in your declaration at paragraph 13, you write that you sponleded to ivory, and i'm quoting, very briefly and not as nicely as usual because i realized ivory was calling ross' enemies against my wishes. what brought you to the realization that as of 12-24 on the fourth ms. madison was calling your husband's enemies against your wishes? >> in our conversation on january 4 when she was trying to convince me to call the police, and she said, we can bring district attorney here, phil brownstein, the chief of police, she also mentioned pamela harris an also mentioned

gavin newsom as her friends and someone who is going to help to do everything against ross. and also she was repeating in our conversation in january 4 and why i was -- the only way i could get out of her house, was saying i have to call my dad is because she was telling me, screw him. at that moment, actually, i didn't know what that means. but looks to me so suspicious that she knowing how hard we were working, even me campaigning with ross without any money, she was calling ross' political enemies. and everyone knows, even me, that i was not really involved, i was helping just giving papers and telling the people

vote for the sheriff, but even me, i know that gavin newsom, pamela harris, they were supporting the other candidate and they were putting a lot of money against ross. so what i'm going to think. immediately i realized i cannot draft her. and also was something that was very shock to me, when i was leaving i was in pajamas because on january 4, i was preparing theo for school and ross took theo to school and i was in pajamas when she called me. i went to her house in pajamas, i love to be in pajamas, by the way. and she told me, don't -- and she told me that in front of eight persons.

don't take a shower, don't make up, don't do anything, look that -- and that was another new word for me that day, disshoveled as you can. ok, go to talk with your daddy, that was the only way i could left her house. don't do anything. >> ms. lopez, i'm going to actually stop you. this is not an answer -- >> sorry. >> to the question. mr. keith, please proceed. >> ms. lopez, earlier you mentioned that ms. madison was advising you to call the police? >> that was that i told linnette. >> ok. but then your declaration you say you realized she was actually calling your husband's political enemies against your wishes. >> yes. >> what new information did you get or -- >> that i didn't -- >> what new information did you get around that time that ms.

madison was out there calling your husband's political enemies. >> that's asked and answered. >> mr. keith, last time you asked that question you got a very -- i think you got a pretty detailed answer. what are you -- >> i don't think i got an answer to the question that i asked. that's why i'm asking the question in this way. >> i'll withdraw the objection. >> ok. ms. lopez, please proceed with your answer. >> repeat the question, please. i feel the same, don't worry. >> if the court reporter could read back the question. [the court reporter read back the last question]

>> i see you are trying to make -- when i talked with linnette, i was having a conversation with linnette about her opinion, when i was talking with ivory, i was talking with her and realizing the things that she was doing, but i didn't share that with linnette. also, i didn't -- and also i talked with my dad and my conversation with my dad was not about that, was about other things. father-daughter relationship, with linnette, domestic violence advocate information. ivory, she wants to call the police and call political enemies. so was absolutely three different conversations. and i didn't told linnette all

the information about phil brownstein or pamela harris, gavin newsom, all this. i didn't share that with linnette. >> ok. now, do you think ivory madison is trying to get your husband politically? >> well, a person who said screw him, i have a lot of friends ready to help. they just need to make the decision what that means. >> do you think it was ivory madison's goal to ruin your husband politically? >> i have to object, relevance. >> ms. lopez has made it relevant through her declaration. >> overruled.

>> i do not think that, because on january 1, that was not her plan. >> but on january 4 it was her plan, you thought? >> she was telling me screw him. that is not let's work on your marriage or something positive. >> ok. was ivory madison donating the maximum amount by law to your husband's campaign part of her conspiracy to get him. >> objection, it's argue meanttive. >> sustained. >> ivory madison hosted a fundraiser for your husband's campaign. >> objection. that's not a question. >> mr. keith, please phrase it as a question. >> did ivory madison host a fundraiser for your husband's campaign?

>> we put her name in the cards but she didn't do anything. >> she donated money to the campaign? >> she told me that, yes, but i don't have any proof about that. >> ok. >> now, you spoke to cali williams later on january 4. >> yes. >> did you tell any lies to cali williams when you spoke to her on january 4? >> i don't think so. >> your husband came out while you were talking with cali williams? >> yes. >> you were on the back porch? >> yes. >> ok. you told cali williams you thought your husband was scared that you were talking about what happened on december 31.

>> i do not recall saying that. i think -- >> so you didn't say that? >> yes, maybe i said something like that. >> ok. and did cali williams tell you that you were brave not to keep quiet about what happened with your husband on december 31? >> i think that is in her declaration that was -- that were not her words that day. >> so she didn't -- it's your testimony she did not say that to you? >> i do not recall she saying that. >> do you recall that she definitely did not say it? >> i do not recall she saying that. >> do you remember one way or the other? >> saying again -- say again the words? >> i'm trying to remember if you just don't remember she

said it or if your testimony is she definitely did not say that? >> i do not remember she says what you said that i don't remember what you say already. >> that you were brave not to keep quiet about this incident? >> i do not remember she saying that. >> ok. >> is cali williams part of a conspiracy against your husband? >> objection, argumentative. >> do you think cali williams is out to get your husband? >> calls for speculation. >> sustained. >> do you have any information about cali williams that would suggest she has a vendetta against your husband? >> did something suggest to me about cali williams? >> do you know any facts about cali williams that would indicate to you --

>> yes, i actually have -- >> ma'am, let me finish my question. >> key facts. >> let's -- >> ok. do you have any facts about cali williams that would indicate that she has a vendetta against your husband? >> i know she was not happy with ross. i know she told me that she -- he was not helping her or something like that. i think she -- she's always doing -- [inaudible] if she has permit for that or not but she's always doing that. and something happened between ross and her shall she looks

like she put money and ross was not agree with that money and he didn't want to pay wg, something like that and she brought that day in the back yard porch. and she said i'm not happy with ross. >> she said that during that conversation? >> yes. >> in which you discussed with her? >> yes, and they brought that about the money. finish, please. >> you did discuss with cali williams what your husband did on december 31? >> yes. >> now, in your declaration you testified you went to speak with cali williams because ms. madison had advised you to talk to cali williams? >> yes. >> ok. and you spoke with cali williams around 1:00 in the

afternoon? >> yes. >> that was after you sent the text message to ivory madison? >> i do not recall that, i think, yes. >> so ms. lopez, if you thought ivory madison was calling your husband's political enemies, why did you follow her advice and talk to cali williams? >> oh, because at this point i didn't know she was -- no, i did -- at that point i knew she was -- she was using -- i do not remember if at that point i knew she was using our names.

when i found that -- maybe i knew at that point that she was using our names. on january 4. that i understood she will never call the police without my consent. so i was trying to be clear on january 4. i do not want to call the police. i want to call a therapist. this is what my emails are about therapy. >> so when you decided to go out and talk to cali williams, at that point in time, did you think ivory madison was out there calling your political enemies -- your husband's consent, or did you think that ivory madison wasn't going to call anybody without your consent? >> you are right. very tupeid. i think we were -- for me saying we are not going to call

the police, i'm not going to call the police, that plan doesn't work. so let's go back to the first plan, who was in case ross doesn't want to do therapy with me and finally we end in a vorgs, she will help me with the -- in a divorce, she will help me with the custody. so for that thing she told me, do you think cali williams heard something about the fight? and i say, i know she was there. in her declaration she said she was not there on december 31, but in her email to me and also that day, she told me, i didn't hear anything. and i say, sure you didn't hear when i say stop? because i think i was very loud. no i didn't hear anything. ok. >> so when you went out to talk to cali williams, did you think

that at that time ivory madison was calling your husband's political enemies? >> well, she did in the morning , and i was -- you know what? for that moment i completely forget the video. i was really very naive in believing ivory and believing that she will never do anything against my wishes, and i want just to go back to the first plan. >> so when you went out to talk to cali williams, you didn't think that ivory madison was calling your husband's political enemies? >> no, i already knew that. but i didn't think that if i don't decide to call the police, she will never do anything. nobody can do anything. >> ok. now, was there any other -- well, let me step back for a minute. why were you surprised that

cali williams wouldn't be able to hear what happened on december 31? >> you have to go to our home. i can hear her dog snoring. i can hear she watching the tv. everybody goes -- we live in a victorian house, that it doesn't happen in isolation. so all the people has been in my house, we hear -- they say you have an elephant up there? and is she walking? and i never called the police or complain to her because it's not her fault. so i can hear her dog snoring, i can hear everything she does. so of course i thought she heard me saying stop. because for me i think i was very loud. >> so you thought she heard you say just a single shouted word stop? >> yes. >> ok.

>> mr. keith, we're about at your time estimate, or i guess it wasn't really your time estimate, it was my imposed time estimate. how are you doing, though, on -- >> i think i'm moving along. i mean, i -- it's hard to tell how much longer it's going to take. i'm far more than halfway done, i can say that much. but i don't know whether i'm 2/3 done or 3/4 done. i'm giving the best estimate i can. >> ok. well, you did say 2 1/2 yesterday. i think we're going to hold you to that. i understand you should get a little bit of leeway because i know you and the witness have not been communicating that well on certain issues and you've gotten answers you didn't ask for. but i mean, i don't think you

should expect to go another hour. >> i don't think it will take another hour. >> yeah, well, i'm saying i think you should plan to wrap up in 30. >> i think it's going to take longer than that. i'll go as fast as i can. >> you'll go -- i mean, we have a lot of discretion to how much testimony. we've heard a lot. if you've got -- don't save your very best for last if you don't think you may -- you may not get there. >> ok. ms. lopez, what time on december -- on january 4 did you find out that there was a police investigation of what your husband did to you on december 31? >> on january 4, around 3:30.

>> ok. and was that when ivory madison told you? >> yes. >> ok. did you have any inkling before 3:30 there was an open police investigation? >> as a good friend and as a good lawyer, she waits three hours to let me know she opened an investigation. i think she was really taking care of me. >> i'll move to strike that response. >> sustained. ms. lopez, you need to answer these questions. >> ok. no. >> and were you on the phone with linnette peralta haynes when you found out from ms. madison there was a police investigation? >> no. >> how long after you found out there was a police

investigation did you get a call from ms. peralta haynes? >> i cannot tell you how long. we -- i don't know, maybe 10, 15 minutes. >> ok. and where were you when ms. peralta haynes called? >> in the stairs of ivory madison's house. >> interior stairs? >> interior, yes. >> and how long did you speak with ms. peralta haynes beforehanding the phone to ms. madison? >> i do not remember, but i just was so panicking and i said to her, my neighbor called the police and i was -- and when i hand the phone to ivory, i was trying to someone speak

in english maybe could explain better that i do not want the police involved. >> so you don't -- >> so i just say help me, help me talk with this. she called the police. >> so you don't know how long you were talking with ms. peralta haynes before you handed the phone to ms. madison? >> how long i was talking who with who? >> with ms. peralta haynes before you handed the phone to ms. madison? >> how long i was talking with ms. peralta haynes? how long it takes to say -- 30 seconds, one minute. >> ok. and what did you hear ivory madison say to ms. peralta haynes? >> i really was trying to pay attention but i couldn't understand anything ivory said. i was so shaking.

>> ok. after ivory madison handed the phone back to you, what did you do? >> i do not remember exactly why i -- what i told linnette. i think i told her call ross. let him know what is happening. and goodbye. >> ok. and did you tell ivory madison that you were concerned for your husband's career at that time? >> she was repeating screw him and why you trying to protect him? so i said, i do not want to screw him. he's a great politician. >> ok. >> how i am going to destroy him -- >> did you ask ivory madison to tell the police she made a mistake? >> i told her i did not recall

exactly what i said because i was almost crying. >> ok. did you tell her not to cooperate with the police? >> i remember saying you don't have my permission to do this. i trust you. i trust you. >> ok. now, i want to look -- i want to go over some emails and text messages that you sent that afternoon. i want to give you exhibit 5 8.

so this is an email message you sent to ms. madison on january 4? >> yes. >> ok. now, phone records that are already in evidence are exhibit 8 3 shows before you sent this message to ms. madison at 4:14 you had a call with linnette peralta haynes that began at 3:56 p.m. and lasted 15 minutes, 36 seconds. in that phone call with ms. peralta haynes, did you discuss sending an email to ivory madison? >> when i left ivory madison's house, i was so shaken that i couldn't find my car. so i was walking on the haith street to city hall and calling

ross, calling linnette, calling ross, calling linnette. and then she answered and when i was talking with her and say oh, my gosh, she had a video, goodbye, goodbye, i have to call you back. and then i wrote an email like you don't mess this -- this email. and i really hope you respect my feelings. >> you don't remember having a phone call with linnette peralta haynes that lasted 15 minutes and 36 seconds before sending this email to ms. madison? >> yes. that phone call was 15 minutes when i was talking with her, i just realized that the video was in -- she had a video so i closed the conversation and i wrote this. >> ok. so in the phone call with ms. peralta haynes, did you discuss sending this email to ms. madison? >> no.

>> ok. and i'd like you to look at another exhibit, exhibit 5 9. and the phone call says you had another conversation that lasted one minute and 20 second. and this email that's exhibit 5 9 was sent at 4:16 p.m. right after that call. >> uh-huh. >> did you discuss sending this email with linnette peralta haynes? >> no. no. actually, i wrote this email around 11:00 but i didn't send it because i think she will

respect me, so that was already wrote in my -- >> and when you wrote to ms. madison, i've been calling social workers, therapists and lawyers, had you in fact been calling other lawyers the morning of january 4? >> no. >> ok. and did you write this email before or after you spoke with linnette peralta haynes that morning? >> i wrote this email around 11:00 p.m. 11:00 a.m. >> ok. and that was the nice way to tell ivory i don't need your help anymore. >> did you write this email before or after you spoke with linnette peralta haynes in the morning for 40 minutes? >> i do not remember. >> ok. now, when you spoke with linnette peralta haynes, did you discuss your husband's childhood?

>> i mentioned that. >> now, in either of the calls that you had with linnette peralta haynes in the 4:00 to 4:15 time frame, did you share your feelings with ms. haynes about the fact there was now a police investigation of what your husband had done to you on the 31st? [discussion with interpreter] >> i'll say it another way. >> rephrase, yes. >> in the phone calls around ms. her alta haynes around 4ing -- ms. peralta haynes around 4:00 p.m. in the afternoon, did 4:00 p.m. in the afternoon, did you ask her for advice about