Case 1:14-cv-00091-L-LDA Document 24-4 Filed 08/06/15 Page 1 of 5 PageID #: 279
EXHIBIT 4
Case 1:14-cv-00091-L-LDA Document 24-4 Filed 08/06/15 Page 2 of 5 PageID #: 280
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
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KAREN DAVIDSON,
*
DEBBIE FLITMAN,
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EUGENE PERRY,
*
SYLVIA WEBER, and
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AMERICAN CIVIL LIBERTIES
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UNION OF RHODE ISLAND
*
*
vs.
*
*
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CITY OF CRANSTON,
*
RHODE ISLAND
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C.A. NO.:
1:14-cv-00091-L-LDA
DEPOSITION OF EUGENE H. PERRY, 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
4:00 p.m.
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtre porters.com
Case 1:14-cv-00091-L-LDA Document 24-4 Filed 08/06/15 Page 3 of 5 PageID #: 281
Eugene H. Perry - January 29, 2015
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okay?
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A.
3
Q.
Yeah.
If you don't understand a question -- if I ask a
4
question and you don't understand it let me know,
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and I will try to rephrase it so that it's more
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understandable because if you answer a question,
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we're going to assume that you understood the
8
question; okay?
9
A.
10
Q.
Uh-huh.
Please speak all your answers and don't nod and
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shake your head because the stenographer is taking
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everything down for a clear record.
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A.
14
Q.
Right.
The other thing is, I'll try not to talk over you.
15
Try not to talk over me, so that she can take
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everything down.
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finished and then respond, and I'll try to wait
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for you to respond as well; okay?
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A.
20
Q.
21
22
23
24
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�.
What's your date of birth?
A.
Q.
All right.
Do you have any questions?
A.
Q.
Wait for the question to be
.
And where do you live?
A.
I live at
Lane in Cranston.
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-4 Filed 08/06/15 Page 4 of 5 PageID #: 282
Eugene H. Perry - January 29, 2015
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1
Q.
Could you spell that for me?
2
A.
3
know that.
4
Q.
6
Q.
Everybody asks that.
I should
And you said it's in Cranston; correct?
A.
5
.
Yes.
Ward 1.
Ward 1.
Okay, thank you.
Are you taking any
7
medications today that would impair your ability
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to answer the questions truthfully?
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A.
10
Q.
No .
Okay.
Is there any reason at all that you
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couldn't respond truthfully to the questions?
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A.
13
Q.
15
Q.
is?
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A.
Q.
20
Q.
22
Q.
24
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Q.
No.
Married, yes.
Yes.
Okay.
A.
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Mr. Stycos.
And that person lives with you?
A.
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can think of.
Are you married or do you live with anyone?
A.
19
I
And do you know who your school committee member
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None that
Who is your council member?
A.
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No.
And what is that person's name?
Elaine.
And what do you do for work?
A.
I'm retired.
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Avenue, Cranston, RI 02920
www.alliedcourtreporters.com
Case 1:14-cv-00091-L-LDA Document 24-4 Filed 08/06/15 Page 5 of 5 PageID #: 283
Eugene H. Perry - January 29, 2015
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people to visit you?
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A.
3
Q.
Yes.
Do you have an interest in being protected in the
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Cranston service's fire and police protecting your
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guests at your house?
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A.
7
Q.
9
Q.
Q.
13
Q.
15
Q.
The last election .
Did you vote in the primaries?
A.
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Yes.
When was the last time you voted?
A.
12
Yes .
Regularly?
A.
10
11
Do y ou vote?
A.
8
I suppose I do, yes .
Yes .
Have you ever reached out to your school committee
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members regarding school committee business?
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A.
18
Q.
No.
Have you e v er had any conversations with any
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school committee members with regard to school
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committee business?
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A.
22
23
Q.
No, no.
My kids are 50 years old .
But you have had conversations with them; with one
or two?
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MR. LIOZ :
Objection.
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MR . PELLEGRINO:
I ' l l withdraw that
Allied Court Reporters, Inc. (401)946-5500
115 Phenix Av enue, Cranston, RI 02920
www.alliedcourtreporters.com