Depo Tom Bradley 030188-Edits

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COURTREPORTERS ____.___ COpyeI l i:h,rTl'1l. l'.""'IW'''ft ,\It'lm8JI I, ,IN THE U.S. JISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA PREFERRED COMMUNICATIONS, INC., ) a California Corporation, ) ) l'laintiff, ) ) VS. ) Case No. 83 5846 ) CBM (Bx) CITY OF LOS ANGELES, CALIFORNIA, ) a Municipal Corporation, and )-DEPARTMENT OF WATER AND POWER, ) a Municipal Utility, ) ) Ilefendants. ) --------) I ------I Deposition of: MAYOR BRADLEY I -----Date and time: March 1, 1988, 10:15 a.m. I Place: Ci ty Bal1 I 201 North Main Street Mayor's Cffice Los Angeles, California I Reporter: Kelly Carri11e Sandoval, C.S.R. Certificate No. 7770 I I 16 H.I E. Pa:rn Street Ar.a, CA 92701 (7:-11558-9400

3550>_. - /, I I .. II Deposition of Mayor Tom Bradley, taken before Kelly Camille a Certified Shorthand Reporter and Notary Public for the State of California, with principal ofEice in the County of Orange, commencing at 10:15 a.m., on Tuesday, March 1, 1988, in City Hall, 201 North Main Street, Maior's Office, Los Angeles, California. APPEARANCES OF COUNSEL: For the Plaintiff: Fa r row, SchL.dhause and Wi Ison BY: HAROLD H. FARROW Attorne'7 at Law 2125 Oak Gro;re Road Suite 120 Walnut Creek California 94598-9383 (415) 945-0200 For the De!endants: ED PEREZ Assistant City Attorney General CounE,el Division 1800 City HaJI East Los Angeles, California 90012 (213) 485-3HO and Law Offices cf Miller, Young & Holbrooke BY: LARRINE S. HOLBROOKE Attorne}, at Law 1225 Nineteerth Street, N.W. Washington, C.C. 20036 (202) 785-0600 ALSO PRESENT: Clinton Gallcway, Plaintiff J' Carl Galloway, Plaintiff (714) -5-58-.94-00-------------'

I letl I (213) 637-3550 2 I N D E X EXAMINATION BY: PAGE .Mr. Farrow 5 E X H I BIT S (None) I I (714) 5 ~ 8-9400 :3 -4I L (213) 6:7-3550 ( 5 10 15 20 25 Los Angeles. California; Tuesday, March 1, 1988 2 1 :0:15 a.m. 3 4 TO\. BRADLEY, called as a witness, and having been first duly sworn, was 6 examined and tesified as follows: 7 8 EXAMINATION 9 BY MR. FARHOW: O. Please state your full name for the record. 11 A. Torn Bradley. 12 Q. What is your occupation at the present time? 13 A. Mayor of the City of Los Angeles. 14 Q. What is your address? A. 200 North Spring Street, Los Angeles, 90012. 16 Q. Mayor, are you aware of the case for which 17 this deposition is being tiken? 18 A. I am. 19 Q. Pardon me. A. I am . 21 Q. And have you teen aware of it for some time? 22 A. Yes . 23 Q. How long have you been Mayor of the City of 24 Los Angeles? A. Fourteen and a half years. Q. And does JOu r cu rrent term expi re? 5589400 [j. &+ 637-3550I I I REPORTERS 26 I 5 5 10 15 20 25 II I I I I I I , 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 26 A. July 1989. Q. Have you annolnced whether or not you will be a candidate for reelection) A. I haVE!. I wLl be. Q. You will be a candidate for reelection? A. Yes. Q. Is that term four years? A. Yes. Q. Have you campaigned for any other political position other than Mayor within the last 10 years? A. Yes, for gover10r of the State of California. Q. How many t reaSHer s of campa igns have you had within the last 10 years? A. One . Q. And what's his name? A. Bruce Corwin. o. Would you spell that? A. C-o-r-w-i-n. Q. Could we have an address on that? A. He's president )f Metropolitan Theaters located on West Third Street. It's near La Canada. I don't remember the address. Q. He has been the campaign treasurer for you in each of the campaigns? A. He has been my campaign treasurer, I guess, from the beginning of time. liliWCERTIFIED (714) 55t-9400 COURT (213) 637-3550REPORTERS ..........................-.-------------6 5 10 15 20 25 I I 1 I 2 3 I 4 I 6 I 7 8 I 9 I 11 12 I 13 I 14 I 16 17 I 18 I 19 I I 21 22 23 24 I I 26 I I Q. In addi tion to campaign treasurer, do you have or have you had within the last 10 years those individuals who have some particular type of function dealing with raising funds other than treasurer? A. Yes, financial chairman. Q. Okay. Is that: :iust one or has there been several other people with that function? A. There have been a variety of people who had that function. Q. Do all of those people have titles or do any of them have tit:es other than financial chairman? A. There are many people who raise funds during a political campaign. Some have titles and some do not. I don't believe I could reca.l all of those who have been been involved in such activi':ies. Q. I see. Dealing with the title of financial chairman, how many of those have you had in the last 10 years? How many different individuals have held that position? (Whereupon Dr. Carl Galloway entered the deposition procee(iings.) THE WITNESS: I'm not sure. The most recent f i nanc ial cha i rman was Kendall. BY MR. FARROW: Q. And before that do you remember who? A. I don't remembe::. (714l5589400 (2131637-3550 7 5 10 15 20 25 -l 1 Q. the trEasurer and the chairman, who 2 prepares the reports for filing with respective political 3 subdivisions concerring campaign contributions? -I 4 A. A man, G-l-a-z-e-r, Jules Glazer. Q. And long he had that function? I 6 A. For at least 1: years. 7 Q. So those who funds, which includes 8 treasurer and finance those performing that --9 function would then convey that information to Mr. Glazer? A. Yes. 11 Q. Do you know the names of the political-12 entities in which Mr. Glazer provides reports to? 13 A. not sure I understand your question. Q. I assume that there would be some sort ofII 14 II report filed with the State for political contributions? 16 A. Yes. 17 Q. There would be some State agency, do you know 18 the name of it?-19 A. Fair Political Practices Commission for the II State and the City Clerk for the City of Los Angeles. 21 Q. Within the last 10 years, have there been any 22 reports filed with any other entity other than those two? -23 A. Not that I'm aware of.- 24 Q. Mr. Glazer prepares those reports, and then II does he submit them to you for approval? 26 A. I have to sign them. -I (714) 5 ;8-9400 r... &"'lCERTIFIED (213) 6\7-3550II II I 8 I I I 2 , ....I s 6 I 8 I :.1 1.1 :2 -, --' j 4 5 _ 6 7 5 _9 20 I ..-. 1 .i... .J..22 I 23 24 =: ') 6 I ._--------- ----------""""""""""""--- """"""""""""--Q. De you s::gn th'Ir: all? A. Yes. Q. de revew them before you A. Yes, I I.hem and sign them. Q. And de you Keep copies of them? A. No. Q. Soes Mr. Glaze' Keep copies? A. Yes. Q . And 1;.' r. ere w:) u1 d thosec0 pie s bel 0 cat e d ? A. Easiest: place, .:::l locate those copies wcc:;'c De In the City Clerk's office. They are required to be on file In there. Q. Well," would ,lssume that the City C:erK would have tr.e I'm looking for the copies. Dees Mr. Glazer keep ccpies? A. Yes. Q. Where wculd he keep those, do you Kno...."? A. His is located at 698 South Berende, Sui tel 0 2 . h a !: 's .L r, L0;3 A1 gel e s . Q . 1 'm r y I jidn't understand the name street. A. Seren, B-e-r-e-n -0. Q. ThanK you. In connection with the work for raising campaig1 funds, can you tell me what your las: campaIgn fer Dayor :ost in the way of campaign costs? A. No,: jon't know. \ -: 14) ) 58- 9... l!() (2 d) )37-3550 II 1 II .., L. 3 . ."II t" .) 6 II II 8 9 : [I II I'" II i .. ."I , ; 5 I _. v 27 I 2 I _ ;1 I ")1 :: I ,) I -. ' ..:. ''2I / f" , Q. Can you give me an approximation? A. It was ever a million dollars. How over a million. I Know. Q. What dLOu"-. campaign for governor? A. Abo'-lt nine ni.lion . Q. In the ear:ie: fer Los example, yo\.,., first ra:1 you've been in office said 14 and a talf years new. It would have been in t r, e 70's yO'-l the first time? A. The f:rst time was 1969. Q. 1969. De you recall what your campaign COSt was approximately a: that time? A. No. Q. In connection ';ith the problem with ra:.s:.n;: funds polit:cal cdlT.paigllir.g, do you know ',,'hetner not aliyone en ycur betlalf c,:,,:egorizes this source of fL:;'c1S by individuals or by ind\.,.,stry or by any other mechanic for sorting OL:t? A. Nc:. Q. So for example, within the movie ir.dustry, you wouldn't have 3ny idea what percentage campaign funds came A. : have no idea. Q. Or hcusing or cdble televisior.? A. N:J. Q. Do you (now whether or not you received (71-! I 551:940il l((213) ,::'Y3550 ---------contributions from tne cable television industry? A. Yes, :'m sure that I have received funds the cable television ind..: s try. Q. from tte tousing industry? A. Yes. Q. In connection the housing industry, d= y=u recognize tne name Eli 3road? A. Yes. Q. And Kal.fman & llroad? A. Yes. Q. And that is a tuilding company, a development cor-ipany? A. Yes. Q. Tr.ey have a numl)er of subsidiary companies and engage ir: the of land, residential primarily; lS that ccrrect? A. That's correct. Q. Do you know whether or not you have received campaign funds from cOlnected with Kaufman & Broad? A. Yes. Q. Coulc yo give some idea of how much? A. I have nc idea. Q. Your records would show that though? A. Yes. you ide1tify individuals who were & Broad bu: who contributed in their (71'41 S 58-9WO (213. (3-'-3;50 I I I I I I I I I I I , 1 2 3 4 5 6 7 8 9 10 11 1 2 1 . .., , h .:..6 I 1 Q u ':9 2C 2: :) 2 -.L .. I Q. How employed by Kaufman 11 o'wn name? A. :;: don't know. :;: would have no way of kno'..;ing. Q. In connection with your position as Mayor of the City of Los Angeles, how flany City Councilmer, a::e 6 there? A. FiEteer.. Q. And are :he councilmen elected by district or city-wide? A. They are elected by district. Q. Are there any at large? A. are not. Q. Of course, you were elected by the full city? ' A. That's correct. " c. Q. Are tnere any ether officials of the City cf Los Angeles elected ci:y-wide Jesides Mayor? A. The C:ty Attorney and the City Controller. Q. In connection witl the regulation of cable 19 television, do you know whethe: or not the City Attorney's off.ice has any function at all> 1 t 2: A. Yes. Q. And could you tel:. me what that is? 2 3 A. City Attorney adv:ses as to all legal 2; matters, contracts, franchises. in regard to the 2 Telecommunications Department. 2t> Q. Does it advise the City Council? (7:; 4- i 558- 9 .00lli& Y1CERTIFIE'8 (213) 6.37-.3,50I 12 I I A. Yes. Q. Does it advise the Mayor?I "' :) A. Yes. . "'II Q. You mentioned, I think, theI 5 'Telecommunications DE'::lartment? I A. Yes. 6 I --; Q. Is that :he prop!r title of that particular department? f A Yes, i t S .I 9 "- i_! Q. And that's a Ci t:' agency? A. Yes, it is. 1 , Q. Jo you k:-Io\-,' the title of the head of the L j ,;:gency? .... A. General . -. ') Q. !s it ca!led a department or agency? t) A. A departrrent. Q. How is the head cf the department selected? A. The is made by the Mayor. Q. Is it subject to confirmation by the City LV Council? A. Yes. Q. how many such agencies or departments are there in the City? 2.: A. Approxima:ely 32. 2S Q. And all them w)u:d have heads nominated by the Mayor and confirmed by the Council? 2S 14) 5:, K- s.; 00r.. &"lCERTIFIED (213: 0"'-3550I II I 13 L I I A. No. :2 Q. Tell me the difference?I 3 A. may be six or seven that are selected and by the Mayer subject to confirmation by theI '. City Council. M550REPORTERS 5 10 15 20 25 A. Nc,. 2 3 4 6 7 8 9 11 12 13 14 l6 17 18 19 22 23 24 26 Q. Do yoc know what equipment is installed for cable? A. Nc:. Q. Would you recognize the phrase conduit, cable television conduit? Would you recognize that phrase? wire some A. Yes. Q. What is it in your mind? A. Encased Q. Encased wLres? A. Encased. Q. TO ,encase wj res? A. (Witness 1":.0(,5 head affirmatively.) Q. HaVE you eVE'::: seen a cable television wire? A. I d :' n \ t r e C.: I 11. Q. DO you have any idea what a cable looks like? A. It's possib.e that I may have seen this 1n demonstrati8n, don't have recollection of it. Q. Wot.:ld you helve any idea any, between a ce,b::"e wire A. No. Q. Any d"-fferellce between wire and a telephone A. No . any independent of the difference, i.E and a power wire? a cable television . I -+} 55b9... UO (2)) 3550 Q. Then I th3t you would have no idea of the difference between a p=wer supply for a telephone and a power supply for caole te:evision? A. That I s c,) r r e ct. Q. Or what a power supply would look like? A. Correct. Q. You also that the fourth from the last item that you was how cities issued franchises. I believe that W3S the phrase. At this I'm paraphrasing. and I may inaccurate so if I misstate it don't hesitate to correctne. I think that was what you were telling me. You how cities issued Era:lchises. A. That's correct. Q. How did do tlat? A. In a: various conferences conducted by the t;a'::ional of Cities or the U.S. Conference of Mayors. Q. Ho',.,' did you -- h:t I s pass that for a moment and come back to it. Just that you mentioned the structure and costs of cable:elevision. Let me ask you first what you meant by A. The various faci .ities that they would be required to instal: from stud.os to, I guess, power boosters so that the transrnis!,ion could be carried for required distances. i 714,: 5')8 (213: I I I I , I I I 2 5 6 ", f 8 , , _ v ':1 :.5 :6 17 :'8 20 21 2"L 2S 26 37 5 10 15 20 25 .1.1 1 II 2 3 .. II 6 -) I 8 I 9 I 11 12 I ' .1-.5 I 14 I 16 17 I 18 19 I I I 21 22 23 24 I I 26 I , Q. I see. So when you use the phrase "structure" you' re refe -ring to a physical thing than the crganization 0:: the industry or sorr,ething that? A. That's correct . Q. You were about such things as Excuse me for just a moment. MS. HO:'BHOOKE: Cff the record. (Pause in the proceedings.) (Whereupon Dr. Carl Galloway left the deposition pr:ceedings.) (Record rea:3.) BY MR. FARROW: Q. Mr. Mayor, I think before we had a break here I was a:;king you about the phrase "structure and cost" tha': I made a note of. I think we estab2.:'s.'1ed that when you used the phrase "structure," were referring to the physical items involved in the construction of the cable television system? A. Yes. Q. I think you described something that sounded like a power booster for transmission? A. (Witness nods head affirmatively.) Q. That might be what we would call an amplifier, think, or sonething of that sort. A. Yes. Q. Where did yO] do that study? Where did you 14) 5589.... 00r... &-lCERTIFIED 213) 6?l!?l550 I I LI 38 II II , .... 2 3 A "-9 l:. J 6 7 B -9 10 II 11 1 .... L 'II -, ..) .;II II .. S 16 7 I 18 19 I 20 I 21 22 ) ':';I "- .J 24 I 2':: I 26 r:ave occasion to learr: ab,)ut that? A. :::n Washinglo:l, C.C. Q. ;',nc do yOJ when that was? f.1 Mar:y aco. In fact, it was before I was elected Mayor. Q. I see. Who you dealing with at the tIme? were you worklng A. As I recall, the National League of Cities had brought in consul:ants who were familiar witt: the cable industry and its operation, and they were briefing varioc.s City officials on how the system worKed. Q. And tris was .'hile you were a candidate fer tJ,ayor? A. No. I was a rrember of the City Council. Q. Before we leave that, do you recall what learned in with the structure of cable :elevision? A. No. Q. Can you give u!; anything at all about that? A. No. It was a ,'ery cursory kind of tr,ing. don't r,ave any specific :ecc.5 0 ) [ 2 } .\.t (,3" 3:> 5(1 39 _._--- I - .. ..-I I I 2 3 I 4 5 I 6 I .., I 8 -9 . (; _u . , 12 II 13 II 14 J5 16 17 II ::'8 19 II 20 21II 22 .. " ,

II 24 II 25 26 II II Q. always has problems trying to deal a phrase like "enormcus costE". A. Enormcus costs to me would be many millions of dollars. Q. Many millions of dollars to operate a cable television system in Los Argeles is what you're saying, gather. It obviously wou:dn't cost that much in other towns. MS. HO:'BROOKE: 'l'hat's not what he said. HIS reference wasn't to the City of Los Angeles . BY MR. F.n.RROW: Q. I'm confused . I'll try it another way. Can you think of some way that you could indicate to me with reiative terms what you wou::'d mean by "enormous costs" of' a cable television business and something else? A. Because a good indices would be the sale of television conpanies might run anywhere from 8 to 15 if. ill ion 0 r mo r e . Q. Do today h3ve any idea what costs to build a cable television system by any standard? A. No. Q. Per mile, per :ustomer, per house, per company? A. The answer is 10 to all of those questions. Q. Have you had o:casion to do any studies concerning the value of cable television companies on any en 55 g. 9400r- & lCEIZTIFlEDCOCRT 40(213,1637 3550 LII I REPORTERS I I ) I '") .L :3 I 'i I "., 6 I he: put their pipelines in. I Q. If I were to ouild a building and needed to be able to dig up the E.treets to hook up the sewer line, I wc:,uld have to pay the City in order to be able tc d_ t::.:::-, I A. Yes. . :3 Q. Are you with alarm companies? I I MS. HOLBROO!-(::::: !\larm companies? MR. FARROW: YE: S THE WITNESS- Wnict alarm companies? I BY MR. Burglar alarm companies, tha: type of th:.ng.I A. Yes. I Q. Do you haVE them in Los Angeles? I ('\4 5)(-)9,*00 - :3; '-355l1 I ..-_..-------------_._._- " u-I I I A. Yes. L-Q. Do you f:alchise burglar a:arm A. We permlts for I :; Q. But 5 A. That's:lght. I L Dc franchise fees? I ! A. No. We them permit tax. 8 I C'. Do you c:lar(3e them a franchise fee because .;; their wires from ?lace to place in the City? I A. They charged a permit fee to exercise ove: then to insure that they are competenp_i I / staffed and to aSSllr'? that when there are false ..0 the Isn't to be sending its fire police -..:; personnel to every fslse alarm without some means ofI "I those _ c Q. Has anybody had occasion to advise _. of different kincs of companies who I :b t ran SIT: l S S 1 :: n wires :f various kinds on utility poles? ..L:1 A . I )('1 Q. 'I a '," wO'... ld :lOt know then that in L p::Jwer and ne a number of other compan:e I I use these poles? 2 A. I kn)w. 2" Q. And t::J the extent they do, you have no I " 2 ': i nfor 111 d t i 0 ,) t hat the y are f ranchi sed, whoeve r the y IT,':' 9 ;, ' ,J 26 be? I I .... 'i)c''J-tuc' ( :2 I () r -355(1 I --------------------------------------.,:f U:E'Y e >.1 st Q, :::f tte'l e). i st 3 MR. PEHEZ: Eo\>; much more do yo!.: have? MR. FARRO,': I have :.he rest of the day. 5 ,,--q. PEREZ: Let's taKe a break. 6 (Rece:::s tr..o{en.) 7 BY M...l:(. O. Mr. Mayor, I !.:nderstand you 8 nave some calendar prot>le:n:3 here about tomorrm.;, re 9 nc: avai_able tomerrow mcrning? A. Absolutel] nJ:. Q ' Yc -' t'" C _sea ._ lie r t his rna r n i n9 f a [k? e ':. :. you recall in with Six Star. Tne .:.3 refreshed your concerning Six Star . I ' IT. -... , trying to establist wh was at that meeting bes:de yourself. You indicatf the Galloway brothers and Chann:ng Johnson. A. I'm serry I nodded. I should have said ye . Q. Mr. was there? 2_ 9 A. Yes. 20 Q. And Councilrran Farrell was there? A. Yes. 22 Q. And Cnannlng Johnson worked for Councilman 23 Farrel.l, right.? 24 A. He did was working for Mr. 26 Q.. Well, at one time. I am not sure whetner ne Farrel: at that time or not. meeting you're , -:' 1:t, 55 b- 9 ..0ll CT'r have been well before 19B3. 2 nave been a )ack in 1980 about? 1 A.. 1t .. 'as before 1983 , I'm sure ..have been 1980. Q. The were representing a groupI o called Universal Cable at that time. Do you recall the 7 A. I :ecall :ne name Universal. I dO:1' t k no\-; : f I that's the group they :epresented. Q. I see. Also at that meeting was I :J.arris? A. Yes, I kr.::.. ''''; :::f him.I Q. He's of yours? I A. Yes. Q. is tte relationship with Mr. Harris? I MS. HOL3ROOKE: :';"" sorry. Wrat relationship is he to WnOG? I BY MR. FARRO";: ;). you. I I've known him for a time. Q. And then Eishcp Brookins? I A. 2.2 A. I know Mr. Brookins. I Q. Was he at the meeting? A. I don't re2all if he was there. I I Q. And de you recall Mr. Bakewell being there? .:. t A. I know Mr. Bakewell. I don't recall i: I r... G'+'lcE::nlFIED(OeRII I II REPORTERS I I I was at meeting. I"e: possiDle. Q. The was at your office?I A. Yes. I ".. Q. And t. he p" r pos e (J: the me e ting was t 0 P''-': together the applicant:; for the franchise in the SOuth I Central ;):..strict; is t::lat right? A. That's cerrect. I I Q. As I undelstood it, what you were doing wa suggesting that thE' c:.1 y no involvement with the pe:)ple a:..19 the meeting but no involvement with anybody else. Tn I I 20 .. c the r wo r d s, yoc didn 't got 0 r. Elk ins and say, " Yo d 21 taKe care of this probler;; froIT. now on," correct? 22 A. That's correct. I 23 Q. You had no involvement at all after that? I 24 A. That's correct. 25 I Q. Have ycu had occasion during the course 2E your conversations other than your '+lCERTIFIE:D \ 71 .:t) 5 58 Si4 (I( II r... i:2 13; () 3 - -3 5SCII I I I I - -over the last couple of years to hear a phrase "c::r'.e May r I s G r 0 up" as be i n 9 a f r a. nchi sin9 9 r 0 up? H a v e yOJ 3 heard that phrase before? .j A. No . Q. Are YOL aware of a group that took part II ..... _c franchising efforts and referred to themselves as "e .f;cyc.: 's Group"? 1:: ""l-:=(. PEREZ: Which franc!l:.sing efforts are YCL S< +::.alkir.g about? "m. FARRDW: ':'he :ra1chising efforts of the Ci:y of , , - Les Ar.geles. , " MR. PEREZ: Which area? , BY ,....R. FFLRROW: Q, The whole area, as far as ::'r;, 2.4 :: ncerned. .... Are yeu awa:'e of any group that called l6 themselves ":he Mayo::-'s 1 -, i A. r'm not awale of it. I .l b Q. I assume thE'n that you never gave anybody s aut her it l' tor e fer tot hEms E' 1 ve s as"The Ma y0 r 's G r 0 uf.''' ? I 2C A. That's corrEe:. I L_, Q. If they werE doing it, they were doing it 22 without your knowledge? I '") "-- A. If they did it, they did it without my 24 approval or authority. I 2S Q. Going back to one of the earlier 26 asked, Mr. Mayor, 'with res ct to YO'J[ studying proces; ccI I C'" 1 -t! 5 [ ... &"'lCERTIFI ( :: : {, I"} ) - ':' (Jill ,."IH-_: .....,f ,T...,.I _.--_.-----learning p:ocess do ycc 2 whether or not anyb()dy 0:1 behalf of the City of Los .l Angeles has, at any time up to today, made any study h ' 1 1_ h '. ;:4 the any, of .. av1ng more tr.a c. :: L E cable te::'evisio:1 sy!;ten? 6 A. I ' IT, nOl .i:H'a re of any such study. 7 Q. lne you awa:, Eo of any study done by anyt::::dy 2 beha f of the City (If Los Angeles up until today Q with the subject matter of environmental concerns in :0 -' with cable te:evision in any way? 1 ... 1 A. In terns cf study, I'm not aware of any : 2 study. I recall hearing corrunents at one time or anothEr 1 -,-.l about blight as a of wires being strung 10 varic_ ;. , ... . parts of the City. 2.5 O. Dc you recall who might have made those :6 CGmIT:en t s? , ..., ..i.. J A. No, I d:)r.'t. 18 Q. Was it your impression, from what ::'9 recall, that they mi3ht have been speaking as a I 20 any kind of a study )[ just somebody's opinion? 21 A. There w!s no reference to study. It ',a:3 22 simply a matter of C1)lTlmon discussion.-, 23 O. Some bod:; saij something about blight witn 2':: wires? I 25 A. nods head affirmatively.) 26 Q. You don t have any idea what a cableI (-} .... 5Sb9.."UCI r"'i &I" 1crnTI FlED \..2 1); c:: J..- 3') 5(.I I : 'II,'" ....... Q. Did your office. your knowledge, have 20 input into the actual draEti1g of any of the cable .2 .. television franchises or '.. as tr,at done by the 'J .(,.. .: 'Telecornrnunications or Tra lsportation people and the Ci: y :23 Cc;,uncil? " J'\: "i A . My office had noth.;.cg to do with that . 25 Q. Mr. Mayor I in this case, Preferred 26 Communications has su:)mitted a set of Interrogatories ar,e -----------.-.-(71'; , 556-,),>(,,1rI'" &illCERTIFIED (n3! 12EI . hH ' m,.; ---------y :r:e responses were prepared. It says Response to ") Third Set of propounded to tre of Los Angeles and Department of Water and Power. ';1 These were sigred by Mr. Perez on or about :) 30th, 1986. He signed of the City rney's office. It's a document, some 53 pages before you get to the signature line. E I have made a couFle of of my own in I want you to glance through it and see whether or n t recognize it as being anything you would have ;., .. participated in preparing responses. I don't know whether 2 Cr not but that's going to be my question. A. Were those asked of the Department .., -1 0: Water anc Power? n>.t. They are asked of the Defendants and the .:. G Defendants are the City of Los Angeles and the Department of Water and Power. They are responses made on beha'f of .:.8 tr,e Defendants. 9 MS. HOLBROOKE: You him to review them to :: 0 see -"1 ..;, ... MR. FARROW: I don't oJ ant him to rea c t h emaIl t b;.;,:. .:, ./,., if he could glance through t:1E questions and answer and .l.j see '..'hether or not he had an:; role the preparation of i responses. ').:; THE I have not seen these before r.or did 2' 6 T have a:rything to do with the prepara':ion. (714 r... G (2:31 63 :.29I II I - ( BY ['ARROW: Q. Okay. T11at'S as good a place 2 as to breaK today. d: appreciate your coopera:i 3 II:a1'::r. This is not a:1 taSi