Deposition of Michael Nelson

LOWNDES COUNTY, GEORGIA
Lowndes County - Superior Court

2020CV0534
2/22/2021 11:00 AM
Beth C. Greene
Clerk of Superior State Juvenile Courts
Reviewed by: Lindsey Tutt
IN THE SUPERIOR COURT OF LOWNDES COUNTY
STATE OF GEORGIA
LEAH RODEMAKER,
Plaintiff,
v. Civil Action No. 2020CV0534
CITY OF VALDOSTA BOARD OF

EDUCATION, or in the Alternative,
VALDOSTA CITY SCHOOL DISTRICT;
WARREN LEE; LIZ SHUMOHARD; TYRA
HOWARD; DEBRA BELL; and KELISA
BROWN,
Defendants.
PLAINTIFF’S NOTICE OF FILING DEPOSITION OF MICHAEL NELSON
COMES NOW Plaintiff and hereby files the following depositions:
1. Copy of Deposition of Michael Nelson taken February 19, 2021 in the case of
Alan Rodemaker v. Ernest James Usher, III, Superior Court of Lowndes County,
Civil Action No. 2020CV0630;
THIS THE 22nd day of February, 2021
SAM D. DENNIS, P.C.
BY: /s/ Sam D. Dennis

Sam D. Dennis
Georgia Bar No. 218315
JOHN D. HOLT, P.C.
BY: /s/ John D. Holt

John D. Holt
SAVAGE, TURNER, DURHAM, PINCKNEY &

SAVAGE
BY: /s/ Brent J. Savage

Brent J. Savage
Brent J. Savage, Jr.
Samuel L. Mikell
Page 1
IN THE SUPERIOR COURT OF LOWNDES COUNTY
STATE OF GEORGIA
ALAN RODEMAKER, )
)
Plaintiff, )
)
-vs- ) CIVIL ACTION NO.
) 2020CV0630
ERNEST JAMES USHER, III, )
)
Defendant. )
__________________________________)
Deposition of MICHAEL NELSON, (via Zoom

conferencing) taken by counsel for Plaintiff, pursuant to
notice and by agreement of counsel, under the Georgia
Civil Practice Act, reported by Erika A. Sjoquist, CSR,
RPR, CRR, GA CCR 5991-4256-1008-8448, remotely via Zoom,
Savannah, Georgia, on Friday, February 19, 2021,
commencing at 1 p.m.
__________________________________________________________
Transcript Prepared By:
McKEE COURT REPORTING, INC.
McKee Court Reporting, Inc.

Page 2
1 APPEARANCES OF COUNSEL
2
3 FOR THE PLAINTIFF:
4 BRENT J. SAVAGE, ESQUIRE
Savage Turner Durham Pinckney & Savage
5
7
SALEEM "Sam" DENNIS, ESQUIRE
8 SAM D. DENNIS, PC
10
11
12
FOR THE DEFENDANT:
13
ERNEST JAMES USHER, IN PROPRIA PERSONA
14
15 (NOT PRESENT)
16
17
18
19 ALSO PRESENT:
20 Alan Rodemaker, Plaintiff
Leah Rodemaker, Plaintiff's spouse
21 Jim Wilson, Attorney at Law
Jerry Lumley, Attorney at Law
22 Brandon Oren, Attorney at Law
23
24
25

Page 3
1 I N D E X
2
3 EXAMINATION PAGE
4 By Brent Savage 4
5
Signature of Deponent Waived
6
Certificate of Reporter 60
7
8
(The Reporter's Disclosure Statement is
9 attached at the back of the transcript.)
10
11 * * * * * * * * * * * * *
12
13 E X H I B I T S
14
15 NUMBER DESCRIPTION PAGE
16 1 Covid Warning Signs 13
17 2 "February 11th Board Meeting 14
Video"
18
7 Social Media Posts 55
19
20
21
22
23
24
25

Page 4
1 - - -
2 PROCEEDINGS
3 - - -
4 MR. SAVAGE: Usual stipulations suit you guys?
5 Brandon and Jerry?
6 MR. LUMLEY: Yes.
7 MR. SAVAGE: Okay.
8 - - -
9 MICHAEL NELSON,
10 being first duly sworn, testified as follows:
11 - - -
12 EXAMINATION
13 BY MR. SAVAGE:
14 Q Mr. Nelson, I'm Brent Savage. We've never met
15 before a few minutes ago. I'm trying to help John and Sam
16 in this case. Thank you for coming.
17 Let me get a little background just so we can
18 start of start our record here.
19 Your name and where you work, sir.
20 A My name is Mike Nelson, and I work for the
21 Valdosta High Touchdown Club.
22 Q By way of background, are you a native?
23 A No. I'm originally from Charleston, South
24 Carolina.
25 Q Okay. How long have you been in Valdosta?

Page 5
1 A Since '66.
2 Q And what brought you here?
3 A My father.
4 Q Okay. Yeah?
5 A Family.
6 Q I gotcha.
7 How long have you been involved with Valdosta
8 High School football?
9 A About 19, 20 years.
10 Q And are you the director of the Valdosta High
11 School Touchdown Club?
12 A I am.
13 Q Tell me what that entails; just kind
14 background, what the Touchdown Club does.
15 A Well, fundraising mainly, you know, to support
16 our nutrition program for our football team is our primary
17 mission. But my job entails raising money, setting
18 fundraisers up, that kind of thing.
19 Q All right, sir. The money that is raised
20 through the fundraisers, you consider those private funds?
21 In other words, they are not taxpayer moneys. They are
22 moneys raised by the Touchdown Club?
23 A Right.
24 Q Okay. And as a head of the Touchdown Club,
25 tell me how long you've been doing that, roughly.

Page 6
1 A I've been doing this for about -- well, I've
2 been on the board for about 19 years. I was elected
3 president 2015, and I was made director 2017.
4 Q All right. And as the director and on the
5 board, did you have dealings with the head football coach
6 there?
7 A Oh, yes.
8 Q All right. The first thing I want to talk to
9 you about is Alan Rodemaker.
10 Do you know why he was non-renewed at the
11 beginning of 2020 as a head football coach?
12 A I have no idea.
13 Q Was this something that you dealt with on a
14 almost daily basis? I mean, the football program.
15 A Yes.
16 Q Did it come as a surprise to you or shock or --
17 maybe that's even a better word.
18 A Yes, it did.
19 Q Who wanted him out in your opinion?
20 A That's a good question. I think Warren Lee
21 maybe had a lot to do with this, but, you know, I don't
22 have any proof of that. I just feel like it.
23 Q Okay. Did you deal with Mr. Lee as the -- on
24 the Touchdown Club as well?
25 A Every now and then. Not often.

Page 7
1 Q Did he attend a lot of out-of-town games or
2 not?
3 A He -- maybe a few. I wasn't really looking for
4 him.
5 Q Okay. Mr. Lee's been on the board for a long
6 period of time.
7 Do you have a belief that he wanted a black
8 football coach --
9 A I did.
10 Q -- at Valdosta?
11 A I did.
12 Q And what's the basis of that belief?
13 A He expressed that to me.
14 Q Tell me what he said, sir.
15 A Well, he just -- you know, as far back as I'd
16 say 2010, he -- he expressed to me that we should have a
17 black coach --
18 Q Okay.
19 A -- and maybe two or three times after that, you
20 know. Just here and there.
21 Q Did he tell you why he wanted a black man as
22 opposed to a white man?
23 A No.
24 Q Do you know of any meetings among board members
25 outside of scheduled and noticed board meetings that took

Page 8
1 place about Coach Rodemaker?
2 A Through another party. I was told by a couple
3 of people they were invited to this thing.
4 Q Okay. Let's take a minute and talk about that
5 a little bit more.
6 Who was the other party that told you about
7 meetings with black board members dealing with Coach
8 Rodemaker?
9 A Shirley Hutchinson. We call her "Sweet Pea."
10 Q Okay.
11 A And Jeff Graham.
12 Q These guys will know who you are talking about,
13 but I don't.
14 Ms. Hutchison, does she work at the school or
15 how do you know her?
16 A She does a lot of cooking for our nutrition
17 program.
18 Q And Mr. Graham or Grant?
19 A Graham.
20 Q Okay. And tell me -- who is he? Just identify
21 him.
22 A He's just a fan that -- he -- you know, just
23 always been there.
24 Q Okay.
25 MR. LUMLEY: May I interrupt? We are getting

Page 9
1 broken up a little bit.
2 MR. SAVAGE: Yeah, I'm sorry. Come over this
3 way.
4 MR. LUMLEY: Did you say Jim Graham or Jeff
5 Gray?
6 THE WITNESS: Jeff Graham, G-R-A-H-A-M.
7 MR. LUMLEY: What was the first name?
8 THE WITNESS: Jeff, J-E-F-F.
9 MR. LUMLEY: Okay. I think it's the --
10 THE WITNESS: I will try to talk a little
11 louder.
12 MR. LUMLEY: It's probably my equipment.
13 MR. SAVAGE: That's all right. We will get it
14 done.
15 BY MR. SAVAGE:
16 Q Let me ask -- so flush that out a little bit
17 more for me.
18 These were meetings of black board members,
19 according to Mr. Graham and Ms. Hutchison?
20 A All they told me is they were invited to it.
21 Q Invited to?
22 A The meeting.
23 Q And they were going to talk among the black
24 board members about Coach Rodemaker?
25 A It was about Rodemaker for sure. This

Page 10
1 conversation was very short and brief. And they just, you
2 know, I asked them -- I don't even know how it came up.
3 Q Yeah. Okay. And did you attend those?
4 A Oh, no.
5 Q Okay. Do you know who did attend or who was
6 rumored to attend?
7 A I don't. I know there's a ton of rumors.
8 Q Okay. Let's explore those some. And I've had
9 this young lady down here and one other lady work for me
10 go through 15,000 posts on the event and 297s, you know.
11 And I'm going to show you some things here, but we will
12 get into that more.
13 Do you know which black board members attended
14 this?
15 A I do not.
16 Q Okay. But the subject was Alan Rodemaker?
17 A Oh, yes.
18 Q Okay.
19 A That's what I was told.
20 Q And did they tell you that the subject was to
21 follow Warren Lee's desires that they get rid of the white
22 coach and get a black coach?
23 A I don't know.
24 Q Fair enough.
25 Now, there are beliefs in this case that Warren

Page 11
1 Lee does not live within his district, right? Have you
2 heard those rumors?
3 A Yes.
4 Q And within his district would be him living on
5 -- I always get them mixed up, Magnolia or Orr Street,
6 which was in his district?
7 A I think it was more like Bunch, wasn't it?
8 Q Okay. Do you have any personal knowledge of
9 where he lives?
10 A Yes.
11 Q Does he live within his district, to your
12 belief?
13 A Well, all I know is -- about where he lives is
14 -- I've never seen a light on. Let's put it that way.
15 Q Have you looked?
16 A Yeah.
17 Q Have you driven by it?
18 A I've driven by his house a couple times.
19 Q With the intension of seeing whether, in fact,
20 he lives where he tells people he lives?
21 A Kind of -- I -- yeah.
22 Q Yeah.
23 And he has said in this case that he lived with
24 his wife, and that she -- that she lives outside the city.
25 He's testified that he's lived with his wife for the last

Page 12
1 10 years.
2 Any other information? Have you ever followed
3 Mr. Lee, just as a curiosity, to see where he was putting
4 his head down?
5 A Well, there was one night, uhm, I pulled up --
6 well, yeah. It was dark by then. I pulled up at the
7 intersection of North 41 and Val Del Road, and he was
8 right next to me. I was heading to Adel. And, uhm, I
9 wound up behind him as we went up by Smok'n Pig on -- what
10 is that Highway? -- 041, and he went down that road for a
11 good ways.
12 And I can't remember if it was before Hahira or
13 after Hahira, and he made a right turn, and I turned just
14 to see where the hell he was going. And he went down the
15 street for just a little ways and turned into a house and
16 parked in the garage behind the house.
17 I turned around and went on to where I was
18 headed.
19 Q All right. Do you consider Warren Lee to be a
20 racist?
21 A I do.
22 Q He believes blacks should get certain
23 advantages?
24 A I do.
25 Q This is, like -- I'm 67. I've practiced law

Page 13
1 for 42 years, so I've been around.
2 (Exhibit 1 marked for identification.)
3 Let me show you what's marked as Exhibit 1. Do
4 they have these exhibits?
5 MR. LUMLEY: I don't have any exhibits.
6 MR. SAVAGE: You've seen this one before? This
7 one. I'll send it to you.
8 MR. LUMLEY: I saw that.
9 MR. SAVAGE: But all make sure. We got some
10 other ones.
11 BY MR. SAVAGE:
12 Q This is part of your school board. When we
13 attempted to serve legal process in this case, the process
14 server that Mr. Dennis used was confronted by these signs.
15 And part of the reason in these cases is gathering
16 information and part of the reasons these cases is to get
17 the full story out.
18 Were you aware that two school board members
19 had threatened to shoot and kill our process server if
20 they rang the doorbell?
21 A No, I was not.
22 Q Okay. And could you just read into the record
23 what that says? That's our process server going out there
24 to serve civil litigation.
25 A "No warning. Out of fear of the spread of

Page 14
1 Covid-19, all uninvited persons who not knock
2 on my door or ring my doorbell will be shot."
3 MR. LUMLEY: I object to the form of those
4 questions.
5 MR. SAVAGE: Yeah. Okay.
6 MR. LUMLEY: I hear your answer, but.
7 MR. SAVAGE: Yeah. I mean, it's just a script.
8 Can we stipulate that's disgraceful, or not?
9 MR. OREN: I object to the form of the
10 question.
11 MR. SAVAGE: Yeah, okay.
13 BY MR. SAVAGE:
14 Q Exhibit 2, these are coming up, is a printout.
15 Do you recognize the person on that --
16 A I do.
17 Q -- print out?
18 Is that the Reverend Rose?
19 A Yes, it is.
20 Q Okay.
21 MR. LUMLEY: Will you hold that up, Mr. Nelson?
22 MR. SAVAGE: Yeah. They are coming up. Do you
23 want to take a second break? They will be coming up.
24 MR. LUMLEY: This is fine. Yeah.
25 THE WITNESS: Okay. Y'all good.

Page 15
1 MR. LUMLEY: Yes, sir.
2 MR. SAVAGE: They're easy to deal with,
3 especially since they shouldn't even be in this
4 deposition, but I want to --
5 MR. LUMLEY: That's why we're being so quiet.
6 BY MR. SAVAGE:
7 Q Now, in this -- Reverend Rose is a leader in
8 the black community?
9 A Yes.
10 Q And he says in this statement (as read):
11 "Whites have made decisions on behalf
12 of the black communities for years. But when
13 a white man is dismissed all of a sudden -- all
14 of the sudden" --
15 I'm just reading the way he wrote it.
16 -- "hell all breaks loose. The black
17 members of the board will stand together and
18 reaffirm."
19 Do you consider Reverend Rose as leading the
20 black board members, suggesting to them everyone on the
21 board put on this -- everyone --
22 "Every member put on this board was
23 put on there by black folks."
24 I've never heard such a racist thing in my
25 life. I think if a white person had said that -- take a

Page 16
1 minute and look at what our friend --
2 A Reverend Rose is a friend of mine. I've known
3 him for a long time.
4 Q Yeah. Can you help me get over the racist --
5 A Okay. What was your question?
6 Q Have you seen this before?
7 A Well, I heard that statement at the last board
8 meeting for -- for Rod. I think that's what he said --
9 Q Right.
10 A -- at that meeting.
11 Q Black board members. You were put on there by
12 blacks. Vote your race. Vote against this white man.
13 Is that what you took from it?
14 A I can -- I can't remember, but I -- I can tell
15 you, I've known Reverend Rose for a long, long time. And
16 that's something he would say. I know he believes that.
17 Q Okay. Well, that's -- that's a shame.
18 A We've actually worked together on some
19 different issues.
20 Q Okay. Do you have a belief that Warren Lee
21 does not live in this district?
22 A I do.
23 Q What is that belief?
24 A I just don't believe that he does.
25 Q Now, Warren Lee... were you aware he had

Page 17
1 numerous complaints while he was with Georgia State Patrol
2 of threatening women, of various acts of misconduct,
3 having affairs while he is on the job?
4 MR. LUMLEY: Object to the form of the
5 question.
6 MR. SAVAGE: Let me finish my question.
7 MR. LUMLEY: I thought you were through.
8 MR. SAVAGE: No, no, no, no.
9 BY MR. SAVAGE:
10 Q That -- that Williams reported him to the
11 Georgia State Patrol, Warren Lee. He's on the school
12 board. He's a leader of the pack here.
13 Clara Henderson, we believe, will testify in
14 this case that he has threatened and intimidated her, and
15 in this case, attempted to usurp power from church staff
16 members and gave a report of that to the Georgia State
17 Patrol.
18 Were you aware of that?
19 A No, I wasn't.
20 MR. OREN: Object to the form.
21 MR. SAVAGE: Okay.
22 MR. LUMLEY: I do too, Brent, to the extent
23 that I -- now that you're complete. If I interrupt
24 you, I apologize.
25 MR. SAVAGE: No, I don't care, Jerry. That's

Page 18
1 okay.
2 What we are going to do, at the end of this
3 deposition, is call on you, as lawyers for the board
4 and lawyers for board members, to launch an
5 investigation into Rush Propst, but I haven't gotten
6 there yet, about stealing money. And it's been
7 reported to the board 45 days ago.
8 BY MR. SAVAGE:
9 Q Were you aware that when I talked to Mr. Lee
10 about, you know, ethics, about whether you have a coach
11 here who's had two families -- are you aware of that with
12 Mr. Propst?
13 A I am.
14 Q Yeah. Tell me about that. I mean, I don't
15 understand how a guy, who lost his job in Colquitt County,
16 got hired here.
17 Do you have an understanding of that?
18 A I do.
19 Q What is it?
20 A Somehow, Propst was able to find out who we
21 were interviewing and was calling certain people here in
22 Valdosta and getting word to these people that were going
23 to be interviewed that this place had a racist board and
24 all of this going on with Rodemaker and just kind of
25 poo-pooed on the whole thing and discouraged these people

Page 19
1 from coming here and interviewing. And eventually, Rush
2 was the last one standing.
3 Q Let's talk about that. Propst, your coach now,
4 it's -- I don't know how much pride Mr. Lee has. He is a
5 Rush Propst believer.
6 But what's he say about the board, that is led
7 by, in my opinion, Mr. Lee, trying to discourage
8 applicants from coming over here? What are you aware of
9 him saying to these prospective applicants?
10 A Rodemaker?
11 Q No, no. Propst saying to the prospective
12 applicants about the board that Mr. Lee represents, in my
13 opinion, the majority.
14 A Uh-huh.
15 Q What was he saying? You said something about
16 they are racist; Propst was getting out there and
17 discouraging.
18 A Well, actually, it wasn't Rush.
19 Q Who was it?
20 A He was having other people --
21 Q Oh.
22 A -- do that for him, and that's kind of how he
23 operates. He uses people.
24 Q All right. And what do you attribute to this
25 Propst-led effort? What statements -- what were they

Page 20
1 saying about this board that these lawyers represent?
2 A Pretty much what I just told you, you know; the
3 board was racist and that the community was divided. And
4 just -- pretty much, that's it.
5 Q Okay. Let met hop ahead, and then I'm going to
6 move back.
7 Are you aware of high school football coach
8 Rush Propst stealing money while he has been there? And
9 has this been reported to the board and to the
10 administration at Valdosta High School?
11 A Yes, it has by me.
12 Q Okay. And I guess Mr. Lumley, whom I have the
13 highest regard --
14 A Let me say this. I did not report this to the
15 board.
16 Q Okay. I know, but I'm asking them -- I have
17 high regard both for Brandon and for Jerry -- to launch an
18 investigation to report what you are about to hear to the
19 Georgia Department of Education and to launch a full scale
20 investigation here.
21 Let's talk about Mr. Propst stealing money here
22 in Valdosta.
23 A Okay.
24 Q How do you feel about that?
25 A Well, way back in -- I think maybe even before

Page 21
1 November, I was told by -- that we had a problem down
2 there at the Winn-Dixie here that Rush had a check made
3 out to him that should have been made out to the school
4 system.
5 Well, I didn't pay any attention to it because
6 that's not my business.
7 Q Right.
8 A But I go in that store every day. That's my
9 grocery store.
10 Q Okay.
11 A Then January the 6th, I get a phone call from
12 the president of the Touchdown Club telling me we got a
13 problem down at Winn-Dixie; that they paid for advertising
14 in the stadium that they never saw; that I needed to go
15 down there and talk to them, get with the manager.
16 And apparently, the whole thing was a scam
17 anyway. I don't know -- for y'all that don't know, we
18 have fake companies every year call local business and act
19 like they are with the school system.
20 MR. LUMLEY: What kind of companies?
21 MR. SAVAGE: Fake companies.
22 MR. LUMLEY: F-A-K-E. All right.
23 THE WITNESS: This whole thing started as a
24 scam to begin with. These companies will call local
25 businesses and act like they are with our school

Page 22
1 system and tell them that, you know, for X number of
2 dollars, we will put your logo on a calendar or send
3 out T-shirts, something like that.
4 Well, these companies called Winn-Dixie, said
5 that for $700 that we would put a sign in our
6 stadium.
7 Well, a couple of weeks later, I guess, I don't
8 know exactly how much later, the manager wanted to
9 send his payment of $700. So he calls a friend of
10 his, Phil Jones, who has a local sports radio show.
11 The manager of Winn-Dixie knew that Phil could get in
12 touch with Rush Propst to find out where to send the
13 check.
14 So Coach Propst sends word to make the check
15 out to him and gave him an address to mail it to.
16 Well, I checked out the address, and it was Coach
17 Propst's address in Moultrie, Georgia.
18 Now, the manager thought it was fishy -- he
19 should have thought that right off the bat -- decided
20 to make the check out to Rush Propst and United
21 Specialty Advertising, which was the fake company
22 that originally contacted Winn-Dixie. And the -- I
23 don't know if it was Stephanie Propst or Rush, but
24 they deposited that in their personal account and got
25 the money.

Page 23
1 Then once this all came to light, he decided to
2 write us a check to pay for it.
3 MR. LUMLEY: Who did? Propst?
4 THE WITNESS: We caught him.
5 BY MR. SAVAGE:
6 Q He or Mrs. Propst put it in their personal
7 account?
8 A Yeah.
9 Q Kind of like stealing a pocket book and when
10 you've got the pocket book in the jail cell, well, you
11 say, "Let me give you the pocket book I just stole back."
12 A Well, when he got caught, he wrote a check.
13 MR. OREN: Sorry to interrupt, but who did the
14 check go to?
15 THE WITNESS: To Valdosta Touchdown Club.
16 MR. OREN: Okay. Thank you.
17 THE WITNESS: I made a deal with the Winn-Dixie
18 people. Give me $400. That will cover the cost of
19 making the sign, and I'll put you in a
20 thousand-dollar spot.
21 Then we went to Rush and told him what we were
22 having to do to make this good, and the
23 superintendent told him, "You need to write a check
24 to us, to the Touchdown Club."
25 BY MR. SAVAGE:

Page 24
1 Q And the superintendent is Mr. Cason?
2 A Right.
3 Q When did this occur, roughly, just the
4 framework at the time?
5 A Well, when I first talked to Winn-Dixie and
6 discovered what went on, that was January the 7th. And
7 that's when I went to Dr. Cason's office and informed
8 Dr. Cason what was going on.
9 Q And what did you tell Dr. Cason on January 7th?
10 Basically what you told me --
11 A The same thing, yeah.
12 Q -- that Rush is taking money meant for
13 advertising for Touchdown Club and put it in his own
14 account?
15 A Uhm-hum.
16 Q What was Dr. Cason's reaction to that? Because
17 I like Dr. Cason, actually.
18 A I do too.
19 Well, Dr. Cason told me that he was going to
20 have to report this to the PSC because that, if he didn't,
21 he would -- his certificate would be at risk.
22 Q That acronym stands for what, PSC?
23 A Professional Standards Commission.
24 Q Okay. Is it your belief, knowing Dr. Cason to
25 be an honorable guy, that this was reported to Mr. Lumley

Page 25
1 and Mr. Oren's clients, the school board? I mean, he
2 would pass this on if this happened.
3 A I thought he would probably go to the school
4 board and the PSC.
5 Q Okay. Has anybody other than Dr. Cason talked
6 about it?
7 A Nobody.
8 Q Any school board members, whether black or
9 white, come forward to you and say, "This is very
10 troubling for us"?
11 A Well, I wanted to go to a school board member,
12 but Dr. Cason advised me not to talk to any school board
13 people.
14 Q Do you know this has been referred to the
15 district attorney?
16 A I do not.
17 Q Okay. Now, let's get beyond the Piggly Wiggly?
18 A Let me say --
19 MR. LUMLEY: Winn-Dixie. Wait a minute.
20 Winn-Dixie.
21 MR. SAVAGE: Huh?
22 MR. LUMLEY: It's Winn-Dixie.
23 MR. SAVAGE: What do you mean?
24 MR. LUMLEY: It's not Piggly Wiggly.
25 MR. SAVAGE: Oh, Winn-Dixie. Okay. Well, I

Page 26
1 get confused. I'm excited to have the truth come out
2 and -- I'm sorry.
3 MR. LUMLEY: That's okay.
4 MR. SAVAGE: I've done this a long time. I
5 should be more professional.
6 MR. LUMLEY: Yeah.
7 THE WITNESS: Let me say the manager at
8 Winn-Dixie is reluctant to go forward with this
9 because he's afraid he's going to get in trouble with
10 his company.
11 MR. SAVAGE: Okay. All right.
12 BY MR. SAVAGE:
13 Q Well, let's talk about what -- when Warren Lee
14 voted yes and Ms. Shumphard and Ms. Howard --
15 Is that your client, other client, Jerry? I
16 get them confused.
17 MR. LUMLEY: Ms. Brown.
18 MR. SAVAGE: Ms. Brown.
19 MR. LUMLEY: Warren Lee and Ms. Kelisa Brown.
21 BY MR. SAVAGE:
22 Q When they voted to have Rush -- what was --
23 what I take from Mr. Lee's view here is he doesn't give a
24 damn about ethics. He doesn't give a damn about, you
25 know, being on the Board of Education as far as holding

Page 27
1 high standards as long as we win football games, as long
2 as we win football games.
3 Now, with Mr. Propst, what did you know, as a
4 person in this community, about his background prior to
5 him being hired? Let's talk about wives and girlfriends.
6 We will break it down.
7 A I mean, I know what everybody else knows. I
8 mean, I hear it like everybody else has heard it; through
9 ESPN, newspaper articles, you know.
10 Q Three kids and a wife in Birmingham.
11 MR. LUMLEY: Before you move on, I want to
12 object to that prior question.
14 MR. LUMLEY: I object to the form of it.
15 MR. SAVAGE: Yeah, that's fine.
16 BY MR. SAVAGE:
17 Q You know, at some point, this is -- this has
18 got to embarrass everybody. It embarrasses me to be in a
19 country that's -- where our school boards are. But, you
20 know, I don't have a vote down here.
21 Now, how about three kids and a girlfriend over
22 here in Georgia. Were you aware of that? She's now his
23 wife, right?
24 A Yes.
25 Q Okay. Have you heard and assume that the

Page 28
1 school board knew about this?
2 A Yeah. They had to have known it.
3 Q Yeah.
4 A The whole country knew it.
5 Q Yeah.
6 How about his dealings with Colquitt County?
7 As far as whether he was terminated there, was that
8 well-known in this community?
9 A Yes.
10 Q And the basis of him being terminated there,
11 what did you understand?
12 A Well, I really -- I've heard so much out of
13 Colquitt, I really don't know exactly why they let him go.
14 I mean, there's so many rumors and innuendos flying around
15 about Rush. I mean, there's no doubt he was a handful.
16 Q Yeah, I'll say.
17 I would like get to see -- who is his ex-wife
18 over there. Shirley is his wife presently, correct?
19 A Stephanie.
20 Q Stephanie is the ex-wife over there.
21 Did she change her last name or she still has
22 the last name "Propst." Do you know?
23 A The present wife?
24 Q No. The second one. The one in Birmingham.
25 A Oh, I don't -- I don't even know. I don't know

Page 29
1 anything about that lady.
2 Q Okay. We are going to loop back. I want to
3 talk about break into Los Angeles, the kid that plays
4 quarterback for the University of Southern California,
5 Garcia.
6 A Jake Garcia.
7 Q Yeah. Did he end up here in Valdosta?
8 A Oh, yeah.
9 Q Do you know anything about Rush Propst paying
10 for his parents to come over here?
11 A Well, he facilitated that.
12 Q Okay. Let's talk about that. What do you know
13 about Propst dealing with Jake Garcia and how did the
14 University of Miami come in?
15 A Well, he asked me to come up with $2,500 a
16 month for him for four months.
17 Q Propst said this to you, personally?
18 A Oh, yeah.
19 Q Wow.
20 A Two players.
21 Q Okay.
22 A Had me raise 2500 a month cash for Jake Garcia
23 and $850 a month cash for Amari Jones.
24 Q Amari Jones is a quarterback out of Kentucky?
25 A No. He's a quarterback out of Atlanta.

Page 30
1 Q Atlanta, okay.
2 And what was this -- what was this funny money?
3 A "Funny money" is the way he liked to call it.
4 Q Yeah.
5 And what was the purpose of this money, the
6 2500 for the Garcias and 850 bucks for the quarterback
7 from Atlanta? I thought he was from Kentucky.
8 A To pay rent.
9 Q Pay rent for the parents?
10 A For the family.
11 Q Yeah.
12 Do you know whether this has been reported to
13 the administration?
14 A No.
15 Q Okay. Well, we will get it over to them this
16 week to see whether they will do anything.
17 A Thank you.
18 Q And we will give a copy to Mr. Lumley and
19 Mr. Oren with the hope -- and I have high respect for
20 them. I'm not being flippant.
21 MR. LUMLEY: Let me assure you I'm going to
22 report it. And I am going to report it to the
23 Georgia High School Association as well.
24 MR. SAVAGE: Good.
25 MR. LUMLEY: I'm going to tell them they need

Page 31
1 to come see this witness.
2 MR. SAVAGE: Yeah, good.
3 MR. LUMLEY: That's all I can do. I don't know
4 why y'all haven't done it already. That's got to be
5 reported. I'm going to do it.
6 MR. SAVAGE: Well, you know, I don't represent
7 the guy.
8 THE WITNESS: I'm glad to hear that.
9 MR. SAVAGE: I never met him until 10 minutes
10 before the deposition, Jerry.
11 MR. LUMLEY: Well, I don't understand.
12 MR. SAVAGE: Don't be mad at me.
13 MR. LUMLEY: Your client is a certificated
14 teacher in Georgia. He has a duty to do that.
15 MR. SAVAGE: Well, how do you know he knew
16 about it?
17 MR. LUMLEY: I don't know why it hasn't been
18 done.
19 MR. SAVAGE: Don't accuse him of that.
20 MR. LUMLEY: It needs to be done just as this
21 witness said it happened.
22 MR. SAVAGE: Nobody knew what he's going to say
23 until he said it.
24 MR. LUMLEY: Well, he said it. I'm reporting
25 him as well.

Page 32
1 MR. SAVAGE: Especially not representing Warren
2 Lee, come after us for ethics.
3 THE WITNESS: I'm not a certified teacher. I
4 don't have any certificate.
5 MR. LUMLEY: I'm talking about Coach Rodemaker
6 is a certified teacher.
7 MR. SAVAGE: How do you know -- I'll shut up.
8 MR. LUMLEY: He heard just like I just heard
9 it.
10 MR. SAVAGE: How do you know?
11 MR. LUMLEY: I am assuming he's going to report
12 it now just like I'm going to report it.
13 THE WITNESS: Good. That's what we want.
14 MR. LUMLEY: How come you haven't done it?
15 THE WITNESS: I told my superintendent to do
16 that.
17 MR. LUMLEY: About Garcia.
18 THE WITNESS: I went to my superintendent on
19 January 7th. I told him about Winn-Dixie, I told him
20 about Garcia, and I told him about Amari --
21 MR. LUMLEY: Okay.
22 THE WITNESS: -- for the sole purpose of this
23 being reported.
24 MR. LUMLEY: I can promise you, I personally
25 will report it.

Page 33
1 THE WITNESS: Well, I'm happy to hear that.
2 MR. SAVAGE: Well, you can take Mr. Lumley at
3 his word.
4 MR. LUMLEY: And it will be done.
5 MR. SAVAGE: Don't get after me and Alan
6 Rodemaker. We never heard this in our life. So, I
7 mean, who would imagine that your people are on the
8 school board supporting a man like this.
9 MR. LUMLEY: We are --
10 MR. SAVAGE: He's fast. He said he wants to
11 you fast track the report, and I'm sure Mr. Lumley
12 will do that.
13 MR. LUMLEY: It will be this afternoon.
14 THE WITNESS: Oh, thank you.
16 MR. LUMLEY: I don't have a choice.
17 THE WITNESS: I'm glad you don't.
18 MR. SAVAGE: Yeah, no kidding. You are a
19 breath of fresh air. That's what I call you. All
20 right.
21 BY MR. SAVAGE:
22 Q Now, so that -- Dr. Cason has -- you told him
23 about this situation with Jones and Garcia back in the
24 beginning of January, that area?
25 A January the 7th.

Page 34
1 Q Okay.
2 A I can even tell you what time.
3 Q What time?
4 A 10:30.
5 Q Okay. Have you heard any more from the school
6 board about that?
7 A Haven't heard a word. They've not returned my
8 phone calls. They've not tried to call me. I go to
9 Winn-Dixie every day, and I've asked the manager, it's
10 probably a week ago, has he heard from our school system.
11 No, he hasn't.
12 I talked to Phil Jones, the person that the
13 manager went to, to find out where to send the check. He
14 hadn't heard from anyone either.
15 That's why I'm happy to hear Mr. Lumley is so
16 anxious to report this. I thought it would be done on
17 January 7th.
18 MR. LUMLEY: I have an obligation. I'm not
19 anxious.
20 MR. SAVAGE: Well, it's an interesting
21 dichotomy between you're gaining this information
22 representing a school board member and reporting the
23 school system. But God bless you.
24 MR. LUMLEY: Yeah.
25 MR. SAVAGE: Now, I would withdraw. I mean,

Page 35
1 I'm serious, Jerry. I love you.
2 MR. LUMLEY: You will withdraw, what?
3 MR. SAVAGE: Well, you are reporting your
4 client. I mean, the school board, ultimately, who
5 hires and fires this stuff. Ostensively, they have
6 known about it a month.
7 MR. LUMLEY: I'm not reporting my client. I'm
8 just reporting what I've heard. Who that falls on, I
9 don't know.
10 MR. SAVAGE: Well, you got the right to hire
11 and fire. That's what you've been saying here.
12 MR. LUMLEY: I don't represent the school
13 system.
14 MR. SAVAGE: Yeah, yeah. Well, okay. Look.
15 I'm only saying because I like you, and you know that
16 down in your heart. You may forget it some days, but
17 you know that.
18 BY MR. SAVAGE:
19 Q Yeah. Okay. Now, after Alan Rodemaker is
20 non-renewed, do you know anything about the attempt to
21 hire a black man, Maurice Freeman, as football coach of
22 Valdosta High School?
23 A What I know is rumor.
24 Q Go ahead.
25 A I just heard that they attempted to hire him,

Page 36
1 and that he was not interested in the job. And
2 eventually, he was talked into putting his application in
3 a week before the interview started. And then the Sunday
4 before the week that the interview started, that he pulled
5 his application.
6 Q Okay. I understand he had a good team at
7 Brooks County?
8 A He's got a good team. He and his wife both
9 have a good paycheck. And I mean, he really would have
10 been leaving a really good situation.
11 Q That's before they ran into my client, the
12 Benyard brothers.
13 A I don't know who they are.
14 Q They are the guys in Irwin County.
15 A Oh, yeah?
16 Q They are good.
17 A I know they are.
18 Q One of them is good. He even got shot when he
19 was an 11th grader. That's why I know them. Shot by a
20 police officer over there, his son. So he's a great kid.
21 Now, any other African Americans that you know?
22 I mean, what -- what -- the school board has said -- and
23 what people have taken -- are advancing as defense is --
24 we hired a white man, Rush Propst, and we are proud of
25 that hire. And we -- we're here to win football games.

Page 37
1 So why do you think that we are racist?
2 Were there any other black coaches that you
3 know of them interviewing?
4 A I know that they -- we had, uhm, several lined
5 up. I don't know if they ever got to interview or not. I
6 mean.
7 Q Reed from north Georgia?
8 A That's a white man.
9 Q Okay.
10 A John Reid.
11 Q I was thinking of Kasim Reed.
12 A Oh, Kasim?
13 Q Maybe I got the wrong last name.
14 A No, I think you are right.
15 MR. LUMLEY: Mayor of Atlanta.
16 THE WITNESS: Yeah.
17 MR. SAVAGE: They want him to be the coach.
18 You guys want him to be the coach.
19 MR. LUMLEY: Fine.
20 MR. SAVAGE: You don't know.
21 MR. LUMLEY: There's a John Reid, though.
22 THE WITNESS: Yeah, there is a John Reid we
23 were interested in that was at Rome and still at
24 Rome.
25 MR. LUMLEY: Yeah.

Page 38
1 MR. SAVAGE: Right.
2 BY MR. SAVAGE:
3 Q Let's move forward to -- suffice it to say, are
4 you aware, by being affiliated the quarterback club, that
5 a number of black candidates were attempted to be
6 interviewed for the job before Propst shows up?
7 A The way this works is there's a committee, and
8 that committee, uhm, is sworn to secrecy. So, you know,
9 anything you hear, it's really not fact or you shouldn't
10 consider it fact.
11 I mean, what we are hearing is what Rush Propst
12 was digging up and feeding our community. You know, he
13 was sabotaging our search from day one.
14 Q That's unbelievable. Calling the people that
15 are sticking with him, at least this week, racists; that
16 this is a racist board, which I'll subscribe to among the
17 -- if they follow Reverend Rose. "Vote your color." I've
18 never heard anything like that in my life. "Vote your
19 color." "Vote black."
20 That he was sabotaging your recruit; he being
21 Rush Propst.
22 A So what is it you want to know?
23 Q What do you know about that?
24 A I mean, like I've said, somehow he would find
25 out who we were going to interview and get word to these

Page 39
1 candidates that that this was not the place to go, you
2 know.
3 I guess some came and interviewed. I don't
4 know. I do know there were some that pulled their
5 application. And eventually, Rush was the last man
6 standing. And I think that's when everybody kind of got
7 on board with him, including me. I mean, there just
8 wasn't any other place to go.
9 Q Well, he's a winner.
10 A Well, he's a winner if he cheats. I don't
11 think he's a winner if he plays the game right.
12 Q Doesn't apparently matter to the certain
13 members of the school board?
14 A It matters to me, and I never realized that
15 like a do now.
16 Q Let's move on with Coach Propst and the six
17 kids. That's a lot of money to come up with.
18 Do you think that's why he steals?
19 A Yes. I think he's under a lot of pressure from
20 his health, from finances. I mean, he's in a bad, bad
21 shape.
22 Q Well, let's talk about other things.
23 Recruiting players. Do you know anything about that
24 beyond paying rent for a quarterback out of Atlanta's
25 family and the quarterback out of California? You know,

Page 40
1 making sure their rent was paid. Do you know anything
2 about him recruiting players?
3 A Well, I'll just tell you, I guess he'd been
4 here maybe two or three weeks. I was in his office. I
5 went in there to find out about how he wanted the
6 Touchdown Club organized. And I knew it was much
7 different than what he had in Moultrie, and he gets up
8 from his desk, walks around, and shuts the door.
9 He says, "Now, I don't know how you are going
10 to feel about this, but I want to be truthful. We need
11 some funny money."
12 Q Funny money.
13 A And I said, "How much funny money you need?"
14 He goes, "I don't know; 10, $15,000. I always
15 need to keep at least $10,000 cash right here in my desk
16 drawer." And he says, "Now there's some things you can't
17 know about; only me and one other person."
18 Q Who is that?
19 A I -- I think the other person was the wallet in
20 his back pocket, to tell you the truth. But...
21 Q Oh, gosh.
22 A Anyhow, that's just how it all got started.
23 And, you know, it's -- it was just a mess. I just... I'd
24 say that I got caught up in it.
25 Q Okay.

Page 41
1 A I never been asked to do those kind of things,
2 by Rodemaker, Gillespie, Tomberlin, Darlington, O'Brien,
3 all these coaches I worked with in the past. Just --
4 Q Funny money?
5 A Funny money.
6 Q Now, how about recruiting players? Do you know
7 anything about that?
8 A That's what he does. I mean, he's trying to
9 turn us into a recruiting machine. I mean, he's told me,
10 he's talking to as many as 15 people, 15 kids all over the
11 country.
12 Q Trying to get them down here to play with the
13 Wildcats?
14 A He's got college recruiters helping him.
15 Q From what universities?
16 A All of them. All -- they are from all over.
17 Q This funny money aspect, did he implicate any
18 college coaches to do the same thing?
19 A No. They never talked to me. Well, do we have
20 to go there?
21 Q That's okay. They can't ask you any questions,
22 so?
23 MR. LUMLEY: I would like an answer to that.
24 THE WITNESS: I'm not going to give it. Lock
25 me up.

Page 42
1 MR. LUMLEY: I don't have the authority to lock
2 you up.
3 THE WITNESS: That's good to hear because I'm
4 not going to answer that question.
5 MR. SAVAGE: Okay.
6 MR. LUMLEY: That's fine.
7 BY MR. SAVAGE:
8 Q Did Coach Propst discuss with you about raising
9 or getting money for payment of players and families?
10 A Only as far as for their rent. But of course,
11 you know, shortly after that, we fell out over that. Once
12 I got into it, I didn't like it.
13 Q Right. He wants to get rid of you, doesn't he?
14 A Oh, yeah. He's trying to get rid of me.
15 Q And what is it? Is she the second wife? What
16 number is she?
17 A The second wife.
18 Q The second Mrs. Propst.
19 A Yeah. He tells me that's not the case. But,
20 you know, he says one thing, but he walks another way.
21 I've been watching the way he walks and quit listening to
22 the way he talks.
23 Q Uhm-hum.
24 A So, yeah, I believe he's trying to take down
25 our Touchdown Club that's been here for over 70 years.

Page 43
1 And I think he's trying to take me down for his wife to
2 have my job, which only pays $500 a week. I don't know
3 why the hell he's going to so much trouble.
4 Q Funny money.
5 A I think it's -- the end game for Rush Propst is
6 to be able to get his hands on cold cash.
7 Q Now, do you know of any recordings about
8 Propst's ideas to raise funny money, things of that
9 nature?
10 A Let's skip that one.
11 Q Okay.
12 A We will bring it out of him, maybe, but not
13 right now.
14 Q Okay. Do you know of any complaints about
15 Coach Rodemaker prior to his nonrenewal? Did you hear
16 people complain about him as president of the Touchdown
17 Club? Do you know the reputation of Rodemaker?
18 A Oh, yeah. He's great to work with. I miss him
19 a lot.
20 Q And do you have an opinion as to whether he was
21 non-renewed because of his race? And I will tell you, we
22 have had some testimony from Bill Love, the former
23 chairman of the board -- you know Bill -- that he believes
24 Coach Rodemaker was non-renewed because he's a white man.
25 And also from Kelly Wilson, who I think is heroic, to

Page 44
1 stand up; that that was a factor in him being non-renewed,
2 that he was a white man?
3 A It sure looks that way. I mean --
4 Q Is that your belief as part of the Touchdown
5 Club?
6 A Until I see some facts to prove otherwise, I
7 mean, it just looks that way. I mean, I never knew him to
8 be that way. And I mean, Rod and I were pretty close, and
9 we met almost on a daily basis, you know.
10 I don't think he was racist, and I don't see
11 just -- I don't understand why they let him go. I never
12 heard a reason really. Of course, you know, if you -- I
13 talk to my friends in the black community. They say it
14 wasn't racism. I talk to my friends in the white
15 community. They say it is racism.
16 Q Have you talked to Reverend Rose about this?
17 A I have.
18 Q And what does he say? He is saying, "Vote your
19 color, man."
20 A Reverend Rose has really never commented on
21 that. His comment is pretty much what -- what you got
22 right there is, you know, when a -- a white man gets
23 hired, all hell breaks loose. But a black, you know,
24 that's his deal.
25 Q It go beyond that in this Exhibit 2. Black

Page 45
1 members of the board will stand together and reaffirm.
2 Black power.
3 A As far as my conversations with Reverend Rose,
4 it was more about when, you know -- everybody raises hell
5 because a white man got fired and not a black man. It
6 really never went much further than that.
7 Q But he tells these board members, who listen to
8 him -- I mean, he's an influential man, is he not, sir?
9 A Well, not so much.
10 Q In the black community, he is?
11 A Not so much.
12 Q Well, he says every one -- every one of the
13 members put on this board was put there by black folks.
14 That's going beyond, you know -- well, they just complain
15 when a white man gets fired, not like they used to with
16 black. He says that everybody's put here by black folks
17 and you should remember that.
18 A Uhm-hum.
19 Q Wow. Now, let's talk -- you know, my opinion,
20 a non-issue --
21 MR. SAVAGE: I filed my motion, Jerry, you will
22 get it, about the alcohol issue.
23 MR. LUMLEY: I just haven't seen it.
24 BY MR. SAVAGE:
25 Q How about Propst getting out there and taking

Page 46
1 private money for alcohol for a restaurant? Have you
2 heard about that? I've heard rumors about he and his wife
3 getting out there, spending 60 bucks --
4 A That was --
5 Q -- on alcohol and leaving a 35-cent tip.
6 A 37 cents; cut him short.
7 Q And that was paid for by private funds? A
8 booster?
9 A Yes. This happened the night before last.
10 Wednesday night. A booster --
11 Q Yeah.
12 A -- was in a local restaurant. Rush and
13 Stephanie came in. The booster sent his waitress over to
14 Rush and Stephanie's table and told them that he was going
15 to get the tab. Enjoy your meal. And, uhm, when my
16 booster got the tab, it was 60-something dollars, mostly
17 alcohol. He's telling me this. I didn't see it.
18 Q Okay.
19 A And that the bartender and everybody at the bar
20 was real upset about it. They were visibly intoxicated
21 when they walked out. And, you know, he had to drive to
22 Moultrie to go home. So if they were intoxicated -- and
23 plus, they were wearing Wildcat stuff sitting in there,
24 drinking, getting shots and just made everybody mad. The
25 whole restaurant was aware of it before the evening over.

Page 47
1 That's really -- outside of that, I haven't really heard
2 anything else around here yet.
3 Q We talked about him stealing the money that got
4 replaced after the superintendent went to him.
5 Are you aware, through rumor or otherwise,
6 about him owing a bunch of money over there in Moultrie?
7 A Oh, yes.
8 Q Tell me about that a little bit.
9 A Well, I just know that, uhm, he owes a lot of
10 money. I know that he has his check is garnished, and I
11 understand there's several people in line for that
12 garnishment.
13 Q Okay.
14 A I know that -- and he told me that he was so
15 broke that a local businessman over in Moultrie was paying
16 his mortgage in Moultrie, 2500 a month, and his rent here
17 in Valdosta in the high end area, Timberloo (phonetic),
18 1800 a month.
19 Q That's nice there. Did he have a booster
20 paying for that?
21 A No. This is somebody out of Moultrie paying.
22 Q Yeah. A booster over there; gets them to do
23 it. Now, let me look at this, and I'm kind of going
24 around a little bit. I've got about five more minutes,
25 and then we will take a break.

Page 48
1 A Good. I need a cigarette.
2 Q Okay. I'll go out there and smoke one with you
3 just for companionship. I don't smoke, but --
4 MR. LUMLEY: I didn't think Brent smoked.
5 THE WITNESS: My mouth is watering for one
6 right now.
7 BY MR. SAVAGE:
8 Q Were you aware of the situation where Warren
9 Lee was written up by the Georgia State Patrol about a
10 complaint from a temp; he took 20,000 bucks from her and
11 had an affair with her while he was married?
12 A No. I never heard anything about that.
13 Q It's dated 2006. Had Warren Lee ever told you
14 what he expects to accomplish as a board member? I mean,
15 a good friend, Mr. Wilson here, we go back to history and
16 stuff. I mean, does he ever talk to you about, you know,
17 that the United States is supposed to be a shining light
18 on the hill, according to the Tocqueville, things like
19 that? Has he ever told you about the high aspirations he
20 has? I guess he wants a black man to be the --
21 A No; never talked to him, like, on those -- no.
22 Q Okay. Other than Mr. Lee, is there anybody
23 that you believe is not in their district and essentially
24 lying to the voters of Valdosta saying, "I live in the
25 district where I'm voted in, but, in fact, I don't live

Page 49
1 there"? Anybody other than that not have a proper address
2 when they apply and vote?
3 A Are you talking about a present board member?
4 Q Yes.
5 A Not that I'm aware of. But I do want to say
6 something about Warren that makes me think that maybe he
7 is a little on the racist side.
8 A few years back, I had to raise -- I guess
9 it's about a half-million dollars for our Jumbotron. And
10 I went to companies, like Coca-Cola, Wiregrass, Houston
11 Clinic, you know, large companies that I thought would
12 have that kind of money to help us out with.
13 When I went to the Board of Education to
14 present this to them, Warren piped up and asked me, "How
15 many black advertisers are on that sign?"
16 And I said, "None."
17 And he goes, "Well, how come you didn't go to
18 any black businesses?"
19 And I was, like, "Well, I'm looking for 25,
20 $30,000. I wasn't thinking about a color. I was thinking
21 about who would have that kind of money."
22 And so, he kind of raked me over the coals in
23 front of the Board of Education.
24 Q What do you say about that? I mean, you are
25 trying to raise the money to get the Jumbotron in there

Page 50
1 that really -- most of the players are black, so it helps
2 them. What does he do to rake you over the coals that
3 way?
4 A Well, I think because there's -- you know, he
5 said there's no black advertisers. And in fact, I -- you
6 know, one of our board members, who did purchase an ad on
7 that thing for $30,000, said to him, "Well, Warren, I'll
8 sell you mine." And Warren declined to purchase.
9 Q Were you aware that Bill Lott (phonetic), in
10 his testimony, said he had been there, personally, privy
11 to Warren Lee, and heard him saying, "We got to get us a
12 black coach," that he said that.
13 A I wasn't aware of that. But Warren has said
14 that to me.
15 Q Yeah, yeah.
16 Now, what --
17 MR. SAVAGE: Jerry, do you know the name of the
18 fraternity -- I'm just trying to get a little help
19 here -- that Mr. Mitchel and all them belong to? Is
20 it Omega Psi Phi?
21 MR. LUMLEY: I don't know, Brent.
23 MR. LUMLEY: I was asking you if that was the
24 --
25 MR. SAVAGE: That was Mr. --

Page 51
1 MR. LUMLEY: It's in one of the depositions.
2 MR. SAVAGE: Yeah.
3 BY MR. SAVAGE:
4 Q You know, when you non-renew a man, who's won a
5 state title -- a lot of my questions are about whether or
6 not they non-renewed; fair, black, white or in between.
7 Did the board ever tell you? Did they ever
8 tell the folks why they non-renewed him?
9 A No.
10 Q Now, these rumors that I've asked the lawyers
11 for the board members and the board to take a position to
12 put out a press release to say that these rumors that have
13 been put out in the wake of our nonrenewal are false, they
14 declined to do that so far. But -- that Alan Rodemaker
15 was involved in taking 40,000 bucks.
16 A I doubt that.
17 Q Yeah. I mean, did you ever have any problems
18 with Alan Rodemaker that you are having with Rush Propst;
19 that he wanted funny money?
20 A Oh, no.
21 Q That he was paying for good football players'
22 families to move to this community and paying their rent?
23 A No, no, no, no. Never anything like that from
24 any coach I've ever worked with. This is the first time
25 I've ever run into this kind of stuff.

Page 52
1 Q Yeah. But I mean, this is being tolerated by
2 the board down here. I'll make the assumption that they
3 are good --
4 A Well, I don't know that the board is aware of
5 it.
6 Q Well, they will be. But they are -- they -- I
7 have enough respect for Dr. Cason that if you told him, at
8 the beginning of January, that Propst is stealing money,
9 putting it in his personal account --
10 A Well, I told him about that business at
11 Winn-Dixie.
12 Q Yeah; that he put the money in his own account.
13 A Uhm-hum.
14 Q Well --
15 A At that time, I didn't know where the money
16 went. I just told him what the situation was, and Rush
17 had a check made out to him that should have been made out
18 to the Touchdown Club.
19 Q Okay. And there were these situations with
20 money being spent on Garcia and Brown. Is Brown the
21 quarterback's name?
22 A Uhm-hum.
23 Q Has he gone to the University of Kentucky? Is
24 that why I'm confused.
25 A No. He's got another year left.

Page 53
1 Q Is he still here?
2 A Yep.
3 Q Oh, man. This is -- this is unconscionable.
4 This is amateur sports.
5 Any of that with Alan Rodemaker; suggesting
6 that we need funny money to get us some players?
7 A Oh, Rod?
8 Q Did Alan Rodemaker ever say that?
9 A No. Matter of fact, Rod used to always say,
10 "We are going to win with the guys we raised." I've heard
11 him say that several times.
12 Q Yeah. Did you used to attend practices from
13 time to time? Attend practices?
14 A Who? Me?
15 Q Yeah.
16 A All the time.
17 Q Was Alan Rodemaker -- there's some complaint
18 from Warren Lee. I don't put much stock in what Warren
19 Lee says. But he said that he's tough on the players,
20 Rodemaker. And he was headed with Propst -- I mean,
21 head-butting, hasn't he?
22 A Well, that's football coach training, but
23 besides that, he head-butted a guy with a helmet on.
24 Split his head wide open.
25 Q Well, I mean, but that --

Page 54
1 MR. LUMLEY: Not a player, a coach.
2 THE WITNESS: Look, I'm a football guy and
3 that's nothing to me.
4 BY MR. SAVAGE:
5 Q But Mr. Lumley's client takes great exception
6 to that.
7 A Well, Mr. Lumley may. But I don't.
8 BY MR. SAVAGE:
9 Q His client said that he, Alan, was too tough on
10 the football players, and that he yelled at a coach at a
11 game. I guess he said it was over -- I asked him, "Has he
12 ever seen Nick save it?"
13 And he said, "Well, he ain't a Wildcat coach."
14 And I asked him, "Why do you tolerate Rush
15 Propst"?
16 A I never seen Warren at a practice. So I don't
17 know how Warren could ever comment about what Rod or any
18 other coaches do, and I never seen him at a practice.
19 Q Yeah. Okay. In any of these things, did --
20 was it raised that Mitchell, Hudson, you know, school
21 administrators are members of Phi Beta Sigma? One of
22 their slogans is "Buy black and pay it back." Is that
23 kind of consistent with what Lee is doing when he says we
24 are the blacks?
25 A I don't know.

Page 55
1 Q Were you aware that Warren Lee, as a member of
2 the board, insisted on passing on applications that in the
3 upper right-hand corner -- and this is after the order to
4 desegregate -- that in the upper right-hand corner, "C"
5 for Caucasian or "A" for African American, so he knew what
6 color people he was going to --
7 A I am not aware of that.
8 Q Yeah. This $40,000, has that propagated
9 throughout the community that Rod stole money when -- that
10 he gets on a podcast with thousand of hits saying he's got
11 firsthand information?
12 A I saw that podcast.
13 Q And it's crazy, isn't it?
14 A Yeah, it is. It's -- it's -- that didn't
15 happen.
17 Q Yeah. But can you imagine saying stuff like
18 that? It's horrible. And then we got Jerry Hadley, and
19 him saying that he's got -- "it's blowing in the wind," I
20 guess is what he said, the money that he was taking,
21 things of that nature.
22 Uhm, where am I here? Here we go. Jerry
23 Hadley. This is the kind of stuff that you propagate when
24 you say or hire people with a secret wife and three kids
25 because all we care about is winning and get rid of Alan

Page 56
1 Rodemaker.
2 Were you aware that in the community, Jerry
3 Hadley was putting out on the worldwide web?
4 A Are they talking about Rod here?
5 Q Yeah. They are lying about him.
6 A Well, I can guarantee you...
7 Q Crazy, isn't it? That's Exhibit 7. Just so we
8 have a record of it.
9 "Well, the news that broke said coach used
10 school money and misused at least $40,000 and had -- and
11 had mouth -- mouth school."
12 I just need to catch up. I'm a bad generation
13 for this lingo. And had mouth school?
14 MR. LUMLEY: Can you hold that up so I can see
15 it?
16 MR. SAVAGE: Yeah, we will in a minute. You
17 can't read anyhow. It's your e-mail.
18 BY MR. SAVAGE:
19 Q "And had mouth school while interviewing with
20 Lowndes and Colquitt for jobs." So basically --
21 A I mean, I don't know what that means. I'm
22 older than you are.
23 Q No, you are not.
24 A I am.
25 Q Well, it's nice of you to say.

Page 57
1 A 65.
2 Q 67.
3 A Oh, two years.
4 Q That's why we understand each other.
5 A Well, I don't understand that.
6 Q Were you aware that Dr. Cason and
7 Dr. Richardson, both of whom I think very well of --
8 A I --
9 Q They are the last hope.
10 A I love Dr. Richardson.
11 Q They are the last hope of the school -- has
12 said they don't know of anything that Alan Rodemaker did
13 wrong.
14 A Yeah.
15 Q Whatever happened to Hal Mumme? I'm just
16 interested.
17 A What do you mean, what happened to him?
18 Q Well, he was in there running with Rush.
19 A Yes.
20 Q What happened to him?
21 A We didn't feel like he was the guy, even though
22 Rush was the other choice. We felt like it was that bad.
23 Q That's amazing to me. I mean, if I were
24 Mr. Lumley -- and I kind of think like him -- I would want
25 to know what we know concretely about Propst, who has been

Page 58
1 hired by the racist board -- his words, not mine -- that
2 he's gone around, getting potential candidates through
3 surrogates, saying, "You don't want to -- that job," with
4 an ulterior motive; that he wants to be the last guy
5 standing; Propst, that he uses surrogates to report to the
6 board that hired him was a racist scrooge. That's what
7 you are telling me, isn't it?
8 A Say that again.
9 Q He used surrogates, other people?
10 MR. LUMLEY: Not me. Not me. Propst.
11 MR. SAVAGE: You are like Trump. You think
12 people is talking about you all the time.
13 MR. LUMLEY: Well, you did say "if I was
14 Mr. Lumley."
15 MR. SAVAGE: I would want to know about this.
16 Considering he can't ask any questions, I'm trying to
17 go ahead.
18 BY MR. SAVAGE:
19 Q That he is using surrogates -- he being Rush
20 Propst -- is using people, because he knows he's being
21 interviewed, to contact the interviewees and saying, "This
22 racist board is somebody you don't want to work for."
23 That's what you told me, is it not?
24 A Yeah. I mean, they would probably tell him
25 anything now. Obviously, I was not there when these

Page 59
1 people made the phone call, but somehow they were picking
2 these candidates off. And I know they were telling them
3 that they had to have been talking about our Board of
4 Education, and they had to have been talking about the
5 community divide. You know, anything they can think of,
6 I'm sure they said to run these applicants off. They were
7 dropping like flies, one right after the other.
8 Q Yeah. Well, I don't blame them.
9 A I wouldn't -- don't blame them either, you
10 know.
11 MR. SAVAGE: Why don't we take a break.
12 Madam Court Reporter, can I get an expedited
13 copy? I would like to file this transcript on
14 Monday, and I'll pay for it.
15 COURT REPORTER: Okay.
16 - - -
17 (Whereupon, deposition proceedings
18 were concluded at 2:11 p.m.)
19 (Signature has been waived by the parties.)
20 - - -
21
22
23
24
25

Page 60
1 C E R T I F I C A T E
2 GEORGIA:
3 LOWNDES COUNTY:
4 I, Erika A. Sjoquist, Certified Court
5 Reporter for the State of Georgia, do hereby certify:
6 That the foregoing deposition was taken
7 before me on the date and at the time and location
8 stated on Page 1 of this transcript; that the witness
9 was duly sworn to testify to the truth, the whole
10 truth and nothing but the truth; that the testimony
11 of the witness and all objections made at the time of
12 the examination were recorded stenographically by me
13 and were thereafter transcribed by computer-aided
14 transcription; that the foregoing deposition, was
15 typed, is a true, accurate and complete record of the
16 testimony of the witness and of all objections made
17 at the time of the examination.
18 I further certify that I am neither related
19 to nor counsel for any party to the cause pending or
20 interested in the events thereof.
21 Witness my hand, I have hereunto affixed my
22 official seal this 22nd day of February, 2021, at
23 Savannah, Chatham County, Georgia.
24 ________________________________
ERIKA A. SJOQUIST, CSR, RPR, CRR
25 GA CCR 5991-4256-1008-8448

Page 61
1 COURT REPORTER DISCLOSURE
2
3 Pursuant to Article 8.B. of the Rules and
Regulations of the Board of Court Reporting of the
4 Judicial Council of Georgia, I make the following
disclosure:
5
I am a Georgia Certified Court Reporter. I
6 am here as an employee of McKee Court Reporting, Inc.
7 I am not disqualified for a relationship of
interest under the provisions of O.C.G.A. Section
8 9-11-28(c).
9 McKee Court Reporting, Inc. was contacted
by Savage Turner Durham Pinckney & Savage to provide
10 court reporting services for this deposition.
11 McKee Court Reporting will not be taking
this deposition under contract that is prohibited by
12 O.C.G.A. 15-14-37(a) and (b).
13 McKee Court Reporting, Inc. has no
exclusive contract to provide reporting services with
14 any party to the case, any counsel in the case, or
any reporter or reporting agency from whom a referral
15 might have been made to cover the deposition.
16 McKee Court Reporting, Inc. will charge its
usual and customary rates to all parties in the case,
17 and a financial discount will not be given to any
party to this litigation, except in circumstances as
18 agreed on a case-by-case basis.
19
20
21
22
23
______________________________ Date: 2/22/21
24 ERIKA A. SJOQUIST, CSR, RPR, CRR
GA CCR 5991-4256-1008-8448
25

Deposition of Michael Nelson

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Deposition of Michael Nelson

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LOWNDES COUNTY, GEORGIA

Lowndes County - Superior Court

v. Civil Action No. 2020CV0534

CITY OF VALDOSTA BOARD OF

PLAINTIFF’S NOTICE OF FILING DEPOSITION OF MICHAEL NELSON

COMES NOW Plaintiff and hereby files the following depositions:

THIS THE 22nd day of February, 2021

SAM D. DENNIS, P.C.

BY: /s/ Sam D. Dennis

BY: /s/ John D. Holt

SAVAGE, TURNER, DURHAM, PINCKNEY &

BY: /s/ Brent J. Savage

Deposition of MICHAEL NELSON, (via Zoom

McKEE COURT REPORTING, INC.

McKee Court Reporting, Inc.

McKee Court Reporting, Inc.

McKee Court Reporting, Inc.

4 MR. SAVAGE: Usual stipulations suit you guys?

5 Brandon and Jerry?

6 MR. LUMLEY: Yes.

7 MR. SAVAGE: Okay.

10 being first duly sworn, testified as follows:

14 Q Mr. Nelson, I'm Brent Savage. We've never met

16 in this case. Thank you for coming.

17 Let me get a little background just so we can

18 start of start our record here.

19 Your name and where you work, sir.

20 A My name is Mike Nelson, and I work for the

21 Valdosta High Touchdown Club.

22 Q By way of background, are you a native?

23 A No. I'm originally from Charleston, South

25 Q Okay. How long have you been in Valdosta?

McKee Court Reporting, Inc.

2 Q And what brought you here?

7 How long have you been involved with Valdosta

8 High School football?

9 A About 19, 20 years.

10 Q And are you the director of the Valdosta High

11 School Touchdown Club?

13 Q Tell me what that entails; just kind

14 background, what the Touchdown Club does.

15 A Well, fundraising mainly, you know, to support

16 our nutrition program for our football team is our primary

17 mission. But my job entails raising money, setting

18 fundraisers up, that kind of thing.

19 Q All right, sir. The money that is raised

20 through the fundraisers, you consider those private funds?

21 In other words, they are not taxpayer moneys. They are

22 moneys raised by the Touchdown Club?

24 Q Okay. And as a head of the Touchdown Club,

25 tell me how long you've been doing that, roughly.

McKee Court Reporting, Inc.

2 been on the board for about 19 years. I was elected

3 president 2015, and I was made director 2017.

4 Q All right. And as the director and on the

8 Q All right. The first thing I want to talk to

9 you about is Alan Rodemaker.

10 Do you know why he was non-renewed at the

11 beginning of 2020 as a head football coach?

13 Q Was this something that you dealt with on a

14 almost daily basis? I mean, the football program.

16 Q Did it come as a surprise to you or shock or --

17 maybe that's even a better word.

19 Q Who wanted him out in your opinion?