Emily Pulitzer Deposition Transcript 1

Emily Pulitzer
IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS

STATE OF MISSOURI
PAUL GUZZARDO,
PLAINTIFF,
Cause No. 0922-CC01036
vs.
GRAND CENTER, INC., et ale
DEFENDANTS.
DEPOSITION OF EMILY R. PULITZER
TAKEN BY PAUL GUZZARDO, ESQ.
ON BEHALF OF THE PLAINTIFF
JUNE 21, 2013
REPORTED BY KAREN M. RUSSO
CERTIFIED COURT REPORTER, No. 628
CERTIFIED SHORTHAND REPORTER
REGISTERED PROFESSIONAL REPORTER
RUSSO REPORTING, LLC
645 BARSTOW PLACE
ST. LOUIS, MISSOURI 63119
(314)346-0141
www.RussoReportingLLC.com
Page 1 .
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
Emily Pulitzer
Page 2
IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS
STATE OF MISSOURI
PAUL GUZZARDO,
PLAINTIFF,
Cause No. 0922-CCOI036
vs.
GRAND CENTER, INC., et al.
DEFENDANTS.
DEPOSITION OF EMILY R. PULITZER, produced, sworn,
and examined on June 21, 2013, at the offices of The
Grand Center, Inc., 3526 Washington Ave., 2nd Floor, St.
Louis, Missouri, 63015, before Karen M. Russo, Certified
Shorthand Reporter within and for the State of Missouri,
in a certain cause now pending in the Circuit Court of
the City of St. Louis, State of Missouri, between PAUL
GUZZARDO, PLAINTIFF, vs. GRAND CENTER, INC., et al.,
DEFENDANTS.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
r--
24
25
Emily Pulitzer
APPEARANCES
FOR THE PLAINTIFF:
Attorney at Law
Paul Guzzardo, Esq.
1703 Madison
P.O. Box 29
Macomb, Illlinois 61455
309.259.9859
FOR THE DEFENDANTS:
Stinson Morrison Hecker LLP
Cicely I. Lubben, Esq.
7700 Forsyth Blvd.
Suite 1100
St. Louis, Missouri 63105
314.259.4551
FOR THE DEPONENT:
Bryan Cave LLP
Eric D. Martin, Esq.
One Metropolitan Square
211 North Broadway
Suite 3600
St. Louis, Missouri 63102-2750
314.259.2324
ALSO PRESENT:
Lou Stemmler, Certified Legal Video Specialist
Page 3
1
J
Emily Pulitzer
Page 5 j
i
is not waived.
S TIP U L A T ION
MR. STEMMLER: We are on the record. This
Pulitzer in the cause of Paul Guzzardo, Plaintiff, vs.
J
j
t
I
1
i
I
i
1
It's approximately
I'm the plaintiff and MR. GUZZARDO:
Today is June 21, 2013.
counsel for the plaintiff, Paul Guzzardo.
themselves for the record, please.
May I ask counsel present to identify
the county of St. Louis, Missouri.
Specialist, for Legal Video Specialists, LLC, based In
IT IS HEREBY STIPULATED AND AGREED by and between
MS. LUBBEN: Cicely Lubben, counsel for
My name is Lou Stemmler, Certified Legal Video
Incorporated, located in the city of St. Louis, Missouri.
Circuit.
9:04 a.m. We're meeting at the offices of Grand Center,
This videotape is being taken on behalf of the plaintiff.
0922-CCOI036 in the Circuit Court of the City of St.
Grand Center, Incorporated, et al., which is Cause Number
Louis in the State of Missouri, the 22nd Judicial
begins tape one in the videotaped deposition of Emily R.
transcribed into printing, and signature by the witness
counsel for the parties that this deposition may be taken
in shorthand by Karen M. Russo, CSR, RPR, and afterwards
1
2
3
4
5
6
7
8
9
10
11
r--- 12
13
14
15
16
17
18
19
20
21
22
23
24
25
Emily Pulitzer
Page 6
defendants.
Pulitzer.
MR. MARTIN: Eric Martin, counsel for Ms.
MR. STEMMLER: May I ask the court
reporter, Karen Russo, to swear in the witness, please?
EMILY R. PULITZER,
of lawful age, being first duly sworn to tell the truth,
the whole truth, and nothing but the truth, deposes and
says on behalf of the Plaintiff as follows:
DIRECT EXAMINATION
BY MR. GUZZARDO:
Q. Thank you for coming, Mrs. Pulitzer. Currently
are you a director of one of the defendant corporations?
The defendants in this action are Grand Center, Inc.,
Vandeventer-Spring Development Corporation, and City
Center Redevelopment Corporation.
A. I'm a board member of Grand Center, Inc.
Q. Do you recall when you first became a director
of Grand Center, Inc., when that might have been?
A. Probably around 1994.
Q. 1994, okay. And have you been since 1994 in
this interim 19 years?
A. Yes, there may have been a year when I was off,
but ...
MS. LUBBEN: Just make sure you let him
Emily Pulitzer
it would have been in the mid to late 1990's.
the foundation.
A. Yes.
A. Yes.
I
j
1
Thank you. What is your
It takes a while to get used
(By Mr. Guzzardo) Q.
A. Sorry.
MS. LUBBEN:
Q. And was the foundation created prior to the
A. Well, the building was opened in October of
Q. Can we, during the course of this deposition,
Q. Thank you. When was it organized, founded?
A. Yes, 3737 Washington Boulevard and the two
A. I'm the founder and the chair of the board.
Q. Other than the museum by Tadao Ando, the
A. Well, the building process was four years, so
Page 7
Q. Do you recall when that might have been?
Grand Center operated by the PFA?
buildings -- and the one building to the west is owned by
building, are there any other facilities or buildings in
opening of the building?
2001.
refer to it as the PFA? Is that all right?
finish his question before you answer.
relationship to the Pulitzer Foundation of the Arts?
to that.
r"
1
2
3
4
5
6
7
8
9
10
11
.r---
12
13
14
15
16
17
18
19
20
21
22
23
24
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
Emily Pulitzer
Page 8
Q. What is the building to the west?
A. It's a house with a workshop attached to it.
Q. Is there any public facility in that building?
A. No.
Q. There is a park on the corner of Olive and
Spring?
A. Yes. That also belongs to the foundation.
Q. The foundation. There were renovations done to
that park at one time?
A. Well, it was created.
Q. When was that done?
A. In 2001 it was finished.
Q. And there were landscape architects called in
to do that project?
A. Basically, I designed it.
Q. Oh. You designed the project, okay. Have you
read the complaint, the complaint, the petition that the
plaintiff filed in this lawsuit?
A. No.
Q. You have not. Have you read any of the
depositions which have been earlier taken in this
lawsuit?
A. No.
Q. Have you discussed the -- do you know the
individuals who have been deposed in this lawsuit?
Emily Pulitzer
ask you a series of questions about what is called Media
Page 9
do you recall a meeting where the Media Box was first
discussed?
A. No.
Media Box and the Media Box project?
A. I don't recall the year, no.
Q. Do you recall the circumstances where it was?
A. Where the Media Box --
I'm now going to
Do you recall whether or not there was any
Okay. All right, thank you.
No.
Do you recall when you first heard the term the
Q.
Q.
A. No.
Box.
A. Yes.
Q. And who has been deposed based upon your
knowledge?
A. Sung Ho Kim and Vince Schoemehl.
Q. Have you discussed the deposition of Vince
Schoemehl with the executive director Schoemehl? Have
you discussed his deposition with him?
A. No.
Q. Have you discussed the deposition of Sung Ho
Kim with Sung Ho?
A. No.
Q. Have you read any of the interrogatories which
have been answered in this case?
,""--'
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
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
Emily Pulitzer
Page 10
Q. Do you recall being -- do you recall the first
time you were in Sung Ho Kim's architectural office?
A. Yes.
Q. Do you recall the time of the year?
A. No, no.
Q. Do you recall when it occurred at that -- do
you recall who was at that meeting with Sung Ho Kim?
A. Not really. I mean I suppose you were there.
It was a long time ago.
Q. Do you recall whether or not Vince Schoemehl
was present at that time or not?
A. No, I don't recall.
Q. Do you recall anything that was discussed
during the course of that meeting?
A. I don't know if it was at that meeting, but I
remember general discussion about the Media Box.
Q. Okay. At that time do you recall whether or
not there was a location proposed for the Media Box?
A. Yes, I think it was the gasoline station site.
Q. Sometimes referred to as Royal Tire and Auto?
A. (The witness nodded.)
Q. Prior to that meeting at Sung Ho Kim's office
had you any communications with the owner of that
property?
A. No.
Emily Pulitzer
Page 11
Q. Okay. At the time of that meeting were you a
member of a committee, one of the Grand Center
committees?
A. Probably.
Q. Currently what committee are you serving on, if
you are serving on any committees?
A. I'm on the land use committee for the plan, the
framework plan.
Q. For the what plan?
A. Framework plan.
Q. Which is?
A. For the -- it's the master plan for Grand
Center.
Q. Okay.
A. I'm on the nominating committee of the board.
Q. Is there an executive committee?
A. There is.
Q. Are you a member of the executive committee?
A. No, I'm not.
Q. Do you recall whether or not at the time of
that original Media Box member you were a member of the
committee and what committees?
A. I can't remember which ones, no.
Q. Okay. At the time of that meeting do you
recall whether or not you were provided with any visual
Emily Pulitzer
Page 12
documents describing Sung Ho Kim's practice or my
practice?
A. Yes, I think there were sketches of what was
being proposed.
Q. Let me mark this.
(Plaintiff's Exhibit 1 was marked for
identification. )
Q. (By Mr. Guzzardo) Please look at what has been
marked as Exhibit Number 1.
MS. LUBBEN: Do you have an extra copy?
MR. GUZZARDO: Yes.
A. Yes.
Q. (By Mr. Guzzardo) Do you recall whether or not
that document was shown to you at that time or shortly
thereafter?
A. I can't recall the specific document, no.
Q. Have you seen any -- have you seen this
document at all? Do you have a recollection of having
seen this document at any time?
A. I don't recall.
Q. Thank you. What, if any, role did you have in
the drafting of what is referred to as the option
contract regarding the Media Box?
A. None.
Q. Were you -- have you seen the option
Emily Pulitzer
A. I don't remember, but that will be a matter of
discuss the contract with Vince Schoemehl or Alan Pratzel
Q. Were you a member of the real estate committee
Q. Did you discuss the contract with Schoemehl or
1
j
1
j
Page 13 1
1
ii
i
'I
I
I
i
t,

\
I
1
;I
!
I'm now presenting a copy of
I can't go through all of that now.
Prior to -- first of all, what has been marked
No.
(By Mr. Guzzardo)
-- regarding the Media Box?
No.
Let's mark this.
A. I doubt that I discussed the contract.
Q. I understand. Did you have the occasion to
A. No.
Q.
Q.
Q.
A. No. Well, it's signed by Vince Schoemehl, not
A.
Q.
A.
A.
at the time the contract was signed in March of 2004?
Pratzel after the contract was signed if you take
Have you seen this document prior to this time?
Exhibit Number 2 purports to be the Media Box contract.
identification.)
by me.
during the course of the drafting of the contract?
what's been marked as Exhibit Number 2.
contract

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
wwW.RussoReportingLLC.com
Emily Pulitzer

Page 14 1
record.
Q. Okay.
first paragraph
Let me direct your attention to the
to paragraph 3, the first paragraph in
paragraph 3 of the contract, if you take a look at that.
A. Yes.
Q. At the time -- I'm specifically referring to
that section regarding the language that says that the
parties will prepare a prospective program and content
summary for the Media Box with an emphasis on the
scholarly media and communications heritage of St. Louis
University's theorists Marshall McLuhan and Father Walter
Ong. At the time of the contract were you familiar with
Marshall McLuhan and Walter Ong?
A. I never met either of them.
Q. Were you aware of their writings?
A. I was aware that they had written. I have not
read their writings.
Q. Did you know Maurice McNamme?
A. Yes.
Q. You did know Maurice McNamme?
A. Yes.
Q. Father McNamme. Did you ever discuss Marshall
McLuhan with Maurice McNamme?
A. No.
Q. Please take a look at paragraph 5.
www.RusSOReportingLLC.com
Emily Pulitzer
Page 15
last name?
A. I doubt it.
A. Yes.
1
1
I
4
I
1
Did you have any occasion to discuss the Okay. Q.
A. Yes.
A. I doubt it.
Q. -- regarding Marshall McLuhan or Father Walter
A. Yes, yes.
Q. Did you have any conversations with your
A. Cooperation and periodic update?
A. I don't remember.
Q. Yes, the first sentence there.
Q. Did you have any conversations with Vincent
Q. Were you aware of the role of Marshall McLuhan
Q. Did you work with a Craig Kaminer on the Media
Ong?
Box project?
of PFA, Matthias Waschek -- is that how you pronounce his
former, I believe it would have been executive director
Schoemehl about Marshall McLuhan and about the writings
of Marshall McLuhan?
impact they would have on Grand Center?
role of these individuals with Vincent Schoemehl and the
and Walter Ong in the study of media art and
communications?
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

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
Emily Pulitzer
Page 16
A. No. At least I didn't.
Q. Okay. Who is Mr. Kaminer?
A. He's involved in public relations and he worked
with -- he was on the board of the contemporary art
museum which is how I got to know him.
Q. Did he do any PR, public relations work for
Grand Center?
A. I don't know.
Q. Do you know who did the Art Life kind of brand
program for Grand Center?
A. Toky, I think. But I could -- I'm not sure.
identification.)
Q. (By Mr. Guzzardo) I'm representing you Exhibit
Number 3. Please take a look at that.
A. Uh-huh.
Q. Had you seen this document before?
A. I don't think so.
Q. The document discusses a PR campaign regarding
Marshall McLuhan. Did that campaign take place as far as
you know?
A. I don't know.
Q. Did you have any discussions with any members
of the board or with Vince Schoemehl regarding the media
campaign in describing that document?
1
I
i
j
1
Emily Pulitzer
A. No.
been marked Plaintiff's Exhibit 4 and 5. Take a look at
A. I doubt it.
(Plaintiff's Exhibits 4 and 5 were marked for
Just take
Do you recall receiving
I don't know what you
Let me present you what has
There was undoubtedly
Jump to 5, then I'll ask questions.
I've read 4.
(By Mr. Guzzardo)
Well, it's possible.
A.
Q.
Q.
A.
Q. Where is the marked contract? Is that over
I'll ask you to take a look at paragraph 5 in
Page 17
Q. Do you have any recollection of Vince Schoemehl
Q. Could I have the contract?
Do you have any recollection of having received
A. Do you want these?
or a member of the Grand Center staff providing kind of
a look at the other memo.
summaries or a synopsis of the memos for you?
those.
copies of those memos at that time?
identification.)
conversation about it.
the contract, the last sentence.
mean by periodic updates.
there? Oh, here it is.
periodic updates on the development of the Media Box?
,r----
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
Emily Pulitzer
described --
discussion.
A. Yes. Whether it was at the Pulitzer or not I
Do you recall
Do you recall whether or not some of the
Do you recall Sung Ho Kim bringing a
Okay.
Okay.
Q.
Q.
hearing a presentation.
A. Yes, I do.
Q. Do you recall a multimedia presentation that I
Page 18
A. Not an official synopsis. There may have been
Q. You don't remember. Now, there's been some
A. Informally.
Q. Okay. Were there committee meetings which were
Q. You had some discussions. Would those
A. I don't, but it's possible it occurred.
content which is, you know, set out in those memos were
don't know, but I do remember seeing a model and having
that meeting?
gave at that meeting?
model into that meeting?
September of 2004 regarding the Media Box.
earlier testimony that there was a meeting at the PFA In
set where the Media Box was the agenda?
meetings?
discussions have taken place informally or in committee
1
2
3
4
5
6
7
8
9
10
11
r--\
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Emily Pulitzer
Page 19
A. I do not know if this is the specific model
Q. And again regarding that meeting, if you can
A. I don't recall the model accurately enough to
have been presented the content laid out in these two
J
j
Is that the
Does it appear to be
If you'd please take a look
Don't guess.
I suppose so.
MS. LUBBEN:
(By Mr. Guzzardo)
(By Mr. Guzzardo)
There's a model in those images.
-- in that meeting? So at some time you would
Q.
Q.
A.
Q.
A. Yes.
Q.
Q. Why don't we mark this?
A. No.
A. Yes.
A. Yes.
that I had been shown.
similar?
architectural project.
identification. )
at Exhibit Number 6 which is a series of images of an
discussed of the PFA?
model in which you were presented at the meeting we've
recall, who was present?
memos, Exhibits 4 and 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
Emily Pulitzer
A. No.
A. Correct.
the time?
I
I
1
1
1
,
. J
Let me present you what is a
Do you recall an installation
(By Mr. Guzzardo)
He's the director of the Worcester Art Museum
Okay, thank you.
I wasn't there.
Q.
A.
A.
Q.
Page 20
Do you recall seeing any of these e-mails at
Q. Were you aware that there was a projection done
Q. Before I forget, is there -- can you tell me
Q. Thank you.
Q. At that time your executive director was
exhibit.
identification.)
thread of e-mails, if you might take a look at the
in Worcester, Massachusetts.
where Matthias Waschek might be contacted?
Matthias Waschek; is that correct?
Pulitzer Foundation?
on the Pulitzer Foundation at that time?
call it 2004 or 'OS, projection installation on the
that was done at First Night of 2000 -- I guess we would
say.
/'
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
Emily Pulitzer
Page 21
Q. Do you recall whether or not Matthias provided
you with either orally or written summaries regarding the
nature of this projection project?
A. No.
Q. Do you recall any discussions with Matthias or
Vince Schoemehl regarding this installation?
A. I don't recall the installation.
Q. Had the exterior Pulitzer museum been used for
projection projects prior to First Night 2004?
A. I don't remember. I don't remember.
Q. It has been used subsequently, of course?
A. Oh, it's been used frequently.
Q. Subsequently, of course. Are you familiar with
Marshall McLuhan's book The Mechanical Bride?
A. No, I have not read it.
Q. Of course you're familiar with Duchamp's The
Bride Stripped Bare?
A. Yes.
Q. Do you know the relationship between Duchamp's
famous piece and McLuhan's Mechanical Bride?
A. Do I have a relationship --
Q. Do you know what, if any, relationship exist
between Duchamp's The Bride Stripped Bare and Marshall
McLuhan's The Mechanical Bride?
A. No, I don't know of any relationship.
Emily Pulitzer
Q. Prior to the publication did you have any
A. I was on the board of the Pulitzer -- Pulitzer,
Q. What was your position regarding Pulitzer media
Page 22 i
Q. Thank you. Mrs. Pulitzer, I would like to ask I
*
you a few questions now about a Post-Dispatch article
Excuse
The next pages are the
That's a cover page.
Do you recall it at the time being --
Before you take the time to read it, have you
Yes.
(By Mr. Guzzardo)
Q.
Q.
A. It's difficult to read.
A. Probably, yeah.
Q. And the Post-Dispatch was
A. Was owned by the company.
A. Yes.
A. Probably.
Q. That would have been in January of 2005,
Inc.
at that time?
discussion with any of the -- any reporter for the
correct?
read that article prior to now?
when it was published?
article.
entitled "Eminent domain takes aim at life's work."
me, I'm doing my collage art.
identification.)
1
2
3
4
5
6
7
8
9
10
11
f"'
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Emily Pulitzer
Page 23
Post-Dispatch regarding --
A. No.
Q. -- this story? Subsequent to the publication
were there any discussions regarding
A. Discussions with whom?
Q. With the reporter or any representative of the
Post-Dispatch regarding this story?
A. No.
Q. After the publication were there any meetings
at Grand Center dealing with this Post-Dispatch story
regarding the Gentle Jim Day property?
A. There may have been.
Q. Do you recall participating in those meetings?
A. No.
Q. Did you have any contact with Alderman Michael
McMillan regarding this matter --
A. No.
Q. -- matters contained in this story?
A. No.
Q. Did you have any contact with Lacy Clay,
Congressman Lacy Clay, or any of his representatives
regarding this eminent domain action?
A. No.
Q. Were you aware of any contact that Michael
McMillan or Lacy Clay had with Grand Center regarding
Emily Pulitzer
this matter?
A. No.
identification.)
'I
Page 24
1
j
Q. (By Mr. Guzzardo) I'm presenting you now
Exhibit 8 9, excuse me.
the exhibit.
A. Yes.
If you please take a look at
Q. Let me direct your attention to two paragraphs,
the paragraph where it states "A St. Louis auto mechanic
whose repair shop was targeted for acquisition to make
way for a "Media Box" will get to keep his land after
all. The board of directors for Grand Center Development
Agency that presides over the cultural district of the
same name voted to drop its eminent domain suit against
Gentle Jim Day, owner of Royal Auto Repair."
Were you -- did you participate in the meeting
and the vote to drop the condemnation action?
A. I don't remember. Again, it would be a matter
of record.
Q. So you have no specific recollection of
attending that meeting?
A. No.
Q. Further in the article it says, "But on
Thursday Schoemehl said the Grand Center board
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
Emily Pulitzer
Page 25
unanimously followed his recommendation to drop the
eminent domain suit against Day. Other Grand Center
sites will be scouted for the proposed building, he
said."
Did you participate in any discussions with
Vince Schoemehl or other board members regarding the
alternative sites?
identification.)
Q. (By Mr. Guzzardo) I'm presenting you Exhibit
10 which is an e-mail with certain images of the burnt
church, and I believe the date of that is
A. May 18, 2005.
Q. And that would have been a week before the
second Post article carne out?
A. Uh-huh.
Q. At that time were you aware that Grand Center
was proposing the burnt church as a potential site for
consideration for the Media Box?
Q. First just for clarity
A. I would say probably not because I would not be
aware of all the endeavors that Grand Center has -- I
have not been aware of all the endeavors that Grand
Emily Pulitzer
A. There's no date on this.
stabilized.
look.
A. It's a church that was -- that burned in 2000
J
1
.;
f
I
1
1
I'm presenting Exhibit
MR. GUZZARDO: Yeah, let's just swap.
I'm sorry, and the format took something off.
Yes.
Okay.
(By Mr. Guzzardo) The print was much larger.
Q.
A.
Q.
Q.
Q. (By Mr. Guzzardo)
A. Then give it back.
Q. Okay, that's fair. What is the burnt church,
Page 26
MR. GUZZARDO: If you don't mind --
Q. There should be. Excuse me, let me just take a
MS. LUBBEN: Do you want to swap?
Vince Schoemehl, I believe also copied to Peter Bunce.
If you could take a moment and take a look at that.
identification. )
Number 11 which is an e-mail thread between myself and
if you could briefly describe that as a Grand Center
and that Grand Center acquired and has partially
projects.
property?
Center has done for development for various development
,r--.
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
r u r E ~
Q. Do you recall having been -- having seen this 1
2
3
Emily Pulitzer
e-mail thread between myself and Vince Schoemehl and
Peter Bunce?
Page 27 1

f
>\
i
!
l
4
5
A.
Q.
No, no.
There is discussions -- there is discussion
6
7
that there's going to be certain media and electronic
projections done of Grand Center, and Vince Schoemehl
8 discusses the possibility of this project. Do you have
9 any background on that? Did it take place?
10 A. No. What we were discussing at the time were
11 things such as the use of the structures that held
12 billboards on the top of buildings and that this would be
13 a good form -- place for public art.
14
15
16
17
18
Q.
A.
Q.
A.
Q.
I And did that move beyond discussions?
No.
Do you know what happened and why not?
No funding.
There was no funding, okay.
19 (Plaintiff's Exhibit 12 was marked for
20 identification.)
21 Q. (By Mr. Guzzardo) Let me at this time present
22 to you Exhibit 12, and ask you to take a look at it and
23 if you then could identify?
24 I don't mean to be redundant, but just for
25 clarity, you had earlier looked at Exhibit 10 which was
wWw.RussoReportingLLC.com
1
2
3
Emily Pulitzer
referencing the burnt church. At the time of that
meeting was there any discussion regarding the matters
contained in Exhibit 10, the Media Box and the burnt
4
Page 28 I
]
.)
j
I
4
5
6
church, as a potential and alternative site during that
May 7th meeting?
7 Q. And I should clarify, Exhibit Number 12 is
8 could you identify it?
9 A. Exhibit Number 12 is the executive committee
10 meeting of Grand Center of March 15 of 2007, and what
11
12
13
14
15
16
17
18
19
20
21
you're referring to is -- in the minutes is the motion to
borrow the money from the Illinois facilities fund,
$750,000 to fund the stabilization and development of the
burnt church.
Q. Okay. At the time of that motion was there any
discussion regarding the earlier
Q. But you're not sure?
A. No. The purpose was to acquire and stabilize
the church.
Q. When you say acquire
1
I
22
23
A.
Q.
For Grand Center to acquire the property.
Grand Center did not have that property at that
24 time?
25 A. That's correct.
Emily Pulitzer
Page 29
1
2
Q.
A.
If you know?
No, I may be wrong. They may have owned it at
3 that time. I don't know. What this says is to fund the
4 stabilization and development, so I assume they did own
5 the property.
6
7
8
Q. Okay. Do you know the state of that loan?
it been paid back?
A. I don't know. But again, that's a matter of
Has
9 record.
10 Q. Okay. Are you familiar with the term the
11 Phoenix Art Forum?
12
13
A.
Q.
No.
Who made the motion to enter into the loan with
14 the Illinois fund to stabilize the church?
15 A. I did.
16 (Plaintiff's Exhibit 13 was marked for
17 identification.)
18
19
20
21
22
23
24
25
Q.
Number 13.
A.
Q.
A.
Q.
A.
Q.
(By Mr. Guzzardo) Let me present Exhibit
Would you please take a look and read?
Yes.
First of all, have you seen this --
No.
-- document before? I didn't hear that.
No.
This is In reference to the, correct, to the
Emily Pulitzer
A. -- was an artist who used fluorescent fixtures
MS. LUBBEN: Object to lack of foundation.
stabilization of the church?
A. Dan Flavin was --
j
I
1,
t
Page 30 ;1
1
t
i
I have a few questions about
this is in reference to the stabilization
MS. LUBBEN: You can answer if you know.
First of all, if you could tell us, who was Dan
Okay, thank you.
Yes.
Oh, I'm sorry, there's proposed transformation
It's right here.
I'm sorry, I don't see it.
Q. Excuse me, it's Flavin?
Q.
A.
Q.
A. No.
Q.
A.
THE WITNESS: Pardon?
Q. (By Mr. Guzzardo) And you note there is a
Q. But you have no background or information
A.
A. Yes.
A. Yes,
Flavin?
the Flavin Constructed Light installation.
forum, yes.
regarding that?
reference to the Phoenix Art Forum in the document?
of the church.
You can answer if you know.
r--
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
Emily Pulitzer
Page 31
and tubes as the components of his art.
Q. And PFA did a Flavin installation, correct?
A. Yes.
Q. And that would have been in 2008; is that
correct?
A. Yes.
Q. What is the lead time from installing the show
and selecting the artist for the show at the PFA,
generally?
A. Well, in that case it was, I think, about a
year.
Q. About a year, okay. And who at the PFA would
have been the curator in charge of this show?
A. We had an outside curator, a woman named
Tiffany Bell who had worked for the Flavin Foundation and
had been involved in the catalogue raisonne of his work
and a retrospective that traveled, I know it was in
London and I've forgotten exactly other places, but was
shown in major institutions.
Q. Prior to the Constructed Light project had the
PFA ever shown any of the individual Flavin pieces as
part of the collection?
A. The Pulitzer had not, but I had curated an
exhibition of his work at the St. Louis Art Museum in
1973 which was a major exhibition there.
Emily Pulitzer
Page 32
A. No.
A. Yes.
that we would commission light projects in the Grand
Presenting you Exhibit
that's from your website or your
The chicken and egg, what came first?
(By Mr. Guzzardo)
That is
Q.
Q.
A. Yes.
Q.
A. The Flavin exhibition came first, and the idea
A. With the Flavin exhibition, yes.
Q. It refers to the Constructed Light and a -- the
A. Yes, I think it's -- yeah, it's the w s i t ~
Q. Do you personally collect Flavin's work?
Q. Did the Constructed Light installation include
natural light, which normally flows into our building,
for the Constructed Light project came because the
installation was flowing out. And that provided the idea
Center area from younger artists.
light project which was in conjunction to the Constructed
what was occurring at night was the light from the Flavin
promotional material regarding the exhibition; is it?
Light exhibition.
identification.)
Number 14 which is -- just take a look at and identify.
some of your collection?
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
Emily Pulitzer
that's when the light project opened.
A. The Flavin exhibition dates are a matter of
record.
Q. Approximately your exhibitions run for what?
Flavin was up and running and you were --
A. Right.
Q. You realized you had done something quite
extraordinary?
Six or eight months?
A. Six months, yes.
Q. Okay, that's the general.
A. Generally.
Q. SO we can assume something like that. So
So --
I mean this is September of 2008 and
Okay.
No.
Q.
A.
Page 33
Q. Just for clarity, so the Dan Flavin exhibition
had been installed
A. Correct.
Q. -- in the PFA?
A. Correct.
Q. And -- okay. How long -- first, do you recall
the dates of the Constructed Light installation or
opening and closing?
A. No.
Q. lsit on that?

1
2
3
4
5
6
7
8
9
10
11
r--
12
13
14
15
16
17
18
19
20
21
22
23
24
25
WWW.RussoReportingLLC.com
Emily Pulitzer
Page 34
1
2
3
A.
Q.
A.
Yes.
Then there were further discussions?
We went to three curators in St. Louis; Robin
J
1
4 Clark who was the contemporary curator at the St. Louis
5 Art Museum, Matt Straus who heads White Flag, and the
6 curator at the Contemporary Museum. Our feeling was that
7 we were not familiar with young artists' work and they
8 were, and we asked them each to nominate artists for this
9 project. And Robin Clark of the St. Louis Art Museum
10 suggested Ann Lislegaard who had a projection on our back
11 wall of a video she had made and Sebastian Hungerer and
12 Rainer Kehres from Germany who did the Burnt Church
13 project.
14 Q. Was the Lislegaard projection on your back wall
15 or the Contemporary?
16
17
A.
Q.
Yes, on our back wall.
There wasn't a projection on the Contemporary;
18 was there?
19
20
A.
Q.
Not at the time.
You said we. Were you the individual at the
21 Pulitzer who was handling this project?
22 A. No, it was Matthias Waschek, and also we had a
23 social worker on our staff, Lisa Harper Chang, and she
24 was involved in this project because the lamps that were
25 used in the church project were all donated by St.
Emily Pulitzer
Page 35
Louisans.
Q. This is an obvious, but at the time of the lamp
project in the church had the church been stabilized?
A. Yes.
Q. I assume except for the artists?
A. Partially. No one was allowed inside.
on the executive committee of Grand Center at that time?
i
I
1
I
Can you tell us if you were
Q. Again Exhibit 12, it references the executive
committee of Grand Center.
A. Yes.
Q. Were you on the boards of Vandeventer-Spring
Redevelopment Corporation at that time?
A. No.
Q. You were not on the board of Vandeventer-Spring
A. No.
Q. Were you on the board of City Center
A. No.
MR. GUZZARDO: Let's do this as a group
exhibit.
identification.)
Q. (By Mr. Guzzardo) Mrs. Pulitzer, I want to
give you what is marked as Plaintiff's Group Exhibit
If you just take a
Emily Pulitzer
Page 36
Number 15, and it purports to be a series of filings with
Secretary of State Robin Carnahan for 2006 and 2007 of
Vandeventer-Spring Redevelopment Corporation and City
Center Redevelopment Corporation.
moment and look at that.
A. Well, I guess this indicates I was a member of
the City Center Redevelopment Corporation.
Q. Do you recall when you first became a director
of City Center?
A. I didn't recall I was on it.
Q. Do you have any recollection on your current
status as it applies to City Center Corporation
A. I don't think I'm a member.
Q. -- or Vandeventer-Spring, okay. Do you have
any recollection of resigning from either of those two
boards?
A. No, but this is all a matter of record. I mean
you have it.
Q. I understand. I just wondered what you
recalled or remembered. How would you describe your
relationship with Sing Ho Kim and Heather Woofter?
A. When?
Q. Currently.
A. Currently?
Q. Currently.
Emily Pulitzer
Page 37
1
2
3
4
A.
Q.
A.
Q.
They're friends.
How long have they been friends?
Maybe three, four years.
Are you familiar with a complaint filed against
5
6
7
the chief disciplinary counsel Alan Pratzel?
A. No.
Q. Has any member of the staff of Grand Center
8 discussed that complaint with you?
9
10
A.
Q.
No.
You know who -- do you know -- you know who
11 Alan Pratzel is?
12 A. Frankly, I had forgotten, but I see he is or
13 formerly was counsel to Grand Center.
14
15
16
MR. GUZZARDO: Thank you, Mrs. Pulitzer.
MS. LUBBEN: I don't have any questions.
MR. MARTIN: Mrs. Pulitzer, you have the
17 opportunity, if you would like, to review your deposition
18 transcript and see if there are any typographical or
19 other type of errors. Would you like to have the
20 opportunity to review your transcript or waive signature?
21 Either -- I think either is acceptable, but if you want
22 the opportunity to review it you can, or if you are
23 fine--
24 THE WITNESS: I'll review it. Thank you.
25 MR. STEMMLER: It's 10:23 a.m. That
Emily Pulitzer
Page 38
1 concludes the videotaped deposition of Emily R. Pulitzer.
2 We're going off the record.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Emily Pulitzer
J
Page 42 a
1
2
3
4
5
6
7
8
9
10
11
r-
12
13
14
15
16
17
18
19
20
21
22
23
24
25
C E R T I F I CAT ION
I, Karen M. Russo, Certified Shorthand Reporter,
within and for the State of Missouri, DO HEREBY CERTIFY
that pursuant to notice/agreement between the parties,
the aforementioned witness came before me at the time and
place hereinbefore mentioned, and having been duly sworn
to tell the whole truth of her knowledge touching upon
the matter in controversy aforesaid; that she was
examined on the day, and her examination was taken in
shorthand and later reduced to printing; that signature
by the witness is not waived and said deposition is
herewith forwarded to the taking attorney for filing with
the Court.
IN WITNESS WHEREOF, I have hereunto subscribed my
name this 12th day of August, 2013.

Karen M. Russo, CSR, RPR
I
j
I
j
,
!
I
I
I
%
:;
1
i
1
t
I
Emily Pulitzer
Page 43
1 IN THE CIRCUIT COURT OF THE City OF St. Louis STATE OF
MISSOURI
2
PAUL GUZZARDO, ) APPEARANCES
3 ) Paul Guzzardo, Esq.
vs. )
4 No. 0922-CC01036 Cicely I. Lubben, Esq.
) Eric d. Martin, Esq.
5 GRAND CENTER, INC., et al., )
6 CERTIFICATE OF OFFICER AND STATEMENT OF DEPOSITION
CHARGES
7 (See Rule 57.03(g) (2) (a) and Section 492.590 RSMo 1985)
8 Deposition of EMILY PULITZER taken 06/21/2013
9 Total number of pages: 43
10 Name and address of person with custody of original
deposition transcript: Paul Guzzardo, Esq., Attorney at
11 Law, 1703 Madison, P.O. Box 29, Macomb, Illlinois, 61455.
12
13
14
15
16
17
18
Tax info re attorney taking deposition
Attendance of reporter:
Transcription fee, original and copy:
Handling and delivery:
TOTAL TO BE TAXED IN FAVOR OF PLFS:
Tax info re attorneys ordering a copy:
Copy of transcript:
E-Transcript:
Exhibit copying services:
Handling and delivery:
TOTAL TO BE TAXED IN FAVOR OF DEFTS:
$ 50.00
$159.10
$ 10.00
$219.10
$ 77.40
$ 25.00
$ 11.40
$ 10.00
$123.80
Upon delivery of transcripts, the above charges had not
19 yet been paid. It is anticipated that all charges will
be paid in the normal course of business.
20
Reported by: KMR
21
22
23
24
25
RUSSO REPORTING SERVICE
645 BARSTOW PLACE
ST. LOUIS, MISSOURI 63119
(314)346-0141
Emily Pulitzer
Page 44
A
10:2 19:14 belief41 :7 call 20:4 Cicely 3:85:25
$123.8043: 17
area 32:25 believe 15:17 25: 13 called 8:13 9:16 39:443:4
$159.1043:13
art 15:5 16:4,9 26:14 campaign 4:7 Circuit 1:1 2:1,16
$219.1043: 14
20:1522:827:13 Bell 31 :15 16: 19,20,25 5:11,13 43:1
$750,00028: 13
29:11 30:1031:1 belongs 8:7 Carnahan 36:2 circumstances 9:20
a.m 5:1537:25
31 :2434:5,9 best 41:7 case 9:13 31:10 city 1:12:1,175:11
above-captioned
article 4:12,13 22:2 beyond 27: 14 catalogue 31: 16 5:166:1535:17
4
22:9,10 24:24 billboards 27:12 cause 1:52:5,165:9 36:3,7,9,1243:1
.,
39:10
,I
acceptable 37:21
25:16 Blvd 3:839:5 5:10 clarify 28:7
i
!
artist 30:25 31:8 board 6:177:7 Cave3:12 clarity 25:22 27:25
,
accurately 19:25
{
artists 32:25 34:7,8 11:15 16:4,24 Cc39:19 33:1
.'
acquire 28: 19,21
28:22
35:5 22:2024: 13,25 CCR39:18 Clark 34:4,9
1
Arts 7:6 25:635:14,17 Center 1:72:7,13 Clay 23:20,21,25
1
acquired 26:7
~
acquisition 24: 11
asked 34:8 boards 35:11 36:16 2:185:10,156:14 closing 33:8
t
action 6:1423:22
assigned 40:7,9,11 book21:14 6:16,17,197:22 collage 22:8
1
24:18
40: 13,15,17,19 borrow 28:12 11 :2,13 15: 10 collect 32: 1
address 43: 10
assume 29:433:21 Boulevard 7:23 16:7,10 17:24 collection 31 :22
,
1
J
aforementioned
35:5 Box3:4 4:6,9 9:17 23:10,2524:13,25 32:4
:;
42:5
attached 8:2 9: 18,18,21,23 25:2,18,2426:1,4 coming 6: 12
.
,
aforesaid 42:8
Attendance 43: 12 10:16,18 11:21 26:727:728:10 commission 32:24
!
!
age 6:7
attending 24:22 12:23 13:3,12 28:22,23 32:25 41:18
!
!
Agency 24: 14
attention 14:2 24:9 14:9 15:25 17:8 35:8,9,1736:4,7,9 committee 11:2,5,7
i
agenda 18:8
attorney 3:3 42:12 18:8,1224:12 36:1237:7,13 11 :15,16,18,22
t
ago 10:9
43:10,12 25:2028:343:11 39:740:343:5 13:23 18:4,728:9
g
AGREED 5:2
attorneys 43: 15 brand 16:9 certain 2: 1625: 12 35:8,9
'j
aim 22:3
August 39:2 42: 15 Bride 21 :14,17,20 27:6 committees 11 :3,6
I
all:7 2:7,185:10
auto 10:20 24:10 21 :23,24 CERTIFICATE 11:22
!
39:740:343:5
24:16 briefly 26:4 43:6 communications
Alan 13:17 37:5,11
Ave 2:13 bringing 18:18 Certified 1: 16,17 10:23 14:10 15:6
f
Alderman 23: 15
aware 14:15,16 Broadway 3: 13 2:143:175:18 company 22:23
~
'1
15:420:723:24 brochure 4:5 42:2
','
allowed 35:4
complaint 8:17,17
t
alternative 25:7
25:18,24,25 Bryan3:12 CERTIFY42:3 37:4,8
28:4
building 7: 12,15,18 chair 7:7 components 31 :1
Ando7:20
B
7:21,248:1,325:3 Chang 34:23 concludes 38: 1
Ann34:10
back 26:23 29:7
32:21 change 40:7,9,11 condemnation
answer 7:1 30:4,6
34:10,14,16
buildings 7:21,24 40:13,15,17,19 24:18
answered 9:13
background 27:9
27:12 changes 40:5 Congressman
~
!
anticipated 43:19
30:15
Bunce 26:14 27:3 charge 31: 13 23:21
,
1
Bare21 :17,23
J
appear 19:23
burned 26:6 charges 43 :6, 18, 19 conjunction 32:15
i
'I
APPEARANCES
BARSTOW 1:19
burnt4:1425:12 chicken 32: 18 consideration
I
3:1 43:2
43:22
25:1926:328:1,3 chief37:5 25:20
applies 36:12
based 5:199:2
28:1434:12 church4:1425:13 Constructed 30: 19
~
approximately
Basically 8: 15
business 43: 19 25:1926:3,628:1 31 :2032:3,14,15
$
j
5:1433:16
begins 5:8
28:4,14,2029:14
32:2033:7 1
architects 8: 13
behalfl:13 5:17
C
30:1,834:12,25 contact 23: 15,20,24.
architectural 4: 10
6:9 C 42:1,1
35:3,3 39:15
Emily Pulitzer
Page 45
\
contacted 20:14 cultural 24:14 direct 4:3 6:10 14:2 E-Transcript 43: 16 35:2543:16
contained 23:18 curated 31 :23 24:9 earlier8:2118:11 exhibition 31 :24,25
28:3 curator31:13,14 director 6: 13,18 27:2528:16 32:12,16,17,19
contemporary 16:4 34:4,6 9:615:1720:10 egg32:18 33:1,14
34:4,6,15,17 curators 34:3 20:1536:8 eight 33:17 exhibitions 33: 16
content 14:8 18:24 current 36: 11 directors 24: 13 either 14:1421:2 Exhibits 4:4 17:12
19:3 Currently 6: 12 disciplinary 37: 5 36:1537:21,21 19:4
j
contract4:6 12:23 11:5 36:23,24,25 discuss 13: 17,20 electronic 27:6 exist 21 :22
13:1,12,17,18,20 custody 43: 10 14:22 15:8 Emilyl:122:115:8 expires 41 :18
13:21,22,24 14:4 discussed 8:249:5 6:638:1 39:9 exterior 21 :8
14:12 17:2,4,7
D
9:7,9,24 10: 13 40:1 41 :6,11 43:8 extra 12:10
controversy 42:8
d3:1243:4
13:22 19:1837:8 eminent 22:3 23 :22 extraordinary
conversation 17:11
Dan 30:21,23 33:1
discusses 16: 19 24:1525:2 33:25
conversations
date 25:13 26:16
27:8 emphasis 14:9
15: 12,16
dates 33:7,14
discussing 27: 10 Enclosed 39:9
F
Cooperation 15: 1
day 23:11 24:16
discussion 10: 16 Enclosures 39: 19
F42:1 j
copied 26: 14
25:241:13 42:9
18:222:2527:5 endeavors 25:24,25
facilities 7:2128:12 Ii
copies 17:21
42:15
28:2,16 enter29:13
facility 8: 3
1
copy 12:10 13:8
dealing 23 :10
discussions 16:23 entitled 22:3
fair 26:3
39:943:13,15,15
Dear39:8
18:3,421:523:4,5 Eric3:12 6:243:4
familiar 14: 12
defendant 6:13 21 :13,1629:10
fr
copying 43: 16 25:527:5,1434:2 errors 37:19

r--. corner 8:5
defendants 1:8 2:8
district 24: 14 Esq 1:12 3:3,8,12
34:737:4 l
Corporation 6: 15
2:193:66:1,14
document 12:14,16 39:443:3,4,4,10
famous 21 :20
6:1635:12,15,18
DEFTS43:17
12:18,19 13:13 estate 13:23
far 16:20
36:3,4,7,12
delivery 43: 13,17
16:17,19,2529:23 et 1:7 2:7,185:10
Father 14:11,22
I
t
43:18 15:21

corporations 6: 13 30:10 39:740:343:5
1
correct20:11,12
deponent 3: 11 40: 5
documents 12:1 exactly 31 :18
FAVOR43: 14,17

22:1628:2529:25
40:22
doing 22:8 examination 4:3
fee 43:13
31:2,533:3,541:7
deposed 8:259:2
domain 22:3 23 :22 6:1042:9
feeling 34:6
correction 39:12,13
deposes 6:8
24:1525:2 examined 2:12 42:9
filed 8:1837:4
'I
t
40:2
deposition 1: 12
donated 34:25 excuse 22:7 24:6
filing 4: 19 42: 12
corrections 39: 12
2:11 5:3,87:89:5
doubt 13:22 15:15 26:1730:24
filings 36: 1
counsel 5:3,21,24
9:7,937:1738:1
15:23 17:1 executive9:611:16
find 39:9
5:25 6:2 37:5,13
39:9,12,1940:2,4
drafting 12:22 11:1815:1720:10
fine 37:23
39:19
42:11 43:6,8,10
13:18 28:935:7,9
finish 7:1
county 5:2041:3
43:12
drop 24:15,1825:1 exhibit 4:5,6,7,8,9
finished 8:12
course 7:8 10:14
depositions 8:21
Duchamp's21:16 4:10,11,12,13,14
first 6:7,18 9:17,23
13:1821:11,13,16
describe 26:4 36:20
21 :19,23 4:15,16,17,18,19
10:1 13:11 14:3,3
43:19
described 18:25
duly 6:7 42:6 12:6,9 13:6,9,12
15:220:321:9
court 1:1,16 2:1,16
describing 12:1
16: 12,14 17: 15
25:2229:21 30:21
5:11 6:442:13
16:25
E
19:10,13 20:18,22
32:18,1933:6
43:1
designed 8:15,16 E42:1
22:424:3,6,725:9
36:8
cover 22:7
development 6: 15 e-mail25:1226:13
25:11 26:10,12
fixtures 30:25
Craig 15:24
17:824:13 26:1,1 27:2
27:19,22,2528:3
Flag 34:5
.r---.
created 7:148:10
28:13 29:4 e-mails 4:11,15
28:7,929:16,18
Flavin 30:19,22,23
CSR5:442:20
difficult 22:6 20:21,23
32:6,835:7,21,22
30:2431 :2,15,21
.............. w
t ... W Nw"",>., .
Emily Pulitzer
Page 47
r
M
27:2433:11 36:17 motion28:11,15 offices 2:125:15 part 31:22
M 1:16 2:14 5:4
mechanic 24: 10 29:13 official 18: 1 partially 26:7 35:4
39: 18 42:2,20
Mechanical 21 :14 move 27: 14 Oh8:1617:521:12 participate 24: 17 ~
Macomb 3:5 43:11
21 :20,24 multimedia 18:15 30:13 25:5
,
Madison 3:443:11
media 4:6,7,9 9:16 museum 7:20 16:5 okay 6:21 8:169:15 participating 23: 13
major 31: 19,25
9:18,18,21,23 20:1521:831:24 10:1711:1,14,24 parties 5:3 14:8
March 13:24 28:10
10:16,18 11:21 34:5,6,9 14:2 15:8 16:2 42:4
mark 12:5 13:5
12:23 13:3,12 18:7,18,2320:2 Paul 1:4,12 2:4,17
19:9
14:9,10 15:5,24
N
26:3,927:18 3:3 5:9,2439:7,13
marked 12:6,9 13:6
16:24 17:8 18:8
N5:142:1
28:1529:6,10 40:343:2,3,10
13:9,11 16:12
18:1222:1824:12
name 5:18 15:19
30:1831:1233:6 pending 2: 16 ~
17:4,12,15 19:10
25:2027:628:3
24:1542:1543:10
33:13,1936:14 periodic 15: 1 17: 8
~
20:1822:4 24:3
meeting 4: 16 5:15
named31:14
Olive 8:5 17:10
1
25:926:1027:19
9:23 10:7,14,15
natural 32:21
ones 11 :23 person 43:10
29:1632:635:22
10:22 11:1,24
nature 21:3
Ong 14:12,13 15:5 personally 32: 1
,I
35:25
18:11,13,16,19
necessary 39: 12
15:22 Peter 26: 14 27:3
Marshall 14:11,13
19:2,6,1724:17
never 14:14
opened 7:1233:12 petition 8: 17
14:22 15:4,13,14
24:2228:2,5,10
night 20:321:9
opening7:1533:8 PFA7:9,22 15:18
15:21 16:2021:14
meetings 18:5,7
32:22
operated 7:22 18:1119:1831:2
21:23
23:9,13
nodded 10:21
opportunity 37:17 31:8,12,21 33:4
Martin 3:126:2,2
member6:17 11:2
nominate 34:8
37:20,22 Phoenix 29: 11
r--
37:1643:4
11 :18,21,21 13:23
nominating 11: 15
option 4:6 12:22,25 30:10
Massachusetts
17:2436:6,13
normal 43: 19
orally21:2 piece21:20
20:16
37:7
normally 32:21
ordering 43: 15 pieces 31 :21
master 11:12
members 16:23
North 3:13
organized 7:11 place 1:19 16:20
t
l
material 32:12
25:6
notary 39:13 41:17
original 11 :21 18:427:9,13 42:6
Matt 34:5
memo4:817:19
note 30:9
39:1243:10,13 43:22
matter 13:2523:16
memos 17:21,25
notice/agreement
outside 31: 14 places 31 :18
24:1,1929:8
18:24 19:4
42:4
owned 7:2422:23 plaintiff 1:5,13 2:5 J
33:1436:1739:10
mentioned 42:6
number 5:10 12:9
29:2 2:183:25:9,17,23 j
39:1442:8
met 14:14
13:9,12 16:15
owner 10:2324:16 5:246:98:18 J
matters 23:18 28:2
Metropolitan 3: 13
19:13 26:13 28:7
Plaintiffs 12:6
Matthias 15:18
Michael 23:15,24
28:929:1932:9 P
13:6 16:12 17:12
20:11,1421:1,5
mid 7:19
36:1 43:9 P 5:1
17:1519:1020:18
34:22
mind26:19
P.O 3:443:11
22:424:325:9
Maurice 14:18,20
minutes 4:16 28:11
0
page 4:222:739: 12
26:10 27:19 29:16
14:23
Missouri 1:2,20 2:2
05:1 42:1
40:6,8,10,12,14
32:635:22,25
McLuhan 14:11,13
2:14,15,173:9,14
Object 30:3
40:16,18
plan 11 :7,8,9,10,12
14:23 15:4,13,14
5:12,16,2039:6
obvious 35:2
pages 22:843:9
please 5:226:5
15:21 16:20
42:343:1,22
occasion 13:16 15:8
paid 29:743:19,19
12:8 14:25 16:15
McLuhan's 21: 14
model 18:19,21
occurred 10:6
paragraph 14:3,3,3
19:1224:629:19
21:20,24
19: 16,17,21,25
18:14
14:4,25 17:6
39:9,12,14
McMillan 23: 16,25
moment26:1536:5
occurring 32:22
24:10
PLFS43:14
McNamme 14:18
money28:12
October 7: 12
paragraphs 24:9
position 22: 18
,.-...
office 10:2,22
14:20,22,23
months33:17,18
Pardon 30:5
possibility 27:8
Imean 10:8 17:10
Morrison 3:7 39:4
OFFICER43:6
park 8:5,9
possible 17:9 18:14
~ mm;&m;%
Emily Pulitzer
Page 49
,"
"'
show 31 :7,8,13 status 36:12 takes 7:322:3 Transcription vs 1:6 2:6,18 5:9
shown 12:14 19:22 Stemmler 3: 17 5:7 tape 5:8 43:13 39:740:343:3
31:19,21 5:186:437:25 targeted 24: 11 transcripts 43: 18
sign 39:10,12 Stinson 3:739:4 Tax43:12,15 transformation
W
signature 5:537:20 STIPULATED 5:2 TAXED 43:14,17 30:13
waive 37:20
39:1240:2242:10 story 23 :3,7, 10, 18 tell 6:7 20:13 30:21 traveled 31 :17
waived 5:642:11
signed 13: 14,21,24 Straus 34:5 35:842:7 true41:7
wa1l34:11,14,16
similar 19:24 Stripped 21 :17,23 term 9: 1729: 10 truth 6:7,8,8 42:7
Walter 14:11,13
Sincerely 39:16 structures 27: 11 testimony 18:11 tubes 31:1
15:5,21
Sing 36:21 study 15:5 39:9 two 7:23 19:324:9
want 17:326:20
site 10:19 25:19 subscribed 41 :13 thank6:127:5,11 36:15
35:2437:21
28:4 42:14 9:15 12:21 20:2 type 37:19
Waschek 15:18
sites 25:3,7 subscribing 40:4 20:1722:130:18 typographical
20:11,1434:22
Six 33:17,18 Subsequent 23:3 37:14,24 37:18
Washington 2:13
sketches 12:3 subsequently 21 :11 theorists 14:11
7:23
social 34:23 21:13 thereon 40:5
U
wasn't20:634:17
sorry 7:226:24 suggested 34: 10 things 27:11
U5:1 way 24:12
30:11,13 suit 24:1525:2 think 10:19 12:3
Uh-huh 16:16 We're 5:1538:2
Specialist 3:175:19 Suite 3:9,1439:5 16:11,1828:6,17
25:17 we've 19:17
Specialists 5:19 summaries 17:25 31 :1032:13 36:13
unanimously 25: 1 website 32:11,13
specific 12: 16 21:2 37:21
understand 13: 16 week25:15
...-...
19:21 24:21 summary 14:9 thread 4: 11,15
36:1939:10 went34:3
specifically 14:6 Sung 9:4,9,10 10:2 20:21 26:13 27:2
undoubtedly 17: 10 west 7:24 8:1
Spring 8:6 10:7,22 12:1 three 34:3 37:3
University's 14:11 WHEREOF 42:14
Square 3:13 18:18 Thursday 24:25
update 15:1 White 34:5
St 1:1,202:1,13,17 suppose 10:8 19:19 Tiffany 31 :15
updates 17:8,10 witness 5:56:5
3:9,145:11,16,20 sure 6:25 16:11 time 8:9 10:2,4,9,11
use 11:7 27:11 10:21 30:537:24
14:10 24:10 31:24 28:18 10:17 11 :1,20,24
42:5,11,14
34:3,4,9,25 39:6 swap 26:20,21 12: 14, 19 13: 13,24
V
woman31:14
43:1,22 swear 6:5 14:6,12 17:21
Vandeventer-Sp...
wondered 36:19
stabilization 28: 13 sworn 2:11 6:7 19:220:8,10,24
6:1535:11,14
Woofter 36:21
29:430:1,7 41:1342:6 22:9,12,1925:18
36:3,14
Worcester 20: 15
stabilize 28: 19 synopsis 17:25 18: 1 27:10,21 28:1,15
various 26: 1
20:16
29:14 28:2429:3 31:7
video 3:175: 18,19
work 15:24 16:6
stabilized 26:8 35:3
T
34:1935:2,9,12
34:11
22:331:16,24
staffl7:2434:23
T 5:1,1 42:1,1
35:15,1842:5
videotape 5: 17
32:1 34:7
37:7
Tadao7:20
Tire 10:20
videotaped 5:8
worked 16:331:15
state 1:2 2:2,15,17
take 13:21 14:4,25
Today 5:14
38:1
worker 34:23
4:195:1229:6
16:15,2017:6,15
Toky 16:11
Vince 9:4,5 10:10
workshop 8:2
36:241 :2,642:3
17:1819:1220:21
top 27:12
13:14,17 16:24
writings 14:15,17
43:1
22:924:626:15
TotaI43:9,14,17
17:23 21:625:6
15:13
STATEMENT
26:15,1727:9,22
touching 42:7
26:1427:2,7
written 14:16 21:2
43:6
29:1932:936:4
transcribed 5: 5
Vincent 15:9,12
wrong 29:2
statements 41:7
taken 1:12 5:3,17
transcript 37: 18,20
visual 11 :25
www.RussoRepo...

states 24: 10
8:21 18:442:9
39:9,10,11 43:10
vote24:18
1:21
Istation 10:19
43:8
43:15
voted 24:15
/
/
:
Emily Pulitzer
Page 50
X
24:6 13:6,9,1243:7 4343:9
204:11 492.59043:7
y
200020:3 26:6
yeah 22:1426:21 2001 7:13 8:12
5
32:13 200413:2418:12
54:3,9 14:25 17:6
year 6:23 9:19 10:4 20:421 :9
17:12,15,18 19:4
31:11,12 200522:1525:14
50.0043:12
years 6:227:18 200636:2
57.03(g) 43:7
37:3 200728:10 36:2
6
young 34:7 200831:433:11
younger 32:25 20131:13 2:12 5:14
64:10 19:10,13
39:2,941 :14
614553:543:11
Z
42:15
6281:16
211:13 2:12 5:14
630152:14
0
39:9
63102-27503:14
0520:4
2113:13
631053:939:6
06/211201343:8
224:12
63119 1:20 43 :22
0922-CCOI0361 :5
22nd 5:12
6451:1943:22
2:5 5:11 43:4
244:13
I
7
1
254:14
74:1120:18
14:5 12:6,9
25.0043:16
77.4043:15
,----..
264:15
. 104:1425:9,12
274:16
77003:839:5
27:2528:3
293:44:1743:11
7th 28:5
10.0043: 13, 17
10:2337:25
2nd 2:13
8
114:1526:10,13
3
84:1222:424:6
11.4043:16
34:714:3,416:12
9
11003:939:5
16:15
124:5,1627:19,22
3/15/074:16
!
28:7,935:7
3/30/07 4: 17
12th42:15
309.259.98593:5
134:6,1729:16,19
314)346-01411 :20
144:1832:6,9
39:1543:23
154:1928:1035:22
314.259.23243:15
36:1
314.259.45513:10
164:7
324:18
174:8,9
354:19 I
17033:443:11
35262:13 I
1825:14
"t
36003:14
194:106:22
37377:23
197331:25
198543:7 4
1990's 7:19
44:8 17:12,15,17
19946:20,21,21
19:4
2
4/14/044:8
"

Emily Pulitzer Deposition Transcript 1

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Emily Pulitzer Deposition Transcript 1

Uploaded by

Copyright:

Available Formats

Emily Pulitzer

IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS

You might also like