>> do what point? >> would you describe her as your friend? >> i would say we are friendly. >> you would stop short of saying she was your friend. >> i met the candidate's wife, and we were friendly. >> i assume you notice english is not her first language. >> yes. >> how would you characterize her verbal english abilities them up >> is good. sometimes i witnessed a couple of confusion miscommunications because of language. >> did you have an opportunity to see her written english? >> never. actually, one time about a halloween parade or something about the campaign. >> did you notice anything about her written abilities? >> you could tell english was

not her first language. >> did you ever go out socially with miss lopez? >> never. >> did you ever tell her about your professional or personal background? >> one time we chatted, and we were talking about her passion anti violence work in venezuela, and i shared a little bit about mine. >> what did you tell her? >> basically i shared her passion for women's rights, and she did some anti homophobia work as well, so i shared my passion, and i let her know i worked in the field of domestic violence and also human trafficking, international. >> tell me about your domestic violence works. where did you get that background? >> i work for abused women, and

that is a domestic violence agency that serves primarily latino women, and i was a volunteer coordinator and community education coordinator. >> how long did you work there? >> i think it was a year and a half or two years. >> when was that? >> the mid to late 1990's. >> you have any formal training in domestic violence? >> we went through a 40-hour course through the state of california. >> you have a certificate in domestic violence? a tax from back then, yes. >> the you have a name on the certificate? >> it is domestic training that most of them have their volunteers go through. >> what do you remember telling

this web about? >> i did not go into details. i just said i worked in the field of domestic violence. i served as a consultant. i was a consultant for domestic violence and how the empowerment class -- the healthy empowerment class. i tried out the curriculum, have it finalized. i think it was early 2000. >> who were you working for at the time? >> it was for the sisters. >> with that amount of contact with the issue of domestic violence, is it fair to say you are familiar with recanting victims?

they often recant their work. are you familiar with that? >> objection. >> overruled. betsy you agree they should be prosecuted even if they did recant. -- >> do you agree it would be prosecuted even if they did recant. >> you may answer the questions. >> yes, i do. >> are you familiar with the power and control wheel? a fax absolutely. >> you are familiar that physical abuse is characterized by relationships with the emotional abuse? >> and verbal abuse.

>> did you communicate by phone december 31 reading or by tax -- by phone or by text? \ >> i only have 3 communications. those were happy new year, and the other two texaxts were lettg him know if he had not found the chief of staff i may have a good recommendations. >> did you communicate about anything else iphonby phone. >> no, i did not. >> did you communicate by e- mail? >> i did not. >> at that time did you sometimes communicate by e-mail

n.y. democrat said what time did? >> the time when you were working as an -- communication by e-mail? that said what time? >> when you were working as a campaign manager. >> i think the question is vague as time. >> it is kind of vague, so maybe if you want to ask everything. >> i will ask if separately. did you communicate with share ref mirkarimi by e-mail between december 31 when january 4? >> i did not have any e-mails. >> did you routinely communicated by e-mail while you were his campaign manager? >> not really. it was in the campaign office while we were working, and some phone calls and texats.

but did you ever communicate by e-mail? so. what did you ever have miss webb's email address? >> it was either halloween or a fund raiser, and i responded to her. it was prior to december 31. >> i was asking whether you ever communicated with the share of by e-mail and i followed up with whether you ever communicated with miss lopez by e-mail. >> those were the only two instances i ever communicated by e-mail. >> the mayor a subpoena in your documents-- mayor supboenaed

your documents. >> yes, he did. >> and the court ordered you to produce any records in your control that were between anyone in regards to the incident and the subsequent police investigation and prosecution. isn't that correct? >> i am not sure about the question, but i would object on relevance. >> what is the relevance? >> i am asking about documents she is not able to provide, and i am establishing a foundation of the court ordered her to provide them. >> i would overrule the objection. i would caution the witness not

to reveal any communications you had with the council in your answer. >> the court excluded attorney- the court ordered you to produce your records in regard to the incident and the subsequent police investigation and prosecution of ross mirkarimi, and that included your e-mails as well as any other documents you might have? >> yes. >> did you do a search for such documents? >> yes, i did. good >> what did you produce? >> i did not have any e-mails during that time. what is the time, december 31 through the first or the 14th?

>> objection. >> sustain. >> would you like to review the court order? >> i am asking what is the time? >> there is nothing to refresh. >> what did you produce in response to the court order? >> overruled. there were documents the and were produced. the fact the documents were produced is not -- there were documents that were produced. the fact that they were produced is not privilege. your objection is overruled. = period they ask me i produced whenever i had, so i think it was two e-mails that i do not think were that related to the case, but i forwarded to

. >> did you only search for documents within a certain time period? >> i think i put a search for all of the documents, and that is what i had, and it was during that time period. >> we know from documents there were texts in regards to these topics that you did not produce to us, and i am wondering if you can tell me why. >> objection, there is no foundation. >> overruled. good >> answer the question? >> answer the question please. >> in terms of texts, i erase them on a regular basis, so by

the time they asked me i had already erased those texts. i did not have anything. >> you also erase your e-mails? oo by the you embrace all of your taxes -- do you erase all of your texts. >> business and a lot of personal ones because it takes up a lot of room. >> how long do you wait? >> sometimes a week. >> you have routine time that you go in and raise your -- and erase your texts. >> yes. >> you put it on your calendar? >> no. >> you have texts that go back

to more than a week ago? >> objection. >> sustained. i would move on. >> since we did not get the documents, i am going to have to rely on your memory. the new tax to anyone else besides ross mirkarimi and ilion a lopez about the incident and the prosecution of the ross mirkarimi? >> not to my knowledge. >> you did not text with political consultants, board members, media contact salmos? >> absolutely not. >> your declaration states met lopez contacted me, and i had

several phone conversations regarding of domestice3dd? related incidents that have occurred with her husband, ross mirkarimi. does that sound right? >> yes. >> if my technology was working i would have this electronically. it is an attempt to take the first stagpage of exhibit 83, ad that is something all council has agreed 0 that compiles communications between a number of people on january 4, and it is all communications we are aware of, texas, phones, e-mails -- texts, phones, emails, and the people in records from are

ross mirkarimi, you, and kellie williams, so that is what exhibit 83 is, and there are seven pages of small text lines, so i have tried to pull some of these out. if you want to take out your binder. >> ok. >> exhibit 83 is there in full. i just want to know that in case you want to double check some of the things i am highlighting to make sure if you have any doubts about their accuracy. the first box is a series of

texts at 10:55 from lopez teto you, and another at 10:56, but , we do not know what the context is, so i am wondering if you remember. >> i vaguely remember. she let me know she had an argument with ross and that she wanted to talk with me. that was the gist of its. >> had she ever confided her personal affairs with you before? >> never. >> were you surprised to get these text messages and? >> yes. >> did you have any idea she was going to do this to? >> no. >> you recall the wording? >> i do not remember.

>> you remember there was an argument she wanted to talk to you about with her husband? fax yes. >> if you look down, there are some phone calls that i want to ask you. do these phone calls follow as a result of the text messages? >> yes. >> the you remember what you costs -- what you talked about? >> i do not remember. also, where i live we have really bad phone service, and the phone constantly drops, so sometimes somebody will have to call me four or five times for us to actually connect. >> according to the exhibit, can you tell me how long you and miss lopez spoke during the 11:00 hour?

40-minute phone call. we did talk on the phone at length at that point. >> what did you talk about 77? >> when we talk to each other, she told me she had an argument with ross, and she told me it was an argument about going to venezuela, and it ended up with her having a bruise on her arm9. >> did she tell you it was not the first time he had hurt her? >> she did not tell me that. >> did she tell you how do yo -- tellyou theo was present and crying. >> not at all. >> did she tell you the argument only happened in the car or at

home? >> she only told me about being in the car. >> did she tell you sheriff mirkarimi had to threaten her with custody because he is a powerful man? >> she did not say that to me. >> sorey, a paper shuffli- sorry, paper shuffling. did she say that she shouted very loudly in her house so her upstairs neighbor could hear the fight? >> she did not tell me that, no. >> how did she describe the physical contact? >> she did not go into detail. she mostly talked about the argument about going to venezuela and that they yelled at each other and that she got a

bruise, but she never went into any detail with me. >> did she tell you where the bruise was? >> on her arm. >> did she tell you about it now? >> i do not remember. >> it would be consistent that she could have been talking about a very small bruise? >> objection, that calls for speculation. >> overruled. >> she said a bruise on her arm, so i did not know what size it was. she did not go into detail. good >> did she tell you the share of -- a share of -- the sheriff repeatedly grabbed her? >> no, she did not. >> did she tell you how long the

>> did she tell you she ran into the street to escape a fight? >> no, she did not. >> i know you already answered, but i forgot. did she say whether or notñv& o was present for the fight? >> i do not recall that, so i am sorry. >> did she tell you share of mirkarimi -- sheriff mirkarimi was talking. >> she said he was yelling. >> did she tell you she recorded it on her mobile phone? >> she did not tell me. >> did she tell you she was on the way to lunch but that he turned the car around to go home? >> she did say they were going to lunch, but she did not say anything about going home. >> were you under the impression the fight happened at the restaurant? >> my impression was the argument happened at a car, and

she stepped out of the car and they were yelling back and forth, and she got back in the car. >> you were not clear whether or not theo was in the car? >> i honestly do not remember. tracks did she tell you she had been talking about this incident -- >> did she tell you she had been talking about this incident with a neighbor? >> she told me she was really worried about custody issues, and she was talking to a friend who is an attorney. >> did she say this was her neighbor, or could she have been referring to someone else? perhaps she just told me a friend who was an attorney.

she did not tell me this person's name. she just said a friend who is an attorney. >> what do you remember about how she described this friend or what they were talking about? >> she did not go into details. >> did she ever mentioned she was talking to a neighbor specifically? >> she did not say that. she said a friend. >> did she tell you she made a video document in the bruce -- documenting the bruise. >> she did but later in the day, not during the phone call. >> about when? you remember? parks i think think it was latee afternoon. i do not know if it was around 5:00 or 6:00, sometime later that day. >> did she describe the video? >> no, she did not. >> did she describe the video or say who shot it >> no, she did

not. she said she had a video in case she needed it for custody issues. >> did she tell you that on the same day that share of mirkarimi -- sheriff mirkarimi and eliana lopez did that, that they were going to look for a therapist? >> no, she did not. >> did she say that theo w6éht)r concern? in regards to that incident >> no, she did not. >> did she tell you that he grabbed her arm? >> no, she did not.

>> did she say that the person who shot the video turk -- told her what to say in the video? >> no, she did not. >> did she say that the person who shot the video told her to go tell her story to a different neighbor? >> no, she did not. >> did she tell you that the person who shot the video advised her to accuse the sheriff of domestic violence so that she could get custody of theo? >> no, she did not. >> did she tell you in that conversation that she believe that ross was a good person >> in the 40-minute phone call?

>> yes. >> she did tell me that she and she wanted to make it work, but she said just in case, she wanted to make sure that she got custody of the notwú-71 -- of - of theo. >> did she say how she was going to do that? >> she wanted to have counseling maybe, some counseling with both of them,wl+h> >> i am sorry. i did not hear you. could you repeat it? marriage counseling, but it was not in that 40-minute conversation, if i remember correctly. >> and thatc+txéq to make her marriage work, marriage counseling prove >> she just mentioned it. i do not know how she was going to make her marriage work. i just know that she mentioned

it. >> and did she tell you that she had any kind of strategy and that keeping custody of theo if the counseling did not work? >> she said the video. her friend made a video, and just in case, which was later in the day, she told me that she would have it just in case, but it was your kind of property just in case she needed it. >> your declaration goes on to say, and we talked about some of this, i have that training regarding domestic violence, and my primary concern, this is the discussing the phone call we were just talking about, my primary concern was to address the situation and determine whether eliana was in any

danger. what did you think there would be danger of could >>=wsfws÷ wef somebody is grabbing you and there is a bruise, i want to see if there is something, and if so, i will make some referrals and support the person with what they are going through. >> show you, if i understand you correctly, you wanted to know if this was domestic violence said you could make a more accurate determination if she was in domestic violence? >> i wanted to support her. she was obviously giving me a call in the middle of the day, something she does not do, and she tells me there was an argument and that there is a bruise, and she;ç[ñaq wanted soe support, and i wanted to give it to her, and i was fully present. >> i still want to know what kind of danger and you thought she was in. >> i think the declaration states that she was satisfied

she was not in danger. >> i will hear your argument. >> the declaration says, "my primary consideration was to assess the situation and determine if eliana danger." i have been trying to understand what danger she was concerned about. >> overruled. >> i will ask a new question. what is the nature of the danger you were concerned she might be in? >> for me, it is asking the person if they feel they are in danger. somebody can say they feel they are in danger physically or emotionally, so it was basically an open ended question to just kind of explore for her if she did feel she was in danger, and after talking to her, i determined that she was not. >> my question was what were you concerned that she might be in concerned that she might be in danger of?