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- 1
- 1 TWENTY-FOURTH JUDICIAL DISTRICT COURT
- 2 PARISH OF JEFFERSON
- 3 STATE OF LOUISIANA
- 4
- 5
- 6 FRANCIENNE SIMMONS, MARIA
- DELOACH, VANESSA SMITH, ET AL
- 7
- 8 NO. 714-616
- 9
- 10 VERSUS
- 11 DIVISION "P"
- 12
- 13 RICKEEM JACKSON AND
- JOHN GEGENHEIMER
- 14
- 15
- 16 MOTION HEARING HELD BEFORE THE HONORABLE
- JUDGE LEE V. FAULKNER, JR. ON AUGUST 29TH, 2014.
- 17
- 18 APPEARANCES:
- 19 RON WILSON, ESQUIRE
- 20 Representing Francienne Simmons, Et Al
- 21
- 22 DEBORAH VILLIO, ESQUIRE
- 23 Representing Rickeem Jackson
- 24
- 25 KATHY TORREGANO, ESQUIRE
- 26 Representing John Gegenheimer, Clerk of Court
- 27
- 28
- 29 REPORTED BY: BRIAN P. SALZER
- CERTIFIED COURT REPORTER
- 30
- 31
- 32
- 2
- 1 I N D E X
- 2 WITNESS PAGE
- 3 RICKEEM JACKSON
- 4 EXAMINATION BY
- 5 MR. WILSON 5, 37
- 6 MR. VILLIO 28
- 7
- 8 FRANCIENNE SIMMONS
- 9 EXAMINATION BY
- 10 MR. WILSON 42
- 11
- 12
- 13
- 14 E X H I B I T S
- 15 EXHIBIT P-1 27
- 16
- 17 EXHIBIT D-1 31
- 18 EXHIBIT D-2 31
- 19 EXHIBIT D-3 32
- 20 EXHIBIT D-4 36
- 21 EXHIBIT D-5 37
- 22
- 23
- 24
- 25
- 26
- 27
- 28
- 29
- 30
- 31
- 32
- 3
- 1 P R O C E E D I N G S
- 2 THE COURT:
- 3 All right, this is 714-616,
- 4 Francienne Simmons, Et Al versus Rickeem Jackson and
- 5 John Gegenheimer, Clerk of Court for the
- 6 Twenty-Fourth Judicial District Court.
- 09:01:14 7 MR. WILSON:
- 09:01:14 8 Good morning, Your Honor. Ron
- 9 Wilson representing the plaintiffs in this matter.
- 09:01:24 10 MS. VILLIO:
- 09:01:24 11 Good morning, Your Honor.
- 12 Deborah Villio representing Mr. Jackson.
- 09:01:28 13 THE COURT:
- 09:01:28 14 All right. Good morning.
- 15 Counsel, if you'll come up momentarily.
- 09:02:00 16 (Bench conference off the record.)
- 09:02:00 17 THE COURT:
- 09:02:00 18 The Court will be in recess.
- 19 (Whereupon, a recess was taken.)
- 09:02:01 20 THE COURT:
- 09:02:01 21 Remain seated. Ready to
- 22 proceed?
- 09:02:01 23 MR. WILSON:
- 09:02:01 24 Your Honor, Ron Wilson, attorney
- 25 for Francienne Simmons, et al. I'm ready to
- 26 proceed.
- 09:02:01 27 MS. VILLIO:
- 09:02:01 28 Your Honor, Deborah representing
- 29 Rickeem Jackson, and I am ready to proceed as well.
- 30 Mr. Jackson, to my knowledge, was not served with
- 31 the paperwork for today, but we waive service and
- 32 are ready to proceed.
- 4
- 09:29:28 1 THE COURT:
- 09:29:28 2 Thank you.
- 09:29:28 3 MS. TORREGANO:
- 09:29:29 4 Good morning, Your Honor. Kathy
- 5 Torregano representing John Gegenheimer, Clerk of
- 6 Court. We are ready.
- 09:29:35 7 THE COURT:
- 09:29:35 8 All right. Thank you.
- 09:29:29 9 MR. WILSON:
- 09:29:36 10 Your Honor, pursuant to the law
- 11 and the Clerk of Court is the agent for service of
- 12 process for Mr. Jackson.
- 09:29:43 13 THE COURT:
- 09:29:43 14 Correct.
- 09:29:47 15 MR. WILSON:
- 09:29:47 16 Your Honor, may I ask for
- 17 sequestration of witnesses?
- 09:29:51 18 THE COURT:
- 09:29:51 19 All right. Any witnesses who
- 20 are expected to testify in this matter, please step
- 21 out. All right, thank you.
- 09:30:06 22 MR. WILSON:
- 09:30:15 23 Your Honor, at this time, I'd
- 24 like to call the defendant, Rickeem Jackson, to the
- 25 witness stand.
- 09:30:22 26 THE COURT:
- 09:30:24 27 Mr. Jackson, if you'll come up,
- 28 sir. Raise your right hand and be sworn, please.
- 29 Raise your right hand, sir.
- 09:30:40 30 RICKEEM JACKSON, after having been first
- 31 duly sworn by the minute clerk, testified as
- 32 follows:
- 5
- 09:30:40 1 MINUTE CLERK:
- 2 Please be seated. State your
- 3 name and address for the record. You may have a
- 4 seat.
- 09:30:44 5 THE WITNESS:
- 09:30:45 6 My name is Rickeem Jackson. My
- 7 address is 2241 Brighton Place, Harvey, Louisiana.
- 09:30:54 8 THE COURT:
- 09:30:54 9 Counsel, let me see you all at
- 10 the bench for one moment.
- 09:30:59 11 (Bench conference off the record.)
- 09:30:59 12 THE COURT:
- 09:30:59 13 Counsel, you may proceed.
- 09:31:33 14 EXAMINATION BY MR. WILSON:
- 09:31:33 15 Q Good morning, Mr. Jackson. My name is Ron
- 16 Wilson. I'm an attorney for Ms. Simmons in this
- 17 case. You're familiar with the nature of these
- 18 proceedings while we're here, aren't you?
- 09:31:44 19 A Yes, sir.
- 09:31:44 20 Q And we're here because your residency is
- 21 being challenged --
- 09:31:48 22 A Yes, sir.
- 09:31:49 23 Q -- or your qualifications to run for
- 24 office.
- 09:31:53 25 A Yes, sir.
- 09:31:53 26 Q Is that right? I don't know you,
- 27 Mr. Simmons (sic). You don't know -- I'm sorry,
- 28 Mr. Jackson. You don't know me; so I'd like to get
- 29 to know a little bit about you right now, take a
- 30 couple of minutes out, find out who you are. My
- 31 understanding is that you're the son of Rickey
- 32 Jackson, correct?
- 6
- 09:32:08 1 A Yes, sir.
- 09:32:08 2 Q And correct me if I'm wrong: You grew up
- 3 in Florida?
- 09:32:13 4 A Incorrect. I went to high school in
- 5 Florida.
- 09:32:16 6 Q Okay. Explain that to me.
- 09:32:22 7 A What do you mean?
- 09:32:25 8 MS. VILLIO:
- 09:32:25 9 Judge, I would object. If
- 10 there's a question he wants ask the witness. But
- 11 I'm not sure what he's asking him at this time.
- 09:32:33 12 THE COURT:
- 09:32:33 13 Counsel, if you'll just
- 14 clarify --
- 09:32:35 15 EXAMINATION BY MR. WILSON:
- 09:32:35 16 Q I'll rephrase that: You said you went to
- 17 high school. Tell me -- I'll start off where did
- 18 you go to elementary school?
- 09:32:43 19 MS. VILLIO:
- 09:32:44 20 Objection to relevance.
- 09:32:46 21 THE COURT:
- 09:32:48 22 Counsel.
- 09:32:48 23 EXAMINATION BY MR. WILSON:
- 09:32:48 24 Q Where did you go to elementary school?
- 09:32:49 25 THE COURT:
- 09:32:49 26 Counsel, I was asking you to
- 27 respond to her objection.
- 09:32:53 28 MS. VILLIO:
- 09:32:53 29 Objection to relevance, Your
- 30 Honor.
- 09:32:53 31 THE COURT:
- 09:32:53 32 Objection to what?
- 7
- 09:32:53 1 MS. VILLIO:
- 09:32:53 2 The requirement is a two-year
- 3 Louisiana State residency. And --
- 09:32:56 4 MR. WILSON:
- 09:32:56 5 Your Honor, I'm trying to figure
- 6 out -- the individual has indicated that he went to
- 7 school in Florida. And I'm just trying to find out
- 8 if his entire life he went to school in Florida and
- 9 lived here, or lived and went to school in Florida,
- 10 or what. I'm just trying to get --
- 09:33:12 11 THE COURT:
- 09:33:13 12 I'll overrule the objection,
- 13 Counsel.
- 09:33:14 14 MS. VILLIO:
- 09:33:14 15 Thank you, Judge.
- 09:33:14 16 EXAMINATION BY MR. WILSON:
- 09:33:14 17 Q Where did you go to elementary school?
- 09:33:19 18 A I went to elementary school at a number of
- 19 places. I went to --
- 09:33:23 20 Q What city?
- 09:33:24 21 A Georgia, actually.
- 09:33:26 22 Q Okay, Georgia. Where did you go to junior
- 23 high school?
- 09:33:30 24 A Junior high school, I moved from Georgia
- 25 to Florida my last two years of grade school or
- 26 junior high.
- 09:33:41 27 Q Let me ask --
- 09:33:41 28 A Seventh and eighth grade.
- 09:33:46 29 Q When you were in -- at that point in time
- 30 when you were in school in Georgia seventh and
- 31 eighth grade, were you living with one parent or
- 32 both parents?
- 8
- 09:33:55 1 A I was living with one parent.
- 09:33:58 2 Q And that would have-- if my understanding
- 3 is correct, that would have been your mother,
- 4 correct?
- 09:34:12 5 A Correct.
- 09:34:16 6 Q And so let's now get to high school. I
- 7 think my understanding of things is that you went to
- 8 a high school, Ocoee?
- 09:34:30 9 A Ocoee, yes.
- 09:34:30 10 Q Ocoee?
- 09:34:32 11 A Yes.
- 09:34:32 12 Q And that's in Florida as well, correct?
- 09:34:34 13 A Yes.
- 09:34:35 14 Q And at the time that you were in high
- 15 school, at Ocoee High School in Florida, again, you
- 16 were living with your mother, correct?
- 09:34:42 17 A That's incorrect and correct at the same
- 18 time. I fluctuated between my dad and my mother. I
- 19 went to Pahokee High School. I went to Ocoee High
- 20 School. I went to two different high schools.
- 09:34:54 21 Q Let me ask --
- 09:34:54 22 A My dad lived in Florida when I was in high
- 23 school.
- 09:34:58 24 Q Let me ask you -- let me ask you this:
- 25 Oh, okay. So at the time you lived with your father
- 26 when you were in high school, it was not Louisiana.
- 27 It was Florida.
- 09:35:07 28 A Excuse me?
- 09:35:08 29 Q The time that you, when you went to high
- 30 school, you said you fluctuated between both
- 31 parents, correct?
- 09:35:13 32 A Right, right.
- 9
- 09:35:14 1 Q And when you were fluctuating between both
- 2 parents, you weren't fluctuating between Jefferson
- 3 and Florida; it was in Florida?
- 09:35:23 4 A The early years of high school, yes.
- 09:35:26 5 Q Let's just talk about your senior year at
- 6 Ocoee. Your senior year at Ocoee, what was that
- 7 year?
- 09:35:39 8 A 2008, 2009.
- 09:35:42 9 Q Okay. And in 2008, 2009, were you in with
- 10 one parent or both parents?
- 09:35:48 11 A I was living with one parent.
- 09:35:49 12 Q And that one parent you were living with
- 13 was in Orlando, Florida?
- 09:35:53 14 A Yes.
- 09:35:54 15 Q So we're on the same page?
- 09:35:55 16 A Yes.
- 09:35:56 17 Q Okay. Now my understanding is that you
- 18 played football, correct?
- 09:36:01 19 A Correct.
- 09:36:02 20 Q And coming out of high school, it's my
- 21 understanding that you attended a junior college.
- 09:36:09 22 A That's correct.
- 09:36:10 23 Q And it was a junior college in California?
- 09:36:12 24 A That's correct.
- 09:36:14 25 Q And when you were -- when you were
- 26 attending that junior college in California, is it
- 27 correct to say you were living in California?
- 09:36:23 28 A That is incorrect. I moved with my father
- 29 when I graduated from high school.
- 09:36:27 30 Q Oh, okay. Do you have with you today
- 31 documentation showing that you were living with your
- 32 father in 2009 I guess it is?
- 10
- 09:36:36 1 A (No response.)
- 09:36:36 2 Q Excuse me, sir. Do you have anything, any
- 3 documentation? Look at me. You don't have to look
- 4 at your Counsel.
- 09:36:43 5 A Yeah.
- 09:36:43 6 MS. VILLIO:
- 09:36:44 7 Objection, Judge. The attorney
- 8 is going to be argumentative with the witness.
- 09:36:49 9 MR. WILSON:
- 09:36:49 10 Your Honor, I'm not being
- 11 argumentative.
- 09:36:51 12 THE COURT:
- 09:36:51 13 All right. Sir, do you have any
- 14 documentation with you? Do you understand the
- 15 question that he's asking you?
- 09:36:54 16 THE WITNESS:
- 09:36:55 17 Yes, from 2009, do I -- I don't
- 18 have documentation, no.
- 09:36:59 19 EXAMINATION BY MR. WILSON:
- 09:37:00 20 Q Okay. Let me ask you this so I can
- 21 just -- my understanding is that you played football
- 22 one year at, in junior college.
- 09:37:10 23 A Yes.
- 09:37:14 24 Q And your mother, by the way, is Norma
- 25 Williams?
- 09:37:18 26 A Correct.
- 09:37:20 27 Q Okay. And after your one year, what year
- 28 did you attend junior college?
- 09:37:25 29 A After I graduated from high school, I
- 30 attended junior college 2009-2010, 2010-2011.
- 09:37:37 31 Q Okay. So in 2011 you were living in
- 32 California, correct, at a junior college?
- 11
- 09:37:46 1 A I wasn't living there. But I was going to
- 2 school there, yes. I don't consider it -- I
- 3 consider it going to school away from home.
- 09:37:53 4 Q Let me ask you this: How old -- when did
- 5 you turn eighteen?
- 09:37:57 6 A When did I turn eighteen?
- 09:38:00 7 Q Yes.
- 09:38:01 8 A I'm twenty-five now; so --
- 09:38:02 9 Q You said seven years ago, correct?
- 09:38:05 10 A Correct.
- 09:38:06 11 Q Okay. Let's do this year, one year at a
- 12 time: After the age of eighteen, were you
- 13 registered to vote?
- 09:38:18 14 A I honestly don't remember.
- 09:38:20 15 Q At age nineteen, were you registered to
- 16 vote?
- 09:38:23 17 A I honestly don't remember.
- 09:38:25 18 Q At age twenty, were you registered to
- 19 vote?
- 09:38:28 20 A Eventually, I was registered to vote. But
- 21 I'm not particularly sure which year it was.
- 09:38:35 22 Q Let's take -- okay. So and I need you to
- 23 go a year at a time.
- 09:38:39 24 A Right.
- 09:38:40 25 Q Were you registered to vote at age twenty?
- 09:38:44 26 A I'm not sure.
- 09:38:45 27 Q Were you registered to vote at age
- 28 twenty-one?
- 09:38:47 29 A I'm not sure when I was registered to
- 30 vote, period.
- 09:38:52 31 Q Let me ask you this: Did you -- did you
- 32 vote in the 2008 presidential election?
- 12
- 09:39:01 1 A There's a possibility. If it was, it was
- 2 an absentee ballot. I wasn't there. I think I
- 3 understand where you're getting at with this: But
- 4 it wasn't an actual me voting at the stand. It
- 5 was -- it was if there was a vote done on my behalf,
- 6 it wasn't under my authorization.
- 09:39:24 7 Q Well, who can vote on your behalf?
- 09:39:27 8 A A lot of people have your information,
- 9 have, you know, your records. It's not that hard to
- 10 send in an absentee ballot vote for anyone that's
- 11 familiar with the voting process.
- 09:39:39 12 Q But I think you've already testified that
- 13 you weren't registered to vote in 2008, correct?
- 09:39:43 14 MS. VILLIO:
- 09:39:43 15 Objection, Your Honor.
- 09:39:42 16 THE WITNESS:
- 09:39:43 17 I said I wasn't sure, period.
- 09:39:43 18 MS. VILLIO:
- 09:39:45 19 That's not the witness'
- 20 testimony.
- 09:39:49 21 THE COURT:
- 09:39:51 22 Counsel, he said he doesn't know
- 23 when he was registered to vote.
- 09:39:57 24 THE WITNESS:
- 09:39:57 25 Thank you.
- 09:39:57 26 EXAMINATION BY MR. WILSON:
- 09:39:57 27 Q Okay. So tell me -- by the way, at age
- 28 eighteen, did you have a driver's license?
- 09:40:02 29 A Yes.
- 09:40:04 30 Q And your driver's license was issued by
- 31 which State?
- 09:40:07 32 A Florida.
- 13
- 09:40:10 1 Q At age nineteen, your driver's license --
- 09:40:14 2 A Correct.
- 09:40:14 3 Q -- at Florida?
- 09:40:16 4 A Correct.
- 09:40:17 5 Q Age twenty?
- 09:40:21 6 A Correct.
- 09:40:24 7 Q And let me ask you this, if I can just
- 8 skip all of this: Do you have your driver's license
- 9 with you today? Do you have your driver's license
- 10 today, sir?
- 09:40:36 11 A Do I have my driver's license with me?
- 12 Yes.
- 09:40:39 13 Q Yes, one of these (indicating). Do you
- 14 have one of these with you today?
- 09:40:42 15 A Yes, I do.
- 09:40:43 16 Q Look at it for me. Do you have it?
- 09:41:00 17 A (Witness viewing license) Yes.
- 09:41:02 18 Q Now at the very bottom, it says -- and I
- 19 could be wrong about a lot of these things. But at
- 20 the bottom it says, "Issue Date," doesn't it?
- 09:41:12 21 A Yes.
- 09:41:13 22 Q I don't want you to tell me the date. I
- 23 have somewhere that the issue date of your driver's
- 24 license is August 19th, 2013, correct?
- 09:41:25 25 A Correct.
- 09:41:27 26 Q So the first driver's license that you had
- 27 issued by the State of Louisiana was August 19th,
- 28 2013, correct?
- 09:41:35 29 A Correct.
- 09:41:36 30 Q Okay. Now we were talking a few seconds
- 31 ago about voting. And you don't know when, exactly
- 32 when you first registered to vote, correct?
- 14
- 09:41:56 1 A Correct.
- 09:41:56 2 Q And let me ask you this: Did you ever
- 3 register to vote in any place outside of Louisiana?
- 09:42:07 4 A I'm not -- I'll go back to the question:
- 5 I wasn't sure when I registered to vote; so I
- 6 couldn't answer that.
- 09:42:13 7 Q That's not the question. I'm not asking
- 8 you when. My only question is were you ever
- 9 registered to vote anyplace outside of Louisiana?
- 09:42:20 10 A I'm not sure.
- 09:42:23 11 Q How old are you, sir?
- 09:42:23 12 A Twenty-five.
- 09:42:24 13 Q And you cannot tell the Court today
- 14 whether or not you were ever registered to vote
- 15 anyplace outside of Louisiana?
- 09:42:30 16 MS. VILLIO:
- 09:42:30 17 Objection, asked and answered.
- 09:42:31 18 MR. WILSON:
- 09:42:31 19 Your Honor --
- 09:42:31 20 THE COURT:
- 09:42:31 21 Sustained, sustained. He's
- 22 already told me, told you he doesn't know.
- 09:42:37 23 EXAMINATION BY MR. WILSON:
- 09:42:37 24 Q Let me tell you what I think I know: And
- 25 I want you to correct me if I'm wrong. And by the
- 26 way, on your driver's license, look at it again for
- 27 me: I think you have an address of 2744 Hyde Park.
- 09:42:55 28 A (Witness viewing license) Correct.
- 09:42:58 29 Q Okay. Now within the past year, how many
- 30 different addresses have you used?
- 09:43:15 31 A What do you mean by used?
- 09:43:17 32 Q And let me help you: Is 2744 Hyde Park
- 15
- 1 and address that you used?
- 09:43:23 2 A Yes.
- 09:43:23 3 Q Is 2241 Brighton Place an address that you
- 4 used?
- 09:43:27 5 A Yes.
- 09:43:27 6 Q Is 3701 Lake Catherine Boulevard an
- 7 address that you used?
- 09:43:32 8 A Yes.
- 09:43:32 9 Q Okay. So within the past two years,
- 10 you've used about three different addresses,
- 11 correct?
- 09:43:39 12 A Correct.
- 09:43:40 13 Q Okay. Now we've already established that
- 14 you don't know when you first registered to vote
- 15 outside of Louisiana, correct?
- 09:43:47 16 A Correct.
- 09:43:53 17 Q Okay. Help me with that.
- 09:43:55 18 THE COURT:
- 09:43:55 19 Mr. Jackson, if you'll just push
- 20 back from that microphone just a little bit.
- 09:43:58 21 (Witness complies.)
- 09:43:58 22 THE COURT:
- 09:43:58 23 Thank you.
- 09:43:59 24 EXAMINATION BY MR. WILSON:
- 09:43:59 25 Q You are, in fact, now registered to vote
- 26 in Louisiana, correct?
- 09:44:02 27 A Correct.
- 09:44:03 28 Q And you have never, ever voted in an
- 29 election in Louisiana, correct?
- 09:44:09 30 A Correct.
- 09:44:10 31 Q As a matter of fact, you have not been
- 32 registered to vote in Louisiana for months yet, have
- 16
- 1 you, correct?
- 09:44:17 2 A I'll say that's correct. I'd say that's
- 3 about right.
- 09:44:20 4 Q And, as a matter of fact, you didn't
- 5 register to vote in Louisiana until August the 13th,
- 6 2014.
- 09:44:26 7 A Correct.
- 09:44:28 8 Q Okay. So as far as documented evidence is
- 9 concerned, we know that your first driver's license
- 10 in Louisiana is August 19th, 2013.
- 09:44:39 11 MS. VILLIO:
- 09:44:39 12 Objection. Is that a question?
- 13 If it is, it's asked and answered.
- 09:44:47 14 THE COURT:
- 09:44:47 15 Sustained.
- 09:44:47 16 EXAMINATION BY MR. WILSON:
- 09:44:48 17 Q The documentation that you have right now,
- 18 as far as establishing your presence in Louisiana,
- 19 the documentation that you have with you now is your
- 20 driver's license, 2013?
- 09:45:03 21 A Is that a question or a statement?
- 09:45:05 22 Q Yes, question.
- 09:45:06 23 A You mean that I brought with me today?
- 09:45:08 24 Q Yes, uh-huh.
- 09:45:09 25 A I have more documentation than just a
- 26 driver's license.
- 09:45:14 27 Q Okay. Now, as a matter of fact, you
- 28 were -- the year, 2012, you played football at
- 29 Robert Morris, correct?
- 09:45:27 30 A Yes, sir.
- 09:45:31 31 Q And the school -- let me show you a
- 32 document, and tell me if you've seen this document
- 17
- 1 before. Are you familiar with that document?
- 09:45:49 2 A (Witness viewing document.)
- 09:45:49 3 Q First of all, do you recognize the
- 4 individual in the document?
- 09:45:52 5 A Absolutely. It's a nice looking young
- 6 man. It's a nice looking young man on the picture,
- 7 me.
- 09:46:01 8 Q Nice looking young man?
- 09:46:02 9 A Oh, yeah.
- 09:46:03 10 Q Is that what you believe, or is that what
- 11 you've been told?
- 09:46:06 12 A Both.
- 09:46:09 13 Q I envy you. No one has ever told me that.
- 14 Okay, now this nice looking young man here is Riheem
- 15 (phonetic) Jackson; that's you.
- 09:46:25 16 A Wrong do you get the "H" from?
- 09:46:27 17 Q Excuse me, Rickeem.
- 09:46:29 18 A Thank you.
- 09:46:29 19 Q And it says that the year, 2012, that's at
- 20 Robert Morris University, football, correct?
- 09:46:35 21 A Correct.
- 09:46:36 22 Q And it says class, senior, correct?
- 09:46:39 23 A Correct.
- 09:46:39 24 Q And it lists hometown, Orlando, Florida.
- 09:46:43 25 A Well, that's the high school hometown that
- 26 I went to. That's every player whatever high school
- 27 you went to is going to have that hometown; that's
- 28 where you played high school ball.
- 09:46:52 29 Q But you didn't -- you didn't tell them to
- 30 correct this, did you?
- 09:46:55 31 A Excuse me?
- 09:46:56 32 Q That is correct, right? Your hometown
- 18
- 1 that's listed on here is Orlando, Florida?
- 09:46:59 2 A Correct. That's what high school I went
- 3 to my senior year; that's every player.
- 09:47:05 4 Q Okay. Now --
- 09:47:06 5 A When I went to high school in 2008 -- I
- 6 played at Robert Morris in 2012, a three-year
- 7 difference, you know. That just goes to show the
- 8 legitimacy of it. They just showed -- they just put
- 9 the hometown of the high school you went to your
- 10 last year.
- 09:47:24 11 Q Now what happened at -- did you play
- 12 football for Robert Morris in 2013?
- 09:47:29 13 A Did I play football? No, I did not.
- 09:47:33 14 Q Okay. And Robert Morris is located in
- 15 Pennsylvania, correct?
- 09:47:36 16 A That's correct.
- 09:47:36 17 Q Okay. And did you complete your studies
- 18 at Robert Morris?
- 09:47:42 19 A Absolutely.
- 09:47:43 20 Q What year?
- 09:47:43 21 A May of 2013.
- 09:47:46 22 Q So in May of 2013, you were a student at
- 23 Robert Morris University in Pennsylvania?
- 09:47:53 24 A That's correct.
- 09:47:59 25 Q So three months after your graduation from
- 26 Robert Morris College, you acquired a driver's
- 27 license in Louisiana?
- 09:48:08 28 A That's correct.
- 09:48:08 29 Q Okay.
- 09:48:08 30 A Yes.
- 09:48:10 31 Q Now Mr. -- you stated earlier today that
- 32 you had documentation other than your driver's
- 19
- 1 license and your voter registration to prove that
- 2 you were, in fact, a resident of the district.
- 09:48:31 3 A Right.
- 09:48:31 4 Q What documentation do you have?
- 09:48:32 5 A Well, I have my bank account statements
- 6 showing when I opened the -- can you repeat the
- 7 question again. What year did you say?
- 09:48:46 8 Q Excuse me?
- 09:48:47 9 A What year did you say that I was a
- 10 resident between -- can you repeat your question you
- 11 just asked?
- 09:48:52 12 Q Oh, right. I said that earlier you had
- 13 testified that you have documentation other than the
- 14 driver's license and other than the voter
- 15 registration --
- 09:49:02 16 A Right.
- 09:49:02 17 Q -- to establish your residency here in the
- 18 district. And I asked you which documentation that
- 19 is.
- 09:49:08 20 A What year did you say? What residency
- 21 when? What time frame are you looking for?
- 09:49:14 22 THE COURT:
- 09:49:14 23 Well, let me just simplify the
- 24 question for you: What other documents do you have
- 25 other than your driver's license here with you today
- 26 that would establish your residency here?
- 09:49:22 27 THE WITNESS:
- 09:49:24 28 I have bank statements of me
- 29 opening, that I've opened. I have documents of me
- 30 being an employee of a business in 2012 in the
- 31 district. I have a couple of documents with my
- 32 attorney.
- 20
- 09:49:43 1 EXAMINATION BY MR. WILSON:
- 09:49:44 2 Q May I see them?
- 09:49:45 3 MS. VILLIO:
- 09:49:45 4 Your Honor, I would object.
- 5 It's Mr. Wilson's burden of proof on behalf of his
- 6 clients. I have documentation. Mr. Jackson does
- 7 not. I will introduce documentation through my
- 8 client at the proper time. Mr. Wilson can ask any
- 9 questions he wants and try to satisfy his burden of
- 10 proof. I think --
- 09:50:02 11 THE COURT:
- 09:50:02 12 And, Counsel, this is what's
- 13 going to happen: I know that there was a subpoena
- 14 that went out to him --
- 09:50:06 15 MR. WILSON:
- 09:50:06 16 Yes, Your Honor.
- 09:50:06 17 THE COURT:
- 09:50:07 18 -- requesting various documents;
- 19 so whatever documents he indicates that he has,
- 20 present those to Mr. Wilson. I'll note your
- 21 objection for the record.
- 09:50:14 22 MR. WILSON:
- 09:50:14 23 And also, if I may state for the
- 24 record, Your Honor, we attempted to take
- 25 Mr. Jackson's deposition. The sheriff went to the
- 26 house on the address, and he said no one was there.
- 27 Several times he went; so we did attempt to procure
- 28 this information well before, in advance of this
- 29 hearing.
- 09:50:30 30 THE COURT:
- 09:50:31 31 What documentation do you have,
- 32 sir? If you have that, Ms. Villio, if you'll
- 21
- 1 present that to Mr. Wilson, please.
- 09:50:41 2 MS. VILLIO:
- 09:50:41 3 Give me one second.
- 09:50:44 4 EXAMINATION BY MR. WILSON:
- 09:50:44 5 Q By the way, do you have a lease agreement
- 6 for the landlord?
- 09:50:50 7 A With which landlord are you talking about?
- 09:50:52 8 Q The landlord, where you live.
- 09:50:54 9 A Where I live currently or where I've
- 10 lived --
- 09:50:58 11 Q Anytime since 2012, do you have today with
- 12 you a lease agreement?
- 09:51:03 13 A No. I live with father. He doesn't
- 14 charge me rent. I'm sorry.
- 09:51:08 15 Q Do you have any Sewerage & Water Board
- 16 bills in your name?
- 09:51:11 17 A My dad pays all the bills. He's very
- 18 supportive of me. He doesn't charge me anything to
- 19 live with him.
- 09:51:23 20 Q Do you -- you have no bills, no documents
- 21 reflecting bills you've paid as far as household
- 22 notes, leases, gas, electric?
- 09:51:33 23 A My dad is Rickey Jackson. He's really
- 24 wealthy. He doesn't charge me anything to live with
- 25 him. I'll say it again.
- 09:51:42 26 Q Thanks for telling us your dad's Rickey
- 27 Jackson and he's wealthy.
- 09:51:47 28 A Thank you. You seem like --
- 09:51:48 29 THE COURT:
- 09:51:48 30 All right. Come on. Let's get
- 31 on with the next question, all right?
- 09:51:51 32 MS. VILLIO:
- 22
- 09:51:51 1 Judge, these are my only copies.
- 2 But I'm assuming Mr. Wilson would have gotten them
- 3 to me.
- 09:51:55 4 THE WITNESS:
- 09:51:55 5 Do you -- well, you have copies;
- 6 so I have copies of it.
- 09:51:58 7 THE COURT:
- 09:51:59 8 All right. Ready to proceed,
- 9 Mr. Wilson?
- 09:52:01 10 MR. WILSON:
- 09:52:01 11 Yes.
- 09:52:03 12 EXAMINATION BY MR. WILSON:
- 09:52:04 13 Q I'm looking at this. Okay, this account
- 14 indicates that the service address was 3204 West
- 15 Metairie, correct?
- 09:52:14 16 A Service on what? I can't see what you're
- 17 reading.
- 09:52:17 18 Q I'm sorry, Mr. Jackson.
- 09:52:19 19 A Thank you.
- 09:52:24 20 Q Okay, here. I'm just asking: The Entergy
- 21 bill says Rickey Jackson; that's your father,
- 22 correct?
- 09:52:32 23 A Correct.
- 09:52:33 24 Q Now it says the service account in West
- 25 Metairie.
- 09:52:36 26 A Correct.
- 09:52:36 27 Q What's the address?
- 09:52:37 28 A The address is 3204 West Metairie Avenue
- 29 North, Metairie, Louisiana.
- 09:52:54 30 Q Okay. Now I'm looking here also at -- you
- 31 said you had a bank account, correct?
- 09:53:00 32 A Correct.
- 23
- 09:53:00 1 Q But I'm looking at a bank account,
- 2 Mr. Jackson, Rickeem Jackson.
- 09:53:05 3 A Right.
- 09:53:06 4 Q Apparently, it says that you started this
- 5 account -- just let me read this into the record.
- 09:53:12 6 A All right.
- 09:53:13 7 Q Okay. "To whom it may concern, dated
- 8 August 28th, 2014, Capital One Bank."
- 09:53:19 9 A Correct.
- 09:53:21 10 Q "We're providing you with the following
- 11 information that was requested, Rickeem Jackson.
- 12 Rickeem Jackson has maintained a Rewards checking
- 13 account since 05-20-2013," correct?
- 09:53:33 14 A Correct.
- 09:53:33 15 Q "Presently on deposit at Capital One Bank,
- 16 zero. The average monthly balance is zero"; that's
- 17 correct?
- 09:53:40 18 A Correct.
- 09:53:40 19 Q So you have no money there now?
- 09:53:42 20 A Well, I took it out for this information
- 21 as I requested it. I didn't want anyone in my
- 22 financial business.
- 09:53:49 23 Q Uh-huh. But that account wasn't started
- 24 until May of 2013, correct?
- 09:53:52 25 A Correct, the same week I graduated
- 26 college, when I came back home.
- 09:53:57 27 Q So May of 2013, June, July, August, is a
- 28 year and three months ago, correct?
- 09:54:04 29 A Correct.
- 09:54:04 30 Q That's less than two years, correct?
- 09:54:07 31 A Yes.
- 09:54:07 32 Q Okay. So that account in an of itself
- 24
- 1 does not establish the fact that you have lived in
- 2 the district for two years, correct?
- 09:54:15 3 MS. VILLIO:
- 09:54:15 4 Objection, Judge. It calls for
- 5 a legal conclusion.
- 09:54:19 6 THE WITNESS:
- 09:54:19 7 That's the only reason I see it.
- 8 That's what --
- 09:54:20 9 THE COURT:
- 09:54:20 10 Listen, listen. When there's an
- 11 objection, stop talking.
- 09:54:25 12 THE WITNESS:
- 09:54:26 13 Okay.
- 09:54:26 14 MR. WILSON:
- 09:54:26 15 I'll move on, Your Honor.
- 09:54:32 16 THE COURT:
- 09:54:32 17 All right. Thank you.
- 09:54:32 18 MR. WILSON:
- 09:54:32 19 Okay.
- 09:54:32 20 THE WITNESS:
- 09:54:33 21 All right. You don't want
- 22 these?
- 09:54:42 23 EXAMINATION BY MR. WILSON:
- 09:54:43 24 Q Yeah, I'm done with these. Thank you. I
- 25 don't see here, Mr. Jackson, you have worked in
- 26 Louisiana.
- 09:55:20 27 A Excuse me?
- 09:55:21 28 Q You've been employed in Louisiana?
- 09:55:23 29 A Yes.
- 09:55:24 30 Q Since when?
- 09:55:26 31 A 2012. I've been working for my dad since
- 32 2012.
- 25
- 09:55:29 1 Q Do you have any tax records or returns
- 2 reflecting that you were working for your dad?
- 09:55:34 3 A No.
- 09:55:34 4 Q So you've not paid taxes?
- 09:55:37 5 A Have I paid taxes? I wasn't getting a
- 6 salary. I was working for my dad's business; so
- 7 there's no taxes to pay. It was -- you know, I was
- 8 living with him for free going back to that; that's
- 9 why I didn't pay bills. It was a trade off. I
- 10 didn't just live in the house, you know. I earned
- 11 my keep, so to speak.
- 09:56:15 12 Q Now you said that -- do you -- do you have
- 13 any documentation evidencing the fact that you lived
- 14 in the district two years before the time you
- 15 qualified, that you've lived in this district,
- 16 District 2 for two years?
- 09:56:52 17 MS. VILLIO:
- 09:56:52 18 Objection, Your Honor. It calls
- 19 for a legal conclusion.
- 09:56:55 20 THE COURT:
- 09:56:56 21 Overruled.
- 09:56:56 22 THE WITNESS:
- 09:56:58 23 Did you see the documents where
- 24 I'm director and officer of the meat company in
- 25 2012?
- 09:57:07 26 EXAMINATION BY MR. WILSON:
- 09:57:07 27 Q Yeah. But you don't have to live here to
- 28 be a director. My question is do you have any
- 29 documentation showing that you had a physical
- 30 presence in this district for two years?
- 09:57:16 31 MS. VILLIO:
- 09:57:16 32 Again, Your Honor, objection.
- 26
- 1 He's asking the witness -- that's not the legal
- 2 requirement. The legal requirement is State
- 3 residency for the last two years; and so I'd object
- 4 to the relevance of documentation within the
- 5 district for the past two years.
- 09:57:33 6 THE COURT:
- 09:57:33 7 Mr. Wilson.
- 09:57:34 8 MR. WILSON:
- 09:57:34 9 Well, Your Honor, just to avoid
- 10 argumentation, I'll rephrase the question.
- 09:57:37 11 EXAMINATION BY MR. WILSON:
- 09:57:37 12 Q Any documentation reflecting that you've
- 13 lived in Louisiana for the past two years?
- 09:57:43 14 MS. VILLIO:
- 09:57:43 15 Again, asked and answered.
- 09:57:44 16 THE WITNESS:
- 09:57:47 17 I showed you what documents that
- 18 I have.
- 09:57:49 19 EXAMINATION BY MR. WILSON:
- 09:57:49 20 Q Okay. And the only documents that you
- 21 have are the documents that you showed me today,
- 22 correct?
- 09:57:54 23 A Correct.
- 09:57:55 24 MR. WILSON:
- 09:57:55 25 Okay, thank you. I have no
- 26 further questions, Your Honor.
- 09:57:57 27 THE COURT:
- 09:57:57 28 Thank you. Ms. Villio.
- 09:57:57 29 MS. VILLIO:
- 09:57:57 30 Thank you, Your Honor.
- 09:57:57 31 MR. WILSON:
- 09:57:58 32 Well, Your Honor, may I -- I'd
- 27
- 1 like to offer, introduce, and file into evidence
- 2 Exhibit 1, as P-1 --
- 09:58:17 3 THE COURT:
- 09:58:18 4 Is that going to be the document
- 5 from Robert Morris?
- 09:58:24 6 MR. WILSON:
- 09:58:24 7 Yes, that Mr. Rickeem
- 8 identified.
- 09:58:26 9 THE COURT:
- 09:58:26 10 Do you have your copy that you
- 11 can mark --
- 09:58:27 12 MR. WILSON:
- 09:58:27 13 Yeah, I have mine.
- 09:58:27 14 THE COURT:
- 09:58:27 15 -- to present to the clerk?
- 16 All, right. Thank you.
- 09:58:27 17 MR. WILSON:
- 09:58:27 18 Thank you, Your Honor.
- 09:58:27 19 THE COURT:
- 09:58:28 20 Ms. Villio, any objection?
- 09:58:31 21 MS. VILLIO:
- 09:58:31 22 No objection, Judge.
- 09:58:35 23 THE COURT:
- 09:58:35 24 All right, Counsel, any
- 25 objection?
- 09:58:35 26 MS. TORREGANO:
- 09:58:35 27 No objection, Your Honor. May I
- 28 approach?
- 09:58:52 29 THE COURT:
- 09:58:52 30 Yes, you can come up.
- 09:58:52 31 (Bench conference off the record.)
- 09:58:52 32 THE COURT:
- 28
- 09:58:52 1 Sir, you can stand down for one
- 2 moment. Please don't discuss your testimony with
- 3 anyone. Court will be in recess for one moment.
- 10:12:23 4 (Whereupon, a recess was taken.)
- 10:12:24 5 THE COURT:
- 10:12:24 6 Mr. Jackson, if you'll come back
- 7 up, sir. Ready, Ms. Villio?
- 10:12:28 8 MS. VILLIO:
- 10:12:28 9 Yes, sir.
- 10:12:30 10 EXAMINATION BY MS. VILLIO:
- 10:12:34 11 Q Mr. Jackson, you're a candidate for the
- 12 Jefferson Parish School Board District 2; is that
- 13 correct?
- 10:12:42 14 A Yes.
- 10:12:43 15 Q And when did you qualify as a candidate?
- 10:12:49 16 A From I think it was August 25th of 20 --
- 10:12:49 17 Q August 25th. Did you qualify on that
- 18 Wednesday?
- 10:12:51 19 A Yes.
- 10:12:51 20 Q August 20th, 2014 sound right?
- 10:12:54 21 A Yes.
- 10:12:55 22 Q Okay. And you indicated your current home
- 23 address is on Brighton Place; is that correct?
- 10:12:59 24 A Yes.
- 10:12:59 25 Q How long have you lived at the Brighton
- 26 Place address?
- 10:13:02 27 A About two months.
- 10:13:03 28 Q And that's in Harvey?
- 10:13:06 29 A Yes.
- 10:13:07 30 Q Are you married, Mr. Jackson?
- 10:13:08 31 A No, ma'am.
- 10:13:09 32 Q Have you ever been married?
- 29
- 10:13:10 1 A No, ma'am.
- 10:13:11 2 Q Before you moved to Brighton Place, where
- 3 did you live?
- 10:13:15 4 A 3701 Lake Catherine.
- 10:13:16 5 Q And that is in Harvey as well?
- 10:13:21 6 A Yes.
- 10:13:21 7 Q And 3701 Lake Catherine, who did you live
- 8 at 3701 Lake Catherine with?
- 10:13:27 9 A With my and my two brothers, Rickeyvis and
- 10 Tyler Jackson.
- 10:13:33 11 Q Okay. And how old is Rickeyvis and how
- 12 old is Tyler?
- 10:13:36 13 A Tyler's twenty. Rickeyvis is twenty-four
- 14 and Tyler's nineteen.
- 10:13:39 15 Q Okay. And when did you -- how long had
- 16 you lived with your father and your two brothers at
- 17 the Lake Catherine address?
- 10:13:46 18 A We moved there in September of 20 -- we've
- 19 been living there since September.
- 10:13:54 20 Q I'm sorry. What?
- 10:13:55 21 A We've been living there since September,
- 22 early September I'd say.
- 10:13:59 23 Q Of 2013?
- 10:14:00 24 A Yes.
- 10:14:01 25 Q Okay. And is that a house?
- 10:14:02 26 A Yes.
- 10:14:03 27 Q And is that a house that was purchased, or
- 28 do y'all rent it?
- 10:14:07 29 A No, we purchased it.
- 10:14:15 30 MS. VILLIO:
- 10:14:16 31 Judge, if you can give me one
- 32 moment.
- 30
- 10:14:18 1 THE COURT:
- 10:14:18 2 Take your time.
- 10:14:27 3 MS. VILLIO:
- 10:14:27 4 Thanks. I was looking at it.
- 5 Wilson, you don't have the act of sale, do you?
- 10:14:27 6 MR. WILSON:
- 10:14:33 7 No, uh-uh. They were all
- 8 together packed. They're probably in there
- 9 someplace.
- 10:14:34 10 MS. VILLIO:
- 10:14:34 11 I just don't see it now. Oh, I
- 12 got it.
- 10:14:53 13 MR. WILSON:
- 10:14:53 14 You have it?
- 10:14:54 15 MS. VILLIO:
- 10:14:54 16 I do.
- 10:15:04 17 EXAMINATION BY MS. VILLIO:
- 10:15:04 18 Q Mr. Jackson, I'm going to show you a
- 19 certified copy of an act of sale for 3701 Lake
- 20 Catherine in September of 2013 and ask you if you
- 21 recognize the name of the purchaser on that act of
- 22 sale and the address, itself.
- 10:15:33 23 A (Witness viewing document) Yes, I
- 24 recognize the name.
- 10:15:36 25 Q And Rickey Jackson is your father?
- 10:15:38 26 A Yes, ma'am.
- 10:15:39 27 Q And how long after your father bought that
- 28 house on Lake Catherine, about how long after he
- 29 bought it do you recall that y'all actually moved in
- 30 to live in the house?
- 10:15:52 31 A It was about two weeks.
- 10:15:53 32 Q Okay. And before living at the Lake
- 31
- 1 Catherine address, where did you live?
- 10:15:58 2 A We lived off of Hyde Park in Harvey.
- 10:16:04 3 Q Okay, Hyde Park in Harvey. And was that a
- 4 location that y'all owned, or was that a location
- 5 that your father rented?
- 10:16:12 6 A We rented from there.
- 10:16:14 7 Q Okay. And Hyde Park is in Harvey as well,
- 8 correct?
- 10:16:19 9 A Correct.
- 10:16:19 10 Q And how long do you recall living at the
- 11 Hyde Park address?
- 10:16:25 12 A About a year and a half. I'd say about
- 13 sixteen, seventeen months.
- 10:16:30 14 Q Okay. And Mr. Wilson had shown you your
- 15 bank account records which I will mark as D-2. And
- 16 I ask you to again take a look at the bank account
- 17 records.
- 10:16:42 18 THE COURT:
- 10:16:42 19 One second, Ms. Villio. You're
- 20 marking the act of sale as D-1?
- 10:16:47 21 MS. VILLIO:
- 10:16:48 22 Yes, sir.
- 10:16:49 23 THE COURT:
- 10:16:49 24 All right, thank you.
- 10:16:50 25 MS. VILLIO:
- 10:16:50 26 And I have D-2.
- 10:16:51 27 EXAMINATION BY MS. VILLIO:
- 10:16:51 28 Q And I'd ask you to take a look at that.
- 29 And the address that you used on that account was
- 30 the Hyde Park address; was it not?
- 10:16:59 31 A Yes, ma'am.
- 10:16:59 32 Q And that account was opened how long after
- 32
- 1 you graduated from Robert Morris University in
- 2 Pennsylvania?
- 10:17:08 3 A Exactly sixteen days.
- 10:17:12 4 Q Okay. And when did you graduate from
- 5 Robert Morris University?
- 10:17:18 6 A On May 4th.
- 10:17:19 7 Q May 4th of 2013?
- 10:17:23 8 A Yes.
- 10:17:27 9 Q I'm going to go ahead and show you what
- 10 I've marked as D-3 which is your transcript and ask
- 11 you if the transcript reflects the date you
- 12 graduated from the university.
- 10:17:37 13 A (Witness viewing exhibit) Yes, ma'am.
- 10:17:38 14 Q And that is May 4th, 2013?
- 10:17:41 15 A Yes.
- 10:17:42 16 Q And the address that that transcript was
- 17 forwarded to is what address?
- 10:17:47 18 A Uh, 3701 Lake Catherine Drive.
- 10:17:48 19 Q Now before living at the Hyde Park
- 20 address, where did you live?
- 10:18:07 21 A Before Hyde Park, we lived in Marrero.
- 10:18:11 22 Q Do you recall where in Marrero?
- 10:18:13 23 A I'm not sure of the exact address. It was
- 24 42 Avenue C or something like that. I'm not --
- 10:18:25 25 Q Does 448 Avenue I, does that mean
- 26 anything?
- 10:18:28 27 A Yes.
- 10:18:30 28 Q Is that -- there's something about
- 29 Barataria. Is that the --
- 10:18:34 30 A Yes.
- 10:18:35 31 Q Is that what you refer to as the Barataria
- 32 home?
- 33
- 10:18:38 1 A Yes, ma'am.
- 10:18:38 2 Q Okay. And how long had you lived at the
- 3 Barataria address, the Avenue I in Marrero address?
- 10:18:47 4 A We lived there about a year, a year and
- 5 three or four months before we moved from that area.
- 10:18:55 6 Q Okay. Any others addresses in Louisiana
- 7 and/or Jefferson Parish that you recall living at?
- 10:19:00 8 A Well, we lived in Metairie for about three
- 9 or four years. But I'm not exactly sure of the
- 10 exact address, though.
- 10:19:09 11 Q Do you recall the street that was?
- 10:19:12 12 A No, I don't.
- 10:19:13 13 Q And if I told you 3204 West Metairie
- 14 Avenue North, West Metairie Avenue North, does that
- 15 mean anything?
- 10:19:21 16 A Yes.
- 10:19:22 17 Q Okay. And what address is that?
- 10:19:23 18 A That's the address in Metairie that I
- 19 lived at.
- 10:19:25 20 Q And who did you live there with?
- 10:19:28 21 A With my dad and my brother.
- 10:19:30 22 Q How long have you lived in Jefferson
- 23 Parish with your father and your brother and/or
- 24 brothers?
- 10:19:37 25 A Well, I lived -- I moved in Metairie, and
- 26 I'd say about three years.
- 10:19:43 27 Q Do you remember the circumstances of when
- 28 you moved?
- 10:19:47 29 A When I moved?
- 10:19:49 30 Q I'm sorry, to Louisiana to live with your
- 31 dad.
- 10:19:53 32 A The circumstances, I've always, you know,
- 34
- 1 since high school, when I wanted to pursue football,
- 2 that's when, you know, me and my dad kind of got
- 3 reacquainted in 2009 and him playing football. I
- 4 was always back and forth, and that's when I moved
- 5 home with him the summer of when I graduated high
- 6 school. And I contemplated going to college. And
- 7 my dad got me in school, and that's what the
- 8 circumstances were.
- 10:20:24 9 Q All right. So the summer after high
- 10 school -- you graduated from high school you said in
- 11 2009?
- 10:20:28 12 A Yes, ma'am.
- 10:20:30 13 Q Would that have been -- did y'all graduate
- 14 in May of 2009?
- 10:20:32 15 A Yes.
- 10:20:33 16 Q Is that when you would --
- 10:20:34 17 A Yes.
- 10:20:34 18 Q And how long after you graduated from high
- 19 school did you come move in with your dad?
- 10:20:40 20 A It was immediately because I really wanted
- 21 to discuss, you know, football and stuff like that;
- 22 so I was trying to see where I was going to go with
- 23 football after college and stuff like that.
- 10:20:51 24 Q So where did you live in the summer of
- 25 2009?
- 10:20:55 26 A In 2009, we lived in Metairie and
- 27 transitioned to the Marrero address.
- 10:21:00 28 Q And then when did you start, decide to go
- 29 to college and start college?
- 10:21:05 30 A 2009, in August, I believe.
- 10:21:09 31 Q So that summer, fall of 2009 --
- 10:21:11 32 A Right.
- 35
- 10:21:11 1 Q -- is when you started going to school --
- 10:21:14 2 A Yes, ma'am.
- 10:21:15 3 Q -- college, or wait, just college?
- 10:21:16 4 A Yes, ma'am.
- 10:21:16 5 Q And you graduated you said from Robert
- 6 Morris University in Pennsylvania May 4th, 2013,
- 7 correct?
- 10:21:19 8 A Yes, ma'am.
- 10:21:25 9 Q While attending -- how long had you --
- 10 when did you start going to Robert Morris
- 11 University?
- 10:21:28 12 A I was there for two years; so 2011.
- 10:21:37 13 Q Okay. And while you -- while you were
- 14 staying in Pennsylvania attending school at Robert
- 15 Morris University, where did you stay?
- 10:21:44 16 A I stayed in a dorm, in a dormitory called
- 17 Concord Hall which is on campus housing at Robert
- 18 Morris University.
- 10:21:57 19 Q And you went to Robert Morris University
- 20 on a football scholarship?
- 10:21:57 21 A Yes, ma'am.
- 10:22:01 22 Q Okay. Where did y'all -- where did you
- 23 call home while attending college? What did you
- 24 consider home?
- 10:22:06 25 A With my dad and my brothers who was
- 26 obviously supporting me.
- 10:22:11 27 Q How often did you return to your home with
- 28 your father and your brothers?
- 10:22:15 29 A Every break. Every holiday. A lot of
- 30 weekends, when we weren't in season, you know, just
- 31 the training. And I advised my dad. And, you know,
- 32 working for the business as officer and director, I
- 36
- 1 had to be back and forth a lot.
- 10:22:34 2 Q And when you say working for the business
- 3 as officer and director, is there more than one
- 4 business? Well, tell me about that business.
- 10:22:42 5 A Yes, I was officer and director of my
- 6 dad's meat company. I'm also the executive director
- 7 for his nonprofit organization, the Rickey Jackson
- 8 Hope Center Foundation.
- 10:23:00 9 Q I'm going show you some certified records
- 10 from the Secretary of State which I've marked as
- 11 D-4. That's the Rickey Jackson Meat Products
- 12 Incorporation?
- 10:23:14 13 A (Witness viewing exhibit) Yes.
- 10:23:16 14 Q And what is the registration date of the
- 15 Rickey Jackson Meat Products Corporation on that
- 16 paperwork, Mr. Jackson?
- 10:23:24 17 A March 7th, 2012.
- 10:23:26 18 Q And you -- what is your role in that
- 19 company?
- 10:23:29 20 A Officer and director --
- 10:23:31 21 Q Okay.
- 10:23:31 22 A -- of the company.
- 10:23:32 23 Q And are you listed on that paperwork as
- 24 officer/director?
- 10:23:37 25 A Yes, ma'am.
- 10:23:38 26 Q And the address, the New Orleans,
- 27 Louisiana address that's listed on that paperwork,
- 28 is that the meat products corporation address?
- 10:23:45 29 A Yes.
- 10:23:54 30 Q And you mentioned another business. Is
- 31 that the Rickey Jackson and Friends Community Hope
- 32 Foundation?
- 37
- 10:24:01 1 A Yes, ma'am.
- 10:24:01 2 Q And tell me a little bit about that. When
- 3 did you and your dad start working on that Hope
- 4 Foundation?
- 10:24:11 5 A It's always been a vision since high
- 6 school. But I talked to him into it. And Sean
- 7 Payton, we got together with that in 2011; that's
- 8 when we first got the insurance on the building and
- 9 the facility that we were going to open up for the
- 10 youth and the community.
- 10:24:30 11 Q Now at the time that y'all got the
- 12 building and the facility and the insurance, had you
- 13 already filed the paperwork with the Secretary of
- 14 State for the corporation, or did that come
- 15 afterwards?
- 10:24:41 16 A It came afterwards.
- 10:24:42 17 Q And your role in the Rickey Jackson and
- 18 Friends Community Hope Foundation is what?
- 10:24:51 19 A Executive Director.
- 10:24:55 20 Q I'm going to show you what I've marked as
- 21 D-5 and ask you if that's the paperwork filed with
- 22 the Secretary of State in September, 2012 relative
- 23 to the Hope Foundation. And it also lists you as a
- 24 director.
- 10:25:11 25 A (Witness viewing exhibit) Yes, ma'am.
- 10:25:37 26 MS. VILLIO:
- 10:25:37 27 Thank you, Mr. Jackson.
- 10:25:39 28 THE WITNESS:
- 10:25:39 29 Thank you.
- 10:25:40 30 THE COURT:
- 10:25:40 31 Mr. Wilson.
- 10:25:41 32 EXAMINATION BY MR. WILSON:
- 38
- 10:25:41 1 Q Just a couple of questions.
- 10:25:48 2 MS. VILLIO:
- 10:25:48 3 One second.
- 10:25:50 4 EXAMINATION BY MR. WILSON:
- 10:25:50 5 Q Mr. Jackson, I'm looking at your
- 6 transcript. It says Page 2 of 2. Where's Page 1 of
- 7 1?
- 10:25:57 8 A I don't have it.
- 10:25:58 9 Q Why?
- 10:25:59 10 A I'm not sure. I just got the date of
- 11 graduation; that's the reason.
- 10:26:04 12 Q What was on the front page? What was on
- 13 Page 1 of 1?
- 10:26:08 14 A Some more classes and grades. It didn't
- 15 have the conclusion of what I was looking for.
- 10:26:14 16 Q Well, when did you obtain a copy of that
- 17 transcript?
- 10:26:23 18 A I'm not sure.
- 10:26:26 19 Q Okay. You indicated you're executive
- 20 director or the officer of the meat company?
- 10:26:36 21 A No, executive director of the nonprofit
- 22 Rickey Jackson Hope Center. I'm officer and
- 23 director of the meat company.
- 10:26:43 24 Q Okay. You're officer and director of the
- 25 meat company?
- 10:26:46 26 A Correct.
- 10:26:46 27 Q Okay. Is that a paid job?
- 10:26:49 28 A No, sir.
- 10:26:51 29 Q Let me ask you: Are you gainfully
- 30 employed? Are you receiving a paycheck from
- 31 anybody?
- 10:26:57 32 A Am I receiving a paycheck from anyone
- 39
- 1 right now?
- 10:27:01 2 Q Yes.
- 10:27:01 3 MS. VILLIO:
- 10:27:01 4 Objection to relevance, Judge.
- 10:27:04 5 THE WITNESS:
- 10:27:04 6 You're asking my salary?
- 10:27:05 7 THE COURT:
- 10:27:06 8 Wait one second, sir. Counsel.
- 10:27:07 9 MR. WILSON:
- 10:27:07 10 Yes, Your Honor. We're trying
- 11 to establish other indicia or presence in the
- 12 community. And one way the Courts have allowed that
- 13 is by --
- 10:27:15 14 THE COURT:
- 10:27:15 15 I'll overrule the objection.
- 16 You can answer that question, sir.
- 10:27:18 17 EXAMINATION BY MR. WILSON:
- 10:27:20 18 Q Yes. Are you presently gainfully employed
- 19 by anyone? Are you getting a paycheck from anyone?
- 10:27:25 20 A Yes.
- 10:27:25 21 Q And do you have a copy of that paycheck
- 22 with you?
- 10:27:28 23 A No, I do not. I have check stubs with me.
- 10:27:31 24 Q How long have you been getting a paycheck?
- 10:27:38 25 A Since I'd say about, since I graduated
- 26 college and got the credentials to get my job.
- 10:27:48 27 Q Okay. So you graduated college in May of
- 28 2013?
- 10:27:49 29 A Yes.
- 10:27:51 30 Q A little bit over a year ago?
- 10:27:53 31 A Yes.
- 10:27:54 32 Q Okay. And do you have any income tax
- 40
- 1 returns?
- 10:27:58 2 A No.
- 10:27:59 3 Q And you say you have check stubs. Do you
- 4 have them with you?
- 10:28:02 5 A No, I don't have check stubs with me.
- 10:28:06 6 Q I think earlier you had testified that you
- 7 weren't being paid, that you were living with your
- 8 father in return for the work that you were doing.
- 9 He was providing you free room and board?
- 10:28:16 10 A That was with the Hyde Park addresses and
- 11 those addresses that you were asking at that
- 12 particular moment. You never asked about the
- 13 situation now.
- 10:28:25 14 Q Since you've lived -- since you have
- 15 lived -- since you have been in Louisiana --
- 10:28:29 16 A Right.
- 10:28:29 17 Q -- have you ever had your own apartment
- 18 where you lived by yourself?
- 10:28:33 19 A No.
- 10:28:34 20 Q And for right now, you do not have your
- 21 own apartment, correct?
- 10:28:37 22 A No.
- 10:28:38 23 Q Okay. Since you've lived in Louisiana,
- 24 have you ever paid rent?
- 10:28:44 25 A I just started paying rent over the last
- 26 seven weeks.
- 10:28:51 27 Q Didn't you earlier testify that you were
- 28 living rent free with your father?
- 10:28:56 29 A No, I testified that I live at 2241
- 30 Brighton Place. My father's address is 3701 Lake
- 31 Catherine.
- 10:29:05 32 Q Do you have a lease?
- 41
- 10:29:05 1 A I no longer live with my father.
- 10:29:07 2 Q Do you have a lease?
- 10:29:08 3 A No.
- 10:29:09 4 Q Do you have a rental agreement?
- 10:29:11 5 A A verbal agreement. I just moved in, like
- 6 I said, about six weeks ago.
- 10:29:15 7 Q Do you have any receipts reflecting the
- 8 payment of rent?
- 10:29:19 9 A Not yet.
- 10:29:20 10 Q Okay. Do you have a receipt showing
- 11 payment of a damage deposit?
- 10:29:25 12 A I just moved.
- 10:29:27 13 Q Do you have a receipt showing --
- 10:29:32 14 A No.
- 10:29:32 15 Q Now you indicated that -- what is it?
- 16 Friends Hope Foundation?
- 10:29:45 17 A Yes.
- 10:29:45 18 Q That has been in existence since 2012?
- 10:29:48 19 A That's -- the grand opening was shortly
- 20 after I graduated because everything was kind of on
- 21 hold. But it's been in existence -- we've had the
- 22 property. We've had our insurance. Because of the
- 23 molestation of priests and stuff like that, we had
- 24 our insurance. And we opened the building up. We
- 25 had rights to the building in 2011 and 2012, yes.
- 10:30:11 26 Q 2011 and 2012, you were in Pittsburgh, in
- 27 Pennsylvania, correct?
- 10:30:18 28 A Which was around the -- the center was not
- 29 opened, correct.
- 10:30:20 30 Q And so the center officially opened in
- 31 2013?
- 10:30:24 32 A Officially, yes.
- 42
- 10:30:25 1 Q Okay, 2013, okay.
- 10:30:25 2 A Yes.
- 10:30:25 3 Q -- which is a little bit over, a little
- 4 bit over a year ago?
- 10:30:26 5 A Yeah.
- 10:30:33 6 MR. WILSON:
- 10:30:33 7 Okay. Your Honor, I have no
- 8 further questions.
- 10:30:35 9 THE COURT:
- 10:30:35 10 All right. Thank you, sir. You
- 11 may stand down. Any other witnesses, Mr. Wilson?
- 10:30:41 12 MR. WILSON:
- 10:30:41 13 Yes, the plaintiff, Your Honor.
- 10:30:43 14 THE COURT:
- 10:30:43 15 All right. Ms. Simmons, if
- 16 you'll come up. You may stand down, sir.
- 17 Ms. Simmons, if you'll come up. Raise your right
- 18 hand and be sworn, please.
- 10:30:47 19 FRANCIENNE SIMMONS, after having been
- 20 first duly sworn by the minute clerk, testified as
- 21 follows:
- 10:30:59 22 MINUTE CLERK:
- 23 You may have a seat, ma'am.
- 24 Please state your name and address for the record,
- 25 please.
- 10:31:00 26 THE WITNESS:
- 10:31:01 27 My name is Francienne Simmons.
- 28 I live at 1701 Pailet Avenue, Harvey, Louisiana.
- 10:31:07 29 EXAMINATION BY MR. WILSON:
- 10:31:07 30 Q Ms. Francienne Simmons, are you one of the
- 31 plaintiffs in this litigation challenging the
- 32 qualifications of Mr. Jackson?
- 43
- 10:31:15 1 A Yes.
- 10:31:16 2 Q And, Ms. Simmons, again, what's your
- 3 address?
- 10:31:19 4 A 1701 Pailet Avenue, Harvey, Louisiana.
- 10:31:23 5 Q Are you a registered voter?
- 10:31:25 6 A Yes.
- 10:31:26 7 Q Okay. And are you -- in which School
- 8 Board district do you reside?
- 10:31:31 9 A I'm in the newly formed District 2.
- 10:31:34 10 MR. WILSON:
- 10:31:34 11 Okay, thank you. I have no
- 12 further questions, Your Honor.
- 10:31:37 13 THE COURT:
- 10:31:37 14 Okay, thank you. Ms. Villio.
- 10:31:38 15 MS. VILLIO:
- 10:31:38 16 No questions, Judge.
- 10:31:40 17 THE COURT:
- 10:31:40 18 Ma'am, I assume you don't have
- 19 any questions.
- 10:31:43 20 MS. TORREGANO:
- 10:31:43 21 No.
- 10:31:44 22 THE COURT:
- 10:31:44 23 All right. Thank you, ma'am.
- 24 You may stand down. Any other witnesses,
- 25 Mr. Wilson?
- 10:31:47 26 MR. WILSON:
- 10:31:47 27 No other witnesses, Your Honor.
- 10:31:49 28 THE COURT:
- 10:31:49 29 Ms. Villio.
- 10:31:49 30 MS. VILLIO:
- 10:31:49 31 Your Honor, I'd move for a
- 32 judgment in Mr. Jackson's favor at this time. The
- 44
- 1 plaintiffs have challenged the two-year State
- 2 residency requirement under Louisiana RS:1752 as to
- 3 Mr. Jackson. The burden is on the plaintiffs to
- 4 prove that Mr. Rickeem Jackson has not maintained a
- 5 residence in the State of Louisiana for two years
- 6 preceding his qualification as a candidate for
- 7 Jefferson Parish School Board District 2, which
- 8 qualification was on August 20th, 2014. And the
- 9 plaintiffs have clearly not satisfied their burden,
- 10 Your Honor; and so at this time, I would request
- 11 that there be a judgment in favor of, dismissing the
- 12 complaint in favor of Mr. Jackson.
- 10:32:29 13 THE COURT:
- 10:32:30 14 Thank you. Mr. Wilson.
- 10:32:34 15 MR. WILSON:
- 10:32:34 16 Your Honor, in handling numerous
- 17 cases of this nature over the years, I've never seen
- 18 a case where there was a clear-cut case of an
- 19 individual not being qualified and not being a
- 20 resident of the State for the past two years. Let's
- 21 go back over his testimony. He doesn't know if he
- 22 ever had a driver's license or when. The first
- 23 driver's license that we have on record for
- 24 Mr. Williams (sic) is 2013. He doesn't know -- a
- 25 twenty-five year old man doesn't know if he's ever
- 26 voted. And he said, "Well, somebody might have
- 27 stolen my ID and voted for me. But pretermitting
- 28 that and putting that all aside, Your Honor, the
- 29 first evidence of registering to vote in the State
- 30 of Louisiana is two or three weeks ago. He has --
- 31 he's a twenty-five year old man, no source of
- 32 income. He has no leases, no rental agreement, no
- 45
- 1 W-2 forms, no income tax return. He has nothing,
- 2 Your Honor, showing a presence in the State of
- 3 Louisiana for two years. I mean nothing. All he
- 4 brought with him today was a convenient memory, you
- 5 know, the ultimate memory of those things which were
- 6 crucial, which were essential. And, of course,
- 7 talking about indicia, indicia of residence, he
- 8 doesn't have one. His word is undocumented word.
- 9 "Well, I was on -- I'm on the Board of my father's
- 10 company." You don't have to be a resident to be on
- 11 the Board of a company. As a matter of fact, when
- 12 the company was formed, he admitted that he was in
- 13 Pennsylvania at the time; so being on the Board of
- 14 your father's company is nothing. The record
- 15 indicates several things, Your Honor, which we
- 16 established. He admitted he went to high school, at
- 17 Ocoee High School in Florida. From Ocoee High
- 18 School, Your Honor, he went to a junior college in
- 19 California. From the junior college in California,
- 20 he went to a university in Pennsylvania. And in May
- 21 of 2013 is when he graduated and when he came to
- 22 Louisiana; that's all he's shown. Everything else
- 23 indicates, Your Honor, that he was not here for the
- 24 required time period.
- 10:34:51 25 I request that the Court just
- 26 deny defendant's motion, Your Honor.
- 10:34:55 27 THE COURT:
- 10:34:55 28 All right.
- 10:34:57 29 MS. VILLIO:
- 10:34:57 30 Your Honor, if I may, for as
- 31 clear-cut as Mr. Wilson sees it, it's amazing to me
- 32 because when I look at this case, I don't even see
- 46
- 1 it as gray. As I indicated, the burden's on the
- 2 plaintiffs. They failed to meet their burden.
- 3 Election laws should be liberally construed, as this
- 4 Court well knows, to promote rather than defeat a
- 5 candidacy. Any doubt as to the qualifications of a
- 6 candidate should be resolved in favor of the
- 7 candidate being permitted to run for office. As the
- 8 Court well knows, residence and domicile are not
- 9 synonomous. The statute, itself, further supports
- 10 this premise requiring only a two-year Louisiana
- 11 State residency, but actual domicile for only one
- 12 year prior to qualifying. And it is clear from the
- 13 plaintiffs' complaint that their only challenge is
- 14 as to the two-year Louisiana State residency
- 15 requirement. It's well settled under Louisiana law
- 16 that while a person may have only one domicile, he
- 17 may maintain two or more residences at the same
- 18 time. As the Court noted in both Davis versus
- 19 Engler (phonetic) and Tomlinson versus Frazier, both
- 20 quoting the Louisiana Supreme Court in the case of
- 21 Caulfield versus Cravens (phonetic), the issue of
- 22 residence depends upon the resident's intent and
- 23 that the intention of the person is determined by
- 24 his expression thereof and his testimony when called
- 25 on considered in connection with his conduct and
- 26 circumstances of life. This was a young man who was
- 27 attending college in Pennsylvania on a football
- 28 scholarship through May 4th, 2013. Before leaving
- 29 for that football scholarship, after he graduated
- 30 from high school in May, 200, he chose to come and
- 31 live home with his father, Rickey Jackson, here in
- 32 the State of Louisiana, in fact, here in Jefferson
- 47
- 1 Parish. The requirement is only a Louisiana State
- 2 requirement. He came to live home in Louisiana,
- 3 Jefferson Parish, Louisiana with his father, Rickey
- 4 Jackson, and then one of his brothers. And his
- 5 second brother, the other brother, came and joined
- 6 them when he got out of high school; so the boys
- 7 chose to live with their father when they graduated
- 8 from high school. He returned home every chance he
- 9 could, based on his testimony, during breaks, during
- 10 the summer, on weekends, whenever he could as a
- 11 young unmarried man and a college student. He never
- 12 abandoned his Louisiana legal domicile with his
- 13 father, and plaintiffs certainly cannot meet their
- 14 burden of proving that he did. The fact that he
- 15 lived with his mother as a young high school student
- 16 prior to his graduation from high school and prior
- 17 to living with his father and prior to going to
- 18 Pennsylvania on a football scholarship, that's --
- 19 the requirement is a two-year State requirement, not
- 20 where he lived when he grew up as a young child. It
- 21 was always -- it was obvious that Mr. Jackson's
- 22 intent was to return to his Louisiana residence
- 23 after graduating from college; and that, Judge, is
- 24 the premise and the basis for the evidence relative
- 25 to the Hope Foundation and relative to the Meat
- 26 Product Foundation Corporation. And the Meat
- 27 Product Corporation was incorporated in March of
- 28 2012, more than two years prior to Mr. Jackson's
- 29 qualification for office. Mr. Jackson is listed as
- 30 an Officer Director of that Meat Product Corporation
- 31 and with the New Orleans address of the Meat Product
- 32 Corporation along with the Hope Foundation that he
- 48
- 1 was working on with his father since 2011 which was
- 2 then incorporated actually in September, 2013
- 3 before its grand opening. All of those things,
- 4 Judge, along with a very key piece of evidence was
- 5 his bank account that he opened within weeks of
- 6 graduating from high school which supports his
- 7 testimony that after he graduated from high
- 8 school --
- 10:39:10 9 MR. WILSON:
- 10:39:10 10 Your Honor --
- 10:39:13 11 MS. VILLIO:
- 10:39:13 12 I apologize, college, after he
- 13 graduated from college that his intent was to come
- 14 live back home with his father. He lived with his
- 15 father in 2009 before he went to college. He came
- 16 back home after college. He graduated from college.
- 17 And during the whole time he was attending college,
- 18 he came home to be with his father and his brothers
- 19 here in Louisiana. He lived in a dorm in college.
- 20 He was a college student at the time.
- 10:39:40 21 The plaintiffs simply have not
- 22 met their burden, Judge. The testimonial evidence
- 23 and the documentary evidence that was produced
- 24 during the plaintiff's case shows that the
- 25 plaintiffs have not met their evidence, their burden
- 26 of proof; and that Mr. Jackson was a Louisiana State
- 27 resident for the two years prior to his candidacy.
- 10:40:00 28 THE COURT:
- 10:40:00 29 Thank you, Ms. Villio.
- 10:40:06 30 MR. WILSON:
- 10:40:02 31 Do I get one more bite?
- 10:40:07 32 THE COURT:
- 49
- 10:40:07 1 I'll get you one more -- I'll
- 2 give you one more bite at the apple.
- 10:40:12 3 MR. WILSON:
- 10:40:09 4 It's going to be a short bite.
- 10:40:13 5 THE COURT:
- 10:40:13 6 Thank you.
- 10:40:13 7 MR. WILSON:
- 10:40:14 8 Your Honor, I think and I truly
- 9 believe that if the scant evidence, a total lack of
- 10 evidence that Mr. Jackson has shown, if it's
- 11 determined that Mr. Jackson is qualified to run and
- 12 has established residence in Louisiana for two
- 13 years, we need to do away with the election code.
- 14 He says over and over again he was a student, you
- 15 know, that came back to be with his father. But,
- 16 okay, on intent, not one letter addressed any of
- 17 those addresses; not a one. There's no evidence
- 18 linking him to any of those addresses. Everything
- 19 indicates, Your Honor, he resided with his mother.
- 20 As a matter of fact, his mother got his scholarship
- 21 for him because she went off to his recruiting
- 22 service. His father didn't do it. The mother did
- 23 it; so, you know, for him to try to establish this
- 24 link between him and Louisiana right now, Your
- 25 Honor, that had never been established before. She
- 26 talked about his banking account. Isn't it
- 27 interesting? The banking account wasn't established
- 28 until 2013. But I think a key, a key document is
- 29 he's twenty-five years old. He was allowed to vote
- 30 at age eighteen. The first time, the first record
- 31 of this individual ever voting anyplace was
- 32 8-13-2014; and that's what we say the Court should
- 50
- 1 look at, 8-13-2014. I mean there's no evidence of
- 2 his presence anywhere in the State of Louisiana,
- 3 Your Honor.
- 10:41:36 4 I think that the motion should
- 5 be denied.
- 10:41:38 6 THE COURT:
- 10:41:38 7 All right. Thank you, Counsel.
- 8 The Court's going to deny the plaintiffs' petition
- 9 and objection to the candidacy of Mr. Rickeem
- 10 Jackson. The Court will note your objection for the
- 11 record. Thank you.
- 10:41:49 12 MS. VILLIO:
- 10:41:49 13 Thank you, Judge.
- 10:41:49 14 THE COURT:
- 10:41:49 15 And I'll draft the reason for
- 16 judgment for you shortly. Thank you.
- 10:41:51 17 MS. VILLIO:
- 10:41:51 18 Thank you, Judge.
- 10:41:52 19 THE COURT:
- 10:41:52 20 Mr. Wilson, let's make sure we
- 21 have those exhibits that you have.
- 10:41:58 22 MR. WILSON:
- 10:41:58 23 I just have one, Judge, if I can
- 24 find it.
- 10:42:01 25 THE COURT:
- 10:42:00 26 He gave me a copy. But I think
- 27 he marked his. I didn't mark mine.
- 10:42:06 28 (Whereupon, Court was adjourned.)
- 10:42:05 29 * * * * *
- 30
- 31
- 32
- 51
- 10:42:06 1 C E R T I F I C A T E
- 10:42:06 2
- 10:42:06 3 This certification is valid only for a
- transcript accompanied by my original signature and
- 4 original required seal on this page.
- 10:42:06 5
- 10:42:06 6 I, BRIAN P. SALZER, a certified Court
- Reporter, in and for the State of Louisiana, as the
- 7 officer before whom this sworn testimony was taken,
- do hereby certify that RICKEEM JACKSON, after having
- 8 been first duly sworn by me upon authority of R.S.
- 37:2554, did testify as hereinabove set forth in the
- 9 foregoing 50 pages;
- 10:42:06
- 10:42:06 10 That this testimony was reported by me in
- the stenotype reporting method, was prepared or
- 11 transcribed by me or under my personal direction and
- supervision, and is a true and correct transcript,
- 12 to the best of my ability and understanding;
- 10:42:06
- 10:42:06 13 That the transcript has been prepared in
- compliance with transcript format guidelines
- 14 required by statute or by rules of the Board, as
- described on the web site of the Board;
- 10:42:06 15
- 10:42:06 That I have acted in compliance with the
- 16 prohibition on contractual relationships as defined
- by Louisiana Code of Civil Procedure Article 1434
- 17 and in rules and advisory opinions of the Board;
- 10:42:06
- 10:42:06 18 That I am not related to counsel or to the
- parties herein, nor am I otherwise interested in the
- 19 outcome of this matter.
- 10:42:06 20
- 10:42:06 21 _________________________
- 10:42:06 BRIAN P. SALZER, CCR
- 10:42:06 22 Certified Court Reporter
- 10:42:06 #87015
- 23
- 24
- 25
- 26
- 27
- 28
- 29
- 30
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