Deposition of David Sorensen in False CPS Report

David T.
Sorensen 1
1 CAUSE NO. 141296646-17
2 RICHARD WEST BO FRENCH, AND § IN THE DISTRICT COURT

SHERIDAN FRENCH, §
3 §
Plaintiffs, §
4 §
VS. § 141st JUDICIAL DISTRICT
5 §
DAVID T. SORENSEN §
6 §
Defendant. § TARRANT COUNTY, TEXAS
7
8 *********************************************
9 ORAL AND VIDEOTAPED DEPOSITION OF
10 DAVID SORENSEN
11 FEBRUARY 23, 2018
12 *********************************************
13
14
15 ORAL AND VIDEOTAPED DEPOSITION of DAVID SORENSEN,
16 produced as a witness at the instance of the Plaintiffs
17 and duly sworn, was taken in the above-styled and
18 -numbered cause on the 23rd of February, 2018, from
19 9:06 a.m. to 11:24 a.m., before Melisa Duncan, CSR in and
20 for the State of Texas, reported by machine shorthand, at
21 the offices of Matthew Pillado, PLLC, 235 NE Loop 820,
22 Hurst, Texas, pursuant to the Rules of Civil Procedure and
23 the provisions stated on the record or attached hereto.
24
25
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David T. Sorensen 2
1 A P P E A R A N C E S
2 FOR THE PLAINTIFF(S):
3 Christopher D. Kratovil
DYKEMA COX SMITH
4 1717 Main Street, Suite 4200
Dallas, Texas 75201
5 214.462.6458
ckratovil@dykema.com
6
7 Tim O'Hare
THE LAW OFFICES OF TIM O'HARE
8 1038 Elm Street
Carrollton, Texas 75006
9 972.960.0000
attorney@oharelawfirm.com
10
11 FOR THE DEFENDANT:
12 Steve Maxwell
Bailey & Galyen
13 1300 Summit Avenue, Suite 650
Fort Worth, Texas 76102
14 817.276.6000
smaxwell@galyen.com
15
16 Matthew Pillado
Artemio Fernandez
17 MATTHEW PILLADO, PLLC
235 NE Loop 820, Suite 103
18 Hurst, Texas 76053
msp@matthewpillado.com
19 af@matthewpillado.com
20 ALSO PRESENT:
21 Bo French
22 Luis Acevedo - Videographer
23
24
25
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David T. Sorensen 3
1 INDEX
2 PAGE
3 Appearances . . . . . . . . . . . . . . . . . . . . . 2
4 DAVID SORENSEN
5 Examination by Mr. Kratovil . . . . . . . . . . . 7
6 Examination by Mr. Maxwell. . . . . . . . . . . . 109
7 Further Examination by Mr. Kratovil . . . . . . . 112
8 Signature and Changes . . . . . . . . . . . . . . . . 114
9 Reporter's Certificate. . . . . . . . . . . . . . . . 116
10 REPORTER'S NOTE: Quotation marks are used for clarity
11 and do not necessarily reflect a direct quote.
12 E X H I B I T S
13 NO. DESCRIPTION PAGE
14 Exhibit 1 . . . . . . . . . . . . . . . . . . . . . . 84
CPS Report
15 Exhibit 2 . . . . . . . . . . . . . . . . . . . . . . 103
Affidavit of Laramie Stroud
16
17 CERTIFIED QUESTIONS
18 NO. PAGE/LINE
19 1 . . . . . . . . . . . . . . . . . . . . . . . 20 : 25
20 2 . . . . . . . . . . . . . . . . . . . . . . . 47 : 13
21 3 . . . . . . . . . . . . . . . . . . . . . . . 47 : 21
22 4 . . . . . . . . . . . . . . . . . . . . . . . 48 : 6
23 5 . . . . . . . . . . . . . . . . . . . . . . . 48 : 14
24 6 . . . . . . . . . . . . . . . . . . . . . . . 48 : 22
25 7 . . . . . . . . . . . . . . . . . . . . . . . 49 : 5
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David T. Sorensen 4
1 CERTIFIED QUESTIONS (Continued)
2 NO. PAGE/LINE
3 8 . . . . . . . . . . . . . . . . . . . . . . . 50 : 4
4 9 . . . . . . . . . . . . . . . . . . . . . . . 50 : 13
5 10 . . . . . . . . . . . . . . . . . . . . . . . 50 : 22
6 11 . . . . . . . . . . . . . . . . . . . . . . . 51 : 5
7 12 . . . . . . . . . . . . . . . . . . . . . . . 51 : 11
8 13 . . . . . . . . . . . . . . . . . . . . . . . 51 : 19
9 14 . . . . . . . . . . . . . . . . . . . . . . . 52 : 2
10 15 . . . . . . . . . . . . . . . . . . . . . . . 52 : 11
11 16 . . . . . . . . . . . . . . . . . . . . . . . 65 : 11
12 17 . . . . . . . . . . . . . . . . . . . . . . . 65 : 17
13 18 . . . . . . . . . . . . . . . . . . . . . . . 67 : 10
14 19 . . . . . . . . . . . . . . . . . . . . . . . 67 : 21
15 20 . . . . . . . . . . . . . . . . . . . . . . . 68 : 3
16 21 . . . . . . . . . . . . . . . . . . . . . . . 68 : 10
17 22 . . . . . . . . . . . . . . . . . . . . . . . 68 : 17
18 23 . . . . . . . . . . . . . . . . . . . . . . . 70 : 5
19 24 . . . . . . . . . . . . . . . . . . . . . . . 70 : 15
20 25 . . . . . . . . . . . . . . . . . . . . . . . 70 : 24
21 26 . . . . . . . . . . . . . . . . . . . . . . . 76 : 15
22 27 . . . . . . . . . . . . . . . . . . . . . . . 76 : 22
23 28 . . . . . . . . . . . . . . . . . . . . . . . 86 : 17
24 29 . . . . . . . . . . . . . . . . . . . . . . . 86 : 23
25
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David T. Sorensen 5
2 NO. PAGE/LINE
3 30 . . . . . . . . . . . . . . . . . . . . . . . 87 : 8
4 31 . . . . . . . . . . . . . . . . . . . . . . . 88 : 10
5 32 . . . . . . . . . . . . . . . . . . . . . . . 89 : 20
6 33 . . . . . . . . . . . . . . . . . . . . . . . 90 : 2
7 34 . . . . . . . . . . . . . . . . . . . . . . . 91 : 5
8 35 . . . . . . . . . . . . . . . . . . . . . . . 91 : 18
9 36 . . . . . . . . . . . . . . . . . . . . . . . 93 : 16
10 37 . . . . . . . . . . . . . . . . . . . . . . . 94 : 5
11 38 . . . . . . . . . . . . . . . . . . . . . . . 94 : 12
12 39 . . . . . . . . . . . . . . . . . . . . . . . 94 : 19
13 40 . . . . . . . . . . . . . . . . . . . . . . . 95 : 1
14 41 . . . . . . . . . . . . . . . . . . . . . . . 95 : 10
15 42 . . . . . . . . . . . . . . . . . . . . . . . 95 : 19
16 43 . . . . . . . . . . . . . . . . . . . . . . . 96 : 1
17 44 . . . . . . . . . . . . . . . . . . . . . . . 96 : 8
18 45 . . . . . . . . . . . . . . . . . . . . . . . 96 : 16
19 46 . . . . . . . . . . . . . . . . . . . . . . . 97 : 18
20 47 . . . . . . . . . . . . . . . . . . . . . . . 98 : 2
21 48 . . . . . . . . . . . . . . . . . . . . . . . 98 : 13
22 49 . . . . . . . . . . . . . . . . . . . . . . . 99 : 3
23 50 . . . . . . . . . . . . . . . . . . . . . . . 99 : 12
24 51 . . . . . . . . . . . . . . . . . . . . . . . 99 : 19
25 52 . . . . . . . . . . . . . . . . . . . . . . . 100 : 4
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David T. Sorensen 6
2 NO. PAGE/LINE
3 53 . . . . . . . . . . . . . . . . . . . . . . . 100 : 13
4 54 . . . . . . . . . . . . . . . . . . . . . . . 101 : 8
5 55 . . . . . . . . . . . . . . . . . . . . . . . 104 : 17
6 56 . . . . . . . . . . . . . . . . . . . . . . . 105 : 8
7 57 . . . . . . . . . . . . . . . . . . . . . . . 105 : 15
8 58 . . . . . . . . . . . . . . . . . . . . . . . 105 : 23
9 59 . . . . . . . . . . . . . . . . . . . . . . . 106 : 6
10 60 . . . . . . . . . . . . . . . . . . . . . . . 106 : 23
11 61 . . . . . . . . . . . . . . . . . . . . . . . 107 : 1
12 62 . . . . . . . . . . . . . . . . . . . . . . . 107 : 15
13 63 . . . . . . . . . . . . . . . . . . . . . . . 108 : 2
14 64 . . . . . . . . . . . . . . . . . . . . . . . 108 : 17
15
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19
20
21
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David T. Sorensen 7
1 P R O C E E D I N G S
2 THE VIDEOGRAPHER: We're on the record for
3 the deposition of David T. Sorensen. The time is
4 9:06 a.m. on February 23, 2018.
5 If the court reporter can administer the
6 oath.
7 DAVID SORENSEN,
8 having been first duly sworn, testified as follows:
9 EXAMINATION
10 BY MR. KRATOVIL:
11 Q. Good morning, sir. Could you please state your
12 full legal name for the record.
13 A. David Thomas Sorensen.
14 Q. And, Mr. Sorensen, could you please give me your
15 current address.
16 A. 2718 Meadow Creek Drive, Missouri City, Texas
17 77459.
18 Q. Mr. Sorensen, what is your current phone number?
19 A. 682-201-9713.
20 Q. Is that a mobile phone, sir?
21 A. Yeah.
22 Q. And who is your mobile phone carrier?
23 A. AT&T.
24 Q. And is that the same number you had during the
25 time relevant to this lawsuit, which I'll represent to you
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David T. Sorensen 8
1 is February 2016?
2 A. I don't know.
3 Q. Do you recall your phone number as of February
4 2016?
5 A. No.
6 Q. Different phone number, same phone number?
7 A. I really have to think. I don't know.
8 Q. Please do think.
9 A. No, it would be a different one.
10 Q. And you don't recall that number?
11 A. Not right off the top of my head, no.
12 Q. Was AT&T your carrier in February 2016?
13 A. That, I don't know.
14 Q. You don't recall your carrier in --
15 A. No.
16 Q. -- February in 2016?
17 Sir, what are your email addresses that you
18 regularly use?
19 A. David.Sorensen107@gmail.
20 Q. Any other email addresses that you regularly use?
21 A. That's basically it -- oh, no.
22 David@consulting643.com.
23 Q. And did you use either of those emails as of
24 February 2016?
25 A. The first one.
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David T. Sorensen 9
1 Q. And the second one?
2 A. No.
3 Q. Did you have any other email addresses that you
4 used regularly as of February 2016?
5 A. Let me think. Not that I can recall.
6 Q. What about social media accounts, sir, do you
7 maintain any social media accounts?
8 A. I have a Facebook, yes.
9 Q. And how are you identified on Facebook?
10 A. My name.
11 Q. David T. Sorensen?
12 A. Just David Sorensen.
13 Q. What about LinkedIn?
14 A. I have one. I don't use it, though.
15 Q. What about Twitter?
16 A. Same.
17 Q. Do you know your Twitter handle?
18 A. Not off the top of my head, no.
19 Q. You don't know your Twitter handle?
20 A. No, I don't really get on it that much.
21 Q. What about Instagram?
22 A. Yes, I have one.
23 Q. What's your Instagram handle?
24 A. I think it's DavidS127.
25 Q. Any other social media accounts other than the
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David T. Sorensen 10
1 ones you've just described to me?
2 A. Let me think. I have My Space.
3 Q. Still in use?
4 A. Yes.
5 Q. You're the last My Space user. I'm impressed.
6 What's your My Space handle?
7 A. Well, I don't remember.
8 Q. Other than your legal name, David T. Sorensen,
9 have you ever been known by any other name?
10 A. Sometimes I go by Dave, but other than that . . .
11 Q. Any assumed names?
12 A. What do you mean?
13 Q. Any -- any name other than your legal name that
14 you use?
15 A. No.
16 Q. Do you ever post political content on your social
17 media accounts?
18 A. Sometimes, yeah.
19 Q. Do you have a special account or separate account
20 that you use for political content?
21 A. No.
22 Q. So you use your ordinary Facebook page for that?
23 A. Uh-huh.
24 Q. What about Twitter?
25 A. Same.
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1 Q. Who is your current employer, sir?
2 A. Steve Brown.
3 Q. Who is Steve Brown?
4 A. He's running for Congress.
5 Q. Where?
6 A. In Houston.
7 Q. What district?
8 A. 22.
9 Q. Is he in a primary?
10 A. That's correct.
11 Q. Which party is primary?
12 A. The Democratic primary.
13 Q. So you're currently working for a political
14 campaign for a man named Steve Brown running for congress
15 in Houston as a Democrat?
16 A. Yeah.
17 Q. And who was your employer prior to Steve Brown?
18 A. I was briefly with Lina Hidalgo, she's running
19 for county judge.
20 Q. Where?
21 A. In Houston, Texas.
22 Q. In what party?
23 A. The Democratic party.
24 Q. Is she in a primary?
25 A. Uncontested.
Lexitas
1 Q. And prior to Judge Hidalgo?
2 A. I was unemployed. And then I was with the
3 Tarrant County Democratic Party.
4 Q. And what did you do for the Tarrant County
5 Democratic Party?
6 A. I did like their emails and stuff.
7 Q. What do you mean by that?
8 A. I help them write emails.
9 Q. To constituents?
10 A. To their email list.
11 Q. And how long were you with the Tarrant County
12 Democratic Party?
13 A. Right after the primary last go around until
14 right before Harvey. I don't remember the exact date.
15 Q. So from approximately March 2016 to approximately
16 August 2018 -- 2017, I should say when Harvey hit?
17 A. Somewhere around there.
18 Q. Okay. And who were you with prior to the Tarrant
19 County Democratic Party?
20 A. Charlie Geren.
21 Q. And who is Charlie Geren?
22 A. He's a state representative for House District
23 99.
24 Q. What party?
25 A. He's Republican.
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1 Q. And what did you do for Mr. Geren?
2 A. I was on his campaign. I was a field guy for his
3 campaign.
4 Q. Okay. We'll come back to that. Let's cover some
5 of the ground rules for a deposition, sir.
6 Have you ever been deposed before?
7 A. I have not.
8 Q. All right. And are you represented by anyone
9 today at this deposition?
10 A. Yes.
11 Q. Who are you represented by?
12 A. Steve Maxwell and Matthew -- I can't pronounce
13 name.
14 MR. PILLADO: That's all right. Pillado.
15 Q. (BY MR. KRATOVIL) As a Kratovil, I can
16 understand when names are hard to pronounce. No problem.
17 Is Mr. Maxwell and Mr. Pillado representing
18 you in your individual capacity or as a former employee of
19 the Charlie Geren campaign.
20 A. For me.
21 Q. So they're your individual counsel?
22 A. Yeah.
23 Q. And, sir, who is paying for your legal counsel?
24 A. Nobody.
25 Q. Are these gentlemen representing you pro bono?
Lexitas
1 A. As far as I know.
2 THE WITNESS: Right, guys?
3 Q. (BY MR. KRATOVIL) So you don't have a fee
4 agreement with either Mr. Maxwell or Mr. Pillado?
5 A. Mr. Pillado sent me one, but it was -- there were
6 zeros there, so that was good for me.
7 Q. Have you ever paid Mr. Pillado or Mr. Maxwell any
8 money?
9 A. No.
10 Q. And Mr. Maxwell represented you previously in a
11 Rule 202 proceeding?
12 A. Yes.
13 Q. And did you pay him for that representation?
14 A. No, sir.
15 Q. Did anybody pay Mr. Maxwell for that
16 representation?
17 A. Not that I know of.
18 Q. Do you have reason to believe that anybody paid
19 him for that representation?
20 A. No.
21 Q. Are you friends with these gentlemen? Why are
22 they representing you for free?
23 A. I know Steve while working with the Tarrant
24 County Democratic Party. I got to know -- he's the former
25 county chair, so . . .
Lexitas
1 Q. So you were one of -- you worked with him at the
2 Tarrant County Democratic Party, and based on that
3 relationship he's doing you a favor?
4 A. I'm kind of confused on how you asked that.
5 Q. I'll re-ask it. Why is Mr. Maxwell representing
6 you for free?
7 MR. MAXWELL: Objection, form.
8 Q. (BY MR. KRATOVIL) You can answer.
9 A. I don't know.
10 Q. You said you've never been deposed before. Do
11 you understand your testimony today is under oath and can
12 be used at trial in front of a judge and jury, just as if
13 you were testifying live in the courtroom?
14 A. Yes.
15 Q. And do you understand the oath you just took is
16 the same oath you would take in a Texas court of law?
17 A. Yes.
18 Q. And do you understand that violating that oath
19 carries with it the same penalties for perjury that you
20 would incur if you testified untruthfully in court?
21 A. Yes.
22 Q. Do you understand that perjury is a crime in the
23 state of Texas?
24 A. Yes.
25 Q. So you understand this is a serious process?
Lexitas
1 A. Yes, sir.
2 Q. So -- a couple of very basic ground rules.
3 You've been doing a good job with this so far. Please let
4 me finish asking my question before you start answering.
5 If you don't understand a question, and you've already
6 done this, you can tell me and I'm happy to rephrase it.
7 A. Okay.
8 Q. I will assume you understand my question unless
9 you tell me otherwise. Is that okay?
11 Q. (BY MR. KRATOVIL) You can answer. See, we're
12 practicing.
13 A. Say that again. I'm sorry. I got confused.
14 Q. Unless you tell me otherwise, I will assume that
15 you understand my question.
18 A. Okay.
19 Q. Answer verbally to the court reporter, no shrugs,
20 nods or grunts. Is that okay?
21 A. Yes. Oh, I just did it.
22 Q. Your counsel may from time to time object, but
23 after he makes his objection, you should answer the
24 question unless he instructs you not to. Do you
25 understand that?
Lexitas
1 A. Yes.
2 Q. And if he instructs you not to answer a question,
3 I will ask you if you're going to follow his advice and
4 not answer and you can respond to that question. Do you
5 understand that?
6 A. Yes, sir.
7 Q. Do you understand these instructions for today's
8 deposition?
9 A. I do.
10 Q. How did you prepare for your deposition today?
11 A. I just drove up here and met with Steve.
12 Q. Did you discuss this deposition with anyone other
13 than your counsel?
14 A. No. Sorry. Oops.
15 Q. Did you speak with anyone affiliated with
16 Mr. Geren's 2018 campaign regarding today's deposition?
17 A. No. I don't even know who that is.
18 Q. Did you speak with anyone from Mr. Geren's staff
19 regarding today's deposition?
20 A. No.
21 Q. Did you speak with any lawyers representing
22 Charlie Geren regarding today's deposition?
23 A. No.
24 Q. Did you speak with any lawyers representing
25 Laramie Stroud regarding today's deposition?
Lexitas
1 A. No.
2 Q. Did you speak with anyone from the Tarrant County
3 Democratic Party regarding today's deposition?
4 A. Well, I'm friends with their executive director,
5 so we met last night just to catch up, but . . .
6 Q. And who is that?
7 A. Marco Rosas.
8 Q. Can you spell that last name for me?
9 A. R-o-s-a-s.
10 Q. And what did you tell Mr. Rosas about today's
11 deposition?
12 A. Well, I just told him I was here for the
13 deposition. I didn't get into details of the deposition.
14 Q. And did he -- how did he respond?
15 A. We just met for beer. I mean, I don't
16 understand.
17 Q. So no -- no substantive discussion of today's
18 deposition?
19 A. No. No.
20 Q. Did you review any documents in preparation for
21 today's deposition?
22 A. I met with my lawyer, but other than that . . .
23 Q. Do you have copies of the documents that you
24 reviewed to prepare for today's deposition with you?
25 A. I don't have any documents.
Lexitas
1 Q. Please describe all documents you reviewed in
2 preparation for today's deposition?
3 A. Can you rephrase that? I'm sorry.
4 Q. Tell me about the documents you looked at to
5 prepare for today's deposition.
6 A. Just the court papers.
7 Q. So you looked at --
8 A. White and black letters. I mean, I don't know
9 what you want me to describe.
10 Q. Anything other than the court papers that you
11 looked at to prepare for today's deposition?
12 A. No.
13 Q. And by "the court papers," do you mean the
14 pleadings in this case?
15 A. Yes.
16 Q. Did you look at the papers from the Rule 202
17 case?
18 A. I wouldn't know.
19 Q. Sir, are you currently taking any medications
20 that would affect your ability to give truthful testimony
21 today?
22 A. I mean, I have medication for my PTSD, but I
23 don't think that would affect this.
24 Q. And, sir, what is that medication?
25 A. Citalopram.
Lexitas
1 Q. And what dosage do you take?
2 A. 10 milligrams.
3 Q. How often?
4 A. Daily.
5 Q. Are you taking any medications that impair your
6 memory?
7 A. Not that I remember.
8 Q. Have you had any alcohol in the last 24 hours?
9 A. Yeah. I just said I met for a beer with Marco.
10 Q. How many beers?
11 A. Oh, three.
12 Q. Are you feeling fine this morning?
13 A. Yeah. Although I may not look it.
14 Q. You look fine to me, sir.
15 Sir, do you know we've been seeking your
16 deposition since last June?
17 A. Since last June. I think so. I -- I don't know
18 the exact dates.
19 Q. Do you understand we've been seeking your
20 deposition since last summer?
22 A. When was it? Oh, last summer.
23 Q. (BY MR. KRATOVIL) Summer of 2017.
24 A. I didn't know it was that long, no.
25 Q. Is there any particular reason you've fought so
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1 hard to avoid talking with me?
2 MR. MAXWELL: Don't answer that question.
3 Q. (BY MR. KRATOVIL) Are you going to follow your
4 attorney's advice and not answer that question?
5 A. Yes.
6 MR. KRATOVIL: What's the basis for your
7 objection, sir?
8 MR. MAXWELL: It's not an objection. It's
9 an instruction to not answer.
10 MR. KRATOVIL: All right. Certify that
11 question, please.
12 Q. (BY MR. KRATOVIL) Sir, what's your date of
13 birth?
14 A. October 29, 1986.
15 Q. Have you ever filed a lawsuit?
16 A. Have I, no.
17 Q. Have you ever been a defendant in a lawsuit prior
18 to this one?
19 A. I got a DWI, but no.
20 Q. When was that?
21 A. 2010.
22 Q. What county?
23 A. Fort Bend.
24 Q. And what was the resolution of the case?
25 A. On probation.
Lexitas
1 Q. And you've successfully served out that
2 probation?
3 A. Yes, sir.
4 Q. When did you complete that probation?
5 A. I don't remember.
6 Q. Approximately?
7 A. It was eight years ago. I -- I have no idea.
8 Q. Is that your only DWI?
9 A. I had another one.
10 Q. When was that?
11 A. 2000 -- the following year.
12 Q. That would be 2011?
13 A. I think so.
14 Q. What county?
15 A. Coryell.
16 Q. And what was the result of that case?
17 A. Probation.
18 Q. And have you successfully served out that
19 probation?
20 A. It's over with.
21 Q. Do you know when you completed that probation?
22 A. No.
23 Q. Have you been -- ever been involved in a lawsuit
24 other than the present one?
25 A. Not that I know of.
Lexitas
1 Q. Have you ever filed for bankruptcy?
2 A. No.
3 Q. Other than the two DWIs that you just testified
4 to, have you ever been arrested?
5 A. No.
6 Q. So just the two DWI arrests?
7 A. Yeah.
8 Q. And those both ended in -- in plea agreements?
9 A. Uh-huh.
10 Q. Do you recall what specifically you pled to in
11 each instance?
12 A. No. I don't know how that's relevant.
13 Q. Ever convicted of anything other than those two
14 DWIs?
15 A. No. Sorry, I was doing the head thing.
16 Q. Ever indicted for anything other than those two
17 DWIs?
18 A. No.
19 Q. Ever investigated by Texas Child Protective
20 Services?
21 A. No.
22 Q. Which I'll refer to as CPS --
23 A. Okay.
24 Q. -- just so we're clear on that.
25 And, sir, a little work history. You are
Lexitas
1 not a health care professional of any sort, are you?
2 A. No.
3 Q. You're not a doctor?
4 A. Excuse me. No.
5 Q. You're not a nurse, dentist, paramedic, nurse's
6 aide or health care provider of any sort?
7 A. No. I took cambot -- combat lifesaving skills in
8 the military, but other than that, I am not a paid health
9 care professional.
10 Q. You're not a professional educator, are you?
11 A. No.
12 Q. You're not a teacher, principal, coach, school
13 administrator or school district employee?
14 A. No.
15 Q. You're not a member of law enforcement, are you?
16 A. No.
17 Q. You're not a peace officer, probation officer or
18 first responder of any sort?
19 A. No. Sorry.
20 Q. Were you any of these things that I just asked in
21 February of 2016?
22 A. No.
23 Q. Weren't an educator in February 2016?
24 A. No.
25 Q. Weren't a peace officer of any sort in February
Lexitas
1 2016?
2 A. No.
3 Q. Weren't a health care professional or health care
4 provider of any sort in February of 2016?
5 A. No.
6 Q. You do not professionally provide care to
7 children, the disabled or the elderly, do you?
8 A. No.
9 Q. And you did not professionally provide care to
10 children, the disabled or the elderly in February 2016,
11 did you?
12 A. I'm sorry, can you ask that again. I'm sorry.
13 Q. You did not professionally provide care to
14 children, the disabled or the elderly in February 2016,
15 did you?
16 A. No.
17 Q. Do you have any training in child care, child
18 psychology, child health?
19 A. No.
20 Q. Are you a parent yourself?
21 A. I'd rather not answer that question.
22 Q. There's not an objection on the table, sir. You
23 have to answer the question.
24 Are you a parent, sir?
25 A. I'm going to need a minute.
Lexitas
1 MR. KRATOVIL: We can't take a break with a
2 live question.
3 MR. MAXWELL: If there's a question on the
4 floor, if you can answer it, answer it. If you can't,
5 then just say --
6 Q. (BY MR. KRATOVIL) And I'm happy to give you a
7 break after -- happy to take a break after the question is
8 answered.
9 A. Yes.
10 Q. How many children do you have, sir?
11 A. Two.
12 Q. And where do your children live?
13 A. In the Panhandle.
14 Q. Are you the primary care provider for those
15 children?
16 A. No.
17 Q. Are you involved in those children's lives day to
18 day?
19 A. I am not.
20 Q. Were you involved in those children's lives day
21 to day in February 2016?
22 A. I am not or was not.
23 Q. So it's fair to say, you don't have much
24 experience dealing with children?
25 A. I don't think that's fair to say, no.
Lexitas
1 Q. Why is it not fair to say?
2 A. I've -- I raised my cousins.
3 Q. How many cousins?
4 A. What -- four. One, two, three, four. Four,
5 right? One -- yes.
6 Q. And so I blew through your request for a break.
7 If you still need that break, I'm happy to take it now.
8 THE WITNESS: I'd like it, yes.
9 MR. KRATOVIL: Okay. Very good. We're off
10 the record.
11 THE VIDEOGRAPHER: Off the record, 9:27.
12 (Recess from 9:27 a.m. to 9:31 a.m.)
13 THE VIDEOGRAPHER: We're on the record, the
14 time's 9:31.
15 Q. (BY MR. KRATOVIL) Sir, just one cleanup item on
16 your cell phone. During the break were you able to
17 remember who your carrier two years ago was?
18 A. No, I was on my girlfriend at the time's plan. I
19 don't know what she used.
20 Q. And what was her name?
21 A. Monica.
22 Q. Last name?
23 A. Alexander.
24 Q. Middle name?
25 A. It will come to me. That's probably why we broke
Lexitas
1 up. Ruth.
2 Q. So as of two years ago, February 2016, you were
3 on Monica Ruth Alexander's cell phone plan?
4 A. Yes.
5 Q. And do you know who Ms. Alexander used as a cell
6 phone carrier?
7 A. Her mother.
8 Q. Her mother's not a cell phone carrier.
9 A. Oh, it was her plan. I'm sorry.
10 Q. AT&T, Sprint, Verizon?
11 A. I didn't ask.
12 Q. You don't know. And when did you switch from
13 Ms. Alexander's plan?
14 A. Around the time we separated. When would that
15 have been? Shoot. It would have been -- excuse me. The
16 end of 2016, the beginning of 2017. I can't remember.
17 Q. And at that point, you got your own cell phone?
18 A. Yes.
19 Q. With what carrier?
20 A. It was a prepaid AT&T.
21 Q. Prepaid AT&T. So from early 2017 or late 2016 to
22 the present, you've been with prepaid AT&T?
23 A. Yes, sir.
24 Q. And you can't remember prior to that who
25 Ms. Alexander was with?
Lexitas
1 A. I don't think I ever knew. It was -- I mean, I
2 just -- they asked for money, I gave it to them.
3 Q. All right. Now, sir, before the break we covered
4 some of the things that you're not. You're not a health
5 care provider, not an educator, not a law enforcement
6 officer. What do you do for a living, sir?
7 A. You know, that's a great question. I help out
8 with political campaigns.
9 Q. And how many years have you worked in politics?
10 A. Since 2014 or '15.
11 Q. And how did you get into politics?
12 A. I submitted my résumé.
13 Q. To whom?
14 A. Well, first it was with Wendy Davis' campaign.
15 They didn't hire me.
16 Q. Wendy Davis, the state senator from here in
17 Fort Worth, who later ran for governor?
18 A. Yes.
19 Q. And she's a Democrat?
20 A. Last I checked.
21 Q. And after you submitted your résumé to Senator
22 Davis' campaign, she didn't hire you?
23 A. No.
24 Q. Who did you submit your résumé to next?
25 A. I -- after that, I did a -- a session in Austin.
Lexitas
1 I was a staffer -- well, intern, staffer, leg. assistant.
2 Whatever you want to call it?
3 Q. And who were you a staffer for in Austin?
4 A. Kenneth Sheets.
5 Q. Okay. And he's a representative from Collin
6 County?
7 A. Is it Collin? I know Mesquite. I don't know
8 what county that is.
9 Q. And after you got done working for Representative
10 Sheets, who did you work for next?
11 A. After that I worked for Charlie Geren.
12 Q. Okay. So you went from Kenneth Sheets
13 legislative ofsted -- office in Austin, excuse me, to
14 Charlie Geren's campaign?
15 A. The campaign, yes.
16 Q. You have -- you have some education in politics,
17 don't you, sir?
18 A. I have a degree in political science, yes.
19 Q. From where?
20 A. Texas A&M, Central Texas.
21 Q. And you also have a graduate degree, don't you?
22 A. Well, don't give me more credit than I have now.
23 I haven't finished that one.
24 Q. Well, tell me about it. Well, you started one?
25 A. Yes.
Lexitas
1 Q. Where?
2 A. George Washington University.
3 Q. And what was that advanced degree you were
4 seeking?
5 A. Political management.
6 Q. Okay. And so what -- what attracted you to
7 Representative Geren's campaign?
8 A. I needed a job.
9 Q. And how did you get that job?
10 A. Sent my résumé after I worked with Sheets.
11 Q. And who hired you?
12 A. Murphy Nasica.
13 Q. And who's that?
14 A. A political consultant, I guess, firm.
15 Q. So Murphy Nasica is not a person, but a
16 consulting firm?
17 A. Yes.
18 Q. Could you spell that -- Murphy I think is pretty
19 easy. What's that second name?
20 A. I think it's N-a -- are we good on it?
21 Q. Please go ahead and answer the question.
22 A. N-a-i -- man, I don't know. N-a-s-c-a, I think.
23 Q. And who at Murphy Nasica hired you?
24 A. That would have been either -- oh. What's her
25 name? It'll come to me. I know it. Stephanie something.
Lexitas
1 I think that was her name. Stephanie something. I think
2 it was Stephanie. I'll have to go back and check, but I'd
3 be happy to . . .
4 Q. Was she in Austin or was she here in Fort Worth?
5 A. Austin.
6 Q. So you were hired in Austin to work for Murphy
7 Nasica. How did you make it from Austin and Murphy Nasica
8 to Charlie Geren in Fort Worth?
9 A. They were his consultant that ran his campaign.
10 Q. Because you were working for his consultant?
11 A. Yeah. Yeah.
12 Q. And what was your starting compensation with the
13 Geren campaign?
14 A. I think -- let me think. Somewhere around 3,000,
15 I think.
16 Q. And any expenses reimbursed? Did they pay for
17 your cell phone or your gas or anything like that?
18 A. I think sometimes they would pay for gas, but I
19 don't -- I think towards the end of the campaign, we got a
20 gas -- whatever you want to call it. Gas -- help with
21 gas.
22 Q. Was there any success or win bonus in your
23 compensation package?
24 A. No.
25 Q. And when did you hire on with Murphy Nasica?
Lexitas
1 A. That was right after -- when -- so June 1st was
2 the end of session. I think just a couple weeks after
3 that.
4 Q. So we're talking June 2015?
5 A. Yes, sir.
6 Q. So you started with Murphy Nasica in June 2015.
7 How fast did they get you up here to Fort Worth?
8 A. It was like two weeks afterwards.
9 Q. So you started in Fort Worth working for Charlie
10 Geren's campaign in June 2015?
11 A. Yes.
12 Q. And what were your duties in that position?
13 A. What weren't they? It was a lot of direct voter
14 contact, knocking on -- I knocked on a lot of people's
15 doors asking for their support for Charlie. Not money,
16 for votes. Phone calling, too. What else? Oh, I picked
17 up the -- the push cards. The little cards we hand out at
18 the door from Arlington. That was my designated job. I
19 would put up road signs or yard -- what is it? The big --
20 you know, the big signs. I would put those up. Let's
21 see. What else? Let me think. And -- I mean, that's --
22 that's basically it.
23 Q. Where -- when you would make -- you said -- you
24 testified you'd make calls for the Geren campaign. Where
25 did those calls come from? Where did you make them from?
Lexitas
1 A. We had an office across the street from Charlie's
2 barbecue restaurant.
3 Q. So across from the Railhead in west Fort Worth?
4 A. Yes.
5 Q. Do you remember the address of that office?
6 A. No.
7 Q. Was it Charlie's state rep office?
8 A. No.
9 Q. It was a separate office rented by the campaign?
10 A. Yeah.
11 Q. Was it a supporter giving you space or was it the
12 campaign signed a lease?
13 A. That was above my pay grade.
14 Q. Do you have an estimate as to how many doors you
15 knocked on for Charlie Geren during that 2016 campaign?
16 A. Over 10,000.
17 Q. You personally knocked on over 10,000 doors for
18 Charlie Geren?
19 A. Yeah.
20 Q. And when did you start knocking on doors?
21 A. June '15.
22 Q. So from June '15 through the March 1st primary,
23 you were knocking on doors -- March 1, 2016 primary?
24 A. Yes, sir.
25 Q. How often would you communicate with
Lexitas
1 Representative Geren while you were doing that?
2 A. Not very often at all.
3 Q. How often did you see Representative Geren during
4 the campaign?
5 A. I didn't see him until probably 2016. And I
6 really only saw him when I started doing signs. We had to
7 get a truck because my hatchback doesn't fit big signs.
8 So it was me and him putting them up at first.
9 Q. You and Representative Geren?
10 A. Yes, sir.
11 Q. The two of you?
12 A. Yes.
13 Q. So you got to know him fairly well?
14 A. And there's another -- Chris was his name I
15 think -- yeah. Chris, he was there, too.
16 Q. And do you remember Chris's last name?
17 A. No, but he interviewed for Bo French's campaign
18 manager, so I'm sure y'all have that information.
19 Q. So you and Representative Geren worked together
20 to put up his signs during the 2016 --
21 A. For a couple days. And to make it easier on him,
22 we got a rental truck so he could go do legislative things
23 or whatever state representatives do.
24 Q. So you got to know Representative Geren pretty
25 well putting up signs with him?
Lexitas
1 A. He's not that much of a talker, but we did
2 conversate from time to time.
3 Q. How many days a week did you work for the Geren
4 campaign?
5 A. Six to seven days a week.
6 Q. And how many hours a day?
7 A. Shoot. Let me think. Anywhere from eight hours
8 a day to -- I mean, really all night.
9 Q. During any of the times you interacted with
10 Representative Geren, was he ever under the influence of
11 alcohol?
13 That's outside the motion to dismiss.
15 attorney's advice, not answer that question?
16 A. Yes, sir.
17 Q. All right. So you consistently worked more than
18 40 hours a week for the Geren campaign from June 2015
19 through the March 1, 2016 Republican primary?
20 A. Yes, sir.
21 Q. More than 50 hours a week?
22 A. Probably.
24 A. I'm not good with math. How many hours is that a
25 day?
Lexitas
1 Q. That would be in the neighborhood of 10 to 12
2 hours?
3 A. Okay. So yeah.
4 Q. So the answer is yes --
5 A. Yes.
6 Q. -- more than 60 hours a week?
7 A. Yeah.
9 A. Somewhere around there I think would be good.
10 Q. So for six months you worked 60 to 70 hours a
11 week for the Geren campaign, six to seven days a week?
12 A. It was longer than six months.
13 Q. Longer than six months?
14 A. Yeah. Well, beginning off it was probably only
15 about eight hours a day for six days. But then once we
16 got closer, that's when it got into 60 and 70 hours a
17 week.
18 Q. So it's fair to say you worked very hard for that
19 campaign?
20 A. I think so. You probably have to ask them.
21 Q. Fair to say you were eager for Representative
22 Geren to prevail?
23 A. Yes.
24 Q. Fair to say you were invested in the outcome of
25 the campaign?
Lexitas
3 A. I wanted Mr. Geren to win, yes.
4 Q. You badly wanted Mr. Geren to win?
6 A. What do you mean by "badly"?
7 Q. (BY MR. KRATOVIL) Very much.
8 A. Yes.
9 Q. Who besides yourself worked for the Geren
10 campaign?
11 A. Let's see. There was Laramie Stroud. What was
12 his name from Montana? Brian -- that's his name. Brian
13 O'Leary. Chris -- I don't remember his last name. And
14 what's her name? Mary Allen.
15 Q. Okay. Did you have a title while you worked for
16 the Geren campaign?
17 A. Field director.
18 Q. You were the field director of the Geren campaign
19 in 2016?
20 A. Uh-huh. Well, I think they just gave me that
21 title to make me feel special, but . . .
22 Q. What about Mr. Stroud, what was his role?
23 A. He was a campaign manager.
24 Q. And so he was ultimately in charge, was he your
25 boss?
Lexitas
1 A. Of sorts, yes.
2 Q. What about Mr. Brian O'Leary?
3 A. We all had the -- everyone, other than Laramie,
4 we all had the same titles, field director.
5 Q. And Mary Allen also a field worker?
6 A. That is correct.
7 Q. And Chris, the guy you can't remember his last
8 name, also a field worker?
9 A. (Witness nods head.)
10 Q. So it sounds like there were five paid employees
11 of the Geren campaign last time?
12 A. One of them, Chris and Brian switched spots
13 because he went to a different campaign -- Brian went to a
14 different campaign and Chris came on.
15 Q. So Chris, whose last name we can't remember
16 replaced Brian?
17 A. Yes, sir.
18 Q. And who -- do you know what campaign Brian went
19 to work on?
20 A. No. It was out in Brownwood. I don't remember
21 the name of it.
22 Q. Were all of these employees employed through the
23 Murphy Nasica political consulting firm?
24 A. That's who paid us, yes.
25 Q. So nobody was employed directly by the Geren
Lexitas
1 campaign?
2 A. Right.
3 Q. They were -- he hired a political consultant who
4 hired you?
5 A. Yes.
6 Q. And that's true of the other employees as well?
7 A. Yes.
8 Q. And who had seniority -- you started in June
9 2015. Did anybody start prior to you on this campaign?
10 A. No, sir. I was on the ground first.
11 Q. So you were the most senior employee of the
12 campaign?
13 A. Yes, sir.
14 Q. Served the campaign the longest?
15 A. Yes.
16 Q. What -- was there anything different about
17 Mr. Stroud's role than your role?
18 A. Yeah. He had to do other things as a campaign
19 manager. I don't know what he did.
20 Q. Okay. So you know there were differences, but
21 you don't know what those differences were?
23 Q. How often would you meet with the other members
24 of the Geren campaign team?
25 A. Well, once we finally all pulled together, it was
Lexitas
1 probably daily.
2 Q. So you'd meet with Laramie Stroud, Brian O'Leary,
3 who was later replaced by Chris and Mary Allen daily?
4 A. Yes, if we were working. Not all the times, but
5 most.
6 Q. Starting when -- when were those -- did those
7 daily meetings commence?
8 A. Not until 2016.
9 Q. So January 2016?
10 A. Oh, actually May -- no, I may have lied. It may
11 have been before then. Because I remember we -- maybe
12 around October or November, I'm sorry.
13 Q. So starting in October or November, you would
14 meet daily with Laramie Stroud and the other paid members
15 of the Geren campaign team?
16 A. As best my memory can recall.
17 Q. And where would those meetings occur?
18 A. At the place by the -- barbecue place.
19 Q. That office across from the Railhead?
20 A. Yes, sir.
21 Q. Anywhere else you would meet?
22 A. Waffle House. Sometimes we would eat and meet.
23 Q. And who on the Geren campaign team was in charge
24 of opposition research?
25 A. I have no idea.
Lexitas
1 Q. Did you ever meet at Representative Geren's
2 legislative office?
3 A. At the end of the campaign, they came for the
4 party. The -- what's called election night party.
5 Q. But nothing prior to the election night party?
6 A. Huh-uh.
7 Q. So the political team, including you and campaign
8 manager Stroud, didn't interact with the legislative
9 staff?
10 A. Laramie might have known them previously, but --
11 because I know he's -- he's -- no.
12 Q. You just told me that you don't know who was in
13 charge of opposition research for the 2016 Geren campaign?
14 A. Yeah, I -- I wasn't involved in that.
15 Q. Who would design the mailers that the 2016
16 campaign sent out?
17 A. I -- oh, I do know that -- maybe. Somebody at
18 Murphy.
19 Q. Say again, please.
20 A. Somebody at Murphy.
21 Q. Somebody at Murphy. In Austin or in Fort Worth?
22 A. In Austin.
23 Q. And do you know who at Murphy Nasica designed
24 Mr. Geren's mailers during the last campaign?
25 A. Oh, no.
Lexitas
1 Q. And do you know who would approve those mailers?
2 A. No.
3 Q. Were you involved in that approval process?
4 A. Oh, no.
5 Q. Was Laramie Stroud involved in that approval
6 process?
7 A. I don't know.
8 Q. Did the Geren campaign at any point retain a
9 private investigator to look into Mr. French's background?
10 A. I wouldn't know.
11 Q. Who would know?
12 A. I also wouldn't know that.
13 Q. You don't know who would know?
14 A. Oh. That was a question. I -- I don't know.
15 Q. You worked 70 hours a week for this campaign for
16 over six months and you don't know who would know that?
17 A. About hiring a private investigator?
18 Q. Yes.
19 A. Yeah. I was -- I was in -- my job was to talk to
20 voters, not . . .
21 Q. Same question. You don't know who would have
22 been in charge of opposition research?
23 A. Huh-uh.
24 Q. Do you know what I mean when I say "opposition
25 research"?
Lexitas
1 A. I'm familiar with the term.
2 Q. How do you understand the term?
3 A. Researching a opponent's history.
4 Q. In order to do what?
5 A. Know more about your opponent and how you can
6 contrast yourself if you're a candidate.
7 Q. And did the Geren 2016 campaign undertake any
8 opposition research?
9 A. I don't know that.
10 Q. Again, 70 hours a week working for this campaign,
11 you don't know if they did opposition research?
12 A. Again, my job was to talk to voters, not
13 opposition research.
14 Q. Do you know if Representative Geren personally
15 approved mailers and news alerts in the materials that
16 went out from the campaign?
17 A. I don't know for a fact either way.
18 MR. KRATOVIL: I'd like to take a short
19 break.
22 THE VIDEOGRAPHER: We're on record. The
23 time is 10:00 a.m.
24 Q. (BY MR. KRATOVIL) Sir, you understand you're
25 still under oath?
Lexitas
1 A. Yes.
2 Q. Sir, have you ever met Bo and Sheridan's -- Bo
3 and Sheridan French's four small children?
4 A. I'm trying to think if they ever brought them to
5 a polling location or not. Not that I can remember.
6 Q. So you can't recall meeting the four French
7 children at any point?
8 A. Let me take a minute. Let me think. Not that I
9 can remember.
10 Q. Have you ever seen the four French children?
11 A. On his -- on his -- on his little push cards.
12 Q. So you've seen a picture of them. Have you ever
13 seen them in person?
14 A. No.
15 Q. Have you ever been in the same room with them?
16 A. No.
17 Q. Ever talked with or interacted with the French
18 children, any of them?
19 A. No. Sorry, head thing.
20 Q. Have you ever been inside the French family home?
21 A. No.
22 Q. So you have no personal knowledge about Bo and
23 Sheridan's French parenting of their four small children?
24 A. No.
25 Q. And you don't have any personal knowledge
Lexitas
1 regarding the health or welfare of those children?
2 A. No.
3 Q. Anyone with the Geren 2016 campaign have regular
4 interaction with the French children?
5 A. You probably have to ask them.
6 Q. You're not aware of any?
7 A. No, sir.
8 Q. Is there anyone with the Geren 2016 campaign who
9 have had personal knowledge regarding the health and
10 welfare of those children?
11 A. You'd have to ask them. I mean, I don't know.
12 Q. You're not -- you're not aware of any reason that
13 anyone with the Geren 2016 campaign would have had
14 personal knowledge of the health and welfare of those
15 children?
16 A. Yeah.
17 Q. The Republican primary election last cycle was
18 Tuesday, March 1, 2016; is that correct?
19 A. Yes.
20 Q. And that's as early as a primary can be in Texas?
21 A. Okay.
22 Q. So the Friday before the election was Friday,
23 February 26, 2016?
24 A. Okay.
25 Q. Does that sound right?
Lexitas
1 A. Sounds right.
2 Q. No reason to disagree with me?
3 A. Unless you just want me to.
4 Q. No, I don't want that. I want you to tell the
5 truth.
6 Sir, are you aware that under Texas Family
7 Code, Section 26 -- 261.107, a person commits a state jail
8 felony by knowingly making a false report with intent to
9 deceive to Child Protective Services?
10 A. I didn't know about that.
11 Q. Do you have any reason to disagree with me?
12 A. I mean, it's a law, it's a law.
13 Q. Sir, are you aware that Texas Child Protective
14 Services and the West Over Hills police department visited
15 the home of Bo and Sheridan French on the night of Friday,
16 February 26, 2016?
18 Q. (BY MR. KRATOVIL) Sir, are you going to follow
19 your attorney's advice and not answer that question?
21 Q. Do you know why Texas Child Protective Services
22 and the Westover Hills police department visited the home
23 of Bo and Sheridan French on the night of Friday, February
24 26, 2016?
25 MR. MAXWELL: I'm instructing you to not
Lexitas
1 answer that question.
2 A. I'm not answering.
7 Services visited the home of Bo and Sheridan French on the
8 morning of Saturday, February 27, 2016?
9 MR. MAXWELL: I'm instructing him to not
15 visited the home of Bo and Sheridan French on the morning
16 of Saturday, February 27, 2016?
23 Services visited the home and Bo and Sheridan French again
24 on Sunday, February 28, 2016?
25 MR. MAXWELL: Instructing you to not answer
Lexitas
1 that question.
6 again visited the home of Bo and Sheridan French on the
7 morning of Sunday, February 28, 2016?
11 your attorney's advice and decline to answer that
12 question?
13 A. Yes, sir.
14 Q. Would you agree with me that Sunday, February 28,
15 2016, was the Sunday before the Tuesday Republican
16 primary?
17 A. I'm sorry. Will you say those dates again.
18 Q. Sunday, February 28, 2016, was the Sunday before
19 the Tuesday Republican primary.
20 A. Yes.
21 Q. And Saturday, February 27, 2016, was the Saturday
22 before the Tuesday Republican primary?
23 A. (Witness nods head.)
24 Q. And Friday, February 26, 2016, was the Friday
25 before the Tuesday Republican primary?
Lexitas
1 A. Yes.
2 Q. So we're agreed on that?
3 A. Uh-huh.
4 Q. Sir, are you aware that Child Protective Services
5 received an anonymous report on Friday, February 26, 2016,
6 alleging that Bo French was abusing and neglecting his
7 children?
12 A. Yes, sir.
13 Q. Sir, do you have any knowledge of the anonymous
14 report filed with Texas Child Protective Services on
15 Friday, February 26, 2016, alleging that Bo French was
16 abusing and neglecting his small children?
21 A. Yes, sir.
22 Q. Sir, why would someone make an anonymous report
23 to CPS on Friday, February 26, 2016, alleging that Bo
24 French was abusing and neglecting his small children?
Lexitas
4 A. Yes, sir.
5 Q. Any -- no idea at all why that report was filed?
6 MR. MAXWELL: Objection -- sorry. I'm
7 instructing you to not answer that question.
10 A. Yes.
11 Q. Sir, did you make a politically motivated fake
12 call to CPS about the welfare of the children of Bo French
13 to gain an advantage for the Charlie Geren campaign?
17 your attorney's advice and refuse to answer that question?
18 A. Yes.
19 Q. Was Charlie Geren aware that you made the phone
20 call to CPS alleging that the French children were being
21 abused?
Lexitas
1 A. Yes.
2 Q. Did Charlie Geren himself approve this fraudulent
3 phone call to Child Protective Services about the alleged
4 abuse of the French children in his race against Bo French
5 to gain a political advantage?
9 your attorney's advice and refuse to answer my question?
10 A. Yes.
11 Q. So you have no idea why someone made a fake
12 report to CPS on the night of Friday, February 2016,
13 alleging that Bo French broke the ribs of his young son,
14 Hawk?
18 your attorney's advice and decline to answer that
19 question?
20 A. Yes.
21 Q. Do you know if Hawk French had broken ribs or
22 not?
23 A. That's what I heard.
24 Q. Heard from whom?
25 A. Bo.
Lexitas
1 Q. When?
2 A. It was at a polling location. The sheriff's
3 office over on the north side. What is that? What day
4 was that? I was -- I don't remember the exact day, but it
5 was during that week.
6 Q. So if I understand your testimony correctly,
7 you're claiming that Bo French told you that his
8 three-year-old son -- then three-old-year son, Hawk French
9 had broken ribs?
10 A. Yes.
11 Q. Why would he tell you that?
12 MR. MAXWELL: Objection, form. You can
13 answer.
14 THE WITNESS: Okay.
15 A. Him and his campaign manager were having a
16 discussion about how much of a bad ass his son was.
17 Q. (BY MR. KRATOVIL) Were you part of that
18 discussion?
19 A. I was -- I was there.
20 Q. Were you eavesdropping?
21 A. I was talking to them.
22 Q. Were you part of the discussion about Hawk
23 French?
24 A. I don't know if I was a part of it.
25 Q. So you overheard Mr. French tell his campaign
Lexitas
1 manager that?
2 A. Yeah.
3 Q. What else did you overhear?
4 A. I mean, lots of things. I mean, what do you want
5 to know?
6 Q. What else did you overhear about Hawk French and
7 this alleged injury?
8 A. Whenever I asked what happened, they didn't know
9 why. They didn't know why his ribs were hurt and that
10 they took him to a chiropractor.
11 Q. Hurt or broken?
12 A. He said broke.
13 Q. So your testimony is that you overheard Bo French
14 and his campaign manager discussing three-year-old Hawk
15 French having broken ribs?
16 A. Yes.
17 Q. And when and where did this discussion occur?
18 A. Like I said, I don't remember the exact day, but
19 it was the -- what is the name of that? What's the --
20 shoot. What's the name of that place. It's the early
21 voting location at the sheriff's office over there on your
22 way to Azle. I forget the name of the -- what is the name
23 of that? But it was sometime in that week. I don't
24 remember the exact day.
25 Q. Sir, do you believe Bo French has ever abused any
Lexitas
1 of his four children?
3 A. I don't know that.
4 Q. (BY MR. KRATOVIL) Do you have any reason to
5 believe that Bo French ever abused any of his four
6 children?
7 A. I don't know.
8 Q. Do you believe Bo French has ever neglected any
9 of his four children?
12 A. I mean, I wouldn't have knowledge of that.
13 Q. You don't have knowledge of that?
14 A. I mean, I don't know how he interacts with his
15 children.
16 Q. Do you believe Sheridan French has ever abused
17 any of her four children?
19 A. I won't know that.
20 Q. (BY MR. KRATOVIL) Do you believe Sheridan French
21 has ever neglected any of their four children?
23 A. I don't know.
24 Q. (BY MR. KRATOVIL) Do you have any personal
25 knowledge of Bo French ever abusing any of his four
Lexitas
1 children?
3 A. No.
4 Q. (BY MR. KRATOVIL) Do you have personal knowledge
5 of Sheridan French ever abusing any of her four children?
7 A. No.
9 of Bo French ever neglecting any of his four children?
11 A. No.
13 of Sheridan French ever neglecting any of her four
14 children?
16 A. No. No.
17 Q. (BY MR. KRATOVIL) So let's go back to this
18 conversation you overheard regarding Hawk French's broken
19 ribs. You said something about a chiropractor. Tell me
20 about that part of the conversation.
21 A. When I asked how he got hurt, they said
22 roughhousing or something. And I said, Oh, what did you
23 do then? He said, we took him to a chiropractor.
24 Q. And what did you say? How did you follow up?
25 A. I didn't say anything after that.
Lexitas
1 Q. Was that the end of the conversation?
2 A. Yeah.
3 Q. Did this conversation cause you to have concerns
4 about the welfare of Hawk French?
5 A. It sounded very odd to me, yes.
6 Q. Why did it sound odd to you?
7 A. I mean, I -- if I had -- if my child had broken
8 ribs, I wouldn't take him to a chiropractor.
9 Q. Who did you tell about this conversation?
10 A. Oh, shoot. Nobody really at first. I kind of
11 kept it to myself really just kind of thinking it over.
12 Q. At first you didn't tell anybody. Who did you
13 tell later?
14 A. On, I think, Saturday I told -- or maybe that day
15 actually -- Laramie about it. I asked him if he heard
16 about the stuff or heard about it.
17 Q. Who else was a part of that conversation?
18 A. Nobody.
19 Q. Just you and Laramie talking one on one?
20 A. Yes, sir.
21 Q. Where did you have that conversation?
22 A. I don't know.
23 Q. And what specifically did you tell Laramie?
24 A. What I just repeated to you. I -- that I heard
25 at a polling -- that I heard Bo at a polling location say
Lexitas
1 his child had broken ribs.
2 Q. And this was occurring on the Saturday after you
3 overheard Bo say this?
4 A. No, I don't -- man, I don't remember the --
5 sorry. Let me think for a minute. When did I tell him?
6 I don't remember the exact day, but it was afterwards.
7 Q. Tell me about the conversation. What were you
8 and Laramie talking about?
9 A. How it was -- it just seemed odd. And it
10 definitely gave me pause for concern.
11 Q. What do you mean by "pause for concern"?
12 A. Like you don't take people to chiropractors for
13 broken ribs.
14 Q. And what did Laramie say when you told him this?
15 A. I don't recall.
16 Q. Was this conversation on the phone or was it in
17 person?
18 A. It was on the phone.
19 Q. It was on the phone. Was this the cell phone --
20 your girlfriend's cell phone?
21 A. Well, it was my cell phone, but she paid for
22 it -- no, I paid for it. But, yes, on that old phone.
23 Q. How did this even come up in a conversation with
24 Laramie?
25 A. It was just -- I was like, man, that's weird.
Lexitas
1 Q. Were you talking about Mr. French?
2 A. Well, I mean, it was about him.
3 Q. What about him?
4 A. I'm confused.
5 Q. Mr. Stroud was the campaign manager, correct?
6 A. Uh-huh.
7 Q. You'd speak to him daily about the campaign,
8 correct?
9 A. Yeah.
10 Q. Were you updating him on the campaign when you
11 had this conversation?
12 A. No. I think it was the end of the day or
13 something. And I was just -- I was telling him how I was
14 worried.
15 Q. You claimed to Laramie Stroud you were worried
16 about the welfare of Hawk French?
17 A. I mean, I don't remember exact words I used.
18 Q. But that was the thrust of the conversation?
19 A. What do you mean by "thrust"?
20 Q. That was the purpose or point of the
21 conversation?
22 A. Yes.
23 Q. So the point of your conversation was to share
24 with your campaign manager -- Mr. Geren's campaign
25 manager, Laramie Stroud, that you were worried about the
Lexitas
1 welfare of Hawk French?
2 A. Well, I mean, it was -- it wasn't really in that
3 capacity.
4 Q. What capacity was it in?
5 A. We were friends at the time. We would go have
6 drinks from time to time, you know. So it was just kind
7 of like.
8 Q. Why would you share that information with
9 Mr. Stroud?
10 A. I don't know.
11 Q. What did you expect Mr. Stroud to do with that
12 information?
13 A. Nothing.
14 Q. Did you think that information could be used to
15 gain a political advantage over Mr. French?
16 A. It wasn't about that.
17 Q. What was it about?
18 A. I was just worried about a kid.
19 Q. You were worried about a kid?
20 A. Yeah.
21 Q. Did you give Mr. French -- did you follow-up with
22 Mr. French asking how Hawk's doing, is Hawk getting
23 better?
24 A. Not after our conversations. I -- I tried to
25 keep my conversations, well, really brief.
Lexitas
1 Q. So you worried about his son, but you didn't ask
2 him how his son was doing?
3 A. No.
4 Q. Did you ask him, you know, if they ever
5 determined if the ribs were broken or if it was just, you
6 know, a little bit of pain?
7 A. I did not.
8 Q. You never had any follow-up conversation with
9 Mr. French at all, regarding the welfare of Hawk French?
10 A. Not that I can recall.
11 Q. So you were worried enough about the welfare of
12 Hawk French to report this to your campaign manager, but
13 you weren't worried enough about it to ask Mr. French how
14 the boy was doing?
15 A. I mean, I did when I heard about it to begin
16 with.
17 Q. And what did Mr. French say when you asked at
18 that point how his son was doing?
20 Q. Did he --
21 A. Let me think.
22 Q. Please do.
23 A. They said -- I don't remember.
24 Q. Did you -- did he say something that would lead
25 you to believe that his -- his son was having medical
Lexitas
1 issues when you made that inquiry?
3 Q. So why were you so concerned after hearing this
4 conversation?
5 A. Because it just sounded really odd to me.
6 Q. So do you know what Mr. Stroud did with that
7 information after receiving it?
8 A. He didn't do anything with it.
9 Q. How do you know he didn't do anything with it?
10 A. I guess I don't.
11 Q. When's the last time you talked to Laramie
12 Stroud?
13 A. Six months to a year.
14 Q. Six months to a year ago?
15 A. Yeah.
16 Q. You didn't talk to him at all during 202
17 proceedings in this matter?
18 A. (Witness shakes head.)
19 Q. Did you talk to his attorney Mr. Bill Kirkman at
20 any point?
21 A. No. I don't know who that is.
22 Q. Did you -- did you ever get any additional
23 information on the welfare of Hawk French other than this
24 one conversation you overheard?
25 A. Huh-uh.
Lexitas
1 Q. Do you know if Mr. Stroud ever followed up with
2 Bo or Sheridan French regarding Hawk's welfare?
3 A. You have to ask him.
4 Q. Do you have any reason to believe that this
5 alleged rib injury to Hawk French was the result of abuse
6 by his father Bo French?
8 A. I didn't know.
9 Q. (BY MR. KRATOVIL) What didn't you know?
10 A. How he got hurt.
11 Q. Do you have any reason to believe that this
12 alleged injury to Hawk French was a result of neglect by
13 Bo French?
15 A. I mean, I didn't know. I wasn't privy to his
16 family life.
17 Q. (BY MR. KRATOVIL) Did you have any reason to
18 believe that this alleged injury to Hawk French was the
19 result of abuse by Sheridan French?
21 A. I don't know.
22 Q. (BY MR. KRATOVIL) Did you have any reason to
23 believe that this alleged injury to Hawk French was a
24 result of neglect by Sheridan French?
Lexitas
1 A. Can you say it again, I'm sorry. I was --
2 Q. (BY MR. KRATOVIL) Sure. Did you have any reason
3 to believe that this alleged injury to Hawk French was the
4 result of abuse by Sheridan French?
6 A. I don't know.
7 Q. (BY MR. KRATOVIL) Or neglect by Sheridan French?
9 A. I don't know.
10 Q. (BY MR. KRATOVIL) Did you tell anyone other than
11 Laramie Stroud about this alleged broken rib injury to
12 Hawk French?
13 A. Huh-uh. No.
14 Q. No one at all?
15 A. I might have told my girlfriend at the time,
16 Monica.
17 Q. What did you tell Monica?
18 A. That I was worried. And I just kind of retell
19 the events that I just told y'all, that I heard Bo saying
20 his kid had broken ribs from roughhousing and they took
21 him to a chiropractor and I didn't really know if that was
22 normal or not.
23 Q. You said -- you added a detail in that. You said
24 the broken rib -- you heard the broken ribs were the
25 result of roughhousing. That's part of the conversation
Lexitas
1 you overheard between Bo and his campaign manager?
2 A. No, I asked -- I asked that. So, I guess, I was
3 a part of that conversation when -- I said, "Well, how'd
4 that happen?" And then they said, "I don't know.
5 Probably roughhousing."
6 Q. So why were you so worried?
7 A. Shouldn't we be worried about children. I
8 just -- I like kids. I mean, I --
9 Q. No special -- no special reason?
10 A. No.
11 Q. And how did you -- since you were so worried,
12 what -- what did you do?
13 MR. MAXWELL: I think I'm going to instruct
14 you not to answer in the context that that question was
15 asked.
16 THE WITNESS: Okay.
17 Q. (BY MR. KRATOVIL) You were worried about this
18 three-year-old child. What did you do to ensure the
19 safety of that three-year-old child?
20 MR. MAXWELL: Instructing you not to answer.
22 attorney's advice and not answer?
23 A. Yes.
24 Q. Do you think if a child is being abused or
25 neglected, the parents would take that child to a family
Lexitas
1 chiropractor?
2 MR. MAXWELL: Object to the form.
3 You can answer.
4 A. No.
5 Q. (BY MR. KRATOVIL) Do you think chiropractors
6 can't read an x-ray?
7 MR. MAXWELL: Object, form.
8 You can answer.
9 A. I just know -- I mean, I never really seen them
10 as health care professionals.
11 Q. (BY MR. KRATOVIL) You don't see chiropractors as
12 health care professionals?
13 A. Not to mend broken bones.
14 Q. Do you think they can diagnose a broken rib?
16 You can answer.
17 A. I don't know.
18 Q. (BY MR. KRATOVIL) You don't know if a
19 chiropractor can diagnose a broken bone?
20 A. I don't.
21 Q. You know chiropracty involves the manipulation
22 and spacing of bones?
24 A. Yes, I do know that.
25 Q. (BY MR. KRATOVIL) So you don't think a
Lexitas
1 chiropractor can diagnose a broken bone?
2 MR. MAXWELL: Objection. Asked and
3 answered.
5 A. What was the question again?
6 Q. Can a chiropractor diagnose a broken bone?
7 A. I mean, lots of people can. I mean, I just --
8 when I think of broken bones -- excuse me --
9 chiropractor's not the first thing I think of.
10 Q. If a chiropractor's not a health care
11 professional, what is a chiropractor?
13 You don't have to answer that question.
14 MR. KRATOVIL: Are you instructing him not
15 to answer that, Steve?
16 MR. MAXWELL: I'm instructing him not to
17 answer. That's outside the motion to dismiss.
19 attorney's advice and not answer that?
20 A. Yes.
21 Q. Have you ever reported any alleged child abuse or
22 neglect to Child Protective Services?
23 MR. MAXWELL: I'm instructing you not to
Lexitas
2 A. Yes, sir.
3 Q. Have you ever reported alleged child abuse or
4 neglect to the police?
5 MR. MAXWELL: Object -- I'm sorry. I'm
6 instructing you not to answer.
9 A. Yes.
10 Q. Did you call the police over this purported
11 concern for the welfare of Hawk French?
16 A. Yes.
17 Q. Did you call the -- did you call Texas Child
18 Protective Services over your purported concern for this
19 alleged injury to Hawk French?
23 attorney's advice and not answer that?
24 A. Yes.
25 Q. Other than this snippet of an overheard
Lexitas
1 conversation, did you have any other reason to believe
2 that Bo French was abusing or neglecting his children?
3 MR. MAXWELL: Object, form.
4 You can answer.
5 A. Not that I was aware of, no.
6 Q. (BY MR. KRATOVIL) No basis to think that Bo was
7 abusing his kids?
8 A. No.
9 Q. No basis to think that Bo was neglecting his
10 kids?
12 A. No. I mean, I -- I don't know. No.
13 Q. (BY MR. KRATOVIL) No basis to think Sheridan was
14 abusing her kids?
15 A. No.
16 Q. No basis to think that Sheridan was neglecting
17 her kids?
19 A. No.
20 Q. (BY MR. KRATOVIL) No basis to think that any
21 third-party caregiver, such as a grandparent or babysitter
22 was abusing these children?
24 A. No.
25 Q. (BY MR. KRATOVIL) No basis to think that a
Lexitas
1 third-party caregiver, such as a grandparent or babysitter
2 was neglecting these children?
4 A. Excuse me. No.
5 Q. (BY MR. KRATOVIL) So why did you call CPS, sir?
6 MR. MAXWELL: Do not answer that question.
7 I'm instructing you not to.
9 attorney's advice and not answer my question?
10 A. Yes.
11 Q. Any other conversations that you overheard
12 involving the welfare or health of the French children?
13 A. Let me think. No, not that I can think of.
14 Sorry.
15 Q. Do you know who made the anonymous report to
16 Child Protective Services on the evening of Friday,
17 February 26th, alleging that Bo French was abusing and
18 neglecting his children?
23 A. Yes, sir.
24 Q. Did you in any way participate in making this
25 report to CPS?
Lexitas
2 answer the question.
4 attorney's advice?
5 A. Yes.
6 MR. KRATOVIL: Why don't we just take a
7 two-minute break here, Steve.
8 MR. MAXWELL: Sure.
11 THE VIDEOGRAPHER: We're on the record, the
12 time is 10:34.
14 still under oath?
15 A. Uh-huh.
16 Q. During your almost eight months of work for the
17 Geren campaign, did you ever serve as a designated driver
18 for Mr. Geren?
19 A. Huh-uh.
20 Q. Let's go back and talk about working -- working
21 the polls for the Geren campaign. Was one of your
22 assignments to greet voters at the polls?
23 A. Yes, sir.
24 Q. And were you greeting -- did you ever greet
25 voters at the polls of the Tarrant County Sheriff's
Lexitas
1 office, North Patrol Division, which is located at 6651
2 Lake Worth Boulevard in Fort Worth?
3 A. That's the one I was trying to think of. Sorry.
4 Yes.
5 Q. And do you recall being there on February 17,
6 2016?
7 A. I'm sure I was, but it was -- I had to go -- I'm
8 sure.
9 Q. February 17, 2016, was part of the early voting
10 period in the last election?
11 A. Right. Yeah, I was -- I was at that location
12 quite a few times. So there's a good chance that I was
13 there.
14 Q. And was Mrs. Sheridan French there regularly as
15 well?
16 A. Yeah.
17 Q. And do you recall conversing with Mrs. Sheridan
18 French?
19 A. Yeah, a couple times. I remember one time in
20 specific she was mad that she thought that the Geren
21 campaign was having -- spreading rumors about law
22 enforcement coming over to their house. And I told her,
23 no, we weren't.
24 Q. Was that conversation on February 17, 2016?
25 A. I don't know.
Lexitas
1 Q. Does that sound about right?
2 A. I mean, it was during early vote. I just --
3 that's all remember.
4 Q. I'll represent that that what's Mrs. French has
5 testified to in a verified petition.
6 Does February 16, 2016, sound right for that
7 conversation?
8 A. Like I said, I just know it was early vote.
9 Q. No reason to disagree with me?
10 A. No.
11 Q. So tell me about that conversation with
12 Mrs. French, where she was concerned that the Geren
13 campaign was spreading rumors that the police were coming
14 over to their house?
15 A. I told her that no -- nobody I was knowledge of,
16 all the paid staff, like everyone on that list you made,
17 were not spreading that through direct voter contact or
18 social media or anything like that. And then that --
19 that -- what word am I looking for? I guess she didn't
20 believe me. So I called Charlie to talk to her and I just
21 handed her the phone.
22 Q. And so what did -- so what was the basis of
23 Mrs. French's concern that the Geren campaign was
24 spreading these rumors? Did she share that with you?
25 A. You'd have to ask her.
Lexitas
1 Q. Did she read aloud some text messages that she
2 had received?
4 Q. Did she read aloud some Facebook messenger --
5 messages she had received?
6 A. I remember her mentioning Facebook Messenger, but
7 other than that. I don't know if she read them out to me
8 or not. I think she might have said that somebody was
9 spreading them or something, and it was us that was doing
10 it. And I -- no paid Geren staff was doing that.
11 Q. What was the substance of the text messages that
12 she read aloud, if you recall?
13 A. I mean, I don't know.
14 Q. Had to do with law enforcement allegedly going to
15 the French house?
16 A. Yes.
17 Q. And you -- how did you respond when she shared
18 those concerns with you?
19 A. I said we weren't doing that. We weren't
20 spreading those rumors.
21 Q. And you just testified at that point you pulled
22 out your phone and called Representative Geren?
23 A. Yes, sir.
24 Q. And what did you say to Representative Geren?
25 A. First, I asked if he knew anything about this.
Lexitas
1 He said no. And then I handed the phone over to Sheridan,
2 I believe.
3 Q. Are you sure you handed the phone over to
4 Sheridan?
5 A. I know I offered. I don't know if she took it or
6 not. It was a while ago. Let me think. I can't say for
7 certain either way. I know I offered it, but I don't know
8 if she took it or not.
9 Q. So you offered to let her talk to Representative
10 Geren, but you can't recall if she did talk to
11 Representative Geren?
13 Q. What was the substance of your conversation with
14 Charlie Geren?
15 A. At that time?
16 Q. Uh-huh.
17 A. I was like, "Hey, do you know anything about
18 these rumors they're talking about?" And he said, "No."
19 Q. And --
20 A. Yeah, that was -- yeah, I was like -- he's like
21 no.
22 Q. Any other details?
23 A. Oh, yeah. He offered to talk to her. He said,
24 "I'll talk to her if she wants." And then I offered, I
25 think.
Lexitas
1 Q. So you obviously had Representative Geren's
2 personal cell phone number?
3 A. Yes.
4 Q. Still have it?
5 A. If it hasn't changed.
6 Q. Did you call Representative Geren often during
7 the campaign?
8 A. Only when voters wanted to talk to him or when
9 there was something I couldn't handle.
10 Q. And Charlie Geren obviously knew who you were?
11 A. Yeah.
12 Q. Because you had been out putting up signs
13 together among other things?
14 A. Yes. Excuse me.
15 Q. Are you aware of whether the police had ever been
16 called to the French house as of February 17, 2016?
17 MR. MAXWELL: Instruct you to not answer
18 that question.
21 A. Yes, sir.
22 Q. So you have no knowledge of whether the police
23 have ever visited the French house?
24 MR. MAXWELL: Instruct you to not answer
25 that question.
Lexitas
3 A. Yes, sir.
4 Q. So at the time you were giving assurances to
5 Sheridan French on February 17, 2016, that the Geren
6 campaign was not behind these rumors, you had no knowledge
7 whether the police had ever visited the French house or
8 not?
9 A. Huh-uh. I mean no. I had no knowledge
10 whether -- I don't know who goes to the house.
11 Q. Did you have any reason to believe the police had
12 ever been to the French house?
13 A. I mean, I heard there was rumors of abuse, but
14 they weren't founded by anything.
15 Q. Tell me about those rumors.
16 A. There was rumors that Bo beat his wife.
17 Q. Where did you hear those rumors?
18 A. I think someone from the campaign heard it at the
19 Republican Women's Club.
20 Q. Who from the campaign heard it?
21 A. It would have been Mary.
22 Q. Mary Allen?
23 A. Yes, sir.
24 Q. And who did Mary Allen share those rumors with?
25 A. Like the day after the club meeting, she came to
Lexitas
1 the office and told us about it.
2 Q. When you say "us," who do you mean?
3 A. Laramie. Was that Brian or Chris? I can't
4 remember. And me.
5 Q. So Mary Allen shared rumors with you, Laramie
6 Stroud and either Brian O'Leary or Chris, who's last name
7 we can't remember, that Bo French beat his wife?
8 A. That there were rumors, yes.
9 Q. And did that -- did the campaign team discuss
10 those rumors?
11 A. It was just basically that. Yeah.
12 Q. What was the substance of that discussion?
13 A. I was -- I know I said, "Wow, that's crazy." And
14 that was it. Yeah.
15 Q. Why do you think Ms. Allen thought -- thought it
16 was a good idea to share those rumors with the campaign
17 team?
19 A. I think she was just sharing what she heard.
20 Q. (BY MR. KRATOVIL) Why?
21 A. You'd have to ask her.
22 Q. And the substance of the discussion that you had
23 when she shared those rumors was simply, "Man, that's
24 crazy"?
25 A. Yeah. We had other stuff to do.
Lexitas
1 Q. Did you discuss how to potentially use those
2 rumors for political advantage?
3 A. No.
4 Q. Did you discuss whether to try to confirm those
5 rumors or not?
6 A. No.
7 Q. Did you take any action to follow-up on those
8 rumors?
9 A. I asked -- who did I ask about it? I asked
10 somebody who had been around for a while, like in the
11 community and they're like, yeah, we heard those rumors.
12 That was it.
13 Q. Who did you ask in the community about those
14 rumors?
16 Q. And what was the substance of the rumors?
17 A. Just -- I mean, it was very -- very -- just that.
18 It just sounded like -- it didn't seem like they were
19 founded in anything.
20 Q. So did you personally believe the rumors?
21 A. I didn't know if they were true or not. I mean,
22 I don't know.
23 Q. Did the campaign team ever share these rumors
24 with Representative Geren?
25 A. I did.
Lexitas
1 Q. Tell me about that conversation.
2 A. I said I heard about these rumors. And then he
3 said, "If anyone's getting beat in that household, it's
4 probably Bo."
5 Q. Was that conversation in person or on the phone?
6 A. That was in person.
7 Q. And where was it?
8 A. At the office.
9 Q. At the campaign office?
10 A. Across from Railhead.
11 Q. And how did you bring it up? How did you
12 introduce the topic?
13 A. Just like that.
14 Q. You said, "Representative Geren, I've heard some
15 rumors that Bo French beats his wife"?
16 A. Yeah.
17 Q. Did you provide any additional details?
18 A. I don't have any details.
19 Q. And he came back with a clever quip and that was
20 the end of the conversation?
21 A. Yeah.
22 Q. He didn't say -- you didn't discuss how to use
23 this to the campaign's political advantage?
24 A. No.
25 Q. You didn't discuss maybe we should follow-up on
Lexitas
1 these rumors?
2 A. Huh-uh.
3 Q. You didn't discuss maybe we should notify law
4 enforcement of these rumors?
5 A. Huh-uh.
6 Q. Didn't discuss whether to report these rumors to
7 other authorities?
8 A. No.
9 Q. And that was the end of the conversation he
10 had -- he had a clever remark and that was it?
11 A. Yeah. Then he had to go back over to Railhead.
12 Q. So did the -- did you -- did hear any other
13 rumors, other than the ones Ms. Allen reported to you and
14 the rest of the campaign team?
15 A. That was a recurring rumor I heard just, you
16 know, being out in the community, but other than that, no
17 other rumors.
18 Q. You said you took the rumor to a member of the
19 community who in your phrase had been around for a while.
20 Who was that?
21 A. I don't remember. Some old fart over at -- oh,
22 excuse me. It was some old guy that's always over at
23 Railhead. I don't remember.
24 Q. Why did you share the rumors with the old guy
25 who's always over at Railhead?
Lexitas
1 A. I was just seeing if he heard about it or if he
2 knew it was founded in truth.
3 Q. Why would he know, was he a friend of the
4 Frenches?
5 A. I mean, I -- I don't know. I don't know why I
6 did. I just did.
7 Q. Did you share those rumors with anybody else?
8 A. I'm trying to think. Not that I can think of.
9 Q. So the only people you shared the rumors with
10 were Representative Geren and the -- in your phrase, "old
11 fart over at Railhead"?
12 A. Yeah.
13 Q. Anybody else?
14 A. No, sir, not that I can think of.
15 Q. Do you think it's appropriate to discuss rumors
16 of domestic violence?
18 A. Yes.
19 Q. (BY MR. KRATOVIL) Why?
20 A. I mean, a lot of time rumors are based in fact.
21 Q. Did you take any steps to investigate the truth
22 or falsity of those rumors?
23 A. No.
24 Q. Did anybody affiliated with the Geren campaign
25 take any steps to investigate the truth or falsity of
Lexitas
1 those rumors?
2 A. I wouldn't know that.
3 Q. Did Laramie Stroud take any steps to investigate
4 the truth or falsity of those rumors?
6 Q. Did Mary Allen take any steps to investigate the
7 truth or falsity of those rumors?
8 A. I also wouldn't know that.
9 Q. Did Brian O'Leary take any steps to investigate
10 the truth or falsity of those rumors?
12 Q. So other than sharing with Representative Geren
13 and the old guy at Railhead, you didn't share with anybody
14 else?
15 A. Huh-uh.
16 Q. Did Laramie Stroud those rumors with anybody
17 else?
19 Q. Did Brian O'Leary share those rumors with anybody
20 else?
21 A. I still wouldn't know that.
22 Q. Did Mary Allen share those rumors with anybody
23 else?
25 Q. But she's the one who shared them with your
Lexitas
1 campaign team in the first place?
2 A. Yes.
3 Q. Did Chris, the guy with no last name, share those
4 rumors with anybody else?
5 A. Like I said, it was either him or Brian. I can't
6 remember which.
7 Q. But did he share those rumors with anybody else?
8 A. No. Not that I know of. I don't know.
9 Q. Did Representative Geren share those rumors with
10 anybody else?
12 Q. Who would?
14 A. Who would know?
15 Q. (BY MR. KRATOVIL) Who would know?
16 A. Probably Charlie.
17 Q. Charlie Geren?
18 A. Yeah.
19 (Exhibit 1 was marked.)
20 Q. (BY MR. KRATOVIL) All right. I'm going to hand
21 you what's been marked as Deposition Exhibit 1.
22 MR. KRATOVIL: And, Counsel -- do we have a
23 copy for Steve. And our court reporter has premarked
24 that.
25 Q. (BY MR. KRATOVIL) Go ahead and take a look at
Lexitas
1 that document for me, sir. Exhibit 1.
2 Sir, do you recognize this document from
3 anywhere?
4 A. No.
5 Q. Have you ever seen it before?
6 A. I haven't.
7 Q. I will represent to you that this is a CPS
8 report --
9 A. Okay.
10 Q. -- that was filed on February 26, 2016, against
11 the French family.
12 A. Okay.
13 Q. Do you have any reason to disagree with that?
14 A. No.
15 Q. I'm going to be asking you about this first page.
16 It's a lengthy report. I'm going to be asking you about
17 this first page where it says, "Intake Narrative." Do you
18 see that on the first page?
19 A. Yes.
20 Q. All right. And you'll see it says, "Intake
21 received, February 26, 2016." Do you see that?
22 A. One more time.
23 Q. Under "intake narrative" -- you'll see that it
24 says, "Intake received February 26, 2016."
25 A. Oh, yeah. Yeah. I'm sorry. I was looking
Lexitas
1 someplace else.
2 Q. And it also says where it says stage type FHAB1.
3 So --
4 A. Yeah. P.
5 Q. Yeah, I'm sorry. PHAB1. Do you see that?
6 A. Yes, sir.
7 Q. And you also see a segment that's blacked out
8 here, where it says intake narrative?
9 A. Uh-huh.
10 Q. Do you see that redacted section?
11 A. Oh, is that what that is?
12 Q. Yes, sir. The black spot is a redaction.
13 A. Okay.
14 Q. That black spot would -- does contain the name of
15 the person who made this anonymous phone report.
16 A. Uh-huh.
17 Q. Do you know what's under that black spot?
18 MR. MAXWELL: Objection -- I'm sorry.
19 I'm going to instruct you not to answer.
22 A. Uh-huh.
23 Q. If we were to remove that black spot and we could
24 see the name that phoned in this anonymous report, would
25 that name be David Sorensen?
Lexitas
2 answer.
5 A. Yes, sir.
6 Q. Do you see where it says PHAB1?
7 A. Yes.
8 Q. If I were to represent to you that that's CPS
9 code for an anonymous report, would you have any reason to
10 disagree with me?
11 MR. MAXWELL: I'm going to instruct you not
12 to answer.
15 A. Uh-huh.
16 Q. Is that yes?
17 A. Yes, I am.
18 Q. I'm going to read the first couple of sentences
19 here and there's some code -- under intake narrative,
20 general information description.
21 A. Okay.
22 Q. OV, which is original victim, three-years-old
23 resides with MO, which is mother, FA, father and three SBs
24 which are sibling --
25 A. Okay.
Lexitas
1 Q. -- siblings, age six and younger. Information --
2 information regarding special needs in the home was not
3 obtained. Did I read that correctly?
4 A. That's what it says.
5 Q. Is -- are you aware that in February 2016, Hawk
6 French was three years old?
7 A. I probably knew at the time, but I don't know.
8 Q. The next line reads "2/26/2016."
9 A. Uh-huh.
10 Q. "Recently father was overheard saying that
11 original victim has three broken ribs. Father appeared
12 vague as to how original victim may have obtained injury.
13 Father said something to the effect of, quote, It must be
14 from rough -- must have been from roughhousing, end quote.
15 Father took original victim to see a chiropractor who is
16 family friend. The chiropractor told father that original
17 victim has broken ribs. It, quote, did not appear, end
18 quote, that father planned to seek any additional medical
19 attention for original victim. It is unknown exactly why
20 it is believed that father doesn't plan to seek any
21 additional medical attention for original victim."
22 Does that narrative sound at all familiar?
23 MR. MAXWELL: Don't answer -- I'm sorry.
24 I'm going to instruct you not to answer that question.
Lexitas
2 A. Uh-huh.
3 Q. Respond verbally, sir.
4 A. Yes. I apologize. Yes.
5 Q. You're not going to answer the question?
6 A. I am not.
7 Q. Sir, would you agree with me that that sounds
8 strikingly like the testimony you've just given in this
9 deposition?
10 A. It does sound familiar.
11 Q. It does sound familiar. Where does it sound
12 familiar from?
13 A. From what I just relayed to you.
14 Q. Relayed to me about the conversation you
15 overheard between Bo French and his campaign manager?
17 Q. In fact, it's almost word for word identical?
19 A. Pretty close.
20 Q. (BY MR. KRATOVIL) So you shared this information
21 with CPS?
23 answer that.
Lexitas
1 A. Yes, sir.
2 Q. You're the only person this information could
3 have come from?
5 answer that.
8 A. Yes.
9 Q. Let's continue reading. "Original victim and
10 siblings are not reported to have any suspicious or
11 unexplained injuries prior to original victim's current
12 injuries. There have been rumors heard around town that
13 father is abusive to mother. Additional details were not
14 available. Mother has not been seen with any injuries.
15 Father is running for office of some sort and has had some
16 failed business ventures. Father is under a lot of
17 stress. Additional details regarding the home environment
18 are unknown."
19 Sir, does that information sound familiar?
20 A. Yeah.
21 Q. Where does it sound familiar from?
22 A. From the same, what I just described.
23 Q. So it's very close to the testimony you've just
24 given?
25 A. Yes, sir.
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1 Q. Down to the phraseology, things like "rumors
2 heard around town," very similar to the language you just
3 used.
4 A. It is very similar.
5 Q. Are you the source of this information in this
6 report?
11 A. Yes, sir.
12 Q. "Father is running for office of some sort and
13 has had some failed business ventures." That strikes me
14 as a strange detail to include in an anonymous CPS phone
15 tip; would you agree with me?
17 A. I don't know.
18 Q. (BY MR. KRATOVIL) So somebody phoning in child
19 abuse report is going to mention that the alleged abuser
20 is running for office.
22 to answer that question.
Lexitas
1 Q. "Additional details regarding the home
2 environment are unknown." Did I read that correctly?
3 A. Yes.
4 Q. And you testified earlier you've never been to
5 the French home; is that correct?
6 A. I have not.
7 Q. Have any members of the Geren campaign team been
8 to the French home?
9 A. Yeah. When we were like -- they knocked on his
10 door to try to get his vote.
11 Q. Who knocked on Bo's door or Sheridan's door?
12 A. Oh, shoot. I forgot one other person. Charlie
13 McCaslin, he's another paid -- he was a part-time
14 canvasser for us. He knocked on Bo's door.
15 Q. And was Mr. McCaslin part of the discussion of
16 these alleged rumors of child abuse?
17 A. No, he was at school at the time.
18 Q. What school?
19 A. TCU.
20 Q. So he was just a college kid who you hired to
21 help knock on doors?
22 A. Yes, sir.
23 Q. Was he involved in any of the discussions of the
24 alleged abuse at the French house?
25 A. No. Like I said, he was at school.
Lexitas
1 Q. Was he involved in any of the discussions of the
2 alleged broken ribs that Hawk purportedly suffered?
3 A. No. Not from me any way.
4 Q. Anybody else you've forgotten in terms of a paid
5 Geren campaign team member?
6 A. I think that's it. Sorry about that.
7 Q. So, sir, reading over this intake narrative
8 again -- we've read it in segments. Reading the whole
9 thing, would you agree with me that this is strikingly
10 similar to the testimony you've just given in this case?
13 A. I think I've already agreed to that.
14 Q. You do agree to that?
15 A. I already did.
16 Q. Any idea where this information came from?
22 Q. Also it says, "Father owns several guns. There
23 is rumored domestic violence. There are not any reports
24 of drug or gang affiliations within the home." Did I read
25 that correctly?
Lexitas
1 A. Uh-huh.
2 Q. Were you aware as of February 2016 that Bo French
3 is a gun owner?
4 A. Yeah.
5 Q. So that is a detail that you could have included
6 in this report?
11 A. Yes, sir.
12 Q. Mr. Sorensen, why did you make this report to
13 CPS?
18 A. Yes.
19 Q. Mr. Sorensen, aside from this report, have you
20 ever made any other reports to Child Protective Services?
25 A. Yes, sir.
Lexitas
1 Q. Notwithstanding this case, taking this case and
2 the Frenches and putting it in a separate box, outside of
3 the Frenches, have you ever had any dealings with Texas
4 Child Protective Services?
9 A. Yes, sir.
10 Q. Excluding yourself, are you aware of anyone else
11 affiliated with the Geren 2016 campaign who made a phone
12 call to Child Protective Services regarding Bo and
13 Sheridan French?
18 A. Yes, sir.
19 Q. Did Laramie Stroud call Texas Child Protective
20 Services?
25 A. Yes, sir.
Lexitas
1 Q. Did Brian O'Leary call Texas Child Protective
2 Services?
7 A. Yes, sir.
8 Q. Did Mary Allen call Texas Child Protective
9 Services alleging that Bo and Sheridan French were abusing
10 and neglecting their children?
15 A. Yes, sir.
16 Q. Did Charlie Geren call Texas Child Protective
17 Services and allege that Bo and Sheridan French were
18 abusing or neglecting their children?
22 attorney's advice and refuse to answer my question?
23 A. Yes, sir.
24 MR. KRATOVIL: Steve, I'm just about done.
25 Let me -- let me take a quick break to wind up before we
Lexitas
1 get into the home stretch here.
2 THE VIDEOGRAPHER: Off the record, 11 a.m.
4 THE VIDEOGRAPHER: We're on the record. The
5 time is 11:07.
7 still under oath?
8 A. Yes, sir.
9 Q. Sir, are you aware that you've been sued for
10 defamation by Bo and Sheridan French?
11 A. What does that mean?
12 Q. That's a conversation for you and your attorney
13 to have.
14 A. Okay.
15 Q. Are you aware that there's a claim for defamation
16 against you that's been filed by Bo and Sheridan French?
17 A. Yes.
18 Q. And would you agree with me that in order for Bo
19 and Sheridan French to move forward with their claim for
20 defamation, it's important for them to know whether you
21 made that CPS report or not?
23 to answer that question.
Lexitas
1 A. Yes, sir.
2 Q. You won't even tell me if it's important to my
3 claim?
8 A. Yes, sir.
10 intentional infliction of emotional distress by Bo and
11 Sheridan French?
12 A. Yes.
13 Q. And, sir, would you agree with me that it's
14 important for Bo and Sheridan French in order to move
15 forward with their claim for IIED to know if you made that
16 false CPS report or not?
21 A. Yes.
23 intrusion on seclusion by Bo and Sheridan French?
24 A. I didn't know that -- oh, is it all the -- yes, I
25 guess.
Lexitas
1 Q. You're aware of the claims against you, sir?
2 A. Yes.
3 Q. Would you agree with me that it's important for
4 Bo and Sheridan French to know whether or not you were
5 behind that false CPS report in order to move forward with
6 their claims?
11 A. Yes.
12 Q. And that's true for all of my claims -- all of Bo
13 and Sheridan French's claims against you?
18 A. Yes, sir.
19 Q. Sir, speaking hypothetically with me. If the
20 French family learns the identity of the anonymous tipster
21 who phoned in that CPS report on February 26, 2016, do you
22 have any reason to believe that the life or safety of the
23 French children will be in jeopardy as a result?
Lexitas
3 A. Yes, sir.
4 Q. Sir, do you have any reason to believe that the
5 life or safety of the anonymous tipster will be in
6 jeopardy if the French family learns the identity of that
7 anonymous tipster?
12 A. Yes, sir.
13 Q. Sir, do you have any reason to believe that the
14 life or safety of any other person, who is involved in the
15 CPS report or the CPS investigation of the French family,
16 will be in danger if the French's learn the identity of
17 the anonymous tipster?
22 A. Yes, sir.
23 Q. Sir, are you scared that Bo French will engage in
24 physical violence against you?
25 A. No.
Lexitas
1 Q. Sir, are you afraid that Sheridan French will
2 engage in physical violence against you?
3 A. No.
4 Q. Sir, are you afraid that Mr. O'Hare or myself or
5 anyone working for the Frenches will engage in physical
6 violence against you?
7 A. No.
8 Q. All right. So I'm going to ask you again.
9 Sir, if the Frenches learn the identity of
10 anonymous tipster, do you have reason to believe that
11 anyone's safety or life will be imperiled?
12 MR. MAXWELL: I'm going to instruct you to
13 not answer that question.
16 A. Yes.
17 MR. KRATOVIL: Steve, could I ask you the
18 basis of that instruction, please?
19 MR. MAXWELL: It's me instructing him not to
20 answer it. I think the pattern is pretty clear here, I'm
21 instructing him to not answer any question that will have
22 to do with the confidentiality that the law provides in --
23 with respect to anything involving CPS or law enforcement.
24 MR. KRATOVIL: But, Steve, I've just walked
25 him through the standard that I have to meet --
Lexitas
1 MR. MAXWELL: I understand.
2 MR. KRATOVIL: -- and you're not letting him
3 testify as to the standard that I have to meet in order to
4 get an exception to the rule. So you're not letting me
5 have the substantive information, nor are you letting me
6 have the information that I can use to carve out my
7 exception.
8 MR. MAXWELL: I understand. But the problem
9 is, whether the question is going to require an
10 affirmative response or a negative response, it doesn't
11 matter. The questions have to do with information that is
12 considered to be privileged and confidential. And,
13 frankly, subject to stringent protections. So anything
14 having to do with these kinds of reports, I'm going to
15 instruct him not to answer. So I understand where your
16 coming from --
17 MR. KRATOVIL: And, Counsel, you know there
18 are exceptions to that privilege for fraud, for, you know,
19 intentional falsity. And I need to be able to meet those.
20 MR. MAXWELL: I understand that.
21 MR. KRATOVIL: And you understand that by
22 denying me the ability to ask any questions, you're
23 effectively denying me the ability to carve out my
24 exceptions.
25 MR. MAXWELL: I'm following only what I
Lexitas
1 believe the law to be with respect to the confidentiality
2 afforded to reports to CPS or law enforcement.
3 MR. KRATOVIL: And we had a discussion
4 yesterday with Judge Chupp about Texas Rule of Evidence
5 502. And we talked a lot about 502A, which I understand
6 you to be proceeding under and I respect that, Counsel.
7 Would you agree with me that 502B contains exceptions to
8 502A.
9 MR. MAXWELL: I don't think I'm being
10 deposed today. I'm sorry, Chris.
11 MR. KRATOVIL: I appreciate that, Steve. I
12 think we're going to have to go see Judge Chupp about
13 these numerous unanswered questions.
14 And I would ask you to certify all of the
15 unanswered questions that we have in the record.
16 (Exhibit 2 was marked.)
17 Q. (BY MR. KRATOVIL) All right. Sir, I'm going to
18 share with you what's been marked as Deposition Exhibit 2.
19 And, Counsel, there's a copy for you. There's a copy for
20 you counsel -- or Mr. Sorensen. I'm sorry.
21 Mr. Sorensen, have you ever seen this
22 document before?
23 A. I haven't.
24 Q. Sir, I will represent that this is a affidavit
25 that was given to me by your former colleague, Laramie
Lexitas
1 Stroud, who I understand and you've testified today was
2 the campaign manager for Mr. Geren in 2016. I'd direct
3 you to paragraph six. I'm going to read it to you.
4 A. Okay.
5 Q. "I did not make any report to Child Protective
6 Services or DFPS, which is Department of Family Protective
7 Services, concerning any matter whatsoever related to the
8 French's or their son. I made no report to DFPS
9 concerning any matter described in paragraph 18 of the
10 petition." Did I read that correctly?
11 A. Uh-huh.
12 Q. Sir, did you know that Mr. Stroud had given
13 Mr. French and Mrs. French this affidavit?
14 A. I haven't talked to them, so no.
15 Q. You've never seen this affidavit before?
16 A. No, sir.
17 Q. Would you be willing to give me a similar
18 affidavit?
19 MR. MAXWELL: I'm going to instruct you to
20 not answer that question.
22 your attorney's advice and not answer this question?
24 Q. So, sir, I will represent to you that Mr. Stroud
25 gave the French family this affidavit. And in return they
Lexitas
1 dropped their Rule 202 petition against him. Were you
2 aware of that?
3 A. No, sir.
4 Q. So you're not aware that the Frenches let
5 Mr. Stroud out of this case based on this sworn affidavit?
6 A. Yeah. No, I didn't know about it. I mean, I --
7 yeah, this is the first time I've seen it.
8 Q. Sir, would you be willing to offer a similar
9 sworn affidavit to similarly get out of this case?
10 MR. MAXWELL: I'm going to instruct him not
11 to answer.
13 your attorney's advice and not answer that question.
14 A. Yes, sir.
15 Q. So even if I represented to you that we would let
16 you out of this case in return for a similar affidavit,
17 you wouldn't offer me that affidavit, would you?
19 answer.
23 Q. And you can't offer me that affidavit because you
24 are the person who made this tip to Child Protective
25 Services?
Lexitas
5 A. Yes, sir.
6 Q. And you made that tip to Child Protective
7 Services in an effort to give Charlie Geren's campaign a
8 political advantage?
13 A. Yes.
14 Q. You made this tip to Child Protective Services
15 because you had been working 60 to 70 hours a week for
16 Charlie Geren's 2016 campaign for eight months and you
17 were desperate for him to win?
22 A. Yes.
23 Q. You weaponized CPS, sir?
Lexitas
1 Q. (BY MR. KRATOVIL) You weaponized CPS for
2 political purposes, didn't you, sir?
6 attorney's office advice and not answer that question?
8 MR. KRATOVIL: Steve, we may be done. Let
9 me confer with my co-counsel. Let's go off the record for
10 a moment.
13 THE VIDEOGRAPHER: We're on record. The
14 time is 11:18.
15 Q. (BY MR. KRATOVIL) Sir, I'm going to offer you a
16 hypothetical. If you will go on the record right now,
17 admit that you made the February 26th anonymous call to
18 CPS and apologize to Mr. and Mrs. French right now and
19 admit that you did this to give Charlie Geren a political
20 advantage, we will not nonsuit this case. Is that
21 something you would be interested in doing?
Lexitas
2 Q. Sir, so if we were to let you out of this case,
3 nonsuit it, dismiss it, in return for an admission that
4 you made the call to CPS and a simple apology to Mr. and
5 Mrs. French, you wouldn't take that offer?
7 answer the question. And will note that counsel for the
8 opposing side should not be attempting to enter into an
9 agreement with my client without going through me first,
10 so that's why I'm --
11 MR. KRATOVIL: I'll concede the point,
12 Mr. Maxwell. I asked it as a hypothetical the first time.
13 I will revise that question. The second one was also a
14 hypothetical. Thank you.
15 MR. MAXWELL: And the same instruction will
16 apply to not answer the question.
17 Q. (BY MR. KRATOVIL) Sir, hypothetically you would
18 not simply admit that you made the call and apologize to
19 the French family right here and right now and be done
20 with all of this?
22 answer the question.
Lexitas
1 MR. KRATOVIL: No further questions. Pass
2 the witness.
3 MR. MAXWELL: I do have a follow-up question
4 or two.
5 EXAMINATION
6 BY MR. MAXWELL:
7 Q. Mr. Sorensen, during the course of the deposition
8 and the questions that were being asked of you, some
9 information came out about a conversation or communication
10 that occurred on February 17th of 2016, involving you and
11 Sheridan French. Do you remember that testimony?
12 A. Yes, sir.
13 Q. I just -- I want to ask a couple of follow-up
14 questions.
15 What was the gist of what Sheridan French
16 was either telling you or was telling someone else where
17 you were a part of that conversation?
18 A. That Facebook messages were being sent that law
19 enforcement is repeatedly showing up at the French
20 household.
21 Q. And when you heard that, did that cause you any
22 kind of concern?
23 A. I -- not really. I just wanted them to know that
24 it wasn't coming from -- from us.
25 Q. And I believe you testified that you assured her
Lexitas
1 that it didn't -- that the Geren campaign had nothing to
2 do with that?
3 A. Right.
4 Q. And she didn't believe you?
5 A. No, she didn't.
6 Q. At that point, did you call Charlie Geren to
7 offer -- to have him tell her that there was no
8 involvement of the Geren campaign?
10 Q. Now, after all of that was kind of said and done,
11 did you leave that conversation having any impression at
12 all about what might be going on at the Geren household?
13 A. At the Geren or the --
14 Q. I'm sorry. At the French household.
15 A. I mean, it was -- can you ask the question again?
16 I'm sorry.
17 Q. Yeah. After all that -- that had transpired, the
18 communications or conversations were over, did it leave
19 you with any sense or impression of anything sinister or
20 bad going on at the French household?
21 MR. KRATOVIL: Objection, form.
22 A. I mean, it was puzzling, why would somebody make
23 lies if they were lies about people going -- law
24 enforcement going to the French household?
25 Q. (BY MR. MAXWELL) Was it anything that stayed
Lexitas
1 with you for a period of time after that?
2 A. Yeah, I thought about it.
3 Q. Then according to the questions that were being
4 asked, ten days later on February 27th, there was a
5 conversation between you and Bo French concerning his
6 three-year-old son and some rib injuries or communications
7 which you interpreted as rib injuries; is that correct?
8 A. Yes.
10 Mischaracterizes testimony.
11 Q. (BY MR. MAXWELL) Well, okay. Then to address
12 that. Without going into any detail because it's already
13 been done in the deposition, what was your basic
14 understanding or what was the gist of the conversation
15 between you and Bo French on February 27th that involved
16 his three-year-old son Hawk?
17 MR. KRATOVIL: Objection, form. Asked and
18 answered.
19 A. I'm sorry, one more time.
20 Q. (BY MR. MAXWELL) What was the gist of that
21 conversation?
22 A. Okay.
24 A. It was -- like I said, him and his campaign
25 manager and I were there. And he was talking about how he
Lexitas
1 was a real tough guy because, you know, he had broke his
2 ribs and they didn't know about it for three days. And
3 then from there, they told me -- and that's when I took
4 pause, was like, what happened there. And that's when
5 they talked about, you know, horseplay and then the
6 chiropractor.
7 Q. (BY MR. MAXWELL) Did that conversation viewed in
8 light of the conversation you had had with Sheridan French
9 ten days earlier cause you any pause or any concern about
10 something that may be going on at the French household?
11 MR. KRATOVIL: Objection, form. Leading and
12 calls for speculation.
13 A. It gave me some red flags. You know, everything
14 together from the -- from the rumors to the law
15 enforcement, Facebook messages and then the -- the -- I
16 can't talk. Okay. The broken ribs.
17 MR. MAXWELL: I don't have any further
18 questions. Pass the witness.
19 MR. KRATOVIL: Thank you, Counsel.
20 FURTHER EXAMINATION
21 BY MR. KRATOVIL:
22 Q. Sir, earlier you testified that other than the
23 snippet of conversation you heard between Bo French and
24 his campaign manager regarding Hawk French's purported rib
25 injury, you had no basis to think that any of the French
Lexitas
1 children were being physically abused. Do you remember
2 that testimony?
3 A. I do.
4 Q. Do you stand by that testimony?
5 A. Yes.
6 MR. KRATOVIL: No further questions.
7 MR. MAXWELL: I'll reserve the rest of my
8 questions.
9 MR. KRATOVIL: As will I.
11 (Deposition was concluded at 11:24 a.m.)
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1 CHANGES AND SIGNATURE
2 PAGE LINE CHANGE REASON
3 __________________________________________________________
4 __________________________________________________________
5 __________________________________________________________
6 __________________________________________________________
7 __________________________________________________________
8 __________________________________________________________
9 __________________________________________________________
10 __________________________________________________________
11 __________________________________________________________
12 __________________________________________________________
13 __________________________________________________________
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21 __________________________________________________________
22 __________________________________________________________
23 __________________________________________________________
24 __________________________________________________________
25 __________________________________________________________
Lexitas
1 I, DAVID SORENSEN, have read the foregoing deposition
2 and hereby affix my signature that same is true and
3 correct, except as noted above.
7 _____________________________
DAVID SORENSEN
8
10 THE STATE OF )
11 COUNTY OF )
12
13 Before me, _______________, on this day
14 personally appeared DAVID SORENSEN, known to me (or proved
15 to me under oath or through ___________________) to be the
16 person whose name is subscribed to the foregoing
17 instrument and acknowledged to me that they executed the
18 same for the purposes and consideration therein expressed.
19 Given under my hand and seal of office this
20 day of ___________________, ______.
21
22 _____________________________
NOTARY PUBLIC IN AND FOR
23 THE STATE OF
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1 CAUSE NO. 141296646-17
2 RICHARD WEST BO FRENCH, AND § IN THE DISTRICT COURT

SHERIDAN FRENCH, §
3 §
Plaintiffs, §
4 §
VS. § 141st JUDICIAL DISTRICT
5 §
DAVID T. SORENSEN §
6 §
Defendant. § TARRANT COUNTY, TEXAS
7
8 REPORTER'S CERTIFICATION
ORAL AND VIDEOTAPED DEPOSITION OF DAVID SORENSEN
9 FEBRUARY 23, 2018
10 I, Melisa Duncan, Certified Shorthand Reporter in
11 and for the State of Texas, hereby certify to the
12 following:
13 That the witness, DAVID SORENSEN, was duly sworn
14 by the officer and that the transcript of the oral
15 deposition is a true record of the testimony given by the
16 witness;
17 That the deposition transcript was submitted on
18 the _____________________to the witness or to the attorney
19 for the witness for examination, signature and return to
20 me by _______________________;
21 That the amount of time used by each party at the
22 deposition is as follows:
23 Christopher Kratovil - 1 hour; 50 minutes,
24 Steve Maxwell - 4 minutes.
25 That pursuant to information given to the
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1 deposition officer at the time said testimony was taken,
2 the following includes counsel for all parties of record:
3 FOR THE PLAINTIFF(S):
4 Christopher D. Kratovil
DYKEMA COX SMITH
5 1717 Main Street, Suite 4200
Dallas, Texas 75201
6 214.462.6458
ckratovil@dykema.com
7
8 Tim O'Hare
THE LAW OFFICES OF TIM O'HARE
9 1038 Elm Street
Carrollton, Texas 75006
10 972.960.0000
attorney@oharelawfirm.com
11
12 FOR THE DEFENDANT:
13 Steve Maxwell
Bailey & Galyen
14 1300 Summit Avenue, Suite 650
Fort Worth, Texas 76102
15 817.276.6000
smaxwell@galyen.com
16
17 Matthew Pillado
Artemio Fernandez
18 MATTHEW PILLADO, PLLC
235 NE Loop 820, Suite 103
19 Hurst, Texas 76053
msp@matthewpillado.com
20 af@matthewpillado.com
21 I further certify that I am neither counsel for,
22 related to, nor employed by any of the parties or
23 attorneys in the action in which this proceeding was
24 taken, and further that I am not financially or otherwise
25 interested in the outcome of the action.
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1 Further certification requirements pursuant to
2 Rule 203 of TRCP will be certified to after they have
3 occurred.
4 Certified to by me this 26th day of February 2018.
9 ________________________________
MELISA DUNCAN, Texas CSR 6135
10 Expiration Date: 12/31/19
Firm Registration No. 459
11 Lexitas - Dallas
6500 Greenville, Suite 445
12 Dallas, Texas 75206
214.373.4977
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1 FURTHER CERTIFICATION UNDER RULE 203 TRCP
2 The original deposition was/was not returned to
3 the deposition officer on _______________________;
4 If returned, the attached Changes and Signature
5 page contains any changes and the reasons therefor;
6 If returned, the original deposition was
7 delivered to ________________, Custodial Attorney;
8 That $_______ is the deposition officer's charges
9 to the Plaintiffs for preparing the original deposition
10 transcript and any copies of exhibits;
11 That the deposition was delivered in accordance
12 with Rule 203.3, and that a copy of this certificate was
13 served on all parties shown herein on and filed with the
14 Clerk.
15 Certified to by me this __________ day of
16 ___________________, ________.
17
18
19
20 ________________________________
MELISA DUNCAN, Texas CSR 6135
21 Expiration Date: 12/31/19
Firm Registration No. 459
22 Lexitas - Dallas
6500 Greenville, Suite 445
23 Dallas, Texas 75206
214.373.4977
24
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Lexitas

Deposition of David Sorensen in False CPS Report

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Deposition of David Sorensen in False CPS Report

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David T.

1 CAUSE NO. 141296646-17

2 RICHARD WEST BO FRENCH, AND § IN THE DISTRICT COURT

9 ORAL AND VIDEOTAPED DEPOSITION OF

11 FEBRUARY 23, 2018

15 ORAL AND VIDEOTAPED DEPOSITION of DAVID SORENSEN,

16 produced as a witness at the instance of the Plaintiffs

17 and duly sworn, was taken in the above-styled and

18 -numbered cause on the 23rd of February, 2018, from

19 9:06 a.m. to 11:24 a.m., before Melisa Duncan, CSR in and

20 for the State of Texas, reported by machine shorthand, at

21 the offices of Matthew Pillado, PLLC, 235 NE Loop 820,

22 Hurst, Texas, pursuant to the Rules of Civil Procedure and

23 the provisions stated on the record or attached hereto.

2 FOR THE PLAINTIFF(S):

11 FOR THE DEFENDANT:

22 Luis Acevedo - Videographer

5 Examination by Mr. Kratovil . . . . . . . . . . . 7

6 Examination by Mr. Maxwell. . . . . . . . . . . . 109

7 Further Examination by Mr. Kratovil . . . . . . . 112

8 Signature and Changes . . . . . . . . . . . . . . . . 114

9 Reporter's Certificate. . . . . . . . . . . . . . . . 116

10 REPORTER'S NOTE: Quotation marks are used for clarity

11 and do not necessarily reflect a direct quote.

13 NO. DESCRIPTION PAGE

1 CERTIFIED QUESTIONS (Continued)

1 CERTIFIED QUESTIONS (Continued)

1 CERTIFIED QUESTIONS (Continued)

2 THE VIDEOGRAPHER: We're on the record for

3 the deposition of David T. Sorensen. The time is

4 9:06 a.m. on February 23, 2018.

5 If the court reporter can administer the

8 having been first duly sworn, testified as follows:

11 Q. Good morning, sir. Could you please state your

12 full legal name for the record.

13 A. David Thomas Sorensen.

14 Q. And, Mr. Sorensen, could you please give me your

16 A. 2718 Meadow Creek Drive, Missouri City, Texas

18 Q. Mr. Sorensen, what is your current phone number?

20 Q. Is that a mobile phone, sir?

22 Q. And who is your mobile phone carrier?

24 Q. And is that the same number you had during the

25 time relevant to this lawsuit, which I'll represent to you

3 Q. Do you recall your phone number as of February

6 Q. Different phone number, same phone number?

7 A. I really have to think. I don't know.

9 A. No, it would be a different one.

10 Q. And you don't recall that number?

11 A. Not right off the top of my head, no.

12 Q. Was AT&T your carrier in February 2016?

13 A. That, I don't know.

14 Q. You don't recall your carrier in --

17 Sir, what are your email addresses that you

20 Q. Any other email addresses that you regularly use?

21 A. That's basically it -- oh, no.

23 Q. And did you use either of those emails as of

25 A. The first one.

1 Q. And the second one?

3 Q. Did you have any other email addresses that you

4 used regularly as of February 2016?

5 A. Let me think. Not that I can recall.

6 Q. What about social media accounts, sir, do you

7 maintain any social media accounts?