February, 2008. He called to ask me what position Lt. Rodney Dial held in
5
DPS and I believe, whether Lt. Dial was working as a legislative liaison for
6
DPS during the session. I told him Lt. Dial was, to my knowledge based out
7
of Ketchikan and temporarily assigned during the session to spend part of his
8
time in Juneau and testify to the legislature when needed.
9
After Walt Monegan was removed, I believe I had conversations 10
10
passing with Frank Bailey about the news reports of the removal. I recall
11
Frank Bailey at one point saying he was disappointed at how the removal was
12
being portrayed in the press. I don't recall anything more of substance.
13
QUESTION NO. 16: What communications have you had with
14
Frank Bailey regarding Mike Wooten?
15
RESPONSE: Please see my answer to Question No. 15 above. I
16 had no other direct communications that I can remember. He may have copied
17 me on an e-mail sent to someone else or we may have both been copied on an
18 e-mail.
19 QUESTION NO. 17: What communications have you had with
20 John Glass regarding Walt Monegan?
21 RESPONSE: I have had a number of conversations with Deputy
22 Commissioner of DPS John Glass that in some way related to Walt Monegan.
23 He was present at some of the meetings and/or calls relating to the budget
24 process. I specifically recall a conversation that occurred in the spring of 2008

25 in my office. I discussed with John Glass the goal of trying to get an initiative

26 Affidavit of Randy Ruaro

In the Matter a/Sarah Palin, Governor
Page 17 of 17
 in place that would have some long lasting positive impact on reducing the
number of sexual assaults in rural Alaska. To my memory, John Glass agreed
2
with me based on his experience in rural Alaska that any significant change
3
would require an approach that involved buy-in from communities and tribes
4
in rural Alaska, such as the approach I preferred which involved prevention,
5
education, and treatment and partnering with tribes and communities against
6
sexual assaults, and alcohol interdiction as opposed to Walt Monegan's plan
7
for hiring 20-30 more retired troopers to make roughly 30 more arrests for
8
sexual assault per year. I also had conversations with John Glass when a
9
worker at the Anchorage airport accused Walt Monegan of improper behavior.
10
I have had e-mail communications with John Glass that relate to Walt
II
Monegan. I asked my secretary to print all e-mails to or from John Glass and
12
have separated out those related to DPS. Copies of e-mails she printed are
13
attached as documents 1998 to 2032. The content, context, date and time of
14
each e-mail communication and persons included on each e-mail is apparent
15 from the face of the e-mail.
16 QUESTION NO. 18: What communications have you had with
17 John Glass regarding Mike Wooten?
18 RESPONSE: None that I can remember.
19 QUESTION NO. 19: What communications have you had with
20 Audie Holloway regarding Walt Monegan?
21 RESPONSE: I have had verbal communications with Audie
22 Holloway that related to Walt Monegan. These conversations concerned DPS

23 issues, such as the budgeting process. Audie Holloway participated in some of

24 the meetings I have outlined above.

25

26 Affidavit of Randy Ruaro

In the Matter o.fSarah Palin, Governor
Page 18 of 18
 QUESTION NO. 20: What communications have you had with
Audie Holloway regarding Mike Wooten?
2
RESPONSE: None that I can remember.
3
QUESTION NO. 21: What communications have you had with
4
other members of the Department of Public Safety regarding Walt Monegan?
5
RESPONSE: I have had numerous e-mail and verbal
6
communications with former Legislative Liaison for DPS, Lauren Rice on
7
routine issues related to DPS and sometimes Walt Monegan was copied in an
8
e-mail or mentioned in the e-mail. One relevant conversation occurred on or
9
about July 17, 2008, at DPS headquarters when Ms. Rice informed me that she
10
was resigning or had been removed from her position. While discussing a
11
number of issues, Ms. Rice stated to me that "we" i.e., Walt Monegan, were
12
always willing to accept a much scaled back plan for additional law
13
enforcement officers as part of an initiative to deal with sexual assaults in
14
Alaska. I took her comment as an admission that Walt Monegan was basically
15 playing budget games with the office of the Governor by pursuing a statewide
16 approach that would be very expensive and had virtually no chance of ever
17 being funded by the legislature even if it was brought forth by the Governor.
18 QUESTION NO. 22: What communications have you had with
19 other members of the Department of Public Safety regarding Mike Wooten?
20 RESPONSE: None that I can remember.
21 QUESTION NO. 23: What communications have you had with Kris
22 Perry regarding Walt Monegan?
23 RESPONSE: I do not recall having any communications with Kris

24 Perry regarding Walt Monegan before he was removed from his position as

25 commissioner on July 11, 2008. Sometime after July 11, 2008, I had a

26 Affidavit of Randy Ruaro

In the Matter a/Sarah Palin, Governor
Pagel90fJ9
 conversation with Kris Perry at the Anchorage office of the Governor where
she showed me a picture with Mike Wooten in it that Walt Monegan or
2
someone from DPS had delivered to the office of the Governor. She told me
3
that she found it very odd for the picture to have been delivered to the office of
4
the Governor given the threat by Mike Wooten to kill the Governor's father
5
and the fact that Walt Monegan was told of this threat by the Governor. We
6
have also had numerous communications about allegations of Walt Monegan
7
that he was removed due to his failure to fire Mike Wooten, communications
8
about press articles and news coverage of the issues, and communications
9
about legal matters. One of these conversations concerned the July 13, 2008
10
KTUU news story by Jill Burke and related to Walt Monegan's statement that
11
it was the Governor's right to remove him and he still respected her. I believe
12
we also talked about how Walt Monegan's story seemed to change after Mike
13
Wooten and another person met with Andrew Halcro and Andrew Halcro
14 announced on his blog that Walt Monegan's removal was related to Mike
15 Wooten and how the press had run with the stories from there. I have also had
16 conversations with Kris Perry about legal issues which arose in the course of
17 this investigation, but I consider these conversations to be protected by the
18 attorney client and work product privileges.
19 QUESTION NO. 24: What communications have you had with Kris
20 Perry regarding Mike Wooten?
21 RESPONSE: See above.
22 QUESTION NO. 25: What communications have you had with

23 Nicki Neal regarding Walt Monegan?

24 RESPONSE: None that I can remember.

25

26 Atfidavit of Randy Ruaro

In the Maller a/Sarah Palin, Governor
Page 20 of20
 QUESTION NO. 26: What communications have you had with
Nicki Neal regarding Mike Wooten?
2
RESPONSE: None that I can remember.
3
QUESTION NO. 27: What communications have you had with
4
Janice Mason regarding Walt Monegan?
5
RESPONSE: Before Walt Monegan was removed from his
6
position as commissioner on July 11, 2008, I believe I had communications
7
with Janice Mason about an appointment with the Governor that was set for
8
May 5, 2008, at 1:00 pm to discuss department issues. I may also have spoken
9
with Janice Mason about other appointments or meetings between the
10
Governor and Walt Monegan. After Walt Monegan was terminated, I have had
11
communications about allegations of Walt Monegan that he never got
12
sufficient time to talk to the Governor, that he was removed due to his failure
13
to fire Mike Wooten, communications about press articles and news coverage
14
of the issues, and communications about legal matters. I consider these
15 conversations to be protected by the attorney client and work product
16 privileges.
17 QUESTION NO. 28: What communications have you had with
18 Janice Mason regarding Mike Wooten?
19 RESPONSE: Before Walt Monegan was removed from his
20 position as commissioner, I do not recall having any communications with
21 Janice Mason about Mike Wooten. After Walt Monegan was removed from
22 his position as commissioner, I have had communications with Janice Mason
23 about allegations of Walt Monegan that he was removed due to his failure to

24 fire Mike Wooten, communications about press articles and news coverage of

25 the issues, and communications about legal matters.

26 Affidavit of Randy Ruaro

In the Maller of Sarah Palin, Governor
Page 21 of2 J

- _...•.. _-_ ...•._ - -

 QUESTION NO. 29: What communications have you had with any
other member of the Palin Administration regarding Walt Monegan?
2
RESPONSE: The main person I have had communications with
3
regarding Walt Monegan is the Director of the Office of Management and
4
Budget, Karen Rehfeld. I believe my first communications occurred on or
5
about October 9,2007. I told both her and former Chief-of-Staff Mike Tibbles
6
via e-mail that I was concerned about "DPS pushing the Governor to quickly
7
accept and approve of plans, ideas, budget proposals, etc,,". My concern was
8
this would occur outside of the established OMB process traditionally used by
9
all the other agencies and commissioners. Karen Rehfeld responded on
10
October 9,2007, that she was "stunned" by this.
IJ
Eventually, because I could not get the issues related to the strategic plan
12
and the budget resolved, I sent out an e-mail October 17,2007, suggesting a
13
meeting on October 25,2007, with the former chief-of-staffMike Tibbles,
14
ONIB Director Rehfeld, Walt Monegan, and Audie Holloway.
15 On October 18, 2007, I received an e-mail from OMB Director Rehfeld
16 that had been sent to Walt Monegan. It said in part: "1 have to tell you though,
17 that the Governor has been pretty clear she does not want to increase the
18 budget / position count - .. ,"
19 On or about October 25, 2007, there was a meeting with Karen Rehfeld,
20 former Chief-of-StaffTibbles, Audie Holloway, myself, and I believe Walt
21 Monegan was present telephonically. To my recollection, at this meeting,
22 former Chief-of-StaffTibbles and OMB Director Rehfeld made it clear that the
23 "strategic plan' was unusual, that there is an established budget process, and

24 that they would not recommend the Governor sign it.

25

26 Affldavit of Randy Ruaro

In the Matter a/Sarah Palin. Governor
Page 22 of22
 On December 12,2007, I sent Karen Rehfeld and Mike Tibbles another
e-mail. This e-mail stated:
2
Karen / Mike: I continue to be concerned about the ability
3
of DPS to support the Governor and her budget. I have a
4 meeting scheduled for Dec. 18, at 11 :00 am, with Commissioner
Monegan, Deputy Commissioner Glass, and Colonel Holloway
5 to ask some very direct questions on the subject.
6
Also, I was advised by Lauren Rice last week that DPS is working
7 On a statewide initiative on domestic violence that could cost
tens of millions dollars a year. I think once they have their plan in
8
place, they will ask for a direct meeting with the Governor to try
9 and sell the plan.
10
I am open to suggestions to how we can reconcile the apparent
11
vision of DPS regarding public safety and the reality of the Governor's
12 budget and desire to hold down spending.
13 Karen Rehfeld responded to me on December 12, 2007:

14
Sounds like this is in addition to the Trooper plan - will need to
15 have a better idea of what this all looks like AND, how they
propose to phase in these various plans - hopefully we don't
16
have to weed through another $120 million request next year -
17

18
I called another budget meeting with Walt Monegan and others persons

19
from criminal justice agencies for January 10,2008. I sent an e-mail to Karen

20
Rehfeld about this meeting that said:
"Karen: I met with Commissioner Monegan yesterday. I remain
21
concerned about DPS' being able to testify strongly in support of
22 the Governor's operating budget numbers and their ability to meet
their mission. Despite Walt's earlier assurances this would not be
23
a problem, we seem to have backslid to ... we don't have enough
24 troopers to investigate crimes type comments....
25

26 Affidavit of Randy Ruaro

In the Maller ofSarah Palin, Governor
Page 23 of23

,,--_._._--
 I have spoken to them about this on several occasions and they
basically started shutting down communications. It may take strong
2 direction from the COS or OMB to get the message across and the
meeting today at 2:00 is a good opportunity for that if either of you
3
can attend."
4

5 On February 25, 2008, I received an e-mail from Karen Rehfeld that

6 said:

7
Hi Randy - on the top of my in basket this morning is a Feb. 15
letter from Walt Monegan to Governor Palin supporting a $1.8
8 GF add to the capital budget for the Anchorage Community Land
9
Trust that will match $1.8 million that Rep. Meyer will include in
the capital budget. We vetoed this item in FY 08. I am stunned and
10 amazed - do you know anything about this? ...
II
On March 2, 2008, I received an e-mail from Karen Rehfeld to Walt
12
Monegan that said Walt needed to work with OMB and Karen.
13

14
On March 3, 2008, I sent an e-mail to Karen Rehfeld that said:
15
I have spoken to Walt, John Glass, and Audie about working through
16 issues internally first several times. Mike Nizich has spoken with them,
17
and COS has spoken directly to the Commissioner. They seem
to just not want to accept that concept. Sorry this happened.
18

19 I had many more communications verbally and in e-mails with Karen

20 Rehfeld regarding Walt Monegan. These e-mails are preserved on the state e-
21 mail system and available for review.
22 Another person I had several phone communications with and possibly
23 e-mail communications with was the administrative services director for the
24 DPS budget, Dan Spencer. I spoke with Dan Spencer on several occasions
25 about Walt Monegan's approach to budget issues. To my memory, Dan

26 Affidavit of Randy Ruaro

In the Malter ofSarah Palin, Governor
Page 24 of24
 Spencer replied on at least one occasion that he tried to communicate with
Walt about budget issues but that ifhe raised his concerns too strongly, he
2
might end up being left out of the meetings.
3
Similarly, I had numerous communications with Commissioner Joe
4
Schmidt about Walt Monegan. I may have had conversations with other
5
persons that I do not now recall.
6
QUESTION NO. 30: What communications have you had with any
7
other member of the Palin Administration regarding Mike Wooten?
8
RESPONSE: I do not recall any such communications before Walt
9
Monegan was removed. After Walt Monegan was removed from his position
10
as commissioner, I have had communications with Karen Rehfeld, OMB
11
Director, Anna Kim, Special Assistant, Sharon Leighow, Roseanne Hughes,
12
Kelly Goode about allegations of Walt Monegan that he was removed due to
13
his failure to fire Mike Wooten, communications about press articles and news
14
coverage of the issues.
15
QUESTION NO. 31: What actions did you take involving Walt
16
Monegan or Mike Wooten?
17 RESPONSE: Before Walt Monegan was removed from being the
18 commissioner of DPS, the only actions involving Mike Wooten that I recall
19 taking were participating in the communications listed above with Todd Palin
20 and the Internet research described above. I do not recall Frank Bailey
21 mentioning Mike Wooten or Walt Monegan in the call I referenced above. I
22 do not recall taking other actions involving Mike Wooten before Walt
23 Monegan was removed.
24 Before Walt Monegan was removed, the only actions I took relating to

25 him involved actions taken in the performance of my job duties as a special

26 Affidavit of Randy Ruaro

In the Matter afSarah Palin, Governor
Page 25 of25
 assistant to the Governor. As special assistant to the Governor with
responsibility for DPS, I was essentially the Governor's intennediary. It was
2
my responsibility to be familiar with the activities of the DPS, to report to the
3
Governor and other members of the administration on those activities, to
4
monitor progress on the Governor's priorities and to coordinate legislative
5
efforts on issues such as the budget. At no point before Walt Monegan was
6
removed did any of my actions relating to him involve Mike Wooten.
7
After Walt Monegan was tenninated, I do not believe I took any other
8
"actions" involving Mike Wooten other than communications. After Walt
9
Monegan was tenninated and at the request of the Governor, I worked on
]0
drafting a press response and talking points regarding allegations of Walt
II
Monegan and Mike Wooten. I have monitored this investigation and am
12
responding to these questions.
13
QUESTION NO. 32: Are you in possessIOn of other infonnation,
14
including the actions and communications of others, regarding the events and
15
circumstances surrounding the tennination of Walt Monegan? If so, describe
16
that infonnation in detail.
17 RESPONSE: As set forth above, yesterday via DHL through my
18 attorney I submitted 1554 pages of documents. With these answers, I am
19 submitting an additional 777 pages of emails. I asked my secretary to copy all
20 e-mails between me and other identified witnesses and these e mails are what
21 are submitted herewith. I have also reviewed hundreds of other e-mails
22 responsive to the search tenns for my account sought by the Personnel Board
23 investigator, Mr. Petumonous, and through a public records request by Mr.

24 Branchflower. I believe those e-mails are presently in the custody of Mr.

25 Barnhill at the Department of Law who is perfonning a standard privilege

26 Affidavit of Randy Ruaro

In the Maller a/Sarah Palin, Governor
Page 26 of26
 review of the documents before turning them over. I also am in possession ofa
recording of Audie Holloway's December 6, 2007, interview on KTUU.
2
While I am not in possession of the e-mail, I have seen an e-mail Walt
3
Monegan sent to DPS employees in which he states he knew he was an at will
4
employee. Similarly, while I am not in possession of the e-mail, I have seen
5
an e-mail Walt sent to other commissioners where he acknowledges he did not
6
communicate well with the Governor. I also have July 19, 2008 and July 20,
7
2008 articles from the Anchorage Daily News, one of which is an opinion
8
piece authored by John Cyr, business agent for PSEA and the other article
9
which quotes him. Mr. Cyr mentions Walt Monegan's plans for adding 150
10
extra troopers to the DPS budget. Apparently Walt Monegan had
11
conversations with Mr. Cyr about his budget plans and trooper position plans
12
before discussing and reaching agreement with the Governor on such plans.
13
Further your affiant sayeth naught.
14
DATED this 8th day of October, 2008, at Juneau, Alaska.

/t~
15

16
By: _---=--=---.c.=:.~----::....:::..-----_-

17 Raidy Ruaro

18
SUBSCRIBED AND SWORN to before me, a Notary Public in and for
19
the State of Alaska, this 8th day of October, 2008, at Juneau, Alaska.
20 ......- .__ . __._-----.,..-------.

r'lotary Public 11 (\ r1
l,'v~ L'UL-~

AI
21
C (,andra Calandra
22 N~tary Public in and for Alaska
:';tate of Alaska Alaska
23 :~:.'(.-,rnlssiOIl Expires June 12, 2012
My Commission
24 Expires:~"
25

26 Affidavit of Randy Ruaro

In the Matter ofSarah Palin, Governor
Page 27 of28
 Certificate of Service
2
I hereby certify that on the 8th day of October, 2008, a copy of the foregoing
3 document was served electronically on the following:

4
The Honorable Hollis French, Chair
5 Senate Judiciary Committee
Alaska State Legislature
6 716 West Fourth Avenue, Suite 420
7
Anchorage, Alaska 99501-2133

8 Stephen Branchflower, Esq.

310 K Street, Suite 200
9
Anchorage, AK 99501
10

II

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26 Affidavit of Randy Ruaro

In Ihe Maller a/Sarah Palin, Governor
Page 28 of28