IN THE CIRCUIT COURT OF THE CITY OF ST.

LOUIS
STATE OF MISSOURI
Honorable Rex M. Burlison, Judge

STATE OF MISSOURI, )
)
Plaintiff, )
)
vs. ) Cause No. 1822-CR00642
)
ERIC GREITENS, )
)
Defendant. )

TRANSCRIPT OF MOTION HEARING

April 12, 2018

MS. KIMBERLY GARDNER

HON. ROBERT DIERKER
MR. ROBERT STEELE
Circuit Attorney's Office
1114 Market Street
St. Louis, MO 63101
on behalf of the State of Missouri;

MR. JAMES BENNETT MR. SCOTT ROSENBLUM

MR. JAMES MARTIN Rosenblum Schwartz & Fry
MR. EDWARD DOWD 120 S. Central Ave. #130
MS. MICHELLE NASSER St. Louis, MO 63105
DOWD BENNETT LLP
7733 Forsyth Blvd. #1900
St. Louis, MO 63105
on behalf of the Defendant.

JENNIFER A. DUNN, RPR, CCR #485

OFFICIAL COURT REPORTER
CITY OF ST. LOUIS CIRCUIT COURT
TWENTY-SECOND JUDICIAL CIRCUIT
 2

1 (The following proceedings were had in open

2 court:)
3 THE COURT: Court recalls Cause Number
4 1822-CR00642, State of Missouri versus Eric Greitens.
5 Mr. Martin.
6 MR. MARTIN: Thank you, your Honor. As you
7 may recall from the other day, the motion that we noticed up
8 for today is the motion to redepose William Tisaby, the
9 private investigator hired by the circuit attorney. And for
10 sanctions.
11 I will be very candid with you, because at the end
12 of this we are going to ask for more severe sanctions than
13 what we had previously anticipated asking for.
14 As the Court knows, we took Mr. Tisaby's
15 deposition about a month ago, March 19th. He and the
16 circuit attorney, Ms. Gardner, attended the deposition,
17 every minute of it, said there will be a taped interview of
18 K.S., the alleged victim in this case. But they said the
19 video recorder malfunctioned.
20 Low and behold, we filed this motion today. A few
21 days ago we filed the motion for all exculpatory
22 information, including the equipment that supposedly
23 malfunctioned. And then just hours after the House
24 Committee is issuing its report and conveniently after it
25 has obtained a gag order in this case, the videotape has
 3

1 magically appeared and been produced. We got it last night

2 at 6 o'clock.
3 The tape that Mr. Tisaby claimed in his deposition
4 did not exist while Ms. Gardner was sitting there does
5 exist. It shows, when we got it, it was too late for us to
6 use it to possibly stop the House from issuing an inaccurate
7 report so we could have shown them that they had
8 misinformation about what K.S. was saying in other arenas.
9 There are -- this videotape shows major flaws in
10 K.S.'s testimony, more than we were ever aware of before,
11 and we've pointed some of them out to you before.
12 What it shows is that her story is just that,
13 Judge, it's a story. She indicated to the Grand Jury and to
14 the House when she was in the basement she was numb and
15 didn't know what to do. In this tape, she says she was
16 turned on.
17 That's not in Mr. Tisaby's memo. He didn't
18 mention that in his deposition. We didn't find that out
19 until last night when we got this nonexistent videotape.
20 The tape tells an entirely different story about
21 Ms. K.S.'s interactions with the governor. She has
22 suggested to the House and to the Grand Jury that some of
23 her activities were nonconsensual. The tape shows that just
24 isn't true.
25 And I'm concerned that as I go on today, and it's
 4

1 going to take some time to lay out for you how significant
2 this is and how serious the sanctions must be, that it may
3 sound like I'm just using hyperbole, but the reality is this
4 evidence was hidden from us. It greatly undercuts her
5 credibility, and it was hidden from us until, low and
6 behold, the House has already put out their fallacious and
7 extremely damaging report.
8 Judge, the biggest thing that the press seems to
9 be focused on that has gotten the most attention is this
10 alleged slap. In this videotape interview that was not
11 turned over to us, that was hidden from us for a month, she,
12 K.S., told Mr. Tisaby and Ms. Gardner, who were both at that
13 interview, that just this past January she went back to her
14 friends that she had spoken to, that she said she told them
15 everything that had gone on between her and the governor.
16 And in this taped interview, she said she went
17 back to them this January and asked if they remembered her
18 telling them about a slap. And she said in this interview
19 to Mr. Tisaby and Ms. Gardner that they didn't remember her
20 ever mentioning that.
21 Suddenly now we have evidence that the slap could
22 all be made up. That, in fact, she may have made an effort
23 to have her friends support a made-up story. That evidence
24 was kept from us until late last night when we filed
25 multiple motions trying to get the camera.
 5

1 In fact, one motion that said if you don't have

2 the video, give us the camera so we can check it out, and
3 suddenly it appears after the House put out their report.
4 And in talking about the slap, when K.S. in this
5 interview that we just got is talking about it, she actually
6 looks over to her lawyer, and the still picture won't
7 capture it completely, but as she's talking about that
8 event, the still picture shows, and it's the third picture
9 down, we'll talk about the other two in a minute, she
10 laughs. She looks at her lawyer and she's laughing.
11 Maybe that means a hundred different things, but
12 it's certainly significant evidence that would have made a
13 huge difference in our deposition of K.S.
14 Judge, we believe, as much as anybody, that
15 victims need to be protected. But this woman is not a
16 victim. She was a willing participant in everything they
17 did, and this video goes a long way to establishing that.
18 The disclosures yesterday are a bombshell. And
19 it's not just the video, Judge. You may recall from the
20 motion that we talked about multiple times, and I'll show
21 you the transcript, multiple times Mr. Tisaby said he took
22 no notes. He never takes notes when he talks to a witness.
23 I'm going to hand you now, which is 11 pages of
24 notes of Mr. Tisaby from that interview, never turned over
25 to us before. The notes happen to be written on a
 6

1 memorandum of interview by Ms. Gardner from an interview she

2 did by herself five days earlier.
3 THE COURT: Go back over that again.
4 MR. MARTIN: Ms. Gardner interviewed K.S. by
5 herself on January 24th. The notes of January 29th, the
6 handwritten notes of January 29th of Mr. Tisaby where
7 written on Ms. Gardner's January 24th notes.
8 THE COURT: Typewritten notes.
9 MR. MARTIN: Typewritten notes that we had
10 never been provided before. Two sets of notes we had never
11 been provided before, and a videotape we had never been
12 provided before. And as we'll show you in the transcript,
13 Mr. Tisaby and Ms. Gardner said they didn't exist.
14 When we filed this motion, we expressed grave
15 concerns that there could be destruction of evidence because
16 of this ridiculous claim that the videotape had
17 malfunctioned. You may recall that just the other day the
18 circuit attorney mocked us that we were just playing to the
19 press, but low and behold, the videotape has shown up.
20 We filed a motion that said it was absurd that a
21 former FBI agent, notwithstanding all his incredible
22 background, that he never took notes and that was his
23 practice, never to take notes. We filed a motion on that.
24 The Circuit Attorney's Office mocked us saying we
25 were playing to the press. Low and behold, we have those
 7

1 notes.
2 We filed a motion that said it was blatantly
3 absurd that Mr. Tisaby would do a two-hour interview on
4 January 29th and not ask any questions, but that's what he
5 testified to. The circuit attorney, again, mocked us,
6 saying we were just playing to the press.
7 And low and behold, the video says that Mr. Tisaby
8 was asking all sorts of questions. In fact, he was asking
9 questions that were fed to him, you can see it on the video
10 by Ms. Gardner.
11 We have a multitude of lies, straight out perjury,
12 lies under oath by Mr. Tisaby in his deposition. You will
13 recall we set out in the motion itself what we thought at
14 the time was the biggest lie and that was we took a break
15 for lunch, and he said I'll go to my hotel, I'll check my
16 laptop and I'll see if I have any earlier drafts of my final
17 interview of K.S.
18 He came back, and I asked him, quote, under oath,
19 are you telling us you've checked your laptop and you found
20 no drafts? He said: Yes, sir.
21 Two hours later he admitted his laptop wasn't in
22 St. Louis. At the time we thought that was huge that a
23 former FBI agent, the private investigator hired by the
24 circuit attorney because she couldn't trust the police, I
25 guess, went and lied to us about whether he looked at his
 8

1 laptop or not, but that lie pales in comparison to what we

2 have now.
3 Judge, I'm going to hand you a portion of the
4 transcript of Mr. Tisaby's deposition. If you go to
5 page 13.
6 THE COURT: 113?
7 MR. MARTIN: Yes, thank you. Page 113.
8 "QUESTION: So as a former FBI agent, you sat
9 through a multiple-hour interview asking a woman detailed
10 questions about her activities that are the focus of your
11 investigation and you took no notes? Didn't type no
12 contemporaneous information down, just sat there and
13 listened?
14 "ANSWER: Until she left.
15 "QUESTION: You did, you wrote, you put
16 nothing to paper until she left except the preamble? Thank
17 you."
18 That's what I did when she left I started.
19 Page 115.
20 "QUESTION: Your testimony is that every time
21 you have ever done an interview you just listen and only at
22 the end of any time you've done an interview, and at the end
23 of the interview do you write down the substance of what the
24 witness said?"
25 Yes, sir. Yes, sir. My whole career, my
 9

1 whole career.
2 "QUESTION: You don't take notes while the
3 witness is talking?
4 I sit, and I sit, I sit and take in
5 everything that she may say, Mr. Martin.
6 You took it into your brain?
7 Yes, sir.
8 You don't write it down?
9 I don't write it down.
10 Page 117.
11 Okay. And so the interview went from 7
12 o'clock until when? Mr. Martin, I would say left at nine.
13 So lasted at least two hours.
14 At least two hours.
15 And then you're starting at 9 o'clock, that's
16 when you started typing up anything she said?
17 Sometime shortly thereafter.
18 And you had nothing to look at, just your
19 memory?
20 "ANSWER: Just my memory."
21 Today we have 11 pages of notes. That is a lie
22 under oath. That is perjury.
23 Your Honor, if you'll look at the photographs I
24 gave you in case there's any doubt of whether those were his
25 notes, you'll see the top two, we took just a couple of
 10

1 still shots of Mr. Tisaby, pad and pen in hand writing

2 things down.
3 THE COURT: These photographs came from the
4 video?
5 MR. MARTIN: From the January 29 videotape.
6 THE COURT: That you just got yesterday?
7 MR. MARTIN: That just got turned over.
8 Judge, we would have had these more organized, I was up till
9 midnight because we only got this at 6 o'clock last night.
10 Six hours with a heck of a lot of information.
11 Judge, line number three. If you look at
12 page 174.
13 And you are confident you didn't ask any
14 questions?
15 I'm confident.
16 Page 189.
17 Well, isn't it possible that she wanted to
18 keep the purse and the keys separate?
19 I don't know that, Mr. Martin.
20 "QUESTION: Well, did you ask?"
21 No, sir.
22 "QUESTION: Because you didn't ask any
23 questions?
24 No, sir.
25 "QUESTION: No, sir meaning yes, I did not
 11

1 ask any questions?

2 "ANSWER: I did not ask any questions."
3 Well, we don't yet have the transcript of that
4 tape but, Judge, we're happy to play the entire interview.
5 I don't think you want to take the time for the hearing now.
6 He asked multiple questions, and there's no way the circuit
7 attorney is going to deny that.
8 THE COURT: Who was at this interview?
9 MR. MARTIN: The interview?
10 THE COURT: Who was in the room?
11 MR. MARTIN: In the room; K.S., Mr. Tisaby,
12 Ms. Gardner, and K.S.'s attorney, Scott Simpson.
13 And as I said before, some of the questions asked
14 by Mr. Tisaby, you can see in the video, Ms. Gardner
15 pointing to her notes as to what she wanted asked.
16 Mr. Tisaby sat there under oath in his deposition
17 and lied to us multiple times, while Ms. Gardner, who had
18 attended the deposition, who would have seen the 11 pages of
19 notes, who had him ask questions, who knew there was a
20 videotape, sat there and let him lie every time.
21 She said nothing. She never asked him to correct
22 his lies. She sat there and allowed him to lie under oath.
23 And including, your Honor, page 294, which I have somewhere,
24 of the deposition, 293 of the deposition, after we have
25 grilled Mr. Tisaby how he could possibly exist as an agent
 12

1 and not take notes, we asked him on page 293, or I ask you
2 to look at page 293, because I am no longer the one asking
3 the question.
4 This is Ms. Gardner. She has just sat there,
5 after she attended the interview, 11 pages of notes, written
6 on her prior notes, she often, during the interview, was
7 sitting right next to Mr. Tisaby.
8 And she asked Mr. Tisaby:
9 Was every handwritten note that you've talked
10 about turned over?
11 Yes.
12 She didn't just sit there and conspire in
13 silence. She asked him the question. She suborned perjury.
14 It's very harsh, I understand that, but this is incredible.
15 In a case like this, in a case with this
16 significance, knowing the House was going to put out such
17 vile information in a report, to not turn over the
18 information to us that would have disproved much of what
19 K.S. is saying and completely disprove this claim of
20 nonconsensual is so wrong, Judge.
21 Page 159 and 160. We asked Mr. Tisaby if his
22 memorandum of interviews reflected everything that K.S. said
23 during the interview. If you'll look at the bottom of
24 page 159.
25 Is this everything that she said to you?
 13

1 And we were referring to his memorandum of

2 interview.
3 Yes, sir.
4 Top of 160.
5 There's nothing you left out?
6 No, sir.
7 There are huge things left out of this. Nowhere
8 in his memorandum is it reflected that she said on March 21,
9 in the basement, while she was supposedly tied up on these
10 rings, that she was turned on.
11 Nowhere in this memorandum of the interview does
12 it indicate that her friends were telling her I don't think
13 you ever told me about a slap.
14 Mr. Tisaby also testified that he never reviewed
15 the tape that the ex-husband had made back on March 24,
16 2015, what was first released to the media. The video shows
17 Mr. Tisaby, because the camera's over his shoulder, over
18 this shoulder actually, shows Mr. Tisaby looking at the
19 transcript from March 24th.
20 But he told us in his deposition he had never --
21 he didn't want to know about it, in fact, is what he said.
22 And I'll refer you back to page 117. We asked him
23 if he used anything other than his memory to write his
24 memorandum of interview. And he said, no, only his memory.
25 But now we know he has 11 pages of his own notes,
 14

1 he has eight pages of Ms. Gardner's notes.

2 And in a minute I'm going to show you how his
3 memorandum is almost a quote, quote from quote of not what
4 he wrote down, but of what Ms. Gardner wrote down. But he
5 said he looked at nothing and only used his memory to write
6 this report.
7 And the question is why is he telling all these
8 lies? Because they don't want his notes. They don't want
9 Ms. Gardner's notes, and they don't want this video seen by
10 us because it is very exculpatory, and it undercuts K.S.'s
11 credibility completely, which candidly destroys their case.
12 I'm going to give you now a copy of what's called
13 the Investigative Narrative Confidential. It's the report
14 that Mr. Tisaby wrote regarding the interview of K.S. And I
15 only did the first one and a half pages, because again, it
16 was midnight, but what I did is I highlighted -- I
17 highlighted the portions of Mr. Tisaby's memorandum of
18 interview that are not from his notes, but from the typed
19 notes of Ms. Gardner from January 24th.
20 And if you start to look at it, it's a huge
21 portion of his memorandum that he said he only did from
22 memory, that he didn't look at anybody else's information.
23 That he didn't have notes for.
24 These aren't even from his notes. These are from
25 Ms. Gardner's notes. And the parts that I've highlighted
 15

1 are only direct quotes from Ms. Gardner's typed notes. They
2 are not, gee, they're close, they are quotations from Ms.
3 Gardner's notes.
4 If you look at the one, two, three, four, five,
5 six, the second paragraph from the bottom, let's do it that
6 way. And where I highlighted, she stated E.G.'s home was
7 big, a big CWE brick home, more than one level, about three
8 levels.
9 That was a direct quote from Ms. Gardner's notes.
10 There is no way -- well, I can tell you I've reviewed the
11 video, that was not stated in the video.
12 And oddly, oddly, Mr. Tisaby sat there in a
13 deposition and he said, you know what, I didn't even know
14 what CWE meant, but he had lived in St. Louis for eight
15 years, I'm a little surprised at that, having been a former
16 FBI agent, but he said -- he testified about this supposed
17 information he got from K.S., and said, yeah, I didn't even
18 know who CWE was.
19 I asked him, you didn't ask her what that meant
20 even though you were writing that down? And he stated no, I
21 didn't ask any questions.
22 But that's because she didn't say it and he didn't
23 write it down. He took it from Ms. Gardner's notes. Notes
24 he said he never saw and never used to write his memorandum.
25 In the first paragraph of the second page. He has
 16

1 quote, E.G. made her change clothes out. E.G. made her take
2 off everything. She was shaking and nervous. Those are
3 from Ms. Gardner's notes. Those are direct quotes from Ms.
4 Gardner's notes.
5 And importantly, K.S., in the interview, never
6 said Mr. Greitens made me change into other clothes. She
7 never said that. And I asked him specifically in the
8 deposition, you're saying she said he made her get into
9 these other clothes, and he said that's what she said. He
10 didn't say it in the interview he attended. It's simply
11 notes that Ms. Gardner wrote down.
12 Then important to talking about the exculpatory
13 nature of this tape. Mr. Tisaby wrote in the next
14 paragraph, after -- after she's taken off all her clothes,
15 changed into these other clothes, supposedly only 40 minutes
16 before she had to go to work. After she goes down into the
17 basement, it's an unfinished basement, after she allows
18 voluntarily to have her hands gauze taped to the rings, and
19 she's there supposedly with her hands up on the rings in
20 these different outfit and, quote, K.S. stated at this point
21 she was still thinking that E.G. just wanted to talk.
22 That's actually a direct quote from Ms. Gardner's
23 notes. That is hugely Brady material. That is hugely
24 important.
25 Now that one we had from this report. We had
 17

1 that. But the most important thing about that is she didn't
2 say it to Mr. Tisaby, she said it to the circuit attorney in
3 a one-on-one, plus her -- K.S.'s lawyer, but a one-on-one
4 interview. That's critical information.
5 The circuit attorney knew from the start that she
6 was telling this ridiculous story that after taking off her
7 clothes, sneaking over there, going down to a basement,
8 supposedly being tied up on rings, she thought they were
9 there just to have a chat.
10 Now, if we look at Ms. Gardner's notes from the
11 24th. There are a couple of important points within that.
12 Notes we had never gotten before. Because one of the things
13 that the note says is it's been reported in the press that
14 allegedly, according to Ms. K.S., that Mr. Greitens rubbed
15 her leg in a suggestive fashion.
16 She's telling everybody she either told him stop
17 that, or what are you doing, in a shock and surprise, but
18 the first time she's ever talked to, the time she's talking
19 to Ms. Gardner on her own, what do Ms. Gardner's notes say?
20 Looked at E.G., and he looked sheepish back at her and did
21 not say anything as she was blow drying his hair.
22 Not an unwelcomed move. Not a move that surprised
23 her. But what apparently was described to Ms. Gardner as
24 flirtatious and I guess romantic. But we didn't get that
25 until last night.
 18

1 What's also in the tape, some things that we

2 actually knew because we got it from depositions, but she
3 didn't tell earlier times and, in fact, lied in earlier
4 times, the most blatant one being her discussion of the
5 FaceTiming, which is now out in the public, that she's
6 admitted she FaceTimed with Mr. Greitens while she was at
7 least partially nude.
8 But talking to Ms. Gardner and talking to Mr.
9 Tisaby, she made it sound like that the governor tried --
10 tried to FaceTime with her, she shut it down and showed her
11 husband so that her husband had nothing to worry about.
12 Grossly different stories that show that there is
13 significant credibility issues with this witness.
14 And we've been accused by the circuit attorney of
15 bashing on the witness. Candidly, the circuit attorney
16 should have been bashing on this witness because her story
17 doesn't fly.
18 One of the things she also said in the video
19 deposition, she told Ms. Gardner and Mr. Tisaby, was that
20 her husband was shopping this story around. That's
21 extremely significant to us. Particularly given the
22 disclosure yesterday in the House report that P.S., the
23 former husband of K.S., has admitted under oath that he was
24 getting paid for disclosing this story and, apparently, K.S.
25 knew he was shopping the story around.
 19

1 The timing of finally turning this stuff over is

2 so obviously connected to the release of the report and
3 getting a gag order, it is sinister. And while our original
4 request was for sanctions that we get to redepose Mr.
5 Tisaby, that one I assume seems fairly obvious. We will
6 certainly need to redepose K.S. We may need to redepose --
7 we may need to depose K.S.'s attorney, who was also quoted
8 as saying the video didn't work.
9 But what we have here is criminal perjury under
10 oath. Multiple, multiple lies by a former FBI agent, by the
11 hired man to do this private investigation because the St.
12 Louis Metropolitan Police Department wasn't good enough to
13 do it.
14 Judge, I don't need to tell you in our criminal
15 justice system nothing is more dangerous than a dishonest
16 prosecutor. And Ms. Gardner, the elected circuit attorney,
17 the head of this office, was a full participant in this
18 conspiracy to keep information from us, to allow Mr. Tisaby
19 to lie.
20 This isn't playing with the press. This is real.
21 This is real. And candidly, your Honor, and I have been
22 involved in a case before over in the federal system where
23 the prosecutors found witnesses, they were -- they were
24 visitors from other countries who were favorable to the
25 government, and they shipped them out and didn't tell us
 20

1 about it.
2 Judge Buckles threw out that case. That's what
3 we're asking for here. The lies that have been told, the
4 fact that Ms. Gardner sat in these interviews, the fact that
5 Ms. Gardner sat in the deposition, the fact that she even
6 elicited questions there were no other notes to be had, this
7 is an egregious situation and it has to be dealt with,
8 because candidly, as important as this case is, the rule of
9 law and a dishonest prosecutor are way more important to our
10 system of justice than anything else. And I respectfully
11 suggest serious repercussions need to be happen.
12 Now, I will also tell you, it probably doesn't
13 surprise you with this many pretty faces on this side of the
14 aisle, that other people want a chance to talk, so I'm going
15 to yield a little bit of my time, even though we don't have
16 particular time.
17 MR. ROSENBLUM: Good morning, your Honor.
18 THE COURT: Good morning. Identify yourself
19 for the record.
20 MR. ROSENBLUM: Scott Rosenblum on behalf of
21 E.G., Eric Greitens.
22 Your Honor, I have been practicing law for 35
23 years. I have been honored to represent individuals charged
24 with offenses both in federal court and in state court, and
25 for 35 years in this particular court.
 21

1 I have never in my practice accused a prosecutor

2 of incompetence or misconduct. I am doing that this
3 morning. Ms. Gardner is either guilty of gross incompetence
4 or perjury. There is no middle ground. She has either
5 suborned perjury tacitly or proactively, or both.
6 I sat through the deposition of Mr. Tisaby that
7 Mr. Martin conducted. I conducted the deposition of K.S.
8 for over nine hours without benefit of full discovery. I,
9 along with Ms. Nasser, and we are in the process, as this
10 Court knows, of conducting a deposition of P.S., again,
11 without full, relevant discovery.
12 It was Ms. Gardner that decided to choose this
13 individual, Mr. Tisaby, to investigate this case. I don't
14 think it should go unnoticed that, according to Mr. Tisaby,
15 her entire vetting process of this gentleman was
16 essentially, according to Tisaby, under oath, looking at the
17 website and potentially a phone call and a visit in a hotel
18 room.
19 Undisclosed at that time was the fact that this
20 gentleman had been convicted or charged or accused of
21 bigamy. That he had lied to the FBI, and specifically was
22 discharged because of that, although he disputed that under
23 oath, even when Mr. Martin showed him the FBI finding.
24 He was charged -- he was guilty of back child
25 support, which he tried to dispute. And he indicated that
 22

1 he was charging $250 an hour, and he had made at least five

2 trips, 14 hours round trip, which the State has paid for.
3 In addition, part of the vetting process was
4 showing Ms. Gardner his resume, which contained additional
5 lies about his involvement with Laclede Gas, that he
6 attempted to remove.
7 This is the man that she chose. This is the man
8 that she sat there and watched commit perjury to myself, to
9 Mr. Martin, to Ms. Nasser, in furtherance of this case.
10 Not only it is incumbent upon an officer of the
11 Court, but it's particularly incumbent upon a prosecuting
12 attorney that swears an oath to do justice, to not allow
13 perjury to be committed in her presence, and there is no
14 other conclusion than the exorable conclusion that we
15 witnessed.
16 It gets worse. It is more pernicious. Once
17 Tisaby had said to Mr. Martin, Ms. Nasser and myself, and
18 insisted that he conducted this two-hour interview without
19 benefit of any notes, all he did was ask a question, one
20 question or two, and she -- basically K.S. gave a narrative
21 that he committed to memory. But it wasn't just that he
22 misspoke.
23 When Mr. Martin drilled down on how preposterous
24 this is, and understand, we are not unfamiliar, the lawyers
25 in that room were not unfamiliar with FBI 302 statements.
 23

1 We were not unfamiliar with interviewing FBI agents in

2 proffers and otherwise.
3 Mr. Martin was a U.S. attorney and a federal
4 prosecutor for years. And I practiced in the federal court
5 for 35 years, and Ms. Nasser was a federal prosecutor for 12
6 years, we looked at each other in astoundment that this guy
7 was actually trying to convince us that he was able to do
8 that.
9 But he didn't just misspeak. He gave a back story
10 to support this lie. His back story was that he was known
11 around the channels of the U.S. attorneys for which he
12 worked, he was known for his ability to commit hours of
13 testimony to memory, which he somehow put in a 302 down the
14 road. Sometimes weeks, sometimes months.
15 That he was -- that he trained himself to do this,
16 unlike any other agent. But he was known to be different
17 than all the other agents the way he approached his 302s.
18 And I would invite you to look at the transcript, because
19 that's in there, because at the first opportunity the three
20 of us looked at each other and said is he really trying to
21 sell that to us?
22 This prosecutor sat there and listened to it, and
23 she knew that just wasn't true. She listened to it when he
24 said he asked no questions when the tape belies that. When
25 the tape shows that he asked numerous questions.
 24

1 She vetted him. She relied on a man that has no

2 credibility to conduct this investigation. She went around
3 the FBI. She went around the St. Louis Police Department
4 that may have checked his conduct because they would have
5 known this is not proper.
6 We are provided with this discovery before I had
7 the opportunity -- before I could review it and conduct a
8 deposition of K.S. And why is that critical? It's critical
9 for a number of reasons.
10 It shows how -- and I am not a conspiracy
11 theorist. But it shows how deep this conspiracy is. It
12 shows how deep it is when I questioned K.S. about the very
13 videotape that we're speaking about. And interestingly
14 enough, she supported the assertions made by Tisaby in her
15 deposition. She allowed that, yes, there was a videotape
16 present, just like the one that the videographer had in the
17 deposition, but she was told through her testimony that it
18 malfunctioned and there was no videotape that recorded this
19 interview.
20 But what was particularly interesting is when she
21 was questioned about whether or not Tisaby made notes, her
22 memory seemed to lapse. At best, she could be uncertain.
23 When she was questioned about the nature of the interview,
24 particularly whether or not it was an interview that was
25 more a narrative, as Tisaby described, or whether or not
 25

1 there was actual questioning to elicit her story, and that's

2 all this is, she said oh, no, it was just -- to be frank, it
3 was more just a narrative. I can't say. He asked a number
4 of questions.
5 When I continued to question her about that,
6 finally she allowed, well, he interjected a question here or
7 there.
8 Had I had that tape, obviously, we could have
9 impeached her. I was working off a report that Tisaby made
10 that Mr. Martin has shown you how defective that report is.
11 And at times when I questioned her specifically about the
12 report, she disputed what Tisaby had to say on very critical
13 issues.
14 Tisaby, in his deposition, stated unequivocally
15 that on the morning of the 21st, K.S. undressed in the
16 presence of E.G. She voluntarily removed her clothes and
17 she was nude in his presence. She disputed that. She said
18 I did not say that to Tisaby. I could not have the video to
19 follow-up.
20 She disputed whether or not -- I questioned her
21 about this preposterous contention that Mr. Martin referred
22 to about that she still believed they were going to enjoy a
23 conversation as she was engaging in sexual activity in the
24 basement of which she allowed that she was turned on and
25 excited. Which is not anywhere in this report.
 26

1 All of this information was not provided to us, it

2 was purposely withheld. It completely changed the tenor and
3 the scope of the inquiry of K.S. And it gets worse.
4 It goes from there to the current deposition we're
5 in of P.S. And we had -- we did not have the benefit of the
6 House report. And suffice it to say that everything that's
7 been disclosed in depositions completely rebut and disputes
8 the conclusions of this House Committee report. Not the
9 least of which allude that there was anything, any act that
10 was nonconsensual. Any act.
11 Because it is devoid of that in the deposition
12 process and the discovery process for which we have had
13 up-to-date and it's just augmented now by this late
14 disclosure of the video.
15 It's particularly relevant when we're talking
16 about P.S. P.S. was questioned yesterday under oath whether
17 he shopped his story at all. Under oath he denied it. And
18 yet we have a video where K.S. said that is just not a fact.
19 I couldn't confront him with that because it had not been
20 provided.
21 Yesterday under oath he talked -- he denied that
22 he had received income from any source, monetary payment
23 from any source. He denied that. The House Committee shows
24 that that's just not a fact.
25 Your Honor, in 35 years, I have never made an
 27

1 allegation against not only a prosecutor sworn to uphold

2 justice, but the sitting prosecutor of this district, that
3 not only was her behavior grossly, grossly incompetent,
4 under any stretch, but she suborned perjury in my presence,
5 tacitly and proactively, when she took it upon herself to
6 conduct approximately 20 minutes of some attempted
7 rehabilitation of Mr. Tisaby and specifically inquired about
8 the notes, asked the question, where he answered by saying,
9 yes, I turned over everything to you.
10 That is the classic definition of suborning
11 perjury. That is sanctionable. That is criminal.
12 Mr. Martin asked for the opportunity to redepose. Clearly
13 we're entitled to that. I think we're entitled to more.
14 We need to figure out -- to get to the bottom of
15 this video issue by the chain of custody, including the
16 deposition of Ms. Gardner.
17 And, in addition, I think with this record that we
18 can support every word, the Court should revisit our motion
19 to dismiss this prosecution, dismiss this indictment, and
20 we're asking the Court to consider that as well. Thank you.
21 THE COURT: All right. From the State, at
22 this point, all I want to hear is about the chain of this
23 video projector and the videotape. I want to know how it
24 was first determined that it was malfunctioned, when it was
25 determined that it no longer malfunctioned.
 28

1 I'm not going to hear anything from the State at

2 this time -- we're going to recess from the State and have a
3 discussion in chambers with regard to the severe allegations
4 of criminal perjury and a dishonest prosecutor. Those are
5 some very, very severe allegations that I feel incumbent to
6 make a record to make sure anything that's put on the record
7 at this point from the State has been -- that the State has
8 had the opportunity to consider those allegations.
9 But I do want to hear from the State, whoever has
10 the most information, what the process was on this
11 projector, when it was first asked for, when the request was
12 responded to that it was inoperable and there wasn't any
13 tape, when it was that it was determined that the tape was
14 operable, and when it was actually disclosed to the
15 defendant. Who best can address that?
16 MS. GARDNER: Me, your Honor. Your Honor,
17 the tape was basically set up in the hotel room. When we
18 were under the impression that it was recording, we thought
19 it worked. No one touched the tape. No one did anything
20 until after the interview was over.
21 THE COURT: Whose recorder was it?
22 MS. GARDNER: It was the circuit attorney's
23 recorder, your Honor.
24 THE COURT: Recorder that the circuit
25 attorney routinely uses?
 29

1 MS. GARDNER: Well, I don't know because we

2 just got a tape, one of our recordings that we have in our
3 investigation unit. So I don't know if that's the one we
4 use normally because I don't record normally.
5 THE COURT: Who was in charge of the
6 recording?
7 MS. GARDNER: It was set up by myself, and we
8 put a -- we did all the setup. Mr. Tisaby, we checked the
9 tape at the time. It was working. If you look at the tape,
10 at the whole time we're sitting down, we're not touching the
11 tape, no one's following the tape, it's just us sitting at a
12 table with K.S. and her attorney. No one gets up to check
13 the tape at all during this test -- during this interview.
14 At the end of the interview, me and Mr. Tisaby
15 went to the tape to see if it was -- it recorded. It would
16 go on and cut off. It kept doing that. We could not get it
17 to work. And numerous times many different people
18 attempted. It would come on and go on.
19 So in the attempt, when we got this, to make sure
20 I was turning over everything, I thought the tape only had a
21 coming on and going off. So I gave it to the IT department
22 to make sure, and that was Monday.
23 THE COURT: Of this week?
24 MS. GARDNER: Of this week. I never saw the
25 tape myself because we were under the impression it never
 30

1 recorded. I even told the defense, the defense attorney, it

2 never recorded. I never even saw the tape until this week.
3 I've never even heard what was on the tape until this week.
4 So I asked him, I said, make sure you -- if it
5 comes on and goes off, I want to turn that over to the
6 defense, and the IT person can tell you he found that it
7 worked. It did not work for me. It did not work for other
8 people. He got it off. I did not touch or get anything
9 off.
10 THE COURT: When?
11 MS. GARDNER: The tape recorder, and that was
12 it.
13 THE COURT: When?
14 MS. GARDNER: That was Monday.
15 THE COURT: Your office knew on Monday you
16 had an operable tape?
17 MS. GARDNER: Yes, sir.
18 THE COURT: Your office knew on Monday that
19 there was active depositions going on?
20 MS. GARDNER: Sir, I didn't even look at the
21 tape. First I wanted to make sure to make sure I got
22 everything. I didn't have a chance to look and see what was
23 on the tape.
24 THE COURT: We're going to stop at this
25 point. We're going to need to make a record in chambers.
 31

1 (The proceedings held in chambers were

2 confidential and are contained in a separate transcript not
3 to be released without Court Order.)
4
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 32

1 (The following proceedings were had in open

2 court:)
3 THE COURT: Court will be back in session,
4 please be seated. We're back on the record in Cause Number
5 1822-CR00642.
6 For the State, response to the defense.
7 MR. STEELE: Yes, your Honor. There's been a
8 number of allegations made about Mr. Tisaby, Mr. Tisaby's
9 notes, the video, Ms. Gardner's notes.
10 One thing that has been absent from all these
11 allegations, there's not one ounce of anything in Mr.
12 Tisaby's notes, Ms. Gardner's notes, or the video, which is
13 exculpatory to Mr. Greitens. There's nothing in there.
14 Now, if the Court will recall all these
15 allegations, we keep focusing on we didn't get the notes,
16 what's in the notes, is there anything exculpatory in the
17 notes? No. Mr. Tisaby's notes, is there anything
18 exculpatory? No. Ms. Gardner's notes, anything
19 exculpatory? No. The video? No. There's nothing
20 exculpatory in any of that. No. They have it.
21 On the issue of whether the tape malfunctioned.
22 If the Court has an opportunity to review it, you'll see the
23 initial, somewhere between 15 and 20 minutes, there is no
24 audio. In terms of what is meant by malfunctioning, you see
25 movement but there is no audio. Granted someone should have
 33

1 looked at the end of the tape and saw later on there's

2 audio.
3 But in terms of what is meant by the tape not
4 working properly or malfunctioning, that's what it is,
5 there's no audio. And so that information was given to them
6 and they had that opportunity.
7 Now, in terms of the complaint, the indictment,
8 K.S.'s allegations and charges, they are the same. There's
9 nothing in the notes which would in any way disprove what's
10 in the indictment. K.S.'s photo was taken. It was taken
11 without her consent or knowledge. It was taken while she
12 was partially nude. It was taken in the place where she has
13 an expectation of privacy and transmitted. There's nothing
14 in the notes to dispute that.
15 So if they had the notes it would have changed
16 nothing, because there's nothing in the notes. The whole
17 proceedings have been focusing on what would that have
18 changed. Would it have changed the indictment, would it
19 have changed the nine-hour deposition by Mr. Rosenblum? No.
20 Because she's told the same account every time.
21 The account she told the Circuit Attorney's
22 Office, she told the same thing in the deposition. Nine
23 hours. We didn't have nine hours with her. Mr. Rosenblum
24 and his associates had nine hours. She told the same
25 account. She's told the same account to the committee.
 34

1 So there's nothing in the notes that would have

2 changed the account she gave the circuit attorney. There's
3 nothing in the notes that would have changed the account she
4 gave the committee, and there's nothing in the notes that
5 would have changed the account that she gave to the defense
6 counsel.
7 So all these allegations and these inferences they
8 keep trying to make that it would have changed something, it
9 would have changed nothing. Because there's nothing in the
10 notes.
11 Now, they focus on also the details and say she
12 did not disclose. I'm sure the Court is aware and they are
13 aware, she was asked questions. She gave answers to those
14 questions. Now, she did not disclose how she may have been
15 sexually -- or to what detail she may have been sexually or
16 physically aroused at some point because it was not relevant
17 to the elements of the charge. It was not relevant to what
18 transpired on March the 21st.
19 So all this talk about what she did not disclose,
20 these details, have nothing to do with the elements of the
21 cases.
22 The elements of the case stay the same. Her
23 accounts stay the same. They were the same she gave to the
24 circuit attorney, the same to the committee, the same to
25 Mr. Rosenblum. The same accounts. There's nothing in the
 35

1 notes.
2 This case should not be dismissed. Her testimony
3 will remain the same. He is guilty. What did they cite?
4 Allegations by Mr. Martin, allegations by Mr. Rosenblum.
5 Did she say in those notes anywhere did he not take my
6 picture? Did she say anywhere in those notes that I was not
7 partially nude? Did she say anywhere in those notes she did
8 not have an expectation of privacy? Did she say anywhere in
9 those notes that it was not transmitted?
10 There's nothing in the notes that disputes any
11 element of the charge. Nothing. Zero. The case should not
12 be dismissed. It should go forward because Mr. Greitens is
13 guilty.
14 There's nothing in the notes that prove anything
15 otherwise. If they had anything in those note he could have
16 cited the notes. Where in the notes? Where in Ms.
17 Gardner's notes does she say that --
18 MR. MARTIN: I'm happy to address that.
19 MR. STEELE: Well, you'll get your
20 opportunity.
21 MR. MARTIN: You were looking at me, I
22 thought you were asking.
23 MR. STEELE: I'm not asking. I'm talking.
24 Just like you looked at us. You make all these allegations
25 in court about what's in the notes. What element did it
 36

1 change? What fact did it change? Nothing. Nothing.

2 Now, the whole focus has been, at least most of
3 the focus is on Mr. Tisaby. And when he was deposed, I was
4 not there, but I had an opportunity to read some of it. He
5 told them that he did the interview to assess her
6 credibility. He is not endorsed as a witness.
7 The only thing he did was an interview to see if
8 she gave a credible account. She gave the Circuit
9 Attorney's Office an account. He was there to make a
10 decision whether that account was credible. The same
11 account she gave to the committee, which the committee said
12 was credible. So we hear the same thing. He assessed
13 whether that account was credible.
14 There's also some allegations of information that
15 they did not have prior to, I guess, the committee. That it
16 would have somehow changed something. The deposition of
17 K.S., the Court granted a lot of latitude, there were a
18 number of questions asked, in the defense's opinion, would
19 have possibly brought some evidence.
20 A lot of that got into issues such as her physical
21 reaction or sexual reaction to certain activity. Some of
22 these activities months away from the incident. The
23 incident is March 21st. Some of the actions that they're
24 talking about like the FaceTime. That she FaceTimed him.
25 This is four or five months later. This has
 37

1 nothing to do with the allegations that transpired on

2 March 21st. The fact that she FaceTimed him three or four
3 months later has nothing to do with that.
4 They can argue that to a jury that that somehow
5 means that four months earlier, even though she said there
6 was not consensual, it may have been. It's somehow
7 relevant. The issue is what happened on March 21st of 2015
8 in that basement. Whether she FaceTimed him four months
9 later --
10 THE COURT: You don't think that has anything
11 to do with whether or not the March 21st incident was
12 consensual, the fact that there was Facebooking three or
13 four months later?
14 MR. STEELE: I think they can present that to
15 a jury and the jury can make that decision.
16 THE COURT: Do you think that's relevant?
17 MR. STEELE: I think it's relevant, yes.
18 THE COURT: That's the point, Mr. Steele.
19 MR. STEELE: And this is the point, your
20 Honor. They had that information last week. Because she
21 was deposed on that. So to say that they did not.
22 THE COURT: The point's compounded by Brady,
23 and it seems that your argument is that the State decides
24 before it turns anything over what's relevant. Is that how
25 you read Brady?
 38

1 MR. STEELE: No, your Honor.

2 THE COURT: And the State, you've also made
3 the argument that the State decides before it turns anything
4 over what is or isn't exculpatory. Is that what Brady says?
5 MR. STEELE: No, your Honor. And I'm trying
6 to be as clear as possible.
7 THE COURT: Yes, sir.
8 MR. STEELE: In terms of when this tape, this
9 video -- the deposition was Friday, last week. At some
10 point this week, it became evident that the latter part of
11 the tape is audible, and so in terms of whether this tape
12 was turned over prior to the deposition, that's information
13 they had prior to the tape, and that's what I'm saying.
14 Whatever degree that information on that tape may
15 have been Brady or something, which I don't believe it is,
16 but that information on that tape they already had before
17 Friday. Last week. And so that information is not
18 something new, it is not something that would change
19 anything. They already had that information.
20 So, in terms of what is in those notes, again, I
21 think has been clear that the focus is on we didn't have the
22 notes, and the only thing I'm asking is we focus on the
23 substance and the contents of the notes. What is in the
24 notes that is material. What is in the notes that is
25 exculpatory. And that's all I'm asking that we focus not on
 39

1 we didn't get the notes, but what is in these notes.

2 The other issues, again, are issues of fact for a
3 jury to make a determination on, but again, I just ask the
4 Court to focus on the substance and contents of the actual
5 notes and not simply the allegation that they did not get
6 the notes prior to some point. Because I believe the
7 information, whatever's in those notes, was obtained prior
8 to them getting the video and the notes.
9 There's nothing in the notes that is exculpatory,
10 and whatever information was already gathered through the
11 nine-hour deposition of K.S.
12 THE COURT: All right. Thank you, Mr.
13 Steele. Anyone else?
14 MS. GARDNER: Your Honor, just to even
15 clarify. The tape did not work. It was not --
16 THE COURT: Ms. Gardner, I'm going to make
17 sure that you understand on the record that I am going to
18 take everything that is said here as a sworn statement. Do
19 you understand that?
20 MS. GARDNER: Yes, sir.
21 THE COURT: You may proceed.
22 MS. GARDNER: The tape did not work, your
23 Honor. Why would I turn over something that I'm trying to
24 commit any kind of crime? I turned it over myself. That
25 was my duty, and I did it.
 40

1 Once we were able to get something off of a tape

2 that did not work. So why would I turn that over? And
3 since we want to make allegations about me saying I'm
4 incompetent.
5 I'm going to tell you this, your Honor, as an
6 officer of the Court, I'm going to report that the defense
7 over here, Mr. Ed Dowd, called the actual attorney for K.S.,
8 and asked them not to say there was no photo.
9 But see, I didn't bring that out because the
10 attorney asked me not to do that. Since they're making an
11 allegation against me, I'm going to make an allegation
12 against them. Because that's very important in this case
13 when we talk about unethical behavior, call a victim's
14 attorney and ask them to say there's no photo, would they be
15 willing to make a statement, to ask him to come down to my
16 office to talk to one of us to say that nothing happened.
17 They didn't tell you that part of the story, did
18 they? I'm going to tell you that as an officer of the Court
19 that I did something. I didn't do anything unethical. When
20 I know what was going on, I turned it over.
21 THE COURT: Anything further from the State?
22 MS. GARDNER: No, your Honor.
23 THE COURT: Any response?
24 MR. MARTIN: Yeah, there's a response, your
25 Honor. First of all, the last statements by Ms. Gardner, if
 41

1 she has evidence, let her bring it out. Don't just sort of
2 throw it out.
3 THE COURT: Here's the deal. You don't
4 diminish the speck that's in one's eye by pointing out the
5 speck in the other.
6 MR. MARTIN: So, I want to know, first of
7 all, that we now have two different versions of what was
8 wrong with the tape.
9 Ms. Gardner told you before the break that it was
10 starting and stopping. Mr. Steele said the only problem was
11 it had some minutes at the start of nonaudio. Judge, it's a
12 two-hour tape. The one we've been given, there are 10
13 minutes that the audio is missing. We don't know why the
14 audio is missing, but there's 10 minutes missing.
15 Nobody could have looked at that tape and said,
16 oh, it malfunctioned, it was running the picture, and within
17 10 minutes all the audio is there. You have two different
18 stories now from two different prosecutors as to what was
19 even wrong with the tape.
20 But the tape is only a small portion of the story.
21 While the evidence within the tape is huge, the hiding of
22 evidence, the notes of Mr. Tisaby testifying under oath, and
23 nobody seemed to defend his perjury. His testimony under
24 oath that he took no notes, that he never takes notes, when
25 Ms. Gardner was sitting there as she has now represented in
 42

1 the Court. She was sitting right next to him. And he

2 was -- you can see in the video, you can see in the pictures
3 he's writing the notes out.
4 And she allowed him to testify he never took any
5 notes. That's what we're talking about. And then when we
6 talk about there's no exculpatory information within these.
7 Apparently, Mr. Steele, with all due respect, was not
8 listening to anything I had to say.
9 She is laughing with her lawyer when she is
10 discussing things that she's claiming she didn't want to
11 participate in. She has admitted in this interview that we
12 just got last night that she was telling them she had told
13 her friends everything, and then when the friends are asked
14 by K.S., don't you remember that I told you about the slap?
15 They say, no, we don't remember your telling us that.
16 That's huge to her credibility. Huge to her
17 credibility that is being made a mountain out of in the
18 press right now, that had that information been with us
19 beforehand, this House Committee report might have looked
20 entirely different, and the taint that this has thrown all
21 over this case would be entirely different.
22 She lied in this video, and every time she lies in
23 this video that goes to her credibility. Every time she
24 leaves something out, that goes to her credibility. And
25 when Mr. Steele says that's not exculpatory, as a former
 43

1 public defender for 20 years, I guarantee he would have

2 found it exculpatory if he was sitting at our table.
3 She said, one of the -- the second meeting they
4 had just a few weeks later in the salon, she described as a
5 little bit of kissing. In her deposition she described it
6 as way more than that. She's telling different stories,
7 that goes to her credibility.
8 The FaceTime incident. The FaceTime incident.
9 This entire case is about was a photograph taken, if it was
10 taken was it consensual. And if it was consensual, was it
11 of somebody partially naked.
12 She lied in her interview of January 29 about that
13 FaceTime incident. She made it sound as if it was
14 innocuous, and she cut it off. When we got her to admit in
15 the deposition that she was partially naked, and what that
16 says is that she was willing to have photographs of herself
17 partially naked being sent over the Internet to our client.
18 That's huge. And she didn't tell the truth about
19 that in this January taped interview that we just got last
20 night.
21 The information that she was shopping the story,
22 that her husband was shopping the story. And combine that
23 with the fact that he was paid, that's exceedingly
24 exculpatory information. We still need to explore who else
25 was being paid.
 44

1 The notes, did the notes contain exculpatory

2 information? Ms. Gardner's notes from January 24th, when
3 she was the only witness to the interview, say that the
4 claim of K.S. was that she took off all her clothes, put on
5 some other clothes, willingly went down to the basement,
6 willingly let herself supposedly be tied to these rings.
7 And she, quote, still thought they were there just
8 to talk. That's what Ms. Gardner's notes say. That is
9 exceedingly exculpatory because it's exceedingly
10 unbelievable. Without trying to harm this witness any more
11 than she has, having been dragged through this by the
12 circuit attorneys to begin with, this was a consensual
13 relationship, and she went down there thinking, claiming she
14 was just going to be talk, saying she was being turned on,
15 that doesn't make Tisaby's report, that doesn't make
16 Tisaby's deposition.
17 The amount of exculpatory information, when you
18 look at the notes and you look at the video and you compare
19 it to what has been said elsewhere, is extraordinary.
20 One of the most incredible things that, in all
21 candor, we think destroys this woman's credibility, and
22 again, I'm going to say on the record, real victims deserve
23 every protection in the world. This isn't a victim. She's
24 a consenting person to everything that went on.
25 And the best evidence of the consent was what
 45

1 P.S., her ex-husband, said just in the last couple of days

2 in his deposition under oath, that while the first she said
3 when she went back to get the keys, nothing happened. She
4 later on admitted to him that there was explicit sexual
5 activity going on just a few hours after the events in the
6 basement. That's never mentioned elsewhere.
7 And the failure to talk about something like that,
8 and, in fact, in the Grand Jury, and I believe in the video,
9 and I want to be careful on that, I'm not totally sure of
10 that, I believe in both, she made that second visit much
11 more innocuous. I know she made it much more innocuous in
12 both of them, I'm just not sure of the specific details.
13 But she made testimony in her deposition that
14 there was explicit sexual activity going on, totally
15 voluntary. Her inability to tell the same story, totally
16 contrary to what Mr. Steele is saying that she's telling the
17 same story every time, is hugely exculpatory.
18 But let's not move away from the fact that we are
19 also here because the private investigator hired by Ms.
20 Gardner, personally selected by Ms. Gardner, the contract
21 signed by Ms. Gardner. Ms. Gardner -- apparently there's a
22 big debate. She says she went to the police department,
23 asked for their cooperation. They said no, the police
24 department says that's preposterous.
25 That investigator sat there and lied at least five
 46

1 times. Lied about whether he looked at his laptop at

2 lunchtime. Lied about whether he had taken any notes. Lied
3 about whether he asked questions. Lied about whether he
4 reviewed other things before he wrote his report. Lied
5 about whether he ever saw the notes of Ms. Gardner. Lied
6 about whether he ever looked at the transcripts of the taped
7 interviews that the husband had taken.
8 And Ms. Gardner sat there right there, right next
9 to him, as she even testified in the interview of
10 January 29th, and she sat there right next to him in the
11 deposition. And even went so far as to ask the question, as
12 both Mr. Rosenblum and I have quoted to you, you turned over
13 all the notes? Yes.
14 When she knew he had 11 pages of other notes, and
15 when she knew she had other notes of her own that didn't get
16 turned over until last night.
17 There are huge problems. It is gross
18 prosecutorial misconduct, and it goes to the heart of this
19 case. And we are asking this Court to dismiss this case as
20 a sanction against the circuit attorney for gross
21 prosecutorial misconduct.
22 THE COURT: From the State.
23 MR. DIERKER: Your Honor, I'd like to make
24 just a couple of observations. Accusations of perjury are
25 serious, but we both know that the crime of perjury is a
 47

1 rather intricate offense, and I think that this whole

2 situation has developed because Ms. Gardner has done her
3 duty.
4 She did disclose the materials because she kept
5 after Mr. Tisaby, and she kept after the issue of getting
6 this video to get produced. So she has turned over the
7 materials. The notes that are referred to have handwritten
8 notes and bullet point, typewritten, and those were prepared
9 by Mr. Tisaby. Ms. Gardner had turned over her handwritten
10 notes previously.
11 And I would say lastly that the issue in this
12 situation to me seems to be one of prejudice at trial, and
13 the defense certainly has more than enough material to work
14 with thanks to Ms. Gardner producing what needed to be
15 produced, so that they have suffered no prejudice as far as
16 trial preparation is concerned.
17 So I would submit that the drastic remedy of
18 dismissal is not appropriate.
19 THE COURT: Chief Dierker, and you may not
20 have the information, and it was determined Monday afternoon
21 that that tape was operable, and we were having depositions
22 taken right in this courthouse, why was it until Wednesday
23 evening that that was -- why wasn't it not immediately
24 turned over?
25 MR. DIERKER: I confess I can't answer that,
 48

1 your Honor.
2 THE COURT: All right. Anything further?
3 MR. BENNETT: Your Honor, we're looking for a
4 little bit of guidance on what we understand to be the gag
5 order still in place.
6 THE COURT: Let me seal this part of the
7 hearing off. Anything further on this motion?
8 MR. MARTIN: No, your Honor.
9 THE COURT: Mr. Bennett.
10 MR. BENNETT: Sure. We wanted to get a
11 little bit of guidance on the interplay between the house
12 report and your gag, for lack of a better term, the order
13 that you entered restricting public comment, and to make
14 sure that in the context of responding to what is a related
15 perhaps, but independent action going on there in Jefferson
16 City that the governor's First Amendment rights to respond
17 to the House report would not run afoul of your order and to
18 try to understand the extent to which at all it would be
19 appropriate to comment on variations of the evidence and the
20 things that have been introduced.
21 So I think we're not -- we're looking for help on
22 that, in that regard, from the Court, so that we don't run
23 afoul on behalf of our client on a court order while he
24 attempts to respond to what's going on in Jefferson City.
25 THE COURT: Well, obviously the drop of all
 49

1 that material that was received without cross-examination,

2 without the scrutiny of the evidence that normally exists at
3 a judicial proceeding, has made the gag order tough to
4 defend and tough to clarify.
5 Chief, do you have any comments? It was the
6 State's motion and, ironically, a different branch of the
7 State chose to dump a lot of information that has not gone
8 through the normal rigorous structure that evidence in court
9 does.
10 MR. DIERKER: I think, your Honor, the State
11 acknowledges the right of the governor to respond to the
12 House Committee report. Our concern has been and continues
13 to be with the pending criminal prosecution and the
14 dissemination of materials that were acquired in the course
15 of that prosecution.
16 I don't think that we would have -- I don't think
17 we would see any violation in the Court's order for the
18 governor to respond to what the House Committee has done.
19 THE COURT: Yeah, I think the defendant and
20 the governor being the same have certain constitutional
21 rights. Any defendant can stand on the front of the
22 courthouse and scream their innocence. The gag order was
23 driven mostly by counsel and the back and forth, even
24 counsel for -- that aren't actually counsel of this case,
25 but represent witnesses.
 50

1 So, my feeling is that it would be hard to enforce

2 a gag order against the governor for asserting his
3 constitutional rights of innocence himself. I want the
4 attorneys to consider and follow the gag order themselves,
5 but I think he has a right constitutionally to address
6 what's asserted against him out of the legislative branch,
7 and I have no control over that what they do.
8 MR. BENNETT: Thank you, your Honor.
9 MR. ROSENBLUM: One more issue, your Honor.
10 As the Court's aware, Ms. Nasser and myself are scheduled to
11 resume the deposition of P.S. at 1:30 this afternoon. At
12 the time it concluded yesterday, which comprised a half day
13 on Monday and a half day on Wednesday, we ended it subject
14 to an agreement that the only issues that were going to be
15 explored at that time were questions I had certified that
16 Mr. Watkins, P.S.'s attorney, had objected to and instructed
17 him not to answer.
18 Specifically, questions aimed at any remuneration
19 of any kind he has received during the course of the case.
20 Whether it was going to him directly or going to his
21 attorney.
22 Since that time, we have been provided the
23 videotape, which raises different issues, not the least of
24 which is whether or not P.S. was shopping this story, which
25 he had denied under oath. In addition, we received
 51

1 information about actually receiving payments that he has

2 essentially refused to answer up until this point, or denied
3 it, and other issues have come to light, such as under oath
4 he has actually stated in detail in answering questions of
5 the House, in explicit detail, not the least of which is
6 identifying e-mails with bogus names that he caused to be
7 sent to K.S., when in deposition did he either say he had
8 actually no knowledge or no in responding to those
9 questions.
10 So I'd like to have a -- with the Court's
11 deference, certainly the circuit attorney can respond,
12 attorney-client issues with respect to whether or not we can
13 delve into that area, the source of payments, or I believe
14 Mr. Watkins is on his way down here at 11 o'clock, and we
15 want to explore that issue or those issues, as well as the
16 issues I just spoke of.
17 MR. BENNETT: The only clarification, I think
18 he said he admitted to sending e-mails to Mrs. Greitens.
19 MR. ROSENBLUM: Correct.
20 MR. BENNETT: You said K.S. He's admitted
21 sending e-mails to Mrs. Greitens and then he denied it under
22 oath.
23 MR. ROSENBLUM: Denied it or had no
24 knowledge.
25 THE COURT: Obviously, any constriction of
 52

1 your ability to depose this witness would create the

2 prejudice that the late tender of that tape would create
3 exactly the prejudice that the late tender of that tape
4 caused, so I don't think that I'm going to restrict that
5 whatsoever because in doing so I would create a prejudice
6 that -- by limiting your examination now in light of this
7 tape.
8 MR. ROSENBLUM: Thank you, your Honor.
9 THE COURT: If that gives you guidance.
10 Okay. Anything further?
11 MR. STEELE: I would just like to, since
12 we're on the record, correct a misstatement that P.S. denied
13 sending an e-mail. He did not deny that. He was under oath
14 during the deposition.
15 He indicated that he did, in fact, send an e-mail.
16 There were a number of e-mails. He did not make a complete
17 denial that he never sent any e-mails. He acknowledged that
18 he sent an e-mail to K.S.
19 MR. ROSENBLUM: Well, that's just an
20 inaccurate statement, your Honor. The only e-mail that he
21 acknowledged was an issue that Mr. Watkins turned over on
22 Monday pursuant to a subpoena duces tecum, again, with a
23 bogus name.
24 There was a different e-mail that he acknowledged
25 under oath to the House Committee with yet a different bogus
 53

1 name that he has, as recently as yesterday, denied any

2 knowledge of that particular bogus name and had no knowledge
3 of that particular e-mail, even when directed to the
4 contents on the record, on video, by his attorney,
5 Mr. Watkins.
6 THE COURT: All right. Anything further?
7 All right. We're going to close the record, and I'll need a
8 memo. Thank you, all.
9 (The following proceedings were had in open
10 court:)
11 THE COURT: We're back on the record in Cause
12 Number 1822-CR00642. Yes, sir.
13 MR. ROSENBLUM: Your Honor.
14 THE COURT: Yes, sir.
15 MR. ROSENBLUM: The draft of yesterday's
16 deposition does not -- I don't think has the certified
17 questions, so if the Court would indulge me, I would ask for
18 assistance from the court reporter who was present.
19 THE COURT: You would ask for what?
20 MR. ROSENBLUM: Assistance from the court
21 reporter who was present.
22 THE COURT: Sure.
23 MR. ROSENBLUM: The first issue I want to
24 talk about, there was a number of certified questions with
25 respect to questions propounded to P.S. about source of
 54

1 fees.
2 THE COURT: Source of fees?
3 MR. ROSENBLUM: Source of fees, or source of
4 payment, or source of remuneration. Michelle has all the
5 case law which purports that is not under the purview of
6 privilege or privileged information.
7 THE COURT: Okay. Source of fees to the
8 attorney?
9 MR. ROSENBLUM: Any payments, any form of
10 remuneration that P.S. has received, or his attorney has
11 received on his behalf. There's a specific series of
12 questions about a --
13 THE COURT: All right. So there was
14 objection to that and an instruction not to answer?
15 MR. ROSENBLUM: Correct.
16 THE COURT: Let me --
17 MR. WATKINS: I did, your Honor, I made the
18 objection.
19 THE COURT: All right. So tell me why a
20 source of fee does not fall within the interest or bias that
21 can be probed on cross-examination?
22 MR. WATKINS: Your Honor, two or three
23 things. One is the certified questions were not certified
24 properly.
25 THE COURT: I'm not caught up on that.
 55

1 MR. WATKINS: All right. That's one, and

2 that's for the record. Second thing is the way the
3 questions were propounded clearly sought to elicit
4 information which was well within the attorney-client
5 privilege.
6 If counsel for the governor had asked the question
7 as he did on a number of occasions, what do you know that
8 hasn't otherwise been told to you by your attorney. He can
9 ask that information. Ask for that information. He did.
10 My client said I don't know.
11 THE COURT: What was the question that was
12 instructed not to answer?
13 MR. ROSENBLUM: Well, there's a series of
14 them, your Honor, and I can refer you to them. Just give me
15 a moment. Okay.
16 THE COURT: Mr. Rosenblum, I'm going to give
17 you a minute here. I'm going to ask, Mr. Steele, there's
18 been a request to see the photograph that was presented in
19 the motion this morning.
20 Does the State have any position on that?
21 MR. STEELE: Can I see?
22 THE COURT: Yes.
23 MR. STEELE: I'd like an opportunity to
24 review the actual video. I know there seems to be a time at
25 the bottom or somewhere on the picture, I know there was
 56

1 some references to she may have been laughing about the

2 question or something, and I haven't viewed the video
3 myself, so I don't know if that portion of the tape where
4 that picture's taken -- if there's some audio or what was
5 the question being propounded when she started to laugh.
6 So I'd like some opportunity to see if it's audio
7 at that point.
8 MR. ROSENBLUM: I'm ready.
9 THE COURT: We'll get back to that,
10 Mr. Rosenblum.
11 MR. ROSENBLUM: Okay. So, the first issue
12 that came up, there was a question, the first question was
13 is somebody paying your legal fees other than you?
14 "ANSWER: No, I pay my legal fees.
15 "QUESTION: Is somebody supplying you the
16 money to pay your legal fees?"
17 "MR. WATKINS: Objection to the extent that
18 it seeks to invade the purview of attorney-client privilege,
19 to the extent that you know something, he asked the question
20 that does not do that. You can answer, but right now I'm
21 instructing you not to answer the question."
22 Then I --
23 THE COURT: Let's stop there. Someone
24 supplying you the money to pay your attorney.
25 MR. WATKINS: And my position, your Honor, is
 57

1 that that question can be asked or propounded on my client.

2 And to the extent that he knows an answer, that is not a
3 function of attorney-client.
4 THE COURT: But you told him not to answer
5 before he got to that point, Mr. Watkins.
6 MR. WATKINS: I waited until the question was
7 asked.
8 THE COURT: But he never got to answer what
9 was within his knowledge or purview because you instructed
10 him not to answer.
11 MR. WATKINS: But that wasn't the way the
12 question was asked. It's not my duty and obligation in a
13 deposition to instruct counsel for the defendant how to ask
14 the questions. So what -- and, by the way, I've been
15 working with Scott and trying to streamline things. So when
16 Scott picked up on that and said, oh, okay, to the extent
17 that you don't know, you know something that wasn't told to
18 you by your attorney, what do you know. And the question
19 was answered. There was no objection to that.
20 There is no desire to have anything here protected
21 except communication between an attorney and a client. All
22 other information, it's fine. He can probe into it, but
23 information that relates directly or derived solely from
24 attorney-client communication, I have a duty to protect
25 that.
 58

1 MR. ROSENBLUM: The problem with Mr. Watkins'

2 analysis is it's wrong, and the question was asked the way I
3 wanted to ask the question. He instructed the witness not
4 to answer and legally source of funds is not protected by
5 the attorney-client privilege, and I can supply the Court
6 with a number of cases that stands for that proposition.
7 MR. WATKINS: What we agree that's not --
8 we're not in disagreement with that, your Honor. The fact
9 of the matter is I don't have the benefit of a rough draft
10 of the transcript, otherwise I would show you the other
11 questions where he asked the questions and propounded them
12 properly.
13 THE COURT: What's the question,
14 Mr. Rosenblum, that you want to ask that the witness was
15 instructed not to answer?
16 MR. ROSENBLUM: Well, there's a number of
17 them.
18 "QUESTION: Is somebody supplying you the
19 money to pay your legal fees?" That was the question.
20 He was instructed not to answer.
21 THE COURT: That will be allowed to be
22 answered.
23 MR. ROSENBLUM: Thank you. Next question.
24 Have you -- are you aware of any entity, any
25 source on your behalf paying your legal fees?
 59

1 MR. WATKINS: Objection. Seeks to elicit

2 information.
3 That falls squarely --
4 THE COURT: All right. So that's the exact
5 same question, Mr. Watkins, you said he should be phrasing
6 it to his knowledge. So that question's allowed.
7 MR. WATKINS: Yeah, I have no problem if it's
8 limited to the knowledge, not --
9 THE COURT: That's how he was phrasing it.
10 It sounds like you instructed him not to answer.
11 MR. WATKINS: If I did, your Honor, I
12 apologize.
13 THE COURT: All right. So that's fair.
14 MR. ROSENBLUM: Have you received any benefit
15 with respect to your involvement in this case? Mr. Watkins
16 instructed him not to answer.
17 MR. WATKINS: Same thing. To the extent, not
18 a function of a communication with counsel, it's fine for
19 the answer.
20 THE COURT: He'll be allowed to answer that.
21 MR. ROSENBLUM: "QUESTION: Have you
22 sought -- have you sought any -- at any point to shop your
23 story for any financial remuneration?
24 "ANSWER: No."
25 A book deal, a movie deal, or any other deal
 60

1 that you would gain some financial remuneration?

2 Mr. Watkins objected under the attorney-client privilege and
3 instructed him not to answer.
4 MR. WATKINS: Again, the same thing, your
5 Honor, to the extent that any information may have been
6 procured by my client from me, aside from that he can answer
7 those questions.
8 THE COURT: He'll be able to answer.
9 MR. ROSENBLUM: Have you considered any legal
10 action as a result of this situation? And he was instructed
11 not to answer.
12 MR. WATKINS: What was the question?
13 MR. ROSENBLUM: Have you considered any legal
14 action as a result of this situation? And he was instructed
15 not to answer.
16 MR. WATKINS: Same thing, your Honor.
17 THE COURT: It goes to interest or bias.
18 MR. ROSENBLUM: Were you aware -- were you
19 aware of after -- were you aware of in or about March or
20 April of 2018, any cash being delivered to any person on
21 your behalf? He was instructed not to answer.
22 MR. WATKINS: Again, same thing.
23 THE COURT: Asking him what he was aware of
24 is fair. Fair question on interest or bias.
25 MR. ROSENBLUM: But, your Honor, again, it's
 61

1 our position that source of funds is not protected under the

2 privilege, so even if it's our position he was made aware of
3 that through his lawyer, we're entitled that information.
4 Especially in a later question that he actually talked about
5 in the house, which we'll get to.
6 THE COURT: Well, the question was presented,
7 ask him directly of his knowledge.
8 MR. ROSENBLUM: Correct. But I want to --
9 the question was --
10 THE COURT: I don't want to be back here on
11 privilege on this when we've just taken that privilege up.
12 MR. ROSENBLUM: So the question, my question
13 was: Were you aware or -- were you aware in or about March
14 or April, any cash being delivered to any person on your
15 behalf? And my question is asking him from any source.
16 I want to explore it from any source, including
17 his lawyer. If he got a benefit, which goes to his bias,
18 which is not source of funds, is not protected under the
19 privilege.
20 MR. WATKINS: Okay, your Honor, again, I have
21 no problems with what my client knows outside -- and it's
22 nuance. The privilege attaches to our communication. What
23 our clients -- what my client knows about the source of
24 funds, he's able to -- he's able to communicate. We have
25 concluded the deposition for all matters except the
 62

1 questions that are certified.

2 MR. ROSENBLUM: We're going to raise that
3 issue as well.
4 MR. WATKINS: That was on the record
5 yesterday, and that is what you made on the record and
6 that's what I agreed to. We can address whatever you want.
7 But I made a deal.
8 MR. ROSENBLUM: I'll be happy to. Another
9 question was: Are you aware that your lawyer set up a trust
10 account on your behalf for people to contribute money to
11 you?
12 "ANSWER: I don't know any specifics. I saw
13 a press release yesterday, which would have been Tuesday."
14 You saw a press release? When you testified
15 before the House, did you testify that an unidentified third
16 party had paid $15,000 to cover legal fees and all things
17 that were about to happen to me financially because of the
18 fallout relating to the events? Did you say that statement
19 to the house?
20 Mr. Watkins objected, both on the fact that
21 it mischaracterized the testimony and attorney-client. With
22 respect to mischaracterizing the testimony, I have an e-mail
23 that's exactly the quote from the House and read it
24 verbatim, and he was instructed not to answer for
25 attorney-client privilege.
 63

1 THE COURT: We're not preserving those -- we

2 already decided that nobody waives anything as far as
3 objections.
4 MR. WATKINS: Your Honor, there's a very
5 important thing that I want to point out for the Court right
6 now, and it's vital to the integrity of these proceedings
7 and the proceedings in Jefferson City.
8 Counsel for the defendant has just acknowledged to
9 the Court that he was reading directly, yesterday, during
10 the deposition, from the transcript of testimony that was
11 elicited from my client, utilizing an unredacted copy of the
12 transcript procured somehow, some way utilizing unlawful
13 means, and I'm not accusing counsel of it. But those
14 transcripts were not to be released until there was the
15 public release of --
16 THE COURT: Transcripts of what?
17 MR. WATKINS: The transcripts that were
18 affixed to the House Investigative Committee on Oversights'
19 report that was released yesterday evening. So somehow,
20 some way, counsel for the defendant acquired, prior to the
21 release of the report, the transcripts, which were affixed
22 as exhibits to that report. They were unredacted, and they
23 were not made public, nor were they by order of the House of
24 Representatives to be released to anyone other than the
25 named and dually appointed and seated members of the
 64

1 Investigative Committee on House Oversight, or of Oversight.

2 And, quite frankly, now we've got acknowledgment
3 that that has gone on. I was present during that testimony.
4 What I don't have the benefit of, although I could print it
5 off now online, but what counsel for the defendant had privy
6 to during the deposition, was the fact that immediately
7 thereafter it became clear from the spontaneous testimony of
8 P.S. in front of the House Investigative Committee, that he
9 was confused by the question that the amount that was paid
10 was -- the figure that he had utilized was the amount he had
11 paid our firm, and then it was really clear that he didn't
12 understand that a law firm has a trust account, that doesn't
13 mean a trust was set up for him. But that's besides the
14 point.
15 THE COURT: Yeah, that is beside the point.
16 Here's the point. The objection was an instruction not to
17 answer was about -- regarding something that is part of a
18 public press release?
19 MR. WATKINS: The public press release, your
20 Honor, was basically a tongue-in-cheek press release saying
21 we're accepting donations we're keeping anonymous.
22 THE COURT: Nothing should be tongue-in-cheek
23 here, and tongue-in-cheek is in the eye of the beholder, not
24 all are smiling about.
25 MR. WATKINS: I've been told that many times.
 65

1 THE COURT: Let's get back to the issue at

2 hand. The issue at hand is you asserted a privilege on that
3 question.
4 MR. WATKINS: Yes, your Honor.
5 THE COURT: And it seemed to me that the
6 privilege, even if there is one, is waived when the public
7 is invited.
8 MR. WATKINS: As to that which the public has
9 been invited to. The tea party that he's asking about is
10 not the tea party that my client was talking about in the
11 press release, but I understand that will be up to the
12 counsel to clarify.
13 THE COURT: Okay.
14 MR. ROSENBLUM: Which goes on to talk about
15 the -- again, he talked about at some point maybe he was
16 confused with this point, but I'd like to clarify it, but
17 the Post-Dispatch was covering fees and all things that were
18 about to happen to me financially because of the fallout. I
19 had spent 15,000 or so of my own prior to all of this, and
20 while I was talking to the Post, someone contacted my lawyer
21 and said he was going to help with legal fees.
22 That was actually -- I asked him, I read the
23 statement that he made to the House. About somebody
24 contacting his lawyer with help for legal fees. Did you --
25 and I quoted the House verbatim.
 66

1 Did you make that statement to the house? And he

2 was instructed not to answer by his counsel, Mr. Watkins.
3 MR. WATKINS: Fairly protracted question. At
4 the end of the day it's the same thing we've been talking
5 about.
6 THE COURT: So prior statement of the witness
7 seems to be a favor inquiry.
8 MR. WATKINS: Yes, your Honor. I think my
9 biggest concern at that point was the stark realization at
10 that point that somehow the governor's counsel was granted
11 privy to a transcript that they shouldn't have had.
12 THE COURT: Yeah.
13 MR. WATKINS: But that's another issue.
14 THE COURT: That's for another tea party.
15 MR. ROSENBLUM: Your Honor, just to clarify
16 the record. I'd like Ms. Nasser to speak to how we
17 acquired -- how we were receiving this information by
18 e-mail. I think it will take about two sentences.
19 THE COURT: Ms. Nasser.
20 MS. NASSER: Your Honor, I think as probably
21 everybody in the courtroom knows, that report was available
22 online. And in the middle of the deposition, the fact the
23 report and transcripts were available online was made known
24 to me, and that's how we obtained the transcripts online.
25 THE COURT: During the deposition?
 67

1 MS. NASSER: That's correct, your Honor.

2 THE COURT: Anything further?
3 MR. ROSENBLUM: Yes, your Honor.
4 "QUESTION: Are you aware your lawyers
5 established a trust account after speaking to the
6 Post-Dispatch, are you aware of that?"
7 He was asked. He was instructed not to
8 answer.
9 THE COURT: All right. So you're going to be
10 able to get into these areas. We're not going to go step by
11 step. I think we're clear on what's available as far as
12 probing interest and bias.
13 MR. ROSENBLUM: And there will just be one
14 more area that I want to definitely say that we're going to
15 get into. And I don't want -- I don't -- based on what has
16 happened so far, I believe that there may be an objection,
17 and this was a question that was propounded during the
18 hours, and so anything that's tied into compensation goes
19 through, this is a question, I don't understand the trust
20 part of this, but it goes through a trust through your
21 attorney; is that right?
22 His answer was: Yes, sir. Okay.
23 "ANSWER: I don't want anything. It was
24 offered, I don't want it.
25 "QUESTION: Okay.
 68

1 "ANSWER: I want to take care --

2 "QUESTION: So help with your legal fees is
3 that what you're saying?
4 "ANSWER: Yeah. Legal fees, and if -- who
5 knows, if something was given or whatever, this is going
6 into a trust for my children."
7 So at that point he mentions and has some
8 knowledge about a trust for his children, and I want to
9 inquire about that.
10 MR. WATKINS: For your own edification, your
11 Honor, he's hired our firm to do estate planning for him.
12 It hadn't been done at that point, and it is for the benefit
13 of his kids. Whatever he chooses to put into that trust.
14 THE COURT: That will be able to be probed
15 into.
16 MR. ROSENBLUM: And it was 100 percent
17 correct on behalf of Mr. Watkins that the information that I
18 had available to me at the time that I represented to
19 Mr. Watkins that the deposition would conclude subsequent,
20 or based on your rulings with respect to attorney-client,
21 and that if we resume I would be limited to ask about those
22 issues.
23 Since that time, as the Court has been made well
24 aware of, we have been provided with new discovery at a late
25 date, even though the prosecutor had it on Monday, we had
 69

1 been provided with the videotape of K.S.

2 That brings to light other issues, even though I
3 haven't even read the entire thing, or looked at it, just on
4 a cursory understanding, that brings to other issues that I
5 want to question.
6 THE COURT: What time was the tape produced
7 to you all last night?
8 MR. ROSENBLUM: We received the tape, I
9 believe, yesterday at about 6:15.
10 THE COURT: Had you recessed this deposition
11 by the time you received it?
12 MR. ROSENBLUM: We had recessed the
13 deposition.
14 MS. NASSER: In fact, the offer was for us to
15 get it this morning in court, and instead I came to the
16 Circuit Attorney's Office and obtained it after the
17 deposition.
18 THE COURT: But the point is, the tape wasn't
19 in your possession until this deposition had been recessed?
20 MR. ROSENBLUM: It was not in my possession,
21 nor have I had the opportunity to review the entire tape.
22 MR. WATKINS: Your Honor, I'm a huge fan of
23 making sure a defendant is granted full and fair opportunity
24 to prepare their defense. And this is fair, so I get that.
25 That doesn't bother me.
 70

1 I would ask there be indulgence on the part of --

2 my client has taken two days off of work now, or two half
3 days off of work, and is now dealing with third, although
4 this is no work in the afternoon, it's been a pretty
5 tremendous and overwhelming process for him.
6 THE COURT: Well, I understand that. But the
7 timeliness of turning over discovery required by rule is
8 a --
9 MR. WATKINS: I respect that, your Honor.
10 THE COURT: So that's it.
11 MR. ROSENBLUM: Just with the addendum that I
12 have not reviewed the entire tape because it would have been
13 very difficult to do that.
14 THE COURT: We'll take that as it comes.
15 MR. ROSENBLUM: Okay.
16 THE COURT: I understand that attorneys want
17 to have all the documents and all the evidence out there
18 when they take depositions. And receiving documents after
19 depositions two days or eight hours into it is not normally
20 the way things happen.
21 MR. ROSENBLUM: Thank you, your Honor.
22 THE COURT: And it should not be the way.
23 All right. I'll be around this afternoon.
24 MR. WATKINS: Thank you.
25 THE COURT: Mr. Rosenblum, I've had a request
 71

1 of media, this was presented this morning, to get a copy of

2 this.
3 MR. ROSENBLUM: Can I see it, please?
4 THE COURT: Presented by Mr. Martin. I
5 believe my gag order applies to out-of-court, and it's not
6 intended to apply to anything in court, nor filed without
7 seal.
8 MR. ROSENBLUM: Just with the further comment
9 that it's my understanding the State has sought the
10 protective order to protect her identity, so if the State
11 has no issue with it we don't as well.
12 MR. STEELE: But the State has an issue with
13 it. The representations that something was being said at
14 that point. If the media's not going to get the tape
15 there's no way to verify what was being said, other than
16 what was represented by the defense that there were comments
17 being said at the point.
18 Still, I have no idea if that is, in fact, true,
19 because I haven't seen it myself, and I believe there's a
20 time somewhere on the picture that referenced the tape and
21 exceeds if anything is audible on that tape, and if it is
22 what is being said.
23 But until then, the only evidence or I think
24 construe what was being said at that point, the defense's
25 representation after what appears to be laughter was in
 72

1 response to a question of some sort.

2 MR. ROSENBLUM: For the record, we have no
3 objection.
4 THE COURT: Mr. Steele, have you been through
5 all of the information that the House released?
6 MR. STEELE: I haven't looked at any of it.
7 THE COURT: Mr. Rosenblum, have you been
8 through all the information the House released?
9 MR. ROSENBLUM: I'm sorry? I didn't hear
10 you.
11 THE COURT: My question is, have you had the
12 opportunity to see all the information that the House
13 released yesterday? House of Representatives State of
14 Missouri?
15 MR. ROSENBLUM: Since the time of the
16 deposition adjourning last evening, I was able to read
17 P.S.'s testimony to the house, which on a number of
18 occasions stands in stark contrast to his testimony under
19 oath during the deposition. I plan on inquiring.
20 THE COURT: I'm sorry, sir. Mostly what I'm
21 wanting, Mr. Steele makes a good point that as to
22 confidentiality of this witness, who's depicted in this
23 photograph.
24 MR. ROSENBLUM: Correct.
25 THE COURT: I'm wondering was that
 73

1 confidentiality breached whatsoever by the filings of the

2 State.
3 MR. ROSENBLUM: Not to my knowledge. It
4 appears that all relevant names were redacted.
5 THE COURT: And there was no photos or videos
6 released?
7 MR. ROSENBLUM: I can't respond to that
8 question. I have absolutely no knowledge.
9 MR. WATKINS: My understanding, your Honor,
10 none were released.
11 THE COURT: All right. I'm going to withhold
12 a decision on this. Mr. Steele, you wanted to look at this.
13 MR. STEELE: Yes, sir.
14 THE COURT: I'll be around here if -- are you
15 preparing for that trial still? Trying to?
16 MR. STEELE: I've sent my witness home. We
17 were at 10:00. I sent them back and ask them can they come
18 tomorrow. I have another witness scheduled at one. We were
19 hoping to start this deposition at 11, but now it's 12:30
20 so.
21 THE COURT: I'll wait to hear from your
22 office on this.
23 MR. ROSENBLUM: Your Honor, one moment. Your
24 Honor, I'm in the unique position of actually saying that
25 Mr. Watkins came up with a good idea.
 74

1 MR. WATKINS: It's been more than once.

2 MR. ROSENBLUM: But in any event, Mr. Watkins
3 has graciously suggested that we adjourn the deposition for
4 today so that I can have ample time not only to review
5 K.S.'s videotape, but spend more time with the House
6 Committee's transcript, and as long as we can reschedule in
7 a very timely fashion, whether it be another day this week
8 or a day next week, I'm completely on board with that.
9 THE COURT: I'll leave it to you all to take
10 care of.
11 MR. WATKINS: Thank you, your Honor. Thank
12 you for your time today.
13 THE COURT: My pleasure. If we take the
14 identification, the ability to see whose face is on that,
15 that should take care of the confidentiality.
16 MR. STEELE: It will take care of that, but
17 my issue, there was some representation that something was
18 being said when that -- that was extracted from the actual
19 video. I object to that portion, the video where there's
20 audio or not. I don't know, I'd have to check the time.
21 THE COURT: There's nothing on here that has
22 any questions or language.
23 MR. STEELE: Right. But the proceedings,
24 there was representation.
25 THE COURT: I remember that, but what I'm
 75

1 saying, I don't see any connection between -- on this

2 document. All it shows is people at a table.
3 MR. STEELE: Right. But somewhere on there
4 there's a time. But I need to reference the time so I can
5 take the actual video if there's something that's said on
6 the video. Somewhere on that.
7 THE COURT: Yeah, it's on here. But I'm
8 having trouble with the connection of we're not talking
9 about reporting what was said.
10 MR. STEELE: They made a representation as to
11 what was being said.
12 THE COURT: At the time. But it was in
13 connection with her smiling.
14 MR. STEELE: Right.
15 THE COURT: And they're going to not show her
16 face?
17 MR. STEELE: Right.
18 THE COURT: So that's where I'm having
19 trouble with the connection.
20 MR. STEELE: Because I don't want any
21 misrepresentation that she was laughing in response to a
22 question if in actuality there is no question being
23 propounded at that point on the tape. That has been what's
24 put out into the public. So I just want to see if
25 something's being said.
 76

1 THE COURT: Get back to me.

2 (The hearing was concluded.)
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 77

1 CERTIFICATE
2 I, Jennifer A. Dunn, Registered Professional
3 Reporter and Certified Court Reporter, do hereby certify
4 that I am an official court reporter for the Circuit Court
5 of the City of St. Louis; that on April 12, 2018, I was
6 present and reported all the proceedings had in the case of
7 STATE OF MISSOURI, Plaintiff, vs. ERIC GREITENS, Defendant,
8 Cause No. 1822-CR00642.
9 I further certify that the foregoing pages
10 contain a true and accurate reproduction of the proceedings.
11
12
13
14
15 "/s/JENNIFER A. DUNN, RPR, CCR #485"
16
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 53/14 73/2 73/6 58/6 59/6 39/19
MR. 53/19 73/22 59/10 39/21
BENNETT: 53/22 74/1 59/16 40/21
[5] 48/2 54/2 54/8 MR. 60/3 MS.
48/9 50/7 54/14 STEELE: 60/11 NASSER:
51/16 55/12 [23] 32/6 60/15 [3] 66/19
51/19 56/7 35/18 60/21 66/25
MR. 56/10 35/22 61/19 69/13
DIERKER: 57/25 37/13 62/3 63/3 THE
[3] 46/22 58/15 37/16 63/16 COURT:
47/24 58/22 37/18 64/18 [113]
59/13 37/25 64/24
49/9 $
MR. 59/20 38/4 38/7 65/3 65/7
60/8 52/10 66/2 66/7 $15,000 [1]
MARTIN: 62/16
[13] 2/5 60/12 55/20 66/12
60/17 55/22 68/9 $250 [1]
6/3 6/8 22/1
8/6 10/4 60/24 71/11 69/21
10/6 11/8 61/7 72/5 70/8 /
11/10 61/11 73/12 70/23 /s/JENNIFE
35/17 62/1 62/7 73/15 73/8 R [1]
35/20 65/13 74/15 73/25 77/15
40/23 66/14 74/22 74/10
67/2 75/2 75/9 MS. 1
41/5 48/7
67/12 75/13 GARDNER: 10 [3]
MR.
68/15 75/16 [13] 41/12
ROSENBLU
69/7 75/19 28/15 41/14
M: [51]
69/11 MR. 28/21 41/17
20/16
69/19 WATKINS: 28/25 100
20/19
70/10 [32] 29/6 percent [1]
50/8
70/14 54/16 29/23 68/16
51/18
70/20 54/21 30/10 10:00 [1]
51/22
71/2 71/7 54/25 30/13 73/17
52/7
72/1 72/8 56/24 30/16 11 [8]
52/18
72/14 57/5 30/19 5/23 9/21
53/12
72/23 57/10 39/13 11/18
1 12/24 21st [4] 26/25 3/20 4/18
160 [2] 25/15 5/4 5/5
11... [5] 4
12/5 12/21 34/18 5/7 5/9
13/4 36/23 40 [1] 5/20 7/25
13/25 16/15
46/14 174 [1] 37/2 8/10
10/12 24 [1] 485 [2] 12/10
51/14 1/24
73/19 1822-CR00 13/15 13/13
642 [5] 24th [6] 77/15 13/21
1114 [1]
1/15 1/7 2/4 6/5 6/7 6 15/7
113 [2] 32/5 13/19 63101 [1] 15/16
8/6 8/7 53/12 14/19 1/16 16/12
115 [1] 77/8 17/11 63105 [2] 17/1
8/19 189 [1] 44/2 1/19 1/21 18/11
117 [2] 10/16 29 [2] 6:15 [1] 20/1 22/5
9/10 1900 [1] 10/5 69/9 24/12
13/22 1/20 43/12 24/13
19th [1] 293 [3] 7 24/21
12 [3]
7733 [1]
1/11 23/5 2/15 11/24 24/23
1:30 [1] 12/1 12/2 1/20 25/5
77/5
120 [1] 50/11 294 [1] A 25/11
11/23 25/21
1/19 2 ability [3]
12:30 [1] 29th [4] 25/22
20 [3] 23/12
73/19 6/5 6/6 26/16
27/6 52/1
13 [1] 8/5 32/23 7/4 46/10 27/7
74/14
27/22
130 [1] 43/1 3 able [8]
1/19 32/8
2015 [2] 302 [2] 23/7 40/1
14 [1] 34/19
13/16 22/25 60/8
22/2 35/25
37/7 23/13 61/24
15 [1] 36/24
2018 [3] 302s [1] 61/24
32/23 40/3
1/11 23/17 67/10
15,000 [1] 60/20 40/13
35 [4] 68/14
65/19 42/5 42/6
77/5 20/22 72/16
159 [2] 42/14
21 [1] 20/25 about [76]
12/21 43/9
13/8 23/5 2/15 3/8
43/12
A absurd [2] acknowledg 45/14 admit [1]
about... 6/20 7/3 ed [4] actual [6] 43/14
[33] accepting 52/17 25/1 39/4 admitted
43/18 [1] 64/21 52/21 40/7 [7] 7/21
45/7 46/1 according 52/24 55/24 18/6
46/2 46/3 [3] 17/14 63/8 74/18 18/23
46/3 46/5 21/14 acknowledg 75/5 42/11
46/6 51/1 21/16 es [1] actuality [1] 45/4
53/24 account 49/11 75/22 51/18
53/25 [15] acknowledg actually 51/20
54/12 33/20 ment [1] [13] 5/5 affixed [2]
56/1 33/21 64/2 13/18 63/18
60/19 33/25 acquired 16/22 63/21
61/4 33/25 [3] 49/14 18/2 23/7 afoul [2]
61/13 34/2 34/3 63/20 28/14 48/17
61/23 34/5 36/8 66/17 49/24 48/23
62/17 36/9 act [2] 51/1 51/4 after [19]
64/17 36/10 26/9 51/8 61/4 2/23 2/24
64/24 36/11 26/10 65/22 5/3 11/24
65/9 36/13 action [3] 73/24 12/5
65/10 62/10 48/15 addendum 16/14
65/14 64/12 60/10 [1] 70/11 16/14
65/15 67/5 60/14 addition [3] 16/16
65/18 accounts actions [1] 22/3 16/17
65/23 [2] 34/23 36/23 27/17 17/6
66/5 34/25 active [1] 50/25 28/20
66/18 accurate [1] 30/19 additional 45/5 47/5
68/8 68/9 77/10 activities [1] 22/4 47/5
68/21 Accusations [3] 3/23 address [4] 60/19
69/9 75/9 [1] 46/24 8/10 28/15 67/5
absent [1] accused [3] 36/22 35/18 69/16
32/10 18/14 activity [4] 50/5 62/6 70/18
absolutely 21/1 25/23 adjourn [1] 71/25
[1] 73/8 21/20 36/21 74/3 afternoon
accusing 45/5 adjourning [4] 47/20
[1] 63/13 [1] 72/16
A 2/15 2/21 42/20 allegations already [5]
afternoon... agree [1] 44/4 [14] 28/3 4/6 38/16
[3] 50/11 58/7 44/20 28/5 28/8 38/19
70/4 agreed [1] 46/13 32/8 39/10
70/23 62/6 48/2 32/11 63/2
again [14] agreement 48/18 32/15 also [9]
6/3 7/5 [1] 50/14 48/25 33/8 34/7 13/14
14/15 aimed [1] 53/6 53/7 35/4 35/4 18/1
21/10 50/18 53/8 54/4 35/24 18/18
38/20 aisle [1] 54/13 36/14 19/7
39/2 39/3 20/14 54/19 37/1 40/3 20/12
44/22 all [61] 55/1 alleged [2] 34/11
52/22 2/21 4/22 57/21 2/18 4/10 36/14
60/4 6/21 7/8 59/4 allegedly 38/2
60/22 14/7 59/13 [1] 17/14 45/19
60/25 16/14 61/25 allow [2] although
61/20 22/19 62/16 19/18 [3] 21/22
65/15 23/17 64/24 22/12 64/4 70/3
against [6] 25/2 26/1 65/17 allowed [8] am [5]
27/1 26/17 65/19 11/22 12/2 21/2
40/11 27/21 67/9 69/7 24/15 24/10
40/12 27/22 70/17 25/6 39/17
46/20 29/8 70/17 25/24 77/4
50/2 50/6 29/13 70/23 42/4 Amendmen
agent [7] 32/10 72/5 72/8 58/21 t [1] 48/16
6/21 7/23 32/14 72/12 59/6 amount [3]
8/8 11/25 34/7 73/4 59/20 44/17
15/16 34/19 73/11 allows [1] 64/9
19/10 35/24 74/9 75/2 16/17 64/10
23/16 38/25 77/6 allude [1] ample [1]
agents [2] 39/12 allegation 26/9 74/4
23/1 40/25 [4] 27/1 almost [1] analysis [1]
23/17 41/7 39/5 14/3 58/2
ago [2] 41/17 40/11 along [1] anonymous
42/7 40/11 21/9 [1] 64/21
A 62/12 39/24 14/22 anywhere
another [5] 62/24 40/23 anyone [2] [5] 25/25
62/8 64/17 42/4 39/13 35/5 35/6
66/13 66/2 67/8 44/10 63/24 35/7 35/8
66/14 67/22 46/2 49/5 anything apologize
73/18 67/23 49/17 [33] 9/16 [1] 59/12
74/7 68/1 68/4 49/21 13/23 apparently
answer [38] answered 50/18 17/21 [4] 17/23
8/14 9/20 [3] 27/8 50/19 20/10 18/24
11/2 57/19 51/25 26/9 28/1 42/7
47/25 58/22 52/17 28/6 45/21
50/17 answering 53/1 54/9 28/19 appeared
51/2 [1] 51/4 54/9 30/8 [1] 3/1
54/14 answers [1] 55/20 32/11 appears [3]
55/12 34/13 58/24 32/16 5/3 71/25
56/14 anticipated 58/24 32/17 73/4
56/20 [1] 2/13 59/14 32/18 applies [1]
56/21 any [58] 59/22 35/14 71/5
57/2 57/4 7/4 7/16 59/22 35/15 apply [1]
57/8 8/22 9/24 59/23 37/10 71/6
57/10 10/13 59/25 37/24 appointed
58/4 10/22 60/5 60/9 38/3 [1] 63/25
58/15 11/1 11/2 60/13 38/19 approached
58/20 15/21 60/20 40/19 [1] 23/17
59/10 22/19 60/20 40/21 appropriate
59/16 23/16 61/14 42/8 48/2 [2] 47/18
59/19 26/9 61/14 48/7 48/19
59/20 26/10 61/15 52/10 approximat
59/24 26/22 61/16 53/6 ely [1]
60/3 60/6 26/23 62/12 57/20 27/6
60/8 27/4 72/6 74/2 63/2 67/2 April [4]
60/11 28/12 74/22 67/18 1/11
60/15 32/20 75/1 67/23 60/20
60/21 33/9 75/20 71/6 61/14
35/10 anybody [2] 71/21 77/5
5/14
A 51/13 25/23 70/14 11/6
are [40] 67/14 27/20 71/11 11/13
2/12 3/9 areas [1] 36/6 72/21 11/15
5/18 7/19 67/10 36/20 74/6 74/6 11/21
8/10 aren't [2] 38/6 38/6 75/10 12/1 12/8
10/13 14/24 39/18 aside [1] 12/13
13/7 49/24 40/5 60/6 12/21
14/18 arenas [1] 40/18 ask [28] 13/22
14/24 3/8 41/18 2/12 7/4 15/19
15/1 15/2 argue [1] 41/25 10/13 16/7
15/2 16/2 37/4 42/25 10/20 23/24
16/3 argument 43/4 43/6 10/22 23/25
17/11 [2] 37/23 43/13 11/1 11/2 25/3 27/8
17/17 38/3 46/9 11/19 27/12
20/9 21/9 around [7] 46/11 12/1 28/11
22/24 18/20 46/11 15/19 30/4
24/6 28/4 18/25 46/19 15/21 34/13
31/2 33/8 23/11 47/15 22/19 36/18
34/12 24/2 24/3 47/15 39/3 40/8
39/2 70/23 50/10 40/14 40/10
41/12 73/14 51/3 40/15 42/13
42/13 aroused [1] 51/15 46/11 45/23
45/18 34/16 51/15 53/17 46/3 55/6
46/17 as [63] 2/6 53/1 53/1 53/19 56/19
46/19 2/14 3/25 55/7 55/9 55/9 57/1 57/7
46/24 5/7 5/14 60/10 55/17 57/12
47/7 5/14 6/12 60/14 57/13 58/2
50/10 8/8 11/13 62/3 63/2 58/3 58/11
58/24 11/15 63/2 58/14 65/22
62/1 62/9 11/25 63/22 61/7 67/7
64/24 17/21 65/8 68/21 asking [15]
67/4 67/6 17/23 66/20 70/1 2/13 7/8
73/14 19/8 20/8 67/11 73/17 7/8 8/9
area [2] 20/8 21/9 67/11 asked [36] 12/2 20/3
24/25 68/23 4/17 7/18 27/20
A 27/6 51/12 44/12 61/13
asking... [8] 29/18 53/4 54/8 50/4 61/13
35/22 attempts 54/10 70/16 62/9 67/4
35/23 [1] 48/24 55/4 55/8 audible [2] 67/6
38/22 attended 56/18 38/11 68/24
38/25 [4] 2/16 56/24 71/21 away [2]
46/19 11/18 57/3 audio [10] 36/22
60/23 12/5 57/18 32/24 45/18
16/10 57/21 32/25
61/15 B
65/9 attention 57/24 33/2 33/5
back [20]
asserted [2] [1] 4/9 58/5 60/2 41/13
4/13 4/17
50/6 65/2 attorney 62/21 41/14
6/3 7/18
asserting [45] 2/9 62/25 41/17
2/16 6/18 67/21 56/4 56/6 13/15
[1] 50/2 13/22
assertions 7/5 7/24 68/20 74/20
17/20
[1] 24/14 11/7 attorney's augmented
21/24
assess [1] 11/12 [6] 1/15 [1] 26/13
17/2 17/5 6/24 available 23/9
36/5 23/10
assessed 18/14 28/22 [4] 66/21
32/3 32/4
[1] 36/12 18/15 33/21 66/23
45/3
assistance 19/7 36/9 67/11
49/23
[2] 53/18 19/16 69/16 68/18
53/11
53/20 22/12 attorney-cli Ave [1]
56/9
associates 23/3 ent [10] 1/19
61/10
[1] 33/24 28/25 51/12 aware [16]
65/1
assume [1] 29/12 55/4 3/10
73/17
19/5 30/1 34/2 56/18 34/12
76/1
astoundme 34/24 57/3 34/13
background
nt [1] 23/6 40/7 57/24 50/10
[1] 6/22
attaches [1] 40/10 58/5 60/2 58/24
based [2]
61/22 40/14 62/21 60/18
67/15
attempt [1] 46/20 62/25 60/19
68/20
29/19 50/16 68/20 60/19
basement
attempted 50/21 attorneys 60/23
[9] 3/14
[3] 22/6 51/11 [4] 23/11 61/2
B 44/14 74/7 40/12 44/19
basement... 45/9 became [2] 44/9 48/20
[8] 13/9 47/12 38/10 45/19 49/12
16/17 47/14 64/7 47/2 47/4 50/22
16/17 48/4 because 52/5 57/9 55/8
17/7 48/18 [45] 2/11 62/17 55/18
25/24 49/13 6/15 7/24 65/18 56/1
37/8 44/5 50/1 10/9 70/12 57/14
45/6 50/14 10/22 71/19 60/5
bashing [2] 51/6 12/2 75/20 62/13
18/15 54/21 13/17 been [52] 64/25
18/16 55/24 14/8 3/1 6/10 65/9 66/4
basically [3] 57/1 14/10 6/11 6/11 68/12
22/20 58/21 14/15 15/15 68/23
28/17 58/21 15/22 17/13 68/24
64/20 59/5 17/12 18/14 69/1
be [61] 59/20 18/2 18/16 69/19
2/11 2/17 60/8 18/16 19/21 70/4
4/2 4/9 61/10 19/11 20/3 70/12
4/22 5/15 62/8 20/8 20/22 72/4 72/7
5/25 6/15 63/14 21/22 20/23 74/1
20/6 20/7 63/24 23/18 21/20 75/23
20/11 64/22 23/19 26/7 before [19]
22/13 65/11 24/4 26/19 3/10 3/11
23/16 66/7 67/9 26/11 28/7 32/7 5/25 6/10
24/22 67/13 26/19 32/10 6/11 6/12
25/2 31/3 67/16 29/1 29/4 33/17 11/13
32/3 32/4 68/14 29/25 34/14 16/16
35/2 68/14 33/16 34/15 17/12
35/12 68/21 33/20 36/2 37/6 19/22
38/6 70/1 34/9 38/15 24/6 24/7
40/14 70/22 34/16 38/21 37/24
42/21 70/23 35/12 41/12 38/3
44/6 71/25 37/20 42/18 38/16
73/14 39/6 40/9 44/11 41/9 46/4
B 56/5 1/20 48/9 blatant [1] Brady [5]
before... [2] 60/20 beside [1] 18/4 16/23
57/5 61/14 64/15 blatantly 37/22
62/15 71/13 besides [1] [1] 7/2 37/25
beforehand 71/15 64/13 blow [1] 38/4
[1] 42/19 71/17 best [3] 17/21 38/15
begin [1] 71/22 24/22 Blvd [1] brain [1]
44/12 71/24 28/15 1/20 9/6
behalf [10] 74/18 44/25 board [1] branch [2]
1/16 1/21 75/11 better [1] 74/8 49/6 50/6
20/20 75/22 48/12 bogus [4] breached
48/23 75/25 between [5] 51/6 [1] 73/1
54/11 belies [1] 4/15 52/23 break [2]
58/25 23/24 32/23 52/25 7/14 41/9
60/21 believe [10] 48/11 53/2 brick [1]
61/15 5/14 57/21 bombshell 15/7
62/10 38/15 75/1 [1] 5/18 bring [2]
68/17 39/6 45/8 bias [5] book [1] 40/9 41/1
behavior [2] 45/10 54/20 59/25 brings [2]
27/3 51/13 60/17 both [8] 69/2 69/4
40/13 67/16 60/24 4/12 brought [1]
behold [5] 69/9 71/5 61/17 20/24 36/19
2/20 4/6 71/19 67/12 21/5 Buckles [1]
6/19 6/25 believed [1] big [3] 45/10 20/2
7/7 25/22 15/7 15/7 45/12 bullet [1]
beholder benefit [8] 45/22 46/12 47/8
[1] 64/23 21/8 bigamy [1] 46/25 Burlison [1]
being [19] 22/19 21/21 62/20 1/2
17/8 18/4 26/5 58/9 biggest [3] bother [1]
C
42/17 59/14 4/8 7/14 69/25
61/17 66/9 bottom [4] call [2]
43/17 21/17
43/25 64/4 bit [4] 12/23
68/12 20/15 15/5 40/13
44/14 called [2]
49/20 BENNETT 43/5 48/4 27/14
[3] 1/18 48/11 55/25 14/12
C 73/17 21/13 certain [2] 26/2
called... [1] 74/4 74/6 22/9 36/21 33/15
40/7 75/4 34/22 49/20 33/18
came [5] can't [3] 35/2 certainly [4] 33/18
7/18 10/3 25/3 35/11 5/12 19/6 33/19
56/12 47/25 40/12 47/13 34/2 34/3
69/15 73/7 42/21 51/11 34/5 34/8
73/25 candid [1] 43/9 CERTIFICAT 34/9
camera [2] 2/11 46/19 E [1] 77/1 36/16
4/25 5/2 candidly [4] 46/19 certified [7] channels
camera's 14/11 49/24 50/15 [1] 23/11
[1] 13/17 18/15 50/19 53/16 charge [3]
can [30] 19/21 54/5 53/24 29/5
5/2 7/9 20/8 59/15 54/23 34/17
11/14 candor [1] 77/6 54/23 35/11
15/10 44/21 cases [2] 62/1 77/3 charged [3]
27/18 capture [1] 34/21 certify [2] 20/23
28/15 5/7 58/6 77/3 77/9 21/20
30/6 37/4 care [4] cash [2] chain [2] 21/24
37/14 68/1 60/20 27/15 charges [1]
37/15 74/10 61/14 27/22 33/8
42/2 42/2 74/15 caught [1] chambers charging
49/21 74/16 54/25 [3] 28/3 [1] 22/1
51/11 career [2] Cause [5] 30/25 chat [1]
51/12 8/25 9/1 1/7 2/3 31/1 17/9
54/21 careful [1] 32/4 chance [2] check [4]
55/8 45/9 53/11 20/14 5/2 7/15
55/14 case [24] 77/8 30/22 29/12
55/21 2/18 2/25 caused [2] change [5] 74/20
56/20 9/24 51/6 52/4 16/1 16/6 checked [3]
57/1 12/15 CCR [2] 36/1 36/1 7/19 24/4
57/22 12/15 1/24 38/18 29/8
58/5 60/6 14/11 77/15 changed cheek [3]
62/6 71/3 19/22 Central [1] [12] 64/20
20/2 20/8 1/19 16/15 64/22
C 46/20 64/7 17/7 34/24
cheek... [1] 51/11 64/11 25/16 36/11
64/23 69/16 67/11 44/4 44/5 36/11
Chief [2] 77/4 clearly [2] combine [1] 36/15
47/19 cite [1] 27/12 43/22 42/19
49/5 35/3 55/3 come [4] 49/12
child [1] cited [1] client [21] 29/18 49/18
21/24 35/16 43/17 40/15 52/25
children [2] CITY [6] 48/23 51/3 63/18
68/6 68/8 1/1 1/25 51/12 73/17 64/1 64/8
choose [1] 48/16 55/4 comes [2] Committee'
21/12 48/24 55/10 30/5 s [1] 74/6
chooses [1] 63/7 77/5 56/18 70/14 communica
68/13 claim [3] 57/1 57/3 coming [1] te [1]
chose [2] 6/16 57/21 29/21 61/24
22/7 49/7 12/19 57/24 comment communica
circuit [27] 44/4 58/5 60/2 [3] 48/13 tion [4]
1/1 1/15 claimed [1] 60/6 48/19 57/21
1/25 1/25 3/3 61/21 71/8 57/24
2/9 2/16 claiming [2] 61/23 comments 59/18
6/18 6/24 42/10 62/21 [2] 49/5 61/22
7/5 7/24 44/13 62/25 71/16 compare [1]
11/6 17/2 clarification 63/11 commit [3] 44/18
17/5 [1] 51/17 65/10 22/8 comparison
18/14 clarify [5] 68/20 23/12 [1] 8/1
18/15 39/15 70/2 39/24 compensati
19/16 49/4 clients [1] committed on [1]
28/22 65/12 61/23 [2] 22/13 67/18
28/24 65/16 close [2] 22/21 complaint
33/21 66/15 15/2 53/7 committee [1] 33/7
34/2 classic [1] clothes [9] [16] 2/24 complete
34/24 27/10 16/1 16/6 26/8 [1] 52/16
36/8 clear [5] 16/9 26/23 completely
44/12 38/6 16/14 33/25 [6] 5/7
38/21 16/15 34/4 12/19
C 21/7 consent [2] contained cooperation
completely. 22/18 33/11 [2] 22/4 [1] 45/23
.. [4] conducting 44/25 31/2 copy [3]
14/11 [1] 21/10 consenting contempora 14/12
26/2 26/7 confess [1] [1] 44/24 neous [1] 63/11
74/8 47/25 consider [3] 8/12 71/1
compounde confident 27/20 contention correct [8]
d [1] [2] 10/13 28/8 50/4 [1] 25/21 11/21
37/22 10/15 considered contents [3] 51/19
comprised confidential [2] 60/9 38/23 52/12
[1] 50/12 [2] 14/13 60/13 39/4 53/4 54/15
concern [2] 31/2 conspiracy context [1] 61/8 67/1
49/12 confidential [3] 19/18 48/14 68/17
66/9 ity [3] 24/10 continued 72/24
concerned 72/22 24/11 [1] 25/5 could [12]
[2] 3/25 73/1 conspire [1] continues 3/7 4/21
47/16 74/15 12/12 [1] 49/12 6/15
concerns confront [1] constitution contract [1] 11/25
[1] 6/15 26/19 al [2] 45/20 24/7
conclude confused 49/20 contrary [1] 24/22
[1] 68/19 [2] 64/9 50/3 45/16 25/8
concluded 65/16 constitution contrast [1] 25/18
[3] 50/12 connected ally [1] 72/18 29/16
61/25 [1] 19/2 50/5 contribute 35/15
76/2 connection constriction [1] 62/10 41/15
conclusion [4] 75/1 [1] 51/25 control [1] 64/4
[2] 22/14 75/8 construe 50/7 couldn't [2]
22/14 75/13 [1] 71/24 convenientl 7/24
conclusions 75/19 contacted y [1] 2/24 26/19
[1] 26/8 consensual [1] 65/20 conversatio counsel
conduct [4] [5] 37/6 contacting n [1] [14] 34/6
24/2 24/4 37/12 [1] 65/24 25/23 49/23
24/7 27/6 43/10 contain [2] convicted 49/24
conducted 43/10 44/1 [1] 21/20 49/24
[3] 21/7 44/12 77/10 convince 55/6
[1] 23/7
C 32/3 covering [1] critical [4] 50/12
counsel... 32/14 65/17 17/4 24/8 50/13
[9] 57/13 32/22 CR00642 24/8 66/4 74/7
59/18 34/12 [5] 1/7 25/12 74/8
63/8 35/25 2/4 32/5 cross [2] days [6]
63/13 36/17 53/12 49/1 2/21 6/2
63/20 39/4 40/6 77/8 54/21 45/1 70/2
64/5 40/18 create [3] cross-exam 70/3
65/12 42/1 52/1 52/2 ination [2] 70/19
66/2 46/19 52/5 49/1 deal [5]
66/10 48/22 credibility 54/21 41/3
countries 48/23 [11] 4/5 current [1] 59/25
[1] 19/24 49/8 14/11 26/4 59/25
couple [4] 53/10 18/13 cursory [1] 59/25
9/25 53/17 24/2 36/6 69/4 62/7
17/11 53/18 42/16 custody [1] dealing [1]
45/1 53/20 42/17 27/15 70/3
46/24 58/5 63/5 42/23 cut [2] dealt [1]
course [2] 63/9 42/24 29/16 20/7
49/14 68/23 43/7 43/14 debate [1]
50/19 69/15 44/21 CWE [3] 45/22
court [44] 71/5 71/6 credible [4] 15/7 decided [2]
1/1 1/24 77/3 77/4 36/8 15/14 21/12
1/25 2/2 77/4 36/10 15/18 63/2
2/3 2/14 Court's [3] 36/12
D decides [2]
20/24 49/17 36/13 37/23
50/10 crime [2] damaging 38/3
20/24 [1] 4/7
20/25 51/10 39/24 decision [3]
courthouse 46/25 dangerous 36/10
21/10 [1] 19/15
22/11 [2] 47/22 criminal [5] 37/15
49/22 19/9 date [2] 73/12
23/4 26/13
27/18 courtroom 19/14 deep [2]
[1] 66/21 27/11 68/25 24/11
27/20 day [7] 2/7
31/3 32/2 cover [1] 28/4
6/17
24/12
62/16 49/13 defective
[1] 25/10
D degree [1] deposition 50/11 57/20
defend [2] 38/14 [57] 2/15 51/7 destroys [2]
41/23 delivered 2/16 3/3 52/14 14/11
49/4 [2] 60/20 3/18 5/13 53/16 44/21
defendant 61/14 7/12 8/4 57/13 destruction
[11] 1/9 delve [1] 11/16 61/25 [1] 6/15
1/21 51/13 11/18 63/10 detail [3]
28/15 denial [1] 11/24 64/6 34/15
49/19 52/17 11/24 66/22 51/4 51/5
49/21 denied [9] 13/20 66/25 detailed [1]
57/13 26/17 15/13 68/19 8/9
63/8 26/21 16/8 69/10 details [3]
63/20 26/23 18/19 69/13 34/11
64/5 50/25 20/5 21/6 69/17 34/20
69/23 51/2 21/7 69/19 45/12
77/7 51/21 21/10 72/16 determinati
defender 51/23 24/8 72/19 on [1]
[1] 43/1 52/12 24/15 73/19 39/3
defense [9] 53/1 24/17 74/3 determined
30/1 30/1 deny [2] 25/14 depositions [4] 27/24
30/6 32/6 11/7 26/4 [6] 18/2 27/25
34/5 40/6 52/13 26/11 26/7 28/13
47/13 department 27/16 30/19 47/20
69/24 [5] 19/12 33/19 47/21 developed
71/16 24/3 33/22 70/18 [1] 47/2
defense's 29/21 36/16 70/19 devoid [1]
[2] 36/18 45/22 38/9 derived [1] 26/11
71/24 45/24 38/12 57/23 did [57]
deference depicted [1] 39/11 described 3/4 5/17
[1] 51/11 72/22 43/5 [4] 17/23 6/2 8/15
definitely depose [2] 43/15 24/25 8/18
[1] 67/14 19/7 52/1 44/16 43/4 43/5 10/20
definition deposed [2] 45/2 deserve [1] 10/25
[1] 27/10 36/3 45/13 44/22 11/2
37/21 46/11 desire [1] 14/15
D 52/16 39/1 40/9 16/3 discussion
did... [48] 54/17 40/17 16/22 [2] 18/4
14/16 55/7 55/9 40/19 directed [1] 28/3
14/21 59/11 42/10 53/3 dishonest
17/20 62/15 43/18 directly [4] [3] 19/15
22/19 62/18 46/15 50/20 20/9 28/4
25/18 65/24 64/11 57/23 dismiss [3]
26/5 66/1 72/9 61/7 63/9 27/19
28/19 didn't [39] DIERKER [2] disagreeme 27/19
29/8 30/7 3/15 3/17 1/14 nt [1] 58/8 46/19
30/7 30/8 3/18 4/19 47/19 discharged dismissal
34/12 6/13 8/11 difference [1] 21/22 [1] 47/18
34/14 10/13 [1] 5/13 disclose [4] dismissed
34/19 10/22 different 34/12 [2] 35/2
35/3 35/5 12/12 [16] 3/20 34/14 35/12
35/5 35/6 13/21 5/11 34/19 Dispatch
35/7 35/7 14/22 16/20 47/4 [2] 65/17
35/8 14/23 18/12 disclosed 67/6
35/25 15/13 23/16 [2] 26/7 disprove [2]
36/1 36/5 15/17 29/17 28/14 12/19
36/7 15/19 41/7 disclosing 33/9
36/15 15/21 41/17 [1] 18/24 disproved
37/21 15/22 41/18 disclosure [1] 12/18
39/5 15/22 42/20 [2] 18/22 dispute [2]
39/15 16/10 42/21 26/14 21/25
39/22 17/1 43/6 49/6 disclosures 33/14
39/25 17/24 50/23 [1] 5/18 disputed
40/2 18/3 19/8 52/24 discovery [4] 21/22
40/17 19/25 52/25 [6] 21/8 25/12
40/19 23/9 difficult [1] 21/11 25/17
44/1 47/4 30/20 70/13 24/6 25/20
51/7 30/22 diminish [1] 26/12 disputes [2]
52/13 32/15 41/4 68/24 26/7
52/15 33/23 direct [4] 70/7 35/10
38/21 15/1 15/9 discussing disseminati
[1] 42/10 on [ 1 ]
D 70/18 38/15 DOWD [3] 48/25
disseminati does [8] 41/1 41/3 1/19 1/20 drying [1]
on... [1] 3/4 13/11 41/13 40/7 17/21
49/14 35/17 42/14 down [21] dually [1]
district [1] 49/9 42/15 5/9 8/12 63/25
27/2 53/16 48/22 8/23 9/8 duces [1]
do [27] 54/20 49/16 9/9 10/2 52/22
3/15 7/3 55/20 49/16 14/4 14/4 due [1]
8/23 15/5 56/20 52/4 15/20 42/7
17/19 doesn't [6] 53/16 15/23 dump [1]
19/11 18/17 55/10 16/11 49/7
19/13 20/12 56/3 16/16 DUNN [3]
22/12 44/15 57/17 17/7 1/24 77/2
23/7 44/15 58/9 18/10 77/15
23/15 64/12 61/10 22/23 during [12]
28/9 69/25 62/12 23/13 12/6
34/20 doing [4] 64/4 29/10 12/23
37/1 37/3 17/17 67/15 40/15 29/13
37/11 21/2 67/15 44/5 29/13
37/16 29/16 67/19 44/13 50/19
39/18 52/5 67/23 51/14 52/14
40/10 don't [45] 67/24 draft [2] 63/9 64/3
40/19 5/1 9/2 71/11 53/15 64/6
49/5 50/7 9/8 9/9 74/20 58/9 66/25
55/7 10/19 75/1 drafts [2] 67/17
56/20 11/3 11/5 75/20 7/16 7/20 72/19
57/18 13/12 donations dragged [1] duty [4]
68/11 14/8 14/8 [1] 64/21 44/11 39/25
70/13 14/9 done [5] drastic [1] 47/3
77/3 19/14 8/21 8/22 47/17 57/12
document 20/15 47/2 drilled [1] 57/24
21/13 49/18 22/23
[1] 75/2 E
documents 29/1 29/3 68/12 driven [1]
29/4 doubt [1] 49/23 e-mail [8]
[2] 70/17 52/13
37/10 9/24 drop [1]
E effort [1] 45/6 61/3 46/11
e-mail... [7] 4/22 end [6] entity [1] 49/23
52/15 egregious 2/11 8/22 58/24 53/3 61/2
52/18 [1] 20/7 8/22 equipment 65/6
52/20 eight [3] 29/14 [1] 2/22 68/25
52/24 14/1 33/1 66/4 ERIC [4] 69/2 69/3
53/3 15/14 ended [1] 1/8 2/4 evening [3]
62/22 70/19 50/13 20/21 47/23
66/18 either [4] endorsed 77/7 63/19
e-mails [5] 17/16 [1] 36/6 Especially 72/16
51/6 21/3 21/4 enforce [1] [1] 61/4 event [2]
51/18 51/7 50/1 essentially 5/8 74/2
51/21 elected [1] engaging [2] 21/16 events [2]
52/16 19/16 [1] 25/23 51/2 45/5
52/17 element [2] enjoy [1] established 62/18
E.G [6] 35/11 25/22 [1] 67/5 ever [7]
16/1 16/1 35/25 enough [3] establishin 3/10 4/20
16/21 elements 19/12 g [1] 5/17 8/21
17/20 [3] 34/17 24/14 estate [1] 13/13
20/21 34/20 47/13 68/11 17/18
25/16 34/22 entered [1] even [23] 46/5 46/6
E.G.'s [1] elicit [3] 48/13 14/24 every [10]
15/6 25/1 55/3 entire [6] 15/13 2/17 8/20
each [2] 59/1 11/4 15/17 11/20
23/6 elicited [2] 21/15 15/20 12/9
23/20 20/6 43/9 69/3 20/5 27/18
earlier [5] 63/11 69/21 20/15 33/20
6/2 7/16 else [3] 70/12 21/23 42/22
18/3 18/3 20/10 entirely [3] 30/1 30/2 42/23
37/5 39/13 3/20 30/3 44/23
Ed [1] 40/7 43/24 42/20 30/20 45/17
edification else's [1] 42/21 37/5 everybody
[1] 68/10 14/22 entitled [3] 39/14 [2] 17/16
EDWARD [1] elsewhere 27/13 41/19 66/21
1/19 [2] 44/19 27/13 46/9 everything
[13] 4/15
E exact [1] 44/1 44/9 60/5 7/8 13/21
everything.. 59/4 44/17 extracted 18/3 20/4
. [12] 5/16 exactly [2] 45/17 [1] 74/18 20/4 20/5
9/5 12/22 52/3 exhibits [1] extraordina 21/19
12/25 62/23 63/22 ry [1] 26/18
16/2 26/6 examinatio exist [4] 44/19 26/24
27/9 n [3] 49/1 3/4 3/5 extremely 36/1 37/2
29/20 52/6 6/13 [2] 4/7 37/12
30/22 54/21 11/25 18/21 39/2
39/18 exceedingly exists [1] eye [2] 43/23
42/13 [3] 43/23 49/2 41/4 45/8
44/24 44/9 44/9 exorable 64/23 45/18
exceeds [1] [1] 22/14 52/15
evidence F
[15] 4/4 71/21 expectation 58/8
except [3] [2] 33/13 face [2] 62/20
4/21 4/23 74/14
5/12 6/15 8/16 35/8 64/6
57/21 explicit [3] 75/16 66/22
36/19 Facebookin
41/1 61/25 45/4 69/14
excited [1] 45/14 g [1] 71/18
41/21 37/12
41/22 25/25 51/5 failure [1]
exculpatory explore [3] faces [1] 45/7
44/25 20/13
48/19 [19] 2/21 43/24 fair [5]
14/10 51/15 FaceTime 59/13
49/2 49/8 [5] 18/10
70/17 16/12 61/16 60/24
32/13 explored 36/24 60/24
71/23 43/8 43/8
evident [1] 32/16 [1] 50/15 69/23
32/18 expressed 43/13 69/24
38/10 FaceTimed
ex [2] 32/19 [1] 6/14 fairly [2]
32/20 extent [7] [4] 18/6 19/5 66/3
13/15 36/24
45/1 38/4 48/18 fall [1]
38/25 56/17 37/2 37/8 54/20
ex-husban FaceTiming
d [2] 39/9 42/6 56/19 fallacious
42/25 57/2 [1] 18/5 [1] 4/6
13/15 fact [25]
45/1 43/2 57/16 fallout [2]
43/24 59/17 4/22 5/1 62/18
F fee [1] 19/1 25/6 36/25 6/21 7/23
fallout... [1] 54/20 financial [2] 45/25 8/8 15/15
65/18 feel [1] 59/23 flaws [1] 18/23
falls [1] 28/5 60/1 3/9 19/10
59/3 feeling [1] financially flirtatious 42/25
fan [1] 50/1 [2] 62/17 [1] 17/24 Forsyth [1]
69/22 fees [15] 65/18 fly [1] 1/20
far [5] 54/1 54/2 find [1] 18/17 forth [1]
46/11 54/3 54/7 3/18 focus [8] 49/23
47/15 56/13 finding [1] 8/10 forward [1]
63/2 56/14 21/23 34/11 35/12
67/11 56/16 fine [2] 36/2 36/3 found [4]
67/16 58/19 57/22 38/21 7/19
fashion [2] 58/25 59/18 38/22 19/23
17/15 62/16 firm [3] 38/25 30/6 43/2
74/7 65/17 64/11 39/4 four [6]
favor [1] 65/21 64/12 focused [1] 15/4
66/7 65/24 68/11 4/9 36/25
favorable 68/2 68/4 first [15] focusing [2] 37/2 37/5
[1] 19/24 few [3] 13/16 32/15 37/8
FBI [10] 2/20 43/4 14/15 33/17 37/13
6/21 7/23 45/5 15/25 follow [2] frank [1]
8/8 15/16 figure [2] 17/18 25/19 25/2
19/10 27/14 23/19 50/4 frankly [1]
21/21 64/10 27/24 follow-up 64/2
21/23 filed [8] 28/11 [1] 25/19 Friday [2]
22/25 2/20 2/21 30/21 following 38/9
23/1 24/3 4/24 6/14 40/25 [4] 2/1 38/17
fed [1] 7/9 6/20 6/23 41/6 45/2 29/11 friends [5]
federal [5] 7/2 71/6 48/16 32/1 53/9 4/14 4/23
19/22 filings [1] 53/23 foregoing 13/12
20/24 73/1 56/11 [1] 77/9 42/13
23/3 23/4 final [1] 56/12 form [1] 42/13
23/5 7/16 five [5] 6/2 54/9 front [2]
finally [2] 15/4 22/1 former [7] 49/21
F gain [1] Gardner's gentleman 5/2 14/12
front... [1] 60/1 [19] 6/7 [2] 21/15 55/14
64/8 GARDNER 14/1 14/9 21/20 55/16
Fry [1] [40] 1/13 14/25 get [26] given [4]
1/18 2/16 3/4 15/1 15/3 4/25 16/8 18/21
full [4] 4/12 4/19 15/9 17/24 33/5
19/17 6/1 6/4 15/23 19/4 41/12
21/8 6/13 7/10 16/3 16/4 27/14 68/5
21/11 11/12 16/22 29/16 gives [1]
69/23 11/14 17/10 30/8 52/9
function [2] 11/17 17/19 32/15 go [10]
57/3 12/4 14/4 32/9 35/19 3/25 6/3
59/18 14/19 32/12 39/1 39/5 7/15 8/4
funds [4] 16/11 32/18 40/1 45/3 16/16
58/4 61/1 17/19 35/17 46/15 21/14
61/18 17/23 44/2 44/8 47/6 29/16
61/24 18/8 Gas [1] 48/10 29/18
further [8] 18/19 22/5 56/9 61/5 35/12
40/21 19/16 gathered 65/1 67/10
48/2 48/7 20/4 20/5 [1] 39/10 67/10 goes [13]
52/10 21/3 gauze [1] 67/15 5/17
53/6 67/2 21/12 16/18 69/15 16/16
71/8 77/9 22/4 gave [12] 69/24 26/4 30/5
furtherance 27/16 9/24 71/1 42/23
[1] 22/9 39/16 22/20 71/14 42/24
40/25 23/9 76/1 43/7
G 41/9 29/21 gets [3] 46/18
gag [9] 41/25 34/2 34/4 22/16 60/17
2/25 19/3 45/20 34/5 26/3 61/17
48/4 45/20 34/13 29/12 65/14
48/12 45/21 34/23 getting [4] 67/18
49/3 45/21 36/8 36/8 18/24 67/20
49/22 46/5 46/8 36/11 19/3 39/8 going [46]
50/2 50/4 47/2 47/9 gee [1] 47/5 2/12 4/1
71/5 47/14 15/2 give [4] 5/23 8/3
G 67/9 government 51/21 hair [1]
going... 67/10 [1] 19/25 77/7 17/21
[42] 11/7 67/14 governor grilled [1] half [4]
12/16 68/5 [8] 3/21 11/25 14/15
14/2 71/14 4/15 18/9 gross [3] 50/12
14/12 73/11 49/11 21/3 50/13
17/7 75/15 49/18 46/17 70/2
20/14 gone [3] 49/20 46/20 hand [5]
25/22 4/15 49/7 50/2 55/6 grossly [3] 5/23 8/3
28/1 28/2 64/3 governor's 18/12 10/1 65/2
29/21 good [5] [2] 48/16 27/3 27/3 65/2
30/19 19/12 66/10 ground [1] hands [2]
30/24 20/17 graciously 21/4 16/18
30/25 20/18 [1] 74/3 guarantee 16/19
39/16 72/21 Grand [3] [1] 43/1 handwritte
39/17 73/25 3/13 3/22 guess [3] n [4] 6/6
40/5 40/6 got [21] 45/8 7/25 12/9 47/7
40/11 3/1 3/5 granted [4] 17/24 47/9
40/18 3/19 5/5 32/25 36/15 happen [5]
40/20 10/6 10/7 36/17 guidance 5/25
44/14 10/9 66/10 [3] 48/4 20/11
44/22 15/17 69/23 48/11 62/17
45/5 18/2 29/2 grave [1] 52/9 65/18
45/14 29/19 6/14 guilty [4] 70/20
48/15 30/8 greatly [1] 21/3 happened
48/24 30/21 4/4 21/24 [4] 37/7
50/14 36/20 GREITENS 35/3 40/16
50/20 42/12 [11] 1/8 35/13 45/3
50/20 43/14 2/4 16/6 guy [1] 67/16
52/4 53/7 43/19 17/14 23/6 happy [3]
57/5 57/8 18/6 11/4
55/16 H
55/17 61/17 20/21 35/18
64/2 32/13 had [82] 62/8
62/2 hadn't [1]
65/21 gotten [2] 35/12 hard [1]
4/9 17/12 51/18 68/12 50/1
H 47/6 47/21 65/21 24/21
harm [1] 47/13 75/8 65/24 25/1 25/5
44/10 49/3 49/7 75/18 68/2 25/9
harsh [1] 49/12 he [173] her [75] 25/11
12/14 49/18 He'll [2] 3/12 3/23 25/16
has [64] 50/5 59/20 4/4 4/13 25/20
2/25 2/25 50/19 60/8 4/15 4/17 27/3
3/21 4/6 51/1 51/4 he's [6] 4/19 4/23 29/12
4/9 6/19 53/1 42/3 5/6 5/10 33/11
12/4 53/16 51/20 8/10 33/23
13/25 54/4 61/24 11/15 34/22
14/1 54/10 61/24 12/6 35/2 36/5
15/25 54/10 65/9 13/12 36/20
18/23 63/8 64/3 68/11 13/12 41/1 42/9
20/7 21/4 64/12 head [1] 15/19 42/13
22/2 24/1 65/8 19/17 16/1 16/1 42/16
25/10 67/15 hear [6] 16/8 42/16
28/7 28/7 68/7 27/22 16/14 42/23
28/9 68/23 28/1 28/9 16/18 42/24
32/10 70/2 71/9 36/12 16/19 43/5 43/7
32/22 71/11 72/9 17/3 17/6 43/12
33/12 71/12 73/21 17/15 43/14
36/2 74/3 heard [1] 17/19 43/22
36/25 74/21 30/3 17/20 44/4 45/1
37/3 75/23 hearing [4] 17/23 45/13
37/10 hasn't [1] 1/11 11/5 18/4 45/15
38/21 55/8 48/7 76/2 18/10 46/15
41/1 have [115] heart [1] 18/10 47/2 47/9
41/25 haven't [4] 46/18 18/11 71/10
42/11 56/2 69/3 heck [1] 18/16 75/13
42/20 71/19 10/10 18/20 75/15
44/11 72/6 held [1] 21/15 here [14]
44/19 having [5] 31/1 22/13 19/9 20/3
47/2 47/2 15/15 help [4] 24/14 25/6
44/11 48/21 24/17 39/18
H 11/19 himself [2] 25/14 28/16
here... [10] 11/20 23/15 25/17 28/16
40/7 11/21 50/3 26/17 28/23
45/19 11/22 hired [5] 33/24 32/7
51/14 12/1 2/9 7/23 41/23 37/20
55/17 12/13 19/11 41/23 38/1 38/5
57/20 13/22 45/19 45/2 46/1 39/14
61/10 15/19 68/11 46/4 50/2 39/23
64/23 16/7 his [60] 50/20 40/5
73/14 17/16 3/3 3/18 51/14 40/22
74/21 21/23 6/21 6/22 53/4 40/25
75/7 24/1 7/12 7/21 54/10 46/23
Here's [2] 26/19 7/25 9/24 54/11 48/1 48/3
41/3 30/4 11/16 57/9 59/6 48/8
64/16 36/24 11/22 61/3 61/7 49/10
hereby [1] 37/2 37/8 12/21 61/17 50/8 50/9
77/3 40/15 13/1 13/8 61/17 52/8
herself [5] 42/1 42/4 13/17 65/24 52/20
6/2 6/5 45/4 46/9 13/20 66/2 53/13
27/5 46/10 13/23 67/22 54/17
43/16 50/6 13/23 68/8 54/22
44/6 50/17 13/24 68/13 55/14
hidden [3] 50/20 13/25 72/18 56/25
4/4 4/5 57/4 14/2 14/5 home [3] 58/8
4/11 57/10 14/8 15/6 15/7 59/11
hiding [1] 59/10 14/18 73/16 60/5
41/21 59/16 14/21 HON [1] 60/16
highlighted 60/3 14/24 1/14 60/25
[4] 14/16 60/23 15/24 Honor [55] 61/20
14/17 61/7 17/21 2/6 9/23 63/4
14/25 61/15 22/4 22/5 11/23 64/20
15/6 64/13 23/10 19/21 65/4 66/8
him [40] 65/22 23/12 20/17 66/15
7/9 7/18 68/11 23/17 20/22 66/20
70/5 24/4 26/25 67/1 67/3
H 33/23 how [17] 18/11 28/1
Honor... [8] 33/24 4/1 4/2 18/11 34/12
68/11 45/5 11/25 18/20 35/18
69/22 67/18 14/2 18/23 35/23
70/9 70/19 22/23 43/22 35/23
70/21 house [35] 24/10 45/1 46/7 38/5
73/9 2/23 3/6 24/11 hyperbole 38/13
73/23 3/14 3/22 24/12 [1] 4/3 38/22
4/6 5/3 25/10 38/25
73/24 I
74/11 12/16 27/23 39/16
18/22 34/14 I'd [7] 39/23
Honorable 46/23
[1] 1/2 26/6 26/8 37/24 40/3 40/5
26/23 57/13 51/10 40/6
honored [1] 55/23
20/23 42/19 59/9 40/11
48/11 66/16 56/6 40/18
hoping [1] 65/16
73/19 48/17 66/17 44/22
49/12 66/24 66/16 45/9
hotel [3] 74/20
7/15 49/18 huge [10] 45/12
21/17 51/5 5/13 7/22 I'll [11] 52/4
52/25 13/7 5/20 7/15 54/25
28/17 7/15 7/16
hour [7] 61/5 14/20 55/16
62/15 41/21 13/22 55/17
7/3 8/9 53/7 62/8
22/1 62/19 42/16 56/8
62/23 42/16 70/23 56/20
22/18 73/14
33/19 63/18 43/18 63/13
63/23 46/17 73/21 69/22
39/11 74/9
41/12 64/1 64/8 69/22 72/9
hours [14] 65/23 hugely [3] I'm [46] 72/20
65/25 16/23 3/25 4/3 72/20
2/23 7/21 5/23 8/3
9/13 9/14 66/1 72/5 16/23 72/25
72/8 45/17 10/15 73/11
10/10
21/8 22/2 72/12 hundred [1] 14/2 73/24
72/13 5/11 14/12 74/8
23/12
33/23 72/17 husband [8] 15/15 74/25
74/5 13/15 20/14 75/7
I 40/12 incumbent 17/4 50/3
I'm... [1] 63/5 [3] 22/10 19/18 innocuous
75/18 importantly 22/11 26/1 [3] 43/14
I've [7] [1] 16/5 28/5 28/10 45/11
14/25 impression independen 33/5 45/11
15/10 [2] 28/18 t [1] 48/15 36/14 inoperable
30/3 29/25 indicate [1] 37/20 [1] 28/12
57/14 inability [1] 13/12 38/12 inquire [1]
64/25 45/15 indicated 38/14 68/9
70/25 inaccurate [3] 3/13 38/16 inquired [1]
73/16 [2] 3/6 21/25 38/17 27/7
idea [2] 52/20 52/15 38/19 inquiring
71/18 incident [6] indictment 39/7 [1] 72/19
73/25 36/22 [4] 27/19 39/10 inquiry [2]
identificatio 36/23 33/7 42/6 26/3 66/7
n [1] 37/11 33/10 42/18 insisted [1]
74/14 43/8 43/8 33/18 43/21 22/18
Identify [1] 43/13 individual 43/24 instead [1]
20/18 including [1] 21/13 44/2 69/15
identifying [4] 2/22 individuals 44/17 instruct [1]
[1] 51/6 11/23 [1] 20/23 47/20 57/13
identity [1] 27/15 indulge [1] 49/7 51/1 instructed
71/10 61/16 53/17 54/6 55/4 [15]
immediatel income [1] indulgence 55/9 55/9 50/16
y [2] 47/23 26/22 [1] 70/1 57/22 55/12
64/6 incompeten inferences 57/23 57/9 58/3
impeached ce [2] 21/2 [1] 34/7 59/2 60/5 58/15
[1] 25/9 21/3 information 61/3 58/20
important incompeten [44] 2/22 66/17 59/10
[8] 16/12 t [2] 27/3 8/12 68/17 59/16
16/24 40/4 10/10 72/5 72/8 60/3
17/1 incredible 12/17 72/12 60/10
17/11 [3] 6/21 12/18 initial [1] 60/14
20/8 20/9 12/14 14/22 32/23 60/21
44/20 15/17 innocence 62/24
[2] 49/22
I 5/5 5/24 20/4 46/7 3/24 2/24 3/6
instructed.. 6/1 6/1 intricate [1] 10/17 it [208]
. [2] 66/2 7/3 7/17 47/1 19/20 it's [37]
67/7 8/9 8/21 introduced 38/4 3/13 3/25
instructing 8/22 8/23 [1] 48/20 44/23 5/8 5/12
[1] 56/21 9/11 11/4 invade [1] issue [17] 5/19
instruction 11/8 11/9 56/18 27/15 12/14
[2] 54/14 12/5 12/6 investigate 32/21 14/13
64/16 12/23 [1] 21/13 37/7 47/5 14/20
integrity [1] 13/2 investigatio 47/11 16/10
63/6 13/11 n [4] 8/11 50/9 16/17
intended 13/24 19/11 51/15 17/13
[1] 71/6 14/14 24/2 29/3 52/21 22/11
interactions 14/18 Investigativ 53/23 24/8
[1] 3/21 16/5 e [4] 14/13 56/11 26/13
interest [4] 16/10 63/18 62/3 65/1 26/15
54/20 17/4 64/1 64/8 65/2 29/11
60/17 22/18 investigator 66/13 37/6
60/24 24/19 [4] 2/9 71/11 37/17
67/12 24/23 7/23 71/12 41/11
interesting 24/24 45/19 74/17 44/9 56/6
[1] 24/20 28/20 45/25 issues [14] 57/12
interestingl 29/13 invite [1] 18/13 57/22
y [1] 24/13 29/14 23/18 25/13 58/2 59/7
interjected 36/5 36/7 invited [2] 36/20 59/18
[1] 25/6 42/11 65/7 65/9 39/2 39/2 60/25
Internet [1] 43/12 involved [1] 50/14 61/2
43/17 43/19 19/22 50/23 61/21
interplay 44/3 46/9 involvemen 51/3 63/6 66/4
[1] 48/11 interviewed t [2] 22/5 51/12 70/4 71/5
interview [1] 6/4 59/15 51/15 71/9
[44] 2/17 interviewin ironically 51/16 73/19
4/10 4/13 g [1] 23/1 [1] 49/6 68/22 74/1 75/7
4/16 4/18 interviews is [169] 69/2 69/4 its [1] 2/24
[3] 12/22 isn't [5] issuing [2] itself [1]
I 77/2 23/9 20/10 69/1
itself... [1] 77/15 23/23 22/12 K.S.'s [9]
7/13 Judge [13] 24/16 27/2 3/10 3/21
1/2 3/13 25/2 25/3 11/12
J K
4/8 5/14 26/13 14/10
JAMES [2] 5/19 8/3 26/18 K.S [35] 17/3 19/7
1/18 1/18 10/8 26/24 2/18 3/8 33/8
January 10/11 29/2 4/12 5/4 33/10
[13] 4/13 11/4 29/11 5/13 6/4 74/5
4/17 6/5 12/20 35/24 7/17 keep [4]
6/5 6/6 19/14 39/3 11/11 10/18
6/7 7/4 20/2 39/14 12/19 19/18
10/5 41/11 41/1 12/22 32/15
14/19 judicial [2] 42/12 14/14 34/8
43/12 1/25 49/3 43/4 15/17 keeping [1]
43/19 jury [7] 43/19 16/5 64/21
44/2 3/13 3/22 44/7 16/20 kept [4]
46/10 37/4 44/14 17/14 4/24
January 37/15 45/1 45/5 18/23 29/16
24th [4] 37/15 45/12 18/24 47/4 47/5
6/5 6/7 39/3 45/8 46/24 19/6 21/7 keys [2]
14/19 just [57] 51/16 22/20 10/18
44/2 2/23 3/12 52/11 24/8 45/3
January 29 3/23 4/3 52/19 24/12 kids [1]
[2] 10/5 4/13 5/5 55/14 25/15 68/13
43/12 5/19 6/17 61/11 26/3 KIMBERLY
January 6/18 7/6 63/8 26/18 [1] 1/13
29th [4] 8/12 8/21 66/15 29/12 kind [2]
6/5 6/6 9/18 9/20 67/13 36/17 39/24
7/4 46/10 9/25 10/6 69/3 39/11 50/19
Jefferson 10/7 12/4 70/11 40/7 kissing [1]
[3] 48/15 12/12 71/8 42/14 43/5
48/24 16/21 75/24 44/4 51/7 knew [9]
63/7 17/9 justice [4] 51/20 11/19
JENNIFER 22/21 19/15 52/18 17/5 18/2
[3] 1/24
K knowing [1] 24/22 latitude [1] 45/25
knew... [6] 12/16 laptop [5] 36/17 50/23
18/25 knowledge 7/16 7/19 latter [1] 51/5
23/23 [12] 7/21 8/1 38/10 leave [1]
30/15 33/11 46/1 laugh [1] 74/9
30/18 51/8 last [15] 56/5 leaves [1]
46/14 51/24 3/1 3/19 laughing 42/24
46/15 53/2 53/2 4/24 10/9 [4] 5/10 left [6]
know [26] 57/9 59/6 17/25 42/9 56/1 8/14 8/16
3/15 59/8 61/7 37/20 75/21 8/18 9/12
10/19 68/8 73/3 38/9 laughs [1] 13/5 13/7
13/21 73/8 38/17 5/10 leg [1]
13/25 known [5] 40/25 laughter [1] 17/15
15/13 23/10 42/12 71/25 legal [12]
15/13 23/12 43/19 law [4] 56/13
15/18 23/16 45/1 20/9 56/14
27/23 24/5 46/16 20/22 56/16
29/1 29/3 66/23 69/7 54/5 58/19
40/20 knows [7] 72/16 64/12 58/25
41/6 2/14 lasted [1] lawyer [9] 60/9
41/13 21/10 9/13 5/6 5/10 60/13
45/11 57/2 lastly [1] 17/3 42/9 62/16
46/25 61/21 47/11 61/3 65/21
55/7 61/23 late [6] 3/5 61/17 65/24
55/10 66/21 4/24 62/9 68/2 68/4
55/24 68/5 26/13 65/20 legally [1]
52/2 52/3 65/24 58/4
55/25 L
56/3 68/24 lawyers [2] legislative
lack [1] later [9] 22/24 [1] 50/6
56/19 48/12
57/17 7/21 33/1 67/4 let [5]
Laclede [1] 36/25 lay [1] 4/1 11/20
57/17 22/5
57/18 37/3 37/9 least [9] 41/1 44/6
language 37/13 9/13 9/14 48/6
62/12 [1] 74/22 43/4 45/4 18/7 22/1
74/20 54/16
lapse [1] 61/4 26/9 36/2 let's [4]
L light [3] 20/15 35/24 M
let's... [4] 51/3 52/6 43/5 48/4 41/15 made [32]
15/5 69/2 48/11 42/19 4/22 4/22
45/18 like [15] lived [1] 46/1 46/6 4/23 5/12
56/23 4/3 12/15 15/14 69/3 72/6 13/15
65/1 18/9 LLP [1] looking [5] 16/1 16/1
level [1] 24/16 1/20 13/18 16/6 16/8
15/7 35/24 long [2] 21/16 18/9 22/1
levels [1] 36/24 5/17 74/6 35/21 24/14
15/8 45/7 longer [2] 48/3 24/21
lie [7] 7/14 46/23 12/2 48/21 25/9
8/1 9/21 51/10 27/25 looks [2] 26/25
11/20 52/11 look [16] 5/6 5/10 32/8 38/2
11/22 55/23 9/18 9/23 lot [4] 42/17
19/19 56/6 10/11 10/10 43/13
23/10 59/10 12/2 36/17 45/10
lied [13] 65/16 12/23 36/20 45/11
7/25 66/16 14/20 49/7 45/13
11/17 limited [2] 14/22 LOUIS [10] 49/3
18/3 59/8 15/4 1/1 1/16 54/17
21/21 68/21 17/10 1/19 1/21 61/2 62/5
42/22 limiting [1] 23/18 1/25 7/22 62/7
43/12 52/6 29/9 15/14 63/23
45/25 line [1] 30/20 19/12 65/23
46/1 46/2 10/11 30/22 24/3 77/5 66/23
46/2 46/3 listen [1] 44/18 low [5] 68/23
46/4 46/5 8/21 44/18 2/20 4/5 75/10
lies [8] listened [3] 73/12 6/19 6/25 made-up
7/11 7/12 8/13 looked [14] 7/7 [1] 4/23
11/22 23/22 7/25 14/5 lunch [1] magically
14/8 23/23 17/20 7/15 [1] 3/1
19/10 listening [1] 17/20 lunchtime mail [8]
20/3 22/5 42/8 23/6 [1] 46/2 52/13
42/22 little [5] 23/20 52/15
15/15 33/1
M 44/15 34/18 23/3 me [23]
mail... [6] 46/23 36/23 25/10 13/13
52/18 48/13 37/2 37/7 25/21 16/6
52/20 52/16 37/11 27/12 28/16
52/24 66/1 60/19 35/4 71/4 29/14
53/3 makes [1] 61/13 material [4] 30/7
62/22 72/21 March 19th 16/23 35/21
66/18 making [2] [1] 2/15 38/24 40/3
mails [5] 40/10 March 21 47/13 40/10
51/6 69/23 [1] 13/8 49/1 40/11
51/18 malfunction March 21st materials 47/12
51/21 ed [8] [2] 36/23 [3] 47/4 48/6
52/16 2/19 2/23 37/2 47/7 53/17
52/17 6/17 March 21st 49/14 54/16
major [1] 24/18 incident matter [1] 54/19
3/9 27/24 [1] 37/11 58/9 55/14
make [23] 27/25 March 21st matters [1] 60/6
28/6 28/6 32/21 of [1] 61/25 62/17
29/19 41/16 37/7 may [18] 65/5
29/22 malfunction March 24 2/7 4/2 65/18
30/4 ing [2] [1] 13/15 4/22 5/19 66/24
30/21 32/24 March 24th 6/17 9/5 68/18
30/21 33/4 [1] 13/19 19/6 19/7 69/25
30/25 man [4] Market [1] 24/4 76/1
34/8 19/11 1/15 34/14 mean [1]
35/24 22/7 22/7 MARTIN 34/15 64/13
36/9 24/1 [16] 1/18 37/6 meaning [1]
37/15 many [3] 2/5 9/5 38/14 10/25
39/3 20/13 9/12 39/21 means [3]
39/16 29/17 10/19 47/19 5/11 37/5
40/3 64/25 21/7 56/1 60/5 63/13
40/11 March [11] 21/23 67/16 meant [4]
40/15 2/15 13/8 22/9 maybe [2] 15/14
44/15 13/15 22/17 5/11 15/19
13/19 22/23 65/15 32/24
M mentioned mischaract moment [2] 25/3
meant... [1] [1] 45/6 erizing [1] 55/15 27/13
33/3 mentioning 62/22 73/23 43/6
media [2] [1] 4/20 misconduct Monday [8] 44/10
13/16 mentions [3] 21/2 29/22 45/11
71/1 [1] 68/7 46/18 30/14 45/11
media's [1] Metropolita 46/21 30/15 47/13
71/14 n [1] misinforma 30/18 50/9
meeting [1] 19/12 tion [1] 47/20 67/14
43/3 MICHELLE 3/8 50/13 74/1 74/5
members [2] 1/19 misreprese 52/22 morning [7]
[1] 63/25 54/4 ntation [1] 68/25 20/17
memo [2] middle [2] 75/21 monetary 20/18
3/17 53/8 21/4 missing [3] [1] 26/22 21/3
memorand 66/22 41/13 money [4] 25/15
um [10] midnight 41/14 56/16 55/19
6/1 12/22 [2] 10/9 41/14 56/24 69/15
13/1 13/8 14/16 MISSOURI 58/19 71/1
13/11 might [1] [6] 1/1 62/10 most [6]
13/24 42/19 1/5 1/16 month [2] 4/9 17/1
14/3 minute [4] 2/4 72/14 2/15 4/11 18/4
14/17 2/17 5/9 77/7 months [7] 28/10
14/21 14/2 misspeak 23/14 36/2
15/24 55/17 [1] 23/9 36/22 44/20
memory [9] minutes [7] misspoke 36/25 mostly [2]
9/19 9/20 16/15 [1] 22/22 37/3 37/5 49/23
13/23 27/6 misstateme 37/8 72/20
13/24 32/23 nt [1] 37/13 motion [16]
14/5 41/11 52/12 more [19] 1/11 2/7
14/22 41/13 MO [3] 2/12 3/10 2/8 2/20
22/21 41/14 1/16 1/19 10/8 15/7 2/21 5/1
23/13 41/17 1/21 19/15 5/20 6/14
24/22 mischaract mocked [3] 20/9 6/20 6/23
mention [1] erized [1] 6/18 6/24 22/16 7/2 7/13
3/18 62/21 7/5 24/25 27/18
M 13/14 72/21 68/17 72/7
motion... 13/17 73/12 68/19 Mr. Tisaby
[3] 48/7 13/18 Mr. [44] 70/25 [1] 4/19
49/6 14/14 2/5 4/19 71/4 72/7 Mr. Watkins
55/19 14/17 9/5 10/19 73/25 [16]
motions [1] 15/12 21/7 74/2 50/16
4/25 16/6 21/23 Mr. Bennett 51/14
mountain 16/13 22/9 [1] 48/9 52/21
[1] 42/17 17/2 22/17 Mr. Ed [1] 53/5
move [3] 17/14 22/23 40/7 56/17
17/22 18/6 18/8 23/3 Mr. Martin 57/5 59/1
17/22 18/19 25/10 [14] 2/5 59/5
45/18 19/4 25/21 9/5 10/19 59/15
movement 19/18 27/12 21/7 60/2
[1] 32/25 21/6 33/19 21/23 62/20
movie [1] 21/13 33/23 22/9 66/2
59/25 21/14 34/25 22/17 68/17
MR [67] 27/7 29/8 35/4 35/4 22/23 68/19
1/14 1/18 29/14 40/7 23/3 73/25
1/18 1/18 32/8 32/8 46/12 25/10 74/2
1/19 2/14 32/11 48/9 25/21 Mr.
3/3 3/17 32/13 50/16 27/12 Watkins'
4/12 5/21 32/17 51/14 35/4 71/4 [1] 58/1
5/24 6/6 35/12 52/21 Mr. Mrs. [2]
6/13 7/3 36/3 53/5 Rosenblum 51/18
7/7 7/12 37/18 55/16 [10] 51/21
8/4 9/12 39/12 56/10 33/19 Mrs.
10/1 41/10 56/17 33/23 Greitens
11/11 41/22 57/5 58/1 34/25 [2] 51/18
11/14 42/7 58/14 35/4 51/21
11/16 42/25 59/1 59/5 46/12 MS [63]
11/25 45/16 59/15 55/16 1/13 1/19
12/7 12/8 47/5 47/9 60/2 56/10 2/16 3/4
12/21 55/17 62/20 58/14 4/12 6/1
72/4 66/2 70/25 6/4 6/7
M 41/25 multiple [8] 65/19 22/20
MS... [55] 44/2 44/8 4/25 5/20 65/20 24/25
6/13 7/10 45/19 5/21 8/9 66/8 68/6 25/3
11/12 45/20 11/6 69/20 NASSER [8]
11/14 45/21 11/17 70/2 71/5 1/19 21/9
11/17 45/21 19/10 71/9 22/9
12/4 14/1 46/5 46/8 19/10 72/11 22/17
14/4 14/9 47/2 47/9 multiple-ho 73/3 73/9 23/5
15/1 15/2 47/14 ur [1] 8/9 73/16 50/10
15/23 50/10 multitude 74/13 66/16
16/3 16/3 66/16 [1] 7/11 74/17 66/19
16/11 66/19 must [1] myself [8] nature [2]
16/22 Ms. [6] 4/2 22/8 16/13
17/10 3/21 4/19 my [39] 22/17 24/23
17/19 14/19 7/15 7/15 29/7 need [11]
17/19 14/25 7/16 8/25 29/25 5/15 19/6
17/23 15/9 8/25 9/20 39/24 19/6 19/7
18/8 17/14 20/15 50/10 19/14
18/19 Ms. 21/1 27/4 56/3 20/11
19/16 Gardner 35/5 71/19 27/14
[2] 4/19 39/25 30/25
20/4 20/5 N
21/3 21/9 14/19 40/15 43/24
Ms. 50/1 naked [3] 53/7 75/4
21/12 43/11
22/4 22/9 Gardner's 55/10 needed [1]
[2] 14/25 56/14 43/15 47/14
22/17 43/17
23/5 15/9 56/25 nervous [1]
Ms. K.S [1] 57/1 name [3] 16/2
27/16 52/23
32/9 17/14 57/12 never [27]
Ms. K.S.'s 60/6 53/1 53/2 5/22 5/24
32/12 named [1]
32/18 [1] 3/21 61/12 6/10 6/10
much [4] 61/15 63/25 6/11 6/22
35/16 names [2]
39/16 5/14 61/21 6/23
12/18 61/23 51/6 73/4 11/21
40/25 narrative
41/9 45/10 63/11 13/14
45/11 65/10 [4] 14/13 13/20
N 69/7 32/18 nobody [3] 32/13
never... nine [7] 32/19 41/15 32/19
[17] 9/12 21/8 32/19 41/23 33/9
15/24 33/19 32/20 63/2 33/13
15/24 33/22 32/23 nonaudio 33/16
16/5 16/7 33/23 32/25 [1] 41/11 33/16
17/12 33/24 33/5 nonconsens 34/1 34/3
21/1 39/11 33/19 ual [3] 34/4 34/9
26/25 nine-hour 38/1 38/5 3/23 34/9
29/24 [2] 33/19 40/8 12/20 34/20
29/25 39/11 40/14 26/10 34/25
30/2 30/2 no [66] 40/22 none [1] 35/10
30/3 1/7 5/22 41/24 73/10 35/11
41/24 7/20 8/11 42/6 nonexistent 35/14
42/4 45/6 8/11 42/15 [1] 3/19 36/1 36/1
52/17 10/21 45/23 normal [1] 37/1 37/3
57/8 10/24 47/15 49/8 39/9
new [2] 10/25 48/8 50/7 normally 40/16
38/18 11/6 12/2 51/8 51/8 [4] 29/4 45/3
68/24 13/6 51/23 29/4 49/2 64/22
next [7] 13/24 53/2 70/19 74/21
12/7 15/10 56/14 not [148] noticed [1]
16/13 15/20 57/19 note [3] 2/7
42/1 46/8 20/6 21/4 57/20 12/9 notwithstan
46/10 22/13 59/7 17/13 ding [1]
58/23 23/24 59/24 35/15 6/21
74/8 24/1 61/21 notes [105] now [28]
night [9] 24/18 70/4 4/21 5/23
3/1 3/19 25/2 71/11 nothing 8/2 11/5
4/24 10/9 27/25 71/15 [32] 8/16 13/25
17/25 28/19 71/18 9/18 14/12
42/12 28/19 72/2 73/5 11/21 16/25
43/20 29/11 73/8 13/5 14/5 17/10
46/16 29/12 75/22 18/11 18/5
32/17 77/8 19/15 20/12
N 36/18 52/13 51/25 69/16
now... [18] 52/16 52/25 occasions 73/22
26/13 53/12 72/19 [2] 55/7 officer [3]
32/14 53/24 object [1] 72/18 22/10
33/7 55/7 58/6 74/19 oddly [2] 40/6
34/11 58/16 objected [3] 15/12 40/18
34/14 72/17 50/16 15/12 official [2]
36/2 41/7 numerous 60/2 off [16] 1/24 77/4
41/18 [2] 23/25 62/20 16/2 often [1]
41/25 29/17 objection 16/14 12/6
[8] 54/14 17/6 25/9 oh [3]
42/18 O
52/6 54/18 29/16 25/2
o'clock [5] 56/17 29/21 41/16
56/20 3/2 9/12
63/6 64/2 9/15 10/9 57/19 30/5 30/8 57/16
64/5 70/2 51/14 59/1 30/9 40/1 okay [11]
70/3 64/16 43/14 9/11
oath [22] 67/16 44/4 48/7 52/10
73/19 7/12 7/18
Nowhere 72/3 64/5 70/2 54/7
9/22 objections 70/3 55/15
[2] 13/7 11/16
13/11 [1] 63/3 offense [1] 56/11
11/22 obligation 47/1 57/16
nuance [1] 18/23
61/22 [1] 57/12 offenses [1] 61/20
19/10 observation 20/24 65/13
nude [4] 21/16
18/7 s [1] 46/24 offer [1] 67/22
21/23 obtained 69/14 67/25
25/17 22/12
33/12 [4] 2/25 offered [1] 70/15
26/16 39/7 67/24 once [3]
35/7 26/17
numb [1] 66/24 office [10] 22/16
26/21 69/16 1/15 6/24 40/1 74/1
3/14 41/22
number obvious [1] 19/17 one [35]
41/24 19/5 30/15 5/1 12/2
[14] 2/3 45/2
10/11 obviously 30/18 14/15
50/25 [4] 19/2 33/22 15/4 15/7
24/9 25/3 51/3
32/4 32/8 51/22 25/8 36/9 16/25
48/25 40/16 17/3 17/3
O 66/22 23/19 16/15 43/2
one... [27] 66/23 24/7 19/24 43/17
17/3 17/3 66/24 27/12 20/6 48/23
17/12 only [22] 28/8 20/14 49/12
18/4 8/21 10/9 32/22 22/14 61/1 61/2
18/18 13/24 33/6 23/6 61/22
19/5 14/5 35/20 23/16 61/23
22/19 14/15 36/4 23/17 64/11
24/16 14/21 55/23 23/20 68/11
28/19 15/1 56/6 30/7 39/2 out [28]
28/19 16/15 69/21 41/5 44/5 3/11 3/18
29/2 29/3 22/10 69/23 46/4 4/1 4/6
29/12 27/1 27/3 72/12 46/14 5/2 5/3
32/10 29/20 order [15] 46/15 7/11 7/13
32/11 36/7 2/25 19/3 51/3 12/16
40/16 38/22 31/3 48/5 56/13 13/5 13/7
41/12 41/10 48/12 57/22 16/1 18/5
43/3 41/20 48/17 58/10 19/25
44/20 44/3 48/23 59/25 20/2
47/12 50/14 49/3 63/24 27/14
50/9 51/17 49/17 69/2 69/4 40/9 41/1
54/23 52/20 49/22 71/15 41/2 41/4
55/1 65/6 71/23 50/2 50/4 otherwise 42/3
67/13 74/4 63/23 [4] 23/2 42/17
73/18 open [3] 71/5 35/15 42/24
73/23 2/1 32/1 71/10 55/8 50/6 63/5
one's [2] 53/9 organized 58/10 70/17
29/11 operable [1] 10/8 ounce [1] 71/5
41/4 [3] 28/14 original [1] 32/11 75/24
one-on-on 30/16 19/3 our [17] out-of-cou
e [2] 17/3 47/21 other [32] 5/13 19/3 rt [1] 71/5
17/3 opinion [1] 2/7 3/8 19/14 outfit [1]
online [4] 36/18 5/9 6/17 20/9 16/20
64/5 opportunity 13/23 27/18 outside [1]
[13] 16/6 16/9 29/2 29/2 61/21
O Oversights' 10/16 46/14 19/17
over [35] [1] 63/18 11/23 77/9 participate
4/11 5/6 overwhelmi 12/1 12/2 paid [7] [1] 42/11
5/24 6/3 ng [1] 12/21 18/24 particular
10/7 70/5 12/24 22/2 [4] 20/16
12/10 own [5] 13/22 43/23 20/25
12/17 13/25 15/25 43/25 53/2 53/3
13/17 17/19 Page 113 62/16 particularly
13/17 46/15 [1] 8/7 64/9 [5] 18/21
17/7 19/1 65/19 Page 115 64/11 22/11
19/22 68/10 [1] 8/19 pales [1] 24/20
21/8 27/9 P page 117 8/1 24/24
28/20 [2] 9/10 paper [1] 26/15
P.S [12] 13/22 8/16 parts [1]
29/20 18/22
30/5 page 13 [1] paragraph 14/25
21/10 8/5 [3] 15/5 party [4]
37/24 26/5
38/4 page 159 15/25 62/16
26/16 [2] 12/21 16/14 65/9
38/12 26/16
39/23 12/24 part [7] 65/10
45/1 page 174 22/3 66/14
39/24 50/11
40/2 40/7 50/24 [1] 10/12 38/10 past [1]
40/20 Page 189 40/17 4/13
52/12 [1] 10/16 48/6 pay [4]
42/21 53/25
43/17 page 293 64/17 56/14
54/10 [2] 12/1 67/20 56/16
46/12 64/8
46/16 12/2 70/1 56/24
P.S.'s [2] page 294 partially [6] 58/19
47/6 47/9 50/16
47/24 [1] 11/23 18/7 paying [2]
72/17 pages [9] 33/12 56/13
50/7 pad [1]
52/21 5/23 9/21 35/7 58/25
10/1 11/18 43/11 payment [2]
70/7 page [13]
Oversight 12/5 43/15 26/22
8/5 8/7 13/25 43/17 54/4
[2] 64/1 8/19 9/10
64/1 14/1 participant payments
10/12 14/15 [2] 5/16 [3] 51/1
P 44/24 71/20 51/2 56/7 8/3 14/21
payments... 60/20 picture's [1] 57/5 41/20
[2] 51/13 61/14 56/4 59/22 56/3
54/9 personally pictures [1] 63/5 74/19
pen [1] [1] 45/20 42/2 64/14 portions [1]
10/1 phone [1] place [2] 64/15 14/17
pending [1] 21/17 33/12 64/16 position [5]
49/13 photo [3] 48/5 65/15 55/20
people [5] 33/10 Plaintiff [2] 65/16 56/25
20/14 40/8 1/6 77/7 66/9 61/1 61/2
29/17 40/14 plan [1] 66/10 73/24
30/8 photograph 72/19 68/7 possession
62/10 [3] 43/9 planning 68/12 [2] 69/19
75/2 55/18 [1] 68/11 69/18 69/20
percent [1] 72/23 play [1] 71/14 possible [2]
68/16 photograph 11/4 71/17 10/17
perhaps [1] s [3] 9/23 playing [4] 71/24 38/6
48/15 10/3 6/18 6/25 72/21 possibly [3]
perjury [14] 43/16 7/6 19/20 75/23 3/6 11/25
7/11 9/22 photos [1] please [2] point's [1] 36/19
12/13 73/5 32/4 71/3 37/22 Post [3]
19/9 21/4 phrasing pleasure [1] pointed [1] 65/17
21/5 22/8 [2] 59/5 74/13 3/11 65/20
22/13 59/9 plus [1] pointing [2] 67/6
27/4 physical [1] 17/3 11/15 Post-Dispat
27/11 36/20 point [30] 41/4 ch [2]
28/4 physically 16/20 points [1] 65/17
41/23 [1] 34/16 27/22 17/11 67/6
46/24 picked [1] 28/7 police [5] potentially
46/25 57/16 30/25 7/24 [1] 21/17
pernicious picture [7] 34/16 19/12 practice [2]
[1] 22/16 5/6 5/8 37/18 24/3 6/23 21/1
person [4] 5/8 35/6 37/19 45/22 practiced
30/6 41/16 38/10 45/23 [1] 23/4
55/25 39/6 47/8 portion [5] practicing
[1] 20/22
P 61/6 71/1 35/8 problem [3] producing
preamble 71/4 private [4] 41/10 [1] 47/14
[1] 8/16 preserving 2/9 7/23 58/1 59/7 Professiona
prejudice [1] 63/1 19/11 problems l [1] 77/2
[5] 47/12 press [13] 45/19 [2] 46/17 proffers [1]
47/15 4/8 6/19 privilege 61/21 23/2
52/2 52/3 6/25 7/6 [13] 54/6 proceed [1] projector
52/5 17/13 55/5 39/21 [2] 27/23
preparation 19/20 56/18 proceeding 28/11
[1] 47/16 42/18 58/5 60/2 [1] 49/3 proper [1]
prepare [1] 62/13 61/2 proceeding 24/5
69/24 62/14 61/11 s [10] 2/1 properly [3]
prepared 64/18 61/11 31/1 32/1 33/4
[1] 47/8 64/19 61/19 33/17 54/24
preparing 64/20 61/22 53/9 63/6 58/12
[1] 73/15 65/11 62/25 63/7 proposition
prepostero pretty [2] 65/2 65/6 74/23 [1] 58/6
us [3] 20/13 privileged 77/6 propounde
22/23 70/4 [1] 54/6 77/10 d [7]
25/21 previously privy [2] process [7] 53/25
45/24 [2] 2/13 64/5 21/9 55/3 56/5
presence 47/10 66/11 21/15 57/1
[4] 22/13 print [1] proactively 22/3 58/11
25/16 64/4 [2] 21/5 26/12 67/17
25/17 prior [9] 27/5 26/12 75/23
27/4 12/6 probably 28/10 prosecuting
present [6] 36/15 [2] 20/12 70/5 [1] 22/11
24/16 38/12 66/20 procured prosecution
37/14 38/13 probe [1] [2] 60/6 [3] 27/19
53/18 39/6 39/7 57/22 63/12 49/13
53/21 63/20 probed [2] produced 49/15
64/3 77/6 65/19 54/21 [4] 3/1 prosecutor
presented 66/6 68/14 47/6 [10]
[4] 55/18 privacy [2] probing [1] 47/15 19/16
33/13 67/12 69/6 20/9 21/1
P 24/6 26/1 Q 60/24 11/1 11/2
prosecutor. 26/20 question 61/4 61/6 11/6
.. [7] 23/4 50/22 [60] 8/8 61/9 11/13
23/5 68/24 8/15 8/20 61/12 11/19
23/22 69/1 9/2 10/20 61/12 15/21
27/1 27/2 public [10] 10/22 61/15 20/6
28/4 18/5 43/1 10/25 62/9 64/9 23/24
68/25 48/13 12/3 65/3 66/3 23/25
prosecutori 63/15 12/13 67/4 25/4
al [2] 63/23 14/7 67/17 34/13
46/18 64/18 22/19 67/19 34/14
46/21 64/19 22/20 67/25 36/18
prosecutors 65/6 65/8 25/5 25/6 68/2 69/5 46/3
[2] 19/23 75/24 27/8 72/1 50/15
41/18 purports [1] 46/11 72/11 50/18
protect [2] 54/5 55/6 73/8 51/4 51/9
57/24 purposely 55/11 75/22 53/17
71/10 [1] 26/2 56/2 56/5 75/22 53/24
protected purse [1] 56/12 question's 53/25
[5] 5/15 10/18 56/12 [1] 59/6 54/12
57/20 pursuant 56/15 questioned 54/23
58/4 61/1 [1] 52/22 56/19 [6] 24/12 55/3
61/18 purview [3] 56/21 24/21 57/14
protection 54/5 57/1 57/6 24/23 58/11
[1] 44/23 56/18 57/12 25/11 58/11
protective 57/9 57/18 25/20 60/7 62/1
[1] 71/10 put [10] 58/2 58/3 26/16 74/22
protracted 4/6 5/3 58/13 questioning quite [1]
[1] 66/3 8/15 58/18 [1] 25/1 64/2
prove [1] 12/16 58/19 questions quotations
35/14 23/13 58/23 [36] 7/4 [1] 15/2
provided 28/6 29/8 59/5 7/8 7/9 quote [10]
[9] 6/10 44/4 59/21 8/10 7/18 14/3
6/11 6/12 68/13 60/12 10/14 14/3 14/3
75/24 10/23 15/9 16/1
Q 19/20 53/1 29/6 Registered
quote... [4] 19/21 recess [1] recordings [1] 77/2
16/20 44/22 28/2 [1] 29/2 rehabilitati
16/22 reality [1] recessed redacted on [1]
44/7 4/3 [3] 69/10 [1] 73/4 27/7
62/23 realization 69/12 redepose related [1]
quoted [3] [1] 66/9 69/19 [5] 2/8 48/14
19/7 really [2] record [18] 19/4 19/6 relates [1]
46/12 23/20 20/19 19/6 57/23
65/25 64/11 27/17 27/12 relating [1]
quotes [2] reasons [1] 28/6 28/6 refer [2] 62/18
15/1 16/3 24/9 29/4 13/22 relationship
rebut [1] 30/25 55/14 [1] 44/13
R 26/7 32/4 reference release [9]
raise [1] recall [5] 39/17 [1] 75/4 19/2
62/2 2/7 5/19 44/22 referenced 62/13
raises [1] 6/17 7/13 52/12 [1] 71/20 62/14
50/23 32/14 53/4 53/7 references 63/15
rather [1] recalls [1] 53/11 [1] 56/1 63/21
47/1 2/3 55/2 62/4 referred [2] 64/18
reaction [2] received [9] 62/5 25/21 64/19
36/21 26/22 66/16 47/7 64/20
36/21 49/1 72/2 referring 65/11
read [6] 50/19 recorded [1] 13/1 released
36/4 50/25 [4] 24/18 reflected [10]
37/25 54/10 29/15 [2] 12/22 13/16
62/23 54/11 30/1 30/2 13/8 31/3
65/22 59/14 recorder [5] refused [1] 63/14
69/3 69/8 2/19 51/2 63/19
72/16 69/11 28/21 regard [2] 63/24
reading [1] receiving 28/23 28/3 72/5 72/8
63/9 [3] 51/1 28/24 48/22 72/13
ready [1] 66/17 30/11 regarding 73/6
56/8 70/18 recording [2] 14/14 73/10
real [3] recently [1] [2] 28/18 64/17 relevant [9]
21/11
R repercussio 77/3 77/3 respect [7] resume [3]
relevant... ns [1] 77/4 42/7 22/4
[8] 26/15 20/11 reporting 51/12 50/11
34/16 report [28] [1] 75/9 53/25 68/21
34/17 2/24 3/7 represent 59/15 review [5]
37/7 4/7 5/3 [2] 20/23 62/22 24/7
37/16 12/17 49/25 68/20 32/22
37/17 14/6 representat 70/9 55/24
37/24 14/13 ion [4] respectfully 69/21
73/4 16/25 71/25 [1] 20/10 74/4
relied [1] 18/22 74/17 respond [6] reviewed
24/1 19/2 25/9 74/24 48/16 [4] 13/14
remain [1] 25/10 75/10 48/24 15/10
35/3 25/12 representat 49/11 46/4
remedy [1] 25/25 ions [1] 49/18 70/12
47/17 26/6 26/8 71/13 51/11 revisit [1]
remember 40/6 Representat 73/7 27/18
[4] 4/19 42/19 ives [2] responded Rex [1] 1/2
42/14 44/15 63/24 [1] 28/12 ridiculous
42/15 46/4 72/13 responding [2] 6/16
74/25 48/12 represented [2] 48/14 17/6
remembere 48/17 [3] 41/25 51/8 right [29]
d [1] 4/17 49/12 68/18 response 12/7
remove [1] 63/19 71/16 [5] 32/6 27/21
22/6 63/21 reproductio 40/23 39/12
removed 63/22 n [1] 40/24 42/1
[1] 25/16 66/21 77/10 72/1 42/18
remunerati 66/23 request [4] 75/21 46/8 46/8
on [5] reported [2] 19/4 restrict [1] 46/10
50/18 17/13 28/11 52/4 47/22
54/4 77/6 55/18 restricting 48/2
54/10 reporter [6] 70/25 [1] 48/13 49/11
59/23 1/24 required [1] result [2] 50/5 53/6
60/1 53/18 70/7 60/10 53/7
53/21 reschedule 60/14 54/13
[1] 74/6
R 11/11 48/22 26/18 34/23
right... [14] 21/18 running [1] 30/4 34/23
54/19 22/25 41/16 36/11 34/24
28/17 37/5 34/24
55/1 S
56/20 ROSENBLU 39/18 34/25
M [13] said [67] 41/10 35/3
59/4 2/17 2/18 41/15
59/13 1/18 1/18 36/10
4/14 4/16 43/3
63/5 67/9 20/20 4/18 5/1
36/12
67/21 33/19 44/19 45/15
33/23 5/21 6/13 45/1 45/2 45/17
70/23 6/20 7/2
73/11 34/25 45/23 49/20
35/4 7/15 7/20 51/18 59/5
74/23 8/24 9/16 51/20
75/3 46/12 59/17
55/16 11/13 55/10 60/4
75/14 11/21
75/17 56/10 57/16 60/16
58/14 12/22 59/5 60/22
rights [3] 12/25
48/16 70/25 65/21 66/4
72/7 13/8 71/13 sanction [1]
49/21 13/21
50/3 rough [1] 71/15 46/20
13/24
rigorous [1] 58/9 14/5
71/17 sanctionabl
49/8 round [1] 71/22 e [1] 27/11
22/2 14/21 71/24 sanctions
rings [5] 15/13
13/10 routinely 74/18 [4] 2/10
[1] 28/25 15/16 75/5 75/9 2/12 4/2
16/18 15/17
16/19 RPR [2] 75/11 19/4
15/24
17/8 44/6 1/24 75/25
16/6 16/7 salon [1]
sat [15]
road [1] 77/15 8/8 8/12
rubbed [1] 16/8 16/9 43/4 11/16
23/14 16/9 17/2 same [23]
ROBERT [2] 17/14 18/18
11/20
1/14 1/14 rule [2] 22/17
33/8 11/22
romantic 20/8 70/7 33/20 12/4
23/20
[1] 17/24 rulings [1] 23/24
33/22 15/12
room [5] 68/20 33/24 20/4 20/5
run [2] 25/2 33/25 21/6 22/8
11/10 25/17
48/17 34/22 23/22
S 44/22 11/12 75/1 73/17
sat... [3] 47/11 20/20 75/24 sentences
45/25 51/7 57/15 seeks [2] [1] 66/18
46/8 62/18 57/16 56/18 separate [2]
46/10 67/14 scream [1] 59/1 10/18
saw [7] saying [15] 49/22 seemed [3] 31/2
15/24 3/8 6/24 scrutiny [1] 24/22 series [2]
29/24 7/6 12/19 49/2 41/23 54/11
30/2 33/1 16/8 19/8 seal [2] 65/5 55/13
46/5 27/8 48/6 71/7 seems [6] serious [3]
62/12 38/13 seated [2] 4/8 19/5 4/2 20/11
62/14 40/3 32/4 37/23 46/25
say [30] 44/14 63/25 47/12 session [1]
9/5 9/12 45/16 second [6] 55/24 32/3
15/22 64/20 1/25 15/5 66/7 set [5]
16/10 68/3 15/25 seen [3] 7/13
17/2 73/24 43/3 11/18 28/17
17/19 75/1 45/10 14/9 29/7 62/9
17/21 says [8] 55/2 71/19 64/13
25/3 3/15 7/7 see [21] selected [1] sets [1]
25/12 17/13 7/9 7/16 45/20 6/10
25/18 38/4 9/25 sell [1] setup [1]
26/6 42/25 11/14 23/21 29/8
34/11 43/16 29/15 send [1] severe [3]
35/5 35/6 45/22 30/22 52/15 2/12 28/3
35/7 35/8 45/24 32/22 sending [3] 28/5
35/17 scheduled 32/24 51/18 sexual [4]
37/21 [2] 50/10 36/7 40/9 51/21 25/23
40/8 73/18 42/2 42/2 52/13 36/21
40/14 Schwartz 49/17 sent [6] 45/4
40/16 [1] 1/18 55/18 43/17 45/14
42/8 scope [1] 55/21 51/7 sexually [2]
42/15 26/3 56/6 71/3 52/17 34/15
44/3 44/8 SCOTT [5] 72/12 52/18 34/15
1/18 74/14 73/16 shaking [1]
S shortly [1] shows [13] 52/11 60/10
shaking... 9/17 3/5 3/9 68/23 60/14
[1] 16/2 shots [1] 3/12 3/23 72/15 six [2]
she [176] 10/1 5/8 13/16 sinister [1] 10/10
she's [14] should [11] 13/18 19/3 15/5
5/7 5/10 18/16 23/25 sir [18] slap [6]
16/14 21/14 24/10 7/20 8/25 4/10 4/18
16/19 27/18 24/11 8/25 9/7 4/21 5/4
17/16 32/25 24/12 10/21 13/13
17/18 35/2 26/23 10/24 42/14
17/18 35/11 75/2 10/25 small [1]
18/5 35/12 shut [1] 13/3 13/6 41/20
33/20 59/5 18/10 30/17 smiling [2]
33/25 64/22 side [1] 30/20 64/24
42/10 70/22 20/13 38/7 75/13
43/6 74/15 signed [1] 39/20 sneaking
44/23 shoulder 45/21 53/12 [1] 17/7
45/16 [2] 13/17 significance 53/14 so [64] 3/7
sheepish 13/18 [1] 12/16 67/22 5/2 8/8
[1] 17/20 shouldn't significant 72/20 9/11 9/13
shipped [1] [1] 66/11 [4] 4/1 73/13 12/20
19/25 show [6] 5/12 sit [4] 9/4 18/11
shock [1] 5/20 6/12 18/13 9/4 9/4 19/2
17/17 14/2 18/21 12/12 20/14
shop [1] 18/12 silence [1] sitting [8] 29/3
59/22 58/10 12/13 3/4 12/7 29/19
shopped [1] 75/15 simply [2] 27/2 29/21
26/17 showed [2] 16/10 29/10 30/4 33/5
shopping 18/10 39/5 29/11 33/15
[5] 18/20 21/23 Simpson [1] 41/25 34/1 34/7
18/25 showing [1] 11/12 42/1 43/2 34/19
43/21 22/4 since [6] situation 36/12
43/22 shown [3] 40/3 [5] 20/7 37/21
50/24 3/7 6/19 40/10 47/2 38/11
25/10 50/22 47/12 38/17
S 74/4 75/4 37/4 37/6 32/23 61/18
so... [42] 75/18 63/12 55/25 61/23
38/20 75/24 63/19 71/20 speak [1]
40/2 41/6 solely [1] 66/10 75/3 75/6 66/16
46/11 57/23 someone sorry [2] speaking
47/6 some [27] [3] 32/25 72/9 [2] 24/13
47/15 3/11 3/22 56/23 72/20 67/5
47/17 4/1 11/13 65/20 sort [2] specific [2]
48/21 18/1 27/6 something 41/1 72/1 45/12
48/22 28/5 [18] 34/8 sorts [1] 54/11
50/1 34/16 36/16 7/8 specifically
51/10 36/4 38/15 sought [4] [5] 16/7
52/4 52/5 36/14 38/18 55/3 21/21
53/17 36/19 38/18 59/22 25/11
54/13 36/21 39/23 59/22 27/7
54/19 36/23 40/1 71/9 50/18
56/3 56/6 38/9 39/6 40/19 sound [3] specifics [1]
56/11 41/11 42/24 4/3 18/9 62/12
57/14 44/5 56/1 45/7 56/2 43/13 speck [2]
57/15 56/4 56/6 56/19 sounds [1] 41/4 41/5
59/4 59/6 60/1 57/17 59/10 spend [1]
59/13 63/12 64/17 source [17] 74/5
61/2 63/20 68/5 26/22 spent [1]
61/12 65/15 71/13 26/23 65/19
63/19 68/7 72/1 74/17 51/13 spoke [1]
65/19 74/17 75/5 53/25 51/16
66/6 67/9 somebody something' 54/2 54/3 spoken [1]
67/16 [5] 43/11 s [1] 75/25 54/3 54/4 4/14
67/18 56/13 Sometime 54/7 spontaneou
68/2 68/7 56/15 [1] 9/17 54/20 s [1] 64/7
69/24 58/18 sometimes 58/4 squarely [1]
70/10 65/23 [2] 23/14 58/25 59/3
71/10 somehow 23/14 61/1 ST [8] 1/1
73/20 [7] 23/13 somewhere 61/15 1/16 1/19
36/16 [6] 11/23 61/16 1/21 1/25
S 27/21 stay [2] 41/18 50/13
ST... [3] 28/1 28/2 34/22 43/6 submit [1]
19/11 28/7 28/7 34/23 story [21] 47/17
24/3 77/5 28/9 32/6 STEELE [11] 3/12 3/13 suborned
St. [2] 37/23 1/14 3/20 4/23 [3] 12/13
7/22 38/2 38/3 37/18 17/6 21/5 27/4
15/14 40/21 39/13 18/16 suborning
St. Louis [2] 46/22 41/10 18/20 [1] 27/10
7/22 49/7 42/7 18/24 subpoena
15/14 49/10 42/25 18/25 [1] 52/22
stand [1] 55/20 45/16 23/9 subsequent
49/21 71/9 55/17 23/10 [1] 68/19
stands [2] 71/10 72/4 25/1 substance
58/6 71/12 72/21 26/17 [3] 8/23
72/18 72/13 73/12 40/17 38/23
stark [2] 73/2 77/7 step [2] 41/20 39/4
66/9 State's [1] 67/10 43/21 such [3]
72/18 49/6 67/11 43/22 12/16
start [4] stated [6] still [10] 45/15 36/20
14/20 15/6 5/6 5/8 45/17 51/3
17/5 15/11 10/1 50/24 suddenly
41/11 15/20 16/21 59/23 [2] 4/21
73/19 16/20 25/22 straight [1] 5/3
started [3] 25/14 43/24 7/11 suffered [1]
8/18 9/16 51/4 44/7 48/5 streamline 47/15
56/5 statement 71/18 [1] 57/15 suffice [1]
starting [2] [7] 39/18 73/15 Street [1] 26/6
9/15 40/15 stop [4] 1/15 suggest [1]
41/10 52/20 3/6 17/16 stretch [1] 20/11
state [27] 62/18 30/24 27/4 suggested
1/1 1/5 65/23 56/23 structure [2] 3/22
1/16 2/4 66/1 66/6 stopping [1] 49/8 74/3
20/24 statements [1] 41/10 stuff [1] suggestive
22/2 [2] 22/25 stories [3] 19/1 [1] 17/15
40/25 18/12 subject [1] supply [1]
S 48/14 70/14 65/14 28/19
supply... [1] 53/22 70/18 talked [6] 29/2 29/9
58/5 69/23 74/9 5/20 12/9 29/9
supplying surprise [2] 74/13 17/18 29/11
[3] 56/15 17/17 74/15 26/21 29/11
56/24 20/13 74/16 61/4 29/13
58/18 surprised 75/5 65/15 29/15
support [4] [2] 15/15 taken [13] talking [16] 29/20
4/23 17/22 16/14 5/4 5/5 29/25
21/25 swears [1] 33/10 5/7 9/3 30/2 30/3
23/10 22/12 33/10 16/12 30/11
27/18 sworn [2] 33/11 17/18 30/16
supported 27/1 33/12 18/8 18/8 30/21
[1] 24/14 39/18 43/9 26/15 30/23
supposed system [3] 43/10 35/23 32/21
[1] 15/16 19/15 46/2 46/7 36/24 33/1 33/3
supposedly 19/22 47/22 42/5 38/8
[6] 2/22 20/10 56/4 65/10 38/11
61/11 65/20 38/11
13/9 T
16/15 70/2 66/4 75/8 38/13
table [3] takes [2] talks [1] 38/14
16/19 29/12
17/8 44/6 5/22 5/22 38/16
43/2 75/2 41/24 tape [62] 39/15
sure [14] tacitly [2]
28/6 taking [1] 3/3 3/15 39/22
21/5 27/5 17/6 3/20 3/23 40/1 41/8
29/19 taint [1]
29/22 talk [12] 11/4 41/12
42/20 5/9 16/21 13/15 41/15
30/4 take [18]
30/21 20/14 16/13 41/19
4/1 6/23 34/19 18/1 41/20
30/21 9/2 9/4
34/12 40/13 23/24 41/21
11/5 12/1 40/16 23/25 47/21
39/17 16/1 35/5
45/9 42/6 44/8 25/8 52/2 52/3
39/18 44/14 28/13 52/7 56/3
45/12 66/18
48/10 45/7 28/13 69/6 69/8
68/1 53/24 28/17 69/18
T 14/7 17/6 23/13 70/24 58/7 59/4
tape... [6] 17/16 24/17 74/11 59/9
69/21 42/12 35/2 74/11 59/13
70/12 42/15 41/23 thanks [1] 62/6
71/14 43/6 45/13 47/14 62/23
71/20 45/16 62/21 that [542] 64/13
71/21 tells [1] 62/22 that's [50] 66/13
75/23 3/20 63/10 3/17 7/4 66/14
taped [5] tender [2] 64/3 64/7 8/18 9/15 66/24
2/17 4/16 52/2 52/3 72/17 15/22 67/1
16/18 tenor [1] 72/18 16/9 67/18
43/19 26/2 than [15] 16/22 70/10
46/6 term [1] 2/12 3/10 17/4 75/5
tea [3] 48/12 13/23 18/20 75/18
65/9 terms [6] 15/7 20/2 their [6]
65/10 32/24 19/15 23/19 4/6 5/3
66/14 33/3 33/7 20/10 25/1 26/6 14/11
tecum [1] 38/8 22/14 26/24 45/23
52/22 38/11 23/17 28/6 29/3 49/22
tell [12] 38/20 43/6 33/4 69/24
15/10 test [1] 44/11 37/16 them [20]
18/3 29/13 47/13 37/18 3/7 3/11
19/14 testified [5] 56/13 38/12 4/14 4/17
19/25 7/5 13/14 63/24 38/13 4/18
20/12 15/16 71/15 38/25 19/25
30/6 40/5 46/9 74/1 40/12 33/5 36/5
40/17 62/14 thank [13] 41/4 42/5 39/8 40/8
40/18 testify [2] 2/6 8/7 42/16 40/12
43/18 42/4 8/16 42/25 40/14
45/15 62/15 27/20 43/18 42/12
54/19 testifying 39/12 43/23 45/12
telling [10] [1] 41/22 50/8 52/8 44/8 45/6 55/14
4/18 7/19 testimony 53/8 45/24 55/14
13/12 [14] 3/10 58/23 52/19 58/11
8/20 70/21 55/1 55/2 58/17
T 39/9 39/1 42/6 40/18 17/12
them... [2] 40/14 44/6 63/6 42/15 18/1
73/17 40/24 67/10 43/3 44/7 18/18
73/17 41/14 they [52] 45/23 42/10
themselves 42/6 2/18 3/7 47/15 44/20
[1] 50/4 45/21 4/17 4/19 50/7 46/4
then [9] 54/11 5/16 6/13 63/22 48/20
2/23 9/15 55/13 14/8 14/8 63/22 54/23
16/12 55/17 14/9 15/1 63/23 57/15
42/5 56/4 15/2 17/8 66/11 62/16
42/13 58/16 19/23 70/18 65/17
51/21 63/4 19/23 73/17 70/20
56/22 71/15 19/25 75/10 think [26]
64/11 71/19 24/4 they're [4] 11/5
71/23 74/19 25/22 15/2 13/12
theorist [1] 74/21 32/20 36/23 21/14
24/11 75/4 75/5 33/6 33/8 40/10 27/13
there [79] thereafter 33/15 75/15 27/17
there's [38] [2] 9/17 34/7 thing [15] 37/10
9/24 11/6 64/7 34/11 4/8 17/1 37/14
13/5 32/7 these [22] 34/12 32/10 37/16
32/11 10/3 10/8 34/23 33/22 37/17
32/13 13/9 14/7 35/3 36/7 38/21
32/19 14/24 35/15 36/12 44/21
33/1 33/5 14/24 36/15 38/22 47/1
33/8 16/9 37/4 55/2 48/21
33/13 16/15 37/14 59/17 49/10
33/16 16/20 37/20 60/4 49/16
34/1 34/2 20/4 37/21 60/16 49/16
34/4 34/9 32/10 38/13 60/22 49/19
34/25 32/14 38/16 63/5 66/4 50/5
35/10 34/7 34/7 38/19 69/3 51/17
35/14 34/20 39/5 things [15] 52/4
36/14 35/24 40/14 5/11 10/2 53/16
36/22 40/17 13/7 66/8
T thought [7] till [1] timely [1] 21/6
think... [4] 7/13 7/22 10/8 74/7 21/13
66/18 17/8 time [36] times [9] 21/14
66/20 28/18 4/1 7/14 5/20 5/21 21/16
67/11 29/20 7/22 8/20 11/17 22/17
71/23 35/22 8/22 11/5 18/3 18/4 24/14
thinking [2] 44/7 11/20 25/11 24/21
16/21 three [7] 17/18 29/17 24/25
44/13 10/11 17/18 46/1 25/9
third [3] 15/4 15/7 20/15 64/25 25/12
5/8 62/15 23/19 20/16 timing [1] 25/14
70/3 37/2 21/19 19/1 25/18
this [166] 37/12 28/2 29/9 Tisaby [50] 27/7 29/8
those [21] 54/22 29/10 2/8 3/3 29/14
6/25 9/24 threw [1] 33/20 4/12 4/19 32/8 36/3
16/2 16/3 20/2 42/22 5/21 5/24 41/22
28/4 28/8 through 42/23 6/6 6/13 47/5 47/9
34/13 [12] 8/9 45/17 7/3 7/7 Tisaby's [9]
35/5 35/6 21/6 50/12 7/12 10/1 2/14 3/17
35/7 35/9 24/17 50/15 11/11 8/4 14/17
35/15 39/10 50/22 11/14 32/8
38/20 44/11 55/24 11/16 32/12
39/7 47/8 49/8 61/3 68/18 11/25 32/17
51/8 67/19 68/23 12/7 12/8 44/15
51/15 67/20 69/6 12/21 44/16
60/7 63/1 67/20 69/11 13/14 today [6]
63/13 72/4 72/8 71/20 13/17 2/8 2/20
68/21 throw [1] 72/15 13/18 3/25 9/21
though [5] 41/2 74/4 74/5 14/14 74/4
15/20 thrown [1] 74/12 15/12 74/12
20/15 42/20 74/20 16/13 told [22]
37/5 tied [4] 75/4 75/4 17/2 18/9 4/12 4/14
68/25 13/9 17/8 75/12 18/19 13/13
69/2 44/6 timeliness 19/5 13/20
67/18 [1] 70/7 19/18 17/16
T 15/23 63/16 64/12 40/20
told... [17] 27/5 63/17 64/13 44/14
18/19 41/24 63/21 67/5 46/12
20/3 42/4 44/4 66/23 67/19 46/16
24/17 top [2] 66/24 67/20 47/6 47/9
30/1 9/25 13/4 transmitted 68/6 68/8 47/24
33/20 totally [3] [2] 33/13 68/13 52/21
33/21 45/9 35/9 truth [1] turning [3]
33/22 45/14 transpired 43/18 19/1
33/24 45/15 [2] 34/18 try [1] 29/20
33/25 touch [1] 37/1 48/18 70/7
36/5 41/9 30/8 tremendous trying [9] turns [2]
42/12 touched [1] [1] 70/5 4/25 23/7 37/24
42/14 28/19 trial [3] 23/20 38/3
55/8 57/4 touching 47/12 34/8 38/5 TWENTY [1]
57/17 [1] 29/10 47/16 39/23 1/25
64/25 tough [2] 73/15 44/10 TWENTY-SE
tomorrow 49/3 49/4 tried [3] 57/15 COND [1]
[1] 73/18 trained [1] 18/9 73/15 1/25
tongue [3] 23/15 18/10 Tuesday [1] two [19]
64/20 transcript 21/25 62/13 5/9 6/10
64/22 [13] 1/11 trip [1] turn [4] 7/3 7/21
64/23 5/21 6/12 22/2 12/17 9/13 9/14
tongue-in- 8/4 11/3 trips [1] 30/5 9/25 15/4
cheek [3] 13/19 22/2 39/23 22/18
64/20 23/18 trouble [2] 40/2 22/20
64/22 31/2 75/8 turned [18] 41/7
64/23 58/10 75/19 3/16 4/11 41/12
too [1] 3/5 63/10 true [4] 5/24 10/7 41/17
took [12] 63/12 3/24 12/10 41/18
2/14 5/21 66/11 23/23 13/10 54/22
6/22 7/14 74/6 71/18 25/24 66/18
8/11 9/6 transcripts 77/10 27/9 70/2 70/2
9/25 [7] 46/6 trust [10] 38/12 70/19
63/14 7/24 62/9 39/24 two-hour
[3] 7/3
T 27/4 Undisclose 4/24 8/14 up-to-date
two-hour... 28/18 d [1] 8/16 9/12 [1] 26/13
[2] 22/18 29/25 21/19 17/25 uphold [1]
41/12 41/22 undressed 28/20 27/1
type [1] 41/23 [1] 25/15 30/2 30/3 upon [3]
8/11 45/2 unequivoca 46/16 22/10
typed [2] 50/25 lly [1] 47/22 22/11
14/18 51/3 25/14 51/2 57/6 27/5
15/1 51/21 unethical 63/14 us [30] 3/5
typewritten 52/13 [2] 40/13 69/19 4/4 4/5
[3] 6/8 52/25 40/19 71/23 4/11 4/11
6/9 47/8 54/5 60/2 unfamiliar unwelcome 4/24 5/2
typing [1] 61/1 [3] 22/24 d [1] 5/25 6/18
9/16 61/18 22/25 17/22 6/24 7/5
72/18 23/1 up [23] 7/19 7/25
U undercuts unfinished 2/7 4/22 11/17
U.S [2] [2] 4/4 [1] 16/17 4/23 6/19 12/18
23/3 14/10 unidentifie 9/16 10/8 13/20
23/11 understand d [1] 13/9 14/10
unbelievabl [11] 62/15 16/19 18/21
e [1] 44/10 12/14 unique [1] 17/8 19/18
uncertain 22/24 73/24 25/19 19/25
[1] 24/22 39/17 unit [1] 26/13 23/7
under [28] 39/19 29/3 28/17 23/20
7/12 7/18 48/4 unlawful [1] 29/7 23/21
9/22 48/18 63/12 29/12 26/1
11/16 64/12 unlike [1] 51/2 29/11
11/22 65/11 23/16 54/25 35/24
18/23 67/19 unnoticed 56/12 40/16
19/9 70/6 [1] 21/14 57/16 42/15
21/16 70/16 unredacted 61/11 42/18
21/22 understandi [2] 63/11 62/9 69/14
26/16 ng [3] 63/22 64/13 use [2] 3/6
26/17 69/4 71/9 until [17] 65/11 29/4
26/21 73/9 3/19 4/5 73/25 used [3]
U 63/4 32/19 45/9 50/3
violation [1]
used... [3] 70/13 38/9 39/8 49/17 51/15
13/23 74/7 42/2 visit [2] 53/23
14/5 vetted [1] 42/22 21/17 58/14
15/24 24/1 42/23 45/10 61/8
uses [1] vetting [2] 44/18 61/10
visitors [1]
28/25 21/15 45/8 47/6 19/24 61/16
using [1] 22/3 53/4 vital [1] 62/6 63/5
4/3 victim [3] 55/24 63/6 67/14
utilized [1] 2/18 5/16 56/2 voluntarily67/15
64/10 44/23 74/19 [2] 16/18 67/23
utilizing [2] victim's [1] 74/19 25/16 67/24
63/11 40/13 75/5 75/6 voluntary 68/1 68/8
63/12 victims [2] videograph [1] 45/15 69/5
5/15 er [1] 70/16
V W
44/22 24/16 75/20
variations video [37] videos [1] wait [1] 75/24
[1] 48/19 2/19 5/2 73/5 73/21 wanted [7]
verbatim 5/17 5/19 videotape waited [1] 10/17
[2] 62/24 7/7 7/9 [16] 2/25 57/6 11/15
65/25 10/4 3/9 3/19 waived [1] 16/21
verify [1] 11/14 4/10 6/11 65/6 30/21
71/15 13/16 6/16 6/19 waives [1] 48/10
versions [1] 14/9 10/5 63/2 58/3
41/7 15/11 11/20 want [33] 73/12
versus [1] 15/11 24/13 11/5 wanting [1]
2/4 18/18 24/15 13/21 72/21
very [11] 19/8 24/18 14/8 14/8 was [277]
2/11 25/18 27/23 14/9 wasn't [9]
12/14 26/14 50/23 20/14 7/21
14/10 26/18 69/1 74/5 27/22 19/12
24/12 27/15 viewed [1] 27/23 22/21
25/12 27/23 56/2 28/9 30/5 23/23
28/5 28/5 32/9 vile [1] 40/3 41/6 28/12
40/12 32/12 12/17 42/10 47/23
W 55/2 62/2 63/1 25/6 19/23
wasn't... [3] 57/11 64/21 27/20 19/24
57/11 57/14 64/21 29/1 20/6
57/17 58/2 67/10 35/19 22/25
69/18 63/12 67/11 48/25 23/1
watched [1] 63/20 67/14 51/15 25/22
22/8 70/20 75/8 52/19 28/18
Watkins 70/22 we've [6] 55/4 29/25
[16] 71/15 3/11 55/13 31/1 32/1
50/16 we [137] 18/14 58/16 34/23
51/14 we'll [5] 41/12 61/6 62/3 35/21
52/21 5/9 6/12 61/11 68/23 35/22
53/5 56/9 61/5 64/2 66/4 70/6 36/17
56/17 70/14 website [1] 71/11 40/1 44/7
57/5 59/1 we're [31] 21/17 went [13] 47/8
59/5 11/4 20/3 Wednesday 4/13 4/16 47/21
59/15 24/13 [2] 47/22 7/25 9/11 49/14
60/2 26/4 50/13 24/2 24/3 50/14
62/20 26/15 week [10] 29/15 50/15
66/2 27/13 29/23 44/5 52/16
68/17 27/13 29/24 44/13 53/9
68/19 27/20 30/2 30/3 44/24 54/23
73/25 28/2 37/20 45/3 55/3
74/2 29/10 38/9 45/22 60/18
Watkins' [1] 29/10 38/10 46/11 60/18
58/1 30/24 38/17 were [59] 60/19
way [18] 30/25 74/7 74/8 2/1 3/10 61/13
5/17 11/6 32/4 42/5 weeks [2] 3/23 4/12 61/13
15/6 48/3 23/14 6/18 6/25 62/17
15/10 48/21 43/4 7/6 7/9 63/14
20/9 48/21 well [19] 9/24 13/1 63/17
23/17 52/12 10/17 13/12 63/21
33/9 43/6 53/7 10/20 15/20 63/22
51/14 53/11 11/3 17/8 63/23
58/8 61/3 15/10 19/23 63/23
W 3/5 3/14 44/17 37/8 61/18
were... [8] 3/19 4/24 45/3 37/11 62/13
65/17 5/4 5/22 46/14 38/11 63/21
66/17 6/14 8/18 46/15 46/1 46/2 65/8
66/23 9/12 9/16 51/7 53/3 46/3 46/3 65/14
71/16 21/23 56/5 46/5 46/6 72/17
73/4 22/23 57/15 50/20 while [11]
73/10 23/23 61/11 50/24 3/4 9/2
73/17 23/24 62/14 51/12 11/17
73/18 23/24 65/6 74/7 13/9 18/6
what [92] 24/12 70/18 which [33] 19/3
what's [11] 24/20 74/18 5/23 33/11
14/12 24/23 where [12] 11/23 41/21
18/1 25/5 6/6 15/6 14/11 45/2
32/16 25/11 19/22 18/5 48/23
33/9 26/15 26/18 21/25 65/20
35/25 27/5 27/8 22/2 22/4 who [16]
37/24 27/24 33/12 23/11 4/12 11/8
48/24 28/11 35/16 23/13 11/10
50/6 28/11 35/16 25/24 11/17
58/13 28/13 56/3 25/25 11/18
67/11 28/14 58/11 26/9 11/19
75/23 28/17 74/19 26/12 11/19
whatever 29/19 75/18 32/12 15/18
[5] 38/14 30/10 whether 33/9 19/7
39/10 30/13 [23] 7/25 36/11 19/24
62/6 68/5 36/3 38/8 9/24 38/15 28/15
68/13 40/13 24/21 48/18 29/5
whatever's 40/19 24/24 50/12 43/24
[1] 39/7 41/24 24/25 50/23 53/18
whatsoever 42/5 42/9 25/20 50/24 53/21
[2] 52/5 42/13 26/16 50/24 68/4
73/1 42/25 32/21 51/5 54/5 who's [1]
when [55] 43/14 36/10 55/4 61/5 72/22
44/2 36/13 61/17 whoever [1]
28/9
W 40/15 72/22 33/4 47/17
whole [6] 43/16 73/16 57/15 48/17
8/25 9/1 willingly [2] 73/18 world [1] 48/18
29/10 44/5 44/6 witnessed 44/23 49/16
33/16 withheld [1] [1] 22/15 worry [1] 49/17
36/2 47/1 26/2 witnesses 18/11 50/1 52/1
whose [2] withhold [2] 19/23 worse [2] 52/2 52/5
28/21 [1] 73/11 49/25 22/16 52/11
74/14 within [7] woman [2] 26/3 53/17
why [8] 17/11 5/15 8/9 would [49] 53/17
14/7 24/8 41/16 woman's 5/12 7/3 53/19
39/23 41/21 [1] 44/21 9/12 10/8 58/10
40/2 42/6 won't [1] 11/18 60/1
41/13 54/20 5/6 12/18 62/13
47/22 55/4 57/9 wondering 23/18 68/19
47/23 without [9] [1] 72/25 24/4 68/21
54/19 21/8 word [1] 29/15 70/1
will [14] 21/11 27/18 29/18 70/12
2/11 2/17 22/18 work [12] 33/9 write [7]
7/12 19/5 31/3 16/16 33/15 8/23 9/8
20/12 33/11 19/8 33/17 9/9 13/23
32/3 44/10 29/17 33/18 14/5
32/14 49/1 49/2 30/7 30/7 33/18 15/23
35/3 71/6 39/15 34/1 34/3 15/24
58/21 witness 39/22 34/5 34/8 writing [3]
65/11 [16] 5/22 40/2 34/9 10/1
66/18 8/24 9/3 47/13 36/16 15/20
67/13 18/13 70/2 70/3 36/18 42/3
68/14 18/15 70/4 38/18 written [3]
74/16 18/16 worked [3] 39/23 5/25 6/7
William [1] 36/6 44/3 23/12 40/2 12/5
2/8 44/10 28/19 40/14 wrong [4]
willing [3] 52/1 58/3 30/7 42/21 12/20
5/16 58/14 working [4] 43/1 41/8
66/6 25/9 29/9 47/11 41/19
W 27/9 you [164]
wrong... [1] 30/17 you'll [5]
58/2 32/7 9/23 9/25
wrote [7] 37/17 12/23
8/15 14/4 38/7 32/22
14/4 39/20 35/19
14/14 46/13 you're [4]
16/11 53/12 9/15 16/8
16/13 53/14 67/9 68/3
46/4 55/22 you've [4]
65/4 66/8 7/19 8/22
Y 67/3 12/9 38/2
yeah [8] 67/22 your [91]
15/17 73/13 yourself [1]
40/24 yesterday 20/18
49/19 [13] 5/18
Z
59/7 10/6
64/15 18/22 Zero [1]
66/12 26/16 35/11
68/4 75/7 26/21
years [8] 50/12
15/15 53/1 62/5
20/23 62/13
20/25 63/9
23/4 23/5 63/19
23/6 69/9
26/25 72/13
43/1 yesterday's
yes [24] [1] 53/15
7/20 8/7 yet [3]
8/25 8/25 11/3
9/7 10/25 26/18
12/11 52/25
13/3 yield [1]
24/15 20/15