Schwager, Lisa Deposition

7/27/2019 Schwager, Lisa Deposition

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In The Matter Of:

Caffrey vs.Gladwin Community Schools, et al.

LISA SCHWAGERMay 29, 2013

Mid-Michigan Reporting LLC

1606 W Carpenter StMidland MI 48640

(989)835-9171

Min-U-Script with Word Index


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Mid-Michigan Reporting LLC (989)835-9171

LISA SCHWAGER - May 29, 2013

1 STATE OF MICHIGAN

2 IN THE CIRCUIT COURT FOR THE COUNTY OF GLADWIN

3

4 PHILIP CAFFREY,

5 Plaintiff/Counter-Defendant,

6 vs. File No. 12-6665-CZ

7 GLADWIN COMMUNITY SCHOOLS, GLADWIN COMMUNITY SCHOOLS BOARD OF EDUCATION,8 SALLY HIGHTOWER, KELLY GOWER, GREG ALWARD, TREVOR GRAVELLE, BRAD WITHROW,9 LISA SCHWAGER, LINDA WINARSKI, RICK SEEBECK, JULIE A. SHEARER, jointly10 and severally,

11 Defendants/Counter-Plaintiffs. ______________________________________/12

13

14 DEPOSITION OF: LISA SCHWAGER

15 May 29, 2013, at 3:05 p.m.

16 401 West Cedar Avenue, Gladwin, Michigan

17

18 APPEARANCES:

19 For Plaintiff/ CLINE CLOSE DYER Counter-Defendant: BY: KURT N. HANSEN (P14622)20

For Defendants/ O'NEILL WALLACE & DOYLE21 Counter-Plaintiffs: BY: DAVID A. WALLACE (P24149)

22 ALSO PRESENT: PHILIP CAFFREY

23

Reported by: DIANE KRAYNAK, RPR, CRR, CM, SCC24 Certified Shorthand Reporter 2122 (989)835-9171 Fax: (989)835-606425


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1 -----------------------------------------------------------------

2 EXAMINATION INDEX

3 -----------------------------------------------------------------

4 PAGE

5 Examination By Mr. Hansen 3

6

7

8 -----------------------------------------------------------------

9 EXHIBIT INDEX

10 -----------------------------------------------------------------

11 PAGE

12 Schwager Exhibits:

13 1 - Board of Education Minutes 17

14

15

16

17

18 LISA SCHWAGER,

19 having been first duly sworn,

20 testified on her oath as follows:

21

22

23

24

25


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1 EXAMINATION

2 BY MR. HANSEN:

3 Q Would you state your name and address, please.

4 A Lisa Schwager, 410 South Antler Street, Gladwin, Michigan,

5 48624.

6 Q And you're a member of the Gladwin School Board?

7 A Correct.

8 Q And how long have you been a member?

9 A Since May of 2010, I believe.

10 Q You know Mr. Caffrey here?

11 A Um-hum.

12 Q Have you ever met him before?

13 A Before I was on the Board?

14 Q Before today.

15 A Yes. We went to the same church, Sacred Heart Church.

16 Q Have you had any conversations with him in the past two

17 years?

18 A If it was like seeing him on the street or seeing him

19 somewhere, maybe hi, how are you. Probably nothing more

20 than that.

21 Q Have you had any conversations concerning school business or

22 anything else of that nature?

23 A No.

24 Q Do you have any fear of him?

25 A No.


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1 Q Were you aware that a motion for protective order was being

2 filed in this matter?

3 A Was I aware?

4 Q Yes.

5 A I don't recall that, no.

6 Q Now, on December 24th there was a special meeting of the

7 Board of Education?

8 A Yes.

9 Q Do you remember that meeting?

10 A I remember there being one, yes. The morning of, yes.

11 Q And what was the purpose of that meeting?

12 A If I recall correctly, it was to approve some documents that

13 we had to have in a time -- certain time frame.

14 Q Okay. And that had to do with some legal filings in this

15 case?

16 A I believe so.

17 Q And you went into closed session, is that right?

18 A Right.

19 Q And the minutes indicate that you seconded the resolution to

20 go into closed session. Do you recall doing that?

21 A I don't recall, but I'm pretty confident if the minutes said

22 so, then -- then I more than likely did.

23 Q But you don't have a specific memory of doing that.

24 A No.

25 Q Who took the minutes that day, do you know?


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1 A I don't recall. Usually it's our secretary.

2 Q Mr. Withrow?

3 A Mr. Withrow.

4 Q And he takes the notes, is that right?

5 A Yes.

6 Q Do you know what he does with those notes afterwards?

7 A No -- I mean, I -- I could say I assume what he -- I -- he

8 does but I don't know for sure. Usually they go right to --

9 to Julie and then she types them up.

10 Q She types them up, right?

11 A That's what I recall it as.

12 Q Now, part of the minutes indicate that you resolved to

13 authorize Mr. Wallace to represent you and to pursue certain

14 counterclaims, is that right?

15 A I don't recall. What does it say --

16 Q Here, I'll show you the minutes. It's down there towards

17 the bottom.

18 A Um-hum. Okay.

19 Q So, by that resolution, you were authorizing Mr. Wallace to

20 file a counterclaim on your behalf against Mr. Caffrey, is

21 that right?

22 A Against these case numbers, correct.

23 Q Right.

24 A Um-hum.

25 Q And prior to the meeting did you read the counterclaim?


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1 A I don't recall.

2 Q After the meeting did you do so?

3 A I don't recall.

4 Q Prior to voting do you recall ever having read the

5 counterclaim?

6 A We -- we usually do read them when we come to the meeting.

7 We have a certain time frame where we can read over, um-hum.

8 Q And did that happen in this meeting, do you recall?

9 MR. WALLACE: I'm going to object. There's no

10 discussion about what happened in the closed session.

11 Don't answer that question. Attorney/client privilege.

12 MR. HANSEN: I'm not asking about the closed

13 session. I'm asking whether or not she had a time period to

14 read it before the closed session.

15 A I don't recall. Usually that's what we do, but I don't

16 specifically recall.

17 Q Okay. Now, there's some language in there towards the end

18 that says "in any other matters" or something to that

19 effect. Do you see that? It's at the end of the resolution

20 there.

21 A "And any others as applicable", yes.

22 Q What does that refer to?

23 A Any other matters concerning these two case numbers.

24 Q Okay. It's not some other lawsuits or anything else like

25 that.


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1 A Some other lawsuit? No; it should be right to those two,

2 "and any others as applicable".

3 Q Now, when the first lawsuit was filed in this matter, that

4 concerned the FOIA requests for phone bills and details and

5 that type of thing, do you recall that?

6 A I do recall something about them, yes.

7 Q The Board never met concerning that, did it?

8 A I don't recall.

9 Q Okay. Do you recall having any deliberations whatsoever

10 concerning that lawsuit?

11 A As a Board?

12 Q Yes.

13 A I don't recall.

14 Q Did you have any conversations with any Board members or Mr.

15 Seebeck concerning that case?


17 Q Did the Board ever authorize Mr. Seebeck to notify the

18 insurance company?

19 A Concerning?

20 Q Defending that action, that first case.

21 A Did we ever -- repeat your question again.

22 Q Did the Board ever vote to authorize Mr. Seebeck to contact

23 the insurance company to provide a defense in that case?


25 Q So you don't remember any conversations concerning that case


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1 whatsoever one way or another?

2 A Correct.

3 Q Do you think it would be likely that there would have been

4 discussions about that case?

5 MR. WALLACE: Form and foundation and you're

6 asking the witness to speculate. The question has been

7 asked and answered.

8 Q You can answer.

9 A Repeat the question again, please.

10 Q Well, you're being sued, okay? The school system's being

11 sued, okay? You've already indicated that, in other

12 matters, you normally would read pleadings or something, you

13 know, there would be a time for doing that.

14 A Um-hum.

15 Q Do you think it would be likely in this case that you would

16 have had conversations about this lawsuit?

17 MR. WALLACE: Form and foundation. The question

18 has been asked and answered.

19 Q You can answer.

20 A It would be likely that we did because we usually have that

21 time frame.

22 Q Okay. But you don't have any specific memory of it.

23 A No.

24 Q Now, in the counterclaim that you filed against Mr. Caffrey,

25 you claim that he libeled you and slandered you.


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1 A Me personally?

2 Q Yes.

3 A Well, I know that he has -- well, family members of his

4 have. He directly to me?

5 Q Yes.

6 A No.

7 Q Did he make any false statements, oral statements, to any

8 third parties that you are aware of?

9 A I don't recall.

10 Q And did he make any written statements that were false

11 statements about you to anybody?

12 A I don't recall that.

13 Q You've also sued him for intentional infliction of mental

14 distress, okay? And you claim that his conduct towards you

15 was extreme and outrageous and atrocious.

16 What were you referring to?

17 A Well, I would believe that would be referring to all the

18 FOIA requests, and, for instance, the one where I had to

19 print any e-mails that I had between Mr. Seebeck and myself,

20 which -- and I tend to keep everything, and it took me quite

21 a few hours to print everything for a certain time frame

22 that he wanted. I believe it was like October to December

23 or something. I'm not even sure of the exact dates. But it

24 took a lot of personal time.

25 Q Okay. And people have a right to make FOIA requests?


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1

1 A Absolutely.

2 Q Okay. So do you find that to be extreme and outrageous and

3 atrocious conduct, to ask for certain things?

4 A The number of FOIA requests is a bit extreme but --

5 Q The one that I'm referring to --

6 MR. WALLACE: Please let her answer.

7 Q I'm referring to --

8 A Well --

9 Q -- the one that you're talking about.

10 A It was a bit extreme, I felt, yes.

11 Q And why was that extreme?

12 MR. WALLACE: It wasn't a FOIA request, counsel.

13 Please don't confuse the record.

14 MR. HANSEN: I thought that's what she said. She

15 said that she was requested to turn over her e-mails.

16 MR. WALLACE: It was a discovery request.

17 Q It was a discovery request?

18 A I was asked to turn over certain e-mails from a certain time

19 frame, is what I'm referring to.

20 Q By whom?

21 A It was a FOIA request that Mr. Seebeck had asked all of us

22 Board members if we kept e-mails, any e-mails between the

23 School, himself, which I do. I keep all my e-mails.

24 Q Okay.

25 A So those are the ones that took me quite a number of hours


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1

1 to print and turn them in.

2 Q But under the law he's entitled to those, correct?

3 A Correct.

4 Q You just didn't like the fact that you had to put them all

5 together, right?

6 A Well, it took a lot of time.

7 Q I mean, that's why you were upset about it, the amount of

8 time you had to spend, right?

9 A Correct.

10 Q You've also accused him of willful and wanton misconduct.

11 What are you referring to there?


13 Q You've also accused him of abusing process in this case.

14 What are you referring to there?

15 MR. WALLACE: Form and foundation. That's a legal

16 term of art that you know relates to improperly filing

17 multiple lawsuits.

18 Q Do you know what you're referring to?

19 MR. WALLACE: Go ahead and answer if you can, if

20 you understand the question.

21 A I don't understand your question.

22 Q Well, you've sued him for abuse of process; you understand

23 that.

24 A Um-hum.

25 Q Yes?


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1

1 A Yes.

2 Q You have to answer yes so she can record it.

3 And you've made certain allegations there, you know.

4 What do you base these allegations on?

5 A I believe we're basing them on, just from the very

6 beginning, all the number of FOIA requests and all the

7 information that they're asking for, and then coming to the

8 Board meetings and recording them, which I know is

9 absolutely fine, they can do that, but that just seemed

10 automatically to start, well, recently, the past few months.

11 It's like why didn't they come a year ago and record, come

12 to the Board meetings before all this even started? Nobody

13 did. Sharman never did.

14 Q And so you don't --

15 A And that's what I don't understand. If they're interested

16 in coming now and recording, they should have been

17 interested two years ago and recording.

18 Q Well, there has to be a starting point sometime, doesn't

19 there?

20 A (No response.)

21 Q I mean, why not five years ago or ten years ago?

22 A Exactly, um-hum.

23 Q Do you find that offensive, to have them recording the --

24 A No, no. Not at all.

25 Q On the 24th did you consider any legal written opinion?


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1

1 A I don't recall.

2 Q And was Mr. Wallace there?

3 A It does not say he was there, no.

4 Q Was any other attorney there?

5 A No.

6 Q One of the things that's part of this lawsuit is FOIA

7 requests and also Open Meetings Act requests concerning

8 proposed minutes. Do you understand that?

9 A Um-hum.

10 Q Were you aware that there's a difference between proposed

11 minutes and approved minutes?

12 A Yes. We get minutes; we have to approve them at the Board

13 meeting, --

14 Q Right. And for --

15 A -- and they're draft until --

16 Q I'm sorry?

17 A They're draft until we approve them.

18 Q Okay. Let's call "proposed" and "draft" the same things,

19 okay?

20 A Okay.

21 Q And I'll refer to it as "draft", okay?

22 A Okay.

23 Q Are you aware that the Open Meetings Act requires that draft

24 minutes have to be provided eight working days after the

25 meeting?


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1

1 A No, I was not aware.

2 Q You understand that's what this lawsuit is all about, is the

3 failure to turn over these minutes according to the law.

4 A Correct.

5 Q Do you find any problem with that?

6 A No.

7 Q We've heard a lot of testimony about how the Board has never

8 talked about that first lawsuit, never deliberated that

9 first lawsuit or anything else.

10 Is that actually true, that nobody ever talked about

11 that lawsuit with each other or anything else?

12 MR. WALLACE: Form and foundation. You've asked

13 multiple questions.

14 Q Is it really true that nobody ever talked about that

15 lawsuit?

16 A I don't recall if we did or not.

17 Q Are there a lot of lawsuits against the school so this is

18 one of so many that you're not aware of the contents of it?

19 A No; we may have a few lawsuits, but it's not something we

20 spend day in and day out conversing amongst ourselves about.

21 Q Well, would it be unreasonable for the Board to discuss the

22 merits of the claim to decide how to resolve it?

23 MR. WALLACE: Form and foundation.

24 You can answer if you can.

25 A Okay, I -- I don't recall if we ever spent a lot of time


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1

1 discussing this amongst ourselves.

2 Q You could have discussed it; you just don't have specific

3 recollection?

4 A Correct.

5 Q I'm going to show you Seebeck Exhibit 2 and ask you to read

6 Definitions B(1). Just read it to yourself.

7 A Okay.

8 Q Now, from your reading of that, the definition of "member"

9 is the School District or the School Board, is that fair?

10 MR. WALLACE: I'm going to object. The document

11 speaks for itself and is as written.

12 Q Is that your understanding?

13 MR. WALLACE: Form and foundation.

14 Answer if you can, please.

15 A "Member means the School District" is what it says.

16 Q Now, if you agreed -- on the next page or two pages from

17 there, I believe it is, I guess it's three, there at the

18 bottom of the Page 3 and then on the next page, I believe --

19 is that 3 or 2, please?

20 A 3(a).

21 Q Yes.

22 A Okay.

23 Q So it's the member then that is supposed to notify the

24 insurance company, is that right?

25 A "Written notice to the pool", what is "the pool" referring


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1

1 to?

2 Q That's probably the insurance pool but --

3 A So what was your question again?

4 Q The question is: It's the member that's supposed to do the

5 notifying, correct?

6 MR. WALLACE: Same objection, and the contract

7 speaks for itself.

8 A Um-hum.

9 Q That's a yes?

10 A Yes. "The member shall give immediate written notice to the

11 pool of any claim made against a member."

12 Q And that would be the School District, right?

13 A Correct, I believe.

14 Q Did the Board ever authorize Mr. Seebeck to notify the

15 insurance company?

16 A We had given him our okay years ago to -- to do what he felt

17 was necessary, yes.

18 Q Necessary on what?

19 A On behalf of the School concerning lawsuits.

20 Q Do you recall when that was?

21 A No, I do not recall when. I don't have the document.

22 MR. WALLACE: Also, I'd indicate that you have

23 that document.

24 MR. HANSEN: The document that -- of the

25 authority?


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1

1 MR. WALLACE: Yes, sir.

2 MR. HANSEN: Is this the one you're referring to

3 (indicating)?

4 MR. WALLACE: I don't know. I just know you have

5 it.

6 MR. HANSEN: Would you mark this.

7 (Schwager Exhibit 1 was marked by the reporter.)

8 Q I'm showing you what's been marked as Schwager 1, which are

9 the Board minutes of June 23rd of 2008.

10 Drawing your attention to, I believe it's Page 3 of

11 that document under Action Item J.2(c), is that what you're

12 referring to?

13 A I'd have to read it. I was not --

14 Q Sure. Sure.

15 Have you had a chance to read that?

16 A Um-hum. It says that they approved SET SEG for the carrier

17 in the amount of 55,000.

18 Q Okay. That's the document that was supplied to us by your

19 counsel --

20 MR. WALLACE: There's other documents, counsel.

21 That's not the only document.

22 Q Well, that particular provision, all that does is, it

23 authorizes SET SEG to be your insurance company, correct?

24 A Yes, that's what that paragraph says.

25 Q It doesn't authorize Mr. Seebeck to act on your behalf, does


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1

1 it?

2 A This paragraph, no.

3 Q Okay. Are you aware of any statements about Rick that have

4 been made by Mr. Caffrey to any other Board members?

5 A I'm not aware.

6 MR. HANSEN: That's all I have.

7 (Deposition concluded at or about 3:35 p.m.)

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1

1 STATE OF MICHIGAN

2 COUNTY OF MIDLAND

3 I, Diane Kraynak, Notary Public in and for Midland

4 County, State of Michigan, acting in Gladwin County, State

5 of Michigan, do hereby certify that I stenographically

6 recorded the deposition of LISA SCHWAGER, the deponent in

7 the foregoing deposition; that prior to the taking of said

8 deposition the said deponent was duly sworn to tell the

9 truth, the whole truth, and nothing but the truth, and that

10 the foregoing deposition is a true and correct transcript of

11 the testimony of said deponent, to the best of my ability.

12 I further certify that I am not a relative, employee,

13 attorney or counsel of any of the parties, a relative or

14 employee of such attorney or counsel, or am financially

15 interested in the transaction.

16 I further certify that no request was made that the

17 foregoing deposition be submitted to the said deponent for

18 examination and correction by her or that she sign the same.

19

20

_________________________________________21 Diane Kraynak, CSR-2122

Certified Shorthand Reporter22 Registered Professional Reporter Notary Public, Midland County, Michigan23 My Commission Expires: 11-1-13

24

25


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LISA SCHWAGMay 29, 2

A

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Min-U-Script Mid-Michigan Reporting LLC (989)835-9171 (1) Absolutely - Gladw


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Schwager, Lisa Deposition