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1LAURA L. WAGNER, RPR, CCR(502)664-6677
PUBLIC PROTECTION CABINET KENTUCKY CLAIMS COMMISSION
TAX APPEALS FILE NO. K18-S-100
ANCHORAGE PLACE LLC APPELLANT Vs. TONY LINDAUER, JEFFERSON COUNTY PROPERTY VALUATION ADMINISTRATOR and JEFFERSON COUNTY BOARD OF ASSESSMENT APPEALS APPELLEE
* * * * *
The deposition of MATTHEW G. BEVIN was
taken on behalf of the Appellant before Laura L.
Wagner, Registered Professional Reporter and Notary
Public for the State of Kentucky at Large, at 400
West Market Street, Suite 3200, Louisville, Kentucky
on October 13, 2019, at approximately 2:30 p.m.
Said deposition was taken pursuant to Notice for
purposes of discovery and as provided by Kentucky
Rules of Civil Procedure.
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APPEARANCES
MR. MARK F. SOMMER Attorney for Appellant Frost Brown Todd LLC 400 West Market Street, Suite 3200 Louisville, Kentucky 40202 [email protected]
MR. JOHN CARROLL Attorney for Appellee Assistant Jefferson County Attorney 531 Court Place, Suite 900 Louisville, Kentucky 40202 [email protected]
Also Present:
MS. LISA SCHULTZ
MS. ELIZABETH MOSLEY
MS. NATALIE JOHNSON
* * * * *
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INDEX WITNESS: PAGE MATTHEW G. BEVIN Direct Examination by Mr. Sommer -------------------- 4 Cross-Examination by Mr. Carroll ---------------------- 33 Redirect Examination by Mr. Sommer -------------------- 51
EXHIBITS
Exhibit 1 (Notice of deposition) 5
Exhibit 2 (Joe Cattan report) 12
Exhibit 3 (Microbiology report) 17
Exhibit 4 (John May report) 21
Exhibit 5 (News articles) 30
Exhibit A (Deed) 39
Exhibit B (Interrogatory answers) 49
Exhibit C (Louisville Water bills) 50
* * * * *
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MATTHEW G. BEVIN,
a witness, called upon oral examination by counsel
for the Appellant, having been first duly sworn, was
examined and testified as follows:
DIRECT EXAMINATION
BY MR. SOMMER:
Q. Good afternoon, Governor. As you know,
I'm Mark Sommer. I'm your counsel here with Frost
Brown Todd, and with me is my associate, Elizabeth
Mosley, and my paralegal, Lisa Schultz.
I appreciate you coming in today and
working around your calendar. We're here in a tax
case in front of the Kentucky Claims Commission.
That case is filed Anchorage Place, LLC, versus
Jefferson County Property Valuation Administrator,
et al, Case Number K18-S-100. And we're here to
talk about a real property tax dispute for the
value of your residence as of January 1, 2018.
This is unusual, what we're doing today,
and so I want to state that for the record. This
is an agreed-upon deposition by the parties with
the consent of the hearing officer of the Claims
Commission to memorialize your testimony. Given
that the hearing is scheduled for this Thursday and
Friday, and given your heavy workload and travel 2:36:59PM
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schedule, you are unavailable. So that's why we're
doing what we're doing today, just FYI.
I would like to show you a document and
have you take a look at that, if you could. That
document is entitled, Notice of Deposition of
Matthew G. Bevin, individually and as the Anchorage
Place, LLC, representative pursuant to Civil Rule
30.02(6). I would like to make sure you've
received that and have seen that. Yes?
A. Yes.
MR. SOMMER: Without objection,
we'll make that Exhibit 1.
(Whereupon, said document was
marked Exhibit 1.)
MR. CARROLL: No objection.
Q. (BY MR. SOMMER) So today you're
testifying individually as Matthew G. Bevin and
also as the designated representative of the LLC of
which you are a member?
A. Sole member, correct, yes.
Q. Right. Thank you. As noted, this
testimony is being given by agreement of the
parties with the consent of the Commission.
While this might sound unusual, if you
could, state for the record your name -- 2:37:58PM
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A. Sure.
Q. -- your work address, and your current
occupation, then I'm going to go over a couple of
ground rules.
A. Matthew G. Bevin. Work address is -- I
think it's 700 Capital Avenue, Frankfort, Kentucky
40601. I am, as the Governor, just have executive
responsibility for the Commonwealth of Kentucky.
Q. Very good. Thank you. Okay. Only a
couple of rules. And these are designed to make
the session go as efficiently as possible.
The first rule is, the court reporter,
Laura, would appreciate more verbal than nonverbal.
So we're all guilty of nonverbal cues and nonverbal
communication, but since this is a transcribed
versus a video deposition --
A. Sure.
Q. -- we need to go verbal.
I'm going to ask questions. If you
could, wait -- and John will have an opportunity to
ask some questions as well. If you could wait
until the question is finished before answering,
we'll go on.
If you need clarification or you don't
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of us will endeavor to correct that. And if at any
time you want to go back to something you said
previously or a question that was asked or a topic
that was raised previously, feel free to do that
and say, I would like to... XYZ.
A. Okay.
Q. Very good. We're here today to talk
about the property tax value of your residence.
You being the owner of Anchorage Place, LLC, which
is the fee simple owner of 804 Evergreen Road,
Anchorage, KY. So we're talking about property tax
or ad valorem tax; is that right?
A. Yes.
Q. And the value period that we're talking
about specifically is January 1, 2018. Although,
some questions may come with respect to 2017 and
2019 because of the way the case has been argued up
to this date. Do you understand that?
A. Yes.
Q. Okay. That's the background. So let's
go ahead and talk a little bit. You purchased the
property at 804 Evergreen about when?
A. Sorry. I would say the Spring of 2017.
I don't remember the exact date. February or
March, maybe, of 2017. 2:40:15PM
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Q. Okay. I think for the record's purpose,
I think the LLC was formed on or around the first
week of March.
A. Yeah.
Q. So would that be about right?
A. Yes.
Q. And you paid cash for the house?
A. Yes.
Q. And how much was that?
A. One point six million.
Q. Okay. As I noted, there was an LLC,
Anchorage Place. Was that LLC formed specifically
for this transaction?
A. It was, yes. It was -- literally, it was
created just in advance of the purchase and for the
purpose of purchasing the property.
Q. Okay. Now, before you purchased the
house, did you have the house appraised for any
purpose?
A. I did not.
Q. You did not. Prior to closing on the
transaction, did you have the home inspected by a
roofer or anyone, roof builder --
A. No.
Q. -- or anyone like that? No? 2:41:10PM
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A. No. I'd say it might have been a good
idea, but no, I did not.
Q. Okay. Now, it's public information that
you have a large family. You're very blessed with
many beautiful children. And I have five, and I
know what space limitations can do to me or has
done in my time. So I can only imagine what it is
for you.
I would like you to explain for the
benefit of the Commission's record why it is you
bought the property at 804. I'm sure there's one,
two, or three reasons, if at all. But if you
could, in your own words, explain why you made the
purchase.
A. Sure. Because my wife wanted to live
there and have some privacy and better security.
We owned a house in Louisville that we have owned
since 1999 and had lived in as our sole residence
for, I guess, 18 years at that point.
It was very sufficient, but did not
provide very good privacy. People literally
would -- this is since -- while I was Governor --
would come up, walk in the driveway, stick notes on
your car, you know, windshield, walk up, knock on
the door, drive by, throw things at the house. 2:42:26PM
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It's very proximate to the street. And
so it didn't really provide a lot of -- you know,
people would drive by and look in the windows. So
you always had to -- it was just a very -- a loss
of privacy. My wife wanted a place where you could
have some privacy and better security for our
family. And that, as much as anything, was really
the catalyst for purchasing the house.
Q. Very good. So given that question, I'm
assuming that the 10-acre footprint of 804
Evergreen gives you what you were seeking in that
regards?
A. Sure. It gives you more space around
which people can't drive by and look in your
window. They can't throw things, at least with
their own arm, at your house. They don't have the
ability to drive up your driveway as easily anyhow
and, you know, stick things under your door or in
your mail slot or on your car or things of that
sort.
So yeah, it was basically to provide a
bit of space and a bit of a buffer, again, for both
privacy and security for our family.
Q. Very good. Thank you. Now, since you
purchased -- let's just call it March -- let's just 2:43:45PM
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say March 1, just for whatever the record would
say. But since March 1, has anyone ever approached
you to ask you to consider selling some of the
land --
A. No.
Q. -- that is a part of 804?
A. No.
Q. No one has. Would you ever do that?
A. No. I'm precluded from actually doing it
based on the purchase agreement itself, because it
gives the right of first refusal to the very people
that I bought the property from. And it also --
I'm not sure how it would work given the fact that
there's many deed restrictions on the property
itself.
The land and the front -- all the road
frontage I don't own. There's deeded access
through my property to property behind my property
that I don't own, and all the land on the north
side of the property I don't own. So on three
sides I don't own the property, and there's deeded
access through the property to the properties that
I don't own. All of which, even if that were
desired, I don't think it's possible.
Q. Okay. These restrictions you speak of or 2:44:52PM
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the conditions, maybe that's a better way, but the
conditions might also be a restriction. You've
bought and sold houses in your time, right?
A. Yes.
Q. Do you believe those conditions would
impact the saleability of the property?
A. Oh, no question. And it didn't bother us
because the intent was never to try to subdivide
it. And so, of course, knowing full well that it
would restrict that ability was not of a concern
because the whole point was not to have people all
surrounding us in multiple parcels.
I mean, it's only 10 acres, which is not
nothing, but I don't know how many properties you
could possibly get on there before you would have
everybody, you know, looking in each other's
windows.
Q. Right. Very good.
(Whereupon, a document was
marked Exhibit 2.)
Q. (BY MR. SOMMER) Okay. I'm going to
show you a document that's in the record now. And
this is a home inspection report by a home
inspector and structural engineer by the name of
Mr. Joe Cattan. This report, without objection, 2:45:53PM
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will be noted Exhibit 2. It's dated June 24th,
2017, and I'll ask you if you've seen this document
before.
A. I'm sure I have. I remember Joe Cattan.
I remember looking at the property with him. And I
remember there was a report, and so, yes.
Q. So you did accompany Mr. Cattan --
A. Yeah, when he came to the property.
Q. -- when he came and inspected?
A. Yes.
Q. And his deposition is already in record
in this case.
Okay. In this report, Mr. Cattan
identifies in great detail his observations as to
the state of the property. These are my words, but
I'll defer to the document. Example, problems in
the basement, and then he identifies them, if one
exists.
Are you familiar with some of those?
A. Yes. Sadly, they're all still there and
then some.
Q. Right. Can you explain for the benefit
of the Commission what Joe Cattan will identify or
characterize as obsolescence or needed repair type
issues? 2:47:07PM
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A. This is a very old home that is built on
a -- I mean, it's 150-plus years old. It was built
in the mid 19th century. It was built with a brick
foundation that were bricks that were made on
property from clay that was taken out of the ground
there. They have -- to say they're obsolete would
be generous. They're crumbling. They are porous.
They literally shed. They're literally collapsing.
So there's tremendous structural problems with the
foundation itself. This also lets a lot of
moisture through.
And there's also springs that come up in
the basement that used to be captured by cisterns.
But a previous owner had cut into the side of the
cistern, so now it actually probably even more than
historically went in has come into the basement.
So it floods regularly. I mean, by flooding, I
mean inches deep. And that's with drains trying
to --
Q. Six inches?
A. Oh, easy. Yeah. Well, it would be if
there weren't a drain trying to get rid of it as
fast as it was coming. But probably three to
four inches even with the drain and a sump pump
going full time. 2:48:23PM
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Q. To this day?
A. Yes. Because it's still -- even now
we're getting estimates on -- we've done things to
try to alleviate this but to limited success.
But back to the question when Joe Cattan
was there, there's a significant amount of fungal
growth, a lot of mold that's both coloration and
then physical, actual like lichen-looking,
mushroomy-looking stuff.
There is structural problems where you
literally see sagging and/or rotting of structural
timbers. Things that were made in the mid 19th
century, of course, were not built to modern code.
And over time the integrity of the materials, which
wasn't even as good as we might use now, degrades.
And that's what we're dealing with.
So there's a lot of unevenness. There's
a lot of moisture problems, a lot of fungal and,
specifically, a lot of mold problems.
Q. Okay. Mr. Cattan uses a term called
deflection. I'm not a builder. Deflection is
uneven floors, as he describes it?
A. Oh, yes. There's nothing in this house
that's even. But again, it's 150-plus years old.
There literally is not a floor that you could put a 2:49:41PM
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level on and put the bubble in the middle.
Q. Are there issues with doors or windows?
A. Sure. Yes.
Q. Some open, some open roughly or --
A. Yes. Yeah. And some have been planed or
shaved to settle, you know, accommodate for things
opening or not opening.
Q. Okay.
A. Yeah, it's a very old house.
Q. Okay. These characterizations that you
give now and that Mr. Cattan has in his report, did
they exist as of January 1, 2018?
A. Yes.
Q. Okay. And they existed when you
purchased the property?
A. They probably existed in 1918 also, but
yeah.
Q. All right. Very good. And so the
flooding still exists today?
A. It does.
Q. The water in the basement rather?
A. Yes.
Q. The mold condition still exists today?
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success. And now it looks like I'm going to have
to spend probably six figures to really try to
really do it.
Q. I want to show you a document that you --
I think you've seen this before. It's entitled,
Microbiology Laboratory Report. It's dated as of
August 27th, 2019, by a company known as
Environmental Safety Technologies.
MR. SOMMER: Without objection,
this will be Exhibit 3.
MR. CARROLL: I'm going to place
an objection on the record. That's all I'm going
to say for now on that.
MR. SOMMER: Okay.
(Whereupon, said document was
marked Exhibit 3.)
Q. (BY MR. SOMMER) I would like to ask you
a question about this report. As I noted, this was
dated August of 2019. Does this characterize a
mold or other spore problem?
A. It does. What it was done for, it was to
determine to what degree this was of -- should be
of health concern to us living in a house with this
in the basement. I grew up in an old house, so I
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not hanging out down in the basement all the time,
how bad could it be.
But my wife, who thought otherwise and as
it turns out was correct in this, said that it has
more ability to affect us than you realize. A lot
of people with some breathing problems, headaches
and different things and said, well, let's make
sure it wasn't related to this.
And so I had this company come in and
test the air quality in all different parts of the
house, including in the basement. And then
specifically take samples of the types of mold and
things that are found in the basement and test
them. And that's -- this is the result of that
test.
Q. If you go to page two and page three,
there are highlighted areas on each. You'll see in
the top, each of the one thirds moving down -- or
moving from the top down, you'll see a highlighted
area, "within normal tolerances," "within normal
tolerances," and then "not with normal tolerances."
Right? Does that have a meaning?
A. The very -- yes. I mean, again, I'm not
a -- here's what I know. Some of it is black mold.
Black mold is very toxic. This is actually of 2:53:12PM
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great concern. We are going to have to destroy a
lot of what was in that basement. Some may be able
to, at cost, be reclaimed, things that were stored
down there, everything from Christmas decorations
to photo albums to just a lot of personal family
stuff that has been contaminated as a result of
being down there. And the full extent of which we
are literally now still just trying to figure out
how much can be saved and to what extent and at
what cost.
And then a cost benefit analysis being
done as to whether it's better to do that or just
get rid of it. And then what can be done to
eliminate it. Because, apparently, this particular
one, the bottom third, is very, very problematic.
I mean, there was concern initially, even by the
people doing this, that we might have to move out
of the house, and the entire house would have to
be -- I don't -- they basically wrap it up and try
to -- to the extent that it's possible --
Q. Like fumigate it?
A. Yeah, in a sense, but that's not what it
is.
Q. But it's not fumigated, right?
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the mold. And now they believe they can do that by
focusing it on the basement itself, from the lower
level down.
Q. Okay.
A. But again, we're still -- we're getting
multiple estimates from people as to what's
involved with that.
Q. Is it your testimony that the mold issue,
not necessarily the degree of that -- that would be
a scientific issue --
A. Yes.
Q. -- but the mold issue was present on
1/1/18?
A. It was.
Q. I'm going to show you another document --
A. It was present before that. Because even
Joe Cattan was in there doing his inspection well
before that, and that was when he really was
looking at it for the first time with a
professional eye.
Q. Thank you. I want to show you another
document. This is a document entitled, Appraisal
of 804 Evergreen Road. This was prepared by John
May, and it attempts to value and puts a report of
record as of January 1, 2017. I'll ask you if 2:55:13PM
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you've seen that before.
A. Yes.
MR. SOMMER: Without objection,
this will be Exhibit 4.
MR. CARROLL: I have no objection.
(Whereupon, said document was
marked Exhibit 4.)
Q. (BY MR. SOMMER) Now, on page six of
this report, we kind of have to -- maybe it's
better to look to the lower right, Anchorage 0016.
Maybe that's a better way to look at it.
A. Okay.
Q. On this page, there's a table entitled,
Summary of Appraisal Results. And this is where
Mr. May puts forth his conclusions as to the value
of the property. Do you see that page?
A. I do. Although the amount of acreage is
not correct.
Q. Okay. So the first column is 19 acres as
of 1/1/2017?
A. Yeah, right.
Q. That's before you bought it.
A. Gotcha.
Q. And then the second column, that column
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date?
A. Correct.
Q. He has another value. Do you see we're
on that?
A. I do.
Q. And that's ten acres?
A. Yes.
Q. What's the value on 3/9/17 that Mr. May
represents?
A. $375,000.
Q. Okay. And that's for the land?
A. For the land alone. $1,015,000 for the
improvements, for a total value of $1,390,000.
Q. Okay. And you paid $1.6 million on or
about that same date, correct?
A. Correct. Which was what it was listed
for. I mean, it was listed for, I believe, 1.6 or
1.61 or -- I, essentially, paid the list price for
it with the intention of not quibbling. Because
even then, I honestly believed that -- had it been
a traditional property like any other, I would have
probably offered less than. But I figured it would
be probably topical and it would give people
fodder. Had I only known, I would have quibbled.
Q. Now, there was an appeal in 2017 about 2:57:21PM
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the value of the house. You, I'm sure, recall
that?
A. Yes.
Q. And the Board of Assessment Appeals found
the value of your property as of that date,
March 2017, was how much?
A. 1.4 million, $1.39 million.
Q. And they agreed with Mr. May's findings
in full?
A. Yes. I mean, they did, and they did not
appeal it or -- you know, they didn't reject it.
They didn't appeal it. They didn't contest it.
They accepted it, and that year's assessment was
based on it.
Q. So based on that, is that the basis for
your valuation for 1/1/18, that the county accepted
the 1.39 million?
A. What do you mean by the value of 1/1/18?
Q. The tax value of the house --
A. Sure. Yeah, I mean, my understanding
is -- and again, I've owned property in this county
for decades, and it's based on whatever the
assessed value is. And the assessed value as of
1/1/18 was based on the prior year's assessment.
Q. All right. So in some of your media 2:58:26PM
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reports, there's hundreds of articles in the record
in this case already, and I think you and I were
discussing --
A. Yeah.
Q. -- there's probably thousands --
A. Hundreds is probably being on the light
side.
Q. There's thousands of articles out there
on the internet about this. You had made
statements that you may have actually overpaid for
the property?
A. I made that statement a few months
afterwards, before any of -- it may have even been
before -- I believe it was before this assessment
was even done. What's the date on this thing?
Q. This is dated July, I think.
A. My point being -- yes, I mean, it's on
record. We can go find the video. It was in front
of the Capital. But all of our friends in the
media were quite interested in this property. And
I said, let's wait until there's an actual
assessment done.
I said, none of you are tax experts or
appraisal experts, nor am I. So let's get people
who are to actually weigh in, make a determination. 2:59:33PM
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I said, if anything, I probably overpaid for the
house. So, yeah, I mean, I still to this day --
especially in light of everything I now know, I
still believe that.
Q. Okay. When you bought the property in --
or when the LLC, but I'm just --
A. Yes --
Q. -- for expedience, I'm referring --
A. -- I'm the sole member of the LLC, so I
bought it.
Q. When you purchased the property in March
of 2017, there was some effort to finish out, in
permanent space, the third floor. We'll call it a
dormer or an attic, but is that accurate?
A. Correct.
Q. Okay. Now, when you bought it, was it
fully done, was everything turnkey, or were there
still steps to take?
A. It needed carpet laid down, but the
carpet was already up there. It just hadn't been
put down yet. It needed some painting, touching up
the walls and ceiling and around where fixtures had
been put in. But all the walls, all of the
fixtures, the bathroom, the tile, the tub, the
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that was done. It just needed carpet put down, and
it needed paint and touchup basically.
Q. Very good.
A. The floor on which the carpet needed to
be laid was already all down. It was just a
plywood floor that was completely in place. Just
carpet needed to be tacked to it.
Q. Okay. So more finishing features?
A. A hundred percent only finishing.
Q. Is there anything you would like to say
to the Commission? You're the taxpayer in this
case, and so the burden of proof is on you. And so
the custom of the Commission is to allow the
taxpayer to make their say, for lack of a better
term.
Is there anything you would like to say
to the Commission with respect to the almost 24
months of scrutiny of the house transaction, the --
we're now in the third round of appeals now in
2019, but here we're talking about the second round
after your first win in 2017.
A. Yeah, I mean, this is -- it's
unprecedented from anything that's ever happened in
this county or probably in this state. It is
without any question in my mind politically 3:01:57PM
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motivated. It was done with the absolute intent of
making my life and that of my family as miserable
as possible.
It has led to me having to remove people
physically from our property, who are members of
the media, who even as they're being removed from
the property are still demanding to go and take
pictures through the windows before they leave.
It's resulted in me being sued by the
media for the right to come into a private home,
because supposedly that's their prerogative since
I'm a public official. Although, I know of no
other public official in the history of this state
that the media has ever demanded to go into their
private home.
It's led to drones and helicopters being
flown over my house on multiple occasions, to the
extent that my kids were afraid and came in and
were like, What are we supposed to do, should we be
outside?
It's led to a tremendous amount of angst
and emotional distress for my family, and for my
wife in particular. Her exact words are that it
feels like she's been -- repeatedly violated by the
government of Jefferson County. 3:03:32PM
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And it's pretty inexcusable, frankly.
There's literally no example of this ever having
been done ever. It was the assumption that we were
just going to take whatever was done. What was
done by the PVA is immoral, it is unethical. I
would question whether or not it is, in fact,
criminal. And it's my determination to make sure
we figure out the answers to all of the above.
Q. Very good. Thank you. I appreciate your
candor, and I know the Commission will as well,
Governor.
Your home was inspected two times in 24
months. Does that relate to part of your
observation of a moment ago?
A. It does. And that's official
investigations with people coming, going through
our home, going through our stuff, doing this in
ways that really were a violation of any sense of
privacy or any sense of precedent that's ever been
done anywhere.
And that's not to mention all the other
times, in addition to those two, of drones and
helicopters and reporters and people being removed
from the property. Lawsuits against us by local
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attorneys and things into the property to be part
of these official inspections as well as any other
ones they wanted to.
The numbers of times people have found
photos of the home, including the inside of the
home, that had been previously put out online, and
posting these nonstop on websites and passing them
around of the media. Again, with the absolute
intent of trying to undermine the security, trying
to make sure people understood the whole layout of
the house.
This is so remarkably inexcusable. And I
realize you're here as attorneys, but you're
representing something that is wrong, tremendously
wrong. It should not be done to anybody. There
should not be a citizen of Kentucky that ever has
government weaponized against them the way the
Jefferson County PVA has been weaponized against my
family, ever.
Q. Governor, Attorney General Beshear made
comments to the media reported by the Associated
Press, I think, in connection with Fancy Farm and
so-called Fancy Farm events in August of 2017.
There's an article, couple articles, I guess.
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Exhibit 5. It's two articles available online.
These are in the record already, John.
(Whereupon, said document was
marked Exhibit 5.)
Q. (BY MR. SOMMER) This is a report after
the 2017 Jefferson County Board of Assessment
Appeals ruled in your favor. So this is a news
blast.
A. Yeah.
Q. On the third page in, lower right,
Anchorage 2844, there's commentary attributed to
Attorney General Beshear where he indicates that --
he had made a referral of your house purchase and
the tax appeal to federal investigators, as best I
can read.
To your knowledge, has any federal agency
or any other governmental investigative agency ever
made contact with you concerning this?
A. No. Of course not. This is political
tripe.
Q. Very good. Then on the next page --
A. And again, to your point, these were
comments made after there had already been
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determined. But because they didn't like the
outcome and it didn't fit what they had hoped for,
they make up this nonsense. I have no idea whether
he actually did even do this, but nobody has ever
contacted us, ever.
Q. On the next page, Anchorage 2845, in the
lower right corner, the last couple of sentences of
the article reference an organization known as
Common Cause. Do you see where I'm referencing
that?
A. Richard Beliles, Chairman of Common
Cause.
Q. Richard Beliles -- this article indicates
that he was the one who filed an ethics complaint
or ethics complaints, quote, unquote, against you
in connection with the home purchase?
A. Yeah. Coincidentally, I might add, after
the Attorney General said he was going to give
money to Common Cause, the very money that Tim
Longmeyer illicitly gave to his campaign. Tim
Longmeyer, who worked for both him and his father
and is now in federal prison for buying and selling
the state.
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corruption to the Beshear administration. Attorney
General Beshear said he was going to give that
money to Common Cause. And then, magically,
Common Cause then decided to open an investigation
into my home. Just, I'm sure, a sheer coincidence,
I'm sure, yeah.
Q. Very good.
A. But it's interesting, this last comment,
here's Richard Beliles, Chairman of Common Cause,
making the comment that he's never known the PVA
to be that far off, he said. I find it interesting
that Richard Beliles has that much familiarity with
what the PVA and Jefferson County does or does not
do with respect to its accuracy.
This whole thing was an absolute setup
from day one. And this all went down,
incidentally, again, after the process was already
completed. So again, it's just -- it's a hundred
percent political, and I think Zippy the monkey
could tell you that.
Q. That's all the questions I have. Is
there anything further you would like to add on
direct?
MR. SOMMER: And I'm sure, John,
you're going to have questions? 3:09:42PM
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MR. CARROLL: Yes.
MR. SOMMER: Okay. And with that,
I'll yield the witness, John.
Do you want to take a break,
Governor?
THE WITNESS: No, I'm fine.
* * * * *
CROSS-EXAMINATION
BY MR. CARROLL:
Q. Governor, if I may have you take a look
at the deed of property.
A. Which one is this?
Q. It's the deed. It's actually -- there
was some discussion initially about -- a little
uncertainty in regard to approximately the date on
which you purchased this property. Does this help
you recollect that, in fact, it was in March as you
thought it might be that you purchased this
property?
A. Yes, 9 March -- the date of this deed is
9 March 2017.
Q. Okay. And at the bottom of page one
there it mentions -- if you will look here,
Governor Bevin, near the bottom it talks about
right of first refusal. 3:11:03PM
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A. Yes.
Q. And that gives the seller, that is
Mr. Ramsey's LLC, the right to -- if you were to
sell the property, he would have the right to -- if
you gave him a writing showing the amount that you
would sell it, it gives him the right to purchase
it first; is that basically what it does?
A. That's what a right of refusal is,
correct.
Q. And that's what you meant in terms of --
A. That's what a right of first -- right of
first refusal is not what I mean it to be. It
means -- it's literally a legally binding term. I
think you're familiar with it. And it means
exactly what it means by law, not by what I intend
it to mean.
Q. Okay. With respect to Mr. Cattan, and
you mentioned that he came to your property. And I
believe it's in mid June of 2017?
A. (Witness nodding head up and down.)
Q. Does that sound about correct?
A. Correct.
Q. And as well, there's been mention of a
Mr. John May, and he also came to your property, I
believe, or made an appraisal that is their 3:12:08PM
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Exhibit 4. I believe that's also a document, which
is dated in June of 2017. Does that sound about
correct to you?
A. Yes.
Q. When you spoke to Mr. Cattan and after he
inspected your property, did he speak to you about
the mold issue?
A. Yes.
Q. Okay.
A. That's part of why I had him come was
because it was evident, after we had started to
settle in and started moving in, that there were
bigger issues than we had imagined.
And, of course, during that spring is
when we first experienced the amount of moisture
that springs forth in that basement. And so it
caused some concern, and that's why we had him
come in.
Q. Before you actually purchased the
property, did you and your wife do a walkthrough?
A. I had been to the property over the
years. The property has been used over the years
for various functions and different things.
Q. Okay.
A. So I had, at times, been in the home and 3:13:05PM
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on the property. Knew of it. Had never been in
the basement. Did not -- I don't even remember if
I walked -- I probably walked through it. But this
was shortly after I had been Governor for a year
and a half, trying to move, got a lot of stuff
going on.
My wife handled most of this. It was
driven as much, as I said earlier, by her desire to
just have the things we talked about. None of
which, incidentally, thanks to the PVA, have we
had. With that said, it was with that intent. So
she handled most of this moving and things. And it
was after several months, including the first
spring, in that home that we realized we had some
big problems.
Q. Okay.
A. And that was why we had Joe Cattan come
in and do an assessment of it.
Q. Before Mr. Cattan came in, were you aware
there was mold on the property?
A. Yes. Yeah, I mean, that's when we
started going in there, but we didn't realize -- I
wasn't sure how bad it was or how out of line it
would be with something of that age.
Q. Okay. 3:14:13PM
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A. Structurally, too, I was worried about
settling and things. There's a lot of cracks that
have appeared in the walls and things.
Q. And Mr. Cattan has indicated that when he
spoke to you after the inspection that he actually
indicated to you that he believed that you should
look into this issue of the moisture and the mold
sooner rather than later in order to make sure that
that was taken care of?
A. Correct.
Q. You would agree with that if that's what
his testimony looks like?
A. Yes, which is -- correct. And indeed, we
have been spending -- we've -- with sump pumps and
dehumidifiers and, you know, cleaning. We've done
a whole lot of that in the two years since.
Q. Okay. And to be fair, you initially,
when you were speaking with regard to the mold
issue, you were indicating that you, yourself, are
not an expert in terms of a microbiologist --
A. No.
Q. -- or a toxicologist --
A. That is correct.
Q. -- or somebody who actually can look at
something and say that particular strain of mold 3:15:13PM
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is, in fact, a black mold; that's not something
that you're capable yourself of knowing?
A. That is correct.
Q. Okay. With respect to the house itself,
and you've indicated that it's approximately
150-year-old house?
A. It's -- I think it's older than that.
Q. Okay. And it is actually a building
which is on the historic registry for both
Anchorage and locally in Jefferson County as far as
an historic place?
A. I have no idea if it is or not.
Q. Okay. When Mr. Cattan came through, do
you know at that point in time, was the third floor
finished as of the date that he went through there?
A. I think so, yeah.
Q. How about Mr. May?
A. I think so. But honestly, I forget. I
really don't remember when the carpet was laid
down. But the floor was -- it was finished with
respect to -- the carpet may have been still laying
there.
Q. Okay.
A. Because we still owned our home here, and
because we also were living in the Mansion at that 3:16:22PM
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time, the move-in process was not a typical move-in
process. We didn't live in the house for quite
some time initially after we first bought it. And
when we did, we had kids downstairs -- I don't
remember at what point the carpet was tacked down,
but it was sometime during those first months --
during that first year that we were in the house.
Q. I'm going to show you what I'll mark as
Exhibit B.
(Whereupon, the previously
discussed deed document was marked Exhibit A.)
Q. (BY MR. CARROLL) This is a document --
if you could take a look at it just for a minute.
It actually has your page as a signature page in
the back.
A. Okay.
Q. And the main pages are seven and nine, I
believe, are the -- seven and four I think are the
questions that I have anything --
A. So which particular interrogatories do
you want me to look at?
Q. The one is on page seven. It's Number
10.
A. Okay.
Q. And I take it, again, that your signature 3:17:50PM
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here on the back -- well, on the back here there's
a signature. That is, in fact, your signature,
Governor?
A. That is, yes.
Q. And before you would have signed that,
you would have read it at least?
A. I'm sure.
Q. Okay. With respect to Interrogatory
Number 10, it states that you've had, I believe, a
water heater was replaced?
A. Correct.
Q. And then the windows on the first floor
were replaced?
A. I believe about a half dozen or so
windows on the first floor have been --
Q. And that's since you all have moved in?
A. Correct.
Q. So after March of '17?
A. Sometime after that, yes.
Q. Okay. And then an HVAC unit was
installed in the structure --
A. Correct.
Q. -- in the space where the Kentucky State
Police are on?
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Q. Okay. And then on page four, it mentions
here on Interrogatory Number 3 -- if you would look
at that one in particular -- it mentions that some
flooring was added to the basement to lessen impact
of rough/irregular foundation?
A. It was paint.
Q. Not flooring?
A. No. No, it was painted. We painted the
floor.
Q. Okay.
A. It's already a concrete floor.
Q. Okay. Do you know of any instructions
that were provided to John May when he provided his
appraisal when that was asked, or is that something
you had someone else take care of?
A. Instructions as to what? I mean, it was
as a result of the initial assessment by the county
that was completely out of line. It got all of the
folks excited. I then said, let's get an actual
appraisal.
And so an effort was to find somebody to
do an appraisal who was actually an appraiser, and
that was -- I didn't pick John. I didn't -- I
don't remember how John was selected, but he was an
appraiser that was found and agreed to do it. And 3:20:04PM
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it was his appraisal that was then submitted to the
county.
Q. Okay. Do you know at that time how many
bathrooms were on the first floor?
A. The same number that are there now. One
half bath -- no, I'm sorry, there's three toilets,
they're all half baths.
Q. So three half baths on the first floor?
A. Yes, correct.
Q. Then on the second floor there are -- is
it four full baths?
A. Give me a second. One, two, three, four,
five.
Q. Five full baths?
A. One, two, three, four, five. Full being
a bit of a stretch perhaps with a couple of them,
but yes, there's a toilet and a shower.
Q. Okay. And then the third floor has --
A. One.
Q. -- one large bath, pretty much?
A. Large being purely subjective --
Q. Well, it's a couple rooms, isn't it,
there on the third floor --
A. No, it only has -- we're talking about
bathrooms, correct? 3:21:11PM
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Q. Yes. Yes, sir.
A. Yes. No, I mean, it's one room. It's
just a one little bathroom.
Q. And the third floor actually has how many
bedrooms?
A. Three.
Q. Okay.
A. But again, they're very small. They're a
fraction of the size of this room. You know,
they're a lot smaller than -- you know, you could
fit two of them into this room. They're small
because you have limited space because of the
eaves. And they all have restricted headroom. But
there's three separate little bedrooms up there,
and one bathroom.
Q. Do you know the actual square footage in
the house?
A. I don't.
Q. With respect to Mr. May, how long have
you known Mr. May?
A. I don't really know Mr. May. I met him
for the first time when he did the home inspection.
Q. Okay. With respect to Mr. Mitchell,
would it be the same thing with him, as far as your
relationship with him is minimum? 3:22:13PM
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A. Who is Mr. Mitchell?
MR. CARROLL: I think the Governor
doesn't even know who Mr. Mitchell is.
A. I don't even know who that is.
Q. (BY MR. CARROLL) Okay. All right.
Well, that's even more --
A. Yeah, I mean, to the extent that I've met
either one of those guys before -- Mr. Mitchell, I
don't even know who that is. Mr. May, the first
time I remember meeting him -- I mean, I've lived
in this town for twenty some years. It's possible
I met him somewhere, but I've never had any
association with him or interaction with him or
knew him until I met him as a home inspector.
Q. Okay. With respect to estimates, and
with respect to the mold issue, are you saying that
the mold, as far as you know, is limited to the two
subfloors or the basement of the property as far as
you know?
A. In terms of -- primarily, yes, that's
what it appears to be. But again, we're still
having this assessed. Because the problem is when
you have ductwork, spores float, and they are
carried through HVAC systems. And that's been one
of the bigger concerns, which is why we've been 3:23:15PM
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having it tested to the full extent that we have
been.
Q. Okay.
A. But it does seem to be primarily confined
to the source of it, which is the basement of the
house.
Q. All right. And since -- you're saying
that in 2017, it was a couple of months before you
and your family actually moved into the house?
A. It was a continuous process. We moved
stuff in right out of the gate. And then -- you
know, I still have stuff that hasn't been moved in,
literally, that will ultimately be at some point.
So, yeah, I don't -- I really don't even
remember the exact timing because we were living in
Frankfort, too, as a family in the Mansion in
Frankfort for a period of time. So we were a
little here and a little there during this whole
process. But yes, it was a very -- over the course
of a year, we were in the process of moving in.
Q. But for the last several months you
certainly have lived there with your family?
A. Oh, yes. Oh, yes. Yes.
Q. And so it's yourself --
A. Yeah. 3:24:22PM
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Q. -- your wife, and you have nine children?
A. Nine children, correct. Yes. And it's
been our primary residence for certainly the last
couple years, I would say.
Q. Okay.
A. Or you know, we've been in there for --
since sometime in 2017.
Q. Do you have any estimates with you at all
as far as mold remediation or any photographs
having to do with the property showing the mold in
any respect in the house?
A. Well, this was the initial thing to
determine what we actually had, what type of mold.
Back to your earlier question, I wouldn't know one
strain of mold from another.
Q. And you actually asked them to come out
there. Do you remember when it was?
A. My wife took care of this, and I don't
remember when it was. Sometime this year. It was
this year. It was 2019.
Q. Okay.
A. Prior to that, we did a lot of sump pump,
dehumidifiers, spraying of stuff and wiping of mold
and trying to eliminate things, things of that
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or things that might attract mold spores, doing
things within our own ability to try to eliminate
this, but to limited degrees of success. In this
year is when we had these people come and actually
do an analysis.
Q. Okay.
A. My wife has a number of estimates. They
are from different people, because some people do
foundation work, some do floor work, some do mold
remediation work. And the sum total of these, it
will probably be -- I don't know, it's going to be
expensive -- a hundred thousand dollars probably.
Q. But you don't have those estimates?
A. I don't have. We have some of them. My
wife does. I don't have any with me.
Q. Okay.
A. And they've all been obtained in 2019.
And the whole purpose of this is through January 1
of 2018.
Q. Okay. With respect to the property
itself, I've seen that it is currently on sewers?
A. Well, yeah, that was being put on about
the time that we bought it. It was -- in fact,
yes, it is now on sewer, correct.
Q. Okay. And what you're saying is -- 3:26:24PM
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A. I don't remember.
Q. -- it was close to getting sewers --
A. It was. The whole lawn was torn up,
yeah.
Q. -- when you actually bought it?
A. Correct.
Q. But it would have been shortly after the
purchase that they actually were hooked up then,
right?
A. It was torn up when we bought the house,
because the whole -- the city ran the line
essentially parallel to Evergreen, but coming out
of a neighborhood that was off of whatever street
that is before our property. There were huge
trenches. It was dug up before we bought the
property.
Q. Okay.
A. But then connecting it to the house, it
was all during that same year period that all of
the things got connected. But it was -- you could
go back -- I mean, all this -- the city knows when
the city put the sewer line in. I mean, you guys
should know exactly when the sewer line was put in.
Q. I'm going to hand you one more exhibit,
which is -- 3:27:09PM
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MR. SOMMER: No objection on the
other one.
MR. CARROLL: Mark the other one
as well, yes.
(Whereupon, the previously
discussed interrogatory answers were marked
Exhibit B.)
Q. (BY MR. CARROLL) And all I believe this
is, Governor, is just the start of the bills having
to do with those hookups, including the MSD or the
sewer issues. It just basically shows the start
date, which coincides with what you've already
said. But you're welcome to look at them.
A. I would say this, though, they seem to
indicate that it didn't start until the Summer of
'18. I'm telling you, this was all done before
that, long before that.
It was trenched up -- the city knows
exactly when the city used its right of way and its
easements to dig up that property, because I assume
it was done by the city. Whether the town of
Anchorage, the City of Louisville or Jefferson
County. I don't know who did it, but it was dug up
by somebody. MSD. But it was long before these
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So when it actually got turned on or when
bills first started coming, I can't -- I don't --
if you're saying these were the first ones, then I
don't know anything different to that effect.
Q. Okay.
A. But the work was done long before the
Summer of 2018.
MR. SOMMER: Is that C?
MR. CARROLL: Is that C or D?
COURT REPORTER: This will be C.
MR. SOMMER: Yeah, MSD is C.
(Whereupon, said document was
marked Exhibit C.)
Q. (BY MR. CARROLL) And you mentioned that
the first estimates that you believe you got with
respect to the mold issue was in 2019, or that your
wife got?
A. No. The first real estimates of the fact
that it was a problem, and you've already alluded
to, was Mr. Cattan.
Q. Okay.
A. You asked me about his specific quotes
about mold, and I confirmed that that is indeed the
conversation that we had.
Q. Okay. 3:29:41PM
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A. And that was in 2017.
Q. When was -- when did you act on what
Mr. Cattan indicated to you was what he believed to
be perhaps a problem?
A. I've told you three times now what I've
done between 2017 and now. Dehumidifiers, sump
pumps, cleaning of mold, doing the best we can to
remove things that might attract mold. Same thing
I've said three times now.
MR. CARROLL: Okay. That's all I
have. Thank you for your time, Governor.
THE WITNESS: You're welcome.
* * * * *
REDIRECT EXAMINATION
BY MR. SOMMER:
Q. Governor, I have the opportunity to
redirect based on anything he's asked. Is there
anything, given what you answered for the county,
that you would like to expound on? If not, we can
conclude. But if so, feel free to do so for the
benefit of the Commission.
A. Again, I would simply say, to reiterate
what I said earlier since I've reiterated a number
of other things, the PVA and Jefferson County
should not be weaponized against any person living 3:30:57PM
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in Jefferson County, whether that person is in
public office or that person is not in public
office. It is beyond a shadow of a doubt, in my
estimation and the estimation of anybody with the
ability to observe precedent or lack thereof, that
that is exactly what has been done in this
instance.
The degree of collusion between the
state's attorney general, the PVA, their friends in
the media, and their attempt to try to politicize
the purchase of this home, the intentional attempt
to destroy the reputations of not only the person
who sold the property to me, but of me and my
family, the amount of slandering, the amount of
emotional cost would be very difficult, if even
possible, to measure given the amount of it that
has existed.
And it is my determination that this
should never happen to anybody ever again. And it
is my intent to make sure that we continue to take
this to the full extent of understanding not only
what the property is worth, but why the City of
Louisville and Jefferson County specifically and
the PVA specifically felt that it was appropriate
to use the power that had been vested in them to 3:32:44PM
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politically target somebody, because it shouldn't
happen.
MR. SOMMER: Thank you, Governor.
MR. CARROLL: Let me just place on
the record that, again, Governor, we're here for
fair market value of your home and nothing else.
THE WITNESS: We sure are.
Exactly right. Darn right.
MR. SOMMER: Thank you, Governor.
THE WITNESS: Thank you, guys.
(Whereupon, said deposition was
concluded at approximately 3:33 p.m.)
(Witness excused.)
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STATE OF KENTUCKY ) ) SS:
COUNTY OF JEFFERSON)
I, Laura L. Wagner, Registered
Professional Reporter and Notary Public in and for
the State of Kentucky at Large, hereby certify that
the foregoing deposition was taken at the time place
stated in the caption; that the appearances are as
set forth in the caption; that prior to giving the
testimony the witness was first duly sworn by me;
That said testimony was reported by me in
stenographic notes and transcribed under my personal
direction and supervision; and that said typewritten
transcript is a true and correct transcript, to the
best of my ability and understanding.
I further certify that I am not related by
blood or marriage to any of the parties hereto and
that I have no interest in the outcome of the
captioned case.
My Commission as Notary Public expires
January 8, 2022.
Given under my hand this the day
of , 2019.
_______________________________________
LAURA L.WAGNER, RPR, CCR #20042A123 NOTARY PUBLIC, STATE OF KENTUCKY
Notary ID 592505
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COURT REPORTER: [1] 50/9 MR. CARROLL: [9] 5/14 17/10 21/4 32/25 44/1 49/2 50/8 51/9 53/3 MR. SOMMER: [12] 5/10 17/8 17/13 21/2 29/24 32/23 33/1 48/25 50/7 50/10 53/2 53/8 THE WITNESS: [4] 33/5 51/11 53/6 53/9
$$1,015,000 [1] 22/12$1,390,000 [1] 22/13$1.39 [1] 23/7$1.39 million [1] 23/7$1.6 [1] 22/14$1.6 million [1] 22/14$375,000 [1] 22/10
''17 [1] 40/18'18 [1] 49/16
00016 [1] 21/10
11.39 million [1] 23/171.4 [1] 23/71.6 [1] 22/171.61 [1] 22/181/1/18 [4] 20/13 23/16 23/18 23/241/1/2017 [1] 21/2010 [2] 39/23 40/910 acres [1]
12/1310-acre [1] 10/10100 [2] 1/2 4/1612 [1] 3/1213 [1] 1/18150-plus [2] 14/2 15/24150-year-old [1] 38/617 [1] 3/1318 [5] 9/19 20/13 23/16 23/18 23/2419 [1] 21/191918 [1] 16/161999 [1] 9/1819th [2] 14/3 15/12
220042A123 [1] 54/242017 [19] 7/16 7/23 7/25 13/2 20/25 21/20 22/25 23/6 25/12 26/21 29/23 30/6 33/21 34/19 35/2 45/8 46/7 51/1 51/62018 [5] 4/18 7/15 16/12 47/19 50/72019 [9] 1/18 7/17 17/7 17/19 26/20 46/20 47/17 50/16 54/222022 [1] 54/2021 [1] 3/1424 [2] 26/17 28/1224th [1] 13/127th [1] 17/72844 [1] 30/112845 [1] 31/62:30 [1] 1/18
33/9/17 that [1] 22/830 [1] 3/1530.02 [1] 5/8
3200 [2] 1/17 2/433 [1] 3/639 [1] 3/163:33 [1] 53/12
4400 [2] 1/16 2/440202 [2] 2/5 2/940601 [1] 6/749 [1] 3/17
550 [1] 3/1851 [1] 3/8531 [1] 2/8592505 [1] 54/25
7700 [1] 6/6
8804 [6] 7/10 7/22 9/11 10/10 11/6 20/23
9900 [1] 2/89th [1] 21/25
Aability [6] 10/17 12/10 18/5 47/2 52/5 54/14able [1] 19/2about [24] 4/17 7/8 7/11 7/15 7/22 8/5 17/18 22/15 22/25 24/9 26/20 33/14 33/24 34/21 35/2 35/6 36/9 37/1 38/17 40/14 42/24 47/22 50/22 50/23above [1] 28/8absolute [3] 27/1 29/8 32/15accepted [2] 23/13 23/16access [2] 11/17 11/22
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Bbeen... [33] 7/17 9/1 16/5 19/6 22/20 24/13 25/20 25/23 27/24 28/3 28/19 29/6 29/18 30/23 34/23 35/21 35/22 35/25 36/1 36/4 37/14 38/21 40/15 44/24 44/25 45/2 45/12 46/3 46/6 47/17 48/7 52/6 52/25before [25] 1/14 6/22 8/17 12/15 13/3 17/5 20/16 20/18 21/1 21/22 24/13 24/14 24/14 27/8 35/19 36/19 40/5 44/8 45/8 48/14 48/15 49/16 49/17 49/24 50/6behalf [1] 1/14behind [1] 11/18being [13] 5/22 7/9 19/7 19/11 24/6 24/17 27/6 27/9 27/16 28/23 42/15 42/21 47/22believe [13] 12/5 20/1 22/17 24/14 25/4 34/19 34/25 35/1 39/18 40/9 40/14 49/8 50/15believed [3] 22/20 37/6 51/3Beliles [4] 31/11 31/13 32/9 32/12benefit [4] 9/10 13/22 19/11 51/21Beshear [4] 29/20 30/12
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deflection [2] 15/21 15/21degrades [1] 15/15degree [3] 17/22 20/9 52/8degrees [2] 16/25 47/3dehumidifiers [3] 37/15 46/23 51/6demanded [1] 27/14demanding [2] 27/7 28/25deposition [9] 1/13 1/19 3/11 4/21 5/5 6/16 13/11 53/11 54/6describes [1] 15/22designated [1] 5/18designed [1] 6/10desire [1] 36/8desired [1] 11/24destroy [2] 19/1 52/12detail [1] 13/14determination [3] 24/25 28/7 52/18determine [2] 17/22 46/13determined [1] 31/1did [19] 8/18 8/20 8/21 8/22 9/2 9/20 13/7 16/11 23/10 23/10 31/4 35/6 35/20 36/2 39/4 43/22 46/22 49/23 51/2didn't [12] 10/2 12/7 23/11 23/12 23/12 31/1 31/2 36/22 39/2 41/23 41/23 49/15different [5]
18/7 18/10 35/23 47/8 50/4difficult [1] 52/15dig [1] 49/20direct [3] 3/4 4/5 32/23direction [1] 54/12discovery [1] 1/20discussed [2] 39/11 49/6discussing [1] 24/3discussion [1] 33/14dispute [1] 4/17distress [1] 27/22do [37] 7/4 7/18 9/6 11/8 12/5 17/3 19/12 19/25 20/1 21/16 21/17 22/3 22/5 23/18 27/19 31/4 31/9 32/14 33/4 35/20 36/18 38/13 39/20 41/12 41/22 41/25 42/3 43/16 46/8 46/10 46/17 47/5 47/8 47/9 47/9 49/10 51/20document [18] 5/3 5/5 5/13 12/19 12/22 13/2 13/16 17/4 17/15 20/15 20/22 20/22 21/6 30/3 35/1 39/11 39/12 50/12does [15] 16/20 16/24 17/19 17/21 18/22 28/13 28/15 32/13 32/13 33/16 34/7 34/21 35/2 45/4 47/15
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Eeach [3] 12/16 18/17 18/18earlier [3] 36/8 46/14 51/23easements [1] 49/20easily [1] 10/17easy [1] 14/21eaves [1] 43/13effect [1] 50/4efficiently [1] 6/11effort [2] 25/12 41/21either [2] 6/25 44/8eliminate [4] 16/25 19/14 46/24 47/2ELIZABETH [2] 2/13 4/9else [2] 41/15 53/6embezzlement [1] 31/25emotional [2] 27/22 52/15endeavor [1] 7/1engineer [1] 12/24entire [1] 19/18entitled [4] 5/5 17/5 20/22 21/13Environmental [1] 17/8especially [1]
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excused [1] 53/13executive [1] 6/7exhibit [24] 3/11 3/12 3/13 3/14 3/15 3/16 3/17 3/18 5/12 5/14 12/20 13/1 17/10 17/16 21/4 21/7 30/1 30/4 35/1 39/9 39/11 48/24 49/7 50/13Exhibit 4 [1] 35/1Exhibit B [1] 49/7EXHIBITS [1] 3/9exist [1] 16/12existed [3] 16/14 16/16 52/17exists [3] 13/18 16/19 16/23expedience [1] 25/8expensive [1] 47/12experienced [1] 35/15expert [1] 37/20experts [2] 24/23 24/24expires [1] 54/19explain [3] 9/9 9/13 13/22expound [1] 51/19extent [7] 19/7 19/9 19/20 27/18 44/7 45/1 52/21extra [1] 46/25eye [1] 20/20
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53/6familiar [2] 13/19 34/14familiarity [1] 32/12family [11] 9/4 10/7 10/23 19/5 27/2 27/22 29/19 45/9 45/16 45/22 52/14Fancy [2] 29/22 29/23far [6] 32/11 38/10 43/24 44/17 44/18 46/9Farm [2] 29/22 29/23fast [1] 14/23father [1] 31/21favor [1] 30/7fbtlaw.com [1] 2/5features [1] 26/8February [1] 7/24federal [3] 30/14 30/16 31/22fee [1] 7/10feel [2] 7/4 51/20feels [1] 27/24felt [1] 52/24few [1] 24/12figure [2] 19/8 28/8figured [1] 22/22figures [1] 17/2FILE [1] 1/2filed [2] 4/14 31/14find [3] 24/18 32/11 41/21findings [1] 23/8fine [1] 33/6finish [1] 25/12finished [3] 6/22 38/15 38/20
Ffinishing [2] 26/8 26/9first [28] 4/3 6/12 8/2 11/11 20/19 21/19 26/21 33/25 34/7 34/11 34/12 35/15 36/13 39/3 39/6 39/7 40/12 40/15 42/4 42/8 43/22 44/9 49/25 50/2 50/3 50/15 50/18 54/9fit [2] 31/2 43/11five [4] 9/5 42/13 42/14 42/15fixtures [2] 25/22 25/24float [1] 44/23flooding [2] 14/17 16/19floods [1] 14/17floor [17] 15/25 25/13 26/4 26/6 38/14 38/20 40/12 40/15 41/9 41/11 42/4 42/8 42/10 42/18 42/23 43/4 47/9flooring [2] 41/4 41/7floors [1] 15/22flown [1] 27/17focusing [1] 20/2fodder [1] 22/24folks [1] 41/19following [1] 30/24follows [1] 4/4footage [1] 43/16footprint [1] 10/10foregoing [1] 54/6forget [1] 38/18
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28/11 29/20 33/5 33/10 33/24 36/4 40/3 44/2 49/9 51/11 51/16 53/3 53/5 53/9great [2] 13/14 19/1grew [1] 17/24ground [2] 6/4 14/5growth [1] 15/7guess [2] 9/19 29/24guilty [1] 6/14guys [3] 44/8 48/22 53/10
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29/16 29/18 30/16 31/4 32/12 35/22 37/4 39/14 42/18 42/24 43/4 47/7 52/6 52/17hasn't [1] 45/12have [63] having [7] 4/3 27/4 28/2 44/22 45/1 46/10 49/9he [26] 13/8 13/9 13/17 15/22 20/18 22/3 30/12 30/13 31/4 31/14 31/18 32/2 32/11 34/4 34/18 34/24 35/5 35/6 37/4 37/5 37/6 38/15 41/13 41/24 43/22 51/3he's [2] 32/10 51/17head [1] 34/20headaches [1] 18/6headroom [1] 43/13health [1] 17/23hearing [2] 4/22 4/24heater [1] 40/10heavy [1] 4/25helicopters [2] 27/16 28/23help [1] 33/16her [2] 27/23 36/8here [13] 4/8 4/12 4/16 7/7 26/20 29/13 33/23 38/24 40/1 40/1 41/2 45/18 53/5here's [2] 18/24 32/9hereby [1] 54/5hereto [1] 54/16highlighted [2] 18/17 18/19
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11/13 12/14 18/2 19/9 23/6 36/23 36/23 38/17 41/24 42/3 43/4 43/19huge [1] 48/14hundred [3] 26/9 32/18 47/12hundreds [2] 24/1 24/6HVAC [2] 40/20 44/24
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41/2 50/3 51/19 51/20 52/15ill [1] 31/25illicitly [1] 31/20imagine [1] 9/7imagined [1] 35/13immoral [1] 28/5impact [2] 12/6 41/4improvements [1] 22/13in [151] inches [3] 14/18 14/20 14/24incidentally [2] 32/17 36/10including [4] 18/11 29/5 36/13 49/10indeed [2] 37/13 50/23INDEX [1] 3/1indicate [1] 49/15indicated [4] 37/4 37/6 38/5 51/3indicates [2] 30/12 31/13indicating [1] 37/19individually [2] 5/6 5/17inexcusable [2] 28/1 29/12information [1] 9/3initial [2] 41/17 46/12initially [4] 19/16 33/14 37/17 39/3inside [1] 29/5inspected [4] 8/22 13/9 28/12 35/6inspection [4] 12/23 20/17 37/5 43/22inspections [1]
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35/7 37/7 37/19 44/16 50/16issues [4] 13/25 16/2 35/13 49/11it [175] it's [45] 6/6 9/3 10/1 11/24 12/13 13/1 14/2 15/2 15/24 16/9 17/5 17/6 19/12 19/20 19/24 21/9 23/22 24/17 26/22 27/9 27/16 27/21 28/1 28/7 30/1 32/8 32/18 32/18 33/13 33/13 34/13 34/19 38/5 38/7 38/7 39/22 40/25 41/11 42/22 43/2 43/2 44/11 45/24 46/2 47/11its [3] 32/14 49/19 49/19itself [6] 11/10 11/15 14/10 20/2 38/4 47/21
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JJOHN... [7] 30/2 32/24 33/3 34/24 41/13 41/23 41/24john.carroll [1] 2/9JOHNSON [1] 2/14July [1] 24/16June [3] 13/1 34/19 35/2June 24th [1] 13/1just [25] 5/2 6/7 6/25 8/15 10/4 10/25 10/25 11/1 19/5 19/8 19/12 25/6 25/20 26/1 26/5 26/6 28/4 32/5 32/18 36/9 39/13 43/3 49/9 49/11 53/4
KK18 [2] 1/2 4/16K18-S-100 [2] 1/2 4/16KENTUCKY [14] 1/1 1/16 1/17 1/20 2/5 2/9 4/13 6/6 6/8 29/16 40/23 54/1 54/5 54/24kids [2] 27/18 39/4kill [1] 19/25kind [1] 21/9knew [2] 36/1 44/14knock [1] 9/24know [33] 4/7 9/6 9/24 10/2 10/18 12/14 12/16 16/6 18/24 23/11 25/3 27/12 28/10 37/15 38/14 41/12 42/3 43/9 43/10 43/16 43/21 44/3 44/4 44/9 44/17 44/19
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37/8 52/20making [2] 27/2 32/10Mansion [2] 38/25 45/16many [5] 9/5 11/14 12/14 42/3 43/4March [12] 7/25 8/3 10/25 11/1 11/2 21/25 23/6 25/11 33/17 33/20 33/21 40/18March 1 [2] 11/1 11/2March 2017 [2] 23/6 33/21March 9th [1] 21/25mark [4] 2/3 4/8 39/8 49/3marked [8] 5/14 12/20 17/16 21/7 30/4 39/11 49/6 50/13market [3] 1/17 2/4 53/6marriage [1] 54/16materials [1] 15/14MATTHEW [6] 1/13 3/3 4/1 5/6 5/17 6/5may [17] 3/14 7/16 19/2 20/24 21/15 22/8 24/10 24/13 33/10 34/24 38/17 38/21 41/13 43/19 43/20 43/21 44/9May's [1] 23/8maybe [5] 7/25 12/1 21/9 21/11 21/25me [13] 4/9 9/6 27/4 27/9 39/21 42/12 47/15 50/22 52/13 52/13 53/4 54/9 54/10
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million [5] 8/10 22/14 23/7 23/7 23/17mind [1] 26/25mindset [1] 17/25minimum [1] 43/25minute [1] 39/13miserable [1] 27/2Mitchell [4] 43/23 44/1 44/3 44/8modern [1] 15/13moisture [4] 14/11 15/18 35/15 37/7mold [29] 15/7 15/19 16/23 17/20 18/12 18/24 18/25 20/1 20/8 20/12 35/7 36/20 37/7 37/18 37/25 38/1 44/16 44/17 46/9 46/10 46/13 46/15 46/23 47/1 47/9 50/16 50/23 51/7 51/8moment [1] 28/14money [3] 31/19 31/19 32/3monies [1] 31/24monkey [1] 32/19months [7] 24/12 26/18 28/13 36/13 39/6 45/8 45/21more [7] 6/13 10/13 14/15 18/5 26/8 44/6 48/24MOSLEY [2] 2/13 4/10most [2] 36/7 36/12
motivated [1] 27/1move [4] 19/17 36/5 39/1 39/1move-in [2] 39/1 39/1moved [4] 40/16 45/9 45/10 45/12moving [5] 18/18 18/19 35/12 36/12 45/20MR [10] 2/3 2/7 3/5 3/6 3/8 4/6 33/9 36/19 43/19 51/15Mr. [24] 12/25 13/7 13/13 15/20 16/11 21/15 22/8 23/8 34/3 34/17 34/24 35/5 37/4 38/13 38/17 43/20 43/21 43/23 44/1 44/3 44/8 44/9 50/20 51/3Mr. Cattan [10] 13/7 13/13 15/20 16/11 34/17 35/5 37/4 38/13 50/20 51/3Mr. Joe [1] 12/25Mr. John [1] 34/24Mr. May [6] 21/15 22/8 38/17 43/20 43/21 44/9Mr. May's [1] 23/8Mr. Mitchell [4] 43/23 44/1 44/3 44/8Mr. Ramsey's [1] 34/3MS [3] 2/12 2/13 2/14MSD [3] 49/10 49/24 50/11msommer [1]
2/5much [8] 6/25 8/9 10/7 19/9 23/6 32/12 36/8 42/20multiple [3] 12/12 20/6 27/17mushroomy [1] 15/9mushroomy-looking [1] 15/9my [33] 4/9 4/10 9/7 9/15 10/5 11/18 11/18 13/15 18/3 23/20 24/17 26/25 27/2 27/2 27/17 27/18 27/22 27/22 28/7 29/18 32/5 36/7 46/18 47/7 47/14 52/3 52/13 52/18 52/20 54/11 54/14 54/19 54/21
Nname [2] 5/25 12/24NATALIE [1] 2/14near [1] 33/24necessarily [1] 20/9need [2] 6/18 6/24needed [7] 13/24 25/19 25/21 26/1 26/2 26/4 26/7neighborhood [1] 48/13never [5] 12/8 32/10 36/1 44/12 52/19news [2] 3/15 30/7newspapers [1] 28/25next [2] 30/21 31/6
nine [3] 39/17 46/1 46/2no [27] 1/2 5/15 8/24 8/25 9/1 9/2 11/5 11/7 11/8 11/9 12/7 21/5 27/12 28/2 30/19 31/3 33/6 37/21 38/12 41/8 41/8 42/6 42/24 43/2 49/1 50/18 54/17nobody [1] 31/4nodding [1] 34/20none [2] 24/23 36/9nonsense [1] 31/3nonstop [1] 29/7nonverbal [3] 6/13 6/14 6/14nor [1] 24/24normal [3] 18/20 18/20 18/21north [1] 11/19not [41] 8/20 8/21 9/2 9/20 11/13 12/10 12/11 12/13 15/13 15/21 15/25 16/7 18/1 18/21 18/23 19/22 19/24 20/9 21/18 22/19 23/10 28/6 28/21 29/15 29/16 30/19 32/13 34/12 34/15 36/2 37/20 38/1 38/12 39/1 41/7 51/19 51/25 52/2 52/12 52/21 54/15Notary [5] 1/15 54/4 54/19 54/24 54/25noted [4] 5/21 8/11 13/1 17/18notes [2] 9/23 54/11
Nnothing [3] 12/14 15/23 53/6Notice [3] 1/19 3/11 5/5now [24] 8/17 9/3 10/24 12/22 14/15 15/2 15/15 16/11 17/1 17/13 19/8 20/1 21/8 22/25 25/3 25/16 26/19 26/19 31/22 42/5 47/24 51/5 51/6 51/9number [7] 4/16 39/22 40/9 41/2 42/5 47/7 51/23numbers [1] 29/4
Oobjection [8] 5/11 5/15 12/25 17/9 17/12 21/3 21/5 49/1observation [1] 28/14observations [1] 13/14observe [1] 52/5obsolescence [1] 13/24obsolete [1] 14/6obtained [1] 47/17occasions [1] 27/17occupation [1] 6/3October [1] 1/18off [2] 32/11 48/13offered [1] 22/22office [2] 52/2 52/3officer [1] 4/22
official [4] 27/12 27/13 28/15 29/2Oh [5] 12/7 14/21 15/23 45/23 45/23Okay [60] old [6] 14/1 14/2 15/24 16/9 17/24 38/6older [1] 38/7on [70] one [27] 6/25 8/10 9/11 11/8 13/17 18/18 19/15 31/14 32/16 33/12 33/22 39/22 41/3 42/5 42/12 42/15 42/19 42/20 43/2 43/3 43/15 44/8 44/24 46/14 48/24 49/2 49/3ones [2] 29/3 50/3online [2] 29/6 30/1only [8] 6/9 9/7 12/13 22/24 26/9 42/24 52/12 52/21open [3] 16/4 16/4 32/4opening [2] 16/7 16/7opportunity [2] 6/20 51/16or [59] oral [1] 4/2order [1] 37/8organization [1] 31/8other [9] 17/20 22/21 27/13 28/21 29/2 30/17 49/2 49/3 51/24other's [1] 12/16otherwise [1] 18/3our [11] 9/18 10/6 10/23
24/19 27/5 28/17 28/17 38/24 46/3 47/2 48/14out [14] 14/5 18/1 18/4 19/8 19/17 24/8 25/12 28/8 29/6 36/23 41/18 45/11 46/16 48/12outbuilding [1] 40/25outcome [2] 31/2 54/17outside [1] 27/20over [6] 6/3 15/14 27/17 35/21 35/22 45/19overpaid [2] 24/10 25/1own [8] 9/13 10/16 11/17 11/19 11/20 11/21 11/23 47/2owned [4] 9/17 9/17 23/21 38/24owner [3] 7/9 7/10 14/14
Pp.m [2] 1/18 53/12page [14] 3/2 18/16 18/16 21/8 21/13 21/16 30/10 30/21 31/6 33/22 39/14 39/14 39/22 41/1pages [1] 39/17paid [3] 8/7 22/14 22/18paint [2] 26/2 41/6painted [2] 41/8 41/8painting [1] 25/21
paralegal [1] 4/10parallel [1] 48/12parcels [1] 12/12part [4] 11/6 28/13 29/1 35/10particular [5] 19/14 27/23 37/25 39/20 41/3parties [3] 4/21 5/23 54/16parts [1] 18/10passing [1] 29/7people [18] 9/21 10/3 10/14 11/11 12/11 18/6 19/17 20/6 22/23 24/24 27/4 28/16 28/23 29/4 29/10 47/4 47/8 47/8percent [2] 26/9 32/19perhaps [2] 42/16 51/4period [3] 7/14 45/17 48/19permanent [1] 25/13person [4] 51/25 52/1 52/2 52/12personal [2] 19/5 54/11photo [1] 19/5photographs [1] 46/9photos [1] 29/5physical [1] 15/8physically [1] 27/5pick [1] 41/23pictures [1] 27/8place [12] 1/4 2/8 4/14 5/7 7/9 8/12 10/5 17/11
26/6 38/11 53/4 54/6planed [1] 16/5plus [2] 14/2 15/24plywood [1] 26/6point [8] 8/10 9/19 12/11 24/17 30/22 38/14 39/5 45/13Police [1] 40/24political [2] 30/19 32/19politically [2] 26/25 53/1politicize [1] 52/10porous [1] 14/7possible [6] 6/11 11/24 19/20 27/3 44/11 52/16possibly [1] 12/15posting [1] 29/7power [1] 52/25precedent [2] 28/19 52/5precluded [1] 11/9prepared [1] 20/23prerogative [1] 27/11present [3] 2/11 20/12 20/16Press [1] 29/22pretty [2] 28/1 42/20previous [1] 14/14previously [5] 7/3 7/4 29/6 39/10 49/5price [1] 22/18primarily [2] 44/20 45/4primary [1] 46/3prior [4] 8/21 23/24 46/22
Pprior... [1] 54/8prison [1] 31/22privacy [6] 9/16 9/21 10/5 10/6 10/23 28/19private [2] 27/10 27/15probably [13] 14/15 14/23 16/16 17/2 22/22 22/23 24/5 24/6 25/1 26/24 36/3 47/11 47/12problem [4] 17/20 44/22 50/19 51/4problematic [1] 19/15problems [7] 13/16 14/9 15/10 15/18 15/19 18/6 36/15Procedure [1] 1/21process [7] 30/25 32/17 39/1 39/2 45/10 45/19 45/20professional [3] 1/15 20/20 54/4proof [1] 26/12properties [2] 11/22 12/14property [54] 1/7 4/15 4/17 7/8 7/11 7/22 8/16 9/11 11/12 11/14 11/18 11/18 11/18 11/20 11/21 11/22 12/6 13/5 13/8 13/15 14/5 16/15 21/16 22/21 23/5 23/21 24/11 24/20 25/5 25/11 27/5 27/7 28/24 29/1 33/11 33/16 33/19 34/4 34/18 34/24
35/6 35/20 35/21 35/22 36/1 36/20 44/18 46/10 47/20 48/14 48/16 49/20 52/13 52/22PROTECTION [1] 1/1provide [3] 9/21 10/2 10/21provided [3] 1/20 41/13 41/13proximate [1] 10/1public [10] 1/1 1/16 9/3 27/12 27/13 52/2 52/2 54/4 54/19 54/24pump [2] 14/24 46/22pumps [2] 37/14 51/7purchase [8] 8/15 9/14 11/10 30/13 31/16 34/6 48/8 52/11purchased [8] 7/21 8/17 10/25 16/15 25/11 33/16 33/18 35/19purchasing [2] 8/16 10/8purely [1] 42/21purpose [4] 8/1 8/16 8/19 47/18purposes [1] 1/20pursuant [2] 1/19 5/7put [9] 15/25 16/1 25/21 25/23 26/1 29/6 47/22 48/22 48/23puts [2] 20/24 21/15PVA [8] 28/5 29/18 32/10 32/13 36/10 51/24 52/9
52/24
Qquality [1] 18/10question [9] 6/22 7/3 10/9 12/7 15/5 17/18 26/25 28/6 46/14questions [6] 6/19 6/21 7/16 32/21 32/25 39/19quibbled [1] 22/24quibbling [1] 22/19quite [2] 24/20 39/2quote [1] 31/15quotes [1] 50/22
Rraised [1] 7/4Ramsey's [1] 34/3ran [1] 48/11rather [2] 16/21 37/8read [2] 30/15 40/6real [2] 4/17 50/18realize [3] 18/5 29/13 36/22realized [1] 36/14really [9] 10/2 10/7 17/2 17/3 20/18 28/18 38/19 43/21 45/14reasons [1] 9/12recall [1] 23/1received [1] 5/9reclaimed [1] 19/3recollect [1] 33/17record [12] 4/20 5/25 9/10 11/1 12/22
13/11 17/12 20/25 24/1 24/18 30/2 53/5record's [1] 8/1redirect [3] 3/7 51/14 51/17reference [1] 31/8referencing [1] 31/9referral [1] 30/13referring [1] 25/8refusal [4] 11/11 33/25 34/8 34/12regard [2] 33/15 37/18regards [1] 10/12Registered [2] 1/15 54/3registry [1] 38/9regularly [1] 14/17reiterate [1] 51/22reiterated [1] 51/23reject [1] 23/11relate [1] 28/13related [2] 18/8 54/15relationship [1] 43/25remarkably [1] 29/12remediation [2] 46/9 47/10remember [13] 7/24 13/4 13/5 13/6 36/2 38/19 39/5 41/24 44/10 45/15 46/17 46/19 48/1remove [3] 27/4 46/25 51/8removed [2] 27/6 28/23repair [1] 13/24repeatedly [1]
27/24replaced [2] 40/10 40/13report [13] 3/12 3/13 3/14 12/23 12/25 13/6 13/13 16/11 17/6 17/18 20/24 21/9 30/5reported [2] 29/21 54/10reporter [3] 1/15 6/12 54/4reporters [1] 28/23reports [1] 24/1representative [2] 5/7 5/18representing [1] 29/14represents [1] 22/9reputations [1] 52/12residence [4] 4/18 7/8 9/18 46/3resolution [2] 30/24 30/25respect [14] 7/16 26/17 32/14 34/17 38/4 38/21 40/8 43/19 43/23 44/15 44/16 46/11 47/20 50/16responsibility [1] 6/8restrict [1] 12/10restricted [1] 43/13restriction [1] 12/2restrictions [2] 11/14 11/25result [3] 18/14 19/6 41/17resulted [1] 27/9Results [1] 21/14Richard [4]
RRichard... [4] 31/11 31/13 32/9 32/12rid [2] 14/22 19/13right [31] 5/21 7/12 8/5 11/11 12/3 12/18 13/22 16/18 18/22 19/24 21/10 21/21 21/25 23/25 27/10 30/10 31/7 33/25 34/3 34/4 34/6 34/8 34/11 34/11 44/5 45/7 45/11 48/9 49/19 53/8 53/8road [3] 7/10 11/16 20/23roof [1] 8/23roofer [1] 8/23room [3] 43/2 43/9 43/11rooms [1] 42/22rotting [1] 15/11rough [1] 41/5rough/irregular [1] 41/5roughly [1] 16/4round [2] 26/19 26/20RPR [1] 54/24rule [2] 5/7 6/12ruled [1] 30/7rules [3] 1/21 6/4 6/10
SSadly [1] 13/20Safety [1] 17/8sagging [1] 15/11said [24] 1/19 5/13 7/2 17/15 18/4 18/7 21/6 24/21 24/23 25/1 30/3 31/18 32/2 32/11 36/8
36/11 41/19 49/13 50/12 51/9 51/23 53/11 54/10 54/12sale [1] 21/25saleability [1] 12/6same [5] 22/15 42/5 43/24 48/19 51/8samples [1] 18/12saved [1] 19/9say [15] 6/25 7/5 7/23 9/1 11/1 11/2 14/6 17/13 26/10 26/14 26/16 37/25 46/4 49/14 51/22saying [4] 44/16 45/7 47/25 50/3schedule [1] 5/1scheduled [1] 4/24SCHULTZ [2] 2/12 4/10scientific [1] 20/10scrutiny [1] 26/18second [4] 21/24 26/20 42/10 42/12security [4] 9/16 10/6 10/23 29/9see [6] 15/11 18/17 18/19 21/16 22/3 31/9seeking [1] 10/11seem [2] 45/4 49/14seen [5] 5/9 13/2 17/5 21/1 47/21selected [1] 41/24sell [2] 34/4 34/6
seller [1] 34/2selling [2] 11/3 31/22sense [3] 19/22 28/18 28/19sentences [1] 31/7separate [1] 43/14session [1] 6/11set [1] 54/8settle [2] 16/6 35/12settling [1] 37/2setup [1] 32/15seven [3] 39/17 39/18 39/22several [2] 36/13 45/21sewer [4] 47/24 48/22 48/23 49/11sewers [2] 47/21 48/2shadow [1] 52/3shaved [1] 16/6she [1] 36/12she's [1] 27/24shed [1] 14/8sheer [1] 32/5shortly [2] 36/4 48/7should [8] 17/22 27/19 29/15 29/16 37/6 48/23 51/25 52/19shouldn't [1] 53/1show [6] 5/3 12/22 17/4 20/15 20/21 39/8shower [2] 25/25 42/17showing [2] 34/5 46/10shows [1] 49/11side [3] 11/20 14/14 24/7sides [1] 11/21
signature [4] 39/14 39/25 40/2 40/2signed [1] 40/5significant [1] 15/6simple [1] 7/10simply [1] 51/22since [11] 6/15 9/18 9/22 10/24 11/2 27/11 37/16 40/16 45/7 46/7 51/23sir [1] 43/1six [4] 8/10 14/20 17/2 21/8six million [1] 8/10size [1] 43/9slandering [1] 52/14slot [1] 10/19small [2] 43/8 43/11smaller [1] 43/10so [53] 4/20 5/1 5/16 6/14 7/11 7/20 8/5 9/7 10/2 10/3 10/9 10/21 11/20 12/9 13/6 13/7 14/9 14/15 14/17 15/17 16/18 17/24 18/9 21/19 21/25 23/15 23/25 24/24 25/2 25/9 26/8 26/12 26/12 29/12 29/23 30/7 32/18 35/16 35/25 36/11 38/16 38/18 39/20 40/14 40/18 41/21 42/8 45/14 45/17 45/24 50/1 51/20 51/20so-called [1] 29/23sold [2] 12/3
52/13sole [3] 5/20 9/18 25/9some [27] 6/21 7/16 9/16 10/6 11/3 13/19 13/21 16/4 16/4 16/5 18/6 18/24 19/2 23/25 25/12 25/21 33/14 35/17 36/14 39/3 41/3 44/11 45/13 47/8 47/9 47/9 47/14somebody [4] 37/24 41/21 49/24 53/1someone [1] 41/15something [6] 7/2 29/14 36/24 37/25 38/1 41/14sometime [4] 39/6 40/19 46/7 46/19somewhere [1] 44/12SOMMER [6] 2/3 3/5 3/8 4/6 4/8 51/15sooner [1] 37/8sorry [2] 7/23 42/6sort [2] 10/20 46/25sound [3] 5/24 34/21 35/2source [1] 45/5space [6] 9/6 10/13 10/22 25/13 40/23 43/12speak [2] 11/25 35/6speaking [1] 37/18specific [1] 50/22specifically [6] 7/15 8/12 15/19 18/12 52/23 52/24
Sspend [1] 17/2spending [1] 37/14spoke [2] 35/5 37/5spore [1] 17/20spores [2] 44/23 47/1spraying [1] 46/23spring [3] 7/23 35/14 36/14springs [2] 14/12 35/16square [1] 43/16SS [1] 54/1start [3] 49/9 49/11 49/15started [4] 35/11 35/12 36/22 50/2state [11] 1/16 4/20 5/25 13/15 26/24 27/13 31/23 40/23 54/1 54/5 54/24state's [1] 52/9stated [1] 54/7statement [1] 24/12statements [1] 24/10states [1] 40/9stenographic [1] 54/11steps [1] 25/18stick [2] 9/23 10/18still [14] 13/20 15/2 16/19 16/23 19/8 20/5 25/2 25/4 25/18 27/7 38/21 38/24 44/21 45/12stored [1] 19/3strain [2] 37/25 46/15street [4] 1/17 2/4 10/1 48/13stretch [1] 42/16
structural [4] 12/24 14/9 15/10 15/11Structurally [1] 37/1structure [1] 40/21stuff [8] 15/9 19/6 19/25 28/17 36/5 45/11 45/12 46/23subdivide [1] 12/8subfloors [1] 44/18subjective [1] 42/21submitted [1] 42/1success [3] 15/4 17/1 47/3sued [1] 27/9sufficient [1] 9/20Suite [3] 1/17 2/4 2/8sum [1] 47/10Summary [1] 21/14Summer [2] 49/15 50/7sump [4] 14/24 37/14 46/22 51/6supervision [1] 54/12supposed [2] 27/19 30/25supposedly [1] 27/11sure [22] 5/8 6/1 6/17 9/11 9/15 10/13 11/13 13/4 16/3 18/8 23/1 23/20 28/7 29/10 32/5 32/6 32/24 36/23 37/8 40/7 52/20 53/7surrounding [1] 12/12sworn [2] 4/3 54/9
systems [1] 44/24
Ttable [1] 21/13tacked [2] 26/7 39/5take [11] 5/4 18/12 25/18 27/7 28/4 33/4 33/10 39/13 39/25 41/15 52/20taken [5] 1/14 1/19 14/5 37/9 54/6talk [3] 4/17 7/7 7/21talked [1] 36/9talking [4] 7/11 7/14 26/20 42/24talks [1] 33/24target [1] 53/1tax [9] 1/2 4/12 4/17 7/8 7/11 7/12 23/19 24/23 30/14taxpayer [2] 26/11 26/14Technologies [1] 17/8tell [2] 32/20 49/25telling [1] 49/16ten [1] 22/6tend [1] 17/25term [3] 15/20 26/15 34/13terms [3] 34/10 37/20 44/20test [3] 18/10 18/13 18/15tested [1] 45/1testified [1] 4/4testifying [1] 5/17testimony [6] 4/23 5/22 20/8 37/12 54/9 54/10than [8] 6/13 14/15 18/5 22/22 35/13
37/8 38/7 43/10Thank [9] 5/21 6/9 10/24 20/21 28/9 51/11 53/3 53/9 53/10thanks [1] 36/10that [223] that accurate [1] 25/14that's [36] 5/1 7/20 12/1 12/22 14/18 15/7 15/16 15/24 17/12 18/14 19/22 21/11 21/22 21/25 22/6 22/11 26/23 27/11 28/15 28/19 28/21 32/21 34/8 34/10 34/11 35/1 35/10 35/17 36/21 37/11 38/1 40/16 44/6 44/20 44/24 51/10the sale [1] 21/25their [8] 10/16 26/14 27/11 27/14 28/25 34/25 52/9 52/10them [10] 13/17 18/14 29/7 29/17 42/16 43/11 46/16 47/14 49/13 52/25themselves [1] 28/25then [24] 6/3 13/17 13/21 15/8 18/11 18/21 19/11 19/13 21/24 22/20 30/21 32/3 32/4 40/12 40/20 41/1 41/19 42/1 42/10 42/18 45/11 48/8
48/18 50/3there [43] 8/11 9/16 12/15 13/6 13/20 14/6 14/22 15/6 15/10 15/25 16/2 18/17 19/4 19/7 19/16 20/17 22/25 24/8 25/12 25/17 25/20 26/10 26/16 29/15 30/23 32/22 33/13 33/23 35/12 36/20 36/22 38/15 38/22 42/5 42/10 42/23 43/14 45/18 45/22 46/6 46/17 48/14 51/17there's [24] 9/11 11/14 11/17 11/21 14/9 14/12 15/6 15/17 15/17 15/23 21/13 24/1 24/5 24/8 24/21 28/2 29/24 30/11 34/23 37/2 40/1 42/6 42/17 43/14thereof [1] 52/5these [12] 6/10 11/25 13/15 16/10 29/2 29/7 30/2 30/22 47/4 47/10 49/24 50/3they [29] 10/15 10/16 14/6 14/7 14/8 16/12 16/14 16/16 19/19 19/25 20/1 20/1 23/8 23/10 23/10 23/11 23/12 23/12 23/13 27/8 29/3 31/1 31/2 31/3 43/13 44/23 47/7 48/8 49/14
Tthey're [10] 13/20 14/6 14/7 14/8 27/6 42/7 43/8 43/8 43/10 43/11they've [1] 47/17thing [5] 24/15 32/15 43/24 46/12 51/8things [24] 9/25 10/15 10/18 10/19 15/3 15/12 16/6 16/24 18/7 18/13 19/3 29/1 35/23 36/9 36/12 37/2 37/3 46/24 46/24 47/1 47/2 48/20 51/8 51/24think [15] 6/6 8/1 8/2 11/24 17/5 24/2 24/16 29/22 32/19 34/14 38/7 38/16 38/18 39/18 44/2third [8] 19/15 25/13 26/19 30/10 38/14 42/18 42/23 43/4thirds [1] 18/18this [98] those [7] 12/5 13/19 28/22 39/6 44/8 47/13 49/10though [1] 49/14thought [2] 18/3 33/18thousand [1] 47/12thousands [2] 24/5 24/8three [12] 9/12 11/20 14/23 18/16 42/6 42/8 42/12 42/15 43/6 43/14 51/5 51/9
through [12] 11/18 11/22 14/11 27/8 28/16 28/17 31/25 36/3 38/13 38/15 44/24 47/18throw [2] 9/25 10/15Thursday [1] 4/24tile [1] 25/24Tim [3] 31/19 31/20 31/24timbers [1] 15/12time [17] 7/2 9/7 12/3 14/25 15/14 18/1 20/19 38/14 39/1 39/3 42/3 43/22 44/10 45/17 47/23 51/11 54/6times [6] 28/12 28/22 29/4 35/25 51/5 51/9timing [1] 45/15today [7] 4/11 4/19 5/2 5/16 7/7 16/19 16/23Todd [2] 2/4 4/9toilet [1] 42/17toilets [1] 42/6told [1] 51/5tolerances [3] 18/20 18/21 18/21TONY [1] 1/7too [2] 37/1 45/16took [1] 46/18top [2] 18/18 18/19topic [1] 7/3topical [1] 22/23torn [2] 48/3 48/10total [2] 22/13 47/10touching [1] 25/21touchup [1]
26/2town [2] 44/11 49/21toxic [1] 18/25toxicologist [1] 37/22traditional [1] 22/21transaction [3] 8/13 8/22 26/18transcribed [2] 6/15 54/11transcript [2] 54/13 54/13travel [1] 4/25tremendous [2] 14/9 27/21tremendously [1] 29/14trenched [1] 49/18trenches [1] 48/15tripe [1] 30/20true [1] 54/13try [8] 12/8 15/4 16/25 17/2 19/19 19/25 47/2 52/10trying [8] 14/18 14/22 19/8 29/9 29/9 36/5 46/24 46/25tub [1] 25/24turned [1] 50/1turnkey [1] 25/17turns [1] 18/4twenty [1] 44/11two [10] 9/12 18/16 28/12 28/22 30/1 37/16 42/12 42/15 43/11 44/17type [2] 13/24 46/13types [1] 18/12typewritten [1] 54/12typical [1] 39/1
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Vvalorem [1] 7/12valuation [3] 1/7 4/15 23/16value [15] 4/18 7/8 7/14 20/24 21/15 22/3 22/8 22/13 23/1 23/5 23/18 23/19 23/23 23/23 53/6various [1] 35/23varying [1] 16/25verbal [2] 6/13 6/18versus [2] 4/14 6/16very [26] 6/9 7/7 9/4 9/20 9/21 10/1 10/4 10/9 10/24 11/11 12/18 14/1 16/9 16/18 18/23 18/25 19/15 19/15 26/3 28/9 30/21 31/19 32/7 43/8 45/19 52/15vested [1] 52/25video [2] 6/16 24/18violated [1] 27/24violation [1] 28/18
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Wwant... [5] 7/2 17/4 20/21 33/4 39/21wanted [3] 9/15 10/5 29/3was [147] wasn't [3] 15/15 18/8 36/23water [3] 3/18 16/21 40/10way [5] 7/17 12/1 21/11 29/17 49/19ways [1] 28/18we [50] 6/18 9/17 9/17 15/15 19/1 19/7 19/17 21/9 24/18 27/19 27/19 28/3 28/8 35/11 35/13 35/15 35/17 36/9 36/10 36/14 36/14 36/17 36/21 36/22 37/13 38/24 38/25 39/2 39/3 39/4 39/4 39/7 41/8 45/1 45/10 45/15 45/17 45/20 46/13 46/22 47/4 47/14 47/23 48/10 48/15 50/24 51/7 51/19 52/20 53/7we'll [3] 5/12 6/23 25/13we're [19] 4/12 4/16 4/19 5/1 5/2 6/14 7/7 7/11 7/14 15/3 15/16 20/5 20/5 22/3 26/19 26/20 42/24 44/21 53/5we've [6] 15/3 16/24 37/14 37/15 44/25 46/6weaponized [3]
29/17 29/18 51/25websites [1] 29/7week [1] 8/3weigh [1] 24/25welcome [2] 49/13 51/12well [14] 6/21 12/9 14/21 18/7 20/17 28/10 29/2 34/23 40/1 42/22 44/6 46/12 47/22 49/4went [3] 14/16 32/16 38/15were [33] 10/11 11/23 14/4 14/4 15/12 15/13 19/3 24/2 24/20 25/17 27/18 27/19 28/3 28/18 30/22 31/25 34/3 35/12 36/19 37/18 37/19 38/25 39/7 40/13 41/13 42/4 45/15 45/17 45/20 48/8 48/14 49/6 50/3weren't [1] 14/22West [2] 1/17 2/4what [44] 4/19 5/2 9/6 9/7 10/11 13/23 15/16 17/21 17/22 18/24 19/2 19/9 19/10 19/13 19/22 22/16 23/18 27/19 28/4 31/2 32/13 34/7 34/8 34/10 34/11 34/12 34/15 34/15 37/11 39/5 39/8 41/16 44/21 46/13 46/13 47/25 49/12 51/2 51/3
51/5 51/18 51/23 52/6 52/22what's [3] 20/6 22/8 24/15whatever [4] 11/1 23/22 28/4 48/13when [34] 7/22 13/8 13/9 15/5 16/14 20/18 25/5 25/6 25/11 25/16 35/5 35/15 36/21 37/4 37/18 38/13 38/19 39/4 41/13 41/14 43/22 44/22 46/17 46/19 47/4 48/5 48/10 48/21 48/23 49/19 50/1 50/1 51/2 51/2where [7] 10/5 15/10 21/14 25/22 30/12 31/9 40/23whereby [1] 30/25Whereupon [9] 5/13 12/19 17/15 21/6 30/3 39/10 49/5 50/12 53/11whether [5] 19/12 28/6 31/3 49/21 52/1which [20] 5/19 7/9 10/14 11/23 12/13 15/14 19/7 22/16 26/4 33/12 33/16 35/1 36/10 37/13 38/9 39/20 44/25 45/5 48/25 49/12while [2] 5/24 9/22who [15] 18/3 24/25 27/5 27/6 31/14 31/21 31/24 37/24
41/22 44/1 44/3 44/4 44/9 49/23 52/13whole [8] 12/11 29/10 32/15 37/16 45/18 47/18 48/3 48/11why [8] 5/1 9/10 9/13 35/10 35/17 36/17 44/25 52/22wife [11] 9/15 10/5 18/3 27/23 35/20 36/7 46/1 46/18 47/7 47/15 50/17will [11] 6/20 7/1 13/1 13/23 17/10 21/4 28/10 33/23 45/13 47/11 50/10win [1] 26/21window [1] 10/15windows [6] 10/3 12/17 16/2 27/8 40/12 40/15windshield [1] 9/24wiping [1] 46/23wiring [1] 25/25within [3] 18/20 18/20 47/2without [5] 5/11 12/25 17/9 21/3 26/25witness [6] 3/2 4/2 33/3 34/20 53/13 54/9words [3] 9/13 13/15 27/23work [7] 6/2 6/5 11/13 47/9 47/9 47/10 50/6worked [1] 31/21working [1] 4/12workload [1] 4/25
worried [1] 37/1worth [1] 52/22would [43] 5/3 5/8 6/13 7/5 7/23 8/5 9/9 9/22 9/23 10/3 11/1 11/8 11/13 12/5 12/10 12/15 14/6 14/21 17/17 19/18 20/9 22/21 22/22 22/23 22/24 26/10 26/16 28/6 32/22 34/4 34/6 36/24 37/11 40/5 40/6 41/2 43/24 46/4 48/7 49/14 51/19 51/22 52/15wouldn't [1] 46/14wrap [1] 19/19writing [1] 34/5wrong [2] 29/14 29/15
XXYZ [1] 7/5
Yyeah [25] 8/4 10/21 13/8 14/21 16/5 16/9 16/17 19/22 19/25 21/21 23/20 24/4 25/2 26/22 30/9 31/17 32/6 36/21 38/16 44/7 45/14 45/25 47/22 48/4 50/11year [8] 36/4 38/6 39/7 45/20 46/19 46/20 47/4 48/19year's [2] 23/13 23/24years [8] 9/19 14/2 15/24 35/22 35/22 37/16 44/11
Yyears... [1] 46/4yes [49] 5/9 5/10 5/20 7/13 7/19 8/6 8/8 8/14 12/4 13/6 13/10 13/20 15/2 15/23 16/3 16/5 16/13 16/22 18/23 20/11 21/2 22/7 23/3 23/10 24/17 25/7 33/1 33/20 34/1 35/4 35/8 36/21 37/13 40/4 40/19 40/25 42/9 42/17 43/1 43/1 43/2 44/20 45/19 45/23 45/23 45/23 46/2 47/24 49/4yet [1] 25/21yield [1] 33/3you [167] you'll [2] 18/17 18/19you'll see [2] 18/17 18/19you're [14] 5/16 9/4 17/25 26/11 29/13 29/13 32/25 34/14 38/2 45/7 47/25 49/13 50/3 51/12you've [9] 5/8 12/2 13/2 17/5 21/1 38/5 40/9 49/12 50/19your [45] 4/8 4/12 4/18 4/23 4/25 5/25 6/2 6/2 7/8 9/13 9/24 10/14 10/16 10/17 10/18 10/19 10/19 12/3 20/8 23/5 23/16 23/25 26/21 28/9 28/12 28/13 30/7 30/13 30/16 30/22 34/18
34/24 35/6 35/20 39/14 39/25 40/2 43/24 45/9 45/22 46/1 46/14 50/16 51/11 53/6yourself [3] 37/19 38/2 45/24
ZZippy [1] 32/19