Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 1 of 6 PageID #: 265
EXHIBIT 1
Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 2 of 6 PageID #: 266
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
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KAREN DAVIDSON,
*
DEBBIE FLITMAN,
*
EUGENE PERRY,
*
SYLVIA WEBER, and
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AMERICAN CIVIL LIBERTIES
*
UNION OF RHODE ISLAND
*
*
vs .
*
*
*
*
C.A. NO.:
l : 14-cv-00091-L-LDA
CITY OF CRANSTON,
RHODE ISLAND
*
*****************************
DEPOSITION OF KAREN LEWIS DAVIDSON, a
Plaintiff in the above-entitled cause, taken on
behalf of the Defendants, pursuant to notice,
before Sally Brassard, CSR, a Notary Public in and
for the State of Rhode Island and Providence
Plantations, at the Law Offices of Partridge Snow
& Hahn, LLP, 40 Westminster Street, Suite 1100,
Providence, Rhode Island, on January 29, 2015,
scheduled at 12 : 30 p.m.
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 3 of 6 PageID #: 267
Karen Lewis Davidson - January 29, 2015
5
A.
1
2
Q.
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And what was that for?
A.
3
Q.
1982.
A car accident .
Have you ever been deposed in a civil rights
5
action?
6
A.
7
Q.
~.
Other than a car accident, have you brought any
8
other claims -- brought any other suits?
9
A.
10
Q.
12
On behalf of yourself?
A.
11
Q.
I'm a lawyer, yes.
~ .
If you ever need a break during this just let me
13
know, and we'll be happy to oblige .
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ask that if a question has been presented that you
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finish answering the question, then, we'll take a
16
break.
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A.
18
Q.
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21
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I understand.
What is your date of birth?
/
A.
Q.
And where do you live?
A.
Q.
Edgewood.
And is Edgewood a neighborhood within a larger
23
city?
24
A.
25
Q.
I would just
It's the part of Cranston that's on the water.
Okay.
And do you know what city ward you live in?
Allied Court Reporters, Inc . (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 4 of 6 PageID #: 268
Karen Lewis Davidson - January 29, 2015
6
A.
1
2
Q.
4
What ward is that?
A.
3
Q.
Yes.
First.
Are you taking any medications today that would
5
impair your ability to answer the questions
6
truthfully?
7
A.
8
Q.
10
A.
Q.
12
13
Do you have any reason why you couldn't respond to
the questions truthfully today?
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No.
In Cranston, do you live with anyone?
A.
Q.
No.
No.
And you mentioned that you are a lawyer.
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still practicing?
15
A.
16
Q.
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18
20
Q.
Myself.
What kind of law do you practice?
A.
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am.
Who do you practice with?
A.
Q.
I
The right kind.
Good answer.
21
A.
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do some family court work.
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work.
24
25
Q.
Are you
I do work for the ACLU.
I do litigation.
I
It's mostly pro bone
I do wills and trusts and estates.
So, do you have -- when you say you work for
yourself, do you have your own office?
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 5 of 6 PageID #: 269
Karen Lewis Davidson - January 29, 2015
13
1
Q.
How about fire and rescue?
Would they have an
2
interest in whether or not fire and rescue are
3
able to reach them at your house?
4
A.
5
think about.
6
Q.
I don't think that it's something they would
If fire and rescue weren't able to get to your
7
house in case of an emergency, you don't think
8
friends and family that you're entertaining would
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care about that?
A.
10
11
Q.
I don't know.
Do you think they have any interest in being
12
protected by Cranston services at all?
13
A.
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about.
15
Q.
I
don't think it's something that they think
How about you?
Do you have an interest in making
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sure Cranston services are there for your guests
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when they're at your house?
18
A.
19
Q.
21
Q.
Q.
24
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I
Okay.
A.
Q,
Almost every time.
Did you vote in the last election?
A.
22
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Do you vote?
A.
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Of course.
I
did.
Do you vote in primaries as well as -do .
as well as generals?
Allied Court Reporters, Inc. (401) 946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-1 Filed 08/06/15 Page 6 of 6 PageID #: 270
Karen Lewis Davidson - January 29, 2015
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A.
1
2
Q.
I do.
Okay.
You said you vote in almost every one.
3
you remember a time when you may not have?
4
A.
5
ballots.
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election.
7
Q.
Three times I voted from abroad with absentee
I try to vote in every single major
Do you have any children in the schools, in the
8
Cranston schools?
9
A.
10
Q.
~.
Have you ever reached out to your school committee
11
members regarding school committee business?
12
A.
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some time ago .
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together sometimes .
15
Q.
I
talked with my prior school committee member
A.
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her name.
Q.
She's a dog -- we walk our dogs
What's her name?
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Her dog's name is Pepper, and I am blanking on
She lives on the street next to me.
That's fine.
When i t comes to you, if i t comes to
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you, if you wouldn't mind just letting me know.
20
A.
21
Q.
Do
Okay.
That would be great.
Now, you mentioned -- and I
22
am not trying to mischaracterize or put words in
23
your mouth, but you said you talked to her when
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you were walking your dog.
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to her specifically about school committee
Have you ever spoken
Allied Court Reporters, Inc. (401)946 - 5500
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