james madison's senior -- james madison junior, our hero, president, james madison jr. was the member of the anglican vestry. we know he attended church through his life and went to church right across from the white house today. recently on television i saw president obama and his family coming out of the church james madison used to attend so through his life he did attend church. when he was a young man he was uncertain what he wanted to do for a career. after he completed his undergraduate studies he stayed on as a graduate student for a year where he saw among other things hebrew and the only practical application of hebrew for a president -- protestants from orange county would have been to become a minister but apparently he decided at an early age he did not want to be administered so he turned to the idea he would become an attorney and he studied law which after a few weeks he described as exceedingly dry and i can say yes. it is exceedingly dry. he had absolutely nothing to do with drafting the declaration of independence because he was helping draft the cons

madison. as she was hurried out of the white house, she made certain to sit down and write a letter to her sister. she describes the flurry of activity that happened just prior to her leaving. our kind friend, mr. carol of dumbarton house has come to hasten my departure. in a very bad humor with me because i insist on waiting until the large picture of general washington is secured. it requires to be unscrewed from the wall. the process was found to be tedious for these perilous moments. i've ordered the frame be broken and canvas out. it is done. and the previous portrait placed in the hands of two gentlemen from new york for safekeeping. one eyewitness account also describes the scene of washington as from his hotel room, i perceive the smoke coming from the windows of the president's house and in a short time that splendid and elegant edifice reared at the expense of so much cost and labor inferior to none, what i've observed in the different parts of europe, was wrapped in entire flame. th

born on james madison's virginia plantation, he served as a footman during the madison administration. during the war of 1812 helps dolley madison rescue the iconic portrait of george washington from british torches. after 20 years back on the plantation where he was body servant to the ex-president, jennings returned to the square with the widow dolley madison. she had a house on the square's northeast corner where she would live out her widowhood like a queen dowager, presiding over a secondary court to the white house. jennings, her butler and coachman would have a second white house experience beginning in 1845 when his mistress hired him out to president james polk. when dolley madison died in 1849, jennings had spent just the last two of his 50 years as a freeman, little thanks to her. she had offered him for sale for $200. jennings knew people in high places and he had gotten daniel webster, formerly a neighbor on the square to advance him his purchase price. he was working for webster paying off his debt when his former mistress died. she was given the grand estate funeral to

madison is stating her interpretation of what ms. madison said. sometimes we have a conversation and we get an impression. she's repeating her impression. obviously, she wasn't there. but she is certainly able to get her interpretation of what somebody else said and the gist of what was being conveyed. i mean that was -- that's standard conversation and communication. >> i would be inclined to overrule that objection. any decenting view from the commission? >> no. >> mr. kopp? >> yes. then online seven to line eight, the sentence beginning with i and finishing with the word am more prejudicial than probative, irrelevant. >> well, i actually don't have a problem with striking the last block of the sentence. three minutes over? the micro phone. the part whether and i still am. that's not relevant. but what i do believe is relevant, i is it explains why ms. madison took the action that she did, the concern that she had and that prompted her to take the actions that she took. >> i would be inclined to sustain the objection. the last part of line seven

you are saying this -- miss haynes told you she said that to miss madison? >> that is what i recall. >> ended -- did miss haynes express an opinion of what she thought about miss madison calling the police? >> no, except she thought it looked like she was trying to hurt eliana, she did not know what was going on. >> did miss peralta haynes expressed concern about the impact on you of a police investigation? >> yes. >> what did she say? >> to be aware that this is happening. she did not really have to say anything, just myself i knew it would have impact. >> sheriff, is domestic violence a laughing matter? >> of course not. >> when people joke about domestic violence, they devalue victims. >> i think so. >> when people joke about domestic violence, they make light of the serious crime. >> objection. >> overruling. >> rephrase, please. >> when people joke about domestic violence, then make light of something that is a serious crime. >> yes. >> you made a joke about domestic violence at your inauguration. >> assumes facts not in evidence. >> i do not joke about

madison? >> we will not offer testimony by miss madison. we will make the decision after we see the declaration if we want to request she appear for cross-examination. we do not think she is a necessary live witness. chairperson hur: you do not intend to call anyone who is not on the list except for the sheriff? >> we believe the central live witnesses are the sheriff and the mayor. everyone else is subject to whatever information is provided in their declaration. as far as the mayor's witnesses go, we may perceive declarations and agree we do not need a cross examiner. we can argue our case based on what is in the declaration. i am not trying to evade your question. i am telling you i cannot necessarily answer it before i see the contents of their proposed testimony. >chairperson hur: when you list that many people in your list as affirmative witnesses, it does create some confusion but i get it now. is ms. lopez going to testify? >> we hope to have her testify. she is in her native country. her father has cancer. that is an open-ended que

madison and mr. burton the fact that they supported the sheriff in the campaign and that bias somehow motivated their reporting of this incident. chairperson hur: i tend to agree that and that it ised a miss missable to combat bias. -- that it is admissible to combat bias. any objection to that? ok. paragraph six? >> we object on relevance grounds as to its entirety. in addition we don't believe there is foundation or the last sentence and we believe that the last -- or -- excuse me -- the third sentence, we don't think there is foundation -- strike that. we also think that the last three, four, five, mr. kopp can you just say the line number? >> yes. >> is that easier? >> yes. >> we think that line 17 through 23 are speculative. again, more prejudicial than probative. >> mr. keith? >> we think that this does not offer -- well, this is offered to show the relationship between ms. lopez and ms. madison that is really relevant to why ms. madison chose to make the report and the kind of advice that she

madison's retriever. a bit of an exaggeration, but he searched high and low up and down the eastern seaboard for guitars, furniture, rugs, carriages, books, candlestick, snuffers and lace and even -- one more slide. keep going. even wallpaper. one more slide. this is a very famous depiction actually of the boston museum of fine arts, the tea party. later in date than what we are looking at with the madisons, but it explains what you would have seen in a very elegant entertainment situation of the time period. one of the things that he picked up was mrs. madison's iconic turbin. it was a younger look, but she pulled it off quite well. in addition, he picked up her wigs. in one sense, he picked that was a little too small. not sure if that means something if he thought she had a big head or didn't measure it correctly. in march he wrote to mrs. madison to consider what we refer to as the red room and specifies he placed an order for chairs that referred to a suite he commissioned by baltimore cabinet makers

madison included. she is an independent witness and the way we're pursuing by declaration, we don't have the kind of -- i mean, i think for the reasons that you -- the alternative procedure you raced is because we are proceeding by declaration we don't have the decision by the presenting lawyer when somebody's represented by council about what questions to ask and the order in which to take things. so i think the criticism is well taken. and we certainly didn't intend to put matters before the commission that -- that are not relevant. she's not our client. we didn't have control of how she drafted. with regard to the procedure i may very well not contest some of the decisions. we may agree that some of this is admissible. it's useful to go through the declaration an hear the objections because it is going to make the procedure of taking testimony shorter. so that would be my suggestion. but i understand and appreciate the criticism. >> thank you, mr. keith. >> my concern when you say that you didn't ha

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 gen

this is the trash deposit from the madisons' retirement years, downslope of the temple. before we mend this, we label each shard so we know exactly where it came from. state of virginia, "o" is orange county, 249 is the mansion site and had is the inventory number, 10208, that's how we figure what unit it came from, this catalog letter a-x matches up with one of the individual catalog lines that you saw kim and pat writing up previously. and this actually is a back mark that allows us to know it's a davenport, there's the d-a, davenport and it's stone china, this is made in england. but once this is mended what we can tell about this ceramic is the diameter of the plate, what form it took, and then get a better idea what the overall decoration is. this tray over here, we've got a wine bottle seal that we recovered this summer from the slave quarter, and you can see the "j" there, you know, very nicely formed. this would have been one of the president's wine bottles that he used when entertaining the constant guests that were coming heo

murton and miss madison experienced. and we did permit some allegations or some statements from miss madison's explanation that relate specifically to statements about the sheriff's alleged harassment of miss madison. are there -- you know, there was a lot to read so i have read it but i have not marked marked out the portions by 21 through 28 that go to whether or not the sheriff harassed mr. murton. given that it's your objection, can you point us to those portions? >> you would like it see the portions here in which mr. murton's alleges that the sheriff said something that's deemed to be harassment? >> actually, yes, but i probably should put it to mr. keith, because i want to know -- because we allowed it for miss madison to some extent, i would like to be cautious about strike ing it from mr. murton's if it is there. >> so there's basically three different things or categories of harassment mr. murtons is discussion in this portion of the declaration. have you in paragraph 21 he's getting phone calls from journalist

madison that were in the media? >> objection, relevance. >> overruled. >> i do not believe i made any public statement at all. >> did you ever direct anyone not to make attacks on ivory madison? >> i never direct anybody to attack or not attack. >> share of, is it your testimony that on december 31, after you and your wife returned home from that trip to the restaurant, there was no argument at all in the house? >> my wife and i did not go to the restaurant together. my wife went to the restaurant on her own. >> i am talking about this lunchtime trip to the restaurant in the van on december 31, were you turned around in the event. >> there was no argument in the house. >> none whatsoever? >> none whatsoever. >> and it was your testimony there was no physical contact in the house. >> no, not on welcome to -- not unwelcomed. >> your testimony, there was no pushing, pulling, or grabbing in the house. >> none, no. >> just a single grab by end the ban. that is your testimony. >> objection. >> sustained. >> sheriff, after

this is the trash deposit from the madison's retirement years. and before we mend this, what we did is, we labeled each shard so we know exactly where it came from. this is the site number, 44, state of virginia, orange county, 249 is the mansion site and this is the inventory number, 10208. this catalog letter ax matches up with the individual catalog lines and this has a back mark that allows us to know it's the davenport and it's stone china made in england. once this is mended, what we can toll about this ceramic is the diameter of the plate, and get a better idea of what the overall direction is. this tray over here, we've got a wine bottle sealed that we recovered this summer from the slave quarter, and you can see the j. there very nicely formed. this would have been one of the president's wine bottles that we used when entertaining the constant guests coming here to montpeli montpelier. just learning about the slaves and madison's view of slavery, which is incredibly important for understanding who mr. so

madison giving her impression again as to the reason why ms. lopez brought this issue up during this conversation. >> mr. keith? >> i agree. chairperson hur: ok. that is stricken. the sentence beginning with she and ending with threat online 16 -- on line 16, paragraph 16? >> yes. the -- let's see. it's the fourth sentence beginning online 14 ending online 21 beginning with "i" ending with the word "that." the minute miening of this sentence -- the meaning of the sentence isn't clear to me so i guess the proper objection is unintelligible. maybe it's dense but i can't tell what that sentence says or means. chairperson hur: ok. mr. keith? >> well, the sentence -- what i think it means is that she didn't ask and she didn't know why ms. lopez kept saying in 2011. i mean, i think that's the meaning of the sentence. it could have been conveyed in fewer words but she's honestly reporting, i didn't ask about this but she kept saying in 2011. i think as cryptic as this is, the meaning is clear that she didn't know why she kept saying 2011, it wasn't cl

or the press, treatment of the press by miss madison. that's where i see a relevance issue in paragraph 46. >> if i may respond, miss madison knows the effect of what happened. she doesn't necessarily know what started the chain in motion or where it could have stopped. she only knows the impact. i would say that -- we would say we believe that we can present evidence that this was a strategy. but significantly one of our charges is -- or one of the statements made by chief lansdowne in his declaration is it's not ever he caused this, certainly if he caused this, that would not meet the standard. even seeing it happen and not doing something about it when he knew he committed a crime is a problem. and is -- and falls below the law enforcement standard. so just the fact that he's not stopping it fall bees low the standard. the commissioners may or may not find that view persuasive. but it's a view chief lansdowne is qualified to give and to testify to and he can be cross-examined on. i would offer that. as for the notice issues that we we

we spent six to seven years doing the restoration of james and dolly madison's home. and one thing that we're able to represent with restored home are the space where james and dolly is, some of the service places where the slaves worked. what we don't have represented is where the slaves have their homes, this what is we're doing with the excavation in the south yard and timber frame outlines you see right here, is representing -- the house is where they would have worked, this is where they called home. and daily lives, brothers, sisters, mothers, fathers, aunts, uncles would have been played out. to talk about that with visitors to bring humanity to the people that were enslaved by the madisons we felt was important to show their hopes and represent their homes in a physical way. because so many times when when visitors here before we had the timber frame, to be understand what slaves daily life was like and how they had -- they were part of a much larger community with very difficult to do without the structures either being investigated archeologically or timber

i want to know if anyone agrees with madison. and if any of the members of the panel disagree with him as to whether that is a wise clause of the constitution? >> you're looking at me, i don't know why. i think this is a great question. i assume you're reading from madison's participation in the specific debates which take place after the ratification of the constitution. this is something people debate about, whether historians and jack raykof here at -- whether madison was consistent when he was acts as -- opposition to the washington administration, which is the context within which he was writing, i think, one, i think that his comment doesn't really address the issue we have today, which is where you have a large military, that congress has created, voted for and maintains from year to year. at the president's control and the president, i think effectively has the decision whether to employ in hostilities or not. i think madison is right when it comes to declaring war and putting the country on a mobilization or war footing.

james madison. he was born in 1810, according to the family's oral tradition. what happened to george after dolly madison had to sell montpelier, we're not sure. the slaves were broken into three distinct groups at that time. one was sold with the plantation to henry moncure. one group oz slaves was sold outright to other owners all over, and one group of slaves accompanied dolly to washington where she had moved. we believe that george gilmore was among the slaves that were sold with montpelier and stayed on the property after its sale. the next time george gilmore appears in the historical record is in 1870 when he shows up in the united states federal census living right here and on this property. however, we know that this cabin had not been built yet. we know that these trees that made up the cabin weren't cut down until 1873. it's pretty likely that george didn't build this cab uniltill late 1773 or early 1874. we know that through the study of logs, if you look right here, you can actually se

>> reporter: the i team has obtained dotens of e-mails wrifn by madison. she produced them in response to a subpoena in the criminal case. they are heavily redacted, but we can piece together new details from what is not blacked out. the day after the argument on new year's eve, madison convinced lopez to document the bruise on video. >> this is the second time this is happening. >> reporter: madison writes to an unidentified friend, she let me take a video of her crying and showing the bruise. in an e-mail she wrote the same day they shot the video, eliana lopez never mentions going to police. in fact, she tells madison, please send me the info from your therapist. looks like ross is doing research too. in the days to follow madison sent out long missives, apparently embellishing what happened. lopez told me the bruise happened when the sheriff grabbed her arm in the family van and the argument stopped there. but madison writes, "pros was being violent enough with her that she wound up running out of the house and saying to him in the street, do you want

>> reporter: the i team has obtained dotens of e-mails wrifn by madison., but we can piece together new details from what is not blacked out. the day after the argument on new year's eve, madison convinced lopez to document the bruise on video. >> this is the second time this is happening. >> reporter: madison writes to an unidentified friend, she let me take a video of her crying and showing the bruise. in an e-mail she wrote the same day they shot the video, eliana lopez never mentions going to police. in fact, she tells madison, please send me the info from your therapist. looks like ross is doing research too. in the days to follow madison sent out long missives, apparently embellishing what happened. lopez told me the bruise happened when the sheriff grabbed her arm in the family van and the argument stopped there. but madison writes, "pros was being violent enough with her that she wound up running out want the street, dm want meim to call the police" in front of numerous passersby. >> all of these stories about grabbing and all of that thing that i

madison taking calls from ms. lopez and over during that conversation. -- overhearing that conversation. hearing his madison's account of that call. that intense to show that dissuasion is occurring. >> ms. madison would testify to that? >> we expect her credibility to be attacked. >> iac. -- i see. >> the observations of the call coming in from ms. haines as the inspectors were coming to the house, ms. madison was getting off of the phone. that is an observation they made that tends to support the credibility of the testimony. commissioner studley: i thought it was a reasonable balance to have one of these officers provide declaration. the fact that we have this many questions means there may be something and i would rather have us argue after what that we did not have before us. >> [inaudible] commissioner studley: i apologize. all of us are hearing the feedback. we're also trying to speak to the person -- i will repeat what i said. i think the earlier suggestion that you made that the city's select one of the t

>> reporter: the i team has obtained dotens of e-mails wrifn by madison. she produced them in response to a subpoena in the criminal case. they are heavily redacted, but we can piece together new details from what is not blacked out. the day after the argument on new year's eve, madison convinced lopez to document the bruise on video. >> this is the second time this is happening. >> reporter: madison writes to an unidentified friend, she let me take a video of her crying and showing the bruise. in an e-mail she wrote the same day they shot the video, eliana lopez never mentions going to police. in fact, she tells madison, please send me the info from your therapist. looks like ross is doing research too. in the days to follow madison sent out long missives, apparently embellishing what happened. lopez told me the bruise happened when the sheriff grabbed her arm in the family van and the argument stopped there. but madison writes, "pros was being violent enough with her that she wound up running out of the house and saying to him in the street, do you want

and you see the dolly madison house. one reason i wanted to show you these two images is because they were both water colors made by madame denuville. they were some of the notables that rented the decatur house before john gatsby purchased it. these were some of the many people, many notable people, parsonages, if you will, personages, whom jennings got to know. and if even a slave, it helps to know people in high places. he was well connected. he was what we call a networker. and he took appropriate advantage of these connections in his pursuit. and here's a photo of dolly madison's house. you see the cellar windows where jennings quarters would be. and also i feel obliged to say that the door moved all over the place. it was first in front and then moved to the side where you see in this photograph. later that door was made a window and today it's further down on h street. this is one of the earliest photographs of the white house on the south portico, you see president polk and you can believe that dolly kept all the

we saw an artifact of dolley madison. this is of james madison. tell us what your viewers will see here in a minute. >> this came up for auction five years ago. this check. the auctioneer had misread the name of the person it was made out to. they wrote -- i knew it was roger chew wightman, dragged into the white house by the admiral as they were preparing to burn the white house, and the check was made out by james madison to wightman 23 days before burning the white house. it's probably for books, because wightman was a book seller and he was dragged in to represent the humiliation of the americans. he was the only american in the white house, the british bandit, and so i knew knowing more about the providence of this check that it was going to be very valuable. of the fact that wightman was the only person in the white house who wa an american. he later became mayor of washington. he was a notable grand mason, and so that's why i brought it. >> how long had washington been the seat of government by 1814? how long had it been the -- >> 1800. joh

madison's seat. four days later when they returned they found their capital city in ruins and a sight at the white house that most effectively affected the pair. nothing was left of the executive mansion but it's cracked and blackened walls. dolley could never speak of that first sight without emotion, and in that moment spying a passing american soldier, dolley wished "that we had 10,000 such men, sink or enemy to the bottomless pit." friends described the president as miserably shattered, heartbroken and dolley inconsolable, much depressed she could squarely spees without tears. dolley later confessed to mary latrobe she was so angry she wished she had stayed and fired on the troops. i confess i was so unfeminine to be free of fear and willing to remain in the castle with a cannon. i love that picture of dolley in the window with the cannon. it seems dreadfully sad and unfair to stop our story with the james and dolley weeping amongst the smoking rune, but what i'd like to do, sum it up a little ad

i want to commend both sides for the helpful work he did on the madison objections. i think that while we can disagree with certain positions you may have taken, i appreciate both of you working to come to resolution on things, and having us focus on what is likely the more important portions of these. >> thank you. it did take more than an hour, though. [laughter] >> i would join in the chairman's observation. i did find it is very helpful, the way in which it was done. i do not know where the want objections and comments in the same form, which made it very easy for me to follow. >> that was my intention. essentially, i was when to walk through it and have the commission way in. this was submitted by the mayor's office. did the mayor's office accurately reflect the stipulations of the dispute? >> there was an amendment submitted, and i agreed with it. from our perspective, it fairly sets forth the disputes. i do not know that either of us need to say anything to you folks. >> my view on this is that we go through them. unless commissioners have any questions, agree

>> he claim head was 25, sticks in my head it might have been madison, madison was the policeman after the convention to make sure things were accurate. somebody pointed out that he had been 29 at the time. >> who was he? >> charles pinkney was an aristocrat. he had been a soldier during the war, an officer, and had been educated as a lawyer, was a talented guy, smart guy, a little erratic at the convention. but he was the only delegate who showed up with a draft constitution in his hand. it was ignored mostly but he did a lot of work. he had been in the congress and had held hearings actually on whether there ought to be a new constitution at the time was the articles of confederation, but whether that ought to be replaced. despite his youth he thought about these issues pretty hard. >> you are yale, yale undergrad, law school, worked for justice powell on the supreme court as a clerk. judge basilon on the circuit court and judge scaly wright. what about your legal experience -- you practice law -- what about that legal experience and the government mattered to you as you wrote this b

we saw an artifact of dolley madison. this is an artifact of james madison. tell us what your viewers will see here in a minute. >> this check came up for auction five years ago, and the auctioneer had misread the name of the person it was made out to. they wrote weightman. i knew it was roger ch chu weightman, dragged into the white house by the admiral as they were preparing to burn the white house, and the check was made out by james madison to weightman 23 days before burning the white house. it's probably for books, because weightman was a book seller and he was dragged in to represent the humiliation of the americans. he was the only american in the white house when the british burned it, and so i knew, knowing more about the providence of this check, that it was going to be very valuable. one day i might donate it to the white house, but i'm fearful that it might end up in a drawer or something where the public can't see it. but it really is a remarkable find, because of the fact that weightman was the only person in the white house who was an american

in the days to follow madison sent out long lists to people whose names were were blacked out. lopez told me the bruise happened when mirkarimi briefly grabbed her arm inside the family van and argument stop there's but madison writes ross was being violent enough with h her that she wound up running out of the house and saying to him in the street do you want me to call the police in front of numerous passers by. >> all this story about pushing, grabbing, all that i was running outside, that is not true. that never happened. >> reporter: where did that come from? >> i don't know. it is imagination of someone. >> reporter: the documents also show thattivery madison's husband provided his phone to police so they could see his text messages about the incident. but there is a gap no message on the crucial days january 1 when his wife made the bruise video through january 5. >> it calls into question what are they not telling us. who else was involved? what exactly was the nature of what they were up to and what they are up to? >> reporter: all issues to be taken up at the ethics c

then i would be thinking about madison and washington. there was some great human beings there that did a lot. >> luther martin? >> there is a great quote i found and used when some guy said you should hear about luther martin but you shouldn't see him. he drank a lot. apparently had really bad table manners. his clothes were usually spotted with food. i am not positive i need to see luther. >> edwards gary stuttered? >> that's pretty unanimous that he stuttered. >> anybody else have not very good speech? >> well, it was oratorical era so if you weren't good at it they noticed it. there was a fellow frlansing fr new york and there were several delegates who were put down as not speaking well and didn't speak that often. gary was unique in that he didn't speak well and he spoke a lot. >> is there another book for you out of some way or something you learned in this process? >> not directly at the moment. i am interested in my next project on the impeachment trial of andrew johnson. one of the things that i came away from this book feeling

madison and ms. williams, i have a couple of questions, in light of the rulings on the other witnesses. do i understand that you will not -- obviously, you will not have any need to cross-examine paul henderson. do you have any need to cross- examine wendy still? vicki hennessy? richard danielle? i guess we are waiting on exhibit 4. are you going to be challenging the chain of custody of the video, or anything like that? >> no. chairperson hur: no need to cross-examine? >> correct. chairperson hur: that is helpful. thank you. >> i thought i put this in an e- mail. it is possible not everybody got it. chairperson hur: you did? i may have missed it. thank you. the other thing i wanted to ask was about christine florence -- florez. there was potentially a loophole in the order. we did not request objections to testimony. we did not receive any objections to the transcript. does that mean you are not checked into the -- objecting to the testimony submitted with respect to ms. flores? >> i may have misund

madison was pursuing a complaint with the police. she had made mention of a video, which i just learned about for the first time. and she was very concerned. very, very concerned. and wanted to come and meet me and talk with me. and that was pretty much the extent of the conversation. >> and were you in your supervisor's office when you had that call with your wife? >> i believe i was either on the second floor or fourth floor, because i was going back and forth. >> was there anyone around while you were speaking with your wife for that 5:00 minute telephone call? >> there were numerous people around, because the moving -- >> do you recall anyone in specific? >> my staff. >> was there anyone else in the room? >> well, our doors are never closed. so people come in and out. staff like brown and sell may are two of my principal staff people and rick gal brith. but as i said, i was going back and forth between the second and fourth floor, and on the fourth floor would have been sheriff secretary susan and undersecretary who may have left

. >> is it your assertion that sheriff mirkarimi somehow dissuaded ivory madison from speaking with the police? >> i believe he was part of the effort to not have people talk to the police department. including his wife. >> ok, what do you base that belief on? >> the declarations -- not declarations, but the transliteration of the videotape. >> you are talking about the one-minute videotape that miss lopez made with miss madison? >> yes. >> are there any other facts that you base that assertion on? >> objection, attorney-private -- attorney-client privilege. >> excluding conversations with your counsel. >> without limitation, the objection is overruled -- with that limitation, the objection is overruled. >> the declarations of ivory madison. >> now, you have stated in your declaration that one of the reasons that was significant to you that this was official misconduct because a law enforcement officer must follow the law and enforce it, but sheriff mirkarimi pled guilty and was convicted of a crime. is it your belief that any time and law-enforcement officer is convicted of a crime, th