STACY CATHLEEN TEBO DEPOSITION IN THE RIVERS’ CASE PART 2 OF 2

1· BY MR. LARKIN:
·2· · · Q.· ·The second issue in this complaint is — by
·3· Ms. Rivers, or the second paragraph, rather, concerns
·4· a date, March 27th, 2017, at approximately 2:40. I
·5· guess this culminates, she alleges, with you basically
·6· responding to her by yelling, “Just stop it.”
·7· · · · · ·I imagine you had an opportunity to review
·8· her complaint.
·9· · · A.· ·I did.
10· · · Q.· ·What can you tell me about that particular
11· day and that issue?
12· · · A.· ·Well, it really had started — let me give
13· you some background.
14· · · · · ·We had been in the midst of the audit during
15· March.
16· · · Q.· ·Is this the Ken Daniels audit?
17· · · A.· ·Yes.
18· · · Q.· ·Okay.
19· · · A.· ·Okay.· So both Ken and his assistant, whose
20· name is Nikki, had been calling and emailing, you
21· know, for various things, because they gather all
22· kinds of information.· He came there, retrieved some
23· items.
24· · · · · ·And about this time during March is when
25· things really seemed to deteriorate in the office as

all this was going on.· There were questions, and
·2· Anita became defensive about questions that were being
·3· asked from Nikki, the auditor’s assistant.· She had
·4· asked, I think, verbally something to Anita, and then
·5· had emailed a similar, I guess, question to Pam.· And
·6· I heard Anita saying, “Why do they ask the same thing
·7· twice?” You know, da-da-da-da-da, just complaining
·8· about the questioning and maybe that they asked Pam
·9· something that they’d already asked Anita.
10· · · · · ·And there were still problems with the
11· deposits and it not reconciling, and Anita was adamant
12· that that wasn’t her responsibility and it wasn’t her
13· fault that it wasn’t completed.· So that was kind of
14· going on, because the audit isn’t done overnight.
15· There’s several weeks of information gathering that
16· you have to work with the auditor to go through.
17· · · · · ·So we were doing that.· And because it’s just
18· basically the three of us, and we’re set up in such a
19· way that, pretty much, I can see Anita from my office;
20· Pam, I can’t see.· There’s a strange little window in
21· between Pam’s office and Anita’s, and Pam is hard of
22· hearing.· So I can talk to Anita easily, not really
23· Pam.· So a lot of these conversations we can have
24· without physically going or picking up the phone and
25· talking to each other.· So I can hear all these
comments that Anita is making about the audit and her
·2· irritability with what’s going on.
·3· · · · · ·At the same time, we’re having a FDLE audit,
·4· and that’s causing some consternation, because the
·5· police department is on the same server as the town,
·6· and they can’t be on the same server as the town
·7· without these proper firewalls and such that separate
·8· FDLE from — you know, for security reasons.· There
·9· were all kinds of things that we were noncompliant
10· with it, and this was going on too.
11· · · · · ·And I was having a problem with Tracy, the
12· police chief, because she had some reserve officer who
13· was doing her IT for free, but it was clear that he
14· didn’t know what he was doing.· And when that audit
15· came back with so many horrible things wrong with it,
16· I won’t get into all the reasons why, but I let him
17· go, and I said that our IT person would take care of
18· this, because we had a time thing we had to have it
19· done or else, you know, she said they’re going to shut
20· us down.· So I didn’t want that to happen.· So that’s
21· going on at the same time as this other thing is going
22· on.
23· · · · · ·So I’m having my IT people put in a new
24· server.· And so they’re putting it in in Tracy’s old
25· office, which is behind Pam’s office.· When the fire
station was built, Andrew moved over to the fire
·2· station, and I moved Tracy up front because, honestly,
·3· I was worried about Joe Griffin coming in there with a
·4· gun; so she would be at the front.
·5· · · · · ·So they’re putting the server in there.
·6· Anita is not all that great with computers, and she
·7· does something to get rid of the icon — this is the
·8· week of March 13th — to get rid of the billing
·9· software icon.· And there’s a computer at her desk,
10· and there’s one at the front counter.· And she asks
11· Andrew for assistance because he’s young, and he’s
12· good with computers.· I think he’s like 28.· So
13· anybody under 30 knows more about computers, right?
14· · · · · ·So he does something, but at the same time he
15· points — he gets the icon back, but it’s pointed
16· towards the old server instead of the new server.
17· Instead of asking for the IT guys, she just asks for
18· him.· So that creates a problem with the cash that
19· she’s trying — the transaction she’s trying to put
20· through, and none of that is showing up.· And I think
21· she’s probably giving — I think she’s probably given
22· me — I think she’s printed every email she sent
23· something from that day about that.
24· · · · · ·And she takes off that Thursday and Friday.
25· So she would have normally put the late fees onto the
accounts the next day, which is the 16th, onto the
·2· utility billing, but she goes off for a couple days.
·3· We have the Azalea Festival that Saturday.· Pam does
·4· her job, doesn’t put the late fees on the accounts,
·5· which makes Anita mad when she finds out that that
·6· happens or didn’t happen, as the case is.· And then
·7· the qualifying for the election is wrapping up at the
·8· same time on that Tuesday, which was the 21st, I
·9· think.
10· · · · · ·So we don’t know who paid cash for their
11· bills that Wednesday, Thursday, or Friday.· So I have
12· to start getting involved in trying to figure this all
13· out, at the same time our financial auditor is telling
14· us, “Hey, you guys have been overbilling all your
15· sewer customers for the last 17 months, and you’ve
16· been underbilling your commercial garbage customers
17· for less amount of time,” I forget how much it was.
18· So it was a big problem.
19· · · · · ·Anita, when I asked her about this garbage
20· thing, was very defensive and said, “I’ve never known
21· how to change the rates.· I don’t have anything to do
22· with that.· I don’t know how to do it.· Nobody ever
23· taught me how to do it,” which isn’t true.· I remember
24· when Pam and her had an argument almost April of last
25· year about the garbage rates.
·So I felt like she decided to do this —
·2· because there was such a huge problem with the
·3· billing, and we were in trouble with our auditor
·4· because we had just messed up everybody’s account so
·5· badly, I feel like that spawned her to create this
·6· side issue or diversion to another place and to take
·7· it away from, really, a bad mistake that she had made,
·8· but ultimately we had all made it because we didn’t
·9· check behind her and, you know — so that falls on me
10· too.
11· · · · · ·But the cash thing that was happening, that
12· happened as a result of the change in the servers.
13· While I was trying to figure that out, I was also
14· trying to figure out how to credit the sewer customers
15· and how much those credits would be, because they
16· weren’t for all of them, because there’s tiers on the
17· sewer rates.· So I had asked Andrew to help also.
18· · · · · ·So Pam, Andrew, myself — and I was very
19· unfamiliar with the billing software before any of
20· this happened, never went in there, ever.· We started
21· looking in there, and I heard Anita making comments
22· about “people checking behind me” and, you know, just
23· things like that.· She was upset that people were
24· looking into it, but we were trying to figure out how
25· much we owed people and who all it affected.· And
because the three of them had went to the training for
·2· that software, I asked for Andrew’s help.
·3· · · · · ·So on — let me look at my notes.· Because
·4· this was all, really, in one week that the cash thing
·5· happened.
·6· · · · · ·She was mad about the qualifying also.· That
·7· was another thing that happened also during that week,
·8· because Helen — I know I’m kind of all over the
·9· place, and you’re like, “What?”
10· · · · · ·Helen Miller is so intent on being mayor
11· again that she will do anything to be mayor again.· So
12· she was trying to get others to run, like this Nicole
13· Williams, who is Anita’s good friend, because there
14· was two seats that were up, and those were Rhett
15· Bullard and Tonja Brown.· Now, she didn’t want either
16· of them to be re-elected; so she was trying to get
17· others to run.
18· · · · · ·Nicole Williams picked up a packet but never
19· brought it back.· At the last minute, when Anita
20· wasn’t there on the 17th, I think it was, of March, we
21· had two people come in the last minute to pick up a
22· packet.· Now, the qualifying closes at noon on
23· Tuesday.· So it’s very last minute.· Tom Moore, who is
24· on the Helen team; and then this other man, Richard
25· Marshall, who used to be on the city council
·Richard Marshall was the one who — he turns
·2· in 16 petitions; you need 15.· Two of them weren’t any
·3· good because — well, one of them wasn’t filled out,
·4· and the other one lived outside of town limits.· But
·5· because he turned it in so late, they go to the
·6· supervisor’s office for verification, it was too late.
·7· So he only had 14, but he waited until the last
·8· minute.· That’s bad.
·9· · · · · ·So Anita was really, really upset about that,
10· and she, like, went on a rant.· And I wrote this in
11· here, because she talks about Pam saying the word
12· “damn.”· Wow.· She’s like, “I a hate fucking liar.”
13· · · · · ·Because Pam came to my office to say, “Oh,
14· this is going to be bad.· You know, Laura checked the
15· signatures.· There was only 14.”
16· · · · · ·And I said, “Well, you know, what are you
17· going to do?· You have to have 15.· There’s nothing to
18· be done.”
19· · · Q.· ·Did you have any role in determining whether
20· Mr. Marshall or Mr. Moore —
21· · · A.· ·No.
22· · · Q.· ·– could run?
23· · · A.· ·So I talked to Pam, and I know Anita hears
24· the whole conversation.· So Pam goes back to her
25· office to make the call, and as she’s talking to
Richard Marshall, Anita is saying, “I hate a fucking
·2· liar,” and she’s just stomping around her area, and
·3· then goes over to Tracy’s office.
·4· · · · · ·She’s talking about Pam, because Pam was
·5· calling Richard to say what happened with those two
·6· petitions that were not counted by the supervisor’s
·7· office.· So she was angry about that, and I think she
·8· was very upset by that because she really wanted —
·9· she doesn’t like either Tonja or Rhett and would like
10· to see them off of the council and would like to see
11· Helen be mayor again.· So —
12· · · Q.· ·This is the same election that she wanted to
13· serve as a poll —
14· · · A.· ·Yeah, right.
15· · · Q.· ·– supervisor?
16· · · A.· ·Poll worker.
17· · · Q.· ·Poll worker?
18· · · A.· ·Uh-huh.· Right.
19· · · · · ·The election was just on April 25th, and it’s
20· 7:00 to 7:00 just like other elections are, 7:00 a.m.
21· to 7:00 p.m.
22· · · · · ·So that was on the 21st.· The 23rd, which was
23· two days later, is when the — Nikki from the
24· auditor’s office was calling asking about the
25· commercial garbage rates, and I already talked about
that a minute ago.· So this was all kind of happening
·2· at one time.
·3· · · · · ·Also that day I saw her slam her phone down,
·4· and she was just verbally complaining that Andrew
·5· never answers her calls.· That was another instance
·6· where she did that.
·7· · · · · ·That — later that day, I was on the intercom
·8· in my office.· I was on the phone, but I had
·9· intercomed Andrew over in the fire station, and we
10· were trying to work through the overbilling and the
11· underbilling, and I could not get into the IMS
12· software on my computer.· So he was trying to tell me
13· the reports that he could try to run and how we could
14· try to figure out.
15· · · · · ·So we’re just trying to talk through it, and
16· he said, “Oh” — now, this is March 23rd.· He said,
17· “There’s not” — “there aren’t any late fees on
18· anybody’s accounts.”
19· · · · · ·I said, “Oh,” because I realized, well, Anita
20· had been off on that past Thursday and Friday when she
21· should have done that.· So while we’re talking, I send
22· an email to Anita telling her to put the late fees on
23· the accounts.
24· · · · · ·As soon as she read that, she got up from her
25· chair and was like, “You didn’t put the late fees
on?” you know, real loud to Pam.· And when you try to
·2· talk to Pam through that — it’s like a sliding little
·3· clear window — I don’t know why it was there in the
·4· first place, but she’s — I told her she needs a
·5· hearing aid.
·6· · · · · ·So she comes out of her office because Anita
·7· is yelling at her about this, her not doing her job of
·8· putting the late fees on the accounts, and it is now
·9· the 23rd, and they should have went on the 16th.· So
10· I’m trying to talk about fixing the billing rates on
11· the phone, and meanwhile she’s yelling at Pam about
12· “You didn’t do this.”
13· · · · · ·And then Pam said, “Well, nobody does payroll
14· when I go off on vacation or take the day off.”
15· · · · · ·And then Anita is like, “Well, nobody never
16· told me how to do payroll.· Nobody ever teaches me
17· anything.”· And then she goes on that where she’s
18· saying that kind of thing again.
19· · · · · ·They were so loud that I couldn’t hear what
20· he was telling me, and he could hear everything that
21· was going on, obviously, because, you know, it’s
22· probably from, you know, that wall to that wall that
23· they’re that far away from me.· So it’s quite easy for
24· him to hear.
25· · · Q.· ·Andrew Greene?
A.· ·Right.· Now, Cecil had been at the fire
·2· station at the same time, because I asked him later
·3· about it, Cecil Brownfield, who is a volunteer
·4· firefighter, and he’s a police officer.
·5· · · · · ·So I didn’t intervene in it.· I didn’t want
·6· to intervene in it because it was like, “Oh, man.” I
·7· just kept doing what I was doing on the phone.
·8· · · Q.· ·If I may, when you say you didn’t want to
·9· intervene in it, you’re talking about the conversation
10· between Anita and Ms. Tomlinson?
11· · · A.· ·Right.
12· · · Q.· ·And if I understand correctly, Ms. Rivers is
13· attempting to blame Ms. Tomlinson for the late fees
14· not being added on —
15· · · A.· ·Yes.
16· · · Q.· ·– during the time period when she was off.
17· · · A.· ·Yes.
18· · · Q.· ·Okay.· But the late fees were a job that
19· Ms. Rivers was supposed to be doing?
20· · · A.· ·Yes.
21· · · Q.· ·But she was off during that period of time,
22· and I guess, if I’m understanding correctly,
23· Ms. Rivers was assuming or claiming that her duties
24· should have been taken over by Ms. Tomlinson while she
25· was off
· · A.· ·Yes.· Correct.
·2· · · Q.· ·So we don’t have any late fees, as Andrew
·3· Greene discovers.
·4· · · A.· ·Right.
·5· · · Q.· ·And then you say, “Why don’t we have any late
·6· fees?” or something to that effect, and Ms. Rivers
·7· attempts to blame Ms. Tomlinson, and then they have
·8· some type of argument?
·9· · · A.· ·Yes.· I just sent her an email saying,
10· “Please put the late fees on,” because I’m talking on
11· the phone about the sewer overbilling at the time and
12· how to fix that big problem.
13· · · · · ·So that gets out of control and —
14· · · Q.· ·How does it get out of control?
15· · · A.· ·It’s just — you know, it shouldn’t — it
16· just shouldn’t happen in a — you know, if somebody
17· came in at that time, that would have been really
18· embarrassing to town hall.
19· · · Q.· ·Was Ms. Tomlinson and Ms. Rivers raising
20· their voices at each other?
21· · · A.· ·Yes.
22· · · Q.· ·Were they using profanities?
23· · · A.· ·No, I don’t think so.
24· · · Q.· ·Okay.
25· · · A.· ·No
· Q.· ·What was Ms. Tomlinson saying?
·2· · · A.· ·She said that nobody does her job when she
·3· leaves in payroll.
·4· · · Q.· ·I see.· All right.
·5· · · A.· ·And then Anita started complaining that
·6· nobody ever teaches her anything, she doesn’t know how
·7· to do payroll.· She was the one that was talking or
·8· yelling the most.
·9· · · Q.· ·Okay.
10· · · A.· ·Pam ended up just going back to her office,
11· and I just kept talking to Andrew when I could through
12· the yelling that — I don’t know how long it lasted,
13· maybe a solid minute.· It seems like a long time when
14· it’s happening.
15· · · · · ·I also didn’t feel well that day.· I was
16· starting to get a sinus headache.· So I was just
17· trying to work through this, wanted to get home, go
18· home at a reasonable hour.
19· · · · · ·As soon as Pam left at like 5:02, and usually
20· Anita would always leave at 5:00 also, she said to me
21· while I was at my desk, she was still at her computer,
22· she says, “How is it that the whole fire department
23· knows about our conversation earlier?”
24· · · · · ·And I said, “Are you talking about you and
25· Pam arguing?
She’s like, “Yeah.· The whole fire department
·2· knows that.”
·3· · · · · ·And I assume she just means Cecil, because he
·4· happened to be there in the fire station, because I
·5· later asked Andrew who was in the fire station with
·6· him.
·7· · · · · ·So I said to her, “Well, probably because I
·8· was talking to Andrew while you and Pam were yelling
·9· at each other, and he heard everything.
10· · · · · ·”No, that’s impossible.· He couldn’t hear it.
11· That’s not true.· You know, people just talk around
12· here,” da-da-da-da-da, that kind of thing.
13· · · · · ·I said, “You were very, very loud, and it was
14· clear to hear every single thing that was said.”
15· · · · · ·So then she said, “I know who protects who
16· around here.· I know who’s on whose team and who
17· covers up for who,” and she was saying it all like
18· rapid fire and from her desk to where I was.
19· · · · · ·And I was typing, trying to finish my work.
20· And I was just like, “What?”· I do like this at her,
21· and she says, “It’s cool, Stacy.· Don’t worry about
22· it.· It’s cool.· It’s cool.”
23· · · · · ·And then she said some more sentences kind of
24· like that, basically, about how she’s on a different
25· team, and it was — it’s just the way she talked to
me.· It was so disrespectful.· She was loud, and I
·2· just — I didn’t even — like, where is this coming
·3· from?· You know, she just leaves, slams the door for
·4· the day.
·5· · · · · ·And the day after that — because that was, I
·6· think, a Thursday.· Whenever I saw her the next day —
·7· she might have been off the next day after that.· The
·8· next time I saw her, I made a point of trying to — I
·9· had went in this old house that was foreclosed.
10· · · · · ·There’s this really old house that’s big, and
11· it looks like it’s haunted, and I had gotten to go
12· into it.· And I came back and was trying to talk to
13· her about it.· She didn’t want to talk, but I was
14· trying to engage her in conversation, and it seemed
15· like she was okay.· There was this really old safe in
16· the wall from the 1800s, and I was talking about that
17· and about what these people were going to do with this
18· old house.· They got it for $50,000, and it’s like
19· 6,000 square foot on an acre.· She seemed to be okay
20· again.· She was a little cold at first, but she seemed
21· to warm up.
22· · · · · ·Well, the next week is when this happens with
23· the complaint, because she had that day — I was still
24· sick, because I came down with it that day that she
25· had said that to me after Pam left
·This day, I didn’t know that her email wasn’t
·2· working because she didn’t bother telling anybody,
·3· well, except Tracy, I guess.· So I sent her several
·4· important emails, and one of them was this.· “Stop
·5· putting the credits on the accounts,” because first we
·6· were going to start doing that, and then Ken said,
·7· “No, no, no.· I want you to create a big spreadsheet
·8· and do all of this before you start sending credits.”
·9· · · · · ·So I sent her a couple of them, yeah, like
10· this.
11· · · Q.· ·Is that the email you’re referring to?
12· · · A.· ·Yeah.
13· · · Q.· ·For the record, what is the day of that?
14· · · A.· ·March 22nd at 12:30.· And it seems like there
15· was three that I’m remembering that I sent, but I
16· didn’t know that her email wasn’t working; she never
17· said anything about it.
18· · · · · ·Now, our email.· We don’t have an exchange
19· server.· We just use Go Daddy.· So the IT people have
20· nothing to do with the email; Pam is administrator of
21· that.· And, you know, when people leave or people
22· come, you know, she does their email, makes it up, and
23· that’s it.· That’s all there is to it.
24· · · · · ·So at that point in the day or in the
25· afternoon, 2:00-ish or something like that, I got a
call from Jason, who is my IT person, and he said, “I
·2· just got a help ticket, but it came from Tracy’s
·3· computer, and it says Anita’s email isn’t working.”
·4· And he said, “We don’t” — I said, “I know.· I’m
·5· sorry.· I don’t know why they did that.· It’s a
·6· Go Daddy thing.· So, obviously, we’ll get Pam to reset
·7· her password to get into her email.”
·8· · · · · ·And I thought, “Why the heck would Tracy,
·9· who’s been here 15 years, not” — and Anita, who’s
10· been there longer than me, they already know that, why
11· would they not just say to Pam, “Can you reset the
12· password?· Instead, she goes to — doesn’t say
13· anything to anybody.· In the midst of we’re trying to
14· figure out this big mistake we’ve done with
15· everybody’s — most everybody’s accounts, to trying to
16· do a help ticket to IT for a simple email issue like
17· that.
18· · · · · ·So when I hang up the phone, I say, “I’m
19· sorry that they bothered you.”
20· · · · · ·So I asked Anita, I said, “Did you send a
21· help ticket to Jason for the email?”
22· · · · · ·She said, “Yeah.· I haven’t had email all
23· day.”
24· · · · · ·I said, “Well, nobody knows that.· And I’ve
25· sent you a few, like, really important ones.· Go Daddy
is the email, and they don’t have anything to do with
·2· that.”
·3· · · · · ·So I tell Pam, “Can you reset her password?”
·4· and she does.· And she tells me, “I just put it to the
·5· word “password.”
·6· · · · · ·So they weren’t really talking to each other,
·7· mind you, because they’d just had that big old
·8· argument on Thursday afternoon, you know, just a few
·9· days before that.· So as soon as I say, “Anita, it’s
10· just “password,” you just have to — you’re going to
11· have to change it yourself, it should work now, I
12· think, she goes, “Really?” like, so loud from her
13· desk, “Really?· Are you kidding me?”· Like, “She
14· couldn’t tell me herself?” and just goes on this rant
15· from her desk.· She’s so mad that Pam told me that
16· she’d set — reset Anita’s password to the word
17· “password” so that she could get into her email.
18· · · · · ·So in the meantime I had printed out the
19· emails because I didn’t know — I figured, “Oh, man.
20· She’s been doing these credits all day, and she didn’t
21· see whenever I sent that.”
22· · · · · ·And she’s just angry because Pam didn’t tell
23· her, “I reset your password,” which she didn’t ask her
24· to reset it in the first place.· The whole thing, I
25· thought, was stupid
The air conditioning was on.· And normally
·2· you can hear everything.· There’s no private
·3· conversation in that place.· When the air conditioning
·4· is on, it’s pretty loud, but — so I was talking over
·5· that, because I never left my desk, what I was doing.
·6· And she was out there kind of walking around because
·7· she was really agitated when she was saying, “Really?
·8· Really?”
·9· · · · · ·And then she starts saying the same stuff
10· again about “Why can’t she just talk to me?”· And then
11· she starts complaining about Andrew again and just
12· like — kind of just rolling that all together.
13· · · · · ·And I said, “Look, we have really important
14· stuff to figure out here, and I need you to just do
15· it.”
16· · · · · ·And then she starts complaining, and I was
17· like, “Stop it.· I just want you to do your work.· Can
18· you just do that?”
19· · · · · ·And she says, “What?· Am I not allowed to
20· complain?”
21· · · · · ·And I swear to God she sounded just like Joe
22· Griffin, that man who always wants to complain, and,
23· like, “You can’t hear my complaints?”
24· · · · · ·I just said, “Anita, it’s time to work now.
25· So just stop it,” and that was it.· And I wouldn’t say
I yelled it at her, but I said it really, like —
·2· because I was like, “Just stop,” because she was
·3· rehashing the same thing that she had said to me a few
·4· days before and that Monday before when she had called
·5· me about Andrew not answering the phone.
·6· · · · · ·And then, the next thing I know, I look at my
·7· email before I come to work the next morning to see —
·8· I was looking for something from Fred for something
·9· else, and I don’t usually look at my email before I go
10· to work, and then I saw that.· And I thought that is
11· the strangest thing.· One, she doesn’t write like
12· that.· When I look at that and the CDBG protest letter
13· that’s supposedly written by Nicole Williams, it
14· smacks of Helen Miller.
15· · · Q.· ·When you say that, you’re referring to her
16· March 27th complaint?
17· · · A.· ·Yes.
18· · · Q.· ·You believe this is not something that
19· Ms. Rivers authored?
20· · · A.· ·Yes.
21· · · Q.· ·Okay.
22· · · A.· ·Maybe partially, but she doesn’t — I think
23· you’ve seen some her writing.· You know, it’s just not
24· hers.· I don’t think it’s completely hers.
25· · · · · ·And another odd thing is the time that it was
sent, too.· I find that strange because she’s never
·2· stayed up past 10:00 p.m.
·3· · · Q.· ·Okay.· All right.· So let me go back about a
·4· couple of things.
·5· · · · · ·The garbage issue was that there was no rate
·6· increase that was added, as determined by Ken Daniels?
·7· · · A.· ·Yes.
·8· · · Q.· ·The sewer issue was that we were actually
·9· overbilling —
10· · · A.· ·Yes.
11· · · Q.· ·– our citizens?
12· · · A.· ·Uh-huh.
13· · · Q.· ·And so we had to fix the sewer by giving
14· credits and fix the garbage by increasing bills?
15· · · A.· ·Yes.
16· · · Q.· ·And Ms. Rivers claims that she was not
17· trained on how to do those issues?
18· · · A.· ·Yes.
19· · · Q.· ·Are those her job duties?
20· · · A.· ·There is not a job description for her.
21· · · Q.· ·Okay.
22· · · A.· ·So I would say yes, she was asked to do that.
23· Because I recall last April when they were speaking
24· about changing the garbage rates, because we have a
25· contract with Waste Pro, and Pam had said something
bout the garbage rates not being changed, and Anita
·2· had said, “Well, you never told me to change them.
·3· · · · · ·And Pam had said, “Well, they go up every
·4· April.”· And I remember her making a copy of the Waste
·5· Pro contract, and this was in 2016.
·6· · · · · ·So when I started looking into the billing
·7· with the IMS guy, Steve, he told me that the rates
·8· were changed April 6th of last year for residential.
·9· So she changed the residential rates, but she didn’t
10· change the commercial rates.· So she only did part of
11· it, and that was where the problem was.
12· · · · · ·But in her — what she claims is that “I’ve
13· never changed the rates.· I don’t know how to change
14· the rates, and nobody ever taught me how to do that.”
15· · · Q.· ·And it’s your understanding that she was
16· trained on how to do that?
17· · · A.· ·Yes.· I asked the guy from IMS, Steve, that I
18· keep referencing.
19· · · Q.· ·What’s his last name?
20· · · A.· ·Oh, boy.· I can’t even pronounce it.· It’s
21· like Romyer (phonetic).· It’s probably in one of those
22· emails you got there, because I know she emailed Steve
23· after — in that week prior to her complaint,
24· because — no, no, no, it wasn’t.· It was the week of
25· her complaint, because that Tuesday morning, when I
· read it, I did not go into the office.
·2· · · · · ·And I knew that the cash problem still hadn’t
·3· been fixed either where they didn’t know who had paid
·4· what because of the server change.· And I had emailed
·5· Anita the day before, and I had said, “If you haven’t
·6· done so already, you need to get with Steve at IMS and
·7· figure out this cash problem to know who paid those
·8· three days, March 15, 16, 17.”
·9· · · · · ·So I called Steve at IMS, and we walked
10· through all the problems.· And she didn’t bother
11· calling him until that day, and he told me that too,
12· about the cash.
13· · · Q.· ·Okay.
14· · · A.· ·So when I had emailed him that the problem
15· was resolved, to say thank you so much, then she sends
16· a follow-up email that you probably have saying, “Can
17· you please tell me what you did,” to this guy Steve,
18· “because when I called you, you said there was nothing
19· that could be done?”
20· · · Q.· ·Were you going to discipline Ms. Rivers for
21· these issues related to the garbage rate not being
22· increased and the sewer not — or the sewer bills
23· being overbilled?
24· · · A.· ·Yes, but she didn’t know that.
25· · · Q.· ·You mentioned earlier that you believe that
· I guess — I don’t know if this is a particular
·2· example, but that when Ms. Rivers is accused of some
·3· deficiency, that she deflects it to some other matter?
·4· · · A.· ·Yes.
·5· · · Q.· ·Is it — if I’m understanding correctly, is
·6· this an example of that?· When I say “this,” that we
·7· have an auditor come in, Mr. Daniels, and his
·8· assistant Nicole, and they discover that we are
·9· underbilling, or portions of it, and overbilling our
10· sewer, portions of it, and that these are issues that
11· are falling back on Ms. Rivers as deficiencies on her
12· part.
13· · · A.· ·I believe she thought that, yes.
14· · · Q.· ·Okay.· Did you ever exclude Ms. Rivers from
15· being in any type of training with Mr. Daniels or
16· Nicole for purposes of learning how to do changes to
17· the garbage rate or to sewer —
18· · · A.· ·Well, there wasn’t any training with Ken
19· Daniels or his assistant Nikki.
20· · · Q.· ·Do you know what a Z tape is?
21· · · A.· ·A Z tape is something that Mr. Daniels told
22· us that we should have.
23· · · Q.· ·Is that like a backup of what —
24· · · A.· ·Yes.
25· · · Q.· ·So Mr. —
·1· · · A.· ·On the cash register.
·2· · · Q.· ·So when you get cash, you type it into the
·3· cash register, and there should be some type of
·4· record, if you will —
·5· · · A.· ·Yes.
·6· · · Q.· ·– that’s maintained on a Z tape?
·7· · · A.· ·Yes.
·8· · · Q.· ·And that was told to you by Mr. Daniels?
·9· · · A.· ·Yes.
10· · · Q.· ·Did Ms. Rivers ever communicate to you that
11· she thought she should be at that meeting with
12· Mr. Daniels when he was talking about Z tapes?
13· · · A.· ·Well, he wasn’t really talking about the Z
14· tapes at — that wasn’t the purpose of that meeting
15· that we had.
16· · · · · ·The purpose of that meeting was an exit
17· interview, I guess you could call it, of his audit
18· findings and a general overview of what he had found
19· in relation to what we had found last year.· So the
20· finance director, myself, and Mr. Daniels met, as we
21· did last year.
22· · · Q.· ·Was there any reason for Ms. Rivers to be
23· included in those meeting?
24· · · A.· ·No.
25· · · Q.· ·Had she, in the past, been included in those
meeting?
·2· · · A.· ·No, but she did send an email after and
·3· indicated she wanted to be included in the future.
·4· · · Q.· ·Is there any reason, to your knowledge, she
·5· should have been?
·6· · · A.· ·No.
·7· · · Q.· ·Are you the person who determines who should
·8· be and who should not be in those meetings?
·9· · · A.· ·Well, we never made a decision, “Okay.· I’m
10· in, and you’re in it.”· It’s just kind of happened
11· that the manager and the finance director would meet
12· with the auditor.· That’s the way I’ve seen it in
13· other places.
14· · · Q.· ·So, I guess, were you attempting to exclude
15· Ms. Rivers from these meetings?
16· · · A.· ·No.
17· · · Q.· ·It’s just something that this has been your
18· practice, and she was an administrative assistant?
19· · · A.· ·Yes, and this was during business hours also.
20· So she was tending to the front and customers.
21· · · Q.· ·All right.· And the cash drawer is a
22· situation where people come in from the public, and
23· they hand cash in to pay their bills?
24· · · A.· ·Yes.
25· · · Q.· ·Okay.· And Ms. Rivers is responsible for
 that, for accepting the cash and crediting it?

·2· · · A.· ·For ringing up things, you mean?
·3· · · Q.· ·Yes.· I guess, if somebody comes in and wants
·4· to pay their sewer bill in cash —
·5· · · A.· ·Yes.
·6· · · Q.· ·– that would be to Ms. Rivers?
·7· · · A.· ·Or Pam, if she was there.
·8· · · Q.· ·Would Ms. Tomlinson, was she — could she
·9· have been disciplined for the fact that there was no
10· rate increase to garbage and that sewer was being
11· overbilled?
12· · · A.· ·Yes, because, really, she should have checked
13· behind Anita also.
14· · · Q.· ·Is that her job to — is she sort of the big
15· picture?
16· · · A.· ·Well, she’s the finance director, yes.
17· · · Q.· ·Okay.
18· · · A.· ·So, really, when I say — when I was asked
19· during the council meeting last week whose fault is
20· it, and I said it’s all of our fault.
21· · · Q.· ·Ms. Rivers at the ground floor, Ms. Tomlinson
22· in an overview status, and then you as an overview of
23· all of it?
24· · · A.· ·Yes.
25· · · Q.· ·The buck ultimately stops with you as the
town manager?
·2· · · A.· ·Yes.
·3· · · Q.· ·Okay.· Now, so you somewhat raise your voice
·4· at Ms. Rivers, I guess, out of — was it maybe out of
·5· frustration of all of the issues that were going on?
·6· · · A.· ·Yes.
·7· · · Q.· ·Other than that time, have you ever raised
·8· your voice at her again?
·9· · · A.· ·No.
10· · · Q.· ·Before or after?
11· · · A.· ·No.
12· · · Q.· ·And I guess —
13· · · A.· ·And I wouldn’t really — I wouldn’t really
14· characterize it as all that loud either.· I think it
15· was more the manner in which I spoke to her, because
16· it was a very stern tone.· And I think in the past
17· I’ve been too lenient with her in allowing her to say
18· a lot of things she probably shouldn’t have said.
19· · · Q.· ·Do you know whether Bradley Meeks or Kevin
20· Pittman were present when you said it?
21· · · A.· ·Brad was at the copy machine, yes.· Kevin
22· was — Kevin had been in my office earlier about
23· some — we were talking about fire inspections and
24· business tax receipts, and I think he had went into
25· Tracy’s office after that
1· · · Q.· ·Okay.· Did the police chief speak to you
·2· about this incident?
·3· · · A.· ·No.
·4· · · Q.· ·Has anybody come to you and spoken to you
·5· about the incident?
·6· · · A.· ·No.
·7· · · Q.· ·Since — I guess, since these incidents have
·8· occurred — and, basically, it sounds like the week
·9· kind of culminated, the week preceding Ms. Rivers’
10· complaint, with an FDLE audit and another — and the
11· audit findings coming out, and then the election
12· upcoming and so forth, people not being permitted to
13· run, all of these things sort of culminate right
14· before Ms. Rivers’ complaint comes.
15· · · A.· ·Yes.
16· · · · · ·MR. LARKIN:· Okay.· There is an allegation.
17· · · I don’t, to be honest with you, know what it —
18· · · what relationship it has to Ms. Rivers’
19· · · complaint.· Before I get into it, I just want to
20· · · go off the record for a moment.
21· · · · · ·(Recess had from 3:11 p.m. to 3:14 p.m.)
22· BY MR. LARKIN:
23· · · Q.· ·Before I get to that, I just want to have a
24· couple follow-up.· Has the election occurred?
25· · · A.· ·Yes
1· · · Q.· ·And what were the results?
·2· · · A.· ·Rhett Bullard and Tonja Brown were
·3· re-elected.
·4· · · Q.· ·Okay.· The last issue that I wanted to
·5· discuss with you is this.· There’s been an allegation
·6· that there’s been some prescriptive medicine found in
·7· town hall, two pills, one in a bathroom that’s used
·8· only by the women, and another that’s used by both men
·9· and women, two separate occasions, and that the police
10· chief asked, after finding the second pill, whose pill
11· it was, and that you allegedly said it was yours.· Is
12· that true?
13· · · A.· ·Yes.
14· · · Q.· ·Are you taking any prescriptive medications
15· while at work?
16· · · A.· ·Yes.
17· · · Q.· ·Okay.· And the prescription medicine that
18· you’re taking, what is that?
19· · · A.· ·The one that she found?
20· · · Q.· ·Yes, ma’am.
21· · · A.· ·That was a generic Percocet.
22· · · Q.· ·Do you know whether these medications impair
23· your judgment —
24· · · A.· ·No.
25· · · Q.· ·– or your ability to communicate or anything
1· of that nature?
·2· · · A.· ·No, they don’t.
·3· · · Q.· ·Why do you say that?
·4· · · A.· ·Because I’ve had rheumatoid arthritis since I
·5· was 17.· So I have taken lots of different
·6· prescription medications for years.· So I can pretty
·7· much take anything, and it doesn’t affect me.
·8· · · Q.· ·Is there anything else that you want to tell
·9· me that I didn’t ask you?· I know you have the
10· statement that you’ve prepared, and I’ll be happy to
11· include that as an exhibit, and I’ll absolutely review
12· it when looking through this material, but anything in
13· addition?
14· · · A.· ·Well, I started to print emails, but then I
15· thought I don’t want to overload you with a bunch of
16· emails that you probably already have, because I
17· noticed that she’s printing every single thing in the
18· computer.
19· · · · · ·I would just say that this one was really a
20· different incident that I never talked to her about.
21· · · Q.· ·Okay.· And this one that you’re referring to
22· is another Facebook post from August 22nd at 8:13.· Is
23· that August 22nd of 2016?
24· · · A.· ·Yes.
25· · · Q.· ·And this is from Anita Thomas Rivers, and it
 says, “People of White Springs” — “White Springs” in

·2· all caps — “always complain of having nothing to do.
·3· Well, the town have movie night once a month.· It is
·4· set up like a real movie theater atmosphere.· The
·5· movie is free, popcorn is free, and drinks are free.
·6· We do sell hot dogs and candy for one dollar each.
·7· What else could be done to get people to come out?
·8· Nothing.· Because I have decided that these people
·9· just like complaining.· All we heard was that we
10· should do movie night like other cities.· Well, we do,
11· and no one show up.· I bet when it go away they will
12· complain.”· And then in all caps, “Yes, I am ranting
13· because you cannot satisfy people in this hick town.”
14· · · · · ·Did anybody complain to you about that?
15· · · A.· ·Yeah.· I heard about that just generally that
16· you shouldn’t talk badly about the public that you’re
17· serving.
18· · · Q.· ·Did you talk with Ms. Rivers about this
19· Facebook post?
20· · · A.· ·No, I didn’t talk to her about that one.· And
21· I’ve — people have just mentioned that there’s
22· others, but I don’t — I don’t have time to go looking
23· at her Facebook page.· So I haven’t seen any of her
24· allegations that she’s made, racial comments, but I
25· don’t know that to be true at all
Something else that you didn’t ask me about
·2· was the Facebook and the town’s page that I had
·3· created.· And the day that I changed the password,
·4· that was election day.· And she contends in her — all
·5· these emails that I’m stripping her of her duties and
·6· trying to retaliate against her.· What I was trying to
·7· do was stop her from doing something to me that day.
·8· · · · · ·I was at the polling place, and she and I are
·9· the only person that updated that page.· So she would
10· put up flyers if I wanted, whatever, to help me.· So
11· I’m at the polling place, and somebody calls me and
12· says Nicole, or Nikki, Williams is at the S & S store
13· talking on the phone to Anita, and she’s at town hall,
14· and something about your — the town’s Facebook page
15· and something you posted.· And I said, “All I posted
16· was that it’s election day.· Remember to vote.”
17· · · · · ·”Well, no.· Something else about it.· Like
18· something you did that’s going to be illegal from
19· removing something that somebody else put up there.”
20· · · · · ·I said, “Let me go there and see.”
21· · · · · ·So I went there right away, and I just opened
22· my computer, because I always close the lid when I
23· leave, and I see that somebody has tried to log into
24· my computer because, you know, it says the password is
25· incorrect; so I know that she’s been at my computer
And I go to the Facebook and I change the
·2· password.· And three seconds later, she says, “Did you
·3· just change the password?”
·4· · · · · ·And I said, “Yes.”
·5· · · · · ·”Well, what is it?”
·6· · · · · ·I said, “I don’t need your help with it
·7· anymore.· I’ll handle the Facebook page.”
·8· · · · · ·”Oh.”· And then she sends that email that I’m
·9· sure you have that “I’ve always had access, and this
10· isn’t right,” da-da-da.
11· · · · · ·Well, the reason why I did that was because
12· what was she was doing — and then she said I blocked
13· her, which I didn’t.· Then I had to spend time going
14· through and seeing what she did.
15· · · · · ·And Nicole Williams, her friend, had made
16· these comments.· And I have it set up to where you
17· have to go to timeline review, because in the
18· beginning somebody had put something up there, and I
19· was like, “Oh, that’s not good to have on the town
20· page.”· So I went and changed the settings so that it
21· wouldn’t automatically show up.· I would review it,
22· and then, if it was okay, I could post it; if not, it
23· would just sit there indefinitely.
24· · · · · ·So Nicole had put these things like, “PSA.
25· You don’t have to vote for two people.· You can vote
for only one.”· And, “Don’t forget you’ve already been
·2· paid.· So go vote.”
·3· · · · · ·Obviously, I’m not going to put these
·4· things — a lot of things on the town page, because
·5· what she’s saying is that Rhett Bullard had paid
·6· people off to vote for him and Tonja.· “Vote Tom
·7· Moore.· Let’s change the power of three.· Let’s change
·8· the corruption of the third degree.”
·9· · · · · ·And I look and see what Anita had done, which
10· was — I look at the activity log, and she saved these
11· things that Nicole Williams has attempted to tag Admin
12· White Springs on.· So she was going to — and then I
13· talked to this person later and got the full
14· conversation.· She was going to put them on there and
15· screenshot it, because Nicole Williams had said on the
16· phone, “Just screenshot it, and then take it off” to
17· make it look like I had done that, tried to, you know,
18· destroy public records.· So that’s the reason that I
19· changed the password, because —
20· · · Q.· ·How do you know that Nicole Williams said
21· that?
22· · · A.· ·Because I talked to the person that heard her
23· speaking.· She’s very loud.
24· · · Q.· ·Who is that?
25· · · A.· ·His name is Rick Brown.· He is a citizen.
Q.· ·So Mr. Brown reported to you that he heard
·2· Nicole Williams tell Ms. Rivers to screenshot her
·3· posts, put them on the Facebook page for the Town of
·4· White Springs in an attempt to make it look like you
·5· had deleted the original, I guess, post that she had
·6· made?
·7· · · A.· ·Yes.
·8· · · Q.· ·So that you would — that you could then be
·9· accused of destroying public records?
10· · · A.· ·Yes.
11· · · Q.· ·When in reality you had created — or stopped
12· her post from ever hitting the page by creating some
13· type of firewall or some way —
14· · · A.· ·It’s a setting in there.
15· · · Q.· ·– a setting inside of Facebook that will
16· allow the administrator to review the content of a
17· particular post before allowing it to make its way
18· onto the public domain?
19· · · A.· ·Yes.
20· · · Q.· ·I see.
21· · · A.· ·Yes.· And that’s the nature of why I changed
22· the password, because I didn’t want her doing that,
23· obviously.
24· · · Q.· ·And are those records that you have there
25· that look to be in color, are those examples of that
A.· ·These are screenshots, yes, that I took that
·2· day because I — when I changed the password
·3· immediately, I then started looking to see what was
·4· going on.
·5· · · Q.· ·And so —
·6· · · A.· ·And then she, you know, said that “You
·7· blocked me.· I tried to look at it.”
·8· · · · · ·I said, “I didn’t block you.· I don’t know
·9· what you’re talking about.”
10· · · · · ·So I had to go to that and make a screenshot
11· of that where it says you’re blocking — apparently, I
12· blocked Joe Griffin from sending us messages, but, you
13· know, just to show that I — no one is blocked from
14· viewing the page, and that was on that same date.
15· This was election day.
16· · · Q.· ·So this is blocked users, and this is a page
17· at the bottom right that is 1:44 p.m. on April 25th of
18· 2017.
19· · · A.· ·Right.· Right after she sent me that email
20· accusing me of that, I went to that, found that page
21· where I could screenshot it to show that I wasn’t.
22· · · Q.· ·Do you want me to have this?
23· · · A.· ·You can keep it.
24· · · Q.· ·We’ll make it an exhibit.
25· · · A.· ·Okay.
1· · · · · ·(Exhibit 4 was marked for identification.)
·2· BY MR. LARKIN:
·3· · · Q.· ·So if I understand correctly, Ms. Rivers and
·4· Ms. Nicole Williams were attempting to essentially
·5· sabotage you by making it look like you were
·6· destroying public records?
·7· · · A.· ·Yes.
·8· · · Q.· ·Okay.· And with respect to this complaint
·9· dated March 27th of 2017 by Ms. Rivers, it’s your
10· belief that this is not authored by — this was not
11· authored by Ms. Rivers, but someone else?
12· · · A.· ·Yes.
13· · · Q.· ·And that it was the result of and/or
14· motivated by the fact that in part that Ms. Rivers
15· could be disciplined for these deficiencies related to
16· the audit?
17· · · A.· ·Yes.
18· · · Q.· ·And/or the impending election where there
19· were certain people not being permitted to run and/or
20· other candidates that they wanted to win other than
21· Mr. Bullard and Ms. Brown?
22· · · A.· ·Yes.
23· · · Q.· ·So you believe that this complaint is not
24· legitimate?
25· · · A.· ·Yes.
· · · Q.· ·Okay.
·2· · · A.· ·And then — I’m sorry.· I know you, like,
·3· want to get out of here.
·4· · · Q.· ·No.· I’ll stay as long as you want.
·5· · · A.· ·Then Nicole Williams just now has sent this
·6· thing to Fred on — last week saying everything is
·7· racially motivated, supposedly.· That’s this person
·8· here.
·9· · · Q.· ·So this is somebody you believe that may be
10· related to Ms. Rivers?
11· · · A.· ·Yes.· They’re very good friends.· I think
12· they’re cousins, and they’re very close.
13· · · Q.· ·And this is dated May 12th of 2017.· So just
14· the other day.
15· · · A.· ·Right.
16· · · Q.· ·So this is two months —
17· · · A.· ·This is, like, Friday, because she cussed me
18· out Thursday night and then wrote this on Friday and
19· took it to the Fred’s office.
20· · · Q.· ·Do you want this to be part of the record?
21· · · A.· ·Yeah, sure, because I think that it’s all
22· together.· I mean, those various reasons, I don’t
23· think that you can take just one, you know.· Yeah,
24· there was a big problem with the audit.· I don’t think
25· she on her own decided “I’m going to write this
·I think that — I think that Nicole had a
·2· part in it, or Nikki, and Helen.· I think Helen drives
·3· all of it, and that she’s the brains behind the
·4· operation.
·5· · · Q.· ·And Ms. Miller is a current council member?
·6· · · A.· ·She is.
·7· · · Q.· ·And when you say the power, the power of
·8· three, did I hear you say that correctly?· Did
·9· somebody refer to that?
10· · · A.· ·That was Nicole’s post, yeah.
11· · · Q.· ·So that would be Mr. Bullard, Ms. Brown, and
12· Mr. Jefferson?
13· · · A.· ·Yes.
14· · · Q.· ·And those are the three council members that
15· support you?
16· · · A.· ·Yes.
17· · · Q.· ·And then it would be Ms. Miller and who else?
18· · · A.· ·McKenzie.
19· · · Q.· ·Mr. McKenzie?
20· · · A.· ·Yes.
21· · · Q.· ·That do not?
22· · · A.· ·Walter, yeah.
23· · · Q.· ·So this election, then, I guess, in your
24· mind, was relatively critical, that perhaps other
25· groups –
A.· ·Well, not really, because it takes four votes
·2· to get rid of me.
·3· · · Q.· ·I see.· Okay.
·4· · · A.· ·Of course, I would like — I wanted them to
·5· be re-elected because I have a good relationship with
·6· them.· In my opinion, they do participate the most.
·7· · · Q.· ·And so is it your belief that Ms. Rivers —
·8· or do you know whether Ms. Rivers supported the other
·9· candidates?
10· · · A.· ·She supported Tom Moore and made a comment
11· when she went into the precinct that she was only
12· going to vote for one, and that would be Tom Moore.
13· So, obviously, one of them was going to be re-elected
14· because it was an election for two spots and there
15· were only three candidates.
16· · · · · ·So she was at least hoping to knock one of
17· them out, and then — because they decide amongst
18· themselves who’s mayor at the first meeting two days
19· after the election.· So if there was somebody else
20· that got on the council, then she might get to be
21· mayor again, which seems silly for a little town of
22· 800 people, to care about who’s the mayor, but it’s
23· very important to her.
24· · · · · ·MR. LARKIN:· All right.· I guess, for the
25· · · record, there’s a two-page Facebook exhibit with
handwriting from 9/11 of 2016.· One is from Anita
·2· ·Thomas Rivers, and the other is from Toekeyshia
·3· ·Ward Akien.· That’s going to be Exhibit 1.· It’s
·4· ·a two-page exhibit.· That’s Exhibit 1.
·5· · · · (Exhibit 1 was marked for identification.)
·6· · · · MR. LARKIN:· Exhibit 2 will be the — another
·7· ·Facebook post from Ms. Rivers dated August 22nd
·8· ·at 8:30 — at 8:13 a.m.· That will be Exhibit 2.
·9· · · · (Exhibit 2 was marked for identification.)
10· · · · MR. LARKIN:· Exhibit 3 will be the typed
11· ·written notes that I received from Ms. Tebo,
12· ·which is front and back four pages.· I believe
13· ·it’s four pages.· Yeah.· And the back of the last
14· ·page is not typed.· That will be Exhibit 3.
15· · · · THE WITNESS:· And I’m sorry if some of it got
16· ·out of date order, but I did it at different
17· ·times, and I was trying to put it back.
18· · · · MR. LARKIN:· That’s okay.
19· · · · (Exhibit 3 was marked for identification.)
20· · · · MR. LARKIN:· Exhibit 4 will be the screenshot
21· ·pages, which is a composite exhibit of, I guess,
22· ·pages or documents that would show the attempts
23· ·by Ms. Williams to post on the website, the town
24· ·springs website, and I guess Ms. Rivers’ attempts
25· ·to take screenshots of those and/or whether or
1· · · not she was blocked from posting.· That’s
·2· · · Exhibit 4.
·3· · · · · ·(Exhibit 4 was marked for identification.)
·4· · · · · ·MR. LARKIN:· Exhibit 5 is a two-page document
·5· · · stapled which concerns an email from Mr. Koberlein to
·6· · · you dated May 12th, 2017, at 12:57, and then an
·7· · · attached complaint to Mr. Koberlein from Nicole
·8· · · Williams dated May 12, 2017, with a sticky note copied
·9· · · on the bottom.· That will be Exhibit 5 to
10· · · Ms. Tebo’s statement.
11· · · · · ·(Exhibit 5 was marked for identification.)
12· BY MR. LARKIN:
13· · · Q.· ·Is there anything else?
14· · · A.· ·I don’t really know if I should give you some
15· of this because I haven’t read through it.· Now you
16· know why I typed it, but I don’t think we went over
17· it.· A lot of it is just — I seem to be writing down
18· different times that Nicole Williams was coming and
19· going to Tracy’s office, and then Anita would go in
20· there.· I feel like there’s some sort of —
21· · · Q.· ·If you believe any of it is relevant, and you
22· want me to read it, we can certainly make a copy of
23· it.
24· · · A.· ·All right.· Well, it’s really messy.
25· · · Q.· ·Well, I’m not a
1· · · A.· ·It’s bad.
·2· · · Q.· ·I will happy to review it.
·3· · · A.· ·I’m sort of embarrassed.
·4· · · Q.· ·I will give an opportunity for you to put
·5· anything you think is relevant into the record for me
·6· to read, and I can certainly make every attempt to do
·7· so
·8· · · A.· ·All right.
·9· · · Q.· ·Do you plan on doing so —
10· · · A.· ·Yeah.
11· · · Q.· ·– or are you still deciding?
12· · · · · ·You are?
13· · · A.· ·Yes.
14· · · Q.· ·So Exhibit 6 will be handwritten pages
15· beginning with “April 25th, 2017,” at the top.· This
16· is four pages of handwritten notes.· The first page is
17· identified by the date of April 25th, 2017.· It says,
18· “Come back quietly from lunch early to speak with
19· Tracy” at the top.· The next page is dated 4/25/2017,
20· time entry of 4:37.· Third page at the top is entitled
21· “Movie night.” The last page is dated April 25th,
22· 2017, “Rick at store.”
23· · · A.· ·Oh, yeah.· That’s the guy I was talking
24· about, the citizen that —
25· · · · · ·MR. LARKIN:· The citizen.· Okay.
·And that is a four-page document, which will
·2· · · be Exhibit 6.
·3· · · · · ·(Exhibit 6 was marked for identification.)
·4· BY MR. LARKIN:
·5· · · · · ·Is there anything else?
·6· · · A.· ·I don’t think so.· I just wish I could read
·7· all the emails that you have, and then I would know
·8· what you were lacking.
·9· · · Q.· ·Well, I can tell you this.· I don’t know of
10· all the emails that I have that you don’t have.· What
11· I showed you today, though, is I think the ones that
12· were germane to her complaint.· Okay?· And I believe
13· that I’ve — you’ve given me enough information so
14· that I can consider both sides of what’s being said.
15· · · · · ·If there is anything that comes up, I will
16· get ahold of Mr. Koberlein, and we can rectify it.· At
17· that point, I will ask for you to supplement, and you
18· can supplement whatever.· If there are emails
19· addressed to a particular time and date that we did
20· not go over, and I see them, I will ask Mr. Koberlein
21· that you be given the opportunity to supplement with
22· whatever emails you might have.· Okay?
23· · · A.· ·(Nods head.)
24· · · Q.· ·All right.· Is there anything else that you
25· want to talk about that we didn’t already
· · · A.· ·I don’t think so.
·2· · · · · ·Is she saying discrimination because she
·3· black?· Is that what it is?· Because it’s never stated
·4· in the email what the basis is.
·5· · · Q.· ·That is a good question.· I don’t know if
·6· Ms. Rivers’ interview notes will state that.· I don’t
·7· know if that’s what she’s saying.
·8· · · A.· ·It’s just really silly for her to say that
·9· because I had a black boyfriend I was serious about
10· when I got that job.· And because there’s a huge
11· confederate flag at that exit, I never put the picture
12· up on my desk.· And then a couple months down the
13· road, I thought, “Screw these people.· I don’t care.”
14· So I did, and she got a big kick out of it and thought
15· that was great.
16· · · · · ·And the mayor had asked me, “Why didn’t you
17· put that up there?· Did you do it because you thought
18· we were all racist?”
19· · · · · ·And I said, “Yeah, actually.· I mean, you
20· have a big confederate flag by your exit, and you have
21· a black cemetery and a white cemetery.”· I’m from
22· Volusia County, and it’s not like that there.
23· · · · · ·So just the — her — even though she didn’t
24· say “black,” I’m assuming that’s what she’s trying to
25· allege, and that’s just — that’s just really
offensive to me.
·2· · · Q.· ·Okay.· These transcripts will be compiled.
·3· You’ll be given an opportunity, if you would like to,
·4· to read it, review it, before it’s, I guess, placed in
·5· the file to make sure it’s accurate.· If there’s
·6· misspellings — I know we talked about a name, a last
·7· name, I don’t know if you were able to rectify that.
·8· You’re given the opportunity to read it and make sure
·9· you understood the question I was asking, the answer,
10· not really add anything or change anything of
11· substance, but if there’s misspellings or
12· misunderstandings, you can do that.
13· · · · · ·You have to let the court reporter know now
14· so that when she compiles it into a transcript, which
15· will be in the next 10, 14 days, whatever it is, she
16· can contact you, and you can take a look at it before
17· it’s put in final.
18· · · A.· ·And then what are you going to do with it?
19· · · Q.· ·Then I’m going to get it, along with all the
20· other transcripts, and write a report to Mr. Koberlein
21· or, I guess, to the town.
22· · · A.· ·To town council?
23· · · Q.· ·And then at which point the report and all
24· the statements will become public records.
25· · · A.· ·Oh, my
Q.· ·Anything else?
·2· · · A.· ·No.
·3· · · Q.· ·Okay.· Well, I appreciate your time and your
·4· candor, and we will, I guess — if I need any
·5· additional information, I’ll ask Mr. Koberlein if you
·6· can supplement.· Okay?
·7· · · A.· ·Okay.
·8· · · · · ·(The statement concluded at 3:37 p.m.)

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