Capital Reporting Company Wahid, Ron CONFIDENTIAL 05-25-2010

IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA Civil Division RJI GOVERNMENT STRATEGIES, INC. and RJI CAPITAL CORPORATION,

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Plaintiffs/Counter-Defendants,: vs. C.A. No. 2009 CA 75158

TANYA A. RAHALL and HILLIARD A. ZOLA, Defendants/Counter-Plaintiff (RAHALL).

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Washington, D.C. Tuesday, May 25, 2010 Deposition of: RON WAHID called for oral examination by counsel for Defendant/Counter-Plaintiff (Rahall), pursuant to notice, at Nossaman, L.L.P., 1666 K Street, Northwest, Suite 500, Washington, D.C., before Shari R. Broussard, RPR, CSR, of Capital Reporting Company, a Notary Public in and for the District of Columbia, beginning at 10:11 a.m., when were present on behalf of the respective parties:

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Capital Reporting Company Wahid, Ron CONFIDENTIAL 05-25-2010

47 1 hired her in November 2008?
A

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I believe that she had good contacts on

Capitol Hill and had the skill set to be a good lobbyist.

Q

All right.

And you promoted her in

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November 2008; is that right?

A

What

define promote.

Well, was she given a title at RJI

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Government Strategies after November of 2008?

A
Q

Yes,

she was .

And what title was she given? Vice President either Government Relations

or Congressional Relations.
Q

And what does it mean to be a Vice President

of RJI?
A

This one was more of a marketing title.

So

she

she had -- she would have been the number one

person for congressional lobbying in this particular case.

Q

So you gave out titles like vice president

just as marketing titles?

A

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No.

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Tanya because she wouldn't use her brother Nick Rahall?

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Q

Never. You're certain of that? Never. Let me direct your attention to paragraph 25 It says, "In 2 008, Defendant Rahall

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Q

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of the complaint.

threatened to undermine RJI's government relations business by informing Mr. Humphrey that the 'doors on Capitol Hill will be closed' to RJI, its employees and

clients if she did not receive what she wanted on certain issues." Do you see that?
A
Q

Yes. What specifically did Ms. Rahall say to

Mr. Humphrey?
A

You have to ask Mr. Humphrey.

But what was

relayed to me is similar to what is written.

Q

Right.

What did Mr. Humphrey relate to you?

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A
Q

I don't have exact recollection. Well, tell me the best recollection you

have, Mr. Wahid.

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That the doors on Capitol Hill will be

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closed.
Q

What does that mean? It means access to Capitol Hill will be

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closed.
Q

You're saying Tanya Rahall has the ability

to shut all the doors on Capitol Hill to a company? Is that what you're saying?
A

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I'm not saying what ability she has or

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doesn't have.
Q

Well, this is your complaint.

I'm asking

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you what to the best of your recollection did Tanya Rahall say to Mr. Humphrey?
A

I don't know.

It was a conversation between

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Mr. Humphrey and Ms. Rahall.

Q
A

When was this conversation? You have to ask Mr. Humphrey. Was it documented anywhere? Mr. Humphrey discussed it with me at some I don't remember exactly when. You don't know when in 2008 this happened? No, I don't. You have to ask Mr. Humphrey.

Q
A

point.
Q
A

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Capital Reporting Company Wahid, Ron CONFIDENTIAL 05-25-2010

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keep you from walking up and meeting with -A

It's not what I believe.

It's what she

said.
Q

I'm asking what you believe.

Did you

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understand her to say that she could prevent you from going up to Capitol Hill and meeting with a congressman?
A

I did not believe what she can do or not,

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but I did believe that she would try.

Q

Okay.

And tell me how a person could close

down the doors to Capitol Hill to Ron Wahid.

A

I don't know what her mechanism is.

She's

the one who made the threat.

Q

Okay.

But you can't remember any specific

words she said to you? MR. GARSKE: testified to? THE WITNESS: BY MR. KNIGHT:
Q

Other than what he's already

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Other than what I've said?

All right.

And what was she complaining

about to you when she made the threat?

A

I don't specifically recall, but a lot of

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