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Capital Reporting Company
Humphrey, Calvin Ricardo 06-15-2010
SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA
Civil Division
----------------------------:
ri GOVERNMENT STRATEGIES,
IC., et al.,
CONFIDENTIAL
Plaintiffs,
v. Civil Action No.
A. RAHALL, et al., 2009 CA 007515 B
Defendants.
----------------------------:
1posi tion of:
Washington, D.C-.
Tuesday, June 15, 2010
CALVIN RICARDO HUMPHREY,
lled for oral examination by counsel for the
fendant pursuant to notice, taken at the law offices
Nossaman LLP, 1666 K Street, NW, suite 500,
shington, D.C., before Marijane W. Simon, RDR, CLR,
Capital Company, a Notary Public in and
r the District of Columbia, beginning at 10:01 a.m.,
en were present on behalf of the respective part.ies:
448 - DEPO
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2010
.,
1
1 Q
2 A
3 I'm not
Capital Reporting Company
Humphrey, Calvin Ricardo 06-15-2010
November and December of 2008.
I was not in Washington most of that
aware.
time so
4 Q Well, who told you that that was the reason
5 why her performance was inadequate?
6 A I can't remember who specifically told me.
7 I just remember hearing that.
8 Q Okay. Do you know how many clients she
9 contacted during the months of November and December
10 of 2008?
11 A No, I do not.
12 Q Do you know what her duties were for RJI,
13 how she was spending her time during November and
14 December of 2008?
15 A I do not know how she was spending her time,
16 no.
17 Q Now, in paragraph 25 of the amended
18 complaint-- I'm just going to read it. I'll make
19 sure we don't get an objection here.
20 It says, In 2008, Defendant Rahall threatened
21 to undermine RJI's government relations business by
22 informing Mr. Humphrey that the, open quotes, doors on
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2010
104
Capital Reporting Company
Humphrey, Calvin Ricardo 06-15-2010
1 Capitol Hill will be closed to RJI and its employees and
2 clients if she did not receive what she wanted on
3 certain issues.
4 Tell me about that.
5 A That's a correct statement.
6
Q Okay. When in 2008 was that made?
7 A The summer of 2008.
8 Q Okay. While she was a consultant?
9 A Yes.
10 Q Okay. And, specifically, what did she want
11 on certain issues? What was she demanding?
12 A She wanted to be more included.
13 Q
More included in what?
14 A Speedy Funk.
15 Q Okay. And she said that the doors on
16 Capitol Hill will be closed to RJI. What does that
17 mean?
18 A You have to ask Miss Raha1l what she meant.
19 Q
I'm asking you because it's in your
20 complaint. It's in quotes. What does it mean to
21 close -- the doors on Capitol Hill will be closed to
22 RJI?
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2010
105