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IN THE CIRCUIT COURT OF THE FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA.
CASE NO.: 16-2007-CA-00575-MA
DIVISION: CV-C
NORTH FLORIDA SCHOLARSHIP )
ORGANIZATION, INC., a Florida )
Not-For-Profit Corporation, )
Plaintiff, )
vs. )
MISS FLORIDA SCHOLARSHIP PAGEANT, )
INC., a Florida Corporation, )
d/b/a The Miss Florida Pageant; )
JENNIFER HERRINGTON; JACKSONVILLE )
SCHOLARSHIP FOUNDATION, INC., a )
Florida Not-For-Profit Corporation, )
VOYAGER INFO-SYSTEMS, a California )
Business, d/b/a VoyForums.com; and )
GLOBAL GUEST, d/b/a AmazingForums.com, )
a Foreign Business, )
Defendants. )
_______________________________________)
DEPOSITION
OF: PATTY ADEEB
Taken on behalf of the Plaintiff
DATE TAKEN: Tuesday, May 14, 2009
TIME: 9:50 AM - 12:45 PM
PLACE: Verbatim Reporting Services
233 East Bay Street, Suite 916
Jacksonville, Florida 32202
Examination of the witness taken before:
Laurie J. Miller, Court Reporter and Notary Public in and
for the State of Florida at Large.
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VERBATIM REPORTING SERVICES, INC.
916 Blackstone Building
233 East Bay Street
Jacksonville, Florida 32202 (904)355-0198
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A P P E A R A N C E S
KEVIN S. SANDERS, ESQUIRE,
Kevin S. Sanders, P.A.
817 Willow Branch Avenue
Jacksonville, Florida 32205
Attorney for the Plaintiff.
DAVID E. BLOCK, ESQUIRE,
Jackson, Lewis, LLP
Two South Biscayne Boulevard
One Biscayne Tower, Suite 3500
Miami, Florida 33131
Attorneys for the Defendant.
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I N D E X
WITNESS PAGE
PATTY ADEEB
Direct Examination by Mr. Sanders. . . . . . . . . . . 5
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E X H I B I T S
NUMBER PAGE
Plaintiff's Exhibit No. 1 for identification . . . . . 37
Plaintiff's Exhibit No. 2 for identification . . . . . 47
Plaintiff's Exhibit No. 3 for identification . . . . . 49
Plaintiff's Exhibit No. 4 for identification . . . . . 49
Plaintiff's Exhibit No. 5 for identification . . . . . 51
Plaintiff's Exhibit No. 6 for identification . . . . . 56
Plaintiff's Exhibit No. 7 for identification . . . . . 59
Plaintiff's Exhibit Nos. 8 and 9 for identification. . 72
Plaintiff's Exhibit No. 10 for identification. . . . . 74
Plaintiff's Exhibit No. 11 for identification. . . . . 91
Plaintiff's Exhibit No. 12 for identification. . . . . 93
Plaintiff's Exhibit No. 13 for identification. . . . . 94
Plaintiff's Exhibit No. 14 for identification. . . . . 96
Plaintiff's Exhibit Nos. 15, 16 and 17
for identification. . . . . . . . . . . . . . . . . 113
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C E R T I F I E D Q U E S T I O N S
NUMBER PAGE
Certified Question No. 1 . . . . . . . . . . . . . . . 71
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1 PATTY ADEEB,
2 having been produced and first duly sworn as a witness on
3 behalf of the Plaintiff, then testified as follows:
4 DIRECT EXAMINATION
5 BY MR. SANDERS:
6 Q Good morning.
7 Just for the record, you're going to need to
8 state your name and, maybe, spell your last name for the
9 court reporter.
10 A Okay. Patty, with a "Y," Adeeb, A-D-E-E-B.
11 Q And have you ever had your deposition taken
12 before?
13 A Gosh. I think once, 20 or so -- 25 years ago.
14 It's been a long time.
15 Q Well, I'll just sort of refresh your
16 recollection, maybe, on the rules, or at least the way that
17 I like to do things.
18 A deposition is just a friendly question and
19 answer session. It's allowed by the rules of civil
20 procedure. I'll ask questions; you'll give me responses.
21 If it's a yes or no response, try to say "yes" or
22 "no," because sometimes, in the South, depending on how
23 you're accustomed, sometimes people will say "huh-uh" or
24 "uh-huh," and they look very similar when they're written
25 on the page. And then, also, some people will sometimes
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1 nod heads, and she only can take down verbal responses, not
2 physical responses.
3 We talked about the parking. But if you feel ill
4 or you need to take care of parking, or you just need to
5 use the restroom, or something like that -- we'll take a
6 break any time that you say that we need to take a break.
7 This is not an endurance test. I'm not going to try to
8 outlast you or make you sit and be uncomfortable, so we --
9 we don't want to do that.
10 If I ask a question, and you understand it, tell
11 me you don't understand it, and I'll try to do my best to
12 either rephrase it or to make it understandable. If I ask
13 a question, and you answer it, I'm going to assume that you
14 understood what the question was and that you answered to
15 the best of your ability.
16 A Okay.
17 Q Your attorney has the ability to object. The
18 objections are for the record, and it's something that the
19 attorneys will argue in front of the judge at some later --
20 a later point. Unless he instructs you not to answer, then
21 you still will need to answer the question. Okay?
22 A Okay.
23 Q All right. Let's just get some foundational
24 questions out of the way.
25 Your current address is?
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1 A 13846 Atlantic Boulevard, Condo 812; that's
2 Jacksonville, 32225.
3 Q Okay. And are you employed?
4 A Yes.
5 Q And how so?
6 A Florida Community College at Jacksonville.
7 Q Do you have a particular campus?
8 A Deerwood Center campus.
9 Q And educational background?
10 A Doctorate.
11 Q In?
12 A Ed leadership, educational leadership.
13 Q Now, are you familiar with an organization known
14 as the Miss Florida Scholarship Pageant, Inc.?
15 A Yes, sir.
16 Q And how so?
17 A I have served as a local director; executive
18 director, at one point in my life; I served as -- and I now
19 serve as the scholarship chairperson.
20 Q And how long have you served as that?
21 A Gosh. As the scholarship chairperson -- you know
22 what? -- I can't remember how many years it's been.
23 It's over five years. I'm so sorry, I can't
24 remember the exact date I took over. I apologize.
25 Q It's all right.
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1 As the scholarship chairperson, do you know what
2 your duties and responsibilities are?
3 A Oh, yes.
4 Q And what are those?
5 A My duties are to oversee scholarship distribution
6 for the young women who have been awarded scholarship
7 moneys at both the state level, and sometimes I intercede
8 at the local level, if there is a concern for an executive
9 director.
10 Q Now, are those duties and responsibilities
11 written down anywhere?
12 A Yes; in the bylaws, I guess.
13 You know that I'm the scholarship chairman and
14 that my duties are simply to oversee distribution of the
15 moneys and to speak directly with the young women with
16 regard to their receipts, verify with their universities;
17 if a receipt is some type of concern -- like, for
18 tuition -- or where the payments would be made; if it's a
19 direct payment for the young lady, as opposed to a
20 reimbursement to the young woman. I have the authority to
21 speak with a university, and that permission is given to me
22 by the young women by the Buckley Amendment, because I'm
23 not allowed to -- colleges aren't allowed to speak to
24 anyone directly about a student's status at a university
25 unless that young woman or gentleman have given permission.
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1 Q Now, you said that your job description is in the
2 bylaws.
3 Have you seen the bylaws?
4 A I've seen them, but it's been a long time. It's
5 been a really long time since I've seen them. I haven't
6 read them recently.
7 Q Do you have a copy of them anywhere?
8 A Not with me, sir; no, I do not.
9 Q Do you have a copy at the house?
10 A I probably have a copy in my files.
11 MR. BLOCK: On behalf of everyone, can you get us
12 that copy?
13 THE WITNESS: Sir?
14 MR. BLOCK: On behalf of everyone, if you have
15 that copy, can you get it to everybody?
16 THE WITNESS: Yes, I'll try to locate that for
17 you.
18 MR. BLOCK: Thank you.
19 MR. SANDERS: We've taken the depositions of
20 Ms. Sullivan, Mr. McLeod, Mr. Williams, Mr. Richardson
21 (sic) --
22 MR. BLOCK: I think it's Richard Walker.
23 MR. SANDERS: Richard Walker -- I'm sorry --
24 yeah.
25 -- with Richard Walker and Rob Loy, and nobody
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1 seems to have a copy of the bylaws.
2 THE WITNESS: Okay. And I'll search whatever I
3 have. I will tell you that there was -- I moved. We
4 had a renovation at the college; and, last year, a lot
5 of my files were -- I keep everything at the
6 university, and there were a lot of things misplaced.
7 And I can attest to that, because I had lost some very
8 important files that dealt with my young women, and we
9 had to go back and redo them. No one seemed to know
10 where my boxes had been placed at the university in
11 the move. So -- but I will make a diligent look to
12 see if there's anything with any -- any statement as
13 to what my duties are.
14 BY MR. SANDERS:
15 Q Well, let me ask you: Did you read the bylaws or
16 just the part of the bylaws that described your duties?
17 A If I were reading anything, I probably just
18 read -- and it's been so many years ago -- I can't even
19 remember when I took over. I apologize. I should know the
20 date that I took over. It was when the Miss Florida
21 Pageant became an established pageant, under Mary. That's
22 when I took that scholarship chair position; and, at that
23 time -- I'm sure, at a meeting -- my duties were probably
24 either shown to me in writing or given verbally.
25 And it's only pertaining to scholarships, so that
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1 would be the only one that they would - I would be looking
2 at.
3 Q Well, so do you --
4 A That's the only office I held.
5 Q So do you know if it was given to you verbally or
6 in writing, in the form of bylaws, or are you unsure at
7 this point?
8 A I'm unsure, because most organizations have
9 bylaws, and I'm just -- I have not read, honest -- in all
10 honesty, I've not looked at a set of bylaws -- I can't
11 remember looking at them recently at all, so I would assume
12 that the only time I've looked at them was when I took the
13 position. And I know there's been no revisions to my
14 position, so I would have not had any reason to go back and
15 look at anything, unless there was an amendment being made,
16 or something like that, or a change.
17 Q Do you recall -- well, are you on the board of
18 directors?
19 A I'm not on -- I am on the -- we have a board, but
20 I don't serve on the executive board. I am on the board
21 with the regional directors. And then there are certain
22 chairs; like, I'm the chairman of the scholarship factor of
23 the organization.
24 The executive board is Mary and Richard, Rob -- I
25 don't even think -- I wouldn't even say -- I don't know --
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1 I can't specifically say David, because -- I do know Mary,
2 Richard and Rob are considered the executive board.
3 Q What's the difference between the board and the
4 executive board?
5 A Sometimes I don't know.
6 MR. BLOCK: Objection.
7 THE WITNESS: I'm sorry.
8 MR. BLOCK: That's okay.
9 Objection to foundation.
10 You can answer. Every now and then, I'll use
11 words like "foundation" and "form."
12 THE WITNESS: Okay.
13 MR. BLOCK: You don't have to worry about those
14 words, and you can just pause, and then you can go
15 ahead and answer.
16 THE WITNESS: Okay. There might be a meeting
17 that the executive board might have that I might not
18 attend; I might not be required to attend. We're
19 invited to attend, but we don't always go to
20 everything. I can't go to everything, with -- based
21 on my job.
22 BY MR. SANDERS:
23 Q Well, and let me try to be a little more
24 specific. And just for your recollection, I'll just show
25 you this. The North Florida Scholarship Pageant (sic),
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1 Inc., was formed, according to the public records on-line,
2 on -- it looks like June 10th of 2002.
3 Does that --
4 A 2002?
5 Q -- refresh your recollection with regards to when
6 you think you may have been appointed scholarship chairman?
7 A I came on board when Mary established the pageant
8 under her name, as our executive director for the state
9 pageant.
10 Q And if you want to look on that, down below that,
11 it does have the actual -- where it says "Officer/Director
12 Details" -- do you see that, down at the bottom?
13 A Oh, yes.
14 Mary, Richard and Rob; okay. Then I was right;
15 okay. Yes, sir.
16 Q So that's your understanding of who the executive
17 board is?
18 A Yes, sir.
19 Q Now then, is the executive board the same as the
20 corporate board? Do they act as a corporate board of
21 directors, or are they just an executive board for the Miss
22 Florida Pageant?
23 A I don't know.
24 MR. BLOCK: Foundation.
25 Now you say "I don't know."
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1 THE WITNESS: I don't know. I'm sorry.
2 BY MR. SANDERS:
3 Q Now then, if you know, what duties or
4 responsibilities are different from the executive board, as
5 opposed to the full board, as I think is how it's been
6 referred to, the part that you're in?
7 A I would say, technically, that the executive
8 board has a lot more duties than we do.
9 I'm specifically dealing with scholarships, and
10 the regional directors are specifically dealing with the
11 local pageants that they supervise; whereas, the executive
12 board handles setting up of the pageants, the technical
13 things for the state-level program that we put on annually,
14 making all the arrangements for us, and also dealing, at
15 the national level, with Miss America. Mary specifically
16 would be the one that would be the direct report to Miss
17 America. And we, at the lower level -- I don't think we're
18 lower level, specifically, but not at the executive board
19 level -- we would not be reporting directly to Miss
20 America, unless there was a scholarship issue that Miss
21 America needed to speak to me directly about a scholarship
22 issue; like, if a young lady had received all her moneys,
23 so that she could now receive her Miss America awarded
24 moneys. Or if there was a change in any scholarships at
25 the Miss America level that were being awarded for each
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1 year, they might call and let me know a change on something
2 like that directly.
3 But, other than that, it would probably be Mary
4 that would speak directly to Miss America directors.
5 Q Okay. We'll get to Mary in just a minute. I'm
6 still trying to sort out the board a little bit.
7 Does the -- does, I guess, the full board then
8 report to the executive board, or who does the full board
9 report to?
10 MR. BLOCK: Foundation.
11 THE WITNESS: We report to the executive board.
12 I report to both -- I don't report to Rob, but I do
13 report to both Mary and Richard.
14 BY MR. SANDERS:
15 Q And why do you report to Mary and Richard and not
16 Rob?
17 A Mary is the -- well, Rob has a different
18 function. Richard deals with the checking account, as a
19 dual balance with Mary, and so that we will have a checks
20 and balances system. Even though I distribute moneys and
21 make sure everything is on the up and up in terms of
22 scholarship moneys owed, I would -- Mary and Richard write
23 the checks, so that it's not me writing the checks, as well
24 as doing the checks and -- there's a checks and balances
25 there.
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1 Q Who makes, to your knowledge, the day-to-day
2 decisions for the pageants?
3 A I think that's collaborative. I think Mary and
4 Richard and Rob meet very often, and they always -- you
5 know, they'll -- when we have our regular board meetings,
6 they will ask our opinions on things, and we vote on
7 issues.
8 Q Have you ever seen any bylaws or rules or
9 regulations of any kind which govern what the executive
10 board is supposed to do and the full board is supposed to
11 do?
12 A If I did, it would have been when I first came
13 on; and, like I said, I haven't seen or read anything to
14 that nature -- I didn't have a need to.
15 Q At any of the board meetings that you've
16 attended, whether or not you attended an executive board
17 meeting or a full board meeting, do you recall any
18 proposals or amendments to bylaws or any rules or
19 regulations, with regards to the Miss Florida Pageant,
20 since its formation in 2002?
21 MR. BLOCK: Form.
22 THE WITNESS: I'm going to answer that question,
23 I hope the way that I think that you're asking.
24 You're saying to the bylaws?
25 MR. SANDERS: Correct.
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1 THE WITNESS: I wouldn't say I remember anything
2 changing to a bylaw, but we do discuss changes, if
3 there's a scholarship rule -- with respect to my
4 participation, if there is a scholarship rule change.
5 It might be at the Miss America level, and Miss
6 America might direct me now, at the state level, that
7 you now can no longer award moneys for this type of
8 item, or you can award moneys for this type of item
9 now, or if it's an accredited school or a
10 non-accredited school. That would be the type of
11 changes that we might talk -- with respect to me,
12 particularly scholarships.
13 BY MR. SANDERS:
14 Q But those would come down in writing, though,
15 from Miss America; would they not? You would see a copy of
16 that, either as a memo or a note?
17 A As a note. Yes, sir; a note, like a note.
18 Q Have you received any --
19 A Or it might be verbally.
20 Q Okay. Have you received any memos or notes or
21 anything in writing from either Mary, Richard or Rob, with
22 regards to any changes in the bylaws or the way that the
23 day-to-day activities of the Miss Florida Pageant are to be
24 conducted?
25 A Not to my recollection, sir.
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1 Q Do you know if there's any particular bylaw rule
2 or regulation governing local pageants and the directors?
3 A A set of bylaws for them?
4 Q Or a rule or -- something in writing; notes,
5 memos.
6 A I know that, when I was a local director,
7 everything was, like, sent to me in notes, you know, and I
8 had a contract, you know, that the young lady fills out
9 that we -- a lot of the rules and regulations for the young
10 women are within the actual contract, so -- for a local
11 director to follow.
12 Q But that governs the contestants, though, right;
13 not the directors?
14 A Local directors are sent information on a regular
15 basis. I sometimes am not -- I mean, I'm privy to read
16 them, but I don't necessarily read them unless it's
17 pertaining to the scholarships.
18 Q Now, when you say when you were a local
19 director --
20 A That's been years ago.
21 Q -- that was before the formation of this
22 corporation.
23 A Yes, sir.
24 Q So none of that would apply to this corporation?
25 A Okay; yes, sir.
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1 Q I guess I'm just going to go back to the
2 question: Do you know of any written rules, regulations or
3 something in the bylaws which sets out any rules for local
4 directors?
5 A I don't know if you could call them bylaws. I
6 just know that there's continued written communication sent
7 to local directors all the time, from Mary, with regard to
8 rules and regulations, which we're to follow.
9 Q And do you know who would have those rules or
10 regulations or memos or notes?
11 A And maybe I'm stating that wrong. I'm calling it
12 a rule or a regulation or a policy or a process.
13 If Mary is the one who sends them out, I'm
14 assuming Mary would have those. It's just communication.
15 She sends out communication all the time.
16 Q Could you describe for me what Mary's job title,
17 duties, responsibilities, powers are?
18 MR. BLOCK: Objection to foundation.
19 THE WITNESS: Mary is our director. She is the
20 person who sets the foundation for the leadership of
21 the entire program. She is our mediator with the Miss
22 America Organization, under which we have our
23 contract. She informs us of any regulations,
24 processes or rules that Miss America sets down for us.
25 She guides us in our expectations for our positions,
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1 works very diligently to get things set up for us, in
2 terms of our annual pageant; and, throughout the year,
3 she's busy on a daily basis just working with local
4 directors, making sure that the local pageants are
5 running smoothly and that they are all getting
6 prepared for the annual pageant. She sends out
7 regular communications to everyone, that are privy to
8 everyone. I mean, when she sends out an e-mail, it's
9 usually to everyone -- all local directors, all the
10 executive directors and to the board members.
11 BY MR. SANDERS:
12 Q And when you said she works with the locals, in
13 what way does she work with the locals?
14 A She sends communications to them; they write to
15 her, she writes to them. If it's something she thinks one
16 of us can handle -- like the local director; executive
17 director; or myself, as a scholarship person -- she will
18 send an e-mail to us and say, "Listen, I just heard
19 from..." so-and-so "...can you handle this situation?"
20 And, of course, as part of our volunteer duties,
21 we would take that situation and handle it for her, which
22 we should, if that's our role in the organization.
23 Q And how much, I guess, authority or power does
24 she have to make decisions on behalf of Miss Florida
25 Scholarship Pageant, Inc.?
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1 MR. BLOCK: Foundation.
2 THE WITNESS: Okay. I would say she has a lot of
3 authority, but she is very collaborative in her
4 decision making. She usually puts forth to the
5 executive board, and they will discuss; and then, very
6 often, it will come to the entire board, beyond the
7 executive board, for discussion and collaborative
8 decision making.
9 BY MR. SANDERS:
10 Q And I guess that's the curiosity.
11 At what point does she make decisions on her own,
12 and then at what point do those decisions go to an
13 executive board, and then at what point do those have to go
14 to a full board?
15 MR. BLOCK: Form and foundation.
16 THE WITNESS: Okay. May I ask what we're saying
17 when we're saying "form" and "foundation?" I'm a
18 little lost there.
19 MR. BLOCK: If someone said, "Did Joe go to the
20 store and buy milk and butter?" I would object to
21 form.
22 THE WITNESS: It's the type of question --
23 MR. BLOCK: I would object to form, because he
24 could have bought milk and jam. The question has some
25 kind of -- that's an example of a form question.
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1 THE WITNESS: Thank you.
2 MR. BLOCK: A foundation question -- if someone
3 were to ask me how you build a coffee maker, it would
4 be an objection to foundation. First, establish I
5 know the first thing about coffee makers, then you can
6 ask me how to build them.
7 THE WITNESS: I got you. Thank you.
8 I would have to say that I'm not privy to all the
9 things that Mary does on a daily basis. She has a big
10 job as the executive director at the state level. I
11 wouldn't even think that I would be called upon on
12 every decision she has to make. She is the leader,
13 and we work under her voluntarily, as our leader, and
14 trust her to make good decisions on behalf of the
15 organization. But, like I said before, she's very
16 collaborative in making the majority of her decisions,
17 but I'm sure there are decisions that she makes on her
18 own, without having to call upon us, as any of us that
19 are leading an organization might have to do.
20 BY MR. SANDERS:
21 Q And again, based on your knowledge of the
22 corporation, if she made a decision on her own, that would
23 be a decision that would, I guess, be binding on the Miss
24 Florida Scholarship Pageant, Inc., and to the board and to
25 the executive board?
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1 MR. BLOCK: Form and foundation.
2 THE WITNESS: I can't say that, sir. I really
3 can't. It's the nature of the decision. There are
4 many decisions made. They could be minor; they could
5 be critical. I'm not at liberty, at that level, to
6 say all the decisions she makes, but I can just repeat
7 that she tries to include everybody in her decision,
8 to do collaborative decision making at the executive
9 board level and then at the other level of board.
10 BY MR. SANDERS:
11 Q I'm going to ask you a sort of two-part question.
12 The first part is: Percentage-wise, if you can,
13 how many decisions -- if we were to take 100 percent of the
14 decisions for the pageant, what percentage of decisions
15 does Mary make, what percentage of decisions does the
16 executive board make, and then what percentage of decisions
17 does the full board make?
18 MR. BLOCK: Form and foundation.
19 THE WITNESS: I can't answer that, sir.
20 BY MR. SANDERS:
21 Q Let me ask you a different question, then.
22 How many decisions made unilaterally by Mary has
23 the executive board or the full board overturned?
24 MR. BLOCK: Same objections.
25 THE WITNESS: Yes.
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1 We have had discussions, and we might have
2 differences of opinions, and -- for example, Mary
3 might think one way, and we might think another way,
4 and that doesn't mean, always, that we go the way Mary
5 wanted. Mary is very open to discussion and
6 collaborative thinking, so that could work for any of
7 us. The majority, in those discussions -- it's
8 usually a majority decision-making process, for the
9 ones that I am involved with. And it doesn't mean
10 that I agree or everyone agrees; it's just, we discuss
11 it, and we do what's best for the whole, through a
12 majority vote on a lot of decisions.
13 BY MR. SANDERS:
14 Q And, I guess, the specific question: Has the
15 full board or the executive board ever overturned any
16 decisions made by Mary?
17 MR. BLOCK: Same objection.
18 THE WITNESS: I'm not privy to that. I don't
19 know. I don't remember any.
20 BY MR. SANDERS:
21 Q What, if any, authority, powers or duties does
22 Richard have, then?
23 MR. BLOCK: Foundation.
24 THE WITNESS: I think these questions are best
25 suited to the individuals who hold those offices.
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1 But I do -- I can say that Richard helps me with
2 the checks and balances of writing checks to the young
3 women to for their scholarships, and he is very
4 integral in the choreography and the program planning
5 for the Miss Florida program, for the actual show that
6 we put on annually; he's very instrumental in that,
7 working with the dancers, the performers, the girls,
8 getting them ready -- the young women; excuse me --
9 getting the young women ready for the show.
10 But as for specifics, I think that's a question
11 best suited for him to answer.
12 MR. SANDERS: And again, I'm just asking the
13 various board members what their understanding of the
14 officers --
15 THE WITNESS: Yeah. Overall, yes, he works very
16 closely with me, with scholarships. He works very
17 closely with Mary on the day-to-day things throughout
18 the year, getting things ready for -- you know,
19 they've got to get sponsorships; they've got to get
20 locations to hold orientations, and work on hotel
21 arrangements, and making sure that the locals are
22 getting their contracts in, and -- they work very
23 closely together on those areas that the rest of us --
24 due to logistics, you know, we're not nearby, to be
25 available to help in a lot of those day-to-day duties.
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1 BY MR. SANDERS:
2 Q Does Richard -- and I guess we haven't -- this is
3 Richard Walker that we're talking about; and, previously,
4 talking about Mary Sullivan.
5 Does Richard Walker make any unilateral decisions
6 on behalf of the corporation or on behalf of the pageant?
7 MR. BLOCK: Foundation.
8 THE WITNESS: I'm sure, in the course of his day,
9 at his leadership level, there may be decisions that
10 he is able to make in our behalf.
11 And, as I stated before, when you elect officers
12 to an organization, or you are approving officers,
13 there's that element of trust, in that every decision
14 should not have to require the input of every person
15 serving on that board. If you had to do that, you'd
16 be meeting all the time, or you'd be on a conference
17 call all the time.
18 So I have to trust that there are decisions that
19 the executive board makes in our behalf. But,
20 usually, if it's a critical decision, I would assume
21 that they would bring that up for discussion, and I --
22 and, this year, I've truly not been privy to attend
23 all of the meetings due to my job responsibilities.
24 So I'm sure there's been decisions made by the entire
25 board that were discussed fully by Mary and Richard or
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1 Rob with the rest of the board members, in a
2 collaborative setting, or by e-mail. Sometimes
3 something might be sent out just to -- "Listen, you
4 can't be here, and we understand that. What is your
5 understanding? Do you agree with this or not?" And a
6 vote will be made.
7 BY MR. SANDERS:
8 Q I'm going to key in on a couple of things you
9 said. You said you have to trust the officers that you've
10 elected.
11 Does the board elect the officers of the Miss
12 Florida Pageant every year?
13 A No.
14 The officers that have been selected have been
15 there since 2002, in their positions. I'm sure, if there
16 was a concern, all of the board members would come forward.
17 We've had no reason to come forward for a change in
18 officers. They've done an excellent job, I mean, in the
19 organization, and we've had no reason, from my point of
20 view -- I have had no reason to come forward with any
21 complaint about my executive board. If I did, believe me,
22 I would be very vocal and share my concerns, if I had a
23 concern.
24 Q So, since 2002, there's not been any either
25 formal or informal election or review of the officer
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1 status?
2 A We have changed --
3 MR. BLOCK: Object to form.
4 THE WITNESS: Oh.
5 MR. BLOCK: That's okay.
6 THE WITNESS: We have changed our local
7 directors -- either someone left, and the names would
8 come forward, and we would decide if that was -- you
9 know, there would be a vote, you know, "Is everybody
10 in agreement on this person? Can they retain the
11 position of the local director that just left?"
12 It's just been mainly locals. Our executive
13 board has not changed. It might just be at the local
14 level or -- or, on the board level, a regional
15 director might leave, and we have to replace the
16 regional director, which we have done over the years;
17 yes, sir.
18 BY MR. SANDERS:
19 Q And I guess what I'm talking about mainly is
20 the -- either the board for the corporation, which you've
21 acknowledged is Richard, Mary Sullivan and Rob Loy.
22 There's been no elections, no review of the
23 officer status, no --
24 A Not to my recollection.
25 MR. BLOCK: Foundation.
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1 BY MR. SANDERS:
2 Q And, I guess, just to be clear on that, they
3 didn't have, probably, an election meeting where you
4 weren't noticed of that, and you couldn't attend? Were you
5 ever noticed of any meetings for elections of officers
6 or --
7 A For the board?
8 Q For the board; yes, ma'am.
9 MR. BLOCK: Form.
10 THE WITNESS: To my best understanding, the board
11 reports directly -- the executive board reports
12 directly to Miss America. There's a contract
13 agreement there.
14 I would have to say that, if there were any
15 changes to that board -- I mean, we, as a -- a level
16 of the board, could bring concerns, but it would be my
17 understanding that it would be Miss America that would
18 be the persons to address any changes in this board,
19 officially. Even if I had a concern, I would --
20 that's who they report to, is Miss America. They
21 signed a contract with them.
22 BY MR. SANDERS:
23 Q Well, I'll just -- Mr. Block can contradict me,
24 if he wants, but during the course of the depositions of
25 the other corporate officers and a couple of board members,
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1 it has come to light that apparently there are three
2 boards; there's a corporate board, then there's an
3 executive board, and then there's a full board.
4 Are you aware of the three different boards, or
5 were you just under the impression that there were two?
6 MR. BLOCK: Objection as to form.
7 THE WITNESS: No comment on that. I wouldn't
8 want to state something that's inaccurate.
9 MR. SANDERS: And I don't want you to state
10 anything that's inaccurate either. That's fine.
11 THE WITNESS: Yeah.
12 BY MR. SANDERS:
13 Q I'll just ask it, maybe, a different way, then.
14 Did you believe that the executive board and the
15 corporate board, which is on this copy of the corporate
16 documents, were the same?
17 A I would say I would have presumed that to be.
18 Q Have you ever had any experience, either with a
19 corporation, yourself, or somebody that you knew with a
20 corporation, or sitting on an actual corporate board that
21 did business?
22 A Yes, I do. I'm privy of that.
23 Q Did they normally have annual meetings and
24 elections of officers and go through who would be directors
25 for the proceeding year?
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1 A Not necessarily on an annual basis. Some
2 officers were elected for two -- two-year terms, or
3 sometimes -- yes, there would be annual meetings.
4 And when you say "corporate board," I just want
5 to make sure what you're referencing.
6 Q Well, and again, I'm referencing what is listed
7 in Tallahassee, in the corporate records. It's called Miss
8 Florida Scholarship Pageant, Inc.
9 A Uh-huh.
10 Q That is the corporation that technically runs the
11 Miss Florida Pageant; is it not?
12 A Uh-huh.
13 Q And you have to say "yes," remember. You're
14 going "uh-huh."
15 A Yes.
16 Q Now, is it the executive board that signs the
17 contract with Miss America, or is it Mary Sullivan that
18 signs the contract with Miss America?
19 MR. BLOCK: Foundation and form.
20 THE WITNESS: That's a question you'd have to ask
21 Mary, but I would assume it's Mary. That's the one
22 that they've selected as the executive director of the
23 state pageant.
24 BY MR. SANDERS:
25 Q And that would be similar to local pageants.
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1 They all have corporations and corporate boards, but it's
2 one individual that signs as an executive director; is that
3 correct?
4 A I would say that's a question you would need to
5 ask of the local directors, how they set up their corporate
6 boards.
7 Q But with your experience in doing corporate
8 boards, you do know that there's normally annual meetings
9 and elections of officers.
10 No such meetings have taken place for the Miss
11 Florida Scholarship Pageant, Inc., since 2002?
12 MR. BLOCK: Objection to form; foundation.
13 THE WITNESS: Definitely no comment on that,
14 because every organization is different. I mean,
15 there are not a set of rules out there written for how
16 a corporate board is set up, you know, uniformly,
17 across the states, so every board is different. So I
18 would not even think to impose the thought processes
19 of any corporate boards I serve on or work with, to
20 impose those same rules and regulations to the Miss
21 Florida Board.
22 BY MR. SANDERS:
23 Q And I can agree with that to a certain extent.
24 I'll ask it a different way: Were any of the
25 other corporate boards that you were involved with -- did
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1 they never have any annual meetings and never have any
2 elections?
3 MR. BLOCK: Form.
4 THE WITNESS: Some have an annual meeting, but
5 I've not been privy to attend them. I get a board
6 report; I get a corporate report. I never attended
7 the meetings. I might get something in the mail that
8 says, "Do you want to vote on this, or do you want to
9 not vote on this?"
10 But did I attend an annual meeting? No. Was I
11 even invited to attend an annual meeting? No.
12 But I'm speaking to other boards. I'm not
13 speaking to the Miss Florida Board. You asked the
14 question with reference to boards that I know. That's
15 why I'm saying there's not a set of iron-clad rules
16 for corporate boards or executive boards. It's kind
17 of set within the parameters of that organization.
18 BY MR. SANDERS:
19 Q Well, and again -- and I'm not expecting you to
20 be knowledgeable with the Florida statutes. I'm not going
21 to go into those, but --
22 A Yes, sir.
23 Q -- but is it fair to say that the rules that
24 govern a corporation are their bylaws?
25 MR. BLOCK: Objection as to foundation.
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1 THE WITNESS: I'm not sure.
2 BY MR. SANDERS:
3 Q Okay. And you don't know if you've actually seen
4 any bylaws for this corporation?
5 MR. BLOCK: Asked and answered.
6 THE WITNESS: Like I said, if I have any, they
7 would be in a box. And I hope -- like I said, I will
8 diligently make an effort to find those. But last
9 year, when we had our renovations at the university, a
10 lot of my boxes were somewhere -- they're misplaced,
11 or they're destroyed or moved out with the people who
12 demoed the building, but we've been trying to find a
13 lot of information. I had to do a lot of backtracking
14 to update my records and everything, due to those
15 losses.
16 MR. SANDERS: I understand that.
17 THE WITNESS: And I apologize. I don't have some
18 of that.
19 MR. SANDERS: Again, I'm not trying to put any
20 pressure on you.
21 THE WITNESS: No, no. I don't feel it.
22 MR. SANDERS: If you don't know what the answer
23 to the question is, you can certainly say, "I don't
24 know."
25 THE WITNESS: Thank you.
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1 MR. SANDERS: That's a valid answer in a
2 deposition. I'm just asking the questions to see if
3 you know the answers.
4 THE WITNESS: Okay.
5 BY MR. SANDERS:
6 Q And you were talking about the private -- or the
7 corporate boards that you were on, and you mentioned
8 something about you have received notices.
9 Have you received any notices from Mary, or
10 anybody associated with the Miss Florida Scholarship
11 Pageant, Inc., with regards to either upcoming elections or
12 what happened at elections?
13 MR. BLOCK: Form.
14 THE WITNESS: For what? Elections for what?
15 MR. SANDERS: Elections for officers or
16 directors.
17 THE WITNESS: Oh, yes, we get e-mails on a
18 regular basis, if a position needs to be replaced.
19 BY MR. SANDERS:
20 Q Well, when I'm saying that, I'm talking about the
21 corporate officers and the corporate -- not the officers of
22 or the executive directors of the locals.
23 A To my knowledge, nothing specific about a
24 corporate board. If I'm wrong, I'm sorry. I -- to my
25 knowledge.
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1 Q And that's all I'm asking you, what your
2 knowledge base is.
3 A Okay.
4 Q We talked about Mary, we talked about Richard,
5 and I think you said Rob Loy was the other executive board
6 member.
7 Do you know what Rob Loy's job description,
8 powers, duties are?
9 A Again, specifically, all his duties -- mainly,
10 overall, he works with the judges for the state level, and
11 he also helps the local pageants with regard to their
12 judging systems, the processes, the rules and regulations
13 for selecting judges, for how that process should be
14 handled when the young girls are interviewed. Rob also has
15 been very instrumental in helping with the Miss Teen
16 Pageant, the initial beginnings of that program; he worked
17 very hard on that.
18 Q And again, what I've heard mostly, with regards
19 to Richard and Rob, is the duties that they have relating
20 mostly to the pageant.
21 Do you know of any duties that they have relating
22 to the actual corporation?
23 A I just know that Richard and Mary, in particular,
24 work very closely together, to help provide the annual
25 report on the scholarship moneys and how much we have in
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1 our accounts, how much we don't, to publicly provide the
2 entire board information with regard to our status
3 financially. I'm not sure as to Rob's involvement with
4 that level.
5 MR. SANDERS: Let me do this: I'm going to go
6 ahead and put this in as 1, which is the copy of the
7 corporate records for the Miss Florida Scholarship
8 Pageant, Inc.
9 (Plaintiff's Exhibit No. 1 was marked for
10 identification.)
11 BY MR. SANDERS:
12 Q Ms. Adeeb, I'm going to show you a copy that I
13 have of the pageant book for 2006, the Miss Florida
14 Pageant. I'm going to show you this book, which lists what
15 they call the 2006 Miss Florida Scholarship Pageant, Inc.
16 Board of Directors.
17 (Mr. Sanders tendering document to witness.)
18 Are you familiar with that? Have you seen that
19 before?
20 A Yes, sir.
21 Q And again, I've made a copy of this in color, to
22 try to be of assistance. And, if you would -- I'm going to
23 probably put this in as an exhibit to your deposition --
24 could you just verify that this copy is a true and accurate
25 copy of the one that's in the program book.
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1 A Yes, sir.
2 Q Let me give you this one to kind of work with.
3 I'm going to just ask you a few more questions.
4 On the -- in the pageant book, in 2006, it says
5 Mary Sullivan is the executive director and president.
6 Are there different jobs for each one, or are
7 they sort of one and the same, as you've described the
8 duties for Mary Sullivan earlier?
9 MR. BLOCK: Foundation.
10 THE WITNESS: I would say, as the executive
11 director -- you know, that's a title that's a direct
12 report to Miss America, as all the state-level people
13 are called executive directors of their state
14 pageants. And I would say, president, probably -- in
15 my own estimation, she's the president of our state
16 organization, as a whole, for us. But as executive
17 director, they -- they have overlaps in their duties
18 and responsibilities, I would assume; but, as
19 executive director, she is a direct report to Miss
20 America.
21 BY MR. SANDERS:
22 Q And again, you were saying that you were assuming
23 that they have overlaps.
24 Do you know of anything specific that states what
25 the executive director's duties are, either from Miss
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1 America or a part of the corporation, and then what the
2 president's duties are?
3 MR. BLOCK: Foundation.
4 THE WITNESS: That's a question you'd have to ask
5 of Mary.
6 BY MR. SANDERS:
7 Q But you don't, personally, know of anything in
8 writing, then?
9 A No, sir, I've not seen anything in writing.
10 Q And then the same type of question for Richard
11 Walker. It lists him as a CEO and chairman of the board.
12 And again, I'm going to give you an opportunity
13 to maybe embellish, but all I really heard you talk about
14 with him is basically helping you with the money and the
15 scholarships and choreography.
16 What does that fall under; under CEO or chairman
17 of the board, or are there different descriptions for what
18 he's doing?
19 MR. BLOCK: Foundation.
20 THE WITNESS: I think, for specifics of their job
21 requirements, you need to -- you need to get responses
22 from both Richard and Mary, with regards to the
23 differentiation of those titles.
24 BY MR. SANDERS:
25 Q But as a board member since 2002, you wouldn't
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1 know what those differences are?
2 A I can generally talk about things. They work
3 very collaboratively together on all the technical aspects
4 of the pageant. As I stated before, all of us are not
5 privy, logistically, to be available, except by phone or an
6 e-mail, to deal with day-to-day issues.
7 Richard also has a very busy job, as does Mary.
8 We're all volunteers. When Mary and Richard, logistically,
9 can get together more often than we can, and Rob, who is a
10 little bit closer, can get together with them to help --
11 they handle a lot of functions that I, personally, could
12 not help them with, because I'm not there. And I'm very
13 appreciative of all that they do. You know, it takes a lot
14 off of the rest of us who cannot be there to make these
15 things happen.
16 Q And, I guess, I'm sort of looking for the short
17 answer: You don't know of any particular duties or
18 responsibilities for what the title of executive director,
19 president, CEO, or chairman of the board mean, even though
20 you've been a director since 2002?
21 A If there's anything in writing that we have, I
22 haven't seen it in a while, that I can say. I haven't read
23 it or reviewed it.
24 Q Now, I did notice -- and again, I could let you
25 look through the whole book, if you want -- I did notice,
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1 in 2006, the only thing listed in the pageant book is just
2 the board of directors; there's no executive board or
3 anything else.
4 Did the executive board exist in 2006?
5 A I would say that Richard and Mary have always
6 been our executive board. It might not be in here, because
7 it costs of lot of money to put this book together.
8 Q Well, and again --
9 A It might require a separate page.
10 Q Well, and I'm not going to challenge you on that.
11 But they've listed two titles for Mary, executive director
12 and president. They could have put "Executive Board"
13 underneath that, in print; could they have not?
14 MR. BLOCK: Objection to form.
15 THE WITNESS: That's semantics to me. I mean,
16 you know, most of the people who read this book take
17 it and look at a picture of a young girl and store it
18 away as memorabilia, and it's over with.
19 BY MR. SANDERS:
20 Q Under Rob Loy, it says "vice president," and it
21 says that under Kitty Potapow.
22 Did they have similar duties, or do you know what
23 the responsibilities -- first, we'll take Rob Loy, as vice
24 president: Do you know what his duties were under the
25 title of vice president?
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1 A If my memory serves me directly, Kitty was a vice
2 president under -- it was a -- we had a long discussion on
3 the title vice president, because Rob was our vice
4 president for the organization, but Kitty was brought in to
5 help with sponsorships, getting sponsorships brought in for
6 the pageant. And I don't have all full memory of why vice
7 president was finally selected, but it was vice president
8 of this area. Rob is vice president of the executive board
9 for the entire organization. Kitty Potapow was vice
10 president under a specific area, which was scholarship
11 contributions, getting people -- physical support for the
12 program. That's the best I can remember, when that was
13 done.
14 Q And it's my understanding Ms. Potapow is no
15 longer with the board.
16 A Yes, sir.
17 Q And do you know why she left?
18 A If my recollection serves me, her husband was
19 very ill.
20 Q Now, it lists, in the 2006 program book, that
21 Keith Williams was the secretary/treasurer.
22 Do you know what his job description was?
23 A Keith's been very instrumental in helping us put
24 the program together, and ticket sales for the annual
25 program.
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1 Q And I guess I've got to get you to define
2 "program," because there are several different definitions.
3 A Oh, for the entire organization.
4 Q Well, I mean, when you say "program" --
5 A Oh, for the pageant, the annual pageant.
6 He helps put together the program, getting all
7 the photographs of the girls, receiving all the ads from
8 the vendors.
9 Q And you're talking about the program book, like
10 what we're looking at now?
11 A Yes, sir; the program booklet.
12 And then he also is very instrumental in setting
13 up the sale of the tickets and how the -- that whole
14 process. It's a very intricate job, the ticket sales and
15 putting this program together.
16 And he helps throughout the year, too. He also
17 does a lot of running back and forth. He's close, too --
18 also, logistically close to our warehouse, where we house
19 things. He'll load things, carry them back and forth to
20 Mary, if they need them, or help with a local pageant,
21 or -- he does a lot of little things like that, too,
22 throughout the year. They're not really little; they're
23 time consuming.
24 Q Again, do you know of any corporate
25 responsibility -- again, most of what you said sounded like
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1 it was responsibilities towards the pageant, itself.
2 A Yes, sir.
3 Q Any corporate responsibilities that you know of?
4 MR. BLOCK: Foundation.
5 THE WITNESS: I don't know, sir.
6 MR. BLOCK: How are we doing on parking?
7 THE WITNESS: It's 10:30.
8 MR. SANDERS: Yeah; let's take a break.
9 (Brief recess.)
10 BY MR. SANDERS:
11 Q Now, I'm going to get you to look at both pages
12 again.
13 A Okay.
14 Q And, of course, your face is on there as part of
15 the board, in fact, and we've already talked about your job
16 responsibilities.
17 If you'd just look at both pages, are the rest of
18 the people the board members as you recall them back in
19 2006?
20 A To the best of my memory, yes, this is accurate.
21 Q Let me ask you just a few questions. Ray
22 McLeod -- it says he's a board member, but it also says
23 he's legal counsel.
24 Was he actually on the board? Does he make board
25 decisions?
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1 MR. BLOCK: Objection to foundation.
2 THE WITNESS: Yeah; the legal aspect of that.
3 He serves as legal counsel.
4 BY MR. SANDERS:
5 Q So he's not technically on the board?
6 MR. BLOCK: Same objection.
7 THE WITNESS: Yeah; semantics there, for me.
8 He's just our legal counsel. And, you know,
9 everybody is just trying to -- in this program,
10 they're trying to show all the people. If it falls
11 under "board of directors," you know, they're just
12 trying to get everybody's photograph in there, to show
13 who's volunteering and serving.
14 BY MR. SANDERS:
15 Q And Wayne DeWitt, was he actually on the board
16 back then?
17 MR. BLOCK: Foundation.
18 MR. SANDERS: He's right next to Ray McLeod.
19 THE WITNESS: He served as our CPA advisor.
20 BY MR. SANDERS:
21 Q And again, he didn't actually have a vote at the
22 board meeting?
23 A No, sir.
24 Q Besides those two, did the rest of the people
25 have votes at the board meetings?
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1 A Yes, sir.
2 Q Now, it's been indicated that Mr. Boyko,
3 Mr. Jolly, Mr. Smith and Mr. Caglia are no longer with the
4 board.
5 Do you know why they left?
6 A Let's see. I don't remember fully why they left.
7 They -- they were not -- they were serving on the Miss Teen
8 Board, board of directors. Well, we're all part of a
9 group, but they were doing the Miss Teen.
10 Q So they weren't on the full board?
11 A They were on our board, yes -- well, yes, they
12 served with us, but their primary duties were the Miss Teen
13 Pageant.
14 Q Well, did they have a vote in any --
15 A Yes, they did.
16 Q Okay. So they did have a vote?
17 A They were very --
18 Q And you don't recall why any of them, in
19 particular, left?
20 A I just remember that -- I remember, when they
21 left, I missed them. They're very nice gentlemen, all of
22 them.
23 Q Were there any disputes over how the Teen Pageant
24 was being run, which precipitated their leaving?
25 MR. BLOCK: Form and foundation.
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1 THE WITNESS: Not to my knowledge, sir.
2 MR. SANDERS: That two-page color exhibit, with
3 the pictures of the board members, that will be No. 2.
4 (Plaintiff's Exhibit No. 2 was marked for
5 identification.)
6 BY MR. SANDERS:
7 Q Let me show you a copy of an e-mail. It says
8 from Padeeb@aol-dot-com.
9 Would that be you?
10 A Yes, sir.
11 Q That's your e-mail address.
12 And then it went to clsanders@bellsouth-dot-net.
13 It's dated Tuesday, October 17th. I'm going to ask you if
14 you recognize that. It's an attached Exhibit E to the
15 Complaint that's filed in this action.
16 (Mr. Sanders tendering document to witness.)
17 A Yes, sir; I -- I remember this.
18 Q What precipitated sending that -- that e-mail?
19 A If I remember correctly, there was a -- a notice
20 put on the Miss Jacksonville website page by Cammie, saying
21 that you-all weren't going to do the pageant anymore. And
22 I had not -- I was -- as the scholarship chairman, I was
23 saddened to see that you-all were going to be leaving, and
24 so I just -- I didn't know why you-all were leaving, so I
25 just wrote to say that I would miss you-all, and if it's
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1 not too personal, if I could ask why you were leaving.
2 You-all didn't have to answer me, because I'm just the
3 scholarship chairman, but that was what precipitated that.
4 Q Now, had you heard or received notice that the
5 pageant had not been renewed by the Miss Florida Pageant,
6 when you wrote --
7 A At the time I wrote this?
8 Q Yes, ma'am.
9 A To my knowledge, no. I think I just heard that,
10 you know, "Look on the web page; Kevin and Cammie are not
11 going to do their pageant anymore." I can't even remember
12 where I heard it from, it's been so long ago, but I do
13 remember, looking at this e-mail, though, that that's why I
14 sent it to you-all.
15 I would have sent something similar to anybody,
16 you know, I mean, especially -- we worked closely together,
17 I was going to miss you-all, and why were you leaving, if
18 you-all could share it with me.
19 Q Do you recall, in 2006, when the fall workshop
20 was?
21 A Oh, gosh. I know we have one every year.
22 Q If I --
23 A I can't remember back in 2006 right now, no.
24 Q If I were to tell you that it was, I think, the
25 weekend of October 14th, which would have preceded this
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1 e-mail, would that refresh your recollection?
2 A No, sir.
3 MR. SANDERS: That will be No. 3.
4 (Plaintiff's Exhibit No. 3 was marked for
5 identification.)
6 BY MR. SANDERS:
7 Q I'm going to show you another e-mail. Again,
8 it's Padeeb@aol-dot-com, which we've established is your
9 e-mail account, and it's to kevsand1@bellsouth-dot-net and
10 to clsanders@bellsouth-dot-net.
11 Kevsand1 would be Kevin Sanders?
12 A Yes, sir; I would assume, yes, sir.
13 Q Let me show that to you and see if you recognize
14 that.
15 (Mr. Sanders tendering document to witness.)
16 A Yes, sir. I had heard about the passing of your
17 father, and I just sent this as a condolence to you and
18 Cammie.
19 Q And you typed that, and that's what -- that's
20 what you had sent?
21 A Yes, sir.
22 Q And what was the time signature on that?
23 A Oh, the time? May 22nd, 2007, at 12:54.
24 MR. SANDERS: That would be No. 4.
25 (Plaintiff's Exhibit No. 4 was marked for
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1 identification.)
2 BY MR. SANDERS:
3 Q Let me show you your original message, and then a
4 response message of June 12th, 2007, and ask you if you
5 recognize that.
6 (Mr. Sanders tendering document to witness.)
7 A What was the question? I'm sorry.
8 Q Do you recognize that you received that e-mail at
9 some point in time?
10 A Yes, sir.
11 Q And was that e-mail in that format, and did it
12 come in response to your original e-mail?
13 A I would assume so.
14 You know, I'm looking at it here. This is what I
15 would assume. I don't have my copies of any of my AOL
16 stuff, so I'm assuming this is correct, sir.
17 Q Okay. Let me show you another version of this
18 e-mail and ask you if you recognize that.
19 (Mr. Sanders tendering document to witness.)
20 A No, sir. It doesn't even look like a format that
21 you would get in an e-mail. First, it doesn't say "re,"
22 the subject matter. I don't even recollect -- I mean, I
23 don't even recognize this as an e-mail transmission. I
24 don't remember getting anything like this.
25 Q Let me ask you -- the original e-mail, going back
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1 to Exhibit 5, you remembered that.
2 A I did say I remember it. I'm assuming it's
3 correct. I don't have my exact copies. As we know, a lot
4 of people can cut and paste in this day and age on a return
5 e-mail. I'm just assuming, as we're sitting here, that
6 that's the response that was sent to me on June 12th. I
7 don't remember exactly, it's been so long ago -- this is, I
8 mean, in June 2007 -- but I'm assuming that it's correct.
9 (Plaintiff's Exhibit No. 5 was marked for
10 identification.)
11 BY MR. SANDERS:
12 Q Did you forward this e-mail to anyone that you
13 can recall?
14 A I don't remember, but I probably would have
15 forwarded it to -- I probably would have forwarded it to
16 Mary, because I -- I wouldn't have known about any of this,
17 about being a -- I think this may have been the first time
18 I was ever noticed that I was going to be a witness in
19 this. I would assume I would have sent this to Mary. I'd
20 have to go back and look, but -- I mean, I don't have
21 records back that far in my AOL, but I would assume I sent
22 it to Mary, to ask what this was about.
23 Q And when you say "Mary," that's Mary Sullivan?
24 A Yes, sir.
25 Q Now, were you aware that that e-mail was used in
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1 a correspondence to the judge, claiming that Kevin Sanders
2 made an illegal and improper direct contact with someone --
3 A That was used in a what, sir?
4 Q That it was used as an illegal and improper
5 contact with you, as a witness in this case?
6 A I don't know to the fact that it was -- to a
7 judge?
8 Q Correct.
9 A If my memory serves me right, I think I was just
10 informed that we're to go through counsel, our legal
11 counsel, and that I'm not supposed to be just speaking out
12 openly unless I'm going through counsel. I think that's
13 what it was, but it's been so long ago. I think, if my
14 memory serves me correctly, that I shouldn't be openly
15 speaking unless we're in a formal setting.
16 Q There was a letter sent by Kristyne Kennedy, on
17 behalf of Mr. Block, on June 14th, 2007, that attached this
18 second exhibit -- which you did not recognize -- to the
19 letter, claiming indirect contact.
20 A Oh, okay.
21 Was it sent to me?
22 Q No. It was sent to Judge Taylor in this action.
23 A Oh, okay.
24 Q Let me just show you the Exhibit A that was
25 attached to that. And can you identify that the copy that
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1 you have in front of you is a true and accurate copy of the
2 one that's attached to Exhibit A?
3 A It looks the same.
4 Q Okay. And you've noted that it doesn't follow a
5 particular e-mail format.
6 A Well, it's the same statement. There's no --
7 there's no changes in the context of the note. It just --
8 the only thing different is the subject matter and "Sent
9 from the Internet." Those -- and, of course, the format.
10 The format is out of sync, but the context and content of
11 the e-mail states the same thing.
12 Q And you've received forwarded e-mails from people
13 at times; have you not?
14 A Oh, yes, sir.
15 Q And you know, maybe, when something is forwarded,
16 sometimes the format falls out of place.
17 A It does; yes, sir.
18 Q So this would look like a copy of a forwarded
19 e-mail; would it not?
20 MR. BLOCK: Objection to form.
21 THE WITNESS: It could be. I'm not sure.
22 All I know is that, if you were responding to me
23 by e-mail -- if I were responding -- let's say you
24 wrote this to me, and I was responding to you, it
25 would probably come back in this format, with the
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1 subject included.
2 BY MR. SANDERS:
3 Q And you're referring to Exhibit No. 5?
4 A Yes, sir.
5 That's how you would have -- I would have
6 received this response. But, as you said, when you forward
7 something, the format can get all out of whack.
8 Q And then, on the exhibit, what's going to be
9 Exhibit 6 -- we'll just go ahead and put it in as Exhibit
10 6 -- you've matched it up to be a true and accurate copy of
11 the -- of the one that's attached to the letter.
12 A The font size looks different, but --
13 Q It could be a difference in the copying.
14 A Yes.
15 Q Let me also point out to you one thing: In the
16 original e-mail, No. 5 -- if you'll look at No. 5 for just
17 a second -- what's the actual time signature? It's the
18 same date, June the 12th, but what's the time signature on
19 it?
20 A 6:01.
21 Q 6:01.
22 What's the time signature on the forwarded
23 e-mail?
24 A Seven o'clock.
25 Q Seven o'clock.
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1 Do you know if you had forwarded the original
2 e-mail, Exhibit No. 5, to Mary Sullivan shortly after you
3 would have received it on that date?
4 A See, I don't remember. I could have forwarded it
5 to her, or I could have called her on the phone. I don't
6 remember.
7 Q Well, if you hadn't forwarded it to her, do you
8 know how anyone would have gotten a copy of this
9 (indicating)?
10 A No, sir, I don't.
11 Q And the Exhibit 6 completely leaves off your
12 original message; does it not? The original message of
13 sympathy and condolences is not in that.
14 A Yes, sir.
15 Q And just for the record, you didn't -- when you
16 forwarded it, if you forwarded it -- you didn't delete that
17 section and only send the message, or did you?
18 MR. BLOCK: Objection to form.
19 THE WITNESS: I don't remember, sir. I don't
20 know why I would have done that, because it says,
21 "Thanks again for your sympathies."
22 BY MR. SANDERS:
23 Q And the "Thanks again for your sympathies" is not
24 included in Exhibit 6, is it?
25 A No, sir.
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1 (Plaintiff's Exhibit No. 6 was marked for
2 identification.)
3 BY MR. SANDERS:
4 Q Other than Mary Sullivan, do you remember
5 forwarding the original Exhibit 5 to anyone else? Would
6 you have forwarded it to Richard, or to Rob or would it
7 have been --
8 A I don't remember, sir. I normally would just
9 send things to Mary. If I did send it to anybody else, I
10 don't remember. I would have probably just sent it to
11 Mary, but I don't remember.
12 Q Let me show you an e-mail dated 9-17-2006, at
13 11:09 a.m., Eastern Standard Time. It says, "From:
14 Padeeb," which is you, "To: MaryCrwnMry."
15 Is that Mary Sullivan's e-mail address?
16 A Yes.
17 Q I'll ask you if you recognize that.
18 (Mr. Sanders tendering document to witness.)
19 A I don't remember this, but it looks like I'm
20 asking -- it says, "Cammie has decided, on her own..."
21 "What is this? On her own and on his own; is
22 there something else happening?"
23 I didn't understand the e-mail. It looks like
24 I'm just asking is there -- what's going on? Was it,
25 maybe -- and, at the time, if I remember correctly, maybe I
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1 was thinking that maybe it was something that you and
2 Cammie didn't agree on; that maybe one or the other wanted
3 to keep the pageant, and maybe the other one didn't. I
4 didn't know. I'm just assuming. That was an assumption.
5 I can't remember. And I'm probably asking, what else is --
6 I mean, because it does say, "Cammie, on her own..."
7 Q So it was your understanding at that time that it
8 was Cammie who had left, and not necessarily Kevin Sanders?
9 A No; I'm just asking, "On her own and on his own;
10 is there something else happening?" I didn't know, so I
11 was just asking the question.
12 Because I would need to know, as scholarship
13 chairman, what I'm to do next, because, you know, the local
14 pageant scholarships have to be paid, and I would need to
15 know the details of, you know, what's going on, if a
16 pageant is coming to -- you know, is going to end.
17 Q So, other than being concerned about who was
18 going to be running the pageant, did you have any other
19 concerns about this e-mail?
20 MR. BLOCK: Objection to form.
21 THE WITNESS: Yeah.
22 I wasn't asking who was going to be running the
23 pageant. I was just asking, "On her own and on his
24 own..." I didn't know what was happening here, so I
25 was just asking.
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1 I was always used to you-all sending e-mails as a
2 team, usually -- well, I did receive some from you, I
3 guess, or some from Cammie, because you-all served as
4 co's; but, "On her own..." I wasn't questioning
5 anything except I didn't understand that.
6 BY MR. SANDERS:
7 Q Now, the original message came on 9-16-2006, and
8 that was sent out by MaryCrwnMry, Mary Sullivan, and it
9 looks like those are the addresses for the board members;
10 is that correct?
11 A Yes, sir, it looks like it.
12 Q E-mail addresses for the board?
13 A Uh-huh.
14 Q And then your response was the next day, almost
15 to the hour.
16 Again, other than "On her own and on his own,"
17 did you have any other questions or concerns about the
18 e-mail or the canceling of the pageant?
19 A No, sir.
20 I was not questioning the fact that the pageant
21 was not ending, in all honesty -- and this is a personal
22 thing, and I don't mean to put anybody -- I thought maybe
23 it meant that, maybe, you and Cammie were separating.
24 That's what I, in all honesty -- I apologize, but that was
25 what I assumed when I saw that. I was trying not to put
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1 that in an e-mail, about being personal, but I was
2 concerned. You know, it was none of my business, but, to
3 be honest, I thought maybe that's what that meant, that
4 you-all might be separating as a couple -- not
5 pageant-wise, but as a couple -- and, like I said, that was
6 none of my business.
7 Q Well, did you find -- and again, I'm referring to
8 the part that was forwarded by Mary Sullivan, the alleged
9 posting on the website -- did you find that posting
10 offensive or concerning or upsetting, in any form or
11 fashion?
12 A What; this (indicating)?
13 Q Yes.
14 A No; because Cammie had written it. I mean, she
15 was only sharing something that had been written by Cammie.
16 MR. BLOCK: Objection as to form. Sorry, I
17 didn't get it in.
18 MR. SANDERS: That would be No. 7.
19 (Plaintiff's Exhibit No. 7 was marked for
20 identification.)
21 BY MR. SANDERS:
22 Q Let me show you another e-mail. It's dated
23 9-17-2006, at 1:19 p.m. Eastern Standard Time. It's from
24 Patty Adeeb to MaryCrwnMry; and, again, there was an
25 original message sent to you, below that, from Mary
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1 Sullivan. I ask you if you recognize that.
2 (Mr. Sanders tendering document to witness.)
3 A Is this -- this must be Mary's response to my
4 question here?
5 Q And I can't answer that for you. You need to
6 answer that for yourself.
7 A Okay.
8 Q But you're welcome to look at --
9 A Yeah. This is 9-17 -- okay, yeah, it looks like
10 it's possibly an answer.
11 Q So that's in response to what we've labeled as
12 No. 7?
13 A This is -- this goes back to what I said: It's
14 none of my business. I was thinking that maybe it was
15 because you-all might be separating as a couple, and
16 you-all were ending your pageant because you were
17 separating as a couple. And I was telling Mary that maybe
18 something big and personal is the catalyst of this, you-all
19 calling it quits in the pageant, and I was going to -- it
20 was none of my business, but I was going to try to see, you
21 know, as parts of our pageant family, if there's anything,
22 you know -- so if my memory serves me correct on that,
23 after I see this. So that's what my major concern was; I
24 thought that there might be a personal thing between you
25 and Cammie, which you would not have had to answer me at
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1 all.
2 Q Well, let me -- and again, when you had said you
3 were going to try to find something out, I'm just going to
4 go back to --
5 A I don't think I did, though, because I don't
6 think it was any of my business.
7 Q Again, remember, we were asking -- this is
8 Plaintiff's Exhibit 3 -- I was asking you, and I was
9 mentioning the dates on Exhibit 3. That's October 17th.
10 A Uh-huh.
11 Q Your response to Mary is on 9-17, so it's not --
12 A Okay. So I did ask; okay.
13 Q So you did --
14 A All right. I did ask, but I don't think you
15 answered me on a personal level; or, if you did, I don't
16 remember.
17 Q Well, now, there's a response, or --
18 A That was just Cammie -- was that Cammie?
19 Q -- indicating that the scholarships are going to
20 be paid.
21 A Yeah. That's Cammie saying that -- you know, I
22 was concerned, also, about -- I think I even spoke to
23 Cammie on the phone directly. I was concerned about the
24 scholarships, you know, the reports, and then Cammie was
25 kind enough to say everything was up to date, because I
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1 think I did call Cammie on the phone.
2 Q And did you have any concerns that scholarships
3 weren't going to get paid, or any problems --
4 A No, sir. I just was going to be helpful, if
5 there was anything -- because it was so -- you know, it was
6 just on the website, all of a sudden, that the pageant was
7 being canceled. And, you know, if that's part of my
8 duties, not just at the state level, but if there's
9 anything I can do to help at the local level, to make sure
10 everything gets done.
11 And, like I said, it could have been a personal
12 thing, and maybe you-all needed help with the scholarship
13 part of it. But that was never indicated, because Cammie
14 said everything was fine, that all the reports were up to
15 date. And that allowed me to know that I didn't need to
16 intercede to help with anything.
17 Q And did anything after that ever come up with
18 regards to scholarships; any complaints, failures to pay --
19 anything like that?
20 A Not to my recollection.
21 Q No titleholders called and said that they weren't
22 receiving their funds or anything?
23 A Not to my memory.
24 Q Okay. Now, I'm looking down at Mary's response.
25 She says, "Hi, Patty; I'm not privy to anything. I've
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1 never been contacted by Kevin or Cammie."
2 Did you or anyone suggest that Mary should
3 contact Cammie or Kevin with regards to this?
4 MR. BLOCK: Form.
5 THE WITNESS: No, sir. I don't know. I didn't.
6 I mean, you know, that --
7 BY MR. SANDERS:
8 Q Would that have been within what we've sort of
9 briefly talked about as her job description, to contact the
10 pageants?
11 A This is accurate. I mean, as far as I know, no
12 one knew, except by the website, that the pageant was being
13 canceled -- what Cammie wrote.
14 Q Let me ask you this, as being on the board since
15 2002: Are there any written rules or regulations, or is it
16 in the bylaws somewhere or even in, I guess, the local
17 contract that requires that a local ED notice the Miss
18 Florida Board or Mary Sullivan prior to canceling a
19 pageant?
20 A I don't know if it's written, but it's common
21 sense, you know, that if you're not going to have a local,
22 that you would call the directors at the state level and
23 let them know you're not going to be having your pageant.
24 Because as big a pageant as the Miss Jacksonville
25 is -- it was a very prestigious pageant; you know, Miss
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1 Jacksonville is one of our -- you know, Miss Jacksonville;
2 you know, that's a big pageant. You would think that you
3 would notify them that -- because all these young women are
4 impacted, that wouldn't have that pageant to compete in.
5 And I don't know to the fact -- if you-all notified them or
6 not. I don't know that information.
7 Q But, to your knowledge, specifically on the
8 question, do you know anything that's a part of a rule or a
9 regulation or is otherwise a requirement in the contract
10 that requires notice to Miss Florida prior to canceling a
11 pageant?
12 A Verbally, at our meetings, we have addressed
13 that, verbally, that, you know, there's protocol at our
14 workshops. But as far as writing, sir, I don't -- if it's
15 there, I haven't read it in a long time.
16 Q If it's there at all?
17 A If it's there; yes, if it's there.
18 But I do know that we do address these processes
19 at our workshops.
20 Q Now, it says, "I found everything out through
21 their website and Jennifer Herrington."
22 Who is Jennifer Herrington?
23 A Jennifer was a young person that -- well, younger
24 than me -- that worked with the Miss Jacksonville Pageant.
25 I know that there was a relationship -- that she worked
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1 with you-all. I don't know the capacity of her position,
2 at that time, in you-all's organization.
3 Q And I'm just going to ask: Wasn't she the
4 business manager for Miss Florida at that time?
5 A Jennifer Herrington served as a business manager
6 at one point. I'm not sure of the dates.
7 Q Do you know of any concerns regarding Jennifer
8 Herrington, when she was serving as business manager, with
9 some, perhaps, conflicts of interest with regards to
10 supporting or assisting certain women at Miss Florida?
11 A I don't -- I can remember something came up with
12 Jennifer Herrington, but the specifics of it, I don't
13 remember. I'm sorry. I do remember the words "conflict of
14 interest." I do. But I don't remember --
15 Q Did it promote a change in the rules to require
16 that the business manager not be associated with any local
17 pageant?
18 A That would make sense. Whether or not that
19 happened, I can't remember, but that would make sense, that
20 there should not be any conflict of interest if you're the
21 business manager at the state level. It's just like, I
22 can't judge a local pageant because I serve on the state
23 level. The same situation, I guess, would be applicable to
24 any of us; you should not have any conflicts of interest
25 that might be perceived as any type of favoritism to one
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1 pageant or another so that makes very good sense. Whether
2 or not there's anything specific to that, I don't remember,
3 sir.
4 Q You don't know if you saw it --
5 A Or I don't have knowledge of it.
6 Q You sort of remember Jennifer Herrington, and you
7 sort of remember "conflict of interest," but you can't --
8 A I do remember -- I do remember there was a
9 discussion about a conflict of interest. The specifics of
10 that conversation, or that discussion, I don't remember.
11 Q Was that discussion in a formal board meeting or
12 was it between you and Mary or --
13 A No. It was probably at our -- probably at a
14 board meeting, because I don't -- I don't have -- I don't
15 carry on very many private conversations with any of the
16 board members, in terms of an issue. I usually bring it
17 directly to the board, our full board meeting, for open
18 disclosure.
19 Q Do you know Jennifer Herrington well enough to
20 form an opinion about her?
21 A No, sir; not any more than I knew the other
22 people that worked -- she -- I remember, she'd bring her
23 family, and they'd -- to the state level pageant, and she
24 would help with the selling of some of our items, Miss
25 Florida items, but I didn't know her like a -- like on a
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1 personal friendship level.
2 Q Do you know if any titleholders have ever
3 complained about her?
4 A About Jennifer Herrington?
5 Q Yes.
6 A At this moment, I don't remember, but that's not
7 to say that that couldn't have happened, because we deal
8 with complaints all the time, you know, about one person or
9 another. There's -- young women get upset about certain
10 things, they'll call, there will be a discussion, we try to
11 help resolve it. We try to keep things at the local level
12 as much as possible, for their directors to handle, without
13 us being involved. But if we have to be involved, we will.
14 Q Do you know who Kylie Williams is?
15 A Oh, yes.
16 Q And you know her mother Barbara?
17 A Yes; I know her mother and father.
18 Q Let me show you an e-mail that came in. It was
19 provided to Miss Florida, Bates stamped 000431. You
20 probably won't recognize it, because it wasn't sent to you,
21 but I was just going to get you to read that.
22 And just to expedite time, I made a second copy.
23 (Mr. Sanders tendering documents to witness and
24 Mr. Block.)
25 A Who is this one? Who's writing this to you?
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1 Q Barbara Williams.
2 A Okay; Barbara Williams. Oh, this is her mother?
3 Q That's Kylie's mother?
4 A Oh, this is Kylie's mother. I'm sorry.
5 (Witness perusing document.)
6 And I don't know who she's referring to as
7 "they." I don't know who "they" or "them" is in this, who
8 Ms. Williams is referring to as "they" or "them."
9 Q Okay. But she expresses concerns about Jennifer
10 Herrington; does she not?
11 A Yes, she did. I'm not privy to that.
12 The bottom part, where it says there's a conflict
13 of interest, I can definitely say there's a conflict of
14 interest. If you're the business manager, you should not
15 be working on a local pageant, in my opinion.
16 Q And, at the time, she was working as an executive
17 director for the Miss Jacksonville Pageant and business
18 manager?
19 A I don't remember --
20 Q I don't remember that?
21 A -- what her the title was. I'm so sorry, I
22 don't. But, I mean, you-all could -- we could go back and
23 find those records, and then we could know what her exact
24 title was. I don't remember if she was working as a member
25 of the Miss Jacksonville team or if she was executive
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1 director. But if she was executive director and business
2 manager, I wouldn't -- I'd see that as a conflict.
3 Q But do you have any concerns about the feelings
4 expressed by Barbara Williams about Kylie going back, based
5 on Jennifer Herrington --
6 A I don't know who "they" or "them" is.
7 MR. BLOCK: Objection to form.
8 THE WITNESS: Yeah. I don't know who "they" or
9 "them" is, but I can just say, from my -- everyone
10 loves Kylie. She was a wonderful Miss Florida. I
11 have watched her grow in that pageant all the years
12 she's been ever there. I have never thought anything
13 of Kylie except the utmost respect and admiration for
14 her as a young woman. I've never heard anyone say
15 anything different in my presence about Kylie
16 Williams, ever, at our level.
17 BY MR. SANDERS:
18 Q Well, in Ms. Williams' letter, she talks about
19 Kylie --
20 A And Jennifer.
21 Q -- and I think I'm just going to go down one,
22 two, three, four, five -- five lines. It starts with
23 "...things to the board."
24 A To my recollection, if Jennifer said anything to
25 the board about Kylie Williams, I'm not privy to that.
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1 I've never had a discussion about Kylie Williams in a
2 negative way.
3 Q Well, I'm just trying to -- I'm going to read
4 this one section, and see if this explains the "they."
5 It says, "I don't know what Kylie has done to
6 her..." speaking of Jennifer Herrington "...Emily or
7 Candace, but all three do not like her, and nothing will
8 convince me that they do. If Kylie ever won Miss Florida,
9 I know Kylie would accept Jennifer as her manager, but I
10 know Jennifer would never want to be manager to Kylie. We
11 have bent over backwards to be nice to all three..." again,
12 mentioning Jennifer Herrington, Emily and Candace --
13 A Oh.
14 Q "...and I will not do that anymore. I don't care
15 what they say about me..."
16 I'm thinking "they" is Jennifer, Emily and
17 Candace on there, since --
18 "...say about me or how they treat me, but that
19 is my child they are talking about and treating ugly, and I
20 am..." going -- not going to go out of my way to be nice to
21 them.
22 A If, in actuality --
23 MR. BLOCK: One, I don't know if there's a
24 question there yet, but --
25 THE WITNESS: Okay.
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1 BY MR. SANDERS:
2 CQ1 Does that explain to you who the "they" is?
3 A That's what I was going to say.
4 MR. BLOCK: Now -- now let me object.
5 I'm going to object to form, and I'm going to
6 object to relevance. I'm going to certify the
7 question. This is where I'm talking about getting off
8 base, for this witness to try to divine what someone
9 else means by the word "they," in a document she's
10 never seen before today; she's not copied on it.
11 She's -- this is losing focus and, to me, is beyond
12 where the judge wants us to be.
13 THE WITNESS: I agree. This is subjective, and I
14 don't know what this has to do with anything.
15 BY MR. SANDERS:
16 Q Well, and again, I think it's important
17 because -- and again, we haven't finished on this e-mail up
18 here, but the e-mail from Mary to you says, "I'm not privy
19 to anything. I've never been contacted by Kevin or
20 Cammie."
21 This is the first paragraph in her e-mail to you.
22 "I found everything out through their website and
23 Jennifer Herrington."
24 She doesn't mention any other source for
25 information, does she?
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1 A No, sir.
2 Q Did she ever mention to you any source of any
3 information, other than Jennifer Herrington, in any other
4 e-mails that you may have received?
5 A I'd have to -- we're talking about 2007. We'd
6 have to go back and look at -- if you have any other
7 e-mails for me to look at.
8 Q And I do.
9 A Yeah; because I don't remember.
10 Q So you never knew that Ms. Williams had any
11 problems or concerns with Jennifer Herrington?
12 A Not to my knowledge. I don't remember any of
13 this.
14 MR. SANDERS: Let me show you another e-mail.
15 And, I guess, for -- just preserving the record,
16 we're going to put in as Exhibit 8 -- this would be
17 the e-mail between Ms. Adeeb and Mary Sullivan on
18 9-17-2006, at 1:19; the e-mail from Barbara Williams
19 as No. 9.
20 (Plaintiff's Exhibit Nos. 8 and 9 were marked for
21 identification.)
22 BY MR. SANDERS:
23 Q And just let me show you a letter from a former
24 titleholder of the Miss Jacksonville Pageant, talking about
25 Jennifer Herrington while she was involved in the pageant.
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1 (Mr. Sanders tendering document to witness.)
2 MR. BLOCK: Not to break into the line of
3 questioning, I'll just have a standing objection that
4 I'd like to certify that this line of questioning
5 regarding e-mails not sent to, received by, copied to
6 the witness is beyond the scope of the judge's order
7 regarding the depositions of board members.
8 MR. SANDERS: And again, I'm just going to put on
9 the record that the judge didn't give any parameters,
10 except for with regards to time frames and dates.
11 And again, we were addressing the e-mail of Patty
12 Adeeb to Mary Sullivan and a reference that the source
13 of information was Jennifer Herrington, which makes
14 this relevant.
15 MR. BLOCK: Well, we can agree to disagree.
16 And the date of this is 2007.
17 THE WITNESS: But, also, "Jennifer...who called
18 to let me know what was going on," just that you-all
19 were -- and I don't know what "going on" means. It's
20 just -- to me, it just references that the website
21 says that you are canceling the pageant and that
22 Jennifer Herrington called to confirm that.
23 What happened in that conversation between them,
24 I don't know. And I've never seen these. I don't
25 know anything about this stuff.
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1 BY MR. SANDERS:
2 Q In reading the comments of Stevie Rivenbark, do
3 you have any concerns with regards to Jennifer Herrington,
4 or do you just dismiss this as one disgruntled former
5 titleholder?
6 MR. BLOCK: Objection to foundation and form.
7 THE WITNESS: I don't take anything lightly from
8 a young woman who has a complaint. If this complaint
9 had been sent to me, I would have addressed this
10 openly in a board meeting, to discern the accuracy of
11 the accusations being made.
12 BY MR. SANDERS:
13 Q And then, she complains that, during her reign as
14 Miss First Coast in 2005, Jennifer Herrington did nothing
15 but belittle, sabotage, and lie to her?
16 A But that's her word -- I mean, that's her
17 wording. I don't know if those are true. They would have
18 to be checked out. I don't know.
19 MR. SANDERS: And this will be No. 10.
20 (Plaintiff's Exhibit No. 10 was marked for
21 identification.)
22 (Discussion off the record.)
23 (Brief recess.)
24 BY MR. SANDERS:
25 Q Now, Jennifer Herrington has been granted a
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1 pageant; is that correct?
2 A Now?
3 Q Yes.
4 A To be honest with you, I have been totally out of
5 the loop for a lot of the year, due to my job.
6 MR. BLOCK: I'm going to have a standing
7 objection to the questioning about current events.
8 THE WITNESS: Okay. I am not up-to-date, as I
9 should be. I'm up to date with all of my
10 scholarships, but in terms of this year, my job has
11 been very demanding, and I have not been able to
12 participate as I would like this year.
13 BY MR. SANDERS:
14 Q Did you receive any notices with regards to her
15 applying for a local pageant?
16 MR. BLOCK: Standing objection.
17 THE WITNESS: I will tell you that I have missed
18 out on some e-mails that I may have overlooked, due to
19 not paying attention to AOL lately, and being out
20 of -- AOL is not usually my -- it's my outside -- my
21 business e-mail is the one I've been addressing
22 lately, and I have not been participating; and, if
23 there was one, I could have overlooked it. I'm sorry.
24 BY MR. SANDERS:
25 Q Okay. You didn't participate in any board
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1 meetings where she was granted the pageant?
2 A Not to my knowledge.
3 Q Let me ask you this, and we'll get into a little
4 more detail later: Has the process of granting local
5 franchises changed in any way since 2006?
6 MR. BLOCK: Same standing objection.
7 THE WITNESS: Not to my knowledge.
8 BY MR. SANDERS:
9 Q Okay. What was the process in 2006 with regards
10 to obtaining local franchises?
11 MR. BLOCK: Foundation.
12 THE WITNESS: Yeah.
13 It usually comes to vote; the applications come
14 forward, and the board votes -- if you have a quorum,
15 of course -- would vote.
16 BY MR. SANDERS:
17 Q Who gets the ultimate decision on a local
18 franchise?
19 MR. BLOCK: Objection to foundation.
20 THE WITNESS: Yeah.
21 It's normally a vote, a decision vote by the
22 board.
23 BY MR. SANDERS:
24 Q Well, is it -- and again, I've got so many boards
25 I'm dealing with.
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1 A Now, when I say "board," I mean all of us that
2 attend the meetings. And that's the executive board and
3 all -- like those photographs that you would have seen --
4 field directors, vice president, CEO, and Mary, scholarship
5 chairman -- all the people that people in -- monthly.
6 Q All the people that were in the photos --
7 A Those have changed now, but --
8 Q Yeah; which have changed.
9 A Yeah.
10 Q But it's the full board that gets to vote.
11 A Yeah.
12 Q So this is not a process, then, that --
13 A Minus legal counsel and CPA.
14 Q Yeah; the exceptions that you had testified to.
15 A Yes, sir.
16 Q So it's a full board that makes the decision,
17 then, final decision on pageants?
18 A That would be my assumption; yes, sir.
19 Q Is it an assumption, as a board member since
20 2002, or --
21 A I mean, if there's been any discrepancy to that,
22 I don't remember.
23 Q So it's not an executive board decision; it's a
24 full board decision?
25 A That would be my understanding.
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1 Q Well, and let me just ask you: Has that process
2 changed since 2006, that it's still a full board decision?
3 MR. BLOCK: Same objection, as a standing
4 objection.
5 THE WITNESS: If it's changed, due to my lack of
6 availability to the pageant this year, I'm not privy
7 to it.
8 BY MR. SANDERS:
9 Q Okay. So you're not aware of any changes?
10 A No, sir.
11 Q Okay. And you're not aware of anything that came
12 up for a full board vote, with regards to Jennifer
13 Herrington getting a local franchise?
14 MR. BLOCK: Standing objection.
15 THE WITNESS: No, sir.
16 BY MR. SANDERS:
17 Q And do the e-mails that you've looked at, from
18 Barbara Williams, mother of the former Miss Florida, and
19 from a local titleholder, Stevie Rivenbark, have any
20 concerns for you with regards to Jennifer Herrington
21 running a local franchise?
22 MR. BLOCK: Same standing objection.
23 THE WITNESS: As I stated before, I don't put
24 much credence into a lot of things without research,
25 but I don't take any concern lightly.
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1 If a parent or a titleholder makes a complaint,
2 then I think it should be looked into with great
3 concern for what is being stated, and then to check
4 out the accuracy of it, because it may not be true for
5 the person making the accusation, or it may be true.
6 And, I mean, I think we take that part of our role
7 very seriously -- at least, I do; and I think almost
8 all the board members that are on that board do, too.
9 I wouldn't want a young lady feeling that way about
10 any of us that are serving in the capacity of
11 supervising these young women, to feel that way.
12 BY MR. SANDERS:
13 Q Did you ever hear from any titleholders, or
14 anyone, that Jennifer Herrington would have pajama parties
15 with the titleholders?
16 A No, sir.
17 MR. BLOCK: Again, a standing objection.
18 BY MR. SANDERS:
19 Q Would that cause you any concern?
20 MR. BLOCK: Same standing objection.
21 THE WITNESS: When you say "standing objection,"
22 am I not to answer?
23 MR. BLOCK: No, no, no.
24 What I'm trying to do is put on the record that I
25 don't think we should be asking these questions, but I
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1 don't want to interrupt the flow of the deposition.
2 I'll take it up with the judge at another time.
3 THE WITNESS: A pajama party with the young
4 women? I don't know in what capacity, but I -- it
5 depends on the nature of it.
6 No; they have get-togethers and socials and
7 spend-the-nights and building collegiality among the
8 young women and the directors. And, no, sir, I
9 wouldn't see anything wrong with that, unless somebody
10 said something happened at an event like that, or if
11 there was a reason to question it.
12 BY MR. SANDERS:
13 Q Well, do you think an executive director should
14 be a role model and somebody who gives guidance, or someone
15 who should be on the same level as the titleholder?
16 MR. BLOCK: Standing objection, plus form.
17 THE WITNESS: In leadership, I believe that we
18 are role models, but there are different forms of role
19 models; and there's different levels of maturation, of
20 course, for all human beings.
21 In terms of guidance, our job is to guide them in
22 the pageant process. As far as being a mentor in
23 other areas, that is totally subjective; and, unless
24 there was a concern or a definite complaint made by a
25 young woman that someone had overstepped their bounds
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1 from the pageant role of guidance, then that would be
2 the only way I would think that we would intercede in
3 something like that.
4 BY MR. SANDERS:
5 Q Let me go back to an e-mail between you and Mary
6 Sullivan. I believe that's Exhibit No. 8. I'm looking at
7 the very next paragraph, where it says, "Kevin doesn't seem
8 to be acting in a responsible or logical manner."
9 Did you ever have any conversations with Mary
10 Sullivan, other than this e-mail, as to why she believed
11 that Kevin was acting in an -- that Kevin did not seem to
12 be acting in a responsible or logical manner?
13 A If we did, if my memory serves me -- if we did, I
14 don't remember any conversations. But when she says
15 "responsible or logical," she's referring to notification
16 that the pageant was going to be canceled.
17 Q And again, if you'll look down at the bottom, it
18 says, "Obviously, there is more than meets the eye, but I
19 don't know what it is. Neither Kevin or Cammie have
20 followed protocol of informing the MFP of their intent to
21 no longer participate as executive directors."
22 What protocol is written with regards to that?
23 A As I stated, if it's written, I haven't reviewed
24 it. But we do verbally address this in our fall workshops,
25 with all of our executive directors, that, you know, if
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1 there's any concern that a pageant would not, you know,
2 take place on a certain date, we need to be notified
3 immediately. We need to know how we can help. We need to
4 know what the reasons are.
5 Q Have any other executive directors, to your
6 remembrance, ever canceled a pageant without notice to the
7 Miss Florida Pageant, and then later rescheduled it and put
8 it on?
9 A Not if it was a confirmed -- to my knowledge, not
10 if it was a confirmed pageant. They might change the date,
11 but they've always notified us, in my understanding, that
12 the date has been changed, not -- and there's a difference
13 between canceling totally and just changing a date. You
14 send the change of date, that we can't make it happen on
15 this date, so we're going to move it to this date, so they
16 would notify us of that. But in terms of a cancellation, I
17 would say that we've been notified, to the best of my
18 knowledge, on anybody that's canceled a pageant; and, if
19 not, I'm not -- I don't remember.
20 Q Do you know if Barbara Whitehead ever canceled a
21 pageant without informing the Miss Florida Board, only
22 later to reschedule it and put it on?
23 A Not to my knowledge.
24 I mean, she may have changed a date, postponed it
25 to another date, but Ms. Whitehead's usually let everybody
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1 know, to my knowledge, what she's doing. I've never heard
2 any concern otherwise; or, if there was a concern, I don't
3 remember.
4 Q Do you recall if Kathie Dudley ever had to cancel
5 pageants, move them around, and then later informed Miss
6 Florida of that?
7 A Again, if they postpone and move a date, there's
8 a difference between postponing and moving a date and
9 canceling a pageant completely.
10 Q Well, and again --
11 A Because a local director has the right to
12 postpone a date and change it so that the venue can be as
13 successful as possible for them, because they've got to
14 provide the moneys, the scholarship -- everything.
15 So you have to have trust that the local
16 director, you know, if they're postponing their date,
17 they're trying to find a date that's most convenient and
18 physically successful for them. But in terms of canceling
19 a pageant, then that is different -- that's just a
20 different scenario altogether. You really need to know how
21 to move forward with getting that pageant re-set up again,
22 are those people -- I mean, do you need to even consider
23 setting up the pageant again before the annual state
24 pageant? Will it just be out of commission for that year
25 totally? Is there anyone to step in and take over that
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1 pageant? There's a lot of technical things that have to be
2 done if a pageant is being canceled, I mean, just being
3 canceled and not going to happen at all.
4 Q And again, I'm going to ask from a semantical
5 standpoint: If you postpone a pageant, and you move it to
6 a new date, the original date has been canceled; has it
7 not?
8 MR. BLOCK: Objection to form.
9 THE WITNESS: It might be canceled in that
10 person's mind. It doesn't mean there's been a formal
11 notification of the cancellation or the postponement.
12 There's a difference between being canceled and
13 postponed, like I said, and being canceled totally.
14 BY MR. SANDERS:
15 Q Okay. But postponing a pageant to move it to
16 another date means the original pageant date has been
17 canceled?
18 MR. BLOCK: Same objection; and argumentative.
19 MR. SANDERS: Did you have an answer on that?
20 THE WITNESS: Would you repeat that question?
21 I'm sorry.
22 MR. SANDERS: And again, he can have a standing
23 objection.
24 BY MR. SANDERS:
25 Q I just said: Canceling an original date for a
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1 pageant and moving it to another date still means that the
2 original date is canceled, even though the pageant still
3 goes on?
4 MR. BLOCK: Prior objection standing.
5 THE WITNESS: I guess that goes back to
6 semantics. It depends on what you mean by
7 "cancellation."
8 MR. SANDERS: Correct.
9 THE WITNESS: I wanted to see this.
10 (Witness perusing document.)
11 I just had to re-read that again, to make sure I
12 remembered it right. Thank you.
13 BY MR. SANDERS:
14 Q Let me show you another e-mail and ask you if
15 you've ever seen this or were informed of it at any point
16 in time.
17 (Mr. Sanders tendering document to witness.)
18 This e-mail is dated 9-16-2006, at 5:40 p.m.
19 Eastern Standard Time. It says the subject is Miss
20 Jacksonville and Miss First Coast. It's from MaryCrwnMry
21 to Ray McLeod, JPH Angel --
22 Do you know who JPH Angel is?
23 A No, sir; that name doesn't sound familiar to me.
24 Q It says "rwalker@miami.edu"?
25 A I know "rwalker," Richard.
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1 Q Richard Walker. And it says "LOYTPA"?
2 A Rob.
3 Q That's Rob Loy?
4 JKW61, would that be Keith Williams?
5 A Keith; yes.
6 Q And then MAMAKIT777, would that be Kitty Potapow?
7 A Kitty, yes.
8 I can't remember who is JPH.
9 (Witness perusing document.)
10 Okay. I don't remember seeing this e-mail, no,
11 sir, because it wasn't written to me.
12 Q Okay. This e-mail was never put before the board
13 of directors, the full board of directors?
14 A I can't say that. It could have been. It could
15 have been a meeting I missed. I don't know. I can't say
16 that for a fact, sir.
17 Q But you haven't actually seen it?
18 A No, sir; I don't remember seeing it.
19 Q I'm just going to point out a couple of specific
20 matters. And again, this is from Mary Sullivan, because it
21 says "From: MaryCrwnMry"; is that correct?
22 A Yes, sir.
23 Q On the second paragraph, she says, "I..." which I
24 assume is referring to herself, Mary Sullivan "...have
25 assured Jennifer and Jeff that they will have our support
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1 and assistance, especially within (sic) the next few
2 weeks"; is that correct?
3 A That's what it says, sir.
4 Q Okay. Does she have the authority, as the
5 president or the executive director, to make those
6 assurances to Jeff and Jennifer?
7 MR. BLOCK: Foundation.
8 THE WITNESS: From my opinion, yes, she does,
9 because she's our executive director; and, at this
10 time, this was a crisis, it looks like, where she was
11 trying to allow a pageant to continue, and she was
12 just trying to make sure something could happen, if
13 possible, and that we would provide whatever support
14 we could, and assistance.
15 BY MR. SANDERS:
16 Q I'm going to go back up to the paragraph above
17 that, where it -- I guess it would be the second sentence.
18 It says, "They were going to cancel the upcoming pageant of
19 October 21st, 2006, but Jennifer and Jeff Herrington have
20 stepped in and are going to direct the pageant."
21 Does Mary Sullivan have the authority to tell
22 somebody that they can or cannot direct or be the executive
23 director of a pageant?
24 MR. BLOCK: Foundation.
25 THE WITNESS: She would have our support; but,
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1 also, Jennifer was listed as a co-ED for that pageant
2 at some point, so -- then she technically resigned as
3 business manager --
4 MR. SANDERS: Well, that was the next thing I was
5 going to address.
6 THE WITNESS: Yeah. She was already -- she had
7 already been a co-ED; and, as far as I know, there was
8 no -- it reads here that she's meeting with Cammie and
9 that -- it looks like it's just a means to keep the
10 pageant going for the next -- just to let the pageant
11 happen October 21st. It doesn't mean she's going to
12 be the official continued person in this capacity;
13 it's a stand-in, just to get the pageant up and going
14 by October, and then, of course, it would have to come
15 to a vote.
16 BY MR. SANDERS:
17 Q Well, and it doesn't say anywhere in there that
18 they're just stand-ins, does it?
19 A No, sir.
20 But, you know, the normal process is to vote on
21 who is going to be -- but this is a -- like I said, this
22 was a crisis situation. And in that role, as director and
23 president of the Miss Florida pageant, we trust them to
24 make some decisions that have to be made very quickly. And
25 I'm sure, if there had been any doubts on this, that it
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1 would have come before -- somebody would have stepped up
2 and said something, and this would not happen, if there
3 were any concerns.
4 Q Well, again, you don't know if this e-mail was
5 sent to the entire board or not, do you?
6 A It doesn't state that it's sent to the entire
7 board. It says the -- it's the executive board.
8 Q And then I'm going to address that one. It's the
9 final paragraph.
10 It says, "Jennifer was listed as the co-ED, and
11 while she technically resigned to act as business manager,
12 that was never made public past the executive board;
13 therefore, we are adding her back as executive director,
14 again an executive board decision."
15 A Uh-huh.
16 Q Now, does the executive board have that
17 unilateral authority, based on your previous testimony that
18 things like that are a full board decision?
19 MR. BLOCK: Foundation and form.
20 THE WITNESS: I'm just saying that this was a
21 moment of crisis. It does not mean that this was a
22 continued -- this is just a temporary position, in my
23 opinion, just to get the pageant off the ground on
24 October 21st. Further, in-depth discussion would have
25 come before the board at a later point.
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1 BY MR. SANDERS:
2 Q Did it, to your knowledge?
3 A I'm just -- I do remember the things about the
4 business manager being told that she was -- this has been
5 so long ago, it's -- I mean, you know, we approve a lot of
6 pageant directors on a regular basis.
7 This was a crisis here, though. This was just
8 crisis mode, someone stepping in as our president, that we
9 have to trust, just to get the pageant on. And that's what
10 I'm reading that as but that's just my own, personal, you
11 know, look on that.
12 Q Does the executive board or Mary Sullivan have
13 the power to just ignore a resignation just because it
14 wasn't made public?
15 MR. BLOCK: Form and foundation.
16 MR. SANDERS: I'm just reading what it says here.
17 It says, "She was listed as the co-ED, and while she
18 technically resigned to act as business manager, that
19 was never made public..."
20 THE WITNESS: I don't know what that means. Mary
21 wrote that. You'd have to ask her.
22 BY MR. SANDERS:
23 Q And, I guess, I'm just asking you, if Mary wrote
24 that, and that was the action, does the executive board
25 have the authority to ignore a resignation?
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1 MR. BLOCK: Again, form and foundation.
2 THE WITNESS: Yeah.
3 I have no comment on that. I just -- I don't
4 really know how to answer that.
5 BY MR. SANDERS:
6 Q And again, this goes back to what we were
7 discussing earlier, the fact that you knew Jennifer
8 Herrington, there was a possible conflict of interest, and
9 that's why she had resigned to be business manager.
10 A Uh-huh.
11 MR. BLOCK: Same objection.
12 MR. SANDERS: That will be No. 11.
13 (Plaintiff's Exhibit No. 11 was marked for
14 identification.)
15 BY MR. SANDERS:
16 Q Let me show you another e-mail -- it's a forward
17 from Kevin Sanders by Ray McLeod to MaryCrwnMry; it was
18 sent out on 9-18-2006, at 3:34 p.m. -- and ask you, did you
19 ever see that or receive a copy of it?
20 (Mr. Sanders tendering document to witness.)
21 Just for reference sake, it was entered in as
22 Plaintiff's Exhibit 14 in the Sullivan deposition.
23 A (Witness perusing document.)
24 This one says "we're quitting," and this one says
25 "we're not," so --
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1 BY MR. SANDERS:
2 Q Well, let me, maybe, point something out to you
3 on the one that you keep referring back to.
4 A Yeah; because I'm reading that you're stating
5 that, you know -- and then this one says that "I cannot
6 renew the franchise," but you're saying in that one that
7 you're not.
8 Q If you want, you could read it again.
9 Is there anywhere in the statement sent to you --
10 I believe it's Exhibit No. 7 -- is there anywhere in there
11 that says Kevin Sanders had resigned, or did it indicate
12 that the pageant couldn't go forward with the North Florida
13 Scholarship Organization?
14 MR. BLOCK: Objection to the form.
15 THE WITNESS: And I go back to the original --
16 well, all I know is that the pageant was canceled
17 completely, there was a crisis mode. Whether or
18 not -- and I can't remember exactly what happened in
19 terms of everything -- if we voted on you, we voted on
20 her -- I don't remember. It's been so far back,
21 Kevin, I truly don't remember -- I mean, Mr. Sanders.
22 I'm sorry. I don't remember.
23 BY MR. SANDERS:
24 Q Now, the original e-mail on what's going to be
25 Exhibit No. 12, that's from Ray McLeod to Mary. It's a
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1 forward of the e-mail from Kevin Sanders to Roy McLeod; is
2 that correct?
3 A Yes, sir.
4 MR. SANDERS: That will be No. 12.
5 (Plaintiff's Exhibit No. 12 was marked for
6 identification.)
7 BY MR. SANDERS:
8 Q And you've never seen that e-mail; that was never
9 brought up at any board meetings or --
10 A If it was, I don't remember.
11 Q This e-mail wasn't forwarded to your attention?
12 A Not to my knowledge, sir. I didn't really finish
13 reading that last paragraph.
14 Q Oh, I'm sorry. Go ahead.
15 A (Witness perusing document.)
16 Q Let show you a response from Ray McLeod to Kevin
17 Sanders. And, if you want, you can compare the -- the
18 bottom portion is --
19 A Yeah.
20 Q -- is the same.
21 A "Please call me this afternoon to discuss this
22 situation."
23 Q And are you familiar enough with Ray McLeod to
24 know that that's sort of his stamp and address and phone
25 numbers?
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1 A Yes, sir, to the best of my knowledge.
2 MR. SANDERS: Okay. That will be No. 13.
3 (Plaintiff's Exhibit No. 13 was marked for
4 identification.)
5 BY MR. SANDERS:
6 Q And his indication was to call?
7 A Yes, sir.
8 MR. BLOCK: Objection to form, to his indication.
9 THE WITNESS: Based on that e-mail that I'm
10 looking at.
11 MR. BLOCK: The documents say what they say.
12 BY MR. SANDERS:
13 Q Were you ever informed of any telephone calls or
14 conversations between Kevin Sanders, Ray McLeod and Mary
15 Sullivan about the Miss Jacksonville Pageant?
16 A Not directly, sir.
17 Q Who did you hear it from, if it didn't come
18 directly?
19 A When I say "directly," I mean anything I would
20 have heard would have been at a board meeting, with
21 everybody there, or, you know, if an e-mail had been sent
22 out to everybody, because the only part I have in here is
23 the scholarships.
24 Q But again, you're a board member?
25 A Yes.
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1 And if there was a vote called, I would be a
2 party of that vote, if I'm there.
3 Q But, to the best of your recollection, you don't
4 recall Mary mentioning anything or forwarding any e-mails
5 with regards to a telephone conference between herself,
6 Kevin Sanders and Ray McLeod?
7 A No, sir, not to my knowledge.
8 Q Now, I'm trying to look at the time signatures on
9 Exhibit 12 and 13. Ray forwarded the original -- well, the
10 original e-mail went to Ray on September 18th, 2006, at
11 3:31 p.m.; is that correct?
12 A According to the e-mail, it states that.
13 Q And then it was forwarded to Mary Sullivan
14 9-18-2006, the same day, at 3:43; is that correct?
15 MR. BLOCK: Foundation.
16 THE WITNESS: Per the e-mail.
17 BY MR. SANDERS:
18 Q Per the e-mail.
19 Let me show you a copy of an e-mail from Kevin
20 Sanders to Mary Sullivan, with a cc to Ray McLeod, dated
21 September 18th, 2006, at 5:11 p.m., later on that day.
22 (Mr. Sanders tendering document to witness.)
23 A Yes, sir.
24 Q Was this ever forwarded to you or to the board,
25 as far as you know?
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1 A I don't remember. This is back in 2006. I don't
2 remember. I'm so sorry; I don't.
3 Q Okay. So it might have been, but you just don't
4 remember?
5 A It would have -- I don't see any reason to
6 forward that to me. I don't know -- because I don't even
7 know what you're thanking them for. I don't know why it
8 would be sent to us, unless there was something with it.
9 MR. SANDERS: And that will be the next e-mail.
10 (Plaintiff's Exhibit No. 14 was marked for
11 identification.)
12 BY MR. SANDERS:
13 Q This is a two part e-mail; first, an e-mail
14 original message from MaryCrwnMry -- who we've established
15 is Mary Sullivan -- to Kevin, kevsand1@bellsouth-dot-net,
16 with a cc to Ray McLeod. This is dated September 18th,
17 2006, at 11:06 p.m., the same date, and then a reply from
18 Kevin Sanders to MaryCrwnMry, on Tuesday, September 19th,
19 2006, at 10:49 a.m.
20 (Mr. Sanders tendering document to witness.)
21 I'll ask you to look at that and tell me if
22 you've ever seen that before.
23 A I think I do remember seeing this at the board
24 meeting. I remember something about this; not necessarily
25 do I remember your response, but I do remember this from
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1 Mary -- not necessarily seeing the exact e-mail, but the
2 content of the e-mail.
3 Q Okay. And you think that was at a board meeting
4 that you saw that?
5 A Not a board meeting -- well, at the workshop, the
6 happening when we vote for the -- we can vote at any time
7 when a pageant puts through an application. I think it was
8 at the workshop, and we do have board meetings at the
9 workshop.
10 Q And when you're talking about a workshop, are you
11 talking about --
12 A Like orientation or --
13 Q Would it have been --
14 A -- of the executive directors. You know, like
15 we're getting ready to have our -- well, we're getting
16 ready to have an orientation now, but we usually have a
17 fall workshop, too; fall.
18 Q So would this have been brought up at the fall
19 workshop in 2006?
20 A It wouldn't be brought up in front of all the
21 executive directors -- I mean, you know, all the locals,
22 but it would be announced who got the awards.
23 But I do remember they said you were going to --
24 you were going to -- they told you that you could present
25 an application. That's what I remember.
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1 Q Well, again, let's look at the original message
2 from Mary Sullivan. It says, "Dear Kevin, I am pleased
3 that we could talk about the situation and resolve most of
4 the issues. We value your long-time participation and want
5 to see it continue. I would like to confirm some of the
6 things we discussed today."
7 A Yes, sir.
8 Q It says, "One: You will be listed as the
9 executive director of the Miss Jacksonville Pageant and
10 will exercise a franchise agreement for that pageant on or
11 before October 14th, 2006."
12 A Yes, sir.
13 Q Do you know if Kevin Sanders was actually listed
14 as the executive director --
15 A I don't know.
16 Q -- after this e-mail was sent?
17 A "...and will execute a franchise agreement on or
18 before October 14th..."
19 I don't know the specifics of that; no, sir, I
20 don't, because there's a date here.
21 Q Well, again, we had talked about Mary appointing
22 or putting Jeff and Jennifer in as directors.
23 Does she have the power and authority to make an
24 agreement or an understanding with Kevin Sanders with
25 regards to the Miss Jacksonville Pageant?
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1 MR. BLOCK: Foundation.
2 THE WITNESS: I don't think you were listed as an
3 executive director. So, if you weren't listed as an
4 executive director, I don't think she has to do that
5 at all. Because Jennifer was already listed as a
6 former executive director, she probably would have
7 been the most logical person to step in and help us
8 out of the crisis. But I don't remember the
9 specifics, if you were listed as ED at that time.
10 BY MR. SANDERS:
11 Q Do you have personal knowledge of whether or not
12 the franchise agreement, as required, was sent for
13 consideration on or before October 14th, 2006?
14 A If I remember correctly, I don't think yours
15 arrived when the -- when the board met. I don't think your
16 thing -- your application was there. Oh, this has been so
17 long ago. I don't think yours was there to vote on.
18 That would have to be double-checked, but I don't
19 think it was there when the board met to vote.
20 Q Now, the date in this e-mail, the deadline is
21 October 14th, 2006; is that correct?
22 A That's what it says, sir; on or before, yes.
23 Q Let me just show you the Miss Florida Executive
24 Board meeting minutes of September 23rd, 2006, which was
25 before the October 14th deadline.
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1 (Mr. Sanders tendering document to witness.)
2 Have you ever seen those?
3 A I don't remember.
4 Q Well, let me just --
5 A Yes, sir.
6 Q I'd have to -- you will acknowledge that it says:
7 Miss Florida Executive Board Directors Meeting, September
8 23rd; Home of Mary Sullivan, in Miami?
9 A Yes, sir.
10 Q Okay. And it mentions Mary Sullivan, Richard
11 Walker, Keith Williams and Rob Lowe (sic) -- I always say
12 that -- Rob Loy was present?
13 A Uh-huh.
14 Q If you'll look at the second page, the very last
15 entry, it says, "Franchises that were presented for
16 approval..." and it lists Jacksonville; does it not?
17 A Uh-huh.
18 Q So based on the minutes of the executive board
19 meeting of September 23rd, it had been received by the
20 October 14th deadline; had it not?
21 MR. BLOCK: Foundation.
22 THE WITNESS: No, sir, I don't know that. I
23 don't know. It just says you're to have it on or
24 before October 14th, but it says "...full board in
25 October, and possible discussion with Kevin..."
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1 I don't know. I don't know when you -- when the
2 thing was received. I don't know the date, sir.
3 BY MR. SANDERS:
4 Q All right. Well, that's fair enough. You
5 weren't listed as one of the persons in the executive board
6 meeting, but I'm just going to point out, I guess, the line
7 just above that, where it says, "Franchises that were
8 presented for approval..."
9 A And usually they're presented to us, and we vote.
10 We can sometimes vote via e-mail. We have an e-mail --
11 like, they'll send out a name, and they'll say, "Please
12 send forth your vote. Do you agree that this should be an
13 approved franchise?"
14 And we all send in our votes, and they're
15 tallied, and that's how that can be done, so -- because,
16 logistically, we can't all meet. It's too much money to
17 travel, so we do a lot of e-mail votes.
18 Q And let me just tell -- you can tell me, based on
19 how you've done this in the past: Are franchises presented
20 for approval when no franchise, written franchise agreement
21 or application has been submitted?
22 A Not to my knowledge.
23 Q So, for it to actually be referenced in there
24 that it was presented, they would have had to have received
25 it?
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1 MR. BLOCK: Objection as to the form, and
2 foundation.
3 THE WITNESS: When it says, it's -- yeah --
4 presented, the franchises that were presented, that
5 means presented to us, probably. These have been
6 presented to the board to vote on.
7 BY MR. SANDERS:
8 Q Well, again, when you say "us" --
9 A For approval.
10 Q Yeah. This was --
11 A They send us the name; the franchise, itself,
12 would go to the executive board, and then we would just
13 vote on that franchise.
14 Q Well, again, these are executive board minutes;
15 are they not?
16 A Right.
17 But these franchises that were presented, they're
18 usually referencing, though -- it may not be clearly stated
19 there -- we've been presented those to pass or vote on, and
20 they're just making -- these are the ones that are going;
21 but, as you'll notice, we didn't vote on the Jacksonville
22 one yet, there's still a pending discussion that was going
23 to occur with you. So she didn't send out anything for us
24 to vote on for the Jacksonville Pageant, because we don't
25 have a franchise there, or a discussion had to follow, and
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1 there was going to be a vote, probably, in October.
2 Q Well, I'll discuss that a little bit later.
3 So your testimony today is, you don't know if the
4 actual franchise agreement had been received before the
5 October 14th deadline?
6 A No, sir.
7 I remember vaguely that I don't think yours was
8 there when the board met at that workshop to vote. If I'm
9 incorrect, then I need someone to -- to find out that
10 information, but that's my recollection, that yours was not
11 there that morning when the board met, or that night. It
12 was either that night prior or the morning of. I don't
13 remember when we met. I don't even remember if I was
14 there. I just remember that that was something that was
15 stated. I did hear that in a conversation.
16 Q And that was at a board meeting that you heard
17 that?
18 A All we're doing is -- all they do is present the
19 franchises to us to vote for. If yours was not there, we
20 can't vote on it. If yours was there, we would have had to
21 vote on it. So, to my knowledge, yours was not there when
22 we voted. And if I stand to be corrected, I -- that's all
23 I can remember.
24 Q And now, your name is not mentioned on these
25 minutes of September 23rd, but you recall being at this
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1 executive board meeting?
2 A No, no, no; no, sir. I was not at that meeting;
3 no, sir. I'm talking about our general board meeting at
4 the fall workshops that we do; yes, sir. I didn't attend
5 any of the executive board meetings.
6 Q Again, I'm going to introduce these at a later
7 time, but let me show you, then, the minutes of October
8 13th, which is a day before the deadline. It says: Miss
9 Florida Pageant Board of Directors Meeting, October 13th,
10 2006. I'll ask you if you remember seeing those.
11 (Mr. Sanders tendering document to witness.)
12 Those were entered into Mary Sullivan's
13 deposition as Exhibit 18.
14 A See, I was absent that night.
15 Q Right.
16 A That's why, probably, my recollection is so
17 vague.
18 Q If you'll look on the second page --
19 A Oh, okay. Yes, sir; I see this. There were two
20 franchises received.
21 Okay. Then there was a vote made. Then I heard
22 that -- I'm incorrect on my remembrance, then. What I'm
23 referencing may have been something else earlier, that you
24 were taking time to submit your franchise, but that they
25 must have voted on yours that night, and -- between a
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1 Ms. Sidbury.
2 Q Okay. Let me follow up one point on that.
3 Who is Ruth Sidbury?
4 A Ms. Sidbury is a former -- she's been a -- not a
5 former; she is a local executive director. She used to
6 have the Miss Jacksonville Pageant, but now she has -- then
7 she left the Miss Jacksonville, and then she took another
8 pageant. But she's been a long-standing executive director
9 for the Miss Florida Pageant.
10 Q And do you know how long she's been director?
11 A Many years. I don't know the exact number, but I
12 know it's been a long time.
13 Q Did you ever file a formal complaint against Ruth
14 Sidbury?
15 THE WITNESS: Does this have anything to do with
16 present -- I thought this was from 2002 to -- what?
17 MR. BLOCK: I'll list my standing objection to
18 it.
19 I'm not going to direct you not to answer. I
20 think -- I have an opinion that Kevin is going beyond
21 the bounds, but those opinions have to go to the
22 judge.
23 THE WITNESS: Yeah. I don't think this has to do
24 with Ms. Sidbury. I mean, I'm not here to talk about
25 Ms. Sidbury.
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1 BY MR. SANDERS:
2 Q But, at some point, you had a complaint about
3 Ruth Sidbury, that you actually were trying to have her
4 removed as an executive director; did you not?
5 A I would not say that I was having anyone removed.
6 I think that there was a discussion of a concern. And I
7 don't remove anyone from a board. That's a collaborative
8 decision by the board.
9 I have a very good relationship with Ms. Sidbury
10 at this time, and I'm not one to -- things happen in all
11 organizations; people change, and I change -- people
12 change, and I don't think that this has any bearing on what
13 we're here for, to bring Ms. Sidbury into this.
14 Q Well, again, but -- you had made some heavy
15 accusations against Ruth Sidbury at that point in time; had
16 you not?
17 A "Heavy" is your word.
18 MR. BLOCK: Can we just have a time here, for
19 reference, what year we're talking about?
20 THE WITNESS: I don't even remember the year.
21 I'd have to -- I don't even remember.
22 Mr. Sanders may remember.
23 MR. SANDERS: Well, again, it's not my
24 deposition, so I --
25 THE WITNESS: Yeah. I don't remember the time
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1 frame.
2 MR. SANDERS: I'm assuming it's probably two or
3 three years prior to this.
4 BY MR. SANDERS:
5 Q It was under the old board; was it not?
6 A It was under the old board. It doesn't have
7 anything to do with this new board, so I don't know why I'm
8 going back into time over something that's past history and
9 worked out in a very positive way, I mean, you know.
10 Q So you don't have, based on your former
11 accusations of Ruth Sidbury with regards to -- and I'll
12 just say it this way -- with regards to black contestants,
13 you don't have any concerns, today's date, with regards to
14 her treatment of black contestants?
15 A No, sir.
16 MR. BLOCK: Standing objection.
17 THE WITNESS: No, sir.
18 BY MR. SANDERS:
19 Q Okay. And did Mary Sullivan ever indicate to the
20 full board the reason why Ruth Sidbury, Cammie Sanders and
21 Kevin Sanders separated, and Cammie Sanders and Kevin
22 Sanders were awarded the Jacksonville pageant?
23 MR. BLOCK: Form.
24 THE WITNESS: At what time?
25 MR. SANDERS: When the pageant went from Ruth
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1 Sidbury to Kevin and Cammie Sanders.
2 THE WITNESS: You applied for the pageant, and
3 you-all were voted on, and you-all got the pageant.
4 BY MR. SANDERS:
5 Q Okay. Did Mary Sullivan ever indicate to the
6 full board the concerns of Cammie Sanders and Kevin Sanders
7 with regards to how the money was being allocated and
8 directed by Ruth Sidbury?
9 A Not to my knowledge.
10 MR. BLOCK: I'm going to have a standing
11 objection on this, because I don't know what time
12 frame you're talking about here.
13 THE WITNESS: This is a long time ago.
14 MR. SANDERS: Well, that was only about two or
15 three years.
16 THE WITNESS: But, Mr. Sanders, if you will
17 remember correctly, I'm not the type of person that
18 holds a grudge against anyone; and, at that time, if
19 we want to go back, if we want to honestly look at it,
20 you, yourself, personally, wrote some very terrible
21 comments and letters about myself, as a person and
22 professionally. I have disregarded that time, and I
23 have been a -- a supporter of you and your wife in
24 this program. I have overlooked those times and those
25 terrible letters that you wrote, which were not
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1 accurate, sir, and I moved past that, just as I moved
2 past whatever happened with Ms. Sidbury. I have a
3 good relationship with Ms. Sidbury, and I thought that
4 you and I and your wife Cammie had moved past all of
5 those times. I was not deserving, in my opinion, of
6 some of the things written about me, but I did move
7 past that.
8 But if you-all want to bring that up into this
9 deposition, then I must state, with all honesty, that
10 I don't think this has anything to do with it, and
11 I -- I just -- I'm trying to do what's the right thing
12 and the just thing here; I'm trying to answer your
13 questions honestly. And I've always been a supporter
14 of both you and your wife while you had the pageant;
15 and I've never, in any way, treated you-all
16 differently or disrespectfully, even after what
17 terrible things that I endured during that period of
18 time, as a professional. And so I really don't want
19 to go back to that time, sir. I'm past that.
20 (Brief interruption.)
21 I just -- you know, I thought I had to say that,
22 because, I mean, I really -- even in my e-mails to
23 you, you can say that I'm supportive, I care about you
24 and your wife, as people, and that I put things that
25 happen a long time ago in the past, because people
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1 sometimes say and do things that they don't really
2 mean at the time, and people can be forgiven, and --
3 and you move on; you know, you just move on.
4 And so that's where I am in my life with that
5 whole situation. And it was hard, very hard for me,
6 at the time. I did what I thought was right at the
7 time. I don't want to go into the details, but what I
8 did, I did as a person who takes very carefully --
9 critically her role and responsibility in supervising
10 young women in this program. I work in the collegiate
11 setting. I take care of young men and women all the
12 time. I don't like to see them hurt or -- or
13 mistreated in any way.
14 And -- and I sometimes think that maybe you
15 didn't have a full understanding of what truly
16 happened at that time. And that was your friend, and
17 you were trying to defend your friend, and I -- I
18 respect that. But I think that all the details were
19 not there at the time, and -- but I've moved past
20 that.
21 BY MR. SANDERS:
22 Q And again, I don't want to make you late -- I
23 know you have a deadline -- I just want to follow up with
24 maybe one or two more questions on this.
25 Your main focus, your main job right now is
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1 money, making sure the money is accounted for, money is
2 distributed --
3 A Yes, sir.
4 Q -- scholarships and everything like that?
5 A Uh-huh.
6 Q And I know you weren't present at Ruth Sidbury's
7 deposition, but she testified in her deposition that she
8 has never given an accounting or a full audit of finances
9 for the Miss Jacksonville Pageant, when Kevin and Cammie
10 Sanders were there or after Kevin and Cammie Sanders left,
11 to her current board.
12 A To her --
13 MR. BLOCK: Wait, wait, wait. Let him ask a
14 question, because he hasn't -- he's just testifying
15 now.
16 MR. SANDERS: I'm just telling you what was
17 stated there.
18 BY MR. SANDERS:
19 Q The question is: As the scholarship person, does
20 that cause you any concern, that Ruth Sidbury does not
21 bring the information of how many program sales, how many
22 ticket sales, how much money is brought in to a pageant, to
23 the full board, and doesn't allow the board access to
24 banking statements?
25 MR. BLOCK: Foundation and form.
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1 THE WITNESS: To her board?
2 MR. SANDERS: Yes, ma'am.
3 THE WITNESS: Okay. I wouldn't know that unless
4 there was a concern voiced by one of the folks that
5 serve on her board.
6 I know that she's reported, as all the executive
7 directors do, to me their scholarships reports. But
8 with reference to what happens on your board, I
9 haven't had any -- no one made a complaint to me about
10 that. And, yes, I would take that, and think that
11 that would be discussed, if a concern or a complaint
12 had been made.
13 BY MR. SANDERS:
14 Q And again, that's a part of her deposition, but
15 that goes back to my original question, then: Mary
16 Sullivan, then, never informed you of the complaints of
17 Kevin Sanders and Cammie Sanders about Ruth Sidbury and the
18 finances of the then Jacksonville Scholarship Foundation
19 and the disclosures of income?
20 MR. BLOCK: Standing objection.
21 THE WITNESS: Not to my knowledge.
22 MR. SANDERS: Okay. I don't want you to be late
23 for your meeting, so I'm going to --
24 THE WITNESS: Excuse me. I went back in time
25 there. I apologize. That has nothing to do with
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1 this.
2 MR. SANDERS: I will just suspend the balance of
3 the deposition until we can figure out where to go to.
4 I will go ahead -- I haven't quite finished on
5 what's going to be Exhibit 15 -- yes, Exhibit 15 --
6 and we'll pick back up on that when we come back.
7 MR. BLOCK: So we don't get confused -- because I
8 was pre-marking, if you will, in my notes -- I think
9 we had the 9-23 minutes of the executive directors
10 meeting that we discussed that I sort of penciled in
11 as would-be 16, and then the minutes of the October
12 meeting of the full board which would be 17.
13 Do we just want to -- because those documents
14 were discussed.
15 (Discussion off the record.)
16 MR. SANDERS: Well, then, just for benefit of
17 reference, we'll go ahead and make the board minutes
18 of 9-23-2006 No. 16, although I reserve the right to
19 ask additional questions on it, and then we'll make
20 the October 13th, full board minutes No. 17.
21 (Plaintiff's Exhibits No. 15, 16 and 17 were
22 marked for identification.)
23 Just for reference, I may have this partial
24 deposition printed up.
25 THE WITNESS: Okay.
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1 MR. SANDERS: If I do, you have the right to read
2 it. You may want to ask Mr. Block if he wants you to
3 read it.
4 THE WITNESS: Yes, sir.
5 MR. SANDERS: If you believe she's copied
6 everything down correctly and professionally, you can
7 waive that. If you desire to read it, you'll have to
8 make yourself available to come in and read that.
9 THE WITNESS: Okay.
10 MR. BLOCK: We'll read through it.
11 (Witness excused.)
12 (Thereupon, the deposition was adjourned at
13 approximately 12:45 p.m.)
14 * * *
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1
2
3 CERTIFICATE OF OATH
4 STATE OF FLORIDA )
)
5 COUNTY OF DUVAL )
6 I, Laurie J. Miller, Court Reporter, certify that
7 PATTY ADEEB personally appeared before me and was duly
8 sworn.
9 WITNESS my hand and official seal at
10 Jacksonville, this 27th day of May 2009.
11
12 _____________________________
Laurie J. Miller
13
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1
2
3 DEPOSITION CERTIFICATE
4 STATE OF FLORIDA )
)
5 COUNTY OF DUVAL )
6 I, Laurie J. Miller, Court Reporter, do hereby
7 certify that I was authorized to and did stenographically
8 report the foregoing deposition and that the transcript is
9 a true record of the testimony given by the witness.
10 I further certify that I am not a relative,
11 employee, attorney or counsel of any of the parties, nor am
12 I a relative or employee of any of the parties' attorney or
13 counsel connected with the action, nor am I financially
14 interested in the action.
15 Dated this 27th day of May 2009.
16
17 _________________________________
Laurie J. Miller, Court Reporter
18
19
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1 E R R A T A S H E E T
2 This is to certify that I, Patty Adeeb, have read
3 the foregoing transcript of my deposition, Pages 1 through
4 114, taken on Thursday, May 14, 2009, and find the same to
5 be correct, with the following exceptions (if any):
6 PAGE LINE WHERE IT SAYS: SHOULD SAY:
7 ____ ____ ______________________ _______________________
8 ____ ____ ______________________ _______________________
9 ____ ____ ______________________ _______________________
10 ____ ____ ______________________ _______________________
_____________________________
Patty Adeeb
Verbatim Reporting Services, Inc.
Verbatim Reporting Services, Inc.
916 Blackstone Building
233 East Bay Street
Jacksonville, Florida 32202
==========================================================
Phone: (904) 355-0198
May 27, 2009
David E. Block, Esquire
Jackson, Lewis, LLP
Two South Biscayne Boulevard
One South Biscayne Tower, Suite 3500
Miami, Florida 33131
In re: North Florida Scholarship Organization vs. Miss
Florida Scholarship Pageant, et al.
Case No. 16-2007-CA-00575-MA Division: CV-C
Dear Mr. Block:
Attached hereto is your copy of the transcript of the
deposition of your client, Patty Adeeb, taken in the
above-styled case, as well as the original errata sheet for
her deposition transcript.
Please have Ms. Adeeb read your copy of her deposition
transcript and complete and sign the corresponding errata
sheet, then forward the original errata to Mr. Sanders for
inclusion in the original transcript.
If you have any questions or if I may be of further
assistance to you, please don't hesitate to call.
Cordially yours,
Laurie J. Miller,
Court Reporter
cc: Kevin S. Sanders, Esquire
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