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Deposition of Jonnathan Vote 8/13/97
MAUREEN MARIE FANNO 1 1 IN THE CIRCUIT COURT OF THE STATE OF OREGON 2 FOR THE COUNTY OF JACKSON 3 4 In the Matter of the Marriage of: 5 SUSAN SAMORA COUTSOUKIS, 6 Petitioner, 7 and Case No. 94-3846-D-3 8 PHOTIUS COUTSOUKIS, 9 Respondent. / 10 11 12 DEPOSITION OF JONATHAN M. VOTE 13 PERPETUATION OF TESTIMONY 14 15 BE IT REMEMBERED THAT, pursuant to stipulation 16 of counsel for the respective parties hereinafter set 17 forth, the deposition of JONATHAN M. VOTE was taken 18 as a witness in perpetuation of testimony on behalf 19 of the Respondent, before Kaylie M. Searles, 20 Shorthand Reporter, State of Oregon, on Wednesday, 21 August 13th, 1997, beginning at the hour of 9:06 22 a.m., at the law offices of Charter & Lori, 220 North 23 Oakdale Avenue, in the City of Medford, County of 24 Jackson, State of Oregon. 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 2 1 APPEARANCES ii 2 ON BEHALF OF THE PETITIONER: 3 CRISTINA SANZ, ESQ. Attorney at Law 4 2 No. Oakdale Avenue Post Office Box 443 5 Medford, Oregon 97501 6 ON BEHALF OF THE RESPONDENT: 7 CHARTER & LORI Attorneys at Law 8 220 North Oakdale Avenue Medford, Oregon 97501 9 BY: BETH LORI, ESQ. 10 11 12 13 14 15 REPORTED BY: 16 KAYLIE M. SEARLES Shorthand Reporter of Oregon 17 ADVANCED COURT REPORTING & VIDEO SERVICE 18 909 West Eighth Street Medford, Oregon 97501 19 288 Maywood Way, Ashland, Oregon 97520 20 P.O. Box 244, Klamath Falls, Or. 97601 21 (541) 732-1988 MEDFORD (541) 488-5745 ASHLAND (541) 474-7883 GRANTS PASS (541) 732-1987 FAX 22 (541) 884-0217 KLAMATH FALLS (800) 343-3396 23 24 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 3 1 STIPULATION iii 2 3 PURSUANT TO STIPULATION between the counsel 4 for the respective parties, the deposition of JONATHAN M. 5 VOTE was taken as a witness in perpetuation of testimony 6 on behalf of the Respondent, before Kaylie M. Searles, 7 Shorthand Reporter of Oregon, at this time and place, on 8 oral interrogatories to be propounded to said witness 9 pursuant to Oregon Revised Statutes. 10 11 IT IS STIPULATED AND AGREED that all irregularities 12 as to notice of time and place and manner of taking said 13 deposition are hereby waived. All objections to any 14 testimony or evidence taken at the deposition shall be 15 made at the time and noted upon the record. The court 16 before which the testimony is offered shall rule on any 17 objections before the testimony is offered. Any 18 objections not made at the deposition shall be deemed 19 waived. 20 21 IT IS FURTHER STIPULATED that the reading and signing 22 of said deposition by the witness is hereby expressly 23 waived and that the certificate of the reporter taking the 24 deposition shall fully authenticate the same. 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 4 1 INDEX iv 2 INDEX OF EXAMINATION PAGE 3 DIRECT EXAMINATION BY MS. LORI 5 4 CROSS-EXAMINATION BY MS. SANZ 11 5 REDIRECT EXAMINATION BY MS. LORI 22 6 7 INDEX OF EXHIBITS 8 (None) 9 10 INDEX OF INFORMATION REQUESTED BY COUNSEL 11 (None) 12 13 INDEX OF OBJECTIONS BY COUNSEL 14 BY MS. LORI: PAGE LINE 15 15 5 19 8, 12 16 20 11 22 6 17 18 19 20 21 22 23 24 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 5 1 JONATHAN M. VOTE, 2 called as a witness in perpetuation of 3 testimony on behalf of the Respondent, being 4 first duly sworn to testify the truth, the 5 whole truth, and nothing but the truth, was 6 examined and testified as follows: 7 /// 8 DIRECT EXAMINATION 9 BY MS. LORI: 10 Q Would you state your name and your occupation. 11 A Jonathan M. Vote. I'm a computer programmer. 12 Q Who do you work with? 13 A Jackson County. 14 Q How long have you worked with Jackson County? 15 A About eleven years. 16 Q Do you reside in the Jackson County area? 17 A Yes, in Ashland. 18 Q How long have you been living in the Jackson 19 County area? 20 A About 21 years. 21 Q Do you know the people by the name of Susan 22 Coutsoukis and Photius Coutsoukis? 23 A Yes, I do. 24 Q How do you know them? 25 A I met Photius through doing some contract work (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 6 1 for him. I started in February of '95. That's my best 2 recollection. Somewhere around then. And I've been doing 3 contract work for him in the evenings. And I also saw 4 Susan, his estranged wife, when she would come to pick the 5 child up in the evenings. 6 Q Since approximately February 1995, did you work 7 steady for Mr. Coutsoukis? 8 A It hasn't been steady the whole time. It was 9 contract work when he needed it. It's been pretty steady, 10 but there's been some times when he didn't have any work 11 for me. 12 Q When was the last time you saw Photius and Susan 13 Coutsoukis? 14 A It was shortly before they moved to New York. 15 Q Would that be in 1997? 16 A Yes. 17 Q Beginning in 1995, for just that year, how long 18 did you have a working relationship with Mr. Coutsoukis? 19 And by that, I mean, did you work at his establishment 20 and, if so, was it on a daily, monthly, weekly, type of 21 basis? 22 A It was at his establishment in Ashland. It was 23 pretty much on a daily basis throughout that whole year. 24 Sometimes I would take Sundays off, but I did a lot of 25 work during that period. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 7 1 Q What about 1996? Was it pretty much a daily 2 basis or did it change? 3 A No, it was about the same. I'm trying to think 4 of when -- there was about a two month period when he 5 didn't have any work, which was probably about a year ago 6 or a year and a half ago. 7 Q Then in 1997, before they moved to New York, 8 would it be a daily basis or did that change? 9 A It wasn't quite as much, but it was probably a 10 good four or five days a week. 11 Q Do you know the Coutsoukis's daughter, Teddy? 12 A Yes. 13 Q During '95 through '97, did you, during those 14 years, have contact with Teddy Coutsoukis? 15 A Yes. 16 Q Did you see Mr. Coutsoukis and Teddy together? 17 A Yes. 18 Q Would you see them pretty much when you were 19 working for Mr. Coutsoukis? 20 A Yes. 21 Q Did you make observations about Mr. Coutsoukis's 22 parental relationship with Teddy? 23 A Yes. I observed him on many occasions reading 24 to her, feeding her, helping her walk. She used to have 25 difficulty walking, and he'd help her with that. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 8 1 Q How would you describe his parental relationship 2 with Teddy? 3 A I would say he's extremely devoted to his 4 daughter. I'm a parent myself, so I think I can relate. 5 Q Did you have occasions to observe how Teddy 6 responded to Mr. Coutsoukis? 7 A Yes. She responded to him very affectionately 8 when she would hear his voice, if he was in the next 9 room. Or when she'd wake up from her nap and hear his 10 voice, she'd want to go to him. 11 Q Would you describe his attention to Teddy on the 12 scale of a lot or a little? 13 MS. SANZ: I'm sorry. Would you repeat that 14 question. 15 THE REPORTER: "Question: Would you describe 16 his attention to Teddy on the scale of a lot or a 17 little?" 18 THE WITNESS: Well, I would say it leans towards 19 a lot. But he was working, so he would have a baby-sitter 20 there to watch the child, also. 21 BY MS. LORI: (Continuing) 22 Q When a baby-sitter was there, did he still 23 participate with Teddy? 24 A Yes. 25 Q By participation, does that include reading to (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 9 1 her, feeding, helping her walk? 2 A Yes. Yes, all of those things I mentioned were 3 done with the baby-sitter there. 4 Q During the years '95 through '97, did you have 5 any opportunities to make observations of Susan 6 Coutsoukis's parental relationship with Teddy? 7 A Yes. 8 Q What observations did you make of her parental 9 relationship? 10 A Well, initially, she would come to pick Teddy up 11 from Photius's house and she would pretty much just want 12 Teddy to come right away. Photius felt that that was hard 13 on Teddy and asked her to spend a little time to make it 14 an easier transition. Most of the time I observed Susan 15 when she was coming to pick Teddy up. 16 Q Now, you indicated that initially Susan wanted 17 Teddy to come right away, correct? 18 A Correct. 19 Q Did that change, then? 20 A Yes. As time went on, she would stay a little 21 bit later, maybe for 20 minutes or so. 22 Q If you made this observation, did that 20-minute 23 transition seem to help Teddy? 24 A Yes, I think it did. 25 Q Other than the observation you made about the (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 10 1 initial wanting to pick up Teddy right away, and then 2 Susan waiting for about 20 minutes as time went on, did 3 you make any other observations about Susan's parental 4 relationship with Teddy? 5 A Not really. I never saw anything negative with 6 either one, as far as their relationship with Teddy. 7 Q Did you ever see Photius be violent toward 8 Susan? 9 A Never. 10 Q Did you ever see or hear Photius be frustrated 11 with Susan? 12 A I've seen him express frustration. I guess, 13 what comes to mind is when she moved to New York. He was 14 kind of frustrated with that. 15 Q During the times that Susan was picking up or 16 dropping off Teddy, did she ever come late to do either of 17 those events? 18 A She may have. I wouldn't have necessarily known 19 that she was late or not. 20 Q Would you have known whether or not she would 21 have either failed to have picked up the child or would 22 have dropped off the child at a time that was not per a 23 scheduled visit? 24 A As far as I know, she didn't. I wouldn't have 25 necessarily have known that. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 11 1 Q Were you familiar with the schedule? 2 A Not really, no. 3 Q Did you have any familiarity with any medical 4 treatment that Teddy was receiving? 5 A I know she does have some problems of some sort. 6 She was in therapy. But as far as the details, I just 7 don't really recall if I ever knew at the time. I don't 8 think I did. 9 MS. LORI: I don't think I have any other 10 questions. I think Ms. Sanz is going to cross-examine 11 you. 12 /// 13 CROSS-EXAMINATION 14 BY MS. SANZ: 15 Q Mr. Vote, you know that I represent Susan 16 Coutsoukis in this case, right? 17 A Right. 18 Q First I want to clear up a few things. You 19 worked for Jackson County for eleven years, and during 20 that time you also did some contract work for Mr. 21 Coutsoukis? 22 A Correct. 23 Q What kind of work did you do for Jackson County? 24 A Computer programming. 25 Q Did you have flexible hours in that employment? (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 12 1 A Pretty much. Yes. Officially, now we do. 2 Before, unofficially, I did, yes. 3 Q So officially now you have flexible hours, I 4 understand? 5 A Right. 6 Q So when you did contract work for Mr. 7 Coutsoukis, on the average what would be your usual times 8 that you would be there? 9 A Initially, I would work in the evenings from 10 around 5:30 or 6:00 until 8:00, maybe 9:00 at night. 11 Q You'd arrive between 5:30 or 6:00 p.m. until 12 about 9:00 p.m.? 13 A Yes. 14 Q So it was sort of your evening job? 15 A Right. 16 Q And then sometimes on the weekends, I take it? 17 A Correct. 18 Q So the 5:30 to 6:00 p.m., was that daily Monday 19 through Friday? 20 A Pretty much daily. Initially, he was developing 21 a product that we had a deadline for, and so I put in a 22 lot of hours. 23 Q And the majority of those hours were in 1995? 24 A Right. 25 Q And in 1996, did the number of hours that you (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 13 1 performed for Mr. Coutsoukis decrease? 2 A It did a lot, yes. 3 Q And in 1997, did it decrease even more? 4 A No, it picked back up again. 5 Q And did you keep about the same schedule in the 6 evening? 7 A In the latter part of '97 or, at least, when I 8 was working for him, I started doing a more flexible 9 schedule. I would work early in the afternoon and go to 10 his place and maybe not go to his place the next day and 11 work for the county instead. 12 Q But on the average, you'd arrive at 5:30 to 6:00 13 and leave about 9:00 p.m.? 14 A Initially, yes. 15 Q And Teddy, the child involved in this case, when 16 you would show up on your typical schedule at 5:30 or 6:00 17 p.m., she had already been there for some time? 18 A Correct. 19 Q So your observations are primarily that pickup 20 and drop off time between the parents? 21 A Yes, during the weekdays. And then during the 22 weekends, she would be there. 23 Q But not every weekend; is that correct? 24 A Correct. Like I said, toward the end, I spent 25 more time there during the afternoons. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 14 1 Q And, in fact, in the past year, most of the 2 weekends were spent with Mrs. Coutsoukis? 3 A What's that? 4 Q The majority of the weekends -- 5 A With -- 6 Q He did not have Teddy, right? Mr. Coutsoukis 7 did not have Teddy in the last year on most weekends? 8 A That may be true. I don't know. I'm not sure. 9 Q Now, during the time that Teddy was there, did 10 you ever observe her wearing any kind of a brace or braces 11 on her legs? 12 A I believe so. 13 Q And was she wearing that on a continual basis? 14 A I think so. 15 Q Even up to the time of 1997? 16 A That I'm not sure about. 17 Q When do you think was the last time you saw the 18 brace? 19 A I really don't know. 20 Q You don't know? 21 A It would just be a guess. 22 Q So when you say that you saw it, you really 23 don't know when was the last time you saw her wearing the 24 brace? 25 A Right. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 15 1 Q Do you know for what period of time she wore the 2 brace? 3 A No, I don't. 4 Q One week? Two months? Three months? 5 MS. LORI: Well, I'm going to object. He's 6 already indicated he doesn't know. 7 THE WITNESS: I'm not sure. 8 MS. SANZ: You're not sure. 9 BY MS. SANZ: (Continuing) 10 Q When you say that when Teddy wakes up and she 11 hears her father's voice and her reaction to wanting to 12 see her father, wouldn't you say that's a normal reaction 13 that children have when they wake up and they look for a 14 parent? 15 A Yes. 16 Q Your children do that, I assume? 17 A Yes, they do. 18 Q Whether it's you or whether it's their mother? 19 A Correct. 20 Q Would you say it's fair to say that Mr. and Mrs. 21 Coutsoukis did not get along well at all? 22 A They did -- they appeared to at first. They 23 actually did. 24 Q They tried to be civil to each other? 25 A Yes. They would actually hang out together (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 16 1 sometimes. They seemed to be on friendly terms. 2 Q At the latter part of your employment with Mr. 3 Coutsoukis, would you say there was a certain amount of 4 tension between them? 5 A I think so. I saw Susan much less toward the 6 end. The baby-sitter would deal with it, or something. 7 She wouldn't come over. 8 Q The baby-sitter was present the entire time that 9 Teddy was there? 10 A You mean all of the time? 11 Q Yes. 12 A Most of the time she was, not always. 13 Q The majority of the time? 14 A The majority of the time, yes. 15 Q Teddy was indoors the majority of the time, 16 correct? 17 A Yes. 18 Q Even during the summertime? 19 A Well, they would take her out to play. 20 Q But for brief periods of time, right? 21 A Well, I wouldn't say that she was indoors for an 22 unreasonable amount of time, if that's what you are 23 asking, no. 24 Q So during the times that you were there during 25 the day, not just the pickup and drop off time, she went (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 17 1 in and out of the office facility? 2 A Right. 3 Q And she was supervised at all times? 4 A Correct. 5 Q How many baby-sitters did Mr. Coutsoukis -- that 6 you observed -- have employed during the time that you 7 were also involved in Mr. Coutsoukis's business? 8 A Let me try and think. I may miss some. 9 Q You can go ahead and name their names if you 10 want? 11 A There was Jen. There was another one called -- 12 something that started with a "C," Cory or something like 13 that. The last one I remember was Donna, and she was 14 there for quite a long time. I believe there was, at 15 least, one other one, but I don't remember her name. 16 Q Do you think there were other caretakers, other 17 than the four that you -- 18 A There may have been. I'm not sure. 19 Q Were there some caretakers who were only there 20 for less than a week? 21 A Well, there may have been. I don't recall any 22 that were. 23 Q You didn't know all of the caretakers? 24 A Not necessarily. 25 Q Did he have some kind of special rule, in terms (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 18 1 of his employees or other staff that he had, in how to 2 deal with Teddy? 3 A Well, I'm sure he did. You know, I never 4 baby-sat her, so I couldn't tell you. 5 Q Or how to deal with her while at the office? 6 A Well, I know he was always very concerned for 7 her well-being. You know, he would make sure the 8 baby-sitter was careful, because she had special needs due 9 to her handicap. But as far as any special rules he may 10 have had, I wouldn't have known them. 11 Q Did he ever discuss with you her medical 12 condition? 13 A Not in detail, no. He's mentioned before that 14 he's unhappy with the doctors. That there was a 15 pediatrician that he liked quite a bit. 16 Q Well, then informally did he talk to you about 17 Teddy's situation or condition? 18 A Not really. I mean, I don't know exactly what 19 she has or what she's been diagnosed with, or what her 20 prognosis is. 21 Q Did you ever hear him blame someone for her 22 situation, her medical situation? 23 A Yes. He said it developed when Susan took her 24 away from him when they first split up. 25 Q So he blames Susan for -- (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 19 1 A I didn't say that. 2 Q What did you say? 3 A He said that it happened. 4 Q You never actually heard him blame her for that? 5 A I never heard him say: It's Susan fault. 6 Q Does he ever make derogatory remarks or negative 7 remarks about Susan Coutsoukis? 8 MS. LORI: I'm going to object to that as being 9 vague. If you could specify. 10 MS. SANZ: Does he ever make negative remarks 11 about Mrs. Coutsoukis? 12 MS. LORI: Same objection, but go ahead and 13 answer. 14 THE WITNESS: I can't think of anything that 15 he's ever called her, like a name, for instance. I mean, 16 when you say -- I don't really understand the question, I 17 guess. 18 BY MS. SANZ: (Continuing) 19 Q Have you ever heard him make derogatory remarks 20 about his wife? 21 A Well, what do you mean by derogatory remarks? 22 Call her a names? 23 Q Yes. 24 A No. I've never heard him say anything like 25 that. (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 20 1 Q Does Mr. Coutsoukis have a temper? 2 A Yes, he does. 3 Q How would you describe his temper? 4 A Well, I'd say he's harmless. My dad's got a 5 temper, too, but he never spanked me in his life. 6 Q Does he blow up suddenly? 7 A I've heard him lose his temper on the phone with 8 tech support, when he called Microsoft for tech support. 9 Q And describe that. 10 A He was kind of frustrated. I heard him -- 11 MS. LORI: Now I'm going to object to 12 relevancy. This is something to do with being on a 13 telephone line for tech support with a major computer 14 company. It has nothing to do with a relationship with 15 either the wife or the daughter. Go ahead and answer. 16 THE WITNESS: Yes. I've heard him voice 17 frustration and ask to speak with a supervisor, because 18 the person he was talking to obviously didn't have the 19 answers. 20 BY MS. SANZ: (Continuing) 21 Q When you say you think he's harmless, do you 22 think he's just full of hot air, is that essentially it? 23 A Full of hot air? 24 Q What do you mean by harmless? 25 A I've heard him lose his temper, but I don't (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 21 1 think he's a violent person or has a violent bone in him 2 at all. I wouldn't say he's full of hot air, though. 3 Q When he loses his temper and gets angry, does he 4 get verbally abusive? 5 A No, I wouldn't say that. 6 Q He's never been verbally abusive to you? 7 A No. I wouldn't work for him if he was. 8 Q Do you know whether he has been verbally abusive 9 to other employees? 10 A Well, not as far as I know. I guess you'd have 11 to ask them. 12 Q You've never discussed this with them? 13 A No. 14 Q So my understanding is that you've had limited 15 opportunity to observe Mrs. Coutsoukis's care for Teddy. 16 It's been primarily the times when she's picking up Teddy 17 or dropping off Teddy, correct? 18 A That's correct. 19 Q Mostly about 20 minutes at the most, for a time? 20 A That's probably correct, yes. 21 Q The majority of time you are there, you are able 22 to observe Mr. Coutsoukis? 23 A Mm-hmm. 24 Q What would you say is the worst thing about his 25 caretaking with Teddy? (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 22 1 A The worst thing is that he can't take care of 2 her more. 3 Q Does he ever tend to be overly protective? 4 A No. I don't think so. 5 Q Are you an over-protective parent? 6 MS. LORI: Objection to relevancy. 7 THE WITNESS: No, I'm not. 8 MS. SANZ: Thank you. That's all. 9 /// 10 REDIRECT EXAMINATION 11 BY MS. LORI: 12 Q Just a follow-up question. When you were 13 talking about when Teddy would wake up and she would ask 14 for dad, did she also ask for her mom when she was with 15 Photius? 16 A No. 17 MS. LORI: I have no further questions. 18 (Deposition concluded at 9:20 a.m.) 19 --oOo-- 20 21 22 23 24 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 MAUREEN MARIE FANNO 23 1 2 STATE OF OREGON ) ) ss. C E R T I F I C A T E 3 County of Jackson ) 4 5 I, Kaylie M. Searles, do hereby certify that: 6 At the time and place heretofore mentioned in 7 the caption of the foregoing matter, I was a Notary Public 8 in and for the State of Oregon; 9 That at said time and place I reported in 10 stenotype all testimony adduced and proceedings had in the 11 foregoing matter; 12 That thereafter my notes were reduced to a 13 computer-aided transcript and that the foregoing 14 transcript is a true and correct transcript of all such 15 testimony adduced and proceedings had and of the whole 16 thereof, to the best of my ability. 17 IN WITNESS WHEREOF, I have hereunto set my hand 18 and notarial seal this 25th day of August, 1997, in the 19 City of Talent, County of Jackson, State of Oregon. 20 21 22 _________________________________ Notary Public for State of Oregon 23 My commission expires: ___________ 24 25 (541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745
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By Photius Coutsoukis, Respondent.
"I Was There"
** Under development **
