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EXHIBIT 4

Willie Jessop Deposition Excerpts

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UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

United States of America, Plaintiff, vs. Town of Colorado City, Arizona; City of Hildale, Utah; Twin City Power; and Twin City Water Authority, Inc., Defendants.

) ) ) ) ) ) ) ) ) ) ) ) ) )

No. CV-12-8123-PCT-HRH

THE DEPOSITION OF WILLIAM JESSOP (Videotaped)

Colorado City, Arizona May 21, 2013 12:01 p.m.

(ELECTRONIC COPY) PREPARED FOR: DISTRICT COURT

REPORTED BY: Az Litigation Support, LLC Marty Herder, CCR Certified Court Reporter CCR No. 50162

CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 (No exhibits marked.) E X H I B I T S Examination By: Mr. Hamilton I N D E X Page: 5

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3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 For the Defendant Town of Colorado City, Arizona: GRAIF BARRETT & MATURA, P.C. BY: Jeffrey C. Matura, Esq. 1850 North Central Avenue Suite 500 Phoenix, Arizona 85004 Also present: Karen Delancy, paralegal David Darger Vincen Barlow Brent Jensen, videographer For the Defendants City of Hildale, Utah, Twin City Power and Twin City Water Authority, Inc.: STIRBA, P.C. BY: R. Blake Hamilton, Esq. 215 South State Street P.O. Box 810 Suite 750 Salt Lake City, Utah 84110 COUNSEL APPEARING: For the Plaintiff: UNITED STATES DEPARTMENT OF JUSTICE CIVIL RIGHTS DIVISON BY: Lori K. Wagner, Esq. Jessica C. Crockett, Esq. Anika Gzifa, Esq. 950 Pennsylvania Avenue, NW Washington, D.C. 20530 THE DEPOSITION OF WILLIAM JESSOP, Taken at 12:01 p.m., on May 21, 2013, at the EL CAPITAN TECH BUILDING, 255 North Cottonwood Street, Colorado City, Arizona, 86201, before Marty Herder, Certified Court Reporter, pursuant to the Rules of Civil Procedure.

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4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE VIDEOGRAPHER: Good afternoon. My name is P R O C E E D I N G S Colorado City, Arizona May 21, 2013 12:01 p.m.

Brent Jensen, certified legal-video specialist with K-Video Productions. Our court reporter is Marty Herder, representing Arizona Litigation Support. Their address is One East

Washington Street, in Phoenix, Arizona. We are at 255 North Cottonwood Street in Colorado City, Arizona, to take the deposition of William Jessop on behalf of the defendants in the United States District Court of Arizona case of United States of America versus Town of Colorado City, Arizona, et al. CV-12-8123-PCT-HRH. The date is May 21st, 2013, and the time is approximately 12:03 p.m. The attorneys will now introduce themselves. Plaintiffs first, please. MS. WAGNER: United States. MS. CROCKETT: Jessica Crockett for the I am Lori K. Wagner for the Case No.

CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BY MR. HAMILTON: Q. record. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 All right. Would you state your name for the E X A M I N A T I O N WILLIAM JESSOP, called as a witness herein, having been first duly sworn, was examined and testified as follows: United States. MS. GZIFA: Anika Gzifa for the United States. Blake Hamilton for Hildale City,

MR. HAMILTON:

Twin City Water Authority, and Twin City Power. MR. MATURA: Colorado City. THE VIDEOGRAPHER: Thank you. Jeff Matura for the town of

Please swear the witness. MS. WAGNER: Excuse me. Can we have others who

are present identify themselves as well for the record? I have sitting here behind me to the right, paralegal from the United States Department of Justice, Karen Delancy. MR. HAMILTON: We have Vincen Barlow on behalf of

Hildale City, the Hildale city manager, and David Darger, the town of Colorado City manager.

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6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 taken? A. Um, I don't recall. I mean, that's probably A. Q. A. Q. A. Q. timeout? MR. HAMILTON: Sure. We are off the record at 12:04. A. Q. A. Willie Jessop. Will you spell your last name? J-E-S-S-O-P. THE VIDEOGRAPHER: Blake, can we have a quick

THE VIDEOGRAPHER:

(Brief recess taken.) THE VIDEOGRAPHER: BY MR. HAMILTON: Q. All right. Mr. Jessop, thank you for your patience. As you see, we have a full room here. Have you ever had your deposition taken before? I have. And how many times? Many. Do you have an estimate? Probably ten. Ten? When was the last time you had your deposition We are on the record at 12:06.

within a year. Q. Within a year? CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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24 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. A. Q. A. Q. A. I have a black Caterpillar financial -- or a book

that was given to me at Caterpillar earthwork school. Q. Okay. Do you have any documents that you brought here you today because of this deposition? A. Q. A. No. Only your check.

Okay. Yes. There's other documents in there that don't

pertain anything with this. Q. Okay. Let's talk about the disclosure and what your -you have information or you have supposed information about. It says that you have information about the FLDS church control over the Twin Cities, which are Hildale and Colorado City. Are you FLDS? That's a loaded question. Do you consider yourself to be FLDS? I consider myself an LDS. LDS or FLDS? I was Baptized LDS. Okay. Do you consider yourself a follower of the fundamental beliefs of the LDS church? A. That's awful wide range of how to do that. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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25 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A. Q. I believe that I follow the teachings of the prophet Joseph Smith through his prophets. Q. Okay. And who do you consider to be the prophet now? I don't believe there is one right now. Okay. Who do you believe to be the last prophet? Well, I certainly acknowledged Warren as one.

Until he came clean with raping 12 year olds. Q. Jeffs? A. Q. I did. And when did you stop following Warren Jeffs? Do And so at one point in time did you follow Warren

you remember the year? A. Q. A. Q. prophet? A. When the department -- when the Texas Department In what way? In what way? Yeah. When, when did you stop considering him to be a

of Child Protective Services and the Attorney General gave me an audio recording him teaching his 12-year-old wives and 13 and 15 year old how to have group sex. Q. Okay. And do you recall when that was? CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. A. Q. would fly down on a little private jet, and we would pick him up at the airport and take him to his home. And I don't recall the month or year, but I recall that we had just finished his new home up on Utah Avenue. And I was brought into a meeting, and he asked me if I would help relieve some problems he was having with some of the previous people involved in his program and asked me if I would take a more active role in providing him security. And so I basically from that time forward was basically either very directly or directly involved in coordinating his security. Q. entail? And at this time who was the prophet? Rulon Jeffs. Okay. What did coordinating his security entail? Making sure that he had someone at the airport to And what did, what did coordinating his security

pick him up, make sure that he had someone to take him back to the airport, making sure that we had people at his home at night, making sure that we had someone to get him to the meetings he wanted to go to and assisting him at socials and community events. Q. And when you started, it wasn't for Rulon. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 It was

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32 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 for Leroy; right? A. I was real young when I was first put in by -- in

church security under Uncle Roy, but then later went into under and was used under Uncle Rulon. Q. Okay. So you worked with Uncle Roy.

And who is Uncle Roy, as far as the FLDS church is concerned? A. Q. He was considered the prophet. And at that time it was a more inactive role? Is

that how I understand your testimony? A. Q. A. It's what? Was it a less active role? Well, I mean, I was just one of the people that I don't know that it

was used for church security for him. was anything less active. Q. A.

Who was the person that made the threat? You got to remember 20 years. As I recalled it, it was a gentleman by the name

of Leo Evoniuk.

It was a guy that was part of the LeBaron

group that had gone on a killing spree. And the ATF came in and notified us that Roy Johnson was on that hit list. And they helped provide, with

federal and state agencies, they helped provide security. And from that time forward they left a security team in place for Uncle Roy. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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33 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ATF. A. No, it was done, if I recall the time, it was done A. Q. Okay. And that security force included local members of the community. A. Q. A. Q. Correct. And one of those members was you. Correct. And you received a firearm, and you believe it was

from the police department -MS. WAGNER: THE WITNESS: Objection; leading. I was given an opportunity to work

with the local and federal agents at one of the entrances into the community over several weeks, and part of that was carrying one of their firearms. BY MR. HAMILTON: Q. Okay. And at that point you had been deputized. Yes. There was a point over at the fire station

where I was -- as I recall, there was some ceremony where they deputized me. Q. And this was all done under the direction of the

under Washington County. Q. As far as setting up the security detail, it was

done through the ATF -CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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34 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Oh, the ATF was very much involved in that

particular issue, yes. Q. Okay. After securing streets during that time period, what did you do after that point to be -- as far as your duties as church security? A. Q. Provided a watchman at his home. And then Rulon Jeffs approached you and asked you

to take a more active role; correct? A. recall. And I then left for California. part of -- back in the community. And then was approached with several other -- with several other men to take a more lead role in being available for his security. Q. Okay. Besides securing the area during the time when there was a threat on Uncle Roy's life and occasionally watching his house, what other duties did you have as church security during that period of time when he was alive? A. shift. a week. The way I recalled it was we were all given a And I think it was two nights a week or three nights I don't recall. Would basically be available to be Came back and was Uncle Roy passed away in November of 1986, as I

at his home. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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35 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. Is there any other activities that you would

perform besides being at his home and making sure his home was secure? A. Q. A. Q. For Roy Johnson? Yes. That was the primary issue, yes. When Rulon Jeffs approached you and asked you and

several other men to take a more active role, who were the other men; do you recall? A. Yeah. One of -- the one that I recall was Sam

Roundy, Jr. Q. A. Anyone else besides Sam Roundy, Jr.? One of the people that were at the meeting -- one

of the first meetings when I got involved was a gentleman by the name of Jeffrey Jessop. And Allen Steed was there, as I recall. He wasn't involved in the security part, but I went to that meeting with Allen Steed initially. Q. At that point in time did you understand that you

were still deputized? A. Q. A. No. Okay. No. I didn't recall -- I don't -- didn't feel

that the deputization was any more than just when the ATF was here and the Washington County sheriffs were here. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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64 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 And that's the problem we had then and now. Which is fine when we thought -- I thought it was fine when I thought we were all for the good of all under a different administration. Q. It's true that there are elections, correct, in

Hildale -A. Q. A. Block elections, yeah, we deal with that. What do you mean by block elections? Well, for instance, we find out that a certain

politician is against us. It was pretty obvious that we could rally the support of the members of the church to vote for someone and not vote for someone. And I think the record's pretty clear on that. Based on how we thought they would treat our community. Q. Explain that to me though. Were there church

meetings where people were told who to vote for? A. Yeah. There was Saturday update meetings, and it

would basically be leaked out through the city officials who the bishop wanted voted for or didn't. Q. And how do you know it was being leaked out by the

city officials? A. Q. What do you mean? Okay. I was there.

And so did a city official stand up and say

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68 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 With, with, with church leaders and with city government leaders. I sat there and interviewed police officers that may or may not be good for the department with the bishop on who should go to police academy. Q. A. Q. When, when did this take place? Which time? We had that discussion --

Let's talk about the mayor, because that's what

I've been focusing on. You said that you were present when there was church meeting or meetings with church officials and city officials about who would made good city council members. But have you ever been present and seen, for example, like Warren Jeffs or the bishop, the local bishop of this -- this community say this person should be the mayor of Colorado City? A. Q. A. Absolutely. When? I was there when there was being questions asked,

we need a mayor, we need a city council member, that information was then passed on through letters and to Warren Jeffs, and then it was brought out who he wanted, and then we executed it. Q. A. Give me a specific example. That David Zitting shouldn't be the mayor. CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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69 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. When did that happen? It happened, as I recall, in, like, January of

'011 or something. I just remember the incident very well. I remember it was Warren who said that he didn't have any confidence in him and that he needed to be removed from the community. Q. A. Okay. And Lyle told me he was going to do it, and called

him out to R and W, which was my office, and he told him he needed to remove himself from the community. Q. A. Q. Okay. Blake, this whole thing is indefensible. Did -- did he at that point say who should be the

new mayor? A. No. We had a discussion later that day about what

to do for the city. Q. A. Q. A. Q. A. Who -With Lyle. Who had this discussion? Lyle and I. Okay. And what was decided?

We were going through a punch list of people that

were not conflicted out by the state line on who would be loyal to the church, not to -- I mean, the issue is CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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70 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. scam? A. Because the only people that become mayor is CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 replacement with their loyalties to the church. Q. A. or not. At that point there was a discussion on whether we should try to put Jerry Barlow in. Q. Okay. So David Zitting, you were present when David Zitting came out and met with Lyle Jeffs, and Lyle Jeffs told him that he needed to remove himself from the community. A. Q. Uh-hmm. Okay. MR. MATURA: THE WITNESS: BY MR. HAMILTON: Q. And did David Zitting remove himself from the Is that a yes? Yes. Okay. And what was decided?

To see what -- if David Zitting was going to do it

community? A. Q. A. He did. Was there an election to elect a new mayor? I don't recall. It was a scam if there was. What do you mean it was a scam? Why was it a

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170 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. families. Q. A. Really. Yeah. Ask Jerry Darger. Ask Sam Roundy, Jr. their hand and accepted the revelation. Q. A. Q. A. Q. A. Someone tell you that Sam Johnson did that? Yeah, they did. Someone tell you that recall Jerry Darger -Yeah. Are all the officers FLDS? Well, either they're FLDS or they try to be FLDS

to save their families. Q. A. Q. A. Do you know that -Yeah. -- for a fact? Yeah. Because the minute they weren't, they lost their

Let's go down the list. Jerry. Sam. Let's stop with Jerry. Jerry is a current

officer; correct? A. Yeah, without his family. But he's trying to get

his family back, I would assume. Q. So is he FLDS or not FLDS? CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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171 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 had. Either they've gone and deeded all of their -CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 A. Q. A. Q. Well. . . Or do you know? What do you mean do I know? Do you really actually have any knowledge about

that, or are you just speculating? A. Q. A. On what? On whether he's FLDS or not. I would suspect that after he was false -- or, you

know, his father was slammed off the city council and after he was told whatever he was and he was told that he was whatever piece of crap he is, I'm sure that he was probably told that he's not, but I think he's probably still trying to be an officer. Q. Isn't it true you're just guessing now, you're

just speculating? A. Q. In what way? You really don't know whether all the officers are

FLDS or not; correct? A. Well, this is what I do know, Blake, is that every

police officer that wasn't put in united order and go and put all their personal assets in the control of the bishop's office was no longer officers as of 2011. So, that being said, there's only one choice they

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172 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. taken their lists of all their personal assets and given them to the church, which every officer has done, or they haven't done, and if they haven't, they're either kicked out but they're trying to stay in to keep their families. And, no, it's not a guessing game. But you don't really know; right? I mean, you don't know if Jerry Darger was here today whether he would say he was FLDS or not FLDS. A. I think he would say, well, I've been told I'm

not, but I'm trying to be. Q. A. But that's your guess. Oh, no. I've had some discussions with Jerry. And I've had

And I've had discussions with Sam. discussions with different ones. Q.

Have they told you what their religious back --

religious beliefs are? A. Q. I grew up with them, Blake. No, I mean, have -- has Jerry Darger, Sam Johnson,

Helaman Barlow, Curtis Cooke, Hyrum Roundy recently told you what their religions beliefs are? A. Q. A. Q. A. Yeah. They have? Yeah. Every one of them. No. That wasn't the question.

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173 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. Q. A. Q. A. You said is any of them. Okay. And I said yes. Who -- who's had those discussions with you? I'm not going to discuss it with you. I need to protect them and I need to protect their families from being retaliated, Blake. Q. You're telling me that some of those officers have

had personal conversations with you about their religious beliefs. A. Q. A. Q. A. Q. Absolutely. Told you whether they're FLDS or not FLDS. Absolutely. Recently. Yes. You talked about listening to the scanner. One of the allegations that the Department of Justice has alleged, and they said you have information about, is that the Marshal's Office has provided law enforcement information including but not limited to information about emergency calls to FLDS security. Do you know anything about that? Of course I do. Okay. How do you know that? CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649

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202 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that. can. But I -- it doesn't matter what is the time on I could probably get some extra help maybe or CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 line? MR. HAMILTON: out of here. I was working under the assumption you need to leave at 5:30, so -THE WITNESS: I would like to be done at 5:30 if I You tell me when you need to get A. That is just flat not true. Is that a Colorado City police report you're reading to me from? MR. HAMILTON: I think that's probably a good

place to take a break, if you have to leave at 5:30, because we got -- it's 5:25. Do you need -- do you still need to leave at 5:30 to take care of your cattle? THE WITNESS: MS. CROCKETT: questioning -MR. HAMILTON: I'm done with this -- I'm done with And if I How much more before we can be done? I propose finishing this line of

this line of questioning regarding this incident.

move into another area, it's not going to -- I can't finish it up in four minutes. THE WITNESS: So that's why I'm saying -How long before you finish the next

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203 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 * * * * * ______________________________ WILLIAM JESSOP today. So, I think this is a natural breaking point. trying to be respectful of your time, and you said you needed to go take care of your cattle, and I -THE WITNESS: MR. HAMILTON: Perfect. Okay. This concludes tape two in the I'm you -MR. HAMILTON: Yeah, we're not going to finish you something. How much time are you looking at? MR. MATURA: We're not going to be done with

THE VIDEOGRAPHER:

deposition of William Jessop. We are off the record at 4:27. (Whereupon, the deposition recessed at 4:27 p.m.)

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204 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER www.CourtReportersAz.com (480)481-0649 __________________________ C. Martin Herder, CCR Certified Court Reporter Certificate No. 50162 2013. STATE OF ARIZONA COUNTY OF MARICOPA ) ) )

ss.

BE IT KNOWN that the foregoing deposition was taken before me, Marty Herder, a Certified Court Reporter, CCR No. 50162, State of Arizona; that the witness before testifying was duly sworn by me to testify to the whole truth; that the questions propounded to the witness and the answers of the witness thereto were reduced to typewriting under my direction; that the witness elected to read and sign the deposition transcript; that the foregoing 203 pages constitute a true and accurate transcript of all proceedings had upon the taking of said deposition, all done to the best of my skill and ability. I FURTHER CERTIFY that I am in no way related to any of the parties hereto, nor am I in any way interested in the outcome hereof. DATED at Chandler, Arizona, this 27th day of May,