Escolar Documentos
Profissional Documentos
Cultura Documentos
9 FINAL VERSION.
10
11
12
13 April 6, 2010
14
15
16 SUSAN BYSIEWICZ
17
18
19
20
21
24 (860) 549-1850
25
18 plaintiff.
3
1 represents the democratic party. Are we having Mr.
19
20 ( Witness sworn.)
21
22 BY MR. GERSTEN:
23 Q Ms. Bysiewicz, I'm going to show you what I
4 identification.) brief.
5 BY MR. GERSTEN:
9 Circuit.
15 it?
16 A I don't remember.
25 several drafts.
6 which.
10 e-mail?
13 copy?
15 several drafts.
19 A Uh-huh. Yes.
21 well let me ask you this way: Did you transmit your
24 call.
2 e-mail as an attachment?
11 you?
12 A Yes.
15 A Yes.
21 this case?
23 attorney-client privilege.
25 differently.
1 BY MR. GERSTEN:
3 that you know of, and you understand, for filing the
12 Attorney-client privilege.
15 privilege.
17 BY MR. GERSTEN:
19 A No.
21 A Yes.
24 this case?
8
1 the question.
7 BY MR. GERSTEN:
10 order?
11 A Yes.
18 is your understanding.
23 BY MR. GERSTEN:
6 BY MR. GERSTEN:
7 Q Go ahead, ma'am?
9 question.
14 A With you.
16 A Yes.
19 A Yes.
10
6 the question.
7 BY MR. GERSTEN:
11 A Yes.
17
19
24 privilege.
25 BY MR. GERSTEN:
Brandon Smith Reporting
11
5 reasons?
8 BY MR. GERSTEN:
9 Q Is that right?
21 10:01.
22
24
12
1 10:04.
2 BY MR. GERSTEN:
6 correct?
7 A That's correct.
11 in this case?
13 the question.
23
25
2 question.
6 order.
7 BY MR. GERSTEN:
10 please?
11
13
17 BY MR. GERSTEN:
19 position?
20 A My position will be the position of my
25 correct?
14
15
17
18 A I don't know.
19 BY MR. GERSTEN:
23 testimony?
25 plaintiff.
15
1 Q You're also the secretary of state today,
2 aren't you?
3 A Yes, I am.
6 A Yes.
10 A No.
18 BY MR. GERSTEN:
19 Q Go ahead, ma'am?
21 the question.
16
12 A I am not.
19 ?
24 BY MR. GERSTEN:
17
7 whom?
8 A Leslie Mara.
18 at any time?
24 yes.
2 work, correct?
5 reviews?
9 A Correct.
14 A Yes.
18 in the office?
19 A We have policy meetings and I have frequent
22 up.
19
5 correct?
6 A Correct.
10 A We do not.
13 2010?
14 A Yes.
16 in front of people?
17 A Yes.
20
1 A No, not specifically.
6 A Yes.
9 A No.
13 office?
19 unit?
21
9 A Yes.
11 that you were the client when you worked with the
15 you perhaps.
17 question.
24 February 23rd?
22
5 A Yes.
6 BY MR. GERSTEN:
10 circumstances, correct?
12 lawyer.
17 A I couldn't say.
20 days?
23
3 BY MR. GERSTEN:
10
11 BY MR. GERSTEN:
16 that the day you indicated that you took off, not --
17 it's not on your calendar ma'am I'm just looking at the
20 A Yes.
24
1 the morning, then you went to make your phone calls for
9 BY MR. GERSTEN:
14 well.
2 A I can't remember.
6 remember.
14 correct?
15 A Correct.
19 A That's right.
20 Q Okay.
21 MR. GERSTEN: John you got any of those
23 BY MR. GERSTEN:
25 as Exhibit 21?
26
4 2002.
6 me.
8 BY MR. GERSTEN:
10 A Yes.
16 isn't it?
17 A Yes.
21 correct?
22 A Yes.
23
24 (Off-the-record discussion.)
25
27
3 it.
5 BY MR. GERSTEN:
11 2003.
13 BY MR. GERSTEN:
18 A Both things.
20 right?
24 on?
25 A Yes.
28
3 by Ted Bromley?
4 A Yes.
6 way?
10 Q Okay.
12 extra copies of --
14 problem.
21 BY MR. GERSTEN:
24 state, correct?
25 A Yes.
29
9 drafted?
10 A No.
14 this letter.
23 ma'am?
1 the letter.
4 A Correct.
6 A Yes.
9 A Yes.
11 A No.
17 A Correct.
21 correct?
22 A On occasion.
25
31
3 2007.
4 BY MR. GERSTEN:
5 Q Ma'am, this is --
8 BY MR. GERSTEN:
17 A Yes.
20 A No.
23 A Yes.
32
1 you?
4 Mr. Flynn.
7 A We worked on it together.
9 page together?
21 state, correct?
22 A Yes.
33
2 A Yes.
34
4 A Correct.
5 Q Good. And this is a typical letter you send
8 of law?
16 issues.
35
1 two?
2 A I don't know.
3 Q Okay.
4 A The number.
6 A I couldn't say.
8 A I couldn't say.
23 do?
36
2 elections division.
7 correct?
16 in drafting?
20 A Absolutely.
37
1 on?
2 A Yes.
9 Q Okay.
10 A Is another example.
12 sample?
13 A Yes.
15 A Yes.
18 A Yes.
25 one.
38
3 correct?
4 A Yes.
18 the moment.
25 correct?
39
10 at the moment.
13 A Yes.
17 A Yes.
20 A Yes.
22 correct?
40
7 that correct?
9 submitted to you.
20 office?
24 essence.
41
11 right?
12 A Correct.
16 correct?
22 correct?
23 A Yes.
3 A Yes.
8 exhibit.
12 2009.
22 it for signature.
43
8 drafted?
44
1 to federal legislation.
2 Q And this is a document you indicated to us
6 A Yes.
10
13 2009.
14 BY MR. GERSTEN:
16 correct?
17 A Yes.
45
1 A Yes.
5 correct?
18 it.
22 assistance, correct?
25 cases.
46
5 A No.
6 Q And did you write this letter?
11 Q Yes?
12 A Yes.
16 A Yes.
19
22 2009.
23 BY MR. GERSTEN:
25 that you say supports your claim that you are engaged
3 A Yes.
5 17th, 2009.
6 A Yes.
24 state, correct?
25 A Yes.
48
5 this issue.
9 correct?
10 A Correct.
23 people?
49
1 Q Thank you. Now then, ma'am, ?
5 this case?
6 A Exhibit 2?
9 like?
10 A Yes.
14 A Yes.
18 is that correct?
19 A Yes.
24 A Absolutely.
50
3 A Absolutely.
6 correct?
7 A Yes.
11 correct?
12 A Yes.
16 A Yes.
23 questions?
25 please?
51
3
4 MR. HORTON: Maybe I think it's one
8 BY MR. GERSTEN:
20 state of Connecticut?
52
3 correct?
4 A Yes.
7 yourself?
20 A Yes.
24 isn't he?
25 A Yes.
53
4 do you?
5 A No.
10
13 2010.
14 BY MR. GERSTEN:
17 of these documents?
54
1 A Oh, yes.
5 and I don't know what the top of this document is, but
7 automatic or not.
12 BY MR. GERSTEN:
18 sign it.
19 Q Okay.
23 Wes. Thanks.
24 BY MR. GERSTEN:
55
3 A Yes.
6 yesterday, correct?
56
1 with my deputy.
4 A Yes.
20 deposition?
57
2 or so.
5 ?
6 A Sorry. 12:00.
8 BY MR. GERSTEN:
11 guy?
15 Q Okay. Now --
16 A And I may have also spoken to my chief of
22 Killain?
23 A No.
58
2 A No.
6 believe.
7 Q And what was the nature of the constituent
8 request?
10 request.
13 constituent?
14 A No.
18 Q In particular?
25 BY MR. GERSTEN:
10 recount procedures.
13 morning?
17 Q Okay. Now --
23 A Yes.
25 Ferguson?
60
1 A Yes.
4 state?
5 A Yes.
7 his job?
14 successor.
17 Ferguson?
18 A Yes.
20 A Yes.
23 agency.
61
1 A Yes.
9 time?
11 Q Okay?
15 up?
21 A Yes.
62
2 staff?
6 people?
12 question?
13
18 BY MR. GERSTEN:
24 same question?
63
2 BY MR. GERSTEN:
3 Q Go ahead, ma'am?
14 BY MR. GERSTEN:
16 that.
19 election law?
22 Q Okay.
8 BY MR. GERSTEN:
12 not a lawyer?
14 legal opinion?
16 BY MR. GERSTEN:
22 A Yes.
23 Q Okay?
65
1 11:17.
7 BY MR. GERSTEN:
11 look ate them and then tell us what they are. And mark
13 them.
14
19 services report.
20 BY MR. GERSTEN:
22 exhibit --
24 Q 28 is, ma'am?
66
1 prepared by Val Ramos, who is our director of
2 constituent services.
5 A Yes.
13 A Yes.
17 testimony?
18 A Yes.
22 general?
23 MR. ZINN-ROWTHORN: Well, that's
67
4 any.
7 on.
9 BY MR. GERSTEN:
17 A Yes.
20 attorneys?
25 A Yes.
68
2 you, do they?
7 my deputy.
11 A Correct.
19 A Correct.
24 Q Okay.
69
1 correspondence, right?
2 A Correct.
5 strike that.
12 laws.
13 Q Same as you?
14 A Yes.
18 Q Same as you?
19 A Correct.
20 Q Anything else?
22 did.
70
2 however.
6 A Correct.
12 A Yes.
15 A Yes.
19 staff?
5 others.
8 A It could.
13 correct?
19 correct?
20 A Correct.
21 Q And -- now, outside of those legislative
22 sessions, how often would you and Mr. Kozik sit down
25 session?
72
19 well.
23 correct?
24 A Correct.
73
1 Correct?
2 A Yes.
4 face-to-face?
9 topics.
20 months.
21 BY MR. GERSTEN:
23 A Oh, sure.
74
4 conference or --
7 A Yes.
11 Q Great?
25 office.
75
3 A Frequently.
5 times?
6 A I can't speculate about the number, but
7 often.
10 A Yes.
11 Q Okay.
16 Q Okay.
22 A As needed.
1 office?
2 A I don't know.
7 months.
9 often have you and Mr. Button sat down and reviewed an
11 state's office?
13 office, but both Mr. Bromley and Mr. Button have been
15 hearings.
18 law, correct?
19 A Absolutely.
20 Q Okay. I'm going to go to another one because
23 law?
24 A Yes.
77
3 understood?
4 A Yes.
9 office?
10 A Correct.
22 clear?
23 A Yes.
78
1 office of your department relating to elections law
2 issues?
7 way, ma'am: Have you sat down with Mr. Bromley or with
12 A I may have.
14 one occasion?
19 example.
20 Q Okay.
22 another example.
79
4 A Correct.
6 years?
8 Q No problem?
9 A Time frame.
20 issue?
80
1 his inquiry?
8 mind.
15 A We maintain the --
81
8 the public?
9 A No.
10 Q Thank you.
12 law?
14 Q Any purpose.
16 in our office.
21
23
82
3 A I can't recall.
19 ago, right?
20 A No.
24 '90s.
83
1 was when you were employed by the Aetna?
2 A Yes.
7 A Not personally.
17 occasions, you don't use west law and you don't use
23 A Correct.
84
2 in my office.
3 Q Okay. Great.
7 A I can't recall.
11 people, correct?
12 A Yes.
13 Q Okay. Could you describe why that database
85
5 Val?
6 A Yes.
10 practice of law?
12 yes.
13 Q Okay.
16 right?
17
19
20 A Yes.
21 BY MR. GERSTEN:
25 office?
Brandon Smith Reporting
86
3 product of an attorney?
8 Christmas cards?
9 A No.
14 basis?
19 personally.
23 A No.
87
5 database?
9 individual received.
11 to this database?
14 write us a letter.
22 they received.
2 A Not sure.
5 days?
8 use of it.
11 correct?
12 A Yes.
15 of performing services?
23 there?
89
9 office?
15 A No.
19 rabbi?
90
1 A No.
2 Q Now, I'm afraid I didn't quite understand the
6 invited?
9 and I did.
12 secretary of state?
19 public attend.
22
24
25 MR. HORTON: Before you answer, Eliot,
91
7 BY MR. GERSTEN:
10
12
18 Curry, correct?
22 Curry, as I recall.
92
1 people's records.
3 state's office?
12 that?
14 published.
23 A I don't know.
3 A No.
6 A Yes.
8 strike that.
22 database?
24 Q Okay.
94
2 only ones that you reviewed and modified were the ones
4 A No.
11 A I do not.
14 yourself personally?
15 A I do not.
25 Marzik.
95
1 Q Okay. And when you say on that occasion, she
9 Q Okay.
13 approval?
96
2 use it.
5 A They did.
7 the database?
8 A It is a public database.
12 existence.
15 record?
22 A Yes.
97
8 A Yes.
12 services?
14 constituents.
16 database?
19 affiliations?
21 for the -- the chief elections office for the state and
98
5 169 towns.
9 Q Okay.
23 affiliation?
99
15 A Yes.
18 of this state?
19 A No.
24 A I have not.
100
1 you gave us yesterday. You wrote that recusal letter
3 A Yes.
7 A Which matter?
8 Q Your lawsuit.
19 A I believe so.
23 decide?
101
2 the ballot.
17 is nothing?
102
6 BY MR. GERSTEN:
10 candidacy?
11 A Yes.
13 money?
16 fundraising ability?
17 A No.
23 Q Who?
103
5 A Approximately 1800.
9 judge she would done or the courts are going to do, the
10 900 people?
15 Q Okay.
16 A I couldn't give you a number.
23 candidate?
104
6 qualified candidate?
7 A Some. I just can't tell thank you number.
9 correct?
23 A I can't.
2 correct?
16 a candidate?
106
2 you can tell this judge why she didn't give us the
15 my client?
17 harassment. Go ahead.
19 12:26.
20
22
24 BY MR. GERSTEN:
107
1 you are unwilling to respond to the question of
8 that is harassment?
11 here.
23 BY MR. GERSTEN:
24 Q Madam Secretary, you indicated that this
108
3 correct?
4 A Yes.
6 coming up shortly?
13 prepared.
20 campaign personally?
21 A I couldn't say.
24 your campaign?
25 A I don't know.
109
3 A I don't remember.
7 to.
8 Q Any documents.
12 our commitments.
16 your campaign?
17 A Yes.
19 A We have --
21 not we?
22 A Yes.
24 A Yes.
12 A Yes.
15 A No.
17 contributor?
18 A No.
19 Q Is there a sheet used for each contributor or
21 sheet?
25 A It depends.
111
1 Q Depends on what?
3 on the call.
5 the whole day off from work and spend the whole day
6 fundraising, correct?
7 A Yes.
14 understand, ma'am?
17 please?
18
20
22 mean.
112
1 you considering that to be activity you engage in in
3 A No.
5 attorney?
10
11 A No.
14 issues?
19 public policy?
20 A Yes.
113
1 A Correct.
6 law, correct?
7 A Correct.
17 A No.
19 ma'am?
23 Q Fundraising is political?
114
6 Terrible question.
8 you.
15 A That's correct.
25 state, correct?
Brandon Smith Reporting
115
8 practice of law.
11 law?
13 candidate.
16 back, please?
17
19
20 BY MR. GERSTEN:
25 business?
116
5 A The question?
9 A Yes.
10 BY MR. GERSTEN:
12 your lawyer?
13 A Yes, I would.
15 12:41.
16
18
20 BY MR. GERSTEN:
2 the moment.
11 Q Okay?
14 face-to-face?
15 A Telephone call.
17 her?
18 A No.
118
1 A Yes.
3 filed?
4 A Yes.
5 Q Okay.
9 else?
17 attorney general?
21 as a result?
119
6 correct?
7 A Yes.
11 correct?
12 A Yes.
17 correct?
18 A Yes.
21 A Ms. DeNardo.
23 sure, correct?
120
2 Connecticut.
6 correct?
21 A Correct.
24 A Our --
121
1 it to be an exception?
2 A No.
8 previously?
11 substantial question.
14 A Correct.
20 BY MR. GERSTEN:
21 Q Correct, ma'am?
23 yes, sir.
4 can you?
18 advocacy?
19 A I do.
20 Q What is the difference between the advocacy
123
4 A And regulations.
9 in the law?
10 A Yes.
11 Q Okay.
14 client.
17 12:54.
18
20
23 BY MR. GERSTEN:
124
1 talked about voting tabulating that you do do you
2 recall that?
3 A Tabulating.
125
4 A Yes.
8 fundraising?
20 A No.
21 Q Thank you.
126
4
5
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Brandon Smith Reporting