whether you want to cross examine ms. madison based on what you learned so far with respect to the objections.>> mye portions of the declaration that i shot -- thought should be excluded were excluded, i did not intend to cross. chairperson hur: with respect to the statements made to ms. madison by ms. lopez of coffee -- ms. lopez, we have under rule that a lot of those. you are saying you would not want to cross-examine? >> yes. chairperson hur: ok.

the proposal to simply permit ms. mattison to testify and handle commission views on her declaration -- i would welcome the thoughts of my fellow commissioners on that. >> i would be fine with that. that would be a fine way to proceed. that would be a fine way to proceed, we think. >> if mr. kopp does not want to cross-examine ms. mattison, given what is in and what is out, we may not need her to come

in at all. chairperson hur: that is kind of what i was thinking, mr. keith. >> i think we can try to do this on paper. if we come back, we can go to the rest more quickly. >> i should relate to the commissioners that i, about a half an hour before the hearing, received a call from an attorney who identified himself as ms. madison's attorney. for what it is worth to the commission, he expressed a concern by ms. madison about her continued public involvement in this proceeding, and wanting to minimize that. ok. in wanting to minimize that. chairperson hur: here are my competing concerns with this

issue. i am cognizant that objections to the rest of this declaration may be so general that they may not really help us actually that said, i really do not want to inconvenience the witness. finally, i am reluctant to push off testimony, if we need it, from miss madison, further than the days we have allocated in june. it seems to me that written objections would virtually necessitate that. although maybe not, now that i am thinking about this out loud. perhaps we could subpoena ms. mattison to appear. we will take the written objections. if they are hopeful and we can resolve the issues with the

declaration, miss madison could appear, and if mr. kopp does not want to cross her, we would excuse her. if we determined it would be more efficient to simply proceed with direct, we would ask that you be prepared to direct examine her. you could decide after that if you want to conduct cross- examination. >> that is a possibility. as a reported one we had a conference call regarding scheduling, my understanding is that the council is unavailable to the 30th and once you have the opportunity to prepare his client, if she is going to testify. there may be other testimony issues with ms. haines as well. it may or may not be possible to finish by the 29th. i know that taking a witness out of the question gets us there faster.

i would like to take a good run at trading objections, meeting, and conferring, and trying to bring back those objections. this is this type of testimony, so we can get some quick rulings on the 28th. chairperson hur: i propose to do submit objections, and that you respond to them. when can you submit objections? >> to be safe, not before monday. i can try to get in before then. chairperson hur: how about friday? >> i do not want to promise something i cannot deliver. if i can, i am happy to get those objections to the parties. i would much prefer monday.

even if it was monday early, so i could have the weekend. chairperson hur: are you comfortable, if miss madison testified, that it occur in july? you have been pushing for the schedule. i want to be clear that you are fine with testimony occurring later. >> i think we are probably going to have to agree to that, unfortunately. if it does turn out that, according to a her attorney, she can not be available before july 9 -- i do not know if that is because she just had a baby, or there are scheduling reasons. unfortunately, it sounds like there is going to be one date in july where there may be witnes'' testimony. chairperson hur: that being the case, i have no objection to monday, the 25th.

mr. keith? when can you respond? >> i am trying to build in time for us to meet and confer, and bundle the objections, so we can hopefully bring five or six for the commission to rule on, instead of 20. chairperson hur: it would be greatly appreciated. >> it will be hard, if i do not get them until the 25th. but i understand that we all have other cases. if i get the objections by the 25th, i could probably respond to them. if the commission is going to decide these on the 28, i think i need to get them on the 27th. and we would meet and confer. we would have something to say, here is the package of objections. >> but if you got them at 9:00

a.m. on the 25th? could you get them to us by close of business on the 27th? >> sort of an objection, response? that would work. commissioner renne: why is it that you cannot sit down tomorrow with a declaration in front of you, cross out all the lines you do not want in, i mean -- i practice law a lot longer than you. my sense would be that you could do that in the space of an hour. i really believe you could do it in the space of an hour.

cross out everything you think should not be in. give that to mr. keith. he can say he agrees or disagrees. i do not see any reason why it takes weeks to do something on a piece of paper you have gone from page 8 and 9 now. you have 13 pages left. i appreciate that you have other cases. i am sure your client believes that his case is number one. i believe the mayor believes his case is number one. he wants to get it done. >> i appreciate your confidence in me. however, if i were to say i could have this done by close of business tomorrow, or even early thursday, and i am able to do that, i do not want to commit

to a schedule i may not be able to make. i will tell you -- can i and -- commit to friday? would that make everyone happy? commissioner renne: it might make some, but it would not make me happy. it seems to me that if i can get it to mr. keith by sometime on friday, sooner rather than later, that would solve the timing problems, would it not? chairperson hur: in light of that, when would you be able to get us in the -- >> if mr. kopp is available to meet on monday afternoon, we could try to get it on tuesday the 26th. chairperson hur: do we have a

midnight deadline in this case? the same midnight deadline applies. that is for both. >> understood. chairperson hur: does that cover all of the -- >> i am not clear whether you would like me to prepare a subpoena for ms. mattison and ms. martin to appear next week, in light of what you've just heard. chairperson hur: i understand they are represented by the same party. the same lawyer. is that correct? and he is with a firm, correct? i think we can handle this one of two ways. i think the commission can

subpoena these witnesses. i appreciate the attorneys desire to be there. but if he has partners at the firm, i do not have qualms with requesting the appearance of the witnesses with the other attorney. that said, if we are going to have additional testimony in july, i do not want to unnecessarily inconvenience the witness. i think we could handle this one of two ways. we could subpoena her for the 29. rule on the objections on the 28. if it turns out we do not need her on the 29th, we could release her. or we could rule on the objections on the 28, and then make a decision as to whether to subpoena her for a different date in july. i welcome the views of the parties on the proposals.

>> we prefer the latter, out of consideration of the independent witnesses and their counsel. i think if we are going to have a hearing in july anyway, we might as well wait until july to see if it is necessary. >> it might force some of these issues by subpoenaing these witnesses for the next hearing. i do not necessarily have a strong view. i do not know how to interpret what was said, but it makes me wonder whether this witness, if subpoenaed, will appear. the sooner we know that, the better. >> from my communications with mr. roberts, i do not have any indication she does not intend to appear. i am just relating what i know. >> i did not get any indication to that effect. >> commissioners, views on whether we should subpoena on

the 29th, or whether we should await resolution of the objections prior to doing so? >> the information we have is that the attorney for those witnesses is not available until sometime in july. >> he did not express that? >> he did express that to me. he is not available the last week in june and the first week in july. >> i think that is in this -- is ms. haynes's unavailability as well, or her counsel. chairperson hur: in light of that, i think we should withhold issuing a subpoena for ms. madison, as of now.

unless there are dissenting views, i do not feel particularly strongly about it. does that address all of the objections to the mayor's fact witness list? i am sorry. we did not address ms. williams. i think, with ms. williams, because the issues are similar -- it is a shirker declaration. we could go through it, if the parties wanted to. or if you think it would be helpful to meet and confer, so you can reach whatever

stipulations' you may be able to reach with ms. williams that result from your discussions of the other witnesses. we might be happy to hear that, too. >> i could offer that i would be willing to prepare my objections and submit them at the same time as the other objections to the merchants and madison declarations. >> you submitted objections to williams already. >> thank you for reminding me. if they needed to be expanded upon, if we needed to meet and confer, we would be willing to do that. otherwise -- commissioner liu: i do think it might be useful, rather than

general objections to mostly all of the paragraphs. >> i am sorry. you are saying that i could the tell the objections with a bit more specificity to particular sentences within paragraph stacks -- paragraphs? chairperson hur: -- commissioner hayon: -- commissioner liu: correct. >> i suspect there will be fewer issues than with ms. mattison. we may be able to get through it very quickly. chairperson hur: if we dealt with it tonight? >> i would suggest going through right now. chairperson hur: we can give that a shot. i think we need to take a quick break. the court reporter certainly needs a break. let us take 10 minutes. we will then resume. we will start with ms. williams and see how that goes, and then

we will try to address objections of the other party.