Phase Zero: Minority Bar Suppression and the Holmes Lawsuit

DOCUMENTED RECORD — PUBLIC-RECORDS REQUESTS PENDING

The City’s own minutes, a published appellate ruling, and a federal civil rights case that settled: how Racine’s liquor licensing committee treated minority-owned bars, told only from public records.

Featured question

Did the City of Racine hold minority-owned bars to a different licensing standard than white-owned bars?

Disclosure: read this first

The investigator who publishes this page, Jim Spodick, owned 500 Sixth Street and 522 Sixth Street during the events described and was Thomas Holmes’s landlord at Park 6. He has a direct interest in this story and readers are entitled to know it before reading a word of it.

He also worked with the plaintiffs’ lawyers as an investigator before and during Holmes et al. v. City of Racine. The defense asked the federal court to compel production of his emails with plaintiffs’ counsel, and the court addressed that request in an order of March 17, 2015. The City’s letter to the court about him is itself on the public docket (Doc. 132, filed March 10, 2015). He also led the Racine Equality Project. In the filed deposition of campaign aide Zak Williams (Doc. 235-1), the City’s lawyer used emails between Williams and the publisher about ethics complaints against Mayor Dickert to argue that Williams was biased. That exchange is summarized below and readers should weigh it. He produced the documentary Pattern or Practice (2014), which recorded the bar owners’ accounts before the lawsuit was filed.

For those reasons this page is built only from court records available on PACER, published state court decisions, City of Racine public records, and contemporaneous news reporting. Nothing on it comes from a plaintiff’s private file, and nothing on it depends on taking the publisher’s word for anything.

How to read this file

This is a citizen investigation into the City of Racine, organized in phases. Phase One is Machinery Row. This installment is Phase Zero, and it comes first in time. Between roughly 2006 and 2013, the City’s Public Safety and Licensing Committee, which controls who may hold a liquor license, is alleged in a federal lawsuit to have been used against minority-owned bars in ways white-owned bars in comparable situations were not.

Two standards are used on this page and they are kept apart.

• DOCUMENTED means an identified public record establishes it: a court decision, a docket entry, official City minutes, or published reporting of a public act.
• ALLEGED means it is a claim made in a court filing, almost always the plaintiffs’ February 25, 2014 complaint. A complaint is one side’s account. Nothing alleged in it was proved or disproved at trial, and the City admitted no wrongdoing when the case settled.

No person named on this page has been charged with any crime arising from this conduct. Every person named is presumed innocent.

The committee and the instrument

Under Wisconsin law a municipality controls liquor licensing. In Racine that authority sits with the Public Safety and Licensing Committee, made up of Common Council members, whose recommendations go to the full Council. The committee can renew a license, hold it out for nonrenewal, impose conditions, send a licensee to a “due process” hearing, and recommend suspension or revocation.

The first tool at the center of the case is the side agreement: written conditions a licensee signs to get or keep a license. The complaint alleges these included paid off-duty police or private security, camera systems, ID scanners, dress codes, a 25-and-older age limit, capacity caps, music restrictions (“no hip-hop”), early closing, and resurfacing parking lots, and that white-owned bars were rarely asked to sign them. (Alleged, Complaint ¶¶ 48–50.)

The second is the process itself. A licensee summoned again and again pays a lawyer each time and runs the business under a standing threat of losing it. The complaint alleges minority-owned bars were called before the committee almost twice as often as white-owned bars despite fewer police calls for fights, weapons and narcotics. (Alleged, Complaint ¶ 58.)

The one appellate ruling: Park 6

DOCUMENTED. Thomas Holmes ran Park 6 at 500 Sixth Street. In December 2010 the Racine police chief, Kurt Wahlen, filed a complaint seeking revocation of the Park 6 license, in his capacity as a private resident. He did not swear to it. The committee held a hearing, the Common Council revoked the license, and Holmes went to court.

Racine County Circuit Judge Bruce E. Schroeder vacated the revocation. The City appealed. In 2012 WI App 123 (No. 2011AP2282, decided October 2012), the Wisconsin Court of Appeals affirmed. It held that the missing oath was a fundamental defect, not a technicality, so the committee never had authority to proceed. The court said the oath requirement exists to make a complainant weigh the charges and to protect licensees from baseless harassment, and that a later full hearing could not repair a defective start.

That is a narrow holding about one license and one defective complaint. It is also the only appellate ruling in this record, and it went against the City.

The comparison in the City’s own minutes

DOCUMENTED. The committee’s official final minutes allow one direct comparison.

R & B Latin Club, 1600 Douglas Avenue (Item 12-8189). On October 9, 2012 the committee deferred the application and asked the applicant to return addressing members’ concerns. On October 23 the applicant came back with a petition of 41 signatures from neighboring residents and businesses. A motion to deny failed 2–2. A motion to approve, subject to a 25-and-older limit, written parking authorization from the neighboring business, a camera system keeping 30 days of footage, and paving and striping the lot by June 30, 2013, also failed 2–2. On the record, the district alderman said the petition signers may have been pressured and that the business would not be a good fit. Alderman Keith Fair said the applicant had done everything asked of her.

JFitz627, LLC, 1307 Douglas Avenue (Item 12-8368). On November 27, 2012, five weeks later and about three blocks away, a new Class B application was approved at a single meeting.

One applicant appeared twice, produced 41 supporters, accepted conditions on age, parking, cameras and paving, and still could not get a majority. The other appeared once and was approved. The minutes record what happened, not why, and a defender of the City would say the applications differed. Testing that requires the two license files, which are being requested.

The complaint adds two allegations about this stretch of Douglas Avenue: that the R & B Latin Club applicants were told by the Tavern League’s president that their joining “would hurt our reputation,” and that when a nearby Douglas Avenue bar sought a license under new white ownership, the Tavern League’s director told the committee that no member of the Tavern League has a license revoked. (Alleged, Complaint ¶¶ 137–138.)

The establishments, as alleged

The following are the plaintiffs’ allegations in the original federal complaint (Doc. 1, filed February 25, 2014; paragraph numbers refer to it). They are published because they are a public court filing. They are not findings, and the case ended in settlement without any of them being tested at trial.

• Cera’s Tequila Bar, 607 Sixth Street (Cerafin Davalos). Opened December 2006. Called to a due process hearing after a homicide the police department reported at Cera’s although, the complaint says, it happened about half a block away. The Council revoked the license on May 6, 2008. (¶¶ 97–100.)
• The Cruise Inn, 1423 State Street (Jose and Maria Maldonado). After a single non-life-threatening altercation in July 2006 the Council voted to take the bar to a due process hearing. The mayor at the time is alleged to have told Mr. Maldonado to sell because the license would be revoked and the property would soon be worthless, while the City fined the family for weeds and chipped paint. The family listed the bar for sale; the City then announced plans to buy both of their parcels for a combined $260,000. (¶¶ 91–96.)
• Viper’s Lounge, 501 High Street (Wilbur Jones). Called before the committee at least ten times from 2006 on. The Council declined to renew the license in November 2008. (¶¶ 101–105.)
• Ginger’s Lounge, 337 Main Street (Pythaphone Khampane and Omjai Nueakeaw). Signed a side agreement in September 2009 and reported spending more than $10,000 to comply. Before the March 30, 2011 hearing the owners were allegedly told they could keep the license if they stopped playing hip-hop and changed their patrons. They surrendered the license after the committee recommended revocation. (¶¶ 106–111.)
• The Place on 6th, 509 Sixth Street (Otha Keith Fair). Fair was a sitting alderman for part of this period. Called before the committee on 19 occasions. The complaint alleges a downtown landlord offered prospective tenants a rent discount if they would complain about The Place on 6th and Park 6. The license was revoked after an October 2012 hearing. (¶¶ 112–117.)
• Park 6, 500 Sixth Street (Thomas Holmes). Three due process hearings, multiple side agreements, a 45-day suspension in 2010, and City cameras aimed only at Park 6’s front and back doors. The revocation was overturned, as described above. Holmes vacated in December 2012. (¶¶ 118–130.)

The complaint sets these against white-owned bars, naming dates and places where shootings or large fights were followed by “received and filed,” no committee appearance at all, or license renewal. (¶¶ 68–87.) Each of those incidents should have a matching committee agenda or police record. Compiling them is the most valuable open records task in this phase.

The two federal lawsuits

DOCUMENTED. Davalos v. City of Racine, No. 2:08-cv-00712-LA (E.D. Wis.), was filed in 2008. On February 4, 2010 Judge Lynn Adelman’s minutes closed the file administratively because Mr. Davalos had no lawyer, noting he could notify the court if he wished to reopen it.

DOCUMENTED. Holmes et al. v. City of Racine, No. 2:14-cv-00208-JPS (E.D. Wis.), was filed February 25, 2014 by eight plaintiffs: Thomas Holmes, Otha Keith Fair, Pythaphone Khampane, Omjai Nueakeaw, Wilbur Jones, Cerafin Davalos, and Jose and Maria Maldonado. It pleaded claims under 42 U.S.C. §§ 1983 and 1985(3) and under the civil RICO statute against the City, two mayors, the police chief, aldermen, the Downtown Racine Corporation, the Racine City Tavern League and others. Judge J.P. Stadtmueller presided. The City’s lead defense firm was Meissner Tierney Fisher & Nichols. Seven of the eight plaintiffs settled.

DOCUMENTED: the settlement. On October 6, 2015 the Racine Common Council approved a settlement. The Associated Press reported that seven former tavern owners settled for more than $1 million, with the City’s insurer paying each plaintiff $15,000 and the remaining $1.2 million going to their attorneys. CBS 58 reported the total as $1.3 million. The defendants admitted no wrongdoing.

The exact settlement total is a public number that belongs on this page from a public record. The City’s settlement agreement and the Common Council’s October 6, 2015 action are being requested from the City. The figure will be stated to the dollar, with the record linked, when it arrives. Until then this page uses only the published range.

DOCUMENTED: the email search. During discovery the plaintiffs’ lawyers searched City employee email from June 2009 forward and told the court the results were “staggering.” In its own brief opposing further production, the City reported 436 hits for one racial slur. The City said most of those hits were police and public-safety documents quoting third parties and that some were spam. Both sides’ characterizations were reported by Courthouse News Service. The number is the City’s own; what it means was disputed and never decided.

Earlier H.O.T. materials described the figure as “436 racial slurs in City email” and cited “more than 40 Fifth Amendment invocations” in deposition. The first overstated what the record shows. The second has not been matched to a public court record and is withdrawn until it is.

The campaign-contribution testimony

DOCUMENTED: what was said under oath. Mayor John Dickert was deposed in Holmes on July 10 and July 30, 2015. The plaintiffs filed both transcripts with the federal court on September 28, 2015 as Exhibits 15 and 16 to Document 229 (Docs. 229-6 and 229-7). They are public court records. Both volumes are being posted on this page in full so readers can check every page cited here.

That a statement was made under oath is documented. Whether it is true is not. The case settled before trial, no court ever weighed this testimony, and no one was charged with anything arising from it.

Who handled the money in 2009

Dickert testified that in his 2009 campaign Greg Bach was campaign manager, Zak Williams was the paid finance director and fundraiser, and Mary Jerger (Osterman) was the volunteer treasurer. (Vol. 1, pp. 35–36.) He testified that he rarely reviews his campaign finance reports, relies on his treasurer and finance chair to keep contributions within the law, and described his own role this way: “My job is to raise money.” He put the 2009 individual limit at roughly $800 and said he had no idea what the cash limits were. (Vol. 2, pp. 338–347.)

He testified that a 2009 fundraiser was held at the Ivanhoe, owned by Doug Nicholson, and named Nicholson, J.J. McAuliffe and Joey LeGath as bar owners who had given to his campaigns. He said he did not know who belonged to the Tavern League, and that the Tavern League had endorsed his 2009 opponent. (Vol. 2, pp. 351–355, 373.)

The cash allegations, and the denials

Plaintiffs’ counsel questioned Dickert from a recorded statement Zak Williams gave to plaintiffs’ lawyers in November 2013. That statement was not sworn and was not cross-examined; defense counsel objected to its use throughout. It is not published on this site. What follows is only what was read or described on the record in Dickert’s filed deposition, and it is attributed to Williams, not established. (Williams’s later sworn deposition is covered in the next section.)

• That Dickert sent Williams to the Ivanhoe to collect $1,000 in bank-wrapped $100 bills from Nicholson, which was to be explained as money tossed into a jar on the bar, and that the cash was reported as smaller contributions spread across several names. (Vol. 2, pp. 356–366.)
• That after the April 2009 primary Dickert asked him to get another $1,000 from Nicholson, which he did. (Vol. 2, pp. 373–376.)
• That LeGath and other bar owners dropped off envelopes of $100 bills for the campaign. (Vol. 2, pp. 369–373.)

Dickert denied all of it under oath. He testified he did not recall sending Williams for cash, denied being shown the money, and said, “Zak lied.” He said Williams had a personal vendetta against him, and that if Williams had taken such contributions, Williams broke the law without his knowledge. (Vol. 2, pp. 364–377.)

In one question, plaintiffs’ counsel stated that Nicholson had invoked the Fifth Amendment when asked about these events. Dickert said he did not know that. Nicholson’s own transcript is not part of this record, so that statement is counsel’s, not a documented fact on this page. (Vol. 2, pp. 361, 375.)

Zak Williams under oath

DOCUMENTED: what was said under oath. Williams was deposed on September 2, 2015, with his own lawyer present, and was cross-examined by the City’s counsel. The transcript was filed with the court on September 28, 2015 (Doc. 235-1) and is a public court record.

On direct examination, Williams testified that he was the campaign’s first paid staff member in 2009; that in campaign strategy meetings Dickert said the bars west of Main Street needed to leave; that he understood Dickert to be referring to Black patrons; and that the campaign made no outreach to the African-American community. (Doc. 235-1, pp. 43, 50, 56–58.) On cross-examination he agreed that Dickert never told him he was uncomfortable around African-Americans, and that the campaign’s press release, newspaper questionnaire and fundraising letter, which he helped write, said nothing about bars. (pp. 86–91.)

Plaintiffs’ counsel did not walk Williams through the cash pickups described in his 2013 statement. The cash came up on cross-examination. Asked why he had written in 2011 that he wanted to see Dickert in federal prison, Williams answered that Dickert “had me go pick up cash for his campaign.” He also testified that he was the source of an allegation, passed to the publisher in 2013, that Doug Nicholson made illegal contributions to Dickert’s campaign on three occasions. (pp. 276–277, 281–282.) That is sworn testimony. It is still one person’s account, and Dickert denied it under oath.

What the cross-examination showed. The City’s lawyer spent much of the day on Williams’s motives, and the record should be read with that in view:

• He testified that he fell out with Dickert in the fall of 2009 over the City’s handling of a West Racine project for his client Tom Tousis, and that he still dislikes Dickert. (pp. 93–110.)
• He agreed he had worked against Dickert: an independent-expenditure campaign in 2011, a client who ran against him in 2015, talks with a reporter, and anonymous comments online meant to create negative information about the mayor. (pp. 111–113, 316–318.)
• He testified he did paid design work for the publisher’s Racine Equality Project, gave the publisher advice on ethics and state complaints against Dickert, and agreed that one effort’s objective was negative attention for the mayor. He also agreed he thought the group sometimes focused on “petty little rumors.” (pp. 278–291.)
• He testified he was paid nothing for his statement or testimony beyond travel expenses. (p. 98.)

Williams’s account and Dickert’s denial were never tested before a jury. This page does not decide between them.

What the campaign’s own reports show

DOCUMENTED. Dickert identified two 2009 campaign finance reports, signed by his treasurer and filed with the City Clerk (deposition Exhibits 243 and 244). Walking through them, he agreed they list identical $50 contributions from Doug Nicholson and from Sarah Nicholson on April 7, 10, 13, 23 and 27, 2009, and that several year-to-date totals were not updated, which he called mistakes. Asked whether that pattern fit Williams’s account of cash being spread across names, he answered that the Nicholsons may simply have given $50 at a time. (Vol. 2, pp. 377–384.) The reports themselves are public filings and are being requested from the City Clerk so they can be posted directly.

The Tousis account

Plaintiffs’ counsel also put to Dickert the deposition of businessman Tom Tousis, who testified that Dickert gave him a mason jar bearing a “John Dickert for Mayor” sticker, that Williams picked it up once filled with cash, and that Dickert made clear the contribution would not be reported. Dickert denied each point and called Tousis and Williams “two pathological liars,” saying both were angry after a Tousis development did not receive City support. (Vol. 2, pp. 384–400.)

Counsel showed him an April 22, 2009 email in which campaign manager Greg Bach told Williams to call Tousis, and Williams replied that he would pick something up from him the next day. Dickert said he did not know the email’s origin or purpose. (Exhibit 1574; Vol. 2, pp. 402–407.) The email is described here only as it appears in the filed transcript.

The loans

Dickert testified that he may have received $5,000 personal loans in 2009 from his brother and from Boyd Frederick, and he agreed his campaign reports show loans from him to his campaign of $4,000 on March 31, $1,000 on April 22 and $5,000, a total of $10,000. Asked whether he had passed the personal loans through to the campaign, he called that “a bad assumption” and said he did not recall it. He explained that family sometimes helped out while he waited on real estate closing checks. (Vol. 2, pp. 415–422.)

What this testimony does not establish

It does not establish that any contribution was illegal or that anyone knew of one. Williams’s detailed 2013 account was unsworn; his sworn testimony was brief on the cash and was heavily challenged for bias. Tousis’s account was sworn but disputed. Dickert denied both under oath. No regulator, prosecutor or court has made any finding about the 2009 campaign. Every person named is presumed innocent. The testimony is published because it is a public court record of what was said, under oath, about how a mayoral campaign was financed while the City’s licensing practices were being challenged.

Why this is Phase Zero

Phase Zero is told here as a civil rights story that stands on its own. It is also the earliest record of patterns that recur in later phases:

• The same defense firm. Meissner Tierney Fisher & Nichols represented the City in Holmes and appears again in the Machinery Row litigation.
• The same named officials across cases. City officials named in the 2008 Davalos case are named again in the 2017 federal complaint arising from Machinery Row.
• Relocation. The Maldonado allegations describe a City acquisition of a minority-owned licensed property after a revocation threat. Whether federal money and federal relocation duties were involved is unknown; the acquisition file is being requested. Missing relocation benefits are the central documented finding of Phase One.

Watch: Pattern or Practice (2014)

The documentary recorded the bar owners’ own accounts before the federal suit was filed. It runs 1 hour 11 minutes. Watch it here, or on IndieFlix and Prime Video. It is the publisher’s own work and is offered as a record of what was said, not as proof that it was true.

Key findings

Documented

• A1. Two federal civil rights suits arose from Racine liquor licensing: Davalos, No. 2:08-cv-00712-LA (2008), and Holmes, No. 2:14-cv-00208-JPS (filed Feb. 25, 2014). PACER.
• A2. The Davalos case was closed administratively for want of an attorney, not dismissed on the merits, with leave to reopen. Davalos Doc. 25, Feb. 4, 2010.
• A3. Holmes was filed by eight plaintiffs who had owned six minority-owned bars, against the City, Mayor John Dickert, former Mayor Gary Becker, Police Chief Kurt Wahlen, seven current or former aldermen, the Downtown Racine Corporation, the Racine City Tavern League and others. Complaint, Doc. 1.
• A4. Meissner Tierney Fisher & Nichols represented the City and Mayor Dickert in Holmes. Counsel of record.
• A5. The Common Council approved a settlement on Oct. 6, 2015: $15,000 to each of seven plaintiffs from the City’s insurer and about $1.2 million to their attorneys, a total reported as “more than $1 million” (AP) and $1.3 million (CBS 58). No admission of wrongdoing. Exact total awaits the City’s record.
• A6. The City itself told the court an email search found 436 hits for one racial slur, and argued most were third-party quotations in police documents or spam. City’s 2015 brief, as reported by Courthouse News Service.
• A7. The Park 6 revocation rested on the police chief’s unsworn complaint; the Court of Appeals held that a fundamental defect. 2012 WI App 123.
• A8. R & B Latin Club, 1600 Douglas Ave.: deferred Oct. 9, 2012; returned with 41 supporting signatures; deadlocked 2–2 on denial and 2–2 on conditional approval on Oct. 23, 2012. PSL minutes, Item 12-8189.
• A9. JFitz627, LLC, 1307 Douglas Ave., about three blocks away: approved at a single meeting on Nov. 27, 2012. PSL minutes, Item 12-8368.
• A10. Mayor Dickert’s two deposition volumes, filed with the court on Sept. 28, 2015 (Docs. 229-6, 229-7), record him being questioned under oath about cash contributions in his 2009 campaign. He denied every allegation. His campaign’s own reports, which he identified, list identical $50 contributions from Doug and Sarah Nicholson on five dates in April 2009. Former finance director Zak Williams testified under oath that Dickert “had me go pick up cash for his campaign”; he was cross-examined at length on his hostility toward Dickert. Docs. 229-6, 229-7, 235-1; deposition Exhibits 243–244.

Alleged in the federal complaint (unproven)

These are the plaintiffs’ allegations in the original Holmes complaint. The case settled; none was tested at trial, and the City denied wrongdoing.

• B1. That from 2006 to June 2013 minority-owned bars, and white-owned bars with minority patrons, were almost the only bars forced into side agreements or due process hearings. (¶¶ 55–57)
• B2. That shootings, a homicide and large fights at named white-owned bars were “received and filed,” never brought before the committee, or followed by routine renewal. (¶¶ 68–87)
• B3. That City cameras costing about $10,000 were aimed only at Park 6’s doors. (¶ 122)
• B4. That a downtown landlord offered prospective tenants a rent discount to complain about Park 6 and The Place on 6th. (¶ 113)
• B5. That the Ginger’s Lounge owners were told they could keep their license if they stopped playing hip-hop and changed their patrons. (¶ 110)
• B6. That Tavern League members gave to the mayor’s campaigns above legal limits in exchange for official favor. (¶¶ 41–44) An allegation only. No court, prosecutor or regulator has made any such finding.

What this investigation does not know

• The exact settlement total from the City’s own record. Being requested.
• The committee and police records for the white-owned bar incidents in B2. Not yet compiled.
• Why the two Douglas Avenue applications were treated differently. License files being requested.
• Whether federal funds were used to acquire the Cruise Inn property, and whether relocation benefits were owed. Acquisition file being requested.
• Whether any outside authority ever reviewed these practices. None is known.

What the evidence does not establish

The minutes show outcomes, not motives. The Court of Appeals ruling concerns one license and one defective complaint, not a pattern. The complaint is one side’s account. The settlement is not an admission. The documentary is the publisher’s own work. This page asks whether the City applied one standard; it does not claim a court has found that it did not.

Evidence library

• E-1. Davalos minutes of conference, Feb. 4, 2010 (Doc. 25), PACER.
• E-2. PSL Committee minutes, Item 12-8189, Oct. 9 and 23, 2012 (final). The City’s own record; the strongest single document in Phase Zero.
• E-3. PSL Committee minutes, Item 12-8368, Nov. 27, 2012 (final).
• E-4. Park 6 LLC v. City of Racine, 2012 WI App 123.
• E-5. Holmes Complaint, Doc. 1 (Feb. 25, 2014); order of July 30, 2014 (Doc. 60); order of March 17, 2015.
• E-6. AP via Wisconsin Law Journal, Oct. 7, 2015; CBS 58, Oct. 7, 2015; Fox6.
• E-7. Courthouse News Service on the 2015 discovery briefing.
• E-8. Pattern or Practice (2014).
• E-9. Deposition of John Dickert, Vol. 1 (July 10, 2015), Holmes Doc. 229-6, filed Sept. 28, 2015.
• E-10. Deposition of John Dickert, Vol. 2 (July 30, 2015), Holmes Doc. 229-7, filed Sept. 28, 2015.
• E-11. City’s letter to Judge Stadtmueller regarding the publisher, Holmes Doc. 132, filed March 10, 2015.
• E-12. Deposition of William Zachary Williams (Sept. 2, 2015), Holmes Doc. 235-1, filed Sept. 28, 2015.

Verification priorities

• R-1. Settlement agreement and Council action of Oct. 6, 2015. City of Racine.
• R-2. License files for 1600 and 1307 Douglas Avenue, 2012. City of Racine.
• R-3. Committee agendas, minutes and police reports for the white-owned bar incidents in Complaint ¶¶ 68–87. City; Racine PD. Highest value.
• R-4. Executed side agreements, 2008–2012. City of Racine.
• R-5. Acquisition file, 1423 State Street. City / Redevelopment Authority.
• R-6. Holmes 2015 discovery briefs and stipulation of dismissal. PACER.
• R-7. PSL Committee video, Nov. 27, 2012. City of Racine.
• R-8. Dickert for Mayor campaign finance reports, 2009 (deposition Exhibits 243, 244). City Clerk.

What is not used, and why

Nothing from a plaintiff’s private file. The 2015 settlement bars the plaintiffs from knowingly helping anyone pursue claims against the City using information obtained in the lawsuit. To keep every plaintiff clear of that clause, this page uses no document that came from a plaintiff: no settlement papers, payment records, releases, or correspondence. No unpublished interview notes: accounts that do not also appear in a public court filing are not used. No criminal statute labels: no one has been charged. No private contact details. Audit, purchasing-card and False Claims Act material is a separate matter and is not part of this file.

H.O.T. Government’s position

Every factual statement on this page is tied to an identified public record or labeled as an allegation. Corrections are published here with a dated note, not quietly edited. If you can document that something is wrong, write to hotgovernment@gmail.com. Anyone named may send a response and it will be published in full alongside the material it concerns.

No person named here has been charged with any crime arising from this conduct. Every person named is presumed innocent.